QF7HANDYSCAN

HandyScan from GSSI Geophysical Survey Systems, Inc. 13 Klein Drive, P.O. Box 97 North Salem, NH 03073-0097 Phone: (603) 893-1109 / FAX: (603) 889-3984 e-mail: [email protected] web: www.geophysical.com Geophysical Survey Systems, Inc. HandyScan User's Guide MN70-416 Limited Warranty, Limitations Of Liability And Restrictions Geophysical Survey Systems, Inc. hereinafter referred to as GSSI, warrants that, for a period of 12 months from the delivery date to the original purchaser, GSSI's products will be free from defects in materials and workmanship. EXCEPT FOR THE FOREGOING LIMITED WARRANTY, GSSI DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING ANY WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. GSSI's obligation is limited to repairing or replacing parts or equipment which are returned to GSSI, transportation and insurance pre-paid, without alteration or further damage, and which in GSSI's judgment, were defective or became defective during normal use. GSSI ASSUMES NO LIABILITY FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES OR INJURIES CAUSED BY PROPER OR IMPROPER OPERATION OF ITS EQUIPMENT OR SOFTWARE, WHETHER OR NOT DEFECTIVE. Before returning any equipment to GSSI, a Return Material Authorization (RMA) number must be obtained. Please call the GSSI Customer Service Manager who will assign an RMA number. Be sure to have the serial number of the unit available. GSSI does not convey any license under its patent or other intellectual property rights or the rights of others. Note : Information in this manual is subject to change without notice. Please consult the manual updates supplied with your system and contact GSSI with any additional questions. Copyright© 2001 Geophysical Survey Systems, Inc. All rights reserved including the right of reproduction in whole or in part in any form Published by Geophysical Survey Systems, Inc. 13 Klein Drive North Salem, New Hampshire 03073-0097 Printed in the United States GSSI, HandyScan and RADAN are registered trademarks of Geophysical Survey Systems, Inc. Geophysical Survey Systems, Inc. HandyScan User's Guide MN70-416 FCC NOTICES: This device complies with part 15 of the FCC Rules: Operation is subject to the following conditions: 1. This device many not cause harmful interference, and 2. This device must accept any interference received, Including interference that may cause undesired operation Warning: Changes or modifications to this unit not expressly approved by the party responsible for compliance could void the user’s authority to operate the equipment. Operation of this device is restricted to law enforcement, fire and rescue officials, scientific research institutes, commercial mining companies, and construction companies. Operation by any other party is a violation of 47 U.S.C. § 301 and could subject the operator to serious legal penalties. Coordination Requirements. (a) UWB imaging systems require coordination through the FCC before the equipment may be used. The operator shall comply with any constraints on equipment usage resulting from this coordination. (b) The users of UWB imaging devices shall supply detailed operational areas to the FCC Office of Engineering and Technology who shall coordinate this information with the Federal Government through the National Telecommunications and Information Administration. The information provided by the UWB operator shall include the name, address and other pertinent contact information of the user, the desired geographical area of operation, and the FCC ID number and other nomenclature of the UWB device. This material shall be submitted to the following address: Frequency Coordination Branch., OET Federal Communications Commission 445 12 th Street, SW Washington, D.C. 20554 ATTN: UWB Coordination (d) Users of authorized, coordinated UWB systems may transfer them to other qualified users and to different locations upon coordination of change of ownership or location to the FCC and coordination with existing authorized operations. (e) The NTIA/FCC coordination report shall include any needed constraints that apply to day-to-day operations. Such constraints could specify prohibited areas of operations or areas located near authorized radio stations for which additional coordination is required before operation of the UWB equipment. If additional local coordination is required, a local coordination contact will be provided. (f) The coordination of routine UWB operations shall not take longer than 15 business days from the receipt of the coordination request by NTIA. Special temporary operations may be handled with an expedited turn-around time when circumstances warrant. The operation of UWB systems in emergency situations involving the safety of life or property may occur without coordination provided a notification procedure, similar to that contained in CFR47 Section 2.405(a)-(e), is followed by the UWB equipment user. NOTICE: Use of this device as a wall imaging system is prohibited by FCC regulations. Geophysical Survey Systems, Inc. HandyScan User's Guide MN70-416 1 Introduction HandyScan is a small-size, fully functional ground penetrating radar. It can instantly find the position and depth of metal and non-metal bars, pipes and cables. It works in natural and man-made non-conductive materials (concrete, rock, sand, brick, water, and ice). It can also locate voids and measure the thickness floors and other structural elements. HandyScan allows the user to: • Collect single lines of data (page 4) or grid data for plan viewing (page 8). • Review data on screen, determine position and depth of features (page 5). • Print data on the Seiko DPU-3445-20 printer supplied with the system (page 6). • Transfer data to a PC in GSSI (*.dzt) format for storage and processing in RADAN software (page 7). • Display plan views (Depth Slices) of grid data on a PC screen (page 9). Specifications Survey depth 20-30 cm Max survey length 15 m Size 21 x 15 x 1…

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_____________________________________________________________________________________________________________ Geophysical Survey Systems, Inc. _____________________________________________________________________________________________________________ 13 Klein Drive - P.O. Box 97, North Salem, NH 03073-0097, U.S.A. / Telephone (603) 893-1109 Fax (603) 889-3984 website www.geophysical.com e-mail [email protected] November 12, 2002 Attention: Application Examiner Reviewing Engineer Re: Request for confidentiality Applicant: Geophysical Survey Systems, Inc. FRN: 0007-2729-25 FCC ID: QF7HANDYSCAN To whom it may concern, Request is hereby submitted by Geophysical Survey Systems, Inc., to withhold from public review certain portions of the application for equipment certification for the referenced FCC identifier. In particular, the following sections of the application are requested to be kept confidential: • Schematics • Detailed Block diagrams • Detailed Operational/Functional Description Rationale for request for confidentiality: Geophysical Survey Systems, Inc. has invested considerable time and materials in research and development to produce the referenced product. Disclosure of the confidential portions of this application to competitors would not only give them significant competitive advantages in developing similar products, but would also disclose successful implementation of unpublished, leading edge technology developed by us. The fee for confidentiality has been submitted along with the fee for certification. If you have questions or need further information, please contact the undersigned. Sincerely, Dennis J. Johnson President, Geophysical Survey Systems, Inc.

To: FCC Equipment Authorization Branch From: Robert Martin Intertek Testing Services Due to testing difficulties and resulting correspondence from the FCC on other projects, this product was retested. The most recent test report and test setup photos (labeled REVISED) are the result of this retest.

Re:FCC ID QF7HANDYSCAN Applicant:Geophysical Survey Systems, Inc. Correspondence Reference Number:24714 731 Confirmation Number:EA935767 1) The additional schematics have not been submitted yet. We have delivered the entire transmitter schematic, as with our other antennas. We are unable to obtain the remaining schematics from our Japanese manufacturer. We see no need for the remaining schematics. 2) The manual does not mention the use of a kill switch. Can a photo be provided? The button on top of the unit must be held pressed the whole time that data is being taken. If the button is released, the unit will stop transmitting after 10 seconds. This is reflected in the revised user manual – file name “QF7HANDYSCAN Manual_revised.pdf” 3) Provide the waiver from NTIA regarding the 10 dB UWB bandwidth. A request for waiver has been uploaded with file name “Handyscan_GPRwaiver_request.pdf” 4) The frequency range of measurements for the 10 dB UWB bandwidth tests was stated as only up to 2 GHz. It must be tested up to Fc+2/pulse width. Also, it appears from the latest bandwidth plot that the 10 dB UWB bandwidth is much higher than 980 MHz. Please retest up to the proper frequencies and indicate the correct 10 dB UWB bandwidth. Please ensure that NTIA is updated with the proper measurements for their evaluation. Additional tests were performed. The results are reflected in the revised test report with file name “Handyscan_report_rev2-18.pdf”

1 47 C.F.R. Secs. 15.509(d), (e), (f). 2 47 C.F.R. Sec. 15.509(a). Fletcher, Heald & Hildreth, P.L.C. 1300 North 17 th Street 11 th floor Arlington VA 22209 703-812-0400 (voice) 703-812-0486 (fax) MITCHELL LAZARUS 703-812-0440 [email protected] February 19, 2003 Edmond J. Thomas Chief, Office of Engineering and Technology Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re:Geophysical Survey Systems, Inc. Request for Waiver of Section 15.509(a) FCC ID QF7HANDYSCAN, EA935767 (GPR Device) Dear Ed: Pursuant to Section 1.3 of the Commission's Rules, Geophysical Survey Systems, Inc. (GSSI) requests a waiver of Section 15.509(a) to permit the marketing of a GPR device ("Device") whose emissions are below the prescribed limits at all frequencies, but whose UWB bandwidth exceeds 960 MHz. GSSI has pending a certification application for this Device under FCC ID QF7HANDYSCAN, EA935767. BACKGROUND The Device complies in full with the Commission's rules governing emissions at measurement bandwidths of 1 MHz and 1 kHz, and with the provision limiting peak power. 1 The only rule raising any question of compliance is Section 15.509(a), which requires the "UWB bandwidth" of a GPR to lie below 960 MHz. 2 The UWB bandwidth is defined as "the frequency Edmond J. Thomas February 19, 2003 Page 2 3 47 C.F.R. Sec. 15.503(a). 4 FCC Affirms Rules to Authorize the Deployment of Ultra-Wideband Technology, News Release (ET Docket No. 98-153, released Feb. 13, 2003). 5 For example, the ultra-wideband First Report and Order was adopted on February 14, 2002, but did not take effect until July 15 -- five months later. Ultra-Wideband Transmission Systems, 67 Fed. Reg. 34852 (May 16, 2002). band bounded by the points that are 10 dB below the highest radiated emission." 3 In other words, the frequencies at which the emissions fall 10 dB below the maximum must be lower than 960 MHz. DISCUSSION The emissions-limit curve for the Device is attached as Figure 1, and the UWB bandwidth curve as Figure 2. As Figure 1 shows, the emissions are under the mask at all frequencies. Figure 2, however, shows that the upper 10 dB point lies at 982 MHz. Although barely above 960 MHz, this datum puts the Device out of compliance. GSSI respectfully suggests the Device is safe to other spectrum users even though the emissions curve crosses the -10 dB line slightly above 960 MHz. On that basis GSSI asks the Commission to waive Section 15.509(a) and certify the Device on the present record. Reconsideration granted on this issue. Last week, the Commission announced it had granted partial reconsideration on a petition filed by the Ground Penetrating Radar Industry Coalition, to which GSSI belongs. 4 We understand this relief includes a repeal of Section 15.509(a). But the repeal cannot take effect until at least 30 days after the Commission's ruling appears in the Federal Register; and that may take several weeks. GSSI is filing this request for relief in the meantime. 5 The Commission already having made a formal decision that the rule is unnecessary, grant of the requested waiver is entirely consistent with Commission policy. Enforcing the rule after deciding to repeal it simply makes no sense. Edmond J. Thomas February 19, 2003 Page 3 6 Ultra-Wideband Transmission Systems, ET Docket No. 98-153, Order, DA 02- 1658 at para. 15 (released July 12, 2002). 7 WAIT Radio v. FCC, 418 F.2d 1153, 1157 (D.C. Cir. 1969). 8 See Petition for Partial Reconsideration of the Ground Penetrating Radar Industry Coalition, supra, at 3-5. 9 Id., 418 F.2d at 1157 ("[A]llegations such as those made by petitioners, stated with clarity and accompanied by supporting data, are not subject to perfunctory treatment, but must be given a 'hard look.'") LEGAL BASIS Long before granting reconsideration on this issue, the Commission had specifically invited waiver requests such as this one. 6 Moreover, this request complies with the waiver standards set out by the U.S. Court of Appeals for the D.C. Circuit. That court held: [A] general rule, deemed valid because its overall objectives are in the public interest, may not be in the "public interest" if extended to an applicant who proposes a new service that will not undermine the policy, served by the rule, that has been adjudged in the public interest. 7 The conditions set out by the court as mandating consideration of a waiver are thoroughly met here. Grant of the requested waiver will increase the availability of devices that provide safety-of-life applications and other important benefits that are plainly in the public interest. 8 Moreover, in granting reconsideration, the Commission has already decided the rule is unnecessary to protect other services. Thus, a grant poses no threat to any other Commission policy, or to any person. Accordingly, a waiver is in the public interest, and is amply entitled to the "hard look" mandated by WAIT Radio 9 Edmond J. Thomas February 19, 2003 Page 4 Please do not hesitate to call with any questions about this request. Respectfully submitted, Mitchell Lazarus Counsel for Geophysical Survey Systems, Inc. cc:Julius P. Knapp, Deputy Chief, OET Bruce A. Franca, Deputy Chief, OET Bruce A. Romano, Associate Chief (Legal), OET Alan J. Scrime, Chief, Policy and Rules Division Geraldine A. Matise, Deputy Chief, Policy and Rules Division Ira R. Keltz, Deputy Chief, Policy and Rules Division Karen E. Rackley, Chief, Technical Rules Branch John A. Reed, Technical Rules Branch Rashmi Doshi, Chief, Laboratory Division Richard F. Fabina, Chief, Equipment Authorization Branch Figure 1 Figure 2

QF7HANDYSCAN EXTERNAL PHOTOS Page 1 of 2 TOP VIEWS QF7HANDYSCAN EXTERNAL PHOTOS Page 2 of 2 SIDE VIEW BOTTOM VIEW

QF7HANDYSCAN FCC LABEL LOCATION LABELS TO READ: LABEL MATERIAL: THESE LABELS ARE PERMANENT FOR THE LIFE OF THE PRODUCT. THEY ARE REVERSE SCREEN-PRINTED ON 8 MIL POLYESTER FILM WITH PERMANENT ADHESIVE. THIS DEVICE COMPLIES WITH PART 15 OF THE FCC RULES. OPERATION IS SUBJECT TO THE FOLLOWING 2 CONDITIONS: 1. THIS DEVICE MAY NOT CAUSE HARMFUL INTERFERENCE. 2. THIS DEVICE MUST ACCEPT ANY INTERFERENCE RECEIVED, INCLUDING INTERFERENCE THAT MAY CAUSE UNDESIRED OPERATION. MADE IN USA FCC ID. QF7HANDYSCAN 1.25 " 3.5" FCC LABELS Operation of this device is restricted to law enforcement, fire and rescue officials, scientific research institutes, commercial mining companies, and construction companies. Operation by any other party is a violation of 47 U.S.C. § 301 and could subject the operator to serious legal penalties.

QF7Handyscan Internal photos Control Circuit - Front Control Circuit - Back Transmitter-Receiver Circuit - Front Transmitter-Receiver Circuit - Back Elenent Circuit (Transmitter & Receiver fans)

MM FCC Subpart 15FPage 1 of 30 Project Number: 3025094Report number Handyscan_report_rev2-18.doc TEST REPORT Report Number: Handyscan_report_rev2-18.doc Project Number: 3036360 Date: rev. 2/18/03 Date(s) of Test: November 19-22, 2002; February 13-14, 2003 Evaluation of the Model number: Handyscan To CFR 47 Part 15 Subpart F For Geophysical Survey Systems, Inc. Test Performed by: Intertek Testing Services Test Authorized by: Geophysical Survey Systems, Inc. 70 Codman Hill Rd. Boxborough, MA 01719 13 Klein Drive PO Box Salem, NH 03079 Prepared by: _______________________________Date: _______________________________ Robert F. Martin Reviewed by: _______________________________Date: _______________________________ Robert F. Martin Sr. Technical Manager All services undertaken are subject to the following general policy: Reports are submitted for exclusive use of the client to whom they are addressed. Their significance is subject to the adequacy and representative character of the samples and to the comprehensiveness of the tests, examinations or surveys made. No quotations from reports or use of Intertek Testing Services NA Inc. name is permitted except as expressly authorized by Intertek Testing Services NA Inc. in writing. This report must not be used to claim product endorsement by NVLAP, NIST or any other agency of the U.S. Government. AA FCC Subpart 15FPage 2 of 30 Project Number: 3025094Report number Handyscan_report_rev2-18.doc EXECUTIVE SUMMARY...........................................................................................................................................................................................4 1.INTRODUCTION.................................................................................................................................................................................................5 1.1.CLIENT INFORMATION...........................................................................................................................................5 1.2.TEST PLAN REFERENCE.........................................................................................................................................5 1.3.EQUIPMENT UNDER TEST (EUT)..........................................................................................................................5 1.3.1System Support Equipment..........................................................................................................................5 1.3.2System Block Diagram.................................................................................................................................5 1.3.3Justification...................................................................................................................................................5 1.3.4Mode(s) of Operation...................................................................................................................................6 1.4.MODIFICATIONS REQUIRED FOR COMPLIANCE.....................................................................................................6 2.TEST ENVIRONMENT.....................................................................................................................................................................................7 2.1.TEST FACILITY.......................................................................................................................................................7 2.2.TEST EQUIPMENT...................................................................................................................................................7 2.3.SAMPLE CALCULATIONS.......................................................................................................................................7 2.3.1Field Strength Calculation...........................................................................................................................7 2.3.2EIRP Calculation..........................................................................................................................................8 2.3.3RMS calculation...........................................................................................................................................8 2.4.MEASUREMENT UNCERTAINTY.............................................................................................................................9 3.ULTRA WIDEBAND OPERATION...........................................................................................................................................................10 3.1.OPERATIONAL LIMITATIONS (SECTION 15.521)................................................................................................10 3.2.UWB BANDWIDTH (SECTION 15.503(A))..........................................................................................................10 3.2.1Requirement (low-frequency imaging systems)......................................................................................10 3.2.2Test Procedure...........................................................................................................................................10 3.2.3Test Results................................................................................................................................................10 3.3.CENTER FREQUENCY (SECTION 15.503(B)).......................................................................................................13 3.3.1Requirement...............................................................................................................................................13 3.3.2Test Procedure...........................................................................................................................................13 3.3.3Test Results.........................................................................................................................…

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HANDYSCAN waveform in air. Horizontal scale is 6 ns full scale (0.5 ns per minor division).

Handyscan Test setup <960 MHz Handyscan Test Setup 960 – 1000MHz RMS Handyscan Test Setup >960MHz