Attachment STA Justification

This document pretains to SES-STA-20100624-00784 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2010062400784_824028

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) ) In the Matter of ) ) ECHOSTAR CORPORATION ) ) Application for Special Temporary Authority ) File No. SES-STA-_____-_____ to Operate Its Transmit/Receive Earth ) Call Sign E980005 Stations to Launch and Test the EchoStar 15 ) Satellite at 61.55° W.L. ) File No. SES-STA-_____-_____ ) Call Sign E070014 ) ) APPLICATION FOR SPECIAL TEMPORARY AUTHORITY EchoStar Corporation (“EchoStar”) respectfully requests 60-day Special Temporary Authority (“STA”), commencing on or about July 10, 2010, to permit EchoStar to operate two of its transmit/receive earth stations (Call Signs E980005 and E070014) (1) to perform telemetry, tracking and control (“TT&C”) operations while raising and maneuvering its new EchoStar 15 satellite to the 61.55° W.L. orbital location, and (2) to perform in-orbit testing of the satellite in the 12.2-12.7 and 17.3-17.8 GHz bands at 61.55° W.L.1 EchoStar has filed an application to launch EchoStar 15 and operate it at the 61.5° W.L. nominal orbital location (specifically 61.55° W.L.).2 Testing EchoStar 15 and conducting TT&C operations at 61.55° W.L. will ensure the safe and rapid deployment of EchoStar 15 while avoiding disruption to existing customers at 1 EchoStar has filed applications for (1) STA to launch and test EchoStar 15 at 61.55° W.L. (File No. SAT-STA-20100615-00133) (filed June 15, 2010); and (2) STA to operate EchoStar 15 at 61.55 W.L. (File No. SAT-STA-20100615-00134) (filed June 15, 2010). 2 File No. SAT-LOA-20100310-00043, Call Sign S2811 (filed March 10, 2010) (“EchoStar 15 Application”).

61.55° W.L. The proposed testing also will not adversely affect the operations of any other spacecraft or other authorized spectrum users. EchoStar 15 is scheduled to launch on July 10, 2010, and EchoStar requests action on this request by that date. I. GRANT OF THIS APPLICATION IS IN THE PUBLIC INTEREST The Commission has a long-standing policy of granting Special Temporary Authority where such authorization will not cause harmful interference and will serve the public interest, convenience, and necessity.3 The requested operations meet both of these tests. First, neither moving testing EchoStar 15 to 61.55° W.L. nor testing it at that slot will cause harmful interference to any other spacecraft or authorized user of the spectrum. While the satellite is raised and moved to 61.55° all transponders (other than the TT&C transponders) on the satellite will be turned off. Further, EchoStar operates all three satellites currently operating within the 61.5° W.L. orbital cluster – EchoStar 3, EchoStar 6, and EchoStar 12 – and intends to conduct testing on a non-interference basis using the available frequencies not capable of being used by those satellites. EchoStar is confident it will be able to fully coordinate its operations during testing, thereby avoiding any harm to consumers. EchoStar is not aware of any other BSS satellites planned to be brought into operation near 61.55° W.L. during the time frame of EchoStar 15’s in-orbit testing or in the foreseeable future. Second, the requested STA serves the public interest, as it will allow EchoStar to ensure that the satellite is safely maneuvered to the 61.55 W.L. orbital location and will operate correctly prior to bringing the satellite into service, thereby avoiding any subsequent interruption in service. Once testing is complete, EchoStar 15 will begin DBS operations from 61.55. 3 See, e.g., Newcomb Communications, Inc., Order and Authorization, 8 FCC Rcd. 3631, 3633 (1993); Columbia Communications Corp., Order, 11 FCC Rcd. 8639, 8640 (1996); American Telephone & Telegraph Co., Order, 8 FCC Rcd. 8742 (1993). 2

II. SECTION 304 WAIVER In accordance with Section 304 of the Communications Act of 1934, 47 U.S.C. § 304, EchoStar hereby waives any claim to the use of any particular frequency or of the electromagnetic spectrum because of the previous use of the same, whether by license or otherwise. III. CONCLUSION For the foregoing reasons, EchoStar respectfully requests the expeditious grant of a 60- day STA, commencing on or about July 10, 2010, to operate two of its transmit/receive earth stations (Call Signs E980005 and E070014) to launch and raise EchoStar 15 to, and conduct testing at, 61.55° W.L. During the orbital raising of EchoStar 15 to 61.55° W.L., all transponders other than the TT&C transponders will be switched off, and EchoStar will operate its earth stations subject to the following conditions: 1. No harmful interference will be caused to any lawfully operating satellite network or radio communication system, and EchoStar’s operations will cease immediately upon notification of harmful interference. Furthermore, EchoStar shall notify the Commission immediately, in writing, of such an event. 2. EchoStar will accept interference from any lawfully operating satellite network or radio communication system. In addition, during in-orbit testing, EchoStar will operate its earth stations subject to the following conditions: 1. EchoStar will not cause harmful interference to, and will not claim protection from interference caused by, any other lawfully operating satellites or radiocommunications systems. 2. Upon notification of any harmful interference, EchoStar will cease its test operations immediately. In addition, EchoStar will inform the Commission in writing that it has received such a notification. 3

Respectfully submitted, EchoStar Corporation _________/s/_____________________ Pantelis Michalopoulos Alison Minea Christopher R. Bjornson Corporate Counsel Andrew W. Guhr EchoStar Corporation Steptoe & Johnson LLP 1110 Vermont Avenue NW, Suite 750 1330 Connecticut Avenue N.W. Washington, DC 20005 Washington, D.C. 20036 (202) 293-1216 (202) 429-3000 Counsel for EchoStar Corporation June 15, 2010 4


Document Created: 2010-06-22 17:53:21
Document Modified: 2010-06-22 17:53:21
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