Attachment EXXON.pdf

EXXON.pdf

REQUEST submitted by EXXON COMMUNICATIONS COMPANY

Justification

2016-02-11

This document pretains to SES-STA-20160121-00079 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2016012100079_1126856

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


    In the Matter of
                                                )
Application of Exxon Communications
                                                )
Company for a Special Temporary                       File No:
                                                )
Authorization to Operate a Fixed Earth
                                                )
Station Terminal with Permitted List                  Call Sign: E000001
                                                )
Satellites in the 5.925-6.425 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, Exxon
Communications Company (“Exxon”) seeks a special temporary authorization (“STA”)
to operate its licensed Sea Tel Model 9797 C-band terminal on the Hoover Diana – a
stationary oil and gas rig located in the Gulf of Mexico (26° 56’ 20.8" N, 94° 41' 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 Exxon short-term operating authority during the
pendency of its concurrently filed modification application 1 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. Exxon seeks
an STA for a period of up to 60 days, commencing no later than January 20, 2016.




1
 See Application of Exxon Communications Company for Modification of Fixed Earth
Station License to Add Permitted List Authority (“Modification Application”).



                                                                                         1


I.           DISCUSSION
             Exxon 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. Exxon has previously coordinated the satellite arc range from 57° W.L. to 150°
W.L. and certifies that the remaining technical information in its earth station license and
associated application2 remains unchanged.
      The frequency coordination analysis that was previously conducted by Comsearch
demonstrates that Exxon may operate the Sea Tel 9797 earth station terminal from 57°
W.L. to 150° W.L. and will not cause harmful interference.                Comsearch sent a
coordination notice to existing licensees in the band within relevant coordination
distances and no objections were received from incumbent licensees.              Accordingly,
Exxon’s proposed operations are fully compatible with other FCC-licensed operations.
The requested modification will serve the public interest by enhancing Exxon’s satellite
communication capabilities on the Hoover Diana, thereby improving the critical services
provided to crew members for business and emergency operations.
      III.       EXPEDITED CONSIDERSATION
        Exxon 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,
Exxon seeks to commence operations on or after January 20, 2016.
             Pursuant to Section 25.120(b)(3), Exxon is filing for 60-day STA 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, Exxon has
concurrently filed a request to modify its license to add Permitted List authority.3
             Due to a change in satellite capacity, Exxon requires near-term use of Permitted
List satellites to accommodate the capacity adjustment and ensure there is no lapse in

2
    See File No. SES-MFS-20130228-00221 (Call Sign E000001).
3
    See Modification Application, IBFS No. IB2016000167 (filed 1/19/2016).


                                                                                            2


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 Exxon’s modification application.
       Grant of the requested authority will serve the public interest by allowing the
near-term use of the terminal on the Hoover Diana to communicate with Permitted List
satellites, which will greatly benefit employees and personnel and accelerate the
expansion of C-band satellite communications services. Accordingly, Exxon 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, Exxon 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 Hoover Diana no later than January 20, 2016.




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Document Created: 2016-02-19 13:50:23
Document Modified: 2016-02-19 13:50:23

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