2AGZ3S01311S01311

1(2) Starry, Inc. August 27, 2021 Attention: Application Examiner RE: Request for Confidentiality Applicant: Starry, Inc. FCC ID: 2AGZ3S01311 To Whom It May Concern: Pursuant to 47 C.F.R. §§ 0.457(d) and 0.459, Starry, Inc. (Starry) hereby requests short-term and long-term confidential treatment, as described below, for certain exhibits submitted in support of Starry’s application for certification of the equipment associated with the above-referenced FCC identifier. This equipment represents a unique technological implementation that contains certain intellectual property that would significantly harm Starry if revealed to its competitors or to parties that seek to replicate Starry’s equipment. Short-Term Confidentiality In order to avoid premature release of sensitive information prior to the marketing and public release of the equipment covered by this equipment certification application, Starry requests that the Commission treat the following exhibits as confidential until 45 days after the date the Grant of Equipment Authorization is issued. ● Test setup photos ● External photos Disclosure of the exhibits for which Starry seeks short-term confidential treatment during the period of importation and/or distribution would reveal key aspects of proprietary technology to competitors and significantly diminish the value of our investment in research and development. Long-Term Confidentiality Starry requests that the Commission treat the following exhibits as permanently confidential: ● Schematics ● Detailed Block Diagrams ● Detailed Operational/Functional Description ● Tune up procedure ● Parts list ● Internal photos ● User Manual The exhibits for which Starry requests long-term confidential treatment all contain confidential, proprietary technical information that the Commission protects from disclosure as a type of record that is not routinely available for public inspection. 1 Starry has invested considerable time and materials in research and development to produce the referenced product. To protect its investment, Starry does not release this information in the ordinary course of its business because doing so would result in substantial competitive harm to Starry. Disclosure of these confidential exhibits to competitors would not only give them significant competitive advantages in developing similar 1 47 C.F.R. § 0.457(d). 2(2) products, but would also disclose successful implementation of unpublished, leading edge technology developed by Starry and could even reveal information about Starry’s unique economic model. Among the exhibits for which Starry seeks long-term confidential treatment are internal photos. It is appropriate to accord such treatment to the internal photos submitted for two reasons. First, some of these photos are scanning receiving internal photos, which, by rule, the Commission does not make available for inspection. 2 Second, long-term confidential treatment for all other internal photos is also warranted because the referenced product is a non-consumer device that is not sold to end users, nor is it accessible to the general public. These devices are mounted on the top of a large tower or in a locked area, such as a rooftop, and are only serviceable by professional, designated Starry technicians and partners under a Non-Disclosure Agreement (NDA). An example of the NDA between Starry and its technicians and partners is provided herein. Starry also seeks long-term confidential treatment for the user manual of the referenced product. The manual for this product contains confidential proprietary technical information and is only shared outside the company with professional, designated Starry technicians and partners under an NDA. The manual is not provided to end users because this is a non-consumer device that is not available for sale and end users of the device do not have access to it and cannot service it. Therefore, long-term confidential treatment of the user manual is also warranted. Sincerely, Robert M. White Senior Director, Product Realization and Mechanical Engineering Starry, Inc. 2 See 47 C.F.R. § 0.457(d)(1)(ii) (“Portions of applications for equipment certification of scanning receivers and related materials will not be made available for inspection.”).

Starry, Inc. August 27, 2021 Federal Communications Commission 445 12 th Street SW Washington, DC 20554 Subject: Limited Agency Agreement Starry, Inc. FCC ID: 2AGZ3S01311 To Whom It May Concern: We, Starry, Inc., hereby authorized Intertek Testing Services to act as our Agent for the purpose of preparing application for FCC ID number 2AGZ3S01311 under all applicable parts of the FCC rules and regulations. The effective date of this limited agency agreement is August 27, 2021. The Limited Agency Agreement expires on August 27, 2023, unless sooner terminated or extended by written notice to Intertek Testing Services and the Federal Communications Commission. This is to advise that we are in full compliance with the Anti-Drug Abuse Act. The applicant is not subject to a denial of federal benefits pursuant to Section 5301 of the Anti-Drug Act of 1988, 21 U.S.C. 862, and no party to the application is subject to a denial of federal benefits pursuant to that section. If you have any questions or comments, please do not hesitate to contact me. Sincerely, Robert M. White Senior Director, Product Realization and Mechanical Engineering 38 Chauncy Street, Suite 200 Boston, MA 02111

FCC ID 2AGZ3S01311 External Photographs 1 Figure 1. Front Assy View, External Figure 2. Rear Assy View, External FCC ID 2AGZ3S01311 External Photographs 2 Figure 3. Grounding, External, Side view with Mounting bracket Attached FCC ID 2AGZ3S01311 External Photographs 3 Figure 4. Comet 24_Connector Panel Interface/ Bottom View Figure 5. Comet 24, Top View Figure 6. Comet 24, ISO view FCC ID 2AGZ3S01311 External Photographs 4

Unit Label_2AGZ3S01311

FCC ID 2AGZ3S01311 Location of the Unit Label 1 Figure 1. Unit Label (reference example Starry Part Number 950-00079) is located on the external side of the Comet 24 unit.

STARRY, INC. MPE REPORT SCOPE OF WORK MPE CALCULATION – COMET 24 REPORT NUMBER 104749253BOX-007 ISSUE DATE February 2, 2022 PAGES 8 DOCUMENT CONTROL NUMBER Non-Specific Radio Report Shell Rev. December 2017 © 2017 INTERTEK Non-Specific Radio Report Shell Rev. December 2017 Page 2 of 8 Starry, Inc., Model: COMET 24 MPE REPORT (FULL COMPLIANCE) Report Number: 104749253BOX-007 Project Number: G104749253 Report Issue Date: February 2, 2022 Model(s) Tested: COMET 24 Standards: FCC Part 1 Subpart I, February 2022 Procedures Implementing the National Environmental Policy Act of 1969 §1.1307 Actions that may have a significant environmental effect, for which Environmental Assessments (EAs) must be prepared. ISED RSS-102 Issue 5, March 19, 2015 Radio Frequency (RF) Exposure Compliance of Radiocommunication Apparatus (All Frequency Bands) Tested by: Client: Intertek 70 Codman Hill Road Boxborough, MA 01719 USA Starry, Inc. 38 Chauncy St, Suite 200 Boston, MA 02111 USA Report prepared by Report reviewed by Vathana Ven / EMC Engineering Supervisor Kouma Sinn / EMC Engineering Supervisor This report is for the exclusive use of Intertek's Client and is provided pursuant to the agreement between Intertek and its Client. Intertek's responsibility and liability are limited to the terms and conditions of the agreement. Intertek assumes no liability to any party, other than to the Client in accordance with the agreement, for any loss, expense or damage occasioned by the use of this report. Only the Client is authorized to permit copying or distribution of this report and then only in its entirety. Any use of the Intertek name or one of its marks for the sale or advertisement of the tested material, product or service must first be approved in writing by Intertek. The observations and test results in this report are relevant only to the sample tested. This report by itself does not imply that the material, product, or service is or has ever been under an Intertek certification program. Intertek Report Number: 104749253BOX-007 Issued: February 2, 2022 Non-Specific Radio Report Shell Rev. December 2017 Page 3 of 8 Starry, Inc., Model: COMET 24 Table of Contents 1 Introduction and Conclusion ..................................................................................................................... 4 2 Evaluation Summary ................................................................................................................................ 4 3 Client Information .................................................................................................................................... 5 4 Description of Equipment Under Test and Variant Models ......................................................................... 5 5 Power Density Calculation ........................................................................................................................ 6 6 Revision History ....................................................................................................................................... 8 Intertek Report Number: 104749253BOX-007 Issued: February 2, 2022 Non-Specific Radio Report Shell Rev. December 2017 Page 4 of 8 Starry, Inc., Model: COMET 24 1 Introduction and Conclusion This evaluation report covers for a mobile device subject to routine environmental evaluation for RF exposure. A mobile device is defined as a transmitting device designed to generally be used in such a way that a separation distance of at least 20 centimeters is normally maintained between the transmitter’s radiating structurer(s) and the body of the user or nearby persons. The evaluation indicated in section 2.0 were performed on the product constructed as described in section 4.0. The remaining sections are the verbatim text from the actual evaluation during the investigation. These sections include the evaluation name, the specified Method, and Results. No additions, deviations, or exclusions have been made from the standard(s) unless specifically noted. Based on the results of our investigation, we have concluded the product evaluated complies with the requirements of the standard(s) indicated. The results obtained in this report pertain only to the item(s) evaluated. Intertek does not make any claims of compliance for samples or variants which were not evaluated. 2 Evaluation Summary Section Test full name Result 3 Client Information - 4 Description of Equipment Under Evaluation and Variant Models - 5 System Setup and Method - 6 Power Density Calculation (FCC §1.1310) Compliant 7 Revision History - Intertek Report Number: 104749253BOX-007 Issued: February 2, 2022 Non-Specific Radio Report Shell Rev. December 2017 Page 5 of 8 Starry, Inc., Model: COMET 24 3 Client Information This EUT was evaluated at the request of: Client: Starry, Inc. 38 Chauncy St, Suite 200 Boston, MA 02111 USA Contact: Robert White Telephone: (617) 297-9559 Email: [email protected] 4 Description of Equipment Under Test and Variant Models Manufacturer: Starry, Inc. 38 Chauncy St, Suite 200 Boston, MA 02111 USA Description of Equipment Under Test (provided by client) The equipment under test is a Multipoint Radio with integrated Bluetooth Low Energy (BLE) and 5 GHz transmitters. The BLE radio is used only during installation to add technicians for a very short period. The 24 GHz is active during that time and establishing a link / passing traffic. The BLE does not operate after installation is completed, except on site visit, which is rare. 5 GHz radio is always associated. It sends beacons 100% of the time on 5 GHz. It operates at the same time as the 24 GHz, and for a very short period of time with the BLE. Equipment Under Test Power Configuration Rated Voltage Rated Current Rated Frequency Number of Phases 54 Vdc - - - Variant Models: The following variant models have been identified by the manufacturer as being electrically identical models, depopulated models, or with reasonable similarity to the model(s)…

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STARRY, INC. TEST REPORT SCOPE OF WORK Emissions Testing on COMET 24 – 5GHz Radio REPORT NUMBER 104749253BOX-008 ISSUE DATE [LAST REVISED DATE] October 29, 2021 January 6, 2022 PAGES 58 DOCUMENT CONTROL NUMBER Non-Specific Radio Report Shell Rev. December 2017 © 2017 INTERTEK Non-Specific Radio Report Shell Rev. December 2017 Page 2 of 58 Client: Starry, Inc. / Model: COMET 24 – 5GHz Radio EMISSIONS TEST REPORT (FULL COMPLIANCE) Report Number: 104749253BOX-008 Project Number: G104749253 Report Issue Date: 10/29/2021 Report Last Revision Date: 1/06/2022 Model(s) Tested: COMET 24 – 5GHz Radio Standards: CFR47 FCC Part 15.407 Subpart E: 07/2021, CFR47 FCC Part 15 Subpart B: 07/2021, CFR47 FCC Part 1.1310: 07/2021 Tested by: Client: Intertek Testing Services NA, Inc. 70 Codman Hill Road Boxborough, MA 01719 USA Starry, Inc. 38 Chauncy St, Suite 200 Boston, MA 02111 USA Report prepared by Report reviewed by Vathana Ven / EMC Engineering Supervisor Kouma Sinn / EMC Engineering Supervisor This report is for the exclusive use of Intertek's Client and is provided pursuant to the agreement between Intertek and its Client. Intertek's responsibility and liability are limited to the terms and conditions of the agreement. Intertek assumes no liability to any party, other than to the Client in accordance with the agreement, for any loss, expense or damage occasioned by the use of this report. Only the Client is authorized to permit copying or distribution of this report and then only in its entirety. Any use of the Intertek name or one of its marks for the sale or advertisement of the tested material, product or service must first be approved in writing by Intertek. The observations and test results in this report are relevant only to the sample tested. This report by itself does not imply that the material, product, or service is or has ever been under an Intertek certification program. Intertek Report Number: 104749253BOX-008 Issued: 10/29/2021 Last Revised: 1/06/2022 Non-Specific Radio Report Shell Rev. December 2017 Page 3 of 58 Client: Starry, Inc. / Model: COMET 24 – 5GHz Radio Table of Contents 1 Introduction and Conclusion .............................................................................................................. 4 2 Test Summary ...................................................................................................................................... 4 3 Client Information ................................................................................................................................ 5 4 Description of Equipment Under Test and Variant Models ............................................................. 5 5 System Setup and Method .................................................................................................................. 7 6 Maximum Peak Output Power and Human RF exposure ................................................................. 8 7 6 dB Bandwidth, 26 dB Bandwidth and Occupied Bandwidth ...................................................... 16 8 Maximum Power Spectral Density ................................................................................................... 23 9 Transmitter spurious emissions ...................................................................................................... 27 10 Digital Device and Receiver Radiated Spurious Emissions ...................................................... 45 11 AC Mains Conducted Emissions .................................................................................................. 53 12 Revision History ............................................................................................................................. 58 Intertek Report Number: 104749253BOX-008 Issued: 10/29/2021 Last Revised: 1/06/2022 Non-Specific Radio Report Shell Rev. December 2017 Page 4 of 58 Client: Starry, Inc. / Model: COMET 24 – 5GHz Radio 1 Introduction and Conclusion The tests indicated in section 2.0 were performed on the product constructed as described in section 4.0. The remaining test sections are the verbatim text from the actual data sheets used during the investigation. These test sections include the test name, the specified test Method, a list of the actual Test Equipment Used, documentation Photos, Results and raw Data. No additions, deviations, or exclusions have been made from the standard(s) unless specifically noted. Based on the results of our investigation, we have concluded the product tested complies with the requirements of the standard(s) indicated. The results obtained in this test report pertain only to the item(s) tested. Intertek does not make any claims of compliance for samples or variants which were not tested. 2 Test Summary Section Test full name Result 3 Client Information -- 4 Description of Equipment Under Test and Variant Models -- 5 System Setup and Method -- 6 Maximum Peak Output Power and Human RF exposure CFR47 FCC Part 15.407 Subpart E:07/2021, Section 15.407 (a)(3) CFR47 FCC Part 1.1310:2021 Pass 7 6 dB Bandwidth, 26 dB Bandwidth and Occupied Bandwidth CFR47 FCC Part 15.407 Subpart E: 07/2021, Section 15.407(a)(12) and 15.407(e) Pass 8 Power Spectral Density CFR47 FCC Part 15.407 Subpart E: 07/2021, Section 15.407 (a)(3) Pass 9 Transmitter Radiated Spurious Emissions (CFR47 FCC Part 15.407 Subpart C, 15.407(b)(4)(9),15.209:07/2021, 15.205:07/2021, Pass 10 Digital Device Radiated Spurious Emissions (CFR47 FCC Part 15 Subpart B 15.109: 07/2021, Pass 11 AC Mains Conducted Emissions FCC 47CFR Part 15.107: 07/2021 Pass 12 Revision History -- Intertek Report Number: 104749253BOX-008 Issued: 10/29/2021 Last Revised: 1/06/2022 Non-Specific Radio Report Shell Rev. December 2017 Page 5 of 58 Client: Starry, Inc. / Model: COMET 24 – 5GHz Radio 3 Client Information This EUT was tested at the request of: Client: Starry, Inc. 38 Chauncy St, Suite 200 Boston, MA 02111 USA Contact: Robert White Telephone: (617) 297-9559 Fax: None E…

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Intertek Report Number: 104749253BOX-008 Issued: 10/29/2021 Non-Specific Radio Report Shell Rev. December 2017 Page 34 of 69 Client: Starry, Inc. / Model: COMET 24 – 5GHz Radio 9.4 Setup Photographs: Test Setup, 9kHz-30 MHz Intertek Report Number: 104749253BOX-008 Issued: 10/29/2021 Non-Specific Radio Report Shell Rev. December 2017 Page 35 of 69 Client: Starry, Inc. / Model: COMET 24 – 5GHz Radio Intertek Report Number: 104749253BOX-008 Issued: 10/29/2021 Non-Specific Radio Report Shell Rev. December 2017 Page 36 of 69 Client: Starry, Inc. / Model: COMET 24 – 5GHz Radio Test Setup, 30-1000 MHz Intertek Report Number: 104749253BOX-008 Issued: 10/29/2021 Non-Specific Radio Report Shell Rev. December 2017 Page 37 of 69 Client: Starry, Inc. / Model: COMET 24 – 5GHz Radio Test Setup 1-18 GHz Intertek Report Number: 104749253BOX-008 Issued: 10/29/2021 Non-Specific Radio Report Shell Rev. December 2017 Page 38 of 69 Client: Starry, Inc. / Model: COMET 24 – 5GHz Radio Scan, 18-40 GHz