Attachment STA Request

This document pretains to SAT-STA-20100610-00128 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010061000128_821791

            . June 10, 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 to
                       Drift and Operate Intelsat 709
                      . Call Sign: 82396


             Dear Ms. Dortch:

             Intelsat North America LLC ("Intelsat") herein requests a 60—day extension ——
             from June 15, 2010 through August 13, 2010 —— of the Special Temporary
             Authority ("STA")1 previously granted Intelsat to drift Intelsat 709 (call sign
             $2396) from $5.15° E.L. to54.85° E.L. and begin operating at 54.85° E.L.*
             Intelsat 709is currently operating at 54.85° E.L. pursuant to the ITU filings of
             the Indian Agiministration.3 Intelsathas a pending application for permanent




             ‘ Intelsat has filed this STA request, an FCC Form159 and an $830.00 filing
             fee electronically via the International Bureau‘s Filing System.

              * See Policy Branch Information; Actions Taken, Report No. SAT—00666, File
            _ No. SAT—STA—20100111—00006 (Feb. 19, 2010) (Public Notice); Intelsat also
              has a pending request for extension of STA seeking authority through June 14,
             2010, File No. SAT—STA—20100412—00074, (filed Apr. 12, 2010). Intelsat had
             also requested and was granted STA to continue to drift Intelsat 709 past
             54.85° E.L. to 50.0° E.L. and to operate it at 50.0° E.L. for 10 days pursuant to
             the ITU filings of the administration of Turkey before drifting the satellite back
             to 54.85° E.L. See Policy Branch Information; Actions Taken, Report No.
             SAT—00677, File No. SAT—STA—20100315—00046 (Apr. 2, 2010) (Public
             Notice).

             * Intelsat‘s latest extension of its agreement with the Indian Administration
             allows Intelsat to operate a satellite at 54.85° E.L. through December 31, 2010.
             That extension was attached to a previously—filed STA request (see File No. _
             SAT—STA—20091201—00134) and is incorporated herein by reference. Intelsat
             anticipates entering into a further agreement with the Indian Administration
             that will allow Intelsat to operate a satellite in the Ku—bandat 54.85° E.L
             beyond June 30, 2010.



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


 Ms. Marlene H. Dortch _
 June 10, 2010
 Page 2


 authority to redeploy Intelsat 709 to 54.85° E.L., where it will operate 1n the C—
 and Ku—bands pursuant to the ITU filings of the Indlan Administration.*
 Intelsat thus seeks extension of its original STA to continue operating at 54.85°
 E.L. pending action on the application for permanent authority.

 Grant of this STA extension request is in the public interest because it will
 allow Intelsat to ensure continuity of service to customers in the Indian Ocean
 region at 54.85° E.L. Intelsat has a pending modification application to
 relocate the Intelsat 706 satellite from this location to 72.1° E.L.

— Grant of this STA request will not result in increased risk of harmful
 interference. Intelsat will continue to operate Intelsat 709 in conformance with
 the Indian Administration‘s coordination agreements related to the nominal
 55.0° E.L. location. Intelsat also will continue to operate Intelsat 709 at 54.85°
 E.L. consistent with the conditions previously imposed on Intelsat‘s operation
 of Intelsat 709 at this same orbital location."

 Intelsat 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. Except during the transition of traffic from Intelsat 706, Intelsat
 709 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, Intelsat is not aware of any other FCC licensed system, or
 any other system applied for and under consideration by the FCC, having an



 * See Application ofIntelsat North America to Modify License for Intelsat 709,
 File No. SAT—MOD—20091106—00117 (filed Nov. 6, 2009); Application of
 Intelsat North America LLC to Amend Applzcanon File No. SAT—AMD—
 20100104—00003 (filed Jan. 4, 2010).

 * See IBFS Flle Nos. SAT—MOD—2010051 1—00098 and SAT—AMD-20100104-
 0003; See Satellite Policy Branch Information, Satellite Space Applications
 Acceptedfor Filing, Report No. SAT—00662 (Jan. 29, 2010) (Public Notice).
 Intelsat also has a pending request for special temporary authority to relocate
 the Intelsat 706 satellite to 72.1° E.L. See IBFS File No. SAT—STA—20100326—
 00057; See Satellite Policy Branch Information, Satellite Space Applications
 Acceptedfor Filing, Report No. SAT—00693 (May 28, 2010) (Public Notice).

 6 See Policy Branch Information; Actions Taken, Report No. SAT—00666, File
 No. SAT—STA—20100111—00006 (Feb. 19, 2010) (Public Notice).


Ms. Marlené H. Dortch
June 10, 2010
Page 3


overlapping station—keeping volume with Intelsat 709. Finally, Intelsat is not
aware of any system with an overlapping station—keeping volume with Intelsat
709 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 expeditiously grant this request.

Sincerely,        /

/s/ Susan H. Crandall

Susan H. Crandall
Assistant General Counsel
Intelsat Corporation


cc: Karl Kensinger
    Kathyrn Medley:
    Stephen Duall



Document Created: 2019-04-23 12:54:46
Document Modified: 2019-04-23 12:54:46

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