Narrative Statement

0086-EX-ML-2012 Text Documents

Laufer Wind Group LLC

2012-05-16ELS_125807

                                                                     Laufer Wind Group LLC
                                                                  Application for Modification
                                                            of Experimental License WF2XVD
                                                               ELS File No. 0086-EX-ML-2012


                                NARRATIVE STATEMENT

        Pursuant to Section 5.3(d), (f)-(i) and Section 5.53 of the Commission’s rules, 47
C.F.R. §§ 5.3(d), (f)-(i), 5.53 (2010), the Laufer Wind Group LLC (“LWG”) hereby
respectfully requests a modification to its experimental license granted under call sign
WF2XVD and allowing it to operate in the 9380-9440 MHz band for the purpose of
conducting tests in connection with the development of a radar activated FAA obstruction
lighting system for wind farms. Specifically, LWG seeks to add a fourth location to its
license, so that it may conduct tests at the National Renewable Energy Laboratory – National
Wind Technology Center, in Louisville, Colorado.

       The following information is provided in support of this application:


A.     Purpose of Operation and Need for License:

        The Laufer Wind Group LLC is a wind energy consulting and engineering firm
specializing in new technology evaluations and development. LWG is developing the Aircraft
Detection Sight Solution (“ADSS”) to address the competing needs of the wind energy and
aviation industries. The ADSS is also designed to balance FAA lighting requirements with the
nuisance light concerns of local communities, one of the main impediments to wind energy
development in the United States.

B.     Location of Proposed Additional Operation:

        LWG proposes to conduct tests at an additional site deploying temporarily fixed base
station transmitters and associated antennas at the following location:

      Additional Location                             Coordinates (NAD83)
      Location No. 4:                                 39°54'35.2" North Latitude
      4 temporarily fixed base stations               105°13'33.7" West Longitude
      within a 3 km radius of coordinates near
      National Renewable Energy Laboratory,
      National Wind Technology Center
      Louisville, CO 80027




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C.     Technical Specifications:


       1.      Frequencies Desired

      LWG requests authorization to operate in the 9380-9440 MHz band. The tests will be
conducted using channels with bandwidths of 5 to 10 MHz within that band.


       2.      Effective Radiated Power

        All power levels will comply with the limits set forth in the FCC’s rules. The base
stations will operate with a duty cycle of .001 or less and at a peak effective radiated power
(“ERP”) level 12.3 kW or less. Moreover, LWG will limit the power, area of operation, and
transmitting times to the minimum necessary to evaluate the system.

       3.      Modulation and Emissions

       LWG proposes to operate without a modulated carrier. The primary emission
designators are 5M0P0N and 10M0P0N. Other emission modes may be utilized, but in no
event will the emissions extend beyond the frequency band requested.

       4.      Antenna Information

       The antennas will be located outdoors at temporarily fixed sites identified above. No
antennas will be mounted in a fashion that will require approval under FAA and FCC rules
and regulations.

       5.      Equipment To Be Used

       LWG proposes to conduct its tests at this additional site with up to four (4) temporarily
fixed base stations installed within a radius of approximately 3 km from the coordinates
39°54'35.2" North Latitude; 105°13'33.72" West Longitude near the National Renewable
Energy Laboratory – National Wind Technology Center, in Louisville, Colorado.

D.     Protection Against Interference:

         As noted above, LWG has requested authority to operate in the 9380-9440 MHz band.
It will coordinate with any licensees, as required by FCC rules, before commencing
operations.

        LWG also recognizes that the operation of any equipment under experimental
authority must not cause harmful interference to authorized facilities, including the facilities of
other experimental licensees in this band. Should interference occur, LWG will take
immediate steps to resolve the interference, including if necessary arranging for the
discontinuance of its operations. As noted above, LWG will also limit the power, area of
operation, and transmitting times to the minimum necessary to evaluate the system.


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E.       Restrictions on Operation:

      LWG is not seeking authority to perform a market study under this experimental license.
Moreover, no fees will be charged to entities using the equipment during this test. After the test is
completed, LWG will recall and recover all devices that do not comply with FCC regulations.

        In addition, LWG will advise entities using the equipment that permission to operate
has been granted under experimental authority issued to the Laufer Wind Group LLC, that
such operation is strictly temporary, and that the equipment may not cause harmful
interference. Entities will also be advised in accordance with Section 2.803 of the
Commission’s rules, 47 C.F.R. §2.803 (2010), that any unapproved devices have not been
authorized as required by the rules of the FCC and are not being offered for sale or lease, or
sold or leased, until authorization is obtained.

F.       Public Interest Statement:

        LWG submits that modification of its experimental license as requested is in the public
interest, convenience, and necessity. Grant of the application will allow LWG to expand its tests
and demonstration of prototype equipment to enhance the company’s efforts to design and
develop a solution to address the competing needs of the wind energy industry, the aviation
industry, and local communities.

G.       Contact Information:

      For questions about this application, please contact FCC Counsel to the Laufer Wind
Group LLC:

               David E. Hilliard
               Wiley Rein LLP
               1776 K Street, N.W.
               Washington, DC 20006
               Telephone: (202) 719-7058
               Facsimile: (202) 719-7207
               dhilliard@wileyrein.com

       In the unlikely event interference concerns should arise, please Mr. Laufer at the address
below. Mr. Laufer will also serve as the designated point-of-contact (stop buzzer) to terminate
transmissions if interference occurs:

               Eric Laufer, President
               Laufer Wind Group LLC
               270 Lafayette St., Suite 1402
               New York, NY 10012
               Telephone: (212) 792-3912
               Facsimile: (866) 381-5291
               elaufer@lauferwindgroup.com
13320556.4


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Document Created: 2019-04-27 08:40:21
Document Modified: 2019-04-27 08:40:21

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