Attachment Narrative Statement

This document pretains to SES-STA-20160112-00035 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2016011200035_1121625

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) Application of Harris CapRock Corporation ) for a Special Temporary Authorization to File No: ) Operate a Fixed Earth Station Terminal with ) Permitted List Satellites in the 5.925-6.425 Call Sign: E030159 ) GHz (Earth-to-space) and 3.7-4.2 GHz ) (space-to-Earth) Frequency Bands ) Application for Special Temporary Authorization Pursuant to Section 25.120 of the Rules and Regulations of the Federal Communications Commission (the “Commission Rules”), 47 C.F.R. § 25.120, Harris CapRock Corporation (“Harris CapRock”) seeks a special temporary authorization (“STA”) to operate its licensed Sea Tel Model 9797 C-band terminal on the Gunnison Spar – an offshore oil platform located in the Gulf of Mexico (27° 18’ 19.0" N, 93° 32' 20.0" W) – while communicating with satellites on the Commission’s Permitted Space Station List (“Permitted List”). Presently under the license, the terminal is authorized to communicate with certain satellite points of communication in the C-band. The requested STA will afford Harris CapRock short-term operating authority during the pendency of its concurrently filed modification application1 to add Permitted List authority. Grant of the requested STA is essential to ensure that there is no lapse in essential satellite-based services to the oil platform in the context of an upcoming change in serving satellite capacity scheduled for late January/early February 2016. Harris CapRock seeks an STA for a period of up to 60 days, commencing no later than January 20, 2016. 1 See Application of Harris CapRock Communications, Inc. for Modification of Fixed Earth Station License to Add Permitted List Authority, Call Sign E030159 (“Modification Application”). 1

I. DISCUSSION Harris CapRock requests authority to operate the earth station terminal with U.S. licensed satellite and non-U.S. licensed satellites on the Commission’s Permitted Space Station List. Accordingly, Harris CapRock also seeks to widen the range of satellite arc currently in the license to 60° W.L. to 143° W.L., which will slightly modify the maximum EIRP towards the horizon value, as well as the azimuth and elevation angles, as indicated in the modification application. Harris CapRock certifies that the remaining technical information in its earth station license and associated application2 remains unchanged. A frequency coordination analysis was conducted by Comsearch and demonstrates that Harris CapRock may operate the Sea Tel 9797 earth station terminal over the proposed arc range without causing harmful interference. Comsearch sent a coordination notice to existing licensees in the band within the relevant coordination distances and no objections were received from incumbent licensees. Accordingly, Harris CapRock’s proposed operations are fully compatible with other FCC-licensed operations.3 The requested STA will serve the public interest by enhancing Harris CapRock‘s satellite communication capabilities on the Gunnison Spar in the near-term, thereby improving the critical services its provides to crew members for business and emergency operations. III. EXPEDITED CONSIDERSATION Harris CapRock respectfully requests expedited processing of this STA request under Section 25.120. Section 25.120(a) provides that STA requests should be filed at least three working days prior to the date of commencement of the proposed operations. Here, Harris CapRock seeks to commence operations on or after January 20, 2016. Pursuant to Section 25.120(b)(3), Harris CapRock is filing for 60-day STA to 2 See File No. SES-MOD-20130111-00040 (Call Sign E030159). 3 Please note that potentially affected licenses may respond to Comsearch by January 19, 2016, but Comsearch’s analysis suggests that there will be no impact to such licensees by the operations proposed herein. To the extent that a potentially affected licensee contacts Comsearch regarding the proposed operations, Harris CapRock will inform the Commission and adjust its operations accordingly to address the concerns of the relevant licensees. 2

ensure proper short-term authorizations during the pendency of its earth station modification application. Section 25.120(b)(3) provides that the Commission may grant STA for a period not to exceed 60 days if it has not placed the STA request on public notice and the applicant plans to file a request for regular authority for the service. Here, Harris CapRock has concurrently filed a request to modify its license to add Permitted List authority.4 Due to a change in satellite capacity, Harris CapRock requires near-term use of Permitted List satellites to accommodate the capacity adjustment and ensure there is no lapse in vital satellite communication services. Given the near-term commencement of the proposed operations and that they have been fully coordinated, expedited processing of this STA request is warranted and will ensure properly authorized temporary operations while the Commission reviews Harris CapRock’s modification application. Grant of the requested authority will serve the public interest by allowing the near-term use of the terminal on the Gunnison Spar to communicate with Permitted List satellites, which will greatly benefit employees and personnel and accelerate the expansion of C-band satellite communications services. Accordingly, Harris CapRock respectfully submits that the public interest will be served by grant of the requested STA no later than January 20, 2016. IV. CONCLUSION In view of the foregoing, Harris CapRock respectfully requests that the Commission grant its 60-day STA request to allow the Sea Tel 9797 terminal to communicate with satellites on the Permitted List in the C-band on the Gunnison Spar no later than January 20, 2016. 4 See Modification Application. 3


Document Created: 0570-04-08 00:00:00
Document Modified: 0570-04-08 00:00:00
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