Attachment SESSTA2017101601174.

SESSTA2017101601174.

DECISION submitted by FCC

GRANT

0000-00-00

This document pretains to SES-STA-20171016-01174 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2017101601174_1295422

SES—STA—20171016—01174 1B2017002955 E140121 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 30—Day STA Using Hagerstown, Maryland Earth Station E140121 to Provide TT&C for Intelsat 16 During Drift and On— Station at 76.2 W.L. 1. Applicant Name: Intelsat License LLC Phone Number: 703—559—7848 DBA Name: . Fax Number: T703—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 File # SSap 3§8010!4—0 \\“N‘ Call\ég})\Q\;‘\Grant Date_\ E ) “\Q\\\j (or other identifier) crantep o "=srrational Bureau Approved:

% CESCABAE3sHHAQz=0ONN Ca \E Grant Date &Q'SO\, \j (or other identifier) Applicant: Intelsat License LLC Call Sign: E140121 srmraxytep Po— File No.: SES—STA—20171016—01174 ;. nal purcau Approved: Intelsat License LLC ("Intelsat") is granted special temporary authority (STA) for 30 days, beginning October 17, 2017, to operate its Hagerstown, MD earth station with Intelsat 16 (S2750) 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 (S2750) 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.

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 relevant requested operational parameters in IBFS File No. SAT— STA—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.

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). Governmental Enti Noncommercial educational licensee 3 23 C Other(please explain): 4b. Fee Classification CGX — Fixed Satellite Transmit/Receive Earth Station 5. Type Request 3 Use Prior to Grant 34 Change Station Location » @ Other 6. Requested Use Prior Date 7. CityHagerstown 8. Latitude (dd mm ss.s h) 39 35 53.1 N

9. State MD 10. Longitude (dd mmss.s h) 77 45 22.3 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 Hagerstown, Maryland Ku—band earth station, call sign El140121, 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 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@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 sponsor this collection, unlessit 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.

12. Description Intelsat License LLC herein requests a grant of Special Temporary Authority for 30 days, commencing upon grant, to use its Hagerstown, Maryland Ku—band earth station, call sign EBl140121, 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.

Exhibit A Intelsat License LLC Hagerstown, Maryland ViaSat 13.5m 13.5 Meter Earth Station 1. Background . This Exhibit is presented to demonstrate the extent to which the Intelsat License LLC ("Intelsat") satellite earth station in Hagerstown, Maryland is in compliance with the Federal Communications Commision ("FCC") Report and Order 96—377. The potential inteference 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: Coordinates (NAD83): 39° 35‘ 53.1" N, 77° 45 22.3" W Satellite Arc Range for Earth Station: IS—16 at 58°W to 76°W Frequency Band: 13.75—14.00 GHz Polarizations: Linear & Circular Emissions: 1MOOF7D Modulation: FM/PCM/PSK Maximum Aggregate Uplink EIRP: 88.6dBW for all Carriers Transmit Antenna Characteristics Antenna Size: 13.5 Meters in Diameter Anenna Type/Model: ViaSat 13.5m Gain: 64 dBi RF Power into Antenna Flange: 24.6 dBW or 0.6 dBW/4kHz Minimum Elevation Angle: 39.81° @ 150.6° Azimuth 44.13° @ 177.24° Azimuth Side Lobe Antenna Gain FCC Reference Pattern 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 intefference from the earth station could impact the U.S. Navy and/or NASA systems in two areas. These areas are noted in GCC Report and Order 96—377 dated September 1996, and consist of (1) Radiolocation and Radio Navigation, (2) Data Relay Satellites. Summary of Coordination Issues: . a.) Potential Impact to Government Radiolocation (Shipboard Radar) b.) 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—14.0 GHz frequency band aboard ocean—going U.S. Navy ships. FCC order 96—377 allocates the top 250MHz 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*/4kHz. The closest distance to the shoreline from Hagerstown, Maryland earth station is approximately 131 km. The calculation of the power spectral density at this distance is given by: 1. Clear Sky EIRP: 88.6 dBw 2. Carrier Bandwidth: 1000 kHz 3. PD at antenna input: 0.6 dBW/4kHz 4. Transmit Antenna Gain: 64 dBi 5. Antenna Gain to Horizon: —11 dBi 6. Antenna Elevation Angles: 39.8° @ 150.6° azimuth 44.1° @ 177.2° azimuth The earth station will radiate interference toward the ocean according to its off—axis side—lobe performance. A conservative analysis, using FCC standard reference pattern, results in an off—axis antenna gain of —11 towards the nearest shoreline. The signal density at the shoreline, through free space is: PFD = Antenna Feed Power density (dBW/4kHz) + Antenna Off—Axis Gain (dBi) — Spread Loss (dBW/m*) = 0.6dBW/4kHz +—11dBi— (10*log[4*PI*[131km]42)) = —123.7 dBW/m/4kHz — Additional Path Losses (69 dB) Our calculation indicate additional path loss of approximately 69 dB including absorbtion loss and earth diffraction loss for the actual path profiles from the earth station to the nearest shoreline. The calculated PFD, including additional path losses to the closest shoreline, is —192.7dbW/ m4*2/4 kHz. This is 25.7dB below the —167.0 dBW/ m*2/4 kHz interference criteria of the R&O 96—377. Therefore, there should be no interference to the U.S. Navy RADAR from the Hagerstown, Maryland earth station due to the distance and the 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 Hagerstown, Maryland 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 Hagerstown, Maryland.

The TDRSS space—to—space link in the 13.772 to 13.778 GHz band is assumed to be protected it an earth station produces and EIRP of less than 71 dBW/6MHz in this band. The 13.5 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 of the analysis and calculation performed in this exhibit indicate that compatible operation between the earth station at the Hagerstown, Maryland facility and 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 Hagerstown, Maryland site earth station should occur.

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 Hagerstown, Maryland Earth Station E140121 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 Hagerstown, Maryland Ku—band earth station—call sign E140121—to provide telemetry, tracking, and command ("TT&C") services for Intelsat 16 (S2750) 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 C.F.R. §1.3. 5 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).

Ms. Marlene H. Dortch October 16, 2017 Page 3 For the reasons set forth herein, Intelsat respectfully requests that the Commission grant this expedited STA request. Please direct any questions regarding this request to the undersigned at (7O3) 559—6949. Respectfully submitted, /s/ Cynthia J. Grady Cynthia J. Grady Regulatory Counsel Intelsat Corporation ce: Paul Blais


Document Created: 2017-10-20 16:40:16
Document Modified: 2017-10-20 16:40:16
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