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 Page 1 of 7

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. Page 2 of 7

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 Page 3 of 7

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 Page 7 of 7


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