Consumer Project on Technology
	    P.O. Box 19367, Washington, DC 20036
        (202) 387-8030; http://www.essential.org/cpt
     _________________________________________________

August 2, 1996
									  
Via Fax

Mr. Donald Gips
Chief, International Division
Federal Communications Commission
2000 M Street, NW
Washington, DC  20554

Re:  Merger of EchoStar and DBSC


Dear Mr. Gips:

	I am writing to you regarding the request by DBSC and 
EchoStar to merge.  In its July 19, 1996 letter to you, 
EchoStar requested that its merger be approved one week 
later on July 26, 1996.  EchoStar stated that it had made 
financial arrangements and other commitments in anticipation 
of a favorable outcome by the FCC.  I urge you not to 
succumb to such inappropriate pressure.

	If EchoStar and DBSC have irretrievably committed 
resources to accommodate an as yet to be approved 
transaction, that is simply too bad.  In these circumstances 
it is inexcusable for them to make assertions that they have 
counted upon the prospective deal receiving FCC approval 
when antitrust concerns are so obviously at issue and 
approval is clearly not a foregone conclusion.  EchoStar's 
predatory practices in the DBS arena - in which they buy out 
prospective competitors - are also a matter that should be 
carefully considered by the FCC.  These practices have 
serious ramifications for the American public.  

EchoStar's seemingly endless appetite for scarce DBS 
resources (recall the previous merger with another 
competitor-Directsat) has far reaching consequences by 
eliminating other possible media outlets (See Appendix A).  
DBS providers thoroughly control the content of programming.  
However, having many social, cultural, and political 
viewpoints represented - whether in the content of 
programming or commercials -  by as many outlets as possible 
is crucial to the preservation of truly useful First 
Amendment rights.  The fewer DBS operators, the less well 
served is the U.S.  In addition to concerns over fewer 
potential media outlets, EchoStar's merger also reduces the 
possibility that real DBS competition will develop with 
better pricing for consumers because EchoStar will - again - 
be reducing the number of DBS competitors.   

	I urge you to reject EchoStar's request that its merger 
be approved on an expedited basis.  There are important 
consumer, public interest, and First Amendment values that 
will be degraded if the merger is approved.  EchoStar's 
position will be improved by buying off yet another 
potential competitor at the expense of American consumers.  
We respectfully request that this proceeding at the very 
least not be given short shrift.  When the antitrust and 
First Amendment issues are considered it is clear that 
EchoStar's merger must be denied as against the public 
interest.

					Sincerely,  


					/s/Todd J. Paglia
Appendix A