SDBRGS10Utility Meter Transceiver

400 Perimeter Park Drive T: 919-379-1951 Suite K F: 919-463-7706 Morrisville, NC 27560 USA www.sensus.com LETTER OF AUTHORIZATION Tuesday, July 12, 2011 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 RGS10 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 RGS10 and FCC IDENTIFIER SDBRGS10 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 RGS10 ONLY, and shall not be utilized for any other matters on the behalf of Sensus. Sincerely, Al Servais | EMC Compliance Technical Member 400 Perimeter Park Drive | Suite K | Morrisville, NC 27560 USA T: 919-379-1951 | C: 919-208-8983 | [email protected] | www.sensus.com

400 Perimeter Park Drive T: 919-379-1951 Suite K F: 919-463-7706 Morrisville, NC 27560 USA www.sensus.com 1 of 4 Sensus Non Sensus NonSensus Non Sensus Non- -- -Disclosure Disclosure Disclosure Disclosure Memorandum MemorandumMemorandum Memorandum August 25, 2011 Sensus OEMs: This memorandum serves as an additional agreement between Sensus and its OEMs stating that the OEMs will use the Sensus RGS10 module (See Appendix 1) in accordance with the FCC rules on modular approved devices. The Sensus RGS10 Transceiver is professionally installed inside various Sensus Gas Shut-Off Devices (See Appendix 2). The module label will be located either on the side of the host and will display both the FCC and IC IDs of the RGS10 module. 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, which is professionally installed, and is only serviceable by Sensus, or designated technicians (See Appendix 3). The modular device resides in a hermetically sealed HDPE enclosure that is mounted within the valve assembly made of cast iron. The assembly hardware is sealed with looping wire that is crimped and sealed with rock seals. 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 4 Sensus No Sensus NoSensus No Sensus Non nn n- -- -Disclosure Memorandum Disclosure MemorandumDisclosure Memorandum Disclosure Memorandum Appendix 1 Appendix 1Appendix 1 Appendix 1 3 of 4 Sensus Non Sensus NonSensus Non Sensus Non- -- -Disclosure Memorandum Disclosure MemorandumDisclosure Memorandum Disclosure Memorandum Appendix 2 Appendix 2Appendix 2 Appendix 2 4 of 4 Sensus Non Sensus NonSensus Non Sensus Non- -- -Disclosure Memorandum Disclosure MemorandumDisclosure Memorandum Disclosure Memorandum Appendix Appendix Appendix Appendix 3 33 3 Rock Seal in place HDPE Plastic with radio molded within

400 Perimeter Park Drive T: 919-379-1951 Suite K F: 919-463-7706 Morrisville, NC 27560 USA www.sensus.com Friday July 29, 2011 Federal Communications Commission Authorization and Evaluation Division 1435 Oakland Mills Road Columbia, MD 21046 Subject: Confidentiality Request regarding application for certification of FCC ID: SDBRGS10 Sensus Metering Systems, Inc. respectfully requests confidentiality of certain materials provided with the submission of the RGS10 in accordance with 47 CFR 0.459. Pursuant to 47 CFR 0.457(d) of the FCC Rules, information that is considered trade secret and not routinely available to the public may also be withheld from public inspection if a request for non-disclosure is submitted pursuant to 47 CFR 0.459. This confidentiality request applies to the schematics, parts list, theory of operation, manual, internal photos, tune-up procedure and system block diagram contained in the following exhibits: Exhibit Type File Name Justification Schematic 10-0300 – Schematics.pdf Proprietary Information and Trade Secret Parts List 10-0300 – Parts List.pdf Proprietary Information and Trade Secret Theory Of Operation 10-0300 – Theory of Operation.pdf Proprietary Information and Trade Secret Manual 10-0300 – Manual.pdf Proprietary Information and Trade Secret Internal Photos 10-0300 – Internal Photos.pdf Proprietary Information and Trade Secret Tune-Up Procedure 10-0300 – Tune-up Procedure.pdf Proprietary Information and Trade Secret System Block Diagram 10-0300 – System 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 is not 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 400 Perimeter Park Drive | Suite K | Raleigh, NC 27560 USA T: 919-379-1951 | C: 919-208-8983 | [email protected] | www.sensus.com

5015 B. U. Bowman Dr. Buford, GA 30518 July 27, 2011 ACS TCB 5015 B.U. Bowman Drive Buford, GA 30518 Re: FCC ID: SDBRGS10 To Whom It May Concern: The following application is submitted on behalf of our client, Sensus Metering Systems, Inc., for evaluation of their model RGS10 for certification under FCC Part 24, 90, and 101. The RGS10 meter module is a battery-powered module that provides wireless communication capability to a variety of gas meters. Sincerely, Sam Wismer Vice President, Technology Advanced Compliance Solutions, Inc.

400 Perimeter Park Drive T: 919-379-1951 Suite K F: 919-463-7706 Morrisville, NC 27560 USA www.sensus.com MODULAR APPROVAL REQUEST FORM 7/12/2011 Subject: Modular Approval Requirements for FCC certification for Sensus RGS10 Product. Reference: FCC ID: SDBRGS10 Dear Application Examiner, Sensus DNP-RMTII-MA-FLX-900 Product is seeking modular approval for FCC ID: SDBRGS10 This document is to attest that the radio bearing the FCC ID: SDBRGS10 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 must have its own RF shielding. 2. The modular transmitter must have buffered modulation/data inputs. 3. The modular transmitter must have its own power supply regulation. 4. The modular transmitter must comply 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 must be tested in a stand-alone configuration, 6. The modular transmitter must be labeled with its own FCC ID number. 7. The modular transmitter must comply 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 must comply with any applicable RF exposure requirements. Sincerely, Al Servais | EMC Compliance Technical Member 400 Perimeter Park Drive | Suite K | Morrisville, NC 27560 USA T: 919-379-1951 | C: 919-208-8983 | [email protected] | www.sensus.com

5015 B.U. Bowman Drive Buford, GA 30518 USA Voice: 770-831-8048 Fax: 770-831-8598 Certification Exhibit FCC ID: SDBRGS10 IC: 2220A-RGS10 FCC Rule Part: CFR 47 Part 24 Subpart D, Part 90 Subpart I, Part 101 Subpart C IC Radio Standards Specification: RSS 119, RSS 134 ACS Report Number: 10-0300.W06.11.A Manufacturer: Sensus Metering Systems, Inc. Model: RGS10 External Photos Model: RGS10 FCC ID: SDBRGS10 IC: 2220A-RGS10 ACS Report: 10-0300.W06.11.A Advanced Compliance Solutions Page 2 The RGS10 is a modular device in which internal photos have been held confidential. There are no associated external photographs considering the modular classification.

5015 B.U. Bowman Drive Buford, GA 30518 USA Voice: 770-831-8048 Fax: 770-831-8598 Certification Exhibit FCC ID: SDBRGS10 IC: 2220A-RGS10 FCC Rule Part: CFR 47 Part 24 Subpart D, Part 90 Subpart I, Part 101 Subpart C IC Radio Standards Specification: RSS 119, RSS 134 ACS Report Number: 10-0300.W06.11.A Manufacturer: Sensus Metering Systems, Inc. Model: RGS10 Label Information

5015 B.U. Bowman Drive Buford, GA 30518 USA Voice: 770-831-8048 Fax: 770-831-8598 Certification Exhibit FCC ID: SDBRGS10 IC: 2220A-RGS10 FCC Rule Part: CFR 47 Part 24 Subpart D, Part 90 Subpart I, Part 101 Subpart C IC Radio Standards Specification: RSS 119, RSS 134 ACS Report Number: 10-0300.W06.11.A Manufacturer: Sensus Metering Systems, Inc. Model: RGS10 RF Exposure Model: RGS10 FCC ID: SDBRGS10 IC: 2220A-RGS10 ACS Report: 10-0300.W06.11.A Advanced Compliance Solutions Page 2 General Information: Applicant: Sensus Metering Systems, Inc. ACS Project: 10-0300 Device Category: Mobile Environment: General Population/Uncontrolled Exposure Technical Information: Antenna Type: Printed folded dipole antenna Antenna Gain: 2 dBi Maximum Transmitter Conducted Power: 27.02dBm, 504mW Maximum System EIRP: 29.02 dBm, 798 mW Exposure Conditions: Greater than 20 centimeters MPE Calculation The Power Density (mW/cm 2 ) is calculated as follows: S = 2 4R PG  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* 941.487527.020.63503.5021.585 200.159 Power De nsity (mW/cm^2) Dista nce (cm) Transmit Frequency (MHz) Radio Power (dBm) Power Density Limit (mW/Cm2) Radio Power (mW) Ante nna 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.

5015 B.U. Bowman Drive Buford, GA 30518 USA Voice: 770-831-8048 Fax: 770-831-8598 Certification Test Report FCC ID: SDBRGS10 IC: 2220A-RGS10 FCC Rule Part: CFR 47 Part 24 Subpart D, Part 90 Subpart I, Part 101 Subpart C IC Radio Standards Specification: RSS 119, RSS 134 ACS Report Number: 10-0300.W06.11.A Manufacturer: Sensus Metering Systems, Inc. Model: RGS10 Test Begin Date: March 8, 2011 Test End Date: March 9, 2011 Report Issue Date: July 29, 2011 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 NVLAP, NIST, or any agency of the Federal Government. Reviewed by: Kirby Munroe Director, Wireless Certifications ACS, 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 43 pages ACS Report: 10-0300.W06.11.A Advanced Compliance Solutions Page 2 Table of Contents 1.0 GENERAL 3 1.1 Purpose 3 1.2 Product Description 3 1.3 Test Methodology 3 1.3.1 Test Configurations and Justification 3 1.3.2 In-Band Testing Methodology 3 1.4 Emission Designators 4 2.0 TEST FACILITIES 5 2.1 Location 5 2.2 Laboratory Accreditations/Recognitions/Certifications 5 3.0 APPLICABLE STANDARD REFERENCES 5 4.0 LIST OF TEST EQUIPMENT 6 5.0 SUPPORT EQUIPMENT 7 6.0 EQUIPMENT UNDER TEST SETUP AND BLOCK DIAGRAM 7 7.0 SUMMARY OF TESTS 8 7.1 RF Power Output 8 7.1.1 Measurement Procedure 8 7.1.2 Measurement Results 8 7.2 Occupied Bandwidth (Emission Limits) 13 7.2.1 Measurement Procedure 13 7.2.2 Measurement Results 13 7.3 Spurious Emissions at Antenna Terminals 31 7.3.1 Measurement Procedure 31 7.3.2 Measurement Results 31 7.4 Frequency Stability 40 7.4.1 Measurement Procedure 40 7.4.2 Measurement Results 40 8.0 CONCLUSION 43 Model: RGS10 FCC ID: SDBRGS10 IC: 2220A-RGS10 ACS Report: 10-0300.W06.11.A Advanced Compliance Solutions Page 3 1.0 GENERAL 1.1 Purpose The purpose of this report is to demonstrate compliance with CFR 47 Part 24 Subpart D, Part 90 Subpart I, and Part 101 Subpart C of the FCC’s Code of Federal Regulations; and RSS 119 and 134 of Industry Canada’s Radio Standard Specifications. 1.2 Product Description The RGS10 meter module is a battery-powered module that provides wireless communication capability to a variety of gas meters. Manufacturer Information: Sensus Metering Systems, Inc. 400 Perimeter Park Drive, Ste. K Raleigh, NC 27560 Test Sample Serial Numbers: 23009971 Test Sample Condition: The test samples were provided in good working order with no visible defects. 1.3 Test Methodology 1.3.1 Test Configurations and Justification For RF conducted measurements, the RGS10 was modified with an external RF connector to the PCB. The RGS10 utilizes a non-detachable antenna for normal operation but for RF conducted testing the antennas were disconnected and a 50-Ohm test cable soldered (with the appropriate ground connection) to the PCB. The RGS10 operates using various modulation formats/modes all of which were evaluated and worst case data presented where applicable. 1.3.2 In-Band Testing Methodology For testing in accordance with 47 CFR 2.1046-2.1057, OET/Lab recommends that the following be used to select test frequencies for licensed devices: Frequency range over which device operates Number of frequencies Location in the range of operation 1 MHz or less 1 Middle 1 to 10 MHz 2 1 near top and 1 near bottom 10 to 100 MHz 3 1 near top, 1 near middle and 1 near bottom Model: RGS10 FCC ID: SDBRGS10 IC: 2220A-RGS10 ACS Report: 10-0300.W06.11.A Advanced Compliance Solutions Page 4 The RGS10 module is designed to operate in multiple bands under the requirements of CFR 47 Parts 24, 90, and 101. The following is a list of the frequency bands of operation sorted based on the FCC rule parts in which the band is associated. CFR Title 47 Rule Part Frequency Band of Operation (MHz) 24D 901.0 - 902.0 24D 930.0 - 931.0 24D 940.0 - 941.0 90 896.0 - 901.0 90 935.0 - 940.0 101 928.85 - 929.0 101 932.0 - 932.5 101 941.0 - 941.5 101 959.85 - 960.0 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 90 896.0 - 901.0 1 near top and 1 near bottom 24D 901.0 - 902.0 101 928.85 - 929.0 Middle 24D 930.0 - 931.0 Middle 101 932.0 - 932.5 Middle 90 935.0 - 940.0 1 near top and 1 near bottom 24D 940.0 - 941.0 101 941.0 - 941.5 101 959.85 - 960.0 Middle The data provided in this report is sorted based on the rule part. 1.4 Emission Designators The RGS10 transceiver produces (7) distinct modulation formats. The emissions designators for the nine modulation types used by the RGS10 transceiver are as follows: EMISSIONS DESIGNATORS: Normal Mode: 9K60F2D (7-FSK) Double Density Mode: 9K60F2D (13-FSK) C&I Mode: 4K80F2D (7-FSK) Priority Mode: 4K80F2D (13-FSK) Boost Mode: 1K10F2D (7-FSK) MPass Mode (5K): 5K90F1D (2-GFSK) MPass Mode (10K): 11K8F1D (2-GFSK) Model: RGS10 FCC ID: SDBRGS10 IC: 2220A-RGS10 ACS Report: 10-0300.W06.11.A Advanced Compliance Solutions Page 5 2.0 TEST FACILITIES 2.1 Location The radiated and conducted emissions test sites are located at the following address: Advanced Compliance Solutions 5015 B.U. Bowman Drive Buford, GA 30518 Phone: (770) 831-8048 Fax: (770) 831-8598 2.2 Laboratory Accreditations/Recognitions/Certifications ACS is accredited to ISO/IEC 17025 by the National Institute of Standards and Technology under their National Voluntary Laboratory Accreditation Program (NVLAP), Lab Code 200612-0. Unless otherwise specified, all tests methods described within this report are covered under the ISO/IEC 17025 scope of accreditation. The Semi-Anechoic Chamber Test Site, Ope…

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3998 FAU Blvd. Suite 310 Boca Raton, FL 33431 Tel: 561-961-5585 Fax: 561-961-5587 Certification Test Report FCC ID: SBDRGS10 IC: 2220A-RGS10 FCC Rule Part: CFR 47 Part 24 Subpart D, Part 90 Subpart I, Part 101 Subpart C IC Radio Standards Specification: RSS 119, RSS 134 ACS Report Number: 11-2015.W06.11.A This report contains data that are not covered by the NVLAP accreditation Applicant: Sensus Metering Systems, Inc. Model: RGS10 Test Begin Date: March 15, 2011 Test End Date: March 23, 2011 Report Issue Date: August 3, 2011 FOR THE SCOPE OF ACCREDITATION UNDER LAB Code 200897-0 This report is not be used to claim certification, approval, or endorsement by NVLAP, NIST or any government agency. 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 17 pages ACS Report: 11-2015.W06.11.A Advanced Compliance Solutions Page 2 of 17 Table of Content 1.0 GENERAL----------------------------------------------------------------------------------------------------------------------3 1.1 PURPOSE-----------------------------------------------------------------------------------------------------------------3 1.2 PRODUCT DESCRIPTION------------------------------------------------------------------------------------------------3 1.3 TEST METHODOLOGY---------------------------------------------------------------------------------------------------3 1.3.1 CONFIGURATIONS AND JUSTIFICATION----------------------------------------------------------------------------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----------------------------------------------------------------------8 4.0 LIST OF TEST EQUIPMENT---------------------------------------------------------------------------------------------9 6.0 EQUIPMENT UNDER TEST SETUP AND BLOCK DIAGRAM------------------------------------------------ 10 7.0 SUMMARY OF TESTS--------------------------------------------------------------------------------------------------- 11 7.1 FIELD STRENGTH OF SPURIOUS EMISSIONS – FCC PART 2.1053, PART 90.210, PART 24.133, PART 101.111; RSS-119, RSS-134----------------------------------------------------------------------------------------------11 8.0 CONCLUSION-------------------------------------------------------------------------------------------------------------- 16 Model: RGS10 FCC ID: SDBRGS10 IC: 2220A-RGS10 ACS Report: 11-2015.W06.11.A Advanced Compliance Solutions Page 3 of 17 1.0 GENERAL 1.1 Purpose The purpose of this report is to demonstrate compliance with Part 2 Subpart J, Part 24 Subpart D, Part 90 Subpart I and Part 101 Subpart C of the FCC’s Code of Federal Regulations; and RSS 119 and RSS 134 of Industry Canada’s Radio Standard Specifications. 1.2 Product Description The RGS10 meter module is a battery-powered module that provides wireless communication capability to a variety of gas meters. Manufacturer Information: Sensus Metering Systems, Inc. 400 Perimeter Park Drive, Suite K Morrisville, NC 27560 Test Sample Serial Numbers: 23009988 Test Sample Condition: The test samples were provided in good working order with no visible defects. 1.3 Test Methodology 1.3.1 Configurations and Justification The EUT was evaluated for radiated emissions up to the 10 th harmonic. The EUT was setup in the orientation of typical installation. The RGS10 operates using various modulation formats/modes all of which were evaluated and worst case data presented where applicable. 1.3.2 In-Band Testing Methodology For testing in accordance with 47 CFR 2.1046-2.1057, OET/Lab recommends that the following be used to select test frequencies for licensed devices: Frequency range over which device operates Number of frequencies Location in the range of operation 1 MHz or less 1 Middle 1 to 10 MHz 2 1 near top and 1 near bottom 10 to 100 MHz 3 1 near top, 1 near middle and 1 near bottom Model: RGS10 FCC ID: SDBRGS10 IC: 2220A-RGS10 ACS Report: 11-2015.W06.11.A Advanced Compliance Solutions Page 4 of 17 The RGS10 module is designed to operate in multiple bands under the requirements of CFR 47 Parts 24, 90, and 101. The following is a list of the frequency bands of operation sorted based on the FCC rule parts in which the band is associated. CFR Title 47 Rule Part Frequency Band of Operation (MHz) 24D 901.0 - 902.0 24D 930.0 - 931.0 24D 940.0 - 941.0 90 896.01875 - 901.0* 90 935.0 - 940.0 101 928.85 - 929.0 101 932.0 - 932.5 101 941.0 - 941.5 101 959.85 - 959.95* 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 90 896.01875 - 901.0* 24D 901.0 - 902.0 1 near top and 1 near bottom 101 928.85 - 929.0 Middle 24D 930.0 - 931.0 Middle 101 932.0 - 932.5 Middle 90 935.0 - 940.0 24D 940.0 - 941.0 101 941.0 - 941.5 1 near top and 1 near bottom 101 959.85 - 959.95* Middle The data provided in this report is sorted based on the rule part. *NOTE: The EUT does not c…

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