Attachment 00222

This document pretains to SAT-STA-20021121-00222 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2002112100222_296267

                            Wiley Rein & Fielding L
                                                                                                     . .._.. ,

                                                                                                          ennifer D. Hi’h
1776 K STREET NW                November 2 1,2002
WASHINGTON, DC 20006
PHONE        202.719.7000
FAX          202.719.7049
                                BY HAND DELIVERY

Virginia Office             Ms. Marlene H. Dortch
7925 30NES 6RANCl-l DRIVE   Secretary
SUITE 6200                  Federal Communications Commission
MCLEAN, VA 22102
PHONE        703.905.2600
                            236 Massachusetts Avenue, N.E., Suite 110
FAX          703.905.2620   Washington, DC 20002

                            Re:       Request for Special Temporary Authority to Conduct In-Orbit Testing
www.wrf.com                           INTELSAT 907
                                      Call Sign: S2411

                            Dear Ms. Dortch:

                            Intelsat LLC (“Intelsat”) herein requests a grant of Special Temporary Authority
                            (YTA”)’ for 60 days from February l&2003 through April 19,2003 to allow in-
                            orbit testing of INTELSAT 907 at 25.75” W.L. INTELSAT 907 is scheduled to be
                            launched on February 12,2003. In support of its request, Intelsat submits the
                            following information.

                            On August 8,2000, the Federal Communications Commission (“Commission”)
                            granted Intelsat authority to launch and operate INTELSAT 907 at 3 1 S” W.L.2 On
                            September l&2002, Intelsat filed an application to modify the license for
                            INTELSAT 907 to permit deployment of the satellite at 27.5” W.L.3 That
                            application is pending.




                            I
                                     Intelsat has filed this STA request, an FCC Form 159 and a $670.00 tiling fee
                            electronically via the International Bureau’s Filing System.
                            2
                                     See Applications of Intelsat LLC For Authority to Operute, and to Further
                            Construct, Launch and Operate C-Band and Ku-Band Global Satellites That Form a
                            Global Communications System in Geostationaly Orbit, 15 FCC Red 15460 (2000)
                            (Memorandum Opinion Order and Authorization) (“Intelsat LLC Order”), recon. denied, 15
                            FCC Red 25234 (2000) (Order on Reconsideration). This authority became effective upon
                            the July l&2001 transfer of satellite assets from INTELSAT, the intergovernmental
                            organization, to Intelsat and the transfer of INTELSAT’s associated ITU network filings to
                            U.S. registry. See Intelsat LLC Order, 15 FCC Red at 155 19.
                            3
                                     See Policy Branch Information, Satellite Space Applications Acceptedfor Filing,
                            Report No. SAT-00 127, File No. SAT-MOD-200209 18-00 183 (Oct. 30,2002) (Public
                            Notice).


Wiley Rein & Fielding LLP


Ms. Marlene H. Dortch
November 21,2002
Page 2


The 25.75“ W.L. orbital location is the same one used to conduct in-orbit testing of
INTELSAT 905.4 As with INTELSAT 905, Intelsat has coordinated the planned in-
orbit testing of INTELSAT 907 with Hispasat, the operator of a nearby satellite at
30” W.L., as well as with Russia, which holds ITU filings for -- but has no
operational satellites at -- nearby locations, including 25” W.L. and 26.5” W.L. In
the unlikely event that harmful interference occurs, Intelsat will take all necessary
steps to eliminate the interference.

The in-orbit testing of INTELSAT 907 at 25.75” W.L. is a critical step in ensuring
that the satellite will be fully operational at 27.5” W.L. This, in turn, will ensure
continuity of existing services at that location, and thereby promote the public
interest.

For the reasons set forth herein, Intelsat respectfully requests that the Commission
grant this request.

Sincerely,
~-:>+~a &
  *+.
Jennifer D. Hindin

cc:      Tom Tycz
         Jennifer Gilsenan
         Jabin Vahora
         Sylvia Lam




4
        See Intelsat LLC Request for Special Temporuly Authority to In-Orbit Test
INTELSAT at 25.75” W.L., File No. SAT-STA-20020416-00057 (Apr. 16,2002) (stamp
grant by Jennifer Gilsenan, Branch Chief, Satellite Policy Branch, FCC, issued June 4,
2002).


                                     Attachment

                         File No. SAT-STA-20021121-00222

Intelsat LLC is given special temporary authority to perform in-orbit testing of the
INTELSAT 907 satellite at 25.75” W.L. for a period of 60 days commencing February
l&2003 and ending April 19,2003, subject to the following conditions:

       1)     Intelsat LLC shall coordinate with existing geostationary satellites to
              ensure that no unacceptable interference results from its in-orbit testing
              operations;

       2)     In the event that any harmful interference does occur, Intelsat LLC shall
              cease operations until the issue is rectified; and

       3)     Any actions taken as a result of the in-orbit testing authority ARE
              SOLELY AT INTELSAT LLC’S OWN RISK.



Document Created: 2003-01-16 15:20:08
Document Modified: 2003-01-16 15:20:08

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