Attachment Narrative

This document pretains to SAT-STA-20100219-00033 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010021900033_802273

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) ) In the Matter of ) ) DISH OPERATING L.L.C. ) ) Application for Special Temporary Authority ) File No. SAT-STA-20100219-_____ to Operate the EchoStar 14 Satellite at ) 118.9° W.L. ) ) ) ) APPLICATION FOR SPECIAL TEMPORARY AUTHORITY DISH Operating L.L.C. (“DISH”) respectfully requests 60-day Special Temporary Authority (“STA”), beginning on May 1, 2010, to operate its EchoStar 14 satellite at 118.9 W.L. on the 21 Direct Broadcast Satellite (“DBS”) channels already licensed to DISH at the 119º W.L. nominal orbital location in accordance with the specifications described in its application for full authority.1 Along with this application, DISH is filing an application for 60-day STA to launch and test EchoStar 14 at 138.5 W.L. and to relocate the satellite to 118.9 W.L. once testing is complete.2 1 See File No. File No. SAT-LOA-20090518-00053, Call Sign S2790 (filed May 18, 2009); amended by File Nos. SAT-AMD-20090604-00064 (filed June 4, 2009) (“EchoStar 14 Application”); SAT-AMD-20100212-00027 (filed Feb. 12, 2010) (“Amendment Application”). 2 See File No. SAT-STA-20100219-_____ (“Launch STA”). DISH is filing simultaneous with this application a request for STA to relocate EchoStar 7 to 118.8 W.L. File No. SAT- STA-20100219-_____. Action on this request would be necessary only if the Commission has not acted on the EchoStar 14 Application by May 1, 2010.

I. GRANT OF THIS APPLICATION IS IN THE PUBLIC INTEREST On May 18, 2009, DISH filed an application for a minor modification of its DBS authorization, and authority to launch and operate its EchoStar 14 satellite at 118.9º W.L.3 On February 12, 2010, DISH filed a minor amendment to update the predicted cross-polar isolation values provided in the EchoStar 14 Application as a result of the tests recently conducted by the satellite manufacturer.4 EchoStar 14 will allow DISH to improve and expand its services from the 119 W.L. orbital location. For the same reasons described in that application and incorporated herein by reference, so too will the requested STA serve the public interest. The “CONUS-plus” capability of EchoStar 14 will increase DISH’s capacity to provide High Definition programming to subscribers, and its advanced spot-beam technology will enhance DISH’s ability to provide local-into-local stations across the country. The requested STA will ensure DISH is able to bring the technically advanced satellite into service as soon as possible to improve the services available to its customers if its pending application is still under consideration at the time. The proposed operations will not increase interference into any other operator because the only satellite operating at the 119° W.L. orbital location that may be affected is DISH’s own EchoStar 7 satellite as demonstrated in the Technical Narratives submitted with the EchoStar 14 Application and the Amendment Application. II. TECHNICAL REQUIREMENTS OF PART 25 The technical information for the EchoStar 14 satellite required to be submitted pursuant to Part 25 of the Commission’s Rules was set forth in the Technical Narrative, FCC Form 312, 3 See EchoStar 14 Application. 4 See Amendment Application. -2-

and Schedule S of DISH’s EchoStar 14 Application and in the Technical Narrative submitted with its Amendment Application, and is incorporated herein by reference. III. CONCLUSION For the foregoing reasons, DISH respectfully requests that the Commission grant special temporary authority to operate the EchoStar 14 satellite at 118.9 º W.L. While EchoStar 14 is operating at 118.9 W.L. it will abide by the following conditions: 1. All operations at 118.9 W.L. shall be on a non-harmful interference basis, meaning that DISH shall not cause inference to, and shall not claim protection from, interference caused to it by any other lawfully operating satellites. 2. In the event that any harmful interference is caused while the satellite is operating at 118.9 W.L., DISH shall cease operations immediately upon notification of such interference and shall inform the Commission, in writing, of such event. Respectfully submitted, DISH Operating L.L.C. _________/s/_____________________ Pantelis Michalopoulos Linda Kinney Petra A. Vorwig Vice President, Law and Regulation 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) 293-0981 (202) 429-3000 Counsel for DISH Operating L.L.C. February 19, 2010 -3-


Document Created: 2010-02-19 18:24:34
Document Modified: 2010-02-19 18:24:34
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