Attachment SESSTA2014103000831.

SESSTA2014103000831.

DECISION submitted by FCC

STA GRANT WITH CONDITIONS

0000-00-00

This document pretains to SES-STA-20141030-00831 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2014103000831_1071453

                                          1B2014002164
 KL92          SES—STA—20141030—00831
 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:              703—559—7848
            DBA Name:                                    Fax Number:                703—559—8539
            Street:         c/o Intelsat Corporation     E—Mail::>                  susan.crandall@intelsat.com
                            7900 Tysons One Place
            City:           McLean                       State:                     VA
            Country:         USA                         Zipcode:                   22102        —35972
            Attention:      Susan H. Crandall




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Applicant: Intelsat License LLC
Call Sign: KL92
File No.:   SES—STA—20141030—00831
Special Temporary Authority (STA)


Intelsat License LLC ("Intelsat") is granted STA for 30 days for earth station KL92 at Castle
Rock, Colorado at 39° 16‘ 38.0" NL/104° 48° 25"W.L. (NAD—83) to operate with telemetry,
tracking, and control frequencies with Intelsat 30 satellite (Call Sign $2887) at orbital location
95.05° W.L. under the following conditions:

     15 Uplink (Earth—to—space) frequencies for command functions on 13750.50 MHz and
        14003.50 MHz (RHCP) within the operating parameters of its pending application IBFS
        File No. SES—MOD—20141030—00834 that are subject to coordinated emission and
        power limits.

        Downlink (space—to—Earth) frequencies for telemetry functions on 11198.00 MHz,
        11198.50 MHz, 11199.25 MHz, and 11199.75 MHz (RHCP) within the operating
        parameters of its pending application IBFS File No. SES—MOD—20141030—00834.

        Grant of this STA is without prejudice to any determination that the Commission may
        make regarding its pending application IBFS File No. SES—MOD—20141030—00834 and
        without prejudice to any future Commission‘s action.

        All operations under this grant of STA shall be on an unprotected and non—harmful
        interference basis. Intelsat‘s KL92 shall not cause harmful interference to, and shall not
        claim protection from interference caused to it by, any other lawfully operating radio
        communication system.

        In the event of any harmful interference as a result of operations under this grant of
        STA, Intelsat shall cease operations immediately upon notification of such interference
        and shall immediately inform the Commission, in writing, of such an event.

        Any action taken or expense incurred as a result of operations pursuant to this STA is
        solely at Intelsat License LLC‘s risk.

        This grant is issued pursuant to Section 0.261 of the Commission‘s rules on delegated
        authority, 47 C.F.R. § 0.261, and is effective upon release.


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                                     pometiromminmmniitians_.


2. Contact


             Name:         Susan H. Crandall                   Phone Number:                              703—559—7848
             Company:      Intelsat Corporation                Fax Number:                                703—559—3957
             Street:       7900 Tysons One Place               E—Mail:                                    susan.crandall@intelsat.com


             City:         McLean                              State:                                     VA
             Country:      USA                                 Zipcode:                                   22102       —5972.
             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.E.R.Section 1.1114).
g4 Governmental Entity       @3 Noncommercial educational licensee
gry Other(please explain}:

4b. Fee Classification    CGX — Fixed Satellite Transmit/Receive Earth Station

5. Type Request


£y Use Prior to Grant                              3 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                             j
                                                                           (dd mm ss.s h)     104   48   25.0    W
11. Please supply any need attachments.
Attachment 1: STA Request                         Attachment 2:                                      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 License LLC herein requests a grant of Special Temporary Authority for 30 days,
     from November 20,          2014 through December 19,                2014,    to utilize its Castle Rock,                   Colorado
     antenna,      KL92,   to operate in new Tracking,                 Telemetry, and Control frequencies with the
     Intelsat 30 satellite               (Call Sign $2887)         at 95.05 W.L.




13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is                 Yes      «3 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
   Cynthia J. Grady                                                           Regulatory 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).


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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.


                                                                                      INTELSAT
                                                                                        Envision. Connect. Transform.



October 30, 2014



Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12"" Street, S.W.
Washington, D.C. 20554


Re:        Request for Special Temporary Authority to Utilize Castle Rock, Colorado Antenna, KL92, to
           Perform Tracking, Telemetry, and Control for Intelsat 30 Satellite
           EXPEDITED TREATMENT REQUESTED

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests a grant of Special Temporary Authority ("STA")‘ for
30 days, from November 20, 2014 through December 19, 2014, to utilize its Castle Rock, Colorado
antenna, KLO92, to operate in new Tracking, Telemetry, and Control ("TT&C") frequencies with the
Intelsat 30 satellite (Call Sign $2887)° at 95.05° W.L. The proposed operations will be performed using
the following frequencies: 13750.50 MHz and 14003.50 MHz in the uplink (RHCP), and 11198.00
MHz, 11198.50 MHz, 11199.25 MHz, and 11199.75 MHz in the downlink (RHCP). Intelsat will be
filing an application for authority to use this antenna to transmit in these frequencies on a permanent
basis:

In support of its request, Intelsat incorporates by reference its pending application for authority to use
this antenna to transmit in these frequencies on a permanent basis." The application contains detailed
technical information (in Exhibits A, C and D) that demonstrates 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 take all reasonable steps to
eliminate the interference.

To the extent necessary, Intelsat also requests a waiver of the footnote NGS2 to the U.S. Table of
Frequency Allocations, which limits the use of the 10700—11700 MHz frequency band to "international


‘ Intelsat has filed this STA request, an FCC Form 159, and $195.00 filing fee electronically via the International
Bureau‘s Filing System.

2 See Policy Branch Information; Acfions Taken, Report No. SAT—01036, File Nos. SAT—LOA—20121025—00187
and SAT—AMD—20121221—00220 (Aug. 15, 2014) (Public Notice).

* See Intelsat License LLC Requestfor Modification ofEarth Station KL92, File No. SES—MOD—INTR2014—
02158 (filed Oct. 30, 2014).
Intelsat Corporation
7900 Tysons One Place, Mclean, VA 22102—5972 USA www.intelsat.com T +1 703—559—6800


Ms. Marlene H. Dortch
October 30, 2014
Page 2

systems."" Intelsat seeks waiver to permit the Castle Rock, Colorado earth station KLO92 to
communicate with the Intelsat 30 satellite at 95.05° W.L.

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. As shown below, good cause exists here to grant a waiver allowing the KL92 to provide TT&C
services to the Intelsat 30 satellite using frequencies in the 10700—11700 MHz band.

Good cause exists to waive the international only requirements for the 10700—11700 MHz frequency
band. The purpose of NGS2 is to limit the number of the FSS service earth stations with which the co—
primary fixed service would need to coordinate." Intelsat will provide 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 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."" The International Bureau has found that waiving the international only
requirement would not undermine the purpose of the rules if the party seeking a waiver 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.‘" KL92 will not transmit in the 10700—11700 MHz frequency band and
Intelsat agrees to accept any level of interference into those 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.



* See 47 C.F.R. § 2.106 fna. NGS52.
°47 C.F.R. §1.3.
° N. E. Cellular Tel. Co. v. FCC, 897 F.2d4 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.

8 See Satellite Services, 26 RR 24 1257, 1263—65 (1973). See also EchoStar KuX Corporation Applicationfor
Authority to Construct, Launch and Operate a Geostationary Satellite Using the Extended Ku—band Frequencies
in the Fixed—Satellite Service at the 83°W.L. Orbital Location, Order and Authorization, DA 04—3162, 9 (Int‘l
Bur., Sept. 30, 2004) ("EchoStar 83° Waiver").

* See The Boeing Company, Order and Authorization, 16 FCC Red 22645, 22651 (Int‘l Bur. & OET 2001);
Application ofFugro—Chance, Inc. for BlanketAuthority to Construct and Operate a Private Network ofReceive—
Only Mobile Earth Stations, Order and Authorization, 10 FCC Red 2860 (Int‘1 Bur. 1995) (authorizing MSS in
the C—band); see also Application ofMotorola Satellite Communications, Inc. for Modification ofLicense, Order
and Authorization, 11 FCC Red 13952—13956 (Int‘l Bur. 1996) (authorizing service to fixed terminals in bands
allocated the mobile satellite service).

‘° EchoStar 83° Waiver, J 13.


Ms. Marlene H. Dortch
October 30, 2014
Page 3

The provision ofTT&C services to the Intelsat 30 satellite at 95.05° W.L. is a critical step in ensuring
that the satellite will be fully operational at 95.05° W.L. This, in turn, will ensure continuity of service
to customers at the 95.05° W.L. location, and therebypromotes the public interest.

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

Sincérely,




Cynthia J. Grady
Regulatory Counsel
Intelsat Corporation




cc: Paul Blais



Document Created: 2014-12-17 14:37:04
Document Modified: 2014-12-17 14:37:04

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