Attachment STA Request

This document pretains to SAT-STA-20180502-00040 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2018050200040_1386874

May 2, 2018


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

Re:     Request for Special Temporary Authority to Operate Intelsat 5 at 137.0° W.L.
        Call Sign: S2704

Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”) herein requests 180 days, commencing upon grant, of Special
Temporary Authority (“STA”)1 to operate Intelsat 5 (Call Sign S2704) at 137.0° W.L.

Subject to receipt of Federal Communications Commission (“FCC” or “Commission”) approval, the
satellite will be relocated to 137.0° W.L. Intelsat 5 is currently drifting to 93.2° W.L.2 and its
permanently licensed location is 156.9° E.L.3 The drift to 137.0° W.L. should be completed by the end
of May.

The FCC recently made available for reassignment the C-band frequencies at 137° W.L.,4 which
provides a new opportunity for the Intelsat 5 satellite. Intelsat has filed to modify the authorization for
the Intelsat 5 satellite to redeploy Intelsat 5 to 137.0° W.L.5 In support of this relocation, Intelsat
concurrently will be requesting 30 days of STA to drift Intelsat 5 to 137.0° W.L. and operate the satellite
at 137.0° W.L.

The specific telemetry, tracking, and control (“TT&C”) frequencies for Intelsat 5 are as follows: 14498
MHz (H) and 13999 MHz (RHCP) in the uplink; and 11451 MHz (H, V, and RHCP), 11452 MHz (H,
V, and RHCP), and 11454 MHz (RHCP, and LHCP) in the downlink.

1
         Intelsat has filed this STA request, an FCC Form 159, and a $945.00 filing fee electronically via the
International Bureau’s Filing System.
2
        See File No. SAT-STA-20180410-00027 (granted Apr. 13, 2018).
3
     See Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01236, File No. SAT-
MOD-20170331-00057 (May 5, 2017).
4
        See Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01313 (Apr. 27, 2018).
5
       See Intelsat License LLC Modification of Authorization to Redeploy to, and Operate Intelsat 5 (S2704) at,
137.0 W.L., File No. SAT-MOD-20180501-00036 (filed May 1, 2018).


Ms. Marlene H. Dortch
May 2, 2018
Page 2



The communications frequencies for Intelsat 5 are: 5925-6425 MHz, 12750-13250 MHz, and 14000-
14250 MHz in the uplink; and 3700-4200 MHz, 10700-10950 MHz, 11200-11450 MHz, and 11450-
11700 MHz in the downlink.

Grant of this STA request will not result in increased risk of harmful interference. Once on-station at
137.0° W.L., Intelsat will operate the communications payload in conformance with FCC rules and any
relevant coordination agreements.

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 5 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 5 at 137.0° W.L. Finally, Intelsat is not aware of any system with
an overlapping station-keeping volume with Intelsat 5 that is the subject of an International
Telecommunication Union (“ITU”) filing and that is either in orbit or progressing towards launch.

In addition, Intelsat requests that the waiver previously granted to Intelsat 5 at 156.9° E.L. be extended
to the satellite at 137.0° W.L. Specifically, Intelsat requests that the waiver of Section
25.114(c)(4)(vi)(A) of the FCC’s rules, requiring applicants to provide predicted space station antenna
gain contours for each transmit and receive antenna beam requested, previously granted for Intelsat 5 be
extended to the satellite at 137.0° W.L.6

Grant of this STA request is in the public interest because it will allow Intelsat to provide new capacity
from the 137.0° W.L. orbital location.

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) 559-6949.


Sincerely,

/s/ Cynthia J. Grady

Cynthia J. Grady
Regulatory Counsel
Intelsat Corporation


cc: Stephen Duall
    Jay Whaley
    Cindy Spiers


6
 See 47 C.F.R. § 25.114(c)(4)(vi)(A); Application of Intelsat License LLC to Modify Authorization for Intelsat 5
(S2704), Stamp Grant, File No. SAT-MOD-20170331-00057, Condition 9 (May 4, 2017).



Document Created: 2018-05-02 16:05:30
Document Modified: 2018-05-02 16:05:30

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