WJ Communications SX1115 User Manual Response to 2 Dec request re MPE

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Document ID	73371
Application ID	G/Vt3BbQfdMxu63iShog9w==
Document Description	Response to 2 Dec request re MPE
Short Term Confidential	No
Permanent Confidential	No
Supercede	No
Document Type	User Manual
Display Format	Adobe Acrobat PDF - pdf
Filesize	1.44kB (17995 bits)
Date Submitted	1999-12-03 00:00:00
Date Available	1999-12-20 00:00:00
Creation Date	2001-05-10 07:59:13
Producing Software	Acrobat Distiller 4.0 for Windows
Document Lastmod	2001-05-10 07:59:14
Document Title	Response to 2 Dec request re MPE

page 1of 4 pages
Thomas N. Cokenias
EMC & Radio Type Approvals
Test & Consulting Services for Commercial, Military, International Compliance
P.O. Box 1086
El Granada, CA 94018
2 December
Greg:
Your questions and my responses
Tom
Re:
FCC ID NTTSX1115
Applicant:
Correspondence Reference Number: 10902
731 Confirmation Number:
Date of Original E-Mail:
Watkins Johnson Company
EA95108
12/02/1999
Please address the following questions (given that the maximum proposed EIRP is
quite high, there is no way to avoid these issues).
1. The original antenna list has a 8 dBi antenna which has been changed
to a 18.5 dBi antenna in the revised antenna list; please clarify if
this is a replacement or addition.
ANS: The flat panel antenna gain is 18.5 dB. The 8 dBi entry is a typo.
2. The MPE info has a 22 dBi antenna, the uploaded antenna list has a 23 dBi 1ft dish (the closest match), please clarify which is the correct one.
ANS: The Radio Waves model SP1-5.8 1 ft diameter antenna gain is 22 dBi. The 23 dBi
entry is a typo.
3. There is no antenna or other info for the 14 dBi antenna (Mobile Mark, SCR
14-5723). Please upload appropriate antenna info, photo if applicable, and
installation requirements for determining MPE compliance requirements.
ANS: Information has been uploaded. See 14dBispec.pdf
4. The uploaded installation instructions and requirements are CISCO procedures
for using this transceiver. Please provide Watkins Johnson's antenna
installation procedures and requirements for non-CISCO operations. The
applicant is proposing professional installation. Specific antenna installation
procedures and requirements for the 5 (or 6) antennas proposed in this filing
may be provided to the professional installers to ensure MPE compliance; if
applicable, please upload a copy of the specific installation instructions.
Instructions and/or warnings must indicate installer responsibility and
identifying the purpose of installation requirements is for FCC RF exposure
compliance.
ANS: Please disregard the Cisco draft manual previously submitted. The Cisco manual
currently addresses the MMDS ODU head and will require additional revisions to include
tel: 650-726-1263
fax: 650-726-1252
internet: trephonc@macconnect.com
page 2of 4 pages
the UNII transceiver. Instead, please refer to the WJ draft, with modified page 7
amendment.
5. Please address the following and revise info and/or appropriate manuals and
installation guides accordingly (both CISCO and Watkins Johnson if appropriate):
(a) The filing, as indicated on the EAS, is requesting for 316 mW (25 dBm). The
highest conducted output indicated in the MPE info is 27.8 dBm (603 mW). The
maximum conducted output indicated in the WARNING statement in the CISCO
installation manual is 33 dBi (should it be dBm ?), which is higher than those
requested and measured.
ANS: Please disregard the Cisco draft manual previously submitted. The Cisco manual
currently addresses the MMDS ODU head and will require additional revisions to include
the UNII transceiver The 33 dBm output refers to the MMDS band and is not applicable
to this UNII product. Maximum power for the UNII 6 MHz channel is 24.8 dBm, and
for 12 MHz channels the maximum allowed power is 27.8 dBm.
Please update the 731 form for NTTSX1115 to state 27.8 dBm, or 603 mW, as the
maximum power output from this product.
(b) The antenna gain and separation distance for compliance indicated on the
subsequent page (Table 6) of the CISCO manual only goes up to 30 dBi. This
filing is proposing to use antennas up to 34 dBi, please revise accordingly.
ANS: Please disregard the Cisco draft manual previously submitted. The Cisco manual
currently addresses the MMDS ODU head and will require additional revisions to include
the UNII transceiver. The antenna gains shown in Table 6 are for MMDS at an output
power of 33 dBm . The corresponding table for this UNII product is found on the
revised page 7 of the WJ installation instructions
The table reflects highest EIRP values allowed by Part 15 and are applicable to 12 MHz
channels. Power and EIRP for 6 MHz channels would be 3 dB lower.
This table will be reproduced on revised page 7 of the WJ instruction manual. The revised
page 7 is submitted as a separate attachment to this correspondence.
(c) Distances for both uncontrolled and controlled exposures are indicated in
Table 6. There is no explanation to the installer or user on which exposure
distances are applicable for what conditions. Note: unless professional
installers have been specifically trained on RF exposure requirements and know
how to satisfy controlled exposure limits, uncontrolled limits should be used.
ANS: Please disregard the Cisco draft manual previously submitted. The Cisco manual
currently addresses the MMDS ODU head and will require additional revisions to include
the UNII transceiver. The revised page 7 of the WJ draft installation manual will contain
Table 2 showing only uncontrolled exposure distances. Controlled exposure limits will
not be addressed, only uncontrolled exposure limits will be used.
(d) It is not clear if the minimum distances indicated in Table 6 for controlled
and uncontrolled exposure requirements are antenna installation requirements or
distances for persons to maintain. The WARNING statement indicates hazard may
exist, determine antenna gain and locate minimum acceptable distance; but there
is no RF exposure compliance requirements. It should indicated to users and
tel: 650-726-1263
fax: 650-726-1252
internet: trephonc@macconnect.com
page 3of 4 pages
installers about their responsibility to install antennas according to
requirements in order to comply with FCC RF exposure requirements.
ANS: Revisions have been made to the WJ manual to address these items. Please refer
to the revised page 7 for the WJ draft user manual.
5. The proposed antennas must be fix-mounted on permanent structures with an
acceptable separation distance from all bystanders to qualify for categorical
exclusion from routine MPE compliance with respect to 1.1307 for fixed
transmitters; otherwise, they will be handled as mobile transmitters and routine
MPE measurement or computational modeling will be needed to demonstrate
compliance. If an antenna will be co-located with other antennas, RF exposure
compliance for the site must satisfy 1.1307(c) requirements. Please clarify if
antennas for this transmitter will be co-located at sites with multiple
antennas.
ANS: Revisions have been made to the WJ manual to address these items. Please refer
to the revised page 7 for the WJ draft user manual.
Please address above issues with respect to following suggested grant conditions
- Antennas used for this transmitter must be professionally installed on
permanent structures for outdoor operations to qualify for categorical exclusion
from routine MPE evaluation. Appropriate installation instructions,
requirements and minimum separation distances, as determined in the filing, must
be given to installers to ensure antenna installations satisfy MPE compliance
for fixed transmitter operations. If an antenna is co-located with other
antennas at a site, RF exposure requirements for the site must be satisfied with
respect to 1.1307(c). Separate approval for RF exposure compliance is required
for all other non-fixed and indoor operations.
ANS: In summary:
1. Antennas used with the WJ UNII transmitter will be professionally installed
on permanent structures for outdoor point-to-point operation only.
2.
Installation instructions to antenna installers will be placed in the WJ
installation manual. These instructions will include information re minimum
separation distances to satisfy MPE compliance.
3. There will be no indoor or non-fixed operation for this product.
tel: 650-726-1263
fax: 650-726-1252
internet: trephonc@macconnect.com
page 4of 4 pages
Page 7 of the WJ Beta Draft 2 instruction manual will be modified as follows:
BETA DRAFT2 - WJ CONFIDENTIAL
Antenna Installation Instructions: FCC RF Exposure Limits
The WJ SX11xx series of UNII transceivers, used in conjunction with 18 - 34 dBi gain antennas, are to be
employed in point -to- point applications only. Antennas used for these transmitters shall be professionally
installed on permanent structures for outdoor operations. The installer is responsible for ensuring that the
systems using high gain directional antennas are used exclusively for fixed, point-to-point operations.
The installer shall mount all transmit antennas so as to comply with the limits for human exposure to radio
frequency (RF) fields per paragraph 1.1307 of the Federal Communications Commission (FCC) Regulations
. The FCC requirements incorporate limits for Maximum Permissible Exposure (MPE) in terms of electric
field strength, magnetic field strength, and power density.
The WJ UNII transmitters are intended to be installed in restricted access areas, where access can only be
gained by service personnel through the use of a special tool, lock and key, or other means of security.
Regardless, antenna installations shall be engineered so that MPE is limited to 1 mW/cm2 , the more
stringent limit for "uncontrolled environments". Table 2 below specifies the minimum distance that must
be maintained between the antenna and any areas where persons may have access, including rooftop
walkways, sidewalks, as well as through windows and other RF-transparent areas behind which persons may
be located.
Table 2 Antenna Radiation Hazard
Antenna
10 dBi
12 dBi
14 dBi* corner reflector
18.5 dBi* flat panel
20 dBi
22 dBi* 1ft dish
P max per Rules
27.8 dBm
27.8 dBm
27.8 dBm
27.8 dBm
27.8 dBm
27.8 dBm
MPE distance, cm
21.9
27.5
34.7
58.2
69.2
87.1
Regulatory Limit
max power,15.407a3
max power,15.407a3
max power,15.407a3
max power, 15.407a3
max power,15.407a3
max power, 15.407a3
24 dBi
26 dBi* flat panel
28 dBi
30 dBi
32 dBi
34 dBi* 4ft dish
26.8 dBm
24.8 dBm
22.8 dBm
20.8 dBm
18.8 dBm
16.8 dBm
97.7
97.7
97.7
97.7
97.7
97.7
max EIRP, 15.407a3
max EIRP, 15.407a3
max EIRP, 15.407a3
max EIRP, 15.407a3
max EIRP, 15.407a3
max EIRP, 15.407a3
*Antennas tested and qualified for FCC certification August - October 1999. Other antenna types may be
used, provided applicable requirements in FCC Rule parts 2 and 15 are met.
Antenna manufacturer-supplied installation instructions for specific models generally contain information
regarding antenna mounting, aiming, lightning protection, and other relevant factors. In addition to meeting
these requirements, the antenna system installer is responsible for installing antennas so that they comply
with FCC RF exposure requirements.
tel: 650-726-1263
fax: 650-726-1252
internet: trephonc@macconnect.com

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