Narrative Statement

0091-EX-ST-2015 Text Documents

Motorola Solutions, Inc.

2015-01-29ELS_158316

                                                          Motorola Solutions, Inc.
                                                   Request for Part 5 Experimental
                                                     Special Temporary Authority
                                                    ELS File No. 0091-EX-ST-2015




                             NARRATIVE STATEMENT

       Pursuant to Section 5.3(d) and (f) and Section 5.61 of the Commission’s rules,
47 C.F.R. §§ 5.3(d), (f), 5.61 (2013), Motorola Solutions, Inc., hereby respectfully
requests special temporary authority (“STA”) from March 16, 2015 through March
20, 2015, to operate in the 758-768/788-798 MHz bands for the purpose of
demonstrating prototype broadband Long-Term Evolution (“LTE”) equipment to public
safety agencies at the annual International Wireless Communications Expo (“IWCE”)
Conference in Las Vegas, Nevada.


A.    Purpose of Operation and Need for STA:

       Motorola Solutions is a leading manufacturer of mobile radio equipment for the
public safety and homeland security community and is continually engaged in the
design and development of new and innovative communications equipment. The
experimental authority requested herein will allow the company to demonstrate the
functionality of prototype devices designed to support the needs of the public safety
and homeland security community.

       Specifically, Motorola Solutions proposes to conduct demonstrations of
prototype equipment at the IWCE annual conference in Las Vegas, NV. To
accommodate set-up requirements as well as to ensure all operations up to demo
tear-down are covered by Commission authorization, Motorola Solutions respectfully
requests that the FCC grant the STA for the period March 16, 2015 through March
20, 2015.

        Grant of an STA will allow Motorola Solutions to demonstrate prototype
equipment and obtain additional feedback so that it may enhance the company’s
efforts to design, develop and improve its equipment to meet the communications
needs of potential users.




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B.     Location of Proposed Operation:

       Motorola Solutions proposes to conduct its demonstrations in the vicinity of the
Las Vegas Convention Center in Las Vegas, NV. Equipment would include a
temporary base station and associated antenna, along-with a small number of
portable/mobile units, all operating in the vicinity of the convention center site. The
address and approximate reference coordinates for location of the temporary fixed
base station deployment are:

              Las Vegas Convention Center
              3150 Paradise Road
              Las Vegas, NV 89109

              36º 07' 53" North Latitude
              -115º 09' 06" West Longitude

              Datum: NAD83

C.     Technical Specifications:

       1.     Frequencies Desired

       Motorola Solutions requests authorization to operate in the bands 758-
768/788-798 MHz allocated for a nationwide public safety broadband network yet to
be built and licensed to FirstNet on a nationwide basis.

       2.     Effective Radiated Power

       All power levels will comply with the limits set forth in the FCC’s rules, including
those relating to human exposure to radiation.

       Up to 10 portable/mobile units will be deployed and configured to operate at a
maximum average power level of 250 mW effective radiated power (“ERP”) and a
maximum peak power level of 2.5 Watts ERP. The base station will be located at the
convention center and will be configured to operate at a maximum average power
level of 5 Watts ERP and a maximum peak power level of 50 Watts ERP. Motorola
Solutions will reduce the actual powers to the minimum power needed for successful
operation, based on set-up and testing at the demonstration site.

       3.     Modulation and Emissions

       Motorola Solutions proposes to operate using OFDM modulation. The primary
emission designators are 5M0G7D, 5M0W7W, 5M0G2D, 5M0D7D, 10M0G7D,
10M0W7W, 10M0G2D, and 10M0D7D. Other emission modes may be utilized, but
in no event will the emissions extend beyond the frequency bands requested.



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      4.     Antenna Information

        The antenna for the temporary fixed base station will be located at the Las
Vegas Convention Center in Las Vegas, NV at a height no greater than 20 feet above
the floor. The portable/mobile unit antennas in and around the demonstration site will
be located as required for a successful demonstration. No antennas will be mounted
in a fashion that will require approval under FAA and FCC rules and regulations.

      5.     Equipment To Be Used

        Motorola Solutions expects to conduct its demonstration with one base unit
and up to ten mobile/portable units. Moreover, Motorola Solutions will limit the power,
area of operation, and transmitting times to the minimum necessary to provide an
effective demonstration.


D.    Protection Against Causing Interference:

      As noted above, Motorola Solutions has requested authority to operate in the
758-768/788-798 MHz bands allocated for a nationwide public safety broadband
network and licensed to FirstNet on a nationwide basis.

       Under Commission rules, Low Power TV stations and auxiliary stations were
previously required to vacate the 700 MHz band, so no interference should occur to
broadcast facilities.

      Motorola Solutions also conducted a search of the Commission’s Universal
Licensing System (“ULS”) database and determined that the proposed demonstration at
the IWCE conference should not interfere with any primary operations in that spectrum.

      Furthermore, as noted above, the length of the demonstration period is short,
extending only from March 16, 2015 through March 20, 2015.

E.    Restrictions on Operation:

        Motorola Solutions is not seeking authority to perform a market study under
this STA. Moreover, no fees will be charged to entities using the equipment during
this test. After the test is completed, Motorola Solutions will disassemble the
demonstration facilities.

       Motorola Solutions also recognizes that the operation of any equipment under
experimental authority must not cause harmful interference to authorized facilities. In
the unlikely event interference occurs, Motorola Solutions will take immediate steps to
resolve the interference, including discontinuance of operation if necessary.

       Entities will be advised in accordance with Section 2.803 of the Commission’s
rules, 47 C.F.R. §2.803 (2013), that any unapproved devices which have not been


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authorized as required by the FCC are not being offered for sale or lease, or sold or
leased, until authorization is obtained.

F.    Public Interest:

       Motorola Solutions submits that issuance of an STA as requested is in the
public interest, convenience, and necessity. Grant of an STA will help Motorola
Solutions to develop innovative equipment that will accommodate the
communications needs of the public safety community.



G.    Contact Information:

      For questions about this application, please contact:

             Kurt DeSoto, Counsel to Motorola Solutions, Inc.
             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 during the period of
authorization for this STA, please contact:

             Chuck Powers
             Director, Engineering & Technology Policy
             Motorola Solutions, Inc.
             1455 Pennsylvania Ave NW, Suite 900
             Washington, DC 20004
             Telephone: (202) 371-6904
             Chuck.powers@motorolasolutions.com




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Document Created: 2015-01-29 15:47:32
Document Modified: 2015-01-29 15:47:32

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