HNS Certification of

LETTER submitted by HNS License Sub, LLC

Certification of Completion of Construction

2016-10-13

This document pretains to SES-AMD-20150915-00594 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2015091500594_1155331

October 13, 2016 By Electronic Filing Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Certification of Completion of Earth Station Construction Call Sign E150082 File Nos. SES-LIC-20150604-00338 & SES-AMD-20150915-00594 Dear Ms. Dortch: Pursuant to 47 C.F.R. § 25.133(b)(1), HNS License Sub, LLC certifies the following: (i) construction of the above-referenced earth station, licensed as of December 8, 2015, has been completed, and has been tested and found to perform within authorized gain patterns or off-axis EIRP density levels; (ii) the earth stations are operational, as of October 1, 2016;1 (iii) the earth station will remain operational during the license period, unless the license is submitted for cancellation. 1 The earth station is authorized to communicate with the Jupiter 2/EchoStar XIX (formerly, Jupiter 97) satellite, scheduled to launch in December 2016. Thus, earth station operations currently are limited to test transmissions, and full commercial operations will commence upon launch of Jupiter 2. See Improving Public Safety Communications in the 800 MHz Band, Memorandum Opinion and Order and Further Notice of Proposed Rulemaking, 23 FCC Rcd 4393 ¶ 48 (2008) (“[F]or purposes of certifying that a satellite system is operational, we have not required that the certification be based upon commencement of full commercial operations …. [T]he certification [for 2 GHz mobile satellite systems] can be based upon [test] transmissions … and does not require commencement of full commercial operations.”). In an abundance of caution, HNS requests a waiver, to the extent required, of the one-year construction/operation requirement to permit commencement of earth station operations based upon limited test transmissions, followed by full commercial operations upon launch of Jupiter 2. The requested waiver is consistent with the underlying regulatory purpose to ensure prompt deployment, and otherwise serves the public interest. See 47 C.F.R. § 1.3; WAIT Radio v. FCC, 418 F.2d 1153, 1157 (D.C. Cir. 1969), cert. denied, 409 U.S. 1027 (1972); Northeast Cellular Tel. Co., L.P. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990).

October 13, 2016 Page 2 of 2 Please direct any questions regarding this matter to the undersigned. Sincerely, /s/ Jennifer A. Manner Jennifer A. Manner Senior Vice President, Regulatory Affairs cc: Paul Blais (FCC)


Document Created: 2010-01-01 00:00:00
Document Modified: 2010-01-01 00:00:00
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