Attachment Narrative SAT-MOD-20120124-00011

Attachment Narrative

This document pretains to SAT-MOD-20120124-00011 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2012012400011_936398

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

)
In the Matter of )
)
DISH OPERATING L.L.C. )
) File No. SAT-______________
Application for Renewal of Authority to ) Call Sign S2740
Operate EchoStar 7 at 119° W.L. )
)
)

APPLICATION FOR RENEWAL OF AUTHORITY TO OPERATE
ECHOSTAR 7 AT 119° W.L.

Pursuant to Sections 308 , 309, and 319 of the Communications Act of 1934, as

amended,1 and Part 25 of the Commission’s rules,2 DISH Operating L.L.C. (“DISH”) hereby

files this application3 to renew its authority to operate its Direct Broadcast Satellite (“DBS”),

EchoStar 7, at the nominal 119° W.L. orbital location until April 22, 2022.

I. BACKGROUND

The Commission originally granted DISH’s predecessor in interest, EchoStar Satellite

Corporation, authority to operate EchoStar 7 at the 119° W.L. orbital location on January 16,

2002 using channels 1-21.4 Although the EchoStar 7 Order does not state a license expiration

1
47 U.S.C. §§ 308, 309, and 319.
2
47 C.F.R. Part 25.
3
This application qualifies as a minor modification because it proposes no change to
orbital location or authorized frequencies, nor will it increase the potential for interference.
Rather, DISH is requesting renewal of its authority to continue to operate EchoStar 7 at the
nominal 119° W.L. orbital location.
4
See EchoStar Satellite Corporation, Order and Authorization, 17 FCC Rcd. 894 (2002)
(“EchoStar 7 Order”).

date, Section 25.121(a)(2) of the Commission’s rules provides that “[l]icenses for DBS space

stations not licensed as broadcast facilities will be issued for a period of 10 years.”5 For

geostationary space stations, the license term begins “on the date the licensee certifies to the

Commission that the satellite has been successfully placed into orbit and that the operations of

the satellite fully conform to the terms and conditions of the space station radio authorization.”6

EchoStar 7 commenced operations at the 119° W.L. orbital location on April 22, 2002.

Because the original EchoStar 7 license expires on April 22, 2012, DISH requests a

renewal of this license to continue to operate EchoStar 7 at the nominal 119° W.L. orbital

location for another ten years until April 22, 2022. The current predicted end of life for the

EchoStar 7 satellite, based upon the remaining fuel and projected operational parameters, is May

2022. The EchoStar 7 satellite is currently stationed at 118.8° W.L. pursuant to Special

Temporary Authority.7 DISH’s application for minor modification of authority to allow

operation of the EchoStar 7 satellite at 118.8° W.L. on a permanent basis remains pending, and is

hereby incorporated by reference into this renewal application.8 In the event that the

5
47 C.F.R. § 25.121(a)(2).
6
Id. § 25.121(d)(1).
7
See Stamp Grant, File No. SAT-STA-20110804-00144 (granted Sept. 21, 2011).
8
See File Nos. SAT-MOD-20100329-00058 (filed Mar. 29, 2010); SAT-AMD-
20100610-00127 (filed June 10, 2010). DISH submitted an orbital debris mitigation plan for
EchoStar 7, and requested a limited waiver of the Commission’s orbital debris mitigation rules
because as a result of “the design of the spacecraft bus by the satellite manufacturer, . . . the
small amount of oxidizer remaining in the oxidizer tanks of the spacecraft at end-of-mission
cannot be vented. Instead . . . this residual oxidizer will be securely sealed using pyrotechnic
valves upon the completion of the satellite’s transfer to its disposal orbit, and stored under
conditions that would make even a leak extremely unlikely, and an accidental, post-mission
explosion more unlikely still.” File No. SAT-AMD-20100610-00127, Narrative at 3 (filed June
10, 2010).

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Commission grants DISH’s minor modification application, DISH requests that this renewal

application be granted for EchoStar 7 at the 118.8° W.L. orbital location.

The requested renewal will serve the public interest by enabling DISH to continue

providing high-quality DBS services to its customers from the nominal 119° W.L. orbital

location. Indeed, DISH’s ability to compete in this market would be seriously impaired without

the continued ability to provide service from the 119° W.L. nominal orbital location. As the

Commission is well aware, DISH has provided continuous DBS service from its various orbital

locations since 1996, and is now a leading multichannel video programming distributor with its

customer, DISH Network L.L.C., providing service to over 14 million subscribers.

II. CONCLUSION

For the foregoing reasons, DISH respectfully requests that the Commission grant this

application for a minor modification to extend the expiration date of the EchoStar 7 license to

April 22, 2022.

Respectfully submitted,

DISH Operating L.L.C.

_________/s/_____________________
Pantelis Michalopoulos Alison Minea
Stephanie A. Roy Corporate Counsel
L. Lisa Sandoval DISH Operating L.L.C.
Steptoe & Johnson LLP 1110 Vermont Avenue NW, Suite 750
1330 Connecticut Avenue N.W. Washington, DC 20005
Washington, D.C. 20036 (202) 293-1216
(202) 429-3000
Counsel for DISH Operating L.L.C.

January 24, 2012

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Document Created: 2012-01-24 19:44:55
Document Modified: 2012-01-24 19:44:55

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