SDBWFLIntegrated Flexnet WFL 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 Wednesday August 25, 2010 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 WFL 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 WFL and FCC IDENTIFIER SDBWFL 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 WFL 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 Wednesday August 25, 2010 Federal Communications Commission Authorization and Evaluation Division 1435 Oakland Mills Road Columbia, MD 21046 Subject: Confidentiality Request regarding application for certification of FCC ID: SDBWFL 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 09-0282 – Schematics.pdf Proprietary Information and Trade Secret Parts List 09-0282 – Parts List.pdf Proprietary Information and Trade Secret Theory Of Operation 09-0282 – Theory of Operation.pdf Proprietary Information and Trade Secret Manual 09-0282 – Manual.pdf Proprietary Information and Trade Secret Internal Photos 09-0282 – Internal Photos.pdf Proprietary Information and Trade Secret Tune-Up Procedure 09-0282 – Tune-up Procedure.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

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 Sensus OEMs: This memorandum serves as an additional agreement between Sensus and its OEMs stating that the OEMs will use the Sensus FlexNet module (See Appendix 1) in accordance with the FCC rules on modular approved devices. The Sensus FlexNet Transceiver is professionally installed inside various Sensus and third party meters (See Appendix 2). The module label will be located either on the side of the host meter or on the front of the host meter and will display both the FCC and IC IDs of the FlexNet 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, 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 4 Sensus Non Sensus NonSensus Non Sensus Non- -- -Disclosure Memorandum Disclosure MemorandumDisclosure Memorandum Disclosure Memorandum Appendix 1 Appendix 1Appendix 1 Appendix 1- -- - A AA A (T (T(T (T- -- -Version) Version)Version) Version) 3 of 4 Appendix 1 Appendix 1Appendix 1 Appendix 1- -- - B BB B (SOH Version) (SOH Version)(SOH Version) (SOH Version) 4 of 4 Sensus Non Sensus NonSensus Non Sensus Non- -- -Disclosure Memorandum Disclosure MemorandumDisclosure Memorandum Disclosure Memorandum Appendix 2 Appendix 2Appendix 2 Appendix 2 ( (( (Radio/Meter Interface) Radio/Meter Interface)Radio/Meter Interface) Radio/Meter Interface)

5015 B. U. Bowman Dr. Buford, GA 30518 September 7, 2010 ACS TCB 5015 B.U. Bowman Drive Buford, GA 30518 Re: FCC ID: SDBWFL To Whom It May Concern: The following application is submitted on behalf of our client Sensus Metering Systems, Inc. for evaluation of their model WFL for Certification under CFR 47 Part 24 Subpart D, Part 90 Subpart I, and Part 101. The WFL is a stand-alone module consisting of a single printed circuit board which is designed to be integrated into specific host devices. The WFL model applies to two PCB variants, at the modular level. Where the two boards differ is in the endpoint form factor and end use. This difference requires a unique shape of the PCB for the different endpoint form factors. Both PCB variants are electrically identical. The WFL was tested in full to the requirements of the aforementioned rules and was found to be in compliance. Sincerely, Sam Wismer Vice President, Technology Advanced Compliance Solutions, Inc.

5015 B.U. Bowman Drive Buford, GA 30518 USA Voice: 770-831-8048 Fax: 770-831-8598 Certification Exhibit FCC ID: SDBWFL IC: 2220A-WFL 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: 09-0282.W06.11.A Applicant: Sensus Metering Systems Model: WFL External Photos Model: WFL FCC ID: SDBWFL IC: 2220A-WFL ACS Report: 09-0282.W06.11.A Advanced Compliance Solutions Page 2 The WFL 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: SDBWFL IC: 2220A-WFL 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: 09-0282.W06.11.A Applicant: Sensus Metering Systems Model: WFL Label Information 400 Perimeter Park Drive T: 919-379-1951 Suite K F: 919-463-7706 Morrisville, NC 27560 USA www.sensus.com 1 of 2 Sensus NA2W-Water WFL Label Information and Placement Sensus “T” Board Label and Placement Sensus SOH Board Label and Placement Sample Host Label

5015 B.U. Bowman Drive Buford, GA 30518 USA Voice: 770-831-8048 Fax: 770-831-8598 Certification Exhibit FCC ID: SDBWFL IC: 2220A-WFL 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: 09-0282.W06.11.A Applicant: Sensus Metering Systems Model: WFL RF Exposure Model: WFL FCC ID: SDBWFL IC: 2220A-WFL ACS Report: 09-0282.W06.11.A Advanced Compliance Solutions Page 2 General Information: Applicant: Sensus Metering Systems, Inc. ACS Project: 09-0282 Device Category: Mobile Environment: Uncontrolled/General Population Technical Information: Antenna Type: PCB Printed Monopole Antenna Gain: -3dBi Maximum Transmitter Conducted Power: 30.25dBm Maximum System EIRP: 27.25dBm, 0.531 W 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 896.0187529.420.60874.98-30.501 200.087 928.92530.070.621016.25-30.501 200.101 959.92530.250.641059.25-30.501 200.106 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.

5015 B.U. Bowman Drive Buford, GA 30518 USA Voice: 770-831-8048 Fax: 770-831-8598 Certification Test Report FCC ID: SDBWFL IC: 2220A-WFL 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: 09-0282.W06.11.A Applicant: Sensus Metering Systems Model: WFL Test Begin Date: August 19, 2009 Test End Date: September 4, 2009 Report Issue Date: December 3, 2010 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 56 pages ACS Report: 09-0282.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 2.3 Radiated Emissions Test Site Description 6 2.3.1 Semi-Anechoic Chamber Test Site 6 2.3.2 Open Area Tests Site (OATS) 7 2.4 Conducted Emissions Test Site Description 8 3.0 APPLICABLE STANDARD REFERENCES 8 4.0 LIST OF TEST EQUIPMENT 9 5.0 SUPPORT EQUIPMENT 10 6.0 EQUIPMENT UNDER TEST SETUP AND BLOCK DIAGRAM 10 7.0 SUMMARY OF TESTS 11 7.1 RF Power Output 11 7.1.1 Measurement Procedure 11 7.1.2 Measurement Results 11 7.2 Occupied Bandwidth (Emission Limits) 16 7.2.1 Measurement Procedure 16 7.2.2 Measurement Results 16 7.3 Spurious Emissions at Antenna Terminals 36 7.3.1 Measurement Procedure 36 7.3.2 Measurement Results 36 7.4 Field Strength of Spurious Emissions 45 7.4.1 Measurement Procedure 45 7.4.2 Measurement Results – 520x (“T” Board) 45 7.4.3 Measurement Results – 510x (SOH Board) 49 7.5 Frequency Stability 52 7.5.1 Measurement Procedure 52 7.5.2 Measurement Results 53 7.6 Radiated Emissions (Unintentional Radiators/Receiver) 56 7.6.1 Measurement Procedure 56 7.6.2 Measurement Results – 520x (“T” Board) 56 7.6.3 Measurement Results – 510x (SOH Board) 56 8.0 CONCLUSION 56 Model: WFL FCC ID: SDBWFL IC: 2220A-WFL ACS Report: 09-0282.W06.11.A Advanced Compliance Solutions Page 3 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 134 of Industry Canada’s Radio Standard Specifications. 1.2 Product Description The WFL is Two Way Endpoint device used in utility metering applications. It is a battery operated transceiver hardware / software architecture which is able to support Walk By, Drive By, and Fixed Base 2-Watt operation. The WFL model applies to two PCB variants, at the modular level. Where the two boards differ is in the endpoint form factor and end use. This difference requires a unique shape of the PCB for the different endpoint form factors. The 510x or SOH board is square and located above ground on the side of the house. The 520x is the pit version or “T” board. Both PCB variants are electrically identical with respect to the RF design. Manufacturer Information: Sensus Metering Systems, Inc. 400 Perimeter Park Drive, Suite K Morrisville, NC 27560 Test Sample Serial Numbers: ACS#7 (RF conducted), ACS#3, ACS#8 (Radiated) 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 EUT was modified with an external RF connector to the PCB. The EUT utilizes non-detachable antennas 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. Both PCB variants (510x SOH Board & 520x “T” Board) are electrically identical with respect to the RF design, therefore only one version was evaluated for RF conducted measurements. Considering the models are electrically identical there are no differences in the measured characteristics between each. Based on the differences in the PCB size and shape, both variants were evaluated for radiated emissions. The WFL operates using various modulation formats/modes all of which were evaluated and worst case data present 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: WFL FCC ID: SDBWFL IC: 2220A-WFL ACS Report: 09-0282.W06.11.A Advanced Compliance Solutions Page 4 The WFL modules are 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 - 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 90 896.01…

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5015 B.U. Bowman Drive Buford, GA 30518 USA Voice: 770-831-8048 Fax: 770-831-8598 Certification Exhibit FCC ID: SDBWFL IC: 2220A-WFL 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: 09-0282.W06.11.A Applicant: Sensus Metering Systems Model: WFL Test Setup Photos Model: WFL FCC ID: SDBWFL IC: 2220A-WFL ACS Report: 09-0282.W06.11.A Advanced Compliance Solutions Page 2 Figure 1: Radiated Emissions (520x “T” Board) Model: WFL FCC ID: SDBWFL IC: 2220A-WFL ACS Report: 09-0282.W06.11.A Advanced Compliance Solutions Page 3 Figure 2: Radiated Emissions (520x “T” Board) Model: WFL FCC ID: SDBWFL IC: 2220A-WFL ACS Report: 09-0282.W06.11.A Advanced Compliance Solutions Page 4 Figure 3: Radiated Emissions (520x “T” Board) Model: WFL FCC ID: SDBWFL IC: 2220A-WFL ACS Report: 09-0282.W06.11.A Advanced Compliance Solutions Page 5 Figure 4: Radiated Emissions (510x SOH Board) Model: WFL FCC ID: SDBWFL IC: 2220A-WFL ACS Report: 09-0282.W06.11.A Advanced Compliance Solutions Page 6 Figure 5: Radiated Emissions (510x SOH Board) Model: WFL FCC ID: SDBWFL IC: 2220A-WFL ACS Report: 09-0282.W06.11.A Advanced Compliance Solutions Page 7 Figure 6: Radiated Emissions (510x SOH Board)