Attachment STA Request

This document pretains to SAT-STA-20101006-00210 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010100600210_844280

October 6? 2010



Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12" Street, S.W.
Washington, DC 20554

Re:       Request for Special Temporary Authorlty for Intelsat 705 to Dr1ft to
          304.6° E.L. (55.4° W.L.)
          Call Sign: $2395

Dear Ms. Dortch:

Intelsat North America LLC ("Intelsat") herein requests Special Temporary~
Authority (“STA”)1 for 100 days — from November 30, 2010 through March 9,
2011 —to drift the Intelsat 705 satellite (call sign $2395) from 330.5° E.L.
(29.5° W.L.] to 304.6° EL. (55.4° W.L.). Intelsat expects to have the satellite
on—station at 304.6° E.L. at the end of February 2011. Intelsat intends shortly
to file an STA request to temporarily operate the Intelsat 705 satellite at 304.6°
E.L. (55.4° W.L.), where it will be located adjacent to Intelsat 805 which is
located at 304.5° E.L. (55.5° W.L.}," beginning in March 2011.* Intelsat 705
currently is co—located with the Intelsat 801 satellite (call sign $2391) at 330.5°
EL., ;cmd no frequencies will be left vacant at 330.5° E.L. as a result of this
STA.                                                 >


‘ Intelsat has filed this STA request, an FCC Form 159 and an $830.00 filing
fee electronically via the International Bureau‘s Filing System.
2 See Policy Branch Information; Actions Taken, Report No. SAT—00723, File
No. SAT—MOD—20100115—00010 (Sept. 24, 2010) (Public Notice).
* See Applications ofIntelsat LLCfor Authority to Operate and Further
Construct, Launch, and Operate C—Band and Ku—Band Satellites that Form a
Global Communications System in Geostationary Orbit, 15 FCC Red 15460,
15529 (Appendix C) (2000) (Memorandum Opinion and Order and
Authorization), recon. denied, 15 FCC Red 25234 (2000) (Order on
Reconsideration).
* Intelsat expects to de—orbit Intelsat 705 from the 304.6° E.L. (55.4° W.L.)
location. The satellite‘s estimated end of maneuver life, assuming the drift, is
January 2012. The Commission previously approved the de—orbit plan for
Intelsat 705. See Intelsat North America LLC, Application to Modify
Authorization for Intelsat 705 (S$2395), File No. SAT—MOD—20100115—00010
gfiled Jan. 15, 2010) (stamp granted with conditions Sept. 17, 2010).
 See Intelsat North America LLC, Application to Modify Authorization for
Intelsat 801 (S2391), File No. SAT—MOD—20100208—00024 (filed Feb. 8,
2010) (stamp granted with conditions Sept. 23, 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
    October 6, 2010
    Page 2


| : During the drift,; Intelsat will utilize only Intelsat 705‘s TT&C frequencies and
   will follow industry practices for coordinating TT&C transmissions during the
   relocation process. The specific TT&C frequencies are as follows:


   Uplink:

    6173.7 MHz (LHCP) _
  —6176.3 MHz (LHCP)
   Downlink:

    3947.5 MHz (RHCP)
    3948.0 MHz (RHCP)                  \
    3952.5 MHz (RHCP)
    3952.0 MHz (RHCP) >
   Grant of this STA request is in the public interest because it will enable Intelsat
   to begin drifting Intelsat 705 in order to satisfy customer capacity requirements
   at 304.6° E.L. (55.4° W.L.). Specifically, a customer will commence service
   on Intelsat 705 until the planned relocation of another Intelsat satellite to the
   nominal 304.5° E.L. location in mid—2011. Intelsat understands and accepts _
   that a grant of this drift STA would not prejudge the Commission‘s
   determination of Intelsat‘s request to operate Intelsat 705 temporarily at 304.6°
   E.L. (55.4° W.L.), and relocation of the satellite to that location pursuant to
    STA is at Intelsat‘s risk.

   Grant of this STA request will not result in increased risk of harmful
   interference. As noted above, Intelsat will operate only TT&C frequencies
   during the drift and will coordinate its TT&C transmissions with operators of
   satellites in the drift path. Should any interference occur during the drift,
   Intelsat will take all reasonable steps to eliminate such interference. At 304.6°
   E.L. (55.4° W.L.), Intelsat will operate only the satellite‘s TT&C frequencies _
   unless separately authorized also to operate the communications payload.

   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. Intelsat 705 will not be located at the same orbital location as
   another satellite or at an orbital location that has an overlapping station—


Ms. Marlene H. Dortch
October 6, 2010
Page 3


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 705 at 304.6° E.L. (55.4° 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 ITU filing and that is either in orbit or progressing
towards launch.

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

Sincerely,




Susan H. Crandall
Assistant General Counsel
Intelsat Corporation



cc:    Bob Nelson
       Karl Kensinger
       Kathyrn Medley
       Stephen Duall




° Intelsat 705 will continue to be operated in inclined orbit.



Document Created: 2010-10-06 15:32:23
Document Modified: 2010-10-06 15:32:23

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