Attachment Exhibit 1

This document pretains to SES-STA-20151014-00688 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2015101400688_1107692

                                             EXHIBIT 1

        REQUEST FOR RENEWAL OF SPECIAL TEMPORARY AUTHORIZATION
                      (Response to Question 8, FCC Form 312)

          Pursuant to Section 25.120(b)(3) of the Commission’s rules,1 EchoStar Satellite

Operating Corporation and EchoStar Broadcasting Corporation (together with their affiliates,

“EchoStar”) request to renew their special temporary authorizations (“STAs”), for a 180-day

period – until April 29, 2016, to continue: (i) moving and operating the EchoStar 15 satellite

(Call Sign S2811) at the 61.65º W.L. orbital location as an in-orbit spare; and (iii) operating the

associated earth stations (Call Signs E080007 and E080120) to provide telemetry, tracking, and

control (“TT&C”) communications during EchoStar 15’s move and operations at 61.65º W.L.2

EchoStar is requesting this STA renewal to allow it to continue moving and operating EchoStar

15 as an in-orbit spare at 61.65º W.L. in order to provide back-up capacity for DISH Network,

L.L.C. (“DISH”).

I.        BACKGROUND

          HNS Americas Comunicações Ltda. (“HNSA”), a wholly owned, indirect subsidiary of

EchoStar Corporation, holds an authorization to provide Broadcast Satellite Service (“BSS”) to

Brazil from the nominal 45º W.L. orbital location. 3 Accordingly, EchoStar has been operating

the EchoStar 15 satellite in accordance with Brazil’s Region 2 BSS plan for the 45° W.L. cluster,

as well as in conformity with HNSA’s authorization and applicable Brazilian laws, rules, and



1
    See 47 C.F.R. § 25.120(b)(3).
2
 See EchoStar, Stamp Grant, IBFS File Nos. SAT-STA-20150910-00062, SES-STA-20150910-00570,
and SES-STA-20150910-00573 (granted Sept. 30, 2015) (“EchoStar 15 September 2015 STAs”).
3
 A certified translation of the Brazilian authorization is attached to EchoStar’s previously granted
modification application to change EchoStar 15’s assigned orbital location from 44.9º W.L. to 45.1º W.L.
See EchoStar, Application for Minor Modification, Exh. 1 (Term of Right of Exploration), IBFS File No.
SAT-MOD-20130503-00066 (filed May 3, 2013).

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regulations, while HNSA designs and constructs a new, purpose-built satellite for the orbital

location, consistent with HNSA’s Brazilian authorization.

              In late 2012, the Commission authorized EchoStar to relocate and operate EchoStar 15 at

44.9º W.L.4 In June 2013, the Commission modified that authorization to permit operations on a

regular basis at 45.1º W.L. instead of 44.9º W.L., in order to accommodate EchoStar’s

operational preference to position EchoStar 15 at 45.1º W.L. as an interim satellite during the

design and construction of a new satellite. 5

              Recently, DISH, an affiliate and customer of EchoStar, has requested that a spare satellite

be made available to provide backup capacity for its satellite television network, and EchoStar

has determined that moving EchoStar 15 to 61.65º W.L. would be an efficient use of its satellite

fleet to accommodate the request. Accordingly, Echostar sought and obtained 30-day STAs to

move and operate EchoStar 15 at 61.65º W.L. as an in-orbit spare, and to conduct associated

earth station TT&C operations. 6 EchoStar expects to commence moving EchoStar 15 from 45.1º

W.L. to 61.65º W.L. on October 14, pursuant to grant of the STAs.7 Following EchoStar 15’s

expected arrival at 61.65º W.L. on approximately November 16, 2015, EchoStar intends to

continue operating the satellite at that orbital location in the short term, subject to FCC grant of

the requested STA renewal. 8



4
  See EchoStar, Stamp Grant, IBFS File No. SAT-STA-20121022-00185 (granted Nov. 19, 2012)
(authorizing relocation to 44.9° W.L. pursuant to STA); EchoStar, Stamp Grant, File No. SAT-MOD-
20120814-00130 (granted Dec. 13, 2012) (authorizing operations at 44.9° W.L.).
5
 See EchoStar, Stamp Grant, IBFS File No. SAT-MOD-20130503-00066 (granted June 20, 2013). On
May 9, 2013, the FCC granted special temporary authority to drift and operate EchoStar 15 at 45.1º W.L.
See EchoStar, Stamp Grant, IBFS File No. SAT-STA-20130502-00065 (granted May 8, 2013).
6
    See EchoStar 15 September 2015 STAs.
7
    See id.
8
 EchoStar currently has pending modification applications for regular authority to operate EchoStar 15 at
72.6º W.L. as an in-orbit spare and to conduct associated earth station TT&C operations. See EchoStar,
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II.      THE REQUESTED STA OPERATIONS WILL SERVE THE PUBLIC INTEREST
         AND WILL CAUSE NO HARMFUL INTERFERENCE

         Grant of this STA request will serve the public interest by allowing EchoStar the

flexibility to manage its satellite fleet efficiently and operate the EchoStar 15 satellite an in-orbit

spare that will be readily available for backup service, if required. At the same time, the

proposed operations will cause no harmful interference to other authorized services because

EchoStar 15 will operate only on Ku BSS TT&C frequencies as an in-orbit spare, and there are

no satellites operating within two degrees of 61.65º W.L. on overlapping TT&C frequencies, as

discussed in the revised Technical Annex filed in support of the EchoStar 15 September 2015

STAs.9 Furthermore, as noted below, EchoStar 15 will operate at 61.65º W.L. on an unprotected

and non-harmful interference basis. In the event that EchoStar 15’s communications payload is

required to provide backup service, EchoStar will seek appropriate authorization prior to

commencing service.

III.     OPERATIONAL PARAMETERS

         EchoStar will move and operate EchoStar 15 at 61.65º W.L. subject to the conditions

typically imposed on U.S.-licensed satellites operating in accordance with non-U.S. ITU filings,

including the following:

1.       All authorized operations will be on an unprotected and non-harmful interference
         basis (i.e., EchoStar will not cause harmful interference to, and will not claim
         interference protection from, any other lawfully operating station).




IBFS File Nos. SAT-MOD-20150911-00063, SES-MFS-20150911-00571, and SES-MFS-20150911-
00572 (filed Sept. 11, 2015). EchoStar intends to amend or supplement the pending modification
applications shortly.
9
    See Letter from Jennifer A. Manner, EchoStar, to Marlene H. Dortch, Secretary, FCC, IBFS File
Nos. SAT-STA-20150910-00062, SES-STA-20150910-00570, and SES-STA-20150910-00573,
Attachment A (Technical Information) (filed Sept. 17, 2015).


                                                   3


2.     In the event of any harmful interference resulting from the authorized operations,
       EchoStar will cease operations immediately upon notification of such interference
       and will immediately inform the Commission in writing of such interference.

3.     EchoStar will coordinate all TT&C operations with other potentially affected in-
       orbit satellite operators.

4.     EchoStar will maintain the EchoStar 15 at 61.65º W.L. with an east-west
       longitudinal station-keeping tolerance of +/-0.05 degree.

5.     EchoStar will not operate EchoStar 15’s communications payload during the
       satellite’s drift to and operations at 61.65º W.L., absent prior FCC authorization to
       do so.

IV.    CONCLUSION

       Based upon the foregoing, EchoStar urges the Commission to grant the requested

180-day STAs to allow it to continue moving and operating EchoStar 15 at 61.65º W.L.

as an in-orbit spare, and to conduct associated earth station TT&C operations.




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Document Created: 2019-04-25 08:45:58
Document Modified: 2019-04-25 08:45:58

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