Attachment STA Request

This document pretains to SAT-STA-20180118-00007 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2018011800007_1327531

January 18, 2018 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Request for Further Extension of Special Temporary Authority to Conduct In-Orbit Testing of Intelsat 37e; Call Sign S2972 Dear Ms. Dortch: Intelsat License LLC (“Intelsat”) herein requests an additional 30 days of the Special Temporary Authority (“STA”)1 previously granted Intelsat to conduct in-orbit testing (“IOT”) of the Intelsat 37e satellite (Call Sign S2972) at 84.55º E.L., and to drift the satellite to its permanent location of 18.0° W.L.2 Intelsat 37e was launched on September 29, 2017. Intelsat expects to complete IOT at Intelsat 37e’s final location of 18.0° W.L. in late February. Intelsat 37e payload testing will continue to be performed in the following frequency bands:  3400-4200 MHz, 10700-11950 MHz, and 12500-12750 MHz, 18300-18800 MHz, and 19700-20200 MHz (space-to-Earth); and  5850-6650 MHz, 13000-13250 MHz, 13750-14500 MHz, 28350-28850 MHz, and 29500- 30000 MHz (Earth-to-space). Telemetry, Tracking, and Command (“TT&C”) services for Intelsat 37e will continue to be performed at the following center frequencies and in the following frequency bands:  4197.75 MHz, 4198.25 MHz, 4198.75 MHz, and 4199.25 MHz (space-to-Earth); and 1 Intelsat has filed this STA request, FCC Form 159, and a $945.00 filing fee electronically via the International Bureau's Filing System. 2 See Intelsat License LLC Request for Further Extension of Special Temporary Authority to Conduct In-Orbit Testing of Intelsat 37e, Call Sign S2972, File No. SAT-STA-20171218-00173 (filed Dec. 18, 2017); Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01287, IBFS File No. SAT-STA-20171115-00156 (Dec. 1, 2017); Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01274, IBFS File No. SAT-STA-20170921-00135 (Oct. 6, 2017); Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01243, IBFS File No. SAT-LOA-20160915-00089 (June 9, 2017). During the drift from 84.55º E.L. to 18.0º W.L., only the satellite’s TT&C frequencies will be utilized.

Ms. Marlene H. Dortch January 18, 2018 Page 2  5850.5-5853.0 MHz and 6422.0-6424.5 MHz (Earth-to-space), selectable via ground command in 100 kilohertz steps. In support of its further extension request, Intelsat submits the following information. During the IOT of Intelsat 37e, Intelsat will continue to operate in the above referenced C-, Ku-, and Ka- band frequencies. 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 84.55º E.L. Intelsat 37e 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 Federal Communications Commission (“FCC”) licensed system, or any other system applied for and under consideration by the FCC, having an overlapping station-keeping volume with Intelsat 37e at 84.55º E.L. In addition, Intelsat is not aware of any system with an overlapping station-keeping volume with Intelsat 37e at 84.55º E.L. that is the subject of an International Telecommunications Union filing and that is either in orbit or progressing towards launch. The IOT of Intelsat 37e’s C-, Ku-, and Ka-band payloads at 84.55º E.L. is a critical step in ensuring that the satellite will be fully operational at 18.0º W.L. This, in turn, will provide additional capacity to customers at the 18.0º W.L. location, and thereby promotes the public interest. For the reasons set forth herein, Intelsat respectfully requests that the Commission grant this further extension request. Sincerely, /s/ Susan H. Crandall Susan H. Crandall Associate General Counsel Intelsat Corporation cc: Stephen Duall Jay Whaley Cindy Spiers


Document Created: 2018-01-18 14:29:13
Document Modified: 2018-01-18 14:29:13
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