Attachment Narrative

This document pretains to SAT-MOD-20140624-00075 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2014062400075_1051806

                                          EXHIBIT A

                   APPLICATION FOR MILESTONE EXTENSION

        DIRECTV Enterprises, LLC (“DIRECTV”) is authorized to launch and operate

DIRECTV RB-2, a 17/24 GHz Broadcasting Satellite Service (“BSS”) payload (Call Sign

S2712), at the nominal 103° W.L. orbital location. 1 DIRECTV diligently entered into a

construction contract and a launch services contract for this spacecraft. When its

manufacturer began to experience delays in procuring vital parts for the satellite,

DIRECTV switched manufacturers in an effort to assure expeditious delivery of the

spacecraft. It has proceeded with construction under that second contract, and the

satellite is nearly complete with 91.4% of all pre-launch construction payments made.

DIRECTV has also maintained its place in the queue of its launch provider, and made

90% of the payments required under that agreement.

        Unfortunately, DIRECTV will not be able to meet the final milestone in its

DIRECTV RB-2 authorization. The spacecraft will not be completely constructed and

ready for delivery to the launch site until September. More importantly, for a variety of

reasons beyond DIRECTV’s control, the launch window for the satellite has moved

steadily later in time, and is currently estimated to fall in February/March 2015, after

which DIRECTV will need to conduct in-orbit testing before beginning operations at its

licensed location. Accordingly, pursuant to Section 308 of the Communications Act of

1934, as amended, and Section 25.117(e) of the Commission’s rules, DIRECTV hereby

requests a nine-month extension, up to and including April 27, 2015, to meet its “launch

and begin operations” milestone for DIRECTV RB-2. In the alternative, it requests that

the Commission waive that milestone for good cause shown.

1
    See DIRECTV Enterprises, LLC, 24 FCC Rcd. 9393 (Int’l Bur. 2009), recon. denied, 27 FCC Rcd.
    5932 (Int’l Bur. 2012) (“DRB-2 Authorization Order”); Grant Stamp, IBFS File No. SAT-MOD-
    20110727-00136 (Oct. 26, 2011).


    A. Although DIRECTV Has Proceeded Diligently, Unexpected Construction
       Issues Delayed Completion of the Satellite

        DIRECTV and its affiliates have invested decades of effort and several billion

dollars in developing and implementing the nation’s leading direct-to-home (“DTH”)

satellite system. As part of its ongoing efforts to augment its capabilities, in

1997DIRECTV filed a petition for rulemaking to allocate spectrum for the 17/24 GHz

BSS service in the U.S. Table of Frequency Allocations, 2 and was the first to seek

authority from the Commission to operate in the 17/24 GHz BSS band. 3 After

participating in the ensuing rulemaking and pursing its applications for over a decade,

DIRECTV was finally awarded several of the first licenses issued in this new band.

        One such license was for DIRECTV RB-2 to operate in the 17/24 GHz BSS band

at the nominal 103° W.L. orbital location. In order to make use of this license,

DIRECTV incorporated a 17/24 GHz BSS payload as part of a multi-mission, hybrid

spacecraft, known as DIRECTV 15, that also includes Ka-band and Direct Broadcast

Satellite payloads. 4 The DIRECTV RB-2 authorization included the following

performance milestone requirements:

    1. Execute a binding contract for construction by July 27, 2010;

    2. Complete the Critical Design Review (“CDR”) by July 27, 2011;

    3. Commence construction by July 27, 2012; and

    4. Launch and begin operations by July 27, 2014. 5




2
    See Public Notice, Report No. 2208 (rel. July 1, 1997).
3
    See IBFS File Nos. SAT-LOA-19970605-00049, -00050, and -00051.
4
    See Application Narrative, IBFS File No. SAT-LOA-20140604-00055 (filed Jun. 4, 2014).
5
    DRB-2 Authorization Order, ¶ 37.


                                                    2


DIRECTV timely submitted proof that it had satisfied the first three milestones. 6 In

addition, it entered into a launch services contract with Arianespace in September 2011. 7

        Unfortunately, due to circumstances beyond DIRECTV’s control, the schedule for

construction of its satellite began to slip. DIRECTV originally entered into a

construction contract with Space Systems/Loral (“SS/L”) in July 2010. In the spring of

2011, SS/L informed DIRECTV that acquisition of travelling wave tube arrays

(“TWTAs”) for the spacecraft had been delayed three months because the manufacturer

was experiencing significant manufacturing process development issues. Although

DIRECTV continued to work with SS/L and its TWTA manufacturer in an effort to

expedite delivery of these vital parts, the delay only grew worse. By the fall of 2011, the

projected delivery date for the TWTAs was several months behind schedule, with no firm

assurance that further delay would not occur.

        Rather than risk falling still further behind, DIRECTV terminated its agreement

with SS/L and entered into a new construction contract with Astrium SAS in October

2011. That agreement established a thirty-six month period from commencement of

construction to satellite delivery. This meant that the satellite would be slightly behind

the July 2014 launch and operate milestone unless the parties could accelerate production

along the way.




6
    See the following submissions in IBFS File Nos. SAT-LOA-20060908-00100, SAT-AMD-20080114-
    00014, and SAT-AMD-20080321-00077: Letter from William M. Wiltshire to Marlene H. Dortch
    (July 26, 2010) (contract submission); Letter from William M. Wiltshire to Marlene H. Dortch (July
    27, 2011) (submission of amended contract); Letter from William M. Wiltshire to Marlene H. Dortch
    (July 27, 2011) (CDR package submission); Letter from William M. Wiltshire to Marlene H. Dortch
    (July 27, 2012) (commence construction submission). DIRECTV’s showings with respect to all three
    milestones remain pending.
7
    See Press Release, “Arianespace to launch up to four satellites for DIRECTV” (Sep. 13, 2011)
    (available at http://www.arianespace.com/news-press-release/2011/9-13-2011-directv.asp).


                                                   3


       At all times, DIRECTV has proceeded diligently with development of the

DIRECTV RB-2 satellite system. Evidence of DIRECTV’s commitment to developing

and launching this satellite include the following:

  As verified by the letter attached hereto as Attachment A, DIRECTV has made

     91.4% of all pre-launch construction payments due under the Astrium construction

     contract. Astrium has assembled the spacecraft and completed all but the final

     functional and performances tests. It will be ready for delivery in mid-September –

     slightly ahead of the original schedule. DIRECTV has had an employee on-site at

     Astrium to monitor progress of construction.

  As further verified by the letter attached hereto as Attachment B, DIRECTV has

     paid Arianespace 90% of the price of the launch services contract applicable to

     DIRECTV 15, which remains in full force and effect.

  DIRECTV has also made significant progress with other elements of its system,

     including the construction of in-orbit test, TT&C and communications ground

     infrastructure at three of DIRECTV’s existing uplink facilities (in Castle Rock, CO,

     New Hampton, NH, and Moxee, WA), and development of new consumer

     equipment capable of receiving and processing signals in the 17/24 GHz BSS band.

Accordingly, the evidence demonstrates that DIRECTV has invested heavily and

consistently in the DIRECTV RB-2 system. Nonetheless, due to delays in construction at

the beginning of the process, completion of the satellite will miss the July 2014 launch

deadline by approximately 45 days.

   B. The Unavailability of a Launch Vehicle Has Unexpectedly Delayed
      DIRECTV’s Satisfaction of the Final Milestone Requirement Still Further

       As discussed above, DIRECTV has had a launch services contract with

Arianespace in place for several years, and during that time has been working toward a


                                             4


launch in the third quarter of 2014. Arianespace is one of the world’s premier launch

providers, capturing more than half of all commercial satellite launches each year. 8 With

an unbroken string of 59 successful Ariane 5 launches over the last eleven years, it is also

the most reliable launch service provider. 9 Unfortunately, although DIRECTV’s satellite

will be ready for delivery in September, no launch slot is available until 2015 due to a

combination of factors beyond DIRECTV’s control. These factors are discussed below.

         First, although DIRECTV has maintained its place in the Arianespace launch

queue, that place has marched steadily later in time due to delays in earlier-scheduled

launches. Given the complexity of the satellite launch process, delays are not an

uncommon occurrence in the industry. Moreover, because of the nature of Arianespace’s

co-passenger launches, one satellite operator may be ready for launch but be delayed by

wholly unrelated problems experienced by another satellite operator. Specifically,

         [t]he Ariane 5’s business model is based on launching two commercial
         telecommunications satellites at a time, which usually means pairing one
         large satellite with one that is much smaller. The difficulty of finding two
         satellites ready for launch at the same time with a combined weight that
         fits into the Ariane 5 has long been one of the challenges for
         Arianespace. 10

Indeed, this challenge was vividly illustrated at the end of 2013. Arianespace had

scheduled the final Ariane 5 launch of the year for December 6, 2013. Unfortunately, the

small satellite passenger on that flight (Amazonas 4A) was delayed, so both it and its co-



8
     See Arianespace Service and Solutions (available at http://www.arianespace.com/about-us/service-
     solutions.asp).
9
     See Arianespace – Launch Smart, at 3 (available at http://www.arianespace.com/about-us-corporate-
     information/Arianespace-Corporate-Brochure-2014-EN.pdf) (“Arianespace Brochure”); Arianespace
     Mission Update, “Arianespace’s Ariane 5 orbits satellites at the service of SES and HISPASAT” (Mar.
     22, 2014) (available at http://www.arianespace.com/news-mission-update/2014/1147.asp).
10
     Peter B. de Selding, “Ariane 5 Manifest Unsettled for Remainder of 2013 and into 2014,” SPACENEWS
     (Jun. 26, 2013) (available at http://www.spacenews.com/article/launch-report/35984ariane-5-manifest-
     unsettled-for-remainder-of-2013-and-into-2014).


                                                    5


passenger (Astra 5B) could not make use of that launch window. 11 Ultimately, that pair

of satellites was rescheduled for launch on March 7, 2014. 12 Even then, the launch was

further delayed by approximately two weeks in order to accommodate “complementary

checks” on the Amazonas 4A satellite. 13

         Arianespace also had to delay the currently pending Ariane 5 launch, most

recently scheduled for June 6, because one of the passengers (the Optus 10 satellite)

“requires additional verifications.” 14 Arianespace has yet to announce a rescheduled

date for that launch. Indeed, every Ariane 5 launch in 2014 has been delayed to some

extent. 15 Unfortunately, such delays inevitably push back launch windows for other

satellites in the queue, including DIRECTV 15 and its DIRECTV RB-2 payload.

         Second, although Sea Launch and International Launch Services (“ILS”) have the

capability to launch a satellite the size of DIRECTV 15, neither of them offers a practical

alternative. Switching to a different provider would not expedite launch of the satellite,

as there are already others waiting on their manifests. Indeed, the schedules of those

other launch providers also have been affected by recent anomalies. ILS suffered a


11
     See Stephen Clark, “Next Ariane 5 launch delayed to January by satellite issue,” SPACEFLIGHT NOW
     (Nov. 13, 2013) (available at http://spaceflightnow.com/ariane/va216/131113delay/).
12
     Arianespace Mission Update, “Dates set for Arianespace’s first three missions of 2014: Year-opening
     flight is VA217 on February 6”” (Jan. 14, 2014) (available at http://arianespace.com/news-mission-
     update/2014/1124.asp).
13
     Arianespace Mission Update, “Ariane 5 Flight VA216 is postponed for payload checks” (Feb. 14,
     2014) (available at http://www.arianespace.com/news-mission-update/2014/1132.asp).
14
     See Press Release, “Arianespace Flight VA218: Launch Postponed” (May 26, 2014) (available at
     http://www.arianespace.com/news-press-release/2014/5-26-2014-VA218.asp).
15
     See Press Release, “Ariane Flight VA217: Ariane 5 ECA – ABS-2 – Athena Fidus: Launch postponed”
     (Jan. 6, 2014) (available at http://www.arianespace.com/news-press-release/2014/1-6-2014-VA217-
     launch-postponed.asp); Press Release, “Ariane Flight VA216: Ariane 5 ECA – Astra 5B – Amazonas
     4A launch postponed” (Feb. 14, 2014) (available at http://www.arianespace.com/news-press-
     release/2014/2-14-2014-VA216-launch-postponed.asp). In addition, Arianespace is committed to
     launch the Automated Transfer Vehicle to the International Space Station in late July – a launch
     window that cannot be moved and therefore will push the queue back still farther.


                                                    6


Proton launch failure on July 2, 2013 – the fourth launch anomaly for a Proton in two

years. 16 It resumed launch operations later in the year, but suffered another anomaly on

its most recent launch. 17 Moreover, the ILS launch manifest for 2014 and 2015 are

reportedly full. 18 Sea Launch suffered a launch failure in January 2013, and although the

investigation into the cause of that failure concluded in May 2013, 19 there were no

launches on that platform until late May 2014. 20 By contrast, Arianespace is planning a

record number of launches this year, and the Ariane 5 has proven to be a very reliable

platform. Accordingly, there simply is no better option for launching DIRECTV’s

satellite – and launching it quickly.

     C. Commission Precedent Supports Granting a Milestone Extension in These
        Circumstances

         The Commission imposes milestone deadlines for satellite system implementation

in order to ensure that licensees proceed with construction and launch of their satellites in

a timely manner and that valuable spectrum will not be held, to the exclusion of others,

by those who are unwilling or unable to proceed. 21 Extensions may be granted when the


16
     See “Fiery Proton Rocket Crash Leaves Commercial Customers in Limbo,” SPACENEWS (Jul. 8, 2013)
     (available at http://www.spacenews.com/article/launch-report/36142fiery-proton-rocket-crash-leaves-
     commercial-customers-in-limbo).
17
     See Press Release, “Russian State Commission Investigates Russian Federal Proton Launch Anomaly”
     (May 16, 2014) (available at http://www.ilslaunch.com/newsroom/news-releases/russian-state-
     commission-investigates-russian-federal-proton-launch-anomaly).
18
     See Peter B. de Selding, “ILS Rises Above Proton Problems,” SPACE NEWS (Jan. 13, 2014) (available
     at http://www.spacenews.com/article/launch-report/39071launch-satellite-contract-review-ils-rises-
     above-proton-problems).
19
     Press Release, “Sea Launch IS-27 FROB Report Complete” (Jun. 3, 2013) (available athttp://www.sea-
     launch.com/news/11365).
20
     Press Release, “Sea Launch Successfully Launches EUTELSAT 3B” (May 27, 2014) (available at
     http://www.sea-launch.com/news/11407).
21
     See, e.g., Amendment of the Commission’s Space Station Licensing Rules and Policies, 18 FCC Rcd.
     10760, ¶ 173 (2003); TerreStar Networks, Inc., 22 FCC Rcd. 17698, ¶ 6 (Int’l Bur. 2007)
     (“TerreStar”).


                                                    7


delay is due to unforeseeable circumstances beyond the applicant’s control, or when there

are unique and overriding public interest concerns that justify an extension. 22 In this

case, both factors clearly support grant of DIRECTV’s milestone extension request.

           First, “the Commission has considered the extent of a satellite’s construction and

the amounts paid toward to the total contract price as factors in milestone extension

cases.” 23 Thus, for example, the Commission granted a five-month extension to allow

ICO to achieve completion and launch of its satellite. 24 Similarly, it granted TerreStar a

ten-month extension where its satellite was in the final stages of construction and almost

completely paid for, and it had a firm launch contract under which substantial payments

had also been made. 25 In this case, DIRECTV will soon complete construction of its

satellite, and has paid approximately 91.4% of the pre-launch construction payments and

90% of the launch services contract related to it.

           Thus, DIRECTV would have been in a position to launch as early as October –

less than three months beyond the applicable milestone date. Unfortunately, however,

under the most recent estimate, an Ariane 5 launch window for DIRECTV 15 does not

open until approximately February/March 2015. There are no alternatives that would

achieve a more expedited launch. These are precisely the sort of circumstances in which

the Commission has found extension to be justified and appropriate. 26



22
     See 47 C.F.R. § 25.117(e). See also TerreStar, ¶ 6; New ICO Satellite Services G.P., 22 FCC Rcd.
     2229, ¶ 14 (Int’l Bur. 2007) (“New ICO”).
23
     New ICO Satellite Services G.P., 22 FCC Rcd. 2229, ¶ 15 (Int’l Bur. 2007).
24
     Id.
25
     See TerreStar, ¶ 7 and n.15 (discussing factors and citing other cases in which similar commitment
     justified milestone extension).
26
     See, e.g., R/L DBS Co. LLC, 18 FCC Rcd. 7694, ¶¶ 14-15, 17 (Int’l Bur. 2003) (granting a five-month
     launch milestone extension based on, among other things, the unavailability of a launch vehicle due to
     delay in delivery of a spacecraft scheduled for an earlier launch and issues with the launch vehicle

                                                     8


          Second, even were this not the case, DIRECTV’s demonstrated commitment to

construction and launch of this 17/24 GHz BSS payload presents the unique and

overriding public interest grounds that are an independent basis for granting a milestone

extension. The launch of the DIRECTV RB-2 payload will mark the culmination of an

effort that DIRECTV began over 15 years ago. Its long-time commitment will finally

bear fruit with the launch of the first 17/24 GHz BSS payload capable of providing

commercial service. This additional capacity is coming online just in time to support the

launch of bandwidth-intensive ultra-high definition television (“Ultra HD”) services,

which promise a leap forward for video programming similar to that achieved with the

introduction of high definition service. 27 DIRECTV has invested years of effort and

hundreds of millions of dollars to get to this point. No one is more anxious to launch this

satellite than is DIRECTV.

          The Commission has found similar circumstances to justify extension of the

launch and operate milestone in prior cases. For example, in TerreStar, the Commission

found overriding public interest considerations that justified a ten-month extension.

There, as here, delivery of the satellite was delayed due to problems associated with the

delivery of critical parts. 28 The Commission nonetheless found that the licensee had

demonstrated a substantial and continuing commitment to satellite construction and

system implementation. 29 In that case, satellite construction was 84% complete, and the



     itself); Geostar Positioning Corp., 6 FCC Rcd. 2276, ¶ 4 (CCB 1991) (milestone extensions of one to
     one-and-a-half years granted based on revisions to launch provider’s revised manifest).
27
     Ultra HD is an umbrella term that describes two different resolutions: 4K Ultra HD and 8K Ultra HD.
     4K Ultra HD has a resolution of 3,840 x 2,160 pixels, which is four times the number of pixels as
     HDTV, while 8K Ultra HD has a resolution of 7,680 × 4,320 pixels, or sixteen times the number of
     pixels as HDTV.
28
     TerreStar, ¶ 9.
29
     Id., ¶¶ 7, 10.

                                                    9


licensee had paid 97% of the total amount due under the satellite construction contract

price and 70% of the total amount due under the launch services contract. The

Commission also noted that grant of the extension would serve the public interest

because it would allow a licensee “that has demonstrated diligence and commitment . . .

to expeditiously complete implementation of a satellite system with advanced capabilities

for homeland security, rural connectivity, and other critical communications purposes.” 30

          For similar reasons, granting a nine-month extension would be appropriate here. 31

Like TerreStar, DIRECTV has worked diligently and invested significantly in its satellite

system, which will be one of the first capable of providing commercial service in the

17/24 GHz BSS band. DIRECTV has firm arrangements in place for launch of the

satellite within the period of the extension requested herein. It has requested a period

somewhat beyond that launch window in order to accommodate the time necessary for

in-orbit testing and arrival of the satellite on station at its assigned orbital location. Such

an extension is clearly justified in the circumstances presented here.

     D. In the Alternative, the Commission Should Waive the Final Milestone

          Pursuant to Section 1.3 of the Commission’s rules, the Commission may waive its

rules for good cause shown. 32 “Waiver is appropriate if special circumstances warrant a

deviation from the general rule and such deviation would better serve the public interest

than would strict adherence to the general rule,” including “more effective

implementation of overall policy.” 33 In determining whether waiver is appropriate, the



30
     Id., ¶ 10.
31
     See 47 C.F.R. § 25.117(e) (applicant must justify length of requested extension).
32
     47 C.F.R. § 1.3. See also WAIT Radio v. FCC, 418 F.2d 1153 (D.C. Cir. 1969), cert. denied, 409 U.S.
     1027 (1972); Northeast Cellular Telephone Co., LP v. FCC, 897 F.2d 1164 (D.C. Cir. 1990).
33
     GE American Communications, Inc., 16 FCC Rcd. 11038, ¶ 9 (Int’l Bur. 2001).

                                                     10


Commission should “take into account considerations of hardship, equity, or more

effective implementation of overall policy.” 34

         As explained above, the evidence that the satellite will be complete and ready for

launch months before its launch vehicle will be available demonstrates good cause for a

waiver in this case. DIRECTV could neither foresee nor control the cause of the

construction delays and compounding launch unavailability, and a waiver would not

undermine the purpose of the milestone requirements, as it would not result in, facilitate,

or encourage spectrum warehousing. 35 Moreover, grant of the requested waiver would

promote the expeditious use of the undeveloped 17/24 GHz BSS spectrum band, and

enable DIRECTV to provide Ultra HD programming and other video services to millions

of subscribers across the nation.

                          *                           *                          *

         For the foregoing reasons, DIRECTV respectfully requests that the Commission

grant a nine-month extension, up to and including April 27, 2015, to meet its “launch and

begin operations” milestone for DIRECTV RB-2. In the alternative, it requests that the

Commission waive that milestone for good cause shown.


                                             Respectfully submitted,

                                             DIRECTV ENTERPRISES, LLC



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



34
     WAIT Radio, 418 F.2d at 1159.
35
     See, e.g., EchoStar Satellite Corp., 18 FCC Rcd. 15875, ¶ 9 (Int’l Bur. 2003); Astrolink Int’l LLC, 17
     FCC Rcd. 11267, ¶ 6 (Int’l Bur. 2002).


                                                     11


                                        DECLARATION

       I, Philip J. Goswitz, hereby make the following declaration under penalty of perjury. I

understand that this Declaration will be submitted to the Federal Communications Commission.

   1. I am Senior Vice President, Video, Space, and Communications at DIRECTV.

   2. I have reviewed the foregoing Application for Milestone Extension or Waiver, and certify

       that the facts set forth therein are true and correct to the best of my knowledge.



                                             __/s/______________________________
                                             Philip J. Goswitz
                                             Senior Vice President,
                                              Video, Space, and Communications
                                             DIRECTV Enterprises, LLC

Executed: June 24, 2014


ATTACHMENT A


Airbus Defence and Space, 31 rue des Cosmonautes, 31402 Toulouse Cedex 4




 Gaëtan Martin                                                             DIRECTV
 T +33 5 62 19 60 44                                                       2260 E. Imperial Hwy.,
 F +33 5 62 19 74 85
                                                                           El Segundo, CA 90245
 E gaetan.martin@astrium.eads.net
                                                                           United States of America
 Our ref: 2014/ATC/066
                                                                           To the attention of Mr. Brian Regan
                    th
 Toulouse, 12 June 2014                                                    Vice President & Deputy General Counsel


 Subject: DIRECTV 15 Satellite

 Dear Mr Regan,


 We are pleased to give you the latest status of progress for the DIRECTV-15 Satellite Program as per
 June 2014.
 a)     The DIRECTV 15 satellite has now reached a very advanced construction stage, and it is
        currently in final steps of Spacecraft test at Airbus Defence and Space facilities in Toulouse
        before being shipped to launch site. The main steps that have been successfully completed this
        year are (refer to associated pictures):
                   Satellite assembly in February 2014
                   Satellite thermal vacuum test completed on 24th April 2014
                   Satellite mechanical & dynamic test successfully completed on 6th June 2014
        DIRECTV 15 satellite is starting the final functional & performances tests before shipment.
 b)     Our contract awarded by DIRECTV in October 2011 remains in full force, and to date 91.4% of all
        payments due and owing on the satellite construction contract have been paid by DIRECTV
        (excluding in-orbit incentives).
 c)     The current satellite schedule is on track and the projected on ground delivery date is 14th
        September before shipment to the launch site in Kourou (French Guyana) for a launch by the
        Ariane 5 launcher.
 We hope that the above information responds to your expectation and remain at your disposal.
 Yours sincerely.




 Gaëtan Martin
 Commercial & Contract Manager
 Telecommunications Satellites


 www airbusdefenceandspace.com                                             Astrium SAS
                                                                           Société par actions simplifiée (393 341 516 R.C.S. Nanterre)
                                                                           au capital de 16 587 728 €
                                                                           Siège social : 12 rue Pasteur - 92150 SURESNES - FRANCE
                                                                           TVA : FR 63 393 341 516 - APE : 3030Z


                                   ANNEX 1

           DIRECTV 15 Spacecraft pictures at different stage of build




DIRECTV 15 satellite under Mechanical Dynamic Test: Completed on 6th June 2014


DIRECTV 15 satellite under thermal vacuum test: Completed on 24th April 2014




         DIRECTV 15 satellite Assembly performed in February 2014




     DIRECTV 15 Antenna Subsystem test: Completed in December 2013


ATTACHMENT B


                                                             service & solutions

     Direction Commerciale



                                                                           Attn. Mr. Brian REGAN
                                                                           Associate General Counsel
                                                                           DIRECTV OPERATIONS, Inc
                                                                           2230 East Imperial Hwy
                                                                           El Segundo
                                                                           California 90245
                                                                           USA

                                                                           Evry—Courcouronnes, 18 June 2014
                                                                           Ref.: DC/SC/CBA/VPR/L14—118 Issue 2



     VIA ELECTRONIC MAIL ONLY


     Subject:                DIRECTV—14 and 15 Launch Services Agreements Status



     Dear Mr. Regan,

     This purpose of this letter is to confirm that the Launch Services Agreement (Contract
     DC/V/RDA/VSH/C11—009 signed on September 09‘", 2011) for DIRECTV—14 and
     DIRECTV—15 is in full force and effect. Current manifest objectives foresee a launch of
     DIRECTV—14 before the end of 2014 and DIRECTV—15 is expected to be launched
     during the first quarter of 2015.

     I also want to confirm that, to date, DIRECTV has paid 90 % of the launch services
     price for DIRECTV—14 and 90 % of the launch services price for DIRECTV—15.

     Do not hesitate to contact me if you have further questions.

     With my best regards,




                                                                                                                    7



                                                                                       Christophe BARDOU
                                                                             Program Director for DIRECTV—14



     Copies:
     DIRECTV                      P. Goswitz, J. Seto, C. Ho.
    Arianespace                   W. Kernisan, M. Callari, F. Desnoues, C. Bardou, R. Darde.

                                                            www.arianespace.com
                             S.A. au capital de 372 069,01 € — RCS Evry B 318 516 457 — Siren 318 516 457 — APE 5122 Z
                                     Boulevard de I‘Europe ~ B.P. 177 — 91006 Evry—Courcouronnes cedex — France

             Evry                          Kourou                  Washington DC                     Tokyo                     Singapore
TéI : +33 (0)1 60 87 60 00        Tél : +594 594 33 67 07      Tél : +1 202 628 3936        Tél : +813 3592 2766         Tél : +65 6223 6426
Fax : +33 (0)1 60 87 62 17        Fax : +594 594 33 62 66      Fax : +1 202 628 3949        Fax : +81 3 3592 2768        Fax : +65 6223 4268



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Document Modified: 2019-04-13 07:08:49

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