Attachment STA Request

This document pretains to SAT-STA-20110426-00078 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011042600078_886316

April 26, 2011 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Request for 30-Day Further Extension of Special Temporary Authority for Intelsat 3R Call Sign: PAS-2R Dear Ms. Dortch: Intelsat License LLC (“Intelsat”) herein requests an additional 30-day extension -- from April 30, 2011 through May 29, 2011 -- of the Special Temporary Authority (“STA”)1 previously granted Intelsat to drift Intelsat 3R (call sign PAS-2R) from 43.1º W.L. to 81.0º W.L. and operate the satellite temporarily at 81.0º W.L. in accordance with the Argentine Administration’s ITU filings in the C- and Ku-bands.2 In 2009, the estimated fuel on the Intelsat 3R satellite resulted in a planned de- orbit date in early-to-mid 2010. Intelsat has since extended the satellite’s estimated End of Maneuver Life through July 1, 2011 after an annual fuel usage evaluation. Intelsat also has a pending 180-day request for special temporary authority to continue to operate Intelsat 3R at 81.0º W.L. in accordance with the Argentine Administration’s ITU filings in the C- and Ku-bands and to extend the license term of the Intelsat 3R satellite through July 31, 2011.3 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 See Intelsat License LLC Request for Further Extension of Special Temporary Authority, File No. SAT-STA-20110325-00063 (filed Mar. 25, 2011); Intelsat License LLC Request for Extension of Special Temporary Authority, File No. SAT-STA-20110223-00032 (filed Feb. 23, 2011); PanAmSat License Corp. Request for Extension of Special Temporary Authority, File No. SAT-STA- 20110110-00008 (filed Jan. 10, 2011); Policy Branch Information; Actions Taken, Report No. SAT-00713, File No. SAT-STA-20100402-00063 (Aug. 6, 2010); PanAmSat Licensee Corp., Request for Special Temporary Authority for Intelsat 3R (Call Sign PAS-2R), File No. SAT-STA-20100402-00063 (filed Apr. 2, 2010) (stamp grant with conditions Aug. 3, 2010). 3 See PanAmSat Licensee Corp., Request for Special Temporary Authority for Intelsat 3R, (Call Sign PAS-2R), File No. SAT-STA-20110110-00009 (filed Jan. 10, 2011).

Ms. Marlene H. Dortch April 26, 2011 Page 2 Grant of this further STA extension request is in the public interest because it will allow Intelsat to continue to meet customer demand at 81.0º W.L. Continued operation of Intelsat 3R will also allow Intelsat to maximize the utility of its in-orbit assets. Grant of this further STA extension request will not result in increased risk of harmful interference. Intelsat will continue operating the satellite’s communications payload at 81.0º W.L. in accordance with Argentina’s C- and Ku-band ITU filings. Intelsat incorporates by reference its previously-filed letters demonstrating its authority to operate Intelsat 3R at 81.0º W.L.4 As requested in its previous STA extension requests, Intelsat also seeks authority to extend the license term of the Intelsat 3R satellite for the duration of this STA.5 The Intelsat 3R satellite was launched and placed into service on February 1, 1996.6 Pursuant to the satellite’s fifteen-year license term, this authorization was to expire on February 1, 2011.7 Intelsat now anticipates that Intelsat 3R has sufficient fuel to continue providing service to customers through July 1, 2011. Grant of this application is consistent with the Commission’s end-of-life rules. Intelsat anticipates that Intelsat 3R has sufficient fuel to continue providing service to customers through July 1, 2011. At that time, based on standard industry fuel gauging methods, Intelsat anticipates having adequate fuel to de- orbit the Intelsat 3R satellite to a perigee altitude of 150 km above the 4 PanAmSat Licensee Corp., Request for Special Temporary Authority for Intelsat 3R (Call Sign PAS-2R), File No. SAT-STA-20100402-00063 at Attachments 1 and 2 (filed Apr. 2, 2010) (stamp grant with conditions Aug. 3, 2010). 5 See Intelsat License LLC Request for Further Extension of Special Temporary Authority, File No. SAT-STA-20110325-00063 (filed Mar. 25, 2011); Intelsat License LLC, Request for Extension of Special Temporary Authority, File No. SAT-STA-20110223-00032 (filed Feb. 23, 2011); PanAmSat License Corp. Request for Extension of Special Temporary Authority, File No. SAT-STA- 20110110-00008 (filed Jan. 10, 2011); 6 See Letter from Joseph A. Godles to Marlene H. Dortch, PanAmSat Licensee Corp. Annual Status Report at 5 (filed June 30, 2005). 7 See 47 C.F.R. § 25.121(a).

Ms. Marlene H. Dortch \ April 26, 2011 Page 3 _ geostationary arc.Finally, the requested license extension is consistent with precedent for satellites that are performing well.> For the reasons set forth herein, Intelsat respectfully requests that the Commission grant this STA extension request and extend the license period. Sincerely, @M/QQ Susan H. Crandall Assistant General Counsel Intelsat Corporation co: Robert Nelson Karl Kensinger Kathyrn Medley Stephen Duall 8 See, eg. SES Americon, Inc., Application for Modification ofthe Satcom C—3 License to Extend the License Term, File No. SAT—MOD—20080318—00073 (stamp grant June 11, 2008) (granting three—year extension of license term); Pan4mSat Licensee Corp., SBS—6 Modification to Extend License Term, File No. SAT—MOD—20051020—00204 (stamp grant Aug. 17, 2006) (granting five— year extension of license term).


Document Created: 2011-04-26 16:39:23
Document Modified: 2011-04-26 16:39:23
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