Attachment SESSTA2014021200067.

SESSTA2014021200067.

DECISION submitted by FCC

STA GRANT WITH CONDITIONS

0000-00-00

This document pretains to SES-STA-20140212-00067 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2014021200067_1040146

KL92 SES—STA—20140212—00067 1B2014000260 Intelsat License LLC Approved by OMB 3060—0678 APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY APPLICANT INFORMATIONEnter a description of this application to identify it on the main menu: Request for Special Temporary Authority Using Castle Rock, Colorado Earth Station KL92 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 | >A | Cali Sign g\%&__ Gras:iDa%é &g‘\s:. liav Hantific r other igentirior | | 1\ Teaem | Prom J tias 9 nternational Bureau bo..«commsmessemmesmenenmememmmememimen, \ ) Approvers

ris S<SSftecn 63h—COOG—L. | Calt Swngg , Grant D:fiz;s_‘_:x_\‘\' er identifier) Applicant: Intelsat License LLC Call Sign: KL92 File No.: SES—STA—20140212—00067 Special Temporary Authority (STA) / Intelsat License LLC (Intelsat) is granted STA, under the following conditions, to use its Castle Rock, Colorado earth station, call sign KL92, for 30 days, to provide launch and early orbit phase (LEOP) services for the Brazil licensed satellite Amazonas—4A at permanent orbital location at 61.0° W.L. The in—orbit testing location will be at 51.0° W.L. The Amazonas—4A satellite is expected to be launched on March 13, 2014. The following conditions are: 1. Amazonas—4A at LEOP operations will be performed on uplink frequencies (Earth— to—space) 14001.00 MHz and 14498.0 MHz (LHCP) and downlink frequencies (space—to—Earth) 12202.0 MHz and 12698.0 MHz ( RHCP). 2. The maximum uplink EIRP transmitted during the LEOP operations will be 25.5 dBW. 3. The LEOP operations must 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. Currently the 24x7 contact information for the Amazonas—4A at LEOP operations 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. 4. All operations shall be on an unprotected and non—harmful interference basis, i. e., Intelsat shall not cause harmful interference to, and shall not claim protection from interference caused to it by, any other lawfully operating radiocommunication station and it shall cease transmission(s) immediately upon notice of such interference. 5. This grant does not constitute grant of U.S. market access to Amazonas—4A at any location. 6. Grant of this authorization is without prejudice to any determination that the Commission may make regarding any future pending applications. 7. Any action taken or expense incurred as a result of operations pursuant to this STA is solely at Intelsat‘s own risk. 8. This action is issued pursuant to Section 0.261 of the Commission‘s rules on delegated authority, 47 C.F.R. § 0.261, and is effective immediately.

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 Commussion, 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.E.R.Section 1.1114). {) Governmental Entity C Noncommercial educational licensee {} Other(please explain): 4b. Fee Classification CGX — Fixed Satellite Transmit/Receive Earth Station 5. Type Request Use Prior to Grant Change Station Location Other CC3 3 8 @ 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: 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 Licensgse LLC herein requests a grant of Special Temporary Authority for 30 days, commencing March 13, 2014, to use its Castle Rock, Colorado Ku—band earth station, call sign KL92, to provide launch and early orbit phase services for the Amazonas—4A satellite that is now expected to be launched on March 13, 2014. 13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is Yes £4 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 &quot;party to the application&quot; for these purposes. 14. Name of Person Signing 15. Title of Person Signing Susan H. Crandall Assoc. 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 numberor 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 LAW 104—13, OCTOBER 1, 1995, 44 U.S.C. SECTION 3507.

olfi February 12, 2014 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12"" Street, S.W. Washington, D.C. 20554 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, commencing March 13, 2014, to use its Castle Rock, Colorado Ku—band earth station —— call sign KL92 —— to provide launch and early orbit phase ("LEOP") services for the Amazonas—4A satellite that is now expected to be launched on March 13, 2014." The LEOP period is expected to last approximately ten days." The Amazonas—4A satellite was initially expected to launch on December 6, 2013. The Commission previously granted STA to Intelsat for Amazonas— 4A LEOP operations, which initial grant expired on January 5, 2014.* The Amazonas—4A LEOP operations will be performed in the following frequency bands: 14001.0 MHz and 14498.0 MHz in the uplink (LHCP), and 12202.0 MHz and 12698.0 MHz in the downlink (RHCP). 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 Amazonas—4A LEOP mission is as follows: ‘ 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 Amazonas—4A, which Intelsat understands is licensed by the Brazil, will be 61.0° W.L. The in—orbit testing location will be 51.0° W.L. * Intelsat is seeking authority for 30 days to accommodate possible further launch delays. * See Satellite Communications Services Information; Actions Taken, Report No. SES—01605, File No. SES—STA—20131108—00960 (Dec. 12, 2013) (Public Notice). Intelsat Corporation 3400 International Drive NW, Washington DC 20008—3006 USA www.intelsat.com T +1 202—944—6800 F+1 202—944—7898

Ms. Marlene H. Dortch February 12, 2014 Page 2 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 addition, Intelsat attaches Exhibit A, which contains waiver requests. In the extremely unlikely event that harmful interference should occur due to transmissions to or fromits earth station, Intelsat will take all reasonable steps to eliminate the interference. Intelsat also notes that for purposes of the Amazonas—4A LEOP mission, it is seeking to operate in the frequencies listed in the request at power levels not to exceed 25.5 dBW. Finally, Intelsat clarifies that during the Amazonas—4A launch, the spacecraft will be controlled by Orbital Sciences, which is the manager of the LEOP mission. Orbital Sciences will build and send the commands to the Intelsat antenna, which will process and execute the commands. Telemetry received by Intelsat will be forwarded to Orbital Sciences. Intelsat will remain in control of the baseband unit, RF equipment and antenna. Grant ofthis STA request will allow Intelsat to help launch the Amazonas— 4A satellite. This, in turn, will help ensure continuity of service at the 61.0° W.L. orbital location and thereby promotes the public interest. Please direct any questions regarding this STA request to the undersigned at (202) 944—7848. Respectfully submitted, C)xA CE_ Susan H. Crandall Associate General Counsel Intelsat Corporation ce: Paul Blais

Exhibit A 1. 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 Amazonas—4A 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 Amazonas— 4A satellite, nor is Intelsat in contractual privity with that operator. Rather, an affiliate of Intelsat has a contract with Orbital Sciences, the manufacturer of the Amazonas—4A satellite, to conduct LEOP services for the satellite. ! 47 C.F.R. § 25.137 (emphasis added). * 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 96.2° 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"). 347 C.F.R. §§ 25.137 and 25.114. *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.

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 Amazonas—4A 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.‘ 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 Amazonas—4A satellite. It is Intelsat‘s understanding that Amazonas—4A is licensed by Brazil, 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 Amazonas—4A 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).

II. REQUEST FOR WAIVER OF THE U. S. TABLE OF FREQUENCY ALLOCATIONS In the U.S. Table of Frequency Allocations, the 12200—12700 MHz band is allocated to Fixed, Mobile (except aeronautical mobile), Broadcasting, and Broadcasting— Satellite, each on a co—primary basis." Intelsat seeks a waiver of the U.S. Table of Frequency Allocations to allow temporary use of the uplink frequencies 12202 and 12698 MHz for Fixed—Satellite Service ("FSS") in Region 2. 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 cireumstances warrant a deviation from the general rule, and such a deviation will serve the public interest. Good cause exists for a waiver to allow Intelsat to conduct LEOP operations for the Amazonas—4A satellite using the 12202 and 12698 MHz frequencies. The TT&C frequencies on the satellite cannot be changed. As such, during the short period that the Amazonas—4A satellite passes over the United States during the LEOP mission, Intelsat must temporarily utilize these frequencies to command the spacecraft. Intelsat‘s temporary use of the 12202 and 12698 MHz frequencies will not unduly harm incumbent operations. Intelsat plans to use these frequencies solely for the Amazonas—4A LEOP operations, which it expects to last approximately ten days. Furthermore, the Amazonas—4A satellite will make a rapid ascent and will transition across the United States arc very quickly. Therefore, Intelsat believes that any interference it may cause to incumbent operations during the LEOP mission —— to the extent there is any —— will be very short term. For these reasons —— and to ensure a safe LEOP mission for the Amazonas—4A satellite —— the Commission should grant the waiver sought herein. 847 C.F.R. § 2.106. ? 47 C.E.R. §1.3. " NE. Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990) ("‘Northeast Cellular®). ‘ WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969); Northeast Cellular, 897 F.2d at 1166.


Document Created: 2014-03-26 17:19:38
Document Modified: 2014-03-26 17:19:38
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