Radio Frequency-EME REPORT
Radio Frequency –Electromagnetic Energy
(RF-EME) Compliance Report
Site No. CCL02037
MRSFR079536, MRSFR079540, MRSFR079565
Blackberry Farm Golf Course
10110 California Oak Wa
Cupertino, California 95014
Santa Clara County
37.32497310; -122.07507000 NAD83
Transmission Tower
The proposed AT&T installation will be in compliance with FCC regulations
upon proper installation of recommended signage.
EBI Project No. 6222000234
January 31, 2022
Prepared for:
AT&T Mobility, LLC
c/o MasTec Network Solutions
3443 Airport Road
Sacramento, CA 95834
Prepared by:
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T ABLE OF C ONTENTS
E XECUTIVE S UMMARY ..................................................................................................................... 1
1.0 F EDERAL C OMMUNICATIONS C OMMISSION (FCC)R EQUIREMENTS................................... 3
2.0 AT&TRF E XPOSURE P OLICY R EQUIREMENTS .................................................................... 5
3.0 W ORST-C ASE P REDICTIVE M ODELING ................................................................................. 5
4.0 R ECOMMENDED S IGNAGE/C OMPLIANCE P LAN .................................................................... 7
5.0 S UMMARY AND C ONCLUSIONS.............................................................................................8
6.0 L IMITATIONS ......................................................................................................................... 8
A PPENDICES
Appendix A Personnel Certifications
Appendix B Compliance/Signage Plan
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E XECUTIVE S UMMARY
Purpose of Report
EnviroBusiness Inc. (dba EBI Consulting) has been contracted by AT&T Mobility, LLC to conduct radio
frequency electromagnetic (RF-EME) modeling for AT&T Site CCL02037 located at 10110 California Oak
Wa in Cupertino, California to determine RF-EME exposure levels from proposed AT&T wireless
communications equipment at this site. As described in greater detail in Section 1.0 of this report, the
Federal Communications Commission (FCC) has developed Maximum Permissible Exposure (MPE) Limits
for general public exposures and occupational exposures. This report summarizes the results of RF-EME
modeling in relation to relevant FCC RF-EME compliance standards for limiting human exposure to RF-
EME fields.
This report contains the RF EME analysis for the site, including the following:
Site Plan with antenna locations
Graphical representation of theoretical MPE fields based on modeling
Graphical representation of recommended signage and/or barriers
This document addresses the compliance of AT&T’s transmitting facilities independently and in relation
to all collocated facilities at the site.
Statement of Compliance
A site is considered out of compliance with FCC regulations if there are areas that exceed the FCC
exposure limits and there are no RF hazard mitigation measures in place. Any carrier which has an
installation that contributes more than 5% of the applicable MPE must participate in mitigating these RF
hazards.
As presented in the sections below, based on worst-case predictive modeling, there are no modeled
exposures on any accessible utility line level and ground walking/working surface related to ATT’s
proposed antennas that exceed the FCC’s occupational and/or general public exposure limits at this site.
As such, the proposed AT&T installation is in compliance with FCC regulations upon proper installation
of recommended signage and/or barriers.
AT&T Recommended Signage/Compliance Plan
AT&T’s RF Exposure: Responsibilities, Procedures & Guidelines document, dated October 28, 2014,
requires that:
1.All sites must be analyzed for RF exposure compliance;
2.All sites must have that analysis documented; and
3.All sites must have any necessary signage and barriers installed.
Site compliance recommendations have been developed based upon protocols presented in AT&T’s RF
Exposure: Responsibilities, Procedures & Guidelines document, dated October 28, 2014, additional
guidance provided by AT&T, EBI’s understanding of FCC and OSHA requirements, and common industry
practice. Barrier locations have been identified (when required) based on guidance presented in AT&T’s
RF Exposure: Responsibilities, Procedures & Guidelines document, dated October 28, 2014.
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The following signage is recommendedat this site:
Yellow CAUTION 2 sign posted at the base of the transmission tower near the climbing ladder.
The signage proposed for installation at this site complies with AT&T’s RF Exposure: Responsibilities,
Procedures & Guidelines document and therefore complies with FCC and OSHA requirements. Barriers
are not recommended on this site. To reduce the risk of exposure and/or injury, EBI recommends that
access to the transmission tower or areas associated with the active antenna installation be restricted and
secured where possible. More detailed information concerning site compliance recommendations is
presented in Section 4.0 and Appendix B of this report.
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1.0F EDERAL C OMMUNICATIONS C OMMISSION (FCC)R EQUIREMENTS
The FCC has established Maximum Permissible Exposure (MPE) limits for human exposure to
Radiofrequency Electromagnetic (RF-EME) energy fields, based on exposure limits recommended by the
National Council on Radiation Protection and Measurements (NCRP) and, over a wide range of
frequencies, the exposure limits developed by the Institute of Electrical and Electronics Engineers, Inc.
(IEEE) and adopted by the American National Standards Institute (ANSI) to replace the 1982 ANSI
guidelines. Limits for localized absorption are based on recommendations of both ANSI/IEEE and NCRP.
The FCC guidelines incorporate two separate tiers of exposure limits that are based upon
occupational/controlled exposure limits (for workers) and general public/uncontrolled exposure limits for
members of the general public.
Occupational/controlled 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 public/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.
General public/uncontrolled 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.
Table 1 and Figure 1 (below), which are included within the FCC’s OET Bulletin 65, summarize the MPE
limits for RF emissions. These limits are designed to provide a substantial margin of safety. They vary by
frequency to take into account the different types of equipment that may be in operation at a particular
facility and are “time-averaged” limits to reflect different durations resulting from controlled and
uncontrolled exposures.
2
The FCC’s MPEs are measured in terms of power (mW) over a unit surface area (cm). Known as the
power density, the FCC has established an occupational MPE of 5 milliwatts per square centimeter
2
2 for equipment operating in the 1900 MHz frequency
(mW/cm) and an uncontrolled MPE of 1 mW/cm
2
range
. For the AT&T equipment operating at 850 MHz, the FCC’s occupational MPE is 2.83 mW/cm and
2
an uncontrolled MPE of 0.57 mW/cm. For the AT&T equipment operating at 700 MHz, the FCC’s
22
occupational MPE is 2.33 mW/cm and an uncontrolled MPE of 0.47 mW/cm. These limits are considered
protective of these populations.
Table 1: Limits for Maximum Permissible Exposure (MPE)
(A) Limits for Occupational/Controlled Exposure
Frequency Range Electric Field Magnetic Field Averaging Time
Power Density (S)
22
(MHz)Strength (E) Strength (H) \[E\], \[H\], or S
2
(mW/cm)
(V/m) (A/m) (minutes)
0.3-3.0 614 1.63 (100)* 6
2
3.0-30 1842/f 4.89/f (900/f)*6
30-300 61.4 0.163 1.0 6
300-I,500 -- --f/300 6
1,500-100,000-- --5 6
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Table 1: Limits for Maximum Permissible Exposure (MPE)
(A) Limits for Occupational/Controlled Exposure
Frequency Range Electric Field Magnetic Field Averaging Time
Power Density (S)
22
(MHz)Strength (E) Strength (H) \[E\], \[H\], or S
2
(mW/cm)
(V/m) (A/m) (minutes)
(B) Limits for General Public/Uncontrolled Exposure
Frequency Range Electric Field Magnetic Field Averaging Time
Power Density (S)
22
(MHz)Strength (E) Strength (H) \[E\], \[H\], or S
2
(mW/cm)
(V/m) (A/m) (minutes)
0.3-1.34 614 1.63 (100)* 30
2
1.34-30 824/f 2.19/f (180/f)*30
30-300 27.50.0730.230
300-I,500 -- --f/1,500 30
1,500-100,000-- --1.0 30
f = Frequency in (MHz)
* Plane-wave equivalent power density
)
2
Power Density (mW/cm
Based on the above, the most restrictive thresholds for exposures of unlimited duration to RF energy for
several personal wireless services are summarized below:
Approximate Occupational
Personal Wireless Service Public MPE
Frequency MPE
22
Microwave (Point-to-Point) 5,000 - 80,000 MHz 5.00 mW/cm 1.00 mW/cm
22
Broadband Radio (BRS) 2,600 MHz 5.00 mW/cm 1.00 mW/cm
22
Wireless Communication (WCS) 2,300 MHz 5.00 mW/cm 1.00 mW/cm
2 2
Advanced Wireless (AWS) 2,100 MHz 5.00 mW/cm1.00 mW/cm
22
Personal Communication (PCS) 1,950 MHz 5.00 mW/cm 1.00 mW/cm
22
Cellular Telephone 870 MHz 2.90 mW/cm 0.58 mW/cm
22
Specialized Mobile Radio (SMR) 855 MHz 2.85 mW/cm 0.57 mW/cm
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Approximate Occupational
Personal Wireless Service Public MPE
Frequency MPE
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Long Term Evolution (LTE) 700 MHz 2.33 mW/cm 0.47 mW/cm
22
Most Restrictive Frequency Range 30-300 MHz1.00 mW/cm 0.20 mW/cm
MPE limits are designed to provide a substantial margin of safety. 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.
Personal Communication (PCS) facilities used by AT&T in this area operate within a frequency range of
700-1900 MHz. Facilities typically consist of: 1) electronic transceivers (the radios or cabinets) connected
to wired telephone lines; and 2) antennas that send the wireless signals created by the transceivers to be
received by individual subscriber units (PCS telephones). Transceivers are typically connected to antennas
by coaxial cables.
Because of the short wavelength of PCS services, the antennas require line-of-site paths for good
propagation, and are typically installed above ground level. Antennas are constructed to concentrate
energy towards the horizon, with as little energy as possible scattered towards the ground or the sky.
This design, combined with the low power of PCS facilities, generally results in no possibility for exposure
to approach Maximum Permissible Exposure (MPE) levels, with the exception of areas directly in front of
the antennas.
2.0AT&TRF E XPOSURE P OLICY R EQUIREMENTS
AT&T’s RF Exposure: Responsibilities, Procedures & Guidelines document, dated October 28, 2014,
requires that:
1.All sites must be analyzed for RF exposure compliance;
2.All sites must have that analysis documented; and
3.All sites must have any necessary signage and barriers installed.
Pursuant to this guidance, worst-case predictive modeling was performed for the site. This modeling is
described below in Section 3.0. Lastly, based on the modeling and survey data, EBI has produced a
Compliance Plan for this site that outlines the recommended signage and barriers. The recommended
Compliance Plan for this site is described in Section 4.0.
3.0W ORST-C ASE P REDICTIVE M ODELING
In accordance with AT&T’s RF Exposure policy, EBI performed theoretical modeling using RoofMaster™
software to estimate the worst-case power density at the site utility line level and ground-level and/or
nearby rooftops resulting from operation of the antennas. RoofMaster™ is a widely-used predictive
modeling program that has been developed to predict RF power density values for rooftop and tower
telecommunications sites produced by vertical collinear antennas that are typically used in the cellular,
PCS, paging and other communications services. Using the computational methods set forth in Federal
Communications (FCC) Office of Engineering & Technology (OET) Bulletin 65, “Evaluating Compliance
with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields” (OET-65),
RoofMaster™ calculates predicted power density in a scalable grid based on the contributions of all RF
sources characterized in the study scenario. At each grid location, the cumulative power density is
expressed as a percentage of the FCC limits. Manufacturer antenna pattern data is utilized in these
calculations. RoofMaster™ models consist of the Far Field model as specified in OET-65 and an
implementation of the OET-65 Cylindrical Model (Sula9). The models utilize several operational
specifications for different types of antennas to produce a plot of spatially-averaged power densities that
can be expressed as a percentage of the applicable exposure limit. A statistical power factor may be applied
to the antenna system based on guidance from the carrier and system manufacturers.
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For this report, EBI utilized antenna and power data provided by AT&T and compared the resultant worst-
case MPE levels to the FCC’s occupational/controlled exposure limits outlined in OET Bulletin 65.
The assumptions used in the modeling are based upon information provided by AT&T and information
gathered from other sources. Unknown carriers also have antennas on the transmission tower.
Information about these antennas was included in the modeling analysis.
Based on worst-case predictive modeling, there are no modeled exposures on any accessible utility line
level and ground walking/working surface related to ATT’s proposed antennas that exceed the FCC’s
occupational and/or general public exposure limits at this site.
At the nearest walking/working surfaces to the AT&T antennas on the utility line level, the maximum
power density generated by the AT&T antennas is approximately 5.95 percent of the FCC’s general public
limit (1.19 percent of the FCC’s occupational limit). The composite exposure level from all carriers on
this site is approximately 6.67 percent of the FCC’s general public limit (1.33 percent of the FCC’s
occupational limit) at the nearest walking/working surface to each antenna. It should be noted that
percentage of MPE is based on spatially-averaged power densities over a height of six feet, with the height
of the utility line being centered within that spatial range. Based on worst-case predictive modeling, there
are no areas at ground/street level related to the proposed AT&T antennas that exceed the FCC’s
occupational or general public exposure limits at this site. At ground/street level, the maximum power
density generated by the antennas is approximately 10.6 percent of the FCC’s general public limit (2.12
percent of the FCC’s occupational limit).
There are no modeled areas on the utility line level and ground that exceed the FCC’s limits for general
public or occupational exposure in front of the other carrier antennas.
A graphical representation of the RoofMaster™ modeling results is presented in Appendix B.
Microwave dish antennas are designed for point-to-point operations at the elevations of the installed
equipment rather than ground-level coverage. Based on AT&T’s RF Exposure: Responsibilities, Procedures
& Guidelines document, dated October 28, 2014, microwave antennas are considered compliant if they
are higher than 20 feet above any accessible walking/working surface. There are no microwaves installed
at this site.
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4.0R ECOMMENDED S IGNAGE/C OMPLIANCE P LAN
Signs are the primary means for control of access to areas where RF exposure levels may potentially
exceed the MPE. As presented in the AT&T guidance document, the signs must:
Be posted at a conspicuous point;
Be posted at the appropriate locations;
Be readily visible; and
Make the reader aware of the potential risks prior to entering the affected area.
The table below presents the signs that may be used for AT&T installations.
CRAN / HETNET Small Cell Decals / Signs Alerting Signs
NOTICE
DECAL
TRILINGUAL
NOTICE 2
NOTICE
NOTICE
SIGN
CAUTION 2 –
CAUTION 2A
ROOFTOP
CAUTION
DECAL
CAUTION 2C -
CAUTION 2B -
PARAPETS
TOWER
CAUTION
SIGN
WARNING 1B
WARNING 2A
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Based upon protocols presented in AT&T’s RF Exposure: Responsibilities, Procedures & Guidelines
document, dated October 28, 2014, and additional guidance provided by AT&T, the following signage is
recommended on the site:
Yellow CAUTION 2 sign posted at the base of the transmission tower near the climbing ladder.
No barriers are required for this site. Barriers should be constructed of weather-resistant plastic or
wood fencing. Barriers may consist of railing, rope, chain, or weather-resistant plastic if no other types
are permitted or are feasible. Painted stripes should only be used as a last resort and only in regions where
there is little chance of snowfall. If painted stripes are selected as barriers, it is recommended that the
stripes and signage be illuminated. The signage and any barriers are graphically represented in the Signage
Plan presented in Appendix B. It is important to note that this Signage Plan is specific for AT&T antennas
only, and does not address RF emissions of other carrier antennas.
5.0S UMMARY AND C ONCLUSIONS
EBI has prepared this Radiofrequency Emissions Compliance Report for the proposed AT&T
telecommunications equipment at the site located at 10110 California Oak Wa in Cupertino, California.
EBI has conducted theoretical modeling to estimate the worst-case power density from AT&T antennas
and other carrier antennas to document potential MPE levels at this location and ensure that site control
measures are adequate to meet FCC and OSHA requirements, as well as AT&T’s corporate RF safety
policies. As presented in the preceding sections, based on worst-case predictive modeling, there are no
modeled exposures on any accessible utility line level and ground walking/working surface related to ATT’s
proposed antennas that exceed the FCC’s occupational and/or general public exposure limits at this site.
To reduce the risk of exposure and/or injury, EBI recommends that access to the transmission tower or
areas associated with the active antenna installation be restricted and secured where possible. Signage is
recommended at the site as presented in Section 4.0 and Appendix B. Posting of the signage brings the
site into compliance with FCC rules and regulations and AT&T’s corporate RF safety policies. Workers
or members of the general public accessing areas directly in front of the other carrier antennas should
contact the carrier and/or landlord to determine appropriate setbacks or measures to safely occupy those
areas.
6.0L IMITATIONS
This report was prepared for the use of AT&T Mobility, LLC to meet requirements outlined in AT&T’s
corporate RF safety guidelines. It was performed in accordance with generally accepted practices of other
consultants undertaking similar studies at the same time and in the same locale under like circumstances.
The conclusions provided by EBI and its partners are based solely on information supplied by AT&T,
including modeling instructions, inputs, parameters and methods. Calculations, data, and modeling
methodologies for C Band equipment Include a statistical factor reducing the power to 32% of maximum
theoretical power to account for spatial distribution of users, network utilization, time division duplexing,
and scheduling time. AT&T recommends the use of this factor based on a combination of guidance from
its antenna system manufacturers, supporting international industry standards, industry publications, and
its extensive experience. The observations in this report are valid on the date of the investigation. Any
additional information that becomes available concerning the site should be provided to EBI so that our
conclusions may be revised and modified, if necessary. This report has been prepared in accordance with
Standard Conditions for Engagement and authorized proposal, both of which are integral parts of this
report. No other warranty, expressed or implied, is made.
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Appendix A
Personnel Certifications
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Preparer Certification
I, Karl Nicoleau, state that:
I am an employee of EnviroBusiness Inc. (d/b/a EBI Consulting), which provides RF-EME safety and
compliance services to the wireless communications industry.
I have successfully completed RF-EME safety training, and I am aware of the potential hazards from
RF-EME and would be classified “occupational” under the FCC regulations.
I am fully aware of and familiar with the Rules and Regulations of both the Federal Communications
Commissions (FCC) and the Occupational Safety and Health Administration (OSHA) with regard
to Human Exposure to Radio Frequency Radiation.
I have been trained in on the procedures outlined in AT&T’s RF Exposure: Responsibilities,
Procedures & Guidelines document (dated October 28, 2014) and on RF-EME modeling using
RoofMaster™ modeling software.
I have reviewed the data provided by the client and incorporated it into this Site Compliance
Report such that the information contained in this report is true and accurate to the best of my
knowledge.
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Reviewed and Approved by:
Michael McGuire
Electrical Engineer
mike@h2dc.com
Note that EBI’s scope of work is limited to an evaluation of the Radio Frequency – Electromagnetic Energy
(RF-EME) field generated by the antennas and broadcast equipment noted in this report. The engineering
and design of the building and related structures, as well as the impact of the antennas and broadcast
equipment on the structural integrity of the building, are specifically excluded from EBI’s scope of work.
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Appendix B
Compliance/Signage Plan
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Nearest Walking Surface Simulation
EQUIPMENT=10’
Proposed CAUTION
2 Sign at Base of
Lattice Tower
EQUIPMENT=10’
Existing Sign
Proposed Sign
Installed Sign
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