June 7, 2007
Marlene H. Dortch
Secretary
Federal Communications Commission
445 Twelfth Street, S.W.
Washington, DC 20554
Re: Request for Special Temporary Authority for In-Orbit Testing of
DIRECTV 10 at 102.6° W.L.
Call Sign: S2641
Dear Ms. Dortch:
DIRECTV Enterprises, LLC ("DIRECTV") hereby requests Special Temporary
Authority ("STA") to locate the DIRECTV 10 satellite at the 102.6° W.L. orbital location
for in-orbit testing ("IOT") after launch of the satellite, which is currently scheduled for
early July 2007. DIRECTV also requests that this authority cover the use of Ka-band
frequencies for telemetry, tracking and command ("TT&C") functions for a period
commencing upon reaching 102.6° W.L. through migration of the satellite to its licensed
position at the nominal 103° W.L. location. This STA will cover a period of
approximately 30 days, which DIRECTV requests be keyed to become effective upon the
satellite's arrival at 102.6° W.L.
DIRECTV 10 is fully constructed and scheduled for launch early next month.
DIRECTV desires to conduct IOT for approximately four weeks before moving the
satellite slightly to its licensed position to begin commercial operations. Specifically,
DIRECTV contemplates the following schedule [with approximate dates indicated in
brackets]:
• After launch and orbit raising maneuvers, DIRECTV 10 will be located at
102.6° W.L. [on or about August 17, 2007].
• After DIRECTV 10 reaches 102.6° W.L., DIRECTV will then commence
IOT of the satellite [from about August 17, 2007 to September 12, 2007].1
• After IOT is completed, DIRECTV 10 will then be drifted to its assigned
location over the course of approximately three days [reaching that orbital
position on or about September 15, 2007].
Operation and testing of DIRECTV 10 during this maneuver will not result in
harmful interference to other satellite systems. The only other co-frequency satellites
located within two degrees of arc are DIRECTV 8 and DIRECTV 9S, operating at
100.85° W.L. and 101.1° W.L., respectively, and DIRECTV anticipates no difficulty in
coordinating the operations of its satellites. DIRECTV will also coordinate its TT&C
operations during drift 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.
Grant of this STA request will serve the public interest by allowing DIRECTV to
test the DIRECTV 10 satellite to ensure that it is fully operational and ready to begin
providing service to millions of DIRECTV subscribers from the satellite's licensed
orbital location. Allowing DIRECTV to test the satellite at 102.6° W.L. will serve the
public interest by minimizing the risk of interference. Accordingly, and in light of the
impending launch date, DIRECTV requests the expeditious grant of special temporary
authority.
