FirstNet Concurrence Request

0892-EX-ST-2013 Text Documents

General Dynamics C4 Systems

2013-09-20ELS_141555

September 20, 2013

Mr. Julius Knapp
Chief Engineer
Office of Engineering and Technology
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Re: Request for Experimental License; File No. 0892-EX-ST-2013

Dear Mr. Knapp:

General Dynamics C4 Systems (General Dynamics) respectfully requests that the Federal
Communications Commission (“FCC”) allow operation in the 700MHz Public Safety spectrum to
demonstrate Long Term Evolution (“LTE”) equipment and devices in Philadelphia, Pennsylvania
in conjunction with the International Association of Chiefs of Police (“IACP”) Conference, which
will take place October 19 to October 23, 2013. We specifically seek authority to use the 700
MHz Band 14 spectrum, 758-768/788-798 MHz.


The demonstration will conform to the following parameters:

         1. Operation will be confined to the showroom floor of the Pennsylvania Convention
            Center at 1101 Arch Street Philadelphia, PA 19107 and will be conducted only
            during exposition business hours. The equipment for this operation will include one
            General Dynamics base station and associated antenna located at the demonstration
            site, along with a small number of portable user units. Power levels of the equipment
            will be reduced sufficiently to limit coverage to the General Dynamics booth area.

         2. General Dynamics requests authority to operate over the 758-768/788-798 MHz
            band, which is currently licensed on a nationwide basis to the First Responder
            Network Authority (“FirstNet”).

         3. Operation will occur between October 18, 2013 and October 23, 2013, allowing time
            for setup and testing, demonstration, and teardown.

         4. The Experimental STA cannot be renewed. To the extent General Dynamics would
            like to obtain additional Experimental STA use of the radio frequencies licensed to
            FirstNet, beyond the period specified above, General Dynamics must file a separate
            request with the FCC.




2900 Crystal Drive, Suite 510
Arlington, VA 22202
Tel 703 769 1500


September 20, 2013
Page 2




       5. General Dynamics has analyzed information from the FCC’s ULS databases and has
          determined that the proposed operation would not interfere or create a significant
          potential for interference with any public safety operation in the 700MHz band.
          Specifically, we found no active public safety licenses authorizing operation in the
          Philadelphia, PA area on frequencies that are co-channel to those proposed in this
          STA request.

       6. General Dynamics understands that multiple IACP Conference vendors will be
          operating in the same frequency spectrum within the Convention Center during the
          exposition. It will actively work with the other vendors to assure that interference
          to/from the other vendors is minimized.

       7. Temporary operations pursuant to this Experimental STA will not be used in
          mission-critical operations or in the delivery of live transmissions in duties to protect
          life, property, or safety.

       8. The Experimental STA will serve the public interest by providing IACP Conference
          attendees with an opportunity to test and receive an introductory knowledge of the
          potential benefits and capabilities of a Band 14 LTE public safety network.

For the foregoing reasons, General Dynamics requests that the Commission grant the requested
Experimental STA for the purpose of demonstrating LTE equipment at the IACP Conference.

Respectfully submitted,




James Norton
Vice President, Washington Operations
General Dynamics C4 Systems


CC: Genaro Fullano, FCC
    Regina Harrison, NTIA



Document Created: 2013-09-20 13:54:35
Document Modified: 2013-09-20 13:54:35

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