Activation Report-ATT-CCL02719_MPE_Report_Signed 8.7.20Radio Frequency – Electromagnetic Energy
(RF-EME) Site Audit (Post-Construction Monitoring)
USID# 146847
Site No. CCL02719
RSFR LTE 1C Only_NSB_CCL02719
10300 Torre Ave
Cupertino, California 95014
Santa Clara County
37.319148; -122.027991 NAD83
EBI Project No. 6220003673
August 6, 2020
Prepared for:
AT&T Mobility, LLC
c/o Vinculums Services Inc.
1200 Del Paso Road, Suite 150
Sacramento, California 95834
Prepared by:
Signed 8/7/20
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 i
TABLE OF CONTENTS
EXECUTIVE SUMMARY ..................................................................................................................... 2
1.0 SITE DESCRIPTION ................................................................................................................ 4
2.0 FEDERAL COMMUNICATIONS COMMISSION (FCC) REQUIREMENTS ................................... 4
3.0 AT&T RF EXPOSURE POLICY REQUIREMENTS .................................................................... 7
4.0 SITE AND VICINITY SURVEY .................................................................................................. 7
5.0 RECOMMENDED SIGNAGE/COMPLIANCE PLAN .................................................................... 8
6.0 SUMMARY AND CONCLUSIONS ............................................................................................. 9
7.0 LIMITATIONS ......................................................................................................................... 9
APPENDICES
Appendix A Antenna Inventory
Appendix B Site Photographs
Appendix C Site Plan with Monitoring Results
Appendix D Personnel Certifications
Appendix E Site Survey Data
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 2
EXECUTIVE SUMMARY
Purpose of Report
EnviroBusiness Inc. (dba EBI Consulting) has been contracted by AT&T Mobility, LLC to conduct radio
frequency electromagnetic (RF-EME) monitoring for AT&T Site CCL02719 located at 10300 Torre Ave
in Cupertino, California to determine RF-EME exposure levels from wireless communications equipment
installed at this site. As described in greater detail in Section 2.0 of this report, the Federal
Communications Commissions (FCC) has developed Maximum Permissible Exposure (MPE) Limits for
general population exposures and occupational exposures. This report summarizes the results of RF-EME
monitoring in relation to relevant FCC RF-EME compliance standards for limiting human exposure to RF-
EME fields.
EBI field personnel visited this site on August 3, 2020. This report contains a summary of the RF EME
analysis for the site, including the following:
Antenna Inventory
Site Photographs
Site Plan with antenna locations
Graphic representation of onsite monitoring results
This document addresses the emissions and signage of AT&T’s transmitting facilities independently.
Emission readings included in this report are cumulative of all carriers on site. However, this report does
not address other carrier compliance.
Statement of Compliance
An installation is considered out of compliance with FCC regulations if, in an area that exceeds the FCC
limits, that installation’s contribution is greater than 5% of the applicable MPE and there are no mitigation
measures in place.
Based on the FCC criteria, the results of the RF emissions survey indicate that the readings do not exceed
applicable FCC MPE limits.
An installation is considered out of compliance with FCC regulations if, in an area that exceeds the FCC
limits, that installation’s contribution is greater than 5% of the applicable MPE and there are no mitigation
measures in place.
AT&T Recommended Signage/Compliance Plan
AT&T’s RF Exposure: Responsibilities, Procedures & Guidelines document, dated October 28, 2014,
requires that:
1. All sites must be analyzed for RF exposure compliance;
2. All sites must have that analysis documented; and
3. All sites must have any necessary signage and barriers installed.
Site compliance recommendations have been developed based upon protocols presented in AT&T’s RF
Exposure: Responsibilities, Procedures & Guidelines document, dated October 28, 2014, additional
guidance provided by AT&T, EBI’s understanding of FCC and OSHA requirements, and common industry
practice. Barrier locations have been identified (when required) based on guidance presented in AT&T’s
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 3
RF Exposure: Responsibilities, Procedures & Guidelines document, dated October 28, 2014. The following
signage are existing at this site:
Yellow CAUTION 2 signs on the base of each pole.
The signage existing at this site complies with AT&T’s RF Exposure: Responsibilities, Procedures &
Guidelines document and therefore complies with FCC and OSHA requirements. Barriers are not
recommended on this site. More detailed information concerning site compliance recommendations is
presented in Section 5.0 of this report.
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 4
1.0 SITE DESCRIPTION
This project involves wireless telecommunication antennas on a moneucalyptus tower in Cupertino,
California. There are three Sectors (A, B, and C) at the site, with antennas installed per sector.
The Sector A antennas are oriented 80° from true north. The Sector B antennas are oriented 320° from
true north. The Sector C antennas are oriented 200° from true north. Information supplied by AT&T
showed the bottoms of the antennas to be 64 feet above the ground leve
Access to this site is accomplished by elevating workers to antenna level. In addition, the tower is
surrounded by a gated fence. As such, the general public is not able to access the antennas.
EBI conducted a site visit on August 3, 2020. At the time of the site visit, Verizon antennas were present
on the tower. Measurements were taken at ground level to record existing RF-EME levels resulting from
these antennas combined with AT&T’s equipment. Appendix B contains site photographs taken on August
3, 2020 during the on-site survey. Appendix C presents a site plan indicating monitoring and antenna
locations. Appendix E contains climate and site observations recorded during the site visit.
2.0 FEDERAL COMMUNICATIONS COMMISSION (FCC) REQUIREMENTS
The FCC has established Maximum Permissible Exposure (MPE) limits for human exposure to
Radiofrequency Electromagnetic (RF-EME) energy fields, based on exposure limits recommended by the
National Council on Radiation Protection and Measurements (NCRP) and, over a wide range of
frequencies, the exposure limits developed by the Institute of Electrical and Electronics Engineers, Inc.
(IEEE) and adopted by the American National Standards Institute (ANSI) to replace the 1982 ANSI
guidelines. Limits for localized absorption are based on recommendations of both ANSI/IEEE and NCRP.
The FCC guidelines incorporate two separate tiers of exposure limits that are based upon
occupational/controlled exposure limits (for workers) and general population/uncontrolled exposure
limits for members of the general public.
Occupational/controlled exposure limits apply to situations in which persons are exposed as a
consequence of their employment and in which those persons who are exposed have been made fully
aware of the potential for exposure and can exercise control over their exposure. Occupational/
controlled exposure limits also apply where exposure is of a transient nature as a result of incidental
passage through a location where exposure levels may be above general population/uncontrolled limits
(see below), as long as the exposed person has been made fully aware of the potential for exposure and
can exercise control over his or her exposure by leaving the area or by some other appropriate means.
General population/uncontrolled exposure limits apply to situations in which the general public may
be exposed or in which persons who are exposed as a consequence of their employment may not be
made fully aware of the potential for exposure or cannot exercise control over their exposure. Therefore,
members of the general public would always be considered under this category when exposure is not
employment-related, for example, in the case of a telecommunications tower that exposes persons in a
nearby residential area.
Table 1 and Figure 1 (below), which are included within the FCC’s OET Bulletin 65, summarize the MPE
limits for RF emissions. These limits are designed to provide a substantial margin of safety. They vary by
frequency to take into account the different types of equipment that may be in operation at a particular
facility and are “time-averaged” limits to reflect different durations resulting from controlled and
uncontrolled exposures.
nine
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Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 5
The FCC’s MPEs are measured in terms of power (mW) over a unit surface area (cm2). Known as the
power density, the FCC has established an occupational MPE of 5 milliwatts per square centimeter
(mW/cm2) and an uncontrolled MPE of 1 mW/cm2 for equipment operating in the 1900 MHz frequency
range. For the AT&T equipment operating at 850 MHz, the FCC’s occupational MPE limit is 2.83 mW/cm2
and an uncontrolled MPE limit of 0.57 mW/cm2. For the AT&T equipment operating at 700 MHz, the
FCC’s occupational MPE limit is 2.33 mW/cm2 and an uncontrolled MPE limit of 0.47 mW/cm2. These
limits are considered protective of these populations.
Table 1: Limits for Maximum Permissible Exposure (MPE)
(A) Limits for Occupational/Controlled Exposure
Frequency Range
(MHz)
Electric Field
Strength (E)
(V/m)
Magnetic Field
Strength (H)
(A/m)
Power Density (S)
(mW/cm2)
Averaging Time
[E]2, [H]2, or S
(minutes)
0.3-3.0 614 1.63 (100)* 6
3.0-30 1842/f 4.89/f (900/f2)* 6
30-300 61.4 0.163 1.0 6
300-I,500 -- -- f/300 6
1,500-100,000 -- -- 5 6
(B) Limits for General Population/Uncontrolled Exposure
Frequency Range
(MHz)
Electric Field
Strength (E)
(V/m)
Magnetic Field
Strength (H)
(A/m)
Power Density (S)
(mW/cm2)
Averaging Time
[E]2, [H]2, or S
(minutes)
0.3-1.34 614 1.63 (100)* 30
1.34-30 824/f 2.19/f (180/f2)* 30
30-300 27.5 0.073 0.2 30
300-I,500 -- -- f/1,500 30
1,500-100,000 -- -- 1.0 30
f = Frequency in (MHz)
* Plane-wave equivalent power density
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 6
Based on the above, the most restrictive thresholds for exposures of unlimited duration to RF energy for
several personal wireless services are summarized below:
Personal Wireless Service Approximate
Frequency
Occupational
MPE Public MPE
Personal Communication (PCS) 1,950 MHz 5.00 mW/cm2 1.00 mW/cm2
Cellular Telephone 870 MHz 2.90 mW/cm2 0.58 mW/cm2
Specialized Mobile Radio 855 MHz 2.85 mW/cm2 0.57 mW/cm2
Long Term Evolution (LTE) 700 MHz 2.33 mW/cm2 0.47 mW/cm2
Most Restrictive Freq, Range 30-300 MHz 1.00 mW/cm2 0.20 mW/cm2
MPE limits are designed to provide a substantial margin of safety. These limits apply for continuous
exposures and are intended to provide a prudent margin of safety for all persons, regardless of age, gender,
size, or health.
Personal Communication (PCS) facilities used by AT&T in this area can operate within a frequency range
of 700-2300 MHz. Facilities typically consist of: 1) electronic transceivers (the radios or cabinets)
connected to wired telephone lines; and 2) antennas that send the wireless signals created by the
transceivers to be received by individual subscriber units (PCS telephones). Transceivers are typically
connected to antennas by coaxial cables.
Because of the short wavelength of PCS services, the antennas require line-of-site paths for good
propagation, and are typically installed above ground level. Antennas are constructed to concentrate
energy towards the horizon, with as little energy as possible scattered towards the ground or the sky.
This design, combined with the low power of PCS facilities, generally results in no possibility for exposure
to approach Maximum Permissible Exposure (MPE) levels, with the exception of areas directly in front of
the antennas.
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 7
3.0 AT&T RF EXPOSURE POLICY REQUIREMENTS
AT&T’s RF Exposure: Responsibilities, Procedures & Guidelines document, dated October 28, 2014,
requires that:
1. All sites must be analyzed for RF exposure compliance; and
2. All sites must have that analysis documented.
Pursuant to this guidance, an RF site survey has been completed for this site. The results of the site survey
are summarized below in Section 4.0 and in Appendices A, B, and C.
4.0 SITE AND VICINITY SURVEY
EBI performed a ground level RF-EME survey on August 3, 2020. The antenna inventory (based upon the
site survey) and site photos taken from ground level are presented in Appendices A and B, respectively.
To measure the RF emissions within the vicinity, EBI Consulting utilized a NARDA E Field Probe Model
EA5091 Standard Shaped probe S/N 1049, Frequency Range 300 KHz-50 GHz with NARDA
Electromagnetic Survey Meter Model NBM-550 S/N E-0541. Probe calibration was performed on April 8,
2019 with meter calibration performed on April 26, 2019. This meter was programmed to measure the
total power density for all electromagnetic radiation within the 300kHz-50GHz frequency range and
report the power density as a percent of the FCC’s controlled MPE. During this survey, no spatially
averaged readings above 0.9260% of the FCC’s occupational MPE (4.63% of the general public MPE) were
encountered on any ground surface. This maximum spatially averaged reading was measured at ground
level outside the Verizon access gate, as shown in the monitoring site plan in Appendix E.
At the time of the site survey,it was noted that there was a yellow “Caution” sign located on each of the
poles indicating the presence of RF emitting equipment at the site.
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 8
5.0 RECOMMENDED SIGNAGE/COMPLIANCE PLAN
Signs are the primary means for control of access to areas where RF exposure levels may potentially
exceed the MPE. As presented in the AT&T guidance document, the signs must:
Be posted at a conspicuous point;
Be posted at the appropriate locations;
Be readily visible; and
Make the reader aware of the potential risks prior to entering the affected area.
The table below presents the signs that may be used for AT&T installations.
Informational Signs – No longer in Use Alerting Signs
INFO 1
NOTICE 1 NOTICE 2
INFO 2
NOTICE DECAL
INFO 3
CAUTION 2 –
ROOFTOP
CAUTION 2B -
TOWER
INFO 4
CAUTION 2C -
PARAPETS WARNING 2
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 9
Based upon protocols presented in AT&T’s RF Exposure: Responsibilities, Procedures & Guidelines
document, dated October 28, 2014, and additional guidance provided by AT&T, the following signage are
existing on the site:
Yellow CAUTION 2 signs on each of the poles holding the antenna arrays.
Barriers are not recommended for installation. Barriers should be constructed of weather-resistant plastic
or wood fencing. Barriers may consist of railing, rope, chain, or weather-resistant plastic if no other types
are permitted or are feasible. Painted stripes should only be used as a last resort and only in regions where
there is little chance of snowfall. If painted stripes are selected as barriers, it is recommended that the
stripes and signage be illuminated.
6.0 SUMMARY AND CONCLUSIONS
EBI has prepared this Radiofrequency Emissions Compliance Report for telecommunications equipment
installed at the site located at 10300 Torre Ave in Cupertino, California.
The highest level of RF emissions measured within the facility compound was 0.8580% of the FCC’s MPE
limits based on the Occupational standard. Additionally, the highest level of RF emissions measured at
ground level surrounding the structure was 4.6300% of the FCC’s MPE limits based on the General
Population standard. A controlled/occupational environment assumes that access to the facility is generally
restricted to authorized personnel and facility management and members of the general public will not be
able to access the wireless telecommunications facility.
The results of the RF emissions survey indicate that the levels of RF emissions exposure do not exceed
applicable FCC MPE limits.
Signage existing at the site as presented in Section 5.0. Posting of the signage brings the site into compliance
with FCC rules and regulations and AT&T’s corporate RF safety policies.
7.0 LIMITATIONS
This report was prepared for the use of AT&T Mobility, LLC. It was performed in accordance with
generally accepted practices of other consultants undertaking similar studies at the same time and in the
same locale under like circumstances. The conclusions provided by EBI are based solely on the information
collected during the site visit and provided by the client. The observations in this report are valid on the
date of the investigation. Any additional information that becomes available concerning the site should be
provided to EBI so that our conclusions may be revised and modified, if necessary. This report has been
prepared in accordance with Standard Conditions for Engagement and authorized proposal, both of which
are integral parts of this report. No other warranty, expressed or implied, is made.
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 10
Appendix A
Antenna Inventory
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 11
The below table outlines the AT&T antennas that were observed to be on site during EBI’s site walk.
Antenna specifications below are based on direct evidence from an antenna or transmitter cabinet,
information from the site manager or building manager, information from the licensees, educated estimates
by the field technician or a combination of some or all of these sources. “N/A” (not available) is used if
any of the following information was not able to be verified.
Ant # Type Mfr/Model Azimuth°
Height
(Above
Ground
Level/ ft.)
Carrier
1 Panel Commscope/SBNH
H-1D65B 80 52 AT&T
2 Panel Commscope/SBNH
H-1D65B 80 52 AT&T
3 Panel Commscope/SBNH
H-1D65B 80 52 AT&T
4 Panel Commscope/SBNH
H-1D65B 320 52 AT&T
5 Panel Commscope/SBNH
H-1D65B 320 52 AT&T
6 Panel Commscope/SBNH
H-1D65B 320 52 AT&T
7 Panel Commscope/SBNH
H-1D65B 200 52 AT&T
8 Panel Commscope/SBNH
H-1D65B 200 52 AT&T
9 Panel Commscope/SBNH
H-1D65B 200 52 AT&T
10 Panel Unknown NA 65 Verizon
11 Panel Uknown NA 65 Verizon
12 Panel Unknown NA 65 Verizon
13 Panel Unknown NA 65 Verizon
14 Panel Unknown NA 65 Verizon
15 Panel Unknown NA 65 Verizon
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 12
Appendix B
Photographs
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 13
1. Site Overview
2. AT&T Access Gate
3. AT&T Access Gate Signage
4. AT&T Equipment Shelter
5. AT&T Equipment Shelter Signage Close
Up Right
6. AT&T Equipment Shelter Signage Close
Up Left
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 14
7. Base of Poles
8. Caution 2 Sign at Base #1
9. Caution 2 Sign at Base #1 Close Up
10. Caution 2 Sign at Base #2
11. Caution 2 Sign at Base #2 Close Up
12. Caution 2 Sign at Base #3
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 15
13. Caution 2 Sign at Base #3 Close Up
14. AT&T Sector A
15. Verizon antennas
16. AT&T Sector A Broadcast Direction
17. AT&T Sector B
18. Verizon antennas
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 16
19. AT&T Sector B Broadcast Direction
20. AT&T Sector C
21. Verizon antennas
22. AT&T Sector C Broadcast Direction
23. Verizon Access Gate
24. Verizon Access Gate Signage
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 17
25. Verizon Antennas
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 18
Appendix C
Site Plan with Monitoring Locations
Sector ASector BSector CAT&T Access Gate0.5050 @ 1’0.6855 @ 3’3.8400 @ 6’2.0830 @ 20’ LEGEND Verizon Antennas AT&T Antennas ♦ Blue numbers are Spatially-Averaged Measurements % FCC Occupational Limit ♦ Green numbers are Spatially-Averaged Measurements % FCC General Public Limit Site Plan with Monitoring ResultsFacility Operator: AT&T MobilityAT&T Site Number:CCL02719USID Number: 146847Site Name: RSFR LTE 1C Only_NSB_CCL02719Site Visit Date: 08-03-2020Verizon Access Gate0.8000 @ 1’0.7960 @ 3’1.3430 @ 6’0.7520 @ 1’0.7460 @ 3’0.7270 @ 6’0.6625 @ 40’1.5265 @ 40’0.7570 @ 10’0.8580 @ 20’Verizon EQAT&T EQ3.79251.8720Dumpsters4.63001.7200
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 19
Appendix D
Certifications
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 20
Field Personnel Certification
I, Joseph Vitulli, state that:
I am an employee of Envirobusiness Inc. (d/b/a EBI Consulting), which provides RF-EME safety and
compliance services to the wireless communications industry.
I have successfully completed RF-EME safety training, and I am aware of the potential hazards from
RF-EME and would be classified “occupational” under the FCC regulations.
I am familiar with the FCC rules and regulations as well as OSHA regulations both in general and
as they apply to RF-EME exposure.
I have been trained in the proper use of the RF-EME measurement equipment, and have
successfully completed EBI training in the policies and procedures for site survey protocols.
All information collected during the site survey and contained in this report is true and accurate
to the best of my knowledge and based on the data gathered.
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 21
Preparer Certification
I, James Speed, state that:
I am an employee of Envirobusiness Inc. (d/b/a EBI Consulting), which provides RF-EME safety and
compliance services to the wireless communications industry.
I have successfully completed RF-EME safety training, and I am aware of the potential hazards from
RF-EME and would be classified “occupational” under the FCC regulations.
I am familiar with the FCC rules and regulations as well as OSHA regulations both in general and
as they apply to RF-EME exposure.
I have been trained in on the procedures outlined in AT&T’s RF Exposure: Responsibilities,
Procedures & Guidelines document (dated October 28, 2014) and on RF-EME modeling using
RoofView® modeling software.
I have reviewed the data collected during the site survey and provided by the client and
incorporated it into this Site Compliance Report such that the information contained in this report
is true and accurate to the best of my knowledge.
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 22
Appendix E
Site Survey Data
Site Name: RSFR LTE 1C Only_NSB_CCL02719 EBI Project Number: 6220003673
Site Number: CCL02719 23
Surveyor Name: Joseph Vitulli Site Visit Date August 3, 2020
Site Information
RSFR LTE 1C Only_NSB_CCL02719
10300 Torre Ave
Cupertino, California 95014
Santa Clara County
Site Coordinates (NAD83)
37.319148; -122.027991
MONITOR INFORMATION PROBE INFORMATION
Monitor Model # NBM-550 Probe Model # EA5091
Monitor Serial # E-0541 Probe Serial # 1049
Calibration Date April 26, 2019 Calibration Date April 8, 2019
CLIMATE INFORMATION
Temperature (oF) 80
Sunny/Overcast/Cloudy Sunny
Windy/Mild Breeze/No Wind No wind
Rainy/Drizzle/Foggy/Snowy
Other Noteworthy weather factors that
might influence readings
ACCESS INFORMATION
Type of facility: Monoeucalyptus
Property Owner / Contact Number Vinculums Services Inc.
Who manages Access (e.g. security, landlord,
no one) no one
How is access managed? (locks, sign-in) Combo lock
Ease of access, in general (e.g. ease of
breaching any access physical controls)