Please explain in the area below why an STA is necessary:
Caterpillar, Inc. hereby requests special temporary authority (STA) to conduct electromagnetic compatibility (EMC) immunity testing at its proving grounds in Peoria, Illinois and Tucson, Arizona until such time as the FCC acts on its underlying application for experimental authority. See FCC File No. 0003-EX-PL-2007. The parameters of Caterpillars proposed STA are set forth in its pending experimental application. As noted in the underlying experimental application, EMC immunity testing is necessary for product safety and to comply with the regulations of various countries, including the European Community countries, to which Caterpillar exports machinery for sale.
STA is needed in order to conduct EMC testing on various prototype/pilot machines under development in the next few months. The prototype/pilot machines typically have very stringent development cycles with machine schedules project managed to the hour. These prototype/pilot machines typically incorporate new technology designed to maintain or improve Caterpillars competitive position in the marketplace. To reduce the time from development to production, Caterpillar attempts to design EMC robustness early in the development stage of its new machines.
Because of the competitively sensitive nature of the design and functionality of these prototype/pilot machines, this machine program is maintained under strict security security that requires any EMC testing to be conducted on Caterpillars proving grounds rather than the test bed of an outside vendor. In these circumstances, it is crucial to establish and maintain a specific schedule to perform the EMC testing. Unfortunately, without STA, Caterpillar will be unable to establish such a schedule in the near future due to the current backlog of experimental applications pending at the FCC.
For all these reasons, Caterpillar requests STA so that it can schedule and conduct EMC testing on its prototype machines until the FCC acts on its underlying application for experimental authority. Given the importance of these prototypes to maintaining and enhancing its global competitive position, Caterpillar submits that the requested STA is in the public interest and should be granted.
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