Attachment statement

statement

SUBMISSION FOR THE RECORD submitted by DIRECTV Group, Inc; DIRECTV Enterprise LLC

statement

2005-12-28

This document pretains to SAT-MOD-20040614-00113 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2004061400113_412640

§ rat ncsremm smernron HarRis, ceived mesmsige aot ie ae JAN 0 4 2005 Te romrs0 1300 necammo 901 vernoumsmersurecon O sng Po eromers im Intomationat December 28, 2004 RECEIVED BY HAND DELIVERY DEC 2 8 2004 Marlene H. Dortch Sfi Conmitatons Connien Secretary Offen o Sermry Federal Communications Commission 445 Twelfth Street, S.W. Washington, DC 20554 Re: Collision Avoidance Statements S47—MOD—20040614—00113 $4—M0D—20040614—00114 AN 0 s S47—M0D—20040630—00128 SAT—RPL—20010630—00127 Dear Ms. Dortch: On November 4, 2004, the International Bureau granted the above referenced satellite authorizations to The DIRECTV Group, Inc and DIRECTV Enterprises, LLC. Each of those authorizations included a condition requiring the submission of a colliion avoidance statement for the assigned orbital location. In satisfaction of those conditions, enclosed you will find the required statements for the 99° W.L., 101" W.L., and 103° W.L. orbital locations. Sincerely yours, William M. Wiltshire Counselfor The DIRECTY Group, Inc. and DIRECTY Enterprises, LLC Enclosures cc: SclinaKhan

Counision Avomance Stazement ror SPACEWAY—2 a199° W.L. DIRECTV has reviewed the lstof lcensed systems and systems that are under consideration by the FCC for the 99° W.L. orbital location. In order to address non—U.3. Hicensed systems, DIRECTV has reviewed the lstof satellite networks in the vicinity of 99° W.L. for which a request for coordination has been submited to the ITU. Only those networks that are operating or planned to be operated within + 0.2" of99° W.L. have been taken into account in this review. This review has determined that only one other system has been licensed by the FCC for operation at 99° W.L. That system is GALAXY IV(R), which is currently in operation. No other U.S. systems are currently under consideration for licensing by the FCC forthis location. Internationally, Canada, France, and United Kingdom have filed coordination requests for satellte networks atthis orbital location." DIRECTV can find no evidence that satellite construction contracts have been awarded for any ofthese networks, and we note that the FAA Commercial Space Station Second Quarter 2004 Report shows no pending launch for any of these networks. Physical coordination of SPACEWAY—2 with the GALAXY IV(R) network will be required. DIRECTV has contacted the operator of GALAXY IV(R) and confirmed that this satellie is being station kept at 9.0° W.L. + 0.05%. DIRECTV is authorized for an orbital position of 99.05"W.L. + 0.05¢. This would normally create a potential overlap of the station keeping volumes ofthese two satellites. However, DIRECTV intends to operate the SPACEWAY—2 satellite with a station keeping tolerance + 0.025° centered at a nominal orbitallongitude 0f 99.075°WL. In this way the SPACEWAY—2 satellte will * Note that althoush the adminstationof Lanemburgfledan APIat the TTU forasatelite network at 98.8° W.L, his API wasfolowed by a coortination equest that moved th Ailed locationfor this networl to 101° W.L, as is contemplated under RR 9.2 (MOD WRC:t2).

be maintained within its currently authorized orbital position without resulting in a station keeping volume overlap with GALAXY IV@R).

Conuston Avoiance Statement ror DIRECTV 8 xr 1019 W.L. DIRECTV has reviewed the lstof licensed systems, and systems that are under consideration by the PCC for the 101° W.L. orbitallocation. In order to address non— U.S. licensed systems, DIRECTV has reviewed the list of satellite networks in the vicinity of 101° W.L. for which a request for coordination has been submitted to the ITU. Only those networks that are operating or planned to be operated within + 0.2° of 101° W.L. have been taken into account in this review. This review has determined that ix other systems have been licensed by the FCC for, and are currently operating at,101° W.L. Those systems are AMSC—1, AMC—4, DIRECTV 1, DIRECTV 1R, DIRECTV 2, and DIRECTV 48. In addition, the Commission currently has pending applications from (1) Mobile Satellite Ventures (MSV), for a replacement satellite for AMSC—1, (2) Echostar, for a satellte to operate in the extended Ku—band, and (3) DIRECTV and Pegasus, to operate satellitesin the BSS reverse band when it becomes available in 207. Interationally, United Kingdom, France and Luxemburg have fled coordination requests with the ITU for satelite networks at this orbital location. Other than the replacement satellite for MSV, DIRECTV can find no evidence that stellite construction contracts have been awarded for any of these networks, and we note that the FAA Commercial Space Station Second Quarter 2004 Report shows no pending launch for any of these networks. Physical coordination of DIRECTV 8 with the AMC—4, AMSC—1, the MSV replacement satellie, and with the other satellitesin the DIRECTV network will be required. Under the current circummstances, te six satellites operating at the nominal 101° W.L.orbital position actually operate slightly offet from that position, and the four

DIRECTV satellitesat that location are operated such that there is no overlap of their station keeping volumes with those of AMC—4 and AMSC—1. The physical coordination of the DIRECTV satelltes amongst themselves is done entirely within DIRECTV. As explained in the DIRECTV 8 application, DIRECTV 8 will replace the DIRECTV 2 satellite currently operating at 101° W.L., and DIRECTV 2 will be moved outside the cluster at this slot, thereby making space for DIRECTV 8. Thus,the launch of DIRECTV 8 will have no net impact on the number of satelltes that DIRECTV intemnally coordinates at this location.

Couuision Avorpance Srarement ror SPACEWAY—1 at 103° W.L. DIRECTV has reviewed the lst of licensed systems and systems that are under consideration by the FCC for the 103° W.L.orbital location. In order to address non—U.S. Hicensed systems, DIRECTV has reviewed the list of satellte networks in the vicinity of 103° 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 operated, within + 0.2" of 103° W.L. have been taken into account in this review. This review has determined that only one other system has been licensed by the FCC for operation at 103° W.L. That system is AMC—1, which is currently in operation. No other U.S. systems are currently under consideration for licensing by the FCC for this location. Intemationally, Canada, Tonge, and United Kingdom have filed coordination requests for satellite networks at this orbital location. DIRECTV can find no evidence that satellite construction contracts have been awarded for any ofthese networks, and we note that the FAA Commercial Space Station Second Quarter 2004 Report shows no pending launch for any ofthese networks. Physical coordination of SPACEWAY—1 with the AMC—1 network will be required. DIRECTV is authorized for an orbital position of 103.05° W.L. + 0.05¢. DIRECTV intends to operate the SPACEWAY—1 satellite with a station keeping tolerance £0.025" centered ata nominal orbital longitude of 103.075" W.L. In this way the SPACEWAY—I satellte will be maintained within its currently authorized orbital position without resulting in a station keeping volume overlap with AMC—1, nominally located at 103.0° W.L., assuming a standard station keeping tolerance of +0.05 for the AMC—1 spacecraft

wee #3 os as:0ea ENCINEERING CERTIFICATION The undersigned hereby cenifiestothe Federal Communications Commision as follows: ® He is the technically qualiied person responsiblefor the engineering information contained in the foregoing Collision Avoidance Declerations for SPACEWAY 1, SPACEWAY 2, and DIRECTY 8, @ He is amilie with Part 25 of the Commission‘s Rules, and i He has ither prepared or reviewed the enginecting information contained in the foregoing Colliion Avoidance Declaraions, and it is complete and nocurete to the best oThis knowledge and belief Signed: wug Jack Wengryniuk Senjor Director DIRECTV Operations Inc. December 23, 2004 Dae


Document Created: 2005-01-06 17:28:15
Document Modified: 2005-01-06 17:28:15
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