Attachment 20171024151954.pdf

20171024151954.pdf

DECISION submitted by IB-FCC

Grant

2017-10-25

This document pretains to SES-STA-20171016-01169 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2017101601169_1295855

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            £030096      sES—STA—20171016.01169       182017002954
            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:
for Using Castle Rock, Colorado Earth Station E030096 to Provide TT&C for Intelsat 16 During Drift and On—
Stationat 76.2 W.L.
  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:          McLcan                                State:                              VA
            Country:        USA                                  Zipcode:                           22102        ~8972
            Attention:     Susan H Crandall



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                                                                            File #565—574—20/410 16—0 1167
                                                                            Call Sign EA30076Grant Date 1D I(E aor?
                                                                            (orother identifier)


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Applicant: Intelsat License LLC
Call Sign: E030096
File No.: SES—STA—20171016—01169

Intelsat License LLC ("Intelsat") is granted special temporary authority (STA) for 30 days, beginning
October 17, 2017, to operate its Castle Rock, CO earth station with Intelsat 16 (S§2750) satellite to
provide telemetry, tracking, and control ("TT&C") communications on frequencies 13.9975 GHz, 14.4995
GHz (Earth—to—space) and 12.19825 GHz, 12.19875 GHz (space—to—Earth) during Intelsat 16‘s drift from
58.1° W.L. to 76.2° W.L. orbital location and on—station at 76.2° W.L. subject to the following conditions:

1. All operations under this grant of STA shall be on an unprotected and noninterference basis and
Intelsat is obliged to comply with the applicable laws, regulations, rules, and licensing procedures of that
country.

2. All operators of satellites 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
intelsat 16 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.

3. Intelsat will maintain full operational control with Intelsat 16 (S2750) at all times.

4. Intelsat will maintain Intelsat 16 (§2750) with an east—west longitudinal station—keeping tolerance of
+/—0.05 degree at 76.2° W.L. orbital location.

5. 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.

6. Intelsat must operate only the TT&C frequencies authorized for Intelsat 16 during the drift from 58.1°
W.L. to 76.2° W.L. orbital location.

7. The operations of Intelsat 16 and associated earth stations must comport with the applicable uplink
and downlink limits in 47 CFR §25.140(a)(3) of the Commission‘s rules, unless Intelsat coordinates any
non—conforming operations with the operations of U.S.—licensed geostationary orbit space stations
within 6 degrees of the 76.2° W.L. orbital location. Intelsat must also comport with the maximum power
limits indicated in existing or future coordination agreements at 76.2° W.L. Non—conforming operations
must also be coordinated with respect to those operations of non—U.S.—licensed space stations within 6
degrees of 76.2° W.L. involving approved communications with U.S.—licensed earth stations.

8. Any action taken or expense incurred as a result of operations pursuant to this STA is solely at
Intelsat.

9. During drift operations, all transponders other than TT&C transponders will be turned off.

10. Pursuant to footnote US342 of the United States Table of Frequency Allocation, 47 CFR § 2.106,
services operating in the 14.47—14.50 GHz band shall take all practicable steps to protect the radio
astronomy service from harmful interference.


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11. Grant of this authorization is without prejudice to any determination that the Commission may make
regarding pending or future Intelsat applications.

12. Intelsat‘s request for waiver of 47 CFR § 25.120(a), which requires an STA request to be received by
the Commission at least 3 working days prior to the date of proposed operation, is GRANTED, due to the
exigent circumstances that are reflected in this STA request and in accordance with emergency
procedures put in place to provide communications in areas affected by Hurricane Maria.

13. All operations must be within the relevantrequested operational parameters in IBFS File No. SAT—
S$TA—20171016—00139.

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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                                              File #5GS—STA—2077 10 12— Oit

                                              Call Sien£O3%HGrant Date(idfarr7
                                              (or other identifier)


                         GRANTED
                       1 ‘ernational Bureau


                                                                                      INTELSAT.
                                                                                        Envision. Connect. Transform.


October 16, 2017

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 E030096
                  Expedited Treatment Requested

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests a grant of Special Temporary Authority ("STA")‘ for
30 days, commencing upon grant, to use its Castle Rock, Colorado Ku—band earth station—call sign
E030096—to provide telemetry, tracking, and command ("TT&C") services for Intelsat 16 ($2750)
during its drift from 58.1° W.L to 76.2° W.L. and on—station at 76.2° W.L.* Intelsat seeks this STA in
order to assist a customer in responding to the damage caused by Hurricane Maria to the
communications networks in Puerto Rico. The drift is expected to take two weeks.

TT&C operations will be performed in the following frequencies: 12198.25 MHz, 12198.75 MHz,
13997.5 MHz, and 14499.5 MHz. Intelsat is concurrently filing a 180—day STA request for TT&C
services at 76.2° W.L. The drift operations will be coordinated with all operators of satellites that use
the same frequency bands and are in the drift 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 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 has filed its STA request, an FCC Form 159, a $200.00 filing fee, and this supporting letter
electronically via the International Bureau‘s Filing System ("IBFS").
* See Intelsat License LLC Requestfor 30—Day STA to Drift and Operate Intelsat 16 at 76.2 W.L., Call Sign
$2750, File No. SAT—STA—20171016—00139 (filed Oct. 16, 2017).
* Intelsat 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
October 16, 2017
Page 2


The proposed TT&C operations at 76.2° W.L. will be consistent with Intelsat‘s coordination agreements
for the nominal 76.2° W.L. orbital location. In the unlikely event that harmful interference occurs,
Intelsat will take all necessary steps to eliminate the interference.

In further support of this request, Intelsat herewith attaches Exhibit A, which contains 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 or into Federal systems operating in the 13.75—14.00 GHz band. 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 requests a waiver of 47 C.F.R. § 25.120(a), which requires an STA
request to be "received by the Commission at least 3 working days prior to the date of proposed ...
operation[s.]" 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 a natural disaster has decimated
communications in Puerto Rico. In the weeks following Hurricane Maria, the island has been unable to
overcome the damage caused to the communications networks and continues to desperately need basic
communications. In order to reposition Intelsat 16 to 76.2° W.L. quickly, and given that the satellite
drift will take two weeks, Intelsat seeks immediate authorization rather than filing a request 3 working
days prior to the proposed drift and operations. Accordingly, "extraordinary reasons for the delay"
justify waiver of the rule.

Grant of this STA request will allow Intelsat to expeditiously drift Intelsat 16 to a 76.2° W.L., where it
will provide critical communication services in Puerto Rico. Accordingly, grant of this STA request is
in the public interest.




+47 CF.R. §1.3.
* WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969); N.L. Cellular Tel. Co. v. FCC, 897 F.24
1164, 1166 (D.C. Cir. 1990).


Ms. Marlene H. Dortch
October 16, 2017
Page 3


For the reasons set forth herein, Intelsat respectfully requests that the Commiésion grant this expedited
STA request. Please direct any questions regarding this request to the undersigned at (703) 559—6949.

Respectfully submitted,

/s/ Cynthia J. Grady

Cynthia J. Grady
Regulatory Counsel
Intelsat Corporation



cc: Paul Blais


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).
G Governmental Entity       O Noncommercial educational licensee
() Other(please explain):

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


O   Use Prior to Grant                            O   Change Station Location                         ®©   Other



6. Requested Use Prior Date


7. CityCastle Rock                                                        8. Latitude
                                                                          (dd mmss.sh)      39   16    37.0    N


9. State   CO                                                              10. Longitude
                                                                           (dd mm ss.s h)     104   48    24.0   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 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 upon grant, to use its Castle Rock, Colorado Ku—band earth station, call sign
     E0O30096,     to provide telemetry,            tracking, and command services for Intelsat 16                             (S$2750)
    during its drift from 58.1 W.L to 76.2 W.L. and on—station at 76.2 W.L.                                            Intelsat seeks




13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is           @ Yes           ( 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 General 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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12. Description

Intelsat License LLC herein requests a grant of Special Temporary Authority for 30 days,
commencing upon grant, to use its Castle Rock, Colorado Ku—band earth station, call sign EO30096,
to provide telemetry, tracking, and command services for Intelsat 16 ($2750) during its drift from
58 .1 W.L to 76.2 W.L. and on—station at 76.2 W.L. Intelsat seeks this STA in order to assist a
customer in responding to the damage caused by Hurricane Maria to the communications networks in
Puerto Rico.



Document Created: 2017-10-24 15:20:26
Document Modified: 2017-10-24 15:20:26

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