Attachment Narrative

This document pretains to SAT-STA-20120319-00052 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012031900052_945446

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) ) In the Matter of ) ) ECHOSTAR SATELLITE OPERATING ) File No. SAT-STA-20111004-00195 CORPORATION ) File No. SAT-STA-2012__________ ) Call Sign S2741 Application to Renew Special Temporary ) Authority to Operate EchoStar 3 as an In- ) Orbit Spare at 61.45º W.L. ) ) APPLICATION TO RENEW SPECIAL TEMPORARY AUTHORITY EchoStar Satellite Operating Corporation (“ESOC”) hereby requests renewal of its special temporary authority (“STA”) under Section 25.120(b) of the Commission’s rules1 to operate the EchoStar 3 satellite at 61.45º W.L. as an in-orbit spare for an additional 180 days. The current STA expires on May 2, 2012.2 As the Commission is aware, on July 10, 2010, ESOC’s parent company, EchoStar Corporation (“EchoStar”), successfully launched EchoStar 15, a 32-transponder Direct Broadcast Satellite (“DBS”) that, in light of the loss of AMC-14,3 is effectively replacing EchoStar 3.4 EchoStar 15 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 1 47 C.F.R. § 25.120(b). 2 See Stamp Grant, File No. SAT-STA-20111004-00195 (granted Nov. 16, 2011). 3 See Letter from Pantelis Michalopoulos, Counsel for EchoStar Corporation, to Marlene H. Dortch, Secretary, FCC, File No. SAT-STA-20080923-00193 (Dec. 30, 2008). 4 See Stamp Grant, File No. SAT-LOA-20100310-00043 (granted July 1, 2010).

was moved to 61.45° W.L. EchoStar 3, along with EchoStar 12, will supplement service provided by EchoStar 15, as needed, to maintain regular programming. The continued operation of EchoStar 3 helps to ensure that ESOC’s customer, DISH Network L.L.C., will be able to continue providing DBS service to consumers without any service interruptions. I. THIS REQUEST IS IN THE PUBLIC INTEREST AND WILL NOT CAUSE HARMFUL INTERFERENCE For the same reason EchoStar was granted STA to operate EchoStar 3 as an in-orbit spare, so too is this request in the public interest. Grant of this application will ensure safe station-keeping margins for each of the satellites that are located at the nominal 61.5° W.L. orbital location. It also will not cause harmful interference, because EchoStar 3 has moved 0.05 degrees to the east, farther away from the nearest non-EchoStar DBS satellite, 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 EchoStar’s grant.5 ESOC notes that, although EchoStar 3 is currently in a storage configuration and not broadcasting to Earth, in the event of a technical failure of another satellite, ESOC may bring EchoStar 3 back into use. This will ensure that there is no interruption of DBS service to 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, ESOC 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. 5 See Stamp Grant, File No. SAT-STA-20110225-00038 (granted Apr. 7, 2011). -2-

III. CONCLUSION For the foregoing reasons, ESOC respectfully requests the grant of its application for renewal of its special temporary authority to operate EchoStar 3 at 61.45° W.L. as an in-orbit spare for an additional 180 days. Respectfully submitted, /s/ Pantelis Michalopoulos Alison Minea Stephanie A. Roy Corporate Counsel Steptoe & Johnson LLP EchoStar Satellite Operating Corporation 1330 Connecticut Avenue, NW 1110 Vermont Avenue, NW, Suite 750 Washington, D.C. 20036 Washington, D.C. 20005 (202) 429-3000 (202) 293-0981 Counsel for EchoStar Satellite Operating Corporation March 19, 2012 -3-


Document Created: 2012-03-19 17:06:48
Document Modified: 2012-03-19 17:06:48
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