Attachment Narrative

This document pretains to SAT-STA-20121203-00208 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012120300208_977098

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

                                                 )
                                                 )
In the Matter of                                 )
                                                 )
ECHOSTAR SATELLITE OPERATING                     ) File No. SAT-STA-20120531-00092
CORPORATION                                      ) File No. SAT-STA-2012____-_____
                                                 ) Call Sign S2811
Application for Renewal of Special               )
Temporary Authority to Operate at 61.65º         )
W.L.                                             )
                                                 )


        APPLICATION FOR RENEWAL OF SPECIAL TEMPORARY AUTHORITY

         EchoStar Satellite Operating Corporation (“ESOC,” and collectively with its affiliates,

“EchoStar”) hereby requests a 180-day renewal of its special temporary authority (“STA”) to

operate EchoStar 15 at 61.65º W.L.1 The current STA for the space station expires on January

16, 2013.2

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-14,3

effectively replaced EchoStar 3.4 EchoStar 15 became fully operational on August 5, 2010.

Since its launch, EchoStar 15 operated at 61.55º W.L. and then was moved to 61.65º W.L.




1
    EchoStar will maintain EchoStar 15 within a ± 0.05º station-keeping box while at 61.65º W.L.
2
    See Stamp Grant, File No. SAT-STA-20120531-00092 (granted July 18, 2012).
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).


pursuant to STA. EchoStar 15 provides capacity for EchoStar’s customer, DISH Network

L.L.C., to provide Direct Broadcast Satellite (“DBS”) service to U.S. consumers.

       EchoStar 16 is expected to replace EchoStar 15 at the nominal 61.5° W.L. orbital location

once EchoStar 16 completes its in-orbit testing. EchoStar currently expects EchoStar 16 to

arrive at the nominal 61.5° W.L. orbital location sometime in late December or early January.

Once there, EchoStar will work to transfer traffic from EchoStar 15 to EchoStar 16 without

interruption to service to DISH network customers. Once all traffic is transferred, which

EchoStar anticipates will be sometime in the latter half of January, EchoStar expects to move

EchoStar 15 to 44.9º W.L.

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 operate EchoStar 15 at 61.65º W.L.5 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. Grant of this application will not cause harmful interference because EchoStar

will operate EchoStar 15 in accordance with the conditions imposed on the original STA grant.6

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.




       5
           See Stamp Grant, File No. SAT-STA-20120531-00091 (granted June 12, 2012).
       6
           See id.


                                               -2-


IV.    CONCLUSION

       For the foregoing reasons, ESOC respectfully requests grant of its application for renewal

of its 180-day special temporary authority to operate EchoStar 15 at 61.65º W.L.


                                              Respectfully submitted,

                                                       /s/
Pantelis Michalopoulos                        Alison Minea
Stephanie A. Roy                              Corporate Counsel
Jessica I. Rothschild                         EchoStar Satellite Operating 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 Satellite Operating
Corporation


December 3, 2012




                                              -3-



Document Created: 2012-12-03 22:49:52
Document Modified: 2012-12-03 22:49:52

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