HomeMy WebLinkAbout4981 Pole 158-1 Windemere Rd Regulatory Compliance Review 02.15.22DONALD L. HAES, JR., CHP
Radiation Safety Specialist
PO Box 198, Hampstead, NH 03841 617-680-6262 Email: donald_haes_chp@comcast.net
February 15, 2022
RE: Installation of antennas and associated equipment for the AT&T Mobility PWS “Small Cell”
facilities to be mounted on utility poles located within West Yarmouth, MA.
PURPOSE
I have reviewed the information pertinent to the proposed installations. To determine regulatory
compliance, theoretical calculations of maximal radio-frequency (RF) fields have been prepared. The
physical conditions are that AT&T Mobility proposes to install a cannister-styled personal wireless
services (PWS) antenna with remote radio head units (comprising a “Small Cell” (SC)) on utility poles
located within West Yarmouth, MA. See Table 2 and Figure 2 locations.
The theoretical calculations consider the contributions of the proposed AT&T Mobility PWS
transmitters (see Table 3) operating at their proposed FCC licensed capacity. The calculated RF field
values are presented as a percent of current Maximum Permissible Exposures (%MPE) as adopted by the
Federal Communications Commission (FCC),i,ii and those established by the Massachusetts Department
of Public Health (MDPH).iii
SUMMARY
This report is intended to provide written evidence that RF fields from the proposed AT&T
Mobility PWS facilities would comply with the FCC and MDPH RF exposure guidelines. The resulting
data indicate the summation of the proposed AT&T Mobility PWS RF contributions would be within the
established RF exposure guidelines in all accessible areas on the ground. The results in Figure 3 support
compliance with the pertinent sections of the Massachusetts Department of Public Health
regulations regarding PWS facilities, and the FCC’s guidelines for RF exposure.
Based on the results of the theoretical RF fields I have calculated; it is my expert opinion that these
facilities would comply with all regulatory guidelines for RF exposure with the proposed AT&T Mobility
antenna and transmitter installations.
Note: The analyses, conclusions and professional opinions are based upon the precise parameters and conditions for each site. AT&T MOBILITY PWS
facilities with model GQ2412-00613 antenna and 4449 and 4415 RRUs mounted on utility poles within West Yarmouth, MA. Utilization of these
analyses, conclusions, and professional opinions for any personal wireless services installation, existing or proposed, other than the aforementioned ha s not
been sanctioned by the author, and therefore should not be accepted as evidence of regulatory compliance.
Page 2 of 14
EXPOSURE LIMITS AND GUIDELINES
RF exposure guidelines enforced by the FCC were established by the Institute of Electrical and
Electronics Engineers (IEEE)iv and the National Council on Radiation Protection and Measurement
(NCRP).v The RF exposure guidelines are listed for RF workers and members of the public. The
applicable FCC RF exposure guidelines for the public are listed in Table 1 and depicted in Figure 1. All
listed values are intended to be averaged over any contiguous 30-minute period. The applicable exposure
limits for workers (the “controlled area”) are five times higher but averaged over any 6-minute period.
Table 1: Maximum Permissible Exposure (MPE) Values in Public Areas
Frequency Bands Electric Fields Magnetic Fields Equivalent Power
Density
0.3 – 1.34 MHz 614 (V/m) 1.63 (A/m) (100) mW/cm2
1.34 - 30 MHz 824/f (V/m) 2.19/f (A/m) (100) mW/cm2
30 - 300 MHz 27.5 (V/m) 0.073 (A/m) 0.2 mW/cm2
300 - 1500 MHz -- -- f/1500 mW/cm2
1500 - 100,000 MHz -- -- 1.0 mW/cm2
Figure 1: FCC Limits for Maximum Permissible Exposure (MPE)
NOTE: FCC 5% Rule – When the exposure limits are exceeded in an accessible area due to the emissions
from multiple fixed RF sources, actions necessary to bring the area into compliance are the shared
responsibility of all licensees whose RF sources produce, at the area in question, levels that exceed 5% of
the applicable exposure limit proportional to power. (Federal Register / Vol. 85, No. 63 / Wednesday,
April 1, 2020 / Rules and Regulations 18145).
Page 3 of 14
INTRODUCTORY INFORMATION: MAKING SENSE OF THE “G”S
There are many references to the so-called “generation” of wireless technologies in use. Each new
“generation” of wireless technologies has colloquially been designated a numbered “G.”1 The latest “G”
to come out, the fifth generation of wireless technologies or so called “5G”, has attracted extensive
research interest, both inside and outside the scientific community. According to the 3rd generation
partnership project,2 5G networks should support three major families of applications: (1) Enhanced
mobile broadband; (2) Machine type communications, and (3) Ultra-reliable and low-latency
communications. These situations require much more “connectivity” than the latest fourth generation (aka
“4G” or “Long Term Evolution (LTE)”) networks can manage. Thus, new networks must be able to handle
this high system throughput, in addition to supporting existing older technologies still in use. This is being
accomplished through additional spectrum assignments both higher and lower than currently assigned
frequencies used by PWS facilities. In fact, currently deployed 5G networks are operating at frequencies
once used by television stations.
Nonetheless, frequencies assigned by the FCC for 5G use are all within the bands currently under
regulatory oversight, including setting safe limits of exposure to RF energy for both workers, and members
of the public. Just recently (4/2020) the FCC has reaffirmed the efficacy of their regulatory exposure
limits to RF energy; including those for 5G. On another note, the premiere journal on matters associated
with radiation safety (The Health Physics Journal) has released an article on 5G: IEEE Committee on Man
and Radiation—COMAR Technical Information Statement: Health and Safety Issues Concerning
Exposure of the General Public to Electromagnetic Energy from 5G Wireless Communications Networks;
Bushberg, J.T.; Chou, C-K.; Foster, K.R.; Kavet, R.; Maxson, D.P.; Tell, R.A.; Ziskin, M.C.
From an RF safety standpoint, there is nothing peculiar about the fifth generation of wireless
technologies that would set it apart from any of the other advancements of technologies; including the
first two generations (first analog then digital communications), the third generation (the first to be referred
to a numbered-series as “3G”), and the currently deployed fourth generations (LTE). Recently published
studies in peer-reviewed journalsvi have shown typical exposures to RF energy from operating 5G systems
to be well-within the exposure limits.
The FCC currently has categories of devices operating in the Citizens Broadband Radio Service
(CBRS) 3.5 GHz band. Category A refers to a lower power base station, while B and C refer to CBSDs
that must be deployed outdoors and have increasingly higher maximum power limits.
1 PWS “Generations”: 1G: Analog voice; 2G: Digital voice; 3G: Mobile data; 4G: LTE and mobile Internet; 5G: Mobile
networks interconnect people, control machines, objects, and devices with multi-Gbps peak rates and ultra-low latency.
2 SOURCE: (https://www.3gpp.org/about-3gpp) The 3rd Generation Partnership Project (3GPP) unites [Seven]
telecommunications standard development organizations (ARIB, ATIS, CCSA, ETSI, TSDSI, TTA, TTC), known as
“Organizational Partners” and provides their member s with a stable environment to produce the Reports and Specifications
that define 3GPP technologies.
Page 4 of 14
PHYSICAL SITE LOCATIONS
The physical conditions are that AT&T Mobility proposes to install a cannister-styled personal
wireless services (PWS) antenna with remote radio head units on utility poles located within West
Yarmouth, MA. The proposed locations are listed in Table 2 and shown on Figure 2.
Table 2: Proposed Locations in West Yarmouth, MA
For AT&T PWS Small Cell Sites
AT&T
Site Name
Site Nearby
Street Address
Mounting
Centerline
Height
Transmitter
RRU Antenna
cRAN_RCTB_
MCAPE_109 11 Grove Street 30’ (1) 4449
(1) 4415 GQ2412-06613
cRAN_RCTB_
MCAPE_110 9 Windemere Road * 27’ (1) 4449
(1) 4415 GQ2412-06613
cRAN_RCTB_
MCAPE_111 21 Arlington Street 35’9” (1) 4449
(1) 4415 GQ2412-06613
cRAN_RCTB_
MCAPE_114
75 Massachusetts
Avenue 36’ (1) 4449
(1) 4415 GQ2412-06613
* Note lowest centerline mounting height AGL.
Figure 2: Proposed Locations for AT&T PWS SC Sites in West Yarmouth, MA
Page 5 of 14
THEORETICAL RF FIELD CALCULATIONS - GROUND LEVELS
EQUIPMENT INVENTORY
Table 3: Transmitter and Antenna Data and Supporting Parameters for
Theoretical Maximum RF Field Exposure Calculations- Ground Levels
Proposed AT&T PWS SC Sites in West Yarmouth, MA
Remote Radio Head Unit (RRH or RRU)
See Appendix A for Data
Antenna
See Appendix B for Energy Patterns
Model Frequency (MHz)†/
Technology
Tx Output
Power
(watts)‡
Manufacturer
/
Model
Gain
(dBd) ERP (watts)⁂
Centerline Height 27’ (lowest). AGL*
RRUS-4415 1930-1950 /
B25 PCS 40
Galtronics /
GQ2412-
00613
5.36 137.4
RRUS-4449
869-894 / B5 LTE 40 3.95 99.3
720-780 / B12 LTE 40 3.95 99.3
Table Notes
† Transmitter (Tx) Frequency: Central transmit frequency used to account for multiple channels.
‡ Maximum rated output power (per channel).
⁂ ERP: Effective Radiated Power; Equivalent Radiated Power; (ERP)
Personal Wireless Services (PWS) Technologies
LTE: Long Term Evolution (a.k.a. “4G”)
PCS: Personal Communication System
* Note on antenna mounting centerline height: The centerline height chosen for the
calculations was 27 feet AGL. Calculations for HIGHER centerline mounting heights with
identical RRUs and antenna for similar SC facilities would result in LOWER predicted RF
fields, hence LOWER potential RF exposures.
OBSERVATIONS IN CONSIDERATION WITH FCC RULES §1.1307(B) & §1.1310
Is it physically possible to stand next to or touch any omni-directional antenna? No, access to each
utility pole is restricted, and the utility companies will adhere to RF safety guidelines regarding potential
access to the proposed PWS antennas mounted on the poles.
Page 6 of 14
THEORETICAL RF FIELD CALCULATIONS - GROUND LEVELS
METHODOLOGY
These calculations are based on what are called "worst-case" estimates. That is, the estimates
assume 100% use of all transmitters simultaneously. Note that any losses along the horizontal direction
were neglected which means the results would be the maximum values in any direction. The resultant
values are thus conservative in that they over-predict actual resultant power densities. The data used to
prepare the theoretical RF field calculations are outlined in Table 3.
The calculations are based on the following information:
1. Effective Radiated Power (ERP) (See Table 3 and Appendix A data).
2. Antenna height (27’ (lowest) feet centerline, above ground level (AGL)). Simple trigonometry
was used to determine the resultant “RANGE,” and the antenna depression angles.
3. Antenna vertical energy patterns; the source of the negative gain (G) values. See Appendix B.
“Directional” antennas are designed to focus the RF signal, resulting in “patterns” of signal loss
and gain. Antenna vertical energy patterns display the loss of signal strength relative to the
direction of propagation due to elevation angle changes.
The magnitude of the RF field (the power density (S)) from an isotropic RF source is calculated
making use of the power density formula as outlined in FCC’s OET Bulletin 65, Edition 97-01: vii
S = P · G Where: P → Power to antenna (watts)
4 · π · R2 G → Gain of antenna
R → Distance (range) from antenna source to point of intersection
with the ground (feet)
R2 = (Height)2 + (Horizontal distance)2
Since: P · G = EIRP (Effective Isotropic Radiated Power), and for the situation of off-axis power
density calculations, apply the negative elevation gain (G E) value from the vertical energy patterns with
the following formula:
S = EIRP · G E
4 · π · R2
Ground reflections may add in-phase with the direct wave, and essentially double the electric field
intensity. Because power density is proportional to the square of the electric field, the power density may
increase by a factor of four (4). Since ERP is routinely used, convert ERP into EIRP by multiplying by
the factor of 1.64 (the gain of a ½-wave dipole relative to an isotropic radiator).
S = 4 · (ERP · 1.64) · G E = ERP · 1.64 · G E = 0.522 · ERP · G E
4 · π · R2 π · R2 R2
To calculate the % MPE, use the formula:
% MPE = S · 100
MPE
Page 7 of 14
THEORETICAL RF FIELD CALCULATIONS - GROUND LEVELS
RESULTS
The results of the theoretical Cumulative Maximum Percent MPE - vs. - Distance calculations are
shown in Figure 3 as plotted against linear distance from the base of the utility poles representing the
highest possible values along ANY direction. The values have been calculated for a height of six feet
above ground level in accordance with regulatory rationale. The calculated theoretical %MPE values are
plotted in comparison to the MPE of 100% for continuous exposure to members of the general public.
Figure 3: Theoretical Cumulative Maximum Percent MPE - vs. - Distance
Proposed AT&T PWS SC Sites in West Yarmouth, MA
Page 8 of 14
CONCLUSION
This report is intended to provide written evidence that RF fields from the proposed AT&T
Mobility PWS facilities would comply with the FCC and MDPH RF exposure guidelines. The resulting
data indicate the summation of the proposed AT&T Mobility PWS RF contributions would be within the
established RF exposure guidelines in all accessible areas on the ground. The results in Figure 3 support
compliance with the pertinent sections of the Massachusetts Department of Public Health
regulations regarding PWS facilities, and the FCC’s guidelines for RF exposure.
The number and duration of calls passing through PWS facilities cannot be accurately predicted.
Thus, to estimate the highest RF fields possible from operation of these installations, the maximal amount
of usage was considered. Even in this so-called "worst-case,” the resultant increase in RF field levels
would be far below established levels considered safe.
Based on the results of the theoretical RF fields I have calculated; it is my expert opinion that these
facilities would comply with all regulatory guidelines for RF exposure with the proposed AT&T Mobility
antenna and transmitter installations.
Feel free to contact me if you have any questions.
Sincerely,
Note: The analyses, conclusions and professional opinions are based upon the precise parameters and conditions for each site. AT&T MOBILITY PWS
facilities with model GQ2412-00613 antenna and 4449 and 4415 RRUs mounted on utility poles within West Yarmouth, MA. Utilization of these
analyses, conclusions, and professional opinions for any personal wireless services installation, existing or proposed, other than the aforementione d has not
been sanctioned by the author, and therefore should not be accepted as evidence of regulatory compliance.
Page 9 of 14
DONALD L. HAES, JR., CHP
Radiation Safety Specialist
PO Box 198, Hampstead, NH 03841 617 -680-6262 Email: donald_haes_chp@comcast.net
STATEMENT OF CERTIFICATION
1. I certify to the best of my knowledge and belief, the statements of fact contained in this report are
true and correct.
2. The reported analyses, opinions, and conclusions are limited only by the reported assumptions and
limiting conditions, and are personal, unbiased professional analyses, opinions, and conclusions.
3. I have no present or prospective interest in the property that is the subject of this report and I have
no personal interest or bias with respect to the parties involved.
4. My compensation is not contingent upon the reporting of a predetermined energy level or direction
in energy level that favors the cause of the client, the amount of energy level estimate, the
attainment of a stipulated result, or the occurrence of a subsequent event.
5. This assignment was not based on a requested minimum environmental energy level or specific
power density.
6. My compensation is not contingent on an action or event resulting from the analyses, opinions, or
conclusions in, or the use of, this report.
7. The consultant has accepted this assessment assignment having the knowledge and experience
necessary to complete the assignment competently.
8. My analyses, opinions, and conclusions were developed, and this report has been prepared, in
conformity with the American Board of Health Physics (ABHP) statements of standards of
professional responsibility for Certified Health Physicists.
Date: February 15, 2022
Page 10 of 14
DONALD L. HAES, JR., CHP
Radiation Safety Specialist
PO Box 198, Hampstead, NH 03841 617-680-6262 Email: donald_haes_chp@comcast.net
SUMMARY OF QUALIFICATIONS
• Academic Training -
o Graduated from Chelmsford High School, Chelmsford, MA; June 1973.
o Completed Naval Nuclear Naval Nuclear Power School, 6-12/1976.
o Completed Naval Nuclear Reactor Plant Mechanical Operator and Engineering Laboratory
Technician (ELT) schools and qualifications, Prototype Training Unit, Knolls Atomic Power
Laboratory, Windsor, Connecticut, 1-9/1977.
o Graduated Magna Cum Laude from University of Lowell with a Bachelor of Science Degree in
Radiological Health Physics; 5/1987.
o Graduated from University of Lowell with a Master of Science Degree in Radiological Sciences
and Protection; 5/1988.
• Certification -
o Board Certified by the American Board of Health Physics 1994; renewed 1998, 2002, 2006,
2010, 2014, and 2018. Expiration 12/31/2022.
o Board Certified by the Board of Laser Safety 2008; renewed 2011, 2014, 2017, 2020. Expiration
12/31/2023.
• Employment History -
o Consulting Health Physicist; Ionizing/Nonionizing Radiation, 1988 - present.
o Radiation, RF and Laser Safety Officer; BAE Systems, 2005–2018 (retired).
o Assistant Radiation Safety Officer; MIT, 1988 – 2005 (retired).
o Radiopharmaceutical Production Supervisor - DuPont/NEN, 1981 – 1988 (retired).
o United States Navy; Nuclear Power Qualifications, 1975 – 1981 (Honorably Discharged).
• Professional Societies -
o Health Physics Society [HPS].
o American Academy of Health Physics [AAHP]
o Institute of Electrical and Electronics Engineers [IEEE];
o International Committee on Electromagnetic Safety [ICES] (ANSI C95 series).
o Laser Institute of America [LIA].
o Board of Laser Safety [BLS].
o American National Standards Institute Accredited Standards Committee [ASC Z136].
o Committee on Man and Radiation [COMAR].
Page 11 of 14
APPENDIX A
SPECIFIC REMOTE RADIO HEAD UNITS
RRU RRUS-4415 / B25
Page 12 of 14
RRU RRUS-4449 / B2/B12
Page 13 of 14
APPENDIX B
ANTENNA SPECIFICATIONS & ENERGY PATTERNS
GALTRONICS / GQ2412-00613
Page 14 of 14
REFERENCES
i. Federal Register, Federal Communications Commission Rules; Radiofrequency radiation;
environmental effects evaluation guidelines Volume 1, No. 153, 41006-41199, August 7, 1996. (47 CFR
Part 1; Federal Communications Commission).
ii. Telecommunications Act of 1996, 47 USC; Second Session of the 104th Congress of the United States
of America, January 3, 1996.
iii. 105 CMR 122.000: Massachusetts Department of Public Health, Non-Ionizing Radiation Limits for:
The General Public from Non-Occupational Exposure to Electromagnetic Fields, Employees from
Occupational Exposure to Electromagnetic Fields, and Exposure from Microwave Ovens.
iv. IEEE C95.1-1999: American National Standard, Safety levels with respect to human exposure to radio
frequency electromagnetic fields, from 3 kHz to 300 GHz (Updated in 2020 as C95.1-2019/Cor 2-2020™
Standard for Safety Levels with Respect to Human Exposure to Electric, Magnetic, and Electromagnetic
Fields, 0 Hz to 300 GHz, Corrigenda 2).
v. National Council on Radiation Protection and Measurements (NCRP); Biological Effects and Exposure
Criteria for Radiofrequency Electromagnetic Fields, NCRP Report 86, 1986.
vi. Jamshed, Muhammad Ali (Institute of Communication Systems (ICS), Home of 5G Innovation entre
(5GIC), University of Surrey, Guildford GU2 7XH, UK). Electro-magnetic field exposure
reduction/avoidance for the next generations of wireless communication systems. IEEE Journal of
Electromagnetics, RF, And Microwaves in Medicine and Biology, Vol. 4, No. 1, March 2020.
vii. OET Bulletin 65: Federal Communications Commission Office of Engineering and Technology,
Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic
Fields; Edition 97-01, August 1999.