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Fight Continues

Proposed RF Rules Would Slow Deployment of Small Cell Transmitters, Industry Says

Rules proposed by the FCC for radiofrequency emissions would require a “routine evaluation” of too many transmitter sites and slow the deployment of small cells, Verizon said in reply comments to the FCC in dockets ET 13-84 and ET 03-137. AT&T offered similar comments. But the Electromagnetic Radiation Policy Institute (EMRPI) said the FCC’s proposed rules don’t go far enough to protect the public from RF emissions.

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In late March, the FCC released revised RF rules and a further notice asking questions about the commission’s RF exposure limits and policies (CD April 1 p6). In the initial comments, industry and some health-related groups disagreed strongly on whether the rules need to be strengthened to protect consumers (CD Sept 6 p1).

The maximum permissible emissions (MPE)-based exemption threshold for single transmitters proposed by the FCC is “too restrictive,” Verizon said. The stated objective of the NPRM was to “eliminate unnecessary environmental processing reviews to facilitate wireless facilities siting more broadly,” Verizon said (http://bit.ly/1bQJOHr). But parts of a further notice would have the opposite effect and require evaluation of more small cell and distributed antenna system (DAS) transmitters, the carrier said. “For small cells and DAS transmitters, these evaluations would impose additional costs and delays in deploying broadband infrastructure with no corresponding public safety benefit.”

EMPRI said many groups, including the International Brotherhood of Electrical Workers, the American Academy of Pediatrics and The American Academy of Environmental Medicine, endorsed stricter limits on RF emissions in the earlier comment round. “EMRPI supports biologically-based RF safety limits that are ‘as low as reasonably achievable’ and are at least 100 times lower than present FCC RF safety limits,” the group said (http://bit.ly/1atxlsY). Comments supporting lower standards “are almost entirely made by Industry officials and advocacy groups trained in business, electrical engineering and lobbying,” EMPRI said. “Common sense dictates that those trained in biology, physiology, medicine, and the health sciences are the experts that the FCC should rely upon in order to formulate RF safety limits that protect people from unsafe exposure to EMR.”

AT&T also objected to the exemption threshold proposed by the FCC. “If implemented as proposed, wireless facilities that are currently categorically excluded from routine RF evaluation would require evaluation, even in the absence of a finding that those facilities present an increased risk of exposure in excess of the maximum permissible exposure ... limits and even for facilities that present a negligible risk of exposure in excess of the MPE limits because access is controlled by design, such as towers, utility poles, flagpoles, water tanks,” AT&T said (http://bit.ly/1ei7wwG). “In the absence of evidence that the exemption threshold proposed in the Further Notice will better protect the public, there is no justification for imposing this unnecessary burden on wireless licensees and the Commission should leave the current categorical exclusion criteria in place."

"The Commission should ensure that its proposed exemption criteria do not have the unintended effect of eliminating categorical exemptions for transmitters that pose little risk to public safety,” CTIA said, agreeing with its two biggest members. CTIA also said the FCC shouldn’t revise its testing protocols or mandate “stringent” RF disclosures. “The scientific consensus supports the Commission’s current RF exposure standards as more than adequate to protect the public, based on years of research and the fifty-fold safety margin incorporated into the general population exposure standard,” CTIA said (http://bit.ly/1ei8DMX).