Resp to corresp 22745

FCC ID: EHA-RM91501X04

Cover Letter(s)

Download: PDF
FCCID_251749

To:            Joe Dichoso
               jdichoso@fcc.gov
               FCC Application Processing Branch

From:          Dave Fry
               dave.fry@intermec.com
               Regulatory Engineer

Date:          June 21, 2002

Re:           FCC ID EHA-RM91501X04
Applicant:                             Intermec Technologies Corporation
Correspondence Reference Number: 22745
731 Confirmation Number:               EA475343


Reply is in bold Italics.

EMC questions ...

1) Figure 7 of the test report indicates 24 dBm output power. You requested 1 W. Please retest
   at 1 W and provide new data.
   The original report forgot to mention a 6-dB attenuator in the measurement path. The TX
   power was retested and a report amendment generated. The amended report has been
   transferred to the FCC EAS system.

2) The frequency range will be changed from 902.6-927.4. Please verify.
   Please revise as stated above. The actual operation range of the radio is 902.6 – 927.4 MHz

3) The device appears to have multiple antenna ports. Can they transmit simultaneously. What is
   the output power of all ports? Which port was tested? Additional information may be
   requested.
   The transmitter may have up to 4 antennas connected. The operation of the radio only
   enables one antenna port at a time. Multiple antennas are used to provide angular diversity
   to read RFID tags of unknown orientation or to support multiple entryways to read RFID
   tagged items. The transmitter is controlled by logic and software to only enable a single
   antenna port, the board lay out to each port produces the same path loss through the port
   switches between the antenna connectors and the power amplifier, therefore the power
   output of all ports is identical.

4) The Identifier's in the label exhibit do not agree with what was requested. Please submit new
   label exhibit with correct identifier.
   The label information has been revised and has been transferred to the FCC EAS system.

5) Antenna photo's and antenna gain. See also RF safety question # 4 below.
   Photographs of the tested antennas as well as statements for the gain of each has been have
   transferred to the FCC EAS systems. All antennas will be supplied from Intermec with
   antenna connectors comply the unique connector regulations under FCC 15.203. Antenna
   offerings will include longer cables to accommodate various installation needs, however no
   antennas will include antenna connectors that may be field terminated.


RF safety questions

1. Need complete users manual to evaluate installation and normal use conditions.
   The Quick Start Guide showing typical installations and antenna usage warnings has been
   transferred to the FCC EAS systems.

2. FCC rules do not allow estimation of SAR. For various reasons the submitted analysis is not
   valid, e.g., body tissue absorption was not included. This RF exposure analysis will not be
   considered in compliance evaluation.
   The calculations for RF exposure have been revised to show MPE. The statements for safe
   operation have been revised to reflect these calculations. The revised RF exposure
   statements have been transferred to the FCC EAS systems.

3. Depending on installation conditions, device may fall within mobile classification, meaning
   labeling and MPE estimation or test may be needed. Devices that meet the categorical
   exclusion power levels of 2.1091 can use MPE estimation rather than testing to evaluate
   compliance. FCC does accept analogous calculations for SAR. If persons will normally be
   closer than 20 cm, SAR testing may be needed. Please see Suppl C 01 01 Sec 3 Table 1. If
   20 cm spacing is the normal use condition, please revise RF exposure exhibit in terms of MPE
   only, not SAR.
   See the reply above. The radio and installation reflect operation as a mobile transmitter.
   The user installation and warnings reflect operation distances from the antennas of 23-cm
   (9.1 inches). Please see revised details of statements and MPE calculations for the two
   antennas specified for use with this radio.

4. Please submit antenna photos and specs. 3 dBi antenna gives 2W EIRP = 1.22 ERP. For ERP
   > 1.5W, MPE test is needed.
   The antenna photographs and specifications have been transferred to the FCC EAS
   systems.



Document Created: 2002-06-21 08:59:29
Document Modified: 2002-06-21 08:59:29

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