Narrative Statement

1423-EX-ST-2018 Text Documents

Viziv Technologies LLC

2018-08-13ELS_214065

                                                                     Viziv Technologies, LLC
                                                            Attachment to Application for STA
                                                                   File No. 1423-EX-ST-2018

                                       NARRATIVE STATEMENT

           Pursuant to Section 5.61 of the Commission’s rules, 47 C.F.R. §5.61 (2016),
           Viziv Technologies LLC hereby respectfully requests special temporary authority
           (“STA”) beginning October 15, 2018 to conduct experiments to validate the
           performance and operating characteristics of a prototype wave-launching
           apparatus that will produce a type of guided electromagnetic surface wave known
           as a Zenneck surface wave (“ZSW”) (not Norton ground waves) at or near an
           operating frequency of 18 kHz. A primary objective of the experimental tests
           will be to validate the hypothesis and predicted results that a ZSW will provide
           global signal coverage at the selected frequency of operation.

           This STA will build on the existing work to test and validate the utility of ZSWs
           being conducted under existing experimental radio licenses, call signs WI2XTH
           and WJ2XGB.1

           1)      Testing will be done under the control of:

                   Randall Jean, Ph.D
                   James Lilly

           2)      Stop Buzzer Point of Contact:

                   Mr. Tim Lougheed
                   E-mail: tlougheed@vizivtech.com


           3)      Description of Operation and Purpose of Test:

                   The purpose of the test will be to confirm effective launching of a
                   Zenneck surface wave and to measure its propagation and attenuation
                   characteristics on a global scale. More specifically, the operation of the
                   system will demonstrate and prove that a ZSW can be preferentially
                   produced by a novel launch-probe apparatus and that the generated wave
                   will propagate with sufficiently low attenuation to provide global
                   coverage.

                   Test measurements of signal strength will be taken at a minimum of 40
                   locations around the globe. The test instrumentation will be of two types,
                   each measuring the magnetic field within approximately one meter or less


1
    Viziv has undergone a name change – it was formerly known as Texzon Technologies.


     from the surface of the earth. Maximum signal strength for a ZSW occurs
     at the earth’s surface.

     One measurement system will measure a single horizontal axis,
     amplitude-only value of magnetic field strength using an ETS Lindgren
     single loop antenna connected to the input of a Rohde & Schwarz
     Spectrum Rider RPH spectrum analyzer.

     A second measurement system will provide a three-axis measurement of
     both amplitude and phase using a proprietary tuned receiver system
     manufactured for Viziv by Q-Track Incorporated of Huntsville, Alabama.

     Importantly, as has been shown by Viziv’s testing under FCC
     Experimental Licenses, call signs WI2XTH and WJ2XGB, the testing will
     be non-radiating – which will limit the interference effects to any other
     party in the spectrum band under test.

4)   Need for an STA:

     The STA is necessary for Viziv to conduct experiments at 18 kHz and
     thereby continue its ground breaking ZSW work being conducted at
     1710 kHz and 100 kHz under FCC Experimental Licenses, call signs
     WI2XTH and WJ2XGB.

5)   Dates of Operation:

     Operation is requested for the 6 month period beginning October 15, 2018
     through April 14, 2019.

6)   Class of Station:

     There will be a single fixed transmitter.

7)   Location of Proposed Operations:

     1130 Dale Acres Road
     Milford, Texas 76670

     The specific coordinates of the launch probe mechanism are 32ο 08’ 57.5”
     N; 96ο 56’ 32.1” W.

8)   Equipment To Be Used:

     The tests will employ a single prototype vertical wave-launching probe
     apparatus designed and built by Viziv Technologies LLC, comprising a
     phase-shifting coil/air-core transformer at the base of the structure that is
     connected to an elevated charge terminal.


      The transmitter, manufactured by Continental Electronics of Dallas,
      Texas, is a model Continental Electronics Model D120R Amplifier. The
      signal will be unmodulated.

9)    Frequencies Desired:

      Viziv requests to operate on a single frequency within the band from 17.4
      kHz to 18 kHz.

10)   Power Levels:

      Viziv will operate at the lowest power level required to verify global
      propagation and to effectively measure wave characteristics. The
      transmitter has a maximum mean output power of 500 kW. The launch
      probe is designed to launch a guided surface wave and to minimize the
      amount of radiated power. For the prototype design, we estimate that at
      maximum transmitter output, the maximum worst case mean EIRP will be
      1410 W.

11)   Type of Emission, Modulation Technique, and Bandwidth Required:

      The emitted signal will be unmodulated, corresponding to emission
      designator N0N. The signal bandwidth will be less than 10 Hz.

12)   Overall Height of Antenna(s) Above Ground/Orientation:

      The launch probe structure is omnidirectional and is 60.7 meters (199
      feet) tall (above ground level). The launch probe has received a “Notice
      of No Obstruction” from the FAA (see attachment).

13)   Protection Against Causing Harmful Interference:

      Viziv is requesting a single frequency from within the 17.4-18 kHz band.
      That band is allocated for Fixed service (federal primary and non-federal
      secondary) and Maritime Mobile service (federal primary). The band is
      also used by electric utilities for power line carrier systems on an
      unprotected basis. The properties of ZSWs (as opposed to Norton waves)
      of producing no radiation and propagating low to the ground as well as
      the low power density will act to minimize the potential for causing
      harmful interference to any authorized service. Under Viziv’s existing
      and previous experimental licenses for testing ZSWs, there have been no
      reported instances of harmful interference.

      Viziv understands that it must accept any interference from any users of
      this band and that all operations by Viziv will be on a non-interference
      basis. Viziv has established a point of contact identified above with “kill
      switch” authority should any interference occur to stations of authorized
      services. Should interference occur, Viziv will take immediate steps to


      resolve the interference, including, if necessary, arranging for the
      discontinuance of operation.

14)   Compliance with International Radio Regulations:

      Viziv is aware that the propagation characteristics of the Very Low
      Frequency (VLF) band will result in very long transmission distances
      which span the globe. In fact, Viziv’s premise in conducting this test is to
      do just that to prove that a single probe can provide global coverage.
      Internationally, the 17.4-18 kHz band is allocated for Fixed and Maritime
      Mobile service on a primary basis in all three regions.

      Under the proposed demonstration, Viziv will not be communicating with
      any station located in another administration as the extent of its operations
      will be to only take measurements of the ZSW at various locations across
      the earth. The International Radio Regulations (“IRR”) do not preclude
      tests of this type. In fact, the IRR, contemplate that tests spanning
      international boundaries will occur and have developed protocols and
      contingencies.

      Under Article 15 of the IRR, “Interferences,” Section IV, “Tests”,
      prescribes that when authorizing experiments, each administration shall
      take all possible precautions, including suppressing radiation (Section
      15.14). The same characteristics described above for minimizing the
      potential for harmful interference to domestic stations will also minimize
      the potential for harmful interference to stations of other administrations.
      Sections V, “Reports of Infringement” and VI, “Procedure in a case of
      harmful interference” set out the reporting mechanisms between
      administrations should harmful interference occur.

      Also, under Article 27 of the IRR, “Experimental Stations,” Section 27.5
      provides that, “experimental stations shall comply with the technical
      conditions imposed upon transmitters operating in the same frequency
      bands, except where the technical principles of the experiments prevent
      this. In such a case, the administration which authorizes the operation of
      these stations may grant a dispensation in an appropriate form.” Because
      Viziv will be transmitting an unmodulated carrier incapable of carrying
      information, the technical principles of the experiment will preclude it
      from transmitting any identifying information, such as a call sign, as
      generally required under Section 27.6 of the IRR. However, because the
      ZSW has an extremely low probability of causing harmful interference,
      the Commission should exercise its authority under Section 27.5 and not
      impose such a requirement.


15)   Contact Information

      Viziv Technologies Contact:

             Rick Devereaux
             Viziv Technologies LLC
             Telephone: 828-772-6023
             rdevereaux@vizivtech.com

      FCC Legal Counsel/Contact:

             Tom Dombrowsky
             Senior Engineering Advisor
             DLA Piper LLP
             500 8th Street, NW
             Washington, DC 20004
             Telephone: 202.799.4039
             Thomas.Dombrowsky@dlapiper.com



Document Created: 2018-08-13 11:16:23
Document Modified: 2018-08-13 11:16:23

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