BCR-M5B8019Main Remote Unit - Booster

Andrew Corporation 108 Rand Park Drive Garner, NC U.S.A. 27529 Tel: (919) 771-2570 Fax: (919) 771-2360 www.andrew.com 1 June 2007 Equipment Authorization Division Federal Communications Commission 7435 Oakland Mills Road Columbia, MD 21046 FCC ID: BCR-IONM5BD Product Name: ION-M Request for Confidentiality Pursuant to Sections 0.457 and 0.459 of the commission’s rules, we hereby request that the following documents be held confidential: • Schematics o control board circuit diagram.pdf o OTRX NY RX Circuit diagram.pdf o OTRX NY TX Circuit diagram.pdf o RF500862A main schematic.pdf o RF500944A control schematic 1900-2100.pdf o RF501037B Contr. 800-900 schematic.pdf o RF501038A 800-900 schematic.pdf • Manual o Manual ION-M80-85P_19P.pdf o Manual ION-M90_17P EU.pdf • Datasheet o ION-M8_9_17_19_D.pdf • Block Diagram o Block diagram ION-M80-85P_19P.pdf o Block diagram ION-M90_17P.pdf • BOM’s o BoM_ION-M80-85P_19P.xls o BoM_ION-M90_17P.xls These materials contain trade secrets and proprietary information and are not customarily released to the public. The public disclosure of this information might be harmful to the company and provide unjustified benefits to our competitors. The manual is only provided for use by trained technicians and is not available to the general user from Andrew’s website. Dated this 1 Day of June 20 07 By: Michael Williamson Signature Printed Title: Product Manager On behalf of : Andrew Corporation Telephone: (919) 329 8941

Andrew Corporation 108 Rand Park Drive Garner NC 27529 Tel: (919) 329-8941 Fax: (919) 329-8950 www.andrew.com 17 October, 2006 Attn: Director of Certification Authority to Act as Agent I appoint Tom Tidwell, National Technical Systems to act as our agent in the preparation of this application for equipment certification. I certify that submitted documents properly describe the device or system for which equipment certification is sought. I also certify that each unit manufactured, imported or marketed, as defined in Industry Canada’s regulations will have affixed to it a label identical to that submitted for approval with this application. For instances where our authorized agent signs the application for certification on our behalf, I acknowledge that all responsibility for complying with the terms and conditions for Certification, as specified by American TCB, still resides with Andrew Corporation, 108 Rand Park Drive, Garner, NC 27529. Dated this _17 th _day of _October_, 2006__. Agency Agreement Expiration Date: 17 October, 2007 By: __________________________ Michael Williamson (Signature) (Print name) Title: Product Manager On behalf of: Andrew Corporation Telephone: 919-329-8941

NATIONAL TECHNICAL SYSTEMS www.ntscorp.com 1701 East Plano Parkway, Suite 150 • Plano, Texas 75074 (972) 509-2566 • (877) 717-2687 • Fax (972) 509-0073 August 18, 2007 Andrew Corporation Attn. Michael Williamson 108 Rand Park Drive Garner, NC 27529 Re. BRC-IONM5BD This is to notify you that the following FCC rule parts apply to the equipment referenced above. The referenced equipment and its installation must meet all of the criteria contained in these rule parts. § 22.383 In-building radiation systems. Licensees may install and operate in-building radiation systems without applying for authorization or notifying the FCC, provided that the locations of the in-building radiation systems are within the protected service area of the licensee's authorized transmitter(s) on the same channel or channel block. § 90.219 Use of signal boosters. Licensees authorized to operate radio systems in the frequency bands above 150 MHz may employ signal boosters at fixed locations in accordance with the following criteria: (a) The amplified signal is retransmitted only on the exact frequency(ies) of the originating base, fixed, mobile, or portable station(s). The booster will fill in only weak signal areas and cannot extend the system's normal signal coverage area. (b) Class A narrowband signal boosters must be equipped with automatic gain control circuitry which will limit the total effective radiated power (ERP) of the unit to a maximum of 5 watts under all conditions. Class B broadband signal boosters are limited to 5 watts ERP for each authorized frequency that the booster is designed to amplify. (c) Class A narrowband boosters must meet the out-of-band emission limits of §90.209 for each narrowband channel that the booster is designed to amplify. Class B broadband signal boosters must meet the emission limits of §90.209 for frequencies outside of the booster's design passband. (d) Class B broadband signal boosters are permitted to be used only in confined or indoor NATIONAL TECHNICAL SYSTEMS www.ntscorp.com 1701 East Plano Parkway, Suite 150 • Plano, Texas 75074 (972) 509-2566 • (877) 717-2687 • Fax (972) 509-0073 areas such as buildings, tunnels, underground areas, etc., or in remote areas, i.e., areas where there is little or no risk of interference to other users. (e) The licensee is given authority to operate signal boosters without separate authorization from the Commission. Certificated equipment must be employed and the licensee must ensure that all applicable rule requirements are met. (f) Licensees employing either Class A narrowband or Class B broadband signal boosters as defined in §90.7 are responsible for correcting any harmful interference that the equipment may cause to other systems. Normal co-channel transmissions will not be considered as harmful interference. Licensees will be required to resolve interference problems pursuant to §90.173(b). Kindest Regards, Tom Tidwell Manager of Wireless Services National Technical Systems

August 5, 2007 RE: Andrew Corporation FCC ID: BCR-RPT-ION5BD After a review of the submitted information, I have a few comments on the above referenced Application. Depending on your responses, kindly understand there may be additional comments. 1) For the 2 uploaded block diagrams, one received was actually a manual. From reviewing the file names and confidentiality letter we are missing the following file: “Block diagram IONM90_ 17P.pdf”. Please provide. Please find the required file attached. 2) Generally the FCC desires to see top and bottom of all boards for internal photographs. It appears that most boards are only provided for one side. Please review. The boards all have only one side with components and traces. The reverse side connects directly to heat sink to prevent the boards from over heating so there are no components or traces. 3) Due to internal structure, it is uncertain if all RF internal photographs have been provided. First impression and comparing to the manual suggests photographs may only be for the extension unit. Please explain, confirm, or update as necessary. Please find revised internal and external photo files with the photos appropriately labeled. 4) FYI....In the future, kindly consider labeling the various internal photographs to make review simplier. Please find revised internal and external photo files with the photos appropriately labeled 5) The FCC ID on the label, cover letters, etc. provided (BCR-IONM5BD) does not match the information given on the 731 form (BCR-RPT-IONM5BD), information uploaded to our site, test report, etc. It seems there is a mis-match of information throughout the filing. Please correct. The correct FCC ID is BRC-IONM5BD. A revised application form is provided. 6) IC labeling expects the model to match as certified. The label does not appear to contain “IONM80/9/17/19”. The test report and operational description suggests that maybe 3 separate models under the 1 ID should be listed. If so, please clarify which IC listing specifications go with which model. Please review. There should be two models for IC (IONM80/19 and IONM9/17). This is congruent with the two physical units that are active devices. 7) Information (i.e. operational description, etc) suggests the 935 – 941 MHz is an EU band only for GSM. Please explain and/or justify use of this band in the U.S. and if necessary adjust the application as appropriate (i.e. test report, 731 form, etc.). May this is intended for FM emissions only in U.S.? The 935 – 941 MHz band is a licensed band under FCC Part 90, Subpart S and the channels are Industrial/Business and SMR Pool allocations. There are no restrictions on the type of emissions authorized in this band. iDEN modulation (QAM) is usually used in this band, hence the DXW. 8) It is unsure if the 1900 MHz TX schematics (other than control board) have been provided. Please review. Please find the schematics for the 1900 MHz band rf circuits attached. 9) It appears that the extension and coupler units are partially contained in separate enclosures. Note that this application will only be valid for the particular loaded system (i.e. one main unit, one extension unit, and one combining unit) as defined in this application. It appears that the labeling of the individual units may be more appropriate and give greater flexability without relabeling. Does the applicant understand this? For instance, FCC guidance cites the following which would appear to apply to the extension unit: - active interface unit a) amplifies uplink signal from host unit for transmit by donor antenna b) attenuates downlink from donor antenna c) coax cable connection between host and active interface unit d) usually has separate FCC ID; in some cases could be combined/included with host as one enclosure and Single or multiple FCC IDs – One FCC ID per transmitter enclosure or rack, not per system. Generally, if one FCC ID is being used, this would assume that all units are always paired together. Depopulation (i.e. removal of the extension unit) is not necessarily covered. Additionally, since these are in separate enclosures, it would seem that 2 FCC ID’s would be applicable (one for each active unit). See attached guidance for more detail. Please explain and/or correct as necessary. We believe that these units should be approved together since they always operate and are installed as a system. If the extension unit bands are not used then they would simply not be installed but this would in no way effect the operation of the main unit because the main unit determines that an extension unit is not present and will not route 900/1700 band rf signals that it may detect at its optical input. We believe that the extension unit would not require its own FCC ID number since it cannot operate without the main unit. The extension unit does not contain any means of converting optical signals to rf signals without being connected to the main unit. Further these units are marketed and sold together as one solution. 10) Generally these types of applications include the following in the grant notes: “Part of RF Distribution System which includes FCC ID: XXXXXX, FCC ID: YYYYYY and/or FCC ID: ZZZZZZ”. Please comment and provide appropriate information necessary for this (i.e. . See (9) above 11) Please include appropriate exhibit or correspondence showing applicant was informed that boosters must meet all criteria stated in Sections 90.219 and 22.383 for related booster/inbuilding operations. Please find enclosed correspondence. 12) Part 90 appears to only allow transmission from 935 – 940 (ref Part 2, 90), not 941 as cited on the 731 form. Note that Narrow Band Part 24 PCS does fall from 940 – 941 MHz, but the report does not appear to support this. Please explain. The correct band should be 935 – 940 MHz as per Part 90, Subpart S. The Form 731 has been corrected. 13) Please justify use of DXW in the 935 – 941 MHz band. The band should be 935 – 940 MHz. There is no restrict…

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1) The previous response to item 6 mentions models IONM80/19 and IONM9/17. Labels still do not support this. It appears the labels show ION-M90/17P and ION-M80-85/19P. IC expects labels to match as Certified. Please explain, correct, review, etc. We have submitted revised application forms and labels to reflect the desired model numbers. We are opening a separate submission for the extension unit. The existing file will apply to the Main Unit. 2) It was noted that the main schematic, 1900 MHz schematics, control schematic 1900 – 2100, control schematic 800-900 MHz, and 800 – 900 MHz schematic only contain reference designators and do not contain appropriate values. Please correct. We have uploaded Bills of Materials for these products with the component values included. 3) Previous comment 10) was actually in relation to any master unit. Please comment. We identify both the Main Unit and the Extension Unit as “Remote” units as described on page 2 of the FCC “Amplifier and Booster Guidance” document. We do not believe the fiber host unit requires FCC ID number since it connects directly to the BTS via coax rather than through an antenna. Since the fiber host unit does not require FCC ID number per the guidance document (page 3 – “reminder sheet items”, we do not believe that the referenced statement is appropriate. 4) Upon further discussion internally, in order to meet the amplifier, repeater, booster requirements it seems that the main unit should be certified under one ID, and the extension unit certified under it’s own FCC ID with grant notes that reference for use with the main unit’s ID. Please see attachment. This is especially true if the extension unit is not always present as given in your response. The FCC has given multiple interpretations over the past few years that doesn’t allow for a single ID to cover the device when TX components are removed or added. If the extension unit was ALWAYS present with the main unit, it may be considered a stretch but may be possible to do under a single FCC ID. If you desire we will be glad to approach the FCC on this specific instance, but currently it appears this should be 2 FCC ID’s. We have provided a corrected Form 731 for the Main unit and have created a new and separate application for the extension unit. 5) Your response mentions that the rf exposure is addressed at the time of licensing. This is not necessarily always the case. For instance see 90.219(e). Additionally, given the antenna gain and output power, it is not certain how the limitations of 90.219 are met. While these devices do not require a new FCC license they do impact the existing license of the BTS installation and so any change that may impact rf exposure must be reported to FCC when the distribution system is installed. The manufacturer is obligated to provide clear information to the installer/user to insure that the installer will install the device to be within the FCC regulations for RF Exposure. We have provided updated install manuals that specifically address the minimum separation distance and antenna gain for all of the intended installation scenarios. The manufacturer provides for two installation configurations – outdoor fixed and indoor fixed. An outdoor fixed installation would have the antenna mounted on an outdoor permanent structure such as a tower or the side of a building. An indoor fixed installation has the antenna fix mounted to a permanent structure indoors. A different minimum separation distance is required for each scenario. We have provided MPE reports for each configuration. 6) Response to previous comment 20 implies that a corrected IC report was supplied. This does not appear to be received. We have uploaded a corrected IC application and test reports.

RE: Andrew Corporation FCC ID: BCR-M5B8019 After a review of the submitted information, I have a few comments on the above referenced Application. Depending on your responses, kindly understand there may be additional comments. 1) Because uploads are now necessary of all documentation to IC, kindly provide a confidentiality letter for the IC related portion of the filing as well. Please find IC confidentiality request 2) For previous comment 2, you cite that a BOM is now provided. However there is not an easy way to cross reference values to reference designators given the information provided (i.e. reference designators do not match). Additionally, now that this application is being divided into 2 applications for the different components, and given the unique nature of the devices, it is uncertain which schematics still apply here fro this application, and which ones should be removed from the application. Please correct and comment on the following schematics: All of the provided schematics are relevant since the signals pass through the main unit (the device in this filing) whether they are going out to the extension unit or directly to the combiner unit. This is why we believed this should one filing. In other words, the control circuits for the extension unit are actually located in the unit for this filing (the 8019 Main unit). 3) While we understand that RF exposure may be handled by licensing for fixed outdoor use, there are some concerns for indoor use since this is typically a mobile category – not fixed for purposes of RF exposure. First, note that RF exposure information was not provided for 850 MHz indoor. Please find RF exposure information for 850 MHz indoor application. When this system is installed indoors it is always in a restricted area that can be secured. In the past FCC has allowed the manufacturer to categorize this as indoor fixed installation instead of mobile. Please explain. Additionally, please note that RF exposure evaluation (i.e. measurements) are required by 2.1091 for < 1.5 GHz range if the ERP is > 1.5 Watts (i.e. EIRP > 2.46 Watts). Currently information provided for 1900 MHz indoor shows and EIRP of 2.512 W. This is acceptable for > 1.5 GHz since this allows for 3.0 Watts ERP (4.92 Watts EIRP), but not for < 1.5 GHz. Please review. This applies to mobile applications which are defined as “designed to be used in other than fixed locations” according to Part 2.1091. This device will never be installed as a mobile installation as defined by the rules. It will be installed in either an outdoor fixed installation or indoor fixed installation. Further, I am unclear how we can perform power meaningful power density measurements without having access to the specific antenna that will be used in the installation. 4) To further comment 3 above, the RF power provided is per RF output per band (as given earlier response). However it appears that all outputs are multi-plexed together to a single antenna – and also may include FCC ID: BCR-M5B9017. If this is the case, please note that RF exposure should consider all Transmitters in its evaluation as appropriate. The minimum separation distance is meant to be between the antenna (which is at the output of the combiner) and nearby persons. The rf power output that would be listed on this grant would go through the same combiner as the associated grant (for the extension unit). Since these are separate filings it is unclear how we should address this. 5) Users manual may be affected by 3 and 4 above. 6) The matrix provided only shows Analogue from 851 – 869, but it appears that F3E on the 731 is shown for both 851 – 869 and 869 – 894 MHz. Please explain. This was simply left off of the matrix as an oversight 7) Test report page 6 and other pages shows iDEN as GXW, but 731 form appears to show this as F1D. Please review/explain. This was an error on the Form 731. I have updated this form. 8) 731 form appears to show TDMA (DXW for 869 – 894), but this is not shown in the matrix. Please explain. This was simply left off of the matrix as an oversight 9) Kindly explain reference to Part 22 500 Watt ERP limit in the test report power section when other information supports 17 dBi antenna which would exceed this level. Even though this type of device may go under an existing license, the installation must still comply with the terms of the license which includes maximum rf power. Since this is not a Part 15 device and thus is not restricted to a specific antenna but only a maximum antenna gain for rf exposure, the rf power output + antenna gain are usually not part of the equipment approval. We should list maximum rf conducted power on the grant, not erp or eirp. 10) For SMR services, it is uncertain if 90 Subpart S compliance has been shown, especially relevant to 90.669 and 90.691. We have clearly shown compliance with the 43+10 log(P) requirement of 90.669 and the -20 dBm limit of 90.691 (on band edges). 11) The RSS-102 attestation appears to miscalculate the value shown. (Note: 10 W/m^2 = 1 mW/cm^2). Value would appear to be 5 W/m^2. Please find a corrected attestation 12) Despite the fact that FCC only requires worse case to be reported, IC generally requires a low, middle, and high channel – see RSS-GEN Section 4.3. Has low, middle, and high been investigated so that a statement can be made about such tests as power, spurious, etc? The RSS 131 standard does not require this. The rf power output is measured using two CW tones and spurious emissions is measured using the same two tones. This is not a transmitter but a wideband amplifier system without channel filtering. We simply followed the requirements listed in the RSS 131 standard. 13) FYI....Kindly use the most recent IC Form in the future. It appear you used Rev. 9, while current revision if Rev. 14. I have resubmitted the IC form using the newest revision.

RE: Andrew Corporation FCC ID: BCR-M5B8019 After a review of the submitted information, I have a few comments on the above referenced Application. Depending on your responses, kindly understand there may be additional comments. 1) There is still a disconnect of component values on several schematics. We either need to ensure that all schematics contain appropriate component values, or if a BOM is used in conjunction with the schematics that the designation for components matches so component values can be determined. Currently the designation on the schematics does not match designation on the BOM. Please correct. Please find enclosed schematics with the component values listed on the schematics. There are four schematics included: 1) RF00862A main schematic – This is the rf schematic for the PCS and AWS bands. 2) RF5001944A control schematic 1900-2100 – This is the schematic for the electronic circuits that control the amplifiers for PCS and AWS bands. 3) RF501037B Contr. 800-900 schematic – This is the schematic for the electronics that control the amplifiers for the 800 and 900 MHz bands (AMPS, SMR, PMR) 4) RF501038A 800-900 schematic – This is the rf schematic for the 800 and 900 MHz bands (AMPS, SMR, PMR). 2) Regarding MPE, note that you reference the FCC allows for indoor fixed installation. This may be allowed, but note that what we are concerned with is the location of the antennas and not the unit itself. For instance, if antenna can be located in hallways of buildings, depending on the building, this may only meet 20 cm requirements (i.e. I’ve seen leaky coax installaions for subways and underground shopping areas where the cable is placed at head height along stairwells and initial cable runs and certain hallways and therefore these situations would be subject to mobile classification). Remember that mobile classification is simply meaning that the EUT to user antenna distance only meets a 20 cm distance and does not actually deal with the logical meaning of the word mobile (such as device as movable or mounted in position). Without fully understanding antenna types, gains, and installation procedures which clearly show/explain how antennas are mounted indoor, 20 cm would seem reasonable. If you wish to adjust this for fixed indoor installation (referring to antenna locations), please provide further information regarding types of antennas, user installation instructions to support this, etc. Typically there is information showing how antennas must be mounted on permanent indoor structures and located in such a way that their antennas meet minimum spacing requirements (as shown in appropriate MPE calculations – however this must take into consideration all RF output from the antenna, not just a band – see 3) below). Otherwise we will continue based on the information provided for indoor mobile operation. You may wish to clarify what is meant by an indoor fixed installation (i.e. in these situations where is the antennas mounted). If the antennas are still mounted outdoors, on towers or roof tops, etc – then this would be a fixed installation. However if the manufacturer expects to use antennas such as leaky coax (or other indoor antenna installations) to be used in subway runs, underground areas, tunnels, inside buildings, etc. – then many of these situations could be deemed mobile installations unless detailed installation information clearly shows otherwise. Please clarify. Note: Generally speaking FCC has stated that Pico-base stations, Micro-base stations and other fixed-mounted transmitters operating with indoor antenna(s) meet MPE Categorical Exclusion Limits established in §2.1091. If not, it must be clear how antenna to user installation is ensure to meet with necessary distances. Since this is a licensed device the type of antenna used is not defined by the equipment manufacturer. I am not sure how we can predict the MPE without a clear definition of the antenna(s). This is the reason we included maximum antenna gain and separation distance in the installation manual. In the case of leaky coaxial cable the loss associated with the propagation characteristics of this type of radiator would correlate to an “antenna gain” of about -50 dBi. My contention is that RF Exposure is dealt with as part of the site licensing procedure and that we must demonstrate for equipment authorization that the device can meet rf exposure requirements if properly installed (i.e. that the user manual does not recommend any installation that would violate the rf exposure rules. 3) Depending on 2) above, if mobile installations will exist or fixed indoor antenna installations, then MPE must consider all possible RF output for purposes of its calculations. For instance you would calculate maximum RF exposure of all RF power out of a single antenna and using the same distance in each equation (much as has already been provided in the MPE exhibits. However you must then take this one step further and show that the sum of the ratios of density to the respective limits is < 1 such as: Power Density1/Limit1 + Power Density2/Limit2 + repeat for n number of outputs.... < 1 Given the current ratio shown (i.e. 800 MHz is about 0.87 or 87%, and 1900 MHz is about 0.50 or 50%, the sum is > 1 or 100%). Note that this calculation must be for the worse case sum of all possible RF into a single antenna element. Again this has to be dealt with under the site license and this product should not be seen as mobile installation as relates to the method of installation OR minimum separation distance from nearby persons. 4) While we understand your concern regarding previous comment 9, kindly understand that if a 17 dBi gain antenna was to be used and the maximum output utilzied, then the ERP limitations are exceeded. We will assume that the 17 dBi gain is this just a value selected for purposes of showing compliance to various limitations (i.e. RF exposure, EIRP or ERP)? You are correct that for this type of device a…

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This report and the information contained herein represent the results of testing test articles identified and selected by the client performed to specifications and/or procedures selected by the client. National Technical Systems (NTS) makes no representations, expressed or implied, that such testing is adequate (or inadequate) to demonstrate efficiency, performance, reliability, or any other characteristic of the articles being tested, or similar products. This report should not be relied upon as an endorsement or certification by NTS of the equipment tested, nor does it represent any statement whatsoever as to its merchantability or fitness of the test article, or similar products, for a particular purpose. This report shall not be reproduced except in full. NTS Plano, 1701 E. Plano Pkwy., Plano, TX 75074 Tel: (972) 509-2566, Fax: (972) 509-0073 Page 1 of 89 Certification Test Report CFR 47 FCC Part 2 Part 22, Subparts C and H Part 24, Subparts C and E Part 90, Subparts I and S Model: ION-M80-85/19P FCC ID NO.: BCR-M5B8019 Project Code: W7197-2 Revision: 0 Prepared for: Andrew Corporation 108 Rand Park Drive Garner, North Carolina 27529 Author: Tom Tidwell, Manager of Wireless Services Issued: 13 September, 2007 1701 E. Plano Parkway, Suite 150 Plano, Texas 75074 Phone: (972) 509-2566 Fax: (972) 509-0073 Model: ION-M80-85/19P Compliance Test Report FCC ID. BCR-M5B8019 This report and the information contained herein represent the results of testing test articles identified and selected by the client performed to specifications and/or procedures selected by the client. National Technical Systems (NTS) makes no representations, expressed or implied, that such testing is adequate (or inadequate) to demonstrate efficiency, performance, reliability, or any other characteristic of the articles being tested, or similar products. This report should not be relied upon as an endorsement or certification by NTS of the equipment tested, nor does it represent any statement whatsoever as to its merchantability or fitness of the test article, or similar products, for a particular purpose. This report shall not be reproduced except in full. NTS Plano, 1701 E. Plano Pkwy., Plano, TX 75074 Tel: (972) 509-2566, Fax: (972) 509-0073 Page 2 of 89 Report Summary NTS Plano Accreditation Numbers: FCC: 101741 IC: 46405-4319 File # IC-4319A-1 Applicant: Andrew Corporation 108 Rand Park Drive Garner, North Carolina 27529 Customer Representative: Michael Williamson EUT Description: EUT Description Manufacturer Model Revision Serial Number The EUT is a multi-operator remote unit used in conjunction with a master unit in the ION optical distribution system. Andrew W…

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