Attachment STA Request

This document pretains to SAT-STA-20121130-00204 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012113000204_976741

November 30, 2012


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

Re:    Request for Special Temporary Authority to Conduct In-Orbit Testing of
       the Intelsat 27 C- and Ku-band Payloads (File No. SAT-LOA-20110610-
       00105)
       Call Sign S2827

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests a grant of Special Temporary
Authority ("STA")1 for 30 days, from February 17, 2013 through March 18,
2013, to conduct in-orbit testing (“IOT”) of the C- and Ku-band payloads of the
Intelsat 27 satellite (Call Sign S2827) at 51.5° W.L. in the bands 3700-4200
MHz (downlink), 5925-6425 MHz (uplink), 11450-11700 MHz, 11700-12200
MHz (downlink), 12500-12750 MHz, and14000-14500 MHz (uplink), and to
drift the satellite to its permanent location of 55.5° W.L.2 Intelsat 27 currently is
scheduled to be launched on January 30, 2013. In support of its request, Intelsat
submits the following information.

During in-orbit testing of Intelsat 27 at 51.5° W.L., Intelsat will operate in the
above referenced C- and Ku-bands.3 To Intelsat’s knowledge, the only co-
frequency satellites within plus/minus six degrees of 51.5° W.L. are Intelsat 707
at 53.0° W.L., Intelsat 23 at 53.0° W.L., Intelsat 805 at 55.5° W.L., Galaxy 11 at
55.5° W.L., Intelsat 1R at 50.0° W.L., NSS 703 at 47.05° W.L., TDRS 3 at
49.0° W.L., and Inmarsat 3-F4 at 54.0° W.L. Intelsat currently is in
coordination discussions with SES World Skies, the operator of NSS 703;
Inmarsat, the operator of Inmarsat 3-F4; and the United States Government, the


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-00904, File
No. SAT-LOA-20110610-00105 (Oct. 12, 2012) (Public Notice). During the
drift from 51.5° W.L. to 55.5º W.L., only the satellite’s TT&C frequencies will
be utilized. The TT&C frequencies are: 3701.25 MHz, 3701.75 MHz, 3702.25
MHz, and 3702.75 MHz (space-to-Earth), and 5925.5 MHz and 6424.5 MHz
(Earth-to-space).
3
  Intelsat will file a separate request for Special Temporary Authority to test the
Intelsat 27 UHF payload at the satellite’s permanent orbital location of 55.5°
W.L.


Ms. Marlene H. Dortch
November 30, 2012
Page 2

operator of TDRS 3, regarding the Intelsat 27 C/Ku—band IOT. With regard to
the remaining spacecraft, Intelsat will 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 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 51.5° W.L. Intelsat 27 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 27. Finally, Intelsat is not aware of any system
with an overlapping station—keeping volume with Intelsat 27 that is the subject
of an ITU filing and that is either in orbit or progressing towards launch.

The in—orbit testing of Intelsat 27‘s C— and Ku—band payloads at 51.5° W.L. is a
critical step in ensuring that the satellite will be fully operational at 55.5° W.L.
This, in turn, will ensure continuity of service to customers at the 55.5° W.L.
location, and thereby promotes the public interest.

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

Sincerely,


 (C)AACCQ,
Susan H. Crandall
Assistant General Counsel

Intelsat Corporation




co: Robert Nelson
    Kathyrn Medley
     Stephen Duall
     Jay Whaley
     Cindy Spiers



Document Created: 2012-11-30 16:15:53
Document Modified: 2012-11-30 16:15:53

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