Cover Letter from MSI to Julius Knapp

0449-EX-ST-2014 Text Documents

Motorola Solutions, Inc.

2014-06-12ELS_150226

Julius Knapp
Chief, Office of Engineering and Technology
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

RE:      Request for Experimental Special Temporary Authority
         ELS File No. 0449-EX-ST-2014

Dear Mr. Knapp,

       Motorola Solutions, Inc. seeks approval of its above-referenced application for
Experimental Special Temporary Authority (STA) to conduct limited operations in the 768-
769/798-799 MHz guard band spectrum at two locations in the New York City area during the
period of June 20 through August 31, 2014, for the purpose of testing and evaluating the
propagation characteristics and reliability of prototype devices and systems designed to support
land mobile communications.

         Motorola Solutions submits this cover letter as part of the above-referenced application
to affirm its understanding of the primary status of the First Responder Network Authority
(“FirstNet”) as the licensee in the 758-769/788-799 MHz spectrum, to seek FirstNet’s consent to
the proposed operation, and to provide a commitment to conduct operations under this
requested STA as described below:

         1) Operation will be confined to the immediate vicinity of the locations listed in the STA
            request, at 165 Cadman Plaza East, Brooklyn, NY and 49 35th Street, Long Island
            City, NY. The equipment will include two temporary base stations with associated
            antennas and a small number of portable/mobile units all operating within 25 km of
            the base stations.

         2) The demonstrations will be conducted in the 768-769/798-799 MHz guardbands.

         3) Operation will occur during the period June 20 through August 31, 2014, allowing
            time during that period for setup, testing, and teardown.

         4) Motorola Solutions has analyzed information from the FCC’s license databases and
            determined that the proposed operation would not interfere or create a significant
            potential for interference with any public safety operations in the 700 MHz band.

         5) The temporary experimental operation is not intended for the provision of regular
            public safety mission-critical communications or the delivery of live transmissions in
            duties to protect life, property or safety.




Motorola Solutions, Inc.
7031 Columbia Gateway Drive, Floor 3, Columbia, MD 21046


         6) Motorola Solutions recognizes that its experimental operations will be secondary and
            must not cause interference to any operations authorized on a primary basis in this
            spectrum licensed to FirstNet. Further, Motorola Solutions understands that any
            such primary operations have no obligation to mitigate any interference that might be
            present to the experimental operations.

         7) Motorola Solutions acknowledges that although FirstNet has not yet deployed in the
            geographic area covered by the application, if FirstNet or its assignees or lessees
            plan to deploy in the area during the term of this STA, Motorola Solutions may need
            to reduce the coverage or power of its experimental transmissions or cease
            operations entirely to prevent interference to such deployment. Motorola Solutions
            will also obtain any necessary concurrence letters from FirstNet or its assignees or
            lessees.

         8) Motorola Solutions will cooperate with other any other grantees of experimental STAs
            who are conducting tests in the same spectrum to minimize the potential for interference.

         9) Motorola Solutions recognizes that a separate concurrence from FirstNet will be
            required for renewal or extension of this STA, if needed beyond August 31, 2014.

         10) The undersigned person will serve as an overall point-of-contact for the proposed short-
             term testing.

       Motorola Solutions appreciates your consideration of this matter and requests that both the
FCC and FirstNet act as expeditiously as possible so the requested Experimental STA can be
granted in a timely manner to support the proposed testing beginning June 20, 2014.


Regards,




David W. Eierman
Principal Staff Engineer, Spectrum Strategy, Government Affairs
Motorola Solutions, Inc.
7031 Columbia Gateway Drive, Floor 3
Columbia, MD 21046

Voice: 410-712-6242
david.eierman@motorolasolutions.com




cc:      Lance Johnson, NTIA
         LJohnson@ntia.doc.gov




Motorola Solutions, Inc.
7031 Columbia Gateway Drive, Floor 3, Columbia, MD 21046



Document Created: 2014-06-12 14:06:00
Document Modified: 2014-06-12 14:06:00

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