Attachment Narrative

This document pretains to SAT-MOD-20140127-00010 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2014012700010_1032703

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ____________________________________ ) Application of ) ) DIRECTV ENTERPRISES, LLC ) Call Sign: S2455 ) For Modification of the ) File No. ____________________ DIRECTV-7S Authorization to ) Extend the License Term ) ____________________________________) APPLICATION FOR MODIFICATION DIRECTV Enterprises, LLC (“DIRECTV”) hereby applies for a seven-year extension, through April 4, 2021, of the license for its DIRECTV-7S spacecraft, call sign S2455. Grant of the requested modification will serve the public interest by enabling DIRECTV to continue to offer Direct Broadcast Satellite (“DBS”) services to millions of subscribers using DIRECTV-7S, ensuring efficient use of satellite and orbital resources while promoting competition in the multichannel video programming distribution (“MVPD”) market. A completed FCC Form 312 is attached, and DIRECTV hereby incorporates by reference the technical information previously provided regarding the operations of DIRECTV-7S.1 1 See File Nos. SAT-LOA-20030611-00115, SAT-AMD-20031126-00341, SAT-AMD-20031201- 00344, and SAT-MOD-20060616-00065. 1

MODIFICATION REQUEST DIRECTV-7S commenced operations at the 119.2º W.L. orbital location on June 4, 2004,2 and was relocated slightly in 2006 to its current operating position at 119.05° W.L.3 The satellite is licensed to operate in the DBS frequency bands (12.2-12.7 GHz downlink and 17.3- 17.8 GHz uplink), and provides service on both a national basis (including Alaska and Hawaii) and in localized spot beams, used for retransmission of local programming.4 Under the terms of its license and of Section 25.121(a)(2) of the Commission’s rules, the satellite has a license term of 10 years from the date DIRECTV certified the satellite had been successfully placed into orbit.5 Accordingly, the license will expire on June 4, 2014. By this application, DIRECTV respectfully requests that the term be extended by approximately seven years. Such an extension is warranted under the circumstances. DIRECTV-7S went into operation in June 2004, and was designed for an operational and mission life of greater than 15 years.6 Based on the amount of fuel remaining for continued operations at the 119.05° W.L. orbital location, including sufficient remainder to achieve a disposal orbit approximately 300 km above geosynchronous altitude, DIRECTV currently estimates that the spacecraft can continue providing reliable DBS service throughout the requested term extension. As a result, extending the license term of DIRECTV-7S will serve the public interest by allowing DIRECTV to continue to use the spacecraft to provide a high-quality video service offering to consumers 2 See Letter from William M. Wiltshire to Marlene H. Dortch (Nov. 1, 2004). 3 See Grant Stamp, IBFS File No. SAT-MOD-20060616-00065 (granted Aug. 31, 2006). 4 See DIRECTV Enterprises, Inc., 19 FCC Rcd. 7754 (Int’l Bur. 2004) (“D-7S Authorization Order”). 5 See D-7S Authorization Order, ¶ 17; 47 C.F.R. § 25.121(a)(2). 6 See IBFS File No. SAT-LOA-20030611-00115, DIRECTV 7S System Description at 1. 2

throughout the United States, ensuring the efficient use of satellite and orbital resources while promoting competition in the MVPD market. Schedule S. The proposed modification of the DIRECTV-7S license will not result in any changes to the spacecraft’s operating characteristics or to the interference environment. As a result, the information requested in Schedule S duplicates information that is already on file with the Commission concerning the technical parameters of the spacecraft’s operation. In similar cases involving requests for extension of a satellite’s license term, the International Bureau has not required the submission of a Schedule S.7 Accordingly, DIRECTV is not filing a Schedule S with this application. DIRECTV will nevertheless prepare and submit a Schedule S if requested to do so by the staff. CONCLUSION For the foregoing reasons, DIRECTV respectfully requests that the Commission modify the license for DIRECTV-7S to extend its term through April 4, 2021. Respectfully submitted, By: ____/s/________________________ William M. Wiltshire Romulo Pontual Michael Nilsson Executive Vice President and WILTSHIRE & GRANNIS LLP Chief Technology Officer 1200 Eighteenth Street, NW DIRECTV ENTERPRISES, LLC Washington, DC 20036 2230 E. Imperial Highway 7 See, e.g., Grant Stamp, IBFS File Nos. SAT-MOD-20111102-00211 (granted Jan. 18, 2012) (DIRECTV request for extension of DIRECTV-4S satellite license); SAT-MOD-20110718-00130 (granted Oct. 13, 2011) (SES Americom request for extension of AMC-1 satellite license); SAT- MOD-20090217-00024 (granted May 5, 2009) (XM Radio request for extension of XM-1 satellite license). 3

(202) 730-1300 El Segundo, CA 90245 (310) 964-5000 Counsel for DIRECTV Enterprises, LLC 4


Document Created: 2019-04-22 17:04:06
Document Modified: 2019-04-22 17:04:06
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