Narrative Statement

0603-EX-ST-2014 Text Documents

Motorola Solutions, Inc.

2014-07-03ELS_150965

                                                          Motorola Solutions, Inc.
                                                   Request for Part 5 Experimental
                                                     Special Temporary Authority
                                                    OET File No. 0603-EX-ST-2014



                             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 July 31, 2014 through August 6,
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 annual Association of Public-Safety Communication Officials
(“APCO”) Conference in New Orleans, Louisiana.

       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 APCO annual conference in New Orleans, LA. 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 July 31, 2014 through August 6,
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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B.     Location of Proposed Operation:

       Motorola Solutions proposes to conduct its demonstrations in the vicinity of the
New Orleans Ernest N. Morial Convention Center in New Orleans, LA. Equipment
would include a temporary base station and associated antenna, along-with a small
number of portable/mobile units, all operating in the vicinity of the convention center
site. The address and approximate reference coordinates for location of the
temporary fixed base station deployment are:

              New Orleans Ernest N. Morial Convention Center
              900 Convention Center Blvd.
              New Orleans, LA 70130

              29º 56' 35"   North Latitude
              90º 03' 49"   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 convention center 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.

       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.

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      4.     Antenna Information

       The antenna for the temporary fixed base station will be located at the New
Orleans Ernest N. Morial Convention Center in New Orleans, LA 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 IWCE 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 July 31, 2014 through August 6, 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

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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:

              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




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Document Created: 2014-07-03 10:40:38
Document Modified: 2014-07-03 10:40:38

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