Attachment STA Request

This document pretains to SAT-STA-20100624-00146 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010062400146_824308

             June 24, 2010


             Ms. Marlene H. Dortch
             Secretary
             Federal Communications Commission
             445 12"" Street, S.W.
             Washington, DC 20554
INTELSAT.
             Re:         Request for Further Extension of Special Temporary Authority for
                         Intelsat 705 to Drift to and Operate at 330.5° E.L. (29.5° W.L.)
                         Call S1gn $2395

             Dear Ms. Dortch:

             Intelsat North America LLC ("Intelsat") herein requests an additional 60—day
             extens1on through August 26, 2010 — of the Special Temporary Authority
             ("STA") 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° WL.) 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 is currently co—
             located with Intelsat 801.*

             Grant of this STA further extension request is in the public interest because it
             will enable Intelsat to continue to provide robust service to customers. In
             particular, the Intelsat 705 satellite is currently being used at the 330.5° E.L. _
             (29.5° W.L.) orbital location to provide 2010 World Cup—related transmissions




            — * 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); Report
             No. SAT—00687, File No. SAT—STA—20100423—00083 (May 7, 2010) (Public
             Notice).
             3 IntelsatNorth 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
             Intelsat 801, File No. SAT—STA—20100416—00079 (filed April 16, 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 24, 2010
Page 2


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 further 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 to
further extend this 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 further extension request will not result in increased risk of
harmful 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 Comm1ss1on 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 is notlocated at the 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
TITU filing and that is either in( orbit or progressing towards launch.




* 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.                                                 :


Ms. Marlene H. Dortch
June 24, 2010
Page 3


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

Sincerely, .




Susan H. Crandall
Assistant General Counsel
Intelsat Corporation




co:      Bob Nelson
         Karl Kensinger
         Kathyrn Medley
         Stephen Duall



Document Created: 2019-04-17 02:27:31
Document Modified: 2019-04-17 02:27:31

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