Attachment STA Request

This document pretains to SAT-STA-20140219-00025 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2014021900025_1036788

February 19, 2014


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 60-day
extension, commencing February 24, 2014, 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 and operating at 43.10º W.L., 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)

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-00991, File
Nos. SAT-STA-20131219-00146 and SAT-STA-20131023-00125 (Jan. 10,
2014) (Public Notice); Intelsat License LLC, Request for Extension of Special
Temporary Authority to Drift and Operate Intelsat 9 Call Sign S2380, File No.
SAT-STA-20130424-00061 (filed Apr. 24, 2013); Policy Branch Information;
Actions Taken, Report No. SAT-00909, File No. SAT-STA-20120621-00103
(Nov. 2, 2012) (Public Notice). 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) (Public
Notice).


Ms. Marlene H. Dortch
February 19, 2014
Page 2


Downlink:

11700.5 MHz (V)

11702.5 MHz (V)
11700.5 MHz (RHCP)

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 further 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 further 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-


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


Ms. Marlene H. Dortch
February 19, 2014
Page 3


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.

Intelsat also requests that the waiver previously granted Intelsat 9, contained in
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,



(ALCLA_
Susan H. Crandall
Associate General Counsel
Intelsat Corporation


ce: Stephen Duall
    Jay Whaley
    Cindy Spiers




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



Document Created: 2014-02-19 17:32:29
Document Modified: 2014-02-19 17:32:29

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