Attachment STA Request

This document pretains to SAT-STA-20120126-00013 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012012600013_936810

January 26, 2012


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

Re:    Request for Special Temporary Authority to Conduct In-Orbit Testing
       of Intelsat 22 (File No. SAT-LOA-20110929-00193)
       Call Sign S2846

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests a grant of Special Temporary
Authority ("STA")1 for 30 days, from April 1, 2012 through April 30, 2012, to
conduct in-orbit testing (“IOT”) of Intelsat 22 (File No. SAT-LOA-20110929-
00193) at 63.1º E.L. in the bands 3625-4200 MHz (downlink), 5850-6425
MHz (uplink), 11450-11700 MHz (downlink), 14000-14500 MHz (uplink),
and 12250-12750 MHz (downlink), and to drift the satellite to its permanent
location of 72.1° E.L.2 Intelsat 22 currently is scheduled to be launched on
March 14, 2012. In support of its request, Intelsat submits the following
information.

During in-orbit testing of Intelsat 22, Intelsat will operate in the above
referenced C- and Ku-bands. 3 To Intelsat’s knowledge, the only co-frequency
satellites within plus/minus six degrees of 63.1º E.L. are Intelsat 904 at 60.0º
E.L., Intelsat 902 at 62.0º E.L., Intelsat 906 at 64.15º E.L., Intelsat 17 at 66.0º
E.L., Intelsat 7 at 68.65º E.L., Intelsat 10 at 68.5º E.L., and Inmarsat 3F-1 at
64.5º E.L. Intelsat currently is in coordination discussions with Inmarsat
regarding the Intelsat 22 IOT. With regard to the remaining spacecraft,
Intelsat will internally coordinate the proposed testing with the operations of
these satellites. In the unlikely event that harmful interference occurs, Intelsat
will take all necessary steps to eliminate the interference.


1
  Intelsat has filed this STA 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-00835, File
No. SAT-LOA-20110929-00193 (Jan. 13, 2012) (Public Notice). During the
drift from 63.1º E.L. to 72.1º E.L., only the satellite’s TT&C frequencies will
be utilized.
3
  The UHF frequencies on Intelsat 22 will be in-orbit tested at the 72.1º E.L.
location pursuant to authority from the Australian administration.
Coordination of the in-orbit testing of the UHF payload has been coordinated
with the U.S. Department of Defense.


Ms. Marlene H. Dortch
January 26, 2012
Page 2


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 during in—orbit testing at 63.1° E.L. Intelsat 22 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 22. Finally, Intelsat is not
aware of any system with an overlapping station—keeping volume with Intelsat
22 that is the subject of an ITU filing and that is either in orbit or progressing
towards launch.

The in—orbit testing of Intelsat 22 at 63.1° E.L. is a critical step in ensuring that
the satellite will be fully operational at 72.1° E.L. This, in turn, will ensure
continuity of service to customers at the nominal 72.0° E.L. location, and
thereby promotes the public interest.

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

Sincerely,


 C’)\.flu _0 1209
Susan H. Crandall
Assistant General Counsel

Intelsat Corporation




Ce: Robert Nelson
     Karl Kensinger
     Kathyrn Medley
     Stephen Duall
     Jay Whaley



Document Created: 2012-01-26 16:05:22
Document Modified: 2012-01-26 16:05:22

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