PUBLIC Narrative Exhibit

1759-EX-ST-2017 Text Documents

Vivint Wireless, Inc.

2018-01-03ELS_202837

REDACTED FOR PUBLIC DISCLOSURE Vivint Wireless File No. 1759-EX-ST-2017 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 Maricopa County, Arizona and Salt Lake County, Utah.1 Vivint seeks STA for a period of six (6) months beginning as soon as possible but not later than January 17.2 Consistent with Commission Rules, “good cause” exists to support grant of the requested STA.3 Specifically, Vivint seeks STA to participate in collaborative testing with the first wave of Spectrum Access System (“SAS”) administrators presently preparing to undergo certification by the Federal Communications Commission (“FCC” or “Commission”).4 Although the first wave of SAS administrators developed and deployed operational “beta” systems in 2017, delays in certification have hindered intensive, real-world testing of these systems. At present, Vivint understands that test code is tentatively scheduled to be provided through the Wireless Innovation Forum (“WinnForum”) to the National Telecommunications and Information Administration - Institute for Telecommunications Sciences (“NTIA-ITS”) in January 2018, with the expectation that NTIA-ITS will require approximately 60 days to troubleshoot such code. The timeline currently anticipated for WinnForum and NTIA-ITS test code development and troubleshooting would facilitate the start of certification testing toward the beginning of Q2 2018.5 Vivint further understands, however, that a number of issues may delay the start of such certification testing. For example, the terms of a cooperative research and development agreement (“CRDA”) – a prerequisite before test code can be delivered to NTIA-ITS – are still under discussion by the first wave of SAS administrators and NTIA-ITS. In addition, we understand that delays have occurred in the delivery of actual test code to the WinnForum from certain members participating in the certification effort.6 Given the above-referenced complications associated with the commercial deployment of SAS administrators, Vivint seeks STA to undertake experiments that will advance the radio art with respect to the CBRS 3550-3700 MHz band, troubleshoot SAS spectrum management 1 47 CFR § 5.61(a)(1). 2 Id. 3 47 CFR § 5.61(a)(2). 4 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. 5 The FCC has designated the NTIA-ITS to undertake certification testing. The FCC remains responsible for the ultimate grant of certification. 6 Contributions to the WinnForum are voluntary, and no enforcement mechanism exists if a member fails to submit a deliverable.

REDACTED FOR PUBLIC DISCLOSURE Vivint Wireless File No. 1759-EX-ST-2017 Exhibit A systems and user interfaces, and facilitate an expeditious and trouble-free commercial deployment of CBRS. These experiments will benefit consumers and build confidence in the geolocation architecture that underpins the CBRS 3550-3700 MHz band, and which may also facilitate shared use of other bands with primary or co-primary federal allocations in the future. In particular, under the proposed STA Vivint will evaluate radio device performance while collaboratively testing various aspects of the SAS administrator systems that may not be thoroughly scrutinized under certification testing, which is designed to confirm compliance with Part 96 Rules, but not intended to evaluate other performance metrics. Among other performance metrics, Vivint expects to evaluate the following under the instant STA: • The ability of SAS systems to handle large numbers of simultaneous frequency assignment/channel requests from simulated General Authorized Access (“GAA”) user devices. • SAS administrator reaction timing and channel loading methodology when responding to requests for alternate frequencies in the event of interference into a GAA system. • Geolocation accuracy of devices under test. • Propagation characteristics and ambient RF levels in suburban settings during peak and off-peak use of CBRS 3550-3700 MHz band wireless broadband devices. • SAS user interface troubleshooting/debugging. Maricopa County and Salt Lake County represent optimal STA test sites for CBRS 3550- 3700 MHz spectrum. Both test sites enjoy flat topographies that facilitate line-of-sight transmission with minimal links. Moreover, Vivint has an extensive presence in both metropolitan areas, which will facilitate the installation and maintenance of equipment under test. Vivint’s proposed tests do not represent an interference threat to incumbent operations. Both test sites are 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 Arizona or 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 7 See https://transition.fcc.gov/bureaus/ib/sd/3650/grandftr.pdf (last visited 11/9/2017). 8 See 47 C.F.R. §§ 90.1301, et seq. Page 2 of 3

REDACTED FOR PUBLIC DISCLOSURE Vivint Wireless File No. 1759-EX-ST-2017 Exhibit A with the power levels in Section 96.41. As described in Exhibit B, Vivint will also provide a 24/7 point 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 each 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. Page 3 of 3


Document Created: 2018-01-03 13:29:07
Document Modified: 2018-01-03 13:29:07
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