Attachment Narrative

This document pretains to SAT-STA-20190508-00037 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2019050800037_1677748

                                  EXHIBIT 1
                  REQUEST FOR SPECIAL TEMPORARY AUTHORITY

        DIRECTV Enterprises, LLC (“DIRECTV”) respectfully requests a grant of space station

special temporary authority (“STA”)1 for 30 days to conduct in-orbit testing (“IOT”) of the T16

satellite (Call Sign S3039) at 134.75° W.L. and to drift the satellite to its requested permanent

location of 100.85° W.L.2 DIRECTV requests that this special temporary authority commence

upon arrival of T16 at 134.75° W.L., which is currently anticipated to be on or about June 29,

2019—nine days after the satellite’s scheduled launch on June 20, 2019. The IOT period is

expected to last approximately three weeks, and the drift to 100.85° W.L. is expected to last

approximately seven weeks.3

        DIRECTV separately and simultaneously is requesting earth station special temporary

authority to operate its Los Angeles, California earth station (Call Sign E980285) and two Castle

Rock, Colorado earth stations (Call Signs E930304 and E070027) to support IOT of the T16

satellite.

        T16 payload testing will be performed in the following frequency bands:

FSS Ka-band

       18.3-18.55 GHz, 18.55-18.59 GHz, and 19.7-20.2 GHz (space-to-Earth); and

       28.35-28.6 GHz, 29.25-29.29 GHz, and 29.5-30.0 GHz (Earth-to-space).


1
  DIRECTV has filed this STA request, an FCC Form 159, and a $980.00 filing fee
electronically via the International Bureau’s Filing System.
2
 Although T16 is currently authorized to operate at 102.70° W.L., DIRECTV has filed a
modification application to change T16’s authorized orbital location from 102.70° W.L. to
100.85° W.L. See Modification Application to Change T16 Orbital Location (S3039), File No.
SAT-MOD-20190508-00036.
3
  During the drift from 134.75° W.L. to 100.85° W.L., only the satellite’s TT&C frequencies will
be utilized. DIRECTV intends to file STA extension requests to cover any testing or drift period
that exceeds 30 days from T16’s arrival at 134.75° W.L.

                                                 1


BSS 17/24 GHz band

      17.3-17.7 GHz (space-to-Earth); and

      24.75-25.15 GHz (Earth-to-space).

DBS Ku-band

      12.2-12.7 GHz (space-to-Earth); and

      17.3-17.8 GHz (Earth-to-space).

       Telemetry, Tracking, and Command (“TT&C”) services for T16 will be performed using

the following center frequencies:

      12697 MHz and 12698 MHz (space-to-Earth); and

      17789 MHz and 17791 MHz (Earth-to-space).

       During the IOT of T16, DIRECTV will operate in the above-referenced frequency bands.

DIRECTV has identified the operational satellites within +/-6 degrees of the requested IOT

location of 134.75° W.L. Coordination has been completed with the operators of such satellites

to resolve potential interference issues. In the unlikely event that harmful interference occurs

during IOT, contact information has been shared with these operators, and DIRECTV will take

all necessary steps to eliminate the interference.

       DIRECTV has assessed and limited the probability of T16 becoming a source of debris as

a result of collision with large debris or other operational space stations during IOT at 134.75°

W.L. T16 will not be located at the same orbital location as another satellite or at an orbital

location that has an overlapping station-keeping volume with another satellite. Further,

DIRECTV is not aware of any other FCC-licensed system, or any other system applied for and

under consideration by the FCC, having an overlapping station-keeping volume with T16 at

134.75° W.L. In addition, DIRECTV is not aware of any system with an overlapping station-


                                                     2


keeping volume with T16 at 134.75° W.L. that is the subject of an International

Telecommunication Union (“ITU”) filing and that is either in orbit or progressing towards

launch.

          To the extent necessary, DIRECTV requests that any waivers granted to T16 at its

nominal operational orbital positions be extended to the satellite at 134.75° W.L.

          The IOT of T16’s payloads at 134.75° W.L. is a critical step in ensuring that the satellite

will be fully operational. This, in turn, will provide additional capacity to customers at the

satellite’s nominal operational orbital positions, thereby promoting the public interest.

Accordingly, DIRECTV respectfully requests that the Commission grant this request.




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Document Created: 2019-05-08 16:02:49
Document Modified: 2019-05-08 16:02:49

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