OAYARS100Vehicle Radar System

1 September 13, 1999 CONFIDENTIALITY REQUEST CONTAINED WITHIN Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 Re:ADC Automotive Distance Control GmbH application for certification of FCC ID: OAYARS100 Collision Avoidance Radar Gentlemen: ADC Automotive Distance Control GmbH, Postfach 3268, 88114 Lindau, Germany, herein submits a request for confidentiality of the schematic diagram and one internal photograph of the proprietary antenna structure contained in the certification application for the reference radar under FCC Rules Part 15. This request will be followed by submission of a check for $135.00 along with Form 159 to the Mellon Bank. The schematic diagram and the specific internal photograph have been scanned into an electronic format at the FCC Lab without a request for confidentiality. The schematic and photo will be resubmitted with this letter to assist in identifying the correct items to retain as confidential material. ADC Automotive Distance Control GmbH (ADC) request, pursuant to 47CFR 0.459, post grant confidentiality for portions of the material contained in the reference application such that the identified material will be withheld from public inspection following the grant of this authorization. This material, as indicated by request for confidentiality of the items during this electronic submission process and further identified below includes: 1.Circuit diagrams submitted as Equipment Authorization Electronic Filing attachment: "schematics" Exhibit #5 2. Internal photo of antenna structure submitted as Equipment Authorization Electronic Filing attachment: "internal photo" Exhibit #9. This resubmission is only to assist in identifying the documents for which confidentiality is requested so that the current items scanned at the FCC facility can be identified and marked as confidential. Specifically, these exhibits contain information relating to circuit function and complexity that could be of benefit to competitors. The internal photo shows design features of the radiating system that are unique to ADC and considered to be proprietary information. This material contains trade secrets and confidential information that ADC does not customarily release to the public and which is otherwise not generally available to the public. 2 Please contact the undersigned by phone at 410-531-3439, by fax at 410-531-0807, by email at [email protected], or by correspondence at the address below if there are any further questions or additional information needed concerning this filing. Regards, (signed) Phillip Inglis, Agent for ADC and Cetecom 14085 Howard Rd. Dayton, MD. 21036

Attached are photos of the display unit as installed in the motor vehicle. The unit is integrated into the dashboard of, in this case, a Mercedes automobile. Control of the unit is via a switch integrated into the steering column of the Mercedes.

Subject: AW: ADC radar Date: Mon, 13 Sep 1999 17:04:32 +0200 From: "Kartmann, Uwe" <[email protected]> To: Phillip Inglis <[email protected]> Hi Phil, Today I received a fax from ADC with some of the required information: 1. The Antenna will be fixed into the grille (the grill of the Mercedes Benz, I don't know the right English expression). Important for us is the fact, that it will not be mounted into the bumper and it will be mounted fixed. As far as I understood your last e-mail, FCC Part 2.1091 will apply in this case. 2. ADC also sent me some technical specifications according to the signal: * pulswith: 36 ns * pulserate: 350 kHz * duty cycle: 36 ns * 350 kHz = 0,0126=1,26% 3. According the correct label, they asked if you would generate the correct label with a drawing. Please send me the draft. 4. The user manual of the equipment is available only in German language. Is it necessary to insert the statement "The user of this equipment..." into this manual? Or is it sufficient to show FCC a written notice from ADC to Daimler Crysler, to publish the statement in the user manual of the car? 5. Attached I send you some copies of the display unit. The translation of the text of the left hand foto is:"If you switch the Distronic on, you will see into the speed-display of your car one or two segments of the stored speed ."(by tempomat). The translation of the text into the following foto is: "If the System makes out a car in front of yours, all segments, beginning with the speed of this car until your stored speed, will be illuminated. If the car isn't seen any more, only the segments of the stored speed will be illuminated and the car will be accelerated to this stored speed." The third picture shows the tempomat button: Position 5 is the on/off switch of the Distronic. 6. ADC wants you to file a request to keep the documentation confidential. If you want to start the radar, you must connect both parts to each other and supply the equipment with 12 V DC. That's all, it will start working. No other requirements are necessary. Kind Reards Uwe > -----Ursprüngliche Nachricht----- > Von: Phillip Inglis [SMTP:[email protected]] > Gesendet am: Montag, 13. September 1999 15:18 > An: Kartmann, Uwe > Cc: Cetecom b.v.b.a > Betreff: ADC radar > > Dear Uwe, > > I used the data from the European report for showing compliance with > the > RF exposure requirements. That data was taken using a video averaging > technique for determining the average power. If the FCC accepts that > technique we will be ok. If not, I don't believe it will exceed the > limits regardless of the measurement technique they require. > > Since ADC hasn't responded, I assume they have no objection to their > schematic being released to the public after a grant is issued. If > they > decide to protect it from the public, we have until the grant is > issued > to file a confidentiality request. > > Do you want me to draft a proper ID label and send it to you? You can > forward it to them for their approval before I file it. > > I may need some information regarding getting the radar operational > for > the tests at the Lab. I didn't see very much information concerning > making it operational. Do we just need to connect the modules > together > and apply battery power? Does it need an input from some other source > to make it turn on? If their are any particulars regarding its > operation please forward them. > > Regards, > Phil --------------------------------------------------------------------- Name: Display.unit.doc Display.unit.doc Type: Microsoft Word Document (application/msword) Encoding: base64

RF Exposure Information Pursuant to Section 15.253(f): Maximum radiation occurs whether the vehicle is in motion or not. When the vehicle is not in motion, the appropriate category for RF Exposure is general population/ uncontrolled exposure. At 76-77 GHz the specification limits exposure to 1 mW/cm 2 . Stationary is the only operational configuration that must be evaluated for RF exposure. The operation and installation manual specifies a mounting location for the antenna installation to be typically behind the radiator of the vehicle it is installed in. Measurement data taken from the European test report on an identical transmitter head shows the radar unit produces a level of 3.8 nW/cm 2 measured at a distance of 1 meter using a standard gain horn and a Tektronix spectrum analyzer. The calculation is based on the received power level at that distance divided by the planar surface area of the standard gain horn antenna. With a mounting location behind the radiator of a vehicle, the expected closest distance an individual could come to the radiating antenna would vary between at least 20 cm up to distances approaching 1 meter. Due to the margin of compliance, > 50 dB, further calculations are not considered necessary. A copy of the test data sheet from the European test report is attached. Phillip Inglis