Request for Confidential Treatment and Exhibits PUBLIC

1216-EX-ST-2015 Text Documents

Google Inc.

2015-11-16ELS_169428

PUBLIC REDACTED VERSION Google Inc. File No. 1216-EX-ST-2015 Date: November 16, 2015 Subject: Public and Redacted Version of Request for Confidential Treatment and Complementary Exhibits FCC File No: 1216-EX-ST-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 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. 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 5.61 of the Federal Communications Commission’s (FCC’s or Commission’s) Rules, 47 C.F.R. § 5.61, Google Inc. (Google) requests Special Temporary Authority (STA) to conduct demonstrations of experimental transmitters. The STA is sought for a period of 180 days beginning on December 16, 2015. Google outlines below its need for the requested STA and the reasons that the STA should be granted expeditiously. The STA is needed for development of [REDACTED]. Among other parameters, Google will evaluate [REDACTED]. Request for Confidential Treatment - Page 1

PUBLIC REDACTED VERSION Google Inc. File No. 1216-EX-ST-2015 The equipment used will include [REDACTED] at any given time. [REDACTED] radio will 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 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 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. Grant of this STA 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 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 proposed testing, informing them of the technical parameters of the proposed experimentation.2 No licensee objected.3 ● Satellite operations: Google’s proposed 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 be pointing 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 1 See Exhibit C (Frequency Coordination Report). 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 proposed operation. The request for an STA seeks authorization 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. 1216-EX-ST-2015 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 proposed 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 km 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 proposed 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 proposed operation can be no closer than the Nevada border, roughly 257 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 operations and the Nevada border is 257 kilometers. Request for Confidential Treatment - Page 3

PUBLIC REDACTED VERSION Google Inc. File No. 1216-EX-ST-2015 kilometers away from Google’s proposed 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 proposed operating area, the MEO satellite’s receive antenna will 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. 1216-EX-ST-2015 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 received below noise below noise below noise by satellite floor floor floor Based on this analysis, the signal received by a LEO satellite from Google’s operation will 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 and MEO satellites. ● Unlicensed operations: Google’s proposed 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 levels water basin levels, coal piles, or grain levels in a grain silo.17 The Commission’s rules require their transmit antennas to be oriented downward. Google’s proposed 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 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. 1216-EX-ST-2015 will be further 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 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 proposed operations.19 Notification letters were sent to each of the licensees operating within the vicinity of Google’s proposed testing, informing them of the technical parameters of the proposed experimentation.20 No licensee objected.21 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 proposed 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 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. The proposed experimental operations in the 27 and 31 GHz bands accordingly will be conducted without harmful interference to other authorized users. For these reasons, Google requests approval of this STA request. 19 See Exhibit C at 1. 20 Id. 21 Id. The notification letters discussed wideband operation. As noted above, Google seeks to conduct 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. 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. 1216-EX-ST-2015 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 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 Frequency Range Low (GHz) High (GHz) [REDACTED] 27.900 28.000 Radio Modulation Emission Modulation Maximum Maximum Designator Bandwidth Power Out EIRP [REDACTED] QAM 100MD1D 100 MHz 4W 48.3 dBW Request for Confidential Treatment - Page 7

PUBLIC REDACTED VERSION Google Inc. File No. 1216-EX-ST-2015 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 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 Request for Confidential Treatment - Page 8

PUBLIC REDACTED VERSION Google Inc. File No. 1216-EX-ST-2015 Radio Modulation Emission Modulation Maximum Maximum Designator Bandwidth Power Out EIRP [REDACTED] QAM 300MD1D 300 MHz 4W 54 dBW [REDACTED] BPSK 15M0G1D 15 MHz 4W 54 dBW [REDACTED] Continuous 100HK0N 100 Hz 4W 54 dBW Waveform 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 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 C - Interference Analysis: Google does not request confidential treatment of Exhibit C. Request for Confidential Treatment - Page 9

PUBLIC REDACTED VERSION Google Inc. File No. 1216-EX-ST-2015 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 STA. The Exhibits were filed with the Office of Engineering and Technology on November 16, 2015. For additional information, please see File No. 1216-EX-ST-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 STA tests/experiments may include trade secret information. The Commission 25 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. 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 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 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. 1216-EX-ST-2015 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.”) 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. Request for Confidential Treatment - Page 11

PUBLIC REDACTED VERSION Google Inc. File No. 1216-EX-ST-2015 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 12

PUBLIC REDACTED VERSION Google Inc. File No. 1216-EX-ST-2015 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) requests Special Temporary Authority (STA) to conduct demonstrations of experimental transmitters. The STA is sought for a period of 180 days beginning on December 16, 2015. Google outlines below its need for the requested STA and the reasons that the STA should be granted expeditiously. The STA is needed for development of [REDACTED]. Among other parameters, Google will evaluate [REDACTED]. The equipment used will include [REDACTED] at any given time. [REDACTED] radio will 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 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 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. Grant of this STA 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 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 proposed testing, informing them of the technical parameters of the proposed experimentation.2 No licensee objected.3 ● Satellite operations: Google’s proposed 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. 1 See Exhibit C (Frequency Coordination Report). 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 proposed operation. The request for an STA seeks authorization 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. 1216-EX-ST-2015 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 be pointing 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 proposed 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 km away from Google’s test location, ensuring that its receiver will be a minimum 0.41 degrees off-boresight from the Google transmitter. 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 operations and the Nevada border is 257 kilometers. Exhibit A - Page 2

PUBLIC REDACTED VERSION Google Inc. File No. 1216-EX-ST-2015 MEO and LEO satellites: Google’s proposed 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 proposed operation can be no closer than the Nevada border, roughly 257 kilometers away from Google’s proposed 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 proposed operating area, the MEO satellite’s receive antenna will 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. 1216-EX-ST-2015 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 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 and MEO satellites. ● Unlicensed operations: Google’s proposed 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 levels water basin levels, coal piles, or grain levels in a grain silo.17 The Commission’s rules require their transmit antennas to be oriented downward. Google’s proposed 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 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. 1216-EX-ST-2015 31.0-31.3 GHz band users (31 GHz band): ● Terrestrial licensees: Google’s 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 proposed operations.19 Notification letters were sent to each of the licensees operating within the vicinity of Google’s proposed testing, informing them of the technical parameters of the proposed experimentation.20 No licensee objected.21 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 proposed 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 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. The proposed experimental operations in the 27 and 31 GHz bands accordingly will be conducted without harmful interference to other authorized users. For these reasons, Google requests approval of this STA request. 19 See Exhibit C at 1. 20 Id. 21 Id. The notification letters discussed wideband operation. As noted above, Google seeks to conduct 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. See id. at 8. 22 Id. at 1. 23 Id. 24 Id. Exhibit A - Page 5

PUBLIC REDACTED VERSION Google Inc. File No. 1216-EX-ST-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 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. 1216-EX-ST-2015 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 [REDACTED] QAM 100MD1D 100 MHz 4W 48.3 dBW 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. 1216-EX-ST-2015 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 [REDACTED] QAM 300MD1D 300 MHz 4W 54 dBW [REDACTED] BPSK 15M0G1D 15 MHz 4W 54 dBW [REDACTED] Continuous 100HK0N 100 Hz 4W 54 dBW Waveform 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 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 3

Google Inc. File No. 1216-EX-ST-2015 EXHIBIT C – FREQUENCY COORDINATION REPORT

Experimental Operation Mountain View, CA Frequency Coordination Report – 28 & 31 GHz Prepared on Behalf of Google Inc. November 11, 2015

Google Inc. Experimental Operation in Mountain View, CA Frequency Coordination Report 28 & 31 GHz Table of Contents 1.   Summary of Results 1   2.   Coordination Data 2   3.   Common Carrier and LTTS Coordination 3   4.   LMDS Coordination 4   5.   Interference Analysis into Site-Based Licenses 5   6.   Addendum 8   7.   Contact Information 9  

Google Inc. Experimental Operation in Mountain View, CA Frequency Coordination Report 28 & 31 GHz 1. Summary of Results In support of experimental operations at 28 and 31 GHz1, Comsearch performed a frequency search considering all existing and proposed incumbent licenses that could potentially be impacted by the proposed experimental system. The search results identified area licenses in the common carrier fixed point-to-point microwave service, local television transmission service (LTTS) and local multipoint distribution service (LMDS). The search also identified site-based licenses in the microwave public safety and industrial/business pool services. Prior notification letters were sent to the area-based licensees and a summary of the notification data is provided in section two of this report. No objections were received from any of the incumbent licensees for the proposed frequency range of 27.9 – 28.0 GHz and 31.0 – 31.3 GHz. The Google experimental system will be operating on a secondary basis to incumbent operations, and a point of contact at Google has been provided in case any concerns arise during operation. In addition to the above coordination effort, an analysis was performed to assess the interference into all potentially affected site-based 31 GHz stations in the microwave public safety and industrial/business pool services. This analysis shows that no incumbent fixed operations should be affected by the proposed experimental operation. 1 The experimental system will operate in the 27.9 – 28.0 GHz and 31.0 – 31.3 GHz portions of the 28 GHz / 31 GHz / LMDS band. Comsearch 1 November 11, 2015

Google Inc. Experimental Operation in Mountain View, CA Frequency Coordination Report 28 & 31 GHz 2. Coordination Data This section presents the data pertinent to the experimental system in Mountain View, California. This data was circulated to all incumbent licensees in the shared 28 and 31 GHz frequency ranges. Administrative Information MTNVIEW1 CA MTNVIEW2 CA Status / License Basis Proposed / Non-Interference Proposed / Non-Interference Licensee Name GOOGLE INC. GOOGLE INC. Radio Service / Station Class XT - Experimental FX -- Fixed Site Information Latitude (NAD 83) 37 ° 20’ 41” N 37 ° 25’ 33” N Longitude (NAD 83) 122 ° 12’ 56” W 122 ° 4’ 22” W Ground Elevation (m/ft-AMSL) 497.3 / 1631.55 5.48 / 17.99 Path Azimuth (°) 54.508 234.595 Path Length (km / miles) 15.522 / 9.645 Antenna #1 Description 2-ft PARABOLIC 2-ft PARABOLIC Gain (dBi) 42.3 42.3 Beamwidth (°) 1.3 1.3 Centerline (m / ft - AGL) 1.8 / 6.0 19.8 / 65.0 Antenna #2 Description Directional Antenna 1-meter PARABOLIC Gain (dBi) 27.0 48.0 Beamwidth (°) 3.0 0.7 Centerline (m / ft - AGL) 1.8 / 6.0 19.8 / 65.0 Radio Information Emission Bandwidth 100 MHz 300 MHz Max EIRP (dBm) 78.3 84.0 Transmit Frequencies (MHz) 27,900-28,000 31,000-31,300 Comsearch 2 November 11, 2015

Google Inc. Experimental Operation in Mountain View, CA Frequency Coordination Report 28 & 31 GHz 3. Common Carrier and LTTS Coordination In accordance with FCC Rules and Regulations, the 28/31 GHz experimental system in Mountain View, California was prior-coordinated by Comsearch. Notification letters for this system were sent to the following common carrier fixed microwave licensees. These licensees are authorized to operate temporary fixed operations over a designated geographic area. Licensee Band Authorized Geographic Area AT&T 28 GHz, 31 GHz Continental US M.U.T. Licensing, LLC 28 GHz Statewide: California Verizon 28 GHz, 31 GHz Continental US A notification letter and datasheet for the experimental system were also sent to the following 28/31 GHz local television transmission licensees. These licensees are authorized to operate temporary fixed operations on a nationwide basis. Licensee Band Authorized Geographic Area AT&T California 31 GHz Continental US Information Super Station, LLC 28 GHz, 31 GHz Continental US NSM Surveillance 31 GHz Continental US Remote Facilities Consulting Services 31 GHz Nationwide No objections were received from the common carrier or local television transmission service incumbents. Comsearch 3 November 11, 2015

Google Inc. Experimental Operation in Mountain View, CA Frequency Coordination Report 28 & 31 GHz 4. LMDS Coordination A Notification letter was sent to the following 28/31 GHz LMDS licensees. The proposed experimental system will operate on frequencies that overlap Block A and Block B of the LMDS service. The total frequency allocation for each block of the LMDS spectrum appears below. Block A: 27.500-28.350 GHz 29.100-29.250 GHz 31.075-31.225 GHz Block B: 31.000-31.075 GHz 31.225-31.300 GHz Licensee Block Market Market Name Nextlink/XO B BTA4042 Sacramento, CA Straight Path Spectrum A BTA404 San Francisco-Oakland-San Jose, CA T-Mobile3 A BTA404 San Francisco-Oakland-San Jose, CA TelePacific Communications4 A BTA404 San Francisco-Oakland-San Jose, CA No objections were received from the LMDS incumbents for the proposed frequency range of 27.9 – 28.0 GHz and 31.0 – 31.3 GHz. 2 The proposed experimental system will be located inside BTA404. 3 T-Mobile has acquired LMDS spectrum from Straight Path in the San Francisco-Oakland-San Jose, CA BTA. 4 Straight Path is leasing spectrum to TelePacific Communications in the San Francisco-Oakland-San Jose, CA BTA. Comsearch 4 November 11, 2015

Google Inc. Experimental Operation in Mountain View, CA Frequency Coordination Report 28 & 31 GHz 5. Interference Analysis into Site-Based Licenses Comsearch performed interference calculations to determine the potential for interference from Google’s proposed 31 GHz experimental transmitter into site-licensed 31 GHz microwave public safety and industrial/business incumbent receivers. As input to the interference study, Comsearch retrieved data for potentially affected 31.0 - 31.3 GHz microwave public safety and industrial/business pool systems from the FCC ULS database. The systems selected for the analysis include 25 duplex fixed links (50 receivers) in ULS as well as point-radius licenses west of 110 degrees longitude. The distance limit imposed by this geographic selection is more than sufficient to ensure that harmful interference with systems to the east would not occur. Standard direct interference calculations were used to predict the interference level into each receiver in the selected data. For line-of-sight propagation, the interference level at the input to a 31 GHz band receiver is calculated as: 𝐼 = 𝐸𝐼𝑅𝑃(𝛼) − 𝐹𝑆𝐿 − 𝐴𝐵𝑆 + 𝐺! 𝛿 − 𝐿!"#$% Where: EIRP(α) = The EIRP of the experimental transmitter as a function of the off-axis angle α (dBm) α = The experimental transmitter antenna off-axis angle (deg) FSL = The free-space path loss from experimental transmitter to the receiver (dB) ABS = The oxygen and water vapor absorption loss for the path from experimental transmitter to receiver (dB) Gr = The receiver antenna gain (dBi) as a function of the off-axis angle δ δ = The receiver antenna off-axis angle (deg) Lfixed = The receiver common and receive-side fixed losses (dB) Absorption losses were calculated according to the methods of Annex 2 of Recommendation ITU-R P.676-10. The temperature, atmospheric pressure, and water vapor density parameters that are required as inputs to the P.676 algorithms were determined at each receiver location using the methods of Recommendation ITU-R P.835-5 and the associated ITU data banks. Specific attenuation values (dB/km) for oxygen and water vapor absorption were calculated for each 31 GHz band receiver in the data set based on the location and antenna height. The total absorption loss was calculated as the total (water vapor plus oxygen) specific attenuation for the receiver location times the length of the interference path. Consistent with FCC rules Section 101.105 and TIA TSB10-F, interference low enough to degrade the performance of a 31 GHz receiver by less than 1 dB is considered not to be harmful. The interference objective used in the analysis to satisfy this condition was determined as follows. Comsearch 5 November 11, 2015

Google Inc. Experimental Operation in Mountain View, CA Frequency Coordination Report 28 & 31 GHz The thermal noise power level in a receiver is: 𝑁 =   −114 + 10 ∗ 𝑙𝑜𝑔!" 𝐵𝑊 + 𝑁𝐹  (𝑑𝐵𝑚) Where: BW = The receiver bandwidth in MHz NF = The receiver noise figure (dB) The receiver bandwidth is estimated to be the same as the transmitter emission bandwidth indicated on the license. The receiver noise figure is estimated to be 3 dB. By power addition, interference at 6 dB below the receiver thermal noise power level would result in 1 dB degradation of the receiver performance. The interference objective for this condition is: 𝐼!"# = −114 + 10 ∗ 𝑙𝑜𝑔!" 𝐵𝑊 + 𝑁𝐹 − 6  (𝑑𝐵𝑚) Based on the assumption of a typical 3 dB noise figure, the interference objective for this analysis is: 𝐼!"# = −114 + 10 ∗ 𝑙𝑜𝑔!" 𝐵𝑊 − 3  (𝑑𝐵𝑚) For each receiver, the predicted interference level under the assumption of line-of-sight propagation was compared to the 1 dB threshold degradation (TD) objective to determine whether harmful interference could occur. Interference Analysis Results The interference level was calculated into each 31 GHz band receiver in the selected data and the analysis showed that the interference into all receivers meets the 1 dB TD objective. Thus Google’s proposed experimental operations are not predicted to cause interference to any of the incumbent site-based systems at 31 GHz. Example analysis results to illustrate the calculations are listed in Table 1 below. Comsearch 6 November 11, 2015

Google Inc. Experimental Operation in Mountain View, CA Frequency Coordination Report 28 & 31 GHz Distance   Receiver   from   Experimental   Experimental   Receiver   Antenna   Experimental   Transmitter   Transmitter   Free-­‐Space   Antenna   Gain  at   Margin  to   Receiver   Experimental   Transmitter   Antenna  Off-­‐ EIRP  at  Off-­‐ Loss  plus   Off-­‐Axis   Off-­‐Axis   1  dB  TD   Receiver   Transmitter   Receiver  Site   Frequency   Transmitter   to  Receiver   Axis  Angle   Axis  Angle   Absorption   Angle   Angle   Interference   Objective   Call  Sign   Call  Sign   Name   (GHz)   Site  Name   (km)   (deg)   (dBm)   Loss  (dB)   (deg)   (dBi)   Level  (dBm)   (dB)   5 WNTY579   WNTY579   SACRAMENTO   31.1625,   MTNVIEW2   121.9   150.3   26.0   176.7   N/A     38.2   -­‐112.5   2.5   31.0125   (Omni)   WNTV245   WNTV245   PALM  SPRINGS   31.0125,   MTNVIEW2   642.5   107.7   26.0   227.3   N/A     38.2   -­‐163.1   57.9   31.0375,   (Omni)   31.0625,   31.0875,   31.1625,   31.1875,   31.2125   WPJD930   WPJD930   PALM  SPRINGS   31.0125,   MTNVIEW2   643.0   107.7   26.0   227.4   N/A   38.2   -­‐163.2   57.9   31.0375,   (Omni)   31.0625,   31.0875,   31.1125,   31.1625,   31.1875,   31.2375,   31.2625   WPOP444   WPOP440   RUSSELL  RD   31075   MTNVIEW2   646.1   133.2   26.0   228.3   2.3   20.9   -­‐181.4   79.4   Table 1: Example Interference Analysis Results into 31 GHz Site-Based Licenses 5 Due to the distance from WNTY579 to the experimental transmitter (121.9 km), Comsearch sent a notification letter to the incumbent licensee. The incumbent responded that they have no objection to Google’s proposed system. All other callsigns were of sufficient distance to preclude coordination. Comsearch 7 November 11, 2015

Google Inc. Experimental Operation in Mountain View, CA Frequency Coordination Report 28 & 31 GHz 6. Addendum Google will potentially operate narrower emission bandwidths of 100 Hz (CW tone) and 15 MHz during radio setup of the fixed link. 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. This short duration operation at the narrower emission bandwidth is considered a minor revision, and no further analysis is required. Comsearch 8 November 11, 2015

Google Inc. Experimental Operation in Mountain View, CA Frequency Coordination Report 28 & 31 GHz 7. Contact Information For questions or information regarding the 28 and 31 GHz Frequency Coordination Report, please contact: Contact person: Joanna Lynch Title: Manager, Spectrum & Data Solutions Company: Comsearch Address: 19700 Janelia Farm Blvd., Ashburn, VA 20147 Telephone: 703-726-5711 Fax: 703-726-5599 Email: jlynch@comsearch.com Web site: www.comsearch.com Comsearch 9 November 11, 2015


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