Attachment Narrative

This document pretains to SAT-STA-20190703-00055 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2019070300055_1771788

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 July 24, 2019 to drift its T9S satellite (Call Sign S2669) from its current location at 101.1 W.L. to 101.2 W.L. and to operate the satellite at 101.2 W.L. DIRECTV is simultaneously filing a space station modification application to permanently change the authorized orbital location of T9S from 101.1 W.L. to 101.2 W.L. T9S is permanently authorized to operate at 101.1 W.L.2 DIRECTV’s T4S satellite (Call Sign S2430) is permanently authorized to operate at 101.2 W.L.3 T4S is approaching the end of its operational life, and DIRECTV plans to deorbit the satellite later this year. In connection with the deorbiting of T4S, DIRECTV plans to relocate T9S to 101.2 W.L. and to transfer all traffic from T4S to T9S. DIRECTV plans to relocate T9S from 101.1 W.L. to 101.2 W.L. as early as July 24, 2019, and the drift period is expected to last approximately five days. Once relocated, T9S will initially be collocated with T4S for approximately six weeks while traffic is transferred from T4S to T9S, and T4S will then be deorbited. As noted above, DIRECTV is simultaneously filing a space station modification application to permanently change the authorized orbital location of T9S from 101.1 W.L. to 101.2 W.L. 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-01226, File No. SAT-MOD-20161219-00128 (Mar. 24, 2017). 3 See Policy Branch Information; Actions Taken, Public Notice, Report No. SAT-00838, File No. SAT-MOD-20111102-00211 (Jan. 20, 2012). 1

During the drift of T9S from 101.1 W.L. to 101.2 W.L., DIRECTV will utilize only the satellite’s telemetry, tracking, and command (“TT&C”) frequencies and will follow industry practices for coordinating TT&C transmissions during the relocation process. The specific TT&C frequencies are as follows:  12695.5 MHz (space-to-Earth); and  17795.0 MHz (Earth-to-space). Once relocated to 101.2 W.L., DIRECTV seeks authority to operate on the Ku-DBS (12.2-12.7 GHz (space-to-Earth) and 17.3-17.8 GHz (Earth-to-space)) and Ka-Band (18.3- 18.8/19.7-20.2 GHz (space-to-Earth) and 28.35-28.6/29.25-29.5/29.5-30.0 GHz (Earth-to-space)) communications frequencies already licensed to T9S at the nominal 101 W.L. orbital location.4 Grant of this STA request will not result in increased risk of harmful interference. As noted above, DIRECTV will operate only the above-listed TT&C frequencies during the drift and will coordinate its TT&C transmissions with operators of satellites in the drift path. In the unlikely event that any interference should occur during the drift, DIRECTV will take all reasonable steps to eliminate such interference. Once on station at 101.2 W.L., DIRECTV will operate the communications payload in conformance with FCC rules and any relevant coordination agreements. 4 Because DIRECTV will provide DBS service using 12/17 GHz frequency bands already assigned to DIRECTV for use at the nominal 101 W.L. orbital location, this application for special temporary authority does not implicate the Commission’s freeze on new DBS applications. See Direct Broadcast Satellite (DBS) Service Auction Nullified: Commission Sets Forth Refund Procedures for Auction No. 52 Winning Bidders and Adopts a Freeze on All New DBS Service Applications, Public Notice, 20 FCC Rcd 20618 (2005) (clarifying that “[t]he freeze does not apply to applications for replacement satellites, modifications to existing satellite licenses, or requests for special temporary authority, unless such applications seek authority to operate on frequencies and/or orbital locations not previously authorized for operation by that licensee”) (emphasis added). 2

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 the satellite’s temporary collocation with T4S, which DIRECTV will manage internally to ensure safe station-keeping, T9S 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 T9S at 101.2 W.L. DIRECTV is also not aware of any other system with an overlapping station-keeping volume with T9S 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 the transfer of traffic from T4S to T9S in connection with the decommissioning of DIRECTV’s T4S satellite, thereby ensuring continuing service coverage to DIRECTV customers. Accordingly, DIRECTV respectfully requests that the Commission grant this request. 3


Document Created: 2019-07-03 14:57:24
Document Modified: 2019-07-03 14:57:24
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