Attachment STA Request

This document pretains to SAT-STA-20180312-00021 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2018031200021_1352921

                                                                                     INTELSAT.
                                                                                       Envision. Connect. Transform.


March 12, 2018



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

Re:       Request for Extension of Special Temporary Authority to Drift Intelsat 1R to, and Operate at,
          157.1° E.L.; Call Sign: $2368

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests an additional 30 days of the Special Temporary
Authority (sTA*Y previously granted Intelsat to drift Intelsat 1R (Call Sign $2368) from 169.2° E.L.
to 157.1° E.L. and operate the satellite at 157.1° E.L.

The Intelsat 1R satellite‘s permanent licensed location is 50.1° W.L.," and the satellite is currently
operating at 157.1° E.L. pursuant to STA authority." Intelsat has a pending modification application to
operate the Intelsat 1R satellite permanently at 157.1° E.L.

While operating at 157.1° E.L., Intelsat will continue to 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: 13995 MHz and
14498.5 MHz (Earth—to—space); and 11696 MHz and 11697 MHz (space—to—Earth).

At 157.1° E.L., Intelsat will also continue to operate on the following communications frequencies:
5925—6425 MHz, and 13750—14500 MHz, (Earth—to—space); and 3700—4200 MHz, 10950—1 1200 MHz,
and 11450—11950 MHz (space—to—Earth).

Grant of this STA extension request will not result in increased risk of harmfulinterference. While on—
station at 157.1° E.L., Intelsat will continue to operate the communications payload in conformance with
its coordination agreements concerning the nominal 157° E.L. location.


‘ Intelsat has filed this STA request, FCC Form 159, and a $945.00 filing fee electronically via the International
Bureau‘s Filing System.
* See Policy Branch Information; Actions Taken, Report No. SAT—01156, File No. SAT—MOD—20160219—00019
(May 6, 2016) (Public Notice).
3 See Policy Branch Information; Actions Taken, Report No. SAT—01263, File No. SAT—STA—20170626—00100
(Aug. 25, 2017) (Public Notice).
* See Policy Branch Information; Satellite Space Applications Acceptedfor Filing, Report No. SAT—01300, File
No. SAT—MOD—20180103—00002 (Feb. 9, 2018) (Public Notice).
Intelsat Corporation
7900 Tysons One Place, Mclean, VA 22102—5972 USA www.intelsat.com T+1 703—559—6800


Ms. Marlene H. Dortch
March 12, 2018
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. Intelsat 1R is not 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 1R at 157.1° E.L. Finally, Intelsat is not aware of any system with an
overlapping station—keeping volume with Intelsat 1R that is the subject of an ITU filing and that is either
in orbit or progressing towards launch.

In addition, Intelsat requests that all applicable waivers previously granted to Intelsat 1R at 169.2° E.L.
continue to be extended to the satellite at 157.1° E.L. for the reasons previously set forth in the
permanent grant for Intelsat 1R at 50.1° wW.LS

Grant of this STA extension request is in the public interest because it will allow Intelsat to continue
providing service at 157.1° E.L.

For the reasons set forth herein, Intelsat respectfully requests that the Commission grant this STA
extension request. Please direct any questions regarding this supplement to the undersigned at
(703) 559—6949.


Sincerely,


 CogrithenQ VMhaole
      Acypyfhe          —o    ELL"/L

Cynthia J. Grady
Regulatory Counsel
Intelsat Corporation




ce:     Stephen Duall
       Jay Whaley
       Cindy Spiers




5 See supra at n. 2. Due to the modification of several technical rules, certain waivers previously issued to Intelsat
for operation of the Intelsat 1R satellite are no longer required. E.g., Section 25.211(a), 25.202(g), Section
25.114(d)(3), and Section 25.283(c) recently have been eliminated or modified, so waivers are no longer required
under the new Part 25 rules. See Comprehensive Reviewof Licensing and Operating Rules for Satellite Services,
Second Report and Order, IB Docket No. 12—267, FCC 15—167 at «[ 333 (rel. Dec. 17, 2015).



Document Created: 2018-03-12 14:57:02
Document Modified: 2018-03-12 14:57:02

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