D12 Clarification Le

LETTER submitted by DIRECTV Enterprises, LLC

Clarification Letter

2009-12-02

This document pretains to SAT-LOA-20090807-00086 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2009080700086_784621

WILTSHIRE & GRANNIS ur December 2, 2009 BY ELECTRONIC FILING Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth Street, S.W. Washington, DC 20554 Re: IBFS File No. SAT—LOA—20090807—00086 (S2797) Dear Ms. Dortch: In response to inquiries from the Commission staff, DIRECTV Enterprises, LLC ("DIRECTV") submits two minor clarifications with respect to the above referenced application for authority to launch and operate the DIRECTV 12 Ka—band satellite. First, DIRECTV recognizes that, as provided in Section 25.145(g) of the Commission‘s rules, the operations of DIRECTV 12 in the 18.3—18.8 GHz band are not entitled to protection from the co—primary operations of terrestrial fixed service systems until after the period during which terrestrial stations remain co—primary has expired. Because DIRECTV 12 will operate within the power flux—density limits established in Section 25.208(c) of the Commission‘s rules, the satellite‘s operations will have no harmful effect on such terrestrial stations and no further coordination is required.‘ Second, DIRECTV 12 is a partial replacement for two existing satellites currently operating at the nominal 103° W.L. orbital location. Specifically, DIRECTV 12 will replace the spot beam payload operating in the 18.3—18.8 GHz band on the DIRECTV 10 satellite, and will also replace that portion of the CONUS payload operating in the 19.87—20.2 GHz band on the SPACEWAY 1 satellite. Because DIRECTV 12 will operate at the same nominal orbital location and in frequencies already authorized for DIRECTV‘s existing operations, the satellite should be deemed to be a partial replacement. DIRECTV will continue the operations of DIRECTV 10 and SPACEWAY 1 until DIRECTV 12 arrives on station to replace portions of those operations, and will take measures to ensure that the transition of service among the satellites is as seamless to subscribers as possible. ! See Redesignation ofthe 17.7—19.7 GHz Frequency Band, 16 FCC Red. 19808, € 52 (2001) ("‘the pfd values in place were already designed to ‘pre—coordinate‘ spacecraft transmissions and terrestrial fixed service receivers regardless of the elevation angle and azimuth of the terrestrial receiver" and were adopted "to avoid the need for FS/FSS coordination").

WILTSHIRE & GRANNIS LLP Marlene H. Dortch December 2, 2009 Page 2 of 2 If you have any questions, please do not hesitate to contact me. Respectfully submitted, /s/ William M. Wiltshire Counsel to DIRECTVY Enterprises, LLC ce: Andrea Kelly Kathyrn Medley 1200 18TH STREET, NW | SUITE 1200 | WASHINGTON, DC 20036 | TEL 202—730—1300 | FAX 202—730—1301 | WILTSHIREGRANNIS.COM


Document Created: 2019-04-11 22:25:23
Document Modified: 2019-04-11 22:25:23
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