Attachment STA Request Narrativ

This document pretains to SES-STA-20150925-00646 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2015092500646_1105645

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) In the Matter of ) File No. SES-STA-20150209-00068 ) File No. SES-STA-2015_____-_____ EchoStar Broadcasting Corporation ) Call Sign E010242 ) Applications for Renewal of Special ) File No. SES-STA-20150209-00067 Temporary Authority to Operate Two ) File No. SES-STA-2015_____-_____ Transmit/Receive Earth Stations with ) Call Sign E020248 EchoStar 3 at 61.8° 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 (together 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 October 28, 2015.2 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-20150209-00068, Call Sign E010242 (granted May 1, 2015); File No SES-STA-20150209-00067, Call Sign E020248 (granted May 1, 2015).

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. Accordingly, grant of the requested in the public interest. I. THE 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.5 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.6 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 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. 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. 4 Stamp Grant, File No. SAT-STA-20120424-00073, Call Sign S2741 (granted Apr. 30, 2012). EchoStar 3 continues to operate at 61.8° W.L. 5 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). 6 See id.

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 Jennifer A. Manner Vice President, Regulatory Affairs EchoStar Broadcasting Corporation 11717 Exploration Lane Germantown, MD 20876 (301) 428-5893 jennifer.manner@echostar.com September 25, 2015


Document Created: 2015-09-25 09:06:59
Document Modified: 2015-09-25 09:06:59
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