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December 3, 1998).w Primestar then filed a letter with the Commission requesting expedited approval of the  S ' xITSAT/Primestar Application involving Tempo's 11 DBS channels at 119 W.L.u X {O!'ԍSee Public Notice, Report No. SPB143 (rel. December 3, 1998).u MCI sought, and  SZ' xreceived, Commission consent to assign its 28 assigned DBS channels at 110 W.L. to EchoStar.LZbX {O\$'ԍSee supra footnote 6.L The TSAT/Primestar Application and the EchoStar/Directsat STA Request are pending.  S' e 5.` ` On January 22, 1999, DirecTV's parent corporation, Hughes Electronics Corporation,  xannounced it had reached an agreement with Primestar under which DirecTV would acquire Primestar's",((  "  x^assets, as well as Primestar's rights to acquire Tempo's assets. Primestar's assets consist of its directto xhome ("DTH") satellite business, a 160channel, mediumpower MVPD service transmitted to  S' xapproximately 2.3 million customers.X yO'ԍEstimate derived from SkyTrend, http://www.skyreport.com/skyreport/dth_us.htm. On April 28, 1999, DirecTV completed its acquisition of  S' xxPrimestar's assets.|XX yO'ԍSee http://www.directv.com/news/primestarcompletion.html for press release.| However, since Primestar transmits its DTH service from leased satellite capacity on  xa fixed satellite at Kuband, DirecTV's acquisition of Primestar's customers did not require Commission  xreview or approval. Tempo's assets include two satellites (one in orbit at the 119 W.L. orbital location  xand one not yet launched), as well as its authorization to implement DBS service from the 119 W.L.  xorbital location over the same 11 DBS channels that are the subject of the TSAT/Primestar Application.  xOn January 27, 1999, the Commission received two related filings: the Tempo/DirecTV Application, for  S' xconsent to assign Tempo's DBS authorization at 119 W.L. to DirecTV;X {O 'ԍSee Public Notice, Report No. SPB147 (rel. February 1, 1999) (Tempo/DirecTV PN). and a letter, jointly filed by  xTSAT and Primestar, requesting that the TSAT/Primestar Application be held in abeyance and  SH 'subsequently dismissed upon approval of the Tempo/DirecTV Application ("Abeyance Request Letter").SZH zX yOb' " ԍLetter to Magalie Roman Salas, Secretary, FCC, from Richard E. Wiley, Counsel for TSAT, and Philip L.  {O*' x Verveer, Counsel for Primestar (January 27, 1999). See also Tempo/DirecTV Application at n.4 & Assignee's Public Interest Statement at 6.S  S ' e 6.` ` Tempo and DirecTV assert that grant of the Tempo/DirecTV Application will provide  xkimportant benefits to MVPD customers. First, they assert that grant will allow DirecTV to compete more  S ' xeffectively with EchoStar and cable operators.x X yO'ԍTempo/DirecTV Application, Assignee's Public Interest Statement at 13.x Second, grant will resolve general concerns regarding  xTempo's incentives to use DBS resources to compete with cable, given the cable industry's investments  SX' xtin Tempo.@X, X {O$'ԍId. at 4.@ Third, grant will spur technical innovation by encouraging the satellite industry to develop  xsmall earth stations that can receive and integrate signals from multiple orbital positions, thus expanding  S' xprogramming choices for DBS subscribers, including underserved consumers.B X {Of'ԍId. at 45.B Finally, the applicants  xacknowledge that Tempo is not currently providing DBS service from its 11 DBS channels, and claim that,  xas a result of Commission approval, DirecTV will be able to offer commercial service from Tempo's  S' xsatellite at the 119 W.L. orbital location "almost immediately" after consummation of this transaction.,P X {O!' "V ԍId. at 56 & Assignor's Public Interest Statement at 1 ("Consummation of the proposed transaction would  {OJ"'provide for the prompt initiation of service using [Tempo]'s authorized DBS assets.") (emphasis added).,  xZIndeed, DirecTV estimates that "it will take only a matter of weeks to bring [Tempo]'s inorbit satellite  S@'into commercial service."k@X {O%'ԍId., Assignee's Public Interest Statement at 4 n.16.k ">,((  "Ԍ S' e 7.` ` Several parties filed petitions to deny or requested imposition of conditions with regard  S' xto the Tempo/DirecTV Application. X yO@' " ԍEchoStar Petition to Deny (filed March 5, 1999) ("EchoStar Petition"); Small Cable Business Association  xg Comments and Request for Conditional Grant (filed March 5, 1999) ("SCBA Request"); Media Access Project  x7 Contingent Petition to Dismiss or Deny (filed March 5, 1999, as counsel for Office of Communication, Inc., of the  x United Church of Christ, Consumers Union, and the National Association for Better Broadcasting) ("MAP Petition");  x Tempo Opposition (filed March 19, 1999); DirecTV Opposition and Reply Comments (filed March 19, 1999)  x^ ("DirecTV Opposition"); EchoStar Consolidated Reply (filed April 2, 1999) ("EchoStar Reply"). On April 13, 1999,  x Tempo and DirecTV filed a Joint Response to the EchoStar Reply, seeking leave to file outside the comment period  {O' x^ specified in the Tempo/DirecTV PN. For good cause shown, we grant Tempo and DirecTV's request, and we will consider their Joint Response in order to ensure a complete record in this proceeding. EchoStar contends that we should not permit a single operator to  xQuse spectrum at all three fullCONUS orbital locations because the technical inefficiencies associated with  S' xkproviding a threesatellite DBS service outweigh any benefit of bolstering competition to cable operators.cX yO 'ԍEchoStar Petition at 24; EchoStar Reply at 1215.c  xEchoStar also argues that Tempo has been warehousing its 11 channels at 119$W.L., and has not satisfied  S8' x@its due diligence requirements.8* X yO' "u ԍEchoStar Petition at 4; EchoStar Reply at 212. The due diligence rules for DBS permittees granted  x construction permits prior to January 19, 1996 are contained in Section 100.19(a) of the Commission's Rules,  x 47C.F.R.  100.19(a), and contain two prongs. The first prong requires a DBS permittee to complete contracting  x for its satellite(s) within a year of receiving its construction permit. The second prong requires that the satellite station(s) be in operation within six years of the construction permit grant. While not opposing the Tempo/DirecTV Application, the Small Cable  xMBusiness Association ("SCBA") is concerned that concentrating the ownership of all fullCONUS DBS  S' xchannels between two providers (i.e., EchoStar and DirecTV) adversely affects the public interest, and  S' xthus, asks for a conditional grant.EX yO<'ԍSCBA Request at 35.E Specifically, SCBA argues that the only way to ensure longterm  xgcompetition between DBS and small cable systems is for the Commission to require DBS providers, in  xthis case, DirecTV, to offer a reasonablypriced, digital package of programming that small cable operators  SJ ' xcan resell to their customers under their own name.BJ jX {OT'ԍId. at 57.B Finally, while not addressing the merits of the  x/Tempo/DirecTV Application, Media Access Project ("MAP") requests that we dismiss or deny the  xTempo/DirecTV Application unless the parties provide the requisite information necessary to analyze the  S 'transaction under the citizenship and character requirements for the award of broadcast licenses.E X yOn'ԍMAP Petition at 14.E  S ' e 8.` ` Having considered the record developed in this proceeding, and for the reasons discussed  xbelow, we conclude that it is in the public interest to approve the Tempo/DirecTV Application,  xDconditioned on DirecTV commencing service from the 119 W.L. orbital location no later than November  x28, 1999. In light of this decision, the TSAT/Primestar Application is moot. As a result, and at the parties' request in the Abeyance Request Letter, we dismiss the TSAT/Primestar Application.",((  "  S' FIII. DISCUSSION  S'A.Tempo/DirecTV Application  S`' 1.` ` Legal Standard  S' e 9.` ` Section 310(d) of the Communications Act, as amended ("Communications Act"), requires  S' xQa finding that any proposed assignment of license serves the public interest, convenience, and necessity.G X yOP'ԍ47 U.S.C.  310(d).G  xThus, the central issue before us is whether the public interest is served by allowing DirecTV, a current  xDBS distributor, to acquire the assets of another potential DBS distributor, Tempo, by acquiring the latter's  x<DBS license. To make this finding, we must weigh any potential public interest harms against any  SH ' xpotential public interest benefits, considering competitive effects and other public interest factors.!&H XX {O@ ' " ԍMCI/EchoStar Order, FCC 99109, at  7 (citing Southern New England Telecomm. Corp. and SBC  {O ' x Communications, Inc., CC Docket No. 9825, Memorandum Opinion and Order, 13 FCC Rcd 21292, 21298 (1998);  {O' x WorldCom, Inc. and MCI Communications Corp., CC Docket No. 97211, Memorandum Opinion and Order, 13 FCC Rcd 18025, 18030 (1998)). As  S 'the Commission recently explained in the MCI/EchoStar Order:  e %` ` [O]ur public interest analysis is not, however, limited by traditional  e antitrust principles. . . . It also encompasses the broad aims of the  e TCommunications Act. . . . To apply our public interest test, then, we must  e adetermine whether the [assignment] violates our rules, or would otherwise  e frustrate our implementation or enforcement of the Communications Act  e and federal communications policy. That policy is, of course, shaped by  e GCongress and deeply rooted in a preference for competitive processes and  S'outcomes."FX {O' " ԍId. (quoting TeleCommunications, Inc. and AT&T Corp., CS Docket No. 98178, Memorandum Opinion and Order, FCC 9924 at  14 (rel. February 18, 1999)).x`  Sj' e W 10.` ` Consistent with this precedent, we begin our analysis by identifying the relevant product  SB' xmarkets that are affected by the proposed transaction,#$BX {O' " ԍId. at  8 (citing e.g., Teleport Communications Group, Inc. and AT&T Corp., CC Docket No. 9824,  {OL' x Memorandum Opinion and Order, 13 FCC Rcd 15236, 15245 (1998); NYNEX Corp. and Bell Atlantic Corp.,  x Memorandum Opinion and Order, 12 FCC Rcd 19985, 20008 (1997)). Each product market has a geographic component. and then we consider the competitive effects of  xthe proposed transaction in these markets. Finally, we consider other issues raised by parties with respect to other public interest factors." #,((  "  S' 2.` ` Public Interest Determination  Q'` ` a. Relevant Product Markets  S`' e  11.` ` In its annual assessment of the video marketplace, the Commission has found that DBS  S8' xtoperators compete in two product markets.$8X {O' " ԍAnnual Assessment of the Status of Competition in Markets for the Delivery of Video Programming, CS Docket No. 97141, Fourth Annual Report, 13 FCC Rcd 1034 at Section III (1998). First, DBS operators compete with each other and other  xMVPDs in the distribution of multiple channels of video programming to consumers (the "MVPD  S' xmarket"). %("X {O ' " ԍAnnual Assessment of the Status of Competition in Markets for the Delivery of Video Programming, CS  {Ot ' x^ Docket No. 98102, Fifth Annual Report, 13 FCC Rcd 24284, 24287 (1998) (1998 Cable Competition Report). DoJ  {O> ' xk concurs with the Commission's analysis that the relevant product market is the provision of MVPD services. See  {O 'MCI/EchoStar Order, FCC 99109, at n.29.  The Commission has found that the relevant geographic market for assessing MVPD  x*competition is a local area. The extent of the local area is defined by the overlap of the service footprints  S' x*of the various service providers in that area.&X yOJ'ԍ The "footprint" of a service provider is determined by the provider's geographic reach. For example, the geographic footprint of a cable franchise  x@operator is determined by the location of the homes within a franchise that an operator passes with its  SH ' xcable and thus can serve.'H X {O' "  ԍSee Annual Assessment of the Status of Competition in the Market for the Delivery of Video Programming, CS Docket No. 96133, Third Annual Report, 12 FCC Rcd 4358, 4418 (1997). As a DBS distributor operating from fullCONUS orbital locations, DirecTV  S ' xdistributes multiple channels of video programming directly to consumers across the United States.( X yO'ԍSee http://www.directv.com/ for a description of DirecTV's current offerings and coverage. Thus, DirecTV competes in many different local MVPD markets.  S ' e  12.` ` Second, DBS operators compete with each other and other distributors of video  S ' xprogramming for the acquisition of programming (the "programming market").j) X {O'ԍ1998 Cable Competition Report, 13 FCC Rcd at 24362.j The Commission has  xfound that the relevant programming market for DBS is national in geographic scope, but can be regional  S0' xif the programmer wishes to reach a more geographically targeted audience.*Z0X {O' " ԍId. Most programmers produce video programming with the intent of distributing it to a national audience.  x However, there is some video programming, such as regional sports programming, that is intended for distribution to a regional audience only and so is sold to distributors for that purpose. Because DirecTV distributes  x video programming to a national audience, DirecTV primarily competes with other companies for the acquisition of programming in the national programming market."@*,((  "  Q'` ` b. Competitive Effect of the Proposed Transaction in the Product Markets  S' e q 13.` ` The MVPD market. DBS distributors generally, and DirecTV specifically, compete with  S' xa number of other MVPDs using different transmission media.+"X yO' "h ԍCompetitors in the MVPD market include cable operators, DBS operators, wireless cable operators  x (Multichannel Multipoint Distribution Services, Local Multipoint Distribution Services, etc.), Satellite Master Antenna  {O' x Television Systems, and Local Exchange Carriers. See 1998 Cable Competition Report, 13 FCC Rcd at 24292361 (detailed description and evaluation of the different competitors in the MVPD market). As of December 1998, there were  S`' xapproximately 99.4 million households with a television set ("TV households") in the United States.,`X yO ' " ԍEstimate derived from the National Cable Television Association's Yearend Review web pages, http://www.ncta.com/yearend98_6.html. Of  S8' xZthese TV households, approximately 79.6 million subscribed to the services of some MVPD.-8 X {O 'ԍId., http://www.ncta.com/yearend98_6.html and http://www.ncta.com/yearend98_4.html. Of this  xkestimated total, cable distributors had 67.01 million subscribers (or 84.2% of the MVPD total), while DBS  S' xdistributors had 7.8 million subscribers (or 9.8% of the MVPD total).:.X {O$'ԍId.: Thus, aggregating across distributors, cable distributors, rather than DBS distributors, dominate the MVPD market nationally.  Sp' e   14.` ` Examining the market shares of individual distributors presents a picture that is roughly  xconsistent with this aggregate characterization of the MVPD market. As of March 1999, DirecTV had  xapproximately 4.762 million subscribers, a figure that combines DirecTV's subscribers with those recently  S ' xacquired from USSB./ . X yO'ԍEstimate derived from SkyTrend, http://www.skyreport.com/skyreport/dth_us.htm. This subscriber estimate is less than that of the top four cable operators for similar  xpoints in time. AT&T Broadband & Internet Services ("AT&T") had 10.923 million subscribers (March  x31999), Time Warner Cable had 6.456 million subscribers (February 1999), Comcast Communications  xg("Comcast") had 5.387 million subscribers (April 1999) and MediaOne Group ("MediaOne") had 5.127  SX' xmillion subscribers (April 1999).f0X X {O'ԍSee http://www.cvmag.com/database/db_topco.htm.f Thus, prior to DirecTV's acquisition of Primestar, DirecTV was apparently the fifth largest MVPD.  S' e B15.` ` DirecTV's position as a MVPD is likely to be improved somewhat after its recent  S' xQacquisition of Primestar, but by how much is unclear.f1ZP X {O ' " ԍSee supra paragraph 5. DirecTV plans to operate Primestar's mediumpower DTH business for a period  x of approximately two years, during which time it will attempt to transition the mediumpower customers to its highpower DBS service. Tempo/DirecTV Application at 4 n.6.f First, EchoStar began an aggressive campaign to  xacquire former Primestar's subscribers as soon as DirecTV announced its intention to acquire Primestar.  xcEchoStar created a bonus plan for retailers that convert Primestar subscribers to become EchoStar  S@' xsubscribers, instead of DirecTV subscribers.Z2@rX {OR&'ԍSkyTrends, 99 Annual Report, at 24.Z Consequently, DirecTV is likely to gain only a portion of  xPrimestar's estimated 2.3 million subscribers. Second, the largest cable multiple system operators ("MSO")"2,((  "  xare currently acquiring additional subscribers through their acquisition of smaller cable MSOs. Pending  xtransactions include: AT&T and Comcast acquiring different parts of MediaOne; Cox Communications  xpurchasing TCA Cable TV and Media General Cable; Adelphia Communications taking over Century  S' xpCommunications and FrontierVision Partners;3X {O'ԍJohn M. Higgins, Top MSOs Own 90% of Subs, BROADCASTING & CABLE, May 24, 1999, at 34. and, recently announced, Charter Communications'  S`' x}purchases of Falcon Communications and Fanch Communications.4`ZX {OZ'ԍCharter Becomes 4th Largest MSO with Acquisition of Fanch, COMM. DAILY, May 28, 1999, at 5. Each of these deals boost the  xcustomer base of the purchasing MSO well beyond 5 million subscribers, with AT&T topping 16 million  S' xcsubscribers.i5X {O 'ԍEstimates derived from Higgins, supra footnote 51.i With this significant consolidation occurring in the cable industry, we do not expect  xDirecTV's increased subscribership as a result of its acquisition of Primestar to significantly change its position in the MVPD market nationally.  Sp' e 16.` ` However, our analysis also must consider the fact that cable MSOs operate in different  xlocal MVPD markets, while DirecTV provides services to most local MVPD markets. Thus, the degree  xtto which cable distributors dominate different local MVPD markets varies across regions of the United  xStates is unclear. There are consumers, such as those living in sparsely populated rural areas, who may  xbe able to purchase only the offerings of DBS distributors because their homes are not served by any other  xMVPD. We do not have available the more geographically delineated data necessary to ascertain the  xlmarket position of DBS operators in different local MVPD markets. Nevertheless, we note that  SX' x7approximately 96.6% of U.S. TV households are passed by a cable system.u6X~X {Ov' "& ԍThe National Cable Television Association reports in its Cable Television Developments: Fall 1998/Winter  {O@' x 1999 at 1, that of a total of 98,920,000 television households, 95,520,000 or 96.6% of these households are passed  {O ' x by a cable system. These estimates were taken from Paul Kagan Associates, Inc., Marketing New Media (November  x 16, 1998). A household is "passed" if cable service is sufficiently available to it that it might subscribe to cable service if it chooses.u This estimate suggests that  xmost TV households in the United States have a choice between at least one cable operator and two full S' xCONUS DBS competitors (i.e., DirecTV and EchoStar). Further, based on nationally aggregated MVPD  xmarket estimates, cable operators have far more subscribers on average than do DBS operators as a  S' xgroup.N74 X {O'ԍSee supra paragraph 13.N Thus, we conclude that while DirecTV will likely become the fifth or sixth largest MVPD as a  x&result of its acquisitions of USSB and Primestar, DirecTV will face stiff competition from at least one  x/other MVPD operator in each of the markets in which it competes. Consequently, we believe that  x<DirecTV currently does not possess market power in the distribution of multiple channels of video programming to consumers.  S' e 17.` ` Nor do we view the assignment of Tempo's license to DirecTV as conferring on DirecTV  x*an ability to exercise market power in the future in any of the local MVPD markets in which it competes.  xgWe make this judgment recognizing that the practical result of granting the proposed assignment is the  SR' x7one SCBA expresses concern over,E8R X yO&'ԍSCBA Request at 35.E i.e., all existing fullCONUS DBS channels will be under the control  xof DirecTV or EchoStar, the two largest DBS operators. In this regard, short of DirecTV or EchoStar", V 8,((  ~"  xselling or leasing significant channel capacity to a third party, grant of the proposed transaction prevents  x/a third domestic DBS operator from using DBS channels at one of the existing fullCONUS orbital locations to provide service to different MVPD markets.  S`' e 18.` ` Despite this consolidation, it is still possible for another entity in the future to enter the  xtU.S. DBS market and compete with these two DBS operators. Domestically, there is the possibility of  xa domestic MVPD operator entering different MVPD markets through alternative satellite distribution  S' xmethods.9X yOP' " ԍING Baring Furman Selz LLC's "Satellite Weekly Research" report of May 25, 1999 indicates that BellSouth Corp. is examining MVPD market entry through a medium power satellite service. Furthermore, as the Commission noted in the MCI/EchoStar Order, there is the possibility that  S' xforeign DBS operators might enter the U.S. DBS industry.i: X {O 'ԍMCI/EchoStar Order, FCC 99109, at  21 & n.52.i For example, the United States has reached  x^agreements with Mexico and Argentina to permit DTH satellite services, including DBS, licensed by either  Sr' xcountry to provide service into each other's territory.;"rX {O' "& ԍ See Public Notice, International Bureau Announces Conclusion of U.S.Mexico Protocol for DirecttoHome  x Satellite Services, 12 FCC Rcd 13105 (1996); Public Notice, International Bureau Announces Conclusion of U.S. x7 Argentina Framework Agreement and Protocol for DirecttoHome Satellite Services and FixedSatellite Services, DA 981114 (rel. June 12, 1998). Consequently, the consolidation of domestic full xxCONUS capacity into the hands of two domestic DBS operators does not totally foreclose additional entry into the U.S. DBS industry.  S ' e 19.` ` More importantly, the Commission also noted in the MCI/EchoStar Order that because  xcable operators are increasing their product offerings, DBS operators will have to increase their product  S ' xofferings to remain competitive.b< X {O'ԍMCI/EchoStar Order, FCC 99109, at  20.b DBS operators seeking to expand their service offerings will need  xincreased channel capacity. For this reason, we find that DirecTV's acquisition of the Tempo channels will improve its ability to compete with cable operators.  S' e 20.` ` The programming market. DBS operators compete with other distributors of video  xprogramming to obtain programming to distribute. Like most MVPDs, DirecTV primarily distributes the  xproduct of distributors who provide a stream or "channel" of programming by packaging selfproduced  xand/or acquired video programs. Thus, the proposed transaction affects both those who purchase and package video programming as well as those who produce video programs for subsequent distribution.  S' e N21.` ` As discussed above, DirecTV does not possess market power in MVPD markets nationally,  xnor is it likely to acquire such market power as a result of the proposed transaction. Consequently, we  xdo not believe that DirecTV will be able to exercise market power, now or in the future, in acquiring video programming for national distribution as a result of this transaction.  Q,'` ` c. Other Competitive Issues  S' e 22.` ` Upon consummation of the proposed transaction, DirecTV will be the first entity licensed  x@to provide DBS service from all three fullCONUS locations by adding 11 channels at 119 W.L. to its  xauthorized channels at 110 W.L. and 101 W.L. EchoStar alleges that "while it is clear that DBS" . <,((  "  xproviders should be allowed access to two [fullCONUS] orbital locations to ensure the capacity necessary  x7to compete against cable operators, it is not clear that the Commission should permit, at least for the time  S' xbeing, a single operator to use spectrum at all three orbital locations."F=X yO'ԍEchoStar Reply at 12.F Specifically, EchoStar maintains  xpthat if DirecTV provides service to customers from all three fullCONUS orbital locations, it would  S`' xunderutilize its satellites (i.e., portions of each satellite's capacity would be unused), and would have to  S:' x7supply each customer with two satellite dishes.J>:XX yO2'ԍEchoStar Petition at 23.J In that regard, EchoStar claims that its own experience  S' x<suggests consumers are reluctant to install and use two dishes.D?X {O 'ԍId. at 3 n.4.D Given these purported economic  xtinefficiencies in DirecTV's business plan, EchoStar raises the possibility that DirecTV's motive for this  xtransaction is to block EchoStar's use of these channels rather than effectively compete in the MVPD  S' xZmarket.V@zX {O'ԍId. at 4; EchoStar Reply at 15.V We find EchoStar's argument unpersuasive for two reasons. First, EchoStar presumes that  xDirecTV plans to serve all customers from all three satellites, while DirecTV enumerates many plans for  xthe Tempo frequencies that can just as easily stand on their own in providing competition to MVPD  S" ' x&operators.jA" X yO'  ԍXUpon Commission consent to the proposed assignment, DirecTV can utilize the 11 [Tempo]   frequencies . . . to offer additional highquality entertainment, educational, and informational   programming; new product tiers, which may include women's, religious, and family programming;   new a la carte channel options; and additional ethnic programming. The additional capacity also   will allow [DirecTV] to capitalize on such emerging consumer services as high definition  u television, data enhanced broadcasting, and interactive service offerings to meet competition from incumbent cable providers that already are offering these new services.  Tempo/DirecTV Application, Assignee's Public Interest Statement at 3.j For those customers that desire to access DirecTV's services from all three fullCONUS  x@satellite locations, DirecTV asserts that it is developing viable technologies that would allow it to serve  S ' xconsumers from a single dish to benefit not only DirecTV customers, but the DBS industry as well.BZ X {ON' " ԍId. at 45; DirecTV Opposition at 6 & Attachment 1. If DirecTV is successful in developing a single dish  x capable of receiving programming from three separate locations, then its innovations could allow DBS operators with only nonCONUS satellites to potentially compete more effectively with those that have fullCONUS satellites.  xkEchoStar presents no compelling reasons to discourage such innovation. Second, the Commission's rules  xdo not prevent a license or orbital position from being assigned simply because a competing licensee  xargues that implementation of the authorization would be economically inefficient. Indeed, the  xCommission repeatedly has emphasized that the applicant -- not the Commission -- is in the best position  S 'to make these sorts of business judgments.C X {O#' " ԍSee, e.g., Rulemaking to Amend Parts 1, 2, 21, and 25 of the Commission's Rules to Redesignate the 27.5 x 29.5 GHz Frequency Band, to Reallocate the 29.530.0 GHz Frequency Band, to Establish Rules and Policies for  {O:%' x Local Multipoint Distribution Service and for Fixed Satellite Services, CC Docket No. 92297, Second Report and  x Order, Order on Reconsideration, and Fifth Notice of Proposed Rulemaking, 12 FCC Rcd 12545, 12608, 12643  {O&' x (1997); Inquiry into the Development of Regulatory Policy in Regard to Direct Broadcast Satellites for the Period  {O'' x| Following the 1983 Regional Administrative Radio Conference, Gen. Docket No. 80603, Notice of Proposed Policy"'B,(('" Statement and Rulemaking, 86 F.C.C.2d 719, 750 (1981)."  XC,((  "Ԍ S' e 0ԙ23.` ` SCBA argues that DBS providers should be required to offer small cable operators (i.e.,  x7those unable to support costly upgrades to digital cable) a reasonablypriced, wholesale package of digital  S' xvideo programming that the operator could redistribute under its own identity.EDXX yO'ԍSCBA Request at 57.E SCBA's argument is  xbased on Primestar orally representing that it would provide small cable operators such a package if the  Sb' xxTSAT/Primestar Application were approved.QEbX {O'ԍId. at 2 & Exhibit A at 3.Q SCBA further argues that this requirement would serve the  xpublic interest by ensuring the "viability of small cable businesses, an action necessary to ensure longterm  S' xQcompetition between DBS and small cable in rural America."@FzX {O, 'ԍId. at 7.@ We deny SCBA's request for two reasons.  xFirst, as the Commission recently stated, "the public interest [ ] is in insuring robust competition and not  S' xin protecting the financial interests of particular firms."&G X {On' " ԍMCI/EchoStar Order, FCC 99109, at  25. See generally id. at  3138 (discussing SCBA's claim of potential harm to terrestrial broadcasters and small cable operators presented by the MCI/EchoStar transaction).& Second, SCBA's perceived oral understanding  S' xwith Primestar has no bearing on the Tempo/DirecTV Application,VHf X {O'ԍSee also Tempo Opposition at 4.V nor do we, in any event, adjudicate  Sr' xprivate contractual matters in such circumstances.sIr X {O 'ԍSee, e.g., MCI/EchoStar Order, FCC 99109, at  30.s Consequently, we deny SCBA's request for this condition.  Q '` ` d. Qualification Requirements  S ' e W24.` ` MAP argues that, in acting upon the Tempo/DirecTV Application, the Commission must  S ' xapply the citizenship standard set forth in Section 310(b) of the Communications Act,dJ X yO'ԍMAP Petition at 15 (citing 47 U.S.C. 310(b)).d its DBSspecific  SZ' xiteration at Section 100.11 of the Commission's Rules,_KZX {O'ԍId. at 2 (citing 47 C.F.R.  100.11)._ and the character standard set forth in Section  S2' x308(b) of the Communications Act._L2X {O~ 'ԍId. at 4 (citing 47 U.S.C. 308(b))._ Therefore, MAP requests that the Commission require Tempo and  x&DirecTV to provide the information necessary for the Commission to apply these requirements to this  S' xapplication.@M>X {O#'ԍId. at 2.@ At its core, the MAP Petition reiterates legal arguments MAP and/or its clients have" M,((  "  S' xpresented in DBSrelated proceedings that were pending at the time MAP filed its Petition, N&X {Oh' " ԍId. at 23, incorporating by reference the arguments presented in its clients' Petition to Dismiss or Deny the  x. assignment application of MCI Telecommunications Corporation and EchoStar 110 Corporation, IBFS File No. SAT {O' xt ASG199812020093, and its clients' Application for Review of MCI Telecommunications Corporation, Order,  {O'11FCC Rcd 16275 (Int'l Bur. 1996) (MCI Order).  but that the Commission recently has decided.  S' e 925.` ` Specifically, in the MCI MO&O, the Commission recently affirmed the International  x3Bureau's decision that Section 310(b) of the Communications Act does not apply when licensing non S:' x broadcast, noncommon carrier video service providers such as subscription DBS licensees.O:X {O ' " ԍMCI Telecommunications Corporation, Memorandum Opinion and Order, FCC 99110, at  1114 (rel.  {OZ 'May 19, 1999) (MCI MO&O), aff'g MCI Order, 11FCC Rcd 16275. Thus,  xTempo and DirecTV are not required to submit citizenship information under Section 310(b). With  x^respect to Section 100.11 of the Commission's Rules, we note there is an outstanding Notice of Proposed  xRulemaking in which the Commission seeks comment on whether it should modify its DBS eligibility  xrules "such that the foreign ownership limitations currently located in Section 100.11 would apply to  Sr' xsubscription DBS providers."PrX {O$' " ԍPolicies and Rules for the Direct Broadcast Satellite Service, IB Docket No. 9821, Notice of Proposed  {O'Rulemaking, 13 FCC Rcd 6907, 6922 (1998) (Part 100 NPRM). As the Commission recently stated in the MCI MO&O, "the applicability  xof foreign ownership limits for subscription DBS services is an issue the Commission will resolve in its  S$ ' xkfinal decision in the Part 100 proceeding. We believe that rulemaking proceeding is the appropriate forum  S ' x*to consider a change in our rules."aQ\ n X {O ' " ԍMCI MO&O, FCC 99110, at  21 (citing Community Television of Southern California v. Gottfried, 459  {O' x; U.S. 498, 511 (1983) and Capital Cities/ABC, Inc. and The Walt Disney Company, Memorandum Opinion and Order, 11 FCC Rcd 5841, 5888 (1996)).a In this case, unlike in the MCI MO&O, no specific facts are alleged  xregarding foreign ownership of the applicants, and therefore, we do not have to reach the issue of whether  S 'a waiver of the Commission's rule is appropriate.JR X {O'ԍSee id. at  20.J  S`' e 26.` ` In the MCI MO&O, the Commission also stated that Section 308(b) character scrutiny is  S:' xrelevant in all licensing determinations.WS\:$X {O' "_ ԍId. at  2225 (citing the Tempo Authorization, 7 FCC Rcd at 2729, as an example of the Commission's  {O' xQ evaluation of character qualifications in the subscription DBS context, i.e., prior to issuing Tempo's construction permit).W Thus, a properly raised character qualification issue would be  xrelevant in ruling on this assignment of license application. However, MAP has not raised any question  S' xZregarding either Tempo's or DirecTV's character qualifications. As the Commission stated in the MCI  S' xkMO&O: "The Commission customarily presumes that license applicants are trustworthy in the absence of  xevidence to the contrary, and the presumption need not be explicitly stated in a license order when it has  Sv' xnot been called into question."FTvHX {O^&'ԍId. at  25.F Therefore, we do not find it necessary to address MAP's request in this proceeding, and dismiss the MAP Petition on those grounds."N T,((  "Ԍ S'ԙ 3.` ` Due Diligence Conditions  S' e S27.` ` When both the TSAT/Primestar Application and the MCI/Primestar Application were  xpending at the Commission, the International Bureau granted Tempo an extension of its May 1, 1998 due  xDdiligence deadline for commencing service from its 11 assigned channels at the 119 W.L. orbital location  x*"until six months following the Commission's determination on the [TSAT/Primestar and MCI/Primestar]  S' xApplications or decision on any petitions for reconsideration of such determination."U&X {Ox' " ԍTempo Extension Order, 13 FCC Rcd at 11073, 11075. The Commission granted Tempo its DBS  {OB' xg construction permit on May 1, 1992. Tempo Authorization, 7 FCC Rcd 2728. Therefore, Tempo's deadline for  {O ' x meeting the second prong of its due diligence was May 1, 1998. See 47C.F.R.  100.19(a), described supra footnote28. EchoStar challenges  xxthe validity of the due diligence deadline extension on several grounds. First, EchoStar argues that Tempo  S' xhas lost its authorization because the original transaction underlying the extension has been aborted (i.e.,  xcno decision was ever reached by the Commission on either the Tempo/Primestar transaction or the  Sr' xMCI/Primestar transaction).EVrX yO'ԍEchoStar Reply at 6.E EchoStar therefore contends that Tempo should not be allowed to utilize  SJ ' x!the Primestarrelated extension for the DirecTV transaction.:WJ FX {O0'ԍId.: EchoStar further argues that, because Tempo  x3did not meet its due diligence requirements, "it is not fit to hold the license it intends to assign in order  S ' xxto effectuate such an assignment."X X {Or' "y ԍId. at 810 (citing Advanced Communications Corp., 11 FCC Rcd 3399 (1995) (Advanced Cancellation  {O<'Order)). Furthermore&bFinally, EchoStar alleges that cableowned Tempo's motive for  xZdelaying due diligence is to warehouse DBS spectrum, thus limiting access to this spectrum by cable's  xDBS competitors. In that regard, EchoStar argues that denying the Tempo/DirecTV Application would  S ' xbe consistent with Commission precedent on DBS spectrum warehousing set in the Advanced Cancellation  S\'Order.Y\4 X {O0' "g ԍId. at 1012. In the Advanced Cancellation Order, the Commission found that, despite a decade of authority,  xo including a fouryear extension, DBS permittee Advanced Communications Corporation ("Advanced") had not made  x concrete progress toward commencing operation of a DBS service. The Commission affirmed the International  x Bureau's decision to cancel Advanced's construction permit for failure to meet due diligence, and the Commission's  {OR' x action was upheld on appeal. See Advanced Communications Corp. v. FCC, 84 F.3d 1452 (D.C. Cir. 1996), cert.  {O'denied, 117 S. Ct. 718 (1997).  S' e 28.` ` We disagree with EchoStar's interpretation of our actions and Commission precedent. In  S' xthe Tempo Extension Order, the International Bureau specifically stated that the due diligence deadline  S' xZwould resume following "Commission determination" on both the TSAT/Primestar Application and the  x<MCI/Primestar Application. Although MCI and Primestar voluntarily withdrew the MCI/Primestar  xApplication in November 1998, the TSAT/Primestar Application has awaited Commission action. Given  SJ' xQour determination to dismiss the TSAT/Primestar Application in this Order, the due diligence clock begins  xto run today. Therefore, we deny EchoStar's challenge to the validity of Tempo's authorization, as well  xas EchoStar's allegation regarding Tempo's fitness to assign its authorization to DirecTV. Finally, this case"Y,((  n"  S' xis unlike the Advanced Cancellation Order, because Tempo, unlike Advanced, has made significant strides  S'toward commencing DBS service.QZZX {OB' " ԍSee supra paragraph 3; see also Tempo Extension Order, 13 FCC Rcd at 11072 ("Tempo, unlike Advanced,  x has not remained idle but has made tangible progress toward implementing service from its assigned frequencies at the 119 W.L. location.").Q  S' e 029.` ` In order to assure prompt implementation of this authorization, and to further the policy  Sb' xobjectives of the Tempo Extension Order, we condition the grant of the Tempo/DirecTV Application on  x the requirement that DirecTV commence service from the 119 W.L. orbital location no later than six  xxmonths from today, November 28, 1999. Given DirecTV's declaration that it "is not requesting, and there  S' x will be no need for, any additional due diligence extension at 119 W.L.,"[\X {Ov ' "l ԍTempo/DirecTV Application, Assignee's Public Interest Statement at 67; see DirecTV Opposition at7  x3 ("[U]pon grant of the instant Application, [DirecTV] will utilize a [Tempo] satellite that already is in orbit and  {O 'capable of providing service almost immediately."). See also supra footnotes 2425 & accompanying text. we believe that six months is an adequate amount of time for DirecTV to meet this authorization's due diligence requirements.  St' B.EchoStar's Request for Special Temporary Authority  S$ ' e 30.` ` EchoStar's authorization to use 21 DBS channels at the 119 W.L. orbital location is based  xon the authorizations to two related entities, EchoStar and Directsat. In March 1996, EchoStar was  x}granted an STA to operate over five of Tempo's channels at 119 W.L. for a six month period, as a  xV"temporary bridge" to make more efficient use of spectrum resources until Directsat's satellite was  S ' xkoperational at 119 W.L.\ X {O2'ԍEchoStar Satellite Corp., Order, 11 FCC Rcd 5351, 5352 (Sat. & Radiocom. Div. 1996). The STA was subject to the condition that EchoStar cease operations upon the  S\' x*launch of Tempo's satellite to the 119 W.L. orbital location.:]\X {O'ԍId.: In June 1996, EchoStar filed a request for  xan extension of its STA to operate on Tempo's channels, and Directsat requested an STA to operate its  x3satellite on the remainder of Tempo's channels. On November 26, 1996, the Chief of the Satellite and  xRadiocommunication Division denied both requests. In doing so, the Division stated that because  S' xDirectsat had launched its satellite, the original basis for the STA was no longer valid. ^2 X {O' "I ԍEchoStar Satellite Corporation, Order, 11 FCC Rcd 16455, 16457 (Sat. & Radiocom. Div. 1996); Directsat  {OX'Corporation, Order, 11 FCC Rcd 16460, 16462 (Sat. & Radiocom. Div. 1996).  On February 24,  x*1997, we denied EchoStar and Directsat's Consolidated Petition for Reconsideration, stating that granting  Sl'an STA a few weeks prior to Tempo's satellite launch was not in the public interest.a_l X {O!'ԍTempo Launch Order, 13 FCC Rcd at 921011.a  S' e 31.` ` After Tempo launched its satellite and reported technical difficulties, EchoStar and  xZDirectsat filed a third request for an STA to use Tempo's 11 channels at the 119 W.L. orbital location  S' x3to provide EchoStar DBS service.i` X {O&'ԍEchoStar/Directsat STA Request, supra footnote 11.i Specifically, EchoStar and Directsat argue that Tempo's reported  xtechnical difficulties are evidence that the frequencies would remain unused in the near term, and that"`,((  ("  xxEchoStar/Directsat, with enough capacity on their combined inorbit satellites to utilize these channels, are  S' x@situated to put these resources to productive temporary use.@aX {O@'ԍId. at 2.@ Moreover, they also state that they will  S' x"discontinue any use of the channels on one day's notice and seven days prior to commencement of  S'service by Tempo."XbZX {O'ԍId. at 14 (emphasis in original).X Tempo opposed EchoStar/Directsat's STA request.|cXX yO' " ԍPetition of Tempo Satellite, Inc. to Dismiss or Deny (filed August 29, 1997). Subsequently, the Commission  x received the following pleadings: Opposition of EchoStar Satellite Corporation and Directsat Corporation (filed September 11, 1997); Reply of Tempo Satellite, Inc. (filed September 18, 1997).|  S:' e 32.` ` Our approval of the Tempo/DirecTV Application today allows DirecTV to follow through  S' xwith immediately initiating service from the 119 W.L. orbital location.Sd X {O 'ԍSee supra paragraphs 6 & 29.S Since we have assurances that  xthe 11 DBS channels in question will be used by the authorized assignee in the very near future, an STA  xfor another licensee to utilize these frequencies is not appropriate. We therefore deny the EchoStar/Directsat STA Request.  Sr'  S" ' DIV. CONCLUSION ă  S ' e 0 33.` ` In view of the foregoing, we find that grant of the authorization for 11 DBS channels at  x@the 119 W.L. orbital location to DirecTV will serve the public interest, convenience, and necessity by increasing competition in the MVPD markets to the benefit of U.S. consumers.  S '- V. ORDERING CLAUSES ă  S' e !34.` ` Accordingly, pursuant to authority delegated by Section 0.261 of the Commission's Rules,  x47 C.F.R.  0.261, IT IS ORDERED that the assignment application, IBFS File No. SATASG19990127 x00014, File No. DBS8804, filed by Tempo Satellite, Inc. and DirecTV Enterprises, Inc. IS GRANTED,  xSUBJECT TO THE CONDITION that DirecTV initiate DBS service to customers using channels 22-32 at the 119 W.L. orbital location by November 28, 1999.  S' e "35.` ` IT IS FURTHER ORDERED that the Petition to Deny filed by EchoStar Communications  xZCorporation, and the Request for Conditional Grant filed by the Small Cable Business Association ARE DENIED, and the Contingent Petition to Dismiss or Deny filed by Media Access Project IS DISMISSED.  S*' e #36.` ` IT IS FURTHER ORDERED that the assignment shall be completed within 60 days from  xthe release of this Order and that the Commission shall be notified by letter within 30 days of consummation. "d,((  "Ԍ S' e $37.` ` IT IS FURTHER ORDERED that the application for consent to transfer of control, IBFS  xFile No. SATT/C1997071800065, File No. 91SATTC97, filed by TCI Satellite Entertainment, Inc. and PRIMESTAR, Inc., IS DISMISSED.  S`' e %38.` ` IT IS FURTHER ORDERED that the Consolidated &b   &b Applications for Special Temporary  xAuthority filed by EchoStar Satellite Corporation and Directsat Corporation, IBFS File Nos. SATSTA xQ1997072100066 and SATSTA1997072100067, File Nos. 92SATSTA97 and 93SATSTA97, ARE DENIED.  S'&39.` ` IT IS FURTHER ORDERED that this Order is effective upon release. ` `  hhCqFEDERAL COMMUNICATIONS COMMISSION ` `  hhCqRoderick K. Porter ` `  hhCqActing Chief, International Bureau