Attachment SESSTA2016020500121.

SESSTA2016020500121.

DECISION submitted by FCC

GRANT

0000-00-00

This document pretains to SES-STA-20160205-00121 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2016020500121_1127941

KL92 SES—STA—20160205—00121 182016000381 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: f 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 m-woDNz CallS:gn MD&_.\\" {or other 1dexmfier) GRANTED International Bureau

Intelsat License LLC KL92 SES—STA—20160205—00121 Special Temporary Authority Intelsat is granted, under the following conditions, Special Temporary Authority for 30 days, beginning March 4, 2016, to use it Ku—band earth station at Castle Rock, Colorado to provide launch and early orbit phase (LEOP) services to the Eutelsat—65W satellite at its permanent orbital location 65° W.L. The satellite is expected to be launched on March 8, 2016. 1. Uplink to Eutelsat—65W @ 65° W.L on 13752.0 MHz and 14000 MHz (RHCP) within coordinated emission and power limits. 2. Downlink from Eutelsat—65W @ 65°W.L on 10949.7 MHz and 11200.3 MHz (LHCP). 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 Eutelsat 65W LEOP mission is as follows: Ph.: (703) 559—7701 — East Coast Operations Center (primary); (310) 525—5591 — 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, Intelsat License LLC, KL92, 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. File #CCGS&T(O—BQ\L6 ~Dor! Call s,g\% Grant Date_J&\\v (or other identifier) Dates GRANTED Fr"m’j‘)\\? To: International Bureau Approved: (

2. Contact Name: Cynthia J. Grady Phone Number: 703—559—6949 Company: Intelsat Corporation Fax Number: 703—559—8539 Street: 7900 Tysons One Place E—Mail: cynthia.grady@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 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.F.R.Section 1.1114). C Governmental Entity g*y Noncommercial educational licensee «34 Other(please explain): 4b. Fee Classification CGX — Fixed Satellite Transmit/Receive Earth Station 5. Type Request «4 Use Prior to Grant «34 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 (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: Exhibit B 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, commencing March 8, 2016, to use its Castle Rock, Colorado Ku—band earth station, call sign KL92, to provide launch and early orbit phase services for the Eutelsat—65W satellite. Eutelsat—65W is expected to be launched on March 8, 2016. 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 "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).

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@fec.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 number or 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.

INTELSAT Envision. Connect. Transform. February 5, 2016 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th 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 8, 2016, to use its Castle Rock, Colorado Ku—band earth station—call sign KL92—to provide launch and early orbit phase ("LEOP") services for the Eutelsat—65 W satellite. Eutelsat—65 W is expected to be launched on March 8, 2016." The LEOP period is expected to last approximately 10 days." The Eutelsat—65 W LEOP operations will be performed in the following frequencies: 13752.0 MHz and 14000.0 MHz in the uplink (RHCP), and 10949.7 MHz and 11200.3 MHz in the downlink (LHCP). 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 Eutelsat—65 W mission is as follows: Ph.: (703) 559—7701—East Coast Operations Center (primary) (310) 525—5591 — West Coast Operations Center (back—up) Request to speak with Harry Burnham or Kevin Bell. Intelsat hereby attaches Exhibits A and B, which contain technical information 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, as well as a waiver request. ‘ 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 Eutelsat—65W, which Intelsat understands is licensed by France, will be at 65.0° W.L. The in—orbit testing location will be 42.5° W.L. * Intelsat is seeking authority for 30 days to accommodate a possible launch delay. * SSL, the manager of the Eutelsat—65 W mission, will handle the coordination. Intelsat Corporation 7900 Tysons One Place, Mclean, VA 22102—5972 USA www.intelsat.com T +1 703—559—6800

Ms. Marlene H. Dortch February 5, 2016 Page 2 Intelsat is in the process of coordination and will provide technical information that demonstrating that the operation of the earth station will be—compatible with its.electromagnetic environment and willnot cause harmful interference into any lawfully operating terrestrial facility before launch. In the extremely unlikely event that harmful interference should occur due to trarismissionsto or from its earth station, Intelsat willfake all reasonable steps to eliminate the interference. Intelsatalso notes that for purposes of the Eutelsat—65W LEOP mission, it is seeking to operate in the frequencies listed in this request at power levels notto exceed 21.0 dBW. Finally, Intelsat clarifies that during the Eutelsat—65W launch, SSL will serveas the mission manager. SSL will build and send the commands to the Intelsat anternina, which will process and execute the commands. Telemetry received by Intelsat will beforwarded to SSL. Intelsat will remain in control of the baseband unit, RF equipment, and antenna. Grant of this STA request will allow Intelsat tohel_p launch the Eutelsat—65W satellite. This, in turn, will help provide video services atthe 65.0° W.L. orbital location and thereby promotes the public interest. Please direct any questions regarding this STA request to the undersigned at (703) 559—6949. Respectfully submitted, CynthiaJ. Grady Regulatory Counsel Intelsat Corporation co: Paul Blais

Exhibit A 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.© Waiveris 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 Eutelsat—65 W 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 Eutelsat—65 W satellite, nor is Intelsat in contractual privity with that operator. Rather, an affiliate of Intelsat has a contract with SSL, the manufacturer of the Eutelsat—65 W 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.2d 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 Eutelsat—65 W 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 10 days of LEOP services to the Eutelsat—65 W satellite. It is Intelsat‘s understanding that Eutelsat—65 W is licensed by France, 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 Eutelsat—65 W satellite using its U.S. earth station for a period of approximately 10 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 10 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).

Exhibit B Intelsat License LLC Castle Rock, Colorado NEC 12.5 Meter Earth Station Call Sign: KL92 Compliance with FCC Report & Qrder (FCC96—377) for the 13.75 — 14.0 GHz Band Analysis and Calculations 1. Background This Exhibit is presented to demonstrate the extent to which the Intelsat License LLC ("Intelsat") satellite earth station in Castle Rock, Colorado is in compliance with Federal Communications Commission ("FCC") Report and Order 96—377. The potential interference from the earth station to U.S. Navy shipboard radiolocation operations ("RADAR") and the National Aeronautics and Space Administration ("NASA") space research activities in the 13.75 — 14.0 GHz band is addressed in this exhibit. The parameters for the earth station are: Table 1. Earth Station Characteristics e Coordinates (NAD83): 104° 48‘ 25.0" W, 39° 16‘ 38.0"° N W e Satellite Location for Earth Station: EUTELSAT—65W ffrom 33° to 177° W e Frequency Band: 13.7515—13.7525 GHz uplink & 13.9995—14.0005 GHz uplink e Polarizations: Linear & Circular + Emissions: 1MOOFXD e Modulation: FM/PCM/PSK e Maximum Aggregate Uplink EIRP: 85 dBW for all Carriers e Transmit Antenna Characteristics Antenna Size: 12.5 meter in Diameter Antenna Type/Model: Harris Gain: 64.0 dBi e RF power into Antenna Flange: 21.0 dBW or 2.6 dBW/4 kHz (Maximum]

* Minimum Elevation Angle: 5.03° @ 258.51° Az 5.32° @ 101.75° Az e Side Lobe Antenna Gain: 29 — 25*log(8) Because the above uplink spectrum is shared with the Federal Government, coordination in this band requires resolution data pertaining to potential interference between the earth stations and both U.S. Navy Department and NASA systems. Potential interference from the earth station could impact the U.S. Navy and/or NASA systems in two areas. These areas are noted in FCC Report and Order 96—377 dated September 1996, and consist of (1) Radiolocation and radio navigation, (2) Data Relay Satellites. Summary of Coordination Issues: 1) Potential Impact to Government Radiolocation (Shipboard Radar) 2) Potential Impact to NASA Tracking and Data Relay Satellite Systems ("TDRSS") 2. Potential Impact to Government Radiolocation (Shipboard Radar) Radiolocation operations ("RADAR") may occur anywhere in the 13.4 — 14 GHz frequency band aboard ocean going U.S. Navy ships. FCC order 96—377 allocates the top 250 MHz of this 600 MHz band to the Fixed Satellite Service ("FSS") on a co—primary basis with the radiolocation operations and provides for an interference protection level of —167 dBW/m*/4 kHz. The closest distance to the shoreline from the Castle Rock earth station is approximately 1350 km southwest toward the Pacific Ocean. Therefore, there should be no interference to the U.S. Navy RADAR from the Castle Rock, Colorado due to distance and terrain blockage between the site and the shore. 3. Potential Impact to NASA‘s Tracking and Data Relay Satellite System The geographic location of the Intelsat earth station in Castle Rock, Colorado is outside the 390 km radius coordination contour surrounding NASA‘s White Sands, New Mexico ground station complex. Therefore, the TDRSS space—to—earth link will not be impacted by the Intelsat earth station in Castle Rock, Colorado. The TDRSS space—to—space link in the 13.772 to 13.778 GHz band is assumed to be protected if an earth station produces an EIRP less than 71 dBW/6 MHz in this band. The 12.5 meter earth station antenna will not transmit in this band. Therefore, there will be no potential interference to the TDRSS space—to—space link.

4. Coordination Result Summary and Conclusions The results ofthe analysis and calculations performed in this exhibit indicate that compatible operation between the earth station at the Castle Rock, Colorado facility and the U.S. Navy and NASA TDRSS space—to—earth and space—to—space links are possible. No interference to U.S. Navy RADAR or NASA TDRSS operations from the Castle Rock, Colorado site earth station will occur.


Document Created: 2016-02-24 16:41:38
Document Modified: 2016-02-24 16:41:38
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