Attachment Exhibits A-C

This document pretains to SES-STA-20130610-00483 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2013061000483_999828

EXHIBIT A INTELSAT LICENSE LLC 30-DAY STA REQUEST FOR ASTRA-2E LEOP SERVICES EARTH STATION KA258 HAGERSTOWN, MARYLAND June 10, 2013

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.1 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.2 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.3 The Commission may grant a waiver for good cause shown.4 The Commission typically grants a waiver where the particular facts make strict compliance inconsistent with the public interest.5 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.6 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 Astra-2E 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 Astra-2E satellite, nor is Intelsat in contractual privity with that operator. Rather, an affiliate of Intelsat has a contract with EADS Astrium, the manufacturer of the Astra-2E satellite, to conduct LEOP services for the satellite. 1 47 C.F.R. § 25.137 (emphasis added). 2 See EchoStar Satellite Operating Company Application for Special Temporary Authority Related to Moving the EchoStar 6 Satellite from the 77° W.L. Orbital Location to the 96.2º W.L. Orbital Location, and to Operate at the 96.2° W.L. Orbital Location, DA 13-593, File No. SAT-STA-20130220-00023 (released Apr. 1, 2013) (noting that operating TT&C earth stations in the United States with a foreign-licensed satellite does not constitute “DBS service”). 3 47 C.F.R. §§ 25.137 and 25.114. 4 47 C.F.R. §1.3. 5 N.E. Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990) (“Northeast Cellular”). 6 WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969); Northeast Cellular, 897 F.2d at 1166.

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 Astra-2E satellite at its final orbital location. However, the present 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.7 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 Astra-2E satellite. It is Intelsat’s understanding that Astra-2E is licensed by Luxembourg, which is a WTO-member country. 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 Astra-2E 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. 7 See 47 C.F.R. §25.137(d)(4).

EXHIBIT B INTELSAT LICENSE LLC 30-DAY STA REQUEST FOR ASTRA-2E LEOP SERVICES EARTH STATION KA258 HAGERSTOWN, MARYLAND June 10, 2013

Exhibit B Request for Waiver of Footnote 2 of Section 25.202(a)(1) and Footnote NG104 of the U.S. Table of Allocations To the extent necessary, Intelsat also requests waiver of Section 25.202(a)(1) and Footnote NG104 of the U.S. Table of Allocations, which restrict the use of the 10700-11700 MHz band by the non-federal fixed satellite service in the geostationary orbit to international systems only.1 Good cause exists to waive the international systems only requirement for the 10700-11700 MHz frequency band. The purpose of NG104 and footnote 2 of Section 25.202(a)(1) is to limit the number of fixed satellite service earth stations with which the co- primary fixed service would need to coordinate.2 Intelsat will provide LEOP services in the 10700-11700 MHz frequency band only on a non-interference/non-protected basis and, therefore, will not need to coordinate with fixed service stations. Moreover, grant of this waiver is consistent with the Commission’s precedent. A waiver of the U.S. Table of Allocations is generally granted “when there is little potential interference into any service authorized under the Table of Frequency allocations and when the nonconforming operator accepts any interference from authorized services.”3 The International 1 See 47 C.F.R. §§ 25.202(a)(1), fn. 2 and 2.106, fn. NG104. 2 See Satellite Services, 26 RR 2d at 1263-65 (1973). See also EchoStar KuX Corporation Application for Authority to Construct, Launch and Operate a Geostationary Satellite Using the Extended Ku-band Frequencies in the Fixed-Satellite Service at the 83º W.L. Orbital Location, Order and Authorization, DA 04-3162, 9 (Int’l Bur., Sept. 30, 2004) (“EchoStar 83º Waiver”). 3 See The Boeing Company, Order and Authorization, 16 FCC Rcd 22645, 22651 (Int’l Bur. & OET 2001); Application of Fugro-Chance, Inc. for Blanket Authority to Construct and Operate a Private Network of Receive-Only Mobile Earth Stations, Order and Authorization, 10 FCC Rcd 2860 (Int’l Bur. 1995) (authorizing MSS in the C-band); see also Application of Motorola Satellite Communications, Inc. for Modification of License, Order and Authorization, 11 FCC Rcd 13952-13956 (Int’l Bur. 1996) (authorizing service to fixed terminals in bands allocated the mobile satellite service).

Bureau has found that waiving NG104 and footnote 2 of Section 25.202(a)(1) would not undermine the purpose of the rules if the party seeking a waiver: (1) will be utilizing earth stations that are receive-only in these bands and thus “not capable of causing interference into FS stations” operating in the bands and (2) agrees “to accept any level of interference from FS stations” into its receiving earth stations.4 Intelsat satisfies these criteria. The earth stations operating in the 10700-11700 MHz band for purposes of the Astra-2E LEOP mission will not transmit in these bands and Intelsat agrees to accept any level of interference into these earth stations from fixed service stations in the band. Accordingly, the earth stations operating in these bands pose no interference concerns with respect to co-frequency fixed service stations. Finally, Intelsat notes that it expects to operate with the Astra-2E satellite using its U.S. earth stations only for a period of approximately ten days. Given these particular facts, the waiver sought herein is plainly appropriate. 4 EchoStar 83° Waiver, ¶ 13.

EXHIBIT C INTELSAT LICENSE LLC 30-DAY STA REQUEST FOR ASTRA-2E LEOP SERVICES EARTH STATION KA258 HAGERSTOWN, MARYLAND June 10, 2013

Exhibit C Prepared By COMSEARCH 19700 Janelia Farm Boulevard, Ashburn, VA 20147 (703)726-5500 http://www.comsearch.com Prepared For Intelsat License LLC Hagerstown, Maryland Temporary Transmit/Receive Earth Station Operation Dates: 06/20/2013 – 09/20/2013 Pursuant to Part 25.203(c) of the FCC Rules and Regulations, the satellite earth station proposed in this application was coordinated by Comsearch using computer techniques and in accordance with Part 25 of the FCC Rules and Regulations. Verbal and written coordination was conducted with the below listed carriers on May 14, 2012. Company ACC License, LLC ADAMS COUNTY EMERGENCY MANAGEMENT AGENCY ALLEGANY COUNTY GOVERNMENT APC Realty and Equipment CO LLC ART Licensing Corp. Airband Communications Inc Arlington County Emergency Comm Ctr B.F. SAUL COMPANY BUSINESS INFORMATION GROUP, INC. Believe Wireless, LLC Blaze Broadband Blue Ridge Carriers Boeing Company CAMP HILL SCHOOL DISTRICT CBS Broadcasting Inc CBS Communications Services Inc. CECIL COUNTY PUBLIC SCHOOLS CNG Transmission Corporation CRISPUS ATTUCKS ASSOCIATION Cable Of The Carolinas Calvert County Government Cambria, County of Cape May County Municipal Utilities Auth Cape May County, MIS Department Carlisle Area School District City of Altoona Clearwire Spectrum Holdings III, LLC Commissioners of Caroline County Conterra Ultra Broadband, LLC Cumberland County, New Jersey Cumberland Valley School District Frequency Coordination and Interference Analysis Report 05/28/2013 Page 1 of 7

Company (Continued) DELAWARE RIVER & BAY AUTHORITY DOVER AREA SCHOOL DISTRICT Delmarva Power & Light Company ECW Wireless, LLC East Pennsboro Area School Eastern Lancaster County School District Eduro Networks LLC Enoch Pratt Free Library Federal Communications Commission Franklin County Dept. of Emergency Servi GETWIRELESS.NET George Washington University Glenville State University HALIFAX AREA SCHOOL DISTRICT Harrison County Emergency Services High Voltage Communications LLC Hope Gas, Inc. LANCASTER GENERAL HOSPITAL Last Mile Inc. Loudoun Wireless LLC Loudoun, County of MLS ENGINEERING MVC Research. LLC Maryland Port Administration Maryland, State Of - MDOT - MTA MetroPCS AWS, LLC NBC TELEMUNDO LICENSE LLC NEXSTAR BROADCASTING, INC. National Radio Astronomy Observatory National Tower Company Netrepid, Inc. New Cingular Wireless PCS LLC - AZ New Cingular Wireless PCS LLC - DC New Cingular Wireless PCS LLC- WV/NC/SC New Cingular Wireless PCS, LLC - PA Newgig Networks, LLC Northern York County School District PENNSYLVANIA TURNPIKE COMMISSION Prince William, County of Radio One, Inc RapidDSL & Wireless, Inc. Red Rose Transit Authority Red Zebra Broadcasting Licensee, LLC Roadstar Internet, Inc. SHIPPENSBURG AREA SCHOOL DISTRICT SOMERSET COUNTY SUSQUEHANNA TOWNSHIP SCHOOL DISTRICT Shenandoah Personal Communications, LLC Sprint Spectrum, LP State of WV DHHR/BPH STECS Steelton-Highspire School District Frequency Coordination and Interference Analysis Report 05/28/2013 Page 2 of 7

Company (Continued) THE HERSHEY COMPANY Telecom Transport Management, Inc WASHINGTON CABLE SYSTEMS INC WKYSFM, INC Washington Metro Area Transit Police Dep West Virginia PCS Alliance, L.C. Western PA Internet Access, Inc. Windstream D&E Systems, Inc. Wireless Internetwork LLC World Class Wireless LLC York County Dept of Emergency Services York Water Co There are no unresolved interference objections with the stations contained in these applications. The following section presents the data pertinent to frequency coordination of the proposed earth station that was circulated to all carriers within its coordination contours. Frequency Coordination and Interference Analysis Report 05/28/2013 Page 3 of 7

COMSEARCH Earth Station Data Sheet 19700 Janelia Farm Boulevard, Ashburn, VA 20147 (703)726-5500 http://www.comsearch.com Date: 05/28/2013 Job Number: 130514COMSJC03 Administrative Information Status TEMPORARY (Operation from 06/20/2013 to 09/20/2013) Call Sign TEMP09 Licensee Code INTELS Licensee Name Intelsat License LLC Site Information HAGERSTOWN, MARYLAND Venue Name Latitude (NAD 83) 39° 35' 54.0" N Longitude (NAD 83) 77° 45' 33.0" W Climate Zone A Rain Zone 2 Ground Elevation (AMSL) 174.65 m / 573.0 ft Link Information Satellite Type Geostationary Mode TO - Transmit-Only Modulation Digital Satellite Arc 6° W to 149° West Longitude Azimuth Range 101.9° to 257.8° Corresponding Elevation Angles 5.3° / 5.7° Antenna Centerline (AGL) 9.45 m / 31.0 ft Antenna Information Transmit Manufacturer TIW Model 14.2 Meter Gain / Diameter 65.1 dBi / 14.2 m 3-dB / 15-dB Beamwidth 0.10° / 0.20° 816KFXD & 850KFXD Max Available RF Power (dBW/4 kHz) -0.2 -0.4 (dBW/MHz) 23.8 23.6 Maximum EIRP (dBW/4 kHz) 64.9 64.7 (dBW/MHz) 88.9 77.7 (dBW) 88.0 88.0 Interference Objectives: Long Term -154.0 dBW/4 kHz 20% Short Term -131.0 dBW/4 kHz 0.0025% Frequency Information Transmit 18.0 GHz Emission / Frequency Range (MHz) 816KFXD / 17301.0 816KFXD / 17302.5 850KFXD / 17309.5 850KFXD / 18090.0 Max Great Circle Coordination Distance 446.5 km / 277.4 mi Precipitation Scatter Contour Radius 0.0 km / 0.0 mi Frequency Coordination and Interference Analysis Report 05/28/2013 Page 4 of 7

COMSEARCH Earth Station Data Sheet 19700 Janelia Farm Boulevard, Ashburn, VA 20147 (703)726-5500 http://www.comsearch.com Coordination Values HAGERSTOWN, MD Licensee Name Intelsat License LLC Latitude (NAD 83) 39° 35' 54.0" N Longitude (NAD 83) 77° 45' 33.0" W Ground Elevation (AMSL) 174.65 m / 573.0 ft Antenna Centerline (AGL) 9.45 m / 31.0 ft Antenna Model TIW 14.2 Meter Antenna Mode Transmit 18.0 GHz Interference Objectives: Long Term -154.0 dBW/4 kHz 20% Short Term -131.0 dBW/4 kHz 0.0025% Max Available RF Power -0.2 (dBW/4 kHz) Transmit 18.0 GHz Horizon Antenna Horizon Coordination Azimuth (°) Elevation (°) Discrimination (°) Gain (dBi) Distance (km) 0 0.00 101.81 -10.00 153.39 5 0.00 96.84 -10.00 153.39 10 0.00 91.86 -10.00 153.39 15 0.00 86.88 -10.00 153.39 20 0.00 81.90 -10.00 153.39 25 0.00 76.92 -10.00 153.39 30 0.00 71.95 -10.00 153.39 35 0.00 66.97 -10.00 153.39 40 0.00 62.00 -10.00 153.39 45 0.00 57.03 -10.00 153.39 50 0.00 52.06 -10.00 153.39 55 0.00 47.09 -9.82 153.96 60 0.00 42.14 -8.62 158.39 65 0.00 37.19 -7.26 162.91 70 0.00 32.26 -5.72 168.15 75 0.00 27.34 -3.92 174.35 80 0.00 22.47 -1.79 181.89 85 0.00 17.65 0.83 191.39 90 0.00 12.98 4.17 203.75 95 0.00 8.66 8.56 221.33 100 0.00 5.61 13.27 446.50 105 0.00 6.15 12.28 303.98 110 0.00 9.60 7.45 216.77 115 0.00 13.27 3.93 202.81 120 0.00 16.89 1.31 192.91 125 0.00 20.41 -0.75 185.64 130 0.00 23.83 -2.43 179.61 135 0.00 27.11 -3.83 174.68 140 0.00 30.23 -5.01 170.57 145 0.00 33.14 -6.01 167.15 150 0.00 35.82 -6.85 164.29 155 0.00 38.20 -7.55 161.93 160 0.00 40.26 -8.12 160.03 165 0.00 41.93 -8.56 158.57 170 0.00 43.16 -8.88 157.03 175 0.00 43.92 -9.07 156.41 180 0.00 44.18 -9.13 156.21 185 0.00 43.92 -9.07 156.41 Frequency Coordination and Interference Analysis Report 05/28/2013 Page 5 of 7

COMSEARCH Earth Station Data Sheet 19700 Janelia Farm Boulevard, Ashburn, VA 20147 (703)726-5500 http://www.comsearch.com Coordination Values HAGERSTOWN, MD Licensee Name Intelsat License LLC Latitude (NAD 83) 39° 35' 54.0" N Longitude (NAD 83) 77° 45' 33.0" W Ground Elevation (AMSL) 174.65 m / 573.0 ft Antenna Centerline (AGL) 9.45 m / 31.0 ft Antenna Model TIW 14.2 Meter Antenna Mode Transmit 18.0 GHz Interference Objectives: Long Term -154.0 dBW/4 kHz 20% Short Term -131.0 dBW/4 kHz 0.0025% Max Available RF Power -0.2 (dBW/4 kHz) Transmit 18.0 GHz Horizon Antenna Horizon Coordination Azimuth (°) Elevation (°) Discrimination (°) Gain (dBi) Distance (km) 190 0.00 43.16 -8.88 157.03 195 0.00 41.93 -8.56 158.57 200 0.00 40.26 -8.12 160.04 205 0.00 38.20 -7.55 161.93 210 0.00 35.81 -6.85 164.29 215 0.00 33.14 -6.01 167.15 220 0.00 30.22 -5.01 170.58 225 0.00 27.11 -3.83 174.67 230 0.00 23.83 -2.43 179.61 235 0.00 20.42 -0.75 185.63 240 0.00 16.89 1.31 192.93 245 0.00 13.28 3.92 202.80 250 0.00 9.59 7.46 216.82 255 0.00 6.33 11.96 314.25 260 0.00 6.11 12.35 428.23 265 0.00 9.18 7.93 218.73 270 0.00 13.46 3.77 202.23 275 0.00 18.11 0.55 190.38 280 0.00 22.90 -2.00 181.15 285 0.00 27.76 -4.09 173.78 290 0.00 32.66 -5.85 167.68 295 0.00 37.59 -7.38 162.52 300 0.00 42.53 -8.72 158.06 305 0.00 47.48 -9.91 153.67 310 0.00 52.44 -10.00 153.39 315 0.00 57.40 -10.00 153.39 320 0.00 62.37 -10.00 153.39 325 0.00 67.34 -10.00 153.39 330 0.00 72.31 -10.00 153.39 335 0.00 77.28 -10.00 153.39 340 0.00 82.26 -10.00 153.39 345 0.00 87.23 -10.00 153.39 350 0.00 92.21 -10.00 153.39 355 0.00 97.18 -10.00 153.39 Frequency Coordination and Interference Analysis Report 05/28/2013 Page 6 of 7

Certification I hereby certify that I am the technically qualified person responsible for the preparation of the frequency coordination data contained in this report. I am familiar with Parts 101 and 25 of the FCC Rules and Regulations and I have either prepared or reviewed the frequency coordination data submitted with this report, and that it is complete and correct to the best of my knowledge and belief. Jeffrey E. Cowles Engineer III, Telecommunications COMSEARCH 19700 Janelia Farm Blvd. Ashburn, Virginia 20147 DATED: May 28, 2013 Frequency Coordination and Interference Analysis Report 05/28/2013 Page 7 of 7


Document Created: 2013-06-10 17:21:41
Document Modified: 2013-06-10 17:21:41
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