Attachment Narrative

This document pretains to SAT-AMD-20120420-00070 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2012042000070_949176

MINOR AMENDMENT TO DIRECTV KU-79W APPLICATION DIRECTV Enterprises, LLC (“DIRECTV”) has filed an application for authority to launch and operate a Ku-band satellite in the Fixed Satellite Service at the nominal 79º W.L. orbital location, to be designated as DIRECTV KU-79W. 1 In this Application, DIRECTV submits minor amendments to correct a few clerical errors in its original application, including a revised Schedule S that incorporates all such corrections. In accordance with Section 25.117(d)(1) of the Commission’s rules, DIRECTV identifies in this Application only those items of information that should be changed from its original application. DIRECTV hereby certifies that the remaining information in its original application has not changed. 1. TT&C Frequencies In the Schedule S filed with its original application, DIRECTV specified that telemetry would be transmitted on two frequencies: 11724 MHz and 11725 MHz. Those frequencies fall within one of the satellite’s communications transponders. The correct frequencies are 11704 MHz and 11705 MHz, as shown on the revised Schedule S attached hereto. DIRECTV notes that the TT&C link budget submitted as Exhibit C to its application narrative used one of the correct telemetry frequencies (11705 MHz). 2. Antenna Gain Contour The original antenna gain contour pattern for the Mexico beam submitted in .gxt format did not include a -8 dB contour. The revised Schedule S attached hereto includes a new .gxt file that includes the -8dB contour for that beam. 1 See IBFS File No. SAT-LOA-20120316-00051.

3. Solar Array The original application indicated that the area of the satellite’s solar array would be 13 m2. This figure is erroneous, as it relates to only a single wing of the solar array. The revised Schedule S attached hereto reflects the correct value of 26 m2 for both wings of the array. 4. Remote Location for TT&C – Request for Waiver In the Schedule S accompanying its original application, DIRECTV indicated that it planned to operate the satellite by remote control, but did not provide further information related to the remote control point. However, as DIRECTV stated in its original narrative application, it “has not yet contracted for the construction of the DIRECTV KU-79W satellite, and therefore has not yet finalized arrangements for tracking, telemetry and control.” (Application Narrative at 10.) In these circumstances, DIRECTV is unable to provide the contact information for the remote control point requested in Schedule S. Accordingly, to the extent necessary, DIRECTV requests a waiver of the requirement to submit such information. The Commission may waive its rules for good cause shown, 2 or where the particular facts make strict compliance inconsistent with the public interest. 3 At this very early stage, DIRECTV knows that it will conduct TT&C operations for this satellite from a remote site, but does not know any details related those TT&C operations. Accordingly, in this case, there is no way to provide the information requested. 2 47 C.F.R. § 1.3; see also WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969), cert. denied, 409 U.S. 1027 (1972). 3 See Northeast Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990). 2

Were the Commission to delay or deny the application for lack of such information, it would unnecessarily require satellite applicants to finalize all arrangements for TT&C years before launch of a new satellite – in fact, before the satellite authorization is even granted. This could significantly delay or deny the provision of valuable satellite services to the public. There can be no realistic concern that the inability to provide specific information on TT&C arrangements at this early stage could affect ultimate operations of the satellite. DIRECTV operates a fleet of satellites, and clearly will arrange for TT&C of DIRECTV KU-97W well in advance of launching the satellite just as it has done for its many other satellites. At that point, DIRECTV will be in a position to supply the information requested by Schedule S. At present, however, DIRECTV respectfully requests that the Commission waive any requirement for submission of information on the remote control site for TT&C and continue to process the application to completion as expeditiously as possible. Respectfully submitted, DIRECTV ENTERPRISES, LLC By: __/s/________________________ Romulo Pontual Executive Vice President 3

ENGINEERING CERTIFICATION The undersigned hereby certifies to the Federal Communications Commission as follows: (i) I am the technically qualified person responsible for the engineering information contained in the foregoing Amendment, (ii) I am familiar with Part 25 of the Commission's Rules, and (iii) I have either prepared or reviewed the engineering information contained in the foregoing Minor Amendment, and it is complete and accurate to the best of my knowledge and belief. Signed: /s/ Jack Wengryniuk April 20, 2012 Date 4


Document Created: 2012-04-20 16:33:15
Document Modified: 2012-04-20 16:33:15
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