Attachment Extension grant

This document pretains to SES-STA-20071120-01605 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2007112001605_606897

                                  E070119                        SES—STA—20071120—01605     182007002785
                                  PetroCom License Corporation



                                                                                                                                  Approved by OMB
                                                                                                                                         3060—0678

                            APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY



APPLICANT INFORMATIONEnter a description of this application to identify it on the main menu:
STA to test earth station prior to deployment in Gulf of Mexico
 1. Applicant


           Name:        PetroCom License Corporation                          Phone Number:                504—736—9400
           DBA Name:                                                          Fax Number:                  504—734—6100
           Street:      5901 Earhart Expressway                               E—Mail:                      kwright@petrocom.com



           City:        Harahan                                              State:                        LA

           Country:     USA                                                  Zipcode:                      70123      —
           Attention:   Mr Kenneth Wright
                                    nhrmrtosrenarmnemmimece sn


     2. Contact


                  Name:          Russell Fox                        Phone Number:                        202.434.7483

                  Company:       Mintz, Levi, Cohn, Ferris, Glovsky Fax Number:                          202.434.7400
                                 and Popeo, PC.
                  Street:       701 Pennsylvania Ave., NW           E—Mail:                              rfox@mintz.com
                                Suite 900
                  City:         Washington                          State:                               DC
                  Country:      USA                                 Zipcode:                             20004     —

                  Attention:    Russell Fox                         Relationship:                        Legal Counsel


     (Ifyour application is related to an application filed with the Commission, enter cither the file numberor the IB Submission ID of the related
     application. Please enter only one.)
      3. Reference File Number SESLIC2007062200852 or Submission ID
      4a. Is a fee submitted with this application?
     @ If Yes, complete and attach FCC Form 159.        If No, indicate reason for fee exemption (see 47 C.ER.Section 1.1114).
     C Governmental Entity         £4 Noncommercial educational licensee
     C Other(please explain):

     4b. Fee Classification    CGX — Fixed Satellite Transmit/Receive Earth Station

     5. Type Request


     0 Use Priorto Grant                               C Change Station Location                       @ Other



     6. Requested Use Prior Date
            11/23/2007
Do


7. CityIngleside                                                           8. Latitude
                                                                           (dd mmss.sh)      27    52     5.0    N

9. State   TX                                                               10. Longitude
                                                                           (dd mmss.sh)      97    10     24.0   W

11. Please supply any need attachments.
Aitachment 1:                                     Attachment 2:                                      Attachment 3:


12. Description.   (If the complete description does not appearin this box, please go to the end of the form to view it in its entirety.)
    STA for testing antenna onshore prior to deployment in the Gulf of Mexico.




13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is              Yes        C No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 ofthe Anti—Drug Act
of 1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance.
See 47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes.


14. Name ofPerson Signing                                                   15. Title of Person Signing
  Jon Denton                                                                  Engineering Manager

           WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                  (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                      (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Seetion 503).


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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.


                                                                                    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 25.120 of
the rules and regulations of the Federal Communications Commission ("FCC" or "Commission")
hereby requests that the FCC grantit special temporary authority ("STA"), for a period ofthirty
(30) days, beginning on November 23, 2007, to operate the facilities associated with the satellite
earthstation (the "Station") described in the attached technical description, fortesting purposes
only. PetroCom will ultimately operate the Station from the Tahiti oil production platform (the
"Platform") in the Gulf of Mexico (the "Gulf") owned by Chevron. The Station will allow
PetroCom to provide service to Chevron. The Station will permit Chevron to communicate from
the Platform to Chevron personnel on shore. It is anticipated that the Station will be shipped to
the Platform within sixty (60) days of grant of STA. PetroCom has received authority to operate
the Station on a permanent basis from the Platform." The FCC previously issued STA to
PetroCom covering the interim operation of this station for testing pumoscs but testing is not yet
complete and the Station is not yet ready to be shipped to the Platform."

As the FCC has recognized by granting PetroCom STA fortesting purposes undersimilar
conditions, pum to shipping the Station to the Platform and deploying the Station on the
Platform, it is necessary for PetroCom to test the Station at a shipyard in Ingleside, Texas."" By
testing the Station beforeit is deployed in the Gulf, PetroCom will be able to ensure its proper
functioning prior to shipment. Once the Station is shipped to the Platform it will be the principal
source of communications from the Platform. Because the Station will be the primary means of
communications on the Platform, testing afterthe installation of the Station poses a risk to the
safety and health of personnel onboard as well as to the environment, in the event ofan incident
requiring intervention. With testing verified at the shipyard in Ingleside, communications will be
available immediately once the Station is installed.

Accordingly, testing of the Stationat the shipyard location is necessary before the Stationis
transported to the Platformin the Gulf. STA under these conditions is contemplated by Section


¥       See PetroComLicense Corporation, FCC File No. SES—LIC—20070622—00852, Callsign EO70119
(granted July 31, 2007).
x      See PetroComLicense Corporation, FCC File No. SES—STA—20071022—01447 (granted October
23, 2007); PetroCom License Corporation, FCC File No. SES—STA—20070921—01307 (granted September
25, 2007); PetroCom License Corporation, FCC File No. SES—STA—20070823—01118 (granted August 27,
2007); PetroCom License Corporation, FCC File No. SES—STA—20070724—00981 (granted July 26, 2007);
PetroComLicense Corporation, FCC File No. SES—STA—20070626—00871 (granted June 27, 2007);
PetroCom License Corporation, FCC File No. SES—STA—20070524—00719 (granted May 25, 2007);
PetroCom License Corporation, FCC File No. SES—STA—20070424—00513 (granted April 27, 2007).
x      See, e.g., 1d.; PetroCom License Corporation, FCC File No. SES—STA—20050623—00809, Callsign
E050131 (granted June 27, 2005); PetroCom License Corporation, FCC File No. SES—STA—20041123—
01729, Callsign E040444 (granted December 7, 2004).


25.120(a) of the FCC‘s rules, which states that STA may be requested for "cireumstances
requiring...temporary use of facilities." It would be inefficient for the FCC to process an
application for permanent authorization for the Station at the shipyard facility, because of the
limited duration at which the Station will be located there.

Accordingly, the FCC is requested to issue STA to PetroCom, effective November 23, 2007, for
a period of thirty (30) days, so that 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 FCC 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@mintz.com.


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


                                       Request for Waiver

PetroCom License Corporation ("PetroCom") hereby requests that the Federal Communications
Commission ("FCC" or "Commission") waive the provisions of Section 25.209 to permit it to
operate an earth station antenna in the 4/6 GHz Band (the "C Band") that does not comply with
the antenna gain limitations specified in the FCC‘s rules. This waiver request is submitted in
support of PetroCom‘s request for special temporary authority ("STA") to test a satellite earth
station (the "Station") at a location other than where it will be permanently installed. PetroCom
has obtained permanent authorization for the Station, which included a separate request for
waiver of the rules in connection with that application."" Attached to this wavier request are the
following exhibits:

       Exhibit A — Frequency Coordination for Testing
       Exhibit B — Radiation Hazard Study
       Exhibit C — Schedule B, Technical and Operational Description of Earth Station During
       Testing
        Exhibit D — Electrical Test Report for SeaTel 2.4 m Antenna
        Exhibit E — Data Tables
        Exhibit F — Affidavits from Adjacent Satellite Operators

PetroCom attests to the fact that, as demonstrated by the attached Radiation Hazard Report
(Exhibit B), the safe limits for non—ionizing radiation (1m/W/em*) will not be exceeded.

Despite the fact that the main beammof the proposed earthstation antenna does not conformto the
provisions of Section 25.209(a) and (b), the FCC should grant the requested waiver and STA
because PetroCom will not cause unacceptable levels of interference under conditions of uniform
2 degree orbital spacings. The antenna pattern of the Station exceeds the gain specifications of
Section 25.209 forthe 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 antenna meets the requirements of Section 25.209 of the
FCC‘s rules.

However, the effects of non—compliance with the antenna gain requirements are ameliorated by
the reduction in power ofthe transmit antenna. The provisions of Section 25.212 of the FCC‘s
rules specify that the maximum RF power density normally licensed for smaller diameter
antennas, utilizing C—band data traffic, is —2.7 dBW/4 kHz. The Station is proposed to operate
with an RF transmit power density of ~34.96 dBW/4 kHz. A comparison of the FCC‘s
maximum authorized RF transmit power density (—2.7 dBW/4 kHz) and the actualtransmit
power density of the proposed earth station (—34.96 dBW/4 kHz), indicates that the applied—for
transmit power density is 32.76 dBW lower than the specified powerrestrictions. Whenthe

V       See PetroCom License Corporation, FCC File No. SES—LIC—20070622—00852, Callsign EO70119
(granted July 31, 2007).


antenna pattern envelopes are considered, the applied—fortransmit power density is still 23.76
dBW less than the maximum RF powerdensity normally licensed by the FCC.

To support Petrocom‘s claim that the operationit proposes will not cause adjacent satellites
exposure to greater EIRP density from PetroCom‘s facilities than those adjacent satellites would
experience from an antenna conforming to the gain patterns of Section 25.209(a) and operating
at the EIRP density limits specified in Section 25.212(c), Petrocom submits an Electrical Test
Report prepared for the antenna manufacturer showing the gain patterns of the antenna. To
supplement this claim Petrocomis also submitting a data table showing how the proposed
operation meets the Commission‘s off—axis criteria at various elevation angles.

This reduced RF transmit power will result in acceptable performance for the antenna with
respect to adjacent satellite interference. PetroCom will operate with the AMC—3 satellite (87
degrees W.L.). PetroCom has obtained consent to the use of these non—conforming antennas
fromall affected parties. Affidavits from PanAmSat and Loral attesting that they are aware and
acknowledge Petrocom‘s proposed operation in the C Band and that they do not object to that
operation are attached hereto. 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.

Finally, PetroCom notes that previous licenses and STAs have been granted to it by the FCC for
  »   &            —     +         :      —    2        :
this size antenna, including for this Station."‘ Accordingly, grant of the requested STA and the
forthcoming underlying application will be consistent with past Commission practice.

Should there be any questions regarding this waiver request, the FCC 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@mintz.com.




*      See, ecg., PetroCom License Corporation, FCC File No. SES—STA—20071022—01447 (granted
October 23, 2007); PetroCom License Corporation, FCC File No. SES—STA—20070921—01307 (granted
September25, 2007); PetroCom License Corporation, FCC File No. SES—STA—20070823—01118 (granted
August 27, 2007); PetroCom License Corporation, FCC File No. SES—STA—20070724—00981 (granted
July 26, 2007); PetroCom License Corporation, FCC File No. SES—STA—20070626—00871 (granted June
27, 2007); PetroCom License Corporation, FCC File No. SES—STA—20070524—00719 (granted May 25,
2007); PetroCom License Corporation, FCC File No. SES—STA—20070424—00513 (granted April 27,
2007); PetroCom License Corporation, FCC File No. SES—STA—20050623—00809, Callsign E050131
(granted June 27, 2005); PetroCom License Corporation, FCC File No. SES—STA—20041123—01729,
Callsign E040444 (granted December 7, 2004); PetroCom License Corporation, FCC File No. SES—LIC—
20050505—00538, Callsign E050131 (granted June 13, 2005); PetroCom License Corporation, FCC File
No. SES—STA—20041122—01722, Callsign E040444 (granted January 26, 2005).



Document Created: 2007-11-26 11:02:25
Document Modified: 2007-11-26 11:02:25

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