Attachment STA Request

This document pretains to SAT-STA-20100823-00180 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010082300180_835966

           _ August 23, 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 Slgn $2395

            Dear Ms. Dortch:

            Intelsat North America LLC ("Intelsat") herein requests an additional 60—
            day extension — through October 25, 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°
            W.L.) 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 operaté at, 330.5° EL.
            (29.5° W.L.)," where it is currently co—located with Intelsat sor.*

            Grant of this STA further extension request is in the pubhc interest because
            it will enable Intelsat to continue to provide robust service to customers.




            * 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); Report No. S¥AT—00709, File No. SAT—STA—
            20100624—00146 (Jul. 23, 2010) (Public Notice).
            * See Policy Branch Information; Actions Taken, Report No. SAT—00669,
            File No. SAT—MOD—20100115—00010 (Mar. 5, 2010).
            * See Policy Branch Information; Actions Taken, Report No. SAT—00668,
            File No. SAT—STA—20091216—00146 (Feb. 26, 2010) (Public Notice);
            Report No. SAT—00690, File No. SAT—STA—20100416—00079 (May 14,
            2010); Report No. SAT—00715, File No. SAT—STA—20100616—00139 (Aug.
            ©13, 2010); Intelsat North America LLC, Requestfor Extension ofSpecial
            Temporary Authorityfor Intelsat 801, File No. SAT—STA—20100816—00177
            (filed Aug. 16, 2010).



            Ifitelsat 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
August 23, 2010
Page 2 .
                                                              [(


.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 continue to operate the satellite‘s communications payloadin
conformance with its coordination agreements covering the location as well
as the Commission‘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 not
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, 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 networkwith an overlapping station—keeping volume with
Intelsat 705 that is the subject of an ITU filing and that is either in orbit or
progressing towards launch.




5 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
 August 23, 2010
 Page 3 .



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

 Sincerely,



  @«JLQ/QQ \
 Susan H. Crandall
 Assistant General Counsel
 Intelsat Corporation




 ce:     Bob Nelson
         Karl Kensinger
         Kathyrn Medley
         Stephen Duall



Document Created: 2010-08-23 16:49:16
Document Modified: 2010-08-23 16:49:16

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