Narrative Statement

1578-EX-ST-2017 Text Documents

Echodyne Corp.

2017-10-26ELS_200324

                                                                            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 November 15, 2017 to May 14, 2018 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 locations will enable the company to
demonstrate the capabilities of its radar technology for navigation and counter-UAS applications.

         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. This
requested STA is to enable Echodyne to conduct testing with additional partners to validate and
improve the performance of the MESA-DAA radar.

B.       Location of Proposed Operation:

        Echodyne proposes to test the radars on the ground and on airborne platforms within a
specified area of operation. Any use of UAVs in testing will be done in accordance with FAA
regulations. By this application, Echodyne seeks authority to conduct tests at the following
locations:

     Location                        Coordinates           Radius of Operation
                                     (NAD83)
     Seattle, WA                     47° 39’ 18”           3 km, altitudes up to 122m AGL
                                     -122° 18’ 24”
     Corpus Christi, TX              27° 40' 8"            1 km, altitudes up to 122m AGL
                                     -97° 17' 14"
     Kent, WA                        47° 24' 38"           1 km, altitudes up to 122m AGL
                                     122° 14' 14"

Note that the requested location at Corpus Christi, TX is part of an FAA UAS test facility, and
the requested location at Seattle, WA is selected for the purpose of fulfilling the requirements of
a contract with DARPA for its Aerial Dragnet Program under DARPA Contract
HR001117C0076.


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C.     Technical Specifications:

       1.      Frequencies Desired

       Echodyne requests authorization to operate in the 24.45-24.65 GHz band.

       2.      Effective Radiated Power

       The units to be deployed operate at a peak maximum transmitter power output of 2W,
and a peak maximum effective radiated power of 243W.

       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. The mobile units on aircraft will operate at heights specified above under
Section B.

       5.      Equipment To Be Used

         Echodyne proposes to test its MESA-DAA radar. It expects that it will be able to conduct
its testing with a maximum of 10 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 November 15,
2017 to May 14, 2018. 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.

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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.

       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: 2017-10-26 15:55:48
Document Modified: 2017-10-26 15:55:48

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