D12 STA Supplemental

LETTER submitted by DIRECTV Enterprises, LLC

Supplemental Information Letter

2009-12-03

This document pretains to SAT-STA-20091201-00132 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2009120100132_784910

December 3, 2009 BY ELECTRONIC FILING Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth Street, S.W. Washington, DC 20554 Re: IBFS File No. SAT-STA-20091201-00132 (S2797) Dear Ms. Dortch: DIRECTV Enterprises, LLC (“DIRECTV”) hereby submits additional information of the above referenced request for special temporary authority (“STA”) to conduct in-orbit testing (“IOT”) of the DIRECTV 12 satellite scheduled to be launched later this month. As discussed in the STA request, IOT of the spacecraft will involve the use of unmodulated CW carriers operated at transmit powers generally consistent with the DIRECTV 12 application, except for short periods of time during gain transfer measurements for spot transponders when the maximum transmit power could exceed that value by up to 7 dB. As a result, during those short periods of maximum power, DIRECTV 12 would exceed the power flux-density (“PFD”) limit in Section 25.208(c) of the Commission’s rules for the 18.3-18.8 GHz band by up to 9 dB. 1 Nonetheless, for the reasons discussed below, DIRECTV submits that the requested STA will not cause harmful interference to any co-primary user of the band. The DIRECTV 12 operations in the relevant band consist of multiple spot beams supporting satellite channels in the 18.58-18.8 GHz frequency range. During IOT, each beam will be successively positioned over DIRECTV’s broadcast center located in Castle Rock, Colorado (“CRBC”). The transmit power of each beam will be increased with the transponder in linear (as opposed to automatic level control) mode in order to achieve full saturation. The spot beams will only exceed the PFD limit in Section 25.208(c) for a period of 10-15 seconds at the peak of each such test, and the frequencies used will vary as different beams are tested. Thus, over the course of four weeks of IOT, any one frequency will be subject to additional PFD during a minimal number of episodes and for a minimal amount of time in each episode. A representative view of a spot beam positioned over CRBC is shown below, including antenna gain contours out to the -10 dB contour (at which point the 9 dB exceedance of the applicable PFD level at beam peak would be completely eliminated). As can be seen in this 1 At no time during IOT will DIRECTV 12 exceed the PFD limits established in Section 25.208(d). 1200 18TH STREET, NW | SUITE 1200 | WASHINGTON, DC 20036 | TEL 202-730-1300 | FAX 202-730-1301 | WILTSHIREGRANNIS.COM

WILTSHIRE & GRANNIS LLP Marlene H. Dortch December 3, 2009 Page 2 of 3 diagram, the potentially affected area includes most of Colorado and Wyoming as well as northern New Mexico. In order to determine the impact of IOT operations in the potentially affected area, DIRECTV accessed the Commission’s Universal Licensing System (“ULS”) to determine what terrestrial operators might also be authorized to operate in the 18.58-18.8 GHz band in Colorado, Wyoming, and New Mexico. As specified in Section 101.97 of the Commission’s rules, any such system that was the subject of a license extension after June 8, 2000 is authorized on a secondary basis to FSS systems. As shown on the attached spreadsheet, of the 43 terrestrial systems identified by ULS as operating in this band in the target states, only three are operating pursuant to licenses that were not extended after June 8, 2000. Accordingly, the vast majority of these licensees operate on a secondary basis in the band. One of the three remaining licenses (WNEF866) appears to have expired without renewal. Another (WNTD994) is centered at 18.625 GHz with a bandwidth of 10 MHz, which places these operations essentially entirely in a guard band between two DIRECTV 12 transponders. The third (WNTD993) is centered at 18.655 GHz with a bandwidth of 6.3 MHz, which places these operations 7 MHz off the center of a DIRECTV 12 transponder. Because this license includes a single 6.3 MHz emission designator, and because all DIRECTV 12 testing will occur at transponder center frequencies, the CW signal used for testing this transponder during DIRECTV 12 IOT would fall approximately 4 MHz out of band – which should be more than sufficient for the out-of-band signal rejection capabilities of the terrestrial system to attenuate the DIRECTV 12 signal sufficiently to avoid interference.

WILTSHIRE & GRANNIS LLP Marlene H. Dortch December 3, 2009 Page 3 of 3 Accordingly, DIRECTV submits that, even though the IOT operations of DIRECTV 12 will exceed the PFD limits in Section 25.208(c) for a limited number of very short-term events, grant of the requested STA will not result in harmful interference to any co-primary user of the 18.3-18.8 GHz band. 2 In addition, DIRECTV would like to take this opportunity to provide 24/7 contact information in case any issue arises in connection with the operations of DIRECTV 12 under the requested STA. The direct number at DIRECTV’s CRBC facility is 720-733-7290,where someone should be on duty at all times during IOT. If you have any questions, please do not hesitate to contact me. Respectfully submitted, /s/ William M. Wiltshire Counsel to DIRECTV Enterprises, LLC cc: Andrea Kelly Kathyrn Medley 2 To the extent the Commission concludes that a waiver of the PFD limit in Section 25.208(c) is required in connection with this STA request, DIRECTV submits that the public interest would be served by the grant of such a waiver for the reasons stated herein, and requests that such a waiver be granted.

ULS Terrestrial Licenses in the 18.58-18.8 GHz Band Wyoming License Call sign activity Date WGW709 Renewal 12/5/2000 WLV863 Renewal 1/17/2001 WLW555 Renewal 1/17/2001 Colorado License Call sign activity Date KAH90 Renewal 9/6/2000 KBC20 Renewal 4/2/2008 KBD28 Renewal 9/6/2000 KCM97 Renewal 4/2/2008 KFD63 Renewal 7/4/2000 KHT45 Renewal 4/2/2008 KXR22 Renewal 1/9/2001 WLC746 Renewal 3/13/2001 WLL206 Renewal 3/13/2001 WLM388 Renewal 2/27/2001 WLS557 Renewal 1/23/2002 WLT597 Renewal 3/13/2001 WLT687 Renewal 9/6/2000 WLT830 Renewal 3/13/2001 WLT958 Renewal 3/13/2001 WLU342 Renewal 3/13/2001 WLU957 Renewal 9/6/2000 WLV331 Renewal 3/13/2001 WLV735 Renewal 3/15/2001 WML462 Renewal 2/27/2001 WMQ382 Renewal 1/17/2001 WMR770 Renewal 9/6/2000 WMS986 Renewal 9/6/2000 WNEV873 Renewal 4/2/2008 WNEW980 Renewal 1/30/2009 WNTD904 Renewal 9/22/2009 WNTD993 Renewal 5/31/2000 WNTD994 Renewal 5/31/2000 WNTH275 Renewal 4/2/2008 WNTH382 Renewal 9/27/2000

WNTK920 Renewal 8/10/2001 WNTK921 Renewal 11/4/2008 WNTQ394 Renewal 9/25/2002 WPJC735 Renewal 9/6/2000 WQBJ319 Issued 10/19/2004 New Mexico License Call sign activity Date KLX60 Renewal 12/22/2000 KOE33 Renewal 1/6/2001 WMK343 Renewal 2/27/2001 WNEF886 Expired* 9/17/1999 WPOT561 Renewal 2/27/2009


Document Created: 2009-12-03 15:41:04
Document Modified: 2009-12-03 15:41:04
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