Attachment STA Request

This document pretains to SAT-STA-20110510-00088 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011051000088_888837

            May 10, 2011


            Ms. Marlene H. Dortch
            Secretary
            Federal Communications Commission
            445 12"" Street, S.W.
            Washington, DC 20554
INTELSAT.   Re:         Request for Extension of Special Temporary Authority to Drift and
      /
                        Operate Intelsat 702
                        Call Sign $2388


            Dear Ms. Dortch:

            Intelsat License LLC ({/k/a Intelsat North America LLC) ("Intelsat") herein —
            requests a 30—day extensmn through June 12, 2011, of the Special Temporary
            Authority ("STA")‘ previously granted Intelsat to dr1ft Intelsat 702 (call 51gn
            $2388) from 66.0° E.L. to 54.85° E.L. and begin operating at 54.85° E.L. 1n the
            C— and Ku—bands pursuant to the ITU filings of the Indian Administration." At
            54.85° E.L., Intelsat 702 will replace Intelsat 709, which Intelsat plans to
            redeploy to 72 10° E.L.

            Intelsat 702 recently arrived on station 54.85° E.L. As noted in the original
            STA request, Intelsat expects Intelsat 702 to operate at 54.85° E.L. for
            approximately three months, after which it will be relocated.. Following traffic
            transfer from Intelsat 709 to Intelsat 702, Intelsat 709 will be relocated to_
            72.10° E.L. as noted above.

            Intelsat 702 will continue to operate at 54.85° E.L. in the following
            frequencies. The specific TT&C frequencies are as follows:


            ‘ Intelsat has filed this STA extension request, an FCC Form 159 and an
            $830.00 filing fee electronically via the International Bureau‘s Filing System.
            * See Policy Branch Information; Actions Taken, Report No. SAT—00772, File
            No. SAT—STA—20110307—00051 (Apr. 15, 2011). Intelsat‘s recent extension of
            its agreement with the Indian Administration allows Intelsat to operate a
            satellite at 54.85° E.L. through June 30, 2011. That extension was filed as a
            supplement to the original STA request and is incorporated herein by
            reference. See Letter from Susan H. Crandall, Intelsat, to Marlene H. Dortch,
            FCC, File No. SAT—STA—20110307—00051 (Mar. 29, 2011).
            * See Intelsat License LLC, Application to Modify Authorization for Intelsat
            709 (§2396), File No. SAT—MOD—20110428—00081 (filed Apr. 28, 2011); see
            alsoIntelsat License LLC Requestfor Special Temporary Authority, Flle No.
            SAT—STA—20110316—00055 (filed Mar. 16, 2011)


            Intelsat Corporation                                                                   .
            3400 International Drive NW, Washington DC 20008—3006 USA www.intelsat.com T +1 202—944—6800 F41 202—944—7898


Ms. Marlene H. Dortch
May 10, 2011
Page 2


Uplink:

6173.7 MHz and 6176.3 MHz (LHCP)

Downlink:

3947.5 MHz and 3948.0 MHz (RHCP)
3952.5 MHz and 3952.0 MHz (RHCP)
’Il‘he specific communications payload frequencies are as follows:

Uplink:

5925—6425 MHz
14.0—14.5 GHz

Downlink:

3700—4200 MHz
10.95—11.2 GHz
1145—11.7 GHz
12.5—12.75 GHz*
Intelsat requests that the Part 25 waivers originally granted to the Intelsat 702
spacecraft continue to apply at the 54.85° E.L. location, 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.

Grant of this STA request is in the public interest because it will allow Intelsat
to ensure continuity of service to customers in theIndian Ocean region for a
few more months. Intelsat will ensure that any of its customers at 54.85° E.L.

                                          &

* Although Intelsat 702 also has the capability to transmit in the frequency
band 11.7—11.95 GHz, Intelsat does not intend to utilize this frequency band
from the 54.85° E.L. orbital location.
° 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).


Ms. Marlene H. Dortch
May 10, 2011      '
Page 3


whose contracts have not terminated are moved to other satellites before
Intelsat 702 leaves the location.

Grant of this STA request will not result in increased risk of harmful
interference. At 54.85° E.L., Intelsat will continue to operate the
communications payload in conformance with the Indian Administration‘s
coordination agreements related to the nominal 55.0° E.L. location. Intelsat
also agrees to operate Intelsat 702 at 54.85° E.L. consistent with the conditions
previously imposed on Intelsat‘s operation of Intelsat 709 at this same orbital
location.®

Intelsat has assessed ‘and limited the probability of the space station becoming
a source of debris as a result of collision with large debris or other operational
space stations. Except for Intelsat 709, Intelsat 702 will not be located at the
same orbital location as another satellite or at an orbital location that has an
overlapping station—keeping volume with another satellite. Further, Intelsat is
not aware of any other FCClicensed system, or any other system applied for
and under consideration by the FCC, having an overlapping station—keeping
volume with Intelsat 702 at 54.85° E.L. Finally, Intelsat is not aware of any
system with an overlapping station—keeping volume with Intelsat 702 at 54.85°
E.L. 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 expeditiously grant this request.                     .

Sincerely,




Susan H. Crandall
Assistant General Counsel
Intelsat Corporation




co: Karl Kensinger
    Kathyrn Medley
    Stephen Duall

 See Policy Branch Information; Actions Taken, Report No. SAT—00730, File
No. SAT—STA—20101006—00209 (Oct. 22, 2010) (Public Notice).



Document Created: 2019-04-12 16:03:53
Document Modified: 2019-04-12 16:03:53

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