Wireless Facility Radio Frequency Exposure Compliance Review

Transcription

1 Wireless Facility Radio Frequency Exposure Compliance Review Gibraltar Peak Communications Site 3035 Gibraltar Road, Santa Barbara, CA 9/21/2015 Preiser Consulting La Posta Court, Corona, CA Tel Fax

2 Gibraltar Peak Communications Site 3035 Gibraltar Road, Santa Barbara, CA Introduction Preiser Consulting has been engaged by the County of Santa Barbara to conduct a peer review, consistent with recognized industry standard practices, of a radio frequency (RF) compliance report developed by Remote Possibilities on behalf of Community Radio Inc. (CRI), dated March 27, 2014, addressing RF safety aspects of a radio communications site located at 3035 Gibraltar Road, Santa Barbara, CA. System Description The wireless facility is located on a 36 acre property in Santa Barbara, CA. It provides services in a number of radio services, including, FM radio, broadcast television, microwave, cellular and land mobile radio. Figure 1 Aerial View of Gibraltar Peak P r e i s e r C o n s u l t i n g P a g e 2

3 Methodology In conducting a peer review, relevant site application documents are reviewed and analyzed against current Federal Communications Commission (FCC) regulations and guidelines, wireless industry standards and best practices. Guidelines are primarily provided in the FCC Office of Engineering & Technology Bulletin No. 65, Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields, August 1997 ( OET Bulletin 65 ) and Supplements A, B and C. In this cased the following documents were reviewed and analyzed relative to the RF safety aspects to determine compliance with Federal Communications Commission guidelines: Radio frequency (RF) compliance report by Remote Possibilities on behalf of Community Radio Inc. (CRI), dated March 27, 2014, including appendices. Addendum to the report, dated July, 9, 2015 Findings Relating to Radio Frequency Emissions Safety The FCC provides for two common methods to determine compliance with FCC regulations and guidelines as established in OET65: 1) Predictive Methods which are based on calculations and computer modeling, and 2) Field Measurements based on actual measurement of the RF fields. The Predictive Method is commonly used for relatively simple sites with few transmitters. However, as the site complexity increases, such as encountered with large antenna farms, this method is no longer practical from a computational standpoint. In such cases, the Field Measurement Method is more commonly used to establish compliance. In this particular case, Remote Possibilities used the Field Measurement Method to determine whether there is a potential for human exposure in excess of the MPE limits specified by the FCC. According to the report, the measurements were conducted with an industry standard measurement instrument, a Narda Model NBM-550 with a Model EA5091 electrical field probe. (See specifications in Attachment 1.) The EA5091 probe provides for broadband measurements in the frequency range of 300 khz to 50 GHz and is based on a shaped response corresponding to the FCC MPE limits. P r e i s e r C o n s u l t i n g P a g e 3

4 The report by Remote Possibilities provides MPE measurements at 68 points at or near the facility, including 26 points along Gibraltar Road. It is noted that the report mentions 43 points of measurements specifically required by the County of Santa Barbara. However, it is not clear which of the 69 measurement points, if any, comprise the 43 points required by the County. A review of the measurements obtained outside the perimeter of the facility indicates that the levels are substantially below the MPE level for exposure to the general public. The measurements obtained at ground level within the facility itself indicate all points to be within the occupational MPE limit. The occupational MPE limit may be exceeded when working at elevated positions in proximity of antennas. However, this can be mitigated by imposing access control, limiting access to the facility to personnel that has undergone RF safety training, and by maintaining the proscribed warning signage. These mitigation measures bring the facility into compliance with the FCC guidelines. Summary and Conclusions Preiser Consulting is of the opinion that: The methodology used to determine FCC compliance as described in the Remote Possibilities report is consistent with FCC guidelines and industry best practices. Based on a review of the measurement provided in the Remote Possibilities report, the site meets Federal Communications Commission guidelines pertaining to radio frequency exposure to the general public outside the gates to this facility as of the date of the measurements. Based on a review of the measurement provided in the Remote Possibilities report, the site meets Federal Communications Commission guidelines pertaining to radio frequency exposure to qualified occupational personnel working within the perimeter of this facility as of the date of the measurements. Access control, barriers and warning signage as indicated in the report need to be maintained. P r e i s e r C o n s u l t i n g P a g e 4

5 Certification 1. I have read and fully understand the FCC regulations concerning RF safety and the control of human exposure to RF fields (47 CFR et seq). 2. To the best of my knowledge, the statements and information disclosed in this report are true, complete and accurate. 3. The analysis of site RF compliance as detailed in the Remote Possibilities report is consistent with the applicable FCC regulations, additional guidelines issued by the FCC, and industry practice. Date: September 21, 2015 Dieter J. Preiser, PMP P r e i s e r C o n s u l t i n g P a g e 5

6 Attachment 1 Narda Model NBM-550 Specifications A t t a c h m e n t 1 P a g e 1

7 A t t a c h m e n t 1 P a g e 2

8 A t t a c h m e n t 1 P a g e 3

9 A t t a c h m e n t 1 P a g e 4

10 A t t a c h m e n t 1 P a g e 5

11 A t t a c h m e n t 1 P a g e 6

12 Attachment 2 The FCC MPE Limits The Federal Communications Commission (FCC) has established limits for maximum continuous human exposure to RF fields as directed by the Telecommunications Act of The FCC maximum permissible exposure (MPE) limits represent the consensus of federal agencies and independent experts responsible for RF safety matters. Those agencies include the National Council on Radiation Protection and Measurements (NCRP), the Occupational Safety and Health Administration (OSHA), the National Institute for Occupational Safety and Health (NIOSH), the American National Standards Institute (ANSI), the Environmental Protection Agency (EPA), and the Food and Drug Administration (FDA). In developing its guidelines, the FCC also considered input from the public and technical community notably the Institute of Electrical and Electronics Engineers (IEEE). The FCC s RF exposure guidelines are incorporated in Section et seq of its Rules and Regulations (47 CFR ). Those guidelines specify MPE limits for two types of exposures to RF energy: 1. Occupational / Controlled Exposure persons who are exposed as a consequence of their employment and are fully aware of the potential for exposure and have the ability to exercise control over their exposure. 2. General Population/Uncontrolled Exposure apply when one is exposed and may not be fully aware of the potential for exposure or cannot exercise control over their exposure. The specified continuous exposure MPE limits are based on known variation of human body susceptibility in different frequency ranges, and a Specific Absorption Rate (SAR) of 4 watts per kilogram, which is universally considered to accurately represent human capacity to dissipate incident RF energy (in the form of heat). The occupational MPE guidelines incorporate a safety factor of 10 or greater with respect to RF levels known to represent a health hazard, and an additional safety factor of five is applied to A t t a c h m e n t 2 P a g e 1

13 the MPE limits for general population exposure. Thus, the general population MPE limit has a built-in safety factor of more than 50. The limits were constructed to appropriately protect humans of both sexes and all ages and sizes and under all conditions and continuous exposure at levels equal to or below the applicable MPE limits is considered to result in no adverse health effects or even health risk. The reason for two tiers of MPE limits is based on an understanding and assumption that members of the general public are unlikely to have had appropriate RF safety training and may not be aware of the exposures they receive; occupational exposure in controlled environments, on the other hand, is assumed to involve individuals who have had such training, are aware of the exposures, and know how to maintain a safe personal work environment. The FCC s RF exposure limits are expressed in two equivalent forms, using alternative units of field strength (expressed in volts per meter, or V/m), and power density (expressed in milliwatts per square centimeter, or mw/cm2). The table below lists the FCC limits for both occupational and general population exposures, using the mw/cm2 reference, for the different radio frequency ranges. The diagram below provides a graphical illustration of both the FCC s occupational and general population MPE limits. A t t a c h m e n t 2 P a g e 2

14 Because the FCC s RF exposure limits are frequency-shaped, the exact MPE limits applicable for a particular system installation depend on the frequency range used by the systems of interest. The most appropriate method of determining RF compliance is to calculate the RF power density attributable to a particular system and compare that to the MPE limit applicable to the operating frequency in question. The result is usually expressed as a percentage of the MPE limit. For potential exposure from multiple systems, the respective percentages of the MPE limits are added, and the total percentage compared to 100 (percent of the limit). If the result is less than 100, the total exposure is in compliance; if it is more than 100, exposure mitigation measures are necessary to achieve compliance. A t t a c h m e n t 2 P a g e 3

15 Attachment 3 Statement of Qualifications SUMMARY OF EXPERIENCE: Over 35 years experience in all facets of telecommunications, with specialization in wireless technologies, including six years as an independent consultant for state and local government agencies on wireless and wireline telecommunications technologies. Areas of expertise include: Mobile radio technologies for public-safety agencies Wireless site development and operation Tower design and implementation Radio Frequency Safety Cellular voice and data technologies In-building coverage solutions Distributed Antenna Systems (DAS) Fiber optic and microwave backhaul transmission Next Generation systems design and implementation Satellite voice and data transmission CLIENTS SERVICED: Wireless Site Development and Evaluation: City of San Diego, CA City of Martinez, CA City of Berkeley, CA City of Belmont, CA City of Palo Alto, CA City of Burlingame, CA City of San Jose Other Wireless Projects: County of Los Angeles, CA County of Riverside, CA Salt Lake City, UT North-Slope Borough, AK Clark County, WA Chelan County PUD, WA Fresno Fire Department ADDITIONAL INFORMATION: BS Degree in Electronics, MBA in Information Systems Certified Telecommunications Engineer - RF Endorsement (NARTE) First Class FCC Radio Telephone license Project Management Professional (PMP) certification from the Project Management Institute (PMI) Certified Cost Engineer (AACE), volunteer certification course instructor. Served as chairman of the Engineering Sub-Committee of the California Public-Safety Radio Association. (CPRA) a local chapter of the Association of Public Safety Officials (APCO). Served as chairman of the Regulatory Review Committee of the California Public-Safety Radio Association representing southern California in matters before the FCC and Public Utilities Commission. Member of the Associated Public-Safety Communications Officials International (APCO) FCC Amateur Radio License, N6DGS Served as a Computer and Communications Specialist with the California Air National Guard, Combat Communications Squadron A t t a c h m e n t 3 P a g e 1