Attachment STA Request

This document pretains to SAT-STA-20131017-00121 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2013101700121_1014959

October 17, 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 October 15, 2013 through December 12, 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 Policy Branch Information; Actions Taken, Report No. SAT-
00972, File Nos. SAT-STA-20130808-00104 and SAT-STA-
20130607-00080 (Sept. 13, 2013) (Public Notice); 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
October 17, 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.


4
  See Policy Branch Information; Actions Taken, Report No. SAT-
00972, File No. SAT-STA-20130808-00104 (Sept. 13, 2013)
(Public Notice); 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
October 17, 2013
Page 3

Grant of this STA further extension request will not result in
increased risk of harmful interference. While on—station at 33.0°
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. With the exception of Intelsat
28, 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,



CACiLIQ
 .A

Susan H. Crandall
Assistant General Counsel
Intelsat Corporation


ce: Stephen Duall
    Jay Whaley
    Cindy Spiers



Document Created: 2013-10-17 12:43:42
Document Modified: 2013-10-17 12:43:42

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