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AMEND 2019-0001; PCS 150 MOUNT KELLY; RADIO FREQUENCY SITE COMPLIANCE REPORT; 2018-12-27
SITESAFE RF COMPLIANCE EXPERTS 8618 Westwood Center Drive, Suite 315, Vienna, VA 22182 703.27 6.1100 • 703.27 6.1 169 fax info@sitesafe.com • www.sitesafe.com Crown Castle on behalf of Sprint Site ID -880230 Assessment Purpose -Sprint app 408051 Site Name -Mt Kelly Site Compliance Report 2237 Janis Way Carlsbad, CA 92008 Site visit date: December 26, 2018 Site visit time: 1 :30 PM Site survey by: Robert Davis Latitude: N33-9-54.51 Longitude: Wl 17-19-19 .95 Structure Type: Monopole Report generated date: December 27, 2018 Report by: Sam Cosgrove Customer Contact: Jake Sowers 0 8 2019 CITY O CARLSBAD PLANN NG DIVISION Sprint is compliant and will remain complaint upon implementation of the proposed changes. © 2018 Sitesafe, LLC. Vienna, VA Klaus Bender Registered Professional Engineer (Electrical) State of California, 18131, Expires 2019-June-30 Date Signed: 2018-December-27 ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ Sprint 880230 -Mt Kelly Radio Frequency (RF) Site Compliance Report 2237 Janis Way, Carlsbad, CA 92008 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.27 6.1100 • info@sitesafe.com Table of Contents 1 EXECUTIVE SUMMARY ....................................................................................... 2 2 REGULATORY BASIS ........................................................................................... 3 2.1 FCC RULES AND REGULATIONS ............................................................................ 3 2.2 OSHA STATEMENT······························································································ 4 3 SITE COMPLIANCE ............................................................................................. 5 3.1 SITE COMPLIANCE STATEMENT·············································································· 5 3.2 ACTIONS FOR SITE COMPLIANCE .......................................................................... 5 4 SAFETY PLAN AND PROCEDURES ...................................................................... 6 5 ANALYSIS ........................................................................................................... 7 5.1 RF EMISSIONS DIAGRAM ·················································································•"· 7 5.2 SITE MEASUREMENTS .......................................................................................... 13 6 SITE AUDIT ........................................................................................................ 15 6. 1 SITE ACCESS PROCEDURES ........••...................................................... ················· 15 6.2 ANTENNA INVENTORY························································································ 16 6.3 SITE PICTURES ..................................... ··························································· .... 18 7 FIELD TECHNICIAN CERTIFICATION ................................................................ 24 8 ENGINEER CERTIFICATION .............................................................................. 25 APPENDIX A -STATEMENT OF LIMITING CONDITIONS ......................................... 26 APPENDIX B -ASSUMPTIONS AND DEFINITIONS .................................................. 27 GENERAL MODEL ASSUMPTIONS ···············•··················································•················ 27 USE OF GENERIC ANTENNAS························································································· 27 DEFINITIONS ................................................................................................................. 28 APPENDIX C -RULES & REGULATIONS ................................................................... 30 EXPLANATION OF APPLICABLE RULES AND REGULATIONS .................................................. 30 OCCUPATIONAL ENVIRONMENT EXPLAINED .......•••...................••.•................................... 30 APPENDIX D -GENERAL SAFETY RECOMMENDATIONS ....................................... 31 ADDITIONAL INFORMATION ......................................................•••.................................. 32 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.27 6.1100 • info@sitesafe.com 1 Executive Summary Crown Castle on behalf of Sprint has contracted with Sitesafe, LLC. (Sitesafe), an independent Radio Frequency (RF) regulatory and engineering consulting firm, to determine whether the proposed communications site, 880230 -Mt Kelly, located at 2237 Janis Way, Carlsbad, CA, is in compliance with Federal Communication Commission (FCC) Rules and Regulations for RF emissions. Sitesafe's field personnel visited 880230 -Mt Kelly on December 26, 2018. This report contains a detailed summary of the RF environment at the site including: • Site compliance determination; • Photographs of the site; • Diagram of the site; • Inventory of the make / model of all transmitting antennas found on the site (where possible); • Record of any Maximum Permissible Exposure ("MPE") measurements taken on the site, as applicable; and • Theoretical MPE based on modeling. This report addresses exposure to radio frequency electromagnetic fields in accordance with the FCC Rules and Regulations for all individuals, classified in two groups, "Occupational or Controlled" and "General Public or Uncontrolled." Sprint is compliant and will remain compliant with the FCC rules and regulations, as described in OET Bulletin 65, upon implementation of the proposed changes. During our field visit, Sitesafe documented the presence and location of signs and barriers. This document specifically addresses compliance of Sprint's transmitting facilities independently and in relation to all collocated transmitting facilities, which together constitute the RF environment at the site. If you have any questions regarding RF safety and regulatory compliance, please do not hesitate to contact Sitesafe's Customer Support Department at (703) 276- 1100. 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.27 6.1100 • info@sitesafe.com Page 2 2 Regulatory Basis 2.1 FCC Rules and Regulations In 1996, the Federal Communications Commission (FCC) adopted regulations for the evaluating of the effects of RF emissions in 47 CFR § 1.1 307 and 1.1310. The guideline from the FCC Office of Engineering and Technology is Bulletin 65 ("OET Bulletin 65"), Evaluating Compliance with FCC Guidelines for Human Exposure to Radio Frequency Electromagnetic Fields, Edition 97-01, published August 1997. Since 1996 the FCC periodically reviews these rules and regulations as per their congressional mandate. FCC regulations define two separate tiers of exposure limits: Occupational or "Controlled environment" and General Public or "Uncontrolled environment". The General Public limits are generally five times more conservative or restrictive than the Occupational limit. These limits apply to accessible areas where workers or the general public may be exposed to Radio Frequency (RF) electromagnetic fields. Occupational or Controlled limits apply in situations in which persons are exposed as a consequence of their employment and where those persons exposed have been made fully aware of the potential for exposure and can exercise control over their exposure. An area is considered a Controlled environment when access is limited to these aware personnel. Typical criteria are restricted access (i.e. locked or a larmed doors, barriers, etc.) to the areas where antennas are located coupled with proper RF warning signage. A site with Controlled environments is evaluated with Occupational limits. All other areas are considered Uncontrolled environments. If a site has no access controls or no RF warning signage it is evaluated with General Public limits. The t heoretical modeling of the RF electromagnetic fields has been performed in accordance with OET Bulletin 65. The Maximum Permissible Exposure (MPE) limits utilized in this analysis are outlined in the following diagram: FCC Limits for Maximum Permissible Exposure (MPE) Plane-wave Equivalent Power Density ~ ., 3 1000 ,---------;::::======;- -Occupational --General Public / \ / .._ ___ / ~ 0.1 -!------------- 0.01 +-----,----,---,-----r-~ 0 10 100 1,000 10,000 Frequency (MHz) 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.276.1100 • info@sitesafe.com Page 3 --..... --=-·----- Limits for Occupational/Controlled Exposure (MPE) Frequency Electric Magnetic Power Averaging Time IE I 2, Range Field Field Density (S) I H 12 or S (minutes) (MHz) Strength (E) Strength (mW/cm2) (V/m) (H) (A/m) 0.3-3.0 614 1.63 (100)* 6 3.0-30 1842/f 4.89/f (900/f2)* 6 30-300 61.4 0.163 1.0 6 300-1500 f/300 6 1500-5 6 100,000 Limits for General Population/Uncontrolled Exposure (MPE) Frequency Electric Magnetic Power Averaging Time IE I 2, Range Field Field Density (S) I H 12 or S (minutes) (MHz) Strength (E) Strength (mW/cm2) (V/m) (H) (A/m) 0.3-1.34 614 1.34-30 824/f 30-300 27.5 300-1500 1500- 100,000 f = frequency in MHz 1.63 2.19/f 0.073 (100)* 30 (180/t2)* 30 0.2 30 f/1500 30 1.0 30 *Plane-wave equivalent power density 2.2 OSHA Statement The General Duty clause of the OSHA Act (Section 5) outlines the occupational safety and health responsibilities of the employer and employee. The General Duty clause in Section 5 states: (a) Each employer- ( 1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; (2) shall comply with occupational safety and health standards promulgated under this Act. (b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct. OSHA has defined Radiofrequency and Microwave Radiation safety standards for workers who may enter hazardous RF areas. Regulation Standards 29 CFR § 1910.147 identify a generic Lock Out Tag Out procedure aimed to control the unexpected energization or start up of machines when maintenance or service is being performed. 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.27 6.1100 • info@sitesafe.com Page4 3 Site Compliance 3.1 Site Compliance Statement Upon evaluation of the cumulative RF emission levels from all operators at this site, and a thorough review of site access procedures, RF hazard signage and visible antenna locations, Sitesafe has determined that: Sprint is compliant with the FCC rules and regulations, as described in OET Bulletin 65, and will remain compliant upon implementation of the proposed changes. The compliance determination is based on General Public MPE levels due to theoretical modeling and/or physical measurements, RF signage placement, proposed antenna inventory and the level of restricted access to the antennas at the site. Any deviation from the Sprint's proposed deployment plan could result in the site being rendered non-compliant. Measurements have also been performed to validate the assumptions used in our theoretical modeling of this site. Modeling is used for determining compliance and the percentage of MPE contribution. Measurements provide a view of MPE percentage levels at the site at the time of Sitesafe's visit and are used to validate modeling results. 3.2 Actions for Site Compliance Based on common industry practice and our understanding of FCC and OSHA requirements, this section provides a statement of recommendations for site compliance. RF alert signage recommendations have been proposed based on existing measurements and theoretical analysis of MPE levels. Sitesafe has documented the locations of any RF signs and barriers that are required for compliance. Barriers can consist of locked doors, fencing, railing, rope, chain, paint striping or tape, combined with RF alert signage. This site will be compliant with the FCC rules and regulations. 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.27 6.1100 • info@sitesafe.com Page 5 SITESAFE 4 Safety Plan and Procedures The following items are general safety recommendations that should be administered on a site by site basis as needed by the carrier. General Maintenance Work: Any maintenance personnel required to work immediately in front of antennas and / or in areas indicated as above 100% of the Occupational MPE limits should coordinate with the wireless operators to disable transmitters during their work activities. Training and Qualification Verification: All personnel accessing areas indicated as exceeding the General Population MPE limits should have a basic understanding of EME awareness and RF Safety procedures when working around transmitting antennas. Awareness training increases a workers understanding to potential RF exposure scenarios. Awareness can be achieved in a number of ways (e.g. videos, formal classroom lecture or internet based courses). Physical Access Control: Access restrictions to transmitting antennas locations is the primary element in a site safety plan. Examples of access restrictions are as follows: • Locked door or gate • Alarmed door • Locked ladder access • Restrictive Barrier at antenna (e.g. Chain link with posted RF Sign) RF Signage: Everyone should obey all posted signs at all times. RF signs play an important role in properly warning a worker prior to entering into a potential RF Exposure area. Assume all antennas are active: Due to the nature of telecommunications transmissions, an antenna transmits intermittently. Always assume an antenna is transmitting. Never stop in front of an antenna. If you have to pass by an antenna, move through as quickly and safely as possible thereby reducing any exposure to a minimum. Maintain a 3 foot clearance from all antennas: There is a direct correlation between the strength of an EME field and the distance from the transmitting antenna. The further away from an antenna, the lower the corresponding EME field is. Site RF Emissions Diagram: Section 5 of this report contains an RF Diagram that outlines various theoretical Maximum Permissible Exposure (MPE) areas at the site. The modeling is a worst case scenario assuming a duty cycle of 100% for each transmitting antenna at full power. This analysis is based on one of two access control criteria: General Public criteria means the access to the site is uncontrolled and anyone can gain access. Occupational criteria means the access is restricted and only properly trained individuals can gain access to the antenna locations. 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.27 6.1100 • info@sitesafe.com Page 6 5 Analysis 5.1 RF Emissions Diagram The RF diagram(s) below display theoretical spatially averaged percentage of the Maximum Permissible Exposure for all systems at the site unless otherwise noted. These diagrams use modeling as prescribed in OET Bulletin 65 and assumptions detailed in Appendix B. The key at the bottom of each diagram indicates if percentages displayed are referenced to FCC General Population Maximum Permissible Exposure (MPE) limits. Color coding on the diagram is as follows: • Gray represents areas predicted to be at 5% of the MPE limits, or below. • Green represents areas predicted to be between 5% and 100% of the MPE limits. • Blue represents areas predicted to be between 100% and 500% of the MPE limits. • Yellow represents areas predicted to be between 500% and 5000% of the MPE limits. • Red areas indicated predicted levels greater than 5000% of the MPE limits. The theoretical analysis identified the maximum predicted MPE levels on the Adjacent rooftop to be: Maximum Cumulative Theoretical General Public MPE level: Maximum Sprint Theoretical General Public MPE level: 2.1% <1% General Population diagrams are specified when an area is accessible to the public; i.e. personnel that do not meet Occupational or RF Safety trained criteria, could gain access. If trained occupational personnel require access to areas that are delineated as Blue or above 100% of the limit, Sitesafe recommends that they utilize the proper personal protection equipment (RF monitors), coordinate with the carriers to reduce or shutdown power, or make real-time power density measurements with the appropriate power density meter to determine real-time MPE levels. This will allow the personnel to ensure that their work area is within exposure limits. The key at the bottom also indicates the level or height of the modeling with respect to the main level. The origin is typically referenced to the main rooftop level, or ground level for a structure without access to the antenna level. For example: Average from O feet above to 6 feet above origin and Average from 20 feet above to 26 feet above origin 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.27 6.1100 • info@sitesafe.com Page 7 The first indicates modeling at the main rooftop (or ground) level averaged over 6 feet. The second indicates modeling at a higher level (possibly a penthouse level) of 20 feet averaged over 6 feet. Abbreviations used in the RF Emissions Dia rams PH=##' Penthouse at## feet above main roof M## Measurement## taken durin a site visit As discussed in Section 5, site measurement locations for spatial average measurements collected at the time of Sitesafe's visit have been added to the RF emissions diagram. While the theoretical modeling represents worst case MPE levels based on the assumption(s) detailed above, the measurement data is a snapshot of MPE levels at the time of our visit, and dependent on transmitter duty cycle, system implementation and emissions from other RF sources at nearby antenna sites. 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.27 6.1100 • info@sitesafe.com Page 8 (Feet) 0 30.7 61.3 W\VW.sitesafe.com Site Name:Mt Kelly 12/27/2018 12,19,49 PM RF Exposure Simulation For: Mt Ke lly TOP OF TANK=25' (AGL) ~MOTOROLA MOTOROLA >= 5000 +- % of FCC Public Exposure Limit Spatial average O' -6' "of FCC Public: Erposure limit >= 500 >= 100 >= 5 Ciirrier ldenlifiQtion .,l,TUMOB!lJ"VU( .V(IIIZO'IWIIIH(U •T•MOIIL£ O SP~NT Barrier Proposed B;miers/ Signs <5 TANK ACCESS 2 SPRINT MONOEUCALYPTUS -+----af---+--4--4---+---1--- Sitesafe Q£T .6S Model Near Field Boundary: LS • Aperture Reflection Factor: 1 Spatially Averaged !5' (AGL) MOTOROLA 0 (Feet) 9.8 www.s1tesafe.com Site Name:Mt Kelly 12/27/2018 12'20,58 PM M25 19.6 RF Exposure Si mulation For: Mt Kelly Det ail View >• 5000 % of FCC Public Exposure Limit Spatial average O' -6' "of FCC Public. Exposure Limit >• 500 >• 100 >• 5 Carrier ktentlfiation <5 M7 .AT&•M081U~UC .vu,zONWlll(.05 .TM06'l( o .SP~.NT 0 UN<-.OWH CAllll!!:11 Proposed &arrh:rs/ Signs TANK ACC Sitesafe OET•65 Model Near Field Boundary: 1.5 • Aperture Aenection Factor: 1 Spatially Averaged SPRINT CENTERLINE,. 44' AGL WATER TANK= 25' AGL (Feet) 0 9.1 www.s1tesafe.com Site Name:Ml Kelly 12/27/201812:33:25 PM 18.2 RF Exposure Simulation For: Mt Kelly Elevation View UNKNOWN CARRIER CENTERLINES= 50' & 54' AGL >= 5000 MONOEUCALYPTUS = 45' AGL GROUND LEVEL .. % of FCC Public Exposure Limit Spatial average O' -6' "or FCC Public Exposure Limit >= 500 >= 100 >= 5 C,1rrler Identification .Ar&rMOIIUTVlLC .vt:111z0Nw111russ .,,..oe,u o s,11i.r Proposed IJ.anier.1/ Si1ns +- + +- <5 0 IJ"l'(NOWNCAR!Jltll ROOFTOP = 30' AGI t t Sitesafe OET-65 Model Near field Boundary: 1.5 • Aperture Reflection Factor: 1 Single level (0) 0 (Feet) 27.6 www.sitesafe.com Sate Name:Mt Kelly 12/27/2018 12:23:45 PM -I- 55.2 RF Exposure Simulation For: Mt Kelly Sprint Contribution TOP OF TANK=25' (AGL) 1---- 1 TANK ACCESS 2 SPRINT MONOEUCAL YPTUS ~ 118_,,.,H----/---SPRINT ~ ,~.~C...-"7"'~--GENERATOR EJ MOTOROLA MOTOROLA MONOEUCALYPTUS >= 5000 % of FCC Public Exposure Limit Spatial average O' -6' "of FCC Public h powre Limit >= 500 >= 100 >• 5 Carrier ldentiflcaUon -~r&·MoaiulYuc .V(1uo-,w1~urss .tN"Ot'le o s,;vn Barrier Proposed &aM"lers/ Sl1ns i <5 0 U'l(M>WNCAMIEII. Sitesafe OET-65 Model Near Field Boundary: 1.5 • Aperture Renection Factor: 1 Spatially Averaged 5.2 Site Measurements This section provides a summary of the measurements collected at the site. Actual measurements locations at which these data points were collected are included in the RF emission diagram provided in Section 5 of this report. Two types of measurements were collected at each measurement location: maximum (peak) and spatial average. The spatial average measurement consists of a collection of ten (10) measurements within a ten (10) second time interval taken from zero (0) to six (6) feet in height. The purpose of this measurement technique is to identify the average power density over the dimensions of a typical human body. Table 2 below contains all the measurements collected from accessible areas located at the site at the time of Sitesafe's visit. Whenever possible, measurements are taken in front of the antenna in the transmitting direction. However, because of the antenna configuration at this site, specific emissions could not be discerned from nearby facilities, and no attempt was made to d etermine power density levels from a specific transmitting antenna. Highest Measured Occupational Level: < l % This value is equal to: Highest General Public Level: <5%. Table 1: Soatial Averaae and Maximum Occuoational Measurements Measurements Spatial Maximum Measurements Spatial Maximum Points Ml M2 M3 M4 MS M6 M7 M8 M9 MlO Mll M12 Ml3 M14 M15 Averaae Points <1 % <1 % Ml6 <l % <l % Ml? <l % <1 % Ml8 <l % <l % Ml9 <l % <l % M20 <l % <1 % M21 <l % <l % M22 <l % <1 % M23 <l % <l % M24 <l % <l % M25 <l % <1 % M26 <l % <l % M27 <l % <l % M28 <l % <l % M29 <l % <l % 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.276.1100 • info@sitesafe.com Page 13 Averaae <l % <l % <l % <l % <l % <l % <l % <l % <l % <l % <l % <l % <l % <1 % <l % <l % <l % <l % <1% <l % <1 % <1 % <l % <l % <l % <1 % <l % <l % RF meters and probes have been calibrated and used according to the manufacturer's specifications. Measurements provide a view of the MPE percentage levels at the site at the time of Sitesafe's site visit and are used to validate modeling results. Theoretical modeling is used for determining compliance and the percentage of MPE contributions. An RF Emission diagram has been included in section 5 of this document. All measurement locations are identified in this diagram. The locations of measurements in the RF Emission diagram can be cross referenced with Table 2 (above) to determine the actual spatial average and maximum measurement value per location. 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.276.1100 • info@sitesafe.com Page 14 6 Site Audit 6.1 Site Access Procedures A site visit was conducted on December 26, 2018 at approximately 1 :30 PM. The weather conditions were Sunny with a temperature of 62 degrees. At that time, a diagram of the site was verified, obtained or produced containing the locations of all visible antennas, RF signs and access points on site. These antennas were recorded and photographed. The antenna make(s)/model(s) and centerlines were verified where possible. The following information was gathered regarding site access at the facility. Site access was locked or restricted at the time of the site visit. Sprint's mono-eucalyptus is located inside a locked water compound and is not surrounded by a fence. Sprint's equipment is surrounded by a fence with a locked gate. RF Advisory signage was posted at all site access points. Figure 1: Site Access 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.276.1100 • inlo@sitesale.com Page 15 6.2 Antenna Inventory The Antenna Inventory shows a ll transmitting antennas at the site. This inventory was verified on site, and was utilized by Sitesafe to perform theoretical modeling of RF emissions. The inventory coincides with the site diagrams in this report, identifying each antenna's location at 880230 -Mt Kelly. The antenna information collected includes the following information: • Licensee or wireless operator name • Frequency or frequency band • Transmitter power -Effective Radiated Power ("ERP"), or Equivalent Isotropic Radiated Power ("EIRP") in Watts • Antenna manufacturer make, model, and gain For other carriers at this site, the use of "Generic" as an antenna model, or "Unknown" for an operator means the information with regard to carrier, their FCC license and/or antenna information was not available nor could it be secured w hile on site. Equipment, antenna models and nominal transmit power were used for modeling, based on past experience with radio service providers. 8618 Westwood Center Drive• Suite 315 • Vienno, VA 22182 703.276.1100 • info@sitesafe.com Page 16 Ant f 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Operated By SPRINT SPRINT SPRINT SPRINT SPRINT SPRINT SPRINT SPRINT SPRINT • §!!:!=.§.~!:.~ J The following antenna inventory and representative photographs were obtained or verified during the site visit and were utilized to create the site model diagrams: Tobi• 2: Anl•MG lnv•ntory Antenna Model Ant Type length TX Freq TECH IU Antenna Horlzontal Pow•r Pow ... Power #of ERP (II) (MHz) (Deg) Gain Hall Power Typo Units Trans (Walls) (d9d) Beamwktth (Deg) RFS APXVSPPl 8-C-A20 (Proposed) Panel 6 862 LTE 60 13.37 65 40 TPO Wall 1 869.1 RFS APXVTM l 4-C-120 (Proposed) Panel 4.7 2496 LTE 60 15.86 68 1600 ERP Wall 1 1600 RFS APXVSPPl 8-C -A20 (Proposed) Panel 6 1930 LTE 60 16.27 65 60 TPO Wall 1 2541.9 RFS APXVSPPl 8-C-A20 (Proposed) Panel 6 862 LTE 130 13.37 65 40 TPO Wall 1 869.1 RFS APXVTM 14-C-120 (Proposed) Panel 4.7 2496 LTE 130 15.86 68 1600 ERP Watt 1 1600 RFS APXVSPPl 8-C -A20 (Proposed) Panel 6 1930 LTE 130 16.27 65 60 TPO Wall 1 2541.9 RFS APXVSPP 18-C -A20 (Proposed) Panel 6 862 LTE 220 13.37 65 40 TPO Wall 1 869.1 RFS APXVTM 14-C-120 (Proposed) Panel 4.7 2496 LTE 220 15.86 68 1600 ERP Watt 1 1600 RFS APXVSPP 18-C-A20 (Proposed) Panel 6 1930 LTE 220 16.27 65 60 TPO Watt 1 2541.9 UNKNOWN CARRIER Generic Omni 9.5 450 360 5.97 360 100 ERP Wall 1 100 UNKNOWN CARRIER Generic Yagi 1.2 450 300 9.97 60 100 ERP Wall 1 100 MOTOROLA Generic Omni 14 850 360 9.97 360 1000 ERP Wall 1 1000 MOTOROLA Generic Omni 14 850 360 9.97 360 1000 ERP Wall 1 1000 MOTOROLA Generic Omni 14 850 360 9.97 360 1000 ERP Wall 1 1000 MOTOROLA Generic Omni 14 850 360 9.97 360 1000 ERP Watt 1 1000 MOTOROLA Generic Omni 14 850 360 9.97 360 1000 ERP Wall 1 1000 MOTOROLA Generic Omni 14 850 360 9.97 360 1000 ERP Woll 1 1000 UNKNOWN CARRIER Generic Aperture 2 18000 90 37.66 2 0.01 TPO Watt 1 58.3 UNKNOWN CARRIER Generic Panel 1.7 2400 310 12.01 90 4 ERP Wall 1 4 NOTE: Z indicates relative position of the antenna to the origin location on the site. displayed in the model results diagram. The Z reference indicates antenna height above the main site level unless otherwise indicated. ERP values provided by the client and used in the modeling may be greater than are currently deployed. For other carriers at this site the use of "Generic" as an antenna model or "Unknown" for a wireless operator means the information with regard to carrier. their FCC license and/or antenna information was not available nor could it be secured while on site. Equipment. antenna models and nominal transmit power were used for modeling. based on past experience with radio service providers. 8618 Westwood Center Drive • Suite 315 •Vienna.VA 22182 703.276.1100 • info@sitesofe.com Page 17 z OT EDT (II) 45 0 0 44 0 0 45 0 0 45 0 0 45 0 0 44 0 0 44 0 0 44 0 0 44 0 0 54 0 0 50 0 0 45 0 0 45 0 0 45 0 0 45 0 0 45 0 0 45 0 0 35 0 0 45 0 0 6.3 Figure 2: Sprint Proposed Alpha Sector Antennas 1 through 3 Figure 3: Sprint Proposed Beta Sector Antennas 4 through 6 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.276.1100 • info@sitesafe.com Page 18 _,a:.. • Figure 4: Sprint Proposed Gamma Sector Antennas 7 through 9 Figure 5: Antenna 10 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.276.1100 • info@sitesale.com Page 19 Figure 6: Antenna 11 11/11/2011 11:41 Figure 7: Antennas 12 through 14 8618 Westwood Center Drive • Suite 315 • Vienna, VA 22182 703.276.1100 • info@sitesale.com Page 20 Figure 8: Antennas 15 through 17 Figure 9: Antenna 18 8618 Westwood Center Drive• Suite 315 •Vienna.VA 22182 703.276.1100 • inlo@sitesale.com Page 21 12/2112018 11:4'1 Figure 10: Antenna 19 Figure 11 : Sprint Equipment 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.276.1100 • info@sitesafe.com Page 22 • §!I.':;.§.~f..~ j Figure 12: Motorola Equipment 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.276.1100 • lnfo@sitesafe.com Page 23 7 Field Technician Certification I, Robert Davis, state: That I om on employee. of Sitesafe, LLC., in Vienna, Virginia, which provides RF compliance services to.clients in the wireless communications industry; and That I hove successfully completed RF Safety Awareness training, o m aware of the hazards and, therefore, con be exposed to RF fields classified for "Occupational" exposure; That I om familiar with the Rules and Regulations of the Federal Communications Commission (FCC) as well as the regulations of the Occupational Safety and Health Administration (OSHA), both in general and specifically as they apply to the FCC Guidelines for Human Exposure to Radio-frequency Radiation; and That I hove been trained in the proper use of measurement equipment, and hove successfully completed Sitesofe training in policy, procedure and proper site measurement and modeling; and That I performed survey measurements of the RF environment at the site identified as 880230 -Mt Kelly on December 26, 2018 at l :30 PM in order to determine where there might be electromagnetic energy that is in excess of both the Controlled Environment and Uncontrolled Environment levels; and That the survey measurements were performed with measurement equipment, model NBM-550 2401-0 1 B field intensity meter (serial number F-0280) and model EA- 5091 2402-07B field intensity probe, (serial number 11 91) calibrated on 2/23/2017; and That I have prepared this Site Compliance Report and believe it to be true and accurate to the best of my knowledge and based on data gathered. By: Robert Davis 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.276.1100 • info@sitesafe.com Page 24 • §!!.~.§.~f..~ J 8 Engineer Certification The professional engineer whose seal appears on the cover of this document hereby certifies and affirms: That I am registered as a Professional Engineer in the jurisdic tion indicated in the professional engineering stamp on the cover of this document; and That I am an employee of Sitesafe, LLC., in Vienna, Virginia, at which place the staff and I provide RF compliance services to clients in the wireless communications industry; and That I am thoroughly familiar with the Rules and Regulations of the Federal Communications Commission (FCC) as well as the regulations of the Occupational Safety and Health Administration (OSHA), both in general and specifically as they apply to the FCC Guidelines for Human Exposure to Radio-frequency Radiation; and That survey measurements of the site environment of the site identified as 880230 -Mt Kelly have been performed in order to determine where there mig ht be electromagnetic energy that is in excess of both the Controlled Environment and Uncontrolled Environment levels; and That I have thoroughly reviewed this Site Compliance Report and believe it to be true and accurate to the best of my knowledge as assembled by and attested to by Sam Cosgrove. December 27, 2018 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.27 6.1100 • info@sitesafe.com Page 25 Appendix A -Statement of Limiting Conditions Sitesafe field personnel visited the site and collected data with regard to the RF environment. Sitesafe will not be responsible for matters of a legal nature that affect the site or property. The property was visited under the premise that it is under responsible ownership and management and our client has the legal right to conduct business at this facility. Due to the complexity of some wireless sites, Sitesafe performed this visit and created this report utilizing best industry practices and due diligence. Sitesafe cannot be held accountable or responsible for anomalies or discrepancies due to actual site conditions (i.e., mislabeling of antennas or equipment, inaccessible cable runs, inaccessible antennas or equipment, etc.) or information or data supplied by Sprint, the site manager, or their affiliates, subcontractors or assigns. Sitesafe has provided computer generated model(s) in this Site Compliance Report to show approximate dimensions of the site, and the model is included to assist the reader of the compliance report to visualize the site area, and to provide supporting documentation for Sitesafe' s recommendations. Sitesafe may note in the Site Compliance Report any adverse physical conditions, such as needed repairs, observed during the survey of the subject property or that Sitesafe became aware of during the normal research involved in performing this survey. Sitesafe will not be responsible for any such conditions that do exist or for any engineering or testing that might be required to discover whether such conditions exist. Because Sitesafe is not an expert in the field of mechanical engineering or building maintenance, the Site Compliance Report must not be considered a structural or physical engineering report. Sitesafe obtained information used in this Site Compliance Report from sources that Sitesafe considers reliable and believes them to be true and correct. Sitesafe does not assume any responsibility for the accuracy of such items that were furnished by other parties. When conflicts in information occur between data provided by a second party and physical data collected by Sitesafe, the physical data w ill be used. 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.276.1100 • inlo@sitesafe.com Page 26 Appendix B -Assumptions and Definitions General Model Assumptions In this site compliance report, it is assumed that all antennas are operating at full power at all times. Software modeling was performed for all transmitting antennas located on the site. Sitesafe has further assumed a 100% duty cycle and maximum radiated power. The site has been modeled with these assumptions to show the maximum RF energy density. Sitesafe believes this to be a worst-case analysis, based on best available data. Areas modeled to predict emissions greater than 100% of the applicable MPE level may not actually occur, but are shown as a worst-case prediction that could be realized real time. Sitesafe believes these areas to be safe for entry by occupationally trained personnel utilizing appropriate personal protective equipment (in most cases, a personal monitor). Thus, at any time, if power density measurements were made, we believe the real- time measurements would indicate levels below those depicted in the RF emission diagram(s) in this report. By modeling in this way, Sitesafe has conservatively shown exclusion areas -areas that should not be entered without the use of a personal monitor, carriers reducing power, or performing real-time measurements to indicate real-time exposure levels. Use of Generic Antennas For the purposes of this report, the use of "Generic" as an antenna model, or "Unknown" for an operator means the information about a carrier, their FCC license and/or antenna information was not provided and could not be obtained while on site. In the event of unknown information, Sitesafe will use our industry specific knowledge of equipment, antenna models, and transmit power to model the site. If more specific information can be obtained for the unknown measurement criteria, Sitesafe recommends remodeling of the site utilizing the more complete and accurate data. Information about similar facilities is used when the service is identified and associated with a particular antenna. If no information is available regarding the transmitting service associated with an unidentified antenna, using the antenna manufacturer's published data regarding the antenna's physical characteristics makes more conservative assumptions. Where the frequency is unknown, Sitesafe uses the closest frequency in the antenna's range that corresponds to the highest Maximum Permissible Exposure (MPE), resulting in a conservative analysis. 8618 Westwood Center Drive • Suite 315 • Vienna, VA 22182 703.276.1100 • info@sitesafe.com Page 27 Definitions 5% Rule -The rules adopted by the FCC specify that, in general, at multiple transmitter sites actions necessary to bring the area into compliance with the guidelines are the shared responsibility of all licensees whose transmitters produce field strengths or power density levels at the area in question in excess of 5% of the exposure limits. In other words, any wireless opera tor that contributes 5% or greater of the MPE limit in an area that is identified to be greater than 100% of the MPE limit is responsible taking corrective actions to bring the site into compliance. Compliance -The determination of whether a site is safe or not with regards to Human Exposure to Radio Frequency Radiation from transmitting antennas. Decibel (dB) -A unit for measuring power or strength of a signal. Duty Cycle -The percent of pulse duration to the pulse period of a periodic pulse train. Also, may be a measure of the temporal transmission characteristic of an intermittently transmitting RF source such as a paging antenna by dividing average transmission duration by the average period for transmission. A duty cycle of 100% corresponds to continuous operation. Effective (or Equivalent) Isotropic Radiated Power (EIRP) -The product of the power supplied to the antenna and the antenna gain in a given direction relative to an isotropic antenna. Effective Radiated Power (ERP) -In a given direction, the relative gain of a transmitting antenna with respect to the maximum directivity of a half wave dipole multiplied by the net power accepted by the antenna from the connecting transmitter. Gain (of an antenna) -The ratio of the maximum intensity in a given direction to the maximum radiation in the same direction from an isotropic radiator. Gain is a measure of the relative efficiency of a directional antennas as compared to an omni directional antenna. General Population/Uncontrolled Environment -Defined by the FCC, as an area where RFR exposure may occur to persons who are unaware of the potential for exposure and w ho have no control of their exposure. General Population is also referenced as General Public. Generic Antenna -For the purposes of this report, the use of "Generic" as an antenna model means the antenna information was not provided and could not be obtained while on site. In the event of unknown information, Sitesafe will use our industry specific knowledge of antenna models to select a worst case scenario antenna to model the site. Isotropic Antenna -An antenna that is completely non-directional. In other words, an antenna that radiates energy equally in a ll directions. Maximum Measurement -This measurement represents the single largest measurement recorded when performing a spatial average measurement. 8618 Westwood Center Drive • Suite 315 • Vienna, VA 22182 703.276.1100 • info@sitesafe.com Page 28 • §!!.':;.§.~!:.~ J Maximum Permissible Exposure (MPE) -The rms and peak electric and magnetic field strength, their squares, or the plane-wave equivalent power densities associated with these fields to which a person may be exposed without harmful effect and with acceptable safety factor. Occupational/Controlled Environment -Defined by the FCC, as an area where Radio Frequency Radiation (RFR) exposure may occur to persons who are aware of the potential for exposure as a condition of employment or specific activity and can exercise control over their exposure. OET Bulletin 65 -Technical guideline developed by the FCC's Office of Engineering and Technology to determine the impact of Radio Frequency radiation on Humans. The guideline was published in August 1997. OSHA (Occupational Safety and Health Administration) -Under the Occupational Safety and Health Act of 1970, employers are responsible for providing a safe and hea lt hy workplace for their employees. OSHA's role is to promote the safety and hea lt h of America's working men and women by setting and enforcing standards; providing training, outreach and education; establishing partnerships; and encouraging continual process improvement in workplace safety and health. For more information, visit www.osha.gov. Radio Frequency Radiation -Electromagnetic waves that are propagated from antennas through space. Spatial Average Measurement -A technique used to average a minimum of ten (10) measurements taken in a ten (10) second interval from zero (0) to six (6) feet. This measurement is intended to model the average energy an average sized human body will absorb while present in an electromagnetic field of energy. Transmiffer Power Output (TPO) -The radio frequency output power of a transmitter's final radio frequency stage as measured at the output terminal while connected to a load. 8618 Westwood Center Drive• Suite 315 •Vienna.VA 22182 703.276.1100 • info@sitesale.com Page 29 Appendix C -Rules & Regulations Explanation of Applicable Rules and Regulations The FCC has set forth guidelines in OET Bulletin 65 for human exposure to radio frequency electromagnetic fields. Specific regulations regarding this topic are listed in Part l, Subpart I, of Title 47 in the Code of Federal Regulations. Currently, there are two different levels of MPE -General Public MPE and Occupational MPE. An individual classified as Occupational can be defined as an individual who has received appropriate RF training and meets the conditions outlined below. General Public is defined as anyone who does not meet the conditions of being Occupational. FCC and OSHA Rules and Regulations define compliance in terms of total exposure to total RF energy, regardless of location of or proximity to the sources of energy. It is the responsibility of all licensees to ensure these guidelines are maintained at all times. It is the ongoing responsibility of all licensees composing the site to maintain ongoing compliance with FCC rules and regulations. Individual licensees that contribute less than 5% MPE to any total area out of compliance are not responsible for corrective actions. OSHA has adopted and enforces the FCC's exposure guidelines. A building owner or site manager can use this report as part of an overall RF Health and Safety Policy. It is important for building owners/site managers to identify areas in excess of the General Population MPE and ensure that only persons qualified as Occupational a re granted access to those areas. Occupational Environment Explained The FCC definition of Occupational exposure limits apply to persons who: • are exposed to RF energy as a consequence of their employment; • have been made aware of the possibility of exposure; and • can exercise control over their exposure. OSHA guidelines go further to state that persons must complete RF Safety Awareness training and must be trained in the use of appropriate personal protec tive equipment. In order to consider this site an Occupational Environment, the site must be controlled to prevent access by any individuals classified as the General Public. Compliance is also maintained when any non-occupational individuals (the General Public) are prevented from accessing areas indicated as Red or Yellow in the attached RF Emissions diagram. In addition, a person must be aware of the RF environment into which they are entering. This can be accomplished by an RF Safety Awareness class, and by appropriate written documentation such as this Site Compliance Report. All Sprint employees who require access to this site must complete RF Safety Awareness training and must be trained in the use of appropriate personal protective equipment. 8618 Westwood Center Drive • Suite 315 • Vienna, VA 22182 703.27 6.1100 • inlo@sitesale.com Page 30 ' . • :§i!!.~.§.~f.-~ J Appendix D -General Safety Recommendations The following are general recommendations appropriate for any site with accessible areas in excess of 100% General Public MPE. These recommendations are not specific to this site. These are safety recommendations appropriate for typical site management, building management, and other tenant operations. 1. All individuals needing access to the main site (or the area indicated to be in excess of General Public MPE) should wear a personal RF Exposure monitor, successfully complete proper RF Safety Awareness training, and have and be trained in the use of appropriate personal protective equipment. 2. All individuals needing access to the main site should be instructed to read and obey all posted placards and signs. 3. The site should be routinely inspected and this or similar report updated with the addition of any antennas or upon any changes to the RF environment including: • adding new antennas that may have been located on the site • removing of any existing antennas • changes in the radiating power or number of RF emitters 4. Post t he appropriate NOTICE, CAUTION, or WARNING sign at the main site access point(s) and other locations as required. Note: Please refer to RF Exposure Diagrams in Section 5, to inform everyone who has access to this site that beyond posted signs there may be levels in excess of the limits prescribed by the FCC. In addition to RF Advisory Signage, a RF Guideline Signage is recommended to be posted a t the main site access point(s). The signs below are examples of signs meeting FCC guidelines. & NOTICE & ----· ---~TW AM ______ I --...................... -.. -.. A.CO.,•--_.._... ........ ......_ ................... .., ................... -............................... ~Dt,_ ... ._.d.,...,_ Au..,.._.,.,,_....,...,.... .... ......,. ... .....,.,.....,.,..,. ...... .,..,....~ .& Ot,_..,. .... ~ ............... ........ NOTICE (<'f>) 11.odlofNqucl'lt)' 1lold.l l,oy-"''-l"lat ""Y t~ llt ,cC tofttftlM!lc t.-lloJIIL e-z:~z..::..-:: ........ -----·----__ .,.,_ AcAUTION ~ ~ondll\hjltlt11J Ra41o ,,___CY ""'1ll ti l1'1111 t li. m~y -dfCCMH ,o, hwm.>n a.,.,po,ur ... ,.,.,...,,-.$,,,....,.,~ ..... ..,. .. ,,.,O"" ...... ..,...,,..,..iw .. , __ ....,.,..,,,,..ir.uw'1t"• ..... ...... ~.. . ........... -. ' _ ... :, ... , • .:-c~ • .,. Beyo""W.,,.,..,L R•dlo IIIK!l>ffl<f lloldf at 1/lb 111• UC#"'ll\ol'C:t;RIIH IO< IUna~ Upot:Ul'O. ,..,. .•.• ...,, .. ~4...,_.,,., ... ~ hf''Jl'Oilrfll Iii, ..... ~, ,.........,.C&o .. ft.,...ll!lefl'Nla~•)' . .. ._ .. , ... ~ ............................ . ....... ..,. ,.. ... ..,. 5. Ensure that the site door remains locked (or appropriately controlled) to deny access to the general public if deemed as policy by the building/site owner. 6. For a General Public environment the five color levels identified in this analysis can be interpreted in the following manner: • Gray represents area at below 5% of the General Public MPE limits or below. This level is safe for a worker to be in at any time. 8618 Westwood Center Drive• Suite 315 • Vienna, VA 22182 703.276.1100 • info@sitesafe.com Page 31 • Green represents areas predicted to be between 5% and l 00% of the General Public MPE limits. This level is safe for a worker to be in at any time. • Blue represents areas predicted to be between l 00% and 500% of the General Public MPE limits. This level is safe for a worker to be in at any time. • Yellow represents areas predicted to be between 500% and 5000% of the General Public MPE limits. This level is safe for a worker to be in. • Red areas indicated predicted levels greater than 5000% of the General Public MPE limits. This level is not safe for the General Public to be in. 7. For an Occupational environment the five color levels identified in this analysis can be interpreted in the following manner: • Areas indicated as Gray are at 5% of the Occupational MPE limits or below. This level is safe for a worker to be in at any time. • Green represents areas predicted to be between 5% and 20% of the Occupational MPE limits. This level is safe for a worker to be in at any time. • Blue represents areas predicted to be between 20% and l 00% of the Occupational MPE limits. This level is safe for a worker to be in at any time. • Yellow represents areas predicted to be between 100% and 500% of the Occupational MPE limits. Only individuals that have been properly trained in RF Health and Safety should be allowed to work in this area. This is not an area that is suitable for the General Public to be in.s • Red areas indicated predicted levels greater than 500% of the Occupational MPE limits. This level is not safe for the Occupational worker to be in for prolonged periods of time. Special procedures must be adhered to such as lock out tag out procedures to minimize the workers exposure to EME. 8. Use of a Personal Protective Monitor: When working around antennas, Sitesafe strong recommends the use of a Personal Protective Monitor (PPM). Wearing a PPM will properly forewarn the individual prior to entering an RF exposure area. Keep a copy of this report available for all persons who must access the site. They should read this report and be aware of the potential hazards with regards to RF and MPE limits. Additional Information Additional RF information is available by visiting both www.Sitesafe.com and www.fcc.gov/oet/rfsafety. OSHA has additional information available at: http://www.osha-slc.gov/SL TC/radiofrequencyradiation. 8618 Westwood Center Drive • Suite 315 • Vienna, VA 22182 703.276.1100 • info@sitesafe.com Page 32 . .