Attachment STA Request

This document pretains to SAT-STA-20121001-00164 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012100100164_968227

October 1, 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 702
       Call Sign S2388


Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests Special Temporary
Authority ("STA")1 for 60 days -- from October 20, 2012 through
December 18, 2012 -- to drift Intelsat 702 (call sign S2388) from
47.5° E.L. to 33.0º E.L. and to operate it at that location in inclined
orbit in the C- and Ku-bands. Intelsat concurrently is filing an
application for modification of the Intelsat 702 license to allow for the
satellite’s permanent operation at 33.0º E.L.

Intelsat 702 currently is operating at 47.5º E.L.2 Intelsat 709 is
expected to arrive at 47.5° E.L. in mid-October and replace Intelsat
702.3 Subject to receipt of FCC approval, Intelsat 702 will be
relocated to 33.0° E.L. – with the drift starting October 20, 2012 and
the satellite on-station in mid-December 2012. At 33.0º E.L., Intelsat
702 will be collocated with Intelsat New Dawn (call sign S2751),
which currently operates at 32.8° E.L.4

During the drift of Intelsat 702 from 47.5° E.L. to 33.0º E.L., Intelsat
will utilize only the satellite’s TT&C frequencies and will follow

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-
00866, File Nos. SAT-STA-20120329-00063 and SAT-STA-
20120416-00068 (May 11, 2012) (Public Notice).
3
  Intelsat 709 currently is drifting to 47.5° E.L. pursuant to STA. See
Policy Branch Information; Actions Taken, Report No. SAT-00875,
File No. SAT-STA-20120426-00076 (June 15, 2012) (Public Notice);
Policy Branch Information; Actions Taken, Report No. SAT-00869,
File No. SAT-STA-20120409-00066 (May 18, 2012) (Public Notice).
4
  See Policy Branch Information; Actions Taken, Report No. SAT-
00769, File No. SAT-MOD-20101029-00228 (Apr. 1, 2011) (Public
Notice).


Ms. Marlene H. Dortch
October 1, 2012
Page 2


industry practices for coordinating TT&C transmissions during the
relocation process. The specific TT&C frequencies are as follows:

Uplink:

6173.7 MHz and 6176.3 (LHCP)

Downlink:

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

Once on-station at 33.0° E.L., Intelsat also will operate the following
Intelsat 702 communications frequencies:

Uplink:

5925-6425 MHz
14000-14500 MHz

Downlink:

3700-4200 MHz
10950-11200 MHz
11450-11700 MHz
12500-12750 MHz5

Grant of this STA request is in the public interest because it will allow
Intelsat to maximize the efficient use of its satellite fleet while
bringing additional capacity to Europe, Africa and Asia.

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 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 at
33.0º E.L., Intelsat will operate the communications payload in


5
 Although Intelsat 702 also has the capability to transmit in the
frequency band 11.7-11.95 GHz, Intelsat does not intend to utilize this
frequency band from the 33.0º E.L. orbital location.


Ms. Marlene H. Dortch
October 1, 2012
Page 3


conformance with Intelsat‘s coordination agreements related to that
location and the FCC‘s rules governing operations at the location vis—
a—vis adjacent locations.

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. Intelsat 702 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 702 at
33.0° E.L. Finally, Intelsat is not aware of any system with an
overlapping station—keeping volume with Intelsat 702 at 33.0° E.L.
that is the subject of an ITU filing and that is either in orbit or
progressing towards launch.

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

Sincerely,



CancC12Q,
Susan H. Crandall
Assistant General Counsel
Intelsat Corporation


co: Stephen Duall
    Jay Whaley



Document Created: 2012-10-01 16:34:55
Document Modified: 2012-10-01 16:34:55

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