The FCC is reviewing its guidelines for human exposure to RF electromagnetic fields from commission-regulated transmitters and devices, with respect to the National Environmental Policy Act.
In a further notice of proposed rulemaking (ET Docket No. 13-84, ET Docket No. 03-137), the Commission proposes streamlining and clarifying its RF exposure rules for transmitters and revamping regulation of signage that warns of RF exposure on rooftops containing cell sites. The FCC is also initiating a Notice of Inquiry to review the new scientific research on RF exposure and appropriate limits.
Presently, each radio service is, or can be, treated differently with respect to compliance with RF exposure requirements. For example, AWS licensees use power per megahertz, while 800 MHz cellular licensees are regulated using power-per-channel. To make matters more confusing, some radio services share the same spectrum and other radio services are excluded altogether.
The FCC decided it was time for consistent exclusion criteria across all the radio services based solely on height, distance and radio frequency.
“We seek to streamline and harmonize many procedures to achieve equal treatment of RF-emitting sources based on their physical properties rather than service categories,” according to the further notice. “Thus, we propose establishing general exemptions from evaluation to determine compliance in place of existing service-specific ‘categorical exclusions.’ These proposed exemptions involve simple calculations to establish whether any further determination of compliance is necessary.”
Rooftop RF-exposure Signage Revamp
The current rules for rooftop signage where RF transmitters have been deployed have been inconsistent concerning where and when rooftop signage was required. The FCC has found situations where rooftops were under-signed or over-signed resulting in not enough information being provided on one hand and confusion on the other. One strict, and erroneous, reading of the current FCC rules is that cellular base stations that are high above the ground can be excluded from rooftop signage, even if they are on a roof where people can access them. An additional reason for the rule change, a rooftop with three carriers can each post different, and sometimes conflicting, signs.
In order to clear up the confusion, the FCC seeks to clarify that compliance with RF signage regulations on rooftops should be taken seriously. The agency is proposing to standardize the rules that require RF warning signage on rooftop cell sites. The goal of the new rules will be to make it clear where and when signage is needed and what that signage should say.
“We also propose to adopt specific new requirements for signs and barriers at fixed transmitter sites to ensure compliance with public and occupational exposure limits,” according to the notice. “Further, we propose a clarification of the definition of transient exposure for non-workers exposed at levels up to occupational limits.”
A Review of RF Exposure Research or A New RF Standard?
The NOI will solicit new RF and maximum permissible exposure (MPE) research from the public and from government agencies. While the FCC notes that, to date, organizations with expertise in the health field have not suggested there is a basis for changing the FCC’s standards, the commission does solicit comment on whether its standards should be modified.
According to Bill Sill, Wilkinson Barker Knauer, “The wireless industry should be active in the NOI proceeding. To date, the FCC has effectively espoused a definitive set of RF and MPE standards, which local jurisdictions have respected. The challenge before the FCC is to make sure that regardless of whether it makes any changes or not, the standards remain clear and are supported by a preponderance of credible scientific evidence.”