Attachment 20150327171236.pdf

20150327171236.pdf

DECISION submitted by IB-FCC

Grant

2015-03-03

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

IBFS_SESSTA2015030300107_1081847

                                         E4132     .   SES—STA—20150303—00107   182015000382
                                         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 Fillmore, California Earth Station F4132
 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        =5972
           Attention:   Susan H. Crandall




                                                                                   )1 fhe Comwdsfrsm®
                                                                                                                    #+


Applicant:      Intelsat License LLC
File No.:       SES—STA—20150303—00107
Call Sign:      E4132

Intelsat License LLC is granted special temporary authority, for 30 days, from March 3, 2015, to
operate its earth station, Call Sign E4132, located in, Fillmore, California, to provide launch and
early orbit phase services for the ABS—3 satellite, licensed and registered by Papua New Guinea, as it
travels to its permanent orbital location 3.0° W.L. Communications will be on the following center
frequencies: 6420 MHz and 6425 MHz (LHCP) in the (Earth—to—space) and 4194.5 MHz and 4197.0
MHz (LHCP) in the (space—to—Earth) and under the following conditions:


1. Intelsat License LLC will coordinate with operators of co—frequency satellites in the drift path.

2. Operations in the uplink frequencies will be within the coordinated parameters of the antenna‘s
current license.

3 Operations, shall not cause harmful interference to, and shall not claim protection from,
interference caused to it by any other lawfully operating station and it shall cease transmission(s)
immediately upon notice of such interference.

4. Grant of this authorization is without prejudice to any determination that the Commission may
make regarding pending or future Intelsat License LLC‘s applications.

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

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.
                                                                 ‘(:Jitf, tondFone"


2. Contact


             Name:           Susan H. Crandall                        Phone Number:                         703—559—7848
             Company:        Intelsat Corporation                     Fax Number:                           703—559—8539
             Street:         7900 Tysons One Place                    E—Mail:                               susan.crandall@intelsat.com


             City:           McLean                 ‘                 State:                                VA
             Country:        USA                                      Zipcode:                              22102       —5972
             Attention:                                               Relationship:                         Legal Counsel


(If your application is related to an application filed with the Comumission, enter eitherthe 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?
& [Yes, complete and attach FCC Form 159.                If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
<3 Governmental Entity         4 Noncommercial educational licensee
C Other(please explain):

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

5. Type Request


 lel   Use Prior to Grant                               (®)   Change Station Location                       @   Other


6. Requested Use Prior Date


7. CityFillmore                                           .                      8. Latitude
                                                                                 (dd mm ss.s h)   34   24    22.0   N


9. State   CA                                                              10. Longitude
                                                                           (dd mm ss.s h)    118    53   34.0   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 appearin 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,
     commencing immediately,               to use   its Fillmore,         California C—band earth station,                    call    sign
     E4132, to provide launch and early orbit phase services for the ABS—3A satellite.




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
   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).


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 burdenit 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 sponsorthis collection, unless it displays a currently valid OMB control numberorif 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 LaAW 104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.


                                                                                      INTELSAT
                                                                                        Envision. Connect. Transform.



March 2, 2015


Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12"" 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")‘ for
30 days, commencing immediately, to use its Fillmore, California C—band earth station—call sign
EA4132—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. The LEOP period is
expected to last approximately 160 days," and the ABS—3A LEOP operations will be performed in the
following frequency bands: 6420.00 MHz and 6425.00 MHz in theuplmk (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," 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).              f



‘ 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").

 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.

* Intelsat will also be seeking authority for 180 days to accommodate the longer orbit—raising time period required
for an electric propulsion satellite.

* 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.

Intelsat Corporation
7900 Tysons One Place, Mclean, VA 22102—5972 USA www.intelsat.com T +1 703—559—6800


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."

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." 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.

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."

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.




° See 47 C.F.R. 25.120(a).
647 C.F.R. §1.3.
" 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,




Cynthia J. Grady
Regulatory Counsel
Intelsat Corporation



go:      Paul Blais



Document Created: 2019-04-21 14:57:33
Document Modified: 2019-04-21 14:57:33

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