Attachment STA Request

This document pretains to SAT-STA-20130412-00059 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2013041200059_993131

April 12, 2013


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 Drift
       Intelsat 5
       Call Sign S2704


Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests an additional 30 days—from
April 21, 2013 through May 20, 2013—of the Special Temporary Authority
("STA")1 previously granted Intelsat to drift Intelsat 5 (call sign S2704) from
169.0° E.L. to 65.45° E.L., where it will eventually operate in the C- and Ku-
bands under new U.S. ITU filings.2 Intelsat has a pending 180-day STA request
for this redeployment, which includes a request to extend the Intelsat 5 license
term for the duration of this STA further extension request.3 Intelsat also has
filed an application for modification of the Intelsat 5 license to allow for its




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-00941, File
No. SAT-STA-20130318-00033 (Apr. 5, 2013) (Public Notice); Policy Branch
Information; Actions Taken, Report No. SAT-00934, File No. SAT-STA-
20130214-00022 (Mar. 1, 2013) (Public Notice); Policy Branch Information;
Actions Taken, Report No. SAT-00928, File No. SAT-STA-20130116-00008
(Feb. 1, 2013) (Public Notice); Policy Branch Information; Actions Taken,
Report No. SAT-00928, File No. SAT-STA-20121218-00218 (Feb. 1, 2013)
(Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-
00914, File No. SAT-STA-20121120-00201 (Nov. 30, 2012) (Public Notice);
Policy Branch Information; Actions Taken, Report No. SAT-00907, File No.
SAT-STA-20120911-00147 (Oct. 26, 2012) (Public Notice); Intelsat is not
herein seeking authority to operate the satellite’s communications payload.
3
  See Policy Branch Information; Satellite Space Applications Accepted for
Filing, Report No. SAT-00906, File No. SAT-STA-20121017-00182 (Oct. 26,
2012) (Public Notice).


Ms. Marlene H. Dortch
April 12, 2013
Page 2

permanent operation at 65.45° E.L.4 In addition, Intelsat has filed a
modification application that includes a request to extend the Intelsat 5 license
for a longer term.5

Intelsat 5 is currently drifting from 169.0° E.L. to 65.45° E.L. The satellite is
expected to be on-station in late May 2013.

During the drift of Intelsat 5 from 169.0° E.L. to 65.45° E.L., Intelsat will
continue to 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:

14498 MHz (H)
13999 MHz (RHCP)

Downlink:

11451 MHz (H, V and RHCP)
11452 MHz (H, V and RHCP)
11454 MHz (RHCP and LHCP)

Grant of this STA further extension request is in the public interest because it
will allow Intelsat to meet anticipated customer demand at 65.45° E.L.
Continued operation of the Intelsat 5 satellite beyond its license term of March
21, 2013 also serves the public interest by enabling customers to receive
additional services with this in-orbit spacecraft prior to its de-orbit. The FCC
has already approved a post-mission disposal plan for the Intelsat 5 satellite that
reserves 21.2 kg of fuel for an intended de-orbit of 150 km.6

4
  See Policy Branch Information; Satellite Space Applications Accepted for
Filing, Report No. SAT-00937, File No. SAT-MOD-20121109-00196 (Mar. 15,
2013) (Public Notice).
5
  See Policy Branch Information; Satellite Space Applications Accepted for
Filing, Report No. SAT-00937, File No. SAT-MOD-20121002-00176 (Mar. 15,
2013) (Public Notice).
6
  See Policy Branch Information; Actions Taken, Report No. SAT-00561, File
No. SAT-MOD-20080725-00150 (Oct. 24, 2008). Intelsat notes that the
Satellite Industry Association’s pending request for blanket waiver of Section
25.283(c) incorrectly included the Intelsat 5 satellite. Pleading Cycle
Established for Comment on Satellite Industry Association’s Blanket Waiver
Request Concerning Relieving Satellite Pressure Vessels, IB Docket No. 02-54,
DA 10-2291 (Dec. 14, 2010) (Public Notice).


Ms. Marlene H. Dortch
April 12, 2013
Page 3


Grant of this STA further extension 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 ofsatellites 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 65.45° E.L. and subject to FCC approval,
Intelsat plans to operate the communications payload in conformance with its
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. Intelsat 5 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 5 at 65.45°
E.L. Finally, Intelsat is not aware of any system with an overlapping station—
keeping volume with Intelsat 5 at 65.45° 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 further extension request.

Sincerely,


AMCA2Z®
Susan H. Crandall
Assistant General Counsel
Intelsat Corporation


ce: Stephen Duall
    Jay Whaley
    Cindy Spiers



Document Created: 2013-04-11 14:54:52
Document Modified: 2013-04-11 14:54:52

© 2025 FCC.report
This site is not affiliated with or endorsed by the FCC