Attachment comments

comments

COMMENT submitted by DIRECTV, Inc.

comments

2004-11-08

This document pretains to SAT-AMD-20040928-00192 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2004092800192_405604

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 RECEIVED NOV — 8 2004 ) In the Matter of ) dealCommuncatons Connision ) Offee ol Secutay MoniveSarevure Ventures ) File No. Supsipiary Luc ) SAT—AMD—20040928—00192 ) Amendment to Application for ) Authority to Launch and Operate a ) Call Sign 82358 Replacement L—Band Mobile ) Satellte Service Satellite at 101° W.L. ) onmeniiieiineenon COMMENTSOF DIRECTV, INC. DIRECTV, Inc.,on behalf ofitself and its affiiates (collectively, DIRECTV") submits the following brief Comments in response to stationkeeping information filed by Mobile Satellite Ventures Subsidiary LLC (MSV")." MSV requests stationkeeping allowance at 101° W.L. twiceas wide as that allotted to any ofthe other six satelltes operating at that location (including MSV‘s existing satellte) — and half ofthe area allotted to all four DIRECTV satellites at that location — on the grounds that such an allowance would help it conserve fuel. This consideration is, of course, true of all satelltes, not just MSV‘s as—yet—unbuilt one.. Even assuming that relaxing the stationkeeping requirements can in some cases be justified by the fuel savings achieved. the very congested 101° W.L. orbital location is hardly an appropriate candidate for such S Mobile Stelite Ventures Subsidiry LLC, Amendment to Appliatin for Authorit to Launch and Operte a Replacement MSS Satlite at101° W.L., ile No. SAT—AMD—20040928—00192 (filed Sept. 28,2004) (‘Sept. Amendment). MSV‘sstaioncepinganlysis is found in the Amendments Technical Appendix t page S

a relaxation. Although DIRECTV is willing to work with MSV on spacing issues at 101° W.L.to find an accommodation (ifpossible), it cannot support MSV‘s stationkecping proposal at this time. By way of background, DIRECTV operates four satellites at the 101° W.L. orbital location, where two other satelltes also now operate.". DIRECTV plans to launch another satellte t this location next spring.® and it intends to launch additional satellitesthere in the future. The 101° W.L. orbital location thus is, and will remain, one ofthe most congested places in the U.S. orbital are. Moreaver, DIRECTV is constrained by international agreement t locate all of ts DBS satellites at the nominal 101° W.L. orbital location within a 0.4° "box" bounded by 100.8° W.L. and 101.2° W.L. MSV now seeks to operate a new, as—yet—undesigned satellte at this crowded location with a stationkeeping tolerance of + 0.1°,rather than the +0.05° typically contemplated by the Commission‘s rules.* In other words, MSV seeks to operate within one halfof the "box‘"in which all DIRECTV satellites must operate. Asked to provide "further information regarding the cost benefitsor other support for it [stationkeeping] request," MSV argues that, because its new satelite will be similar to a Bocing 702 or Eurostar 3000 satellit, "the altemnative of maintaining a + 0.05° East—West station keeping box would severely penalize the replacement satellite by necessitating excessive ‘Thesatlites operting atthis nomina orbitlloction are DIRECTV 1, 12, and 45, as wellasthe AMC 4 and AMSC satlites See Public Noic, DA 04—3529 (rel. Nov 5 2006)(efectingauthorization of DIRECTV 8 DBSio« band hybrid stelitat 100.48" W.L). e Mobile Stelite VentresSubsidiy LLC, Amendmentto Application for Authority to Launch and Operte a Replacement MSStelit t 101° WL., Fle No. SAT—AMD—20040209—00014 filed Feb.9,2004)(‘Fcbruary Amendinent‘,. Forreasons unrlated t hese comments, the Interational Bureaufistdismissed this February Amendiment, thenreistated i. See Letrfrom Thomas . Tycz, Chiet Sitelite Divisin, Internationa! Bureauto Lon C. Levi, Viee President, Mobile Satelte Ventures Subsidiry LLC, DA 04—1095 (rel. Aprl23, 2004; Moble Steite Fentures Subsidary LLC, DA 02983 (rel.Sept 15, 2004)

fuel expenditures, resulting in either a significant decrease in satellite lifetime or a severe reduction in the available mass for the communications payload."" DIRECTV is not without sympathy for MSV‘s argument that a wider stationkeeping area would help it save fuel. This, however, is true ofall satellites. All satellte operators,including DIRECTV, could save fuel with wider stationkeeping areas. The Commission nonetheless typically requires narrow stationkeeping areas in order to maximize the use of searceorbital resources and minimize the likelihood ofcolliion." MSV has failed to demonstrate why it should be treated differently— and at the 101° W.L. orbital location ofall places. The Commission, it is true, has deferred the issue ofwhether ts rules should require MSS satellites to operate within the + 0.05° stationkecping tolerance required for Fixed—Satellite Service ("FSS") satellites." Yet in proposing such a requirement, the Commission postulated that FSS stationkeeping rules could be "usful as basic ‘riles of the road? for the purpose of limiting the probability of collision with other large objects, particular with respect to potential colliions between functional spacecraft at geostationaryorbit"" If this is true anywhere, it is true at 101° W.L. Put another way, the particularly challenging physical sharing environment at 101° W. is just about the last orbitallocation where one would want to experiment with a wider stationkeeping area — and is just about the last orbitallocation where such experimentation could be justified on the generic grounds of fuel savings. Sept AmendmentatTechApp.5. Seear CrR 5252100 Mitigation ofOrbitel Debris, 19 ECC Red. 11567,11586 (2004)(discusingextensionof sttiontecping requirements beyand Fixed—Satelite Serviceopertors). AMitgation ofOrbital Debris, Notice oProposed Rule Making, 17 ECC Red. 5865606 (2002).

This does not mean that MSV‘s request cannot be accommodated — only that MSV has failed to justifyits request for special treatment. As with any orbital location at which it operates, DIRECTV is ready and willing to work with MSV on spacing issues at the 101° W.L. slot. In addition, perhaps MSV and the Commission should consider whether MSV would be better able to operate from a location slightly offsct from 101° W.L. — ie outside of the congested 100.8° W.L.—101.2° W.L. "box" in which DIRECTV must operate by international agreement. But,as the operator with the most existing and proposed satelites that would be constrained by MSV*s request, DIRECTV cannot support the request as currently styled and justified. Respectfully submitted, James Butterworth TV Williom ishire Senior Vice President Michael D. Nilsson DIRECTV, Inc. Hamus, Wicrsime & Grannis uur 2230 E. Imperial Highway 1200 Eighteenth Street, N.W. El Segundo, CA 90245 Washington, DC 20036 (202) 730—1300 Counselfor DIRECTY, Inc November 8, 2004

CERTIFICATE OF SERVICE Ihereby certify that, on this 8° day of November, 2004, a copy of the foregoing Comments of DIRECTV, Inc. was served by first class mail, postage prepaid, upon: Bruce D. Jacobs Shaw Pittman LLP 2300 N Street, NW. Washington, DC 20037


Document Created: 2004-11-18 13:59:46
Document Modified: 2004-11-18 13:59:46
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