Attachment Narrative

This document pretains to SAT-STA-20130514-00069 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2013051400069_996971

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) ) In the Matter of ) ) ECHOSTAR SATELLITE OPERATING ) File No. SAT-STA-20121113-00198 CORPORATION ) File No. SAT-STA-2013____-_____ ) Call Sign S2741 Application for Renewal of Special ) Temporary Authority to Operate EchoStar 3 ) as an In-Orbit Spare at 61.8º W.L. ) ) ) APPLICATION FOR RENEWAL OF SPECIAL TEMPORARY AUTHORITY By this Application, and pursuant to Section 25.120(b)(2) of the Commission’s rules,1 EchoStar Satellite Operating Corporation (“ESOC,” and with its affiliates, “EchoStar”) hereby requests a 180-day renewal of its special temporary authority (“STA”) to operate the EchoStar 3 satellite at 61.8º W.L. as an in-orbit spare. Specifically, EchoStar requests continued authority to conduct TT&C over the following frequencies: 17301.5 MHz (command); and 12201.0 MHz, 12203.0 MHz, and 12699.0 MHz (telemetry). The current STA for the space station expires on June 25, 2013.2 EchoStar launched the EchoStar 16 satellite in November 2012 to provide additional service for its customer, DISH Network L.L.C., at the nominal 61.5º W.L. orbital location. In anticipation of the arrival of EchoStar 16 at 61.5º W.L., and to provide adequate station-keeping 1 47 C.F.R. § 25.120(b)(2). 2 See Stamp Grant, File No. SAT-STA-20121113-00198 (granted Jan. 28, 2013).

margins for all the satellites in the 61.5° W.L. orbital cluster,3 EchoStar repositioned EchoStar 3 at 61.8º W.L. in early 2012.4 Operating at 61.8º W.L. as an in-orbit spare, EchoStar 3 remains in close proximity to the 61.5º W.L. nominal orbital location and available, if needed, for repositioning within the orbital cluster to provide service.5 Accordingly, grant of the requested STA is in the public interest. I. 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 previously granted STA to operate EchoStar 3 as an in-orbit spare.6 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. Moreover, grant of this application will not cause harmful interference because EchoStar will conduct TT&C operations with EchoStar 3 at 61.8º W.L. in accordance with the conditions imposed on the original STA grant.7 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. 3 EchoStar 3 has been operating at 61.8° W.L. while EchoStar 12 has been operating at 61.35° W.L., EchoStar 15 at 61.65° W.L., and EchoStar 16 at 61.5° W.L. 4 Stamp Grant, File No. SAT-STA-20120424-00073, Call Sign S2741 (granted Apr. 30, 2012). 5 With the relocation of EchoStar 15 to the 45° W.L. cluster, Stamp Grant, SAT-STA-20130502- 00065, Call Sign S2811 (granted May 8, 2013), EchoStar is evaluating spare capacity requirements for the 61.5° W.L. cluster. As part of these considerations, EchoStar is considering its options for bringing EchoStar 3 back within the 61.5° W.L. orbital cluster. 6 See Stamp Grant, File No. SAT-STA-20120424-00073 (granted Apr. 30, 2012). 7 Id. -2-

III. CONCLUSION For the foregoing reasons, ESOC respectfully requests grant of its application for renewal of its STA to operate EchoStar 3 as an in-orbit spare at 61.8° W.L. Respectfully submitted, /s/ Pantelis Michalopoulos Stephanie A. Roy Steptoe & Johnson LLP 1330 Connecticut Avenue, N.W. Washington, DC 20036 (202) 429-3000 Counsel for EchoStar Satellite Operating Corporation May 14, 2013 -3-


Document Created: 2013-05-14 10:43:18
Document Modified: 2013-05-14 10:43:18
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