Final Transition Plan GN Docket Nos

Home , Galaxy (satellite), Galaxy 15, Galaxy 17, Galaxy 18, Galaxy 19, Galaxy 23

August 14, 2020

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

Re: Submission for the Record – Final Transition Plan GN Docket Nos. 18-122, 20-173

Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”)1 submits its final C-band Transition Plan pursuant to 47 C.F.R. § 27.1412(d) and the Federal Communications Commission’s (the “Commission”) March 3, 2020 Report and Order.2

This final Transition Plan contains changes and clarifications that reflect the feedback and comments that the Commission staff provided on Intelsat’s initial Transition Plan.3 More detailed descriptions of the changes made since Intelsat’s initial submission on June 19, 2020 are listed in an itemized Catalog of Revisions found at the beginning of the final Transition Plan.

Intelsat looks forward to continued engagement with all C-band stakeholders in implementing this Transition Plan. Please contact the undersigned with any questions regarding this matter.

1 Intelsat License LLC, an FCC satellite licensee, and its affiliated entity Intelsat US LLC, which provides operational services to Intelsat License LLC, are collectively referred to in the Transition Plan as “Intelsat.” Intelsat filed an election form to accept the Commission’s accelerated relocation framework and deadlines on May 26, 2020. 2 See Expanding Flexible Use of the 3.7 to 4.2 GHz Band, Report and Order and Proposed Modification, 35 FCC Rcd. 2343, paras. 302-06 (2020). 3 See generally Intelsat License LLC Notice of Ex Parte Meeting (Aug. 10, 2020), https://ecfsapi.fcc.gov/file/10810600724158/Ex%20Parte%20Meeting%20-%20Intelsat%208-10- 2020.pdf; Intelsat License LLC Notice of Ex Parte Meeting (Aug. 4, 2020), https://ecfsapi.fcc.gov/file/1080467946484/Ex%20Parte%20Meeting%20Restoration%20Service% 20and%20Cost%20Allocation%20-%20Intelsat%208-4-2020.pdf; Intelsat License LLC Notice of Ex Parte Meeting (July 27, 2020), https://ecfsapi.fcc.gov/file/10727200387174/Ex%20Parte%20Meeting%20Intelsat%20Transition% 20Plan%20-%20Intelsat%207-27-2020.pdf.

Respectfully submitted,

Intelsat License LLC

Michelle V. Bryan Secretary, Intelsat License LLC, and Executive Vice President, General Counsel and Chief Administrative Officer, Intelsat US LLC 7900 Tysons One Place McLean, VA 22102-5972

Enclosures

Intelsat C-Band Clearing Transition Plan (Final) Appendices: Earth Station Listings

Intelsat C-Band Clearing Transition Plan

8/14/2020

1 Table of Contents Catalog of Revisions ...... 4 2 Introduction ...... 6 3 Satellite and Launch Program ...... 9 3.1 Overview ...... 9 3.2 Galaxy Fleet Satellite Replacement Plan ...... 11 3.3 Implementation of Compression/Upgrades to Reclaim Spectrum ...... 13 3.4 Transitioning Cable Programmers and Their Earth Station Affiliates...... 14 3.5 Transitioning Broadcast, Religious, Radio and Data Customers ...... 16 3.6 New Satellite Launch Program ...... 18 4 TT&C Gateway Relocation and Ground Systems Grooming ...... 20 4.1 Phase I Transition Activities...... 21 4.1.1 Paumalu Teleport ...... 22 4.1.2 Brewster Teleport ...... 22 4.2 Phase II Transition Activities...... 23 4.2.1 Andover Teleport ...... 23 4.2.2 Latin America Teleport ...... 24 4.2.3 Hartebeesthoek, South Africa Teleport ...... 24 4.3 Summary of Antenna Relocations ...... 24 4.4 TT&C Antennas for the Seven New Galaxy Satellites ...... 25 5 Work Associated with Repacking the C-Band ...... 25 5.1 Process and Communications about Customer Transitions ...... 26 5.1.1 Outreach Effort for Data Collection ...... 27 5.1.2 Scheduling Process ...... 27 5.1.3 Engineering for Site-Specific Technical Challenges ...... 28 5.1.4 Self-installation and Reimbursement of Actual Expenses ...... 28 5.2 Earth Station Change Types ...... 28 5.2.1 Frequency Change [F] ...... 29 5.2.2 Transponder Reassignment of In-Orbit Protection Bandwidth [R] ...... 29 5.2.3 Polarity Changes [P] ...... 29 5.2.4 Satellite Changes [S]...... 29 5.2.5 Compression/Technology Upgrades Required [C] ...... 30 5.3 Filter Installation ...... 30 5.3.1 Filter Versions ...... 31 5.3.2 Phase I Filtering ...... 31

5.3.3 Phase II Filtering ...... 32 5.3.4 Coordination with SES for Cable Headends and Multi-feed Antenna Filtering ...... 32 5.3.5 Earth Station Operator Responsibilities ...... 33 6 Customer Migration Plans ...... 34 6.1 Transition Plan (Chronological) ...... 34 6.1.1 Table 1 Phase I Grooming Plan Transition Activities (Chronological) ...... 34 6.1.2 Table 2 Phase II Grooming Plan Transition Activities (Chronological) ...... 36 6.2 Transition Plan (Customer-Centric) ...... 38 6.2.1 Table 3 Phase I Grooming Plan Transition Activities (Customer-Centric) ...... 38 6.2.2 Table 4 Phase II Grooming Plan Transition Activities (Customer-Centric) ...... 41 6.3 Satellite Transponder Loading View ...... 43 6.3.1 Figure 1 Cable Neighborhoods C-Band Loading – Baseline...... 44 6.3.2 Figure 2 Cable Neighborhoods C-Band Loading – End of Phase I ...... 45 6.3.3 Figure 3 Cable Neighborhoods C-Band Loading – End of Phase II ...... 46 6.3.4 Figure 4 Broadcast, Radio and Data C-Band Loading - Baseline ...... 47 6.3.5 Figure 5 Broadcast, Radio and Data C-Band Loading – End of Phase I ...... 48 6.3.6 Figure 6 Broadcast, Radio and Data C-Band Loading – End of Phase II ...... 49 6.4 Customer Services Not Requiring a Move ...... 50 6.5 Non-CONUS Services in the Lower 300 MHz ...... 50 7 Intelsat’s Earth Station Migration Plan ...... 50 7.1 Earth Station and Antenna Data Set Explained ...... 50 7.2 Cable Headends ...... 51 7.3 Galaxy 18 and Galaxy 23 Antenna Seeding ...... 52 7.4 Compression ...... 52 7.5 The Church of Jesus Christ of Latter-Day Saints ...... 53 7.6 Broadcast, Religious, Radio and Data Customers’ Affiliate Earth Station Scoping ...... 53 8 Transition Plan Summary ...... 53 8.1 Program Management ...... 53 8.2 High Level Costs ...... 54 8.3 High Level Timeline ...... 55 9 Conclusion ...... 56 Appendix 1: Listing of all earth stations claimed by Intelsat by earth station type Appendix 2: Listing of all earth stations claimed by Intelsat within Phase I’s 46 of the top 50 PEAs Appendix 3: Listing of all earth stations and other applicable sites requiring implementation of technology upgrades to support compression

Catalog of Revisions

Minor word edits are not cataloged.

Section 1 Table of Contents

• Updated to reflect new pagination, changes in section heading, and new sections 5.1.1, 5.1.2, 5.1.3, 5.1.4, 5.3.

Section 2 Introduction

• Revised description of the status of Intelsat’s activities on the consolidation of Telemetry, Tracking and Control (“TT&C”)/Gateway antennas.

Section 3 Satellite and Launch Program

• Clarified the significance of Restoration services, including Intelsat’s contractual obligations to provide the same or better level of Restoration services to its customers as it does today. • Corrected transponder utilization data. • Explained the process to repack customers that are not offering service in the contiguous United States in order to free needed capacity in the upper 200 MHz for the transition. • Clarified Intelsat’s approach to allocate “reasonable costs” that are “necessitated by the relocation” and incremental costs for multi-band replacement satellites, consistent with the rules adopted in the Report and Order. • Added a table providing the elements of satellite deployment costs.

Section 4 TT&C Gateway Relocation and Ground Systems Grooming

• Identified the selected East Coast consolidated TT&C/Gateway site and provided updates on the progress to finalize arrangements and the consolidation timeline for that teleport. • Provided additional details on estimated costs for TT&C/Gateway consolidation by planned consolidation activities. • Clarified that Intelsat does not intend to seek reimbursement for costs incurred relocating antenna assets to two existing international sites.

Section 5 Work Associated with Repacking the C-Band

• Provided more detail on Intelsat’s earth station outreach, including coordination with earth station operators facing site-specific technical challenges and non-contingous US earth stations affiliated with Intelsat customers. • Clarified that earth station operators that prefer to do their own installation can declare that intention to Intelsat and seek reimbursement of actual expenses through the Relocation Payment Clearinghouse. • Provided information on Intelsat’s planned coordination with SES Americom, Inc. (“SES”) on common tasks, such as the supply and installation of earth station filters at cable headends to minimize the burden on earth station staff. • Provided additional detail on estimated costs for earth station migration and compression upgrades by planned relocation activities.

Section 6 Customer Migration Plans

• Updated details on customer migration plans in the tables and the loading diagrams to reflect minor corrections and to address customer-specific feedback.

Section 7 Intelsat’s Earth Station Migration Plan

• Updated the status of Intelsat’s earth station migration plan, including changes to the claimed list to reflect new information available from the Incumbent Earth Station List issued by the International Bureau on August 3, 2020. • Provided a status update of Intelsat’s process of reconciling Intelsat’s customer affiliate database with the Incumbent Earth Station List. • Updated the customer migration plans in the loading charts and the tables to address customer-specific feedback. • Updated the broadcast, religious, radio and data customers’ affiliate earth station details to address customer-specific feedback.

Section 8 Transition Plan Summary

• Modified the aggregated timeline for antenna seeding, compression, and earth station filter installation.

Section 9 Conclusion

• No changes.

Appendix 1

• Updated listing of all earth stations claimed by Intelsat by earth station type.

Appendix 2

• Updated listing of all earth stations claimed by Intelsat within Phase I’s 46 of the top 50 Partial Economic Areas (“PEAs”).

Appendix 3

• Updated listing of all earth stations and other applicable sites requiring implementation of technology upgrades to support compression.

2 Introduction

Intelsat License LLC (“Intelsat”) submits its final Transition Plan, in accordance with the requirements set forth in the Federal Communications Commission’s (the “FCC” or the “Commission”) C-band Report and Order.1 This Transition Plan is the result of more than two years of planning and engineering undertaken in conjunction with Intelsat’s customers, industry stakeholders, vendors, and other space station operators in order for 300 MHz of spectrum – inclusive of a 20 MHz guard band -- to be cleared for use by new terrestrial flexible use licensees.

Undertaking the clearing of C-band spectrum is a monumental technical, operational and commercial task layered with highly interdependent activities. The main elements of the plan, which are explained in more detail below, involve the following:

• The construction and launch of seven new satellites to create sufficient capacity to repack services and effectuate spectrum clearing.

o Intelsat has signed manufacturing contracts with two U.S. vendors and has nearly finalized all related contracts so the satellites can be ready to satisfy the timing requirements of the Transition Plan.

• The consolidation of Intelsat Telemetry, Tracking, and Control (“TT&C”)/Gateway antennas into two remote locations on the east and west coast of the United States.

• The migration of customers to the upper 200 MHz of the C-band and the corresponding changes required at thousands of cable, broadcast, radio and religious affiliate earth stations.

o Intelsat has partnered with its customers over the past two years and has developed individual migration plans for each customer.

• The installation of filters, antennas and receive equipment into cable, broadcast, radio and data earth stations.

For the transition to be successful, each work stream within these project elements must occur in a tightly scheduled, highly coordinated fashion. The plan relies on the participation and active cooperation of all major stakeholders. In support of that, Intelsat has assembled an internal team of over fifty full time employees focused on the clearing initiative and has partnered with a third party to develop a program management function that will support the leaders of each of the work streams identified in this Transition Plan. Intelsat has developed a comprehensive communications plan to keep customers, earth station operators, suppliers and the broader ecosystem up to date on individual project plans and all related activities.

1 See Expanding Flexible Use of the 3.7-4.2 GHz Band, Report and Order and Order of Proposed Modification, 35 FCC Rcd. 2343 (2020) [hereinafter “Report and Order”].

Intelsat owns and operates the largest fleet of geostationary satellites in the industry. The Commission’s framework adopted in its Report and Order directly affects 25 of Intelsat’s satellites that have coverage into the contiguous United States (“CONUS”).2 In order to clear the lower 300 MHz for use in CONUS, Intelsat will be transitioning and migrating services on its U.S. domestic Galaxy fleet, which currently consists of ten station-kept satellites in the North American arc.3 The Report and Order’s requirements also affect Intelsat’s services on fifteen Ocean Region satellites, where Intelsat will need to migrate antennas to the two new TT&C/Gateway facilities in order to continue to downlink international programming in the lower 300 MHz for contribution to earth stations across CONUS.4 The construction and launch of new satellites, the antenna migration to new TT&C/Gateway facilities, the migration of customers and the corresponding equipment upgrades required at affiliate earth stations are all integral components to clearing the spectrum in the identified timelines and to providing customers with service continuity throughout the clearing process.

2 The definition of CONUS as used in this Transition Plan is that used in the Report and Order and the Commission’s rules. See Report and Order, App’x A, § 25.103 and § 27.1411(b)(6). 3 The “North American arc” is the portion of the geostationary arc that is used primarily for the distribution of television and radio programming to all fifty U.S. states. It consists of those orbital locations from 87° W.L. through 139° W.L. There are orbital locations outside of this arc that are visible to earth stations in some portion of the contiguous 48 states or to Alaska or Hawaii. Satellites at these non-North American arc locations are referred to herein as “Ocean Region” or “international” satellites. 4 Intelsat has sought reconsideration to allow its continued access to 500 MHz at two consolidated TT&C/Gateway sites in CONUS on a protected basis, so that Intelsat can ensure C-band service continuity to customers on its Ocean Region satellites. See Intelsat License LLC Petition for Reconsideration (May 26, 2020), https://ecfsapi.fcc.gov/file/10526884925025/Petition%20for%20Reconsideration%20- %20Intelsat%2026%20May%202020.pdf. This Transition Plan is not directly dependent upon the Commission’s resolution of this issue. For planning purposes, however, it would be desirable to have the Commission resolve this matter as soon as possible.

Prior to the FCC initiating its C-band proceeding, Intelsat analyzed how its customers on Galaxy satellites were planning to densify programming on fewer transponders through compression and terrestrial means over a longer timeframe. The output of this assessment formed the basis of Intelsat’s pre-C-band proceeding satellite replacement plan -- one that would have densified customer content on fewer (high-performance, full-spectrum) satellites. However, the framework contained in the Report and Order reversed this planned path to long-term densification.5

5 See also Intelsat License LLC Notice of Ex Parte Meeting, 2 (Aug. 10, 2020), https://ecfsapi.fcc.gov/file/10810600724158/Ex%20Parte%20Meeting%20-%20Intelsat%208-10- 2020.pdf.

To achieve the timeframes specified in the Report and Order, Intelsat must create a “non- commercial” balance of satellite capacity, compression gains, migration activities and “same or better services” to clear the 300 MHz required. The accelerated deadlines create the immediate need to “spread” programming in the upper 200 MHz across all current cable-/broadcast-penetrated satellites, rather than pursuing the previous densification strategy of fewer orbital locations utilizing all 500 MHz. Spreading the content requires the launch of an increased number of partial replacement satellites, as compared to Intelsat’s pre-C-band proceeding plan that would have required the launch of fewer, more densified satellites.

Intelsat is committed to implementing this complex transition and already has taken a number of steps in advance of submitting this Transition Plan – steps that were required in order to align project plan milestones with the Commission’s accelerated deadlines for spectrum clearing. Intelsat remains open to constructive dialogue with all stakeholders in this process, while also noting that some aspects of the planning and process detailed in this Transition Plan cannot be modified without making the project deadlines impossible to achieve.

The FCC’s Report and Order makes receipt of accelerated relocation payments contingent upon Intelsat meeting certain milestone dates, with severe reductions in the payments for missing specified deadlines. Accordingly, Intelsat’s Transition Plan has been carefully orchestrated to meet those aggressive deadlines and there is limited flexibility in this orchestration to accommodate changes. 3 Satellite and Launch Program 3.1 Overview

The Intelsat satellite replacement and launch program works in concert with the customer migration program and provides continuity for every service for which a customer desires continuity, while supporting the clearing of 300 MHz within the required milestone dates. The FCC has recognized that satellite services are an essential part of the communications infrastructure in the United States. The suite of services that Intelsat provides, and will continue to provide both now and post-transition, may be summarized as follows:

Distribution services are services that transmit video and audio programming, as well as data, in a “one-to-many” broadcast mode. The majority of services on the Galaxy fleet provide programing and data Distribution to thousands of affiliate earth stations. To provide some perspective, the Galaxy fleet is the leading Distribution platform for U.S. television and radio programmers, who generate over $80-90 billion annually in revenues from subscription fees, advertising revenues, and other revenue from the delivery of these services.6

Contribution services are services that are critical for the backhaul of television, news, radio and data content from remote events or from distributed content affiliates throughout CONUS. Intelsat

6 See Derek Baine, Kagan Data Services: Advertising Forecasts (2019 Edition), S&P GLOBAL MARKET INTELLIGENCE (2020).

has 90 customers that access Contribution transponders for internal or managed solutions (packaging remote truck, production and satellite transport) for events and remote productions. In 2019, Contribution events created over 16,000 C-band service reservations and utilized (at peak use times) over 20 transponders on a simultaneous basis. This is how programmers produce sports, news and special events content.

Restoration services are services that ensure that Contribution or Distribution services have continuity should a satellite suffer a transponder or payload failure, or a terrestrial network anomaly occurs. Restoration services are critical services integrated into the Galaxy fleet to ensure service/business continuity and to protect the enterprise value of Intelsat’s customers. Restoration services are contracted for, paid for, and provided as part of the cable distribution service bundle and similarly, to broadcaster and data network customers as well. Customers that desire this service have historically relied on and will continue relying on the continuity of their services, pre- planning the “go-to” locations with their earth stations for service restoration and on near real time or swift implementation of restoration to minimize any service disruptions.7

To implement the Report and Order, Intelsat is integrating multiple principles to: i) clear the quantity of spectrum the Commission requires for CONUS (300 MHz); ii) clear the spectrum within the accelerated timelines dictated by the Report and Order; and iii) provide “same or better” services to Intelsat’s customers and the broader ecosystem.8 This requires balancing a range of requirements.

The sections that follow further detail Intelsat’s customer migration plans. Recognizing the practical constraints, Intelsat’s Transition Plan leverages the following key principles:

• Focus on use of existing “penetrated” orbital locations.

• Prioritize CONUS services on the upper 200 MHz and transition non-CONUS services to the lower 300 MHz.

• Replace Galaxy satellites at penetrated orbital locations and deploy compression to customer services where it materially reduces going-forward capacity and allows programming to “fit” within the top 200 MHz.

• Simplify many replacement C-band satellite payloads to ten transponders, while building a minority of C-band payloads with 24 transponders for Alaska, Hawaii, and off-shore applications.

• Maintain proven component, system, satellite, and in-orbit redundancies to meet contracted service levels of 99.999% availability or greater.

7 See Intelsat License LLC Notice of Ex Parte Meeting, 2-5 (Aug. 4, 2020), https://ecfsapi.fcc.gov/file/1080467946484/Ex%20Parte%20Meeting%20Restoration%20Service%20 and%20Cost%20Allocation%20-%20Intelsat%208-4-2020.pdf. 8 See Report and Order, paras. 32, 171, 194, 201, 239.

Simplify C-band payloads for manufacturing and launch schedule Prioritize domestic material and Groom CONUS services to the adherence service sourcing while top 200 MHz while deploying maintaining satellite compression for material manufacturer and launch provider spectrum reclamation diversity for schedule risk management

Continuity of Leverage existing Success in transition Contribution, penetrated satellite schedule, operational Distribution, and orbital reliability and Restoration services for neighborhoods customer experience all C-Band customers

3.2 Galaxy Fleet Satellite Replacement Plan

The Intelsat satellite replacement plan is focused on the ten station-kept Galaxy satellites that contain C-band payloads in the North American arc.9 The C-band payloads on these ten Galaxy satellites currently utilize 500 MHz of C-band spectrum configured as 24 x 36 MHz transponders, with twelve transponders in each linear polarization (horizontal and vertical). These C-band payloads are used to distribute video, radio and data services to thousands of receive sites across North America and the Caribbean. The ten C-band payloads are broadly separated into two categories or applications, with the payloads not generally being interchangeable between the two applications.

Cable Services: Six C-band payloads are used for Distribution and Restoration services to thousands of cable affiliates.

Broadcast and Data Services: Four C-band payloads are used to distribute broadcast TV, radio, and data services, to provide Contribution services for programmers, and to provide Restoration services for broadcast and data customers.

9 See supra note Error! Unknown switch argument..

Broadcast and cable television use satellite communications as a cost-effective, reliable, and efficient method to distribute programming. Broadcast and cable programmers over time have congregated on specific satellites, and broadcast affiliates and cable headends installed antennas and receivers (or were given the infrastructure) to receive the satellite-delivered programming. Over time, natural concentrations arose in the form of “neighborhoods.” If a specific C-band payload has earth station equipment installed so that its transmissions are received at all cable or broadcast affiliates, it is 100% “penetrated.” Most Galaxy C-band payloads are 100% penetrated for their specific application. This is the current use state of these satellite payloads, and this has fundamental implications for any swift spectrum clearing and for this Transition Plan.

Leveraging “penetrated” orbital locations is critical to comply with the timing element of the Report and Order.10 Prior to the proceeding, Intelsat planned to reduce the number of orbital locations over a longer time period (but utilize all 500 MHz) as customers self-compressed and densified their transponder channels. The Report and Order reverses this densification approach and requires an entirely different transition model. Instead, Intelsat must spread programming to more orbital locations to clear the 300 MHz than would naturally have occurred over the next few years.

10 Intelsat’s redeployment of GCI services is an exception to the use of penetrated satellites. Intelsat has coordinated with GCI proactively to bifurcate their non-CONUS network and relocate nearly half of the GCI network from Galaxy 18 to Horizons 3e. Given the shorter warm-weather seasons in Alaska when antenna work can be performed on GCI antennas, Intelsat initiated this GCI network bifurcation in advance of the FCC Report and Order. The GCI network bifurcation allows Intelsat to clear the upper 200 MHz of Galaxy 18 for CONUS services, a critical component of the Transition Plan to clear 300 MHz of spectrum.

Given the practical constraint that most earth stations do not have the technical capability, physical space, or ability to add new receive antennas or license them within the timeframes required, Intelsat would not be able to deploy customer programming to non-penetrated orbital locations. Thus, the only feasible means to achieve the Commission’s accelerated transition schedule requires Intelsat to utilize all -- and only -- penetrated orbital locations.

As a result, Intelsat must replace all current penetrated C-band payloads before their planned end- of-life to successfully spread programming to allow clearing of the necessary spectrum.11 In tandem with this satellite replacement program, Intelsat must deploy updated compression systems with selected programmer customers, as well as migrate non-CONUS services out of the upper 200 MHz so that the programming intended for Distribution services in CONUS can “fit” into the throughput capacity of the reconfigured Galaxy fleet.12 As previously stated, every service for which a customer desires continuity will be accommodated by this Transition Plan.

3.3 Implementation of Compression/Upgrades to Reclaim Spectrum

Compression is deployed in this Transition Plan solely to reclaim bandwidth/spectrum on an ongoing basis within the timeframe of the Report and Order and to ensure all current customer services have continuity on a “same or better” standard. Compression is not being deployed to “future-proof” customer services by increasing current Mbps throughput, allowing for future services such as 4K or 8K, HDR upgrades or ASTC broadcast models. Instead, the amount of compression deployed in this Transition Plan is directly dictated by (and balanced by) the amount of available capacity

11 See Intelsat License LLC Notice of Ex Parte Meeting, 1-2 (Aug. 10, 2020). 12 See Report and Order, para. 194.

(supply) created by the Intelsat satellite launch plan and the clearing deadlines set by the FCC Report and Order.

Intelsat examined current customer usage and conferred with many customers throughout 2019 about the deployment of compression systems. Intelsat has confirmed the implementation of compression upgrades with eleven customers, each of which has expressed agreement to participate in the compression plan. The key considerations for customers for whom compression will be implemented were:

1. Compression and platform upgrades generate material reductions in existing overall capacity usage or capacity usage for the specific orbital location.

2. Customers undergoing compression/platform upgrades may choose the technology provider that is best suited for their operations.

3. Intelsat will contract with and direct compression technology vendors to ensure deliveries and installations of necessary equipment that supports the Report and Order’s accelerated timelines.

The efficiency upgrades envisioned based on discussions with affected customers include a mix of High Efficiency Video Coding (“HEVC”), Advanced Video Coding (“AVC”) and other data compression technologies, coupled with new Integrated Receiver Decoders (“IRDs”) in most cases.

The planned upgrades reduce usage for the affected customers by 45% from (current) 56 transponder units to 31 units post-transition.

Full-time Capacity Reclamation from Planned Compression

Current transponder Final transponder utilization utilization after compression (all frequencies) (4.0 to 4.2 GHz)

56 transponders 31 transponders

It should be noted that as the transition evolves, Intelsat may need (or be able) to make revisions to the compression program to adjust for customer developments such as a non-renewal or capacity reductions due to corporate mergers, customers electing alternate Distribution methods or ceasing content Distribution services in the United States.

3.4 Transitioning Cable Programmers and Their Earth Station Affiliates

Six of the Galaxy C-band payloads (listed below) currently distribute, and will continue to distribute, programming to cable affiliates. Intelsat estimates that over 720 channels are distributed to over 2,500 cable headends via these six satellites. The Intelsat Transition Plan provides continuity for every channel/programmer that desires continued services.

The gray font identifies the satellites that do not need to be replaced during the transition, as explained in more detail below. Galaxy 12 is not utilized for cable Distribution services due to the antenna tracking limitations related to operating the satellite in Inclined Orbit.

Location and Satellite Service Type C-band Design Replacement 133° W.L. G-15 Non-preemptible Simplified payload Funded replacement 129° W.L. G-12 Inclined (N/A) Simplified payload Funded replacement 127° W.L. G-13 Non-preemptible Full payload Funded replacement 125° W.L. G-14 Non-preemptible NA Intelsat replacement 123° W.L. G-18 Non-preemptible NA Intelsat replacement 121° W.L. G-23 Restoration Simplified payload Funded replacement 91° W.L. G-17 Non-preemptible Simplified payload Funded replacement

Today, five of the six C-band payloads above are used for Distribution services to cable affiliates. The sixth, Galaxy 23, provides Restoration services for the majority of the cable customers who hold contractual rights for service restoral if a partial or full satellite failure occurs. In light of this critical restoration use and customer requirement, most services on Galaxy 23 currently are sold on a preemptible basis – i.e., those customers can be preempted if there is a transponder or spacecraft issue on another Galaxy C-band payload that creates the need to restore services on Galaxy 23.

Four of the six cable arc C-band payloads will need to be replaced to meet the FCC’s accelerated spectrum clearing timeframe. The replacement C-band payloads for Galaxy 13, Galaxy 15, Galaxy 17, and Galaxy 23 will provide Distribution services. For clarity, the replacement for Galaxy 23 will convert that orbital location from a Restoration role into a Distribution role. Galaxy 15R, Galaxy 17R and Galaxy 23R will be designed with 10 x 36 MHz transponders in the upper 200 MHz of the C- band. Galaxy 13R will be designed with 24 x 36 MHz transponders. The upper transponders will be used for Distribution services in CONUS and the lower transponders will be used for Alaska, offshore and other non-CONUS services.13

To provide cable arc customers with a consistent level of Restoration services protection, Intelsat will launch Galaxy 12R and locate the C-band payload at 129° W.L. This satellite will be designed with 10 x 36 MHz transponders and will be the new Restoration payload. This will allow the capacity currently on Galaxy 23 to support Distribution services (leveraging its current cable affiliate penetration).

13 A few non-CONUS customers, specifically in Alaska and Canada, are currently receiving services from satellites that need to be replaced. These customers must be repacked in the lower 300 MHz in order to free capacity in the upper 200 MHz for customers serving CONUS. An example of this situation is GCI. These grooming activities are part of the overall transition program and would not have been necessary but for the Commission’s mandate to clear 300 MHz of C-band spectrum within an accelerated timeframe. Therefore, these activities are integral to Intelsat’s Transition Plan and qualify for reimbursement under the Commission’s stated standards.

Intelsat will launch the replacement for Galaxy 14 in Q3 2020. The replacement C-band payload, Galaxy 30 (formerly Galaxy 14R), was designed with 24 x 36 MHz C-band transponders. The upper transponders will continue to be used by customers for Distribution services to cable headends and the lower transponders will be used to provide services to offshore locations and Alaska. Because Galaxy 30 was planned before the C-band rulemaking, Intelsat will not seek reimbursement for this satellite even through it is critical to, and integrated into, Intelsat’s C-band clearing strategy and project planning.14

Galaxy 18 does not need to be replaced during the clearing period. As such, Intelsat does not intend to seek reimbursement for the Galaxy 18 replacement satellite, even though the replacement will be utilized for service continuity after the clearing period.

Intelsat will seek reimbursement for the C-band payloads on the new Restoration satellite and the four replacement Distribution satellites required to repack Intelsat’s cable programming customers. The number of transponders available for primary cable Distribution will shrink from 144 (6 x 24) today to 60 (6 x 10) post clearing. The upper 200 MHz of spectrum on the Distribution service satellites will be 99.5% loaded after the repacking occurs.

In summary, to successfully clear the lower 300 MHz of spectrum in the CONUS cable arc in the accelerated timeframe and to provide cable customers with the same or better level of service, Intelsat will need to: i) repurpose Galaxy 23 from Restoration services to Distribution services; ii) launch a new Restoration satellite (Galaxy 12R) to 129° W.L.; iii) replace four additional Distribution satellites by the end of the clearing timeframe; and iv) implement the other elements of the Transition Plan discussed below.

3.5 Transitioning Broadcast, Religious, Radio and Data Customers

As stated above, Intelsat uses four of the Galaxy C-band payloads for Distribution, Contribution and Restoration services for broadcast, religious, radio, and data networks. The four satellites that are currently used for these customers are listed in the table below. Of the four satellites, two need to be replaced during the clearing period: Galaxy 3C and Galaxy 28, as identified in black font.

Location and Satellite Service Type C-band Design Replacement 99° W.L. G-16 Non-preemptible Simplified payload Intelsat replacement 97° W.L. G-19 Non-preemptible Simplified payload Intelsat replacement 95° W.L. G-3C Non-preemptible Simplified payload Funded replacement 89° W.L. G-28 Non-preemptible Simplified payload Funded replacement

The replacement and transition strategy in the broadcast arc is less complex than the cable arc. Intelsat does not need to migrate or compress as many services on these four satellites as there is a material amount of capacity currently utilized for Contribution services, which are not “always on.” The primary activities will be to: i) migrate current CONUS services to the upper 200 MHz; ii) migrate

14 See Report and Order, para. 197, n.528.

non-CONUS services to the lower 300 MHz; iii) reconfigure the location/assignment of Contribution service transponders; iv) compress/upgrade two customers’ services; and v) replace aging satellites. All four satellites in the arc will be utilized for clearing CONUS Distribution, Contribution and Restoration services.

The two satellites replacing Galaxy 3C and Galaxy 28 will provide: i) Distribution services; ii) Restoration services for key broadcast customers such as ABC, CBS, and Fox; and iii) Contribution services that are critical for event and content production. If these two satellites are not replaced, capacity for contracted Restoration and Contribution services would be reduced below contractually committed levels, which would not meet the “substantially the same or better” service standard adopted by the Commission in the Report and Order.15

The C-band payloads in the broadcast arc are currently designed with 24 x 36 MHz transponders. The replacement C-band payloads will be designed with 10 x 36 MHz transponders, which allows Intelsat to complete repack activities. Additionally, the new broadcast arc satellites can provide continuity for Contribution capacity/services. Intelsat has ninety customers that access Contribution transponders for internal or managed solutions (packaging remote truck, production and satellite transport) for events and remote productions. In 2019, Contribution events created over 16,000 C- band service reservations and utilized (at peak use times) over twenty transponders on a simultaneous basis. The number of transponders available for broadcast Distribution, Contribution and Restoration in CONUS will reduce from 96 (4 x 24) available transponder units today to 40 (4 x 10) units post-transition. The satellites will be 100% utilized in the upper 200 MHz after the repacking efforts but sized to continue to meet the forecasted peak demand for Contribution services, about which some parties in the proceeding have expressed concern.16

Galaxy 16 and Galaxy 19 do not need to be replaced during the clearing period. As such, Intelsat does not intend to seek reimbursement for the Galaxy 16 and Galaxy 19 replacement satellites, even though these replacements will be utilized for service continuity after the clearing period.

The cost for the C-band payloads on the seven new satellites is estimated to be $790 million (or $113 million per satellite), which is within the range provided in the Cost Catalog published by the Wireless Telecommunications Bureau.17

15 See Report and Order, paras. 32, 171, 194, 201, 239. 16 See, e.g., Comments of PSSI Global on SSO Joint Petition for Stay, 15-17 (May 27, 2020), https://ecfsapi.fcc.gov/file/105272141027253/PSSI%20Comments%20on%20SSO%20Joint%20Petit ion%20for%20Stay%20and%20Attachments.pdf. See also Intelsat License LLC Comments on PSSI Request for Stay, 4-9 (June 25, 2020), https://ecfsapi.fcc.gov/file/10625907124551/Comments%20on%20PSSI%20Request%20to%20Stay %20-%20Intelsat%206-25-2020.pdf. 17 See Wireless Telecommunications Bureau Releases Final Cost Category Schedule for 3.7-4.2 GHz Band Relocation Expenses And Announces Process and Deadline for Lump Sum Elections, Public Notice, GN Docket No. 18-122, IB Docket No. 20-205, DA-20-802, Attach., 3 (July 30, 2020), https://docs.fcc.gov/public/attachments/DA-20-802A2.pdf. As Intelsat has noted in other filings in

The individual customer transition activities and future loading plans for the broadcast arc satellites are discussed below.

3.6 New Satellite Launch Program

The seven satellites discussed above will be launched on four separate launch vehicles, using at least two different launch service providers. Intelsat has developed a launch program that places each satellite in service by the end-of-life of each replaced satellite, with an appropriate margin to ensure clearing deadlines can be met. Intelsat has integrated manufacturer and launch vehicle provider diversity in this new satellite launch plan to manage schedule risk, to increase the probability of success in meeting the clearing deadlines, and to reduce the overall program cost. Six of the satellites will launch in pairs and one is planned to be a dedicated launch. The table below outlines the new satellite and launch vehicle program, which is described in further detail below.

Location and In Service Satellite Launch Launch Satellite Date Manufacturer Vehicle Sequence 121° W.L. G-23R Q3 2022 Maxar Provider 1 Launch 1 91° W.L. G-17R Q3 2022 Maxar Provider 1 Launch 1 129° W.L. G-12R Q3 2022 Northrop Grumman Provider 1 Launch 2 133° W.L. G-15R Q3 2022 Northrop Grumman Provider 1 Launch 2 95° W.L. G-3CR Q4 2022 Maxar Provider 2 Launch 3 89° W.L. G-28R Q4 2022 Maxar Provider 2 Launch 3 127° W.L. G-13R Q3 2023 TBD TBD Launch 4

this proceeding, it will add additional payloads on some of the satellites identified above, but only if those payloads can be added without interfering with the compressed spectrum clearing schedule requirements and be consistent with FCC cost reimbursement guidelines. Intelsat will not seek reimbursement for any incremental cost resulting from the additional payload based on incremental cost as determined by the satellite manufacturer. See Report and Order, para. 201; Wireless Telecommunications Bureau Releases Final Cost Category Schedule for 3.7-4.2 GHz Band Relocation Expenses and Announces Process and Deadline for Lump Sum Election, Public Notice, GN Docket Nos. 18-122, 20-205, DA 20-802, para. 14, n.57 (July 30, 2020), https://ecfsapi.fcc.gov/file/07302324113729/DA-20-802A1.pdf; Intelsat License LLC Notice of Ex Parte Meeting (May 26, 2020), https://ecfsapi.fcc.gov/file/10526045231531/Ex%20Parte%20Meeting%20- %20Intelsat%2026%20May%202020.PDF. When seeking reimbursement, Intelsat will submit to the Clearinghouse supporting documentation showing how each satellite manufacturer applied the Commission’s established incremental cost allocation methodology to ensure that any addition to a C-band payload is appropriately accounted for to the Relocation Payment Clearinghouse. See Intelsat License LLC Ex Parte Submission for the Record (Aug. 6, 2020), https://ecfsapi.fcc.gov/file/108062256102552/Ex%20Parte%20Brattle%20Group%20White%20Paper %20-%20Intelsat%208-6-2020.pdf; Intelsat License LLC Notice of Ex Parte Meeting (Aug. 4, 2020), https://ecfsapi.fcc.gov/file/1080467946484/Ex%20Parte%20Meeting%20Restoration%20Service%20 and%20Cost%20Allocation%20-%20Intelsat%208-4-2020.pdf.

The first pair of satellites will be manufactured by Maxar and will replace Galaxy 23 and Galaxy 17. In order to meet clearing deadline dates, Intelsat started the program (at risk) for these satellites in April 2020 in advance of the Report and Order becoming effective.18 The pair of Maxar satellites will be launched on a single launch vehicle and the satellites are expected to be in service by Q3 2022. Intelsat plans to finalize the launch vehicle contract for these two satellites in Q3 2020.

The second pair of satellites will be manufactured by Northrup Grumman and will replace Galaxy 12 and Galaxy 15. In order to meet the FCC’s accelerated clearing deadlines, Intelsat started the program (at risk) for these satellites in April 2020.19 The pair of satellites will be launched on a single launch vehicle and are expected to be in service by Q3 2022. Intelsat plans to finalize the launch vehicle contract for these two satellites in Q3 2020.

The third pair of satellites will be manufactured by Maxar and will replace Galaxy 3C and Galaxy 28. In order to meet the FCC’s accelerated clearing deadlines, Intelsat started the program (at risk) for these satellites in April 2020.20 The pair of satellites will be launched on a single launch vehicle and the satellites are expected to be in service by Q4 2022.

Intelsat plans to contract with a second launch services provider for the launch of this third pair of satellites. The selection of a second launch services provider provides diversity in the event of a launch failure of the first launch provider (an industry standard action), which also significantly de- risks the overall satellite deployment schedule. Intelsat plans to be under contract with the second launch provider in Q3 2020.

Intelsat is currently evaluating proposals for Galaxy 13R from multiple satellite manufacturers and plans to start the program in September 2020. Intelsat plans to finalize the launch vehicle contract in tandem with the satellite manufacturer decision. As is commercially standard, cost, schedule availability, and vehicle reliability will be the key determining factors in vendor selection. Intelsat plans to have Galaxy 13R in service by December 5, 2023 – in line with the spectrum clearing milestones. The timing of the initial launch is intended to provide Intelsat with enough schedule margin to complete a second satellite program, as described above, in the event of a launch failure of the first. This will provide customers with additional protection against service interruption through the end of the clearing period.

The total cost for the four launch vehicles and the associated launch insurance is estimated to be $390 million.

Should a launch failure occur, Intelsat will confer with the relevant satellite manufacturers and launch service providers to determine if a replacement launch can occur in a timely manner. If a relaunch attempt can be made prior to the end-of-life of the satellite(s) being replaced, construction is most likely the preferred path. If a relaunch attempt cannot be made prior to the end-of-life of the

18 Intelsat entered into an Authorization to Proceed (“ATP”) agreement with the manufacturer for the purpose of ordering long lead-time items. 19 Id. 20 Id.

satellite(s) being replaced, Intelsat will reconfigure the orbital deployment of the C-band payloads to prioritize Distribution services.

The total cost of Intelsat’s C-band replacement satellite portion of the Transition Plan, including launch, insurance, and program management, is estimated to be $1.18 billion,21 which is well within the range of reasonable costs that the FCC estimated would be incurred for satellite procurement and launch costs. 22

# of Cost Per Total Satellites Satellite Cost Payload 7 $ 113 $ 790 Launch Vehicle 40 280 Subtotal $ 153 $ 1,070 Insurance 12 85 Program Management 4 25 Total $ 169 $ 1,180 4 TT&C Gateway Relocation and Ground Systems Grooming

In addition to the effort associated with the Galaxy spacecraft and grooming activities discussed above, there will be an equally significant amount of work required on the ground to facilitate service

21 The numbers presented in the table are in millions. Similar breakouts of TT&C and Ground costs are included in sections 4 and 5 below. 22 Report and Order, para. 210.

continuity for customers downlinking programming into CONUS from Intelsat’s Pacific Ocean Region (“POR”) and Atlantic Ocean Region (“AOR”) satellites and to ensure that Intelsat can continue to command and control certain satellites from the two new TT&C/Gateway locations it has selected on the east and west coast of the United States prior to the Commission’s Phase I and Phase II deadlines. 23 This Transition Plan discusses each phase separately below.

4.1 Phase I Transition Activities

Intelsat currently operates teleports in Riverside, Filmore, and Napa, California, which support customer services or TT&C carriers that will need to be relocated prior to the Phase I deadline. A few of these services/carriers can be transitioned to Intelsat’s Paumalu teleport on the island of Oahu, Hawaii. However, the majority will need to be transitioned to Intelsat’s new West Coast consolidated TT&C/Gateway teleport in Brewster, Washington. The work that is already underway to consolidate activities at these two sites is discussed below.

23 As Intelsat explained in its pending Petition for Reconsideration, robust TT&C operations, including orbit raising, are critically important to the safety of flight of Intelsat’s satellites, as well as to service continuity. Intelsat relies upon TT&C functions to maintain control of its satellites and interference with TT&C carriers cannot occur without jeopardizing the satellites’ safety. Intelsat has presented its concerns about adequate protection of the TT&C signals to the Commission and sought protected access for all 500 MHz at its consolidated TT&C/Gateway sites, as well as reconsideration of the technical specifications for the TT&C filters required to safely control satellite operations post-transition.

4.1.1 Paumalu Teleport

Intelsat currently operates a full-motion, C-band antenna at Intelsat’s Fillmore teleport to support orbit raising operations for Intelsat and third-party satellites utilizing frequencies in the lower 120 MHz of the C-band. To replace this Fillmore antenna, a new full-motion C-band antenna will need to be built at Paumalu to support these requirements moving forward. Given the long lead times associated with this type of antenna, Intelsat placed an order to purchase this asset in May 2020 to ensure operational readiness by December 2021.

Intelsat currently supports customer services on Horizons 3e and Intelsat 19 at its Napa teleport in the lower 120 MHz of the C-band. These services must transition to Paumalu. This additional customer traffic, coupled with the increase of ground equipment to support this traffic in Paumalu, necessitates upgrades in Intelsat’s electrical infrastructure and an increase in fiber capacity to provide connectivity back to Intelsat’s mainland points of presence (“PoPs”). The planning for this work is in progress and expected to be complete by mid-summer 2021.

4.1.2 Brewster Teleport

The Brewster teleport is located in a remote area of eastern Washington state and has been selected as Intelsat’s West Coast consolidated TT&C/Gateway teleport. Intelsat will be procuring seven new antennas to be installed at the Brewster facility. These antennas will be taking over TT&C operations and providing spectrum monitoring for satellites serving CONUS from the Atlantic and Pacific Ocean regions. Intelsat will also downlink customer C-band services in the lower 300 MHz at this teleport, although the Report and Order does not accord those services protected status.24 The specific satellites requiring new antennas for TT&C and supporting customer traffic are Intelsat 18, Intelsat 21, Intelsat 23, and Intelsat 34. Intelsat will also relocate its West Coast TT&C rover antenna25 to Brewster, as well as its two rover antennas for spectrum monitoring across the fleet.

Significant upgrades will be required at the Brewster teleport to accommodate these seven new antenna systems and associated radio frequency (“RF”) equipment, specifically to the electrical power infrastructure, environmental systems, and terrestrial fiber capacity. These upgrades are required to meet the increased load associated with the new systems and to bring the teleport infrastructure up to the baseline standard that exists at Intelsat teleports, allowing continued high- availability Service Level Agreements (“SLAs”) contained in Intelsat’s customer contracts.

Given the requirement to have these new systems operationally ready by the Phase I deadline of December 2021, Intelsat has already engaged with the Brewster facility in designing the preliminary

24 In order to ensure service continuity for customers on Ocean Region satellites that downlink to CONUS, Intelsat has sought reconsideration of the issue of protected use of the lower 300 MHz at the two TT&C/Gateway sites. See Intelsat License LLC Petition for Reconsideration (May 26, 2020). 25 Intelsat utilizes TT&C rover antennas for certain satellites that are designed not to require dedicated ranging from two separate earth stations. This design allows a single antenna to provide temporary TT&C ranging support across multiple satellites, where applicable.

construction activities and has issued and funded an ATP, allowing the ordering of long-lead items. The plan is to complete the required infrastructure upgrades and the installation of the antenna foundations by the end of 2020. In 2021, antenna construction will begin in parallel with the ongoing infrastructure upgrades. Services will be gradually transitioned from existing facilities over the course of 2021. The final antenna system will come online in November of that year.

4.2 Phase II Transition Activities

Phase II transition activities are specific to antennas and services currently supported at Intelsat’s two East Coast teleports in Atlanta, Georgia and Hagerstown, Maryland. Most of these services will be relocated to Intelsat’s new East Coast consolidated TT&C/Gateway teleport in Andover, Maine. Two services cannot be supported at that site due to satellite coverage constraints and will be transitioned to international teleport locations within their respective coverage areas.

4.2.1 Andover Teleport

The Andover teleport is located in a remote area of western Maine and has been selected as Intelsat’s East Coast consolidated TT&C/Gateway teleport. Intelsat will be procuring six new antennas to be installed at the Andover facility. These antennas will support TT&C operations, will provide spectrum monitoring for services on Intelsat’s Atlantic Ocean fleet, and will be utilized to downlink C-band services in the lower 300 MHz for customers who deliver international programing to affiliates in CONUS.26 The specific satellites for which the Andover site will provide TT&C services are Intelsat 901, Intelsat 25, Intelsat 35e, and Intelsat 37e. Intelsat also intends to relocate its East Coast TT&C rover antenna and its East Coast full-motion launch support antenna to this East Coast consolidated teleport.

Like the Brewster teleport site, significant upgrades will be necessary for the existing power systems, environmental systems, and terrestrial connectivity at the Andover facility to support the new antenna systems and meet contractual SLAs with Intelsat’s customers.

Intelsat is finalizing the implementation plan for the antenna builds in Andover and expects to finalize contracts by Q4 2020. At that point, planning and detailed site design efforts will commence, followed by construction activities kicking off in Q2 2021. The Andover site will be ready for operations in Q3 2023.27

26 As noted above, Intelsat sought reconsideration to allow its continued access to 500 MHz at two consolidated TT&C/Gateway sites in CONUS on a protected basis, so that Intelsat can ensure service continuity of C-band services on these non-North America arc satellites. See Intelsat License LLC Petition for Reconsideration, 5-7 (May 26, 2020). 27 Another aspect of Intelsat’s Petition for Reconsideration is a request that the Commission extend the date for the consolidation of Intelsat’s TT&C/Gateway sites to the Phase II deadline, as a Phase I deadline for this activity is infeasible given the amount of work required and the timing as a practical matter would not affect 3.7 GHz licensee deployments. See id. at 20-22.

4.2.2 Latin America Teleport

Intelsat currently supports services on Intelsat 14 from its teleport in Atlanta, Georgia. Because Intelsat 14’s coverage area does not extend far enough North to be received by either of the sites under consideration for the East Coast consolidated teleport, Intelsat will need to identify and contract with a teleport in Latin America to provide spectrum monitoring for this satellite. Planning for this activity will commence in late 2020 and the antenna will be ready for operation no later than Q2 2023.

4.2.3 Hartebeesthoek, South Africa Teleport

Multiple Intelsat 9-series satellites will go into inclined orbit operation over the next five years and once inclined, will not be supportable by the East Coast consolidated teleport due to look-angle restrictions at both sites that are under consideration. Primary TT&C operations for each of these satellites will continue to occur at Intelsat’s Fuchsstadt teleport in Germany, but the back-up TT&C mission currently being supported in Atlanta or Hagerstown will be transitioned to a single TT&C rover antenna to be constructed in Hartebeesthoek, South Africa. This same rover antenna will also provide back-up TT&C services for Intelsat 14. Planning for these activities will commence in late 2020 and the antennas will be ready for operation in Q2 2023.

4.3 Summary of Antenna Relocations

Satellite Current Antenna Current Antenna Antenna New Antenna Function Location Size Location Horizons 3e Customer traffic Napa, CA 9M Paumalu, HI Intelsat 19 Customer traffic Napa, CA 9M Paumalu, HI Full-Arc Launch Support Fillmore, CA 13M Paumalu, HI Intelsat 18 TT&C/Customer Riverside, CA 13M Brewster, WA traffic Intelsat 23 TT&C/Customer Riverside, CA 13M Brewster, WA traffic Intelsat 34 TT&C/Customer Riverside, CA 13M Brewster, WA traffic Intelsat 21 Customer traffic Atlanta, GA 7M Brewster, WA Full-Arc Spectrum Hagerstown, MD 7M Brewster, WA Monitoring Full-Arc Spectrum Atlanta, GA 7M Brewster, WA Monitoring Full-Arc TT&C Rover Filmore, CA 13M Brewster, WA (West) Intelsat 901 MEV TT&C/Customer Hagerstown, MD 13M Andover, ME traffic Intelsat 35e TT&C/Customer Hagerstown, MD 13M Andover, ME traffic Intelsat 37e Customer traffic Hagerstown, MD 13M Andover, ME Intelsat 25 TT&C/Customer Hagerstown, MD 13M Andover, ME traffic Full-Arc Launch Support Hagerstown, MD 13M Andover, ME Full-Arc TT&C Rover (East) Hagerstown, MD 13M Andover, ME

Satellite Current Antenna Current Antenna Antenna New Antenna Function Location Size Location Intelsat 14 Customer traffic Atlanta, GA 9M Bogota, Columbia Intelsat 14, 902, TT&C Hagerstown, MD 13M Hartebeesthoek, 903, 904 and 905 and Atlanta, GA South Africa

4.4 TT&C Antennas for the Seven New Galaxy Satellites

In order to meet the accelerated relocation timeline, Intelsat needs to upgrade or build seven antennas to support TT&C operations on the Galaxy replacement satellites. To the greatest extent possible, Intelsat will attempt to re-purpose existing antenna systems that become available as older satellites are retired. A summary of the TT&C antenna requirements for the replacement satellites is specified below:

Satellite TT&C Band Solution Galaxy 17R C Upgrade existing antenna at the Riverside, CA teleport Galaxy 23R C New antenna to be built at the Napa, CA teleport Galaxy 15R C Upgrade existing antenna at the Atlanta, GA teleport Galaxy 12R C Upgrade existing antenna at the Riverside, CA teleport Galaxy 13R Ku Upgrade existing antenna at the Atlanta, GA teleport Galaxy 28R C New antenna to be built at either the Riverside or Napa, CA teleport Galaxy 3CR C New antenna to be built at either the Riverside or Napa, CA teleport

The total cost for Intelsat’s TT&C/Gateway relocation and ground system grooming plan is estimated to be $95 million.28 The following breakdown shows the anticipated spend by site:

Cost Category Paumalu Brewster Andover Total Site work, electrical, civils, HVAC, etc. $9 $17 $22 $48 Antennas & RF 6 15 18 39 Network Equipment 1 2 2 5 Monitoring Equipment N/A 2 1 3 Total: $16 $36 $43 $95

Intelsat is not seeking reimbursement for the work required to relocate antennas to the two international sites noted in this Transition Plan. 5 Work Associated with Repacking the C-Band

In order to successfully clear the 300 MHz as required in the Report and Order, Intelsat will need to partner with customers and earth stations to reconfigure satellite transmissions/carriers and receive

28 The numbers presented in the table are in millions.

sites. The framework for this undertaking is explained generally in this section, then specifically itemized for each customer migration in Section 6 below.

Intelsat has partnered with its customers to develop the individual migration plans since the FCC issued the initial Notice of Proposed Rulemaking in July 2018, when it was evident there would be significant spectrum clearing in the C-band.29 Proposed migration plans for each customer have been refined, with customer inputs, over the course of more than a year. The following steps were taken to share information with customers throughout the process and to finalize their specific migration plans:

• Intelsat has organized monthly C-band customer group calls, as well as held individual meetings on an ongoing basis, to provide its customers with information about the proceeding and to address concerns.

• Each customer has been provided a unique migration plan detailing the impact of the clearing on their own services. If there was customer feedback on specific migration plans, that feedback was incorporated into further iterations of the plan to the extent possible to limit the impact on customer services throughout the plan period.

• These plans have been adjusted over time to account for integration concerns, to adjust the timelines as the clearing dates were finalized, and to compensate for revisions to customer notification requirements.

• Individual plans were finalized and delivered to all customers the week of May 18, 2020.

Intelsat’s plan was built to provide the highest level of certainty to meet the accelerated clearing timelines set forth in the Report and Order. The selection of customers for revisions (frequency, polarization, satellite, or technology upgrades) was an objective-based exercise performed in good faith. The plan assumes compression/technology upgrades for eleven customers in order to reclaim material amounts of capacity. Material changes to the plan to accommodate additional customer moves or upgrades will negatively impact the schedule.

5.1 Process and Communications about Customer Transitions

Clear communications and coordination between Intelsat, its customers, and the earth station operators are critical for the Transition Plan to be a success. The following provides information about the processes that will be used for contacting earth station operators and for coordinating the required work at affiliate locations.

29 Expanding Flexible Use of the 3.7 to 4.2 GHz Band, Notice of Proposed Rulemaking, 33 FCC Rcd. 6915 (2018).

5.1.1 Outreach Effort for Data Collection

Intelsat is currently conducting outreach to all earth station sites listed on the Commission’s Incumbent Earth Stations list.30 This action will ensure that the earth station data listed in the International Bureau Filing System (“IBFS”) database is accurate and it will confirm the current operating environment of each earth station. Intelsat will reconcile this information against its customer affiliate lists. The data compiled will allow Intelsat to define hardware solutions for all earth stations to ensure the “same or better service” standard throughout the clearing process.

Intelsat has contracted with the companies listed below to perform the outreach, to develop the affiliate level transition plans, and to ensure customer migrations are implemented within the defined timeframes:

1. USSI Global (Melbourne, Florida): cable affiliates

2. WESCO [formerly Satellite Engineering Group] (Kansas City, Missouri): broadcast, radio and religious affiliates

3. ATCi (Chandler, Arizona): Simulsat (multi-satellite antennas) antenna filtering

4. Convergent Media (Alpharetta, Georgia): data analysis and work order management

Validated affiliate data will be captured in a centralized database and used to generate earth station- specific work orders that will be executed by one of Intelsat’s equipment installers.

5.1.2 Scheduling Process

Intelsat installers will contact each earth station operator as required to schedule a service window during the dual illumination period outlined in each customer’s individual migration plan. During the initial scheduling call, the installer will discuss the work to be performed with the site contact identified during outreach or their designated proxy. The installer will seek to understand site policies and access requirements, confirm the scope of the work order and coordinate the service window. If the earth station operator identifies a site-specific technical issue on the scheduling call, the installer may choose to conduct a site survey to understand the nature of the problem and to identify a mutually agreeable solution. Once the solution is fully defined, the installer will seek approval for any identified non-standard work from Intelsat’s program manager, will draft a work order and will dispatch the installation team to complete the work at the designated date and time. The site contact will be asked to sign off on the work order once the work is completed.

30 See International Bureau Releases List of Incumbent Earth Stations in The 3.7-4.2 GHz Band in The Contiguous United States, Public Notice, IB Docket No. 20-205, DA 20-823, App’x. (Aug. 3, 2020), https://docs.fcc.gov/public/attachments/DA-20-823A2.pdf.

5.1.3 Engineering for Site-Specific Technical Challenges

If the earth station operator identifies a site-specific technical issue during the maintenance window, the installer will work with the site contact to document any change orders that may arise and refine the plan to complete the work. The site contact will be asked to sign off on the final work order once the work is completed.

Intelsat has designed its antenna seeding program on Galaxy 23 and Galaxy 18 to utilize 3.7M receive antennas throughout CONUS. If there is a legitimate circumstance where a 3.7M antenna cannot be installed, Intelsat’s installers will work with earth station site technical contacts to engineer a suitable solution. In the event a non-standard solution is needed at the site, the installer, in conjunction with the site technical contact, will specify the final solution and will document the work that was performed.

The Commission’s established framework in the Report and Order does not allow for reimbursement of anything other than reasonable transition costs. It is also explicit about the timelines required for clearing. As such, requests by covered incumbent earth station operators for larger antennas, for supplemental accessories, or for a different brand antenna with similar performance characteristics will not be accommodated.

If a solution cannot be negotiated to move work forward in any of the scenarios above, the issue will be escalated to the Relocation Coordinator as detailed in the Report and Order.

5.1.4 Self-installation and Reimbursement of Actual Expenses

Some earth station operators, who have chosen not to opt out and assume full responsibility for the work required at their site, have asked for the flexibility to perform installation work on their own. Intelsat fully supports self-installation and reimbursement of actual expenses directly to the earth station operators by the Relocation Payment Clearinghouse, so long as the earth station operator seeking this particular arrangement agrees to abide by the schedule contained in the Transition Plan and the Report and Order.

Intelsat will ask operators who intend to self-install to submit in writing their intention and to certify to Intelsat that the work has been completed as planned. In these cases, the earth station operator will be responsible for seeking reimbursement for the certified work order through the Relocation Payment Clearinghouse.

5.2 Earth Station Change Types

In the customer migration plans, each transition can require one or more changes to the customer’s service. These changes necessitate that specific work be performed at the earth stations that receive a customer’s programming. The description of each potential earth station change type is identified below. Note that in the following sections, any work Intelsat commits to complete is for eligible earth stations that have not opted out of satellite operator assistance (unless otherwise noted).

Change Type

• N – No change to satellite, frequency, or polarity (service remains “as-is”) • F – Frequency change • R – Transponder reassignment of in-orbit protection bandwidth • P – Polarity change • S – Satellite change • C – Compression required

5.2.1 Frequency Change [F]

The simplest earth station change is when a service moves from one frequency to another on the same satellite without a change in polarization. The associated work involved at the earth station is to retune the receiver equipment to accept the signal at the new frequency. This work is routine, as satellite operators groom services on satellites and earth stations perform receiver retuning in the normal course of business. Generally, Intelsat will not need to send a technician out to perform these types of frequency changes unless: 1) the frequency change is part of additional work being performed at the same time, such as a filter installation or an antenna repoint; or 2) the earth station owner explicitly requests an installer perform the task due to lack of technical expertise at the site or if an unexpected issue arises in making the change.

5.2.2 Transponder Reassignment of In-Orbit Protection Bandwidth [R]

This change is relevant only for customers who have purchased Restoration services. As a result of the clearing process, some customers are being asked to relocate their Restoration capacity to another frequency or satellite. This change requires no actual work on the ground or satellite during the clearing period but is noted to account for the changes to the overall loading plans of each satellite.

5.2.3 Polarity Changes [P]

Polarity changes occur when a service moves to a new frequency on the satellite and that frequency uses the opposite polarity (e.g., horizontal vs. vertical). The antenna feed at earth stations that receive that service will need to be able to accept the alternate polarity. In some cases, an adjustment or replacement to the antenna feed may need to be performed. Intelsat will send an installer to perform this work during the dual illumination period.

5.2.4 Satellite Changes [S]

In order to repack services into the upper 200 MHz, some of Intelsat’s customers have been asked to move to a different Intelsat satellite. These types of transitions are not unusual, are commercially and technically reasonable, and involve a dual illumination of services so that earth stations may reconfigure antennas and receivers to the new satellite/location without loss of service.

In order to increase the supply of capacity for Distribution services in the Galaxy cable arc, Intelsat will launch a supplemental antenna program for Galaxy 18 and Galaxy 23. The antenna program

will ensure that all satellites in the cable arc are 100% penetrated and will provide customers with service continuity throughout the clearing process. Intelsat intends to supply American-made 3.7M single or dual-feed antennas as part of this supplemental program. Customers will migrate to Galaxy 18 and Galaxy 23 once the antenna seeding program is completed in 2021.

5.2.5 Compression/Technology Upgrades Required [C]

In order to achieve the spectrum reclamation directed by the Commission, Intelsat will need to deploy compression upgrades with selected customers. Intelsat has identified and conferred with the customers whose compression upgrades will yield the most spectrum gains/reclamation. The effect of the compression upgrades is discussed in Section 3.3.

Compression and technology upgrades require close coordination between Intelsat’s customers, Intelsat, and the earth stations receiving the new equipment. Intelsat will work with each of the customers that are upgrading to define the equipment required and to ensure deployment by the phase end dates. Customers will identify specific earth station requirements by site and select, in conjunction with their vendors, the quantity of receivers required at each receive site. Intelsat will be responsible for ordering the materials specified on each customer’s bill of materials from the applicable vendor and will deliver the materials to the earth station owner for installation.

Intelsat’s installers will offer turnkey installation services for Incumbent Earth Stations whose operators who have not opted out and taken the lump sum. This will include shipping required IRDs to earth stations, labeling the equipment in a standard, easily-understandable format for the earth station operators, and, where necessary, racking and cabling the equipment in the earth station facility under the direction of the earth station technical resource assigned to sign off on the work.

In some cases, temporary cooling, floor space, or power may be required while the additional IRDs are added and before legacy IRDs can be retired. In these rare cases, Intelsat and its installers will design/procure commercially reasonable temporary solutions to alleviate the bottleneck of power, cooling, and floor space. If an earth station requires long-term adjustments to core power, cooling, or floor space, Intelsat expects the earth station operators to make the upgrades and seek reimbursement directly from the Relocation Payment Clearinghouse for those expenses.

5.3 Filter Installation

All CONUS earth stations will require the installation of a passband filter to mitigate potential interference from 5G signals, and some earth stations will require an interim filter, as explained below. Intelsat’s installers will provide and install a filter for every qualified antenna feed at earth stations that Intelsat claims responsibility for in Section 7 of this Transition Plan.31 Given the universal application of the filters, the installations are not reflected in the Transition Plan as a distinct change type. Each filter will have the following characteristics:

31 Section 7 of Intelsat’s Transition Plan will be revised once it is known which earth stations have opted out.

1. The filters are passive and require no electrical power to work.

2. The filters are generally less than 12” long, made of aluminum and bolt onto the antenna feed. The specification sheet for the filter Intelsat will be using will be posted on the Intelsat C-band microsite in Q3 2020, which will be accessible via http://intelsatcbandtransition.com.

3. The filter is also designed to serve as an altimeter radar filter. Thus, in cases where existing antenna feeds have an altimeter filter installed, Intelsat’s implementation vendors will remove the altimeter filter and replace it with the new dual-purpose (5G and altimeter) filter.

5.3.1 Filter Versions

The Report and Order’s accelerated timeline specifies the release of the lower 300 MHz spectrum in two phases, allowing mobile networks to begin operations in 46 PEAs as early as December 6, 2021 (Phase I). In order to address the two-phased approach of the accelerated spectrum clearing, Intelsat has developed two filters and a deployment plan that allows for the filtering of satellite transmissions in the defined timeframe. The version of the filter to be installed will be based on the frequency range in which an earth station is receiving programming as of the milestone dates.

The “Blue” filter version will be deployed to filter spectrum from 3700-4000 MHz and will allow the earth stations to receive transmissions from 4000 to 4200 MHz.

The “Red” filter version will be deployed to filter spectrum from 3700-3820 MHz and will allow the earth stations to receive transmissions from 3820 to 4200 MHz.

5.3.2 Phase I Filtering

All earth stations in and around the top 46 PEAs must have a filter installed by the Phase I deadline (December 5, 2021) or be at risk of interference from 5G base stations being deployed. Intelsat has identified a preliminary list of earth stations impacted in Phase I in Appendix 2.32

Any earth station antenna feeds in these PEAs receiving programming in the frequency range of 3820-4000 MHz after December 5, 2021 will need to have Red filters installed. These filters will be replaced by Blue filters in Phase II.

Any earth station antenna feed in these PEAs that receives programming only in the 4000-4200 MHz range will only require the installation of a Blue filter.

32 Intelsat has compiled a list of claimed earth stations by physical location/address. These physical locations are comprised, in many cases, of multiple incumbent earth station antenna records from the Commission’s Incumbent Earth Station list. Intelsat’s methodology is further described in section 7.1.

5.3.3 Phase II Filtering

By the December 5, 2023, the Phase II deadline, all CONUS receive antenna feeds will be equipped with Blue filters. This includes replacement of the Red filters installed in Phase I with Blue filters.

Intelsat will clear spectrum starting at the bottom of the frequency range, and then move higher. Customers located in the frequency range of 3700-3820 MHz will be transitioned to their end state location in the upper 380 MHz during Phase I. Any services in the frequency range of 3820-4000 MHz will be transitioned to their end state in Phase II. In both phases, filters can only be installed after the services have been migrated to the end state for that phase. Installing filters before this point in time would cause disruption to the service.

At many cable headends, antenna feeds take multiple services off the same satellite and the earth station filter cannot be installed until the last service is cleared on the relevant satellite. Due to this, the Intelsat Transition Plan relies on cable headend filter installations occurring exclusively within the last 6 months of each phase. This will ensure that filters are not installed while services are not yet cleared.

5.3.4 Coordination with SES for Cable Headends and Multi-feed Antenna Filtering

The Report and Order holds incumbent satellite operators individually responsible for migrating customer services out of the lower 300 MHz. At cable headends, incumbent earth station operators are likely to have antennas that access multiple satellite operators, which could create logistical challenges if migration is not managed efficiently.

Given the added complexity at these earth stations, Intelsat and SES have agreed to coordinate some of the commonly required activities. Both operators will take individual responsibility for their antenna seeding plans, for their customer compression upgrades and for any other customer specific work required at an earth station. After the customer migrations are completed, Intelsat and SES have agreed to coordinate filter installation for incumbent earth stations located at cable headends and any other incumbent earth station sites that have antennas accessing both Intelsat and SES satellites. Such coordination will minimize the burden on the earth station technical staff and will reduce the risk of issues occurring during the filter installation process.

SES and Intelsat have also agreed to voluntarily install filters on any unregistered antennas located at Incumbent Earth Station sites at the same time they install filters on the collocated Incumbent Earth Stations that receive services from either SES or Intelsat satellites. The fact that SES and Intelsat will install filters on these unregistered antennas does not change their status with respect to the Report and Order and therefore, these unregistered antennas will not be eligible for interference protection from future licensed terrestrial services.33 Furthermore, because SES and Intelsat are volunteering to take on this filtering activity, which is outside the scope of the obligations imposed by the Report and Order, the unregistered antennas subject to this agreement will not be considered part of SES or Intelsat’s accelerated clearing obligations or relevant for either operator’s accelerated clearing certification. Finally, for the avoidance of doubt, SES and Intelsat will not install filters or

33 See Report and Order, paras. 116, 123.

take any responsibility for transitioning unregistered antennas that are not collocated with an Incumbent Earth Station pointed to an Intelsat or SES satellite.

The total cost of Intelsat’s repacking and customer migration plan is estimated to be $400 million. The following breakdown shows the cost categories:34

Cost Category Scope Cost • Earth station change orders • Filter hardware and installation Customer • Dual illumination costs $100 Migration • Antenna hardware and installation • Estimate for Non-Standard Costs associated with Earth Station Change Orders • Uplink compression hardware • IRDs hardware for compression customers Compression • Configuration, Test, and IRD Shipping Costs $300 • Estimate for Non-Standard Costs associated with Compression Upgrades

5.3.5 Earth Station Operator Responsibilities

Intelsat plans to standardize its approach to earth station owners to ensure roles and responsibilities are clear throughout implementation. Intelsat is undertaking substantial work and risk to meet the Commission’s ambitious spectrum clearing timeline and understands that the service migrations required in this Transition Plan may be challenging for earth station owners. While the process defined above is intended to offset much of the technical work that would be required at the receive earth stations (on a cost-free basis to the earth station operators), it is dependent on earth station operators providing local site access, technical input and cooperation.

Each earth station operator is responsible for facilitating access to the site on a timely and reasonable basis. Intelsat will ask earth station operators to identify and provide access to a technical resource representative who is authorized to approve the work. Intelsat’s installers cannot begin work without an assigned representative.

34 The numbers presented in the table are in millions.

6 Customer Migration Plans

The following section provides the detailed migration plans for customer services. Three different views of the same migration plan are presented: (1) a chronological view of the planned transition activity, (2) a customer-centric view of the transitions, and (3) a view of satellite transponder loading across the migration phases. Rows that have been shaded grey denote completed transition activities.

6.1 Transition Plan (Chronological)

The below tables illustrate the detailed transition activities planned in chronological order across Phase I and Phase II of the migration.

6.1.1 Table 1 Phase I Grooming Plan Transition Activities (Chronological)

Phase I Lower Upper Phase 1 Lower Upper Phase I Duration Phase I Change Start Freq. Freq. End Freq. Freq. Technology Start Date (Days) End Date Type Customer Sat/Trx (MHz) (MHz) Sat/Trx (MHz) (MHz) Upgrade 05-Dec-19 548 05-Jun-21 C, F NPR G-16 01C 3702 3738 G-16 23C 4142 4178 Audio/Video 05-Dec-19 548 05-Jun-21 C NPR G-16 23C 4142 4178 G-16 23C 4142 4178 Audio/Video 05-Dec-19 239 31-Jul-20 C, F NPR G-16 07C 3822 3858 G-16 23C 4142 4178 Audio/Video 28-Feb-20 90 28-May-20 S, P, F GCI G-18 18C 4042 4078 H-3e 29-Feb-20 90 29-May-20 S, P, F GCI G-18 19C 4062 4098 H-3e 02-Apr-20 90 01-Jul-20 S, P, F GCI G-18 17C 4022 4058 H-3e 03-Apr-20 90 02-Jul-20 S, P, F GCI G-18 15C 3982 4018 H-3e 03-Apr-20 90 02-Jul-20 S, P, F GCI G-18 23C 4142 4178 H-3e 04-Apr-20 90 03-Jul-20 S, P, F GCI G-18 11C 3902 3938 H-3e 08-Apr-20 90 07-Jul-20 S, P, F GCI G-18 21C 4102 4138 H-3e 11-Apr-20 90 10-Jul-20 S, P, F GCI G-18 20C 4082 4118 H-3e 20-May-20 0 20-May-20 R Disney OU Pool G-16 08C 3842 3878 G-16 09C 3862 3898 04-Jun-20 5 09-Jun-20 F Televisa G-16 20C 4082 4118 G-16 08C 3842 3878 10-Jun-20 0 10-Jun-20 R FoxCorp Restoration G-16 13C 3942 3978 G-16 20C 4082 4118 10-Jun-20 20 30-Jun-20 F Televisa G-19 16C 4002 4038 G-19 08C 3842 3878 11-Jun-20 0 11-Jun-20 R Disney OU Pool G-16 17C 4022 4058 G-16 13C 3942 3978 30-Jun-20 0 30-Jun-20 R Disney OU Pool G-16 22C 4122 4158 G-16 11C 3902 3938 01-Jul-20 62 1-Sep-20 F EWTN G-15 05C 3782 3818 G-15 23C 4142 4178 01-Jul-20 30 31-Jul-20 F Sinclair G-17 06C 3802 3838 G-17 10C 3882 3918

Phase I Lower Upper Phase 1 Lower Upper Phase I Duration Phase I Change Start Freq. Freq. End Freq. Freq. Technology Start Date (Days) End Date Type Customer Sat/Trx (MHz) (MHz) Sat/Trx (MHz) (MHz) Upgrade 01-Jul-20 30 31-Jul-20 F Sinclair G-17 17C 4022 4058 G-17 15C 3982 4018 01-Jul-20 30 31-Jul-20 F The CW G-17 01C 3702 3738 G-17 19C 4062 4098 01-Jul-20 30 31-Jul-20 F US Government G-3C 24C 4162 4198 G-3C 08C 3842 3878 01-Jul-20 90 29-Sep-20 S, F TV Azteca G-19 03C 3742 3778 G-16 22C 4122 4158 01-Jul-20 9 10-Jul-20 F Televisa G-16 24C 4162 4198 G-16 12C 3922 3958 01-Jul-20 180 28-Dec-20 F Discovery G-13 14C 3962 3998 G-13 24C 4162 4198 01-Aug-20 0 01-Aug-20 R ViacomCBS G-3C 12C 3922 3958 G-3C 24C 4162 4198 01-Aug-20 30 31-Aug-20 F Word Network G-17 03C 3742 3778 G-17 19C 4062 4098 01-Oct-20 30 31-Oct-20 F LeSea Broadcasting G-16 15C 3982 4018 G-16 17C 4022 4058 01-Oct-20 90 30-Dec-20 C, F Encompass G-13 06C 3802 3838 G-13 16C 4002 4038 AVC 01-Oct-20 90 30-Dec-20 C, S, F Encompass G-14 05C 3782 3818 G-13 16C 4002 4038 AVC 01-Oct-20 90 30-Dec-20 C, S, P, F Encompass G-17 21C 4102 4138 G-13 23C 4142 4178 AVC 29-Dec-20 0 29-Dec-20 R GCI Restoration G-13 24C 4162 4198 G-13 14C 3962 3998 31-Dec-20 0 31-Dec-20 R GCI Restoration G-13 16C 4002 4038 G-13 06C 3802 3838 31-Dec-20 90 31-Mar-21 C, F FoxCorp G-17 05C 3782 3818 G-17 21C 4102 4138 HEVC 01-Jan-21 30 31-Jan-21 F Rignet G-19 17C 4022 4058 G-19 09C 3862 3898 01-Jan-21 90 01-Apr-21 C, F Disney G-14 11C 3902 3938 G-14 07C 3822 3858 HEVC 01-Jan-21 90 01-Apr-21 C, S, P, F Disney G-15 02C 3722 3758 G-17 17C 4022 4058 HEVC 01-Jan-21 90 01-Apr-21 C, P, F Disney G-17 02C 3722 3758 G-17 17C 4022 4058 HEVC 01-Jan-21 90 01-Apr-21 C FoxCorp G-15 10C 3882 3918 G-15 10C 3882 3918 HEVC 01-Jan-21 90 01-Apr-21 C FoxCorp G-17 16C 4002 4038 G-17 16C 4002 4038 HEVC 01-Feb-21 30 03-Mar-21 F BBC / Intelsat MCPC platform G-13 04C 3762 3798 G-13 20C 4082 4118 01-Feb-21 30 03-Mar-21 F Caracol / Intelsat MCPC platform G-13 04C 3762 3798 G-13 20C 4082 4118 01-Feb-21 30 03-Mar-21 F Mega Media / Intelsat MCPC platform G-13 04C 3762 3798 G-13 20C 4082 4118 01-Feb-21 30 03-Mar-21 F NHK / Intelsat MCPC platform G-13 04C 3762 3798 G-13 20C 4082 4118 01-Feb-21 60 02-Apr-21 P, F AT&T Sports G-17 20C 4082 4118 G-17 11C 3902 3938 01-Feb-21 90 02-May-21 S, F ATCi G-13 18C 4042 4078 G-23 23C 4142 4178 01-Feb-21 90 02-May-21 S, F Comcast/NBC-U G-14 04C 3762 3798 G-18 19C 4062 4098 01-Feb-21 90 02-May-21 S, F Herring Networks G-13 18C 4042 4078 G-23 23C 4142 4178 01-Feb-21 90 02-May-21 S, F IKO Media Group G-23 24C 4162 4198 G-18 15C 4000 4018 01-Feb-21 90 02-May-21 C, S, F MLB G-13 01C 3702 3738 G-18 21C 4102 4138 HEVC 01-Feb-21 90 02-May-21 C, S, F MLB G-17 04C 3762 3798 G-18 21C 4102 4138 HEVC 01-Feb-21 90 02-May-21 S, P, F Trinity Broadcasting Network G-14 01C 3702 3738 G-18 17C 4022 4058 28-Feb-21 0 28-Feb-21 R GCI Restoration G-13 12C 3922 3958 G-13 07C 3822 3858 01-Mar-21 90 30-May-21 S, P, F CenturyLink G-23 04C 3762 3798 G-13 12C 3922 3958 01-Mar-21 90 30-May-21 C, P, F Sinclair G-15 04C 3762 3798 G-15 21C 4102 4138 HEVC

6.1.2 Table 2 Phase II Grooming Plan Transition Activities (Chronological)

Phase II Lower Upper Phase II Lower Upper Phase II Duration Phase II Change Start Freq. Freq. End Freq. Freq. Technology Start Date (Days) End Date Type Customer Sat/Trx (MHz) (MHz) Sat/Trx (MHz) (MHz) Upgrade 01-Jun-21 210 28-Dec-21 C, F Discovery G-13 22C 4122 4158 G-13 24C 4162 4198 AVC 06-Dec-21 30 05-Jan-22 F FoxCorp G-15 10C 3882 3918 G-15 24C 4162 4198 HEVC 06-Dec-21 30 05-Jan-22 F The SPACECONNECTION G-19 07C 3822 3858 G-19 17C 4022 4058 06-Dec-21 30 05-Jan-22 F Tri-State Christian TV G-17 14C 3962 3998 G-17 18C 4042 4078 06-Dec-21 30 05-Jan-22 F US Government G-16 10C 3882 3918 G-16 24C 4162 4198 06-Dec-21 60 04-Feb-22 P, F Globecast G-19 13C 3942 3978 G-19 18C 4042 4078 06-Dec-21 60 04-Feb-22 P, F Shepherd's Chapel G-16 16C 4002 4038 G-16 15C 4000 4018 06-Dec-21 60 04-Feb-22 P, F United Teleports Inc. G-19 10C 3882 3918 G-19 17C 4022 4058 06-Dec-21 90 06-Mar-22 S, F Comcast/NBC-U G-17 07C 3822 3858 G-18 20C 4082 4118

Phase II Lower Upper Phase II Lower Upper Phase II Duration Phase II Change Start Freq. Freq. End Freq. Freq. Technology Start Date (Days) End Date Type Customer Sat/Trx (MHz) (MHz) Sat/Trx (MHz) (MHz) Upgrade 06-Dec-21 90 06-Mar-22 S, F LinkUp G-3C 08C 3842 3878 G-19 17C 4022 4058 06-Dec-21 90 06-Mar-22 S, F The SPACECONNECTION G-28 15C 3962 3998 G-19 17C 4022 4058 06-Dec-21 90 06-Mar-22 S, F Tribune G-14 13C 3942 3978 G-18 18C 4042 4078 29-Dec-21 90 29-Mar-22 C Encompass G-13 23C 4142 4178 G-13 23C 4142 4178 AVC 04-Jan-22 90 04-Apr-22 C, P, F Encompass G-13 13C 3942 3978 G-13 22C 4122 4158 AVC 04-Jan-22 90 04-Apr-22 C, S, P, F Encompass G-14 10C 3882 3918 G-13 22C 4122 4158 AVC 05-Jan-22 30 04-Feb-22 F PROLASA G-19 15C 3982 4018 G-19 17C 4022 4058 01-Feb-22 30 03-Mar-22 F CenturyLink G-13 12C 3922 3958 G-13 18C 4042 4078 05-Feb-22 90 06-May-22 S, F The SPACECONNECTION G-3C 10C 3882 3918 G-16 16C 4002 4038 05-Feb-22 90 06-May-22 S, F The SPACECONNECTION G-3C 14C 3962 3998 G-16 18C 4042 4078 01-Mar-22 90 30-May-22 C, F Starz G-13 09C 3862 3898 G-13 17C 4022 4058 HEVC 01-Mar-22 90 30-May-22 C, F Starz G-13 15C 3982 4018 G-13 17C 4022 4058 HEVC 01-Mar-22 90 30-May-22 C, F Starz G-15 08C 3842 3878 G-15 20C 4082 4118 HEVC 01-Mar-22 90 30-May-22 C, F Starz G-15 14C 3962 3998 G-15 20C 4082 4118 HEVC 04-Mar-22 0 04-Mar-22 R GCI Restoration G-13 18C 4042 4078 G-13 12C 3922 3958 07-Mar-22 90 05-Jun-22 C A&E G-14 23C 4142 4178 G-14 23C 4142 4178 AVC 07-Mar-22 90 05-Jun-22 C, F A&E G-14 21C 4102 4138 G-14 23C 4142 4178 AVC 31-May-22 90 29-Aug-22 C, F Encompass G-13 11C 3902 3938 G-13 15C 4000 4018 AVC 06-Jun-22 90 04-Sep-22 C WarnerMedia G-15 18C 4042 4078 G-15 18C 4042 4078 HEVC 06-Jun-22 90 04-Sep-22 C WarnerMedia G-15 19C 4062 4098 G-15 19C 4062 4098 HEVC 06-Jun-22 90 04-Sep-22 C, F WarnerMedia G-14 15C 3982 4018 G-14 21C 4102 4138 HEVC 06-Jun-22 90 04-Sep-22 C, F WarnerMedia G-14 16C 4002 4038 G-14 20C 4082 4118 HEVC 06-Jun-22 90 04-Sep-22 C, F WarnerMedia G-15 15C 3982 4018 G-15 19C 4062 4098 HEVC 06-Jun-22 90 04-Sep-22 C, F WarnerMedia G-15 16C 4002 4038 G-15 18C 4042 4078 HEVC 06-Jun-22 90 04-Sep-22 C, P, F WarnerMedia G-14 17C 4022 4058 G-14 20C 4082 4118 HEVC 01-Sep-22 90 30-Nov-22 S, P, F AT&T Sports G-17 11C 3902 3938 G-18 23C 4142 4178 05-Sep-22 30 05-Oct-22 F C-SPAN G-14 12C 3922 3958 G-14 16C 4002 4038 05-Sep-22 30 05-Oct-22 F INSP G-15 17C 4022 4058 G-15 15C 4000 4018 05-Sep-22 30 05-Oct-22 F Overon G-14 11C 3902 3938 G-14 17C 4022 4058 05-Sep-22 90 04-Dec-22 C, S Encompass G-23 15C 3982 4018 G-14 15C 4000 4018 HEVC 01-Oct-22 90 30-Dec-22 C ViacomCBS G-19 19C 4062 4098 G-19 19C 4062 4098 HEVC 01-Oct-22 90 30-Dec-22 C ViacomCBS G-19 21C 4102 4138 G-19 21C 4102 4138 HEVC 01-Oct-22 90 30-Dec-22 C, P, F ViacomCBS G-19 20C 4082 4118 G-19 19C 4062 4098 HEVC 01-Oct-22 90 30-Dec-22 C, S, F ViacomCBS G-28 10C 3862 3898 G-23 21C 4102 4138 HEVC 01-Oct-22 90 30-Dec-22 C, S, P, F ViacomCBS G-28 09C 3842 3878 G-23 21C 4102 4138 HEVC

Phase II Lower Upper Phase II Lower Upper Phase II Duration Phase II Change Start Freq. Freq. End Freq. Freq. Technology Start Date (Days) End Date Type Customer Sat/Trx (MHz) (MHz) Sat/Trx (MHz) (MHz) Upgrade 01-Oct-22 90 30-Dec-22 S, F ViacomCBS G-28 15C 3962 3998 G-23 24C 4162 4198 01-Oct-22 90 30-Dec-22 S, F ViacomCBS G-28 16C 3982 4018 G-23 23C 4142 4178 06-Oct-22 90 04-Jan-23 S, F Sinclair G-17 22C 4122 4158 G-15 16C 4002 4038 HEVC 06-Oct-22 90 04-Jan-23 S, F Sinclair G-17 23C 4142 4178 G-15 17C 4022 4058 HEVC 06-Oct-22 90 04-Jan-23 S, P, F Sinclair G-17 08C 3842 3878 G-15 17C 4022 4058 HEVC 06-Oct-22 90 04-Jan-23 S, P, F Sinclair G-17 10C 3882 3918 G-15 17C 4022 4058 HEVC 06-Oct-22 90 04-Jan-23 S, P, F Sinclair G-17 15C 3982 4018 G-15 16C 4002 4038 HEVC 05-Jan-23 30 04-Feb-23 F Altitude Sports & Entertainment G-17 09C 3862 3898 G-17 23C 4142 4178 05-Jan-23 30 04-Feb-23 F AMC G-17 13C 3942 3978 G-17 15C 4000 4018 05-Jan-23 30 04-Feb-23 F BYU G-17 12C 3922 3958 G-17 22C 4122 4158 05-Jan-23 30 04-Feb-23 F The SPACECONNECTION G-17 12C 3922 3958 G-17 22C 4122 4158 01-Feb-23 90 02-May-23 S Sinclair G-23 17C 4022 4058 01-Feb-23 90 02-May-23 S Sinclair G-23 18C 4042 4078 01-Feb-23 90 02-May-23 S Sinclair G-23 19C 4062 4098 01-Feb-23 90 02-May-23 S Sinclair G-23 20C 4082 4118 01-Mar-23 30 31-Mar-23 F Dejero Labs G-19 14C 3962 3998 G-19 16C 4002 4038

6.2 Transition Plan (Customer-Centric)

The tables below illustrate the detailed transition activities planned by customer across Phase I and Phase II.

6.2.1 Table 3 Phase I Grooming Plan Transition Activities (Customer-Centric)

Phase I Lower Upper Phase I Lower Upper Start Freq. Freq. Change Phase I Duration Phase I End Freq. Freq. Technology Customer Sat/Trx (MHz) (MHz) Type Start Date (Days) End Date Sat/Trx (MHz) (MHz) Upgrade Disney G-14 09C 3862 3898 C, S, P, F 01-Jul-21 90 29-Sep-21 G-17 20C 4082 4118 HEVC Disney G-14 11C 3902 3938 C, F 01-Jan-21 90 01-Apr-21 G-14 07C 3822 3858 HEVC Disney G-14 14C 3962 3998 C, S, P, F 01-Apr-21 90 30-Jun-21 G-18 24C 4162 4198 HEVC Disney G-15 02C 3722 3758 C, S, P, F 01-Jan-21 90 01-Apr-21 G-17 17C 4022 4058 HEVC Disney G-17 02C 3722 3758 C, P, F 01-Jan-21 90 01-Apr-21 G-17 17C 4022 4058 HEVC Disney G-18 22C 4122 4158 C 01-Jul-21 90 29-Sep-21 G-18 22C 4122 4158 HEVC Disney OU Pool G-16 08C 3842 3878 R 20-May-20 0 20-May-20 G-16 09C 3862 3898 Disney OU Pool G-16 17C 4022 4058 R 11-Jun-20 0 11-Jun-20 G-16 13C 3942 3978 Disney OU Pool G-16 22C 4122 4158 R 30-Jun-20 0 30-Jun-20 G-16 11C 3902 3938 Encompass G-13 06C 3802 3838 C, F 01-Oct-20 90 30-Dec-20 G-13 16C 4002 4038 AVC Encompass G-14 05C 3782 3818 C, S, F 01-Oct-20 90 30-Dec-20 G-13 16C 4002 4038 AVC Encompass G-17 21C 4102 4138 C, S, P, F 01-Oct-20 90 30-Dec-20 G-13 23C 4142 4178 AVC EWTN G-15 05C 3782 3818 F 01-Jul-20 62 1-Sep-20 G-15 23C 4142 4178 FoxCorp G-15 10C 3882 3918 C 01-Jan-21 90 01-Apr-21 G-15 10C 3882 3918 HEVC FoxCorp G-16 19C 4062 4098 C 01-May-21 122 31-Aug-21 G-16 19C 4062 4098 HEVC FoxCorp G-17 05C 3782 3818 C, F 31-Dec-20 90 31-Mar-21 G-17 21C 4102 4138 HEVC FoxCorp G-17 16C 4002 4038 C 01-Jan-21 90 01-Apr-21 G-17 16C 4002 4038 HEVC FoxCorp G-3C 18C 4042 4078 C 01-May-21 122 31-Aug-21 G-16 19C 4062 4098 HEVC FoxCorp G-3C 19C 4062 4098 C 01-May-21 122 31-Aug-21 G-16 19C 4062 4098 HEVC FoxCorp Restoration G-16 13C 3942 3978 R 10-Jun-20 0 10-Jun-20 G-16 20C 4082 4118 GCI G-18 11C 3902 3938 S, P, F 04-Apr-20 90 03-Jul-20 H-3e GCI G-18 15C 3982 4018 S, P, F 03-Apr-20 90 02-Jul-20 H-3e GCI G-18 17C 4022 4058 S, P, F 02-Apr-20 90 01-Jul-20 H-3e GCI G-18 18C 4042 4078 S, P, F 28-Feb-20 90 28-May-20 H-3e GCI G-18 19C 4062 4098 S, P, F 29-Feb-20 90 29-May-20 H-3e GCI G-18 20C 4082 4118 S, P, F 11-Apr-20 90 10-Jul-20 H-3e GCI G-18 21C 4102 4138 S, P, F 08-Apr-20 90 07-Jul-20 H-3e GCI G-18 23C 4142 4178 S, P, F 03-Apr-20 90 02-Jul-20 H-3e GCI Restoration G-13 12C 3922 3958 R 28-Feb-21 0 28-Feb-21 G-13 07C 3822 3858 GCI Restoration G-13 16C 4002 4038 R 31-Dec-20 0 31-Dec-20 G-13 06C 3802 3838 GCI Restoration G-13 20C 4082 4118 R 04-Mar-21 0 04-Mar-21 G-13 04C 3762 3798 GCI Restoration G-13 24C 4162 4198 R 29-Dec-20 0 29-Dec-20 G-13 14C 3962 3998

Phase I Lower Upper Phase I Lower Upper Start Freq. Freq. Change Phase I Duration Phase I End Freq. Freq. Technology Customer Sat/Trx (MHz) (MHz) Type Start Date (Days) End Date Sat/Trx (MHz) (MHz) Upgrade Herring Networks G-13 18C 4042 4078 S, F 01-Feb-21 90 02-May-21 G-23 23C 4142 4178 IKO Media Group G-23 24C 4162 4198 S, F 01-Feb-21 90 02-May-21 G-18 15C 3982 4018 LeSea Broadcasting G-16 15C 3982 4018 F 01-Oct-20 30 31-Oct-20 G-16 17C 4022 4058 Mega Media / Intelsat MCPC platform G-13 04C 3762 3798 F 01-Feb-21 30 03-Mar-21 G-13 20C 4082 4118 MLB G-13 01C 3702 3738 C, S, F 01-Feb-21 90 02-May-21 G-18 21C 4102 4138 HEVC MLB G-17 04C 3762 3798 C, S, F 01-Feb-21 90 02-May-21 G-18 21C 4102 4138 HEVC NHK / Intelsat MCPC platform G-13 04C 3762 3798 F 01-Feb-21 30 03-Mar-21 G-13 20C 4082 4118 NPR G-16 01C 3702 3738 C, F 05-Dec-19 548 05-Jun-21 G-16 23C 4142 4178 Audio/Video NPR G-16 07C 3822 3858 C, F 05-Dec-19 239 31-Jul-20 G-16 23C 4142 4178 Audio/Video NPR G-16 23C 4142 4178 C 05-Dec-19 548 05-Jun-21 G-16 23C 4142 4178 Audio/Video Overon G-23 22C 4122 4158 S, P, F 02-Apr-21 90 01-Jul-21 G-14 11C 3902 3938 Overon G-23 24C 4162 4198 S, P, F 02-Apr-21 90 01-Jul-21 G-14 11C 3902 3938 Rignet G-19 17C 4022 4058 F 01-Jan-21 30 31-Jan-21 G-19 09C 3862 3898 ShopHQ G-14 03C 3742 3778 P, F 02-Mar-21 60 01-May-21 G-14 22C 4122 4158 Sinclair G-15 04C 3762 3798 C, P, F 01-Mar-21 90 30-May-21 G-15 21C 4102 4138 HEVC Sinclair G-15 20C 4082 4118 C, F 01-Mar-21 90 30-May-21 G-15 22C 4122 4158 HEVC Sinclair G-15 21C 4102 4138 C 01-Mar-21 90 30-May-21 G-15 21C 4102 4138 HEVC Sinclair G-15 22C 4122 4158 C 01-Mar-21 90 30-May-21 G-15 22C 4122 4158 HEVC Sinclair G-17 06C 3802 3838 F 01-Jul-20 30 31-Jul-20 G-17 10C 3882 3918 Sinclair G-17 08C 3842 3878 C 01-Jun-21 90 30-Aug-21 G-17 08C 3842 3878 HEVC Sinclair G-17 10C 3882 3918 C 01-Jun-21 90 30-Aug-21 G-17 10C 3882 3918 HEVC Sinclair G-17 15C 3982 4018 C 01-Jun-21 90 30-Aug-21 G-17 15C 3982 4018 HEVC Sinclair G-17 17C 4022 4058 F 01-Jul-20 30 31-Jul-20 G-17 15C 3982 4018 Sinclair G-17 22C 4122 4158 C 01-Jun-21 90 30-Aug-21 G-17 22C 4122 4158 HEVC Sinclair G-17 23C 4142 4178 C 01-Jun-21 90 30-Aug-21 G-17 23C 4142 4178 HEVC Televisa G-16 20C 4082 4118 F 04-Jun-20 5 09-Jun-20 G-16 08C 3842 3878 Televisa G-16 24C 4162 4198 F 01-Jul-20 9 10-Jul-20 G-16 12C 3922 3958 Televisa G-19 16C 4002 4038 F 10-Jun-20 20 30-Jun-20 G-19 08C 3842 3878 The CW G-17 01C 3702 3738 F 01-Jul-20 30 31-Jul-20 G-17 19C 4062 4098 Trinity Broadcasting Network G-14 01C 3702 3738 S, P, F 01-Feb-21 90 02-May-21 G-18 17C 4022 4058 TV Azteca G-19 03C 3742 3778 S, F 01-Jul-20 90 29-Sep-20 G-16 22C 4122 4158 US Government G-13 17C 4022 4058 F 01-May-21 30 31-May-21 G-13 05C 3782 3818

Phase I Lower Upper Phase I Lower Upper Start Freq. Freq. Change Phase I Duration Phase I End Freq. Freq. Technology Customer Sat/Trx (MHz) (MHz) Type Start Date (Days) End Date Sat/Trx (MHz) (MHz) Upgrade US Government G-3C 24C 4162 4198 F 01-Jul-20 30 31-Jul-20 G-3C 08C 3842 3878 ViacomCBS G-3C 12C 3922 3958 R 01-Aug-20 0 01-Aug-20 G-3C 24C 4162 4198 Word Network G-17 03C 3742 3778 F 01-Aug-20 30 31-Aug-20 G-17 19C 4062 4098

6.2.2 Table 4 Phase II Grooming Plan Transition Activities (Customer-Centric)

Phase II Lower Upper Phase II Lower Upper Start Freq. Freq. Change Phase II Duration Phase II End Freq. Freq. Technology Customer Sat/Trx (MHz) (MHz) Type Start Date (Days) End Date Sat/Trx (MHz) (MHz) Upgrade A&E G-14 21C 4102 4138 C, F 07-Mar-22 90 05-Jun-22 G-14 23C 4142 4178 AVC A&E G-14 23C 4142 4178 C 07-Mar-22 90 05-Jun-22 G-14 23C 4142 4178 AVC Altitude Sports & Entertainment G-17 09C 3862 3898 F 05-Jan-23 30 04-Feb-23 G-17 23C 4142 4178 AMC G-17 13C 3942 3978 F 05-Jan-23 30 04-Feb-23 G-17 15C 4000 4018 AT&T Sports G-17 11C 3902 3938 S, P, F 01-Sep-22 90 30-Nov-22 G-18 23C 4142 4178 BYU G-17 12C 3922 3958 F 05-Jan-23 30 04-Feb-23 G-17 22C 4122 4158 CenturyLink G-13 12C 3922 3958 F 01-Feb-22 30 03-Mar-22 G-13 18C 4042 4078 Comcast/NBC-U G-17 07C 3822 3858 S, F 06-Dec-21 90 06-Mar-22 G-18 20C 4082 4118 C-SPAN G-14 12C 3922 3958 F 05-Sep-22 30 05-Oct-22 G-14 16C 4002 4038 Dejero Labs G-19 14C 3962 3998 F 01-Mar-23 30 31-Mar-23 G-19 16C 4002 4038 Discovery G-13 22C 4122 4158 C, F 01-Jun-21 210 28-Dec-21 G-13 24C 4162 4198 AVC Encompass G-13 11C 3902 3938 C, F 31-May-22 90 29-Aug-22 G-13 15C 4000 4018 AVC Encompass G-13 13C 3942 3978 C, P, F 04-Jan-22 90 04-Apr-22 G-13 22C 4122 4158 AVC Encompass G-13 23C 4142 4178 C 29-Dec-21 90 29-Mar-22 G-13 23C 4142 4178 AVC Encompass G-14 10C 3882 3918 C, S, P, F 04-Jan-22 90 04-Apr-22 G-13 22C 4122 4158 AVC Encompass G-23 15C 3982 4018 C, S 05-Sep-22 90 04-Dec-22 G-14 15C 4000 4018 HEVC FoxCorp G-15 10C 3882 3918 F 06-Dec-21 30 05-Jan-22 G-15 24C 4162 4198 HEVC GCI Restoration G-13 18C 4042 4078 R 04-Mar-22 0 04-Mar-22 G-13 12C 3922 3958 Globecast G-19 13C 3942 3978 P, F 06-Dec-21 60 04-Feb-22 G-19 18C 4042 4078 INSP G-15 17C 4022 4058 F 05-Sep-22 30 05-Oct-22 G-15 15C 4000 4018 LinkUp G-3C 08C 3842 3878 S, F 06-Dec-21 90 06-Mar-22 G-19 17C 4022 4058 Overon G-14 11C 3902 3938 F 05-Sep-22 30 05-Oct-22 G-14 17C 4022 4058 PROLASA G-19 15C 3982 4018 F 05-Jan-22 30 04-Feb-22 G-19 17C 4022 4058 Shepherd's Chapel G-16 16C 4002 4038 P, F 06-Dec-21 60 04-Feb-22 G-16 15C 4000 4018

Phase II Lower Upper Phase II Lower Upper Start Freq. Freq. Change Phase II Duration Phase II End Freq. Freq. Technology Customer Sat/Trx (MHz) (MHz) Type Start Date (Days) End Date Sat/Trx (MHz) (MHz) Upgrade Sinclair S 01-Feb-23 90 02-May-23 G-23 17C 4022 4058 Sinclair S 01-Feb-23 90 02-May-23 G-23 18C 4042 4078 Sinclair S 01-Feb-23 90 02-May-23 G-23 19C 4062 4098 Sinclair S 01-Feb-23 90 02-May-23 G-23 20C 4082 4118 Sinclair G-17 08C 3842 3878 S, P, F 06-Oct-22 90 04-Jan-23 G-15 17C 4022 4058 HEVC Sinclair G-17 10C 3882 3918 S, P, F 06-Oct-22 90 04-Jan-23 G-15 17C 4022 4058 HEVC Sinclair G-17 15C 3982 4018 S, P, F 06-Oct-22 90 04-Jan-23 G-15 16C 4002 4038 HEVC Sinclair G-17 22C 4122 4158 S, F 06-Oct-22 90 04-Jan-23 G-15 16C 4002 4038 HEVC Sinclair G-17 23C 4142 4178 S, F 06-Oct-22 90 04-Jan-23 G-15 17C 4022 4058 HEVC Starz G-13 09C 3862 3898 C, F 01-Mar-22 90 30-May-22 G-13 17C 4022 4058 HEVC Starz G-13 15C 3982 4018 C, F 01-Mar-22 90 30-May-22 G-13 17C 4022 4058 HEVC Starz G-15 08C 3842 3878 C, F 01-Mar-22 90 30-May-22 G-15 20C 4082 4118 HEVC Starz G-15 14C 3962 3998 C, F 01-Mar-22 90 30-May-22 G-15 20C 4082 4118 HEVC The SPACECONNECTION G-17 12C 3922 3958 F 05-Jan-23 30 04-Feb-23 G-17 22C 4122 4158 The SPACECONNECTION G-19 07C 3822 3858 F 06-Dec-21 30 05-Jan-22 G-19 17C 4022 4058 The SPACECONNECTION G-28 15C 3962 3998 S, F 06-Dec-21 90 06-Mar-22 G-19 17C 4022 4058 The SPACECONNECTION G-3C 10C 3882 3918 S, F 05-Feb-22 90 06-May-22 G-16 16C 4002 4038 The SPACECONNECTION G-3C 14C 3962 3998 S, F 05-Feb-22 90 06-May-22 G-16 18C 4042 4078 Tribune G-14 13C 3942 3978 S, F 06-Dec-21 90 06-Mar-22 G-18 18C 4042 4078 Tri-State Christian TV G-17 14C 3962 3998 F 06-Dec-21 30 05-Jan-22 G-17 18C 4042 4078 United Teleports Inc. G-19 10C 3882 3918 P, F 06-Dec-21 60 04-Feb-22 G-19 17C 4022 4058 US Government G-16 10C 3882 3918 F 06-Dec-21 30 05-Jan-22 G-16 24C 4162 4198 ViacomCBS G-19 19C 4062 4098 C 01-Oct-22 90 30-Dec-22 G-19 19C 4062 4098 HEVC ViacomCBS G-19 20C 4082 4118 C, P, F 01-Oct-22 90 30-Dec-22 G-19 19C 4062 4098 HEVC ViacomCBS G-19 21C 4102 4138 C 01-Oct-22 90 30-Dec-22 G-19 21C 4102 4138 HEVC ViacomCBS G-28 09C 3842 3878 C, S, P, F 01-Oct-22 90 30-Dec-22 G-23 21C 4102 4138 HEVC ViacomCBS G-28 10C 3862 3898 C, S, F 01-Oct-22 90 30-Dec-22 G-23 21C 4102 4138 HEVC ViacomCBS G-28 15C 3962 3998 S, F 01-Oct-22 90 30-Dec-22 G-23 24C 4162 4198 ViacomCBS G-28 16C 3982 4018 S, F 01-Oct-22 90 30-Dec-22 G-23 23C 4142 4178 WarnerMedia G-14 15C 3982 4018 C, F 06-Jun-22 90 04-Sep-22 G-14 21C 4102 4138 HEVC WarnerMedia G-14 16C 4002 4038 C, F 06-Jun-22 90 04-Sep-22 G-14 20C 4082 4118 HEVC WarnerMedia G-14 17C 4022 4058 C, P, F 06-Jun-22 90 04-Sep-22 G-14 20C 4082 4118 HEVC WarnerMedia G-15 15C 3982 4018 C, F 06-Jun-22 90 04-Sep-22 G-15 19C 4062 4098 HEVC WarnerMedia G-15 16C 4002 4038 C, F 06-Jun-22 90 04-Sep-22 G-15 18C 4042 4078 HEVC WarnerMedia G-15 18C 4042 4078 C 06-Jun-22 90 04-Sep-22 G-15 18C 4042 4078 HEVC WarnerMedia G-15 19C 4062 4098 C 06-Jun-22 90 04-Sep-22 G-15 19C 4062 4098 HEVC

6.3 Satellite Transponder Loading View

The figures below illustrate the progressive clearing of the lower 300 MHz across Intelsat’s impacted satellites during the two phases of the migration.35 The first three diagrams show the current loading, loading at the end of Phase I, and loading at the end of Phase II for the cable satellites. The next three diagrams show the same data for the broadcast satellite fleet.

35 The loading charts below have been revised and are different from those previously proposed by Intelsat as a former member of the C- Band Alliance because the previous proposal assumed that only 200 MHz of the C-band spectrum would be cleared for future overlay licensee use. See C-Band Alliance Notice of Ex Parte Meeting, 6-8 (Feb. 7, 2019), https://ecfsapi.fcc.gov/file/102072699030257/CBA%20- %20Ex%20Parte%20re%20Grooming%20Plans.pdf.

6.3.1 Figure 1 Cable Neighborhoods C-Band Loading – Baseline

6.3.2 Figure 2 Cable Neighborhoods C-Band Loading – End of Phase I

6.3.3 Figure 3 Cable Neighborhoods C-Band Loading – End of Phase II

6.3.4 Figure 4 Broadcast, Radio and Data C-Band Loading - Baseline

6.3.5 Figure 5 Broadcast, Radio and Data C-Band Loading – End of Phase I

6.3.6 Figure 6 Broadcast, Radio and Data C-Band Loading – End of Phase II

6.4 Customer Services Not Requiring a Move

The following customer services are already located in the upper 200 MHz of the band and will require no migration activities. The associated antennas at these customers’ affiliated earth stations will only require the installation of passband filters at the appropriate time to mitigate against future interference from flexible use operations.

Customer Sat/Trx Actualidad Media Group G-19 17C AMC G-14 18C Comcast/NBC-U G-14 19C G-17 24C Disney G-16 21C HDNet G-13 19C NFL Network G-13 21C PAC-12 G-18 16C Univision G-19 22C US Government G-19 17C ViacomCBS G-14 24C

6.5 Non-CONUS Services in the Lower 300 MHz

While most CONUS-based services are being migrated into the upper 200 MHz, Intelsat has stated on the record that certain limited services that do not downlink in CONUS will remain in the lower 300 MHz.36 These critical services are focused on Alaska, the Gulf of Mexico, the Caribbean, Mexico and Central America. Intelsat will transition all such non-CONUS services to the lower 300 MHz of spectrum and consolidate these services on fewer satellites.

Successful completion of the migrations outlined above will clear the lower 300 MHz of all of the CONUS services on Intelsat’s North American arc C-band fleet, leaving only non-CONUS services in the lower 300 MHz on those satellites. 7 Intelsat’s Earth Station Migration Plan 7.1 Earth Station and Antenna Data Set Explained

The Report and Order directs space station operators to submit transition plans that include “(5) the number and location of earth stations antennas currently receiving the space station operator’s transmissions that will need to be transitioned to the upper 200 megahertz; (6) an estimate of the number and location of earth station antennas that will require retuning and/or repointing in order to receive content on new transponder frequencies post-transition.”37

36 See supra note 10. 37 Report and Order, para. 303.

Intelsat has continued to progress its earth station data set since the June 19, 2020 Transition Plan filing and submits revised appendices.

In the appendices to the Transition Plan, Intelsat provides the earth station name and the associated IBFS fields as the Report and Order contemplates. Intelsat is unable to claim the specific earth station antennas it will transition because the data provided through IBFS is insufficient to do so. Instead, Intelsat provides a quantity of Intelsat-claimed antennas identified during outreach, irrespective of incumbency status of particular antennas, at each earth station site based on known or presumed customer affiliate relationships.38 For comparison, Intelsat also includes the quantity of incumbent antennas at each site as specified in the Incumbent Earth Station list.

To help reconcile between Intelsat’s site-level scoping and the Commission’s Incumbent Earth Station list, Intelsat denotes all incumbent earth station antenna records under the respective site within Appendix 1 and 2. Intelsat will then reconcile the antennas list with the Relocation Coordinator during the transition process.

Intelsat notes that the deadline for earth station operators to elect to the opt-out lump sum has not yet passed. Once the lump sum opt-out process concludes, with the Commission’s approval, Intelsat will remove from its lists those earth station operators that opt out from all transition activities. Also, Intelsat’s original earth station data set was compiled at the site (or physical location) level, and that outreach was conducted without attempting to ascertain which antennas pointed at Intelsat satellites were registered at a particular site. In some cases, Intelsat will not know whether an incumbent earth station is its responsibility until its installer arrives at the site to process a work order and can perform a physical assessment. Intelsat will work closely with the Relocation Coordinator throughout the transition to update transition activities and the status of the incumbent earth stations in the overall transition plan.

7.2 Cable Headends

Given Intelsat’s market share of CONUS cable Distribution services, Intelsat is assuming that one or more of Intelsat’s satellites are downlinked at every cable headend. Intelsat estimates that there are approximately 2,500 total cable headends and that approximately 10,000 antennas are currently receiving Intelsat’s customer’s transmissions, all of which require some degree of retuning and/or repointing to support Intelsat’s migration plan.

38 Take, for example, a case where an earth station operator registered one antenna on a site but has three antennas on the site. During outreach, Intelsat determines that two of those antennas are pointed at Intelsat satellites and one at an SES satellite. There is no reliable or accurate way to know whether Intelsat or SES should claim the earth station in this case, so after plans are finalized it is likely that in some cases both Intelsat and SES will have claimed the earth station. Close coordination with the Relocation Coordinator throughout the process is the best path to ensuring all earth stations are remediated without wasting resources or creating unnecessary overlaps.

Based on Intelsat’s analysis of the Incumbent Earth Station list, it estimates that there are approximately 2,000 cable headend sites registered. This list of cable headends is included in Appendix 1 and Appendix 2.

7.3 Galaxy 18 and Galaxy 23 Antenna Seeding

As mentioned in Section 5.2.4, Intelsat will launch a supplemental antenna program for Galaxy 18 and Galaxy 23. The antenna program will ensure that all satellites in the cable arc are 100% penetrated and will provide customers with service continuity throughout the clearing process. While the list of earth stations associated with these customers is not complete, Intelsat will provide antennas where they do not already exist for the following customers’ affiliates:

1. AT&T Sports 2. ATCi 3. Comcast/NBC-U 4. Disney 5. Herring Networks 6. IKO Media Group 7. MLB 8. Tribune 9. Trinity Broadcasting Network 10. Sinclair

7.4 Compression

Intelsat must implement compression and technology upgrades for select customers as part of its Transition Plan in order to free sufficient spectrum to meet the Commission’s objectives. In the table below, Intelsat identifies the specific technology chosen by each content provider that will be compressed and the associated earth station impact.

Customer Technology Work Required A&E AVC No IRDs required Discovery AVC IRD replacements at cable headends Disney HEVC IRD replacements at cable headends Encompass AVC IRD replacements at cable headends FoxCorp HEVC IRD replacements at cable headends MLB HEVC IRD replacements at cable headends NPR Audio/video compression Upgraded modems/terminals at affiliates Sinclair HEVC IRD replacements at cable headends and broadcast affiliates Starz AVC IRD replacements at cable headends WarnerMedia HEVC IRD replacements at cable headends ViacomCBS HEVC IRD replacements at cable headends and broadcast affiliates

Based on customer affiliate data provided to date for customers that will be implementing compression technology upgrades, Intelsat has included the list of sites expected to require IRD upgrades/replacements in Appendix 3. Where possible, these affiliates have been correlated to existing earth stations contained in the IBFS database designated by subsequent Commission Public Notices identifying those that are considered incumbent earth stations. Intelsat’s analysis, in collaboration with Intelsat’s customers, will continue until all affected affiliate earth stations are conclusively identified.

7.5 The Church of Jesus Christ of Latter-Day Saints

The Church of Jesus Christ of Latter-Day Saints is exclusively Intelsat’s customer and has an extensive network of approximately 3,450 earth stations, the majority of which have a single antenna that will require retuning to support the planned frequency change outlined in Section 5.2.1. The list of The Church of Jesus Christ Latter-Day Saints affiliates is included in Appendix 1 and Appendix 2.

7.6 Broadcast, Religious, Radio and Data Customers’ Affiliate Earth Station Scoping

Detailed identification of Intelsat’s broadcast, religious, radio, and data customers’ affiliate CONUS earth stations and their associated antenna impacts is underway and dependent on Intelsat’s affiliate matching and earth station outreach activities outlined in Section 5.1. Intelsat has included Incumbent Earth Station affiliates identified to date for these customers in Appendix 1 and Appendix 2. Intelsat’s analysis, in collaboration with its customers, will continue until all impacted affiliate earth stations are conclusively identified. 8 Transition Plan Summary

Intelsat’s Transition Plan is the result of more than two years of planning and engineering undertaken in conjunction with Intelsat’s customers, industry stakeholders, vendors, and other space station operators in order for 300 MHz of spectrum – inclusive of a 20 MHz guard band -- to be cleared for use by new terrestrial flexible use licensees. For the transition to be successful, all the various work streams within each of these main project elements will need to occur in a tightly scheduled, highly coordinated fashion. The plan will rely on the participation and active cooperation of all major stakeholders. The section below summarizes the program deliverables, the aggregate costs and the overall clearing timeline.

8.1 Program Management

Intelsat has been preparing for the implementation of C-band spectrum clearing for over two years and is well positioned to take the actions necessary clear within the designated timeframes. Intelsat’s assembled internal team consists of over 50 full-time employees focused on the clearing initiative. The team is comprised of strong, senior leaders dedicated to the program, complemented by world-class partners from across the industry.

Effective program management is vital to the success of the C-band clearing. Intelsat has contracted with a third party to develop a program management function that will support the leaders of each of the work streams identified in this Transition Plan. The program management office will have the following responsibilities:

• Development of the Transition Plan program milestones • Project tracking and reporting • Financial analysis and reporting • Interface to the Relocation Payment Clearinghouse • Interface to the Relocation Coordinator

Intelsat expects that the program office will remain in place through the end of the Transition Plan milestones identified in this section. The office’s functions will include certifying to the Relocation Coordinator that the spectrum milestones have been met and closing out any cost reimbursements with the Relocation Payment Clearinghouse. The estimated cost for management of the program is estimated to be $15 million over the Transition Plan period.

8.2 High Level Costs

The following is the aggregate view of the estimated reimbursable costs by category for the overall Intelsat Transition Plan.39 The estimates are based on the assumptions articulated above and will be revised as the program plan progresses into its implementation phase.

Document Total Category Section Cost Description Satellite Costs $ 790 7 Satellites Launch Vehicle & Insurance Costs $ 390 4 Launches Subtotal Satellite & Launch Costs 3 $ 1,180

Customer Migration, Compression and Repacking Costs 5 $ 400 11 Customers, 16,000 Affiliates Teleport Migration Costs 4 $ 95 2 Teleports, 18 Antennas Intelsat Program Management 8 $ 15 Program Management Subtotal Ground Infrastructure $ 510

Total $ 1,690

39 The numbers presented in the table are in millions.

8.3 High Level Timeline

Finally, a high-level view of the aggregated timeline for the various workstreams is provided below:

2020 2021 2022 2023 Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

FCC Auction

Clearinghouse Relocation Clearinghouse Certificate of Comments on Certificate of Coordinator Coordinator Funded by Completion due Certificates Completion due Selected Selected Overlay for Phase 1 close for Phase 2 Licensees E/S Opt Outs List Published Eligible Regluatory Milestones Regluatory ES list Published

G-23R and G-17R Constructed Launch and Orbit Raising

G-15R and G-12R Constructed Launch and Orbit Raising

G-3CR and G-28R Constructed Launch and Orbit Raising and Launch

G-13R Constructed Launch and SatelliteProcurement Orbit Raising

Hawaii Antenna Construction Int & Test Service

Brewster, WA Site Upgrades and Antennas Contracting Construction Int & Test Service transition Andover, ME Site Upgrades & Antennas Contracting Construction Integration & Testing Service Transition S. America Antenna Contracting Construction Int & Test Service Transition S. Africa Antenna Contracting Construction Int & Test Service Transition

Teleport Consolidations Teleport Antenna for New Satellites G-23R (New antenna - Napa) G-17R (Antenna Upgrades Riverside, CA) G-15R (Antenna Upgrades - Atlanta, GA) G-12R (Antenna Upgrades - Riverside, CA) G-3CR (New Antenna - Riverside, CA or Napa, CA) G-28R (New Antenna - Riverside, CA or Napa, CA) G-13R (Antenna Upgrades - Atlanta, GA, Hagerstown, MD, or Napa, CA)

Antenna Seeding - Galaxy 18 4 1 2 1 Comcast/NBC-U, MLB, Disney Comcast/NBC-U, AT&T Sports IKO Media Group, Trinity Tribune Broadcasting Network

Antenna Seeding - Galaxy 23 2 1 Antenna Seeding Herring Networks, Sinclair ATCi

Compression Design, Procurement, Installation 1 1 2 1 1 1 1 2 1 1 1 1 2 2 1 1 Encompass NPR MLB A&E

Starz Encompass WarnerMedia

Compression FoxCorp Sinclair Discovery Disney CBS Broadcasting

Cable Phase I Customer Migrations Cable Filtering (Red) Cable Phase II Customer Migrations Filter Filter Cable Cable Filtering (Blue) Installation - - Installation

Non-Cable Early Filtering (Red & Blue) Non-Cable Phase I Customer Migrations & Filtering Filter Non-Cable Phase II Customer Migrations & Filtering Non-Cable Installation - - Installation

Phase I Accelerated Phase II Accelerated Relocation Deadline Relocation Deadline

9 Conclusion

Intelsat is dedicated to successfully completing this transition process in conformance with the accelerated deadlines in the Report and Order. This Transition Plan is designed to minimize customer and earth station impact to the greatest extent possible and will allow Intelsat to provide similar or better service levels post the clearing process. Intelsat looks forward to working with all stakeholders to move forward and to complete this program.