An Engineer Looks At The RF Compliance Certification
A couple of months ago, our colleague (and renewal guru) Dan Kirkpatrick previewed the revised application (Form 303-S) that broadcasters will be using in the current renewal cycle. Among the new aspects of the form that Dan addressed was the change in the RF compliance certification. Now our friend Kevin Fisher, of Smith and Fisher (the long-time communications engineering firm that bears his name), has written a post on the S&F blog providing an engineer’s perspective on some of the nitty-gritty details involved in compliance with RF exposure limits. If you happen to share space with other RF users on a single tower (or find yourself in a cluster of communications towers), you’ll probably find Kevin’s observations – which you can find here – interesting.
This new form 303-S would appear to be in conflict with Section 1.1307(b)(3) of the FCC Rules, which provides a safe harbor for a broadcast station that is, by itself, 5% or less of its applicable RF exposure limit.
This important safe harbor was the result of a November 3, 1988, Request for Declaratory Ruling by Hammett & Edison, Inc., Consulting Engineers. The safe harbor was adopted in the December 20, 1989, General Docket 88-469 R&O. Although H&E had asked for a 5% safe harbor, that R&O only adopted a 1% safe harbor, because of objections to a 5% safe harbor by EPA. However, in the August 25, 1997, ET Docket 93-62 Second MO&O, the Commission increased the safe harbor threshold to 5% (i.e., the value originally requested by H&E).
Dane E. Ericksen, P.E.
Hammett & Edison, Inc.
Consulting Engineers
San Francisco