Request for Confidential Treatment and Exhibits PUBLIC

0784-EX-ST-2016 Text Documents

Google Inc.

2016-06-13ELS_178063

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 Date: June 13, 2016 Subject: Public and Redacted Versions of Request for Confidential Treatment and Complementary Exhibits File Number: 0784-EX-ST-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 extension of Special Temporary Authority (STA Extension) 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 STA Extension and Exhibits A and B. Google does not seek to withhold from public inspection information in the STA Extension 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 5.61 of the Federal Communications Commission’s (FCC’s or Commission’s) Rules, 47 C.F.R. § 5.61, Google Inc. (Google) outlines below its need for the requested extension of Special Temporary Authority (STA Extension) and the compelling reasons why it should be granted expeditiously. Google requests that the STA Extension be granted for a period of 180 days. The STA Extension is needed for continued development of [REDACTED]. Among other parameters, Google will continue to evaluate [REDACTED]. Request for Confidential Treatment - Page 1

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 Consistent with 1216-EX-ST-2015 (Call Sign WJ9XGG), the equipment used will continue to include [REDACTED] at any given time. [REDACTED] radio will continue to be used with [REDACTED] antennas with a gain not to exceed 42.3 dBi. For that radio, the maximum equivalent isotropically radiated power (EIRP) will not exceed 48.3 dBW, regardless of the antenna used. [REDACTED] radio will continue to be used with [REDACTED] antennas with a gain not to exceed 48 dBi. Maximum EIRP from this radio will not exceed 54 dBW, regardless of the antenna used. While most of Google’s testing will continue to use wideband transmissions, Google also seeks authorization to conduct limited narrowband testing in the 31 GHz band. Narrowband testing is expected to take place over no more than 12 hours during the pendency of the STA Extension. Grant of this STA Extension will not adversely impact any authorized user of RF spectrum for the reasons stated below. 27.9-28.0 GHz band users (the 27 GHz band): Google’s continued operations will not cause harmful interference to other users of the 27 GHz band. ● Terrestrial licensees: On Google’s behalf, Comsearch identified 27 GHz band licensees in the common carrier fixed point-to-point microwave service, local television transmission service (LTTS) and local multipoint distribution service (LMDS).1 Notification letters were sent to each of the licensees operating within the vicinity of Google’s testing, informing them of the technical parameters of the experimentation.2 No licensee objected3 and no interference has been reported. ● Satellite operations: Google’s continued testing will not interfere with satellite receivers operating in the 27 GHz band. Google has conducted analyses evaluating the potential for interference to geostationary (GSO) satellites, medium-earth orbit (MEO) satellites, and low-earth orbit (LEO) satellites. Each of these analyses is described below. GSO satellites: To assess potential interference to GSO satellites, Google calculated interference levels from the sidelobes of its [REDACTED] antenna into the satellite receiver. The 27 GHz band is allocated for earth-to-space transmissions, so interference with ground station receivers is not a concern.4 Moreover, the 27 GHz transmitter will continue to point at an elevation angle below the 1 See Exhibit C (Frequency Coordination Report) to 1216-EX-ST-2015 (Call Sign WJ9XGG). 2 Id. at 1. 3 Id. The technical coordination report specified that Google would use an antenna with a gain of 27 dBi in its operation. The request for an STA Extension seeks authorization to continue to operate antennas with gains as low as 22 dBi. However, if Google uses a lower antenna gain, the EIRP in the direction of other authorized operations would be correspondingly reduced, ensuring that there is no greater potential for interference to those operations. 4 See 47 C.F.R. § 2.106. Request for Confidential Treatment - Page 2

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 horizon, so the main beam will never be pointing toward the satellite receiver. In performing its analysis, Google relied on the technical parameters for GSO satellites set forth in ITU-R Recommendation SF 1601-2.5 In particular, this recommendation suggests a GSO satellite has a maximum receive antenna gain of 55 dBi and a system noise temperature of 500K.6 To approximate worst case conditions, Google assumed that Google’s ground transmitter was located directly in the spot beam of the satellite’s receiver. Google made additional worst case assumptions regarding its own antenna by assuming its antenna has +10 dBi gain in the direction of the GSO satellite receiver.7 Assuming free space propagation between Google’s transmitter and the satellite’s receiver, Google’s analysis showed that any signal received by the satellite from Google’s transmitter would be at least 19.2 dB below the satellite receiver’s thermal noise floor. This equates to at most 0.052 dB in degradation, which should be nearly undetectable on a data link. ITU Recommendation S.1323-2 recommends that internetwork interference caused by the earth and space station emissions of any one other GSO FSS network operating in the same frequency band or bands be limited to 6% of the total system noise power under clear-sky conditions.8 Link degradation of 0.052 dB corresponds to 1.2% of total system noise power. Moreover, the received signal at the GSO satellite is likely is to be even weaker because any satellite antenna pointed at an associated satellite earth station necessarily will be pointing substantially away from Google’s transmitter location. The closest earth station to Google’s terrestrial transmitter is at least 257 km away.9 As a result, any satellite receiver operating in this band will be pointed at a terrestrial location at least 257 kilometers away from Google’s test location, ensuring that its receiver will be a minimum 0.41 degrees off-boresight from the Google transmitter. MEO and LEO satellites: Google’s continued testing will not interfere with MEO or LEO satellites. A search of the FCC’s IBFS database shows that there are no MEO or LEO earth stations 5 ITU-R Recommendation SF 1601-2, Methodologies for Interference Evaluation from the Downlink of the Fixed Service Using High Altitude Platform Stations to the Uplink of the Fixed-satellite Service Using the Geostationary Satellites Within the Band 27.5-28.35 GHz (2007), available at http://www.itu.int/rec/R-REC-SF.1601-2-200702-I (ITU-R Recommendation SF 1601-2). 6 Id. at 8. 7 [REDACTED]. 8 ITU-R Recommendation S.1323-2, Maximum Permissible Levels of Interference in a Satellite Network (GSO/FSS; Non-GSO/FSS; Non-GSO/MSS Feeder Links) in the Fixed-satellite Service Caused by Other Codirectional FSS Networks Below 30 GHz (2002), available at https://www.itu.int/rec/R-REC-S.1323/en (ITU-R Recommendation S.1323-2). 9 The distance between Google’s continued operations and the Nevada border is 257 kilometers. Request for Confidential Treatment - Page 3

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 registered in California. Therefore, the closest earth station to Google’s operation can be no closer than the Nevada border, roughly 257 kilometers away from Google’s operation. If a MEO satellite operates at roughly 8,000 kilometers above the earth’s surface10 and points at an earth station at least 257 kilometers from the edge of Google’s operating area, the MEO satellite’s receive antenna will continue to be off axis from Google’s transmitter in California by at least 1.8 degrees. Relying on the antenna patterns recommended in ITU-R Recommendation F.699-7,11 the satellite receive antenna gain in the direction of Google’s operation is at most 30 dBi for MEO satellites. Using a worst case antenna gain of +10 dBi in the direction of the satellite, and a satellite receiver noise temperature of 500K,12 the signal received by a MEO satellite from Google’s transmitter will be at least 28 dB below the noise floor. As noted above, ITU Recommendation S.1323-2 recommends that internetwork interference caused by the earth and space station emissions of any one other GSO FSS network operating in the same frequency band or bands be limited to 6% of the total system noise power under clear-sky conditions.13 Transmissions at 28.3 dB below the noise floor correspond to 0.16% of total system noise power and will not cause harmful interference to MEO satellites. To assess potential interference to LEO satellites, Google assumed that such satellites would operate at orbital heights between 500 and 2000 kilometers above mean sea level and conducted the same analysis described above.14 Google’s results are summarized in the table below: 10 O3b Networks operates a MEO satellite in this band, and that satellite operates at an orbital height of 8062 kilometers. 11 ITU-R Recommendation F.699, Reference Radiation Patterns for Fixed Wireless System Antennas for Use in Coordination Studies and Interference Assessment in the Frequency Range From 100 MHz to About 70 GHz (2006), available at https://www.itu.int/rec/R-REC-F.699/en. 12 ITU-R Recommendation SF 1601-2. 13 ITU-R Recommendation S.1323-2. The ITU has not issued similar recommendations for MEO and LEO satellites, so Google has assumed that the system noise temperature and antenna gain characteristics for LEOs and MEOs are similar to those provided in the ITU-R Recommendation S.1323-2. 14 Mark A. Sturza, LEOs: The Communications Satellites of the 21st Century 1, IEEE Technical Applications Conference Northcon/96 Conference Record (1996), available at http://ieeexplore.ieee.org/xpls/abs_all.jsp?arnumber=564754&tag=1. Request for Confidential Treatment - Page 4

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 Satellite height 500 km 1000 km 2000 km Minimum angle 27 degrees 14 degrees 7 degrees off-boresight from Google operations Maximum receive 10 dBi 15.3 dBi 21.4 dBi antenna gain in direction of Google operations Maximum power of 27.7 dBm 28.2 dBm 27.7 dBm Google signal below noise below noise below noise received by satellite floor floor floor Based on this analysis, the signal received by a LEO satellite from Google’s operation will continue to be at least 27 dB below the receiver noise floor. This interference level, too, is undetectable on a data link. As noted above, ITU Recommendation S.1323-2 recommends that internetwork interference caused by the earth and space station emissions of any one other GSO FSS network operating in the same frequency band or bands be limited to 6% of the total system noise power under clear-sky conditions.15 Transmissions at 27 dB below the noise floor correspond to 0.2% of total system noise power and will not cause harmful interference to LEO satellites. ● Unlicensed operations: Google’s continued testing will not interfere with unlicensed users of the 24.05-29.00 GHz band. Unlicensed use of the band is limited to level sensing radars.16 These low-power radars measure the level, or relative height, of various substances in man-made or natural containers. For example, they may be used to measure water basin levels, coal piles, or grain levels in a silo.17 The Commission’s rules require their transmit antennas to be oriented downward. Google’s continued operation will transmit horizontally, and at ground level, the test emissions will not exceed the −14 dBm/MHz EIRP density set forth in the rules for these radars.18 [REDACTED]. [REDACTED], the closest possible sensors would be at least 300 meters away, [REDACTED]. [REDACTED]. Moreover, many level probing radars are used in confined spaces where Google’s signal will continue to be further 15 ITU-R Recommendation S.1323-2. 16 See 47 C.F.R. §15.256. 17 In the Matter of Amendment of Part 15 of the Commission’s Rules To Establish Regulations for Tank Level Probing Radars in the Frequency Band 77-81 GHz, et al., Report and Order and Order, 29 FCC Rcd. 761 ¶ 1 (2014). 18 See 47 C.F.R. §15.256(g)(3). Request for Confidential Treatment - Page 5

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 attenuated by obstructions. As a result, there is no risk of harmful interference to unlicensed operations in this band. 31.0-31.3 GHz band users (31 GHz band): ● Terrestrial licensees: Google’s continued operations also will not cause harmful interference to other users of the 31 GHz band. On Google’s behalf, Comsearch also identified the common carrier fixed point-to-point microwave service, LTTS, and LMDS licensees operating in this band in the vicinity of Google’s operations.19 Notification letters were sent to each of the licensees operating within the vicinity of Google’s testing, informing them of the technical parameters of the experimentation.20 No licensee objected21 and no interference has been reported. Comsearch also identified site-based licenses in the microwave public safety and industrial/business pool services.22 It then performed an analysis to assess the interference into all potentially affected site-based 31 GHz stations in the microwave public safety and industrial/business pool services.23 This analysis shows that no incumbent fixed operations should be affected by the experimental operation.24 ● Federal operations: The Table of Frequency Allocations reflects a federal allocation for standard frequency and time signal-satellite (space-to-earth) operations. Google is not aware of any federal standard frequency and time signal-satellites using the 31 GHz band, but is prepared to coordinate with such satellite operations as necessary. Google is also prepared to coordinate with NTIA to ensure that federal operations in the band do not experience harmful interference. International users: Because the test sites are more than 700 kilometers away from U.S. borders, no international coordination is required. 19 See Exhibit C at 1. 20 Id. 21 Id. The notification letters discussed wideband operation. As noted above, Google seeks to continue conducting a limited number of narrowband tests. Comsearch’s report notes that since “the narrower emission bandwidth is within the 31.0 to 31.3 GHz range of the coordinated emission bandwidth and the EIRP is not increasing, the interference potential is not increased” in the minimal narrowband testing. As such, no additional coordination with terrestrial licensees should be required for continued testing. See id. at 8. 22 Id. at 1. 23 Id. 24 Id. Request for Confidential Treatment - Page 6

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 Finally, as noted, Google has already been conducting similar tests in this area under a grant of Special Temporary Authority, and no disruptions have been noted. 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: 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 Chris White Contact Details 1600 Amphitheatre Parkway Mountain View, CA 94043 Phone: (650) 214-0860 Email: cjwhite@google.com Ka-Band Transmitter Equipment and Station Details Transmitter Equipment (Location #1) Equipment [REDACTED] Number of Terminals [REDACTED] Station Class Fixed Location 37° 20’ 41” N, 122° 12’ 56” W Request for Confidential Treatment - Page 7

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 Frequency Range Low (GHz) High (GHz) [REDACTED] 27.900 28.000 Radio Modulation Emission Modulation Maximum Maximum Designator Bandwidth Power Out EIRP/ERP [REDACTED] QAM 100MD1D 100 MHz 4W 48.321 dBW/ 0.0414 MW Antenna Information (Location #1) Antenna #1 [REDACTED] Type [REDACTED] Quantity [REDACTED] Gain 42.3 dBi Beam Width at 1.3 degrees Half-Power Point Orientation in 56 degrees (NE) Horizontal Plane Orientation in Vertical -2 degrees Plane Antenna #2 [REDACTED] Type [REDACTED] Quantity [REDACTED] Gain 22-27 dBi Beam Width at 0.5-3 degrees in azimuth, 10-50 degrees in Half-Power Point elevation Orientation in 56 degrees (NE) Horizontal Plane Orientation in Vertical -2 degrees Plane Request for Confidential Treatment - Page 8

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 Transmitter Equipment (Location #2) Equipment [REDACTED] Number of Terminals [REDACTED] Station Class Fixed Location 37° 25’ 33” N, 122° 4’ 22” W Frequency Range Low (GHz) High (GHz) [REDACTED] 31.000 31.300 Radio Modulation Emission Modulation Maximum Maximum Designator Bandwidth Power Out EIRP/ERP [REDACTED] QAM 300MD1D 300 MHz 4W 54.021 dBW/ 0.153 MW [REDACTED] BPSK 15M0G1D 15 MHz 4W 54.021 dBW/ 0.153 MW [REDACTED] Continuous 100HK0N 100 Hz 4W 54.021 Waveform dBW/ 0.153 MW Antenna Information (Location #2) Antenna #1 [REDACTED] Type [REDACTED] Quantity [REDACTED] Gain 42.3 dBi Beam Width at 1.3 degrees Half-Power Point Orientation in 234 degrees (SW) Horizontal Plane Orientation in Vertical +2 degrees Plane Request for Confidential Treatment - Page 9

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 Antenna #2 [REDACTED] Type [REDACTED] Quantity [REDACTED] Gain 48 dBi Beam Width at 0.70 degrees Half-Power Point Orientation in 234 degrees (SW) Horizontal Plane Orientation in Vertical +2 degrees Plane 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 B were submitted to the Commission in support of the STA Extension. The Exhibits were filed with the Office of Engineering and Technology on June 13, 2016. For additional information, please see File No. 0784-EX-ST-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 STA Extension discuss tests/experiments that include trade secret information. The Commission has clarified that confidential treatment should be afforded to 25 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. 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 STA Extension have not yet been fully developed but are expected to lead to material developments in markets subject to 25 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 10

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 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 11

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-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 STA Extension 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 12

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 EXHIBIT A – NARRATIVE STATEMENT Consistent with the standards set forth in Section 5.61 of the Federal Communications Commission’s (FCC’s or Commission’s) Rules, 47 C.F.R. § 5.61, Google Inc. (Google) outlines below its need for the requested extension of Special Temporary Authority (STA Extension) and the compelling reasons why it should be granted expeditiously. Google requests that the STA Extension be granted for a period of 180 days. The STA Extension is needed for continued development of [REDACTED]. Among other parameters, Google will continue to evaluate [REDACTED]. Consistent with 1216-EX-ST-2015 (Call Sign WJ9XGG), the equipment used will continue to include [REDACTED] at any given time. [REDACTED] radio will continue to be used with [REDACTED] antennas with a gain not to exceed 42.3 dBi. For that radio, the maximum equivalent isotropically radiated power (EIRP) will not exceed 48.3 dBW, regardless of the antenna used. [REDACTED] radio will continue to be used with [REDACTED] antennas with a gain not to exceed 48 dBi. Maximum EIRP from this radio will not exceed 54 dBW, regardless of the antenna used. While most of Google’s testing will continue to use wideband transmissions, Google also seeks authorization to conduct limited narrowband testing in the 31 GHz band. Narrowband testing is expected to take place over no more than 12 hours during the pendency of the STA Extension. Grant of this STA Extension will not adversely impact any authorized user of RF spectrum for the reasons stated below. 27.9-28.0 GHz band users (the 27 GHz band): Google’s continued operations will not cause harmful interference to other users of the 27 GHz band. ● Terrestrial licensees: On Google’s behalf, Comsearch identified 27 GHz band licensees in the common carrier fixed point-to-point microwave service, local television transmission service (LTTS) and local multipoint distribution service (LMDS).1 Notification letters were sent to each of the licensees operating within the vicinity of Google’s testing, informing them of the technical parameters of the experimentation.2 No licensee objected3 and no interference has been reported. ● Satellite operations: Google’s continued testing will not interfere with satellite receivers operating in the 27 GHz band. Google has conducted analyses evaluating the potential for interference to geostationary (GSO) satellites, 1 See Exhibit C (Frequency Coordination Report) to 1216-EX-ST-2015 (Call Sign WJ9XGG). 2 Id. at 1. 3 Id. The technical coordination report specified that Google would use an antenna with a gain of 27 dBi in its operation. The request for an STA Extension seeks authorization to continue to operate antennas with gains as low as 22 dBi. However, if Google uses a lower antenna gain, the EIRP in the direction of other authorized operations would be correspondingly reduced, ensuring that there is no greater potential for interference to those operations. Exhibit A - Page 1

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 medium-earth orbit (MEO) satellites, and low-earth orbit (LEO) satellites. Each of these analyses is described below. GSO satellites: To assess potential interference to GSO satellites, Google calculated interference levels from the sidelobes of its [REDACTED] antenna into the satellite receiver. The 27 GHz band is allocated for earth-to-space transmissions, so interference with ground station receivers is not a concern.4 Moreover, the 27 GHz transmitter will continue to point at an elevation angle below the horizon, so the main beam will never be pointing toward the satellite receiver. In performing its analysis, Google relied on the technical parameters for GSO satellites set forth in ITU-R Recommendation SF 1601-2.5 In particular, this recommendation suggests a GSO satellite has a maximum receive antenna gain of 55 dBi and a system noise temperature of 500K.6 To approximate worst case conditions, Google assumed that Google’s ground transmitter was located directly in the spot beam of the satellite’s receiver. Google made additional worst case assumptions regarding its own antenna by assuming its antenna has +10 dBi gain in the direction of the GSO satellite receiver.7 Assuming free space propagation between Google’s transmitter and the satellite’s receiver, Google’s analysis showed that any signal received by the satellite from Google’s transmitter would be at least 19.2 dB below the satellite receiver’s thermal noise floor. This equates to at most 0.052 dB in degradation, which should be nearly undetectable on a data link. ITU Recommendation S.1323-2 recommends that internetwork interference caused by the earth and space station emissions of any one other GSO FSS network operating in the same frequency band or bands be limited to 6% of the total system noise power under clear-sky conditions.8 Link degradation of 0.052 dB corresponds to 1.2% of total system noise power. Moreover, the received signal at the GSO satellite is likely is to be even weaker because any satellite antenna pointed at an associated satellite earth station necessarily will be pointing substantially away from Google’s transmitter location. The closest earth station to Google’s terrestrial transmitter is at least 257 km away.9 As a result, any satellite receiver operating in this band will be pointed at a terrestrial location at least 257 kilometers away from Google’s test location, 4 See 47 C.F.R. § 2.106. 5 ITU-R Recommendation SF 1601-2, Methodologies for Interference Evaluation from the Downlink of the Fixed Service Using High Altitude Platform Stations to the Uplink of the Fixed-satellite Service Using the Geostationary Satellites Within the Band 27.5-28.35 GHz (2007), available at http://www.itu.int/rec/R-REC-SF.1601-2-200702-I (ITU-R Recommendation SF 1601-2). 6 Id. at 8. 7 [REDACTED]. 8 ITU-R Recommendation S.1323-2, Maximum Permissible Levels of Interference in a Satellite Network (GSO/FSS; Non-GSO/FSS; Non-GSO/MSS Feeder Links) in the Fixed-satellite Service Caused by Other Codirectional FSS Networks Below 30 GHz (2002), available at https://www.itu.int/rec/R-REC-S.1323/en (ITU-R Recommendation S.1323-2). 9 The distance between Google’s continued operations and the Nevada border is 257 kilometers. Exhibit A - Page 2

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 ensuring that its receiver will be a minimum 0.41 degrees off-boresight from the Google transmitter. MEO and LEO satellites: Google’s continued testing will not interfere with MEO or LEO satellites. A search of the FCC’s IBFS database shows that there are no MEO or LEO earth stations registered in California. Therefore, the closest earth station to Google’s operation can be no closer than the Nevada border, roughly 257 kilometers away from Google’s operation. If a MEO satellite operates at roughly 8,000 kilometers above the earth’s surface10 and points at an earth station at least 257 kilometers from the edge of Google’s operating area, the MEO satellite’s receive antenna will continue to be off axis from Google’s transmitter in California by at least 1.8 degrees. Relying on the antenna patterns recommended in ITU-R Recommendation F.699-7,11 the satellite receive antenna gain in the direction of Google’s operation is at most 30 dBi for MEO satellites. Using a worst case antenna gain of +10 dBi in the direction of the satellite, and a satellite receiver noise temperature of 500K,12 the signal received by a MEO satellite from Google’s transmitter will be at least 28 dB below the noise floor. As noted above, ITU Recommendation S.1323-2 recommends that internetwork interference caused by the earth and space station emissions of any one other GSO FSS network operating in the same frequency band or bands be limited to 6% of the total system noise power under clear-sky conditions.13 Transmissions at 28.3 dB below the noise floor correspond to 0.16% of total system noise power and will not cause harmful interference to MEO satellites. To assess potential interference to LEO satellites, Google assumed that such satellites would operate at orbital heights between 500 and 2000 kilometers above mean sea level and conducted the same analysis described above.14 Google’s results are summarized in the table below: 10 O3b Networks operates a MEO satellite in this band, and that satellite operates at an orbital height of 8062 kilometers. 11 ITU-R Recommendation F.699, Reference Radiation Patterns for Fixed Wireless System Antennas for Use in Coordination Studies and Interference Assessment in the Frequency Range From 100 MHz to About 70 GHz (2006), available at https://www.itu.int/rec/R-REC-F.699/en. 12 ITU-R Recommendation SF 1601-2. 13 ITU-R Recommendation S.1323-2. The ITU has not issued similar recommendations for MEO and LEO satellites, so Google has assumed that the system noise temperature and antenna gain characteristics for LEOs and MEOs are similar to those provided in the ITU-R Recommendation S.1323-2. 14 Mark A. Sturza, LEOs: The Communications Satellites of the 21st Century 1, IEEE Technical Applications Conference Northcon/96 Conference Record (1996), available at http://ieeexplore.ieee.org/xpls/abs_all.jsp?arnumber=564754&tag=1. Exhibit A - Page 3

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 Satellite height 500 km 1000 km 2000 km Minimum angle 27 degrees 14 degrees 7 degrees off-boresight from Google operations Maximum receive 10 dBi 15.3 dBi 21.4 dBi antenna gain in direction of Google operations Maximum power of 27.7 dBm below 28.2 dBm below 27.7 dBm below Google signal received noise floor noise floor noise floor by satellite Based on this analysis, the signal received by a LEO satellite from Google’s operation will continue to be at least 27 dB below the receiver noise floor. This interference level, too, is undetectable on a data link. As noted above, ITU Recommendation S.1323-2 recommends that internetwork interference caused by the earth and space station emissions of any one other GSO FSS network operating in the same frequency band or bands be limited to 6% of the total system noise power under clear-sky conditions.15 Transmissions at 27 dB below the noise floor correspond to 0.2% of total system noise power and will not cause harmful interference to LEO satellites. ● Unlicensed operations: Google’s continued testing will not interfere with unlicensed users of the 24.05-29.00 GHz band. Unlicensed use of the band is limited to level sensing radars.16 These low-power radars measure the level, or relative height, of various substances in man-made or natural containers. For example, they may be used to measure water basin levels, coal piles, or grain levels in a silo.17 The Commission’s rules require their transmit antennas to be oriented downward. Google’s continued operation will transmit horizontally, and at ground level, the test emissions will not exceed the −14 dBm/MHz EIRP density set forth in the rules for these radars.18 [REDACTED]. [REDACTED], the closest possible sensors would be at least 300 meters away, [REDACTED]. [REDACTED]. Moreover, many level probing radars are used in confined spaces where Google’s signal will continue to be further attenuated by obstructions. As a result, there is no risk of harmful interference to unlicensed operations in this band. 15 ITU-R Recommendation S.1323-2. 16 See 47 C.F.R. §15.256. 17 In the Matter of Amendment of Part 15 of the Commission’s Rules To Establish Regulations for Tank Level Probing Radars in the Frequency Band 77-81 GHz, et al., Report and Order and Order, 29 FCC Rcd. 761 ¶ 1 (2014). 18 See 47 C.F.R. §15.256(g)(3). Exhibit A - Page 4

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 31.0-31.3 GHz band users (31 GHz band): ● Terrestrial licensees: Google’s continued operations also will not cause harmful interference to other users of the 31 GHz band. On Google’s behalf, Comsearch also identified the common carrier fixed point-to-point microwave service, LTTS, and LMDS licensees operating in this band in the vicinity of Google’s operations.19 Notification letters were sent to each of the licensees operating within the vicinity of Google’s testing, informing them of the technical parameters of the experimentation.20 No licensee objected21 and no interference has been reported. Comsearch also identified site-based licenses in the microwave public safety and industrial/business pool services.22 It then performed an analysis to assess the interference into all potentially affected site-based 31 GHz stations in the microwave public safety and industrial/business pool services.23 This analysis shows that no incumbent fixed operations should be affected by the experimental operation.24 ● Federal operations: The Table of Frequency Allocations reflects a federal allocation for standard frequency and time signal-satellite (space-to-earth) operations. Google is not aware of any federal standard frequency and time signal-satellites using the 31 GHz band, but is prepared to coordinate with such satellite operations as necessary. Google is also prepared to coordinate with NTIA to ensure that federal operations in the band do not experience harmful interference. International users: Because the test sites are more than 700 kilometers away from U.S. borders, no international coordination is required. Finally, as noted, Google has already been conducting similar tests in this area under a grant of Special Temporary Authority, and no disruptions have been noted. 19 See Exhibit C at 1. 20 Id. 21 Id. The notification letters discussed wideband operation. As noted above, Google seeks to continue conducting a limited number of narrowband tests. Comsearch’s report notes that since “the narrower emission bandwidth is within the 31.0 to 31.3 GHz range of the coordinated emission bandwidth and the EIRP is not increasing, the interference potential is not increased” in the minimal narrowband testing. As such, no additional coordination with terrestrial licensees should be required for continued testing. See id. at 8. 22 Id. at 1. 23 Id. 24 Id. Exhibit A - Page 5

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 EXHIBIT B - 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 Chris White Contact Details 1600 Amphitheatre Parkway Mountain View, CA 94043 Phone: (650) 214-0860 Email: cjwhite@google.com Exhibit B - Page 1

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 Ka-Band Transmitter Equipment and Station Details Transmitter Equipment (Location #1) Equipment [REDACTED] Number of Terminals [REDACTED] Station Class Fixed Location 37° 20’ 41” N, 122° 12’ 56” W Frequency Range Low (GHz) High (GHz) [REDACTED] 27.900 28.000 Radio Modulation Emission Modulation Maximum Maximum Designator Bandwidth Power Out EIRP/ERP [REDACTED] QAM 100MD1D 100 MHz 4W 48.321 dBW/ 0.0414 MW Antenna Information (Location #1) Antenna #1 [REDACTED] Type [REDACTED] Quantity [REDACTED] Gain 42.3 dBi Beam Width at Half-Power Point 1.3 degrees Orientation in Horizontal Plane 56 degrees (NE) Orientation in Vertical Plane -2 degrees Antenna #2 [REDACTED] Type [REDACTED] Quantity [REDACTED] Gain 22-27 dBi Beam Width at Half-Power Point 0.5-3 degrees in azimuth, 10-50 degrees in elevation Orientation in Horizontal Plane 56 degrees (NE) Orientation in Vertical Plane -2 degrees Exhibit B - Page 2

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 Transmitter Equipment (Location #2) Equipment [REDACTED] Number of Terminals [REDACTED] Station Class Fixed Location 37° 25’ 33” N, 122° 4’ 22” W Frequency Range Low (GHz) High (GHz) [REDACTED] 31.000 31.300 Radio Modulation Emission Modulation Maximum Maximum Designator Bandwidth Power Out EIRP/ERP [REDACTED] QAM 300MD1D 300 MHz 4W 54.021 dBW/ 0.153 MW [REDACTED] BPSK 15M0G1D 15 MHz 4W 54.021 dBW/ 0.153 MW [REDACTED] Continuous 100HK0N 100 Hz 4W 54.021 dBW/ Waveform 0.153 MW Antenna Information (Location #2) Antenna #1 [REDACTED] Type [REDACTED] Quantity [REDACTED] Gain 42.3 dBi Beam Width at Half-Power Point 1.3 degrees Orientation in Horizontal Plane 234 degrees (SW) Orientation in Vertical Plane +2 degrees Exhibit B - Page 3

PUBLIC REDACTED VERSION Google Inc. File No. 0784-EX-ST-2016 Antenna #2 [REDACTED] Type [REDACTED] Quantity [REDACTED] Gain 48 dBi Beam Width at Half-Power Point 0.70 degrees Orientation in Horizontal Plane 234 degrees (SW) Orientation in Vertical Plane +2 degrees Exhibit B - Page 4


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Document Modified: 7220-04-27 00:00:00
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