ARRL

ARRL General Bulletin ARLB008 (2013)

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ARLB008 FCC Seeks to Reassess RF Exposure Limits

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ARRL Bulletin 8  ARLB008
From ARRL Headquarters  
Newington CT  April 4, 2013
To all radio amateurs 

SB QST ARL ARLB008
ARLB008 FCC Seeks to Reassess RF Exposure Limits

On March 27, the FCC released a First Report and Order, Further
Notice of Proposed Rulemaking and a Notice of Inquiry (ET Docket
Nos. 13-84 and 03-137). The documents seek to reassess the FCC's RF
exposure limits and policies, as well as to propose changes to the
FCC's rules regarding human exposure to RF electromagnetic fields.
These proposed changes would affect the Amateur Radio Service (Part
97) rules.  The First Report and Order can be found on the web in
PDF format at,
http://transition.fcc.gov/Daily_Releases/Daily_Business/2013/db0329/FCC-13-39A1.pdf.

In the 201-page document, the FCC noted that "[p]eriodic review of
the government's rules and regulations to ensure they have kept pace
with current knowledge and changing needs is an important
characteristic of good government, and we here will advance the
process of providing a comprehensive review and modification, where
appropriate, of this Commission's various rules pertaining to the
implementation of the National Environmental Policy Act (NEPA)
requirements for environmental reviews, specifically those reviews
related to health and safety of radiofrequency (RF) emissions from
radio transmitters. Our actions herein are intended to ensure that
our measures are compliant with our environmental responsibilities
and requirements and that the public is appropriately protected from
any potential adverse effects from RF exposure as provided by our
rules, while avoiding any unnecessary burden in complying with these
rules."

The document is divided into three parts: a First Report and Order
(First R&O) and a Further Notice of Proposed Rulemaking (FNPRM) in
ET Docket No. 03-137, and a Notice of Inquiry (Inquiry) in a new
docket, ET Docket No. 13-84. In the R&O, the FCC looks at several
technical and semantic issues -- initiated in 2003 -- to be revised
and updated; in the FNPRM, the FCC proposes to further update and
revise its procedures and treat all services equally.

In the Inquiry, the FCC seeks comments to determine whether its RF
exposure limits and policies need to be reassessed. "Since
consideration of the limits themselves is explicitly outside of the
scope of ET Docket 03-137, we propose with the Inquiry to open a new
docket to consider those limits in light of more recent
developments," the FCC said. "The Inquiry is intended to open
discussion on both the currency of our RF exposure limits and
possible policy approaches regarding RF exposure. We look forward to
developing a complete record to determine whether the current rules
and policies should remain unchanged, or should be relaxed or
tightened."

According to the FCC, mitigation matters are "post-evaluation
procedures to ensure exposure limits are not exceeded, such as
labels, signs, barriers, enforcement and occupational issues." In
its Notice of Inquiry, the FCC included clarifications related to
the application of occupational exposure limits for devices and at
fixed transmitter sites. The FCC noted that it "should be helpful to
licensees to codify our earlier adopted policy with regard the use
of occupational/controlled limits at Amateur Radio stations."

This policy was first established in the RF Report and Order of
1996, but it was not incorporated in the rules at that time. It
allows amateur stations to be evaluated "with respect to
occupational/controlled exposure limits, as long as appropriate
training and information has been provided to the amateur licensee
and members of his or her immediate household. Other nearby persons
who are not members of the amateur licensee's household must be
evaluated with respect to the general population/uncontrolled
exposure limits." The FCC will codify this policy by adding a
paragraph as a new sub-section in Section 1.1310 -- radiofrequency
radiation exposure limits -- to its rules.

The FCC pointed out that one goal of the general exemptions from
routine RF exposure evaluation proposed "is to avoid specific
exemptions for particular services and ensure a consistent set of
rules without exceptions." With this in mind, the FCC is proposing
to delete the special exemptions from evaluation in the Amateur
Radio Service in Section 97.13(c) of its rules.

"We appreciate that Amateur Radio operators are knowledgeable about
the appropriate use of their equipment, such that separation
distances are likely to be maintained to ensure compliance with our
exposure limits," the FCC said. "However, since the existing amateur
exemptions are based only on transmitter power and do not consider
separation distance or antenna gain, exempt transmitting antennas
that are unusually close to people could potentially lead to
non-compliant exposure levels." The FCC said that a separation
distance of at least 24 feet would meet its proposed exemption
criteria, "considering a currently exempt 50 W transmitter at VHF in
accord with Section 97.13(c) and assuming an antenna gain of 6 dBd."

The FCC noted that existing classification of amateur exposure as
occupational "is consistent with use of our proposed general
exemption criteria based on general population exposure limits
because awareness of exposure greater than the general population
limits is required in all occupational settings, including amateur
households. Application of the general exemptions proposed here to
Amateur Radio installations would preclude the possibility of
overexposure and require further evaluation only when necessary,
giving guidance for both fixed and mobile transmitting antennas."

The FCC invited comments on how this would affect the amateur
community: "Parties that support maintaining the current exemption
based on power alone are requested to explain how it provides
adequate assurance that the public is protected against exposure to
RF energy in excess of our limits and the extent of the burden
imposed by this proposal. We encourage interested parties to comment
on the relative costs and benefits of the proposed changes in this
section, as well as those of alternative approaches."

"The ARRL has an RF Safety Committee, consisting of experts in the
field," explained ARRL Chief Executive Officer David Sumner, K1ZZ;
"The committee members, as well as Board members and staff are
reviewing the lengthy document and will formulate a response."

Comments will be accepted until 90 days after the R&O, FNPRM and
Notice of Inquiry are published in the Federal Register (this can
take up to six weeks after its release by the FCC). Reply comments
will be accepted until 150 days after publication in the Federal
Register.
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