Page 1 of 11 Wireless Facility Peer Engineering Review Regarding Verizon Wireless Application 2750 Dwight Way, Berkeley, CA August 10, 2015
Page 2 of 11 Introduction RCC Consultants, Inc. has been engaged by the City of Berkeley, CA to conduct a peer review, consistent with recognized industry standard practices, of a proposal from Verizon, to install a new wireless base station facility at 2750 Dwight Way, Berkeley, CA. This location is a residential neighborhood consisting of single and multi-family units, apartments, and other moderate density residential buildings. RCC has performed many similar peer reviews for municipal clients throughout the US, including several in the San Francisco Bay area. For purposes of this report, the term Verizon will also refer to, GTE Mobilenet of California, CellCo Partnership, and Verizon Wireless as well as any other entities related directly to this application, collectively, as the applicant in this matter Methodology In conducting a peer review, RCC reviews and analyzes site application documents against wireless industry standards and best practices. In this case, RCC considered the application materials as submitted by the applicant. In addition RCC conducted model calculations to verify results. Also provided as part of the application was a revised RF EME report provided to Verizon by Hammett and Edison Inc., Consulting Engineers which contains additional information supporting Verizon s application. Background and Scope The proposed facility is located at 2750 Dwight Way, Berkeley, CA. This facility is a new site for Verizon (no prior usage) and is located in a residential area. There are no other wireless facilities on this building. Verizon proposes to construct a new facility to provide services consistent with high capacity services and general cell services for voice and data usage. These new facilities will significantly increase the amount of traffic that the overall Verizon network will support in the immediate area of this proposed facility. In addition to new antennas at this site (within a screened enclosure), there are supporting equipment cabinets and devices that are commonly used in this type of installation. The RF generating apparatus (transmitter) is in a sealed case and does not warrant further consideration due to near-zero emissions. The batteries and other support equipment will be located in an equipment cabinet located away from the antennas on the rooftop in a separate screened enclosure. The only radiating devices, are the antennas. Site Location Description and Environment The site location is on the rooftop of a multifamily residential building. The building is located within a residential neighborhood predominantly occupied by multifamily residential buildings. Buildings adjacent to the site are all multifamily residential
Page 3 of 11 structures. Single family dwellings are also located in the neighborhood. In addition, the U.C. Berkeley Clark Kerr Campus is located one block east of the site, on Warring Street. All of these neighborhood uses would be served by this cell site. The apparent target serve area for this cell site is the residential market nearby. This is often found in areas with mobile populations as the population becomes more reliant on wireless devices and less reliant on conventional wired phones. In addition, many are migrating to wireless services for Internet access which will also be served with this new site. A street view of the subject location follows on next page:
Page 4 of 11 Justification for the placement of the Site This location is at and near other wireless facilities providing similar services. The facility in this application is designed to provide high levels of both voice and broadband data wireless services which consumers are demanding at growing rates. This high speed wireless data access is used for internet access, streaming of video and audio services and other high-bandwidth utilization services. When voice and data are combined, the network utilization and therefore the quality of coverage improves significantly. As wireless networks mature, the number of overall cell sites typically increases, and the height above ground for these sites typically decreases. This installation is proposed to be near roof level, rather than on a tower which indicates the cell network is maturing in this area. Rooftop sites are typically less visible and less visually intrusive than tower structures. As other networks mature, the typical height will decrease for these other networks also. In a typical cell site, the target usage is often a roadway, a commercial area, a residential area, etc. This location performs as the site for predominantly residential usage in the nearby areas A cell site typically will utilize the highest structure within the coverage area (within reason) in order to provide an unobstructed view of the coverage target area. This building appears to provide that advantage which makes this a more desirable site from a coverage standpoint.
Page 5 of 11 The current location fits well into a network design using the current best practices for cellular network design. Utilization of a different site could impact other adjacent cells precipitating other changes to the network. Following are depictions of coverage provided by Verizon.
Page 6 of 11 As shown above, the area labeled as College and Dwight changes coverage from the color red, to the color green. This demonstrates a much higher level of coverage. Determination of Need for this Additional Facility The applicant has provided coverage plots as part of the application package that graphically demonstrate the effect that the proposed site will contribute to coverage in the area. Coverage modeling such as used to produce these maps is an accepted industry planning tool for RF (signal) coverage. The graphic models have been incorporated in this report from the original application for reference. The area around the proposed site is represented by sites labeled Berkeley Downtown, UC Berkeley South, UC Berkeley East, Berkeley Bekins, Shattuck South and Berkeley Claremont. These neighbor sites graphically show a distinct and significant area of lesser coverage as shown by the red area south of the proposed site at College and Dwight (2750 Dwight Way). The second illustration of this area shows coverage with the proposed site operating in conjunction with the previously shown sites which provides coverage in the previously red colored area on the map, indicating a significant improvement in Verizon services in that area. Based on the coverage maps provided, and the signal levels demonstrated in the model plot, this site will improve reliability and capacity within the immediate area of the proposed cell site. The current levels, without the proposed site, are of the lowest service level possible, which results in lower data speeds, poor voice quality, and potentially lost coverage/data delays, degrading network performance. The addition of this proposed cell site to the network will improve capacity and coverage reliability in the area significantly. Alternative Sites Considered Verizon, as part of their application, has identified 6 other sites that they considered in the selection of the site proposed. Each of the 6 sites was identified by Verizon as not worthy of consideration because of several factors as identified in Verizon s application. No other sites were identified for consideration in this report. Radio Frequency Emissions Safety Verizon has provided, as part of the application process to the City of Berkeley, an RF-EME study (Radio Frequency Electro-magnetic Energy) that predictively models expected RF exposure levels in the vicinity of the antennas and beyond. This report was written by Hammett and Edison, Inc., Consulting Engineers. The report contains information for each antenna location and a site diagram (Figure 3 in the report) supporting this information. Also included is a chart indicating the exposure levels and a graphic depiction of the exposure area. RCC did perform modeling calculations on the antennas from which the recommendations on mediation are made to verify accuracy of the claims in the report.
Page 7 of 11 The highest RF levels are in front of the antennas, as expected. The antennas are directed outward from a screened enclosure on top of a penthouse on top of the building. This elevates the antennas above the head level of any person on the roof level. The design of this site takes into consideration the elevation of antennas. This takes the radiation of the antenna and raises it above the level that people would encounter excessive levels. The vertical beam-width of the antenna is typically 3 to 6 degrees, which places rooftop signal levels well away from areas that people can access. The areas below the antennas, inside the building in particular, all fall well below the MPE for uncontrolled or civilian exposure levels. In looking at adjacent buildings, the levels are well below the MPE for uncontrolled exposures. Typically, at power levels shown at this site, the maximum distance from the antennas where signal levels can rise above Maximum Permitted Exposure (MPE) levels is 12 feet. This calculation was made using the most restrictive method as identified by the FCC, and which takes into account a highly likely scenario of double reflection of signals. By taking this worst case situation, we can predict the safest situation to protect the general public. The FCC has determined the highest RF levels, or Maximum Permitted Exposure (MPE) levels that can be reached by licensees in potential exposure to humans. These exposure levels are divided into two standards to reflect potential exposures. These divisions are identified as Uncontrolled where the user is not aware or cannot control exposure to antennas, and Controlled, where the person exposed is aware of the exposure and can mitigate exposure through limiting exposure. (Site drawing on following page)
Page 8 of 11 In the Hammett and Edison report, the signage proposed in Figure 3 (copied above) is intended to provide information by which the person that may be exposed will be aware of the exposure potential. Also recommended is training of the building operator and any person that may have access to the roof so that they also qualify for Controlled Access status. Not included, and RECOMMENDED is to post a sign at the access points to the roof to advise persons entering the roof area of potential exposure to RF energy. The doorway to the roof in particular requires signage which should be mounted beside the door in a clearly visible area, as well as generally cautionary information containing a phone number for the Verizon NOC (Network Control Center). See photo on following page of access point to the roof. In addition to the door, the ladder to the enclosure shown in the site drawings in the application package should have both cautionary signage and informational signage.
Page 9 of 11 In the Hammett and Edison report, the writer states in a footnote that the language of these signs is outside the scope of their expertise. The OET 65 signage requirements show satisfactory language to include. In addition, multi-language sign may be appropriate at the election of the City. There is a potential for a worker to be exposed above the Controlled level when performing maintenance or repairs to the exterior of the building. In the safety industry, a mitigation and control plan will be necessary to protect worker safety. This is not a complex document and the information sign proposed in the construction drawings contains the action items for the safety plan. The signage and markings proposed in the Hammett & Edison report do not constitute a mitigation plan. A written safety plan should be incorporated at this site to comply with FCC and CalOSHA rules on exposure to hazards. In using the best practices available in the industry (both cellular and safety), these represent critical parts of a mitigation plan to reduce the potential hazards. Compliance with applicable Federal radio frequency emission standards
Page 10 of 11 Based on the RF-EME exposure study and the modeling performed for this site, the potential exposure levels in those controlled access areas are significantly higher than FCC limits for Controlled exposure on certain specific areas above the level of the main roof. All other areas interior to the building, on lower adjacent rooftops. or street level, fall far below the Maximum Permitted Exposure (MPE) levels for uncontrolled or public access, and do not warrant further consideration. The upper roof area is the only area of concern. Levels on the outside of the screened area for the antennas can be many times the Maximum Permitted Exposure level (MPE) and, therefore, require mitigation. The Mitigation for this site can be accomplished through several approaches, or a combination thereof. This combination of approaches is utilized in the Hammett & Edison report, with the recommended changes noted herein. Following are these factors that provide mitigation to the controlled area: 1) Access and Barriers The use of building design in this location permit the rooftop area to be treated as a controlled access area. The rooftop access is only through the locked penthouse doorway. There are no other access ways noted in the report. Signage for the door has been recommended in this report. No barriers are necessary at this site due to controlled access to the roof area. 2) Signage The signage recommended for the site include the yellow caution and the yellow Information sign, as well as the Green Information sign for Verizon Wireless NOIC access, including the telephone number and site ID. The location of signage is shown on the above Figure 3 from the Hammett and Edison report. With the additions noted above, signage can be considered adequate. The combined use of these two aspects of access control and signage constitute a safe site design. Potential for interference with existing or planned public safety emergency response telecommunications facilities No Public Safety antenna locations were noted in the immediate area. Summary and Conclusions The new systems proposed for this site are reasonable and will exceed the Maximum Permitted Exposure levels in certain areas that are normally accessible only to workers and are clearly not accessible to the general public. Mitigation of any potential hazard can be readily accomplished through signage, markings, and a written Exposure Control Plan for maintenance at the site in those areas with higher exposure levels. The following actions are recommended:
Page 11 of 11 1) The safety marking and exposure controls shown in the Hammett and Edison, Inc. report Figure 3 should be incorporated in the construction drawings and any final approvals by the City of Berkeley, with the following changes: a) Signage be added at the door to the roof as noted in this report. b) Signage be included on the ladder securement device to advise potential users of the ladder of high exposure levels. Physical barriers are not necessary at this site as the access to the rooftop is through a locked door. 2) A written exposure control plan for this facility is necessary and the building owner and occupants that will go onto the roof must be provided training to understand exposure to high RF environments. Respectfully Submitted Douglas R Dickinson Managing Consultant, RCC Consultants June 30, 2015