Attachment STA Request

This document pretains to SAT-STA-20110228-00039 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011022800039_871860

February 28, 2011 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, DC 20554 Re: Request for Further Extension of Special Temporary Authority for Galaxy 15, Call Sign S2387 Dear Ms. Dortch: Intelsat License LLC (“Intelsat”)1, pursuant to Section 25.210 of the rules of the Federal Communications Commission (“FCC” or “Commission”),2 herein requests an additional 30 days, from March 4, 2011 through April 2, 2011, of the Special Temporary Authority (“STA”)3 previously granted Intelsat 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.4 1 The licenses previously held by PanAmSat Licensee Corp. (“PanAmSat”) recently have been assigned to Intelsat License LLC. See Letter from Jennifer Hindin to Marlene H. Dortch, Notification of Consummation of Pro Forma Assignment and Transfer of Control and Name Change, File Nos. SES-ASG- 20101203-01501, SES-ASG-20101206-01502, SES-T/C-20101203-01503, SES- ASG-20101203-01504, SES-ASG-20101206-01512, SAT-ASG-20101203- 00251, SAT-ASG-20101203-00252, SAT-T/C-20101203-00253, SAT-T/C- 20101203-00254, and 0004520968 (filed Jan. 18, 2011). 2 47 C.F.R. § 25.210. 3 Intelsat has filed this STA request, an FCC Form 159 and an $830.00 filing fee electronically via the International Bureau’s Filing System. 4 47 C.F.R. § 25.210(j). See Policy Branch Information; Actions Taken, Report No. SAT-00755, File No. SAT-STA-20110127-00017 (Feb. 4, 2011) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00750, File No. SAT-STA-20101228-00268 (Jan. 14, 2011) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00741, File No. SAT- STA-20101129-00248 (Dec. 3, 2010) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00735, File No. SAT-STA- 20101029-00227 (Nov. 5, 2010) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00727, File No. SAT-STA-20100929-00203 (Oct. 8, 2010) (Public Notice); Policy Branch Information; Actions Taken,

Ms. Marlene H. Dortch February 28, 2011 Page 2 As the Commission is aware, on April 5, 2010, the Galaxy 15 satellite suffered an anomaly of unknown origin. Due to this anomaly, the satellite drifted outside of its authorized +/- 0.05º East/West station-keeping box pursuant to STA.5 On December 23, 2010, Galaxy 15 lost Earth lock, all power drained from its batteries, and the command unit reset, as it was designed to do.6 Shortly thereafter, Galaxy 15 began accepting commands and Intelsat began receiving telemetry from the satellite. The satellite initially was placed in Sun acquisition mode for diagnostic testing. On December 27, 2010, after the spacecraft’s batteries were fully charged and the satellite was thermally balanced, Galaxy 15 was placed in Earth acquisition mode. Currently, Galaxy 15 is drifting west to 133.1° W.L. where it will temporarily be collocated with Galaxy 12, which operates at 133.0° W.L. Intelsat currently expects Galaxy 15 to be on-station at 133.1° W.L. on April 3, 2011. During the duration of this requested STA extension period, Intelsat will continue to utilize only the satellite’s TT&C frequencies7 unless operation of the communications frequencies is separately authorized.8 Report No. SAT-00720, File No. SAT-STA-20100830-00185 (Sep. 10, 2010) (Public Notices); Policy Branch Information; Actions Taken, Report No. SAT- 00715, File No. SAT-STA-20100803-00172 (Aug. 13, 2010) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00706, File No. SAT-STA-20100628-00149 (Jul. 9, 2010) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00698, File No. SAT-STA- 20100601-00118 (Jun. 11, 2010) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00687, File No. SAT-STA-20100430-00087 (rel. May 7, 2010); Policy Branch Information; Actions Taken, Report No. SAT- 00682, File No. SAT-STA-20100409-00071 (Apr. 16, 2010) (Public Notice). 5 See supra n.4. 6 The satellite’s communications payload had earlier shut off as a result of power loss. 7 The specific TT&C frequencies are: 6420.5 MHz (V) and 6424.5 MHz (RHC) (uplink) and 4198.0 MHz (H), 4199.875 (H), 4198.0 (LHC), and 4199.875 (LHC) (downlink). 8 Intelsat has a pending STA request to operate the Galaxy 15 communications payload at 133.1° W.L. See Intelsat License LLC Request for Special Temporary Authority to Drift and Operate Galaxy 15, File No. SAT-STA- 20110209-00028 (filed Feb. 9, 2011).

Ms. Marlene H. Dortch February 28, 2011 Page 3 Grant of this STA further extension request is in the public interest. The Commission may grant waiver for good cause shown." The Commission typically grants a waiver where the partlcular facts make strict compliance inconsistent with the public interest."" In granting a waiver, the Commission may take into account considerations of hardship, equlty, or more effective implementation of overall policy on an individual basis."‘ 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, Intelsat was unable to comply with the requirements of Section .25.210(J) of the Commission‘s rules. Now that Intelsat is able to command Galaxy 15, it will ensure the satellite‘s safe station—keeping during its drift west to 133.1° W.L. and while it is on—station at that location. For the reasons set forth herein, Intelsat respectfully requests that the Commission expeditiously grant this STA further extension request. Sincerely, (CJ—4L CACQ Susan H. Crandall Assistant General Counsel Intelsat Corporation ce: Robert Nelson Karl Kensinger Kathyrn Medley Stephen Duall °47 CFR. § 1.3. NE. Cellular Tel. Co. v. FCC, $97 F.24 1164, 1166 (D.C. Cir. 1990) ("Northeast Cellular®). 4 WAIT Radio v. FCC, 418 F.24 1153, 1159 (D.C. Cir. 1969), Northeast Cellular 897 F.2d at 1166.


Document Created: 2011-02-28 15:54:42
Document Modified: 2011-02-28 15:54:42
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