Attachment STA Request

This document pretains to SAT-STA-20191104-00125 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2019110400125_1995259

November 4, 2019 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Request for Special Temporary Authority to Drift Intelsat 902 to 309.9° E.L. Call Sign: S2406 Dear Ms. Dortch: Intelsat License LLC (“Intelsat”) herein requests a grant of Special Temporary Authority (“STA”)1 for 30 days, commencing November 15, 2019, to drift Intelsat 902 (Call Sign S2406) from 62.0° E.L. to 309.9° E.L. (50.1° W.L). Intelsat will also be filing a 180-day request for STA and an application to modify the Intelsat 902 satellite license in support of this redeployment. The Intelsat 902 satellite is currently operating in inclined orbit at 62.0° E.L.2 Recently, Intelsat 39 (Call Sign S3023) replaced Intelsat 902 at the nominal 62.0° E.L. orbital location and began providing service.3 Subject to receipt of Federal Communications Commission (“FCC” or “Commission”) approval, Intelsat 902 will be relocated to 309.9° E.L. The drift of Intelsat 902 is expected to begin November 15, 2019 and will take approximately five months. During the drift of Intelsat 902, Intelsat will 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: 6173.7 MHz and 6176.3 MHz in 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 Policy Branch Information, Actions Taken, Report No. SAT-01199, File No. SAT-MOD- 20160816-00084 (Nov. 4, 2016) (Public Notice); see Letter from Cynthia J. Grady, Senior Counsel, Intelsat US LLC, to Marlene H. Dortch, Secretary, Federal Communications Commission, File No. SAT-MOD-20160816-00084 (Oct. 23, 2019). 3 See Application of Intelsat License LLC to Modify Authorization for Intelsat 39, File No. SAT- MOD-20191024-00119 at 2 (filed Oct. 24, 2019).

Ms. Marlene H. Dortch November 4, 2019 Page 2 uplink; and 3947.5 MHz, 3948.0 MHz, 3952.0 MHz, and 3952.5 MHz in the downlink. Grant of this STA request will not result in increased risk of harmful interference. As noted above, Intelsat will operate only the above listed TT&C frequencies during the 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 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 Intelsat 902 at 309.9° E.L.4 Finally, Intelsat is not aware of any system with an overlapping station-keeping volume with Intelsat 902 that is the subject of an International Telecommunication Union filing and that is either in orbit or progressing towards launch. Grant of this STA request is in the public interest because it will allow Intelsat to add capacity at the nominal 310° E.L. orbital location after the loss of Intelsat 29e. 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 Senior Counsel Intelsat US LLC cc: Stephen Duall Jay Whaley Jennifer Balatan 4 Intelsat 902 will be nominally collocated with Intelsat 9, which will operate at 310.0° E.L. (50.0° W.L.). See Intelsat License LLC’s Request for Extension of Special Temporary Authority to Drift Intelsat 9 to 50.0° W.L., File No. SAT-STA-20190912-00092 (filed Oct. 25, 2019).


Document Created: 2019-11-04 14:10:09
Document Modified: 2019-11-04 14:10:09
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