Attachment Cover Letter

This document pretains to SES-STA-20120703-00630 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2012070300630_958753

                                          July 3, 2012
System Analysis Branch
Satellite Division
International Bureau
Federal Communications Commission
445 12th Street SW
Washington, DC 20554

        Re:      Request for Special           Temporary       Authority     –    Harris    CapRock
                 Communications, Inc.

    Pursuant to Section 25.120(b) of the Rules and Regulations (“Regulations”) of the
Federal     Communications     Commission      (“Commission”),    Harris    CapRock
Communications Inc. (“HARRIS CAPROCK”) seeks Commission consideration to
renew a Special Temporary Authority (“STA”) to operate Earth Stations on Vessels
(“ESVs”) while an application for permanent authority is being reviewed. On May 9,
2012, HARRIS CAPROCK filed an application to modify its existing ESV license to
include the Intellian V60 and V801 antennas (File No. SES-MOD-20120509-00427,
callsign E060157). On June 2, 2012, HARRIS CAPROCK filed an STA application and
was granted for a 30 day period as file SES_STA-20120602-00488. The existing STA
expires on July 7, 2012.

    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.”

    HARRIS CAPROCK is a global provider of fully managed communications solutions
for remote and harsh environments. The proposed application would authorize HARRIS
CAPROCK to operate ESVs on vessels that routinely perform new construction and
maintenance of subsea facilities in the Gulf of Mexico. The communication links at issue
will carry video images of subsea structures as well as their construction and
maintenance. The proper supervision of subsea operations is paramount to the prevention
of construction disasters as well as the safety of personnel engaged in such endeavors.
This is an extraordinary circumstance that requires temporary operations in the public
interest. The delay in the institution of these temporary operations would seriously
prejudice the public interest.



1
 Intellian V60 is a Ku-band 60cm diam. stabilized antenna. The Intellian V80 is a Ku-band 80cm diam.
Stabilized antenna. Both operate with a radome.


    The analysis in the principal application has shown that the Intellian V60 and
Intellian V80 antennas conform to the spectral density envelopes outlined in Section
25.222 of the Regulations when limited to -22.30 dB/4KHz and -20.13 dB/4KHz
respectively, at the feed. Harris CapRock will operate within these limits. Furthermore,
Intellian has certified that the antennas comply with the 100ms automatic shut-off for an
off-axis deviation of more than 0.5 degrees from the target satellite.2 The analysis in the
application has also shown that radiation levels at the proposed terminals will be within
the exposure limits of 47 CFR §1.1310

    Pursuant to Section 25.120(b)(3) of the Regulations, the Commission may grant
temporary authorization for a period not to exceed 60 days, if the STA has not been
placed on public notice, and the applicant plans to file a request for regular authority for
the service. In the instance case, the Commission has not placed the STA application on
public notice. Furthermore, HARRIS CAPROCK has filed an application for permanent
authority. HARRIS CAPROCK is asking the Commission to grant it STA beginning Ju
7, 2012. The planned satellites are G25 (93W) and Telstar 14 (63W).




                                       Sincerely,

                                       /s/ Raul Magallanes

                                       Raul Magallanes
                                       Counsel to Harris CapRock Communications, Inc.




2
    47 C.F.R. §25.222(a)(1)(iii)(A).



Document Created: 2012-07-03 19:16:09
Document Modified: 2012-07-03 19:16:09

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