Attachment STA Request

This document pretains to SAT-STA-20110325-00061 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011032500061_878860

March 25, 2011


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

Re:    Request for Special Temporary Authority to Continue Operating the
       Communications Payload on Intelsat 709 at 54.85º E.L., Call Sign
       S2396

Dear Ms. Dortch:

Intelsat License LLC (f/k/a Intelsat North America LLC) (“Intelsat”) herein
requests Special Temporary Authority (“STA”)1 for 30 days—from April 1,
2011 through April 30, 2011—to continue operating the communications
payload on the Intelsat 709 satellite (call sign S2396) at the 54.85º E.L. orbital
location.

Intelsat 709 is currently operating at 54.85º E.L. pursuant to the International
Telecommunication Union (“ITU”) filings of the Indian Administration. The
FCC authorization for Intelsat 709 to operate at this location includes the
following condition:

       “19. Intelsat is authorized to operate the communications
       payload of the Intelsat 709 satellite at the 54.85º E.L. orbital
       location until expiration of its current agreement with ISRO,
       which has been extended until March 31, 2011. See
       Attachment, IBFS File No. SAT-STA-20101207-00256. After
       this date, Intelsat must either seek authority from the
       commission to extend the term of this authorization or cease
       operating the communications payload of the Intelsat 709 at the
       54.85º E.L. orbital location. Intelsat may continue to operate
       the TT&C payload after this date.”2

The purpose of this STA request is to seek continued authority to operate
Intelsat 709 at 54.85º E.L. prior to its planned relocation to the 72.10° E.L.



1
  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
  Intelsat North America LLC, Modification to Relocate and Operate Intelsat
709 at 54.85 E.L., IBFS File No. SAT-MOD-20091106-00117, Condition 19
(stamp grant with conditions, Feb. 11, 2011).


Ms. Marlene H. Dortch
March 25, 2011
Page 2


orbital location on May 15, 2011.3 Intelsat will file another STA request
seeking the necessary authority to operate Intelsat 709 through the end of May
2011. Prior to the relocation of Intelsat 709, and subject to receipt of FCC
approval, traffic at the 54.85° E.L. orbital location will be transferred to the
Intelsat 702 satellite.4

Intelsat expects to extend its current agreement with the Indian Administration
and will file a copy of the extension when it becomes available.

All information regarding the operation of the Intelsat 709 satellite at 54.85°
E.L. has been provided in Intelsat’s current authorization and is incorporated
herein by reference.5 Intelsat will continue to comply with all conditions of its
authorization to operate at the 54.85° E.L. orbital location, and asks that the
Part 25 waivers originally granted to the Intelsat 709 spacecraft continue to
apply, namely, the waivers of Sections 25.202(g), 25.210(a)(1), 25.210(a)(3),
25.210(c), 25.210(i) and 25.211(a) of the Commission’s rules.6

Grant of this STA request is in the public interest because it will allow Intelsat
to ensure continuity of service at the 54.85° E.L. location pending arrival of the
Intelsat 702 satellite. Moreover, grant of this STA request will not result in
increased risk of harmful interference. As noted above, Intelsat will operate
pursuant to its current authorization.




3
  Request for Special Temporary Authority to Drift and Operate Intelsat 709,
File No. SAT-STA-20110316-00055 (filed Mar. 16, 2011).
4
  See Request for Special Temporary Authority to Drift and Operate Intelsat
702, Call Sign S2388, File No. SAT-STA-20110307-00051 (filed Mar. 7,
2011).
5
  See supra note 2.
6
  See Applications of Intelsat LLC for 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 Rcd 15460,
15529 (Appendix C) (2000) (Memorandum Opinion and Order and
Authorization), recon. denied, 15 FCC Rcd 25234 (2000) (Order on
Reconsideration).


  Ms. Marlene H. Dortch
  March 25, 2011
  Page 3


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




  Ascaee.
  Sincerely,




   Susan H. Crandall
._ Assistant General Counsel
  Intelsat Corporation

  cc: Stephen Duall
      Kathyrn Medley



Document Created: 2011-03-25 16:14:11
Document Modified: 2011-03-25 16:14:11

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