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Consulting and Engineering Services
Antenna Site FCC Compliance Assessment and Report
Site NY61XC174B Our Lady Star of the Sea 5411 Amboy Road Staten Island, NY
January 22, 2009
14 Ridgedale Avenue - Suite 209 • Cedar Knolls, NJ 07927 • 973-451-1630
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Executive Summary Overview Site Description Measurement Equipment and Procedure Measurement Results Compliance Conclusion Certification
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Appendix A. Site Photographs Appendix B. Background on the FCC MPE Limit Appendix C. Summary of Expert Qualifications
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On January 10, 2009, Pinnacle Telecom Group (“PTG”) performed on-site measurements of radiofrequency (RF) levels associated with a Sprint wireless base station antenna operation located at 5411 Amboy Road, Staten Island, NY. The site is the Our Lady Star of the Sea School and Church. Sprint refers to the site by the code “NY61XC174B” and its directional panel antennas are mounted on the roof of the gymnasium area of the school.
The purpose of the measurements was to assess and document compliance with the applicable Federal Communications Commission (FCC) limit for maximum permissible exposure (MPE) of the general public to the RF emissions from antennas.
Measurements were performed on the school grounds as well as inside the school. The equipment used to perform the measurements automatically
registers the effects from all RF sources in the area, not just the Sprint antennas.
The results of the measurements – expressed as simple percentages of the FCC MPE limit – were as follows: •
On the school grounds, the highest measured RF level was 1.5 percent of the FCC MPE limit; in other words, the highest RF level is 66 times below the FCC limit.
Inside the school, the highest measured RF level was 2.5 percent of the FCC MPE limit; in other words, the highest RF level is 40 times below the FCC limit.
The results of the measurements demonstrate compliance with the FCC limit. In addition, an “on/off” test was performed to assess whether the RF effects from the Sprint antennas were incrementally significant. The result of that test
demonstrated that there were no measurable differences in the RF levels with the Sprint transmitters turned “on” versus turned “off”.
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On-site RF measurements were performed at the subject site to assess and document compliance with the FCC MPE limit to the RF emissions from the antennas. The MPE limit in question applies to “uncontrolled” exposure of the general public – what the FCC terms the “general population MPE limit”.
At the time the measurements were taken, a new church was under construction, replacing the older church, on which had been cellular base station antenna operations for other wireless service providers. These operations have been relocated to two nearby buildings on Huguenot Street, immediately west of the school property (approximately 230 feet from the school). The new church is in the same location as the old church.
Measurements of RF levels were taken on the grounds of the property around the school building, as well as inside the school in the classrooms, the corridors and the gymnasiums.
The results of a compliance assessment can be described in layman’s terms by expressing the measured RF levels as simple percentages of the FCC MPE limit. If the normalized reference for that limit is 100 percent, then measured RF levels higher than 100 percent indicate the MPE limit is exceeded and there is a need to mitigate the potential exposure. On the other hand, measured RF levels
consistently below 100 percent serve as a clear and sufficient demonstration of compliance with the MPE limit.
The measurement equipment used by PTG provides automatic readouts of the RF levels as percentages of the FCC’s limit. The equipment is “broadband”, covering a frequency range from 300 kHz to 50 GHz, and reflects the frequencyshaping of the FCC’s MPE limit (i.e., the different MPE values applicable to different frequency ranges – see Appendix B). The measurement results
automatically reflect the cumulative effects of all RF sources in the area, not just the antennas that may be the intended subject of the compliance demonstration.
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At the specific request of Sprint’s landlord, Our Lady Star of the Sea, Stewart Maurer, Ph.D. and Professional Engineer, performed measurements at the same time, in the same areas of interest, and under the same conditions. The
measurement equipment used by Dr. Maurer reported RF levels in the form of “raw” field strength (volts/meter), and the equipment was not sensitive to the frequency-shaped nature of the FCC MPE limit. Nevertheless, Dr. Maurer
agreed that his measurement results demonstrated compliance, and by comfortable margins. We understand Dr. Maurer will be issuing a separate
report describing the results of his measurements and the related compliance analysis.
The remainder of this report provides information on the site, a description of the measurement equipment and procedure, the results of the measurement in each area of interest, and an analysis of those results with respect to FCC compliance. In addition, three appendices are included. Appendix A provides photographs of the site. Appendix B provides background on the FCC MPE limit, along with a list of references on compliance. Appendix C provides a summary of the expert qualifications of the individual certifying FCC compliance for the subject antenna site.
Sprint operates directional panel antennas at the site, arrayed in three sectors with each sector pointing in a different direction. The antennas are mounted on the roof of the school’s gymnasium areas, mounted at and above the parapet wall, facing away from the roof, approximately 34 feet above ground level.
During the site visit, we observed that there are other cellular antenna operations on the rooftops of two buildings west of the school property, approximately 230 feet from the school. The directional panel antennas are all mounted
approximately 30 feet above ground level.
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Measurement Equipment and Procedure
The RF measurements by PTG were performed using a Narda model 8722 RF probe and Narda model 8715 RF meter. Both the probe and meter are capable of broadband RF measurements, covering a range of 300 kHz to 50 GHz.
The equipment is calibrated by the manufacturer annually (as recommended), with the most recent calibration having been performed in September 2008.
Measurements of RF levels were performed in the accessible areas of interest around the site. The measurements were taken in a manner consistent with training provided by the equipment manufacturer, including the “RF Field Measurements for Antenna Sites” videotape, developed by Richard Tell Associates and included as part of the Narda equipment package.
The results of the measurements taken on the grounds of the school, expressed as a percentage of the FCC general population MPE limit, are overlaid on the aerial photograph of the site on the next page. The letters A, B and C overlaid on the upper center of the photograph depict the locations of the Sprint antennas on the roof of the school’s gymnasiums. The triangles overlaid on the lower left of the photograph depict the locations of the other nearby cellular antenna operations on the rooftops of two buildings adjacent to the school property.
Note that the photograph, taken from the “Google Earth” website, was taken before the Sprint antennas were on the site and while the old church (noted in the photo) still existed. The photograph does provide, though, a spatial reference for the site.
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Sprint antenna locations (A, B, & C)
0.5% 0.5% 0.5% 0.5% 0.5%
Nearby antenna sites (triangles)
The maximum measured RF level on the grounds around the school buildings, whether the base station antennas were on or off, was 1.5 percent of the FCC general population MPE limit, equivalent to 66 times below the limit.
Measurements of RF levels were also performed in various areas inside the school building. The results of these measurements are listed in the table on the next page that lists the locations where the measurements were taken and the maximum measured RF level in each area. Once again, the measurement
results are expressed as a percentage of the FCC general population MPE limit.
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Location inside school Room 118 Room 114 Room 109 Room 108 Room 107 O’Mara Hall Room 103 Room 102 Room 101 Kindergarten Classroom Pre-K Classroom World Trade Center Memorial Gym Lt. Paul Mitchell Gym School corridors
Maximum measured RF level 1.5% 1.5% 2.0% 2.0% 1.0% 1.5% 2.0% 2.0% 2.5% 2.0% 1.0% 1.0% 1.0% 1.0%
As indicated, the maximum measured RF level inside the school was 2.5 percent of the FCC general population MPE limit, equivalent to 40 times below the limit.
The results of the on-site measurements in all areas of interest showed that the RF levels were all below the 100-percent reference for MPE compliance.
The results of the measurements provide a clear demonstration that the Sprint antenna operation satisfies the FCC compliance requirements.
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The undersigned hereby 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. The equipment used to perform the RF measurements described herein is appropriate to the task, and calibration of its accuracy has been performed within the past 12 months as recommended by the manufacturer. 3. The on-site RF measurements described herein were performed in a manner consistent with industry standards. 4. To the best of my knowledge, the statements and information disclosed in this report are true, complete and accurate. 5. The analysis of site RF compliance provided herein is consistent with the applicable FCC regulations, additional guidelines issued by the FCC, and industry practice. 6. The results of the analysis indicate that the antenna operation at the subject site is in compliance with the FCC regulations concerning RF exposure.
Daniel J. Collins Chief Technical Officer Pinnacle Telecom Group, LLC
1/22/09 __________ Date
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Appendix A: Site Photographs
Shown below are photographs of the site taken on the day of the measurements.
Sprint Sector A
Sprint Sector B (right) and Sector C (left)
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Appendix B: Background on the FCC MPE Limit
As directed by the Telecommunications Act of 1996, the FCC has established a limit for maximum continuous human exposure to RF fields. The FCC maximum permissible exposure (MPE) limit 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 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. Continuous exposure at levels equal to or below the applicable MPE limits is considered to result in no adverse health effects on humans. 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/cm2 reference, for the different radio frequency ranges.
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Frequency Range (F) (MHz)
0.3 - 1.34 1.34 - 3.0 3.0 - 30 30 - 300 300 - 1,500 1,500 - 100,000
Occupational Exposure ( mW/cm2 )
100 100 900 / F2 1.0 F / 300 5.0
General Public Exposure ( mW/cm2 )
100 180 / F2 180 / F2 0.2 F / 1500 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 General Public
Because the FCC’s RF exposure limits are frequency-shaped, the exact MPE limits applicable to the instant situation depend on the frequency range used by the systems of interest. The most appropriate method of determining RF compliance is to assess the RF power density attributable to a particular system and compare that to the MPE
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limit applicable to the operating frequency in question. expressed as a percentage of the MPE limit.
The result is usually
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.
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 Matter of Procedures for Reviewing Requests for Relief From State and Local Regulations Pursuant to Section 332(c)(7)(B)(v) of the Communications Act of 1934 (WT Docket 97-192), Guidelines for Evaluating the Environmental Effects of Radiofrequency Radiation (ET Docket 93-62), and Petition for Rulemaking of the Cellular Telecommunications Industry Association Concerning Amendment of the Commission's Rules to Preempt State 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 Matter of Guidelines for Evaluating the Environmental Effects of Radiofrequency Radiation, released December 24, 1996. FCC Report and Order, ET Docket 93-62, In the Matter of Guidelines for Evaluating the Environmental 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. FCC Office of Engineering and Technology (OET) Bulletin 56, “Questions and Answers About Biological Effects and Potential Hazards of RF Radiation”, edition 4, August 1999. “RF Field Measurements for Antenna Sites”, (video), Richard Tell Associates Inc., 1997. “EME Awareness for Antenna Site Safety”, (video), Motorola (produced in association with Richard Tell Associates Inc.), 1997.
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Appendix C: Summary of Expert Qualifications
Daniel J. Collins, Chief Technical Officer, Pinnacle Telecom Group, LLC
Synopsis: • 36 years of experience in all aspects of wireless system engineering, related regulation, and RF exposure • Has performed or led FCC MPE compliance assessments on more than 12,000 antenna sites since the latest FCC regulations went into effect in 1997 • Has provided testimony as an FCC compliance expert more than 1,200 times since 1997 • Have been accepted as an expert in New York, New Jersey and more than 40 other states, as well as by the FCC • B.E.E., City College of New York (Sch. Of Eng.), 1971 • M.B.A., 1982, Fairleigh Dickinson University, 1982 • Bronx High School of Science, 1966 • lead all PTG staff work involving RF safety and FCC compliance, microwave and satellite system engineering, and consulting on wireless technology and regulation • 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 Design, 1972-77 • Involved in RF exposure matters since 1972 • 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 later adopted by the FCC 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 consulting / engineering firms • Author, Microwave System Engineering (AT&T, 1974) • Co-author and executive editor, A Guide to New Technologies and Services (Bellcore, 1993) • National Spectrum Managers Association (NSMA) – thriceelected President and chair of the Board of Directors; earlier was founding member, twice-elected Vice President, longtime member of the Board, and was named an NSMA Fellow in 1991 • Listed in Who’s Who in the Media and Communication and International Who’s Who in Information Technology • Published more than 35 articles in industry magazines
Specific RF Safety / Compliance Experience:
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