Attachment Narrative

This document pretains to SES-STA-20140106-00010 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2014010600010_1031934

                                      Before the
                       FEDERAL COMMUNICATIONS COMMISSION
                                Washington, D.C. 20554

                                                )
                                                )
In the Matter of                                )   File No. SES-STA-20130514-00390
                                                )   File No. SES-STA-2014____-_____
ECHOSTAR BROADCASTING CORPORATION               )   Call Sign E010242
                                                )
Applications for Renewal of Special             )   File No. SES-STA-20130514-00389
Temporary Authority to Operate Two              )   File No. SES-STA-2014____-_____
Transmit/Receive Earth Stations with            )   Call Sign E020248
EchoStar 3 at 61.8º W.L.                        )
                                                )


                             APPLICATIONS FOR RENEWAL OF
                            SPECIAL TEMPORARY AUTHORITY

         By these Applications, and pursuant to Section 25.120(b)(2) of the Commission’s rules,1

EchoStar Broadcasting Corporation (“EBC,” and with its affiliates, “EchoStar”) requests renewal

of its special temporary authority (“STA”) to operate two transmit/receive earth stations (Call

Signs E010242 and E020248) to provide only telemetry, tracking, and control (“TT&C”) for the

EchoStar 3 satellite at 61.8º W.L. for 180 days. Specifically, EchoStar requests continued

authority to conduct TT&C over the following frequencies: 17301.5 MHz (command); and

12201.0 MHz, 12203.0 MHz, and 12699.0 MHz (telemetry). The current STAs for each of the

earth stations to provide TT&C for EchoStar 3 at 61.8° W.L. expire on February 15, 2014.2

         EchoStar launched the EchoStar 16 satellite in November 2012 to provide additional

capacity for its customer, DISH Network L.L.C., at the nominal 61.5º W.L. orbital location. In

anticipation of the arrival of EchoStar 16 at 61.5º W.L., and to provide adequate station-keeping


1
    See 47 C.F.R. § 25.120(b)(2).
2
 See Stamp Grant, File Nos. SES-STA-20130514-00390, Call Sign E010242 (granted Aug. 19,
2013); SES-STA-20130514-00389, Call Sign E020248 (granted Aug. 19, 2013).


margins for all the satellites in the 61.5° W.L. orbital cluster,3 EchoStar repositioned EchoStar 3

to 61.8º W.L. in early 2012.4 Operating at 61.8º W.L. as an in-orbit spare, EchoStar 3 remains in

close proximity to the 61.5º W.L. nominal orbital location and available, if needed, for

repositioning within the orbital cluster to provide service.5 Accordingly, grant of the requested

STAs is in the public interest.

I.       THIS REQUEST IS IN THE PUBLIC INTEREST AND WILL NOT CAUSE
         HARMFUL INTERFERENCE

         The requested STAs are in the public interest for the same reason EchoStar was initially

granted STA to operate these earth stations with EchoStar 3 at 61.8° W.L.6 Grant of this

application will ensure continued safe station-keeping margins for each of the satellites that are

located at the nominal 61.5° W.L. orbital location. Moreover, grant of this application will not

cause harmful interference because EchoStar will conduct TT&C operations with EchoStar 3 at

61.8º W.L. in accordance with the conditions imposed on the original STA grant.7

II.      WAIVER PURSUANT TO SECTION 304 OF THE ACT

         In accordance with Section 304 of the Communications Act of 1934, as amended,

47 U.S.C. § 304, EchoStar hereby waives any claim to the use of any particular frequency or use



3
  EchoStar 3 has been operating at 61.8° W.L. while EchoStar 12 has been operating at 61.35°
W.L. and EchoStar 16 at 61.5° W.L. EchoStar 15 previously operated at 61.65° W.L., but has
since been relocated to the 45° W.L. cluster.
4
    Stamp Grant, File No. SAT-STA-20120424-00073, Call Sign S2741 (granted Apr. 30, 2012).
5
 With the relocation of EchoStar 15 to the 45° W.L. cluster, Stamp Grant, SAT-MOD-
20130503-00066, Call Sign S2811 (granted June 20, 2013), EchoStar is evaluating spare
capacity requirements for the 61.5° W.L. cluster. As part of these considerations, EchoStar is
considering its options for bringing EchoStar 3 back within the 61.5° W.L. orbital cluster.
6
 See Stamp Grant, File Nos. SES-STA-20120424-00384, Call Sign E010242 (granted May 1,
2012); SES-STA-20120424-00386, Call Sign E020248 (granted May 1, 2012).
7
 See Stamp Grant, File Nos. SES-STA-20120424-00384, Call Sign E010242 (granted May 1,
2012); SES-STA-20120424-00386, Call Sign E020248 (granted May 1, 2012).


                                                 2


of the electromagnetic spectrum as against the regulatory power of the United States because of

the previous use of the same, whether by license or otherwise.

III.   CONCLUSION

       For the foregoing reasons, EchoStar respectfully requests the grant of its application for

renewal of its 180-day special temporary authority to operate two transmit/receive earth stations

(Call Signs E010242 and E020248) to provide TT&C for EchoStar 3 at 61.8º W.L.

                                             Respectfully submitted,



                                                            /s/
                                             Jennifer A. Manner
                                             Vice President, Regulatory Affairs
                                             EchoStar Corporation
                                             11717 Exploration Lane
                                             Germantown, MD 20817
                                             (301) 428-5893
                                             jennifer.manner@echostar.com

January 6, 2014




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Document Created: 2014-01-06 12:10:25
Document Modified: 2014-01-06 12:10:25

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