Narrative Statement

0013-EX-CM-2016 Text Documents

Amazon Robotics LLC

2016-09-06ELS_181603

                                                                 Amazon Robotics LLC
                                                         Application for Modification of
                                                    FCC Experimental License WH2XZJ
                                                       OET File No. 0013-EX-CM-2016


                                   NARRATIVE STATEMENT

         Pursuant to Sections 5.3 (e) and (f), Section 5.51 and Section 5.53 of the Federal
Communications Commission (“FCC”) rules, 47 C.F.R. §§ 5.3 (e) & (f), 5.51, 5.53
(2015), Amazon Robotics LLC respectfully requests a modification of its experimental
license issued under call sign WH2XZJ (with radio station code “XE” i.e., for
Experimental Export) to operate in the 433 MHz band at an additional location for the
purpose of evaluating the performance and functionality of a prototype proximity sensing
system. This system will be deployed only within Amazon fulfillment centers in other
countries which specify 433 MHz as an unlicensed band. Specifically, by this
modification application, Amazon Robotics seeks to conduct supplemental tests at an
affiliated subsidiary’s premises, located at 1800 140th Ave East, Sumner, Washington.

         The following provides additional details regarding this request.

A.       Purpose of Operation and Need for Experimental License:

        Amazon Robotics is designing and developing a proximity sensing system to
enhance the safety of the operations at its fulfillment centers. Under its existing
experimental license, Amazon Robotics has been evaluating radiolocation technology to
be used in the operation of robotics in fulfillment centers outside the United States. The
experiments have been conducted at company facilities that have been configured with a
10 meter x 10 meter test floor mock-up of a typical environment inside a fulfillment
center, which mainly consists of rack storage units where robotic equipment moves under
and among the racks. The tests have involved turning on prototype transmitters and
measuring the received signal strengths as the robotic equipment moves around on the test
floor. Amazon Robotics has conducted tests of different transmit power levels, transmitter
heights, and transmitter orientations.

B.       Location of Proposed Operations:

        As noted above, by this modification application, Amazon Robotics seeks
authority to conduct additional experiments at the facilities of a subsidiary affiliated with
Amazon Robotics. The address and coordinates of the additional location are provided
below:

         Additional Location                       Current Location
             1800 140th Ave East                    300 Riverpark Drive
             Sumner, WA 98390                       North Reading, MA 01864

             Coordinates (NAD83): 47°14'27"N        Coordinates (NAD83): 42°33'19"N
                                 122°14'36"W                             71°07'55"W



13893507.5


C.       Technical Specifications:

         1.     Frequencies Desired

                Amazon Robotics requests an experimental license to operate on channels
                within the band 433.050 to 434.790 MHz.

         2.     Effective Radiated Power

                The maximum effective radiated transmit power will be 10 milliwatts. The
                antenna heights will vary from ground level to a maximum of 6 feet (i.e.,
                the height of an average person).

                In addition, Amazon Robotics will evaluate environmental considerations
                to ensure compliance with Section 1.1307 of the FCC’s rules, 47 C.F.R.
                § 1.1307 (2015).

         3.     Modulation and Emissions
                The primary emission designator for the experimental operations is
                200KD7D. Other emission modes may be utilized, but in no event will
                the emissions extend beyond the frequency band requested.

         4.     Equipment To Be Used

                Equipment Type:               Prototype Equipment
                Manufacturer:                 Amazon Robotics LLC
                No. of Portable Units:        100 at the current location
                                              475 at the proposed, additional location
                No. of Receive Units          100 at the current location
                                              475 at the proposed, additional location

         5.     Antenna Information

                As noted above, the antenna heights will vary from ground level to a
                maximum of 6 feet. If deployed within an existing building, the antennas
                will not extend more than 6 meters above the building. If an antenna is
                mounted on an existing structure other than a building, it will be installed
                in accordance with Federal Aviation Administration (“FAA”) and FCC
                rules and regulations.




13893507.5


D.       Restrictions on Operation:

        Amazon Robotics does not propose to market, sell, or lease prototype equipment
to end users in the United States. As noted above, the company is designing the
equipment for its own internal company use outside the United States. Moreover, after
the experimentation ceases, it will recover all unauthorized devices.

        Amazon Robotics also recognizes that other stations may be licensed on these
frequencies and that the proposed experimental operation must not cause harmful
interference to authorized facilities. It does not anticipate a problem, but should
interference occur, it will immediately take steps to resolve the interference, including if
necessary immediate shut down and the discontinuance of operation.

        Amazon Robotics will also advise entities involved in the experimentation that
permission to operate the equipment has been granted under experimental authority
issued to Amazon Robotics, is strictly temporary and may be canceled at any time, and
that any unauthorized equipment may not be and may not be, offered for sale or lease, or
sold or leased, until authorization is obtained.

E.       Public Interest Statement:

        Amazon Robotics submits that grant of its application to modify its experimental
license as proposed is in the public interest, convenience, and necessity. Such action will
permit it to develop innovative equipment that will allow the company to enhance the
safety of the operations at its fulfillment centers outside the United States.

F.       Contact Information:

         For questions about this modification application, please contact:

                Michael Lewis
                Wiley Rein LLP
                1776 K Street, N.W.
                Washington, DC 20006
                Telephone: (202) 719-7338
                Email: mlewis@wileyrein.com

       In the unlikely event interference concerns should arise in connection with the
operations authorized under the requested experimental license, please contact:

                Joe Finlayson
                Director, Regulatory Compliance
                Amazon Robotics LLC
                300 Riverpark Drive
                North Reading, MA 01864
                Telephone: (978) 276-2815
                Email: jfinla@amazon.com



13893507.5



Document Created: 2016-09-06 12:19:14
Document Modified: 2016-09-06 12:19:14

© 2025 FCC.report
This site is not affiliated with or endorsed by the FCC