Narrative Statement

1109-EX-ST-2015 Text Documents

Motorola Solutions, Inc.

2015-10-07ELS_167969

                                                          Motorola Solutions, Inc.
                                                   Request for Part 5 Experimental
                                                     Special Temporary Authority
                                                    OET File No. 1109-EX-ST-2015

                             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 (2014), Motorola Solutions, Inc., hereby respectfully
requests a special temporary authority (“STA”) from October 24 to October 27, 2015,
to operate in the 758-768/788-798 MHz band for the purpose of demonstrating
prototype broadband Long-Term Evolution (“LTE”) devices at the International
Association Chiefs of Police (“IACP”) Annual Conference to be held in the McCormick
Place Convention Center, Chicago, Illinois.

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
performance and 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 IACP Annual Conference to be held October 24-27, 2015,
in the McCormick Place Convention Center in Chicago, Illinois. To accommodate set-
up requirements, Motorola Solutions respectfully requests that the FCC grant the STA
for the period October 24, 2011 through October 27, 2015.

       Grant of an STA will allow Motorola Solutions to demonstrate prototype
equipment and obtain additional feedback during the IACP Annual Convention so that
it may enhance the company’s efforts to design, develop and improve its equipment
to meet the communications needs of potential users.

B.    Location of Proposed Operation:

      Motorola Solutions proposes to conduct its demonstrations using a single fixed
base station transmitter antenna located inside the McCormick Place Convention
Center communicating with mobile/portable units operating within a radius of 150
meters from the fixed base station. The address and approximate coordinates of the
Convention Center are:

      McCormick Place Convention Center
      2301 South Lake Shore Drive
      Chicago, IL 60616
      41º 51' 07" North Latitude
      87º 36' 42" West Longitude
      Datum: NAD83
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C.    Technical Specifications:

      1.     Frequencies Desired

      Motorola Solutions requests authorization to operate in the band 758-768/788-
798 MHz. This band encompasses both the 758-763/788-793 MHz band known as
the upper 700 MHz D block, which has not yet been licensed for regular operation,
and the 763-768/793-798 MHz public safety block licensed on a nationwide basis to
the Public Safety Spectrum Trust (“PSST”).

      2.     Effective Radiated Power

       The mobile/portable units to be deployed are configured to operate at an
average power level of 50 mW effective radiated power (“ERP”) and a peak power
level of 160 mW ERP. The base station will be configured to operate at an average
power level of 630 mW ERP and a peak power level of less than 1 Watt ERP.

      Motorola Solutions will reduce the actual powers to the minimum power
needed for successful operation, based on set-up and testing at the McCormick Place
Convention Center site. All power levels will comply with the limits set forth in the
FCC’s rules, including those relating to human exposure to radiation.

      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 fixed base station transmitter antenna will be located inside the
McCormick Place Convention Center in Chicago, Illinois at a height no greater than
20 feet above the floor. The mobile/portable antennas will not, under any
circumstances, extend more than 6 meters above ground. 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 that it will be able to conduct its demonstration with
a single base unit and up to five mobile/portable units. The base station is a
prototype unit from Ericsson and the mobile/portable units are prototype equipment
from Motorola Solutions. Moreover, Motorola Solutions will limit the power, area of
operation, and transmitting times to the minimum necessary to evaluate the
equipment.



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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.

       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 IACP 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 October 24 through October 27, 2015.

      In summary, the analysis conducted by Motorola Solutions indicates the
proposed operation should not interference with any licensed operation.

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 recall and recover all
devices that do not comply with FCC regulations.

        Motorola Solutions also recognizes that the operation of any equipment under
experimental authority must not cause harmful interference to authorized facilities.
Should interference occur, Motorola Solutions will take immediate steps to resolve the
interference, including if necessary arranging for the discontinuance of operation.

       In addition, Motorola Solutions will advise entities using the equipment that
permission to operate has been granted under experimental authority issued to
Motorola Solutions, that such operation is strictly temporary, and that the equipment
may not cause harmful interference. Entities will also be advised in accordance with
Section 2.803 of the Commission’s rules, 47 C.F.R. §2.803 (2014), that any
unapproved devices have not been authorized as required by the rules of the FCC
and 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 permit Motorola
Solutions to develop innovative equipment that will accommodate the
communications needs of the public safety and homeland security 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:

               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: 2015-10-07 18:14:45
Document Modified: 2015-10-07 18:14:45

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