Attachment Exhibit 1

This document pretains to SES-STA-INTR2019-03258 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTAINTR201903258_1901519

                               EXHIBIT 1
       REQUEST FOR RENEWAL OF SPECIAL TEMPORARY AUTHORIZATION

         Pursuant to Section 25.120(b)(4) of the Commission’s rules, 1 EchoStar BSS Corporation

(together with its affiliates, “DISH”) 2 requests renewal of its special temporary authorizations

(“STAs”) for an additional 30 days, until October 16, 2019, to operate five earth stations in

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

E070014, E020248, E170094, E980005, and E150098) 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. 3

         Launched in March 2017, EchoStar 23 is a 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, DISH 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 its satellite television network. Accordingly, on July 2, 2019, EchoStar 23 began its

move from 44.9º W.L. to 72.6° W.L. 4 for service to DISH subscribers in the United States and

Canada. 5


1
    See 47 C.F.R. § 25.120(b)(4).
2
 On September 10, 2019, EchoStar BSS Corporation became the licensee for the authorizations
contained in this application following a series of transactions assigning and transferring control
over the licenses. See Letter from Pantelis Michalopoulos and Christopher Bjornson, Counsel to
DISH Network Corporation, to Marlene Dortch, FCC, SES-T/C-20190611-00734, SES-ASG-
20190607-00733, SAT-ASG-20190607-00044 (Sept. 12, 2019).
3
 See EchoStar, Applications for STA, IBFS File Nos. SES-STA-20190812-01090, SES-STA-
20190812-01091, SES-STA-20190812-01092, SES-STA-20190812-01093, SES-STA-
20190812-01094 (filed August 12, 2019).
4
 DISH holds additional 60-day STAs to operate the same five earth stations (Call Signs
E150098, E170094, E070014, E980005, and E020248) for TT&C communications with the


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

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

authorization from the Canadian Administration to operate at the 72.6° W.L. orbital location. 6

Accordingly, the requested STA will allow DISH 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.

DISH 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




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-
02173, at 43-44 (June 19, 2019). DISH also has pending modification applications to operate
these 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).
5
  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).
6
  DISH 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.


                                                  -2-


harmful interference to other authorized operations. 7 Nonetheless, in the unlikely event of

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

interference, including immediately discontinuing the interfering operations upon receiving

notice of such interference.

       Grant of the requested STA will serve the public interest by allowing DISH 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. 8




7
  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).
8
  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 (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”).


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Document Created: 2019-09-12 15:57:30
Document Modified: 2019-09-12 15:57:30

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