Attachment comments

comments

COMMENT submitted by DIRECTV Enterprises

comments

2006-01-24

This document pretains to SAT-LOA-20051221-00267 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2005122100267_477635

Before the FEDERAL COMMUNICATIONS commussion RECEIVED Washington, D.C. 20584 JAN 2 0 2006 ) Fedenl Communcaten Conniain Application of ) ce ol Sesay ) EcnoSraSatcuurre Oreratin ) File No. SAT—MOD—20051221—00267 Comrany j Received : For Modification of Authorization to ) JAN 2 44 2006 Operate a DBS Satellte at 110° W.L ) mntinnncommentennactat COMMENTS OF DIRECTV ENTERPRISES. LLC DIRECTV Enterprises, LLC (‘DIRECTV") hereby comments on the application filed by EchoStar Satellite Operating Company ("EchoStar) for modification ofits authorization to operate a satellte in the Direct Broadcast Satellite("DBS") service atthe 110° W.L.orbitallocation to coverits EchoStar 10 space station. DIRECTV operates its own DBS satellite, DIRECTV 5, at the 109.8° W.L. orbital location, and has additional DBS satellites at the nominal 101° W.L. and 119° W.L. positions as well DIRECTV has analyzed the potentialinterference that would result from the proposed operation ofEchoStar 10 on all ofits DBS satellites. Given the large number of high—power spot beams on EchoStar 10 serving areas throughoutthe entire continental United States, DIRECTV has concluded thatits customers in many areas ofthe country will receive unaceeptable interference. Not surprisingly, the most serious cases of interference would affect service from DIRECTV 5, lcated just 0.2° away from EchoStar 10. DIRECTV 5 operates on DBS channels 28, 30, and 32, which overlap in

frequency but are cross—polarized ffom DBS channels 27,29, and 31 on which EchoStar 10 will operate. Due to the proximity of orbitallocations, te only protection for DIRECTV consumers from cross—polarization interference is the isolation provided by the receive terminals, which typically affords 20—28 dB refection. Given the large EIRP disparity between the operational levels requested for EchoStar 10 and the levels actually provided by DIRECTV 5 — as much as 10 dB less in many cases — C/1values would range from about 12 dB to 19 dB, which is insufficient to provide adequate protection. As a result, consumers receiving service from DIRECTV 5 would suffer reduced service availability, which means that they would experience more frequent and prolonged rain outages. DIRECTV and EchoStar are currently exploring various operationalalternatives that could address this issue.. While both parties are working diligently to come to terms, no agreement has been reached to date. DIRECTV remains hopeful that the partieswill be able to come to an acceptable accommodation.. Absent such an agreement, however, DIRECTV feels compelled to state ts concem with respect to the operational parameters proposed for EchoStar 10 in the pending application.

Accordingly, DIRECTV requests that the Commission hold this application in abeyance untl the interference issues are resolved. Respectfully submitted, DIRECTV Evrermaises, uie By: M. Wiltshire Michael D. Nilsson Hamms, Wirrsmee & Granns uur 1200 Eighteenth Street, N.W. Washington, DC 20036 202—730—1300 Counselfor DIRECTV Enterprises, LC Dated: January 20, 2006

ENGINEERING CERTIFICATION The undersigned hereby certiies to the Federal Communications Commission as follows: ® I am the technically qualified person responsible for the engineering information contained in the foregoing Comments, (i) 1 am familiar with Part 25 of the Commission‘s Rules, and (i) T have either prepared or reviewed the enginecring information contained in the foregoing Comments, and it is complete and accurate to the best ofmy knowledge and belict Signed: is David Patillo January 20, 2006 Date

CERTIFICATE OF SERVICE hereby certify that, on this 20th day ofJanuary, 2006, a copy of the foregoing Comments of DIRECTV Enterprises, LLC was served by hand delivery upon: Pantelis Michalopoulos Steptoe & Johnson LLP 1330 Connecticut Avenue, N.W. Washington, DC 20036


Document Created: 2006-01-24 11:03:58
Document Modified: 2006-01-24 11:03:58
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