FYI. 73. Jim, W6CF __________________________________________________________________ ------------------------------------------------------------------ THE CGC COMMUNICATOR CGC #523 Tuesday, July 16, 2002 Robert F. Gonsett, W6VR, Editor Copyright 2002, Communications General Corporation (CGC) ------------------------------------------------------------------ __________________________________________________________________ SPECIAL REPORT Human exposure to radiofrequency signals is in the news again as the FCC conducts a surprise inspection on Mt. Wilson. The issues uncovered will apply to many smaller communications sites, so sit back and read this entire Special Report. The views expressed in the following Letter to the Editor are those of the author and do not necessarily reflect the views of CGC. The author is an experienced broadcast engineer known to CGC, and his or her name has been withheld upon request. ****************************************************************** MT. WILSON - FCC TAKES HUMAN EXPOSURE TO RADIO FREQUENCY MEASUREMENTS Today [Friday, July 12, 2002], the FCC, in an unprecedented move, shut down every Los Angeles FM and TV station operating from Mt. Wilson in a surprise RF hazard inspection. The situation seems to have started a few weeks ago with the attempted installation of a new antenna for station KDOC, CH-56. KDOC is located in the ground floor of the building known as the "Post Office." The KDOC antenna was to be mounted on a 150' pole [actually a 226' pole -Ed.] directly West of the Post office. 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!" (Note that the FCC order obliges stations to comply with requests to lower power as a safety matter and without regard to ratings or revenue issues. The corporate engineer may not have known that he was exposing his company to many thousands of dollars in fines.) The FM station, after a week of negotiating, finally agreed to cooperate. Yesterday, a team of six FCC "agents" arrived at Mt. Wilson. Their first step was to perform a field intensity survey of their own. They located a site that, according to their instruments, did not meet the safety levels for public access. The site is the KMEX driveway as it rises up behind KBIG and until it reaches the KMEX building. Since there has been considerable construction in that driveway over the past few years, the gate has long since disappeared. Since there is no gate, the driveway is publicly accessible and therefore in violation. It would not have been a violation if there had been a chain across the driveway and a "No Trespassing" sign. Today, the FCC showed up ready to find out who was responsible for that hot-spot in the driveway. They had called the Chief Engineers of every station to meet at Mt. Wilson at 12:00 noon.... They set up their meter at the hot-spot and then asked each station to shut down completely, one-by-one, just long enough to make another measurement. Most stations were off for from 20 seconds to 40 seconds. This process actually took hours to complete as communications was difficult between each transmitter and the man taking the measurements. The Fox-lot stations were then asked to do the same thing for another hot-spot over there. After all of the measurements were done, everyone met at the Mt. Wilson Pavilion to discuss the situation. The agents said that they were not able to review the measurements in the field. Once they were reviewed at the office, there would be Notices of Violations and Notices of Liability (fines.) Many of the Chiefs felt that the stations exceeding the limits would probably be a handful of close-by FMs. The agents then spent a considerable time explaining the rules and the FCC's expectations. They said that the rules have been in place for several years now, and that they were no longer warning people, but enforcing the law. There was also a Q&A time. There was also considerable talk about a group of stations joining to have a new, comprehensive field study done by a qualified engineering firm. Such studies are required for licensees under the new rules. The last time this was done was in 1998 by Hammett & Edison. While some stations have shown little interest in joining the group, there is clearly a cost and accuracy benefit in having as many stations as possible join the group. Perhaps this incident will change the minds of the stations that show little interest. They are still looking for bids and there is not yet a cost estimate. The contact is Steve Colley: <Steve.Colley@nbc.com> or 818-840-3375. An FCC agent then explained that they were there on a regular inspection and not as a result of some incident. Most observers there did not buy this. The agents seemed to have arrived poorly prepared for the inspections, as though they had been called to Mt. Wilson at the last minute. According to some who had spoken to them on Thursday, they were very well aware of the KDOC incident. Perhaps they did not want to pursue the KDOC incident but just make a statement that was loud and clear. If so, their statement was indeed loud and clear. In any case, this incident should alert us to the fact that we have a new responsibility that cannot be ignored any longer. ****************************************************************** RESPONSE FROM READERS An advance copy of the above Letter to the Editor was circulated to a few broadcast engineers for their comments and opinions. The opinions received are divided into two groups, as follows. ****************************************************************** ABOUT THE MT. WILSON/FCC INSPECTION I think (the above story) pretty much sums things up. It will be very interesting to see what comes of this. The inspector would not give any indications of exactly what (the FCC) might do. - Radio Station Engineer ____ Perhaps this is a technical point, but there has never been a gate at the KMEX driveway as far as I know (back to at least 1984). There's always been a chain there with a RF warning sign on it, and there is another warning sign on the side of the KMEX-TV building. But alas, (when the FCC arrived) the chain was unlocked and down. And the sign was laying flat on the ground. It probably wasn't the KMEX folks that dropped the chain, rather the tower folks dealing with KDOC. That's only my guess. The chain was up and locked the day before. I (check the chain) every time I can. - TV station engineer ____ The fact that the FCC made a surprise inspection is not really a surprise. They have stated this would likely happen on several occasions during that past 12 months. Most recently, at the IWCE convention in Las Vegas, in April, one of the FCC's Enforcement Officers stated that we should not be surprised to see the issuance of Notices of Violation and Notices of Liability during the remaining part of the year as the FCC was gearing up to illustrate some examples of violations of their RF rules. The FCC did this last year on Lookout Mountain west of Denver. - Consulting Radio Engineer ****************************************************************** ABOUT GENERAL HUMAN EXPOSURE TO RF ISSUES ON MT. WILSON Seems that a few broadcasters are not very enthusiastic about human exposure to RF compliance issues. When asked to reduce power to facilitate tower work on Mt. Wilson, these excuses are sometimes heard: "I'm unavailable that day" - "I'll be on vacation then" - "How about if we reduce power from, say, 1 to 4 a.m.?" Since multiple stations may be involved in power cut backs to permit tower work, sometimes it's a miracle any work gets done at all. One tower maintenance company complained that after a power reduction was finally accomplished on Mt. Wilson, a TV GM ordered his engineer to RESUME FULL POWER operation immediately. Full power operation was resumed, without warning, and with climbers on the tower structure! Obviously, too many people do not understand the absolute necessity of cooperating and complying when it comes to human exposure to RF signal issues. Compliance with the FCC's exposure rules is the law, and failure to comply could lead to serious liability consequences, to say nothing of FCC sanctions. Much more could and probably should be said on this topic, and we hope you will send us your thoughts. ****************************************************************** YOUR COMMENTS ARE INVITED Written comments from broadcasting professionals on any of the above issues are welcome, and invited. Names will be withheld if you ask us to do so. This forum is to identify problems and look toward solutions in a generic sense, without pointing fingers at specific individuals, stations or companies. All meaningful comments (please be concise) will be published together in an upcoming Special Edition of the CGC Communicator. Let's pull together, learn from the Mt. Wilson incidents and move on. __________________________________________________________________ ------------------------------------------------------------------ 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. ------------------------------------------------------------------ _________________________ End _______________________________