Attachment Narrative

This document pretains to SAT-MOD-20140623-00074 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2014062300074_1051737

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) EchoStar Satellite Operating Corporation ) Call Sign S2232 ) Application for Modification to Extend the ) File No. SAT-MOD-201406 - Term of the EchoStar 6 License ) APPLICATION FOR MODIFICATION TO EXTEND LICENSE TERM EchoStar Satellite Operating Corporation (“EchoStar”) applies for a five-year plus extension, through January 31, 2019, of the license for its EchoStar 6 satellite (Call Sign S2232) at 96.2º W.L.1 Grant of this application, coupled with grant of EchoStar’s pending application to operate the satellite at 96.2º W.L. on a regular basis, will serve the public interest by allowing EchoStar and its development partner to continue developing new markets and innovative satellite video distribution services to a diverse array of customers, including the maritime industry, in underserved markets in the Atlantic Ocean region, including Bermuda, the Caribbean, and Latin America. The satellite was launched in July 2000 with an originally estimated useful life of 12 years. In December 2000, the Commission extended the satellite’s license term until August 11, 2014, consistent with EchoStar’s then-current estimated fuel consumption, business plans, and other considerations.2 The satellite has served as an important component of the EchoStar network, providing direct broadcast satellite (“DBS”) service to U.S. consumers (via DISH 1 EchoStar also has a pending modification application to operate EchoStar 6 96.2º W.L. on a regular basis. See EchoStar Modification Application, File No. SAT-MOD-20130227-00026 (Feb. 27, 2013). 2 See Stamp Grant, File No. SAT-MOD-20100720-00164 (granted Dec. 2, 2010) (“License Extension Grant”). 1

Network) prior to its relocation to its current orbital location at 96.2º W.L. Pursuant to a special temporary authorization (“STA”) granted on April 1, 2013,3 EchoStar 6 was successfully repositioned to 96.2º W.L. on April 13 and has been in operation there since then. EchoStar and its development partner have commenced commercial development activities to leverage this asset to serve consumers in the Atlantic Ocean region.4 The requested license term extension is warranted under the circumstances. On February 7, 2014, EchoStar filed a supplemental notice stating that EchoStar commenced EchoStar 6’s inclined orbit operation on December 12, 2011, and has allowed the inclination to grow naturally (at a rate of approximately 0.8º per year) in order to preserve fuel and extend the satellite’s useful life.5 Based on the amount of fuel remaining for continued operations at 96.2º W.L., including sufficient remainder to achieve a disposal orbit approximately 300 km above geosynchronous altitude, internal projections demonstrate that EchoStar 6 can provide reliable service throughout the requested license term extension.6 Additionally, EchoStar affirms that: (1) the spacecraft has no single points of failure; (2) all subsystems on the spacecraft are operating normally; (3) one 17 GHz and two 14 GHz command receivers on the spacecraft are available for TT&C functions;7 and (4) EchoStar has no plans to move the spacecraft from the nominal 96º W.L. orbital location during the requested license term extension. Moreover, the proposed modification will not result in any changes to 3 See EchoStar Satellite Operating Company, Order and Authorization, 28 FCC Rcd 4229 (IB April 1, 2013). 4 On July 9, 2013, the Commission issued an order upholding the STA grant and denying Spectrum Five LLC’s application for review. See EchoStar Satellite Operating Company, Memorandum Opinion and Order, 28 FCC Rcd 10412 (2013). 5 See Letter from Jennifer A. Manner, EchoStar, to Marlene H. Dortch, File Nos. SAT-MOD-20130227- 00026 et al., at 1 (Feb. 7, 2014). 6 See id. at 2. 7 The spacecraft’s other 17 GHz command receiver failed on March 8, 2010. 2

the spacecraft’s operating characteristics or to the interference environment, and thus a new Schedule S is not required to be submitted.8 The requested license term extension, along with grant of EchoStar’s separate request for authority to operate at 96.2º W.L. on a regular basis, will serve the public interest by enabling EchoStar ultimately to provide new and innovative services to consumers in the Atlantic Ocean region. It also will provide EchoStar with the regulatory certainty required to fully develop a business serving the Caribbean, North American (outside of the United States), and South American markets. For the foregoing reasons, EchoStar respectfully requests that the Commission extend the license term for EchoStar 6 through January 31, 2019. Respectfully submitted, /s/ Jennifer A. Manner Jennifer A. Manner Vice President, Regulatory Affairs EchoStar Satellite Operating Corporation 11717 Exploration Lane Germantown, MD 20876 301-428-5893 jennifer.manner@echostar.com June 19, 2014 8 See, e.g., DIRECTV Modification Application, Stamp Grant, File No. SAT-MOD-20140127-00010 (granted Apr. 24, 2014). 3


Document Created: 2014-06-23 15:24:24
Document Modified: 2014-06-23 15:24:24
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