Amended Narrative Statement

0824-EX-PL-2014 Text Documents

Laufer Wind Group LLC

2015-06-18ELS_163813

Laufer Wind Group LLC
Application for Experimental Export (“XE”) License
ELS File No. 0824-EX-PL-2014

NARRATIVE STATEMENT
(Amended 6/18/2015)

Pursuant to Section 5.3(e) of the Commission’s rules, 47 C.F.R. §§ 5.3(e) (2013), the
Laufer Wind Group LLC (“LWG”) hereby respectfully requests a license with the radio
station code “XE” (i.e., for Experimental Export) so that it may operate on a limited, periodic
basis as described below on 1030 MHz for the purpose of evaluating the functionality of
equipment to be exported and operated outside the United States that will facilitate the use of
radar activated obstruction lighting systems with traffic collisions avoidance systems
(“TCAS”). Grant of this request would complement 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 headquartered in Bedford,
New Hampshire, and conducts research primarily at its Bedford offices and at a location near
Rocky Flats, Colorado. LWG is currently developing the Aircraft Detection Sight Solution
(“ADSS”) to address the competing needs of the wind energy and aviation industries. In
particular, the ADSS is designed to balance Federal Aviation Administration (“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 now seeks to evaluate the performance and compatibility of ADSS equipment it is
designing for use outside the United States with TCAS equipment typically found on aircraft.
Although, the ADSS relies on its primary radar to detect the presence of aircraft, the company 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.

Because LWG is a relatively small company with limited resources, it cannot practicably
and economically conduct such tests at locations outside the United States. Thus, the company
seeks FCC authority to conduct operate and evaluate equipment for export only at the company’s
U.S. locations.

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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

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. As noted below, the equipment will operate with a duty cycle of
.0002% 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 or
FCC rules and regulations.

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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), the company 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:

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. In
particular, LWG will provide advance notification to, and coordinate its activities with, FAA
personnel before commencing any operation. In that regard, the company has designated Eric
Laufer, whose contact information is provided below, to act as the “stop buzzer” for this
experimentation. Moreover, should interference occur, LWG will take immediate steps to
resolve such interference, including if necessary arranging for the discontinuance of its
operations.
Notwithstanding the precautions it will take, LWG does not expect harmful interference
to occur. First, 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 secondary
surveillance radar (“SSR”) systems would not receive replies that could interfere with TCAS or
SSR operations. Second, LWG would limit the scope and during of any operations.
Specifically, it proposes to operate only periodically at each requested location for only a few
minutes every 30 to 60 minutes during typical business hours, and such tests would occur fewer
than 10 times at each location during the term of its license. Thus, LWG’s total transmissions
from any location would be limited to less than approximately 175 minutes per year, or less than
0.0002% of any license term year. Nevertheless, LWG is amendable to the issuance of
experimental authority to limit its operations to only one of the requested locations or to re-locate
or otherwise modify its proposed operations should the Commission staff or interested parties
request such action. The company understands that the FCC may specify these limitations or
other conditions on its authorization.

E. Restrictions on Operation:

LWG is not seeking authority to perform a market study under this experimental license or
to assess any fees or charges in connection with the operation or use of the equipment during these
tests. As noted above, the company seeks to evaluate the performance and acceptability of ADSS
equipment it is designing for use outside the United States. Thus, none of the equipment is being
offered for sale or lease, or sold or leased, for use in the United States. Moreover, the participants
in these tests will be principals or employees of the company, and they will be advised that: (a) the
operations are being conducted under an experimental authority issued to Laufer Wind Group
LLC, (b) the company is responsible for the experimental activities, (c) all operations are being
conducted on a non-interference basis, and (d) after the test is completed, the company will
retrieve and recover all devices that do not comply with FCC regulations. LWG understands that
the FCC may specify these as well as other conditions on its authorization.
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Document Created: 2015-06-18 17:54:25
Document Modified: 2015-06-18 17:54:25

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