Attachment grant

grant

DECISION submitted by FCC,IB

grant

2005-03-31

This document pretains to SAT-STA-20050321-00067 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2005032100067_425761

sihiyet ~200se32| & 67 Ares cansin 70. Cnmipue 3)21 /05 (oroteridenifen 3 ;7/Z/jafi{mmn‘.v:«fi /,/ i_p,,mve;o%%r:% Date & Time Filed: Mar 21 2005 3:52:56—250PM E_ | aprous stt_ Clre — PSichite & File Number: SAT—STA—20080321—00067 Zeterp 6 dhelo ) [’/'./m((m,; Fraals Calsign: FEDERAL CoMMUNICArIONS CoMMIssION ArPLICATION FoR SPACE STATION SPECIAL TEMPoRARY AutioRTy ror orriciat use onty APPLICANT INFORMATION Enter a descrition of this appliation toidentfy t on the main menu: STA for moving Telstar 11 to 37.58 degrees 1. Applicant Name: Loral Orion,Inc Phone Number: 9ot—470—2342 DBA Name: Fax Numb Sot—470—2483 Streets 500Hills Dive r—na se@lorlsynetcom PO. Box 7018 Cit: Bedminter State: w Country: USA Zipeode: oral 7oi8 Attention: MrSTANLEY EDINGER

Attachment Conditions of Authorization — SAT—STA—20050321—00067 Call Sign $2670 March 31, 2005 Loral Orion,Inc.‘s (Loral‘s) application, File No. SAT—STA—20050321— 00067, for Special Temporary Authority IS GRANTED and Loral is authorized to operate the Telstar 11 satellite, Call Sign $2670, athe 37.55° W.L. orbital position in the 11.45—11.7 GHtz, 11.7—12.2 GHz, and 12.5—12.75 GHz (space—to—Earth), and 14.0—14.5 GHz (Rarth—to—space), frequency bands for a period of 60 days commencing on April 1, 2005, in accordance with the terms, conditions, and technical specifications set forth in its application, this Attachment, and the Federal Communications Commission‘s Rules. This grant of special temporary authority is necessitated by the following cireumstances: (1) the AMC—12 satelite is currently drifting to the 37.5° W.L. orbital position pursuant to previously granted authority and is scheduled to arrive at the 37.5° W.L.orbital position by April 3, 2005; and (2) temporary operations at 37.55° W.L. will faciitate the transition and continuity of service from satellitesat the nominal 37.5° W.L. orbital position No harmful interference shall be caused by Telstar11 to any other laswfully operating in—orbit satellite and operations of the Telstar 11 satellte shall cease immediately uponnotifieationofsuch interference. Loral is required to accept interference from other lawfully operating in— orbit satellites. This Special Temporary Authority is granted without prejudice to our final determination of Loral‘s modification request SAT—MOD—20050322— 00069 for regular operational authority at37.55° W.L. This special temporary authority is issued pursuant to Section 0.261 ofthe Commission‘s rles on delegated authority, 47 C.F.R. § 0.261, and is effective upon release.

2. Connct Name: Mr STANLEY EDNGER Phone Number: 90%—470—2302 Companys Loral Synet In. Fax Number: sot—a70—24s3 Streets 500 HilsDrive E—Mail se@loralsynet.com r0. Box 7018 Bedminter State: w Country: USA Zipeote: orozt ~r08 Contact Manager Govermment Relatons Relationship: Sime Tite: (Ifyourapplcation is relted to an application fled withthe Commissionenterthe fil. number blow) 3. Reference File Number ‘a. Is a fe submited with this applcation? @ 1f¥es,complte and atach FCCForm 189. IfNo,indicatereason forfee exemption(see 47 CFRSection 11114 ( Govemmental ntiy gp Noncommercial educational Heensce @ Olherfplease cplain} (tb FeClasilication CRY ~ Space Stition (Gostaionary) 3: Tpe Request @ Change Station Location @ Extend Expiration Date g Oher 6. Temporary Orbit Location 7. Requested Extended Expiration Date 3755

i Descrinton —(lf h complete description does not appear in this box,plcase go to the nd ofhe frm to view t in ts entirey) stR to relocate and operate the Telstar 11 Ku—band satellite assigned to the 37.50 .L lorbital location to the 37.55 W.u. orbital. location. 9. By checking Yes, the undersined certfiesthat nither applicant nor any other pary o the application is subject @p Yes gy No to a denial ofRederl benefitsthat includes FCC benefits prsuant o Section 5301 ohe Anti~Drug Act of 1988, 21 U..C. Section 862, because ofa conviction forposession or dstibution ofa contriled substance, See 47 CFR 1,2002(b)for the meaning of&quotpartyto the application@iquatfor these purposes. 10. Name of Person Sizning 11 Tide o Person Signing Stantey Rdinger Manager Govemment Relations 12. Plcase supply any need atachments. Atachment 1: A Atachment 2 B Atachnent 3: C WwiLLEUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE Y FINE AND / OR IMPRISONNMENT (U.S, Code,Tite 18, Setion 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION (U.S. Code, Ti47, Section 312G)(1)AND/OR FORFETTURE (U.S. Code, Tite 4, Section 503)

ree Novice requrn By TiE rarERWORK REDUCTION ACT "The public eporting forthis ollction of nformation i stimated taverage 2 hours er response, including th ime or reviewing istructions, searching existing data sources,pathering and maintaiing therequired dat, and completing and revewing thecolletion of nformation. Ifyou have any comments on this brden estmate, o how we can improve the collectionandreducethe burde it uses you, lease wite o the Federal Communications Commision, AMD—PERM, Paperwork Reduction Project (3060—0676), Washington, DC 20554. We willals accept your comments regarding the Paperwork Reduction Act aspecs ohiscolection via the Intemmc ifyou send them tJboley@cco. PLEASE bo NosENb comPLETED ForMs To Thts appREss Remember —You ae notrequied o espond to a collection of nformation sponsored by the Federal povernment, andthe govemment may not conduct or sponsor thiscalltion, unless t dislays a currenly valid OME control nmber orifwfail t provideyou with his natce. This collection has been assigned an OME control number of3060—0678. Tik FoREGoING NOTICE Is REQUIRED BY TE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 10+—13, octomeR 1, 1998, 41 Us.C. SECTION aswr.

BEFORE THE Federal Communications Commission WaASHINGTON, D.C. In the Matter of Loral Orion, Inc. (Debtor—in—Possession) File No. SAT—STA— Request for Special Temporary Authorty to Operate Telstar11 at 37.55° WL REGUEST FOR SPECIAL TEMPORARY AUTHORITY Loral Orion, Inc., Debtorin—Possession (‘Loral Orion‘) requests that the Commission grant it special temporary authority (‘STA®)to relocate the Telstar 11 Ku— band satelite assigned to the 37.5" W.L. orbitallocation, to 37.56° W.L.1 This relocation is part of a collocation adjustment to be undertaken in conjunction with the movement of Columbia Communication Corporation‘s (‘Columbia®) new AMG—12 C—band satelite into the 37.45° orbital position where it wl replace Satcom C—1 which is also assigned and currently operating at the 37.5° W.L. orbital location. Columbia has fled a similar request for reassignment to 37.45° WL. Grant of the instant application will serve the publiinterest by faciitating stationkeeping of Telstar 11 and AMC—12, as agreed to by Loral Orion and Columbia. Telstar 11 and Satcom C—1(previously Columbia 515) 1 Coneurrent wih this reauestfor STA,Loral Onion is submitingan applcation for modifcation of s authorization to retect the new orotalsiot assignment requested herein. Loral Orion Incorporates by reference the technicalinformaton it has provided in ts modifcation applicaton. Loral Orion is not submiting new contour maps wih is appleaton because the proposed shit in orbtal lecation wil not change the coverage area ofthe satelte sns

have been collocated in the same box at the 37.5° W.L. orbital location since November 2002. Although an adjacent ‘box" collocation strategy similar to the one proposed in this application would have been useful previously, Telstar 11 has been operating at full capacity untl recently and any movement of the satelite would have involved re—pointing thousands of customers antennae — a very costly endeavor. However, Telstar 11 is now in inclned orbit and there is nominal customer use of the satelite. Loral Orion has already received Commission authority to replace Telstar 11 with Telstar 11. As noted above, Loral Orion is filng an application to modify is orbital position for the remainder of Telstar 11‘s usefulife. Columbia anticipates thatits replacement, AMC—12, will arrve at the 37.45° WLL.. orbita location the first week of April. Columbia and its parent company SES Americom, have requested that Loral move Telstar 11 0.05" to 37.56° priorto the arrval of AMC—12 in order to operate using an adjacent ‘box" collocation strategy and faciltate technical coordination. Loral Orion has agreed to do so upon the FCC‘s grant of the instant STA The relocation of Telstar 11 and the operation of both satelites at the slight offset from their assigned orbital ocation of 37.5° WL. will greatly simplty satelite operations for both Loral Orion and Columbia. The need for constant coordination and the possiblity of collsion of the spacecraf will be substantialy reduced Moreover, this STA requestis consistent with the Commission‘s rules and precedent. In a 1993 Order, the FCC reserved its authority ‘to assign orbitallongitudes offset by 0.05 degrees or some multiple thereoffrom the nominal orbitl location specifed in the station authorizations ‘? The FCC specifically noted that this authority is 2. Seein Part 2ofthe Commission ind Reqations Allen CarterIntoference Batween Fix ies at Recuced n to Revise % se

‘particularly usefu! with co—located satelites of different frequency bands" and that it was codifying industry practice and the Commission‘s previous policies.3 Te FOC recently simplifed the rule wherein this policy was codified; however, it did not eliminate its discretion or authority to allow satelite Icensees to operate from a nominal orbital location different from what was originally assigned. The new Section 25.210() of the Commission‘s rules states that Space stations operated in the geostationary satelite orbit must be maintained within 0.05" of their assigned orbital longitude in the east\west direction, unless specifically authorized by the Commission to operate with a different longitudinaltolerance, and except as provided in Section 25,283(b) (End—ofLife Disposal). Thus, it remains to be the case that the FCC may grant an application for a satelite to be operated from a location that is 0.05° or greaterfrom its originally assigned orbital location. The FCC recently approved a modification application for PanAmSat Licensee Corp. proposing a similar orbital location variation. In that case, PanAmSat sought and the FCC permited PanAmSat to move its Galaxy 5 satelite from 125° W.L. to 12.05° wis Here, Loral Orion‘s STA request should be granted so that Loral Orion is able to move Telstar 11 slowy in orderto conserve as much fuel as possible and be out of SES Americom‘s ‘half"ofthe box by the time AMC—12 arrves in the first week of April 2008. Moreover, grant of the STA is necessary to allow the agreement between Loral Orion Apoleation Processing Rrocedures fr Sateite Communicatons Services. Second Report and Order and Furher Notie ofPropased Ruemaking, 8 FGG Rea 1316 (1993)at para. 10 ® i. « MMticaton of Ofbtal Debis, Second Report and Order, 19 FCC Red 11567 (2004) at pore. «s 5_ See Puble Notie, Report No. SAT—00222, DA No. 04—1746, Fle No SAT—MOD: 20040405—00075 (rl June 18, 2004)

and Columbia to be fuliled. The parties have agreed that an adjacent box collocation strategy, as contemplated by the FCC‘s 1993 Order cited above,is preferred because it offers the lowest probabilty ofinterference or colision for collocated satelites. Finally, as shown in Lorals license modification application that has been will be fled concurrently with the instant request, this slght shif in orbita location will not cause harmful interference to neighboring Ku—band satelite operators, including Intelsat 903 located at 34.5° WL. and NSS—806,located at 40.5° W.L se

For the reasons discussed above, grant ofthis request for STA is in the public interest. Loral Orion requests that the Commission expeditiously grant this request for STA to move Telstar 11 to 37.55° WL. Respectfuly submitted, for LORAL ORION, INC. (Debtorin— Possession) Jeffrey C. Stein March 21, 2005

CERTIFICATIONS Pursuant to Section 1.2002 of the Commission‘s Rules, 47 C.F.R. § 1.2002, Loral Orion, Inc. (Debtor—in—Possession) certfies that neither the applicant nor any party to this application is subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Ant—Drug Abuse Act of 1988 Loral Orion, Inc. (Debtor—in—Possession) waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power ofthe United States because of the previous use of the same, whetherby the license or otherwise, and requests an authorization in accordance with this application: Jeffey C. Stein March 21, 2005

puBLic iNTEREST sTATEMENT Loral Orion, Inc., Debtor—in—Possession (‘Loral Orion‘) requests that the Commission grant tis STA to relocate and operate the Telstar 11 Ku—band satelite assigned to the 37.5° W.L. orbital location, to 37.55° W.L. immediately upon receipt of this fling and the required fling fee. Loral Orion Inc. asks that the Commission grant the instant STA before March 24, 2005 because the next maneuver, to maintain Telstar 11 in the current £0.05° box centered on 37.50®,is scheduled to be performed on that day. This relocation is part of a collocation adjustment to be undertaken in conjunction with the movement of Columbia Communications Corporation‘s (‘Columbia‘s) new AMC—12 C—band satelite into the 37.45° orbital position where it will replace Satcom G—1 which is also assigned and currentyy operating at the 37.5° WL. orbital location. Columbia has fled a similar request for reassignment to 37.45° W.L.1 Grant ofthe instant application will serve the public interest by faciltating stationkeeping of Telstar 11 and AMC—12, as agreed to by Loral Orion and Columbia Telstar 11 and Satcom C—1 (and its predecessor Columbia 515) have been collocated in the same box at the 37.5° W.L. orbital location since November 2002. Although an adjacent ‘box" collocation strategy similar to the one proposed in this application would have been usefu! previously, Telstar 11 has been operating at full capacity untl recently and any movement of the satelite would have involved re— pointing thousands of customer antennae —— a very costly endeavor. However, Telstar 11 is now in inclined orbit and there is nominal customer use of the satelite. Loral Orion 1 Columbiafled a request fr STA to relocate AMG—12 to 37.45" WL on March 16, 2005 (sar—sra—200s0st6—00088)

has already received Commission authoriy to replace Telstar 11 with Telstar 11R Columbia anticipates that the AMC—12 satelite wll arive at the 37.45° W.L. orbital location in the first week of April. Columbia, and its parent company SES Americom, have requested that Loral move Telstar 11 0.05° to 37.55° prioto the arival of AMC—12 in orderto operate using an adjacent "box" collocation strategy and faciitate technical coordination. Loral Orion has agreed to do so upon the FCC‘s grant of the STA filed concurrently with this application The relocation of Telstar 11 and the operation of both satelltes at the slght offset from their assigned orbitallocation of 37.5° WL. will greatly simplfy satelite operations for both Loral Orion and Columbia. The need for constant coordination and the possibiity of callsion of the spacecraft wil be substantialy reduced Moreover, this application is consistent with the Commission‘s rules and precedent. In a 1993 Order, the FCC reserved its authority to assign orbitallongitudes offset by 0.05 degrees or some muliple thereof from the nominal orbitallocation specifed in the station authorizations."2. The FCC specifically noted that this authoriy is "particularly usefu! with co—located satelites of different frequency bands" and that it was codifying industry practice and the Commission‘s previous policies.3 The FCC recently simpified the rule wherein this policy was codified; however, it did not eliminate its discretion or authoriy to allow satelite licensees to operate from a nominal orbital & See i e Amendment of Rar 25 of the Commsion‘s Rules and Reaulations to Reduce Allen Garter nteference etween Fixed:Sateifes atReduced Orotal Spacings and to Revise Anpleation Processina Procedires for Satelte Communetions Services, Second Report and Order and Furher Notie ofPropased Rulemaking, 8 FGC Red 1316 (1989) at para. 19 30 is

location different from what was originally assigned4 The new Section 25.210() ofthe Commission‘s rules states that Space stations operated in the geostationary satelite orbit must be maintained within 0.05" of their assigned orbital longitude in the eastwest direction, unless speciically authorized by the Commission to operate with a different longitudinal tolerance, and except as provided in Section 25.283(b) (End—of—Life Disposal). Thus, it remains to be the case that the FCC may grant an application for a satelite to be operated from a location that is 0.05° or greaterfrom its originally assigned orbital location. The FCC recently approved a modifcation application for PanAmSat Licensee Corp. proposing a similar orbitallocation variation. In that case, PanAmSat sought and the FCC permitted PanAmSat to move its Galaxy5 satelite from 125° WL. to 125.05° wis Here, Loral Orion‘s STA request should be granted sothat Loral Orion is able to move Telstar 11 slowly in order to conserve as much fuel as possible and be out of Columbia‘s "halfof the box by the time AMC—12 arrives in the first week of April 2005 Moreaver, grant of this STA is necessary to allow the agreement between Loral Orion and Columbia to be fulflled. The parties have agreed that an adjacent box collocation strategy, as contemplated by the FCC‘s 1993 Order cited above, is preferred because it offers the lowest probablity of interference or collsion for collocated satelites Finally, tis slight shift in orbital location will not cause harmful interference to neighboring Ku—band satelite operators, including Intelsat 903 located at 34.5° WL. and * Mfigation ofOrbtal Debrs, Second Report and Order, 1 FCC Red 11967 (2004) at para. «s $ See Publc Notce, Report No. SAT—00222, DA No 04—1748, Fle No. SAT—MOD— 20040405—00075 (l. Je 18, 2004) as

NSS—806,located at 40.5" W.L. Although the proposed offset would result in Telstar 11 being slightly closer to NS—806, the satelites will stll be 2.95° apart and there will be no material change to the existing interference environment. The Telstar 11 satelite is fuly compliant with the Commission‘s requirements with respect to two—degree spacing. For the reasons discussed above, grant ofthis STA is in the publicinterest. Loral Orion requests that the Commission expeditiously grant this request to reassign Telstar 11 to 37.55° WL 8 Loral Orion is not submiting new contour maps with hi appleaton because the minor shif i orbtallocation wil not materaly affect coverage of the satelie as shoum on the maps already on fio. sus

ENGINEERING STATEMENT Loral Orion Inc (Loral) is currently liensed to operate Telstar 11 at 37.50° WL utilizing the 14.0—14.5 GHz uplink and 11.45—11.7 GHz, 11.7—12.2 GHfe, and 12.5—12.75 GHe downlink FSS bands to provide U.S. and Europe coverage (See FCC File No: SAT—T/C— 19981218—00102). In this fling. Loral proposes to modify its icense to specify operation ofTelstar 11 from 37.55° WIL instead of37.50° WL. To account fo this change in orbial location,this engineering statement updates te following technical information that Loral previously had submited: (1) gain contours, (2) PFD leves and (3) link budget analysis Gain Contours "The coverage patterns of Telsta11 operating from the proposed 37.55° WL orbital location will be the same as those specifiein the currentlicense. Changing the proposed orbital location from 37.50° WL to 37.55° WL will produce no visible change in the gain contours. Accordingly, no newbeam gain contours are being submitted Power Flux Density Levels "The power fux density (‘PFD*) level at the Earth‘s surface produced by Telsta 11 operating from the proposed 37.55° WL orbital location will be the same as those corresponding to operation from 37.50° WL and have already been provided to the FCC. Link Budgets and Interference Analysis "The Commission has adopted a policy in which the nominal spacing between adjacent co—coverage co—frequencysatellites is 2°. Moving a satelite by 0.05®, so that there is 1.95° and 2.05° ofseparation, respectively, between the re—located satelite and its nearest and next nearest neighbor wll cause nealigible change in the iterference levels introduced into each satellite system. The following analysis substantitesthis claim. Receiving earthstations, which have off—axis gain characterists compliant with Section 25.209(a)(1) ofthe FCC rules, would have an off—axis gain of 21.5 dB toward an interfering satelte, whichis 2° away from the desired satellte. If the interfering satellte is moved 0.05° toward the desired satelite, so that the separation between the desired and interfering satelitesis 1.959, the off—axis gain ofthe receive earth station antenna toward the iterfering satelite would become 21.7 dB. Hence, there would be an increase of0.2 B in the interference levels from the nearest neighbor satelite. Such a small change in the iterference levels would not affect in any meaningful way the existing interference environment. Regarding the stelfte that would be 2.05° away, the nterference environment would also be nealigibly changed. Receiving earth stations, which have off—axis gain characteristicscompliant with Section 25.209(a)(1) of the FCC rules, would have an off— axis gain of21.5 dB toward an iterfering satelte, which is 2° away from the desired satelite. Ifthe iterfering satelite is moved 0.05° away from the desired satelite, so that

the separation between the desied and interfering satelltes is 2.05®, the off—ais gain of the receive earth station antenna toward the interfering stellte would become 21.2 dB. Hence, there would be a decrease of0.3 dB in the interference levels from the next nearest neighbor satelite. Such a small change in the interference levels would not affect in any meaningful way the existing interference environment. Therefore, moving Telstar 11 by 0.05° to 37.55° WL would resultin an insignificant change in the interference environment for both the nearest and neighbor satelites and the Telstar 11 satellte and their associated earth stations. in fact, the operational co—frequency satelites nearestto the 37.55° W orbita location are New SkiesSatelltes NSS—806, located at 40.50° WI., and Intelsat 903, located at 34.50° WL. These satelltes are 3° away from Telsta11, making the iterference environment more benign than in the case of2° separation. In the case ofNSS—806 and Telstar 11, since the stelltes do notcover the same regions — NS—806 covers the Atlantic coast of Brazil and Telstar 11 provides coverage of the US — the systems inherently introduce lowinterference levelsinto each other. With the Telstar 11 spacecraft moving 0.05° closer to NSS—806, the interference levels would increase by about 0.2 dB for earthstations adhering to the of—axis gain characteristics set forth in Section 25.209(a)(1) ofthe FCC Rules, since the ofBaxis gain toward the iterfering satelte would increase from 17.1 dB (in the case of3.00° ofseparation between the sateltes) to 17.3 dB (in the case of 3.05° ofseparation between the satellites). This very small change in the interference levels, on top of the already low interference levels in the nominal case, would not impact the interference environment for NS—806 and Telsta 11 in any mesningful way. Regarding Intelsat 903,with earth stations adhering tothe offxis gain characteristicsset forth in Section 2.209(a)(1) othe FCC Rules, the already low iterference levels would be reduced by less than 0.2 dB. Such a small decrease in the off—axis gain ofIntlsat 903 receive earth station will not change in any meaningful way the existing interference environment ofItelsat 903 receiving earth stations from the proposed operation of Telsta 11 at 37.55° WIL. Similarly, interference from Intelsat 903 transmissions nto Telstr 11 receiving earth stations would be substantially unchanged (0.2 dB varation). Given thatthe proposed operation ofTelstar 11 would not result in any significant change to the existing interference environment as it pertains to Telsar 1 1, Itelsat 903, and NSS—306 no link budget analysis is provided herein‘. Schedule S Submission For reasons thatare discussed above, the proposed operation of Telstar 11 from 37.55° WL would not result in any material changes to the operating characteristesofhe satellitor the existing interference environment, The information requested in Schedule S, therefore, is duplicative ofthe information that Loralalready has provided. Based on this fact and on discussions with the staffofthe Satellte Division, Loral is not including ‘ The Intermational Bureau recently clrified that GSO space station applicants generally are expected to provide thisinformation. See Public Notice, DA 03—3683 (Dec. 3, 2003)

a Schedule S with ts modification application. However, Loral will prepare and file a Schedule S in the event that the Satelite Division determines t to be necessary. Certification Statement 1 hereby certify that I am a technically qualified person and am familior with Part 25 of the Commission‘s Rules and Regultions. The contents ofthis engineering statement were prepared by me or under my direct supervision and to the best of my knowlede are complete and accurate. Peter E. Goctie March 21, 2008


Document Created: 2005-03-31 14:00:05
Document Modified: 2005-03-31 14:00:05
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