Attachment sta request

This document pretains to SES-STA-20000309-00316 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2000030900316_130129

               SWIDLER BERLIN SHEREFF FRIEDMAN, LLP
                                     3000 K STREET, NW, SUITE 300
                                     WASHINGTON, DC 20007-5116
                                         TELEPHONE (202)424-7500                        NEW YORK OFFICE
                                         FACSIMILE (202) 424-7645                       919 THIRD AVENUE
                                                                                      NEW YORK, NY 10022




                                           March 9, 2000

VIA ELECTRONIC FILING

Magalie Roman Salas, Secretary
Federal Communications Commission
International Bureau, Earth Stations
P.O. Box 358160
Pittsburgh, Pennsylvania 15251-5160

               EXPEDITED PROCESSING REQUESTED
       Re:     IWL Communications, Inc.
               Request for Special Temporary Authority to Operate
               Temporary-Fixed Earth Stations Pending Approval of Initial Application

Dear Secretary Salas:

        IWL Communications, Inc. (ΑIWL Communications≅), by its undersigned attorneys and
pursuant to Section 25.120 of the Commission=s Rules, 47 C.F.R. ∋ 25.120, hereby requests Special
Temporary Authority ("STA") to permit it to operate a temporary-fixed earth station pending
approval of its FCC Form 312 application which is being concurrently filed with the Commission
(FCC File No. IB2000000189). Included with the Form 312 is a certification of prior frequency
coordination. IWL Communications seeks immediate authority to provide critical communications
links for an oil drilling platform located in the Gulf of Mexico. Expedited processing is requested for
the urgent reasons set forth herein.

        By design, an oil drilling platform is transient in nature and can be moved to various points
to locate and extract oil deposits beneath the ocean floor. In order to ensure the proper operation
of the platform, as well as the safety of its crew, both routine and critical functions are monitored
through the use of, in this case, a temporary-fixed earth station. The station establishes a vital link
between the platform and the continental United States by providing voice and data capabilities to
the platform. In the event of an emergency, this link can be used to assist in dangerous and life
threatening events, or to avert situations which may lead to adverse environmental impacts.


         Because oil drilling platforms are often relocated without significant advance notice, it is
difficult to obtain a temporary-fixed earth station license from the Commission before the platform
is operational.1 Therefore, unless an STA is obtained, an oil platform may be without important
communications capabilities during its initial stages of operation. The requested STA is necessary
to ensure that critical communications facilities will be available during this start-up period in order
to protect the safety of the workers on the platform, ensure the proper operation of the platform, and
protect the environment. In light of these extraordinary circumstances, IWL Communications
respectfully requests immediate Special Temporary Authority to operate the temporary-fixed earth
station that is the subject of the attached application. IWL Communications acknowledges that grant
of this request will not prejudice action by the Commission on its pending application, and that any
authority granted pursuant to this request is subject to cancellation or modification upon notice, but
without a hearing.

       Please date stamp the extra copy of this filing, and return it in the enclosed self-addressed
stamped envelope. As required by the Commission=s rules, a filing fee in the amount of $135.00 is
included with this STA request. Please direct any inquiries regarding this filing to the undersigned.

                                               Respectfully submitted,



                                               Catherine Wang
                                               Edward S. Quill

                                               Counsel for the IWL Communications, Inc.

cc:    Jeanne W. Stockman




       1
          Applicant understands that the underlying FCC Form 312 seeks authorization to operate
an antenna that does not comply with Section 25.209 of the Commission's rules and that the
application may, therefore, not be eligible for routine processing. IWL further understands that
Commission is reviewing its policy regarding antennas that are not Section 25.209 compliant and
 319896.1
that a Public Notice on this matter is expected in the near future. Because that Public Notice has
not yet been issued, however, Applicant respectfully requests special temporary authority to
operate the subject station pending its issuance and subsequently while Applicant seeks to comply
with its terms.



Document Created: 2019-04-19 18:09:54
Document Modified: 2019-04-19 18:09:54

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