Attachment Motion

Motion

MOTION TO ACCEPT LATE FILED COMMENTS submitted by SCHLUMBERGER OMNES, INC.

Motion for Leave to File Late

2004-10-14

This document pretains to SES-LIC-20021028-01926 for License on a Satellite Earth Station filing.

IBFS_SESLIC2002102801926_401594

RECEIVED - FCC Before the FEDERAL GOMMUNICAT10NS COMMISSION Washington, D.C. 20554 In the Matter of 1 1 SCHLUMBERGER OMNES, INC. ) File No. SES-LIC-20021028-0196 ) Application for Authority to 1 Operate a Ku-band Mobile 1 VSAT Network 1 To: Chief, International Bureau MOTION FOR LEAVE TO FILE LATE On October 25, 2002, the above-referenced FCC Form 312 application was filed to operate a Ku-band mobile VSAT network on vessels traveling along U.S. inland waterway systems (the “Application”). A Petition for Waiver of the Table of Allocations (“Petition”) to permit mobile operation of this VSAT system on frequencies assigned for fixed use was filed with the Application. The International Bureau (“Bureau”) requested additional information concerning the Application. On August 30, 2004, the Bureau granted Schlumberger Omnes, Inc. (“Sol”) until September 29, 2004, to file its responses to the Bureau’s request for information. These responses were filed with the Commission on October 8, 2004, as an amendment (a copy of which is attached hereto). A Motion for Leave to File Late (“Motion”) inadvertently was not included with this amendment. Good cause exists for grant of this Motion and acceptance of the filed amendment. First, SO1 was dependent on obtaining affidavits from

several third parties and worked diligently to get those affidavits completed. SO1 promptly filed the affidavits once they were received. Second, this Application has been pending for almost two (2) years. Grant of the Application and the Petition clearly are in the public interest. Sol’sproposed mobile VSAT technology would enable: (i) barge operators to operate, on an interference-free basis by replacing their conventional, bridge-to-bridge VHF radios with a state-of-the-art telecommunications network; (ii) support the President’s Homeland Security initiatives; and (iii) support U.S. Coast Guard and Army Corps efforts to improve safe barge traffic and early severe weather detection on the Inland Waterway system. Moreover, there was no interference caused by the mobile VSAT when SO1 was operating under STA. Third, no other party protested grant of the Application or Petition and thus no other party would be prejudiced by grant of this Motion. For the foregoing reasons, SO1 requests that the Bureau grant this Motion and accept its late-filed amendment. Respectfully submitted, SCHLUMBERGER 3MNES, INC. I Robert J. Miller Gardere Wynne Sewell LLP 1601 Elm Street, Suite 3000 Dallas, Texas 75201-4761 (214) 999-4219 Its Attorney October 13, 2004 DALLAS 1457549~1

RECEIVED FCC - South Houston Teleport 7265 Old Galveston Road OCT - 8 2004 Houston, Texas 77034 AMENDMENT Schlumberger Omnes, Inc. Call Sign: E020303 File No. SES-LIC-20021028-01926 The above-referenced application is hereby amended to include the attached requested declarations from adjacent satellite operators affected within six degrees of the points of communication (SES Americom Inc., lntelsat Global Services, and PanAmSat Corporation), attesting that each such operator is aware of and acknowledges the applicant's proposed operation in the Ku Band, and does not object to that operation. pYZLJJ 2-nd Michael D. Lennon Teleport Operations Manager Dated:October 7,2004 DALLAS 1455905~1

SESAAPIERICOM An SES GLOBAL Company September 21,2004 Federal Communications Commission - International Bureau 445 12th Street, S.W. Washington, D.C. 20554 Subject: Engineering Certification of SES Americom To whom it may concern: This letter certifies that SES Americom Inc. (ISESII) is aware of the application pending with the Federal Communications Commission (“FCC”) to grant Schlumberger Omnes, Inc. (Sol”) (FCC File No. SES-LIC-20021028-01926) (the “Application”) authority to operate a Ku-band fixed VSAT network serving earth stations on vessels (“ESVs”)along the U.S. Inland Waterway system. SO1 is seeking FCC authorization to utilize the FCC-licensed SES satellite AMC- 4 at 101 degrees W.L. SES has provided lntelsat Global Services with a list of SES transponders currently assigned to support transmissions from these antennas. For purposes of inter-system coordination, SES promptly will provide lntelsat Global Services with relevant information for any additional or different transponders provided by SES. SO1 proposes to use the Spacetrack Ku-band terminal with a 1.2 meter circular aperture antenna. SES understands that this antenna complies with the requirements of Section 25.209 of the FCC’s rules. This antenna will maintain a nominal pointing accuracy of +/-0.2 degrees and will be operated at a maximum input power density at the qntenna waveguide flange of -18 dBW/4 kHz, which satisfies the -14.0 dBW/4 kHz FCC maximum for 2-degree compliant systems and routine licensing.’ Transmission will be inhibited upon loss of receiver lock or at pointing offset larger than 0.2 degrees from the intended satellite. ’ 47 CFR 0 25.134 wwwses-americom.com Page 1 of 3 I SES AMERICOM, Inc. Four Research Way I Princeton NJ 08540 USA I le1 (1) 609-987-4000

September 21,2004 Page 2 of 3 SES and SO1 each acknowledges that these antennas will be installed in compliance with the technical, operational and performance requirements in Part 25 of the FCC’s rules and in compliance with all requirements set forth in Sol’s FCC licenses. The above antennas will be installed by a professional installer and aligned with the intended satellite to less than or equal to the tolerance parameters set forth in this letter. The undersigned further certifies that the maximum downlink satellite ElRP density of 6.0 dBW/4KHz for Sol’s Ku-band VSAT network is within the levels coordinated with lntelsat Global Services. SES acknowledges that Sol’s use of its ESV antenna system, installed and operated in accordance with the above conditions, should not cause unacceptable interference into adjacent satellites. SES further acknowledges that SO1 will accept interference from adjacent satellites to the degree harmful interference would not be expected to be caused to an earth station employing an antenna conforming to the reference patterns defined in Section 25.209 of the FCC’s rules. If the use of this antenna should cause interference into other systems, SO1 has agreed that it will terminate transmissions immediately upon notice from the affected parties. Furthermore, should other satellites be positioned at the aforementioned orbital locations, the transponder assignments coordinated pursuant to this letter will remain the same. Sincerely, Development, Director SES Americom

September 21,2004 Page 3 of 3 Acceptance by Schlurnberger Omnes Inc. : Schlumberger Omnes testifies that the information provided to SES Americom and reflected in this Affidavit letter is true and accurate to the best of Schlumberger Omnes’ knowledge. Operations Manager Schlumberger Omnes, Inc. Acceptance by lntelsat Global Services: lntelsat Global Services agrees to the use of the Spacetrack Ku-band terminal with an aperture of 1.2 meter, with their respective azimuth angle alignment tolerances toward AMC-4 and the power density levels into the antenna flange as stated in this letter, with respect to lntelsat satellite transponders that are within +/- 6 degrees orbital spacing from AMC-4 at 101 degrees W.L. n Ram Manohar Department Manager, Frequency Management lntelsat

An SES GLOBAL Company September 21,2004 Federal Communications Commission - International Bureau 445 12th Street, S.W. Washington, D.C. 20554 Subject: Engineering Certification of SES Americom To whom it may concern: This letter certifies that SES Americom Inc. (‘ISESI’) is aware of the application pending with the Federal Communications Commission (“FCC”) to grant Schlumberger Omnes, lnc. (“Sol”) (FCC File No. SES-LIC-20021028-01926) (the “Application”) authority to operate a Ku-band fixed VSAT network serving earth stations on vessels (“ESVs”) along the U.S. Inland Waterway system. SO1 is seeking FCC authorization to utilize the FCC-licensed SES satellite AMC- 4 at 101 degrees W.L. SES has provided PanAmSat with a list of SES transponders currently assigned to support transmissions from these antennas. For purposes of inter-system coordination, SES promptly will provide PanAmSat with relevant information for any additional or different transponders provided by SES. SO1 proposes to use the Spacetrack Ku-band terminal with a 1.2 meter circular aperture antenna. SES understands that this antenna complies with the requirements of Section 25.209 of the FCC’s rules. This antenna will maintain a nominal pointing accuracy of +/-0.2 degrees and will be operated at a maximum input power density at the antenna waveguide flange of -18 dBW/4 kHz, which satisfies the -14.0 dBW/4 kHz FCC maximum for 2-degree compliant systems and routine licensing.’ Transmission will be inhibited upon loss of receiver lock or at pointing offset larger than 0.2 degrees from the intended satellite. SES and SO1 each acknowledges that these antennas will be installed in compliance with the technical, operational and performance requirements in Part ’ 47 CFR Q 25.134 SES AMERICOM, Inc. I Four Research Way Princeton NJ 08540 I USA 1 t e l l ) 609-987-4000 I www.ses-americom.com

September 21,2004 Page 2 of 3 25 of the FCC’s rules and in compliance with all requirements set forth in Sol’s FCC licenses. The above antennas will be installed by a professional installer and aligned with the intended satellite to less than or equal to the tolerance parameters set forth in this letter. The undersigned further certifies that the maximum downlink satellite ElRP density of 6.0 dBW/4KHz for Sol’s Ku-band VSAT network is within the levels coordinated with PanAmSat. SES acknowledges that Sol’s use of its ESV antenna system, installed and operated in accordance with the above conditions, should not cause unacceptable interference into adjacent satellites. SES further acknowledges that SO1 will accept interference from adjacent satellites to the degree harmful interference would not be expected to be caused to an earth station employing an antenna conforming to the reference patterns defined in Section 25.209 of the FCC’s rules. If the use of this antenna should cause interference into other systems, SO1 has agreed that it will terminate transmissions immediately upon notice from the affected parties. Furthermore, should other satellites be positioned at the aforementioned orbital locations, the transponder assignments coordinated pursuant to this letter will remain the same. Sincerely, Development, Director SES Americom

x September 21,2004 Page 3 of 3 Acceptance by Schlumberger Omnes Inc.: Schlumberger Omnes testifies that the information provided to SES Americom and reflected in this Affidavit letter is true and accurate to the best of Schlumberger Omnes' knowledge. Operations Manager Schlumberger Omnes, Inc. Acceptance by PanAmSat: PanAmSat agrees to the use of the Spacetrack KU-band terminal with an aperture of 1.2 meter, with their respective azimuth angle alignment tolerances toward AMC-4 and the power density levels into the antenna flange as stated in this letter, with respect to Galaxy satellite transponders that are within +/- 6 degrees orbital spacing from AMC-4 at 101 degrees W.L.. Vice P r e s i v Customer Support ngineering PanAmSat Corporation


Document Created: 2004-10-19 11:10:44
Document Modified: 2004-10-19 11:10:44
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