Request for Confidential Treatment and Exhibits PUBLIC

0747-EX-PL-2015 Text Documents

Google Inc.

2015-11-24ELS_169705

                                                                    REDACTED PUBLIC VERSION

                                                                                      Google Inc.
                                                                        File No. 0747-EX-PL-2015


Date:                  November 24, 2015

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

File No:               0747-EX-PL-2015



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
provided in its above-referenced 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 the following information that
has been redacted from the Experimental License and complementary exhibits. Google does
not seek to withhold from public inspection information 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 contains 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 an Experimental Radio Service License (Experimental
           License) and outlines below the compelling reasons why 0747-EX-PL-2015 should be
           granted expeditiously.

                  Google requests that the Experimental License be granted for a period of 24
           months beginning on January 1, 2016. The Experimental License is needed for
           continued development of [REDACTED]. [REDACTED]. The Experimental License

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                                                                              File No. 0747-EX-PL-2015


          builds on testing conducted under Call Sign WH9XYD (File Nos. 0842-EX-ST-2014 and
          0377-EX-ST-2015) and Call Sign WH2XUP (File No. 0271-EX-PL-2015).

                  As under Call Signs WH9XYD and WH2XUP, testing will primarily involve
          [REDACTED]. [REDACTED]. [REDACTED] will automatically disable any transmitter
          [REDACTED] under the Experimental License if [REDACTED] exits the test area covered
          by the Experimental License.

                Google will test [REDACTED]. The requested authorization includes
          [REDACTED]. [REDACTED]. [REDACTED].

                  [REDACTED] will operate with [REDACTED] directional antennas.1 Google will
          operate the [REDACTED] equipment with a minimum antenna gain of 38 dBi and an
          equivalent isotropically radiated power (EIRP) of no greater than 31 dBW. In some
          tests, an antenna gain of 43 dBi may be used, resulting in an EIRP of no greater than 41
          dBW. [REDACTED] will typically operate with [REDACTED] directional antennas with a
          gain of 53 dBi, and in no case will the maximum EIRP exceed 55 dBW.2 Occasionally,
          Google may use [REDACTED] antenna with a gain of 43 dBi; when using this antenna,
          Google will limit its EIRP to 41 dBW.

                  Grant of this Experimental License will not adversely impact any authorized
          user of RF spectrum. An interference study assessing the risk of harmful interference
          associated with Google’s proposed test operations is attached as Exhibit C,3 and a
          detailed description of Google’s proposed interference-avoidance methods is set forth
          in Exhibit D.

                Antenna specifications: As with testing authorized under Call Signs WH9XYD
          and WH2XUP, Google will use [REDACTED].4 [REDACTED].

                 Protection of specific users: As fully explained in Exhibits C and D, Google’s
          proposed operations will not cause harmful interference to other users of the
          millimeter wave bands. We discuss each set of users below.

                 Commercial millimeter wave band users: Google proposes to protect
          commercial millimeter wave users as follows: Using data gathered by the GPS
          receiver [REDACTED], each [REDACTED] transmitter will continually communicate its



1
  Specifications for these antennas are set forth in Exhibit B.
2
  Specifications for these antennas are also set forth in Exhibit B.
3
  See generally Exhibit C (Technical Declaration).
4
  In general, the minimum antenna gain required is 50 dBi. 47 C.F.R. § 101.115. However, antenna gains
of as low as 43 dBi are permitted if the operator employs a proportional reduction in power. See 47 C.F.R.
§101.115 n.15. (“Antenna gain less than 50 dBi (but greater than or equal to 43 dBi) is permitted only with
a proportional reduction in maximum authorized EIRP in a ratio of 2 dB of power per 1 dB of gain, so that
the maximum allowable EIRP (in dBW) for antennas of less than 50 dBi gain becomes +55-2(50–G),
where G is the antenna gain in dBi.”).
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                                                                            File No. 0747-EX-PL-2015


          location and velocity to [REDACTED].5 This information, [REDACTED], allows Google
          [REDACTED].6 This predictive analysis is repeated periodically so that [REDACTED].7

                  For these bounded areas, Google will [REDACTED] assess potential interference
          from Google’s operations ([REDACTED]) into terrestrial millimeter wave links.8 This
          analysis takes into account location, antenna and radio parameters, pointing direction,
          and frequency and bandwidth of receive operation for the registered users, as
          collected daily from an FCC-authorized coordination database.9 It considers the
          location, antenna, and radio parameters, frequency, and bandwidth of [REDACTED],
          which are provided as an input.10 Using these inputs and the assumptions regarding
          potential interference set forth in Exhibit C,11 the path loss between each of the
          transmitters and all registered users that could be affected is computed.12 Various
          combinations of transmit center frequency and bandwidth are then assessed for
          potential interference.13 [REDACTED].14 Of the combinations that fulfill the
          non-interference objective set forth in 47 C.F.R. § 101.105(a)(5)(i), one is selected for
          use.15 [REDACTED].16

                  As set forth in Exhibit C, [REDACTED] transmitting in the frequencies between
          73 and 74 GHz and 83 and 84 GHz, for example, will be able to communicate with
          other [REDACTED] transmitters at power levels [REDACTED] over 88.6% of the land
          area of the continental United States, based on current FCC registrations.17 In the
          limited geographic areas where there is possible harmful interference from
          [REDACTED] communication under operating parameters that would yield a desired
          data rate, Google will prevent interference by relying upon one or more of the following
          measures:

                   ●   Changing and limiting transmission frequencies to those that avoid harmful
                       interference;
                   ●   Reducing transmitter power below the level needed for throughput
                       optimization;
                   ●   Reducing transmitter bandwidth;
                   ●   Aiming the relevant transmit antenna toward a different [REDACTED]
                       receiver at an azimuth or elevation angle that is not aligned with vulnerable
                       receivers;
5
   See Exhibit D (Interference Mitigation Strategies) ¶ 2.
6
   Id ¶ 3.
7
   Id.
8
   Id. ¶ 4.
9
   Id.
10
    Id. ¶ 5.
11
    See Exhibit C (Technical Declaration).
12
    Exhibit D ¶ 5.
13
    Id.
14
    Id.
15
    Id. ¶ 6.
16
    Id.
17
    Exhibit C ¶ 33.
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                                                                            File No. 0747-EX-PL-2015


                      ●   [REDACTED];
                      ●   Employing cross-polarization to reduce the amount of power received by
                          registered users employing different polarization than [REDACTED]; and
                      ●   As a last resort in cases where the above techniques would not eliminate
                          potential harmful interference, discontinuing transmission.

            After this process, [REDACTED].18 [REDACTED].19 The [REDACTED] will shut down its
            transmissions [REDACTED].20

                    While implementing these techniques to avoid harmful interference, Google can
            operate [REDACTED] between [REDACTED] at 96.1% of the sample point locations
            within the continental United States—[REDACTED].21 In the 3.9% of locations where
            potential interference is predicted under some transmitter orientations, at least
            [REDACTED] is available without potential interference in 40% of the hypothetical
            orientations studied.22 In all locations, [REDACTED] will be able to have the desired
            quality of communication with at least [REDACTED].23 The same analysis predicts that,
            using the interference avoidance techniques described above and in Exhibit D, Google
            will be able to establish [REDACTED] between [REDACTED] transmitters and
            [REDACTED] receivers at 99.6% of the sample point locations within the continental
            United States.24

                    Where there are very few registered links in a large geographic area, Google
            may use [REDACTED], protection methods.25 In these cases, Google will conduct an
            analysis similar to the one set forth above for a much larger area—e.g., an entire state
            or U.S. territory—and determine non-interfering operating parameters for that larger
            area.26 [REDACTED]; instead, they would operate under transmission parameters
            selected to avoid harmful interference, and stop operating if they exit the defined
            geographic area without a new authorization [REDACTED].27

                  The same [REDACTED] interference-avoidance methods described above will
            be employed during the brief periods [REDACTED].28 [REDACTED].29 While the
            methodology used is the same, [REDACTED].30



18
     Exhibit D ¶ 7.
19
     Id.
20
     Id.
21
     Exhibit C ¶ 41
22
     Id. ¶ 42.
23
     Id.
24
     Id. ¶ 43.
25
     Exhibit D ¶ 8.
26
     Id.
27
     Id.
28
     Id. ¶¶ 9-11.
29
     Id.
30
     Id.
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                                                                         File No. 0747-EX-PL-2015


                 [REDACTED].31 [REDACTED].32

               On account of these methods, Google’s operations will pose no material risk of
         harmful interference to other commercial millimeter wave band users.

                Federal users: Google has a coordination agreement in place with the National
         Radio Astronomy Observatory (NRAO) to ensure that that operations under
         [REDACTED] current experimental authorizations (Call signs WH9XYD and WH2XUP)
         do not cause interference to radio astronomy observations at NRAO’s Owens Valley
         location. Google is prepared to coordinate with the National Telecommunications and
         Information Administration to ensure that other federal operations in the band do not
         experience harmful interference from Google’s testing in the expanded geographic
         area described in this application.

                As under [REDACTED] existing authorizations, Google [REDACTED]. As
         explained above, [REDACTED]. [REDACTED]. [REDACTED].

                International users: Google proposes to coordinate with international users as
         necessary to avoid harmful interference, and in accordance with international
         agreements. Canada and the United States have negotiated a sharing arrangement
         regarding coordination of 71-76 GHz and 81-86 GHz transmissions.33 Google will use
         the methods set forth in that agreement for coordinating with Canadian licensees, thus
         protecting all Canadian licensed facilities from harmful interference.

                 In Mexico, the 71-76 GHz and 81-86 GHz bands are available for unlicensed
         operations. [REDACTED] proposed in Google’s request for an Experimental License are
         consistent with the antenna gain, power level, EIRP, and power spectral density
         requirements set forth in Mexico’s regulations for unlicensed use of these bands.34
         Therefore, terrestrial operations in Mexico are no more likely to experience harmful
         interference from Google’s [REDACTED] than from in-country terrestrial operations that
         Mexican law currently allows.35 Indeed, because Google’s operations necessarily will
         be across the U.S. border, they are less likely than Mexican unlicensed operations to
         cause interference in Mexico.36 [REDACTED] will operate at even greater distances

31
   Id. ¶ 12.
32
   Id.
33
   Arrangement V: Sharing Arrangement between the Department of Industry of Canada and the Federal
Communications Commission and the National Telecommunications and Information Administration of the
United States of America Concerning the Use Of the Frequency Bands 71-76 GHz, 81-86 GHz, 92-94 GHz
and 94.1-95 GHz by the Fixed Service Along the Canada-United States Border, available at
https://transition.fcc.gov/ib/sand/agree/can_frequency.html and
http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf10755.html.
34
   Acuerdo por el Que se Establecen las Bandas de Frecuencias de 71 a 76 GHz y de 81 a 86 GHz, Como
Bandas de Frecuencias del Espectro Radioeléctrico de Uso Libre, y las Condiciones de Operación a Que
Deberán Sujetarse los Sistemas y Dispositivos Para su Operaciónen Estas Bandas (2012), available at
http://dof.gob.mx/nota_detalle.php?codigo=5237903&fecha=09/03/2012.
35
   Exhibit C at ¶ 45.
36
   Id.
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                                                                            File No. 0747-EX-PL-2015


            from terrestrial operations in Mexico.37 This similarly lessens the potential for
            interference [REDACTED].38



           Exhibit B - Technical Information:

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

            Applicant Name:      Google Inc.
            Applicant FRN:       0016069502


            Legal Contact Details

               Name of Contact      Aparna Sridhar
               Contact Details      Counsel
                                    25 Massachusetts Avenue NW, Ninth Floor
                                    Washington DC 20001


            Technical Contact Details

               Name of Contact      Jeff Gilbert
               Contact Details      1600 Amphitheatre Parkway
                                    Mountain View, CA 94043
                                    Phone: (650) 933-7471
                                    Email: jegilbert@google.com


            Areas of Operation


              Google seeks to operate in all 50 states and in the territory of Puerto Rico.




37
     Id.
38
     Id.
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                                                                              Google Inc.
                                                                File No. 0747-EX-PL-2015


[REDACTED] Transmitter Equipment and Station Details

  Equipment                 [REDACTED]
  Number of Terminals       [REDACTED]
  Station Class             Mobile


  Frequency Ranges                                        Low (GHz)         High (GHz)
                                                            71.000            76.000
  [REDACTED]a
                                                            81.000            86.000

  a
      Google will limits its transmissions to those channels where it will not cause
      interference to licensed users in the vicinity of its operations. See additional
      details set forth in Exhibits A, C, and D.

  Radio            Modulation     Emission      Bandwidth      Maximum        Maximum
                                 Designator                    Power Out        EIRP
  [REDACTED]b         Digital    60M0D1D-      60-580 MHz      0.631 W       41 dBW with
                                 580MD1Dc                     with 43 dBi       43 dBi
                                                               antenna         antenna
                                                               0.447 W    38 dBW with
                                                               with 41.5    41.5 dBi
                                                              dBi antenna   antenna

                                                               0.200 W       31 dBW with
                                                              with 38 dBi       38 dBi
                                                               antenna         antenna
  b
      In all cases, this transmitter will operate within the broader frequency ranges
      described above in the “Frequency Ranges” table.
  c
      During the course of testing, Google plans to operate transmitters with a range of
      bandwidths between 60 and 580 MHz. In no case will the bandwidth be smaller
      than 60 MHz or exceed 580 MHz. Nevertheless, precise emissions designators
      for the transmitters will vary according to the bandwidth of operation.




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                                                          File No. 0747-EX-PL-2015



Antenna #1 Details                [REDACTED]
Type                              [REDACTED]
Quantity                          [REDACTED]d
Gain                              43 dBi
Beam Width at Half-Power Point    1.2 degrees
Orientation in Horizontal Plane   N/A
Orientation in Vertical Plane     N/A


Antenna #2 Details                [REDACTED]
Type                              [REDACTED]
Quantity                          [REDACTED]d
Gain                              43 dBi
Beam Width at Half-Power Point    1.2 degrees
Orientation in Horizontal Plane   N/A
Orientation in Vertical Plane     N/A


Antenna #3 Details                [REDACTED]
Type                              [REDACTED]
Quantity                          [REDACTED]d
Gain                              38.1 dBi gain @ 71-76 GHz
                                  39.9 dBi gain @ 81-86 GHz
Beam Width at Half-Power Point    1.9 degrees @ 71-76 GHz
                                  1.8 degrees @ 81-86 GHz
Orientation in Horizontal Plane   N/A
Orientation in Vertical Plane     N/A




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                                                          File No. 0747-EX-PL-2015



Antenna #4 Details                [REDACTED]
Type                              [REDACTED]
Quantity                          [REDACTED]d
Gain                              41.5 dBi gain @ 71-76 GHz
                                  43 dBi gain @ 81-86 GHz
Beam Width at Half-Power Point    1.0 degrees @ 71-76 GHz
                                  0.8 degrees @ 81-86 GHz
Orientation in Horizontal Plane   N/A
Orientation in Vertical Plane     N/A


Antenna #5 Details                [REDACTED]
Type                              [REDACTED]
Quantity                          [REDACTED]d
Gain                              38 dBi
Beam Width at Half-Power Point    2.0 degrees
Orientation in Horizontal Plane   N/A
Orientation in Vertical Plane     N/A


Antenna #6 Details                [REDACTED]
Type                              [REDACTED]
Quantity                          [REDACTED]d
Gain                              43 dBi
Beam Width at Half-Power Point    1.2 degrees
Orientation in Horizontal Plane   N/A
Orientation in Vertical Plane     N/A
d
    [REDACTED].




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                                                               File No. 0747-EX-PL-2015


[REDACTED] Transmitter Equipment and Station Details

  Equipment                    [REDACTED]
  Number of Terminals          [REDACTED]
  Station Class                Fixed


  Frequency Ranges                                Low (GHz)              High (GHz)
                                                    71.000                  76.000
  [REDACTED]e
                                                    81.000                  86.000

  e
      Google will limits its transmissions to those channels where it will not cause
      interference to licensed users in the vicinity of its operations. See additional
      details set forth in Exhibits A, C, and D.

  Radio           Modulation       Emission    Bandwidth      Maximum        Maximum
                                  Designator                  Power Out        EIRP
  [REDACTED]f        Digital      60M0D1D- 60-580 MHz          1.585 W      55 dBW with
                                  580MD1Dg                    with 53 dBi      53 dBi
                                                               antenna        antenna

                                                               0.631 W      41 dBW with
                                                              with 43 dBi      43 dBi
                                                               antenna        antenna
  f
      This transmitter will operate within the broader frequency ranges described
      above in the “Frequency Ranges” table.
  g
      During the course of testing, Google plans to operate transmitters with a range
      of bandwidths between 60 and 580 MHz. In no case will the bandwidth be
      smaller than 60 MHz or exceed 580 MHz. Nevertheless, precise emissions
      designators for the transmitters will vary according to the bandwidth of
      operation.




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                                                             File No. 0747-EX-PL-2015



  Antenna #1 Details                [REDACTED]
  Type                              [REDACTED]
  Quantity                          [REDACTED]h
  Gain                              53 dBi
  Beam Width at Half-Power Point    0.37 degrees
  Orientation in Horizontal Plane   N/A
  Orientation in Vertical Plane     N/A


  Antenna #2 Details                [REDACTED]
  Type                              [REDACTED]
  Quantity                          [REDACTED]h
  Gain                              53 dBi
  Beam Width at Half-Power Point    0.37 degrees
  Orientation in Horizontal Plane   N/A
  Orientation in Vertical Plane     N/A


  Antenna #3 Details                [REDACTED]
  Type                              [REDACTED]
  Quantity                          [REDACTED]h
  Gain                              43 dBi
  Beam Width at Half-Power Point    1.2 degrees
  Orientation in Horizontal Plane   N/A
  Orientation in Vertical Plane     N/A

  h
      [REDACTED].

[REDACTED]

 [REDACTED]. [REDACTED].




                                             Request for Confidential Treatment - Page 11


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                                                                                           Google Inc.
                                                                             File No. 0747-EX-PL-2015


        Exhibit C - Technical Declaration:

        Google requests confidential treatment of Exhibit C in its entirety.



        Exhibit D - Interference Mitigation Strategies:

        Google requests confidential treatment of Exhibit D in its entirety.



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

       The above-referenced Exhibits were submitted to the Commission in support of the
Experimental License. The Exhibits were filed with the Office of Engineering and Technology on
November 24, 2015. For additional information, please see File No. 0747-EX-PL-2015.



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
details of the Experimental License tests/experiments may include trade secret information.
                                                                                             39
The Commission has clarified that confidential treatment should be 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.

        In addition, agreements entered into between Google and the parties that provided
equipment for testing or will provide analysis of test results require that confidential information
of the parties be held in strict confidence, and that such information not be disclosed to any
third party (with limited exceptions not applicable to this request). The manufacturer name and
model number constitutes confidential trade secrets, technical information, and business
information under the agreements.




39
  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).
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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 that any third parties involved in the 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
has only been disclosed to third parties pursuant to restrictive safeguards.

         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.”)




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                                                                        File No. 0747-EX-PL-2015


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 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,


Aparna Sridhar




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                                                                                            Google Inc.
                                                                              File No. 0747-EX-PL-2015

                               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
an Experimental Radio Service License (Experimental License) and outlines below the
compelling reasons why 0747-EX-PL-2015 should be granted expeditiously.

       Google requests that the Experimental License be granted for a period of 24 months
beginning on January 1, 2016. The Experimental License is needed for continued development
of [REDACTED]. [REDACTED]. The Experimental License builds on testing conducted under Call
Sign WH9XYD (File Nos. 0842-EX-ST-2014 and 0377-EX-ST-2015) and Call Sign WH2XUP (File
No. 0271-EX-PL-2015).

       As under Call Signs WH9XYD and WH2XUP, testing will primarily involve [REDACTED].
[REDACTED]. [REDACTED] will automatically disable any transmitter [REDACTED] under the
Experimental License if [REDACTED] exits the test area covered by the Experimental License.

      Google will test [REDACTED]. The requested authorization includes [REDACTED].
[REDACTED]. [REDACTED].

       [REDACTED] will operate with [REDACTED] directional antennas.1 Google will operate the
[REDACTED] equipment with a minimum antenna gain of 38 dBi and an equivalent isotropically
radiated power (EIRP) of no greater than 31 dBW. In some tests, an antenna gain of 43 dBi may
be used, resulting in an EIRP of no greater than 41 dBW. [REDACTED] will typically operate with
[REDACTED] directional antennas with a gain of 53 dBi, and in no case will the maximum EIRP
exceed 55 dBW.2 Occasionally, Google may use [REDACTED] antenna with a gain of 43 dBi;
when using this antenna, Google will limit its EIRP to 41 dBW.

       Grant of this Experimental License will not adversely impact any authorized user of RF
spectrum. An interference study assessing the risk of harmful interference associated with
Google’s proposed test operations is attached as Exhibit C,3 and a detailed description of
Google’s proposed interference-avoidance methods is set forth in Exhibit D.

     Antenna specifications: As with testing authorized under Call Signs WH9XYD and
WH2XUP, Google will use [REDACTED].4 [REDACTED].




1
  Specifications for these antennas are set forth in Exhibit B.
2
  Specifications for these antennas are also set forth in Exhibit B.
3
  See generally Exhibit C (Technical Declaration).
4
  In general, the minimum antenna gain required is 50 dBi. 47 C.F.R. § 101.115. However, antenna gains
of as low as 43 dBi are permitted if the operator employs a proportional reduction in power. See 47 C.F.R.
§101.115 n.15. (“Antenna gain less than 50 dBi (but greater than or equal to 43 dBi) is permitted only with
a proportional reduction in maximum authorized EIRP in a ratio of 2 dB of power per 1 dB of gain, so that
the maximum allowable EIRP (in dBW) for antennas of less than 50 dBi gain becomes +55-2(50–G),
where G is the antenna gain in dBi.”).
                                                                                         Exhibit A - Page 1


                                                                   PUBLIC REDACTED VERSION

                                                                                     Google Inc.
                                                                       File No. 0747-EX-PL-2015

       Protection of specific users: As fully explained in Exhibits C and D, Google’s proposed
operations will not cause harmful interference to other users of the millimeter wave bands. We
discuss each set of users below.

        Commercial millimeter wave band users: Google proposes to protect commercial
millimeter wave users as follows: Using data gathered by the GPS receiver [REDACTED], each
[REDACTED] transmitter will continually communicate its location and velocity to [REDACTED].5
This information, [REDACTED], allows Google [REDACTED].6 This predictive analysis is repeated
periodically so that [REDACTED].7

        For these bounded areas, Google will [REDACTED] assess potential interference from
Google’s operations ([REDACTED]) into terrestrial millimeter wave links.8 This analysis takes
into account location, antenna and radio parameters, pointing direction, and frequency and
bandwidth of receive operation for the registered users, as collected daily from an
FCC-authorized coordination database.9 It considers the location, antenna, and radio
parameters, frequency, and bandwidth of [REDACTED], which are provided as an input.10 Using
these inputs and the assumptions regarding potential interference set forth in Exhibit C,11 the
path loss between each of the transmitters and all registered users that could be affected is
computed.12 Various combinations of transmit center frequency and bandwidth are then
assessed for potential interference.13 [REDACTED].14 Of the combinations that fulfill the
non-interference objective set forth in 47 C.F.R. § 101.105(a)(5)(i), one is selected for use.15
[REDACTED].16

        As set forth in Exhibit C, [REDACTED] transmitting in the frequencies between 73 and 74
GHz and 83 and 84 GHz, for example, will be able to communicate with other [REDACTED]
transmitters at power levels [REDACTED] over 88.6% of the land area of the continental United
States, based on current FCC registrations.17 In the limited geographic areas where there is
possible harmful interference from [REDACTED] communication under operating parameters
that would yield a desired data rate, Google will prevent interference by relying upon one or more
of the following measures:

            ●    Changing and limiting transmission frequencies to those that avoid harmful
                 interference;
            ●    Reducing transmitter power below the level needed for throughput optimization;

5
   See Exhibit D (Interference Mitigation Strategies) ¶ 2.
6
   Id ¶ 3.
7
   Id.
8
   Id. ¶ 4.
9
   Id.
10
    Id. ¶ 5.
11
    See Exhibit C (Technical Declaration).
12
    Exhibit D ¶ 5.
13
    Id.
14
    Id.
15
    Id. ¶ 6.
16
    Id.
17
    Exhibit C ¶ 33.
                                                                                 Exhibit A - Page 2


                                                                        PUBLIC REDACTED VERSION

                                                                                          Google Inc.
                                                                            File No. 0747-EX-PL-2015

              ●       Reducing transmitter bandwidth;
              ●       Aiming the relevant transmit antenna toward a different [REDACTED] receiver at
                      an azimuth or elevation angle that is not aligned with vulnerable receivers;
              ●       [REDACTED];
              ●       Employing cross-polarization to reduce the amount of power received by
                      registered users employing different polarization than [REDACTED]; and
              ●       As a last resort in cases where the above techniques would not eliminate
                      potential harmful interference, discontinuing transmission.

After this process, [REDACTED].18 [REDACTED].19 The [REDACTED] will shut down its
transmissions [REDACTED].20

        While implementing these techniques to avoid harmful interference, Google can operate
[REDACTED] between [REDACTED] at 96.1% of the sample point locations within the continental
United States—[REDACTED].21 In the 3.9% of locations where potential interference is predicted
under some transmitter orientations, at least [REDACTED] is available without potential
interference in 40% of the hypothetical orientations studied.22 In all locations, [REDACTED] will
be able to have the desired quality of communication with at least [REDACTED].23 The same
analysis predicts that, using the interference avoidance techniques described above and in
Exhibit D, Google will be able to establish [REDACTED] between [REDACTED] transmitters and
[REDACTED] receivers at 99.6% of the sample point locations within the continental United
States.24

       Where there are very few registered links in a large geographic area, Google may use
[REDACTED], protection methods.25 In these cases, Google will conduct an analysis similar to
the one set forth above for a much larger area—e.g., an entire state or U.S. territory—and
determine non-interfering operating parameters for that larger area.26 [REDACTED]; instead, they
would operate under transmission parameters selected to avoid harmful interference, and stop
operating if they exit the defined geographic area without a new authorization [REDACTED].27

        The same [REDACTED] interference-avoidance methods described above will be
employed during the brief periods [REDACTED].28 [REDACTED].29 While the methodology used
is the same, [REDACTED].30


18
     Exhibit D ¶ 7.
19
     Id.
20
     Id.
21
     Exhibit C ¶ 41
22
     Id. ¶ 42.
23
     Id.
24
     Id. ¶ 43.
25
     Exhibit D ¶ 8.
26
     Id.
27
     Id.
28
     Id. ¶¶ 9-11.
29
     Id.
30
     Id.
                                                                                      Exhibit A - Page 3


                                                                     PUBLIC REDACTED VERSION

                                                                                       Google Inc.
                                                                         File No. 0747-EX-PL-2015

       [REDACTED].31 [REDACTED].32

        On account of these methods, Google’s operations will pose no material risk of harmful
interference to other commercial millimeter wave band users.

        Federal users: Google has a coordination agreement in place with the National Radio
Astronomy Observatory (NRAO) to ensure that that operations under [REDACTED] current
experimental authorizations (Call signs WH9XYD and WH2XUP) do not cause interference to
radio astronomy observations at NRAO’s Owens Valley location. Google is prepared to
coordinate with the National Telecommunications and Information Administration to ensure
that other federal operations in the band do not experience harmful interference from Google’s
testing in the expanded geographic area described in this application.

      As under [REDACTED] existing authorizations, Google [REDACTED]. As explained above,
[REDACTED]. [REDACTED]. [REDACTED].

        International users: Google proposes to coordinate with international users as necessary
to avoid harmful interference, and in accordance with international agreements. Canada and
the United States have negotiated a sharing arrangement regarding coordination of 71-76 GHz
and 81-86 GHz transmissions.33 Google will use the methods set forth in that agreement for
coordinating with Canadian licensees, thus protecting all Canadian licensed facilities from
harmful interference.

        In Mexico, the 71-76 GHz and 81-86 GHz bands are available for unlicensed operations.
[REDACTED] proposed in Google’s request for an Experimental License are consistent with the
antenna gain, power level, EIRP, and power spectral density requirements set forth in Mexico’s
regulations for unlicensed use of these bands.34 Therefore, terrestrial operations in Mexico are
no more likely to experience harmful interference from Google’s [REDACTED] than from
in-country terrestrial operations that Mexican law currently allows.35 Indeed, because Google’s
operations necessarily will be across the U.S. border, they are less likely than Mexican
unlicensed operations to cause interference in Mexico.36 [REDACTED] will operate at even




31
   Id. ¶ 12.
32
   Id.
33
   Arrangement V: Sharing Arrangement between the Department of Industry of Canada and the Federal
Communications Commission and the National Telecommunications and Information Administration of the
United States of America Concerning the Use Of the Frequency Bands 71-76 GHz, 81-86 GHz, 92-94 GHz
and 94.1-95 GHz by the Fixed Service Along the Canada-United States Border, available at
https://transition.fcc.gov/ib/sand/agree/can_frequency.html and
http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf10755.html.
34
   Acuerdo por el Que se Establecen las Bandas de Frecuencias de 71 a 76 GHz y de 81 a 86 GHz, Como
Bandas de Frecuencias del Espectro Radioeléctrico de Uso Libre, y las Condiciones de Operación a Que
Deberán Sujetarse los Sistemas y Dispositivos Para su Operaciónen Estas Bandas (2012), available at
http://dof.gob.mx/nota_detalle.php?codigo=5237903&fecha=09/03/2012.
35
   Exhibit C at ¶ 45.
36
   Id.
                                                                                   Exhibit A - Page 4


                                                                    PUBLIC REDACTED VERSION

                                                                                      Google Inc.
                                                                        File No. 0747-EX-PL-2015

greater distances from terrestrial operations in Mexico.37 This similarly lessens the potential for
interference [REDACTED].38




37
     Id.
38
     Id.
                                                                                  Exhibit A - Page 5


                                                                    PUBLIC REDACTED VERSION

                                                                                      Google Inc.
                                                                        File No. 0747-EX-PL-2015

                            EXHIBIT B - TECHNICAL INFORMATION


Applicant Name:         Google Inc.
Applicant FRN:          0016069502


Legal Contact Details

    Name of Contact          Aparna Sridhar
    Contact Details          Counsel
                             25 Massachusetts Avenue NW, Ninth Floor
                             Washington DC 20001


Technical Contact Details

    Name of Contact          Jeff Gilbert
    Contact Details          1600 Amphitheatre Parkway
                             Mountain View, CA 94043
                             Phone: (650) 933-7471
                             Email: jegilbert@google.com


Areas of Operation


   Google seeks to operate in all 50 states and in the territory of Puerto Rico.


[REDACTED] Transmitter Equipment and Station Details

    Equipment                  [REDACTED]
    Number of Terminals        [REDACTED]
    Station Class              Mobile


    Frequency Ranges                                          Low (GHz)            High (GHz)
                                                               71.000                76.000
    [REDACTED]a
                                                               81.000                86.000

    a
        Google will limits its transmissions to those channels where it will not cause interference
        to licensed users in the vicinity of its operations. See additional details set forth in
        Exhibits A, C, and D.


                                                                                   Exhibit B ­ Page 1


                                                                PUBLIC REDACTED VERSION

                                                                                  Google Inc.
                                                                    File No. 0747-EX-PL-2015


Radio                Modulation      Emission       Bandwidth    Maximum           Maximum
                                    Designator                   Power Out           EIRP
[REDACTED]b             Digital     60M0D1D-     60-580 MHz 0.631 W with         41 dBW with
                                    580MD1Dc                   43 dBi               43 dBi
                                                              antenna              antenna
                                                                0.447 W with     38 dBW with
                                                                  41.5 dBi         41.5 dBi
                                                                  antenna          antenna

                                                                0.200 W with     31 dBW with
                                                                   38 dBi           38 dBi
                                                                  antenna          antenna
b
    In all cases, this transmitter will operate within the broader frequency ranges described
    above in the “Frequency Ranges” table.
c
    During the course of testing, Google plans to operate transmitters with a range of
    bandwidths between 60 and 580 MHz. In no case will the bandwidth be smaller than 60
    MHz or exceed 580 MHz. Nevertheless, precise emissions designators for the
    transmitters will vary according to the bandwidth of operation.

Antenna #1 Details                    [REDACTED]
Type                                  [REDACTED]
Quantity                              [REDACTED]d
Gain                                  43 dBi
Beam Width at Half-Power Point        1.2 degrees
Orientation in Horizontal Plane       N/A
Orientation in Vertical Plane         N/A


Antenna #2 Details                    [REDACTED]
Type                                  [REDACTED]
Quantity                              [REDACTED]d
Gain                                  43 dBi
Beam Width at Half-Power Point        1.2 degrees
Orientation in Horizontal Plane       N/A
Orientation in Vertical Plane         N/A



                                                                               Exhibit B ­ Page 2


                                                            PUBLIC REDACTED VERSION

                                                                             Google Inc.
                                                               File No. 0747-EX-PL-2015


Antenna #3 Details                [REDACTED]
Type                              [REDACTED]
Quantity                          [REDACTED]d
Gain                              38.1 dBi gain @ 71-76 GHz
                                  39.9 dBi gain @ 81-86 GHz
Beam Width at Half-Power Point    1.9 degrees @ 71-76 GHz
                                  1.8 degrees @ 81-86 GHz
Orientation in Horizontal Plane   N/A
Orientation in Vertical Plane     N/A


Antenna #4 Details                [REDACTED]
Type                              [REDACTED]
Quantity                          [REDACTED]d
Gain                              41.5 dBi gain @ 71-76 GHz
                                  43 dBi gain @ 81-86 GHz
Beam Width at Half-Power Point    1.0 degrees @ 71-76 GHz
                                  0.8 degrees @ 81-86 GHz
Orientation in Horizontal Plane   N/A
Orientation in Vertical Plane     N/A


Antenna #5 Details                [REDACTED]
Type                              [REDACTED]
Quantity                          [REDACTED]d
Gain                              38 dBi
Beam Width at Half-Power Point    2.0 degrees
Orientation in Horizontal Plane   N/A
Orientation in Vertical Plane     N/A




                                                                       Exhibit B ­ Page 3


                                                                     PUBLIC REDACTED VERSION

                                                                                       Google Inc.
                                                                         File No. 0747-EX-PL-2015



       Antenna #6 Details                  [REDACTED]
       Type                                [REDACTED]
       Quantity                            [REDACTED]d
       Gain                                43 dBi
       Beam Width at Half-Power Point      1.2 degrees
       Orientation in Horizontal Plane     N/A
       Orientation in Vertical Plane       N/A
   d
         [REDACTED].


[REDACTED] Transmitter Equipment and Station Details

       Equipment                 [REDACTED]
       Number of Terminals       [REDACTED]
       Station Class             Fixed


       Frequency Ranges                                      Low (GHz)            High (GHz)
                                                               71.000                  76.000
       [REDACTED]e
                                                               81.000                  86.000

   e
         Google will limits its transmissions to those channels where it will not cause interference
         to licensed users in the vicinity of its operations. See additional details set forth in
         Exhibits A, C, and D.

       Radio                Modulation     Emission      Bandwidth       Maximum         Maximum
                                          Designator                     Power Out         EIRP
       [REDACTED]f            Digital     60M0D1D-       60-580 MHz       1.585 W         55 dBW
                                          580MD1Dg                       with 53 dBi     with 53 dBi
                                                                          antenna         antenna

                                                                          0.631 W         41 dBW
                                                                         with 43 dBi     with 43 dBi
                                                                          antenna         antenna
   f
         This transmitter will operate within the broader frequency ranges described above in the
         “Frequency Ranges” table.


                                                                                   Exhibit B ­ Page 4


                                                                PUBLIC REDACTED VERSION

                                                                                 Google Inc.
                                                                   File No. 0747-EX-PL-2015


  g
        During the course of testing, Google plans to operate transmitters with a range of
        bandwidths between 60 and 580 MHz. In no case will the bandwidth be smaller than 60
        MHz or exceed 580 MHz. Nevertheless, precise emissions designators for the
        transmitters will vary according to the bandwidth of operation.


      Antenna #1 Details                [REDACTED]
      Type                              [REDACTED]
      Quantity                          [REDACTED]h
      Gain                              53 dBi
      Beam Width at Half-Power Point    0.37 degrees
      Orientation in Horizontal Plane   N/A
      Orientation in Vertical Plane     N/A


      Antenna #2 Details                [REDACTED]
      Type                              [REDACTED]
      Quantity                          [REDACTED]h
      Gain                              53 dBi
      Beam Width at Half-Power Point    0.37 degrees
      Orientation in Horizontal Plane   N/A
      Orientation in Vertical Plane     N/A


      Antenna #3 Details                [REDACTED]
      Type                              [REDACTED]
      Quantity                          [REDACTED]h
      Gain                              43 dBi
      Beam Width at Half-Power Point    1.2 degrees
      Orientation in Horizontal Plane   N/A
      Orientation in Vertical Plane     N/A

  h
        [REDACTED].

[REDACTED]

  [REDACTED]. [REDACTED].
                                                                            Exhibit B ­ Page 5


                              PUBLIC REDACTED VERSION

                                                 Google Inc.
                                   File No. 0747-EX-PL-2015


EXHIBIT C –TECHNICAL DECLARATION


           [REDACTED]


                                      PUBLIC REDACTED VERSION

                                                       Google Inc.
                                         File No. 0747-EX-PL-2015


EXHIBIT D - INTERFERENCE MITIGATION STRATEGIES


                 [REDACTED]



Document Created: 2015-11-24 18:58:12
Document Modified: 2015-11-24 18:58:12

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