Attachment STA Request

This document pretains to SAT-STA-20100603-00122 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010060300122_820824

             June 3, 2010

             Ms. Marlene H. Dortch
             Secretary
             Federal Communications Commission
             445 12" Street, S.W.
             Washington, D.C. 20554
INTELSAT.
             Re:     _ Request for 180—Day Special Temporary Authority to Operate Galaxy
      C
                       12 at 133.0° W.L.
                       Call Sign $2422

             Dear Ms. Dortch:

             PanAmSat Licensee Corp. (“PanAmSat”) herein requests a grant of Special
             Temporary Authorlty ("STA")‘ for 180 days——from August 8, 2010 through
             February 3, 201‘1—to operate Galaxy 12 (call sign S2422) at 133.0° W.L.

            Galaxy 12 is currently licensed to operate at 122.9° w1, but has been
            operating at 133.0° W.L. pursuant to two grants of STA followmg a technical
            anomaly on Galaxy 15 (call sign $2387)." As the Commission is aware,
            PanAmSat sought STA to use Galaxy 12 to replace Galaxy 15 at the nominal
            133.0° W.L. orbital location.* PanAmSat has a pending apphcatlon for
            permanent authority to redeploy Galaxy 12 to 133.0° W.L.‘ PanAmSat is

             ‘ 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—00553 File
            No. SAT—MOD—20080630 (Sept. 5, 2008) (Pubhc Notice).

            * See Policy Branch Information; Actions Taken, Report No. SAT—00682, File
            No. SAT—STA—20100408—0070 (Apr. 16, 2010) (Public Notice); Policy Branch
            Information; Actions Taken, Report No. SAT—00690, File No. SAT—STA—
            20100430—00089 (May 14, 2010) (Public Notice).
            : * See Pand4mSat Licensee Corp. Requestfor Special Temporary Authority to
            Drift and Operate Galaxy 12, Call Sign $2422, File No. SAT—STA—20100408—
            00070 (filed Apr. 8, 2010) (grant stamped with conditions Apr. 8, 2010);
            PanAmSat Licensee Corp. Requestfor Extension ofSpecial Temporary
            Authority to Drift and Operate Galaxy 12, Call Sign S82422, File No. SAT—
             STA—20100430—00089 (filed Apr. 30, 2010) (grant stamped with conditions
             May 11, 2010).                                                   ,
             ° See PanAmSat Licensee Corp. Modification ofAuthorization for Galaxy 12 to
             129.0° W.L. (S2422), File No. SAT—MOD—20100120—00013 (filed Jan. 20,
            2010), PandamSat Licensee Corp. Amendment to Application to Modify
            Authorizationfor Galaxy 12 (S2422) for 133 W.L., File No. SAT—AMD—
             20100514—00102 (filed May 14, 2010).                               .


             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
  June 3, 2010
  Page2


._ simultaneously filing a request for STA to operate Galaxy 12 at 133.0° W.L.
  for 60 days from June 9, 2010 through August 7, 2010.

  From the 133.0° W.L. orbital location, Galaxy 12 will utilize the 5925 — 6425
  MHz and 3700 — 4200 MHz frequency bands. The specific TT&C frequencies
  at 133.0° W.L. are as follows:

  Uplink:

  6424.5 MHz (RHCP), (V)

  Downlink:

  4198 MHz (LHCP), (H)
  4199.875 MHz (LHCP), (v)°
 PanAmSat requests that the waiver of Section 25.283(c) of the Commission‘s
 rules previously granted to the Galaxy 12 spacecraft continue to apply at the
  133.0° W.L. location.‘ Section 25.283(c) of the Commission‘s rules requires
  an applicant to demonstrate that all stored energy will be vented at the
  spacecraft‘s end of life."

  Grant of this STA is in the public interest because it will allow PanAmSat to
 ensure continuity of service to customers despite the technical anomaly on
 Galaxy 15. Galaxy 12 customers have not and will not experience service
 degradation or be otherwise harmed by the satellite‘s operation at 133.0° W.L.
 Grant of the STA also will serve the public interest by affording the
 Commission time to complete its review of PanAmSat‘s pending application to
 relocate Galaxy 12 to, and operate at, 133.0° W.L. PanAmSat understands and
 accepts that grant of this STA request would not prejudge the Commission‘s
 determination of PanAmSat‘s request to operate Galaxy 12 at 133.0° W.L. on a



 © When Galaxy 12 operated at 133.3° W.L., thepolarization was reversed for
 both the uplink and downlink TT&C frequencies. Thus, the uplink frequency
 is now operating in vertical polarization; the downlink frequencies in
 horizontal polarization.

 " See PanAmSat Licensee Corp., Modification ofAuthorization for Galaxy 12
 to 122.9 W.L., File No. SAT—MOD—20080630—00133, condition 3 (stamp grant,
  Sept. 2, 2008).                                                                 '
 ©47 C.F.R. § 25.283(c).


 Ms. Marlene H. Dortch
   June 3, 2010
~— Page 3


 permanent basis, and operation of the satellite at that location pursuant to STA
 is at PanAmSat‘s risk.

 Grant of this STA request will not result in increased risk of harmful
 interference. PanAmSat will continue operating the satellite‘s communications
 payload at 133.0° W.L. in conformance with its sister company Intelsat‘s
 coordination agreements related to the 133.0° W.L. orbital location.

 PanAmSat has assessed and limited the probability of the space station
 becoming a source of debris as a result of collision with large debris or other
 operational space stations. At 133.0° W.L., Galaxy 12 will not be located at
 the same orbital location as another satellite or at an orbital location that has an
 overlapping station—keeping volume with another satellite. Further, PanAmSat
 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 Galaxy 12 at 133.0° W.L. Finally, PanAmSat is not aware of any
 system with an overlapping station—keeping volume with Galaxy 12 at 133.0°
 W.L. that is the subject of an ITU filing and that is either in orbit or
, progressing towards launch.                       '

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

 Sincerely,

 /s/ Susan H. Crandall

 Susan H. Crandall
 Assistant General Counsel
 Intelsat Corporation


 co:     Robert Nelson
         Kathyrn Medley
         Stephen Duall



Document Created: 2010-06-03 15:12:13
Document Modified: 2010-06-03 15:12:13

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