Attachment Cover Letter

This document pretains to SES-STA-20130517-00397 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2013051700397_997476

                                                          May 17, 2013
System Analysis Branch
Satellite Division
International Bureau
Federal Communications Commission
445 12th Street SW
Washington, DC 20554

         Re:       Request for Special Temporary Authority, Shell Communications, Inc.

   Pursuant to Section 25.120(b) of the Rules and Regulations (“Regulations”) of the Federal
Communications Commission (“Commission”), Shell Communications, Inc. (“Shell”) seeks
Special Temporary Authority (“STA”) to test a fixed C-band antenna at a shipyard in Ingleside,
Texas prior to installation at a Gulf of Mexico permanent site.1

     According to Section 25.120(a) of the Regulations, “In circumstances requiring immediate or
temporary use of facilities, request may be made for special temporary authority to install and/or
operate new or modified equipment….” 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 this case, Shell plans to perform Factory Acceptance Testing of a Seatel 9797 antenna
prior to installing it a Gulf of Mexico permanent site. It is of paramount importance that the
antenna as issue be thoroughly tested to minimize down time once the antenna is installed in a
Gulf of Mexico platform. The testing is a circumstance requiring temporary operations. Sound
performance of the antenna is in the public interest as satellite communications to Gulf of Mexico
platforms are considered life line links to platform personnel. Delay of this testing would injure
the public interest.

        Pursuant to Section 25.120(b)(4) of the Regulations, the Commission may grant
temporary authorization for a period not to exceed 30 days, if the STA request has not been
placed on public notice, and an application for regular authority is not contemplated. In this case,
because this is a factory acceptance testing operation, Shell does not plan to file an application for
permanent authority. However, temporary frequency coordination has been performed prior to
this STA request and it is attached to the underlying application. The planned satellite is Satmex-
6 (113.0 degrees West).

    The requested date for prior use is May 24, 2013. 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.



1
 Shell Communications, Inc. has already obtained a license for the permanent site in the Gulf of Mexico. See Call sign
E120179, filename SES-LIC-20120830-00791. The test site at Ingleside, Texas, the subject of this STA request, will
have the same transmit characteristics as the permanent site.



Document Created: 2013-05-17 15:15:25
Document Modified: 2013-05-17 15:15:25

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