FCC ID: L2C0023TR UWB Vehicular Radar

Re:

Certification for Delphi Delco UWB Radar Model: 12237659 FCC ID: L2C0023TR IC: 3432A-0023TR USER'S MANUAL INFORMATION

(PRELIMINARY) The User's Manual is in preparation. The following material will be contained in the manual:

FCC ID: L2C0023TR IC: 3432A-0023TR This device complies with Part 15 of the FCC Rules and with RSS-210 of Industry Canada. Operation is subject to the following two conditions:

(1) This device may not cause harmful interference, and

(2) This device must accept any interference received, including interference that may cause undesired operation. WARNING: Changes or modifications not expressively approved by the party responsible for compliance could void the user's authority to operate the equipment. The term IC: before the radio certification number only signifies that Industry Canada technical specifications were met.

October 12, 2004 Re:

Certification for Delphi Delco UWB Radar Model: 12237659 FCC ID: L2C0023TR IC: 3432A-0023TR Federal Communications Commission Equipment Approval Services P.O. Box 358315 Pittsburgh, PA 15251-5315 Please find enclosed application materials for certification of Delphi Delco 12237659 UWB Radar. We tested it and found it to comply with FCC Part 15. If there are any questions regarding the application or testing performed, please contact me at the above address or call 734-483-4211, fax 734-647-2106, or e-mail liepa@umich.edu. Valdis V. Liepa Research Scientist Sincerely, October 12, 2004 Certification and Engineering Bureau Industry Canada 3701 Carling Avenue, Bldg. 94 Ottawa, Ontario K2H 8S2 Please find enclosed application materials for certification of Delphi Delco 12237659 UWB Radar. We tested the device and found it to comply with RSS-210. The product is identified by:

Certification for Delphi Delco UWB Radar Model: 12237659 FCC ID: L2C0023TR IC: 3432A-0023TR Re:

IC: 3432A-0023TR If there are any questions, suggestions, etc., regarding the application or testing performed, please contact me at the above address or call 734-483-4211, fax 734-647-

2106; e-mail: liepa@umich.edu. Valdis V. Liepa Research Scientist Sincerely,

Radar System Design

Design Drivers Small targets at 5 meters distance : Good system detection sensitivity Precision Ranging capability : MUST have large radiated bandwidth Wideband FCC frequency allocations demand very low transmitter power Low transmit power + good system sensitivity means Sensitive receiver required Efficient waveform for detection is necessary

Waveform noise code Continuous Wave radiation modulated in phase by a high speed pseudo Phase modulation is binary phase shift key (BPSK) Code modulated continuous wave provides efficient waveform and good range precision Delco Electronics Systems Proprietary Principles of Operation

Range Bin Definition As a target range (time delay) varies slightly about the time (range) delay imparted to the receive code, the receiver output (voltage) varies to less than maximum. The range response of the system for a fixed return signal power is as follows t u p t u o r e v i e c e r range Rn Delco Electronics Systems Proprietary Principles of Operation

The POSITION of the range bin in space is determined by the time delay of the receive code The entire range is covered by scanning the single range bin in range Scanning is accomplished by adjusting the time delay value of the receive code

The WIDTH of the range bin (depth of bin in space) is determined by the period of one bit of the pseudo noise code sequence high speed code clocks = thin range bins Delco Electronics Systems Proprietary Principles of Operation

Achieving Receiver Sensitivity Direct detection of the LO signal which comes out of the receive phase modulator cannot provide adequate receiver sensitivity The transmit LO signal is further modulated by a data stream to provide an AC signal after down conversion for detection. I Q data target carrier with

"data"

sidebands receive receive code delay unit code generator transmit data transmit code LO Delco Electronics Systems Proprietary Principles of Operation

Diagnostics There is an End to End diagnostic function implemented, which gives very high coverage of detecting failures This feature is accomplished by positioning the system range bin such that it contains the transmit and receive antennas. Direct coupling between antennas provides a reliable signal injection into the receiver range bin positioned over antennas with the proper delay value LO with

"data"

sidebands receive receive code delay unit direct coupling provides Diagnostic signal code generator transmit data transmit code I Q data LO Delco Electronics Systems Proprietary

This device complies with part 15 of the FCC rules, and with RCC -210 of Industry Canada. Operation is subject to the following

{wo conditions:(1)This device may not cause harmful interterence and (2) this device must accept any interference received. including interferences that may cause undesired operation FCC ID: TBD CAN: TBD 2L1T15K859-B6 DeLPHI VAM REATES3OR005300 1008 Assembled in Mexico

*ARBA7659000033001000" Sole P/N:12237659 E

FCC ID L2C0023TR Delphi Delco Electronics Systems 28332 ATTN: Joe Dichoso Re:

Applicant:

Correspondence Reference Number:

731 Confirmation Number: EA384397 Dear Joe, We have some concerns about measurement procedures with regard to demonstration of EIRP emission limit compliance at mm-wave frequencies. Please consider the following example. Example: Measurement of a UWB emission measurement at 100 GHz DUT LNA Mixer Horn Antenna Spectrum Analyzer Measurement Distance Figure 1. Measurement Setup and Test Receiver Chain FCC EIRP limit: -61.3 dBm 1) Formulate power measured at the test receiver due to a source with EIRP = -61.3 dBm

(a) Prec(dBm) = EIRP(dBm) + G + 20 log10(/(4 Rmeas)) where Prec is the power received by the test receiver, G is the receiver antenna gain, is the receiver, and Rmeas is the measurement distance. At a distance of 3 meters, using a standard gain horn antenna of G = 25 dBi, frequency of 100 GHz, and no LNA,

(b) 2) Next, we consider the noise floor of the receiver (without LNA). For an Agilent 8563E Spectrum Analyzer with 11970W harmonic mixer, in a 1 kHz bandwidth, Agilent datasheets give the noise floor as:

Prec(dBm) = -118.3 (at 3 meters) Pr(noise) ~ -85 dBm / 1kHz

(c) For a 1 MHz BW, this equates to -55 dBm / 1 MHz. We measure -50.1 dBm / 1 MHz for our particular mixer and spectrum analyzer. Thus, the signal-to-noise ratio (SNR) at a distance of 3 m from a device, using our particular receiver and spectrum analyzer is (b) (c) = (d)

(d) SNR(3m) = -118 - -50.1 = -67.9 dB At 40 dB/decade field decay (per FCC mm-Wave Measurement Procedures), the range at which this receiver can achieve a SNR > 0 dB occurs at a distance reduced by more than 1.5 decades, a distance of ~6 cm from the DUT. However, from the FCC specified 20 dB/decade for UWB devices, the measurement distance is reduced by more than 3 decades, becoming less than 1.2 mm. 3) While measurements may be made at this range, we must consider whether measurements at these ranges would be acceptable to the FCC. If it is deemed that measurements must be made at a greater distance, then a low noise amplifier may be required. After an extensive search we have found a small handful of companies that can provide top of the line W-band LNAs. Of these LNAs, the best amplifier commercially available, with 18 dB of gain and a noise figure of 4.5 dB, has a lead time of 10 weeks for custom construction and costs between $6000 and $8000. However, please note that such an amplifier, even with an ideal noise figure, would only improve the SNR of our receiver by 18 dB, still requiring measurements at a range of 9 mm from the DUT (assuming a 20 dB/decade field decay). Finally, while we have outlined the situation for a 100 GHz (W-band) example, a similar situation exists for the frequency range between 50 and 75 GHz (V-band), where measurement ranges are only slightly increased. Therefore, our question is: At what measurement range would the FCC consider the measurement results sufficient for demonstration of EIRP compliance?

FCC ID L2C0023TR Delphi Delco Electronics Systems 28186 EA384397 December 22, 2004 Re:

Applicant:

Correspondence Reference Number:

731 Confirmation Number:

The following is in response to the questions raised in certification of the above application. 1) A sealed enclosure is insufficient justification for Confidentiality of the internal photos. If someone can still open the device, and take photos then the internal photos cannot be held confidential. Provide sufficient justification or submit a new confidential letter without the internal photos listed. Delphi has decided that, since a sealed enclosure has been deemed insufficient justification for Confidentiality, they will remove their request to attain permanent internal photo confidentiality. However, Delphi does request short term confidentiality for the internal photos exhibit. This request is justified, as the device in question is scheduled for release in the 2006 automotive model year. Thus, these devices will not be available to the general public for 8 months. A set of updated cover letters has been uploaded with this response. 2) For UWB devices, a 20 dB/decade is used. Do not use a 40 dB/decade extrapolation factor. Please submit a corrected test report. Please note that use of 20 dB/dec in the near-field of the device conflicts with the FCCs microwave measurement procedures document (FCC 20040514-002). Has the FCC decided to modify the microwave measurements procedures? If not, please justify why microwave measurement procedures do not apply to UWB devices operating in the microwave region, as the rate of field decay from such devices does not deviate from those of other microwave devices certified under other sections of the FCC regulations. Please also see our response to question 5) below. 3) Justify a clear demonstration of classification of the 8 GHz and 16 GHz emission as digital circuitry per 15.521(c). The 16 GHz emission is an LO generated for use only in the receive chain of the radar (see block diagram), and as part of a receiver > 960 MHz should not subject per FCC 15.101(b). The 8 GHz radiated emission is not an emission from the TX chain, but is believed to be a spurious emission emanating from the device receive chain LO (the doubler in the RX chain requires the largest portion of the LO power, the reference signal to the transmitter is 14 dB lower). The 8 GHz emission does not radiate at a level above the UWB emission from the transmitters antenna, as computed from the theoretical performance of the BPSK digital encoder and both the calculated and measured response of the TX chain Bandpass Filter (-30 dB at 8 GHz). The waveform associated with the particular PN code has the center spectral line reduced by 36 dB relative to the first upper and lower spectral lines of the waveform. Thus, this emission is believed to be solely an emission from the receiver portion of the radar. Thus, as a component of a receiver > 960 MHz, this emission should not subject per FCC 15.101(b). In the test report, these emissions were labeled as digital emissions when demonstrating that they meet the FCC Class B limit. The test report has been revised and uploaded. 4) Provide a description of the measurement procedure used for measuring compliance with Section 15.515(c). Initially, the peak level of the radiated emissions is measured over all azimuth and elevation angles. (The dominant source of radiated energy is the transmit antenna.) This peak occurs at the same angle that the antenna gain is maximized, which is perpendicular to the radome (azimuth = 0 degrees). This is measured with the radar in spread spectrum mode, operating as it would in the field, with the receive antenna co-polarized with the radar antenna. Next, the radar module is placed in a CW test mode, with the spread spectrum modulation disabled. In this mode, the unit transmits higher power spectral density, providing a means of making the pattern measurement with sufficient dynamic range. With the device in this mode, the worst case azimuth and elevation patterns are measured. Once antenna patterns are obtained, the peak UWB transmitted power level, measured at 24.0 GHz in Section 6.2, is assumed to correlate to the peak of the measured pattern. The off angle power is then computed by subtracting the sidelobe level (dBc) from the main lobe transmitted power. 5) In table 6.1, measurement distances at the upper frequencies are at 0.3, 0.1 and 0.05 meters. With regard to measuring in the near field-

what is the beam width and antenna patterns at these frequencies? and can the full EUT be seen?

The antennas in question are standard gain horn antennas (NRL Rep. No. 4433), and thus they do not see the entire device at close range. Therefore, the DUT was rotated through all axes and angles in front of the antenna, keeping the separation distance listed. However, due to noise floor limitations, measurements must be made at these distances

(with a 40 dB/dec conversion factor) in order to demonstrate compliance as discussed below. Note: The use of a 20 dB/dec near-field attenuation rate will present a certification issue. Note that the measurements made in the frequency bands 40-65 GHz and 65-110 GHz are measurements at receiver noise floor, even with the use of high-end test equipment, mixers, and horn antennas. With a 40 dB/dec near field attenuation, the DUT meets the UWB limits by 3.1 dB in W-band. With a 20 dB/dec near-field extrapolation, the measurement receiver noise floor will be greater than the FCC UWB limit, even for RMS measurements at exceedingly small measurement distances. Thus, in order to decrease the measurement receivers noise floor, 40-110 GHz LNAs will be required (to reduce the receiver noise due to mixer conversion loss). At this time, such devices are not economically feasible for the test and measurement community.

FCC ID L2C0023TR Delphi Delco Electronics Systems 28387 EA384397 Re:

Applicant:

Correspondence Reference Number:

731 Confirmation Number:

The following is in response to the questions raised on the above application:

FCC Equipment Authorization System 1) Short term confidentiality cannot be granted for a period of 8 months. An initial term of 45 days is issued with extensions with justification up to 180 days maximum. You need to contact Rich Fabina a week before the end of each 45 day period to provide justification for an extension. Please confirm. Yes, this will be sufficient. We will contact Rich Fabina at the end of each 45 day period so long as we desire the internal photos to remain confidential, with confidentiality removed no greater than 180 days from the date of the grant. 2) For UWB devices, a 20 dB/decade extrapolation factor must be used. If the device cannot be modified and a corrected test report submitted, then the device will be denied. You must use(purchase or lease) equipment that will be needed for the measurements. The measurement system and configuration (including measurement distance) should have enough sensitivity to demonstrate compliance of the device at the limits specified. A modified radar has been fully re-tested and determined to comply with the FCC regulations using the aforementioned 20 dB/decade criterion. Because small modifications were made to the DUT by the manufacturer, some updated exhibits, in addition to the new test report, have been uploaded. We look forward to your review of the updated application. If possible, please provide us with feedback as quick as possible due to time constraints at our end. Thank you, JDB

Re:

Certification for Delphi Delco UWB Radar Model: 12237659 FCC ID: L2C0023TR IC: 3432A-0023TR POWER OF ATTORNEY A letter granting Valdis V. Liepa the Power of Attorney is on file and can be provided when so requested. Re:

Certification for Delphi Delco UWB Radar Model: 12237659 FCC ID: L2C0023TR IC: 3432A-0023TR REQUEST FOR CONFIDENTIALITY

(5) Schematics

(10) Parts List (Part of Exhibit only) Pursuant to 47 CRF 0.459, Delphi Delco requests that a part of the subject application be held confidential. This comprises Exhibits Delphi Delco has spent substantial effort in developing this product and it is one of the first of its kind in industry. Having the subject information easily available to

"competition" would negate the advantage they have achieved by developing this product. Not protecting the details of the design will result in financial hardship. If there are any questions regarding this request, please contact me at the above address or call 734-483-4211, fax 734-647-2106 or e-mail liepa@umich.edu. Valdis V. Liepa Research Scientist University of Michigan Sincerely, Re:

Certification for Delphi Delco UWB Radar Model: 12237659 FCC ID: L2C0023TR IC: 3432A-0023TR REQUEST FOR SHORT-TERM CONFIDENTIALITY

(5) Internal Photos Delphi Delco requests that a part of the subject application be held short-term confidential. This comprises Exhibit(s) The device in question will not be available to the consumer until the 2006 automotive model year, approximately 8 months from the time of this request. Thus, Delphi Delco requests that the internal photos not be made public at this time. If there are any questions regarding this request, please contact me at the above address or call 734-483-4211, fax 734-647-2106 or e-mail liepa@umich.edu. Valdis V. Liepa Sincerely, October 12, 2004 Re:

Certification for Delphi Delco UWB Radar Model: 12237659 FCC ID: L2C0023TR IC: 3432A-0023TR There were no modifications made to the DUT by this test laboratory. (Also see Section 3.1 of the attached Test Report). _____________________ Valdis V. Liepa Research Scientist STATEMENT OF MODIFICATIONS Re:

GENERAL PRODUCT INFORMATION The device, for which certification is pursued, has been designed by:

Certification for Delphi Delco UWB Radar Model: 12237659 FCC ID: L2C0023TR IC: 3432A-0023TR It will be manufactured by:

Canadian Contact:

Delphi Automotive Systems One Corporate Center Kokomo, IN 46904-9005 Bill Lusa Tel: 734-484-1387 Fax: 734-484-1389 Delphi Delco Electronics de Mexico SA de CV Reynosa Carrertera Reynosa - Matamoros Km 13.5 Parque Industrial Codigo Postal 88780 Partado Postal 1201 Reynosa, Tamaulipas, Mexico Bill Lusa Tel: 734-484-1387 Fax: 734-484-1389 Richard Wilkins c/o Delphi Energy and Chassis Systems Oshawa, Ontario L1N 7S6 richard.wilkins@delphi.com Ph. (905)644-5216 Page 1 of 1 Joseph D Brunett From:

LabHelp [LabHelp@fcc.gov]

Sent:

Friday, September 17, 2004 2:59 PM To:

Valdis V. Liepa Subject: RE: 15.515 / 15.521 Measurements Question:

If the peak detected emissions from a device meet the RMS EIRP limits, with all Spectrum Analyzer settings identical to the requested RMS detected method except with peak detection, is that sufficient to demonstrate compliance with said limits? (Since the peak detected values will always be greater than the RMS detected values for every bin of the spectrum analyzer output.) Our Spectrum Analyzer does not have the built in RMS detector function and, so long as the device meets the EIRP limits with a peak detector, we prefer not to use the alternative method for determining RMS values as it is an exceptionally long and complicated test. Answer:

Yes, you can use a peak detector. Use of a peak detector is sufficient to demonstrate compliance with the RMS limits. 10/12/2004