Narrative Statement

0101-EX-ST-2013 Text Documents

Motorola Solutions, Inc.

2013-02-07ELS_133350

                                                                  Motorola Solutions, Inc.
                                                                   Experimental STA Request
                                                                           0101-EX-ST-2013
                                                                                 Page 1 of 5

                                  NARRATIVE STATEMENT

       By this application, Motorola Solutions, Inc. (“MSI”), respectfully requests special
temporary authority (“STA”) for a five month period beginning March 8, 2013, to test,
evaluate and demonstrate a prototype radio communications system designed to support
the communications requirements of government entities engaged in public safety and
homeland security activities. Specifically, MSI proposes to test a prototype system for a
state government so that it may demonstrate the functionality and capability of the system,
determine user acceptability, and obtain needed feedback to improve and enhance the
design of the system. The experimental activities will be conducted on a non-interference
basis using a limited number of non-Federal Government channels in the 150 MHz band
that have already been pre-coordinated for such operation.

       MSI does not seek authority to conduct market studies or provide communications
services under the requested experimental authority. Nor does it propose to market, sell,
or lease prototype equipment to end users in conjunction with this test. The participants in
the test will be advised that operation is being conducted under an experimental authority
issued to MSI and is temporary. In addition, no fees will be charged to entities using the
equipment during this test. After the experimentation ceases, MSI will recall and recover
all devices that do not comply with FCC regulations.

       The following information is provided in support of this request:

Proposed Operations / Locations and Frequencies:

        As noted above, MSI requests authority to test, evaluate and demonstrate a
prototype radio communications system designed to support the communications
requirements of government entities engaged in public safety and homeland security
activities. To obtain valid data and to present an accurate demonstration of real-world
operations, MSI must deploy a sufficient number of units during its test to simulate actual
usage. MSI expects that it will be able to complete its demonstration with approximately
75 mobile or portables units per transmitter site. Moreover, it will likely conduct tests at
only three to five transmitter sites at a time. It will also limit the power, area of operation,
and transmitting times to the minimum necessary to evaluate the system.

       The proposed locations of the base stations are identified in the table below. Mobile
operations will occur within 80 kilometers of these locations. MSI also seeks authority to
relocate these sites at the request of the user to demonstrate the system at other sites, but
in no event will the transmitters be located outside of the state of Tennessee or exceed the
total number of transmitters or mobiles/portables specified above.


                                                                 Motorola Solutions, Inc.
                                                                  Experimental STA Request
                                                                          0101-EX-ST-2013
                                                                                Page 2 of 5

         Operation under this experimental STA will be conducted on a non-interference
basis on a limited number of 12.5 kHz channel pairs on non-Federal Government
frequencies in the 150 MHz band allocated under Section 22.561 of the FCC’s rules to the
Paging and Radiotelephone Service. 47 C.F.R. § 22.561 (2011). Specifically, MSI seeks
to deploy approximately three, but not more than seven, channel pairs per site that have
been recommended by the state’s frequency coordinators or that are currently under
review by the FCC for assignment to the state agency (i.e., on selected channels
unassigned to other licensees near each location). Moreover, as mentioned above, MSI
will likely conduct tests at only three to five transmitter sites at any given time and will limit
the power, area of operation, and transmitting times to the minimum necessary to evaluate
the system. Nevertheless, to ensure it has flexibility to test the system more expansively, if
needed, MSI has requested authorization to conduct tests on any of the channels allocated
to this band so that it has the option to deploy alternative (non-Federal Government)
channels in the band to avoid interference as necessary.

Technical Specifications:

      Non-Federal Government                152.015 – 152.225 / 158.475 – 158.685 MHz;
      Frequencies Only:                     152.495 – 152.825 / 157.755 – 158.085 MHz
      Base Station Power:                   Varies By Location:
                                            From 50 W to 450 W Peak Effective Radiated
                                            Power (ERP);
                                            From 30 W to 65 W Transmitter Output Power
                                            (TPO) (all power levels will comply with the limits
                                            set forth in the FCC’s rules, including those
                                            relating to human exposure to radiation)
      Mobile Power:                         50 W Peak ERP / 45 W TPO
      Bandwidth:                            12.5 kHz per Channel
      Modulation:                           Frequency Modulation
      Emission Designators:                 8K30F1W, 9K80D7W

      Station Antenna:                      Omnidirectional up to 9 dBi Gain

      Mobile Antenna:                       Omnidirectional up to 3 dBi Gain

      MSI also requests a waiver of the station identification requirements set forth in
Section 5.115 of the Commission's rules, 47 C.F.R. § 5.115 (2011).




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                                                                            Motorola Solutions, Inc.
                                                                             Experimental STA Request
                                                                                     0101-EX-ST-2013
                                                                                           Page 3 of 5


Antenna Information:

       The antennas used for these tests will be installed and operated in accordance with
all FAA and FCC rules and regulations.


Restrictions on Operation / Interference Protection:

       MSI recognizes that experimental operations must not cause harmful interference to
authorized facilities. As stated above, operation under this experimental STA will occur
only on a limited number of 12.5 kHz channel pairs on non-Federal Government channels
allocated under the FCC’s rules and that have pre-coordinated or applied for such use.
MSI will also coordinate with existing licensees, as necessary, but has selected and pre-
coordinated channels that are not assigned in the test area or that are sufficiently distant
so as not to pose interference concerns. Should interference occur, however, MSI will
take immediate steps to resolve the interference, including if necessary arranging for the
discontinuance of operation.

         In addition, MSI will advise entities participating in the test that permission to
operate has been granted under experimental authority issued to MSI, that such operation
is strictly temporary, and that the operation may not cause harmful interference. To that
end, MSI proposes to label prototype equipment or associated written information as
follows:


                                          FCC STATEMENT
               Permission to operate this device has been granted under experimental authority
               issued by the Federal Communications Commission to Motorola Solutions, Inc.,
               is strictly temporary and may be cancelled at any time. Operation is subject to
               the condition that it not cause harmful interference. This device is not, and may
               not be, offered for sale or sold until the approval of the FCC has been obtained.
               Thus, the user does not hold a property right in the device and may be required
               to return the device.




Public Interest Statement:

      MSI submits that issuance of expedited special temporary authority as requested is in
the public interest, convenience, and necessity. Grant of such authority will permit MSI to
design and develop an innovative system that will accommodate the public safety and
homeland security communications needs of users.




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                                                     Motorola Solutions, Inc.
                                                      Experimental STA Request
                                                              0101-EX-ST-2013
                                                                    Page 4 of 5

Contact Information:

      MSI Contact:                               Legal Contact:

      Chris Mitchell                             Kurt DeSoto, Esq.
      Principal Staff Systems Engineer           Wiley Rein LLP
      Motorola Solutions, Inc.                   1776 K Street, N.W.
      341 Cools Spring Blvd.                     Washington, DC 20006
      Franklin, TN 37067.                        Office: (202) 719-7235
      Office: (517) 896-2790                     Facsimile: (202) 719-7049
      chris.mitchell@motorolasolutions.com       kdesoto@wileyrein.com




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                                                                         Motorola Solutions, Inc.
                                                                         Experimental STA Request
                                                                                 0101-EX-ST-2013
                                                                                       Page 5 of 5


                                             ATTACHMENT

Experimental Test Locations:


             Site Name                       Address                       Latitude    Longitude

      Jasper             Lower Fire Tower Road, Jasper (Marion), TN      35-09-30 N   85-39-21 W


      Franklin County    1170 Iron Gap Road, Belvidere (Franklin) , TN   35-05-38 N   86-07-56 W
      911

      Hinch Mountain     Radar Tower Road, Crossville (Cumberland), TN   35-46-49 N   84-58-42 W


      Braden Mountain    Highway 63, Pioneer (Campbell), TN              36-26-29 N   84-20-36 W


      Chuck Swan         Main Forest Road, Sharps Chapel (Union), TN     36-22-20 N   83-53-35 W


      Tennessee          At temporary fixed locations in the State of    35-57-18 N   83-55-02 W
                         Tennessee (within 250 km of the coordinates
                         listed, near TN)


13550350.1




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Document Created: 2013-02-07 17:21:18
Document Modified: 2013-02-07 17:21:18

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