LLB10051MTRANSMITTER FOR METER READING

October 20, 2005 HEXAGRAM, Inc. 23905 Mercantile Rd. Cleveland, OH 44122 216-464-1057 Federal Communications Commission Office of Engineering and Technology Equipment Approval Services RE : Application for obtaining a transmitter approval Attached Application Form 731 FCC ID: LLB10051M Dear Sir or Madam: Hexagram Inc. wishes to obtain an approval for a telemetry transmitter with the FCC ID LLB10051M. The specifics of this transmitter: the LLB10051M transmitter is an external, hermetically sealed, utility-meter reading device. Previously, identically transmitters of Hexagram are approved by FCC. The difference is in a current application: an additional RF amplifier is used to increase the output RF power. Consequently, the PCB and imbedded software are redesign to fit new RF circuitry. Complete information about LLB10051M device is documented in the attached circuit schematics and photographs. The LLB10051M transmitter was tested for conformance to the technical requirements of 90.201 Subpart I-General Technical Standards. Results of tests are attached to this application. The LLB10051M was found to be in conformance with all technical requirements of 90.201. Sincerely, Lazar Feldman Principal Engineer RF & Microwave Technology Hexagram Inc. 216-896-8536

Hexagram, Inc 23905 Mercantile Rd. Cleveland, OH 44122 216-464-1057 FCC ID: LLB 10051M PREVIOUS TYPE ACCEPTANCE The radio transmitter submitted (LLB10051M) herein is used as a telemetry device for the reading of utility meters. An operationally identical device (LLB6327) was previously submitted for Type Acceptance and received a Grant of Type Acceptance on March 4, 1998. This earlier version has been in field service since the grant was issued. Later, (12.12. 2003) identical Hexagram transmitter (LLB6327P) received a Grant of Type Acceptance. The product described in this application (LLB10051M) is modified version of LL6327P. The block diagram and basic circuit configuration of the new product is identical to that of the original LLB6327P (and LLB6082). As detailed in Exhibit D “Description of Operation, the semiconductor lineup has been changed from LLB6327P device in order to accommodate new application requirements, such: • Additional RF Power amplifier • Efficient RF power Amplifier • New form of Enclosure, • PC Board layout to accommodate new application Also, attached is a “Statement Concerning Compliance with Section 90.203 (j) (3)”. The identical statement was submitted with the application for Type Acceptance of the earlier LLB6082 device. Page 1 of 5 STATENET CONCERNING COMPLIANCE WITH SECTION 90.203(J)(3) Introduction Section 90.203 (j)(3) of the Commission’s Rules on transmitters provides, in pertinent part: If the equipment [in the 150-174 and 421-512 MHz bands] is capable of transmitting data and has an overall bandwidth of 6,25 kHz or more, the equipment must be capable of supporting a minimum data rate of 4800 bits per second per 6.25 kHz of bandwidth. 1 Three parties interested in remove utility metering sought reconsideration of this provision to allow alternative showings of spectrum efficiency for low power frequency reuse systems. 2 The commission replied: [W]e will provide manufacturers with additional flexibility to design spectrally efficient transmitters. The commission’s Equipment Authorization Division may, on a case by case basis, grant type acceptance to equipment with slower bit rates than specified in Section 90.203(j)(3) and 90-203(j)(5) of our rules, provided that an acceptable technical analysis is submitted with the application, which demonstrate that the slower data rate will provide spectral efficiency than the standard data rate. 3 The present application is for automatic remote meter equipment, and falls squarely within the scope of this exception. When considered as part of a system, the device in question provides spectrum efficiency and channel utilization far excess of 4800 bits/sec per 6.25 kHz. Technical Analysis The device submitted for type acceptance is a Meter Transmitter Unit (MTU). When the system is implemented, an MTU is attached to each utility meter. The MTU periodically transmits meter readings omni-directionally in transmissions lasting under one-tenth second each. Transmissions from different MTUa are independent and uncorrelated. Data-collector Units (DCU) are mounted on a nominal 1 mile grid. A DCU receives and stores the transmissions from all the MTUs in its range. Once, daily, each DCU transfers the accumulated data to a central computer at the utility office via a cell phone mounted on the DCU. MTU bandwidth is 12.5 kHz, so a strict application of section 90.203(j)(3) would require the equipment to support a data rate of 9600 bits/sec. In fact, to minimize component cost and bit 1 47 C.F.R. para 90.203(j)(3). This provision governs Part 90 type acceptance applications filed from August 1, 1996, through December 31, 2004. 2 Replacement of Prt 90 by Part 88 to revise the private Land Mobil Radio Services, 11 FCC Rcd 17676, 17686 (1996). 3 Id., 11 FCC Rcd at 17687 (emphasis added). Page 2 of 5 error rate, an individual MTU transmits at rate of 1200 bits/sec. The system achieves spectrum efficiency not through a high bit rate in each individual MTU, but through a high level of frequency re-use achieved by deploying a large number of low-power short range transmitters. As detailed in the Appendix, a typical large installation of MTUs on a single 12.5 kHz channel can support data rates exceeding 100,000 bits/sec. This performance represents spectrum efficiency far in excess of that required under Section 90.203(j)(3). Where a typical commercial user of private land mobile radio spectrum, such as a delivery service, requires a pair of channels to provide two-way communication with dozens of trucks at most, the MTU is a part of a system that uses a single channel to service millions of users and to carry data representing billions of dollars in annual revenue. This is an extremely efficient use of the spectrum, and is consistent with the Commission’s purposes underlying Section 90.203(j)(3). An operationally identical MTU (LLB6082) received a grant of Type Acceptance on March 4, 1998. Automatic Meter Reading Systems incorporating this technology have been in service since March 4, 1998 and have incorporated tens of thousands of transmitters. The MTU described in this application for Certification represents an improved product. An earlier product (LLB5155) operating under the Commission rules then in effect has been in service at hundreds of locations since May of 1996. Public Interest Considerations Public interest considerations support the development of Automatic Meter reading equipment, such as the device in question. Automatic Meter Reading equipment directly helps to keep consumer rates down in the time of rapidly increasing labor cost. The alternative, traditional door-to-door meter reading, is not only much more expensive, but dangerous for the meter readers, and necessarily exposes consumers to potential security risk in their homes. Equally important in a pro-competitive regulatory environment, Automatic Meter Reading equipment makes possible time –of-use billing, under which a customer’s utility rate varies with time o…

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October 20, 2005 HEXAGRAM, Inc. 23905 Mercantile Rd. Cleveland, OH 44122 216-896-9536 Federal Communications Commission Office of Engineering and Technology Equipment Approval Services RE : Request for Confidentiality Attached Form 731 – Application FCC ID: LLB10051M Dear Sir or Madam: Hexagram Inc. does not wish to publicly disclose certain technical information which is enclosed with this application. This material contains critical trade secrets and we request that the Commission withhold this information from public inspection pursuant to the provisions of Section 0.457(d) and 0.459 of the Commissions Rules, and Section 552(b)(4) of the Freedom of Information Act. This letter summarizes previously sent to request for confidentiality. MATERIAL TO BE HELD CONFIDENTIAL: File Name Description Pages LLB10051M-Internal photos.pdf Internal Circuit Board Photos Two page LLB10051M-Schematic.pdf Circuit Schematics Two Pages LLB10051M-Operation Desc.pdf Description of Operation Two Pages LLB10051M-Installation.pdf Installation manual Thirty five Pages LLB10051M-Block Diagram.pdf Block Diagram of the device One page LLB10051M Bill of materials.pdf Bill of components and materials Three pages LLB10051M Tune Up.pdf Field calibration and tune up One page The LLB10051 electronic assembly is permanently sealed inside of an electrical meter which cannot be opened without destruction of the seal. The above listed material is confidential and is not available to the public or end user. Sincerely, Lazar Feldman Principal Engineer RF and microwave systems 216-896-8536

Back Front LLB10051M EXTERNAL PHOTOS

FCC ID LLB10051M FCC LABEL LLB10051M

LLB10051M October 22, 2005 RF Exposure calculations Based on FCC 1.1307 & 2.1091, FCC OET Bulletin 65. (1) Categorically Exclusion from RF exposure Evaluation: According to FCC regulations, RF exposure evaluation is Categorically Excluded if transmitter’s operation frequency is less than 1.5 Ghz and ERP is less than 1.5 watt. (2) Absolute Maximum specifications of LLB10051M transmitter • Operational frequency band 450 MHz to 470 MHz. • The LLB10051M transmitter is measured for Max RF Power = 0.794 W. • Absolute Maximum transmission time (duration) for any Hexagram transmitters does not exceed 150 mS (0.15second). • Transmission period – Absolute maximum is 1 transmission per 4 hours. • All Hexagram Transmitters utilize FSK modulation. As stated in (1), the hexagram transmitters do not require RF Exposure evaluation. But, we continue with calculations of safety of RF exposure on TIMCO’s request. (3) Average RF Power Calculation: FCC regulations on permissible RF exposure are not based on peak envelope power (PEP), but on average power (P_ave) over a 30-minute time period for uncontrolled environments. As mentioned in (2), during any 30 minute Hexagram MTU can transmit only once. Duration = 0.15 second. With maximum RF radiation equal to 0.794 W, the Average RF Power over 30 minutes is: P_ave (worst case) at 30 minute= = 794mW*1* [0.15sec/((30*60)sec)]=794*0.000083=66 uW (4) Maximum Radiated Power Density prediction (S): To predict power density (S) at distance R=20 cm from transmitter with P_ave = 0.00007W, next formula is used: S = P_ave/(4*(PI)*R^2). For the worst of the worst worst-case prediction of power density at or near a transmitter surface let’s use: S = P_ave/((PI)*R^2) = 66uW/(3.14*20cm*20cm) = = 0.053 uW/cm^2 This is the impossible worst Case of the near field power density of LLB10051M transmitter. (5) Maximum Permissible Exposure (MPE) from LLB10051M: AS FCC require, the maximum permissible exposure for general public in “uncontrolled situation” at 20 cm is: MPE = frequency[MHz]/1500 == 460MHz/1500 = 0.307 mW/cm^2. Compare results in (4) and (5), S=0.053uW/cm^2 <<< MPE=0.307 mW/cm^2 We see that LLB10051M fully complies with RF safety at a distance of 20 cm. Lazar Feldman Hexagram 216-896-8536

SMITH ELECTRONICS, INC. ELECTROMAGNETIC COMPATIBILITY LABORATORIES RADIO-FREQUENCY EMISSIONS TEST REPORT FOR HEXAGRAM, INC. UTILITY METER TRANSMITTING UNIT (MTU) Model 10051M FCC ID: LLB10051M April 8, 2005 Revised October 25, 2005 Prepared by: Prepared for:Hexagram, Inc. 23905 Mercantile Road Cleveland, OH 44122 Smith Electronics, Inc. 8200 Snowville Road Brecksville, OH 44141 Phone: (440) 526-4386 Fax: (440) 526-9205 James R. Pollock FCC ID: LLB10051MPage 2 of 18 TEST REPORT INTRODUCTION The Hexagram Model 10051M transmitter is a battery-powered transmitter designed to be connected to a typical utility meter. The transmitter is contains an internal antenna, sealed within the case. The unit is provided with a single cable for connecting to a meter. At programmed intervals the transmitter provides a very short, intermittent radio frequency transmission to provide a remote reading of the meter. A microprocessor provides timing, control and data processing functions. One transmitter was tested and this report presents the worst case data obtained in support of an application for certification. MEASUREMENTS PERFORMED Power Output and Spurious EmissionsPage 3 Occupied BandwidthPage 9 Frequency Stability vs. TemperaturePage 11 Frequency Stability vs. Supply VoltagePage 12 Transient StabilityPage 14 The microprocessor portion of the transmitter was also examined for radiated emissions per Part 15, and has been verified to comply with the appropriate sections of that part. The data used for verification of the microprocessor portion is presented in a separate report. FCC ID: LLB10051MPage 3 of 18 POWER OUTPUT AND SPURIOUS EMISSIONS A prototype sample of the transmitter was examined at three fundamental frequencies and their harmonics. All measurements were made on the Smith Electronics open area test site located at 8200 Snowville Road, Brecksville, OH. Data pertinent to this site is on file with the FCC. Due to low signal strengths, the harmonics of the unit above 1000 MHz were made at a test distance of 1 meter. The measurements were made using the substitution method described in TIA/EIA-603. Measurements below 1000 MHz were made at a three-meter test distance with frequencies above 1000 MHz being measured at one meter. A dipole was used for receiving below 1000 MHz and a wave guide antenna was used above 1000 MHz. A spectrum analyzer was used as a receiver. The transmitter was placed on a remotely rotatable, non-conducting test stand. This general set up is shown in Pictorial 1. Because of the intermittent nature of the normally operating transmitter a larger, external battery pack was connected directly to the transmitter and the transmitter was forced to transmit for about 10 seconds at a 50% duty cycle for the measurements. With the test receiver tuned to the unmodulated signal, the transmitter under test was rotated to the position of maximum signal. The receiving antenna was then varied between 1 and 4 meters in height to again maximize the signal. Measurements were made with the antennas positioned both vertically and horizontally and the maximum signal recorded. Peak detection with some video filtering was used for all measurements of this test. The video filtering reduces the effect of noise and permits more accurate measurement. After the maximum received meter readings were obtained for each frequency and polarity, the transmitter under test was removed from the area and replaced by a signal generator and transmitting antenna. With the transmit antenna placed as close as possible to the position of the test unit, the signal generator was activated at a test frequency. With the signal detected, the receive antenna was positioned for maximum reception. The signal generator output was then adjusted until the received signal was equal to the previously received signal from the unit under test. These measurements were repeated for each frequency and antenna orientation and the maximum values obtained are noted in Tables 1a – 1c. Transmitting antenna gain and coax loss figures are also included in the tables In order to convert the signal generator output value to equivalent radiated power from a dipole, the following equation is used: P d = P g – cable loss(dB) + antenna gain(dB d ) where: P d is the dipole equivalent power, P g is the generator output into the substitution antenna and “antenna gain” is the gain of the substitution antenna with respect to a dipole. FCC ID: LLB10051MPage 4 of 18 According to 90.210(d)(3) all emissions greater than 12.5 kHz from the center of the authorized band shall be attenuated below the unmodulated carrier by 50 + 10log(P). The determined power outputs, the required harmonic attenuation as well as the attenuation for each harmonic are found in Tables 1a – 1c. PICTORIAL 1 HEXAGRAM MODEL 10051M FIELD STRENGTH OF SPURIOUS EMISSIONS TYPICAL TEST SETUP FCC ID: LLB10051MPage 5 of 18 TABLE 1a HEXAGRAM MODEL 10051M TRANSMITTER SUBSTITUTION METHOD 3 meter measurement using tuned dipole antenna Frequency (MHz) Gen. Output (dB) Coax Loss (dB) Ant. Gain (dBd) Dipole Eq. Power (dBm) Difference (dB) 45026.21.1025.1 -45.1 dB Req. 900-30.01.70-31.7-56.8 1 meter measurement using horn antenna Frequency (MHz) Gen. Output (dBm) Coax Loss (dB) Ant. Gain (dBd) Dipole Eq. Power (Dbm) Difference (dB) 1350-48.60.73.1-46.2-71.3 1800-62.00.84.9-57.9-83.0 2250-54.21.05.6-49.6-74.7 2700-56.01.16.2-50.9-76.0 3150-54.51.26.7-49.0-74.1 3600-44.51.36.6-39.2-64.3 4050-33.01.46.5-27.9-53.0 4500-43.01.57.2-37.3-62.4 25.1 dBm = 0.354 W Required attenuation for harmonics is 50 + log (0.354) = 45.1 dB FCC ID: LLB10051MPage 6 of 18 TABLE 1b HEXAGRAM MODEL 10051M TRANSMITTER SUBSTITUTION METHOD 3 meter measurement using tuned dipole antenna Frequency (MHz) Gen. Output (dB) Coax Loss (dB) Ant. Gain (dBd) Dipole Eq. Power (dBm) Difference (dB) 46028.51.1027.4 -47.4 dB Req. 920-28.61.70-30.3-57.7 1 meter measurement using horn antenna Frequency (MHz) Gen. Output (dBm) Coax Loss (dB) Ant. Gai…

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