Attachment STA grant

This document pretains to SES-STA-20060224-00299 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2006022400299_484857

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                                                                                                             Approved by OMB
                                                                                                                   3060—0678

                            APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY



APPLICANT INFORMATIONEnter a description ofthis application to identify t on the main menu:
STA to conducttesting on earth station prioto deployment with waiver.
 1. Applicant

           Name:        PettoCom License Corporation   Phone Number:                  504—736—9400
           DBA Name:                                   Fax Number:                    504—734—6100

           Street:      5901 Earhar Expressway         E—Mail:                        jdenton@petrocom.com


           Ciy:         Harmhan                        State:                         La
           Country:     USA                            Zipeode:                       70123        #
           Attention:   Mr Jon Denton




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2. Contact

             Name:        Russell . Fox                    Phone Number:                     ror—ase—7ass
             Companys     Minte,Levin, Cohn,Feris,         Fax Number:                       2n—424—7300
                          Glovsky and Popeo, RC.
             Street:      701 Pennsylvania Avenue, NW      E—Mail:                           RFox@mint.com
                          Suie 900
             City:        Washington DC                    State:                             pe
             Countrys     USA                              Zipeote:                          20004 —
             Attention:   Russel H. Fox                    Relationship:                      Legal Counsel

(1f your application is relted t an applcation filed with the Commission, nter ither the fle number or the 1B Submission Db ofthreated
application. Please enter only one)
 3. Reference File Number SESSTA2005121901772. or Submission ID
    4s. Is a fee submited      this application?
@ 1f¥es, completeand atach FCC Form 150. If No,indicatereason forfee exemption (see 47 ‘ERSection 11114).
@ Governmental Entity gy Noncommercial educational icensee
@ Othertplease explain;
(dFee Classifcation CGX— ined Sitelite TransmitiReceive Barth Station
5. Type Request
@ Use Priorto Grant                           g Chiange Sution Location                     g Oe

6. Requested Use Pror Date
      c22s2006


7. CiyEngleside                                                        8: Latode
                                                                       (Gimmsssh) 27. 51 2408 N
9. Sure TX                                                             10. Lonaitude
                                                                       (G@mmsssh) 19 12 20 W
11; Please supply any need atachments.
Atachment 1: Justieation                        Atachment 2: Waiver                            Atachment3:

12. Deserption. (Ifthe complete descrption does not appear in this box, please go to the end of the form to view t in ts entirety)
    sth to conduct testing prior to deploynent in the Gulf of Mexico and request for Waiver.




13. By checking Yes, the undersigned ceriies that nither aplicant nor any other partyto the applcation is             Yes        g No
subject ta denial f Federal beneft hatincludes FCC benefits pursuant to Section 5301 ofthe Anti—Drug Act
of 1988, 21 U.C. Section 862,because f a conviction for ssession or ditrbution ofa controlld substance.
See 47 CR 1.2002(0) for the meaningof &quotparty t theapplication@iquotfor these purposes

14. Name of Person Signing                                             15. Tite ofPerson Signing
   Jon Denton                                                             Engineering Manager
         WILLEUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE By FINE AND / OR IMPRISONMENT
                   (U.S. Code, Tike 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                    (US. Code, Tile 47, Section 312(a)(1), AND/OR FORFEITURE (U.8. Code, Ti 47, Secion 503).


ree Novice Requiten By THE PAPERWORK REDUCTION ACT
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bo Nor sexp conPLETED FoRMTo Ts Appess.
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TiE FOREGOING NOTICE Is REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCroBER
1, 199844 US.C. SECTION 3s07.


                                                                                Attachment 1
                                                               PetroCom License Corporation
                                   Application for Earth Station Special Temporary Authority
              JUSTIFICATION FOR SPECIAL TEMPORARY AUTHORITY
        PetroCom License Corporation (‘PetroCom"), pursuant to the provisions of Section
25120 ofthe rules and regulations ofthe Federal Communications Commission ("FCC" or
"Commission‘) hereby requests thatthe FCC grant it special temporary authority ("STA"), for a
period ofthirty (30) days, beginning on February 26, 2006, o operate the facilities associated
with the satelit earth station (the "Station") referenced in the associated application for testing
purposes only. PetroCom wl ulimately operate the Station from the Atlantis oil production
platform (the "Platform")in the Gulfof Mexico (the "Gulf") owned by BP Americas, Inc.
(BP). The Station willallow PetroCom to provide service to BP, so that BP may communicate
from the Platform to BP‘s headquarters in Houston, Texas. Itisanticipated that the Station will
be shipped to the Platform within thirty (30) days of grant of STA."" PetroCom has separately
obtained authority to operate the Station from the Platform on a permanent basis."" This STA
requestis identical t one intially granted by the Commission to testthe Station earlie last year
(‘June 2005 STA®)" Like the FCC‘s previous action approving temporary use of the Station,
PetroCom believes that grant of STA is appropriate in thisinstance. Attached to the June 2005
STA applicationis evidence of frequeney coordination for the shipyard and a radiation hazard
study for the antenna.

         PetroCom is mindful thatthe CC will likely only authorizetemporary opertions foa period of
thiry (30) days. Accordingly, upon expirtion ofthe STA requested her, PetroCom will equestfurther
STA untl such time as the Station s transported t the Gulf, As noted below, because te failtics
covered by the STA will not be permanenty locatedatthe site specified, it is more appropriat to seck
continued STA thatto obtai permanent icense fothe sation to operitat his location on a temporary
basis
#      See PetroCom License Corporation, PCC File No. SES—LIC—20050505—00538, Cal sign EOSO131
(granted June 13, 2008).
*       See PetroCom License Corporation, FCC File No. SES—STA—20050623—00809, Call sign
EOSO131 (granted June 27,2005)("June 2008 STA®). PetroCom requested and obtain further STA to test
these facltieswhen t became apparentthat the sation would not b trnsported to the Gulfduring the
time frume initally envisioned. See PetroCom License Corporation, FCC File No. SES—STA—20050722—
00929, Callsign EOSO131 (granted July 27, 2005); PetroCom License Corporation, FCC Fil No. SES—
$TA—20050823—01129, Call sign EOSO131 (granted August 26, 2005); PeteoCom License Corporation,
FCC File No. SES—8TA—20050920—01301, Call sign E050131 (granted September 22, 2005); PetroCom
Lisense Corporation, FCC File No. SES—STA—20081021—01454, Cal sign EOSO131 (granted October 26,
2003); PtroCom Liense Corporation, FCC File No. SES—STA—20051 118—01608,Callsign E0SO131
(granted November 29, 2005); PetroCom License Corportion, FCC File No. SES—STA—20081219—01772,
Call sign EOSO131 (granted December 29, 2005) As the Commission is aware, PetroCom‘s operations
have beendramatically affected by the devastation caused by Hurricanes Katrina and Rite. While
PetroCom reasonably expected that the equipment that is the subject o this STA request would have been
deployed in the Gul,and on the Atlants oil production plaform months ago, the effects of Hurricancs
Eatina and Rita have severely disrupted scheduling ofsctivites in the Gulf. Accordingly, PetroCom‘s
nesd for further STA was completely unforescen.


        As PetroCom explained in its request for the June 2005 STA, prior to shipping the Station
to the Platform and deploying the Station on the Platform, it is necessary for PetroCom to test the
Station atthe KOS shipyard in Engleside, Texas. By testing the Station before it is deployed in
the Gulf, PetroCom will be able to ensure is proper functioning prior to shipment. Once the
Station is shipped to the Platform it wll be the principal source of communications from the
Platform. Because the Station will be the primary means of communications on the Platform,
testing after the installation ofthe Station poses a risk to the safety and health of personnel
onboard as well as to the environment, in the event of an incident requiring intervention. With
testing verified atthe shipyard in Engleside, communications wll be available immediately once
the Station are installed. The need for adequatetesting before installation on the Platform has
become even more important i the wake of Hurricanes Katrina and Rita
        Accordingly,testing of the Stationatthe shipyard location is necessary before the Station
is transported to the Platforms in the Gulf. STA under these conditions is contemplated by
Section 25.120(a) ofthe FCC‘s rules, which states that STA may be requested for
"circumstances requiring..emporary use of facilites:"*"—It would be inefficient for the FCC to
process an application for permanent authorization for the Station at the shipyard faciliy,
because of the imited duration at which the Station will be located there.
        Accordinly, the FCC is requested to issue STA to PetroCom, effective February 26,
2006for a period of thirty (30) days, sothat it may test the Station on land before it is deployed
to the Platform in the Gulf. If there are any questions regarding this STA request,the ECC is
asked to contact communications counsel for PetroCom, Russell H. Fox of Mintz, Levin, Cohn,
Ferris, Glovsky and Popeo, P.C.,202—434—7483, rfox @mint.com




£      47 CR 525.1200)


                                                                                 Attachment 2
                                                                PetroCom License Corporation
                                    Application for Earth Station Special Temporary Authority

                                         Request for Waiver
        PettoCom License Corporation (‘PetroCom") hereby requests that the Federal
Communications Commission (‘FCC" or "Commission®) waive the provisions of Section 25.209
of the rules to permit it to operate an earth station antenna in the 4/6 GH: Band (the °C Band")
that does not comply with the antenna gain limitations specified in the FCC‘s rules. This waiver
requestis submitted in support of PetroCom‘s requestfor special temporary authority ("STA®)to
operate satelit earth station (the "Station")for testing at a temporary location. PetroCom has
already been granted permanent authority, including waiver ofthe rules covering the non—
compliant earth station antenna, forthe Station to operate on an oil platform in the Gulf of
Mexico. PetroCom has also been granted temporary authority on several instances to test the
antenna in June 2008 (‘June 2005 STA"). Technical materials supporting the already granted
waiver request were submitted with the application for permanent authority (*Permanent
Application‘) and are incorporated herein by reference.
       Petrocom attests to the fict that, as demonstrated by the atached Radiation Hazard
Report included in the June 2005 STA request, the safe limits for non—ionizing radiation
(Im/W/em?) will not be exceeded.
       Despitethfact thatthe main beam ofthe proposed earth station antenna does not
conform to the provisions of Section 25.209(a)and (b), the FCC should grant e requested
waiver and STA because PetroCom will not cause unacceptable levels ointerference under
conditions ofuniform two degree orbitalspacings. The antenna pattem ofthe Station exceeds
the gain specifications of Section 25.209 for th sidelobe envelope in the +1.0° to 1.9° region
by a maximum of 9.0 dB, at 6 GHz. Outside the main beam, the anterna meets the requirements
of Section 25.209 ofthe FCC‘s rules:

*        See PettoCom License Corporition, FCC File No. SES—LIC—20050505—00538, Call sign EOS0131
(granted June 13, 2008) (‘Permanent Application®). PetroCom incorporatesby reference the application
for the Atlsnis earth station and the related exhibts documentingthe technical parametrs that support a
walver request. The Commission previously grunted STA for teting ofthis Sation. See PetroCom
Lieense Corpontion, FCC File No. SES—STA—20050623—00809, Call sign E050131 (granted June 27,
2003)(June 2005 STA") see also PtroCom License Corporation, PCC File No. SES—$TA—20050722—
00929, Call sign EOSO131 (granted July 27, 2005PetroCom License Corporation, FCC File No. SES—
$7A—20050823.01129, Call sign EOSO131 (granted August26, 2005); PetroCom License Corporation,
FCC File No. SES—8TA—20050920—01301, Call ign EOSO131 (granted September 22, 2005); PeroCom
Lisense Corporation, FCC File No. SES—STA—20081021—01454, Cal sign EOSO131 (granted October 26,
2005) PetroCom License Comoration, FCC File No. SES—$TA—20081118—01604, Call sign EOSO131
(grinted November 29, 2005); PetroCom License Corporation, FCC File No. SES—STA—20081219—01772,
Call sign EOSO131 (granted December 29, 2005). The frequency coontination and radiation hazard sudy
are atached tothe June 2008 STA requestas Exhibits A and B


        However,the effects of non—compliance with the anterna gain requirements are
ameliorated by the reduction in power of the transmit antenna. ‘The provisions of Section 25.212
of the FCC‘s rulesspecify that the maximum RF power density normally licensed for smaller
diameter antennas, utilizing C—band data taffc,is—2.7 dBWA kitz.The Station is proposed to
operate with an RF transmit power density of—18. dBW/4 kltz. A comparison of the FCC‘s
maximum authorized RF transmit power density(2.7 dBW4 kHz) and the actual transmit
power density ofthe proposed earth station (—18.5 dBW4 kH), indicates thatthe applied—for
transmit power density is 15.8 dBW lower than the specified power restrictions. When the
antenna patterm envelopes are considered, the applied—for transmit power density is stll .8 dBW
less than the maximum RF power density normally licensed by the FCC
        To support PetroCom‘s caim that the operation t proposes will not cause adjacent
satelites exposure to greater EIRP densityfrom PetroCom‘s faciltes than those adjacent
satelites would experience from an antenna conforming to the gain pattems of Section 25.209(a)
and operating at the EIRP density limits specified in Section 25.212(c), Petrocom submitted an
Electrical Test Report prepared for the antenna manufacturer showing the gain pattems of the
antenna. To supplement this claim Petrocom also submitted a data table showing how the
proposed operation meets the Commission‘s off—axis criteria at various elevation angles.
         Finally, this reduced RF transmit power willresult in acceptable performance for the
antenna with respect to adjacent satelite nterference. PetroCom will operate with the AMC—3
satelite (87° W.L.. PetroCom has obtained consent to the use of these non—conforming
antennas from all affected parties, Affidavitsfrom PanAmSat and Loral atesting that they are
aware and acknowledge PettoCom proposed operation in the C Band and that they do not object
to that operation are attached to the Permanent Application. In any case, if the use ofthis
antenna should cause interference into other systems, PetroCom will terminate transmissions
immediately upon notice from the affected parties.
        The antenna is not compliant at two degrees for receive operations. PetroCom does not
believe, however, hatthis non—compliancewill unduly affect ts receive signal quality.
Moreover, PetroCom will accept any adjacent satellte interference in the receive band.
       Finally, PetroCom notes that previous licenses and STA requests have been granted to it
by the FCC for this size antenna. Accordingly, grant of the requested STA will be consistent
with past Commission practice.
       Should there be any questions regarding this waiver request, the FCC is sked to contact
communications counsel for PetroCom, Russell H. Fox of Mintz, Levin, Cohn, Feris, Glovsky
and Popeo, P.C., 202—434—7483, rfox@mintz.com




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Document Created: 2006-02-28 11:34:37
Document Modified: 2006-02-28 11:34:37

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