Narrative Statement

0199-EX-PL-2013 Text Documents

Motorola Solutions, Inc.

2013-03-22ELS_134798

                                                       Motorola Solutions, Inc.
                                                 Application on FCC Form 442
                                                  for an Experimental License
                                                 OET File No. 0199-EX-PL-2013



                           NARRATIVE STATEMENT

       Pursuant to Sections 5.51 and 5.53 of the Commission’s rules, 47 C.F.R.
§§ 5.51, 5.53 (2011), Motorola Solutions, Inc., hereby respectfully requests an
experimental license, for a period of two years, to operate in the 758-768/788-
798 MHz band for the purpose of conducting tests in connection with the
development of Long Term Evolution (LTE) broadband equipment for the 700
MHz band. The testing will be conducted from up to three sites at and near the
offices of Motorola Solutions in Schaumburg, Illinois and at Plantation, Florida.

       A letter of concurrence has been requested from the Illinois State Police,
which is authorized to operate certain narrowband vehicular repeaters under Part
90 of the FCC’s rules in the broadband public safety spectrum, pending further
Commission action on the relocation of its operations to conform to the FCC’s
revised 700 MHz bandplan.

      The following provides more details for this request.

A.    Purpose of Operation and Need for Experimental License:

        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 test and demonstrate the performance and functionality of prototype devices
designed to support the needs of the public safety and homeland security
community.

       Specifically, Motorola Solutions proposes to conduct testing of prototype
equipment at up to three sites in and around its offices located at 1303 East
Algonquin Road in Schaumburg, Illinois and at 8000 West Sunrise Boulevard in
Plantation, Florida. Grant of an experimental license will allow Motorola
Solutions to test and demonstrate prototype equipment to enhance the
company’s efforts to design and develop its equipment to meet the
communications needs of potential users.




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B.    Location of Proposed Operation:

       Motorola Solutions proposes to conduct the proposed tests using three
fixed base station transmitters and antennas located in and around its offices in
Schaumburg, Illinois. The addresses and approximate coordinates (in Datum:
NAD83) of the three sites are:

      1.     1303 East Algonquin Road
             Schaumburg, Illinois 60196
             42º 02' 39" North Latitude
             88º 02' 36" West Longitude

      2.     800 East Northwest Highway
             Palatine, Illinois 60038
             42º 06' 11" North Latitude
             88º 01' 24" West Longitude

      3.     8000 West Sunrise Boulevard
             Plantation, Florida
             26º 08' 52" North Latitude
             80º 15' 14" West Longitude


C.    Technical Specifications:

      1.     Frequencies Desired

       Motorola Solutions requests authorization to operate in the band 758-
768/788-798 MHz. This band encompasses both the 758-763/788-793 MHz band
known as the upper 700 MHz D block, which has not yet been licensed for
regular operation, and the 763-768/793-798 MHz public safety block.

      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. The mobile/portable
units to be deployed are configured to operate at a peak power level of 2.5 Watts
effective radiated power (ERP). The base station will be configured to operate at
a peak power level of 500 Watts ERP. Motorola Solutions will vary the actual
powers within the maximums noted above to test coverage results.

       In addition, Motorola Solutions will evaluate environmental considerations
to ensure compliance with Section 1.1306 of the FCC’s rules, 47 C.F.R. § 1.1306
(2011), and, in particular, the human exposure requirements set forth in FCC
OET Bulletin No. 65.

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      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.

      4.     Antenna Information

       The fixed base station transmitter antenna will be located outdoors at the
three sites specified above. The antenna elevation above ground level will not
exceed 100 feet. The mobile/portable antennas will be installed at a height not
greater than 6 meters above ground when used outdoors or at various locations
as needed for testing when used indoors. 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 that it will be able to conduct its demonstration
with not more than three base stations and up to twenty mobile/portable units at
each site. Moreover, Motorola Solutions will limit the power, area of operation,
and transmitting times to the minimum necessary to evaluate the equipment.

D.    Protection Against Causing Interference:

       As noted above, Motorola Solutions has requested authority to operate in
the 758-768/788-798 MHz band. This band encompasses both the 758-763/788-
793 MHz band known as the upper 700 MHz D block, which has not yet been
licensed for regular operation, and the 763-768/793-798 MHz public safety block.

        Motorola Solutions has analyzed information from the FCC’s license
databases and has determined that the proposed operation would not interfere
with, or create a significant potential for interference with, any public safety
operations in the 700 MHz band. The State of Illinois STARCOM21 system
utilizes a portion of the PSST spectrum block for operation of vehicular repeaters,
pursuant to a waiver that allows it to continue to operate under the former 700
MHz bandplan. Based on discussions with the State, however, the operations
proposed under this application are not expected to cause interference to the
State’s system because vehicular repeaters are seldom needed for coverage in
the areas where testing will be conducted. No reports of interference have been
received as a result of Motorola Solutions’ testing in the past with parameters
identical to those being requested in this application. Motorola Solutions is
coordinating with the Illinois State Police STARCOM21 System Administrator to

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obtain a letter of concurrence on extending the testing and will provide that
concurrence as soon as it is received.

      Motorola Solutions also searched the Commission TV database and
determined that the proposed operation would not interfere with any authorized
Low Power TV stations in the area.

E.     Restrictions on Operation:

       Motorola Solutions 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 test is completed, Motorola
Solutions will recall and recover all devices that do not comply with FCC
regulations.

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

       In addition, Motorola Solutions will advise entities testing the equipment
that permission to operate has been granted under experimental authority issued
to Motorola Solutions, 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
(2011), 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:

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




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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
               Voice: (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 license, please contact:

               Stu Overby
               Senior Director, Spectrum Strategy
               Motorola Solutions, Inc.
               1303 E. Algonquin Rd.
               Schaumburg, IL 60196
               Telephone: (847-421-2952
               Stu.overby@motorolasolutions.com



      The contact information for the designated project manager and “stop-
buzzer” contact for the operations to be conducted as proposed under the
experimental license is:

               Mark Solak
               Motorola Solutions, Inc.
               1303 E. Algonquin Rd.
               Schaumburg, IL 60196

               847-576-3081 office
               847-341-0223 cell
               CELX58@motorolasolutions.com




13570961.1




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Document Created: 2013-03-22 16:56:03
Document Modified: 2013-03-22 16:56:03

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