Attachment STA Request

This document pretains to SAT-STA-20121008-00180 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012100800180_970507

October 8, 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 Operate Intelsat 701
        Call Sign S2400

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests a 30-day further
extension – through November 13, 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
157.0° E.L. in the C- and Ku-bands in inclined orbit mode. 2


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-
00902, File No. SAT-STA-20120910-00145 (Sept. 28, 2012)
(Public Notice); Policy Branch Information; Actions Taken, Report
No. SAT-00890, File No. SAT-STA-20120809-00126 (Aug. 17,
2012) (Public Notice); Policy Branch Information; Actions Taken,
Report No. SAT-00884, File No. SAT-STA-20120710-00112 (July
20, 2012) (Public Notice); Policy Branch Policy Branch
Information; Actions Taken, Report No. SAT-00877, File No.
SAT-STA-20120612-00096 (June 22, 2012) (Public Notice);
Policy Branch Information; Actions Taken, Report No. SAT-
00873, File No. SAT-STA-20120511-00084 (June 8, 2012) (Public
Notice); Policy Branch Information; Actions Taken, Report No.
SAT-00863, File No. SAT-STA-20120413-00067 (Apr. 27, 2012)
(Public Notice); Report No. SAT-00856; File No. SAT-STA-
20120312-00039 (Mar. 30, 2012) (Public Notice); Policy Branch
Information; Actions Taken, Report No. SAT-00846, File No.
SAT-STA-20120209-00015 (Feb. 17, 2012) (Public Notice);
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).


Ms. Marlene H. Dortch
October 8, 2012
Page 2


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


       Uplink:

       6173.7 MHz (LHCP)
       6176.3 MHz (LHCP)

       Downlink:

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


Intelsat will continue to utilize the following communications
frequencies on Intelsat 701 at 157.0° 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 meet customer demand
at this location. Intelsat seeks to continue to operate the Intelsat
701 satellite at 157.0° E.L. pursuant to STA because the satellite
will be redeployed in the near term in order to preserve service
continuity at a different location as a result of a launch delay.


Ms. Marlene H. Dortch
October 8, 2012
Page 3


Intelsat expects shortly to file an application seeking authority to
redeploy Intelsat 701. Intelsat 706 currently is drifting to 157.0º
E.L.3 and will arrive at the location before Intelsat 701 is
redeployed.

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 any
applicable coordination agreements.

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 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(i) and 25.211(a) of the
Commission’s rules.4



3
  See Policy Branch Information; Actions Taken, Report No. SAT-
00902, File No. SAT-STA-20120910-00146 (Sept. 28, 2012)
(Public Notice); Policy Branch Information; Actions Taken, Report
No. SAT-00890, File No. SAT-STA-20120810-00127 (Public
Notice) (Aug. 17, 2012) (Public Notice).
4
  See Applications of Intelsat LLC for 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 Rcd 15460 (2000), recon. denied, 15 FCC
Rcd 25234 (2000).


Ms. Marlene H. Dortch
October 8, 2012
Page 4


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

Sincerely,




Susan H. Crandall
Assistant General Counsel
Intelsat Corporation


ce:     Stephen Duall
        Jay Whaley                                                      |
        Kathyrn Medley                                                  |



Document Created: 2012-10-08 15:27:22
Document Modified: 2012-10-08 15:27:22

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