Attachment Narrative

This document pretains to SES-STA-20120703-00629 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2012070300629_958709

HNS License Sub, LLC FCC Form 312 – STA Narrative Exhibit July 2012 REQUEST FOR SPECIAL TEMPORARY AUTHORITY Call Sign: E060445 HNS License Sub, LLC (“Hughes”) hereby requests Special Temporary Authority (“STA”) beginning on July 21, 2012, and continuing for 60 days thereafter (to September 19, 2012), to utilize the earth stations that are authorized under Call Sign E060445, and proposed in pending modification application File No. SES-MFS-20120322-00290, as amended by File No. SES-AFS-20120426-00396 (collectively, the “Modification Application”), to operate with the U.S.-licensed EchoStar XVII satellite at the 107.1º W.L. orbital location on a pre-grant basis – subject to the conditions proposed herein. All operations under the requested STA will be within the technical parameters specified for the blanket-licensed antennas on Hughes’s license under Call Sign E060445 and the Modification Application, with the exception that the proposed new 69 centimeter antennas will not operate in the 29.25-29.3 GHz band, and none of the existing terminals on the license will use the 29.25-29.3 GHz band to communicate with EchoStar XVII under this STA. Hughes has on file with the FCC a pending application for permanent authority to utilize the existing antennas under Call Sign E060445 and the new antennas proposed in the Modification Application to communicate with EchoStar XVII (as licensed by the Commission on June 12, 2012 in File No. SAT-LOA-20120422-00075). There are unresolved interference issues with respect only to the 29.25-29.3 GHz frequency segment to be used at various continental U.S. (“CONUS”) locations, as the frequency segment overlaps with spectrum utilized by the Iridium mobile-satellite service system from a Tempe, Arizona earth station. 308496

Hughes recognizes that its proposed operation under this STA request is on a non- interfering basis. In the unlikely event that interference issues are raised during IOT operations, Hughes is designating as a contact point Bill McHargue at its Network Management Center in Germantown (Telephone: 301-428-7205). Mr. McHargue will be available on a 24/7 basis to field any interference complaints and address any other technical issues that may arise with the IOT operation. The underlying issue raised by Iridium will need to be addressed in one way or another before Hughes can begin permanent use of the 29.25-29.3 GHz segment for its user terminal operations under the Modification Application. Allowing limited deployment of terminals under the Modification Application in a way that will not affect the party complaining of interference will expedite the introduction of important new satellite broadband services using more streamlined equipment, and thus would advance the public interest. Moreover, the requested STA will serve the public interest by ensuring that new broadband customers can begin to make productive use of the valuable spectrum and orbital resources on EchoStar XVII as soon as possible. On the other hand, denying such authority because of a pending objection that is inapposite to the proposed use would clearly be contrary to the public interest. Given the sensitivity of this proposed use of 29.25-29.3 GHz by earth stations authorized under Call Sign E060445, Hughes is submitting this STA request more than three business days in advance of the date of requested first use. Because Hughes has a pending application to access EchoStar XVII from the same antenna as a U.S.-licensed satellite, a 60-day term is appropriate. See 47 C.F.R. § 25.120(b)(3). 308496

To avoid ex parte issues that result from the reference to the Iridium issues relating to the Modification Application, Hughes will provide an electronic copy of the instant STA request to Iridium. In sum, and in the event that the Commission has not resolved the pending issue of potential interference to Iridium from the use of Hughes’s earth stations under Call Sign E060445 and the Modification Application to communicate with EchoStar XVII as a U.S.- licensed satellite prior to July 21, 2012, Hughes respectfully requests authority to operate its terminals as licensed and proposed in the Modification Application – with the exception that the proposed new 69 centimeter antennas will not operate in the 29.25-29.3 GHz band, and none of the existing terminals on the license will use the 29.25-29.3 GHz band to communicate with EchoStar XVII under this STA. Operation under this STA request would be for the 60-day period starting July 21, 2012 and ending on September 19, 2012. 308496


Document Created: 2012-07-03 14:24:45
Document Modified: 2012-07-03 14:24:45
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