Intelsat License LLC
Washington, D.C. 20554
July 9, 2013
Ms. Susan H. Crandall
Intelsat License LLC
3400 International Drive, N.W.
Washington, DC 20008-3006
Call Sign: KA264
File No.: SES-MOD-20130117-00057
Dear Ms. Crandall:
On January 17, 2013, Intelsat License LLC, (Intelsat) filed the above-captioned
application to (1) to relocate its fixed earth station from Clarksburg, MD, to Hagerstown,
MD, and (2) to add new emission designators and related service and (3) remove certain
previously licensed points of communication that are no longer needed or are included
within ALSAT authority. For the reasons stated below, we dismiss the application as
defective, without prejudice to re-filing.1
Section 25.112(a) of the Commission's rules, 47 C.F.R. 25.112(a), requires the
Commission to return as unacceptable for filing any earth station application that is not
substantially complete, contains internal inconsistencies, or does not substantially comply
with the Commission's rules. For the reasons stated below, Intelsat's application has the
following deficiency, which renders the application unacceptable and subject to
In item E21 of Schedule B to form 312 Intelsat listed "ALSAT" as the only point of
communication and in item E43/44 listed frequencies outside the 5850-6425 MHz (Earth-
to-space) and 3625-4200 MHz (space-to-Earth) frequency bands. In its attachment
named Exhibit A, Intelsat stated, "Additionally, in Schedule B, Intelsat has removed
certain previously licensed points of communication that are no longer needed or are
included within ALSAT authority." Authorizations to communicate with ALSAT may
be granted only in cases where the earth station is eligible for "routine processing".2 The
If Intelsat re-files an application in which the deficiencies identified in this letter have been corrected but
otherwise identical to the one dismissed, it need not pay an application fee. See 47 C.F.R. 1.1111(d).
2 See Amendment of the Commission's Regulatory Policies to Allow Non-U.S. Licensed Space Stations to
Provide Domestic and International Services in the United States, IB Docket No. 96-111, First Order on
Reconsideration, 15 FCC Rcd 7207 (1999), at 7213 13 (stating that licenses for "routine" earth stations
providing fixed-satellite service in the conventional C-band or conventional Ku-band may specify
Federal Communications Commission DA 13-1537routine processing criteria for an earth station communicating in C-band frequencies are
specified in Section 25.212(c) of the Commission's rules, 47 C.F.R. 25.212 (c).
Frequencies outside the 5925-6425 MHz (Earth-to-space) and 3700-4200 MHz (space-to-
Earth) frequency bands are not authorized for routine licensing. Because only earth
stations that meet routine licensing criteria may be granted ALSAT as a point of
communication, Intelsat's application is internally inconsistent and does not substantially
comply with the Commission's rules.
Accordingly, pursuant to Section 25.112(a)(1) of the Commission's rules, 47 C.F.R.
25.112(a)(1), and Section 0.261of the Commission's rules, 47 C.F.R. 0.261, we
dismiss the application without prejudice to re-filing.
Chief, Systems Analysis Branch
"ALSAT" as authorized points of communication, and noting that a "routine" earth station is one that
operates consistently with the technical requirements of Part 25).
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