Attachment Exhibit 1

This document pretains to SES-STA-INTR2019-02350 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTAINTR201902350_1721676

                                             EXHIBIT 1

                       DESCRIPTION OF PROPOSED STA OPERATIONS


          Pursuant to Section 25.120(b)(4) of the Commission’s rules,1 EchoStar Operating L.L.C.

(together with its affiliates, “EchoStar”) requests special temporary authority (“STA”) for 30

days, commencing on or approximately June 17, 2019, to operate five earth stations in

Summerset, SD; Blackhawk, SD; Cheyenne, WY; Quicksburg, VA; and, Gilbert, AZ (Call Signs

E150098, E020248, E980005, E170094, and E070014) for telemetry, tracking, and command

(“TT&C”) communications to support the EchoStar 23 satellite’s brief interim operations at

67.9º W.L. prior to its planned relocation and operations at the 72.6° W.L. orbital location.

Launched in March 2017, EchoStar 23 is a Brazilian-licensed Ku-band Broadcasting-Satellite

Service (“BSS”) satellite initially authorized to operate 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 (together with its affiliates, “DISH”) satellite television

network. Accordingly, EchoStar plans to commence moving EchoStar 23 on June 17, 2019 from

44.9º W.L. to 72.6° W.L.2 for service to DISH subscribers in the United States and Canada.3




1
    See 47 C.F.R. § 25.120(b)(4).
2
  On April 18, 2019, the Commission granted 60-day STAs to operate five earth stations (Call Signs
E150098, E170094, E070014, E980005, and E020248) for TT&C communications with the EchoStar 23
satellite during its drift from 44.9° W.L. to 72.6° W.L. See Satellite Communications Services
Information re: Actions Taken, Public Notice, FCC Report No. SES-02156, at 29-30 (Apr. 24, 2019).
EchoStar also has pending modification applications to operate the same five earth stations for TT&C and
feeder link communications with EchoStar 23 during its relocation and operations at 72.6° W.L. See
EchoStar, Applications for Modification, IBFS File Nos. SES-MFS-20190308-00275 & SES-MFS-
20190214-00088 et seq. (Mar. 8 & Feb. 14, 2019).


        Prior to completing the relocation of EchoStar 23 to 72.6° W.L., EchoStar seeks to

operate the satellite at the 67.9º W.L. orbital location for a brief interim period until EchoStar

obtains authorization from the Canadian Administration to operate at the 72.6° W.L. orbital

location.4 Accordingly, the requested STA will allow EchoStar to operate EchoStar 23 at 67.9°

W.L. for a brief interim period until Canadian authorization may be secured for operations at

72.6° W.L. EchoStar has no plans to bring into use any International Telecommunication Union

filings at or near the 67.9° W. L. orbital location.

        For TT&C communications with EchoStar 23 at 67.9° W.L., 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; and

               12.200 – 12.210 GHz for TT&C downlinks.

        These earth stations have been frequency coordinated over a geostationary satellite arc

that includes the 67.9º W.L. orbital location. Thus, the proposed STA operations will not cause

harmful interference to other authorized operations.5 Nonetheless, in the unlikely event of

harmful interference, EchoStar is prepared to take appropriate measures to eliminate such

interference, including immediately discontinuing the interfering operations upon receiving

notice of such interference.

3
  A modification application 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. is currently pending. See DISH,
Application for Modification, IBFS File No. SES-MFS-20190507-00566 (May 7, 2019).
4
 EchoStar is aware that SES-10 operates at the 66.9° W.L. orbital location and is working with SES to
ensure that its TT&C operations do not interfere with SES-10.
5
 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).


                                                    -2-


        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 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.6




6
 See SES Americom, Inc., Order and Authorization, 21 FCC Rcd 3430, 3433 ¶ 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, 12318 ¶ 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”).


                                                  -3-



Document Created: 2019-06-07 11:09:00
Document Modified: 2019-06-07 11:09:00

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