20111107 STA Supplem

SUPPLEMENT submitted by HNS License Sub, LLC

STA Supplement

2011-11-07

This document pretains to SES-STA-20111024-01253 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2011102401253_925102

              LERMAN
I_.           SENTER
              PLLC                                                                    STEPHEN D. BARUCH
                                                                                           202.416,.6782
                                                                                     SBARUCH @LERMANSENTER.COM




  WASHINGTON, DC                      November 7, 2011

VIA ELECTRONIC POSTING

Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

                       Re:     Supplement to HNS License Sub, LLC
                               Request for Special Temporary Authority
                               File No. SES—STA—20111024—01253(Call Sign E110149)

Dear Ms. Dortch:

        By this letter, HNS License Sub, LLC ("Hughes") seeks to supplement its above—
referenced pending request for Special Temporary Authority ("STA Request") by adding one
potential point of communication to the four satellites that were identified as potential points of
communication in the STA Request. Hughes‘s pending STA request seeks to conduct
operational testing of Hughes‘s proposed new 6.3 meter and 8.1 meter earth station antennas
under Call Sign E110149 at the 15 locations that will be used for these gateway antennas that
will operate with Hughes Network Systems, LLC‘s forthcoming Jupiter 107W satellite upon its
launch next year. Hughes here proposes to increase testing flexibility by adding a new U.S.—
licensed satellite on which it can conduct its Ka—band testing. In addition, Hughes modifies the
start date of the STA Request; the new start date required for the testing program is
November 14, 2011 (rather than November 1, 2011).

       In the STA Request, Hughes identified three satellites — AMC—15 at 105° W.L., AMC—16
at 85° W.L., and Galaxy 28 at 89° W.L. — as the spacecraft Hughes would use for the antenna
testing. With Ka—band testing, particularly short—term testing of the type Hughes proposes,
securing access to satellite capacity is a real challenge. To improve flexibility for the tests which
could need to take place at any given time from one of the 15 gateway locations, Hughes
proposes to add an additional U.S.—licensed Ka—band satellite — EchoStar 9 at 121° W.L. — to the
list of satellites from which Hughes can secure capacity for the testing program being undertaken
pursuant to the STA Request. Specification of this additional point of communication for
temporary testing is the only difference between what Hughes proposed in the underlying earth
station blanket license application (File No. SES—LIC—20111021—01243) under Call Sign
E110149, and what it seeks to do under the STA Request. All other operational parameters,
including frequencies, are as proposed in the license application.




                         2000 K STREET NW, SUITE 600 | WASHINGTON, DC 20006—1809
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         Marlene H. Dortch, Secretary


Ig       November 7, 2011
         Page —2—


         Timing is critical to Hughes here. Construction teams are scheduled to complete
installation of the first of the gateway antennas this week, and operation under the STA Request
will be expected to begin on November 14. This is roughly two weeks later than the
November 1, 2011 date specified in the STA Request. In each case, the construction/operations
crew has only limited time within which to test the antenna to complete its installation process
before having to move to their next installation assignment. If the testing were not able to be
done before the crew departs a particular gateway site, it is uncertain whether another
opportunity would be available before the antenna was required to commence regular operation
with Hughes Network Systems LLC Jupiter 1 satellite following its 2012 launch. Hughes
believes it is imperative to trouble shoot the first installation of each of the two antenna types
that will comprise the gateway component of the Jupiter 107W network before building
additional antennas that include design or operational elements that may be shown to be in need
of correction during the tests of the first installations. Cost considerations involved in returning
the crew to the site come into play as well.

        Under these conditions, Hughes requests authorization to conduct its temporary testing of
the 15 new 6.3 meter and 8.1 meter antennas that will comprise the Jupiter 107W gateway
network using uplink frequencies in the 28.35—28.6 and 29.25—30 GHz bands based on
availability following consultation with the operators of the AMC—15, AMC—16, Galaxy 28, and
EchoStar 9 satellites. All testing will be done at power levels consistent with Section 25.138 of
the Commission‘s rules and the underlying license application for Call Sign E110149. All other
information in the STA pertaining to the proposed antennas is unchanged. Delays in the onset of
testing beyond the November 14, 2011 commentement date requested here would work a real
hardship on Hughes and leave key technical considerations for the upcoming Jupiter program
unresolved.

       A copy of this letter is being filed electronically, through IBFS, into the file of the above—
referenced STA.

       Please direct any questions pertaining to this matter to me.

                                                      Respectfully     yours,




cc: Mr. Paul Blais (by email)



Document Created: 2011-11-07 16:33:18
Document Modified: 2011-11-07 16:33:18

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