Attachment Narrative

This document pretains to SAT-STA-20131111-00130 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2013111100130_1020385

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

                                                 )
                                                 )
In the Matter of                                 )
                                                 )
ECHOSTAR SATELLITE OPERATING                     ) File No. SAT-STA-20130514-00069
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

December 23, 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-20130514-00069 (granted June 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




3
 EchoStar 3 has been operating at 61.8° W.L. while EchoStar 12 has been operating at 61.35°
W.L. and EchoStar 16 at 61.5° W.L. Until recently, EchoStar 15 was also operating in the 61.5°
W.L. cluster, but has now been relocated to 45.1° W.L. Stamp Grant, SAT-MOD-20130503-
00066, Call Sign S2811 (granted June 20, 2013).
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-MOD-
20130503-00066, Call Sign S2811 (granted June 20, 2013), EchoStar is evaluating spare
capacity requirements for the 61.5° W.L. cluster and exploring other uses for the EchoStar 3
satellite.
6
    See Stamp Grant, File No. SAT-STA-20120424-00073 (granted Apr. 30, 2012).
7
    Id.


                                                -2-


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.

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

November 11, 2013




                                              -3-



Document Created: 2013-11-08 14:20:54
Document Modified: 2013-11-08 14:20:54

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