Attachment D8 Extension Request

This document pretains to SAT-MOD-20150304-00009 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2015030400009_1078120

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ____________________________________ ) Application of ) ) DIRECTV ENTERPRISES, LLC ) Call Sign: S2632 ) For Modification of the ) File No. ____________________ DIRECTV-8 Authorization to ) Extend the License Term ) ____________________________________) APPLICATION FOR MODIFICATION DIRECTV Enterprises, LLC (“DIRECTV”) hereby applies for a ten-year extension, through June 23, 2025, of the license for its DIRECTV-8 spacecraft, call sign S2632. 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-8, 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-8.1 1 See IBFS File No. SAT-RPL-20040630-00127. 1

MODIFICATION REQUEST DIRECTV-8 was launched in May 2005and began operations at the nominal 101° W.L. orbital location soon thereafter. The satellite is a hyrbrid, authorized to operate in both the Ka- band2 and on 16 odd-numbered channels (1-31) in the DBS frequency bands (12.2-12.7 GHz downlink and 17.3-17.8 GHz uplink). 3 Under the terms of its authorization and of Section 25.121(a)(2) of the Commission’s rules, the DBS payload on this satellite has a license term of 10 years from the date DIRECTV certified the satellite had been successfully placed into orbit.4 Accordingly, the license will expire on June 23, 2015. By this application, DIRECTV respectfully requests that the term be extended by ten years. Such an extension is warranted under the circumstances. DIRECTV-8 went into operation in June 2005, and was designed for an operational and mission life of at least 12 years.5 The satellite carried a generous fuel supply. Moreover, because it was launched on a Proton rocket, it was inserted into orbit in a way that required the use of very little fuel for orbit- raising maneuvers. Based on the amount of fuel remaining for continued operations at the nominal 101° 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 through approximately February 2034. At this point, however, DIRECTV only seeks an extension through a portion of that period, and 2 See Grant Stamp, IBFS File No. SAT-MOD-20040630-00128 (Nov. 4, 2004). The Ka-band portion of the satellite has a license term of 15 years, and so is authorized through June 23, 2020. See id., Condition 15; 47 C.F.R. § 25.121(a)(1). 3 See Grant Stamp, IBFS File No. SAT-RPL-20040630-00127 (Nov. 4, 2004) (“D8 Authorization”). 4 See D8 Authorization, ¶ 7; 47 C.F.R. § 25.121(a)(2). 5 See IBFS File No. SAT-RPL-20040630-00127, Application at 22 (June 30, 2004). 2

reserves the right to seek a further extension if the satellite is still performing as expected at the end of the first extension period. As a result, extending the license term of DIRECTV-8 will serve the public interest by allowing DIRECTV to continue to use the spacecraft to provide a high-quality video service offering to U.S. consumers, ensuring the efficient use of satellite and orbital resources while promoting competition in the MVPD market. Schedule S. The proposed modification of the DIRECTV-8 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.6 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. 6 See, e.g., Grant Stamp, IBFS File Nos. SAT-MOD-20140127-00010 (Apr. 24, 2014) (DIRECTV request for extension of DIRECTV-7S satellite license); SAT-MOD-20111102-00211 (Jan. 18, 2012) (DIRECTV request for extension of DIRECTV-4S satellite license); SAT-MOD-20110718-00130 (Oct. 13, 2011) (SES Americom request for extension of AMC-1 satellite license); SAT-MOD- 20090217-00024 (May 5, 2009) (XM Radio request for extension of XM-1 satellite license). 3

CONCLUSION For the foregoing reasons, DIRECTV respectfully requests that the Commission modify the license for DIRECTV-8 to extend its term through June 23, 2025. Respectfully submitted, By: ____/s/________________________ William M. Wiltshire Romulo Pontual Michael Nilsson Executive Vice President and HARRIS, WILTSHIRE & GRANNIS LLP Chief Technology Officer 1919 M Street, NW DIRECTV ENTERPRISES, LLC Suite 800 2230 E. Imperial Highway Washington, DC 20036 El Segundo, CA 90245 (202) 730-1300 (310) 964-5000 Counsel for DIRECTV Enterprises, LLC 4


Document Created: 2019-04-13 23:08:30
Document Modified: 2019-04-13 23:08:30
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