Narrative Statement

0824-EX-PL-2014 Text Documents

Laufer Wind Group LLC

2014-11-19ELS_155886

                                                                    Laufer Wind Group LLC
                                                         Application for Experimental License
                                                               ELS File No. 0824-EX-PL-2014

                                NARRATIVE STATEMENT

       Pursuant to Section 5.3(j) of the Commission’s rules, 47 C.F.R. §§ 5.3(j) (2013), the
Laufer Wind Group LLC (“LWG”) hereby respectfully requests an experimental license to
operate on 1030 MHz for the purpose of evaluating the compatibility of traffic collisions
avoidance systems (“TCAS”) with radar activated FAA obstruction lighting systems being
designed by LWG for wind farms. Grant of this request would supplement the research and
development LWG is conducting under its existing experimental authority issued under call
sign WF2XVD.
       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 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.

        LWG proposes to evaluate the compatibility of the ADSS with TCAS equipment
typically found on aircraft. Although, the ADSS relies on its primary radar to detect the presence
of aircraft, LWG is interested in examining the feasibility of supplementing the primary radar
with the information available from TCAS equipment. Specifically, LWG seeks to determine
whether the interrogation functionality of TCAS equipment may be incorporated into the ADSS
to collect range, bearing and other information about aircraft near a wind farm to enhance the
capability, performance and reliability of the ADSS system. LWG does not propose to operate
transponders as part of its experimentation, however; thus, the test equipment will not reply to
interrogations from aircraft or secondary surveillance radar (“SSR”) systems.

B.     Location of Proposed Operations:

       LWG proposes to deploy test equipment at the following two locations:
           Additional Location                              Coordinates (NAD83)
           Location No. 1:                                  40º 30' 42.6" North Latitude
           Up to 4 temporarily fixed base stations          71º 27' 35.6" West Longitude
           within a 3 km radius of
           10 Commerce Park N.
           Bedford, NH 03110
           Location No. 2:                                  39°54'35.2" North Latitude
           Up to 4 temporarily fixed base stations          105°13'33.7" West Longitude
           within a 3 km radius of
           National Renewable Energy Laboratory
           Rocky Flats, CO

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C.     Technical Specifications:

       1.      Frequencies Desired

       LWG requests authorization to operate on 1030 MHz. The tests will be conducted
using channels with bandwidths of 6 to 12 MHz within that band, as described in Section C.3
below.

       2.      Effective Radiated Power
        All operations will be conducted consistent with Part 5 and Subpart Q of Part 87 of the
FCC Rules, 47 C.F.R. Parts 5, 87 (2013). For example, all power levels will comply with the
limits set forth in those rules. The equipment will operate with a duty cycle of .001 or less and at
a peak effective radiated power (“ERP”) level 40 Watts 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

      The primary emission designators for the proposed operations are 6M80K2D and
12M0M1D. Other emission modes may be utilized, but in no event will the emissions extend
beyond the frequency bandwidth requested.

       4.      Antenna Information

       The antennas will be located outdoors at temporarily fixed locations identified in
Section B. 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 each site with up to four (4) temporarily fixed
devices installed within a radius of approximately 3 km from the coordinates specified in
Section B above. In accordance with Section 87.155 of the FCC’s rules, 47 C.F.R. § 80.145
(2013), LWG will use certified equipment in connection with its tests. For example, it
currently proposes to deploy devices certified by Avidyne Corporation under FCC I.D. No.
RZYTAS6XX-A, but LWG may use other authorized equipment as needed.

D.     Protection Against Interference:

      As noted above, LWG does not propose to operate transponders (e.g., transmitting on
1090 MHz) as part of these tests. Thus, aircraft with TCAS capabilities and ground based
SSR systems would not receive replies that could interfere with TCAS or SSR operations.

        Moreover, LWG 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. Accordingly, it will coordinate with any licensees,
as required by FCC rules, before commencing operations and will limit the power, area of
operation, and transmitting times to the minimum necessary to evaluate the system.
Moreover, should interference occur, LWG will take immediate steps to resolve such
interference, including if necessary arranging for the discontinuance of its operations.
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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 these tests. 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 (2013), 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
               Kurt E. DeSoto
               Wiley Rein LLP
               1776 K Street, N.W.
               Washington, DC 20006
               Telephone: (202) 719-7000
               Facsimile: (202) 719-7207
               dhilliard@wileyrein.com
               kdesoto@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
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Document Created: 2014-11-19 11:44:21
Document Modified: 2014-11-19 11:44:21

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