Attachment STA Justification

This document pretains to SES-STA-20190801-01018 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2019080101018_1822881

                                      Marlink, Inc.

                     Request for Special Temporary Authority to
  Operate 5 Winegard Model WX 1200 1.2 Meter Temporary Fixed VSAT Antennas to
               Communicate With Intelsat 23 and Galaxy 19 Satellites

           Marlink, Inc. (“Marlink”) respectfully requests a grant of Special Temporary
Authority (“STA”) effective August 11, 2019 to operate 5 Winegard Model WX 1200
(“WX 1200”) 1.2 Meter Ku-band temporary fixed VSAT antennas to communicate with
the U.S. licensed Intelsat 23 and Galaxy 19 satellites for a demonstration and testing
project. The purpose of the project is to evaluate performance of Marlink’s network in
the monitoring of crude oil extraction points in desolate areas.

         The antennas will be operated in CONUS in an area of West Texas bounded by
103.32W to the west, 100.32W to the east, 33.50N to the north and 30.12N to the south.
The antennas will be operated by remote control via the Marlink Network Operations
Center (MNOC) located in Eik, Norway which will control the remote antennas via
uplink teleports located in the U.S. The MNOC operation of antennas located in the U.S.
is in turn controlled by Marlink’s U.S. FCC Point of Contact which has a business
address of 3327 S. Sam Houston Parkway East, Suite 100, Houston, Texas, 77047 and is
available 24 hours a day, seven days a week via 203-346-0461 which is the U.S. number
for the MNOC.

        The Technical Specifications published by Winegard for the WX 1200 antenna
state that radiation pattern compliance is with FCC Part 25.209. No frequency
coordination or coordination with another country is required for the operation of these
antennas as they will only be transmitting within the U.S. on standard Ku-band
frequencies. FAA notification is not required as the antennas will be located in areas
with structures of equal or greater heights. A Radiation Hazard Report is included as an
exhibit with the STA application.

       As noted above, the Points of Communication for which authorization is
requested are the U.S. licensed Intelsat 23 and Galaxy 19 satellites. The Transmit and
Receive Gains for the WX 1200 antenna are 43 dBi @ 14.125 GHz and 41.5 dBi @
11.950 GHz respectively. The STA is requested to operate the antennas utilizing a total
input power to the antenna flange of 5.4 watts with a total EIRP for all carriers of 50.8
dBW. Authorization is requested to utilize the following Emission Designators -

Frequency     Polarization Emission       Tx/Rx       Max           Max
  (MHz)                                               EIRP          EIRP
                                                      /Carrier      Density
                                                      (dBW)         (dBW/4kHz)
11700-12000       H&V         565KG7W        R
14000-14500       H&V         565KG7W        T        49.97         29.15

Modulation & Services - DIGITAL TRAFFIC USING QPSK MODULATION


       Grant of the STA is in the public interest because as noted above the antennas will
be operated for the purpose of evaluating the performance of Marlink’s network in the
monitoring of crude oil extraction points in desolate areas. Crude oil extraction is an
important element in meeting the nation’s energy needs. It is therefore respectfully
requested that STA as described above be granted for a period of 30 days, effective
August 11, 2019.

      Any questions with respect to this matter may be directed to David Atabala at
281-809-9708 or James G. Lovelace at 571-599-3643.



Document Created: 2019-08-01 22:07:00
Document Modified: 2019-08-01 22:07:00

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