Attachment STA Request

This document pretains to SAT-STA-20140604-00056 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2014060400056_1048960

June 4, 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 Operate Intelsat 706
       Call Sign S2401

Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”) herein requests an additional 60
days—through August 6, 2014—of the Special Temporary Authority
("STA")1 originally granted Intelsat to operate Intelsat 706 (call sign
S2401) at 157.0° E.L. in the C- and Ku-bands in inclined orbit.2
Intelsat has a pending application for permanent authority to operate
Intelsat 706 at 157.0° E.L.3 Intelsat currently expects to operate

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-
01009, File No. SAT-STA-20140403-00037 (Apr. 11, 2014) (Public
Notice); Policy Branch Information; Actions Taken, Report No.
SAT-00995, File No. SAT-STA-20140203-00012 (Feb. 7, 2014)
(Public Notice); Policy Branch Information; Actions Taken, Report
No. SAT-00985, File No. SAT-STA-20131204-00144 (Dec. 13,
2013) (Public Notice); Policy Branch Information; Actions Taken,
Report No. SAT-00977, File No. SAT-STA-2013101700120 (Nov.
1, 2013) (Public Notice); Policy Branch Information; Actions Taken,
Report No. SAT-00972, File Nos. SAT-STA-20130807-00103 and
SAT-STA-20130607-00081 (Sept. 13, 2013) (Public Notice); Policy
Branch Information; Actions Taken, Report No. SAT-00947, File
No. SAT-STA-20130408-00057 (May 3, 2013) (Public Notice);
Policy Branch Information; Actions Taken, Report No. SAT-00931,
File No. SAT-STA-20130206-00017 (Feb. 15, 2013) (Public Notice).
Intelsat 706 began operating in inclined orbit mode in 2011. See
Letter from Susan H. Crandall, Intelsat, to Marlene H. Dortch, FCC,
Call Sign S2401 (filed July 20, 2011).
3
  See Policy Branch Information; Satellite Space Applications
Accepted for Filing, Report No. SAT-00915, File No. SAT-MOD-
20121026-00188 (Nov. 30, 2012) (Public Notice).


Ms. Marlene H. Dortch
June 4, 2014
Page 2


Intelsat 706 at 157.0° E.L. until the satellite is de-orbited in the
second half of 2014.

At 157.0° E.L., Intelsat 706 will continue to operate in the following
frequencies:

TT&C frequencies:

Uplink:

6173.7 (LHCP)
6176.3 (LHCP)

Downlink:

3947.5 (RHCP)
3948.0 (RHCP)
3952.5 (RHCP)
3952.0 (RHCP)

Communications frequencies:

3700 – 4200 MHz (space-to-Earth)
5925 – 6425 MHz (Earth-to-space)
10950 – 11200 MHz (space-to-Earth)
11450 – 11700 MHz (space-to-Earth)
12500 – 12750 MHz (space-to-Earth)
14000 – 14500 MHz (Earth-to-space)

Grant of this STA further extension request is in the public interest
because it will allow Intelsat to continue providing service at 157.0°
E.L. In addition, grant of this request will allow the Commission
more time to consider Intelsat’s pending application to operate
Intelsat 706 at 157.0º E.L. on a permanent basis.

Grant of this STA further extension request will not result in
increased risk of harmful interference. Intelsat will continue to
operate at 157.0° E.L. in conformance with its coordination
agreements for the 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 706 will not be located at


Ms. Marlene H. Dortch
June 4, 2014
Page 3


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 706 at
157.0° EL.

Finally, Intelsat is not aware of any system with an overlapping
station—keeping volume with Intelsat 706 at 157.0° E.L. that is the
subject of an ITU filing and that is either in orbit or progressing
towards launch.

Intelsat requests that the Part 25 waivers originally granted to the
Intelsat 706 spacecraft continue to apply at the 157.0° E.L. location,
namely, the waivers of Sections 25.202(g), 25.210(a)(1).
25.210(a)(3), 25.210(i) and 25.211(a) of the Commission‘s rules.*

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

Sincerely,


CD\AL.CA/QQ
Susan H. Crandall
Associate General Counsel
Intelsat Corporation


go:      Stephen Duall
         Jay Whaley
         Cindy Spiers




* See Applications ofIntelsat LLCfor Authority to Operate and
Further Construct, Launch, and Operate C—Band and Ku—Band
Satellites that Form a Global Communications System in
Geostationary Orbit, 15 FCC Red 15460, 15529 (Appendix C)
(2000) (Memorandum Opinion and Order and Authorization), recon.
denied, 15 FCC Red 25234 (2000) (Order on Reconsideration).



Document Created: 2014-06-04 14:12:07
Document Modified: 2014-06-04 14:12:07

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