Narrative Statement

1571-EX-ST-2017 Text Documents

Echodyne Corp.

2017-10-25ELS_200197

                                                                            Echodyne Corp.
                                   Application for Experimental Special Temporary Authority
                                                            ELS File No. [____-EX-ST-2017]

                                   NARRATIVE STATEMENT

       Pursuant to Section 5.3(d) and (f) and Section 5.61 of the Federal Communications
Commission’s (“FCC”) rules, 47 C.F.R. §§ 5.3(d), (f), 5.61, Echodyne Corp. hereby respectfully
requests a special temporary authority (“STA”) from December 1-31, 2017 to operate in the
24.45-24.65 GHz band to test a new radar developed by Echodyne Corp.

       Grant of authority to test at the proposed location will enable the company to demonstrate
the capabilities of its radar technology for counter-UAS and security applications as part of a
program organized by the Department of Homeland Security.

         In support of this request, the following is shown:

A.       Purpose of Operation and Need for Special Temporary Authority:

        Echodyne Corp., headquartered in Bellevue, Washington, is making high performance
ultra-low cost, size, weight, and power electronically scanning radars. Its Metamaterial
Electronically Scanning Array (“MESA”) offers disruptive capabilities for existing radar
applications and enables new categories of radars for UAS, robots, autonomous vehicles, and
security.

        Under other authorizations, Echodyne has tested its MESA-DAA, which is an
electronically scanning detect and avoid (DAA) radar for small UAVs and other aircraft.
Echodyne has created a ground-based version of that same radar for use in ground-based
navigation systems and ground-based security and surveillance (SSR) systems. This requested
STA is to enable Echodyne to demonstrate the capabilities of its MESA-SSR radar as part of the
Department of Homeland Security’s Technical Assessment of Counter Unmanned Aerial
Systems Technologies in Cities (TACTIC) program.

B.       Location of Proposed Operation:

        Echodyne proposes to test the radar at fixed locations on the ground within a specified
area of operation to validate its performance for counter-UAS uses. By this application,
Echodyne seeks authority to conduct tests at the following location:

     Location                        Coordinates           Radius of Operation
                                     (NAD83)
     Quantico, VA                    38° 34' 27"           7 km
                                     -77° 32' 38"



C.       Technical Specifications:

         1.     Frequencies Desired

         Echodyne requests authorization to operate in the 24.45-24.65 GHz band.
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       2.      Effective Radiated Power

       The units to be deployed operate at a peak maximum transmitter power output of 4W,
and a peak maximum effective radiated power of 486W.

       Echodyne will reduce the actual powers to the minimum power needed for successful
operation, based on set-up and testing at the proposed locations. Operations will be conducted to
comply with rules relating to human exposure to radiation.

       3.      Modulation and Emissions

       Echodyne proposes to operate using linear FM modulation. The primary emission
designator is 190MFXN. Other emission modes may be utilized, but in no event will the
emissions extend beyond the frequency bands requested.

       4.      Antenna Information

        No antennas will be mounted in a fashion that will require approval under FAA and FCC
rules and regulations.

       5.      Equipment To Be Used

         Echodyne proposes to test its MESA-SSR radar. It expects that it will be able to conduct
its testing with a maximum of 4 units.

D.     Protection Against Causing Interference:

        As noted above, Echodyne has requested authority to operate in the 24.45-24.65 GHz band.
It has conducted a search of the Commission’s Universal Licensing System (“ULS”) database and
determined that there are no licensed operations in that spectrum.

       In the event that it receives a complaint of harmful interference resulting from the
proposed operation, Echodyne will take immediate action to address the interference, including if
necessary discontinuing it operations. The company has designated Mr. Jeff Finan, whose
contact information is provided below, to act as the “stop buzzer” for this purpose.

       Furthermore, the length of the test period is short, extending only from December 1-31,
2017. During that period, the proposed operations will be limited in scope. Echodyne will on
average transmit for only 240 minutes over a period of 8 hours on not more than 5 days each
week.

        In summary, the analysis conducted by Echodyne indicates the proposed operation should
not interfere with any licensed operation.

E.     Restrictions on Operation:

        Echodyne recognizes that the operation of any equipment under experimental authority
must not cause harmful interference to authorized facilities. Should interference occur,
Echodyne will take immediate steps to resolve the interference, including if necessary arranging
for the discontinuance of operation.

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       In addition, Echodyne will advise entities using the equipment that permission to operate
has been granted under experimental authority issued to Echodyne, that such operation is strictly
temporary, and that the equipment may not cause harmful interference. Entities will also be
advised in accordance with Section 2.803 of the Commission’s rules, 47 C.F.R. §2.803, that any
unapproved devices have not been authorized as required by the rules of the FCC.

F.     Public Interest:

        Grant of an authorization will permit Echodyne to develop innovative radar equipment
that will enhance public safety.

G.     Contact Information:

       For questions about this application, please contact:

              Michael Lewis
              Senior Engineering Advisor
              DLA Piper LLP
              500 Eighth Street, N.W.
              Washington, DC 20004
              Telephone: (202) 799-4042
              Facsimile: (202) 799-5007
              michael.a.lewis@dlapiper.com
       For questions about the company or the testing, please contact:

               Andrea Radosevich
               General Counsel
               Echodyne Corp.
               2380 116th Ave NE
               Bellevue, WA 98004
               (206) 399-9793
               andrea@echodyne.com

       In the unlikely event interference concerns should arise during the period of authorization
requested by this application, please contact the company’s “Stop Buzzer” identified below:

               Jeff Finan
               Echodyne Corp.
               2380 116th Ave NE
               Bellevue, WA 98004
               (425) 445-0631
               jeff@echodyne.com




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Document Created: 2017-10-25 11:52:22
Document Modified: 2017-10-25 11:52:22

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