Walt Disney Imagineering Research & Development, Inc. Request For

Walt Disney Imagineering Research & Development, Inc. Request for Experimental STA ELS File No. 0469-EX-ST-2018

NARRATIVE STATEMENT

Pursuant to Section 5.3(a) and (e) and Section 5.61 of the Federal Communications Commission’s (“FCC”) rules, 47 C.F.R. §§ 5.3(a) & (e); 5.61 (2016), Walt Disney Imagineering Research & Development, Inc. (“Disney”) hereby respectfully requests experimental special temporary authority (“STA”) commencing June 1, 2018, to conduct proof-of-concept testing of authorized Part 15 ultra-wideband (“UWB”) equipment within Disney’s park premises at Anaheim, California. Operation of authorized devices on a mobile basis is permitted without an STA. An STA is needed only to test such devices at fixed locations. See generally 47 C.F.R. § 15.519 (2016).

Grant of this request would allow Disney to complete the tests it commenced under the STA issued to it under Experimental Licensing System (“ELS”) File No. 1225-EX-ST-2017, call sign WL9XMN. That STA allowed the company to collect initial data to assess the performance and functionality of the equipment, but Disney was unable to complete such tests due to certain limitations. Specifically, Disney’s operations were limited by its access to the the premises. The park has its own schedule for entertainment, maintenance and construction, and the testing had to be scheduled around those activities. In particular, the test operations were limited by the crowd levels during the Thanksgiving and Christmas holiday seasons. Moreover, the ability to conduct tests under the existing STA was affected by the schedules of test personnel, many of whom also work on other projects, or the lack of additional equipment to replace test devices in need of repair.

The following additional information is provided in support of this request:

1) Applicant Information:

Walt Disney Imagineering Research & Development, Inc. 1401 Flower St. Glendale, CA 91221 Telephone: (818) 544-2172 Facsimile: (818) 544-4565 FCC Registration Number (FRN): 0008339962

2) Test Specifications:

Disney seeks to conduct additional tests of the functionality of equipment authorized under FCC ID: NUF-P440-A for operation under Section 15.519 of the FCC’s Rules. Id. at § 15.519. Although licensing authority is not needed to operate these devices on a mobile basis in accordance with the FCC’s rules, experimental authority is required here to permit Disney to test an innovative deployment of such devices that involves their operation at temporary fixed sites. The devices will be acquired from the manufacturer and will not be modified by Disney.

As noted above, the requested authorization is intended to replace and supplement Disney’s existing STA issued under call sign WL9XMN, ELS File No, 1225-EX-ST-2017. Moreover, this request seeks authority with the identical spectrum and same conditions

Walt Disney Imagineering Research & Development, Inc. Request for Experimental STA ELS File No. 0469-EX-ST-2018

contained in that STA (as well as many of those contained in the authorizations issued to 5D Robotics, Inc., under call signs WK9XYX, WK9XVW and WL9XLX), as follows:

Special Conditions: (1) Licensee should be aware that other stations may be licensed on these frequencies and if any interference occurs, the licensee of this authorization will be subject to immediate shut down. (2) In lieu of frequency tolerance, the occupied bandwidth of the emission shall not extend beyond the band limits set forth above. (3) Walt Disney Imagineering Research & Development, Inc. must notch out the 3500 - 3650 MHz band. (4) Walt Disney Imagineering Research & Development, Inc. must notch out the 4990 - 5000 MHz band. (5) All the experimental devices will be under the control of Walt Disney Imagineering Research & Development, Inc. (6) Walt Disney Imagineering Research & Development, Inc. must ensure that the operation will not cause harmful interference to any existing registered stations in the 3700-4200 MHz band, and notify the registered users in the proposed area. (7) Stop buzzer POC is Mr. Jeremy Mika, phone (818) 553-4876, email: [email protected] (8) Licensee must ensure the power output is below the levels for UWB operation per FCC Part 15 rules. (9) Licensee must ensure that operations outside the bands specified, including but not limited to the 3500 - 3650 MHz and 4990 - 5000 MHz bands, meet the emissions limits per FCC Part 15 rules, Section 15.519.

3) Need for and Purpose of STA:

As described above, Disney seeks an experimental STA to conduct additional, limited tests of the functionality of approved Part 15 UWB devices that have received FCC equipment authorization under FCC ID: NUF-P440-A issued to TDC Acquisition Holdings Inc. That equipment has been authorized for operation under Section 15.519 of Part 15 of the FCC’s rules. Id. at § 15.519, and will not be modified for purposes of this test. Experimental authority is needed to permit Disney to evaluate an innovative deployment of such devices that involves their operation both on a mobile basis and at temporary fixed sites. See generally 47 C.F.R. § 15.519 (2016).

Disney proposes to assess the capability of ultra-wideband technologies to support radiolocation requirements needed at its premises in Anaheim, California. It does not seek authority to conduct market studies or provide for-profit communications services under the requested experimental authority. The participants involved with the testing are employees of the company or personnel acting under the control of the company and will be advised that: (a) the operations are being conducted under an experimental authority issued to Walt Disney Imagineering Research & Development, Inc., (b) Disney is responsible for the experimental activities, (c) all operations are being conducted on a non-interference basis, and (d) after the test is completed, Disney will retrieve and recover all devices that do not comply with FCC

Walt Disney Imagineering Research & Development, Inc. Request for Experimental STA ELS File No. 0469-EX-ST-2018

regulations. Disney understands that the FCC may specify these as well as other conditions on its authorization.

4) Spectrum Requested:

Disney’s operations will be limited to the band 3100-5300 MHz.

5) Equipment To Be Used:

As noted above, Disney proposes to deploy approved Part 15 UWB devices that have received FCC equipment authorization under FCC ID: NUF-P440-A issued to TDC Acquisition Holdings Inc. The equipment will be acquired by Disney from the manufacturer, will not be modified for purposes of this test, and will operated in compliance with the emissions limits set forth in Section 15.519 of Part 15 of the FCC’s rules. Id. at § 15.519.

6) Technical Specifications:

a. No. of Test Units: <40 b. Effective Radiated Power (ERP): <45.1 nanowatts Mean (i.e., -41.3 dBm equivalent isotropically radiated power (“EIRP) when measured using a resolution bandwidth of 1 MHz, per Section 15.519(c) of the FCC’s rules. Moreover, per Section 15.519(e) of the FCC’s rules, the operation will not exceed the limit on the peak level of the emissions contained within a 50 MHz bandwidth centered on the frequency at which the highest radiated emission occurs, fM. That limit is 0 dBm EIRP (i.e., 1 mW). c. Unmodulated Emission Designator: 2G00P0N d. Frequency Band: 3.1-5.3 GHz e. Locations: Disney proposes to conduct proof-of-concept testing by placing not more than 35 devices at temporary fixed locations on its premises at Disneyland in Anaheim, California. Specifically, the temporary fixed test devices will be located within a radius of 1.5 kilometer of the coordinates 33-48-32N; 117-55- 10W (NAD83 Datum). In addition, Disney proposes to deploy up to 5 mobile units that will operate within a radius of 1.5 kilometer of the temporary fixed locations. Not more than a total of 40 devices will be operated during the experimentation proposed in this request. f. Duty Cycle: During the next phase of testing, Disney will likely only enable the system at key times throughout a period of approximately 90 days during the term of the STA. As an example, it might conduct tests 4 hours each day for the first week, and then sporadically over the next 12 weeks, probably for only 1-2 days a week (for the same 4-hour duration).

Disney will limit the power, test area, and deployment times to the minimum necessary to conduct its evaluations. Disney does not propose to supply station identification as set forth in Section 5.115 of the Commission's Rules during the experimentation.

Walt Disney Imagineering Research & Development, Inc. Request for Experimental STA ELS File No. 0469-EX-ST-2018

7) Restrictions on Operation:

As described above, Disney does not propose to market, sell, or lease any equipment under the requested authority. All equipment will remain in Disney’s possession and control during the experimentation and evaluation. If any different treatment becomes necessary during the course of its experimentation, Disney will seek separate and additional authority from the agency.

Disney recognizes that the operation of the devices under experimentation must not cause harmful interference to authorized facilities. To that end, the company will advise persons operating the equipment that permission to use the equipment has been granted under experimental authority issued to Disney, is strictly temporary and may be canceled at any time. The company will also advise operators of the condition that the equipment may not cause harmful interference.

Disney does not expect its proposed operation to cause harmful interference, however. As noted above, the experimentation will be restricted to its premises, and the devices will operate at a mean ERP of 45.1 nanowatts or less. Moreover, in the unlikely event that Disney receives a complaint of harmful interference, it will take immediate action to address the interference, including if necessary discontinuing its operations. To facilitate such action, if needed, the company has designated Jeremy Mika, Show Software Developer Sr. to act as the “stop buzzer” for this test. That person’s contact information is provided below.

8) Public Interest Statement:

Disney submits that issuance of experimental authority is in the public interest, convenience, and necessity. Grant of this application will permit Disney to complete proof-of- concept testing of equipment needed to support its internal requirements for radiolocation capabilities.

Walt Disney Imagineering Research & Development, Inc. Request for Experimental STA ELS File No. 0469-EX-ST-2018

9) Contact Information:

a. Stop Buzzer: Jeremy Mika Show Software Developer Sr. Walt Disney Imagineering Research & Development, Inc. 1401 Flower Street Glendale, CA 91201 Telephone: (818) 553-4876 [email protected]

b. Company Contact: John N. Ward Associate Principal Counsel Walt Disney Imagineering Research & Development, Inc. 1410 Flower Street Glendale, CA 91221 Telephone: (818) 544-2172 Facsimile: (818) 544-4565 [email protected]

c. Legal Representative Contact: Wayne Johnsen Wiley Rein LLP 1776 K Street, N.W. Washington, DC 20006 Telephone: (202) 719-7303 Facsimile: (202) 719-7049 [email protected]

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