DNS REVIEWED PLN NIER ReportNON -IONIZING ELECTROMAGNETIC EXPOSURE ANALYSIS
ENGINEERING CERTIFICATION FOR
at&t
PROJECT: Modification to Existing Antennas
AT&T SITE NAME: WA6358 — Lake Ballinger
CROWN CASTLE SITE: 840470 — Lake Ballinger
SITE ADDRESS: 23931 Highway 99
Edmonds, WA 98026
DATE: February 24, 2022
PREPARED BY:
m•
MORRISON HERSHFIELD
600 Stewart Street, Suite 200
Seattle, WA 98101
206-268-7370
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INTRODUCTION
Morrison Hershfield has been retained by AT&T to evaluate a proposed AT&T
telecommunications site as described below. Evaluation is for compliance with current
Federal Communications Commission (FCC) and local rules regarding public exposure to
radiofrequency (RF) electromagnetic fields (EMFs).
PROJECT
The proposed AT&T project consists of an existing WCF (Wireless Communications
Facility) located at 23931 Highway 99, Edmonds, WA 98026; Latitude and Longitude:
47°46'54.30",-122°20'37.90". The planned improvements will include the placement of
new antennas as described below. These antennas will be mounted to the existing mount
assembly at top of a tower structure at 56' AGL worst condition to the centerline of the
antennas.
All antennas face outward and point directionally away. Therefore it is unlikely that anyone
other than authorized RF workers could approach near enough to any of the transmit
antennas to cause that person's RF exposure to exceed FCC limits. It is expected that RF
exposure conditions near ground level at the site, and at all adjacent properties, due to the
contributions from all transmitting antennas will be well below the FCC public exposure
limit.
PROPOSED EQUIPMENT
Type of Service: 5G / LTE Cellular
Antennas:
Sector
Azimuth
Height
Description
Alpha:
30
56'
(1) Existing Commscope / NNH4-65C-R6 Panel Antenna
30
56'
(1) Existing Commscope / NNH4-65C-R4 CCIV2 Panel Antenna
30
58'
(1) New NOKIA / AEQK Integrated Antenna
Beta:
160
56'
(1) Existing Commscope / NNH4-65C-R6 Panel Antenna
160
56'
(1) Existing Commscope / NNH4-65C-R4 CCIV2 Panel Antenna
160
58,
(1) New NOKIA / AEQK Integrated Antenna
Gamma:
270
56'
(1) Existing Commscope / NNH4-65C-R6 Panel Antenna
270
56'
(1) Existing Commscope / NNH4-65C-R4 CCIV2 Panel Antenna
270
58'
(1) New NOKIA / AEQK Integrated Antenna
AT&T Site WA6358 — Lake Ballinger
MH Project #: 220003900
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PROPOSED EQUIPMENT (cont)
Maximum Power: 1692 watts
CALCULATIONS
Calculations for RF power densities near ground level are based on the "Evaluating
Compliance with FCC Guidelines for Human Exposure to Radio Frequency
Electromagnetic Fields, OET Bulletin 65" Edition 97-01, August 1997; issued by the
Federal Communications Commission Office of Engineering & Technology.
Compliance is determined by comparing RF field predictions with the general
population/uncontrolled environment (i.e., "Public") Maximum Permissible Exposure limits
(MPEs) allowed by the FCC rules, as specified in CFR 47 §1.1310. The following formula
has been used to calculate the power densities at specific locations:
S = 0.36 x ERP / RI
1►JI10 0-
S = power density (mW/cm2)
ERP = power in watts
R = distance to the center of the radiation antenna (ft)
Formula is based on Equation 9 on page 21 of OET Bulletin 65. It includes the effect of
ground reflections. The Effective Radiated Power (ERP) depends on the vertical antenna
pattern.
THEORETICAL ANALYSIS
All existing and proposed transmit antennas are highly directional and project the majority
of the transmitted RF energy horizontally and well above all nearby accessible areas.
The following theoretical calculations predict the peak exposure condition for a six-foot
person standing at the nearest approach to the transmit antennas. A six-foot tall person
standing on the ground near the base of the antenna support or building would be at least
approximately 50 feet below all of the existing and proposed transmit antennas.
AT&T Site WA6358 — Lake Ballinger
MH Project #: 220003900
M
CONTRIBUTION OF AT&T FACILITY TO RF EXPOSURE ENVIRONMENT
Based on information provided by AT&T RF Engineers, the maximum ERP from any
sector of the proposed AT&T facility will be less than or equal to 1692 watts with all
channels activated. Thus the worst -case downward ERP is 16.92 watt (i.e., 1/100th of 100
watts) from the facility.
By use of the power density formula previously described, with input values of 16.92 watt
downwards ERP, and a distance of 50 feet, the worst -case calculated power density at
head height from the AT&T facility to a six-foot person standing at ground level is
0.0024369 mW/cm2.
AT&T antennas will transmit and/or receive at different MHz frequency bands worst case
being the LTE at 700 MHz. The Public MPE limit for the LTE frequency transmitted by this
facility is 0.47 mW/cm2.
The worst -case calculated exposure condition resulting from the AT&T facility is the power
density divided by the Public MPE limit = 0.5221929% of the Public MPE limit.
All ground level areas are expected to have exposure conditions less than the calculated
Public MPE due to the proposed AT&T facility.
OTHER CARRIERS
The following are examples of wireless carriers providing service to the local area:
CDMA/LTE 700-2500 Mhz Sprint, Verizon, US Cellular
GSM/UMTS/LTE 600-2100 Mhz AT&T, T-Mobile
CONTRIBUTION OF OTHER EXISTING CARRIERS TO RF EXPOSURE
ENVIRONMENT
Based on our information, there is an unknown carrier currently collocated on the existing
structure. Worst case parameters of similar facilities in the area, the maximum ERP from
any sector of the existing antennas on the structure is less than or equal to 8000 watts
with all channels activated. Therefore the worst -case downward ERP is 8000 / 100 = 80
watts from the existing facility.
AT&T Site WA6358 — Lake Ballinger
MH Project #: 220003900
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1- By use of the power density formula previously described, with input values of 80 watts
downwards ERP, and a distance of 35 ft, the worst -case calculated power density at head
height from the existing Unknown facility #1 to a six-foot person standing at ground level is
0.0235102 mW/cm2.
All of the existing antennas transmit and/or receive within the PCS, ESMR or Cellular
frequency band. The Public MPE limit for all frequencies at worst case scenario for the
purpose of this calculation is 0.40 mW/cm2.
The worst -case calculated exposure condition resulting from the existing Unknown facility
#1 is the power density divided by the Public MPE limit = 5.8775510% of the Public MPE
limit.
All accessible ground level areas are expected to have exposure conditions less than the
calculated Public MPE due to this existing facility.
COLOCATED FACILITITES TOTAL MPE
The predicted maximum worst -case RF exposure conditions resulting from all proposed
and existing wireless facilities at all ground -level areas is the arithmetic sum of the
contributions from each facility:
0.5221929 For AT&T + 5.8775510 = 6.3997439% of the Public MPE limit allowed
by FCC rules.
This worst -case calculated exposure level is well below the 100% FCC limit. The actual
exposure conditions are likely to be many times less than this worst -case value.
AT&T Site WA6358 — Lake Ballinger
MH Project #: 220003900
III
FCC COMPLIANCE
The general population/uncontrolled exposure near this facility, including persons at
ground level, surrounding properties, inside and on existing structures will have RF
exposure much lower than the "worst case" scenario, which is a small fraction of the MPE
limit.
Only, trained personnel will be allowed to access the AT&T antennas and equipment for
maintenance operations. It shall be the responsibility of AT&T and/or its contractors to
provide adequate occupational training making employees fully aware of the potential for
RF exposure, and to exercise control over their exposure that is within their
occupational/controlled limits.
The FCC has determined that at sites where multiple wireless facilities are co -located, the
responsibility for site -wide RF safety compliance is the shared responsibility of all
licensees whose facilities produce exposure conditions greater than 5% of the applicable
MPE exposure limit. Thus a new applicant is responsible for compliance (or submitting an
environmental assessment) at a multiple -facility site only if the proposed facility, when
considered alone, would produce exposure conditions in excess of 5% of the MPEs.
Wireless facilities that produce less than 5% of the applicable MPE exposure limit at
accessible locations are considered to be exempt from further study.
As demonstrated in this report by worst -case exposure calculations, the proposed AT&T
facility is part of a multiple wireless facility, and will produce far less than 5% of the
applicable exposure limit for public environments. Therefore, pursuant to the
Commission's rules no further calculations, measurements or other RF studies are
required, and the proposed AT&T facility is presumed to be in compliance with the FCC's
RF exposure rules.
Because the proposed AT&T facility is in compliance with federal rules, it is also in
compliance with local regulations concerning RF exposure. The following is the complete
text of 47 U.S.C. § 332(c) (7) (B) (IV):
"No State or local government or instrumentality thereof may regulate the
placement, construction, or modification of personal wireless service facilities on
the basis of the environmental effects of radio frequency emissions to the extent
that such facilities comply with the Commission's regulations concerning such
emissions.
AT&T Site WA6358 — Lake Ballinger ■
MH Project #: 220003900
7-
CONCLUSIONS
Based on these calculations, the proposed WCF will comply with current FCC and local
rules and guidelines regarding human exposure to radio frequency electromagnetic fields.
This conclusion is based solely on the comparison of predicted RF conditions in specific
areas with the corresponding safe exposure limits set forth in the FCC rules. The FCC
exposure limits are based on recommendations by federal and private entities with the
appropriate expertise in human safety issues.
To avoid any misunderstanding, I hereby state that, to the best of my knowledge, belief
and professional judgment, this report represents an accurate appraisal of exposure to RF
EM fields based upon careful evaluation to the extent reasonably possible.
Respectfully Submitted
For the Firm,
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Jason Ceglia, PE
Morrison Hershfield Corp.
AT&T Site WA6358 — Lake Ballinger
MH Project #: 220003900