Attachment STA Request

This document pretains to SAT-STA-20110923-00185 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011092300185_918302

September 23, 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 for
       Galaxy 26
       Call Sign: S2469

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests an additional 60-day
extension – from October 8, 2011 through December 6, 2011 – of the Special
Temporary Authority ("STA")1 previously granted to Intelsat to drift Galaxy
26 from 50.75º E.L. to 50.0° E.L. and operate it at 50.0° E.L. in the C- and Ku-
bands pursuant to the ITU filings of the Turkish Administration.2 Intelsat also
has a pending application to modify the Galaxy 26 license for permanent
operation at that location.3

Grant of this STA further extension request is in the public interest because it
will allow Intelsat to continue to provide U.S. Government customers with
capacity in the Indian Ocean region without risk of harmful interference. As
the Commission is aware, there is a shortage of available Ku-band capacity in
the Middle East region.4 Extending Intelsat’s STA to operate Galaxy 26 at
50.0° E.L. helps fulfill critical spectrum needs in this region, thus serving the
public interest.



1
  Intelsat has filed this STA request, an FCC Form 159 and an $860.00 filing
fee electronically via the International Bureau's Filing System.
2
  See Policy Branch Information; Actions Taken, Report No. SAT-00800, File
No. SAT-STA-20110727-00137 (Aug. 12, 2011) (Public Notice); Policy
Branch Information; Actions Taken, Report No. SAT-00787, File No. SAT-
STA-201110314-00053 (June 17, 2011) (Public Notice). Although Turkey’s
ITU filings initially did not contain the frequency band 11700-12200 MHz,
Turkey has since filed for the band.
3
  See Policy Branch Information, Satellite Space Applications Accepted for
Filing, Report No. SAT-00775, File Nos. SAT-MOD-20110420-00073 (May
6, 2011) (Public Notice).
4
  See GAO, Competition, Capacity, and Costs in the Fixed Satellite Services
Industry, Report to Congressional Requesters at 12 (Sept. 2011), available at
http://www.gao.gov/new.items/d11777.pdf (“GAO Report”) (finding that there
is less available satellite capacity in the Middle East and Africa than other
regions, such as North and South America, Asia, and Western Europe).


Ms. Marlene H. Dortch
September 23, 2011
Page 2



Grant of this STA further extension request will not result in increased risk of
harmful interference. As explained in its initial STA request, the reason
Galaxy 26 was moved from 50.75° E.L. to 50.0° E.L. was to mitigate
interference with respect to the recently—launched Yahsat—1 A satellite at 52.5°
EL. As noted above, at 50.0° E.L., Intelsat will continue to operate Galaxy
26 pursuant to the coordination agreements of the Turkish Administration for
that location." Intelsat plans to seek a meeting with Al Yah
Satellite Communications Company PrJSC ("Yahsat"), to be held in the United
Arab Emirates as soon as possible, in order to continue discussing the
coordination situation. In the meantime, operation of Galaxy 26 at 50.0° E.L.
will continue to be conducted on a non—interference, non—protected basis with
respect to Yahsat and any other operator of nearby co—frequency satellites. In
addition, Intelsat agrees to accept the same conditions that were imposed in its
existing STA to operate Galaxy 26 at 50.0° E.L." These conditions ensure that
Yahsat‘s current and future operations on Yahsat—1A will not be negatively
impacted by Galaxy 26‘s continued operation — as they have not been to date.

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

Sincerely,


(CAMC1OG
Susan H. Crandall
Assistant General Counsel
Intelsat Corporation


ce:     Bob Nelson
        Kathyrn Medley
        Stephen Duall
        Jay Whaley
        John.Janka, Counsel to YahSat
        Daniel Mah, SES



5 Yahsat—1A was launched with Intelsat‘s New Dawn satellite on April 22,
2011. Yahsat—1A is a C—, Ku—, Ka—band satellite.
6 See Letter from Susan H. Crandall, Intelsat, to Marlene H. Dortch, Federal
Communications Commission, File Nos. SAT—MOD—20110420—00073 and
SAT—STA—20110314—00053 (June 8, 2011).
" See supra n.2.



Document Created: 2011-09-23 15:24:50
Document Modified: 2011-09-23 15:24:50

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