Before the

FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

____________________________________
)
Application of )
)
DIRECTV ENTERPRISES, LLC ) File No. SAT-LOA-____________
) Call Sign:
For Authority to Launch and )
Operate DIRECTV RB-2A, a Satellite )
in the 17/24 GHz Broadcasting Satellite )
Service at 103° W.L. )
____________________________________)

APPLICATION FOR AUTHORITY TO LAUNCH AND OPERATE

William M. Wiltshire
Michael D. Nilsson
WILTSHIRE & GRANNIS LLP
1200 Eighteenth Street, N.W.
Washington, DC 20036
202-730-1300 tel
202-730-1301 fax
 TABLE OF CONTENTS

Page

I. GRANT OF THIS APPLICATION WOULD SERVE THE PUBLIC INTEREST ............... 2

II. INFORMATION REQUIRED UNDER SEC. 25.114 OF THE COMMISSION’S RULES ... 5

1. Name, Address, and Telephone Number of Applicant ............................... 5

2. Name, Address, and Telephone Number of Counsel.................................. 5

3. Type of Authorization Requested ............................................................... 5

4. General Description of Overall System Facilities, Operations and Services

..................................................................................................................... 6

5. Operational Characteristics ......................................................................... 6

5.1 Frequency/Channelization and Polarization Plan ........................... 6

5.2 Communications Payload ............................................................... 7
5.2.1 Uplink Transmissions ......................................................... 7
5.2.2 Downlink Transmissions .................................................... 7
5.3 TT&C Subsystem............................................................................ 8

6. Orbital Locations ........................................................................................ 9

7. Predicted Spacecraft Antenna Gain Contours........................................... 10

7.1 Uplink Beams................................................................................ 10

7.2 Downlink Beams ........................................................................... 10
7.3 TT&C Beams ................................................................................ 10

8. Service Description, Link Description and Performance Analysis, Earth

Station Parameters .................................................................................... 11

8.1 Service Description ....................................................................... 11

8.2 Link Performance.......................................................................... 11
8.3 Earth Station Parameters ............................................................... 12

9. Satellite Orbit Characteristics ................................................................... 12

10. Power Flux Density................................................................................... 12

11. Arrangement for Tracking, Telemetry, and Control ................................. 14

12. Physical Characteristics of the Space Station ........................................... 14

i
 13. Common Carrier Status............................................................................. 14

14. Schedule .................................................................................................... 14

15. Public Interest Considerations .................................................................. 15

16. Interference Analysis ................................................................................ 15

17. Orbital Debris Mitigation .......................................................................... 16

III. ITU COST RECOVERY .......................................................................................... 22

IV. CONCLUSION ........................................................................................................ 22

Appendix A: Link Budget Analysis

Appendix B: Antenna Beam Diagrams

Appendix C: TT&C Link Budgets

ii
 Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

____________________________________
)
Application of )
)
DIRECTV ENTERPRISES, LLC ) File No. SAT-LOA-____________
) Call Sign:
For Authority to Launch and )
Operate DIRECTV RB-2A, a Satellite )
in the 17/24 GHz Broadcasting Satellite )
Service at 103° W.L. )
____________________________________)

APPLICATION FOR AUTHORITY TO LAUNCH AND OPERATE

DIRECTV Enterprises, LLC (“DIRECTV”) hereby requests authority to launch

and operate DIRECTV RB-2A, a geostationary 17/24 GHz Broadcast Satellite Service

(“BSS”) satellite to be located at the nominal 103° W.L. position.1 DIRECTV recently

received authority to launch and operate another 17/24 GHz BSS satellite, DIRECTV

RB-2, at this orbital location.2 Accordingly, this request does not seek authority to use

any additional orbital locations or additional spectrum beyond that for which DIRECTV

is already authorized.

The DIRECTV RB-2A payload will be combined with a Ka-band FSS payload on

a high-power hybrid satellite (DIRECTV 12), which is scheduled to be launched later this

year. The resulting 17/24 GHz BSS system will provide DIRECTV an early entry into

the use and development of this newly authorized frequency band and maintain the

1
DIRECTV is simultaneously filing a separate but interrelated application for authority to launch and
operate a Ka-band satellite, DIRECTV 12, at this same location. This hybrid satellite will carry both a
Ka-band FSS and a 17/24 GHz BSS payload, each of which will have its own authorization.
2
See DIRECTV Enterprises, LLC, DA 09-1624 (Int’l Bur., rel. July 28, 2009).

1
company’s position as a pioneer in delivering digital video entertainment to American

consumers. Although DIRECTV intends to construct, launch, and operate more robust

17/24 GHz BSS payloads at this location in the future, the one proposed herein enables

immediate use of valuable orbital/spectrum resources despite the uncertainties of

international coordination and licensing of 17/24 GHz BSS systems.

Consistent with Commission rules,3 DIRECTV has initiated construction, at its

own risk, pending Commission action on this request so that the payload will be

completed in time for the scheduled launch of DIRECTV 12 in the fourth quarter of this

year. Given the short timeframe in which it intends to accomplish these objectives,

DIRECTV requests that the Commission grant this application as expeditiously as

possible.

I. GRANT OF THIS APPLICATION WOULD SERVE THE PUBLIC INTEREST

DIRECTV has long been recognized as a leader in developing innovative ways to

use advanced technology to bring more and better products and services to U.S.

consumers. In keeping with this tradition, in 2006, DIRECTV proposed a satellite system

that would use CONUS beams to provide nationwide service with the newly-available

BSS spectrum in the 17/24 GHz band at the nominal 103° W.L. orbital location.4 That

application, as subsequently revised to conform to the service and licensing rules adopted

by the Commission,5 was granted on July 28, 2009.6 DIRECTV intends to proceed with

the DIRECTV RB-2a satellite under that authorization.

3
47 C.F.R. § 25.113 (f).
4
See File No. SAT-LOA-20060908-00100.
5
See FCC File Nos. SAT-AMD-20080114-00014, SAT-AMD-20080321-00077.
6
See note 2, supra.

2
 However, two significant developments have led DIRECTV to seek authority for

a precursor 17/24 GHz BSS payload at this time. First, due to the novelty and complexity

of various aspects of this service, DIRECTV’s original application at this slot was not

granted until nearly three years after it was initially filed. In the interim, although

DIRECTV could not be sure that it would receive the authorization it sought, it had the

opportunity to place a first-generation 17/24 GHz BSS payload on a satellite (DIRECTV

12) that was also designed to enhance DIRECTV’s Ka-band operations at the nominal

103° W.L. location. That satellite is scheduled for launch later this year. Rather than

miss this opportunity, DIRECTV proceeded at its own risk to design and construct a

17/24 GHz BSS payload for DIRECTV 12.

Second, in June 2007, Industry Canada issued an authorization to operate a 17/24

GHz BSS system at the 103° W.L. orbital location to Ciel Satellite Limited Partnership.7

This authorization was issued as part of an Industry Canada satellite licensing initiative

aimed at making telecommunications services “more accessible to Canadians of all

regions”8 In these circumstances, international coordination of a CONUS beam

providing service all the way to the Canadian border with a Canadian system providing

service across Canada could be a significant challenge.

Given the uncertainty in domestic licensing and the potential difficulties

associated with international coordination, DIRECTV devised a first-generation 17/24

GHz BSS payload more appropriate to the circumstances. In order to ensure that it had

sufficient flexibility to engage in meaningful coordination negotiations, DIRECTV

changed from a single CONUS beam to a number of full-power spot beams aimed as far

7
See Letter from J.K. Lindsey to David Lewis (dated June 27, 2008) (available at
www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf09020.html).

3
south as Texas and as far north as Alaska. This also reduced the cost and complexity of

the payload, and therefore the risk of proceeding in anticipation of final Commission

authorization. At the same time, the payload will allow DIRECTV to begin providing

commercial service in the 17/24 GHz BSS band before any other satellite operator in the

world, making use of these valuable spectrum/orbital resources mere months after

receiving its first license in the band. Though DIRECTV will not be able to provide

nationwide service from this payload, it will be able to provide niche services to portions

of the country immediately, and will be able to use the lessons learned from that service

in the design and construction of more robust next-generation 17/24 GHz BSS satellites

at this and other locations in the future.

DIRECTV and its affiliates have invested years of effort and several billion

dollars in developing and implementing the nation’s leading DTH satellite system. It is

legally, technically, and otherwise qualified to construct, launch and operate the

requested satellite system. The 17/24 GHz BSS system proposed in this application will

help to ensure that DIRECTV RB-2A will operate efficiently and effectively and will be

able to provide services that will enhance DIRECTV’s overall consumer offerings. The

addition of this system will continue the evolution of DIRECTV’s network architecture,

augmenting its capabilities and thereby enhancing its ability to respond to the rapidly

changing needs of its customers in the satellite services markets.

For the foregoing reasons, DIRECTV requests that the Commission grant this

application as expeditiously as possible.

8
See comments of Canadian Minister of Industry on the satellite licensing initiative at
http://www.ic.gc.ca/eic/site/ic1.nsf/eng/02185.html.

4
II. INFORMATION REQUIRED UNDER SEC. 25.114 OF THE COMMISSION’S RULES

1. Name, Address, and Telephone Number of Applicant

DIRECTV Enterprises, LLC

2230 East Imperial Highway
El Segundo, CA 90245
(310) 964-0700

2. Name, Address, and Telephone Number of Counsel

William M. Wiltshire
Wiltshire & Grannis LLP
1200 Eighteenth Street, N.W.
Washington, DC 20036
(202) 730-1300

3. Type of Authorization Requested

DIRECTV seeks authority to launch and operate a new 17/24 GHz BSS payload,

DIRECTV RB-2A, and locate it at a position slightly offset from the nominal 103° W.L.

orbital location as part of a hybrid satellite with both 17/24 GHz BSS and Ka-band FSS

payloads to be named DIRECTV 12. This application relates solely to the 17/24 GHz

reverse band BSS portion of the proposed hybrid satellite.9

DIRECTV recognizes that the orbital location it seeks is slightly offset from the

presumptive “on-grid” slot at 103° W.L. established in Appendix F of the BSS R&O10 (an

“Appendix F slot”). Accordingly, it seeks authority to operate at reduced power and

without full interference protection, as contemplated in Sections 25.114(d)(15)(iii) and

25.262(b) of the Commission’s rules.11

9
Information related to the Ka-band portion of the proposed DIRECTV 12 hybrid satellite is being filed
concurrently in a separate application.
10
See Establishment of Policies and Service Rules for the Broadcasting Satellite Service at the 17.3-17.7
GHz Frequency Band and at the 17.7-17.8 GHz Frequency Band Internationally, and at the 24.75-
25.25 GHz Frequency Band for Fixed Satellite Services Providing Feeder Links to the Broadcasting-
Satellite Service and for the Satellite Services Operating Bi-directionally in the 17.3-17.8 GHz
Frequency Band, 22 FCC Rcd. 8842, Appendix F (2007) (“BSS R&O”).
11
See 47 C.F.R. §§ 25.114(d)(15)(iii) and 25.262(b). Although an operator offset by up to one degree
from an Appendix F slot does not have to reduce power or accept additional interference if there is no

5
 4. General Description of Overall System Facilities, Operations and
Services

DIRECTV RB-2A will consist of a 17/24 GHz BSS payload that is part of the

hybrid DIRECTV 12 geostationary satellite to be located at the nominal 103° W.L.

orbital location. DIRECTV RB-2A will provide DTH service in the recently available

ITU Region 2 BSS band and its associated feeder link band (i.e., 17.3-17.7 GHz (space-

to-Earth) and 24.75-25.15 GHz (Earth-to-space)) to subscribers using relatively small

receive antennas. The on-station telemetry, tracking, and control (TT&C) functions of

DIRECTV RB-2A will be provided as part of the Ka-band FSS payload of DIRECTV 12.

DIRECTV RB-2A will be capable of broadcasting up to eighteen transponders on

nine specific frequencies in both RHCP and LHCP in any of its downlink spot beams.

The downlink coverage will be distributed among four downlink spot beams in the

western United States.12 All eighteen channels will have a usable bandwidth of 36 MHz

and the satellite transmit spectrum used will be restricted to the 17.3-17.7 GHz (space-to-

Earth) frequency band. The satellite will be fed from uplink transmissions received in an

uplink spot beam. The uplink transmissions will be restricted to the 24.75-25.15 GHz

(Earth-to-space) frequency band.

5. Operational Characteristics

5.1 Frequency/Channelization and Polarization Plan

Details of the DIRECTV RB-2A frequency/channelization and polarization plan,

including the TT&C frequencies in the Ka-band, are included in the accompanying

Schedule S, which is hereby incorporated by reference as if fully set forth herein. All

other applicant or licensee at the adjacent Appendix F slot, there are licensees at the adjacent slot in
this case, so this provision of the rule is not applicable.
12
A request for waiver of the geographic service requirements set forth in Section 25.225 of the
Commission’s rules is included with this application.

6
uplink channels will be fed to DIRECTV RB-2A from the DIRECTV uplink facility in

Moxee, WA. The emission designator for the uplink and downlink communications

signals will be 36M0G7W and the allocated bandwidth for these emissions is 36 MHz.

5.2 Communications Payload

5.2.1 Uplink Transmissions

The maximum receive antenna gain, receive system noise temperature, and

maximum G/T of the DIRECTV RB-2A payload are all specified in the accompanying

Schedule S. Note that the G/T will decrease, dB-for-dB, from the maximum as the uplink

location moves away from beam peak.

DIRECTV RB-2A will employ a 400 MHz input bandpass filter to limit the

overall bandwidth of the received signals. The specified performance for this filter is

shown in Table 5-1.

Parameter Frequency (Fc) Specification

In-Band Gain Variation ±190 MHz 1.5 dB
±200 MHz 1.6 dB
Out of Band Rejection ±230 MHz 2.0 dB
±250 MHz 4.0 dB
±270 MHz 12.0 dB
±300 MHz 24.0 dB
±500 MHz 40.0 dB
Table 5-1. Normalized Response Characteristic of DIRECTV RB-2A
400 MHz Input Bandpass Filter

5.2.2 Downlink Transmissions

The DIRECTV RB-2A downlinks will be capable of a maximum EIRP of 55.6

dBW in beams directed toward the western part of CONUS and 61.6 dBW in the beam

directed toward Alaska. The peak transmit antenna gain and associated contours for each

of the downlink spot beams are specified in the accompanying Schedule S.

7
 The DIRECTV RB-2A uplink channels will be routed through the low noise

satellite receiver, where they will be frequency translated to the desired output channel

frequency, and then to the input bandpass filter. The frequency translated and filtered

signals will be amplified by channel amplifiers with selectable fixed/Automatic Level

Control (ALC) modes prior to final amplification. The fixed gain mode will have at least

20 dB of gain adjustment with a step size of 1 dB. The ALC will hold the output level

constant over an input dynamic range of at least 15 dB and will have a minimum output

level adjustment of 10 dB in 0.5 dB increments.

DIRECTV RB-2A will employ a 400 MHz output bandpass filter to limit the

overall bandwidth of transmitted signals. The specified performance for this filter is

shown in Table 5-2.

Parameter Frequency (Fc) Specification

In-Band Gain Variation ±190 MHz 2.5 dB
±200 MHz 3.4 dB
Out of Band Rejection ±230 MHz 6.0 dB
±250 MHz 10.0 dB
±270 MHz 16.0 dB
±300 MHz 20.0 dB
Table 5-2. Normalized Response Characteristic of DIRECTV RB-2A
400 MHz Output Bandpass Filter

5.3 TT&C Subsystem

The TT&C subsystem provides redundant telemetry, tracking, and command

channels for the spacecraft. The principal functions of the subsystem are:

1. Reception and amplification of the radio frequency pointing beacon and command
uplinks and demodulation of baseband for subsequent signal processing and
command distribution.
2. Modulation, up-conversion, amplification, and transmission of all telemetry data.
3. Reception and retransmission of ground-station-generated ranging signals.

8
The subsystem is configurable to accommodate the unique requirements of pre-launch,

orbit raising, and on-station synchronous orbit operations. The command and telemetry

frequencies for the DIRECTV 12 satellite (including the DIRECTV RB-2A payload) are

located in the Ka-band as shown in the accompanying Schedule S. The minimum cross-

polarization isolation for the on-station command and telemetry antennas will be 27 dB.13

Note that the telecommand and beacon are transmitted using the same carrier.

The beacon is always transmitted, in order to maintain proper pointing of the DIRECTV

12 spot beams. This beacon signal is modulated with tones producing approximately ±80

kHz of frequency modulation. This beacon carrier is also modulated with command data

when satellite commands are transmitted to the spacecraft and this command data

modulates the carrier to a width of approximately 1.3 MHz. The emission designators

associated with the TT&C subsystem are 1M30F9D for command, 106KG9D for

telemetry, and 160KF3N for beacon with associated allocated bandwidths of 1.3 MHz,

106 kHz and 160 kHz for each of these emissions, respectively.

The telemetry and command link performance is summarized in the link budget

analysis in Appendix C. The antenna patterns for the TT&C subsystem are discussed in

Section 7.3.

6. Orbital Locations

As specified in the accompanying Schedule S, DIRECTV seeks to locate the

DIRECTV RB-2A satellite at 102.765° W.L. orbital location, where it will be essentially

collocated with the SPACEWAY 1 and DIRECTV 10 satellites.14 This will enable

DIRECTV to use a single dish to receive signals from all three satellites. The only other

non-DIRECTV satellite within 0.4º of this orbit location is the AMC-1 satellite operated

13
A request for waiver of the cross-polarization requirements set forth in Section 25.210(i)(1) of the
Commission’s rules is included with this application.

9
by SES Americom at 103.0° W.L. Physical coordination of DIRECTV RB-2A with

these other satellites is discussed in Section 18.

7. Predicted Spacecraft Antenna Gain Contours

7.1 Uplink Beams

The satellite will receive communications signals from the DIRECTV uplink

facility in Moxee, WA. The receive antenna gain contour for the DIRECTV RB-2A

receive beam is given in GXT format in the accompanying Schedule S.

7.2 Downlink Beams

DIRECTV RB-2A will employ a transmit antenna system for 17/24 GHz BSS

service comprising four spot beams in the western United States. Each of these spot

beams will be capable of transmitting across the frequency band 17.3-17.7 GHz using

LHCP or RHCP. The peak transmit gain, and the antenna gain contours in GXT format,

are given for each of these four beams in the accompanying Schedule S.

7.3 TT&C Beams

During transfer orbit, signals commanding the satellite will be received via a wide

angle coverage antenna, capable of supporting command operation in all mission phases

including attitude anomalies. The command antenna coverage will be ± 20 degrees about

the spacecraft spin axis during transfer orbit and ± 40 degrees about the spacecraft z-axis

in both forward and aft directions. A representation of the antenna patterns for these

wide area coverage antennas is shown in Appendix B, Figure B-1. Normal on-station

command of the satellite will be achieved through the Ka-band beacon track array and the

on-station telemetry will be transmitted via the Ka-band telemetry horn antenna of

14
Note that DIRECTV 10 is currently authorized to operate at 102.775° W.L. and SPACEWAY 1 is
currently authorized to operate at 102.885° W.L. DIRECTV will be filing requests in the future to
slightly modify the orbital locations of these two satellites such that the final configuration of these

10
DIRECTV 12. The coverage pattern for the Ka-band beacon track array is shown in

Appendix B as Figure B-2 and for the telemetry horn as Figure B-3. On-station

contingency command and telemetry of the satellite will be achieved through the wide-

angle omni antenna, bicone and pipes as discussed above.

8. Service Description, Link Performance Analysis, and Earth Station

Parameters

8.1 Service Description

DIRECTV will use the DIRECTV RB-2A satellite to retransmit digital video and

audio entertainment, educational and informational programming to subscribers in the

western United States covered by one of the four spot beams available on the satellite.

8.2 Link Performance

As three of the four DIRECTV RB-2A spot beams fall into a region with a single

common maximum PFD allowed under Section 25.208(w), and as all three of these spot

beams have similar performance characteristics, a representative communications link

budget for a city in one of the spot beams is shown in Appendix A. A separate link

budget is included for the Alaska beam, as this beam falls into a different downlink PFD

region than the other three beams. Because DIRECTV is applying for an orbital location

that is offset 0.235° from an Appendix F slot, these budgets include an entry for adjacent

satellite interference (“ASI”) from neighboring 17/24 GHz BSS satellites nominally

spaced 3.765º, 4.235º, 7.765º and 8.235º away. The TT&C link budgets are shown in

Appendix C as Tables C-1 and C-2.

satellites will be DIRECTV 12 at 102.765° W.L., DIRECTV 10 at 102.815° W.L., and SPACEWAY 1
at 102.925° W.L., with the E-W station keeping of all three satellites maintained to within ±0.025°.

11
 8.3 Earth Station Parameters

There are essentially two types of earth stations to be used with the DIRECTV

RB-2A satellite: feeder-link earth stations and subscriber terminals. The feeder-link

stations will be relatively large transmit antennas, typically 9 to 13 meters, that track the

satellite electronically and will be used for transmitting programming material from

DIRECTV transmit facility to the satellite. The subscriber terminals for reception in

CONUS will be relatively small (65 cm) antennas located at subscribers’ premises.

Subscriber terminals for reception outside CONUS may need to be somewhat larger,

approximately 1 meter.

9. Satellite Orbit Characteristics

The DIRECTV RB-2A satellite will be maintained in geosynchronous orbit at the

102.765º W.L. orbital location with a maximum N-S drift of ± 0.05°, and a maximum E-

W drift of ± 0.025°. The antenna axis attitude will be maintained within a time-weighted

3σ value of ± 0.1° for all modes of operation.

10. Power Flux Density

The allowable PFD levels in the 17.3-17.7 GHz band are defined in Section

25.208(w) of the Commission’s rules on a regional basis for all conditions, including

clear sky, and for all methods of modulation as:

(1) In the region of the contiguous United States, located south of 38º North Latitude
and east of 100º West Longitude: -115 dBW/m2/MHz;

(2) In the region of the contiguous United States, located north of 38º North Latitude
and east of 100º West Longitude: -118 dBW/m2/MHz;

(3) In the region of the contiguous United States, located west of 100º West
Longitude: -121 dBW/m2/MHz; and

(4) For all regions outside of the contiguous United States including Alaska and
Hawaii: -115 dBW/m2/MHz.

12
As discussed in Section 5.2.2 above, the maximum downlink EIRP for the DIRECTV

RB-2A beams that fall in the western part of CONUS will be 55.6 dBW/36 MHz channel,

while the maximum downlink EIRP for the beam that is directed toward Alaska will be

61.6 dBW/36 MHz channel. DIRECTV calculates the maximum power flux

density/MHz on the Earth’s surface from these emissions as: Max EIRP/channel minus

spreading loss in direction of max gain minus bandwidth correction factor15. For the

western CONUS beams this equates to 55.6 dBW/36MHz – 162 (dB-m2) – 10log(36) =

-122.0 dBW/m2/MHz, and for the Alaska beam this equates to 61.6 dBW/36MHz – 162

(dB-m2) – 10log(36) = -116.0 dBW/m2/MHz.

Because DIRECTV RB-2A will be placed at 102.765º W.L. rather than the

Appendix F slot at 103° W.L., there will be 0.235º less spacing between DIRECTV RB-

2A and the next closest on-grid location established in the BSS R&O. DIRECTV

calculates that this slight offset results in approximately 0.7 dB less discrimination from

this adjacent location.16 The maximum PFD calculated above, which is 1.0 dB less than

the maximum allowed in Section 25.208(w)(1) for the western United States and in

Section 25.208(w)(4) for Alaska, more than accounts for this slight reduction in

discrimination from this next closest location as required under Section 25.140(b)(4)(iii).

This means that the DIRECTV RB-2A system is necessarily compliant with the PFD

levels established in Section 25.208(w)(1) through (4). As discussed in Section 7.2

15
Note that this is a conservative estimate of maximum power flux density, as the actual power flux
density would be further reduced by clear sky atmospheric losses.
16
This value was calculated by determining the reduction in off-axis discrimination for a 45 cm antenna
compliant with Section 25.224 which would result from the reduced topocentric angular separation for
the proposed orbital location relative to the off-axis discrimination of that same 45 cm antenna that
would result from the topocentric angular separation for the case of 4° nominal grid spacing. While
DIRECTV recognizes that the reduction in off-axis discrimination, and hence in the required level of
reduced power, would vary slightly for different locations in the DIRECTV RB-2A coverage area, it
used the generally accepted simplifying estimation that topocentric angle is 10% greater than
geocentric angle. The additional power reduction of DIRECTV RB-2A beyond the estimated 0.7 dB
more than compensates for any discrepancy associated with this simplifying assumption.

13
above, the downlink antenna gain patterns for the DIRECTV RB-2A spot beams are

included in GXT format in the accompanying Schedule S, and inspection of those

patterns shows that three of these patterns are west of 100º W.L. in CONUS and that the

fourth pattern covers Alaska. As a result, the maximum PFD on the earth’s surface

complies with Section 25.208(w) in the applicable region defined in the Commission’s

rules.

11. Arrangement for Tracking, Telemetry, and Control

DIRECTV has contracted with Intelsat Satellite Operations to perform the TT&C

operations for the DIRECTV 12 satellite on which the DIRECTV RB-2A payload will

reside. The Intelsat control center is located in Long Beach, CA. The primary TT&C

uplink will come from DIRECTV’s Castle Rock Broadcast Center, in Castle Rock, CO.

The backup TT&C uplink will come from DIRECTV’s Northeast Uplink Facility in New

Hampton, NH.

12. Physical and Bus Characteristics of the Space Station

The key spacecraft physical and bus characteristics are summarized in the

accompanying Schedule S.

13. Common Carrier Status

DIRECTV intends to operate the DIRECTV RB-2A payload on a non-broadcast,

non-common carrier basis, as it operates its current DBS and Ka-band satellite capacity at

its existing orbital locations. DIRECTV may sell and/or lease a portion of its capacity on

a non-common carrier basis for complementary business purposes.

14. Schedule

DIRECTV anticipates that Boeing will complete construction of DIRECTV RB-

2A in October of this year and that the satellite will be launched by the end of this year.

14
 15. Public Interest Considerations

See Section I above.

16. Interference Analysis

In order to achieve maximum compatibility between diverse networks, the

Commission has established coordination thresholds for earth station off-axis EIRP

density and spacecraft PFD in Sections 25.223 and 25.208, respectively. As such,

DIRECTV has assumed for the purposes of this application a regional maximum

downlink PFD value from neighboring systems consistent with Section 25.208(w),

maximum feeder link earth station off-axis transmit power density consistent with

Section 25.223 and receive earth station compliance with Section 25.224 (i.e.,

Recommendation ITU-R BO.1213).

The interference analyses that are included in this application were performed in

conjunction with the end-to-end link performance analyses. Abbreviated link budgets are

presented in Tables A-1 and A-2 of Appendix A. The analysis includes the effects of

adjacent satellite interference from satellites nominally spaced 3.765º, 4.235º, 7.765º and

8.235º away in evaluating whether the system accommodates the various data rates at

acceptable C/(N+I) thresholds. Additionally, adjacent satellite interference was

calculated assuming 1 dB of pointing loss for the receive antenna. Tables A-1 and A-2 of

Appendix A demonstrates that the DIRECTV RB-2A satellite design described in this

application is compatible with the aforementioned transmission parameters and

interference environment. Accordingly, the proposed 17/24 GHz BSS satellite would

operate successfully in such an environment. In addition, it can be readily shown that in

order to meet the off-axis EIRP requirements of Section 25.223, the maximum power

density into a Section 25.209 compliant transmit antenna must be below 3.4 dBW/MHz.

15
The link budget in Appendix A shows a maximum clear sky power density into the

feeder link antenna of:

3.6 dBW/36 MHz – 10log(36) = -12 dBW/MHz.

This value is well below the requirement of 3.4 dBW/MHz, and in fact would be 2 dB

lower when transmit losses are properly taken into account. This more than compensates

for any reduced off-axis EIRP requirement as a consequence of the slightly off-grid

location proposed for DIRECTV RB-2A.

DIRECTV recognizes that it must accept any increased interference from

compliant systems operating at Appendix F slots that may result from operating

DIRECTV RB-2A at a slight offset from the on-grid slot of 103° W.L.

17. Orbital Debris Mitigation

DIRECTV has incorporated the material objectives set forth in this application

into the technical specifications established for construction of DIRECTV RB-2A.

Spacecraft Hardware Design

DIRECTV has assessed and limited the amount of debris released in a planned

manner during normal operations. DIRECTV RB-2A will not be a source of debris

during launch, drift, or operating mode, as DIRECTV does not intend to release debris

during the planned course of operations of the satellite.

DIRECTV has also considered the possibility of DIRECTV RB-2A becoming a

source of debris by collisions with small debris or meteoroids that could cause loss of

control of the spacecraft and prevent post-mission disposal. As such, DIRECTV has

taken steps to address this possibility by incorporating redundancy, shielding, separation

of components, and other physical characteristics into the satellite’s design. For example,

omni-directional antennas have been mounted on opposite sides of the spacecraft, and

either will be sufficient to support orbit raising. The command receivers and decoders,

16
telemetry encoders and transmitters, and the bus control electronics are fully redundant,

physically separated, and located within a shielded area to minimize the probability of the

spacecraft becoming a source of debris due to a collision. DIRECTV will continue to

review these aspects of on-orbit operations with the spacecraft manufacturer and will

make such adjustments and improvements as appropriate to assure that its spacecraft will

not become a source of debris during operations or become derelict in space due to a

collision.

Minimizing the Chance of Accidental Explosions

DIRECTV, in direct consultation with Boeing, has assessed and limited, to the

maximum extent possible, the probability of accidental explosions during and after

completion of mission operations. The key areas reviewed for this purpose have included

leakage of propellant and mixing of fuel and oxidizer as well as battery pressure vessels.

The basic propulsion design (including component and functional redundancy, and the

placement of fuel tanks inside a central cylinder which provides a high level of

shielding), propulsion subsystem component construction, preflight verification through

both proof testing and analysis, and quality standards have been designed to ensure a very

low risk of propellant leakage and fuel and oxidizer mixing that can result in subsequent

explosions. During the mission, batteries and various critical areas of the propulsion

subsystem will be continually monitored (for both pressure and temperature) to preclude

conditions that could result in the remote possibility of explosion and subsequent

generation of debris.

After DIRECTV RB-2A reaches its final disposal orbit, all on-board sources of

stored energy will be depleted, all fuel line valves will be left “open,” and all batteries

will be left in a permanent discharge state. The solar cells will be slewed away from the

sun to minimize power generation. As for pressurized vessels, all except four will be

17
depressurized once the satellite has reached end of life. Two of the vessels that retain

residual pressure consist of two helium tanks that are used to maintain pressure in the

propellant tanks during the launch of the spacecraft. At the end of the launch phase,

standard practice is to seal the tanks and lines permanently so as to prevent fuel and

oxidizer from bleeding back into the lines, where they could mix and create the risk of

explosion. Boeing estimates that, at the time they are sealed, these tanks will each

contain only 200 grams of helium at a pressure of 1600 kPA. DIRECTV has been

informed by Boeing that this procedure is used for all Boeing 702 buses and possibly by

the entire spacecraft industry. The remaining helium in the two vessels is inert, and is at

a residual pressure well below the maximum rating of the tanks.

The other two vessels that will maintain a residual pressure at satellite end of life

contain the xenon propellant for the XIPS drives. The XIPS drives will be used to

maneuver the satellite to its storage orbit after removal from service. The pressure at the

thrusters is kept constant by a regulator, and once the pressure in the xenon tank drops

below the set point of the regulator, gas stops flowing from the tank. At end of life (i.e.,

once disposal orbit has been achieved), there will remain approximately 2 kg of xenon in

each tank at a pressure of 150 kPA. This procedure is standard for all Boeing 702

spacecraft buses using XIPS thrusters for stationkeeping, and is a byproduct of the

capability DIRECTV has to ensure compliance with the Commission’s post-mission

disposal requirements. As with the residual helium, the xenon fuel that remains is inert,

and as such there is no risk of chemical energy release.

All four of these tanks with residual pressure are located in the center of the

spacecraft, and thus are well shielded and considered to be impervious to collisions with

small debris or small meteoroids. The only failure mode that is foreseen as leading to a

possible venting of the tanks is a penetration of the bus from a collision with a large,

18
high-energy object, in which case the energy of collision would far surpass the residual

energy from the stored pressure in the vessel. Given the limited pressure remaining in

each tank, a sudden release of pressure on its own is not expected to cause fragmentation

of the satellite or the ejection of debris.

Accordingly, DIRECTV submits that the standard practice of retaining four tanks

with a low residual pressure is a responsible approach and results in a far lower risk of

accidental explosion than would any attempt to completely depressurize the tanks during

or after the spacecraft’s mission. DIRECTV believes that this practice is fully consistent

with the intent of Section 25.114(d)(14)(ii) of the Commission’s rules, as it will neither

pose a risk of accidental explosion nor lead to the ejection of material.

Safe Flight Profiles

DIRECTV has assessed and limited the probability of DIRECTV RB-2A

becoming a source of debris by collisions with large debris or other operational space

stations through detailed and conscientious mission planning. DIRECTV has reviewed

the list of licensed systems and systems that are under consideration by the Commission

for the nominal 103° W.L. orbital location it has requested. In addition, in order to

address non-U.S. licensed systems, DIRECTV has reviewed the list of satellite networks

in the vicinity of 103° W.L. for which a request for coordination has been submitted to

the ITU. Only those networks that are operating, or are planned to be operating, within ±

0.2° have been taken into account in this review.

As a consequence of this review, it has been determined that only three other

systems have been licensed by the Commission for, and are currently operating at, the

nominal 103° W.L. location: SPACEWAY-1 at 102.885° W.L., DIRECTV 10 at

102.775º W.L., and AMC-1 at 103.0° W.L. Physical coordination of DIRECTV RB-2

with AMC-1, SPACEWAY-1, and DIRECTV 10 at the nominal 103° W.L. position will

19
be required. As noted above, the DIRECTV satellites actually operate slightly offset

from the 103.0º W.L. position, such that there is no overlap of the station-keeping

volumes of these DIRECTV spacecraft with AMC-1 at that position. As for physical

coordination with SPACEWAY-1 and DIRECTV 10, DIRECTV will carefully

orchestrate orbit maneuvers of these two satellites with those of DIRECTV RB-2A to

ensure that all three satellites are operated safely. Specifically, DIRECTV intends to

operate these three spacecraft at orbital positions separated by .05° and to maintain east-

west station keeping within a ±.025° tolerance to avoid any overlap in their areas of

operation.

With regard to ITU filings within ±0.2 degrees of 103° W.L., the ITU has

published requests for coordination for the following satellite networks:

• Canadian CAN-BSS-103.0, CAN-BSS11 and CAN-BSS19 networks at 103°W.L.;

• Luxemburg LUX-G4-58A, LUX-G6-41 at 103° W.L.

• Holland BSSNET2-103W at 103° W.L.

Of these networks, DIRECTV can find evidence of licensing with respect to only one, as

Ciel Satellite LP has been granted a license by Canada.17 However, DIRECTV is not

aware of any satellite construction contracts that have been awarded for any of these

networks, nor does the most recently available Federal Aviation Administration

Commercial Space Station Report show any pending satellite launches for these networks.

Post-Mission Disposal

Consistent with the requirements of Section 25.283(a) of the Commission’s rules,

at the end of the operational life of the satellite, DIRECTV will maneuver DIRECTV

17
See generally information available at http://strategis.ic.gc.ca/epic/site/smt-gst.nsf/en/h_sf08522e.html.

20
RB-2A into a disposal orbit with an altitude no less than that calculated using the IADC

formula:

36,021 km + (1000·CR·A/m).

where CR is the solar pressure radiation coefficient of the spacecraft, and A/m is the Area

to mass ratio, in square meters per kilogram, of the spacecraft. The relevant values for

the DIRECTV RB-2A satellite are:

CR = 1.152

A = 167.6 m2

m = 3556 kg

Inserting these values into the equation yields the following results:

36,021 km + (1000*1.152*(167.6/3556)) = 36075.3 km

Since geostationary altitude is generally considered to be 35,786 km,18 this yields a

desired disposal orbit of at least 289 km above the geostationary arc. DIRECTV intends

to boost DIRECTV RB-2A to at least this height, and in fact will target a height of

approximately 300 km above geostationary altitude.

DIRECTV currently intends to allocate and reserve approximately 10 kg of

propellant for final orbit raising maneuvers to this altitude. This value was determined

through a detailed launch vehicle propellant budget analysis applied to the parameters of

one of DIRECTV’s most recently designed satellites. In addition, DIRECTV has

assessed fuel gauging uncertainty and this budgeted propellant provides an adequate

margin of fuel reserve to ensure that the disposal orbit will be achieved despite such

uncertainty.

18
Orbital Debris Mitigation, ¶ 65.

21
III. ITU COST RECOVERY

DIRECTV is aware that, as a result of the actions taken at the 1998

Plenipotentiary Conference, as modified by the ITU Council in 2005, processing fees are

now charged by the ITU for satellite network filings. As a consequence, Commission

applicants are responsible for any and all fees charged by the ITU. DIRECTV hereby

states that it is aware of this requirement and accepts responsibility to pay any ITU cost

recovery fees associated with this application. Invoices for such fees may be sent to the

contact representative listed in the accompanying FCC Form 312.

IV. CONCLUSION

The proposed space station will provide DIRECTV with a first-generation 17/24

GHz BSS satellite that will enhance its ability to provide high quality multichannel video

service to American consumers.

For these reasons, DIRECTV submits that the proposed satellite will serve the

public interest and respectfully requests that the Commission expeditiously grant this

request.

Respectfully submitted,

DIRECTV ENTERPRISES, LLC

By: __/s/________________________
Romulo Pontual
Executive Vice President

22
 ENGINEERING CERTIFICATION

The undersigned hereby certifies to the Federal Communications Commission as

follows:

(i) I am the technically qualified person responsible for the engineering

information contained in the foregoing Application,

(ii) I am familiar with Part 25 of the Commission's Rules, and

(iii) I have either prepared or reviewed the engineering information contained

in the foregoing Application, and it is complete and accurate to the best of
my knowledge and belief.

Signed:

/s/
Jack Wengryniuk

August 7, 2009
Date
 APPENDIX A

Link Budget Analysis

 Table A-1. DIRECTV RB-2A Link Budget – Downlink to El Paso, TX

Clear
DIRECTV RB-2A (103W) El Paso, TX Sky Rain Dn

Uplink C/N (thermal), dB Transmit power, dBW 3.6 9.6

Moxee, WA Transmit losses, dB -2.0 -2.0
Ground antenna gain, dB 66.3 66.3
Antenna pointing loss, dB -0.5 -0.5
Free space loss, dB -211.5 -211.5
Atmospheric loss, dB -0.5 -0.5
Uplink rain loss, dB 0.0 -6.0
Satellite G/T, dB/K 20.5 20.5
Bandwidth, dB-Hz -74.8 -74.8
Boltzmann's constant, dBW/Hz K 228.6 228.6

Total Uplink C/N 29.7 29.7

Downlink C/N (thermal),dB Satellite EIRP, dBW/36 MHz 53.0 53.0

El Paso Free space loss, dB -208.4 -208.4
Downlink rain loss, dB N/A -3.0
Total Atmospheric Loss (dB) -0.4 -3.2
Rain temp increase, dB 0.0 -2.8
Rcv. antenna pointing loss, dB -1.0 -1.0
Antenna wetting + noise increase, dB 0.0 -1.0
Ground G/T, dB/K 18.0 18.0
Bandwidth, dB-Hz -74.8 -74.8
Boltzmann's constant, dBW/Hz K 228.6 228.6

Total Downlink C/N 15.1 8.5

Clear
Sky Rain Dn
Totals Uplink C/N (thermal), dB 29.7 29.7
Downlink C/N (thermal), dB 15.1 8.5
x-pol interference, dB 19.2 19.2
Aggregate C/I from ASI 18.5 18.5
Aggregate C/I from TX E/S 31.2 31.2
ACI, dB 20.0 20.0
ABI, dB 99.0 99.0
Total inter and intra-system C/I, dB
(incl. x-pol, ASI, ACI, ABI, TX E/S) 14.3 14.3

Total C/(N+I), dB 11.6 7.4

Total inter and intra-system Required C/(N+I), dB (includes
C/I, dB implementation margin) 3.8 3.8

Margin, dB 7.8 3.6

A-1
 TABLE A-2. DIRECTV RB-2A LINK BUDGET – DOWNLINK TO ANCHORAGE, AK

Clear
DIRECTV RB-2A (103W) Anchorage, AK Sky Rain Dn

Uplink C/N (thermal), dB Transmit power, dBW 3.6 9.6

Moxee, WA Transmit losses, dB -2.0 -2.0
Ground antenna gain, dB 66.3 66.3
Antenna pointing loss, dB -0.5 -0.5
Free space loss, dB -211.5 -211.5
Atmospheric loss, dB -0.5 -0.5
Uplink rain loss, dB 0.0 -6.0
Satellite G/T, dB/K 20.5 20.5
Bandwidth, dB-Hz -74.8 -74.8
Boltzmann's constant, dBW/Hz K 228.6 228.6

Total Uplink C/N 29.7 29.7

Downlink C/N (thermal),dB Satellite EIRP, dBW/36 MHz 52.0 52.0

Anchorage, AK Free space loss, dB -208.4 -208.4
Downlink rain loss, dB 0.0 -2.8
Total Atmospheric Loss (dB) -1.4 -4.1
Rain temp increase, dB 0.0 -2.7
Rcv. antenna pointing loss, dB -1.0 -1.0
Antenna wetting + noise increase, dB 0.0 -1.0
Ground G/T, dB/K 21.8 21.8
Bandwidth, dB-Hz -74.8 -74.8
Boltzmann's constant, dBW/Hz K 228.6 228.6

Total Downlink C/N 16.8 10.4

Clear
Sky Rain Dn
Totals Uplink C/N (thermal), dB 29.7 29.7
Downlink C/N (thermal), dB 16.8 10.4
x-pol interference, dB 19.2 19.2
Aggregate C/I from ASI 11.9 11.9
Aggregate C/I from TX E/S 31.2 31.2
ACI, dB 20.0 20.0
ABI, dB 99.0 99.0
Total inter and intra-system C/I, dB
(incl. x-pol, ASI, ACI, ABI, TX E/S) 10.6 10.6

Total C/(N+I), dB 9.6 7.5

Total inter and intra-system Required C/(N+I), dB (includes
C/I, dB implementation margin) 3.8 3.8

Margin, dB 5.8 3.7

A-2
 APPENDIX B

TT&C Antenna Beam Diagrams

 FORWARD PIPE
±40°

_
.

(Z-A XIS)

BICO NE
±20°

±40°
AFT PIPE

Figure B-1. Wide-Area TT&C Beams

B-1
 -30.00
-40.00 -40.00
-40.00 -40.00

-8.00
-30.00 -10.00
-4.00 -30.00 -40.00
-30.00
-20.00 0.00
-40.00 -2.00

-40.00 -6.00
-40.00
-40.00 -15.00 -40.00

-30.00

-40.00

-40.00

Figure B-2. On-Station Command Antenna Coverage

B-2
Figure B-3. On-Station Telemetry Horn Antenna Coverage

B-3
 APPENDIX C

TT&C Link Budgets

Table C-1. On-Station Telemetry Link Budget

C-1
Table C-2. On-Station Command and Beacon Link Budget

C-2