**DA 06-774**

March 31, 2006

Mr. Alfred Mamlet

Steptoe & Johnson LLP

1330 Connecticut Ave NW

Washington, D.C. 20036-1795

Call Sign: E050292

File No.: SES-LIC-20051018-01424

File No.: SES-STA-20051115-01578

Dear Mr. Mamlet:

On October 18, 2005, Stratos Offshore Services Company (Stratos) filed
the above-captioned application seeking a license to operate a network
of Ku-Band earth stations on board vessels (ESV) through a previously
licensed 6-meter fixed earth station[^1] in Scott, Louisiana. Pursuant
to Section 25.112(a)(1) of the Commission's rules, 47 C.F.R. §
25.112(a)(1), we dismiss the application and the associated request for
special temporary authority (STA) as defective.

Specifically, for Stratos's proposed one-meter ESV antennas (Remote
Types #1 and #4), Stratos lists the proposed Maximum EIRP per Carrier
(item E48) as 45.8 dBW for emission designator (item E47) 400KG7D. This
value is greater than, and therefore inconsistent with, the Total EIRP
for All Carriers (item E40), which Stratos indicates is 43.5 dBW.
Similarly, for the 2.4 meter ESV antennas (Remote Type #3), Stratos
lists the proposed Maximum EIRP per Carrier (item E48) as 52.2 dBW for
the following emission designators (item E47): 4M90G7D, 2M80G7D,
2M40G7D, 1M40G7D and 200KG7D. This is greater than the Total EIRP for
All Carriers (item E40) which Stratos indicates is 48.6 dBW. Given these
inconsistencies, we cannot determine the proposed emission power. As a
result, the application is defective, and is therefore dismissed.

While we dismiss the application on the above basis, we take the
opportunity to apprise you of other concerns we have should Stratos
choose to re-file the application.

First, in Items E57 and E59 of the Schedule B of the application,
Stratos lists the minimum antenna elevation angle as 0 degree. Section
25.205 of the Commission's rules, however, states that earth station
antennas shall not be authorized for transmission at an angle that is
less than 5 degrees measured from the horizontal plane to the direction
of the maximum radiation.

Second, Stratos indicates that its proposed 1.0 meter and 1.2 meter
antennas meet the off-axis EIRP density limits contained in Sections
25.222(a)(1) through (4) of the Commission's rules, 47 C.F.R. §
25.222(a)(1) through (4). Stratos appears to base this assertion on the
assumption that the antennas also comply with the antenna radiation
performance standards contained in Section 25.209 of the Commission's
rules, 47 C.F.R. § 25.209. The technical showings supplied in other
applications for licenses for the same SeaTel 1.0 and 1.2 meter antennas
as Stratos proposes to utilize, indicate that the antennas do not
satisfy Section 25.209's antenna radiation performance standards between
1.25 and 1.5 degrees. Consequently, Stratos must include, in any
refiling, a demonstration of its off-axis EIRP density levels beginning
at 1.25 degrees off-axis with 0.1 degree increments out to 2.25 degrees
off-axis. The demonstration should include a comparison of the
authorized off-axis EIRP density limits specified in Section
25.222(a)(1)-(4) of the Commission's rules.

Finally, in Attachment C of the application, Stratos states that "...the
antenna controller can detect within 100 milliseconds a pointing error
that exceeds 0.5 degrees and cease transmissions immediately...".
Stratos must clarify in any refiling whether the antenna controller can
automatically detect and cease transmissions within 100 milliseconds of
a pointing error that exceeds 0.5 degrees, in conformance with Section
25.222(a)(7) of the Commission's rules, 47 C.F.R. § 25.222(a)(7).

Accordingly, pursuant to Section 25.112(a)(1)[^2] 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 both
applications as defective without prejudice to refiling.

Sincerely,

Scott A. Kotler

Chief, Systems Analysis Branch

Satellite Division

International Bureau

[^1]: Call Sign E980235

[^2]: 47 C.F.R. § 25.112(a)(1). See *also* Echostar Satellite LLC,
    *Order on Reconsideration,* DA 04-4056 (released December 27, 2004).