THE CGC COMMUNICATOR
                            CGC #523
                     Tuesday,  July 16, 2002
                 Robert F. Gonsett, W6VR, Editor
     Copyright 2002, Communications General Corporation (CGC)
  Human exposure to radiofrequency signals is in the news
again as the FCC conducts a surprise inspection on Mt. Wilson.
The issues uncovered will apply to many smaller communications
sites, so sit back and read this entire Special Report.
  The views expressed in the following Letter to the Editor
are those of the author and do not necessarily reflect the
views of CGC.  The author is an experienced broadcast engineer
known to CGC, and his or her name has been withheld upon request.
  Today [Friday, July 12, 2002], the FCC, in an unprecedented
move, shut down every Los Angeles FM and TV station operating
from Mt. Wilson in a surprise RF hazard inspection.
  The situation seems to have started a few weeks ago with the
attempted installation of a new antenna for station KDOC, CH-56.
KDOC is located in the ground floor of the building known as the
"Post Office."  The KDOC antenna was to be mounted on a 150' pole
[actually a 226' pole  -Ed.] directly West of the Post office.
  KDOC engineers had calculated the stations that needed to
reduce power and had sent out requests.  When it came time to
climb the pole, the tower crew found that the RF levels were
still too high.  They eventually found that the offending signal
was from an FM station that was not on the KDOC list of stations
that needed to reduce power.  The station's engineer was called
and asked to reduce power to 80%.  He was willing to comply but
was overruled by a corporate engineer saying, "I can't reduce
power while everyone is listening to my morning man!"  (Note that
the FCC order obliges stations to comply with requests to lower
power as a safety matter and without regard to ratings or revenue
issues.  The corporate engineer may not have known that he was
exposing his company to many thousands of dollars in fines.)
The FM station, after a week of negotiating, finally agreed to
  Yesterday, a team of six FCC "agents" arrived at Mt. Wilson.
Their first step was to perform a field intensity survey of their
own.  They located a site that, according to their instruments,
did not meet the safety levels for public access.  The site is
the KMEX driveway as it rises up behind KBIG and until it reaches
the KMEX building.  Since there has been considerable
construction in that driveway over the past few years, the gate
has long since disappeared.  Since there is no gate, the driveway
is publicly accessible and therefore in violation.  It would not
have been a violation if there had been a chain across the
driveway and a "No Trespassing" sign.
  Today, the FCC showed up ready to find out who was
responsible for that hot-spot in the driveway.  They had called
the Chief Engineers of every station to meet at Mt. Wilson at
12:00 noon....  They set up their meter at the hot-spot and then
asked each station to shut down completely, one-by-one, just long
enough to make another measurement.  Most stations were off for
from 20 seconds to 40 seconds.  This process actually took hours
to complete as communications was difficult between each
transmitter and the man taking the measurements.  The Fox-lot
stations were then asked to do the same thing for another hot-spot
over there.  After all of the measurements were done, everyone
met at the Mt. Wilson Pavilion to discuss the situation.
  The agents said that they were not able to review the
measurements in the field.  Once they were reviewed at the office,
there would be Notices of Violations and Notices of Liability
(fines.)  Many of the Chiefs felt that the stations exceeding the
limits would probably be a handful of close-by FMs.  The agents
then spent a considerable time explaining the rules and the FCC's
expectations.  They said that the rules have been in place for
several years now, and that they were no longer warning people,
but enforcing the law.  There was also a Q&A time.
  There was also considerable talk about a group of stations
joining to have a new, comprehensive field study done by a
qualified engineering firm.  Such studies are required for
licensees under the new rules.  The last time this was done was
in 1998 by Hammett & Edison.  While some stations have shown
little interest in joining the group, there is clearly a cost and
accuracy benefit in having as many stations as possible join the
group.  Perhaps this incident will change the minds of the
stations that show little interest.  They are still looking for
bids and there is not yet a cost estimate.  The contact is
Steve Colley: <Steve.Colley@nbc.com> or 818-840-3375.
  An FCC agent then explained that they were there on a regular
inspection and not as a result of some incident.  Most observers
there did not buy this.  The agents seemed to have arrived poorly
prepared for the inspections, as though they had been called to
Mt. Wilson at the last minute.  According to some who had spoken
to them on Thursday, they were very well aware of the KDOC
incident.  Perhaps they did not want to pursue the KDOC incident
but just make a statement that was loud and clear.  If so, their
statement was indeed loud and clear.  In any case, this incident
should alert us to the fact that we have a new responsibility
that cannot be ignored any longer.
  An advance copy of the above Letter to the Editor was
circulated to a few broadcast engineers for their comments and
opinions.  The opinions received are divided into two groups,
as follows.
  I think (the above story) pretty much sums things up.  It
will be very interesting to see what comes of this.  The inspector
would not give any indications of exactly what (the FCC) might do.
  - Radio Station Engineer
  Perhaps this is a technical point, but there has never been
a gate at the KMEX driveway as far as I know (back to at least
1984).  There's always been a chain there with a RF warning sign
on it, and there is another warning sign on the side of the KMEX-TV
building.  But alas, (when the FCC arrived) the chain was unlocked
and down.  And the sign was laying flat on the ground.
  It probably wasn't the KMEX folks that dropped the chain,
rather the tower folks dealing with KDOC.  That's only my guess.
The chain was up and locked the day before.  I (check the chain)
every time I can.
  - TV station engineer
  The fact that the FCC made a surprise inspection is not really
a surprise.  They have stated this would likely happen on several
occasions during that past 12 months.  Most recently, at the IWCE
convention in Las Vegas, in April, one of the FCC's Enforcement
Officers stated that we should not be surprised to see the issuance
of Notices of Violation and Notices of Liability during the
remaining part of the year as the FCC was gearing up to illustrate
some examples of violations of their RF rules.  The FCC did this
last year on Lookout Mountain west of Denver.
  - Consulting Radio Engineer
  Seems that a few broadcasters are not very enthusiastic about
human exposure to RF compliance issues.  When asked to reduce
power to facilitate tower work on Mt. Wilson, these excuses are
sometimes heard: "I'm unavailable that day" - "I'll be on vacation
then" - "How about if we reduce power from, say, 1 to 4 a.m.?"
  Since multiple stations may be involved in power cut backs
to permit tower work, sometimes it's a miracle any work gets done
at all.  One tower maintenance company complained that after a
power reduction was finally accomplished on Mt. Wilson, a TV GM
ordered his engineer to RESUME FULL POWER operation immediately.
Full power operation was resumed, without warning, and with
climbers on the tower structure!
  Obviously, too many people do not understand the absolute
necessity of cooperating and complying when it comes to human
exposure to RF signal issues.  Compliance with the FCC's exposure
rules is the law, and failure to comply could lead to serious
liability consequences, to say nothing of FCC sanctions.  Much
more could and probably should be said on this topic, and we
hope you will send us your thoughts.
  Written comments from broadcasting professionals on any
of the above issues are welcome, and invited.  Names will be
withheld if you ask us to do so.
  This forum is to identify problems and look toward solutions
in a generic sense, without pointing fingers at specific
individuals, stations or companies.  All meaningful comments
(please be concise) will be published together in an upcoming
Special Edition of the CGC Communicator.
  Let's pull together, learn from the Mt. Wilson incidents
and move on.
  The CGC Communicator is published for broadcast professionals
  in so. California by Communications General Corporation (CGC),
  consulting radio engineers, Fallbrook, CA.  Short news items
  without attached files are always welcome from our readers;
  letters may be edited for brevity.  E-mail may be sent to:
  rgonsett@ieee.org  or  telephone (760) 723-2700.
  CGC Communicator articles may be reproduced in any form provided
  they are unaltered and credit is given to Communications General
  Corporation and the originating authors, when named.  Past
  issues may be viewed and searched at http://www.bext.com/_CGC/
  courtesy of Bext Corporation.
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