WHY HAS THE FCC ADOPTED GUIDELINES FOR RF EXPOSURE?

The FCC authorizes and licenses devices, transmitters and facilities that generate RF radiation.  It has jurisdiction over all transmitting services in the U.S. except those specifically operated by the Federal Government.  However, the FCC’s primary jurisdiction does not lie in the health and safety area, and it must rely on other agencies and organizations for guidance in these matters.

Under the National Environmental Policy Act of 1969 (NEPA), all Federal agencies are required to implement procedures to make environmental consideration a necessary part of an agency’s decision-making process.  Therefore, FCC approval and licensing of transmitters and facilities must be evaluated for significant impact on the environment.  Human exposure to RF radiation emitted by FCC-regulated transmitters is one of several factors that must be considered in such environmental evaluations.  In 1996, the FCC revised its guidelines for RF exposure as a result of a multi-year proceeding and as required by the Telecommunications Act of 1996.

Facilities under the jurisdiction of the FCC having a high potential for creating significant RF exposure to humans, such as radio and television broadcast stations, satellite-earth stations, experimental radio stations and certain cellular, PCS and paging facilities are required to undergo routine evaluation for compliance with RF exposure guidelines whenever an application is submitted to the FCC for construction or modification of a transmitting facility or renewal of a license.   Failure to show compliance with the FCC’s RF exposure guidelines in the application process could lead to the preparation of a formal Environmental Assessment, possible Environmental Impact Statement and eventual rejection of an application.   Technical guidelines for evaluating compliance with the FCC RF safety requirements can be found in the FCC’s OET Bulletin 65 .

Low-powered, intermittent, or inaccessible RF antennas and facilities (including many cell sites) are normally “categorically excluded” from the requirement of routine evaluation for RF exposure.  These exclusions are based on calculations and measurement data indicating that such transmitting stations or devices are unlikely to cause exposures in excess of the guidelines under normal conditions of use.  The FCC’s policies on RF exposure and categorical exclusion can be found in Section 1.1307(b) of the FCC’s Rules and Regulations [47 CFR 1.1307(b)].  It should be emphasized, however, that these exclusions are not exclusions from compliance, but, rather, only exclusions from routine evaluation.  Transmitters or facilities that are otherwise categorically excluded from evaluation may be required, on a case-by-case basis, to demonstrate compliance when evidence of potential non-compliance of the transmitter or facility is brought to the Commission’s attention [see 47 CFR 1.1307(c) and (d)].