Understanding and Complying With the FCC’s New Rules on Analyzing RF Exposure
Earlier this year, the FCC changed the way amateurs need to analyze the RF exposure levels of their stations to determine whether a detailed evaluation is necessary. It replaced the peak envelope power (PEP) exemption table that was created specifically for amateurs with formulas based on effective radiated power (ERP) and separation distances that apply to all services. As discussed below, the result is that more amateurs will likely need to conduct detailed evaluations to confirm their operations comply with the agency’s RFE limits. It is important to note upfront that the limits themselves have not changed. The only change is to the methods used to determine whether a full evaluation is needed.
The revised rules apply initially only to new installations; they do not apply to existing antennas or stations until May 3, 2023, unless those installations are modified so as to affect their RFE characteristics, such as changing to a different transceiver with higher transmitter power, reconfiguring an antenna, or moving an antenna to a new location.1
Given the nature of Amateur Radio Service—in particular amateurs’ interest in testing the performance and functionality of new antennas, different antenna configurations, and various antenna locations—the FCC’s rule changes will likely have a significant and wide-ranging impact on their operations. Notably, amateurs will be required to make a number of additional calculations about the technical characteristics of their operations before they may commence operation and should keep records of their analyses.
This article is not intended to describe every aspect of the revised rules2 (or to offer legal advice), but to provide a general overview of the changes the FCC made to the exemptions that apply to amateur stations and to offer a few examples of how the changes might affect new installations.
What Are the Differences Between Compliance, Exemption, and Evaluation?
Before discussing the revised rules, it might be helpful to explain what the FCC means when it uses the terms “compliance,” “exemption,” and “evaluation.” The FCC has always required amateurs to comply with the agency’s rules that limit RFE. There is no change to this “compliance” obligation or to the RFE limits themselves; the agency changed only the way in which amateurs need to determine whether they must demonstrate compliance with the existing limits.
The FCC’s rules continue to include an “exemption” from the need for amateurs to conduct an “evaluation” to confirm that their proposed installations comply with the FCC’s RFE limits. But the parameters of the exemptions have changed, as have the methods of determining whether they apply. Generally, an exemption applies if the proposed installation meets certain criteria that the FCC has concluded will likely safeguard against excessive RFE. If
