Attachment STA Request

This document pretains to SAT-STA-20190711-00060 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2019071100060_1787105

July 11, 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 Operate Intelsat 901 at 29.5° W.L.
       with New Frequencies; Call Sign: S2405


Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”) herein requests an additional 30 days of Special Temporary
Authority (“STA”)1 previously granted to Intelsat to operate Intelsat 901 (Call Sign S2405) in the
communications frequencies 3625-3700 MHz and 5850-5925 MHz in order to provide additional
capacity at 29.5° W.L.2 The proposed operations are expected to last approximately five months.

Intelsat 901 is permanently licensed to operate at 29.5° W.L. in the following bands: 3700-4200 MHz,
5925-6425 MHz, 10950-11200 MHz, 11450-11700 MHz, and 14000-14500 MHz.3 Intelsat is seeking
authority to continue to operate in 3625-3700 MHz and 5850-5925 MHz. This will allow Intelsat to
continue serving customers in these frequency bands.



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 Satellite Policy Branch Information, Actions Taken, Report No. SAT-01397, File No. SAT-
STA-20190610-00045 (June 21, 2019) (Public Notice).
3
  See Satellite Policy Branch Information, Actions Taken, Report No. SAT-01290, File No. SAT-
MOD-20170831-00126 (Dec. 15, 2017) (Public Notice). Although Intelsat 901 is capable of
operating in the 3625-3700 MHz and 5850-5925 MHz bands, Intelsat did not originally seek authority
to operate in these bands at 29.5° W.L.


Ms. Marlene H. Dortch
July 11, 2019
Page 2




Additionally, Intelsat is seeking to continue to operate under No. 4.4 of the International
Telecommunication Union (“ITU”) Radio Regulations. Intelsat has assessed the operational
environment near 29.5° W.L. and there are currently no co-frequency operations in 3625-3700 MHz
and 5850-5925 MHz within +/- 6 degrees. Intelsat’s continued operation of Intelsat 901 will be on a
non-interference, non-protection basis and will conform with the Federal Communications
Commission’s rules governing operations vis-à-vis adjacent locations.

Later this year Intelsat will replace Intelsat 901 with Intelsat 904 (Call Sign S2408) at 29.5° W.L. and
will redeploy Intelsat 901.4 Intelsat is currently drifting Intelsat 904 to 29.5° W.L. and the spacecraft
is expected to arrive at 29.5° W.L. in approximately four months.5 In the permanent modification
Intelsat filed to support the redeployment of Intelsat 904, Intelsat requested that a new U.S. ITU filing
be made at 29.5° W.L. for operations in the 3625-3700 MHz and 5850-5925 MHz bands.6

The temporary operation of Intelsat 901 in the 3625-3700 MHz and 5850-5925 MHz bands will help
provide additional capacity for customers at the nominal 29.5° W.L. location. Accordingly, grant of
this STA extension request is in the public interest.

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

Respectfully submitted,

/s/ Cynthia J. Grady

Cynthia J. Grady
Senior Counsel
Intelsat US LLC


cc: Stephen Duall
    Jay Whaley
    Cindy Spiers

4
 See Satellite Policy Branch Information, Actions Taken, Report No. SAT-01397, File No. SAT-
MOD-20190207-00009 (June 21, 2019) (Public Notice).
5
 See Satellite Policy Branch Information, Actions Taken, Report No. SAT-01385, File No. SAT-
STA-20190318-00016 (April 26, 2019) (Public Notice); Satellite Policy Branch Information, Actions
Taken, Report No. SAT-01394, File No. SAT-STA-20190515-00038 (May 31, 2019) (Public Notice).
6
 See Satellite Policy Branch Information, Space Station Applications Accepted for Filing, Report No.
SAT-01390, File No. SAT-MOD-20190422-00031 (May 17, 2019) (Public Notice).



Document Created: 2019-07-11 13:20:48
Document Modified: 2019-07-11 13:20:48

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