Attachment Narrative

This document pretains to SAT-STA-20110202-00021 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011020200021_866598

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

                                                 )
                                                 )   Call Sign S2741
In the Matter of                                 )
                                                 )   File No. SAT-STA-20100615-00135
ECHOSTAR CORPORATION                             )   File No. SAT-STA-20100803-00173
                                                 )   File No. SAT-STA-20100901-00189
Application to Renew Its Special Temporary       )   File No. SAT-STA-20101004-00208
Authority to Operate EchoStar 3 as an            )   File No. SAT-STA-20101105-00231
In-Orbit Spare at 61.45º W.L.                    )   File No. SAT-STA-20101201-00249
                                                 )   File No. SAT-STA-20110103-00002
                                                 )   File No. SAT-STA-2011__________


      APPLICATION FOR RENEWAL OF SPECIAL TEMPORARY AUTHORITY

       EchoStar Corporation (“EchoStar”) hereby 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 February 5, 2011.2

       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, is

effectively replacing 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-20110103-00002 (granted Jan. 13, 2011).
       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, which is operating at 72.5 W.L. Furthermore, while EchoStar 3 is

operating at 61.45 W.L., it will continue to 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 (granted 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


February 2, 2011




        5
            Id.



                                                -3-



Document Created: 2011-02-02 14:26:28
Document Modified: 2011-02-02 14:26:28

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