THE CGC COMMUNICATOR
                            CGC #528
                      Monday, July 29, 2002
                 Robert F. Gonsett, W6VR, Editor
     Copyright 2002, Communications General Corporation (CGC)
  In concluding this series on human exposure to radio-
frequency radiation ("RFR") and the Mt. Wilson RFR inspection
by the FCC in particular, it is important to revisit a few issues
and clarify some points.  We have also summarized or reproduced
more of the many letters received.  At the end of this newsletter,
you will once again be invited to submit your thoughts.
  Thank you for your many contributions in helping us put
this series together.
  With respect to the Sunset Ridge Incident (CGC #523 as
corrected and properly named in CGC #525), where a TV station
allegedly increased power while climbers were on a tower
structure, it is improper to assume (as some of our readers did)
that any of the climbers were overexposed to RF signals.  A
climber can momentarily be exposed to high RF fields, and yet
remain fully RFR compliant by time averaging the fields, as
authorized by the FCC's RFR rules.
  In this case, a climber's monitoring equipment might have
detected unusually high fields as he ascended or descended a
tower structure.  A normal reaction would be to move to a fully
compliant zone until the problem was resolved.  Again, it is
important to avoid making the assumption that an overexposure
occurred when so little is known about this case.
  Of course, the idea that anyone would knowingly increase
power while climbers are on a tower structure is outrageous,
and a number of our readers expressed their anger at the Sunset
Ridge incident.  John Ovalle of EMF Engineering put it simply:
"....To raise power, knowing that it will [might] harm someone,
should be considered a felony."
  The following information is from a southern California
broadcast engineer known to our office, and outlines another
attempt to "turn up the power with climbers on the tower."  This
incident reportedly happened a few years ago in the southern
part of our state.  In this case, a station General Manager
reportedly ordered that full power operation be resumed when
climbers were on a tower, but the engineer refused to do so,
and kept the power at the proscribed cutback level.  Nevertheless,
the incident left a mental scar, the engineer being outraged at
having been asked to commit an unconscionable act.
  Obviously, there are some important lessons to be learned
from power increase reports:  Make sure that all decision makers
associated with your station are aware of a power cutback in
advance, and make doubly sure they understand the absolute
necessity of maintaining the cutback while climbers are on a
tower structure.  This, of course, presupposes that adequate
advance notice is given for a cutback request.
  There needs to be some industry consensus on how much advance
notice of a cutback is reasonable, what form the notice is to
take, and what information is to be provided in the notice
including calculations (or prior agreements) in support of the
requested cutback figure.
  Another issue raised while covering the Mt. Wilson RFR
inspection by the FCC was the following quotation taken from
paragraph three of the anonymous letter featured in CGC #523:
  "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!""
  The last sentence quoted above was called to our attention
as being incorrect, and was investigated by our office.  Parties
close to the incident - on both sides of the aisle - disagreed
with the account.  They maintained that the requested power
reduction did occur, it occurred promptly and, to the best of
their knowledge, the power stayed down during the entire time
of the climb.
  CGC #523 reported that Steve Colley of KNBC(TV) is involved
in obtaining a new RFR report for Mt. Wilson, while CGC #526
mentioned that, "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."
  To make sure there is no misunderstanding as to who is doing
what in compiling the latest large-scale Mt. Wilson RFR study,
Steve Colley of KNBC is spearheading the overall effort to
generate a Request for Proposal ("RFP"), while a sub-committee
at KABC has been working on the Scope of Work component of the
  According to Steve, work on this project began May 17, 2002
- well in advance of the FCC's on-site inspection - and was
initiated at the suggestion of Andy Bater of Tribune.  Mount
Wilson's large RFR study is periodically updated in accordance
with good engineering practice.
                     A MATTER OF MICTURITION
  Returning now to the FCC's RFR inspection of publicly
accessible areas on Mt. Wilson, two readers expressed their
views on what might happen if the Commission issues a finding of
excessive RF fields.  One of these letters (written immediately
after Part I of our RFR series was published) is reproduced below:
  "As the former FCC/San Francisco supervisor of enforcement who
  frequently had to give hearing and court testimony on how such
  inspections were made and what the results mean, I'm curious to
  know who these inspectors were, what instruments were used, how
  the measurements were made, when the instruments were last
  calibrated and where, and what training they had in these
  specialized measurements.
  "As far as I know, the only two Registered Professional
  Employers on the staff of all the FCC offices in California are
  the two non-supervisory engineers in SF, both of whom were
  proteges of mine.
  "I can predict that if any Notices come out, there will be
  a large legal and technical micturition contest between the
  stations' hired guns and the Commish' and these issues will be
  in the forefront.  (Been there, went through it....)
  "I'm not concerned about who did or didn't make a complaint and
  I'm not involved with either side."
  Phil Kane - P.E./Esq. -  Beaverton (Washington County), OR
  A few writers and callers have suggested engineering changes
that could improve the RFR environment on Mt. Wilson.  Many (if
not all) of the ideas have been considered before, but perhaps
not in a public forum.  They are summarized below:
  * To avoid reduced power operation during tower climbing
    activity, install your aux antenna on a distant tower,
    and invite one of the users on that tower to put their
    aux antenna on your tower.
  * Further reduce RFR in public areas by expanding the use
    of reduced interbay spacings on antennas.
  * Elevate high powered/low elevation antennas.
  * Consider the use of highly elevated master antennas.
  CGC #525 noted that the term radiofrequency radiation
("RFR") too often triggers fatal images in the public's mind:
Images of atomic (ionizing) radiation and people "glowing in the
dark."  We asked if a better term could be used and a number of
Communicator readers submitted early comments, such as:
  "Originally, one variety of medical scanner was known as an
  "NMR" machine, for Nuclear Magnetic Resonance.  After this
  frightened many people, the industry quickly renamed the units
  Magnetic Resonance Imaging (MRI) machines.  Same machine,
  better name!
  "It's not enough for us to preach to the choir about ionizing
  and non-ionizing radiation.  Words have power, and "radiation"
  and its variants scare people. It's as simple as that."
  Andrew Ellis, KCBS/KLLC (views expressed are my own), SFO
  "In my practice advising governments about cellular/PCS RF
  issues, I routinely deal with the public.  It's guaranteed that
  if "RF radiation" is uttered in a public setting you'll find
  parents at the Planning Commission or City Council begging the
  officials not to allow <insert carrier name> to kill their
  "For years I've used "RF emission" in my presentations.  It
  accurately conveys the subject matter, but does not seem to
  alarm the public as does "RF radiation."  Also, I carefully
  avoid terms such as "illuminate" or "light up" for the same
  Jonathan Kramer, JD, W6JLK
  Considering these and other views expressed, possible
replacements for the term "radiofrequency radiation" are now
as follows:
  RFE - Radiofrequency energy
  RFE - Radiofrequency emissions
  RFE - Radiofrequency exposure
  RFF - Radiofrequency fields
  RFS - Radiofrequency signals
  Same as above, but with "EM" (for electromagnetic)
  replacing "RF."
  Comments on suitable replacement terms are welcome and sought,
particularly from individuals who have given public testimony.
                       A WEB SITE TO ASSIST
  "I've used this website as a reference many times that talks
about human exposure levels and sources.  It pertains to cellular
specifically but it is the best explanation of RFR and the effect
on humans I've ever read AND it is published by Dr. Moulder who
is not in the communications industry."
  Eric Kruzel
  Dr. Moulder is Professor of Radiation Oncology, Radiology
and Pharmacology/Toxicology at the Medical College of Wisconsin.
Dr. Moulder has taught, lectured and written on the biological
effects of non-ionizing radiation and electromagnetic fields
since the late 1970s.   -Ed.
                       SOMETHING TO PONDER
  One CGC Communicator reader asked why two RFR exposure
standards have been adopted by the FCC - one for the general
public (the "uncontrolled environment" standard) and one for
workers (the "controlled environment" standard).  If the
Commission considers 1.0 mW/square centimeters safe for workers
at 100 MHz, why is the public exposure standard five times
tougher to meet (0.2 mW/square centimeters)?
  This is an excellent question which reaches to the heart of RFR
standards setting work.  According to Ric Tell, who is an expert
in the RFR arena, just because a worker has some knowledge of RF
and some control over his position in the environment does not
make his body "more durable" against the effects of RF.
  I have taken the RFR rules seriously from day one and have
had the support of my company in assuring compliance.  I believe
we may be seeing some failures by even some of the largest
broadcasting companies to understand the seriousness of this
issue, and thus provide the support and funding necessary to the
local engineer to fulfill this obligation.
  John A. Buffaloe, Engineering Manager
  Jefferson Pilot Communications Co. of CA
  ....Until everyone in the industry recognizes the inherent
site safety hazards at both controlled and non-controlled sites,
mitigation methods and training requirements, the fines will be
a minor concern compared to the overall liability and risk.
  John MacFarlane  (Land-mobile radio industry)
  ....A benefit (perhaps the intended benefit) of all this
hoopla has been that the television stations currently doing
major work at Mount Wilson have taken positive steps to ensure
that all [affected] licensees on the mountain are made aware, well
in advance, of their intentions, that power reduction requests are
made and acknowledged in writing, and that there is accountability
at all steps of the process including verification that all
workers are in the clear after completion of work and prior to
restoration of full power.
                       YOUR TURN TO COMMENT
  After we received an avalanche of letters following the
publication of our first Special Report on the Mt. Wilson RFR
situation, we asked you to withhold further comments until
we could get our arms around this story.  Thanks for helping in
that regard.
  Now it is your turn to reply once again.  Please respond by
e-mail, keep all remarks to 200 words or less and let us know
if your name should be withheld from publication.
  If you need more than 200 words or wish to raise new issues,
post your comments on the web and provide us with a synopsis and
a URL, or send your comments to either of the publications listed
below.  They are working on RFR stories now.  We plan to publish
all accepted letters in the CGC Communicator this Wednesday
evening.  (Promotional material from vendors and RFR firms will
not be considered - sorry guys.)
  The publications working on RFR stories are as follows:
  Radio World: <radioworld@imaspub.com>, attention: Reader's Forum
  TV Technology magazine: <hayes@iptv.org>, attention Bill Hayes
  Paul McLane, Editor of Radio World, writes, "Please let your
readers know that Radio World welcomes their comments about RFR
and this [the Mt. Wilson RFR inspection] in particular."
  On July 10, an article on RFR and the FCC written by Bill
Hayes was published in TV Technology magazine on page 16, and
Bill plans to write more.  Bill says, "I believe we are just
seeing the beginning."
  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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