Narrative Statement

0616-EX-ST-2013 Text Documents

Motorola Solutions, Inc.

2013-06-28ELS_138613

                                                           Motorola Solutions, Inc.
                                                    Request for Part 5 Experimental
                                                      Special Temporary Authority
                                                     OET File No. 0616-EX-ST-2013



                             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 August 16 through August 23, 2013,
to operate in the 758-768/788-798 MHz band for the purpose of demonstrating prototype
broadband Long-Term Evolution (“LTE”) equipment to public safety agencies at the
annual Association of Public-Safety Communications Officials (“APCO”) International
Conference in Anaheim, California.

       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 and will forward it to the Commission upon
receipt.

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 International annual conference in Anaheim,
California. To accommodate its activities from set-up through disassembly of the
demonstration, Motorola Solutions respectfully requests that the FCC issue the
authorization to cover the period from August 16 through August 23, 2013.

        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
Anaheim Convention Center. 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 as
follows:

       Anaheim Convention Center
       800 W Katella Avenue
       Anaheim, CA 92802

       33º 48' 00" North Latitude
       117º 55' 16" West Longitude
       Datum: NAD83

C.     Technical Specifications:

       1.     Frequencies Desired

        Motorola Solutions requests authorization to operate in the band 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 the National
Telecommunications and Information Administration (“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. One base station 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
Anaheim Convention Center 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, it 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 band 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 the Commission’s 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 APCO conference should not interfere with any primary operations in that spectrum.

      Furthermore, as noted above, the length of the demonstration period is limited,
extending only from August 16 through August 23, 2013.

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.
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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:

      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
             Telephone: (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:

             Stu Overby
             Senior Director, Spectrum Strategy
             Motorola Solutions, Inc.
             1303 E. Algonquin Rd.
             Schaumburg, IL 60196
             Telephone: (847)-576-2952
             Stu.overby@motorolasolutions.com




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Document Created: 2013-06-28 12:03:59
Document Modified: 2013-06-28 12:03:59

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