Attachment Intelsat - corrected

Intelsat - corrected

DECISION submitted by IB,FCC

Grant corrected Nov 4 2014

2014-10-24

This document pretains to SAT-STA-20140919-00102 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2014091900102_1067766

                                                                 secorvected on           11 /O4/14—+

$2887        SAT—STA—20140919—00102      182014001869
                                                                             tile # SMT— Sih— 2014 0OJ19— ool02.
Intelsat License LLC
Intelsat 30                                                                  Call Sign S2887 Grant Date IO /24 /14
                                                                             (or other identifier)
                                                                                                      Term Dates   period of    Approved by OMB
                                                                                 m 10/25)1y_                rm
                                                                                                             éfldé
                                                                                                               30                     3060—0678

                                                         Ktoith conditions .
                                                                               Pprovel
    Date & Time Filed: Sep 19 2014 4:56:47:046PM
    File Number: SAT—STA—20140919—00102                                                              §}7{TDu«\\
    Callsign:                                                                                           Salellite Rlicg Branch

                                                FEDERAL COMMUNICATIONS COMMISSION
                                      APPLICATION FOR SPACE STATION SPECIAL TEMPORARY AUTHORITY

                                                           FOR OFFICIAL USE ONLY


      APPLICANT INFORMATION
   Enter a description of this application to identify it on the main menu:
    Request for Special Temporary Authority to Conduct IOT of the Intelsat 30 Satellite Call Sign $2887
    1. Applicant

                Name:         Intelsat License LLC             Phone Number:                           703—559—7848
                DBA Name:                                      Fax Number:                             703—559—8539
                Street:       c/o Intelsat Corporation         E—Mail:                                 susan.crandall@intelsat.com
                              7900 Tysons One Place

                City:         McLean                           State:                                  VA
                Country:       USA                             Zipcode:                                22102        —5972
                Attention:    Susan H. Crandall


                                       Intelsat License LLC
                             IBFS File No. SAT—STA—20140919—00102
                                            Call Sign: $2887

The application of Intelsat License LLC (Intelsat), IBFS File No. SAT—STA—20140919—00102, is
GRANTED. Accordingly, Intelsat is authorized for a period of 30 days, commencing October
25, 2014, to conduct in—orbit testing of the Intelsat 30 space station (Call Sign S$2887) at the
132.0° W .L. orbital location using the 10.95—11.2 GHz (space—to—Earth), 11.45—11.7 GHz (space—
to—Earth), 11.7—12.2 GHz (space—to—Earth), 13.75—14.0 GHz (Earth—to—space), and 14.0—14.5 GHz
(Earth—to—space) frequency bands. In addition, Intelsat is authorized to conduct antenna
measurements at 3511 MHz (space—to—Earth) and 6536 MHz (Earth—to—space). Intelsat is
authorized to conduct Telemetry, Tracking, and Command (TT&C) operations with the Intelsat
30 space station to maintain Intelsat 30 during in—orbit testing at the 132.0° W.L. orbital location,
and to effect the drift of Intelsat 30 to the 95.05° W.L. orbital location upon completion of in—
orbit testing, using the following center frequencies: 11.198.0 GHz, 11.1985 GHz, 11.19925
GHz, and 11.19975 GHz (space—to—Earth), and 13.7505 GHz and 14.0035 GHz (Earth—to—space).
Operations under this authorization must be in accordance with the terms, conditions, and
technical specifications set forth in Intelsat‘s application and the Federal Communications
Commission‘s rules not waived herein, and are subject to the following conditions:
         1.     All operations under this grant of special temporary authority must be on an
unprotected and non—harmful interference basis, i.e., Intelsat must not cause harmful interference
to, and shall not claim protection from interference caused to it by, any other lawfully operating
station.
        2.      In the event of any harmful interference under this grant of special temporary
authority, Intelsat must cease operations immediately upon notification of such interference, and
must inform the Commission, in writing, immediately of such an event.
       3.       Intelsat must coordinate the operations of Intelsat 30 with existing geostationary —
space stations to ensure that no unacceptable interference results from its operations at the 132.0°
W.L. orbital location or during drift to the 95.05° W.L. orbital location.
       4.      Intelsat 30‘s operations at 132.0° W.L. must be limited to IOT in the 10.95—11.2
GHz (space—to—Earth), 11.45—11.7 GHz (space—to—Earth), 11.7—12.2 GHz (space—to—Earth), 13.75—
14.0 GHz (Earth—to—space), and 14.0—14.5 GHz (Earth—to—space) frequency bands and must not
include the provision of commercial services.
         5.      Intelsat must operate only the TT&C frequencies on Intelsat 30 during the space
station‘s drift from the 132.0° W.L. orbital location to the 95.05° W.L. orbital location.
        6.     During in—orbit testing, Intelsat must maintain the Intelsat 30 space station within
an east—west longitudinal station—keeping tolerance of +0.05 degrees of the 132.0° W.L. orbital
location.
        7.     IOT operations in the 10.95—11.2 GHz (space—to—Earth), 11.45—11.7 GHz (space—
to—Earth), 11.7—12.2 GHz (space—to—Earth), 13.75—14.0 GHz (Earth—to—space), and 14.0—14.5 GHz
(Earth—to—space) frequency bands at 132.0° W.L. must comply with the conditions imposed in
IBFS File No. SAT—LOA—20121025—00187, as amended by IBFS File No. SAT—AMD—
20121221—00220 (granted August 14, 2014).‘


\ See Policy Branch Information: Action Taken, Public Notice, Report No. SAT—01040 (IBFS File No. SAT—LOA—
20110610—00105) (Aug. 14, 2014).


                                     Intelsat License LLC
                           IBFS File No. SAT—STA—20140919—00102
                                         Call Sign: $2887

        8:      Intelsat‘s request for waiver of footnote NG52 of the United States Table of
Allocations, 47 C.F.R. § 2.106, to use the 10.95—11.2 GHz and 11.45—11.7 GHz frequency bands
for the limited purpose of IOT on an unprotected, non—interference basis in the United States is
GRANTED, as conditioned. We find that waiver of footnote NG52 does not undermine the
purpose of the rules because the waiver involves only earth stations that are receive—only in the
10.95—11.2 GHz and 11.45—11.7 GHz frequency band and thus are not capable of causing
interference into fixed stations operating in this band. Furthermore, because Intelsat has agreed
to accept any level of interference from fixed stations into its receive—only earth stations‘
operations in these bands, fixed station operators will not be required to coordinate their station
operations with the space station operator‘s receive—only earth stations‘ operations. Under these
circumstances, we determine that an additional coordination burden is not placed upon fixed
station operators and their ability to expand service in the future would not be restricted in any
manner. Grant of this waiver is consistent with prior Commission precedent.
       9.      Intelsat is afforded 30 days from the date of release of this action to decline this
authorization as conditioned. Failure to respond within this period will constitute formal
acceptance of the authorization as conditioned.
        10.     This action is issued pursuant to Section 0.261 of the Commission‘s rules on
delegated authority, 47 C.F.R. § 0.261, and is effective immediately. Petitions for
reconsideration under Section 1.106 of the Commission‘s rules or applications for review under
Section 1.115 of the Commission‘s rules, 47 C.F.R. §§ 1.106, 1.115, may be filed within 30 days
of the public notice indicating that this action was taken.

                                            * corcected on 1N/O4/14®
                                                                                          02.
                                                   Tile #   SAT—SiP—2014O91$— ool

                                                   Call Sign S286—7_ Grant Date i0/24/)$
                                                   (or other identifier)
                                          af                               Term Dates penced of
                                           4e      Fm;n“!Q/ZSgIL(                To: T~OG d(s S



                              rwih romdifies         00 Step       . Duall
                                                        Chief, Satellite Fb)"\ca Branch


2. Contact


             Name:          Susan H. Crandall                    Phone Number:                        703—559—7848
             Company:       Intelsat Corporation                 Fax Number:                          703—559—8538
             Street:        7900 Tysons One Place                E—Mail:                              susan.crandall@intelsat.com



             City:          McLean                               State:                               VA
             Country:       USA                                  Zipcode:                             22102      —5972
             Attention:     Susan H. Crandall                    Relationship:                        Legal Counsel


   (If your application is related to an application filed with the Commission, enter either the file number or the IB Submission ID of the related
application. Please enter only one.)
   3. Reference File Number or Submission ID
 4a. Is a fee submitted with this application?
) IfYes, complete and attach FCC Form 159.          If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
«4 Governmental Entity        g4 Noncommercial educational licensee
qy Other(please explain):

4b. Fee Classification    —CRY — Space Station (Geostationary)
5. Type Request


3   Change Station Location                         Lt   Extend Expiration Date                      @   Other


6. Temporary Orbit Location                                                 7. Requested Extended Expiration Date


8. Description   (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.)
     Intelsat License LLC herein requests a grant of Special Temporary Authority for 30 days,
     from October 25,          2014    through November 24,             2014,    to conduct        in—orbit testing of the
     Intelsat 30 satellite             (Call Sign $2887)           at 132.0 W.L and to drift the satellite to its
     permanent location of 95.05 W.L.                     Intelsat 30 currently is scheduled to be launched on




9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject     @ Yes           4 No
to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 1988,
21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See 47 CFR
1.2002(b) for the meaning of "party to the application" for these purposes.


10. Name of Person Signing                                                  11. Title of Person Signing
Cynthia J. Grady                                                            Regulatory Counsel, Intelsat Corporation
12. Please supply any need attachments.
 Attachment 1: STA Request                         Attachment 2:                                      Attachment 3:


          WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                 (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                  (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.


8. Description

Intelsat License LLC herein requests a grant of Special Temporary Authority for 30 days,          from
October 25,      2014 through November 24,   2014,   to conduct in—orbit testing of the Intelsat 30
satellite (Call Sign $2887) at 132.0 W.L and to drift the satellite to its permanent location of
95.05 W.L.       Intelsat 30   currently is scheduled to be launched on October 16,   2014.


                                                                                      INTELSAT.
                                                                                       Envision. Connect. Transform.



September 19, 2014


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

Re:        Request for Special Temporary Authority to Conduct In—Orbit Testing of the
           Intelsat 30 Satellite (File Nos. SAT—LOA—20121025—00187; SAT—AMD—20121221—00220); Call
           Sign $2887

Dear Ms. Dortch:


Intelsat License LLC (‘Intelsat") herein requests a grant of Special Temporary Authority ("STA")‘ for
30 days, from October 25, 2014 through November 24, 2014, to conduct in—orbit testing ("IOT") of the
Intelsat 30 satellite (Call Sign $2887) at 132.0° W.L. in the bands 10950—11200 MHz, 11450—11700
MHz, and 11700—12200 MHz (downlink), 13750—14000 MHz and 14000—14500 MHz (uplink), as well
as run antenna cuts at 3511 MHz (downlink) and 6536 MHz (uplink)," and to drift the satellite to its
permanent location of 95.05° W.L.* Intelsat 30 currently is scheduled to be launched on October 16,
2014. In support of its request, Intelsat submits the following information.

During IOT of Intelsat 30 at 132.0° W.L., Intelsat will operate in the above referenced C— and Ku—bands.
To Intelsat‘s knowledge, there are no co—frequency satellites within plus/minus six degrees of 132.0°
W.L. In the unlikely event that harmful 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 collision with large debris or other operational space stations during IOT at 132.0° W.L.
Intelsat 30 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


‘ Intelsat has filed this STA request, an FCC Form 159, and a $930.00 filing fee electronically via the
International Bureau‘s Filing System.
> The remainder of the satellite‘s C—band frequencies—3400—3700 MHz (downlink) and 6425—6725 MHz
(uplink)—will be tested at the satellite‘s permanent licensed location of 95.05° W.L.
*‘ See Policy Branch Information; Actions Taken, Report No. SAT—01036, File Nos. SAT—LOA—20121025—00187
and SAT—AMD—20121221—00220 (Aug. 15, 2014) (Public Notice). During the drift from 132.0° W.L. to 95.05°
W.L., only the satellite‘s TT&C frequencies will be utilized. The TT&C frequencies are: 11198.0 MHz, 11198.5
MHz, 11199.25 MHz, and 11199.75 MHz (space—to—Earth), and 13750.5 MHz and 14003.5 MHz (Earth—to—
space).


Intelsat Corporation
7900 Tysons One Place, McLean, VA 22102—5972 USA www.intelsat.com T +1 703—559—6800


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


other FCC licensed system, or any other system applied for and under consideration by the FCC, having
an overlapping station—keeping volume with Intelsat 30 at 132.0° W.L. Finally, Intelsat is not aware of
any system with an overlapping station—keeping volume with Intelsat 30 that is the subject of an ITU
filing and that is either in orbit or progressing towards launch.

In addition, in order to conduct IOT in the 10950—11200 MHz and 11450—11700 MHz bands, this
application for STA requests a waiver of the footnote NGS52 to the U.S. Table of Frequency Allocations,
which limits the use of 10700—11700 MHz to "international systems."* Intelsat seeks waiver to permit
the Intelsat 30 satellite to operate in 10950—11200 MHz and 11450—11700 MHz at 132.0° W.L. for the
limited purpose of IOT."

The Commission may grant a waiver for good cause shown.° The Commission typically grants a waiver
where the particular facts make strict compliance inconsistent with the public interest.‘ In granting a
waiver, the Commussion may take into account considerations of hardship, equity, or more effective
implementation of overall policy on an individual basis.© Waiver is therefore appropriate if special
circumstances warrant a deviation from the general rule, and such a deviation will serve the public
interest.

Good cause exists to waive the international only requirements for the use of the 10950—11200 MHz and
11450—11700 MHz frequency bands. The purpose of the international only rule in the 10700—11700
MHz band is to limit the number of the FSS service earth stations with which the co—primary fixed
service would need to coordimate." Intelsat will provide services in the 10950—11200 MHz and 11450—
11700 MHz frequency bands only on a non—interference/non—protected basis, and therefore will not need
to coordinate with fixed service stations. Additionally, IOT will be conducted for only a short duration.

Moreover, grant of this waiver is consistent with the Commission‘s precedent. A waiver of the Table of
Allocations is generally granted "when there is little potential interference into any service authorized
under the Table of Frequency allocations and when the nonconforming operator accepts any interference
from authorized services.""" The International Bureau has found that waiving the international only


* See 47 C.F.R. § 2.106 fa. NGS52.
* Intelsat has received waiver of footnote NGS52 for operations in the 11450—11700 MHz band at the 95.05° W.L.
location. See Intelsat License LLC, Application for Authority to Launch and Operate Intelsat 30 Satellite, File
Nos. SAT—LOA—20121025—00187 and SAT—AMD—20121221—00220, 15 (stamp grant Aug. 14, 2014).
847 C.F.R. §1.3.
‘ NE. Cellular Tel. Co. v. FCC, §97 F.241164, 1166 (D.C. Cir. 1990) ("Northeast Cellular®‘).
8 WAITRadio v. FCC, 418 F.24 1153, 1159 (D.C. Cir. 1969); Northeast Cellular, 897 F.2d at 1166.
* See Satellite Services, 26 RR 24 1257, 1263—65 (1973). See also EchoStar KuX Corporation Applicationfor
Authority to Construct, Launch and Operate a Geostationary Satellite Using the Extended Ku—band Frequencies
in the Fixed—Satellite Service at the 83°W.L. Orbital Location, Order and Authorization, DA 04—3162, 9 (Int‘l
Bur., Sept. 30, 2004) ("EchoStar 83° Waiver").
9 See The Boeing Company, Order and Authorization, 16 FCC Red 22645, 22651 (Int‘l Bur. & OET 2001);
Application ofFugro—Chance, Inc. for BlanketAuthority to Construct and Operate a Private Network ofReceive—
Only Mobile Earth Stations, Order and Authorization, 10 FCC Red 2860 (Int‘l Bur. 1995) (authorizing MSS in


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


restriction would not undermine the purpose of the rules if the party seeking a waiver will be utilizing
earthstations thatare receive—oan/in these bands and thus "not capable of causing interference into FS
stations" operating in the bands." The earthstations operating in the10950—1 1200 MHz and 11450—
11700 MHzbands on Intelsat 30 will not transmitin these bands and Intelsat agrees to accept any level
of interference into those earth stations from fixed service stations in these barids. Accordingly, the
earth stations operating in these bands poseno interference concerns with respect to co—frequency fixed
servicestations.

The IOT of Intelsat 30°s Ku—band payioad and the running of antenna cuts in certain C—band frequencies
at 132.0° W.L. is a critical step in ensuring that the satellite will be fully operational at 95.05° W.L.
This, in turn, will ensure continuity of service to customers at the 95.05° W.L. location, and thereby
promotes the public interest.

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

Sincerely,


CpthQ4h.4_
Cynthia J. Grady
Regulatory Counsel
Intelsat Corporation



cc: Stephen Duall
    Jay Whaley
    Cindy Spiers




the C—band); see also Application ofMotorola Satellite Communications, Inc. for Modification ofLicense, Order
and Authorization, 11 FCC Red 13952—13956 (Int‘l Bur. 1996) (authorizing service to fixed terminals in bands
allocated the mobile satellite service).
‘ EchoStar 83° Waiver, [ 13.



Document Created: 2014-11-05 12:50:44
Document Modified: 2014-11-05 12:50:44

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