Attachment MOD - S2712

This document pretains to SAT-MOD-20110727-00136 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2011072700136_907995

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

____________________________________
                                        )
Application of                          )
                                        )
DIRECTV ENTERPRISES, LLC                )                  Call Sign: S2712
                                        )
For Minor Modification                  )                  File No. ____________________
of the DIRECTV RB-2                     )
Satellite in the 17/24 GHz Broadcasting )
Satellite Service at 103° W.L.          )
____________________________________)


                      APPLICATION FOR MINOR MODIFICATION

        DIRECTV Enterprises, LLC (“DIRECTV”) hereby requests that the Commission

modify its license for DIRECTV RB-2, a geostationary satellite in the 17/24 GHz

Broadcasting Satellite Service (“BSS”) authorized to operate at the nominal 103° W.L.

orbital location. 1 This modification has two aspects. First, DIRECTV proposes to expand

the current coverage area of DIRECTV RB-2 to include Puerto Rico. The minor

modification to the coverage area of the satellite will enhance DIRECTV’s ability to provide

service in this U.S. territory, 2 but will not create harmful interference to any other satellite

system. Second, DIRECTV provides post-mission disposal plans for this satellite, in

satisfaction of a condition in its authorization. 3 Accordingly, the proposed modification will

serve the public interest while having no countervailing effects.



1
    See DIRECTV Enterprises, LLC, 24 FCC Rcd. 9393 (Int’l Bur. 2009) (“DRB-2 Authorization”).
2
    Note that service to Puerto Rico is currently provided by a DIRECTV affiliate, DIRECTV Latin America,
    using leased satellite capacity.
3
    See DRB-2 Authorization, ¶ 39.



                                                    1


I.     CHANGES TO PREVIOUS TECHNICAL INFORMATION

       In this Application, DIRECTV seeks neither additional spectrum nor additional

orbital resources, but only a slight modification to the coverage area of the satellite to include

coverage of the U.S. territory of Puerto Rico. In accordance with Section 25.117(d)(1) of

the Commission’s rules, DIRECTV identifies in this Application, Technical Annex, and

associated Schedule S, only those items of information that have changed from its station

license and associated application(s). DIRECTV hereby certifies that the remaining

information in its station license and associated application(s) has not changed.

       The only aspect of the satellite’s operations that will change as a result of adding this

new coverage area is the predicted gain contours and peak EIRP. Accordingly, new contours

are included in an accompanying Schedule S, along with any other technical parameters that

have changed. In addition, a set of downlink gain contours are included in the Technical

Annex attached hereto along with accompanying sample link budgets.

II.    POST-MISSION DISPOSAL INFORMATION

       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 RB-1 into

a disposal orbit with an altitude no less than that calculated using the IADC formula:

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

where CR is the solar pressure radiation coefficient of the spacecraft, and A/m is the Area to

mass ratio, in square meters per kilogram, of the spacecraft. The relevant values for the

DIRECTV RB-1 satellite are:

               CR = 1.24

               A = 112 m2

               m = 3550 kg


                                                2


Inserting these values into the equation yields the following results:

                       36,021 km + (1000*1.24*(112/3550)) = 36,060 km

Since geostationary altitude is generally considered to be 35,786 km, 4 this yields a desired

disposal orbit of at least 274 km above the geostationary arc. DIRECTV intends to boost

DIRECTV RB-1 to at least this height, and in fact will target a height of approximately 300

km above geostationary altitude.

        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. In addition, DIRECTV has 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.

        DIRECTV also notes that the only satellite network request for coordination located

within ±0.15 degrees of 102.825° W.L. published by the ITU is that for USASAT-70W,

which was submitted to the ITU on behalf of DIRECTV. In addition, the only currently

operating satellite within ±0.10 degrees of 102.825° W.L. is DIRECTV 10 located at

102.815° W.L., and DIRECTV will ensure safe operations of DIRECTV RB-2 with its own

satellite. Accordingly, this completes physical coordination of the satellite with operators of

space stations with potentially overlapping stationkeeping volumes, as required under the

DRB-2 Authorization. 5




4
    Mitigation of Orbital Debris, 19 FCC Rcd. 11567, ¶ 65 (2004).
5
    See DRB-2 Authorization, ¶ 38.


                                                     3


III.      THE PROPOSED MODIFICATION WOULD SERVE THE PUBLIC INTEREST

          The predicted antenna gain contour submitted in connection with the DIRECTV RB-

2 authorization includes coverage of CONUS+Alaska+Hawaii, and DIRECTV requests that

it be authorized to add the territory of Puerto Rico to the coverage area of this satellite. This

modification will enable DIRECTV or one of its affiliates to enhance the services provided to

Puerto Rico significantly, by both increasing the number of channels available and by

providing more of those channels in high definition format. As a result, this change will

allow DIRECTV to enhance competition, offering Puerto Rican consumers an even more

robust multichannel video alternative to incumbent cable systems.

          Moreover, DIRECTV’s proposal will achieve this benefit without causing harmful

interference to any other operator. In fact, with the changes proposed for the downlink

antenna pattern, the peak EIRP over CONUS will decrease from the previously authorized 63

dBW/36 MHz channel to approximately 58 dBW/36 MHz channel, and the peak EIRP over

Puerto Rico will be approximately 54 dBW. A figure illustrating the downlink antenna gain

contours for the proposed revised downlink antenna pattern is shown in the attachment to this

application.

          The allowable PFD levels in the 17.3-17.7 GHz band are defined in Section

25.208(w) of the Commission’s rules on a regional basis for all conditions, including clear

sky, and for all methods of modulation as:

       (1) In the region of the contiguous United States, located south of 38º North Latitude and
           east of 100º West Longitude: -115 dBW/m2/MHz;

       (2) In the region of the contiguous United States, located north of 38º North Latitude and
           east of 100º West Longitude: -118 dBW/m2/MHz;




                                                 4


      (3) In the region of the contiguous United States, located west of 100º West Longitude: -
          121 dBW/m2/MHz; and

      (4) For all regions outside of the contiguous United States including Alaska and Hawaii:
          -115 dBW/m2/MHz.

The maximum CONUS downlink EIRP for the revised DIRECTV RB-1 transmit antenna

will be approximately 58.0 dBW/36 MHz channel. DIRECTV calculates the maximum

power flux density/MHz on the Earth’s surface from this emission as: Max EIRP/channel

minus spreading loss in direction of max gain minus bandwidth correction factor, or 58.0

dBW/36MHz – 162.4 (dB-m2) – 10log(36) = -120 dBW/m2/MHz. This maximum would

occur at beam peak, over Florida, and as can readily be seen from the gain contours in the

attachment, this necessarily means that the revised DIRECTV RB-1 would easily comply

with the allowable PFD levels defined in Section 25.208(w), with at least 4 dB of margin

throughout the CONUS coverage area. Since the maximum EIRP over Puerto Rico is

approximately 4 dB less than the maximum over CONUS, the maximum PFD would also be

approximately 4 dB less and would again easily comply with the requirements of Section

25.208(w).

         For the foregoing reasons, DIRECTV submits that grant of the proposed minor

modification would serve the public interest and respectfully requests that the Commission

expeditiously grant this request.

IV.      WAIVER PURSUANT TO SECTION 304 OF THE COMMUNICATIONS ACT

         In accordance with Section 304 of the Communications Act of 1934, as amended, 47

U.S.C. § 304, DIRECTV hereby waives any claim to the use of any particular frequency or

of the electromagnetic spectrum as against the regulatory power of the United States because

of the previous use of the same, whether by license or otherwise.


                                                5


Respectfully submitted,

DIRECTV ENTERPRISES, LLC



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




        6


                         ENGINEERING CERTIFICATION

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

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

(ii)    I am familiar with Part 25 of the Commission's Rules, and

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



                                             Signed:


                                             /s/
                                             Jack Wengryniuk


                                             July 26, 2011
                                             Date


TECHNICAL ATTACHMENT


Figure A—1. Downlink Gain Contours for DIRECTV RB—2




                          A—l


Table A-1. DIRECTV RB-2 Link Budget – Downlink to Miami

                                                 Rain Up
                                       Clear     and Rain
                                       Sky         Dn
Uplink
Transmit power, dBW                       12.2       17.2
Transmit losses, dB                        1.2        1.2
Ground antenna gain, dB                   65.2       65.2
Antenna pointing loss, dB                  0.5        0.5
Free space loss, dB                      211.5      211.5
Atmospheric loss, dB                       1.0        1.0
Uplink rain loss, dB                       0.0        5.0
Satellite G/T, dB/K                       17.5       17.5
Bandwidth, dB-Hz                          74.8       74.8
Boltzmann's constant, dBW/Hz K          -228.6     -228.6
Uplink C/N (thermal), dB                  34.5       34.5
C/I (x-pol, NPR), dB                      25.0       25.0
Total Uplink C/(N+I), dB                  24.5       24.5

Downlink
Satellite EIRP, dBW/36 MHz                58.0       58.0
Free space loss, dB                      208.7      208.7
 Gaseous                                   0.4        0.4
 Cloud                                     0.6        0.6
 Scintillation                             0.4        0.4
 Downlink rain loss, dB                    0.0        5.8
Rain temp increase, dB                     0.0        4.0
Rain + Atmos Loss, dB                      1.2        6.9
Rcv. antenna pointing loss, dB             1.0        1.0
Antenna wetting + noise increase, dB       0.0        1.0
Ground G/T, dB/K                          17.9       17.9
Bandwidth, dB-Hz                          74.8       74.8
Boltzmann's constant, dBW/Hz K          -228.6     -228.6
Total Downlink C/N, dB                    18.8        8.1

Totals
Uplink C/N (thermal), dB                  24.5       24.5
Downlink C/N (thermal), dB                18.8        8.1
 x-pol interference, dB                   20.0       20.0
 Aggregate C/I from ASI                   18.0       18.0
 Aggregate C/I from TX E/S                43.3       43.3
 Adjacent Channel C/I, dB                 25.0       25.0
 Co-frequency C/I, dB                     99.0       99.0
Total C/(N+I), dB                         13.4        7.2
Required C/(N+I), dB                       4.7        4.7
Margin, dB                                 8.7        2.5




                                 A-2


Table A-2. DIRECTV RB-2 Link Budget – Downlink to Chicago

                                                 Rain Up
                                       Clear     and Rain
                                       Sky         Dn
Uplink
Transmit power, dBW                       12.2       17.2
Transmit losses, dB                        1.2        1.2
Ground antenna gain, dB                   65.2       65.2
Antenna pointing loss, dB                  0.5        0.5
Free space loss, dB                      211.5      211.5
Atmospheric loss, dB                       1.0        1.0
Uplink rain loss, dB                       0.0        5.0
Satellite G/T, dB/K                       17.5       17.5
Bandwidth, dB-Hz                          74.8       74.8
Boltzmann's constant, dBW/Hz K          -228.6     -228.6
Uplink C/N (thermal), dB                  34.5       34.5
C/I (x-pol, NPR), dB                      25.0       25.0
Total Uplink C/(N+I)                      24.5       24.5

Downlink
Satellite EIRP, dBW/36 MHz                54.0       54.0
Free space loss, dB                      208.8      208.8
 Gaseous                                   0.4        0.4
 Cloud                                     0.7        0.7
 Scintillation                             0.5        0.5
 Downlink rain loss, dB                    0.0        2.9
Rain temp increase, dB                     0.0        3.3
Rain + Atmos Loss, dB                      1.3        4.0
Rcv. antenna pointing loss, dB             1.0        1.0
Antenna wetting + noise increase, dB       0.0        1.0
Ground G/T, dB/K                          17.9       17.9
Bandwidth, dB-Hz                          74.8       74.8
Boltzmann's constant, dBW/Hz K          -228.6     -228.6
Total Downlink C/N, dB                    14.7        7.6

Totals
Uplink C/N (thermal), dB                  24.5       24.5
Downlink C/N (thermal), dB                14.7        7.6
 x-pol interference, dB                   20.0       20.0
 Aggregate C/I from ASI                   17.0       17.0
 Aggregate C/I from TX E/S                43.3       43.3
 Adjacent Channel C/I, dB                 25.0       25.0
 Co-frequency C/I, dB                     99.0       99.0
Total C/(N+I), dB                         11.5        6.8
Required C/(N+I)                           4.7        4.7
Margin, dB                                 6.8        2.1




                                 A-3


Table A-3. DIRECTV RB-2 Link Budget – Downlink to Los Angeles

                                                    Rain Up
                                          Clear     and Rain
                                          Sky         Dn
 Uplink
 Transmit power, dBW                         12.2       17.2
 Transmit losses, dB                          1.2        1.2
 Ground antenna gain, dB                     65.2       65.2
 Antenna pointing loss, dB                    0.5        0.5
 Free space loss, dB                        211.5      211.5
 Atmospheric loss, dB                         1.0        1.0
 Uplink rain loss, dB                         0.0        5.0
 Satellite G/T, dB/K                         17.5       17.5
 Bandwidth, dB-Hz                            74.8       74.8
 Boltzmann's constant, dBW/Hz K            -228.6     -228.6
 Uplink C/N (thermal), dB                    34.5       34.5
 C/I (x-pol, NPR), dB                        25.0       25.0
 Total Uplink C/(N+I), dB                    24.5       24.5

 Downlink
 Satellite EIRP, dBW/36 MHz                  52.0       52.0
 Free space loss, dB                        208.8      208.8
  Gaseous                                     0.4        0.4
  Cloud                                       0.2        0.2
  Scintillation                               0.3        0.3
  Downlink rain loss, dB                      0.0        1.6
 Rain temp increase, dB                       0.0        2.1
 Rain + Atmos Loss, dB                        0.8        2.2
 Rcv. antenna pointing loss, dB               1.0        1.0
 Antenna wetting + noise increase, dB         0.0        1.0
 Ground G/T, dB/K                            17.9       17.9
 Bandwidth, dB-Hz                            74.8       74.8
 Boltzmann's constant, dBW/Hz K            -228.6     -228.6
 Total Downlink C/N, dB                      13.2        8.6

 Totals
 Uplink C/N (thermal), dB                    24.5       24.5
 Downlink C/N (thermal), dB                  13.2        8.6
  x-pol interference, dB                     20.0       20.0
  Aggregate C/I from ASI                     18.0       18.0
  Aggregate C/I from TX E/S                  43.3       43.3
  Adjacent Channel C/I, dB                   25.0       25.0
  Co-frequency C/I, dB                       99.0       99.0
 Total C/(N+I), dB                           10.9        7.7
 Required C/(N+I), dB                         4.7        4.7
 Margin, dB                                   6.2        3.0


                                    A-4


Table A-4. DIRECTV RB-2 Link Budget – Downlink to Juneau

                                                 Rain Up
                                       Clear     and Rain
                                       Sky         Dn
Uplink
Transmit power, dBW                       12.2       17.2
Transmit losses, dB                        1.2        1.2
Ground antenna gain, dB                   65.2       65.2
Antenna pointing loss, dB                  0.5        0.5
Free space loss, dB                      211.5      211.5
Atmospheric loss, dB                       1.0        1.0
Uplink rain loss, dB                       0.0        5.0
Satellite G/T, dB/K                       17.5       17.5
Bandwidth, dB-Hz                          74.8       74.8
Boltzmann's constant, dBW/Hz K          -228.6     -228.6
Uplink C/N (thermal), dB                  34.5       34.5
C/I (x-pol, NPR), dB                      25.0       25.0
Total Uplink C/(N+I), dB                  24.5       24.5

Downlink
Satellite EIRP, dBW/36 MHz                51.0       51.0
Free space loss, dB                      209.3      209.3
 Gaseous                                   0.5        0.5
 Cloud                                     0.7        0.7
 Scintillation                             0.9        0.9
 Downlink rain loss, dB                    0.0        3.3
Rain temp increase, dB                     0.0        3.4
Rain + Atmos Loss, dB                      1.6        4.6
Rcv. antenna pointing loss, dB             1.0        1.0
Antenna wetting + noise increase, dB       0.0        1.0
Ground G/T, dB/K                          23.2       23.2
Bandwidth, dB-Hz                          74.8       74.8
Boltzmann's constant, dBW/Hz K          -228.6     -228.6
Total Downlink C/N, dB                    16.1        8.7

Totals
Uplink C/N (thermal), dB                  24.5       24.5
Downlink C/N (thermal), dB                16.1        8.7
 x-pol interference, dB                   20.0       20.0
 Aggregate C/I from ASI                   16.3       16.3
 Aggregate C/I from TX E/S                43.3       43.3
 Adjacent Channel C/I, dB                 25.0       25.0
 Co-frequency C/I, dB                     99.0       99.0
Total C/(N+I), dB                         11.9        7.6
Required C/(N+I), dB                       4.7        4.7
Margin, dB                                 7.2        2.9


                                 A-5


Table A-5. DIRECTV RB-2 Link Budget – Downlink to San Juan, PR

                                                   Rain Up
                                         Clear     and Rain
                                         Sky         Dn
Uplink
Transmit power, dBW                         12.2       17.2
Transmit losses, dB                          1.2        1.2
Ground antenna gain, dB                     65.2       65.2
Antenna pointing loss, dB                    0.5        0.5
Free space loss, dB                        211.5      211.5
Atmospheric loss, dB                         1.0        1.0
Uplink rain loss, dB                         0.0        5.0
Satellite G/T, dB/K                         17.5       17.5
Bandwidth, dB-Hz                            74.8       74.8
Boltzmann's constant, dBW/Hz K            -228.6     -228.6
Uplink C/N (thermal), dB                    34.5       34.5
C/I (x-pol, NPR), dB                        25.0       25.0
Total Uplink C/(N+I), dB                    24.5       24.5

Downlink
Satellite EIRP, dBW/36 MHz                  54.0       54.0
Free space loss, dB                        208.9      208.9
 Gaseous                                     0.2        0.2
 Cloud                                       0.2        0.2
 Scintillation                               0.3        0.3
 Downlink rain loss, dB                      0.0        4.9
Rain temp increase, dB                       0.0        3.5
Rain + Atmos Loss, dB                        0.6        5.3
Rcv. antenna pointing loss, dB               1.0        1.0
Antenna wetting + noise increase, dB         0.0        1.0
Ground G/T, dB/K                            17.9       17.9
Bandwidth, dB-Hz                            74.8       74.8
Boltzmann's constant, dBW/Hz K            -228.6     -228.6
Total Downlink C/N, dB                      15.3        6.0

Totals
Uplink C/N (thermal), dB                    24.5       24.5
Downlink C/N (thermal), dB                  15.3        6.0
 x-pol interference, dB                     20.0       20.0
 Aggregate C/I from ASI                     14.0       14.0
 Aggregate C/I from TX E/S                  43.3       43.3
 Adjacent Channel C/I, dB                   25.0       25.0
 Co-frequency C/I, dB                       99.0       99.0
Total C/(N+I), dB                           10.6        5.1
Required C/(N+I), dB                         4.7        4.7
Margin, dB                                   5.9        0.4


                                   A-6



Document Created: 2011-07-27 14:52:39
Document Modified: 2011-07-27 14:52:39

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