Attachment Intelsat - Grant Jul

Intelsat - Grant Jul

DECISION submitted by IB,FCC

Grant

2012-07-12

This document pretains to SAT-RPL-20120326-00061 for Replacement Application on a Satellite Space Stations filing.

IBFS_SATRPL2012032600061_959429

                                          1B2012000901
$2863       SAT-RPL-20120326-0
                               0061
                                                                                     ‘Ffle# sat—RPL— 20120 326—0006
Intelsat License LLC
INTELSAT 21
                                                                                     Call Sign 32863 GrantDate_O7/12. /12.
                                                                                     (or other identifier)
                                                                                         .‘ See                Term Dates SCC _            Approved by OMB
                                                                                     From _eonditions                    q.; conditions          3060—0678
                                                                GRANTED *
  Date & Time Filed: Mar 26 2012 9:24:36:763PM                International Bureau   Approved:
  File Number: SAT—RPL—20120326—00061                    *with conditions                                    Stepheq/J     . Dual)     :
  Callsign/Satellite ID: $2863                                                                               Cinief, Satellite Po\ichmnch

                         APPLICATION FOR SATELLITE SPACE STATION AUTHORIZATIONS                                             FCC Use Only
                                            FCC 312 MAIN FORM
                                          FOR OFFICIAL USE ONLY


  APPLICANT INFORMATION
  Enter a description of this application to identify it on the main menu:
  Authority to Launch and Operate Replacement Satellite, Intelsat 21, at 58.0 W.L.
    1—8. Legal Name ofApplicant
              Name:          Intelsat License LLC                   Phone Number:                               202—944—7848
              DBA Name:                                             Fax Number:                                 202—944—7870
              Street:        c/o Intelsat Corporation               E—Mail:                                     susan.crandall@intelsat.com
                             3400 International Drive, N.W.

              City:          Washington                             State:                                       DC
              Country:       USA                                   Zipcode:                                     20008          —3006
              Attention:     Susan H. Crandall


                                          Attachment to Grant
                               IBFS File No. SAT—RPL—20120326—00061
                                            Call Sign $2863

The application of Intelsat License LLC (Intelsat) for authority to construct, launch and operate a
geostationary orbit space station, to be known as Intelsat 21, at the 58.0° W.L. orbital location, IBFS File
No. SAT—RPL—20120326—00061, IS GRANTED. Accordingly, Intelsat is granted authorityto operate
Intelsat 21 at the 58.0° W.L. orbital location to provide Fixed—Satellite Services (FSS) in the 3700—4200
MHz (space—to—Earth), 5925—6425 MHz (Earth—to—space), 11.45—11.7 GHz (space—to—Earth), 11.7—12.2
GHz (space—to—Earth) and 14.0—14.5 GHz (Earth—to—space) frequency bands. In addition, Intelsat is
authorized to conduct telemetry, tracking, and command (TT&C) operations at 58.0° W.L. using the
following center frequencies: 11451.25/11453.25 MHz (space—to—Earth), 11451.75/11453.75 MHz (space—
to—Earth), and 13750.5 MHz /13994.5 MHz (Earth—to—space). Operations under this grant shall be in
accordance with the technical specifications set forth in Intelsat‘s application, Federal Communications
Commission (Commission) rules not waived herein, and are subject to the following conditions:
         1.      Intelsat shall prepare the necessary information, as may be required, for submission to the
International Telecommunication Union (ITU) to initiate and complete the advance publication,
international coordination, due diligence, and notification process of this space station, in accordance with
the ITU Radio Regulations. Intelsat shall be held responsible for all cost—recovery fees associated with
ITU filings. We also note that no protection from interference caused by radio stations authorized by
other administrations is guaranteed unless coordination and notification procedures are timely completed
or, with respect to individual administrations, by successfully completing coordination agreements. Any
radio station authorization for which coordination has not been completed may be subject to additional
terms and conditions as required to effect coordination of the frequency assignments of other
administrations. See 47 C.F.R. § 25.111(b).
       2.      In connection with the provision of service in any particular country, Intelsat is obliged to
comply with the applicable laws, regulations, rules, and licensing procedures of that country.
         3.     Intelsat shall operate Intelsat 21 at the 58.0° W.L. in compliance with all existing or
future coordination agreements for this location.
         4.      While at the 58.0° W.L. orbital location, Intelsat shall maintain the Intelsat 21 space
station with an east/west longitudinal station—keeping tolerance of +/— 0.05 degrees.
         5.       Intelsat‘s request for a waiver of Section 25.210(a)(3) of the Commission‘s rules, 47
C.ER. § 25.210(a)(3), IS GRANTED. Section 25.210(a)(3) requires all FSS space stations used for
domestic service in the 3700—4200 MHz and 5925—6425 MHz bands to be capable of switching
polarization sense upon ground command. The Commission requires polarity—switching capability for
two reasons: (1) to provide U.S.—licensed satellites with the flexibility to operate at differentorbital
locations, and (2) to mitigate potential interference between adjacent fixed—satellite systems transmitting
analog television signals. This waiver grant is based upon a finding that the ability to switch polarization
is not currently necessary to protect other satellites at adjacent orbital locations from harmful interference,
because there is no co—frequency C—band space station operating within two degrees of Intelsat‘s proposed
location. Intelsat states that the nearest co—frequency C—band space stations are Intelsat 707 located at 53°
W.L., Intelsat 805 and Galaxy 11, both located at the nominal orbital location of 55.5° W.L., and
Amazonas—1 and 2, located at 61° W.L.‘ As a condition to the grant of this waiver, Intelsat must
accommodate future satellite networks that are compliant with Section 25.210(a)(3). Further, Intelsat
must operate Intelsat 21 pursuant to any existing or future coordination agreements for this location.
         6.      Intelsat‘s request for a waiver of Section 25.210(i)(1) of the Commission‘s rules, 47
C.E.R. § 25.210(i)(1), IS GRANTED. Section 25.210(i)(1) requires that satellites be designed to provide
a cross—polarization isolation such that the ratio of the on—axis co—polar gain to the on—axis cross—polar

‘ Legal Narrative at 5; Engineering Statement at pages 4 and 5.


                                           Attachment to Grant
                                IBFS File No. SAT—RPL—20120326—00061
                                             Call Sign $2863

gain of the antenna in the assigned frequency band will be at least 30 dB within its primary coverage area.
Intelsat states that the 30 dB requirement is not met within a limited portion of the coverage areas of the
Intelsat 21‘s West Hemi vertically polarized receive beam." Intelsat states that the level of isolation of the
non—compliant Intelsat 21 beam has a cross—polarization isolation of at least 27 dB within limited regions
of its primary coverage area." Intelsat reports that this level was the best that the satellite manufacturer
could achieve without causing excessive degradation in the co—polarized gain of the beam and/or in the
size of its coverage area." We agree that waiver in this instance will not produce a significant increase in
interference, except to the applicant itself. As a condition to the grant of this waiver, Intelsat shall claim
no more protection from interference from other licensed radio—communication systems operating in
accordance with the Commission‘s rules than if its antennas met Section 25.210(i) of the rules.
         7.        Intelsat‘s request for a waiver of Section 25.202(g) of the Commission‘s rules, 47 C.F.R.
§25.202(g), IS GRANTED. Section 25.202(g) requires "telemetry, tracking and telecommand (TT &C)
functions for U.S. domestic satellites shall be conducted at either or both edges of the allocated band(s).
Frequencies, polarization and coding shall be selected to minimize interference into other satellite
networks and within their own satellite system." Intelsat requests this waiver for the proposed use of
13750.5 MHz and 13994.5 MHz for command frequencies that are outside of the 14.0—14.5 GHz portion
of the satellite‘s Ku—band payload. This waiver grant is based upon the following findings:
                  (a) Operation of Intelsat 21‘s command frequencies in the 14.0—14.5 GHz band at the
                  nominal 58° W.L. orbital location will increase the risk of interference with the
                  operations of Intelsat 16 and, for a period of time, Intelsat 9, which currently operate in
                  the 14.0—14.5 GHz band at the nominal 58° W.L. orbital location.

                  (b) Intelsat has previously coordinated the use of 13.75—14.0 GHz at the nominal 58°
                  W.L. orbital location.
As a condition to grant of this waiver, Intelsat must accommodate future space station networks that are
compliant with Section 25.202(g). Further, Intelsat must operate Intelsat 21 pursuant to any existing or
future coordination agreements for this location.
         8.       Pursuant to footnote US337 of the United States Table of Frequency Allocations, 47
C.F.R. § 2.106, any earth station in the United States and its possessions (US&P) communicating with the
Intelsat 21 space station in the 13.75—14.0 GHz frequency band (Earth—to—space) is required to coordinate
through National Telecommunications and Information Administration‘s (NTIA‘s) Interdepartment Radio
Advisory Committee‘s (IRAC‘s) Frequency Assignment Subcommittee (FAS)."
         9.      Operations of any earth station in the US&P communicating with the Intelsat 21 space
station in the 13.75—14.0 GHz frequency band (Earth—to—space) shall comply with footnote US356 to
United States Table of Frequency Allocations, 47 C.F.R. § 2.106, which specifies a minimum antenna
diameter of 4.5 meters and a minimum and maximum equivalent isotropically radiated power (e.i.r.p.).°

> Legal Narrative at 4; Engineering Statement at pages 6 and 7, and Exhibit 5D.
* Engineering Statement at 6.
* 1d.
° Footnote US337 requires that earth stations operating in the 13.75—13.8 GHz frequency band shall be coordinated
through NTIA‘s IRAC‘s FAS to minimize interference to the forward space—to—space link of the National
Aeronautics and Space Administration Tracking and Data Relay Satellite System. 47 C.F.R. § 2.106, US337.
© Footnote US356 places a restriction on a minimum antenna diameter of 4.5 meters and the e.i.r.p. that should be on
FSS operations in order to protect government operations in the band, including manned space flight. 47 C.F.R. §
2.106, US356.


                                           Attachment to Grant
                                IBFS File No. SAT—RPL—20120326—00061
                                                 Call Sign $2863

Operations of any earth station located outside the US&P communicating with the Intelsat—16 space
station in the 13.75—14.0 GHz frequency band (Earth—to—space) shall be consistent with footnote 5.502 to
the ITU Radio Regulations, which allows a minimum antenna diameter as small as 1.2 meters for earth
stations of a geostationary satellite orbit network.‘
        10.    Operators of earth stations accessing the Intelsat 21 space station in the 13.75 — 14.0 GHz
frequency band are encouraged to cooperate voluntarily with the National Aeronautics and Space
Administration (NASA) in order to facilitate continued operation of NASA‘s Tropical Rainfall Measuring
Mission (TRMM) satellite.>
         11.     Intelsat‘s request for waivers of footnote NG104 of the United States Table of
Allocations, 47 C.F.R. § 2.106, and of footnote 2 to Section 25.202(a)(1) of the Commission‘s rules, 47
C.F.R. § 2.202(a), in order to use the 11.45—11.70 GHz frequency band to offer domestic services on a
non—interference basis in the United States ARE GRANTED, as conditioned." We find that waiver does
not undermine the purpose of the rules because the waiver involves only earth stations that are receive—
only in the 11.45—11.70 GHz frequency band and thus are not capable of causing interference into fixed
stations operating in this band. Furthermore, because Intelsat has agreed to accept any level of
interference from fixed stations into its receive—only earth stations‘ operations in these bands, fixed station
operators are not be required to coordinate their station operations with the space station operator‘s
receive—only earth stations‘ operations.‘" Under these circumstances, we determine that an additional
coordination burden is not placed upon fixed station operators and their ability to expand service in the
future would not be restricted in any manner."‘
         12.      Intelsat shall operate its earth stations in the 11.45—11.70 GHz band that provide domestic
service in the United States on an unprotected, non—interference basis relative to fixed stations and, as
such, Intelsat may not cause harmful interference to, or claim protection from, fixed stations to which



‘ Footnote 5.502 to the ITU Radio Regulations establishes minimum antenna diameters for earth stations of
geostationary and non—geostationary satellite networks, and places certain restrictions on either the minimum e.i.r.p.
or the power flux density (p.f.d.) levels produced by earth stations operating in the 13.75—14.0 GHz frequency band.
8 NASA‘s TRMM satellite system radar in the 13.793—13.805 GHz frequency band remains operational and is a
highly valuable and visible United States asset with a broad range of international users. Accordingly, NTIA has
requested cooperation from the Commission and non—Federal Government entities in providing assistance in
reducing interference with the TRMM radar. Specifically, NTIA requests that FSS earth stations in the 13.793 —
13.805 GHz frequency band located south of 39° N. and east of 110° W. operate with emission levels below —1 50
dBW/600 kHz at the TRMM space station receiver. Letter from Frederick R. Wentland, Acting Associate
Administrator, Office of Spectrum Management, NTIA, to Don Abelson, Chief, International Bureau, FCC
(February 28, 2002). Considering the secondary nature of the TRMM operation, NTIA‘s request is not a condition
of this authorization. The Commission, however, urges all operators of earth stations accessing the Intelsat 21 space
station in the 13.75 — 14.0 GHz frequency band to cooperate voluntarily with NASA in order to facilitate continued
operation of the TRMM satellite.
° The Commission previously granted a waiver of Footnote NG104 to permit domestic operations in the 11.45—11.7
GHz band at 58° W.L. via Intelsat 9 — the satellite that will be replaced by Intelsat 21. See PanAmSat Licensee
Corp., Application for Authority to Use Extended Ku—band Frequencies for Domestic Service, Order and
Authorization, 20 FCC Red 14642 (Int‘l Bur. 2005). The conditions placed on the domestic operations of Intelsat 21
in the 11.45—11.7 GHz frequency band are the same as those that were placed on the domestic operations of Intelsat
9 in this band.
9 See Legal Narrative at 7 and 8.
4 See id., 20 FCC Red at 14646.


                                        Attachment to Grant
                             IBFS File No. SAT—RPL—20120326—00061
                                          Call Sign $2863

frequencies in the 11.45—11.70 GHz band have either already been assigned, or to which frequencies in
the 11.45—11.70 GHz band may be assigned at a later date.
         13.      Intelsat is required to inform its customers, in writing, including end—users receiving
service from resellers accessing capacity on the Intelsat 21 space station, that domestic service in the
United States in the 11.45—11.70 GHz band is being provided on an uncoordinated basis, and that the
potential exists that future—licensed fixed stations may cause harmful interference to these unprotected
earth stations.
         14.     Intelsat‘s use of the 11.45—11.7 GHz frequency band is subject to footnote US211 to the
United States Table of Frequency Allocations, 47 C.F.R. § 2.106, US211, which urges applicants for
airborne or space station assignments to take all practicable steps to protect radio astronomy observations
in the adjacent bands from harmful interference, consistent with footnote US74.
         15.      Operations of Intelsat 21 to or from the United States shall comply with the power levels
specified in Section 25.212 of the Commission‘s rules, 47 C.F.R. § 25.212, unless Intelsat coordinates
any operations using power levels exceeding the levels in Section 25.212 with all potentially affected
adjacent satellites within 6 degrees orbital separation of the 58.0° W.L. orbital location. Intelsat shall
inform the Commission of the power levels it has coordinated. In addition, Intelsat must inform all
affected earth station operators that Section 25.220 of the Commission‘s rules applies to operations that
exceed the power levels specified in Section 25.212. In no event shall the uplink power density level of
Intelsat 21‘s digital carriers exceed —38.7 dBW/Hz and the downlink EIRP density of such carriers exceed
—31.2 dBW/Hz for the C—band. Further, in no event shall the uplink power density of Intelsat 21‘s digital
carriers in the 11450—11700 MHz band exceed —20 dBW/Hz and in the 11700—12200 band exceed —20
dBW/Hz for the Brazilian beam and —18.9 dBW/Hz for the Mexico beam.
         16.     Intelsat 21 must begin providing service at the 58.0° W.L. orbital location in the 3700—
4200 MHz (space—to—Earth), 5925—6425 MHz (Earth—to Space), 11.45—12.2 GHz (space—to—Earth), and
14.0—14.5 GHz (Earth—to—space) frequency bands before the satellite it is replacing, Intelsat 9 (Call Sign
$2380), discontinues service at the 58.0° W.L. orbital location. Failure to meet this milestone shall render
this authorization to operate in these frequency bands NULL and VOID.
          17.     The license term for the space station is 15 years and will begin on the date that Intelsat
certifies to the Commission that Intelsat 21 has been successfully placed into orbit and its operations fully
conform to the terms and conditions of this authorization. Intelsat is directed to file its certification of
commencement of operation with the Commission within five business days of Intelsat 21 being placed
into operation at the 58.0° W.L. orbital location.
         18.     Intelsat is afforded 30 days from the date of release of this grant and authorization to
decline this authorization as conditioned. Failure to respond within this period will constitute formal
acceptance of the authorization as conditioned.
        19.      This action is issued pursuant to Section 0.261 of the Commission‘s rules on delegated
authority, 47 C.F.R. § 0.261, and is effective immediately. Petitions for reconsideration under Section
1.106 of the Commission‘s rules or applications for reconsideration under Section 1.115 of the
Commission‘s rules, 47 C.F.R. §§ 1.106, 1.115, may be filed within 30
                                                                    days of the pubhc notice
indicating that this action was taken.                         m                                                  .
                                                                   File# SQT—RPL- 2012032_@-000(o|

                                                                    Call Sign $2¢W3 GrantDate O7/12. h2
                                                                    (or other identifier)
                                                                           see              Term Dates See ||
                                                                    From cenditions              To —condifions

                                                                    Approved:
                                            *’wnfl\cgndeS


  9—16. Name of Contact Representative
            Name:            Intelsat License LLC                  Phone Number:                        202—944—7848
            Company:         Intelsat Corporation >                Fax Number:                          202—944—7870
            Street:          3400 International Drive, N.W.        E—Mail:                              susan.crandall@intelsat.com



            City:            Washington                            State:                               DC
            Country:         USA                                   Zipcode:                             20008     —3006
            Attention:       Susan H. Crandall                     Relationship:                        Legal Counsel


CLASSIFICATION OF FILING
17. Choose the buttonnext to the                   b.
classification that applies to thisfiling for    g4 b1. Application for License of New Station
both questions a. and b. Choose only one
                                                 (N/A) b2. Application for Registration of New Domestic Receive—Only Station
for 17a and only one for 17b.                    (N/A) b3. Amendment to a Pending Application
                                                 (N/A) b4. Modification of License or Registration
  a.                                             (N/A) b5. Assignment of License or Registration
(N/A) al. Earth Station                          (N/A) b6. Transfer of Control of License or Registration
  «) a2. Space Station                           (N/A) b7. Notification of Minor Modification
                                                 (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed Satellite

                                                 C3 b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States
                                                ) b10. Replacement Satellite Application — no new frequency bands
                                                4 b11. Replacement Satellite Application — new frequency bands (Not eligible for streamlined
                                                processing)
                                                g£3 b12. Petition for Declaratory Ruling to be Added to the Permitted List
                                                (N/A) b13. Other (Please specify)


  17¢. Is a fee submitted with this application?
@ IfYes, complete and attach FCC Form 159.
  If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
  £4 Governmental Entity        g3, Noncommercial educational licensee
g4 Other(please explain):

17¢. Fee Classification     BNY — Space Station (Geostationary)


18. If this filing is in reference to an existing station, enter:

(a) Call sign of station:
    Not Applicable




19. If this filing is an amendment to a pending application enter:
(a) Date pending application was filed:                                     (b) File number of pending application:

Not Applicable                                           f                  Not Applicable


TYPE OF SERVICE
20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply:

E a. Fixed Satellite
D b. Mobile Satellite
D c. Radiodetermination Satellite
D d. Earth Exploration Satellite
D e. Direct to Home Fixed Satellite
D £f. Digital Audio Radio Service
D g. Other (please specify)


21. STATUS: Choose thebutton next to the applicable status. Choose       22. If earth station applicant, check all that apply.
only one.                                                                Not Applicable
  ol Common Carrier @ Non—Common Carrier

23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one.Are these
facilities:
       C Connected to a Public Switched Network      C Not connected to a Public Switched Network          @ N/A

24. FREQUENCY BAND(S): Place an "X" in the box(es) next to all applicable frequency band(s).
E a. C—Band (4/6 GHz) IE b. Ku—Band (12/14 GHz)
  D c.Other (Please specify upper and lower frequencies in MHz.)
          Frequency Lower:      Frequency Upper: (Please specify additional frequencies in an attachment)


TYPE OF STATION
 25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one.

 (N/A) a. Fixed Earth Station
 (N/A) b. Temporary—Fixed Earth Station
 (N/A) c. 12/14 GHz VSAT Network
 (N/A) d. Mobile Earth Station
 @ e Geostationary Space Station.
 £4 f. Non—Geostationary Space Station
 J S Other (please specify)




26. TYPE OF EARTH STATION                FACILITY: Not Applicable
PURPOSE OF MODIFICATION


 27. The purpose of this proposed modification is to: (Place an "X" in the box(es) next to all that   Not Applicable
 apply.)

 ENVIRONMENTAL POLICY


 28. Would a Commission grant of any proposal in this application or amendment have a significant environmental     ; Yes @ No
 impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of
 the Commission‘s rules, 47 C.F.R. §§ 1.1308 and 1.1311, as an exhibit to this application. A Radiation Hazard
 Study must accompany all applications for new transmitting facilities, major modifications, or major amendments.


 ALIEN OWNERSHIP
Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or aeronautical fixed radio station
services are not required to respond to Items 30—34.


29. Is the applicant a foreign government or the representative of any foreign government?                                Yes @ No




30. Is the applicant an alien or the representative of an alien?                                                          Ye @©No 4 N/A




31. Is the applicant a corporation organized under the laws of any foreign government?                                    o Yes @ No C N/A




32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by       g*4 Yes @No N/A
aliens or their representatives or by a foreign government or representative thereof or by any corporation organized
under the laws of a foreign country?




33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than          @Yes 4 No 4 N/A
one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign
government or representative thereof or by any corporation organized under the laws of a foreign country?




34. If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or
foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote.


BASIC QUALIFICATIONS


35. Does the Applicant request any waivers or exemptions from any of the Commission‘s Rules?                             @ Yes ; No
 IfYes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.
                                                                                                                         EngineeringStatement




36. Has the applicant or any party to this application or amendment had any FCC station authorization or license         @, Yes ; No
revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or
construction permit denied by the Commission? IfYes, attach as an exhibit, an explination of cireumstances.




37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling    «4 Yes @ No
the applicant ever been convicted of a felony by any state or federal court? IfYes, attach as an exhibit, an
explination of circumstances.




38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant,        «4 Yes @ No
guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication, directly or
indirectly, through control of manufacture or sale of radio apparatus, exclusive traffic arrangement or any other
means or unfair methods of competition? IfYes, attach as an exhibit, an explanation of cireumstances




39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending   < Yes @ No
matter referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the circumstances.


40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names,
address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer‘s
voting stock and the percentages so held. In the case offiduciary control, indicate the beneficiary(ies) or class of
beneficiaries. Also list the names and addresses of the officers and directors of the Filer.




41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is         Yes ; No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of
1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See
47 CFR 1.2002(b) for the meaning of &quot;party to the application&quot; for these purposes.




42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? IfYes,    y Yes & No
answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate. If No,
proceed to question 43.




42b. What administration has licensed or is in the process of licensing the space station? If no license will be
issued, what administration has coordinated or is in the process of coordinating the space station?


43. Description. (Summarize the nature of the application and the services to be provided).     (If the complete description does not appear in this
box, please go to the end of the form to view it in its entirety.)
     Intelsat License LLC,             pursuant to Section 25.114 of the rules of the Federal
     Communications Commission, hereby applies to launch and operate a replacement C/Ku—band
     satellite,       to be known as         Intelsat 21,         at the 58.0 W.L.          orbital location.            Intelsat 21        is
     scheduled for launch on a Sea Launch vehicle early in the third quarter of 2012 and will
  Narrative & Exhibits



43a. Geographic Service Rule Certification                                                                                    @ A
By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic
coverage requirements specifiedin 47 C.F.R. Part 25.
                                                                                                                              «y B
By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements.
                                                                                                                              4 C
By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25 and will not comply with such requirements because it is not
feasible as a technical matter to do so, or that, while technically feasible, such services would require so many
compromises in satellite design and operation as to make it economically unreasonable. A narrative description
and technical analysis demonstrating this claim are attached.



CERTIFICATION
The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the
United States because of the previous use of the same, whether by license or otherwise, and requests an authorization in accordance with this
application. The applicant certifies that grant of this application would not cause the applicant to be in violation of the spectrum aggregation limit
in 47 CFR Part 20. All statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application.
The undersigned, individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are
true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.


44.   Applicant is a (an): (Choose the button next to applicable response.)


 C Individual
 C Unincorporated Association
 C Partnership
 C Corporation
 C Governmental Entity
 @ Other (please specify)      Limited Liability Company


45. Name of Person Signing                        |                      46. Title of Person Signing
Susan H. Crandall                                                        Asst. General Counsel, Intelsat Corporation
47. Please supply any need attachments.
 1:                                              2:                                               3:




          WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                 (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                 (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).



Completed Schedule S




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FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT

The public reporting for this collection of information is estimated to average 0.25 — 24 hours per response, including the time for reviewing
instructions, searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of
information. If you have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you,
please write to the Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554.
We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to
PRAQ@fcece.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS.

Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not
conduct or sponsor this collection, unless it displays a currently valid OMB control number or if we fail to provide you with this notice. This
collection has been assigned an OMB control number of 3060—0678.

THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.




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43. Description. (Summarize the nature of the application and the services to be provided).

Intelsat License LLC, pursuant to Section 25.114 of the rules of the Federal Communications
Commission, hereby applies to launch and operate a replacement C/Ku—band satellite,                      to be known as
Intelsat 21,      at the 58§.0 W.L.       orbital     location.       Intelsat 21 is scheduled for launch on a Sea
Launch vehicle early in the third quarter of 2012 and will replace the Intelsat 9 satellite                      (call
sign $2380),      which is currently operating at 58.0 W.L




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Document Created: 2012-07-12 15:41:17
Document Modified: 2012-07-12 15:41:17

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