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Home My WebLink AboutAntenna Site FCC RF Compliance Assesment and Report ^� yW ��'ry �5 ��,.��f �� ,I �d �� PINNAC�E TE�ECOM GROUp "m� Professional and Technical Services ��wJ Y�( �� '� �`�I�I,, . � ��u0� ��ra�� w"k��i�qGr�� ry 7�rvaa+Ct�ti�hk� ANTENNA SITE FCC RF COMp�IANCE ASSESSMENT ANd REpORT PREPAREd FOR NEV1/ YORI( SMSA LIMITECI PARTNERSIiIp d�b�A VERIZON WIRE�ESS ��ORIENT POINT 2�� SITE 40200 M Ai N ROAd ORIENT� NY MARcN 15, 2016 �4 RIdC�EdA�E AVENUE - SuirE 260 • CEdAR KNO��S� NJ 07927 • 973-451-1630 CONTENTS INTROdUCTION ANd SUMMARy 3 ANTENNA ANd TRANSMISSION DATA 4 COMP�IANCE ANA�yS15 7 COMP�IANCE CONC�USION �2 CERTIFICATION �3 AppENdix A. BACI(C�ROUNd ON TIiE FCC MPE LIMIT AppENdix B. SUMMARy OF EXPERT QUA�IFICATIONS 2 INTROdUCTION ANd SUMMARy At the request of New York SMSA Limited Partnership d/b/a Verizon Wireless ("Verizon Wireless"), Pinnacle Telecom Group has perFormed an independent assessment of radiofrequency (RF) levels and related FCC compliance for a proposed wireless base station antenna operation on an extension to an existing monopole at 40200 Main Road in Orient, NY. Verizon Wireless refers to the site as "Orient Point 2" and the proposed operation involves directional panel antennas and transmission in the 746 MHz, 1900 MHz, and 2100 MHz frequency bands licensed to Verizon Wireless by the FCC. The FCC requires wireless antenna operators to perform an assessment of potential human exposure to radiofrequency (RF) fields emanating from all the transmitting antennas at a site whenever antenna operations are added or modified, and to ensure compliance with the Maximum Permissible Exposure (MPE) limit in the FCC regulations. In this case, the compliance assessment needs to take into account the RF effects of existing antenna operations at the site by AT&T. Note that FCC regulations require any future antenna collocators to assess and assure continuing compliance based on the cumulative effects of all then-proposed and then-existing antennas at the site. This report describes a mathematical analysis of RF levels resulting around the site in areas of unrestricted public access, that is, at ground level around the site. The compliance analysis employs a standard FCC formula for calculating the effects of the antennas in a very conservative manner, in order to overstate the RF levels and to ensure "safe-side" conclusions regarding compliance with the FCC limit for safe continuous exposure of the general public. The results of a compliance assessment can be explained in layman's terms by describing the calculated RF levels as simple percentages of the FCC MPE limit. If the reference for that limit is 100 percent, then calculated RF levels higher than 100 percent indicate the MPE limit is exceeded, while calculated RF levels consistently lower than 100 percent serve as a clear and sufficient demonstration of compliance with the MPE limit. We will also describe the overall worst-case calculated result via the "plain-English" equivalent "times-below-the-limit factor". 3 The results of the FCC RF compliance assessment in this case are as follows: ❑ At street level around the site, the conservatively calculated maximum RF level from the combination of proposed and existing antenna operations is 6.3986 percent of the FCC MPE limit — well below the 100-percent reference for compliance. In other words, even with the significant degree of conservatism in the calculations, the worst-case calculated RF level is still more than 15 times below the FCC limit for safe, continuous exposure to the RF emissions from antennas. ❑ The result of the analysis demonstrates compliance with the FCC regulations and MPE limit. Moreover, because of the extremely conservative calculation methodology and operational assumptions we applied in the analysis, RF levels actually caused by the antennas will be significantly lower than the calculation results here indicate. The remainder of this report provides the following; o relevant technical data on the Verizon Wireless antenna operations, and on the existing AT&T antenna operations at the site; ❑ a description of the applicable FCC mathematical model for assessing MPE compliance, and application of the relevant technical data to that model; and ❑ the result of the analysis, and the compliance conclusion for the site. In addition, Appendix A provides background on the FCC MPE limit, along with a list of FCC references on compliance, and Appendix B summarizes the expert qualifications of the author of this report. ANTENNA ANd TRANSMISSION DATA The table that follows provides the key compliance-related data for the proposed Verizon Wireless antenna operations. 4 . � ,,,, ,�, _�:�� ,;, ,� ,�„ �„ ,�� , � ,�<,, , ,., � _ � � General Data �� ,;, �,, ,. n,,, , �,,;, ,,, ,,., ,� „ , , ,,,. �, , �,,, ;, , „ , ��. „ ,, �, Freguency Bands _746 MN�� 1900 MHz and 2100 MHz .��..... _�. .. Service Covera�e TX�e , Sectonzed � _ ,,,..,� �.�.....��. ��...... Antenna Type Directional Panel ......__.. ._ ��. �. ......_.�... _....��.. Antenna Centerline Hei ht AGL 85 ft. 6 in. .....�� .....� ......__�. ..� ��__.__. ....... Antenna Line Loss 0 dB conservativel i �c�red „ .��,__., � �., ��.,,�,.� —� �� -�. %, 746 MHz Ante�ata , , ,� �� , „ , �/i,� %i%� ��i � i � � <, �,, � � � , � ,,, u..�.��.�., ;, � �� _ ��_.M��,�,�„ro,� ,......._�... .��_ � �.... �w Antenna Mwodel Max. Gain�wwww� Am henol CWWX063X25G00 (16 3mmmdBi) RF Channels p�r Sector 2 40 watts ��i� � � ii iai �� . i 1900 MHz Antenna Data � ��'" �� ,�� , , i��,iii ,��,i,r,,i, ,io%//niiio��,:� � ii ia/ %,%%/// I Antenna Model__�Max. Gain _ Am�henol CWWX063X25G0�0 17.0 dBi� _ �I, RF Channels��r Sector 2 60 watts ,, �'iii� �°�"i��i i/ ,iiI'"�iii ��,/i �i//�i, iiii/��o�/�%/ i�/� %� j�� '' �i i � ��aio�� ///0//ri � � ��%/� ✓ , i// 2100 MHz Antenna Data ��' „� ,� ,, �� i ,,,,, , � , � � � �iiii� , % �. �.,. ;_,.�,�� !„ ��,. �i. �, G/,>,,,�i,��...�,.,,,,.i �i. � ��, . :, „;m ,..�„�.�.�.. � ... �..-., . ,.. ,,, Antenna Model Maxmm Gam _wAm,��enol CWWX063X25G00 �17.3 dB�wwwwmm RF Channels�er Sector 2 60 watts ��,, , , , �,,,,.�, ��,_,.��--� The antenna vertical-plane radiation pattern is used in the caiculations of RF levels at street level around a site. Figures 1 through 3 that follow show the vertical-plane patterns of the proposed antennas. In this type of antenna pattern diagram, the antenna is effectively pointed at the three o'clock position (the horizon) and the pattern at different angles is described using decibel units. Note that the use of a decibel scale to describe the relative pattern at different angles actually serves to significantly understate the actual focusing effects of the antenna. Where the antenna pattern reads 20 dB the relative RF energy emitted at the corresponding downward angle is 1/100th of the maximum that occurs in the main beam (at 0 degrees); at 30 dB, the energy is only 1/1000th of the maximum. Note that the automatic pattern-scaling feature of our internal software may skew side-by-side visual comparisons of different antenna models, or even different parties' depictions of the same antenna model. 5 Figure 1.Amphenol CWWX063X25G00 -746 MHz Vertical-plane Pattern ,� � _. _ f � ,P �° ��,�„ �� .. � . �� / ��„�� i ,,� �.� � � � �� ,� �' ��;� �,� �,� � � � � �� ,� . � �� " �� "� �,,"" � �,"� �� 'µ�"�,,�� , . . m� � � M w '�` 1 �.w� � � �,�� ,G , �,,� � ,� ... � ti, , �. .,. �,� � � �. �,. �r. , .. ". . 0 deg _....... ��_ .�. ..... .... . � .� �� . :.. .....��_� .�.._ �...0 horizon �� .,� ��,,� ,, , ��, �, � � . � .M w. ��, � � � � � p�° � "� ,� �p� �,�� § '� M i" �'M, d F 4 �� A" � � h✓ W '�, W �� `� � � � �`�� ' °�� n �, �, �;"� "" � � � �� ..a�, "w`"�� ,� ,� � �.ry � � �, �'",, ��,�, �� .�,.��` ��°�°•m 5 dB/division Figure 2.Amphenol CWWX063X25G00 -1900 MHz Vertical-plane Pattern � .�. � � ��lm ��t"� �`�� ,�_ � �M.� �,r° w��, ,'�� w.� �� I �,� � ;, ,✓� '� -.., � . N� � �� "�^� ��"n��'� �� ' ��m,,.��1 � ., ti� " „ . �t' �.,„�, ,�A �y � ..�°�" ,..,�`�� ,_° �n, � �,v �4 N �'�° �"�"w �.,. ,, ,.., "*�u� . ��, ...� � . ..�� 0 deg � �� . ...._.: � �. ��.., horizon � �� , � . � � �' �� r , � �� . � � � � � � � � 4, �, � �, �� m �_ � �� . � � � " � � �"� ,�� "� � '� �„� ��' _.�;� ��°�� ,�,�� ,�"��. �� ° � ��" �°� `��' � � � 0 ��. ��e. � ��,, �,� � � , ��. W�� .�� a � � 4 f 9 � ��w� "�"� 5 dB/division , _. .. 6 Figure 3. Amphenol CWWX063X25G00 -2100 MHz Vertical-plane Pattern ......... ..... .� .......��..�� .��.� . , w �"�,,,� � �. �+ �' � �� .�-� � .�� w J� �� ,�� ,�� °� � � � ��. �� .�� tiyw��'� �� ,�'�t a � ��n.�'�r' "��k� � .,�i �+� v� �'�� .b. r .m..P�e � � � .. � . � �"�� ' ;, � v �a � 0 deg �� ., � ,, , � � ..,. horizon � � �. ,� _�.. mm , � �,�,* .m �a� " � _,. �� f� �,. � � � � � ;�o � a�^�,., `� ' " . � , �, � �,s � � � �, � `� �� , �� , �r,,..�, � ��r � � � �µ �M.��''� �� '� �� " ,� �. �� , � ��a�� r � � �� ,•,,,�� .,...�-- �w, •,'�;a°" . �, r � �w` �� a� � ,£�� M, �-..� � 5 d6 /division As noted at the outset, there is an existing wireless antenna operation by AT&T to include in the compliance assessment and we will conservatively assume operation with maximum channel capacity and at maximum transmitter power in each of their respective FCC-licensed frequency bands. AT&T is licensed to operate in the 700, 850, 1900 and 2300 MHz frequency bands. In the 700 MHz band, AT&T uses two RF channels per antenna sector and a maximum transmitter power of 40 watts. In the 850 MHz band, AT&T uses four 20-watt channels per sector. In the 1900 MHz band, AT&T uses two 20-watt channels and one 60-watt channel per sector. In the 2300 MHz band, AT&T uses two 50-watt channels per sector. COMP�IANCE ANA�y51S FCC Office of Engineering and Technology Bulletin 65 ("OET Bulletin 65") provides guidelines for mathematical models to calculate the RF levels at various points around transmitting antennas. At street-level around an antenna site (in 7 what is called the "far field" of the antennas), the RF levels are directly proportional to the total antenna input power and the relative antenna gain in the downward direction of interest — and the levels are otherwise inversely proportional to the square of the straight-line distance to the antenna. Conservative calculations also assume the potential RF exposure is enhanced by reflection of the RF energy from the intervening ground. Our calculations will assume a 100% "perfecY' reflection, the worst-case approach. The formula for street-level RF compliance calculations for any given wireless antenna operation is as follows: MPE% _ (100 "'TxPower* �O �Gmax-Vdiscl10) * 4 )/ ( MPE * 4�* R2 ) where MPE% � RF level, expressed as a percentage of the MPE limit applicable to continuous exposure of the general public 100 � factor to convert the raw result to a percentage TxPower � maximum net power into antenna sector, in milliwatts, a function of the number of channels per sector, the transmitter power per channel, and line loss 10 ��`"aX-vd'S�'o� = numeric equivalent of the relative antenna gain in the downward direction of interest, referenced to any applied antenna mechanical downtilt; data on the antenna vertical-plane pattern is taken from manufacturer specifications 4 = factor to account for a 100-percent-efficient energy reflection from the ground, and the squared relationship between RF field strength and power density(22= 4) MPE =� FCC general population MPE limit R = straight-line distance from the RF source to the point of interest, centimeters The street-level MPE% calculations are performed out to a distance of 500 feet from the facility to points 6.5 feet (approximately two meters, the FCC- recommended standing height) off the ground, as illustrated in the Figure 4 on the next page. 8 antenna � height from ` �`�'"M--�,w R .�.., antenna ��""~-w.�. bottom to � 6.5' ,�, ��* above � � ..� ��, -�.,. ground �`'°�.�� ..""..� .~�.. level �� , . � I ��"""� .�� "�� .�.............��...........................m......... .. _...... ...�� ..� A..... . _. w �..��. 500 Ground Distance D from the site Figure 4. MPE% Calculation Geometry It is popularly understood that the farther away one is from an antenna, the lower the RF level — which is generally but not universally correct. The results of MPE% calculations fairly close to the site will reflect the variations in the vertical- plane antenna pattern as well as the variation in straight-line distance to the antennas. Therefore, RF levels may actually increase slightly with increasing distance within the range of zero to 500 feet from the site. As the distance approaches 500 feet and beyond, though, the antenna pattern factor becomes less significant, the RF levels become primarily distance-controlled, and as a result the RF levels generally decrease with increasing distance, and are well understood to be in compliance. FCC compliance for a collocated antenna site is assessed in the following manner. At each distance point along the ground, an MPE% calculation is made for each antenna operation (including each frequency band), and the sum of the individual MPE% contributions at each point is compared to 100 percent, the normalized reference for compliance with the MPE limit. We refer to the sum of the individual MPE% contributions as "total MPE%", and any calculated total MPE% result exceeding 100 percent is, by definition, higher than the FCC limit and represents non-compliance and a need to mitigate the potential exposure. If 9 all results are consistently below 100 percent, on the other hand, that set of results serves as a clear and sufficient demonstration of compliance with the MPE limit. Note that according to the FCC, when directional antennas such as the panels commonly used in wireless communications are used, the compliance assessments are based on the RF effect of a single (facing) antenna sector or, in cases of non-identical parameters, the worst-case effect of any individual sector. The following conservative methodology and assumptions are incorporated into the MPE% calculations on a general basis: 1. The antennas are assumed to be operating continuously at maximum power, and at maximum channel capacity. 2. The power-attenuation effects of shadowing or other obstructions to the line-of-sight path from the antenna to the point of interest are ignored. 3. The calculations intentionally minimize the distance factor (R) by assuming a 6'6" human and performing the calculations from the bottom (rather than the centerline) of the antenna. 4. The potential RF exposure at ground level is assumed to be 100-percent enhanced (increased) via a "perfect" field reflection from the intervening ground. The net result of these assumptions is to significantly overstate the calculated RF exposure levels relative to the levels that will actually occur— and the purpose of this conservatism is to allow very "safe-side" conclusions about compliance. The table that follows provides the results of the street-level MPE% calculations for each operator, with the overall worst-case result highlighted in bold in the last column. 10 �. w......�� ..��... ��._. �._ ��..._...��..� r�r��wmwdl ��rAzr�r� "��ra�� '��rk�a�r� C3h�t�rro�c� '�'ir�N�� Vlfir�l+�� '�J'#r�� ATBT Total �� 4� �� l�'�4�b �1PIt�z ��W �fl�l� MPE% MPE% �1��°!� MF"��J� NU�P'�'�,1� .�,. _ � ._, , �, ,, ---- , �. �„ ;, ,, ,,,, �, �� ,;, .,,, , ,,, ,,,,,,, , ,.,,, , ,, , , . . - C� �.t��7 d.C�O�� C�.9��'� C�.��"�C� 0.2284 .,.,.w. A..._��...._ � ,.,.,,.....m..�,�,�.m..�...� .�,,�.,m,m..,�..� __.�,�...��...�. �.__�,.,..� .....____ 20 0.0269 0.0212 0.0101 0.8821 0.9403 _..............�................. . .._..........�...��.......�.�.._��_......................._...��...........��_W........................_.. ....... ...��.� 40 0.0479 0 0598mmmmmmmmm ww 0.1686 0 3872 0.6635 � ...... 60 0.2060 0.1587 0.0833 5.9506 I 6.3986 .._. 80 0.6586 0.3849 0.1110 2.8877 I 4.0422 100 0.1496 0.5642 0.5388 0.6281 1.8807 ', 120 0.1016 0.1793 0.6817 0.6481 1.6107 � 140 � � 0.0753 0.1876 0.2105 1.2656 1.7390 .._................1.60�...�_...........� .._....�_..��.0393�...�� 0.0100 _0.1204...�_��. �....�.._�................��mm.�. 0 1.4616 1.6313 .�W 180 0.0628 ........��.....0.0403 .�....0.0075 ....m....1.4596........�� . 1.5702...........��. �.......... ... .....�www www...�_ww_www�.�..�.�wwwwwww_� �.._ 200 0.0588 0.0222 0.0116 2.1769 2.2695 ... ww 220 0.0232 0.0105 0.0236 2.3895 2.4468 240 0.0066 0.0254 0.0116 2.4963 2.5399 ............,,,,_m�._m,,......�,,,..., ,.....�.� mmmmmmmmmm 260 m„mmmmmmmm __ 0.0008 0.0372 0.0041 2.4718 2.5139 � m�m280mmm � mmmm0.0221 0.0309 � 0.0135 � mm��mm2.3949 � 2.4614 � 300�.._�_0..0.1..94�....._��._��__��.�........��_..�...._��.�.��__�..... �..____....��...��.....� 0.0272 0.0119 2.0941 2.1526 320 0.0335 0.0138� �m�mmmm�mmmmm0.0110Wmm�mmmmmm mmmmmmmmmmm2.1015mmmmmmm�ml 2.1W598mmmmmmmmm�mm 340 0.0441 i u�mm0.0058 � 0.0051 �Wm�WmWmW1.8663 I 1.9213 m�mmmmmm� 360 0.0510 �0.0068 m�mmmm�mm 0.0020 2.0407 2.1005 �......._.. 380 0.0459 0.0061 0.0018 1.8349 1.8887 I 400 0.0561 0.0111 0.0069 2.2005 2.2746 i 420 0.0511 0.0101 0.0062 1.9986 2.0660 440 0.0739 0.0119 0.0168 1.8232 1.9258 460 0.0678 0.0109 0.0154 1.6698 1.7639 480 0.1162 0.0087 0.0220 2.1041 2.2510 , 500 .. 0.1073 .....�..,..._.__ 0.0081 -�0.0203.....�..,.�................1.940.7........._..._.�..2..0764 As indicated, even with the significant degree of conservatism built into the calculations, the maximum calculated RF level 6.3986 percent - well below the 100-percent reference for compliance, particularly given the conservatism incorporated in the calculations. A graph of the overall street-level calculation results, provided on the next page, provides a clearer visual illustration of the relative insignificance of the calculated RF levels. The line representing the overall calculation results shows a clear, consistent margin to the FCC compliance limit. 11 COMPLIANCE ASSESSMENT RESULTS � Normalized FCC MPE Limit �� Total MPE% Results 120 _...� ..... ......n ....... . .. �� ,. ................. _.. m, ...e..�� ....... .. .,.. a 100 � � � Q. 80 _— ._.�.�'' � .. ..._ .......�. . .� .�.�mP.� _��.��.�_.. i O m a 6o M�.._ ��._........._. . ....�. � �_.._ �� ..�... . .......�_. .�� d C940 ��.... ..._.... _. ' _.m. .��_... .._�� .�...w .�. ,� ' � 0 20 ..u_. �.. .... _........... ..� � � e 0 � 0 100 200 300 400 500 Dlstance (ft) COMP�IANCE CONC�USION According to the FCC, the MPE limit has been constructed in such a manner that continuous human exposure to RF emissions up to and including 100 percent of the MPE limit is acceptable and safe. The analysis in this case shows that at street level around the site the maximum calculated RF level from the combination of proposed and existing antenna operations is 6.3986 percent of the FCC general population MPE – well below the 100-percent reference for compliance. In other words, the worst-case calculated RF level around the site is more than 15 times below the limit considered safe for continuous human exposure to the RF emissions from antennas. The results of the analysis demonstrates compliance with the FCC regulations and associated guidelines on compliance. Moreover, because of the extremely conservative calculation methodology and operational assumptions we applied in the analysis, RF levels actually caused by the antennas will be significantly lower than the calculation results here indicate. 12 CERTI FICATION The undersigned certifies as follows: 1. I have read and fully understand the FCC regulations concerning RF safety and the control of human exposure to RF fields (47 CFR 1.1301 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 RF compliance provided herein is consistent with the applicable FCC regulations, additional guidelines issued by the FCC, and industry practice. 4. The results of the analysis indicate that the antenna operations at the subject site will be in compliance with the FCC regulations concerning RF exposure. 3/15/16 I��r�u J, �`�Ilins Date Chief ��:f�nical Officer 13 AppENdix A. BAckcRouNd oN rNE FCC MPE LiMiT FCC Rules and Regulations As directed by the Telecommunications Act of 1996, the FCC has established limits for maximum continuous human exposure to RF fields. 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 formulating 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 1.301 et seq of its Rules and Regulations (47 CFR 1.1301-1.1310). Those guidelines specify MPE limits for both occupational and general population 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 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 on the next page lists the FCC limits for both occupational and general population exposures, using the mW/cmz reference, for the different radio frequency ranges. 14 Frequency Range(F) Occupational Exposure General Public Exposure (MHz) (mWlcmz) (mWlcmz) 0.3 - 1.34 100 100 1.34 - 3.0 100 180 / Fz 3.0 - 30 900 / F2 180/ F2 30 - 300 1.0 0.2 300 - 1,500 F / 300 F / 1500 1,500 - 100,000 5.0 1.0 The diagram below provides a graphical illustration of both the FCC's occupational and general population MPE limits. Power Density (mW/cm2) 100 Occupational ,. e ,. � � ` `"��"`�"`�"` General Public � � , 0. w k 0. 5A ` A, e W r �y � k "� 1.0 ` � � ,��.�_n.�.....__m.... , , z , � r ry r A ✓ r +^ � � �.2 �,.�. �'��..�,.w.�._:.�_..........,��_......�d+'. ,r I .. � ........ � ...... 4 I U . l 0.3 1.34 3.0 30 300 1,500 100,000 Frequency(MHz) Because the FCC's MPE limits are frequency-shaped, the exact MPE limits applicable to the instant situation depend on the frequency range used by the systems of interest. 15 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. Note that the FCC "categorically excludes" certain types of antenna facilities from the routine requirement to specifically (i.e., mathematically) demonstrate compliance with the MPE limit. Among those types of facilities are cellular antennas mounted on any type of tower, when the bottoms of the antennas are more than 10 meters (c. 32.8 feet) above ground. The basis for the categorical exclusion, according to the FCC, is the understanding that because of the low power and the directionality of the antennas, such facilities — individually and collectively — are well understood to have no significant effect on the human environment. As a result, the FCC automatically deems such facilities to be in compliance. In addition, FCC Rules and Regulations Section 1.1307(b)(3) describes a provision known in the industry as "the 5% rule". It describes that when a specific location — like a spot on a rooftop — is subject to an overall exposure level exceeding the applicable MPE limit, operators with antennas whose MPE% contributions at the point of interest are less than 5% are exempted from the obligation otherwise shared by all operators to bring the site into compliance, and those antennas are automatically deemed by the FCC to satisfy the rooftop compliance requirement. FCC References on Compliance 47 CFR, FCC Rules and Regulations, Part 1 (Practice and Procedure), Section 1.1310 (Radiofrequency radiation exposure limits). FCC Second Memorandum Opinion and Order and Notice of Proposed Rulemaking (FCC 97-303), In the Matfer of Procedures for Reviewing Requests for Relief From Sfafe and Local Regulations Pursuanf fo Section 332(c)(7)(8)(v) of fhe Communications Act of 1934 (WT Docket 97-192), Guidelines for Evaluating fhe Environmental Effects of Radiofrequency Radiation (ET Docket 93-62), and Petition for Rulemaking of fhe Cellular Telecommunications Industry Association Concerning Amendment of the Commission's Rules fo Preempf Stafe and Local Regulation of Commercial Mobile Radio Service Transmitting Facilities, released August 25, 1997. FCC First Memorandum Opinion and Order, ET Docket 93-62, In the Matfer of Guidelines for Evaluating the Environmental Effecfs of Radiofrequency Radiation, released December 24, 1996. 16 FCC Report and Order, ET Docket 93-62, In fhe Mafter of Guidelines for Evaluating the Environmenfal Effects of Radiofrequency Radiation, released August 1, 1996. FCC Office of Engineering and Technology (OET) Bulletin 65, "Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields", Edition 97-01, August 1997. 17 AppENdix B. SUMMARy OF EXPERT QUA�IFICATIONS Daniel J. Collins, Chief Technical Officer, Pinnacle Telecom Group, LLC ,. , ,, _. .�.�� Synopsis. •40+years of experience in all aspects of wireless system engineering, related regulation, and RF exposure • Has performed or led RF exposure compliance assessments ' on more than 20,000 antenna sites since the new FCC rules went into effect in 1997 • Has provided testimony as an RF compliance expert more than 1,500 times since 1997 • Have been accepted as an expert in New Jersey and more than 40 other��t��, as well as k�y the FCC � �, , �, . , B.E.E.,�Cit �Colle e of New � � �,, , ,. , Education: . � y g York (Sch. Of Eng.), 1971 � •M.B.A., 1982, Fairleigh Dickinson University, 1982 �wwwwwwww wwwwwwwww • Bronx Hts�h School of Sci�rn��, 1966 „IT_ITITITITIT� wwwwww_ Current Responsibilities: • Leads all PTG staff work involving RF safety and FCC compliance, microwave and satellite system engineering, ...... . and consultin� on wireless technolo�y and re�ulation Prior Exper�ence: • Edwards & Kelcey, VP— RF Engineering and Chief Information Technology Officer, 1996-99 • Bellcore, Executive Director— Regulation and Public Policy, 1983-96 •AT&T(Corp. HQ), Director—Spectrum Management Policy and Practice, 1977-83 •AT&T Long Lines, Group Supervisor—Microwave Radio . ..... System Desiqn, 1972-77 S ec�fic RF Safef /�mmmmmmmm�mm WWWWW �w. Involved in RF ex osure ma mm�m�mmmmmmmmm�mmm p � Y p tters since 1972 Compliance Experience: . Have had lead corporate responsibility for RF safety and compliance at AT&T, Bellcore, Edwards & Kelcey, and PTG •While at AT&T, helped develop the mathematical models for predicting RF exposure • Have been relied on for compliance by all major wireless carriers, as well as by the federal government, several state and local governments, equipment manufacturers, system integrators, and other consultin�/en�ineering firms ��__.... ..._ ..... ___�� Ofher Background: •Author, Microwave System Engmeering(AT&T, 1974) •Co-author and executive editor, A Guide to New Technologies and Services(Bellcore, 1993) • National Spectrum Managers Association (NSMA)—former three-term President and Chairman of the Board of Directors; was founding member, twice-elected Vice President, a long-time member of the Board of Directors, and was named an NSMA Fellow in 1991 • Have ublished more than 35 articles in indust ma azines 18