FCC ID: SDL-PS85R01 Ultra-Wideband Wallscanner

SILT SILT Li-lon Eiri SILT Cal PS 85 (01) 2014/53/EU EN 61010-1:2010 EN 50665:2017 Dr. Tahar Zrilli Head of Quality and Process Management Business Area Electric Tools & Accessories Hilti Corporation FeldkircherstraBe 100 9494 Schaan | Liechtenstein EN 301489-33 V2.2.1 EN 302065-4 V1.1.1 EN 300330 V2.1.1 Schaan, 04.03.2021

\ (ee Thomas Hillbrand Head of BU Measuring Systems Business Unit Measuring Systems SILT SILT SILT SILT OO SILT

(Com (ig B 12/2.6 (01) 2.5 Ah 0,24 kg 0.53 Ib C 4/12-50 B 12/4.0 (01) 4.0 Ah 0,35 kg 0.77 Ib SILT SILT SILT SILT SILT SILT SILT Brick / Universal, 6cm. SILT Concrete, 20cm 5 60 65 60 65 6 80 85 90 SILT Horizontal Coring Brick 5 10 15 20248em)30 35 40

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: ) SILT SILT SILT SILT

| ae | Declaration of Conformity (DOC) China RoHS II Proposal corded power tool Hazardous Substances Poly- Poly-

Hexavalent brominated brominated Part Name Cadmium (Cd)}_ Chromium Ronen diohenvieeth

(Cr(V1)) iphenyls iphenyl-ethers

(PBDE) Electronics (PCB, switch, wiring) Motor Power cord Fastener elements Metal parts Power supplies Brass parts Aluminium parts Battery Battery charger O: Indicates that said hazardous substance contained in all of the homogeneous materials for this part is below the limit requirement of GB/T 26572 X: Indicates that said hazardous substance contained in at least one of the homogenous matrials used for this part is above the limit requirement of GB/T 26572 but corresponds to the exemption SILT SILT SILT Hilti Corporation LI-9494 Schaan Tel.:+423 234 21 11 Fax:+423 234 29 65 www.hilti.group

PS 85 English PS 85 Original operating instructions Original operating instructions 1 Information about the operating instructions 1.1 About these operating instructions Before use, read through and familiarize yourself with this document and the detailed operating instructions. This is a prerequisite for safe, trouble-free handling and use of the product. To access the detailed operating instructions and obtain more informa-

tion on operation, technology, environment and recycling, follow this link: qr.hilti.com/manual/?id=2327817 Observe the safety instructions and warnings in this documentation, in the detailed operating instructions and on the product. Always keep the operating instructions with the product and make sure that the operating instructions are with the product when it is given to other persons. 1.2 Declaration of conformity Hilti hereby declares that the radio equipment type PS 85 is compliant with Directive 2014/53/EU. The complete text of the EU declaration of conformity has been posted on the Internet here: qr.hilti.com/manual/?id=2327817 2 Safety 2.1 General safety instructions, measuring tools WARNING! Read all safety precautions and other instructions. Measuring tools can present hazards if handled incorrectly. Failure to observe the safety instructions and other instructions can result in damage to the measuring tool and/or serious injury. Keep all safety precautions and instructions for future reference. Work area safety Keep your workplace clean and well lit. Cluttered or poorly lit workplaces invite accidents. Do not operate the product in explosive atmospheres, such as in the presence of flammable liquids, gases or dust. Keep children and other persons clear when the product is in use. Use the product only within its specified limits. Comply with your national accident prevention regulations. Electrical safety Do not expose the product to rain or moisture. Penetrating moisture can cause short circuits, electrical shock, burns or explosions. Wipe the product dry before stowing it in the transport container. English 1 Personal safety Stay alert, watch what you are doing and use common sense when operating a measuring tool. Do not use a measuring tool while you are tired or under the influence of drugs, alcohol or medication. A moment of inattention while operating the measuring tool can result in serious personal injury. Avoid unusual body positions. Keep proper footing and balance at all times. Wear personal protective equipment. Wearing personal protective equipment reduces the risk of injury. Do not render safety devices ineffective and do not remove infor-

mation and warning notices. Avoid accidental starting. Make sure that the measuring tool is switched off before connecting it to the battery and before picking it up or carrying it. Use the product and accessories in accordance with these instruc-

tions and in the way specified for this special type of tool. Take the working conditions and the work to be performed into account. Use of products for applications different from those intended could result in hazardous situations. Do not lull yourself into a false sense of security and do not flout the safety rules for measuring tools, even if you are familiar with the measuring tool after using it many times. Carelessness can result in serious injury within a fraction of a second. Do not use the measuring tool in the vicinity of medical devices. Using and handling the measuring tool Use the product and accessories only when they are in perfect working order. Store measuring tools out of reach of children when not in use. Do not allow persons who are not familiar with the product or these instructions to operate it. Measuring tools are dangerous in the hands of inexperienced persons. Measuring tools need care and attention. Check that moving parts operate satisfactorily and do not jam, and make sure that no parts are broken or damaged in such a way that the measuring tool might no longer function correctly. Have damaged parts repaired before using the measuring tool. Many accidents are caused by poorly maintained measuring tools. Do not under any circumstances modify or tamper with the product. Changes or modifications not expressly approved by Hilti may restrict the users authorization to operate the product. Check the accuracy of the measuring tool before using it for important measurements, and if it has been dropped or subjected to other mechanical stresses. 2 English Due to the measuring principle employed, the results of measure-

ments can be negatively affected by certain ambient conditions. These include, the proximity of devices that produce strong magnetic or electro-magnetic fields, vibrations and temperature changes. for example, Rapidly changing measuring conditions can falsify the results. When the product is brought into a warm environment from very cold conditions, or vice-versa, allow it to become acclimatized before use. Big differences in temperature can lead to incorrect operation and incorrect results. When adapters or accessories are used, make sure they are mounted securely. The measuring tool is designed for the tough conditions of jobsite use, but as with other optical and electrical products (e.g. binoculars, spectacles, cameras) it must be handled with care. The specified operating and storage temperatures must be ob-

served. 2.2 Additional safety instructions Personal safety Keep the measuring tool well away from all implants. Comply with the national accident prevention regulations. Do not use the measuring tool to examine humans or animals. Operation of the device in the proximity of expectant mothers or persons with a cardiac pacemaker is not permissible. Electrical safety Remove the battery prior to storage. Using and handling the measuring tool Prior to use, always check the measuring tool's presettings and the settings you have made yourself. After switching on and while using the product, always pay attention to the information and warnings that appear on the display. Keep the underside of the scanner and the wheels clean as these parts can have an influence on measuring accuracy. Do not affix stickers or adhesive labels to the sensor area at the back of the measuring tool. Metal plates / labels, in particular, will affect measuring results. While measuring is in progress, always keep all 4 wheels in contact with the surface being scanned. Do not pass over steps or edges. While scanning is in progress, to avoid influencing the scan hold the measuring tool only by the grip provided for the purpose. English 3 While scanning is in progress, do not wear gloves and ensure an adequate earth/ground connection. An inadequate earth/ground connection can impair material detection (including detection of electrically live lines). Always move the measuring tool back and forth with a perfectly steady action. Do not drill at positions where the measuring tool has detected the presence of an object. Take the diameter of the drill bit into account and always allow an adequate safety factor. Do not use the measuring tool to detect critical objects such as load-

bearing structural elements, high-tension lines, gas or steam lines, high-pressure lines and similar objects. Never rely on the measuring tool alone. Verify the results of measure-

ments by cross-checking with other sources of information and by taking control measurements and, if necessary, by drilling pilot holes. Make sure that the wrist strap is securely attached. Prior to each use, always check the attachment point of the wrist strap for possible damage. Risk of injury by falling tools and/or accessories. Use only the wrist strap supplied. Carry the measuring tool only by the grip provided for the purpose. Keep the grip clean, dry and free from oil and grease. Keep the display clean and easily readable. Wipe the display only with a clean, non-scratch cloth. Due to the measuring principle employed, the results of measurements can be negatively affected by certain ambient conditions. These include, e.g. proximity to devices that generate powerful magnetic or elec-

tromagnetic fields, dampness, construction materials containing metal, aluminum foil-backed insulation, multiple layers, materials with cavities or electrically conductive wall coverings or tiles. Accordingly, other sources of information (e.g. plans of the building) should also be con-

sulted before beginning drilling, sawing or grinding in the area scanned. When scanning is in progress, avoid the vicinity of devices (such as cellphones, for example) that emit strong electric, magnetic or electro-

magnetic fields. On all devices capable of producing emissions that can impair measurement, deactivate the relevant functions if possible, or switch the devices off. Do not operate the measuring tool in the vicinity of military installations, airports, radio astronomy facilities or in aircraft unless prior permission has been obtained. Check the accuracy of the measuring tool if it has been dropped or subjected to other mechanical stresses. If the measuring tool is damaged, have it repaired by a Hilti service center. The specified operating and storage temperatures must be observed. 4 English 2.3 Careful handling and use of batteries Comply with the following safety instructions for the safe handling and use of Li-ion batteries. Failure to comply can lead to skin irritation, severe corrosive injury, chemical burns, fire and/or explosion. Use only batteries that are in perfect working order. Treat batteries with care in order to avoid damage and prevent leakage of fluids that are extremely harmful to health!

Do not under any circumstances modify or tamper with batteries!

Do not disassemble, crush or incinerate batteries and do not subject them to temperatures over 80 C (176 F). Never use or charge a battery that has suffered an impact or been damaged in any other way. Check your batteries regularly for signs of damage. Never use recycled or repaired batteries. Never use the battery or a battery-operated power tool as a striking tool. Never expose batteries to the direct rays of the sun, elevated tempera-

ture, sparking, or open flame. This can lead to explosions. Do not touch the battery poles with your fingers, tools, jewelry, or other electrically conductive objects. This can damage the battery and also cause material damage and personal injury. Keep batteries away from rain, moisture and liquids. Penetrating moisture can cause short circuits, electric shock, burns, fire and explosions. Use only chargers and power tools approved for the specific battery type. Read and follow the relevant operating instructions. Do not use or store the battery in explosive environments. If the battery is too hot to touch, it may be defective. Put the battery in a place where it is clearly visible and where there is no risk of fire, at an adequate distance from flammable materials. Allow the battery to cool down. If it is still too hot to touch after an hour, the battery is faulty. Consult Hilti Service or read the document entitled "Instructions on safety and use for Hilti Li-ion batteries". Observe the special guidelines applicable to the transport, storage and use of lithium-ion batteries. Read the instructions on safety and use of Hilti Li-ion batteries that you can access by scanning the QR code at the end of these operating instructions. 2.4 Careful handling and use of button-cell batteries Never swallow button-cell batteries. Severe internal caustic burns or death can result within 2 hours of swallowing a button-cell battery. Make sure that button-cell batteries are inaccessible to children. Consult a physician immediately if there is any suspicion that a button-

cell battery has been swallowed or inserted into a body orifice. English 5 When replacing batteries, make sure that the correct procedure is followed. There is a risk of explosion. Do not attempt to recharge button-cell batteries and do not short-

circuit button-cell batteries. The button-cell battery can develop a leak, explode, catch fire and injure persons. Remove and dispose of discharged button-cell batteries correctly. Discharged button-cell batteries can develop leaks and so damage the product or injure persons. Do not damage button-cell batteries and do not attempt to take button-cell batteries apart. The button-cell battery can develop a leak, explode, catch fire and injure persons. Do not bring a damaged button-cell battery into contact with water. In the presence of water, escaping lithium can produce hydrogen and so lead to a fire or an explosion, or cause injury to persons. 3 Technical data 1.8 GHz 5.7 GHz 0.00001 mW Frequency, radar sensor Maximum transmitting power, radar sensor Frequency, inductive sensor 48 kHz 52 kHz Maximum magnetic field strength (at 10 m) 20 dBA/m 4 Switching measuring tool on/off Before switching on the measuring tool, check that the sensor area is not damp. If necessary, wipe the measuring tool dry with a cloth. 1. To switch the measuring tool on, press the on/off button or the start/stop button. Outside the operating temperature range, a fault message is dis-

played and the measuring tool automatically switches off. Allow the measuring tool to cool down or warm up, as appropriate, and then switch it on again. The tool automatically switches itself off completely if it is not used for 5 minutes. You can change this preset delay before automatic deactivation in the main menu. 2. To switch the measuring tool off, press the on/off button. 6 English 5 FCC statement (applicable in US) / IC statement (applica-

ble in Canada) This equipment has been tested and found to comply with the limits for a class B digital device, pursuant to part 15 of the FCC rules. These limits are designed to provide reasonable protection against harmful interference in a residential installation. This equipment generates, uses, and can radiate radio frequency energy and, if not installed and used in accordance with the instructions, may cause interference to radio communications. However, there is no guarantee that interference will not occur in a particular installation. If this equipment does cause harmful interference to radio or television reception, which can be determined by turning the equipment off and on, the user is encouraged to try to correct the interference by taking the following measures:

Re-orient or relocate the receiving antenna. Connect the equipment to a power outlet on a circuit different from that Increase the separation between the equipment and receiver. to which the receiver is connected. Consult the dealer or an experienced TV/radio technician for assistance. Changes or modifications not expressly approved by Hilti may restrict the users authorization to operate the equipment. This device complies with the requirements set out in Paragraph 15 of the FCC rules and fulfills the requirements defined in RSS220 in combination with the RSS-Gen of IC. Operation is subject to the following two conditions:

This device shall cause no harmful interference. This device must accept any interference received, including interference that may cause undesired operation. For users in the USA: Operation of this device is restricted to law enforce-

ment, fire and rescue officials, scientific research institutes, commercial mining companies, construction companies and private parties operating on behalf of these groups. Operation by any other party is a violation of 47 U.S.C. 301 and can result in serious legal penalties. Coordination requirements 1. UWB imaging systems require coordination through the FCC before the equipment may be used. The operator shall comply with any constraints on equipment usage resulting from this coordination. 2. The users of UWB imaging devices shall supply operational areas to the FCC Office of Engineering and Technology, which shall coordinate this information with the Federal Government through the National Telecom-

munications and Information Administration. The information provided by the UWB operator shall include the name, address and other pertinent contact information of the user, the desired geographical area(s) of opera-

English 7 tion, and the FCC ID number and other nomenclature of the UWB device. If the imaging device is intended to be used for mobile applications, the geographical area(s) of operation may be the state(s) or county(ies) in which the equipment will be operated. The operator of an imaging system used for fixed operation shall supply a specific geographical location or the address at which the equipment will be operated. This material shall be submitted to Frequency Coordination Branch, OET, Federal Commu-

nications Commission, at the address of the FCC's main office indicated in 47 CFR 0.401(a), ATTN: UWB Coordination. 3. The manufacturers, or their authorized sales agents, must inform pur-

chasers and users of their systems of the requirement to undertake detailed coordination of operational areas with the FCC prior to the equip-

ment being operated. 4. Users of authorized, coordinated UWB systems may transfer them to other qualified users and to different locations upon coordination of change of ownership or location to the FCC and coordination with existing authorized operations. 5. The FCC/NTIA coordination report shall identify those geographical areas within which the operation of an imaging system requires additional coordination or within which the operation of an imaging system is prohibited. If additional coordination is required for operation within specific geographical areas, a local coordination contact will be provided. Except for operation within these designated areas, once the information requested on the UWB imaging system is submitted to the FCC no additional coordination with the FCC is required provided the reported areas of operation do not change. If the area of operation changes, updated information shall be submitted to the FCC following the procedure in paragraph 2) of this section. 6. The coordination of routine UWB operations shall not take longer than 15 business days from the receipt of the coordination request by NTIA. Special temporary operations may be handled with an expedited turn-

around time when circumstances warrant. The operation of UWB systems in emergency situations involving the safety of life or property may occur without coordination provided a notification procedure, similar to that contained in 2.405(a) through (e) of this chapter, is followed by the UWB equipment user. Responsible party Hilti, Inc. 7250 Dallas Parkway, Suite 1000 US-Plano, TX 75024 www.hilti.com For users in Canada: This radar imaging device shall be operated only where directed toward the floor or wall, and where it is in contact with or at a distance of 20 cm from the floor or wall surface. This radar imaging device 8 English shall be operated only by law enforcement agencies, scientific research institutes, commercial mining companies, construction companies, and emergency rescue or fire-fighting organizations. English 9 10 English English 11 Hilti = registered trademark of Hilti Corp., Schaan 20221222

Sticker artwork For professional use only.:

This sticker is placed twice at prominent locations of the outer packaging as follows:

U.S. Agent Designation for Service of Process

(Applicant and U.S. Agent are Separate Parties) TO: American Certification Body, Inc. 313 Park Avenue Suite 300 Falls Church, VA 22046 ATTENTION: FCC Certification Section 2.911(d)(7) Information Designated U.S. Agent Company Name: CT Corporation System Contact Name: Brett Bagwell Street Address: 1999 Bryan St., Suite 900, City/Province/Zip: Dallas, TX 75201-3136 Telephone No: 214-979-1172 This letter is to confirm that we (the Designated U.S. Agent) have accepted the responsibility to act as the Designated U.S. Agent for Service of Process as required by section 47 CFR 2.911(d)(7) on behalf of the Applicant noted below. U.S. Agent Signature: C T Corporation System Date:2/24/2023 Signed by (Printed Name/Title): Sherry McGinnes /Assistant Secretary y (

g

) The Applicant acknowledges that they must maintain an agent for no less than one year after terminating all marketing and importation OR the conclusion of any Commission-related proceeding involving the equipment. The applicant further acknowledges their responsibility to inform the FCC whenever the Designated U.S. Agent information above changes. Applicant Company name:

Grantee Code:

Contact Name:

Street Address:

City/Province/Zip:

Telephone No:

Email:

FRN #:

Hilti, Inc. SDL Michael Hoffmann 7250 Dallas Parkway, Suite 1000 Plano, TX 75024 469-863-9711 michael.hoffmann@hilti.com 005175575 0005175575 Applicant Signature:

Date:

03/13/2023 Signed by (Printed Name/Title): Michael Hoffmann Vice President Product Safety and Liability Hilti, Inc. 7250 Dallas Parkway, Suite 1000 Plano, Texas 75024 800-879-8000 www.hilti.com

Federal Communications Commission 7435 Oakland Mills Road Columbia MD 21046 United States of America Subject: Request for Confidentiality FCC ID: SDL-PS85R01 To Whom it May Concern, Kaufering, Dec. 5, 2022 Pursuant to the provisions of Sections 0.457 and 0.459 of the Commissions rules (47 CFR 0.457, 0.459), we are requesting the Commission to withhold the following attachments as confidential from public disclosure indefinitely. Schematic diagram Block diagram Parts List / BOM Theory of Operation Above mentioned documents contain detailed system and equipment descriptions that are considered as proprietary information in operation of the equipment. The public disclosure of above documents might be harmful to our company and would give competitor an unfair advantage in the market. It is our understanding that all measurement test reports, FCC ID label format and correspondent during certification review process cannot be granted as confidential documents and that information will be available for public review once the grant of equipment authorization is issued. Yours sincerely ppa. Dr. Ute Dawin Head of Tool Certification Hilti Entwicklungsgesellschaft mbH Hiltistrasse 6 86916 Kaufering / Germany ppa. Dr. Dieter Profunser Head of Development PT&A Hilti Entwicklungsgesellschaft mbH Hiltistrasse 6 86916 Kaufering / Germany Hilti Corporation Feldkircherstrasse 100 | P.O. Box 333 9494 Schaan | Liechtenstein P +423-234 2111 | F +423-234 3332 | www.hilti.group Legal Form: Stock Corporation | Registered Office: 9494 Schaan Commercial Register Nr.: FL-1.011.557-0 | VAT-Nr.: 50 555

Certification Application Attestation Statements American Certification Body, Inc. 313 Park Avenue Suite 300 Falls Church, VA 22046 To Whom It May Concern:

Date: February 27, 2023 Statement for 47 CFR section 2.911(d)(5)(i) Hilti Corporation certifies that as of the date of the application the equipment for which authorization is sought is not covered equipment1 prohibited from receiving an equipment authorization pursuant to section 2.903 of the FCC rules. If the equipment for which the applicant seeks authorization is produced by any of the entities identified on the current Covered List, including affiliates or subsidiaries of the named companies, the applicant must include an explanation on why the equipment is not covered equipment. Additional Explanation: <N/A>

Statement for 47 CFR section 2.911(d)(5)(ii) Hilti Corporation (the applicant) certifies that, as of the date of the filing of this application, the applicant is not identified on the Covered List as an entity producing covered equipment. Thank you, Signed:

Printed:

Title:

Company Name:

Address:

ppa. Dr. Ute Dawin Head of Tool Certification Hilti Entwicklungsgesellschaft mbH Hiltistrasse 6, 86916 Kaufering Germany ppa. Dr. Dieter Profunser Head of Development PT&A Hilti Entwicklungsgesellschaft mbH Hiltistrasse 6, 86916 Kaufering Germany Phone:

+49 8191 90 3803

+49 8191 90 3525 1 - The Commissions Covered List is published by the Public Safety and Homeland Security Bureau and posted on the Commissions website. This Covered List, which is periodically updated, identifies particular equipment, produced by particular entities, that constitutes covered equipment. https://www.fcc.gov/supplychain/coveredlist . 012423-17 rev2

Federal Communications Commission DA 22-8 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Robert Bosch LLC ET Docket No. 20-268 Request for Waiver of Sections 15.503(d), 15.503(h), and 15.521(d) of the Commissions Rules

) ORDER Adopted: January 4, 2022 Released: January 4, 2022 By the Acting Chief, Office of Engineering and Technology:

I. INTRODUCTION 1. By this Order, we grant a request by Robert Bosch LLC (Bosch), for a waiver of our rules governing unlicensed ultra-wideband (UWB) devices to permit the certification and marketing of the newest version of its UWB wall imaging system. We find that opening a path for the sale and operation of this next generation equipment will allow Bosch to deploy its system to enhance the through-wall imaging capabilities for construction professionals, in furtherance of the public interest; and that operation of this device under the specified waiver conditions poses no greater risk of causing harmful interference to communication services than those devices already permitted under the existing rules. II. BACKGROUND 2. On April 13, 2020, Robert Bosch LLC (Bosch) filed a request for waiver of the Commissions Part 15 ultra-wideband (UWB) rules to allow the marketing and operations of its frequency hopped UWB wall imaging system, known as the Wallscanner D-tect 200 Professional (D-tect 200).1 Bosch states that the D-tect 200 is a tool for skilled professional deployment in the construction trade, used for detection and inspection of ferrous and non-ferrous metals, electric cables, wooden beams, plastic pipes, and for identification of structural flaws within construction materials. According to the request, the device operates between 1.8 GHz and 5.7 GHz, and hops continuously over the complete operating frequency range from lowest to highest frequency.2 Bosch states that the application and use of the D-tect 200 is precisely the same as its predecessor, the D-tect 150,3 for which we had previously 1 Robert Bosch LLC Request for Waiver of Section 15.503(h) of the Commissions Rules to Permit the Marketing, Sale and Operation of Ultra-Wideband Wall Imaging Device; and Waiver of Section s 15.503 (d) and 15.521(d) of the Commissions Rules Governing Minimum Bandwidth (Bosch waiver request), filed April 13, 2020. 2 See Bosch Comments at 1-2. 3 See Bosch waiver request at 3. Federal Communications Commission DA 22-8 granted a waiver of the definitional requirement in Section 15.503(h) of our rules.4 The D-tect 150 otherwise operates under our existing rules; as Bosch points out, it uses pulse modulation and operates between the frequency range of 2.2 - 5.8 GHz.5 The new device, the D-tect 200, incorporates design revisions including changes in circuitry that would not permit it to be authorized under the existing certification issued for the D-tect 150. 3. Specifically, Bosch seeks a rule waiver to permit it to use a frequency hopping configuration, which is new to the D-tect model design.6 Bosch asks for a waiver of section 15.503(d), which requires that a UWB transmitter at any point in time have a fractional bandwidth equal to or greater than 0.20 or a UWB bandwidth equal to or greater than 500 MHz, regardless of the fractional bandwidth. Bosch also requests a related waiver of section 15.503(h), which lays out the definition for a wall imaging system, and Section 15.521(d), which requires that if pulse gating is employed where the transmitter is quiescent for intervals that are long compared to the nominal pulse repetition interval, measurements shall be made with the pulse train gated on. A waiver of Sections 15.503(d), 15.503(h), and 15.521(d) of the rules is needed so that Bosch can perform measurements to demonstrate compliance with the rules, while the system is operating in its normal transmission mode, and so that Bosch can market the D-tect 200 devices. Finally, Bosch has also committed to no longer manufacturing equipment under its previous waiver should its instant request be granted.7 4. On August 20, 2020, the Office of Engineering and Technology (OET) sought comment on Boschs request.5 The Comment cycle ended on October 19, 2020. GPS Innovation Alliance (GPSIA) was the only party aside from Bosch to file comments in the docket. GPSIA does not oppose the grant of the specific waiver request, noting that Bosch does not propose to operate in the Global Navigation Satellite System (GNSS) band of particular interest to GPSIA, and that the definitional issue that Bosch raises is effectively similar to relief we previously granted to Bosch in 2011.8 However, GPSIA expresses general concerns about the Commissions rule waivers affecting UWB devices due to the proximity of some UWB device operations to spectrum used by GNSS receivers. It asks us to exercise great caution in granting waivers and ensure that waiver requests continue to be based on specific and unique circumstances that warrant a discrete waiver of the specific rule.9 For this particular waiver request, it asks us to impose conditions on Bosch to ensure that its device is used for professional use (as opposed to being a general consumer use device).10 Finally, to assist interested parties in evaluating future petitions filed with the Commission, GPSIA states that we should require UWB rule waiver applicants to provide specific technical information at the time they initiate a request for a waiver.11 4 Robert Bosch, GmbH Request for Waiver of Part 15 Ultra-wideband Rule for a Wall Imaging Device, ET Docket No. 10-253, Order, 26 FCC Rcd 7572 (OET 2011) (Bosch 2011 Waiver Order). 5 See Letter from Christopher D. Imlay, Counsel to Robert Bosch, to Chief, Office of Engineering and Technology, FCC, filed in ET Docket 20-268 on July 28, 2021, at 3 (Bosch July 28, 2021 ex parte). 7 See Letter from Scott Delacourt, Counsel to Robert Bosch, to Marlene Dortch, Secretary, FCC, Dec. 29, 2021 (also discussing several conditions that Bosch would be able to meet if they were included in a waiver grant). 6 See Bosch waiver request at 2. 8 GPSIA Comments at 1-2. 9 Id. at 2. 10 Id. at 5-6. 11 Id. at 6. 2 Federal Communications Commission DA 22-8 III. DISCUSSION 5. We are authorized to grant a waiver under Section 1.3 of the Commission's rules if the petitioner demonstrates good cause for such action.12 Good cause, in turn, may be found where particular facts would make strict compliance inconsistent with the public interest.13 To make this public interest determination, the waiver cannot undermine the purpose of the rule, and there must be a stronger public interest benefit in granting the waiver than in applying the rule.14 The UWB standards in Part 15 were adopted to ensure that UWB devices, including wall imaging systems, do not cause harmful interference to authorized radio services, including those operated by the Federal Government.15 As discussed below, we find that, with appropriate operational and technical limitations, granting Boschs request for waiver poses no greater risk of causing harmful interference to radio communications services than any other wall imaging device operating under our rules. In addition, we find that there is a stronger public interest benefit in granting this waiver than in strictly applying the rules. In the waiver order previously granted to the D-tect 150 the Commission found that a waiver of the rules would allow deployment of a product with beneficial applications in building construction, as well as inspection and maintenance of buildings in the United States. That analysis continues to apply because, the D-tect 200 device improves on but otherwise serves the same function as the D-tect 150. The design changes are intended to provide greater resolution and precision in detecting materials through walls which in turn, can enhance safety and increase efficiency for construction professionals. Thus, we find that the waiver standard has sufficiently been met. A. Waiver of the UWB definition in Section 15.503(d) 6. Section 15.503(d) of the Commissions rules defines a UWB transmitter as a device that at any point in time has an UWB bandwidth equal to or greater than 500 megahertz or a fractional bandwidth equal to or greater than 0.20.16 Bosch describes the D-tect 200 as using frequency-hopped emissions.17 The transmitted signal hops continuously over the frequency range from 1.8 GHz and 5.7 GHz. The signal has a bandwidth of less than 1 kHz, an on-time of no less than 50 microseconds, an off-

time of 15 microseconds or less, and 30 discrete hops. It also has the maximum time for each hop sequence of 2.3 milliseconds. Each of these individual transmissions is less than 500 megahertz in bandwidth at any point in time and Boschs device does not have a 0.20 or greater fractional bandwidth. Thus, even though the device operates over a frequency range that exceeds 500 megahertz, it would not meet the definitional requirement for operation under the UWB rules.18 12 47 CFR 1.3. See also ICO Global Communications (Holdings) Limited v. FCC, 428 F.3d 264 (D.C. Cir. 2005);

Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164 (D.C. Cir. 1990); WAIT Radio v. FCC, 418 F.2d 1153

(D.C. Cir. 1969). 13 Northeast Cellular, 897 F.2d at 1166; see also ICO Global Communications, 428 F.3d at 269 (quoting Northeast Cellular); WAIT Radio, 418 F.2d at 1157-59. 14 See, e.g., WAIT Radio, 418 F.2d at 1157 (stating that even though the overall objectives of a general rule have been adjudged to be in the public interest, it is possible that application of the rule to a specific case may not serve the public interest if an applicant's proposal does not undermine the public interest policy served by the rule);

Northeast Cellular, 897 F.2d at 1166 (stating that in granting a waiver, an agency must explain why deviation from the general rule better serves the public interest than would strict adherence to the rule). 15 Revision of Part 15 of the Commission's Rules Regarding Ultra-Wideband Transmission Systems, ET Docket No. 98-153, First Report and Order, 17 FCC Rcd 7435 (2002) (UWB First R&O); see also, 47 CFR 15.501-15.525. 16 47 CFR 15.503(d). 17 See Bosch Comments at 1-2. 18 Stepped frequency, swept frequency, and frequency hopped devices like Boschs D-tect 200 have a difficult time meeting the rules technical specifications because the large bandwidth is achieved by stepping or sweeping a 3

(continued.) Federal Communications Commission DA 22-8 7. The UWB imaging rules were designed to accommodate devices that emit impulsive or transient-like signals that are spread across a very wide bandwidth to produce an image of objects within the ground or other materials.19 The primary difference between the Bosch device and other UWB wall imaging devices provided for in the rules is that the D-tect 200 does not transmit a single impulsive signal but instead transmits sequentially in hops over a large band of spectrum to gather all the needed data. In the past the Commission has determined that frequency agile UWB devices may perform in a manner that is equivalent to non-frequency agile devices.20 For example, in the waivers granted to Curtiss-Wright Controls Inc., Proceq USA Inc., and more recently the Massachusetts Institute of Technology, the Commission recognized that stepped frequency UWB devices were functionally equivalent to other UWB devices and that the risk of interference from the associated devices would be no greater than from other UWB devices.21 Here we find that the D-tect 200 devices is functionally equivalent to other types of UWB wall imaging devices in that it uses transient-like signals spread across a wide bandwidth to detect objects behind concrete and other construction materials. The risk of interference is comparable to that from other such UWB wall imaging, such as the previous iteration of the D-tect 150 device,22 and so a waiver in this case will not undermine the intent of our rule. B. Waiver of the measurement procedures in Sections 15.521(d) and 15.31(c) 8. Section 15.521(d) sets forth the measurement procedures for UWB devices to demonstrate compliance with applicable emissions limits.23 For emissions above 960 MHz, this rule requires that, if pulse gating is used and the transmitter is quiescent for longer intervals than the nominal pulse repetition interval, measurements are made with the pulse train gated on. Bosch asserts that for reasons equally applicable to D-tect 200, the Commission granted a waiver to Curtiss-Wright Controls Inc. of Sections 15.503(d) and 15.521(d) of the Commissions Rules due to the restrictive means of determining the minimum operational bandwidth of a UWB transmitter contained in the rule.24 Bosch claims that the D-

tect 200 will meet all other Subpart F, Part 15 rules and other applicable Part 15 rules, and Bosch will have the device certified as an intentional radiator under applicable parts of the Commissions Rules.25 Additionally, we recognize from Boschs filing that the D-tect 200 will also require a waiver of Section narrow signal through the broader frequency range, and therefore wont be instantaneously wide enough to meet the rules specific requirements. 19 See UWB First R&O, 17 FCC Rcd at 7437-7440, 7450, 7476 and 7494. 20 See Petition for Waiver of the Part 15 UWB Regulations Filed by the Multi-band OFDM Alliance Special Interest Group, ET Docket No. 04-352, Order, 20 FCC Rcd 5528 (2005) (MBOA-SIG Waiver), as well as Curtiss-Wright Controls Inc. Request for Waiver of Part 15 of the Commissions Rules Applicable to Ultra-Wideband Devices, ET Docket No. 10-167, Order, 27 FCC Rcd 234, (OET 2012) (CWCI Waiver) and Kyma Medical Technologies Ltd.,, Request for Waiver of Part 15 of the Commissions Rules Applicable to Ultra-Wideband Devices, ET Docket No. 15-119, Order, 31 FCC Rcd 9705 (OET 2016) (Kyma Waiver), Proceq USA Inc. Request for Waiver of Part 15 of the Commissions Rules Applicable to Ultra-Wideband Devices , DA -18-251, Order, 33 FCC Rcd 2258, (OET 2018) (Proceq Waiver), Massachusetts Institute of Technology Request for Waiver of Part 15 of the Commissions Rules Applicable to Ultra-Wideband Devices, ET Docket No. 19-89, Order, 35 FCC Rcd 4389 (2020) (MIT Waiver). 21 See CWCI Waiver, See also Proceq Waiver and MIT Waiver. 22 See Bosch July 28, 2021 ex parte, Exhibit A at slides 6-9. Bosch demonstrates that the both the D-tect 150 and the D-tect 200 have comparable transmit EIRP characteristics. Bosch also shows that both devices will comply with the regulated emissions limits. 24 See Bosch Waiver Request at 7-9 (citing waiver requests by Curtiss-Wright Controls, and Bosch D-tect 150). 23 47 CFR 15.521(d). 25 Id. at 21. 4 Federal Communications Commission DA 22-8 15.31(c)26 of the Commissions rules which sets forth the measurement standards for unlicensed devices to demonstrate compliance with applicable emission limits. This rule requires that measurement of swept frequency equipment shall be made with the frequency sweep stopped and this requirement has been traditionally interpreted to also be applicable to stepped, hopped, and other frequency diverse modulations schemes. However, application of the requirement to stop the frequency hop when performing compliance measurements would result in a fundamental emission bandwidth measurement that will not comply with the UWB bandwidth requirements. 9. We recognized in prior orders granting waivers of the measurement procedures for UWB transmitters, where emissions were permitted to be measured with the transmitter operating in its normal transmission mode, that the interference aspects of a transmitter employing frequency hopping, frequency stepping, or gating are quite similar, as viewed by a receiver.27 That is because transmitters using these burst formats appear to the receiver to emit for a short period of time followed by a quiet period.28 We concluded that any requirement to stop the frequency hopping, band sequencing, or system gating serves only to add another unnecessary level of conservatism to already stringent UWB standards.29 In conjunction with NTIA, we have further determined that allowing stepped frequency devices to be measured with the stepping function on would not increase the interference potential of the device above that of impulse UWB devices if all other emission limits and technical requirements are met.30 10. Boschs request represents an analogous situation. Because a waiver of the measurement procedures in Sections 15.31(c) and 15.521(d) will not increase the potential for harmful interference to authorized services, permitting Bosch to demonstrate compliance with the UWB emission limits with the stepping function active will not undermine the purpose of the rule.31 To ensure that the D-tect 200 device does not emit in any individual 1 megahertz or narrow band continuously, we include a duty cycle in our waiver conditions.32 In sum, we find that permitting Bosch to demonstrate compliance with the UWB wall imaging system emission limits under a waiver of the measurement procedures under the conditions specified below poses no greater risk of causing harmful interference to radio communications services than any other UWB wall imaging system operating under our rules, and therefore will not undermine the purpose of these rules. C. Waiver of the UWB definition in Section 15.503(h) 11. Section 15.503 (h) of the Commissions rules defines a wall imaging system as: A field disturbance sensor that is designed to detect the location of objects contained within a wall or to determine the physical properties within the wall. The wall is a concrete structure, the side of a bridge, the wall of a mine or another physical structure that is dense enough and thick enough to absorb the majority of the signal transmitted by the imaging system. This category of equipment does not include products such as stud locators that are designed to locate objects behind gypsum, plaster or similar walls that are not capable of absorbing the transmitted signal.33 According to Bosch, the D-tect-

200 is not entirely consistent with this definition as it will not always be the case that the scanned 27 See, e.g., MBOA-SIG Waiver, Kyma Waiver and, Proceq Waiver, MIT Waiver. 26 47 C.F.R. 15.31(c). 28 See, e.g., CWCI Waiver. 29 Id. 30 See Id. See also MBOA-SIG Waiver Order, 20 FCC Rcd at 5531-5536. 31 Our reliance on the MBOA-SIG Waiver and the CWCI Waiver decision in this instance is only relative to the measurement procedure in Section 15.521(d). 32 See infra para. 15, condition 4. 33 47 C.F.R. 15.503(h). 5 Federal Communications Commission DA 22-8 structure will be dense and thick enough to absorb the entirety of the transmitted signal and the device can function as a stud locator.34 12. Boschs predecessor device, the D-tect 150 shared these same characteristics. OET waived Section 15.503(h) for the D-tect 150 concluding that this would not increase the potential for harmful interference to authorized services because the technical and operational provisions of Section 15.509 remain in place to limit harmful interference.35 In granting the waiver, OET also noted that the device would be useful only to those engaged professionally in building and construction which meets the Commissions intention to limit proliferation of UWB imaging devices to coordinated and controlled ranges of applications in order to limit their interference potential. For these same reasons, we conclude that waiver of Section 15.503(h) is warranted for the D-tect 200. According to Bosch, the D-tect 200 will meet the technical requirements of Section 15.509.36 The D-tect 200 is also intended for use by those in the building and construction industry.37 Given that the D-tect 150 has been authorized since 2011 without any reports of harmful interference, we see no reason to reach a different conclusion on waiving Section 15.503(h) for the D-tect 200. While no conditions were associated with the D-tect 150 waiver, we find that generally the D-tect 200 device will have minimum utility by consumers or those not involved in the building and construction trades. However, we do see merit in GPSIAs assertion that this waiver should be conditioned on marketing and operating the D-tect 200 to those engaged professionally in the building and construction trades. We will also include a condition that prohibits the marketing of the D-tect 200 device for retail consumer markets and require analogous labeling statements. These conditions are designed to add an additional level of protection, as Bosch has stated that the application and use of the D-tect 200 is the same its predecessor and we are aware of no complaints that it has been marketed to or subject to popular use by non-professional users. 13. To further ensure that the purpose of the rule is not undermined, we will limit the number of devices that may be deployed under this waiver to six thousand (6000) per year. D. Waiver conditions 14. This Order is narrowly tailored to address the particular facts relevant to the Bosch device and is conditioned on Bosch meeting the specified waiver conditions. Because the D-tect 200 must comply with these rules, and because it can operate under a waiver of the four rules we have identified in a manner consistent with the use characteristics associated with other UWB wall imaging applications without increasing the potential for harmful interference to authorized users, we find good cause to grant the waiver request. In doing so, we specifically address the particular circumstances related to the Bosch petition and agree with GPSIA that we will need to carefully evaluate future Part 15 UWB waivers based on the specific and unique circumstances associated with each application. The general concerns about issuing future Part 15 UWB waivers that GPISA has raised in its comments remain available for our consideration later and in an appropriate context. Furthermore, we will not use this proceeding to establish a new precedent for UWB rule waiver applicants to provide specific technical information in their petitions, as GPSIA has asked. We believe that applicants should continue to have broad flexibility in how they choose to structure their petitions. As a practical matter, because parties must submit sufficient information to mitigate the risk of delayed consideration or outright dismissal of their petitions, there is ample incentive for them to make their filings as complete and detailed as practical. 15. Our waiver is limited to the Bosch D-tect 200 device as manufactured, marketed and/or sold by Robert Bosch LLC and its affiliates and its use as described in the waiver request, and applies to: 1) the instantaneous bandwidth requirement in 47 CFR 15.503(d) as waived to permit operation of the 34 Bosch Waiver Request at 8, 14-15; Bosch Comments at 1-2. 35 Bosch 2011 Waiver Order, 26 FCC Rcd at 7574, para. 8. 36 Bosch Waiver Request at 13-14. 37 Bosch Comments at 2. 6 Federal Communications Commission DA 22-8 frequency-hopped UWB wall imaging system; 2) the measurement requirements in 47 CFR 15.31(c) and 15.521(d) as waived to permit the D-tect 200 device to be tested with the frequency sweep, stepping, or frequency hopping function active, rather than stopped, to demonstrate compliance with the maximum permitted average power in 47 CFR 15.509; 3) the definitional requirement in 47 CFR 15.503(h) as waived to permit the operation of a wall imaging system or a field disturbance sensor that is designed to detect the location of objects contained within a wall or to determine the physical properties within the wall. that is operated on materials that may or may not be thick enough to absorb the majority of the signal transmitted by the imaging system to permit limited usage of a drywall scanner/stud finder function of the device. This waiver is subject to the following conditions:

1) The D-tect 200 single hop step shall have a bandwidth of less than 1 kHz. 2) The intentional emissions generated by the D-tect 200 must be completely contained within the 1.8 to 5.7 GHz frequency range. 3) The D-tect 200 shall operate with frequency hopped modulation in 30 steps between 1.8 and 5.7 GHz. 4) The D-tect 200 maximum average transmission on-time shall be no less than 50 microseconds, the average transmission off-time shall be 15 microseconds or less. The maximum of the average ramp time shall be 2.3 milliseconds, resulting the maximum average dwell time to be 77 microseconds (2.3 milliseconds / 30 steps = 77 microseconds). 5) The device shall include a feature to ensure that it will only transmit when placed in contact with or close proximity to the building structure being measured and/or evaluated. 6) The D-tect 200 will not transmit continuously and will cease transmission 10 seconds after no movement. 7) For certification testing, the measurement of the emissions from the Bosch D-tect 200 shall be conducted with the hopping function active. 8) The D-tect 200 devices shall comply with all other technical and operational requirements applicable to UWB wall imaging devices under Part 15, Subpart F of the Commissions rules. 9) The waiver conditions granted herein are not transferable to any third party via 2.933 or any other means of technology transfer. 10) This waiver and its conditions shall apply only to the UWB devices described herein and are not to be considered to apply generally to any other UWB operations where further analysis would be necessary to assess the potential for impact to other authorized users. 11) The total U.S. sales of D-tect 200 devices shall not exceed 6000 devices, annually. 12) The D-tect 200 device shall not be marketed for retail consumer markets. The D-tect 200 device will be used by those engaged professionally in the building and construction trades. 13) The D-tect 200 device package shall include labeling stating For professional use only. 14) The user manual for the D-tect 200 will clearly state that Device operation is limited to those engaged professionally in the building and construction trades. 15) Upon grant of this waiver, Bosch will abide by its commitment to no longer manufacture equipment under the waiver, DA 11-899, granted by OET on May 23, 2011 in ET Docket No. 10-

253. 16) A copy of this Order shall be provided with the application for certification of the device. 7 Federal Communications Commission DA 22-8 IV. ORDERING CLAUSES 16. Accordingly, pursuant to authority delegated in Sections 0.31 and 0.241 of the Commission's rules, 47 CFR 0.31, 0.241, and Section 1.3 of the Commission's rules, 47 CFR 1.3, IT IS ORDERED that the Request for Waiver filed by Robert Bosch LLC on April 13, 2020 IS GRANTED consistent with the terms of this Order. This action is taken pursuant to Sections 4(i), 302, 303(e), and 303(r) of the Communications Act of 1934, as amended, 47 U.S.C. Sections 154(i), 302, 303(e), and 303(r). This action is effective upon release of this Order. 17. IT IS FURTHER ORDERED that, if no applications for review are timely filed, this proceeding SHALL BE TERMINATED and the docket CLOSED. FEDERAL COMMUNICATIONS COMMISSION Ronald T. Repasi Acting Chief Office of Engineering and Technology 8

From PT-MT/PXP1 Our Reference Heiko Sgarz Tel

+49 711 758-2909 Leinfelden 11 January 2022 Report Issue Topic Description 1.0 PS85 FCC Waiver Conditions This document describes how the FCC Waiver conditions (DA-22-

8A1) are met. The PS85 is a device variant of the Bosch D-tect 200 sold under Hilti brand. Condition 1 The PS85 single hop step shall have a bandwidth of less than 1 kHz. Yes. See operation description. Condition 2 The intentional emissions generated by the PS85 must be completely contained within the 1.8 to 5.7 GHz frequency range. Yes. See operation description. Condition 3 The PS85 shall operate with frequency hopped modulation in 30 steps between 1.8 and 5.7 GHz. Yes. See operation description. Condition 4 The PS85 maximum average transmission on-time shall be no less than 50 microseconds, the average transmission off-time shall be 15 microseconds or less. The maximum of the average ramp time shall be 2.3 milliseconds, resulting the maximum average dwell time to be 77 microseconds (2.3 milliseconds / 30 steps = 77 microseconds). Yes. See operation description. Condition 5 The device shall include a feature to ensure that it will only transmit when placed in contact with PS85 FCC Waiver Conditions.docx Page 1 of 4 From PT-MT/PXP1 Our Reference Heiko Sgarz Tel

+49 711 758-2909 Leinfelden 11 January 2022 Report Issue Topic Please enter issue Please enter topic or close proximity to the building structure being measured and/or evaluated. Yes. See document on TX disabling logic. Condition 6 The PS85 will not transmit continuously and will cease transmission 10 seconds after no movement. Yes. See document on TX disabling logic. Condition 7 For certification testing, the measurement of the emissions from the Bosch PS85 shall be conducted with the hopping function active. The hopping function has been active for all measurements contained in the test reports as it is active for the series device, if not stated differently. Condition 8 The PS85 devices shall comply with all other technical and operational requirements applicable to UWB wall imaging devices under Part 15, Subpart F of the Commissions rules. See the test report included. Condition 9 The waiver conditions granted herein are not transferable to any third party via 2.933 or any other means of technology transfer. The waiver will only be used by Robert Bosch LLC and its affiliates including private label customers as discussed with the FCC. Condition 10 This waiver and its conditions shall apply only to the UWB devices described herein and are not to be considered to apply generally to any other UWB operations where further analysis would be necessary to assess the potential for impact to other authorized users. PS85 FCC Waiver Conditions.docx Page 2 of 4 From PT-MT/PXP1 Our Reference Heiko Sgarz Tel

+49 711 758-2909 Leinfelden 11 January 2022 Report Issue Topic Please enter issue Please enter topic We are aware of this. Condition 11 The total U.S. sales of D-tect 200/PS85 devices shall not exceed 6000 devices, annually. Robert Bosch LLC will ensure to limit the sales to the stated number for the sum of devices from Bosch and its affiliates including private label customers. A reporting of the quantities from the records is possible upon request. Condition 12 The PS85 device shall not be marketed for retail consumer markets. The PS85 device will be used by those engaged professionally in the building and construction trades.

$1.300 USD (w/o battery and charger) recommended retail price is high compared to stud finders or common multi detectors in the market ($50-$200), is not likely a not professional user spends this money in this tool. Hilti tools are for professional use only and distributed via direct sales (a Hilti employee is delivering the tool directly to the customer) to professional construction customers and are available online for key account customers registered as professional construction customers. Battery platform fits to other Hilti professional tools only The packaging includes labelling stating For professional use only. The user manual states that Device operation is limited to those engaged professionally in the building and construction trades. Condition 13 The PS85 device package shall include labelling stating For professional use only. See packaging artwork. Condition 14 The user manual for the PS85 will clearly state that Device operation is limited to those engaged professionally in the building and construction trades. See operating instructions, page 8. PS85 FCC Waiver Conditions.docx Page 3 of 4 From PT-MT/PXP1 Our Reference Heiko Sgarz Tel

+49 711 758-2909 Leinfelden 11 January 2022 Report Issue Topic Please enter issue Please enter topic Condition 15 Upon grant of this waiver, Bosch will abide by its commitment to no longer manufacture equipment under the waiver, DA 11-899, granted by OET on May 23, 2011 in ET Docket No. 10- 253. The production of the D-tect150 and private label variants (under the waiver DA 11-899) has been stopped before the waiver grant and will not be started again. Condition 16 A copy of this Order shall be provided with the application for certification of the device. A copy of the waiver is included with the filing. PT-MT/PXP1 PS85 FCC Waiver Conditions.docx Page 4 of 4