Attachment STA Request

This document pretains to SAT-STA-20120823-00141 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012082300141_964429

August 23, 2012


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

Re:     Request for Extension of Special Temporary Authority for Intelsat 20,
        File No. SAT-LOA-20111024-00208, Call Sign S2847

Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”) herein requests an additional 30 days —from
August 29, 2012 through September 27, 2012 — of the Special Temporary
Authority (“STA”)1 previously granted Intelsat for its Intelsat 20 satellite (Call
Sign S2847) to (1) seek a waiver of the U.S. Table of Frequency Allocations to
permit launch and early orbit phase (“LEOP”) operations using downlink
frequencies in the 12700-12750 MHz band in Region 2;2 (2) conduct in-orbit
testing (“IOT”) at 63.15º E.L.; and (3) drift the satellite to its permanent
location of 68.5° E.L.3 Intelsat 20 was launched on August 2, 2012 and
currently is undergoing in-orbit testing.

IOT. Intelsat will continue to conduct in-orbit testing of Intelsat 20 (Call Sign
S2847) at 63.15º E.L. in the bands 3700-4200 MHz (downlink), 5925-6675
MHz (uplink), 10950-11200 MHz (downlink), 11450-11700 MHz (downlink),
12500-12750 MHz (downlink),13750-14500 MHz (uplink), 29500-30000
MHz (uplink) and 19700-20200 MHz (downlink). To Intelsat’s knowledge,
the only co-frequency satellites within plus/minus six degrees of 63.15º 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 68.65 E.L., Intelsat 10 at 68.5º E.L.,
and Inmarsat 3-F1 at 64.5°E.L. Intelsat will continue to coordinate with
Inmarsat, the operator of Inmarsat 3-F1, regarding the Intelsat 20 IOT. With

1
  Intelsat has filed this STA request, an FCC Form 159, a $860.00 filing fee
and this supporting letter electronically via the International Bureau’s Filing
System (“IBFS”).
2
  The authorization for the Intelsat 20 satellite does not seek authority to
operate the Intelsat 20 satellite in the 12700-12750 MHz band in Region 2.
See Policy Branch Information; Actions Taken, Report No. SAT-00886, File
No. SAT-LOA-20111024-00208 (July 27, 2012) (Public Notice).
3
  See Policy Branch Information; Actions Taken, Report No. SAT-00887, File
No. SAT-STA-20120622-00104 (Aug. 3, 2012) (Public Notice). Only the
TT&C frequencies will continue to be used during the satellite’s drift from
63.15° E.L. to 68.5º E.L.


Marlene H. Dortch
August 23, 2012
Page 2

regard to the remaining spacecraft, Intelsat will continue to 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.

Intelsat is aware that FSS operations are not authorized in the 12500-12750
MHz band in Region 2. In-orbit testing of Intelsat 20 will continue to be
conducted by earth stations located outside the United States and will not
affect satellite or terrestrial operations in the 12500-12750 MHz band in
Region 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 63.15º E.L. Intelsat 20 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 20. Finally, Intelsat is not aware of any system
with an overlapping station-keeping volume with Intelsat 20 that is the subject
of an ITU filing and that is either in orbit or progressing towards launch.

Drift. During the drift from 63.15º E.L. to 68.5° 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:

13750.5 (V)
14498.0 (V)
13750.5 (LHCP)
14498.5 (LHCP)

Downlink:

12746.5 (V)
12747.0 (V)
12748.0 (V)
12748.5 (V)
12746.5 (LHCP)
12747.0 (LHCP)
12748.0 (LHCP)
12748.5 (LHCP)


Marlene H. Dortch
August 23, 2012
Page 3


Grant of this STA extension request will facilitate the continued in—orbit testing
of Intelsat 20 at 63.15° E.L., which is a critical step in ensuring that the satellite
will be fully operational at 68.5° E.L. The subsequent drift of the satellite to
68.5° E.L. will ensure continuity of service to customers, and thereby promotes
the public interest.

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

Sincerely,

LC_O
Susan H. Crandall
Assistant General Counsel
Intelsat Corporation




cc:     Robert Nelson
        Kathyrn Medley
        Stephen Duall
        Jay Whaley



Document Created: 2012-08-23 16:18:34
Document Modified: 2012-08-23 16:18:34

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