DIRECTV Ex Parte re

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by DIRECTV Enterprises, LLC

DIRECTV Ex Parte re 103W

2014-12-18

This document pretains to SES-LFS-20140924-00752 for License to use Foreign Satellite (earth) on a Satellite Earth Station filing.

IBFS_SESLFS2014092400752_1071637

December 18, 2014 BY ELECTRONIC FILING Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth Street, S.W. Washington, DC 20554 Re: Notice of Ex Parte Presentations, IBFS File Nos. SAT-RPL-20121228-00227, SAT-AMD-20131113-00132, and SES-LFS-20140924-00752 Dear Ms. Dortch: On December 16, 2014, Phil Goswitz, Stacy Fuller, Jack Wengryniuk and undersigned counsel on behalf of DIRECTV Enterprises, LLC (“DIRECTV”) had separate meetings with the following Commission personnel with respect to the above referenced proceedings: • Diane Cornell, Special Counsel to Chairman Wheeler, • David Goldman, Senior Legal Advisor to Commissioner Rosenworcel, • Louis Peraertz, Legal Advisor to Commissioner Clyburn, • Brendan Carr, Legal Advisor to Commissioner Pai, • Erin McGrath, Legal Advisor to Commissioner O’Rielly, and • Mindel De La Torre, Troy Tanner, Jose Albuquerque, Karl Kensinger, and Lynne Montgomery of the International Bureau. During each meeting, the DIRECTV representatives provided and discussed the attached presentation. Respectfully submitted, /s/ William M. Wiltshire Counsel for DIRECTV Enterprises, LLC Attachment cc: Karis A. Hastings Margaret L. Tobey Stephanie Roy FCC Meeting Attendees

»1 DIRECTV Licensing Issues at the 103W Orbital Location December 16, 2014

Overview DIRECTV @AMC—1 C/Ku satellite at 103W is "reliable" through 2016 ©Both DIRECTV and SES/Ciel are licensed to operate at 103W in the 17/24 GHz BSS band @©DIRECTV has launched first 17/24 GHz BSS satellite to 99W second satellite complete and ready for launch to 103W in Q2 2015 ®@©Prior to seeking US authorization, SES used SES—3 to disadvantage US interests, including at 103W ®@SES now seeks the benefits of a US license for the C/Ku—band payloads on SES—3 while Ciel continues to block DIRECTYV‘s use of the 17/24 GHz BSS band ® There is no reason to rush to grant SES—3 a US license prior to completion of coordination

DIRECTV — the Leader in 17/24 GHz BSS e qp)( s(aU ©DIRECTV pioneered 17/24 GHz BSS service in the U.S. @DIRECTV filed a petition for rulemaking to create this service in 1997 ®©Pushed for spectrum allocation and service rules for over a decade ©DIRECTV also applied for 17/24 GHz BSS licenses in 1997 ®©Awarded two licenses in first round of grants, for 99W and 103W, in July 2009 ®First satellite launched to I9W on December 6 ® Second satellite fully constructed, awaiting launch vehicle

DIRECTV Operations at 99W and 103W C DirEctV ®©DIRECTV has been operating at 99W and 103W since 2005 in the FSS Ka—band (20/30 GHz) ® This served as cornerstone for DIRECTV leading the HD revolution ®©DIRECTV plans to use 17/24 GHz BSS at 99/103W to lead the introduction of Ultra HD services ®© Currently nearly 15 million DIRECTV subscribers receive service from 99/103W @Placing 17/24 GHz BSS at the same locations enables subscribers to use a single small dish to receive programming in all bands

uency Band Allocation @®DirEcTV Downlink Frequencies DIRECTV Ku band Reverse es s Allocated band B" band PWEETl 12.2 12.7 17.3 17.7 18.3 C th) 20.2 Four 500 MHz RHCP (GHz) Frequency ~< Bands 500 MHz us Specific Bands Assigned at Each Orbital Slot

uU u ce Is Here e J§ V DIRECTV 4K DIRECTV AKREADY

AMC—1 Operations at 103W Sl ®SES operates the C/Ku—band AMC—1 satellite at 103W @AMC—1 is licensed through October 2016 ® The FCC extended the license in 2011 based on SES‘s representation that the spacecraft would be able to "continue providing reliable service" through October 2016 ® Satellite continues to perform — in fact, SES continues to market capacity on AMC—1 ®©For example, just last month, iN DEMAND extended its agreement for C—band capacity on the spacecraft ®@©According to SES, "the next window for the transition [to SES—3] will not open until after the end of the NFL season in February 2015 (at the earliest)" ®@©Clearly, there is no urgency to replace AMC—1

SES—3 History Eny ® SES—3 was originally launched under Luxemburg authority in July 2011 ®Like SES—1 and SES—2, carries a token 17—24GHz BSS payload ® After in—orbit testing, SES—3 was positioned at 99W ®@LUX claimed at ITU to have brought 17—24 GHz BSS into use @/TU later rejected that claim ® SES then sent SES—3 to 108E for another mission ® SES—3 arrived at 103W in late September 2012 ® SES used token 17/24 GHz BSS payload on SES—3 to bring into use a Canadian ITU network at 103W ® Only after completing all of these other activities did SES seek to re—flag the C/Ku—band payloads on SES—3 as US in late December 2012

Ciel Background at 103W Sl ® Ciel was originally licensed for 17/24 GHz BSS (Ciel 6) by Industry Canada in June 2008 ® License application proposed serving Canada ® License grant required a satellite to be in use by 1/1/2013 ® License was modified in October 2009 requiring "interim" satellite (Ciel 61) by 1/1/2013 and "new" satellite (Ciel 6) by 1/1/15 ® License was modified again in September 2012 requiring "new" satellite by 12/1/18 (over 10 years from initial grant) ® Token payload on SES—3 has become Ciel 6i ® Ciel‘s customer, DISH Network, has contractual rights to use Ciel‘s 17/24 GHz BSS capacity at this slot ® —Recently filed for blanket earth station authorization to explore the possibility of feeding video to as—yet unbuilt terrestrial mobile network

Ciel 61 vs DIRECTV RB—2 Capability at 103W DIRECTV CCS —_,:% Ciel 6i DIRECTV RB—2 Very broad beam from simple horn antenna Shaped CONUS beam + HI and P.R. spot beams Single 500 MHz channel (only 400 MHz available in US) Eighteen 36 MHz channels Single TWTA amplifier to support this single channel 39 TWTA amplifiers to support these eighteen channels Receives LHCP, transmits LHCP/RHCP Max transmit power capability of: Very limited transmit power capability: 33 dBW max 59 dBW CONUS, 57.5 dBW HI, 60.6 dBW PR. (i.e. over 400 times the transmit power of Ciel 6i)

Ciel 6i vs CAN—BSS19 Capability DIREC _ sz< s=zsaz— { _ Nel sr —C [( CAN—BSS19 * Single low gain (23 dBi) TX and RX beam * Shaped CONUS beam (35 dBi), Shaped South America Beam (35 dBi), Steerable high gain beam (44.5 dBi) (i.e. 16 to 140 times the gain of Ciel 6i) * Single 500 MHz channel * Twenty—four 24 MHz channels across 500 MHz * Receives LHCP, transmits LHCP/RHCP * Receives and transmits LHCP/RHCP * Very low transmit power capability: 33 dBW max * Max transmit power capability of: 57 dBW CONUS, 57 dBW S.A., 64.5 dBW steerable (i.e. over 250 times the transmit power of Ciel 6i) Min transmit power capability of 53/53/60.5 dBW (i.e., over 100 times the transmit power of Ciel 6i)

There is No Reason to License SES—3 Now e qp)( s(aU ® There is no urgent need to replace AMC—1, which continues its "reliable" performance ® SES used SES—3 for other missions for over a year before even placing the satellite at 103W ®In any event, SES says that it cannot swap SES—3 for AMC—1 until "at least" February 2015 ®In the meantime, coordination of 17/24 GHz BSS operations between DIRECTV and Ciel continues ®@FCC and Industry Canada are assisting in search for compromise solution ®©Public interest analysis may depend upon the outcome of the coordination process

DON‘T JUST WATCH TV. DIRECTV. B>1 DIRECTV


Document Created: 2019-04-19 09:35:07
Document Modified: 2019-04-19 09:35:07
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