Attachment STA Request

This document pretains to SES-STA-INTR2019-02718 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTAINTR201902718_1799157

July 17, 2019

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

       Re:      Request for Extension of Special Temporary Authority
                Ellenwood, Georgia Earth Station E170122

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 Ellenwood, Georgia Ku-band earth
station (Call Sign E170122) to provide launch and early orbit phase (“LEOP”) service for Eutelsat-7C,
and telemetry, tracking, and command (“TT&C”) services during in-orbit testing (“IOT”) and drifting
of the satellite to its final location. Eutelsat-7C was launched on June 20, 2019.3 Intelsat expects to
provide LEOP and TT&C services for approximately 210 days.4

The Eutelsat-7C LEOP operations will continue to 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 (RHCP) 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


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-02174, File No.
SES-STA-20190516-00669 (June 26, 2019) (Public Notice).
3
 The IOT location for Eutelsat-7C, which Intelsat understands is licensed by France, will be 1.7° E.L.
The satellite’s final location will be 7° E.L.
4
 Intelsat is concurrently seeking authority for 180 days to accommodate the longer orbit-raising time
period required for an electric propulsion satellite. See Satellite Communications Services, Satellite
Radio Applications Accepted For Filing, Report No. SES-02170, File No. SES-STA-20190516-00668
(June 12, 2019) (Public Notice).


Ms. Marlene H. Dortch
July 17, 2019
Page 2

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 Eutelsat-7C LEOP 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.

In further support of this request, Intelsat incorporates by reference Exhibits A and B6 included with
its original request, 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 extension request will allow Intelsat to help safely insert the Eutelsat-7C satellite
into the geostationary arc. This will help provide services at the 7° E.L. 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




5
    SSL, the manager of the Eutelsat-7C mission, will handle the coordination
6
    See supra n. 2.



Document Created: 2019-07-17 12:28:17
Document Modified: 2019-07-17 12:28:17

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