Attachment Narrative

This document pretains to SAT-STA-20100901-00189 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010090100189_838010

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

                                                 )
                                                 )
In the Matter of                                 )
                                                 )
ECHOSTAR CORPORATION                             )   Call Sign 2741
                                                 )
Application to Renew its Special Temporary       )   File No. SAT-STA-20100615-00135
Authority to Operate EchoStar 3 as an            )   File No. SAT-STA-20100803-00173
In-Orbit Spare at 61.45º W.L.                    )   File No. SAT-STA-2010__________
                                                 )
                                                 )


      APPLICATION FOR RENEWAL OF SPECIAL TEMPORARY AUTHORITY

       By this Application, EchoStar Corporation (“EchoStar”) requests renewal of its special

temporary authority (“STA”) for an additional 30 days to operate the EchoStar 3 satellite at

61.45º W.L. as an in-orbit spare. Pursuant to the Commission’s authorization, EchoStar moved

the satellite to that orbital location on July 10, 2010 to accommodate EchoStar 15,1 and the

current STA to operate there expires on September 5, 2010.2

       As the Commission is aware, on July 10, 2010, EchoStar successfully launched EchoStar

15, a 32-transponder-capable Direct-Broadcast Satellite (“DBS”) satellite that, in light of the loss

of AMC-14, will effectively replace EchoStar 3.3 The satellite became fully operational on

August 5, 2010. To accommodate testing and operation of EchoStar 15 at 61.55 W.L. and the

concurrent and efficient operation of EchoStar’s other satellites at the nominal 61.5 W.L. orbital


       1
           See Stamp Grant, File No. SAT-STA-20100615-00135 (granted July 7, 2010).
       2
        See Stamp Grant, File No. SAT-STA-20100803-00173 (granted Aug. 6, 2010)
(“EchoStar 3 STA”).
       3
           See File No. SAT-LOA-20100310-00043 (granted July 1, 2010).


location, the EchoStar 3 satellite was moved to 61.45 W.L. EchoStar 3, along with EchoStar 6,

and EchoStar 12, will supplement the service, as needed, provided by EchoStar 15 to maintain

regular programming. The continued operation of EchoStar 3 ensures that EchoStar’s customer,

DISH Network Corporation, will be able to continue providing DBS service to consumers

without any service interruptions.

I.     RENEWAL IS IN THE PUBLIC INTEREST AND WILL NOT CAUSE
       HARMFUL INTERFERENCE

       For the same reason the previous STA was granted, so too is this modest extension in the

public interest. Grant of this application will ensure safe station-keeping margins for each of the

satellites that will be located at the nominal 61.5 W.L. orbital location. Grant of this application

also will not cause harmful interference because EchoStar 3 has moved 0.05 degrees to the east,

farther away from the nearest Broadcasting-Satellite Service (“BSS”) satellite other than

EchoStar’s satellites, DIRECTV 1R, operating at 72.5 W.L. Furthermore, while EchoStar 3 is

operating at 61.45 W.L., it will abide by the conditions set forth in the grant.4

       EchoStar notes that although EchoStar 3 is currently in storage configuration and not

broadcasting to earth, in the event of a technical failure of another satellite, EchoStar may bring

EchoStar 3 back into use. This will ensure that there is no interruption of service to DBS

consumers.

II.    WAIVER PURSUANT TO SECTION 304 OF THE ACT

       In accordance with Section 304 of the Communications Act of 1934, as amended,

47 U.S.C. § 304, EchoStar hereby waives any claim to the use of any particular frequency or of




       4
           EchoStar 3 STA at 1, 6.



                                                -2-


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.

III.      CONCLUSION

          For the foregoing reasons, EchoStar respectfully requests the grant of its application to

renew its special temporary authority for an additional 30 days to operate EchoStar 3 at 61.45°

W.L. EchoStar will continue to operate the satellite pursuant to the conditions imposed in the

grant.5


                                                  Respectfully submitted,


                                                            /s/

Pantelis Michalopoulos                            Alison Minea
Christopher R. Bjornson                           Corporate Counsel
L. Lisa Sandoval                                  EchoStar Corporation
Steptoe & Johnson LLP                             1110 Vermont Avenue, NW, Suite 750
1330 Connecticut Avenue, N.W.                     Washington, D.C. 20005
Washington, D.C. 20036                            (202) 293-0981
(202) 429-3000
Counsel for EchoStar Corporation


September 1, 2010




          5
              Id.



                                                  -3-



Document Created: 2010-09-01 18:07:41
Document Modified: 2010-09-01 18:07:41

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