Attachment STA Request

This document pretains to SAT-STA-20160722-00069 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2016072200069_1144492

July 22, 2016 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Request for Special Temporary Authority to Conduct In-Orbit Testing of Intelsat 33e; Call Sign S2939 Dear Ms. Dortch: Intelsat License LLC (“Intelsat”) herein requests a grant of Special Temporary Authority (“STA”)1 for 30 days, beginning September 10, 2016 to conduct in-orbit testing (“IOT”) of the Intelsat 33e satellite (Call Sign S2939) at 59.55º E.L. and to drift the satellite to its permanent location of 60.0° E.L.2 Intelsat 33e is scheduled to be launched on August 24, 2016. The IOT period is expected to last approximately 35 days; and the drift to 60.0° E.L. is expected to last approximately four days. Intelsat 33e IOT payload testing will be performed in the following frequency bands:  3625 – 4200 MHz, 10950 – 11200 MHz, 11200 – 11450 MHz,3 11450 – 12200 MHz, 12500 – 12600 MHz, and 18300 – 20200 MHz (space-to-Earth);  5850 – 6725 MHz, 13750 – 13850 MHz, 14000 – 14500 MHz, 17300 – 17800 MHz, and 28100 – 30000 MHz (Earth-to-space). Telemetry, Tracking, and Command (“TT&C”) services for Intelsat 33e will be performed in the following center frequencies:  4197.25 MHz, 4197.75 MHz, 4198.25MHz, and 4198.75 MHz (space-to-Earth);  6422.00 MHz, 6424.5 MHz, 5850.5 MHz, and 5853.0 MHz (Earth-to-space). In support of its request, Intelsat submits the following information. During the IOT of Intelsat 33e, Intelsat will operate in the above referenced C-, Ku-, and Ka-bands. Intelsat has identified the operational satellites within +/-6 degrees of the IOT location. Coordination is 1 Intelsat has filed this STA request, an FCC Form 159, and a $930.00 filing fee electronically via the International Bureau’s Filing System. 2 See Policy Branch Information; Actions Taken, Report No. SAT-01139, File No. SAT-LOA- 20150327-00016 (Feb. 26, 2016) (Public Notice). During the drift from 59.55° E.L. to 60.0º E.L., only the satellite’s TT&C frequencies will be utilized. 3 Intelsat did not seek authority, and is not licensed, to operate in this band at 60.0° E.L.

Ms. Marlene H. Dortch July 22, 2016 Page 2 ongoing with several operators of such satellites to resolve potential interference issues. Intelsat expects to complete coordination discussions before launch of the Intelsat 33e satellite. 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 59.55º E.L. Intelsat 33e 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 33e at 59.55° E.L. In addition, Intelsat is not aware of any system with an overlapping station-keeping volume with Intelsat 33e at 59.55° E.L. that is the subject of an International Telecommunication Union (“ITU”) filing and that is either in orbit or progressing towards launch. Intelsat’s IOT operations in the 12500 – 12600 MHz, 17300 – 17800 MHz, 18800 – 19300 MHz, and 19300 – 19700 MHz frequency bands at the 59.55° E.L. orbital location will only occur in Regions 1 and 3, consistent with the frequency allocations in Regions 1 and 3. Finally, Intelsat requests that the waivers previously granted to Intelsat 33e at 60.0° E.L. be extended to the satellite at 59.55° E.L. In particular, Intelsat requests that the previously-granted waivers of Sections 25.210(f) and 25.210(i)(1) be extended to the satellite at 59.55° E.L., for the reasons previously set forth in the previous grant.4 The IOT of Intelsat 33e’s C-, Ku-, and Ka-band payloads at 59.55º E.L. is a critical step in ensuring that the satellite will be fully operational at 60.0º E.L. This, in turn, will provide additional capacity to customers at the 60.0º E.L. location, and thereby promotes the public interest. For the reasons set forth herein, Intelsat respectfully requests that the Commission grant this request. Sincerely, /s/ Cynthia J. Grady Cynthia J. Grady Regulatory Counsel Intelsat Corporation cc: Stephen Duall Jay Whaley Cindy Spiers 4 See supra note 2.


Document Created: 2016-07-22 15:06:20
Document Modified: 2016-07-22 15:06:20
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