Attachment Narrative

This document pretains to SAT-LOA-20121101-00190 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2012110100190_973422

                               Before the
            FEDERAL COMMUNICATIONS COMMISSION
                         Washington, D.C. 20554


____________________________________
                                    )
Application of                      )
                                    )
DIRECTV ENTERPRISES, LLC            )       Call Sign:
                                    )
For Authorization to Launch and     )       File No. SAT-LOA-_____________
Operate DIRECTV KU-76W, a           )
Ku-Band Space Station, at 76.0 WL  )
____________________________________)




                  APPLICATION FOR AUTHORIZATION TO
                 LAUNCH AND OPERATE DIRECTV KU-76W




                                    William M. Wiltshire
                                    Michael D. Nilsson

                                    WILTSHIRE & GRANNIS LLP
                                    1200 Eighteenth Street, N.W.
                                    Washington, DC 20036
                                    202-730-1300 tel
                                    202-730-1301 fax


                                            TABLE OF CONTENTS

                                                                                                                              Page


I.      GRANT OF THIS APPLICATION WOULD SERVE THE PUBLIC INTEREST ............... 2

II.     INFORMATION REQUIRED UNDER SEC. 25.114 OF THE COMMISSION’S RULES ... 3

        1.     Name, Address, and Telephone Number of Applicant ............................... 3
        2.     Name, Address, and Telephone Number of Counsel.................................. 3
        3.     Type of Authorization Requested ............................................................... 3
        4.     General Description of Overall System Facilities, Operations and Services
               ..................................................................................................................... 3
        5.     Operational Characteristics ......................................................................... 4
               5.1         Frequency and Polarization Plan .................................................... 4
               5.2         Communications Payload ............................................................... 5
5.2.1   Uplink Transmissions 5
5.2.2   Downlink Transmissions ........................................................................................ 6
               5.3         TT&C Subsystem............................................................................ 6
        6.     Orbital Locations ........................................................................................ 7
        7.     Predicted Spacecraft Antenna Gain Contours............................................. 8
               7.1         Uplink Beams8
               7.2         Downlink Beams ............................................................................. 8
               7.3         TT&C Beams8
        8.     Service Description, Link Description and Performance Analysis, Earth
               Station Parameters ...................................................................................... 9
               8.1         Service Description ......................................................................... 9
               8.2         Link Performance............................................................................ 9
               8.3         Earth Station Parameters ................................................................. 9
        9.     Satellite Orbit Characteristics ................................................................... 10
        10.    Power Flux Density................................................................................... 10
        11.    Arrangement for tracking, telemetry, and control .................................... 10
        12.    Physical Characteristics of the Space Station ........................................... 10
        13.    Spacecraft Bus Subsystem ........................................................................ 11
        14.    Common Carrier Status............................................................................. 11
        15.    Schedule .................................................................................................... 11
        16.    Public Interest Considerations .................................................................. 11
        17.    Interference Analysis ................................................................................ 12
        18.    Orbital Debris Mitigation .......................................................................... 14
        III.    ITU Cost Recovery .................................................................................. 18

IV.     CONCLUSION ........................................................................................................ 18

Appendix A: DIRECTV KU-76W Link Budget Analysis
Appendix B: Antenna Beam Contours
Appendix C: TT&C Link Budget Analysis



                                                                i


                                       Before the
             FEDERAL COMMUNICATIONS COMMISSION
                               Washington, D.C. 20554


____________________________________
                                    )
Application of                      )
                                    )
DIRECTV ENTERPRISES, LLC            )               Call Sign:
                                    )
For Authorization to Launch and     )               File No. SAT-LOA-_____________
Operate DIRECTV KU-76W, a           )
Ku-Band Space Station, at 76 WL    )
____________________________________)


         APPLICATION FOR AUTHORITY TO LAUNCH AND
    OPERATE DIRECTV KU-76W, A KU-BAND SATELLITE, AT 76° W.L.

       DIRECTV Enterprises, LLC (“DIRECTV”) hereby applies for authority to launch

and operate a geostationary Ku-band spacecraft, at the nominal 76º W.L. orbital location.

A completed Form 312 and accompanying Schedule S related to this application are

attached. DIRECTV intends to use this satellite, to be designated DIRECTV KU-76W,

to provide high quality direct-to-home (“DTH”) satellite service, including high-

definition (“HD”) video programming. This application provides the information

required by the Commission’s rules in support of the proposed satellite authorization.

Expeditious grant of this application will enable DIRECTV to extend its leadership in

digital home video entertainment innovation in Mexico.


   I.    GRANT OF THIS APPLICATION WOULD SERVE THE PUBLIC INTEREST

        Since initiating service in 1994, DIRECTV has become the leading provider of

DTH digital television services in the United States, with approximately 19.9 million

subscribers. It currently has a fleet of eleven in-orbit spacecraft operating in the Ku- and

Ka-bands, which have enabled DIRECTV to maintain and extend its leadership in HD

services and to inaugurate 3D services as well. Its affiliate, DIRECTV Latin America

(“DTVLA”), is the leading provider of DTH digital television services throughout Latin

America, serving nearly 13.7 million subscribers in over 10 countries using Ku-band

satellites. This includes approximately 4.6 million subscribers served by DTVLA’s

affiliate Innova, S. de R.L. de C.V., commonly referred to as Sky Mexico, which is

growing by approximately one million subscribers per year despite intensifying

competition. These companies strive to combine unique and compelling content with

technological innovation and industry-leading customer service to make DIRECTV and

DTVLA the clear choice among consumers throughout the Americas.

        This application seeks launch and operating authority for a new Ku-band

spacecraft at 76º W.L., which DIRECTV intends to use to expand its DTH capabilities

still further in order to support the ongoing transition to HD services in Mexico.

Transmitting programming in HD (and 3D) format requires significantly more capacity

than transmitting the same programming in SD format. As more programmers migrate to

HD and 3D, DIRECTV will need to make sure that its system has the additional capacity

available to handle the demands of an increasingly robust slate of HD and 3D

programming. The need for additional capacity is especially acute in Mexico, where the

existing use of a Ku-band satellite would ease the transition to the use of an additional

Ku-band satellite.


                                             2


         Granting this application will serve the public interest in several ways. First, the

Commission will enable DIRECTV, and its affiliate DTVLA, to increase the amount of

HD programming available to subscribers in Mexico. Second, the ability to keep pace

with HD programming demands will make DTVLA better able to compete against cable

and telco multichannel video services in Mexico. Third, the rich and varied HD services

offered from this orbital location will give subscribers additional incentive to upgrade to

digital television sets, further promoting the digital transition.

         For all of these reasons, DIRECTV submits that the Commission should grant this

application as expeditiously as possible.

   II.      INFORMATION REQUIRED UNDER SEC. 25.114 OF THE COMMISSION’S RULES

         1.    Name, Address, and Telephone Number of Applicant

         DIRECTV Enterprises, LLC
         2230 East Imperial Highway
         El Segundo, CA 90245
         (310) 964-0700

         2.    Name, Address, and Telephone Number of Counsel

         William M. Wiltshire
         Wiltshire & Grannis LLP
         1200 Eighteenth Street, N.W.
         Washington, DC 20036
         (202) 730-1300

         3.    Type of Authorization Requested

         DIRECTV hereby applies for authority to launch and operate DIRECTV KU-

76W, a geostationary Ku-band satellite that will operate at the nominal 76° W.L. orbital

location.

         4.    General Description of Overall System Facilities, Operations and
               Services

         DIRECTV KU-76W will consist of a geostationary satellite located at the

nominal 76° W.L. orbital location and associated ground station equipment. DIRECTV
                                           3


KU-76W is designed to provide DTH service in the FSS Ku-band (11.7-12.2 GHz

(space-to-Earth) and 14.0-14.5 GHz (Earth-to-space)). The on-station Telemetry,

Tracking and Control (“TT&C”) functions will be provided at the edges of these same

frequency bands.

       The DIRECTV KU-76W satellite is capable of supporting twenty four 36 MHz

Ku-band transponders (twelve vertical polarization and twelve horizontal polarization)

providing coverage via a Mexican national beam. The Mexican national coverage beam

is designed to provide coverage to all of Mexico, Central America and part of the

Caribbean. This beam will carry national HD programming material. All Mexican

national programming material will be distributed either from within Mexico or from

DIRECTV broadcast facility locations within the U.S. The DIRECTV KU-76W system

and associated ground Ku-band assets will be capable of transmitting approximately 120

channels of HD programming.

       5.    Operational Characteristics

            5.1    Frequency and Polarization Plan

       Details of the DIRECTV KU-76W frequency/channelization and polarization

plan, including the TT&C frequencies, are included in the accompanying Schedule S,

which is hereby incorporated by reference as if fully set forth herein. The emission

designator for transmissions in the uplink and downlink will be 36M0G7W. The

allocated bandwidth for these emissions is 36 MHz.

       The interconnection capability of each national programming uplink channel to its

corresponding downlink channel for the DIRECTV KU-76W is shown in the

accompanying Schedule S. Note that because of the national coverage design, the uplink

and downlink channels can only be used once.


                                            4


            5.2     Communications Payload

                   5.2.1    Uplink Transmissions

        The maximum receive antenna gain, receive system noise temperature, and

maximum G/T of the DIRECTV KU-76W satellite are all specified in the accompanying

Schedule S. Note that the G/T will decrease, dB-for-dB, from the maximum as the uplink

location moves away from beam peak. All Mexican national uplink channels are to be

transmitted from locations within Mexico or from one or more of DIRECTV’s existing

uplink facilities in the U.S.

        The DIRECTV KU-76W uplink channels will be routed to the appropriate band-

limiting input multiplexer (“IMUX”) comprising the receive channel filters to limit the

bandwidth of received signals. The specified performance of these filters is shown in

Table 5-1. The received signals will then be frequency translated to the desired output

channel frequency. The filtered and frequency translated signals will be amplified by

channel amplifiers with selectable fixed/Automatic Level Control (ALC) modes prior to

final amplification. The fixed gain mode will have at least 20 dB of gain adjustment with

a step size of 1 dB. The ALC will hold the output level constant over an input dynamic

range of at least 15 dB and will have a minimum output level adjustment of 10 dB in 0.5

dB increments.

        Parameter              Frequency (Fc)                Specification
 Insertion Loss Variation          ±9 MHz                     0.15 dBp-p
                                  ±11.6 MHz                   0.19 dBp-p
                                  ±14.4 MHz                   0.40 dBp-p
                                  ±18.0 MHz                   1.14 dBp-p
  Out of Band Rejection           ±22.8 MHz                     3.0 dB
                                  ±35.5 MHz                    30.0 dB
                                  ±56.3 MHz                    30.0 dB
    Table 5-1. Response Characteristic of Representative DIRECTV KU-76W
                            IMUX Channel Filter


                                            5


                  5.2.2    Downlink Transmissions

       The national coverage downlink beams will use 150 Watt TWTAs which, when

combined with the transmit antenna gain, results in a maximum EIRP of 53 dBW. The

peak transmit antenna gain and associated contours are specified in the accompanying

Schedule S (see also Section 7.2).

       DIRECTV KU-76W will employ output multiplexer (“OMUX”) filters to limit

the bandwidth of transmitted signals. The specified performance for these filters is

shown in Table 5-2.

        Parameter                Frequency (Fc)             Specification
 Insertion Loss Variation            ±9 MHz                   0.10 dBp-p
                                    ±11.6 MHz                 0.15 dBp-p
                                    ±14.4 MHz                 0.22 dBp-p
                                    ±18.0 MHz                 0.38 dBp-p
  Out of Band Rejection             ±26.3 MHz                   3.0 dB
                                    ±33.3 MHz                  25.0 dB
 Table 5-2. Response Characteristic of Representative DIRECTV KU-76W OMUX
                                 Channel Filter

            5.3    TT&C Subsystem

       The TT&C subsystem provides redundant telemetry, tracking, and command

channels for the spacecraft. The principal functions of the subsystem are:

   1. Reception and amplification of the radio frequency command uplinks and
      demodulation of baseband for subsequent signal processing and command
      distribution.

   2. Modulation, up-conversion, amplification, and transmission of all telemetry data.

   3. Reception and retransmission of ground-station-generated ranging signals.

The subsystem is configurable to accommodate the unique requirements of pre-launch,

orbit raising, and on-station orbit operations. Access at initial spacecraft acquisition and

major orbit-raising maneuvers will be via the wide-beam (+Z) and narrow-beam (-Z)

omni antennas. Normal on-station commands will be received through the receive

                                              6


communications antenna, while on-station telemetry will be transmitted through the

transmit communications antenna. The command and telemetry frequencies and antenna

polarizations are shown in the accompanying Schedule S. The minimum cross-

polarization isolation for the on-station command and telemetry antennas will be 30 dB.

        The telemetry and command link performance is summarized in the link budget

analysis in Appendix C. The antenna patterns for the TT&C subsystem are discussed in

Section 7.3. The emission designators associated with the TT&C subsystem are

1M30F9D for command and 106KG9D for telemetry, with associated allocated

bandwidths of 1.3 MHz and 106 kHz for each of these emissions, respectively.

        6.     Orbital Locations

        The DIRECTV KU-76W satellite will operate at the nominal 76o W.L. orbital

location, and specifically at 76.0° W.L (see also Section 18 and GSO Orbit tab of

Schedule S). Until fairly recently, the Commission had licensed Ku-band satellite

operations at 74º WL, 77º W.L., and 79º W.L. – i.e., three slots covering five degrees of

the geostationary arc. However, the authorizations for the latter two slots lapsed and

were made available for reassignment,1 and there is currently no Ku-band satellite

operating at 74º W.L.2 The Commission recently granted DIRECTV’s application for

the Ku-band authorization at 79º W.L. to support Sky Mexico.3 Although this application

seeks authority to operate at 76º W.L. rather than 77º W.L. as previously authorized by

the Commission, it will maintain the same usage of orbital resources – i.e., three slots


1
    See Public Notice, 26 FCC Rcd. 6798 (Int’l Bur. 2011) (frequencies previously licensed to PanAmSat
    at the nominal 77º W.L. location available for reassignment); Public Notice, 27 FCC Rcd. 2040 (Int’l
    Bur. 2012) (frequencies previously licensed to SES Americom at nominal 79º W.L. available for
    reassignment).
2
    See Public Notice, 27 FCC Rcd. 570 (Int’l Bur. 2012) (granting application to modify license for
    Horizons 2 space station at 84.85º E.L. rather than 74.05º W.L.).
3
    See Grant Stamp, IBFS File No. SAT-LOA-20120316-00051 (dated July 12, 2012).
                                                    7


covering five degrees of the geostationary arc – and will maintain two-degree spacing

with respect to the vacant slot at 74º W.L.

       7.    Predicted Spacecraft Antenna Gain Contours

            7.1    Uplink Beams

       The satellite will receive communications signals from within Mexico and from

DIRECTV uplink locations within the U.S. in the 14.0-14.5 GHz frequency band using

both vertical and horizontal polarizations (see also Sections 5.1 and 5.2.1). Typical

DIRECTV KU-76W receive antenna gain contours are provided in GXT format in the

accompanying Schedule S and are also included in Appendix B. All uplink beams will

have a minimum cross-polarization isolation of 30 dB.

            7.2    Downlink Beams

       The national coverage beam for DIRECTV KU-76W will cover all of Mexico,

Central America and part of the Caribbean using both vertical and horizontal

polarizations. The peak transmit gain, and the antenna gain contours in GXT format, are

given in the accompanying Schedule S. These gain contours are also graphically

depicted in Appendix B. The downlink beams will have a minimum cross-polarization

isolation of 30 dB. (See also discussion in Sections 5.1 and 5.2.2.)

            7.3    TT&C Beams

       The TT&C coverage during transfer orbit and on-station contingency will be

provided by the wide angle TT&C antennas, which will be oriented around the nominal

+Z direction and the nominal –Z direction. The TT&C on-station coverage will be

provided by the receive communications antenna for command and by the transmit

communications antenna for telemetry. The receive antenna pattern for on-station

command and the transmit antenna beam pattern for on-station telemetry are given in


                                              8


GXT format in the accompanying Schedule S (see also Sections 7.1 and 7.2 above). The

wide beam TT&C antenna coverage pattern is shown in Appendix B as Figure B-4.

       8.    Service Description, Link Description and Performance Analysis, Earth
             Station Parameters

            8.1    Service Description

       As discussed more fully in Section II of this application, DIRECTV will use the

DIRECTV KU-76W satellite to transmit HD digital video and audio entertainment, and

educational and informational programming to customers throughout Mexico, Central

America and parts of the Caribbean, who will receive this programming using small dish

antennas.

            8.2    Link Performance

       A representative link budget is shown in Appendix A as Table A-1. This analysis

assumes a receive antenna size of 65 cm and also includes the interference contribution

for adjacent satellite interference from neighboring Ku-band satellite networks nominally

spaced at 2⁰, 4⁰, 6⁰ and 8⁰ away. It is further assumed that all of these neighboring

networks use 1.2 meter transmit earth stations with transmit power spectral density

comparable to that of DIRECTV KU-76W and that these neighboring satellites operate

with transmit power density comparable to that of DIRECTV KU-76W. Note that an

availability of 99.7% has been assumed for these link budgets.

       Representative link budgets for the telemetry and command links are shown in

Appendix C as Tables C-1 and C-2, respectively.

            8.3    Earth Station Parameters

       There are essentially two types of earth stations that will be used with the

DIRECTV KU-76W satellite: feeder-link earth stations and subscriber terminals. The

feeder-link stations will be relatively large transmit antennas, typically 8 to 9.1 meters,
                                              9


that track the satellite electronically and are used for transmitting national HD

programming material to the satellite. The subscriber terminals are effectively 65 cm

receive antennas that are installed at the customers’ premises and have fixed pointing,

which is optimized at installation.

       9.    Satellite Orbit Characteristics

       The DIRECTV KU-76W satellite will be maintained in geosynchronous orbit at

its nominal orbital location with a North-to-South drift tolerance of ± 0.05 degrees and an

East-to-West drift tolerance of ± 0.05 degrees. The antenna axis attitude will be

maintained so as to keep the beam pointing error to within 0.1 degrees.

       10.   Power Flux Density

       There are no power flux density limits in the 11.7-12.2 GHz space-to-Earth

frequency band to be use by DIRECTV KU-76W.

       11.   Arrangement for tracking, telemetry, and control

       DIRECTV has not yet contracted for the construction of the DIRECTV KU-76W

satellite, and therefore has not yet finalized arrangements for tracking, telemetry and

control. DIRECTV does, however, currently maintain a fleet of eleven satellites as part

of its existing business, and it is envisioned that TT&C for DIRECTV KU-76W would be

handled in a manner similar to that of DIRECTV’s existing satellites. DIRECTV will

evaluate its options and take all necessary steps to ensure that proper arrangements are in

place, well before satellite launch, to control the DIRECTV KU-76W satellite through its

launch and transfer orbit phase and into and during the operational lifetime phase of the

satellite mission, including post-operation disposal.

       12.   Physical Characteristics of the Space Station

       DIRECTV has not yet contracted for the construction of the DIRECTV KU-76W

satellite and therefore has not yet settled upon exact specifications for the physical
                                              10


characteristics of the satellite. Accordingly, the payload envelope has been sized to allow

more than one spacecraft currently available with extensive heritage and fully qualified

technology to serve as the design platform. With this proviso, DIRECTV anticipates that

the key spacecraft characteristics for DIRECTV KU-76W could be as summarized in the

appropriate sections of the accompanying Schedule S.

       13.   Spacecraft Bus Subsystem

       As discussed in Section 12 above, DIRECTV has not yet contracted with a

manufacturer for the construction of the DIRECTV KU-76W satellite and DIRECTV

does not wish to show a preference by providing data specific to any one manufacturer.

As such, it is difficult to discuss any specific characteristics of what may comprise the

spacecraft bus subsystem beyond that already included in the accompanying Schedule S.

       DIRECTV will provide the Commission with any and all required spacecraft bus

characteristics once a final spacecraft provider has been selected and a final satellite

design has been adopted.

       14.   Common Carrier Status

       DIRECTV intends to operate DIRECTV KU-76W on a non-broadcast, non-

common carrier basis. DIRECTV may sell and/or lease a portion of its capacity on a

non-common carrier basis for complementary business purposes.

       15.   Schedule

         DIRECTV will contract for, begin construction of, and launch and operate

DIRECTV KU-76W in accordance with any Commissions imposed satellite construction

milestones, such as those specified in Section 25.164 of the Commission’s rules.

       16.   Public Interest Considerations

       See Section II above.


                                             11


        17.    Interference Analysis

        The link budget included in Appendix A demonstrates that the DIRECTV KU-

76W satellite design described in this application will operate successfully within the

two-degree spacing environment established by the Commission’s policy and

implementing rules. Additionally, the proposed DIRECTV KU-76W satellite will remain

in compliance with the relevant technical rules established by the Commission.

        In terms of uplink interference compatibility, it is assumed that the transponder

gains of the DIRECTV KU-76W satellite and its neighboring satellites can be matched to

result in similar input signal spectral density levels at the satellites. In this case, the

uplink C/I will be a function of the difference between the gain of the transmitting earth

stations at boresight and the gain at the topocentric off-axis angle. The topocentric off-

axis angle for a geocentric separation of 2⁰ is approximately 2.2⁰. The off-axis gain at

2.2⁰ for an antenna that just meets the 29-25 log(Θ) reference pattern is 20.4 dBi. The

boresight gain will be a function of the antenna size of the transmitting earth station.

Table 17-1 illustrates the C/I that would result from different size transmitting earth

stations.

                     Table 17-1. Uplink C/I for 2⁰ geocentric spacing

                                   On axis Gain
            Antenna size (m)          (dBi)               Off-axis Gain          C/I (dB)
                  1.2                  43.2                   20.4                22.8
                  1.8                  46.7                   20.4                26.3
                  2.4                  49.2                   20.4                28.8


        Assuming that the minimum worst case required C/N for a digital service is 8 dB,

the effect of the worst case C/I from a 1.2 meter earth station (i.e., 22.8 dB) would only

degrade the C/N by 0.15 dB, equivalent to an increase of 3.5% in the interfered-with


                                               12


signal’s noise floor. This increase is less than the 6% coordination trigger specified in the

ITU Radio Regulations.

       In terms of downlink interference compatibility, it is assumed that the EIRP

density of the DIRECTV KU-76W satellite and its neighboring satellites are equal.

Similar to the uplink case, the downlink C/I will be a function of the difference between

the gain of the receiving earth stations at boresight and the gain at the topocentric off-axis

angle. The topocentric off-axis angle for a geocentric separation of 2⁰ is approximately

2.2⁰. The off-axis gain at 2.2⁰ for an antenna that just meets the 29-25 log(Θ) reference

pattern is 20.4 dBi. The boresight gain will be a function of the antenna size of the

receiving earth station. Table 17-2 illustrates the C/I that would result from different

size receiving earth stations.

     Table 17-2. Downlink C/I for 2⁰ geocentric spacing vs. receive antenna size

                                 On axis Gain
         Antenna size (m)           (dBi)               Off-axis Gain         C/I (dB)
              0.65                   36.3                   20.4               15.9
               1.2                   41.7                   20.4               21.2
               1.8                   45.2                   20.4               24.7
               2.4                   47.7                   20.4               27.2


       Assuming that the minimum receive earth station size and minimum required C/N

for a digital service for neighboring networks is 1.2 meters and 8 dB, respectively, the

worst case C/I for a 1.2 meter earth station (i.e., 21.2 dB) would only degrade the C/N by

0.2 dB, equivalent to an increase of 4.7% in the interfered-with signal’s noise floor. This

increase is less than the 6% coordination trigger specified in the ITU Radio Regulations.

Note that DIRECTV intends to use 65 cm receive earth stations (first line in Table 17-2

above) and that the worst case potential C/I from immediately adjacent satellites would

be 15.9 dB. This has been accounted for in arriving at the value of aggregate receive C/I

                                             13


in the link budget of Appendix A. As this link budget clearly shows, even with this

aggregate C/I the DIRECTV link budget closes with adequate margin.

       18.   Orbital Debris Mitigation

       DIRECTV intends to incorporate the material objectives set forth in this

application into the technical specifications established for procurement and construction

of DIRECTV KU-76W. DIRECTV will include provisions for review of orbit debris

mitigation as part of the preliminary design review and critical design review for the

spacecraft, and for incorporation of these objectives, as appropriate, into its test plan,

including a formal analysis of orbital debris risks associated with the TT&C, propulsion,

and power generation and storage systems. Because this mitigation statement is

necessarily forward looking, the process of procuring, designing, building, and testing

may result in minor changes to the parameters discussed herein. If appropriate,

DIRECTV will modify this mitigation statement to reflect such changes.

   Spacecraft Hardware Design

       DIRECTV has assessed and limited the amount of debris released in a planned

manner during normal operations. DIRECTV KU-76W will not be a source of debris

during launch, drift, or operating mode, as DIRECTV does not intend to release debris

during the planned course of operations of the satellite.

       DIRECTV will also consider the possibility of DIRECTV KU-76W becoming a

source of debris by collisions with small debris or meteoroids that could cause loss of

control of the spacecraft and prevent post-mission disposal. As such, DIRECTV will

take steps to address this possibility by incorporating redundancy, shielding, separation of

components, and other physical characteristics into the satellite’s design. For example,

omni-directional antennas will be mounted on opposite sides of the spacecraft, and either


                                              14


will be sufficient to support orbit raising. The command receivers and decoders,

telemetry encoders and transmitters, and the bus control electronics will be fully

redundant, physically separated, and located within a shielded area to minimize the

probability of the spacecraft becoming a source of debris due to a collision. DIRECTV

will continue to review these aspects of on-orbit operations with the spacecraft

manufacturer and will make such adjustments and improvements as appropriate to assure

that its spacecraft will not become a source of debris during operations or become derelict

in space due to a collision.

   Minimizing Accidental Explosions

        DIRECTV will contract for an overall spacecraft design that limits the probability

of accidental explosion. The key areas reviewed for this purpose will include leakage of

propellant and mixing of fuel and oxidizer as well as battery pressure vessels. The basic

propulsion design (including component and functional redundancy, and the placement of

fuel tanks inside a central cylinder which provides a high level of shielding), propulsion

subsystem component construction, preflight verification through both proof testing and

analysis, and quality standards will be designed to ensure a very low risk of propellant

leakage and fuel and oxidizer mixing that can result in subsequent explosions. During

the mission, batteries and various critical areas of the propulsion subsystem will be

continually monitored (for both pressure and temperature) to preclude conditions that

could result in the remote possibility of explosion and subsequent generation of debris.

       After DIRECTV KU-76W reaches its final disposal orbit, all on-board sources of

stored energy will be depleted, all fuel line valves will be left “open,” any pressurized

system will be vented, and all batteries will be left in a permanent discharge state. The

solar cells will be slewed away from the sun to minimize power generation.


                                             15


       Through this process, DIRECTV will assess and limit the possibility of accidental

explosions during mission operations and assure that all stored energy at the end of the

satellite’s operation will be removed.

   Safe Flight Profiles

        DIRECTV will assess and limit the probability of DIRECTV KU-76W becoming

a source of debris by collisions with large debris or other operational space stations

through detailed and conscientious mission planning. DIRECTV has reviewed the list of

licensed systems and systems that are under consideration by the Commission for the

76.0° W.L. orbital location it has requested. In addition, in order to address non-U.S.

licensed systems, DIRECTV has reviewed the list of satellite networks in the vicinity of

76.0° W.L. for which a request for coordination has been submitted to the ITU. Only

those networks that are operating, or are planned to be operating, within ± 0.2° have been

taken into account in this review.

       As a consequence of this review, it has been determined that no other system is

currently licensed by the Commission for, or is currently operating at, the nominal 76°

W.L. location. Accordingly, DIRECTV intends to operate DIRECTV KU-76W at the

76.0º W.L. position.

       With regard to ITU filings within ±0.2 degrees of 76.0° W.L., the only request for

coordination the ITU has published is for a United Kingdom satellite network (UKSAT-

KU-4) at 76º W.L. This ITU network was filed by the U.K. on behalf of DIRECTV UK

Ltd.

       Given the current absence of a construction contract for DIRECTV KU-76W, it is

difficult to assess what satellites will actually be operating at the nominal 76° W.L.

position at the time that the satellite is to be launched. As such, DIRECTV will certainly


                                             16


revisit this issue once a satellite construction contract is in place.

        Frequency and physical coordination during orbital drift cannot be undertaken

until the spacecraft and launch vehicle manufacturers are selected and a launch plan has

been developed. No pre-operational orbits requiring special temporary authority are

currently anticipated.

    Post-Mission Disposal

        Consistent with the requirements of Section 25.283(a) of the Commission’s rules,

at the end of the operational life of the satellite, DIRECTV will maneuver DIRECTV

KU-76W into a disposal orbit with an altitude no less than that calculated using the IADC

formula:

                                   36,021 km + (1000·CR·A/m).


Based on its experience with other satellites in its fleet, DIRECTV anticipates that, once

the satellite’s actual characteristics have been determined, this calculation will lead to a

disposal orbit with a minimum perigee of somewhat less than 300 km above the normal

GSO operational orbit.4 Accordingly, DIRECTV currently anticipates that it will

maneuver DIRECTV KU-76W to an altitude 300 km above GSO orbit at the end of its

operational life, which should provide additional margin above the results of the IADC

formula.

        DIRECTV currently intends to allocate and reserve approximately 10 kg of

propellant for final orbit raising maneuvers to this altitude. This value was determined

through a detailed launch vehicle propellant budget analysis applied to the parameters of

one of DIRECTV’s most recently designed satellites. In addition, DIRECTV has


4
    For example, the disposal orbit perigee calculated for the DIRECTV 12 satellite was approximately
    289 km above GSO orbit altitude, which DIRECTV rounded up to 300 km to provide adequate margin.
                                                17


assessed fuel gauging uncertainty and this budgeted propellant provides an adequate

margin of fuel reserve to ensure that the disposal orbit will be achieved despite such

uncertainty.

   III. ITU COST RECOVERY


         DIRECTV is aware that, as a result of the actions taken at the 1998

Plenipotentiary Conference, as modified by the ITU Council in 2005, processing fees are

now charged by the ITU for satellite network filings. As a consequence, Commission

applicants are responsible for any and all fees charged by the ITU. DIRECTV hereby

states that it is aware of this requirement and accepts responsibility to pay any ITU cost

recovery fees associated with this application. Invoices for such fees may be sent to the

contact representative listed in the accompanying FCC Form 312.

   IV.    CONCLUSION

         In summary, the satellite proposed in this application will provide DIRECTV with

a highly capable spacecraft that will support a significant amount of additional high

quality HD multichannel video programming for millions of subscribers in Mexico,

Central America and parts of the Caribbean. This new capability will expand

opportunities for a diverse array of HD programming, advance the HDTV transition, and

enhance DIRECTV’s ability to offer a powerful alternative to incumbent cable operators.

For these reasons, DIRECTV submits that the proposed satellite will serve the public

interest and respectfully requests that the Commission expeditiously grant this

application.




                                             18


Respectfully submitted,

DIRECTV ENTERPRISES, LLC



By:    __\s\________________________
       Romulo Pontual
       Executive Vice President




      19


                         ENGINEERING CERTIFICATION



The undersigned hereby certifies to the Federal Communications Commission as
follows:

 (i) He is the technically qualified person responsible for the engineering information
     contained in the foregoing Application,

 (ii) He is familiar with Part 25 of the Commission's Rules, and

 (iii) He has either prepared or reviewed the engineering information contained in the
       foregoing Application, and it is complete and accurate to the best of his knowledge
       and belief.


                                             Signed:


                                             /s/
                                             Jack Wengryniuk
                                             Senior Director
                                             DIRECTV Engineering

                                             November 1, 2012
                                             Date


           APPENDIX A


DIRECTV KU76W LINK BUDGET ANALYSIS


                                                             Clear
DIRECTV KU-76W                        Mexico City             Sky     Rain Dn

Uplink C/N (thermal), dB    Transmit power, dBW                17.0      19.0
                            Transmit power density dBW/Hz     -58.6     -56.6
                            Transmit losses, dB                -2.0      -2.0
                            Ground antenna gain, dB            59.8      59.8
                            Antenna pointing loss, dB          -0.5      -0.5
                            Free space loss, dB              -207.6    -207.6
                            Atmospheric loss, dB               -0.2      -0.2
                            Uplink rain loss, dB                0.0      -2.0
                            Satellite G/T, dB/K                 3.8       3.8
                            Bandwidth, dB-Hz                   74.8      74.8
                            Boltzmann's constant, dBW/Hz K    228.6     228.6

Total Uplink C/N                                              24.1       24.1

Downlink C/N (thermal),dB   Satellite EIRP, dBW/36 MHz         53.0      53.0
                            Free space loss, dB              -206.0    -206.0
                            Atmospheric loss, dB               -0.2      -0.2
                            Downlink rain loss, dB              0.0      -2.5
                            Rain temp increase, dB              0.0      -2.2
                            Rcv. antenna pointing loss, dB     -0.5      -0.5
                            Ground G/T, dB/K                   14.0      14.0
                            Bandwidth, dB-Hz                   74.8      74.8
                            Boltzmann's constant, dBW/Hz K    228.6     228.6

Total Downlink C/N                                            14.1         9.4

                                                             Clear
                                                              Sky     Rain Dn
Totals                      Uplink C/N (thermal), dB          24.1       24.1
                            Downlink C/N (thermal), dB        14.1         9.4
                            x-pol interference, dB            99.0       99.0
                            C/I from ASI                      11.0       11.0

                            Total C/(N+I), dB                   9.2        7.0
                            Required C/(N+I), dB                3.8        3.8

                            Margin, dB                          5.4        3.2

    Table A-1. DIRECTV KU76W Link Budget – Mexican National Coverage


     APPENDIX B


Antenna Beam Contours


  -4.00
                    0.00
           -2.00                     -6.00
  -15.00
                             -2.00

            -8.00
                    -10.00




                                        -20.00




Figure B-1. DIRECTV KU-76W Receive Beam


    -8.00


                                                 -20.00
                             -10.00


            -4.00 0.00
             -6.00-2.00
                                        -15.00

                                      -2.00
                          -15.00




Figure B-2. DIRECTV KU-76W Transmit Beam


                      FORWARD PIPE
                          ±40




                                              (Z-A XIS)


          BICO NE
            ±20




                            ±40
                          AFT PIPE




Figure B-3. DIRECTV KU-76W Wide Beam TT&C Antenna Coverage


  APPENDIX C


TT&C Link Budgets


  Frequency                          11705    MHz
  Transmit power                       -7.5   dBW
  Transmit losses                       5.0   dB
  Antenna gain at EOC in CONUS        27.8    dBi

  EIRP                                 15.3   dBW
  Spec.                                12.0   dBW
  Margin                                3.3   dB



Table C-1. DIRECTV KU-76W On-Station Telemetry Link Budget




  Frequency                          14005    MHz
  Flux density at S/C                 -90.5   dBW/m^2
  Isotropic area                      -44.4   dB-m^2
  Antenna gain                         36.5   dB
  Receive losses                       19.0   dB

  Command receiver input power        -87.4   dBm
  Command receiver threshold         -122.0   dBm
  Margin                               34.6   dB



Table C-2. DIRECTV KU-76W On-Station Command Link Budget



Document Created: 2019-04-10 18:07:35
Document Modified: 2019-04-10 18:07:35

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