System Technical Description Exhibit 2

0178-EX-CM-2018 Text Documents

General Motors Research Corporation

2018-08-23ELS_214709

                                               Exhibit #2

GPS Re-Radiation System Technical Description
GM proposes to install the five (5) fixed GPS re-radiation GLI-Metro-G repeaters which will be located
indoors in the test crash hall, which is a facility/building located at the General Motors Milford Proving
Grounds in Milford, Michigan. The building in question is used exclusively for GM operations to conduct
vehicle crash testing and telematics system testing under a variety of constraints and scenarios.

A total of two rooftop active antennas (one existing, one new) will be used and locations are as follows:


  No.         Rooftop Antenna              Latitude                Longitude               Location
            (receives GPS signal
               from satellites)
  1.           Active Antenna                           FCC license acquired already

  2.          Active Antenna            42°33'52.76"N           83°40'42.19"W          Outdoor/Rooftop



The locations of the GPS Repeaters (with their attached passive transmitting antennas) for which GMRC
seeks approval are given in the following table. Repeater A is existing and an FCC license has already
been acquired for it; only a change in power level is being proposed. GMRC proposes to add Repeaters
B, C, D, E, and F to the license.



 Repeater     Transmitting Equipment             Latitude                Longitude            Location

       A       GLI-Metro-G Repeater          42°33'56.60"N            83°40'42.70"W            Indoor

       B       GLI-Metro-G Repeater          42°33'55.53"N            83°40'42.70"W            Indoor

       C       GLI-Metro-G Repeater          42°33'54.10"N            83°40'42.70"W            Indoor

       D       GLI-Metro-G Repeater          42°33'54.10"N            83°40'42.41"W            Indoor

       E       GLI-Metro-G Repeater          42°33'52.54"N            83°40'42.41"W            Indoor

       F       GLI-Metro-G Repeater          42°33'52.54"N            83°40'42.48"W            Indoor




                                                                                                            1


Below is the system diagram of the crash test facility, showing the GPS repeater locations.




Below is the aerial view of the crash test facility with the GPS repeater locations (A is existing, B, C, D, E,
and F are proposed).




                                                                                                                  2


Emission Calculations
Emission calculation per antenna/GPS repeater1 are explained below, and compliance with Redbook
section 8.3.27 is demonstrated.

For simplicity the calculations are performed as if the antenna were omnidirectional, i.e. the figure for
forward gain (gain in the main lobe) is used in all directions. This simplification is acceptable because it
never falsely indicates compliance with Redbook section 8.3.27; the simplification never results in
understatement of the power (and in some cases results in overstatement of the power).

Repeater A re-radiates both L1 and L2, while Repeaters B, C, D, E, and F re-radiate L1 but not L2.

Power Settings
The GPS repeater offers an output power setting, which is a whole number from -85 to -65 inclusive. It
specifies the output power of the repeater, which is then supplied to the passive transmitting antenna
that is attached to the repeater. The proposed output power settings in order to receive good coverage
in the crash test facility are as below:

                         Repeater        Transmit ERP L1        Transmit ERP L2       Units
                            A                 -65                    -65              dBm
                            B                 -70                     NA              dBm
                            C                 -70                     NA              dBm
                            D                 -70                     NA              dBm
                            E                 -70                     NA              dBm
                            F                 -65                     NA              dBm

Assessment against 8.3.27 section “e”
Section 8.3.27 of the NTIA “Manual of Regulations and Procedures for Federal Radio Frequency
Management (Redbook)”, Sept 2017 Revision of the Sept 2015 edition, states the following in section
“e”:
        “The area of potential interference to GPS reception (e.g., military or contractor facility) has to
        be under the control of the user.”


In this request for license modification GMRC considers the “area of potential interference to GPS
reception” to be the area in which the received power (as EIRP) is greater than -140 dBm.

The crash test facility (the building shown earlier) is located inside the GM Milford Proving Grounds,
which is a large private access controlled campus surrounded by a fence. Thus this campus is clearly
under the control of the user. For each repeater, the area in which the received power is greater
than -140 dBm EIRP falls completely within this campus, and thus the area of potential interference to
GPS reception is under the control of the user. Therefore the proposed solution is in compliance with
8.3.27 section “e”.

The calculations that support this claim are provided below. First we define the area of potential
interference for each repeater by calculating the distance of the -140 dBm threshold from that repeater.


1
    Each GPS re-radiator consists of a repeater with an attached passive transmitting antenna.

                                                                                                               3


After that we show that all of these areas of potential interference are within the GM Milford Proving
Grounds and thus are “under the control of the user”.

Calculate areas of potential interference

 Antenna A - L1 Calculation
 Label     Parameter                   Value          Units       Notes / Formula
 A         Transmit ERP                316            pW          Output power of repeater
 B         Frequency                   1575.42        MHz         L1 center frequency
 C         Distance                    505            feet        Distance at which received
                                                                  power falls below -140 dBm
                                                                  EIRP
                                                                  = D * 3.2808 feet/meter
 D         Distance                    154            meters      Distance at which received
                                                                  power falls below -140 dBm
                                                                  EIRP
 E         Free Space Path Loss        80.1           dB          = 20 * log(B) + 20 * log(D) -
                                                                  27.55
 F         Transmit ERP                -65.0          dBm         Output power of repeater
                                                                  = 10 * log(A / 1,000,000,000)
 G         Transmit EIRP               -62.85         dBm         Output power of repeater
                                                                  = F + 2.15
 H         Antenna Gain                3              dBi
 I         Received Power              -140.0         dBm         =G–E+H
           Threshold of Interest




                                                                                                         4


Antenna A - L2 Calculation
Label   Parameter               Value     Units    Notes / Formula
A       Transmit ERP            316       pW       Output power of repeater
B       Frequency               1227.60   MHz      L2 center frequency
C       Distance                459       feet     Distance at which received
                                                   power falls below -140 dBm
                                                   EIRP
                                                   = D * 3.2808 feet/meter
D       Distance                140       meters   Distance at which received
                                                   power falls below -140 dBm
                                                   EIRP
E       Free Space Path Loss    77.2      dB       = 20 * log(B) + 20 * log(D) -
                                                   27.55
F       Transmit ERP            -65.0     dBm      Output power of repeater
                                                   = 10 * log(A / 1,000,000,000)
G       Transmit EIRP           -62.85    dBm      Output power of repeater
                                                   = F + 2.15
H       Antenna Gain            0         dBi
I       Received Power          -140.0    dBm      =G–E+H
        Threshold of Interest




Antenna B - L1 Calculation
Label   Parameter               Value     Units    Notes / Formula
A       Transmit ERP            100       pW       Output power of repeater
B       Frequency               1575.42   MHz      L1 center frequency
C       Distance                284       feet     Distance at which received
                                                   power falls below -140 dBm
                                                   EIRP
                                                   = D * 3.2808 feet/meter
D       Distance                86.7      meters   Distance at which received
                                                   power falls below -140 dBm
                                                   EIRP
E       Free Space Path Loss    75.2      dB       = 20 * log(B) + 20 * log(D) -
                                                   27.55
F       Transmit ERP            -70.0     dBm      Output power of repeater
                                                   = 10 * log(A / 1,000,000,000)
G       Transmit EIRP           -67.85    dBm      Output power of repeater
                                                   = F + 2.15
H       Antenna Gain            3         dBi
I       Received Power          -140.0    dBm      =G–E+H
        Threshold of Interest




                                                                                   5


Antenna C - L1 Calculation
Label   Parameter               Value     Units    Notes / Formula
A       Transmit ERP            100       pW       Output power of repeater
B       Frequency               1575.42   MHz      L1 center frequency
C       Distance                284       feet     Distance at which received
                                                   power falls below -140 dBm
                                                   EIRP
                                                   = D * 3.2808 feet/meter
D       Distance                86.7      meters   Distance at which received
                                                   power falls below -140 dBm
                                                   EIRP
E       Free Space Path Loss    75.2      dB       = 20 * log(B) + 20 * log(D) -
                                                   27.55
F       Transmit ERP            -70.0     dBm      Output power of repeater
                                                   = 10 * log(A / 1,000,000,000)
G       Transmit EIRP           -67.85    dBm      Output power of repeater
                                                   = F + 2.15
H       Antenna Gain            3         dBi
I       Received Power          -140.0    dBm      =G–E+H
        Threshold of Interest




Antenna D - L1 Calculation
Label   Parameter               Value     Units    Notes / Formula
A       Transmit ERP            100       pW       Output power of repeater
B       Frequency               1575.42   MHz      L1 center frequency
C       Distance                284       feet     Distance at which received
                                                   power falls below -140 dBm
                                                   EIRP
                                                   = D * 3.2808 feet/meter
D       Distance                86.7      meters   Distance at which received
                                                   power falls below -140 dBm
                                                   EIRP
E       Free Space Path Loss    75.2      dB       = 20 * log(B) + 20 * log(D) -
                                                   27.55
F       Transmit ERP            -70.0     dBm      Output power of repeater
                                                   = 10 * log(A / 1,000,000,000)
G       Transmit EIRP           -67.85    dBm      Output power of repeater
                                                   = F + 2.15
H       Antenna Gain            3         dBi
I       Received Power          -140.0    dBm      =G–E+H
        Threshold of Interest




                                                                                   6


Antenna E - L1 Calculation
Label   Parameter               Value     Units    Notes / Formula
A       Transmit ERP            100       pW       Output power of repeater
B       Frequency               1575.42   MHz      L1 center frequency
C       Distance                284       feet     Distance at which received
                                                   power falls below -140 dBm
                                                   EIRP
                                                   = D * 3.2808 feet/meter
D       Distance                86.7      meters   Distance at which received
                                                   power falls below -140 dBm
                                                   EIRP
E       Free Space Path Loss    75.2      dB       = 20 * log(B) + 20 * log(D) -
                                                   27.55
F       Transmit ERP            -70.0     dBm      Output power of repeater
                                                   = 10 * log(A / 1,000,000,000)
G       Transmit EIRP           -67.85    dBm      Output power of repeater
                                                   = F + 2.15
H       Antenna Gain            3         dBi
I       Received Power          -140.0    dBm      =G–E+H
        Threshold of Interest




Antenna F - L1 Calculation
Label   Parameter               Value     Units    Notes / Formula
A       Transmit ERP            316       pW       Output power of repeater
B       Frequency               1575.42   MHz      L1 center frequency
C       Distance                505       feet     Distance at which received
                                                   power falls below -140 dBm
                                                   EIRP
                                                   = D * 3.2808 feet/meter
D       Distance                154       meters   Distance at which received
                                                   power falls below -140 dBm
                                                   EIRP
E       Free Space Path Loss    80.1      dB       = 20 * log(B) + 20 * log(D) -
                                                   27.55
F       Transmit ERP            -65.0     dBm      Output power of repeater
                                                   = 10 * log(A / 1,000,000,000)
G       Transmit EIRP           -62.85    dBm      Output power of repeater
                                                   = F + 2.15
H       Antenna Gain            3         dBi
I       Received Power          -140.0    dBm      =G–E+H
        Threshold of Interest




                                                                                   7


Distances from repeaters to edge of area under the control of the user

The crash test facility building is located inside the GM Milford Proving Grounds. This private access
controlled campus is surrounded by a fence which constitutes the edge of the area under the user’s
control. The closest fence to the building is the fence that lies to the south of the building and runs
east-to-west. In the below figure, this fence is the red line near the bottom. Orange brackets/text in the
figure show the approximate distances between the various repeaters and the southern fence.




As shown in the above figure:

    •   The distance from Repeater A to the fence is 381 meters.
    •   The distance from Repeater B to the fence is 348 meters.
    •   The distance from Repeaters C and D to the fence is 304 meters.
    •   The distance from Repeaters E and F to the fence is 256 meters.




                                                                                                        8


Summary and Conclusion

The following table summarizes the above results:

 Area of Potential Interference vs. User Control
 Repeater      Band     Distance at which            Distance from       Area of potential
                        received power falls         repeater to edge    interference is under
                        below -140 dBm EIRP          of campus           control of user?
                        (meters)                     (meters)
 A             L1       154                          381                 YES
 A             L2       140                          381                 YES
 B             L1       86.7                         348                 YES
 C             L1       86.7                         304                 YES
 D             L1       86.7                         304                 YES
 E             L1       86.7                         256                 YES
 F             L1       154                          256                 YES


For each repeater the area of potential interference is under the control of the user, and therefore the
proposal is compliant with Redbook section 8.3.27 section “e”.

Assessment against 8.3.27 section “f”
As stated above the proposed solution is in compliance with 8.3.27 section “e”. Therefore the
requirements of section “f” are not applicable. However for completeness we assess each repeater
against the requirement in section “f” below.


Section “f” imposes a maximum permissible EIRP in dBm called “𝑃𝑇𝑚𝑎𝑥”, which is calculated according to
the following formula:

𝑃𝑇𝑚𝑎𝑥 = 𝑃𝑅 + 20 log10 𝑓 + 20 log10(30 + 𝑑) − 27.55

Where:
         𝑃𝑇𝑚𝑎𝑥 is the maximum permissible EIRP in dBm
         𝑃𝑅 is the power received at 30 meters from the building (i.e. -140 dBm/24 MHz)
         𝑓 is frequency in MHz (i.e. 1575.42 for L1, 1227.60 for L2, 1176.45 for L5)
         𝑑 is the distance between the radiator and the closest exterior wall of the building in meters.

The following calculations determine 𝑃𝑇𝑚𝑎𝑥 for each repeater.




                                                                                                           9


Antenna A - L1 Calculation
Label   Parameter     Value     Units    Notes / Formula
A       𝑃𝑅            -140      dBm      Power received at 30 meters
                                         from the building
B       𝑓             1575.42   MHz      L1 center frequency
C       𝑑             7.24      meters   Distance between the
                                         radiator and the closest
                                         exterior wall of the building
D       𝑃𝑇𝑚𝑎𝑥         -72.2     dBm      Maximum permissible EIRP
                                         = A + 20 * log(B)
                                           + 20 * log(30 + C) − 27.55
E       𝑃𝑇𝑚𝑎𝑥         60.3      pW       Maximum permissible EIRP
                                         = 10(D/10)+9



Antenna A – L2 Calculation
Label   Parameter     Value     Units    Notes / Formula
A       𝑃𝑅            -140      dBm      Power received at 30 meters
                                         from the building
B       𝑓             1227.60   MHz      L2 center frequency
C       𝑑             7.24      meters   Distance between the
                                         radiator and the closest
                                         exterior wall of the building
D       𝑃𝑇𝑚𝑎𝑥         -74.3     dBm      Maximum permissible EIRP
                                         = A + 20 * log(B)
                                           + 20 * log(30 + C) − 27.55
E       𝑃𝑇𝑚𝑎𝑥         37.2      pW       Maximum permissible EIRP
                                         = 10(D/10)+9



Antenna B - L1 Calculation
Label   Parameter     Value     Units    Notes / Formula
A       𝑃𝑅            -140      dBm      Power received at 30 meters
                                         from the building
B       𝑓             1575.42   MHz      L1 center frequency
C       𝑑             9.22      meters   Distance between the
                                         radiator and the closest
                                         exterior wall of the building
D       𝑃𝑇𝑚𝑎𝑥         -71.7     dBm      Maximum permissible EIRP
                                         = A + 20 * log(B)
                                           + 20 * log(30 + C) − 27.55
E       𝑃𝑇𝑚𝑎𝑥         67.6      pW       Maximum permissible EIRP
                                         = 10(D/10)+9



                                                                         10


Antenna C - L1 Calculation
Label   Parameter     Value     Units    Notes / Formula
A       𝑃𝑅            -140      dBm      Power received at 30 meters
                                         from the building
B       𝑓             1575.42   MHz      L1 center frequency
C       𝑑             5.93      meters   Distance between the
                                         radiator and the closest
                                         exterior wall of the building
D       𝑃𝑇𝑚𝑎𝑥         -72.5     dBm      Maximum permissible EIRP
                                         = A + 20 * log(B)
                                           + 20 * log(30 + C) − 27.55
E       𝑃𝑇𝑚𝑎𝑥         56.2      pW       Maximum permissible EIRP
                                         = 10(D/10)+9


Antenna D - L1 Calculation
Label   Parameter     Value     Units    Notes / Formula
A       𝑃𝑅            -140      dBm      Power received at 30 meters
                                         from the building
B       𝑓             1575.42   MHz      L1 center frequency
C       𝑑             4.61      meters   Distance between the
                                         radiator and the closest
                                         exterior wall of the building
D       𝑃𝑇𝑚𝑎𝑥         -72.8     dBm      Maximum permissible EIRP
                                         = A + 20 * log(B)
                                           + 20 * log(30 + C) − 27.55
E       𝑃𝑇𝑚𝑎𝑥         52.5      pW       Maximum permissible EIRP
                                         = 10(D/10)+9


Antenna E - L1 Calculation
Label   Parameter     Value     Units    Notes / Formula
A       𝑃𝑅            -140      dBm      Power received at 30 meters
                                         from the building
B       𝑓             1575.42   MHz      L1 center frequency
C       𝑑             4.61      meters   Distance between the
                                         radiator and the closest
                                         exterior wall of the building
D       𝑃𝑇𝑚𝑎𝑥         -72.8     dBm      Maximum permissible EIRP
                                         = A + 20 * log(B)
                                           + 20 * log(30 + C) − 27.55
E       𝑃𝑇𝑚𝑎𝑥         52.5      pW       Maximum permissible EIRP
                                         = 10(D/10)+9




                                                                         11


    Antenna F - L1 Calculation
    Label      Parameter                     Value            Units        Notes / Formula
    A          𝑃𝑅                            -140             dBm          Power received at 30 meters
                                                                           from the building
    B          𝑓                             1575.42          MHz          L1 center frequency
    C          𝑑                             7.90             meters       Distance between the
                                                                           radiator and the closest
                                                                           exterior wall of the building
    D          𝑃𝑇𝑚𝑎𝑥                         -72.0            dBm          Maximum permissible EIRP
                                                                           = A + 20 * log(B)
                                                                             + 20 * log(30 + C) − 27.55
    E          𝑃𝑇𝑚𝑎𝑥                         63.1             pW           Maximum permissible EIRP
                                                                           = 10(D/10)+9


The following table summarizes the above calculations.

    Repeater       Band    Output    Gain of         Output ERP       Output      Maximum
                           ERP of    Antenna         of Antenna        EIRP of   Permissible
                          Repeater    (dBi)            (dBm)2         Antenna    EIRP (dBm)
                           (dBm)                                       (dBm)3
        A           L1       -65         3              -62            -59.85       -72.2
        A           L2       -65         0              -65            -62.85       -74.3
        B           L1       -70         3              -67            -64.85       -71.7
        C           L1       -70         3              -67            -64.85       -72.5
        D           L1       -70         3              -67            -64.85       -72.8
        E           L1       -70         3              -67            -64.85       -72.8
        F           L1       -65         3              -62            -59.85       -72.0


Conclusions

As noted earlier, the proposal is compliant with section “e” of Redbook section 8.3.27, and thus section
“f” is not applicable. Section “f” calculations are given here only for information.

One should also bear in mind that while the antenna is directional, the calculations treat the antenna as
omnidirectional; more specifically the main lobe gain of the antenna is used in all directions, resulting in
overstatement of the power in the side lobes and back lobe. Thus the proposal is closer to meeting the
“-140 dBm at 30 meters from the building” threshold than the above calculations indicate.

Also it should be remembered that the repeaters will be located in a metal building with few windows,
resulting in greater signal attenuation – and thus lower power outside the building – than the above
calculations indicate.


2
    Output ERP of Antenna = Output ERP of Repeater + Gain of Antenna
3
    EIRP (dBm) = ERP (dBm) + 2.15

                                                                                                           12


The following two pages discuss the GLI-Metro-G
specifications for transmission of GPS and GLONASS




                                                     13


14



Document Created: 2018-08-23 12:06:50
Document Modified: 2018-08-23 12:06:50

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