Attachment Antenna Unknown Make

This document pretains to SES-REG-INTR2018-09021 for Earth Station Registration on a Satellite Earth Station filing.

IBFS_SESREGINTR201809021_1558515

                                                                              Sarkes Tarzian, Inc.
                                                                                  FCC Form 312
                                                                                    October 2018


    Explanatory Statement re: Form 312, Question 35 and Schedule B, Questions E30 & E31

        The attached Form 312 application states in response to Questions E30 & E31 on
Schedule B that the manufacturer and model number of one or more antennas being registered is
“Unknown.” No information is provided in response to these questions due to the age of the
antenna and the absence of company records detailing this information. The antenna diameter
and estimated receive gain are provided, however.

        To the extent necessary, the applicant seeks a waiver of the Form 312 application
requirements to permit acceptance of the application without this information. The public
interest will be served by granting such a waiver in that processing and grant of the requested
registration will provide the Commission with information it is affirmatively seeking in
connection with its rulemaking in GN Docket No. 18-122.1

        The applicant, however, does not believe that any waiver of the Commission’s Rules is
required and therefore has answered “No” to Question 35 on the Main Form 312. In particular,
Sections 25.130(a) and 131(a) of the Commission’s Rules, which govern the technical content of
receive-only Earth station applications, do not list the antenna manufacturer and model as
required data, but instead specify provision of only the antenna diameter or equivalent diameter,
as well as the specific satellite(s) with which it plans to operate, or the eastern and western
boundaries of the arc it plans to coordinate. See 47 C.F.R. § 25.130(a) and 25.131(a). This
information is provided in the attached application, and no coordination report is necessary
pursuant to the blanket waiver of this requirement in the Commission’s April 19, 2018 Public
Notice.2 Accordingly, acceptance of this registration application with the information provided
is appropriate and consistent with the Commission’s Rules.




1
 Expanding Flexible Use of the 3.7 to 4.2 GHz Band, Order and Notice of Proposed
Rulemaking, FCC 18-91 (released July 13, 2018).
2
  See FCC Public Notice, “90-Day Window to File Applications for Earth Stations Currently
Operating in 3.7-4.2 GHz Band, DA 18-398 (released April 19, 2018), at 4-5 (waiving the
requirement contained in Section 25.131(d) of the FCC’s rules for C-band receive-only
registration applications to include a coordination report).



Document Created: 2019-04-25 12:10:47
Document Modified: 2019-04-25 12:10:47

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