FROM PROMISE TO FULFILLMENT, Part 7.


“God causes all things to work together for good”


This is a continuation of the story of Engineer F. M. Perry’s involvement with the construction and start-up operation of The World Christian Broadcasting Corporation’s international short wave radio station KNLS at Anchor Point, Alaska

______________________________________________________________________________


January 1982 -


After the Borough Public Hearing on September 21, 1981, some people of the Anchor Point area continued to have questions or complaints concerning radiation hazards that might be caused by the WCBC short wave radio station. The Borough officials, considering the matter closed, referred the letters they received to the WCBC attorney, Mr. C. B. Baldwin, with the thought that WCBC might help quell the turmoil by making some reasonable answers. At least one Anchor Point citizen, (representing a group of citizens) sent a 32 page hand written letter containing 28 specific questions to the Federal Communication Commission (FCC) in Washington, DC. A copy of the letter reached Bob Scott through the WCBC Attorney in Washington, Mr. Richard Zaragoza. The FCC treated the citizen’s questions seriously even as they were considering the WCBC application which they had just received. F. M. had previously answered some of the questions at the Public hearing in September. Consulting Engineer David Hudson replied to some of the questions, giving them good professional treatment. It is understood that Mr. Charles Breig of the FCC gave serious attention, requiring several weeks of work, to answering all of the questions. A letter dated December 19, 1981 from Attorney Richard Zaragoza shows the seriousness with which the FCC treated the questions. A part of Mr. Zaragoza’s letter is quoted below:


“December 29, 1981

Robert E. Scott, President

World Christian Broadcasting Corporation

P. O. Box 3857

301 South Pioneer Drive

Abilene, TX 79604


“Dear Bob,


            “Enclosed you will find the November 12, 1981 letter from Linda Feiler to the FCC. The letter is long. The questions are numerous and they do show a very deep and possibly very sincere concern about biological radiation hazards to people and to wildlife.


            “I just got off the phone with Charles Breig at the FCC who will in the next few weeks attempt to answer her questions point by point. The FCC is treating the matter seriously. The issue may come down to whether or not we have enough land to place a fence at appropriate distances around the transmitters/antennas. ......


            “You will also find enclosed a copy of Dave Hudson’s engineering statement as it relates to the environmental considerations as well as the Commission’s rule relating to the environment. What I am concerned about here is that our application not only be accurate as filed but also be up to date. For example, Dave represented in his statement that ‘Construction of the proposed facility has not been a source of controversy in the local community.’ While this statement may have been accurate when it was first drafted, he question I pose is wether it is still accurate. If not, perhaps we ought to file an amendment to the application updating this statement. .....


            “I am of the preliminary view that we should attempt to file some amendment or response before the FCC’s letter goes out so we can transform the FCC’s response to Ms. Feiler from simply a response to answers into an FCC statement in support of our application. ....


            “Very truly yours,


            Richard R. Zaragoza.


“Cc: F. M. Perry

        David Hudson

        C. R. Baldwin, Esq.”

_____________________________________________________________


By this time F. M. had received a copy of the long letter the Anchor Point citizen had sent to the FCC. Noting the concern expressed in Mr. Zaragoza’s letter of September 19, F. M. felt that, as Director of Engineering for the project, he should submit to Mr. Charles Breig of the FCC his recommended answers to the citizen’s questions. F. M.’s letter, directed to Attorney Zaragoza for passing to Mr. Breig, is reproduced below:


“World Christian Broadcasting Corp.

Box 378, Fort Valley Route

Strasburg, Virginia 22657

4 January 1982


“Mr. Richard R. Zaragoza

Fisher, Wayland, Cooper and Leader

1100 Connecticut Avenue, N. W.

Washington, D. C. 20036


“Dear Dick:


            `“I have read with great interest and some concern your letter of December 29, 1981 to Mr. Robert Scott and the accompanying letter of November 12,1981 from Linda Feiler to the FCC. Since I have visited the Anchor Point area three times now and testified at the Kenai Borough Planning Commission's public hearing mentioned in Ms. Feiler's letter, I may be able to shed some light on the background and meaning of Ms. Feiler's questions.


            “Since my first trip to the proposed station site at Anchor Point, Alaska in September 1980 I have sought to discover any Kenai Borough restriction or ordinance which might apply to our proposed project. I visited the Borough offices in Kenai in September 1980 and was informed that there were no zoning classifications or restrictions of any kind on the site or in the adjacent areas of the Borough. The Borough spokesman with whom I conversed said, "If it's all right with the FCC, it's all right with us."


            “Later, however, our attorney in Kenai, Mr. C. R. Baldwin, suggested that Chapter 21.12 of the Code of Ordinances, concerning "Noxious, injurious or hazardous uses" of land, might be interpreted by someone to apply to our use of land. (A copy of this chapter of the Code of Ordinances is attached.) Therefore, it was decided that we would "head off" any possible objection to our radio station on that ground by going to the Borough for a ruling. To our surprise, the Borough Planning Commission decided to make that ruling at a public hearing in Anchor Point on September 21,1981.


            “I testified at the public hearing. A copy of my report of the proceedings is attached. The ordinance was discussed by the members of the Planning Commission in public session. No one of the members could establish that the ordinance specifically applied in our case of land use for a radio station. It was moved, seconded and unanimously approved that the Planning Commission establish that the ordinance "MAY APPLY" in our case.


            “Our attorney, Mr. Baldwin, then requested that an "exception" be granted. After testimony by Mr. Baldwin and myself, statements from the public were heard. Three people requested that WCBC be deterred from building the radio station at Anchor Point making statements of their belief that the radiation from the station might be hazardous to health and might interfere with other radio communication in the area. Ms. Linda Feiler did not make any public statement at the hearing, although she may have been present. The owner and operator of a local FM/AM broadcast station made a statement refuting the earlier statements that the proposed WCBC station would be a health hazard or interfere with radio communication.


            “It was moved, seconded and unanimously approved that the Planning Commission

grant an exception to the ordinance allowing our construction of the proposed

radio station on the proposed site. At another public hearing on December 11,

1981, the Planning Commission considered an appeal to "strike out" this exception. I was not present at this hearing but I understand that the Planning Commission, by majority vote, allowed the exception to stand.


            “Below you will find my comments in answer to some of Ms. Feiler's questions. Some of the questions can only be answered by the FCC or by someone, such as Consulting Engineer David Hudson, who is a member of ANSI. I have not attempted to answer these questions:


            “Please note that in my comments and in our application to the FCC it is the ‘more strict radiation standards’ recently proposed by ANSI that have been used. We feel that we have made a ‘worse case’ assumption in locating the fence where we have shown it on the accompanying sketches. This is further explained in my attached comments. We should not have to enlarge our fenced-in land area unless the FCC decides to require a standard more strict than the new proposed ANSI standard.


            “Dave Hudson' s environmental statement was prepared with my help and the statement that the ‘construction of the proposed facility has not been a source of controversy in the local community’ was my recommended statement. The community of Anchor Point has been aware since the property was purchased in 1979 that an international broadcast station was planned for the site. In my opinion most people of the community have been aware of the plans.


            “My presence in the community for more than a week in September 1980, for several days in May 1981, and again for a few days in September 1981 became known throughout the community even while I was there. I was approached by a number of people, some asking for jobs and some expressing approval of the project. I accepted bids tor portions of the construction work and discussed the project with a number of possible contractors in the local community. To my knowledge, no opposition was expressed until the public hearing dealt with the so-called ‘hazardous use ordinance.’


            “It is clear that we now have some opposition and our statements in the FCC application might be updated to that effect.


            “As you say, Ms. Feiler's letter is long. My comments are also long. I am enclosing copies of other material which makes my presentation long indeed! I hope you can glean material which will be useful to Mr. Breig in answering the letter from Ms. Feiler.


            “Sincerely,

 

            “F. M. Perry

            Director of Engineering.”

___________________________________________________________


The following questions are quoted from a letter from Ms. Linda Feiler to the FCC dated November 12.1981. The comments are those of Mr. F. M. Perry, PE, Director of Engineering for the World Christian Broadcasting Corporation.


Question #1: "Is or is there not a health hazard near or in front of the two Dipole 611 antennas transmitter? (Please refrain from using the word MAY.)”


Comments on Question # 1: There is only one Model 611 antenna in our FCC

application. Ms. Feiler's question concerning “two Dipole 611 antennae" probably refer to the material which we placed on file with the Kenai Borough Planning Commission and which was given to all interested people of the community at the public hearing at Anchor Point on September 21, 1981. In addition to a sketch showing the antenna layout as submitted to the FCC (which shows one TCI Model 611 curtain dipole antenna hung between two towers and one TCI Model 516 horizontal log periodic antenna), we gave out a sketch showing our possible expansion plans some years hence. This latter sketch showed two sets of two each Model 611 curtain dipole antennae. Each set contained two Model 611 antennas hung on three towers. These sketches also showed a safety enclosure fence around the antennas. Along with the sketches we made available a written narrative statement which concluded that ‘outside the fenced-in area there will be no health hazard whatsoever. This statement was supported by a four page set of my calculations showing that "the power density ot the radiation from the WCBC antennas at any point outside the protective fence at all times will be well below the standard for safe continuous exposure set by the American National Standards Institute.” (I refer here to the new standard recently proposed by ANSI.)


In addition to my calculations, we also placed on file with the Kenai Borough Planning Commission a statement by Consulting Engineer David Hudson which concluded that "the expected power flux density at the fence will not exceed 1.6% of that allowed by the new ANSI standard.” (Copies of the above mentioned documents are attached.)


Ms. Feiler's request that the answer to her question not use the word "MAY" probably refers to the minutes of the public hearing mentioned above. The Kenai Borough Planning Commission made a determination at that hearing that the so-called "hazardous use ordinance" (Chapter 21.12 of the Code of Ordinances) "MAY APPLY" to the use of our land for a radio broadcast station. If the Planning Commission had determined that the ordinance did not apply, the hearing would have been over at that point. I believe it is the use of the word "MAY" in the Kenai Borough Planning Commission public hearing to which Ms. Feiler objects. At no time during the hearing did we say that there "may" be a health hazard outside of the fenced-in area shown on the sketches.


In my professional opinion there will not be a health hazard near or in front or the two Model 611 antennas to anyone who remains outside the fenced-in area.


Question # 2: "Can or will the FCC suggest putting this type of Dipole 611 antennas towers in an area that is steadily increasing in population with a heavy accent on State Recreation Parks and the Anchor River? "


Comments on Question # 2: Since the power density of the radiation from the WCBC antennas at any point outside the protective fence at all times will be well below the standard for safe continuous exposure set by the American National Standards Institute, there need be no restrictions on activities by the population in areas surrounding the station.


Question # 3: "How many Dipole 611's (2 antennas supported by 3 towers) are there now in existence? Where are they located? How long have they been in operation?"


Comments on Question # 3: I am awaiting information from TCI. the manufacturer of the Model 611 antenna in order to answer this question specifically. However, it should be noted that similar curtain dipole antennas constructed by various organizations or individuals have been in use for a number of years. KGEI in San Francisco has a relatively "old" curtain dipole antenna that has been in use for a number of years in the highly populated San Francisco Bay area.


Question # 4: "What tests have been done to test the safety or hazards for plant, animal, insect or waters within the restricted areas near the Dipole 611 antennas?"


Comments on Question # 4: The ANSI Standards apply to human beings and to animals of the same order of size as human beings. The standards would be less severe for animals of smaller size since they are a smaller portion of a wavelength in size compared to the wavelengths to be used. I understand the standards are based on test data. (Perhaps Consulting Engineer David Hudson, who is a member of ANSI, can supply some details of the test data available.)


The entire "restricted areas" near WCBC’s Model 611 antennas will be on property totally owned or leased by WCBC and it will be entirely fenced-in.


Question # 5: "What test have been done to insure the safety of the above mentioned (plant, animal, insect or waters) outside the restricted area (near fence and outward from the fence)?”


Comments on Question # 5: See comments to question # 4, above. By ANSI

standards, the area at the fence line and outside the fence line will be safe for continuous exposure of humans and animals.


Question # 6: "Have these tests been routinely carried out since the existence of the first Dipole 6ll?"


Comments on Question # 6: I am awaiting information from TCI, the manufacturer of the Mode161l curtain dipole antenna, concerning the history of the antenna design. I am told by TCI that the RF radiation characteristics of each TCI antenna which is correctly erected has been measured to be essentially the same as those specified on the Model 611 specification sheet (copy attached). This means that the TCI Model 611 antenna, if erected correctly, will perform as our calculations predict and that the protective fence as indicated on the WCBC sketch will be adequate. Field strength measurements to confirm the adequacy of the protective enclosure will be made on the WCBC antennas before they are placed in regular operation.


Question # 7: "How much electricity will be needed to operate the Dipole?”


Comments on Question # 7: The total electric power that will be required from the Homer Electric Power Association (for one 100 KW transmitter) will be approximately 250 KW. The total RF power delivered to the Model 611antenna will be approximately 100 KW.


Question # 8: "How high and how wide an area will the Dipole 611 accommodate? (Include height of safety lights)."


Comments on Question # 8: Each of the two towers required by the initial WCBC Model 611 antenna will be 350 feet high. The two towers will stand 370 feet apart. The area necessary to accommodate the antenna will be that shown on the sketch (fenced-in area extending 750' in front of the antenna and 450' to the sides and rear of the antenna.)


Question # 9: "What is the standard for safety for the installation of this tower (area near and around it)? When were the standards updated, begun, and how often are they updated? Please begin with the first Dipole 611 (1930's ?) to 1981. We are concerned primari1y with radiation hazards. No. of ft. 1940 -1981."


Comments on Question # 9: The commonly accepted safety standard for non-ionizing radiation exposure is that promulgated by the American National Standards Institute by the C95 Committee. It has been incorporated by the Department of Labor into the OSHA Regulation No. 1910.97. The standard stipulates that, in the range from 3.0 to 30 MHz, continuous exposure should not exceed: RFPG - 900/f2, where RFPG (Radio Frequency Protection Guide) is

given in milliwatts per square centimeter power flux density and f is in MHz. In our case the most stringent RFPG occur at 21.75 MHz and is equal to 1.90 mW/cm2.


The standard applies to any antenna whether it be an AM or FM broadcast station antenna, a TV station antenna, a citizens band radio antenna, or an international short wave station antenna such as the Model 611. Consult1ng Engineer David Hudson may be able to provide the history of the ANSI standard.


Ms. Feiler may be concerned that the standard might be changed again in future years making our presently proposed fenced-in area inadequate to protect the population. Perhaps Consulting Engineer David Hudson can comment on this possibility.


Question # l0: "Just what is the difference between the radiation we fear and the radiation emitted from the Dipole 61l?"


Answer to Question # 10: The radiation emitted from the Model 611 curtain dipole antenna is non-ionizing radio frequency radiation just like that of any other radio transmitting antenna. It is not ionizing radiation produced by atomic reactions, decaying isotopes, and radioactive substances. It is electromagnetic radiation similar in nature to that emitted by microwave ovens, commercial TV and radio broadcasting stations, and citizen band radios. A recent article in IEEE Spectrum (December 1980, page 51) pointed out that almost everyone is continuously exposed to small levels of such radiation from the natural thermal radiation of the environment. A substantial fraction of the population receives higher than average exposure because of their use of two common radio frequency radiation sources: microwave ovens and citizen's band radios.


The maximum leakage radiation from microwave ovens is limited in the design and manufacturing process to specified values considered to be safe to the occupants of the kitchen. The power of CB radio transmitters is limited so that the radiation received by the operator does not exceed values considered to be safe.


The RF radiation from the Model 611 curtain dipole antenna falls off rapidly with distance from the antenna. The RF radiation at the fence line will not exceed 1.6% of that allowed by the ANSI standard for continuous exposure. As the distance beyond the fence line increases the radiation continues to fall off rapidly to negligible amounts.


A resident of Anchor Point will receive far greater radiation from his own Citizen's Band transmitting antenna than he will receive from WCBC's Model 611 antenna. This statement is based on the following: IEEE Spectrum, December 1980, pages 51 and 52 states that a "CB radio, whose power is limited by law to less than 7 watts, can produce whole-body average radiation of up to 70 microwatts per square centimeter." My calculations indicate that the power flux density of the Model 611 antenna radiations at one mile from the antenna and 6 feet above ground will be only 0.24 microwatts per square centimeter, or only 0.34% of the radiation possible from the citizen's band transmitting antenna.


Question # 11: "Since many of us are now experiencing interference on our radios and televisions are we to assume that once again we will be plagued with more interference?"


Comments on Question # 11: The so-called "interference problem" encountered with radio and television receivers may not be "assumed" to be the fault of nearby broadcast stations. It may be due to any one of many things, including poor selectivity characteristics in the receiver. The WCBC station at Anchor Point will attenuate all spurious emissions as required by the FCC rules and regulations. This should allow full compatibility with the radio and TV receivers of the community.


Should anyone in the community have a problem with their receiver which they think is caused by the WCBC station, it will be the policy of WCBC to provide assistance in solving the problem.


Question # 12: "Is it true that it is up to the already existing public to go through the time and expense of alleviating present and newly found problems from such radio transmitters as local radio stations and the Dipole 611?"


Comments on Question # 12: If the local radio station is at fault, it should make correction. See answer to question # 11 above.


Question # 12: “If in future years the radiation restricted area increases, will we be forced to close down parks and restrict fishing or will the towers (Dipole 611's) be stopped or forced to move?"


Comments on Question # 12: WCBC has no right to "close down parks and restrict fishing.” The construction of the WCBC radio station on the proposed site will not close down any parks or restrict any fishing. Under present construction plans or under any conceivable future expansion plan, WCBC has no desire to "close down parks or restrict fishing" nor is it conceivable that WCBC could force such action.


Question # 14: "Is the FCC familiar with tests or any current data involving the safety standards as accepted from any other nations, such as Germany, Switzerland, Russia, England etc.? Please submit any information possible."


Comments on Question # 14: I am not familiar with the standards of other countries.


Question # 15: "Will the FCC please inform us as to whether transmitters such as the Dipole 611 were bombed during past wars?"


Comments on Question # 15: I have no certain knowledge. But I doubt that any international broadcast station located on U. S. soil has ever been bombed as a result of enemy war action.


Question # 16: "Is it true that a hostile foreign nation is capable of "beaming in" on the Dipole 611 waves, rays (or ?) or transmission and send a bomb on this wave or ray? (Please excuse me if my term is inaccurate)."


Comments on Question # 16: It is possible for broadcast stations to be used as "homing beacons" and as guiding references for missiles. However, it is my understanding that broadcast stations would be required to shut down in the event of hostile threat in accordance with national defense plans. It should also be noted that modern war missiles do not require radio signals to find their targets. The location of the proposed radio station is no more a military secret then that of any other broadcast station.


Question # 17: “If any damages are incurred from the Dipole 611 at any date after its installation,does the FCC, the Dipole 611 manufacturers, the Borough, or the World Christian Broadcasting Corp. become responsible for these damages both monetarily and otherwise?"


Comments on question # 17: I will leave this for comment by the attorneys.


Question # 18: "Is the manufacturer of the Dipole 611 still in existence? Please send name and address."


Comments on Question # 8: An antenna similar to the Model 611 curtain dipole

could be purchased from a number of manufacturers, or it would be fabricated on site by personnel of the WCBC. However, the specific Model 611 is a proprietary product of Technology for Communications International (TCI), 1625 Stierlin Road, Mountain View, CA. 94043. At present WCBC plans to purchase the proprietary antenna from TCI.


Question # 19: "Will a log be kept on current standards, tests administered by the FCC, and results, for the interested public of the Anchor Point area? Will these be made accessible to us?"


Comments on Question # 19: During the construction of the Anchor Point station all equipment will be tested and adjusted to assure compliance with the terms of the FCC construction permit, the technical provisions of our application to the FCC, and the FCC rules and regulations. Complete logs of the tests and their results will be kept for inspection by the Engineer-in-charge of the FCC Alaska radio district. After operation of the station has begun, the performance of the equipment will be constantly monitored and logged for FCC inspection. The test results of these logs can be made available for perusal by the general public within the bounds of practicability.


Question # 20: "Does the FCC upon getting the required approval from the Borough, check over maps and all other data supplied to the non-electrica1 engineers--general public borough assembly group authorized to vote on these matters? Are updated maps required?”


Comments on Question # 20: This question seems to be based on the assumption that the FCC depends upon the judgement of the Borough Planning Commission to provide approval of the proposed radio station. It should be noted that WCBC arbitrarily approached the Borough Planning Commission to ascertain if the "hazardous use ordinance" applied to land use for radio transmitting purposes. No other radio transmitting stations had ever approached the Borough Planning Commission concerning the ordinance, and no radio transmitting facility, to my knowledge, had ever been accused of violating the ordinance. There are a number of radio broadcasting stations in the Borough and there have been, in times past, such installations as "White Alice," scatter communication facilities, early warning radar stations, etc.


WCBC has submitted an application to the FCC with complete back-up data. The FCC does not depend upon the Borough Planning Commission and their "non-electrical" engineers to judge the accuracy and integrity of the application. The FCC and the Borough Planning Commission serve separate complementary functions and are not interdependent.


WCBC submitted to the FCC the most updated map of the area which could be located. WCBC personnel surveyed the Anchor Point area with map in hand and concluded that the map to be submitted included all necessary and important features.


Question # 21: "Please look at map provided in packet. This is a copy. Since there is a radiation hazard area and a radiation restricted area and a 450' zone behind the towers how can there be no radiation at the sides of the pie? (This question was accompanied by a sketch which shows an "area restricted to residences approx. 1/2 mile radius," and a "radiation hazard area, radius 1,516 feet".)


Comments on question # 21: Some weeks prior to the public hearing and before we knew there was to be a public hearing, I submitted some calculations and sketches to our attorney, Mr. C. R. Baldwin, in Kenai. These calculations and sketches were made by me and they indicated an area that might be restricted to residences within a radius of approximately 1/2 mile in front of the antennas, and an area of possibly more intense radiation with a radius of 1,516 feet in front or the antennas. The dimensions of these possibly hazardous areas were based on preliminary information and were purposely conservative because at that time (1) I did not know what the new ANSI standard for safe continuous exposure would be, and (2) I did not know the characteristics of the Model 611 antenna near field radiation pattern. It was intended that these sketches be tentative and subject to correction. However, copies were filed with the Kenai Borough Planning Commission when we asked for a determination concerning the applicability of the "hazardous use ordinance". Apparently Ms. Feiler obtained a copy of this material from the Planning Commission.


After the new ANSI standard and the Model 611 antenna characteristics became known to me, I made new calculations and new sketches reducing the possible radiation hazard area to a radius of 750' in front of the antennas and 450' to the sides and rear of the antennas. I presented these new calculations and sketches at the public hearing and requested that the previously submitted calculations and sketches be discarded. After some questions before the public hearing, the new calculations and sketches were accepted by the Planning Commission.


Referring to the obsolete sketch included with Ms. Feiler's question, her question is a reasonable one. There is some radiation at very close range at the sides and rear of an antenna like the Model 611. The new sketches take this into account by establishing the protective fence line 450' to the sides of the "pie" and 450' behind the antennas. The WCBC transmitter/studio/office building will be located just beyond this fence.


Question # 22: "What will animal, plant or insect life look like 20 or 30 years after being subjected to this radiation?"


Comments on Question # 22: There is no reason that this electromagnetic radiation (non-ionizing in nature) will cause changes in animal or plant life as does ionizing radiation over a period of years. Kenai Borough in past years has had some installations which emitted more intense RF radiation than the WCBC station will emit (such as tropo-scatter communication facilities and early warning radar facilities). In addition there are numerous radio broadcast stations, microwave links, and other radio communication facilities (including amateur and citizen's band stations) radiating into the area at the present time. Apparently there has been no effect from this RF radiation on plant, animal, and insect life in the Borough.


Question # 23: "Is it normal for a broadcaster not to consult with local FCC officials and go ahead and apply for forms and licences from officials in Washington? (If not, why in this case?)"


Comments on Question # 23: Yes, it is normal. I understand that local FCC officials are brought into the station application process at the discretion of the Washington headquarters. The FCC rules and regulations require WCBC to notify the local FCC officials in Alaska when construction starts and to keep local FCC officials informed of construction progress and tests so that inspections may be made by the local officials.


Question # 24: "Who and in what bureau in FCC is investigating safety standards? Please advise us as to who it is: name, person/s in charge and answer the following A, B, C.


“(A) Are there or have there ever been any safety standards set for the Dipole 611 antenna (manufactured by T. C. I. Tech. for Com. Intr.) by the FCC?


“(B) Does ANSI work with the FCC in setting up these safety standards. If so, could we have the name and address of heads of these bureaus and specific officers assigned?


“(C) Is there or have there been any recent changes in regulations concerning the Dipole 611 ant. safety: specifically in minimum distances from the tower where there is NO HARMFUL RADIATION? What are these distances in relation to this tower and antenna operated at 100,000 w.?"


Comments on Question # 24: The safety standards for the TCI Model 611 curtain

dipole antenna are the same as those for any other transmitting antenna whether for AM, FM, TV broadcast stations, citizen band stations, amateur band stations, etc. because the standards are expressed in terms of maximum allowable power flux density in the atmosphere. When applying the standards to specific antennas the minimum distances where there is No Harmful Radiation becomes a function of the frequency used, the power input to the antenna, and the directional characteristics of the antenna.


There has been a recently proposed change in ANSI standards. The proposed new ANSI standards were used in establishing the minimum distance from the WCBC Model 611 antenna above which distance there is no harmful radiation. This minimum distance increases with frequency and is greatest at the highest frequency of transmission. The highest frequency at which WCBC expects to transmit is 21.75 MHz. At 21.75 MHz the minimum distance for safe continuous exposure is calculated to be 550 feet. This minimum distance is required in the center of the antenna beam at a height of 6 feet above horizontal ground level. The minimum distance in all other directions from the Model 611 antenna is less than 550 feet.


We established the safety fence line at a 750' radius in front of the antenna thus providing a 200' safety factor. We established the safety fence line to the sides and rear of the antenna at 450' which is 60% of that established for the center of the main antenna beam. This will give a reasonable safety factor to the sides and rear of the antenna.


The antenna will be tested before the station goes on the air to confirm that the safety factors are maintained as intended.


Question # 25: "Frequency Interference. Dennis Stoneburg--in interview--FCC Anchorage, AK--Signals from the Dipole might interfere with CB channels operating at 27 MHz and single sideband channels operating at 200 MHz – As citizen band frequencies are used as a secondary communication system, second only to the telephone in this area--and in the trucking and fishing industry here, what are the possibilities of this frequency interference occurring?


“(A) At what distances from the tower would this occur'? Norman Flotke--Law Enforcement--FCC Anchorage AK--telephone conversation--"Frequency interference problems can show up on stereo speakers." When mentioned that a State Trooper Frequency-Modulator Repeater Station was within 1 1/2 miles W. by NW of Dipole, in direct line with western transmission or the Dipole, He said he did NOT KNOW if this would interfere or not. Mr. Stoneburg also DID NOT KNOW.


“(B) Could the FCC Wash. DC. be of help in these questions? We NEED SOME HARD DATA TO GO ON. Please give NAMES & POSITIONS OF THOSE involved in answering questions.


“(C) Please indicate distance from antenna that this problem will occur? There are nearly forty (40) people living within 3 miles of the Dipole (proposed site) at present and the actual town site lies 3 1/2-4 miles Northwest of the site. Any growth of the town site to the South or East will bring it closer to the tower."


Comments on Question # 25: The transmitting frequencies of the WCBC station

to be established at Anchor Point will be as assigned by the FCC and will always be within the following frequency bands:


5.95 to 6.2 MHz.

9.5 to 9.775 MHz.

11.7 to 11.975 MHz.

15.1 to 15.45 MHz.

17.7 to 17.9 MHz.

21.45 to 21.75 MHz.


The frequency will be monitored at all times and controlled to remain within 0.0015 percent of the assigned frequency. Spurious emissions shall be attenuated to the level or below the level required by the FCC rules and regulations. WCBC will be purchasing the finest transmitting equipment available. Equipment of similar manufacture is in satisfactory operation at many locations throughout the world without causing interference with other radio services.


Perhaps it should be pointed out that one purpose of the rules and regulations of the FCC is to guard against interference among the various FCC authorized radio services.


In my experience as a radio engineer I have found that it is possible for a poor quality receiver (one with poor front end selectivity) to be de-sensitized by a very strong signal on another frequency. The result is that the ability of the receiver to pick up weak signals is inhibited. This occurs only when the receiver is in very close proximity to the transmitting source and is due to the poor design of the receiver. It is impossible to forecast whether any examples of this problem will occur. If it does, WCBC personnel will assist to the extent possible to alleviate the problem.


A stereo audio amplifier/speaker system is not designed to pick up and detect AM radio signals such as those transmitted by WCBC at Anchor Point. However, in my experience I have found that audio amplifiers can sometimes inadvertently pick up radio signals and detect them so that the audio modulation is then heard in the speakers. When this occurs it is a mal-function of the audio amplifier and can be prevented by minor changes in the amplifier circuitry.


I personally journeyed to Anchor Point three times (the last time in September 1981) for the purpose of locating any other radio communication facility in the area and of investigating any possibilities of interference from our WCBC short wave transmitting facility.


I did not find a "State Trooper frequency modulator repeater station" in the area. However, approximately in the location mentioned by Ms. Feiler (about l 1/2 miles WNW of our proposed antenna location) I found a tower 268' tall with base at 250' altitude. The tower was located at 59 degrees, 45 minutes, 22 seconds latitude and 151 degrees, 46 minutes, 21 second E longitude. There was no equipment installed on the tower except an aircraft clearance light.


Inquiry in the area revealed that the tower belonged to the State of Alaska, Division of Telecommunications Systems. I contacted by telephone Mr. Mel Helverson of the Division's Anchorage office and made an appointment to see him the following day. Upon visiting the Division's headquarters at 5900 East Tudor Road in Anchorage, I was greeted by Mr. Herb Holman and Mr. John Marrone. I informed these men that I was somewhat concerned about the possibility that our proposed station might interfere with equipment they might plan to install on the tower.


Mr. Holman explained that the tower was to eventually support "straight through" microwave relay equipment to carry TV programming from a relay point at Ninilchik to the north to the Homer and Seldovia areas to the south. The receiving frequency of the relay is to be in the 6 GHZ band and the transmitting frequency is to be in the 2 GHZ band. The intermediate frequency of the repeater equipment is to be 70 kHz. He said that a TV translator might be installed on the tower eventually to distribute TV service to homes in the Anchor Point area. Mr. Holman and I agreed that there is no likelihood of interference between the two installations. If there should be interference we agreed to work together to alleviate it.


Question # 26: “What are the locations of all Dipole 611 antennas that have been submitted for licencing under the jurisdiction of FCC and were approved and built? Also please add those that were not APPROVED and the reasons why."


Comments on Question # 26: I am awaiting information from TCI concerning their distribution of the Model 611 antenna.


Question # 27: "How does the FCC go about determining what is a remote site and what is not?"


Comments on Question # 27: As far as I know, there is no established criterion that a broadcast transmitter site be "remote". In the environmental statement included in our FCC application we termed the area "relatively remote from developed areas" meaning, as the accompanying map indicated, that there are no housing developments in close proximity to the site. The term remote is, of course, a relative term. Ms. Feiler's statement that "there are nearly forty (40) people living within 3 miles of the Dipole (proposed site)" seems to me to add substance to our statement that the site is "relatively remote from developed areas". However, Ms. Feiler seems to object to the use of the term "remote" with respect to our proposed site.


We also stated in the environmental statement that "it is unlikely that the adjacent marsh areas will ever be inhabited". Viewing other such marshy muskeg areas throughout the Borough of Kenai we saw none which were being drained or filled to support housing. However, should anyone desire to inhabit the marshy area immediately adjacent to the WCBC station, there is no reason they should not do so.


All of the owners, except one, of land immediately adjacent to WCBC property have expressed approval of the WCBC land use. One owner of adjacent land expressed dis-approval on grounds that his property might decrease in value and that he might be denied access rights. He has been assured that WBBC will provide the access he needs to his land.


Comments by:

F. M. Perry, PE,

Director of Engineering,

World Christian Broadcasting Corporation.

_____________________________________________


Finally the FCC accepted the environmental statement prepared by David Hudson and filed in the WCBC application. This environmental statement is reproduced below:


WORLD CHRISTIAN BROADCASTING CORPORATION, NEW INTERNATIONAL BROADCAST STATION


ENVIRONMENTAL STATEMENT David Hudson


“The following narrative statement is submitted pursuant to Section 1.1311 of the FCC Rules. The proposed station site is 3.8 miles southeast of the village of Anchor Point on a plateau which slopes gently upward from the shores of Cook Inlet on the west. The Anchor River cuts through the plateau running a northwesterly direction into Cook Inlet at Anchor Point. The Anchor River passes about one-half mile south and east of the antenna site forming a narrow valley 100 feet or more below the level of the surrounding plateau. The Sterling Highway is built along the bank of the Anchor River and passes within 0.5 mile of the site.


“The antenna site lies at an altitude of 300 feet above mean sea level and consists of 71.35 acres, one third of which is marshland (referred to as muskeg) and two thirds of which is forested. The site is essentially flat. The trees of the forested area are Alaska spruce, averaging about 50 feet in height. The marshy area, averaging 5 to 10 feet lower than the forested area, is covered by tufted grass growing in several inches of water during most of the year. Water is held in these marshy areas by a layer of clay "hardpan" which lies 3 to 5 feet below the surface. There is no permafrost beneath the surface of the land in this area. The land has never been cleared or tilled.


“Access to the site is provided by an existing gravel road which leaves the Sterling Highway about 3.5 miles southeast of Anchor Point village. This road will be improved and extended to run along an established right-of-way along the southern border of the station site.


“Power to the site will be provided by overhead lines from existing facilities in the vicinity operated by the Homer Electric Association, Inc. of Homer, Alaska. A moderate-size building will be constructed on the site for the transmitter and studio for the station. Housing for the staff is available in the villages of Anchor Point and Homer.


“Although this area of the Kenai Peninsula was opened to homesteading more than 20 years ago and much of the area is now privately owned, wildlife such as moose, bear, and numerous smaller game still roam freely through the area. The two antennas to be operated on the site will not be hazardous to such wildlife which may roam around the site. Appropriate fencing will be constructed around the antenna structures themselves, to ensure safety.


“The proposed site was chosen because it is both relatively remote from developed areas and quite suitable to the mode of propagation to be used. It is unlikely that the adjacent marsh areas will evel" be inhabited. The construction of the building and antennas will not disturb existing land use in the area. Trees will be cleared only as necessary to allow space for erecting the antennas, and to provide adequate clearance in front.


“There are no zoning classifications or restrictions of any kind on the site or in the adjacent areas of the Borough of Kenai. No building permit is required from the Borough of Kenai or the State of Alaska. Construction of the proposed facilities has not been a source of controversy in the local community. [Note: The controversy in the local community was evident only after this environmental statement was already filed with the FCC application. FMP]


“The only perceived unavoidable adverse environmental effects consist of the

visual impact of the towers and antennas. No steps to minimize the visual impact appear feasible. Because the antenna structures do not require extensive alteration of the land, there will be no significant defacement or erosion. The buildings will not require more than standard attention to good construction practices. There are no building regulations for the area.


“To the extent necessary for the footings and erection of the towers and buildings, the area will be cleared in such a way that no large areas will be exposed and the useful trees and underbrush will be preserved to the greatest extent possible. Marshy areas of the site will be avoided in the construction of antenna tower foundations since such areas are susceptible to frost heaving. Tower foundations will be constructed in nonfrost-susceptible soil in the forested areas of the site where good drainage is indicated. All tower and building foundations will be designed by a competent structural engineer who is throughly familiar with local soil, seismic and wind requirements.


“There is no feature of the site which has special environmental significance. It is not a wilderness area, wildlife preserve, natural flyway for birds, or a site of scenic, cultural, historic, architectural, archeological or recreational value. It is not a historically significant site listed in the National Register of Historic Places. No substantial change will occur in the character of the land utilized. There will be no significant deforestation, water diversion, wetland fill, or other extensive change of surface features. There will be no continuing pattern of human intrusion into any wilderness area, wildlife preserve or other like area.


“Accordingly, applicant submits that a grant of the proposed radio station authorization will not have any significant adverse environmental effect.”


810804 FIGURES 4A and 4B. End of Environmental Report.

_______________________________________________________


During January 1982, the FCC’s Mr. Charles Breig, assigned to evaluate the WCBC application for a construction permit, was engaged in deciding what specific requirements to apply to WCBC to protect the Anchor Point public from the hazards of RF radiation from the short wave antennas. The fact that high powered short wave transmitting antenna beams can present safety hazards to the public was not denied by anyone. The debate was about what size the protective (fenced-in) enclosure around the antennas must be to protect the public from the hazardous radiation. Speculation during early planning had been rampant about how much fenced-in area would be required around the antennas because the power output and the antenna types had not yet been decided. But when the FCC application was finally submitted, transmitter power and antenna type were specified and a specific plot plan was submitted showing the area required and the exact placement of the fence to protect the public from RF radiation. F. M.’s calculations were the basis for the WCBC plot plan. The FCC, having never had a broadcasting configuration quite like this one to evaluate, took time and effort to check F. M.’s calculations. And they felt somewhat under stress in evaluating the WCBC plot plan because of the community opposition to the station on grounds of an RF safety hazard. (Of course, F. M. had never before designed a high powered short wave installation so he had consulted with and gotten the help of several experienced engineers in doing so.)


During this time also the citizens in active opposition to the station grew in number. The citizen who sent the first long letter to the FCC learned the name of the FCC official evaluating WCBC application, Mr. Charles Breig, and wrote a letter directly to him enclosing the personal opposition letters of about 14 or 15 citizens of the Anchor Point area. Some quotes from the letters follow:


            “The Anchor Point area has grown rapidly and is continuing to grow. We are not a bush area any longer. As long as there is a shred of doubt as to the safety and health of our people, the birds that will fly into it, and other wild life we enjoy - why not put it in a remote area? KGTL increased their power and subsequently knocked out channel 7 and badly distorted reception on the other stations on my TV. ... Just what will a more powerful station do? ... I am not against the station per se. but against the location and the effects on now and future generations - especially their children. The majority feel their human rights as American citizens are not being considered. With the Three Mile Island and similar incidents in mind they fear the consequences.”


            “This letter is to protest the proposed short wave transmitter, in our area, that is being shoved down our throats. We neither need or want such an installation, there are plenty here now to our way of thinking. Not only do we feel it could cause a health problem - which promised will not - we’ve had such promises before and find ourselves stuck with the results but looking forward to poorer radio reception than we have now. ... In our local newspaper it stated ‘the easement from the State is one of the conditions applied by the planning commission in granting World Christian an exemption from the ‘noxious, injurious or hazardous use’ clause in Borough land use law. That doesn’t sound good to us. ... We moved here to escape all this encroachment of our rights, starting with health, peace of mind and our private property. Is this really necessary? Why can’t this area be left and another, more receptive to the plan, found?”


            “As a resident voter I have heard a lot of talk about this new radio tower. The opinion around here is that its hazardous to the local population, but nobody seems to have the facts. I feel that we have been left in the dark....”


            “Is it a must that the World Christian broadcasting tower and station be located in Anchor Point if so why? If this station is as proposed, non-hazardous, then why shouldn’t it be more centrally located and made easily accessible. In other words put it in Kenai or Anchorage where it doesn’t interfere with people’s lives so severely.”


            “Since I am a resident voter, and tax payer in Anchor Point, Alaska, I am seriously opposed to the erection of the Christian World Radio Tower because of the harm it will do to the land and people. ...”


            “I am opposed to the erection of a short wave communications system here at the Anchor Point locale. I believe that it would interfere with the beauty of the area, not to mention the interference with current broadcasting systems now in effect. ..”


            “I believe if these people would receive their own Lord they would not have time to be blasting the world with their idea of God, etc.”


            “To express my opinion and the opinion of everyone I know, the proposed short wave transmitter is not at all popular. Of all the more remote places it could be built, why here?”


            “I wish to express concern about the new idea of a short wave transmitter in Anchor Point. My first question is why so close to an area populated with so many people. Not just adults but many children. Why not somewhere a little closer to nothing?”


            “I am a resident of Anchor Point. I am opposed to the site of the short wave resident facility. I am a dedicated Christian and would like to see a radio broadcast to the socialist countries, but my fears are of future wars. Radio communications are the first to be leveled in times of war, and unfortunately, bomb targets are the labels of such facilities. My recommendation is to construct the station on the Aleutian Chain, some uninhabited little island. ...”


            “Senator Ted Stevens

            United States Senate

            Washington, DC 20510

            Dear Senator Stevens:

            “.... This World Christian Broadcasting Corp. does not have their License through the FCC yet and we are hoping that by writing our Senators and Representatives, that we can either stop this absurd deal or at least stop and take a better look at what will happen to our fish in the near by Anchor River, our moose who will be grazing near the tower, which was testified will be giving off certain radiation, let alone the people who live in our beautiful community. ... This tower will be broadcasting to 1/3 of the world’s population, with their main concern Russia and China. This will be of no benefit to Anchor Point, the Kenai Peninsula, or the State of Alaska. So my main question is why take the chance of harming our animals, our towns people, and also run the risk of making our television and radio reception worse than it is already. ...”


            “From tax payers and concerned citizens of the Kenai Peninsula Borough. We oppose the construction of the World Christian Broadcasting Corporation’s short wave radio station and transmission tower in the Anchor Point area due to the radiation emitted from this project. Under the Borough Ordinance we are to be protected from noxious, injurious, or hazardous conditions. Until sufficient evidence and independent research has proven that the radiation will not be harmful to our human lives, we oppose this construction in our area.” (This and other similar petitions were signed by about 100 citizens total.)


            “I am appalled that such a monstrosity can be constructed with the concert of the planning commission who, after an unadvertised meeting, have taken it upon themselves to subject my family, friends and neighbors to a potential health hazard as well as a potential invasion of our privacy should this station bleed through on our radios, television, CB, or Ham radios.”


In addition to the individual letters referenced above, WCBC received copies of letters that were sent by some of the citizens to the Director of the National Bureau of Standards (NBS) in Boulder, Colorado; to the Senior Planner of the Kenai Peninsula Borough; to the Chief of Industrial Hygiene, Department of Labor in Anchorage; to the Radiation Representative of the Environmental Protection Agency in Seattle, Washington; and to the Environmental Supervisor of the Department of Environmental Conservation, State of Alaska. The government agencies answered the letters generally by referring the writers back to the FCC.


(To be continued)