Narrative Statement

0141-EX-CN-2017 Text Documents

Laufer Wind Group LLC

2017-03-08ELS_188719

                                                                     Laufer Wind Group LLC
                                                    Application for FCC Experimental License
                                                               ELS File No. 0141-EX-CN-2017


                                NARRATIVE STATEMENT

        Pursuant to Section 5.3(e)-(h) and Section 5.53 of the Federal Communications
Commission’s (“FCC”) rules, 47 C.F.R. §§ 5.3(e)-(h), 5.53 (2015), the Laufer Wind Group
LLC (“LWG”) hereby respectfully requests an experimental license to replace its previous
license granted under call sign WF2XVD so that it may continue tests in connection with its
development of a radar activated FAA obstruction lighting system for wind farms that operate
in the 9380-9440 MHz band.

       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. It has developed 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.     Locations of Proposed Operation:

       By this application, LWG proposes to conduct tests at a subset of the same locations
that were authorized under its previous license issued under call sign WF2XVD. In fact, the
technical specifications of the operations proposed in this application are also identical to
those authorized under its previous license.

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.



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       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 in the
accompanying application on FCC Form 442. 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 three (3)
temporarily fixed base stations installed at each location.

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.


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 tests
are 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 (2015), 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.




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F.       Public Interest Statement:

        LWG submits that grant of an experimental license as requested is in the public interest,
convenience, and necessity. Such action 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 its FCC counsel.

                Kurt E. DeSoto
                Wiley Rein LLP
                1776 K Street, N.W.
                Washington, DC 20006
                Telephone: (202) 719-7235
                Facsimile: (202) 719-7207
                kdesoto@wileyrein.com

         In the unlikely event interference concerns should arise, please contact Mr. Laufer 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

13555717.1




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Document Created: 2017-03-08 13:28:51
Document Modified: 2017-03-08 13:28:51

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