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7/26/2019 An analysis of siting criteria for the KRPI 5-tower array
1/212014-10-15 10:53 AM Page 1of 21
An analysis of siting criteria for the KRPI 5-tower array
Prepared by
Jim Ronback, System Safety Engineer, Ret.
1530 Kirkwood RoadTsawwassen, BC, Canada
V4L 1G1
Introduction
BBC Broadcasting, Inc. (BBC) which operates a radio station KRPI 1550 AM out of Ferndale (12), WA has applied to
Whatcom County Planning and Development Services (PDS) for a Conditional Use Permit (CUP) to erect an array of
five broadcasting towers on a 10 acre lot roughly 950 feet from the Canadian border. The FCC has approved the
relocation of the array and pre-approved a construction permit for KRPI to broadcast at 50,000 Watts both day and
night.
AM signals of this strength are known to produce harmful blanketing interference within an electric field of 1 Volt
per meter contour around the towers. In their CUP application, BBC, Inc., and Hatfield & Dawson (H&D), an
engineering consulting firm recruited by BBC, take note of this problem. They acknowledge problems with
electronic equipment, phones, computers and other communication systems that are likely to occur and discuss
the need for mitigation. They estimate the number of residents in Point Roberts who will be affected as 111 during
the nighttime and 304 at daytime. As will become clear, this is a vast underestimate of the actual number when the
population of Tsawwassen, BC, Canada which lies immediately north of the border is taken into account. In fact,
some 20,000 (by the 2006 census; current estimate is approximately 21,000) residents live within the 4.5 km (2.8
mi)1wide blanketing interference contour. Figure 1 below takes the H&D map and overlays it on a Google map of
Tsawwassen, BC and shows the full daytime and nighttime contours.
Because of these blanketing interference problems affecting nearby populations, whenever possible, powerful AMbroadcasting towers are located in remote rural sites or mountain tops not highly populated areas. Blanketing
interference from high power AM broadcast towers can result in an excessive wide spectrum of radio frequency
(RF) energy due to harmonics that can cause coupling of RF noise in various frequency bands into conductors such
as power lines, unshielded speaker wires, unshielded power cords, cordless phones, poorly shielded RF amplifiers in
AM and FM radio and TV tuners and antennas. They can also compromise the functions of public address systems,
HAM radio operations, baby and invalid-patient monitors, robots, emergency radio services and other electronic
devices.
For the public living or working near an antenna tower, the issues of the potential for negative impact upon
property values and the potential for negative health effects are their greatest concerns related to antenna
installations. (88)
For over a decade, the residents in Ferndale have complained2to the Federal Communications Commission (FCC)
about just such harmful RF blanketing interference. The problem has become so acute that H&D, in their report to
BBC Broadcasting, described the city as a poisoned well. H&D was retained by BBC to find a place to relocate.
They had several criteria in mind (see the position paper Omissions and misrepresentations), but ultimately
1KRPI directional antenna pattern for Point Roberts showing 1Volt/meter contours
https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101484673&qnum=5120©num=1&exhcnum=42Ferndale Complaints, http://allpointbulletin.com/static/files/Attachment%20B%20comments%20ferndale.pdf
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identified Point Roberts as optimal. In their CUP application and in their application to the FCC for approval to
relocate, H&D identify only a small portion of the 1,300 residents of Point Roberts as being within the scope of the
anticipated harmful blanketing interference. There was no mention made of those living in densely populated
Tsawwassen.
These circumstances produce a problem that is, literally, of international proportions. There are treaties in place
that require cooperation and clearance when telecommunication and broadcast signals cross borders, specifically
the 1984 Ottawa Agreement and the International Telecommunications Union (ITU). There are also guidelines that
establish maximums for electromagnetic RF blanketing interference (10) have been set by both the FCC (2) in the
United States and Canadas Industry Canada (IC). ICs radio tower site selection population rule C-10.3.1(c)3and the
FCC codes contained in 73.24, 73.37 and 73.1650 (all revised in 2012) outline international guidelines and
maximum population densities within affected areas.
In addition, the ITU, which both the US and Canada are signatory to, states in Article 0.4 (3): All stations, whatever
their purpose, must be established and operated in such a manner as not to cause harmful interference to the
radio services or communications of other Members or of recognized operating agencies, or of other duly
authorized operating agencies which carry on a radio service, and which operate in accordance with the provisions
of these Regulations (No. 197 of the Constitution).(79)
In the following analyses it is shown that when the full blanketing interference contours are examined without
being truncated by the border between the US and Canada, they encompass a population with patterns of relative
high density that violate the guidelines of the FCC and IC as well as the spirit of the ITU.
An examination of the H&D report and the BBC Broadcasting applications
It is worth asking why the initial application failed to trigger off alarm bells at IC and the FCC. Industry Canada was
notified of the minor change that was requested and signed off on it in 2012. But none of the issues raised above
were considered, only the question of whether there were AM stations in the vicinity whose signals might becompromised by adjacent channel interference by moving to Point Roberts and boosting nighttime broadcasting
power to 50,000 watts from 10,000 watts.
It seems fairly clear that BBC deliberately ignored the dense population in Tsawwassen which is part of the
Corporation of Delta. It cannot be that they were unaware. The KRPI studios are in Richmond, BC just north of
Delta. Their main offices are located there as well. Their stated target audience is in British Columbias lower
mainland including Metro Vancouver. Their revenue stream is wholly (or nearly so) Canadian. It can only be that by
failing to recognize the 21,000 plus residents of Tsawwassen none of the issues pointed out here needed to be
taken into consideration by the FCC. Sometimes omissions are neutral. Sometimes they are simple mistakes.
Sometimes they are motivated.
3Part 2: Application Procedures and Rules for AM Broadcasting Undertakings BPR-2 Issue 2 January 2009http://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/bpr2-rpr2-v2-jan2009-eng.pdf/$file/bpr2-rpr2-v2-jan2009-eng.pdf
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Figure 1: RF Blanketing Interference contours of 1 V/m extended into Canada.
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H&Ds report provided RF electric field strength maps in their site selection engineering report. It shows only the
truncated daytime and nighttime RF blanketing interference contours of 1 V/m, omitting any details of the dense
population data for Tsawwassen, BC. By providing this incomplete map on their relocation application they
circumvented the need to comply with the FCC and IC site selection population regulations.
To understand how this came about consider that the FCCs 73.24 (g) specifies that an applicant must show that
the population within the 1 V/m contour does not exceed 1.0 percent of the population within the 25 mV/m
contour. provided, however, that where the number of persons within the 1 V/m is 300 or less the provisions of
this paragraph are not applicable.
That however above stipulates that the minimum population within the 25 mV/m contour must be more than
30,100, of which 1% allows a population of 301 or more to be within the daytime blanketing interference contour
of 1 V/m. The application BBC filed with the FCC set the nighttime and daytime populations within the 1 V/m
blanketing interference contours at 111 and 304 respectively within Point Roberts only. If the daytime number is
less than 300, KRPI can claim that rule 73.24(g) is not applicable during the daytime. The nighttime population of
111 means that the population within the 25 mV/m contour must exceed 11,100 south of the border. While the
presented contour in the Radio-Locator map has an open, and hence ambiguous, segment to the south, it ishighly unlikely that the population within it reaches the threshold as there are no cities within it other than Friday
Harbor with a population of some 2,200.
To circumvent this problem, BBC asked for and obtained a waiver on the grounds that the 304 persons within the
daytime 1 V/m is barely above the cut-off of 300 persons within the blanketing interference contour. Of course,
304 is the number living within it in Point Roberts. Unless someone at the FCC who was reviewing this application
knew that thousands of homes, schools, churches and businesses were directly to the north of the planned tower
array across the border, there would be no reason not to grant it.
Its also worth noting the language of Industry Canadas clause C-10.3.1 which expresses similar considerations. It
states that the population within the day or night 1 V/m contour should be less than 0.02% of the populationwithin the 5 mV/m contour.
There are reasons why these guidelines are expressed in this fashion. Radio waves spread like the diminishing
waves in a pond when a rock is thrown into it. The strength of the signal along the radial varies as the inverse of the
square root of the radius, i.e., Sqrt(1/radius). Thus the likelihood of harmful blanketing interference depends upon
the distance from the source. It may require adjustments taken for geological factors such as, conductivity over
land and water, terrain height, signal strength and time of day. For example, that map in Figure 1 shows that the
maximum northwest radial for the nighttime 1 V/m contour is about 4.5 Km (2.8 miles). The northwest lobe of the
nighttime blanketing interference contour encompasses most of Tsawwassen, including the most densely
populated area. The guidelines are established so that the proportion of the population within the reach of the
radio signal that will suffer harmful blanketing interference is kept at a minimum. As noted above, this is why in
high-density areas efforts are made to locate broadcasting towers on the outskirts, away from neighborhoods with
high population densities.
The analyses that follow show that when the residents of Tsawwassen, BC are brought into the calculations the
tower array slated for Point Roberts violates the guidelines of the FCC, IC and the ITU.
Using the ratio of signal strengths, the estimated nighttime local listening 2.5 mV/m (red) contour maximum
radial is {Sqrt(1000/2.5) = 20} * 4.5 = 90 km (56 miles) approximately (see Figures 2 and 4 below). Thus the
nighttime maximum radial for FCCs 25 mV/m population rule is ([Sqrt(1000/ 25)] = 6.32) * 4.5 = 28.5 km (17.7
miles) approximately. In Figure 4 the proximate Industry Canada 5 mV/m nighttime contour is shown. Its maximum
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radial is [Sqrt(1000/ 5)] *4.5 = 63.6 Km. On the map it should be 64/90 = 0.71 times the distance from the site of
the KRPI towers along the radial to the red 2.5 mV/m contour in the Radio-Locator map in Figure 4. This gives the
predicted nighttime coverage map for Point Roberts towers. For the FCCs 25 mV/m population contour it will be
28.5/90 = 0.317 or about 32% of the distance to the red contour of 2.5 mV/m.
In Figure 4 the 0.7 and 0.3 proportions of the varying radials to the red 2.5 mV/m contour are applied to give a
more accurate representation of the approximate population contours of ICs 5 mV/m and FCCs 25 mV/m. The
stronger electric field has a smaller contour. These estimated contours do not include the effects of varying
conductivity of the land and water or the height of the terrain, all of which will have some impact on the actual
interference contours.
The Industry Canada population rule in C-10.3.1 (c) requires that 0.02% of the population within the 5 mV/m
contour not exceed the population within the 1 V/m blanketing interference contour. In Figure 4 the 5 mV/m
contour is about 0.7 times the distance along the radial to the 2.5 mV/m red local contour. In Figure 4, if we include
the nighttime populations within the FCC 25 mV/m contour on both sides of the border, then the nighttime
population within the harmful 1 V/m blanketing interference contour has about 21,000 people in Tsawwassen and
111 in Point Roberts = 21,111 approximately (though likely more).
By ignoring the people north of the border, BBC asked FCC for a waiver of 73.24(g) because the number of people
only in Point Roberts within the daytime 1V/m contour was 304 instead of 300 or less. FCC granted the waiver
when they granted the construction permit.
If the Tsawwassen people within the nighttime 1V/m contour were also included the limit of rule 73.24(g) would
violated more than 8 times over allowable limit. The corresponding Industry Canada (IC) rules would be exceeded
by over 41 times as explained below.
A good representation of the predicted Point Roberts listening coverage from KRPI in Point Roberts for their target
market is given in the Radio-Locator maps showing the 2.5 (local) and 0.5 (distant) mV/m contours in Figures 2, 4
(nighttime) and Figure 3 (daytime). In Figure 4 the estimated IC contour of 5 mV/m is shown in black, encompassesmost of Metro Vancouvers and Victorias population which combined is roughly 2.6 million.
The IC population rule in C-10.3.1 (c) requires that 0.02% of the population within the 5 mV/m contour not exceed
the population within the 1 V/m blanketing interference contour. In 2013, the nighttime 5 V/m contour
encompasses 2,450,000 in Metro Vancouver and one half of Metro Victoria (100,000) = 2.55 million. Thus 0.02% is
510. Thus 21,111/510 = 41 exceeds the IC limit 41 times.
The population for the FCC nighttime contour of 25 mV/m in Figure 4 encompasses Point Roberts (1,300),
Tsawwassen (22,000), Ladner (25,000), and most of Richmond (190,000) = 238,300. One percent of that is 2,383.
The 21,111 people of Tsawwassen and Point Roberts within the nighttime 1 V/m blanketing interference contour
exceeds that by 21,111/2,383 = 8.8times. Thus KRPI does not comply with the FCC rule 73.24(g).
If the projected growth of Tsawwassen like the Southlands development with 950 homes within the daytime
contour, is taken into account it is worse.
In short, no matter how the harmful blanketing interference contours are estimated, whether nighttime or daytime
broadcasting is under consideration, every calculation that includes the populations that H&Ds report and BBCs
application, wilfully neglected, shows that the population that will suffer from harmful blanketing interference
violates significantly both the IC and the FCC upper bounds. In the Tsawwassen-Point Roberts peninsula there are
over 21,000 people who live within the radio frequency (RF) nighttime blanketing contour of 1 V/m.
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As outlined in another position paper (Omissions and misrepresentations), this tower array is designed to
broadcast into the lower mainland in BC, Canada. The company identifies itself as British Columbias #1 South
Asian voice. Its studios, business offices, staff and officers are in Richmond, BC. By establishing itself as an
American company, KRPI circumvented Canadian Radio-television Telecommunications (CRTC) broadcasting
regulations. By failing to acknowledge the residents of Tsawwassen, KRPI circumvented scrutiny from FCC rules. By
limiting its presentation to the residents of Point Roberts, KRPI circumvented oversight from Industry Canada.
If this five-tower antenna site was proposed 330 meters further north, above the 49th parallel it would not meet
Industry Canada-CRTC site selection criteria using the population in Canada only. It would be rejected because it
exceeds the population of 520 allowed within the RF blanketing interference contour of 1 Volt per meter by
21,000/ 510 = 41 times.
Radio waves and harmful blanketing interference do not stop at borders. Engineering ethics to protect the public
should not be constrained by borders. Because of these misleading representations of the facts by omission and
obfuscation, the CUP application of BBC Broadcasting Inc. should be denied.
Alternately, if Whatcom County cannot say Yes or No because this issue is outside of their jurisdiction, then prior to
its determination on the BBCs permit application, the BBCs violation of both Industry Canada regulation C-10.3.1and FCC rule 73.24 (g) needs to be reported to Industry Canada and the FCC and dealt with between Industry
Canada and FCC.
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Figure 2. Predicted nighttime coverage of KRPI from Point Roberts, WA at 50,000 watts
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Figure 3 Predicted daytime coverage from Point Roberts at 50,000 watts
The red, purple, and blue lines on both coverage maps correspond to the "local", "distant", and "fringe" coverage
areas of each radio station:
Local Coverage:Within this area the radio station will be picked up on almost any radio with moderately good to
very good reception.
Distant Coverage:Within this area the signal may be weak unless you have a good car radio or a good stereo with agood antenna. The station will be difficult to get on Walkmans or other portable radios.
Fringe Coverage:Within this area, the station's signal will be very weak and only picked up on a very good radio
with a good antenna. Its also possible that reception will be compromised by adjacent channel interference from
other stations.
The "local", "distant" and "fringe" lines on the AM maps corresponds to the predicted 2.5, 0.5, and 0.15 mV/m
contours respectively (of the horizontal ground wave propagation only).
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How the contours were drawn:
Given two points, one on the 1V/m interference contour on the map provided by KPRI and the 2.5 mV/m local
contour found on the Radio-Locator.com map, curves can be drawn where the intermediate contours are located.
By overlaying the maps at the same scale, each intermediate contour is drawn as a proportion of the radial lines
drawn from the tower array in Point Roberts to the point where it intersects with the 2.5mV/m contour that
encompasses the local area. Using several radial lines to the outer contour, the shape of the intermediate
contours are derived that are similar in shape but shrunk in proportion to their signal strength. The signal from the
towers spreads out and diminishes in strength in proportion to Sqrt(1/radius). For example the portion of the radial
to a point on along it to the 2.5 mV/m local contour at which the 25 mV/m contour would be located is
Sqrt(2.5mV/25mV) = 0.316 or about 32%.
In Table 1, the maximum radial columns give the length relative to 1V/m interference maximum radial of 4,500
meters or 2.79 miles.
Also included in Table 1 is the limit for uncontrolled Maximum Permissible Exposure (MPE) at 1550 kHz, for the
general population in an accessible area is:
824/1.550 MHz = 532 V/m, or 180/ (1.55 MHz^2) = 74.9 mW/cm^2 averaged for 30 minutes. Based on themaximum radial of the 1V/m contour of 4500 meters, this MPE contour is about 195 meters or 0.12 miles from the
tower.
Note: The signal power density spread out and diminishes at the rate 1/ (radius^2).
The 5% level MPE contour occurs at about 866 meters or 0.54 miles. Thus if the general population exposed within
that contour exceeds the 5% level of the maximum allowed, averaged within any 30 minute interval, then this must
trigger an Environmental Assessment (EA)4process.
In Table 1 below, the column Contour distance relative to the 2.5 mV local listening contour, lists the relative
portions along the radials for all the different contours.
The Canadian limits shown in Table 1 are for broadcast receivers or radio sensitive equipment. They are used for
transmitting sources other than Broadcast Radio Stations, e.g., ham radio station, or an electric arc welding shop
next door. Industry Canada charges a fee of $80 to have an inspector come and investigate. (76, 77)
Summary
The KRPI application to relocate their radio towers from Ferndale to Point Roberts and boost their nighttime signal
to 50,000 watts deliberately ignored the impact on the dense population of 21,000 people in Tsawwassen just
across the border. By ignoring and blanking out Tsawwassen on their map, they did not need to apply the
population related rules from either the FCC or IC that are required for siting a broadcast radio tower. These rules
would ensure that the broadcast radio towers are located away from densely populated areas, such as mountain
tops or rural areas with less than 300 people within the harmful 1Volt/meter blanketing interference contour.
Thus the shapes of the different FCC (25 mV/m) and IC (5 mV/m, 250 mV/m) listening population contours are
located between the 1 V/m blanketing interference contour and the local listening contour of 2.5 mV/m. The
relative populations within those pairs of contours determine if a proposed site is permitted or not. In addition,
4See last paragraph on page 66 of FCC OET Bulletin 65, Edition 97-01
http://www.whatcomcounty.us/pds/plan/current/pdf/fcc-guidelines-human-exposure-to-emf.pdf.
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listed in Table 1 there are safety related contour distances relative to the 1V/m blanketing interference contour
that are closer to the towers.
The analysis shows that both the FCC and Industry Canada rules for siting a radio tower were not complied with if
one includes the 21,000 people in Tsawwassen that are within the harmful 1 V/m blanketing interference contour.
Therefore the application for a land use permit from Whatcom County must be denied because of the deliberate
omissions and obfuscations that allowed the FCC to be misled to issue a construction permit to KRPI under false
pretenses.
To fill in the gaps of missing data provided to Whatcom County CUP application, the contours for 532 V/m, 100V/m,
27 V/m, 250 mV/, 25 mV/m, 5 mV/m and 2.5 V/m must be provided by BBC, along with the separate and combined
US and Canada populations that are contained within these contours. Without this data it is not possible for the
Hearing Examiner to render a fair decision.
Alternately, if Whatcom County cannot say Yes or No because this international violation issue is outside of their
jurisdiction, then prior to its determination on the BBCs permit application, it is only a matter of BASIC FAIRNESS
that the BBCs violation of both Industry Canada regulation C-10.3.1 and the FCC rule 73.24 (g) needs to be
reported to Industry Canada and dealt with between Industry Canada and FCC first, to allow Industry Canada torescind their no objection to the FCC application for a construction permit that did not identify the dense
population of 21,000 immediately across the border only 330 meters away.
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Table 1 - Electric Field Contours used by FCC and Industry Canada rules for the proposed
KRPI 1550 AM radio towers in Point Roberts at 50,000 watts.
Correcting for near field effects are not assumed for the 1V/m or more contours.
NighttimeContours@ 50 KW= E
EstimatedFCCUSPopulation
EstimatedIC Canadapopulation
EstimatedTotalPopulation
Maximumradial
Meters=Sqrt(1000/E mV/m) *4500m
MaximumradialMiles
Contourdistancerelative to2.5V/m Comments
614V/m TBD TBD TBD 182 0.11 0.0020up 1340kHz
Max Avg.Safeexposure togeneralpopulationduring any30 Minuteinterval.
532 V/m 195 0.12 0.00225% = 27V/m
824/1.55 at1550 kHz
100V/m TBD TBD TBD 450 0.28 0.0050PacemakerDefibrillator
Limit
27V/m 866 0.54 0.00965% of532V/m
at 1550 kHz
1V/m 304 20,000 20,304 4,500 2.79 0.050Interferencecontour
250mV/m TBD TBD TBD 9,000 5.59 0.100ICpopulationrule
25mV/m 233,300 60,000 293,300 28,460 17.7 0.316 FCC rule
5mV/m TBD 2,600,000 TBD 63,640 39.5 0.707
MetroVancouver+ Victoria IC rule
2.5mV/m TBD 2,700,000 2,700,000 90,000 55.9 1.000
BC lowermainland+TBD inUSA
locallistening
Postscript: The precautionary principle should be observed
Starting with the maximum exposure limit for the sum of RF-EMF exposures, on the basis of bio-effects and adverse
effects listed in the BioInitiative Report 2012, which reviews over 2000 studies (75);
The European Citizens' Initiative "Electromagnetic Radiation", 2013, (81) recommends for chronic or continuous
exposure a limit of:
0.1W/cm2 = 1 milliwatt/m2 = 0.6 Volts/meter
The maximum radial becomes 5.8 Km (3.6 miles) from KRPI towers @ 50,000 Watts. The area for the 0.6V/m
contour is 1.6 times larger than the area of the 1 V/m blanketing interference contour.
The epidemiological evidence, while still accumulating, is strong enough to support a conclusion and the 2B
classification for the International Agency for Research on Cancer (IARC), an agency of the World Health
Organization (WHO). The conclusion means that there could be some risk of brain cancer, and therefore we
need to keep a close watch for a link between cell phones and cancer risk (50).
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Other studies show that there may be a possible increased incidence of childhood leukemia and brain cancer for
people living near AM radio towers (49, 55).
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Figure 4. Estimated 5 mV/m and 25 mV/m nighttime coverage from Point Roberts
IC contour of 5 mV/m = 0.71 of the radials of the Red contour at 2.5 mV/m
FCC contour of 25 mV/m = 0.32 of the radials of the Red contour at 2.5 mV/m
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References
Note: The FCC website is flaky and may occasionally not be available for use.
1) C-10.3.1 Protection of AM Receivers against Intermodulation and Cross-modulation
Applicants and existing broadcasters are to ensure that their installations are designed and operated in consideration of the
following requirements in order to better assess the potential for interference:Demonstrate that the transmitting site, the antenna pattern and the power of the station is in compliance with the following:
(a) the population within the day or night 250 mV/m contour shall not exceed one person per watt of transmitter power. For
example, for 10,000 watts, the population should not exceed 10,000 persons;
(b) the population enclosed by the day or night 250 mV/m contour shall not exceed one third of the total population within the
centre to be served; and
(c) the population within the day or night 1 V/m contour should be less than 0.02% of the population within the 5 mV/m
contour.
Note: Sqrt(1000/250) = 2. Thus the 250 mV/m maximum radial would be 2 * 4.5 = 9 Km (5.6 miles) approximately. It doublesthe diameter of 1V/m lobes. Thus we should also draw the 250 mV/m contours for nighttime and daytime to check (a) and (b)
above. Item (a) suggests that the maximum nighttime power should be limited to 42,000 watts if all of Ladner and Tsawwassen
are within the nighttime lobe of 250 mV/m. Item (b) suggest that the population served must not exceed 3 * 42,000= 126,000.
C-10.4 Resolving Issues
(B) In the case of immunity-type interference
The broadcasters will be responsible of solving immunity-type interference when applicable, i.e., for valid complaints.
The guidelines on resolving immunity issues related to radio-sensitive equipment are outlined in Industry Canadas Client
Procedures Circular, Determinations of Harmful Interference with respect to Radio-Sensitive Equipment (CPC-3-14-01). This
CPC can also be used as a guide for resolving immunity-related interference to broadcast receivers and associated equipment.
Part 2: Application Procedures and Rules for AM Broadcasting Undertakings BPR-2 Issue 2 January 2009http://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/bpr2-rpr2-v2-jan2009-eng.pdf/$file/bpr2-rpr2-v2-jan2009-eng.pdf
2) FCC 73.24, Revised as of October 1, 2010
73.24 Broadcast facilities; showing required.
An authorization for a new AM broadcast station or increase in facilities of an existing station will be issued only after a
satisfactory showing has been made in regard to the following, among others:
(a) That the proposed assignment will tend to effect a fair, efficient, and equitable distribution of radio service among the
several states and communities.
(b) That a proposed new station (or a proposed change in the facilities of an authorized station) complies with the pertinent
requirements of
73.37 of this chapter.
(e) That the technical equipment proposed, the location of the transmitter, and other technical phases of operation comply
with the regulations governing the same, and the requirements of good engineering practice.
(g) That the population within the 1 V/m contour does not exceed 1.0 percent of the population within the 25 mV/m
contour: Provided,
however, That where the number of persons within the 1 V/m contour is 300 or less the provisions of this paragraph are
not applicable.
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(i) That, for all stations, the daytime 5 mV/m contour encompasses the entire principal community to be served. That, for
stations in the 535-1605 kHz band, 80% of the principal community is encompassed by the nighttime 5 mV/m contour or the
nighttime interference-free contour, whichever value is higher. That, for stations in the 1605-1705 kHz band, 50% of the
principal community is encompassed by the 5 mV/m contour or the nighttime interference-free contour, whichever value is
higher. That, Class D stations with nighttime authorizations need not demonstrate such coverage during nighttime operation.
(j) That the public interest, convenience, and necessity will be served through the operation under the proposed assignment.http://louise.hallikainen.org/FCC/FccRules/2010/73/24/
3) FCC 73.1650, Revised as of December 4, 2012
73.1650 International agreements.
(a) The rules in this part 73, and authorizations for which they provide, are subject to compliance with the international
obligations and undertakings of the United States. Accordingly, all provisions in this part 73 are subject to compliance with
applicable requirements, restrictions, and procedures accepted by the United States that have been established by or pursuant
to treaties or other international agreements, arrangements, or understandings to which the United States is a signatory,
including applicable annexes, protocols, resolutions, recommendations and other supplementing documents associated with
such international instruments.
(b) The United States is a signatory to the following treaties and other international agreements that relate, in whole or in
part, to AM, FM or TV broadcasting:
(1) The following instruments of the International Telecommunication Union:
(i) Constitution, (ii) Convention, (iii) Radio Regulations.
(2) Regional Agreements for the Broadcasting Service in Region 2:
(3) Bi-lateral Agreements between the United States and Canada relating to:
(i) AM Broadcasting.
..
http://www.hallikainen.org/~harold/FCC/FccRules/2012/73/1650/index.php
4) Hatfield & Dawsons principal engineers of the firm are members of the Association of Federal Communications Consulting
Engineers (AFCCE) and the Institute of Electrical and Electronic Engineers (IEEE).
http://www.hatdaw.com/present.html
5) AFCCE members follow:
NSPE Code of Ethics for Engineers - this is a worthwhile read
http://www.afcce.org/code.htm
6) Institute of Electrical and Electronics Engineers: "We, the members of the IEEE, do hereby commit ourselves to the highest
ethical and professional conduct and agree: 1. to accept responsibility in making decisions consistent with the safety, health
and welfare of the public, and to disclose promptly factors that might endanger the public or the environment;"
Engineering ethics
https://en.wikipedia.org/wiki/Engineering_ethics
7) Ritual of the Calling of an Engineer (in Canada)
https://en.wikipedia.org/wiki/Ritual_of_the_Calling_of_an_Engineer
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8) The portion of the Vancouver Island Transmission Reinforcement Project (the Project) within the U.S. would be confined to
about 7.5 miles (12 kilometers) of submarine cable decommissioning and replacement in the Strait of Georgia off of Point
Roberts, Washington.
http://transmission.bchydro.com/nr/rdonlyres/5c8118c0-2e42-4e33-bc97-
2d29256fe112/0/whatcommajorprojectpermitapp14july2006.pdf
9) Deliberate ignorance means, intentionally ignoring a fact when one has every reason to believe about its existence. Whenknowledge of existence of a particular fact is an essential part of an offence, such knowledge may be established if the person
is aware of a high probability of its existence, unless s/he actually believes that it does not exist.
Deliberate ignorance may be established when:
1) The person actually knew about a particular fact.
2) The person deliberately closed his/her eyes to what s/he had every reason to believe was the fact.
3) The requisite proof of knowledge on the part of a person cannot be established by merely demonstrating that s/he was
negligent, careless or foolish.
Deliberate ignorance
http://definitions.uslegal.com/d/deliberate-ignorance/
10) Broadcast Blanketing Interference
http://www.gpo.gov/fdsys/pkg/FR-1996-05-28/pdf/96-12946.pdf
11) FCC Cases on Blanketing Interference - The Responsibility of Broadcasters to their Neighbors
http://www.broadcastlawblog.com/2008/02/articles/tower-issues/fcc-cases-on-blanketing-interference-the-responsibility-of-
broadcasters-to-their-neighbors/
12) KRPI 1550 AM, Ferndale WA
http://www.krpiradio.com/
13) Radio Broadcasting Services; AM or FM Proposals To Change the Community of License
http://www.gpo.gov/fdsys/pkg/FR-2012-02-15/pdf/2012-3561.pdfhttps://www.federalregister.gov/articles/2012/02/15/2012-3561/radio-broadcasting-services-am-or-fm-proposals-to-change-
the-community-of-license
14) KRPI application 2012
https://licensing.fcc.gov/cgi-
bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu.hts?context=25&appn=101484673&formid=301&fac_num=21416
15) FCC's perspective
http://wireless.fcc.gov/siting/FCC_LSGAC_RF_Guide.pdf
16) Blanketing Interference and RFI
http://www.engineeringradio.us/blog/2010/06/blanketing-interference-and-rfi/
17) Census: B.C. cities Burnaby, Richmond, Surrey outpacing Vancouver growthhttp://www.canada.com/technology/Census+cities+Burnaby+Richmond+Surrey+outpacing+Vancouver+growth/6119737/story.html
18) NoTowers website
www.NoTowers.webs.com
19) KRPI Antenna pattern for Point Roberts showing 1Volt/meter contourshttps://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101484673&qnum=5120©num=1&exhcnum=4
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20) Site Selection Report for KRPIhttp://allpointbulletin.com/static/files/Site%20Selection%20Report%20Prepared%20for%20KRPI%20Ferndale%20March%202011.pdf
21) FCC relocation permit for KRPI in Point Roberts
http://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/pubacc/prod/view_auth.pl?Application_id=1484673&File_number=BP-
20090226AAF&Callsign=KRPI&Facility=21416
23) This gives some more design details used to generate the 1V/meter plots
http://licensing.fcc.gov/prod/cdbs/pubacc/Auth_Files/1484673.pdf
24) Litany of complaints to FCC by residents of Ferndale
http://allpointbulletin.com/static/files/Attachment%20B%20comments%20ferndale.pdf
25) FCC monitoring stations quiet zones
http://www.w3beinformed.org/id61.html
26) Ferndale Monitoring Station to be closed in Aug 1995 (but still protected by statute?)
http://transition.fcc.gov/Speeches/Hundt/spreh519.txt
27) U.S. Fish & Wildlife Service Concerns Over Potential Radiation Impacts of Cellular Communication Towers on Migratory
Birds and Other Wildlife Research Opportunities
http://www.hese-project.org/hese-uk/en/papers/manville_wildlife_towers.pdf
28) Longcore T, Rich C, Mineau P, MacDonald B, Bert DG, et al. (2012)
An Estimate of Avian Mortality at Communication Towers in the United States and Canada.
PLoS ONE 7(4): e34025. doi:10.1371/journal.pone.0034025
http://www.plosone.org/article/info:doi/10.1371/journal.pone.0034025
29) Manville, A.M., II. 2005. Bird strikes and electrocutions at power lines, communication towers, and wind turbines: state of
the art and state of the science next steps toward mitigation. Bird Conservation Implementation in the Americas:
Proceedings 3rd International Partners in Flight Conference 2002, C.J. Ralph and T. D. Rich, Editors. U.S.D.A. Forest Service
General Technical Report PSW-GTR-191, Pacific Southwest Research Station, Albany, CA: 1051-1064http://www.fws.gov/midwest///wind/references/ManvilleBirdMortality.pdf
31) Radio Broadcasting Services; AM or FM Proposals To Change the Community of License, KRPI notice
https://www.federalregister.gov/articles/2012/02/15/2012-3561/radio-broadcasting-services-am-or-fm-proposals-to-change-
the-community-of-license
32) KRPI application 2012
https://licensing.fcc.gov/cgi-
bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu.hts?context=25&appn=101484673&formid=301&fac_num=21416
33) "In light of Canadas withdrawal of its objection, the Commission should grant the Petition for Reconsideration, withdraw
its dismissal of BBCs application, and consider the merits of BBCs request to relocate its transmitter site in order to eliminate
blanketing interference complaints in and around its current site in Ferndale."Supplemental Filing Regarding Canadian Interferencehttps://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101484673&qnum=5120©num=1&exhcnum=1
34)?
https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101484673&qnum=5120©num=1&exhcnum=2
35) KRPI From the Residents' Point of View
http://www.radiowest.ca/forum/viewtopic.php?f=6&t=14132
36) Interference
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http://www.fcc.gov/topic/interference
37) Interference: Defining the Source
http://www.fcc.gov/guides/interference-defining-source
38) FCC complaint form
https://esupport.fcc.gov/ccmsforms/form2000.action?form_type=2000F
39) Agreement between the Government of the United States of America and the Government of Canada Relating to the AM
Broadcasting Service in the Medium Frequency Band, in Ottawa in 1984
http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf08821.html
40)?https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101484673&qnum=5120©num=1&exhcnum=3
41) Permit granted by FCC on 24 May 2012
http://licensing.fcc.gov/prod/cdbs/pubacc/Auth_Files/1484673.pdf
42) Application for a "minor" change to move transmitting site and change directional pattern, 8 Aug 2011
http://licensing.fcc.gov/cgi-bin/prod/cdbs/forms/prod/getimportletter_exh.cgi?import_letter_id=27586
FCC Application Search Details:
43) File Number: BP-20090226AAF
http://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/pubacc/prod/app_det.pl?Application_id=1484673
44) Correspondence folder
http://licensing.fcc.gov/cgi-
bin/ws.exe/prod/cdbs/pubacc/prod/corrp_list.pl?Application_id=1484673&File_Prefix=BP&App_Arn=20090226AAF&
Facility_id=21416
45) FCC Final Rule Regarding Human Exposure to RadiofrequencyElectromagnetic Fields
http://www.rfcomply.com/news/fullnews.php?fn_id=288
46) 47 CFR Parts 1, 2, and 15, et al.
Human Exposure to Radiofrequency Electromagnetic Fields; Reassessment of Exposure to Radiofrequency Electromagnetic
Fields Limits and Policies;
Final Rule and Proposed Rule, 4 June 2013
http://www.gpo.gov/fdsys/pkg/FR-2013-06-04/pdf/2013-12716.pdf
47) Electropollution, Scott Appert at
http://www.biohealthyhomes.com/about.html.Here is a video of his on EMR:
http://youtu.be/PktaaxPl7RI
48) Electromagnetic fields cause fluorescent bulbs to glow
http://www.doobybrain.com/2008/02/03/electromagnetic-fields-cause-fluorescent-bulbs-to-glow/
49) Koreans Again Link AM Radio to Childhood Leukemia
http://www.mast-victims.org/index.php?content=news&action=view&type=newsitem&id=1932
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50) IARC CLASSIFIES RADIOFREQUENCY ELECTROMAGNETIC FIELDS AS POSSIBLY CARCINOGENIC TO HUMANS
http://www.iarc.fr/en/media-centre/pr/2011/pdfs/pr208_E.pdf
51) Letter to the FCC regarding RF Exposure Limits, 30 Aug 2013, 189 pp.
http://aaemonline.org/images/FCCLtr.pdf
http://aaemonline.org/
52) American Academy of Environmental Medicine
Electromagnetic and Radiofrequency Fields Effect on Human He
http://aaemonline.org/emfpositionstatement.pdf
53) European Citizens' Initiative "Electromagnetic Radiationhttp://www.peccem.org/DocumentacionDescarga/Campanas/ICE2013/ENG_EUROPEAN_MANIFESTO_IN_SUPPORT_THE_ECI.pdf
54) Radio-Frequency Radiation Exposure from AM Radio Transmitters and Childhood Leukemia and Brain Cancer
http://aje.oxfordjournals.org/content/166/3/270.full.pdf
55) RE: RADIO-FREQUENCY RADIATION EXPOSURE FROM AM RADIO TRANSMITTERS AND CHILDHOOD
LEUKEMIA AND BRAIN CANCER
http://aje.oxfordjournals.org/content/167/7/883.full.pdf
56) Five Author's reply
http://aje.oxfordjournals.org/content/167/7/884.full.pdf
57) KRPI AM Radio Transmitter Site / BBC Broadcasting Inc.
http://www.co.whatcom.wa.us/pds/plan/current/krpi-radio.jsp
58) Making Sense of Odds and Odds Ratios
David A. Grimes, MD, and Kenneth F. Schulz, PhD, MBA
http://meds.queensu.ca/medicine/obgyn/pdf/Making.Sense.of.Odds.pdf
59) Zhang J, Yu KF. Whats the relative risk? A method of correcting the odds ratio in cohort studies of common outcomes.JAMA 1998;280:16901.
http://jama.jamanetwork.com/article.aspx?articleid=188182
60) Point Roberts Radio Towers blog
http://prtowers.blogspot.ca/
61) Border Blaster
https://en.wikipedia.org/wiki/Border_blaster
62) Mexican Border Blasters Break For The Border
http://www.modestoradiomuseum.org/border%20index.html
63) Koreans Again Link AM Radio to Childhood Leukemia- RFI Tops Health in U.S. AM Tower Siting Battle
http://microwavenews.com/news-center/koreans-again-link-am-radio-childhood-leukemia-rfi-tops-health-us-tower-siting-
battle
64) American Journal of Epidemiology aje.oxfordjournals.org
Am. J. Epidemiol. (2007) 166 (3): 270-279. doi: 10.1093/aje/kwm083
First published online: June 7, 2007
Radio-Frequency Radiation Exposure from AM Radio Transmitters and Childhood Leukemia and Brain Cancer
http://aje.oxfordjournals.org/content/166/3/270.abstract
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65) EPA on Nonthermal Effects
http://microwavenews.com/news/backissues/s-o02issue.pdfpage 8
66 ) Several articles on RF impacts
http://www.powerwatch.org.uk/news/20070725_essex_provocation
67) Near the end of the Delta Council session on Sept 9, the Mayor agreed to have a letter sent under her nameSee time segment 2:20:40 to 2:24:45
http://deltabc.ca.granicus.com/MediaPlayer.php?view_id=2&clip_id=264
68) Exhibit C on the FCC website which has the engineering study can now be linked but it does not appear on the Whatcom
website.https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101484673&qnum=5130©num=1&exhcnum=8
and it is not the same as:
69) Appendix C - Existing conditions from key observation points
http://www.co.whatcom.wa.us/pds/plan/current/pdf/2-appendix-c-existing-conditions-from-key-observation-points.pdf
70) "Accordingly, pursuant to Section 309(k) of the Act and Sections 0.61 and 0.283 of the
Commission's Rules, IT IS ORDERED that the informal objection filed by Ms. Sheila Weber on behalf of Residents Against High-
Power Radio Interference IS DENIED. IT IS FURTHER ORDERED, that the application (File No. BR-20050922ACS) of BBC
Broadcasting, Inc. for renewal of license for station KRPI(AM), Ferndale, Washington IS GRANTED."
http://licensing.fcc.gov/cgi-bin/prod/cdbs/forms/prod/getimportletter_exh.cgi?import_letter_id=8700
http://digital.library.unt.edu/ark:/67531/metadc6515/m1/64/ same letter appears here!
71) The customer complaints from Ferndale are summarized but detailed list attached to Ms. Sheila Weber's letter is not
included. Fortunately they are still available at:
http://allpointbulletin.com/static/files/Attachment%20B%20comments%20ferndale.pdf
72) In re: BBC Broadcasting, Inc., KRPI (AM), Ferndale, Washington
Facility ID 21416, File No. BR-20050922ACS
Application for Renewal of License- Informal Objectionhttp://licensing.fcc.gov/cgi-bin/prod/cdbs/forms/prod/getimportletter_exh.cgi?import_letter_id=8700
73) Wireless Harm - Biological Effects of Wireless Technology
http://www.freewebs.com/maggiezhou/wirelessharm.htm
74) Recommendation ITU-R P.832-3 (02/2012)
World atlas of ground conductivities
http://www.itu.int/dms_pubrec/itu-r/rec/p/R-REC-P.832-3-201202-I!!PDF-E.pdf
75) BioInitiative 2012- A Rationale for Biologically-based Exposure Standards for Low-Intensity
Electromagnetic Radiation
http://bioinitiative.org/report/wp-content/uploads/pdfs/BioInitiativePressRelease1-1-2013.pdf
http://www.bioinitiative.org/report/wp-content/uploads/pdfs/BioInitiativeReport2012.pdf1479 pp
76) Determinations of Harmful Interference with respect to
Radio-Sensitive Equipment
http://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/cpc3141e.pdf/$FILE/cpc3141e.pdf
77) Criteria for Resolution of Immunity Complaints Involving Fundamental
Emissions of Radiocommunications Transmitters
http://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/emcab2.pdf/$FILE/emcab2.pdf
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78) See last paragraph on Page 66 of FCC OET Bulletin 65, Edition 97-01
http://www.whatcomcounty.us/pds/plan/current/pdf/fcc-guidelines-human-exposure-to-emf.pdf
79) ITU Regulations
http://www.itu.int/en/sama/Pages/questionnaire2.aspx?pub=R-REG-RR-2012-ZPF-E
80) Agreement between the Government of the United States of America and the Government of Canada relating to the AMBroadcasting Service in the Medium Frequency Band
http://transition.fcc.gov/ib/sand/agree/files/can-bc/can-am.pdf
81) European Citizens' Initiative "Electromagnetic Radiationhttp://www.peccem.org/DocumentacionDescarga/Campanas/ICE2013/ENG_EUROPEAN_MANIFESTO_IN_SUPPORT_THE_ECI.pdf
http://apps.fcc.gov/ecfs/document/view?id=7520941197
82) EMR Epidemiological Principles for EMF and EMR Studies
http://www.neilcherry.com/documents/90_p1_EMR_Epidemiological_Principles_for_EMF_and_EMR_Studies.pdf
83) STPA Primer, Chap 1, Sec 1,What is an Accident Causality Model, by Nancy Leveson, MIT, Ver. 1, Aug. 2013
http://sunnyday.mit.edu/STPA-Primer-v0.pdf
84) Adult and Childhood Leukemia near a High-Power Radio Station in Rome, Italy
Paola Michelozzi, Alessandra Capon, Ursula Kirchmayer, Francesco Forastiere, Annibale Biggeri,
Alessandra Barca, and Carlo A. Perucci, 2002, American Journal of Epidemiology, Vol.155, No. 12
http://aje.oxfordjournals.org/content/155/12/1096.full.pdf
85) Vatican Radio is told to pay out over cancer risk scare, By Michael Day in Milan, Tuesday, 1 March 2011
http://www.independent.co.uk/news/world/europe/vatican-radio-is-told-to-pay-out-over-cancer-risk-scare-2228541.html
86) Tsawwassen residents opposed to plans to build new radio towers, October 24, 2013 5:27 am
http://globalnews.ca/news/922458/tsawwassen-residents-opposed-to-plans-to-build-new-radio-towers/
87) Radio tower proponents swing into action, Thu, Oct 24, 2013 by Meg Olson
http://www.allpointbulletin.com/news/article.exm/2013-10-24_radio_tower_proponents_swing_into_action
88) Report On the National Antenna Tower Policy Review, Section D The Six Policy Questions
Question 6. What evidence exists that property values are impacted by the placement of antenna towers?
http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf08353.html
89) Impact of Cellphone Towers on Property Values
http://www.mfe.govt.nz/publications/rma/nes-telecommunications-section32-aug08/html/page12.html
90) Guide to Assist Landuse Authorities in Developing Antenna Siting Protocols, Issue 1, January 2008
http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf08839.html
91) Radiofrequency Toolkit for Environmental Health Practitioners
http://www.bccdc.ca/NR/rdonlyres/9AE4404B-67FF-411E-81B1-4DB75846BF2F/0/RadiofrequencyToolkit_v4_06132013.pdf