Application Narrative

0207-EX-ST-2008 Text Documents

DIRECTV Enterprises, LLC

2008-04-16ELS_89552

EXHIBIT A REQUEST FOR SPECIAL TEMPORARY AUTHORITY DIRECTV Enterprises, LLC (“DIRECTV”) has been granted Special Temporary Authority (“STA”) to launch and operate an experimental 17/24 GHz BSS communications payload on the DIRECTV 11 satellite at the 100.7° W.L. orbital location ± 0.3°.1 DIRECTV hereby requests additional authority (1) to 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,2 and (2) to communicate with the satellite for this purpose using DIRECTV’s earth stations in Castle Rock, CO (call sign E070027)3 and New Hampton, NH (call sign E070002)4. DIRECTV requests authority for these operations for up to one hundred twenty (120) days, beginning on or about May 15, 2008.5 Because DIRECTV 11 is currently in the orbit-raising phase of its mission, DIRECTV respectfully requests expedited action on this request. The Commission has authorized DIRECTV to launch and operate DIRECTV 11, a Ka-band satellite to be located at 99.225° W.L.,6 which is a critical component in DIRECTV’s continued expansion of national and local high definition television programming for American consumers. The satellite was launched successfully on March 19, 2008, and DIRECTV intends to conduct in-orbit testing at 99.4° W.L. 1 See File No. 0544-EX-ST-2007 (call sign WD9XCI). 2 The specific Ka-band frequencies to be used for TT&C are 18301.25/18301.75 MHz (telemetry) and 29.253 MHz (command). 3 See FCC File No. SES-LIC-20070205-00188 (granted Mar. 13, 2007). 4 See FCC File No. SES-LIC-20070104-00010 (granted Mar. 13, 2007). 5 All other information submitted in the context of the original STA request remains unchanged, and is hereby incorporated by reference as if fully set forth herein. 6 See FCC File No. SAT-MOD-20071010-00138 (granted Mar. 19, 2008). A-1

DIRECTV also has pending several applications for authorizations to operate in the 17/24 GHz BSS band under a spectrum allocation that just recently became effective.7 In order to help develop operational data on this band, DIRECTV has added to DIRECTV 11 an experimental payload operating in the 17.3-17.7 GHz (downlink) and 24.75-25.15 GHz (uplink) bands. It has been granted an STA to operate at 100.7° 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. However, the TT&C functions of the spacecraft are performed in the Ka-band frequencies on which DIRECTV is authorized to operate at its licensed orbital location. Accordingly, DIRECTV needs authority for TT&C communications in this band for transit from IOT at 99.4° W.L. to 100.7° W.L., during operation at 100.7° W.L., and for transit to its licensed location at 99.225° W.L. Operation of the Ka-band payload of DIRECTV 11 in this very limited portion of the orbital arc will not result in harmful interference to any other licensed user of the spectrum. The only other co-frequency satellites located within two degrees of the satellite’s proposed area of operations are DIRECTV 8 and DIRECTV 9S, operating at 100.85° W.L. and 101.1° W.L., respectively, 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. Similarly, operation of the Ka-band earth stations at DIRECTV’s existing earth station facilities will not cause harmful interference.8 DIRECTV is already licensed to 7 See Redesignation of the 17.7-19.7 GHz Frequency Band, 15 FCC Rcd. 13430, 13476-80 (2000). 8 Detailed information about these sites (call signs E070027 and E070002) can be found in FCC File Nos. SES-LIC-20070205-00188 and SES-LIC-20070104-00010, respectively. A-2

use these sites for TT&C of the spacecraft at its licensed position of 99.225° W.L., and the slight offset to 100.7° W.L. and during transit will not have any material effect on any other licensed system. Grant of this STA request will serve the public interest by providing DIRECTV the critical authority necessary to support its proof of concept video transmissions in the 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.9 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. 9 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). A-3


Document Created: 2008-04-16 15:29:24
Document Modified: 2008-04-16 15:29:24
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