Request for Confidential Treatment and Exhibits PUBLIC

0539-EX-PL-2016 Text Documents

Google Inc.

2016-08-05ELS_180386

                                                                   PUBLIC REDACTED VERSION

                                                                                     Google Inc.
                                                                       File No. 0539-EX-PL-2016


Date:                 August 5, 2016

Subject:              Public and Redacted Versions of Request for Confidential Treatment and
                      Complementary Exhibits

File Number:          0539-EX-PL-2016



To Whom It May Concern:

        Google Inc. (Google), pursuant to 5 U.S.C. § 552 and Sections 0.457 and 0.459 of the
Commission's Rules, 47 C.F.R. §§ 0.457, 0.459, hereby requests that certain information
complementary to its above-referenced application for an Experimental Radio Service License
(Experimental License) be treated as confidential and not subject to public inspection. The
designated information constitutes confidential and proprietary information that, if subject to
public disclosure, would cause significant commercial, economic, and competitive harm. As
described below, Google’s request satisfies the standards for grant of such requests set forth in
Sections 0.457 and 0.459 of the Commission’s Rules.

        In accordance with Section 0.459(b) and in support of this request, Google provides the
following information:


1.      Identification of the Information for Which Confidential Treatment is Sought:

       Google’s request for confidential treatment is limited to information that has been
redacted from the Experimental License and Exhibits A and C. Google does not seek to
withhold from public inspection information in the Experimental License and associated exhibits
necessary for interference mitigation, including applicant name, contact information, test
location, frequency, output power, effective radiated power, emission characteristics, and
modulation.


        Exhibit A - Narrative Statement:

        Google requests confidential treatment of the following underlined text from Exhibit A
        that contain confidential and proprietary information regarding the proposed
        tests/experiments:


                       Consistent with the standards set forth in Section 5.63 of the Federal
               Communications Commission’s (Commission’s) Rules, 47 C.F.R. § 5.63, Google
               Inc. (Google) requests authorization to conduct radio experiments in support of
               developing Citizens Broadband Radio Service (CBRS) technologies, using
               [REDACTED] experimental transmitters at up to 24 U.S. locations. The
               experimental authorization is sought for a period of 24 months. Google outlines

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                below its need for the requested authorization and the reasons why it should be
                granted expeditiously.

                                                       Background

                        In establishing the CBRS, the Commission opened a door for wireless
                innovation and bandwidth abundance. Rather than allocating the 3.5 GHz band to
                a single use, the Commission rightly decided to allow shared use of the
                spectrum. Users of the spectrum might, for instance, deploy “small cell” networks
                that can carry heavy loads of data in high-traffic areas—such as crowded
                stadiums—or offer fixed wireless broadband services in rural areas. The
                additional spectrum that is now available in the 3.5 GHz band will also help
                relieve Wi-Fi congestion—improving the experience of consumers accessing the
                Internet over wireless broadband.

                        A key component to sharing in this band is the Spectrum Access System
                (SAS), which utilizes database technology to protect important federal
                government uses of spectrum. These systems will ensure that neither priority
                access nor general authorized access users interfere with the existing
                government and private users who will continue to need 3.5 GHz spectrum in a
                limited number of areas. SAS database systems also will allow new users to
                share effectively with each other. Google has been a leader in using databases to
                free-up available spectrum, and it is one of the companies working to develop a
                sharing system for the 3.5 GHz band.

                        The instant experimental authorization is needed to advance technologies
                in the 3.5 GHz band. Specifically, the experimental authorization will allow Google
                to continue its experimentation with propagation and [REDACTED]. As discussed
                further below, the parameters of the experimental authorization will protect
                incumbent operators from harmful interference. Indeed, there have been no
                reports of interference from Google’s ongoing experimental operations under call
                signs WH2XNF (File Nos. 0722-EX-PL-2014 and 0004-EX-ML-2015) and WI2XFG
                (File No. 0095-EX-PL-2016).1

                       Google requests authorization to operate in and adjacent to the
                3550-3700 MHz band that has been opened for innovative small-cell spectrum
                sharing by CBRS devices. Google requests authorization to operate on
                frequencies down to 3400 MHz and up to 3800 MHz so that [REDACTED].
                Authority to operate in this range will ensure that Google has access to sufficient
                spectrum for experimentation while avoiding interference to incumbent
                operations, including federal government operations and operations under Parts


1
  Call sign WH2XNF (File Nos. 0722-EX-PL-2014 and 0004-EX-ML-2015) is associated with 3550-3700
MHz operations in Mountain View, CA, Arlington, VA, and Reston, VA. That experimental authorization is
set to expire in December 2016. If this request for experimental authorization is granted, Google plans to
let its authorization under WH2XNF expire and experimental operations at those three locations would
continue under the new authorization.
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                                                            File No. 0539-EX-PL-2016


25 and 90 of the Commission’s rules.

        The proposed experimentation will allow Google to perform propagation,
[REDACTED] testing [REDACTED]. Data obtained from these tests will be reflected
in the design of Google’s commercial SAS, which is currently under development
to serve users in the new CBRS band. Specifically, together with testing under call
signs WH2XNF and WI2XFG, the proposed testing will assist in enabling: (1)
[REDACTED]; (2) [REDACTED]; and (3) [REDACTED]. [REDACTED]. [REDACTED].

                                 Planned Operations

        Google anticipates performing the following tests under the requested
experimental authorization. As described in the next section, the proposed
experimental operations in the 3.5 GHz band will be conducted without harmful
interference to other authorized users.

    ●   Propagation Testing: Google will use both a simple continuous wave
        (CW) tone and a broadband signal to understand the effects of clutter
        loss, differential fading, multipath, and other propagation phenomena. To
        test [REDACTED], Google will use a mobile receiving station [REDACTED].
        Google may also position [REDACTED]. In each local test area, Google will
        generally operate only [REDACTED] while conducting propagation tests.

    ●   Testing of [REDACTED]: Google will test [REDACTED]. In Atlanta, Austin,
        and Provo, Google will use [REDACTED].

    ●   [REDACTED] Testing: Google will [REDACTED]. [REDACTED] .

    ●   [REDACTED] Testing: Google will investigate [REDACTED].

        In order to perform these tests, Google seeks authorization to operate
[REDACTED] experimental transmitters per test area. Specifically, Google seeks
authorization for [REDACTED] eNodeBs (also referred to as access points or base
stations) and [REDACTED] end user devices (EUDs) that will communicate with
the eNodeBs ([REDACTED] EUDs per [REDACTED] eNodeB on average). Google
will deploy this equipment [REDACTED] within the proposed areas of operation. It
is unlikely that [REDACTED], or the full number of authorized devices, will ever
transmit simultaneously. Rather, the full complement of test areas is needed to
ensure sufficient diversity of test environments.

        Google requests authorization to transmit in a variety of locations and
environments that meet several characteristics, including the radio propagation
environment, height and variety of clutter (buildings and foliage), existence of
suitable Google infrastructure and resources to support experimentation, and
existence of partners who may participate in the tests. To that end, Google
requests authorization to conduct testing in up to 24 U.S. areas. The test areas
will be selected from the list of locations in Exhibit B. All test areas will be subject
to the same limit of [REDACTED] experimental transmitters, and none of the
areas will have a radius of operations greater than 40 kilometers. See Exhibit B
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                                                                             File No. 0539-EX-PL-2016


                for the proposed radius of operation for each of the potential test locations.

                        From the list in Exhibit B, Google plans to deploy initially in Atwater,
                California, Mountain View, California, Palo Alto, California, San Bruno, California,
                San Francisco, California, San Jose, California, Boulder, Colorado, Kansas City,
                Kansas,2 Omaha, Nebraska, Raleigh, North Carolina, Provo, Utah, and Reston,
                Virginia.

                       EUDs operating under the requested authorization will be used by
                Google’s employees and contractors. Such devices may also be used, under
                close supervision, by “trusted testers” selected by Google on a volunteer basis
                without payment. No commercial operations will be conducted under the
                requested authorization and all equipment will be collected at the end of the
                experimentation period.

                                                 Interference Analysis

                        The 3400-3800 MHz frequency range covers multiple allocated bands and
                a variety of incumbent systems and services. As described below, Google will
                deploy and operate its equipment under this experimental authorization in a
                manner that will avoid interference to other authorized users.

                        Transmit Power and Out-of-Band Emission Considerations

                        Most operations under this experimental authorization will be conducted
                within the Part 96 Category B CBSD EIRP limit of 47 dBm per 10 MHz.
                Experimentation will also be conducted within the Category A CBSD EIRP limit of
                30 dBm per 10 MHz. [REDACTED], Google requests authorization to operate up to
                a conducted power spectral density (PSD) limit of 40 dBm per 10 MHz and a
                radiated PSD of 57 dBm per 10 MHz. [REDACTED], Google also requests
                authorization to operate up to a total conducted power limit of 49 dBm [40 dBm +
                10log(8)] and a maximum radiated power (EIRP) of 66 dBm. The requested
                maximum conducted and radiated power limits will provide flexibility to support a
                wide range of complementary advanced technology development and
                experimentation. [REDACTED].3 [REDACTED]. [REDACTED].

                        Additionally, Google requests authority to conduct narrowband
                propagation testing in the 3550-3575 MHz segment using a maximum conducted
                power of 47 dBm and a maximum radiated power of 77 dBm (assuming the use
                of a high-gain, narrow beamwidth 30 dBi antenna). [REDACTED]. [REDACTED].
                Google notes that extensive propagation testing has been conducted in this band
                under its existing experimental authorization (call sign WH2XNF) in the densely
                populated areas of Arlington, Virginia, and Mountain View, California, with no
                reports of interference. Google has chosen the 3550-3575 MHz portion as it is
2
  Call sign WI2XFG (File No. 0095-EX-PL-2016) is associated with 3400-3700 MHz operations in the
Kansas City area. In the present application, Google requests authority to operate up to 3800 MHz in a
limited section of Kansas City, KS.
3
  See [REDACTED].
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                                                          File No. 0539-EX-PL-2016


removed by at least 75 MHz from the nearest adjacent-band allocation.
Furthermore, the possibility of interference to authorized users of the band will be
mitigated by using narrow beamwidth antennas and narrowband CW
transmissions, along with out-of-band emission levels that will meet or exceed
(i.e., be lower than) the limits in Section 96.41(e) of the Commission’s Rules, 47
C.F.R. § 96.41(e).

       In summary, Google requests authorization to operate up to the following
power limits:

Planned Testing             Conducted Power Limits        Radiated Power Limits
Broadband Network           40 dBm per 10 MHz power 57 dBm per 10 MHz
(3400-3800 MHz)             spectral density        radiated power spectral
                                                    density
                            49 dBm total conducted
                            power (assumes eight    66 dBm total radiated
                            10-MHz aggregate        power (assumes eight
                            channels)               10-MHz aggregate
                                                    channels)
Narrowband Propagation      47 dBm                        77 dBm
(3550-3575 MHz)


        Below, Google explains its plans for protection of the following incumbent
users in the 3400-3800 MHz frequency range.

Frequencies                        Users

3400-3500 MHz                      Military radar systems
                                   Amateur radio

3500-3650 MHz                      Shipborne military radar systems

3600-3700 MHz                      Grandfathered FSS receive-only earth
                                   stations

3650-3700 MHz                      Ground-based military radar systems
                                   Part 90, Subpart Z operators

3700 MHz                           FSS receive-only earth stations


       Protection of Military Radar Systems Below 3500 MHz

       In the 3100-3500 MHz band, the U.S. military operates radar systems on
ships and at several land-based military installations around the country. To

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                protect such uses, Google will ensure that the signals from its experimental
                operations remain at or below levels that would reasonably preclude the
                possibility of interference. Specifically, for all test locations within the coastal
                exclusion zones (see Figures 1-3 below) or within 150 km of an in-land
                operations area, Google will use the NTIA propagation model that was used to
                compute the coastal exclusion zones4 (hereafter referred to as the NTIA model)
                to predict the aggregate interference from its deployed transmitters operating at
                or below 3550 MHz to the closest point of the military operations area (coastal or
                land-based) and will limit its signal strength to at or below the ambient noise level
                of -174 dBm/Hz at that point, as received by an isotropic antenna. In the
                calculation, Google will include both fundamental emissions below 3500 MHz
                and out-of-band emissions from devices operating above 3500 MHz.

                         Amateur Radio Operations in 3400-3500 MHz

                        The amateur radio service has a secondary allocation in the 3300-3500
                MHz band (3.4 GHz band). Based on Google’s spectrum monitoring elsewhere in
                the U.S., amateur operation in this band appears to be infrequent and generally
                point-to-point. However, Google will coordinate with the amateur radio
                community to ensure that Google’s operations do not interfere with any amateurs
                who may be utilizing the 3.4 GHz band. For example, Google will inform the
                American Radio Relay League prior to beginning operations in each area and
                provide contact information so they can report any suspected interference.

                         Protection of Shipborne Military Radar Systems in 3500-3650 MHz

                        In the 3500-3650 MHz band, the U.S. military operates shipborne radars in
                coastal areas. To protect such uses, Google will ensure that the signals from the
                experimental operations remain at or below levels that would reasonably
                preclude the possibility of interference. Alternatively, if operating such that the
                signals could exceed the interference threshold at the coast, Google will operate
                a sensor to detect military radar operations and reconfigure its devices to avoid
                those frequencies during the operations.

                        Specifically, for all test locations within the coastal exclusion zones
                established by the Commission5 (see Figures 1-3 below), Google will use the
                NTIA model to predict the aggregate interference from its deployed transmitters
                to the closest point on the coast6 and limit the signal strength to at or below the

4
  The model is described on the NTIA website at
https://www.ntia.doc.gov/report/2015/35-ghz-exclusion-zone-analyses-and-methodology.
5
  See 47 C.F.R. §§ 96.15(a)(1), 96.15(a)(3), 96.15(b); see also Letter from Paige Atkins, Associate
Administrator, Office of Spectrum Management, National Telecommunications and Information
Administration, to Marlene H. Dortch, Secretary, FCC, GN Docket No. 12-354, at Enclosure 1 (proposing
exclusion zones to protect shipborne radars).
6
  In the event of unusual local geography (e.g., a hill or mountain that blocks the path to the nearest point
on the coast but does not block other paths starting a short distance from that point), Google will analyze
paths to a range of points on the coast and ensure that its signal does not exceed the interference
threshold at any of those points.
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                ambient noise level of -174 dBm/Hz at that point, as received by an isotropic
                antenna. In the calculation, Google will include both fundamental emissions in
                3500-3650 MHz and out-of-band emissions from devices operating below 3500
                MHz and above 3650 MHz. If the signal level is predicted to exceed -174 dBm/Hz
                at the closest point on the coast, Google will deploy a sensor to detect military
                radar operations offshore and configure its devices to avoid the frequency at
                which the military is operating, and +/-5 MHz on either side. This is consistent
                with the operational concept of the ESC in the Part 96 rules.7 Google will use a
                prototype ESC sensor for this purpose, which will be designed to meet the
                WinnForum requirements on ESC sensitivity.8

                      Protection of Grandfathered FSS Receive-Only Earth Station Operations in
                3600-3700 MHz

                        In the 3600-3700 MHz band, FSS receive-only earth stations operate on a
                grandfathered basis in accordance with the FCC’s rules.9 The earth stations are
                located at 35 sites that are largely clustered along the coasts.10 For all test areas
                subject to Grandfathered FSS Operations protection requirements (see Figures
                1-3 below), Google will meet the Part 96 requirements11 and will conduct its
                calculations using the NTIA model. In the event that Google’s predictions show
                that the Part 96 limits may be exceeded for a particular site, Google will
                coordinate with the operators of the affected earth station(s).

                        Protection of Ground-based Military Radar Systems in 3650-3700 MHz

                         In the 3650-3700 MHz band, the U.S. military conducts research and
                development (R&D) activity at three land-based sites whose coordinates are
                listed in the FCC’s rules.12 To protect such uses, Google will ensure that the
                signals from its experimental operations remain at or below levels that would
                reasonably preclude the possibility of interference. Specifically, for all test
                locations within 150 km of the R&D sites,13 Google will use the NTIA model to
                predict the aggregate interference from its deployed transmitters to the R&D sites
                and will limit its signal strength to at or below the ambient noise level of -174
                dBm/Hz at that point, as received by an isotropic antenna. In the calculation,
                Google will include both fundamental emissions in 3500-3650 MHz and

7
  See 47 C.F.R. § 96.67.
8
  Specifically, “[a]n ESC shall be capable of detecting an in-band incumbent radar over a maximum
propagation loss from the radar of 184 dB on the coastline and given a sufficiently elevated sensor
location (e.g. 25m) with a clear line-of-sight to the horizon.” WINNF-15-S-0112-V1.0.0 CBRS Operational
and Functional Requirements at 27, available online at
http://groups.winnforum.org/p/cm/ld/fid=85&tid=338&sid=5781.
9
  See 47 C.F.R. § 2.106; Table of Frequency Allocations (Mar. 4, 2016) at footnote US107.
10
   The sites are listed on the Commission’s website at
https://www.fcc.gov/general/35-ghz-band-protected-fixed-satellite-servicefss-earth-stations.
11
   See 47 C.F.R. § 96.17.
12
   See 47 C.F.R. § 2.106; Table of Frequency Allocations (Mar. 4, 2016) at footnote US109.
13
   Consistent with the proposed power levels for its experimental operations, Google will observe a 150
km exclusion zone instead of the 80 km exclusion required by 47 C.F.R. § 96.15(b)(2).
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out-of-band emissions from devices operating below 3500 MHz and above 3650
MHz. In general, Google will avoid operating in the 3650-3700 MHz band unless
necessary for the purpose of the experiment, as there are many incumbents in
this band segment in addition to the military radar operations.

       Protection of Part 90 Incumbents in the 3650-3700 MHz Band

         To protect existing Part 90 operations in the 3650-3700 MHz band,
Google will coordinate its proposed experimental transmissions in this band with
all Part 90 licensees in the Commission’s ULS database that are within 25 km of
a Google transmitter location. Because there are many Part 90 systems
operating in this band segment, and because Google plans to coordinate with
adjacent-band FSS sites, Google will generally avoid using the 3650-3700 MHz
band except when necessary to meet testing objectives, [REDACTED].

      Protection of FSS Receive-Only Earth Station Operations in the 3700-4200
MHz Band

        Numerous FSS receive-only earth stations operate in the 3700-4200 MHz
band (C-band). To protect such uses, Google will meet the protection
requirements for these systems as established in Part 96. Once again, Google
will conduct its calculations using the NTIA model. Google will meet the in-band
protection requirements in 47 C.F.R. § 96.17(a), extended to 3700-4200 MHz,
since Google will be operating in-band in this segment. In the event that Google’s
predictions show Part 96 limits may be exceeded for a particular site, Google will
coordinate with the operators of the affected earth station(s). As previously
noted, Google intends to avoid operations above 3600 MHz due to the number of
incumbents, unless such operations are necessary to meet the objectives of the
experiments.



                                      Figures

       The following figures show the locations of Google’s planned and
potential test areas relative to the locations of incumbents requiring interference
protection. The following key applies to the figures:

   ●   Green areas: Locations where Google plans to operate under the
       requested experimental authorization, if approved.
   ●   Blue areas: Locations where Google may operate under the requested
       experimental authorization, if approved.
   ●   Gold-colored areas: Protection zones for incumbent federal ground-based
       radar operations in the 3100-3500 MHz band.
   ●   Red lines: Coastal exclusion zones for incumbent U.S. military shipborne
       operations in the 3500-3650 MHz band.
   ●   Red circles: Exclusion zones for incumbent U.S. military R&D sites in the
       3650-3700 MHz band, calculated using a 150 km exclusion distance.

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●   Red dots: Incumbent FSS earth stations in the 3600-3700 MHz band.

    Figure 1: Nationwide view of planned and potential test areas




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                                     File No. 0539-EX-PL-2016


Figure 2: Close-up of San Francisco Bay area




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Figure 3: Close-up of Reston, VA area




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                                             Conclusion

               The proposed experimental operations will advance radio technologies
       associated with the new CBRS service and be conducted without harmful
       interference to other authorized users. For the foregoing reasons, Google
       requests approval of this application.



Exhibit C - Technical Information:

Google requests confidential treatment of the following underlined text from Exhibit C
that contain confidential and proprietary information regarding the proposed
tests/experiments:


       Applicant Name:         Google Inc.
       Applicant FRN:          0016069502


       Legal Contact Details

               Name of Contact        Stephanie Selmer
               Contact Details        Associate Corporate Counsel
                                      25 Massachusetts Avenue NW, Ninth Floor
                                      Washington, DC 20001



       Technical Contact Details

               Name of Contact        Dr. Andrew Clegg
               Contact Details        1875 Explorer Street, Tenth Floor
                                      Reston, VA 20190
                                      Phone: (202) 370-5644
                                      Email: aclegg@google.com




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Transmitter Equipment and Station Details
 Radio Information

       Equipment             [REDACTED]

       Quantity              [REDACTED]

       Area of Operation     Operations vary from 7 km to 40 km from the
                             geographic centerpoint of each test area. See
                             Exhibit B for the specific areas of operation.


       Frequency                                    High (MHz)      Low (MHz)
       [REDACTED]                                     3800             3400


 Amplifier Information

       Equipment             [REDACTED]

       Quantity              [REDACTED]

       Area of Operation     Operations vary from 7 km to 40 km from the
                             geographic centerpoint of each test area. See
                             Exhibit B for the specific areas of operation.

 Antenna Details

       Antennas              [REDACTED]

       Type                  Both directional and omnidirectional antennas
                             will be used.
       Quantity              [REDACTED]

       Gain                  30 dBi max; -4 dBi min
       Beam Width at         Various (5° to 360° Horizontal; 5° to 180° Vertical)
       Half-Power Point
       Orientation in        Various (0° to 360°)
       Horizontal Plane
       Orientation in        10° to -30°
       Vertical Plane



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                          Radio           Modulation    Emission Bandwidth Maximum        Maximum
                                                       Designator           Power         EIRP/ERP
                                                                             Out
                          [REDACTED]      Continuous   10H0N0N      10 Hz       50 W14     EIRP =
                                          waveform                                         47 dBW
                                                                                          (50 kW)14

                                                                                            ERP =
                                                                                          44.9 dBW
                                                                                          (31 kW)14

                                                                                           (with 30
                                                                                              dBi
                                                                                           antenna)



                          [REDACTED]        Digital    10M0W7D     10 MHz        10 W      For 10 W
                                                       20M0W7D     20 MHz        20 W     conducted:
                                                       40M0W7D     40 MHz        40 W        EIRP =
                                                       60M0W7D     60 MHz        60 W       27 dBW
                                                       80M0W7D     80 MHz        80 W       (500 W);
                                                                                              ERP =
                          [REDACTED]        Digital    10M0F9W     10 MHz        10 W
                                                                                           24.9 dBW
                                                       20M0F9W     20 MHz        20 W
                                                                                            (305 W)
                                                       40M0F9W     40 MHz        40 W
                                                       60M0F9W     60 MHz        60 W      For 20 W
                                                       80M0F9W     80 MHz        80 W     conducted:
                                                                                             EIRP =
                          [REDACTED]        Digital    10M0G7D     10 MHz        10 W       30 dBW
                                                       20M0G7D     20 MHz        20 W      (1000 W);
                                                       40M0G7D     40 MHz        40 W        ERP =
                                                       60M0G7D     60 MHz        60 W      27.9 dBW
                                                       80M0G7D     80 MHz        80 W       (611 W)
                          [REDACTED]        Digital    10M0GXW     10 MHz        10 W      For 40 W
                                                       20M0GXW     20 MHz        20 W     conducted:
                                                       40M0GXW     40 MHz        40 W        EIRP =
                                                       60M0GXW     60 MHz        60 W        33 dBW
                                                       80M0GXW     80 MHz        80 W      (2000 W);
                                                                                              ERP =
                                                                                           30.9 dBW
                                                                                            (1222 W)
                                                                                           For 60 W
                                                                                          conducted:
                                                                                            EIRP =
                                                                                           34.8 dBW
                                                                                           (3000 W);
                                                                                             ERP =
                                                                                           32.6 dBW

14
     High power operation limited to [REDACTED] in the 3550­3575 MHz band segment.
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                                                                                              (1833 W)
                                                                                             For 80 W
                                                                                            conducted:
                                                                                              EIRP =
                                                                                              36 dBW
                                                                                             (4000 W);
                                                                                               ERP =
                                                                                             33.9 dBW
                                                                                             (2444 W)

                                                                                            (all with 17
                                                                                                 dBi
                                                                                             antenna)
                         [REDACTED]         Digital     2M00P0N       2 MHz         4W         EIRP =
                                                                                              22 dBW
                         [REDACTED]         Digital     5M00Q7N        5 MHz        4W        (160 W)
                                                        10M0Q7N       10 MHz
                                                        20M0Q7N       20 MHz                  ERP =
                                                                                             19.9 dBW
                                                                                              (98 W)

                                                                                             (with 16
                                                                                                dBi
                                                                                             antenna)



2.      Identification of the Commission proceeding in which the information was submitted or
        a description of the circumstances giving rise to the submission.

       Exhibits A and C were submitted to the Commission in support of the Experimental
License. The exhibits were filed with the Office of Engineering and Technology on August 5,
2016. For additional information, please see File No. 0539-EX-PL-2016.


3.      Explanation of the degree to which the information is commercial or financial or
        contains a trade secret or is privileged.

        The information requested to be kept confidential has significant commercial value. The
exhibits supporting the Experimental License discuss tests/experiments that include trade
secret information. The Commission has clarified that confidential treatment should be
                           15
afforded to trade secrets. Google’s tests/experiments and proprietary wireless applications
using particular radio frequency equipment represent a “secret commercially valuable plan”
within the meaning of a trade secret as recognized by the Commission.


15
  Examination of Current Policy Concerning the Treatment of Confidential Information Submitted to the
Commission, Report and Order, GC Docket No. 96-55, at para. 3, (released Aug. 4, 1998) (defining “trade
secrets” for purpose of Commission rules on confidential treatment).
                                                            Request for Confidential Treatment - Page 15


                                                                    PUBLIC REDACTED VERSION

                                                                                      Google Inc.
                                                                        File No. 0539-EX-PL-2016


4.     Explanation of the degree to which the information concerns a service that is
       competitive.

       The services and technologies that are the subject of this Experimental License have not
yet been fully developed but are expected to lead to material developments in markets subject
to competition from multiple U.S. and non-U.S. third parties.


5.     Explanation of how disclosure of the information could result in substantial competitive
       harm.

        The technology under development is highly sensitive and confidential in nature. The
release of such information would provide valuable insight into Google’s technology innovations
and potential business plans and strategies. Public disclosure would jeopardize the value of the
technology under examination by enabling others to utilize Google’s information to develop
similar products in a similar time frame.


6.     Identification of any measures taken by the requesting party to prevent unauthorized
       disclosure.

        Google has taken steps to keep confidential the information set forth in the confidential
exhibits by limiting the number of people involved in the tests/experiments to only those on a
“need to know” basis, and by requiring any third parties involved in the testing process to
execute robust nondisclosure agreements.


7.     Identification of whether the information is available to the public and the extent of any
       previous disclosures of the information to any third parties.

        The information contained in the confidential exhibits is not available to the public, and
will only be disclosed to third parties pursuant to the restrictive safeguards described above.

         Google voluntarily provides the information to the Commission at this time with the
expectation that it will be treated confidentially in accordance with the Commission's rules. See
Critical Mass Energy Project v. Nuclear Regulatory Comm’n, 975 F.2d 871, 879 (D.C. Cir. 1992)
(commercial information provided on a voluntary basis “is ‘confidential’ for the purpose of
Freedom of Information Act (FOIA) Exemption 4 if it is of a kind that would customarily not be
released to the public by the person from whom it was obtained.”)


8.     Justification of the requested period of confidentiality.

        Google expects that confidential treatment will be necessary for the length of the
proposed experiment and thereafter in order to protect its evolving business and technology
strategies.

                                                        Request for Confidential Treatment - Page 16


                                                                    PUBLIC REDACTED VERSION

                                                                                      Google Inc.
                                                                        File No. 0539-EX-PL-2016


9.     Any other information that would be useful in assessing whether this request should be
       submitted.

       The information subject to this request for confidentiality should not be made available
for public disclosure at any time. There is nothing material that public review of this information
would add to the Commission’s analysis of Google’s request for an experimental authorization.

       Moreover, public disclosure of the sensitive information in the confidential exhibits to the
Experimental License after the Commission has ruled on the Request for Confidentiality is not
necessary for the Commission to fulfill its regulatory responsibilities.

       Consistent with 47 C.F.R. § 0.459(d)(l), Google requests notification if release of the
information subject to this request is requested pursuant to the FOIA or otherwise, so that
Google may have an opportunity to oppose grant of any such request.

Sincerely yours,




Stephanie Selmer




                                                        Request for Confidential Treatment - Page 17


                                                                          PUBLIC REDACTED VERSION

                                                                                             Google Inc.
                                                                               File No. 0539-EX-PL-2016
                                EXHIBIT A - NARRATIVE STATEMENT

       Consistent with the standards set forth in Section 5.63 of the Federal Communications
Commission’s (Commission’s) Rules, 47 C.F.R. § 5.63, Google Inc. (Google) requests
authorization to conduct radio experiments in support of developing Citizens Broadband Radio
Service (CBRS) technologies, using [REDACTED] experimental transmitters at up to 24 U.S.
locations. The experimental authorization is sought for a period of 24 months. Google outlines
below its need for the requested authorization and the reasons why it should be granted
expeditiously.

                                              Background

         In establishing the CBRS, the Commission opened a door for wireless innovation and
bandwidth abundance. Rather than allocating the 3.5 GHz band to a single use, the Commission
rightly decided to allow shared use of the spectrum. Users of the spectrum might, for instance,
deploy “small cell” networks that can carry heavy loads of data in high-traffic areas—such as
crowded stadiums—or offer fixed wireless broadband services in rural areas. The additional
spectrum that is now available in the 3.5 GHz band will also help relieve Wi-Fi
congestion—improving the experience of consumers accessing the Internet over wireless
broadband.

         A key component to sharing in this band is the Spectrum Access System (SAS), which
utilizes database technology to protect important federal government uses of spectrum. These
systems will ensure that neither priority access nor general authorized access users interfere
with the existing government and private users who will continue to need 3.5 GHz spectrum in a
limited number of areas. SAS database systems also will allow new users to share effectively
with each other. Google has been a leader in using databases to free-up available spectrum, and
it is one of the companies working to develop a sharing system for the 3.5 GHz band.

        The instant experimental authorization is needed to advance technologies in the 3.5 GHz
band. Specifically, the experimental authorization will allow Google to continue its
experimentation with propagation and [REDACTED]. As discussed further below, the parameters
of the experimental authorization will protect incumbent operators from harmful interference.
Indeed, there have been no reports of interference from Google’s ongoing experimental
operations under call signs WH2XNF (File Nos. 0722-EX-PL-2014 and 0004-EX-ML-2015) and
WI2XFG (File No. 0095-EX-PL-2016).1

        Google requests authorization to operate in and adjacent to the 3550-3700 MHz band
that has been opened for innovative small-cell spectrum sharing by CBRS devices. Google
requests authorization to operate on frequencies down to 3400 MHz and up to 3800 MHz so
that [REDACTED]. Authority to operate in this range will ensure that Google has access to
sufficient spectrum for experimentation while avoiding interference to incumbent operations,

1
  Call sign WH2XNF (File Nos. 0722-EX-PL-2014 and 0004-EX-ML-2015) is associated with 3550-3700
MHz operations in Mountain View, CA, Arlington, VA, and Reston, VA. That experimental authorization is
set to expire in December 2016. If this request for experimental authorization is granted, Google plans to
let its authorization under WH2XNF expire and experimental operations at those three locations would
continue under the new authorization.
                                                                                         Exhibit A - Page 1


                                                                      PUBLIC REDACTED VERSION

                                                                                        Google Inc.
                                                                          File No. 0539-EX-PL-2016
including federal government operations and operations under Parts 25 and 90 of the
Commission’s rules.

        The proposed experimentation will allow Google to perform propagation, [REDACTED]
testing [REDACTED]. Data obtained from these tests will be reflected in the design of Google’s
commercial SAS, which is currently under development to serve users in the new CBRS band.
Specifically, together with testing under call signs WH2XNF and WI2XFG, the proposed testing
will assist in enabling: (1) [REDACTED]; (2) [REDACTED]; and (3) [REDACTED]. [REDACTED].
[REDACTED].

                                        Planned Operations

       Google anticipates performing the following tests under the requested experimental
authorization. As described in the next section, the proposed experimental operations in the 3.5
GHz band will be conducted without harmful interference to other authorized users.

   ●   Propagation Testing: Google will use both a simple continuous wave (CW) tone and a
       broadband signal to understand the effects of clutter loss, differential fading, multipath,
       and other propagation phenomena. To test [REDACTED], Google will use a mobile
       receiving station [REDACTED]. Google may also position [REDACTED]. In each local test
       area, Google will generally operate only [REDACTED] while conducting propagation tests.

   ●   Testing of [REDACTED]: Google will test [REDACTED]. In Atlanta, Austin, and Provo,
       Google will use [REDACTED].

   ●   [REDACTED] Testing: Google will [REDACTED]. [REDACTED].

   ●   [REDACTED] Testing: Google will investigate [REDACTED].

        In order to perform these tests, Google seeks authorization to operate [REDACTED]
experimental transmitters per test area. Specifically, Google seeks authorization for [REDACTED]
eNodeBs (also referred to as access points or base stations) and [REDACTED] end user devices
(EUDs) that will communicate with the eNodeBs ([REDACTED] EUDs per [REDACTED] eNodeB on
average). Google will deploy this equipment [REDACTED] within the proposed areas of
operation. It is unlikely that [REDACTED], or the full number of authorized devices, will ever
transmit simultaneously. Rather, the full complement of test areas is needed to ensure sufficient
diversity of test environments.

         Google requests authorization to transmit in a variety of locations and environments that
meet several characteristics, including the radio propagation environment, height and variety of
clutter (buildings and foliage), existence of suitable Google infrastructure and resources to
support experimentation, and existence of partners who may participate in the tests. To that
end, Google requests authorization to conduct testing in up to 24 U.S. areas. The test areas will
be selected from the list of locations in Exhibit B. All test areas will be subject to the same limit
of [REDACTED] experimental transmitters, and none of the areas will have a radius of operations
greater than 40 kilometers. See Exhibit B for the proposed radius of operation for each of the
potential test locations.

       From the list in Exhibit B, Google plans to deploy initially in Atwater, California, Mountain

                                                                                    Exhibit A - Page 2


                                                                         PUBLIC REDACTED VERSION

                                                                                           Google Inc.
                                                                             File No. 0539-EX-PL-2016
View, California, Palo Alto, California, San Bruno, California, San Francisco, California, San Jose,
California, Boulder, Colorado, Kansas City, Kansas,2 Omaha, Nebraska, Raleigh, North Carolina,
Provo, Utah, and Reston, Virginia.

       EUDs operating under the requested authorization will be used by Google’s employees
and contractors. Such devices may also be used, under close supervision, by “trusted testers”
selected by Google on a volunteer basis without payment. No commercial operations will be
conducted under the requested authorization and all equipment will be collected at the end of
the experimentation period.

                                         Interference Analysis

       The 3400-3800 MHz frequency range covers multiple allocated bands and a variety of
incumbent systems and services. As described below, Google will deploy and operate its
equipment under this experimental authorization in a manner that will avoid interference to
other authorized users.

        Transmit Power and Out-of-Band Emission Considerations

        Most operations under this experimental authorization will be conducted within the Part
96 Category B CBSD EIRP limit of 47 dBm per 10 MHz. Experimentation will also be conducted
within the Category A CBSD EIRP limit of 30 dBm per 10 MHz. [REDACTED], Google requests
authorization to operate up to a conducted power spectral density (PSD) limit of 40 dBm per 10
MHz and a radiated PSD of 57 dBm per 10 MHz. [REDACTED], Google also requests
authorization to operate up to a total conducted power limit of 49 dBm [40 dBm + 10log(8)] and
a maximum radiated power (EIRP) of 66 dBm. The requested maximum conducted and radiated
power limits will provide flexibility to support a wide range of complementary advanced
technology development and experimentation. [REDACTED].3 [REDACTED]. [REDACTED].

         Additionally, Google requests authority to conduct narrowband propagation testing in the
3550-3575 MHz segment using a maximum conducted power of 47 dBm and a maximum
radiated power of 77 dBm (assuming the use of a high-gain, narrow beamwidth 30 dBi antenna).
[REDACTED]. [REDACTED]. Google notes that extensive propagation testing has been conducted
in this band under its existing experimental authorization (call sign WH2XNF) in the densely
populated areas of Arlington, Virginia, and Mountain View, California, with no reports of
interference. Google has chosen the 3550-3575 MHz portion as it is removed by at least 75 MHz
from the nearest adjacent-band allocation. Furthermore, the possibility of interference to
authorized users of the band will be mitigated by using narrow beamwidth antennas and
narrowband CW transmissions, along with out-of-band emission levels that will meet or exceed
(i.e., be lower than) the limits in Section 96.41(e) of the Commission’s Rules, 47 C.F.R. §
96.41(e).

        In summary, Google requests authorization to operate up to the following power limits:


2
  Call sign WI2XFG (File No. 0095-EX-PL-2016) is associated with 3400-3700 MHz operations in the
Kansas City area. In the present application, Google requests authority to operate up to 3800 MHz in a
limited section of Kansas City, KS.
3
  See [REDACTED].
                                                                                        Exhibit A - Page 3


                                                                     PUBLIC REDACTED VERSION

                                                                                       Google Inc.
                                                                         File No. 0539-EX-PL-2016

Planned Testing                     Conducted Power Limits       Radiated Power Limits
Broadband Network (3400-3800        40 dBm per 10 MHz            57 dBm per 10 MHz radiated
MHz)                                power spectral density       power spectral density

                                    49 dBm total conducted       66 dBm total radiated power
                                    power (assumes eight         (assumes eight 10-MHz
                                    10-MHz aggregate             aggregate channels)
                                    channels)
Narrowband Propagation              47 dBm                       77 dBm
(3550-3575 MHz)


      Below, Google explains its plans for protection of the following incumbent users in the
3400-3800 MHz frequency range.

    Frequencies                                    Users

    3400-3500 MHz                                  Military radar systems
                                                   Amateur radio

    3500-3650 MHz                                  Shipborne military radar systems

    3600-3700 MHz                                  Grandfathered FSS receive-only earth
                                                   stations

    3650-3700 MHz                                  Ground-based military radar systems
                                                   Part 90, Subpart Z operators

    3700 MHz                                       FSS receive-only earth stations


         Protection of Military Radar Systems Below 3500 MHz

       In the 3100-3500 MHz band, the U.S. military operates radar systems on ships and at
several land-based military installations around the country. To protect such uses, Google will
ensure that the signals from its experimental operations remain at or below levels that would
reasonably preclude the possibility of interference. Specifically, for all test locations within the
coastal exclusion zones (see Figures 1-3 below) or within 150 km of an in-land operations area,
Google will use the NTIA propagation model that was used to compute the coastal exclusion
zones4 (hereafter referred to as the NTIA model) to predict the aggregate interference from its
deployed transmitters operating at or below 3550 MHz to the closest point of the military
operations area (coastal or land-based) and will limit its signal strength to at or below the
ambient noise level of -174 dBm/Hz at that point, as received by an isotropic antenna. In the

4
 The model is described on the NTIA website at
https://www.ntia.doc.gov/report/2015/35-ghz-exclusion-zone-analyses-and-methodology.
                                                                                     Exhibit A - Page 4


                                                                           PUBLIC REDACTED VERSION

                                                                                              Google Inc.
                                                                                File No. 0539-EX-PL-2016
calculation, Google will include both fundamental emissions below 3500 MHz and out-of-band
emissions from devices operating above 3500 MHz.

        Amateur Radio Operations in 3400-3500 MHz

        The amateur radio service has a secondary allocation in the 3300-3500 MHz band (3.4
GHz band). Based on Google’s spectrum monitoring elsewhere in the U.S., amateur operation in
this band appears to be infrequent and generally point-to-point. However, Google will coordinate
with the amateur radio community to ensure that Google’s operations do not interfere with any
amateurs who may be utilizing the 3.4 GHz band. For example, Google will inform the American
Radio Relay League prior to beginning operations in each area and provide contact information
so they can report any suspected interference.

        Protection of Shipborne Military Radar Systems in 3500-3650 MHz

        In the 3500-3650 MHz band, the U.S. military operates shipborne radars in coastal areas.
To protect such uses, Google will ensure that the signals from the experimental operations
remain at or below levels that would reasonably preclude the possibility of interference.
Alternatively, if operating such that the signals could exceed the interference threshold at the
coast, Google will operate a sensor to detect military radar operations and reconfigure its
devices to avoid those frequencies during the operations.

        Specifically, for all test locations within the coastal exclusion zones established by the
Commission5 (see Figures 1-3 below), Google will use the NTIA model to predict the aggregate
interference from its deployed transmitters to the closest point on the coast6 and limit the signal
strength to at or below the ambient noise level of -174 dBm/Hz at that point, as received by an
isotropic antenna. In the calculation, Google will include both fundamental emissions in
3500-3650 MHz and out-of-band emissions from devices operating below 3500 MHz and above
3650 MHz. If the signal level is predicted to exceed -174 dBm/Hz at the closest point on the
coast, Google will deploy a sensor to detect military radar operations offshore and configure its
devices to avoid the frequency at which the military is operating, and +/-5 MHz on either side.
This is consistent with the operational concept of the ESC in the Part 96 rules.7 Google will use a
prototype ESC sensor for this purpose, which will be designed to meet the WinnForum
requirements on ESC sensitivity.8

5
  See 47 C.F.R. §§ 96.15(a)(1), 96.15(a)(3), 96.15(b); see also Letter from Paige Atkins, Associate
Administrator, Office of Spectrum Management, National Telecommunications and Information
Administration, to Marlene H. Dortch, Secretary, FCC, GN Docket No. 12-354, at Enclosure 1 (proposing
exclusion zones to protect shipborne radars).
6
  In the event of unusual local geography (e.g., a hill or mountain that blocks the path to the nearest point
on the coast but does not block other paths starting a short distance from that point), Google will analyze
paths to a range of points on the coast and ensure that its signal does not exceed the interference
threshold at any of those points.
7
  See 47 C.F.R. § 96.67.
8
  Specifically, “[a]n ESC shall be capable of detecting an in-band incumbent radar over a maximum
propagation loss from the radar of 184 dB on the coastline and given a sufficiently elevated sensor
location (e.g. 25m) with a clear line-of-sight to the horizon.” WINNF-15-S-0112-V1.0.0 CBRS Operational
and Functional Requirements at 27, available online at
http://groups.winnforum.org/p/cm/ld/fid=85&tid=338&sid=5781.
                                                                                           Exhibit A - Page 5


                                                                         PUBLIC REDACTED VERSION

                                                                                            Google Inc.
                                                                              File No. 0539-EX-PL-2016
        Protection of Grandfathered FSS Receive-Only Earth Station Operations in 3600-3700 MHz

        In the 3600-3700 MHz band, FSS receive-only earth stations operate on a grandfathered
basis in accordance with the FCC’s rules.9 The earth stations are located at 35 sites that are
largely clustered along the coasts.10 For all test areas subject to Grandfathered FSS Operations
protection requirements (see Figures 1-3 below), Google will meet the Part 96 requirements11
and will conduct its calculations using the NTIA model. In the event that Google’s predictions
show that the Part 96 limits may be exceeded for a particular site, Google will coordinate with
the operators of the affected earth station(s).

        Protection of Ground-based Military Radar Systems in 3650-3700 MHz

        In the 3650-3700 MHz band, the U.S. military conducts research and development (R&D)
activity at three land-based sites whose coordinates are listed in the FCC’s rules.12 To protect
such uses, Google will ensure that the signals from its experimental operations remain at or
below levels that would reasonably preclude the possibility of interference. Specifically, for all
test locations within 150 km of the R&D sites,13 Google will use the NTIA model to predict the
aggregate interference from its deployed transmitters to the R&D sites and will limit its signal
strength to at or below the ambient noise level of -174 dBm/Hz at that point, as received by an
isotropic antenna. In the calculation, Google will include both fundamental emissions in
3500-3650 MHz and out-of-band emissions from devices operating below 3500 MHz and above
3650 MHz. In general, Google will avoid operating in the 3650-3700 MHz band unless necessary
for the purpose of the experiment, as there are many incumbents in this band segment in
addition to the military radar operations.

        Protection of Part 90 Incumbents in the 3650-3700 MHz Band

        To protect existing Part 90 operations in the 3650-3700 MHz band, Google will
coordinate its proposed experimental transmissions in this band with all Part 90 licensees in the
Commission’s ULS database that are within 25 km of a Google transmitter location. Because
there are many Part 90 systems operating in this band segment, and because Google plans to
coordinate with adjacent-band FSS sites, Google will generally avoid using the 3650-3700 MHz
band except when necessary to meet testing objectives, [REDACTED].

        Protection of FSS Receive-Only Earth Station Operations in the 3700-4200 MHz Band

        Numerous FSS receive-only earth stations operate in the 3700-4200 MHz band (C-band).
To protect such uses, Google will meet the protection requirements for these systems as
established in Part 96. Once again, Google will conduct its calculations using the NTIA model.
Google will meet the in-band protection requirements in 47 C.F.R. § 96.17(a), extended to
3700-4200 MHz, since Google will be operating in-band in this segment. In the event that

9
  See 47 C.F.R. § 2.106; Table of Frequency Allocations (Mar. 4, 2016) at footnote US107.
10
   The sites are listed on the Commission’s website at
https://www.fcc.gov/general/35-ghz-band-protected-fixed-satellite-servicefss-earth-stations.
11
   See 47 C.F.R. § 96.17.
12
   See 47 C.F.R. § 2.106; Table of Frequency Allocations (Mar. 4, 2016) at footnote US109.
13
   Consistent with the proposed power levels for its experimental operations, Google will observe a 150
km exclusion zone instead of the 80 km exclusion required by 47 C.F.R. § 96.15(b)(2).
                                                                                        Exhibit A - Page 6


                                                                  PUBLIC REDACTED VERSION

                                                                                    Google Inc.
                                                                      File No. 0539-EX-PL-2016
Google’s predictions show Part 96 limits may be exceeded for a particular site, Google will
coordinate with the operators of the affected earth station(s). As previously noted, Google
intends to avoid operations above 3600 MHz due to the number of incumbents, unless such
operations are necessary to meet the objectives of the experiments.



                                            Figures

        The following figures show the locations of Google’s planned and potential test areas
relative to the locations of incumbents requiring interference protection. The following key
applies to the figures:

   ●   Green areas: Locations where Google plans to operate under the requested experimental
       authorization, if approved.
   ●   Blue areas: Locations where Google may operate under the requested experimental
       authorization, if approved.
   ●   Gold-colored areas: Protection zones for incumbent federal ground-based radar
       operations in the 3100-3500 MHz band.
   ●   Red lines: Coastal exclusion zones for incumbent U.S. military shipborne operations in
       the 3500-3650 MHz band.
   ●   Red circles: Exclusion zones for incumbent U.S. military R&D sites in the 3650-3700 MHz
       band, calculated using a 150 km exclusion distance.
   ●   Red dots: Incumbent FSS earth stations in the 3600-3700 MHz band.




                                                                               Exhibit A - Page 7


                                                 PUBLIC REDACTED VERSION

                                                                   Google Inc.
                                                     File No. 0539-EX-PL-2016
Figure 1: Nationwide view of planned and potential test areas




                                                                Exhibit A - Page 8


                                        PUBLIC REDACTED VERSION

                                                             Google Inc.
                                               File No. 0539-EX-PL-2016
Figure 2: Close-up of San Francisco Bay area




                                                        Exhibit A - Page 9


                                        PUBLIC REDACTED VERSION

                                                         Google Inc.
                                           File No. 0539-EX-PL-2016
Figure 3: Close-up of Reston, VA area




                                                   Exhibit A - Page 10


                                                                PUBLIC REDACTED VERSION

                                                                                  Google Inc.
                                                                    File No. 0539-EX-PL-2016


                                         Conclusion

        The proposed experimental operations will advance radio technologies associated with
the new CBRS service and be conducted without harmful interference to other authorized users.
For the foregoing reasons, Google requests approval of this application.




                                                                            Exhibit A - Page 11


                                                                                    Google Inc.
                                                                      File No. 0539-EX-PL-2016


                         EXHIBIT B - LIST OF POTENTIAL TEST LOCATIONS

Google requests authorization to operate in the following geographic areas:

                       City               Geographic Centerpoint         Radius of
                                                                         Operations
         ARIZONA
           Phoenix                    33° 26’ 54” N, 112° 4’ 27” W            30 km
         CALIFORNIA
           Atwater                    37° 22’ 14” N, 120° 34’ 29” W           30 km
           Los Angeles                33° 59’ 43” N, 118° 28’ 35” W           10 km
           Mountain View              37° 25’ 16” N, 122° 4’ 14” W            10 km
           Palo Alto                  37° 26’ 12” N, 122° 9’ 38” W            10 km
           San Bruno                  37° 37’ 42” N, 122° 25’ 36” W           10 km
           San Francisco              37° 45’ 26” N, 122° 26’ 32” W           7 km
           San Jose                   37° 20’ 14” N, 121° 52’ 58” W           10 km
         COLORADO
           Boulder                    40° 0’ 27” N, 105° 15’ 43” W            30 km
         FLORIDA
           Tampa                      27° 56’ 59” N, 82° 27’ 26” W            30 km
         GEORGIA
           Atlanta                    33° 54’ 42” N, 84° 21’ 26” W            30 km
         ILLINOIS
           Chicago                    41° 52’ 41” N, 87° 37’ 48” W            30 km
         IOWA
           Des Moines                 41° 35’ 36” N, 93° 39’ 51” W            30 km
         KANSAS
           Kansas City                39° 7’ 34” N, 94° 49’ 34” W             5 km
         NEBRASKA
           Omaha                      41° 15’ 28” N, 95° 56’ 8” W             30 km
         NEVADA
           Las Vegas                  36° 11’ 12” N, 115° 8’ 23” W            30 km
         NEW YORK
           New York                   40° 45’ 0” N, 73° 59’ 37” W             30 km
         NORTH CAROLINA

                                                                                 Exhibit B - Page 1


                                                               Google Inc.
                                                 File No. 0539-EX-PL-2016


 Raleigh         35° 47’ 44” N, 78° 30’ 55” W         30 km
OKLAHOMA
 Oklahoma City   35° 28’ 8” N, 97° 30’ 53” W          30 km
OREGON
 Portland        45° 31’ 26” N, 122° 40’ 10” W        30 km
TEXAS
 Austin          30° 13’ 0” N, 97° 45’ 4” W           30 km
UTAH
 Provo           40° 14’ 29” N, 111° 42’ 44” W        30 km
VIRGINIA
 Blacksburg      37° 13’ 40” N, 80° 25’ 20” W         30 km
 Reston          38° 57’ 31” N, 77° 21’ 33” W         40 km




                                                          Exhibit B - Page 2


                                                                     PUBLIC REDACTED VERSION

                                                                                       Google Inc.
                                                                         File No. 0539-EX-PL-2016


                             EXHIBIT C - TECHNICAL INFORMATION

Applicant Name:         Google Inc.
Applicant FRN:          0016069502


Legal Contact Details

    Name of Contact       Stephanie Selmer
    Contact Details       Associate Corporate Counsel
                          25 Massachusetts Avenue NW, Ninth Floor
                          Washington, DC 20001



Technical Contact Details

    Name of Contact       Dr. Andrew Clegg
    Contact Details       1875 Explorer Street, Tenth Floor
                          Reston, VA 20190
                          Phone: (202) 370-5644
                          Email: aclegg@google.com



Transmitter Equipment and Station Details
 Radio Information

    Equipment                      [REDACTED]
    Quantity                       [REDACTED]
    Area of Operation              Operations vary from 7 km to 40 km from the geographic
                                   centerpoint of each test area. See Exhibit B for the specific
                                   areas of operation.


    Frequency                                                 High (MHz)          Low (MHz)
    [REDACTED]                                                   3800                3400

 Amplifier Information

    Equipment                                [REDACTED]
    Quantity                                 [REDACTED]
    Area of Operation                        Operations vary from 7 km to 40 km from the
                                             geographic centerpoint of each test area. See

                                                                                  Exhibit C - Page 1


                                                                       PUBLIC REDACTED VERSION

                                                                                        Google Inc.
                                                                          File No. 0539-EX-PL-2016


                                             Exhibit B for the specific areas of operation.

    Antenna Details

       Antennas                              [REDACTED]
       Type                                  Both directional and omnidirectional antennas will
                                             be used.
       Quantity                              [REDACTED]
       Gain                                  30 dBi max; -4 dBi min
       Beam Width at Half-Power Point        Various (5° to 360° Horizontal; 5° to 180° Vertical)
       Orientation in Horizontal Plane       Various (0° to 360°)
       Orientation in Vertical Plane         10° to -30°


       Radio                 Modulation     Emission       Bandwidth   Maximum        Maximum
                                           Designator                  Power Out      EIRP/ERP
       [REDACTED]            Continuous     10H0N0N          10 Hz       50 W1          EIRP =
                              waveform                                                 47 dBW
                                                                                       (50 kW)1

                                                                                       ERP =
                                                                                      44.9 dBW
                                                                                      (31 kW)1

                                                                                     (with 30 dBi
                                                                                      antenna)



       [REDACTED]               Digital    10M0W7D          10 MHz       10 W         For 10 W
                                           20M0W7D          20 MHz       20 W        conducted:
                                           40M0W7D          40 MHz       40 W           EIRP =
                                           60M0W7D          60 MHz       60 W          27 dBW
                                           80M0W7D          80 MHz       80 W         (500 W);
                                                                                         ERP =
       [REDACTED]               Digital    10M0F9W          10 MHz       10 W
                                                                                      24.9 dBW
                                           20M0F9W          20 MHz       20 W
                                                                                       (305 W)
                                           40M0F9W          40 MHz       40 W
                                           60M0F9W          60 MHz       60 W         For 20 W
                                           80M0F9W          80 MHz       80 W        conducted:


1
    High power operation limited to [REDACTED] in the 3550­3575 MHz band segment.
                                                                                     Exhibit C - Page 2


                                          PUBLIC REDACTED VERSION

                                                           Google Inc.
                                             File No. 0539-EX-PL-2016


[REDACTED]   Digital   10M0G7D   10 MHz     10 W         EIRP =
                       20M0G7D   20 MHz     20 W        30 dBW
                       40M0G7D   40 MHz     40 W       (1000 W);
                       60M0G7D   60 MHz     60 W          ERP =
                       80M0G7D   80 MHz     80 W       27.9 dBW
                                                        (611 W)
[REDACTED]   Digital   10M0GXW   10 MHz     10 W
                       20M0GXW   20 MHz     20 W        For 40 W
                       40M0GXW   40 MHz     40 W      conducted:
                       60M0GXW   60 MHz     60 W         EIRP =
                       80M0GXW   80 MHz     80 W        33 dBW
                                                       (2000 W);
                                                         ERP =
                                                       30.9 dBW
                                                        (1222 W)
                                                       For 60 W
                                                      conducted:
                                                        EIRP =
                                                       34.8 dBW
                                                       (3000 W);
                                                         ERP =
                                                       32.6 dBW
                                                       (1833 W)
                                                       For 80 W
                                                      conducted:
                                                        EIRP =
                                                        36 dBW
                                                       (4000 W);
                                                         ERP =
                                                       33.9 dBW
                                                       (2444 W)

                                                     (all with 17 dBi
                                                         antenna)
[REDACTED]   Digital   2M00P0N   2 MHz      4W           EIRP =
                                                        22 dBW
[REDACTED]   Digital   5M00Q7N   5 MHz      4W
                                                        (160 W)
                       10M0Q7N   10 MHz
                       20M0Q7N   20 MHz
                                                        ERP =
                                                       19.9 dBW
                                                        (98 W)




                                                      Exhibit C - Page 3


PUBLIC REDACTED VERSION

                 Google Inc.
   File No. 0539-EX-PL-2016


            (with 16 dBi
             antenna)




            Exhibit C - Page 4



Document Created: 0000-00-00 00:00:00
Document Modified: 0000-00-00 00:00:00

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