Reply of Spectrum Five LLC REPLY by Spectrum Five LLC SAT-STA-20130912-00115 EchoStar 6 - Reply r

EchoStar 6 - Reply r

REPLY submitted by Spectrum Five LLC

Reply of Spectrum Five LLC

2014-03-11

This document pretains to SAT-STA-20130912-00115 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2013091200115_1039202

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

In the Matter of )
)
ECHOSTAR SATELLITE OPERATING ) File No. SAT-STA-20140113-00004
CORPORATION ) Call Sign S2232
)
Request for Renewal of Special Temporary )
Authorization to Move EchoStar 6 to, and )
Operate It at, 96.2º W.L. )

To: Chief, International Bureau

REPLY OF SPECTRUM FIVE LLC

David Wilson
Chief Executive Officer

SPECTRUM FIVE LLC
807 Las Cimas Parkway
Suite 270
Austin, TX 78746

March 11, 2014

TABLE OF CONTENTS

Page
I. Introduction and Summary 1

II. EchoStar’s Statement that SES-Bermuda was Not Licensed by 2
Bermuda Until August 2013 Is a New and Significant Inconsistency That
Renders All the STA Requests Defective.

III. EchoStar’s
Failure
to
Provide
Communications
Service
Means
the
STA
4

Standard
Cannot
be
Satisfied
for
Any
of
the
Pending
STA
Requests.

IV.

EchoStar’s
Responses
to
Spectrum
Five’s
Demonstration
that
the

7

Station-‐Keeping
Condition
of
the
April
STA
has
been
Willfully
and

Repeatedly
Violated
is
Unavailing;
“Substantial
Compliance”
is
no

Substitute
for
Actual
Compliance.

V.
EchoStar
6’s
Highly-‐Inclined
Operation
Prevents
EchoStar
from

11

Providing
Service
to
Any
Consumer-‐Grade,
Non-‐Tracking
Earth
Station

Antennas
of
the
Type
Used
in
DBS/BSS.

VI.
Conclusion

12

ii

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

In the Matter of )
)
ECHOSTAR SATELLITE OPERATING ) File No. SAT-STA-20140113-00004
CORPORATION ) Call Sign S2232
)
Request for Renewal of Special Temporary )
Authorization to Move EchoStar 6 to, and )
Operate It at, 96.2º W.L. )

To: Chief, International Bureau

REPLY OF SPECTRUM FIVE LLC

Spectrum Five LLC (“Spectrum Five”), pursuant to Section 25.154 of the

Commission’s Rules, hereby replies to the “Response to ‘Opposition’” filed by EchoStar

Satellite Operating Corporation (“EchoStar”) in the above-captioned proceeding stemming

from EchoStar’s request for Special Temporary Authority (“STA”) to provide Direct

Broadcasting Satellite (“DBS”) service at the unassigned 96.2° W.L. orbital location from the

highly-inclined-orbit EchoStar 6 satellite.1

I. Introduction
and
Summary

In its Opposition, Spectrum Five provided three compelling reasons why the

Commission should deny the January 2014 60-day STA Request (which sought to extend or

renew the 60-day STA the International Bureau granted in April 2013) and dismiss the four

other pending 60-day STA extension/renewal requests as moot.2 Spectrum Five showed that:

1
EchoStar Satellite Operating Company Response to “Opposition” in File No. SAT-STA-20140113-
00004 (filed February 26, 2014) (“EchoStar Response”). The EchoStar STA request is referred to
herein as the “EchoStar January STA Request.” The filing deadline for this Reply was extended by
one day pursuant to Public Notice Report No. 14-299 (released March 4, 2014).
2
Spectrum Five Opposition in File No. SAT-STA-20140113-00004 (filed February 11, 2014).

(i) EchoStar has violated the express condition that the EchoStar 6 satellite be maintained at

96.2° W.L. with an east/west longitudinal station-keeping tolerance of +/- 0.05 degrees;3 (ii)

EchoStar continues to misrepresent the extent to which the EchoStar 6 satellite is being used

near 96.2° W.L. for the fixed-satellite and mobile-satellite services authorized in the EchoStar

60-Day STA Grant;4 and (iii) the extent of EchoStar 6 satellite’s north-south inclination

prevents any non-tracking earth station (such as consumer-grade earth stations used with DBS

systems) from receiving a constant signal from EchoStar 6.

EchoStar’s Response does not meaningfully address the issues raised by Spectrum

Five. Instead, EchoStar provides materially inconsistent claims that serve only to reinforce

the points Spectrum Five raised against the pending STA requests for EchoStar 6 and

introduce new reasons to deny the pending STA requests.

As Spectrum Five demonstrated in its Opposition and reinforces here, the Commission

must deny the January STA Request and all pending EchoStar 6 STA requests. The

Commission should also refer EchoStar’s violations of the station-keeping condition in the

EchoStar 60-Day STA Grant and its subsequent misrepresentations to the Enforcement

Bureau for appropriate disciplinary action.

II.

EchoStar’s
Statement
that
SES-‐Bermuda
was
Not
Licensed
by
Bermuda
Until

August
2013
Is
a
New
and
Significant
Inconsistency
That
Renders
All
the

STA
Requests
Defective.

One significant and new inconsistency relates to the question of when EchoStar’s

customer had authorization from the Bermudian government. In the initial STA request,

EchoStar attached a letter from a Bermuda government official dated February 20, 2013

3
Spectrum Five Opposition, at 2 - 4 (citing EchoStar Satellite Operating Corporation, 28 FCC Rcd
4229, ¶ 20 (Int’l Bur. 2013) (“EchoStar 60-Day STA Grant”)).
4
Spectrum Five Opposition, at 4-6.

2

stating that Bermuda had authorized SES’s Bermudian subsidiary to operate DBS/BSS

satellites at 96.2° W.L.5 In its current Response, however, EchoStar claims that SES

“obtained a license from the Bermuda Ministry of Economic Development to provide satellite

service to Bermuda via EchoStar 6” on August 14, 2013. 6 EchoStar Response at 3.

Under Bermuda law, a satellite operator must receive three separate certifications to be

licensed – a “certification of compliance,” a “certification of competence to engage in

coordination,” and “a certification of coordination.” The certification of compliance is a

determination by the Bermuda government that the operator is qualified to apply for a license

by meeting a long list of basic qualifications, is “competent and capable of carrying out the

proposed satellite network project,” and that the project “is in the interests of the people of

Bermuda.” All three are prerequisites for Bermudian satellite licensing, although it is

possible to gain a conditioned license if coordination has been started but not completed.7

According to a February 14, 2014 statement to the Bermuda Parliament by Bermuda’s

minister with responsibility for Telecommunications, the first two certificates were issued to

SES’s subsidiary in March 2013 – a month after Bermuda informed the Commission via letter

that SES was “authorized” to provide service at 96.2° W.L. under the BERMUDASAT-1 ITU

filings.8 If Bermuda had not even determined if SES was eligible to hold a satellite license at

5
See EchoStar February 20, 2013 STA Request in File No. SAT-STA-20130220-00023, at Exhibit 1.
6
EchoStar Response at 3.
7
See Bermuda Satellite Network Notification and Coordination Regulations 2007 (Regulation Nos. 5,
6, 9, 10, 12, and 18), available at
http://www.bermudalaws.bm/Laws/Consolidated%20Laws/Satellite%20Network%20Notification%20
and%20Coordination%20Regulations%202007.pdf.
8
See Ministerial Statement to the Bermuda House of Assembly by Dr the Hon. E. Grant Gibbons, JP,
MP, Minister of Education and Economic Development, February 14, 2014, at 2, available at
http://www.parliament.bm/uploadedFiles/Content/Home/BermudaSat-1%20-%20G.%20Gibbons%20-
%20Feb14%202014.pdf.
3

the time of the statement to the Commission, it is now unclear how SES could have been

“authorized” at the time of that statement. Furthermore, ex parte submissions show that

coordination discussions between SES and DIRECTV were underway on or before March 7,

2013, which draws into question whether SES was even authorized to enter into coordination

talks with DIRECTV at the time those discussions began.

Whether or not it was reasonable for the Bureau to rely on the letter submitted with

EchoStar’s original STA request, EchoStar’s new statements and those from the Bermuda

government demonstrate that SES was not authorized to provide service pursuant to

BERMUDASAT-1 ITU filing at the time the original STA request was filed, granted, or for

that matter, for the duration of the original 60-day STA. Furthermore, Bermuda is not an ITU

recognized Administration. No.18.1 of the ITU Radio Regulations requires that a private

party must be licensed to operate by its Administration, in this case the United Kingdom. The

record is entirely silent about when – if ever – SES’s Bermudian subsidiary received

authorization from the United Kingdom, only from Bermuda. Indeed, any action by the

United Kingdom to ratify the Bermuda license could only have occurred after Bermuda

granted the license, which according to EchoStar was August 14, 2013 – six months after

application was made. The absence of the license renders all of the STA requests and

modification application incomplete and defective.

III.

EchoStar’s
Failure
to
Provide
Communications
Service
Means
the
STA

Standard
Cannot
be
Satisfied
for
Any
of
the
Pending
STA
Requests.

On the subject of “operation” of EchoStar 6 at 96.2° W.L., EchoStar 6 conflates

TT&C of the satellite with operation of it, and offers a series of internally inconsistent

statements that fail to mask the flaws in its argument. The undisputed fact remains that there

was no operation of the satellite’s communications payload at any time during the original 60-

4

day STA, and this is the key consideration for purposes of the Commission’s determination of

whether the current STA request or any of the previous STA extension/renewal requests

should be granted.

For most of its Response, EchoStar acknowledges that it has not operated the

satellite’s payload at all in the more than 11 months since EchoStar 6 was relocated to the area

of 96.2° W.L.9 Spectrum Five notes that EchoStar now claims, for the first time, that

“EchoStar 6’s communications payload has been activated since November 2013[.]”10

EchoStar, however, offers no amplification or substantiation (with declarations or otherwise)

of this claim of convenience – a claim that is contravened by the recent independent, third

party monitoring showing no payload transmissions and EchoStar’s own statements and

carefully parsed words. As it mentioned in the Opposition, Spectrum Five retained an

independent third party to monitor the EchoStar 6 payload in February 2014, and observed no

communications activity taking place on any of EchoStar 6’s transponders.11

The point here, and one that cannot be erased with EchoStar’s empty and vague

claims, is that EchoStar has failed to provide any service via the EchoStar 6 satellite’s

communications payload for more than 345 days and counting since the EchoStar 60-Day

STA Grant, and has no immediate prospects even now for doing so.12 This core and

9
EchoStar reports that it “is engaged in discussions with various commercial partners to bring the
benefits of its mobile video service to, for instance, the maritime market ….” EchoStar Response, at
2. EchoStar claims that the conclusion of the negotiations “will result in the provision of new services
to underserved markets in the mid-Atlantic Ocean region.” Id. (emphasis added). Later on, EchoStar
talks about discussions it has held with potential customers/service providers, and describes what the
satellite “will be used” to provide. Id. at 3.
10
Id. at 3-4.
11
See Spectrum Five Opposition at 5-6.
12
In fact, one of the main services EchoStar proposed to provide via EchoStar 6 at 96.2° W.L. –
direct-to-home services to Bermuda – is clearly not viable due to the high inclination angle of the
5

uncontroverted fact begs the question why Echostar did not originally avail itself of normal

licensing procedures, but instead forced the Commission to truncate normal licensing

procedures through the use of the STA process. But for the bringing into use of the

BERMUDASAT-1 ITU filing, it is clear that there was no urgency demanding the use of the

STA process. EchoStar and its development partner SES are fully capable of exploring

service to underserved markets in the mid-Atlantic Ocean region on any number of other

satellites they control that have better and more powerful coverage of the area in question.

These facts preclude the Commission from finding that the public interest would be seriously

prejudiced (or indeed, negatively impacted in any way whatsoever) by a denial of the STA

request.13 Spectrum Five made this point in its Opposition, and EchoStar offered no cogent

response.14 And the irony is not lost on Spectrum Five that EchoStar demanded that the

Commission use the STA process, and has continued to push it, only to reveal in its most

recent response that SES did not even hold a license from Bermuda.

EchoStar’s forward-looking public interest claims associated with all of the pending

STA requests can be considered in connection with the pending application for a permanent

EchoStar 6 satellite, which would require tracking antennas in every installation. See infra, at Section
V.
13
Spectrum Five does admit to being intrigued by EchoStar’s claim to be in negotiations to provide
“new services to underserved markets in the mid-Atlantic Ocean region.” EchoStar Response, at 2.
The record seems to be bereft of any indication of the number of unserved households EchoStar has
found in the mid-Atlantic Ocean.
14
See Spectrum Five Opposition, at 6. EchoStar cites the Commission’s July 2013 decision affirming
the EchoStar 6 STA Grant for the proposition that the Commission has already addressed and rejected
this argument on the merits. EchoStar is wrong. At the point of the Commission decision cited by
EchoStar (¶ 15), the Commission reiterated that it found the original STA to be in the public interest
because the United States was able to fully protect orbital locations currently providing service to the
United States. EchoStar Satellite Operating Corp., 28 FCC Rcd 10412, at ¶ 15 (2013). That finding
does not apply to the later STA requests, which must be evaluated de novo as there are no “renewals”
of STAs. With no service requirements extant or imminent, EchoStar cannot show (and indeed has
made no attempt to show) that it would be seriously prejudiced by the denial of any of the pending
STA requests.

6

modification of EchoStar’s license for EchoStar 6,15 but they do not and cannot be deemed to

satisfy the second of the required elements for STA grants – i.e., that the public interest would

be seriously prejudiced by a denial of the STA request. With no service being provided or

even on the imminent horizon, there can be no prejudice from a denial of the STA request.

This is inexorably true for each of the pending STA extension/renewal requests.16 All of the

pending STA extension/renewal requests for EchoStar 6 at 96.2° W.L. should now be denied

or dismissed.

IV.

EchoStar’s
Responses
to
Spectrum
Five’s
Demonstration
that
the
Station-‐
Keeping
Condition
of
the
April
STA
has
been
Willfully
and
Repeatedly

Violated
is
Unavailing;
“Substantial
Compliance”
is
no
Substitute
for
Actual

Compliance.

In response to Spectrum Five’s demonstration that EchoStar 6 violated the

Commission’s condition of the EchoStar 60-Day STA Grant requiring EchoStar to maintain

the EchoStar 6 satellite within 0.05° W.L. of the 96.2° W.L. orbital location,17 EchoStar

makes two assertions – first, that the original STA did not specify when EchoStar was obliged

to commence maintaining EchoStar 6 within the applicable +/- 0.05° station-keeping box, and

second, that “the available tracking data shows substantial compliance with the FCC’s station-

15
EchoStar Response, at 3.
16
If it were known at the time of the initial STA in February/March 2013 that EchoStar would not
have offered a single bit of service to anyone over EchoStar 6 at 96.2° W.L. in the more than 300 days
since the STA was granted, this entire affair would have been avoided. The service arguments
advanced by EchoStar were a pretext to its true motivation – the securing of permanent rights to the
DBS slot at 95°/96° W.L. for itself and development partner SES, despite the continuing DBS freeze.
Clearly, normal licensing procedures for the modification application would have been sufficient for
the stated objective; the STA just wasted everyone’s time and left the Commission in a difficult
position of defending an anticompetitively-motivated action. This is especially the case given, as
noted above, that EchoStar and its development partner SES are fully capable of exploring service to
underserved markets in the mid-Atlantic Ocean region on any number of other satellites they control
that have better and more powerful coverage of the area in question.
17
Spectrum Five Opposition, at 2-4.

7

keeping requirement.”18 Neither assertion is true, and the second assertion is also irrelevant.

EchoStar has failed once again to respond to Spectrum Five’s serious allegations of

misconduct.

EchoStar argued to the Commission in earlier filings that since April 25, 2013,

EchoStar 6 has been completely within 0.05° of 96.2° W.L.19 Using real tracking data taken

from NORAD (a neutral party), Spectrum Five showed that EchoStar 6 was not within its

required +/- 0.05° station-keeping box during the first 60-day STA term and well thereafter.20

At the time Spectrum Five presented this data to the Commission (July 2013), EchoStar

criticized NORAD for being inaccurate and Spectrum Five for challenging the experienced

operator, EchoStar. As it turns out, NORAD knew where EchoStar 6 was, while EchoStar did

not. What is clear is that EchoStar 6 was not station-kept to within 0.05° of 96.2° W.L.

during the initial 60-day STA term.

In early January 2014, EchoStar – without regard to any of the pending STA requests

– made a new submission acknowledging that the original “data” it provided on EchoStar 6’s

location from April to June 2013 were inaccurate due to a calibration error in its TT&C

18
EchoStar Response, at 4.
19
See, e.g., Letter dated July 15, 2013, in File No. SAT-STA-20130510-00067, from P. Pham,
Counsel for EchoStar, to M. Dortch, Secretary, FCC, at 3 and Attachment 2 (EchoStar Spacecraft
Engineering Manager declares under penalty of perjury that “[f]rom April 25 to the present, the
satellite has remained fully within a 0.05° station-keeping box at all times.”). See also Letter dated
August 26, 2013, in File No. SAT-STA-20130510-00067, from B. Tramont, Counsel for EchoStar, to
M. Dortch, Secretary, FCC, at 2. As Spectrum Five noted in its Opposition, EchoStar made these
claims while attempting to dismiss or discredit NORAD data supplied by Spectrum Five which
showed that the EchoStar 6 satellite was clearly not station kept to within 0.05 degrees of 96.2° W.L.
during or after April 2013, and continuing on through the summer and into the fall. Spectrum Five
Opposition, at 2-3.
20
See Spectrum Five Opposition, at 3 & n.6.

8

system. 21 EchoStar provided the Commission with a “chart” that it asserts “depicts EchoStar

6’s east-west orbital movement and location based upon tracking data and calculations”

correcting for its calibration error.22 This means that EchoStar has not produced any “new”

data regarding EchoStar 6’s location from April through June 2013; it has only made an

attempt to reconstruct corrupt data after the fact.

Now, EchoStar comes back, in response to an opposition to its request for a fifth

extension of the initial STA from April 2013, and proffers the incredible argument that the

Commission’s condition for station-keeping did not specify when station-keeping had to

commence. To EchoStar, this means that station keeping to the required tolerance did not

have to commence during the initial term, or during the terms of the three succeeding (and

still pending) STAs. Instead, it means that the station keeping was acceptably commenced

during the term of the fourth STA extension, once EchoStar figured out where its satellite was

for the preceding eight months and corrected its telecommands.

The Commission should not stand for EchoStar’s disregard for the station-keeping

condition it imposed in the EchoStar 60-Day STA Grant. EchoStar shrugged off Spectrum

Five’s demonstrations of non-compliance back in July 2013, and did not “discover” its error

until after ITU began investigating the satellite’s location in October 2013. EchoStar then

waited three months after “discovering” its error to report the matter to the Commission

(under Section 1.65 of the Commission’s Rules, a regulation that requires reporting within 30

21
See Letter (redacted version) dated January 3, 2014, from J. Manner, EchoStar, to M. Dortch,
Secretary, FCC (“Manner Letter”). This Reply does not rely upon or utilize in any way material
EchoStar submitted to the Commission under request for confidential treatment, so there is no need for
redaction or confidential treatment of this Opposition.
22
Manner Letter, at 2.

9

days). Finally, EchoStar has, to this date, not sought a waiver or any relief from the

condition.

EchoStar’s claim that “the available tracking data shows substantial compliance with

the FCC’s station-keeping requirement”23 is both untrue and irrelevant. The condition to

maintain EchoStar 6 within 0.05° of 96.2° W.L. was not a best-efforts matter, it was a hard

and fast obligation. Either EchoStar complied with the condition or it did not. EchoStar did

not comply, and simply dismissed NORAD data. EchoStar offers no precedent for the

proposition that it could violate the condition and still be found in compliance with the

EchoStar 60-Day STA Grant.24

Moreover, EchoStar did not apprise the Commission of its supposedly newly-

discovered error until another three months had elapsed. EchoStar has filed multiple STA

requests for EchoStar 6 since the July demonstration (including two requests after its October

“discovery”), and never sought a waiver of the station-keeping obligation. This is the epitome

of willful and repeated violations of Commission obligations that results in enforcement

action at the Commission. Under no circumstances can the Commission ignore the

23
EchoStar Response, at 4.
24
EchoStar’s attempt to rely on a preliminary finding at the ITU regarding the United Kingdom’s
claim that EchoStar 6 satisfied the ITU “bringing-into-use” regulation for the BERMUDASAT-1
frequency assignments is both incorrect and unavailing. First, the ITU’s Radiocommunication Bureau
(“BR”) did not determine that EchoStar 6 “is in full compliance with the ITU’s station-keeping
requirement.” See EchoStar Response, at 4. The BR (improperly in Spectrum Five’s view) seemed to
base its determination on a station-keeping tolerance of +/- 0.1° (as allowed as a maximum in the
Region 2 BSS Plan), notwithstanding the BERMUDASAT-1 filings’ specification of +/- 0.05°
stationkeeping. Moreover, the BR confirmed that EchoStar 6 was not station-kept to within 0.05° of
96.2° W.L.; it found (again improperly for multiple reasons in Spectrum Five’s view) that EchoStar
“had the capability to maintain its position” within 0.05°. The BR finding is preliminary, and is being
taken to the Radio Regulations Board for review by the administration of the Netherlands. The BR’s
findings to date, however, not only fail to advance EchoStar’s claim, they confirm its violation of the
Commission’s station-keeping obligation from the EchoStar 60-Day STA Grant.

10

brazenness and gravity of EchoStar’s malfeasance; it certainly cannot reward such behavior

with a grant of any of the pending STA requests.

V.
EchoStar
6’s
Highly-‐Inclined
Operation
Prevents
EchoStar
from
Providing

Service
to
Any
Consumer-‐Grade,
Non-‐Tracking
Earth
Station
Antennas
of

the
Type
Used
in
DBS/BSS.

EchoStar responds ineffectively to Spectrum Five’s demonstration that EchoStar 6 is

incapable of providing the types of service outlined in the STA extension/renewal requests.

Spectrum Five, noting that EchoStar 6 was at approximately 1.3° of north-south excursion in

April 2013, and at approximately 1.9° of north-south excursion today, observed that the

satellite is incapable of providing any services to non-tracking earth stations.25

EchoStar does not take issue with the observation that tracking earth stations would be

required for operation with EchoStar 6. Instead, it asserts that the inclined-orbit operation of

EchoStar 6 is well suited for mobile services to ships and vessels that “require tracking earth

stations antennas to compensate for both the ship’s movement and EchoStar 6’s inclination

. . . .”26 EchoStar’s response confirms that operation of EchoStar 6 with fixed land-based

consumer-grade terminals such as those used in BSS/DBS is not possible due to the satellite’s

high inclination.

VI.
Conclusion

On the basis of Spectrum Five’s Opposition and the foregoing discussion, the

Commission must deny all of EchoStar’s pending requests for extension/renewal of the April

2013 STA grant authorizing the temporary relocation of EchoStar 6 to the 96.2° W.L. orbital

location. EchoStar and its development partner SES have numerous operational satellites (as

25
Spectrum Five Opposition, at 6-7.
26
EchoStar Response, at 5.
11

contrasted with the inoperative EchoStar 6 satellite) that are newer, have superior coverage of

the area they state they wish to serve, and more power. These existing operational satellites

are well suited to explore the future service opportunities EchoStar wants to explore under

STAs at 96.2° W.L. In light of the fact that this exploration is not exclusive to 96.2° W.L.,

and the EchoStar 6 satellite was inoperative as late as February 2014, the Commission should

rely on its normal licensing process; reject any further consideration of the STA requests;

order EchoStar 6 back to its prior location at 77° W.L.; and address any future opportunities

in the course of the pending modification of license application or in response to a new

modification application.

Respectfully submitted,

SPECTRUM FIVE LLC

By:__/s/ David Wilson_______
David Wilson
Chief Executive Officer

Spectrum Five LLC
807 Las Cimas Parkway
Suite 270
Austin, TX 78746
512.428.4750

March 11, 2014

12

CERTIFICATE OF SERVICE

I, Pam Conley, hereby certify that a true and correct copy of the foregoing Reply

of Spectrum Five LLC was served on the following, by First-Class U.S. Mail, postage

prepaid, this 11th day of March, 2014.

Jennifer A. Manner
Vice President of Regulatory Affairs
EchoStar Satellite Operating Company
11717 Exploration Lane
Germantown, MD 20876

___/s/___Pam Conley____________

Document Created: 2014-03-11 16:51:20
Document Modified: 2014-03-11 16:51:20

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