Narrative Statement

0093-EX-CM-2017 Text Documents

Kamstrup A/S

2017-04-28ELS_191198

                       Narrative Statement of the Proposed Modified Experimentation

         Kamstrup requests to modify its experimental license to operate prototype telemetry
equipment that it is developing for U.S. utilities. Specifically, Kamstrup requests to operate on the 902-
928 MHz band. This band will be in addition to its already existing operations on 450-470 MHz. As
previously reported in its last application, this request is for a conventional experimental authority
pursuant to Section 5.54(a) of the Commission’s Rules for a product development trial, or a market
trial.1 Experimental authorization is necessary for Kamstrup to operate the equipment as part of trials
with utilities to demonstrate the capabilities of the telemetry equipment. The trials will take place with
various utilities and accordingly, blanket experimental authority is requested to operate in various
locations in the United States. Blanket authority will provide flexibility that is needed to conduct these
trials with the utilities that will be participating in the trials. While Kamstrup requests blanket authority
the trials would limited in scope, and Kamstrup has limited its request to authorize the operation of 50
telemetry devices under the trial. The devices would be used for temporary fixed operations; would not
be left behind with the utility in the area of the trial; and would always be accompanied by a Kamstrup
representative operating the transmitter. The specific objective to be accomplished by the trial is to
measure the performance of the equipment in the field and to demonstrate its capability to meet utility
requirements for functionality, reliability, safety and security. The addition of the 902-928 MHz
frequencies will supplement the existing authority to operate on licensed spectrum that is allocated for
FCC Part 90 private land mobile radio operations to provide greater coverage and reliability for utility
telemetry applications. In addition, the output power of the base stations and remote meters will
comply with the FCC’s Part 90 rules.

        For all of these reasons, Kamstrup respectfully requests blanket experimental authority to
operate prototype telemetry equipment for use in trials with utilities to demonstrate the performance
of the equipment as part of a product development and market trial.




1
 See 47 C.F.R. §5.54 (stating that a conventional experimental radio license “is issued for a specific research or
experimentation project (or a series of closely-related research or experimentation projects), a product
development trial, or a market trial.”)



Document Created: 2017-04-28 06:53:51
Document Modified: 2017-04-28 06:53:51

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