Attachment STA Request

This document pretains to SES-STA-20190717-00992 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2019071700992_1797010

July 16, 2019

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

       Re:      Request for Extension of Special Temporary Authority
                Hagerstown, Maryland Earth Station KA258

Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”) herein requests an additional 30 days of Special Temporary
Authority (“STA”)1 previously granted to Intelsat2 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).3 Specifically, Intelsat seeks to provide launch and
early orbit phase (“LEOP”) services; TT&C during in-orbit testing (“IOT”) at 134.75° W.L.;4 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. T16 was launched on 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.



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 Communications Services Information, Actions Taken, Report No. SES-02174, File No.
SES-STA-20190603-00722 (June 26, 2019) (Public Notice).
3
 See Satellite Policy Branch Information, Space Station Applications 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.).
4
 See Satellite Policy Branch Information, Actions Taken, Report No. SAT-01394, SAT-STA-
20190508-00037 (May 31, 2019) (Public Notice).


Ms. Marlene H. Dortch
July 16, 2019
Page 2




The T16 TT&C operations will continue to 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 operations will be coordinated with all operators of satellites that use the same
frequency bands and are in the drift path.5 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 incorporates by reference Exhibit A6 included with its
original STA 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 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.




5
    Airbus, the mission manager of the T16 mission, will handle the coordination.
6
    See supra n. 2.


Ms. Marlene H. Dortch
July 16, 2019
Page 3




Grant of this STA extension 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.

For the reasons set forth herein, Intelsat respectfully requests that the Federal Communications
Commission grant this STA extension request. Please direct any questions 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: 2019-07-16 12:45:55
Document Modified: 2019-07-16 12:45:55

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