Narrative Statement

0512-EX-ST-2006 Text Documents

Amtech Systems LLC

2006-07-27ELS_77234

                                                                              Application for STA
                                                                             Amtech Systems LLC
                                                                               0512-EX-ST-2006

                                 NARRATIVE STATEMENT

Pursuant to Sections 5.3(d),(g), and (i) and 5.61 of the Commission’s rules, 47 C.F.R.
§§5.3(d),(g),(i), and 5.61 (2004), Amtech Systems LLC (“Amtech”) hereby respectfully requests
a special temporary authority (“STA”) to test and demonstrate prototype equipment to upgrade
its existing system. Amtech proposes to conduct the test commencing September 1, 2006.

In support of this request, the following is shown:

1)     Applicant’s Name, Address, FCC Registration Number (“FRN”):

       Amtech Systems LLC
       8158 Adams Drive
       Liberty Center, Building 200
       Hummelstown, PA 17036

       FRN: 0009732876

2)     Need for STA:

       Amtech requires special temporary authority so that it may test and evaluate prototype
       equipment. It expects that it will be able to complete its test in less than 6 months, so that
       it does not require a regular two-year license.

3)     Purpose of Operation:

       Amtech, through its affiliate TransCore Link Logistics (“TransCore”), is engaged in the
       design and development of an upgrade to its currently licensed system that will be
       introduced once the company has received all necessary regulatory and business
       approvals. The experimental authority requested herein will allow the company to test
       compliance and performance of the system and to determine the system’s acceptability.
       Such authority is required in particular so that the company may deploy and test a limited
       number of mobile earth terminals (“METs”) prior to obtaining any necessary equipment
       authorization or other appropriate approvals.

4)     System Description and Operation:

       The system is designed to provide messaging capabilities between the METs and
       customer facilities. It is comprised of hub equipment, wireline terrestrial links from the
       hub to Channel Units located at a satellite system provider land earth station (“LES”)
       facility, a channel on the satellite system that is leased from the satellite provider, and
       METs mounted on vehicles or other mobile equipment or at temporary fixed locations.


     The METs are the only new RF components of this system, and all operations under the
     trial will be conducted with the permission and under the auspices of the satellite system
     provider, Mobile Satellite Ventures (“MSV”).

     The hub is located at TransCore’s offices in Kanata, Ontario, during the trial. The
     Channel Units are located at an MSV LES in Ottawa, Ontario. These Channel Units will
     interface to MSV’s existing and separately licensed LES equipment, which will transmit
     the signal to the satellite. Internet facilities will be used to connect the Channel Units to
     the hub. The trial will be conducted over MSV’s MSAT-1 or MSAT-2 satellites at
     106.5°W and 101°W.

     The company will not collect fees or charges from users during the trial. Nor will it
     conduct market trials or provide unapproved units to consumers or the general public.

5)   Class of Station:

     Mobile. A limited number of mobiles will be located at temporarily fixed locations.

6)   Location of Proposed Operation:

     The company proposes to deploy a limited number of METs (not more than 25) that will
     operate on a mobile and temporarily fixed basis in the Eastern United States under the
     STA requested herein. Only the East Central Beam of the MSAT satellites will be used
     during the trial. The METs cannot transmit if they cannot receive a signal from the
     satellite. Thus, the operations are limited technically to states east of a line from North
     Dakota to Texas. Nevertheless, Amtech will further limit the trial so that the METs
     operate only in the following states: ME, VT, NH, MA, RI, CT, NY, NJ, PA, VA, NC,
     SC, GA and FL.

     The company also is conducting tests in Canada, with approval by Industry Canada and
     in accordance with its rules and regulations.

7)   Equipment To Be Used:

     The trial will use prototype equipment under model number MT-3000-MC. A maximum
     of 25 of these MET units, which are manufactured by TransCore, will be used in the
     United States during the trial. The MT-3000-MC unit is based on the identical hardware
     that is currently licensed for operation under model number MT-3000. See File No. SES-
     MOD-20050819-01117 (modification application granted to add the MT-3000 unit to
     Call Sign E030120).

     The MT-3000 hardware platforms will operate on the trial system using new software
     with a new air interface. METs with the new software, however, are designated with the
     “–MC” suffix in the model number.


8)    Frequencies Desired:

      The METs will operate in the L-band (1626.5-1660.5 MHz transmit and 1525-1559 MHz
      receive). Specific transmit and receive channels will be assigned by the satellite provider
      in the L-band. Modulation for transmit and receive is OQPSK.

9)    Power Levels:

      The peak transmit power (“TPO”) is 1.0 Watts. The peak effective radiated power (“ERP”) is
      3 dBW or 2.0 Watts.

10)   Type of Emissions:

      MET transmit channel: 30K0G1D

      MET receive channel: 5K00G1D (authorization for receive frequencies not required;
      provided in this narrative and in the application for informational purposes only)

11)   Overall Height of Antenna(s) Above Ground:

      The MET units are less than 4 inches tall and would be mounted directly on a vehicle or
      other equipment. The transmitters, with integral antennas will not, under any
      circumstances, extend more than 6 meters above the local road base level. Any antennas
      that are mounted on an existing structure other than a building will be installed in
      accordance with FAA and FCC rules and regulations.

12)   Half-Duplex Operation:

      The METs operate in half-duplex mode. Accordingly, and to the extent necessary,
      Amtech respectfully requests a waiver of Footnote US315 in Section 2.106 of the
      Commission’s rules, 47 C.F.R. § 2.106, which requires real-time preemption for maritime
      and aviation distress services.

      The METs normally attempt to receive a 0.5 second subframe once in every 5-second
      subframe group. If this reception is not successful, then no subsequent transmission will
      be permitted from the MET unit until a later subframe is successfully received by it. The
      METs deployed during the trial will be programmed so that no transmission will occur
      later than 3 seconds after the last successful receive. If a shut-down is required, the
      forward link (to the METs) will be immediately shut-down, resulting in no further
      successful receives by any MET and thus within 3 seconds there will be no further MET
      transmissions.

      As a result, the METs will meet a 3 second shut-down requirement consistent with FCC
      rulings regarding waivers for half-duplex METs granted recently by the FCC. See, e.g.,
      Skywave (Call Sign E030055, File No. SES-LIC-20030311-00353)(special provision
      number 5955: which allowed a shutdown time of 2.6 seconds); Skybitz (Call Sign


      E000725, File No. SES-MOD-20030116-00057)(special provision number 5856: which
      allowed a 3 second shut-down time).

13)   Restrictions on Operation:

      Users participating in the trial will be advised that the MET units cannot be sold, must be
      returned and must not cause interference to other equipment. Specifically, the company
      will inform users that: (a) permission to operate the units has been granted under
      experimental authority issued by the Federal Communications Commission, is strictly
      temporary and may be cancelled at any time, (b) MET operation is subject to the
      condition that it not cause harmful interference, and (c) the user does not hold a property
      right in the device and may be required to return the device to the company. In addition,
      the company will conspicuously label all MET units as follows:

                                             FCC STATEMENT
                         This device has not been authorized as required by the
                         rules of the Federal Communications Commission. This
                         device is not, and may not be, offered for sale or lease,
                         or sold or leased, until authorization is obtained.



14)   Contact Information:

       Company Contact:                                       Legal Contacts:

       Brian Armbruster                                       David Hilliard
       Director, Systems Engineering                          Kurt DeSoto
       GlobalWave Products & Services                         Wiley Rein & Fielding LLP
       TransCore Link Logistics                               1776 K Street, N.W.
       2 Brewer Hunt Way                                      Washington, DC 20006
       Kanata, Ontario K2K 2B5
                                                              Telephone: (202) 719-7000
       Telephone: (613) 591-0100 ext4651                      Facsimile: (202) 719-7207
       Facsimile: (613) 592-0104                              dhilliard@wrf.com
       Brian.Armbruster@TransCore.com                         kdesoto@wrf.com



Document Created: 2006-07-27 11:24:23
Document Modified: 2006-07-27 11:24:23

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