Narrative Statement

0718-EX-CN-2017 Text Documents

Motorola Solutions, Inc.

2017-08-31ELS_197697

                                                                   Motorola Solutions, Inc.
                                                    Request for Special Temporary Authority
                                                                  File No. 0718-EX-CN-2017


                                NARRATIVE STATEMENT

      Pursuant to Section 5.3(e), (f) and (g) and Section 5.51 of the Federal
Communications Commission’s (“FCC”) rules, 47 C.F.R. §§ 5.3(e), (f) and (g), 5.51 (2016),
Motorola Solutions, Inc., respectfully requests an export only, station code “XE”
experimental license 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.

        Grant of this application would serve to replace the existing special temporary
authorization (“STA”) issued to Motorola Solutions for experimentation granted under File
No. 0275-EX-ST-2017, call sign WC9XQF. That STA allowed the company to collect
sufficient data to assess the performance and reliability characteristics of prototype
equipment and software to determine if additional research is needed and should be
scheduled. This filing seeks authority to continue the research and development.

       As provided under Section 5.61(c) of the Commission’s rules, 47 C.F.R. § 5.61(c)
(2016), this application is also intended to serve as a continuance or extension of the
above-referenced STA. Motorola Solutions understands, however, that such continuance
or extension applies only to the operations as authorized and as conditioned under the
STA. The extension is necessary to allow the company to continue its technical tests
pending Commission action on 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 test and demonstrate 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.




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                                                                    Motorola Solutions, Inc.
                                                     Request for Special Temporary Authority
                                                                   File No. 0718-EX-CN-2017


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.

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 the requested authority. 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.

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                                                                                       Motorola Solutions, Inc.
                                                                Request for Special Temporary Authority
                                                                              File No. 0718-EX-CN-2017



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.


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 authority
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.




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                                                                  Motorola Solutions, Inc.
                                                   Request for Special Temporary Authority
                                                                 File No. 0718-EX-CN-2017




G.    Public Interest:

       Motorola Solutions submits that issuance of the requested authority 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.

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




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Document Created: 2017-08-31 14:30:46
Document Modified: 2017-08-31 14:30:46

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