Attachment STA Request

This document pretains to SAT-STA-20130808-00104 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2013080800104_1006642

August 8, 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 702 Call Sign S2388 Dear Ms. Dortch: Intelsat License LLC (“Intelsat”) herein requests a 60-day further extension -- from August 16, 2013 through October 14, 2013 -- of the Special Temporary Authority (“STA”)1 previously granted Intelsat to drift Intelsat 702 (call sign S2388) from 47.5° E.L. to 33.0° E.L. and to operate it at that location in inclined orbit in the C- and Ku-bands.2 Intelsat has a pending application for modification of the Intelsat 702 license to allow for the satellite’s permanent operation at 33.0º E.L.3 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 Intelsat License LLC, Request for Further Extension of Special Temporary Authority for to Drift and Operate Intelsat 702, Call Sign S2388, File No. SAT-STA-20130607-00080, (filed June 6, 2013); Policy Branch Information; Actions Taken, Report No. SAT- 00945, File No. SAT-STA-20130410-00058 (Apr. 26, 2013) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00935, File No. SAT-STA-20130212-00021 (Mar. 8, 2013) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00921, File No. SAT-STA-20121211-00215 (Dec. 21, 2012) (Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00905, File No. SAT-STA-20121001-00164 (Oct. 19, 2012) (Public Notice). 3 See Policy Branch Information; Satellite Space Applications Accepted for Filing, Report No. SAT-00910, File No. SAT-MOD- 20121001-00163 (Nov. 9, 2012) (Public Notice).

Ms. Marlene H. Dortch August 8, 2013 Page 2 Intelsat 702 currently is operating at 33.0° E.L. It is collocated with Intelsat 28 (f/k/a Intelsat New Dawn; call sign S2751), which currently operates at 32.8° E.L.4 The Intelsat 702 TT&C frequencies are as follows: Uplink: 6173.7 MHz and 6176.3 (LHCP) Downlink: 3947.5 MHz and 3948.0 MHz (RHCP) 3952.5 MHz and 3952.0 MHz (RHCP) The Intelsat 702 communications frequencies are as follows: Uplink: 5925-6425 MHz 14000-14500 MHz Downlink: 3700-4200 MHz 10950-11200 MHz 11450-11700 MHz 12500-12750 MHz5 Grant of this STA further extension request is in the public interest because it will allow Intelsat to continue serving customers from the 33.0° E.L. orbital location while the Commission processes the application for permanent authority. Grant of this STA further extension request will not result in increased risk of harmful interference. While on-station at 33.0° 4 See Policy Branch Information; Actions Taken, Report No. SAT- 00769, File No. SAT-MOD-20101029-00228 (Apr. 1, 2011) (Public Notice). 5 Although Intelsat 702 also has the capability to transmit in the frequency band 11.7-11.95 GHz, Intelsat does not intend to utilize this frequency band from the 33.0° E.L. orbital location.

Ms. Marlene H. Dortch August 8, 2013 Page 3 E.L., Intelsat will continue to operate the communications payload in conformance with Intelsat‘s coordination agreements related to that location and the FCC‘s rules governing operations at the location vis—a—vis adjacent locations. 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 702 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 702 at 33.0° E.L. Finally, Intelsat is not aware of any system with an overlapping station—keeping volume with Intelsat 702 at 33.0° 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, ARCLPO_ Susan H. Crandall Assistant General Counsel Intelsat Corporation cc: Stephen Duall Jay Whaley Cindy Spiers


Document Created: 2013-08-08 14:33:38
Document Modified: 2013-08-08 14:33:38
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