79W Response to Arge

COMMENT submitted by DIRECTV, LLC

Response to Communications Secretariat Argentina

2012-06-14

This document pretains to SAT-AMD-20120420-00071 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2012042000071_955045

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ____________________________________ ) Application of ) ) DIRECTV ENTERPRISES, LLC ) Call Sign: S2861 ) For Authorization to Launch and ) File Nos. SAT-LOA-20120316-00051 Operate DIRECTV KU-79W, a ) SAT-AMD-20120420-00071 Ku-Band Space Station, at 79.0° WL ) ____________________________________) RESPONSE OF DIRECTV ENTERPRISES, LLC DIRECTV Enterprises, LLC (“DIRECTV”) hereby responds to the comments filed in the above referenced proceedings by the Communications Secretariat of the Republic of Argentina (the “Secretariat”). 1 In those comments, the Secretariat discusses operational parameters agreed to between the United States and Argentine administrations with respect to Ku-band operations at the 79º W.L. orbital location, and in particular states that the maximum EIRP level allowable under that agreement is 53 dBW. Because DIRECTV did not have access to the relevant coordination agreement before filing its application, it proposed to operate its satellite with a maximum downlink EIRP level of 54 dBW. However, the spacecraft has been designed such that DIRECTV can easily decrease its operating power below this maximum level as necessary to comply with any applicable coordination agreement. Although DIRECTV has not yet had access to all coordination agreements applicable to this orbital location, it hereby confirms that it fully intends to honor the terms of such coordination agreements of which it is made aware. 1 See Letter from Arq. Carlos Lisandro Salas, Communications Secretary, to Marlene H. Dortch (June 4, 2012) (“Comments”). 1

The Secretariat also expresses concern over DIRECTV’s proposed use of 65 cm subscriber receive antennas, which it fears might experience harmful interference from other transmissions made consistent with the U.S.-Argentina coordination agreement. 2 Without access to that agreement, DIRECTV cannot adequately assess the validity of this concern or the potential for interference. However, just as DIRECTV is prepared to comply with all applicable coordination agreements, it is also prepared to adjust its operations as necessary to account for the activities of others operating consistent with such agreements and assure its viewers a high quality video programming experience. Respectfully submitted, DIRECTV ENTERPRISES, LLC By: ___/s/_______________________ William M. Wiltshire Michael Nilsson WILTSHIRE & GRANNIS LLP 1200 Eighteenth Street, N.W. Washington, DC 20036 202-730-1300 Counsel for DIRECTV Enterprises, LLC June 14, 2012 2 See Comments at 2. 2

CERTIFICATE OF SERVICE I hereby certify that, on this 14th day of June, 2012, a copy of the foregoing Response was served by fax and e-mail delivery upon: Mr. Gustavo J. FERNANDEZ Head of the Satellite Affairs Division International and Institutional Relations Department National Communication Commission Republic of Argentina Fax: + 54 11 4347.9546 E-mail: gfernandez@cnc.gov.ar ___/s/____________________ Laura Merkey


Document Created: 2019-04-10 17:38:16
Document Modified: 2019-04-10 17:38:16
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