Intelsat Comments re

COMMENT submitted by Intelsat License LLC

Intelsat Comments re Inmarsat KA25 STA Application

2015-04-30

This document pretains to SES-STA-20150326-00182 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2015032600182_1086818

                                         Before the
                             Federal Communications Commission
                                    Washington, DC 20554


      In the Matter of

      Inmarsat Mobile Networks, Inc.                     File No. SES-STA-20150326-00182

      Application for Special Temporary
      Authority for Paumalu, Hawaii Earth
      Station, Call Sign KA25



                         COMMENTS OF INTELSAT LICENSE LLC

       Intelsat License LLC (“Intelsat”) hereby comments on the above-captioned application

submitted by Inmarsat Mobile Networks, Inc. (“Inmarsat Mobile Networks”) for Special

Temporary Authority (“STA”) for 180 days to use its Paumalu, Hawaii earth station, Call Sign

KA25, to provide C-band telemetry, tracking, and control (“TT&C”) communications for the

Inmarsat-5 F3 spacecraft, which will be located at, or close to, 180.0° E.L. during its Launch and

Early Orbit Phase (“LEOP”), electric orbit raising, and In-Orbit Testing (“IOT”).1 Intelsat

operates the C/Ku-band Intelsat 18 satellite (Call Sign S2817) at 180.0° E.L.2 Intelsat therefore

has a clear interest in ensuring that Inmarsat Mobile Networks’ operations do not cause harmful

interference to the ongoing operations of Intelsat 18.




1
 See Satellite Communications Services; Satellite Radio Applications Accepted For Filing,
Report No. SES-01736, File No. SES-STA-20150326-00182 (Apr. 1, 2015) (Public Notice).
2
 Policy Branch Information; Actions Taken, Report No. SAT-00796, File No. SAT-LOA-
20101014-00219 (Jul. 29, 2011) (Public Notice).


            The Inmarsat-5 F3 spacecraft is a Ka-band satellite with C-band frequencies “for TT&C

during transfer orbit and for emergency purposes.”3 In the instant STA application, Inmarsat

Mobile Networks proposes to add the Inmarst-5 F3 spacecraft as a C-band point of

communication for the KA25 earth station for a five to six week electrical propulsion orbit

raising phase followed by a one month IOT phase “at (or close to) the geostationary location of

180° E.L.”4 Presumably, Inmarsat Mobile Networks will seek additional authority as necessary

to use the KA25 earth station for emergency C-band TT&C purposes.5

           Inmarsat Mobile Networks’ assertion that “all [coordination] issues have been

satisfactorily resolved”6 is not accurate. The use of the KA25 earth station to provide TT&C in

C-band frequencies to the Inmarsat-5 F3 spacecraft at, or in close proximity to, 180.0° E.L., even

for limited periods of time, will cause harmful interference to Intelsat’s co-frequency Intelsat 18

satellite located at 180.0° E.L. This interference unquestionably will cause disruption and

service outages for the customers currently receiving service on the Intelsat 18 transponders that

use the same C-band frequencies as proposed by Inmarsat Mobile Networks. Although Inmarsat

has commenced coordination discussions with Intelsat, it has not informed Intelsat about how it

intends to protect existing Intelsat services on Intelsat 18.

           Prior to action by the Federal Communications Commission (“FCC”) on this application,

Inmarsat Mobile Services should be required to file additional detailed technical information to

3
     Inmarsat Mobile Networks, Inc., Application for Special Temporary Authority for Paumalu,
Hawaii Earth Station, Call Sign KA25, File No. SES-STA-20150326-00182, Technical Annex at
1 (filed Mar. 26, 2015) (“KA25 STA Application”).
4
        KA25 STA Application, Narrative at 1.
5
        Inmarsat Mobile Networks states that the satellite “is meant to serve the United States”. Id.
at 3.
6
        Id. at 4.
                                                    2


demonstrate how C-band TT&C can be conducted without causing harmful interference to

Intelsat’s existing use of the same frequencies. Instead of providing such information, Inmarsat

Mobile Networks is seeking a waiver for portions of Section 25.114, including information

related to “antenna patterns” and “energy.”7 The provision of such information, however, is

necessary for Intelsat to better assess the potential service disruptions to its customers. The FCC

therefore should deny this waiver request unless and until coordination with Intelsat has been

achieved.

       In addition, the STA application does not provide an exact orbital location for IOT.

Instead, it specifies operations “at (or close to) the geostationary location of 180° E.L.”8 The

FCC should require Inmarsat Mobile Networks to specify the precise IOT location. Obviously,

conducting IOT at a location with greater orbital separation from Intelsat 18 at 180.0° E.L. may

mitigate the harmful interference caused by Inmarsat Mobile Networks’ use of the C-band

frequencies for this time period. Even so, additional technical information would still be

required to demonstrate how Inmarsat Mobile Networks’ later use of C-band frequencies for

back-up TT&C to the Inmarsat-5 F3 satellite once it is located at the nominal 180.0° E.L. orbital

location can be conducted without harming customers on Intelsat 18.

       For the reasons set forth herein, the FCC should deny Inmarsat Mobile Networks’ waiver

request for portions of Section 25.114 unless Inmarsat Mobile Networks first achieves

coordination with Intelsat. Additionally, the FCC should require Inmarsat Mobile Networks to

specify the Inmarsat-5 F3 spacecraft’s precise IOT location.




7
    Id. at 2.
8
    Id. at 1.
                                                 3


                       Respectfully submitted,

                       /s/ Susan H. Crandall
                       Susan H. Crandall,
                       Associate General Counsel

                       Cynthia J. Grady
                       Regulatory Counsel

                       INTELSAT CORPORATION

Jennifer D. Hindin
Colleen King
WILEY REIN LLP
1776 K Street, N.W.
Washington, DC 20006

April 30, 2015




                          4


                                CERTIFICATE OF SERVICE

I, Derrick Johnson, do hereby certify that on this 30th day of April 2015, a copy of the foregoing
Comments of Intelsat License LLC is being sent via first class, U.S. Mail, postage paid, to the
following:


Chris Murphy
Vice President, Government Affairs
Inmarsat
1101 Connecticut Avenue, NW
Suite 1200
Washington, DC 20036




                                                   Gl
                                             Derrick Johnson
                                             Senior Paralegal
                                             Intelsat Corporation



Document Created: 2015-04-30 11:19:03
Document Modified: 2015-04-30 11:19:03

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