Attachment STA Request

This document pretains to SES-STA-20181011-03177 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2018101103177_1552405

October 11, 2018

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

         Re:    Request for Extension of Special Temporary Authority
                Castle Rock, Colorado Earth Station KL92

Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”) herein requests an additional 30 days of Special Temporary
Authority (“STA”)1 previously granted Intelsat to continue using its Castle Rock, Colorado Ku-band
earth station—call sign KL92—to provide launch and early orbit phase (“LEOP”) services for the
Azerspace-2 satellite.2 Azerspace-2 was launched on September 25, 2018.3 Intelsat expects the
LEOP period to last approximately 180 days and has a pending 180-day STA request for this antenna
to accommodate the longer orbit-raising time period required for an electric propulsion satellite.4

The Azerspace-2 LEOP operations will continue to be performed at the following frequencies:
14497.50 MHz and 14499.5 MHz (CP) in the uplink; and 12745.0 MHz, 12745.5 MHz, 12748.25
MHz, and 12748.75 MHz (CP) in the downlink. The LEOP operations will continue to be
coordinated with all operators of satellites that use the same frequency bands and are in the LEOP
path.5 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 Azerspace-2 LEOP mission is as follows:

Ph.:     (703) 559-7701 – East Coast Operations Center (primary)

1
  Intelsat has filed its STA request, FCC Form 159, a $210.00 filing fee, and this supporting letter
electronically via the International Bureau’s Filing System (“IBFS”).
2
 See Satellite Communications Services Information; Actions Taken, Report No. SES-02096, File No.
SES-STA-20180828-02516 (Sept. 12, 2018) (Public Notice).
3
 The in-orbit testing location for Azerspace-2, which Intelsat understands is licensed by Azerbaijan,
will be 63.8° E.L. The final location of Azerspace-2 will be 45.0° E.L.
4
 See Satellite Communications Services; Satellite Radio Applications Accepted for Filing, Report No.
SES-02095, File No. SES-STA-20180828-02526 (Sept. 12, 2018) (Public Notice).
5
    SSL, the manager of the Azerspace-2 LEOP mission, will handle the coordination.


Ms. Marlene H. Dortch
October 11, 2018
Page 2




          (310) 525-5591 – West Coast Operations Center (back-up)

Request to speak with Harry Burnham or Kevin Bell.

In further support of this extension request, Intelsat incorporates by reference Exhibit A, submitted
with its original STA request,6 which contains requests for waiver. 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.

Finally, Intelsat clarifies that during the Azerspace-2 LEOP mission, SSL will continue to serve as the
mission manager. SSL 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 SSL. Intelsat will
continue to 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 extension request will allow Intelsat to continue helping with the launch of the
Azerspace-2 satellite. This, in turn, will help provide additional capacity from the 45.0º E.L. orbital
location and thereby promotes the public interest.

Please direct any questions regarding this STA extension request to the undersigned at (703) 559-
6949.

Respectfully submitted,

/s/ Cynthia J. Grady

Cynthia J. Grady
Senior Counsel
Intelsat US LLC



cc: Paul Blais




6
    See supra n. 2.



Document Created: 2018-10-11 08:49:41
Document Modified: 2018-10-11 08:49:41

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