Attachment Narrative Statement SES-LIC-20160107-00027

Attachment Narrative Statement

This document pretains to SES-LIC-20160107-00027 for License on a Satellite Earth Station filing.

IBFS_SESLIC2016010700027_1120924

context, but RigNet has fully coordinated the proposed operations at the subject site so
there is no potential for interference from the proposed operations.

I. BACKGROUND
RigNet seeks to operate the Orbit-2.2 terminal in certain Ka-band frequencies on
a fixed oil platform while communicating with the O3b system. In 2015, the
Commission granted O3b’s Petition for Declaratory Ruling seeking market access to
serve the United States.2 In that application, O3b submitted a Schedule S describing the
technical characteristics of its satellite system. RigNet certifies that it will operate the
Orbit-2.2 terminal with the O3b system consistent with the technical parameters outlined
in the O3b application for market access.
The Orbit-2.2 terminal has been the subject of numerous blanket license and
waiver applications by O3b, where the Commission has authorized Ka-band operations of
the terminal on maritime vessels and at fixed locations. In May 2014, the Commission
granted O3b a blanket earth station onboard vessel (“ESV”) license and a related waiver
to operate one hundred Orbit-2.2m terminals on U.S. and non-U.S. registered vessels in
NGSO primary Ka-band spectrum, the 28.6-29.1 GHz (Earth-to-space) band and the
18.8-19.3 GHz (space-to-Earth) band.3 In September 2014, the Commission granted
authority to O3b to operate the Orbit-2.2m on up to three non-U.S. registered vessels in
and near U.S. waters in the GSO primary Ka-band spectrum, the 28.35-28.4 GHz (Earth-
to-space) band and 18.3-18.6 GHz (space-to-Earth) band.4
The following year in May 2015, the Commission granted O3b maritime
operating authority to use Orbit-2.2 terminals on six non-U.S. registered maritime vessels
in and near U.S. waters in the local multipoint distribution service (“LMDS”) primary

2
See File No. SAT-LOI-20141029-00118, Call Sign S2935 (granted Jan. 22, 2015).
3
See File No. SES-LIC-20130528-00455 (Call Sign E130098); Letter from Jose
Albuquerque, Chief, Satellite Division and Mark Settle, Chief, Policy and Rules Division,
to Joslyn Read, O3b Limited, DA 14-637 (rel. May 13, 2014).
4
See File No. SES-MSC-20140318-00150, Letter from Jose Albuquerque, Chief,
Satellite Division and Mark Settle, Chief, Policy and Rules Division, to Suzanne Malloy,
O3b Limited, DA 14-1369 (rel. September 22, 2014).

2

uplink band, the 27.6-28.35 GHz (Earth-to-space), and the Fixed Service (“FS”) primary
downlink band, 17.8-18.3 GHz (space-to-Earth).5 Most recently in June 2015, O3b was
issued a blanket ESV license to operate 1,000 fixed Orbit-2.2 terminals in NGSO primary
Ka-band spectrum, the 28.6-29.1 GHz (Earth-to-space) band and the 18.8-19.3 GHz
(space-to-Earth) band.6
As demonstrated above, there is extensive precedent for the Commission to
license the Orbit-2.2 terminal to operate on a fixed oil rig platform in the Gulf of Mexico.
RigNet’s proposed operation of a single Orbit-2.2 terminal in a fixed oil rig is much more
limited in scope and number than the aforementioned O3b authorizations. Furthermore,
RigNet holds multiple licenses for comparable offshore earth station terminal and VSAT
network operations in the C-band and Ku-band7 and grant of the requested authority is
consistent with RigNet’s ongoing commercial operations. Finally, the Commission has
previously granted authorization to RigNet for fixed terminal operations in the Gulf of
Mexico8 and the herein proposed operations will be similar in nature. Grant of the
requested authority will allow RigNet to enhance the commercial offerings on the Shenzi
Platform and enable more efficient provision of critical communications services for
employees and personnel on the platform using innovative terminal technologies, while
also expanding the use of Ka-band satellite spectrum.
RigNet seeks to operate the Orbit-2.2 on a fixed oil platform while
communicating with the O3b Ka-band NGSO FSS system.9 For the relevant Ka-band

5
See SES-MSC-20150206-00066, Letter from Jose Albuquerque, Chief, Satellite
Division and Mark Settle, Chief, Policy and Rules Division, to Suzanne Malloy, O3b
Limited, DA 15-601 (rel. May 20, 2015).
6
See File No. SES-LIC-20141001-00781 (Call Sign E140101).
7
See, e.g., RigNet Satcom, Inc., File No. SES-LIC-20070827-01132 (Call Sign E070189)
& File No. SES-MOD-20100409-00427 (Call Sign E060317).
8
See RigNet Satcom, Inc., File No. SES-LIC-20070827-01132 (Call Sign E070189).
9
The Orbit 2.2 terminal has been more recently referred to as the OceanTRx™ 7-500
2.2m Ka-band stabilized maritime VSAT System. A commercial data sheet is available
at the following link: http://www.o3bnetworks.com/wp-content/uploads/2015/02/O3b-
Maritime-2.2m-Orbit-DatasheetT-TRx-7-500.pdf (visited Jan. 5, 2015).

3

frequencies, Comsearch conducted frequency coordination analyses that demonstrate
RigNet may operate the Orbit-2.2 terminal without causing harmful interference. 10
Comsearch sent a coordination notice to existing licensees within relevant coordination
distances and RigNet’s proposed operations on the Shenzi platform are fully compatible
with other FCC-licensed operations in these frequencies and present no potential for
interference into other users of the subject Ka-band frequencies. RigNet also provides
the attached Form 312, Schedule B, Technical Appendix and associated exhibits for
relevant information relating to the Orbit-2.2 Ka-band terminal’s operational
characteristics.
II. SPECTRUM USE
The United States Table of Allocations and the Commission’s Ka-band Plan
identifies various spectrum allocations for services in the Ka-band . RigNet will operate
the Orbit-2.2 terminal in accordance with the Commission’s Ka-band rules and policies
or, to the extent necessary, seeks a limited waiver of the Commission’s rules to operate
the terminal on a non-conforming (unprotected and non-interference) basis.
RigNet seeks to communicate with O3b’s Ka-band NGSO FSS system in the
following bands: 27.6-28.4 GHz (Earth-to-space), 28.6-29.1 GHz (Earth-to-space), 17.8-
18.6 GHz (space-to-Earth) and 18.8-19.3 GHz (space-to-Earth). The Orbit-2.2 terminal
will be mounted on a single oil platform and, although the pointing angle of the antennas
will change as O3b’s satellites are tracked, the platform will remain stationary. In the
following sections, RigNet demonstrates that it can operate the stationary Orbit-2.2
terminal consistent with the Commission’s Ka-band spectrum policies.
O3b has previously completed all necessary coordination with U.S. government
satellite networks operating in the Ka-band, including GSO and NGSO networks. O3b
has also completed coordination with the U.S. government under footnote US334 of the
FCC Table of Frequency Allocations. RigNet certifies that its proposed operations will
be in accordance with all existing and future coordination agreements between O3b and
other authorized Ka-band spectrum users.

10
See Technical Appendix, VI.

4

A. Uplink Frequencies & Ka-band Plan Designation
a. Primary NGSO FSS Uplink
The Table of Frequency Allocations and the Commission’s Ka-band Plan provide
that the 28.6-29.1 GHz (Earth-to-space) band segment may be used by NGSO FSS
systems on a primary basis and by GSO FSS systems on a secondary basis. 11
Accordingly, RigNet will operate the Orbit-2.2 terminal on a primary basis in the 28.6-
29.1 GHz band in accordance with the Table of Allocations and Ka-band Plan.
b. Secondary NGSO FSS Uplink
The Commission’s Table of Allocations and Ka-band Plan provide that in the
27.6-28.35 GHz (Earth-to-space) band, LMDS systems are primary and FSS systems are
secondary.12 Furthermore, in the 28.35-28.4 GHz (Earth-to-space) band segment, GSO
FSS systems are primary and NGSO FSS systems are secondary.13 Accordingly, RigNet
will operate the Orbit-2.2 on a secondary, non-harmful interference basis to LMDS in the
27.6-28.35 GHz band and to GSO FSS systems in the 28.35-28.4 GHz band.
RigNet notes that its proposed operations in the 27.6-28.35 GHz band segment are
consistent with the Commission’s view on the type of FSS operations that would not
cause harmful interference to primary LMDS stations in the band. The Commission has
previously stated that FSS operations in this bands are limited to “gateway-type”
operations. However, the Commission’s references to “gateway-type” service in the
27.5-28.35 GHz band are not intended as a requirement that all earth stations in the band
serve as gateway earth stations. Rather, the mention of “gateway-type” service in the

11
In the Matter of Rulemaking to Amend Parts 1, 2, 21, and 25 of the Commission's Rules
to Redesignate the 27.5-29.5 GHz Frequency Band, to Reallocate the 29.5-30.0 GHz
Frequency Band, to Establish Rules and Policies for Local Multipoint Distribution
Service and for Fixed Satellite Services, 11 FCC Rcd. 19005, ¶¶ 57-58 and 78 (1996)
(“Ka-band Plan R&O”). See also In the Matter of Redesignation of the 17.7-19.7 GHz
Frequency Band, Blanket Licensing of Satellite Earth Stations in the 17.7-20.2 GHz and
27.5-30.0 GHz Frequency Bands, and the Allocation of Additional Spectrum in the 17.3-
17.8 GHz and 24.75-25.25 GHz Frequency Bands for Broadcast Satellite-Service Use, 15
FCC Rcd 13430, ¶¶ 28 and 34 (2000) (“Redesignation of Ka-band Plan R&O”).
12
See Ka-band Plan R&O ¶¶ 59-62; see also Redesignation of Ka-band R&O ¶ 28.
13
Ka-band Plan R&O ¶ 42; see also Redesignation of Ka-band Plan R&O ¶ 28.

5

27.5-28.35 GHz band serves as an example of what the Commission’s envisions as the
type of service that FSS operators would be able to provide on a secondary basis without
causing interference to primary LMDS stations in the band.
The Commission’s main concern is ubiquitous terminals that could interfere with
LMDS operations, recognizing that “as a practical matter, it is unlikely that FSS can
operate ubiquitous terminals on an unprotected non-interference basis to LMDS.” 14
Although the rules limit operations in some bands to gateway earth stations only, the
27.5-28.35 GHz band is not among them and there is no requirement that earth station
terminals serve as gateways.15 RigNet’s proposed earth station operations, at a single
enterprise location -- an oil production facility -- in the Gulf of Mexico, are limited in
scope and consistent with the Commission’s views on high data-rate, gateway-type
operations. Accordingly, RigNet can be permitted to operate on a secondary basis to
LMDS in the 27.6-28.35 GHz band.
As a secondary user, RigNet’s proposed operations in the 27.6-28.35 GHz band
must not cause interference to primary LMDS stations. The attached Comsearch
coordination report demonstrates that RigNet may operate the Orbit-2.2 earth station
terminal on the Shenzi Platform without causing harmful interference to LMDS licensees.
Comsearch sent a coordination notice to all existing licensees in the band within
application coordination distances and no objections were received from incumbent
licensees. Furthermore, RigNet agrees not to cause harmful interference to future
primary LMDS operations in the band and will accommodate any future LMDS licensees
to the extent necessary to avoid harmful interference.
In the 28.35-28.4 GHz band, RigNet will operate the Orbit-2.2 terminal on a
secondary basis to GSO FSS systems and will not cause harmful interference to U.S.-

14
In the Matter of Rulemaking to Amend Parts 1, 2, 21, and 25 of the Commission's Rules
to Redesignate the 27.5- 29.5 GHz Frequency Band, to Reallocate the 29.5-30.0 GHz
Frequency Band, to Establish Rules and Policies for Local Multipoint Distribution
Service and for Fixed Satellite Services, Third Report and Order, 12 FCC Rcd 22310,
22327, ¶ 42 (1997).
15
The Commission has previously recognized that Ka-band maritime earth station
operations are consistent with the Commission’s view of “gateway-type” services and
operations. See File No. SES-MSC-20150206-00066.

6

licensed GSO FSS systems in this band segment. Although Orbit-2.2 terminal will
operate exclusively with O3b’s NGSO FSS system, RigNet will operate the terminal
consistent with the off-axis EIRP limits specified in Section 25.138 of the Commission’s
rules to ensure compatibility with GSO FSS Ka-band satellite operations.16 Furthermore,
as discussed in the attached Technical Appendix, the Orbit-2.2 terminal is designed to
meet certain FCC ESV operational requirements, including: (i) pointing accuracy of 0.2°
or better; (ii) automatic cessation of emissions within 100 ms if pointing offset exceeds
0.5°; and (iii) transmissions will not resume until pointing accuracy is within 0.2°.17
Finally, as previously demonstrated by O3b, operations of the subject Ka-band
NGSO system comply with the relevant equivalent power flux density (“EPFD”) uplink
limits in the 27.6-28.4 GHz band pursuant to Article 22 of the ITU Radio Regulations.18
Thus, the proposed NGSO terminal operations will provide the required level of
protection from GSO FSS systems operating in the 27.6-28.4 GHz band.
B. Downlink Frequencies & Ka-band Designation
a. Primary NGSO FSS Downlink
The Table of Frequency Allocations and the Commission’s Ka-band Plan provide
that the 18.8-19.3 GHz (space-to-Earth) band may be used by NGSO FSS operations on a
primary basis.19 Furthermore, as previously demonstrated by O3b, operations of the

16
See 47 C.F.R. § 25.138; Technical Appendix, I.
17
See Technical Appendix, V.
18
See File No. SES-MSC-20150206-00066, Technical Appendix A.7; contactMEO
Communications, LLC, 21 FCC Rcd 4035, 4043-4044 (IB 2006) (where the Commission
held that compliance with the ITU’s EPFD limits provides a sufficient basis for an NGSO
FSS system to operate on a non-interference basis in a band in which GSO FSS systems
are primary).
19
See Ka-band Plan R&O ¶¶ 59-62; see also Redesignation of Ka-band R&O ¶ 28. Note
that low power point-to-multipoint terrestrial fixed systems may continue to be licensed
and operate on a co-primary basis with NGSO/FSS in the 18.82-18.87 GHz and 19.16-
19.21 GHz bands.

7

subject Ka-band NGSO system comply with the relevant power flux density (“PFD”)
downlink limits for the 18.8-19.3 GHz band designed to protect terrestrial FS services.20
b. Downlink with No NGSO FSS Allocation
The Table of Frequency Allocations and the Commission’s Ka-band Plan provide
that the 17.8-18.3 GHz band may be used by FS systems on a primary basis and NGSO
FSS operations on a non-conforming basis.21 Furthermore, the Table of Allocations and
Ka-band Plan provide that in the 18.3-18.6 GHz band, GSO FSS systems are primary
with no allocation for NGSO FSS systems.22 Accordingly, RigNet will operate the Orbit-
2.2 on a non-conforming, non-interference basis to FS systems in the 17.8-18.3 GHz
band and to GSO FSS systems in the 18.3-18.6 GHz band.
RigNet respectfully requests a waiver of the U.S. Table of Frequency Allocations,
47 C.F.R. § 2.106, and the Ka-band Plan to the extent necessary to permit its non-
conforming use of the 17.8-18.6 GHz band. In considering requests for non-conforming
uses, the Commission has indicated it would grant such waivers when there is little
potential for interference into any service authorized under the Table of Frequency
Allocations and when the non-conforming operator accepts any interference from
authorized services.23
RigNet certifies it will not claim protection from conforming uses of the spectrum
while the terminal is operating and agrees to accept any harmful interference from other
services while operating on an unprotected, non-conforming basis. In addition, RigNet
will immediately terminate its earth station operations upon notification that such

20
See File No. SES-LIC-20130528-00455, Technical Appendix, A.5-A.7. Fixed Service
stations in the United States operating in the 18.8-19.3 GHz band are no longer co-
primary with FSS users in this band. See 47 C.F.R. § 101.85(b)(2).
21
See Redesignation of Ka-band Plan R&O ¶¶ 28 and 34.
22
Id.
23
See Letter from Jose Albuquerque, Chief, Satellite Division and Mark Settle, Chief,
Policy and Rules Division, to Suzanne Malloy, O3b Limited, DA 14-1369 (rel.
September 22, 2014); Contactmeo Communications, LLC, Order and Authorization, 21
FCC Rcd 4035, 4044 (IB 2006); ViaSat AMSS Order, File No. SES-MFS-20090624-
00789; see also 47 C.F.R. § 1.3.

8

operations are not permitted under the terms of a coordination agreement with, or are
causing harmful interference to, any lawfully operating radio system in the 17.8-18.6
GHz band in conformance with the U.S. Table of Frequency Allocations. RigNet also
certifies that its operations will be in accordance with any coordination agreement that
has been or will be reached between O3b and other lawfully operating spectrum users.
As previously demonstrated by O3b, operations of the subject Ka-band NGSO
system comply with the relevant downlink PFD limit for the 17.8-18.6 GHz band
designed to protect terrestrial FS services.24 Operations of the subject Ka-band NGSO
system also comply with EPFD downlink limits in the 17.8-18.6 GHz band,25 therefore
providing the required level of protection from GSO FSS systems operating in the band
pursuant to Article 22 of the ITU Radio Regulations. Furthermore, the terminal will
operate within the off-axis EIRP limits specified in Section 25.138 of the Commission’s
rules and the pointing accuracy, recording and automatic muting capabilities of the Orbit-
2.2 will ensure that there is no harmful interference to GSO FSS systems in this band.
III. PUBLIC INTEREST
Grant of the requested earth station operating authority will strongly serve the
public interest. As described in the application materials, the Orbit-2.2 will comply with
the Commission’s rules and policies governing Ka-band earth station operations and will
otherwise operate on an unprotected non-interference, non-conforming basis.
Authorizing the Orbit-2.2 terminal for Ka-band operations will also facilitate the
utilization of Ka-band spectrum for more regularized commercial operations. In addition,
RigNet will be able to provide more robust broadband satellite communications services
to employees on the Shenzi Platform and enhance the commercial offerings in remote
locations. Users will be able to utilize high-speed Internet access, corporate VPN, e-mail,
voice and other services, including emergency communications to support oilrig
personnel. Moreover, the Orbit-2.2 terminal will facilitate operational flexibility and
service optimization based on spectrum availability and customer needs.

24
See File No. SES-MSC-20150206-00066, Technical Appendix A.5.
25
Id. at Technical Appendix A.7.

9

IV. WAIVER
RigNet is seeking a waiver of the U.S. Table of Frequency Allocations, Section
2.106 of the Commission’s Rules, 47 C.F.R. § 2.106, and the Commission’s Ka-band
plan to the extent necessary to permit its non-conforming use of the Ka-band as described
above. As noted, in considering requests for non-conforming uses, the Commission has
indicated it would grant such waivers when there is little potential for interference into
any service authorized under the Table of Frequency Allocations and when the non-
conforming operator accepts any interference from authorized services.26
There is strong Commission precedent for granting such a waiver. The
Commission has granted identical waiver requests to O3b on numerous occasions for its
non-conforming use of the Ka-band maritime ESV operations.27 The O3b waivers were
granted in the context of NGSO maritime vessel operations and O3b has been granted
authorization to operate on an unprotected non-interference basis in primary, secondary
and non-conforming NGSO FSS spectrum. RigNet’s proposed operations are much more
limited and substantially conform to the Table of Allocations and Commission’s Ka-band
Plan. Additionally, RigNet has demonstrated it can operate the terminal on an
unprotected non-conforming basis without causing harmful interference to other legally
operating systems in the 17.8-18.6 GHz band.
As detailed in the above sections, when operating on an unprotected non-
conforming, non-interference basis in the 17.8-18.6 GHz band, RigNet will not claim
protection from conforming uses of the spectrum. In addition, RigNet will operate the
terminal within the off-axis EIRP limits in Section 25.138 and otherwise comply with the
Commission’s two-degree spacing policy. Upon notification that such operations are not
permitted under the terms of a coordination agreement with, or are causing harmful
interference to, any lawfully operating system in the subject Ka-band segments in
conformance with the U.S. Table of Frequency Allocations, RigNet will immediately
cease transmissions. Accordingly, the Commission may grant the requested waiver.

26
See supra note 24.
27
See Letter, DA 14-637 (rel. May 13, 2014); Letter, DA 14-1369 (rel. September 22,
2014); Letter, DA 15-601 (rel. May 20, 2015).

10

V. CONCLUSION
In view of the foregoing, RigNet respectfully requests that the Commission grant
it a license to operate the Orbit-2.2 fixed earth station terminal on the Shenzi Platform in
the Gulf of Mexico in the Ka-band to communicate with O3b’s NGSO FSS system.

11

Document Created: 0950-04-21 00:00:00
Document Modified: 0950-04-21 00:00:00

© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC