Progress Report (May 20, 1997)

4682-EX-PL-1995 Post Grant Documents

FINAL ANALYSIS, INC.

2000-04-12ELS_34946

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                                      KELLEY DRYE & WARREN Lir
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  TOKYO, JAPAN                                        May 20, 1997
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       Federal Communications Commission
       Experimental Radio Services
       P.O. Box 358320
       Pittsburgh, PA 15251—5320
       ATTN:              Mr. Douglas A. Young
                          Office of Engineering & Technology

                         Re:    Final Analysis, Inc. Applications for Renewal of Experimental Little
                                LEO Authorizations for: FAISAT—2v Little LEO Satellite (Call Sign
                                KS2XCY, File No. 4682—EX—PL—95); Remote Terminals (Call Sign
                                KS2XCZ, File No. 4683—EX—PL—95); and Logan, (Cache) UT Ground
                                Station (Call Sign KS2XDA, File No. 4684—EX—PL—95).

       Dear Mr. Young:

                      Final Analysis, Inc., by its attorneys, hereby submits its applications for
       renewal of the above—captioned authorizations for its experimental non—voice non—
       geostationary mobile satellite service ("NVNG MSS" or "Little LEO") operations. Renewal
       is requested for the following components of the experimental program: (i) Little LEO
       satellite ("FAISAT—2v");* (ii) 350 remote user terminals;* and (iii) a ground station in




            ‘ See Final Analysis, Inc., Experimental Radio Station Construction Permit and
       Authorization, Call Sign KS2XCY (File No. 4682—EX—PL—95) issued August 11, 1995,
       expires August 1, 1997 (hereinafter "FAISAT—2v Authorization").

            * See Final Analysis, Inc., Experimental Radio Station Construction Permit and License,
       Call Sign KSZXCZ (File No. 4683—EX—PL—95) issued August 11, 1995, expires August 1,
       1997 (hereineafter "Remote Terminal Authorization").



       ## DCOL/BATAP/41869.41


                             KELLEY DRYE & WARREN LuP

Federal Communications Commission
May 20, 1997
Page 2



Logan, Utah.* The initial authorizations for these components will expire on August 1,
1997. Accordingly, for the reasons stated below, Final Analysis respectfully urges the
Commission expeditiously to grant the instant applications for renewal of the above—captioned
authorizations for the basic two—year experimental operating period consistent with Sections
5.55(d) and 5.63 of the Commission‘s rules, 47 C.F.R. §§ 5.55(d), 5.63.

               Grant of these renewal applications is in the public interest. A central purpose
of Final Analysis‘s experimental satellite program is to determine the ability of NVNG MSS
operations to coexist in certain frequency bands with existing users of those bands. To that
end, Final Analysis initially planned to ship FAISAT—2v to Russia for integration in Omsk,
Russia and launch as a secondary payload aboard a Cosmos rocket from the Cosmodrome in
Plesetsk, Russia by the end of the first quarter of 1997. However, unforeseen circumstances
beyond Final Analysis‘s control prevented Final Analysis from meeting the Cosmos rocket
launch on April 17, 1997. In particular, multi—agency coordination was required upon
FAISAT—2v‘s shipment to Russia between the U.S. Department of State and several Russian
government agencies including the Russian foreign ministry and the Russian space agency.*
This lengthy coordination process delayed integration of FAISAT—2v‘s components in Omsk
and prevented timely transport of the integrated satellite to Plesetsk on schedule for the April
17, 1997 launch. Nevertheless, a new launch date for FAISAT—2v aboard a Cosmos rocket
is anticipated for the third quarter of 1997 and could occur as early as June, 1997.
However, the initial authorizations for FAISAT—2v, as well as the remote user terminals and
the Logan ground station, will expire on August 1, 1997. Accordingly, grant of renewed
operating authority for an additional two—year experimental authorization period is necessary
in order to allow Final Analysis to continue and complete the experimental program pursuant
to its original goals.

             Moreover, grant of Final Analysis‘s renewal applications is consistent with the
Commission‘s rules. Consistent with Section 5.55(d) of the Rules, Final Analysis‘s


    > See Final Analysis, Inc., Experimental Radio Station Construction Permit andLicense,
Call Sign KS2XCY (File No. 4684—EX—PL—95) issued August 11, 1995, expires August 1,
1997 (hereineafter "Logan Ground Station Authorization").

     * See Final Analysis Quarterly Progress Report, filed on March 27, 1997.

    °* In light of the unexpected delay in the launch date for FAISAT—2v, Final Analysis is
unlikely to be able to complete the experiment within the limited term of continuing
operating authority that is automatically extended to a licensee upon the timely filing of a
renewal application pending Commission action on the application. Cf. 47 C.F.R. § 1.62(d).



## DCO1/BATAP/41869.41


                                               KELLEY DRYE & WARREN Lur

Federal Communications Commission
May 20, 1997
Page 3



experimental operations are in exact accordance with the terms of the existing authorizations
for FAISAT—2v, the remote user terminals and the Logan ground station.©       Furthermore,
Final Analysis‘s experimental operations are in full compliance with the Commission‘s
experimental technical standards and operating rules‘ and Final Analysis has timely
submitted all required experimental progress reports.®

               An original and two copies each of the renewal applications for the above—
captioned authorizations are enclosed. Also included with this filing are three checks in the
amount of $45.00 each made out to the Federal Communications Commission for the
appropriate filing fees (FCC Fee Code EAE). Please acknowledge receipt of this filing by
date—stamping the enclosed duplicate for return with the courier. Please do not hesitate to
contact undersigned counsel at the above—referenced number if you have any questions
regarding this matter.

                                                             Respectfully submitted,




                                                             Peter A. Batacant
                                                             Counsel for Final Analysis, Inc.




    © We note that subsequent additions to Final Analysis‘s experimental program are not
subject to the instant renewal requests. Final Analysis has added a ground station at its
corporate headquarters in Lanham, Maryland (see Experimental Radio Station Construction
Permit and License, Call Sign WA2XHE (File No. 5582—EX—PL—97) issued April 10, 1997
expires April 1, 1999) and has applied for permanent experimental authority and currently
holds special temporary operating authority with respect to an additional 148.7 MHz
frequency for telemetry, tracking and control of FAISAT—2v at its Logan, Utah ground
station (see Final Analysis, Inc. Application for Modification of Experimental Authorization
for Fixed Ground Station at Logan, Utah, Call Sign KS2XDA, File No. 4684—EX—PL—95,
filed on January 17, 1997 and Experimental Special Temporary Authorization Call Sign
KSZ2ZXDA, File No. S—2779—EX—97 issued January 21, 1997, expires on July 21, 1997).

      " See 47 C.F.R. § 5.101 et seq.

      8 See 47 C.F.R. § 5.204.
* Admitted in New York and Connecticut only.


## DCOL/BATAP/41869.41



Document Created: 2001-07-30 18:43:53
Document Modified: 2001-07-30 18:43:53

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