Attachment SESSTA2018022800171.

SESSTA2018022800171.

DECISION submitted by FCC

GRANT

0000-00-00

This document pretains to SES-STA-20180228-00171 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2018022800171_1377285

1B2018000507 E000296 SES—STA—20180228—00171 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 to Use Hagerstown, MD Earth Station E000296 to Provide LEOP Services for Bangabandhu—1 Satellite 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 rile 5BCSRoSsJQ&qgRE&—8son! EODF cmnattElC {or other identifi GRANTED International Bureau Approved/

Applicant: Intelsat License LLC Call Sign: E000296 File No.: SES—STA—20180228—00171 Special Temporary Authority (STA) Intelsat License LLC is granted to operate under STA for 30 days, beginning April 5, 2018, to use its C—band fixed earth station located 39° 35°54.0" N/ 077° 45° 35.0"° W in Hagerstown, Maryland to provide launch and early orbit phase (LEOP) services for the Bangabandhu—1 satellite at its permanent orbital location 119.1° E. The satellite is expected to be launched on April 5, 2018. Operations will be under the following conditions: 1. Uplink to Bangabandhu—1 @ 119.1° E on 5850 MHz and 6425 MHz (LHCP) frequencies with coordinated 850KFXD emission and coordinated power limits. 2. Downlink from Bangabandhu—1 @ 119.1° E on 3703.0 MHz and 4199.8 MHz (CP) frequencies. 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 Bangabandhu—1 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, EO00296, 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 and must inform the Commission, in writing, immediately of such an event. 5. Grant of this STA is without prejudice to any determination that the Commission may make regarding pending or future Intelsat License LLC applications. 6. 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 upon release. ) iOESSROSES3E—00041 “\% 13 CE}&%@_Q\:_GM Date\“%“ (or other identifier International Bureau

Summary of Ext—C band Technical Information For Coordination with NTIA/FAS and WTB Applicant: Intelsat License LLC Call Sign: E000296 File No.: SES—STA—20180228—00171 Purpose of operation: Intelsat License LLC herein requests a grant of Special Temporary Authority for 30 days to use its C—band earth station, Call Sign EO00296, located in Hagerstown, Maryland to provide launch and early orbit phase ("LEOP") services for the Bangabandhu—1 ("BS—1") satellite at the 119.1° E orbital location. The BS—1 satellite is licensed by the Bangladesh administration, and is expected to launch on April 5, 2018. Start Date: April 5, 2018 End Date: May 5, 2018 Site Location: Hagerstown, Maryland Latitude: 39 deg 35° 54.0" N (NAD—83) Longitude: 077 deg 45° 35.0° W (NAD—83) Transmit frequency: 5850.0 MHz, 6425.0 MHz | Receive frequency: 3703.0 MHz, 4199.8MHz Polarization: LHCP —uplink CP— downlink Antenna Size in meter: 9 m, Vertex model KPC Antenna Gain Transmit: 53.5 dBi@ 6.1 GHz Frequency Band Emissions eirp (dBW) eirp density (MHz) (dBW/4kHz) 5850 MHz 850KFXD 86.47 63.2 6425 MHz 850KFXD 86.47 63.2 Satellites: Bangabandhu—1@ 119.1° W

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 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). Cc Governmental Entity £3 Noncommercial educational licensee £34 Other(please explain): 4b. Fee Classification CGX — Fixed Satellite Transmit/Receive Earth Station 5. Type Request g2y Use Prior to Grant g4y Change Station Location «y Other 6. Requested Use Prior Date 7. CityHagerstown 8. Latitude ‘ (dd mm ss.s h) 39 35 54.0 N

9. State MD 10. Longitude ‘ (dd mm ss.s h) 77 45 35.0 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 April 5, 2018, to use its Hagerstown, Maryland C—band earth station, call sign E0O0O0296, to provide launch and early orbit phase services for the Bangabandhu—1 satellite. BS—1 is expected to launch on April 5, 2018. Intelsat expects the LEOP period to last 13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is Yes £y 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 Susan H. Crandall Assoc. 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).

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 numberor 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 April 5, 2018, to use its Hagerstown, Maryland C—band earth station, call sign EO00296, to provide launch and early orbit phase services for the Bangabandhu—1 satellite. BS—1 is expected to launch on April 5, 2018. Intelsat expects the LEOP period to last approximately 30 days .

INTELSAT Envision. Connect. Transform. February 28, 2018 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Request for Special Temporary Authority Hagerstown, Maryland Earth Station E000296 Dear Ms. Dortch: Intelsat License LLC ("Intelsat") herein requests a grant of Special Temporary Authority ("STA")‘ for 30 days, commencing April 5, 2018, to use its Hagerstown, Maryland C—band earth station—call sign E000296—to provide launch and early orbit phase ("LEOP®") services for the Bangabandhu—1 ("BS—1") satellite. BS—1 is expected to launch on April 5, 2018." Intelsat expects the LEOP period to last approximately 30 days. The BS—1 LEOP operations will be performed at the following center frequencies: 5850.0 MHz and 6425.0 MHz (LHCP) in the uplink, and 3703.0 MHz and 4199.8 MHz (CP) in the downlink. 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 BS—1 L'EOP 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. In further support of this request, Intelsat herewith attaches Exhibits A and B, which contain a coordination report and waiver requests. 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. I Intelsat has filed its STA request, FCC Form 159, a $200.00 filing fee, and this supporting letter electronically via the International Bureau‘s Filing System ("IBFS"). 2 The in—orbit testing and final orbital location for BS—1, which Intelsat understands is licensed by Bangladesh, will be 119.1° EL. > Thales Alenia Space, the manager of the BS—1 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 28, 2018 Page 2 Finally, Intelsat clarifies that during the BS—1 LEOP mission, Thales Alenia Space ("Thales") will serve as the mission manager. Thales 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 Thales. 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. Grant of this STA request will allow Intelsat to help launch the BS—1 satellite. This will help provide services at the 119.1° E.L. location and thereby promotes the public interest. Please direct any questions regarding this STA request to the undersigned at (703) 559—7848. Respectfully submitted, /s/ Susan H. Crandall Susan H. Crandall Associate General Counsel Intelsat Corporation co: Paul Blais

Exhibit A Prepared By COMSEARCH 19700 Janelia Farm Boulevard, Ashburn, VA 20147 {703)726—5500 http://www.comsearch.com Prepared For Intelsat License LLC Hagerstown, Maryland Temporary Transmit—Only Earth Station Operation Dates: 03/27/2018 — 04/26/2018 Pursuant to Part 25.203(c) of the FCC Rules and Regulations, the satellite earth station proposed in this application was coordinated by Comsearch using computer techniques and in accordance with Part 25 of the FCC Rules and Regulations. Verbal and written coordination was conducted with the below listed carriers on January 22, 2018. Company AB Services LLC AT&T Corp. AT&T Wireless Services 3 LLC — PA Access MLP Operating LLC Adams County Department of Emergency Sve Affiniti PA, LLC Albemarle, County of, Virginia Allentown SMSA Limited Partnership Alitel Communications LLC — Western PA Alite! Communications LLC—E OH WV American Electric Power Service Corp Appalachia Engineering Services Appalachian Power Company Aratika LLC Argos Engineering, LLC Atlantic Broadband (Penn), LLC Atlantic City Electric Company Atlantic, County of Baltimore County of Maryland Baitimore Gas and Electric Company Beaver Springs Faith Baptist Church, Inc Bedford County of Believe Wireless, LLC Berks County Department of Emergency Ser Blair County 911 Blue Ridge Carriers Blueline Communications Bucks County Dept. of Emergency Comm CBS Radio of Maryland, LLC CNG Transmission Corporation Calvert, County of Cambria, County of Capital Communications of America Caroline County, VA Carroll, County of Cellco Partnership — Bridgeville, PA/WV Frequency Coordination and Interference Analysis Report 02/22/2018 Page 1 of 9

Cellco Partnership — Southern Virginia Cellco Partnership— PA Region Cellco Partnership—WDC/Baitimore Cellco Prtnrshp — Phil. Tri—State Rgn Centre Communications Inc. Charles, County of Chester, County of Chesterfield, County of City of Fredericksburg Citynet Clearfield, County of Clinton, County of Columbia Gas Transmission, LLC Columbia, County Commonwealth of Pennsylvania Commonwealth of Pennsylvania—Radio Proj. Comprehensive Wireless LLC Conterra Ultra Broadband, LLC Coralinks County of Augusta County of Burlington, Public Safety Cntr County of Camden County of Centre County of Culpeper County of Fayette County of Frederick County of King William, Virginia County of Lycoming County of York DSRC Networks Dauphin County Emergency Management Delaware County (PA) Emergency Services Delaware Division of Communications Delmarva Broadcasting Company Delmarva Power and Light Company Direct Broadcast Services, Inc. Dominion Energy Transmission, Inc. ECW Wireless, LLC Eastern MLG LLC Electric Railroad, LLC Enoch Pratt Free Library Essex, County of Exelon Generation Company, LLC FELHC, Inc. Federal Communication Commission Frederick County Fulton County of (PA) Fundamental Broadcasting LLC GSB Broadcasting LLC GTT America LLC Garden State Transmissions Getwireless.Net Gloucester, County of Goochland County Goochland, County of Greene, County of (PA) Frequency Coordination and Interference Analysis Report 02/22/2018 Page 2 of 9

Hanover, County of Hardy Cellular Telephone Company Hardy County OEM/Eq11 Harrisonburg—Rockingham ECC Henrico County High Voltage Communications LLC (CFN) Huntingdon County, Pa Huntingdon, County of Indiana, County of Jackson County West Virginia Jefferson County of Pennsylvania Jefferson Microwave, LLC Juniata County Emergency Services Kentucky Power Company King and Queen County Kryptick Technologies Lancaster County—Wide Communications Limitless Mobile, LLC Loudoun, County of MGW Networks, LLC Maryland Public Broadcasting Commission Maryland State Highway Administration Maryland, State of — Dept.of Info & Tech McKean, County of Mifflin County Montgomery County Of Montgomery, County of National Tower Company II, LLC National Tower Company LLC New Cingular Wireless PCS LLC — NJ New Cingular Wireless PCS — Maryland New Cingular Wireless PCS LLC — DC New Cingular Wireless PCS LLC — Ohio New Cingular Wireless PCS LLC — VA New Cingular Wireless PCS LLC — WV,NC,SC New Cingular Wireless PCS LLC—DE/NH/RI New Cingular Wireless PCS, LLC — PA New Jersey Turnpike Authority—Pkwy Div New Jersey, State of —NJ Transit New Line Networks, LLC Norfolk Southern Railway Northumberland County DPS/911 Ohio Valley Electric Company PSEG Services Corporation Peco Energy Company Pennsylvania Turnpike Commission Peoples Natural Gas Company LLC Pepco Holdings Inc. Perry, County of Pittsburgh SMSA Limited Partnership Preston County Office of Emergency Manag Prince George‘s County Prince William, County of Radio One Inc Rappahannock Electric Cooperative Richmond, City of Frequency Coordination and Interference Analysis Report 02/22/2018 Page 3 of 9

Rockbridge Reg. Pub Safety Comm Ctr Rural Broadband Network Services LLC SW Networks Shenandoah Personal Communications, LLC Shenandoah Valley Electric Cooperative Somerset, County of South Central Task Force (SCTFNET) Southern Maryland Electric Cooperative I Spotsylvania, County of Sprintcom, Inc St. Mary‘s County of (MD) Stafford, County of State of Maryland, MIEMSS Sullivan, County of T—Mobile License LLC Texas Eastern Communications, LLC The Voice Radio, LLC Thought Transmissions, LLC Torelico LLC Transcontinental Gas Pipeline Corp. US Cellular Operating Company, LLC (W1) USCOC of Cumberland, Inc. USCOC of Virginia RSA #3, Inc. USOC of Pennsylvania RSA No 10 B2 Inc. Uniti Fiber PEG, LLC Ursa Navigation Solutions, Inc. Verizon Maryland, Inc. Verizon Wireless (VAW ) LLC — Delaware/NJ Verizon Wireless (VAW ) LLC — Maryland Verizon Wireless (VAW ) LLC — W/B/V Mkts Verizon Wireless {(VAW ) LLC—Pennsylvania Verizon Wireless VAW LLC — West Virginia Verizon Wireless VAW LLC—Southern VA Virginia RSA 5 Limited Partnership Virginia Broadband, LLC Virginia Department of State Police Virginia Electric & Power Company WV DHHR BPH, Office of Ems, Com. Div. Warrenton Faugquier Joint Communications Washington Gas Light Company Washington Suburban Sanitary Commission Washington, County of Webline Holdings LLC West Virginia Educational Broadcasting Westmoreland, County of Wheeling Power Company Wicomico County Wireless Internetwork LLC World Class Wireless, LLC iSignal xWave Engineering LLC There are no unresolved interference objections with the station contained in these applications. Frequency Coordination and Interference Analysis Report 02/22/2018 Page 4 of 9

The following section presents the data pertinent to frequency coordination of the earth station that was circulated to all carriers within its coordination contours. Frequency Coordination and Interference Analysis Report 02/22/2018 Page 5 of 9

COMSEARCH Earth Station Data Sheet 19700 Janelia Farm Boulevard, Ashburn, VA 20147 {(703)726—5500 http://www.comsearch.com Date: 02/22/2018 Job Number: 180122COMSGEO9 Administrative Information Status TEMPORARY (Operation from 03/27/2018 to 04/26/2018) Call Sign | E000296 Licensee Code INTELS Licensee Name Intelsat License LLC Site Information HAGERSTOWN, MD Venue Name Latitude (NAD 83) 39° 35‘ 54.0" N Longitude (NAD 83) 77° 45‘ 35.0" W Climate Zone A Rain Zone 2 Ground Elevation (AMSL) 173.74 m / 570.0 ft Link Information Satellite Type Geostationary Mode TO — Transmit—Only Modulation Digital Satellite Arc 6° W to 149° West Longitude Azimuth Range 101.9° to 257.8° Corresponding Elevation Angles 5.3° / 5.7° Antenna Centerline (AGL) 5.79 m / 19.0 ft Antenna Information Transmit — FCC32 Manufacturer Vertex Model 9 KPC Gain / Diameter 53.5 dBi / 9.0 m 3—dB / 15—dB Beamwidth 0.36° 7 0.67° Max Available RF Power (dBW/4 kHz) 9.7 (dBW/MHz) 33.7 Maximum EIRP (dBW/A kHz) 63.2 (dBW/MHz) 87.2 Interference Objectives: Long Term —154.0 dBW/4 kHz 20% Short Term —131.0 dBW/4 kHz 0.0025% Frequency Information Transmit 61 GHz Emission / Frequency Range (MHz) 850KFXD / 5850.0 850KFXD / 6425.0 Max Great Circle Coordination Distance 536.7 km / 333.4 mi Precipitation Scatter Contour Radius 551.9 km / 342.9 mi Frequency Coordination and Interference Analysis Report 02/22/2018 Page 6 of 9

Coordination Values HAGERSTOWN, MD Licensee Name Intelsat License LLC Latitude (NAD 83) 39° 35‘ 54.0" N Longitude (NAD 83) 77° 45‘ 35.0" W Ground Elevation (AMSL) 173.74 m / 570.0 ft Antenna Centerline (AGL) 5.79 m / 19.0 ft Antenna Model Vertex 9 meter Antenna Mode Transmit6.1 GHz Interference Objectives: Long Term —154.0 dBwW/4 kHz 20% Short Term —131.0 dBW/4 kHz 0.0025% Max Available RF Power 9.7 (dBW/4 kHz) Transmit 6.1 GHz Horizon Antenna Horizon Coordination Azimuth (°) Elevation (°) Discrimination (°) Gain (dBi) Distance (km) 0 0.00 101.81 —10.00 217.18 5 0.00 96.84 —10.00 217.18 10 0.00 91.86 ~10.00 217.18 15 0.00 86.88 —10.00 217.18 20 0.00 81.90 —10.00 21718 25 0.00 76.92 ~10.00 217.18 30 0.00 71.95 ~10.00 217.18 35 0.00 66.97 —10.00 21718 40 0.00 62.00 —10.00 217.18 45 0.00 57.03 —10.00 21718 50 0.00 52.06 —10.00 217.18 55 0.00 47.09 —9.82 217.92 60 0.00 42.14 ' —8.62 223.08 65 0.00 37.19 —7.26 229.09 70 0.00 32.26 —5.72 236.20 75 0.00 27.34 —3.92 244.82 80 0.00 22 47 —1.79 254.99 85 0.00 17.65 0.83 269.27 90 0.00 12.98 4.17 289.20 95 0.00 8.66 8.56 318.38 100 0.00 5.61 13.27 536.66 105 0.00 6.15 12.28 394.45 110 0.00 9.60 745 310.72 115 0.00 13.27 3.93 287.69 120 0.00 16.89 1.31 272.02 125 0.00 20.41 —0.75 260.53 130 0.00 23.83 —2.43 251.68 135 0.00 2711 —3.83 245.27 140 0.00 30.23 —5.01 239.54 145 0.00 33.14 —6.01 234.83 150 0.00 35.82 —6.85 230.94 155 0.00 38.20 —1.55 2217.78 160 0.00 40.26 —8.12 225.25 165 0.00 41.93 —8.56 223.32 170 0.00 43.16 —8.88 221.95 175 0.00 43.92 ~9.07 221.14 180 0.00 4418 —9.13 220.87 185 0.00 43.92 — —9.07 221. 14 Frequency Coordination and Interference Analysis Report 02/22/2018 Page 7 of 9

Coordination Values HAGERSTOWN, MD Licensee Name Intelsat License LLC Latitude (NAD 83) 39° 35‘ 54.0" N Longitude (NAD 83) 77° 45‘ 35.0" W Ground Elevation (AMSL) 173.74 m / 570.0 ft Antenna Centerline (AGL) 5.79 m / 19.0 ft Antenna Model Vertex 9 meter Antenna Mode Transmit 6.1 GHz Interference Objectives: Long Term —154.0 dBW/4 kHz 20% Short Term —131.0 dBW/4 kHz 0.0025% Max Available RF Power 9.7 (dBW/4 kHz) Transmit 6.1 GHz Horizon Antenna Horizon Coordination Azimuth (°) Elevation (°) Discrimination (°) Gain (dBi) Distance (km) 190 0.00 43.16 —8.88 221.95 195 0.00 41.93 —8.56 223.32 200 0.00 40.26 —8.12 225.25 205 0.00 38.20 —1.55 227.78 210 0.00 35.81 —6.85 230.94 215 0.00 33.14 —6.01 234.83 220 0.00 30.22 —5.01 239.55 225 0.00 2711 —3.83 245.27 230 0.00 23.83 —2 43 251.67 235 0.00 20.42 —0.75 260.52 240 0.00 16.89 1.31 272.04 245 0.00 13.28 3.92 287.67 250 0.00 9.59 7.A6 310.80 255 0.00 6.33 11.96 402.56 260 0.00 6.11 12.35 518.24 265 0.00 9.18 7.93 313.99 270 0.00 13.46 3.77 286.74 275 0.00 1811 0.55 267.72 280 0.00 22.90 —2.00 253.91 285 0.00 —27.76 —4.09 244.01 290 0.00 32.66 —5.85 235.56 295 0.00 37.59 —7.38 228.57 300 0.00 42.53 —8.72 222.65 305 0.00 47 48 —9.91 217.55 310 0.00 52.44 —10.00 217 18 315 0.00 57.40 —10.00 217. 18 320 0.00 62.37 —~10.00 217 18 325 0.00 67.34 —10.00 217.18 330 0.00 72.31 —10.00 21718 335 0.00 77.28 —10.00 217.18 . 340 0.00 82.26 —10.00 21718 345 0.00 87.23 —10.00 217.18 350 0.00 92.21 —10.00 217.18 355 0.00 97.18 —10.00 21718 Frequency Coordination and Interference Analysis Report 02/22/2018 Page 8 of 9

Certification I hereby certify that | am the technically qualified person responsible for the preparation of the frequency coordination data contained in this report. | am familiar with Parts 101 and 25 of the FCC Rules and Regulations and 1 have either prepared or reviewed the frequency coordination data submitted with this report, and that it is complete and correct to the best of my knowledge and belief. Gary K. Edwards Senior Manager COMSEARCH 19700 Janelia Farm Boulevard Ashburn, VA 20147 DATED: February 22, 2018 Frequency Coordination and Interference Analysis Report 02/22/2018 Page 9 of 9

Exhibit B 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 communicate with a non—U.S. licensed space station" to serve the United States must demonstrate that U.S.—licensed satellite systems have effective competitive opportunities to provide analogues services in certain countries and must provide the same legal and technical information for the non—U.S.—licensed space station as 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." Waiver is 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 of the FCC‘s rules. With respect to Section 25.114, Intelsat seeks authority only to provide LEOP services for the Bangabandhu—1 ("BS—1") 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 BS—1 satellite, nor is Intelsat in contractual privity with that operator. Rather, an affiliate of Intelsat has a contract with Thales Alenia Space, the manufacturer of the BS—1 satellite, to conduct LEOP services. 1 47 C.F.R. § 25.137. 2 See EchoStar Satellite Operating Company Applicationfor 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, Order and Authorization, 28 FCC Red. 4229 (2013) (noting that operating TT&C earth stations in the United States with a foreign—licensed satellite does not constitute "DBS service"). > 47 C.F.R. §§ 25.137 and 25.114. * 47 CF.R. § 1.3. 5 N.E. Cellular Tel. Co. v. FCC, §97 F.2d 1164, 1166 (D.C. Cir. 1990) ("Northeast Cellular®). 6 WAIT Radio v. FCC, 419 F.2d4 1153, 1159 (D.C. Cir. 1969); Northeast Cellular, 897 F.2d at 1166.

The information required under Section 25.114 of the FCC‘s rules is not necessary to determine potential harmful interference. The Schedule S information for this satellite would pertain to the operation of the BS—1 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 of the Commission‘s rules. 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 of the agency‘s rules. 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 Section 25.137 would not be served by applying these rules to LEOP services. For example, Section 25.137(d)(4) 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 of Section 25.137(d)(4)—to provide parity between U.S.—licensed and non—U.S.—licensed commercial satellite systems in discouraging orbital location warehousing—would not be served by requiring Intelsat to post a bond to provide approximately 30 days of LEOP services to the BS—1 satellite. It is Intelsat‘s understanding that BS—1 is licensed by Bangladesh, which is a WTO—member country. Thus, the purpose of Section 25.137—to ensure that U.S. satellite operators enjoy "effective competitive opportunities" to serve certain foreign markets—will not be undermined by grant of this waiver request. Finally, Intelsat notes that it expects to operate with the BS—1 satellite using its U.S. earth station for a period of approximately 30 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 30 days, would pose undue hardship without serving underlying policy objectives. Given these particular facts, the waiver sought herein is plainly appropriate. 7 47 C.F.R. § 25.137(a). 8 See 47 C.FR. §25.137(d)(4).


Document Created: 2018-04-17 19:33:23
Document Modified: 2018-04-17 19:33:23
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