Attachment Narrative

This document pretains to SAT-STA-20110204-00025 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011020400025_867355

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) In the Matter of ) ) Call Sign S2232 ECHOSTAR CORPORATION ) ) File No. SAT-STA-2011__________ Application for Emergency Special Temporary ) Authority to Move EchoStar 6 to, and Station It ) at, 76.95° W.L. ) ) EXPEDITED CONSIDERATION REQUESTED APPLICATION FOR EMERGENCY SPECIAL TEMPORARY AUTHORITY By this Application, EchoStar Corporation (“EchoStar”) requests emergency Special Temporary Authority (“STA”),1 under Section 25.120(a),2 for 30 days (a) to move the EchoStar 6 satellite from its current orbital position at 61.65º W.L. to the 76.95º W.L. orbital location; and (b) to station the satellite there. This emergency request is necessary to allow EchoStar to transfer traffic to EchoStar 6 while it completes its restoration activities following the recent single event upset (“SEU”) that temporarily affected the EchoStar 8 satellite.3 As a consequence, 1 In conjunction with this application, EchoStar is separately filing the following application for STA to operate four transmit/receive earth stations to provide TT&C for the satellite while it is relocated to 76.95 W.L. EchoStar will also separately file (1) an STA to operate EchoStar 6 at 76.95 W.L. for 30 days and (2) an STA to operate three transmit/receive earth stations to provide TT&C and feeder link service to the satellite while it is located at 76.95 W.L. 2 47 C.F.R. § 25.120(a). 3 As EchoStar stated to the Commission in a letter dated February 1, 2011, EchoStar believes that the SEU, which occurred on January 30, 2011, did not cause any significant or permanent damage that will affect EchoStar 8’s future operations. See Letter from Petra A. Vorwig, Counsel for EchoStar Corporation, to Marlene H. Dortch, Secretary, FCC, filed in File No. SAT-T/C-20090217-00026 (Feb. 1, 2011).

EchoStar had to move traffic from EchoStar 8 to other satellite capacity. The problems caused by the SEU have been resolved in part, and EchoStar has started to restore traffic on EchoStar 8. EchoStar has determined, however, that additional tests of EchoStar 8’s health are necessary. To conduct these tests without disrupting service to customers, it is necessary to be able to transfer traffic seamlessly to another satellite at the same orbital location. The instant request is in response to this need. The Mexican concessionaire for the 77 W.L. orbital location has informed COFETEL, and understands that COFETEL consents to the 30-day temporary operation of EchoStar 6 as a U.S. satellite, subject to the eventual exchange of letters concerning the EchoStar 6 satellite.4 Since the need for the EchoStar 8 tests is urgent, EchoStar respectfully requests verbal action on this request today.5 I. BACKGROUND The nominal 77º W.L. orbital location is allotted to Mexico under the Region 2 Broadcasting-Satellite Service plan set forth in Appendices 30 and 30A to the international Radio Regulations. EchoStar currently operates three Direct Broadcast Satellites (“DBS”) at the nominal 77° W.L. orbital location under Mexican authority issued to its partner, QuetzSat, S. de R.L. de C.V. (“QuetzSat”): EchoStar 1, EchoStar 4, and EchoStar 8. The satellites are used by EchoStar’s customer DISH Network L.L.C. (“DISH”) and DISH Mexico to provide DBS service in the United States and Mexico, respectively. The U.S. service includes local-into-local programming in a number of markets in the southern United States. 4 EchoStar will soon file a modification application to allow the provision of service to the United States (to the extent necessary) from EchoStar 6 located at 76.95 W.L. as a Mexican- licensed satellite. 5 The technical parameters of the satellite and its proposed operations are provided in the attached Technical Annex (Attachment 1). -2-

The spare capacity available at 77º W.L. is not enough to provide full “redundancy” for EchoStar 8. As the Commission is aware, EchoStar 4 recently experienced transponder anomalies, and is not currently operational.6 As for EchoStar 1, a satellite launched in December 1995, it has limited capability (only up to 16 transponders), and thus it, too, is inadequate to the task of carrying the traffic necessary during EchoStar 8’s tests. For the reasons set forth herein, grant of this Application will not cause harmful interference to any authorized user of the spectrum and will serve the public interest. II. GRANT OF THIS APPLICATION IS IN THE PUBLIC INTEREST The emergency STA requested in this application is in the public interest because it will ensure the provision of DBS service to the United States, including the provision of local-into- local service in several markets, and ensure continuity of receipt of both national and local programming for the subscribers of EchoStar’s customers, DISH, while EchoStar 8 undergoes testing. Additionally, it will provide spare capacity at 77 W.L. in the event EchoStar 1 or EchoStar 8 suffers a problem. Moreover, this move will not result in a service interruption at 61.65º W.L. because EchoStar 12 and EchoStar 15 will continue to provide service from that orbital slot, and EchoStar 3 is available as an in-orbit spare in the event either of these satellites suffers an outage.7 The relocation of EchoStar 6 to 76.95º W.L. and its operation there also will not cause harmful interference to any other U.S.-licensed satellite operator. There is no DBS orbital location in the vicinity of 77° W.L. that is assigned to the United States (the closest U.S. location 6 See Confidential Letter from Pantelis Michalopoulos, Counsel for EchoStar Corporation to Stephen Duall, IB, FCC, File Nos. SAT-STA-20100920-00199, SAT-STA-20100920-00198, SAT-STA-20100920-00197 (Jan. 18, 2011). 7 See Stamp Grant, File No. SAT-STA-20110103-00002 (granted Jan. 13, 2011). -3-

is 61.5° W.L.). There will likewise be no harmful interference from the operation of an additional satellite at 76.95 W.L. into Canada’s DBS allotments at 72.5º W.L. and 82º W.L. There is an existing coordination agreement between Mexico and Canada regarding the Mexican 77° W.L. orbital location and the Canadian orbital locations 82° W.L. and 72.5° W.L. While EchoStar 6 will remain a U.S.-licensed satellite, EchoStar will operate the satellite so that it is within the specifications of that agreement and/or future coordination agreements. Additionally, during relocation maneuvers, all transponders other than the TT&C transponders will be switched off,8 and EchoStar will operate the satellite subject to the following conditions: 1. EchoStar shall coordinate all drift operations with other potentially affected in- orbit operators. 2. Drift operations shall be on a non-harmful interference basis, meaning that EchoStar shall not cause interference to, and shall not claim protection from, interference caused to it by any other lawfully operating satellites. 3. In the event that any harmful interference is caused as a result of relocation operations, EchoStar shall cease operations immediately upon notification of such interference and shall inform the Commission immediately, in writing, of such event. While EchoStar 6 is stationed at 76.95 W.L., EchoStar will operate the satellite in accordance with the following conditions: 1. Operations shall be on a non-harmful interference basis, meaning that EchoStar shall not cause interference to, and shall not claim protection from, interference caused to it by any other lawfully operating satellites operating within the parameters of applicable international coordination agreements. 2. In the event that any harmful interference is caused while the satellite is operating at 77° W.L., EchoStar shall cease operations immediately upon notification of 8 During the relocation, EchoStar will use the following TT&C frequencies for EchoStar 6: 17305.0 MHz for command, and 12203.0 MHz and 12204.0 MHz for the beacon. -4-

such interference and shall inform the Commission immediately, in writing, of such event. Finally, the proposed temporary operation of the EchoStar 6 satellite at 76.95º W.L. will not create any risk of in-orbit collision. EchoStar 6 will be maintained within +/- 0.05º east/west station-keeping, which will ensure that its station-keeping volume will not overlap with EchoStar’s own satellites at 77º W.L. III. 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. IV. CONCLUSION For the foregoing reasons, EchoStar respectfully requests the grant of its application for emergency special temporary authority for 30 days to relocate EchoStar 6 to the 76.95° W.L. nominal orbital location and station the satellite at that location. Respectfully submitted, /s/ Pantelis Michalopoulos Alison Minea Petra A. Vorwig 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 4, 2011 -5-

ATTACHMENT 1 Technical Information for ECHOSTAR-6 1. GENERAL DESCRIPTION The ECHOSTAR-6 satellite will provide DBS services to the Continental United States from the 76.95° W.L. geostationary orbital position. While this orbital location is allotted to Mexico, EchoStar is requesting emergency Special Temporary Authority from the Commission to operate ECHOSTAR-6 from the slot in response to a recent anomaly suffered by ECHOSTAR-8 operating at 77° W.L. ECHOSTAR-6 was designed to provide 32 channels in medium power mode or 16 channels in high power mode. Full frequency re-use is achieved through the use of dual circular polarization. 2. SATELLITE TRANSMIT PERFORMANCE The downlink beam coverage of the ECHOSTAR-6 satellite from the 76.95° W.L. location is shown in Figure 2-1.1,2 The satellite employs two shaped reflectors, each operating in both right- hand circular polarization (RHCP) and left-hand circular polarization (LHCP). The performance in both polarizations is nominally the same. The cross-polar isolation of the satellite transmit antennas exceeds 30 dB at all transmit frequencies. The peak antenna gain is 35.5 dBi. Each transponder will use either a single 125 Watt Traveling Wave Tube Amplifier (TWTA) (“medium power” mode) or two paralleled 125 Watt TWTAs (“high power” mode), the latter giving approximately a 2.5 dB increase in transmit EIRP. The losses between the TWTA output 1 This beam coverage is achieved by applying appropriate pointing bias to the ECHOSTAR-6 satellite, which was originally designed for operation at the 110°W.L. orbital location, to provide CONUS coverage and near-CONUS service. 2 Note that service to Hawaii and Alaska is not possible using ECHOSTAR-6 from the 77° W.L. orbital location owing to the fact that Hawaii is below 3° elevation angle and the highest elevation angle towards Alaska from the 77°W.L. orbital location is less than 10°. A1

and the antenna input amount to 1.8 dB in medium power mode and 2.3 dB in high power mode. The maximum beam peak saturated EIRP level for the transponders in medium power mode is 54.7 dBW and 57.2 dBW in high power mode. For operations at 76.95° W.L. ECHOSTAR-6 will only be operated in medium power mode. Figure 2-1: ECHOSTAR-6 Downlink Beam Coverage from 76.95°W.L. EchoStar 6 Transmit at 77° W.L. SATSOFT -20 -15 -20 8.00 -20 -15 -1 5 -20 -20 -20 -10 -8 7.00 -6 -15 -10 -6 -8 Theta*sin(phi) in Degrees -4 6.00 -6 -6 -15 -2 -2 -4 -15 -20 5.00 0 -6 -8 -2 -2 -10 -4 4.00 -20 -30 -15 -6 -8 -10 -30 -20 3.00 -3 0 -20 -20 -30 -20 -7.00 -6.00 -5.00 -4. 00 -3.00 -2.00 -1.00 0.00 1.00 2.00 3.00 Theta*cos(phi) in Degrees 3. SATELLITE RECEIVE PERFORMANCE This uplink beam operates in both RHCP and LHCP. The antenna gain contours of the beam are shown in Figure 3-1. The performance in both polarizations is nominally the same. The cross- polar isolation of the satellite receive antennas exceeds 30 dB at all receive frequencies. The peak gain of the beam is 33.8 dBi, with a noise temperature of 590K, for a peak G/T of 6.1 dB/K. A2

Figure 3-1: ECHOSTAR-6 Uplink Beam Coverage from 76.95°W.L. EchoStar 6 Receive at 77° W.L. SATSOFT -20 -20 -15 -30 8.00 -10 -8 -20 -6 -15 -4 7.00 -15 -2 -8 -1 0 -4 -6 -2 -15 -2 Theta*sin(phi) in Degrees 6.00 -2 5.00 -15 -20 -20 -6 -2 -8 -4 -10 4.00 -6 -4 -20 -8 -20 -30 -15 -10 3.00 -20 -15 -15 -30 -7.00 -6.00 -5.00 -4. 00 -3.00 -2.00 -1.00 0.00 1.00 2.00 3.00 Theta*cos(phi) in Degrees 4. FREQUENCY AND POLARIZATION PLANS The ECHOSTAR-6 satellite uses the standard channel center frequencies and channel bandwidths prescribed in the ITU’s Region 2 BSS Plan.3 Circular polarization is used on both the uplink and downlink. 3 Channel bandwidth is 24 MHz. Spacing between center frequencies of adjacent cross-polar channels is 14.58 MHz. Thus, the center of the co-polar channels is offset by 29.16 MHz. A3

5. COMMUNICATIONS PAYLOAD CONFIGURATION The uplink signals are received in both polarizations by the satellite receive antenna. Two active receivers are used on the satellite – one for each polarization. After appropriate down-conversion, channel filtering and amplification the signals are transmitted from the satellite using a single 125 Watt TWTA per channel in the case of medium power mode operation. Each channel can be configured to use two parallel TWTAs for high power mode operation, giving a corresponding increase in the EIRP level of approximately 2.5 dB. In total, the communications payload can support 32 channels in medium power mode, or 16 channels in high power mode, or the corresponding number of a mixture of high power and medium power mode transponders. The reconfiguration of all transponders is switchable by ground telecommand. The outputs of the TWTAs are then multiplexed into the appropriate downlink antenna ports. 6. SATURATION FLUX DENSITY AND TRANSPONDER GAIN The Saturation Flux Density (SFD) of the uplink receive beam ranges between –74.7 dBW/m2 (low gain) to –94.7 dBW/m2 (high gain) at receive beam peak and is adjustable in 1 dB steps. The transponder gain is controlled by an Automatic Level Control (ALC) system which automatically adjusts the transponder gain to give a constant satellite transmit power level for each transponder. The maximum transponder gain is 129.1 dB. 7. RECEIVER AND TRANSMITTER CHANNEL FILTER RESPONSE CHARACTERISTICS The typical receiver and transmitter frequency responses of each RF channel, as measured between the receive antenna input and transmit antenna, fall within the limits shown in Table 7-1 below. A4

In addition, the frequency tolerances of Section 25.202(e) and the out-of-band emission limits of Section 25.202(f)(1), (2) and (3) of the Commission’s rules will be met. 47 C.F.R. §§ 25.202(e), (f)(1), (f)(2), (f)(3). Table 7-1: Typical Receiver and Transmitter Filter Responses Offset from Channel Center Receiver Filter Response (dB) Transmitter Filter Response (dB) Frequency (MHz) ±5 > -0.5 > -0.4 ±7 > -0.7 > -0.5 ±9 > -1.0 > -0.8 ± 11 > -1.5 > -1.7 ±12 > -2.0 > -3.6 ±17.5 < -18 < -8 ±20.2 < -38 < -18 ±27.2 < -50 < -35 8. SPACECRAFT DESCRIPTION The ECHOSTAR-6 satellite’s characteristics, including its physical and electrical characteristics, are described in the associated Schedule S form, which EchoStar will provide in a supplemental filing. 9. EARTH STATIONS The primary subscriber earth station antennas to be used with the ECHOSTAR-6 satellite will range between 45 cm and 60 cm, although slightly larger antennas might be used in certain circumstances. A5

The feeder link earth stations will be located at EchoStar’s existing facilities in Cheyenne, WY and Gilbert, AZ. 10. Telemetry, Tracking and Control (TT&C) A summary of the TT&C subsystem performance is given in Table 10-1. Table 10-1: Summary of the TT&C Subsystem Performance Parameter Performance On-Station Command Frequency 17,305 MHz Uplink Flux Density Between -88 and -108 dBW/m2 Uplink Polarization LHCP 12,203 MHz On-Station Telemetry Frequencies 12,204 MHz Maximum Downlink EIRP 16.0 dBW Downlink Polarization LHCP 11. LINK BUDGETS Representative link budgets for the DBS transmissions, which include details of the transmission characteristics, performance objectives and earth station characteristics, are provided in the associated Schedule S submission, which will be provided in a supplemental filing. Link budgets for the TT&C transmissions are also included therein. A6

12. ORBITAL DEBRIS MITIGATION PLAN Several sections of Section 25.114(d) require a statement that the station operator has made certain assessments.4 12.1 Spacecraft Hardware Design The ECHOSTAR-6 satellite was designed and manufactured by Space Systems/Loral and was launched in 2000. The satellite will not undergo any planned release of debris during its operation. EchoStar has assessed and limited the probability of the satellite becoming a source of debris by collisions with small debris or meteoroids of less than one centimeter in diameter that could cause loss of control and prevent post-mission disposal. Such probability has been limited through component placement and the use of redundant systems. The ECHOSTAR-6 satellite has separate TT&C and propulsion subsystems that are necessary for end-of-life disposal. The spacecraft TT&C system, vital for orbit raising, is extremely rugged with regard to meteoroids smaller than 1 cm, by virtue of its redundancy, shielding, separation of components and physical characteristics. An omni-directional antenna and wide angle horn system are used principally during orbit raising. The redundant command receivers and decoders and telemetry encoders and transmitters are located within a shielded area and physically separated. A single rugged thruster and shielded propellant tank provide the energy for orbit raising. Otherwise, there are no single points of failure in the system. 12.2 Minimizing Accidental Explosions EchoStar has assessed and limited the probability of accidental explosions during and after completion of mission operations. A Failure Mode Verification Analysis has also been conducted, and the probability of accidental explosions has been limited through extensive monitoring of the ECHOSTAR-6 satellite’s batteries and fuel tanks for pressure and temperature. 4 47 C.F.R. §§ 25.114(d)(14)(i-iii). A7

Furthermore, bipropellant mixing is prevented by the use of valves that prevent backwards flow in propellant lines and pressurization lines. Excessive battery charging or discharging is limited by a monitoring and control system which will automatically limit the possibility of fragmentation. Corrective action, if not automatically undertaken, will be immediately undertaken by the spacecraft operator to avoid destruction and fragmentation. Thruster temperatures, impulse and thrust duration are carefully monitored, and any thruster may be turned off via redundant valves. At the end of the satellite’s life, all energy sources will be depleted. Specifically, the batteries will be left in a permanent state of discharge, chemical propulsion systems will be depleted, and the electrical propulsion system will be disabled. 12.3 Safe Flight Profiles In considering current and planned satellites that may have a station-keeping volume that overlaps the ECHOSTAR-6 satellite, EchoStar has reviewed the lists of FCC licensed satellite networks, as well as those that are currently under consideration by the FCC. In addition, networks that have been submitted to the ITU within ±0.15 degrees from 76.95° W.L. have also been reviewed. Currently there are three operational Mexican licensed satellites in the vicinity of 76.95° W.L. These are as follows:  ECHOSTAR-4 satellite at 76.85° W.L.  ECHOSTAR-8 satellite at 77.0° W.L.  ECHOSTAR-1 satellite at 77.15° W.L. Both ECHOSTAR-8 and ECHOSTAR-1 satellites are operated with an east-west station-keeping tolerance of ±0.05 degrees. ECHOSTAR-4 operates at ±0.1 degrees. ECHOSTAR-6 will be operated with an east-west station-keeping tolerance of ±0.05°. Before the ECHOSTAR-6 satellite arrives at 76.95° W.L., ECHOSTAR will coordinate the location of each spacecraft with the Mexican Regulatory Authority to safely locate each spacecraft within the ±0.2 degree cluster A8

of 77° W.L. and in a manner such that there will be no station-keeping volume overlap between the various satellites. There are no pending applications before the Commission for additional satellites to be located at an orbital location in the immediate vicinity of 76.95° W.L. The BSS ITU networks in the vicinity of 76.95° W.L. belong to Mexico. Although there are numerous FSS networks within ±0.15 degrees of 76.95° W.L., EchoStar can find no evidence that any of these networks are under construction or scheduled for launch. Based on the preceding, EchoStar concludes there is no requirement to physically coordinate the ECHOSTAR-6 satellite with another satellite operator at the present time. 12.4 Post Mission Disposal Upon mission completion, the ECHOSTAR-6 satellite will be maneuvered to a disposal orbit at least 300 km above its operational geostationary orbit.5 Based on data from the satellite manufacturer, less than 7 kg of fuel will be required to achieve this. Accordingly, 7 kg of fuel will be reserved at the end of the satellite’s life. The fuel reserve will be calculated using three methods. The first method is the pressure-volume temperature method, which uses tank pressure and temperature information to determine remaining propellant. The second method is the bookkeeping method, which evaluates the flow rate at average pressure and total thruster on-time of orbital maneuvers to determine the amount of propellant used. The third method is the propellant depletion gauge operations method, which uses propellant temperature measurements taken while tank heaters are activated to determine more accurately the amount of oxidizer and fuel in tanks at the end of mission life. EchoStar has assessed fuel gauging uncertainty and has provided an adequate margin of fuel to address such uncertainty. 5 The ECHOSTAR-6 satellite was launched in 2000. Pursuant to the Commission’s Mitigation of Orbital Debris, Second Report and Order, 19 FCC Rcd 11567 (2004), a calculation of the satellite’s disposal orbit according to the IADC formula is not required. See id. ¶ 81 (“[W]e will grandfather all on orbit GEO spacecraft that were launched as of the release of the Notice in this proceeding”). A9

CERTIFICATION OF PERSON RESPONSIBLE FOR PREPARING ENGINEERING INFORMATION I hereby certify that I am the technically qualified person responsible for preparation of the engineering information contained in this application, that I am familiar with Part 25 of the Commission’s rules, that I have either prepared or reviewed the engineering information submitted in this application and that it is complete and accurate to the best of my knowledge and belief. /s/ ¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯ Darren Hamilton Director Space Systems Engineering EchoStar Satellite Services L.L.C. Englewood, CO, USA (303) 706-4353 February 4, 2011 A10


Document Created: 2011-02-04 17:37:40
Document Modified: 2011-02-04 17:37:40
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