Attachment Exhibit A

This document pretains to SES-STA-20140129-00063 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2014012900063_1033717

                                                                                   RigNet SatCom, Inc.
                                                               Request for Special Temporary Authority
                                                                                             Exhibit A

          EXHIBIT A – REQUEST FOR SPECIAL TEMPORARY AUTHORITY

        RigNet SatCom Inc. (“RigNet”), pursuant to Section 25.120 of the Commission’s Rules,
47 C.F.R. § 25.120, hereby requests Special Temporary Authority (“STA”) for short-term
transmit and receive operations of a Seatel 9797 Earth Station on Vessel (“ESV”) terminal
operating in the conventional C-band1 on the Chevron Jack St. Malo (“Malo Terminal”), a U.S.-
flagged offshore platform involved in drilling and petroleum production. Although the Malo
Terminal is located more than 200 km from the baseline of the United States, frequency
coordination has been completed to ensure that any offshore U.S.-licensed fixed microwave
installations within a 200 km radius of the ESV terminal’s location will not be affected. STA is
sought for a period of 60 days beginning on February 1, 2014.2

        Stratos Offshore Services Company (“Stratos”) previously obtained STA to operate the
Malo Terminal on November 26, 2013 for a period of 30 days,3 and the Commission later
extended this authority through February 9, 2014.4 Given that the Malo Terminal is part of
Stratos’ retail energy business, which RigNet intends to purchase along with certain other
assets,5 and because RigNet intends to close on the aforementioned transaction after having
obtained FCC approval for the assignment of the permanent licenses that enable the operation of
these assets, 6 separate and independent authority is required for RigNet to assume responsibility
for the operation of the Malo Terminal.

       The proposed Malo Terminal ESV operations comply with all of the relevant technical
parameters and showings required by Section 25.221 of the Commission’s Rules, and there is a
pending application to modify Call Sign E980235 to enable the permanent operation of the
above-referenced Seatel C-Band ESV antenna.7 In addition, the Malo Terminal has been
successfully coordinated with potentially affected terrestrial fixed service providers.8

        STA is required because the Chevron Jack St. Malo deepwater drilling and production
platform is a newly constructed vessel which has only recently been towed to its current location
in international waters in the Gulf of Mexico, and Ku-band ESV service was deemed inadequate
for the telemetry, control and tracking (“TT&C”) and data communications needs of the newly

1
    3700-4200 MHz space-to-earth and 5925-6425 MHz earth-to-space.
2
    An application is on file to modify Call Sign E980235 to enable the permanent operation of the Malo
    Terminal. See International Bureau File No. SES-MOD-20131112-00965 (“Modification Application”).
3
    See International Bureau File No. SES-STA-20131112-00966.
4
    See International Bureau File No. SES-STA-20131216-01198.
5
    See International Bureau File No. SES-ASG-20130815-00737 (“RigNet Assignment Application”)
6
    The International Bureau approved the RigNet Assignment Application on January 28, 2014.
7
    The proposed STA operations will conform to the technical parameters provided in the pending modification
    application. See Modification Application.
8
    See Exhibit B.


                                                Page 1 of 2


                                                                             RigNet SatCom, Inc.
                                                         Request for Special Temporary Authority
                                                                                       Exhibit A

launched and untested vessel. Specifically, Chevron and satellite engineers assigned to the
project determined that Ku-band communications, which are susceptible to rain fade attenuation
in the tropical conditions present in the deep waters of the Gulf of Mexico region, do not provide
a sufficient level of reliability for the TT&C and data communications needs of the vessel at its
isolated deployment location. In contrast, C-band communications, which are generally not
susceptible to rain fade attenuation and other atmospheric anomalies, offer greater reliability in
the harsh environment where the new platform is deployed. Given that TT&C and data
communications are critical for the safety of personnel living on the platform and for reliable
equipment control and environmental monitoring, STA is warranted and in the public interest in
this case.

        Because the proposed STA operations conform to the parameters in Section 25.221 for
routine ESV operations and have been fully coordinated, any adjacent operations will be fully
protected. Nevertheless, RigNet will make available a 24/7 point of contact in the event that any
issues arise in connection with the operations under the requested STA. Personnel will be on
duty at all times during the STA period and can be contacted at (888) 974-4638.




                                           Page 2 of 2



Document Created: 2014-01-29 10:35:31
Document Modified: 2014-01-29 10:35:31

© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC