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 Federal  Communications  Commission  DA  05-  2671 
 Before  the  Federal  Communications  Commission 
 Washington,  D.  C.  20554 

 In  the  Matter  of 
 DIRECTV  Enterprises,  LLC 

 Applications  for  Modification  of  Assigned  Orbital  Location  of  the  the  DIRECTV  8  (K)  Ka- 
 Band  Payload  and  DIRECTV  8  (D)  DBS  Payload  from  100.85  W.  L.  to  100.75  W.  L. 

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 File  Nos.  SAT-  MOD-  20050513-  00100  SAT-  MOD-  20050513-  00101 
 Call  Signs:  S2132;  S2632 

 ORDER 
 Adopted:  October  07,  2005  Released:  October  07,  2005 

 By  the  Deputy  Chief,  Satellite  Division,  International  Bureau: 
 I.  INTRODUCTION 
 1.  By  this  Order,  we  modify  the  authorizations  of  DIRECTV  Enterprises,  LLC  (DIRECTV)  for  its  Direct  Broadcast  Satellite  (DBS)  space  station  and  Fixed  Satellite  Service  (FSS)  Ka-  band  1  space  station  2  on 

 the  DIRECTV  8  Geostationary  Satellite  Orbit  (GSO)  satellite  to  allow  for  relocation  of  the  DIRECTV  8  satellite  from  the  100.85  W.  L.  orbital  location  3  to  the  100.75  W.  L.  orbital  location.  4  In  doing  so,  as 
 explained  below,  we  decline  to  condition  this  grant  on  DIRECTVs  successful  coordination  of  the  DIRECTV  8  satellite  with  the  satellites  of  Mobile  Satellite  Ventures  Subsidiary,  LLC  (MSV)  at  the  nominal 
 101  W.  L.  location,  as  sought  by  MSV.  5  Grant  of  these  applications  will  result  in  the  efficient  deployment  of  orbital  resources  and  reduce  the  stationkeeping  burden  on  DIRECTV. 

 1  As  used  in  this  Order,  the  term  Ka-  band  refers  to  the  18.3-  18.8  GHz  (space-  to-  Earth),  19.7-  20.2  GHz  (space-  to-Earth), 
 28.35-  28.6  GHz  (Earth-  to-  space),  and  29.25-  30.0  GHz  (Earth-  to-  space)  frequency  bands.  2 
 As  used  in  this  Order,  the  term  space  station  has  the  meaning  given  in  the  International  Telecommunication  Union  (ITU)  Radio  Regulations,  i.  e.,  one  or  more  transmitters,  or  receivers,  or  a  combination  of  transmitters  and 

 receivers  necessary  for  carrying  on  a  radiocommunication  service,  and  located  on  an  object  which  is  beyond,  or  is  intended  to  go  beyond,  the  major  portion  of  the  Earths  atmosphere.  ITU  Radio  Regulations  Articles  1.  61  and  1.64; 
 see  also  47  C.  F.  R.    25.  201.  3 
 DIRECTV  8  was  launched  in  May  2005.  DIRECTV  was  granted  authority,  pursuant  to  a  Special  Temporary  Authority  (STA),  to  conduct  in-  orbit  testing  of  the  DIRECTV  8  satellites  DBS  payload  at  the  138  W.  L.  location 

 and  upon  completion  of  the  test  to  return  the  satellite  to  its  assigned  location.  See  International  Bureau,  Policy  Branch  Information:  Actions  Taken,  Public  Notice,  Report  No.  SAT-  00317  (rel.  August  26,  2005)  (granting  File  No. 
 SAT-  STA-  20050624-  00136).  4 
 The  0.  1  change  in  orbit  location  corresponds  to  a  minimum  horizontal  separation  of  about  73.  6  kilometers,  or  45.  7  statute  miles. 

 5  See  Comments  of  Mobile  Satellite  Ventures  Subsidiary  LLC,  filed  May  31,  2005  (MSV  Comments). 
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 II.  BACKGROUND 
 2.  In  2004,  the  Commission  authorized  DIRECTV  to  operate  two  separate  space  stations  on  the  DIRECTV  8  satellite  at  the  100.85  W.  L.  orbital  location.  One  authorization  is  for  a  DBS  space  station 

 (Call  Sign  S2632)  and  one  is  for  a  Ka-  band  FSS  space  station  (Call  Sign  S2132).  6  The  DBS  space  station  is  authorized  to  operate  on  the  16  odd-  numbered  channels  between  1  and  31  inclusive  in  the  12.  2  12.7 
 GHz  (space-  to-  Earth)  and  17.3  17.8  GHz  (Earth-  to-  space)  frequency  bands.  The  Ka-  band  FSS  space  station  is  authorized  to  operate  in  the  18.3-  18.8  GHz  (space-  to-  Earth),  19.7-  20.2  GHz  (space-  to-  Earth), 
 28.35-  28.6  GHz  (Earth-  to-  space),  and  29.25-  30.0  GHz  (Earth-  to-  space)  frequency  bands.  Under  its  authorization,  DIRECTV  8  is  assigned  to  the  100.85  W.  L.  orbital  location  with  0.05  longitudinal 
 stationkeeping,  i.  e.,  DIRECTV  8  currently  has  an  authorized  longitudinal  range  of  100.  80  W.  L.  to  100.90  W.  L. 

 3.  Six  in-  orbit  satellites  are  authorized  to  operate  at  assigned  locations  within  0.25  degrees  of  the  101  W.  L.  location,  including  DIRECTV  8.  Specifically,  MSVs  in-  orbit  satellite,  AMSC-  1,  is 
 authorized  to  operate  at  the  100.95  W.  L.  orbital  location  with  0.  05  longitudinal  stationkeeping.  7  AMSC-  1  therefore  has  an  authorized  longitudinal  range  of  100.90  W.  L.  to  101.00  W.  L.  DIRECTVs 
 DIRECTV  1R  satellite  is  authorized  at  the  100.85  W.  L.  orbital  location  with  0.05  longitudinal  stationkeeping,  i.  e.,  DIRECTV  1R  currently  has  an  authorized  longitudinal  range  of  100.80  W.  L.  to 
 100.90  W.  L.  8  DIRECTVs  DIRECTV  4S  satellite  is  authorized  at  the  101.20  W.  L.  orbital  location  with  0.  05  longitudinal  stationkeeping,  thus  DIRECTV  4S  has  an  authorized  longitudinal  range  of  101.15 

 6  See  International  Bureau,  Policy  Branch  Information:  Actions  Taken,  Public  Notice,  Report  No.  SAT-  00256  (rel. 
 November  5,  2004)  (granting  File  Nos.  SAT-  RPL-  20040630-  00127  (DBS  space  station)  and  SAT-  MOD-  20040630-  00128  (Ka-  band  space  station)).  The  November  5,  2004  actions  authorized  the  DIRECTV  8  satellite  to  operate  at 

 the  100.  85  W.  L.  orbital  location.  Subsequent  modifications  and  Special  Temporary  Authorizations  (STAs)  relating  to  DIRECTV  8  did  not  affect  the  authorized  orbital  location.  See  International  Bureau,  Policy  Branch  Information: 
 Actions  Taken,  Public  Notice,  Report  No.  SAT-  00317  (rel.  August  26,  2005)  (granting  File  No.  SAT-  STA-20050624-  00136  for  in-  orbit  testing);  Report  No.  SAT-  00308  (rel.  July  15,  2005)  (granting  File  Nos.  SAT-  STA-20050526- 
 00108  (DBS  space  station)  and  SAT-  STA-  20050526-  00109  (Ka-  band  space  station));  Report  No.  SAT-00302  (rel.  June  24,  2005)  (granting  File  Nos.  SAT-  STA-  20050616-  00126  (DBS  space  station)  and  SAT-  STA-20050616- 
 00126  (Ka-  band  space  station));  Report  No.  SAT-  00294  (rel.  May  27,  2005)  (granting  File  Nos.  SAT-STA-  20050506-  00095  (DBS  space  station)  and  SAT-  STA-  20050506-  00096  (Ka-  band  space  station)).  The  origin  of 
 the  DIRECTV  8  satellite  dates  to  1997,  when  the  Commission  authorized  DIRECTVs  predecessor-  in-  interest,  Hughes  Communications  Galaxy,  Inc.,  to  launch  and  operate  a  GSO  FSS  satellite  system.  See  Hughes 
 Communications  Galaxy,  Inc.,  Order  and  Authorization,  13  FCC  Rcd  1351(  1997),  modified  by  Hughes  Communications  Galaxy,  Inc.,  Order  and  Authorization,  16  FCC  Rcd  2470  (2001),  further  modified  by  Hughes 
 Communications  Galaxy,  Inc.,  Order  and  Authoriztion,  16  FCC  Rcd  12627  (2001).  In  April  2002,  the  Commission  authorized  the  pro  forma  assignment  of  this  license  from  Hughes  Communications  Galaxy,  Inc.  to  Hughes  Network 
 Systems,  Inc.  See  File  No.  SAT-  ASG-  20011204-  00110.  In  May  2004,  the  Commission  authorized  the  pro  forma  assignment  of  this  license  from  Hughes  Network  Systems  to  DIRECTV.  See  File  No.  SAT-  ASG-  20040520-  00101. 
 7  See  International  Bureau,  Policy  Branch  Information:  Actions  Taken,  Public  Notice,  19  FCC  Rcd  20460  (rel. 
 August  27,  2004)  (Granting  File  No.  SAT-  MOD-  20040623-  00120).  8 
 See  International  Bureau,  Policy  Branch  Information:  Satellite  Space  Applications  Accepted  for  Filing,  Public  Notice,  Report  No.  SAT-  00123,  File  No.  SAT-  STA-  20020910-  00172  (rel.  September  27,  2002).  The  DIRECTV  1R 

 satellite  was  relocated  in  conjunction  with  the  relocation  of  the  DIRECTV  3  satellite  to  enable  DIRECTV  1R  to  carry  the  traffic  assigned  to  DIRECTV  3.  DIRECTV  subsequently  filed  a  modification  application  to  make  these 
 changes  permanent.  See  File  No.  SAT-  MOD-  20030205-  00032.  This  application,  except  for  the  portion  dealing  with  the  request  to  redesignate  the  orbital  location  for  DIRECTV  1R,  was  withdrawn  by  DIRECTV  on  March  9, 
 2004.  See  Letter  from  James  R.  Butterworth,  Senior  Vice  President,  DIRECTV,  to  Thomas  S.  Tycz,  Chief,  Satellite  Division,  International  Bureau,  dated  March  9,  2004.  See  also 
 http://  svartifoss2.  fcc.  gov/  servlet/  ib.  page.  FetchAttachment?  attachment_  key=  374272  for  grant-  stamped  application  to  move  DIRECTV  1R. 
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 W.  L.  to  101.25  W.  L.  SES  Americom  has  a  satellite,  AMC-  4,  that  is  authorized  to  operate  at  the  101.00  W.  L.  orbital  location  with  0.  05  longitudinal  stationkeeping,  thus  AMC-  4  has  an  authorized  longitudinal 
 range  of  101.05  W.  L.  to  100.95  W.  L.  9  DIRECTVs  DIRECTV  2  satellite  is  authorized  to  operate  at  the  100.8  W.  L.  orbital  location.  Recently,  DIRECTV  requested  and  received  an  STA  to  move  DIRECTV  2 
 to  100.6  W.  L.  in  anticipation  of  transferring  traffic  from  DIRECTV  2  to  DIRECTV  8.  10  In  addition  to  the  in-  orbit  satellites,  one  satellite  is  authorized  to  operate  within  0.25  degrees  of  the  101  W.  L.  orbital 
 location  but  is  not  yet  launched.  Specifically,  on  May  23,  2005,  the  Commission  granted  MSVs  application  for  MSV-  1  to  be  located  at  the  101.0  W.  L.  orbital  location  with  0.  05  longitudinal 
 stationkeeping,  thus  MSV-  1  has  an  authorized  longitudinal  range  of  100.95  W.  L.  to  101.05  W.  L.  The  MSV-  1  satellite  is  expected  to  be  launched  in  2010.  Other  applications  to  launch  and  operate  satellites  at 
 assigned  locations  within  0.25  degrees  of  the  101  W.  L.  orbital  location  remain  pending  at  the  Commission.  11 

 4.  On  May  13,  2005,  DIRECTV  filed  two  applications    one  for  each  space  station    seeking  authority  to  relocate  the  DIRECTV  8  satellite  from  the  100.85  W.  L.  location  to  the  100.75  W.  L. 
 location.  12  DIRECTVs  applications  were  placed  on  public  notice  as  accepted  for  filing  on  June  10,  2005.  13  On  May  31,  2005,  MSV  filed  comments  requesting  us  to  condition  grant  of  the  DIRECTV  8 
 relocation  upon  DIRECTVs  successful  coordination  of  DIRECTV  8  with  MSVs  satellites  at  the  same  orbital  location.  14  On  September  22,  2005,  DIRECTV  filed  an  ex  parte  letter  stating  that  such  a  condition 
 is  without  precedent.  15  DIRECTV  also  stated  that  because  the  DIRECTV  8  satellite  will  replace  another  DIRECTV  satellite  licensed  to  operate  at  the  nominal  101  W.  L.  orbital  location,  there  will  be  no  increase 
 in  congestion  at  this  orbital  location.  16  On  September  30,  2005,  MSV  filed  an  ex  parte  letter  in  response  to 

 9  See  Assignment  of  Orbital  Locations  to  Space  Stations  in  the  Domestic  Fixed-  Satellite  Service  and  the 
 Applications  of  GE  American  Communications,  Inc.,  Order  and  Authorization,  15  FCC  Rcd  3385  (1999)  (AMC-  4  Authorization  Order)  (granting  File  No.  SAT-  MOD-  19981023-  00076  for  the  101.  00  W.  L.  orbital  location). 

 Subsequent  modifications  and  STAs  relating  to  AMC-  4  did  not  affect  the  regularly  authorized  orbital  location.  See  International  Bureau,  Policy  Branch  Information:  Actions  Taken,  Public  Notice,  Report  No.  SAT-  00194  (rel. 
 February  23,  2004)  (granting  File  No.  SAT-  STA-  20030626-  00118);  Report  No.  SAT-  00128  (rel.  November  15,  2002)  (granting  File  No.  SAT-  MOD-  20021108-  00206). 
 10  See  International  Bureau,  Policy  Branch  Information:  Actions  Taken,  Public  Notice,  Report  No.  SAT-  00323  (rel. 
 September  30,  2005).  We  anticipate  that  DIRECTV  will  file  a  further  modification  with  respect  to  DIRECTV  2  to  locate  it  near  the  101  W.  L.  location  as  an  in-  orbit  spare  or  to  move  it  to  another  location. 

 11  International  Bureau,  Policy  Branch  Information:  Satellite  Space  Applications  Accepted  for  Filing,  Public  Notice, 
 Report  No.  SAT-  00288  (rel.  April  29,  2005)  (accepting  File  No.  SAT-  RPL-  20050322-  00070  for  filing)  (Application  of  DIRECTV  for  Authority  to  Launch  and  Operate  DIRECTV  9S,  a  Direct  Broadcast  Satellite,  at  101  W.  L.);  File 

 Nos.  SAT-  LOA-  19970605-  00050  (application  to  operate  in  the  17  GHz  BSS  band);  SAT-  LOA-  20020322-  00033  (application  to  operate  in  the  17  GHz  BSS  band).  The  17  GHz  BSS  applications  have  not  yet  been  accepted  for 
 filing.  12 
 File  Nos.  SAT-  MOD-  20050513-  00101  (for  DBS  authorization)  and  SAT-  MOD-  20050513-  00100  (for  Ka-  band  authorization).  The  applications  are  substantively  identical,  therefore,  we  will  refer  to  the  two  applications 

 collectively  as  the  Application  or  the  DIRECTV  Application.  13 
 See  International  Bureau,  Policy  Branch  Information:  Satellite  Space  Applications  Accepted  for  Filing,  Public  Notice,  Report  No.  SAT-  00297  (rel.  June  10,  2005). 

 14  MSV  Comments  at  3. 
 15  Letter  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  from  William  M.  Wiltshire, 
 Counsel  for  DIRECTV  Enterprises,  LLC,  dated  September  22,  2005  (DIRECTV  Ex  Parte  Letter).  16 

 Id.  at  2. 
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 DIRECTVs  letter.  17  MSV  states  that  the  Commission  should  make  it  clear  that  launch  and  operation  of  the  new  DIRECTV  satellite  prior  to  launch  and  operation  of  MSVs  next-  generation  satellite  does  not 
 provide  DIRECTV  with  greater  rights  than  MSV  to  operate  at  a  given  location  in  the  orbital  arc.  18 
 III.  DISCUSSION 
 5.  DIRECTV  requests  authority  to  reposition  the  DIRECTV  8  satellite  from  the  100.85  W.  L.  orbital  location  to  the  100.75  W.  L.  orbital  location.  DIRECTV  indicates  that  the  requested  relocation 

 will  enable  it  to  operate  its  DIRECTV  8  satellite  in  a  stationkeeping  volume  that  does  not  overlap  with  any  of  the  other  space  stations  operating  at  the  nominal  101  W.  L.  orbital  location.  19  We  conclude  that 
 grant  of  the  requested  modification  will  serve  the  public  interest,  convenience  and  necessity  because  it  will  result  in  the  efficient  deployment  of  orbital  resources. 

 6.  Grant  of  DIRECTVs  Application  will  result  in  DIRECTV  8  having  a  longitudinal  range  of  100.70  W.  L.  to  100.80  W.  L.  This  will  simplify  stationkeeping  operations  for  DIRECTV  1R  and 
 DIRECTV  8  by  eliminating  the  overlap  between  the  stationkeeping  volumes.  We  also  note  that  because  the  DIRECTV  8  satellite  is  a  replacement  for  the  DIRECTV  2  satellite,  operation  of  DIRECTV  8  at  the 
 100.75  W.  L.  location  will  not  increase  congestion  at  the  nominal  101  W.  L.  orbital  location.  20  With  respect  to  MSVs  concerns,  we  note  that  grant  of  this  request  will  result  in  a  minimum  angular  separation 
 of  0.1  between  DIRECTV  8  at  its  requested  location  and  AMSC-  1.  This  would  presumably  obviate  any  stationkeeping  concern  of  MSV  at  this  location  with  respect  to  DIRECTV  8.  This  would  also  hold  true 
 with  respect  to  the  authorized  but  not  launched  MSV-  1  satellite.  Thus,  grant  of  DIRECTVs  application  will  increase  the  separation  between  the  DIRECTV  8  satellite  and  MSVs  current  and  future  authorized 
 satellites  at  the  nominal  101  W.  L.  orbital  location. 
 7.  With  respect  to  MSVs  proposed  condition,  we  note  as  an  initial  matter  that  the  authorization  for  the  MSV-  1  satellite  was  not  conditioned  upon  successful  coordination  of  its  satellite  with  those  of 

 DIRECTV  at  the  same  location.  Therefore,  adopting  the  condition  proposed  by  MSV  would  constitute  inconsistent  treatment  of  the  two  licensees.  21  We  note,  however,  that  parties  licensed  at  a  particular 
 orbital  location  are  expected  to  coordinate  with  other  parties  licensed  at  the  same  location  to  avoid  in-orbit  collisions.  22  Thus,  we  will  not  impose  the  condition  requested  by  MSV  regarding  adjacent  satellite 

 17  Letter  to  Marlene  H.  Dortch,  Secretary,  Federal  Communications  Commission,  from  Jennifer  A.  Manner,  Vice 
 President,  Regulatory  Affairs,  Mobile  Satellite  Ventures  LP,  dated  September  22,  2005.  18 

 Id.  19 
 DIRECTV  Application  at  1-  3.  20 
 See  DIRECTV  Ex  Parte  Letter  at  2.  21 
 Id.  at  1.  22 
 See  Mitigation  of  Orbital  Debris,  Second  Report  and  Order,  19  FCC  Rcd  11567  (2004)  (Orbital  Debris  2  nd  Report  and  Order).  In  the  Orbital  Debris  2  nd  Report  and  Order,  the  Commission  concluded  that,  while  the  choice  of  orbital 

 regimes  is  best  left  to  the  discretion  of  operators,  in  some  instances  the  public  interest  would  be  served  by  a  detailed  discussion  of  how  operators  would  avoid  potential  collisions  between  operational  spacecraft  with  overlapping 
 stationkeeping  volumes.  Id.  at  paras.  49-  50.  For  example,  where  operators  proposed  to  co-  locate  multiple  satellites  at  the  same  geostationary  orbital  location,  the  Commission  required  operators  to  state  what  measures  will  be  taken  to 
 prevent  collisions.  Id.  at  para.  51.  The  Commission  noted  that,  although  it  is  possible  to  successfully  locate  multiple  satellites  at  a  single  location  and  within  the  same  stationkeeping  volume,  such  arrangements  require  real-time 
 coordination  that  must  be  disclosed  to  the  Commission.  Id.  The  record  reflects  that  DIRECTV,  MSV,  and  SES  Americom  have  held  discussions  concerning  the  current  arrangement  of  satellites  at  the  101  W.  L.  orbital  location. 
 DIRECTV  Ex  Parte  Letter  at  1.  We  note  that  should  a  coordination  arrangement  between  the  licensees  result  in  parameters  not  consistent  with  the  authorized  parameters  for  any  space  station,  we  expect  the  licensee  of  that  space 
 station  to  file  an  appropriate  modification  request  prior  to  implementation  of  that  agreement.  Operations  not  consistent  with  those  authorized  are  subject  to  enforcement  action. 
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 coordination  on  DIRECTV  and  will,  as  is  our  normal  practice,  rely  on  the  operators  to  coordinate  in  good  faith.  23 
 IV.  CONCLUSION  AND  ORDERING  CLAUSES 
 8.  Accordingly,  IT  IS  ORDERED  that,  the  request  of  DIRECTV  Enterprises  LLC  to  modify  the  assigned  orbital  location  of  its  DIRECTV  8  satellite  from  the  100.85  W.  L.  orbital  location  to  the  100.75 

 W.  L.  orbital  location,  File  Nos.  SAT-  MOD-  20050513-  00101  (Call  Sign  S2632)  and  SAT-  MOD-20050513-  00100  (Call  Sign  S2132),  IS  GRANTED,  subject  to  the  following  conditions: 

 a.  DIRECTV  Enterprises,  LLC  shall  coordinate  all  drift  orbit  DBS  and  Telemetry,  Tracking,  and  Control  operations  with  other  potentially  affected  in-  orbit 
 operators. 
 b.  During  the  relocation  of  the  DIRECTV  8  satellite  operations  shall  be  on  a  non-harmful  interference  basis,  meaning  that  DIRECTV  Enterprises,  LLC  shall  not 

 cause  interference  to,  and  shall  not  claim  protection  from  interference  caused  to  it  by  any  other  lawfully  operating  satellites. 

 c.  In  the  event  that  any  harmful  interference  is  caused  as  a  result  of  operations  during  the  relocation  of  the  DIRECTV  8  satellite,  DIRECTV  Enterprises,  LLC, 
 shall  cease  operations  immediately  upon  notification  of  such  interference  and  shall  inform  the  Commission  immediately,  in  writing,  of  such  an  event. 

 d.  All  of  the  originally  authorized  terms,  conditions,  and  technical  specifications  of  the  DIRECTV  8  DBS  space  station  (Call  Sign  S2632)  and  FSS  space  station 
 (Call  Sign  S2132),  except  for  the  authorized  orbital  location,  remain  in  effect. 
 9.  IT  IS  FURTHER  ORDERED  that  DIRECTV  Enterprises,  LLC  has  30  days  from  the  date  of  the  release  of  this  order  to  decline  this  authorization  as  conditioned.  Failure  to  respond  within  that  period 

 will  constitute  formal  acceptance  of  the  authorization  as  conditioned. 
 10.  This  order  is  issued  pursuant  to  Section  0.261  of  the  Commissions  rules  on  delegations  of  authority,  47  C.  F.  R.    0.261,  and  is  effective  upon  release. 

 FEDERAL  COMMUNICATIONS  COMMISSION 
 Fern  J.  Jarmulnek  Deputy  Chief 
 Satellite  Division  International  Bureau 

 23  See,  e.  g.,  Satellite  Transponder  Leasing  Corp.,  5  FCC  Rcd  1651,  1652  (Com.  Car.  Bur.  1990)  and  American 
 Satellite  Company,  5  FCC  Rcd  1186,  1189  (Com.  Car.  Bur.  1990)  (Bureau  declined  to  impose  coordination  conditions  where  no  insurmountable  coordination  issues  were  raised). 
5