Attachment letter

letter

LETTER submitted by Telesat Canada

letter

2005-11-01

This document pretains to SAT-STA-20051018-00201 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2005101800201_473817

Wiley Rein & Fielding ur rEeceIvED wov 1 9 205 arrex siseer e November 10, 2005 bominuntcatons conniate® Jenifer D. Hindin 200.709.4005 msseton, oe rooe mou imzizos rotun en eermnny Jindngurt.com o maune wigu rtce Ms. Marlene H. Dortch risanes sewr oave Secretary sure c Federal Communications Commission more massane 445 12th Street, SW mc mamane Washington, DC 20554 Re: DIRECTV Enterprises, LLC ("DIRECTV"), Request for Special monntcon Temporary Authority ("STA®)to Relocate DIRECTV 2 to 91° W.L. and to Conduct Telemetry, Tracking and Command Operations for an Interim Period, File No. SAT—STA—20051018—00201 Dear Ms. Dortch: Telesat Canada (*Telesat"),by it attomeys, respectfully requests that the Federal Communications Commission ("Commission") place the above—referenced item on public notice as soon as practicable and grant it as promptly as possible thereafter." On October 18, 2005, DIRBCTV requested STA to relocate the DIRECTV 2 satellte to the Canadian 91° W.L. Broadcast Satellte Service ("BSS") orbital location.* Under an arrangement between DIRECTV and Telesat, and subject to U.S. and Canadian regulatory approval, Telesat will use DIRECTV 2 to support BSS service into Canada." As enumerated below, important public interest considerations support prompt processing of DIRECTV‘s STA request. In fact, due to the pressing nature of these considerations, Telesat hopes to have DIRECTV 2 operational at 91° W.L. by Junuary 1, 206. * To theextent necessry, Telesat respectfillyrequests eave to fl hisupplemental informaton. * See DIRECTV Emerpises, LLC, RequestforSpecial Temporary Authorityto Relocate DIRECTV 2 t91° W.L. and to Condact Telemety, Tracking and Command Opertionsfor an Interim Period, ie No. SAT—STA—2008 1018—00201 (Rled Oce18, 2005)(‘DIRECTY2 S7A Request) 9. DIRBCTV 3 is curenty codocated with Telesa‘s Nimig 1 satlite at 91° WL; Nimig2 is locatedat82° WIL. See ApplictionofDIRECTV, Inc, Order, 19 FCC Red 11.055 CBur.2008) (CDIRECTV 3 Order®). IfDIRECTV receives therequisie approvals, DIRECTV 3 willbe maved to §2° W.L. and codocated with Nimig 2. DIRECTV 2 willbe co—locted with Nimig 1 t 91° W.L Par of h reasonfor not moving DIRECTV 2 diectlyto 82° W.L relaes o DIRECTV 2‘s shon remaining fol i

WileyRein & Ficlding us Ms. Marlene H. Dortch November 10, 2005 Page 2 First, Telesat needs expedited access to DIRECTYV 2 to address an increasing capacity shortage. As previously recognized by the Commission, supporting cooperation between U.. and Canadian satellite operators in meeting capacity needs is an important public policy goal." Telesat‘s urgent capacity needs stem from a partial power failure on its Nimig 2 satellite that has resulted in reduction in the number of functioning transponders." Currently, Nimig 2 only has 25 operational transponders and will continue to lose additional transponders each year due to power constraints. The prime power stuation is particularly critical during eclipse seasons, when additional power is required for battery charging. The 2006 vermal eclipse begins in February. Second, acting quickly on DIRECTV‘s STA request will ensure that valuable resources are used in an efficient manner. DIRECTV 2 was launched in 1994 and it is estimated that it will reach its end of fuel life at 91° W.L. in the frst half of 2007. Placing DIRECTV‘s STA request on public notice and granting it prompily will ensure that this valuable resource provides service for as much of is short remaining life as possible. Third, by commencing the comment period as soon as possible, the Commission will help provide improved services to Canadian BSS customers in timely manner. The additional capacity provided by DIRECTV 2 will help Telesat‘s fleet of BSS satelltes offer additional services including high—definition programming, while at the same time ensuring adequate backup for the degrading Nimiq 2. Fourth, expedited treatment of DIRECTV‘s STA request, including grant by stamp following the public notice period, would be appropriate because this tem does not present any new or novel regulatory issues. This STA request is virtually identical to the one the Commission granted last year authorizing the relocation of DIRECTV 5. See DIRECTV 3 Order see also Leverof Nov.7, 1972, from Mr. Bert W. Rein (US. Department of State o the Honorable Keneth B. Wiliams (Miniser, Embasty ofCanade, Washingion D.C). * See DIRBCTV 3 Onter, 19 FCC Red at 11,086 (13). A moredetailed discusion of "Telesa‘ Nimig 2 powerancmaly can befound in pror Teesatfligs. See eg. DIRECTV, Inc. Request for Special Temporary Authoriy to Relocte DIRECTV 3 to 82° W.L.an to Conduct Telemetn, Trackin, and Command (‘TTAC‘) Operations fr a Inerim Period, SAT—STA— 2002090—00300, OppostionofTlesarCanada (iled Nov. 12, 2003)

Wiley Rein & Fielding us Ms. Marlene H. Dortch November 10, 2005 Page 3 3 to the Canadian 82° W.L. orbitallocation for the provision of BSS into Canada." In fact, quick processing of this STA request would be commensurate with the public policies motivating the Commission‘s adoption of its fleet management processing procedures." Those procedures allow U.S. operators to relocate a satellie between U.S—licensed orbital locations upon 30 days prior notice to the Commission. While this STA request does not qualify for fleet management treatment because the 91° W.. BSS orbitallocation is notlicensed by the United States, it will not result in disruption of service to any customers and otherwise satisfes the Flee: Management Order requirements. Therefore, Telesat would greatly appreciate swift action in response to this STA request. Placing it on public notice and taking action by grant—stamp would help ensure that Telesat has adequate capacity to serve Canadian BSS consumers, minimizethe effects of Nimig 2‘s power degradation, and maximize the limited remaining uscfulness of DIRECTV 2. Should you have any questions about this filing, please contact the undersigned counsel for Telesat. Thank you. Sincerely, %@,b s Jenaifer D. Hindin ces Andrea Kelly, IB Robert Nelson, TB Scott Kotler, IB William Wikishire, Counsel for DIRECTV * Conpare DIRECTV3 Order with DIRECTV2 STA Request See Anendment ofthe Commission‘s Space Suation Licensing Rules andPolces, Sccond Reportand Order, 18 RCC Red 12.507(el June 20,2003)(*Flees Management Order®). Seeals, acr® prs se 50 See47 CER §25.1180.


Document Created: 2005-12-30 11:54:10
Document Modified: 2005-12-30 11:54:10
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