Attachment STA Request

This document pretains to SAT-STA-20131125-00139 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2013112500139_1028857

November 25, 2013


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

Re:    Request for Extension of Special Temporary Authority to Drift
       Intelsat 702 to, and Operate at, 32.9° E.L. (327.1º W.L.);
       Call Sign: S2388

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests an additional 30-day
extension -- through December 30, 2013 – of the Special Temporary
Authority ("STA")1 previously granted Intelsat to drift Intelsat 702 (S2388)
from 33.0º E.L. to 32.9º E.L. and to operate it in the C- and Ku-bands at
32.9º E.L.2 Intelsat 702 currently is on station at 32.9º E.L.

Intelsat will continue to operate Intelsat 702 in the 5925-6425 MHz, 3700-
4200 MHz, 14000-14500 MHz, 10950-11200 MHz, 11450-11700 MHz,
and 12500-12750 MHz frequency bands and will continue to provide
TT&C using the 6173.7 MHz, 6176.3 MHz (LHCP), 3947.5 MHz, 3948.0
MHz, 3952.5 MHz and 3952.0 MHz (RHCP) frequencies. Intelsat seeks
this STA extension in order to ensure continued safe station-keeping of
Intelsat 702 with the neighboring Eutelsat 33A satellite and a satellite that
Eutelsat recently has moved to the nominal location. Intelsat has reached a
station-keeping agreement with Eutelsat with respect to the nominal 33.0º
E.L. location.

Intelsat will continue to operate Intelsat 702 at 32.9º E.L. in accordance
with Intelsat’s coordination agreements concerning the nominal 33.0º E.L.
location. In the unlikely event that 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 collisions with large debris or
other operational space stations. Intelsat 702 will not be located at 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-00977,
File No. SAT-STA-20131023-00124 (Nov. 1, 2013) (Public Notice).


Ms. Marlene H. Dortch
November 25, 2013
Page 2


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 32.9° E.L. Finally, Intelsat is not
aware of any system with an overlapping station—keeping volume with
Intelsat 702 at 32.9° E.L. that is the subject of an ITU filing and thatis
either in orbit or progressing towards launch.

The temporary operation of Intelsat 702 at 32.9° E.L. will help to ensure
the safe station—keeping of that satellite with the two Eutelsat satellites
located at the nominal 33.0° E.L. location. Accordingly, grant of this STA
request is in the public interest.

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




~Dacics_
Sincerely,




Susan H. Crandall
Associate General Counsel
Intelsat Corporation




Ce: Stephen Duall
     Jay Whaley
     Cindy Spiers



Document Created: 2013-11-25 16:07:03
Document Modified: 2013-11-25 16:07:03

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