Attachment Narrative

This document pretains to SES-MFS-20150401-00186 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2015040100186_1081883

HNS License Sub, LLC FCC Form 312 Modification Narrative Page 1 of 4 Description of the Application Background Pursuant to Section 25.117 of the Federal Communications Commission’s rules,1 HNS License Sub, LLC (“Hughes”) requests consent to modify its earth station license for Call Sign E060445 (File No. SES-MFS-20120322-00290). With this application, Hughes seeks authorization for the following modifications to its license: i) add the Jupiter 97W (EchoStar XIX) satellite at 97.1° W.L. as a point of communication for each antenna type; and ii) increase the number of certain antenna types to five (5) million terminals under this blanket license. JUPITER 97W as a New Point of Communication On July 27, 2012, the FCC authorized Hughes to access the U.S. market using Jupiter 97W, a satellite that will operate in the Ka-band and provide broadband services to U.S. consumers across the country.2 On December 10, 2014, Hughes filed an application, which is pending, to modify its authorization, in part, to update the FCC licensing information associated with the satellite to reflect that it will be operated by Hughes under the International Telecommunications Union (“ITU”) network RAGGIANA-5 registered at the ITU by Papua 1 47 C.F.R § 25.117. 2 See Hughes, Letter of Intent, IBFS File No. SAT-LOI-20110809-00148 (granted Jul. 27, 2012). The application was placed on Public Notice on Mar. 20, 2015.

HNS License Sub, LLC FCC Form 312 Modification Narrative Page 2 of 4 New Guinea and to operate in the frequency bands 18.3-19.3 GHz, 19.7-20.2 GHz 27.8-29.1 GHz and 29.25-30.0 GHz.3 As stated above, Hughes seeks to add the Jupiter 97W satellite at 97.1° W.L. as a point of communication to all antennas included under this authorization.4 Maximum Number of Remotes Hughes, through this modification, also seeks authorization to increase the maximum number of terminals identified under site ID “TR 74 CM” and site IDs “74CM(FA)” to five (5) million terminals. Hughes is not proposing to add any additional authorized frequencies or modify the technical parameters of any of the antennas under this authorization. Moreover, Hughes will continue to operate the remote terminals under this authorization pursuant to coordination agreements between Hughes and Iridium Constellation LLC.5 Accordingly, there are no interference concerns with the application. 3 See IBFS File No. SAT-MOD-20141210-00127 (filed Dec. 10, 2014). 4 The FCC added the Jupiter 97W satellite to the Ka-band Permitted List at the 97.1° W.L. orbital location for the 28.35-28.6 GHz and 29.25-30.0 GHz frequency bands (Earth-to-space), and the 18.3-18.8 GHz and 19.7-20.2 GHz frequency bands (space-to-Earth). See Stamp Grant, SAT- LOI-20110809-00148 ¶ 10 (granted Jul. 27, 2012). However, E060445 does not have the ALSAT designation so it is not authorized to communicate with all satellites on the Permitted Space Station List. 5 See SES-MFS-20120426-00395, et al., Joint Notice of Withdraw of Pending Petitions to Deny of HNS License Sub, LLC and Iridium Constellation LLC (filed Jan. 9, 2014).

HNS License Sub, LLC FCC Form 312 Modification Narrative Page 3 of 4 Deletion of Antenna ID As an administrative matter, Hughes notes that the three earth station antenna manufacturers have been either acquired or rebranded as follows: a. “Raven” is now known as “Skyware Global”; b. “Prodelin” is now known as “GD Satcom”; c. “Andrew” is now known as “ASC Signal Corp” Consequential to these changes, the antenna ids “74CM(FA)” and “74CM(FB) are the same, allowing the deletion of all entries under this Call Sign relating to “74CM(FB)” Coordination with NGSO Feeder Links The frequency band 29.25-29.50 GHz which will be used by the remotes in this license that will be associated with JUPITER 97W is shared on a co-primary basis with the feeder link stations of MSS NGSO systems under 47 C.F.R. §25.258. Hughes has previously concluded a coordination agreement with Iridium, the only NGSO licensee in this band. By complying with the coordination agreement, Hughes will ensure the protection of Iridium’s operations in the band. Conclusion Grant of this application is in the public interest as it will allow Hughes to deploy the remote earth station terminals needed to support its broadband consumers utilizing the Jupiter

HNS License Sub, LLC FCC Form 312 Modification Narrative Page 4 of 4 97W satellite, which is scheduled to be launched in 2016. Specifically, Jupiter 97W will offer significant additional capacity to the Hughes fleet to meet the broadband needs of business and residential users in North America, delivering such high demand services as HD video programming, on-demand entertainment, digital music, interactive television, video conferencing and high capacity two-way communications. Accordingly, grant of this modification application is in the public interest and the FCC should expeditiously grant this modification. Respectfully Submitted, /s/ Steven Doiron Steven Doiron Senior Director, Regulatory Affairs HNS License Sub, LLC 11717 Exploration Lane Germantown, MD 20876 (301)428-5506


Document Created: 2015-04-01 09:20:32
Document Modified: 2015-04-01 09:20:32
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