Attachment STA Request

This document pretains to SES-STA-20150303-00107 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2015030300107_1077907

March 2, 2015 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, DC 20554 Re: Request for Special Temporary Authority Fillmore, California Earth Station E4132 EXPEDITED TREATMENT REQUESTED Dear Ms. Dortch: Intelsat License LLC (“Intelsat”) herein requests a grant of Special Temporary Authority (“STA”)1 for 30 days, commencing immediately, to use its Fillmore, California C-band earth station—call sign E4132—to provide launch and early orbit phase (“LEOP”) services for the ABS-3A satellite. This request for STA is related to a verbal grant provided by the Federal Communications Commission (“FCC”) on March 2, 2015. ABS-3A was successfully launched March 1, 2015.2 The LEOP period is expected to last approximately 160 days,3 and the ABS-3A LEOP operations will be performed in the following frequency bands: 6420.00 MHz and 6425.00 MHz in the uplink (LHCP), and 4194.5 MHz and 4197.0 MHz in the downlink (LHCP). As Intelsat has previously informed the International Bureau staff on March 2, 2015, upon launch Intelsat discovered the ABS-3A satellite frequencies provided by its customer, which are reflected in Intelsat’s December 16, 2014 STA request,4 were incorrect. The original STA request specified use of 6020.00 MHz and 6025.0 MHz in the uplink (LHCP)—the correct uplink frequencies are 6420.00 MHz and 6425.0 MHz (LHCP). 1 Intelsat has filed its STA request, an FCC Form 159, a $195.00 filing fee, and this supporting letter electronically via the International Bureau’s Filing System (“IBFS”). 2 The permanent orbital location for ABS-3A, which Intelsat understands is licensed by Papua New Guinea, will be at 3° W.L. The in-orbit testing location will be 3° W.L. 3 Intelsat will also be seeking authority for 180 days to accommodate the longer orbit-raising time period required for an electric propulsion satellite. 4 See Satellite Communications Services Information; Actions Taken, Report No. SES-01723, File No. SES-STA- 20141217-00904 (Feb. 4, 2015) (Public Notice). Intelsat will not be operating under this grant of authority.

Ms. Marlene H. Dortch March 2, 2015 Page 2 Intelsat requests that the STA sought herein commence immediately. The frequency error was unforeseen, as the incorrect frequencies were provided in error by the party contracting with Intelsat for LEOP services. As such this is the type of extraordinary event that makes grant of an STA on less than three working days’ advance notice appropriate.5 To the extent necessary, Intelsat also requests a waiver of 47 C.F.R. § 25.120(a), which requires an STA request to “contain the full particulars of the proposed operation including all the facts sufficient to justify the temporary authority sought.” The Commission may grant a waiver for good cause shown.6 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.7 Waiver is therefore appropriate if special circumstances warrant a deviation from the general rule, and such a deviation will serve the public interest. Good cause exists to waive 47 C.F.R. § 25.120(a) because the unforeseen error in uplink frequencies was not, and could not have been, discovered by Intelsat until after the launch of the ABS-3A satellite and therefor it is not possible for Intelsat to obtain a coordination report to submit contemporaneously with this request. Intelsat will take all practical steps to coordinate the safe operation of E4132. 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. Grant of this STA request will allow Intelsat to preform TT&C for the ABS-3A satellite and therefor safely transition the satellite to geostationary orbit. As such, this request is in the public interest. Intelsat will, as soon as possible, provide technical information demonstrating 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. Intelsat has commenced coordination based on the correct frequencies. In further support of this request, Intelsat hereby attaches Exhibit A, a waiver request of 47 C.F.R § 25.137 and § 25.114, which was also part of its original STA request.8 During the ABS-3A LEOP mission, Boeing will serve as the mission manager. Boeing 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 Boeing. Intelsat will perform the ranging sessions by sending a tone to the spacecraft periodically. Intelsat will remain in control of the baseband unit, RF equipment, and antenna. 5 See 47 C.F.R. 25.120(a). 6 47 C.F.R. §1.3. 7 WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969); N.E. Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990). 8 See supra note 4.

Ms. Marlene H. Dortch March 2, 2015 Page 3 For these reasons set forth herein, Intelsat respectfully requests that the Commission expeditiously grant this request. Please direct any questions regarding this STA request to the undersigned at (703) 559—6949. Respectfully submitted, @W 7_ q. Sm ‘éf Cynthia J. Grady Regulatory Counsel Intelsat Corporation ge: Paul Blais


Document Created: 2015-03-02 16:14:50
Document Modified: 2015-03-02 16:14:50
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