Attachment A 0183EXCN2019 Final

0183-EX-CN-2019 Text Documents

Carnegie Mellon University

2019-04-12ELS_227488

     Attachment A – Background Information, Response to Item 7 Questions & Request for
                                 Extended License Term

       This application has its roots in Experimental License WI2XPQ (expired). That license
allowed the Applicant, Carnegie Mellon University (“CMU”) to participate in the Naval Post-
Graduate School’s Joint Interagency Field Experimentation (“JIFX”), sometimes referred to as
“Naval Postgraduate School Field Experimentation (‘NPS-FX’).” Information about the
experimentation is available online at https://my.nps.edu/web/fx. These events are generally held at
Camp Roberts, Highway 101, Camp Roberts, CA 93451-5000. CMU has been, and will
continue to be, an active participant in JFIX exercises.

         JIFX enables a diverse group of academics, government labs, private industry, end users,
and others to come together to develop and refine new technologies in a field environment. The
results advance both the science of radio engineering and national defense. At times, emergency
first responders also participate. Due to the sponsorship of the Army and Navy and the
relationship of JFIX to military effectiveness and national defense, the exact nature of the
experiments and exercises are generally treated as confidential and not disclosed beyond the
sponsors and, as appropriate, the participants. As permitted by the Army and the Navy and upon
reasonable request by the Commission, CMU would disclose information to the Commission on
a confidential basis. This information would include: a) The complete program of research and
experimentation proposed, including description of equipment and theory of operation; b) The
specific objectives sought to be accomplished and c) How the program of experimentation has a
reasonable promise of contribution to the development, extension, expansion or utilization of the
radio art, or is along a line not already investigated.

       In addition, CMU has been approached by the United States Department of Agriculture
(“USDA”) to participate in similar radio technology research throughout the state of California.
CMU believes that this additional research, the results of which can generally be disseminated,
can and will provide further benefits the public interest. Therefore, in this application, CMU is
seeking permission to extend the license footprint throughout California, although CMU expects
much of the experiments will be carried out in rural parts of the state.

         CMU conducts many of its “on-location” experiments from its mobile RF laboratory (a
retrofitted EMT rescue vehicle, length 7 meters, height 2.7 meters) with an extendable antenna
mast (16 meters maximum from the top of the mast to the bottom of the tires). Attachment B.
This vehicle will be deployed at Camp Roberts and around the rest of the state. Accordingly, it
is impossible to provide exact details requested in the questions about antenna height except at
Camp Roberts.1 Other experiments will be conducted with mobile transmitters outside the
mobile lab.2 When operating in locations within 805 meters of a covered airport, CMU will




1
 CMU’s application includes antenna height location for Camp Roberts and is the same as that which
was approved as part of WI2XPQ.
2
    CMU’s use of directional antennas will be in compliance with Part 15, Subpart C of the FCC’s rules.

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make any notifications to the Federal Aviation Administration (“FAA”) as explained in Section
17.7 of the Commission’s rules, 47 C.F.R. § 17.7.

         Since both the JFIX- and USDA-related experiments will be ongoing,3 CMU requests
that it be granted an experimental license for the maximum period of five years. Section 5.71(a),
47 C.F.R. § 5.71(a). Such a grant would allow more CMU resources to be spent on research,
rather than on license renewals. Further, CMU has a good compliance record with Commission
rules, such that a longer license term does not increase the risk of harmful interference.




3
    For example, JFIX events are held quarterly.

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Document Created: 2019-04-12 14:47:24
Document Modified: 2019-04-12 14:47:24

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