Letter

0747-EX-PL-2015 Text Documents

Google Inc.

2016-01-27ELS_171957

$Google Inc. File No. 0747-EX-PL-2015 although we respect that the commenters’ concerns are genuinely held, there is no factual basis for them. Terrestrial operations : Google’s proposed terrestrial operations comply with the technical standards set forth in the FCC’s Part 101 rules for fixed microwave services. Unlike typical fixed microwave operations, though, Google’s terrestrial antennas will be pointed upward. This will greatly mitigate RF exposure on the ground, as received power from Google’s directional transmissions drops off by 1,000 times at just a few degrees off-boresight. Airborne operations : Transmitted power levels from airborne transmitters will not exceed -2 dBW and EIRP will not exceed 41 dBW, well below the maximum power allowed in the band. These emissions also will follow the formula set forth in 47 C.F.R. § 101.115(b) (note 15), which specially limits maximum allowable EIRP for antennas with gain between 43 and 50 dBi. And again, receivers or persons even slightly off-boresight from the directional antennas will receive only a small fraction of the maximum transmitted energy. The great distances involved further reduce power levels received on the ground. Even if an airborne transmitter were aimed precisely at a person on the ground directly below it, the signal strength received on the ground would be millions of times weaker than FCC limits for the band. For all these reasons, the proposed operations present no meaningful health or environmental risks. 2. Google will avoid harmful interference to other users of the E-band. Google’s proposed experimental operations are designed to protect existing users of the E-band from harmful interference.2 The authorized transmitters will be collocated on shared platforms, and Google anticipates that only a small percentage of the authorized transmitters typically will be in use in the United States at any given time. To avoid harmful interference, Google’s proprietary interference-mitigation methods rely on the Commission’s link registrations and information regarding Google’s own operations, including the precise location of transmitters and the technical characteristics both the transmitters and the antennas deployed. To ensure current information, Google will retrieve E-band licensee information daily from an FCC-authorized third-party database manager. With this information, Google will dynamically calculate available frequencies, optimal bandwidths, and maximum transmit powers for any given location. Google will not use combinations of center frequency, bandwidth, transmit power, and pointing 2 S ee Letter from Wesley K. Wright, Counsel to Fixed Wireless Communications Coalition, Inc.,, to Marlene H. Dortch, Secretary, FCC (filed Jan. 11, 2016) (asking for further information regarding interference mitigation strategy). 2$

Document Created: 2016-01-27 13:08:28
Document Modified: 2016-01-27 13:08:28