Attachment DIRECTV - Grant Augu

DIRECTV - Grant Augu

DECISION submitted by IB, FCC

GRANT

2019-08-14

This document pretains to SAT-MOD-20190625-00051 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2019062500051_1849523

S2930 SAT-MOD-20190625-00051 1B2019002523 DIRECTV Enterprises, LLC I. ~ ~ ‘~ ‘~ E’~ ~ ~ t’~ ~ Ti 5 Call Sign ~ ~ ~3C) GrantDatc O8~ J44 19 (orotheridentifier) ~ . ~ Approved by 0MB Terni Date l 3060—0678 GRANTED~ From ô~/i4/i~ To: c~/zs a Date & Time Filed: Jun 25 2019 2:36:02:926PM Internal ional Bureau Approved: ~ // File Number: SAT—MOD—201906250005 I ~w’rth ~ii~a~s ~ ~ Sct1eiIt~ ~ 8~nch FCC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AMD MAIN FORM FCC Use Only FCC 312 MAIN FORM FOR OFFICIAL USE ONLY APPLICANT INFORMATION Enter a description of this application to identify it on the main menu: Modification Application to Change TI 5 Orbital Location (Call Sign S2930) 1 8. Legal Name of Applicant Name: DIRECTV Enterprises, LLC Phone Number: 310 964 4996 DBA Fax Number: Name: Street: 1 1 20 20th Street, NW E—Mail: spdulac a attcorn Suite 1000 City: Washington State: DC Country: USA Zipcode: 20036 Attention: Steve Dulac

ATTACHMENT TO GRANT DIRECTV Enterprises, LLC IBFS File No. SAT-MOD-20 190625-00051 IBFS File No(s): SAT-MOD-20190625-00051 GRANTED — Licensee/Grantee: DIRECTV Enterprises, LLC (DIRECTV) With Conditions Call Sign: S2930 Satellite Name: T15 (formerly DIRECTV 15 & RB-2)1 Orbital Location: 102.85° Wi. (required station- (± 0.025 degrees) keeping tolerance) Administration: United States of America International Bureau Nature of Service: Fixed-Satellite Service (FSS), 17/24 GHz Broadcast Satellite Division Satellite Service (BSS) ~ Scope of Grant: Authority to specify operations at the 102.85° W.L orbital location instead of the previously authorized orbital location of 102.75° W.L.; to provide FSS service and 17/24 GHz BSS service at 102.85° W.L.; and to conduct TT&C necessary to drift T15 to 102.85° W.L. Previous Grants: Grant of a 30-day extension of the launch and begin operations milestone applicable to DIRECTV RB-2. See IBFS File No. SAT-MOD-20150722-00052 (granted Sept. 2, 2015) Authority to operate DIRECTV 15 at 102.75° W.L. to provide FSS, including direct-to- home services. See IBFS File Nos. SAT-LOA-20140825-00094 & SAT-AMD-20150407- 000 18 (granted May 20, 2015) Modification of the license for DIRECTV RB-2, in order to conform the parameters of its authorization with the satellite as constructed and to permit operations at the 102.75° W.L orbital location, instead of the currently authorized orbital location of 102.825° W.L. See IBFS File No. SAT-MOD-20140612-00066 (granted May 14, 2015) Extension of milestone to launch and commence operations for DIRECTV RB-2. See IBFS File No. SAT-MOD-20140624-00075, DA 15-589 (lB 2015) Modification of the license for DIRECTV RB-2 to demonstrate compliance with the technical rules and information requirements adopted in the 17/24 GHz BSS Second Report and Order, FCC 11-93, 26 FCC Rcd 8927 (2011). SAT-MOD-20140612-00067 (granted Nov. 20. 2014) Modification of the license for DIRECTV RB-2 at 102.825° W.L. to demonstrate compliance with the technical rules and information requirements adopted in FCC 11-93, 26 FCC Rcd 8927 (2011). See 1BPS File Nos. SAT-MOD-201 11128-00229 & SAT-AMD 201203 14-00041 (granted May 24, 2012) Modification of license for DIRECTV RB-2 to expand the coverage area to include Puerto Rico. See IBFS File No. SAT-MOD-201 10727-00 136 (granted Oct. 26, 2011) Authority to launch and operate DIRECTV RB-2 in the 17/24 GHz Broadcasting Satellites Service at 102.825° W.L. See 1BPS File No. SAT-LOA-20060908-00100, SAT-AMD 20080 1 14-000 14 & SAT-AMD-20080321-00077, 24 FCC Rcd 9393 (113 2009), pet. for ___________________ recon. denied. Service Area(s): CONUS, Alaska, Hawaii, Puerto Rico ‘The RB-2 payload on DIRECTV 15 was originally authorized and operated under Call Sign S2712, but in September 2017 itwas consolidated into Call Sign S2930 (the Call Sign assigned to DIRECTV 15). Page 1 of 3

ATTACHMENT TO GRANT DIRECTV Enterprises, LLC IBFS File No. SAT-MOD-20190625-0005 1 Frequencies: 17/24 0Hz BSS 17.3-17.7 0Hz (space-to-Earth) 24.75-25.15 GHz (Earth-to-space) FSS2 18.3-18.59 0Hz (space-to-Earth) 19.7-20.2 GHz (space-to-Earth) 28.35-28.6 GHz (Earth-to-space) 29.25-29.29 0Hz (Earth-to-space) 29.5-30.0 GHz (Earth-to-space) Telemetry, Tracking, and Command 20.1985 0Hz and 20.1995 0Hz (space-to-Earth) 29.5025 0Hz and 29.5059 0Hz (Earth-to-space) Unless otherwise specified herein, operations under this grant must comport with the legal and technical specifications set forth by the applicant or petitioner and with Federal Communication Commission’s rules not waived herein. This grant is also subject to the following conditions: 1. DIRECTV must continue to operate the T15 space station at the 102.85° W.L. orbital location subject to the conditions in prior grants.3 2. DIRECTV must maintain the T15 space station at the 101.2° W.L. orbital location with an east/west longitudinal station-keeping tolerance of ± 0.05 degrees. 3. Operations during the drift to 102.85° W.L. must be on an unprotected and non-harmful interference basis, i.e. the T15 space station must not cause harmful interference to, and DIRECTV must not claim protection from interference caused to it by, any other lawfully operating station. In the event of any harmful interference, DIRECTV must cease operations immediately upon notification of such interference, and must inform the Commission, in writing, immediately of such an event. 4. DIRECTV must coordinate the operations of T15 during the drift to 102.85° W.L. with existing geostationary space stations to ensure that no unacceptable interference results from its operations 5. DIRECTV must file with the Commission the information required by section 25.172 of the Commission’s rules, 47 CFR § 25.172. 6. Nothing in this grant changes the license term for the T15 space station (Call Sign S2930), which expires on August 25, 2030. Licensee/grantee is afforded thirty (30) days from the date of release of this action to decline the grant as conditioned. Failure to respond within this period will constitute formal acceptance of the grant as conditioned. This action is taken pursuant to Section 0.26 1 of the Commission’s rules on delegated authority, 47 C.F.R. § 0.261, and is effective upon release. Station licenses are subject to the conditions specified in Section 309(h) of the Communications Act of 1934, as amended, 47 U.S.C. § 309(h). 2Tl5 is authorized to use the 18.3-18.59 GHz (space-to-Earth) and 28.35-28.6 GHz, 29.25-29.29 (Earth-to-space) frequency bands, but these frequencies will be used for backhaul rather than direct provision of service to subscribers. ~ See Previous Grants Page 2 of 3

ATTACHMENT TO GRANT DIRECTV Enterprises, LLC IBFS File No. SAT-MOD-20190625-00051 Action August 14, 2019 Date: Term Dates From: August 14, 2019 To: August 25, 2030 Approved: 44~/L~sll Stephen J. all Chief, Satellite Policy Branch Page 3 of 3

9—16. Name of ~.ontact Representative Name: Jennifer D. Hindin Phone Number: 202—719—4975 Company: Wiley Rein LLP Fax Number: 202—719—7049 Street: 1776 K Street, NW E—Mail: jhindin~~~vileyrein.com City: Washington State: DC Country: USA Zipcode: 20006— Attention: Relationship: Legal Counsel CLASSIFICATION OF FILING 17. Choose the button next to the classification that applies to this filing for (N/A) bI. Application for License of New Station both questions a. and b. Choose only one (N/A) h2. Application for Registration of New Domestic Receive—Only Station for I 7a and only one for 1 7h. 0 b3. Amendment to a Pending Application • h4. Modification of License or Registration 0 al. Earth Station h5. Assignment of License or Registration . . • a2. Space Station b6. Transfer of Control of License or Registration o b7. Notification of Minor Modification (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed Satellite (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States (N/A) blO. Other (Please specify) (N/A) bi I. Application for Earth Station to Access a Non—U.S.satellite Not Currently Authorized to Provide the Proposed Service in the Proposed Frequencies in the United States (N/A) bi 2. Application for Database Entry O b13. Amendment to a Pending Database Entry Application 0 h14. Modification of Database Entry

17c. isa fee submitted with this application? o If Yes, complete and attach FCC Form 159. If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1 114). 0 Governmental Entity ~ Noncommercial educational licensee o Other(please explain): I 7d. Fee Classification BFY — Space Station Modification(Geostationary) 18. If this filing is in reference to an 19. If this filing is an amendment to a pending application enter both fields, if this tiling is a existing station, enter: modification please enter only the file number: (a) Call sign of station: (a) Date pending application was filed: (b) File number: S2930 SATLOA2O 14082500094

TYPE OF SERVICE 20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply: a. Fixed Satellite Q b. Mobile Satellite Q c. Radiodetermination Satellite d. Earth Exploration Satellite e. Direct to Home Fixed Satellite Q f Digital Audio Radio Service g. Other (please specify) 1 7/24 GHz Broadcasting—Satellite Service 21. STATUS: Choose the button next to the applicable status. Choose 22. If earth station applicant, check all that apply. only one. Q Using U.S. licensed satellites 0 Common Carrier Non—Common Carrier Q Using Non—U.S. licensed satellites 23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these facilities: o Connected to a Public Switched Network Not connected to a Public Switched Network N/A 24. FREQUENCY BAND(S): Place an ~)(~ in the box(es) next to all applicable frequency band(s). Q a. C—Band (4/6 GHz) Q h. Ku—Band (12/14 GHz) c.Other (Please specify upper and lower frequencies in MHz.) Frequency Lower: 1 7300 Frequency Upper: 30000 (Please specify’ additional frequencies in an attachment)

TYPE OF STATION 25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one. o a. Fixed Earth Station o b. Temporary—Fixed Earth Station o c. o d. Mobile Earth Station e. Geostationary Space Station 0 ~ Non—Geostationary Space Station o g. Other (please specify) 26. TYPE OF EARTH STATION FACILITY: otForTransmit/Receive ~ Transmit—Only Space Station applications, select N/A.” ~ Receive—Only ® N/A

PURPOSE OF MODIFICATION 27. The purpose of this proposed modification is to: (Place an ‘X’ in the box(es) next to all that apply.) Q a authorization to add new emission designator and related service —— Q b authorization to change emission designator and related service —— Q c authorization to increase EIRP and EIRP density —— Q d authorization to replace antenna —— Q e authorization to add antenna —— Q f—— authorization to relocate fixed station Q g authorization to change frequencv(ies) Q h authorization to add frequency —— Q i authorization to add Points of Communication (satellites & countries) —— Qi —— authorization to change Points of Communication (satellites & countries) Q k ——authorization for facilities for which environmental assessment and radiation hazard reporting is required —— authorization to change orbit location Qm —— authorization to perform fleet management EJ n — authorization to extend milestones Qo —— Other (Please specify)

ENVIRONMENTAL POLICY 28. Would a Commission grant of any proposal in this application or amendment have a significant environmental o Yes No impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of the Commission’s rules. 47 C.F.R. 1.1308 and 1.1311, as an exhibittothis application.A Radiation Hazard Study must accompany all applications for new transmitting facilities, major modifications, or major amendments. ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast. common carrier, aeronautical en route or aeronautical fixed radio station services are not required to respond to Items 30—34. 29. Is the applicant a foreign government or the representative of any foreign government? 0 Yes No 30. Is the applicant an alien or the representative of an alien? 0 Yes No N/A 31. Is the applicant a corporation organized under the laws of any foreign government? 0 Yes No N/A 32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by o Yes 0 No N/A aliens or their representatives or by a foreign government or representative thereof or by any corporation organized under the laws of a foreign country?

33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than o Yes No N/A one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign government or representative thereof or by any corporation organized under the laws of a foreign country? 34. If any answer to questions 29. 30. 31. 32 and/or 33 is Yes, attach as an exhibit an identitkation of the aliens or foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote. BASIC QUALIFICATIONS 35. Does the Applicant request any waivers or exemptions from any of the Commission’s Rules? 0 Yes No If Yes. attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents. 36. Has the applicant or any party to this application or amendment had any FCC station authorization or license o Yes No revoked or had any application for an initial. modification or renewal of FCC station authorization, license. or construction permit denied by the Commission? If Yes. attach as an exhibit, an explination of circumstances.

37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling o Yes No the applicant ever been convicted of a felony by any state or federal court? If Yes, attach as an exhibit, an explination of circumstances. 38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant, o Yes No guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication, directly or indirectly, through control of manufacture or sale of radio apparatus. exclusive traffic arrangement or any other means or unfair methods of competition?lfYes, attach as an exhibit. an explanation of circumstances 39. Is the applicant, or any person directly or indirectly controlling the applicant. currently a party in any pending 0 Yes No matter referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the circumstances. 40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names. address. and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer’s voting stock and the percentages so held. In the case of fiduciary control, indicate the heneficiary(ies) or class of Question 40 beneficiaries. Also list the names and addresses of the officers and directors of the Filer.

41. By checking Yes. the undersigned certifies, that neither applicant nor any other party to the application is Yes No subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See 47 CFR 1.2002(b) for the meaning of &quot~party to the application&quot: for these purposes. 42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? If Yes, o Yes No answer 42b and attach an exhibit providing the information specitied in 47 C.F.R. 25.137. as appropriate. If No, proceed to question 43. 42b. What administration has licensed or is in the process of licensing the space station? If no license will he issued. what administration has coordinated or is in the process of coordinating the space station? 43. Description. (Summarize the nature of the application and the services to be provided). (If the complete description does not appear in this box. please go to the end of the form to view it in its entirety.) DIRECTV Enterprises, LLC seeks to modify its authorization for T15 (Call Sign S2930) to change the authorized orbital location from 102.75 WL to 102.85 WL. Narrative

43a. Geographic Service Rule Certification By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic coverage requirements specified in 47 C.F.R. Part 25. By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements. OC By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic coverage requirements specified in 47 C.F.R. Part 25 and will not comply with such requirements because it is not feasible as a technical matter to do so. or that, while technically feasible, such services would require so many compromises in satellite design and operation as to make it economically unreasonable. A narrative description and technical analysis demonstrating this claim are attached. CERTIFICATION The Applicant 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, and requests an authorization in accordance with this application. The applicant certifies that grant of this application would not cause the applicant to he in violation of the spectrum aggregation limit in 47 CFR Part 20. All statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application. The undersigned. individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.

44. Applicant is a (an): (Choose the button next to applicable response.) o Individual 0 Unincorporated Association O Partnership 0 Corporation Governmental Entity • Other (please specify) 45. Name of Person Signing V 46. Title of Person Signing Steve Dulac Director, Content Technology & Regulatory Policy ——> WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT (U.S. Code, Title I 8, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION (U.S. Code, Title 47, Section 31 2(a)( I )), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).

FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting for this collection of information is estimated to average 2 hours per response. including the time for reviewing instructions, searching existing data sources. gathering and maintaining the required data, and completing and reviewing the collection of information. lfyou have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the Federal Communications Commission. AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA~fcc.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS. Remember You are not required to respond to a collection of information sponsored by the Federal government, and the government may not — conduct or sponsor this collection. unless it displays a currently valid 0MB control number or if we fail to provide you with this notice. This collection has been assigned an 0MB control number of 3060—0678. THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104-13, OCTOBER 1, 1995, 44 U.S.C. SECTiON 3507.

Before the FEDERAL COMMUNICATIONS COMMISSiON Washington, DC 20554 ) In the Matter of ) ) IMRECTV ENTERPRISES, LLC ) File No. SAT-MOD_____________ ) Application to Modify Authorization for TI 5 ) (S2930) ) ____________________________________________________________________________________ ) APPLIcATiON OF DIRECTV ENTERPRISES, LLC TO MODIFY AUTHORIZATION FOR TIS (S2930) DIRECTV Enterprises, LLC (“D[RECTV”). pursuant to Section 25.117 of the rules of the Federal Communications Commission (“FCC” or “Commission”),1 hereby requests to modify its authorization for Tl5 (call sign S2930).2 Specifically, DIRECTV seeks authority to change the authorized orbital location of T15 from 102.75° W.L. to 102.85° W.L. In accordance with the Commission’s rules,3 this application is being filed electronically as an attachment to FCC Form 3 12. Because the satellite will be relocated just 0.10° from its currently authorized orbital location, the technical information on file with the Commission for TI 5 (including the technical information submitted on Schedule S) remains unchanged and is 147 C.F.R. § 25.117. 2 Policy Branch In/b rrnation; Actions Taken, Public Notice, Report No. SAT-0 1086, File No. SAT-LOA-20140825-00094 (May 22, 2015); Policy Branch Information; Actions Taken. Public Notice. Report No. SAT-01084. File No. SAT-MOD-20140612-00066 (May 15, 2015). ~ See 47 C.F.R. § 25.117(c).

incorporated by reference.4 To the extent necessary. DIRECTV requests that any previously granted technical waivers continue to apply to the operation ofTl5 at 102.85° W.L. 1. PROPOSED MODIFICATION AND PUBLIC iNTEREST SHOWING DIRECTV is implementing certain changes to its existing satellite fleet in connection with the recent launch of DIRECTV’s 116 satellite (Call Sign S3039) on .lune 20. 2019. T15 is a multi-band, multi-mission satellite designed to operate at any of DIRECT V’s currently licensed Ka-band, 17/24 GFIz BSS, or 12/17 GHz DBS orbital locations. At the nominal 103° W.L. orbital location, 115 operates in the 18.3-18.59/19.7-20.2 GHz (space-to-Earth) and 28.35- 28.6/29.25-29.29/29.5-30.0 GHz (Earth-to-space) Ka-band frequency bands and the 17.3-17.7 GHz (space-to-Earth) and 24.75-25.1 5 GHz (Earth-to-space) I 7/24 GHz BSS frequency bands.~ T15 is permanently authorized to operate at 102.75° W.L. but is currently operating at 100.85° W.L. pursuant to a grant of special temporary authority.6 By this modification application, DIRECTV seeks authority to permanently change the authorized orbital location ofTl5 from 102.75° W.L. to 102.85° W.L. DIRECTV’s 110 satellite (Call Sign S2641) is permanently authorized to operate at 102.85° W.L. but will be relocated to 102.75° W.L. pursuant to a grant ~ See LBFS File Nos. SAT-MOD-20150722-00052. SAT-LOA-20l40825-00094; SAT-MOD 20140612-00066, SAT-MOD-20 140624-00075, SAT-MOD-20 140612-00067, SAT-MOD- 20111128-00229, SAT-MOD-201 10727-00136, SAT-LOA-20060908-00 100. ~ See Policy Branch In/brmation; Actions Taken, Public Notice, Report No. SAT-0 1086, File No. SAT-LOA-20140825-00094 (May 22. 2015); Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01084, File No. SAT-MOI)-20l40612-00066 (May 15, 2015). T15~s 17/24 GHz BSS band payload was originally authorized under Call Sign S2712, which was consolidated with Call Sign S2930 in September 2017. 6 See Satellite Policy Branch Information: Actions Taken, Public Notice. Report No. SAT-0 1395, File No. SAT-STA-20 190416-00028 (June 7, 2019).

of special temporary authority issued by the Commission on June 6, 2019.~ DIRECTV is simultaneously filing a separate modification application to permanently change the authorized orbital location of T10 from 102.85° W.L. to 102.75° W.L. Upon receipt of Commission approval, l)1RECTV expects to begin drifting Ti 5 to 102.85° W.L. as early as September 16, 2019. The drift is expected to take approximately eight days. [)uring the drift period. DIRECTV will utilize only the satellites telemetry, tracking, and command (“TT&C~’) frequencies and will follow industry practices for coordinating TT&C transmission during the relocation process. T15’s specific TT&C frequencies are as follows: 29502.5 MI-Iz and 29505.9 MHz (Earth-to-space); and 20198.5 MHz and 20199.5 Ml-{z (space-to-Earth). Grant of this relocation request will not result in increased risk of harmful interference. As noted above, DIRECTV will operate only the above-listed TT&C frequencies during the drift and will coordinate T15~s TT&C transmissions with operators of satellites in the drift path. In the unlikely event that any interference should occur during the drift, D[RECTV will take all reasonable steps to eliminate such interference. DIRECTV will operate T15’s Ka-hand and 17/24 0Hz BSS communications payloads and TT&C frequencies at 102.85° W.L. in conformance with FCC rules and DIRECTVs coordination agreements concerning the nominal 103° W.L. orbital location. [)IRECTV will operate Ti 5 at 102.85° W.L. in accordance with all previously imposed FCC conditions. Grant of this application will serve the public interest because it will facilitate I)lRECTV~s fleet management operations in connection with the recent launch of DIRECTV’s ~ See Satellite Policy Branch Information: Actions Taken. Public Notice. Report 1~o. SAT-0 1395, File No. SAT-STA-20190531-00043 (June 7,2018).

Tl6 satellite, which will extend coverage, improve service performance, and provide additional capacity to DIRECTV customers. 11. MILESTONES AND BOND DIRECTV requests grant of this application without milestones or a bond because the Commission’s milestone and bond requirements do not apply to satellites that are already in- orbit and operating.8 iii. ITU COST RECOVERY DIRECTV is aware that processing fees are currently charged by the International Telecommunication Union (“lTU’~) for satellite filings and that Commission applicants are responsible for any and all fees charged by the ITU.9 DIRECTV is aware of and unconditionally accepts this requirement and responsibility to pay any ITU cost recovery fees associated with the ITU filings that the Commission makes on behalf of 1)IRECTV for the satellite relocation proposed in this application. ~ See, e.g., intelsat License LLC, Modification Application to Redeploy and Operate Intelsal 16 at 58.1° W.L., FileNO. SAT-MOD-20160201-00009. Condition No. 12 (stamp grant May 18, 2016) (“Because Intelsat 16 is already in-orbit and operating, grant of authority to operate [ntelsat 16 at 58.1° W.L. is not subject to milestone conditions and lntelsat is not required to post a bond. As such, waiver of Sections 25.164(a) and 25.165 of the Commission’s rules is not necessary.”). ~ See implementation of ITU Cost Recove~y Charges for Satellite Network Filings, Public Notice. 16 FCC Rcd 18732 (2001).

IV. CONCLUSION For the reasons set forth above, DIRECTV respectfully requests that the Commission grant this modification app! ication. Respectfully submitted. .I)IRECTV ENTERPRISES, LLC By :/s/ Steve Dulac Steve Dulac Director, Content Technology & Regulatory Policy Of Counsel: Jennifer D. Hindin Daniel P. Brooks WILEY REIN LLP 1 776 K Street, NW Washington, DC 20006 Tel: (202) 719-7000 Fax: (202) 719-7049 jh indin~wileyrein.com dbrooks~wileyrein.com June 25, 2019


Document Created: 2019-08-15 13:22:28
Document Modified: 2019-08-15 13:22:28
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