Attachment 82499 Application fo

This document pretains to SAT-LOA-19941116-00088 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA1994111600088_973559

                                                          UNITED STATES DEPARTMENT OF COMMERCE
                                                          National Telecommunications and
                                                          Information Administration
                                                          Washington, D.C. 20230

                                                               August 24, 1999



                                                           RECEIVEE
Ms. Magalie Roman Salas                                                    ns
Secretary                                                      AVG 2 4 1999 :
Federal Communications Commission
                                                        FEDERAL COMMUNICATIONS COMMIZGSH °.
1919 M Street, N.W.                                          emce 8 Tat SEcarinin             :       z.
Room 222                                                                                 s3       4
Washington, DC 20554

        RE:    Application for Review and Clarification, Final Analysis Communications Services, Inc.,
               File Nos.25—SAT—P/LA—95,76—SAT—AMEND—95,
               79—SAT—AMEND—96. 151—SAT—AMEND—96, 7—SAT—AMEND—97

Dear Ms. Salas:

Enclosed you will find an two copies of the letter from William T. Hatch, Acting Associate
Administrator, National Telecommunications and Information Administration, to Nader
Mondanlo, Chairman and President of Final Analysis Communications Services, regarding the
above—referenced proceeding. A copyof this letter was hand—delivered to Don Abelson, Chief of
the International Bureau, and Tom Tycz, Chief of the Satellite and Radiocommunications
Division, International Bureau. As indicated in the Certificate of Service, the other parties to the
proceeding have also been served.

Please direct any questions you may have regarding this filing to the undersigned. Thank you for
your cooperation.

                                                      Respectfully submitted,


                                                    1’"/
                                                       (/ /\,/
                                                            k,//A/V(/
                                                      I\\&thy D. Smlth
                                                      Acting Chief Counsel

Enclosures


                                                          UNITED STATES DEPARTMENT OF COMMERCE
                                                          National Telecommunications and
                                                          Information Administration
                                                          Washington, D.C. 20230



                                                                        AUG 2 4 1999


Mr. Nader Modanlo
Chairman and President
                                         x     ~.                     RECEIVEp
                                             ie
Final Analysis Communication Services
9701—E Philadelphia Court                                                AUG 2 4 1999
Lanham, MD 20706—4400                                             Fabahat. communicanons CoMMIsgey
                                                                       erPcE oF ThE secaetary
Dear Mr. Modanlo:

I received your letter of July 19, 1999 and I am concerned that you have misunderstood our letter
of July 8 responding to your request to begin technical coordination on your proposed, but not
licensed, system. You have not correctly interpreted the Government‘s requirements for systems
operating on a timeshared basis with government systerms. It was not our purpose to restate the
requirements laid out in FCC rules or the provisions of your license in response to your request to
initiate post—license coordination. We, of course, are aware of your opposition to certain aspects
of your license. Because of its importance to post—license coordination, we note in your letter
that you are committed to fully comply with FCC‘s Rules in Section 25.259(b) and (c). As we
stated in our letter, compliance with these rules, as well as paragraph 39 of your license, with
practical implementation measures, including monitoring, is of critical concern to us to ensure
the continued viability of the NOAA satellite system.

As we have stated before, the FCC has all of the information it needs to make its decision on
your license. We appreciate your interest in resolving your license with the FCC as soon as
possible so that we can begin post—license coordination. Until the FCC concludes this matter, we
see no benefit to our continued debate on these questions, a debate which may itself be causing
delay in the FCC reaching its decision.

                                                     Sincerely,

  >       ,                                          J///A@W
                                                     William T. Hatch
                                                     Acting Associate Administrator
                                                     Office of Spectrum Management

cc: Don Abelson, Chief, International Bureau


                                CERTIFICATE OF SERVICE

I, Teresa Goode, do hereby certify that a copy of the foregoing Letter from the National
Telecommunications and Information Administration was hand—delivered (*) or sent via first
class United States mail, on this 24" day of August, 1999, to the following:

Mr. Nader Modanlo                                         Aileen Pisciotta, Esq.
Chairman and President                                    Peter A. Batacan, Esq.
Final Analysis Communications Services                    Kelly, Drye & Warren, LLP
9701—E Philadelphia Court                                 1200 — 19°" Street, N.W.
Lanham, MD 20706—4400                                     Suite 500
                                                          Washington, DC 20554
Mr. Don Abelson*
Chief, International Bureau                               Robert A. Mazer, Esq.
Federal Communications Commission                         Vinson & Elkins
The Portals                                               1455 Pennsylvania Avenue, N.W.
445 Twelfth Street, S.E.                                  Washington, DC 20004—1008
Washington, DC 20554
                                                          Stephen Goodman, Esq.
Mr. Tom Tycz*                                             Halprin, Temple & Goodman
Chief, Satellite & Radiocommunication                     1100 New York Avenue, N.W.
 Division                                                 Suite 650 East
International Bureau                                      Washington, DC 20005
Federal Communications Commission
The Portals                                               Henry Goldberg, Esq.
445 Twelfth Street, S.E.                                  Joseph Godles, Esq.
Washington, DC 20554                                      Mary Dent, Esq.
                                                          Goldberg, Godles, Wiener & Wright
Mr. Nelson Pollack                                        1229 — 19" Street, N.W.
AFFMA                                                     Washington, DC 20036
4040 North Fairfax Drive
Suite 204                                                 Leslie Taylor, Esq.
Washington, DC 22203—1613                                 Leslie Taylor Associates, Inc.
                                                          6800 Carlynn Court
Mr. Richard Barth                                         Bethesda, MD 20817—4302
U.S. Department of Commerce
National Oceanic and Atmospheric
 Administration
Office of Radio Frequency Management
Room 2246, SSMC—2                *
1325 East West Highway
Silver Spring, MD 29010
                                              W|
                                                    Teresa Goode


                                                      OF



                                           NQ\“                       UNITED STATES DEPARTMENT OF COMMERCE
                                            % &                       National Telecommunications and
                                           %‘e,               C       Information Administration
                                                  Stares of           Washington, D.C. 20230



                                          LCl _                                      AUG 2 4 1999
                                                           :‘«
Mr. Nader Modanlo                         on We                                            .
Chairman and President                      it                                     HECE,VED                       ~
Final Analysis Communication Services                  OE
9701—E Philadelphia Court                                                             AUG 2 4 1999
Lanham, MD 20706—4400                                                          FED&RAL communscanons COMMIRGe::
                                                                                    OPRCE 0F THE sEcaEtary    '
Dear Mr. Modanlo:

I received your letter of July 19, 1999 and I am concerned that you have misunderstood our letter
of July 8 responding to your request to begin technical coordination on your proposed, but not
licensed, system. You have not correctly interpreted the Government‘s requirements for systems
operating on a timeshared basis with government systems. It was not our purpose to restate the
requirements laid out in FCC rules or the provisions of your license in response to your request to
initiate post—license coordination. We, of course, are aware of your opposition to certain aspects
of your license. Because of its importance to post—license coordination, we note in your letter
that you are committed to fully comply with FCC‘s Rules in Section 25.259(b) and (c). As we
stated in our letter, compliance with these rules, as well as paragraph 39 of your license, with
practical implementation measures, including monitoring, is of critical concern to us to ensure
the continued viability of the NOAA satellite system.

As we have stated before, the FCC has all of the information it needs to make its decision on
your license. We appreciate your interest in resolving your license with the FCC as soon as
possible so that we can begin post—license coordination. Until the FCC concludes this matter, we
see no benefit to our continued debate on these questions, a debate which may itself be causing
delay in the FCC reaching its decision.

                                                                  Sincerely,

                                                                  c/////«éw
                                                                  William T. Hatch
                                                                  Acting Associate Administrator
                                                                  Office of Spectrum Management

cc: Don Abelson, Chief, International Bureau


                                CERTIFICATE OF SERVICE

I, Teresa Goode, do hereby certify that a copy of the foregoing Letter from the National
Telecommunications and Information Administration was hand—delivered (*) or sent via first
class United States mail, on this 24"" day of August, 1999, to the following:

Mr. Nader Modanlo                                         Aileen Pisciotta, Esq.
Chairman and President                                    Peter A. Batacan, Esq.
Final Analysis Communications Services                    Kelly, Drye & Warren, LLP
9701—E Philadelphia Court                                 1200 — 19 Street, N.W.
Lanham, MD 20706—4400                                     Suite 500
                                                          Washington, DC 20554
Mr. Don Abelson*
Chief, International Bureau                               Robert A. Mazer, Esq.
Federal Communications Commission                         Vinson & Elkins
The Portals                                               1455 Pennsylvania Avenue, N.W.
445 Twelfth Street, S.E.                                  Washington, DC 20004—1008
Washington, DC 20554
                                                          Stephen Goodman, Esq.
Mr. Tom Tycz*                                             Halprin, Temple & Goodman
Chief, Satellite & Radiocommunication                     1100 New York Avenue, N.W.
 Division                                                 Suite 650 East
International Bureau                                      Washington, DC 20005
Federal Communications Commission
The Portals                                               Henry Goldberg, Esq.
445 Twelfth Street, S.E.                                  Joseph Godles, Esq.
Washington, DC 20554                                      Mary Dent, Esq.
                                                          Goldberg, Godles, Wiener & Wright
Mr. Nelson Pollack                                        1229 — 19" Street, N.W.
AFFMA                                                     Washington, DC 20036
4040 North Fairfax Drive
Suite 204                                                 Leslie Taylor, Esq.
Washington, DC 22203—1613                                 Leslie Taylor Associates, Inc.
                                                          6800 Carlynn Court
Mr. Richard Barth                                         Bethesda, MD 20817—4302
U.S. Department of Commerce
National Oceanic and Atmospheric
 Administration
Office of Radio Frequency Management
Room 2246, SSMC—2                  *


                                              Pn
1325 East West Highway
Silver Spring, MD 29010

                                                    Teresa Goode



Document Created: 2012-11-02 11:38:46
Document Modified: 2012-11-02 11:38:46

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