Attachment submission

submission

REQUEST submitted by DIRECTV

submission

2007-04-12

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

IBFS_SATSTA2007040900060_561173

HARRIS, 1200 EGHTEENTH STREET, NW WASHINGTON, DC 20036 WILTSHIRE & Tel 202.730.1300 rax 202.730.1301 WWW.HARRISWILTSHIRE.COM G RAN N lS U-P ATTORNEYS AT LAW April 12, 2007 RECEIVED — FCC 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 Cz 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, DIRECTV intends 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, Pougas } 1 , Lj/f//{/%\ W %’ 4 , M William M. Wiltshire Counsel to DIRECTY Enterprises, LLC ce: Sankar Persuad


Document Created: 2007-04-19 12:05:55
Document Modified: 2007-04-19 12:05:55
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