Attachment STA Request

This document pretains to SAT-STA-20120209-00015 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012020900015_938834

February 9, 2012


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 Stop Drift and Operate Intelsat 701
       Call Sign S2400

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests a 30-day extension –
through March 18, 2012 – of the Special Temporary Authority
("STA")1 previously granted Intelsat to stop the drift of Intelsat 701
(call sign S2400) and operate the satellite at 157.0º E.L. in the C- and
Ku-bands in inclined orbit mode. 2

Intelsat 701 is currently operating at 157.0º E.L. Intelsat expects to
operate the satellite at that location until its planned end of life, which
currently is expected to be January 2033,3 assuming continued inclined
orbit operations.4

Intelsat will continue to utilize the following TT&C frequencies on
Intelsat 701 at 157.0º E.L.:

       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-
00842, File No. SAT-STA-20120113-00006 (Feb. 3, 2012) (Public
Notice); Policy Branch Information; Actions Taken, Report No. SAT-
00831, File No. SAT-STA-20111213-00238 (Dec. 23, 2011) (Public
Notice).
3
  Intelsat will file shortly a modification application seeking permanent
authority to operate Intelsat 701 at this location.
4
  See Letter from Susan H. Crandall, Intelsat, to Marlene H. Dortch,
FCC, Call Sign S2400 (Dec. 1, 2011).


Ms. Marlene H. Dortch
February 9, 2012
Page 2


       Downlink:

       3947.5 MHz (RHCP)
       3948.0 MHz (RHCP)
       3952.5 MHz (RHCP)
       3952.0 MHz (RHCP)


Intelsat will continue to utilize the following commununications
frequencies on Intelsat 701 at 157.0º E.L.:

       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 further extension request is in the public interest
because it will allow Intelsat to continue to ensure continuity of service
to a customer that cannot tolerate the degree of inclination of the
satellite it currently operates on. This customer will be transferred
from its current satellite to Intelsat 701 at 157.0º E.L. In addition, grant
is in the public interest because it will continue to allow Intelsat to meet
additional customer demand at this location.

Grant of this STA further extension request will not result in increased
risk of harmful interference. Intelsat will continue to operate Intelsat
701 at 157.0° 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


Ms. Marlene H. Dortch
February 9, 2012
Page 3



other operational space stations. 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 FCC, having
an overlapping station—keeping volume with Intelsat 701 at 157.0° E.L.
Finally, Intelsat is not aware of any system with an overlapping station—
keeping volume with Intelsat 701 at 157.0° 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 157.0° 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() and 25.211(a) of the Commission‘s rules."

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

Sincerely,                              .

 eao
Susan H. Crandall
Assistant General Counsel
Intelsat Corporation


ce:      Stephen Duall
         Jay Whaley
         Kathyrn Medley




* 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: 2012-02-09 16:39:13
Document Modified: 2012-02-09 16:39:13

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