HAC RFE Test Report

FCC ID: ZNFX212TA

Test Report

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                                     PCTEST ENGINEERING LABORATORY, INC.
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                                                      HEARING AID COMPATIBILITY
Applicant Name:                                                                                              Date of Testing:
LG Electronics U.S.A, Inc.                                                                                   10/29/2018
1000 Sylvan Avenue                                                                                           Test Site/Location:
Englewood Cliffs, NJ 07632                                                                                   PCTEST Lab, Columbia, MD, USA
United States                                                                                                Test Report Serial No.:
                                                                                                             1M1810290199-01-R2.ZNF


FCC I D:                                                         ZNFX212TA

APPLI C A NT:                                                    LG ELECTRONICS U.S.A, INC.

Scope of Test:                                                   RF Emissions Testing
Application Type:                                                Class II Permissive Change
FCC Rule Part(s):                                                CFR §20.19(b)
HAC Standard:                                                    ANSI C63.19-2011
                                                                 285076 D01 HAC Guidance v05
                                                                 285076 D02 T-Coil testing for CMRS IP v03
DUT Type:                                                        Portable Handset
Model:                                                           LM-X220MA
Additional Model(s):                                             LMX220MA, X220MA
Test Device Serial No.:                                          Pre-Production Sample [S/N: 02819]
Class II Permissive Change(s):                                   See FCC Change Document
Original Grant Date:                                             03/28/2018


C63.19-2011 HAC Category:                                        M4 (RF EMISSIONS CATEGORY, LTE B26 & B25 Only)

Note: This revised Test Report (S/N: 1M1810290199-01-R2.ZNF) supersedes and replaces the previously issued test report on the
same subject device for the same type of testing as indicated. Please discard or destroy the previously issued test report(s) and
dispose of it accordingly.

This report and category pertain only to LTE bands 26 & 25 supported by this wireless portable device. The overall category rating
of the device is determined by the lowest rating obtained over all air interfaces supported by the device. This wireless portable
device has been shown to be hearing-aid compatible for LTE bands 26 & 25, under the above rated category, specified in
ANSI/IEEE Std. C63.19-2011 and has been tested in accordance with the specified measurement procedures. Hearing-Aid
Compatibility is based on the assumption that all production units will be designed electrically identical to the device tested in this
report. Test results reported herein relate only to the item(s) tested. North America bands only.

I attest to the accuracy of data. All measurements reported herein were performed by me or were made under my supervision and
are correct to the best of my knowledge and belief. I assume full responsibility for the completeness of these measurements and
vouch for the qualifications of all persons taking them.




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                                            T A B L E                           O F              C O N T E N T S




1.            INTRODUCTION ............................................................................................................................. 3

2.            DUT DESCRIPTION ........................................................................................................................ 4

3.            ANSI/IEEE C63.19 PERFORMANCE CATEGORIES .................................................................... 5

4.            SYSTEM SPECIFICATIONS ........................................................................................................... 6

5.            MODULATION INTERFERENCE FACTOR.................................................................................. 11

6.            RF CONDUCTED POWER MEASUREMENTS............................................................................ 13

7.            JUSTIFICATION OF HELD TO EAR MODES TESTED ............................................................... 18

8.            EQUIPMENT LIST ......................................................................................................................... 19

9.            MEASUREMENT UNCERTAINTY ................................................................................................ 20

10.           CONCLUSION ............................................................................................................................... 21

11.           REFERENCES .............................................................................................................................. 22




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1.            INTRODUCTION

On July 10, 2003, the Federal Communications Commission (FCC) adopted new rules requiring wireless
manufacturers and service providers to provide digital wireless phones that are compatible with hearing
aids. The FCC has modified the exemption for wireless phones under the Hearing Aid Compatibility Act of
1998 (HAC Act) in WT Docket 01-309 RM-86581 to extend the benefits of wireless telecommunications to
individuals with hearing disabilities. These benefits encompass business, social and emergency
communications, which increase the value of the wireless network for everyone. An estimated more than
10% of the population in the United States show signs of hearing impairment and of that fraction, almost
80% use hearing aids. Approximately 500 million people worldwide suffer from hearing loss.


Compatibility Tests Involved:

The standard calls for wireless communications devices to be measured for:
    RF Electric-field emissions
    T-coil mode, magnetic-signal strength in the audio band
    T-coil mode, magnetic-signal frequency response through the audio band
    T-coil mode, magnetic-signal and noise articulation index

The hearing aid must be measured for:
    RF immunity in microphone mode
    RF immunity in T-coil mode

In the following tests and results, this report includes the evaluation for a wireless communications
device.




                                                                   Figure 1-1 Hearing Aid in-vitu




1
    FCC Rule & Order, WT Docket 01-309 RM-8658

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2.             DUT DESCRIPTION




FCC ID:                                                             ZNFX212TA
Manufacturer:                                                       LG Electronics U.S.A, Inc.
                                                                    1000 Sylvan Avenue
                                                                    Englewood Cliffs, NJ 07632
                                                                    United States
Model:                                                              LM-X220MA
Additional Model(s):                                                LMX220MA, X220MA
Serial Number:                                                      02819
Antenna Configurations:                                             Internal Antenna
DUT Type:                                                           Portable Handset

                                                                           Table 2-1
                                                                   ZNFX212TA HAC Air Interfaces
                              Band                                                                          Simultaneous
  Air-Interface                                 Type Transport         HAC Tested                                                                         Name of Voice Service
                             (MHz)                                                                         But Not Tested

                              850
                                                        VO                  No2                            Yes: WIFI or BT                                       CMRS Voice
        GSM                   1900
                         GPRS/EDGE                      VD                  No2                            Yes: WIFI or BT                                       Google Duo
                              850
                              1700                      VD                  No2                            Yes: WIFI or BT                                       CMRS Voice
       UMTS
                              1900
                             HSPA                       VD                  No2                            Yes: WIFI or BT                                       Google Duo
                           680 (B71)
                           700 (B12)                                        No 2
                           850 (B5)
                           850 (B26)                                        No1
     LTE (FDD)                                          VD                                                 Yes: WIFI or BT                                   VoLTE, Google Duo
                           1700 (B4)
                          1700 (B66)                                        No2
                           1900 (B2)
                          1900 (B25)                                        No1
                              2450
                        5200 (U-NII 1)
        WIFI           5300 (U-NII 2A)                  VD                  No2                       Yes: GSM, UMTS, or LTE                                VoWIFI, Google Duo
                       5500 (U-NII 2C)
                        5800 (U-NII 3)
         BT                   2450                      DT                  No                        Yes: GSM, UMTS, or LTE                                          N/A
 Type Transport                                                       Notes:
 VO = Voice Only                                                      1. Evaluated for MIF and low-power exemption.
 DT = Digital Data - Not intended for CMRS Service                    2. This report only pertains to LTE Band 25 & 26. For full data, please refer to the previous
 VD = CMRS and IP Voice over Data Transport                           Certification Test Report (RFE Test Report S/N: 1M1802060016-09-R1.ZNF).


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3.            ANSI/IEEE C63.19 PERFORMANCE CATEGORIES
I. RF EMISSIONS

The ANSI Standard presents performance requirements for acceptable interoperability of hearing aids
with wireless communications devices. When these parameters are met, a hearing aid operates
acceptably in close proximity to a wireless communications device.



                                          Category                                              Telephone RF Parameters


                                                                                                       E-field emissions
                                 Near field Category                                                           CW
                                                                                                            dB(V/m)
                                                                                      f < 960 MHz
                                               M1                                                               50 to 55
                                               M2                                                               45 to 50
                                               M3                                                               40 to 45
                                               M4                                                                  < 40
                                                                                      f > 960 MHz
                                               M1                                                               40 to 45
                                               M2                                                               35 to 40
                                               M3                                                               30 to 35
                                               M4                                                                  < 30

                                                                Table 3-1
                                         WD near-field categories as defined in ANSI C63.19-2011




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4.            SYSTEM SPECIFICATIONS

ER3DV6 E-Field Probe Description

Construction:                       One dipole parallel, two dipoles normal to probe axis
                                    Built-in shielding against static charges
Calibration:                        In air from 100 MHz to 3.0 GHz
                                    (absolute accuracy ±6.0%, k=2)
Frequency:                          100 MHz to > 6 GHz;
                                    Linearity: ± 0.2 dB (100 MHz to 3 GHz)
Directivity                         ± 0.2 dB in air (rotation around probe axis)
                                    ± 0.4 dB in air (rotation normal to probe axis)                                                                          Figure 4-1
Dynamic Range                       2 V/m to > 1000 V/m                                                                                                  E-field Free-space
                                    (M3 or better device readings fall well below diode                                                                         Probe
                                    compression point)
Linearity:                          ± 0.2 dB
Dimensions                          Overall length: 330 mm (Tip: 16 mm)
                                    Tip diameter: 8 mm (Body: 12 mm)
                                    Distance from probe tip to dipole centers: 2.5 mm


Probe Tip Description

HAC field measurements take place in the close near field with high gradients. Increasing the measuring
distance from the source will generally decrease the measured field values (in case of the validation
dipole approx. 10% per mm).

The electric field probes have an irregular internal geometry because it is physically not possible to have
the 3 orthogonal sensors situated with the same center. The effect of the different sensor centers is
accounted for in the HAC uncertainty budget ("sensor displacement"). Their geometric center is at 2.5mm
from the tip, and the element ends are 1.1mm closer to the tip.




The antistatic shielding inside the probe is connected to the probe connector case.




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Instrumentation Chain
                                                                                     Equation 1




Probe Response to Frequency

The E-field sensors have inherently a very flat frequency response. They are calibrated with a number of
frequencies resulting in a common calibration factor, with the frequency behavior documented in the
calibration certificate (See also below).




                                                     Figure 4-2 E-Field Probe Frequency Response




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SPEAG Robotic System

       E-field measurements are performed using the DASY5 automated dosimetric assessment system.
       The DASY5 is made by Schmid & Partner Engineering AG (SPEAG) in Zurich, Switzerland and
       consists of high precision robotics system (Staubli), robot controller, Intel CORE i7 computer, near-
       field probe, probe alignment sensor, and the HAC phantom. The robot is a six-axis industrial robot
       performing precise movements to position the probe to the location (points) of maximum
       electromagnetic field (EMF).




                                                                              Figure 4-3
                                                                          SPEAG Robotic System


System Hardware

       A cell controller system contains the power supply, robot controller, teach pendant (Joystick), and a
       remote control used to drive the robot motors. The PC consists of the computer with operating
       system and RF Measurement Software DASY5 v52.8 (with HAC Extension), A/D interface card,
       monitor, mouse, and keyboard. The Staubli Robot is connected to the cell controller to allow software
       manipulation of the robot. A data acquisition electronic (DAE) circuit that performs the signal
       amplification, signal multiplexing, AD-conversion, offset measurements, mechanical surface
       detection, collision detection, etc. is connected to the Electro-optical coupler (EOC). The EOC
       performs the conversion from the optical into digital electric signal of the DAE and transfers data to
       the PC plug-in card.




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System Electronics

       The DAE consists of a highly sensitive electrometer-grade preamplifier with auto-zeroing, a channel
       and gain-switching multiplexer, a fast 16 bit AD-converter and a command decoder and control logic
       unit. Transmission to the PC-card is accomplished through an optical downlink for data and status
       information and an optical uplink for commands and clock lines. The mechanical probe mounting
       device includes two different sensor systems for frontal and sidewise probe contacts. They are also
       used for mechanical surface detection and probe collision detection. The robot uses its own controller
       with a built in VME-bus computer.




                                                                          Figure 4-4
                                                                  SPEAG Robotic System Diagram

DASY5 Instrumentation Chain

              The first step of the evaluation is a linearization of the filtered input signal to account for the
              compression characteristics of the detector diode. The compensation depends on the input
              signal, the diode type and the DC-transmission factor from the diode to the evaluation electronics.
              If the exciting field is pulsed, the crest factor of the signal must be known to correctly compensate
              for peak power. The formula for each channel can be given as:




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              The measurement/integration time per point, as specified by the system manufacturer is >500ms.

              The signal response time is evaluated as the time required by the system to reach 90% of the
              expected final value after an on/off switch of the power source with an integration time of 500ms
              and a probe response time of <5 ms. In the current implementation, DASY5 waits longer than
              100ms after having reached the grid point before starting a measurement, i.e., the response time
              uncertainty is negligible.

              If the device under test does not emit a CW signal, the integration time applied to measure the
              electric field at a specific point may introduce additional uncertainties due to the discretization.
              The tolerances for the different systems had the worst-case of 2.6%.




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5.            MODULATION INTERFERENCE FACTOR
I. Measuring Modulation Interference Factors
For any specific fixed and repeatable modulated signal, a modulation interference factor (MIF, expressed
in dB) may be determined that relates its interference potential to its steady-state RMS signal level or
average power level. This factor is a function only of the audio-frequency amplitude modulation
characteristics of the signal and is the same for field-strength and conducted power measurements. The
MIF is valid only for a specific repeatable audio-frequency amplitude modulation characteristic; any
change in modulation characteristic requires determination and application of a new MIF.

The MIF may be determined using a radiated RF field or a conducted RF signal:

               a. Using RF illumination or conducted coupling, apply the specific modulated signal in question
                  to the measurement system at a level within its confirmed operating dynamic range.
               b. Measure the steady-state RMS level at the output of the fast probe or sensor.
               c. Measure the steady-state average level at the weighting output.
               d. Without changing the square-law detector or weighting system, and using RF illumination or
                  conducted coupling, substitute for the specific modulated signal a 1 kHz, 80% amplitude
                  modulated carrier at the same frequency and adjust its strength until the level at the
                  weighting output equals the step c) measurement.
               e. Without changing the carrier level from step d), remove the 1 kHz modulation and again
                  measure the steady-state RMS level indicated at the output of the fast probe or sensor.
               f. The MIF for the specific modulation characteristic is provided by the ratio of the step e)
                  measurement to the step b) measurement, expressed in dB (20 × log[(step e)/(step b)]).

The following procedure was used to measure the MIF using the SPEAG Audio Interference Analyzer
(AIA), Type No: SE UMS 170 CB, Serial No.: 1010:

               1. The device was placed into a simulated call using a base station simulator or set to transmit
                  using test software for a given mode.
               2. The device was then set to continuously transmit at maximum power.
               3. Using a coupler if needed, the device output signal was connected to the RF In port of the
                  AIA, which was connected to a desktop computer. Alternatively, a radiated RF signal may be
                  used with the AIA’s built-in antenna.
               4. The MIF measurement procedure in the DASY software was run, and the resulting MIF value
                  was recorded.
               5. Steps 1-4 were repeated for all CMRS air interfaces, frequency bands, and modulations.

The modulation interference factors obtained were applied to readings taken of the actual wireless device
in order to obtain an accurate audio interference level reading using the formula:

                   Audio Interference Level [dB(V/m)] = 20 * log[Raw Field Value (V/m)] + MIF (dB)

Because the MIF value is output power independent, MIF values for a given mode should be constant
across all devices; however, per C63.19-2011 §D.7, MIF values should be measured for each device
being evaluated. The voice modes for this device have been investigated in this section of the report.




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II. MIF Measurement Block Diagrams




                                                                              Figure 5-1
                                                                      MIF Measurement Setup
                                                                        for licensed modes

III. Measured Modulation Interference Factors:

                                                                      Table 5-1
                                                        LTE FDD Modulation Interference Factors1,2
        LTE               Frequency                                       Bandwidth                                                                                              MIF
                                                    Channel                                       Modulation                 RB Size                RB Offset
       Band                 [MHz]                                           [MHz]                                                                                                [dB]

          25                  1882.5                   26365                      20                  16QAM                        1                       0                   -10.49
          26                   831.5                   26865                      15                  16QAM                        1                       0                    -9.99
          26                   831.5                   26865                      15                   QPSK                        1                       0                   -13.53
          26                   831.5                   26865                      15                  16QAM                        1                      36                   -10.14
          26                   831.5                   26865                      15                  16QAM                        1                      74                   -10.16
          26                   831.5                   26865                      15                  16QAM                       36                       0                   -17.34
          26                   831.5                   26865                      15                  16QAM                       75                       0                   -19.65
          26                   831.5                   26865                      10                  16QAM                        1                       0                   -10.01
          26                   831.5                   26865                       5                  16QAM                        1                       0                   -10.41
          26                   831.5                   26865                       3                  16QAM                        1                       0                   -10.18
          26                   831.5                   26865                     1.4                  16QAM                        1                       0                    -9.91
          26                   814.7                   26697                     1.4                  16QAM                        1                       0                   -10.35
          26                   848.3                   27033                     1.4                  16QAM                        1                       0                   -10.43

1 Note: Measured MIF values may be lower than sample MIF values provided in ANSI C63.19-2011 Annex D.7 Table

D.5 due to manufacturing variations for each device, however per Annex D.7, the sample MIF values of Table D.5 are
not intended to substitute for measurements of actual devices under test and their respective operating modes.
2 Note: All FDD LTE bands were found to have substantially similar MIF values given similar RB, BW, and modulation

configurations.




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6.            RF CONDUCTED POWER MEASUREMENTS
I. Procedures Used to Establish RF Signal for HAC Testing
The handset was placed into a simulated call using a base station simulator in a shielded chamber.
Such test signals offer a consistent means for testing HAC and are recommended for evaluating HAC.
Measurements were taken with a fully charged battery. In order to verify that the device was tested and
maintained at full power, this was configured with the base station simulator.

II. HAC Measurement Conditions
Output Power Verification
Maximum output power is verified on the High, Middle and Low channels for all applicable air interfaces.
See Table 6-1 for air interface specific settings of transmit power parameters.

                                                           Table 6-1
                                      Power Control Parameters and Settings by Air Interface
                               Air Interface:     Parameter Name:           Parameter Set To:
                                    LTE                 TPC                   “Max Power”

III. Setup Used to Measure RF Conducted Powers
Power measurements for licensed modes were performed using a base station simulator under digital
average power.




                                                                     Figure 6-1
                                                       Power Measurement Setup for licensed modes

IV. LTE Conducted Powers

       a. LTE Band 26
                                                          Table 6-2
                                 LTE Band 26 (831.5MHz) Conducted Powers – 15MHz Bandwidth
                                                                                       LTE Band 26 (Cell)
                                                                                       15 MHz Bandwidth
                                                                                       Mid Channel
                                                                                           26865             MPR Allowed per
                                          Modulation      RB Size       RB Offset       (831.5 MHz)                                     MPR [dB]
                                                                                                               3GPP [dB]
                                                                                     Conducted Power
                                                                                           [dBm]
                                                              1             0               24.11                                           0
                                                              1            36               24.40                    0                      0
                                                              1            74               23.95                                           0
                                            QPSK             36             0               23.21                                           1
                                                             36            18               22.94                                           1
                                                                                                                    0-1
                                                             36            37               22.92                                           1
                                                             75             0               22.92                                           1
                                                              1             0               22.85                                           1
                                                              1            36               22.67                   0-1                     1
                                                              1            74               22.76                                           1
                                            16QAM            36             0               21.92                                           2
                                                             36            18               21.97                                           2
                                                                                                                    0-2
                                                             36            37               21.96                                           2
                                                             75             0               21.93                                           2

Note: Since LTE Band 26 at 15MHz bandwidth does not support 3 non-overlapping channels, conducted
power measurements were made only on the middle channel.


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                                                           Table 6-3
                                  LTE Band 26 (831.5MHz) Conducted Powers – 10MHz Bandwidth
                                                                                       LTE Band 26 (Cell)
                                                                                       10 MHz Bandwidth
                                                                   Low Channel           Mid Channel          High Channel
                                                                       26740                26865                 26990           MPR Allowed per
                        Modulation     RB Size      RB Offset                                                                                              MPR [dB]
                                                                    (819.0 MHz)          (831.5 MHz)           (844.0 MHz)          3GPP [dB]
                                                                                    Conducted Power [dBm]
                                          1             0              24.08                24.15                 23.99                                        0
                                          1            25              24.23                24.23                 24.24                  0                     0
                                          1            49              24.19                24.12                 24.17                                        0
                          QPSK            25            0              23.23                23.22                 23.24                                        1
                                          25           12              23.10                23.22                 23.22                                        1
                                                                                                                                         0-1
                                          25           25              23.05                23.15                 23.22                                        1
                                          50            0              23.10                23.15                 23.23                                        1
                                          1             0              23.23                23.02                 23.17                                        1
                                          1            25              23.20                23.18                 23.22                  0-1                   1
                                          1            49              23.18                23.01                 23.23                                        1
                          16QAM           25            0              22.14                22.18                 22.19                                        2
                                          25           12              22.14                22.20                 22.20                                        2
                                                                                                                                         0-2
                                          25           25              22.17                22.22                 22.23                                        2
                                          50            0              22.12                22.23                 22.11                                        2




                                                          Table 6-4
                                  LTE Band 26 (831.5MHz) Conducted Powers – 5MHz Bandwidth
                                                                                       LTE Band 26 (Cell)
                                                                                       5 MHz Bandwidth
                                                                   Low Channel           Mid Channel          High Channel
                                                                       26715                26865                 27015           MPR Allowed per
                        Modulation     RB Size      RB Offset                                                                                              MPR [dB]
                                                                    (816.5 MHz)          (831.5 MHz)           (846.5 MHz)          3GPP [dB]
                                                                                    Conducted Power [dBm]
                                          1             0              24.19                23.97                 24.26                                        0
                                          1            12              24.34                24.18                 24.38                  0                     0
                                          1            24              24.30                23.97                 24.17                                        0
                          QPSK            12            0              23.34                23.29                 23.42                                        1
                                          12            6              23.35                23.38                 23.41                                        1
                                                                                                                                         0-1
                                          12           13              23.25                23.30                 23.30                                        1
                                          25            0              23.26                23.31                 23.41                                        1
                                          1             0              22.96                23.30                 23.04                                        1
                                          1            12              22.95                23.06                 22.83                  0-1                   1
                                          1            24              22.98                22.91                 22.75                                        1
                          16QAM           12            0              22.21                22.18                 22.33                                        2
                                          12            6              22.22                22.41                 22.17                                        2
                                                                                                                                         0-2
                                          12           13              22.15                22.20                 22.41                                        2
                                          25            0              22.26                22.17                 22.36                                        2




                                                          Table 6-5
                                  LTE Band 26 (831.5MHz) Conducted Powers – 3MHz Bandwidth
                                                                                       LTE Band 26 (Cell)
                                                                                       3 MHz Bandwidth
                                                                   Low Channel           Mid Channel          High Channel
                                                                       26705                26865                 27025           MPR Allowed per
                        Modulation     RB Size      RB Offset                                                                                              MPR [dB]
                                                                    (815.5 MHz)          (831.5 MHz)           (847.5 MHz)          3GPP [dB]
                                                                                    Conducted Power [dBm]
                                          1             0              24.12                24.22                 24.09                                        0
                                          1             7              24.22                24.22                 24.15                  0                     0
                                          1            14              24.27                24.06                 24.26                                        0
                          QPSK            8             0              23.27                23.22                 23.20                                        1
                                          8             4              23.29                23.23                 23.17                                        1
                                                                                                                                         0-1
                                          8             7              23.27                23.17                 23.06                                        1
                                          15            0              23.25                23.21                 23.15                                        1
                                          1             0              23.20                23.22                 22.96                                        1
                                          1             7              22.91                23.27                 23.45                  0-1                   1
                                          1            14              22.82                23.12                 23.21                                        1
                          16QAM           8             0              22.29                22.23                 22.21                                        2
                                          8             4              22.27                22.25                 22.16                                        2
                                                                                                                                         0-2
                                          8             7              22.20                22.09                 22.23                                        2
                                          15            0              22.26                22.20                 22.24                                        2




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                                                           Table 6-6
                                  LTE Band 26 (831.5MHz) Conducted Powers – 1.4MHz Bandwidth
                                                                                       LTE Band 26 (Cell)
                                                                                       1.4 MHz Bandwidth
                                                                   Low Channel           Mid Channel          High Channel
                                                                       26697                26865                 27033           MPR Allowed per
                        Modulation     RB Size      RB Offset                                                                                              MPR [dB]
                                                                    (814.7 MHz)          (831.5 MHz)           (848.3 MHz)          3GPP [dB]
                                                                                    Conducted Power [dBm]
                                          1             0              24.22                24.31                 24.04                                        0
                                          1             2              24.26                24.33                 24.12                                        0
                                          1             5              24.36                23.99                 24.04                                        0
                                                                                                                                         0
                          QPSK            3             0              24.22                24.21                 24.37                                        0
                                          3             2              24.26                24.33                 24.23                                        0
                                          3             3              24.20                24.30                 24.27                                        0
                                          6             0              23.24                23.30                 23.10                  0-1                   1
                                          1             0              23.25                23.21                 22.88                                        1
                                          1             2              23.01                23.25                 22.87                                        1
                                          1             5              23.19                23.02                 22.84                                        1
                                                                                                                                         0-1
                          16QAM           3             0              23.46                22.98                 22.76                                        1
                                          3             2              23.51                23.02                 23.33                                        1
                                          3             3              23.46                22.98                 23.25                                        1
                                          6             0              22.35                22.05                 22.28                  0-2                   2




       b. LTE Band 25
                                                          Table 6-7
                                 LTE Band 25 (1882.5MHz) Conducted Powers – 20MHz Bandwidth
                                                                                       LTE Band 25 (PCS)
                                                                                       20 MHz Bandwidth
                                                                   Low Channel           Mid Channel          High Channel
                                                                       26140                 26365                26590           MPR Allowed per
                        Modulation     RB Size      RB Offset                                                                                              MPR [dB]
                                                                   (1860.0 MHz)          (1882.5 MHz)         (1905.0 MHz)          3GPP [dB]
                                                                                    Conducted Power [dBm]
                                          1             0              23.90                24.07                 24.05                                        0
                                          1            50              23.67                24.17                 23.96                  0                     0
                                          1            99              23.90                23.78                 24.01                                        0
                          QPSK            50            0              22.94                22.93                 22.73                                        1
                                          50           25              22.89                23.01                 22.89                                        1
                                                                                                                                         0-1
                                          50           50              22.71                22.55                 22.53                                        1
                                         100            0              22.78                22.80                 22.68                                        1
                                          1             0              22.64                22.40                 22.89                                        1
                                          1            50              22.81                22.63                 22.71                  0-1                   1
                                          1            99              22.26                22.35                 22.42                                        1
                          16QAM           50            0              21.92                21.90                 21.73                                        2
                                          50           25              21.82                21.97                 21.90                                        2
                                                                                                                                         0-2
                                          50           50              21.78                21.55                 21.60                                        2
                                         100            0              21.86                21.80                 21.68                                        2




                                                          Table 6-8
                                 LTE Band 25 (1882.5MHz) Conducted Powers – 15MHz Bandwidth
                                                                                       LTE Band 25 (PCS)
                                                                                       15 MHz Bandwidth
                                                                   Low Channel           Mid Channel          High Channel
                                                                       26115                 26365                26615           MPR Allowed per
                        Modulation     RB Size      RB Offset                                                                                              MPR [dB]
                                                                   (1857.5 MHz)          (1882.5 MHz)         (1907.5 MHz)          3GPP [dB]
                                                                                    Conducted Power [dBm]
                                          1             0              24.09                23.86                 23.86                                        0
                                          1            36              24.02                24.06                 23.98                  0                     0
                                          1            74              24.06                23.99                 23.91                                        0
                          QPSK            36            0              23.10                23.10                 22.99                                        1
                                          36           18              23.01                23.08                 23.04                                        1
                                                                                                                                         0-1
                                          36           37              23.09                23.00                 22.92                                        1
                                          75            0              23.07                23.06                 22.91                                        1
                                          1             0              23.02                23.09                 23.08                                        1
                                          1            36              23.09                23.09                 23.09                  0-1                   1
                                          1            74              23.10                23.09                 23.10                                        1
                          16QAM           36            0              22.03                22.08                 22.09                                        2
                                          36           18              21.96                22.06                 22.08                                        2
                                                                                                                                         0-2
                                          36           37              21.86                21.93                 22.09                                        2
                                          75            0              21.95                21.96                 21.89                                        2




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                                                          Table 6-9
                                 LTE Band 25 (1882.5MHz) Conducted Powers – 10MHz Bandwidth
                                                                                       LTE Band 25 (PCS)
                                                                                       10 MHz Bandwidth
                                                                   Low Channel           Mid Channel          High Channel
                                                                       26090                 26365                26640           MPR Allowed per
                        Modulation     RB Size      RB Offset                                                                                              MPR [dB]
                                                                   (1855.0 MHz)          (1882.5 MHz)         (1910.0 MHz)          3GPP [dB]
                                                                                    Conducted Power [dBm]
                                          1             0              24.17                24.15                 24.06                                        0
                                          1            25              24.18                24.17                 24.17                  0                     0
                                          1            49              24.17                24.16                 24.14                                        0
                          QPSK            25            0              23.11                23.17                 23.17                                        1
                                          25           12              23.14                23.17                 23.16                                        1
                                                                                                                                         0-1
                                          25           25              23.14                23.05                 23.04                                        1
                                          50            0              23.18                23.18                 23.08                                        1
                                          1             0              23.17                22.57                 23.10                                        1
                                          1            25              23.14                23.18                 23.17                  0-1                   1
                                          1            49              23.18                23.10                 23.16                                        1
                          16QAM           25            0              22.09                22.18                 22.14                                        2
                                          25           12              22.12                22.18                 22.13                                        2
                                                                                                                                         0-2
                                          25           25              21.97                22.18                 22.10                                        2
                                          50            0              22.10                22.16                 22.17                                        2




                                                           Table 6-10
                                  LTE Band 25 (1882.5MHz) Conducted Powers – 5MHz Bandwidth
                                                                                       LTE Band 25 (PCS)
                                                                                        5 MHz Bandwidth
                                                                   Low Channel           Mid Channel          High Channel
                                                                       26065                 26365                26665           MPR Allowed per
                        Modulation     RB Size      RB Offset                                                                                              MPR [dB]
                                                                   (1852.5 MHz)          (1882.5 MHz)         (1912.5 MHz)          3GPP [dB]
                                                                                    Conducted Power [dBm]
                                          1             0              23.82                23.84                 23.95                                        0
                                          1            12              23.98                23.78                 23.99                  0                     0
                                          1            24              23.80                23.66                 23.93                                        0
                          QPSK            12            0              22.93                22.99                 22.98                                        1
                                          12            6              22.94                22.99                 22.99                                        1
                                                                                                                                         0-1
                                          12           13              22.96                22.96                 22.95                                        1
                                          25            0              23.00                22.99                 22.99                                        1
                                          1             0              22.81                22.86                 22.73                                        1
                                          1            12              22.97                22.56                 22.55                  0-1                   1
                                          1            24              22.87                22.46                 22.53                                        1
                          16QAM           12            0              21.86                22.00                 21.99                                        2
                                          12            6              21.99                21.92                 21.96                                        2
                                                                                                                                         0-2
                                          12           13              21.88                21.88                 22.00                                        2
                                          25            0              21.85                21.91                 21.89                                        2




                                                           Table 6-11
                                  LTE Band 25 (1882.5MHz) Conducted Powers – 3MHz Bandwidth
                                                                                       LTE Band 25 (PCS)
                                                                                        3 MHz Bandwidth
                                                                   Low Channel           Mid Channel          High Channel
                                                                       26055                 26365                26675           MPR Allowed per
                        Modulation     RB Size      RB Offset                                                                                              MPR [dB]
                                                                   (1851.5 MHz)          (1882.5 MHz)         (1913.5 MHz)          3GPP [dB]
                                                                                    Conducted Power [dBm]
                                          1             0              23.84                23.94                 23.81                                        0
                                          1             7              23.94                23.94                 23.87                  0                     0
                                          1            14              23.99                23.78                 23.98                                        0
                          QPSK            8             0              22.99                22.94                 22.92                                        1
                                          8             4              23.01                22.95                 22.89                                        1
                                                                                                                                         0-1
                                          8             7              22.99                22.89                 22.78                                        1
                                          15            0              22.97                22.93                 22.87                                        1
                                          1             0              22.92                22.94                 22.68                                        1
                                          1             7              22.63                22.99                 23.17                  0-1                   1
                                          1            14              22.54                22.84                 22.93                                        1
                          16QAM           8             0              22.01                21.95                 21.93                                        2
                                          8             4              21.99                21.97                 21.88                                        2
                                                                                                                                         0-2
                                          8             7              21.92                21.81                 21.95                                        2
                                          15            0              21.98                21.92                 21.96                                        2




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                                                        Table 6-12
                               LTE Band 25 (1882.5MHz) Conducted Powers – 1.4MHz Bandwidth
                                                                                       LTE Band 25 (PCS)
                                                                                       1.4 MHz Bandwidth
                                                                   Low Channel           Mid Channel          High Channel
                                                                       26047                 26365                26683           MPR Allowed per
                        Modulation     RB Size      RB Offset                                                                                              MPR [dB]
                                                                   (1850.7 MHz)          (1882.5 MHz)         (1914.3 MHz)          3GPP [dB]
                                                                                    Conducted Power [dBm]
                                          1             0              24.15                24.24                 23.97                                        0
                                          1             2              24.19                24.26                 24.05                                        0
                                          1             5              24.29                23.92                 23.97                                        0
                                                                                                                                         0
                          QPSK            3             0              24.15                24.14                 24.30                                        0
                                          3             2              24.19                24.26                 24.16                                        0
                                          3             3              24.13                24.23                 24.20                                        0
                                          6             0              23.17                23.23                 23.03                  0-1                   1
                                          1             0              23.18                23.14                 22.81                                        1
                                          1             2              22.94                23.18                 22.80                                        1
                                          1             5              23.12                22.95                 22.77                                        1
                                                                                                                                         0-1
                          16QAM           3             0              23.39                22.91                 22.69                                        1
                                          3             2              23.44                22.95                 23.26                                        1
                                          3             3              23.39                22.91                 23.18                                        1
                                          6             0              22.28                21.98                 22.21                  0-2                   2




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7.            JUSTIFICATION OF HELD TO EAR MODES TESTED
I. Analysis of RF Air Interface Technologies

       An analysis was performed, following the guidance of §4.3 and §4.4 of the ANSI standard, of the RF
       air interface technologies being evaluated. The factors that will affect the RF interference potential
       were evaluated, and the worst-case operating modes were identified and used in the evaluation. A
       WD’s interference potential is a function both of the WD’s average near-field field strength and of the
       signal’s audio-frequency amplitude modulation characteristics. Per §4.4, RF air interface technologies
       that have low power have been found to produce sufficiently low RF interference potential, so it is
       possible to exempt them from the product testing specified in Clause 5 of the ANSI standard. An RF
       air interface technology of a device is exempt from testing when its average antenna input power plus
       its MIF is ≤17dBm for all of its operating modes. RF air interface technologies exempted from testing
       in this manner are automatically assigned an M4 rating to be used in determining the overall rating for
       the WD.

       The worst-case MIF plus the worst-case average antenna input power for all modes are investigated
       below to determine the testing requirements for this device.

II. Individual Mode Evaluations

                                                                 Table 7-1
                                           Max Power + MIF calculations for Low Power Exemptions
                                                                                                  Maximum               Worst Case             Total            C63.19
                                                Air Interface                                   Average Power              MIF               (Power +           Testing
                                                                                                    (dBm)                  (dB)              MIF, dB)          Required

                                                 LTE - FDD                                           24.40                  -9.91               14.49              No




III. Low-Power Exemption Conclusions

LTE FDD is exempt from RF emissions testing and rated M4 under the low power exemption of
Clause 4 of ANSI C63.19-2011.




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8.            EQUIPMENT LIST
                                                                                    Table 8-1
                                                                                  Equipment List
    Manufacturer                 Model                                    Description                                   Cal Date       Cal Interval        Cal Due        Serial Number

     Pasternack                PE2237-20                          Bidirectional Coupler                                   N/A               CBT*             N/A                 N/A
  Rohde & Schwarz              CMW500                         Radio Communication Tester                                5/29/2018         Annual           5/29/2019            162125
      Seekonk                   NC-100                           Torque Wrench (8" lb)                                  5/10/2018         Biennial         5/10/2020             21053
       SPEAG                     AIA                          Audio Interference Analzyer                                 N/A               CBT*             N/A                 1010

                                    Calibration traceable to the National Institute of Standards and Technology (NIST).

*Note: CBT (Calibrated Before Testing). Prior to testing, the measurement paths containing a cable, attenuator, coupler or filter
were connected to a calibrated source (i.e. a signal generator) to determine the losses of the measurement path. The power meter
offset was then adjusted to compensate for the measurement system losses. This level offset is stored within the power meter
before measurements are made. This calibration verification procedure applies to the system verification and output power
measurements. The calibrated reading is then taken directly from the power meter after compensation of the losses for all final
power measurements.




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9.            MEASUREMENT UNCERTAINTY
                                                                               Table 9-1
                                                                      Uncertainty Estimation Table




       Notes:
       1.  Test equipments are calibrated according to techniques outlined in NIS81, NIS3003 and NIST Tech Note 1297. All
           equipments have traceability according to NIST. Measurement Uncertainties are defined in further detail in NIS 81
           and NIST Tech Note 1297 and UKAS M3003.
       2.  * Uncertainty specifications from Schmidt & Partner Engineering AG (not site specific)

Measurement uncertainty reflects the quality and accuracy of a measured result as compared to the true value. Such
statements are generally required when stating results of measurements so that it is clear to the intended audience
that the results may differ when reproduced by different facilities. Measurement results vary due to the measurement
uncertainty of the instrumentation, measurement technique, and test engineer. Most uncertainties are calculated
using the tolerances of the instrumentation used in the measurement, the measurement setup variability, and the
technique used in performing the test. While not generally included, the variability of the equipment under test also
figures into the overall measurement uncertainty. Another component of the overall uncertainty is based on the
variability of repeated measurements (so-called Type A uncertainty). This may mean that the Hearing Aid immunity
tests may have to be repeated by taking down the test setup and resetting it up so that there are a statistically
significant number of repeat measurements to identify the measurement uncertainty. By combining the repeat
measurement results with that of the instrumentation chain using the technique contained in NIS 81 and NIS 3003,
the overall measurement uncertainty was estimated.



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10.           CONCLUSION

The measurements indicate that LTE bands 26 & 25 of the wireless communications device complies with
the HAC limits specified in accordance with the ANSI C63.19 Standard and FCC WT Docket No. 01-309
RM-8658. Precise laboratory measures were taken to assure repeatability of the tests. The tested device
complies with the requirements in respect to all parameters specific to the test. The test results and
statements relate only to the item(s) tested.

Please note that the M-rating for this equipment only represents the field interference possible against a
hypothetical and typical hearing aid. The measurement system and techniques presented in this
evaluation are proposed in the ANSI standard as a means of best approximating wireless device
compatibility with a hearing-aid. The literature is under continual re-construction.




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enquiry about obtaining additional rights to this report or assembly of contents thereof, please contact INFO@PCTEST.COM.


11.           REFERENCES

       1. ANSI/IEEE C63.19-2011, “American National Standard for Methods of Measurement of
          Compatibility between Wireless Communication Devices and Hearing Aids.”, New York, NY,
          IEEE, May 2011

       2. FCC Office of Engineering and Technology KDB, “285076 D01 HAC Guidance v05,” September
          13, 2017

       3. FCC Office of Engineering and Technology KDB, “285076 D02 T-Coil Testing for CMRS IP v03,”
          September 13, 2017

       4. FCC Public Notice DA 06-1215, Wireless Telecommunications Bureau and Office of Engineering
          and Technology Clarify Use of Revised Wireless Phone Hearing Aid Compatibility Standard, June
          6, 2006

       5. FCC 3G Review Guidance, Laboratory Division OET FCC, May/June 2006

       6. Berger, H. S., “Compatibility Between Hearing Aids and Wireless Devices,” Electronic Industries
          Forum, Boston, MA, May, 1997

       7. Berger, H. S., “Hearing Aid and Cellular Phone Compatibility: Working Toward Solutions,”
          Wireless Telephones and Hearing Aids: New Challenges for Audiology, Gallaudet University,
          Washington, D.C., May, 1997 (To be reprinted in the American Journal of Audiology).

       8. Berger, H. S., “Hearing Aid Compatibility with Wireless Communications Devices, “ IEEE
          International Symposium on Electromagnetic Compatibility, Austin, TX, August, 1997.

       9. Bronaugh, E. L., “Simplifying EMI Immunity (Susceptibility) Tests in TEM Cells,” in the 1990 IEEE
          International Symposium on Electromagnetic Compatibility Symposium Record, Washington,
          D.C., August 1990, pp. 488-491

       10. Byme, D. and Dillon, H., The National Acoustics Laboratory (NAL) New Procedure for Selecting
           the Gain and Frequency Response of a Hearing Aid, Ear and Hearing 7:257-265, 1986.

       11. Crawford, M. L., “Measurement of Electromagnetic Radiation from Electronic Equipment using
           TEM Transmission Cells, “ U.S. Department of Commerce, National Bureau of Standards, NBSIR
           73-306, Feb. 1973.

       12. Crawford, M. L., and Workman, J. L., “Using a TEM Cell for EMC Measurements of Electronic
           Equipment,” U.S. Department of Commerce, National Bureau of Standards. Technical Note 1013,
           July 1981.

       13. Decker, W. F., Crawford, M. L., and Wilson, W. A., “Construction of a Large Transverse
           Electromagnetic Cell”, U.S. Department of Commerce, National Bureau of Standards, Technical
           Note 1011, Feb. 1979.

       14. EHIMA GSM Project, Development phase, Project Report (1st part) Revision A. Technical-
           Audiological Laboratory and Telecom Denmark, October 1993.



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mechanical, including photocopying and microfilm, without permission in writing from PCTEST Engineering Laboratory, Inc. If you have any questions about this international copyright or have an
enquiry about obtaining additional rights to this report or assembly of contents thereof, please contact INFO@PCTEST.COM.


       15. EHIMA GSM Project, Development phase, Part II Project Report. Technical-Audiological
           Laboratory and Telecom Denmark, June 1994.

       16. EHIMA GSM Project Final Report, Hearing Aids and GSM Mobile Telephones: Interference
           Problems, Methods of Measurement and Levels of Immunity. Technical-Audiological Laboratory
           and Telecom Denmark, 1995.

       17. HAMPIS Report, Comparison of Mobile phone electromagnetic near field with an upscaled
           electromagnetic far field, using hearing aid as reference, 21 October 1999.

       18. Hearing Aids/GSM, Report from OTWIDAM, Technical-Audiological Laboratory and Telecom
           Denmark, April 1993.

       19. IEEE 100, The Authoritative Dictionary of IEEE Standards Terms, Seventh Edition.

       20. Joyner, K. H, et. al., Interference to Hearing Aids by the New Digital Mobile Telephone System,
           Global System for Mobile (GSM) Communication Standard, National Acoustic Laboratory,
           Australian Hearing Series, Sydney 1993.

       21. Joyner, K. H., et. al., Interference to Hearing Aids by the Digital Mobile Telephone System, Global
           System for Mobile Communications (GSM), NAL Report #131, National Acoustic Laboratory,
           Australian Hearing Series, Sydney, 1995.

       22. Konigstein, D., and Hansen, D., “A New Family of TEM Cells with enlarged bandwidth and
           Optimized working Volume,” in the Proceedings of the 7th International Symposium on EMC,
           Zurich, Switzerland, March 1987; 50:9, pp. 127-132.

       23. Kuk, F., and Hjorstgaard, N. K., “Factors affecting interference from digital cellular telephones,”
           Hearing Journal, 1997; 50:9, pp 32-34.

       24. Ma, M. A., and Kanda, M., ”Electromagnetic Compatibility and Interference Metrology,” U.S.
           Department of Commerce, National Bureau of Standards, Technical Note 1099, July 1986, pp.
           17-43.

       25. Ma, M. A., Sreenivashiah, I. , and Chang, D. C., “A Method of Determining the Emission and
           Susceptibility Levels of Electrically Small Objects Using a TEM Cell,” U.S. Department of
           Commerce, National Bureau of Standards, Technial Note 1040, July 1981.

       26. McCandless, G. A., and Lyregaard, P. E., Prescription of Gain/Output (POGO) for Hearing Aids,
           Hearing Instruments 1:16-21, 1983

       27. Skopec, M., “Hearing Aid Electromagnetic Interference from Digital Wireless Telephones, “IEEE
           Transactions on Rehabilitation Engineering, vol. 6, no. 2, pp. 235-239, June 1998.

       28. Technical Report, GSM 05.90, GSM EMC Considerations, European Telecommunications
           Standards Institute, January 1993.

       29. Victorian, T. A., “Digital Cellular Telephone Interference and Hearing Aid Compatibility—an
           Update,” Hearing Journal 1998; 51:10, pp. 53-60

       30. Wong, G. S. K., and Embleton, T. F. W., eds., AIP Handbook of Condenser Microphones: Theory,
           Calibration and Measurements, AIP Press.

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© 2018 PCTEST Engineering Laboratory, Inc. All rights reserved. Unless otherwise specified, no part of this report may be reproduced or utilized in any part, form or by any means, electronic or
mechanical, including photocopying and microfilm, without permission in writing from PCTEST Engineering Laboratory, Inc. If you have any questions about this international copyright or have an
enquiry about obtaining additional rights to this report or assembly of contents thereof, please contact INFO@PCTEST.COM.



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