Narrative Statement

0259-EX-ST-2007 Text Documents

Transcore

2007-05-09ELS_81109

                                                                                    Transcore, Inc.
                                                                                    FCC Form 442
                                                                                   Request for STA
                                                                                  0054-EX-ST-2007
                                                                             And resubmitted under
                                                                                  0259-EX-ST-2007

                               EXHIBIT TO STA APPLICATION

         By this application, Transcore, (“TC IP Ltd.”), respectfully requests special temporary
authority (“STA”), beginning May 19, 2007, and continuing intermittently through June 18, 2007,
to test a non-multilateration toll tag reader system under development for export and use in certain
countries in the Middle East. The system will not be marketed for use in the United States.

        The system and application is very similar to one in which the Commission recently granted
an STA, as described in File No. 0192-EX-ST-2006. That application, which also related to system
testing prior to export, involved a railroad car tag reading application in India.

       The system, which is being developed and manufactured in Albuquerque, New Mexico, will
upon successful development be exported to operate in the 865 - 875 MHz band. The system will
separately transmit a carrier signal and a modulated signal to illuminate and write data to tags using
modulated backscatter techniques. Transcore submits this Application for Special Temporary
Authority, including the information in this Exhibit, in support of this request.

Purpose of Operation:

        Transcore proposes to test the tag reader system using an overhead gantry in a parking lot,
which is intended to simulate its deployment on a toll booth island. The tag will be mounted on a
vehicle that will pass underneath the gantry. The reader will transmit a carrier to illuminate the tag
as well as a modulated signal to write data to the tag. The signal that the tag reflects back to the
reader will be approximately 40 dB below the power transmitted toward the tag by the reader. The
tag is passive in the sense that it lacks a battery or other independent power source; it simply
imposes modulation on the reflected carrier, but does not generate an intentionally radiated signal.

       The reader is a special export version of the Transcore Encompass™ 5 or Transcore
Encompass™ 6 Multi-Protocol reader. The antennas that Transcore will test are an Andrew
antenna model DB872G45A-XY, and a modified version of the Transcore AA3152 Universal Toll
Antenna, with its operational frequencies shifted to operate in the 865 - 875 MHz band. The
technology being employed has been used for years in the United States in the non-multilateration
sub-bands of the Location and Monitoring Service operating in the 902 - 928 MHz band. As such,
much of the testing has been carried out based on data gathered from operation in the 902 -
 928 MHz band. However, Transcore needs to conduct final design verification using signals
emitted in the spectrum in which the system will operate overseas.

        Transcore respectfully requests agency action so that it may begin experimentation on April
20. It cannot conduct the tests any later. Transcore scheduled the tests for this period to meet user
requirements, including product delivery requirements.


                                                    -2-

Proposed Testing Locations:

       Transcore proposes to conduct the testing on one of two property sites near its engineering
and production facilities in Albuquerque, NM. No more than three tag readers operating
simultaneously will be set up within 1.2 kilometers of the following location.

                              Albuquerque, NM
                              North Latitude 35 deg 11’ 29”
                              West Longitude 106 deg 35’ 35”
                              Datum: NAD83


Technical Specifications:

               Frequency (frequency stability will be      865-875 MHz
               maintained within ± 2.5 PPM)
               Station Power                               43 dBm EIRP
               (power levels will comply with FCC limits
               relating to human exposure to radiation)
               Bandwidth                                   0.100 kHz maximum for the
                                                           carrier signal;
                                                           515 kHz for the modulated
                                                           signal
               Modulation                                  The carrier signal has no
                                                           modulation;
                                                           The modulated signal will
                                                           carry Manchester encoded
                                                           data, with a 35 dB depth of
                                                           modulation
               Emission                                    OK10N0N for the carrier
               Designators                                 signal;
                                                           515KL1D for the modulated
                                                           signal
               Station Antennas                            Directional up to 14 dBi Gain
                                                           (Additional information is
                                                           provided below)

       Transcore requests a waiver of the station identification requirements set forth in Section
5.115 of the Commission’s rules, 47 C.F.R. § 5.115 (2006).

Interference Protection:

        For purposes of the experimental activities conducted under the authority requested in this
application, Transcore proposes to place the carrier and modulated signals and the orientation of
antennas (described further below) so as to avoid causing interference to any licensee. Transcore
recognizes that the band is used for public safety operations, cellular services, and trunked SMR
operations. As such Transcore would coordinate with these licensees and take steps to reduce the
likelihood of any harmful interference. All operation will be under the control of Transcore
personnel. In the event that interference is experienced, the Transcore contact named on page 4
below will have the testing shut down immediately.


                                                        -3-

Antenna Information:

       Transcore will be testing two antennas – an Andrew antenna, and a modified version of the
AA3152 Universal Toll Antenna (“UTA”). The principal plane radiation patterns for the two
antennas are provided on page 5 of this Exhibit. The antenna gain for both antennas is
approximately 13 - 14 dB. Transcore will control the RF power fed into the antenna to ensure that
the maximum EIRP does not exceed 43 dBm.

       The antennas will be no higher than six (6) meters above the ground and will be affixed to a
gantry. As such, no FAA coordination is required.

         Horizon plots showing that antenna gain on the horizon also are provided for both antennas
at page 6. These plots show that the energy emitted toward the horizon is substantially diminished
(i.e., approximately 0 and -3 dBi gain toward the horizon for the Andrew and UTA antennas
respectively) due to the downward tilt of the mounted antennas. The antenna tilt will be 75 degrees
down from the horizontal, which is essentially pointing directly downward.

Types and Number of Units To Be Tested:

        Transcore requires three readers to obtain valid data and present an accurate demonstration
of real-world operations. The installations will be temporary fixed facilities that direct their signal
toward a tag mounted on a passing vehicle that will move within several meters of the reader’s
antenna.

Restrictions on Operation:

        The equipment to be used in this testing is being developed solely for export outside the
United States as part of a Transcore contract to develop a system of vehicle identification and
location in certain countries in the Middle East, which are friendly U.S. trading partners. The
equipment under test will be labeled as follows:




                                               FCC STATEMENT

                 Permission to operate this device has been granted under experimental authority
                 issued by the Federal Communications Commission to Transcore, Inc., is strictly
                 temporary and may be cancelled at any time. Operation is subject to the
                 condition that it not cause harmful interference. This device has been developed
                 solely for export outside the United States. It may not be offered for sale or use
                 or sold for delivery in the United States unless and until the approval of the FCC
                 has been obtained.


                                                -4-

Public Interest Statement:

        Transcore submits that issuance of special temporary authority is in the public interest,
convenience, and necessity. Grant of the authority will permit Transcore to develop innovative
equipment that will promote domestic industry and provide much-needed technology to a friendly
trading partner of the United States.

Contact Information:

Transcore:                                              Legal Counsel:

Michael Melville                                        David Hilliard or John Kuzin
8600 Jefferson Street NE                                Wiley Rein & Fielding LLP
Albuquerque, NM 87113 USA                               1776 K Street, NW
Tel. 505.856.8095                                       Washington, DC 20006
Mob: 505.259.3482                                       Tel. 202.719.7058 or 202.719.3506
michael.melville@transcore.com                          dhilliard@wrf.com or jkuzin@wrf.com


                                                             -5-

                                 Principal plane patterns, 870 MHz, Andrew antenna

                                                  15



                                                  10



                                                   5



                                                   0
gain (dBi)




                                                                                                   E-plane
                                                   -5
                                                                                                   H-plane


                                                  -10



                                                  -15



                                                  -20



                                                  -25
             -180   -135   -90          -45             0          45      90        135    180
                                               angle (degrees)



                                   Principal plane patterns, 870 MHz, UTA antenna

                                                   15


                                                   10


                                                    5


                                                    0


                                                    -5
gain (dBi)




                                                                                                     E-plane
                                                   -10
                                                                                                     H-plane

                                                   -15


                                                   -20


                                                   -25


                                                   -30


                                                   -35
             -180   -135   -90           -45             0          45      90        135    180
                                               angle (degrees)


                                                          -6-

                                 Horizon pattern for Andrew antenna, 870 MHz

                                                      5




                                                      0




                                                     -5
gain (dBi)




                                                    -10




                                                    -15




                                                    -20




                                                    -25
             -180   -135   -90           -45               0        45         90   135    180
                                                 angle (degrees)



                                   Horizon pattern for UTA antenna, 870 MHz

                                                      0




                                                      -5




                                                     -10
gain (dBi)




                                                     -15




                                                     -20




                                                     -25
             -180   -135   -90            -45              0        45         90    135    180
                                                  angle (degrees)



Document Created: 2007-05-09 16:29:49
Document Modified: 2007-05-09 16:29:49

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