Exhibit 1

0723-EX-PL-2014 Text Documents

Continental Automotive Systems, Inc.

2014-10-10ELS_154463

                                                                            Exhibit 1

                             PUBLIC INTEREST STATEMENT

1.     Introduction

        Continental Automotive Systems, Inc. (“Continental”) respectfully requests that the
Commission grant a two year experimental license to permit Continental to operate the facilities
specified in the attached application.

2.     Purpose and Nature of the Operation

        The proposed transmissions are intended to support technical research and equipment
development, field testing and customer demonstration of devices and systems to operate in the
Dedicated Short-Range Communications Service (“DSRC”) in the 5.850-5.925 GHz band. The
tests are intended for the development and the validation of series production devices and end
user applications that use the DSRC communication.

        Continental is requesting this authority to conduct (1) experimentations; (2) research; (3)
technical demonstrations; (4) field tests; (5) demonstrations of equipment to prospective
purchasers; (6) testing; and (7) development of radio technique, equipment, operational data,
or engineering data. Continental's systems may also be operated at trade shows and other venues
to demonstrate how they can be deployed to meet DSRC applications for vehicles, heavy
trucks, buses and emergency vehicles. The operation of Continental's DSRC systems as proposed
here will contribute to the development and market rollout of radio technology to enhance
vehicle safety, efficiency of use of the transportation infrastructure and safety of commercial
vehicle operations.

        The experiment will involve the testing of mobile units, mainly On-Board Units
(“OBUs”), only and will not involve the operation of Roadside Units (“RSUs”). In addition, this
is to confirm that the experiment is not a market study and will not involve the operation of units
by members of the general public. All devices will work as standalone units and not as a
network.

3.     Additional Technical Specifications

      (A) Emissions – Continental will use emissions which comply with the emissions
mask and formulas in the FCC approved ASTM-DSRC Standard for Class B or Class C devices.

        (B) The maximum center height of DSRC Antenna mounted on light vehicles will not
exceed 2m above ground and for commercial vehicles they will not exceed 4m above ground.
Additional test equipment will use antennas that do not excess 6m. OBUs and test equipment
will be mounted on a lower level as the antennas.

        (C) Most tests will be conducted with about 3-5 cars equipped with up to three OBUs,
(e.g., 15 DSRC devices). Complex driving situations for the validation of advanced driving


assistance functions will need tests up to 20 cars equipped with up to 3 OBUs. Worst case
channel load test will need up to 200 devices. The number of tests with these different numbers
of active DSRC devices have a ratio of roughly 100:10:1. The reason to equip a single car with
more than one OBU is that an independent monitoring device is needed and in some cases new
versions of devices need to be tested against old versions.

4.     Request for Waiver of Station ID Requirements

       Waiver of the Station ID rules set forth at Section 5.115 is respectfully requested.

5.     Justification For Nationwide Geographic Coverage

       The experiment will involve testing – over a 2 year period - not only at Continental
laboratories, but also at field test locations throughout the country. Continental estimates the
maximum duration of its proposed field tests operations at any location, other than the
Continental laboratories, will have duration of no more than 6 weeks.

        Continental is expecting to develop systems for use under different road conditions and
environmental conditions and to demonstrate system capabilities to car manufactures and the
public throughout the U.S. On-site demonstrations are particularly helpful to gain familiarity
with equipment compatibility, functionality on their systems, and the range of potential uses
which they can serve. To gain optimal system response even in rare driving situations test
driving in all geographic regions and all operation conditions (cities, mountains, desert, plain
land, etc.) is necessary. A 2 year license providing coverage nationwide would be more efficient
for the Commission staff than having Continental file numerous duplicative applications, in
which the only substantive difference would be the location of the testing.

6.     Interference Mitigation

        Continental is well aware of its obligations under Part 5 of the Commission’s rules to
avoid interference to co-channel licensees in non-experimental services, and will take all steps to
ensure compliance with this obligation. With respect to interference mitigation, Continental
notes as follows:

       -   Authority is requested for only limited and sporadic transmit operation of the
           facilities. Specifically, operation of the facilities will be sporadic, not continuous.
           The minimum distance between two transmissions will not be smaller than 90ms, the
           duration of a single transmission will not be longer than 1.5 ms

       -   The devices will comply to FCC class B or class C masks

       -   The device will comply to IEEE 802.11p, so Collision Avoidance will be
           implemented in the devices


7.     Stop Buzzer

       Continental advises that the following will be available by wireless telephone
and will act as a “stop buzzer” if any issues regarding interference arise during testing:

       Andrew L. Attard
       Work: (248) 393-6533
       Mobile: (313) 717-4188

       For the foregoing reasons, Continental respectfully submits that approval of this
application is in the public interest, convenience and a necessity.



Document Created: 2019-04-27 08:42:38
Document Modified: 2019-04-27 08:42:38

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