Attachment STA Narrative

This document pretains to SES-STA-20160112-00047 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2016011200047_1121324

                                      Before the
                       FEDERAL COMMUNICATIONS COMMISSION
                                Washington, D.C. 20554


    In the Matter of
                                                )
Application of Shell Communications, Inc.
                                                )
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: E060229
                                                )
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, Shell
Communications, Inc. (“Shell Communications”) seeks a special temporary authorization
(“STA”) to operate its licensed Andrew 243 C-band terminal on the Amelia HP – an
offshore oil platform located in the Gulf of Mexico (29° 40' 54.3" N, 91° 5' 51.1" 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 Shell Communications 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. Shell Communications seeks an STA for a period of up to 60 days, commencing
no later than January 20, 2016.




1
 See Application of Shell Communications, Inc. for Modification of Fixed Earth Station
License to Add Permitted List Authority, Call Sign E060229 (“Modification
Application”).



                                                                                       1


I.           DISCUSSION
             Shell Communications 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, Shell Communications also seeks to expand the range
of satellite arc currently in the license to 60° W.L. to 143° W.L., which will slightly
modify the maximum EIRP spectral density towards the horizon value, as well as the
azimuth and elevation angles, as indicated in the attached modification application. Shell
Communications 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 Shell Communications may operate the Andrew 243 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 have been received from incumbent licensees.
Accordingly, Shell Communications’ proposed operations are fully compatible with other
FCC-licensed operations.3 The requested STA will serve the public interest by enhancing
Shell Communications’ satellite communication capabilities on the Amelia HP in the
near-term, thereby improving the critical services its provides to crew members for
business and emergency operations.
      III.      EXPEDITED CONSIDERSATION
        Shell Communications 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, Shell Communications seeks to commence operations on or after
January 20, 2016.
             Pursuant to Section 25.120(b)(3), Shell Communications is filing for 60-day STA

2
    See File No. SES-MFS-20081209-01574 (Call Sign E060229).
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, Shell will inform the Commission and
adjust its operations accordingly to address the concerns of the relevant licensees.


                                                                                             2


to 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,
Shell Communications has concurrently filed a request to modify its license to add
Permitted List authority.4
            Due to a change in satellite capacity, Shell Communications 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 Shell Communications’
modification application.
            Grant of the requested authority will serve the public interest by allowing the
near-term use of the terminal on the Amelia HP to communicate with Permitted List
satellites, which will greatly benefit employees and personnel and accelerate the
expansion of C-band satellite communications services.                 Accordingly, Shell
Communications 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, Shell Communications respectfully requests that the
Commission grant its 60-day STA request to allow the Andrew 243 terminal to
communicate with satellites on the Permitted List in the C-band on the Amelia HP no
later than January 20, 2016.




4
    See Modification Application.


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Document Created: 2016-01-11 19:00:03
Document Modified: 2016-01-11 19:00:03

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