Attachment SES-STA-20190516-006

SES-STA-20190516-006

DECISION submitted by FCC

Grant

0000-00-00

This document pretains to SES-STA-20190516-00667 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2019051600667_1834873

SESSTA20190516O667 182019001565 KL92 Intelsat License LLC Approved by 0MB 3060—0678 APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY APPLICANT INFORMATIONEnter a description of this application to identify it on the main mentt: 180—day STA To Use Castle Rock, Colorado Earth Station KL92 to Provide LEOP and TT&C Services for the Eutelsat—7C 1. Applicant Name: Intelsat License LLC Phone Number: 703—559—7848 DBA Name: Fax Number: 703—559—8539 Street: do Intelsat US LLC E—Mail: susan.crandall@inteIsat.com 7900 Tysons One Place City: McLean State: VA Country: USA Zipcode: 22102 —5972 Attention: Susan H. Crandall 7i File # s5T0t%” Call SIEn_kL9’%Grant Date______ (or other identifier) Ic Dates From:______ ,‘yro:_______ GRANTED International Bureau Approved: %€J’? 1

2. Contact Name: Cynthia J. Grady Phone Number: 703—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 Country: USA Zipeode: 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 TB 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 Yes, complete and attach FCC Form 159. If No, indicate reason for fee exemption (see 47 C.f.R.Section 1.1114). • Governmental Entity Noncoinmercial educational licensee Other(please explain): 4b. Fee Classification CGX — Fixed Satellite Transmit/Receive Earth Station 5. Type Request Use Prior to Grant Change Station Location Other 0 0 6. Requested Use Prior Date 7. CityCastle Rock 8. Latitude (dd mm ss.s h) 39 16 38.0 N 2

9. State CO 10. Longitude (dd mm ss.s h) 104 4$ 26.9 W 1 1. 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 180 days, commencing upon grant, to use its Castle Rock, Colorado Ku-band earth station (Call Sign KL92) to provide launch and early orbit phase service for Eutelsat—7C, and telemetry, tracking, and command services during in-orbit testing and drifting of the satellite to 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 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 1 001), 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

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 PRAfcc.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 0MB control number or if we fail to provide you with this notice. This collection has been assigned an 0MB 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. 4

12. Description Intelsat License LLC herein requests a grant of Special Temporary Authority for 180 days, commencing upon grant, to use its Castle Rock, Colorado Ku—band earth station (Call Sign KL92) to provide launch and early orbit phase service for Eutelsat—7C, and telemetry, tracking, and command services during in—orbit testing and drifting of the satellite to its final location. 5

it &W Jcirhc #5Es -57,c’-0201 ?/-äá Call Sign k’L ?Grant Date O/O (or other identifier) & Dates Applicant: Intelsat License LLC file No.: SES-STA-20190516-00667 GRANTED Call Sign: KL92 1ntemationa Bureau Special Temporary Authority Intelsat License LLC (“Intelsat”) was granted special temporary authority for 180 days, beginning August 7, 2019, to operate its fixed earth station in Castle Rock, CO to provide launch and early orbit phase (LEO?) services for the Eutelsat-7C satellite and conduct telemetry, tracking and command services during in-orbit testing and as it drifts to its final orbital location. LEOP operations will be performed on the following center frequencies: 11199.0 MHz, 11200.6 MHz, 11698.2 MHz, and 11699.0 MHz (space-to-Earth); and 13750.40 MHz, 13999.25 MHz, 14250.00 MHz, and 14499.80 MHz (Earth-to-space) under the following conditions: 1. Operations will not exceed the operational power levels and parameters. 2. All operations under this grant of special temporary authority shall be on an unprotected and non-harmful interference basis. Intelsat shall not cause harmful interference to and shall not claim protection from interference caused to it by, any other lawfully operating radio communication system. 3. In the event of any harmful interference under this grant of special temporary authority, Intelsat must cease operations immediately upon notification of such interference, and must inform the Commission, in writing, immediately of such an event. 4. 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’s Eutelsat-7C mission is Ph.: (703) 559-7701-East Coast Operations Center (primary); (3 10) 525-5591-West Coast Operations Center (back-up). Request to speak with Harry Burnham or Kevin Bell. 5. Any action taken or expense incurred as a result of operations pursuant to this special temporary authority is solely at Intelsat’s risk. 6. Intelsat’s operations to the date of this grant were authorized pursuant to Section 1.62 of Commission’s rules 47 C.F.R. of Commission’s rules 47 C.F.R. 7. Grant of this authorization is without prejudice to any determination that the Commission may make regarding pending or future Intelsat applications. This action is issued pursuant to Section 0.26 1 of the Commission’s rules on delegated authority, 47 C.F.R. §0.261, and is effective immediately.

INTELSAT Envision. Connect. Transform. May 16, 2019 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Request for Special Temporary Authority Castle Rock, Colorado Earth Station KL92 Dear Ms. Dortch: Intelsat License LLC (“Intelsat”) herein requests a grant of Special Temporary Authority (“STA”)’ for 1 80 days, commencing upon grant, to use its Castle Rock, Colorado Ku-band earth station (Call Sign KL92) to provide launch and early orbit phase (“LEOP”) service for Eutelsat-7C, and telemetry, tracking, and command (“TT&C”) services during in-orbit testing and drifting of the satellite to its final location. Eutelsat-7C is expected to launch on June 20, 2019.2 Intelsat expects to provide LEOP and TT&C services for approximately 210 days.3 The Eutelsat-7C LEOP operations will be performed at the following frequencies: 11199.0 MHz, 11200.6 MHz, 11698.2 MHz, and 11699.0 MHz (LHCP) in the downlink; and 13750.40 MHz, 13999.25 MHz, 14250.00 MHz, and 14499.80 MHz (R}ICP) in the uplink. The LEOP operations will be coordinated with all operators of satellites that use the same frequency bands and are in the LEOP path.4 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 Eutelsat-7C LEOP mission is as follows: 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 The lOT location for Eutelsat-7C, which Intelsat understands is licensed by France, will be I •70 E.L. The satellite’s final location will be 7° E.L. Intelsat is seeking authority for 180 days to accommodate the longer orbit-raising time period required for an electric propulsion satellite. SSL, the manager of the Eutelsat-7C mission, will handle the coordination. Intelsat US LLC 7900 Tysons One Place. McLean, VA 2202-5972 USA www.lntelsat.com T +1 703-5S9-6800

Ms. Marlene H. Dortch May 16, 2019 Page 2 Ph.: (703) 559-7701 — East Coast Operations Center (primary) (310) 525-5591 — West Coast Operations Center (back-up) Request to speak with Harry Bumham or Kevin Bell. In further support of this request, Intelsat herewith attaches Exhibits A and B, which contain a 13 GHz 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. Finally, Intelsat clarifies that during the Eutelsat-7C LEOP mission SSL will 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 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 Eutelsat-7C satellite and safely insert it into the geostationary arc. This will help provide services at the 70 E.L. location and thereby promotes the public interest. Please direct any questions regarding this STA request to the undersigned at (703) 559-6949. Respectfully submitted, /s/Cynthiai Grady Cynthia I. Grady Senior Counsel Intelsat US LLC cc: Paul Blais

Exhibit A Intelsat License ICC Castle Rock, Colorado NEC Cassegrain 12.5 Meter Earth Station 1. Background This Exhibit is presented to demonstrate the extent to which the Intelsat License LLC (“Intelsat”) satellite earth station in Castle Rock, Colorado 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° 16’ 38” N, 104° 48’ 26.9” W Satellite Arc Range for Earth Station: Eutelsat-7C at 32.6°W to 177°W Frequency Band: 13.75-14.00 GHz Polarizations: Linear & Circular Emissions: 1MOOF2D Modulation: FM/BPSK/NRZ-L Maximum Aggregate Uplink EIRP: 92dBW for all Carriers Transmit Antenna Characteristics Antenna Size: 12.5 Meters in Diameter Anenna Type/Model: NEC Cassegrain Gain: 64dBi RF Power into Antenna Flange: 28 dBW or 5 UBW/4kHz Minimum Elevation Angle: 5.02° @ 101.48° Azimuth 5.03° @ 258.51° 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 fF55”) on a co-primary basis with the radiolocation operations and provides for an interference protection level of -167 dBW/m2/4kHz. The closest distance to the shoreline from Castle Rock, Colorado earth station is approximately 1350 km. Therefore, there should be no interference to the US Navy RADAR from the Castle Rock, Colorado facility due to distance and terrain between Castle Rock and the shoreline. 3. Potential Impact to NASA’s Tracking and Data Relay Satellite System The geographic location of the Intelsat earth station in Castle Rock, Colorado 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 Castle Rock, Colorado. The TDRSS space-to-space link in the 13.772 to 13.778 GHz band is assumed to be protected if an earth station produces and EIRP of less than 71 dBW/6MHz in this band. The 12.5 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 Castle Rock, Colorado 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 Castle Rock, Colorado site earth station should occur.

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.1 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.2 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, Jntelsat respectfully requests a waiver of Sections 25.137 and 25.114 of the Commission’s rules.3 The Commission may grant a waiver for good cause shown.4 The Commission typically grants a waiver where the particular facts make strict compliance inconsistent with the public interest.5 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.6 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 Eutelsat-7C satellite. The information sought by Section 25.114 is 1 47 C.F.R. § 25.137. 2 See EchoStar Satellite Operating Company Application for Special Temporary Authority Related to Moving the EchoStar 6 Satellitefrom the 77° WL. Orbital Location to the 96.2° WL. Orbital Location, and to Operate at the 96.2° WL. Orbital Location, Order and Authorization, 28 FCC Rcd. 4229 (2013) (noting that operating TT&C earth stations in the United States with a foreign-licensed satellite does not constitute “DBS service”). 47C.F.R. §‘25.137and25.114. ‘I 47C.F.R.1.3. N.E. Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990) (“Northeast Cellular”). 6 WAITRadio v. FCC, 419 F.2d 1153, 1159 (D.C. Cir. 1969); Northeast Cellular, 897 F.2d at 1166.

Exhibit B Request for Special Temporary Authority Page 2 not relevant to LEOP services. Moreover, Intelsat does not have—and would not easily be able to obtain—such information because Jntelsat is not the operator of the Eutelsat 7C satellite. Intelsat has a contract with SSL, the manufacturer of the Eutelsat-7C satellite, to conduct LEOP and TT&C services. 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 Eutelsat-7C 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 and TT&C during in- orbit testing and drifting. hi 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 as well as in-orbit testing and drifting to the satellite’s final location. Moreover, as with any STA, Intelsat will perform the 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 or TT&C 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.7 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.8 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 seven months of LEOP and TT&C services to the Eutelsat-7C satellite. It is Intelsat’s understanding that Eutelsat-7C is licensed by France, 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. 747 C.F.R. 25.137(a). $ § See 47 C.F.R. §25.137(d)(4).

Exhibit B Request for Special Temporary Authority Page 3 Finally, Intelsat notes that it expects to operate with the Eutelsat-7C satellite using its U.S. earth station for a period of approximately seven months. Requiring Jntelsat 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 seven months, would pose undue hardship without serving underlying policy objectives. Given these particular facts, the waiver sought herein is plainly appropriate.


Document Created: 2019-08-28 12:01:51
Document Modified: 2019-08-28 12:01:51
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