Attachment Narrative

This document pretains to SAT-STA-20110324-00060 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011032400060_878713

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) Call Sign S2741 ) In the Matter of ) File No. SAT-STA-20100615-00135 ) File No. SAT-STA-20100803-00173 ECHOSTAR CORPORATION ) File No. SAT-STA-20100901-00189 ) File No. SAT-STA-20101004-00208 Application to Renew Its Special Temporary ) File No. SAT-STA-20101105-00231 Authority to Operate EchoStar 3 as an ) File No. SAT-STA-20101201-00249 In-Orbit Spare at 61.45º W.L. ) File No. SAT-STA-20110103-00002 ) File No. SAT-STA-20110202-00021 ) File No. SAT-STA-20110225-00037 ) File No. SAT-STA-2011__________ ) APPLICATION FOR RENEWAL OF SPECIAL TEMPORARY AUTHORITY1 EchoStar Corporation (“EchoStar”)2 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 15,3 and the current STA to operate there expires on April 6, 2011.4 1 EchoStar has filed a request for special temporary authority to operate EchoStar 3 as an in-orbit spare for 180 days. See File No. SAT-STA-20110225-00038 (filed Feb. 25, 2011). 2 On February 24, 2011, EchoStar Corporation filed an application requesting consent to the pro forma assignment of its authorization to operate the EchoStar 3 satellite (Call Sign S2741) and the associated special temporary authority to operate the satellite as an in-orbit spare at 61.45 W.L. to EchoStar Satellite Operating Corporation. See File No. SAT-ASG-20110224- 00033 (filed Feb. 24, 2011). EchoStar requests that, in the event this STA request is granted prior to consummation of the pro forma assignment, that EchoStar be authorized to assign any authority granted in response to this request on a pro forma basis to EchoStar Satellite Operating Corporation. 3 See Stamp Grant, File No. SAT-STA-20100615-00135 (granted July 7, 2010). 4 See Stamp Grant, File No. SAT-STA-20110225-00037 (granted Mar. 1, 2011).

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 3.5 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 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 while the Commission evaluates EchoStar’s request to extend its STA for 180 days.6 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.7 5 See Stamp Grant, File No. SAT-LOA-20100310-00043 (granted July 1, 2010). 6 See File No. SAT-STA-20110225-00038 (filed Feb. 25, 2011). 7 See Stamp Grant, File No. SAT-STA-20100803-00173 (granted Aug. 6, 2010). -2-

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 use 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. 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.8 8 Id. -3-

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, NW Washington, D.C. 20005 Washington, D.C. 20036 (202) 293-0981 (202) 429-3000 Counsel for EchoStar Corporation March 24, 2011 -4-


Document Created: 2011-03-24 18:12:01
Document Modified: 2011-03-24 18:12:01
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