Attachment Intelsat - Grant Sep

Intelsat - Grant Sep

DECISION submitted by IB, FCC

Grant

2018-09-20

This document pretains to SAT-STA-20180703-00050 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2018070300050_1537942

                                                                               File # SAT—$Th— 20180703— 60050
$2404       SAT—STA—20180703—00050      1B2018003421
Intelsat License LLC                                                           Call Sign 44047
                                                                                         52"{0"‘ Grant Date_ O3 /2'0/1§
                                                                               (or other identifier)                                      ;
                                                                                                       Term Dates Péfll—d of     Approved by OMB
                                                                               From 03/ZO/186                71,._I® d ay$                    3060—0678
                                                          GRANTED*“
    Date & Time Filed: Jul 3 2018 9:41:29:906AM         International Bureau   Approved:          9

    File Number: SAT—STA—20180703—00050                #with conditons                                          3. Dual)              |
    Callsign:                                                                                                       Branch
                                                                                                      chfgégqu.t Pgm:,
                                               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:
    Request for 180—Day STA to Drift and Operate Intelsat 805 at 169.1 E.L., Call Sign $2404
     1. Applicant

                Name:         Intelsat License LLC            Phone Number:                             703—559—7848

                DBA Name:                                     Fax Number:                               703—559—8539
                Street:       c/o Intelsat US LLC             E—Mail:                                   susan.crandall@intelsat.com
                              7900 Tysons One Place
                City:         McLean                          State:                                    VA
                Country:      USA                             Zipcode:                                  22102       —~3972
                Attention:    Susan H. Crandall


                                      ATTACHMENT TO GRANT
                                            Intelsat License LLC.
                                  IBFS File No. SAT—STA—20180703—00050

IBFS File No{s):        SAT—STA—20180703—00050                                               GR A NTE D —
Licensee/Grantee:       Intelsat License LLC                                                 With Conditions
Call Sign:              $2404                                                                               |
Satellite Name:         Intelsat 805
Orbital Location:       169.1° E.L.
(required station—      (+/— 0.05 degrees east/west station keeping)
keeping tolerance)
Administration:         United States of America
Nature of Service:      Fixed—Satellite Service; Telemetry, Tracking, and                  International Bureau
                        Command (TT&C)                                                       Satellite Division
Scope of Grant:         Special temporary authority for a period of 180 days to (1) conduct TT&C operations
                        necessary to drift Intelsat 805 from the 169.0° E.L. orbital location to the 169.1° E.L.
                        orbital location, and (2) provide fixed—satellite service from 169.1° E.L. in the 3400—4200
                        MHz (space—to—Earth), 5850—6650 MHz (Earth—to—space), 12.5—12.75 GHz (space—to—Earth),
                        and 14.0—14.25 GHz (Earth—to—space) frequency bands
Service Area            Australia, Eastern Asia, Japan, Western North America. See IBFS File No. SAT—AMD—
                        20151120—00077, Engineering Statement at 2.
Frequencies:            3400—4200 MHz (space—to—Earth)
                        5850—6650 MHz (Earth—to—space)
                        12.5—12.75 GHz (space—to—Earth)
                        14.0—14.25 GHz (Earth—to—space)

                        TT&C center frequencies:
                        3947.5 MHz; 3948.0 MHz; 3950.0 MHz; 3952.0 MHz (space—to—Earth)
                        6173.7 MHz; 6176.3 MHz; 12198.75 MHz (Earth—to—space)
Unless otherwise specified herein, operations under this grant must comport with the legal and technical
specifications set forth by the applicant or petitioner and with Federal Communication Commission‘s rules
not waived herein. This grant is also subject to the following conditions:


    1.   Operations pursuant to this special temporary authority must be on an unprotected and non—harmful
         interference basis, i.e., the Intelsat 805 space station must not cause harmful interference to, and must not
         claim protection from interference caused to it by, any other lawfully operating station. In the event of
         any harmful interference, Intelsat must cease operations immediately upon notification of such
         interference, and must inform the Commission, in writing, immediately of such an event.
   2.     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.    Intelsat must operate Intelsat 805 at the 169.1° E.L. orbital location in compliance with all existing or
         future coordination agreements for this location. In the absence of a coordination agreement, such
         communications must comply with applicable provisions of the ITU Radio Regulations as the
         Commission cannot guarantee the success of the required conditions.
   4.    While at the 169.1° E.L. orbital location, Intelsat must maintain the Intelsat 805 spacecraft with an
         east/west station—keeping tolerance of +/— 0.05 degrees.
   5.    The operations of Intelsat 805 and associated earth stations must comport with the applicable uplink and
         downlink limits in 47 CFR § 25.140(a)(3) of the Commission‘s rules, unless Intelsat coordinates any non—
         conforming operations with the operations of U.S.—licensed geostationary orbit space stations within 6
         degrees of the 169.1° E.L. orbital location. Intelsat must also comport with the maximum power limits
         indicated in existing or future coordination agreements at 169.1° E.L. Non—conforming operation must


                                                   Page 1 of 3


                                        ATTACHMENT TO GRANT
                                              Intelsat License LLC.
                                    IBFS File No. SAT—STA—20180703—00050

          also be coordinated with respect to those operations of non—U.S.—licensed space stations within 6 degrees
          of 169.1° E.L. involving approved communications with U.S.—licensed earth stations.
     6.   Use of the 3400—3600 MHz (space—to—Earth) frequency band is not permitted for non—Federal FSS in the
          United States Table of Frequency Allocations, 47 C.F.R. § 2.106. Intelsat must not permit any earth
          station in the United States or its possessions to operate with the Intelsat 805 space station in the 3400—
          3600 MHz (space—to—Earth) frequency band.‘
     7.   Intelsat must inform its customers and operators using the 3400—3600 MHz (space—to—Earth) frequency
          band of the potential for interference from U.S. government operations worldwide.
     8.   Intelsat‘s use of the 3600—3650 MHz (space—to—Earth) band is subject to GN Docket No. 12—3 54, which
          limits FSS communications within the United States in the 3600—3650 MHz band on a primary basis to
          existing earth stations or to new earth stations within 10 miles of existing earth stations. All other FSS
          earth station operations in the band 3600—3650 MHz must be on a secondary basis.
     9.   Intelsat‘s use of the 3600—3650 MHz (space—to—Earth) band is subject to footnote US245 of the United
          States Table of Frequency Allocations, 47 C.F.R. § 2.106, US245, which states that the 3600—3650 MHz
          use of the non—Federal FSS is limited to international inter—continental systems and is subject to case—by—
          case electromagnetic compatibility analysis.
      10. Intelsat‘s use of the 3650—3700 MHz (space—to—Earth) band is subject to footnote NG185 of the United
          States Table of Frequency Allocations, 47 C.F.R. § 2.106, NG185, which states that the 3650—3700 MHz
          use of the non—Federal FSS is limited to international inter—continental systems.
      11. Intelsat‘s use of the 3650—3700 MHz (space—to—Earth) band is subject to footnote NG169 of the United
          States Table of Frequency Allocations, which states that after December 1, 2000, operations on a primary
          basis by the FSS (space—to—Earth) in the band 3650—3700 MHz must be limited to grandfathered earth
          stations. All other FSS earth station operations in the band 3650—3700 MHz must be on a secondary
          basis.
      12. Use of the 5850—5925 MHz frequency band shall comply with the terms of footnote US245 to the U.S.
          Table of Frequency Allocations, 47 C.F.R. § 2.106, US245, and Section 2.108 of the Commission‘s rules,
          47 C.F.R. § 2.108, which states that the 5850—5925 MHz use of the non—Federal fixed—satellite service is
          limited to international, intercontinental satellite systems and is subject to case—by—case electromagnetic
          compatibility analysis. Intelsat shall not claim protection from radiolocation transmitting stations
          operating in accordance with footnote G2.°
      13. Intelsat is directed to bear in mind the needs of the passive services when operating the Intelsat 805 space
          station in the 6425—6650 MHz frequency band pursuant to Footnote 5.458 to the United States Table of
          Frequency Allocations, 47 C.F.R. §2.106, Footnote 5.458.




‘ Intelsat previously stated that the 3400—3600 MHz band would not be used in the United States. See Legal Narrative, IBFS
File No. SAT—MOD—20151020—00072, at 9.
2 Amendment of the Commission‘s Rules with Regard to Commercial Operations in the 3550—3650 MHz Band, GN Docket
No. 12—354, Notice of Proposed Rulemaking and Order, 27 FCC Red 15594, 15646, € 168 (2012).

3 For technical information of these radiolocation systems, see NTIA Report.83—115, Spectrum Resource Assessment in the
5650—5925 MHz Band, and NTIA Report 00—373, Measured Occupancy of 5850—5925 MHz and Adjacent 5—GHz Spectrum
in the United States at http://www.its.bldrdoc.gov/pub/pubs.php.

                                                       Page 2 of 3


                                         ATTACHMENT TO GRANT
                                               Intelsat License LLC.
                                     IBFS File No. SAT—STA—20180703—00050

      14. Intelsat‘s request that the prior waivers granted to Intelsat 805 for Sections 2.106, 25.114(d)(14)(ii),
          25.202(g), 25.210(f), and 25.283(c) of the Commission‘s rules be extended to the operation of Intelsat
          805 at 169.1° E.L. is GRANTED,* subject to the conditions in the prior grants."
      15. Any action taken or expense incurred as a result of operations pursuant to this special temporary authority
          is solely at Intelsat‘s own risk.

 Licensee/grantee is afforded thirty (30) days from the date of release of this action to decline the grant as
 conditioned. Failure to respond within this period will constitute formal acceptance of the grant as conditioned.
 This action is taken pursuant to Section 0.261 of the Commission‘s rules on delegated authority, 47 CFR § 0.261,
 and is effective upon release.

 Station licenses are subject to the conditions specified in Section 309(h) of the Communications Act of 1934, as
 amended, 47 U.S.C. § 309(h).

 Action           September 20, 2018
 Date:
 Term Dates       From: September 20, 2018              To: period of 180 days

 Approved:


                  /blgto)           Uull
                  Stephen {Duall
                  Chief, Satellite Policy Branch




4 We note that Section 25.202(a)(1) has been changed, and no longer applies, and Sections 25.210(a)(3) and 25.210(i)(1) have
been removed. Thus, Intelsat‘s request to extend the waiver for these rules is not needed. In addition, Intelsat requested a
waiver of Condition 19 in the Horizons 3e grant, which requires Intelsat 805 to continue providing service at the 169.0° E.L.
orbital location until Horizons 3e begins providing services there. Letter from Cynthia J. Grady, Regulatory Counsel, Intelsat
US LLC, to Marlene H. Dortch, Secretary, FCC, at 2 n.6 (dated July 3, 2018) (citing IBFS File No. SAT—MOD—20170622—
00093). We find that the waiver is not needed, in this instance, because the condition is designed to deter warehousing and
Intelsat 805‘s move to the 169.1° E.L. orbital location does not raise warehousing concerns since Intelsat will continue to
provide the same service at 169.1° E.L. as it did at 169.0° E.L.

5 See IBFS File Nos. SAT—MOD—20151020—00072, SAT—AMD—20151120—00077, grant stamp Feb. 24, 2016; Applications of
Intelsat LLC For Authority to Operate, and to Further Construct, Launch and Operate C—Band and Ku—Band Global
Satellites That Form a Global Communications System in Geostationary Orbit, Memorandum Opinion and Order and
Authorization, 15 FCC Red 15460, at Appendix C (2000), recon. denied, 15 FCC Red 25234.

                                                        Page 3 of 3


2. Contact


             Name:          Cynthia J. Grady                     Phone Number:                        703—559—6949
             Company:       Intelsat US LLC                      Fax Number:                          703—559—8539
             Street:        7900 Tysons One Place                E—Mail:                              cynthia.grady@intelsat.com


             City:          McLean                               State:          .                    VA
             Country:       USA                                  Zipcode:                             22102      —5972
             Attention:                                          Relationship:                        Legal Counsel


   (If your application is related to an application filed with the Commission, enter either the 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 exemption (see 47 C.F.R.Section 1.1114).
Cp Governmental Entity       t Noncommercial educational licensee
C Other(please explain):

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

«& Change Station Location                          {£4 Extend Expiration Date                       g£4 Other


6. Temporary Orbit Location                                                 7. Requested Extended Expiration Date
        169.1 E.L.


8. Description   (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.)
     Intelsat License LLC herein requests 180 days of the Special Temporary Authority,
     commencing August 10,             2018,     to drift Intelsat 805              (§$2404)    from 169.0 E.L.          to,   and operate
     at,   169.1 E.L.         Specifically,         Intelsat seeks STA to operate the telemetry,                           tracking,       and
     command and communications frequencies on the Intelsat 805 during the drift from 169.0 E.




9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject     @ Yes           y 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
Cynthia J. Grady                                                            Regulatory Counsel, Intelsat US LLC
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).


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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 of the Special Temporary Authority,                        commencing
August    10,    2018,   to drift   Intelsat   805   ($2404)   from 169.0 E.L.   to,   and operate at,    169.1 E.L.
Specifically,       Intelsat seeks STA to operate the telemetry,           tracking,     and command and
communications frequencies on the Intelsat 805 during the drift from 169.0 E.L.                     to 169.1 E.L.      and
on—station at 169.1 E.L.


                                                                                      INTELSAT
                                                                                       Envision. Connect. Transform.



July 3, 2018


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 Intelsat 805 to, and Operate at, 169.1° E.L.;
         Call Sign: $2404

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests 180 days of the Special Temporary Authority
("STA"),! commencing August 10, 2018, to drift Intelsat 805 ($2404) from 169.0° E.L. to, and operate
at, 169.1° E.L. Specifically, Intelsat seeks STA to operate the telemetry, tracking, and command
("TT&C") and communications frequencies on the Intelsat 805 during the drift from 169.0° E.L. to
169.1° E.L. and on—station at 169.1° E.L. The drift is expected to take approximately one week. Intelsat
will be filing shortly a permanent application for this redeployment.

Intelsat 805‘s TT&C frequencies are: 6173.7 MHz, 6176.3 MHz, and 12198.75 MHz in the uplink; and
3947.5 MHz, 3948.0 MHz, 3950.0 MHz, and 3952.0 MHz in the downlink. Intelsat 805‘s
communications frequencies are: 5850—6650 MHz and 14000—14250 MHz in the uplink; and 3400—4200
MHz and 12500—1 2750 MHz in the downlink.

The Intelsat 805 satellite is currently operating at 169.0° E.L. In order to bridge any gaps in service that
will occur between the start of inclined orbit operation of Intelsat 805° and the arrival of Horizons 3e




‘ Intelsat has filed this STA request, an 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—01139, File No. SAT—MOD—
20151020—00072 (Feb. 26, 2016) (Public Notice).

3 See Letter from Cynthia J. Grady, Regulatory Counsel, Intelsat Corporation, to Marlene H. Dortch,
Secretary, FCC, File No. SAT—MOD—20151020—00072 (June 27, 2017).
Intelsat Corporation
7900 Tysons One Place, Mclean, VA 22102—5972 USA www.intelsat.com T +1 703—559—6800


Ms. Marlene H. Dortch
July 3, 2018
Page 2



($2947),5 JCSAT—RA ($2960) will be nominally collocated with Intelsat 805. Both Intelsat 805 and
JCSAT—RA will operate at the nominal 169° E.L. until the arrival of Horizons 3e later this year.©

Grant of this modification application will not result in increased risk of harmful interference. As noted
above, Intelsat will operate the above listed TT&C and communications frequencies during the drift, and
will follow industry practices for coordinating transmissions during the relocation process. During the
drift to 169.1° E.L. Intelsat will continue to operate the TT&C frequencies and communications payload
in conformance with its coordination agreements concerning the nominal 169° E.L. location. Should
any interference occur during the drift, Intelsat will take all reasonable steps to eliminate such
interference. Additionally, Intelsat will operate Intelsat‘s communications payload and TT&C
frequencies at 169.1° E.L. in conformance with existing coordination agreements and the Federal
communications Commission‘s ("FCC" or "Commission") rules governing operations vis—a—vis adjacent
locations.

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 805 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 805 at 169.1° E.L. Finally, Intelsat is not aware of any system with an
overlapping station—keeping volume with Intelsat 805 at either location that is the subject of an ITU
filing and that is either in orbit or progressing towards launch.

In addition, Intelsat requests that the waiver previously granted to Intelsat 805 at 169.0° E.L. be
extended to the satellite at 169.1° E.L. Specifically, Intelsat requests that the waiver of Sections 2.106,



* See Policy Branch Information; Actions Taken, Report No. SAT—01313, File No. SAT—MOD—
20170622—00093 (Apr. 27, 2018).

° JCSAT—RA is currently operating at 128.0° E.L. Contingent on receipt of Commission authority,
JCSAT—RA will to be relocated to 169.0° E.L. See Policy Branch Information; Actions Taken, Report
No. SAT—01211, File No. SAT—LOA—20160411—00035 (Jan. 27, 2017) (Public Notice).

© Out of an abundance of caution, and to the extent necessary, Intelsat requests a waiver of Condition 19
of the Horizons 3e grant, which requires that Intelsat 805 continue providing service from 169.0° E.L. in
the 3700—4200 MHz, 5925—3425 MHz, 10.85—11.7 GHz, 12.5—12.75 GHz, and 14.0—14.25 GHz bands
until Horizons 3e begins providing services at 169.0° E.L. See Horizons—3 License LLC Application to
Modify Authorization for Horizons 3e Satellite (S2947), File No. SAT—MOD—20170622—00093
(condition #19, stamp grant issued Apr. 25, 2018 by Stephen J. Duall). Intelsat is seeking to move
Intelsat 805 one tenth of a degree to accommodate the arrival of JCSAT—RA at 169.0° E.L. and ensure
safe station—keeping of the satellites located at nominal 169° E.L. This accommodation will allow
Intelsat to continue providing continuity of service to customers at nominal 169° E.L. until Horizons 3e
arrives. As such, to the extent a waiver is required, grant would serve the public interest.


Ms. Marlene H. Dortch
July 3, 2018
Page 3



25.114(d)(14)(ii), 25.202(a)(1), 25.202(g), 25.210(a)(3), 25.210(i)(1), 25.210(f)," and 25.283(c) of the
Commission‘s rules be extended to the satellite at 169.1° E.L. for the reasons previously set forth.©

Grant of this STA request is in the public interest because it will allow Intelsat to ensure continuity of
service at the nominal 169° E.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 request
to the undersigned at (703) 559—6949.


Sincerely,

/s/ Cynthia J. Grady

Cynthia J. Grady
Regulatory Counsel
Intelsat US LLC



ce: Stephen Duall
    Jay Whaley
    Cindy Spiers




" Intelsat 805 previously obtained a waiver of Section 25.210(g)(1), which required full frequency reuse.
This requirement is now included in Section 25.210(f).

8 See Policy Branch Information; Actions Taken, Report No. SAT—01139, File No. SAT—MOD—
20151020—00072 (Feb. 26, 2016) (Public Notice).



Document Created: 2018-09-24 16:53:38
Document Modified: 2018-09-24 16:53:38

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