Greetings. Today is the due date for comments in the FCC's docket proceeding reexamining its RF exposure regulations. The attached comments were filed by authority of the Executive Committee today. They were drafted some time ago and an earlier version was edited somewhat by Dave Sumner. Since then, with the help of President Craigie, Brennan Price and Ed Hare, we have substantially edited that first version. You will see that these comments are critical of the FCC's proposal to subject the Amateur Service (and all other radio services across the board) to a "general exemption" table. This table would determine when an Amateur station would have to conduct a routine environmental review of a proposed installation. The "general exemption" table is far more encompassing than is the existing table applicable only to the Amateur Service in Section 97.13(c) because the existing table is based only on TPO and not ERP and it doesn't take into account distance separation of persons from the transmitting antenna. FCC is concerned about the current Amateur exemption criteria. However, for the reasons we note in these comments, the proposed general exemption table would require routine environmental evaluations by many, many more Amateur stations than are now required to perform them. Our position is that this is severe regulatory overkill.
Se also asked that any exemption criteria that are adopted should be the preemptive standard as against any more stringent state or local criteria for what is considered "safe" and not subject to further procedural showings.
There are quite a few comments in this proceeding, many of which express the generalized hysteria that accompanies any discussion with non-technical people of the issue of RF exposure. Ed Hare anticipates the need for some additional showings in the reply stage of this proceeding.
This filing does not reflect any specific suggested input from our RF Safety Committee.
73, Chris W3KD
Christopher D. Imlay
Booth, Freret, Imlay & Tepper. P.C.
14356 Cape May Road
Silver Spring, Maryland 20904-6011
(301) 384-5525 telephone
(301) 384-6384 facsimile
W3KD(a)ARRL.ORG
