Attachment STA Request

This document pretains to SAT-STA-20110607-00103 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011060700103_892534

June 7, 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 to Drift and Operate Intelsat 702, Call Sign S2388 Dear Ms. Dortch: Intelsat License LLC (“Intelsat”) herein requests a further 30-day extension -- from June 13, 2011 through July 12, 2011 -- of the Special Temporary Authority (“STA”)1 previously granted Intelsat to drift Intelsat 702 (call sign S2388) from 66.0° E.L. to 54.85º E.L. and begin operating at 54.85º E.L. in the C- and Ku-bands pursuant to the ITU filings of the Indian Administration.2 At 54.85° E.L., Intelsat 702 recently replaced Intelsat 709, which is being redeployed to 72.10° E.L.3 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. 1 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. 2 See Policy Branch Information; Actions Taken, Report No. SAT-00782, File No. SAT-STA-20110510-00088 (May 27, 2011) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00772, File No. SAT-STA- 20110307-00051 (Apr. 15, 2011) (Public Notice). Intelsat’s recent extension of its agreement with the Indian Administration allows Intelsat to operate a satellite at 54.85º 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). Intelsat expects the agreement to be further extended to allow Intelsat to continue operating in C- band at 54.85° E.L. beyond June 30, 2011 and will file such extension with the FCC. Intelsat will not operate Ku-band at this location beyond June 30, 2011. 3 See Policy Branch Information; Satellite Space Applications Accepted for Filing, Report No. SAT-00781, File No. SAT-MOD-20110428-00081 (May 27, 2011) (Public Notice); see also Policy Branch Information; Actions Taken, Report No. SAT-00782, File No. SAT-STA-20110512-00089 (May 27, 2011) (Public Notice).

Ms. Marlene H. Dortch June 7, 2011 Page 2 Intelsat 702 will continue to operate at 54.85° E.L. in the following frequencies. The specific TT&C frequencies are as follows: 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) The 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 11.45-11.7 GHz 12.5-12.75 GHz4 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.5 Grant of this STA request is in the public interest because it will allow Intelsat to ensure continuity of service to customers in the Indian Ocean region for a few 4 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. 5 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 June 7, 2011 Page 3 more months. Intelsat will ensure that any of its customers at 54.85° E.L. 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 54.85º E.L., Intelsat will continue to operate the communications payload in conformance with the Indian Administration’s coordination agreements related to the nominal 55.0º E.L. location. Intelsat also agrees to operate Intelsat 702 at 54.85º E.L. consistent with the conditions previously imposed on Intelsat’s operation of Intelsat 709 at this same orbital location.6 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. 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 FCC licensed 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, /s/ Susan H. Crandall Susan H. Crandall Assistant General Counsel Intelsat Corporation cc: Karl Kensinger Kathyrn Medley Stephen Duall 6 See Policy Branch Information; Actions Taken, Report No. SAT-00730, File No. SAT-STA-20101006-00209 (Oct. 22, 2010) (Public Notice).


Document Created: 2011-06-07 17:58:00
Document Modified: 2011-06-07 17:58:00
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