Attachment STA Request

This document pretains to SAT-STA-20111202-00231 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011120200231_928811

December 2, 2011 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, DC 20554 Re: Request for Special Temporary Authority to Operate Intelsat 701 Call Sign S2400 Dear Ms. Dortch: Intelsat License LLC ("Intelsat") herein requests Special Temporary Authority ("STA")1 for 180 days, commencing April 1, 2012, to operate Intelsat 701 (call sign S2400) at 72.1º E.L. in the C- and Ku-bands. Intelsat 701 currently is drifting from 180.0° E.L. to 72.1º E.L.2 Intelsat 701 is being relocated to 72.1º E.L. to provide capacity to customers, including a U.S. Government customer, currently on Intelsat 709 in the event of a launch delay of Intelsat 22. Intelsat 701 is expected to be on-station at 72.1° E.L. in early April 2012 and is expected to operate there until Intelsat 22 commences service, after which it will be redeployed.3 The specific TT&C frequencies that will be utilized on Intelsat 701 are as follows: Uplink: 6173.7 MHz (LHCP) 6176.3 MHz (LHCP) 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-00826, File No. SAT-STA-20111114-00218 (Dec. 2, 2011) (Public Notice). 3 Intelsat 22 currently is expected to launch in the first quarter of 2012. See Intelsat License LLC Application for Authority to Launch and Operate Intelsat 22, a Replacement Satellite With New Frequencies, at 72.1° E.L., File No. SAT-LOA-20110929-00193 (filed Sept. 29, 2011).

Ms. Marlene H. Dortch December 2, 2011 Page 2 Downlink: 3947.5 MHz (RHCP) 3948.0 MHz (RHCP) 3952.5 MHz (RHCP) 3952.0 MHz (RHCP) The communications frequencies that will be utilized on Intelsat 701 are as follows: Uplink: 5925 – 6425 MHz 14000 – 14500 MHz Downlink: 3700 – 4200 MHz 10950 – 11200 MHz 11450 – 11700 MHz 11700 – 11950 MHz 12500 – 12750 GHz Grant of this STA request is in the public interest because it will allow Intelsat to ensure continuity of service to customers, including a U.S. Government customer, currently on Intelsat 709 that will not be able to tolerate the degree of inclination of that satellite should the Intelsat 22 launch be delayed. Should there be a launch delay, these customers will be transferred from Intelsat 709 to Intelsat 701 until Intelsat 22 is available. Grant of this STA request will not result in increased risk of harmful interference. Intelsat will operate Intelsat 701 at 72.10° E.L. in accordance with Intelsat’s coordination agreements related to the 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 701 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

Ms. Matlene H. Dortch December 2, 2011 Page 3 FCC, having an overlapping station—keeping volume with Intelsat 701 at 72.1° EL. Finally, except for Intelsat 709, Intelsat is not aware of any system with an overlapping station—keeping volume with Intelsat 701 at 72.1° E.L. that is the subject of an ITU filing and that is either in orbit or progressing towards launch. Intelsat requests that the Part 25 waivers originally granted to the Intelsat 701 spacecraft continue to apply at the 72.1° E.L. location, namely, the waivers of Sections 25.140(b)(2), 25.202(g), 25.210(a)(1), 25.210(a)(3), 25.210(i) and 25.211(a) of the Commission‘s rules.* For the reasons set forth herein, Intelsat respectfully requests that the Commission grant this request. Sincerely, (”}m_ Cz2S2_ Susan H. Crandall Assistant General Counsel Intelsat Corporation ce: Stephen Duall Jay Whaley * See Applications ofIntelsat LLCfor Authority to Operate, and to Further Construct, Launch and Operate C—band and Ku—band Satellites that Form a Global Communications System in Geostationary Orbit, Memorandum Opinion Order and Authorization, 15 FCC Red 15460 (2000), recon. denied, 15 FCC Red 25234 (2000).


Document Created: 2011-12-02 15:12:02
Document Modified: 2011-12-02 15:12:02
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