Attachment STA grant

This document pretains to SES-STA-20090304-00235 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2009030400235_704192

                                                       SES—STA—20090304—00235     182009000581
                                         PetroCom License Corporation



                                                                                                                    Approved by OMB
                                                                                                                          3060—0678

                            APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY



APPLICANT INFORMATIONEnter a description ofthis application to identify it on the main menu:
Application for STA for SP70C
 1. Applicant

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


           City:        Harahan                            State:                                LA
           Country:     USA                                Zipcode:                              70123      —
           Attention:   Jon Denton




                                                                       SEesSstA—20090204—002357
                                                                                _____ Graat Date 3 t&tfi { 7



                                                                                    *".sfazlo9


2. Contact


             Name:          Raul Magallanes                     Phone Number:                       2813171397
             Company:      The Law Office of Raul               Fax Number:                         2812718085
                            Magallanes, PLLC

             Street:        PO Box 1213                         E—Mail:                             info@rmtelecomlaw.com


             City:         Houston                              State:                               TX
             Country:      USA                                 Zipcode:                             77549      —
             Attention:    Raul Magallanes                     Relationship:                         Legal Counsel


(If your applicationis related to an application filed with the Commission, enter either the file number or the 1B Submission ID of the related
application. Please enter only one.)
 3. Reference File Number or Submission ID
 4a. Is a fee submitted with this application?
& !IfYes, complete and attach FCC Form 159.         If No, indicate reason for fee exemption(see 47 C.F.R.Section 1.1114).
3 Governmental Entity        ¢*4 Noncommercial educational licensee
O Other(please explain}:

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

5. Type Request

@ Use Prior to Grant                              C Change Station Location                        <3 Other


6. Requested Use Prior Date
      03/09/2009


7. CityGulf of Mexico                                                      8. Latitude
                                                                           (dd mmss.sh)      29    1    47.64    N
9. State   LA                                                              10. Longitude
                                                                           (dd mmss.s h)     88   56     32.78   W
11. Please supply any need attachments.
Attachment 1: Cover Letter                        Attachment 2: Interf. Analysis                       Attachment 3: Non Compliant


12. Description.   (If the complete description does not appear in this box, please go to the end ofthe form to view it in its entirety.)
    Application for STA for SP70C




13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is              Yes        £y No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the 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 &quot;party to the application&gquot; for these purposes.


14. Name of Person Signing                                                 15. Title ofPerson Signing
  Jon Denton                                                                  Director of Technology
           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, Section 503).


FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT

The public reporting for this collection of information is estimated to average 2 hours per response, including the time for reviewing instructions,
searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection ofinformation. If you
have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the
Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept
your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to jboley@fec.gov. PLEASE
DO NOT SEND COMPLETED FORMS TO THIS ADDRESS.

Remember — You are not required to respond to a collection ofinformation sponsored by the Federal government, and the government may not
conduct or sponsorthis collection, unless it displays a currently valid OMB control numberor if we fail to provide you with this notice. This
collection has been assigned an OMB control number of 3060—0678.

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


            ))) Tecscommunicarions Law

                        The Law Office of
                        Raul Magallanes                                           www rimtelecomiaw.com


                                                      March 4, 2009
Scott Kotler, Chief
System Analysis Branch
Satellite Division
International Bureau
Federal Communications Commission
445 12" Street SW
Washington, DC 20554

         Re:       Request for Special Temporary Authority

Dear Mr. Kotler,

    Pursuant to Section 25.120(a) of the Rules and Regulations ("Regulations") of the Federal
Communications Commission ("Commission"), Petrocom License Corporation. ("Petrocom‘") seeks
Commission consideration for a Special Temporary Authority ("STA") to operate a new earthstation.

    According to Section 25.120(b)(3) of the Regulations, the Commission may grant temporary authority
for a period not to exceed 60 days, if the STA request has not been placed on public notice, and the
applicant plans to file a request for regular authority for the service. In the instant case, the STA request
has not been placed on public notice and Petrocom plans to file an application for regular authority.
Therefore, Petrocom respectfully requests an STA for a period not to exceed 60 days.

    According to Section 25.120 (b)(1) of the Regulations, "The Commission may grant a temporary
authorization only upon a finding that there are extraordinary circumstances requiring temporary operations
in the public interest and that delay in the institution of these temporary operations would seriously
prejudice the public interest".

     In the instant case, Petrocom operates a GSM cellular network in the Gulf of Mexico. Various cell
towers are backhauled from Gulf of Mexico fixed platforms to inland interconnection points through
satellite links, Because of damage caused by Hurricanes Ike, some of this cellular infrastructure was
damaged requiring upgrade or replacement. The planned satellite is AMC3 (87W).

     Petrocom‘s GSM cellular network is the only licensed cellular service in the Gulf of Mexico and is
used extensively by crew members of the various oil exploration and production platforms. Some cell sites
are being switched from Ku to C—band to improve reliability while others are being deployed as new sites.

     In order to insure restoration of this damaged site and uninterrupted service, the requested date for
prior use is March 9. 2009. In accordance to Section 25.120(a) of the Regulations, this STA is being filed
at least 3 working days prior to the date of proposed operation.

    Because of the nature of operations in this platform and the critical role of the existing earth station
communications link, it is in the public interest that the proposed earth station be operational to
accommodate the critical calls that are placed by platform personnel. In addition, should there be an
emergency in this platform; this earth station would be used to place calls to communicate with the
appropriate agencies.

                                                      Sincerely,

                                                      /s/ Raul Magallanes
                                                      Attorney


                                                          Petrocom License Corporation




                               Non—Compliant Statement

According to Section 25.212(c)(2) of the Rules and Regulations of the Federal
Communications Commission (Regulations"), in the 5925—6425 MHz band, earth
stations with an equivalent diameter of equal to or greater than 4.5m may be routinely
licensed if the maximum power density into the antenna does not exceed —2.7dBW/MAKHz
for digital SCPC carriers. Furthermore, antennas with an equivalent diameter of less than
4.5m are subject to the provisions of Section 25.220 of the Regulations.

The antenna at issue is a C—band Prodelin 1251(2.4m) ("Antenna"). This Antenna is less
than 4.5m in diameter. The Antenna does not strictly comply with Section 25.209 of the
Regulations. However, pursuant to Section 25.220 (b—c) of the Regulations, an applicant
may request the Commission to consider a non—compliant antenna if it can be shown that
the operational power density will be below the requirement of Section 25.212(c)(2).
Specifically, the earth station operator must provide the power and power density levels
that result by reducing the values stated in Section 25.212(c)(2) by the number of
decibels that the non—compliant antenna fails to meet the standards of Section 25.209 of
the Regulations.

In this case, the proposed Antenna exceeds the patterns of Section 25.209 by
approximately 12dB in the +(140° to 180°) region along the azimuth axis. The Antenna
is designed to operate with a maximum EIRP density into the antenna flange of —21
dBW/A4KHz.     This is 18.3 dB below the —2.74BW/A4KHz limit.              Applying the
methodology in Section 25.220 (b—c), the maximum EIRP density at Antenna flange is
increased by 12dB to yield,

                         —21 dBW/AKHz + 12 dB =—9 dBW/AMAKHz.

As calculated, this figure is still below the allowed maximum EIRP density at the
Antenna flange of —2.7 dBW/AKHz by 6.3 dB.

The applicant agrees to accept any adjacent satellite interference in the 3700—4200 MHz
receive band as a result of the performance of the Antenna. Should the use of this
Antenna cause interference to other systems; the applicant agrees to terminate
transmission upon notice from the Commission.

Appendix A shows a spectral density showing for this Antenna at low, mid, and high
band. The antenna gain varies slightly with frequency and so does the spectral density.



Document Created: 2009-03-24 14:18:11
Document Modified: 2009-03-24 14:18:11

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