Exhibit A Request for STA

0010-EX-TU-2008 Text Documents

DIRECTV Enterprises, LLC

2008-07-16ELS_91921

EXHIBIT A REQUEST FOR SPECIAL TEMPORARY AUTHORITY DIRECTV Enterprises, LLC (“DIRECTV”) hereby requests Special Temporary Authority (“STA”) to (1) launch and operate an experimental 17/24 GHz BSS communications payload on the DIRECTV 11 satellite at the 101.6° W.L. orbital location ± 0.3°; (2) conduct telemetry, tracking, and control (“TT&C”) functions using the Ka- band payload on DIRECTV 11 in transit to and from that location and while on station there;1 and (3) operate an earth station in Moxee, WA in the 17/24 GHz BSS bands. DIRECTV requests authority for these operations for up to one hundred twenty (120) days, beginning on or about March 1, 2008. Because launch of DIRECTV 11 is scheduled for mid-January 2008, DIRECTV respectfully requests expedited action on this request.2 The Commission has authorized DIRECTV to launch and operate DIRECTV 11, a Ka-band satellite to be located at 99.2° W.L.,3 which is a critical component in DIRECTV’s continued expansion of national and local high definition television programming for American consumers. The satellite is fully constructed and currently scheduled for launch on a Sea Launch vehicle in mid-January 2008. DIRECTV also has pending several applications for authorizations to operate in the 17/24 GHz BSS band 1 The specific Ka-band frequencies to be used for TT&C are 18301.25/18301.75 MHz (telemetry) and 29.253 MHz (command). 2 DIRECTV has filed a separate request for expedition that discusses the basis for prompt action more fully. 3 See FCC File No. SAT- AMD-20050103-00001 (granted Mar. 8, 2005). A-1

under a spectrum allocation that just became effective earlier this year. 4 Although the Commission recently adopted processing and service rules for this band, it also issued a further notice of proposed rulemaking (“FNPRM”) requesting further information on a number of technical and spectrum sharing issues.5 The comment cycle in that proceeding concludes in December 2007. Yet at present, there are no satellites or earth stations operating in this band, and thus very little information about its characteristics. Because DIRECTV hopes to use the capacity afforded by this new band to expand its service offerings still further, it is intensely interested in ensuring that the Commission has sufficient reliable data upon which to base its decisions in the FNPRM proceeding. Accordingly, it has added DIRECTV 11 an experimental payload operating in the 17.3-17.7 GHz (downlink) and 24.75-25.15 GHz (uplink) bands to help generate such data, as well as other operational information.6 DIRECTV seeks an STA to operate at 101.6° W.L. ± 0.3° in order to test the interaction of 17/24 GHz BSS and Direct Broadcast Satellite (“DBS”) operations in close proximity near 101° W.L. Operation of the 17/24 GHz BSS payload of DIRECTV 11 at 101.6° W.L. will not result in harmful interference to any other licensed user of the spectrum. There are no other operational 17/24 GHz BSS satellite systems. While the DBS service uses the 17.3- 17.7 GHz band for uplinks, DIRECTV is the sole DBS licensee at 101° W.L. and the 4 See Redesignation of the 17.7-19.7 GHz Frequency Band, 15 FCC Rcd. 13430, 13476-80 (2000). 5 See Establishment of Policies and Service Rules for the Broadcasting Satellite Service at the 17.3-17.7 GHz Frequency Band and at the 17.7-17.8 GHz Frequency Band Internationally, and at the 24.75-25.25 GHz Frequency Band for Fixed Satellite Services Providing Feeder Links to the Broadcasting-Satellite Service and for the Broadcasting Satellite Service Operating Bi-directionally in the 17.3-17.7 GHz Frequency Band, 22 FCC Rcd. 8842 (2007). 6 Antenna patterns for this payload are attached as Appendix 1. A-2

next nearest DBS satellite is located more than eight degrees away. DIRECTV will carefully coordinate its operations to ensure that they do not interfere with its ongoing DBS service, and is prepared to terminate all 17/24 GHz BSS operations immediately upon notification from the Commission that its operations cause harmful interference to any authorized user of the spectrum. TT&C operations in the Ka-band also will not result in harmful interference to adjacent satellites. The only other co-frequency satellites located within two degrees of arc are DIRECTV 8 and DIRECTV 9S (operating at the nominal 101° W.L. location) and SPACEWAY 1 (operating at 102.8° W.L.), and DIRECTV anticipates no difficulty in coordinating the operations of its satellites. DIRECTV will also coordinate its TT&C operations during drift with all other potentially affected operators to ensure that no harmful interference results. Furthermore, DIRECTV is prepared to terminate all Ka- band operations immediately upon notification from the Commission that its operations cause harmful interference to any authorized user of the spectrum. Similarly, operation of the 17/24 GHz BSS earth station at one of DIRECTV’s existing earth station facilities will not cause harmful interference.7 This site is located far from any DBS uplink facility, and is also well outside any Economic Area licensed for terrestrial fixed service operations in the 24 GHz band.8 Accordingly, there is no 7 Detailed information about this site (call sign E060299) can be found in FCC File No. SES- LIC-20060802-01301. 8 According to the Commission’s Universal Licensing System, there is no terrestrial system licensed to operate in the 25.05-25.25 GHz band in the states of Washington, Oregon, Idaho, and Montana. Accordingly, the power flux-density of the 24 GHz uplink signal at the boundary of the nearest terrestrial license area will be well below the -114 dBW/m2/MHz level required under the Commission’s rules. See 47 C.F.R. § 25.203(l). A-3

competing authorized user of the spectrum within the area of proposed earth station operations. Grant of this STA request will serve the public interest by allowing DIRECTV to conduct proof of concept video transmissions in this newly available BSS band. Among other things, DIRECTV anticipates that the data it is able to collect from these operations will provide valuable insights for the Commission’s pending rulemaking on certain technical and sharing issues for the 17/24 GHz BSS service. In addition, for the reasons discussed above, grant of this STA request will not result in increased risk of harmful interference to any other system. A-4

APPENDIX 1 Figure 1. Transmit Antenna Pattern (Peak EIRP) SATSOFT -2 -4 8.00 -3 -2 -1 46. 51 6.00 -1 4.00 Theta*sin(phi) in Degrees -2 -6 2.00 -8 -3 -10 -6 -4 -8 0.00 -10 -15 -15 -20 -20 -2.00 -8.00 -6.00 -4.00 -2.00 0.00 2.00 4.00 6.00 8.00 T heta*cos(phi) in Degrees A-5

Figure 2. Receive Antenna Pattern (Peak G/T) SATSOFT 8.00 -2 -1 -5. 91 6.00 -1 4.00 Theta*sin(phi) in Degrees -3 -6 -8 -4 2.00 -2 -3 -4 0.00 -10 -6 -15 -2.00 -8 -8.00 -6.00 -4.00 -2.00 0.00 2.00 4.00 6.00 T heta*cos(phi) in Degrees A-6


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Document Modified: 2008-07-16 11:22:15
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