HNS Certification of

LETTER submitted by HNS License Sub, LLC

Certification of Completion of Construction

2016-10-13

This document pretains to SES-LIC-20150604-00347 for License on a Satellite Earth Station filing.

IBFS_SESLIC2015060400347_1155346

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 Signs E150080, E150081, E150083, E150084, E150086, E150088, E150090 & E150091
         File Nos. SES-LIC-20150604-00336, SES-LIC-20150604-00337, SES-LIC-20150604-
         00339, SES-LIC-20150604-00340, SES-LIC-20150604-00342, SES-LIC-20150604-
         00344, SES-LIC-20150604-00346 & SES-LIC-20150604-00347

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 stations, licensed as of December 2, 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 stations will remain operational during the license period, unless the license is
         submitted for cancellation.


1
  The earth stations are 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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