Narrative Regarding Extension of Experimental STA

0351-EX-ST-2003 Images

Aloha Networks, Inc.

2003-09-19ELS_63007

                                                                  APPLICATION OF
                                                             ALOHA NETWORKS, INC.

                                                                                EXHIBIT A

               EXPLANATION REGARDING EXTENSION OF
          EXPERIMENTAL SPECIAL TEMPORARY AUTHORIZATION

      Aloha Networks, Inc. ("Aloha") respectfully requests an extension of its
Experimental Special Temporary Authorization ("STA") to continue operating Station
WBIXNQ for an additional 180 days.

       As more fully explained in Exhibit A to Aloha‘s original request for STA, Aloha has
developed advanced commercial VSAT services using the ALOHA access protocol. See File
No. 0327—EX—ST—2001. Aloha has been using its STA to conduct system testing to ensure
proper system performance prior to launch of a commercial version of this product. As
discussed in Exhibit A to Aloha‘s original STA request, Aloha proposed initially to employ
a 4.5 meter hub earth station and VSAT terminals with antennas ranging in size from 45
cm to 1.2 meters as remotes collocated at its facilities in San Francisco, California, and
eventually to locate 50—250 antennas at positions in the Continental United States
(CONUS). Using a moderately large number of distributed remote terminals over an
extended period has allowed Aloha to analyze the product‘s performance and identify the
feasibility of certain remote configurations, and has assisted in the optimization of the
design as necessary for the operations contemplated.

       Based on its initial test results using its Experimental STA, Aloha anticipated that it
would seek a permanent license from the Commission for its operations early this year.
Notwithstanding the encouraging results of Aloha‘s initial tests, Aloha re—evaluated the
system and determined that a 9.2—meter hub earth station antenna, rather than a 4.5 meter
antenna, is preferable for Aloha‘s long term operations. The 9.2—meter hub station antenna
that Aloha used to conduct the additional testing of its system is licensed to SES
Americom, Inc. under call sign E920698 and is located at 2823 Grimville Road,
Woodbine, Carroll County, Maryland (39—22—33 North Latitude / 77—4—54 West
Longitude). Accordingly, Aloha needed to conduct additional testing to ensure that its
business plan would operate successfully. Aloha now has an application on file with the
ECC for a permanent license (Application id: 1B2003001867). Aloha seeks an extension of
its Special Temporary Authority to permit Aloha to continue its operations while its
permanent license application is pending.

       Aloha has expended considerable financial resources in connection with its system
testing and planned permanent operations, much or all of which will be lost if its
Experimental STA is not extended. Therefore, for good cause shown, Aloha respectfully
requests that the Commission extend Aloha‘s Experimental STA for an additional 180—day
period to allow the Commission time to analyze and approve its application.




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Document Created: 2019-02-15 15:13:37
Document Modified: 2019-02-15 15:13:37

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