Attachment Narrative

This document pretains to SES-STA-INTR2019-00354 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTAINTR201900354_1626779

EXHIBIT 1 DESCRIPTION OF PROPOSED STA OPERATIONS Pursuant to Section 25.120(b)(3) of the Commission’s rules,1 EchoStar Operating L.L.C. (together with its affiliates, “EchoStar”) requests special temporary authority (“STA”) for 60 days, commencing on or approximately March 15, 2019, to operate four earth stations in Cheyenne, WY, Blackhawk/Summerset, SD, and Gilbert, AZ (Call Signs E980005, E020248, E150098, and E070014) for telemetry, tracking, and command (“TT&C”) and feeder link communications with the EchoStar 23 satellite during its relocation to, and operations at, the 72.6º W.L. orbital location.2 Launched in March 2017, EchoStar 23 is a Brazilian-licensed Ku-band Broadcasting- Satellite Service (“BSS”) satellite currently operating at 44.9º W.L. Despite initial plans to operate EchoStar 23 to provide direct-to-home (“DTH”) television service to Brazil, EchoStar has determined that the satellite will be better utilized at the 72.6º W.L. orbital location, in conjunction with the Canadian-licensed Nimiq 5 satellite at 72.7º W.L., to support ongoing DTH service for DISH Network, L.L.C.’s (“DISH”) satellite television network. Accordingly, the requested STA will allow EchoStar to move EchoStar 23, commencing on or approximately April 1, 2019, to 72.6° W.L. to provide service to DISH subscribers in the United States and Canada.3 1 See 47 C.F.R. § 25.120(b)(3). 2 EchoStar is concurrently filing modification applications to add EchoStar 23 at the 72.6º W.L. orbital location at as a point of communications for TT&C and feeder link communications. 3 A modification application will be filed shortly for blanket licensing authority to operate receive-only U.S. earth stations for reception of service from the EchoStar 23 satellite at 72.6º W.L.

For TT&C and feeder link communications with EchoStar 23, the subject earth stations will operate on the following frequencies, consistent with the frequency bands and other technical parameters specified under their existing licenses: • 17.300 – 17.310 GHz and 17.791 GHz for TT&C uplinks; • 12.200 – 12.210 GHz for TT&C downlinks; and • 17.300 – 17.800 GHz for feeder uplinks. All four earth stations are already licensed for TT&C and feeder link communications using the above-specified frequencies with EchoStar 23 at 44.9º W.L., and have been frequency coordinated over a geostationary satellite arc that includes the 72.6º W.L. orbital location. Thus, the proposed STA operations will not cause harmful interference to other authorized operations.4 Nonetheless, in the unlikely event of harmful interference, EchoStar is prepared to take appropriate measures to eliminate such interference, including immediately discontinuing operations upon receiving notice of such interference. Grant of the requested STA will serve the public interest by allowing EchoStar the flexibility to manage its satellite fleet efficiently, provide for more productive use of its satellites, and further ensure full use of spectrum and uninterrupted service from the nominal 72.6º W.L. orbital location. Indeed, the Commission has a longstanding policy of leaving fleet management decisions to satellite operators because doing so generally serves the public interest.5 4 Additionally, the proposed STA operations are substantially consistent with Section 25.118(a)(3) of the Commission’s rules, allowing earth station operators to change a satellite point of communication without prior authorization under certain circumstances when an earth station antenna is not repointed beyond the coordinated range. See 47 C.F.R. § 25.118(a)(3). 5 See SES Americom, Inc., Order and Authorization, 21 FCC Rcd 3430, ¶ 8 (2006) (FCC “generally has allowed satellite operators to rearrange satellites in their fleet to reflect business and customer considerations where no public interest factors are adversely affected”); AMSC Subsidiary Corporation, Order and Authorization, 13 FCC Rcd 12316, ¶ 8 (IB 1998) (finding that that a satellite licensee “is in a better position to determine how to tailor its system to meet the particular needs of its customers”). -2-


Document Created: 2010-01-01 00:00:00
Document Modified: 2010-01-01 00:00:00
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