Attachment Response to IB

This document pretains to SAT-AMD-20100510-00096 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2010051000096_815591

Pantelis Michalopoulos 1330 Connecticut Avenue, NW 202.429.6494 Washington, DC 20036-1795 pmichalo@steptoe.com Tel 202.429.3000 Fax 202.429.3902 steptoe.com FILED ELECTRONICALLY VIA IBFS May 10, 2010 Marlene H. Dortch Secretary Federal Communications Commission International Bureau 445 12th Street, S.W. Washington, DC 20554 Re: DISH Operating L.L.C., Call Sign 2658, SAT-MOD-20091027-00114, SAT-AMD- 2010____-____ Dear Ms. Dortch: This letter responds to a letter from Mr. Robert Nelson requesting additional information regarding the above-referenced application filed by DISH Operating L.L.C. (“DISH”).1 The application requests authority under Section 25.161(c) of the Commission’s Rules to allow DISH to suspend operations on the licensed Direct Broadcast Satellite (“DBS”) frequencies at the nominal 148º W.L. orbital location for more than 90 days, until it can free up and relocate a suitable satellite to replace the EchoStar 5 satellite. Mr. Nelson’s letter seeks information concerning the EchoStar 8 and QuetzSat-1 satellites. As an initial matter, the application identified the EchoStar 8 satellite as the most likely replacement for EchoStar 5 because, at the time the request was filed, EchoStar 8 was the first satellite from the EchoStar and DISH fleets that could be made available for a move to 148° W.L. consistent with sound operational planning. In the application, DISH noted that it may resume operations over the 32 DBS channels at 148° W.L. “using the EchoStar 8 satellite, or another satellite in DISH’s fleet if one were to become available.”2 Should another satellite 1 Letter from Robert G. Nelson, Chief, Satellite Division, to Pantelis Michalopoulos, Counsel for DISH Operating L.L.C. (April 23, 2010). 2 File No. SAT-MOD-20091027-00114, Narrative at 4 (filed Oct. 27, 2009).

Marlene H. Dortch May 10, 2010 Page 2 become available earlier than EchoStar 8, DISH may request authority to operate that satellite at 148° W.L. EchoStar 8 The Bureau makes three inquiries regarding the EchoStar 8 satellite. First, it seeks information about the current condition of EchoStar 8, including estimated fuel remaining and the date of the satellite’s expected end-of-life. EchoStar 8 is currently operating at the 77º W.L. slot and is providing programming exclusively to U.S. subscribers. While it did suffer several propulsion related anomalies in 2003, that subsystem has been stable over the last seven years, and EchoStar 8 has been operating satisfactorily using a unique stationkeeping and momentum management regime. At the end of 2009, EchoStar 8 had approximately 500 kg of propellant remaining on board, which would put the end of maneuvering life based on its fuel supply in the second half of 2017. Second, the Bureau asks when DISH expects to commence EchoStar 8’s operations at the 148° W.L. nominal orbital location. Assuming the QuetzSat-1 satellite launches in November 2011 and the satellite becomes operational 60 days after launch, EchoStar 8 could be released from service at 77° W.L. beginning around early February 2012. The satellite would drift at a rate of 0.5 degree/day, and would take approximately 140 days to reach 148° W.L. Based on this drift rate, EchoStar 8 would arrive at 148° W.L. around June 2012, and would become available for service after in-orbit testing. Finally, the Bureau asks for an explanation of DISH's proposal to relocate EchoStar 8 to 148° W.L. in light of EchoStar Corporation’s pending application for authority to transfer the EchoStar 8 satellite to QuetzSat S. de R.L. de C.V., and operate EchoStar 8 at the 77° W.L. orbital location under Mexican authority. EchoStar’s application to transfer EchoStar 8 to the QuetzSat entity is purely a result of the Mexican government requirements for operating a “foreign” satellite at a Mexican orbital slot. Once QuetzSat-1 is launched and in operation, it is DISH’s and QuetzSat’s intent to release EchoStar 8 from service at 77° W.L. so that it can be relocated to a U.S. orbital slot and operated under U.S. authority. QuetzSat-1 The Bureau asks for the current state of construction progress and the anticipated launch date for the QuetzSat-1 satellite. DISH understands, based on conversations with QuetzSat, that the current contract delivery for QuetzSat-1 from the manufacturer is July 2011. Quetzsat-1 is currently in its payload panel integration phase and is on schedule to meet the July 2011 factory completion date. The current launch window is November 2011.

Marlene H. Dortch May 10, 2010 Page 3 Please feel free to contact me with any questions regarding this submission. Sincerely, /s/ Pantelis Michalopoulos Counsel for DISH Operating L.L.C. cc: (via email) Robert Nelson, International Bureau Alyssa Roberts, International Bureau


Document Created: 2010-05-10 19:35:12
Document Modified: 2010-05-10 19:35:12
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