Attachment 20111215134803.pdf

20111215134803.pdf

DECISION submitted by IB/FCC

Granted STA

2011-12-14

This document pretains to SES-STA-20111115-01374 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2011111501374_929900

KL92 SES—STA—20111115—01374 1B2011004912 Intelsat License LLC Approved by OMB 3060—0678 O APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY APPLICANT INFORMATIONEnter a description of this application to identify it on the main menu: STA for Earth Station KL92 to Provide LEOP Services for the SES—4 Satellite 1. Applicant Name: Intelsat License LLC Phone Number: 202—944—7848 DBA Name: Fax Number: 202—944—7870 Street: c/o Intelsat Corporation E—Mail: susan.crandall@intelsat.com 3400 International Drive, N.W. City: Washington State: DC Country: USA Zipcode: 20008 —3006 Attention: Susan H Crandall * ~>5 it s j la u: L.3 (4th @az» rodit io S s sEesSTA —AROlWi{ig—o181f 32(4 {c;zc( (

Conditions: Applicant: Intelsat License LLC File Number: SES—STA—20111115—01374 Call Sign: KL92 Intelsat License LLC is granted, under the following conditions, Special Temporary Authority for 30 days, from 12/28/2011through 01/26/2012, to operate as described in SES— STA—20111115—01374. Based on the following conditions: 1. Operations under this authority are on a non—interference basis only. 2. Operations under this authority are on a non—protected basis only. U ditises Bodeg ?H«‘Cen (f‘afl!Sigmg12. GemDare 12‘\3\@?( (mmfliefldmfiex)) To: ol @Q(bp(fi. comena ieomals

November 15, 2011 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12" Street, S.W. Washington, D.C. 20554 INTELSAT. Re: Request for Special Temporary Authority Castle Rock, Colorado Earth Station KL92 Dear Ms. Dortch: Intelsat License LLC ("Intelsat") herein requests a grant of Special Temporary Authority ("STA")‘ for 30 days, from December 28, 2011 through January 26, 2012, to use its Castle Rock, Colorado Ku—band earth station —— call sign KL92 —— to provide launch and early orbit phase ("LEOP") services for the SES—4 satellite that is expected to be launched on December 28, 2011. The LEOP period is expected to last approximately 10 days." The SES—4 LEOP operations will be performed in the following frequency bands: 14499.0 MHz and 14496.0 MHz (uplink) and 11451.0 MHz, 11454.0 MHz, 12500.5 MHz and 12502.0 MHz (downlink). The LEOP operations will be coordinated with all operators of satellites that use the same frequency bands and are in the LEOP path.* All operators of satellites in that path will be provided with an emergency phone number where the licensee can be reached in the event that harmful interference occurs. The 24x7 contact information for the SES—4 LEOP mission is as follows: Ph.: (202) 944—7701 — East Coast Operations Center (primary) (310) 525—5900 — West Coast Operations Center (back—up) Request to speak with Harry Burnham or Kevin Bell. In further support of this request, Intelsat is attaching Exhibits A and B, which contain a waiver request, as well as technical information that demonstrates ‘ Intelsat has filed its STA request, an FCC Form 159, a $180.00 filing fee and this supporting letter electronically via the International Bureau‘s Filing System ("IBFS"). > The permanent orbital location for SES—4 will be 22.0° W.L. The satellite will be in—orbit tested at 26.0° W.L. * Intelsat is seeking authority through January 26, 2012 to accommodate a possible launch delay. * Space Systems Loral, which is managing the SES—4 launch mission, is handling the coordination. Intelsat Corporation 3400 International Drive NW, Washington DC 20008—3006 USA wwew.intelsat.com T +1 202—944—6800 F41 202—944—7898

Ms. Marlene H. Dortch November 15, 2011 Page 2 that the operation of the earth station will be compatible with its electromagnetic environment and will not cause harmful interference into any lawfully operating terrestrial facility. In the extremely unlikely event that harmful interference should occur due to transmissions to or from its earth station, Intelsat will takeall reasonable steps to eliminate the interference. Grant of this STA request will allowIntelsat to help launch the SES—4 satellite to the 22.0° W.L. location. This, in turn, will help provide continuity of service at that location, and thereby promote the public interest. Please direct any questions regarding this STA request to the undersigned at (202) 944—7848. Respectfully submitted, { . . Susar; H. Crandall Assistant General Counsel Intelsat Corporation Co: Paul Blais

2. Contact Name: Susan H. Crandall Phone Number: 202—944—7848 Company: Intelsat Corporation Fax Number: 202—944—7870 Street: 3400 International Drive, N.W. E—Mail: susan.crandall@intelsat.com City: Washington State: DC Country: USA Zipcode: 20008 —3006 Attention: Susan H. Crandall Relationship: Legal Counsel (If your application is related to an application filed with the Commission, enter either the file number or the IB Submission ID of the related application. Please enter only one.) 3. Reference File Number or Submission ID 4a. Is a fee submitted with this application? @) IfYes, complete and attach FCC Form 159. If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114). C3 Governmental Entity ¢3 Noncommercial educational licensee C Other(please explain): 4b. Fee Classification CGX — Fixed Satellite Transmit/Receive Earth Station 5. Type Request {} Use Prior to Grant {}4 Change Station Location @ Other 6. Requested Use Prior Date 7. CityCastle Rock 8. Latitude (dd mm ss.s h) 39 16 38.0 N

9. State CO 10. Longitude (dd mm ss.s h) 104 48 25.0 W 11. Please supply any need attachments. Attachment 1: STA Request Attachment 2: Exhibit A Attachment 3: Exhibit B 12. Description. (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.) Intelsat License LLC herein requests a grant of Special Temporary Authority for 30 days, from December 28, 2011 through January 26, 2012, to use its Castle Rock, Colorado Ku—band earth station, call sign KL92, to provide launch and early orbit phase services for the SES—4 satellite that is expected to be launched on December 28, 2011. 13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is @ Yes «y No subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See 47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes. 14. Name of Person Signing 15. Title of Person Signing Susan H. Crandall Asst. General Counsel, Intelsat Corporation WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).

FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting for this collection of information is estimated to average 2 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. If you have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA@fce.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS. Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not conduct or sponsor this collection, unless it displays a currently valid OMB control number or if we fail to provide you with this notice. This collection has been assigned an OMB control number of 3060—0678. THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC L&AW 104—13, OCTOBER 1, 1995, 44 U.S.C. SECTION 3507.

Exhibit A PETITION FOR WAIVER OF SECTIONS 25.137 AND 25.114 Pursuant to Section 25.137 of the Federal Communications Commission‘s ("Commission" or "FCC") rules, earth station applicants "requesting authority to operate with a non—U.S. licensed space station to serve the United States" must demonstrate that effective competitive opportunities exist and must provide the same technical information required by Section 25.114 for U.S.—licensed space stations.‘ Intelsat License LLC ("Intelsat") herein seeks authority to provide launch and early orbit phase ("LEOP") services —— not commercial services —— to the United States, and thus believes that Section 25.137 does not apply. To the extent the Commission determines, however, that Intelsat‘s request for authority to provide LEOP services on a special temporary basis is a request to serve the United States with a non U.S.—licensed satellite, Intelsat respectfully requests a waiver of Sections 25.137 and 25.114 of the Commission‘s rules." The Commission may grant a waiver for good cause shown." The Commission typically grants a waiver where the particular facts make strict compliance inconsistent with the public interest.* In granting a waiver, the Commission may take into account considerations of hardship, equity, or more effective implementation of overall policy on an individual basis." Waiver is therefore appropriate if special circumstances warrant a deviation from the general rule, and such a deviation will serve the public interest. In this case, good cause exists for a waiver of both Section 25.137 and Section 25.114. With respect to Section 25.114, Intelsat seeks authority only to provide LEOP services for the SES—4 satellite. The information sought by Section 25.114 is not relevant to LEOP services. Moreover, Intelsat does not have — and would not easily be able to obtain —— such information because Intelsat is not the operator of the SES—4 satellite, nor is Intelsat in contractual privity with that operator. Rather, an affiliate of Intelsat has a contract with Space Systems Loral, the manufacturer of the SES—4 satellite, to conduct LEOP services for the satellite. The information that Intelsat is not including is not required to determine potential harmful interference. The Schedule S information for this satellite would pertain to the operation of the SES—4 satellite at its final orbital location. However, the present ! 47 C.F.R. § 25.137 (emphasis added). 2 47 C.F.R. §§ 25.137 and 25.114. 3 47 C.F.R. §1.3. * N.E. Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990) ("Northeast Cellular‘). ° WAIT Radio v. FCC, 418 F.24 1153, 1159 (D.C. Cir. 1969); Northeast Cellular, 897 F.2d at 1166. |

application for LEOP services involves communications prior to the satellite attaining its final location in the geostationary orbit. In other words, during the LEOP mission, the earth station will not be communicating with a satellite located in the geostationary orbit. Rather, it will be transmitting to a satellite traveling on its "transfer orbit" or "LEOP path", which starts immediately following its separation from a launch vehicle, and ends when the satellite reaches its geostationary orbital location. Moreover, as with any STA, Intelsat will perform the LEOP services on a non—interference basis. Because it is not relevant to the service for which Intelsat seeks authorization, and because obtaining the information would be a hardship, Intelsat seeks a waiver of all the information required by Section 25.114. Intelsat has provided in this STA request the required technical information that is relevant to the LEOP services for which Intelsat seeks authorization. Good cause also exists to waive Section 25.137. Section 25.137 is designed to ensure that "U.S.—licensed satellite systems have effective competitive opportunities to provide analogous services" in other countries. Here, there is no service being provided by the satellite; it is simply being placed in its orbital location after separating from the launch vehicle. Thus, the purpose of the information required by Section 25.137 is not implicated here. For example, Section 25.137(d) requires earth station applicants requesting authority to operate with a non—U.S.—licensed space station that is not in orbit and operating to post a bond.° The underlying purpose in having to post a bond—i.e., to prevent warehousing of orbital locations by operators seeking to serve the United States—would not be served by requiring Intelsat to post a bond in order to provide approximately ten days of LEOP services to the SES—4 satellite. It is Intelsat‘s understanding that SES—4 is licensed by Luxembourg, which is a WTO—member country. Moreover, the Commission currently is considering New Skies Satellites B.V.‘s Petition for Declaratory Ruling seeking U.S. market access for the SES— 4 satellite.‘ Thus, the purposes of Section 25.137—to ensure that U.S. satellite operators enjoy "effective competitive opportunities" to serve foreign markets and to prevent warehousing of orbital locations serving the United States—will not be undermined by grant of this waiver request. Finally, Intelsat notes that it expects to operate with the SES—4 satellite using its U.S. earth station for a period of approximately ten days. Requiring Intelsat to obtain copious technical and legal information from an unrelated party, where there is no risk of harmful interference and the operations will cease after approximately ten days, would pose undue hardship without serving underlying policy objectives. Given these particular facts, the waiver sought herein is plainly appropriate. ° See 47 C.F.R. §25.137(d)(4). " See Policy Branch Information; Satellite Space Applications Acceptedfor Filing, Report No. SAT—00791, File No. SAT—PPL—20110620—00112 (July 8, 2011) (Public Notice).

Exhibit B [ SITE NAME (or identifier): Castle Rock, CRK—K01, Call Sign: KL—92 Antenna location LONGITUDE (deg, min, sec— NAD 83) ) 104° 48‘ 22.867" W LATITUDE (deg, min, sec— NAD 83) ) 39° 16‘ 35.215" N ANTENNA HEIGHT IN METERS: GROUND ELEVATION( AMSL) 2096.23 ANTENNA LOCATION: GROUND: Yes ROOF (Meters) BUILDING HEJIGHT (Meters) Antenna Characteristics (size & gain) SIZE 12.5 M TX GAIN 63.68 dBi RX GAIN 39.8 dB/K (@ 20 degrees Elevation) ANTENNA MODEL ANTENNA MANUFACTURER MAXIMUM HPA POWER 92.0 dBwW TOTAL EIRP FOR ALL CARRIERS SATELLITES ARC TO COORDINATE 28 to 181 degrees west SATELLITES DESIRED: UPLINK FREQUENCIES: 14499.0 MHz and 14496.0 MHz RHCP DOWNLINK FREQUENCIES: 11451.0, 11454.0; 12500.5 & 12502.0 MHz RHCP Uplink carrier parameters TYPE OF SERVICE (broadcast data TTC) TTC DATA RATE(S): 250 bps MODULATION: PCM/FM POLARIZATION RHCP FORWARD ERROR CODING RATE: none OCCUPIED BANDWIDTH 850 kHz UPLINK EIRP PER CARRIER One Cxr only Downlink Carrier Parameters TYPE OF SERVICE (broadcast data TTC) TM DATA RATE(S): 4800 POLARIZATION: RHCP MODULATION: PM OCCUPIED BANDWIDTH 288 kHz


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Document Modified: 2019-04-27 22:50:30
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