SDB520QRemote Telemetry Module

Federal Communications CommissionDA 11-1316 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of CITY OF LEWISBURG Request for Waivers of Part 90 Rules to Permit Implementation of Wireless Water Management System ) ) ) ) ) ) ) FCC File No. 0004650786 WT Docket No. 11-56 ORDER Adopted: July 28, 2011Released: July 29, 2011 By the Deputy Chief, Mobility Division, Wireless Telecommunications Bureau: 1.Introduction. We have before us an application and waiver request filed by the City of Lewisburg, West Virginia (“Lewisburg”). 1 Lewisburg requests waivers of various Part 90 rules to allow implementation of a wireless water management system. For the reasons discussed herein, we grant Lewisburg’s waiver request. 2.Background.Lewisburg has approximately 3,500 residents, and is the seat of Greenbrier County, a rural county in southern West Virginia. 2 Lewisburg is located within the Quiet Zone for the National Radio Astronomy Observatory (NRAO) at Green Bank, West Virginia. 3 Section 1.924(a) of the Commission’s Rules provides that an entity filing an application to operate a new or modified station in the NRAO Quiet Zone must notify NRAO, and provide technical details of its proposed operation. 4 3.Lewisburg’s Department of Public Works provides potable water, storm water management services, and other services to the residents and businesses of Lewisburg and surrounding areas; and its Fire Department relies on water provided by the Department of Public Works in protecting safety of life and property. 5 The Department of Public Works currently reads water meters manually, which allows even serious water leaks to go undetected for a month or longer. 6 Pursuant to the American Recovery and Reinvestment Act of 2009 (ARRA), Lewisburg received a grant to purchase and install a radio-based 1 SeeFCC File No. 0004650786 (filed March 14, 2011), Request for Waiver (“Waiver Request”). Lewisburg supplemented its waiver request on June 29, 2011. See Letter dated June 29, 2011 from Julian P. Gehman, counsel for Lewisburg, to Rick Kaplan, Chief, Wireless Telecommunications Bureau(“Supplement”). 2 Waiver Request at 1. Greenbrier County has a population density of approximately thirty-five people per square mile. Id.; see also47 C.F.R. § 27.14(o)(1)(iii) (defining “rural area” as “a county (or equivalent) with a population density of 100 persons per square mile or less”). 3 See47 C.F.R. § 1.924(a)(1). 4 Id. Applicants may coordinate their proposed operations with NRAO before filing the application. If the application lacks NRAO’s prior written consent, NRAO may file comments or objections, which the Commission will consider when deciding howto resolve the application. See47 C.F.R. § 1.924(a)(2), (3). 5 Waiver Request at 1. 6 Id. Federal Communications CommissionDA 11-1316 2 meter-reading and control system. 7 Lewisburg then solicited proposals for construction of a wireless water management system pursuant to the terms of the grant. 4.The only qualified proposal was for a system utilizing equipment manufactured by Sensus USA, Inc. (Sensus), and operating on 900 MHz band spectrum licensed to Sensus. 8 NRAO, however, would not consent to operation in that band due to concerns about the power density. 9 NRAO did consent to operation in the Federal 410-430 MHz band (where Sensus equipment used abroad operates), but Lewisburg could not obtain authorization to operate in that band. 10 The National Telecommunications and Information Administration (NTIA) recommended that Lewisburg instead operate in the 450-470 MHz band (for which Sensus can modify its 410-430 MHz equipment). 11 5.In 2011, Lewisburg successfully coordinated with NRAO for operation in the 450-470 MHz band, 12 then filed the above-captioned application and associated waiver request. 13 Lewisburg proposes to operate three fixed base stations, and up to five thousand remote units. Each base station would transmit and receive on a different pair of fifty-kilohertz frequencies. 14 6.Discussion. To obtain a waiver of the Commission's Rules, a petitioner must demonstrate eitherthat the underlying purpose of the rule(s) would not be served or would be frustrated by application to the present case and that grant of the waiver would be in the public interest; or that, in view of unique or unusual factual circumstances of the instant case, application of the rule(s) would be inequitable, unduly burdensome, or contrary to the public interest, or the applicant has no reasonable alternative. 15 Lewisburg asserts that the underlying purposes of the rules at issue would not be frustrated because there are no nearby land mobile systems that will be impacted from operation of the system, and numerous other land mobile frequencies remain available for assignment in this rural area. 16 In addition, Lewisburg argues that it has no other option for implementing a wireless water management system pursuant to the ARRA grant in the NRAO Quiet Zone,and the public interest benefits of proposed system weigh heavily 7 Id.at 2. 8 See Supplement at 1. Sensus manufactures the equipment, and its subsidiary Sensus Spectrum LLC holds the 900 MHz band licenses. Waiver Request at 2. 9 SeeWaiver Request at 2. 10 Id.at 2-3. 11 Id.at3. 12 SeeLetter dated March 9, 2011 from Paulette W. Woody, Interference Office, NRAO to City of Lewisburg (attached to application FCC File No. 0004650786). NRAO consented to the proposed operations on the condition that the effective radiated power relative to a dipole antenna at location 2 (Frankford Tank) be limited to 12.2 watts per 14.75 kilohertz unit bandwidth at 41.1 degrees true azimuth bearing. See id.at 1-2. 13 The Wireless Telecommunications Bureau’s Mobility Division sought comment on Lewisburg’s waiver request. SeeWireless Telecommunications Bureau Seeks Comment on City of Lewisburg, WV Request for Waivers of Part 90 Rules to Permit Implementation of Wireless Water Management System, Public Notice, WT Docket 11-56, 2…

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5015 B. U. Bowman Dr. Buford, GA 30518 July 10, 2012 ACS TCB 5015 B.U. Bowman Drive Buford, GA 30518 Re: FCC ID: SDB520Q To Whom It May Concern: The following application is submitted on behalf of our client, Sensus Metering Systems, Inc., for evaluation of their model 520Q for certification under FCC Part 90 Subpart I. The purpose of this application is to modular approve the model 520Q (FCC ID: SDB520Q) wireless transceiver. The FCC ID: SDB520Q is a stand-alone radio module that is designed to be integrated into specific host devices. The model 520Q was evaluated in accordance to WT Docket No. 11-56, DA 11- 1316 which waives 90.203(j) from the test requirements. The FCC ID: SDB520Q was tested standalone and the radiated emissions evaluation was performed in the orientation of typical installation. The FCC ID: SDB520Q was found to be in compliance with the test requirements. Sincerely, Sam Wismer Vice President, Technology Advanced Compliance Solutions, Inc.

Reliability and Compliance T: 919-317-6351 639 Davis Drive F: 919-317-6210 Morrisville, NC 27560 USA www.sensus.com LETTER OF AUTHORIZATION Monday, July 02, 2012 To whom it may concern: I hereby appoint Sam Wismer of Advanced Compliance Solutions, Inc. to act as our agent in the preparation of an application for equipment authorization of the 520Q to the FCC Rules and Regulations. I certify that all exhibits contained within this filing properly describe the device or system for which authorization is sought. I further certify that appropriate arrangements have been made to assure that production units of this equipment bearing the name 520Q and FCC IDENTIFIER SDB520Q listed in this application will continue to comply with the Commission's requirements. I further certify by signature below that no party (per 47 CFR 1.2002(b)) to the application is subject to a denial of Federal benefits, including FCC benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. 853(a). This appointment also includes the authority to complete FCC Form 731 on our behalf and sign the application as an authorized agent. This authorization is valid for 520Q ONLY, and shall not be utilized for any other matters on the behalf of Sensus. Sincerely, Al Servais | Reliability and Compliance Program Manager 639 Davis Drive | Morrisville, NC 27560 USA T: 919-317-6351 | C: 919-208-8983 | [email protected] | www.sensus.com

Reliability and Compliance T: 919-317-6351 639 Davis Drive F: 919-317-6210 Morrisville, NC 27560 USA www.sensus.com 1 of 3 Sensus Non Sensus NonSensus Non Sensus Non- -- -Disclosure Disclosure Disclosure Disclosure Memorandum MemorandumMemorandum Memorandum July 17, 2012 Sensus OEMs: This memorandum serves as an additional agreement between Sensus and its OEMs stating that the OEMs will use the Sensus 520Q module (See Appendix 1) in accordance with the FCC rules on modular approved devices. The Sensus 520Q Transceiver is professionally installed inside a Sensus meter (See Appendix 2). The module label will be located in a visible area on the host and will display all necessary and pertinent information about the modular device. Confidentiality of the internal photos and the technical manual is being requested because this is a non-consumer device which is not accessible by the general public, professionally installed, and is only serviceable by Sensus, or designated technicians. Please feel free to contact me directly should there be any questions regarding this matter . Respectfully, Al Servais | Reliability and Compliance Program Manager 400 Perimeter Park | Suite K | Morrisville, NC 27560 USA T: 919-379-1951 | C: 919-208-8983 | [email protected] | www.sensus.com 2 of 3 Sensus Non Sensus NonSensus Non Sensus Non- -- -Disclosure M Disclosure MDisclosure M Disclosure Memorandum emorandumemorandum emorandum Appendix 1 Appendix 1Appendix 1 Appendix 1 3 of 3 Sensus Non Sensus NonSensus Non Sensus Non- -- -Disclosure Memorandum Disclosure MemorandumDisclosure Memorandum Disclosure Memorandum Appendix 2 Appendix 2Appendix 2 Appendix 2

Reliability and Compliance T: 919-317-6351 639 Davis Drive F: 919-317-6210 Morrisville, NC 27560 USA www.sensus.com MODULAR APPROVAL REQUEST FORM 7/2/2012 Subject: Modular Approval Requirements for FCC certification for Sensus 520Q Product. Reference: FCC ID: SDB520Q Dear Application Examiner, Sensus 520Q Product is seeking modular approval for FCC ID: SDB520Q This document is to attest that the radio bearing the FCC ID: SDB520Q meets the requirements for a modular approval as detailed in the FCC public notice DA00-1407. Compliance to each requirement is described below: 1. The modular transmitter has its own RF shielding. 2. The modular transmitter has buffered modulation/data inputs. 3. The modular transmitter has its own power supply regulation. 4. The modular transmitter complies with the antenna requirements of Section 15.203 and 15.204(c). (The antenna must either be permanently attached or employ a “unique” antenna coupler (at all connections between the module and the antenna, including the cable). 5. The modular transmitter has been tested in a stand-alone configuration, 6. The modular transmitter is labeled with its own FCC ID number. 7. The modular transmitter complies with any specific rule or operating requirements applicable to the transmitter and the manufacturer must provide adequate instructions along with the module to explain any such requirements. 8. The modular transmitter complies with any applicable RF exposure requirements. Sincerely, Al Servais | Reliability and Compliance Program Manager 639 Davis Drive | Morrisville, NC 27560 USA T: 919-317-6351 | C: 919-208-8983 | [email protected] | www.sensus.com

Reliability and Compliance T: 919-317-6351 639 Davis Drive F: 919-317-6210 Morrisville, NC 27560 USA www.sensus.com Monday, July 02, 2012 Federal Communications Commission Authorization and Evaluation Division 1435 Oakland Mills Road Columbia, MD 21046 Subject: Confidentiality Request regarding application for certification of FCC ID: SDB520Q Pursuant to Sections 0.457 and 0.459 of the Commission’s Rules, we hereby request confidential treatment of information accompanying this application as outlined below: Exhibit Type File Name Justification Schematic 12-2066 - Schematics.pdf Proprietary Information and Trade Secret Parts List 12-2066 - BOM_Parts List.pdf Proprietary Information and Trade Secret Theory Of Operation 12-2066 - Theory of Operation.pdf Proprietary Information and Trade Secret Manual 12-2066 - User Manual.pdf Proprietary Information and Trade Secret Internal Photos 12-2066 - Internal Photos.pdf Proprietary Information and Trade Secret Tune-Up Procedure 12-2066 - Tune-Up Procedure.pdf Proprietary Information and Trade Secret Block Diagram 12-2066 - Block Diagram.pdf Proprietary Information and Trade Secret Confidentiality of the Internal Photos is being requested because this is a non-consumer device which is not accessible by the general public and is only serviceable by the applicant or designated technicians. The Manual is technical and is not provided to the consumer because the consumer cannot service or install the device. Therefore confidentiality of the Manual is also requested. The above materials contain trade secrets and proprietary information not customarily released to the public. The public disclosure of these materials may be harmful to the applicant and provide unjustified benefits to its competitors. The product covered by this Confidentiality Request may or may not be sold to any OEM and is only installed in Sensus Products by Sensus Employees or Contractors. The applicant understands that pursuant to Section 0.457 of the Rules, disclosure of this application and all accompanying documentation will not be made before the date of the Grant for this application. Sincerely, Al Servais | Reliability and Compliance Program Manager 639 Davis Drive | Morrisville, NC 27560 USA T: 919-317-6351 | C: 919-208-8983 | [email protected] | www.sensus.com

3998 FAU Blvd. Suite 310 Boca Raton, FL 33431 Tel: 561-961-5585 Fax: 561-961-5587 Certification Exhibit FCC ID: SDB520Q FCC Rule Part: Part 90 Subpart I ACS Project: 12-2066 Manufacturer: Sensus Metering Systems, Inc. Model: 520Q External Photos Model: 520Q FCC ID: SDB520Q ACS Project: 12-2066 Advanced Compliance Solutions Page 2 The 520Q is a modular device in which internal photos have been held confidential. There are no associated external photographs considering the modular classification.

3998 FAU Blvd. Suite 310 Boca Raton, FL 33431 Tel: 561-961-5585 Fax: 561-961-5587 Certification Exhibit FCC ID: SDB520Q FCC Rule Part: Part 90 Subpart I ACS Project: 12-2066 Manufacturer: Sensus Metering Systems, Inc. Model: 520Q Label Information Model: 520Q FCC ID: SDB520Q ACS Project: 12-2066 Advanced Compliance Solutions Page 2 Figure1: 520Q Module – Label and Location (Top View) Model: 520Q FCC ID: SDB520Q ACS Project: 12-2066 Advanced Compliance Solutions Page 3 Figure 2: 520Q Module – Label and Location (Bottom View) Model: 520Q FCC ID: SDB520Q ACS Project: 12-2066 Advanced Compliance Solutions Page 4 Figure 3: Host Sample Label

3998 FAU Blvd. Suite 310 Boca Raton, FL 33431 Tel: 561-961-5585 Fax: 561-961-5587 Certification Exhibit FCC ID: SDB520Q FCC Rule Part: Part 90 Subpart I ACS Project Number: 12-2066 Manufacturer: Sensus Metering Systems, Inc. Model: 520Q RF Exposure Model: 520Q FCC ID: SDB520Q General Information: Applicant: Sensus Metering Systems, Inc. ACS Project: 12-2066 Device Category: Mobile Environment: General Population/Uncontrolled Exposure Technical Information: Antenna Type: Dipole Antenna Gain: -2 dBi Maximum Transmitter Conducted Power: 28.87 dBm Maximum System EIRP: 26.87 dBm, 486.41 mW Exposure Conditions: Greater than 20 centimeters MPE Calculation The Power Density (mW/cm 2 ) is calculated as follows: S = 2 4R PG π Where: S = power density (in appropriate units, e.g. mW/cm2) P = power input to the antenna (in appropriate units, e.g., mW) G = power gain of the antenna in the direction of interest relative to an isotropic radiator R = distance to the center of radiation of the antenna (appropriate units, e.g., cm) MPE Calculator for Mobile Equipment Limits for General Population/Uncontrolled Exposure* 451.037528.870.30770.90-20.631 200.097 Power Density (mW/cm^2) Distance (cm) Transmit Frequency (MHz) Radio Power (dBm) Power Density Limit (mW/Cm2) Radio Power (mW) Antenna Gain (dBi) Antenna Gain (mW eq.) Installation Guidelines The installation manual should contain text similar to the following advising how to install the equipment to maintain compliance with the FCC RF exposure requirements: RF Exposure In accordance with FCC requirements of human exposure to radio frequency fields, the radiating element shall be installed such that a minimum separation distance of 20 centimeters will be maintained. Conclusion This device complies with the MPE requirements by providing adequate separation between the device, any radiating structure and the general population. ACS Project: 12-2066 Advanced Compliance Solutions Page 2

3998 FAU Blvd. Suite 310 Boca Raton, FL 33431 Tel: 561-961-5585 Fax: 561-961-5587 Certification Test Report FCC ID: SDB520Q FCC Rule Part: Part 90 Subpart I ACS Report Number: 12-2066.W03.1A Applicant: Sensus Metering Systems, Inc. Model: 520Q Test Begin Date: May 31, 2012 Test End Date: June 13, 2012 Report Issue Date: July 3, 2012 For The Scope of Accreditation Under Certificate Number AT-1533 For The Scope of Accreditation Under Lab Code 200612-0 This report must not be used by the client to claim product certification, approval, or endorsement by ACLASS, NVLAP, ANSI, or any agency of the Federal Government. Project Manager: Reviewed by: Thierry Jean-Charles Kirby Munroe EMC Engineer Director, Wireless Certifications Advanced Compliance Solutions, Inc. Advanced Compliance Solutions, Inc. This test report shall not be reproduced except in full. This report may be reproduced in part with prior written consent of ACS, Inc. The results contained in this report are representative of the sample(s) submitted for evaluation. This report contains 35 pages ACS Report: 12-2066.W03.1A Advanced Compliance Solutions Page 2 of 35 Table of Content 1.0 GENERAL----------------------------------------------------------------------------------------------------------------------3 1.1 PURPOSE---------------------------------------------------------------------------------------------------------------------3 1.2 PRODUCT DESCRIPTION----------------------------------------------------------------------------------------------------3 1.3 TEST METHODOLOGY-------------------------------------------------------------------------------------------------------3 1.4 EMISSION DESIGNATORS---------------------------------------------------------------------------------------------------4 2.0 TEST FACILITIES-----------------------------------------------------------------------------------------------------------5 2.1 LOCATION---------------------------------------------------------------------------------------------------------------------5 2.2 LABORATORY ACCREDITATIONS/RECOGNITIONS/CERTIFICATIONS-------------------------------------------------5 2.3 RADIATED & CONDUCTED EMISSIONS TEST SITE DESCRIPTION-----------------------------------------------------6 3.0 APPLICABLE STANDARD REFERENCES--------------------------------------------------------------------------7 4.0 LIST OF TEST EQUIPMENT----------------------------------------------------------------------------------------------8 5.0 SUPPORT EQUIPMENT---------------------------------------------------------------------------------------------------9 6.0 EQUIPMENT UNDER TEST SETUP AND BLOCK DIAGRAM--------------------------------------------------9 7.0 SUMMARY OF TESTS--------------------------------------------------------------------------------------------------- 10 7.1 RF POWER OUTPUT------------------------------------------------------------------------------------------------------ 10 7.2 OCCUPIED BANDWIDTH (EMISSION LIMITS)--------------------------------------------------------------------------- 13 7.3 SPURIOUS EMISSIONS AT ANTENNA TERMINALS--------------------------------------------------------------------- 25 7.4 FIELD STRENGTH OF SPURIOUS EMISSIONS-------------------------------------------------------------------------- 28 7.5 FREQUENCY STABILITY--------------------------------------------------------------------------------------------------- 30 7.6 TRANSIENT FREQUENCY BEHAVIOR------------------------------------------------------------------------------------ 34 8.0 CONCLUSION-------------------------------------------------------------------------------------------------------------- 35 Model: 520Q FCC ID: SDB520Q ACS Report: 12-2066.W03.1A Advanced Compliance Solutions Page 3 of 35 1.0 GENERAL 1.1 Purpose The purpose of this report is to demonstrate compliance with Part 2 Subpart J, and Part 90 Subpart I of the FCC’s Code of Federal Regulations for a modular approval. 1.2 Product Description The 520Q is a transceiver module that is configured using an RF interface. The unit provides wireless communication capability to a variety of register read, TouchCoupler water meters and TFRs. The 520Q can be connected to one or two meters simultaneously each of independent type and protocol. The device will communicate via the Sensus fixed wireless telemetry network to provide meter readings and diagnostic data from the meter to the utility provider via radio. Manufacturer Information: Sensus Metering Systems, Inc. 639 Davis Drive Morrisville, NC 27560 Test Sample Serial Numbers: 14003004, 14003024 Test Sample Condition: The unit was in good operating conditions with no physical damages. 1.3 Test Methodology 1.3.1 Configurations and Justification The 520Q was tested in accordance to WT Docket No. 11-56, DA 11-1316 which waives 47 CFR 90.203(j) from the test requirements. For the RF conducted measurements, the EUT was modified with a temporary RF connector at the antenna port. For the Radiated emissions, the EUT was evaluated in the orientation of typical installation. The 520Q provides multiple modulations formats/modes all of which were evaluated and the worst case data are presented were applicable. The evaluation for unintentional emissions is documented separately in a verification report. Model: 520Q FCC ID: SDB520Q ACS Report: 12-2066.W03.1A Advanced Compliance Solutions Page 4 of 35 1.3.2 In-Band Testing Methodology The EUT band of operation is provided in the table below. CFR Title 47 Rule Part Frequency Band of Operation (MHz) 90 451.0375 – 463.7875 Based on the requirements set forth in accordance 47 CFR 2.1046-2.1057 as stated above, the methodology in selecting the places to test in the available bands of operation is outlined in the following table. CFR Title 47 Rule Part Frequency Band of Operation (MHz) Location in the Range of Operation Approx. Test Freq. 451.0375 457.4125 90 451.0375 – 463.7875 1 near top, 1 near middle and 1 near bottom 4…

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3998 FAU Blvd. Suite 310 Boca Raton, FL 33431 Tel: 561-961-5585 Fax: 561-961-5587 Certification Exhibit FCC ID: SDB520Q FCC Rule Part: Part 90 Subpart I ACS Project: 12-2066 Manufacturer: Sensus Metering Systems, Inc. Model: 520Q Test Setup Photos Model: 520Q FCC ID: SDB520Q ACS Project: 12-2066 Advanced Compliance Solutions Page 2 Figure 1: Radiated Emissions – Front View Model: 520Q FCC ID: SDB520Q ACS Project: 12-2066 Advanced Compliance Solutions Page 3 Figure 2: Radiated Emissions – Back View Model: 520Q FCC ID: SDB520Q ACS Project: 12-2066 Advanced Compliance Solutions Page 4 Figure 3: RF Conducted Emissions