RF Exposure Limits

[smlondon at lucent.com]

CONTRARY TO WHAT N6NB SAYS, THE SKY ----IS----- FALLING

I have now read the FCC Report and Order, as well as comments on the reflector.

On the surface, N6NB may be correct - very few amateurs will be out of
compliance with the FCC-mandated RF exposure limits.  However, armed with the
FCC Report and Order, and the lack of Federal premption, it is truly
frightening what state and local municipalities, as well as homeowners
associations, can do to amateurs.

N0YVY quite clearly summarized the premption issue:

>While this preemption is not extended to
>the Amateur Radio Service or the broadcast industry, the ruling
>specifically states that the FCC feels the RF exposure limits in the FCC
>regulations are appropriate. The ruling leaves the door open for future FCC
>preemption if a pattern of state and local regulation develops which
>hinders operation of FCC licensed stations, especially if these local
>limitations are not based on legitimate technically supported health and
>safety issues.

I fully expect overzealous local municipalities, such as Boulder County,
Colorado, to do the following:

1) Enact RF exposure limits more stringent than the FCC

   As long as there isn't a "pattern of state and local regulation", there is
nothing to stop your municipality from enacting tighter limits.  Even the 50
watt threshold isn't sacrosanct.

2) Require independent RF exposure engineering analysis of PROPOSED amateur
radio installations before the amateur is permitted to do ANY transmitting.

   From my past experience with Boulder County, there is NO WAY they will
accept some back-of-envelope calculations and photocopies of tables from the
ARRL Handbook !  They will legislate site-specific RF exposure analyses
conducted by an independent, certified, licensed, professional engineer.

3) Require periodic RF exposure measurements of existing amateur stations,
conducted by an independent, certified, licensed, professional engineer.

   While there is nothing in the FCC Report and Order requiring measurements,
again, the lack of Federal premption opens the door to your municipality
requiring measurements.


By now, I'm sure you are saying to yourself "That's just N2IC being a
pessimist. The FCC would never allow that !"  .  Think again.  Look at the FCC
inaction, in light of the major PRB-1 defeats against hams.

Steve London, N2IC/0
smlondon at lucent.com