Attachment STA Request

This document pretains to SAT-STA-20190717-00064 for Special Temporal Authority on a Satellite Space Stations filing.


July 17, 2019


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


         Re:     Request for Further Extension of Special Temporary Authority to Drift Intelsat 904 to
                 29.5° W.L., Call Sign: S2408

Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”) herein requests an additional 60 days of Special Temporary
Authority (“STA”)1 previously granted Intelsat to drift Intelsat 904 (Call Sign S2408) from 45.1° E.L.
to 29.5° W.L.2 Intelsat is relocating Intelsat 904 after the successful launch and arrival of Intelsat 38
at 45.0° E.L.3 and has a pending application to modify Intelsat 904’s license for this redeployment.4
The drift of Intelsat 904 is expected to take approximately six months.

During the drift of Intelsat 904 Intelsat will continue to only utilize the satellite’s telemetry, tracking,
and control (“TT&C”) frequencies and will follow industry practices for coordinating TT&C
transmission during the relocation process. The TT&C frequencies are as follows: 3947.5 MHz,
3948.0 MHz, 3952.0 MHz, and 3952.5 MHz (downlink); 6173.7 MHz and 6176.3 MHz (uplink).

Grant of this STA further extension request will not result in increased risk of harmful interference.
As noted above, Intelsat will continue to operate only the above listed TT&C frequencies during the

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, e.g., Satellite Policy Branch Information, Actions Taken, Report No. SAT-01394, File No. SAT-
STA-20190515-00038 (May 31, 2019) (Public Notice).
3
    Intelsat 38 is a Ku-band satellite authorized by Azerbaijan and is also known as Azerspace-2.
4
 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).


Ms. Marlene H. Dortch
July 17, 2019
Page 2




drift and will coordinate its TT&C transmissions with operators of satellites in the drift path. Should
any interference occur during the drift, Intelsat will take all reasonable steps to eliminate such
interference.

Further, Intelsat has assessed and limited the probability of the space station becoming a source of
debris as a result of collision with large debris or other operational space stations. Intelsat 904 will be
temporarily collocated with Intelsat 901, before the planned relocation of Intelsat 901 in Q3 2019.
Intelsat is not aware of any other Federal Communications Commission (“FCC” or “Commission”)
licensed system, or any other system applied for and under consideration by the FCC, having an
overlapping station-keeping volume with Intelsat 904 at 29.5° W.L. Finally, Intelsat is not aware of
any system with an overlapping station-keeping volume with Intelsat 904 that is the subject of an ITU
filing and that is either in orbit or progressing towards launch.

Grant of this STA further extension request is in the public interest because it will allow Intelsat to
continue with redeploying Intelsat 904 following the launch of, and transfer of traffic to, Intelsat 38,
thereby maximizing the use of on-orbit resources.

For the reasons set forth herein, Intelsat respectfully requests that the Commission grant this STA
further extension request. Please direct any questions regarding this supplement 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: 2019-07-17 16:57:38
Document Modified: 2019-07-17 16:57:38

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