SDBZIGELS01Sensus Metering Systems Wireless Telemetry Module

Reliability and Compliance T: 919-317-6351 639 Davis Drive F: 919-317-6210 Morrisville, NC 27560 USA www.sensus.com LETTER OF AUTHORIZATION Tuesday, February 21, 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 ZIGELS01 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 ZIGELS01 and FCC IDENTIFIER SDBZIGELS01 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 ZIGELS01ONLY, 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

5015 B. U. Bowman Dr. Buford, GA 30518 February 23, 2012 ACS TCB 5015 B.U. Bowman Drive Buford, GA 30518 Re: FCC ID: SDBZIGELS01 To Whom It May Concern: The following application is submitted on behalf of our client, Sensus Metering Systems, Inc., for evaluation of their model ZIGELS01 for certification under FCC Part 15.247. The ZIGELS01 is a stand-alone module consisting of a single printed circuit board which is designed to be integrated into specific host devices. The ZIGELS01 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.

Reliability and Compliance T: 919-317-6351 639 Davis Drive F: 919-317-6210 Morrisville, NC 27560 USA www.sensus.com Sensus Non-Disclosure Memorandum February 21, 2012 Sensus OEMs: This memorandum serves as an additional agreement between Sensus and its OEMs stating that the OEMs will use the Sensus ZIGELS01 module (See Appendix 1) in accordance with the FCC rules on modular approved devices. The Sensus ZIGELS01 Transceiver is professionally installed inside various Sensus 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 ZIGELS01 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 1 of 3 2 of 3 Sensus Non-Disclosure Memorandum Appendix 1 3 of 3 Sensus Non-Disclosure Memorandum Appendix 2

Reliability and Compliance T: 919-317-6351 639 Davis Drive F: 919-317-6210 Morrisville, NC 27560 USA www.sensus.com Tuesday, February 21, 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: SDBZIGELS01 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 11-2108 - Schematics.pdf Proprietary Information and Trade Secret Theory Of Operation 11-2108 - Theory of Operation.pdf Proprietary Information and Trade Secret Manual 11-2108 - User Manual.pdf Proprietary Information and Trade Secret Internal Photos 11-2108 - Internal Photos.pdf Proprietary Information and Trade Secret Block Diagram 11-2108 - 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

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 3/15/2012 Subject: Modular Approval Requirements for FCC certification for Sensus ZIGELS01 Product. Reference: FCC ID: SDBZIGELS01 Dear Application Examiner, Sensus ZIGELS01 Product is seeking modular approval for FCC ID: SDBZIGELS01 This document is to attest that the radio bearing the FCC ID: SDBZIGELS01 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

3998 FAU Blvd. Suite 310 Boca Raton, FL 33431 Tel: 561-961-5585 Fax: 561-961-5587 Certification Exhibit FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 FCC Rule Part: CFR 47 Part 15.247 IC Radio Standards Specification: RSS 210 ACS Project: 11-2108 Manufacturer: Sensus Metering Systems, Inc. Model: ZIGELS01 External Photos Model: ZIGELS01 FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 The ZIGELS01 is a modular device in which internal photos have been held confidential. There are no associated external photographs considering the modular classification. ACS Project: 11-2108 Advanced Compliance Solutions Page 2

3998 FAU Blvd. Suite 310 Boca Raton, FL 33431 Tel: 561-961-5585 Fax: 561-961-5587 Certification Exhibit FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 FCC Rule Part: CFR 47 Part 15.247 IC Radio Standards Specification: RSS 210 ACS Project: 11-2108 Manufacturer: Sensus Metering Systems, Inc. Model: ZIGELS01 Label Information Model: ZIGELS01 FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 ACS Project: 11-2108 Advanced Compliance Solutions Page 2 Figure 1: Sample Label Figure 2: Label Location (Bottom of PCB) Model: ZIGELS01 FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 ACS Project: 11-2108 Advanced Compliance Solutions Page 3 Figure 3: Sample Host Label

3998 FAU Blvd. Suite 310 Boca Raton, FL 33431 Tel: 561-961-5585 Fax: 561-961-5587 Certification Exhibit FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 FCC Rule Part: 15.247 IC Radio Standards Specification: RSS-210 ACS Project Number: 11-2108 Manufacturer: Sensus Metering Systems, Inc. Model: ZIGELS01 RF Exposure Model: ZIGELS01 FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 ACS Project: 11-2108 Advanced Compliance Solutions Page 2 General Information: Applicant: Sensus Metering Systems, Inc. ACS Project: 11-2108 Device Category: Mobile Environment: General Population/Uncontrolled Exposure Technical Information: Antenna Type: Inverted-F Antenna Gain: 0 dBi Maximum Transmitter Conducted Power: 12.08 dBm Maximum System EIRP: 12.08 dBm, 16.14 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* 240512.081.0016.1401.000 20 244010.581.0011.4301.00020 248010.031.0010.0701.00020 Distan (cm) Transmit Frequency (MHz) Radio Power (dBm) Power Density Limit (mW /Cm2) Radio Power (mW) Antenna Gain (dBi) Antenna Gain (mW e q.) 0.003 0.002 0.002 Power De nsity (mW/cm^2) ce 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.

3998 FAU Blvd. Suite 310 Boca Raton, FL 33431 Tel: 561-961-5585 Fax: 561-961-5587 Certification Test Report FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 FCC Rule Part: 15.247 IC Radio Standards Specification: RSS-210 ACS Report Number: 11-2108.W06.11.A Manufacturer: Sensus Metering Systems, Inc. Model: ZIGELS01 Test Begin Date: November 19, 2011 Test End Date: November 22, 2011 Report Issue Date: December 19, 2011 FOR THE SCOPE OF ACCREDITATION UNDER CERTIFICATE NUMBER AT-1533 This report must not be used by the client to claim product certification, approval, or endorsement by ACLASS, 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 32 pages TABLE OF CONTENTS 1 GENERAL ......................................................................................................3 1.1 Purpose .............................................................................................................................................. 3 1.2 Product description .......................................................................................................................... 3 1.3 Test Methodology and Considerations ........................................................................................... 3 2 TEST FACILITIES ..........................................................................................4 2.1 Location ............................................................................................................................................. 4 2.2 Laboratory Accreditations/Recognitions/Certifications ............................................................... 4 2.3 Radiated & Conducted Emissions Test Site Description .............................................................. 5 3 APPLICABLE STANDARD REFERENCES...................................................7 4 LIST OF TEST EQUIPMENT..........................................................................8 5 SUPPORT EQUIPMENT ................................................................................9 6 EQUIPMENT UNDER TEST SETUP BLOCK DIAGRAM ..............................9 7 SUMMARY OF TESTS .................................................................................11 7.1 Antenna Requirement – FCC: Section 15.203 ............................................................................. 11 7.2 6 dB Bandwidth - FCC: Section 15.247(a)(2) IC: RSS-210 A8.2(a) ........................................... 11 7.3 Peak Output Power - FCC Section 15.247(b)(3) IC: RSS-210 A8.4(4)....................................... 15 7.4 Band-Edge Compliance and Spurious Emissions-FCC 15.247(d) IC:RSS-210 A8.5................ 17 7.5 Power Spectral Density - FCC Section 15.247(e) IC: RSS-210 A8.2(b) ..................................... 27 7.6 Power Line Conducted Emissions – FCC: Section 15.207 IC: RSS-Gen 7.2.4 .......................... 29 8 CONCLUSION..............................................................................................32 Model: ZIGELS01 FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 ACS Report: 11-2108.W06.11.A Advanced Compliance Solutions Page 3 of 32 1 GENERAL 1.1 Purpose The purpose of this report is to demonstrate compliance with Part 15 Subpart C of the FCC’s Code of Federal Regulations and Industry Canada’s Radio Standards Specification RSS-210 for a modular approval. 1.2 Product description The ZIGELS01 ZigBee® module is a 2.4GHz O-QPSK radio transmitter and receiver which adhere to the IEEE 802.15.4 standard. The module can be installed within an Elster A3 electric meter with FlexNet to facilitate home-area-network (HAN) wireless communication capability. The ZigBee module when combined with a FlexNet module provides a utility with the means to communicate between a back-end system and individual devices connected to the HAN (eg in-premise display). Technical Information: Band of Operation: 2405 MHz - 2480 MHz Number of Channels: 16 Modulation Format: O-QPSK Antenna Type/Gain: Inverted F, 0 dBi Operating Voltage: 13 VDC Manufacturer Information: Sensus Metering Systems, Inc. 639 Davis Drive Morrisville, NC 27560 Test Sample Serial Number(s): 1D2301000164E4, 1D2301000164E8, 1D2301000164EA Test Sample Condition: The test samples were provided in good working order with no visible defects. 1.3 Test Methodology and Considerations For radiated emissions, including band edge, the EUT was evaluated in the orientation of typical installation. For the purpose of RF conducted measurements, the module was modified with a temporary 50 ohm SMA connector at the antenna port. The power line conducted emissions evaluation were performed for the EUT inserted inside of an Elster meter which was acting as a host. The power line conducted emission results are reported for the configuration leading to the highest emissions. The unintentional emissions evaluations are documented separately in a Verification Report. Model: ZIGELS01 FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 ACS Report: 11-2108.W06.11.A Advanced Compliance Solutions Page 4 of 32 2 TEST FACILITIES 2.1 Location The radiated and conducted emissions test sites are located at the following address: Advanced Compliance Solutions, Inc. 3998 FAU Blvd, Suite 310 Boca Raton, Florida 33431 Phone: (561) 961-5585 Fax: (561) 961-5587 www.acstestlab.com FCC Test Firm Registration #: 587595 Industry Canada Lab Code: 4175C 2.2 Laboratory Accreditations/Recognitions/Certifications ACS is accredited to ISO/IEC 17025 by ANSI-ASQ National Accreditation Board under their ACLASS program and has been issued certificate number AT-1533 in recognition…

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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: SDBZIGELS01 IC: 2220A-ZIGELS01 FCC Rule Part: CFR 47 Part 15.247 IC Radio Standards Specification: RSS 210 ACS Project: 11-2108 Manufacturer: Sensus Metering Systems, Inc. Model: ZIGELS01 Test Setup Photos Model: ZIGELS01 FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 Figure 1: Radiated Emissions – Front View ACS Project: 11-2108 Advanced Compliance Solutions Page 2 Model: ZIGELS01 FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 Figure 2: Radiated Emissions – Back View ACS Project: 11-2108 Advanced Compliance Solutions Page 3 Model: ZIGELS01 FCC ID: SDBZIGELS01 IC: 2220A-ZIGELS01 Figure 3: RF Conducted Emissions ACS Project: 11-2108 Advanced Compliance Solutions Page 4