Attachment Narrative

This document pretains to SAT-STA-20120711-00115 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012071100115_959190

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) ) In the Matter of ) ) ECHOSTAR SATELLITE OPERATING ) File No. SAT-STA-20120531-00091 CORPORATION ) File No. SAT-STA-___________ ) Call Sign S2811 Applications for Special Temporary ) Authority to Operate EchoStar 15 at 61.65º ) W.L. ) ) ) APPLICATION FOR RENEWAL OF SPECIAL TEMPORARY AUTHORITY By this application, and pursuant to Section 25.120(b)(4) of the Commission’s rules,1 EchoStar Satellite Operating Corporation (“ESOC,” and collectively with its affiliates, “EchoStar”) hereby requests a 30-day renewal of its special temporary authority (“STA”) to operate the EchoStar 15 satellite at the 61.65º W.L. orbital position. I. BACKGROUND 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-14,2 effectively replaced EchoStar 3.3 EchoStar 15 became fully operational on August 5, 2010. EchoStar 15 has been operating at 61.55º W.L. since its launch, providing capacity for 1 47 C.F.R. § 25.120(b)(4). 2 See Letter from Pantelis Michalopoulos, Counsel for EchoStar Corporation, to Marlene H. Dortch, Secretary, FCC, File No. SAT-STA-20080923-00193 (Dec. 30, 2008). 3 See Stamp Grant, File No. SAT-LOA-20100310-00043 (granted July 1, 2010).

EchoStar’s customer, DISH Network L.L.C., to provide Direct Broadcast Satellite (“DBS”) service to U.S. consumers. EchoStar is now preparing to launch the EchoStar 16 satellite as early as August 2012, which will further supplement the service provided from 61.5º W.L. and ensure the continued full utilization of the DBS spectrum at that orbital location. In anticipation of this launch and the assumption of operations at 61.5º W.L. by EchoStar 16, EchoStar is repositioning the spacecraft in the 61.5º W.L. orbital cluster. EchoStar now has satellites at 61.35º W.L. (EchoStar 12), 61.65 º W.L. (EchoStar 15), and 61.8 º W.L. (EchoStar 3).4 Upon the successful launch of EchoStar 16 later this year, which will be placed at 61.5º W.L., EchoStar’s satellites in the cluster will be aligned at 0.15º separation, with the three operational satellites centered around the 61.5º W.L. nominal orbital location. This renewal STA is necessary to allow the continued operation of EchoStar 15 while EchoStar’s application for a 180-day STA remains pending before the Commission.5 II. THIS REQUEST IS IN THE PUBLIC INTEREST AND WILL NOT CAUSE HARMFUL INTERFERENCE The requested STA is in the public interest for the same reason EchoStar was granted STA to move and operate EchoStar 15 at 61.65º W.L. Moreover, 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. ESOC will operate EchoStar 15 on a non-harmful interference basis in accordance with the conditions imposed on the original STA grant.6 4 Policy Branch Information, Actions Taken, Report No. SAT-00865, File No. SAT-STA- 20120424-00073 (eff. April 30, 2012). 5 See File No. SAT-STA-20120531-00092 (filed May 31, 2012). 6 See Stamp Grant, File No. SAT-STA-20120531-00091 (granted June 12, 2012). -2-

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, 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. IV. CONCLUSION For the foregoing reasons, ESOC respectfully requests grant of its application for renewal of its special temporary authority to operate EchoStar 15 at 61.65º W.L. 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 July 11, 2012 -3-


Document Created: 2012-07-11 15:26:57
Document Modified: 2012-07-11 15:26:57
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