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CCL00737 13192 10095833 EME Report 12-03-2020 On-Site ELECTROMAGNETIC ENERGY (EME) EXPOSURE REPORT Site Name: Site ID: USID: FA Location: Site Type: Location: Latitude (NAD83): Longitude (NAD83): Report Completed: AT&T M-RFSC Prepared By: Central Cupertino CCL00737 13192 10095833 Rooftop 10101 North De Anza Boulevard Cupertino, CA 95014 37.3238333 -122.0331111 December 03, 2020 Casey Chan Prepared for: AT&T Mobility c/o Caldwell Compliance, Inc. 6900 Koll Center Parkway. Ste. 401 Pleasanton, CA 94566 OSC Engineering Inc. Page 2/21 Site Compliance Conclusion The AT&T site CCL00737 located at 10101 North De Anza Boulevard Cupertino, CA 95014 complies with FCC Guidelines. OSC Engineering Inc. Page 3/21 Site Overview and Description • The antennas are mounted on a rooftop • The site consists of three (3) sectors with a total of twelve (12) antennas • The site is within a secure rooftop • The site is not co-located Compliance Notes Occupational Safety & Compliance Engineering (OSC Engineering) has been contracted by Caldwell Compliance, Inc. to conduct an RF (radio frequency) On-site analysis. The Federal Communications Commission (FCC) has set limits on RF energy exposed to humans on a wireless cell site. The FCC has also mandated that all RF wireless sites must be in compliance with the FCC limits and a compliance check must be performed annually to ensure site compliance. OSC Engineering uses the FCC OET-65 as well as AT&T ND-00059 to make recommendations based on results and information gathered from drawings and Radio Frequency Data Sheets. A site-specific compliance plan is recommended for each transmitting site. This report serves as a single piece of the overall compliance plan. Information utilized for this report: Drawings: 3701A0RQTL.10095833.CCL00737.J5.AE201 100CDs AE06 2019-11-05 OSC Engineering Inc. Page 4/21 Compliance Results of the Existing Site (on-site audit) RF Sign(s) @ access point(s): No signs RF Sign(s) and/or barriers @ antenna sector A: Existing: 14’ physical barrier with one (1) Caution 2 sign on middle post on the east side of sector and a 16’-10” physical barrier with one (1) Caution 2 sign on the middle post on the west side of sector Existing: One (1) Caution 2 sign behind sector Existing: Two (2) Caution 2 signs on screen wall in front of sector RF Sign(s) and/or barriers @ antenna sector B: Existing: 13.5’ physical barrier with one (1) Caution 2 sign on middle post on the east side of sector and a 6’-3” x 6’- 10” x 8’ physical barrier with two (2) Caution 2 sign on the posts on the west side of sector Existing: One (1) Caution 2 sign behind sector Existing: Two (2) Caution 2 signs on screen wall in front of sector RF Sign(s) and/or barriers @ antenna sector : Existing: 32’-2” physical barrier with three (3) Caution 2 sign on posts on the east side of sector and a 16’-4” physical barrier with one (1) Caution 2 sign on the middle post on the west side of sector Existing: Two (2) Caution 2 signs behind sector Existing: Two (2) Caution 2 signs on screen wall in front of sector Max RF Exposure Level measured (AT&T antennas @ roof): 197.15 % FCC General Population MPE Limit @ Sector A 139.6 % FCC General Population MPE Limit @ Sector B 206.85 % FCC General Population MPE Limit @ Sector C Max RF Exposure Level measured (all carriers @ roof): 206.85 % FCC General Population MPE Limit Max RF Exposure Level measured (AT&T antennas @ ground): <1 % FCC General Population MPE Limit OSC Engineering Inc. Page 5/21 FCC Regulations and Guidelines from OET 65 When considering the contributions to field strength or power density from other RF sources, care should be taken to ensure that such variables as reflection and re-radiation are considered. In cases involving very complex sites predictions of RF fields may not be possible, and a measurement survey may be necessary The process for determining compliance for other situations can be similarly accomplished using the techniques described in this section and in Supplement A to this bulletin that deals with radio and television broadcast operations. However, as mentioned above, at very complex sites measurements may be necessary. In the simple example shown in the below diagram, it is desired to determine the power density at a given location X meters from the base of a tower on which are mounted two antennas. One antenna is a CMRS antenna with several channels, and the other is an FM broadcast antenna. The system parameters that must be known are the total ERP for each antenna and the operating frequencies (to determine which MPE limits apply). The heights above ground level for each antenna, H1 and H2, must be known in order to calculate the distances, R1and R2, from the antennas to the point of interest. 1 1 OET Bulletin 65, Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields, Page 37- 38 OSC Engineering Inc. Page 6/21 On-site Measurement When on-site measurements are required for an Electromagnetic Energy (EME) Survey, all measurements performed by OSC Engineering are taken with a Narda Broadband RF Field Meter and Narda E-Field Probe. The Narda Broadband Meters (NBM series) are the most accurate non-ionizing radiation systems available. Calibration of the Narda Meter was carried out in accordance with ISO-9001. Calibration of the Narda Probe was carried out in accordance with ISO-10012- 1. Measurement Technique: Measurements performed by OSC Engineering are recorded in Maximum-Hold as well as Spatial Averaging. Only Maximum-Hold is recorded and reported in situations that do not exceed the General Population Limit (uncontrolled). Both Maximum-Hold and Spatial Averaging measurements are recorded in situations exceeding the General Population (thereby including Occupational/controlled as well). At minimum measurements are taken at a ten (10) foot by ten (10) foot interval. Measurements near antennas are taken in various increments between one (1) foot and the location where emissions levels are no longer exceeding FCC MPE limit. Measurements are taken in accordance with section 7 of AT&T deliverables (AT&T Mobility RF Safety Survey Report Deliverables Version 7 [17 July 2009]) OSC Engineering Inc. Page 7/21 Site Photographs General View Access Point Access Point Access Point OSC Engineering Inc. Page 8/21 Site Photographs AT&T Sector A (Caution 2 Sign behind sector) AT&T Sector A (16’-10” physical barrier with Caution 2 Sign) AT&T Sector A (2 Caution 2 sign @ sector) AT&T Sector A (14’ physical barrier with Caution 2 Sign) OSC Engineering Inc. Page 9/21 Site Photographs AT&T Sector B (8’x 6’-10”x 6’-3” physical barrier with Caution 2 signs) AT&T Sector B (Caution 2 signs in front of sector on screen wall) AT&T Sector B (13.5’ physical barrier with Caution 2 Sign) AT&T Sector B (Caution 2 Sign behind sector) OSC Engineering Inc. Page 10/21 Site Photographs AT&T Sector C (Caution 2 Signs behind sector) AT&T Sector C (32’-2” physical barrier with Caution 2 Signs) AT&T Sector C (Caution 2 signs in front of sector on screen wall) AT&T Sector C (16’-4” physical barrier with Caution 2 sign) OSC Engineering Inc. Page 11/21 EME On Site Survey Data On-site or “live” readings are measurements at a given point, at a given time. These measurements will vary depending on various factors. Measurements were performed per AT&T’s ND-00059 standards. Maximum value (max-hold) readings were taken and are shown on the diagram “On-Site Measurements Result- view of diagram facility” page. Spatial averaging readings were taken for areas exceeding the General population/ Uncontrolled Limits. For the purpose of this report, maximum values are shown as a conservative measure. Where applicable, measurements were performed on the ground as well as rooftop for AT&T as well as for other carriers (co-locators). Recommendations are based on simulation results rather than on-site measurements for further conservatory measures. Survey Date: Time: Temperature: Condition: December 01, 2020 10:00 AM ≈ 48˚ F Mild Breeze, Sunny Access to rooftop: Access to antennas: How is access gained: Elevator to stairs to a door out to the roof Walk up to antennas once onto the rooftop Schedule appointment with Apple to obtain access Electric Field Probe Manufacturer: Narda Model: EF5092 Serial Number: 01277 Broadband Field Meter Manufacturer: Narda Model: NBM-520 Serial Number: D-0565 OSC Engineering Inc. Page 12/21 On-Site Audit-Measurement Results (values listed as a percentage of the GP MPE Limit) OSC Engineering Inc. Page 13/21 Existing Signage / Recommendation If work is being performed in the vicinity of the transmitting antennas, site shut-down procedures must be followed. See page entitled AT&T Antenna Shut-down protocol for further information. •Access Point No Signs / action required Sector A: Existing: 14’ physical barrier with one (1) Caution 2 sign on middle post on the east side of sector and a 16’-10” physical barrier with one (1) Caution 2 sign on the middle post on the west side of sector Existing: One (1) Caution 2 sign behind sector Existing: Two (2) Caution 2 signs on screen wall in front of sector To be installed: Caution 2 sign on every post. Move existing barrier 6’ away from the parapet on the west side. Sector B: Existing: 13.5’ physical barrier with one (1) Caution 2 sign on middle post on the east side of sector and a 6’-3” x 6’-10” x 8’ physical barrier with two (2) Caution 2 sign on the posts on the west side of sector Existing: One (1) Caution 2 sign behind sector Existing: Two (2) Caution 2 signs on screen wall in front of sector To be installed: Caution 2 sign on every post. Move existing barrier 6’ away from the parapet. Sector C : Existing: 32’-2” physical barrier with three (3) Caution 2 sign on posts on the east side of sector and a 16’-4” physical barrier with one (1) Caution 2 sign on the middle post on the west side of sector Existing: Two (2) Caution 2 signs behind sector Existing: Two (2) Caution 2 signs on screen wall in front of sector To be installed: Caution 2 sign on every post. Move existing barrier 6’ away from the parapet. OSC Engineering Inc. Page 14/21 FCC MPE Limits (from OET-65) Occupational/controlled2 exposure limits apply to situations in which persons are exposed as a consequence of their employment and in which those persons who are exposed have been made fully aware of the potential for exposure and can exercise control over their exposure. Occupational/controlled exposure limits also apply where exposure is of a transient nature as a result of incidental passage through a location where exposure levels may be above general population/uncontrolled limits (see below), as long as the exposed person has been made fully aware of the potential for exposure and can exercise control over his or her exposure by leaving the area or by some other appropriate means. As discussed later, the occupational/controlled exposure limits also apply to amateur radio operators and members of their immediate household. General population/uncontrolled3 exposure limits apply to situations in which the general public may be exposed or in which persons who are exposed as a consequence of their employment may not be made fully aware of the potential for exposure or cannot exercise control over their exposure. Therefore, members of the general public would always be considered under this category when exposure is not employment-related, for example, in the case of a telecommunications tower that exposes persons in a nearby residential area. 2 OET-65 “Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields pg. 9. 3 OET-65 “Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields pg. 9. OSC Engineering Inc. Page 15/21 Limits for Maximum Permissible Exposure (MPE)4 “The FCC Exposure limits are based on data showing that the human body absorbs RF energy at some frequencies more efficiently than at others. The most restrictive limits occur in the frequency range of 30-300MHz where whole-body absorption of RF energy by human beings is most efficient. At other frequencies whole-body absorption is less efficient, and, consequently, the MPE limits are less restrictive.”5 4 OET-65 “FCC Guidelines Table 1 pg. 72. 5 OET-65 “FCC Guidelines for Evaluating Exposure to RF Emissions”, pg. 8 OSC Engineering Inc. Page 16/21 Limits for Maximum Permissible Exposure (MPE) continued 6 “MPE Limits are defined in terms of power density (units of milliwatts per centimeter squared: mW/cm2), electric field strength (units of volts per meter: V/m) and magnetic field strength (units of amperes per meter: A/m). In the far-field of a transmitting antenna, where the electric field vector (E), the magnetic field vector (H), and the direction of propagation can be considered to be all mutually orthogonal (“[plane-wave” conditions], these quantities are related by the following equation: 6 OET-65 “FCC Guidelines Table 1 pg. 72. OSC Engineering Inc. Page 17/21 RF Safety Alerting Signs 7 7 AT&T ND-00059 Rev. 5.1 RF exposure: Responsibilities and Guidelines page 72 to 73 Caution Sign 2 Warning Sign 1B Caution Sign 2B (Tower) Caution Sign 2C (5x7) Notice Sign 2 Notice Decal (1’, 2’, 3’) Caution Sign 1 Notice Sign 1 OSC Engineering Inc. Page 18/21 RF Safety Information Signs 8 8 AT&T ND-00059 Rev.5.1 RF exposure: Responsibilities and Guidelines page 75 to 76 Information Sign 2 (reduced size) Information Sign 2 Trilingual Sign Information Sign 1 Information Sign 4 Information Sign 3 OSC Engineering Inc. Page 19/21 Limitations OSC Engineering completed this report based on information and data provided by the client and on-site data collection. The data provided by the client is assumed to be accurate. This report is completed by OSC Engineering to determine whether the wireless communications facility complies with the Federal Communications Commission (FCC) Radio Frequency (RF) Safety Guidelines. The Office of Engineering and Technology (OET-65) Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Radiation has been prepared to provide assistance in determining whether proposed or existing transmitting facilities, operations or devices comply with limits for human exposure to radiofrequency (RF) fields adopted by the Federal Communications Commission (FCC)9. As the site is being upgraded and changed this report will become obsolete. Use of this document will not hold OSC Engineering Inc. nor it’s employees liable legally or otherwise. This report shall not be used as a determination as to what is safe or unsafe on a given site. All workers or other people accessing any transmitting site should have proper EME awareness training. This includes, but is not limited to, obeying posted signage, keeping a minimum distance from antennas, watching EME awareness videos and formal classroom training. 9 OET-65 “FCC Guidelines for Evaluating Exposure to RF Emissions”, pg. 1 OSC Engineering Inc. Page 20/21 AT&T Barrier Guidelines Environmental, Health and Safety (EH&S) guidelines prohibit construction of RF safety barriers that extend to, or are within the 6-ft setback from, unprotected roof edges but do not meet the OSHA fall protection requirements of 29 CFR 1910.23 and 29 CFR 1926.500 through 1926.503. The following details are intended to assist AT&T RF safety engineers and RSVs in meeting the AT&T Mobility RF safety compliance guidelines as defined in ND-00059. Whereas, AT&T employees and contractors working within 6 ft. from an unprotected roof edge must follow OSHA guidelines with respect to fall protection and roof line safety.10 For Clarity: Unprotected roof edge refers to a parapet less than thirty-six (36) inches in height. 10 RF Safety Barrier 6-ft Rule v3_ehscmts_EHS cmts_ws, “Installing Radio Frequency (RF) safety barriers on roofs with unprotected edges job aid” Page 1 Overview OSC Engineering Inc. Page 21/21 AT&T Antenna Shut-Down Protocol AT&T provides Lockout/Tagout (LOTO) procedures in Section 9.411 (9.4.1- 9.4.9) in the ND-00059. These procedures are to be followed in the event of anyone who needs access at or in the vicinity of transmitting AT&T antennas. Contact AT&T when accessing the rooftop near the transmitting antennas. Below is information regarding when to contact an AT&T representative. 9.4.7 Maintenance work being performed near transmitting antennas Whenever anyone is working within close proximity to the transmitting antenna(s), the antenna sector, multiple sectors, or entire cell site may need to be shut down to ensure compliance with the applicable FCC MPE limit. This work may include but is not limited to structural repairs, painting or non-RF equipment services by AT&T personnel/contractors or the owner of a tower, water tank, rooftop, or other low-centerline sites. The particular method of energy control will depend on the scope of work (e.g., duration, impact to the antenna or transmission cabling, etc.) and potential for RF levels to exceed the FCC MPE limits for General Population/Uncontrolled environments 9.4.8 AT&T Employees and Contractors AT&T employees and contractors performing work on AT&T cell sites must be trained in RF awareness and must exercise control over their exposure to ensure compliance with the FCC MPE limit for Occupational/Controlled Environments (“Occupational MPE Limit”). The rule of staying at least 3 feet from antennas is no longer always adequate to prevent exposure above the Occupational MPE Limit. That general rule was applied early in the development of cellular when omni-directional antennas were primarily used and later when wide-beamwidth antennas were used. That application was then appropriate for the Occupational exposure category. However, the current prevalence of antennas with 60- and 70- degree horizontal half-power beamwidths at urban and suburban GSM and UMTS/HSDPA sites raises some question about the continued reliability of the 3-foot rule. Antennas with low bottom-tip heights and total input powers around 70-80 W can produce exposure levels exceeding the Occupational MPE Limits at 4 feet, and these levels can be augmented by emissions of co-located operators. Therefore, AT&T employees and contractors should apply the above general work procedures and use an RF personal monitor to assess exposure levels within the work vicinity. 9.4.9 Other Incidental Workers All other incidental workers who are not trained in RF safety are considered general public and subject to the FCC MPE limits for General Population/Uncontrolled Environments. In such instance, the M-RFSC (primary contact) or R-RFSC (secondary contact) must refer to the Mobility RF site survey plan to assess the potential RF exposure levels associated with the antenna system. If capable of exceeding the FCC General Population/Uncontrolled MPE limit, then local sector/site shutdown is necessary. The FE/FT must also follow the local shutdown procedure and use their RF personal monitor as a screening tool for verification, as necessary. 11 ND-00059_Rev_5.1 “Lockout/Tagout (LOTO) Procedures” Page 45.