IHDT6ND1

MOTOROLA, INC. July 8, 1998 Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, Maryland 21046 Re:Request for Additional Technical Information, received by E-Mail on July 1, 1998, regarding pending Application for Type Acceptance, FCC ID: IHDT6ND1, [Correspondance ID: 1670]. Dear Mr. Coperich: In response to item 1 of the above request, to supplement the test report with a direct reference to the emission limits under Section 25.200(b) of the (proposed) Commission's R&R, the equipment was tested for compliance to those limits and this is specified in the Measurement Procedures (Exhibit 12, reference Exhibit 12-2 for conducted and Exhibit 12-3 for radiated) as well as in the text below the graphs of the Exhibit 9C series. This information has been added to the REVISED Exhibit 9D graph being submitted per below. While there is not a specific reference that these are the 25.200(b) proposed limits, they are the limits. If it is necessary to include specific reference to 25.200(b) in these Exhibits, please advise and this will be done. In response to item 2 of the above request, an indication of the highest frequency measured for radiated spurious emissions, the highest measurement frequency was indeed 16.3 GHz, which includes at least the 10th Harmonic of the highest fundamental frequency (based on the upper Carrier Frequency of 1626 MHz). This refers to Exhibit 9D. The oversight of indicating Frequency along the x-axis only to 10000 MHz (10 GHz) is noted, however, in the text below the graph, the following statement is made "Spectrum search performed from 30 MHz to16.3 GHz (10X Carrier Frequency)." Additional units have been produced and tested since the testing of the prototype that was used to produce the data in these test reports. Several Radiated Emissions, harmonics of the carrier, have become "reportable" emissions over design iterations, variations in production and component characteristics. Please accept the enclosed REVISED Exhibit 9D which shows an "inclusive" x-axis Frequency range (to 100000 MHz) and the additional "reportable" emissions. In response to item 3 of the above request, which requests "measurement report for SAR levels responding to Section 2.1093 of the Commission's R&R", this testing has been done and the transceiver is compliant but we have not yet been successful in attempts to format this report to be electronically submitted. Please advise if it will still be acceptable to submit this report as "hard copy" and to whom that should be addressed. I trust that, pending submittal of the "SAR report," this will satisfy the request and allow the Grant to be issued for this equipment. Please contact me by telephone at (847) 523-7373 or by facsimile at (847) 523-2350 if there are any further questions or additional information needed concerning this filing and/or this reply. Regards, John A. Kalenowsky Patent Engineer/FCC Liaison Cellular Subscriber Sector cc:File

To: Kwok Chan, Federal Communications Commissioncc: John Kalenowsky From: Paul Moller Date: July 8, 1998 Subject: FCC ID IHDT6ND1 Kwok, This memo is in further response to the request for “measurement data showing compliance with the SAR requirement” for Motorola FCC ID IHDT6ND1 reference ID number 1670 requesting additional data dated July 1, 1998. 1) Figure 3 shows the orientation of the subject phone with respect to the scan area as shown in the SAR contour plots. In summary, the 0,0 location on the plots is always chosen to be the center of the ear of the phantom. The center of the ear piece of the phone is also located at this position. The phone thus extends in the –X direction, with the center line of the phone aligned with a line connecting the center of the ear and the center of the mouth. I am also including an excerpt from the Motorola internal document “Motorola Cellular Electromagnetics Lab SAR Measurement Procedure” titled Phone Positioning and Scan Area for further reading. 2) The phone is placed as close to the phantom head as possible and also consistent with the intended use position as identified in the Motorola users manual for the subject phone. I have measured the distance from the test phantom to three locations on the subject phone. They are as follows. As a point of reference, the phantom’s ear is 5 mm thick at the top of the ear, which is intended to simulate the ear of an actual user of a cellular phone. Figures 1 and 2 show the phone positioned on the phantom for the antenna in the retracted and extended positions respectively. See the figures on the next page. The following are some distances measured from the phantom to the phone as positioned in figures 1 and 2. a) Phantom to center of earpiece of phone: 13 mm b) Phantom to body of phone at the top of the phone: 24 mm c) Phantom to retracted antenna: 52 mm d) Phantom to extended antenna: 57 mm Figure 1 Figure 2 3) The subject phone was tested only in the left side talk position and held in a position as described in the Motorola users manual. The unit is equipped with a telescoping quadrifilar helix antenna that serves as both a receive and transmit antenna. The operation of the Iridium™ system is such that the subscriber unit must be in communication with satellites in low earth orbit. This means that the subscriber units antenna must have a clear view of the sky above the users head at all times. Thus the antenna is designed so as to have three positions. The first position is the “stowed” position where the antenna is rotated behind the subscriber unit. In this position the user would not be able to place or receive a phone call. This position is available for convenience of storage. The second position is the “retracted” position where the antenna is pointed towards the zenith, but is kept in its shortened telescoping dimension. The third position is were the antenna is also pointed towards the zenith, but is in its long telescoping dimension referred to as the “extended position”. Furthermore, the antenna can rotate to either of two detented positions which are roughly 30 degrees to the left and roughly 30 degrees to the right. These are intended to keep the antenna pointed to the zenith in both the left and right handed talk positions. Figures 3 and 4 show the unit configured for left handed talk position, in the extended and retracted positions respectively. Figure 3Figure 4 Due to the design of the antenna, the RF currents that contribute most to the SAR measurement are the currents at the base of the antenna. Due to the construction of phone and antenna mast, the base of the antenna is always at least several centimeters away from the users head. Also, since the antenna is mounted at the center of the phone, the location level of highest SAR is essentially the same for both the left and right side talk positions. Any differences between left and right side that show up are within measurement error, and are more controlled by phone positioning than by any real left / right difference. 4) The tissue simulant used is a sugar, water, salt solution. It has a relative dielectric constant of 40 and a conductivity of 1.58 S/m at 1621 MHz. This is accomplished by using the following percentages of materials by weight: a) water: 47.3% b) sugar: 51.6% c) salt 0% d) HEC (a gelling agent): 1.0% e) Dowicil 75 (anti-bacterial compound): 0.1% 5) I am including a copy of the draft titled “Electromagnetic Energy Exposure of Simulated Users of Portable Cellular Telephones, dated December 1997 written by Dr. Q. Balzano of the Motorola Florida Corporate Electromagnetics Research Laboratory, dated December 1995. This document will explain in detail the test methodology, SAR formulas, and tissue materials that were used for the SAR testing of the subject phone. 6) I have an estimate of the possible errors that we have in the measurement system. The breakdown of the individual errors is as follows: Error (%) a) Measurement of the conductivity of the tissue simulant±3% b) Temperature rise calibration of probe±5% c) Measurement of thermal capacity of tissue simulant±5% d) Accuracy of a repeatable phone position±1% e) Probe isotropic response±12% Since it is statistically unlikely that any of the errors are correlated, it is reasonable to use a Root- Sum-Squared calculation to estimate the total error. Using this method I calculate a likely error of ±14.3%, or about ±15%. If you have any further questions please give me a call at 847-523-5210. Paul Moller

SAR Measurement SAR Measurement OPERATIONAL GUIDE FLORIDA CORPORATE ELECTROMAGNETICS RESEARCH LABORATORY FORT LAUDERDALE, FLORIDA - December 1997 - Florida Corporate Electromagnetic Research Laboratory 2 Table of Contents 1.0 Introduction 2.0 SAR Measurement System 2.1.0 E-Field Probe 2.1.1 Isotropic E-field Probe 2.1.2 Angular Response Outputs 2.2.0 Instrumentation Amplifier 2.2.1 Views of Instrumentation Amplifier 2.2.2 Diagram of Instrumentation Amplifier and Battery Supply 2.3.0 High Impedance Cables 2.4.0 Robotic Arm 2.4.1 View of Robotic Arm 2.5.0 Arm Extension 2.5.1 View of Arm Extension 2.6.0 Probe Holder 2.6.1 Cross-section of Probe Holder 2.7.0 Computer System 3.0 SAR Measurement System Calibration 3.1.0 Determine E-field from Amplified Probe Outputs 3.1.1 Method 3.1.1.a Amplifier Setting Calibration Setup 3.1.2 Measurement 3.2.0 SAR from Temperature Measurement and Correlation to E-field Probe 3.2.1 Measurement 3.2.1.a Flat Phantom, Thermistor and E-Probe 3.2.1.b Correlation of E-field and Temperature Measurements 3.2.1.c Field Attenuation in Simulated Tissue 3.2.2 Determination of SAR Conversion Factor 4.0 Data Acquisition Methodology 4.1.0 E-field Measurement 4.2.0 SAR Measurement 4.3.0 Data Extrapolation 4.4.0 Data Interpolation and Gram Averaging Florida Corporate Electromagnetic Research Laboratory 3 Table of Contents continued 5.0 Phantoms 5.1.0 Phantom Shells 5.2.0 Simulated Tissue 5.2.1 Preparation 5.2.1.a Simulated Tissue Ingredients 5.2.2 Electrical Characteristics Measurement 5.2.2.a Equipment Used for Electrical Characteristics Measurement 5.2.2.b Simulated Tissue Electrical Characteristics: Measured Data 5.2.2.c Simulated Tissue Electrical Characteristics: Plotted Data 5.2.2.d Dielectric Constant and Conductivity at Several Frequencies 5.2.3 Determining Relative Dielectric Constant and Effective Conductivity 5.2.3.a Table Comparing Mixture Analysis Methods 5.3.0 Determining the Heat Capacity of Simulated Tissue 5.3.1 Instruments and Materials 5.3.2 Method 5.3.3 Rationale Appendix A. Wire Stripper A.1 Wire Stripper Design B. Cable Construction B.1 Details of High-impedance Cable Construction C. Definition Amplifier Setting and Other Terms D. Units and Various Calibration Factors E. Derivation of Extrapolation Method F. Complex Permittivity Measurements F.1 Rigorous Method G. Error Analysis (in preparation) Note: This manual is intended as a supplement to the complete training course in SAR measurement given to Motorola personnel responsible for SAR evaluations. Although every effort has been made to be factually correct, the suitable application of the instruments and techniques described in this manual require hands-on training and practice. This report was compiled from materials written and developed by the staff of the Florida Corporate Electromagnetics Research Laboratory. The principal authors are Oscar M. Garay and Quirino Balzano. Important contributions were provided by the entire AC497 team. Asher Sheppard (Asher Sheppard Consulting, Redlands, CA) assisted materially with editorial and technical matters. The authors gratefully acknowledge the excellent secretarial and graphic arts support from Esther Scott. Florida Corporate Electromagnetic Research Laboratory 4 FLORIDA CORPORATE ELECTRONICS RESEARCH LABORATORY 1.0 Introduction The increasing popularity of mobile phones and radios has been accompanied by a growing concern for possible health effects from radio frequency (RF) emissions of these and other transmitting devices. There is special interest in hand-held units where the radiating antenna is in close proximity to the user’s head or body. It is unavoidable that some RF energy is absorbed by the user, usually by the parts of the body closest to the antenna. The requirement for accurate quantification of electromagnetic fields inside the body of a user of these devices has grown during the last few years. When a radio wave at the frequencies used for wireless communications encounters a person, some of the wave is reflected; only a portion will enter the body. The precise proportions of absorbed, reflected and transmitted energies depend on the frequency of the wave and the electrical characteristics of the biological tissue. Research regarding the biological effects of radio and microwave radiation has been in progress for several decades and there are a large number of published studies. The only well understood and widely accepted effect of RF exposure of biological tissue at VHF and UHF is heating. Radio frequency electromagnetic dosimetry is the quantification of the magnitudes and distribution of absorbed energy within biological objects that are exposed to RF radiation. Dosimetry for RF is significantly more complex than for radiation of much higher frequencies, such as infrared, light, ultraviolet, and ionizing radiation. It is usually sufficient to characterize the intensity of the external exposure wave in terms of dose or dose rate. At radio frequencies the dosimetric quantity, Specific Absorption Rate (SAR), is defined as the rate at which energy is absorbed per unit of mass per unit of time (e.g. in units of W/kg). The SAR is determined not only by the characteristics of the external electromagnetic waves, but also the electrical and geometric characteristics of the exposed subject. SAR distributions are usually measured in human models or animal tissues, or are determined mathematically. Two methods are available: (1) Electric field measurement. Because the SARis related to the internal electric field strength (E) as well as the electric conductivity and the mass density of tissues, it can be measured by small E-field probes. (2) Temperature measurement. The initial rate of temperature rise in an exposed object is a function of SAR so that implantable RF-transparent temperature probes also may be used to measure localized SARs. The definition of Specific Absorption Rate is the time derivative of the incremental energy (dW) absorbed by (…

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File : /idx3/system/sarmeas2/data/Proto/iridhiZ.VLT Start : 15-Apr-98 10:07:46 am End : 15-Apr-98 10:19:11 am Radio Type : Iridium Model Number : SWF3178A Serial Number : prototype Frequency : 1621 MHz Output Power : .6W averaged Antenna Type : Cicular Antenna Posn. : In Phantom Type : Head Phantom Posn. : Left Ear Scan Type : ZOOM/SAR Probe Name : p026 Field Type : E Field Orientation : 0 Degrees Mixture Type = Brain Mixture Dielectric Constant = 40.00 Mixture Conductivity = 1.580 Comment : Iridium phone head phantom; left ear antenna in the retracted position. Robot : Robot Probe Offset = 0.29 cm Sensor Factor = 0.0108 Conversion Factor = 0.801 p026 Amplifier Channel Settings : 0.305 0.284 0.259 Max Location : X = -4.250, Y = 0.000, Z = 0.000 (cm) Value = 4.246 Measured Values (volts) = 3.488E-003 3.017E-003 2.913E-003 2.197E-003 2.809E-003 1.870E-003 2.033E-003 2.741E-003 2.902E-003 2.835E-003 2.183E-003 Peak Voltage = 0.0039 1 cm Voltage = 0.0023 SAR (mW/g) = 0.2296

File : /idx3/system/sarmeas2/data/Proto/irid1hoA.VLT Start : 15-Apr-98 09:37:47 am End : 15-Apr-98 09:44:29 am Radio Type : Iridium Model Number : SWF3178A Serial Number : prototype Frequency : 1621 MHz Output Power : .6W averaged Antenna Type : Circular Antenna Posn. : Out Phantom Type : Head Phantom Posn. : Left Ear Scan Type : AREA Probe Name : p026 Field Type : E Field Orientation : 0 Degrees Mixture Type = Brain Mixture Dielectric Constant = 40.00 Mixture Conductivity = 1.580 Comment : Iridium phone head phantom; left ear antenna in the extended position. Robot : Robot Probe Offset = 0.29 cm Sensor Factor = 0.0108 Conversion Factor = 0.801 p026 Amplifier Channel Settings : 0.305 0.284 0.259 Max Location : X = -1.000, Y = 1.000, Z = 0.000 (cm) Value = 4.723 Area too wide. SAR value not calculated. Will be calulated in zoom scan.

File : /idx3/system/sarmeas2/data/Proto/iridhiA.VLT Start : 15-Apr-98 10:01:09 am End : 15-Apr-98 10:07:46 am Radio Type : Iridium Model Number : SWF3178A Serial Number : prototype Frequency : 1621 MHz Output Power : .6W averaged Antenna Type : Circular Antenna Posn. : In Phantom Type : Head Phantom Posn. : Left Ear Scan Type : AREA Probe Name : p026 Field Type : E Field Orientation : 0 Degrees Mixture Type = Brain Mixture Dielectric Constant = 40.00 Mixture Conductivity = 1.580 Comment : Iridium phone head phantom; left ear antenna in the retracted position. Robot : Robot Probe Offset = 0.29 cm Sensor Factor = 0.0108 Conversion Factor = 0.801 p026 Amplifier Channel Settings : 0.305 0.284 0.259 Max Location : X = -4.000, Y = 1.000, Z = 0.000 (cm) Value = 4.510 Area too wide. SAR value not calculated. Will be calculated in zoom scan.

File : /idx3/system/sarmeas2/data/Proto/irid1hoZ.VLT Start : 15-Apr-98 09:44:29 am End : 15-Apr-98 09:56:07 am Radio Type : Iridium Model Number : SWF3178A Serial Number : prototype Frequency : 1621 MHz Output Power : .6W averaged Antenna Type : Circular Antenna Posn. : Out Phantom Type : Head Phantom Posn. : Left Ear Scan Type : ZOOM/SAR Probe Name : p026 Field Type : E Field Orientation : 0 Degrees Mixture Type = Brain Mixture Dielectric Constant = 40.00 Mixture Conductivity = 1.580 Comment : Iridium phone head phantom; left ear antenna in the extended position. Robot : Robot Probe Offset = 0.29 cm Sensor Factor = 0.0108 Conversion Factor = 0.801 p026 Amplifier Channel Settings : 0.305 0.284 0.259 Max Location : X = -2.000, Y = 2.000, Z = 0.000 (cm) Value = 4.638 Measured Values (volts) = 3.793E-003 2.652E-003 2.292E-003 2.561E-003 1.813E-003 1.280E-003 2.748E-003 3.443E-003 3.237E-003 3.281E-003 2.992E-003 Peak Voltage = 0.0044 1 cm Voltage = 0.0025 SAR (mW/g) = 0.2560

To: Kwok Chan / Frank Coperich, Federal Communications Commissioncc: John Kalenowsky From: Paul Moller Date: July 30, 1998 Subject: FCC ID IHDT6ND1 Kwok / Frank, This memo is in response to “Questions regarding the SAR report portion of your filing” for FCC ID IHDT6ND1, correspondence ID 2054, received via email on July 20, 1998. Please accept the following revised paragraph 3 (additions and changes shown in italic) and supplemental paragraph 7. 3) The subject phone was tested only in the left side talk position and held in a position as described in the Motorola users manual. The unit is equipped with a telescoping quadrifilar helix antenna that serves as both a receive and transmit antenna. The operation of the Iridium™ system is such that the subscriber unit must be in communication with satellites in low earth orbit. This means that the subscriber units antenna must have a clear view of the sky above the users head at all times. Thus the antenna is designed so as to have three positions. The first position is the “stowed” position where the antenna is rotated behind the subscriber unit. In this position the user would not be able to place or receive a phone call. This position is available for convenience of storage. The second position is the “retracted” position where the antenna is pointed towards the zenith, but is kept in its shortened telescoping dimension. The third position is were the antenna is also pointed towards the zenith, but is in its long telescoping dimension referred to as the “extended position”. Furthermore, the antenna can rotate to either of two detented positions which are roughly 30 degrees to the left and roughly 30 degrees to the right. These are intended to keep the antenna pointed to the zenith in both the left and right handed talk positions. Figures 3 and 4 show the unit configured for left handed talk position, in the extended and retracted positions respectively. Due to the design of the antenna, the RF currents that contribute most to the SAR measurement are the currents at the base of the antenna. Due to the construction of phone and antenna mast, the base of the antenna is always at least several centimeters away from the users head. Thus the RF currents on the face of the phone are very low and the resulting SAR is dominated by the RF currents at the base of the antenna. Since the base of the antenna is several centimeters from the user, the maximum SAR is low enough so as to be difficult to measure. Also, since the antenna is mounted at the center of the phone, the location level of highest SAR is essentially the same for both the left and right side talk positions. Any differences between left and right side that show up are within measurement error, and are more controlled by phone positioning than by any real left / right difference. 7)The peak power of the probe and measurement system measure the average of the RF signal that is generating the SAR. In the case of the subject phone, the average power is 0.6 Watt which is well within the linear range of the probe. In order to measure the average value of the RF signal, the measurement system measures over a time period long enough to capture two pulses of the 11 Hz signal. The sampling speed is then increased until the peak to average ratio of the SAR reading is the same as the peak to average ratio of the actual RF envelope. This ensures that the measured average RF level is correct. If you have any further questions please give me a call at 847-523-5210. Paul Moller

APPLICANT: MOTOROLA, INC. FCC ID: IHDT6ND1 REVISED EXHIBIT 9D TRANSMITTER RADIATED EMISSIONS, MAX LEVELS OF CHANNELS #3, 120, 238 Carrier Power: 7 W max (+38.45 dBm), .645 W average (+28 dBm) Carrier Frequency: 1616 to 1626.5 MHz (240 Channels) Channels Tested: Channels #3, #120, and #238 *Emissions greater than 20 dB below the spec were not reported SSTG EMC Group *Spectrum search performed from 30 MHz to 16.3 GHz (10X Carrier Frequency) 7/7/98 5:01 PM -80 -70 -60 -50 -40 -30 -20 -10 0 100 1000 10000 100000 Frequency (MHz) Spurious Level (dBc) Spec Limit (7W) = -51.45 dBc (-14.25 dBm) (2nd, -59.5 dBc) (3 rd, -54.7 dBc) CARRIER 252 431.6 860 (5 th, -60.3 dBc) (6th, -62 dBc) (7th, -70 dBc) (8th, -70.5 dBc)