Narrative Statement

0124-EX-PL-2012 Text Documents

Panasonic Avionics Corporation

2012-03-07ELS_123774

Panasonic Avionics Corporation Application for 2-Year Experimental License NARRATIVE DESCRIPTION Panasonic Avionics Corporation (“Panasonic”) requests a two-year experimental license, commencing on or about April 15, 2012, to conduct ground testing in support of Panasonic’s Global Communications Suite (“GCS”) featuring the “eXConnect” Ku-band aeronautical mobile-satellite service (“AMSS”) system to provide broadband connectivity onboard aircraft in flight. It is requested that the license be granted to conduct the testing on location at five airports around the United States: the Melbourne International Airport, Melbourne, FL; the Griffiss International Airfield, Rome, NY; the San Francisco International Airport, San Francisco, CA; the Denver International Airport, Denver, CO; and the O’Hare International Airport, Chicago, IL. Background On November 2, 2010, the FCC granted a two-year experimental license (Call Sign WF2XLF), effective until November 1, 2012, to conduct two types of testing: (1) electromagnetic interference (“EMI”) ground testing of multiple, simulated transmit portable electronic devices (“T-PEDs”) RF transmissions in the aircraft cabin in multiple frequency bands: GSM, cellular, Wi-Fi and others; and (2) picocell system operations in the aircraft cabin for enabling GSM phone communications for passengers and crew. Call Sign WF2XLF authorizes testing onboard parked aircraft at four sites: (1) Southern California Logistics Airport, Victorville, CA; (2) Paine Field Airport, Everett, WA; (3) Piedmont-Triad International Airport, Greensboro, NC; and (4) TSTC Wace Airport, Waco, TX.1 Subsequent to the grant of Call Sign WF2XLF, Panasonic has sought and obtained a series of separate, but related experimental STAs at additional airfields: (1) Call Sign WE9XMG, granted August 1, 2010, to conduct T-PED testing in certain Wi-Fi bands at the Hartsfield-Jackson International Airport in Atlanta, GA; (2) Call Sign WE9XVM, granted April 18, 2011, to conduct T-PED and picocell testing at the Roswell Industrial Air Center, Roswell, NM; (3) Call Sign WF9XCS, granted September 9, 2011, to conduct T-PED interference testing in certain Wi- Fi bands at Paine Field Airport, Everett, WA (Call Sign WF9XCS); and (4) Call Sign WF9XGL, granted on December 1, 2011, to conduct T-PED interference testing in multiple frequencies at the Melbourne, FL International Airport. Currently pending is an application (File No. 0123- EX-ST-2012) for an experimental STA at the Griffiss International Airfield in Rome, NY, which proposes to use the same test frequencies as authorized for Melbourne, FL (Call Sign WF9XGL). 1 Prior to the application for and grant of Call Sign WF2XLF, in November 2009, the FCC granted an experimental STA for the same frequencies at these four sites (Call Sign WE9XDS). The application materials for WE9XDS include a detailed description of the proposed T-PED and picocell testing. For the Commission’s reference, a copy of Pansonic’s narrative statement accompanying the application for this earlier experimental STA is attached hereto as Attachment 1.

Need for a Two-Year License The development of the eXConnect AMSS system to provide inflight broadband connectivity requires extensive testing under very specific circumstances: It must be done onboard functional, service-ready commercial aircraft. These aircraft are constantly on the move for their primary purpose of commercial passenger and freight transportation. When they do become available for ground testing, it is usually for short periods and on short notice. In the past, as detailed in the background section above, Panasonic has requested authority for these tests through a series of applications for short-duration Special Temporary Authority (STA). However, the pace and unpredictability of aircraft availability makes such a piecemeal approach administratively and economically inefficient for all parties. Therefore, through this two-year license application, Panasonic intends to consolidate the licensing process and promote administrative efficiency by identifying a slate of test sites and test frequencies that represent the majority of likely test scenarios over the next two years. Request for Experimental License Panasonic is seeking the requested two-year license to conduct T-PED interference ground testing at five sites:2  Melbourne International Airport, Melbourne, FL (28° 06’ 10” N.; 80° 38’ 43” W.);  Griffiss International Airfield, Rome, NY (43° 14’ 01” N.; 75° 24’ 25” W.);  San Francisco International Airport, San Francisco, CA (37° 38’ 10” N.; 122° 23’ 57” W.);  Denver International Airport, Denver, CO (39° 50’ 57” N.; 104° 40’ 25” W.); and  O’Hare International Airport, Chicago, IL (42° 0’ 30” N.; 87° 55’ 22” W.), Panasonic will conduct T-PED interference testing in the identified frequencies (see below) using a signal generator to simulate the operation of multiple T-PEDs. The proposed testing will be conducted onboard parked aircraft, composed of various models of a Boeing 747-400. Authorization is sought commencing April 15, 2012. 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 2 Panasonic acknowledges that that FCC’s Rules provide that experimental STAs may be extended pursuant to the filing of an application for an experimental two-year license at least 15 days prior to the expiration of the experimental STA. FCC Rule 5.61(b) (47 C.F.R. § 5.61(b)). Panasonic also acknowledges that the current experimental STA for Melbourne, FL (Call Sign WF9XGL) does not expire until June 2012, and the application for the Rome, NY (File No. 0123-EX-ST-2012) site remains pending. However, in the interest of administrative efficiency, Panasonic requests that the instant two-year experimental license application also include these two sites. The proposed test frequencies are the same for all five requested sites.

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. Testing Plan and Frequencies Attachment 2 is the draft T-PED Susceptibility Test Frequency Plan (Testing Plan) developed by Panasonic’s contractor, Armstrong Aerospace, for the planned tests. As noted in the Testing Plan, the proposed tests will be performed in accordance with FAA and industry-developed guidelines for T-PED operation in airplanes: RTCA/DO-294C – Guidance on Allowing Transmitting Portable Electronic Devices (T-PEDs) on Aircraft.3 In addition, the testing will be conducted on a parked aircraft generally on a remote part of the tarmac and with access limited to authorized personnel. Table 1 below lists the proposed test frequency bands. 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. (The proposed test bands and associated technical information are nearly the same as previously authorized in the experimental STA for Melbourne, FL (Call Sign WF9XGL).) 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 attached copy of the earlier experimental STA application (Call Sign WE9XDS) (Attachment 1). Finally, Panasonic acknowledges and accepts that the Special Conditions previously attached to the Melbourne, FL experimental STA (Call Sign WF9XGL) would apply to any experimental STA granted for the proposed tests at the additional sites in Melbourne, Rome, San Francisco, Denver, and Chicago. Included as Attachment 3 is the “Stop Buzzer” contact for the proposed tests.4 * * * For the reasons described above, Panasonic respectfully requests the grant of a two-year experimental license for the five test sites listed above, commencing on or about April 15, 2012. 3 A copy of this document is available from RTCA: www.rtca.org. 4 Panasonic will update the “Stop Buzzer” contact as may necessary upon grant of the requested two-year experimental license and prior to the scheduled start of any tests.

Table 1 - T-PED EMI Test Frequencies / Transmit Power Requirements Wireless Frequency Frequency Test Modulation Test Target Target Target Emission Standard start of band end of band Frequency Waveform EIRP EIRP ERP (W) Code (MHz) (MHz) (MHz) (dBm) (W)  CDMA 2000 410 420 415 CW 2 42.0 15.8 13.7 N0N GSM 400 450.4 457.6 454 Pulse 1 45.0 31.7 29.5 P0N CDMA 2000 450 460 455 CW 2 42.0 15.8 13.7 N0N CDMA 2000 479 484 482 CW 2 42.0 15.8 13.7 N0N CDMA 2000 776 794 785 CW 2 42.0 15.8 13.7 N0N CDMA 2000 806 849 828 CW 2 42.0 15.8 13.7 N0N CDMAone 824 849 828 CW 2 42.0 15.8 13.7 N0N UMTS FDD 824 849 828 CW 2 36.0 15.8 13.7 N0N GSM 850 824 849 828 Pulse 1 45.0 31.7 29.5 P0N IS-136 824 849 828 Pulse 1 39.8 31.7 29.5 P0N UMTS TDD 824 849 828 Pulse 1 36.0 31.7 29.5 P0N CDMA 2000 870 925 898 CW 2 42.0 15.8 13.7 N0N GSM 900 876 915 913 Pulse 1 45.0 31.7 29.5 P0N Mobile Sat 1613.8 1626.5 1626 Pulse 1 42.0 15.8 13.7 P0N CDMA 2000 1710 1785 1748 CW 2 42.0 15.8 13.7 N0N DCS 1800 1710 1785 1748 Pulse 1 42.0 15.8 13.7 P0N CDMA 2000 1850 1910 1884 CW 2 42.0 15.8 13.7 N0N UMTS FDD 1850 1910 1884 CW 2 36.0 15.8 13.7 N0N CDMAone 1850 1910 1884 CW 2 42.0 15.8 13.7 N0N UMTS TDD 1850 1910 1884 Pulse 1 36.0 15.8 13.7 P0N PCS 1900 1850 1910 1884 Pulse 1 42.0 15.8 13.7 P0N IS-136 1850 1910 1884 Pulse 1 39.8 15.8 13.7 P0N UMTS TDD 1900 1920 1910 Pulse 1 36.0 4.0 1.8 P0N

Wireless Frequency Frequency Test Modulation Test Target Target Target Emission Standard start of band end of band Frequency Waveform EIRP EIRP ERP (W) Code (MHz) (MHz) (MHz) (dBm) (W)  CDMA 2000 1920 1980 1949 CW 2 42.0 15.8 13.7 N0N UMTS FDD 1920 1980 1949 CW 2 36.0 15.8 13.7 N0N UMTS TDD 2010 2025 2018 Pulse 1 36.0 4.0 1.8 P0N UMTS/3G/PCN 2110 2170 2140 CW 2 36.0 4.0 1.8 N0N 802.11b/g 2400 2497 2412 Pulse 1 37.0 5.0 2.9 P0N 802.11b/g 2437 Pulse 1 37.0 5.0 2.9 P0N 802.11b/g 2462 Pulse 1 37.0 5.0 2.9 P0N 802.11b/g FDD LTE 2500 2685 2595 Pulse/CW 1,2 42.0 15.8 13.7 P0N/N0N Wi-Max 3400 3600 3450 Pulse/CW 1,2 42.0 15.8 13.7 P0N/N0N 802.11a/n 5150 5250 5170 Pulse 1 37.0 5.0 2.9 P0N 802.11a/n 5250 5350 5300 Pulse 1 37.0 5.0 2.9 P0N 802.11a 5470 5725 5580 Pulse 1 37.0 5.0 2.9 P0N 802/11a/n 5725 5825 5825 Pulse 1 37.0 5.0 2.9 P0N


Document Created: 2012-03-07 18:33:21
Document Modified: 2012-03-07 18:33:21
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