Exhibit A to Aloha Networks Experimental License STA

0327-EX-ST-2001 Text Documents

Aloha Networks, Inc.

2001-09-10ELS_48493

             EXHIBIT A

   FCC FORM 442 AND SUPPORTING
    DOCUMENTATION FOR ALOHA
NETWORKS, INC.‘S REQUEST FOR SPECIAL
      TEMPORARY AUTHORITY


                                                                                 FOR
Azproved by OMB              EEDERAL COMMUNICATIONS CoMMISSION                   ree
    30sO—0065                                                                     UsE
I:<pires ©/30/08                   FCC FORM 442                                  onLy

                APPLICATION FOR NEW OR MODIFIED RADJO STATION AUTHORIZATION UNDER PART i6
                      OF FCC RULES — EXPERIMENTAL RADIO SERVICE (OTHER THAN BROADCAST)

[BeeTt} on                  _}
    APPLICANT NAME (Lest, first, middle Initial)
          Aloha Networks,          Inc.
    MAILING ADDRESS (Line i) (Maximum 86 characters — refer to Instruction (2) on reverse of form)
     P.0. Box_ 29472
    MAILING ADDRESS (Line 2 (If required) (Maxzimum 05 characters)


    CiTy
     San Francisco                                                 .                                          .
    STATE OR COUNTRY GF foreign address)                          2IP CODE                CALL SIGN OR FILE NUMBER
     California                                                   94129—0472
Enter in Colmn (A) the correct Fee Type Code for the service you sre appying for. Fee Typs Codes may be found in FCC
 Fee Filing Guides. Emter in Cotumn (B) the Fee Multiple, if applicable. Enter in Colmn (C) the result obtained from mutipying
 the value of the Foe Type Code in Colmn (A) by the number entered in Column (B), if any.
                {A)                            (B)                             (C)
                                          FEE MULTIPLE                FEE DUE FOR FEE TVPE
           FEE TYPE CODE                   tif required)               COdE N COLUMN (ta;
    (2
           &E     a    OE                                            #


    s8ECT IONn                |    «——    To be used onlky when you are requesting concurent actions which result in a
R                                         requirement to list more than one Fes Type Code.


                (A)                            (B)                             (C)
           FEE TYPE CODE                 FEE MULTIPLE                FEE DUKE FOR FEE TYPE
                                          tif required)               CODE IN COLUMN (A)



    {2)                                                               %


    (3)                                                               A

    (4)                                                               s

    (5)                                                               *
    ADD ALL AMOUNTS SHOWN IN COLUMN C, LINES (17)                                  ‘
    THROUGH f6), AND ENTER THE TOTAL HERE.                               % AMOLNT E&H,fi'fi
    THIs AMOUNT SHOULD EQUAL YOUR ENCLOSED                                              JCarin
    REMITTANCE.
                                                              >      &

"tris form has been authoriged for reproduction.                                                                   FCC Form422
                                                                                                                     March 1998


           ®EDERAL COMMUNICATIONS COMMISSION                                                                                           APPROVED 8¥ Gms
           ‘washington, DC 20554                                                                                                          308B0—0085
                                                                                                                                       Expres 9/30/28

                       APPLICATION FOR NEW OR MODIFIED RADIO STATION AUTHORIZATION UNDER PART 6
                           OF FCC RULES — EXPERIMENTAL RADIO SERYVICE (OTHER THAN BROADCAST)


           L      Applicant‘s Name and Post Office address                                                Do NOT WRITE IN THIS BLOCK
                  (Street addrass, city, siate, and ZIP Code. See mmouon                 File No
                  No. 4)


                    Aloha Networks, Inc.
                    P.0. Box 29472
                    Ssan Francisco, CA 94129%—0472


           Tla). Application for (check only one box)                                   Kb). For Modification indicate below:

                X) New station         [L] ModiHfication of existing authcrization
                                                                          File No:                        Call Sign:
           E. Application for Modification: Check the box beside all particulars to be modified. Check either additionr or re—
                plasement to indicate whether the change is an addition or a replacement of parsmeters in the current authorization

       C]rreouerey —                             O enssion —                           D rower —                           Giocation —
               [7] addrion o []] repincement?        J addition or [[]J repiacement?     [7] edaition or (7] repmosmentt       [[] addrtion or [2] repticemenrt?


       [] OEA PARTICULARS — addkion or replcement? ©escribe below or in sttached EMHIBIT No.                                     4



           4
                 Frequency istate                                                                                  MODLLATING          NECESSARY BANDWIDTH
               ahether 6Mz or MiHt}                                                                                  SIGNaAt                    0¢iz)


14000—145
14000—145
14000—14
14000—14
14000—14
14000—14



           (h) List each frequency or frequency band separately. (If more spase is required, aitach as EXHIBIT No.      rwwne
           (E} Insert meximum RF. cutput power al the transmitier ierminals Specify units
           (() iInsert meximum effective radiated power from the antenna (If pulssd emission. specify peak power). Specify
                    units.
           (D)      Insert "MEAN® or "PEBAK® (See definitions in Part D.
           (B)       List each type of emission separstely for saoh frequency. (See Section 2201 of FCC Rules)
           (F)      iInsert as appropriate for the type of modulation:
                    () the maximum speed of keying in beud«
                    (2) meaximum sudio modulating frequency;
                    (8) frequency deviation of carrier
                    (4) pulse duration and repetition rate.
               For complex emissions desoribe in detail in the speos provided below.
           t!) Describe how the necesssry bandwidth war determined in spaose provided below,                                    FCC Form 442 — Page 2
                                                                                                                                                March 1696


6i. Proposed locetion of transmitter and transmitting antenna (oheck only one box to indicate type of opomfi:n):
    Q mxBD/BasE                     L momus                       [] PaAsS AWD MOBILE
613. If         permanently located at          PIXPD locetion,    give below:              Wo). IP moblie, describe the exact aree of
Stite             County                 —_|      City or Town                                   operation
  Number and street (or other indioation of lecation)


 5:D)(1). Enter geographical coordiantes exact to the nesrest mecond (as instruction 10)    ¥CXUEnter geographice: coordrates of the approximate
 Ao‘th lattude CD—MM—$8                        West Lengitude CO—~MM—85%

          ° conus                 >                       *conus                                                                               ~
 54). Datum (see instruction 10) ..................                  0 xapa                 KAD 80
 €. is a directional antenna (other than radar) used* R) yrs                           C xo
        If "YES, give the following information:
        (a) Width of beam in degreesat the half—power point_See                     Exhibit        _A
        (b) Orientation in horizontai plane                                      to) Orientation in vertioe! plane
_\J'




        is this authorization to be used for fulfilling the requirement of a government contract with an agency of the
        United Siates Government"                          D TBs               NO
        If "YES", atiach as EXHIBIT No.                           & narrative Siatement desoribing the government projeot,
        agency and sentact number.                                    —
 £. Is this authorirstion to be used for the exciusive purpose of developing radio equipment for export to be ersployed
    by stations under the jurlsdiotion of a forseign government?
                                                                     O se              G xo
        If "YES", attach as EXHIRIT No                            the following information: Provide the centract nun‘b-r and the
        namse of the foreign government concerned.

£. is this authorization to be used for providing communications esmential to a ressearch project? (The radio communi—
   gation is not the objective of the research                       @
                                                          TBS             NO
   If "YES®, attach as EXHIBIT No                 a narrative Fiatement provding the following information:
   (a) A description of the nature of the research project being conr 10ted.
   (b) A showing that the communications faocllities requested are necessary for the research project invoived.
   to) A showing that existing communicvations fecilities are insdequate

17. If all the answers to Items 7, 8 and 9 are "NO‘, atiach as EXHIEIT No. o+ mo_———__—.. 8 BDAFTAUVE Statement drecribing
        in detail the fellowing
        (a) The complete prcgnm of research and experimeniation proposed including description of equipment
            and theory of operation.
        (b) The specific objectives sought to be accomplished.
        (o) How the program of sxperimeniation has a reasonable promime of contribution to the development extension,
            expansion, or utllization of the radio art, or is along line not already in vestigated.
lh) Give an estimate of the length of time that will be required to complets the program or experimentation {proposed
          in this application: _____
       (b) If less than 2 years, give the length of Ume in months that the authorization requested in this application
           will be required:
1i.        Would a Commission grant of this application come within Section 11807 of the PCC Rules such that it may have a
          significant environmental impant (see instruction i}?         D es             m o                         .
          If "TPS", attach as EXHIAIT No                              an Environmenial Asmmesment as required by Section ueu

IE.       List below tranrmitting equipment to be installed (if oxwuxonm. so statek
          MANLFACTURER                                                                UMBSER                                     NO. OF UNiTs


           CHANNEL MASTER                                                   See Exhibit A



                                                                                                                      FCC Form 442 — Page
                                                                                                                                 March 1996


«.    is the equipment listed in Item i8 capable of station identification pursuant to Seotion 6iS2! D                     TES      D     NO

4&    Will the antenna extend more than 6 melers above the ground, or if mounted on en existing bullding, wil} i; extend
      more than 6 meters above the bullding, or will the proposed antenna be mounted on an existing structure other
      than a building?                          .    D 1Bs          D wo
      If "YES*, give the following (see Instruction 0)
      {a) Overall height above ground to tip of antenns is                              meters.
      (b) Hlevation of ground at antenna site above mean see level is                              melara
      (o) Distance to neerest aircreft landing area is                                                                   kilometers.
      (d) List any natural formations of existing man—mede structures (hills, trees, water tanks, towers eto) which, in
          the cpinion of the applicant would tend to shield the antenna from alroraft and thereby minimize the
          meronautioal hazard of the antenna.




      (e) Submit as EXHIBIT No.        munucc—.«_.... 8 vertical profile sketch of total structure including s#upporting bullding.
          If any, giving heights in meters above ground for aill significant features Clearly indicate existing portion,
          noting partioulars of aviation obstruotion lighting miready available.
13.    Applicant lz     (/Cheekt enly ane bea?

      J momviouar               L association                      O rartxErsur                   CORPORATION

      [L] OoTHER (Gdesoribe in space provided below)




17.   Is tpplluni a forelign government or a representative of a foreign government?                                 D    TES       fl     NO

55.   Haz applicant or any party to this application had any PCC riation Hoense or permit revoked or had any
      applioation for permit, loense or rensewal denied by this Commission?                                          D    Es        fl     xo
      If "YES", atteoh is EXHIBIT No.                             a statement giving cell sign of lHoense or permit
      revoked and relate circumstances.

is.    Will applioant be owner and operutor of the station?                                                          O y            O xo
D.    Give neme, title and telephone number (include arese oode), and Internet e—mail address (if applicable) of person
      who can best handle inquirles pertaining to this application.



iD.   APPLICANT ANTI—DRU® ABUSE CERTFICATION:
      By checking "YES", the individual applicant certifies that he or she is eligible for this loense. This requires that
      he or she is not subject to s denial of federal benefites, Including FCC benefits, as a result of a drug offense
      conviction pursuant to Section 6601 of the Anti— Drug Abuse Act of 1088, 21 ULC. 882 A non— individual applicant.
      ag. oorporation, partnership or other uninoorporated association, certifies that no party to the application is
      subject to a denial of federal benefits, pursuant to that seotion. For definition of a "party" for these purposer,
      see 47 CFR 129002(b).                                                                             D zs        D xo

i2    List below all exhibits in num'r}a.l sequenoe and the item number of form requiring the exhibit identified.

  BonBiTt NUMBER      1TTM NO. Of FOMM           posst?   MdBIA                                   DO#B!! dAMEIR             IYIM NO. DF FOMA




            F
            G      Experimental Program Description                                                               FCC Form 442 — Page 4.
                                                                                                                                 March 1996


it3   CERTFICATION:                                                            *
      Attention: Read this certification carefully before signing this application.
      THE APPLICANT CERTFIES THAT:
      (a) Coples of PCC Rule Parts 2 and Gare on hand; and
      (b) Adequate financial appropriations bave been made to carry on the program of experimentation which will
          be conducted by qualified personnel: and
      {o) All operations will be on an experimental basis in accordance with Part 6 and other applicable rules, and will
          be conducted in such a manner and at such a time as to preclude harmful interference to any authorized
          station; and
      (d) Grant of the authorization reaquested herein will not be construed as a finding on the part of the Commission:
          () that the frequencies and olher technical parameters specified in the authorizeation are the best
              suited for the proposed progrem of experimentation, and
          (2) that the applicant will be authorized to operate on any basis other than sxperimental, and
          (9) that the Commission is obligated by the results of the experimental program to make provision in Its rules
               including its table of frequency allocations for applicant‘s type of operation on & regularly lHoensed baisia
      APPLICANT CERTFIES FURTHER THAT:
      (e) All the statements in the application and aitached exhiblis are true, complete and correct to the best of the
          applicant‘s knowledge; and
      (f} The applicant is willing to finance and conduct the experimental program with full knowledge and
          understanding of the above lmitations and                  —
      (g) The applicant waives any claim to the use of any perticular frequency or of the electromagnetic spectruri as
          agalnst the regulatory power of the USA.


          Signed and dated this                                       day of                                          .19

          Name of Applicant
                                                         {nest cerrespend cith nome given en page 1}


          By
                                  Eprint?                                                 °   leignaters?

          Title

      Check appropriate classification:

      D    Individual applicant      D      Member of applicant partnership

      [ authorized employee          [ Office of applicant corporation or aswociation

WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNIJSHABLE AY FINE AND/OR IMPRISONMENT (U.S. Code, Title
‘tJ Section 1001), AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT IU.8. Code, Titie 47,
usetion 312la¥(1}, AND/OR FORFEITURE (U.8. Code, Titls 47, Section 509).
                                    NOTIFICATION TO INDIVIDUALS UNDER PRIVACY ACT OF 1874
                                          AND THE PAPERWORK REDUCTION ACT OF 1980
Information requested through this form is authorized by the Communications Act of 1984, as amended, and specified
11y Section 806 therein. The information will be used by Federal Communioations Commission staff to determine
«igibility for lesuing authorizations in the use of the frequency spectrum and to effect the provisions of regulatory
iusponsibilities rendered by the Commission by the Act Information requested by this form will be available to the
pablic unless ctherwise requested pursuant to 47 CFR 0450 of the FCC Rules and Regulations Your response is required
io obtain this authorization.

Public reporting burden for this collection of information is estimated to average four (4) hours par response, inckhxting the time
"or reviewing Instructions, searching existing data sources, gathering and maintaining the data néeeded, and completing and review—
—ng the collection of information, Send comments regarding this burden estimiate or any other mspect of this coliection of
information, Including suggestions for reducing the burden to the Federal Communications Commission, Records Manasgement
If—anch, Paperwork Reduction Project (3080—0085), Washington, DC 20654. DC NOT send completed spplications to this
uddross.     Individuais are not required to respond to this collection uniess it displeys a currently valld OMB control number,

‘"‘HE FOREGOING NOTICE IS REQUIRED BY THE PRIVACY ACT OFP 1974, PL. 98—579, DECEMBER 81, 1974, 56 USC. G6Za(eX8),
AND THE PAPERWORK REDUCTION ACT OF 1080, PL 06—6i1, DECEMEBER 11 1000, 44 USC. G5O7.

                                                                                                            FCC Form 442 — Page 6
                                                                                                                       March 1896


Aloha Networks, Inc.
FCC Form 442—Filing Document

                                        Exhibit A

                       Summary of Transmit Antenna Parameters

1.      Channel Master —0.45 m Ku—Band Antenna

        Operating Frequency (Tx)            13.75 — 14.50 GHz
        Polarizations:                      Linear
        3 dB Beamwidth (Tx)                 3.0° @ 14.3 GHz
        Modulation                          Digital, 2.4 MHz
        Gain (Tx)                           34.7 dBi
        RF power into Antenna Flange:       1.91 Watts or —25 dBW/4 kHz
        Antenna Uplink EIRP                 37.5 dBW or 9.7 dBW/4 kHz

2.      Channel Master —0.60 m Ku—Band Antenna

        Operating Frequency (Tx):           13.75 — 14.50 GHz
        Polarizations:                      Linear
        3 dB Beamwidth (Tx)                 2.4° @ 14.3 GHz
        Modulation                          Digital, 2.4 MHz
        Gain (Tx):                          37.2 dBi
        RF power into Antenna Flange:       1.91 Watts or —25 dBW/4 kHz
        Antenna Uplink EIRP:                40.0 dBW or 12.2 dBW/4 kHz

3.      Channel Master — 0.75 m Ku—Band Antenna

        Operating Frequency (Tx):           13.75 — 14.50 GHz
        Polarizations:                      Linear
        3 dB Beamwidth (Tx)                 1.9° @ 14.3 GHz
        Modulation                          Digital, 2.4 MHz
        Gain (Tx):                          39.1 dBi
        RF power into Antenna Flange:       1.91 Watts or —25 dBW/4 kHz
        Antenna Uplink EIRP:                41.9 dBW or 14.1 dBW/4 kHz

4.      Channel Master — 1.0 m Ku—Band Antenna

        Operating Frequency (Tx):           13.75 — 14.50 GHz
        Polarizations:                      Linear
        3 dB Beamwidth (Tx)                 1.5° @ 14.3 GHz
        Modulation                          Digital, 2.4 MHz
        Gain (Tx):                          41.5 dBi
        RF power into Antenna Flange:       1.91 Watts or —25 dBW/4 kHz
        Antenna Uplink EIRP:                44.3 dBW or 16.5 dBW/4 kHz




                                                                   Exhibit A—Page 1 of 2
                                                                      September 4, 2001


Aloha Networks, Inc.
FCC Form 442—Filing Document




5.      Channel Master —1.2 m Ku—Band Antenna

        Operating Frequency (Tx):       13.75 — 14.50 GHz
        Polarizations:                  Linear
        3 dB Beamwidth (Tx)             1.2° @ 14.3 GHz
        Modulation                      Digital, 2.4 MHz
        Gain (Tx):                      43.3 dBi
        RF power into Antenna Flange:   1.91 Watts or —25 dBW/4 kHz
        Antenna Uplink EIRP:            46.1 dBW or 18.3 dBW/4 kHz

6.      TBD — 4.5 m Ku—Band Antenna

        Operating Frequency (Tx):       13.75 — 14.50 GHz
        Polarizations:                  Linear
        3 dB Beamwidth (Tx)             0.35° @ 14.3 GHz
        Modulation                      Digital, 2.4 MHz
        Gain (Tx):                      53.7 dBi
        RF power into Antenna Flange:   1.91 Watts or —25 dBW/4 kHz
        Antenna Uplink EIRP:            56.5 dBW or 28.7 dBW/4 kHz




                                                               Exhibit A—Page 2 of 2
                                                                  September 4, 2001


Aloha Networks, Inc.
FCC Form 442—Filing Document



                                      Exhibit B

                               Radiation Hazard Analyses
                       (4.5m, 1.2m, 1.0m, 0.75m, 0.60m, & 0.45m)




                                                                   Exhibit B —Page 1 of 31
                                                                        September 4, 2001


                                                                         EXHIBIT B
                                                                         Page 1 of 5



                         Analysis of Non—Ionizing Radiation
                        for a 4.5 Meter Earth Station System


This   report   analyzes the     non—ionizing      radiation    levels   for a 4.5 meter
earth station system.      The analysis and calculations performed in this report
are in compliance with the methods described in the FCC Office of Engineering
and Technology Bulletin, No. 65         first published in      1985 and revised in 1997
in Edition 97—01.     The radiation safety       limits used in     the   analysis are in
conformance     with the      FCC R&O 96—326.        Bulletin No. 65       and   the    FCC
R&O specifies that there are two separate tiers of            exposure limits     that are
dependant on    the   situation in which        the exposure takes      place and/or    the
status   of   the   individuals     who are    subject to    the exposure.     The Maximum
Permissible     Exposure (MPE)      limits    for persons     in a   General Population/
Uncontrolled    environment     are   shown in Table 1.       The    General Population/
Uncontrolled MPE is     a function of      transmit frequency and is for an exposure
period of     thirty minutes      or less.     The   MPE   limits   for   persons    in an
Occupational/Controlled      environment are shown in Table 2.           The Occupational
MPE is a function of transmit frequency and is for an exposure period of six
minutes or less.     The purpose     of the analysis described in this report is to
determine   the   power    flux   density     levels   of   the   earth   station in    the
far—field, near—field,      transition region,       between the    subreflector or feed
and  main   reflector surface,       at   the   main reflector     surface, and between
the  antenna    edge   and   the    ground and      to   compare   these   levels    to the
specified MPEs.


  Table 1.   Limits for General Population/Uncontrolled Exposure (MPE)

  Frequency Range     (MHz)               Power Density     (mWatts/cm**2)

         30—300                                         0 . 2
        300—1500                               Frequency (MHz) * (0.8/1200)
       1500—100,000                                     1 .0



  Table 2. Limits for Occupational/Controlled Exposure (MPE)

  Frequency Range     (MHz)               Power Density     (mWatts/cm**2)

         30—300                                         1.0
        300—1500                               Frequency (MHz) * (4.0/1200)
       1500—100,000                                     5.0



Table 3 contains the parameters that are used to calculate the various power
densities for the earth stations.


                                                                                          EXHIBIT B
                                                                                          Page 2 of 5


Table 3.   Formulas and Parameters Used for Determining Power Flux Densities

     Parameter                Abbreviation                 Value                              Units
     Antenna Diameter             D                        4 .5                               meters
     Antenna Surface Area         Sa                       II   * D*+*2/4                     meters**2
     Subreflector Diameter        Ds                        61.0                              cm
     Area of Subreflector        As                        II * Ds**2/4                       cm**2
     Frequency                   Frequency                 14250                              MHz
     Wavelength                   lambda             300 /frequency (MHz)                     meters
     Transmit Power               P                          1 .91                            Watts
     Antenna Gain                 Ges                    53 .7                                dBi
     Pi                           II                       3.1415927                          n/a
     Antenna Efficiency           n                        0 .55                              n/a



1.   Far Field Distance Calculation

The distance to the beginning of the far field can be determined from the
following equation: (1)

     Distance to the Far Field Region, (Rf)         = 0.60 * D**2 / lambda                                    (1)
                                                       577.1 meters



The maximum main beam power density in the Far Field can be determined
from the following equation: (2)

     On—Axis Power Density in the Far Field, (Wf)                   Ges   *   P   /   4   *   II    * Rf**2   (2)
                                                                     0.107 Watts/meters*®*2
                                                                     0.011 mWatts/com**2




2.   Near Field Calculation

Power flux density is considered to be at a maximum value throughout the
entire length of the defined Near Field region.   The region is contained
within   a cylindrical volume having  the same diameter  as   the antenna.
Past the   boundary of the Near Field region  the power density from the
antenna   decreases  linearly with    respect  to  increasing    distance.

The distance to the end of the Near Field can be determined from the
following equation: (3)

     Extent of the Near Field, (Rn)         D*+*2 / (4 * lambda)                                              (3)
                                             240.5 meters



The maximum power density in the Near Field can be determined from the
following equation: (4)

     Near Field Power Density, (Wn)         16.0   * n *    P   /    II   * D**2                              (4)
                                       i1




                                             0.264 Watts/meters*®*2
                                       i




                                             0.026 mWatts/cm**2


                                                                      EXHIBIT B
                                                                      Page 3 of 5

3.    Transition Region Calculations

The Transition region    is located between the Near and Far Field regions.
The power density begins     to decrease linearly with increasing     distance
in   the  Transition region.   While   the power density decreases inversely
with   distance in   the  Transition   region,   the power  density decreases
inversely with     the square of  the distance in the Far Field region.    The
maximum power density     in  the Transition   region will    not  exceed that
calculated   for   the Near  Field region.   The   power density calculated in
Section 1 is   the highest power density    the antenna can produce in any of
the regions   away from   the antenna.   The power density at a    distance Rt
can be determined from the following equation: (5)

     Transition region Power Density, (Tt)    = Wn * Rn / Rt                        (5)
                                                 0.026 mWatts/cm**2


4.   Region between Main Reflector and Subreflector

Transmissions from the feed assembly are directed toward the subreflector
surface, and are reflected back toward the main reflector. The most common
feed assemblies are waveguide flanges, horns or subreflectors.  The energy
between  the subreflector and the  reflector surfaces can be calculated by
determining  the power density at   the subreflector surface.  This can be
determined from the following equation: (6)


     Power Density at Feed Flange, (Ws)      4 * P / As                             (6)
                                              2.614 mWatts/cm**2



5.   Main Reflector Region

The power density in the main reflector is determined in the same manner
as  the power density at  the subreflector.  The area is now the area of
the main reflector aperture and can be determined from the following
equation: (7)

     Power Density at the Main Reflector Surface, (Wm) = 4 * P / Sa                 (7)
                                                      0.480 Watts/meters*®*2
                                                    it




                                                          0.048 mWatts/cm**2
                                                    i




6.   Reqion between Main Reflector and Ground

Assuming uniform illumination of the reflector surface, the power density
between   the antenna and ground  can be determined    from the following
equation: (8)

     Power Density between Reflector and Ground, (Wg)     = P / Sa                (8)
                                                             0.120 Watts/meters**2
                                                             0.012 mWatts/cm**2


                                                                           EXHIBIT B
                                                                           Page 4 of 5


Table 4.      Summary of Expected Radiation levels for Uncontrolled Environment

                                       Calculated Maximum Radiation
                                            Power Density Level
     Region                                  (mWatts/cm**2)         Hazard Assessment


1.   Far Field     (Rf)     = 577.1 meters        0 .011               Satisfies FCC MPE

2. Near Field       (Rn)    = 240.5 meters        0 .026               Satisfies FCC MPE

3. Transition Region
     Rn <   Rt   < Rf,    (Rt)                    0 .026               Satisfies   FCC MPE

4. Between Main Reflector                         2 .614               Potential Hazard
     and Subreflector

5. Main Reflector                                 0 .048               Satisfies FCC MPE

6.   Between Main Reflector                       0 .012               Satisfies FCC MPE
     and Ground




Table 5.      Summary of Expected Radiation levels for Controlled Environment

                                       Calculated Maximum Radiation
                                            Power Density Level
     Region                                  (mWatts/cm**2)         Hazard Assessment


1.   Far Field     (Rf)     = 577.1 meters        0 .011               Satisfies FCC MPE

2. Near Field       (Rn)    = 240.5 meters        0 .026               Satisfies FCC MPE

3.   Transition Region
     Rn < Rt     < Rf,    (Rt)                    0 .026               Satisfies   FCC MPE

4. Between Main Reflector                         2 .614               Satisfies FCC MPE
   and Subreflector

5. Main Reflector                                 0 .048               Satisfies FCC MPE

6.   Between Main Reflector                       0.012                Satisfies FCC MPE
     and Ground




It  is  the        applicant‘s   responsibility     to     ensure  that  the public and
operational        personnel   are  not exposed     to     harmful  levels of radiation.


                                                             EXHIBIT B
                                                             Page 5 of 5




7.   Conclusions




Based  on  the above  analysis  it   is concluded that  harmful levels of
radiation will  not exist in regions   normally occupied by the public or
the earth station‘s operating personnel.   The transmitter will be turned
off during antenna maintenance so that   the FCC MPE of 5.0 mW/oem**2 will
be complied with for those regions with close proximity to the reflector
that exceed acceptable levels.


                                                                                 EXHIBIT B
                                                                                 Page 1 of 5



                            Analysis of Non—Ionizing Radiation
                           for a 0.45 Meter Earth Station System

This   report       analyzes the    non—ionizing        radiation       levels   for a 0.45 meter
earth station system.     The analysis and calculations performed in this report
are in compliance with the methods described in the FCC Office of Engineering
and Technology Bulletin, No. 65     first published in   1985 and revised in 1997
in Edition 97—01.    The radiation safety    limits used in  the   analysis are in
conformance    with   the    FCC R&O 96—326.    Bulletin No. 65     and   the   FCC
R&O specifies that there are two separate tiers of      exposure limits    that are
dependant on   the   situation in which the exposure takes       place and/or   the
status  of   the   individuals   who are  subject to   the exposure.    The Maximum
Permissible    Exposure (MPE)    limits  for persons    in a  General Population/
Uncontrolled        environment    are     shown in     Table   1.     The   General   Population/
Uncontrolled MPE is    a function of   transmit frequency and is for an exposure
period  of   thirty minutes     or less.  The   MPE   limits   for persons    in  an
Occupational/Controlled     environment are shown in Table 2.       The Occupational
MPE is a function of transmit frequency and is for an exposure period of six
minutes or less.    The purpose   of the analysis described in this report is to
determine  the   power    flux density   levels   of   the   earth   station in  the
far—field, near—field,     transition region,   between the    subreflector or feed
and main   reflector surface,     at  the main reflector      surface, and between
the  antenna   edge   and   the  ground and   to    compare   these   levels  to the
specified MPEs.




  Table    1.   Limits   for General     Population/Uncontrolled Exposure (MPE)

  Frequency Range        (MHz)                 Power Density         (mWatts/cm**2)

           30—300                                               0 .2
          300—1500                                    Frequency (MHz) * (0.8/1200)
       1500—100,000                                             1 .0



  Table 2.      Limits for Occupational/Controlled Exposure (MPE)

  Frequency Range        (MHz)                 Power Density         (mWatts/cm**2)

           30—300                                               1 .0
          300—1500                                    Frequency (MHz) * (4.0/1200)
       1500—100, 000                                            5 .0




Table 3 contains the parameters that are used to calculate the various power
densities for the earth stations.


                                                                                          EXHIBIT B
                                                                                          Page 2 of 5


Table 3.   Formulas and Parameters Used for Determining Power Flux Densities

     Parameter                Abbreviation               Value                                Units
     Antenna Diameter             D                      0 .45                                 meters
     Antenna Surface Area         Sa                     II * D*+*2/4                         meters**2
     Feed Flange Diameter         Df                          7 .6                            ocm
     Area of Feed Flange          Fa                     II * Df**2/4                         cm**2
     Frequency                    Frequency              14250                                MHz
     Wavelength                   lambda           300/frequency (MHz)                        meters
     Transmit Power               P                       1 .91                               Watts
     Antenna Gain                 Ges                 34 .7                                   dBi
     Pi                           II                     3.1415927                            n/a
     Antenna Efficiency           n                      0 .65                                n/a



1.   Far Field Distance Calculation

The distance to the beginning of the far field can be determined from the
following equation: (1)

     Distance to the Far Field Region, (Rf)         0.60 * D**2 / lambda                                        (1)
                                                     5.8 meters



The maximum main beam power density in the Far Field can be determined
from the following equation: (2)

     On—Axis Power Density in the Far Field, (Wf)                  Ges    *   P   /   4   *   II    *   Rf**2   (2)
                                                                     13.467 Watts/meters*®*2
                                                                     1.347 mWatts/cm**2



2.   Near Field Calculation

Power flux density is considered to be at a maximum value throughout the
entire length of the defined Near Field region.   The region is contained
within   a cylindrical volume having  the same diameter  as   the antenna.
Past the   boundary of the Near Field region  the power density from   the
antenna   decreases  linearly with    respect  to  increasing    distance.

The distance to the end of the Near Field can be determined from the
following equation: (3)

     Extent of the Near Field, (Rn)    D**2 /      (4 * lambda)                                                 (3)
                                           2.4 meters



The maximum power density in the Near Field can be determined from the
following equation: (4)

     Near Field Power Density, (Wn)    16.0    *   n *    P    /     II   * D**2                                {(4)
                                           31.439 Watts/meters**2
                                           3.144 mWatts/cm**2


                                                                                        EXHIBIT B
                                                                                        Page 3 of 5

3.   Transition Region Calculations

The Transition region    is located   between the Near and Far Field regions.
The power density begins     to decrease linearly with increasing   distance
in   the  Transition region.   While  the power density decreases inversely
with   distance in   the  Transition  region,  the power  density decreases
inversely with     the square of  the distance in the Far Field region.  The
maximum power density     in the Transition   region will   not  exceed that
calculated   for   the Near  Field region.  The power density calculated in
Section 1 is   the highest power density   the antenna can produce in any of
the regions   away from the antenna.    The power density at a   distance Rt
can be determined from the following equation: (5)

     Transition region Power Density, (Tt)            Wn * Rn / Rt
                                                       3.144 mWatts/cm**2


4.   Region between Feed Assembly and Antenna Reflector

Transmissions   from the feed assembly    are  Girected toward  the   antenna
reflector surface, and are confined within a conical shape defined by      the
type  of   feed assembly.  The most   common  feed assemblies are   waveqguide
flanges, horns or subreflectors.    The energy between the feed assembly and
reflector surface   can be  calculated by determining the power density at
the  feed   assembly surface.  This   can be   determined from the following
equation: (6)

     Power Density at Feed Flange, (Wf)      4    *    P /   Fa                                       (6)
                                                 168 .413 mWatts/cm**2


5.   Main Reflector Region

The power density in the main reflector is determined in the  same manner
as the power density at the feed assembly.   The  area is now the area of
the reflector aperture   and can be   determined  from   the    following
equation: (7)

     Power Density at the Reflector Surface, (Ws)                 4    *   P   /   Sa                 (7)
                                                                      48 .037 Watts/meters*®*2
                                                                      4.804 mWatts/cm**2


6.   Region between Reflector and Ground

Assuming uniform illumination of the reflector surface, the power density
between   the antenna and ground  can be determined    from the following
equation: (8)

     Power Density between Reflector and Ground, (Wy)                      P / Sa                 (8)
                                                                            12.009 Watts/meters*®*2
                                                                      II




                                                                            1.201 mWatts/cm**2


                                                                         EXHIBIT B
                                                                         Page 4 of 5


Table 4.      Summary of Expected Radiation levels for Uncontrolled Environment

                                      Calculated Maximum Radiation
                                           Power Density Level
     Region                                  (mWatts/cm**2)        Hazard Assessment


1.   Far Field    (Rf)     = 5.8 meters         1 .347               Potential Hazard

2. Near Field      (Rn)    = 2.4 meters         3 .144               Potential Hazard

3.   Transition Region
     Rn < Rt < Rf, (Rt)                         3 .144               Potential Hazard

4.   Between Feed Assembly                      168 .413             Potential Hazard
     and Antenna Reflector

5. Main Reflector                               4 .804               Potential Hazard

6.   Between Reflector                          1 .201               Potential Hazard
     and Ground




Table 5.      Summary of Expected Radiation levels for Controlled Environment

                                      Calculated Maximum Radiation
                                           Power Density Level
     Region                                 (mWatts/cm**2)           Hazard Assessment


1.   Far Field    (Rf)     = 5.8 meters         1.347                Satisfies FCC MPE

2. Near Field      (Rn)    = 2.4 meters         3 .144               Satisfies FCC MPE

3.   Transition Region
     Rn < Rt < Rf,       (Rt)                   3 .144               Satisfies FCC MPE

4.   Between Feed Assembly                      168 .413             Potential Hazard
     and Antenna Reflector

5.   Main Reflector                             4 .804               Satisfies FCC MPE

6.   Between Reflector                          1.201                Satisfies FCC MPE
     and Ground




It  is  the      applicant‘s   responsibility     to     ensure  that  the  public and
operational      personnel   are  not exposed     to     harmful  levels of radiation.


                                                                          EXHIBIT B
                                                                          Page 5 of 5




    7.   Conclusions




Based on  the above analysis it  is concluded that  the FCC MPE  quidelines
have been exceeded (or met) in the regions of Table 4. and 5. The applicant
proposes  to comply with   the MPE limits  by one or more of the following
methods .

The proposed earth station will be installed at the Aloha Networks facility.
The antenna facility should be surrounded by a fence, which will restrict any
public access to the site.  The earth station will be marked with the standard
radiation hazard warnings, as well as the area in the vicinity of the earth
stations to inform those in the general population, who may be working or
otherwise present in or near the direct path of the main beanms.

Aloha Networks,   Inc.   will   ensure that   the main beam of   the antenna will be
pointed at least one diameter away from any buildings,           or other obstacles in
those areas that exceeds the MPE levels.

Finally, the earth station operating personnel will not have excess to areas
that exceed the MPE levels, while the earth station is in operation.  The
transmitter will be turned off during periods of maintenance, so that the MPE
standard of 5.0 mW/cm**2 will be complied with for those regions in close
proximity to the reflector, and normally occupied by operating personnel.


                                                                          EXHIBIT B
                                                                          Page 1 of 5



                        Analysis of Non—Ionizing Radiation
                       for a 0.6 Meter Earth Station System


This   report   analyzes the    non—ionizing   radiation   levels   for a 0.6 meter
earth station system.      The analysis and calculations performed in this report
are in compliance with the methods described in the FCC Office of Engineering
and Technology Bulletin, No. 65      first published in    1985 and revised in 1997
in Edition 97—01.     The radiation safety    limits used in   the   analysis are in
conformance     with   the    FCC R&O 96—326.    Bulletin No. 65      and   the   FCC
R&O specifies that there are two separate tiers of        exposure limits    that are
dependant on    the   situation in which     the exposure takes    place and/or   the
status   of   the   individuals   who are  subject to    the exposure.    The Maximum
Permissible     Exposure (MPE)    limits  for persons     in a General Population/
Uncontrolled    environment   are   shown in     Table   1.    The    General   Population/
Uncontrolled MPE is    a function of    transmit frequency and is for an exposure
period  of   thirty minutes     or less.   The   MPE   limits   for   persons  in an
Occupational/Controlled environment are shown in Table 2.            The Occupational
MPE is a function of transmit frequency and is for an exposure period of six
minutes or less.    The purpose   of the analysis described in this report is to
determine  the   power    flux density    levels   of   the   earth   station in  the
far—field, near—field,     transition region,    between the    subreflector or feed
and main   reflector surface,     at  the   main reflector     surface, and between
the  antenna   edge   and   the  ground   and  to    compare   these   levels  to the
specified MPEs.




  Table 1.   Limits for General Population/Uncontrolled Exposure (MPE)

  Frequency Range    (MHz)              Power Density         (mWatts/cm**2)

        30—300                                         0 .2
       300—1500                                Frequency (MHz) * (0.8/1200)
      1500—100,000                                     1 .0



  Table 2.   Limits for Occupational/Controlled Exposure (MPE)

  Frequency Range    (MHz)              Power Density         (mWatts/cm**2)

        30—300                                         1 .0
       300—1500                                Frequency (MHz) * (4.0/1200)
      1500—100,000                                     5.0




Table 3 contains the parameters that are used to calculate the various power
densities for the earth stations.


                                                                                    EXHIBIT B
                                                                                    Page 2 of 5


Table 3.   Formulas and Parameters Used for Determining Power Flux Densities

     Parameter                Abbreviation            Value                             Units
     Antenna Diameter             D                   0 .6                              meters
     Antenna Surface Area         Sa                  II * D**2/4                       meters*®*2
     Feed Flange Diameter         Df                     7 .6                           cm
     Area of Feed Flange          Fa                  II * Df**2/4                      cm**2
     Frequency                    Frequency           14250                             MHz
     Wavelength                   lambda           300/frequency (MHz)                  meters
     Transmit Power               P                        1 .91                        Watts
     Antenna Gain                 Ges                 37 .2                             aBi
     Pi                           II                    3.1415927                       n/a
     Antenna Efficiency           n                     0 .65                           n/a



1.   Far Field Distance Calculation

The distance to the beginning of the far field can be determined from the
following equation: (1)

     Distance to the Far Field Region, (Rf)       = 0.60 * D*®*2 / lambda                                 (1)
                                                     10.3 meters



The maximum main beam power density in the Far Field can be determined
from the following equation: (2)

     On—Axis Power Density in the Far Field, (Wf)               Ges   *   P /   4   *   II    *   Rf**2   (2)
                                                                 7.578 Watts/meters*®*2
                                                                 0 .758 mWatts/cm**2



2.   Near Field Calculation

Power flux density is considered to be at a maximum value throughout the
entire length of the defined Near Field region.   The region is contained
within   a cylindrical volume having  the same diameter  as   the antenna.
Past the   boundary of the Near Field region  the power density from   the
antenna   decreases  linearly with    respect  to  increasing    distance.

The distance to the end of the Near Field can be determined from the
following equation: (3)

     Extent of the Near Field, (Rn)    D*+*2 / (4 * lambda}                                               (3)
                                        4.3 meters


The maximum power density in the Near Field can be determined from the
following equation: (4)

     Near Field Power Density, (Wn)    16.0   *   n *    P /     II   * D*+*2                             (4)
                                        17.689 Watts/meters*®*2
                                        1.769 mWatts/cm**2


                                                                                  EXHIBIT B
                                                                                  Page 3 of 5

3.   Transition Region Calculations

The Transition region    is located between the Near and Far Field regions.
The power density begins     to decrease linearly with increasing distance
in   the  Transition region.   While  the power density    decreases inversely
with   distance in   the  Transition  region,    the power  density decreases
inversely with     the square of  the distance in the Far Field region.    The
maximum power density     in  the Transition   region will    not  exceed that
calculated   for   the Near  Field region.   The   power density calculated in
Section 1 is   the highest power density the antenna can produce in any of
the regions   away from the antenna.    The power density at a     distance Rt
can be determined from the following equation: (5)

     Transition region Power Density, (Tt)    = Wn * Rn / Rt
                                                 1.769 mWatts/cm**2


4.   Region between Feed Assembly and Antenna Reflector

Transmissions   from     the feed assembly   are   directed toward                the   antenna
reflector surface,     and are confined within a conical             shape defined by         the
type  of   feed assembly.  The most   common  feed assemblies are waveguide
flanges, horns or subreflectors.    The energy between the feed assembly and
reflector surface   can be  calculated by determining the power density at
the  feed   assembly surface.  This   can be   determined from the following
equation: (6)

     Power Density at Feed Flange, (Wf)      4 * P / Fa                                             (6)
                                              168 .413 mWatts/cm**2


5.   Main Reflector Region

The power density in the main reflector is determined in the  same manner
as the power density at the feed assembly.   The  area is now the area of
the reflector aperture   and can be   determined  from   the    following
equation: (7)

     Power Density at    the Reflector Surface, (Ws)        4    *   P   /   Sa
                                                       i1




                                                                27.021 Watts/meters**2
                                                       It




                                                                2.702 mWatts/cm**2


6.   Reqion between Reflector and Ground

Assuming uniform illumination of the reflector surface, the power density
between   the antenna and ground  can be determined    from the following
equation: (8)

     Power Density between Reflector and Ground, (Wg)                P / Sa                (8)
                                                                      6.755 Watts/meters**2
                                                                      0.6756 mWatts/cm**2


                                                                          EXHIBIT B
                                                                          Page 4 of 5


Table 4.      Summary of Expected Radiation levels for Uncontrolled Environment

                                       Calculated Maximum Radiation
                                            Power Density Level
     Region                                  (mWatts/cm**2)         Hazard Assessment


1.   Far Field    {(Rf)     = 10.3 meters        0 .758               Satisfies FCC MPE

2. Near Field      (Rn)     = 4.3 meters         1.769                Potential Hazard

3.   Transition Region
     Rn < Rt < Rf, (Rt)                          1.769                Potential Hazard

4.   Between Feed Assembly                       168 .413             Potential Hazard
     and Antenna Reflector

5. Main Reflector                                2 .702               Potential Hazard

6. Between Reflector                             0 .676               Satisfies FCC MPE
   and Ground




Table 5.      Summary of Expected Radiation levels for Controlled Environment

                                       Calculated Maximum Radiation
                                            Power Density Level
     Region                                  {mWatts/cm**2)         Hazard Assessment


1.   Far Field    (Rf)      = 10.3 meters        0 .758               Satisfies FCC MPE

2. Near Field      (Rn)     = 4.3 meters         1.769                Satisfies FCC MPE

3.   Transition Region
     Rn < Rt    < Rf,     (Rt)                   1 .769               Satisfies   FCC MPE

4.   Between Feed Assembly                       168 .413             Potential Hazard
     and Antenna Reflector

5.   Main Reflector                              2 .702               Satisfies FCC MPE

6.   Between Reflector                           0 .676               Satisfies FCC MPE
     and Ground




It  is  the       applicant‘s   responsibility     to     ensure  that  the  public and
operational       personnel   are  not exposed     to     harmful  levels of radiation.


                                                                EXHIBIT B
                                                                Page 5 of 5




    7.   Conclusions




Based on  the above analysis it  is concluded that  the FCC MPE quidelines
have been exceeded (or met) in the regions of Table 4. and 5. The applicant
proposes  to comply with   the MPE limits  by one or more of the following
methods .

The proposed earth station will be installed at the Aloha Networks facility.
The antenna facility should be surrounded by a fence, which will restrict any
public access to the site.  The earth station will be marked with the standard
radiation hazard warnings, as well as the area in the vicinity of the earth
stations to inform those in the general population, who may be working or
otherwise present in or near the direct path of the main beams.

Aloha Networks, Inc. will ensure that the main beam of the antenna will be
pointed at least one diameter away from any buildings, or other obstacles in
those areas that exceeds the MPE levels.

Finally, the earth station operating personnel will not have excess to areas
that exceed the MPE levels, while the earth station is in operation.   The
transmitter will be turned off during periods of maintenance, so that the MPE
standard of 5.0 mW/cem**2 will be complied with for those regions in close
proximity to the reflector, and normally occupied by operating personnel.


                                                                        EXHIBIT B
                                                                        Page 1 of 5



                        Analysis of Non—Ionizing Radiation
                       for a 0.75 Meter Earth Station System

This   report   analyzes the     non—ionizing     radiation    levels   for a 0.75 meter
earth station system.      The analysis and calculations performed in this report
are in compliance with the methods described in the FCC Office of Engineering
and Technology Bulletin, No. 65        first published in      1985 and revised in 1997
in Edition 97—01.     The radiation safety       limits used in    the   analysis are in
conformance     with   the    FCC R&O 96—326.       Bulletin No. 65       and   the    FCC
R&O specifies that there are two separate tiers of           exposure limits     that are
dependant on    the   situation in which       the exposure takes place and/or         the
status   of   the   individuals    who are    subject to    the exposure.     The Maximum
Permissible     Exposure (MPE)     limits    for persons     in a   General Population/
Uncontrolled    environment    are   shown in Table 1.       The    General Population/
Uncontrolled MPE is     a function of     transmit frequency and is for an exposure
period of     thirty minutes      or less.    The   MPE   limits   for   persons    in an
Occupational/Controlled environment are shown in Table 2.               The Occupational
MPE is a function of transmit frequency and is for an exposure period of six
minutes or less.     The purpose    of the analysis described in this report is to
determine   the   power    flux density      levels   of   the   earth   station in    the
far—field, near—field,      transition region,      between the    subreflector or feed
and main    reflector surface,      at   the   main reflector     surface, and between
the  antenna    edge   and   the   ground    and   to   compare   these   levels    to the
specified MPEs.



  Table 1.   Limits for General Population/Uncontrolled Exposure (MPE)

  Frequency Range     (MHz)               Power Density    (mWatts/cm**2)

         30—300                                       0 .2
        300—1500                              Frequency (MHz)*(0.75/1200)
       1500—100,000                                     1 .0



  Table 2.   Limits for Occupational/Controlled Exposure (MPE)

  Frequency Range     (MHz)               Power Density    (mWatts/cm**2)

         30—300                                         1.0
        300—1500                              Frequency (MHz) * (4.0/1200)
       1500—100,000                                   5.0



Table 3 contains the parameters that are used to calculate the various power
densities for the earth stations.


                                                                         EXHIBIT B
                                                                         Page 2 of 5


Table 3.   Formulas and Parameters Used for Determining Power Flux Densities

     Parameter                Abbreviation            Value                Units
     Antenna Diameter             D                   0 .75                 meters
     Antenna Surface Area         Sa                  II * D**2/4          meters**2
     Feed Flange Diameter         Df                     7 .7              cm
     Area of Feed Flange          Fa                  II * Df**2/4         cm**2
     Frequency                    Frequency           14250                MHz
     Wavelength                   lambda           300/frequency (MHz)     meters
     Transmit Power               P                        1.91            Watts
     Antenna Gain                 Ges                  39 .1               dBi
     Pi                           II                   3.1415927           n/a
     Antenna Efficiency           n                    0 .65               n/a


1.   Far Field Distance Calculation

The distance to the beginning of the far field can be determined from the
following equation: (1)

     Distance to the Far Field Region, (Rf)       = 0.60 * D**2 / lambda                (1)
                                                      16.0 meters



The maximum main beam power density in the Far Field can be determined
from the following equation: (2)

     On—Axis Power Density in the Far Field, (Wf)          = Ges * P / 4 * II * Rf**2   (2)
                                                              4.807 Watts/meters**2
                                                              0.481 mWatts/cm**2


2.   Near Field Calculation

Power flux density is considered to be at a maximum value throughout the
entire length of the defined Near Field region.   The region is contained
within   a cylindrical volume having  the same diameter  as   the antenna.
Past the   boundary of the Near Field region  the power density from the
antenna   decreases  linearly with    respect  to  increasing    distance.

The distance to the end of the Near Field can be determined from the
following equation: (3)

     Extent of the Near Field, (Rn)         D*+*2 / (4 *   lambda)                      (3)
                                        =     6.7 meters

The maximum power density in the Near Field can be determined from the
following equation: (4)

     Near Field Power Density, (Wn)         16.0 * n * P / II * D**2                    {4)
                                             11.222 Watts/meters*®*2
                                             1.122 mWatts/cm**2


                                                                                          EXHIBIT B
                                                                                          Page 3 of 5

3.   Transition Region Calculations

The Transition region    is located between the Near and Far Field regions.
The power density begins     to decrease linearly with increasing distance
in   the  Transition region.   While   the power density decreases inversely
with   distance in   the  Transition   region,   the power  density decreases
inversely with     the square of  the distance in the Far Field region.    The
maximum power density     in  the Transition   region will    not  exceed that
calculated   for   the Near  Field region.   The   power density calculated in
Section 1 is   the highest power density the antenna can produce in any of
the regions   away from   the antenna.   The power density at a    distance Rt
can be determined from the following equation: (5)

     Transition region Power Density, (Tt)                Wn * Rn / Rt




                                                 It
                                                           1.122 mWatts/cm**2


4.   Region between Feed Assembly and Antenna Reflector

Transmissions   from   the feed assembly   are  directed toward  the   antenna
reflector surface, and are confined within a conical shape defined by      the
type  of   feed assembly.   The most   common  feed assemblies are   wavequide
flanges, horns or subreflectors.     The energy between the feed assembly and
reflector surface    can be  calculated by determining the power density at
the  feed   assembly surface.   This   can be   determined from the following
equation: (6)

     Power Density at Feed Flange, (Wf)      4        *    P /   Fa
                                                 164.067 mWatts/cem**2


5.   Main Reflector Region

The power density in the main reflector is determined in the  same manner
as the power density at the feed assembly.   The  area is now the area of
the reflector aperture   and can be   determined  from   the    following
equation: (7)

     Power Density at the Reflector Surface, (Ws)                     4    *   P /   Sa
                                                                          17.293 Watts/meters*®*2
                                                                          1.729 mWatts/cm**2


6.   Region between Reflector and Ground

Assuming uniform illumination of the reflector surface, the power density
between   the antenna and ground can be determined     from the following
equation: (8)

     Power Density between Reflector and Ground, (Wg)                      = P / Sa                 (8)
                                                                              4.323 Watts/meters*®*2
                                                                              0.432 mWatts/cm**2


                                                                             EXHIBIT B
                                                                             Page 4 of 5


Table 4.      Summary of Expected Radiation levels for Uncontrolled Environment

                                          Calculated Maximum Radiation
                                               Power Density Level
     Region                                      (mWatts/cm**2)        Hazard Assessment


1.   Far Field     (Rf)     = 16.0 meters           0 .481               Satisfies FCC MPE

2. Near Field       (Rn)    = 6.7 meters            1.122                Potential Hazard

3.   Transition Region
     Rn < Rt < Rf, (Rt)                             1.122                Potential Hazard

4.   Between Feed Assembly                          164 .067             Potential Hazard
     and Antenna Reflector

5.   Main Reflector                                 1.729                Potential Hazard

6.   Between Reflector                              0 .432               Satisfies FCC MPE
     and Ground




Table 5.      Summary of Expected Radiation levels for Controlled Environment

                                          Calculated Maximum Radiation
                                               Power Density Level
     Region                                     ({mWatts/cm**2) Hazard Assessment


1.   Far Field     (Rf)     = 16.0 meters           0 .481               Satisfies FCC MPE

2.   Near Field     (Rn)    =    6.7 meters         1.122                Satisfies   FCC MPE

3.   Transition Region
     Rn <   Rt   < Rf,    (Rt)                      1.122                Satisfies   FCC MPE

4.   Between Feed Assembly                          164 .067             Potential Hazard
     and Antenna Reflector

5. Main Reflector                                   1.729                Satisfies FCC MPE

6.   Between Reflector                              0 .432               Satisfies FCC MPE
     and Ground




It  is  the        applicant‘s   responsibility       to     ensure  that  the  public and
operational        personnel   are  not exposed       to     harmful  levels of radiation.


                                                                    EXHIBIT B
                                                                    Page 5 of 5




    7.   Conclusions




Based on  the above analysis it  is concluded that  the FCC MPE  quidelineshave
been exceeded (or met) in the regions of Table 4. and 5. The applicant proposes
to comply   with   the MPE limits   by one or   more of the following methods.

The proposed earth station will be installed at the Aloha Networks facility.
The antenna facility should be surrounded by a fence, which will restrict any
public access to the site.  The earth station will be marked with the standard
radiation hazard warnings, as well as the area in the vicinity of the earth
stations to inform those in the general population, who may be working or
otherwise present in or near the direct path of the main beams.

Aloha Networks, Inc. will ensure that the main beam of the antenna will be
pointed at least one diameter away from any buildings, or other obstacles in
those areas that exceeds the MPE levels.

Finally, the earth station operating personnel will not have excess to areas
that exceed the MPE levels, while the earth station is in operation.  The
transmitter will be turned off during periods of maintenance, so that the MPE
standard of 5.0 mW/cm**2 will be complied with for those regions in close
proximity to the reflector, and normally occupied by operating personnel.


                                                                                 EXHIBIT B
                                                                                 Page 1 of 5



                         Analysis of Non—Ionizing Radiation
                        for a 1.0 Meter Earth Station System


This   report   analyzes the    non—ionizing   radiation   levels   for a 1.0 meter
earth station system.      The analysis and calculations performed in this report
are in compliance with the methods described in the FCC Office of Engineering
and Technology Bulletin, No. 65      first published in    1985 and revised in 1997
in Edition 97—01.     The radiation safety    limits used in   the   analysis are in
conformance     with   the    FCC R&O 96—326.    Bulletin No. 65      and   the   FCC
R&O specifies that there are two separate tiers of        exposure limits    that are
dependant on    the   situation in which     the exposure takes    place and/or   the
status   of   the   individuals   who are  subject to    the exposure.    The Maximum
Permissible     Exposure (MPE)    limits  for persons     in a  General Population/
Uncontrolled     environment     are     shown in     Table   1.     The    General   Population/
Uncontrolled MPE is    a function of  transmit frequency and is for an exposure
period  of  thirty minutes     or less.  The   MPE  limits   for  persons  in  an
Occupational/Controlled    environment are shown in Table 2.     The Occupational
MPE is a function of transmit frequency and is for an exposure period of six
minutes or less.   The purpose   of the analysis described in this report is to
determine  the   power   flux density   levels   of  the   earth  station in  the
far—field,   near—field,      transition region,        between the         subreflector or feed
and main   reflector surface,           at  the   main reflector           surface, and between
the  antenna  edge  and  the           ground   and  to  compare           these   levels to the
specified MPEs.




  Table 1.   Limits for General Population/Uncontrolled Exposure (MPE)

  Frequency Range     (MHz)                  Power Density         ({mWatts/cm**2)

        30—300                                                0 .2
       300—1500                                     Frequency (MHz) * (0.8/1200)
      1500—100,000                                            1 .0



  Table 2.   Limits for Occupational/Controlled Exposure (MPE)

  Frequency Range     (MHz)                  Power Density         (mWatts/cm**2)

        30—300                                                1.0
       300—1500                                     Frequency (MHz) * (4.0/1200)
      1500—100, 000                                           5.0




Table 3 contains the parameters that are used to calculate the various power
densities for the earth stations.


                                                                                   EXHIBIT B
                                                                                   Page 2 of 5


Table 3.    Formulas and Parameters Used for Determining Power Flux Densities

     Parameter                Abbreviation                Value                     Units
     Antenna Diameter             D                       1.0                       meters
     Antenna Surface Area         Sa                      II * D**2/4               meters**2
     Feed Flange Diameter         Df                        7 .7                    cm
     Area of Feed Flange          Fa                      II * Df**2/4              cm»**2
     Frequency                    Frequency               14250                     MHz
     Wavelength                   lambda            300 /frequency (MHz)            meters
     Transmit Power               P                        1 .91                    Watts
     Antenna Gain                 Ges                   41.5                        dBi
     Pi                           II                      3.1415927                 n/a
     Antenna Efficiency           n                       0 .63                     n/a



1.   Far Field Distance Calculation

The distance to the beginning of the far field can be determined from the
following equation: (1)

     Distance to the Far Field Region, (Rf)        = 0.60 * D*+*2 / lambda                       (1)
                                                      28.5 meters



The maximum main beam power density in the Far Field can be determined
from the following equation: (2)

     On—Axis Power Density in the Far Field, (Wf)                 Ges * P / 4 * II * Rf**2       (2)
                                                            it



                                                                   2.643 Watts/meters*®*2
                                                            4t




                                                                   0 .264 mWatts/cm**2
                                                            1




2.   Near Field Calculation

Power flux density is considered to be at a maximum value throughout the
entire length of the defined Near Field region.                  The region is contained
within   a cylindrical volume having  the same diameter  as   the antenna.
Past the   boundary of the Near Field region  the power density from   the
antenna   decreases  linearly with    respect  to  increasing    distance .

The distance to the end of the Near Field can be determined from the
following equation: (3)

     Extent of the Near Field, (Rn)    D**2 /       (4 * lambda)                                 (3)
                                           11.9 meters



The maximum power density in the Near Field can be determined from the
following equation: (4)

     Near Field Power Density, (Wn)    16.0    *    n *    P /     II   *   D**2                 (4)
                                           6.170 Watts/meters**2
                                           0.617 mWatts/cem**2


                                                                          EXHIBIT B
                                                                          Page 3 of 5

3.   Transition Region Calculations

The Transition region    is located between the Near and Far Field regions.
The power density begins     to decrease linearly with increasing   distance
in   the  Transition region.   While  the power density decreases inversely
with   distance in   the  Transition  region,  the power  density  decreases
inversely with     the square of  the distance in the Far Field region.  The
maximum   power density     in   the Transition    region    will   not    exceed that
calculated   for  the Near  Field region.  The  power density calculated in
Section 1 is   the highest power density the antenna can produce in any of
the regions   away from  the antenna.  The power density at a   distance Rt
can be determined from the following equation: (5)

     Transition region Power Density, (Tt)    = Wn * Rn / Rt                                (5)
                                                 0.617 mWatts/cm**2


4.   Region between Feed Assembly and Antenna Reflector

Transmissions   from     the feed assembly   are   directed toward        the   antenna
reflector surface,     and are confined within a conical       shape defined by       the
type  of   feed assembly.  The most   common  feed assemblies are  waveguide
flanges, horns or subreflectors.    The energy between the feed assembly and
reflector surface   can be  calculated by determining the power density at
the  feed   assembly surface.  This   can be   determined from the following
equation: (6)

     Power Density at Feed Flange, (Wf)      4 * P / Fa                                     (6)
                                              164.067 mWatts/cm**2


5.   Main Reflector Region

The power density in the main reflector is determined in the  same manner
as the power density   at the feed assembly.  The area is now the area of
the reflector aperture    and can be   determined from   the    following
equation: (7)

     Power Density at    the Reflector Surface, (Ws)        4 * P / Sa                      (7)
                                                             9.728 Watts/meters**2
                                                             0.973 mWatts/cm**2


6.   Region between Reflector and Ground

Assuming uniform illumination of the reflector surface, the power density
between   the antenna and ground can be determined     from the following
equation: (8)

     Power Density between Reflector and Ground, (Wg)           P / Sa                (8)
                                                                 2.432 Watts/meters**2
                                                                 0.243 mWatts/cm**2


                                                                            EXHIBIT B
                                                                            Page 4 of 5


Table 4.      Summary of Expected Radiation levels for Uncontrolled Environment

                                         Calculated Maximum Radiation
                                              Power Density Level
     Region                                    ({mWatts/cm**2)          Hazard Assessment



1.   Far Field    (Rf)     =    28.5 meters        0 .264               Satisfies   FCC MPE

2.   Near Field    (Rn)    = 11.9 meters           0 .617               Satisfies FCC MPE

3.   Transition Region
     Rn < Rt < Rf,       (Rt)                      0 .617               Satisfies FCC MPE

4.   Between Feed Assembly                         164 .067             Potential Hazard
     and Antenna Reflector

5.   Main Reflector                                0 .973               Satisfies FCC MPE

6.   Between Reflector                             0 .243               Satisfies FCC MPE
     and Ground




Table 5.      Summary of Expected Radiation levels for Controlled Environment

                                         Calculated Maximum Radiation
                                              Power Density Level
     Region                                    {mWatts/cm**2)         Hazard Assessment


1.   Far Field    (Rf)     = 28.5 meters           0 .264               Satisfies FCC MPE

2. Near Field      (Rn)    = 11.9 meters           0 .617               Satisfies FCC MPE

3.   Transition Region
     Rn < Rt < Rf, (Rt)                            0 .617               Satisfies FCC MPE

4. Between Feed Assembly                           164 .067             Potential Hazard
   and Antenna Reflector

5. Main Reflector                                  0 .973               Satisfies FCC MPE

6.   Between Reflector                             0 .243               Satisfies FCC MPE
     and Ground




It  is  the       applicant‘s   responsibility       to     ensure  that  the  public and
operational       personnel   are  not exposed       to     harmful  levels of radiation.


                                                            EXHIBIT B
                                                            Page 5 of 5




7.   Conclusions




Based  on  the above  analysis  it   is concluded that  harmful levels of
radiation will  not exist in regions   normally occupied by the public or
the earth station‘s operating personnel.   The transmitter will be turned
off during antenna maintenance so that   the FCC MPE of 5.0 mW/cm**2 will
be complied with for those regions with close proximity to the reflector
that exceed acceptable levels.


                                                                              EXHIBIT B
                                                                              Page 1 of 5



                            Analysis of Non—Ionizing Radiation
                           for a 1.2 Meter Earth Station System


This   report   analyzes the     non—ionizing     radiation   levels   for a 1.2 meter
earth station system.      The analysis and calculations performed in this report
are in compliance with the methods described in the FCC Office of Engineering
and Technology Bulletin, No. 65        first published in     1985 and revised in 1997
in Edition 97—01.     The radiation safety      limits used in     the  analysis are in
conformance     with   the    FCC R&O 96—326.       Bulletin No. 65      and   the    PCC
R&O specifies that there are two separate tiers of           exposure limits    that are
dependant on    the   situation in which       the exposure takes place and/or        the
status   of   the   individuals     who are   subject to    the exposure.    The Maximum
Permissible     Exposure (MPE)      limits   for persons     in a   General Population/
Uncontrolled environment        are   shown in Table 1.      The    General Population/
Uncontrolled MPE is     a function of      transmit frequency and is for an exposure
period   of   thirty minutes      or less.    The   MPE  limits    for persons     in an
Occupational/Controlled      environment are shown in Table 2.         The Occupational
MPE is a function of transmit frequency         and is for an exposure period of six
minutes or less.     The purpose     of the analysis described in this report is to
determine   the   power    flux   density    levels   of  the    earth  station in    the
far—field,      near—field,  transition region,  between the  subreflector or feed
and  main       reflector surface,  at  the  main reflector  surface, and  between
the  antenna  edge        and    the   ground    and   to   compare   these   levels      to the
specified MPEs.




  Table    1.   Limits   for General   Population/Uncontrolled Exposure (MPE)

  Frequency Range        (MHz)                  Power Density   (mWatts/cm**2)

           30—300                                            0 .2
          300—1500                                  Frequency (MHz) * (0.8/1200)
       1500—100, 000                                         1 .0



  Table 2. Limits for Occupational/Controlled Exposure (MPE)

  Frequency Range        (MHz)                  Power Density   (mWatts/cm**2)

           30—300                                            1 .0
          300—1500                                  Frequency (MHz) * (4.0/1200)
       1500—100,000                                          5.0




Table 3 contains the parameters that are used to calculate the various power
densities for the earth stations.


                                                                                    EXHIBIT B
                                                                                    Page 2 of 5


Table 3.   Formulas and Parameters Used for Determining Power Flux Densities

     Parameter                Abbreviation                   Value                   Units
     Antenna Diameter             D                          1 .2                    meters
     Antenna Surface Area         Sa                         II     * D**2/4         meters**2
     Feed Flange Diameter         Df                          18 .0                   cnm
     Area of Feed Flange          Fa                         II * Df**2/4             cm**2
     Frequency                    Frequency                  14250                   MHz
     Wavelength                   lambda                300/frequency (MHz)          meters
     Transmit Power               P                            1 .91                 Watts
     Antenna Gain                 Ges                      43 .3                     dBi
     Pi                           II                         3.1415927               n/a
     Antenna Efficiency           n                          0 .67                   n/a



1.   Far Field Distance Calculation

The distance to the beginning of the far field can be determined from the
following equation: (1)

     Distance to the Far Field Region, (Rf)            = 0.60 * D**2 / lambda                     (1)
                                                          41.0 meters



The maximum main beam power density in the Far Field can be determined
from the following equation: (2)

     On—Axis Power Density in the Far Field, (Wf)                    Ges * P / 4 * II * Rf**2     (2)
                                                               II



                                                                      1.929 Watts/meters**2
                                                                      0.193 mWatts/cm**2



2.   Near Field Calculation

Power flux density is considered to be at a maximum value throughout the
entire length of the defined Near Field region.   The region is contained
within   a cylindrical volume having  the same diameter  as   the antenna.
Past the   boundary of the Near Field region the power density from the
antenna   decreases  linearly with    respect  to  increasing    distance.

The distance to the end of the Near Field can be determined from the
following equation: (3)

     Extent of the Near Field, (Rn)         D*+*2 / (4 * lambda)                                  (3)
                                       4i




                                             17.1 meters
                                       11




The maximum power density in the Near Field can be determined from the
following equation: (4)

     Near Field Power Density, (Wn)         16.0   *   n *    P /     II   * D**2                 (4)
                                             4.504 Watts/meters*®*2
                                             0.450 mWatts/cm**2


                                                                                 EXHIBIT B
                                                                                 Page 3 of 5

3.     Transition Region Calculations

The Transition region    is located between the Near and Far Field regions.
The power density begins     to decrease linearly with increasing    distance
in   the  Transition region.   While  the power density decreases inversely
with   distance in   the  Transition  region,   the power  density decreases
inversely with     the square of  the distance in the Far Field region.   The
maximum power density     in  the Transition   region will   not  exceed that
calculated   for   the Near  Field region.   The power density calculated in
Section 1 is   the highest power density   the antenna can produce in any of
the regions   away from the antenna.    The power density at a    distance Rt
can be determined from the following equation: (5)

       Transition region Power Density, (Tt)          Wn * Rn / Rt                             (5)
                                                       0 .450 mWatts/om**2


4.     Region between Feed Assembly and Antenna Reflector

Transmissions  from  the feed assembly are   directed toward  the  antenna
reflector surface, and are confined within a conical shape defined by  the
type     of    feed assembly.   The most   common      feed assemblies are         waveguide
flanges, horns or subreflectors.  The energy between the feed assembly and
reflector surface  can be  calculated by determining the power density at
the     feed   assembly surface.    This   can   be     determined from the following
equation: (6)

       Power Density at Feed Flange, (Wf)        4 * P / Fa                                    (6)
                                                  30.023 mWatts/cm**2


5.     Main Reflector Region

The power density in the main reflector is determined in the  same manner
as the power density at the feed assembly.   The  area is now the area of
the reflector aperture   and can be   determined  from   the    following
equation: (7)

       Power Density at the Reflector Surface, (Ws)          4    *   P /   Sa                 (7)
                                                                 6.755 Watts/meters**2
                                                                 0.676 mWatts/cm**2


6.     Region between Reflector and Ground

Assuming uniform illumination of the reflector surface, the power density
between  the antenna  and ground  can be determined    from the following
equation: (8)

       Power Density between Reflector and Ground, (Wg)               P / Sa                 (8)
                                                                 It




                                                                       1.689 Watts/meters*®*2
                                                                 it




                                                                       0.169 mWatts/cm**2
                                                                 it


                                                                           EXHIBIT B
                                                                           Page 4 of 5


Table 4.      Summary of Expected Radiation levels for Uncontrolled Environment

                                      Calculated Maximum Radiation
                                           Power Density Level
     Region                                 (mWatts/cm**2)         Hazard Assessment


1.   Far Field    (Rf)     = 41.0 meters         0 .193                Satisfies FCC MPE

2. Near Field      (Rn)    = 17.1 meters         0 .450                Satisfies FCC MPE

3.   Transition Region
     Rn < Rt < Rf, (Rt]                          0 .450                Satisfies FCC MPE

4. Between Feed Assembly                         30 .023               Potential Hazard
   and Antenna Reflector

5. Main Reflector                                0 .676                Satisfies FCC MPE

6.   Between Reflector                           0 .169                Satisfies FCC MPE
     and Ground




Table 5.      Summary of Expected Radiation levels for Controlled Environment

                                      Calculated Maximum Radiation
                                           Power Density Level
     Region                                 {mWatts/cm**2)         Hazard Assessment


1.   Far Field    (Rf)     = 41.0 meters         0 .193                Satisfies FCC MPE

2. Near Field      (Rn)    = 17.1 meters         0 .450                Satisfies FCC MPE

3.   Transition Region
     Rn < Rt    < Rf,    (Rt)                    0 .450                Satisfies FCC MPE

4.   Between Feed Assembly                       30 .023               Potential Hazard
     and Antenna Reflector

5.   Main Reflector                              0 .676                Satisfies FCC MPE

6. Between Reflector                             0 .169                Satisfies FCC MPE
   and Ground




It  is  the       applicant‘s   responsibility     to      ensure  that  the  public and
operational       personnel   are  not exposed     to      harmful  levels of radiation.


                                                            EXHIBIT B
                                                            Page 5 of 5




7.   Conclusions




Based on   the above  analysis  it   is concluded that  harmful levels of
radiation will  not exist in regions   normally occupied by the public or
the earth station‘s operating personnel.   The transmitter will be turned
off during antenna maintenance so that   the FCC MPE of 5.0 mW/cm**2 will
be complied with for those regions with close proximity to the reflector
that exceed acceptable levels.


Aloha Networks, Inc.
FCC Form 442—Filing Document




                                      Exhibit C

                   Demonstration of Compliance with FCC Rules


Aloha Networks, Inc. seeks authority pursuant to Section 25.209(e) of the Commission‘s
Rules, 47 C.F.R § 25.209(e), to operate a VSAT earth station antenna ranging from 0.45
to 1.2 meter in diameter. The antennas are the Channel Master 0.45m, 0.60m, 0.75m,
1.0m, and a 1.2 meter offset antenna system. As required by the rules attached are the
following: (1) Exhibit D — Engineering analysis showing compliance with the two degree
spacing policy for sub—meter VSAT antennas; (2) Exhibit E — Manufacturer antenna
patterns for Mid Frequency Bands.




                                                                       Exhibit C —Page 1 of 1
                                                                          September 4, 2001


Aloha Networks, Inc.
FCC Form 442—Filing Document



             Exhibit D; _2° Adjacent Satellite — Technical Analysis




Table of Contents


1.0     Purpose


2.0     Azimuth Axis System Performance
2.1     Antenna Performance in the Azimuth Axis
2.2     Uplink Flange Density and Off—Axis EIRP Density
2.3      Conclusion


Table 1: VSAT Uplink Flange and EIRP Density to 2° Adjacent Satellites


3.0     Elevation Axis System Performance
3.1     Antenna Performance in the Elevation Axis (Table 2)
3.2     Uplink Flange Density and Off—Axis EIRP Density
3.3     ITU Recommendation
3.4     Existing HNS Elliptical Antennas
3.5     Conclusion




1.0     Purpose


                                                               Exhibit D — Page 1 of 8
                                                                   September 4, 2001


Aloha Networks, Inc.
FCC Form 442—Filing Document




This Exhibit will provide the technical analysis showing the performance of the Channel
Master antennas (0.45, 0.60, 0.75, 1.0, and 1.2 meter) and space system transmission

characteristics are compliant with the Commission‘s two degree (2 °) spacing policy.
This Exhibit will show the adjacent satellite interference caused by transmissions from
the Channel Master antenna (0.45 to 1.2—meter) will be no greater than an antenna
compliant with the combined 47 C.F.R. § 25.209 and 25.212 for uplink EIRP density
interference towards adjacent satellites spaced at two degree intervals of longitude in the
azimuth axis and for proposed NGSO systems in the elevation axis.




2.0     Azimuth Axis System Performance


Exhibit E (Antenna Patterns) provides the measured performance data for the Channel
Master 0.45, 0.60, 0.75, 1.0, and 1.2 meter antenna referenced in this Exhibit.


2.1     Antenna Performance in the Azimuth Axis
The measured data indicates that the 0.45, 0.60, 0.75, 1.0, and the 1.2 meter antenna are
not compliant with the antenna pattern envelope specified in 47 C.EF.R. § 25.209(a) from
1° to 1.7° for the azimuth axis. However, the Channel Master antennas will meet the
29—25Log(O) specifications between 1.7° and 7° rather than 1.25° and 7° as specified in
47 C.F.R. § 25.209(g) for small antennas operating in the 12/14 GHz Band (Domestic
FSS Ku—Band).


Domestic FSS Ku—Band satellites are spaced at 2° intervals of longitude with respect to
the center of the earth. However, the angular separation of the satellites as viewed by
earth stations from the surface of the earth is nominally 2.3 °. Therefore, the antenna‘s
compliance with the FCC requirements for angles 1.7° and greater will provide the
required interference isolation performance toward adjacent satellites.




                                                                          Exhibit D — Page 2 of 8
                                                                              September 4, 2001


Aloha Networks, Inc.
FCC Form 442—Filing Document

The Channel Master antennas referenced above are designed to use feeds to support
either of the following configurations:


                 1) a single FSS (transmit/receive) satellite
                2) a combination of FSS (transmit/receive) and BSS (receive only DBS)
                       satellites in the mode where the antenna will only transmit and receive
                       using a single FSS satellite, the satellites to be used for this operation
                       are domestic satellites (assume to be full domestic arc).


2.2     Uplink Flange Density and Off—Axis EIRP Density


Combining 47 C.F.R. § 25.209 (Antenna performance standards) and 25.212 (Narrow—
Band Transmissions in the Fixed—Satellite Services) provides the maximum EIRP density
a digital VSAT earth station can transmit toward an adjacent satellite. 47 C.F.R. §
25.209(a) determines the maximum acceptable VSAT earth station transmit antenna gain
toward the adjacent satellite as follows:


Maximum Transmit Antenna Gain at 2° = 29—25*Logi,(2°) dBi = 21.5 dBi


47 C.F.R. § 25.209© specifies a maximum acceptable digital VSAT earth station uplink
power density at the antenna transmit flange of —14 dBW/4 kHz. Therefore, the
maximum adjacent satellite interference (ASI) EIRP density can be determined by
combining 47 C.F.R. § 25.209(a) and 25.212(c) in the following formula:
Maximum ASI EIRP Density = Max. Transmit Antenna Gain at 2° + Max.


Transmit Power Density at Antenna Flange = 21.5 dBi + (—14 dBW/4 kHz)
                                                 =7.5 dBW/4 kHz


The following table provides the uplink flange density and EIRP density toward the two—
degree adjacent satellites for all Aloha Networks proposed remote antenna system
transmit data rates, modulation, transmit power, and bandwidth. A transmission line loss


                                                                              Exhibit D — Page 3 of 8
                                                                                   September 4, 2001


Aloha Networks, Inc.
FCC Form 442—Filing Document

of 0.2 dB between the HPC (transmit HPA) and the antenna flange and the gains of each
remote antenna at 2° boresight are used in calculating the uplink flange density and EIRP
density.


2.3      Conclusion



Section 2 of this Exhibit showed that each of the remote antenna (0.45, 0.60, 0.75, 1.0,
and 1.2 meter) are compliant with the 47 C.F.R. § 25.209 antenna pattern envelope in the
direction of the adjacent satellites spaced at two degrees from the space satellite. The
table in this Exhibit indicates in all transmission cases the uplink flange density is below
the maximum specification of —14 dBW/4 kHz (47 C.F.R. § 25.212{c}). Also, the EIRP
density in the direction of the adjacent satellites at two degrees of separation will be
below the +7.5 dBW/ 4 kHz maximum EIRP density criteria for adjacent satellite
interference required by the combination of 47 C.F.R. § 25.209 and 25.212. Therefore,
for the critical adjacent satellite interference specification of EIRP density at two degrees
from boresight, the remote antennas to be use by Aloha Networks, Inc. will provide
performance equivalent to an antenna that is compliant with applicable 47 C.F.R. § 25
rules.




                                                                          Exhibit D — Page 4 of 8
                                                                              September 4, 2001


Aloha Networks, Inc.
FCC Form 442—Filing Document




                       Table 1: Aloha Networks VSAT Uplink Flange and EIRP Density to 2° Adjacent Satellites

                                                ***HPC to Antenna Loss: 0.2 Db***




                                                                                                               Exhibit D — Page 5 of 8
                                                                                                                   September 4, 2001


Aloha Networks, Inc.
FCC Form 442—Filing Document

3.0     Elevation Axis System Performance


The reflectors of the remote antennas are elliptically shaped. The antenna performance in
the elevation axis is not a concern for the current Ku—Band geostationary (GEO) satellites
but is a potential concern for proposed non—geostationary (NGSO) satellite systems which
desire to use the same frequency band as the domestic US FSS Ku—Band used by Aloha
Networks‘ VSAT networks. This section will address the interference into NGSO
systems from the referenced Channel Master Remote Antenna elevation axis.


3.1     Antenna Performance in the Elevation Axis



As seen in Exhibit E (Antenna Patterns), the remote antennas transmit performance in the
elevation axis are compliant with the 47 C.F.R. § 25.209 antenna pattern specification 32—
25*Logi,(O) dBi starting at 2.5 degrees off boresight. Also from Exhibit E, at two
degrees from boresight the gains of the 0.45 and 0.60—meter antennas are 31.7 and 27.2
dBi while 47 C.F.R. § 25.209 provides for an antenna gain of 24.5 dBi at two degrees, a
difference of 7.2 dB for the 0.45m remote antenna and 2.7 dB for the 0.60m remote
antenna.



                       Table 2: Antenna Gains @ 2° off Boresight (dB)




                                                                       Exhibit D — Page 6 of 8
                                                                           September 4, 2001


Aloha Networks, Inc.
FCC Form 442—Filing Document

3.2     Uplink Flange Density and Off—Axis EIRP Density


The table (table 1) in this Exhibit indicates the maximum uplink flange density to be used
for carrier transmission from the remote antennas is —25 dBW/4 kHz rather than the
maximum allowable —14 dBW/4 kHz under 47 C.F.R. § 25.212 for narrow and/or
wideband digital services. Therefore, the EIRP density at two degrees off boresight in
the elevation axis will be the combination of the antenna performance and the maximum
uplink flange density which equates to the following:


                EIRP Densi       2 off Boresight in the elevation axis
                a) 0.45 m:     31.7 dBi + (— 25 dBW/4 kHz) = 6.7 dBW/4 kHz
                b) 0.60 m:     27.2 dBi + (— 25 dBW/4 kHz) =2.2 dBW/4 kHz
                c) 0.75 m:     24.1 dBi + (— 25 dBW/4 kHz) =— 0.9 dBW/4 kHz
                d) 1.0 m:      13.3 dBi + (— 25 dBW/4 kHz) =— 11.7 dBW/4 kHz
                f) 1.2 m:      12.3 dBi + (— 25 dBW/4 kHz) =— 12.7 dBW/4 kHz


Also specified in 47 C.F.R. § 25.212 is the uplink flange density limit for narrow—band
analog carriers. For these carriers the uplink flange density limit is —8 dBW/4 kHz. This
is 6 dB higher than the digital service limit. Since the FSS Ku—Band is used by both
analog and digital services the NGSO systems will need to be designed for the worst case
analog FSS densities. Combining 47 C.F.R. § 25.209 and 25.212 for analog services the
maximum off—axis EIRP density at two degrees in the elevation axis is:


Max. Elevation Axis EIRP Density at 2° = 32—25Log(2")+(—8 dBW/4 kHz)
                                                        = 16.5 dBW/4 kHz
Therefore, the narrow—band analog off—axis EIRP density at 2° is 16.5 dBW/4 kHz which
is 9.8 dB higher than the 6.7 dBW/4 kHz maximum EIRP density.




3.3     ITU Recommendation


                                                                         Exhibit D — Page 7 of 8
                                                                             September 4, 2001


Aloha Networks, Inc.
FCC Form 442—Filing Document



The ITU is working to provide recommended off—axis power density specifications for
the operation of proposed NGSO systems using the same frequency band as the Region 2
FSS Ku—Band (11.7 to 12.2 GHz space to earth and 14.0 to 14.5 GHz earth to space) as
Aloha Networks VSAT networks plans to utilize. Chapter 3 of the latest ITU CPM
Report, prepared by the ITU for the WRC—2000, indicates that the off—axis EIRP density
levels allowed are much less stringent than the combined levels from 47 C.E.R. § 25.209
and 25.212 (by over 10 dB). ITU—R document $.524 also discusses this issue as well. In
the ITU documents, there are different levels specified for different carrier types, the FM—
TV levels being over 11 dB more permissible.


3.4     Existing HNS EKlliptical Antennas


Hughes Networks Systems (HNS) has an existing FCC license (call sign E900682) which
includes an antenna with a dimension of 46 cm in the elevation axis compared to the
higher dimensions for the Aloha Networks remote antennas. Therefore, there is already a
licensed antenna with similar, and most likely worse, antenna pattern performance in the
elevation axis. The HNS application indicates the maximum uplink flange density, which
will be used with this antenna, is the maximum allowable in 47 C.F.R. § 25.212 of —14
dBW/4 kHz. HNS has deployed elliptical shaped VSAT antennas at many of its
customer‘s sites including thousands of US based installations at Mobile gas stations.


3.5     Conclusion



For future NGSO system interference concerns, the Aloha Networks remote antenna
applications will have off—axis EIRP density performance below currently operational
FSS systems, FSS maximum limits and the ITU recommendations.




                                                                        Exhibit D — Page 8 of 8
                                                                            September 4, 2001


Aloha Networks, Inc.
FCC Form 442—Filing Document

                                    Exhibit E


                   Antenna Patterns for Channel Master Antennas


                          Transmit Mid Frequency Bands




                                                              Exhibit E—Page 1 of 1
                                                                 September 4, 2001


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Aloha Networks, Inc.
FCC Form 442—Filing Document




                                                Exhibit G
                                     Testing Program Description


Aloha Networks, Inc. is a VSAT network supplier which has developed advanced
commercial VSAT services using the ALOHA access protocol. Aloha Networks has
developed Spread ALOHA ® Multiple Access (SAMA*"), a spread—spectrum multiple
access technology that overcomes the current bottleneck in two—way digital wireless communication
networks by providing an improved access methodology required for
very large numbers of remote users. Aloha would like to perform some system testing in
order to determine the operational viability of their new spread—spectrum based
transmission scheme using sub—meter remote facilities.

Aloha proposes to employ a 4.5 meter hub earth station and VSAT terminals employing
antennas ranging in size from 45 cm to 1.2 meters as remotes. Initially the hub and
remotes will be collocated at their facilities in San Francisco, CA. Eventually up to 50—
250 antennas will be located at positions in the continental United States (CONUS) to
examine the impact of multiple remote users distributed across the country. Aloha
believes there VSAT network access architecture and RF design will allow for sub—meter
remote terminals however they would like to ensure proper system performance prior to
launch of a commercial version on this product. Using a moderately large number of
distributed remote terminals over a several month period will allow Aloha Networks to
accurately analyze the product‘s performance and identify the feasibility of certain
remote configurations and assist in the optimization of the design.




                                                                                    Exhibit G — Page 1 of 1
                                                                                         September 4, 2001



Document Created: 2001-09-07 17:21:33
Document Modified: 2001-09-07 17:21:33

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