Attachment SES-STA-20181022-031

SES-STA-20181022-031

DECISION submitted by FCC

Grant

0000-00-00

This document pretains to SES-STA-20181022-03183 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2018102203183_1681902

                                                            SES-STA-20181022-03183                    1B201$008367
                                                ntelsat License LLC



                                                                                                                                              Approved by 0MB
                                                                                                                                                     3060—0678

                               APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY



APPLICANT 1NFORMATIONEnter a description of this application to identifi it on the main menu:
Request for further Extension STA to Continue Operating 7.3m S—band Antenna at Paumalu, Hawaii
    1. Applicant

              Name:        Intelsat License LLC                 Phone Number:                                     J7o3_559_7848

              DBA Name:                                         Fax Number:                                    f703_559_8539

              Street:      do Intelsat US LLC                   E—Mail:                                           Jsusan.crandall@intelsat.com
                           7900 Tysons One Place
              City:        McLean                              [State:                                             VA

              Country:     USA                                 [Ziflcode:                                          22102         —5972

              Attention:   Susan H. Crandall


                                                                                                      file #         -
                                                                                                               SE5 —)c //t’ 2             -




                                                                                                      Call Sign              Grant Date____________
                                                                                                      (or other identifier
                                                                                                                             Term Dates

                                                                         GRANTED
                                                                      ifliLl   T:1   ‘)fl[I 1uieaii




1


                                                                                                                                                       4




    2. Contact

                 Name:         Cynthia J. Grady                      Phone Number:                          202—559—6949
                 Company:      Intelsat US LLC                        Fax Number:                           703—559—8539
                 Street:       7900 Tysons One Place                 E—Mail;                                cynthia.grady@intelsat.com


                 City:         McLean                                 State:                                VA
                                                                                                            22102       —
                 Country:      USA                                    Zipcode:
                 Attention:                                           Relationship:                         Legal Counsel


    (If your application is related to an application filed with the Commission, enter either the file number or the lB 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?
                                                          If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
    ® IfYes, complete and attach FCC Form 159.
        Govermnental Entity             Noncommercial educational licensee
    0
        Other(please explain);
    0
    4b. Fee Classification    CGX   —   fixed Satellite Transmit/Receive Earth Station
    5. Type Request


        Use Prior to Grant                               t3 Change Station Location                           Other
    0

    6. Requested Use Prior Date


    7. CityPaumalu                                                               8. Latitude
                                                                                 (dd mm ss.s h)   21   40    14.2   N



2


                                                                                                                                                      3




    9. State   HI                                                              10. Longitude
                                                                               (ddmmss.sh)        15$   2   7.$   W

    11. Please supply any need attachments.
    Attachment 1: STA Request                         Attachment 2:                                      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 an additional 30 days of STA previously granted to
         Intelsat to utilize a 7.3m S—band antenna located at its Paumalu, Hawaii teleport to
         provide TT&C restoration services for the EUTELSAT—WA fS3031) satellite during its drift
         to,   and operation at,           132.85 W.L.




    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 198$, 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                                                            Senior Counsel, Intelsat US LLC
               WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND I OR IMPRISONMENT
                      (U.S. Code, Title 1$, 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).




3


I




         4-
         Ott,
                    C
         E.0        0
         4.         C
         0
           .2       n
         dO
         f:tt,
         U
                    4
                    C




         t     0




         dO
         ttt


         00
         0=




    SU   00
         4-    0
    4-
               -o
               S
               d


                                                                        File #5-,- ‘z- c3 / 8.


                                                                        Call Sign                Grant Date_1
                                                                        (or other idetititier)
Applicant:    Intelsat License LLC                                                               TerniDat
                                                                                     /     /
File No:      SES-STA-20 181022-03183             GRANTED               1ioHi.._Z9                   ‘I’o:
Call Sign:    None                              Iii winational Bureau

Intelsat License LLC (“Intelsat”) is granted of special temporary Authority (“STA”) to operate
its 7.3m S-band antenna in Paumalu, HI to test telemetry, tracking, and command (TT&C)
restoration services for the EUTELSAT-WA ($3031) satellite at 132.85° W.L. on center
frequencies 2085.688 MHz (Earth-to-space) and 2265.0 MHz (space-to-Earth) under the
following conditions:

1. Operations shall be on an unprotected, non-interference basis with respect to other
   authorized stations, including federal stations.
2. Uplink operation from Paumalu, HI ground station to EUTELSAT-WA (S3031) shall not
   occur when the NASA International Space Station (ISS) (NORAD designation 25544 or
   international spacecraft ID 1998-067A) is within 10 degrees of Paumalu, HI ground station
   antenna boresight.
3. Operations using 2085.688 MHz or 2265.0 MHz shall be pre-coordinated with the NASA
   GSFC Spectrum Manager, Scott Galbraith at 301-286-5089 or
   VINCENT.S.GALBRAITH@NASA.GOV, at least 7 days prior to operation.
4. Due to potential harmful interference to naval activities, Intelsat License LLC RF operations
   plan shall be submitted as soon as possible to the Naval Surface Warfare Center, Dahlgren
   Division (NSWCDD), Mr. James Moneyhon (540) 653-3477, or
   james.moneyhon@navy.mil, for assessment.
5. Any future requests or extensions will need to submit applications to the FCC to be re
   coordinated with NTIA.
6. Any action taken or expense incurred as a result of operations pursuant to this STA is solely
   at Intelsat’s risk.
7. Operations with the EUTELSAT-WA ($3031) satellite from the expiration of SES-STA
   20180912-02660 to the beginning of this authorization were authorized under 47 CFR §
    1.62.
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.


          INTELSAT
               Envision. Connect. Transform.



October 16, 2018

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554

         Re:       Request for Further Extension of Special Temporary Authority
                   7.3rn S-band Antenna, Paumalu, Hawaii

Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”) herein requests an additional 30 days of Special Temporary
Authority (“STA”)t previously granted to Intelsat to utilize a 7.3m S-band antenna located at its
Paumalu, Hawaii teleport to provide telemetry, tracking, and command (‘Tr&C”) restoration services
for the EUTELSAT-WA (S3031)2 satellite during its drift to, and operation at, 132.85° W.L.3
EUTELSAT-WA is now on-station at 132.85° W.L. Restoration services include bi-annual testing,
which will last approximately two hours per test, and TT&C services in the event the satellite’s
primary Ku-band TT&C experiences an anomaly.

The EUTELSAT-WA operations will continue to be performed in the following frequencies:
2085.688 MHz in the uplink (RHCP and LHCP) and 2265.0 MHz in the downlink (RHCP and
LHCP). The drift operations will be coordinated with all operators of satellites that use the same
frequency bands.4 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.

The 24x7 contact information for the EUTELSAT-WA TT&C operations is as follows:

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

  Intelsat has filed its STA request, an FCC Form 159, a $210.00 filing fee, and this supporting letter
electronically via the International Bureau’s Filing System (“IBFS”).
2
 See Policy Branch Information; Actions Taken, Report No. SAT-0 1309, File No. SAT-PPL
20180302-00018 (Apr. 6, 2018) (Public Notice).
 See Intelsat License LLC, Request for STA Extension to Continue Operating 7.3m S-band Antenna
at Paumalu, Hawaii, File No. SES-STA-20180912-02660 (stamp grant issued Sept. 21, 2018 by Paul
Blais); Satellite Communications Services Information; Actions Taken, Report No. SES-02090, File
No. SES-STA-201$0711-01659 (Aug. 22, 2017) (Public Notice).
    Telespazio, the manager of the EUTELSAT-WA mission, will handle the coordination.
ntesat US CCC
7900 lysans One Place, McLean, VA 22102-5972 USA www.lntelsatcom T +1 703-559-6800


I




    Ms. Marlene H. Dortch
    October 16, 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 further extension request, Intelsat incorporates by reference Exhibit A from
    its original request, 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 commercial terrestrial facility.

    The U.S. Table of Frequency Allocations5 allocates the 2025-2 100 MHz band for Fixed, Mobile, and
    Federal use. The 2200-2290 MHz is allocated to Federal services (Space Operations, Earth
    Exploration-Satellite, fixed, Mobile, and Space Research). In order to ensure Intelsat can provide
    TT&C restoration services in these bands, Intelsat requests waiver of the U.S. Table of Frequency
    Allocations to permit its 7.3m S-band antenna in Paumalu, Hawaii to communicate with EUTELSAT
    WA for the limited purpose of emergency Tf&C restoration.

    The Commission may grant a waiver for good cause shown.6 The Commission typically grants a
    waiver where the particular facts make strict compliance inconsistent with the public interest.7 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.8 Waiver is therefore appropriate if
    special circumstances warrant a deviation from the general rule, and such a deviation will serve the
    public interest. As shown below, good cause exists here to grant a waiver to allow Intelsat’s 7.3m 5-
    band antenna to provide TT&C restoration services for EUTELSAT-WA using three small carriers
    within the 2025-2 100 MHz and 2200-2290 MHz bands. Additionally, the anticipated operation of
    these carriers will be for a few hours of testing annually, as prolonged transmission would only occur
    in cases of spacecraft anomaly.

    Good cause exists to waive the Table of Allocations for 2025-2 100 MHz and 2200-2290 MHz
    frequency bands. The EUTELSAT-WA satellite is designed with its contingency TT&C frequencies
    in S-band, consistent with the allocation of ITU Region 1, where the satellite previously operated. As
    the spacecraft is now in orbit, it is not possible to change the contingency TT&C frequencies.

    Moreover, grant of this waiver is consistent with the Commission’s precedent. A waiver of the Table
    of Allocations is generally granted “when there is little potential interference into any service
    authorized under the Table of Frequency allocations and when the nonconforming operator accepts



        See 47 C.F.R.   § 2.106.
    647CfR §1.3.                                                       V




        N.E. Cellular Tel. Co. v. FCC, 897 f.2d 1164, 1166 (D.C. Cir. 1990) (“Northeast Cellular”).
    8
        WAIT Radio v. FCC, 41$ f.2d 1153, 1159 (D.C. Cir. 1969); Northast Cellular, $97 F.2d at 1166.


Ms. Marlene H. Dortch
October 16, 2018
Page 3
                                                   a




any interference from authorized services.”9 As noted above, in the 2025-2 100 MHz band, the
Paumalu, Hawaii S-band antenna will transmit only a few hours per year unless there is an anomaly
on the spacecraft. In the event an anomaly occurs, all efforts will be made to immediately regain use
of the Ku-band rr&c. Additionally, in 2200-2290 MHz band, Intelsat agrees to accept any level of
interference into this earth station from Federal users in the band.1°

Grant of this STA further extension request will allow Intelsat to continue to be able to provide
emergency restoration TT&C services to the EUTELSAT-WA spacecraft, which will ensure safe
station-keeping of the satellite and thereby promotes the public interest.

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

                                                   a


Respectfully submitted,

/s/ Cynthia I Grady

Cynthia J. Grady                                                    .•


Senior Counsel
Intelsat US LLC                                           -




cc: Paul Blais
                                                              1’




                                                    a




  See The Boeing Company, Order and Authorization, 16 FCC Red 22645, 22651 (Int’l Bur. & OFT
2001); Application ofFugro-Chance, Inc. for Blanket Authority to Construct and Operate a Private
Network ofReceive-Only Mobile Earth Stations, Order and Authorization, 10 FCC Red 2860 (Int’l
But. 1995) (authorizing MSS in the C-band); see also Application ofMotorola Satellite
Communications, Inc. for ModfIcation ofLicense, Order and Authorization, 11 FCC Red 13952-
13956 (Int’l Bur. 1996) (authorizing service to fixed terminals in bands allocated the mobile satellite
service).
10
   The Commission previously has authorized temporary commercial use of 2200-2290 MHz on this
basis. See Policy Branch Information; Actions Taken, Report No. SES-02071, File No. SES-STA
20180530-01000 (June 20, 2018) (Public Notice).
                                                                    ,,



Document Created: 2019-05-18 22:18:34
Document Modified: 2019-05-18 22:18:34

© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC