Validation of Intelsat Phase I Relocation
On November 12, 2021, the Federal Communications Commission's Wireless Telecommunications Bureau (WTB) issued an Order validating the Phase I Certification of Accelerated Relocation filed by Intelsat License LLC, debtor in possession, as amended. The action facilitates the ongoing clearing of the 3.7-4.2 GHz band (C-band) to enable flexible terrestrial wireless use across the contiguous United States.
Under the transition rules adopted in the FCC's 3.7 GHz Report and Order (GN Docket No. 18-122), eligible space station operators could voluntarily elect an accelerated relocation schedule in exchange for Accelerated Relocation Payments (ARPs). The Phase I deadline required operators to clear existing services from the lower 120 MHz (3700-3820 MHz) and install passband filters on associated incumbent earth stations in 46 of the top 50 Partial Economic Areas (PEAs) by December 5, 2021.
- Certification Filed: October 4, 2021 (amended October 15, 2021)
- Docket Numbers: GN Docket No. 18-122 and GN Docket No. 21-320
- Document Number: DA 21-1423
- Phase I Target Deadline: December 5, 2021
- Phase II Target Deadline: December 5, 2023
Intelsat Transition Showing and Clearing Performance
Intelsat submitted documentation confirming that it completed all required customer migrations to clear the lower 120 MHz of its C-band operations in the continental United States. Intelsat also verified the installation of passband filters to block 3700-3820 MHz signals across its claimed incumbent earth stations within 46 of the top 50 PEAs.
In its filing, Intelsat addressed the eight clearing criteria specified by the WTB. Intelsat indicated that although construction is underway for seven replacement C-band satellite payloads with launches scheduled for 2022 and 2023, the launch of new satellites was not required to complete its Phase I clearing milestones. Furthermore, Intelsat implemented video compression, modulation, and decoding upgrades to compress and migrate customer feeds into the upper portion of the band while maintaining service quality.
- Customer Migration: Lower 120 MHz fully cleared across CONUS operations.
- Earth Station Outreach: Ongoing identification and filtering conducted from May 2020 through September 2021.
- TT&C Consolidation: Identified telemetry, tracking, and command sites in Brewster, Washington, and Andover, Maine, which the Bureau determined to be reasonable.
Payment Disbursement and Ongoing Obligations
Because no challenges were filed against Intelsat's filing in GN Docket No. 21-320, the Bureau validated the Phase I certification. Following this validation, the Relocation Payment Clearinghouse will notify 3.7 GHz Service Licensees, who are required to pay their designated share of the Phase I Accelerated Relocation Payment to the Clearinghouse within 60 days of notice. The Clearinghouse must then disburse the funds to Intelsat within seven days of receipt.
The Bureau noted that validation is subject to specific ongoing conditions. If the Commission subsequently determines that additional earth stations, antennas, or feeds were associated with Intelsat, the operator remains obligated to complete all necessary transition remediation work in a prompt and effective manner. The Order is without prejudice to future procedures or requirements for Phase II certifications, which require clearing the full lower 300 MHz into the 4.0-4.2 GHz range by December 5, 2023.
- Clearinghouse Notice: Required promptly following Bureau validation.
- Licensee Payment Window: 60 days following notification from the Clearinghouse.
- Clearinghouse Disbursement Window: Within 7 days of receiving licensee payments.
- Remediation Requirement: Mandatory transition completion for any omitted or disputed earth stations.