Attachment STA Request

This document pretains to SAT-STA-20100426-00084 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010042600084_812727

             April 26, 2010


             Ms. Marlene H. Dortch
             Secretary                          *
             Federal Communications Comrmssmn
             445 12"" Street, S.W.
             Washington, DC 20554
INTELSAT.    Re:       Request for Special Temporary Authority for Galaxy 15
              ‘        Call Sign $2387

             Dear Ms. Dortch:

             PanAmSat Licensee Corp. .(“PanAmSat’.’), pursuant to Section 25.120 of
             the rules of the Federal Communications Commission ("FCC" or
             "Commission")," herein requests Special Temporary Authority ("STA"»
             for three days —— from May 3, 2010 through May 5, 2010 —— to operate the
             Galaxy 15 satellite‘s (Call Sign $2387) C—band communications payload
             outside of the +/— 0.05° East/West station—keeping box ?ursuant to a
             waiver of Section 25.210(j) of the Commission‘s rules.

             As PanAmSat previously has informed the International Bureau
             ("Bureau") staff, on April 5, 2010 the Galaxy 15 satellite experienced an
             anomaly of unknown origin. Due to this anomaly, the Galaxy 15
            ~ satellite has drifted outside of its authorized +/— 0.05° East/West station—
             keeping box. The Galaxy 15 satellite is currently located at
             approximately 132.74° W.L. pursuant to STA.* During the time period
             covered by this STA request, Galaxy 15 will be located at 132.5 +/— 0.1°                                        5
             W.L.

             PanAmSat will utilize the transmissions contemplated herein in an
             attempt to disable the communications payload on the Galaxy 15
             satellite. PanAmSat will take this action only if all ongoing efforts to



             ‘A47 C.F.R. § 25.120.
             > PanAmSat has filed this STA request, an FCC/Form 159 and an
             $830.00 filing fee electromcally via the Internatmnal Bureau‘s Filing
             System.

             3 47 C.F.R. § 25.210(G).
             * See Policy Branch Information; Actions Taken, Report No. SAT—
             00682, File No. SAT—STA—20100409—00071 (Apr 16, 2010) (Pubhc
             Notlce)




             Intelsat Corporation .
             3400 International Drive NW, Washington DC 20008—3006 USA www.intelsat.com T +1 202—944—6800 F+1 202—944—7898


Ms. Marlene H. Dortch
April 26, 2010
Page 2


regain control of Galaxy 15 have not been successful by May 3.
PanAmSat‘s sister company, Intelsat North America LLC, has filed an
STA request to utilize an earth station in Clarksburg, Maryland (KA275)
to transmit to the satellite for purpose of this disabling effort." In the
course of these transmissions, the Galaxy 15 transponders will operate at
saturation, resulting in each of the 10 MHz carriers having at beam peak
a downlink EIRP of approximately 41 dBW.

Grant of this STA request is in the pubhc interest. The Commission may
grant a waiver for good cause shown." The Commission typically grants .
a waiver where the partlcular facts make strict compliance inconsistent
with the public interest.‘ In granting a waiver, the Commission may take
into account considerations of hardship, equity, or moreeffectwe
implementation of overall policy on an individual basis.s Waiver is
therefore appropriate if special circumstances warrant a deviation from
the general rule, and such a deviation will serve the public interest.

Good cause exists in this case based on hardship. Due to the technical
anomaly on the Galaxy 15 satellite, PanAmSat is unable to comply with
the requirements of Section 25.210(J) of the Commission‘s rules.
PanAmSat will, however, take all practicable steps to coordinate the safe
operation of Galaxy 15. Moreover, grant of this STA request will allow
PanAmSat to attempt to disable the communications payload on the
Galaxy 15 satellite should ongoing attempts to regain control of the
spacecraft prove unsuccessful. If this attempt to disable the
communications payload is successful, it will greatly reduce the



5 See Intelsat North America LLC Requestfor Special Temporary
Authority, Clarksburg, Maryland Earth Station KA275, File No. SES—
STA—INTR2010—01283 (filed Apr. 23, 2010). As noted therein, in the
course of the three days of operations, during one or more periods of up
to three hours, the earth station will be transmitting simultaneously to the
24 transponders of the Galaxy 15 satellite.

647CFR§13
" N.E. Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990)
("Northeast Cellular®").

8 WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969); Northeast
Cellular, 897 F.2d at 1166.


 Ms. Marlene H. Dortch
 April 26, 2010
 Page 3


 likelihood of Galaxy 15 causing potential interference into the operations
_ of other operators, thereby promoting the public interest.

 For the reasons set forth herein, PanAmSat respectfully requests that the
 Commission grantthis request.

— Sincerely,




 Susan H. Crandall
 Assistant General Counsel
 Intelsat Corporation _:


 ce: Robert Nelson
      Kathyrn Medley
    . Stephen Duall



Document Created: 2010-04-26 16:34:22
Document Modified: 2010-04-26 16:34:22

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