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FCC Part 15.247 Transmitter Certification Hybrid Spread Spectrum Transmitter Test Report FCC Rule Part: 15.247 ACS Report Number: 04-0170-15C247 Manufacturer: Onity, Inc. Equipment Type: Modular Radio Test Begin Date: May 21, 2004 Test End Date: May 25, 2004 Report Issue Date: August 6, 2004 FOR THE SCOPE OF ACCREDITATION UNDER LAB Code 200612 Reviewed by: Hernando Orozco EMI/EMC Approvals Engineer ACS, Inc. Prepared by: R. Sam Wismer Engineering Manager 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 13 pages 5015 B.U. Bowman Drive Buford, GA 30518 USA Voice: 770-831-8048 Fax: 770-831-8598

Table of Contents 1.0 General 3 1.1 Introduction 3 1.2 Product Description 3 1.2.1 Intended Use 3 2.0 Location of Test Facility 3 2.1 Description of Test Facility 3 2.1.1 Open Area Test Site 4 2.1.2 Conducted Emissions Test Site 5 3.0 Applicable Standards and References 6 4.0 List of Test Equipment 6 5.0 EUT Setup Block Diagram 7 6.0 Summary of Tests 7 6.1 Section 15.203 - Antenna Requirement 7 6.2 Section 15.207 - Power Line Conducted Emissions 7 6.2.1 Test Methodology 7 6.2.2 Test Results 7 6.3 Section 15.209 - Radiated Emissions (Unintentional Radiation) 8 6.3.1 Test Methodology 8 6.3.2 Test Results 8 6.4 Section 15.247(b)(3) Peak Output Power 8 6.4.1 Test Methodology 8 6.4.2 Test Results 8 6.5 Section 15.247(a)(2) 6dB Bandwidth 9 6.5.1 Test Methodology 9 6.5.2 Test Results 9 6.6 Section 15.247(c) - Spurious Emissions 10 6.6.1 Conducted Spurious Emissions 10 6.6.1.1 Test Methodology 10 6.6.1.2 Test Results 10 6.6.2 Radiated Spurious Emissions 10 6.6.2.1 Test Methodology 10 6.6.2.2 Test Results 10 6.7 Section 15.247(f) Peak Power Spectral Density 12 6.7.1 Test Methodology 12 6.7.2 Test Results 12 6.8 Section 15.247(d) Channel Dwell Time 13 6.8.1 Test Methodology 13 6.8.2 Test Results 13 7.0 MODIFICATIONS 13 8.0 CONCLUSION 13 Additional Exhibits Included In Filing Conducted Spurious Plots Radiated Spurious Plots Bill of Materials Test Setup Photographs Product Labeling Info RF Exposure MPE Calculations Schematics Internal Photographs System Block Diagram Theory of Operation Manual

1.0 GENERAL 1.1 Introduction The purpose of this report is to demonstrate compliance of a Limited Modular Approval to 15.247 of the FCC s Code of Federal Regulations. 1.2 Product Description The Room Control Unit (RCU) is the brain of the Onity s wireless energy management system. It receives the temperature, humidity, guest settings, fan mode, motion status, and door status from the various system devices and determines how to operate the HVAC system and lighting control. The RCU has six relay drivers for outputs, a local door switch input, three setup buttons, three LED indicators, a local temperature sensor input, and a Real Time Clock (RTC) interface. The RCU receives transmissions from all the wireless devices via its on board radio. Detailed photographs of the EUT are filed separately with this filing. 1.2.1 Intended Use The RFRCU modular radio receives transmissions from all the wireless devices via its on board radio. 2.0 LOCATION OF TEST FACILTY All testing was performed by qualified ACS personnel located at the following address: ACS, Inc. 5015 B.U. Bowman Drive Buford, GA 30518 2.1 DESCRIPTION OF TEST FACILITY Both the Open Area Test Site(OATS) and Conducted Emissions site have been fully described, submitted to, and accepted by the FCC, Industry Canada and the Japanese Voluntary Control Council for Interference by information technology equipment. In addition, ACS is compliant to ISO 17025 as certified by the National Institute of Standards and Technology under their National Voluntary Laboratory Accreditation Program. The following certification numbers have been issued in recognition of these accreditations and certifications: FCC Registration Number: 89450 Industry Canada Lab Code: IC 4175 VCCI Member Number: 1831 VCCI OATS Registration Number R-1526 VCCI Conducted Emissions Site Registration Number: C-1608 NVLAP Lab Code: 200612 ACS Report: 04-0170-15C Advanced Compliance Solutions Page 3

2.1.1 Open Area Test Site The open area test site consists of a 40 x 66 concrete pad covered with a perforated electro-plated galvanized sheet metal. The perforations in the sheet metal are 1/8 holes that are staggered every 3/16. The individual sheets are placed to overlap each other by 1/4 and are riveted together to provide a continuous seam. Rivets are spaced every 3 in a 3 x 20 meter perimeter around the antenna mast and EUT area. Rivets in the remaining area are spaced as necessary to properly secure the ground plane and maintain the electrical continuity. The entire ground plane extends 12 beyond the turntable edge and 16 beyond the antenna mast when set to a 10 meter measurement distance. The ground plane is grounded via 4-8 copper ground rods, each installed at a corner of the ground plane and bound to the ground plane using 3/4" stainless steel braided cable. The turntable is an all aluminum 10 flush mounted table installed in an all aluminum frame. The table is remotely operated from inside the control room located 40 from the range. The turntable is electrically bonded to the surrounding ground plane via steel fingers installed on the edge of the turn table. The steel fingers make constant contact with the ground plane during operation. Adjacent to the turntable is a 7 x 7 square and 4 deep concrete pit used for support equipment if necessary. The pit is equipped with 5-4 PVC chases from the pit to the control room that allow for cabling to the EUT if necessary. The underside of the turntable can be accessed from the pit so cables can be supplied to the EUT from the pit. The pit is covered with 2 sheets of 1/4" diamond style re-enforced steel sheets. The sheets are painted to match the perforated steel ground plane, however the underside edges have been masked off to maintain the electrical continuity of the ground plane. All reflecting objects are located outside of the ellipse defined in ANSI C63.4. A diagram of the Open Area Test Site is shown in Figure 2.1-1 below: 10 3 Meters 40 7x7x4 Pit 66 Feet Figure 2.1-1: Open Area Test Site ACS Report: 04-0170-15C Advanced Compliance Solutions Page 4

2.1.2 Conducted Emissions Test Site Description The AC mains conducted EMI site is a shielded room with the following dimensions: Height: 3.0 Meters Width: 3.6 Meters Length: 4.9 Meters The room is manufactured by Rayproof Corporation and installed by Panashield, Inc. Earth ground is provided to the room via an 8 copper ground rod. Each panel of the room is connected electrically at intervals of 4. Power to the room is filtered to prevent ambient noise from coupling to the EUT and measurement equipment. Filters are models 1B42-60P manufactured by Rayproof Corporation. The room is of sufficient size to test table top and floor standing equipment in accordance with section 6.1.4 of ANSI C63.4. A diagram of the room is shown below in figure 2.1.2-1:.4 Meters EUT LISN.8 Meters 1.0 Meter Non Conductive Table (.8Meters Tall) Non-EUT LISN 1.5 Meter 3.0 Meters 4.9 Meters Figure 2.1.2-1: AC Mains Conducted EMI Site ACS Report: 04-0170-15C Advanced Compliance Solutions Page 5

3.0 APPLICABLE STANDARD REFERENCES The following standards were used: ANSI C63.4-1992: Method of Measurements of Radio-Noise Emissions from Low-Voltage Electrical and Electronic Equipment in the 9KHz to 40GHz US Code of Federal Regulations (CFR): Title 47, Part 2, Subpart J: Equipment Authorization Procedures (October 2002) US Code of Federal Regulations (CFR): Title 47, Part 15, Subpart C: Radio Frequency Devices, Intentional Radiators (October 2002) FCC OET Bulletin 65 Appendix C - Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields 4.0 LIST OF TEST EQUIPMENT All test equipment used for regulatory testing is calibrated yearly or according to manufacturer s specifications. ACS # Table 4.0-1: Test Equipment Equipment Calibration Information Mfg. Eq. type Model S/N Cal. Due --- Agilent Spectrum Analyzer E7402A US4024025 9 02/26/05 26 Chase Bi-Log Antenna CBL6111 1044 10/14/04 152 EMCO LISN 3825/2 9111-1905 01/08/05 153 EMCO LISN 3825/2 9411-2268 12/11/04 193 ACS OATS Cable Set RG8 193 01/09/05 167 ACS Conducted EMI Cable Set RG8 167 01/09/05 5 Harbour Industries Cable LL-335 None 08/20/04 6 Harbour Industries Cable LL-335 None 08/06/04 22 Agilent Pre-Amplifier 8449B 3008A00526 09/18/04 73 Agilent Pre-Amplifier 8447D 272A05624 04/30/05 30 Spectrum Technologies Horn Antenna DRH-0118 970102 05/08/05 105 Microwave Circuits High Pass Filter H1G810G1 2123-01 DC0225 06/09/05 209 Microwave Circuits High Pass Filters H3G020G2 4382-01 DC0421 06/09/05 40 EMCO Biconical Antenna 3104 3211 09/19/04 1 Rohde & Schwarz Receiver 804.8932.52 833771/007 02/26/05 2 Rohde & Schwarz Receiver 1032.5640.53 839587/003 02/26/05 213 Test Equipment Corp. Pre-Amplifier PA-102 44927 06/28/05 211 Eagle Band Reject Filter C7RFM3NFNM n/a 06/28/05 168 Hewlett Packard Pulse Limiter 11947A 3107A02268 04/30/05 93 Chase EM Clamp CIC 8101 65 01/12/05 184 ACS Cable RG8 184 01/09/05 169 Solar Electronics LISN 9117-5-TS-50-N 031032 04/12/05 ACS Report: 04-0170-15C Advanced Compliance Solutions Page 6

5.0 SYSTEM BLOCK DIAGRAM Table 5.0: System Block Diagram Diagram Number Manufacturer 1 EUT Equipment Type Room Control Unit 2 Onity Host Device Model Number Serial Number FCC ID RFRCU None R32-RFRCU Thermostat, Door Switch, & Motion Sensor N/A N/A 1 2 6.0 SUMMARY OF TESTS Figure 5.0-1: EUT Test Setup 6.1 Antenna Requirement FCC Section 15.203 The EUT employs an integrated antenna that cannot be modified without damaging the device. 6.2 Power Line Conducted Emissions - FCC Section 15.207 6.2.1 Test Methodology ANSI C63.4 sections 6 and 7 were the guiding documents for this evaluation. Conducted emissions were performed from 150kHz to 30MHz with the spectrum analyzer s resolution bandwidth set to 9kHz and the video bandwidth set to 30kHz. 6.2.2 Test Results The EUT will be provided DC power by the host device in which it is installed. With no connection to the AC mains this requirement is not applicable to the EUT. ACS Report: 04-0170-15C Advanced Compliance Solutions Page 7

6.3 Radiated Emissions - FCC Section 15.109(Unintentional Radiation) 6.3.1 Test Methodology ANSI C63.4 Sections 6 and 8 were the guiding documents for this evaluation. Radiated emissions tests were performed over the frequency range of 30MHz to 5000MHz. Measurements of the radiated field strength were made at a distance of 3m from the boundary of the equipment under test (EUT) and the receiving antenna. The antenna height was varied from 1m to 4m so that the maximum radiated emissions level would be detected. Radiated measurements were made with the Spectrum Analyzer s resolution bandwidth set to 120KHz for measurements above 30MHz. The EUT was caused to go into a Standby mode of operation for this test. 6.3.2 Test Results Results of the test are given in Tables 6.3.2-1through 6.3.2-3 below: Table 6.3.2-1: Radiated Emissions Tabulated Data (Unintentional Radiators) Frequency (MHz) Uncorrected Reading (dbµv) Antenna Polarity (H/V) Antenna Height (cm100) Turntable Position ( ) Total Correction Factor Corrected Reading (dbµv) Limit (dbµv) Margin Results 31.07 12.57 V 200 0 19.45 32.02 40.0 8.0 Pass 117.94 22.55 H 200 158 12.84 35.39 43.5 8.1 Pass 176.92 21.0 V 144 268 11.55 32.55 43.5 10.9 Pass 191.66 23.03 H 125 362 11.05 34.08 43.5 9.4 Pass 221.16 21.43 H 100 133 11.56 32.99 46.0 13.0 Pass 294.9 36.9 H 150 218-8.32 28.58 46.0 17.4 Pass 353.86 39.77 V 200 101-6.04 33.73 46.0 12.3 Pass 904.99 37.53 H 200 90 5.17 42.70 46.0 3.3 Pass 6.4 Peak Output Power FCC Section 15.247(b)(3) 6.4.1 Test Methodology (Conducted Method) The 6dB bandwidth of the EUT was within the resolution bandwidth of the Agilent E7402A spectrum analyzer, therefore the power measurement was made using the spectrum analyzer method. The resolution and video bandwidth were set to 3MHz. A 10dB pad was used for this measurement therefore a correction factor of 10dB was adjusted up in the table to reflect the use of the pad. The EUT was caused to transmit a continuous signal at the low, center and high channels. 6.4.2 Test Results Results are shown below in table 6.4.2-1 and in figure 6.4.2-1 below: ACS Report: 04-0170-15C Advanced Compliance Solutions Page 8

Table 6.4.2-1: RF Output Power Frequency [MHz] [dbm] Limit [dbm] Margin [db] 904.79 3.6 30 25.4 918.87 4.3 30 25.7 924.84 3.5 30 26.5 Result: PASS Figure 6.4.2-1: Peak Output Power 6.5 6dB Bandwidth FCC Section 15.247(a)(2) 6.5.1 Test Methodology The 6dB bandwidth was measured in accordance with FCC 97-114 Appendix C. The EUT was caused to generate a continuous at the low, center and high channels. 6.5.2 Test Results The unit uses hybrid technology therefore there is no requirement for this system to comply with the 500kHz minimum bandwidth associated with a DTS system in accordance with Section 15.247(f). ACS Report: 04-0170-15C Advanced Compliance Solutions Page 9

6.6 Spurious Emissions FCC Section 15.247(c) 6.6.1 Conducted Spurious Emissions 6.6.1.1 Test Methodology The EUT was investigated for conducted spurious emissions from 30MHz to 10GHz, 10 times the highest fundamental frequency. Measurements were made at the low, center and high channels of the EUT. For each measurement, the spectrum analyzer s VBW was set to 100kHz and the RBW was set to 1MHz. No averaging factor was applied. 6.6.1.2 Test Results All emission found were greater than 20dB down from the fundamental carrier. The RF conducted spurious emissions found in the band of 30MHz to 10GHz are reported graphically separately with this filing in a file titled 04-0170 Conducted Spurious Plots.pdf. 6.6.2 Radiated Spurious Emissions 6.6.2.1 Test Methodology Radiated emissions tests were made over the frequency range of 30MHz to 10GHz, 10 times the highest fundamental frequency. The EUT was rotated through 360 and the receive antenna height was varied from 1m to 4m so that the maximum radiated emissions level would be detected. For frequencies below 1000MHz, quasi-peak measurements were made using a resolution bandwidth (RBW) of 120kHz and a video bandwidth(vbw) of 300kHz. For frequencies above 1000MHz, average measurements were made using an RBW of 1MHz and a VBW of 10Hz and peak measurements were made with RBW of 1MHz and a VBW of 1MHz. The EUT was caused to generate a constant carrier signal for the test. An averaging factor was applied to the measurements to account for the duty cycle of the EUT. The factor was determined based on the 16.5% duty cycle of the EUT. The factor was calculated using the formula 20 log(.165) = 15.6dB. This corrected result was then compared to the average limits. 6.6.2.2 Test Results Radiated spurious emissions found in the band of 30MHz to 10GHz are reported in Table 6.6.2.2-1 through 6.6.2.2-3. Plots of these emissions are also presented separately in a file titled 04-0170 Radiated Spurious Plots. Each emission found to be in a restricted band as defined by section 15.205, was compared to the radiated emission limits for as defined in section 15.209. ACS Report: 04-0170-15C Advanced Compliance Solutions Page 10

Frequency (MHz) Table 6.6.2.2-1: Radiated Spurious Emissions (Low) Detector (P/A) Antenna Polarity (H/V) Correction Factors Corrected Limit Margin Final Result (Pass/Fail) 2714 56.19 P H -1.58 54.61 74.00 19.39 PASS 2714 54.79 A H -17.18 37.61 54.00 16.39 PASS 3619 45.54 P V 4.83 50.37 74.00 23.63 PASS 3619 45.54 A V -10.77 34.77 54.00 19.23 PASS 4524 49.36 P H 6.46 55.82 74.00 18.18 PASS 4524 45.67 A H -9.14 36.53 54.00 17.47 PASS 5429 41.56 P H 9.18 50.74 74.00 23.26 PASS 5429 41.56 A H -6.42 35.14 54.00 18.86 PASS Frequency (MHz) Detector (P/A) Table 6.6.2.2-2: Radiated Spurious Emissions (Mid) Antenna Polarity (H/V) Correction Factors Corrected Limit Margin Final Result (Pass/Fail) 2756 61.93 P H -1.51 60.42 74.00 13.58 PASS 2756 31.634 A H -17.11 44.23 54.00 9.77 PASS 36.75 46.26 P V 5.03 51.29 74.00 22.71 PASS 3675 46.26 A V -10.57 35.69 54.00 18.31 PASS 4594 55.73 P H 6.77 62.50 74.00 11.50 PASS 4594 54.44 A H -8.83 45.61 54.00 8.39 PASS 7353 40.9 P V 12.48 53.38 74.00 20.62 PASS 7353 40.9 A V -3.12 37.78 54.00 16.22 PASS Frequency (MHz) Table 6.6.2.2-3: Radiated Spurious Emissions (High) Detector (P/A) Antenna Polarity (H/V) Correction Factors Corrected Limit Margin Final Result (Pass/Fail) 2774 60.83 P H -1.48 59.35 74.00 14.65 PASS 2774 60.22 A H -17.08 43.14 54.00 10.86 PASS 3699 46.72 P V 5.12 51.84 74.00 22.16 PASS 3699 46.72 A V -10.48 36.24 54.00 17.76 PASS 4624 54.44 P H 6.90 61.34 74.00 12.66 PASS 4624 53.09 A H -8.70 44.39 54.00 9.61 PASS 7398 42.07 P V 12.37 54.44 74.00 19.56 PASS 7398 34.81 A V -3.23 31.58 54.00 22.42 PASS ACS Report: 04-0170-15C Advanced Compliance Solutions Page 11

Sample Calculations R C = R U + CF T Where: CF T = Total Correction Factor (AF+CA+AG)-DC(Average Measurements Only) R U = Uncorrected Reading R C = Corrected AF = Antenna Factor CA = Cable Attenuation AG = Amplifier Gain DC = Duty Cycle Correction Factor (If applicable) Example Calculation: Corrected : 56.19 + (-1.58) = 54.61 dbuv Margin: 74dBuV 54.61 dbuv = 19.39 db 6.7 Channel Dwell Time- FCC Section 15.247(f) 6.7.1 Test Methodology Under 15.247(f) the frequency hopping operation of the hybrid system, with the direct sequence or digital modulation turned off, the unit shall have an average time of occupancy on any frequency not to exceed 0.4 seconds within a time period in seconds equal to the number of hopping frequencies employed multiplied by 0.4. The EUT uses 5 channels therefore the channel dwell time must be less than.4 seconds in a 2 second period. 6.7.2 Test Results Results are shown below in and figure 6.5.3-1. Result: The duration of the RF transmission is 16.5ms. The EUT is designed to transmit twice per channel for redundancy and there are a total of 5 channels. There is 232mS delay between the 2 transmissions and then the EUT hops to another channel according to the pseudorandom frequency table before transmitting again. Therefore the period is 16.5mS(TXon) + 232mS(TXoff) = 248.5mS. There are 8 transmissions of 16.5mS in the 2 second period, resulting in a channel dwell time of 133mS. See Figure 6.7.2-1 below for a single hop: ACS Report: 04-0170-15C Advanced Compliance Solutions Page 12

6.8 Peak Power Spectral Density- FCC Section 15.247(d) 6.8.1 Test Methodology The power spectral density was measured in accordance with OET bulletin 97-114, appendix C. The EUT was caused to generate a constant carrier on the middle fundamental channel. A 10dB pad was used for this measurement therefore a correction factor of 10dB was adjusted up in the table to reflect the use of the pad. The hopping function was turned off for the measurement. 6.8.2 Test Results Results are shown below in figure 6.8.1-1. Figure 6.8.1-1: Peak Power Spectral Density 7.0 MODIFICATIONS No modifications were made to bring the EUT into compliance with the rules. 8.0 CONCLUSION In the opinion of ACS, Inc. the RFRCU manufactured by Onity, Inc., meets the relevant requirements of FCC Parts 2 and 15, as required. ACS Report: 04-0170-15C Advanced Compliance Solutions Page 13