FCC ID: E5MDS-RCL220 220MHz Data Transceiver Module for use in the GE MDS Orbit platform

RCL220 Radio Module Module Integration Guide Revision 1.0 Prepared by: GE MDS Engineering Team 17-JULY-2023 RCL220: Module Integration Guide Table of Contents General Description ...................................................................................................................................... 2 Specifications ................................................................................................................................................ 3 Table 1: RCL220 Module Specifications .................................................................................................... 3 Hardware Dimensions ................................................................................................................................... 4 Interface Specification .................................................................................................................................. 5 Application Information: Radio Network operation ..................................................................................... 6 Note about terminology used ............................................................................................................... 6 LCU-OCU Direct Mode (No Repeaters) ..................................................................................................... 6 LCU-OCU Mode with Coordinating Repeater ........................................................................................... 7 Multiple LCU-OCU with Multiple Repeaters ............................................................................................. 8 User Interface ............................................................................................................................................... 9 Regulatory Information for Limited Modular Use ...................................................................................... 12 Applicable FCC Rules ............................................................................................................................... 12 Operational use conditions ..................................................................................................................... 12 Limited Module Host restrictions ........................................................................................................... 12 Trace antenna designs ............................................................................................................................ 12 RF exposure considerations .................................................................................................................... 12 Antennas ................................................................................................................................................. 12 Labeling and Compliance ........................................................................................................................ 13 Test Modes .............................................................................................................................................. 13 Additional testing for Part 15 Subpart B ................................................................................................. 13 EMI Considerations ................................................................................................................................. 13 Changes ................................................................................................................................................... 14 Process for FCC Compliance of RCL220 Installed in Host ........................................................................... 15 Receiver sDoC Procedure ........................................................................................................................ 15 Transmitter Conducted Emissions Assessment ...................................................................................... 15 Transmitter Radiated Emissions Assessment ......................................................................................... 16 Page 1 of 16 RCL220: Module Integration Guide General Description The Association of American Railroads has established a specification for the remote control of locomotives. The Remote-Control Locomotive (RCL) protocol is transmitted wirelessly from external control points to the locomotive. GE MDS is providing the equipment that provides the wireless physical layers over which the RCL communication protocol is shared in the 220MHz band. The RCL220 Radio Module is shown in Figure 1, Below. This module is in a form factor approximately 4x2x0.5, has a 52-pin card edge connector for data/power interface, and a TNC connector for the antenna connection. Figure 1: RCL220 Radio Module This module is designed for installation only in the GE MDS Orbit MCR chassis as shown in Figure 2, below. Figure 2: GE MDS Orbit MCR (Left) and ECR (Right) form factors. The Orbit MCR host supplies regulated 5.25V power for operation of this module, serial interfaces for payload and diagnostics, and an USB interface that is used for updating the module firmware. Page 2 of 16 RCL220: Module Integration Guide Specifications Table 1: RCL220 Module Specifications Description:

220MHz Railroad Communications Module Manufacturer:

Operating Frequency Range:

GE MDS, LLC 175 Science Parkway Rochester, NY 14620 USA 217-222MHz (Transmit) 217-222MHz (Receive) Applicable Regulations:

FCC CFR47 Part 90 (217-222MHz) ISED RSS-119 (217-220MHz) Output Power:

+33dBm Modulation:

Bandwidth:

Channel Spacing:

GMSK, Bandwidth Time = 0.3, 9615bps 12.5kHz 12.5kHz Transmitter Architecture:

Synthesized Direct Conversion Receiver Architecture:

Synthesized Direct Conversion Reference Clock:

39MHz, 0.5ppm RF Interface:

TNC (Female) for Tx/Rx functions Data Interface:

52-pin Card Edge connector provides:

USB (Maintenance/Firmware updates) Serial (Diagnostics/Configuration) Serial (Payload data) Operating Temperature Range: -40 to +70C Module Operating Voltage:

5.25VDC (Supplied through edge connector) Module Operating Current:

2.0A (At maximum TX RF power operation) Module Dimensions:

3.4x1.6x0.4 Page 3 of 16 RCL220: Module Integration Guide Hardware Dimensions Page 4 of 16 RCL220: Module Integration Guide Interface Specification The 52pin Host interface pinout is as shown in Table 2, Below. Table 2: Host Interface Pinout Page 5 of 16 RCL220: Module Integration Guide Application Information: Radio Network operation The RCL220 is a half-duplex radio module designed for use in TDMA RCL networks. The unit is designed for installation in the Operator Control Unit (OCU) to communicate with other radio products in a railyard, including locomotive (Locomotive Control Unit, or LCU) or Repeaters. This product is configured with a list of TX and RX frequency pairs that are entered by an authorized representative of the railroad communications team. The frequencies are scanned in receive mode until a reliable RF link is found. Note about terminology used The frequency hopping referred to within this document is not a form of spread spectrum, but rather a method the railroad spectrum licensee uses to automatically chose other frequency pairs they have been assigned when a channel is congested and/or has poor signal conditions to sustain reliable communications. The system will step through two frequency pairs in four seconds. Repeaters in the railyard are devices that can receive transmissions from LCU or OCU radios, demodulate the data, interpret the payload, and transmit new data to the LCU or OCU radios if needed. The term repeater in this sense is different than the repeaters classified by the FCC or ISED. LCU-OCU Direct Mode (No Repeaters) In its simplest form the RCL system can operate in a standalone fashion with no repeaters present. Prior to on-air deployment, an off-line configuration is required at which time the two OCUs are paired to their LCU. This initialization ensures that only the two pre-defined OCUs can communicate with and control the LCU. After initialization, when the units go live in the yard they will operate in Distributed Coordination Mode, also known as Direct Mode, and the wireless communication between the devices is done with a TDMA time slot channel changing scheme. Figure 4: LCU-OCU Direct Mode Page 6 of 16 RCL220: Module Integration Guide LCU-OCU Mode with Coordinating Repeater The system contains one Repeater which is configured in Coordinator mode. The LCU / OCUs are paired ahead just like in the Single-RCL use case, they boot into the slot-hopped DCM and establish communication with each other. Simultaneously, LCU discovers and establish communication with the coordinator and when the Distributed Coordination Mode (DCM) exit criteria are met, the LCU drives the system to switch to the Centralized Coordination Mode (CCM) which is controlled by the Coordinator. In CCM the timeslots allocated to the individual RCL systems in the yard is done intelligently by the Coordinator to prevent over-the-air packet collisions. This use case is also advantageous in that the overall wireless coverage is improved by having the secondary path between the LCU and OCUs that goes through the Coordinator. Figure 5: LCU-OCU Mode with Repeater Page 7 of 16 RCL220: Module Integration Guide Multiple LCU-OCU with Multiple Repeaters The system contains one Repeater which runs in Coordinator mode and one or more additional Repeaters acting as Satellites. The Coordinator and Satellites are linked together via a high-speed backbone on Ethernet, fiber, or highspeed wireless. The system behaves the same as the Single-

Repeater Use Case with one exception: all the wireless data packets received by the Repeaters are shared on the backbone. With the sharing of the packets across all the Repeaters the control algorithm can determine which Repeater is best to re-transmit to each OCU or LCU in the yard, resulting in the optimal coverage/communication scenario for the overall system. Figure 6: Multiple LCU-OCU Mode with Multiple Repeaters Page 8 of 16 RCL220: Module Integration Guide User Interface The Orbit MCR Host provides a command line interface on the COM2 port for radio configuration. Figure 7, below, shows the command line interface port of the Orbit MCR. Use baud 115200, 8-N-1. Figure 7: COM2 CLI (Command Line Interface) port for RCL220 inside of the Orbit MCR Host SREV [TIME]

Display MCU (TI) software revision. Entering the optional time argument causes a build timestamp to be displayed. PASS xxxx By entering a password additional engineering and factory only commands may be used. RX xxx.xxxxx This sets the receive frequency used in test mode. Up to 5 digits can be entered after the decimal point, but trailing zeros do not have to be entered. Range checking is not performed. TX xxx.xxxxx This sets the transmit frequency used in test mode. Up to 5 digits can be entered after the decimal point, but trailing zeros do not have to be entered. Range checking is not performed. MFREQ1 xxx.xxxxx BFREQ1 xxx.xxxxx MFREQ2 xxx.xxxxx BFREQ2 xxx.xxxxx MFREQ3 xxx.xxxxx BFREQ3 xxx.xxxxx MFREQ4 xxx.xxxxx BFREQ4 xxx.xxxxx These commands set the corresponding receive & transmit frequency pair used as specified by the DSP (mac controller). Up to 5 digits can be entered after the decimal point, but trailing zeros do not have to be entered. Range checking is not performed. Page 9 of 16 RCL220: Module Integration Guide PWR x KEY KEYR This sets the transceivers output power. Valid options are H, L, and XL, for high, low, and extra low power settings, respectively. (At calibration time, H is normally associated with 2 watts, and L is normally associated with 0.5 watts, and XL is associated with FPWR 1). This is a test command that allows the user to unconditionally key the radio for test purposes. Key the radio with random data for test purposes. TONEKEY Key the radio unmodulated for test purposes. DKEY This is a test command that cancels the affect of a previous KEY command. MODEM SER RSSI RSSI ON This displays the current modem configuration. (Normally BAUD 9600, BT=.3, BW=12.5KHz). This can be used to determine if a modem test configuration is in effect (i.e., tones or analog operation). This displays the serial number of the radio (separate versions of this command exist for MCU &

DSP) This causes the receiver to output the current value of RSSI. The output range is 50 dBm

(strongest signal) to 120 dBm (no signal). This causes the receiver to output the current value of RSSI once every 3 seconds. RSSI OFF Turns off the continuous RSSI reading ATTN (ON/OFF) This puts the LNA in low gain mode (ON) or normal gain mode (OFF) HELP Displays this list of commands PROG INIT This initiates a procedure to reprogram the FLASH memory for the radio. This resets some common user programmable settings to the factory default. MODEM BAUD=9600, BT=.3, BW=12.5KHz RX 220.00000 MHz TX 220.00000 MHz BFREQ1 221.10625 MHz MFREQ1 220.106250 MHz BFREQ2 221.11875 MHz MFREQ2 220.11875 MHz PWR=H CAL DEV 40 POLL STARTUP OFF IEEP This resets all non-volatile memory. The radio will require factory recalibration. MM xxxx Used to directly view or modify a memory location. Page 10 of 16 RCL220: Module Integration Guide ALARM Returns a 4-digit hexadecimal alarm code. 0x8000 = Out-of-Lock 0x4000 = Not Calibrated FPWR xxx This is used to adjust output power. The valid range is 0 to 4096. CPWR x RSSL RSSH CAL CF xxxx This is used to associate the current output power with a pre-programmed PWR command setting. Valid options are H and L, for high and low power settings, respectively. Used to calibrate the RSSI while injecting a Low signal level (-90 dBm). Used to calibrate the RSSI while injecting a High signal level (-70 dBm). This allows calibration of the Center Frequency. The digits xxxx are in the range of 32767 to 32767 and represent a correction to be added to the operating frequency.

(Not in Hertz) Page 11 of 16 RCL220: Module Integration Guide Regulatory Information for Limited Modular Use Applicable FCC Rules This module is designed as a Part 90 device operating in the 217-222MHz band as detailed in Table 1:

RCL220 Module Specifications. WARNING: Any changes or modifications to the module not expressly approved by party responsible for compliance ( GE MDS, LLC) could void the users authority to operate the equipment. Operational use conditions This module may only be used with the GE MDS Orbit MCR Chassis. This module is intended for use in locomotive applications. This product is designed for operation from -40 to +70C and is not intended for outdoor use. This device is for professional installation only. Output power is configurable up to

+33dBm and must be adjusted to accommodate for antenna gain to conform to the specific ERP limits of the FCC licensee using this product. Limited Module Host restrictions The RCL220 radio module features a unique board to board connector and requires limited supply voltage and heatsinking provided by the Orbit MCR chassis. Trace antenna designs The RCL220 does not include any trace antenna designs, and therefore there are no applicable considerations for this topic. RF exposure considerations The radio equipment described in this operation emits radio frequency energy. The concentrated energy from a directional antenna may pose a health hazard. Persons may not come closer than 44 centimeters to the front of the antenna when the transmitter is operating with a 2.0dBi antenna and configured for

+33dBm output power. Antennas The conducted output power of the module installed in the host chassis is up to +33dBm. This module is intended for professional installation only for integration into the GE MDS Orbit MCR host. The antennas that have been tested and approved for use with this module are as listed in Table 3, below. Manufacturer PCTEL PCTEL Sinclair Sti-Co Table 3: Antennas tested with the RCL220 Module Model BMAXMFTS PCT-RSA-20 ST221-SfeNF HDLP-NB-220 Type Omnidirectional Omnidirectional Omnidirectional Omnidirectional Gain 0.0dBi 2.0dBi 2.12dBi 2.12dBi Page 12 of 16 RCL220: Module Integration Guide Labeling and Compliance Figure 8, below, is an example of the label that must be present on the Host: Orbit MCR as shown in Figure 9. This label is installed at the GE MDS factory during production. Figure 8, above: Orbit MCR Label showing Contains E5MDS-RCL220, 101D-RCL220 Figure 9: Location of label detailed in Figure 8, placed on the underside of the Orbit MCR Test Modes The Orbit MCR Host does not externalize module operational test modes to the end user. Test and alignment are performed during production calibration. Prior to product shipment, GE MDS performs a series of tests in the production environment to ensure that the completed assembly is operating satisfactorily. Additional testing for Part 15 Subpart B The Orbit MCR is the only permissible host for the GE MDS RCL220 Module. GE MDS must test and ensure that the MCR host complies with FCC Part 15 Subpart B when operating with the RCL220 radio module in place. EMI Considerations The RCL220 Radio Module includes integrated shielding for the RF section This module conforms to all applicable Part 15 and Part 90 requirements without needing to be installed inside of the host Page 13 of 16 RCL220: Module Integration Guide enclosure. The Orbit MCR host does not allow multiple modules (Cellular and 220MHz) to operate simultaneously, Changes GE MDS does not offer for sale the RCL220 as a standalone device for integration with other hosts. As the grantee of the host and this module, GE MDS does not have any offer guidance or technical contacts to enable third party entities to create such products. Page 14 of 16 RCL220: Module Integration Guide Process for FCC Compliance of RCL220 Installed in Host This section describes the procedure for ensuring that full compliance of the RCL220 Module is maintained when installed in the Orbit MCR Host. The module is evaluated inside of the Orbit MCR using the sDoC procedure established by the FCC for the receiver. The steps below additionally identify a process to assess Transmit and conducted and radiated emissions when the RCL220 Module is operating at its lowest and highest frequencies, and highest transmitter power setpoint when installed in the host. The transmitter assessment steps ensure no degradation of transmitter performance when operating in the host. 1. Install RCL220 Radio Module into the MCR Chassis per the Module Integration Instructions section of this document. 2. Attach the appropriate power source to the Orbit MCR: DC 10-60V, 12W minimum. 3. Connect a PC to the Orbit MCR COM2 port for configuration of the RCL220 module for testing purposes. 4. Log in to the EUT using factory login username and password. Receiver sDoC Procedure Unintentional emissions of the RCL220 shall be performed on the module when it is installed in the Orbit MCR. The end product is tested as a complete assembly with module installed. Performance is evaluated at the lowest, middle, and highest receive frequencies and evaluated against Part 15.109 using the 2.15dBi Omnidirectional antenna. Conducted emissions are performed using the conducted antenna port test per Part 15.111. 1. The EUT, when powered on, immediately enters receive mode. Commands to change RX frequency are required to complete the evaluation of the end product in receive mode. 2. Configure receiver to lowest frequency (command rx 217) 3. Perform radiated/conducted emissions testing 4. Repeat steps 2,3 at the middle frequency (command rx 219) 5. Repeat steps 2,3 at the highest receive frequency (command rx 222) GE MDS shall generate a Suppliers Declaration of Conformity sDoC declaring conformance of the unintentional radiator (receiver emissions) to FCC standards. GE MDS Orbit MCR is to provide instructions for RF exposure information to end users from page 12. Transmitter Conducted Emissions Assessment 1. Attach a spectrum analyzer to the EUT Transmit Antenna port. Ensure proper attenuation is present for +33dBm without sustaining damage. Spectrum analyzer should be configured for the same RBW, VBW, and Sweep Time, Start, and Stop frequencies as the Part 90 and Part 15 FCC Test Data results published in the RCL220 reports. 2. Configure transmitter power to +33dBm (command pwr hi) 3. Configure transmitter to lowest frequency (command tx 217) 4. Key the transmitter (command key) Page 15 of 16 RCL220: Module Integration Guide 5. Record the results for Conducted TX 217MHz. 6. Analyze the results to ensure that no new conducted spurious emissions exist, and that no existing spurious emissions are greater than the values obtained in the modular test reports. 7. Repeat steps 3, 4, 5, 6 at the highest frequency (command tx 222) Transmitter Radiated Emissions Assessment 1. This testing must be performed in an Anechoic Chamber. A spectrum analyzer should be configured for the same RBW, VBW, and Sweep Time, Start, and Stop frequencies as the Part 90 and Part 15 FCC Test Data results published in the RCL220 reports. Radiated Emissions tests are performed with both vertical and horizontal polarizations and 360-degree turntable. The original unintentional radiated emissions results are repeated with the RCL220 Module installed in the Orbit MCR. 2. Terminate the Transmitter antenna port using a 50-ohm load with a minimum power handling capability of 2W. 3. Configure transmitter power to +33dBm (command pwr hi) 4. Configure transmitter to lowest frequency (command tx 217) 5. Key the transmitter (command key) 6. Record the results for Conducted TX 217MHz. 7. Analyze the results to ensure that no new conducted spurious emissions exist, and that no existing spurious emissions are greater than the values obtained in the modular test reports. 8. Repeat steps 3, 4, 5, 6 at the highest frequency (command tx 222) Page 16 of 16

GE MDS MCR JOB : 1234567 POWER : 10 60V MAX 4.5A MAX OPERATING TEMP : - 40 to + 70 C TEMP CODE: T3 CONFIG : MXNCL4CN4GYNNS1FINUNE GE MDS LLC 175 SCIENCE PARKWAY ROCHESTER NY, 14620 USA Cell IMEI: 990000947608736 CONTAINS:

RCL220 E5MDS-RCL220 101D-RCL220 SN# 9999999 MAC 00:06:3D:08:3D:9C This device complies with Part 15 of the FCC rules. 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. IP Address = 192.168.1.1 DEFAULTS: Username = admin Password = admin This Telemetering equipment is approved for Class 1, Division 2, Groups ABCD hazardous locations.

GE Renewable Energy GE MDS LLC 175 Science Parkway, Rochester, New York 14620 USA

(585) 242-9600 Phone

(585) 242-9620 Fax Agent Authorization Company: GE MDS LLC Address: 175 Science Parkway, Rochester NY 14620 USA Product Name: Orbit MCR Model Number(s): RCL220 Product Description:

220MHz Data Transceiver Module for use in the GE MDS Orbit platform. We authorize MiCOM Labs Inc., 575 Boulder Court, Pleasanton, California 94566, USA, to act on our behalf on all matters concerning the certification of above named equipment. We declare that MiCOM Labs Inc. is allowed to forward all information related to the approval and certification of equipment to the regulatory agencies as required and to discuss any issues concerning the approval application. Any and all acts carried out by MiCOM Labs on our behalf shall have the same effect as acts of our own. Best regards, John Barenys Operations Manager GE MDS LLC 175 Science Parkway Rochester, NY 14620

(585) 683-4254 john.barenys@ge.com

GE Renewable Energy GE MDS LLC 175 Science Parkway, Rochester, New York 14620 USA

(585) 242-9600 Phone

(585) 242-9620 Fax Section 2.911(d)(5)(ii) Certification Applicant (Covered List) Company name: GE MDS LLC Address:175 Science Parkway, Rochester, NY 14620 USA Product Name: Orbit MCR FCC ID: E5MDS-RCL220 Model(s):RCL220 2.911(d)(5)(ii) Applicant filing We, GE MDS, LLC (the applicant) certify that, as of the date of the filing of the application, the applicant is is not identified NOTE 1 on the Covered List NOTE 2, established pursuant to 1.50002 of this chapter, as an entity producing covered communications equipment. Yours sincerely, Name:

Jon Vilagy Date:

6/28/2023 Title and Company name: TRS Engineer, GE MDS LLC NOTE 1 Delete option not applicable to this application. NOTE 2 Covered List; is the List of Equipment and Services Covered By Section 2 of The Secure Networks Act, available at https://www.fcc.gov/supplychain/coveredlist References;

1) 986446 D01 Covered Equipment v01 https://apps.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?switch=P&id=325672 2) Federal Register document 2022-28263 published on 02/06/23 https://www.federalregister.gov/documents/2023/02/06/2022-28263/protecting-against-national-security-

threats-to-the-communications-supply-chain-through-the

GE Renewable Energy GE MDS LLC 175 Science Parkway, Rochester, New York 14620 USA

(585) 242-9600 Phone

(585) 242-9620 Fax Section 2.911(d)(5)(i) Certification Equipment Type Company name: GE MDS LLC Address:175 Science Parkway, Rochester, NY 14620 USA Product Name: Orbit MCR FCC ID: E5MDS-RCL220 Model(s):RCL220 2.911(d)(5)(i) Equipment Type We, GE MDS, LLC (the applicant) certify that the equipment for which authorization is sought through certification is not:

Prohibited from receiving an equipment authorization pursuant to 2.903; of the FCC rules. Identified as an equipment type in the Covered List NOTE 1 Yours sincerely, Name:

Jon Vilagy Date:

6/28/2023 Title and Company name: TRS Engineer, GE MDS LLC NOTE 1 Covered List; is the List of Equipment and Services Covered By Section 2 of The Secure Networks Act, available at https://www.fcc.gov/supplychain/coveredlist References;

1) 986446 D01 Covered Equipment v01 https://apps.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?switch=P&id=325672 2) Federal Register document 2022-28263 published on 02/06/23 https://www.federalregister.gov/documents/2023/02/06/2022-28263/protecting-against-national-security-

threats-to-the-communications-supply-chain-through-the

GE Renewable Energy GE MDS LLC 175 Science Parkway, Rochester, New York 14620 USA

(585) 242-9600 Phone

(585) 242-9620 Fax Office of Engineering Technology Federal Communications Commission 7435 Oakland Mills Road Columbia, MD 21046 USA Date: 6/28/2023 Subject; Request for Confidentiality FCC ID: E5MDS-RCL220 To Whom It May Concern, Pursuant to the provisions of the Commissions rules Title 47 Sections 0.457 and 0.459, we are requesting the Commission to withhold the following attachment(s) as confidential documents from public disclosure indefinitely. These documents contain detailed system and equipment descriptions and are considered as proprietary information in operation of the equipment. The public disclosure of these documents might be harmful to our company and would give competitors an unfair advantage in the market. Schematic Diagram Block Diagram Parts List Operational Description Tune-up Procedure In additional to above mentioned documents, in order to comply with the marketing regulations in Title 47 CFR 2.803 and the importation rules in Title 47 CFR 2.1204, while ensuring that business sensitive information remains confidential until the actual marketing of newly authorized devices, we request Short Term Confidentiality of the following attachment(s);

External Photos Test Setup Photos Internal Photos User Manual For 45 days, pursuant to Public Notice DA 04-1705. OR For 180 days pursuant to KDB 726920 D01. It is our understanding that all measurement test reports, FCC ID label format and correspondence during the certification review process cannot be granted as confidential documents and this information will be available for public review once the grant of equipment authorization is issued. Best regards, John Barenys Operations Manager GE MDS LLC 175 Science Parkway Rochester, NY 14620

(585) 683-4254 john.barenys@ge.com

Federal Communications Commission Equipment Authorization Division 7435 Oakland Mills Road Columbia, MD 21046 USA Date: 11/08/2023 Subject; Modular Transmitter Application Company name: GE MDS, LLC FCC ID: E5MDS-RCL220 Dear Sir/Madam, This letter includes the FCC application requirements for Modular Transmitter Approval Request for;-

FCC KDB 996369 D01 Module Certification Guide v02; and FCC KDB 996369 D03 OEM Manual v01 In accordance with 47CFR 15.212 Modular Transmitters and KDB 996369 D01 Module Equip Auth Guide v02. FCC ID E5MDS-RCL220 has been examined against the following requirements. Requirement per 15.212 and KDB 996369 D01 The radio elements must have the radio frequency circuitry shielded. Physical components and tuning capacitor(s) may be located external to the shield, but must be on the module assembly. The module must have buffered modulation/data inputs to ensure that the device will comply with Part 15 requirements with any type of input signal. The module must contain power supply regulation on the module. The module must contain a permanently attached antenna, or contain a unique antenna connector, and be marketed and operated only with specific antenna(s), per 15.203, 15.204(b), 15.204(c), 15.212(a), 2.929(b). The module must demonstrate compliance in a stand-alone configuration. Explanation from Grantee

(do not write yes/no, but explain why product complies/how it is achieved) The RCL220 Radio Module includes integrated shielding for the RF section This module conforms to all applicable Part 15 and Part 90 requirements without needing to be installed inside of the host. The RCL220 uses RF System on Chip for input config and control. This IC features automatic receiver gain control, transmitter power control, and programmable GPIO to disable the transmitter and command the Tx/Rx RF switch when the unit is in receive. The GE MDS Orbit MCR provides a fixed 5.25V power source and data interfaces through the card edge connector to enable module operation. Page 12 of the manual has an approved antenna matrix. The module was not tested in stand-alone configuration it was tested in the GE MDS Orbit MCR Host. FCC Modular Approval Request Rev 3.0 The module must be labeled with its permanently affixed FCC ID label, or use an electronic display (see KDB Publication 784748). The module must comply with all specific rules applicable to the transmitter, including all the conditions provided in the integration instructions by the grantee. The module must comply with RF exposure requirements See page 13 of OCR manual. It shall be permanently affixed. Page 12 of the manual outlines the specific rules. The radio equipment described in this operation emits radio frequency energy. The concentrated energy from a directional antenna may pose a health hazard. Persons may not come closer than 44 centimeters to the front of the antenna when the transmitter is operating with a 2.0dBi antenna. Integration Instructions for host product manufacturers The following items are submitted in support of application for Modular Transmitter FCC ID as noted above as required by the FCC KDB 996369 D03 OEM Manual v01. These items are provided as integration instructions for host product manufacturers (e.g., OEM instruction manual) to use when integrating a module in a host product. Any requirements that are not applicable to the Module are as indicated below. Requirements of KDB 996369 D03 KDB Ref Sect 2.2 2.3 2.4 2.5 2.6 2.7 2.8 2.9 Summary of requirements and Checklist. Refer to the KDB for description of the complete requirements;

User Manual Page Number reference 11 11 11 11 11 11 12 12 List of applicable FCC rules Summarize the specific operational use conditions Limited module procedures Trace antenna designs RF exposure considerations Antennas Label and compliance information Information on test modes and additional testing requirements Additional testing, Part 15 Subpart B disclaimer 2.10 12 Name:

John Barenys Date: 11/08/2023 Title:

Senior Operations Manager Signature of applicant FCC Modular Approval Request Rev 3.0

GE Renewable Energy GE MDS LLC 175 Science Parkway, Rochester, New York 14620 USA

(585) 242-9600 Phone

(585) 242-9620 Fax TO: FEDERAL COMMUNICATIONS COMMISSION 7435 Oakland Mills Road Columbia, MD 21046 U.S.A. Re: section 2.911(d)(7) filing To whom it may concern, This letter is to confirm that Jonathan Vilagy, Senior Technical Regulations and Standards Engineer of GE MDS, LLC has accepted responsibility to act as the agent for service of process as acknowledged by the applicant, GE MDS, LLC. U.S. Agent: Jonathan Vilagy Title: Senior Technical Regulations and Standards Engineer Company Name: GE MDS, LLC Address: 175 Science Parkway, Rochester, NY 14620 Telephone No:

(585) 241-5516 Email:

jonathan.vilagy@ge.com The applicant accepts and acknowledges the obligation to maintain an agent for no less than one year after the grantee has terminated all marketing and importation or the conclusion of any Commission-related proceeding involving the equipment. Signature of Applicant:

Signature of U.S. Agent (if different from applicant):

Name: Jonathan Vilagy Date: 28-JUNE-2023 Name:

Date: