Attachment STA Request

This document pretains to SES-STA-20190603-00722 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2019060300722_1715681

June 3, 2019

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 KA258

Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”) herein requests an expedited grant of Special Temporary Authority
(“STA”)1 for 30 days, commencing June 20, 2019, to use its Hagerstown, Maryland Ku-band earth
station (call sign KA258) to provide ground segment telemetry, tracking, and command (“TT&C”)
services to the T16 satellite (call sign S3039).2 Specifically, Intelsat seeks to provide launch and early
orbit phase (“LEOP”) services; TT&C during in-orbit testing (“IOT”) at 134.75° W.L.;3 TT&C during
the satellite’s drift from its IOT location to its final location of 100.85° W.L.; and backup TT&C on-
station at 100.85° W.L. The launch is currently scheduled for June 20, 2019 and the LEOP, IOT, and
drift are expected to take approximately 45 days. Backup TT&C services at 100.85° W.L. will be
provided indefinitely and Intelsat will be filing for authority to provide this service on a permanent
basis.

The proposed operations will be performed using the following frequencies: 17789.0 MHz and
17791.0 MHz (RHCP) in the uplink; and 12697.0 MHz and 12698.0 MHz (RHCP) in the downlink.
The proposed operations will be coordinated with all operators of satellites that use the same

1
  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 Satellite Policy Branch Information, Actions Taken, Report No. SAT-01381, SAT-RPL-
20180913-00071 (Mar. 29, 2019) (Public Notice); see also Satellite Policy Branch Information, Space
Station Application Accepted for Filing, Report No. SAT-01392, SAT-MOD-20190508-00036 (May
24, 2019) (Public Notice) (seeking modification to change the assigned orbital location of T16 to
100.85° W.L.)
3
 See Satellite Policy Branch Information, Actions Taken, Report No. SAT-01394, SAT-STA-
20190508-00037 (May 31, 2019) (Public Notice).


Ms. Marlene H. Dortch
June 3, 2019
Page 2




frequency bands and are in the drift path.4 All operators of potentially affected satellites 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 T16 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.

The proposed TT&C operations at 100.85° W.L. will be consistent with the coordination agreements
for the nominal 100.85° W.L. orbital location entered into by DIRECTV Enterprises, LLC – the
licensee of T16. 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 hereby 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. 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 T16 LEOP mission, Airbus will serve as the mission manager.
Airbus 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 Airbus. 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.




4
    Airbus, the mission manager of the T16 mission, will handle the coordination.


Ms. Marlene H. Dortch
June 3, 2019
Page 3




Grant of this STA request will allow Intelsat to help safely launch, test, deploy, and station-keep T16.
This, in turn, will help support direct-to-home services from the 100.85° W.L. orbital 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/ Cynthia J. Grady

Cynthia J. Grady
Senior Counsel
Intelsat US LLC

cc: Paul Blais



Document Created: 2019-06-03 14:10:01
Document Modified: 2019-06-03 14:10:01

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