Attachment STA Request

This document pretains to SES-STA-20100514-00594 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2010051400594_817181

May 14, 2010


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

Re:    Request for Special Temporary Authority for Clarksburg, Maryland
       Earth Station, Call Sign: KA275

Dear Ms. Dortch:

Intelsat North America LLC (“Intelsat”) herein requests Special Temporary
Authority (“STA”)1 for 23 days—from May 19, 2010 through June 10, 2010—
to use its Clarksburg, Maryland earth station (call sign KA275) to provide
emergency communications services in the 3700-4200 MHz and 5925-6425
MHz conventional C-band frequencies to the AMC-11 satellite (call sign
S2433) at the nominal 131º W.L. orbital location. The AMC-11 satellite is
licensed to SES Americom, Inc. (doing business as “SES WORLD SKIES”).

This STA request seeks temporary authority to add communications services,
including video and data, as approved services for KA275. The emission
designators for the proposed services are 36M0G7W (digital video and data),
36M0F7D (digital data), and 36M0F8W (analog video and data).

The KA275 earth station is not currently licensed to provide communications
services. Instead, the license specifies telemetry, command and ranging
services, and the emission designators in the license reflect that use. However,
the KA275 earth station already contains the ALSAT designation, authorizing
communications with all U.S.-licensed satellites including AMC-11. The
KA275 earth station also is authorized to use the conventional C-band
frequencies from 3700-4200 MHz and 5925-6425 MHz and has been
coordinated for operations in these frequencies for the portion of the satellite
arc where AMC-11 operates. The KA275 antenna will operate consistent with
the power levels specified in its existing authorization when providing
communications services.

Grant of this STA request will serve the public interest. As the Commission is
aware, the Galaxy 15 satellite (call sign S2387) operated by Intelsat’s sister
company, PanAmSat Licensee Corp. (“PanAmSat”), experienced an anomaly
on April 5, 2010 and is currently drifting East in an uncontrolled manner
1
  Intelsat has filed this STA request, an FCC Form 159 and a $175.00 filing fee
electronically via the International Bureau’s Filing System.


Ms. Marlene H. Dortch
May 14, 2010
Page 2


toward the nominal 131° W.L. orbital location, where AMC-11 operates. The
requested authority will allow PanAmSat and SES WORLD SKIES to mitigate
potential interference and minimize service disruptions. Use of the 19m
antenna in Clarksburg, MD will facilitate the successful transmission of C-
band communications traffic during the period of time that Galaxy 15 drifts
through the nominal 131° W.L. orbital location. Specifically, the KA275 earth
station will uplink communications traffic to AMC-11 as the satellite
maneuvers to the East and then to the West to avoid an in-orbit collision with
Galaxy 15. The FCC has granted flexibility for the AMC-11 satellite to
operate outside its licensed 131° W.L. station-keeping box to maintain a .3 to
.5 degree separation between the two satellites.2 The large size and advanced
tracking capabilities of the KA275 earth station will best ensure uninterrupted
signals during these maneuvers. As a result, grant of the requested STA will
minimize service disruptions for customers.

In addition, grant of this request will not adversely affect other satellite service
providers. Intelsat and SES WORLD SKIES are coordinating the proposed
use of the KA275 earth station for communications services with the AMC-11
satellite. Intelsat or PanAmSat operate the closest C-band satellites to the
nominal 131° W.L. orbital location -- i.e., Galaxy 12 (call sign S2422) at
nominal 133° W.L.3 and Galaxy 13 (call sign S2386) at nominal 127° W.L.
Intelsat does not expect that its proposed provision of communications services
using the KA275 earth station will cause harmful interference to either of its
adjacent satellites and will coordinate internally the proposed operations.




2
 SES Americom, Inc. requested and received STA to drift the AMC-11
satellite 0.5 degrees to the east and west of its assigned orbital location of 131°
W.L.(i.e., between 130.5° W.L. and 131.5° W.L.) for a period of thirty days,
commencing on May 20, 2010. See SES Americom Inc., Application for
Special Temporary Authority to Drift and Operate AMC-11, File No. SAT-
STA-20100430-0086 (filed Apr. 30, 2010) (grant stamped May 12, 2010).
3
 See PanAmSat Licensee Corp. Request for Special Temporary Authority to
Drift and Operate Galaxy 12 (call sign S2422), File No. SAT-STA-20100408-
00070 (filed Apr. 8, 2010) (grant-stamped Apr. 9, 2010); PanAmSat Licensee
Corp. Request for Extension of STA to Drift and Operate Galaxy 12, File No.
SAT-STA-20100430-00089 (filed Apr. 30, 2010) (grant-stamped May 11,
2010).




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Ms. Marlene H. Dortch
May 14, 2010
Page 3


For the reasons set forth herein, Intelsat respectfully requests that the
Commission expeditiously grant this request.

Sincerely,

/s/ Susan H. Crandall

Susan H. Crandall
Assistant General Counsel
Intelsat Corporation



cc:    Kathyrn Medley
       Stephen Duall




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Document Created: 2010-05-14 15:35:51
Document Modified: 2010-05-14 15:35:51

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