Attachment STA Request

This document pretains to SAT-STA-20120815-00132 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012081500132_963390

August 15, 2012 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, DC 20554 Re: Request for Special Temporary Authority to Drift and Operate Intelsat 8 (Call Sign S2460) Dear Ms. Dortch: Intelsat License LLC ("Intelsat") herein requests Special Temporary Authority ("STA")1 for 30 days, commencing September 8, 2012, to drift Intelsat 8 (call sign S2460) from 166.0° E.L. to 169.0° E.L. and operate at 169.0° E.L.2 At the 169.0° E.L., Intelsat 8 will operate co-located with Intelsat 5.3 Intelsat 8 currently is authorized to operate at 166.0º E.L.4 Following traffic transfer to other Intelsat satellites, Intelsat 8 will be relocated to 169.0º E.L. Subject to receipt of FCC approval, Intelsat expects to begin drifting Intelsat 8 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 Intelsat has a pending application to modify the Intelsat 8 license to allow the satellite’s permanent redeployment to 169.1° E.L. See Policy Branch Information; Satellite Applications Accepted for Filing, File No. SAT-MOD- 20120619-00100 (July 20, 2012) (Public Notice). Intelsat concurrently is filing to amend that application to seek operational authority at 169.0º E.L. rather than 169.1° E.L. 3 The end of life of Intelsat 8, assuming the drift and station-kept operations, is expected to be May 2019. The January 2014 end of life projection for Intelsat 8 listed in Intelsat’s 10-K filing is the estimated end of service life. See Annual Report Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934, For the fiscal year ended December 31, 2011, Intelsat S.A. (Mar. 1, 2012) available at http://www.intelsat.com/_files/investors/financial/2011/Q4-2011- Intelsat-Form10K.pdf. The service life is a more conservative estimate that may be adjusted subsequently to reflect potential fuel life based on the health of the satellite. 4 See PanAmSat Licensee Corp. Application for Authority to Construct, Launch and Operate a Hybrid International Communications Satellite, 14 FCC Rcd 2719 (1998); Policy Branch Information; Actions Taken, Report No. SAT- 00358, DA 06-980, File No. SAT-MOD-20060228-00017 (May 5, 2006) (Public Notice).

Ms. Marlene H. Dortch August 15, 2012 Page 2 on or about September 8, 2012 and have the satellite on-station at 169.0° E.L. approximately 10 days later.5 During the drift of Intelsat 8 from 166.0° E.L. to 169.0° E.L., Intelsat will utilize only the satellite’s TT&C frequencies and will follow industry practices for coordinating TT&C transmissions during the relocation process. The specific TT&C frequencies are as follows: Uplink: 13998.0 MHz (RHCP) Downlink: 12747.0 MHz (H) 12748.0 MHz (V) 12747.0 MHz (LHCP) 12748.0 MHz (RHCP) The Intelsat 8 communications frequencies are as follows: Uplink: 5925 – 6425 MHz 14000 – 14500 MHz Downlink: 3700 – 4200 MHz 12250-12750 MHz Grant of this STA request is in the public interest because it will allow Intelsat to expand customer services at the 169.0° E.L. location.6 Grant of this STA request will not result in increased risk of harmful interference. As noted above, Intelsat will operate only the above listed TT&C 5 Intelsat is seeking a 30-day STA in order to accommodate a potential delay in the start of drift. 6 As noted above, all customers with current contracts operating on Intelsat 8 at 166.0° E.L. at the time of the planned redeployment to 169.0° E.L. will be accommodated on other Intelsat satellites prior to the Intelsat 8 drift.

Ms. Marlene H. Dortch August 15, 2012 Page 3 frequencies during the drift, and will coordinate its TT&C transmissions with operators of satellites in the drift path. Should any interference occur during the drift, Intelsat will take all reasonable steps to eliminate such interference. Once on-station, Intelsat will operate the TT&C and communications frequencies in accordance with its coordination agreements governing the nominal 169.0° E.L. 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. With the exception of Intelsat 5, Intelsat 8 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.7 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 8 at 169.0° E.L. Finally, Intelsat is not aware of any system with an overlapping station-keeping volume with Intelsat 8 at 169.0° E.L. that is the subject of an ITU filing and that is either in orbit or progressing towards launch. Intelsat also requests that the waiver previously granted Intelsat 8 of Section 2.106 with respect to use of the 12250-12750 MHz frequency band on a non- interference, non-protected basis in ITU Region 2 continue to apply at 169.0° E.L.8 7 Intelsat 8 and Intelsat 5 will be operated in the same station-keeping box until Intelsat 5 is relocated. 8 See PanAmSat Licensee Corp. Application for Modification of Authority to Operate the PAS-5 Satellite at the 166° E.L. Orbital Location, Order and Authorization, DA 06-6, File Nos. SAT-MOD-19980928-00078, SAT-AMD- 19990222-00024, SAT-AMD-20020326-00055, SAT-STA-20020705-00097, and SAT-AMD-20051116-00220, 21 FCC Rcd 36, ¶ 1 (Jan. 4, 2006). The Intelsat 8 satellite previously was known as PAS-5.

Ms. Marlene H. Dortch August 15, 2012 Page 4 For the reasons set forth herein, Intelsat respectfully requests that the Commission expeditiously grant this request. Sincerely, G mCca2a, Susan H. Crandall Assistant General Counsel Intelsat Corporation ce: Stephen Duall Jay Whaley


Document Created: 2012-08-15 16:44:57
Document Modified: 2012-08-15 16:44:57
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