Attachment Narrative SAT-MOD-20140612-00065

Attachment Narrative

This document pretains to SAT-MOD-20140612-00065 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2014061200065_1050203

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

____________________________________
)
Application of )
)
DIRECTV ENTERPRISES, LLC ) Call Sign: S2712
)
For Minor Modification of Authorization to ) File No. SAT-MOD-___________
Launch and Operate DIRECTV RB-2 )
____________________________________)

APPLICATION FOR MINOR MODIFICATION OF
AUTHORITY TO LAUNCH AND OPERATE DIRECTV RB-2

On July 27, 2009, the Commission authorized DIRECTV Enterprises, LLC

(“DIRECTV”) to launch and operate DIRECTV RB-2, a 17/24 GHz BSS satellite, at the

nominal 103° W.L. orbital location. 1 Since that time, DIRECTV has contracted for a

multi-band, multi-mission satellite known as DIRECTV 15, which will carry a full 17/24

GHz BSS payload that will operate under the DIRECTV RB-2 authorization. 2 The

construction of DIRECTV 15 is now nearing completion and, accordingly, in this

Application DIRECTV requests that its 17/24 GHz BSS authorization be modified in the

manner set forth herein so that it will conform to the parameters of the satellite currently

under construction.

While the number of changes proposed herein is fairly numerous, upon review it

becomes clear that the changes are relatively minor refinements to what was previously

1
See DIRECTV Enterprises, LLC, 24 FCC Rcd. 9393 (Int’l Bur. 2009).
2
DIRECTV recently filed an application for authority to operate the Ka-band payload on the DIRECTV
15 satellite, as well as information related to the 12/17 GHz BSS payload that will not be licensed or
operated at this time. See Application Narrative, IBFS File No. SAT-LOA-20140604-00055 (filed
Jun. 4, 2014) (“D15 Application”). As discussed in greater detail below, certain aspects of that
application are relevant to this application as well, and have been incorporated by reference.

requested and authorized. Indeed, the changes proposed herein do not involve a request

for additional orbital or spectrum resources, and thus should be deemed minor in nature. 3

In accordance with Section 25.117(d)(1) of the Commission’s rules, DIRECTV

identifies in this Application only those items of information that should be changed from

its original application. For ease of reference, DIRECTV is also submitting a Schedule S,

which includes all of the revised technical information relevant to the 17/24 GHz BSS

payload. DIRECTV hereby certifies that the remaining information in its original

application and the Schedule S that accompanied it has not changed.

I. GRANT OF THIS APPLICATION WOULD SERVE THE PUBLIC INTEREST

DIRECTV is the nation’s leading provider of satellite direct-to-home video

services, with over 20 million subscribers. It began operations with a single satellite

operating in the Ku-band Broadcasting Satellite Service frequencies at a single orbital

location. In order to keep up with consumers’ demand for more video content and the

increasing bandwidth required to deliver such content (especially in high definition),

DIRECTV currently operates a fleet of satellites operating in the both Ku- and Ka-bands.

In order to meet future demand, including the impending introduction of high-bandwidth

programming in Ultra HD format, DIRECTV is now adding a third frequency band to its

operations – the 17/24 GHz BSS band. The DIRECTV RB-2 payload is an important

part of that expansion effort.

Since grant of its original license, DIRECTV has worked with its satellite

manufacturer to optimize operational parameters in the 17/24 GHz BSS band, consistent

with all applicable Commission rules. As a result, certain aspects of those operations as

originally envisioned have changed slightly. Granting this Application will serve the

3
See 47 C.F.R. § 25.117(d)(2)(iii) (defining major modification requests that must be placed in a
processing queue pursuant to Section 25.158).

2

public interest by conforming DIRECTV’s authorization to the parameters of the satellite

currently under construction, and thus help enable DIRECTV to become the first satellite

operator to provide commercial service using the 17/24 GHz BSS band.

For the foregoing 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,
4
AS REVISED

In this section, we present those aspects of DIRECTV’s original application for

authority to operate DIRECTV RB-2 that it proposes to modify. For ease of comparison,

the subsection headings in the discussion below correspond to the headings of the

relevant subsections from the original application.

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

As discussed above, DIRECTV RB-2 is now a 17/24 GHz BSS payload on a

multi-band, multi-mission satellite known as DIRECTV 15. While the coverage area for

the payload has not changed, the manner in which that area will be covered by the

downlink beams has been modified. In addition, one of the two previously identified

uplink locations has also changed. As discussed below, the TT&C for the overall satellite

is now no longer in the 17/24 GHz BSS band, but rather in one of the bands used by

4
In a recent Public Notice, the International Bureau set forth an interim waiver policy with regard to a
number of satellite application information requirements. (See Public Notice, “International Bureau
Adopts Policy of Granting Interim Waiver of Certain Requirements for Space Station Applications,”
29 FCC Rcd. 664 (Int’l Bur. 2014)). The information contained in this application and the
accompanying Schedule S is consistent with the policy set forth in that Public Notice. Accordingly,
DIRECTV requests grant of a waiver of the information requirements covered by the policy set forth
therein. Notably, DIRECTV seeks a waiver of Section 25.114(c)(4)(vi), which requires applicants to
specify the gain of each transponder channel including any adjustable gain step capabilities. As
required by Footnote 6 of the Public Notice, DIRECTV has entered a value of “1” in columns q and r
of Table S7. Further in accordance with the instructions provided in Footnote 6, and in reliance
thereon, DIRECTV states that such entries in these data fields are outside the scope of DIRECTV’s
certification concerning the accuracy of information provided in this application.

3

another payload on the satellite. Finally, there are a number of other, smaller changes to

the payload’s operations, which are discussed below.

5.1 Frequency/Channelization and Polarization Plan

Details of the DIRECTV RB-2 frequency/channelization and polarization plan

for the communications channels have not changed. As mentioned above, however, the

TT&C frequencies are no longer in the 17/24 GHz BSS band, but are now in the Ka-

band. 5 All uplink communications channels will be fed to DIRECTV RB-2 from two

distinct sites, these being the DIRECTV uplink facilities in Moxee, WA (“NWUF”) and

New Hampton, NH (“NEUF”), whereas previously these were NWUF and the DIRECTV

facility in Tucson, AZ (“SWUF”). The national channels will be delivered to the 48

contiguous states (“CONUS”) plus Alaska through a single beam, and to Hawaii and

Puerto Rico through dedicated spot beams, whereas previously this combined coverage

was provided with a single beam. All these beams will carry identical national HD

programming material.

5.2.1 Uplink Transmissions

The maximum G/T of the DIRECTV RB-2 satellite is specified in the

accompanying Schedule S, which is hereby incorporated by reference as if fully set forth

herein. Note that the previous G/T value of 17.5 dB/K has changed to 21.5 dB/K. The

minimum saturation flux density for each uplink beam is specified in the Schedule S and

the maximum saturation flux density is -80.7 dBW/m2 for beam S4 and -78.8 dBW/m2

for beam S5.

5
The parameters for TT&C operations are discussed fully in the D15 Application. See D15 Application
at 11-15 and App. B.

4

5.2.2 Downlink Transmissions

The maximum EIRP and EIRP density of the downlink beams will be as follows:

Beam Max EIRP (dBW/36 MHz) Max EIRP density (dBW/MHz)
CONUS+AK 58.9 43.3
Hawaii 57.5 41.9
Puerto Rico 60.6 45.0

These maximum levels are also included in the accompany Schedule S. Note that the

previous maximum EIRP of the single CONUS+AK+HI+PR beam was 58 dBW/36

MHz, and the maximum EIRP density was 42.4 dBW/MHz.

5.3 TT&C Subsystem

As DIRECTV RB-2 is now a payload on the DIRECTV 15 satellite, details of the

TT&C subsystem can be found in the application for DIRECTV 15. 6

6. Orbital Locations

DIRECTV seeks authority to operate DIRECTV RB-2 at 102.75° W.L. where it

will be essentially collocated with the SPACEWAY 1, DIRECTV 10 and DIRECTV 12

satellites. 7 This will enable DIRECTV to use a single dish to receive signals from all

four satellites.

6
See id.
7
Note that SPACEWAY 1 is currently authorized to operate at 102.925° W.L., DIRECTV 10 is
currently authorized to operate at 102.815° W.L. and DIRECTV 12 is currently authorized to operate
at 102.765° W.L. Before DIRECTV 15 is launched, DIRECTV will file requests to slightly modify the
orbital locations of these other two satellites such that the final configuration of these satellites will be
DIRECTV 15 at 102.75° W.L., DIRECTV 12 at 102.80° W.L., and DIRECTV 10 at 102.85° W.L.,
with the east-west station keeping of each satellite maintained to within ±0.025°. The location of
SPACEWAY 1 will remain unchanged in this new configuration.

5

7.1 Uplink Beams

DIRECTV RB-2 will receive communications signals from the DIRECTV uplink

facilities in Moxee, WA and New Hampton, NH. The receive antenna gain contour for

the DIRECTV RB-2 receive beams are given in GXT format in the accompanying

Schedule S.

7.2 Downlink Beams

DIRECTV RB-2 will employ a multiple beam transmit antenna system for 17/24

GHz BSS service to provide U.S. national coverage. One beam will cover

CONUS+Alaska, and individual spot beams will cover Hawaii and Puerto Rico. All

beams will be capable of transmitting across the frequency band 17.3-17.7 GHz using

LHCP and RHCP. The antenna gain contours, in GXT format, are given in the

accompanying Schedule S.

7.3 TT&C Beams

As discussed in Section 5.3, DIRECTV RB-2 is now a payload on the DIRECTV

15 satellite. The details of the TT&C beams for this satellite can be found in the

application for DIRECTV 15.

8.2 Link Performance

Representative communications link budgets for DIRECTV RB-2 are shown in

Appendix A as Tables A-1 to A-5, i.e., one for a city in each of the CONUS downlink

power flux density (“PFD”) regions defined by the Commission’s rules, and one each for

Hawaii and Puerto Rico. Because DIRECTV is applying for an orbital location that is

offset 0.25° from an Appendix F slot, these budgets include an entry for adjacent satellite

interference (“ASI”) from neighboring 17/24 GHz BSS satellites nominally spaced 3.75º,

4.25º, 7.75º and 8.25º away.

6

9. Satellite Orbit Characteristics

DIRECTV RB-2 will be maintained in geosynchronous orbit at the 102.75º W.L.

orbital location with a maximum N-S drift of ± 0.05°, and a maximum E-W drift of ±

0.025°. The antenna axis attitude will be maintained within a time-weighted 3σ value of

± 0.1° for all modes of operation.

10. Power Flux Density

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;

(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.

As discussed in Section 5.2.2 above, the maximum downlink EIRP for DIRECTV RB-2

in the CONUS+AK beam will be 58.9 dBW/36 MHz channel. DIRECTV calculates the

maximum power flux density 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 58.9 dBW/36MHz – 162.4 (dB-m2) – 10log(36) = -119.1 dBW/m2/MHz. The

maximum downlink EIRP for regions outside of the contiguous United States is 60.6

dBW which, through the same calculation, results in a maximum power flux density of

-117.4 dBW/MHz.

7

Because DIRECTV RB-2 will be placed at 102.75º W.L. rather than the Appendix

F slot of 103° W.L., there will be 0.25º less spacing between DIRECTV RB-2 and the

next closest on-grid location established in the BSS R&O. This slight offset results in 0.7

dB less discrimination from this adjacent location. 8 The maximum PFD calculated

above, which is 4.1 dB less than the maximum allowed in Section 25.208(w)(1) for

CONUS and 2.4 dB less than the maximum allowed for regions outside of CONUS,

accounts for this slight reduction in discrimination from this next closest location as

required under Section 25.140(b)(4)(iii). This means that the DIRECTV RB-2 system is

necessarily compliant with the PFD levels established in Sections 25.208(c) and

25.208(w)(1) and (4).

As discussed in Section 7.2 above, the downlink antenna gain pattern for

DIRECTV RB-2 is included in GXT format in the accompanying Schedule S, and is also

represented below for the CONUS+AK beam. Inspection of this pattern shows that (1)

the antenna peak gain is north of 38º North latitude and east of 100º W.L., but as

discussed above the peak PFD density for this beam of -119.1 dBW/MHz complies with

both Section 25.208(w)(1) and (w)(2); and (2) the antenna relative gain west of 100º

W.L. is at least 4 dB below peak gain, which means that the peak PFD density in this

region is below -123.1 dBW/MHz, making this beam compliant with Section

25.208(w)(3). As a result, the maximum PFD on the earth’s surface complies with

Section 25.208(w) in each of the applicable regions defined in the Commission’s rules.

8
This value is based on the reduction of topocentric angle and the assumption of a 45 cm receive
antenna that meets the reference antenna pattern of Section 25.224.

8

presented in Tables A-1 through A-5 in Appendix A, i.e. one budget for each of the

CONUS PFD regions defined in Section 25.208(w) and one budget for each of Hawaii

and Puerto Rico. In each case, the analysis includes the effects of adjacent satellite

interference from satellites nominally spaced 3.75º, 4.25º, 7.75º and 8.25º away in

evaluating whether the system accommodates the various data rates at acceptable C/(N+I)

thresholds. Additionally, adjacent satellite interference was calculated assuming 0.5°

mis-pointing of the receive antenna and 0.05° station-keeping of the interfering satellites.

Tables A-1 to A-5 of Appendix A demonstrate that the DIRECTV RB-2 design described

in this application is compatible with the aforementioned transmission parameters and

interference environment. Accordingly, the proposed 17/24 GHz BSS satellite would

operate successfully in such an environment.

To properly account for interference from adjacent operating satellite systems, the

uplink budgets include aggregate interference from earth terminals associated with

satellites at 3.75º, 4.25º, 7.75º and 8.25º of orbit separation. On the uplink, the budgets

include a level of interference that accounts for the maximum level of off-axis EIRP

permissible under Section 25.223. On the downlink, the satellites at 3.75º, 4.25º, 7.75º

and 8.25º of orbit separation are each assumed to produce an interference level equivalent

to the maximum PFD value permissible under Section 25.208(w) at that geographical

location. In all cases it is shown that the system, as proposed, will be able to operate

successfully in this interference environment. DIRECTV recognizes that it must accept

any increased interference from compliant systems operating at Appendix F slots that

may result from operating DIRECTV RB-2 at a slight offset from the on-grid slot at 103°

W.L.

10

18. Orbital Debris Mitigation

As discussed in this application, DIRECTV RB-2 is now a payload on the

DIRECTV 15 satellite. The details of the orbital debris mitigation plan for the satellite

can be found in the application for DIRECTV 15, and is hereby incorporated as if fully

set forth herein.

Respectfully submitted,

DIRECTV ENTERPRISES, LLC

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

11

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

June 12, 2014
Date

APPENDIX A

DIRECTV RB-2 LINK BUDGET ANALYSIS

Document Created: 2019-04-09 22:11:37
Document Modified: 2019-04-09 22:11:37

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