Attachment RF Study

This document pretains to SES-MOD-20170309-00254 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2017030900254_1200144

                               Engineering Statement
                     RADIOFREQUENCY EXPOSURE CALCULATIONS
                                                prepared for
                                    WVTM Hearst Television Inc.

        WVTM Hearst Television Inc. (“WVTM”) is the applicant for a transportable “Ku Band” satellite
uplink license modification. The following study was conducted to evaluate the proposed facility with
respect to the potential for human exposure to radiofrequency (“RF”) electromagnetic field. Specifically,
the study determined whether exposure to RF electromagnetic field would exceed FCC maximum
permissible exposure limits to the general public and to occupational workers at locations in the vicinity
of the uplink antenna based on data provided by the applicant and representatives of the equipment
manufacturers.



Human Exposure to Radiofrequency Electromagnetic Field
        The WVTM proposed operation was evaluated using the procedures outlined in FCC OET
Bulletin No. 65 (“OET 65"). OET 65 describes a means of determining whether a proposed facility
exceeds the RF exposure guidelines specified in §1.1310 of the Rules. Under present Commission policy,
a facility may be presumed to comply with the limits in §1.1310 if it satisfies the exposure criteria set
forth in OET 65. Based upon that methodology, and as demonstrated in the following, the transmitting
system under study will comply with the cited adopted guidelines at publicly accessible locations when
procedures described herein are followed.



Public Exposure
        The mechanical design of the mounting equipment is optimized to orient the antenna toward
satellites that are located well above the horizon.      Prevention of public exposure to predicted RF
electromagnetic field in excess of the general population/uncontrolled limit1 depends on adherence to the
following operational guidelines by the WVTM technicians.


        As shown below, RF attributable to the WVTM uplink antenna at locations outside of the “main
beam” and 1.45 meters or more from the center of the main beam will not exceed the FCC general
population and uncontrolled RF exposure limits. According to representatives of WVTM, at its lowest
elevation, the center of the uplink antenna is 4.0 meters above the ground and thus more than one dish-
diameter above head level (2 meters) on level terrain.




1
  The general population/uncontrolled maximum permissible exposure (“MPE”) limit of 1 mW/cm² for 14,250 MHz
is specified in §1.1310 of the Rules.


                                        Engineering Statement
                                                (page 2 of 4)

        To assure that no publicly accessible area is within the “main beam” of the uplink antenna, sites
and satellites will be selected such that the elevation angle of the antenna will exceed five degrees and the
main beam will exceed 1.45 meters above the horizon, nearby buildings, and places accessible by the
public. In unusual cases where this isolation cannot be achieved, WVTM will utilize crowd control
stanchions, cones, and RF exposure warning signs to control access to areas that are known to exceed the
FCC’s general population uncontrolled MPE limit. These areas will be defined either by measurements
made by qualified, on-site personnel, or by the calculations described herein.


        Based on data provided by the applicant, the following parameters were used in the study:


            Antenna Manufacturer                          Sat-Lite Technologies
            Antenna Model                                 1411 Peloris
            Center Transmit Frequency                     14,250 MHz
            Wavelength at Center Frequency                0.021 meters
            Max Average Antenna Input Power               87.10 Watts
            Antenna Diameter                              1.45 meters
            Antenna Gain                                  44.8 dBi
            Antenna Gain Ratio                            30199.5
            Antenna Aperture Efficiency                   0.644


        The area in the immediate vicinity of the antenna is known as the “near field region.”            In this
region (up to 25.0 meters in the case at hand), the antenna directional characteristics have not fully
formed. Therefore, antenna manufacturer “off-axis” discrimination specifications cannot be utilized for
the purpose of determining potential RF exposure. OET 65 provides a methodology (Equation 13) for
calculating a “worst case” exposure figure within this region. Additionally, OET 65 specifies that the
“worst case” power density would be reduced by 20 dB at locations at least one antenna diameter
(1.45 meters) off-axis from the “main beam” of the antenna. In this instance, the predicted off-axis, near
field is 0.136 mW/cm², or 13.6 percent of the general population/uncontrolled limit. Off-axis predicted
fields reduce commensurately at greater distances from the antenna in the antenna transition region.


        In the “far field” region of the antenna (in this case, starting at a distance of 60.0 meters from the
antenna), the antenna directional characteristics have formed and the off-axis power density can be


                                                                                                      Page 2 of 4
                                                                                                  Copyright 2017
                                                                                  Cavell, Mertz & Associates, Inc.


                                             Engineering Statement
                                                     (page 3 of 4)

readily calculated using “off-axis” antenna discrimination specifications. At locations greater than five
degrees off-axis from the “main beam,” the manufacturer of the proposed antenna specifies a minimum
side-lobe attenuation of 30.3 dB.2 Again using the methodology detailed in OET 65, this “off-axis”
attenuation is predicted to result in a power density of 0.0055 mW/cm², or 0.55 percent of the general
population/uncontrolled limit.


Controlled Access Area Exposure

           Access to the vicinity of the antenna will be limited and restricted to authorized, trained
personnel. Using data provided by the applicant, the potential for RF exposure to occupational workers
was evaluated. As described previously, the maximum predicted off-axis, “near field” power density is
0.136 mW/cm², which is 2.72 percent of the controlled limit. As the operator will generally be posted at
locations at ground level or within the vehicle itself, it is anticipated that actual exposure will be
substantially less than the above “worst case” prediction.



           With respect to worker safety, it is believed that based on the preceding analysis, excessive
exposure would not occur provided that adequate physical separation is established. As mentioned
previously, detailed operator policy will be employed protecting workers from excessive exposure when
work must be performed where high RF levels may be present. Such protective measures may include,
but will not be limited to, restriction of access to areas where levels in excess of the guidelines may be
expected, or the complete shutdown of facilities when work or inspections must be performed in areas
where the exposure guidelines would otherwise be exceeded. On-site RF exposure measurements may
also be undertaken to establish the bounds of safe working areas. The applicant will coordinate exposure
procedures with all pertinent facilities.



Conclusion

           As demonstrated, excessive levels of RF energy will not be caused at publicly accessible areas by
strictly following the policy detailed herein. Consequently, neither the general public nor occupational
staff will be exposed to RF levels in excess of the Commission’s guidelines. Whenever necessary to
assure compliance, access to the vicinity of the uplink antenna will be restricted and controlled through

2
    According to the manufacturer, the antenna meets the minimum off-axis specification detailed in FCC Rule
     §25.209(a)(2) or 32-25 Log(θ) dBi.



                                                                                                           Page 3 of 4
                                                                                                       Copyright 2017
                                                                                       Cavell, Mertz & Associates, Inc.


                                        Engineering Statement
                                               (page 4 of 4)

the use of crowd control stanchions, cones, and conspicuous RFR warning signs as part of an overall RF
safety program. The above study presumes that the subject antenna is the sole source of RF energy at the
uplink site. In the case of multiple emitters, further analysis or measurement is necessary to assure
compliance.



Certification

        The undersigned hereby certifies that the foregoing statement was prepared by him or under his
direction, and that it is true and correct to the best of his knowledge and belief. Mr. Rhodes is a senior
engineer in the firm of Cavell, Mertz & Associates, Inc.




                                                               Michael D. Rhodes, P.E.
                                                               March 7, 2017


Cavell, Mertz & Associates, Inc.
7724 Donegan Dr.
Manassas, VA 20109-2686
(703) 392-9090




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                                                                                                 Copyright 2017
                                                                                 Cavell, Mertz & Associates, Inc.



Document Created: 2017-03-08 13:38:30
Document Modified: 2017-03-08 13:38:30

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