Attachment STA Request

This document pretains to SAT-STA-20100810-00175 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010081000175_834502

              August 10, 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 to
                       Drift and Operate Intelsat 709 |
                       Call Sign $2396


             Dear Ms. Dortch:

             Intelsat North America LLC ("Intelsat") herein requests an additional 60—day
             extension —— from August 14, 2010 through October 12, 2010 —— of the Special
             Temporary Authority ("STA")‘ previously granted Intelsat to drift Intelsat 709
             (callsign $2396) from §5.15° E.L. to 54.85° E.L. and begin operating at 54.85°
             EL.‘ Intelsat 709 is currently operatlng at 54.85° E.L. pursuant to the ITU
             filings of the Indian Administration." Intelsat has a pending application for
             permanent authority to redeploy Intelsat 709 to 54.85° E.L., where it will
             operate in the C- and Ku—bands pursuant to the ITU filings of the Indian
             Administration." Intelsat thus seeks further extension of its original STA to




              ‘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—00666, File
             No. SAT—STA—20100111—00006 (Feb. 19, 2010) (Public Notice); Policy
             Branch Information; Actions Taken, Report No. SAT—00702, File No. SA¥T—
             STA—20100412—00074, (Jun. 25, 2010) (Public Notice); Policy Branch
             Information; Actions Taken, Report No. SAT—00706, File No. SAT—STA—
             20100610—00128 (Jul. 9, 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—20100610—00128) and is incorporated herein by reference.

            * See Policy Branch Information, Satellite Space Applications Acceptedfor
             Filing, Report No. SAT—00662, File Nos. SAT—MOD—20091106—00117 and
             SAT—AMD—20100104—00003 (Jan. 29, 2010) (Public Notice).




             Intelsat Corporation
             3400 international Drive NW, Washington DC 20008—3006 USA www.intelsat.com T4+1 202—944—6800 F+1 202—944—7898


Ms. Marlene H. Dortch
August 10, 2010
Page 2


continue operating at 54.85° E.L. pendmg action on the application for
permanent authority.

Grant of this STA further 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. Grant also will allow the Commission more time
in which to consider the pending application for permanent authority.

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 prev1ously imposed on Intelsat‘s operation
of Intelsat 709 at this same orbital locatlon

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. 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 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.




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


Ms. Marlene H. Dortch
Auguest 10, 2010
Page 3


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

Sincerely,                     ¢




Susan H. Crandall —                         ‘
Assistant General Counsel
Intelsat Corporation


ce: Karl Kensinger
    Kathyrn Medley
    Stephen Duall



Document Created: 2010-08-10 12:09:21
Document Modified: 2010-08-10 12:09:21

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