Narrative Statement

0103-EX-ML-2016 Text Documents

Panasonic Avionics Corporation

2016-05-23ELS_177199

                           Panasonic Avionics Corporation
                         Modification of Call Sign WH2XCJ
                       T-PED Interference Ground Testing at:
                    Tulsa International Airport, Tulsa, Oklahoma
                      Dallas Love Field Airport, Dallas, Texas
                                    May 23, 2016

                           MODIFICATION NARRATIVE

    Panasonic Avionics Corporation (“Panasonic”) respectfully requests a modification of
its existing two-year experimental license (Call Sign WH2XCJ) to add two (2) additional
commercial airfield test locations to conduct ground testing in support of Panasonic’s
Global Communications Suite (“GCS”), featuring the “eXConnect” Ku-band aeronautical
mobile-satellite service (“AMSS”) that provides onboard connectivity for transmit
portable electronic devices (“T-PEDs”).    Authorization is sought to conduct limited
testing in Wi-Fi frequency bands only at Tulsa International Airport in Tulsa, Oklahoma
and Dallas Love Field Airport in Dallas, Texas commencing in August 1, 2016.
    I.      Background
    Panasonic was recently granted a modification of the subject two-year experimental
license to consolidate T-PED interference testing operations at over twenty commercial
airfield test locations under Call Sign WH2XCJ,1 which includes authority to operate in
the Wi-Fi frequency bands requested herein. This application now requests authority to
add two (2) additional airfield locations in Tulsa, Oklahoma (36° 12’ 19.8” N, 95° 52’
38.11” W) and Dallas, Texas (32° 50’ 54.81” N, 96° 51’ 50.84” W) to Call Sign
WH2XCJ, where Panasonic will test and gather electromagnetic interference (“EMI”)
data on T-PED RF transmissions in the aircraft cabin in Wi-Fi frequency bands.2 All
tests will be conducted inside closed cabins onboard aircraft parked at a remote location
at the airfields.
    II.     Testing Plan and Frequencies
    Attached is Table 1, which lists each frequency bands in which Panasonic is

1
 See Panasonic Avionics Corporation, File No. 0038-EX-ML-2016 (Call Sign
WH2XCJ).
2
 For a detailed description of the proposed T-PED testing, see Panasonic Avionics
Corporation, File No. 0117-EX-PL-2014 (Call Sign WH2XCJ), Attachment 1.

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authorized to conduct testing under Call Sign WH2XCJ. Also listed are the proposed
wireless standards and associated technical information for each test band: modulation
(pulse or continuous wave), maximum EIRP, maximum ERP, emission designator,
among others. A single 1 MHz test frequency in each uplink band, also identified, will
be used for testing. In this modification application, Panasonic only seeks to test in the
following Wi-Fi frequency bands at the at the Dallas, Texas and Tulsa, Oklahoma
locations:
      •   2400-2497 MHz: 97 MHz
      •   5150-5250 MHz: 100 MHz
      •   5250-5350 MHz: 100 MHz
      •   5725-5825 MHz: 100 MHz
Panasonic is not seeking any changes in the other technical aspects of proposed tests in
these bands as previously authorized and as described in the earlier experimental license
application3 or previous modification application.4
      Panasonic confirms that there are no wireless licensees within the applicable radius of
operations (1 kilometer) at either the Dallas, Texas or Tulsa, Oklahoma location that
requires coordination. In addition, Panasonic has not identified any affected Broadband
Radio Service (“BRS”)/Educational Broadband Service (“EBS”) or Fixed Microwave
(“FM”) licensee within the radius of operations and there is no potential for interference
to other lawfully operating spectrum users in the proposed Wi-Fi bands.
      Panasonic is currently in the process of coordinating with the local Society of
Broadcast Engineers (“SBE”) coordinators in Dallas, Texas and Tulsa, Oklahoma for its
proposed operations in the 2400-2497 MHz band and will update the Commission and its
application upon receiving feedback from each SBE coordinator. Finally, Panasonic has
received from the FAA non-governmental tracking numbers (“NGT#”) for both test


3
    Id.
4
 Supra footnote 1. Panasonics notes that the Commission’s Experimental Licensing
System (“ELS”) automatically generated the Form 442 for this experimental modification
application and included Panasonic’s existing authority across all T-PED test frequencies
and locations, in addition to the herein requested authority.



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locations for its proposed operations in the 5150-5250 MHz frequency band.5 The
Commission may grant the requested experimental license modification application
subject to the existing condition to coordinate with any potentially affected operations
prior to conducting T-PED testing in Wi-Fi frequencies at Tulsa International Airport in
Tulsa, Oklahoma or Dallas Love Field Airport in Dallas, Texas.
      As Panasonic has explained in its previous applications, its access to aircraft is
dependent upon the manufacturer, airline or other owner making the airplane available at
a time convenient for them. Panasonic has only a short window – in most cases only a
few days – once an airplane is available to conduct the testing before the airplane must be
returned to the owner. Testing and re-testing in the authorized frequencies will be
conducted at scheduled intervals during the periods that the airplanes are available within
the authorized testing period.
      III.   Expedited Processing and Public Interest
      Panasonic respectfully requests expedited processing of this application.         As
discussed, there is extensive Commission precedent to allow Panasonic to conduct the
proposed tests because Panasonic is currently authorized under the license for broader T-
PED frequency testing, including for the herein proposed Wi-Fi frequency bands. The
Commission has previously reviewed and approved identical test operations at similarly
situated airfield locations across the U.S. – including most recently at Charlotte Douglas
International Airport in Charlotte, North Carolina6 – and, being familiar with Panasonic’s
T-PED testing procedure, may expeditiously grant this application.
      Grant of the requested authority will serve the public interest by allowing Panasonic
to satisfy FAA certification requirements and to continue development of its innovative
eXConnect AMSS system, which enables in-flight voice and broadband Internet access to
passengers and crew.        In addition, Panasonic has demonstrated that its proposed
experimental operations raise no concern regarding potential interference to co-frequency
EBS, FM and BRS services, and any necessary coordination with other potentially

5
    Tulsa International Airport: NGT# 160188
    Dallas Love Field Airport: NGT# 160189
6
 See Panasonic Avionics Corporation, File No. 0038-EX-ML-2016 (Call Sign
WH2XCJ).

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affected users (through the SBE and FAA) will be completed prior to commencing T-
PED testing at the airport facility. Of course, Panasonic’s operations will be conducted
on an unprotected, non-interference basis and will otherwise comply with Part 5 of the
FCC Rules.
   IV.     Conclusion
   Based on the foregoing, Panasonic respectfully requests that the Commission grant
this application to modify its existing two-year experimental license, Call Sign WH2XCJ
to permit T-PED testing in the Wi-Fi bands identified above at Tulsa International
Airport in Tulsa, Oklahoma and Dallas Love Field Airport in Dallas, Texas, commencing
on August 1, 2016.




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Document Created: 0500-08-28 00:00:00
Document Modified: 0500-08-28 00:00:00

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