Response to Question 7

0032-EX-PL-2012 Text Documents

Curtiss-Wright Controls, Inc.

2012-01-19ELS_122413

Background and Response to Question 7 on FCC Form 442


Background. Curtiss-Wright Controls Inc. (CW) filed a Part 15 waiver request with the FCC in June 2010
seeking authorization to operate its 3d-Radar ground penetrating radar (GPR) device for non-federal use. (ET
Docket No.10-167.) In July 2011 (while this waiver request was pending), CW filed an STA request with the
FCC (STA File Number 0407-EX-STA-2011) for authorization to conduct demonstrations of the 3d-Radar GPR
device for prospective non-federal customers. The FCC granted an STA to CW (call sign WF9XAO) which
expires on February 9, 2012.

On January 11, 2012, the FCC granted CW’s waiver request which will allow CW to market the 3d-Radar
device upon receiving FCC equipment authorization. (A copy of the waiver grant is being submitted with this
application.) Although CW will not be able to obtain FCC equipment authorization for its device by February 9,
2012, CW wants to continue conducting demonstrations of its device for prospective customers beyond this
date.

Section 5.61 of the FCC’s Rules states: “Extensions of a special temporary authorization will be granted
provided that an application for a regular experimental license has been filed at least 15 days prior to the
expiration of the licensee’s temporary authority. When such an application is timely filed, operations may
continue in accordance with the other terms and conditions of the temporary authority pending disposition of the
application, unless the applicant is notified otherwise by the Commission.” Based on this Rule and input from
FCC staff, we understand that CW may continue conducting demonstrations pursuant to its existing STA
beyond February 9th once this application has been filed.

Narrative. In response to Question 7 on FCC Form 442, below is a narrative about the proposed use of the
device (including a description of the equipment and theory of operation), the objectives to be accomplished,
and how such use will contribute to the development, extension, expansion or utilization of the device and its
application.

The 3d-Radar GPR device is an ultra-wideband emitter regulated under the Part 15 Rules which is used to
survey sub-surface and below ground structures. Under an experimental authorization, activities will be of
limited duration for a few hours each day on selected days and at selected locations in the U.S. as determined
by prospective customers. Through demonstrations for (and discussions with) prospective customers, CW will
be able to better assess customer needs which, in turn, may impact the development and implementation of
certain functional aspects of the device.



Document Created: 2012-01-19 14:25:13
Document Modified: 2012-01-19 14:25:13

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