An analysis of siting criteria for the KRPI 5-tower array

7/26/2019 An analysis of siting criteria for the KRPI 5-tower array

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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&copynum=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&copynum=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&copynum=1&exhcnum=1

34)?

https://licensing.fcc.gov/cdbs/CDBS_Attachment/getattachment.jsp?appn=101484673&qnum=5120&copynum=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&copynum=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


56) Five Author's reply


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&copynum=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


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?


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


91) Radiofrequency Toolkit for Environmental Health Practitioners

http://www.bccdc.ca/NR/rdonlyres/9AE4404B-67FF-411E-81B1-4DB75846BF2F/0/RadiofrequencyToolkit_v4_06132013.pdf

An analysis of siting criteria for the KRPI 5-tower array

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