UnitedStates
Environmental Protection
Agency
Office of
Radiation Programs
Washington, D C 20460
Radiation
v>EPA
An Estimate of the
Potential Costs of
Guidelines Limiting
Public Exposure to
Radiofrequency Radiation
from Broadcast Sources
Volume 1 : Report
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DISCLAIMER
This document was prepared as an account of work sponsored by an agency of the United Stales Government.
Neither the United Stales Government nor the University of California nor any of their employees, makes any
warrant), express or implied, or assumes an) legal liability or responsibility for the accuracy, completeness, or
usefulness of an) information, apparatus, product, or process disclosed, or represents that its use would not infringe
privately owned rights. Reference herein to any specific commercial products, process, or service by trade name.
trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or
favoring b> the United States Government or the University of California. The views and opinions of authors
expressed herein do not necessaril) stale or reflect those of the United Slates Government or the University of
California, and shall not be used for advertising or product endorsement purposes.
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EPA 520/1-85-025
UCRL-53562 Vol. 1
AN ESTIMATE OF THE POTENTIAL COSTS OF
GUIDELINES LIMITING PUBLIC EXPOSURE
TO RADIOFREQUENCY RADIATION
FROM BROADCAST SOURCES
Volume 1: Report
BY
Charles H. Hall
Lawrence Livermore National Laboratory
Livermore, CA 94550
3uly 1985
This report was prepared as an account of contract work sponsored by the United States
Environmental Protection Agency under Interagency Agreement No. AD-89-F-2-803-0
with Lawrence Livermore National Laboratory.
Project Officers
C. Elliot Foutes
Richard A. Tell
Office of Radiation Programs
U.S. Environmental Protection Agency
Washington, D.C. 20460
U.S. Environment?! r:-'^,1:'-;^ /->ency
Region 5, Library ^.' -;
77 West Jackson J
Chicago, IL 60GJ-.--.
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TT
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PREFACE
The purpose of the study reported here is to estimate the potential cost of a federal
guidance proposed by the Environmental Protection Agency (EPA) limiting public exposure
to radiofrequency (RF) radiation. An estimate of the economic effects of proposed
federal actions is mandated by a series of Executive Orders (EOs), the latest of which is
EO 12291, Federal Regulation, which is implemented by an Office of Management and
Budget guidance on regulatory impact analysis and, in EPA, by a companion guideline for
performing regulatory impact analyses. The federal radiofrequency radiation protection
guidance has been developed by the EPA under the Federal Radiation Council Authority,
42 U.S.C. 202 l(h), transferred to EPA by EO 10831, Reorganization Plan Number 3 of
1970 and by Public Law 86-373.
The EPA has conducted research over the past 12 years on the electromagnetic
environment to which the public is exposed and on the propagation of RF by a wide
variety of sources, the most significant of which are AM and FM radio, VHF-TV and
UHF-TV broadcast stations. The cost study is limited to these significant sources of RF.
One of the results of this study, in conjunction with EPA research, is a conceptual
development of the type of mitigation measures necessary to effect compliance, as
indicated by model results at 18 alternative guidance levels ranging from 1 yW/cm2 (FM
and TV) or 10 V/m (AM) to 10,000 yW/cm2 (FM and TV) or 1,000 V/m (AM). The cost of
compliance was estimated using a series of models that present a range (low, medium, and
high) of costs to society-at-large, costs to the broadcast industry and costs to and effects
on the net income of the average broadcast station. The costs are expressed in a variety
of ways, including gross cost, net annual cash flow cost, average annual cash flow cost,
and present value.
The report is organized into two volumes, the first a description of the study and a
summary of results, the second a series of appendices containing an explanation and
sample of the calculations for each of the three segments of the broadcast industry; the
appendices also include detailed tabular and graphic descriptions of various cost estimates
at each of the 18 guidance levels at the three cost levels. Volume I begins with a preface,
executive summary, and abstract, followed by an introduction in which a discussion of the
purpose and scope of the study lead to an extensive graphic presentation of conclusions
supported by summary tables. Following this is a background section outlining the purpose
for and current efforts to regulate RF radiation, public and industry concerns over RF and
111
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its regulation, a brief review of the electromagnetic environment and of health effects
research, a profile of commercial broadcast facilities and a discussion of the framework
for regulatory (economic) impact analyses.
The next section describes the method of approach used in the cost study. Following
this is a section describing the compliance measure concepts developed by the EPA and
consultants as part of this study. The remaining section describes the cost models—social,
industry, and average firm. All assumptions, including costs, application of compliance
measures and financial parameters, are discussed throughout and summarized at the
conclusion of Volume I for convenience.
Volume II contains three appendices, one each for AM and FM radio and TV
broadcast stations, that present a step-by-step explanation of each of the calculations in
the cost models. Those are followed by other appendices that present detailed estimates
of the cost of compliance with 18 guidance levels at three cost levels, given in terms of
the cost to society-at-large, the cost to industry, and the cost to the average broadcast
firm; in addition, the number of stations requiring a compliance measure at each guidance
level is given. The average annual cash flow cost and present value estimates are plotted
for each of the three analyses (social, industry, and average firm) at three cost levels.
These are supported by data in the tables, which also contain other cost analyses not
plotted.
This two-volume report is one of a number of documents presenting research that
was used to develop the proposed RF guidance and provide analyses for reviewers and
decision makers considering it. A presentation of the engineering and health studies is
contained in three reports published or in preparation by the U.S. Environmental
Protection Agency. A review of over 5000 citations of health risks and biological effects
of RF is given in U.S. Environmental Protection Agency, Biological Effects of
Radiofrequency Radiation, J. A. Elder and D. F. Cahill Eds., Health Effects Research
Laboratory, Research Triangle Park, North Carolina, EPA-600/8-83-026F, September
1984. A study of the engineering aspects of radiofrequency radiation is contained in
Gailey, P. C. and R. A. Tell, An Engineering Assessment of the Potential Impact of
Federal Radiation Protection Guidance on the AM, FM, and TV Broadcast Services, U.S.
Environmental Protection Agency, Washington, D.C. (in press). A third report has been
prepared on the radiofrequency environment: Hankin, N. N., The Radiofrequency
Radiation Environment; Environmental Exposure Levels and RF-Emitting Sources, U.S.
Environmental Protection Agency, Washington, D.C. (in press).
IV
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TABLE OF CONTENTS
VOLUME I: Report
Preface iii
Executive Summary ix
Abstract 1
Introduction and Background 1
Purpose 1
Scope 2
Research Results Overview 2
Standards Limiting Exposure to Radiofrequency and
Microwave Energy 10
Current Regulatory Efforts 12
The Electromagnetic Energy Environment 12
Research on Biological Effects and Health Risks of
Radiofrequency/Microwave Radiation 13
Concerns of the Broadcast, Communications, and
Electronic Equipment Industries 14
Purpose of Standards Limiting Public Exposure to
Radiof requency/Microwave Energy 16
Prof ile of Broadcast Facilities 16
Framework for the Economic Study 23
Methodology 29
Environmental Protection Agency Radiofrequency
Radiation Research 30
Environmental Protection Agency Data Base 32
Radiofrequency Radiation Source Groups 32
Environmental Protection Agency Broadcast Signal
Propagation Models 34
Radiofrequency Radiation Guidelines 34
Compliance Measures Research 35
Model of Station Selection of Compliance Measures 35
Environmental Protection Agency Compliance
Measures Effect Models 39
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Society-at-Large Cost Estimation Models 39
Industry Cost Estimation Models 40
Average Firm Cost Estimation Models 41
Summation Cost Models 41
Measures to Comply with Radiofrequency Radiation Guidelines 42
Reduce Effective Radiated Power 42
Prohibit Public Access to Areas Exposed to Field
Strengths Exceeding the Standard 43
Post Warning Signs in Areas Exposed to Excess RF 43
Install Shield on Building-Based Antenna Towers 45
Install Reflective Materials on Adjacent Building Windows 45
Change the Power-to-Gain Relationship 46
Replace Existing Antenna with A More Efficient Model 46
Optimize Inter-Bay Spacing of the Antenna Elements
for Minimal Downward Radiation 47
Measurement 47
Calculation 48
Create Groups of Elements 48
Raise the Antenna 50
Summary of Compliance Measures Selected for FM, AM, and
TV Broadcast Stations 51
Compliance Measure Costs 54
Society-at-Large Cost Model 59
Industry Cost Model 63
Average Firm Cost Model 67
Summary of Assumptions 72
General Assumptions 72
Assumptions for FM Radio Stations 73
Assumptions for AM Radio Stations 74
Assumptions for TV Broadcast Stations 74
Summary of Research Results 74
References 79
VI
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VOLUME II: Appendices
Appendix A: Economic Methodology: Sample Computations and
Engineering Data for FM Stations A-l
Appendix B: Economic Methodology: Sample Computations and
Engineering Data for AM Stations B-l
Appendix C: Economic Methodology: Sample Computations and
Engineering Data for TV Stations C-l
Appendix D: Cost Estimates for FM Stations D-l
Appendix E: Cost Estimates for AM Stations E-l
Appendix F: Cost Estimates for TV Stations F-l
Appendix G: Total Cost Estimates: FM, AM, TV G-l
VI1
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ITTA
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EXECUTIVE SUMMARY
The purpose of this study is to estimate the potential cost of a federal guidance
limiting public exposure to radiofrequency (RF) radiation; the study addresses the cost of
compliance of the broadcast industry and its three major segments—the 9000 AM and FM
radio stations and the 1000 VHF-TV and UHF-TV broadcast stations in the U.S. The cost
of compliance was estimated in terms of three kinds of economic analyses, for which
models were developed: the cost to society-at-large, the cost to the broadcast industry,
and the cost to and effect on the net profit of the average broadcast station. For these
analyses, estimates were made of the cost of 18 alternative guidance levels ranging from
1 yW/cm2 (FM and TV) or 10 V/m (AM), the most stringent, to 10,000 yW/cm2 (FM and TV)
or 1000 V/m (AM), the least stringent, using a low, medium, and high estimate of the cost
of components for compliance measures.
The federal RF radiation protection guidance analyzed in this study has been
developed and proposed by the U.S. Environmental Protection Agency (EPA) under the
authority of the Federal Radiation Council, 42 U.S.C. 2021 (h), which was transferred to
the EPA by Executive Order (EO) 10831, Reorganization Plan Number 3 of 1970 and by
Public Law 86-373. Accordingly, the Nonionizing Radiation Branch, Office of Radiation
Programs of the EPA has conducted an extensive research program over the past 12 years
on the electromagnetic environment to which the public is exposed. This research has
included a number of studies of the propagation of RF by a wide variety of sources
including shortwave (high frequency) radio, satellite communication earth terminals,
point-to-point microwave radio antennas, various kinds of radar, land/mobile
communications, and hand-held transceivers. This research indicates that the broadcast
industry, FM radio and VHF-TV transmitters in particular, contribute the majority of RF
to which the public is exposed in the general environment. Therefore, the EPA has
focused on the broadcast industry as the most important foundation for a cost study and
has developed models that estimate the RF energy deposition on the ground from AM and
FM radio, VHF-TV and UHF-TV antennas. The models use a data base the EPA developed
by combining information manually extracted from Federal Communications Commission
engineering files with results of studies of the propagation characteristics of various
commonly used antennas. Using these models the EPA has estimated the RF pattern and
intensity of all 10,000 AM and FM radio, VHF-TV and UHF-TV broadcast stations. These
RF propagation estimates were compared with the 18 specified guidance levels; for those
stations estimated to exceed a given guidance level, a series of increasingly
IX
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complex, effective, and costly compliance measures was tried in succession until
compliance was indicated by model results. This provided the engineering basis for the
cost models.
An estimate of the economic effects of proposed federal actions is mandated by a
series of Executive Orders, the latest of which is EO 12291, Federal Regulation, which is
implemented by an Office of Management and Budget guidance on regulatory impact
analysis and, in EPA, by a companion guideline for performing regulatory impact
analyses. Accordingly, the EPA contracted with the Environmental Sciences Division of
the Lawrence Livermore National Laboratory under EPA-DOE (Department of Energy)
Interagency Agreement AD-89-F-2-803-0 to conduct the cost study.
The social cost models estimate the entire cost to society-at-large, defined as the
opportunity cost of allocating resources for the purpose of reducing RF radiation at the
exclusion of other uses, in terms of component and gross cost, annual cash flow
(undiscounted) cost and present (discounted) value of the cost of the guidance. The
industry cost models estimate the annual and average cash flow (undiscounted) cost and
present (discounted) value of the cost of compliance. The average firm models estimate
the annual gross cash flow (undiscounted) cost, tax shelter, net annual and average cash
flow cost, net income after compliance and present value of the cost of compliance. The
industry and average firm models produce results that are net of income tax deductions
and credits and include the cost of financing the required compliance measures.
The results show that the cost of compliance in all three analyses drops very rapidly
from guidance level 1 to 4, then rapidly from 4 to about 9 or 10, and then more gradually
to level 18. The percentages of stations requiring a mitigation measure are 94% (FM),
100% (AM), and 76% (TV) at guidance level 1; at guidance level 18 the percentages
requiring a mitigation measure are 1% (FM), 0% (AM), and 0% (TV). The present
(discounted) value of the cost to society-at-large of compliance with the proposed RF
guidance varies from a maximum (high cost assumptions) of $866.6 million for guidance
level 1 to a minimum (low cost assumptions) of $12.7 million for guidance level 18. The
annual cash flow (undiscounted) cost to society varies from $207.8 million to
$3.1 million. The present value of the net after tax cost to the broadcast industry varies
from $414.6 million to $6.9 million. The average annual net after tax cash flow cost to
the broadcast industry varies from $59.1 million to $0.8 million. The average present
value of the net after tax cost to the average broadcast firm varies from a maximum of
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$40.6 thousand (FM), $7.9 thousand (AM), $285.3 thousand (TV) to a minimum of
$4.8 thousand (FM), $1.3 thousand (AM), $0.7 thousand (TV). The average annual net
after tax cash flow cost to the average broadcast firm varies from a maximum of
$9.7 thousand (FM), $1.8 thousand (AM), $67.8 thousand (TV) to a minimum of
$1.1 thousand (FM), $0.3 thousand (AM), $0.1 thousand (TV). The reduction in the net
profit of the average broadcast firm from maximum cash flow expenses associated with
compliance varies from a maximum of 16.4% (FM), 5.1% (AM), 8.4% (TV) to a minimum of
2.5% (FM), 1.4% (AM), 0.1% (TV). The reduction in the net profit from the average cash
flow expense of Compliance is about 50% of the maximum percent effect on profits.
XI
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Xli
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ABSTRACT
The purpose of this study is to estimate the cost of a federal guidance proposed by
the U.S. Environmental Protection Agency (EPA) limiting public exposure to
radiofrequency (RF) radiation from the broadcast industry—the 9000 AM and FM radio
stations and 1000 VHF-TV and UHF-TV broadcast stations in the U.S.— that EPA research
indicates is the most significant source of RF to which the public is exposed. The
Lawrence Livermore National Laboratory developed models that estimate a variety of
costs at 18 alternative guidance levels for three kinds of economic analysis: the cost to
society-at-large, the cost to the broadcast industry and the cost to and effect on net
profit of the average broadcast station. The total present (discounted) value of the cost
to society varies from a maximum (high-cost assumption) of $866.6 million for guidance
level 1 and drops very rapidly to guidance level 4 then rapidly to level 10 and more
gradually to a minimum (low-cost assumption) of $12.7 million for guidance level 18. The
maximum reduction in net profit from increased cash flow costs to the average broadcast
firm over the assumed 6 years of costs varies from 16.4% (FM) at guidance level 1 to
0.1% (TV) at guidance level 18.
INTRODUCTION AND BACKGROUND
PURPOSE
The goal of this study is to assist the Environmental Protection Agency (EPA) in
addressing the cost of regulation as mandated by Executive Order (EO) 122911, by Office
of Management and Budget (OMB) guidance on regulatory impact analysis2, and by EPA
guidance on regulatory impact analysis.3 To accomplish this goal, Lawrence Livermore
National Laboratory (LLNL) has developed and applied a methodology to analyze the
potential cost of a Federal guidance limiting public exposure to radio freqency (RF)
radiation proposed by the EPA. At the time this analysis was conducted, important
categories of benefits had been identified but not quantified.
The purpose of this study, to develop and apply a cost methodology, was carried out
by developing models that estimate a variety of costs of compliance for three types of
economic analysis: the cost to society-at-large, the cost to the broadcast industry, and
the cost to and effect on the net profit of the average broadcast firm. Using the results
of an engineering analysis provided by EPA,1* we made estimates of the cost of 18
alternative guidance levels ranging from 1 yW/cm2 (FM and TV) or 10 V/m (AM), the most
stringent, to 10,000 yW/cm2 (FM and TV) or 1,000 V/m (AM), the least stringent, using
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three levels of costs for compliance measure components. Among the costs estimated for
each of the three analyses are component and gross compliance cost, projected actual and
average annual cash flow (undiscounted) cost, and present (discounted) value. The average
firm models estimate the net after tax effect of compliance on profit.
SCOPE
Anthropogenic sources of RF are many and are proliferating. Contributors to the
general RF environment include point-to-point and earth-satellite communication system
microwave broadcast antennas, military and civilian defense and navigation radar,
land-mobile transmitters, hand-held transceivers, police traffic control radar, medical
diathermy, commercial and residential microwave ovens, industrial sealers and heaters,
shortwave radio, commercial FM and AM radio, VHF-TV and UHF-TV broadcast sources.
Continued development of applications of RF energy in industrial processes and the
communications industry such as the emerging low-power TV stations, cellular radio, and
high-density TV, will increase the number of sources of RF. This study focuses on the
existing commercial technology of the broadcast industry, because EPA's Office of
Radiation Programs (ORP) research over the past 12 years indicates that this industry and
FM and VHF-TV transmitters in particular are the most significant sources of RF to which
the public is exposed.
RESEARCH RESULTS OVERVIEW
The EPA originally established 18 VHP field intensity levels as the basis of the
economic study. The majority of the cost estimates were performed with the assumption
that the frequency dependency of the guidance levels would be structured with the FM
and TV limit (in yW/cm2) established uniformly about 26.5 times more stringent than the
AM limit for all 18 guidance levels studied. However, the EPA is now considering three
alternative frequency-dependent guidance options: for option 1, the FM and TV limit (in
yWcm2) is 20 times more stringent than for AM; for options 2 and 3, the FM and TV limit
is 200 times more strigent than for AM. The three alternative regulatory options thus
have a different relationship between the limits applied to the AM band and those applied
to FM and VHF-TV frequencies from the guidance levels used originally in the cost
analysis. However, because each of the three broadcast services was analyzed
independently at 18 different guidance levels, the total cost of any frequency-dependent
standard can be estimated by combining the cost to each service at the guidance level
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applied to that service. The alternative guidance options currently under consideration
for proposal by the EPA are structured for the three broadcast services as follows:
EPA Alternative Guidance Options
Limiting field strength
at AM frequencies V/m
New
guide
option
field
strength
)ption 1 87
)ption 2 275
)ption 3 614
Nearest
lower
cost
study
field
strength
86.6
264.6
446.7
Cost
study
guide
level
5
12
16
Limiting power densities at
FM and TV frequencies yW/cm*
New
guide
option
field
strength
100
200
1000
Nearest
lower
cost
study
field
strength
100
200
1000
Cost
study
guide
level
6
7
15
Using the nearest lower, more expensive, guidance level when the new option falls
between two guidance levels used in the cost study,a we estimated the social, industry,
and average firm costs of compliance with the three new options. Figures 1-3 indicate
the present value of the cost to society, industry and the average firm, respectively. The
total present value of the cost to society varies from a maximum of $93.4 million
(high-cost assumptions) for option 1 to $15.9 million (low-cost assumptions) for option 3
(Fig. 1). The total present value of the cost of compliance to the broadcast industry
varies from a maximum of $45.6 million (high cost) for option 1 to $8.4 million (low cost)
for option 3 (Fig. 2). The average present value of the cost of compliance for the average
firm varies from a maximum of $22.0 thousand (FM), $2.6 thousand (AM), $70.3 thousand
(TV) for option 1 (high cost) to a minimum of $6.4 thousand (FM), $1.3 thousand (AM),
$23.1 thousand (TV) for option 3 (low cost) (Fig. 3). Data for these figures are presented
in Tables 1-3. Additional estimates of costs to the average firm are shown in Table 3 and
include the average net annual cash flow cost and the maximum and average reduction in
profit.
a Another approach is to interpolate between two guidance levels for which costs have
been estimated. Using the next lower cost study guidance level is more conservative,
overstating the cost somewhat.
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OJ
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ca
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O
70 |-
60
50
40
30 -
20 -
10 -
FM
FM
AM
TV
AM
FM
TV
AM
High
Medium
Low
TV
Option 1
Option 2
Option 3
Figure 1. The range of the total present (constant dollar) value
of the cost to society-at-large of guidelines limiting public
exposure to radiofrequency radiation from FM, AM, and TV broadcast
sources is shown for three possible guidance structures.
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GO
t_
to
o
ca
c
o
35 r
30
25
20
15
13
5 -
High
Medium
Low
Option 1
Option 2
Option 3
Figure 2. The range of the total present (constant dollar) value of the net after-tax cost
to the broadcast industry of guidelines limiting public exposure to radiofrequency
radiation from AM, FM, and TV broadcast sources is shown for three possible guidance
structures.
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GO
£_
CO
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CO
oo
80 r
70
60
50
40
30
20
10
TV
FM
AM
TV
FM
AM
FM
High
Medium
Low
TV
Option 1
Option 2
Option 3
Figure 3. The range of the average present (constant dollar) value
of the net after-tax cost to the average FM, AM, and TV broadcast
station of guidelines limiting public exposure to radiofrequency
radiation is shown for three possible guidance structures.
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TABLE 1. AN ESTIMATE OF THE TOTAL PRESENT (CONSTANT DOLLAR) VALUE OF THE COST TO SOCIETY-AT-LARGE
OF GUIDELINES LIMITING PUBLIC EXPOSURE TO RADIOFREQUENCY RADIATION FROM FM, AM, AND TV BROADCAST
SOURCES IS SHOWN FOR THREE POSSIBLE GUIDANCE STRUCTURES. NUMBERS ARE IN MILLIONS OF DOLLARS.
FM AM TV TOTAL
LOU MED HIGH LOW MED HIGH LOW MED HIGH LOW MED HIGH
ALTERNATIVE 1 22.2 44.7 60.4 9.4 15.0 22.0 7.1 9.8 11.0 38.7 69.5 93.4
ALTERNATIVE 2 16.2 31.2 41.6 6.8 9.8 13.3 3.5 4.7 5.4 26.5 45.7 60.3
ALTERNATIVE 3 7.8 12.4 16.0 6.7 9.6 12.8 1.4 1.9 2.4 15.9 23.9 31.2
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TABLE 2. AN ESTIMATE OF THE TOTAL PRESENT (CONSTANT DOLLAR) VALUE OF THE NET AFTER-TAX COST TO THE BROADCAST
INDUSTRY OF GUIDELINES LIMITING PUBLIC EXPOSURE TO RADIOFREQUENCY RADIATION FROM FM, AM, AND TV BROADCAST
SOURCES IS SHOWN FOR THREE POSSIBLE GUIDANCE STRUCTURES. NUMBERS ARE IN MILLIONS OF DOLLARS.
FM AM TV TOTAL
LOW MED HIGH LOW MED HIGH LOH MED HIGH LOW MED HIGH
ALTERNATIVE 1 10.9 21.7 29.2 4.8 7.6 11.0 3.4 4.7 5.4 19.1 34.0 45.6
ALTERNATIVE Z 8.0 15.Z 20.3 3.6 5.2 6.9 1.7 Z.3 2.7 13.4 Z2.7 29.9
ALTERNATIVE 3 4.C 6.4 8.2 3.6 S.I 6.7 0.8 1.0 1.3 8.4 12.4 16.2
OO
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TABLE 3. AN ESTIMATE OF THE POTENTIAL NET AFTER-TAX COST TO THE AVERAGE BROADCAST STATION OF GUIDELINES
LIMITING PUBLIC EXPOSURE TO RADIOFREQUENCY RADIATION FROM FM, AM, AND TV BROADCAST SOURCES IS SHOWN FOR
THREE POSSIBLE GUIDANCE STRUCTURES. NUMBERS ARE IN THOUSANDS OF DOLLARS.
ALTERNATIVE 1
AVG ANN CASH FLOW COST
AVERAGE PRESENT VALUE
MAX PROFIT DROP (.'/.•>
AVG PROFIT DROP (.V.I
ALTERNATIVE 2
AVG ANN CASH RON COST
AVERAGE PRESENT VALUE
MAX PROFIT DROP (.'.',)
AVG PROFIT DROP (.•/.)
ALTERNATIVE 3
AVG ANN CASH FLOII COST
AVERAGE PRESENT VALUE
MAX PROFIT DROP CO
AVG PROFIT DROP (.7.)
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STANDARDS LIMITING EXPOSURE TO RADIOFREQUENCY
AND MICROWAVE ENERGY
There is a long history of serious concern over establishing standards for
occupational and public exposure and product emissions of electromagnetic, or radio
wave, energy.5 The EPA, with the absorption of the Federal Radiation Council in 1970,
has assumed authority over non-ionizing as well as ionizing radiation as an environmental
parameter within its jurisdiction that has potential public health risks. This parallels a
number of other agencies, public and private, that have a continuing interest in
non-ionizing or radiofrequency and microwave (RF/MW) radiation energy. Since 1966, the
American National Standards Institute (ANSI) has issued, and conducted scheduled
revisions of, both occupational and non-occupational (public) RF/MW standards, the latest
in August of 1983.6 Figure 4 shows a comparison of selected RF standards including the
previous and current ANSI standards.
The National Telecommunications and Information Administration (NTIA) within the
Department of Commerce (DOC) has held responsibility for coordinating non-ionizing
radiation bioeffects research. The NTIA was formed in 1978 when the Office of
Telecommunications Policy was transferred from the Executive Office of the President to
the NTIA. However, NTIA has recently decided to discontinue its bioeffects research
coordination function. Its Electromagnetic Radiation Management Advisory Council, as a
result, has been disbanded. The NTIA's spectrum policy, planning, and management
function under the Frequency Management Advisory Council, all basically contributing to
the DOC's fundamental mission to facilitate business, trade, commerce, and industrial
production, will continue. The Department of Defense has initiated a review of its own
exposure standards for RF/MW radiation. The American Conference of Governmental and
Industrial Hygienists is also reviewing its RF/MW exposure standard.
The Occupational Safety and Health Administration published occupational RF/MW
exposure standards until a recent decision to withdraw all such voluntary advisory
standards.3 The National Institute of Occupational Safety and Health has prepared a
criterion document on the occupational health effects of RF/MW that has not been made
public at this time.
In the international arena, the World Health Organization has published an RF/MW
health effects criteria document that contains population, occupational, and product
a This decision was reversed by OSHA in February 1984 at the request of the Federal
Communications Commission (Microwave News, IV(2), March, 1984).
10
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-------
standards, in addition to sections on implementation and further research needs. The
International Non-Ionizing Radiation Committee of the International Radiation Protection
Association has very recently published an occupational RF/MW exposure standard.
In the United States, the Technical Electronic Product Radiation Safety Standards
Committee of the National Center for Devices and Radiological Health of the Food and
Drug Administration is charged with recommending product emission standards for such
appliances as microwave ovens and industrial heat sealers.
CURRENT REGULATORY EFFORTS
The Federal Communications Commission (FCC) has overall responsibility for
licensing broadcast stations and maintaining acceptable broadcast/reception conditions
and standards of service and otherwise regulating the broadcast industry. The FCC
decided in 1979 that, under the National Environmental Policy Act (NEPA)7 of 1969, it
also had responsibility for public safety with regard to RF energy emanating from
broadcast sources it is responsible for regulating. To this end, the FCC issued a notice of
inquiry8 followed by an Advance Notice of Proposed Rule Making (ANPR)^ both of which
solicited comments on the FCC's proposal to issue standards limiting public exposure to
RF from regulated broadcast sources. The FCC has worked closely with the EPA,
particularly the ORP, which is responsible for EPA's ionizing and non-ionizing radiation
regulatory program. The EPA has also issued an ANPR10 on its intention, in concert with
the FCC, to publish a guideline limiting public exposure to RF/MW radiation. At the same
time, the ORP is preparing a preliminary draft of the Federal Guidance for public
exposure to RF to be implemented and administered by the various pertinent Federal
agencies. An interagency work group has reviewed the Draft Proposed Guidance.11
Further, the EPA's Office of Research and Development Health Effects Research
Laboratory has prepared a draft of a health effects criteria document.12 This draft has
been reviewed by a Scientific Advisory Board (SAB) panel and has been revised at the
direction of the SAB.
THE ELECTROMAGNETIC ENERGY ENVIRONMENT
Communications, entertainment, recreation, manufacturing, food processing,
medicine, defense, navigation, and space exploration have all benefited from advances in
the use of RF/MW over the past 40 years. The public is exposed to intermittent or
continuous RF/MW sources from a growing variety of sources: AM and FM radio and
television broadcasting stations; navigation and defense radar; land-mobile (citizens band,
12
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emergency services, telephone); hand-held transceivers; police traffic control radar;
point-to-point, earth-satellite, and deep space microwave communications; medical
diathermy; commercial and residential microwave ovens; and industrial RF/MW sealers
and heaters.
Radiowaves are electromagnetic energy consisting of coupled electric and magnetic
fields that oscillate at the same frequency as the source, from which they propagate
outward at the velocity of light in the medium through which the energy is moving. The
relationship between the frequency, f, and wavelength, X, for electromagnetic waves is
approximately as follows:
X = s/f, (1)
where
X = the wavelength in meters,
s = speed of light in air, meters per second, and
f = the frequency in Hertz or cycles per second.
The EM energy spectrum extends from zero to 1025 Hz and includes the electrical
frequency (low cycles per second), radiofrequency, optical frequency, and ionizing
frequency ranges. Radiofrequency and microwave radiation includes the spectrum from
3 kHz to 300 GHz, with wavelengths varying from 100,000 m to 1 mm. Microwaves are
defined as the portion including the spectrum between 300 MHz and 300 GHz, with
wavelengths from 1 m to 1 mm.
The RF environment includes fields from many sources and frequencies. However,
two frequency bands deliver the majority of the energy to which the public is exposed, the
AM radio band, 0.535 to 1.605 MHz, and the FM radio, VHP and UHF TV bands,
54-890 MHz. A report analyzing the radiofrequency radiation environment to which the
public is exposed and a discussion of the RF sources responsible has been prepared by the
EPA.13
RESEARCH ON BIOLOGICAL EFFECTS AND HEALTH RISKS OF
RADIOFREQUENCY/MICROWAVE RADIATION
Research on biological effects and health risks of RF/MW evidences long-standing,
widespread, and diverse concern over the possible consequences of exposure to RF/MW
radiation. This research dates from at least World War II when the U.S. Naval Research
Laboratory investigated the possible harmful effects of microwaves. In 1948, researchers
at the Mayo Clinic documented the first hazardous effect—cataracts in dogs used as
experimental subjects.1 ** Soviet researchers reported behavioral and subjective
13
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symptomatic effects at about the same time. In 1953, a Hughes Aircraft Company
engineer, John T. McLaughlin, documented an apparent pattern of disease among radar
workers. In reaction to this development, the Navy established a temporary exposure
standard for MW. In 1956, the Armed Services initiated a more rigorous research effort
known as the Tri-Services Program to establish a scientifically-based RF/MW standard.15
ANSI assumed responsibility for setting voluntary standards and has a scheduled review of
its standards every five years. Subsequently, a number of federal agencies became
interested in RF/MW from an occupational, public exposure, and product emission
standpoint. Currently, biological effects and health risk research is being monitored,
funded, coordinated, or conducted by several agencies, among them the Office of Naval
Research, the Air Force School of Aerospace Medicine, Center for Devices and
Radiological Health (Food and Drug Administration), the National Institute of
Environmental Health Sciences, the Environmental Protection Agency, the Department of
Energy, and the Naval Medical Research and Development Command (Naval Aerospace
Medical Research Laboratory).
Recently, the EPA evaluated the available scientific data in a report entitled
Biological Effects of Radiofrequency Radiation.12 Although there are over 5000 citations
in the literature of studies of RF radiation effects, reports were included in the document
only if they met certain minimum acceptance criteria and if they could be useful in
developing the basis for exposure guidelines by adequately identifying and quantifying the
biological and health effects.16
CONCERNS OF THE BROADCAST, COMMUNICATIONS, AND ELECTRONIC
EQUIPMENT INDUSTRIES
Industry concerns focus on growing public resistance to siting communication and
broadcast facilities in local communities. Industry is also concerned with having to
satisfy state and local RF/MW public exposure standards that may be established at
different levels that may be unnecessarily stringent because these agencies lack the
facilities or funds to conduct the necessary scientific studies on which to base carefully
designed standards. However, state and local officials feel compelled to respond to
constituencies that express a growing perception of health risk from RF/MW exposure.
Electronic equipment manufacturers are also concerned over product emission safety
standards, a subject which this economic study does not address.
Numerous companies and industrial organizations have urged the EPA and FCC to
adopt RF/MW standards in hopes of allaying public fears of perceived health risks. Among
these are the American Telephone and Telegraph Company, American Satellite Company,
-------
GTE Service Corporation, TV Broadcasters All-Industry Committee, National Association
of Broadcasters, Association for Broadcast Engineering Standards, Columbia Broadcasting
Systems, Motorola Corporation, American Radio Relay League (Amateur Radio
Organization), Doubleday Broadcasting, and even state and local officials who must
address citizen concerns over RF/MW exposure.17
The public's growing perception of the risk of health hazards from RF/MW is causing
increasing local opposition to the siting of communication and broadcast facilities,
according to a communications and electronics research/industry newsletter.18 This
opposition appears to have originated with the rejection of Home Box Office corporation's
application for a communications satellite (comsat) facility by Rockaway Township, New
Jersey. Subsequently, RCA Americom was denied permission to build a comsat facility on
both Bainbridge Island and in Indianola-Kingston (Kitsap County), Washington. The Port
Authorities for New York and New Jersey and Merrill Lynch Pierce Fenner and Smith are
proposing a teleport facility on Staten Island in the face of public opposition. Filmways
Communications has been denied permission to build a television broadcast station in
Onondaga, New York. U.S. Telecommunications Systems (an ITT subsidiary) was denied a
permit to build a microwave relay station in Coventry, Connecticut. World Christian
Broadcasting Corporation is facing severe opposition to its proposed shortwave station in
Anchor Point, Alaska. Vernon, New Jersey, denied RCA Americom permission to build a
microwave relay uplink station for its satellite communication center. Alascom
Corporation is facing opposition to a comsat facility on Vashon Island (King County),
Washington. ITT Corporation has been denied permission to build a point-to-point
microwave relay station in South Nyack, New York, and faces organized opposition to its
alternate site proposal for Ringwood, New Jersey. Group W Satellite Communications
Corporation is facing opposition organized by the Citizen's Action Group to a comsat
facility in Stamford, Connecticut. There has been long-standing opposition to the Navy's
installation of large antenna systems required by its submarine communication system
(known successively as Project Sanguine, Seafarer, and now, ELF) in Clam Lake,
Wisconsin, and K.I. Sawyer Air Force Base in Michigan. Recently, the Coast Guard faced
opposition to an OMEGA radar antenna facility in Hawaii. In addition, there is a growing
body of litigation concerning alleged health effects of exposure to RF/MW.
In response to public fears of perceived health hazards from RF/MW, a number of
state and local agencies have initiated studies and several are in the process of, or have
adopted, RF/MW public exposure standards. Among the latter are Multnoma County,
Oregon, the states of New Jersey, Conneticut, Wisconsin, Massahusetts, Texas, and
15
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Arizona, and the cities of Portland, Oregon and Onondaga, New York.19 Industry is
concerned about technical compliance with differing local standards involving an energy
medium that is difficult to control with respect to jurisdictional boundaries. Federal,
state, and local government agencies are concerned about enforcement difficulties in a
regulatory environment of multiple RF/MW public exposure standards.
The electronic equipment manufacturing industry is further concerned with the
growing volume of litigation dealing with alleged health effects from products including
microwave and radar antennas, microwave ovens, and video display terminals.
PURPOSE OF STANDARDS LIMITING PUBLIC EXPOSURE TO
RADIOFREQUENCY/MICROWAVE ENERGY
The EPA, observing the conjunction of numerous forces, including long-standing
scientific interest in the biological effects and health risks, increasing public perception
of health hazards, industry concern over siting, the desire for consistency among differing
local and state standards, and increasingly vocal opposition and litigation, is completing
research necessary to establish a standard limiting public exposure to RF/MW radiation.
The research is comprehensive in scope, including health effects, cost studies, field
measurements of the electromagnetic environment, signal propagation studies, and studies
of the efficacy of a wide variety of compliance measures, some of which have been
designed and modeled during the course of this research.
PROFILE OF BROADCAST FACILITIES
The broadcast industry is large and growing, as the following statistics reveal;20
total assets in 1980 were $5.5 billion, about 65% of which is in the TV industry. The total
industry employs about 126,000 people who earn an aggregate wage of $3.1 billion.
Industry gross revenues were about $12.0 billion (73% TV); net (after taxes) income was
$1.8 billion (92% TV). In the decade 1971-1981, the number of FM radio stations
increased by 47%, AM stations by 8% and TV stations by 11%. A general reason for this
growth is seen in a study of the number of trillion words transmitted by public media.21
This study tracked trends in the volume and cost of words transmitted by 17 media. More
words were transmitted by radio (AM and FM) and were the least costly of any of the
media. Radio and television grew in number of words transmitted and in reduction of cost
by about the same percentage over the period of 1960 to 1977; however radio continues to
16
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transmit about 3-1/2 times as many words (5.5 x 1017) as TV at one tenth the cost per
word ($3.0 x 10"9).a Of the voice communication media, as distinct from data
communication, CATV grew twice as fast in number of words produced over the same
period but transmits almost 20 times fewer words than TV at ten times the cost per word.
The physical facilities of an FM radio station vary but typically include a broadcast
studio/office, from which the program content is assembled for transmission (Fig. 5). The
broadcast antenna is often located on a tower at the studio site. If so, the broadcast
material is conveyed over wire directly to the transmitter, which provides the power to
the antenna. Power from the transmitter is usually conveyed to the antenna via a coaxial
transmission line and fed to each element of the antenna (called a bay) through an
electrical coupler or feed system that distributes and phases the signal for each bay. A
studio-transmitter-link is used to broadcast the program material to the
transmitter-antenna when the latter is remote from the broadcast studio.
Antenna signal patterns are routinely "tuned" or shaped to avoid interference with
another station's signal, to direct the signal to the greatest population, to fill in nulls or
poor reception areas, or to avoid broadcasting a signal to non-market areas, the ocean, for
example. The signal shaping is accomplished in different ways for AM, FM, and TV. The
factors for all three, though, involve the geometry of the element design, spacing, and
placement, tower design and geometry, and signal phase control.
A broadcast station is a complex interaction of several forces that together result in
the public image of a station that is dynamic, fluid, and curiously life-like as few other
organizations are. The owners/partners/ managers bring the entrepreneurial spirit to the
enterprise. Before the expansion of the FM car stereo market, this often flew in the face
of continual losses and required a dedication to a particular type of programming and
character of station, e.g., classical or jazz music.
The FM broadcast industry is undergoing a period of rapid change and expansion that
began about a decade ago, spurred by expanding FM audiences. The enormous increase in
FM listeners is the result of a conjunction of three trends. First, there have been
significant improvements in the quality of recording, transmitting, and receiving
equipment that have raised the standards and expectations of listeners for high quality
sound, particularly for music. Second, good FM receivers are now widely available as
standard equipment, dealer-installed option, or after-market installation for automobiles.
This brings job-holding commuters—key targets of radio advertising campaigns—into the
prime 6-9 a.m. listener period, greatly increasing the potential advertising revenue for FM
a 1972 dollars.
17
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MIC
Recorded
input
Other
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Hard-wired line
STL
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processing and antenna
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7
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Broadcast
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Broadcast
antenna
I I
Studio site
Transmitter site
Figure 5. The elements of a broadcast system are shown with the ultimate signal carried
from the transmitter via coaxial cable and broadcast from the antenna, which is insulated
from the tower. FM radio, VHF-TV and UHF-TV antenna systems are similar. AM
antenna systems differ in that the whole tower is used as a signal radiating element; the
tower is electrically grounded with a system of radial copper wires.
18
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radio stations. Third, FM programming, following the growth in audiences and advertising
revenues, has greatly diversified and expanded. FM stations air a wide variety of
programming and they also segment the listener market into increasingly smaller,
specialized fractions. One result of this growth is that the market price for FM stations
has jumped by as much as a factor of 10 in the past decade.
With the growth in the FM market and the tremendous surge in the cost of FM
stations, there is a greater emphasis on the balance sheet. In 1971, 35% of independent
FM stations reported a profit; in 1980, 50% were profitable.
The rapidly inflating market prices for FM stations, a function of the growth in FM
listenership, the increasing scarcity of good broadcasting sites in lucrative markets, and
tax laws have created a situation in which market appreciation and realization of income
taxed at lower rates, e.g., long term capital gains, assume dominant importance. This
accounts, partly, for the fact that 50% of independent FM stations tolerate operating
losses in the current economy.
A station's value is not solely a function of current earnings, market share, audience
size, or gross revenues. A major factor is potential earnings, which are primarily a
function of potential audience size and demographic description of the population in the
region. The area of dominant influence, usually larger than the FCC-defined market area,
is influenced by two factors: signal strength, and audience draw (determined chiefly by
the underlying demography of the potential audience and the programming). If the
potential audience is sufficiently large and has the appropriate demographic profile, a
station's market share can often be increased by changes in programming.
The programming function really establishes the character and image of the station
with listeners. Station images have become fairly standardized; the industry uses
commonly understood image or market categories such as easy listening, rock and roll,
country and western, soul, jazz, classical, talk, and top 40 to report sales and revenue
statistics, demographic and market trends. According to programming specialists, the
type of programming is probably the most significant determinant of the demographic
description of a station's listener audience.
The engineering people keep the station on the air and design or hire consultants to
design new equipment configurations. Engineers emphasize the importance of maintaining
maximum power to saturate the audience and keep the signal quality high. In fact, the
FCC requires stations to maintain a minimum signal strength of 60 dbu (1.0 mV/m) over
the broadcast coverage area and 70 dbu over the city of license.
19
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The marketing and sales staff sell advertising time, which is the sole source of
revenue for a station. Generally, radio advertising is a relatively inexpensive way to
reach a wide audience. However, the marketing people also like to emphasize a station's
power or height of antenna or size of market to attract advertisers. Stations generally
like to maintain a balance among the three sources of sales revenues: national, regional,
and local. Small stations tend to rely on national sales representatives and the size of
broadcast coverage area (area and population) rather than on ratings to sell national time.
The radio personalities convey the station image and character along with the
programming and can greatly influence listener audience share and advertising revenues.
Programs and radio personalities are continually rated by one of the audience sampling
services. The rating and audience share influence ad rates for a show, time segment or
station. Hence, the competition for high ratings and shares is intense, especially in
competitive radio markets such as Los Angeles, New York, and San Francisco.
Radio stations, with all of their dynamic elements, operate within the regulatory
framework maintained by the FCC. The FCC is generally responsible for assuring that
each station has an interference-free broadcast coverage area. This is accomplished by
regulating the effective radiated power (ERP), which is a function of transmitted power
and antenna gain; antenna height; and geographic separation from other stations.
Recently, the FCC has been affected by a general move in the federal government toward
deregulation of industries; as a consequence, there may be some deregulation of the
broadcast industry in the future.
When a station applies for its first license to broadcast or applies for a permit to
change its broadcast components, a wide variety of permits, each with its underlying
engineering study is necessary. These may include a mileage separation, field strength,
and population density study. The Federal Aviation Administration (FAA) requires a
permit and accompanying study for many tower installations. Many of these studies are
required as part of the compliance measures discussed further in this report. In addition,
local jurisdictions require studies supporting land use permit and zoning applications.
Other changes affecting the broadcast industry include the planned introduction of
AM stereo, cellular radio, high-definition television, and low-power television. These are
not expected to have any influence on the RF environment to which the public is exposed.
Television stations are more capital intensive than FM stations; expenses are higher
but the potential profits are very high, particularly in large metropolitan markets. The
series of photographs (Figs. 6-9) show studio and transmission facilities of FM radio and
20
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Figure 6. Material is broadcast live, prerecorded, or recorded live from
the field.
Figure 7. The signal is conveyed from the studio to a remote broadcast
tower via a microwave studio-transmitter link.
21
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Figure 8. The studio-transmitter signal is received by a microwave dish
antenna, converted to broadcast power at the transmitter, and fed to the
broadcast antenna via coaxial cable.
Figure 9. The coaxial cable feeds broadcast antennas on the tower (not
visible above the catwalk).
22
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television stations. Sutro tower, in San Francisco (Figs. 10-12), is a sophisticated system
serving a number of television and FM stations and private land-mobile systems. An AM
system is shown in Figs. 13-14.
AM radio station antennas typically have a configuration similar to that shown in
Fig. 13. These antenna systems do not lend themselves easily to modification as do FM
and TV antennas. Therefore, prohibiting public access by fencing the area near the
antenna that is exposed to RF over-standard was used as the compliance measure for
those AM stations that required some form of mitigation. Figure 14 shows a three-tower
AM antenna system.
FRAMEWORK FOR THE ECONOMIC STUDY
Cost-benefit analysis (CBA) dates from the 1844 publication of an essay, "On the
Measurement of the Utility of Public Works," by Jules Dupoit.22 Dupoit conceived the
notion of consumers' surplus, which is related to the concept of willingness to pay, and net
social benefit, cornerstone principles of CBA.
More recently, the United States Flood Control Act of 1936 required that benefits
of federal projects should exceed costs.23"24 Thereafter, most federal public works
agencies, notably the Corps of Engineers, used CBA to assess project worth throughout
the next 40 years. Since the 1960's, especially following the enactment of NEPA in 1969,
many statutes have been adopted that require some form of formalized decision making
that balance beneficial and adverse effects or financial and social impacts.25 During the
Ford Administration, two EOs were promulgated requiring some form of economic
balancing calculus.26 President Carter further formalized these requirements in
EO 12044,27 which defined the threshold size of federal projects requiring analysis and the
requirement for a regulatory analysis. This EO was supplanted by President Reagan in
EO 12291,28 which clearly identifies maximization of net social benefits as an objective
of regulation. The EO mandates a Regulatory Impact Analysis for every major rule,
defined as any regulation that is likely to result in:
1. an annual effect on the economy of $100 million or more;
2. a major increase in costs or prices for consumers, individual industries, federal,
state, or local government agencies...; or
3. significant adverse effects on competition, employment, investment,
productivity, innovation...29
23
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^mm
- -" ^vj^-^r^'---^
"- '^&?s-*& v^"!:"r- ^
Figure 10.
A sophisticated broadcast antenna system, such as this one in
San Francisco, accommodates a number of television and FM broadcasters and
land-mobile users.
The tower is 977 feet above a hill that is 834 feet
-------
b. Television transmitter and monitor
a. Microwave antenna.
c. Circularly-polarized antenna.
d. Batwing superturnstyle antenna.
Figure 11. The large tower system in San Francisco accommodates a variety
of antennas and includes sophisticated transmitter-monitoring systems.
-------
1*1-" ^
a. Traveling wave slotted antenna
(very top of mast).
c. Antennas protected by radomes.
b. Circularly-polarized antenna
(1/3 up left side of tower leg).
d. Circularly-polarized television
antennas.
Figure 12.
antennas.
The large tower system in San Francisco serves additional
26
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H
X 300 m (980 ft)
H
Figure 13. Typical AM antenna ground field (broadcast frequency = 1000 KHz).
27
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Figure 14. AM radio broadcast antennas are typically located in flat
terrain with good ground conductivity characteristics. Each tower is
grounded with a system of buried copper wires; the entire tower functions
as the broadcast antenna.
28
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Regulatory Impact Analyses are to contain the following information:
1. a description of the potential benefits of the rule...;
2. a description of the potential costs of the rule...;
3. a determination of the net benefits of the rule...;
4. a description of alternative approaches that could substantially achieve the
same regulatory goal at a lower cost...30
In response, the OMB issued a memo to federal agencies that reiterated the
substance of EO 12291 and ampilified portions of it, notably the definitions of
alternatives to be considered, costs, benefits, and net benefit.31
The EPA drafted an extensive regulatory impact analysis guide, which, together
with its four appendices, establishes the EPA's policy response to EO 12291.32 This guide
discusses in detail suggestions for documenting the need for the action; considering of
alternative actions; considering benefits, including health and non-health effects; costs to
society-at-large (opportunity costs of using resources for a selected purpose at the
exclusion of other purposes); and net benefits.
METHODOLOGY
The following is a description of the approach used in this study. The general
procedures, data bases, compliance measures and their selection, pre- and post-
compliance RF propagation models, social, industry, and individual firm models are
outlined. Figure 15 illustrates the relationships among the components of the method of
approach.
With reference to Fig. 15, EPA's ORP, as a result of research over the past
12 years, has developed models that estimate the RF in terms of electric field strength
and power density of the 10,000 AM and FM radio, VHF-TV and UHF-TV broadcast
stations in the U.S. The models use data developed by the EPA from FCC engineering
files, research results, and other sources to estimate the current RF environment
resulting from the broadcast activities of the stations. To facilitate efficient modeling of
the large number of FM radio stations, they were divided into groups with similar antenna
design and mounting characteristics. AM radio stations were divided into groups whose
antennas expose similar areas to a given intensity of RF. TV broadcast stations were
analyzed individually. Stations whose RF is estimated to exceed one of the 18 alternative
guidance levels studied are assigned the least costly compliance measure, selected from a
series of increasingly complex, costly and effective measures, developed as part of the
29
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research for this cost study, that will effect compliance. When a compliance measure is
estimated by the model to achieve compliance for a station or group of similar stations, it
becomes the basis for the cost input to the three cost models. The cost models produce a
variety of cost estimates for three kinds of economic analyses of each of the 18 guidance
levels studied using three levels of costs for compliance measures.
ENVIRONMENTAL PROTECTION AGENCY RADIOFREQUENCY
RADIATION RESEARCH
Over the past decade, the EPA has been conducting research to define the RF/MW
environment to which the public is exposed.33"39 This has been an extensive research
effort that provides the foundation for defining the current RF conditions and identifying
potential areas and sources of RF that further research might document as posing a health
risk. In the course of these investigations, the EPA has measured the RF field strengths
in almost 500 sites in the U.S. in a wide variety of environments and distances from
broadcast sources.1*0"1*2 These studies show that 99% of the urban population is exposed to
less than 1 yW/cm2 of RF (the lowest level considered in the cost study); the median
exposure is one-half percent of this small value.
Studies were also conducted of traffic control, ground and airborne radar systems.
Traffic radar broadcast systems studied produce less than 1 yW/cm2 at distances from the
units that people would normally be found. The maximum power density produced is
3.6 mW/cm2 at 9 cm (3.6 in) from the antenna.1*3
Air traffic control radar systems studied in the San Francisco Bay Area showed a
maximum exposure of 1.1 x 10~3 yW/cm2,1*1* indicating that this source is also below levels
being considered for the guideline. In another study, the power density of
aircraft-mounted radar systems was measured. Exposures of up to 10 mW/cm2 at 8 to
18 feet horizontally from the aircraft radar unit were measured1*5 (10 mW/cm2 is the 1966
ANSI C95.1 standard). However, commercial aircraft radar units are generally over
6 feet above the ground (the height of persons on the ground).
Another study was conducted of RF in and on the roofs of tall buildings in proximity
to broadcast antennas. Eight buildings were surveyed in five cities across the country.
No interior area was found to have an exposure greater than 100yW/cm2; several roof
locations,1*6 to which the public does not normally have access, were exposed to levels
between 100 and 200 yW/cm2. One roof location exposure was found to be 23GyW/cm2. It
was found that mylar film used as a solar reflector is very effective at attenuating RF
and could offer a low-cost means to reduce RF in buildings, if this were necessary.
30
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signal
gation
dels
i
Post-guideline
compliance
broadcast RF
environment
Social
cost
models
Industry
cost
models
Social
cost
analyses
Industry
cost
analyses
Average
firm cost
models
Average
firm cost
analyses
Figure 15. The general method of approach combines the output of data bases, physical
signal propagation models and the application of compliance measures to social, industry
and average firm cost models.
31
-------
The studies of exposure from radar and inside buildings, together with the extensive
studies of general population exposure to RF have lead the EPA to concentrate on
commercial broadcasting and, in particular, FM radio as the chief source of public
exposure to RF in the environment.
ENVIRONMENTAL PROTECTION AGENCY DATA BASE
The EPA has spent considerable time over the past three years assembling a
comprehensive data base on the most critical RF sources from a guidance viewpoint: AM
and FM radio and VHP- and UHF-TV stations. This data base identifies each station by
call letter, city and state, corporate name, address of studio, geocoordinate location of
the transmitter and antenna, and a description of broadcast engineering characteristics
such as ERP, antenna type, make and model, number of elements, gain, type of mounting,
height above average terrain (HAAT), height of antenna above ground, transmitter power,
and others. These data are the basis for the signal propagation modeling performed by the
EPA.
RADIOFREQUENCY RADIATION SOURCE GROUPS
There are approximately MOO FM, 4600 AM, and 1100 TV broadcast stations in the
United States. Each station represents a unique physical, topographic, equipment,
financial, corporate structure, market, and engineering situation. Antennas are of a
variety of configurations and design. They are mounted on a variety of towers, from
telephone poles to very tall self-supporting towers. Some towers are located on flat
terrain, some on mountain tops, some on building roofs. Most antennas are located alone
on a tower; however, some FM and TV antennas are co-located on the same tower. A few
FM antennas are designed so that several stations can broadcast simultaneously from a
single antenna.
The FCC recognizes three geographic zones with different technical requirements
and regulatory rules that accommodate the regional differences in physical and marketing
environments.
The FM stations were partitioned into four groups on the basis of gross similarity in
antenna mounting, which influences the power density pattern and technical solutions
available for complying with standards.
Of the 4400 FM broadcast stations, the EPA data base contained information on
about 3900. An adjustment was made in each group on the basis of the existing
distribution to reflect the actual number of stations. These were partitioned according to
the following antenna mounting methods.
32
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1. FM stations with antennas mounted alone on a tower (guyed or self-supporting)
whose base is on the ground (SFMT).
2. FM stations with antennas co-mounted with one or more other antennas on a
tower (guyed or self-supporting) whose base is on the ground (MFMT).
3. FM stations with antennas mounted alone on a mast or tower whose base is on a
building (SFMB).
4. FM stations with antennas co-mounted with one or more other antennas on a
mast or tower whose base is on a building (MFMB).
The SFMTs and MFMTs were analyzed without modification. However, except for
survey costs, the SFMBs and MFMBs were not included in the cost estimate for several
reasons. Antennas mounted on masts or towers on building roofs are generally in areas of
relatively high population density. However, the two major paths of public exposure to
high field strengths are very rare occurrences. The first path is the exposure of people on
the roof. Except in rare instances, the World Trade Center in New York, for instance, the
public does not have access to building tops on which antennas are mounted. The other
major public exposure path involving roof-mounted antennas is the exposure of people in
nearby buildings, particularly in situations in which the RF waves are transmitted
horizontally from an elevation identical to people in an adjacent building. Buildings
attenuate RF significantly and levels measured inside structures adjacent to FM broadcast
antennas are relatively low, typically below 50 y W/cm2 and are not known to exceed
lOOyW/cm2.1*6
Where there is an antenna on a roof top adjacent to a new building that is taller than
the antenna mast, exposure of occupants in the new building to the main signal beam is
possible. However, the presence of the new building significantly degrades the signal
coverage of the station's listener market. This is particularly true of FM because the
physical characteristics of FM waves cause them to reflect easily off obstructions.
Therefore, FM stations whose broadcast signals have been blocked by new construction
are strongly motivated to relocate their antennas, often to the roof of the new building.
If this location is not available, stations attempt to lease space on an existing tower or
build a new tower elsewhere. Recently, towers that have been shadowed by new buildings
have been moved to different locations in Houston where antennas were relocated from
One Shell Plaza to a tower. Antennas were moved from the Biscayne Bay Building in
Miami to a TV tower when a taller structure shadowed them. Therefore it is assumed for
this analysis that FM antennas mounted on masts or towers on rooftops will not require
modification to comply with RF guidelines.
33
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The EPA data base is complete with respect to all AM broadcast stations. There is
a basic similarity in the configuration of AM antenna systems, rendering only one
compliance measure appropriate. The AM stations were segmented according to the
distance from the tower that is exposed to RF exceeding the specified field strength level.
Television stations were analyzed individually because the prominent differences
among stations, such as the broadcast frequency band (VHP or UHF), ERP, and whether
the antenna is single- or co-mounted with other TV antennas on the same tower, all
influence the choice of technical measures for compliance with a guideline. Furthermore,
the fewer number of TV stations made individual analysis relatively easy to do.
ENVIRONMENTAL PROTECTION AGENCY BROADCAST SIGNAL
PROPAGATION MODELS
Over the past 5 years, the EPA has been developing and refining models of AM, FM,
VHF-TV and UHF-TV antenna wave propagation*7 from monopole and dipole
configurations of various sizes. These models calculate the horizontal and vertical
polarized components of the signal and grating lobe and compute exposure in V/m and
yW/cm2 at any height above ground and distance from the antenna.
The data in the EPA data base were used, together with antenna performance
characteristics, as input to model the strength of signals broadcast from every radio and
television station in the data base. The models have been calibrated by independent field
measurements at a variety of broadcast sources. The models identify stations that will
probably exceed various specified field strengths or power density levels. They also
estimate the distance from the tower that the values are exceeded.
RADIOFREQUENCY RADIATION GUIDELINES
Because the final values at which the guidance will be set were not known at the
time of this study, all cost analyses were performed for 18 different possible guidance
levels. This approach has the advantage of revealing the variations in cost as a function
of guidance level over a wide range of possible standard levels.
The AM radio RF guidance is presented in V/m, ranging from 10 V/m to 1,000 V/m;
the FM radio, VHF-TV and UHF-TV broadcast RF guidance is presented in yW/cm2,
ranging from 1 uW/cm2 to 10,000 uW/cm2. A frequency-dependent standard reflects the
approach used in existing radiofrequency standards in the United States and other
-------
countries. Figure 16 shows a shape and limiting values for a typical guidance level. Note
that the curve is flat from 30 MHz to 1 GHz. Many existing standards begin an upward
ramp at about 300 MHz similar to that shown in Fig. 17. EPA's proposed guidance may
also incorporate a ramp, but the exact shape was not established at the time of this
study. The shape which was chosen for this study represents the most conservative
approach which might be chosen by EPA. If a portion of the flat region which extends
from 30 MHz to 1 GHz were changed to a ramp shape, the resulting impact of the
guidance on UHF stations would be reduced from the values predicted in this analysis.
The limiting values of the 18 guidance levels for AM, FM, and TV frequencies are shown in
Table 4.
As mentioned earlier, the EPA is now considering three alternative guidance levels
structured differently from those used as the basis of the total cost estimates. However,
the results of the cost study can be used regardless of the shape of the guidance
proposed. The total cost of the guidance can be found by combining the cost of the
guidance level applicable for FM, VHF-TV and UHF-TV stations with the cost of the
guidance level applicable for AM stations. The range of guidance levels examined in this
report should permit combinations to cover whatever shape guidance is finally proposed.
The standard is assumed to apply anywhere on the ground to which the public would
normally have access. The public has access to broadcast studios, which are often located
very near the transmitting tower.
COMPLIANCE MEASURES RESEARCH
An extensive effort was made to identify technical means for RF sources to comply
with various guidance standard levels. The advice of consultants, the broadcast industry,
and equipment manufacturers was sought in an attempt to identify all practical solutions.
New concepts for compliance measures were identified and subjected to mathematical
modeling to test their efficacy. Some of these ideas have proved effective and some have
not. A discussion of all of the compliance measures and the group that was selected as
practical is given later in this report.
MODEL OF STATION SELECTION OF COMPLIANCE MEASURES
An estimate of the costs of a guidance requires some idea of the choice of
compliance measures broadcast sources will make in response to an RF standard. Stations
differ in the markets they operate in, their financial condition, the technical aspects of
35
-------
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500
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300 --
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MRGNETIC FIELD LIMIT 250 mR/m
100
80
70
60
50
40
30
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10
ELECTkIC FIELD LIMIT
1HU V/m
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to I
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115.2 mfl/m
43.4 V/m, 500 uW/cm^
10 kHz 100 kHz 1 MHz
10 MHz 100 MHz 1 GHz
F" requency
10 GHz 100 GHz
Figure 16. Limiting values of magnetic and electric field strength for a typical guidance
for AM, FM, VHF-TV and UHF-TV.
-------
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600
500
400 4-
300 --
250 --
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10
100
90
80
70
60
50
40
30 --
20 --
RM
MflGNETIC FIELD LIMIT 515.8 mR/m
ELECTRIC FIELD LIMIT 194.2 V/m
+H-
ID r
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ro
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5 1 .50 mR/m
19.40 V/m
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115.2 mR/m
43.40 V/m
10 kHz
100 kHz
1 MHz
10 MHz
100 MHz
1 GHz
10 GHz
100 GHz
Frequency
Figure J7. Limiting values of magnetic and electric field strength for another typical
guidance for AM, FM, VHF-TV and UHF-TV.
-------
Table 4. Limiting values of the 18 guidance levels for AM, FM, and TV frequencies.1*
Guidance
level
1
2
3
1
5
6
7
8
9
10
11
12
13
14
15
16
17
18
Limiting field strength
at AM frequencies
V/m
10.0
31.6
44.7
70.8
86.6
100.0
141.3
173.2
200.0
223.9
244.9
264.6
281.8
300.0
316.2
446.7
708.0
1,000.0
Limiting power densities
at FM and TV frequencies
uW/cm2
1
10
20
50
75
100
200
300
400
500
600
700
800
900
1,000
2,000
5,000
10,000
their broadcast systems and out-of-compliance situation, equipment changes
contemplated for other reasons that would minimize the real cost of compliance and the
quality and cost of equipment they can afford. Broadcast equipment varies greatly in
cost, and since all but one of the compliance measures involve installation of new
equipment, cost will be a primary selection criterion.
a A survey of selected FM radio broadcast stations to determine typical equipment
rollover schedules was conducted of a large sample of the FM radio stations.1* The results
were not available in time to be taken into consideration in the cost study, but generally,
approximately 20% of stations anticipate replacing their antennas within three years,
another 10%, within ten years and the remaining 30% do not expect to replace antennas.
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Ultimately, each station is assumed to require an engineering study to determine its
compliance with the RF guidance, should it be implemented.3 There are a variety of
technical solutions and the choice of the most suited for a particular station will be a
function of the factors mentioned above. It was not possible to design a detailed
engineering solution for each station that might exceed a particular standard; therefore,
the cost models were built on assumptions of compliance measure choice based on the
collective professional judgment of the researchers, EPA, broadcasters, and engineering
consultants. Generally it is assumed that stations will select the least expensive solution
that will achieve compliance.
ENVIRONMENTAL PROTECTION AGENCY COMPLIANCE
MEASURES EFFECT MODELS
Individual stations or groups of stations whose RF is estimated to exceed one of the
18 alternative guidance levels studied are assigned the least costly compliance measure,
selected in the EPA compliance model from the final list of increasingly complex,
effective and costly measures that will effect compliance. Every station was estimated
to achieve compliance at every standard level studied using one of the compliance
measures. The output of this modeling provides the engineering basis for estimating the
costs of compliance.
SOCIETY-AT-LARGE COST ESTIMATION MODELS
The input to the cost models is generated by the compliance measures effects
propagation models and cost data developed as part of the compliance measures research.
Normally, in a cost benefit analysis, extensive discussion is given to the choice of discount
rate used to calculate the present value of a stream of future costs or benefits. It is
assumed for the social cost analysis, however, that the costs for compliance with an RF
guidance would occur during the year in which compliance is mandated for a station. This
assumption is used because the purchase and installation of equipment necessitated by the
guidance can easily be accomplished in one year, and, although firms may elect to finance
the purchase of the equipment, the terms of payment and cost of borrowing are not
a This may not be necessary for all stations. The EPA is developing criteria that will
permit stations to conduct preliminary evaluations of the need for a more detailed
survey. The conservative assumption used in this analysis somewhat overstates the cost
of compliance, particularly at the higher, less stringent, guidance levels.
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considered in social cost accounting. Thus, there is no stream of costs. A minor
exception is a portion of the cost for one FM radio compliance measure that represents
the annual expense of leasing space on another broadcaster's tower. This is a continuing
cost that only amounts to one to two percent of the social cost; even though the discount
rate used for this fractional component, therefore, has virtually no impact on the
aggregate cost, the OMB-suggested rate of 10% was used. It is assumed that stations will
comply with the guidance in five equal groups or cohorts over a five year period, one
cohort complying in each of five successive years. Because it is assumed that each
station faces a once-only cost, the "cash flow" social cost of compliance associated with
each cohort complying in a particular year is a one-year undiscounted expenditure. But to
calculate the present value to society of the cost of the guidance for all five cohorts with
associated expenditures over a five-year period requires discounting the second through
the fifth cohort expenditures back to equivalence with the first. Costs to society
estimated by the model are presented in terms of gross total compliance cost, including
the cost of a survey for all stations and the cost of compliance measures for stations
requiring mitigation, annual "cash flow" (undiscounted) cost and total present (discounted)
value. The analyses were performed for 18 alternative guidance levels at three cost
levels.
INDUSTRY COST ESTIMATION MODELS
Inputs to the industry cost models include compliance measures effects model
results, compliance cost data, and income tax variables. The cost to industry analysis
differs from the social cost analysis in several ways. The industry cost analysis considers
the net-of-taxes cash flow cost of compliance with the guidance. Interest, the cost of
financing capital equipment purchases, is included as an expense. But interest,
depreciation, expenses, and the investment tax credit reduce tax liability. The cost of
compliance is thus shared between industry and the government in the form of tax credits
and deductions from taxable income. It is assumed for the industry cost analysis that
stations comply in five equal annual cohorts just as in the social cost analysis. However,
it is also assumed for the industry analysis that stations incur expenses in the first year
and over the subsequent five years of capital amortization. Therefore, the entire industry
cost stream is spread over 10 years as each succeeding cohort initiates compliance,
followed by five years' amoritization (refer to Appendix Tables D-2, E-2, or F-2 in
Volume 2). The industry present value of the cost of compliance is calculated by
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discounting the entire 10 year cost stream. Costs to industry estimated by the model are
presented in terms of projected actual and average annual cash flow costs and present
value. The output values are given for 18 guidance levels at three cost levels.
AVERAGE FIRM COST ESTIMATION MODELS
Input to the models of the three broadcast industry segments include compliance
measures effects models results, compliance cost data, income tax variables, and income
data on the broadcast industry. A more detailed examination of private sector effects of
the guidance was made by analyzing the costs in terms of the average AM, FM and TV
broadcast station. Models were developed that project pro forma income statements for
the average profitable and the average unprofitable FM, AM and TV broadcast stations. It
is assumed for the average firm analysis that the individual station faces first-year costs
and capital amortization expenses over the next five years. The present value cost for
the average firm is calculated by discounting the first year and five subsequent years.
The present value cost for the average firm in each of the five cohorts is calculated
separately; an average present value cost is derived by calculating the mean of the
present value for a firm in each of the five cohorts. Estimates are made of gross and
net-after-tax projected and average annual cash flow cost and the effect on taxable
income and present value of the net cost of compliance. An analysis is also presented of
the maximum and average annual percent reduction in profit (or increase in loss) of the
net-after-tax cost of compliance for the average FM, AM and TV broadcast firm. These
analyses are presented for 18 guidance levels at three cost-levels as an illustration of the
potential effect of a guideline on an individual firm.
SUMMATION COST MODELS
Results of the previous model analyses are used to estimate aggregate social and
industry costs of the guidance, the effect of compliance on the average broadcast station,
and the total number of broadcast stations requiring a compliance measure at any given
guidance level. The summation analyses are given for 18 guidance levels at three costs
levels.
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MEASURES TO COMPLY WITH RADIOFREQUENCY RADIATION GUIDELINES
During the course of this study much thought has been given to identifying ways in
which broadcasters could comply with an RF guideline, if it becomes necessary. Several
meetings were held with a number of consultants, equipment manufacturers, and station
engineers to identify as many solutions as possible. Two computer design studies were
funded as part of this study, the purposes of which were to analyze the efficacy of a
variety of bay spacings and groupings in reducing downward radiation.
This research indicates that practical and effective measures to mitigate unwanted
levels of RF to comply with a guidance are limited to variations of three actions: (1)
exclude or warn the public of areas exposed to RF over the standard, (2) use existing
antenna models or design new ones that produce less unwanted downward grating, or
side-lobe, radiation, or (3) raise the antenna to reduce the RF energy at ground level. All
three compliance measure approaches are applicable to FM radio; only exclusion of the
public is appropriate for AM radio; a combination of antenna design and increasing the
height of the antenna can be used for television broadcast systems.
The following discussion describes the major ideas considered for potential
compliance measures in terms of technical merit and practical acceptance.
REDUCE EFFECTIVE RADIATED POWER
Power density is proportional to the square of field strength; a station could,
technically, reduce its broadcast power and power density. Although few listeners in the
major reception area of a station would notice even a 50% reduction in ERP, outlying
listeners might. Furthermore, success in broadcasting is commonly thought to consist of
five elements: market, signal coverage, programming, advertising rates, and promotion.
Therefore, station managers and sales/marketing people would perceive such a reduction
as a significant loss from a sales viewpoint.
Even if a given station could cover the area of license with grade A reception with
lower ERP, its signal cannot be weaker than competing stations without affecting
comparative reception and, thus, listener reaction, ratings, and advertising rates. A
change in ERP, especially a significant one, can directly affect coverage, and indirectly,
market and advertising rates. The other mitigation measures merely affect operating or
capital budgets for a short period, but a reduction in ERP may affect revenues.
Therefore, broadcasters will do anything to avoid reducing ERP.
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Furthermore, the FCC requires stations to maintain a specified signal strength over
the broadcast coverage area and to maintain the licensed transmission power output to
within -10% to +5%, so a significant reduction in ERP is not feasible.
PROHIBIT PUBLIC ACCESS TO AREAS EXPOSED TO FIELD STRENGTHS EXCEEDING
THE STANDARD
This approach assumes a station will conduct an instrument survey of the field
strength transmitted by its antenna and then erect a barrier to exclude the public from
access to areas exposed to power densities above the standard. The FCC could accept
this solution as an absolute deterrent to public exposure to RF above the standard.
The configuration of AM transmitter-antenna systems differs from FM and TV
systems, whose antennas are electrically insulated from the towers they are hung on.
Transmission of energy occurs only through the physical antenna bays; the tower is merely
a means of raising the antenna above surrounding obstructions. However, the entire tower
is used to generate the signal in AM systems. AM tower-antenna systems are grounded
with an extensive series of radial copper lines buried about 6 inches beneath the surface.
Refer to Fig. 13 for an illustration of a generalized AM antenna system. AM stations own
or lease an area large enough for the ground-wire system. Many of these antenna
systems, which are usually located in undeveloped rural or industrial areas of low
pedestrian traffic, are completely fenced, often for other reasons, for example to control
cattle grazing. For this analysis, it is assumed that AM stations lease or own land
sufficient to exclude the public from the area exposed to RF over the standard level at
each guidance level.1* This compliance measure is the only one appropriate for AM radio
broadcast stations.
On the basis of the collective judgment of professional consulting engineers and
station personnel, assumptions were made about the number of AM stations whose towers
are already adequately protected from public access by fencing. Refer to Table 5 for the
percentage of stations assumed to be fenced and therefore need no additional fencing.
POST WARNING SIGNS IN AREAS EXPOSED TO EXCESS RF
The cost analysis was performed on the basis of positive compliance measures that
assure that the public will not be exposed to RF radiation above the guidance. However,
because many FM antennas are located in remote areas and are inaccessible to all but an
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Table 5. Percent of AM broadcast antennas assumed to be adequately fenced to meet RF
guideline.
Cost level Percent of stations
High [5%
Medium 33%
Low 50%
occasional passerby, a separate study was performed of the effect on the cost of
compliance of permitting such stations to post signs warning of the over-guidance RF
radiation.
A study of population proximal to a sample of SFMT FM antennas shows that a
significant portion are very remote from population concentrations. Using 1980 census
data and a commercially prepared geographical data base matching 1980 census tract, and
census enumeration districts (CED), which are geographical units of varying size
corresponding to about 400 population, the geographic location of a sample of FM
antennas was compared with the location of these geographical units. Table 6
summarizes the distance of the antenna samples from CEDs. The area surrounding the
antenna in which no CEDs (no apparent population) are found is calculated from the radial
distance from the antenna to the nearest CED.
It was arbitrarily assumed for the special analysis of the posting alternative that the
three most restrictive distance categories would serve as an estimate of the percentage
of FM stations that might be allowed to post warning signs as a means of compliance with
the RF guidance. Thus, for the low-cost special posting analysis it was assumed that, of
the FM stations, 22% could use this solution, the medium-cost analysis, 14%, and the
high-cost analysis, 9%. However, because there is considerable uncertainty at this stage
about the details of implementation, the primary cost analysis assumes posting warning
signs will not be permitted; only the special analysis of the posting alternative assumes
this inexpensive solution will be permitted and only the difference between the two
analyses is reported.
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Table 6. Proximity of a sample of single FM antennas mounted on ground-based towers to
Census Enumeration Districts (CED).
Percent of stations whose antennas are
no closer than 6 given distances from a CED
distance (km)
distance (mi)
area (rrmi2)
Percent of
stations
.5
.31
.30
81.0
1.0
.62
1.21
60.0
2.0
1.24
4.83
37.0
3.0
1.86
10.87
22.0
4.0
2.49
19.48
14.0
5.0
3.1
30.19
9.0
INSTALL SHIELD ON BUILDING-BASED ANTENNA TOWERS
FM antennas mounted on masts or towers located on building roofs to which the
public has access can expose the rooftop to relatively high field strengths. One solution is
to place a shield on the tower just under the antenna that would reflect the signal away
from the rooftop. However, successful design of this solution requires extensive
engineering studies that will vary with the situation. It is assumed that the number of
antennas on roofs to which the public has access is so small that they can be ignored in
the analysis.7 AM and TV antenna systems are not mounted on buildings.
INSTALL REFLECTIVE MATERIALS ON ADJACENT BUILDING WINDOWS
Where an FM antenna on a building-based tower beams the signal horizontally to
nearby buildings, the signal can be very effectively reduced by installing reflective mylar
material designed to reflect light and heat. This solution is not included in the cost
analysis because it is assumed that building-based antennas, in general, do not expose the
public to excessive field strengths.
45
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CHANGE THE POWER TO GAIN RELATIONSHIP
The ERP of a station is a function of the power transmitted and the signal
amplification (gain) of the antenna. FM and TV antennas, which are similar in design,
have more gain (greater multiplication of the signal) with more bays and less gain with
fewer bays. Low-gain antennas (fewer bays) tend to produce a large, bulbous main
radiation lobe pattern that places a higher intensity of RF in the vicinity immediately
beneath the antenna than does a high-gain antenna, which produces a more horizontal
beam that does not irradiate the immediate vicinity with as intense an energy level. (All
of the energy levels discussed here are low by current safety standards; the point being
emphasized here is the relative difference between low- and high-gain FM and TV
antennas.) One way to reduce near-field power density might be to redesign the antenna
to cast more energy farther from the tower where its intensity would be reduced (power
density is proportional to the inverse of the square of the distance; therefore, a beam of
RF energy that intercepts the ground at a distance from the antenna will result in weaker
power density than a similar beam intercepting the ground close to the antenna).
However, low-gain antennas are increasingly used, especially by FM stations
because: 1) they are effective in filling poor-reception areas in valleys below the antenna,
2) they reduce multi-path problems, 3) they improve mobile (auto) receiver reception, a
growing segment of the market, and 4) they can result in reduced phase distortion in the
transmitted signal. Because this concept would probably meet with a fair amount of
industry resistance, it was not pursued.
REPLACE EXISTING ANTENNA WITH A MORE EFFICIENT MODEL
Some FM and TV antennas have a more efficient radiating pattern than others. That
is, they concentrate more of the total energy in the main beam or lobe and less in side, or
grating lobes. Less efficient antennas have larger "losses" from the main beam into
grating lobes, which are often responsible for significant RF on the ground in the vicinity
of the antenna. If the existing antenna is of an inefficient type, it can be replaced with a
more efficient model, significantly reducing the downward radiation.
This solution may not be appropriate in situations where a station has purposely
designed an antenna to broadcast a large lobe to fill poor-reception areas in hilly terrain
or in other special-application situations. However, in general, this solution is quite
workable and has been used as a compliance measure for both FM and TV antennas.
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OPTIMIZE INTER-BAY SPACING OF THE ANTENNA ELEMENTS FOR
MINIMAL DOWNWARD RADIATION
FM and TV antennas are normally designed with the bays spaced one wavelength
apart for signal phasing and gain purposes. However, if the bays are physically spaced
between one wavelength and one-half wavelength apart and the phasing and feed system is
modified, adjacent bays tend to cancel out downward radiation while still producing
main-beam gain. There is some loss of gain in a less-than-full-wavelength-spaced system
compared to a full-wavelength-spaced system, but this can be overcome by adding a few
more bays.
The optimal inter-bay spacing would probably fall between one-half wavelength and
one wavelength. The optimal spacing for each antenna installation depends on a number
of factors such as the desired radiation pattern, antenna and tower configuration,
transmitter power-antenna gain relationship, and others. In general, the smaller the
inter-bay spacing, the greater the number of supplemental bays required to maintain the
original gain. Accurate engineering costing would require detailed knowledge of the new
antenna spacing, available only with a complete engineering study. However, determining
the radiation performance characteristics of FM and TV antennas, though complicated,
can be done by two basic methods: measurement and calculation.
Measurement
A full-size test antenna can be placed on an outdoor antenna pattern range and its
transmission characteristics measured. The quality of the range is the key to good
results. A good antenna pattern range approximates free space, i.e., it produces patterns
as if the test antenna were isolated from all of its surroundings (no appreciable reflections
from nearby structures or the earth under the antenna). Such ranges are expensive to
establish and generally do not exist.
Scale model measurements of an antenna also can provide radiation characteristics
but generally require expensive indoor antenna ranges (anechoic chambers).
-------
Calculation
In order to calculate antenna radiation patterns, one must know the amount of
current flowing on all metal parts of the antenna and its supporting and nearby
structures. For simple antennas (such as dipoles and loops), a method is employed
whereby the current shape is assumed. This method is seldom applicable to commercial
FM antennas because they are more complicated than dipoles and loops, primarily because
they contain support brackets and vertical feed line sections for which these simple
assumptions are inadequate.
One of the project consultants used a computer code developed by two researchers
at LLNL called Numerical Electromagnetic Code (NEC),1*9 which uses the Method of
Moments to calculate the currents on an antenna, regardless of the structure's
complexity. This technique can be used by an experienced antenna engineer who is
thoroughly knowledgeable in the theoretical limitations of the method to construct an
accurate numerical model of the antenna. The results of this kind of analysis have been
validated for a wide range of antenna types, which encompass FM structures, during the
past 10 years.
The assumption was made in this study that all new antennas with bays optimized
for minimal downward radiation would use half-wavelength spacing. This assumption
somewhat overstates the cost to industry for this compliance measure but introduces
some conservatism in the overall results.
Figure 18, plotted by NEC, shows a typical relationship between FM antenna gain
and number of elements for bays spaced one wavelength and one-half wavelength apart.
Of the antenna solutions, this is the most expensive because the old antenna must be
replaced and a new one assembled and tested at the manufacturing plant. A greater
number of elements is required. Further, the tower often must be analyzed for its
structural ability to handle the extra load the greater number of elements would entail.
Still, the solution is technically feasible and not prohibitively expensive in many cases. It
has been used as a compliance measure for FM and TV antennas in this study. When this
compliance measure is assumed to be employed, it is always with a new antenna of a more
efficient radiating pattern.
CREATE GROUPS OF ELEMENTS
Two computer modeling studies have been conducted to investigate the
effectiveness of this concept in reducing downward radiation for FM and TV antennas.50
Bays were divided into groups with intra-group spacing maintained at one wavelength and
-------
18
16 -
14 -
04
02
02
04
O Elements spaced one wavelength apart
• Elements spaced one-half wavelength apart
I
06
08 10
Elements
12
14 16
Figure 18. Typical FM antenna gain related to number of
elements: a comparison of half-wavelength with full-wavelength
spacing.
-------
inter-group spacing either half a wavelength or one-and-one half wavelengths. The
studies show that the experimental antenna configurations do not significantly reduce
near-field power density. Furthermore, antenna systems with such configurations would
have to undergo extensive development and testing by manufacturers. The resulting
antenna systems would be more costly than existing ones. Because this measure is
apparently minimally effective in reducing near-field power density and will be relatively
expensive, it would be impractical, and as a result it was not used in the cost analysis.
RAISE THE ANTENNA
The power density is inversely related to the square of the distance between the
source and subject, so raising the antenna to increase its distance from the ground is
effective in reducing power density from FM and TV antennas.
However, FM and TV broadcast antennas cannot be mounted on towers built to any
arbitrary height a station owner desires. Antennas must conform to a number of FCC
regulations, among them a relationship between HAAT and ERP. The relationship differs,
depending on the power class of the station, but in general, the taller the antenna in terms
of HAAT, the lower the ERP must be to regulate inter-station signal interference.
Furthermore, towers generally must conform to FAA regulations, which govern air space
obstructions. In addition, there may be height restrictions imposed by local city, county,
and township planning bodies. However, in most instances, replacement towers and
antennas could be designed to meet FCC, FAA, and local permit requirements.
Therefore, it is assumed that towers of the required height will be permitted. Where this
is not the case, it is almost certain that some other technical solution can be designed to
achieve compliance with the standard, probably at a cost no greater than the estimated
cost of a new tower.
Towers are of two types, guyed or self-supporting. In either case, they are built to a
given height with a calculated load-bearing capacity. It is not usually possible later to
add sections to the top of the tower to raise it because the structure has not been
designed to hold the added weight and because the guying has been designed with a given
horizontal and vertical geometry that cannot easily be changed. Therefore it is
necessary, in virtually every case, to build a new tower to raise an antenna, if lease space
cannot be found on an existing taller tower.
Where an antenna can be moved to an existing tower, often a self-supporting TV
tower is chosen, because they are so large that the relatively minor added load of an FM
50
-------
Antenna is usually able to be accommodated. However, very often a detailed
structural analysis is necessary to certify the tower's ability to handle the additional
load. Often the tower must be structurally reinforced.
The general solution involving raising the antenna has been incorporated into three
applications for FM antennas, leasing space on an existing tower, building a taller tower
on the existing site, and building a new tower on a new site. TV antennas are assumed to
be raised on new towers on the existing tower site. This solution is not appropriate for
AM antenna systems, which incorporate the entire tower (usually 1/4 wavelength tall) and
an extensive electrical ground system in the antenna system.
SUMMARY OF COMPLIANCE MEASURES FOR FM, AM,
AND TV BROADCAST STATIONS
Table 7 shows a summary of the compliance measures used in the analysis of FM,
AM, and TV stations. The compliance measures for FM are applied as shown in Table 4, in
order of increasing cost. This results, generally, in a minimum cost solution, although
there may be occasional non-minimum cost compliance measure selection because, for
example, some shorter guyed towers (measures 5,6) are less expensive than some complex
one-half wavelength antennas (measure 3). Each TV station was examined individually for
the minimum cost compliance measure. For TV antennas, compliance measures 2 and 3
are assumed to be combined to result in an antenna design of reduced downward
radiation. Compliance measure 5 is applied to TV with either the existing antenna or a
new antenna, depending on cost.
Because FM radio stations are the chief source of public exposure to RF radiation,
most of the effort in this study was focused on mitigation measures and costs pertaining
to the FM broadcast industry. A number of the compliance measures appropriate for FM
antennas may also be appropriate for TV antennas; these include posting warning signs
(not used with FM stations except in the special cost study) and building a new tower on a
new site. Mitigation for TV antennas includes one tower option, build a taller tower on
the existing site. Generally, TV antennas must be placed on the top of a tower;
frequently, a TV station or group of stations will build a tower, occupy the top and lease
antenna space lower down to FM stations. We assumed that most of the available
favorable locations for TV antennas are already occupied because the capital costs and
revenue requirements for TV stations required a good antenna location originally to
facilitate market coverage. We therefore assumed that the existing tower would be
replaced by a taller one in situations where compliance was estimated to be achieved only
by raising the TV antenna.
51
-------
Table 7. Compliance measures assumed available for FM, AM, and TV broadcast stations.
1.
2.
3.
4.
5.
6.
7.
Compliance FM
Post area over-guidance not allowed3
Replace existing antenna OK
with more efficient model
with standard 1 -wavelength
Replace existing antenna OK
with more efficient model
with bays spaced
1/2-wavelength apart
Lease on taller
existing tower OK
Build new tower on
existing site OK
Build new tower on
new site OK
Prohibit public access not
to area over-guidance applicable
AM
not allowed
not
applicable
not
applicable
not
applicable
not
applicable
not
applicable
OK
TV
not allowed
OK for both VHF-TV
and UHF-TV antennas
OK only for
VHF-TV antennas
not
applicable
OK
not
applicable
not applicable
a Costs reported assume FM stations will not be allowed to use this inexpensive
compliance measure, which does not positively reduce RF levels but warns passersby of
excess RF levels. A separate analysis was conducted of the effect on the overall cost of
permitting FM stations whose antennas met strictly defined criteria of "remoteness" from
population. The savings amounts to as much as 20% for the FM industry and as much as
&% for the entire broadcast industry at guidance level 1. The saving in using posting
warning signs declines dramatically at higher guidance levels.
It is also possible that both FM and TV broadcast stations could comply by
prohibiting public access to the area exposed to RF radiation that exceeds the guideline.
This is the one measure applied to AM stations because there are few alternatives and AM
stations generally control access to sufficient land to fence the over-standard area. The
owership or leasehold and surrounding land use situation is much less clear for FM and TV
stations. The additional factors of possible land purchase or lease costs involved in the
fence solution were too varied to include this option for FM and TV antennas.
52
-------
FM antennas that are raised on taller towers using compliance measures 4,5, or 6
are arbitrarily distributed among those three measures as shown in Table 8. One-third of
the stations with antennas co-mounted with one or more other antennas on towers whose
antennas are raised using compliance measure 5 or 6 are assumed to relocate with at least
one other station, reducing the cost of these measures for the MFMT by one-sixth (1/3 of
the MFMT stations x 1/2 the cost).
Many AM radio stations antennas are already protected by fencing for insurance
purposes or because they are located in pasture land or as a protection against vandalism.
The number of AM stations assumed to have adequately fenced antennas, and thus not
requiring a compliance measure, is shown in Table 5. It was assumed that the base of all
AM towers are fenced to a distance of 6 ft from the tower and, therefore, any tower
estimated to be emitting RF radiation in excess of a given guidance level out to a
distance of 6 ft was assumed to be in compliance.
Table 8. Distribution of compliance measures 4, 5, and 6 among single and multiple FM
stations requiring antennas mounted on taller towers (percent).
Fix 4
Lease on
another existing
tower
Fix 5
Build taller
tower on
existing site
Fix 6
Build taller
tower on
new site
Total
of
three
fixes
Low-cost analysis
12.5
75.0
12.5
100%
Medium-cost analysis
25.0
50.0
25.0
100%
High-cost analysis
37.5
25.0
37.5
100%
53
-------
COMPLIANCE MEASURE COSTS
All stations are assumed for purposes of the cost analysis to require a survey of the
electromagnetic environment to determine the need for compliance measures. The
survey, probably by a professional consulting engineering or station staff engineer, will be
used with a thorough analysis of the station's existing equipment to make decisions about
the compliance measure to use. Stations differ so much in equipment configuration,
location, market, competition, power requirements, land owned, local soils and
meteorological conditions (which influence tower costs), tower accessibility and financial
condition that it is not possible to apply a generalized engineering solution to a
calculated, rather than a field-measured, problem and accurately cost it. The range of
costs from low to high in the following discussion reflects these uncertainities.
The compliance measures applicable to FM stations are detailed in Table 9. The
cost of posting warning signs for antennas in remote areas is shown, although this
inexpensive measure is not included in the costs reported (see note b, Table 9).
The only positive compliance measure available to AM stations that may be
over-standard is fencing to exclude the public from exposure. The cost of fencing is
shown with an electromagnetic survey in Table 10.
The compliance measures available to TV stations include replacing the existing
antenna with a type that produces reduced downward energy, raising the existing antenna
on a taller tower, or building a new tower on a new site with a new antenna. The cost
components are shown in Table 11.
a This may not be necessary for all stations. The EPA is developing criteria that will
permit stations to conduct preliminary evaluation of the need for a more detailed survey.
The conservative assumption used in this analysis somewhat overstates the cost of
compliance, particularly at the higher, less stringent, guidance levels.
-------
Table 9. Costs3 of compliance measures for FM radio broadcast stations.51'
9.a. Survey of electromagnetic environment around antenna to determine compliance
with guideline and need for compliance measure:
Cost per station
Survey
Low
$1,500
Medium
$2,000
High
$2,500
9.b. Compliance measure 1. Post area
Percent of stations for which posting
assumed to be appropriate
Cost of signs
exposed to over-standard levels of RF.13
Low
22%
$2,000
Cost per station
Medium
14%
$2,000
High
9%
$2,000
9.c. Compliance measure 2. Replace existing FM antenna with new model having smaller
grating lobe.0'0*
Cost per station
Number of bays
1
2
3
4
5
6
7
8
9
10
11
12
13
14
16
Low
$ 1,750
3,500
5,300
7,000
8,800
11,400
13,200
15,000
16,700
18,500
20,200
22,000
26,000
27,900
31,700
Medium
$ 4,690
8,300
12,200
16,200
21,100
24,300
28,300
32,700
36,900
41,000
44,700
50,000
54,200
59,300
67,700
Highf
$ 6,650
11,500
16,725
22,300
27,700
32,850
38,350
44,500
50,275
56,050
60,960
65,870
73,060
80,250
91,720
55
-------
Table 9. (continued)
9.d. The number of half-wavelength spaced antenna elements required to produce the
same gain as single-wavelength spaced antenna elements.8
Number of antenna elements
Gain
dba
3.0
6.3
8.5
10.0
10.9
11.7
12.4
12.9
13.5
14.0
14.5
14.9
15.2
15.6
16.2
9.e. Compliance
One wavelength One-half
wavelength
spacing spacing
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
11.0
12.0
13.0
14.0
16.0
measure 3. Replace existing
1.0
3.4
5.4
7.5
9.4
11.3
13.1
15.0
16.9h
18.8n
20.6h
22.5n
24.4n
26.3n
30.0h
FM antenna
Ratio of
required elements
1.000
1.700
1.800
1.875
1.875
1.875
1.875
1.875
1.875
1.875
1.875
1.875
1.875
1.875
1.875
with new antenna whose
elements are spaced A/2 apart.0'*3'1
Cost per station
Number of bays
1
2
3
4
5
6
7
8
9
10
11
12
13
14
16
Low
$ 1,750
5,950
9,540
13,125
16,500
21,375
24,750
28,125
31,325
34,700
37,875
41,250
48,750
52,325
59,450
Medium
$ 4,690
14,110
21,960
30,375
39,550
45,575
53,075
61,325
69,200
76,875
83,825
93,750
101,625
111,200
126,950
Highf
$ 6,650
19,550
30,105
41,813
51,950
61,600
71,900
83,450
94,275
105,100
114,300
123,500
137,000
150,475
171,975
56
-------
Table 9. (continued)
9.f. Compliance measure 4. Lease space for an FM radio broadcast antenna on another,
existing tower.
Cost per station
Equipment!
Lease
TOTAL
Low
$17,000
29,750k
$46,750
Medium High
$23,000 $27,000
59.5001 89,250m
$82,500 $116,250
9.g. Compliance measure 5. Build taller tower on same site as existing tower.n»°>P
Cost per station
Height (<} of new tower (ft)
50
75
100
125
150
175
200
250
300
350
400
500
Low^
$14,100
15,700
17,300
19,600
21,900
24,100
26,500
30,500
36,100
46,700
54,000
81,800
Medium
$24,500
26,800
29,200
32,600
36,000
39,200
42,800
48,700
56,900
72,600
83,400
105,900
Highr
$ 32,800
35,900
39,000
43,500
48,000
52,300
57,000
64,800
75,700
96,500
110,700
130,000
9.h. Compliance measure 6. Building new tower on new site.n»°»P
Cost per station
Height (<) of new tower (ft) Low"
100 $60,000
150 62,500
200 65,000
250 67,500
300 70,000
350 75,000
400 80,000
500 95,000
Medium
$117,500
120,750
124,500
128,250
132,000
140,000
151,000
180,000
High"
$175,000
179,000
184,000
189,000
194,000
205,000
222,000
265,000
57
-------
Table 9. (concluded)
Notes for Table 9.
aCosts, in 1983 dollars, are for a series of alternative compliance measure options
available to an individual FM radio station. The three cost levels reflect variations in
equipment configuration, installation conditions, transportation, broadcast conditions and
other factors too numerous and station-specific to address for each individual station.
b This compliance measure was analyzed only for its effect on the overall cost of
compliance. The results reported in this study assume that posting will not be permitted
as a positive compliance measure.
c Side-mounted, circularly-polarized FM broadcast antennas.
d Does not include panel antennas. Prices vary widely depending on the quality of
antenna, power rating, how the power is fed to the elements and whether or not the
antenna is equipped with deicing or radome all-weather protection excludes low cost
"educational" models developed for low power educational stations.
e Does not include deicers.
f Includes deicers.
§ Source: plots in Figure 18.
h Projections beyond lower curve in Figure 18.
i Costs for single-wavelength-spaced antennas in Table 9.c are adjusted by the ratio
shown in Table 9.d.
J Costs assume half the stations use their existing antennas. Therefore, the costs (low,
medium, high) for a 3-bay A/2 wave antenna shown in Table 9.e are multiplied by 0.50, to
which is added $12,000 for structural analysis and certification. One third of the multiple
FM stations are assumed to share an antenna with another station; therefore, in the cost
models, the cost shown is multiplied by the factor (1 - (1/3 * 1/2)) for MFM stations.
k Assumes annual lease payments of $3,000, discounted over 50 years at 10.0%.
1 Assumes annual lease payments of $6,000, discounted over 50 years at 10.0%.
m Assumes annual lease payments of $9,000, discounted over 50 years at 10.0%.
n Tower costs vary widely and depend on site location, size and accessibility, shipping
distance and mode, soil load bearing capability, wind and ice loading, height, whether
guyed or self-supporting, transmission line used, aviation lighting, local building code
requirements and the installation of elevators. Normal transport and installation of tower
and antenna are included. Transmitter-associated hardware and some transmission line
are excluded.
° Assumptions regarding distribution of antennas among compliance measures ^, 5, and 6
(all basically involve relocating the antenna to a taller tower) can be found in Table 8.
P In the cost models, it is assumed that half the stations use their existing antennas. The
other half are assumed to use a 3-bay A/2 wave antenna, the costs for which are multiplied
by 0.50 (see Table 9.e) and added to the cost of the tower. One third of the multiple FM
stations are assumed to share an antenna and tower with another station; therefore, in the
cost models, the cost shown is multiplied by the factor (1 - (1/3 * 1/2)) for MFM stations.
3 Includes new tower shipped, installed, painted and with power; new transmission line,
FCC and FAA application and building permits.
r Includes new tower shipped, installed, painted and with power; new transmission line,
site improvements, studio-transmitter link, remote control system, FCC performance
testing, FCC and FAA application and building permits.
58
-------
Table 10. Costs of compliance measures for AM radio broadcast stations.
lO.a. Survey of electromagnetic environment around tower to determine compliance with
guideline and need for compliance measure.51 "^
Cost per station
Low Medium High
Survey $1,500 $2,000 $2,500
JO.b. Compliance measure applicable to AM: fencing to positively keep the public out of
areas exposed to over-standard levels of RF.55
Cost per station
Low Medium High
Fencing per foot $ 6 $ 9 $ 12
Gate 400 600 800
SOCIETY-AT-LARGE COST MODEL
This model is shown schematically in Fig. 19. The analysis begins with the EPA data
base, which provides some of the input to the signal propagation models. The EPA
propagation models estimate the signal strength or power density of each broadcast
station. These are then analyzed with respect to the 18 alternative guidance levels. The
EPA models sort through the appropriate compliance measures (Table 4), applying them in
sequence. If, to meet a given guidance level, the first applicable measure is not sufficient
to reduce a station's power density, the program selects and tests the next measure, and
so on. The result is that each station is estimated to be in compliance with each of the
18 guidance levels by the application of at least one compliance measure.
The social cost model takes these data as input, costs the chosen measure for each
station, adds the cost of the electromagentic survey and calculates the component and
gross cost, annual "cash flow" (undiscounted) cost and the present (discounted) value of
the total cost of compliance for each of the 18 guidance levels analyzed using three cost
levels. As is typical with large projects, virtually all the costs occur when compliance is
required. Benefits would occur over a long period of time.
To compare current year dollar expenditures with future year expenses and benefits,
all dollar values are brought into equivalence by discounting future values to the year of
analysis. The fundamental problem with comparing unadjusted dollar values from
different years is that current year dollars are more valuable than future dollars. If given
a choice, the prudent decision-maker will always prefer to receive a sum of dollars
59
-------
Table 11. Costs of compliance measures for TV broadcast stations.51-5lf
11.a. Survey of electromagnetic environment around tower to determine compliance with
guideline and need for compliance measure.51 ~sk
Cost per station
Survey
Low
$1,500
Medium
$2,000
High
$2,500
ll.b. New Antenna3
VHF-TVb
UHF-TV
Cost per station
Low Medium High
$240,000 $480,000 $960,000
150,000 300,000 600,000
ll.c. Tower replacement.
Cost per station
Height of new tower (ft)
lOQe
200
300
400
500
600f
700
800
900
1000
2000
Low
$ 57,000
120,000
174,000
262,500
360,000
270,000
307,500
343,500
396,750
483,750
1,875,000
Medium
$ 76,000
160,000
232,000
350,000
480,000
360,000
410,000
450,000
529,000
645,000
2,500,000
High
$ 83,600
176,000
255,000
385,000
528,000
396,000
451,000
503,800
581,900
709,500
2,750,000
a Installed.
b Custom design doubles the cost of these antennas over the normal cost. VHP antennas
are amenable to design change, UHF's are not.
c Tower costs vary widely and depend on site location, size and accessibility, shipping
distance and mode, soil load bearing capability, and wind and ice loading, height, whether
guyed or self-supporting, transmission line used, aviation lighting, local building code
requirements and the installation of elevators. Normal transport and installation of tower
and antenna are included. Transmitter, associated hardware, and some transmission line
excluded. These costs assume replacement of an existing tower on the same site; no major
site preparation except required tower footings is included.
d Includes new tower installed, painted and with power; new transmission line,
transportation, FCC and FAA application and building permits.
e Self-supporting towers.
* Guyed towers.
60
-------
< Begin ^\
analysis J
EPA AM, FM,
and TV station
data bases
Cost of
survey for
all broadcast
stations
Compliance
measures
EPA signal
propagation
models
Number of stations
exceeding specified
guidance level
pre- and post-
compliance measure
Cost of
compliance
measures
selected
CIS guidance A
levels Y
• Component cost
• Annual cash flow cost
• Present value
Repeat
analysis
Figure 19. The society-at-large cost model estimates the cost to society of guidance
limiting public exposure to RF; the model calculates the component and gross total
compliance cost, annual "cash flow" cost and total present value of 18 alternate guidance
levels at three cost levels.
61
-------
immediately rather than the same face value in the future because the dollars received
now can be invested or loaned and the value thereby increased. Discounting adjusts the
stated current year dollar values so that an equitable comparison can be made exclusive
of this consideration.
The basic formula for discounting to obtain the present worth for a uniform annual
value is given by:
or for a varying annual value,
n
PV= £ A(l + i) , (3)
k=l
where
PV = net present value,
A = annual value,
i = discount rate,
n = total years of analysis, and
k = individual year of analysis.
The fundamentals of time value, equivalence and comparison of money values can be
found in a number of texts.51"61*
In the present cost analysis, only the lease portion of compliance measure k,
applicable to FM radio stations, occurs over a period of time. This cost was discounted
over 50 years (equivalent to the life of a tower) at 10.0%, the rate suggested by OMB for
this kind of analysis. Inflation can be ignored and costs and benefits valued in constant
year dollars if the discount rate takes this into account.65"66
The costs are calculated first in terms of the gross component costs for the survey
and the compliance measures required. The total of these two divided by five yields the
annual "cash flow" cost under the assumption that compliance for the industry would be
spread over five years among equal-sized groups or cohorts of stations. This assumption is
a way of representing the time that may be involved in surveying for compliance, hiring
an engineering firm, determining the appropriate solution, designing the changes,
manufacturing the equipment, especially innovative antennas, and installing and certifying
the new equipment. Stations will be affected differently by this sequence of steps to
compliance, depending on the type of change necessary, complexity of overall broadcast
equipment, and availability of engineering services and the necessary equipment.
62
-------
The total gross cost to society of the guideline limiting public exposure to RF from
AM, FM and TV broadcast is given by:
TGC = TCS + TCC , (3)
where
TGC = total gross cost of compliance,
TCS = total gross cost of survey for ail stations, and
TCC = total cost of compliance measures required.
The annual "cash flow" cost (ACF) of compliance for a given cohort is given by:
ACF = TGC/5 , (4)
The present value (PV) of the cost to society-at-large of the guidance is given by:
PV= £'ACF (1.10)'k"1*, (5)
k=l
where
PV = the social cost present value, and
ACF = the annual "cash flow" cost of compliance.
These social costs can be incorporated into a full cost-benefit analysis with the
appropriate definition and valuation of benefits. Refer to Appendices A, B, and C for
detailed explanations and examples of these calculations.
INDUSTRY COST MODEL
It is of interest to estimate the actual effect of the guidance on the broadcast
industry, taking into account the cost of borrowing money for the required capital
improvements, the effect on corporate taxes, and the net impact on annual cash flow.
Reference to Fig. 20 will show that the industry cost model is the same as the social
cost model through the calculation of the total cost of all compliance measures required
for stations exceeding a specified guidance level. From this point, the costs are
segregated according to net cash flow and tax impact, in accordance with standard
techniques of evaluating projects in a business decision-making context.67"70 Finally, the
net cost of the project is determined from the cash flow and tax benefit estimates.
63
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< Begin ^V
analysis J
EPA AM, FM,
and TV station
data bases
Cost of
survey for
all broadcast
stations
Compliance
measures
EPA signal
propagation
models
Number of stations
exceeding specified
guidance level
pre- and post-
compliance measure
Cost of
compliance
measures
selected
CIS guidance \_
levels J"
Annual and average
net cash flow cost
Present value
Repeat
analysis
Figure 20. The industry cost model estimates the cost to the broadcast industry of
guidance limiting public exposure to RF radiation; the model calculates the annual and
average net cash flow and total present value of the cost of compliance of 18 alternative
guidance levels at three cost levels.
-------
The present value analysis and the cost of capital are both computed using 10% as
the rate, as directed by the EPA. Interest increases the gross expense of the compliance
measure but is deductible from gross income and has an effect on the taxes owed.
Tangible property is segregated from intangible expenses because they are treated
differently for tax purposes. Tangible property is subject to depreciation and investment
tax credit; intangible costs are subtracted from pre-tax profit ("expensed"), generally in
the year of occurrence. In this analysis, the lease portion of compliance measure 4 for
FM stations and the survey are considered intangible costs and are expensed. For each
cohort of stations, the gross annual cash flow cost of compliance with an RF standard
consists of:
GCF(k) = TCS(k) + DP(k) + LSE(k) + AM(k) + IN(k) , (6)
where
GCF = gross cash flow cost,
LSE = lease costs,
DP = down payment,
AM = annual loan amortization payments,
IN = interest on loan,
TCS = total cost of a survey, and
k = year of cost.
The reduction in tax or tax shelter, is given by
TS(k) = TR • EX(k) + TR • DPN(k) + TR • IN(k) + ITC(k), (7)
where
TS = tax shelter,
TR = the marginal tax rate applicable to corporate income above $100,000, OA6,
EX = expensed costs (TCS, LSE),
DPN = depreciation of tangible assets,
I = interest,
ITC = investment tax credit (assumed to be [0%), and
k = year of analysis.
65
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The net annual cash flow cost of compliance for the industry is determined by the
following:
NCF(k) = GCF(k) - TS(k), (8)
where
NCF = net cash flow cost of compliance,
GCF = gross cash flow cost,
TS = tax shelter, and
k = year of analysis.
The NCF for the five cohorts is calculated by dividing the total cash flow cost for
the industry by 5:
CNCF(k) = NCF(k)/5 , (9)
where
CNCF(k) = the cohort net cash flow cost in year k.
The net cash flow cost of compliance for each of the five cohorts of stations is
spread out over six years with each succeeding cohort beginning its six-year expense one
year after the preceeding one. Thus, total industry costs are spread over 10 years
(5 cohorts of stations, each with expenditures over 6 years). The guidance for each
cohort is assumed to be implemented in year zero, during which the electromagnetic
survey is conducted, the equipment ordered, down payment (25%) made and investment
tax credit taken. During the subsequent five years, the loan is amortized (equal annual
principal reductions in accordance with typical commercial line of credit terms), interest
paid (annually) and deducted, and depreciation is taken in accordance with the federal tax
code accelerated capital recovery system,71 in contrast to the social cost analysis, which
assumes each cohort incurs its costs in one year. The CNCFs are staggered in relation to
the following cohort's CNCFs. Therefore, their sum in years k=l is CNCF (k=l) for the
first cohort; the sum of the second year is CNCF (k=2) for cohort 1 plus CNCF (k=l) for
cohort 2 and so on. The yearly sums are denoted TNCF(k).
An average NCF is derived as follows:
10
ANCF = Z TNCF(k)/10, (10)
k=l
where
ANCF = average annual net cash flow cost.
66
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The industry present value is calculated by discounting the entire ten-year cost stream at
10%, as directed by the EPA, as follows:
10
PV= TNCFM/d.lO)" . (11)
k=l
Refer to Appendices A, B, and C for detailed explanations and examples of these
calculations.
AVERAGE FIRM COST MODEL
A more specific analysis was conducted to estimate the effects of the guideline on
the average AM, FM, or TV broadcast firm. The individual firm cost model is shown in
Fig. 21. It is identical to the social and industry cost models through the calculation of
the total cost of all compliance measures required for stations exceeding the specified
power density level. From these total industry-wide costs, the average cost for an
individual AM, FM, or TV broadcast firm is calculated. The average pre-tax operating
profit for profitable AM, FM, and TV broadcast firms72 was used to create a pro forma
profit and loss statement for an average firm in each of the three sectors of the broadcast
industry. The additional expenses of compliance are subtracted from gross income; net
income is then a function of the tax credit and depreciation, which is substituted for
amortization for tax purposes. The analysis assumes that operating profit remains stable
throughout the period of analysis, a year "zero" during which the guidance is implemented
and five years of loan payments. The impact of compliance on net (after tax) income in
years zero to 5 is compared with the assumed net income prior to implementation of the
guideline. The financial and ownership structure and tax situation of individual firms are
not known; therefore it was assumed that the profit calculated is taxed according to the
current corporate tax rate schedule.73 The costs of compliance for each of the three
segments of the industry are averaged over the number of stations requiring a compliance
measure at each of the 18 guidance levels analyzed to provide average costs for this
analysis.
The effect of compliance with the RF guidance on the average AM, FM, or TV
station net profit is estimated in a series of calculations beginning with the gross pre-tax
cash flow cost, as follows:
67
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f Begin
~*"\ analysis
EPA AM, FM,
and TV station
data bases
Cost of
survey for
all broadcast
stations
Compliance
measures
EPA signal
propagation
models
Number of stations
exceeding specified
guidance level
pre- and post-
compliance measure
Cost of
compliance
measures
selected
CIS guidance \_
levels J
Annual gross cash flow cost
Annual tax shelter
Annual and average net cost
Cohort and average
present value
Repeat
analysis
Figure 21. The average broadcast firm model estimates the cost to the average station of
a guideline limiting public exposure to RF radiation; the model takes into account the tax
effects and calculates the net after tax profit, the annual gross and net cost and the
present value of the cost of compliance with 18 alternative guidance levels at three cost
levels.
68
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AOIA(k) = AOIB(k) - AGCF(k), (12)
where
AOIA = average (AM, FM, or TV) firm pre-tax operating income net of average
gross cash flow compliance costs,
AOIB = average (AM, FM, or TV) firm pre-tax operating income as reported in
Ref. 72,
AGCF = the average cost of compliance for an individual AM, FM, or TV firm (GCF
T total number of [AM, FM, or TV] stations requiring a compliance measure
at each power density level), and
k = year of analysis.
Expensed costs, interest (both of which are included in AGCF, above) and
depreciation affect the computation of corporate income tax liability as follows:
ATOI(k) = AOIA(k) + ADP(k) + AAM(k) - ADPN(k), (13)
where
ATOI = average taxable operating income,
AOIA = average firm pre-tax operating income net of average gross cash flow
compliance costs,
ADP = average down payment,
AAM = average loan amortization,
ADPN = average depreciation allowance, and
k = year of analysis.
The gross tax liability is calculated using the corporation tax rate schedule found in
Ref. 73.
The net tax liability and net profit are calculated as follows:
ANIA(k) = AOIA(k) - ANT(k) ,
where
ANIA = average net firm after-tax profit,
AOIA = average firm income after compliance and before taxes,
ANT = average net taxes = ACT - AITC,
k = year of analysis, and
69
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where
ACT = average gross tax, and
AITC = average investment tax credit (10% of tangible capital investment),
taken in the year of purchase (assumed to be first year of
compliance).
The net after tax cash flow cost of compliance for the average broadcast firm is
given by:
NCC(k) = AGCF(k) - ATSA(k) , (15)
where
NCC = net cost of compliance,
AGCF = average gross cash flow cost of compliance,
ATSA = average tax savings, (ANTB - ANT(k)),
where
ATSB = average net taxes in the year prior to the guideline,
ANT(k) = average net tax in year k, and
k = year of analysis.
The average net cost of compliance is calculated from the annual net cost as follows:
6
ANCC = Z) NCC(k)/6 . (16)
k=l
The present value cost for the average firm is calculated by discounting the first
year and five subsequent years. Each cohort's present value cost is calculated
separately. Because there are five cohorts, each realizing costs in succeeding years, the
PV of a firm in the last cohort will be substantially less than the PV of a firm in the first
cohort. The present value for a firm in each cohort is calculated as follows:
PV(c)= E NCC(k)/(l.l) k"2+c, (17)
5
E
k=l
where
PV(c) = the present value of the cost of compliance for the average firm in
cohort c,
70
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i = cohort 1, 2, 3, 4, or 5,
k = year of expenditure for the average firm, and
NCC(k) = annual net cost of compliance in year k.
An average present value cost is derived by calculating the mean of the present value for
the five cohorts.
5
APV = Z PV(c) /5 . (18)
c=l
A separate analysis was completed of the impact of compliance on the average
unprofitable broadcast firm. The results, given the generalized assumptions made for this
analysis, are similar to profit-making firms in terms of net cost of compliance. The
expenditures for compliance do not, of course, help unprofitable firms improve their
income statements.
An analysis was completed of the maximum and average effect of compliance with
the guidance on net profit in terms of percent decline in profit (profitable stations) or
percent increase in loss (unprofitable stations) as follows:
MPE = MNCC/ANPB , (19)
where
MPE = the maximum annual percent effect on net profit or loss,
MNCC= the maximum annual net cost of compliance, and
ANPB = the average net profit or loss in the year prior to compliance.
A similar analysis was completed of the average, as opposed to the maximum effect
on profit or loss as follows:
APE = ANCC/ANPB , (20)
where
APE = the average annual percent effect on net profit or loss,
ANCC = the average annual net cost of compliance for the average firm, and
ANPB = the average net profit or loss in the year prior to compliance.
A separate program aggregates the AM, FM, and TV industry segment results for the
social cost and industry cost analysis to create industry-wide results.
71
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SUMMARY OF ASSUMPTIONS
Throughout the preceeding discussion of method of approach, compliance measures
and cost models, a series of assumptions were used. These are assembled below for
convenient reference.
GENERAL ASSUMPTIONS
1. AM, FM, and TV stations will select compliance measures in the order of increasing
cost used in this analysis.
2. The propagation models, calibrated by a field test program by the EPA, accurately
estimate power density propagation; no adjustments need be made for any known
biases in these models.
3. For the social cost analysis, all expenses for each cohort of stations are assumed to
occur in the year of implementation.
4. For the industry cost and average firm cost analyses, the year of implementation of
a guideline is known as "year zero;" expenses are spread out over the following five
years. The financial effects of compliance on the average firm are compared with a
base year immediately prior to year zero.
5. For all analyses, stations are assumed to comply in five equal annual cohorts.
6. Positive compliance measures are assumed (those that physically prevent public
access to RF over the standard). However, the effect of allowing FM stations with
remotely located antennas to post warning signs, an inexpensive measure, was
analyzed for its effect in reducing the cost of the guideline. For this special
analysis, it was assumed that 22%, 14% and 9% of FM stations could post signs for
the low, medium and high cost analyses, respectively.
7. All stations are assumed to require a survey of the electromagnetic environment
around their towers, whether a compliance measure is needed or not. This
assumption may not actually be necessary to implement a guidance because the EPA
may be able to devise a self-screening procedure that stations can use to determine
on a first-cut basis whether or not a more detailed survey is needed.
8. For the industry and firm cost models:
a) Capital equipment is purchased at 25% down with 5 annual equal payments, and
b) Interest is assumed to be 10% as directed by the EPA.
9. A common discount rate of 10% was used in all analyses.
72
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10. For the industry analysis, the tax shelter aspects of the calculations use the top
corporate tax rate, 46%.
11. For the individual firm analysis, the corporate tax is calculated according to the
federal tax rate schedule.
12. Assumptions for tax shelter used in the individual firm analysis result in identical
net costs to profitable and unprofitable stations. It is assumed for this analysis that
the losses are passed on to some corporate, partnership or individual tax entity that
uses the losses as a deduction.
ASSUMPTIONS FOR FM RADIO STATIONS
1. Stations with tower-mounted antennas were included; building-mounted antennas
were not.
2. Both single-mounted and co-mounted antennas on one tower or antenna farms were
included.
3. Compliance measures were generally applied in the order of increasing cost.
4. For compliance measures involving replacement of antennas, the old antenna was
replaced with one of equivalent ERP.
5. Because the EPA data base contains only 3895 (89%) of the 4374 FM radio stations,
it was assumed that the larger group of FM stations contain the same ratio of
antenna types, tower heights, ERP, etc. as the group in the data base. Thus, each
group of FM stations was increased by 4374 T 3895 = 1.123.
6. On the basis of professional judgment, those FM stations that could not achieve
compliance using fixes 2 or 3 were distributed among compliance measures 4, 5, and
6 (Table 15) according to the percentages given in Table 8.
7. It is assumed for compliance measures 4, 5, and 6 that half the stations can use their
existing antennas; the cost of a 3-bay, X/2 antenna (Table 9.e) was multiplied by 0.5
and added to the cost of a structural analysis for compliance measure 4 ($12,000),
and to the cost of a new tower for compliance measures 5 and 6.
8. One third of the stations with antennas co-located on towers with other FM stations
are assumed to relocate with another station if compliance measure 4, 5, or 6 is
used, reducing the cost of these measures by 1/6 for these stations as a whole
(1/3 of stations x 1/2 cost).
9. The EPA-FCC data on antenna height are based on the center of ERP; therefore, for
costing purposes, 25' was added to the height of each tower needed for compliance
measures 5 and 6; 25' is half the average height of a typical 6-bay FM antenna.
73
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ASSUMPTIONS FOR AM RADIO STATIONS
1. Varying percentages of AM stations were assumed to have existing adequate fencing
(see Table 5) reducing the overall cost of compliance accordingly.
2. The area fenced is assumed to be square; the fence contains one 20' gate for
vehicular access.
ASSUMPTIONS FOR TV BROADCAST STATIONS
1. It is assumed that TV antennas can be modified in a manner similar to that of FM
antennas to reduce downward radiation from grating lobes.
SUMMARY OF RESEARCH RESULTS
The results of the economic study are presented in the following series (at the end
of this section) of summary figures (Figs. 22-49) and tables (Tables 12-17); more detailed
data are given in Volume II, Appendices D-G. The presentation of the summary results is
organized into the following sequence: total (FM, AM, TV) social cost, total industry cost,
FM average firm, AM average firm, TV average firm, FM-AM-TV cost distribution,
compliance measure component cost analysis, FM compliance measure one cost analysis,
and number of stations affected by the guidelines.
What are the costs to the society-at-large of the proposed guideline limiting public
exposure to RF from broadcast sources? Figures 22 and 23 at the end of this section give
the range (low, medium, and high cost assumptions) of the cost to society-at-large of a
guidance limiting public exposure to RF from AM, FM, and TV broadcast sources for 6 of
18 guidance levels analyzed. Figure 22 shows the cost in terms of total present value;
Figure 23 shows the annual cash flow cost. The PV of the cost to society varies from a
maximum (high cost assumptions) of $866.6 million for guidance level 1 to a minimum
(low cost assumptions) of $12.7 million for guidance level 18. The cash flow cost to
society varies from $207.8 million to $3.1 million. Data for these figures are identified in
Table 12 at the end of this section and also in Table G-l in the Appendix.
How much will the proposed guidelines cost the broadcast industry as a whole? In
contrast to the cost to society, the PV of the cost of the guidelines to the total broadcast
industry (Fig. 2k) varies from $414.6 million to $6.9 million. The average net after tax
CFC of the cost of compliance for the total broadcast industry (Fig. 25) is also less than
the equivalent cost to society, varying from $59.1 million to $0.8 million. Data for these
-------
figures are identified in Table 13 at the end of this section and also in Table G-2 in the
Appendix. The lower costs to industry as contrasted with the costs to society result from
the difference in definitions of the two costs. The cost to society-at-large is defined as
including all the opportunity costs (costs of using resources for one use and foregoing the
opportunity to use them for other uses); the cost to industry is an estimate of the net cost
and includes transfer payments not considered in the social cost, such as tax deductions
and credits and interest on funds assumed borrowed for the compliance measures.
The next 12 figures show the range of the estimated cost of compliance for the
average (FM, Figs. 26-29; AM, Figs. 30-33; TV, Figs. 34-37) broadcast station in terms of
average PV, average net CFC, and the maximum and average reduction in net profit
resulting from the net CFC cost of compliance; all shown for 6 of 18 guidance levels. The
average present value of the cost of compliance for the average broadcast station varies
from $40.6 thousand (FM-Fig. 26), $7.9 thousand (AM-Fig. 30), $285.3 thousand
(TV-Fig. 34) at guidance level 1 to $4.8 thousand (FM), $1.3 thousand (AM), $0.7 thousand
(TV) at guidance level 18. The average CFC is estimated to vary from a maximum of
$9.7 thousand (FM-Fig. 27), $1.8 thousand (AM-Fig. 31), $67.8 thousand (TV-Fig. 35) at
guidance level 1 to a minimum of $1.1 thousand (FM), $0.3 thousand (AM), $0.1 thousand
(TV) at guidance level 18. The estimated reduction in profit associated with the
maximum cash flow cost for compliance over six years for the average broadcast station
is shown for FM (Fig. 28), AM (Fig. 32), and TV (Fig. 36) and varies from a maximum of
16.4% (FM) at guidance level 1 to 0.10% (TV) at guidance level 18. The reduction in net
profit associated with the average cash flow cost for compliance over six years for the
average broadcast station is shown for FM (Fig. 29), AM (Fig. 33), and TV (Fig. 37) and
varies from a maximum of 10.1% (FM) at guidance level 1 to 0% (TV) at guidance
level 18. Data for these figures are identified in Table 14 at the end of this section and
in Tables D-3, E-3, F-3, and G-3 in the Appendix.
The net effect of the maximum annual net after tax cash flow cost of compliance on
unprofitable broadcast stations is the same in absolute dollar terms as for profitable
stations but the percentage effect varies with the guidance level and the cost level. The
average unprofitable FM radio station loses 18% more than the average profitable station
makes net of taxes,72 so the same cost of compliance will be a smaller percentage
addition to the average losses than reduction in the average profit. The average
unprofitable FM station will experience an average increase in net losses varying from
about 19% (guidance level 1 - high cost) to about 1% (level 18 - low cost). The average
75
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unprofitable AM radio station loses 8% less than the average profitable station makes net
of taxes,72 so the same compliance costs will be a greater percentage of losses than
profits. The average unprofitable AM station will have average increased losses ranging
from about 3% (guidance level 1 - high cost) to less than 1% (level 18 - low cost). The
average unprofitable TV broadcast station loses only 31% as much as the average
profitable station makes net of taxes72 so the same absolute dollar cost of compliance will
be several times greater in percentage terms for unprofitable stations than for profitable
ones. The average unprofitable TV station will experience increased losses ranging from
about 27% (guidance level 1 - high cost) to especially zero (guidance level 18 - low cost).
The general pattern of all costs (and the number of stations requiring a compliance
measure at a given guidance level) is clear; the cost of the guidance drops dramatically
from guidance level 1 (1 pW/cm2 - FM/TV RF units), the most stringent analyzed, to
about i+ (20 uW/cm2), then falls rapidly to about 9 or 10 (400 yW/cm2) and more gradually
to guidance level 18 (10,000 uW/cm2), the least stringent level analyzed.
How do the three major segments of the broadcast industry compare in the share of
the costs of the guideline attributable to them? An analysis of the distribution of costs
among the three industry segments was made using the medium level PV of the cost to
society; the distribution is shown in Fig. 38 for 6 of the 18 guidance levels. At guidance
level 1, the cost of compliance for TV broadcast stations predominates because the
compliance measures are more costly for TV than for radio stations. Thereafter, the
number of TV stations requiring a compliance measure drops sharply and FM radio stations
dominate the total cost until the last guidance levels are reached, when the relatively
larger number of AM stations requiring a compliance measure causes the AM sector to
predominate. Even though the number of AM radio stations requiring a compliance
measure is greater than the number of FM stations beginning with guidance level 2
(Tables 15-17), the compliance measures for FM stations are more complex and costly
than those for AM stations, causing the expenses for the FM segment to exceed those for
AM up to guidance level 17. Data for this analysis are identified in Table 12,
medium-level TNPV cost to society; also see Tables D-l, E-l, F-l, and E-l in the
Appendix.
The total cost of compliance can be grossly segmented into two components, the
cost of a survey of the RF environment around the antenna to determine the need for and
extent of mitigation measures required and the cost of the compliance measure itself.
The distribution of these two cost components is shown for FM (Fig. 39), AM (Fig. 40),
and TV (Fig. 41) based on the medium-level component cost to society-at-large. The
consistent pattern is that, at lower, more difficult-to-achieve guidance levels, the cost of
76
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the compliance measure predominates. However, at less stringent standard levels
(guidance level 12, FM; guidance level 4, AM; guidance level 8, TV) the cost of the survey
for all stations exceeds the cost of compliance for those stations requiring it. Data
plotted in Figs. 39, 40, and 41 are identified in Tables D-1, E-1, F-1, respectively, in the
Appendix.
Although the cost analyses were performed assuming some form of positive
compliance, the EPA investigators observed in the course of their work that many FM
transmitters are located in remote areas often inaccessible to the public. Therefore we
tested the effect on costs of assuming that a percentage of FM stations would be
permitted to post warning signs around antennas that emit RF above the guideline. The
percentage of stations allowed this inexpensive solution was based on criteria for
remoteness developed from population statistics using CED data in conjunction with the
geographic location of FM antennas. Allowing FM stations, whose antennas are defined as
remote, to post warning signs reduces the cost to society of the guidelines for the FM
segment of the broadcast industry at guidance level 1 by up to 20% (Fig. 42) and reduces
the cost of compliance to the FM broadcast industry by very nearly 20% (Fig. 43).
Reductions in cost at less stringent guidance levels display the same decline as overall
costs. When the other two segments of the broadcast industry, which are not affected by
the inexpensive posting option, are combined with the FM segment, the overall effect is
diluted. The overall cost to society of the guideline is reduced by a maximum of 8% at
guidance level 2 (Fig. 44); the overall cost of compliance to the broadcast industry is
reduced by about 7.5% at guidance level 2 (Fig. 45). The plots in Figs. 44 and 45 show
that cost reductions are depressed at guidance level 1, after which they rise and then
resume a pattern consistent with the cost-guidance level relationships discussed earlier.
The reason these cost reduction curves increase before decreasing relative to guidance
level is that the cost of compliance for TV stations, which is not affected by the posting
solution, dominates the total cost at guidance level 1 (see Fig. 38). However, beginning
with guidance level 2, the cost of compliance for the FM broadcast sector is higher than
the cost for the AM and TV sectors combined, so the cost reduction that is applicable to
the FM sector has a greater effect on the aggregate cost of compliance at guidance
level 2 than at guidance level 1.
How many stations would require measures to comply with a guideline if it were
implemented? The number of stations assumed to require some kind of compliance
measure other than the survey is shown for FM (Fig. 46), AM (Fig. 47), and TV (Fig. 48).
The assumptions for selection of compliance measures and for differences among the
three cost levels result in three distinctly different numbers of AM radio stations
77
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requiring compliance measures at the low, medium, and high cost estimates, which is
reflected in the three plots in Fig. 47. The number of FM and TV broadcast stations that
require a compliance measure is constant across all three cost levels (Figs. 46 and 48).
The number of AM stations varies with the cost level because assumptions were made
about the proportion of stations already fenced at the three cost levels (see Table 5). The
percentage distribution of the number of FM, AM, and TV stations requiring a compliance
measure is shown in Fig. 49 at 6 of the 18 guidance levels studied. This distribution
differs from that shown for costs in Fig. 38 for two reasons. First, though the number of
stations actually requiring a compliance measure declines to very small numbers at the
less stringent guidance levels, all stations were assumed to require a survey (and the
associated cost) at all guidance levels. Further, the cost of compliance for TV broadcast
stations is disproportionately costly relative to the number of TV stations requiring a
compliance measure. Data for Figs. 46-48 are identified in Tables 15, 16, and 17 at the
end of this section and also in Tables D-4, E-4, and F-4 in the Appendix.
78
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High
Medium
Low
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6
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15
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Guidance Level
Figure 22. The range of total present value (constant dollar)
cost to society-at-large of guidelines limiting public exposure
to radiofrequency radiation from AM, FM, and TV broadcast sources
is shown for 6 of 18 guidance levels studied.
79
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Guidance Level
Figure 23. The range of annual cash flow (current year dollar)
cost to society-at-large of guidelines limiting public exposure
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is shown for 6 of 18 guidance levels studied.
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High
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Guidance Level
Figure 24. The range of the total present (constant dollar)
value of the net after-tax cost to the broadcast industry of
guidelines limiting public exposure to radiofrequency radiation
from AM, FM, and TV broadcast sources is shown for 6 of 18
guidance levels studied.
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100
.2 io
CO
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~ 1
High
Medium
Low
6 10
Guidance Level
15
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Figure 25. The range of average annual net after tax cash flow
(current year dollar) cost to the broadcast industry of guidelines
limiting public exposure to radiofrequency radiation from AM, FM,
and TV broadcast sources is shown for 6 of 18
guidance levels studied.
82
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50
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30 -
20 -
10 -
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Medium
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Guidance Level
15
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Figure 26. The range of the average (of 5 cohorts) present
(constant dollar) value of the net after-tax cost to the average
profitable FM radio broadcast station of guidelines limiting public
exposure to radiofrequency radiation is shown for 6 of 18
guidance levels studied.
83
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12r
11
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6
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High
Medium
Low
15
16
Figure 27. The range of average annual net after-tax cash flow
(current year dollar) cost to the average profitable FM radio
broadcast station of guidelines limiting public exposure to radio-
frequency radiation is shown for 6 of 18 guidance levels studied.
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18
16
14
12
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Medium
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6
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15
18
Guidance Level
Figure 26. The percentage reduction in the net profit of the
average profitable FM radio broadcast station associated with
the maximum annual cash flow cost of compliance with guidelines
limiting public exposure to radiofrequency radiation is shown for
6 of 18 guidance levels at 3 cost levels.
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Guidance Level
Figure 29. The percentage reduction in the net profit of the
average profitable FM radio broadcast station associated with
the average annual cash flow cost of compliance with guidelines
limiting public exposure to radiofrequency radiation is shown for
6 of 18 guidance levels at 3 cost levels.
86
-------
cd
o
00
-O
C
cd
w
3
O
10
9
6
7
6
3 -
Z -
1 -
High
Medium
Low
6
10
15
16
Guidance Level
Figure 30. The range of the average (of 5 cohorts) present
(constant dollar) value of the net after-tax cost to the average
profitable AM radio broadcast station of guidelines limiting public
exposure to radiofrequency radiation is shown for 6 of 18
guidance levels studied.
87
-------
o
o
CU
£_
-o
c
3
ac
20 r
18
16
14
12
10
8
6
4 -
2 -
6
10
Guidance Level
High
Medi urn
Low
15
18
Figure 31. The range of average annual net after-tax cash flow
(current year dollar) cost to the average profitable
AM radio broadcast station of guidelines limiting public exposure
to radio-frequency radiation is shown for 6 of 18 guidance
levels studied.
88
-------
c
o>
o
J_
OJ
10
9
8
rt
1 -
High
Medium
Low
6
10
15
IB
Guidance Level
Figure 32. The percentage reduction in the net profit of the
average profitable AM radio broadcast station associated with
the maximum annual cash flow cost of compliance with guidelines
imiting public exposure to radiofrequency radiation is shown for
6 of 18 guidance levels at 3 cost levels.
89
-------
3r
c
CD
O
t_
(U
O.
1 -
High
Medium
Low
6
10
15
18
Guidance Level
Figure 33. The percentage reduction in the net profit of the
average profitable AM radio broadcast station associated with
the average annual cash flow cost of compliance with guidelines
limiting public exposure to radiofrequency radiation is shown for
6 of 18 guidance levels at 3 cost levels.
90
-------
300
250
co
20°
GO
-0
C
CO
O
.c
e-
150
100 -
50
High
Medium
Low
6
10
15
18
Guidance Level
Figure 34. The range of the average (of 5 cohorts) present
(constant dollar) value of the net after-tax cost to the average
profitable TV broadcast station of guidelines limiting public
exposure to radiofrequency radiation is shown for 6 of 18
guidance levels studied.
91
-------
CO
I_
CO
CO
-o
c
CO
CO
70
60
50
40
30 -
20 -
10 -
High
Medium
Low
1
6
10
15
18
Guidance Level
Figure 35. The range of average annual net after-tax cash flow
(current year dollar) cost to the average profitable TV
broadcast station of guidelines limiting public exposure to radio-
frequency radiation is shown for 6 of 18 guidance levels studied.
92
-------
c
CD
O
S-
CU
O-
1 -
High
Medium
Low
6 10
Guidance Level
15
18
Figure 36. The percentage reduction in the net profit of the
average profitable TV broadcast station associated with
the maximum annual cash flow cost of compliance with guidelines
limiting public exposure to radiofrequency radiation is shown for
6 of IB guidance levels studied.
93
-------
6r
c
o>
o
J-,
0>
CL
2 -
1 -
High
Medium
Low
6 10
Guidance Level
15
16
Figure 37. The percentage reduction in the net profit of the
average profitable TV broadcast station associated with the
average annual cash flow cost of compliance with guidelines
imiting public exposure to radiofrequency radiation is shown for
6 of 18 guidance levels studied.
-------
377.FM
7%AM
63%F
16%AM
64%F
21%TV
20%AM
15%TV
56%TV
33*AM
40XAM
46%AM
9%TV
58%FM
9%TV
51XFM
1 1%TV
43%FM
10
15
18
Guidance Level
Figure 38. The distribution of the total present (constant dollar) value
cost to society-at-large among AM, FM, and TV broadcasters of guidelines
limiting public exposure to radiofrequency radiation is shown for
6 of 18 guidance levels studied (medium cost analysis).
-------
Survey( 3.4%)
Compliance( 96.6%)
Survey( 12.3%)
Compliance( 87.7%)
Survey( 16.3%)
Compliance( 83.7%)
Survey( 41.0%)
Compliance( 58.9%)
Survey( 58.8%)
Compliance( 41.2%)
Survey( 99.1%)
Compliance( 0.9%)
10
15
Guidance
18
Leve
Figure 39. The distribution of the two main cost components for the
total gross (undiscounted) cost to society-at-large of guidelines limiting
public exposure to radiofrequency radiation from FM broadcast sources is
shown for 6 of 18 guidance levels studied (medium cost analysis).
96
-------
Survey( 19.0%)
Compliance( 80.9%]
Survey( 49.0%)
Compliance( 50.9%)
Survey( 53.9%)
Compliance( 46.1%)
Survey( 76.5%)
Compliance( 23.4%)
Survey( 79.0%)
Compliance! 21.0%)
Survey( 97.1%)
Compliance( 2.8%)
10
15
Guidance
16
Level
Figure 40. The distribution of the two main cost components for the
total gross (undiscounted) cost to society-at-large of guidelines limiting
public exposure to radiofrequency radiation from AM broadcast sources is
shown for 6 of 18 guidance levels studied (medium cost analysis).
97
-------
Survey( 0.6")
Comp1iance( 99.4%
Survey( 9.5%)
Compliance! 90.4%)
Survey( 18.4%)
Compliance! 81.6%)
Survey! 68.1%)
Compliance! 31.9%
10
Survey! 93.4%)
Compliance! 6.6%)
15
Guidance
Level
Survey(100.0%)
Compliancef 0. '
Figure 41. The distribution of the two main cost components for the
total gross (undiscounted) cost to soc lety-at-large of guidelines limiting
public exposure to rad lofrequency radiation from TV broadcast sources is
shown for 6 of 18 guidance levels studied (medium cost analvsis).
-------
Guidance Level
23 4 5 6
OJ
u
IB
S
/iW/cnr
Figure 42. The present (constant dollar) value of the cost to society-
at-large of guidelines limiting public exposure to radiofrequency
radiation from FM radio broadcast sources is reduced by the percentages
shown if compliance measure one is permitted.
99
-------
Guidance Level
23 4 5 6
c
o>
o
OJ
D_
15 18
g
/if/cm2
Figure 43. The present (constant dollar) value of the net after-tax
cost to the FM broadcast industry of guidelines limiting public exposure
to radiofrequency radiation is reduced by the percentages shown if
compliance measure one is permitted.
100
-------
Guidance Level
15 IB
Ml/cm ^
Figure 44. The total present (constant dollar) value of the cost to society-at-large
of guidelines limiting public exposure to radiofrequency radiation from AM, FM, and
TV broadcast sources is reduced by the percentages shown if compliance measure one
is permitted for FM stations.
101
-------
Guidance Level
o
i_
O)
18
/if/cm2
Figure 45. The total present (constant dollar) value of the cost to the AM,
FM, and TV broadcast industry of guidelines limiting public exposure to
radiofrequency radiation is reduced by the percentages shown if compliance
measure one is permitted for FM stations.
102
-------
Guidance Level
4500
4000
10
12
13
14
15
18
fi W/cm
Figure 46. The number of FM radio broadcast stations requiring measures to
comply with guidelines limiting public exposure to radiofrequency radiation
is shown for 18 specified guidance levels.
103
-------
Guidance Level
4000
23 4
3000-
o
03
CO
- 2000
o
O)
I
IB
1000 ~
265
(1000)
Q
mW/cm
(V/m)
Figure 47. The number of AM radio broadcast stations requiring measures to
comply with guidelines limiting public exposure to radiofrequency radiation
is shown for IB specified guidance levels at three cost levels.
-------
800
700
600
.1 500
Guidance Level
10
r
12
I"
13
14
"1 "
o
k-
OJ
400
300
— o
/i W/cm ^
Figure 48. The number of TV broadcast stations requiring measures to
comply with guidelines limiting public exposure to radiofrequency radiation
is shown for 18 specified guidance levels.
-------
40%AM
64%AU
1%TV
48%FM
69%AM
3%TV
2%TV
33%FM
28%FM
75%AM
84%AU
1XTV
23%FM
1%TV
1 5%FM
96%A
10
15
Guidance Level
18
Figure 49. The percentage distribution of AM, FM and TV broadcast stations
requiring compliance measures is shown for 6 of 18 guidance levels
studied (medium cost analysis).
-------
O
VI
TABLE 12. AN ESTIMATE OF THE POTENTIAL COST TO THE SOCIETY-AT-LARGE OF GUIDELINES LIMITING PUBLIC EXPOSURE
TO RftDIOFREQUENCY RADIATION FROM AM, FM. VHF-TV. AND UHF-TV BROADCAST SOURCES IS GIVEN FOR 3 COST LEVELS.
THE ANNUAL CASH FLOW (CURRENT YEAR DOLLAR) COST AND THE PRESENT (CONSTANT DOLLAR) VALUE ARE SHOWN ._.„,,,..,„
FOR COMPLIANCE WITH 18 SPECIFIED GUIDANCE LEVELS. IT IS ASSUMED THAT FM STATIONS SELECT ONE OF FIVE COMPLIANCE
MEASURES (2 THROUGH 6) AND THAT COMPLIANCE COSTS (ANNUAL CASH FLOW) ARE SPREAD EVEMIY AMONG FIVE ANNUAL COHORTS
OF STATIONS. NUMBERS ARE IN MILLIONS OF DOLLARS. MICROWATTS PER SQ. CM IS ABBREVIATED UW/CM-2; VOLTS PER METER, V/M.
GUIDANCE LEVEL
1 .
ANNUAL CASH FLOW COST
PRESENT VALUE
2.
ANNUAL CASH FLOW COST
PRESENT VALUE
3.
ANNUAL CASH FLOW COST
PRESENT VALUE
4.
ANNUAL CASH FLOW COST
PRESENT VALUE
5.
ANNUAL CASH FLOW COST
PRESENT VALUE
FM
LOW
30.
125.
13.
54.
1 0 .
43.
6
28
5
24
0
1
0
3
, 4
.2
.9
.8
.9
.5
MED
1 .
51 .
214.
10.
28.
116 ,
20.
21 .
91
50.
14
59
75.
12
49
HIGH
LOW
UW/CM-2
5
7
73.
305.
3
5
5.3
22.2
UW/CM-2
0
,6
39.
164.
UW/CM-2
.9 T "
.3
127 .
4
3
. 5
.1
3.0
12.5
11.1
UW/CM-2
.3
.5
19
81
.6
.6
2.3
9 .8
UW/CM-2
.0
.9
16
68
.4
.2
2.3
9.4
AM
MED
10.
9.
40.
32.
5.
21
45.
18
71 .
3
1 5
87.
3
15
V/M
7
5
V/M
.1
.1
V/M
.4
V/M
.8
.7
V/M
.6
.0
HIGH
15.7
65.4
7 .8
32.3
27 .8
5.6
23.3
5.3
22.0
LOW
45.
190.
10.
45
29
3
1 3
Z
8
6
2
.8
.1
Q
.3
.1
. 0
.1
.7
TV
MED
1 .
76.
317 .
10.
16 .
70.
20.
1 0
42
50.
4
18
75.
3
12
HIGH
LON
TOTAL
MED
HIGH
UW/CM-2
0
0
118.
495.
9
7
80.
337 .
9
5
137.
572.
2
2
207.8
866.6
UW/CM-2
9
5
20.
85.
UW/CM-2
3 1 °
.8
50
5
5
Q
.1
26.
Ill .
20
83
8
8
o
.6
49.
208.
36 ,
1 52
9
2
p 5
.4
67.7
282.2
49.1
204.9
UW/CM-2
.5
.9
5
21
.2
.9
12
51
.4
.6
22
94
.6
. 1
30.4
126 .7
UW/CM'Z
. 0
.3
3
14
.4
.0
10
42
.2
.6
18
77
. 5
.2
25.0
1 04.1
-------
TABLE 12.
(CONTINUED)
O
00
GUIDANCE LEVEL
ANNUAL CASH FLOH COST
PRESENT VALUE
ANNUAL CASH FLOW COST
PRESENT VALUE
8.
ANNUAL CASH FLOW COST
PRESENT VALUE
9.
ANNUAL CASH FLOW COST
PRESENT VALUE
10.
ANNUAL CASH FLON COST
PRESENT VALUE
FM
LOH
5.X
22.2
3.9
16.2
3.2
13.3
2.7
11.1
2.4
10.2
MED HIGH
100.
10.
44,
200.
7 .
31 .
300.
5.
24
400.
4
19
500.
4
17
UK/CM -2
.7 14.
.7 60.
UH/CM- 2
.5 10.
.2 41 .
UH/CM-2
.9 7 .
.7 32.
UN/CM -2
.8 6.
.9 26,
UW/CM-2
.3 5,
.8 23.
5
4
0
6
8
7
,3
.2
.6
.3
LOU
2.
9.
2.
8.
2,
8
1
8
1
7
,2
, T
.1
,6
.0
.1
.9
.1
.7
.0
AM
MED
100.
3,
14,
141 .
3.
13,
173.
3,
12
200.
3
12
224.
2
1 0
V/M
.4
.3
V/M
.2
.4
V/M
.0
.4
V/M
.0
.3
V/M
.4
.1
HIGH
5.
20.
4,
19.
4,
17.
4
17
3
13
,0
9
,6
.3
,2
.7
.2
.5
.3
.7
LOH
1 ,
7.
0.
3.
0.
2
0
2
0
2
i 7
,1
.8
.5
.6
.6
. 5
.2
.5
.0
TV
MED HIGH
100.
2.
9 .
200.
1 ,
4 .
300.
0.
3,
400 .
0
2
500.
0
2
LOW
TOTAL
MED
HIGH
UW/CM-2
,3
2
.8 11 .
UH/CM~
,1
.7
UW/CM-
.8
.4
UH/CM-
.7
.9
UW/CM-
.6
.6
2
1 .
5,
2
1 .
4,
2
0
3
2
0
3
.6
.0
.3
,4
.0
,0
.8
.5
.8
.2
9.
38.
6.
28.
5.
24,
5.
21
4
19.
.2
.4
8
.3
,8
,0
.1
.4
.6
.1
16 .
68.
11 ,
49 .
9
40
8
35
7
30
.5
,8
.8
.3
.7
.6
.4
.1
.3
. 5
22.
92.
1 5.
66 .
13,
54.
11 .
47
9
40
, 1
.3
.9
.3
.0
.4
.3
.1
.6
.1
-------
TABLE 12.
(CONTINUED)
O
SO
GUIDANCE LEVEL
ANNUAL CASH FLOW COST
PRESENT VALUE
12.
ANNUAL CASH FLOW COST
PRESENT VALUE
13.
ANNUAL CASH FLOW COST
PRESENT VALUE
14.
ANNUAL CASH FLOW COST
PRESENT VALUE
1 5.
ANNUAL CASH FLOW COST
PRESENT VALUE
FM
LOU
2.2
9.4
2.1
8.6
Z.ti
8.3
1 .9
8.0
1 .9
7.8
MED HIGH
600.
3.
16 .
700.
3.
14.
800.
3,
13.
900.
3
12
1000.
3
12
LON
UW/CM-2
8
5.
0 20 .
UH/CM
4
3
-2
4.
18.
0
8
5
.6
1 .
6 .
1 ,
6 .
7
9
.6
.8
UW/CM-2
,3
.7
UW/CH
.1
.9
UW/CM
.0
.4
4.
17
-2
4
16
"2
3
16
.2
.7
.0
.7
.8
.0
1
6
1
6
1
6
.6
.8
.6
.8
.6
.8
AM
MED
245.
2.
10.
265.
2.
9
282.
2
9
300.
2
9
316.
2
9
V/M
4
.0
V/M
.4
.8
V/M
.3
.8
V/M
.3
.8
V/M
.3
.8
HIGH
3.
13.
3.
13.
3.
13.
3.
13.
3.
13.
2
5
2
3
2
2
2
2
1
1
LOW
0.
1 .
0.
1 .
0
1
0
1
0
1
4
6
.4
.5
.4
.5
.4
.5
.3
.4
TV
MED HIGH
600.
0.
2.
700.
0.
2,
800.
0
2
900.
0
2
1000.
0
1
UW/CM -
5
1
2
0.
2.
6
6
LOW
4.
17.
3
p 9
TOTAL
MED
6 .
28.
7
1
HIGH
8.9
36.9
UW/CM-2
,5
,1
UW/CM-
. 5
.0
UW/CM-
.5
.0
UW/CM -
.5
.9
0.
2.
2
0.
2
2
0
2
2
0
2
6
.5
.6
.5
.6
.5
.6
.4
4.
17.
4
16
3
16
3
16
.1
.0
.0
.6
.9
.3
.8
.0
6.
26 ,
6
25
5
24
5
24
.3
,2
.1
.5
.9
.7
.8
. 1
8.3
34.4
8.0
33.4
7 .8
32.4
7 .6
31 .5
-------
TABLE
(CONTINUED)
GUIDANCE LEVEL
16.
ANNUAL CASH FLOW COST
PRESENT VALUE
ANNUAL CASH FLOW COST
PRESENT VALUE
ANNUAL CASH FLOW COST
PRESENT VALUE
LOW
FM
MED
HIGH
2000. UH/CM-2
1.6 2.3 2.9
6.5 9.6 12.2
5000. UW/CM-2
1.4 1.9 2.4
5.7 7.8 9.8
10000. UW/CM'2
1.3 1.8 2.2
5.5 7.4 9.2
LOU
1 .4
6 .0
AM
MED
447. V/M
1.6 2.3
6.7 1.6
708. V/M
2.0
8.2
1000. V/M
1.4 1.9
5.9 7.9
HIGH
3.1
12.8
2.5
10.4
2.4
10.0
LOW
TV
MED
HIGH LOW
2000. UW/CM-2
0.3 0.4 0.5 3.5
1.4 1.8 2.3 14.6
5000. UW/CM-2
0.3 0.4 0.5 3.1
1.4 1.8 2.3 13.1
10000. UW/CM-2
0.3 0.4 0.5 3.1
1.4 1.8 2.3 12.7
TOTAL
MED
5.0
27 .0
4.3
17 .8
4.1
17.1
HIGH
6.6
27.3
5.4
22. 5
5.2
21 .5
-------
TABLE 13. AN ESTIMATE OF THE POTENTIAL COST TO THE BROADCAST INDUSTRY OF GUIDELINES LIMITING PUBLIC EXPOSURE
TO RADIOFREQUENCY RADIATION FROM AM. FM, VHF-TV, AND UHF-TV BROADCAST SOURCES IS GIVEN FOR 3 COST LEVELS.
THE AVERAGE ANNUAL CASH FLOW (CURRENT YEAR DOLLAR) COSTS AND THE PRESENT (CONSTANT DOLLAR) VALUE ARE
SHONN FOR COMPLIANCE NITH 1R SPECIFIED GUIDANCE LEVELS. IT IS ASSUMED THAT FM STATIONS SELECT ONE OF FIVE
COMPLIANCE MEASURES (2 THROUGH 6) AND THAT COMPLIANCE COSTS (ANNUAL NET CASH FLOW) ARE SPREAD EVENLY AMONG FIVE
ANNUAL COHORTS OF STATIONS. NUMBERS ARE IN MILLIONS OF DOLLARS.
IIICROHATTS PER SO. CM IS ABBREVIATED KM/CM'21 VOLTS PER METER. V/M.
GUIDANCE LEVEL
1 .
AVG ANNUAL CASH FLOW
PRESENT VALUE
2.
AVG ANNUAL CASH FLON
PRESENT VALUE
3.
AVG ANNUAL CASH FLOW
PRESENT VALUE
4.
AVG ANNUAL CASH FLON
PRESENT VALUE
5.
AVG ANNUAL CASH FLOW
PRESENT VALUE
FM
LOW
8.5
59.9
3.7
26.1
2.9
20.8
1 .9
14.0
1 .6
12.0
MED
1 .
14.
103.
10.
7,
56.
20.
6
43
50.
4
28
75.
3
24
HIGH
LOW
UW/CM-2
.8
21 .
,7 149.
UN/CM
.9
.0
-2
11 .
79.
3
1
2
2
1 .
10.
0.
6.
5
,9
.8
,3
UW/CM-2
.2
.9
8.
61 .
,7
,2
0.
5.
.7
.6
UW/CM-2
.0
.7
5.
39,
.5
,4
0
5
.6
.0
UW/CM-2
.4
.1
4.
33
.6
.0
0
4
.6
.8
AM
MED
10.
2.
19.
32.
1 ,
10.
45.
1 ,
9
71 .
1
7
87.
1
7
V/M
.7
,6
V/M
.4
.5
V/M
.2
.2
V/M
.0
.9
V/M
.0
.6
HIGH
4.
31
2
15
1
13
1
1 1
1
11
.4
.5
.2
.9
.8
.8
.5
.6
.5
.0
LOW
12,
89.
3,
21 ,
2
13
0
6
0
4
.8
,8
.0
.3
.0
.9
.9
.2
.6
.2
TV
MED
1 .
21 .
149.
10.
4
33,
20.
2
20
50.
1
9
75.
0
5
HIGH
LOW
TOTAL
MED
HIGH
UW/CM-2
.3
33.
.6 233,
UW/CM
.7
.4
-2
5.
40
.4
.9
.8
.5
22.
160.
7 .
53,
.8
,5
.5
.7
38.
273.
14.
99,
.8
,0
.1
.8
59.1
414.6
19.1
135.6
UW/CM-2
.9
.3
UW/CM
.3
.1
3
23
-2
1
10
.4
.8
.5
.5
5
40
3
25
.6
.4
.4
.2
10
73
6
45
.3
.3
.3
.7
13.9
98.8
8.5
61 .5
UW/CM-2
.8
.9
0
6
.9
.8
2
21
.8
.0
5
37
.2
.7
7.0
50.8
-------
TABLE 13.
(CONTINUED)
GUIDANCE LEVEL
AVG ANNUAL CASH FLOW
PRESENT VALUE
7.
AVG ANNUAL CASH FLOW
PRESENT VALUE
8.
AVG ANNUAL CASH FLCH
PRESENT VALUE
9.
AVG ANNUAL CASH FLOW
PRESENT VALUE
AVG ANNUAL CASH FLOM
PRESENT VALUE
FH
LOH
1 .
10.
1 ,
8,
0
6
0
5
0
5
,5
,9
.1
.0
.9
.6
.7
.6
.7
.2
MED HIGH
100.
3.
21 ,
200.
2
15
300.
1
12
400.
1
9
500.
1
8
UW/CM
,0
.7
-2
4.
29.
1
2
LOW
0,
4,
,6
,7
UW/CM- 2
.1
.2
UW/CM
.6
.2
2.
20.
-2
2.
16.
8
3
2
0
0
4
0
4
.6
. 5
.5
.2
UW/CM- 2
.3
.9
UW/CM
.2
.9
1 .
13.
-2
1 .
11 .
7
0
5
6
0
4
0
3
. 5
.2
.5
.7
AM
NED
1 00.
0.
7.
141 .
0.
6.
173.
0.
6.
200.
0.
6.
224.
0.
5.
TV
HIGH
V/M
9
3
V/M
9
8
V/M
8
4
V/M
8
3
V/M
7
3
1 .
10.
1 .
9.
1 .
9.
1 .
8.
0.
7 .
4
5
3
8
2
0
2
9
9
1
LOW
0.
3.
0.
1 .
0.
1 .
0.
1 .
0.
1 .
5
4
2
7
2
3
1
1
1
0
MED HIGH
100.
0.
4,
200.
0,
2.
300.
0
1
400.
0
1
500.
0
1
UW/CM-
,7
,7
UW/CM-
.3
.3
UW/CM'
.2
.7
UW/CM -
.2
.5
UW/CM -
.Z
.4
2
0
5
2
0
2
2
0
2
2
0
1
2
0
1
.7
.4
.4
.7
.3
.1
.2
.8
.2
.7
LOW
2.
19.
1 .
14.
1 .
12.
1 .
11 .
1 .
9.
6
0
9
2
6
2
4
0
3
9
TOTAL
MED
4.
33.
3.
24.
2.
20.
2.
17 .
2.
1 5.
6
7
3
4
7
3
3
7
0
5
HIGH
6.2
45.1
4.4
32.8
3.6
27.1
3.1
23.7
2.6
20.4
-------
TABLE 13.
(CONTINUED)
GUIDANCE LEVEL
11 .
AVG ANNUAL CASH Ft OH
PRESENT VALUE
12.
AVG ANNUAL CASH FLOW
PRESENT VALUE
13.
AVG ANNUAL CASH FLOW
PRESENT VALUE
14.
AVG ANNUAL CASH FLOW
PRESENT VALUE
1 5.
AVG ANNUAL CASH FLOW
PRESENT VALUE
FM
LOH
0.6
4.8
0.6
4.4
0.5
4.3
0.5
4.1
0.5
4.0
MED HIGH
too.
1
8
700.
0
7
800.
0
6
900.
0,
6
1000.
0,
6.
UW/CM-2
.1 1
.0 10
UW/CM-2
.9 1
.3 9
UN/CM -2
.9 1
.9 9
UW/CM-2
.9 1
.6 8
UW/CM-2
.8 1
.4 8
.4
.4
.2
.4
.2
.0
.1
.5
.1
.2
LOW
0,
3
0,
3,
0,
3.
0.
3,
0.
3,
,5
.7
.4
.6
.4
.6
.4
,6
,4
,6
AM
MED
245.
0,
5.
265.
0.
5.
282.
0,
5,
300.
0,
5.
316.
0.
5.
V/M
,7
.2
V/M
,6
.2
V/M
,6
.1
V/M
,6
1 1
V/M
6
,1
HIGH
0
7
0
6
0
6
0
6
0.
6
.9
.0
.9
.9
.9
.9
.9
.9
.9
.8
LOW
0
0
0
0
0
0
0
0
0
0
.1
.8
.1
.8
.1
.8
.1
.8
.1
.8
TV
MED
600.
0
1
700.
0
1
800.
0
1
900.
0
1
1000.
0
1
HIGH
LOH
TOTAL
MED
HIGH
UW/CM-2
.1
.1
0
1
.2
.4
1
9
.2
.3
1
14
.8
.4
2
18
.4
.9
UW/CM-2
.1
.1
0
1
.2
.3
1
8
.1
.9
1
13
.7
.5
2
17
.3
.7
UW/CM-2
.1
.1
UW/CM
.1
.1
UW/CM
.1
.0
0
1
-2
0
1
-2
0
1
.2
.3
.2
.3
.2
.3
1
8
1
8
1
8
.1
.7
.1
.6
.0
.4
1
1 3
1
12
1
12
.7
.2
.6
.8
.6
.5
2
17
2
16
2
16
.2
.2
.1
.7
.1
.3
-------
TABLE 13.
(CONTINUED)
GUIDANCE LEVEL
16.
AVG ANNUAL CASH FLOH
PRESENT VALUE
17.
AW3 ANNUAL CASH FLOM
PRESENT VALUE
18.
AVG ANNUAL CASH FLOH
PRESENT VALUE
FM
LOW
0.4
3.4
0.4
S.1
0.4
3.0
MED
2000.
0,
5.
SOOO.
0.
4.
10000.
0,
4
HIGH
LOW
UW/CM-2
.6
,0
0.8
6 .4
0.
3.
.4
.6
UW/CM-2
. 5
.2
UW/CM
.5
.0
0.6
5.3
-2
0.6
5.0
0.
3
0.
3
.4
.2
.4
.2
AM
MED
447.
0,
5,
708.
0.
4
1000.
0,
4
V/M
.6
.1
V/M
.5
.4
V/M
.5
.3
HIGH
0.
6
0.
5
0
5
.8
.7
.7
.6
,6
.4
LOW
0.
0.
0.
0
0
0
.1
.7
.1
.7
.1
.7
TV
MED HIGH
2000.
0
1 ,
5000.
0,
1
10000.
0
1
LOW
TOTAL
MED
HIGH
UW/CM-2
.1
.0
UW/CM-
.1
.0
0
1 ,
2
0
1
.1
.2
. 1
.2
0
7.
0
7
.9
.7
.8
.0
1
11
1
9
.4
.1
.2
. 5
1 .8
14.3
1 .5
12.1
UW/CM'2
.1
.0
0
i
.1
.2
0
6
.8
.9
1
9
.1
.2
1 .4
11 .6
-------
TABLE 14. AM ESTIMATE OF THE POTENTIAL COST TO THE AVERAGE BROADCAST STATION OF GUIDELINES LIMITING PUBLIC
EXPOSURE TO RADIOFREQUENCY RADIATION FROM AM, FM, VHF-TV, AND UHF-TV BROADCAST SOURCES IS GIVEN FOR 3 COST
LEVELS. THE AVERAGE ANNUAL CASH FLOW (CURRENT YEAR DOLLAR) COST, THE AVERAGE PRESENT (CONSTANT DOLLAR) VALUE
OF THE NET AFTER TAX COST AND THE MAXIMUM AND AVERAGE PERCENT REDUCTION IN NET PROFIT ARE SHOWN FOR
COMPLIANCE WITH 18 SPECIFIED GUIDANCE LEVELS. IT IS ASSUMED THAT FM STATIONS SELECT ONE OF FIVE COMPLIANCE
MEASURES (2 THROUGH 6) AND THAT COMPLIANCE COSTS (ANNUAL NET CASH FLOW) ARE SPREAD EVENLY AMONG FIVE ANNUAL
COHORTS OF STATIONS. NUMBERS ARE IN THOUSANDS OF DOLLARS. MICROWATTS PER SQ. CM IS ABBREVIATED UW/CM~2;
VOLTS PER METER, V/M.
GUIDANCE LEVEL
1 .
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP IX}
AVG PROFIT DROP C/.)
2.
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP <•/.}
AVG PROFIT DROP l'/.J
3.
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP C/.}
AVG PROFIT DROP ('/.I
4.
AVG ANNUAL CASH FLOH
AVERAGE PRESENT VALUE
MI\X PROFIT DROP C; >
AVG PROFIT DROP { *)
LOU
3.8
16.2
7.0
4.0
1 .9
8.1
5.8
2.0
1 .9
8.0
3.8
2.0
1 .8
7.7
3.6
1 .9
FM
MED
1 .
6.
28.
11 .
7.
10.
4.
17.
7 .
4.
20.
4.
17.
7 .
4.
50.
J.
16.
7 .
4.
AM
HIGH
LOU
UW/CM-2
7
2
7
0
9.
40.
16.
10.
7
6
4
.1
0.
4.
2.
1 .
.9
.0
.7
.2
UW/CM-2
2
7
7
4
6
25
10
6
.0
.1
.7
.2
0
2
1
0
.5
.0
.7
.6
UH/CM'2
1
3
6
3
S
24
10
6
.7
.3
.5
.0
0
1
1
0
.4
.8
.6
.5
UW/CM-2
9
5
3
1
5
22
10
5
.4
.9
.0
.7
0
1
1
0
.3
.5
.5
.4
MED
10.
1 .
5.
3.
1 ,
32.
0.
2
2
0
45.
0
2
Z
0
71 .
0
2
2
0
V/M
4
.9
9
.8
V/M
.7
.9
.4
.9
V/M
.6
.5
.2
.7
V/M
.5
.1
.0
.6
HIGH
1 .8
7.9
5.1
2.4
0.9
3.9
3.1
1 .1
0.7
3.3
2.9
1 .0
0.6
2.8
2.6
0.8
LON
26.
109.
3.
2.
20.
84.
2
1
17
72
2
1
12
54
1
1
0
4
2
0
,1
. 5
.5
.5
.3
.6
.2
.3
.9
.5
.6
.0
TV
MED
1 .
43
182
5
3
10.
31
132
3
2
20.
Z5
106
3
1
50.
19
80
2
1
HIGH
UW/CM-2
.4
.4
.4
.3
67.8
285.3
8.4
5.2
UW/CM-2
.5
.7
.9
.4
38.2
160.8
4.8
2.9
UW/CM-2
.3
.5
.2
.9
29.5
124.4
3.7
2.3
UW/CM-2
.0
.1
.4
.5
21 .8
91 .8
2.8
1 .7
-------
TABLE 14. (CONTINUED)
GUIDANCE LEVEL
5.
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP (X)
AVG PROFIT DROP ( X)
6.
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP ('/. >
AVG PROFIT DROP (.'/.}
7.
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP ('/.)
AVG PROFIT DROP ('/.)
8.
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP C/.1
AVG PROFIT DROP (X)
FM
LOW
1 .8
7.6
3.6
1 .9
* .8
7.5
3.6
1 .8
1 .7
7.4
3.5
1 .8
1 .7
7 .2
3.5
1 .8
MED
75.
3,
16,
7.
4,
100.
3
16.
7,
4.
ZOO.
3
15
7
3
300.
3
15
7
3
HIGH
LOU
UN/CM -2
.9
,5
,3
.1
5
22
9
5
.4
.8
.9
.6
0,
1 .
1 .
0.
,3
4
4
,4
UN/CM" 2
8
.1
.2
.0
5
22
9
5
.2
.0
.7
.4
0.
1 .
1 ,
0,
3
.4
p 4
,4
UW/CM-2
.7
.8
. 1
.9
5
21
9
5
.0
.4
.5
.3
0,
1
1
0,
.3
.4
,4
.4
UW/CM-2
.7
.5
.0
.8
4
20
9
5
.9
.9
.3
.2
0,
1
1
0,
.3
.3
.4
,4
AM
MED
87.
0
2
2
0
100.
0
2
2
0
141 .
0
2
2
0
173.
0
1
1
0
V/M
.5
.0
.0
.6
V/M
.4
.0
.0
.6
V/M
.4
.0
.0
.6
V/M
.4
.9
.9
.5
HIGH
0.
2.
2.
0.
0.
2.
2.
0.
0.
2,
2.
0.
0.
2
2
0
6
6
5
.8
6
.6
.5
8
,6
.6
.5
.7
.5
.4
.4
.7
LOW
11 .
48.
1 .
0.
10.
45.
1 .
0.
8.
33.
1 .
0
7.
30
0
0.
p 4
,1
4
,9
.8
,6
.4
.8
.0
.8
.0
.6
.3
.9
.9
.6
TV
MED
75.
16
68
2
1
100.
15
63
1
1
200.
10
45
1
0
300.
9
41
1
0
HIGH
UW/CM-2
.3
.8
.1
.3
18.3
77.1
2.3
1 .4
UW/CM~2
.1
.7
.9
.2
16.7
70.3
2.1
1 .3
UW/CM-2
.9
.9
.4
.8
12.0
50.6
1 . 5
0.9
UW/CM-2
.8
.2
.3
.7
10.8
45.5
1 .4
0.8
-------
TABLE 14. (CONTINUED)
GUIDANCE LEVEL
9.
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP ( '/.)
AVG PROFIT DROP ( '/, 1
1 0.
AVG ANNUAL CASH FLOI'J
AVERAGE PRESENT VALUE
MAX PROFIT DROP C/.1
AVG PROFIT DROP (.V.1
11 .
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP (X)
AVG PROFIT DROP C/.1
12.
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP < :.'>
AVG PROriT DROP <.•/.•>
LOW
FM
MED
HIGH
LOW
AM
MED
HIGH
LOI-I
TV
MED
HIGH
400. UW/CM-2
1.7 3.6 4.8
7.1 15.2 20. 5
3.4 6.8 9.1
1.7 3.8 5.1
500. UM/CM-2
1.7 3.6 4.8
7.1 15.2 20.4
3.4 6.8 9.1
1.7 3.7 5.0
600. UU/CM-2
1.6 3.5 4.7
6.9 14.9 20,0
3.3 6.7 8.9
1.7 3.7 4.9
700. UW/CM-2
1.6 3.4 4.5
6.7 14.3 19.3
3.3 6.5 8.7
1.6 3.5 4.8
200. V/M
0.3 0.4 0.5
1.3 1.9 2.4
1.4 1.9 2.4
0.4 0.5 0.7
224. V/M
0.3 0.4 0.5
1.3 1.9 2.4
1.4 1.9 2.4
0.4 0.5 0.7
245. V/M
0.3 0.4 0.5
1.3 1.9 2.4
1.4 1.9 2.4
0.4 0.5 0.7
265. V/M
0.3 0.4 0.5
1.3 1.9 2.4
1.4 1.9 2.4
0.4 0.5 0.7
400. UW/CM-2
7.3 9.7 10.7
30.7 41.0 45.2
0.9 1.3 1.4
0.6 0.7 0.8
500. UW/CM-2
7.2 9.7 10.6
30.5 40.7 44.9
0.9 1.2 1.4
0.6 0.7 0.8
600. UW/CM-2
5.5 7.3 8.0
23.1 30.8 34.0
0.7 1.0 1.1
0.4 0.6 0.6
700. UW/CM-2
5.5 7.3 8.0
23.1 30.8 34.0
07 1.0 1.1
0.4 0.6 0.6
-------
TABLE 14. (CONTINUED)
oo
GUIDANCE LEVEL
1 3.
AVG ANNUAL CASH FLOH
AVERAGE PRESENT VALUE
MAX PROFIT DROP (X)
AVG PROFIT DROP (X)
14.
AVG ANNUAL CASH FLOH
AVERAGE PRESENT VALUE
MAX PROFIT DROP (X)
AVG PROFIT DROP (X)
1 5.
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP
AVG PROFIT DROP (X)
16 .
AVG ANNUAL CASH FLOH
AVERAGE PRESENT VALUE
MAX PROFIT DROP (X)
AVG PROFIT DROP < X >
FM
ION
1 .
6 .
3.
1 .
1 .
6 .
3.
1 .
1 .
6.
3.
1 .
1 .
5.
2,
1 .
5
6
,2
6
5
5
2
6
5
.4
,1
.6
q
.8
.9
.4
MED
800 .
3.
14.
6 .
3.
900.
3.
1 4.
6.
3.
1000.
3.
13.
6 .
3,
2000.
2.
12,
5
3.
UH/CM
.3
.1
,4
.5
UH/CM
,3
0
.3
.4
HIGH
-2
4
18
8
4
-2
4
18
8
4
.5
.9
.5
.7
.4
.8
. 5
.6
LOW
0
1
1
0
0
1 ,
1
0
.3
.3
.4
.4
.3
,3
.4
.4
UH/CM- 2
.2
.6
.2
,4
4
18
8
4
.3
.3
.3
.5
0
1
1
0
.3
.3
.4
.4
UH/CM- 2
p 9
.3
.7
.0
3
16
7
4
.9
.5
.6
.1
0.
1
1
0
.3
.3
.4
.4
AM
MED
282.
0
1
1
0
300.
0
1
1
0
316.
0
1
1
0
447.
0
1
1
0
V/M
.4
.9
.9
.5
V/M
.4
.9
.9
.5
V/M
.4
.9
.9
. 5
V/M
.4
.8
.9
.5
HIGH
0
2
2
0
0
2
2
0
0
2
2
0
0
2
2
0
.5
.4
.4
.7
.5
. 4
.4
.7
.5
.4
.4
.7
.5
.4
.4
.7
LOW
5
23
0
0
5
23
0
0
5
23
0
0
0
0
0
0
.5
.1
.7
.4
.5
. 1
.7
.4
.5
. 1
.7
.4
.1
.7
.1
. 0
TV
MED
800.
7
30
1
0
900.
7
30
1
0
1000.
7
30
1
0
2000.
0
0
0
0
UW/CM
.3
.8
.0
.6
UH/CM
.3
.8
.0
.6
UW/CM
.3
.8
.0
.6
UH/CM
.2
.9
.1
.0
HIGH
"2
8.0
34.0
1 .1
0.6
-2
8.0
34.0
1 .1
0.6
-2
8.0
34.0
1 .1
0.6
-2
0.2
1 .1
0.1
0.0
-------
TABLE 14.
(CONTINUED)
GUIDANCE LEVEL
17.
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP C/.1
AVG PROFIT DROP (X)
18.
AVG ANNUAL CASH FLOW
AVERAGE PRESENT VALUE
MAX PROFIT DROP (.'/.I
AVG PROFIT DROP C/.1
LOU
FM
MED
HIGH
5000. UH/CM-2
1 .2
5.0
2.6
1 .2
2.4
10.4
4.9
2.6
3.3
14.0
6 .6
3.4
LOU
AM
MED
HIGH
708. V/M
0.3
1 .3
1 .4
0.4
0.4
1 .8
1 .9
0.5
0.5
2.3
2.4
0.7
LOW
TV
MED
HIGH
5000. UN/CM-2
0.1
0.7
0.1
0.0
0.2
0.9
0.1
0.0
0.2
1 .1
0.1
0.0
10000. UW/CM'2
1.1 2.3 3.2
4.8 10.0 13.5
2.5 4.8 6.3
1.2 2.4 3.3
1000. V/M
0.3 0.4 0.5
1.3 1.8 2.3
1.4 1.9 2.4
0.4 0.5 0.7
10000. UW/CH-2
0.1 0.2 0.2
0.7 0.9 1.1
0.1 0.1 0.1
0.0 0.0 0.0
-------
TABLE 15 . THE NUMBER OF FM STATIONS REQUIRING MEASURES TO COMPLY WITH GUIDELINES LIMITING PUBLIC
EXPOSURE TO RADIOFREQUENCY RADIATION IS GIVEN FOR 18 SPECIFIED GUIDANCE LEVELS. IT IS ASSUMED
THAT STATIONS SELECT ONE OF FIVE COMPLIANCE MEASURES (2 THROUGH 6).
GUIDANCE LEVEL
FIX1
FIX2
FIX3
FIX4
FIXB
FIX6
SUB-TOTAL*
TOTAL**
1 .
1 MICROWATT PER SQ. CM
N>
O
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
2. 10
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
3. 20
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
SFMT
MFMT
SFMT
MFMT
SFMT
HFMT
MICROWATT PER SQ.
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
MICROWATT PER SQ.
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
0
0
0
0
0
0
CM***
0
0
0
0
0
0
CM
0
0
0
0
0
0
637
1 4
637
14
637
14
1052
59
1052
59
1052
59
1021
65
1 021
65
1 021
65
1592
120
1 592
120
1592
120
1519
140
1 519
140
1 519
1 40
1028
1 15
1028
1 1 5
1 028
1 1 5
129
32
258
64
388
96
25
1 5
51
30
76
45
12
12
25
25
38
37
776
192
517
128
258
64
1 53
91
102
61
51
30
76
75
51
50
25
25
129
32
258
64
388
96
25
1 5
51
30
76
45
12
12
25
25
38
37
3263
390
3262
390
3263
390
2774
320
2775
320
2774
319
2149
279
21 50
280
21 50
279
3653
3652
3653
3094
3095
3093
2428
2430
2429
*TOTAL NUMBER OF STATIONS REQUIRING A FIX AT THE SPECIFIED GUIDANCE LEVEL
SFMT=SINGLE FM TOMER, MFMT=MULTIPLE FM TOWER
**FACTORS ASSIGNING STATIONS AMONG FIXES 4,5 AND 6 CREATE ROUNDING ERRORS.
***THE IIUMBEK OF STATIONS REQUIRING FIX 2 INCREASES AT GUIDANCE LEVEL 2
BECAUSE GUIDANCE LEVEL 1 REQUIRES MORE STATIONS TO ADOPT MORE COMPLEX
MITIGATION MEASURES.
-------
TABLE 15 . (CONTINUED)
GUIDANCE LEVEL
FIX1
FIXZ
FIX3
FIX4
FIXS
FIX6
SUB-TOTAL*
TOTAL**
4.
50 MICROWATT PER SQ. CM
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
5. 75
LON COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
6 . 100
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
MICROWATT PER SQ.
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
MICROWATT PER SQ.
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
0
0
0
0
0
0
CM
0
0
0
0
0
0
CM
0
0
0
0
0
0
818
83
818
83
818
83
733
62
733
62
733
62
686
55
686
55
686
55
500
86
500
86
500
86
345
86
345
86
345
86
286
1 04
286
1 04
286
1 04
4
7
8
14
13
21
3
6
10
9
16
1
2
4
6
26
42
17
28
8
14
18
32
12
2)
6
1 0
10
13
6
8
3
4
4
7
8
14
1 3
21
3
5
10
9
16
1
2
3
4
5
6
1352
225
1351
225
1352
225
1102
190
11 02
189
1102
190
984
1 76
984
175
985
175
1 577
1576
1 577
1292
1291
1292
1 160
1 1 59
1 160
*TOTAL NUMBER OF STATIONS REQUIRING A FIX AT THE SPECIFIED GUIDANCE LEVEL
SFMT = SINGLE FM TOIIER, MFMT = MULT IPL E FM TOHER
**FACTORS ASSIGNING STATIONS AMONG FIXES 4,5 AND 6 CREATE ROUNDING ERRORS.
-------
TABLE 15 . (CONTINUED)
GUIDANCE LEVEL
FIX1
FIX2
FIX3
FIX4
FIX5
FIX«
SUB-TOTAL*
IS)
7.
200 MICROWATT PER SO. CM
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
8. 300
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
9. 400
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
SFMT
MFHT
SFMT
MFMT
SFMT
MFMT
MICROWATT
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
MICROWATT
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
0
0
0
0
0
0
PER SQ. CM
0
0
0
0
0
0
PER SQ. CM
0
0
0
0
0
0
460
43
460
43
460
43
340
43
340
43
340
43
233
42
233
42
233
42
If, 6
77
166
77
166
77
108
69
108
69
108
69
80
58
80
58
80
s;i
0
0
0
1
0
2
0
0
0
0
0
0
0
0
0
0
0
0
1
5
1
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
2
0
0
0
0
0
0
0
0
0
0
0
0
627
125
627
125
626
125
448
1 12
448
1 12
448
112
313
1 00
313
1 00
313
100
TOTAL«»
752
752
751
560
560
560
413
413
413
»TOTAL NUMBER OF STATIONS REQUIRING A FIX AT THE SPECIFIED GUIDANCE LEVEL
SFMT=SIMGLE FM TOUER, MFMT=MULTIPLE FM TOMER
»«FACTORS ASSIGNING STATIONS AMONG FIXES 4,5 AND 6 CREATE ROUNDING ERRORS.
-------
TABLE 15 . (CONTINUED)
GUIDANCE LEVEL
FIX!
FIX2
FIXS
FIX4
FIXS
FIX6 SUB-TOTAL*
TOTAL**
1 0 .
500 MICROWATT PER SO. CM
IS)
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
1 1 . 600
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
12. 700
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
MICROWATT PER SQ.
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
MICROWATT PER SQ .
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
0
0
0
0
0
0
CM
0
0
0
0
0
0
CM
0
0
0
0
0
0
18R
43
188
43
188
43
162
39
162
39
162
39
134
38
134
38
134
38
64
50
64
50
64
SO
48
42
48
42
48
42
42
31
42
31
42
31
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
252
93
252
93
252
93
210
81
21 0
81
210
81
176
69
176
69
176
69
345
345
345
291
291
291
245
245
245
*TOTAL NUMDER OF STATIONS REQUIRING A FIX AT THE SPECIFIED GUIDANCE LEVEL
SFMT=SINGLE FM TOWER, MFMT=MULTIPLE FM TOWER
**FACTORS ASSIGNING STATIONS AMONG FIXES 4,5 AND 6 CREATE ROUNDING ERRORS.
-------
TABLE 15 . (CONTINUED)
GUIDANCE LEVEL
FIX1
FIX2
FIX3
FIX4
FIX5
FIX*
SUB-TOTAL*
TOTAL«*
13.
800 MICRONATT PER SO. CM
IS)
-c-
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
11. 900
LC1N COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
15. 1 000
im-i COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
SFMT
MFMT
SFMT
MPMT
SFMT
MFMT
MICROHATT PER SO.
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
MICROWATT PER SQ .
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
0
D
0
0
0
0
CM
0
0
0
0
0
0
CM
0
0
0
0
0
0
123
39
123
39
123
39
107
38
107
38
107
38
105
39
105
39
105
39
35
29
35
29
35
29
31
25
31
25
31
25
24
20
24
20
24
20
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1 58
68
1 58
68
1 58
6«
1 3R
63
138
63
1 38
63
129
59
129
59
129
59
226
226
Z26
201
201
201
188
18R
188
«TOTAL NUMBER OF STATIONS REQUIRING A FIX AT THE SPECIFIED GUIDANCE LEVEL
SFMT=SINGLE Ft) TOl-ltR, MFMT =MULTIPL E FM TOVIHR
**FACTORS ASSIGNING STATIONS AMONG FIXES 4,5 AND 6 CREATE ROUNDING ERRORS.
-------
TABLE 15 . (CONTINUED)
GUIDANCE LEVEL
FIX1
FIX3
FIX4
FIX5
FIX6
SUB-TOTAL*
TOTAL**
U.
2000 MICROWATT PER SO. CM
K)
In
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
17. 5000
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
18. 10000
LOW COST
ANALYSIS
MEDIUM COST
ANALYSIS
HIGH COST
ANALYSIS
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
MICROWATT PER SQ.
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
MICROWATT PER SQ.
SFMT
MFMT
SFMT
MFMT
SFMT
MFMT
0
0
0
0
0
0
CM
0
0
0
0
0
0
CM
0
0
0
0
0
0
56
22
56
22
56
22
16
8
16
8
16
8
3
0
3
0
3
0
1 0
6
1 0
6
1 0
6
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
66
28
66
28
66
28
16
8
1 6
8
16
8
J
0
3
0
3
0
94
94
94
24
24
24
3
3
3
*TOTAL NUMBER OF STATIONS REQUIRING A FIX AT THE SPECIFIED GUIDANCE LEVEL
SFMT=SINGLE FM TOMER, MFMT=MULTIPLE FM TOWER
**FACTORS ASSIGNING STATIONS AMONG FIXES 4.5 AND 6 CREATE ROUNDING ERRORS.
-------
TABLE 16. THE NUMBER OF AM BROADCAST STATIONS REQUIRING MEASURES TO
COMPLY WITH GUIDELINES LIMITING PUBLIC EXPOSURE TO RADIOFREQUENCY
RADIATION IS GIVEN FOR 18 SPECIFIED GUIDANCE LEVELS AT THREE COST LEVELS.
ACTUAL NUMBER OF STATIONS ESTIMATED TO REQUIRE MITIGATION MEASURE ADJUSTED
BY FACTORS GIVEN IN TABLE 5.
GUIDANCE LEVEL LOW COST MEDIUM COST HIGH COST
1 10.00 V/M 2311 3081 3928
2 31.62 V/M 2311 3081 3923
3 44.67 V/M 2310 3080 3927
4 70.79 V/M 2273 3030 3864
5 86.60 V/M 2246 2995 3819
6 100.00 V/M 2095 2793 3562
7 141.25 V/M 1856 2475 3156
8 173.18 V/M 1700 2266 2890
9 200.00 V/M 1690 2253 2873
10 223.87 V/M 844 1125 1435
11 244.91 V/M 831 1107 1412
12 264.55 V/M 776 1034 1319
13 281.84 V/M 773 1031 1314
14 300.00 V/M 773 1030 1314
15 316.23 V/M 762 1015 1295
16 446.68 V/M 710 946 1207
17 707.95 V/M 185 247 315
18 1000.00 V/M 87 116 148
126
-------
TABLE 17. THE NUMBER OF TV BROADCAST STATIONS
AFFECTED BY GUIDELINES LIMITING PUBLIC EXPOSURE
TO RADIOFREQUENCY RADIATION IS GIVEN FOR 18
SPECIFIED GUIDANCE LEVELS.
GUIDANCE LEVEL
1
2
3
4
5
6
7
8
9
10
11
12
13
14
1 5
16
17
18
1
10
20
50
75
1 00
200
300
400
500
600
700
800
900
1000
2000
5000
10000
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
MICROWATTS
PER
PER
PER
PER
PER
PER
PER
PER
PER
PER
PER
PER
PER
PER
PER
PER
PER
PER
SQ.
SO.
SQ.
SQ.
SQ.
SQ.
SQ.
SQ.
SQ.
SQ.
SQ.
SQ.
SO.
SQ.
SQ.
SO.
SQ.
SQ.
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
CM
819
246
183
102
73
60
30
19
13
1 0
5
4
3
3
2
0
0
0
127
-------
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