Attachment Hughes Network Syste

Hughes Network Syste

DECISION submitted by IB, FCC

Grant

2019-06-13

This document pretains to SAT-MOD-20190212-00011 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2019021200011_1731929

                                                                                  File #_SBT—MOD—20180212—Gooul
$3017
Piores   n tWSAkT-MOD-zo190212-00011       1B2019000315
 ughes    Network Systems, LLC
ECHOSTAR XXxIV                                                                    Call Sign S30NZ)_ Grant Date o6h3/ig
                                                                                  (or other identifier
                                                                                          $2e        )    Torm Dates   3C€             Approved by OMB
                                                                                  From_condifions               To:    condifions            3060—0678

     Date & Time Filed: Feb 12 2019 4:50:15:606PM          International Bureau   Approved:                                    lomme
    File Number: SAT—MOD—20190212—0001 1                   «uith conditions                                       nT.Dm[l
                                                                                                         Chief,Sabetlie Policy Branch
         FCC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AMD — MAIN FORM                                  _|FCC Use Only


                              FCC 312 MAIN FORM FOR OFFICIAL USE ONLY


     APPLICANT INFORMATION
     Enter a description of this application to identify it on the main menu:
     Modification of EchoStar XXIV to add spectrum bands and orbital debris plan
     1—8. Legal Name ofApplicant

                 Name:           Hughes Network Systems, LLC    Phone Number:                             301—428—5893
                 DBA                                            Fax Number:                               301—428—2818
                 Name:
                 Street:         11717 Exploration Lane         E—Mail:                                   jennifer.manner@echostar.com


                 City:           Germantown                     State:                                     MD
                 Country:        USA                            Zipcode:                                  20876        —
                 Attention:      Jennifer A Manner


                                     ATTACHMENT TO GRANT
                                     Hughes Network Systems, LLC
                  IBFS File Nos. SAT-LOA-20 170621-00092; SAT-AMD-20 170908-00128;
                                      SAT-MOD-20 190212-00011

IBFS File No(s):         SAT-LOA-20 170621-00092                                                       GRANT
                         SAT-AMD-20 170908-00128                                                    With Conditions
                         SAT-MOD-20 190212-00011
Licensee/Grantee:        Hughes Network Systems, LLC (Hughes)
Call Sign:               S3017
Satellite Name:          EchoStar XXIV (also known as HNS-95W or Jupiter 3)
Orbital Location:        95.2° W.L.
(required station-       (+1- 0.05 degrees east-west station-keeping)
keeping tolerance)                                                                         International Bureau
Administration:          United States of America                                             Satellite Division
Nature of Service:       Fixed-Satellite Service (FSS)
Scope of Grant:          Modification of authorization for EchoStar XXIV to: (1) operate using the 18.8-19.3 GHz
                         band for service in the United States; and (2) operate in additional frequencies at 28.6-29.1
                         GHz. Grant of Hughes’s previously deferred request for operations in the 50.4-51.4 GHz
                         frequency band.

Previous Grant(s):       Grant of authority to construct, deploy, and operate a geostationary orbit (GSO) space
                         station providing fixed-satellite service. Deferral of consideration of Hughes’s request for
                         operations in the 50.4-51.4 GHz frequency band and associated waiver. IBFS File Nos.
                         SAT-LOA-20170621-00092 and SAT-AMD-20170908-00128 (granted in part, deferred in
                         part, Mar. 20, 2018)’

Service Area(s):         North, South, and Central America. See IBFS File Nos. SAT-AMD-20170908-00 128,
  ,                      Schedule S Tech Report, HNS 95W isoline contour .gxt, and SAT-MOD-20190212-0001 1,
                         Schedule S Tech Report.
Frequencies:             18.3-18.8 GHz (space-to-Earth)
                         18.8-19.3 GHz (space-to-Earth)
                         19.7-20.2 GHz (space-to-Earth)
                         27.5-28.0 GHz (Earth-to-space)
                         28.1-28.6 GHz (Earth-to-space)
                         28.6-29.1 GHz (Earth-to-space)
                         29.3-29.9 GHz (Earth-to-space)
                         29.992-29.996 GHz (Earth-to-space)
                         40.0-42.0 GHz (space-to-Earth)
                         47.2-50.2 GHz (Earth-to-space)
                         50.4-51.4 GHz (Earth-to-space)

                         Telemetry, tracking, & command (‘TT&C) center frequencies:
                         20.197 GHz (space-to-Earth)
                         20.199 GHz (space-to-Earth)
                         29.993 GHz (Earth-to-space)
                         29.995 GHz (Earth-to-space)



‘We note that in Condition 18 of the original license grant, the Satellite Division required Hughes to provide an updated
orbital debris mitigation plan. See IBFS File Nos. SAT-LOA-20170621-00092 and SAT-AMD-20170908-00128. In its
modification application, Hughes has satisfied this condition by filing an updated orbital debris mitigation plan consistent
with Section 25.1 14(d)(14)(i)-(iv) of the Commission’s rules, 47 CFR § 25.1 14(d)(14)(i)-(iv). See IBFS File No. SAT
MOD-20190212-0001 1, Attachment A, Technical Annex.
                                                         Page 1 of 5


                                        ATTACHMENT TO GRANT
                                   Hughes Network Systems, LLC
                1BFS File Nos. SAT-LOA-20 170621-00092; SAT-AMD-20 170908-00128;
                                    SAT-MOD-20 190212-00011

Unless otherwise specified herein, operations under this grant must comport with the legal and technical
specifications set forth by the applicant or petitioner and with Federal Communication Commission’s rules
not waived herein. This grant is also subject to the following conditions:

    1.   Hughes must prepare the necessary information, as may be required, for submission to the International
         Telecommunication Union (ITU) to initiate and complete the advance publication, coordination, due
         diligence, and notification process of this space station, in accordance with the ITU Radio Regulations.
         Hughes will be held responsible for all cost-recovery fees associated with 1TU filings. No protection
         from interference caused by radio stations authorized by other administrations is guaranteed unless
         coordination and notification procedures are timely completed or, with respect to individual
         administrations, coordination agreements are successfully completed. Any radio station authorization for
         which coordination has not been completed may be subject to additional terms and conditions as required
         to effect coordination of the frequency assignments of other administrations. See 47 CFR § 25.111.
   2. In connection with the provision of service in any particular country, Hughes is obliged to comply with
      the applicable laws, regulations, rules, and licensing procedures of that country.
   3. Hughes must operate the EchoStar XXIV space station at the 95.2° W.L. orbital location in compliance
      with all existing or future coordination agreements for this location.
   4.    Hughes must maintain the EchoStar XXIV space station within an eastlwest longitudinal station-keeping
         tolerance of +I~ 0.05 degrees of the 95.2° W.L. orbital location.
   5.    Operations of the EchoStar XXIV space station and associated earth stations must comport with the
         applicable uplink and downlink limits in 47 CFR § 25.140(a)(3) of the Commission’s rules, unless
         Hughes coordinates any non-conforming operations with the operations of U.S.-licensed geostationary
         orbit space stations within 6 degrees of the 95.2° W.L. orbital location. Non-conforming operation must
         also be coordinated with respect to those operations of non-U.S.-licensed space stations within 6 degrees
         of 95.2° W.L. involving approved communications with U.S.-licensed earth stations.
   6.    Operations in the 18.3-19.3 GHz and 19.7-20.2 GHz frequency bands must complete coordination with
         U.S. Federal systems, in accordance with footnote US334 to the United States Table of Frequency
         Allocations, 47 CFR § 2.106, prior to being used. Operations in the 18.3-19.3 GHz and 19.7-20.2 GHz
         bands must be in accordance with any signed coordination agreement reached between Hughes and U.S.
         Federal operators. Two weeks prior to the start of any operations in the 18.3-19.3 GHz or 19.7-20.2 GHz
         bands, Hughes must provide contact information for a 24/7 point of contact for the resolution of any
         harmful interference to Jimmy Nguyen, Email: Jimmy.Nguyen@us.af.mil.
   7. The power flux-density (PFD) at the Earth’s surface produced by the emissions from the EchoStar XXIV
      space station, in the 18.3-19.3 GHz, 19.7-20.2 GHz, and 40.0-42.0 GHz frequency bands (space-to
      Earth), must not exceed the applicable power flux-density limits contained in Sections 25.138(a)(6),
      25.140(a)(3)(iii), and 25.208, and in Article 21 of the ITU Radio Regulations.
   8.    Operations of the EchoStar XXIV space station in the 18.8-19.3 GHz (space-to-Earth) and 28.6-29.1 GHz
         (Earth-to-space) frequency bands must not cause harmful interference to, or claim interference protection
         from, primary NGSO FSS systems licensed in the United States. Hughes must terminate operations
         immediately upon notification of harmful interference.
    1.   No later than sixty days before the scheduled initial launch of each NGSO FSS satellite system licensed
         in the United States to operate in the 18.8-19.3 GHz (space-to-Earth) and 28.6-29.1 GHz (Earth-to-space)
         frequency bands, Hughes must either: (1) notify the Commission in writing when an agreement has been
         reached with the NGSO satellite system operator, or (2) seek and obtain the Commission’s approval of a
         modification of this license including detailed technical demonstrations of how Hughes will protect the
         NGSO FSS satellite system. If neither condition is met, Hughes must cease operations in the 18.8-19.3
                                                    Page 2 of 5


                                           ATTACHMENT TO GRANT
                                    Hughes Network Systems, LLC
                 1BPS File Nos. SAT-LOA-20 170621-00092; SAT-AMD-20 170908-00128;
                                     SAT-MOD-20 190212-00011

         GHz and 28.6-29.1 0Hz frequency bands pursuant to this license until such time as compliance is
         demonstrated.2 With respect to any NOSO FSS system licensed or granted market access in the United
         States that conm~iences operations prior to the scheduled launch of EchoStar XXIV, Hughes must comply
         with either (1) or (2) above and must not commence operations in the 18.8-19.3 0Hz and 28.6-29.1 0Hz
         frequency bands pursuant to this license until such time as compliance is demonstrated.
    9.   Operations of the EchoStar XXIV space station in the 27.5-28.35 0Hz (Earth-to-space) frequency band
         are secondary with respect to Upper Microwave Flexible Use Service (UMFUS) operations, except for
         FSS operations associated with earth stations authorized pursuant to 47 CFR § 25.136 and will comply
         with any determinations set forth in the Spectrum Frontiers Proceeding (ON Docket 14-177).
    10. The 29.25-29.5 0Hz band is designated for uplinks for FSS systems using geostationary satellites and for
        feeder uplinks for Mobile Satellite Systems using non-geostationary orbit satellites on a co-primary basis.
        Communications between U.S.-licensed earth stations and the EchoStar XXIV space station in the 29.3-
        29.5 0Hz band must comply with Section 25.258 of the Commission’s rules. 47 CFR § 25.258.
    11. In accordance with footnote US211 to 47 CFR § 2.106, Hughes is urged to take all practicable steps to
        protect radio astronomy observations in the adjacent bands from harmful interference from its operations
        in the 40.0-42.0 0Hz band.
    12. Operations of the EchoStar XXIV space station in the 40.0-40.5 0Hz frequency band must be
        successfully coordinated with Federal Space Research Service (SRS) facilities, pursuant to
        Recommendation ITU-R SA.1396, “Protection Criteria for the Space Research Service in the 37-38 GHz
        and 40.0-40.5 0Hz Bands.”
    13. Operations in the 47.2-48.2 0Hz band must provide interference protection to the fixed and mobile
        services, except as authorized pursuant to 47 CFR § 25.136.
    14. Any future grant of earth station licenses for operations with the EchoStar XXIV space station will be
        subject to the following condition, unless the condition is satisfied prior to such license grant: in the
        48.94-49.04 0Hz band, operations must be coordinated with radio astronomy stations operating on a co
        primary basis in this band. 47 CFR § 2.106, footnote US342.
    15. Any future grant of earth station licenses for operations with the EchoStar XXIV space station will be
        subject to the following condition: Hughes’s earth station emissions into the 50.2-50.4 0Hz band must
        comport with the limits contained in ITU-R Resolution 750 (REV. WRC-15) andJor footnote US 156 to
        Section 2.106 of the Commission’s rules, 47 CFR §2.106, footnote US 156, including any future revisions
        of footnote US 156 to Section 2.106. Such revisions may be introduced either because of modifications
        that may be approved by WRC-19 to Resolution 750, or as a result of a Commission rulemaking




2 O3b Limited supports addition of this condition in order to ensure that NGSO systems, such as 03b’s system, are protected
in the 18.8-19.3 GHz and 28.6-29.1 0Hz bands, which are allocated to NGSO systems on a primary basis in the United
States. See generally, Comments of O3b Limited (filed Apr. 15, 2019). Hughes opposes this condition. See Letter from
Jennifer A. Manner, Senior Vice President, Regulatory Affairs, Hughes Network Systems, LLC, to Marlene H. Dortch,
Secretary, FCC, dated May 3, 2019 (May 2019 Ex Parte). First, we will consider Hughes’ May 2019 Ex Parte, even though
it was late-filed pursuant to Section 25.154(c) (responses must be filed within 10 days of the petitions to deny or comments).
47 CFR § 25.154(c). Second, we decline Hughes’ request to omit this condition from the EchoStar XXIV grant because this
condition helps to ensure that GSO systems, which are secondary in these bands, protect the primary NGSO systems. This
condition has also been placed on a prior grant of a GSO satellite seeking authority to operate in the 18.8-19.3 0Hz and 28.6-
29.1 GHz bands. See Intelsat License LLC, IBFS File Nos. SAT-LOA-20170524-00078 & SAT-AMD-201706l3-00086
(grant stamp, re-issued June 26, 2018).
                                                        Page 3 of 5


                                           ATTACHMENT TO GRANT
                                     Hughes Network Systems, LLC
                  LBFS File Nos. SAT-LOA-20 170621-00092; SAT-AMD-20 170908-00128;
                                      SAT-MOD-20 190212-00011

         proceeding, independent of any 1TU deliberation.
     16. Hughes’ request for authority to use the 50.4-5 1.4 GHz band for gateway uplinks is granted, subject to
         the limitations imposed by Section 25.136 of the Commission’s rules, as modified by the Spectrum
         Frontiers Fifth Report and Order.3
     17. Hughes’ request for waiver of 47 CFR § 25.202(a)(1), concerning the availability of the 50.4-5 1.4 GHz
         band for FSS, IS DISMISSED AS MOOT. This band is allocated in the U.S. Table of Frequency
         Allocations to the FSS, but at the time Hughes filed its application the 50.4-51.4 GHz band was not listed
         among the available frequencies for FSS in Section 25.202(a)(1) of the rules. The Commission
         subsequently removed the list of frequencies in Section 25.202(a)(1) as unnecessary, thereby eliminating
         this barrier against applying for FSS use of the frequencies in the 50.4-51.4 GHz band.
     18. Prior to commencing operations with the EchoStar XXIV space station, Hughes must file with the
         Commission the information required by Section 25.172 of the Commission’s rules, 47 CFR § 25.172.
     19. Hughes request for a waiver of Section 25.114(c)(4)(vii) of the Commission’s rules, 47 CFR §
         25.1 14(c)(4)(vii), IS GRANTED. In response to a request from the Commission for additional
         information regarding its application, Hughes provided a revised isoline diagram and amended its
         Schedule S accordingly. We find that this showing, along with the other technical information provided
         with its application, is sufficient to support a waiver.
    20. Hughes request for a waiver of footnote NG165 Section 2.106 of the Commission’s Rules IS
        DISMISSED as MOOT. GSO operations in this band are permitted on a secondary basis. 47 CFR §
        2.106.
    21. Hughes request for a waiver of Section 25.156(d)(5) of the Commission rules, 47 CFR § 25.156(d)(5), IS
        DISMISSED as MOOT. Section 25.156(d)(5) stated that in bands where the Commission has not
        adopted frequency-band specific service rules it will not consider applications for GSO-like operation
        after it has granted an application for NGSO-like operation in the same band, and vice versa, unless and
        until the Commission establishes NGSO/GSO sharing criteria for that frequency band. However, the
        Commission recently eliminated Section 25.156(d)(5) in a rulemaking4 and those rules are now in effect
        making a waiver of the rule unnecessary.
    22. Hughes request for a waiver of the NGSO FSS Cut-off deadline for applications in the V-band IS
        DISMISSED as MOOT. By its own terms the application deadline of which Hughes requested a waiver
        applied only to NGSO FSS systems.5 Consequently the EchoStar XXIV space station, a GSO-like
        system, was not covered by the filing deadline making a waiver unnecessary.
    23. Hughes’s request for a waiver of the application processing rules of Sections 25. 156(d)(3) and (4) of the
        Commission’s rules, 47 CFR § 25.156(d)(3)-(4), IS DISMISSED as MOOT. Section 25.156(d)(3)
        requires the Commission to consider applications covering multiple service bands as separate applications
        for each band. As all the frequency bands requested by Hughes are addressed in this grant, no waiver of
        Section 25.1 56(d)(3) is necessary. Section 25.1 56(d)(4) requires that applications for feeder-link



~ See generally, Use of Spectrum Bands Above 24 GHzfor Mobile Radio Services et. al., Fifth Report and Order, FCC 19-30,
paras. 8-12 (rel. Apr. 15, 2019).
~ Update to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and Related Matters, Report and
Order and Further Notice of Proposed Rulemaking, 32 FCC Rcd 7809, 782 1-22, para. 39 (2017).
~ Cut-off Establishedfor Additional NGSO-Like Satellite Applications or Petitions for Operations in the 37.5-40.0 GHz, 40.0-
42.0 GHz, 47.2 -50.2 GHz, and 50.4 -51.4 GHz Bands, Public Notice, 31 FCC Rcd 11957 (lB 2016).
                                                       Page 4 of 5


                                           ATTACHMENT TO GRANT
                                     Hughes Network Systems, LLC
                  IBFS File Nos. SAT-LOA-20 170621-00092; SAT-AMD-20 170908-00128;
                                      SAT-MOD-20 190212-00011

          authority be treated as an application separate from associated service bands. However, as an FSS system
          EchoStar XXIV by definition does not have feeder links6 making waiver of Section 25.156(d)(4)
          unnecessary.
      24. Hughes must post a surety bond in satisfaction of 47 CFR §~ 25.165(a)(2) & (b) no later than April 19,
          2018, and thereafter maintain on file a surety bond requiring payment in the event of a default in an
          amount, at minimum, determined according to the formula set forth in 47 CFR § 25.165(a)(2); and
          Hughes must launch the space station, position it in its assigned orbital location, and operate it in
          accordance with the station authorization no later than March 20,2023,47 CFR § 25.164(a).
          This authorization will be null and void automatically, without further Commission action if Hughes fails
          to comply with any of these requirements. Failure to comply with the milestone requirement of 47 CFR §
          25.164(a) will also result in forfeiture of Hughes’s surety bond. By April 3, 2023, Hughes must either
          demonstrate compliance with its milestone requirement or notify the Commission in writing that the
          requirement was not met. 47 CFR § 25.164(f).
      25. The license term for the EchoStar XXIV space station is 15 years and will begin on the date that Hughes
          certifies to the Commission that EchoStar XXIV has been successfully placed into orbit and its operations
          fully conform to the terms and conditions of this authorization. Hughes is directed to file its certification
          of commencement of operation with the Commission within five business days of EchoStar XXIV being
          placed into operation at the 95.2° W.L. orbital location.


Licensee/grantee is afforded thirty (30) days from the date of release of this action to decline the grant as
conditioned. Failure to respond within this period will constitute formal acceptance of the grant as conditioned.

This action is taken pursuant to Section 0.26 1 of the Commission’s rules on delegated authority, 47 C.F.R. §
0.26 1, and is effective upon release.

Station licenses are subject to the conditions specified in Section 309(h) of the Communications Act of 1934, as
amended, 47 U.S.C. § 309(h).

Action           June 13, 2019
Date:
Term Dates       From: see conditions                 To: see conditions

Approved:



                 Step e    .Duall
                 Chief, Satellite Policy Branch




647   CFR § 25.103.

                                                      Page 5 of 5


9—16. Name of Contact Representative

                Name:          Hughes Network Systems, LLC           Phone Number:                        301—428—5893
                Company:                                             Fax Number:                          301—428—2818
                Street:        11717 Exploration Lane                E—Mail:                              jennifer.manner@echostar.com


                City:          Germantown                             State:                              MD
                Country:        USA                                  Zipcode:                             20876—
                Attention:                                           Relationship:


CLASSIFICATION OF FILING
    17. Choose the button next to the
    classification that applies to this filing for   (N/A) bI. Application for License of New Station
    both questions a. and b. Choose only one         (N/A) b2. Application for Registration of New Domestic Receive—Only Station
    for I 7a and only one for I 7b.                   0  b3. Amendment to a Pending Application
                                                          b4. Modification of License or Registration
       0   al. Earth Station                         b5. Assignment of License or Registration
                                                             .            .



       • a2. Space Station                           b6. Transfer of Control of License or Registration
                                                      0   b7. Notification of Minor Modification
                                                      (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed
                                                     Satellite
                                                      (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United
                                                     States
                                                      (N/A) blO. Other (Please specif~’)
                                                        (N/A) bI 1. Application for Earth Station to Access a Non—U.S.satellite Not Currently Authorized
                                                     to Provide the Proposed Service in the Proposed Frequencies in the United States
                                                        (N/A) bI 2. Application for Database Entry
                                                      0   b13. Amendment to a Pending Database Entry Application
                                                      0   b14. Modification of Database Entry


2


   1 7c. Is a fee submitted with this application?
• If Yes, complete and attach FCC Form 159.            If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
0       Governmental Entity       ~ Noncommercial educational licensee
O       Other(please explain):
I 7d.

Fee Classification BFY        —   Space Station Modification(Geostationary)




18. If this filing is in reference to an          19. If this filing is an amendment to a pending application enter both fields, if this filing is a
existing station, enter:                          modification please enter only the file number:
(a) Call sign of station:                         (a) Date pending application was filed:              (b) File number:
        S3017
                                                                                                       SATLOA20 17062100092


TYPE OF SERVICE
20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply:

    a. Fixed Satellite
    b. Mobile Satellite

EJ c. Radiodetermination Satellite
Q d. Earth Exploration Satellite
EJ e. Direct to Home Fixed Satellite
EJ f. Digital Audio Radio Service
EJ g. Other (please specify)
21. STATUS: Choose the button next to the applicable status. Choose      22. If earth station applicant, check all that apply.
only one.                                                                EJ   Using U.S. licensed satellites
0   Common Carrier          Non—Common Carrier                                Using Non—U.S. licensed satellites

23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these
facilities:
o Connected to a Public Switched Network         0   Not connected to a Public Switched Network            N/A
  24. FREQUENCY BAND(S): Place an ‘X’ in the box(es) next to all applicable frequency band(s).
Q a. C—Band (4/6 GHz) Q b. Ku—Band (12/14 GHz)
     c.Other (Please specify upper and lower frequencies in MHz.)
        Frequency Lower: 18300             Frequency Upper: 51400             (Please specify additional frequencies in an attachment)


TYPE OF STATION
25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one.

 o a. Fixed Earth Station
 o b. Temporary—Fixed Earth Station
 o c. 12/14 GHz VSAT Network
 o d. Mobile Earth Station
 • e. Geostationary Space Station
 o ~ Non—Geostationary Space Station
 o g. Other (please specify)
26. TYPE OF EARTH STATION FACILITY:
o   Transmit/Receive ~ Transmit—Only            ~ Receive—Only     • N/A
“For Space Station applications, select N/A.”


PURPOSE OF MODIFICATION


27. The purpose of this proposed modification is to: (Place an ‘X’ in the box(es) next to all that apply.)


    EJ a     —    authorization to add new emission designator and related service
    EJ b     —    authorization to change emission designator and related service
    EJ c     —    authorization to increase EIRP and EIRP density
    EJ d     —    authorization to replace antenna
    EJ e     authorization to add antenna
             —

         f—— authorization to relocate fixed station
         g   ——   authorization to change frequency(ies)
         h   —     authorization to add frequency
         i   ——   authorization to add Points of Communication (satellites & countries)

     EJ ~ authorization to change Points of Communication (satellites & countries)
             ——



     EJ k authorization for facilities for which environmental assessment and
             —

radiation hazard reporting is required
     EJ I authorization to change orbit location
             ——



     EJ m authorization to perform fleet management
             ——



     EJ n authorization to extend milestones
             —

         o   —     Other (Please specify)


ENVIRONMENTAL POLICY


28. Would a Commission grant of any proposal in this application or amendment have a significant environmental          o Yes     No
impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of
the Commission’s rules, 47 C.F.R. 1.1308 and 1.1311, as an exhibit to this application.A Radiation Hazard Study
must accompany all applications for new transmitting facilities, major modifications, or major amendments.



ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or
aeronautical fixed radio station services are not required to respond to Items 30—34.


29. Is the applicant a foreign government or the representative of any foreign government?                              0   Yes   No




 30. Is the applicant an alien or the representative of an alien?                                                       o   Yes   No    N/A




 31. Is the applicant a corporation organized under the laws of any foreign government?                                     Yes   No    N/A




 32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by    o   Yes    No   N/A
 aliens or their representatives or by a foreign government or representative thereof or by any corporation organized
 under the laws of a foreign country?


33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than          o   Yes         No    N/A
one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign
government or representative thereof or by any corporation organized under the laws of a foreign country?



34. If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or
foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote.



BASIC QUALIFICATIONS


35. Does the Applicant request any waivers or exemptions from any of the Commission’s Rules?                                  0 Yes            No
If Yes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.




36. Has the applicant or any party to this application or amendment had any FCC station authorization or license                    Yes    Q   No
revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or
construction permit denied by the Commission? If Yes, attach as an exhibit, an explination of circumstances.
                                                                                                                          Exhibit 2


37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling        o Yes     No
the applicant ever been convicted of a felony by any state or federal court? If Yes, attach as an exhibit, an
explination of circumstances.




38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant,                Yes   No
guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication, directly or
indirectly, through control of manufacture or sale of radiQ apparatus, exclusive traffic arrangement or any other
means or unfair methods of competition?If Yes, attach as an exhibit, an explanation of circumstances




39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending       o Yes     No
matter referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the circumstances.




40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names,
address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer’s
voting stock and the percentages so held. In the case of fiduciary control, indicate the beneficiary(ies) or class of    Exhibit 3
beneficiaries. Also list the names and addresses of the officers and directors of the Filer.


41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is                Yes          No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of
1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See
47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes.



42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? If Yes,        0   Yes          No
answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate. If No,
proceed to question 43.




42b. What administration has licensed or is in the process of licensing the space station? If no license will be issued, what administration has
coordinated or is in the process of coordinating the space station?United States



43. Description. (Summarize the nature of the application and the services to be provided).    (If the complete description does not appear in this
box, please go to the end of the form to view it in its entirety.)
    Applicant seeks to modify EchoStar XXIV license to    1) add spectrum at 28.6-29.1 GHz for
                                                                                   -


     FSS feeder uplinks; 2) add spectrum at 18.8-19.3 GHz for FSS downlinks to user terminals
     in the U.S.; and 3) provide an updated description of the orbital debris mitigation plan.
     See Exhibit 1.
Exhibit I


43a. Geographic Service Rule Certification
By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25.

By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements.
                                                                                                                              OC
By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25 and will not comply with such requirements because it is not
feasible as a technical matter to do so, or that, while technically feasible, such services would require so many
compromises in satellite design and operation as to make it economically unreasonable. A narrative description
and technical analysis demonstrating this claim are attached.
                                                                                                                              A


CERTIFICATION
The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the
United States because of the previous use of the same, whether by license or otherwise, and requests an authorization in accordance with this
application. The applicant certifies that grant of this application would not cause the applicant to be in violation of the spectrum aggregation limit
in 47 CFR Part 20. All statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application.
The undersigned, individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are
true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.


44. Applicant is a (an): (Choose the button next to applicable response.)


0    Individual
0    Unincorporated Association
o Partnership
0    Corporation
o Governmental Entity
• Other (please specify)




    45. Name of Person Signing                                              46. Title of Person Signing
    Jennifer A. Manner                                                      Senior Vice President, Regulatory Affairs
       ——>




             WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                      (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                    (U.S. Code, Title 47, Section 312(a)(I)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


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Remember You are not required to respond to a collection of information sponsored by the Federal government, and the government may not
           —


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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104-13, OCTOBER
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Document Created: 2019-06-13 17:18:00
Document Modified: 2019-06-13 17:18:00

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