Attachment STA Request

This document pretains to SAT-STA-20190128-00003 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2019012800003_1611924

January 28, 2019 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Request for Extension of Special Temporary Authority to Drift JCSAT-RA to, and Operate at, 168.9° E.L. Call Sign: S2960 Dear Ms. Dortch: Intelsat License LLC (“Intelsat”) herein requests an additional 30 days of Special Temporary Authority (“STA”)1 previously granted Intelsat to drift JCSAT-RA (Call Sign S2960) from 169.0° E.L. to 168.9° E.L. and operate the satellite temporarily at 168.9° E.L. The JCSAT-RA satellite is permanently licensed to operate at 169.0 E.L.,2 and is currently operating at 168.9° E.L. subject to STA.3 Intelsat relocated JCSAT-RA to accommodate the arrival of Horizons 3e (S2947) at 169.0° E.L. following the satellite’s successful launch. On-station at 168.9° E.L., Intelsat will continue to utilize the satellite’s telemetry, tracking, and control (“TT&C”) and communications frequencies. The specific TT&C frequencies are: 4199.55 MHz (beacon), 12.2485 GHz (beacon), 12.7472 GHz (beacon), 12.74835 GHz, and 12.74975 GHz (space-to-Earth); and 13.9935 GHz and 14.496 GHz (Earth-to-space). The specific communications frequencies are: 3940-4200 MHz, 6225-6425 MHz, 6425-6485 MHz, 12200-12250 MHz, 12250- 12500 MHz, 12500-12750 MHz, 13750-13997 MHz, 13997-14000 MHz, 14000-14250 MHz, and 14250-14500 MHz 1 Intelsat has filed this STA request, an FCC Form 159, and a $980.00 filing fee electronically via the International Bureau’s Filing System. 2 See Policy Branch Information; Actions Taken, Report No. SAT-01330, File No. SAT-LOA- 20160411-00035 (July 13, 2018) (Public Notice). 3 See Policy Branch Information; Actions Taken, Report No. SAT-01366, File No. SAT-STA- 20181218-00091 (Dec. 21, 2018) (Public Notice).

Ms. Marlene H. Dortch January 28, 2019 Page 2 Grant of this STA extension request will not result in increased risk of harmful interference. On- station at 168.9° E.L., Intelsat will continue to operate the satellite in conformance with its coordination agreements concerning the nominal 169.0° E.L. location. 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 is not aware of any FCC licensed system, or any other system applied for and under consideration by the FCC, having an overlapping station-keeping volume with JCSAT-RA at 168.9° E.L. Finally, Intelsat is not aware of any system with an overlapping station-keeping volume with JCSAT-RA that is the subject of an ITU filing and that is either in orbit or progressing towards launch. In support of this STA extension request, Intelsat requests that the prior waivers granted for JCSAT- RA for Section 2.106 regarding the 12.2-12.7 GHz and 12.7-12.75 bands at 169.0° E.L. be extended to JCSAT-RA at 168.9° E.L. Grant of this STA extension request is in the public interest because it will allow Intelsat to continue safely station-keep JCSAT-RA at the nominal 169° 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 STA request to the undersigned at (703) 559-6949. Sincerely, /s/ Cynthia J. Grady Cynthia J. Grady Senior Counsel Intelsat US LLC cc: Stephen Duall Jay Whaley Cindy Spiers


Document Created: 2019-01-28 12:15:16
Document Modified: 2019-01-28 12:15:16
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