Attachment STA Request

This document pretains to SAT-STA-20140424-00041 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2014042400041_1044330

April 24, 2014


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

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

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests an additional 60-day
extension – through June 28, 2014 – of the Special Temporary Authority
("STA")1 previously granted Intelsat to drift Intelsat 702 (S2388) from 33.0°
E.L. to 32.9° E.L. and to operate it in the C- and Ku-bands at 32.9° E.L.2
Intelsat 702 currently is on station at 32.9° 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
further extension in order to ensure continued safe station-keeping of Intelsat
702 with the neighboring Eutelsat 33A satellite and a satellite that Eutelsat

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-01002,
File No. SAT-STA-20140225-00027 (Mar. 14, 2014) (Public Notice); Policy
Branch Information; Actions Taken, Report No. SAT-00993, File No. SAT-
STA-20140123-0007 (Jan. 31, 2014) (Public Notice); Policy Branch
Information; Actions Taken, Report No. SAT-00991, File No. SAT-STA-
20131219-00147 (Jan. 10, 2014) (Public Notice); Policy Branch
Information; Actions Taken, Report No. SAT-00977, File No. SAT-STA-
20131125-00139 (Dec. 6, 2013) (Public Notice); Policy Branch Information;
Actions Taken, Report No. SAT-00977, File No. SAT-STA-20131023-
00124 (Nov. 1, 2013) (Public Notice). Intelsat has a pending application to
modify the license for Intelsat 702 to allow for its permanent operation at
32.9º E.L. See Intelsat License LLC Amendment to Pending Application for
Modification of Authority for Intelsat 702, File No. SAT-AMD-20140204-
00019 (filed Feb. 4, 2014); 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
April 24, 2014
Page 2


recently has moved to the nominal location. Intelsat has reached a station—
keeping agreement with Eutelsat with respect to the nominal 33.0° E.L.
location.

Intelsat will continue to operate Intelsat 702 at 32.9° E.L. in accordance with
Intelsat‘s coordination agreements concerning the nominal 33.0° 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 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. thatis the subject of an ITU filing and that is 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 further
extension request is in the public interest.

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

Sincerely,




Susan H. Crand%—%’
Associate General Counsel
Intelsat Corporation

Ce: Stephen Duall
    Jay Whaley
    Cindy Spiers



Document Created: 2014-04-24 16:25:41
Document Modified: 2014-04-24 16:25:41

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