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    Super Moderator Gary Toma's Avatar
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    Here's the full 3 page narrative:





    EXHIBIT 1
    REQUEST FOR SPECIAL TEMPORARY AUTHORITY

    DIRECTV Enterprises, LLC (“DIRECTV”) respectfully requests a grant of special temporary authority
    (“STA”)1 for 30 days commencing September 4, 2018 to drift its T15 satellite (Call Sign S2930) from
    its current location at 102.75 W.L. to 100.85 W.L. and to operate the satellite at 100.85 W.L.
    T15 is currently located at its permanently licensed orbital location of 102.75 W.L.2

    DIRECTV plans to relocate the satellite 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. The drift is scheduled to begin on September
    4, 2018 and is expected to last approximately ten days. Once relocated, T15 will initially be
    collocated with DIRECTV’s T8 satellite (Call Sign S2632) at 100.85 W.L.3 DIRECTV plans to file a
    separate STA request to relocate T8 to 100.75 W.L. once T15 is relocated to 100.85 W.L. and
    traffic is transferred from T8 to T15. DIRECTV also intends to file an additional, 180-day STA
    request to continue operating T15 at 100.85 W.L. until the satellite returns to its permanently
    licensed orbital location.4


    1 DIRECTV has filed this STA request, an FCC Form 159, and a $945.00 filing fee electronically via
    the International Bureau’s Filing System.

    2 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.

    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 DIRECTV currently anticipates returning T15 to the nominal 103 W.L. orbital location in 2019
    based on business needs.


    1



    During the drift of T15 from 102.75 W.L. to 100.85 W.L., DIRECTV will utilize only the
    satellite’s telemetry, tracking, and control (“TT&C”) frequencies and will follow industry
    practices for coordinating TT&C transmission during the relocation process. The specific TT&C
    frequencies are as follows:

     29502.5 MHz and 29505.9 MHz (T); and
     20198.5 MHz and 20199.5 MHz (R).

    Once relocated to 100.85 W.L., DIRECTV seeks authority to operate on the Ku-DBS communications
    frequencies (12.2-12.7 GHz (space-to-Earth) and 17.3-17.8 GHz (Earth-to- space)). At the nominal
    101 W.L. orbital location, DIRECTV will provide DBS service using
    12/17 GHz DBS frequency bands already assigned to DIRECTV for use at the location on DIRECTV’s T8,
    T9S (Call Sign S2669), and T4S (Call Sign S2430) satellites. As such, this application for special
    temporary authority does not implicate the Commission’s freeze on new DBS applications.5
    Grant of this STA 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 100.85 W.L., DIRECTV will operate the
    communications payload in conformance with FCC rules and any relevant coordination


    5 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



    agreements. DIRECTV has previously provided technical information for T15’s Ku-DBS
    payload and incorporates such information by reference here.6

    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 colocation with DIRECTV’s T8 satellite, which DIRECTV will manage internally
    to ensure safe-stationkeeping, T15 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 T15 at
    100.85 W.L. DIRECTV is also not aware of any other system with an overlapping station-keeping
    volume with T15 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.

    6 See Application of DIRECTV Enterprises, LLC For Authorization to Launch and Operate DIRECTV 15 at
    103W.L., File No. SAT-LOA-20140825-00094 (granted May 20, 2015).




    3

    Last edited by Gary Toma; 08-19-2018 at 01:12 AM.

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