Narrative Statement

0274-EX-ST-2017 Text Documents

Motorola Solutions, Inc.

2017-03-17ELS_189232

                                                             Motorola Solutions, Inc.
                                                      Request for Part 5 Experimental
                                                        Special Temporary Authority
                                                       ELS File No. 0274-EX-ST-2017

                              NARRATIVE STATEMENT

       Pursuant to Section 5.3(e), (g) and (h) and Section 5.61 of the Commission’s
rules, 47 C.F.R. §§ 5.3(e), (g) and (h), 5.61 (2015), Motorola Solutions, Inc., hereby
respectfully requests special temporary authority (“STA”) 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 and related entities at its new
corporate office location in Chicago, Illinois.

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 tests and demonstrations of
prototype equipment at its offices located at 500 W. Monroe Street, Chicago, Illinois.
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.

B.    Location of Proposed Operation:

       As noted above, Motorola Solutions proposes to conduct tests and
demonstrations at its new office location in Chicago, Illinois. Equipment would include
temporary base stations and associated antennas, along-with a small number of
portable/mobile units, all operating in the vicinity of the office. The address and
approximate reference coordinates (in Datum: NAD83) of the temporary fixed base
stations are:


                    500 W. Monroe Street
                    Chicago, Illinois 60661

                    41º 52' 51" North Latitude
                    -087º 38' 24" West Longitude




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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 20 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 stations 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.

       4.     Antenna Information

       The antennas for the temporary fixed base stations will be located at 500 W.
Monroe Street in Chicago at a height not greater than 20 feet above the ground or a
building. The portable/mobile unit antennas will operate in and around the temporary
fixed site 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 up to four base
units and up to twenty mobile/portable units. The base stations and mobile/portable
units are prototype equipment. Motorola Solutions will limit the power, area of
operation, and transmitting times to the minimum necessary to provide an effective
demonstration.




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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. Motorola Solutions recognizes
that it must accept interference from any other users of these bands and that all
operations by Motorola Solutions will be on a secondary basis. Moreover, Motorola
Solutions has established a point of contact (“POC”) identified below with “kill switch”
authority and will send the POC’s contact information to FirstNet in connection with the
approval of the requested STA.

         Motorola Solutions also conducted a search of the Commission’s Universal
Licensing System (“ULS”) database and verified that the proposed demonstration
should not interfere with any primary operations in that spectrum. Moreover, 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. Furthermore, as noted above, the length of the tests and demonstrations will
be limited in duration.

        In summary, the analysis conducted by Motorola Solutions indicates the
proposed operation should not interference with any licensed operation. Should
interference occur, Motorola Solutions will take immediate steps to resolve the
interference, including if necessary arranging for the discontinuance of operation.

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.

       In addition, entities will be advised in accordance with Section 2.803 of the
Commission’s rules, 47 C.F.R. §2.803 (2015), that any unapproved devices which have
not been authorized as required by the FCC are not being offered for sale or lease, or
sold or leased, until authorization is obtained.




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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:

               Technical Contact and “Stop Buzzer/Kill Switch:”
                      Gregory J. Buchwald
                      DMTS Engineer
                      Motorola Solutions, Inc.
                      500 W Monroe St., 41st Floor
                      Chicago, IL 60661
                      Telephone: (815) 351 4020
                      Facsimile: (312) 559-5616
                      Email: Greg.Buchwald@motorolasolutions.com

               Motorola Solutions FCC 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

               FCC Legal Contact:
                      Kurt DeSoto
                      Wiley Rein LLP
                      1776 K Street, N.W.
                      Washington, DC 20006
                      Telephone: (202) 719-7235
                      Facsimile: (202) 719-7207
                      kdesoto@wileyrein.com


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Document Created: 2017-03-17 19:24:47
Document Modified: 2017-03-17 19:24:47

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