Attachment 2003DIRECTV- april 2

2003DIRECTV- april 2

LETTER submitted by DIRECTV

f

2003-04-24

This document pretains to SAT-STA-20020910-00172 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2002091000172_825387

Apr=24—2003 08 :12am From— T=587 P.0027/002 F—297 RECEIVED Thomas Tycz Chief, Satellite Division APR 2 4 2003 Intemational Butreau Federal Communication Commission ons commseon D I R,E reperat communicatiT C TT V 445 12"" Street, SW OFFICE OF THE SECRETARY eCe’v Washington, DC 20554 APR 3 q 2003 Re: File Nos. SAT—STA—20020910—00172 m Policy B Dear Mr. Tycz: ’memationag‘;:fi:aU As you know, pursuant to a grant of Special Temporary Authority in September 2002, DIRECTV moved its DIRECTV 3 satellite out of geostationary orbit into a storage orbit. DIRECTV has pending a minor modification application to reflect this change to its DBS system. The primary réeason that DIRECTV sought FCC consent to move DIRECTV 3 was the failure of the main spacecraft control processor {"SCP") on that satellite. The satellits remains fully capabie of DBS operation due to the presence of a backup SCP, although DIRECTV decided it prudent to move the satellite out of the 101 degree W.L. orbira) location since it was only needed as a backup at the time, DIRECTV stands by this business decision. However, DIRECTV wishes to clatify for the record its view that the Commission should not over—emphasize concerns regarding a lack of SCP redundancy to the point where fully operational satellites, in which hundreds of millions of dollars have been invested, are effectively rendered useless for reasons unrelated to the actual capabilities of the satellite. For example, DIRECTV 3 remains an important source of emergency backup capacity, which DIRECTV (and, presumably, the Commission) would want to see urilized in the event of a catastrophic faiture of one of its in—orbit satellites. Furthermore, we and the manufacturer of the satellites suffering SCP failures, believe that the risk of failure caused by "tin whiskers" decreases after a period of time since munufacture or launch, a point that DIRECTV3 has passed. In fact, there are other satellites with a lack of SCP redundancy currently operating in the geostationary are whose capacity is vital to meeting existing service needs,. The public interest is, nonetheless, furthered by the operation of these spacecraft. We therefore do not wish to suggest that an SCP failure should preciude valuable uses of operational satellites that can serve and enhance the public inlerest. Thank you for your consideration and the opportunity to clarify DIRECTYV‘s views on this point. Veré truly yours, % James Butterworth * Senior Vice President PDIRECTV, Inc. % gg: James H. Barker, Esq. 2230 East lmperlal Hwy. E1 §¢gundo, CA 90245 P hone $ 10 545 5000 A HvaniEes COMPANY


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Document Modified: 2019-04-22 21:31:00
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