Request for Confidential Treatment and Exhibits PUBLIC

1021-EX-ST-2015 Text Documents

Google Inc.

2015-09-14ELS_167093

                                                                  PUBLIC REDACTED VERSION

                                                                                        Google Inc.
                                                                         File No. 1021­EX­ST­2015

Date:                  September 14, 2015

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

FCC File Number:       1021­EX­ST­2015



To Whom It May Concern:

        Google Inc. (Google), pursuant to 5 U.S.C. § 552 and Sections 0.457 and 0.459 of the
Commission's Rules, 47 C.F.R. §§ 0.457, 0.459, hereby requests that certain information
complementary to its above­referenced application for Special Temporary Authority (STA) 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 STA 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.

       Google requests confidential treatment of the following underlined text from each of the
exhibits in support of the application, all of which contain confidential and proprietary information
regarding the proposed tests/experiments.

        Exhibit A ­ Narrative Statement:

                  Google Inc. (Google), pursuant to Section 5.61 of the Federal Communications
           Commission’s (FCC’s or Commission’s) Rules, 47 C.F.R. § 5.61, hereby requests a
           Special Temporary Authority (STA) to conduct experimental operations. The STA is
           sought for a period of 180 days. Consistent with the standards set forth in the rule,
           Google outlines below its need for the requested STA and the reasons that this
           request should be granted expeditiously.

                Google’s Project Wing involves the development of low­altitude small
           unmanned aerial systems (UAS). These UAS can help to solve many longstanding
                                                      Request for Confidential Treatment ­ Page 1


                                                                   PUBLIC REDACTED VERSION

                                                                                        Google Inc.
                                                                         File No. 1021­EX­ST­2015

           challenges, such as rapidly delivering medical supplies to remote areas and inspecting
           hard­to­reach infrastructure without risk to human participants. The requested STA,
           including waiver of [REDACTED], is needed for demonstration and testing of
           [REDACTED], in a carefully controlled environment.

                Testing under the STA will be limited to [REDACTED] transmitters
           [REDACTED]. [REDACTED]. [REDACTED]. [REDACTED].

                  The transmitters [REDACTED] are [REDACTED] that have been certified by
           the Commission for sale in the United States. Because the transmitters will
           [REDACTED], they will only operate on frequencies [REDACTED] at the proposed test
           area.1 The transmitters will also operate at or below the power levels and with the
           emissions characteristics set forth in their respective equipment authorization grants.

                  Flight operations are being conducted pursuant to an [REDACTED], which is
           provided as Exhibit C. [REDACTED].

                    The proposed use of the transmitters conforms to applicable Commission rules
           in all respects but one: [REDACTED]. [REDACTED].2 [REDACTED].3 [REDACTED].
           [REDACTED].4

                  These concerns are not relevant to the operations proposed in this STA, as the
           Wing [REDACTED]. [REDACTED]. [REDACTED].

                   As reflected in Exhibit D, [REDACTED] providing service to the transmitters at
           issue in this STA (and to the surrounding areas) confirms that the proposed use does
           not pose any threat to [REDACTED]. Google does not propose to operate on
           frequencies [REDACTED].

                  The Commission is considering whether to [REDACTED].5 This proposal is
           grounded in the same concern as the current [REDACTED].6 For the same reasons
           discussed above, the [REDACTED] operations proposed here do not implicate that
           concern. Accordingly, Google seeks the requested authorization notwithstanding the
           possible future amendment of [REDACTED],7 or any other changes to the




1
    See Exhibit B for a complete list of frequencies that will be used by each transmitter.
2
    [REDACTED].
3
    [REDACTED].
4
    Id.
5
    [REDACTED].
6
    [REDACTED].
7
    [REDACTED].

                                                       Request for Confidential Treatment ­ Page 2


                                                               PUBLIC REDACTED VERSION

                                                                                    Google Inc.
                                                                     File No. 1021­EX­ST­2015

        Commission’s rules that otherwise would restrict or prohibit the proposed operations
        during the term of the STA.

               Absent the requested authorization, Google will be unable in its testing to take
        advantage of [REDACTED]. This would limit the value of the planned radio
        experimentation and hinder the development of a significant new use case for
        [REDACTED]. [REDACTED] could generate new business opportunities for
        communications service providers and remove barriers to the broader deployment of
        UAS.8 This technology could also support important safety advances, as Google and
        other companies work develop robust, redundant mobile communications for UAS.9



       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           Jeremy Chalmer
           Contact Details           1600 Amphitheatre Parkway
                                     Mountain View, CA 94043
                                     jchalmer@google.com
                                     650­253­9000




8
  See Comments by the Association for Unmanned Vehicle Systems International, App. at 2­15
Operation and Certification of Small Unmanned Aircraft Systems, FAA­2015­0150 (May 6,
2015), http://www.regulations.gov/#!documentDetail;D=FAA­2015­0150­4416.
9
  See Comments of Google Inc. Operation and Certification of Small Unmanned Aircraft
Systems at 10, FAA­2015­0150,
http://www.regulations.gov/#!documentDetail;D=FAA­2015­0150­4529.


                                                   Request for Confidential Treatment ­ Page 3


                                                             PUBLIC REDACTED VERSION

                                                                                    Google Inc.
                                                                     File No. 1021­EX­ST­2015

        Transmitter #1 Equipment and Station Details

           Equipment             [REDACTED]
           Number                [REDACTED]
           Area of Operation     Operation will be confined to the area delimited by a 10 km
                                 radius around:
                                     ● 37° 19’ 26” N 120° 18’ 39” W


          Transmitter #1 Frequencies and Emissions Characteristics

             Frequencies       Modulation   Emission   Maximum Maximum                 EIRP
                (MHz)                       Designator Bandwidth  Power               (dBW)
                                                        (MHz)10  Out (W)10
             706.50­713.50       Digital     4M50G7D          4.50          0.147      ­8.3
                                             4M50W7D
             824.20­835.00       Digital     244KGXW          4.49          0.617      ­2.1
                                             240KG7W
                                             4M15F9W
                                             1M12G7D
                                             1M13W7D
                                             2M71G7D
                                             2M71W7D
                                             4M49G7D
                                             4M49W7D
             845.00­846.50       Digital     244KGXW          1.13          0.617      ­2.1
                                             240KG7W
                                             1M12G7D
                                             1M13W7D
           1710.70­1720.00       Digital     4M14F9W          4.52          0.415      ­3.8
                                             1M12G7D
                                             1M13W7D
                                             2M72G7D
                                             2M71W7D
                                             4M50G7D
                                             4M52W7D
           1730.00­1735.00       Digital     4M14F9W          4.52          0.415      ­3.8


10
   For each frequency range, maximum bandwidths and powers are listed. Individual emissions
designators may indicate lower bandwidths and may be associated with lower power levels. As
noted in Exhibit A, power levels and emissions characteristics will be consistent with the
certification grant for the particular device being used.
                                                 Request for Confidential Treatment ­ Page 4


                                                   PUBLIC REDACTED VERSION

                                                                          Google Inc.
                                                           File No. 1021­EX­ST­2015


                                   1M12G7D
                                   1M13W7D
                                   2M72G7D
                                   2M71W7D
                                   4M50G7D
                                   4M52W7D
   1865.00­1885.00     Digital     242KGXW          17.9          0.94       ­0.3
                                   245KG7W
                                   4M15F9W
                                   1M12G7D
                                   1M12W7D
                                   2M72G7D
                                   2M72W7D
                                   4M51G7D
                                   4M50W7D
                                   8M98G7D
                                   9M00W7D
                                   13M5G7D
                                   13M4W7D
                                   17M9G7D
                                   17M9W7D
   1895.00­1909.80     Digital     242KGXW          9.00          0.94       ­0.3
                                   245KG7W
                                   4M15F9W
                                   1M12G7D
                                   1M12W7D
                                   2M72G7D
                                   2M72W7D
                                   4M51G7D
                                   4M50W7D
                                   8M98G7D
                                   9M00W7D


Transmitter #2 Equipment and Station Details

  Equipment           [REDACTED]
  Number              [REDACTED]
  Area of Operation   Operation will be confined to the area delimited by a 10 km
                      radius around:
                          ● 37° 19’ 26” N 120° 18’ 39” W



                                       Request for Confidential Treatment ­ Page 5


                                                            PUBLIC REDACTED VERSION

                                                                                   Google Inc.
                                                                    File No. 1021­EX­ST­2015

          Transmitter #2 Frequencies and Emissions Characteristics

             Frequencies      Modulation    Emission      Maximum Maximum             EIRP
                (MHz)                       Designator    Bandwidth Power Out        (dBW)
                                                           (MHz)11    (W)11
            706.50­713.50       Digital     4M47G7D          4.50          0.282       ­5.5
                                            4M50D7W
            824.20­835.00       Digital     250KGXW          4.16         0.7112       ­1.5
                                            239KG7W
                                            1M28F9W
                                            1M07G7D
                                            1M08D7W
                                            4M16F9W
            845.00­846.50       Digital     250KGXW          1.28         0.7112       ­1.5
                                            239KG7W
                                            1M28F9W
                                            1M07G7D
                                            1M08D7W
           1710.70­1720.00      Digital     4M15F9W          4.15         0.4966       ­3.0
                                            1M08G7D
                                            1M11D7W
           1730.00­1735.00      Digital     4M15F9W          4.15         0.4966       ­3.0
                                            1M08G7D
                                            1M11D7W
           1865.00­1885.00      Digital     251KGXW          17.8         1.5959       2.0
                                            245KG7W
                                            1M29F9W
                                            4M20F9W
                                            1M07G7D
                                            1M08D7W
                                            17M7G7D
                                            17M8D7W
           1895.00­1910.00      Digital     251KGXW          4.20         1.5959       2.0
                                            245KG7W
                                            1M29F9W
                                            4M20F9W
                                            1M07G7D

11
  For each frequency range, maximum bandwidths and powers are listed. Individual emissions
designators may indicate lower bandwidths and may be associated with lower power levels. As
noted in Exhibit A, power levels and emissions characteristics will be consistent with the
certification grant for the particular device being used.
                                                 Request for Confidential Treatment ­ Page 6


                                                              PUBLIC REDACTED VERSION

                                                                                     Google Inc.
                                                                      File No. 1021­EX­ST­2015


                                               1M08D7W


        Transmitter #3 Equipment and Station Details

           Equipment             [REDACTED]
           Number                [REDACTED]
           Area of Operation     Operation will be confined to the area delimited by a 10 km
                                 radius around:
                                     ● 37° 19’ 26” N 120° 18’ 39” W


          Transmitter #3 Antenna Information

           Antenna                               [REDACTED]
           Type                                  Omnidirectional
           Quantity                              [REDACTED]
           Gain                                  1.49 dBi to 2.93 dBi (frequency dependent)
           Beam Width at Half­Power Point        120°
           Orientation in Horizontal Plane       N/A
           Orientation in Vertical Plane         N/A


          Transmitter #3 Frequencies and Emissions Characteristics

             Frequencies       Modulation     Emission     Maximum Maximum              EIRP
                (MHz)                        Designator    Bandwidth Power Out         (dBW)
                                                            (MHz)12    (W)12
            825.50­835.00        Digital       4M17F9W         4.17          0.199       ­7.0
                                               2M90G7D
                                               2M90W7D
           1865.00­1885.00       Digital       4M17F9W         18.1         0.1811       ­7.4
                                               13M6G7D
                                               1M10W7D
                                               18M1G7D
                                               18M1W7D

12
  For each frequency range, maximum bandwidths and powers are listed. Individual emissions
designators may indicate lower bandwidths and may be associated with lower power levels. As
noted in Exhibit A, power levels and emissions characteristics will be consistent with the
certification grant for the particular device being used.
                                                  Request for Confidential Treatment ­ Page 7


                                                                  PUBLIC REDACTED VERSION

                                                                                         Google Inc.
                                                                          File No. 1021­EX­ST­2015


            1895.00­1909.30         Digital      4M17F9W            4.1         0.1706       ­7.7
                                                 1M10W7D



       Exhibit C ­ Airworthiness Statement:

       Google requests confidential treatment of Exhibit C in its entirety.


       Exhibit D ­ Correspondence with Serving Mobile Carrier:

       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 above­referenced Exhibits were submitted to the Commission in support of the STA.
For additional information, please see File No. 1021­EX­ST­2015.


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 STA tests/experiments may include trade secret information. The Commission
                                                                              13
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 may 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.




13
   Examination of Current Policy Concerning the Treatment of Confidential Information
Submitted to the Commission, Report and Order, GC Docket No. 96­55, at para. 3, (released
Aug. 4, 1998) (defining “trade secrets” for purpose of Commission rules on confidential
treatment).
                                                      Request for Confidential Treatment ­ Page 8


                                                                  PUBLIC REDACTED VERSION

                                                                                       Google Inc.
                                                                        File No. 1021­EX­ST­2015

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 have not yet been fully
developed but are expected to lead to material developments in markets subject to competition
from multiple U.S. and non­U.S. third parties.


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

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


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

        Google has taken steps to keep confidential the information set forth in the confidential
exhibits by limiting the number of people involved in the tests/experiments to only those on a
“need to know” basis, and 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 the 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.”)




                                                     Request for Confidential Treatment ­ Page 9


                                                                  PUBLIC REDACTED VERSION

                                                                                       Google Inc.
                                                                        File No. 1021­EX­ST­2015

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
STA 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




                                                    Request for Confidential Treatment ­ Page 10


                                                                   PUBLIC REDACTED VERSION

                                                                                        Google Inc.
                                                                         File No. 1021­EX­ST­2015

                              EXHIBIT A ­ NARRATIVE STATEMENT

        Google Inc. (Google), pursuant to Section 5.61 of the Federal Communications
Commission’s (FCC’s or Commission’s) Rules, 47 C.F.R. § 5.61, hereby requests a Special
Temporary Authority (STA) to conduct experimental operations. The STA is sought for a period
of 180 days. Consistent with the standards set forth in the rule, Google outlines below its need
for the requested STA and the reasons that this request should be granted expeditiously.

         Google’s Project Wing involves the development of low­altitude small unmanned aerial
systems (UAS). These UAS can help to solve many longstanding challenges, such as rapidly
delivering medical supplies to remote areas and inspecting hard­to­reach infrastructure without
risk to human participants. The requested STA, including waiver of [REDACTED], is needed for
demonstration and testing of [REDACTED], in a carefully controlled environment.

     Testing under the STA will be limited to [REDACTED] transmitters [REDACTED].
[REDACTED]. [REDACTED]. [REDACTED].

       The transmitters [REDACTED] are [REDACTED] that have been certified by the
Commission for sale in the United States. Because the transmitters will [REDACTED], they will
only operate on frequencies [REDACTED] at the proposed test area.1 The transmitters will also
operate at or below the power levels and with the emissions characteristics set forth in their
respective equipment authorization grants.

        Flight operations are being conducted pursuant to an [REDACTED], which is provided as
Exhibit C. [REDACTED].

       The proposed use of the transmitters conforms to applicable Commission rules in all
respects but one: [REDACTED]. [REDACTED].2 [REDACTED].3 [REDACTED].
[REDACTED].4

     These concerns are not relevant to the operations proposed in this STA, as the Wing
[REDACTED]. [REDACTED]. [REDACTED].

        As reflected in Exhibit D, [REDACTED] providing service to the transmitters at issue in
this STA (and to the surrounding areas) confirms that the proposed use does not pose any
threat to [REDACTED]. Google does not propose to operate on frequencies [REDACTED].




1
    See Exhibit B for a complete list of frequencies that will be used by each transmitter.
2
    [REDACTED].
3
    [REDACTED].
4
    Id.

                                                                                    Exhibit A ­ Page 1


                                                             PUBLIC REDACTED VERSION

                                                                                  Google Inc.
                                                                   File No. 1021­EX­ST­2015

        The Commission is considering whether to [REDACTED].5 This proposal is grounded in
the same concern as the current [REDACTED].6 For the same reasons discussed above, the
[REDACTED] operations proposed here do not implicate that concern. Accordingly, Google
seeks the requested authorization notwithstanding the possible future amendment of
[REDACTED],7 or any other changes to the Commission’s rules that otherwise would restrict or
prohibit the proposed operations during the term of the STA.

        Absent the requested authorization, Google will be unable in its testing to take
advantage of [REDACTED]. This would limit the value of the planned radio experimentation and
hinder the development of a significant new use case for [REDACTED]. [REDACTED] could
generate new business opportunities for communications service providers and remove barriers
to the broader deployment of UAS.8 This technology could also support important safety
advances, as Google and other companies work develop robust, redundant mobile
communications for UAS.9




5
    [REDACTED].
6
    [REDACTED].
7
    [REDACTED].
8
  See Comments by the Association for Unmanned Vehicle Systems International, App. at 2­15
Operation and Certification of Small Unmanned Aircraft Systems, FAA­2015­0150 (May 6,
2015), http://www.regulations.gov/#!documentDetail;D=FAA­2015­0150­4416.
9
  See Comments of Google Inc. Operation and Certification of Small Unmanned Aircraft
Systems at 10, FAA­2015­0150,
http://www.regulations.gov/#!documentDetail;D=FAA­2015­0150­4529.


                                                                            Exhibit A ­ Page 2


                                                             PUBLIC REDACTED VERSION

                                                                                  Google Inc.
                                                                   File No. 1021­EX­ST­2015

                        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          Jeremy Chalmer
   Contact Details          1600 Amphitheatre Parkway
                            Mountain View, CA 94043
                            jchalmer@google.com
                            650­253­9000


Transmitter #1 Equipment and Station Details

   Equipment             [REDACTED]
   Number                [REDACTED]
   Area of Operation     Operation will be confined to the area delimited by a 10 km radius
                         around:
                            ● 37° 19’ 26” N 120° 18’ 39” W




                                                                             Exhibit B ­ Page 1


                                                                         PUBLIC REDACTED VERSION

                                                                                               Google Inc.
                                                                                File No. 1021­EX­ST­2015

    Transmitter #1 Frequencies and Emissions Characteristics

        Frequencies        Modulation       Emission          Maximum          Maximum             EIRP
           (MHz)                            Designator        Bandwidth        Power Out          (dBW)
                                                                (MHz)1           (W)1
       706.50­713.50           Digital       4M50G7D              4.50            0.147             ­8.3
                                             4M50W7D
       824.20­835.00           Digital       244KGXW              4.49            0.617             ­2.1
                                             240KG7W
                                             4M15F9W
                                             1M12G7D
                                             1M13W7D
                                             2M71G7D
                                             2M71W7D
                                             4M49G7D
                                             4M49W7D
       845.00­846.50           Digital       244KGXW              1.13            0.617             ­2.1
                                             240KG7W
                                             1M12G7D
                                             1M13W7D
      1710.70­1720.00          Digital       4M14F9W              4.52            0.415             ­3.8
                                             1M12G7D
                                             1M13W7D
                                             2M72G7D
                                             2M71W7D
                                             4M50G7D
                                             4M52W7D
      1730.00­1735.00          Digital       4M14F9W              4.52            0.415             ­3.8
                                             1M12G7D
                                             1M13W7D
                                             2M72G7D
                                             2M71W7D
                                             4M50G7D
                                             4M52W7D
      1865.00­1885.00          Digital       242KGXW              17.9             0.94             ­0.3
                                             245KG7W
                                             4M15F9W
                                             1M12G7D

1
  For each frequency range, maximum bandwidths and powers are listed. Individual emissions
designators may indicate lower bandwidths and may be associated with lower power levels. As noted in
Exhibit A, power levels and emissions characteristics will be consistent with the certification grant for the
particular device being used.
                                                                                           Exhibit B ­ Page 2


                                                             PUBLIC REDACTED VERSION

                                                                                 Google Inc.
                                                                  File No. 1021­EX­ST­2015


                                    1M12W7D
                                    2M72G7D
                                    2M72W7D
                                    4M51G7D
                                    4M50W7D
                                    8M98G7D
                                    9M00W7D
                                    13M5G7D
                                    13M4W7D
                                    17M9G7D
                                    17M9W7D
    1895.00­1909.80     Digital     242KGXW           9.00           0.94           ­0.3
                                    245KG7W
                                    4M15F9W
                                    1M12G7D
                                    1M12W7D
                                    2M72G7D
                                    2M72W7D
                                    4M51G7D
                                    4M50W7D
                                    8M98G7D
                                    9M00W7D


Transmitter #2 Equipment and Station Details

   Equipment           [REDACTED]
   Number              [REDACTED]
   Area of Operation   Operation will be confined to the area delimited by a 10 km radius
                       around:
                          ● 37° 19’ 26” N 120° 18’ 39” W




                                                                            Exhibit B ­ Page 3


                                                                         PUBLIC REDACTED VERSION

                                                                                               Google Inc.
                                                                                File No. 1021­EX­ST­2015

    Transmitter #2 Frequencies and Emissions Characteristics

       Frequencies         Modulation       Emission          Maximum            Maximum             EIRP
          (MHz)                             Designator        Bandwidth          Power Out          (dBW)
                                                                (MHz)2             (W)2
       706.50­713.50          Digital       4M47G7D               4.50              0.282             ­5.5
                                            4M50D7W
       824.20­835.00          Digital       250KGXW               4.16             0.7112             ­1.5
                                            239KG7W
                                            1M28F9W
                                            1M07G7D
                                            1M08D7W
                                            4M16F9W
       845.00­846.50          Digital       250KGXW               1.28             0.7112             ­1.5
                                            239KG7W
                                            1M28F9W
                                            1M07G7D
                                            1M08D7W
      1710.70­1720.00         Digital       4M15F9W               4.15             0.4966             ­3.0
                                            1M08G7D
                                            1M11D7W
      1730.00­1735.00         Digital       4M15F9W               4.15             0.4966             ­3.0
                                            1M08G7D
                                            1M11D7W
      1865.00­1885.00         Digital       251KGXW               17.8             1.5959             2.0
                                            245KG7W
                                            1M29F9W
                                            4M20F9W
                                            1M07G7D
                                            1M08D7W
                                            17M7G7D
                                            17M8D7W
      1895.00­1910.00         Digital       251KGXW               4.20             1.5959             2.0
                                            245KG7W
                                            1M29F9W
                                            4M20F9W
                                            1M07G7D


2
  For each frequency range, maximum bandwidths and powers are listed. Individual emissions
designators may indicate lower bandwidths and may be associated with lower power levels. As noted in
Exhibit A, power levels and emissions characteristics will be consistent with the certification grant for the
particular device being used.
                                                                                            Exhibit B ­ Page 4


                                                                         PUBLIC REDACTED VERSION

                                                                                               Google Inc.
                                                                                File No. 1021­EX­ST­2015


                                            1M08D7W


Transmitter #3 Equipment and Station Details

     Equipment                [REDACTED]
     Number                   [REDACTED]
     Area of Operation        Operation will be confined to the area delimited by a 10 km radius
                              around:
                                 ● 37° 19’ 26” N 120° 18’ 39” W


    Transmitter #3 Antenna Information

     Antenna                                    [REDACTED]
     Type                                       Omnidirectional
     Quantity                                   [REDACTED]
     Gain                                       1.49 dBi to 2.93 dBi (frequency dependent)
     Beam Width at Half­Power Point             120°
     Orientation in Horizontal Plane            N/A
     Orientation in Vertical Plane              N/A


    Transmitter #3 Frequencies and Emissions Characteristics

       Frequencies         Modulation        Emission         Maximum          Maximum             EIRP
          (MHz)                             Designator        Bandwidth        Power Out          (dBW)
                                                                (MHz)3           (W)3
       825.50­835.00          Digital       4M17F9W               4.17            0.199             ­7.0
                                            2M90G7D
                                            2M90W7D
      1865.00­1885.00         Digital       4M17F9W               18.1            0.1811            ­7.4
                                            13M6G7D
                                            1M10W7D
                                            18M1G7D
                                            18M1W7D


3
  For each frequency range, maximum bandwidths and powers are listed. Individual emissions
designators may indicate lower bandwidths and may be associated with lower power levels. As noted in
Exhibit A, power levels and emissions characteristics will be consistent with the certification grant for the
particular device being used.
                                                                                           Exhibit B ­ Page 5


                                            PUBLIC REDACTED VERSION

                                                               Google Inc.
                                                File No. 1021­EX­ST­2015


1895.00­1909.30   Digital   4M17F9W   4.1        0.1706           ­7.7
                            1M10W7D




                                                          Exhibit B ­ Page 6


                         PUBLIC REDACTED VERSION

                                            Google Inc.
                             File No. 1021­EX­ST­2015

EXHIBIT C ­ [REDACTED]


     [REDACTED]


                                PUBLIC REDACTED VERSION

                                                   Google Inc.
                                    File No. 1021­EX­ST­2015

EXHIBIT D ­ CORRESPONDENCE WITH [REDACTED]

               [REDACTED]



Document Created: 9170-05-10 00:00:00
Document Modified: 9170-05-10 00:00:00

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