Narrative Statement

0323-EX-ST-2014 Text Documents

Motorola Solutions, Inc.

2014-04-16ELS_148122

                                                            Motorola Solutions, Inc.
                                                     Request for Part 5 Experimental
                                                       Special Temporary Authority
                                                      ELS File No. 0323-EX-ST-2014


                                     EXHIBIT A


                             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 (2012), Motorola Solutions, Inc., hereby respectfully
requests special temporary authority (“STA”) from May 5, 2014 through May 9, 2014,
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 Emergency Preparedness Conference in Atlantic City, New Jersey.

       Motorola Solutions has requested a letter of consent from the First Responder
Network Authority (“FirstNet”) for the proposed operation, by way of the associated
cover letter submitted with this application.

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 Emergency Preparedness Conference in Atlantic City,
New Jersey. 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 May 5, 2014
through May 9, 2014.

        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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                                                                Motorola Solutions, Inc.
                                                         Request for Part 5 Experimental
                                                           Special Temporary Authority
                                                          ELS File No. 0323-EX-ST-2014


B.     Location of Proposed Operation:

       Motorola Solutions proposes to conduct its demonstrations in the vicinity of the
Tropicana Hotel in Atlantic City, New Jersey. Equipment would include two
temporary base stations and associated antennas, along-with a small number of
portable/mobile units, all operating in the vicinity of the conference site. The address
and approximate reference coordinates for location of the temporary fixed base
station deployment are:

              Tropicana Hotel
              2821 Boardwalk,
              Atlantic City, New Jersey 08401

              39° 21' 6.78" North Latitude
              -74° 26' 39.86” 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. A copy of this application and
request for FirstNet consent is being submitted concurrently with NTIA, which
manages the FirstNet consent process.

       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. Two base stations will be located at
the conference site 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.




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                                                             Motorola Solutions, Inc.
                                                      Request for Part 5 Experimental
                                                        Special Temporary Authority
                                                       ELS File No. 0323-EX-ST-2014


      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 antenna for the temporary fixed base station will be located at the
Tropicana Hotel in Atlantic City, New Jersey, 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. A copy of this application
and request for FirstNet consent to this request for STA is being submitted
concurrently with NTIA, which manages the FirstNet consent process.

       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 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 May 5, 2014 through May 9, 2014.


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                                                              Motorola Solutions, Inc.
                                                       Request for Part 5 Experimental
                                                         Special Temporary Authority
                                                        ELS File No. 0323-EX-ST-2014


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 (2012), 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.

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
             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 STA, please contact:

             Catherine Seidel
             Chief, North American and International
             Spectrum and Regulatory Policy
             Motorola Solutions, Inc.
             1455 Pennsylvania Ave NW, Suite 900
             Washington, DC 20004
             Telephone: (202) 371-6900; Cathy.Seidel@motorolasolutions.com
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Document Created: 2014-04-16 11:49:20
Document Modified: 2014-04-16 11:49:20

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