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).

FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting for this collection of information is estimated to average 2 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. If you have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA@fcee.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS. Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not conduct or sponsor this collection, unless it displays a currently valid‘OMB control number or if we fail to provide you with this notice. This collection has been assigned an OMB control number of 3060—0678. 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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