Attachment ex parte

ex parte

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by DIRECTV

ex parte

2005-09-22

This document pretains to SAT-MOD-20050513-00101 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2005051300101_458319

EX PaRTE OR Lare FLEp HaRRis y 1200 ovremem smeernrow wasimnoron, oc 20006 WTetep Te 202230900 nocaeea0.301 ORIGINAL smsememnnn son ETT Sno aromersar uw September 22, 2004 RECEIVED Received SEP 2 2 2005 BY HAND DELIVERY Marlene H. Dortch CT OCT 04 2 005 udn Communt atem mmuniaten s Conniaton Seastar y Poliey Branch Federal Communi cations Commission intomational Bureau 445 Twelfth Street, S.W. Washington, DC 20554 Re:=— DIRECTV Enterpriscs, LLC — Ex Parte Communication SAT—RPL—20050322—00070 SAT—MOD—20050513—00100 SAT—MOD—20050513—00101 Dear Ms. Dortch DIRECTV Enterprises, LLC (DIRECTV") has filed the above referenced applications for authority to locate two satellites, DIRECTV 8 and DIRECTV 95, at the nominal 101° W.L. orbital location. Mobile Satellite Ventures Subsidiary LLC (°MSV") filed Comments on those applications in which it: (1) noted congestion at this orbital location due to the number of satelites operating there, (2) noted that DIRECTV and MSV have held productive inital conversations regarding the physical arrangement of their respective satellits atthis slot,but have not yet come to a comprehensive agreement, and (3) requested that the Bureau condition grant of DIRECTVs applications on successful coordination of its satellites at 101° W.L. with those of MSV at the same nominal location.! While DIRECTV agrees that this orbitalslot is congested, and has in fact discussed improving the current physical arrangement ofthe satellites at 101° W.L. with the other two operators that have satellites atthis location (%e., MSV and SES Americom), we disagree with the third point above. No such condition on grant of DIRECTV‘s applications is justified or required in this case. MSV cites no precedent in which the Commission has imposed such a condition, and DIRECTV is aware ofnone. ‘— See Comments of Mobile Satllte Ventures Subsidiary LLC, File Nos. SAT—RPL—20050322— 00070, SAT—MOD—20050513—00100, and SAT—MOD—20050513—00101 (filed May 31, 2005)

Hamas, Wirsume & Grannis Marlene H. Dortch September 22, 2005 Page 2 Moreover, because DIRECTV 8 and DIRECTYV 98 will replace other DIRECTV satelltes licensed to operate at 101° W.L., operation of these two satelltes will not have any effect on congestion at this slot.* Itis hard to understand how MSV‘s rights (whatever they may be) could be prejudiced by a substittion ofnew DIRECTV satellites for older ones thatleaves the total number ofits satellites at 101° W.L. unchanged. DIRECTV notes that, although the Commission recently authorized MSV to launch its own next—generation satelite (MSV—1) to the nominal 101° W.L. location, that authorization did notinclude a coordination condition such as MSV has proposed here." MSV has consistently characterized that satellite as a replacement for the AMSC—I satellite currently operating at 101° W.L., which would then become an in—orbit spare and therefore could be moved out ofthe congested center of this cluster." DIRECTV‘s replacement applications are no different in this respect, and therefore should not be subject to different treatment DIRECTV will continue to discuss possible improved physical arrangements for the satellites atthe nominal 101° W.L. location, and remains hopeful that the affected parties can reach a consensus plan. However,it would be inappropriate to impose the condition MSV has proposed — one that would make such consensus a precondition to operation ofDIRECTV‘s replacement satellites, and thereby give MSV unilateral veto rights, Such a condition finds absolutely no support in either the facts or Commission precedent, and should be refected. Sincerely yours, Tady... 1. Abilsct=> William M. Wiltshire Counselfor DIRECTV Enterprises, LLC * Contrary to MSV‘s assertion that "DIRECTV does not specify a precise orbital location" for DIRECTV 98 (seeid.at2), the application clearly statesthat it will replace the DIRECTV 1 satellitatthe 101.125° W.L. orbital loction.". See Application, File No. SAT—RPL— 20050322:00070, Exhibit D, at A—15. See also d. at A—18 (lsting 101.125° W.L. as proposed orbitl lcation). * See Mobile Satelite Ventures LLC, 20 FCC Red. 9752 (Int| Bur, 2005). * See, eg, Amendment, File No. SAT—AMD—20040209—00014, t 1 (‘MSV‘s replacement Mobile Satellte Service(MSSsatllte (MSV—1°)willbelocated in the geostatonary orbital are at 101° WL..... After the trafic is transfered, the frst generation satelite will be used as an in orbit spare.".

> Marias, Wicrsinee & Grannis Marlene H. Dortch September 22, 2005 Page3 ce Cassandra Thomas Robert Nelson Chip Fleming Bruce D. Jacobs Jennifer A. Manner


Document Created: 2005-10-04 18:18:38
Document Modified: 2005-10-04 18:18:38
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