Attachment Narrative

This document pretains to SAT-STA-20190521-00040 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2019052100040_1690789

EXHIBIT 1 REQUEST FOR SPECIAL TEMPORARY AUTHORITY DIRECTV Enterprises, LLC (“DIRECTV”) respectfully requests an extension of its grant of special temporary authority (“STA”)1 for an additional 180 days commencing May 27, 2019 to operate its T8 satellite (Call Sign S2632) at the 100.75 W.L. orbital location. Pursuant to Section 1.62 of the Commission’s rules, DIRECTV will continue to operate T8 at 100.75 W.L. pursuant to the terms and conditions of its existing STA pending action on this timely filed renewal request.2 T8 is permanently licensed to operate at 100.85 W.L.3 DIRECTV has temporarily relocated and is currently operating its T15 satellite (Call Sign S2930) at the 100.85 W.L. orbital location pursuant to a grant of special temporary authority.4 DIRECTV has relocated T15 to 100.85 W.L. to fill a temporary business need for additional Ku-band DBS (12.2-12.7 GHz (space-to-Earth) and 17.3-17.8 GHz (Earth-to-space)) capacity at the nominal 101 W.L. orbital location. On September 27, 2018, the Commission granted DIRECTV’s 30-day request for special temporary authority commencing October 2, 2018 to drift T8 from 100.85 W.L. to 100.75 W.L. and to operate the satellite at 100.75 W.L.5 On November 28, 2018, the Commission granted 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 See 47 C.F.R. § 1.62. 3 See Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01088, File No. SAT-MOD- 20150304-00009 (May 29, 2015); Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-00431, File Nos. SAT-AMD-20070111-00010, SAT-MOD-20061213-00151 (Mar. 30, 2007). T8’s Ka-band payload was originally authorized under Call Sign S2132, which was consolidated with Call Sign S2632 in September 2017. 4 See Satellite Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01358, File No. SAT- STA-20180830-00064 (Nov. 2, 2018); see also 180-Day STA Extension Request to Operate T15 (Call Sign S2930) at 101 WL, File No. SAT-STA-20190416-00028. 5 See 30-Day STA Request to Relocate T8 (Call Sign S2632), File No. SAT-STA-20180921-00074 (granted Sept. 27, 2018). 1

DIRECTV’s 180-day STA request to continue operating T8 at 100.75 W.L. until the satellite returns to its permanently licensed orbital location.6 The drift began on October 3, 2018 and was completed on October 10, 2018. As DIRECTV anticipates a continuing business need to continue operating T15 at the 100.85 W.L. orbital location, DIRECTV respectfully submits this STA extension request to continue operating T8 at 100.75 W.L. for an additional 180-day period beginning May 27, 2019 until the satellite returns to its permanently authorized orbital location.7 While T8 is located at 100.75 W.L., DIRECTV will provide telemetry, tracking, and control (“TT&C”) using the following frequencies:  17307.00 MHz (Earth-to-space); and  12203.25 MHz and 12203.75 MHz (space-to-Earth). Grant of this STA will not result in increased risk of harmful interference. Once on station at 100.75 W.L., DIRECTV will operate the communications payload in conformance with FCC rules and any relevant coordination agreements. DIRECTV has assessed and limited the probability of the space station becoming a source of debris as a result of collisions with large debris or other operational space stations. T8 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. 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 T8 at 100.75 W.L. DIRECTV is also not 6 See Satellite Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01361, File No. SAT- STA-20180928-00077 (Nov. 30, 2018). 7 DIRECTV currently anticipates returning T8 to the 100.85 W.L. orbital location in 2019 based on business needs. 2

aware of any other system with an overlapping station-keeping volume with T8 that is the subject of an ITU filing that is either in orbit or progressing towards launch. Grant of this STA request will serve the public interest because it will extend coverage, improve service performance, and provide additional capacity to customers at the nominal 101 W.L. orbital location. Accordingly, DIRECTV respectfully requests that the Commission grant this request. 3


Document Created: 2019-05-21 11:44:43
Document Modified: 2019-05-21 11:44:43
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