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Saipem America, Inc.

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Released: May 13, 2013
Federal Communications Commission
Washington, D.C. 20554
May 13, 2013

DA 13-1076

Mr. Mauro Piasere
Saipem America, Inc.
15950 Park Row
Houston, TX 770844
Call Sign: E130029
File No.: SES-LIC-20130213-00168
Dear Mr. Piasere:
On February 8, 2013, Saipem America Inc., (Saipem) filed the above-captioned
application for a fixed earth station license, involving a 2.4-meter antenna located on an
oil platform in the Gulf of Mexico, which would operate with the Intelsat 903 space
station at the 34.5° W.L. orbital location on center frequencies 3825.0 MHz (space-to-
Earth) and 6050.0 MHz (Earth-to-Space). Pursuant to Section 25.112(a)(1) of the
Commission’s rules, 47 C.F.R. § 25.112(a)(1), we dismiss the application as defective,
without prejudice to re-filing.1
Section 25.112(a) of the Commission’s rules requires the Commission to return, as
unacceptable for filing, any application that is not substantially complete, that contains
internal inconsistencies, or that does not substantially comply with the Commission’s
rules2. For the reasons set forth below, we find the application of Saipem unacceptable
for filing:
· Saipem did not provide a Radiation Hazard Study, as required by item 28 of FCC
Form 312.
· Saipem did not provide transmit and receive antenna gain values, as required by
items E41 and E42 of Schedule B.
· Saipem did not provide an Emission Designator, as required by item E47 of
Schedule B.

If Saipem re-files an application in which the deficiencies identified in this letter have been corrected but
otherwise identical to the one dismissed, it need not pay an application fee. See 47 C.F.R. § 1.1111(d).
47 C.F.R. § 25.112(a).

Federal Communications Commission DA 13-1076

Saipem indicated in item E48 of Schedule B that its Maximum EIRP per Carrier
will be 60.0 dBW. We note that is inconsistent with a Total EIRP for all carriers
of 12.3 dBW that Saipem indicates in item E40 of Schedule B. In addition, the
maximum EIRP specified by Saipem exceeds the value coordinated and reported
in the Comsearch coordination report filed in support of Saipem’s application.
Saipem did not provide, as required in items E61 through E68 of Schedule B, a
point of contact within the United States that is available 24 hours a day, 7 days a
week, that has the ability to shut off its earth station immediately upon
notification of harmful interference pursuant to Section 25.271 of the
Commission’s rules.3
Although not grounds for dismissal, Saipem states in item E15 of Schedule B that the
2.4-meter antenna’s gain pattern is compliant with Section 25.209 (a) and (b), as
demonstrated by the manufacturer's qualification measurement. Pursuant to Section
25.111(a) of the Commission’s rules, we request that, as part of any re-filing, Saipem
demonstrate compliance with Sections 25.209(a) and (b) and Section 25.132 of the
Commission’s rules.4 If Saipem cannot demonstrate compliance with Sections 25.209(a)
and (b), then Saipem must either submit the certifications listed in Section
25.220(d)(1)(i-iv) of the Commission’s rules, or Saipem may cite the particular
application file number and call sign of a license in which that type of non-routine
antenna has been previously approved, pursuant to the procedures set forth in the Part 25
Earth Station Fifth Report and Order.5 Please note that the Commission maintains a list
of approved non-routine antennas at .
Accordingly, pursuant to Section 25.112(a)(1) of the Commission’s rules, 47 C.F.R.
§ 25.112(a)(1), and Section 0.261 of the Commission’s rules on delegations of authority,
47 C.F.R. § 0.261, we dismiss the application, without prejudice to re-filing.
Paul E. Blais
Chief, Systems Analysis Branch
Satellite Division
International Bureau

3 47 C.F.R. § 25.27.
4 47 C.F.R. § 25.111(a); 47 C.F.R. §§25.209(a) and (b); and 47 C.F.R. § 25.132.
5 47 C.F.R. §§ 25.220(d)(1)(i-iv).

Federal Communications Commission DA 13-1076


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