Attachment Narrative

This document pretains to SAT-STA-20101201-00249 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010120100249_854376

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) ) In the Matter of ) Call Sign S2741 ) ECHOSTAR CORPORATION ) File No. SAT-STA-20100615-00135 ) File No. SAT-STA-20100803-00173 Application to Renew Its Special Temporary ) File No. SAT-STA-20100901-00189 Authority to Operate EchoStar 3 as an ) File No. SAT-STA-20101004-00208 In-Orbit Spare at 61.45º W.L. ) File No. SAT-STA-20101105-00231 ) 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 December 6, 2010.2 As the Commission is aware, on July 10, 2010, EchoStar successfully launched EchoStar 15, a 32-transponder Direct Broadcast Satellite (“DBS”) 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 location, the EchoStar 3 satellite was moved to 61.45 W.L. EchoStar 3, along with EchoStar 6 and EchoStar 1 See Stamp Grant, File No. SAT-STA-20100615-00135 (granted July 7, 2010). 2 See Stamp Grant, File No. SAT-STA-20101105-00231 (granted Nov. 15, 2010). 3 See Stamp Grant, File No. SAT-LOA-20100310-00043 (granted July 1, 2010).

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 L.L.C., 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 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 initial 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 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. 4 See Stamp Grant, File No. SAT-STA-20100803-00173 (Aug. 6, 2010). -2-

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 initial 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 December 1, 2010 5 Id. -3-


Document Created: 2010-12-01 15:34:30
Document Modified: 2010-12-01 15:34:30
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