Narrative Statement

0242-EX-ST-2014 Text Documents

Booz Allen Hamilton Inc.

2014-03-28ELS_147428

                                                                       Booz Allen Hamilton, Inc.
                                                       Request for Special Temporary Authority
                                                                   ELS File No. 0242‐EX‐ST‐2014


                         EXHIBIT A – NARRATIVE STATEMENT
By this application, and pursuant to Sections 5.3(d) and 5.61 of the FCC Rules, 47 C.F.R. §§
5.3(d) and 5.61 (2012), Booz Allen Hamilton, Inc. (“Booz Allen”), respectfully seeks a 6 month
experimental license beginning May 1, 2014, to develop, test and demonstrate prototype
remote sensors with low power communications equipment that will operate in the 317 MHz
band allocated for non‐multilateration operations. A separate request for expedited treatment
is included with this application.

The following information is provided in support of this request:

   1) Need for a 6‐month authorization
      Booz Allen needs a 6‐month license to accommodate ongoing testing of equipment
      that is expected to change and evolve over this period as a result of Booz Allen’s
      research and development.

   2) Purpose of Operation
      The proposed operation will allow Booz Allen to develop, test, and demonstrate to
      Department of Defense (“DoD”) representatives sensors that employ a low power
      communication transceiver module.

       Booz Allen does not seek authority to conduct market studies or provide
       communications services under the requested experimental authority. The
       participants in the test will be advised that: (a) the test is being conducted under an
       experimental authority issued to Booz Allen, (b) Booz Allen is responsible for
       operations, (c) all operations are conducted on a non‐interference basis, and (d) after
       the test is completed, Booz Allen will retrieve and recover all devices that do not
       comply with FCC regulations. Booz Allen understands that the FCC may specify these
       as well as other conditions on its authorization.

   3) Sponsorship
      Booz Allen has discussed the communications capability and application with DoD
      agencies which have interest in advanced communications devices and systems and
      interest in demonstration of technologies and devices.

       Booz Allen is cognizant that the spectrum access requested is allocated to the U.S.
       Federal Government for fixed and mobile services, and that it is also allocated to the
       U.S. Federal Government on a primary basis for mobile‐satellite service, limited to
       military operations. Because of this allocation, Booz Allen will coordinate and
       cooperate with U.S. Federal Government and military entities to demonstrate the
       prototype equipment. It will only perform demonstrations and experiments with the

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                                                                   Booz Allen Hamilton, Inc.
                                                   Request for Special Temporary Authority
                                                               ELS File No. 0242‐EX‐ST‐2014

   spectrum coordination and cognizance of entities with authorization to use and
   coordinate operations in these bands.

   In addition, Booz Allen will work with identified Government entities to coordinate
   specific experiments and demonstrations, in a determined sub‐set of channels in the
   requested band, detailed in Appendix A. Booz Allen’s technology and experimental
   prototypes are frequency agile and can be tuned at the time of the experiment or
   demonstration on channels centered on frequencies from 317.015 through 317.325
   MHz, as shown in Appendix A and the attached application. In addition, Booz Allen
   can monitor the band and channels, and it will work with the Government
   coordinators, to operate only on channels that are unused at the time of the
   demonstration or testing. Because Booz Allen technology uses short burst
   transmissions, typically only a few second in duration, it can monitor the channel and
   avoid interference with other users.

4) Technical Specifications
      a. Power Levels
                i. Transmitter Power Output (“TPO”): 2W peak
               ii. Effective Radiated Power (“ERP”): 3W peak
             iii. Necessary bandwidth:
                        1. 5 kHz for low data rate operations
                        2. 25 kHz for high data rate operations
              iv. Modulation: BFSK, QFSK, QAM
               v. Emissions: F1D, F2D
              vi. Frequencies: Exact center frequencies, as directed by the sponsor, are
                   listed in Appendix A.
             vii. Antenna: Omnidirectional, Low‐gain directional or steerable
            viii. Notes: Other emission modes may be utilized, but in no event will the
                            emissions extend beyond the frequency bands requested. All
                            power levels will comply with the limits set forth in the FCC’s
                            rules, including those relating to human exposure to radiation.

       b. Antenna Information
          The antennas that would be deployed under this license will not extend more
          than 3 meters above the ground.

           Omnidirectional antennas will be used in experiments that require uniform
           azimuthal coverage; directional antennas will be used in experiments to
           prevent interference or to limit azimuthal coverage.




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                                                                    Booz Allen Hamilton, Inc.
                                                    Request for Special Temporary Authority
                                                                ELS File No. 0242‐EX‐ST‐2014

       c. Proposed Locations
          Booz Allen seeks authority to conduct its experimental operations at the
          locations specified in the attached table and FCC Form 442. Although it will
          conduct tests and demonstrations primarily at DoD sponsor sites, Booz Allen
          also plans to test and demonstrate equipment at other locations. Specifically,
          Booz Allen seeks authority to operate and demonstrate products: (i) at its own
          premises; and (ii) at the premises of entities working under Booz Allen's
          authorization in the design and development of the devices and related
          products. Indeed, these operations would be consistent with the requirements
          set forth in Section 2.803 of the Commission's marketing rules and 47 C.F.R. §
          2.803 (2012); see also Revision of Part 2 of the Commission's Rules Relating to
          the Marketing and Authorization of Radio Frequency Devices, ET Docket No.
          94‐45, Report and Order, released Feb. 12, 1997, at 11‐13, 19‐20 (“Marketing
          Rule Revisions”).

       d. Equipment to be used
          Booz Allen proposes to deploy only a limited number of units which, as noted
          above, would operate at low power levels. Booz Allen expects that it will be
          able to complete its experimentation and demonstration with a maximum of 4
          units per test location. In all experiments, Booz Allen will also limit the power,
          area of operation, and transmitting times of these units to the minimum
          necessary to evaluate the equipment.

       e. Sponsor coordination and cognizance
          Booz Allen will work with the sponsor to perform tests and demonstrations
          under the sponsor’s guidance, on sponsor licensed and specified channels, on a
          secondary and on a non‐interference basis.

           As shown in the separate request for expedited treatment, Booz Allen will only
           perform demonstrations with the cognizance and coordination of DoD
           sponsors that have requested a demonstration of the communication device,
           and it will operate only on specific frequencies on a secondary and non‐
           interference basis.

5) Restrictions on Operation
   Booz Allen understands that the FCC permits (a) companies to enter into agreements
   and contracts to manufacturer new products and (b) manufacturers to sell—but not
   deliver—products on a conditional basis to wholesalers and retailers. Booz Allen also
   understands that the FCC permits the operation of equipment for, among other
   things, compliance testing, demonstration at trade shows and other exhibitions with
   appropriate notices displayed, and evaluation of product performance and customer
   acceptability at the manufacturer's facilities or at certain non‐residential sites during

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                                                                      Booz Allen Hamilton, Inc.
                                                      Request for Special Temporary Authority
                                                                  ELS File No. 0242‐EX‐ST‐2014

the developmental, design and pre‐production stages. See Marketing Rule Revisions, §
2.803; Part 15 Revisions, 6 FCC Rcd 1683, 1685 (1991).

Notwithstanding these general rules, the FCC requires parties to seek authorization to
use devices that normally require a license to operate, or that will be operated, at
residential locations. Such authority may be granted under the FCC's experimental
rules set forth in Part 5 of the Code of Federal Regulations, 47 C.F.R. Part 5 (2012).
Accordingly, Booz Allen seeks an experimental license to conduct experimental
operations permitted under Part 5 of the Commission’s rules. Those rules permit such
operation provided that: (a) participants are advised that the service or device is
granted under experimental authority and is strictly temporary; and (b) the devices
are owned by the licensee.

Booz Allen does not propose to market, sell, or lease any prototype equipment to end
users, however. After the experimentation and demonstrations cease, Booz Allen
would recall and recover all devices. If any different treatment becomes necessary
during the course of its experimentation and demonstrations, Booz Allen will seek
separate and additional authority from the agency.

Booz Allen also recognizes that the operation of any unapproved or unlicensed devices
under experimentation must not cause harmful interference to authorized facilities.
Should interference occur, Booz Allen will immediately take reasonable steps to
resolve the interference, including if necessary discontinuing operation. To that end,
Booz Allen would advise entities using the equipment that permission to operate the
equipment has been granted under experimental authority issued to Booz Allen, is
strictly temporary and may be canceled at any time. It will also advise entities that
operation is subject to the condition that the equipment may not cause harmful
interference. Specifically, Booz Allen proposes to label the equipment conspicuously
as follows:

                                             FCC STATEMENT
           Permission to operate this device has been granted under experimental authority
           issued by the Federal Communications Commission to Booz Allen Hamilton, Inc.,
           is strictly temporary, and may be canceled at any time. Operation is subject to the
           following two conditions: (1) this device may not cause harmful interference and
           (2) this device must accept any interference received including interference that
           may cause undesired operation.
           This device has not been authorized as required by the rules of the Federal
           Communications Commission. This device is not, and may not be, offered for sale
           or sold until the approval of the FCC has been obtained. Thus, the user does not
           hold a property right in the device and may be required to return the device.


Moreover, Booz Allen submits that its experimental operations and demonstrations
are unlikely to cause interference. Booz Allen intends to monitor use of the relevant

                                                                                           Page 4 of 7


                                                                   Booz Allen Hamilton, Inc.
                                                   Request for Special Temporary Authority
                                                               ELS File No. 0242‐EX‐ST‐2014

   frequencies before commencing transmissions, and it will not operate if the
   frequencies are in use. Booz Allen’s experimental prototypes are frequency agile and
   can be tuned at the time of the experiment or demonstration to any frequency or
   channel in the requested band. In addition, Booz Allen will monitor the band and
   channels, and work with the Government coordinators, to operate only on channels
   that are unused at the time of the demonstration or experiments. Because the
   prototype devices use short burst transmissions, typically only a few second in
   duration, Booz Allen can monitor the channel and avoid interference with other users.

6) Public Interest
   Booz Allen submits that issuance of a license is in the public interest, convenience, and
   necessity. Grant of a license will permit Booz Allen to develop innovative equipment
   that will accommodate the communications needs of prospective DoD users.

7) Contact Information
      a. Technical Point of Contact                     b. Legal Contact
         Dr. John C. Swartz, Lead Associate                Ms. Callie Carr, Counsel
         Booz Allen Hamilton, Inc.                         Booz Allen Hamilton, Inc.
         511 Davis Drive, Suite 400                        8283 Greensboro Drive
         Morrisville, NC 27560                             McLean, VA 22102
         Office:     (919) 595‐4825                        Office: (703) 377‐4473
         Facsimile: (919) 595‐4825                         Email: Carr_Callie@bah.com
         Mobile: (919) 270‐5074
         Email: swartz_john@bah.com




                                                                                  Page 5 of 7


                                                           Booz Allen Hamilton, Inc.
                                           Request for Special Temporary Authority
                                                       ELS File No. 0242‐EX‐ST‐2014

                               LOCATIONS

16 kilometer radius of
Booz Allen Hamilton, Inc., 511 Davis Drive, Suite 400, Morrisville, NC 27560
(N 35.874524, W7 8.859994)
32 kilometer radius of
Fort Story, Guadalcanal Rd, Virginia Beach, VA 23451
(N 36.922456, W 76.003287)
32 kilometer radius of
1771 Felix Canyon Rd., Flying H, NM 88339
(N 33.020755, W 105.113869)
32 kilometer radius of
Falcon St, Fort Bragg, NC 28307
(N 35.129912, W 79.024905)
16 kilometer radius of
8190 Condor St, Tampa, FL 33621
(N 27.851537, W 82.489046)
3 kilometer radius of
5499 15th St SE, Rochester, MN 55904
(N 44.000614, W 92.369879)
32 kilometer radius of
155 County Road 270, Mico, TX 78056
(N 29.576138, W 98.900573)




                                                                         Page 6 of 7


                                                                  Booz Allen Hamilton, Inc.
                                                  Request for Special Temporary Authority
                                                              ELS File No. 0242‐EX‐ST‐2014

             APPENDIX A ‐ SPONSOR‐SPECIFIED FREQUENCIES FOR USE

              Decimal Channel#**   UHF Channel        Frequency (MHz)
                      199             N19                 317.015
                      200             N20                 317.025
                      201             N21                 317.035
                      202             N22                 317.045
                      203             N23                 317.055
                      204             N24                 317.065
                      205             N25                 317.075
                      206             N26                 317.085

                     208               O19                317.095
                     210               O20                317.105
                     212               O21                317.115
                     213               O22                317.125
                     214               O23                317.135
                     215               O24                317.145
                     216               O25                317.155
                     217               O26                317.165

                     218               P19                317.175
                     219               P20                317.185
                     221               P21                317.195
                     223               P22                317.205
                     225               P23                317.215
                     226               P24                317.225
                     227               P25                317.235
                     228               P26                317.245

                     229               Q19                317.255
                     230               Q20                317.265
                     231               Q21                317.275
                     232               Q22                317.285
                     233               Q23                317.295
                     234               Q24                317.305
                     235               Q25                317.315
                     236               Q26                317.325
             ** Per MIL‐STD‐188‐181A Table A‐I.




13716414.1




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Document Created: 2014-03-28 16:24:53
Document Modified: 2014-03-28 16:24:53

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