Attachment STA Request

This document pretains to SAT-STA-20100423-00083 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010042300083_812507

             April 23, 2010


             Ms. Marlene H. Dortch
             Secretary
             Federal Communications Commission
             445 12"" Street, S.W.
             Washington, DC 20554
INTELSAT
             Re:       Request for Extension of Special Temporary Authority for Intelsat 705
                       to Drift to and Operate at 330.5° E.L. (29.5° W.L.]
                       Call Sign: $2395                                                          2

             Dear Ms. Dortch:

             Intelsat North America LLC (Intelsat") herein requests a 60—day extension —
             through June 28, 2010 — of the Special Temporary Authority ("stA"y‘
             previously granted Intelsat to drift the Intelsat 705 satellite (call sign $2395)
             from 310.0° E.L: (50° W.L.) to 330.5° E.L. (29.5° W.L.) and then operate the —
             satellite at the 330.5° E.L. (29.5° W.L.) location." Intelsat has a pending
             application to modify the Intelsat 705 license to allow it to relocate the satellite
             to, and operate at, 330.5° E.L. (29.5° W.L.)," where it will be co—located with
             Intelsat 801.

             Intelsat 705 currently is drifting and is expected to be on—station at 330.5° E.L.
             (29.5° W.L.) in early May. During the drift, Intelsat will continue to utilize
             only Intelsat 705‘s TT&C frequencies and will follow industry practices for —
             coordinating TT&C transmissions during the relocation process. The specific
             TT&C frequencies are as follows:




             ‘ Intelsat has filed this STA request, an FCC Form 159 and an $830.00 filing
             fee electronically via the International Bureau‘s Filing System.:
              See Policy Branch Information; Actions Taken, Report No. SAT—00670, File
             No. SAT—STA—20100205—00023—00023 (Mar. 5, 2010) (Public Notice). _
             * Intelsat North America LLC, Application to Modify Authorization for Intelsat
             705, File No. SAT—MOD—20100115—00010 (filed Jan. 15, 2010). This
              pending modification application noted that the drift of Intelsat 705 to 330.5°
              E.L. (29.5° W.L.) was planned for February 15, 2010. The start of the drift
           ._ was delayed until early March 2010.
             * See Policy Branch Information; Actions Taken, Report No. SAT—00668, File
             No. SAT—STA—20091216—00146 (Feb. 26, 2010) (Public Notice); Intelsat
             North America LLC, Requestfor Extension ofSpecial Temporary Authorityfor
             Intélsat 801, File No. SAT—STA—20100416—00079 (filed April 16, 2010).


             intelsat Corporation                                                                                          '
             3400 International Drive NW, Washington DC 20008—3006 USA wwuw.intelsat.com T+1 202—944—6800 F+1 202—944—7898


Ms. Marlene H. Dortch
April 23, 2010
Page 2


Uplink:

6173.7 MHz (LHCP)
6176.3 MHz (LHCP)

Downlink:

3947.5 MHz (RHCP)
3948.0 MHz(RHCP)
3952.5 MHz (RHCP)
3952.0 MHz (RHCP)
Grant of this STA extension request is in the public interest because it will
enable Intelsat to provide robust service to customers. In particular, the
Intelsat 705 satellite will be used at the 330.5° E.L. (29.5° W.L.] orbital
location to provide 2010 World Cup—related transmissions in June and July
2010. These World Cup—related transmissions cannot be accommodated on
Intelsat 801 at the same location because Intelsat 801 is too highly inclined to
support such transmissions.                                .

Grant of the STA extension also will serve the public interest by affording the
Commission additional time to complete its review of Intelsat‘s pending
modification application to relocate Intelsat 705 to, and operate at, 330.5° E.L.
(29.5° W.L.). Intelsat understands and accepts that a grant of STA would not
prejudge the Commission‘s determination of Intelsat‘s request to operate
Intelsat 705 at 330.5° E.L. (29.5° W.L.) on a permanent basis, and operation of
the satellite at that location pursuant to STA is at Intelsat‘s risk.   '

Grant of this STA extension request will not result in increased risk of harmful
interference. As noted above, Intelsat will operate only TT&C frequencies
during the drift and will coordinate its TT&C transmissions with operators of
satellites in the drift path. Should any interference occur during the drift,
Intelsat will take all reasonable steps to eliminate such interference. At the
330.5° E.L. (29.5° W.L.) location, Intelsat will operate the satellite‘s
—communications payload in conformance with its coordination agreements
covering the location as well as the Commission‘s rules regarding two—degree
spacing.

Intelsat has assessed and limited the probability of the space station becoming
a source of debris as a result of collisions with large debris or other operational
space stations. Except for Intelsat 801, Intelsat 705 will not be located at the


Ms. Marlene H. Dortch
April 23, 2010
Page 3


same orbital location as another satellite or at an orbital location that has an
overlapping station—keeping volume                                      |    |

with another satellite." Further, except for Intelsat 801, Intelsat is not aware of
any other FCC licensed system, or any other system applied for and under
consideration by the FCC, having an overlapping station—keeping volume with
Intelsat 705 at 330.5° E.L. (29.5° W.L.): Finally, Intelsat is not aware of any
satellite network with an overlapping station—keeping volume with Intelsat 705
that is the subject of an ITU filing and that is either in orbit or progressing
towards launch.

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

Sincerely,



O_MLC_/LQS\
Susan H. Crandall
Assistant General Counsel
Intelsat Corporation




co:      Bob Nelson
         Karl Kensinger
         Kathyrn Medley
         Stephen Duall




5 Intelsat will operate both satellites in the 29.5° +/— 0.05° station—keeping box.
Both satellites operate in inclined orbit, which facilitates sharing of the station—
keeping box.



Document Created: 2019-04-15 12:02:48
Document Modified: 2019-04-15 12:02:48

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