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CA_SJ_CUPERTINO_346 RF reportVerizon Wireless • Proposed Node (No. 545476 “CA_SJ_CUPERTINO_346”) 10385 South De Anza Boulevard • Cupertino, California B32-H1DT Page 1 of 3 ©2020 Statement of Hammett & Edison, Inc., Consulting Engineers The firm of Hammett & Edison, Inc., Consulting Engineers, has been retained on behalf of Verizon Wireless, a personal wireless telecommunications carrier, to evaluate the addition of Node No. 545476 “CA_SJ_CUPERTINO_346” to the Verizon network in Cupertino, California, for compliance with appropriate guidelines limiting human exposure to radio frequency (“RF”) electromagnetic fields. Executive Summary Verizon proposes to install two small antennas on the municipal light pole sited in the public right-of-way near 10385 South De Anza Boulevard in Cupertino. The proposed operation will comply with the FCC guidelines limiting public exposure to RF energy. Prevailing Exposure Standards The U.S. Congress requires that the Federal Communications Commission (“FCC”) evaluate its actions for possible significant impact on the environment. A summary of the FCC’s exposure limits is shown in Figure 1. These limits apply for continuous exposures and are intended to provide a prudent margin of safety for all persons, regardless of age, gender, size, or health. The most restrictive limit for exposures of unlimited duration at several wireless service bands are as follows: Transmit “Uncontrolled” Occupational Limit Wireless Service Band Frequency Public Limit (5 times Public) Microwave (point-to-point) 1–80 GHz 1.0 mW/cm2 5.0 mW/cm2 Millimeter-wave 24–47 1.0 5.0 Part 15 (WiFi & other unlicensed) 2–6 1.0 5.0 CBRS (Citizens Broadband Radio) 3,550 MHz 1.0 5.0 BRS (Broadband Radio) 2,490 1.0 5.0 WCS (Wireless Communication) 2,305 1.0 5.0 AWS (Advanced Wireless) 2,110 1.0 5.0 PCS (Personal Communication) 1,930 1.0 5.0 Cellular 869 0.58 2.9 SMR (Specialized Mobile Radio) 854 0.57 2.85 700 MHz 716 0.48 2.4 600 MHz 617 0.41 2.05 [most restrictive frequency range] 30–300 0.20 1.0 General Facility Requirements Wireless nodes typically consist of two distinct parts: the electronic transceivers (also called “radios”) that are connected to the traditional wired telephone lines, and the passive antenna(s) that send the wireless signals created by the radios out to be received by individual subscriber units. The radios are Verizon Wireless • Proposed Node (No. 545476 “CA_SJ_CUPERTINO_346”) 10385 South De Anza Boulevard • Cupertino, California B32-H1DT Page 2 of 3 ©2020 often located on the same pole as the antennas and are connected to the antennas by cables. Because of the short wavelength of the frequencies assigned by the FCC for wireless services, the antennas require line-of-sight paths for their signals to propagate well and so are installed at some height above ground. The antennas are designed to concentrate their energy toward the horizon, with very little energy wasted toward the sky or the ground. This means that it is generally not possible for exposure conditions to approach the maximum permissible exposure limits without being physically very near the antennas. Computer Modeling Method The FCC provides direction for determining compliance in its Office of Engineering and Technology Bulletin No. 65, “Evaluating Compliance with FCC-Specified Guidelines for Human Exposure to Radio Frequency Radiation,” dated August 1997. Figure 2 describes the calculation methodologies, reflecting the facts that a directional antenna’s radiation pattern is not fully formed at locations very close by (the “near-field” effect) and that at greater distances the power level from an energy source decreases with the square of the distance from it (the “inverse square law”). This methodology is an industry standard for evaluating RF exposure conditions and has been demonstrated through numerous field tests to be a conservative prediction of exposure levels. Site and Facility Description Based upon information provided by Verizon, including operating data from Modus, LLC, it is proposed to install two Ericsson Model 6701, 2-foot tall, directional panel antennas antennas with integrated radios on a new light pole to replace the existing pole sited in the public right-of-way on the north side of McClellan Road at its intersection with Felton Way in Cupertino, behind the strip mall at 10385 South De Anza Boulevard. The antennas would employ no downtilt, would be mounted at an effective height of about 31½ feet above ground, and would be oriented toward 90°T and 270°T. The maximum effective radiated power proposed in any direction is 193 watts in the 28 GHz band. There are reported no other wireless telecommunications base stations at the site or nearby. Study Results For a person anywhere at ground, the maximum RF exposure level due to the proposed Verizon operation is calculated to be 0.0039 mW/cm2, which is 0.39% of the applicable public exposure limit. The maximum calculated level at the second-story elevation of any nearby building* is 0.90% of the public exposure limit. It should be noted that these results include several “worst-case” assumptions and therefore are expected to overstate actual power density levels from the proposed operation. * Located at least 35 feet away, based on photographs from Google Maps. Verizon Wireless • Proposed Node (No. 545476 “CA_SJ_CUPERTINO_346”) 10385 South De Anza Boulevard • Cupertino, California B32-H1DT Page 3 of 3 ©2020 Recommended Mitigation Measures Due to their mounting location and height, the antennas would not be accessible to unauthorized persons, and so no measures are necessary to comply with the FCC public exposure guidelines. To prevent occupational exposures in excess of the FCC guidelines, it is recommended that appropriate RF safety training be provided to all workers who have access within 8 feet outward from the antennas.† No access within 2 feet directly in front of the antennas should be allowed while the antennas are in operation, unless other measures can be demonstrated to ensure that occupational protection requirements are met. It is recommended that explanatory signs‡ be posted at the antennas and/or on the pole below the antennas, readily visible from any angle of approach. Conclusion Based on the information and analysis above, it is the undersigned’s professional opinion that operation of the node proposed by Verizon Wireless near 10385 South De Anza Boulevard in Cupertino, California, will comply with the prevailing standards for limiting public exposure to radio frequency energy and, therefore, will not for this reason cause a significant impact on the environment. The highest calculated level in publicly accessible areas is much less than the prevailing standards allow for exposures of unlimited duration. This finding is consistent with measurements of actual exposure conditions taken at other operating nodes. Training authorized personnel and posting explanatory signs are recommended to establish compliance with occupational exposure limits. Authorship The undersigned author of this statement is a qualified Professional Engineer, holding California Registration No. E-21306, which expires on September 30, 2021. This work has been carried out under his direction, and all statements are true and correct of his own knowledge except, where noted, when data has been supplied by others, which data he believes to be correct. Neil J. Olij, P.E. 707/996-5200 July 31, 2020 † May include workers on the pole, on nearby poles, or on a lift to trim nearby trees. ‡ Signs should comply with OET-65 color, symbol, and content recommendations. Contact information should be provided (e.g., a telephone number) to arrange for access to restricted areas. The selection of language(s) is not an engineering matter, and guidelines from the landlord, local zoning or health authority, or appropriate professionals may be required. FCC Radio Frequency Protection Guide FCC Guidelines Figure 1 1000 100 10 1 0.1 0.1 1 10 100 103 104 105 Occupational Exposure Public Exposure PCS CellFM PowerDensity(mW/cm2)The U.S. Congress required (1996 Telecom Act) the Federal Communications Commission (“FCC”) to adopt a nationwide human exposure standard to ensure that its licensees do not, cumulatively, have a significant impact on the environment. The FCC adopted the limits from Report No. 86, “Biological Effects and Exposure Criteria for Radiofrequency Electromagnetic Fields,” published in 1986 by the Congressionally chartered National Council on Radiation Protection and Measurements (“NCRP”). Separate limits apply for occupational and public exposure conditions, with the latter limits generally five times more restrictive. The more recent standard, developed by the Institute of Electrical and Electronics Engineers and approved as American National Standard ANSI/IEEE C95.1-2006, “Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to 300 GHz,” includes similar limits. These limits apply for continuous exposures from all sources and are intended to provide a prudent margin of safety for all persons, regardless of age, gender, size, or health. As shown in the table and chart below, separate limits apply for occupational and public exposure conditions, with the latter limits (in italics and/or dashed) up to five times more restrictive: Frequency Electromagnetic Fields (f is frequency of emission in MHz) Applicable Range (MHz) Electric Field Strength (V/m) Magnetic Field Strength (A/m) Equivalent Far-Field Power Density (mW/cm2) 0.3 – 1.34 614 614 1.63 1.63 100 100 1.34 – 3.0 614 823.8/ f 1.63 2.19/ f 100 180/ f2 3.0 – 30 1842/ f 823.8/ f 4.89/ f 2.19/ f 900/ f2 180/ f2 30 – 300 61.4 27.5 0.163 0.0729 1.0 0.2 300 – 1,500 3.54 f 1.59 f f /106 f /238 f/300 f/1500 1,500 – 100,000 137 61.4 0.364 0.163 5.0 1.0 Frequency (MHz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©2020 RFR.CALC™ Calculation Methodology Assessment by Calculation of Compliance with FCC Exposure Guidelines Methodology Figure 2 ©2020 The U.S. Congress required (1996 Telecom Act) the Federal Communications Commission (“FCC”) to adopt a nationwide human exposure standard to ensure that its licensees do not, cumulatively, have a significant impact on the environment. The maximum permissible exposure limits adopted by the FCC (see Figure 1) apply for continuous exposures from all sources and are intended to provide a prudent margin of safety for all persons, regardless of age, gender, size, or health. Higher levels are allowed for short periods of time, such that total exposure levels averaged over six or thirty minutes, for occupational or public settings, respectively, do not exceed the limits. Near Field. Prediction methods have been developed for the near field zone of panel (directional) and whip (omnidirectional) antennas, typical at wireless telecommunications base stations, as well as dish (aperture) antennas, typically used for microwave links. The antenna patterns are not fully formed in the near field at these antennas, and the FCC Office of Engineering and Technology Bulletin No. 65 (August 1997) gives suitable formulas for calculating power density within such zones. For a panel or whip antenna, power density S = 180 θ BW × 0.1 × Pnet π×D ×h , in mW/cm2, and for an aperture antenna, maximum power density Smax = 0.1 × 16 × η × Pnet π × h 2 , in mW/cm2, where qBW = half-power beamwidth of antenna, in degrees, Pnet = net power input to antenna, in watts, D = distance from antenna, in meters, h = aperture height of antenna, in meters, and h = aperture efficiency (unitless, typically 0.5-0.8). The factor of 0.1 in the numerators converts to the desired units of power density. Far Field. OET-65 gives this formula for calculating power density in the far field of an individual RF source: power density S = 2.56 × 1.64 × 100 × RFF 2 × ERP 4 × π × D2 , in mW/cm2, where ERP = total ERP (all polarizations), in kilowatts, RFF = three-dimensional relative field factor toward point of calculation, and D = distance from antenna effective height to point of calculation, in meters. The factor of 2.56 accounts for the increase in power density due to ground reflection, assuming a reflection coefficient of 1.6 (1.6 x 1.6 = 2.56). The factor of 1.64 is the gain of a half-wave dipole relative to an isotropic radiator. The factor of 100 in the numerator converts to the desired units of power density. This formula is used in a computer program capable of calculating, at thousands of locations on an arbitrary grid, the total expected power density from any number of individual radio frequency sources. The program also allows for the inclusion of uneven terrain in the vicinity, as well as any number of nearby buildings of varying heights, to obtain more accurate projections.