Subject: [NEXTEL-1] CHEVRON USA, Requests Wavier To Run Wideband Data (50 kHz and D emissions) On UHF.

From: Marcel <[email-masked]>
Date: Tue, 25 Mar 2003 15:34:50 -0500

CHEVRON USA, Requests Wavier To Run Wideband Data (50 kHz and D emissions) On UHF.
---------------------------------------------------
DA 03-859
Released:  March 25, 2003

WIRELESS TELECOMMUNICATIONS BUREAU SEEKS COMMENT ON REQUEST FOR WAIVER BY CHEVRON USA,
INC. TO ALLOW TEMPORARY FIXED, WIDEBAND, DIGITAL OPERATION IN THE GULF AREA

Comment Date:  April 24, 2003    Reply Comment Date:  May 9, 2003
On December 23, 2002, Chevron USA, Inc. (“Chevron”) filed an application and request for
waiver for temporary fixed operation of four frequency pairs in the 490-491 and 493-494
MHz bands, at locations in the Gulf of Mexico and along the adjacent Mississippi and
Louisiana shorelines, with a bandwidth of 50 kHz and D1  emissions.   Chevron states that
grant of the requested waiver will be consistent with the Commission’s policies and
practices and will promote the public interest.  We seek comment on Chevron’s request.

The maximum bandwidth permitted under our rules for 470-512 MHz channels is 25 kHz.
Further, our rules do not permit D1 emissions in the Southern Louisiana-Texas Offshore
Zone.   Chevron contends that D1 emission and 50 kHz bandwidth are necessary for
satisfactory data and voice communications to each drill rig and lift boat in a single
radio link.  Chevron has determined that a smaller bandwidth will not provide the required
bit rate of 128 kbps.  Consequently, Chevron is also requesting a waiver of the equipment
certification requirement, where the proposed equipment is not certified under Part 90 for
use with 50 kHz channels;  and the emission mask requirement, which applies to 25 kHz
channels and is too stringent for 50 kHz channels.   In addition, Chevron seeks a waiver
of the minimum distances between shore or offshore stations and TV stations, 241 km (150
mi) for co-channel  and 128 km (80 mi) for adjacent channel,  set forth in our rules.
Chevron’s proposed operations would approach points located 117.8 miles from co-channel TV
station W17CG on TV Channel 17, and 51.5 miles from adjacent Channel TV station KLTL-TV on
TV Channel 18.  To compensate, Chevron proposes to operate at a reduced power of no more
than 2 watts ERP, which is well below the smallest listed power of 35 watts corresponding
to a distance of 241 km (150 mi) in the co-channel distance table.   Chevron submitted an
engineering statement that illustrates interference protection to the Grade B contours of
both TV stations.

Using the first prong of the waiver standard of Section 1.925(b)(3),  Chevron argues that
grant of the requested waiver will not undermine the fundamental purpose served by five of
the six rules in question, and that the grant would be in the public interest.  With
respect to Section 90.173(m), Chevron states that use of a single 50 kHz channel pair at
each location is a more spectrally efficient approach than the use of multiple, smaller
bandwidth channels.  Chevron cites that its low transmitter power of 1 watt is unlikely to
substantially limit potential spectrum use by other, future applicants.  Chevron also
argues that the purposes of Section 90.210(c) are not thwarted, since the measured
emissions of the proposed equipment are below the required emissions at and beyond the
channel edge.  With respect to the emission designator rule of Section 90.315(c), which
ensures that operations in a particular band are compatible and unlikely to result in
interference, Chevron states that advances in technology alleviate or eliminate concerns
that may have been present at the time the rule was adopted.  With respect to the distance
requirements of Sections 90.315(d) and 90.315(g), Chevron notes that its interference
protection to the respective Grade B contours in excess of the 65 dB standard illustrates
that a waiver would not undermine the purpose of these rules.  Chevron argues that a grant
of its waiver request would be in the public interest because the proposed radio system
serves important safety and environmental functions, such as oil spill prevention and
detection.

Under the second prong of the waiver standard of Section 1.925(b)(3), Chevron seeks a
waiver of the Section 90.203(a) certification requirement because it has no reasonable
alternative.  Chevron seeks to use MDS LEDR equipment, which has been certified under Part
74 with 25 kHz and 50 kHz channels and under Part 90 with 25 kHz channels.  However,
Chevron has been unable to identify any existing equipment that is certified for use under
Part 90 with 50 kHz channels, presumably because such channels are not available for use
under Part 90.

Interested parties may file comments on Chevron’s Waiver Request on or before April 24,
2003. Parties interested in submitting reply comments must do so on or before May 9,
2003.  All comments should reference Chevron’s Waiver Request, including the DA number of
this Public Notice, and should be filed with the Office of the Secretary, Federal
Communications Commission, 445 12th Street, S.W., Room TW-325, Washington, D.C. 20554.  A
copy of each filing should be sent to:  (1) Qualex International, Inc., Portals II, 445
12th Street, S.W., Room CY-B402, Washington, D.C. 20554, (202) 863-2893; (2) Tom Eng,
Federal Communications Commission, Wireless Telecommunications Bureau, Public Safety and
Private Wireless Division, Policy and Rules Branch, 445 12th Street, S.W., Room 4-B512,
Washington, D.C. 20554; and (3) Maria Ringold, Federal Communications Commission, Consumer
and Governmental Affairs Bureau, Reference Information Center, 445 12th Street, S.W., Room
CY-B529, Washington, D.C. 20554.

Chevron’s application and Waiver Request can be accessed electronically via the
Commission’s Universal Licensing System, http://wireless.fcc.gov/uls.  In addition, the
full text of the Waiver Request, comments and reply comments will be available for
inspection and duplications during regular business hours in the Reference Information
Center (RIC) of the Consumer and Governmental Affairs Bureau, Federal Communications
Commission, 445 12th Street, S.W., Room CY-A257, Washington, D.C. 20554.  Copies may also
be purchased from the Commission’s duplicating contractor, Qualex International, Portals
II, 445 12th Street, S.W., Room CY-B402, Washington, D.C. 20554, (202) 863-2893, facsimile
(202) 863-2898, or via-e-mail [email-masked]. For further information regarding the
public reference file for this Request, contact Maria Ringold, Chief, Wireless Branch,
RIC, (202) 418-1355.

Unless otherwise provided, requests for waiver of the Commission's Rules are subject to
treatment by the Commission as restricted proceedings for ex parte purposes under Section
1.1208 of the Commission's Rules, 47 C.F.R. § 1.1208.  Because of the policy implications
and potential impact of this proceeding on persons not parties to the waiver request, we
believe it would be in the public interest to treat this case as a permit-but-disclose
proceeding under the ex parte rules, See 47 C.F.R. §§ 1.1200(a), 1.1206.  Therefore,
subsequent to the release of this Public Notice, ex parte presentations that are made with
respect to the issues involved in the subject Waiver Request will be allowed but must be
disclosed in accordance with the requirements of Section 1.1206(b) of the Commission's
Rules, 47 C.F.R. § 1.1206(b).

For further information, contact Mr. Tom Eng, of the Policy and Rules Branch of the Public
Safety and Private Wireless Division of the Wireless Telecommunications Bureau at (202)
418-0019, TTY (202) 418-7233, or via e-mail to [email-masked].

By the Chief, Public Safety and Private Wireless Division, Wireless Telecommunications
Bureau.

-FCC-

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-03-859A1.doc
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