Attachment STA Request

This document pretains to SAT-STA-20100628-00149 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010062800149_825628

June 28, 2010 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Request for Further Extension of Special Temporary Authority for Galaxy 15 Call Sign S2387 Dear Ms. Dortch: PanAmSat Licensee Corp. (“PanAmSat”), pursuant to Section 25.120 of the rules of the Federal Communications Commission (“FCC” or “Commission”),1 herein requests an additional 30 days – through August 2, 2010 – of the Special Temporary Authority (“STA”)2 previously granted PanAmSat to conduct Telemetry, Tracking and Command (“TT&C”) operations on the Galaxy 15 satellite (call sign S2387) outside of the +/- 0.05º East/West station-keeping box pursuant to a waiver of Section 25.210(j) of the Commission’s rules.3 The Galaxy 15 satellite was located at the 133.0º W.L. orbital location.4 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 1 47 C.F.R. § 25.120. 2 PanAmSat has filed this STA request, an FCC Form 159 and an $830.00 filing fee electronically via the International Bureau’s Filing System. 3 47 C.F.R. § 25.210(j). See Policy Branch Information; Actions Taken, Report No. SAT-00698, File No. SAT-STA-20100601-00118 (rel. June 11, 2010, effective June 8, 2010) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00687, File No. SAT-STA-201000430-00087 (rel. May 7, 2010, effective May 6, 2010) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00682, File No. SAT-STA- 20100409-00071 (rel. Apr. 16, 2010, effective Apr. 9, 2010) (Public Notice). 4 See Policy Branch Information; Actions Taken, Report No. SAT-00233, File No. SAT-AMD-20021029-00199 (Aug. 13, 2004) (Public Notice).

Ms. Marlene H. Dortch June 28, 2010 Page 2 authorized +/- 0.05º East/West station-keeping box.5 The satellite currently is located at approximately 128.65º W.L. Grant of this STA further extension request is in the public interest. The Commission may grant a waiver for good cause shown.6 The Commission typically grants a waiver where the particular facts make strict compliance inconsistent with the public interest.7 In granting a waiver, the Commission may take into account consideration of hardship, equity, or more effective implementation of overall policy on an individual basis.8 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. For the reasons set forth herein, PanAmSat respectfully requests that the Commission grant this STA further extension request. Sincerely, /s/ Susan H. Crandall Susan H. Crandall Assistant General Counsel Intelsat Corporation cc: Robert Nelson Karl Kensinger Kathyrn Medley Stephen Duall 5 See PanAmSat Licensee Corp., Request for Special Temporary Authority for Galaxy 15, Call Sign S2387, File No. SAT-STA-20100426-00084 (filed Apr. 26, 2010). 6 47 C.F.R. § 1.3. 7 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.


Document Created: 2010-06-28 12:14:50
Document Modified: 2010-06-28 12:14:50
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