Attachment Intelsat - Grant Aug

Intelsat - Grant Aug

DECISION submitted by IB,FCC

Grant

2015-08-20

This document pretains to SAT-STA-20150505-00033 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2015050500033_1101041

$2253         SAT—STA—20150505—00033      182015000869                             File #_Snt—ST—20i5p5o5— COoo33
Intelsat License LLC
Galaxy 11
                                                                                   CallSign §225% Grant Date_O#{20 /15
                                                                                   (or other identifier)                     L            Approved by OMB
                                                                                       ;                   Term Dates pericd of                 3060—0678
                                                                                   From _1 ZHS ZIS                  To, 180 de
  Date & Time Filed: May 5 2015 10:46:37:056AM            International Bureau_|   Approved:
  File Number: SAT—STA—20150505—00033                       —            ¢
        o                                                ¥wrh condihore                                S            J. Puall
  Callsign:                                                                                            cCn      ,     Setel ite PolicyBrarch
                                              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:
   180—Day STA to Drift and Operate Galaxy 11 at 60.1 E.L. ($2253)
  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:         McLcan                             State:                                     VA

               Country:       USA                               Zipcode:                                   22102          —5972
               Attention:    Susan H. Crandall


                                               Attachment to Grant
                                 IBFS File No. SAT—STA—20150505—00033
                                                 Call Sign $2253

The application of Intelsat License LLC (Intelsat) for special temporary authority, IBFS File No.
SAT—STA—20150505—00033, is GRANTED in part and DEFERRED in pal‘t‘l Specifically, Intelsat is
authorized, for a period of 180 days, commencing on November 15, 2015, to conduct Telemetry,
Tracking, and Command (TT&C) operations with the Galaxy 11 space station (Call Sign $2253)
necessary to drift the Galaxy 11 space station from the 55.6° W.L. orbital location to the 60.1° E.L.
orbital location—and to maintain Galaxy 11 at 60.1° E.L.—using the following center frequencies: 14000.5
MHz, 14498.5 MHz, 11701 MHz, and 11702 MHz. No action is taken on Intelsat‘s requests to modify
the post—mission disposal plan for Galaxy 11 and to operate Galaxy 11 at 60.1° E.L. using the 13.75—14.5
GHz (Earth—to—space), 10.95—11.2 GHz (space—to—Earth), and 11.7—12.2 GHz (space—to—Earth) frequency
bands. Operations under this authorization must be in accordance with the technical specifications set
forth in Intelsat‘s application and its current authorization for Galaxy 11, IBFS File No. SAT—MOD—
20121018—00184, Federal Communication Commission rules not waived herein, and are subject to the
following conditions:
         1.      All operations under this authorization must be on an unprotected and non—harmful
interference basis, i.e., the Galaxy 11 space station shall not cause harmful interference to, and shall not
claim protection frominterference caused to it by, any other lawfully operating station. In the event of
any harmful interference, Intelsat shall cease operations immediately upon notification of such
interference, and shall inform the Commission, in writing, immediately of such an event.
         3.       In connection with the provision of service in any particular country, Intelsat is obliged to
comply with the applicable laws, regulations, rules, and licensing procedures of that country.
        3.      While at the 60.1° E.L. orbital location, Intelsat must maintain the Galaxy 11 spacecraft
with an east/west longitudinal station—keeping tolerance of +/— 0.05 degrees.
        4.       Any action taken or expense incurred as a result of operations pursuant to this special
temporary authority is solely at Intelsat‘s own risk.
         5.      Intelsat is afforded thirty days from the date ofrelease ofthis grant and authorization to
decline this authorization as conditioned, Failure to respond within this period will constitute formal
acceptance of the authorization as conditioned.
         6.      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 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 date of the public notice indicating that this action was taken.

                                                                 Filo a#    T—       —205    0505 —Ooo!


                                                                 Cull Sign $2253$ GrantDate 0§/20/15
                                                                 (or other identifier)
                                                                                         Torm Dates W\"\Od of
                                                                 From, 11 / IS[ 5              To:   180 d‘fis



                                          +uch conddions


* The application was placed on Public Notice as accepted for filing on June 5, 2015, See Policy Branch
Information, Satellite Space Applications Acceptedfor Filing, Public Notice, Report No. SAT—01089 (IBFS File No.
SAT—STA—20150505—00033). No comments were filed.

                                                         1


2. Contact


             Name:           Susan H. Crandall                   Phone Number:                         703—559—7848
             Company:        Intelsat Corporation                Fax Number:                           703—559—8539
             Street:         7900 Tysons One Place               E—Mail:                               susan.crandall@intelsat.com



             City:           McLean                              State:                                VA

             Country:        USA                                 Zipcode:                              22102      —5972
             Attention:                                          Relationship:                         Legal Counsel


   (If your applicationis related to an applicationfiled with the Commission, entereitherthe 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 exeimption (see 47 C.F.R.Section 1.1114).
3 Governmental Entity         [e] Noncommercial educational licensee
[e] Other(please explain):

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


@   Change Station Location                          3   Extend Expiration
                                                                   P       Date                       W   Other


6. Temporary Orbit Location                                                 7. Requested Extended Expiration Date


8. Description   (If the complete description does not appearin this box, please go to the end of the formto view it in its entirety.)
     Intelsat License LLC herein requests 180 days,                           commencing November 15,              2015,    of Special
     Temporary Authority to drift Galaxy 11                        (Call Sign $2253)         from 55.6 W.L.          to 60.1 E.L.        and
     operate the satellite temporarily at 60.1 E.L.                            Intelsat also herein notifies the Federal
     Communications Commission of a revised post—mission disposal statement with respect to the




9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject @ Yos             gty 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
Susan H. Crandall                                                          Assoc. General 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).


FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT

The public reporting for this collection of informationis estimated to average 2 hours per response, including the time forreviewing instructions,
searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection ofinformation. If you
have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the
Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC20554. We will also accept
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DO NOT SEND COMPLETED FORMS TO THIS ADDRESS.

Remember — You are not required to respond to a collection ofinformation sponsored by the Federal government, and the government may not
conduct or sponsorthis collection, unless it displays a currently valid OMB control numberorif we fail to provide you with this notice. This
collection has been assigned an OMB control number of 3060—0678.

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 180 days,     commencing November 15,   2015,   of Special Temporary
Authority to drift Galaxy 11   (Call Sign $2253)   from 55.6 W.L.   to 60.1 E.L.   and operate the
satellite temporarily at 60.1 E.L.    Intelsat also herein notifies the Federal Communications
Commission of a revised post—mission disposal statement with respect to the Galaxy 11 satellite.


                                                                                      INTELSAT.
                                                                                       Envision. Connect. Transform.


May 5, 2015


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

Re:      Request for Special Temporary Authority to Drift Galaxy 11 to, and Operate at, 60.1° E.L. and
         Notification of Revised Post—mission Disposal Statement; Call Sign: $2253

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests 180 days, commencing November 15, 2015, of Special
Temporary Authority ("STA")‘ to drift Galaxy 11 (Call Sign $2253) from 55.6° W.L. to 60.1° E.L. and
operate the satellite temporarily at 60.1° E.L. Intelsat also herein notifies the Federal Communications
Commission ("FCC") of a revised post—mission disposal statement with respect to the Galaxy 11
satellite.

The Galaxy 11 satellite is currently operating at 55.6° W.L.. Subject to receipt of FCC approval, the
satellite will be relocated to 60.1° E.L.—with the drift starting no earlier than November 15, 2015. The
satellite should arrive on—station by late May 2016. Intelsat is relocating the Galaxy 11 satellite to meet
a temporary customer demand.

During the drift of the Galaxy 11 satellite from 55.6° W.L. to 60.1° E.L., Intelsat will utilize only the
satellite‘s telemetry, tracking, and control ("TT&C") frequencies and will follow industry practices for
coordinating TT&C transmission during the relocation process. The specific TT&C frequencies are:
14000.5 MHz, 14498.5 MHz, 11701 MHz, and 11702 MHz.

Once located at 60.1° E.L., Intelsat will also operate on the following communications frequencies:
13750 — 14500 MHz, 10950 — 11200 MHz, and 11700 — 12200 MHz.

Grant of this STA request will not result in increased risk of harmful interference. As noted above,
Intelsat will operate only the above listed TT&C frequencies during the drift, and will coordinate its
TT&C transmissions with operators of satellites in the drift path. Should any interference occur during
the drift, Intelsat will take all reasonable steps to eliminate such interference. Once on—station at 60.1°
E.L., Intelsat will operate the communications payload in conformance with its coordination agreements
concerning the nominal 60° E.L. location.

‘ Intelsat has filed this STA request, an FCC Form 159, and a $930.00 filing fee electronically via the
International Bureau‘s Filing System.
* See Policy Branch Information; Actions Taken, Report No. SAT—01050, File No. SAT—MOD—20121018—00184
(Oct. 31, 2014) (Public Notice) (hereinafter "Galaxy 11 Modification®).

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


Ms. Marlene H. Dortch
May 5, 2015
Page 2




Further, 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. Galaxy 11 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 Galaxy 11 at 60.1° E.L. Finally, Intelsat is not aware of any system with
an overlapping station—keeping volume with Galaxy 11 that is the subject of an ITU filing and that is
either in orbit or progressing towards launch.                                           '

Grant of this STA request is in the public interest because it will allow Intelsat to meet a temporary
customer demand at 60.1° E.L.

In addition, Intelsat notifies the FCC that it now expects to dispose of the spacecraft by moving it to a
planned minimum altitude of 175 kilometers (perigee) above the geostationary arc." Intelsat is reserving
29.4 kg of fuel for this purpose. As the Commission is aware, because there is no mechanism for
precisely calculating the amount of fuel left on the spacecraft once it is in orbit, it is possible that the
spacecraft will not meet the planned minimum de—orbit altitude.

In its Second Report and Order in IB Docket 02—54, Mitigation of Orbital Debris,* the FCC declared that
satellites launched prior to March 18, 2002, such as the Galaxy 11 satellite, would be designated as
grandfathered satellites not subject to a specific disposal altitude. Therefore, the planned disposal orbit
for Galaxy 11, as revised, complies with the FCC‘s rules.

In addition, Intelsat provides the following information:

    1)    Planned orbital eccentricity: 0.00035 (This is a best estimate of optimal eccentricity to match the
         natural eccentricity circle due to Sun and Moon perturbations after decommission.)"




* In 2012, Intelsat stated that it expected to de—orbit the Galaxy 11 satellite to an altitude of 300 km. See Galaxy
11 Modification, Engineering Statement at 9. To the extent necessary, Intelsat requests that the waiver of
Sections 25.114(d)(14)(ii) and 25.283(c) previously granted to the Galaxy 11 spacecraft continue to apply. These
rules require that spacecraft are able to vent all pressurized systems at end of life. See Intelsat License LLC, _
Application to Modify Authorization for Galaxy 11, File No. SAT—MOD—20121018—00184, Stamp Grant at «[ 4
(Oct. 30, 2014).
* Mitigation of Orbital Debris, Second Report and Order, IB Docket No. 02—54, released June 21, 2004.

* Intelsat‘s priority is to achieve the planned minimum perigee of 175 km. However, because it is extremely
difficult to anticipate end—of—life thruster performance and operational conditions, it is extremely difficult to
achieve the planned eccentricity. In order to achieve the planned eccentricity, not only must there be sufficient
propellant reserved but, in addition, individual thrusters must be fired at specific times during satellite
decommissioning because the timing of thruster firing will affect eccentricity. Due to difficulties in predicting the
thruster end—of—life performance, as well as earth station availability and visibility as the satellite drifts, it may not
be possible to fire the right thruster at the optimal times. Thus, optimal eccentricity may not be achieved, which,
in turn, will affect the apogee altitude.


Ms. Marlene H. Dortch
May 5, 2015
Page 3



      2)   Planned apogee altitude: 189.4 km above the geostationary arc.

      3)    Information concerning the methods that will be used to assess and provide adequate margins
           concerning fuel gauging uncertainty:©
               a. Intelsat propulsion engineers review the current propellant usage—particularly the
                  mixing ratio—to properly allocate sufficient margin to account for unavailable propellant
                  that may result from a non—optimal mixing ratio, in addition to the nominal hold—back and
                 reserves provided to us by the manufacturer.
              b. Intelsat performs thermal gauging nearthe spacecraft‘s end oflife by inferring the
                 remaining propellant from the thermal signature when Intelsat applies heat to different
                  part of the propellant tank system.


For the reasons set forth herein, Intelsat respectfully requests that the Commission grant this STA
request. Please direct any questions regarding this supplement to the undersigned at (703) 559—7848.


Sincerely,

 CyACAcG—
Susan H. Crandall
Associate General Counsel
Intelsat Corporation




ce:    Stephen Duall
       Jay Whaley
       Cindy Spiers




© This information is considered when determining the additional hold—back and adjustments to book values to
attempt to ensure sufficient propellant to achieve the planned minimumaltitude. There are, however, many
uncertainties to both methods that could lead to incorrect conclusions regarding remaining fuel, which could
affect the disposal altitude the spacecraft reaches.



Document Created: 2015-08-20 18:40:41
Document Modified: 2015-08-20 18:40:41

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