Attachment grant

grant

DECISION submitted by IB,FCC

grant

2007-04-16

This document pretains to SAT-STA-20070409-00060 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2007040900060_560830

                                                                                                             Approved by OMB
                                                                                                                    3060—0678


Date & Time Filed: Apr 9 2007 2:56:04:063PM
File Number: SAT—STA—20070409—00060
Callsign:                                                                     desceR OTY—2
                                         FEDERAL COMMUNICATIONS COMMISSION
                              APPLICATION FOR SPACE STATION SPECIAL TEMPORARY AUTHORITY

                                                      FOR OFFICIAL USE ONLY


  APPLICANT INFORMATION
Enter a description ofthis application to identify it on the main menu:
 STA — D2 — de=—orbit @ 91 WL
1. Applicant

            Name:        DIRECTV Enterprises, LLC          Phone Number:        310—726—4993
            DBA Name:                                      Fax Number:          310—535—5323
            Street:      2230 E. Imperial Hwy              E—Mail:              dapattillo@directv.com


            City:        El Segundo                        State:               CA
            Country:      USA                              Zipcode:             90245         —
            Attention:   Dave Pattillo




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                                                                                     Call Sign ________ Grant Date_8 pa\\G,1007
                                                                                     (or other identifier)
                                                                                                             Term Dates
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2. Contact


             Name:         William M. Wiltshire                  Phone Number:                        202—730—1350
             Company:      Harris, Wiltshire & Grannis, LLP__    Fax Number:                          202—730—1301


             Street:         1200 18th Street, NW                E—Mail:                              wwiltshire@harriswiltshire.com



             City:         Washington                            State:                               DC
             Country:        USA                                 Zipcode:                             20036 *    —

             Attention:    William M. Wiltshire                  Relationship:                        Legal Counsel


   (If your application is related to an application filed with the Commission, enter either the file number or the IB Submission ID of the related
application. Please enter only one.)
   3. Reference File Number or Submission ID
 4a. Is a fee submitted with this application?
@ If Yes, complete and attach FCC Form 159.         If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
£y Governmental Entity         g*y Noncommercial educational licensee
£74 Other(please explain):

4b. Fee Classification    —CRY — Space Station (Geostationary)
5. Type Request


 C   Change Station Location                        O   Extend Expiration Date                       @   Other



6. Temporary Orbit Location                                                 7. Requested Extended Expiration Date


8. Description   (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.)
     See Exhibit A.




9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject @ Yes               {‘_‘)No
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 "party to the application" for these purposes.


10. Name of Person Signing                                                   11. Title of Person Signing
James Butterworth                                                           Senior Vice President

12. Please supply any need attachments.
 Attachment 1: Exhibit A                            Attachment 2:                                      Attachment 3:



          WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                 (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                  (U.S. Code, Title 47, Section 312(a)(1)), 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. If you
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 jboley@fece.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 sponsorthis collection, unless it displays a currently valid OMB control number orif we fail to provide you with this notice. This
collection has been assigned an OMB 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.


                   REQUEST FOR SPECIAL TEMPORARY AUTHORITY


            DIRECTV Enterprises, LLC ("DIRECTV") requests special temporary authority

     ("STA"), beginning on May 1, 2007 and lasting for a period of up to thirty (30) days, in

 order to (1) de—orbit its DIRECTV 2 satellite from its current location at the Broadcasting

     Satellite Service ("BSS") slot allocated to Canada at 91° W.L. in the ITU Region 2 BSS

 Plan, and (2) perform telemetry, tracking and command ("TT&C") functions with

 DIRECTV 2 during this maneuver.

            Under an arrangement with Telesat Canada ("Telesat"), this satellite has been

 used by Telesat to support BSS service into Canada under a license issued by the

 Canadian government. The satellite has now reached the end of its useful life, and will

 soon be replaced by the DIRECTV 1 satellite.‘

            DIRECTV intends to de—orbit DIRECTV 2 to a location consistent with both the

 guidelines established by the Inter—Agency Space Debris Coordination Committee

 (“IADC”)2 and the Commission‘s requirements for geostationary space stations operating

 at U.S.—licensed locations under authorizations issued after March 2002.° The formula

 used by both the IADC and the Commission for this purpose is:

                                      36,021 km + (1000*Cg;*A/m)

 where Cz is the solar pressure radiation coefficient of the spacecraft, and A/m is the Area

 to mass ratio, in square meters per kilogram, of the spacecraft. The relevant values for

 the DIRECTV 2 satellite are:

 ‘      The Commission has authorized DIRECTV to relocate DIRECTV 1 to the 91° W.L. orbital location,
        where it will replace DIRECTV 2. See File No. SAT—STA—20070126—00019 (granted March 8, 2007).
ho




        See Mitigation of Orbital Debris, 19 FCC Red. 11567, $ 65 (2004).

 3      47 C.FR. § 25.283.


                     Cr =0.5589
                     A = 63.9 m
                     m = 1251 kg

    Plugging these values into the equation yields the following results:

                       36,021 km + (1000°0.5589*(63.9/1251)) = 36,049.55 km

    Since geostationary altitude is generally considered to be 35,786 km," this yields a

    desired disposal orbit of at least 263.6 km above the geostationary arc. DIRECTV

    intends to boost DIRECTV 2 to at least this height, and in fact will target a height of

    approximately 300 km above geostationary altitude.

            Grant of the requested STA will not present any significant risk of interference to

    other satellites. During the relocation of DIRECTV 2, the satellite‘s communications

payload will remain inactive and only the TT&C payload will operate. DIRECTV

requests authority to operate on the following TT&C frequencies: 17303.0 MHz and

    17797.0 MHz (uplink) and 12201.0 and 12202.25 MHz (downlink). DIRECTV will

coordinate with potentially affected satellite operators in accordance with industry

practice, and will operate on a non—interference basis. Upon completion of de—orbit

maneuvers, DIRECTV will ensure that all stored energy sources on board DIRECTV 2

are discharged by venting excess propellant, discharging batteries, relieving pressure

vessels, and other appropriate measures.

           For the foregoing reasons, DIRECTV urges the Commission to grant the

requested STA as expeditiously as possible.




*      Orbital Debris Mitigation, "| 65.


WVUT$                                                                        1200 EIGHTEENTH STREET, NW
                                                                            WASHINGTON, DC 20036

W".TSH'RE    &                                                              TEL 202.730.1300   FAX 202.730.1301
                                                                            WWW.HARRISWILTSHIRE.COM

ELt                                                                         ATTORNEYS AT LAW




                                           April 12, 2007



    BY HAND DELIVERY

    Andrea Kelly
   Chief, Policy Branch
   Satellite Division
   International Bureau
   Federal Communications Commission
   445 Twelfth Street, S.W.
   Washington, DC 20554

           Re:     FCC File No. SAT—STA—20070409—00060

   Dear Ms. Kelly:

           In the above referenced proceeding, DIRECTV Enterprises, LLC ("DIRECTV")
   has requested Special Temporary Authority ("STA") to de—orbit the DIRECTV 2 satellite
   from the nominal 91° W.L. orbital location. After discussing the methodology for
   calculating the value for C; used in the guideline formula established by the Inter—
   Agency Space Debris Coordination Committee ("IADC""), DIRECTV has concluded that
   a value of 1.2 would be more appropriate for purposes of this application. Accordingly,
   the IADC equation for DIRECTV 2 as revised yields the following results:

                     36,021 km + (1000*1.2*(63.9/1251)) = 36,082.294 km
   Since geostationary altitude is generally considered to be 35,786 km, this yields a desired
   disposal orbit of at least 296.3 km above the geostationary arc. As stated in its
   application, DIRECTVintends to boost DIRECTV 2 to a target height of approximately
   300 km above geostationary altitude, which should be more than sufficient to satisfy this
   guideline.‘




   ‘   In addition, the figure used for the surface area of the satellite is a worst—case value,
       based on an unrealistically conservative assumption that the solar panels and
       reflectors will always be facing directly toward the sun.


HARRIS, WILTSHIRE & GRANNIS LLP

Andrea Kelly
April 12, 2007
Page 2 of 2

       If you have any questions, please do not hesitate to contact me.

                                             Respectfully submitted,


                                              W/ith»bitets 4y ,
                                             William M. Wiltshire
                                             Counsel to DIRECTY Enterprises, LLC


co:    Sankar Persuad



Document Created: 2007-04-16 16:14:08
Document Modified: 2007-04-16 16:14:08

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