CGC #1182

by CGC on December 21, 2012

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                       THE CGC COMMUNICATOR

                            CGC #1182

                    Friday,  December 21, 2012

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                Robert F. Gonsett, W6VR,  Editor
                

    Copyright 2012, Communications General® Corporation (CGC)

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  A MODEST GIFT FROM THE FOREST SERVICE

  Richard Rudman, Ed Sogge and Bob Gonsett met with USDA
Forest Service ("FS") staff on August 10, 2012 and asked that
certain provisions of a key FS document be set aside.  Notably,
Appendix G of their Land Management Plan affecting the Angeles
(e.g. portions of Mt. Wilson), Cleveland (e.g. Santiago Peak),
Los Padres and San Bernardino National Forests contains a
number of technically objectionable provisions.  The provisions
were apparently designed in part to protect birds from strong
RF fields.

  Among the Appendix G requirements is that "all microwave
dishes" be radome covered and that would include those that do
not transmit signals, and even grid-type dishes that were never
designed to accommodate radomes.  Those dishes, if covered, would
be ripped off tower structures in heavy winds.  Another concern
is that wire-type anti-perching spike strips will eventually
generate RFI as the spikes corrode, become damaged, rub against
each other and arc.  Rudman, Sogge and Gonsett also questioned
the mandate that building roofs be partially equipped with anti-
perching devices.  What exactly is this intended to accomplish?
If anti-perching devices must be used, only RF-interference-free
devices should be allowed, and they should be of the type that
do not injure birds through a trail-and-error learning process.

  As a follow-up to the August meeting, Bob Gonsett called
Jake Rodriguez of the Cleveland National Forest on November 2,
2012 and found out that some progress had been made.  Rather than
using the very strict language of Appendix G, the Cleveland
agreed to use the more sensible language in the Site Plan (as
we had suggested) when it comes to the issue of radome covers.
Mr. Rodriguez confirmed the call in writing as follows:

  ______


  "Bob -- Thank you for the phone conversation today.
  Through that phone call I clarified that only radiating
  (transmitting) microwave dishes need to be covered on the
  Cleveland National Forest.  That statement is based on the
  following excerpt from Cleveland National Forest
  Communications Site Management Plans, in particular,
  I am quoting the Santiago Peak Plan:

  "Communications Site Management Plan, Santiago Peak section
  VIII. PLANNING INFORMATION, STANDARDS AND CRITERIA, part
  c. 8. a. [concerning microwave dishes]:

  "a.  All radiating parabolic dish antennas shall be equipped
  with a radome (cover) to prevent perching on the feedhorn
  within the near-radiating field.  This requirement is author-
  ized under Clause III. C. in the Forest Service communications
  use lease, which provides that the "Lessee will comply with
  applicable laws, for environmental protection."

  "Additionally, without commitments on either end, we
  briefly discussed the "possibility" of the communications
  site group funding a Forest Service Enterprise Team to
  facilitate an in-depth review, response, and if appropriate,
  amendment to the existing Communications Site Management
  Plans and Forest Land Management Plan.

  "I look forward to speaking more with you in the future."

  Jake Rodriguez
  Recreation & Lands Officer
  Trabuco Ranger District
  Cleveland National Forest

  ______


  The Cleveland National Forest's willingness to focus on
the Site Plan wording instead of the Appendix G provision that
requires "all microwave dishes" to be radome covered represents
solid progress in a complex proceeding.  Now, all non-radiating
dishes will be exempt from coverings, for the moment at least,
and in the Cleveland National Forest at least.  This means that
on Santiago Peak and other Cleveland sites, receive-only dishes
including receive-only satellite dishes will not require radomes.

  The next logical step is to ask the other National Forests
affected by Appendix G to adopt the same common sense reasoning.
On Mt. Wilson in particular, we believe that the Forest Service
should also drop the Appendix G stipulation that all new towers
be subject to a 199 foot height limitation.  The Wilson Site Plan
allows greater heights (and tower lighting is not required by
the FAA on those towers because of the unique circumstances at
Wilson).  Using taller towers has been an important Forest
Service philosophy that permits antennas to be consolidated
resulting in the deployment of fewer tower structures.

  After the holidays, we will undoubtedly consider the
appropriate next steps.  The progress that we make will
depend on a number of factors including the interest that
the communications stake holders show in amending Appendix G.
Without an amendment to that document, no long-term progress
is possible.  The Forest Service could, at any time, move to
revise its Site Plans to incorporate the Draconian provisions
of Appendix G and that would be a big step backward for all
parties involved.

  Special thanks to Jake Rodriguez and his associates for
taking the first step to bring reasoning and common sense
to the unrest created by Appendix G.  It will be interesting
to see what happens in 2013.

  http://tinyurl.com/ForestServiceAppendixG


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