Attachment Narrative

This document pretains to SAT-STA-20141118-00122 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2014111800122_1069349

H WG HARRIS, WILTSHIRE & GRANNIS ur November 18, 2014 BY ELECTRONIC FILING Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth Street, S.W. Washington, DC 20554 Re: Requestfor Special Temporary Authorityfor In—Orbit Testing of DIRECTV 14 and DIRECTVY RB—1 at 76° W.L. Dear Ms. Dortch: DIRECTV Enterprises, LLC ("DIRECTV") hereby requests Special Temporary Authority ("STA") to locate the DIRECTV 14 satellite (call sign $2869) along with the DIRECTV RB—1 payload (call sign $2711) at the 76° W.L. orbital location for in—orbit testing ("IOT") after launch of the satellite, which is currently scheduled for December 4, 2014. This STA will cover a period of approximately 30 days within a 60 day window, which DIRECTV requests be keyed to become effective upon the satellite‘s arrival at 76° W.L. DIRECTV 14 is currently at the launch site being readied for launch. DIRECTV desires to conduct IOT for approximately four weeks before moving the satellite to its licensed position to begin commercial operations. Specifically, DIRECTV contemplates the following schedule [with approximate dates indicated in brackets]: _ After launch and orbit raising maneuvers, DIRECTV 14 will be located at 76° W.L. [no earlier than about December 14, 2014]. «_ After DIRECTV 14 reaches 76° W.L., DIRECTV will then commence IOT of the satellite for approximately 4 weeks.‘ °_ After IOT is completed, DIRECTV 14 will then be drifted to its assigned location at 99° W.L. (nominal) over the course of approximately 23 days [reaching that orbital position on or about February 5, 2015]. \ During the period covered by this STA, DIRECTV will use 28351.0 and 28353.0 MHzfor its command uplinks and 18799.0 and 18799.5 MHz for its telemetry downlinks. 1919 M STREETNW | EIGHTH FLOOR | WASHINGTON, DC 20036 | TEL 202 730 1300 | FAX 202 730 1301 [ HWGLAW.COM

HARRIS, WILTSHIRE & GRANNIS LLP Marlene H. Dortch November 18, 2014 Page 2 of 3 In order to address the timing uncertainties normally associated with positioning a spacecraft after launch, DIRECTV requests that the STA become effective upon the arrival of DIRECTV 14 at 76° W.L. Operation and testmg ofDIRECTV 14 and DIRECTV RB—1 during IOT will consist of performance venficatlon testlng of all transponders and antenna pattern verification testing of all antennabeaims. ‘During this testing, unmodulated CW carriers will be used to generate swept frequency response and gain transfer characteristics of each transponder The maximumvalueof transmit power used durmg this testing will be consistent with the DIRECTV14 and DIRECTV RB—1 applications," except for short periods of time during gain transfer when the maximum transmit power for DIRECTV 14 could exceed that value by up to 10 dB during some tests." This testing will not result in harmful interference to other Ka—band satellite systems as the closest co—frequency operational satellite is located 9° away. Nor will this testing result in harmful interference to any DBS satellite system as the closest co—frequency operational DBS satellite is located 1° away and, as demonstrated in the measured transmit antenna gain submission for DIRECTV RB—1, the 17/24 GHz BSS payload on DIRECTV 14 will not exceed the —1 17 dBW/m*/100kHz PFD coordination trigger beyond 0.12°.4 DIRECTV will also coordinate its TT&C operations with all other potentially affected operators to ensure that no harmful interference results. Furthermore, DIRECTV is prepared to terminate all testing operations immediately upon notification from the Commission that its operations cause harmful interference to any authorized user of the spectrum. Grant of this STA request will serve the public interest by allowing DIRECTV to test the DIRECTV 14/RB—1 satellite to ensure that it is fully operational and ready to begin providing service to millions of DIRECTV subscribers from the satellite‘s licensed orbital location. Allowing DIRECTV to test the satellite at 76° W.L. will serve the public interest by minimizing the risk of interference. 2 See IBFS File Nos. SAT—LOA—20120518—00085 (DIRECTV 14) and SAT—LOA—20060908— 00099, SAT—MOD—20110727—00135, SAT—MOD—20111128—00230 (DIRECTV RB—1). > Note that, as with IOT testing of DIRECTV 10, 11 and 12, all DIRECTV 14 IOT testing will be closely coordinated with U.S. government systems under FN US334. * See IBFS File No. SAT—MOD—20141103—00119.

HARRIS, WILTSHIRE & GRANNIS LLP Marlene H. Dortch November 18, 2014 Page 3 of 3 Accordingly, and in light of the impending launch date, DIRECTV requests the expeditious grant of special temporary authority. Respectfully submitted, William M. Wiltshire Counsel to DIRECTY Enterprises, LLC


Document Created: 2019-04-13 23:44:27
Document Modified: 2019-04-13 23:44:27
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