Attachment STA Request

This document pretains to SAT-STA-20121119-00199 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012111900199_975785

November 19, 2012


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

Re:    Request for Extension of Special Temporary Authority to
       Drift and Operate Intelsat 10
       Call Sign S2382


Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”) herein requests an additional 30
days—from November 22, 2012 through December 21, 2012—of the
Special Temporary Authority ("STA")1 previously granted Intelsat to
drift Intelsat 10 (call sign S2382) from 68.5° E.L. to 47.5° E.L., and to
operate it at that location in the C- and Ku-bands pursuant to the ITU
filings of the German Administration.2 Intelsat has a pending 180-day
STA request to continue drifting the satellite3 and expects shortly to
file an application for modification of the Intelsat 10 license to allow
for its permanent operation at 47.5° E.L.




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-
00907, File No. SAT-STA-20120925-00155 (Oct. 26, 2012); Intelsat
incorporates herein by reference the description of Europe*Star
Gesellschaft Fur Satellitenkommunikation mbH (“Europe*Star”), the
entity that holds the authorization to operate at 47.5° E.L., set forth on
page 2 of its STA request, File No. SAT-STA-20110715-00129.
Intelsat further incorporates by reference the New Slot Usage
Agreement between Europe*Star and PanAmSat Europe, as well as
Europe*Star’s authorization from the German Administration to
operate at the 47.5° E.L. orbital location, that previously were filed
with the FCC; See Policy Branch Information; Actions Taken, Report
No. SAT-00476, File No. SAT-STA-20061102-00128 (Oct. 12, 2007)
(Public Notice) (granting STA request to drift Intelsat 601 from
63.65° E.L. to 47.5° E.L.).
3
  See Policy Branch Information; Satellite Space Applications
Accepted for Filing, Report No. SAT-00908, File No. SAT-STA-
20121022-00186 (Nov. 2, 2012) (Public Notice).


Ms. Marlene H. Dortch
November 19, 2012
Page 2

Intelsat 10 currently is drifting to 47.5° E.L. and is expected to be on-
station at that location in early January 2013. At 47.5° E.L., Intelsat
10 will be collocated with Intelsat 709.

During the drift of Intelsat 10 from 68.5° E.L. to 47.5° E.L., Intelsat
will continue to operate 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:

14000.5 MHz (RHCP)
14499.5 MHz (H)

Downlink:

12747.5 MHz (H and RHCP)
12748.5 MHz (H and RHCP)

Once on-station at 47.5° E.L., Intelsat will operate the following
Intelsat 10 communications frequencies:

3700-4200 MHz
5925-6425 MHz

14.0-14.5 GHz
11.45-11.7 GHz
12.25-12.75 GHz

Grant of this STA extension request is in the public interest because it
will allow Intelsat to meet customer demand at 47.5° E.L.

Grant of this STA extension request will not result in increased risk of
harmful interference. As noted above, Intelsat will continue to
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 47.5° E.L., Intelsat will operate the communications payload


Ms. Marlene H. Dortch
November 19, 2012
Page 3


in conformance with Germany‘s coordination agreements related to
that location or on a non—interference, non—protected basis.

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. Except briefly for Intelsat 709,
Intelsat 10 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 10 at 47.5° E.L. Finally, Intelsat is not
aware of any system with an overlapping station—keeping volume with
Intelsat 10 at 47.5° 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,



@\A‘L CJQ%
Susan H. Crandall
Assistant General Counsel
Intelsat Corporation


co: Stephen Duall
    Jay Whaley
    Cindy Spiers




* Intelsat 709 and Intelsat 10 for some period of time will be operated
in the same station—keeping box. Intelsat will take all necessary
measures to ensure safe station—keeping of Intelsat 709 and Intelsat
10.



Document Created: 2012-11-19 16:25:52
Document Modified: 2012-11-19 16:25:52

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