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                      THE CGC COMMUNICATOR
                            CGC #526
                      Monday, July 22, 2002
                 Robert F. Gonsett, W6VR, Editor
     Copyright 2002, Communications General Corporation (CGC)
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  SPECIAL REPORT -  RFR - PART III
  Instead of publishing extracts from the many Letters to the
Editor concerning Part I of our Mt. Wilson RFR series at this
time, there is a change of plans.  Jerry Ulcek, the FCC's point-
man when it comes to human exposure to RF compliance issues in
the field, has provided some new and useful information, and we
thought it might be productive to present some RFR background
material as well.
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                    COOPERATION IS THE KEY
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  It is important to realize that COOPERATION between FCC
licensees is the key to resolving a vast number of RFR problems.
Take power reductions required for tower work, for example.  It
is far better to work out mutually-acceptable power cut-back
schedules with other stations - even if not optimum  - than to
have the FCC dictate the terms of the cut-backs.  The following
letter from one of our readers illustrates this point:
  ______
  "Just a thought, this most likely would not happen,
  but being retired from the military I have seen situations
  where people refused to cooperate and the end result was
  always the same: Shut down everything while people are
  working in or around high RF areas.  I know that we are not
  on a ship, but the same applies.  On a ship when people are
  working around the transmitting areas ALL transmitting equipment
  would have to be shut down no matter what.  It would be a
  shame if that is what it had to come to in order to do tower
  work, having a FCC rep there and ordering everything shut down
  ...."
  Richard Kidder, KMPH Engineering, Fresno, CA
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       IMPORTANT FCC PROVISIONS ON OCCUPATIONAL RFR SAFETY
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  The FCC has made its position with regard to occupational
RFR exposure clear and direct:
  "It has come to our attention that some licensees either may
  not understand their responsibilities or may not be diligent in
  protecting humans from excessive RF radiation, particularly in
  cases where maintenance and repair work must be performed on or
  near antennas, tuning elements and transmitters.  The obligation
  to protect humans from excessive RF radiation does not permit
  any exceptions.  If, for example, it is necessary that a tower
  crew work on or near an antenna, the power to the antenna must
  be reduced for as much and as long as necessary to avoid
  exposing the tower crew to RF radiation in excess of the ANSI
  guidelines. The licensee may not refuse to reduce the power on
  the grounds that it could result in a temporary LOSS OF AUDIENCE
  OR ADVERTISING REVENUE [emphasis added].  Further, the licensee
  may not avoid complying with the ANSI guidelines even if a
  particular tower crew is willing to accept high RF exposure
  levels."
  [FCC Public Notice of August 19, 1992 (as cited in footnote
  33 of OET-65), paragraph 3.  The Notice goes on to apply joint
  responsibility for RFR compliance to multiple licensees at
  multi-user sites.  A copy of the complete Notice is available
  to any of CGC's regular clients by fax at no charge.]
  The Commission has further stated its position on the
  occupational exposure issue in Appendix B of OET-65 by saying,
  "Legal releases signed by workers willing to accept high
  exposure levels are not acceptable and may not be used in lieu
  of corrective measures."
  The operators on Mt. Wilson are by and large familiar with
these requirements and deal with them in a professional manner.
However, many of our readers occupy smaller sites where RFR
compliance needs to be taken much more seriously, especially now
that the FCC is hot on the trail of rule violators.  (Some
writers maintain that, as a group, land-mobile operators are
particularly lax when it comes to RFR compliance.)
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                    LETTER FROM JERRY ULCEK
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  CGC #525 presented some hypothetical situations which FCC's
Jerry Ulcek has answered as follows:
  CGC:  [If you see suspicious tower climbing activity where
  RF over exposures are likely to occur,] consider approaching
  the crew chief and ask to see and discuss his or her RFR safety
  plan, and the power cut-back call list.  Perhaps the chief
  knows nothing about RFR compliance, but would be willing to
  learn and cooperate.
  ULCEK:  "I strongly agree with this, especially if you know
  that the climber is being illuminated by your antenna and you
  have not been contacted with regard to powering down.  If there
  is a reasonable prospect that a tower climber is being
  overexposed to RF, we will look into the facts behind the
  incident and see which licensees are involved and see what type
  of policies were in place by each of the licensees involved to
  protect tower climbers.  Licensees are in violation if they
  knowingly allow tower climbers on a tower without proper
  precautions such as but not limited to: power reduction
  agreements, personal monitors, RF protective suits, etc.
  Even if a tower climber says he doesn't need these precautions,
  the licensees are still responsible and required to comply
  with the FCC's limits."
  ___
  CGC: If you [observe suspicious tower climbing activity or
  are having problems in obtaining power cut-backs and] need to
  contact someone on the outside, would the FCC be the best party
  to call?  Specifically who should be called, and will they
  respond promptly?  Would it ever be appropriate to contact OSHA?
  ULCEK: "If you have already made contact with the tower
  climber and/or crew chief, go to the licensee that hired them
  next.  If your request is not honored or cooperation is not
  gained from another licensee(s) or the tower climber, then
  call me and I will personally address the uncooperative station
  engineer or General Manager immediately if need be.  For those
  that want my contact information, email me individually at:
  <julcek@fcc.gov> and I will email you this information.
  "OSHA could also be contacted, but their jurisdiction would
  be over the employer of the tower climber in this situation
  which more than likely would not be the licensee unless of
  course the licensee has people on staff that perform tower
  work.  I can also email those individuals that are interested
  in an OSHA contact for RF Safety."
  ___
  Mr. Ulcek works with major RFR violation issues, and his
phone number/s are handed out only to those with a need to
know.  If Mrs. Jones is upset about a 300' cellular tower down
the road from her home (producing 0.001 mW/square centimeter
on her doorstep), have her call the FCC's public contact
number: 888-CALL-FCC (225-5322) or, for the deaf, 888-TELL-FCC
(835-5322).
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    THE FCC INSPECTED MT. WILSON ON AT LEAST TWO DAYS, NOT ONE
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  The FCC will not discuss the details of the Mt. Wilson RFR
inspection while their investigation is pending.  However, CGC
Communicator readers indicate that an FCC inspection team visited
Mt. Wilson on Thursday, July 11, 2002, prior to calling the
broadcasters together the following day for power-off tests.
One reader wrote as follows:
  "Thursday, a preliminary and cursory walk around on the public
roads, then if any access to fenced areas (gates, fences, chains,
etc.) were open, the [FCC] team moved to and about the areas that
would be accessible to the public and made more discriminating
measurements [and took photos]....  They notified us that any gate
open to public access would be traveled.  [The KMEX chain was
down, the inspectors were up the driveway when we found them at
one point in the day.  Promptly, one of the Mt. Wilson engineers]
added chain and locked it, added new RFR sign....  [The FCC also]
took pictures and notes of readings on the roadway near the Telco
bldg., up past the water tank down to KNBC...."
  The point here is that the FCC may visit your site
unannounced, at any time, and wander around.  You may not have a
breathing spell to lock a gate or post a warning sign until
after their camera shutter has clicked.  Make sure your site is
RFR compliant today.
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      THE MT. WILSON OPERATORS ARE PRO-ACTIVE ON RFR ISSUES
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  In preparing our newsletters on the Mt. Wilson RFR
situation, we have candidly presented some critical issues
without "naming names" or looking to prosecute individuals,
stations or companies for various misdeeds, real or inferred.
Rather, we have made every attempt to present factual information
in such a way that we can all learn from the present state of
affairs, and move forward productively.
  It is inevitable that some tower climbers and members of the
general public will develop cancer and other dreaded diseases in
the years ahead, and clever lawyers may then ask, "What factors
in your life might have contributed to your most unfortunate
condition?"  Ultimately, lawsuits for allegations of over-
exposure to RF signals could impact our industry; that is
another reason why every step must be taken now to guard against
over-exposure incidents.
  Mt. Wilson is one of the largest broadcast transmission
facilities in the United States, and the site supports a
considerable number of land-mobile and point-to-point microwave
radios as well.  The Mt. Wilson users have by and large been
leaders in the RFR compliance field, and have commissioned
various studies - involving both theoretical and measured data
- though the years.
  As we go to press, KABC-TV is putting the finishing touches
on (or has just completed) a Scope of Work that will become part
of a Request for Proposal for Mt. Wilson's next comprehensive
RFR study.  If history repeats itself, many of the Wilson users
will "buy into" and financially support the new study.  RFR
compliance is an ongoing job.
  While these special edition CGC Communicator newsletters have
discussed FCC-related RFR issues, it is important to keep in
mind that OSHA and CAL-OSHA have their own ideas about worker
safety.  Concepts like "lock-out/tag-out" and the use of RF Safety
Officers will be left to the trade journals.  We can't do it all
in our little newsletter, as much as we wish we could.
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                     AN RFR SUCCESS STORY
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  Nothing like a bit of good news.  Here is a letter from a
CGC Communicator reader who was completing a new transmitter
installation for KPFK(FM) when FCC inspectors appeared.  KPFK
is the most powerful FM station on Mt. Wilson at 112 kW ERP (not
a mere 110 kW as the current FCC CDBS database reflects).  The
letter reads as follows:
  ".... On Thursday, July 11, we greeted the FCC inspectors
  who were on Mt. Wilson, and provided a tour of the new KPFK
  facility.  The ground level NIER readings for KPFK, KMZT and
  KLVE combined resulted in a very happy outcome for us, with the
  readings at .014 [mW/square centimeter] (public standard is .2).
  When the FCC inspectors made the readings, they were actually
  surprised how low the levels were, considering how much power
  KPFK alone was pushing.  At this point, I am real happy with my
  decision to go with .9 lambda interbay spacing, as it seems to
  work well beyond my expectations.  Because KMZT and KLVE are
  also using reduced interbay spacing, the ground level NIER is
  quite low...."
  Don Mussell, Consulting Radio Engineer
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                           STAY TUNED
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  PLEASE SAVE YOUR COMMENTS
  Once again, please hold your comments for now.  We are not
far from the finish line in this Special Report series, and once
finished you will have an opportunity to comment on the complete
record.  Thanks for waiting.
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  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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