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8/14/2019 Pinnacle Report
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Pinnacle Telecom GroupConsulting and Engineering Services
Antenna Site FCC ComplianceAssessment and Reportprepared forSprint
Site NY61XC174BOur Lady Star of the Sea5411 Amboy RoadStaten Island, NY
January 22, 2009
14 Ridgedale Avenue - Suite 209 Cedar Knolls, NJ 07927 973-451-1630
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Contents
Executive Summary 3Overview 4Site Description 5Measurement Equipment and Procedure 6Measurement Results 6Compliance Conclusion 8Certification 9
Appendix A. Site PhotographsAppendix B. Background on the FCC MPE LimitAppendix C. Summary of Expert Qualifications
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Executive SummaryOn January 10, 2009, Pinnacle Telecom Group (PTG) performed on-site
measurements of radiofrequency (RF) levels associated with a Sprint wireless
base station antenna operation located at 5411 Amboy Road, Staten Island, NY.
The site is the Our Lady Star of the Sea School and Church. Sprint refers to the
site by the code NY61XC174B and its directional panel antennas are mounted
on the roof of the gymnasium area of the school.
The purpose of the measurements was to assess and document compliance with
the applicable Federal Communications Commission (FCC) limit for maximum
permissible exposure (MPE) of the general public to the RF emissions from
antennas.
Measurements were performed on the school grounds as well as inside the
school. The equipment used to perform the measurements automatically
registers the effects from all RF sources in the area, not just the Sprint antennas.
The results of the measurements expressed as simple percentages of the FCC
MPE limit were as follows:
On the school grounds, the highest measured RF level was 1.5 percent of
the FCC MPE limit; in other words, the highest RF level is 66 times below
the FCC limit.
Inside the school, the highest measured RF level was 2.5 percent of the
FCC MPE limit; in other words, the highest RF level is 40 times below the
FCC limit.
The results of the measurements demonstrate compliance with the FCC limit. In
addition, an on/off test was performed to assess whether the RF effects from
the Sprint antennas were incrementally significant. The result of that test
demonstrated that there were no measurable differences in the RF levels with
the Sprint transmitters turned on versus turned off.
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OverviewOn-site RF measurements were performed at the subject site to assess and
document compliance with the FCC MPE limit to the RF emissions from the
antennas. The MPE limit in question applies to uncontrolled exposure of the
general public what the FCC terms the general population MPE limit.
At the time the measurements were taken, a new church was under construction,
replacing the older church, on which had been cellular base station antenna
operations for other wireless service providers. These operations have been
relocated to two nearby buildings on Huguenot Street, immediately west of the
school property (approximately 230 feet from the school). The new church is in
the same location as the old church.
Measurements of RF levels were taken on the grounds of the property around
the school building, as well as inside the school in the classrooms, the corridors
and the gymnasiums.
The results of a compliance assessment can be described in laymans terms by
expressing the measured RF levels as simple percentages of the FCC MPE limit.
If the normalized reference for that limit is 100 percent, then measured RF levels
higher than 100 percent indicate the MPE limit is exceeded and there is a need
to mitigate the potential exposure. On the other hand, measured RF levels
consistently below 100 percent serve as a clear and sufficient demonstration of
compliance with the MPE limit.
The measurement equipment used by PTG provides automatic readouts of the
RF levels as percentages of the FCCs limit. The equipment is broadband,
covering a frequency range from 300 kHz to 50 GHz, and reflects the frequency-
shaping of the FCCs MPE limit (i.e., the different MPE values applicable to
different frequency ranges see Appendix B). The measurement results
automatically reflect the cumulative effects of all RF sources in the area, not just
the antennas that may be the intended subject of the compliance demonstration.
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At the specific request of Sprints landlord, Our Lady Star of the Sea, Stewart
Maurer, Ph.D. and Professional Engineer, performed measurements at the same
time, in the same areas of interest, and under the same conditions. The
measurement equipment used by Dr. Maurer reported RF levels in the form of
raw field strength (volts/meter), and the equipment was not sensitive to the
frequency-shaped nature of the FCC MPE limit. Nevertheless, Dr. Maurer
agreed that his measurement results demonstrated compliance, and by
comfortable margins. We understand Dr. Maurer will be issuing a separate
report describing the results of his measurements and the related compliance
analysis.
The remainder of this report provides information on the site, a description of the
measurement equipment and procedure, the results of the measurement in each
area of interest, and an analysis of those results with respect to FCC compliance.
In addition, three appendices are included. Appendix A provides photographs of
the site. Appendix B provides background on the FCC MPE limit, along with a
list of references on compliance. Appendix C provides a summary of the expert
qualifications of the individual certifying FCC compliance for the subject antenna
site.
Site DescriptionSprint operates directional panel antennas at the site, arrayed in three sectors
with each sector pointing in a different direction. The antennas are mounted on
the roof of the schools gymnasium areas, mounted at and above the parapet
wall, facing away from the roof, approximately 34 feet above ground level.
During the site visit, we observed that there are other cellular antenna operationson the rooftops of two buildings west of the school property, approximately 230
feet from the school. The directional panel antennas are all mounted
approximately 30 feet above ground level.
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Measurement Equipment and ProcedureThe RF measurements by PTG were performed using a Narda model 8722 RF
probe and Narda model 8715 RF meter. Both the probe and meter are capable
of broadband RF measurements, covering a range of 300 kHz to 50 GHz.
The equipment is calibrated by the manufacturer annually (as recommended),
with the most recent calibration having been performed in September 2008.
Measurements of RF levels were performed in the accessible areas of interest
around the site. The measurements were taken in a manner consistent with
training provided by the equipment manufacturer, including the RF Field
Measurements for Antenna Sites videotape, developed by Richard Tell
Associates and included as part of the Narda equipment package.
Measurement ResultsThe results of the measurements taken on the grounds of the school, expressed
as a percentage of the FCC general population MPE limit, are overlaid on the
aerial photograph of the site on the next page. The letters A, B and C overlaid onthe upper center of the photograph depict the locations of the Sprint antennas on
the roof of the schools gymnasiums. The triangles overlaid on the lower left of
the photograph depict the locations of the other nearby cellular antenna
operations on the rooftops of two buildings adjacent to the school property.
Note that the photograph, taken from the Google Earth website, was taken
before the Sprint antennas were on the site and while the old church (noted in
the photo) still existed. The photograph does provide, though, a spatial referencefor the site.
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The maximum measured RF level on the grounds around the school buildings,
whether the base station antennas were on or off, was 1.5 percent of the FCC
general population MPE limit, equivalent to 66 times below the limit.
Measurements of RF levels were also performed in various areas inside the
school building. The results of these measurements are listed in the table on the
next page that lists the locations where the measurements were taken and themaximum measured RF level in each area. Once again, the measurement
results are expressed as a percentage of the FCC general population MPE limit.
1.0%5%
AB
C
1.5%
1.0%
0.5%
1.5%
0.5%
0.5%
0.5%
0.5%
1.5%
0.5%
0.5%
1.0%
1.5%
0.5%
0.5%0.5%
0.5%
Sprint antenna locations(A, B, & C)
Nearby antenna sites(triangles)
Church
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Location inside school Maximum measured RF level
Room 118 1.5%
Room 114 1.5%
Room 109 2.0%
Room 108 2.0%
Room 107 1.0%
OMara Hall 1.5%
Room 103 2.0%
Room 102 2.0%
Room 101 2.5%
Kindergarten Classroom 2.0%
Pre-K Classroom 1.0%
World Trade Center Memorial Gym 1.0%
Lt. Paul Mitchell Gym 1.0%
School corridors 1.0%
As indicated, the maximum measured RF level inside the school was 2.5 percent
of the FCC general population MPE limit, equivalent to 40 times below the limit.
Compliance ConclusionThe results of the on-site measurements in all areas of interest showed that the
RF levels were all below the 100-percent reference for MPE compliance.
The results of the measurements provide a clear demonstration that the Sprint
antenna operation satisfies the FCC compliance requirements.
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CertificationThe undersigned hereby certifies as follows:
1. I have read and fully understand the FCC regulations concerning RF safety
and the control of human exposure to RF fields (47 CFR 1.1301 et seq).
2. The equipment used to perform the RF measurements described herein is
appropriate to the task, and calibration of its accuracy has been performed
within the past 12 months as recommended by the manufacturer.
3. The on-site RF measurements described herein were performed in a manner
consistent with industry standards.
4. To the best of my knowledge, the statements and information disclosed in
this report are true, complete and accurate.
5. The analysis of site RF compliance provided herein is consistent with the
applicable FCC regulations, additional guidelines issued by the FCC, and
industry practice.
6. The results of the analysis indicate that the antenna operation at the subject
site is in compliance with the FCC regulations concerning RF exposure.
____________________________________ __________Daniel J. Collins Date
Chief Technical OfficerPinnacle Telecom Group, LLC
1/22/09
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Appendix A: Site PhotographsShown below are photographs of the site taken on the day of the measurements.
Sprint Sector A
Sprint Sector B (right) and Sector C (left)
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Appendix B: Background on the FCC MPE LimitAs directed by the Telecommunications Act of 1996, the FCC has established alimit for maximum continuous human exposure to RF fields.
The FCC maximum permissible exposure (MPE) limit represent the consensus offederal agencies and independent experts responsible for RF safety matters.Those agencies include the National Council on Radiation Protection andMeasurements (NCRP), the Occupational Safety and Health Administration(OSHA), the National Institute for Occupational Safety and Health (NIOSH), theAmerican National Standards Institute (ANSI), the Environmental ProtectionAgency (EPA), and the Food and Drug Administration (FDA). In formulating itsguidelines, the FCC also considered input from the public and technicalcommunity notably the Institute of Electrical and Electronics Engineers (IEEE).
The FCC RF exposure guidelines are incorporated in Section 1.301 et seqof itsRules and Regulations (47 CFR 1.1301-1.1310). Those guidelines specify MPE
limits for both occupational and general population exposure.
The specified continuous exposure MPE limits are based on known variation ofhuman body susceptibility in different frequency ranges, and a SpecificAbsorption Rate (SAR) of 4 watts per kilogram, which is universally considered toaccurately represent human capacity to dissipate incident RF energy (in the formof heat). The occupational MPE guidelines incorporate a safety factor of 10 orgreater with respect to RF levels known to represent a health hazard, and anadditional safety factor of five is applied to the MPE limits for general populationexposure. Thus, the general population MPE limit has a built-in safety factor ofmore than 50. Continuous exposure at levels equal to or below the applicableMPE limits is considered to result in no adverse health effects on humans.
The reason for two tiers of MPE limits is based on an understanding andassumption that members of the general public are unlikely to have hadappropriate RF safety training and may not be aware of the exposures theyreceive; occupational exposure in controlled environments, on the other hand, isassumed to involve individuals who have had such training, are aware of theexposures, and know how to maintain a safe personal work environment.
The FCCs RF exposure limits are expressed in two equivalent forms, usingalternative units of field strength (expressed in volts per meter, or V/m), andpower density (expressed in milliwatts per square centimeter, or mW/cm2). Thetable on the next page lists the FCC limits for both occupational and general
population exposures, using the mW/cm2
reference, for the different radiofrequency ranges.
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Frequency Range (F)(MHz)
Occupational Exposure( mW/cm2 )
General Public Exposure( mW/cm2 )
0.3 - 1.34 100 100
1.34 - 3.0 100 180 / F2
3.0 - 30 900 / F2 180 / F2
30 - 300 1.0 0.2
300 - 1,500 F / 300 F / 1500
1,500 - 100,000 5.0 1.0
The diagram below provides a graphical illustration of both the FCCs
occupational and general population MPE limits.
Because the FCCs RF exposure limits are frequency-shaped, the exact MPElimits applicable to the instant situation depend on the frequency range used bythe systems of interest.
The most appropriate method of determining RF compliance is to assess the RFpower density attributable to a particular system and compare that to the MPE
Power Density
(mW/cm2)
Frequency (MHz)
100
0.2
1.0
5.0
0.3 1.34 3.0 30 300 1,500 100,000
Occupational
General Public
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limit applicable to the operating frequency in question. The result is usuallyexpressed as a percentage of the MPE limit.
For potential exposure from multiple systems, the respective percentages of theMPE limits are added, and the total percentage compared to 100 (percent of thelimit). If the result is less than 100, the total exposure is in compliance; if it is
more than 100, exposure mitigation measures are necessary to achievecompliance.
References on Compliance47 CFR, FCC Rules and Regulations, Part 1 (Practice and Procedure), Section1.1310 (Radiofrequency radiation exposure limits).
FCC Second Memorandum Opinion and Order and Notice of ProposedRulemaking (FCC 97-303), In the Matter of Procedures for Reviewing Requestsfor Relief From State and Local Regulations Pursuant to Section 332(c)(7)(B)(v)
of the Communications Act of 1934 (WT Docket 97-192), Guidelines forEvaluating the Environmental Effects of Radiofrequency Radiation (ET Docket93-62), and Petition for Rulemaking of the Cellular Telecommunications IndustryAssociation Concerning Amendment of the Commission's Rules to PreemptState and Local Regulation of Commercial Mobile Radio Service TransmittingFacilities, released August 25, 1997.
FCC First Memorandum Opinion and Order, ET Docket 93-62, In the Matter ofGuidelines for Evaluating the Environmental Effects of Radiofrequency Radiation,released December 24, 1996.
FCC Report and Order, ET Docket 93-62, In the Matter of Guidelines for
Evaluating the Environmental Effects of Radiofrequency Radiation, releasedAugust 1, 1996.
FCC Office of Engineering and Technology (OET) Bulletin 65, EvaluatingCompliance with FCC Guidelines for Human Exposure to RadiofrequencyElectromagnetic Fields, Edition 97-01, August 1997.
FCC Office of Engineering and Technology (OET) Bulletin 56, Questions andAnswers About Biological Effects and Potential Hazards of RF Radiation, edition4, August 1999.
RF Field Measurements for Antenna Sites, (video), Richard Tell Associates
Inc., 1997.
EME Awareness for Antenna Site Safety, (video), Motorola (produced inassociation with Richard Tell Associates Inc.), 1997.
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Appendix C: Summary of Expert QualificationsDaniel J. Collins, Chief Technical Officer, Pinnacle Telecom Group, LLC
Synopsis: 36 years of experience in all aspects of wireless system
engineering, related regulation, and RF exposure Has performed or led FCC MPE compliance assessments
on more than 12,000 antenna sites since the latest FCCregulations went into effect in 1997
Has provided testimony as an FCC compliance expert morethan 1,200 times since 1997
Have been accepted as an expert in New York, New Jerseyand more than 40 other states, as well as by the FCC
Education: B.E.E., City College of New York (Sch. Of Eng.), 1971
M.B.A., 1982, Fairleigh Dickinson University, 1982
Bronx High School of Science, 1966Current Responsibilities: lead all PTG staff work involving RF safety and FCC
compliance, microwave and satellite system engineering,and consulting on wireless technology and regulation
Prior Experience: Edwards & Kelcey, VP RF Engineering and ChiefInformation Technology Officer, 1996-99
Bellcore, Executive Director Regulation and Public Policy,1983-96
AT&T (Corp. HQ), Director Spectrum Management Policyand Practice, 1977-83
AT&T Long Lines, Group Supervisor Microwave RadioSystem Design, 1972-77
Specific RF Safety /Compliance Experience:
Involved in RF exposure matters since 1972
Have had lead corporate responsibility for RF safety and
compliance at AT&T, Bellcore, Edwards & Kelcey, and PTG While at AT&T, helped develop the mathematical models
later adopted by the FCC for predicting RF exposure
Have been relied on for compliance by all major wirelesscarriers, as well as by the federal government, several stateand local governments, equipment manufacturers, systemintegrators and other consulting / engineering firms
Other Background: Author, Microwave System Engineering(AT&T, 1974)
Co-author and executive editor, A Guide to NewTechnologies and Services(Bellcore, 1993)
National Spectrum Managers Association (NSMA) thrice-elected President and chair of the Board of Directors; earlier
was founding member, twice-elected Vice President, long-time member of the Board, and was named an NSMA Fellowin 1991
Listed in Whos Who in the Media and CommunicationandInternational Whos Who in Information Technology
Published more than 35 articles in industry magazines