Narrative Statement

0275-EX-ST-2017 Text Documents

Motorola Solutions, Inc.

2017-03-17ELS_189233

                                                                   Motorola Solutions, Inc.
                                                    Request for Special Temporary Authority
                                                                   File No. 0275-EX-ST-2017
                                                                                 Page 1 of 4




                                NARRATIVE STATEMENT

       Pursuant to Section 5.3(e), (f) and (g) and Section 5.61 of the Federal
Communications Commission’s (“FCC”) rules, 47 C.F.R. §§ 5.3(e), (f) and (g), 5.61 (2015),
Motorola Solutions, Inc., respectfully requests an export only, station code “XE”
experimental special temporary authority (“STA”) to support the testing and demonstration
of prototype equipment under development for use outside of the United States that will
operate in the 1350-1390 MHz and 1452-1492 MHz bands.

       In addition, Motorola Solutions respectfully requests expedited treatment of this
request so that it may commence tests on May 1, 2017. Justification for such action is
attached separately in the “Request for Expedited Treatment” accompanying this
application.

       The following information is provided in support of this request:

A.     Purpose of Operation:

       Motorola Solutions, Inc. is a leading manufacturer of mobile radio equipment and
systems and is continually engaged in the design and development of new and innovative
solutions. It is actively involved in particular with researching and developing wireless data
and voice capabilities incorporated into not only enterprise products, but also into non-
commercial communications systems.

       By this application, Motorola Solutions seeks to tests and demonstrates equipment
and solutions designed for use outside of the United States. It does not propose to test
equipment for domestic use under the requested authority. Moreover, Motorola Solutions
does not propose to market, sell, or lease prototype equipment under the requested
authority for operation within the United States. After the experimentation ceases,
Motorola Solutions will recall and recover all test devices.

B.     Proposed Locations:

       Motorola Solutions proposes to conduct tests and demonstrations at three locations
specified in the attached application at: (1) its offices located at 500 W. Monroe Street,
Chicago; (2) its facilities located in Schaumburg, IL; and (3) a remote, rural location in
Sawyer County, Wisconsin, south of Line A.


                                                                    Motorola Solutions, Inc.
                                                     Request for Special Temporary Authority
                                                                    File No. 0275-EX-ST-2017
                                                                                  Page 2 of 4

C.     Technical Specifications:

       Application Type/Classification:           XE (Experimental Export Only)

       Frequency Bands:                           1350-1390 MHz and 1452-1492 MHz

       Modulation:                                OFDM, unmodulated carrier for reference only

       Bandwidth / Emissions Designators:         5M00D1D, 5M00D7D, 5M00G1D, 5M00G2D,
                                                  5M00G7D, 5M00W7W, 10M0D1D, 10M0D7D,
                                                  10M0G1D, 10M0G2D, 10M0G7D, 10M0W7W,
                                                  20M0D1D, 20M0D7D, 20M0G1D, 20M0G2D,
                                                  20M0G7D, 20M0W7W

       Antenna Data / Temp. Fixed Stations:
             Power Output (TPO):                  4 Watts Peak
             ERP / EIRP:                          38.7 Watts / 63.4 Watts

       Antenna Data / Mobile Units:
             TPO:                                 4 Watts Peak
             ERP / EIRP:                          38.7 Watts / 63.4 Watts

       As the modulation bandwidth is scaleable, other emission modes may be utilized,
but in no event will the emissions extend beyond the frequency bands requested. All
power levels will comply with the limits set forth in the FCC’s rules, including those relating
to human exposure to radiation.

D.     Equipment To Be Used:

       Motorola Solutions proposes to deploy a limited number of units at the proposed
locations. It expects that it will be able to complete its experimentation and demonstration
with a maximum of 2 temporary fixed base stations at each location and 2 mobile units in
the vicinity of each temporary base station location. Thus, the maximum number of
temporarily fixed base stations will be 6 and the maximum number of mobiles will be 6 to
be deployed under this STA. Moreover, Motorola Solutions will limit the power, area of
operation, and transmitting times of these units to the minimum necessary to conduct its
tests and demonstrations.

E.     Antenna / Antenna Structure Heights:

The antennas to be installed under this authority will not extend more than six meters
above the ground or, if mounted on an existing building, will not extend more than six
meters above the building. If an antenna is mounted on an existing structure other than a
building, it will be installed in accordance with FAA and FCC rules and regulations.


                                                                                     Motorola Solutions, Inc.
                                                               Request for Special Temporary Authority
                                                                              File No. 0275-EX-ST-2017
                                                                                            Page 3 of 4


F.    Restrictions on Operation:

       As noted above, Motorola Solutions does not propose to market, sell, or lease
prototype equipment to end users or conduct a market study in conjunction with this test.
Moreover, no fees will be charged to entities using the equipment during this test. After
the experimentation ceases, Motorola Solutions will recall and recover all devices that do
not comply with FCC regulations. If any different treatment becomes necessary during the
course of its experimentation, Motorola Solutions will seek separate and additional
authority from the agency.

       Motorola Solutions also recognizes that all operations under the requested STA
must not cause harmful interference to authorized facilities. It does not anticipate that
such interference will occur, but should such interference occur, Motorola Solutions will
immediately take steps to resolve the interference, including if necessary discontinuing
operation.

       In addition, Motorola Solutions would advise entities using the equipment that
permission to operate the equipment has been granted under experimental authority
issued to Motorola Solutions, is strictly temporary and may be canceled at any time.
Specifically, Motorola Solutions proposes to label the equipment or associated equipment
information conspicuously 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 canceled at any time.

                     This device has not been authorized as required by the rules of the
                     Federal Communications Commission. This device is not, and may not
                     be, offered for sale or lease, or sold or leased, until authorization is
                     obtained. Thus, the user does not hold a property right in the device and
                     may be required to return the device.




G.    Public Interest:

      Motorola Solutions submits that issuance of an STA is in the public interest,
convenience, and necessity, as it will permit Motorola Solutions to develop innovative
equipment that will accommodate the communications needs of users.


                                                              Motorola Solutions, Inc.
                                               Request for Special Temporary Authority
                                                              File No. 0275-EX-ST-2017
                                                                            Page 4 of 4

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



Document Created: 2017-03-17 19:37:35
Document Modified: 2017-03-17 19:37:35

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