Attachment STA Request

This document pretains to SAT-STA-20130424-00061 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2013042400061_994295

April 24, 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
       and Operate Intelsat 9 (Call Sign S2380)

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests an additional 180-day
extension, commencing April 30, 2013, of the Special Temporary Authority
("STA")1 previously granted Intelsat to drift Intelsat 9 (call sign S2380) from
58.0° W.L. to 43.10° W.L. and operate at 43.10° W.L. in inclined orbit mode.2

Intelsat 9 currently is on station at 43.10º W.L., operating co-located with
Intelsat 11.3 At that location, Intelsat 9 will continue operating in the following
TT&C frequencies:

Uplink:

14494.5 MHz (V)

14000.5 MHz (RHCP)

Downlink:

11700.5 MHz (V)
11702.5 MHz (V)
11700.5 MHz (RHCP)



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
  Intelsat began operating Intelsat 9 in inclined orbit in late 2012. See Letter
from Susan H. Crandall, Intelsat, to Marlene H. Dortch, FCC (Nov. 7, 2012)
(notifying the FCC of the commencement of inclined orbit operations). The
satellite’s expected end of life is 2016.
3
  Intelsat has a pending application to modify the Intelsat 9 license to allow the
satellite’s permanent redeployment to 43.10° W.L. See Policy Branch
Information; Satellite Space Applications Accepted for Filing, Report No.
SAT-00883, File No. SAT-MOD-20120703-00110 (July 20, 2012).


Ms. Marlene H. Dortch
April 24, 2013
Page 2


11702.5 MHz (RHCP)
11700.5 MHz (H)
11702.5 MHz (H)

Intelsat will continue to utilize the following communications payload
frequencies:

Uplink:

5925 – 6425 MHz
14000 – 14500 MHz

Downlink:

3700 – 4200 MHz
11450 – 11700 MHz
11700 – 12200 MHz

Grant of this STA extension request is in the public interest because it will
allow Intelsat to continue service at the 43.10° W.L. location.

Grant of this STA extension request will not result in increased risk of harmful
interference. Intelsat will continue to operate the TT&C and communications
frequencies in accordance with its coordination agreements governing the
nominal 43.0° W.L. location.

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 9 is not located at the same orbital location as another
satellite or at an orbital location that has an overlapping station-keeping
volume with another satellite.4 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 9 at
43.10° W.L. Finally, Intelsat is not aware of any system with an overlapping
station-keeping volume with Intelsat 9 at 43.10° W.L. that is the subject of an
ITU filing and that is either in orbit or progressing towards launch.




4
 Intelsat 9 and Intelsat 11 are being operated in adjacent station-keeping
boxes.


Ms. Marlene H. Dortch
April 24, 2013
Page 3


Intelsat also requests that the waiver previously granted Intelsat 9 of footnote
NG 104 of Section 2.106 and footnote 2 of Section 25.202(a)(1) with respect to
the domestic use of the 11450—11700 MHz band continue to apply at 43.10°
w.L.‘

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

Sincerely,



ALCE_
Susan H. Crandall
Assistant General Counsel
Intelsat Corporation


ce: Stephen Duall
    Jay Whaley
    Cindy Spiers




5 PanAmSat Licensee Corp. Applicationfor Authority to Use Extended Ku—
Band Frequenciesfor Domestic Service, Order and Authorization, 20 FCC Red
14642 (2005).



Document Created: 2013-04-24 16:25:09
Document Modified: 2013-04-24 16:25:09

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