Exhibit A Public

0208-EX-ST-2018 Text Documents

Vivint Wireless, Inc.

2018-02-08ELS_204595

REDACTED
FOR PUBLIC DISCLOSURE

Vivint Wireless
File No. 0208-EX-ST-2018
Exhibit A

EXHIBIT A – NARRATIVE DISCUSSION AND STA JUSTIFICATION

Pursuant to Section 5.61(a)(1) of the Commission’s Rules, Vivint Wireless, Inc.
(“Vivint”) provides this narrative statement in support of its request for Special Temporary
Authorization (“STA”) to conduct operational testing using 3550-3700 MHz Citizens Broadband
Radio Service (“CBRS”) spectrum in Salt Lake County, Utah.1 Vivint seeks STA for a period of
six (6) months beginning as soon as possible but not later than February 25, 2018.2

Due to unforeseen circumstances, Vivint will not be able to proceed with planned
operational testing in Maricopa County, Arizona and requests this STA to permit testing of
additional equipment in Salt Lake County, Utah.3

Consistent with Commission Rules, “good cause” exists to support grant of the requested
4
STA.

1
47 CFR § 5.61(a)(1).
2
Id.
3
See Call Sign WM9XEE, File No. 1759-EX-ST-2017.
4
47 CFR § 5.61(a)(2).
5
Commercial deployment of CBRS devices cannot occur prior to certification of at least one SAS
administrator given the need to enable geolocation capabilities to protect incumbent coastal radar systems.
6
The FCC has designated the NTIA-ITS to undertake certification testing. The FCC remains responsible for
the ultimate grant of certification.

REDACTED
FOR PUBLIC DISCLOSURE

Vivint Wireless
File No. 0208-EX-ST-2018
Exhibit A

Salt Lake County represents an optimal STA test site for CBRS 3550-3700 MHz
spectrum. That test site enjoys flat topographies that facilitate line-of-sight transmission with
minimal links. Moreover, Vivint has an extensive presence in the metropolitan areas, which will
facilitate the installation and maintenance of equipment under test.

Vivint’s proposed test does not represent an interference threat to incumbent operations.
The test site is located hundreds of miles from coastal radar operations, far outside Part 96
exclusion zones. No international ground stations requiring protection in the 3650-3700 MHz
band operate in Utah.7 Vivint will coordinate with Wireless Broadband Services (“WBS”)
operated under Subpart Z of the Commission’s Part 90 Rules.8 Vivint will also comply with the
power levels in Section 96.41. As described in Exhibit B, Vivint will also provide a 24/7 point

7
See https://transition.fcc.gov/bureaus/ib/sd/3650/grandftr.pdf (last visited 2/7/2018).
8
See 47 C.F.R. §§ 90.1301, et seq.

2

REDACTED
FOR PUBLIC DISCLOSURE

Vivint Wireless
File No. 0208-EX-ST-2018
Exhibit A

of contact with “kill switch” capability in the unlikely event of harmful interference with
incumbent users.

Exhibit B provides the unit volume and technical characteristics for the STA test site
proposed by Vivint for the instant application. Vivint requests authority for the minimal number
of devices needed to evaluate the viability of the 3550-3700 MHz to support a high-density
deployment of fixed wireless devices.

Grant of this STA will not affect possible rule changes currently pending before the
Commission, and all equipment proposed to be used by Vivint pursuant to this STA complies
with all existing and proposed future CBRS rules.

For the foregoing reasons, Vivint respectfully requests that the Commission expeditiously
grant the requested STA.

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Document Created: 2018-02-08 18:42:19
Document Modified: 2018-02-08 18:42:19

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