LLB8877TRANSMITTER FOR METER READING

Page 1 of 5 Hexagram, Inc 23905 Mercantile Rd. Cleveland, OH 44122 216-464-1057 FCC ID: LLB 8877 PREVIOUS TYPE ACCEPTANCE The radio transmitter submitted (LLB8877) herein is used as a telemetry device for the reading of utility meters. An operationally identical device (LLB8877) 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, identical Hexagram transmitter (LLB6327) received a Grant of Type Acceptance. The product described in this application (LLB8877) is modified version of LLB6082. The block diagram and basic circuit configuration of the new product is identical to that of the original LLB6082 (and LLB6372). As detailed in Exhibit D “Description of Operation, the semiconductor lineup has been changed from LLB6327 device in order to accommodate new application requirements, such: • Efficient RF power Amplifier • New form of Enclosure, • PC Board layout to accommodate new enclosure 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 2 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 error rate, an individual MTU transmits at rate of 1200 bits/sec. The system achieves spectrum 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 3 of 5 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 of day or day of the week. Electric time-of-us…

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HEXAGRAM, Inc. RF & MICROWAVE TECHNOLOGY DEPARTMENT Lazar Feldman Principal Engineer 216-464-1057 x1229 [email protected] RE: LLB8877; TIMCO Job 1280UC3 September 21, 2003 Mr. Bruno Clavier, Chief Engineer, Timco Engineering RE: your letter of 9-15-2003 Dear Mr. Bruno Clavier, Thanks for your input regarding Hexagram LLB8877 submission. Following your numbering; bellow is the information on your request. 1. Revised request for confidentiality is included in this e-mail package. 2. See next paragraph. 3. Module/Modular approval is not feasible for LLB8877 due to the fact that each manufacturer has different mechanical structure of their electrical meter. Therefore, in each specific case, Hexagram will redesign the MTU and will submit documentation for FCC approval for use of our transmitter within a new electrical meter environment. Therefore, Please, authorize the use of LLB8877 with Invensys Watt-hour meter. The LLB8877 is tested within the Invensys Watt-hour meter. Also, the previously submitted file LLB8877-Location FCC label.pdf consists of external photo of the final device. 4. See previous paragraph. 5. The file LLB8877 Int Photo-no shield.pf is a photograph of the component level of the board without shield. 6. LLB8877 uses a ribbon cable with a ferrite suppression core on the cable. This ferrite core does not affect the RF performance of the LLB8877, and, it is used to preserve the data reading integrity of the electrical meter. 7. The LLB8877 has undergone intensive laboratory RF testing during design and prototype validation. The frequency 460MHz is the worst case point due to the fact that transmitter’s filters and matching circuits have the smallest losses in the middle of the band. At the ends of the band, the radiated components are lower than at the 460MHz. 8. The Occupied Bandwidth (OBW) plots are blurry due to the fact the Lab that performed the test had to print them to add the mask boundaries (manually), and, after that they scan them back into electronic format. We attached file LLB8877 OBW-plots.pdf for your review. These are original plots from real-time spectrum analyzer (TEK3086) and they have no mask boundaries. You may see the span is set to 100 kHz. According to TEK 3086 user manual, page 3-34, the resolution (and video) bandwidth of the instrument is internally set to: ][156 641 ][100 641 Hz kHzSetSpan RBW=== The FCC requires to set the spectrum analyzer for RBW and VBW of not less than 100 [Hz]. We fully comply with this request. Dear Mr. Clavier; I hope, I have answered to all of your questions. If there any more questions or requests, please, submit them to my attention, because I am responsible for all RF product in the company. Sincerely Lazar Feldman

September 10, 2003 HEXAGRAM, Inc. 23905 Mercantile Rd. Cleveland, OH 44122 216-464-1057 Federal Communications Commission Office of Engineering and Technology Equipment Approval Services RE : Request for Confidentiality Attached Form 731 – Application FCC ID: LLB8877 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 LLB8877-Int photos.pdf Internal Circuit Board Photos One page LLB8877-Schematic.pdf Circuit Schematics Four Pages LLB8877-Operation Desc.pdf Description of Operation Two Pages LLB8877-Installation.pdf Installation manual Thirty seven pages LLB8877-Block Diagram.pdf Block Diagram of the device One page LLB8877 Bill of materials.pdf bill of components and materials Three pages LLB8877 Tune Up.pdf Field calibration and tune up One page The LLB8877 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, Lawrence M. Sears Director of Technology

September 10, 2003 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: LLB8877 Dear Sir or Madam : Hexagram Inc. wishes to obtain an approval for a telemetry transmitter with the FCC ID LLB8877. Previously, identically transmitters of Hexagram are approved by FCC. The difference is in a new application: the LLB8877 transmitter is installed within a solid-state electrical meter. Complete information about LLB8877 device is documented in the attached circuit schematics and photographs. The LLB8877 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 LLB8877 was found to be in conformance with all technical requirements of 90.201. Sincerely, Lawrence M. Sears Director of Technology

SMITH ELECTRONICS, INC. ELECTROMAGNETIC COMPATIBILITY LABORATORIES RADIO-FREQUENCY EMISSIONS TEST REPORT FOR HEXAGRAM, INC. ELECTRIC METER TRANSMITTING UNIT (MTU) Model 8877 FCC ID: LLB8877 September 10, 2003 Rev. 1 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: LLB8877Page 2 of 16 TEST REPORT INTRODUCTION The Hexagram Electric MTU transmitter is a line-powered transmitter designed to be installed in a typical electric meter. The transmitter will be mounted inside the glass cover of the meter and provide a very short, intermittent radio frequency transmission to provide a remote reading of the meter. A microprocessor provides timing, control and data processing functions. The built in antenna is inaccessible to the user and no provision is made for an external antenna. This report describes the tests performed on the transmitter in support of an application for certification. MEASUREMENTS PERFORMED Power Output and Spruious EmissionsPage 3 Occupied BandwidthPage 7 Frequency Stability vs. TemperaturePage 9 Frequency Stability vs. Supply VoltagePage 10 Transient StabilityPage 12 The microprocessor portion of the transmitter was also examined for conducted and 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: LLB8877Page 3 of 16 POWER OUTPUT AND SPURIOUS EMISSIONS A series of measurements of the operating frequency and any harmonic emissions was made on the Smith Electronics, open field test site located at 8200 Snowville Road, Brecksville, OH. Data pertinent to this site is on file with the FCC. A scan of the transmitter emissions made in the shielded room showed no significant emissions other than the fundamental and its harmonics. The measurements were made using the substitution method described in TIA/EIA-603-A. Measurements below 1000 MHz were made at a three-meter test distance with frequencies above 1000 MHz being measured at one meter. A receiver and a tuned dipole were used for receiving below 1000 MHz and a spectrum analyzer and a wave guide antenna were used above 1000 MHz. The transmitter, installed in a typical meter, 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 and its mode of operation while AC powered, an external battery pack was connected directly to the transmitter and the transmitter was forced to continually transmit 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. No differences were observed with different signal detectors, so a quasi-peak detector was used for the signals below 1000 MHz and average detection above 1000 MHz. After the maximum received meter readings were obtained for each frequency and polarity, the meter 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 transmit antenna was rotated slightly to maximize the reading. The receive antenna was also positioned for maximum reception. The signal generator output was then adjusted until the received signal was equal to the 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 Table 1. Transmitting antenna gain and coax loss figures are also included in Table 1 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: LLB8877Page 4 of 16 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). Using P = 0.0832 W, the required attenuation is 39.2 dB. An examination of Table 1 shows that all emissions are 49.8 dB or more below the carrier power level. PICTORIAL 1 HEXAGRAM ELECTRIC METER TRANSMITTING UNIT OUTPUT POWER AND SPURIOUS EMISSIONS TEST SETUP FCC ID: LLB8877Page 5 of 16 TABLE 1 HEXAGRAM EMU 8877 TRANSMITTER SUBSTITUTION METHOD 3 meter measurement using tuned dipole transmit antenna Frequency (MHz) Gen. Output (dB) Coax Loss (dB) Ant. Gain (dBd) Dipole Eq. Power (dBm) Difference (dB) 46019.50.3019.2-- 920-33.70.50-34.2-53.4 1 meter measurement using horn transmit antenna Frequency (MHz) Gen. Output (dBm) Coax Loss (dB) Ant. Gain (dBd) Dipole Eq. Power (dBm) Difference (dB) 1380-35.50.73.1-33.1-52.3 1840-47.40.84.9-43.3-62.5 2300-38.00.95.6-33.4-52.5 2760-35.71.16.2-30.6-49.8 3220-46.31.26.7-40.8-60.0 3680-50.91.36.6-45.6-64.8 4140-50.51.46.5-45.4-64.6 4600-54.71.57.2-49.0-68.2 19.2 dBm = 83.2 mW or 0.0832 W Required attenuation for harmonics is 50 + 10log (.0832) = 39.2 dB Measurements made with 10 kHz IFBW and 10 kHz video BW EMU 8877 September 8, 2003 FCC ID: LLB8877Page 6 of 16 TEST EQUIPMENT USED Meters & Analyzers Singer-Stoddart EMI Field Intensity Meter Model NM 37/57 S/N 0366-06168 Calibrated 6/03 Hewlett-Packard Spectrum Analyzer Model 8593EM S/N 3536A00147 Calibrated 6/00 Anten…

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