Request for Confidential Treatment and Exhibits PUBLIC

0613-EX-PL-2015 Text Documents

Google Inc.

2015-09-28ELS_167586

                                                                  PUBLIC REDACTED VERSION

                                                                                       Google Inc.
                                                                        File No. 0613­EX­PL­2015


Date:                   September 28, 2015

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

FCC File Number:        0613­EX­PL­2015



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 above­referenced application for a New 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, B, 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 (FCC’s or Commission’s) Rules, 47 C.F.R. § 5.63,
               Google Inc. (Google) requests a New Experimental Radio Service License
               (Experimental License) and outlines below the compelling reasons why
               0613­EX­PL­2015 should be granted expeditiously.

                  Consistent with 0092­EX­ST­2015, Google seeks to continue to operate a
               GPS re­radiating kit within a confined and carefully controlled industrial indoor

                                                          Request for Confidential Treatment ­ Page 1


                                                         PUBLIC REDACTED VERSION

                                                                              Google Inc.
                                                               File No. 0613­EX­PL­2015


    environment. In doing so, Google will continue to [REDACTED]. This will allow
    Google to continue to [REDACTED].

         The GPS re­radiator covered by this Experimental License will continue to
    have an antenna mounted to a 15­meter roof to receive GPS signals, cable from
    the roof to the indoor location, amplifier, and passive re­radiating antenna. The
    re­radiating antenna will continue to be mounted to the ceiling of the room at nine
    meters from the ground and face downward over the test setup. The passive
    re­radiating antenna will continue to provide GPS information to [REDACTED].
    This test set­up will continue to allow Google to mitigate potential interference
    risks between different components.

          The proposed operations will continue to be conducted without harmful
    interference to other authorized users, and Google is prepared to coordinate with
    any federal users as necessary. The re­radiation system will continue to be
    located indoors, in a large, secure structure. The system will continue to be
    positioned at least 20 feet from the nearest outside wall of the building. The
    worst­case signal strength at 100 feet from the re­radiating antenna will continue
    to be 6 dB below the maximum allowed power of ­140 dBm/24 MHz. Given the
    low signal strength and the positioning of the system within the structure, the
    likelihood of any interference occurring continues to be very low. In particular,
    because the re­radiating antenna will be operating indoors in a Google­controlled
    facility, this signal will be attenuated by building loss, further reducing any minimal
    likelihood of harmful interference outside that facility. Furthermore, Google has
    conducted similar tests in this area under a grant of special temporary authority,
    and no disruptions were been noted.

         As demonstrated in Exhibit C, the proposed experimental operations will
    continue to be conducted in accordance with technical requirements that the
    National Telecommunications and Information Administration (NTIA) has
    established for federal agencies’ use of GPS re­radiators. Satisfaction of these
    guidelines, although not required for the requested Commission authorization,
    further demonstrates that the experimentation will continue to be conducted
    without risk of harmful interference to other users.

         For these reasons, Google requests approval of this Experimental License.

Exhibit B ­ Technical Information

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




                                                Request for Confidential Treatment ­ Page 2


                                                   PUBLIC REDACTED VERSION

                                                                        Google Inc.
                                                         File No. 0613­EX­PL­2015


Legal Contact Details

Name of Contact         Megan Anne Stull
Contact Details         Counsel
                        25 Massachusetts Avenue NW, Ninth Floor
                        Washington DC 20001


Technical Contact Details

Name of Contact         Paul Miller
Contact Details         2175 Monarch Street
                        Alameda, CA 94501
                        Phone: (619) 871­6246
                        Email: paulmi@google.com


Transmitter Equipment and Station Details
Radio Information

 Equipment                    [REDACTED]
 Quantity                     [REDACTED]
 Area of Operation            Operation not to exceed 0.05 km from the
                              following geographic centerpoint:

                                  ●   37° 46' 58" N, 122° 18' 27" W


 Frequencies                                                 MHz
 [REDACTED]                                             1575.42 MHz
 [REDACTED]                                             1227.60 MHz

Antenna Details

 Antennas
 Type                                 Omnidirectional
 Quantity                             [REDACTED]
 Gain                                 3.5 dBi




                                           Request for Confidential Treatment ­ Page 3


                                                                  PUBLIC REDACTED VERSION

                                                                                       Google Inc.
                                                                        File No. 0613­EX­PL­2015



            Radio            Modulation       Emission      Bandwidth      Maximum Maximum
                                             Designator                     Power   EIRP
                                                                             Out
            [REDACTED]          N/A          24M0G1D           N/A        6.2E­12 W        ­108.6
                               (GPS                           (GPS                          dBW
                            amplification)                 amplification)



        Exhibit C ­ Technical Information: Technical Guidelines for GPS Re­Radiators

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

                  In connection with its request for a New Experimental Radio Service License
             (Experimental License) (0613­EX­PL­2015), Google Inc. submits the following
             information to demonstrate its satisfaction of the technical requirements the
             National Telecommunications and Information Administration (NTIA) has
             established for federal agencies’ use of GPS re­radiators, as set out in Section
             8.3.28 of the NTIA Manual of Regulations and Procedures for Federal Radio
             Frequency Management.1



                 Section 8.3.28(a): Individual authorization is for indoor use only, and is
             required for each device at a specific site.

                   The device will continue to be used indoors, within a masonry structure. It
             will be located at [REDACTED] (37° 46' 58" N, 122° 18' 27" W).



                  Section 8.3.28(d): The maximum length of the assignment will be two years,
             with possible renewal.

                 Google is seeking an Experimental License for two years.




1
 National Telecommunications and Information Administration, Manual of Regulations and
Procedures for Federal Radio Frequency Management § 8.3.28 (2014), available at
http://www.ntia.doc.gov/files/ntia/publications/redbook/2014­05/8_14_5.pdf.
                                                          Request for Confidential Treatment ­ Page 4


                                                  PUBLIC REDACTED VERSION

                                                                       Google Inc.
                                                        File No. 0613­EX­PL­2015


     Section 8.3.28(e): The area of potential interference to GPS reception (e.g.,
military or contractor facility) has to be under the control of the user.

    Google leases the building where the GPS repeater will continue to be placed
under an agreement that extends beyond 2015. Google will continue to control
access to the building at all times covered by the requested Experimental License.



      Section 8.3.28(f): The maximum equivalent isotropically radiated power
(EIRP) must be such that the calculated emissions are no greater than ­140
dBm/24 MHz as received by an isotropic antenna at a distance of 100 feet (30
meters) from the building where the test is being conducted. The calculations
showing compliance with this requirement must be provided with the application
for frequency assignment and should be based on free space propagation with no
allowance for additional attenuation (e.g., building attenuation).

    Google’s analysis demonstrating compliance with these limits is set forth
below.

  ­130 dBm     GPS power at the receiving antenna
  +40 dB       Receiving antenna pre­amplifier
  ­5.1 dB      Cable loss (100 ft. LMR­400)
  +33 dB       Maximum power amplifier gain (+24 dB nominal)
  ­10 dB       Fixed attenuator
  ­4.9 dB      Variable attenuator
  ­5.1 dB      Cable loss (100 ft LMR­400)
  +3.5 dBi     Transmitting antenna peak gain
  ­78.6 dBm    Equivalent EIRP from the re­radiator

Calculation of loss for free space propagation using ITU model:

Free space loss (dB) = 20log(f) + 20log(d) – 27.54

Where:
  d (Distance in meters from re­radiating antenna to 100 ft outside the building) =
  36 m
  f (Carrier frequency in MHz) = 1575.24 MHz

  ­67.5 dB     Free space gain at 100 ft from the building
  ­78.6 dBm    Equivalent EIRP from the re­radiator


                                          Request for Confidential Treatment ­ Page 5


                                                                PUBLIC REDACTED VERSION

                                                                                     Google Inc.
                                                                      File No. 0613­EX­PL­2015


                ­146.1 dBm Received power 100 ft from the building (less than ­140 dBm
                required)



             Section 8.3.28(g): GPS users in the area of potential interference to GPS
             reception must be notified that GPS information may be impacted for periods of
             time.

                  During the period covered by the Experimental License, Google will continue
             to post prominent signage on the exterior of the building notifying GPS users that
             GPS information may be impacted for periods of time during testing.



             Section 8.3.28(h): The use is limited to activity for the purpose of testing RNSS
             equipment/systems.

                  Activities under the Experimental License will continue to be limited to those
             related to testing RNSS equipment/systems.



             Section 8.3.28(i): A "Stop Buzzer" point of contact for the authorized device must
             be identified and available at all times during GPS re­radiation operation of the
             device under any condition.

                 Google’s point of contact for the experiment continues to be Paul Miller. His
             contact information is as follows: 2175 Monarch Street, Alameda, CA 94501, (619)
             871­6246.


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, B, 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 September
28, 2015. For additional information, please see File No. 0613­EX­PL­2015.


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

                                                        Request for Confidential Treatment ­ Page 6


                                                                    PUBLIC REDACTED VERSION

                                                                                         Google Inc.
                                                                          File No. 0613­EX­PL­2015


information. The Commission has clarified that confidential treatment should be afforded to
              2
trade secrets. Google’s tests/experiments represent a “secret commercially valuable plan”
within the meaning of a trade secret as recognized by the Commission.


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 non­U.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 will require that any third parties involved in any preliminary analysis
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
2
  Examination of Current Policy Concerning the Treatment of Confidential Information Submitted to the
Commission, Report and Order, GC Docket No. 96­55, at para. 3, (released Aug. 4, 1998) (defining “trade
secrets” for purpose of Commission rules on confidential treatment).
                                                           Request for Confidential Treatment ­ Page 7


                                                                  PUBLIC REDACTED VERSION

                                                                                       Google Inc.
                                                                        File No. 0613­EX­PL­2015


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.


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 License.

       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,



Megan Anne Stull




                                                          Request for Confidential Treatment ­ Page 8


                                                                 PUBLIC REDACTED VERSION

                                                                                      Google Inc.
                                                                       File No. 0613­EX­PL­2015


                            EXHIBIT A – NARRATIVE STATEMENT

    Consistent with the standards set forth in Section 5.63 of the Federal Communications
Commission’s (FCC’s or Commission’s) Rules, 47 C.F.R. § 5.63, Google Inc. (Google) requests
a New Experimental Radio Service License (Experimental License) and outlines below the
compelling reasons why 0613­EX­PL­2015 should be granted expeditiously.

      Consistent with 0092­EX­PL­2015, Google seeks to continue to operate a GPS re­radiating
kit within a confined and carefully controlled industrial indoor environment. In doing so, Google
will continue to [REDACTED]. This will allow Google to continue to [REDACTED].

     The GPS re­radiator covered by this Experimental License will continue to have an antenna
mounted to a 15­meter roof to receive GPS signals, cable from the roof to the indoor location,
amplifier, and passive re­radiating antenna. The re­radiating antenna will continue to be
mounted to the ceiling of the room at nine meters from the ground and face downward over the
test setup. The passive re­radiating antenna will continue to provide GPS information to
[REDACTED]. This test set­up will continue to allow Google to mitigate potential interference
risks between different components.

     The proposed operations will continue to be conducted without harmful interference to other
authorized users, and Google is prepared to coordinate with any federal users as necessary.
The re­radiation system will continue to be located indoors, in a large, secure structure. The
system will continue to be positioned at least 20 feet from the nearest outside wall of the
building. The worst­case signal strength at 100 feet from the re­radiating antenna will continue
to be 6 dB below the maximum allowed power of ­140 dBm/24 MHz. Given the low signal
strength and the positioning of the system within the structure, the likelihood of any interference
occurring continues to be very low. In particular, because the re­radiating antenna will be
operating indoors in a Google­controlled facility, this signal will be attenuated by building loss,
further reducing any minimal likelihood of harmful interference outside that facility. Furthermore,
Google has conducted similar tests in this area under a grant of special temporary authority, and
no disruptions were noted.

     As demonstrated in Exhibit C, the proposed experimental operations will continue to be
conducted in accordance with technical requirements that the National Telecommunications and
Information Administration (NTIA) has established for federal agencies’ use of GPS re­radiators.
Satisfaction of these guidelines, although not required for the requested Commission
authorization, further demonstrates that the experimentation will continue to be conducted
without risk of harmful interference to other users.

       For these reasons, Google requests approval of this Experimental License.




                                                                                 Exhibit A ­ Page 1


                                                           PUBLIC REDACTED VERSION

                                                                                 Google Inc.
                                                                  File No. 0613­EX­PL­2015


                        EXHIBIT B ­ TECHNICAL INFORMATION

Legal Contact Details

Name of Contact                 Megan Anne Stull
Contact Details                 Counsel
                                25 Massachusetts Avenue NW, Ninth Floor
                                Washington DC 20001


Technical Contact Details

Name of Contact                  Paul Miller
Contact Details                  2175 Monarch Street
                                 Alameda, CA 94501
                                 Phone: (619) 871­6246
                                 Email: paulmi@google.com


Transmitter Equipment and Station Details
Radio Information

Equipment                              [REDACTED]
Quantity                               [REDACTED]
Area of Operation                      Operation not to exceed 0.05 km from the following
                                       geographic centerpoint:

                                       ●       37° 46' 58" N, 122° 18' 27" W


Frequencies                                                         (MHz)
[REDACTED]                                                       1575.42 MHz
[REDACTED]                                                       1227.60 MHz

Antenna Details

Antennas
Type                                           Omnidirectional
Quantity                                       [REDACTED]
Gain                                           3.5 dBi



                                                                            Exhibit B ­ Page 1


                                                 PUBLIC REDACTED VERSION

                                                                      Google Inc.
                                                       File No. 0613­EX­PL­2015


Radio        Modulation       Emission     Bandwidth     Maximum Maximum
                              Designator                  Power   EIRP
                                                           Out
[REDACTED]       N/A          24M0G1D          N/A        6.2E­12 W    ­108.6
                (GPS                          (GPS                      dBW
             amplification)                amplification)




                                                                Exhibit B ­ Page 2


                                                                 PUBLIC REDACTED VERSION

                                                                                      Google Inc.
                                                                       File No. 0613­EX­PL­2015


             EXHIBIT C – TECHNICAL GUIDELINES FOR GPS RE­RADIATORS

     In connection with its request for a New Experimental Radio Service License (Experimental
License) (0613­EX­PL­2015), Google Inc. submits the following information to demonstrate its
satisfaction of the technical requirements the National Telecommunications and Information
Administration (NTIA) has established for federal agencies’ use of GPS re­radiators, as set out
in Section 8.3.28 of the NTIA Manual of Regulations and Procedures for Federal Radio
Frequency Management.1



    Section 8.3.28(a): Individual authorization is for indoor use only, and is required for each
device at a specific site.

    The device will continue to be used indoors, within a masonry structure. It will be located at
[REDACTED] (37° 46' 58" N, 122° 18' 27" W).



    Section 8.3.28(d): The maximum length of the assignment will be two years, with possible
renewal.

    Google is seeking an Experimental License for two years.



    Section 8.3.28(e): The area of potential interference to GPS reception (e.g., military or
contractor facility) has to be under the control of the user.

      Google leases the building where the GPS repeater will continue to be placed under an
agreement that extends beyond 2015. Google will continue to control access to the building at
all times covered by the requested Experimental License.



     Section 8.3.28(f): The maximum equivalent isotropically radiated power (EIRP) must be
such that the calculated emissions are no greater than ­140 dBm/24 MHz as received by an
isotropic antenna at a distance of 100 feet (30 meters) from the building where the test is being




1
 National Telecommunications and Information Administration, Manual of Regulations and
Procedures for Federal Radio Frequency Management § 8.3.28 (2014), available at
http://www.ntia.doc.gov/files/ntia/publications/redbook/2014­05/8_14_5.pdf.
                                                                                 Exhibit C ­ Page 1


                                                                PUBLIC REDACTED VERSION

                                                                                     Google Inc.
                                                                      File No. 0613­EX­PL­2015


conducted. The calculations showing compliance with this requirement must be provided with
the application for frequency assignment and should be based on free space propagation with
no allowance for additional attenuation (e.g., building attenuation).

    Google’s analysis demonstrating compliance with these limits is set forth below.

       ­130 dBm       GPS power at the receiving antenna
       +40 dB         Receiving antenna pre­amplifier
       ­5.1 dB        Cable loss (100 ft. LMR­400)
       +33 dB         Maximum power amplifier gain (+24 dB nominal)
       ­10 dB         Fixed attenuator
       ­4.9 dB        Variable attenuator
       ­5.1 dB        Cable loss (100 ft LMR­400)
       +3.5 dBi       Transmitting antenna peak gain
       ­78.6 dBm      Equivalent EIRP from the re­radiator

   Calculation of loss for free space propagation using ITU model:

       Free space loss (dB) = 20log(f) + 20log(d) – 27.54

       Where:
       d (Distance in meters from re­radiating antenna to 100 ft outside the building) = 36 m
       f (Carrier frequency in MHz) = 1575.24 MHz

       ­67.5 dB       Free space gain at 100 ft from the building
       ­78.6 dBm      Equivalent EIRP from the re­radiator
       ­146.1 dBm     Received power 100 ft from the building (less than ­140 dBm
       required)



Section 8.3.28(g): GPS users in the area of potential interference to GPS reception must be
notified that GPS information may be impacted for periods of time.

      During the period covered by the Experimental License, Google will continue to post
prominent signage on the exterior of the building notifying GPS users that GPS information may
be impacted for periods of time during testing.




                                                                                Exhibit C ­ Page 2


                                                                  PUBLIC REDACTED VERSION

                                                                                       Google Inc.
                                                                        File No. 0613­EX­PL­2015


Section 8.3.28(h): The use is limited to activity for the purpose of testing RNSS
equipment/systems.

        Activities under the Experimental License will continue to be limited to those related to
testing RNSS equipment/systems.



Section 8.3.28(i): A "Stop Buzzer" point of contact for the authorized device must be identified
and available at all times during GPS re­radiation operation of the device under any condition.

       Google’s point of contact for the experiment continues to be Paul Miller. His contact
information is as follows: 2175 Monarch Street, Alameda, CA 94501, (619) 871­6246.




                                                                                    Exhibit C ­ Page 3



Document Created: 2015-09-28 16:37:12
Document Modified: 2015-09-28 16:37:12

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