Attachment STA Request

This document pretains to SAT-STA-20100525-00107 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010052500107_819358

W WILTSHIRE & GRANNIS ur May 25, 2010 Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth Street, S.W. Washington, DC 20554 Re: Requestfor Special Temporary Authorityfor In—Orbit Testing of DIRECTV 10 at 102.6° W.L. Dear Ms. Dortch: DIRECTV Enterprises, LLC ("DIRECTV") hereby requests Special Temporary Authority ("STA") to repeat an abbreviated set of in—orbit tests on the DIRECTV 10 satellite (call sign $2641) at the 102.6° W.L. orbital location. DIRECTV requests that this STA cover a period of approximately 30 days starting on June 2, 2010. DIRECTV 10 is currently drifting toward the 102.6° W.L. orbital location while traffic is being transferred from DIRECTV 10 to the recently launched DIRECTV 12 satellite.‘ Once DIRECTV 10 arrives at 102.6° W.L.and all traffic has been successfully transferred to DIRECTV 12, DIRECTV will conduct a restorative procedure on the spacecraft. The abbreviated set of tests that are the subject of this request are needed to quantify any performance improvement achieved as a consequence of the restorative procedure. Testing of DIRECTV 10 after the restorative procedure will consist of verification testing of certain specific aspects of the satellite‘s performance. The maximum value of satellite transmit power used during most of this testing will generate power flux density ("PFD") levels on the Earth‘s surface below the —118 dBW/m*/MHz value specified in Section 25.138(a)(6) of the Commission‘s rules. However, a few of the tests will exceed this PFD level for short periods of time when the maximum satellite transmit power could ‘ This activity is taking place under Grant Stamp, IBFS File No. SAT—STA—20100507—00095 (granted May 12, 2010). 1200 18TH STREET, NW | SUITE 1200 | WaSHINGTON, DC 20036 | TEL 202—730—1300 | FAX 202—730—1301 | WILTSHIREGRANNIS.COM

WILTSHIRE & GRANNIS LLP Marlene H. Dortch May 25, 2009 Page 2 of 4 exceed the value specified in the current DIRECTV 10 authorization by up to 7 dB." This testing will not result in harmful interference to other satellite systems. The only other non—DIRECTV owned co—frequency satellite operating within +6° of the 102.6° W.L. orbital location is AMC—15 located at the 105.05° W.L. location, and DIRECTV has already been discussing the coordination of these operations with SES World Skies, the licensee of that satellite, as required under Section 25.138(b), and is confident that an agreement with SES World Skies will be reached. DIRECTV will also coordinate its TT&C operations with all other potentially affected operators to ensure that no harmful interference results. Furthermore, DIRECTV is prepared to terminate all testing operations immediately upon notification from the Commission that its operations cause harmful interference to any authorized user of the spectrum. As discussed above, a few of the tests to be conducted will result in the PFD on the Earth‘s surface exceeding the value specified in Section 25.138(a)(6) for short periods of time (F.e., seconds to tens of seconds) in specific DIRECTV 10 downlink spot beams. In addition, due to the use of unmodulated CW carriers during these tests, the PFD in these spot beams will also exceed the PFD limit in Section 25.208(c) of the Commission‘s rules for the 18.3—18.8 GHz band by up to 7.5 dB.> Nonetheless, for the reasons discussed below, DIRECTV submits that the requested STA will not cause harmful interference to any co—primary terrestrial user of the band. The DIRECTV 10 operations in the relevant band consist of multiple spot beams supporting satellite channels in the 18.58—18.8 GHz frequency range. During the tests in question, the Section 25.208(c) PFD level will be exceeded only in the beams near DIRECTV‘s Castle Rock, CO Broadcast Center. The spot beams will only exceed the PFD limit in Section 25.208(c) for a period of 10—15 seconds near the peak of each such test, and the frequencies used will vary as different beams are tested. Thus, over the course of the few days during which these tests will be conducted, any one frequency will be subject to additional PFD a minimal number of episodes and for a minimal amount of time in each episode. The figure below shows the maximum geographical extent of the set of spot beams in which the PFD limit of Section 25.208(c) will be exceeded. Because the figure shows the —10 dB contour for each of the beams, the actual potentially affected geographical area is less than that shown in the figure (as the tests will exceed the PFD limit by only 7.5 dB). As can be seen in this diagram, the potentially affected area * See IBFS File No. SAT—MOD—20091009—00109. Note that all of this DIRECTV 10 testing will be closely coordinated with U.S. government systems under FN US334. * At no time during this testing will DIRECTV 10 exceed the PFD limits established in Section 25.208(d).

WILTSHIRE & GRANNIS LLP Marlene H. Dortch May 25, 2009 Page 3 of 4 includes all of Colorado, most of New Mexico, and parts of Wyoming, Nebraska, Kansas, Oklahoma, Texas, Arizona and Utah. In order to determine the impact of these operations in the potentially affected area, DIRECTV accessed the Commission‘s Universal Licensing System ("ULS") to determine what terrestrial operators might also be authorized to operate in the 18.58—18.8 GHz band in each of the potentially affected areas. As specified in Section 101.97 of the Commission‘s rules, any such system that was the subject of a license extension after June 8, 2000 is authorized on a secondary basis to FSS systems. As shown on the attached spreadsheet, all of the 111 terrestrial systems identified by ULS as operating in this band in the target states have been renewed after June 8, 2000. Accordingly, each of these licensees operates on a secondary basis in the band. siwl— NB KS new catives wegrens s ol s0c0 acol— \\b/ fhenn Tempe X 7 ¢ sok TX w 1 i i i 1 i 1 i 1 11400 uzce noc 10800 me co 10400 10200 xo ce co es to East Leneiite Oepeen Accordingly, DIRECTV submits that, even though the requested operations of DIRECTV 10 will slightly exceed the PFD limits in Section 25.208(c) for brief periods,

WILTSHIRE & GRANNIS LLP Marlene H. Dortch May 25, 2009 Page 4 of 4 grant of the requested STA will not result in harmful interference to any co—primary user of the 18.3—18.8 GHz band.* In addition, as has been done in the past, DIRECTV would like to take this opportunity to provide 24/7 contact information in case any issue arises in connection with the operations of DIRECTV 10 under the requested STA. The direct number at DIRECTV‘s Castle Rock facility is 720—733—7290 and DIRECTV personnel will be at that location during all testing. Grant of this STA request will serve the public interest by allowing DIRECTV to test the DIRECTV 10 satellite after a restorative procedure has been conducted and thereby to quantify any improvement in performance obtained as a consequence of that procedure. Allowing DIRECTV to test the satellite at 102.6° W.L. will serve the public interest by minimizing the time that DIRECTV 10 is out of service. Accordingly, and in light of the impending launch date, DIRECTV requests the expeditious grant of special temporary authority. Respectfully submitted, _ William M. Wiltshire Counsel to DIRECTY Enterprises, LLC * To the extent the Commission concludes that a waiver of the PFD limit in Section 25.208(c) is required in connection with this STA request, DIRECTV submits that the public interest would be served by the grant of such a waiver for the reasons stated herein, and requests that such a waiver be granted.


Document Created: 2010-05-25 14:39:55
Document Modified: 2010-05-25 14:39:55
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