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Sure Shot Transmissions, Inc.

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Released: January 25, 2013
Federal Communications Commission
Washington, D.C. 20554


DA 13-104

January 25, 2013
Ms. Carolyn Blasko
Sure Shot Transmissions, Inc.
P.O. Box 489
10314 Main Street
New Middletown, OH 44442-0489
Call Sign: E940167
File No.: SES-MOD-20120912-00810
SES-AMD-20130104-00004
Dear Ms. Blasko:
On September 12, 2012, Sure Shot Transmissions, Inc. (Sure Shot) filed the above-captioned
applications to modify its current license for a Temporary-Fixed earth station. For the reasons
explained below, we dismiss the application without prejudice to refiling.1
Section 25.112(a) of the Commission’s rules requires the Commission to return, as unacceptable
for filing, any earth station application that is not substantially complete, contains internal
inconsistencies, or does not substantially comply with the Commission’s rules.2 Sure Shot’s
application does not comply with the Commission’s rules, which renders it unacceptable and
subject to dismissal.
The amendment to Sure Shot’s modification application, SES-AMD-20130104-00004,
incorrectly calculates power levels. Sure Shot lists, in Schedule B of the amendment, for
emission designator 36M0F9W (E47), the maximum effective isotropic radiated power (EIRP) as
78.0 dBW (E48) and the maximum EIRP density per carrier as 46.01 dBW/4kHz (E49). Based
on a total input power at the antenna flange of 400 W (E38) and a transmit antenna gain of 45.5
dBi (E41), our calculations indicate that the maximum EIRP of emission designator 36M0F9W
should be 71.52 dBW, and the maximum EIRP density per carrier should be 31.98 dBW/4kHz.
In addition, although Sure Shot’s current authorization for a 3.7-meter antenna includes ALSAT
authority, Sure Shot must comply with current rules and policies when replacing the antenna.
Current rules and policies stipulate that earth stations may be granted ALSAT as a point of


1 If Sure Shot Transmission, Inc. refiles an application identical to the portion dismissed, with the
exception of supplying the corrected information, it need not pay an application fee. See 47 C.F.R. §
1.1111(d).
2 47 C.F.R. § 25.112(a).

Federal Communications Commission DA 13-104

communication only in cases where the earth station is eligible for routine processing.3 Routine
processing under Sections 25.212(c) and 25.211 (d)(2) of the Commission’s rules for earth
stations in the 14.0-14.5 GHz frequency band requires that the maximum input power density into
the antenna be no greater than -14.0 dBW/4kHz for narrowband analog transmissions,
narrowband and wideband digital transmissions, and video transmissions, and that the maximum
input power into the antenna be no greater than 27 dBW for analog video transmissions.4 The
antenna input power and transmit EIRP values in Sure Shot’s application exceeds these
values.
Furthermore, when the input power density level exceeds -14.0 dBW/4kHz, Section
25.211(f) of the Commission’s rules requires applicants to comply with the procedures set forth
in Section 25.220.5 Those procedures require a demonstration that the earth station complies with
the off-axis EIRP density envelopes specified in Section 25.218(d). Applicants must demonstrate
such compliance by submitting tables, as defined in Section 25.115(h)(1-4), that show the off-axis
EIRP.6 Sure Shot’s application does not comply with the routine licensing rules for ALSAT
authority and fails to provide the off-axis-EIRP tables necessary to demonstrate compliance with
Section 25.220.
Accordingly, pursuant to Section 25.112(a)(1) and Section 0.261 of the Commission’s rules on
delegation of authority, 47 C.F.R. § 25.112(a)(1) and 47 C.F.R. § 0.261, we dismiss Sure Shot’s
applications without prejudice to refiling.
Although not a grounds for dismissal, we also note that Sure Shot did not list modulation and
services descriptions in Schedule B (E50) for the emission designator 36M0F9W. Sure Shot
must provide such information, if it chooses to refile.
Sincerely,
Paul Blais
Chief, Systems Analysis Branch
Satellite Division
International Bureau


3 See Amendment of the Commission’s Regulatory Policies to Allow Non-U.S. Licensed Space Stations to
Provide Domestic and International Services in the United States, IB Docket No. 96-111, First Order on
Reconsideration, 15 FCC Rcd 7207 (1999), at 7213 ¶13 (stating that licenses for “routine” earth stations
providing fixed-satellite service in the conventional C-band Ku-band may specify “ALSAT” as authorized
points of communication, and noting that a “routine” earth station is one that operates consistently with the
technical requirements of Part 25).
4
47 C.F.R. § 25.212(c) and 47 C.F.R. § 25.211(d)(2)
5 47 C.F.R.§ 25.220 and 47 C.F.R. § 25.211(f)
6
47 C.F.R. § 25.218(d), 47 C.F.R. § 25.115(h)(1-4), 47 C.F.R.§ 25.220.
2

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