Attachment STA Request

This document pretains to SAT-STA-20110503-00083 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011050300083_887346

May 3, 2011



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

Re:      Request for Special Temporary Authority to De-Orbit the Intelsat 3R
         Satellite, Call Sign PAS-2R

Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”), pursuant to Section 25.120 of the rules of the
Federal Communications Commission (“FCC” or “Commission”),1 herein
requests Special Temporary Authority (“STA”), beginning on July 1, 2011 and
lasting for a period of thirty days, to de-orbit the Intelsat 3R satellite (Call Sign
PAS-2R) from its current location at 81.0° W.L.2 and to perform telemetry,
tracking and command (“TT&C”) functions with Intelsat 3R during this
maneuver.

Grant of this STA is in the public interest. The Intelsat 3R satellite was
launched in 1996 and is nearing the end of its useful life. Intelsat seeks to
commence de-orbiting the spacecraft sometime between July 1, 2011 and July
30, 2011.

Intelsat intends to de-orbit the Intelsat 3R satellite to a perigee 150 km above
synchronous altitude. Intelsat has reserved 27.6 kilograms of fuel for this
purpose. To calculate the reserved fuel figure, Intelsat used the “rocket

1
    47 C.F.R. § 25.120.
2
 See Intelsat License LLC Request for Further Extension of Special
Temporary Authority, File No. SAT-STA-20110426-00078 (filed Apr. 26,
2011); 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).


Marlene H. Dortch, Secretary
May 3, 2010
Page 2

equation” – i.e., it used the expected mass of the satellite at the end of life and
the required delta-velocity to achieve the desired orbit. Intelsat has assessed
the fuel gauging uncertainty and believes it has provided an adequate margin
of fuel reserve to address the uncertainty in the remaining propellant. As a
satellite launched prior to March 18, 2002, the minimum perigee requirements
for decommissioning set forth in Section 25.283(a) of the Commission’s rules
do not apply to Intelsat 3R.3

The de-orbit of Intelsat 3R will not cause any significant risk of harmful
interference to other satellites. During the de-orbit, the satellite’s
communications payload will remain inactive and only the TT&C payload will
operate. Intelsat requests authority to operate the following TT&C
frequencies: 6424.5 MHz (H) and 5925.5 MHz (H) (command uplink); 4198.5
MHz (H)(V) and 4199.0 MHz (H)(V) (telemetry downlink). These
frequencies will be coordinated and will operate on a non-interference basis.4

Finally, consistent with Section 25.283(c), upon completion of de-orbit
maneuvers, all stored energy sources will be discharged by venting excess
propellant, discharging batteries, relieving pressure vessels, and other
appropriate measures.5




3
    47 C.F.R. § 25.283(d).
4
    See 47 C.F.R. § 25.283(b).
5
  Intelsat notes that in a recent pleading filed by the Satellite Industry
Association (“SIA”), the Intelsat 3R satellite was included as a satellite whose
design does not permit all pressure vessels to be relieved at end of life. See
Satellite Industry Association, Request for Blanket Waiver of Section 25.283(c)
of the Commission’s Rules, IB Docket No. 02-54, Annex 1 (filed Oct. 1, 2010).
The inclusion of the Intelsat 3R on this list is an error; the Intelsat 3R satellite
is capable of venting all stored energy sources at the end of life.


Marlene H. Dortch, Secretary
May 3, 2010
Page 3

For the reasons set forth herein, Intelsat respectfully requests that the
Commission expeditiously grant this request for special temporary authority to
de-orbit the Intelsat 3R satellite.

Sincerely,

/s/ Susan H. Crandall

Susan H. Crandall
Assistant General Counsel
Intelsat Corporation


cc:    Bob Nelson
       Karl Kensinger
       Kathyrn Medley
       Stephen Duall



Document Created: 2011-05-03 11:41:59
Document Modified: 2011-05-03 11:41:59

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