Narrative Purpose of STA and Frequency Coordination

0683-EX-ST-2019 Text Documents

Robert Bosch LLC

2019-04-16ELS_227686

Robert Bosch LLC
Request for Grant of Special Temporary Authority
File No. 0683- EX-ST-2019
Narrative Exhibit Describing Operation


Please note that this application for STA is similar, other than the specified locations of
operation, to prior applications for Special Temporary Authority (See File No. 1893-EX-
ST-2018 that was granted (Call Sign WN9XPI) by the Commission for a single location in
Novi, Michigan; 2050-EX-ST-2018 for testing and development of identical equipment at
Columbus, Indiana (Call Sign WN9XUD); 2061-EX-ST-2018 for testing and development
of identical equipment at Novi, Michigan and Columbus, Indiana (Call Sign WN9XUE)
and 0250-EX-ST-2019 for a single location in Oregon (Call Sign WO9XBP).

This application, filed by Robert Bosch LLC, an international manufacturer of tools, automotive
equipment, and industrial and consumer products, requests special temporary authority during a
six-month period beginning as soon as possible and ending six months later, to permit
development and testing, on a nationwide basis, a telematics unit which supports connectivity
using commercial mobile networks in the area. The product is intended to address the challenges
of connectivity associated with current transportation and management of vehicles (including
commercial vehicles, agricultural and industrial vehicles, passenger cars and other mobility
applications). The applications of this product will include vehicle management, geofencing,
fleet management, remote diagnostics, theft protection, alerts and preventive maintenance.
Communications will be commercially provided through AT&T or another commercial service
provider for this series of experiments using SIM cards from the local commercial mobile service
provider. Bosch will not be using spectrum in the cellular bands that is allocated to any
commercial service provider other than through a commercial service provider (AT&T), so no
interference on those allocations can arise from the use of this device. Specific frequencies will
be determined by the network operator only. There will be no RF signals transmitted without the
SIM card from the commercial service provider. The product uses network data services
provided by the commercial service provider to transfer information to the server. This system is
capable of using 2G, 3G and LTE depending on the SIM provided by the commercial mobile
services provider.

Wi-Fi and Bluetooth capabilities are incorporated in the product, but those will be used only for
in-vehicle applications where the product acts as a local hotspot. Only Part 15 bands are
specified for these components of the product.

The purpose of this STA is to develop applications for this telematics device by incorporating it
in various vehicles. Test opportunities have arisen at the locations of three vehicle manufacturers
to incorporate the telematics device in the vehicles at a given location. The test opportunities are
short term. Bosch has, as is seen from the above list of specific location STAs, been very active
in the development and testing of this product by incorporating it in particular vehicles, and this
testing will continue for the next six months during this period. There has been no reported
interference at any of the prior tests conducted pursuant to the above-referenced STAs. All of the
experimental devices will be retrieved by Robert Bosch LLC from the three locations


upon completion of the operation.

The bands sought herein are as follows:
3G Band 2: 1850 to 1910 MHz
3G Band 5: 824 to 849 MHz& 869 to 894 MHz
LTE Band 2: 1850 to 1910 MHz& 1930 to 1990 MHz
LTE Band 4: 1710 to 1755 MHz & 2110 to 2155 MHz
LTE Band 5 : 824 to 849MHz
LTE Band 7: 2500 to 2570 MHz & 2620 to 2690 MHz
LTE Band 12: 699 to 716
LTE Band 17: 704 to 716
WiFi 2GHz: 2400 – 2483.5 MHz
WiFi 5GHz: 5180 – 5320 MHz & 5500 - 5825 MHz
BLE:         2402 – 2483.5 MHz

There will also be a GPS receiver included in the product.

Neither the composite product nor its components is certified in the United States as of yet.
Hence the need for the STA for this pre-production testing and development of various vehicular
applications for the device.

The Stop Buzzer contact in the United States for Bosch for this test series at all locations will be
Sunitha Kailasam of Bosch, whose mobile phone number is 248-207-0699 and whose e-mail is
sunitha.kailasam@us.bosch.com. Should any interference arise or be complained of by any
entity during the event, all operation will cease until the interference complaint is resolved to the
satisfaction of the complainant.

Should any question arise concerning this application, kindly notify undersigned counsel.

Christopher D. Imlay
Booth, Freret & Imlay, LLC
14356 Cape May Road
Silver Spring, MD 20904-6011
(301) 384-5525 telephone
(301) 384-6384 facsimile
chris@imlaylaw.com
chris.imlay@gmail.com



Document Created: 2019-04-16 14:34:18
Document Modified: 2019-04-16 14:34:18

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