Question 7 Narrative Statement

0282-EX-PL-2010 Text Documents

Gogo LLC

2010-06-19ELS_108074

Aircell LLC

Attachment 1



In conjunction with its FCC license to provide broadband internet service on
commercial airlines, AirCell LLC is requesting an Experimental License under Part 5
of the FCC Rules to conduct Federal Aviation Administration (FAA) required tests to
determine the susceptibility of aircraft avionics to interference from radio frequency
emissions from consumer devices operating in the Industrial, Scientific, Medical
(ISM) and Unlicensed National Information Infrastructure (UNII) bands. Pursuant to
Documents DO-294B and DO-160 of the Radio Technical Commission for
Aeronautics (RCTA), and the FAA, standards for testing the susceptibility of avionics
to interference have been set. To comply with these standards, tests within an
aircraft must radiate at the legal maximum power authorized for the radiating
device, plus the link budget of the highest gain antenna permitted, times the
number of simultaneous radiating devices. For the purpose of Aircell’s tests, the
math computes a 1 watt signal into a 6 db gain antenna times three wireless access
points (WAP). That comes to 30 dBm + 6 dB = 4 watts X 3 WAPs = 12 watts. Since
the 12 watt signal exceeds the allowed limits for unlicensed devices, an
Experimental License is required.

Aircell must demonstrate conformance to the standards mentioned above in order
to receive FAA Supplemental Type Certificates (STA) necessary for the deployment
of its srvice aboard commercial airliners. In accordance with FAA test requirements
detailed in RTCA document DO-294B, AirCell is required to conduct certain in-cabin
tests while the aircraft is no less than 150 feet from any metallic structure. To
accomplish this, AirCell will have to conduct tests while the aircraft is parked
outside the hangar area in a number of airports throughout the country.
Measurements taken under AirCell’s previous STAs for similar testing indicate that
emissions outside the fuselage of the aircraft do not exceed the maximum allowed
under FCC Rules for the frequencies being tested. As an added precaution, test
aircraft will be located no less than 500 feet from any location where regular use of
the frequencies can be expected. A list of the airports where these tests will be
conducted is attached.



Document Created: 2010-06-20 02:52:50
Document Modified: 2010-06-20 02:52:50

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