Attachment Narrative

This document pretains to SAT-STA-20190531-00043 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2019053100043_1711487

EXHIBIT 1 REQUEST FOR SPECIAL TEMPORARY AUTHORITY DIRECTV Enterprises, LLC (“DIRECTV”) respectfully requests a grant of special temporary authority (“STA”)1 for 60 days commencing June 17, 2019 to drift its T10 satellite (Call Sign S2641) from its current location at 102.85 W.L. to 102.75 W.L. and to operate the telemetry, tracking, and command (“TT&C”) and communications frequencies on the T10 satellite at 102.75 W.L. and during the drift from 102.85 W.L. to 102.75 W.L. DIRECTV plans to file a space station modification application to permanently change the authorized orbital location of T10 from 102.85 W.L. to 102.75 W.L. T10 is permanently authorized to operate at 102.85 W.L.2 DIRECTV’s T15 satellite (Call Sign S2930) is permanently authorized to operate at 102.75 W.L.3 but is currently operating at 100.85 W.L. pursuant to a grant of special temporary authority.4 DIRECTV is implementing certain changes to its existing satellite fleet in connection with the upcoming launch of DIRECTV’s T16 satellite (Call Sign S3039), which is currently scheduled for June 20, 2019. DIRECTV plans to relocate T10 from 102.85 W.L. to 102.75 W.L. as early as June 17, 2019, and the drift period is expected to last approximately 30 days. As noted above, DIRECTV plans to file a space station modification application to permanently change the authorized orbital location of T10 from 102.85 W.L. to 102.75 W.L. DIRECTV also plans to file a 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 Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01080, File No. SAT-MOD- 20150320-00012 (May 1, 2015). 3 See Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01086, File No. SAT-LOA- 20140825-00094 (May 22, 2015); Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01084, File No. SAT-MOD-20140612-00066 (May 15, 2015). T15’s 17/24 GHz BSS band payload was originally authorized under Call Sign S2712, which was consolidated with Call Sign S2930 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. 1

separate space station modification application to permanently change the authorized orbital location of T15 from 102.75 W.L. to 102.85 W.L. At 102.75 W.L. and during the drift from 102.85 W.L. to 102.75 W.L., DIRECTV will continue to operate the TT&C and communications frequencies on the T10 satellite in conformance with FCC rules and DIRECTV’s coordination agreements concerning the nominal 103 W.L. orbital location. As such, grant of this STA will not result in increased risk of harmful interference. In the unlikely event that any interference should occur during the drift, DIRECTV will take all reasonable steps to eliminate such interference. T10’s frequencies are as follows: TT&C  18300.25 MHz and 18300.75 MHz (space-to-Earth).  29251.0 MHz and 29493.0 MHz (Earth-to-space). Communications  18.3-18.8 GHz (space-to-Earth).  28.35-28.6 GHz and 29.25-29.5 GHz (Earth-to-space). 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. Apart from DIRECTV’s T12 satellite (Call Sign S2797),5 which DIRECTV will manage internally to ensure safe station-keeping, T10 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. As noted above, although DIRECTV’s T15 satellite is permanently authorized 5 T12 is permanently authorized to operate at 102.8 W.L. See Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-01084, File Nos. SAT-MOD-20150320-00013 & SAT-MOD-20150327-00015 (May 15, 2015). T12’s 17/24 GHz BSS band payload was originally authorized under Call Sign S2796, which was consolidated with Call Sign S2797 in September 2017. 2

to operate at 102.75 W.L., T15 is currently operating at 100.85 W.L. pursuant to a grant of special temporary authority, and DIRECTV plans to file a modification application to permanently relocate T15 to 102.85 W.L. Additionally, although DIRECTV’s T16 satellite 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.6 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 T10 at 102.75 W.L. DIRECTV is also not aware of any other system with an overlapping station-keeping volume with T10 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 facilitate DIRECTV’s fleet management operations in connection with the launch of DIRECTV’s T16 satellite, which will extend coverage, improve service performance, and provide additional capacity to DIRECTV customers. Accordingly, DIRECTV respectfully requests that the Commission grant this request. 6 See Modification Application to Change T16 Orbital Location (S3039), File No. SAT-MOD-20190508-00036. DIRECTV was also recently granted special temporary authority to conduct in-orbit testing for T16 at 134.75° W.L. and to drift the satellite to 100.85° W.L. See STA Request for T16 (Call Sign S3039) to Conduct IOT at 134.75° W.L., File No. SAT-STA-20190508-00037 (stamp grant May 29, 2019). 3


Document Created: 2019-05-31 16:11:05
Document Modified: 2019-05-31 16:11:05
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