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HomeMy WebLinkAboutAmateur Radio Text Amend DocsCommunity Development Department Planning Division Building Safety Division Environmental Health Division 117 NW Lafayette Avenue Bend Oregon 97701-1925 (541)388-6575 FAX (541)385-1764 http://www.co.deschutes.or.us/cdd/ Memorandum TO: Deschutes County Board of County Commission FROM: Kristen Maze DATE: March 26, 2008 SUBJECT: Amateur Radio Text Amendment TA -06-10 On February 25, 2008 a 2nd public hearing for the amateur radio facilities was held before the Board of County Commissioner's ("Board"). At this hearing the Board listened to public testimony for and against specific regulations for amateur radio facilities. The Board closed the public hearing and left the written record open until March 12, 2008 at 5:00 pm. Attached for the record, and review by the Board are written testimony received prior to the record closing date. Staff has received approximately 18 letters, most in favor of little or no restriction for amateur radio facilities with the exception of a few letters that strongly contend that amateur radio facilities need strict regulation and should be governed under the Deschutes County Code (DCC) for the Wireless Telecommunication Facilities section 18.116.250. Below is a summary of attached letters listed chronologically, being with most recently received: 1. Rex Auker, March 11, 2008: This letter outlines recommended text changes to the proposed amateur radio code. This recommendation follows the current DCC Wireless Telecommunication code and also addresses findings regarding scenic vistas. 2. FCC, Received March 12, 2008: A Federal Communication Commission discussion about why the commission did not discuss its limited preemption policy to covenants, conditions and restrictions (CC&R's) in the 1985 PRB-1 decision. 3. Robert Swaney, March 11, 2008: This letter includes a height needs analysis specific to Bob Swaney's amateur radio facility and two other attachments on the importance of amateur radio operators. Mr. Swaney's letter outlines why Deschutes County should not be setting height limits on amateur radio facilities nor should the county discourage the desires of amateur radio operators with additional fees and strict regulations. Quality Services Performed with Pride 4. Loren Rasmussen, March 9, 2008: The County has made this an issue because one person doesn't like the placement of radio antennas. Deschutes County should regulate with existing code. 5. Ken Brinich, March 5, 2008: Deschutes County does not have the authority to regulate or preserve private view sheds unless a view shed is acquired by conveyance or grant. 6. Judith Barton, March 5, 2008: Addresses concerns about antennas being temporary structures that are frequently moved and do not need building permits. 7. John Ogden, February 29, 2008: The County should adopt only minor regulations and have only a general exemption of amateur radio facilities because they are regulated by the FCC. 8. Darrell Fevergeon, February 29, 2008: Deschutes County should not be spending so much time on regulations that are governed by the state and federal laws. 9. Mr. and Mrs. Phi Fenn, February 27, 2008: "Strongly support stricter zoning regulations on towers and poles related to wireless and ham radio activity." 10. Ken Brinich, February 26, 2008: This letter is a response to a public hearing question about a landowner's requirement to sign for a building permit. A landowners signature is only required for a land use permit. 11. Ken Brinich, February 26, 2008: Response to a public hearing suggestion that amateur radio operators should be held to the same standards as wireless telecommunications facilities. What is the county need to regulate? Height should not be a factor in regulating amateur radio facilities. Amateur radio facilities should have minimum or no regulations in Deschutes County in order to meet the "reasonable accommodation" obligation addressed in the state and federal law. 12. Rex Auker, February 26, 2008: Review of Snook vs. City of Missouri City, TX, which up holds the county's ability to review amateur radio facilities on the merit of each facility and on specific license of the operator and the intended use of the facility. Snook case took into consideration all sorts of information including the opinions of neighbors. Less information gathered by an agency leads to denial of an application which generally leads to a court case because the agency has failed to give adequate consideration of "reasonable accommodation". 13. Gene Walters February 25, 2008: Supports strict controls of elevated structures (amateur radio facilities). 14. Rex Auker, February 25, 2008: Lists general guidelines that Deschutes County should use to regulate amateur radio facilities. This letter goes into detail in support of strict regulations for amateur radio facilities. 15. Ken Brinich, February 22, 2008:Identifies the attached Snook case and an article from the Connecticut Law Review that reviews reasonable accommodation cases where there has been conflict between PRB-1 and local zoning authorities. 16. Ken Brinich, February 20, 2008: Ken Brinich submitted his changes to the proposed amateur radio text amendment. 17. Ken Brinich, February 19, 2008: Addresses state and federal law requiring the county to meet the two pronged test. 1. Reasonable accommodation. 2. County authority is limited to a least restrictive standard. 18. George Morton, February 11, 2008: Lists 8 reasons why amateur radio operators and facilities should not have strict regulations, if any. This work session will focus on a discussion of the proposed text amendment based on what the Board heard during public testimony and the attached written record. 2 \(/\\I\ Rex A. Auker 62575 Stenkamp Road Bend, Oregon 97701 2crj_D__BY: March 11, 2008 MAR 12 2008 Board of Commissioners Deschutes County DELI EtED BY: 117 NW LaFayette Avenue Bend, Oregon 97701 Subj: Amateur Radio Text Amendment TA -06-10 Introduction: The purpose of this letter is to respond to comments made at the public hearing on February 25, 2008 and to recommend important improvements to TA -06-10: Summary of Recommended Improvements to TA -06-10. 1. Because there is such great variety in the size and structure of amateur radio antennae and support structures it is necessary as a regulative strategy to first clearly define what antenna structures are permitted then require individual review of all antenna structures that deviate from what is clearly permitted. I suggest the three-tier strategy, definitions, and findings as follows: a. Defmition of Amateur Radio Facilities: 'Amateur Radio Facilities' means the external, outdoor structures associated with an operator's amateur radio service. b. Definition of Wood Monopole: "Wood monopole" means a wooden structure consisting of a single vertical pole or post inserted directly into the ground or attached to a foundation footing that does not rise above grade level. A wood monopole structure shall hot have guy wires or other external stabilizers and it shall be of sufficient size and strength to safely support all antennae which are planned to be mounted on it. c. Definition of Antenna Support Structure: "Antenna support structure" means a structure the principle purpose of which is to support an antenna. This does not include buildings such as sheds, barns or residences or vertical structures the principle purpose of which is to support other apparatus such as signs, lights or power lines. d. Defmition of antenna: "Antenna" means the device by means of which radio- frequency waves are radiated and received. All amateur radio antennae shall have 1 surface coatings or textures that do not reflect light, preferably in non -obtrusive colors that blend visually with the surrounding environment. e. Description of Three -Tier Approach: Tier I: Tier I amateur radio facilities consist of antennae and wood monopole antenna support structures whose combined height cannot exceed 45 feet above grade. Tier I amateur radio facilities may also consist of antennae and antenna support structures made from any material which are mounted on top of existing structures and do not extend more than 15 feet above the existing structures on which they are mounted. Tier I amateur radio facilities are permitted outright in any zone and require building permits only as specified in other relevant sections of Deschutes County Code. Tier II: Tier II amateur radio facilities consist of antennae and wood monopole antenna support structures whose combined height exceeds 45 feet but cannot exceed 75 feet above grade. Tier II facilities are permitted outright in all commercial and industrial zones. Tier II facilities are permitted outright in all other zones provided the land parcel on which they are located is larger than 2 acres. Tier II facilities are subject to building and land use permits as specified in Deschutes County Code requirements for the underlying zone. Tier III: Tier III amateur radio facilities include all those facilities that do not meet the specifications of Tier I and II. Also included in Tier III are the second or additional amateur radio facilities and antenna support structures of any type which are built on the same land parcel. Tier III amateur radio facilities are permitted subject to a conditional use permit that considers all the individual factors needed to support "reasonable accommodation" and "minimum practicable restriction" determinations. It shall be the responsibility of the applicant to provide this information. The requirements of DCC 18.128.340 shall apply to all Tier III amateur radio facilities and are deemed sufficient to support a non -controversial decision in favor of the amateur radio operator. In controversial cases, an up -front refundable deposit shall be collected to cover the cost of a hearing officer review. Also, the fees collected for all Tier III amateur radio facilities shall include an up -front refundable deposit sufficient to cover the cost for a telecommunications expert to conduct a thorough fact-finding investigation which will include all pertinent information plus recommendations for "reasonable accommodation" and "minimum practicable regulation" determinations. The up -front deposits for hearing officer review, "reasonable accommodation" and "minimum practicable regulation" determinations shall be returned to the applicant if and when a permit is issued and if the deposits have not been expended for their stated purposes. 2 c. Findings Regarding Scenic Vistas and Natural Horizons and Skylines (Addresses requirements imposed by ORS 221.295): Some of the most valuable resources of Deschutes County are its scenic vistas and natural horizons and skylines. Considering Deschutes County's large concentration of tourist and destination resort facilities, these resources are deemed to be of vital importance to both the county's economy and quality of life. Therefore, the preservation of existing scenic vistas and natural horizons and skylines is deemed to be a specific aesthetic objective pursuant to ORS 221.295. The term "natural horizons and skylines" means horizons and skylines consisting of natural topography and vegetation unencumbered by man-made structures. In many parts of the county natural horizons and skylines are composed of trees and other vegetation. The height of these trees and vegetation varies according to plant species. For the purpose of clarity and ease of administration regarding amateur radio facilities the natural horizon at any location in the county is defined as a line 45 feet above the ground underneath it. Accordingly, any amateur radio facility whose components, including antennae, are capable of extending higher than 45 five feet above the ground on which it is based is deemed to be extending above the natural horizon and skyline. Amateur radio facilities that extend above the natural horizon and skyline are prohibited except as otherwise allowed under the sections of the Deschutes County Code that address amateur radio facilities. Antenna support structures consisting of a single wood monopole are deemed to be consistent with the aesthetic objective of preserving scenic vistas and natural horizons and skylines. Antenna support structure composed of any other materials are deemed to be inconsistent with the aesthetic objective of preserving scenic vistas and natural horizons and skylines; therefore they are prohibited except as otherwise allowed under the sections of Deschutes County Code that address amateur radio facilities. 2. Wood monopole antenna support structures are sufficient to meet the needs of most amateur radio operators and should be permitted outright according to the three-tier strategy listed above. This will facilitate timely and cost effective approval of most amateur radio facility permits. Because of their small footprint, wood monopole antenna support structures will have little negative impact on irrigated land. They will also blend aesthetically with residential, agricultural and forest zones. The three-tier strategy I am suggesting also has the effect of encouraging the use of natural -looking materials, and it treats amateur radio in an even-handed manner when compared to wireless telecommunications facilities. 3. In 2000 the FCC declared that local codes that prohibit industrial -type structures in residential zones do not violate the principle of "reasonable accommodation". The currently proposed definition of amateur radio facility specifically allows metallic industrial -type structures to be constructed in residential, forest and exclusive farm use zones where normally such structures are prohibited. The definition of an amateur radio facility should not contain language that specifically allows metallic antenna support 3 structures because it has the effect of giving blanket authorization for industrial -type structures in residential, forest and agricultural zones. 4. The three-tier strategy I am suggesting does not prohibit metallic structures, but it requires that they be approved on a case-by-case basis. It is reasonable to require case- by-case consideration of metallic antenna support structures because of their great variety in shape and size. Also, the court decisions concerning amateur radio facilities require individual "reasonable accommodation" and "minimum practicable regulation" determinations whenever a county questions an amateur radio operator application to build a tower. This greatly increases the county's responsibility to give thorough, competent and individual consideration to each application for an amateur radio tower. 5. Amateur radio operators resist the idea of applying for conditional use permits or being required to submit specific information about the antenna towers they plan to erect. The FCC, however, has intentionally declined to place specific restrictions on local governments concerning the administrative processes that should be applied to amateur radio facilities. The courts have clearly established that each antenna structure must be evaluated on an individual basis to determine if a local ruling provides for "reasonable accommodation" and "minimum practicable regulation". a. In Orin Snook vs City of Missouri City, Texas, the court ruled that "reasonable accommodation" and "minimum practicable restriction" determinations must specifically address the license of the operator, the intended use of the antenna, the site, the specific antenna array, the effect of surrounding vegetation, etc. The court also took note of the neighbors' comments at public hearings. Also in that case, the city required the amateur operator to submit copious amounts of information. Mr. Snook asked for a ruling against the city because of the administrative burden that was placed on him, but the court denied it. Instead, the court supported the city's prerogative to require the amateur operator to provide the large volume of information it requested. 6. Large antenna structures on small land parcels increases the likelihood of conflict between the amateur radio operator and the neighbors. The potential for conflict is reduced, however, when there is clarity about what is permitted. The three -tiered strategy I am suggesting provides clarity in routine cases and provides for dialogue and careful consideration in cases that are exceptional. Large metallic structures are not expressly prohibited, but they are subject to an administrative review that is commensurate with the magnitude of impact they might have on the health, safety and aesthetics of a neighborhood or community. 7. There is a high probability that if a large antenna structure is allowed to be built on irrigated farm land, the land will in effect be converted to non-farm use. If this occurs in an exclusive farm use or other agricultural zone, it will be in direct conflict with county and state land use goals and objectives. In Oregon the protection of farm land is of such a high priority that it is reasonable to prohibit the construction of amateur radio towers on irrigated land. 4 a. If an amateur operator believes that he must build an antenna structure on irrigated land, then he always has the option of applying for a zoning variance. Through that process he will be able state his case and receive careful consideration of his individual circumstances. If a zoning variance is requested, the county will need to conduct a thorough and expert fact-finding investigation and make specific "reasonable accommodation" and "minimum practicable restriction" determinations. By prohibiting the construction of amateur radio towers on irrigated land the county does not necessarily guarantee that none will be built, but the prohibition will have the effect of requiring the amateur operator to specifically demonstrate why he should be allowed to override the legitimate state and county interests in preserving farm land. 8. Multiple antenna support structures on one land parcel increases the probability of changing the character of the local community and giving rise to conflict with neighbors. For most amateur operators, the allowance for one antenna support structure will make reasonable accommodation for their communications objectives. Also, multiple antennae can be mounted on a single support structure. In the minority of cases where an amateur operator's objectives require multiple antenna support structures, it is certainly within the county prerogative to require the thorough review associated with Tier III structures. This requirement should be interpreted to include antenna arrays that consist of multiple free- standing vertical structures used to support a single or multiple antenna array. If an array requires more than one wood monopole vertical support structure of any height, then it should be evaluated as a Tier III amateur radio facility. 9. The Tier III requirements that are specified in DCC 18.128.340 require that a tower or monopole be finished in natural wood colors or colors selected from amongst colors approved by Ordinance 97-017. It should be noted that this requirement applies only to the antenna support structures, not to the antennae; therefore it will have absolutely no effect on the operational capabilities of the antennae. 10. ORS 221.295 declares that the county may not regulate antenna below 70 feet in height except to meet a clearly defined health, safety or aesthetic objective. I have included "Findings Regarding Scenic Vistas and Natural Horizons and Skylines" to address that requirement. 11. Finally, I want to affirm that the regulation of amateur radio facilities is indeed a complex issue, in part due to the federal preemption of local authority, in part due to the activist nature of the amateur radio community. However, in consideration of the interests of all county residents, I am pleased that the Board of Commissioners is deciding to place reasonable limits on the construction of amateur radio facilities. Again, I extend my thanks for your time and effort. Rex A. Auker 5 6 FCC: Wireless Services: Amateur Radio Service: Releases: PRB-1nn gis�oaTeX o4 a wtwl S cOYla-S. rte. t19-626—I0 FCC Home Search Updates E-Filing Initiatives For Consumers Find People FCC Federal Uommuriiations -' Commission Amateur Search: Help - Advanced Amateur Home About Amateur Communications & Operations International Arrangements Operator Class Reciprocal Arrangements Call Sign Systems Sequential Special Event Vanity Amateur Licensing Club Stations Common Filing Tasks Examinations Military Recreation Volunteer Examiners VECs Releases PRB-1 Amateur Site Map Related Sites Forms & Fees Rules Wireless Rules & Regulations (Title 47) ULS Universal Licensing System Page 1 of 5 Radio Service FCC > WTB > Services > Amateur Home > Releases > PRB-1 PRB-1 (2000 - Reconsideration) Introduction and Executive Summary ► Background Discussion ► Conclusion Ordering Clause Adopted 11/13/2000 Released 11/15/2000 ORDER ON RECONSIDERATION (RM 8763) In the Matter of Modification and Clarification of Policies and Procedures Governing Siting and Maintenance of Amateur Radio Antennas and Support Structures, and Amendment of Section 97.15 of the Commission's Rules Governing the Amateur Radio Service Before the Federal Communications Commission Washington, D.C. 20554 36149 By the Deputy Chief, Wireless Telecommunications Bureau. Return To Top Introduction and Executive Summary 1. In this Order on Reconsideration, we address Petitions for Reconsideration (ARRL Petition) filed by the American Radio Relay League, Inc. (ARRL), and by Barry N. Gorodetzer and Kathy Conard-Gorodetzer (Gorodetzer Petition) (collectively "Petitioners"). The Petitions seek reconsideration of a Wireless Telecommunications Bureau (Bureau) Order, released November 19, 1999, denying the petition for rule making filed by ARRL on February 7, 1996. For the reasons given herein, we deny the subject petitions for reconsideration. Return To Top Background 2. In its 1985 PRB-1 decision, the Commission established a policy of limited preemption of state and local regulations governing amateur station facilities, including antennas and support structures. However, the Commission expressly decided not to extend its limited preemption policy to covenants, conditions and FCC Site Map PRB-1 (1985) PRB-1 (1999) PRB-1 (2000 - Reconsideration) PRB-1 (2001) BY: MAR 1 2 2008 DELIVERED BY: http://wireless.fcc.gov/services/index.htm?job=prb-1&id=amateur&page=3 12/3/2007 FCC: Wireless Services: Amateur Radio Service: Releases: PRB-1 WTB Wireless Telecommunicatic Bureau restrictions (CC&Rs) in deeds and in condominium by- laws. 3. On February 7, 1996, ARRL filed a petition for rule making seeking a review of the Commission's limited preemption policy. ARRL requested, inter alia, that limited preemption be extended to CC&Rs. In an Order, released November 19, 1999, we denied the petition for rule making. We concluded that specific rule provisions bringing private restrictive covenants within the ambit of PRB-1 were not necessary or appropriate. On reconsideration, the petitioners reiterate the request that the Commission's limited preemption policy be extended to CC&Rs. ARRL also seeks a declaratory ruling that the imposition of unreasonable or excessive costs in obtaining a land use permit for an amateur antenna, or fulfilling a condition in such a permit, would be contrary to the Commission's limited preemption policy enunciated in PRB-1. Return To Top Discussion 4. In PRB-1, the Commission stated that CC&Rs restricting amateur operations were not a matter of concern to it, because "[s]uch agreements are voluntarily entered into by the buyer or tenant when the agreement is executed," and "[p]urchasers or lessees are free to choose whether they wish to reside where such restrictions on amateur antennas are in effect or settle elsewhere." ARRL directed much of its rulemaking petition, and the bulk of its petition for Reconsideration, to arguing that the Commission has authority to preempt CC&Rs that restrict amateur operations. In the Order, we declined to address this argument because we were not persuaded that such action, even if authorized, is "necessary or appropriate at this time." 5. The Petitioners contend, however, that the Telecommunications Act of 1996 provided the Commission with the authority to address CC&Rs, and, further, that the Commission has acknowledged this authority. ARRL further argues that restrictive covenants in deeds "have never been the equivalent of private contracts." Moreover, ARRL states that the purchaser of land, in modern transactions, "never actually agrees, and very seldom even understands when he or she buys property subject to deed restrictions that amateur antennas are not permitted." 6. Assuming, without deciding, that the Commission has authority to address CC&Rs in the context of amateur radio facilities, this alone does not necessarily warrant revisiting the exclusion of CC&Rs from the Commission's limited preemption policy in this context. Unlike over -the - air reception devices (OTARDs), which are very limited in size in residential areas, amateur station antennas may vary widely in size and shape. Amateur station antenna configurations depend on a variety of parameters, Page 2 of 5 ,_ "- http://wireless.fcc.gov/services/index.htm?job=prb-1&id=amateur&page=3 12/3/2007 FCC: Wireless Services: Amateur Radio Service: Releases: PRB-1 Page 3 of 5 including the types of communications that the amateur operator desires to engage in, the intended distance of the communications, and the frequency band. Amateur station antennas, in order to achieve the particular objectives of the amateur radio operator, can be a whip attached to an automobile, mounted on a structure hundreds of feet in height, or a wire hundreds (or even more than a thousand) of feet in length. They can be constructed of various materials occupying completely an area the size of a typical backyard. In addition, there can be an array of different types of antennas. Regardless of the extent of our discretion with respect to CC&Rs generally, we are not persuaded by ARRL's arguments that it is appropriate at this time to consider exercising such discretion with respect to amateur station antenna preemption. Moreover, we do not believe that ARRL has demonstrated that there has been a significant change in the underlying rationale of the PRB-1 decision, or that the facts and circumstances in support thereof, that would necessitate revisiting the issue. In the absence of such showing, we believe that the PRB-1 ruling correctly reflects the Commission's preemption policy in the amateur radio context. 7. In PRB-1, the Commission held that "local regulations which involve placement, screening, or height of antennas based on health, safety, or aesthetic considerations must be crafted to accommodate reasonably amateur communications, and to represent the minimum practicable regulation to accomplish the local authority's legitimate purpose." The ARRL's second request in its Petition concerns imposition of excessive costs for, or the inclusion of burdensome conditions in, permits or variances needed prior to installation of an outdoor antenna. As it did in its petition for rule making, ARRL requests a ruling from the Commission that imposition of unreasonable or excessive costs levied by a municipality for a land use permit, or unreasonable costs to fulfill conditions appended to such permit, violates PRB-1. In our Order, we concluded that the current standards in PRB-1 of reasonable accommodation and minimum practicable regulation are sufficiently specific to cover any concerns related to unreasonable fees or onerous conditions. With these guidelines in place, an amateur operator may apprise a zoning authority that a permit fee is too high, and therefore unreasonable, or that a condition is more than minimum regulation, and, therefore, impracticable to comply with. 8. We take this opportunity to amplify upon the meaning of 'reasonable accommodation' of amateur communications in the context of local land use and zoning regulations. The Commission adopted a limited preemption policy for amateur communications because there is a strong federal interest in promoting amateur communications. We do not believe that a zoning regulation that provides extreme or excessive prohibition of amateur communications could be deemed to be a reasonable accommodation. For example, we believe that a regulation that would restrict amateur communications using small dish antennas, antennas that do not present any safety or health hazard, or antennas that are similar http://wireless.fcc.gov/services/index.htm?j ob=prb-1 &id=amateur&page=3 12/3/2007 FCC: Wireless Services: Amateur Radio Service: Releases: PRB-1 Page 4 of 5 Licensing. Technical Support and Website Issues to those normaiiy permitted for viewing television, either locally or by satellite, is not a reasonable accommodation or the minimum practicable regulation. On the other hand, we recognize that a local community that wants to preserve residential areas as livable neighborhoods may adopt zoning regulations that forbid the construction and installation in a residential neighborhood of the type of antenna that is commonly and universally associated with those that one finds in a factory area or an industrialized complex. Although such a regulation could constrain amateur communications, we do not view it as failing to provide reasonable accommodation to amateur communications. 9. In his comments supporting the ARRL Petition, Duane Mantick states that the Commission's rules regarding radio frequency (RF) safety and the actions of local authorities are inconsistent because to comply with the RF safety requirements an antenna must be a certain height in order to keep 2 meter and 10 meter radio signals away from the general public. According to Mr. Mantick, this is in direct conflict with the local zoning regulations and covenant provisions which are designed to keep the height of the antenna structure as low as possible. Mr. Mantick argues that the amateur operator must, in order to comply with safety requirements, reduce output power to 50 watts or less and thus sacrifice transmission effectiveness, and due to a low antenna, sacrifice reception effectiveness as well. It appears that Mr. Mantick's comments overstate the situation that an amateur operator faces. An environmental evaluation needs to be made only if the power on 10 meters exceeds 50 watts. Further, if more power is employed at the station and measures are required to prevent human exposure to RF electromagnetic fields, then adjustments can be made at the amateur station regarding the amount of power used, the duty cycle employed, and the antenna configuration. Thus, it is feasible for an amateur operator to comply with the Commission's safety requirements relating to human exposure to RF radiation, and at the same time to comply with local zoning regulations that govern antenna height. In sum, while we appreciate that the two considerations discussed above, that is, safety requirements vis -...-vis zoning regulations, might present a challenge to the amateur operator, we do not believe that the safety of individuals should be compromised to address such challenge. Moreover, we continue to believe that we should not specify precise height limitations below which a community may not regulate, given the varying circumstances that may occur, as a response to this challenge. Return To Top Conclusion 10. Accordingly, we conclude that the Petitions for Reconsideration filed by the ARRL and Barry and Kathy Conard-Gorodetzer should be partially granted insofar as we have provided clarification herein, but in all other http://wireless.fcc.gov/services/index.htm?job prb-1&id=amateur&page=3 12/3/2007 FCC: Wireless Services: Amateur Radio Service: Releases: PRB-1 respects should be denied. Return To Top Ordering Clause 11. IT IS ORDERED THAT, pursuant to Sections (4)(i) and 405(a) of the Communications Act of 1934, as amended, 47 U.S.C. - 154(i), 405(a), and Section 1.106 of the Commission's Rules, 47 C.F.R. - 1.106, the Petitions for Reconsideration of the American Radio Relay League, Inc., filed on December 20, 1999, and Barry and Kathy Conard-Gorodetzer, filed on December 17, 1999, ARE PARTIALLY GRANTED to the extent clarification has been provided herein, but in all other respects ARE DENIED. This action is taken under delegated authority contained in Sections 0.131 and 0.331 of the Commission's Rules, 47 C.F.R. - 0.131, 0.331. FEDERAL COMMUNICATIONS COMMISSION Kathleen O'Brien Ham Deputy Chief, Wireless Telecommunications Bureau Return To Top Last reviewed/updated on 2/19/2002 Page 5 of 5 Licensing, Technical Support and Website Issues - Forgot Your Password? - Submit eSupport request Phone: 1-877-480-3201 TTY: 1-717-338-2824 Federal Communications Commission 445 12th Street SW Washington, DC 20554 More FCC Contact Information... Phone: 1 -888 -CALL -FCC (1-888- 225-5322) TTY: 1 -888 -TELL -FCC (1-888- 835-5322) Fax: 1-866-418-0232 E -Mail: fccinfofcc.gov http://wireless.fcc.gov/services/index.htm?job=prb- l &id=amateur&page=3 - Privacy Policy - Website Policies & Notices - Required Browser Plug -ins - Freedom of Information Act 12/3/2007 ROBERT SWANEY Deschutes County Community Development Attn: Kristen Maze 117 NW Lafayette Avenue Bend, Oregon 97701 In Re: Proposed Text Amendment TA -06-10 Dear Ms. Maze: March 11, 2008 RECEIVED MMR 1 2 2008 Li V , €D BY: Needs Analysis Attached. The enclosed "Needs Analysis" (see Attachment A) forn l66atlon and amateur radio interests was generated at my request (and expense) by an independent consulting engineer, to demonstrate why antenna height matters to me, and why a low maximum height would be unreasonably restrictive. As we explore the permitting process, it may be helpful to understand one significant difference between cellular telephone systems and amateur radio communications.' If the cellular carrier cannot cover a particular area, it is possible for that carrier to install a second site to cover unserviced geography. The radio amateur has no such choice. His or her antenna system, an ordinary accessory use of a residential property, is located where s/he lives. A remote site cannot be required, nor is it desirable — except in specialized circumstances. In any event, no local government could mandate a firm, fixed maximum height at the home of a radio amateur. For example, Bulchis v. City of Edmonds, 671 F. Supp. 1270 (W.D. WA 1987), in a summary judgment in favor of the radio amateur, held that an ordinance requiring a conditional use permit for an antenna support structure over 25 feet high did not provide for reasonable accommodation as applied. In addition, Palmer v. City of Saratoga Springs, 180 F. Supp. 2d 379 (N.D.N.Y. 2001) held the absolute height limit of 20 feet in the ordinance was preempted. "(A)n unvarying height restriction on amateur radio antennas would be facially invalid in light of PRB- 1." (Citing three cases, including Bulchis.) The Need for Height is Not Based on Folklore. The generalized explanations and statements made in the recent public hearing by the amateur radio community may have left the impression that the relationship between height and performance of antennas is just a matter of accepted wisdom on our part, and not really provable or expressible in concrete terms. Nothing could be further from the truth. 1 Just to be clear, it should be noted that the preemption for cellular telephone antennas, found at 47 U.S.C. § 332 (c) (7), which tends to preserve traditional local zoning authority, is entirely different from the preemption for amateur radio antennas, found at 47 CFR §97.15(b). Orel 62515 Stenkamp Road • Bend, Oregon 97701 • (541) 330-6791 • FAX: (206) 457-6607 First, the engineering community, at the behest of commercial and government interests, has developed methodology to predict the effectiveness of antennas at various heights, for various paths, at various frequencies — as you will see demonstrated in the Needs Analysis accompanying this letter. Second, the sound scientific basis for the potential need for height is reflected in decisions and orders of the Federal Communications Commission. For example: (A)n antenna array for International amateur communications will differ from an antenna used to contact other amateur operators at shorter distances. Memorandum Opinion and Order (FCC 85-506), Federal Preemption of State and Local Regulations Pertaining to Amateur Radio Facilities (1985) ¶25 In 2000, the FCC elaborated: (A)mateur station antennas may vary widely in size and shape. Amateur station antenna configurations depend on a variety of parameters, including the types of communications that the amateur operator desires to engage in, the intended distance of the communications, and the frequency band. Amateur station antennas, in order to achieve the particular objectives of the amateur radio operator, can be a whip attached to an automobile, mounted on a structure hundreds of feet in height, or a wire hundreds ... of feet in length. In the Matter of Modification and Clarification of Policies and Procedures Governing Siting and Maintenance of Amateur Radio Antennas and Support Structures, and Amendment of Section 97.15 of the Commission's Rules Governing the Amateur Radio Service, RM -8763 (2000), Order on Reconsideration, ¶6 (Footnote omitted.) Unfortunately, not enough radio amateurs can assemble the team of lawyers and engineers to explain this to the County Commissioners in a lucid, accurate manner. Far fewer would ever be interested in pursuing the same interests in the hobby that I do, and would therefore need the height I need. The attached analysis shows exactly why my station was designed as it was. As you will see, to achieve my purposes, the antennas I have should be higher. I'm not the average amateur radio operator. I'm well experienced in long distance High Frequency (HF) amateur radio communications from both the U.S. and locations at great distance from the U.S. I've designed and built several stations with various levels of space, terrain, and ground quality. I also have financial resources well above the average amateur radio operator, and ready access to specialized expertise for station design and building, based on personal relationships built up over many years. The attached analysis cost me $1,500, and I already knew all of the conclusions in advance because of my level of knowledge and experience. I bore the cost to have it produced by a credible, independent source, in a form that would be more persuasive than the vague generalizations offered at the most recent public hearing, when you heard that "higher is better". Any amateur radio operator can demonstrate that in a rational, defendable form, using antenna and terrain modeling and propagation forecasting software that is available today. The issues are the time and money the amateur has to invest to produce that information in a form that you can review, and would the County be able to analyze it in sufficient depth to verify its accuracy and conclusions? The Burden Rests on the County. If the County wishes to regulate the height of amateur radio facilities, it must demonstrate understanding and acknowledge the "particular objectives" of the individual amateur radio operator applicant, not just applicants generally. Remember what the FCC said about this? The burden falls on the County to demonstrate that the zoning bylaw represents "the least practicable regulation" for "the types of communications that the amateur operator desires to engage in, the intended distance of the communications, and the frequency band." id at ¶6. This is a "least restrictive means" test. PRB-1's guidelines brings (sic) to a local zoning board's awareness that the very least regulation necessary for the welfare of the community must be the aim of its regulations so that such regulations will not impinge on the needs of amateur operators to engage in amateur communications. id., at ¶9. To do that, the County must demonstrate that staff can review and understand this form of analysis without resorting to an outside expert, the cost of which I expect would be placed on the applicant. I certainly take the position that making the radio amateur pay for a Needs Analysis, and then pay for the County's consultant to analyze the analysis, subjects the radio amateur to an unreasonable cost burden. Costs Must be Considered. The County's regulations should be designed to avoid discouraging the desires of amateurs of much more modest means to build a station. To date, I have seen no evidence whatsoever to suggest that the County Staff has analyzed any of the elements of the proposed regulation to determine the potential out-of-pocket costs or time potentially expended by an amateur applying under these regulations. I have heard some general discussions about the obvious upfront fees going to the County, and possibly minimizing some of those costs, but that is hardly the whole picture when considering whether regulations are too costly and therefore not a "reasonable accommodation" which represents the "least restrictive" means of regulation. Safety. As you continue consideration of the regulation of amateur radio antenna support structures, I want to make it clear that the building code, including all of its safety considerations, always applies. The building code applies to an antenna support structure of any height. Public Policy. Finally, I suggest to the County that it is good public policy to encourage Amateur Radio installations, and not discourage them. In its initial consideration which led to 47 CFR §97.15(b) the FCC held: 24. ... [T]here is ... a strong federal interest in promoting amateur communications. 25. Because amateur station communications are only as effective as the antennas employed, antenna height restrictions directly affect the effectiveness of amateur communications. Some amateur antenna configurations require more substantial installations than others if they are to provide the amateur operator with the communications that he/she desires to engage in. For example, an antenna array for International amateur communications will differ from an antenna used to contact other amateur operators at shorter distances. FCC Order PRB-1, 101 FCC 2d 952, 50 Fed. Reg. 38813 (September 25, 1985) http://wireless.fcc.gov/services/amateur/prb/index.html (last visited March 10, 2008). Thereafter, 47 CFR §97.15(b) was adopted to read: a station antenna structure may be erected at heights and dimensions sufficient to accommodate amateur service communications. (State and local regulation of a station antenna structure must not preclude amateur service communications. Rather, it must reasonably accommodate such communications and must constitute the minimum practicable regulation to accomplish the state or local authority's legitimate purpose. See PRB-1, 101 FCC 2d 952 (1985) for details.) This concept was affirmed by the Congress of the United States in Public Law 103-408 (J.Res., 103d Congress, 1994) §1 "Congress finds and declares that — (3) reasonable accommodation should be made for the effective operation of amateur radio from residences, private vehicles and public areas, and that regulation at all levels of government should facilitate and encourage amateur radio operation as a public benefit." http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=103 cong bills&docid=f sj90enr.txt.pdf Private emergency responders, such as the American Red Cross, have also adopted statements requesting cooperation from local governments. See Attachment B. The benefit of amateur radio, ready to go, is well described in the clippings found in Attachment C. Summary. County -level regulation of Amateur Radio antenna systems is rare in the United States. The history of Amateur Radio in this County demonstrates that voluntary self regulation is effective. Local Amateur Radio operators take advantage of available screening where available and it to the extent it does not unreasonably interfere with our operations. No credible evidence to the contrary has been presented, before either the Planning Commission or the BOCC, over the past 14 months this matter has been under consideration. Experienced Amateur Radio operators look for locations with as much land and suitability for their antennas as possible, within the constraints of their budgets. There are numerous issues with the proposed ordinance in its latest form. In this submission, I address Commissioner Melton's question: How or why does regulating tower height, the essence of the County's proposal, affect amateur communications? The towers support antennas. Antenna height is critical to effective communications across a wide spectrum of frequencies, for a wide variety of needs. The County's approach must meet federal standards encouraged by the Congress, ordered by the FCC, and tested in many state and federal courts. On the issue of limiting us to just one antenna or antenna support structure I reiterate my opposition. The burdens of time and money created by site planning are beyond what may be considered "the very least regulation necessary ... so that such regulations will not impinge on the needs of amateur operators."I remind the BOCC of federal order FCC 99-2569 (1999), found at http://wireless.fcc.gov/services/amateur/prb/prb1999.html 7. ... PRB-1 decision precisely stated the principle of "reasonable accommodation". In PRB-1, the Commission stated: "Nevertheless, local regulations which involve placement, screening, or height of antennas based on health, safety, or aesthetic considerations must be crafted to accommodate reasonably amateur communications, and to represent the minimum practicable regulation to accomplish the local authority's legitimate purpose." Given this express Commission language, it is clear that a "balancing of interests" approach is not appropriate in this context. 9. ... [W]e believe that PRB-1's guidelines brings (sic) to a local zoning board's awareness that the very least regulation necessary for the welfare of the community must be the aim of its regulations so that such regulations will not impinge on the needs of amateur operators to engage in amateur communications. (Emphasis added.) The details discussed at the past two BOCC public hearings should have been considered at the Planning Commission level. The Planning Commission's proposal for consideration by the BOCC is flawed and I believe a court would find it illegal. A discussion of how and why the Planning Commission's proposal came to pass is a discussion well worth having. Whether it would be constructive right now is questionable. The best course of action is to terminate further consideration of the proposed ordinance, and direct the County Community Development Department to accept and process building permit applications submitted by Amateur Radio operators. The BOCC should reaffirm that the Height Exception language mistakenly removed from the planning code remains current law. This is consistent with how CDD exercised its authority prior to 2005. Alternatively, the BOCC should consider adopting our originally proposed text amendment (with modifications that apply setbacks generally applicable to the zoning of the applicant's property, and nothing beyond those required setbacks). Either course of action would allow the County to regulate the structural safety of Amateur Radio antenna support structures, avoid unnecessary and burdensome costs on the Amateur Radio community, and end the controversy this matter has created. As the situation stands today, should this regulation be adopted, the County could not represent to any Court in good faith that the proposed regulation meets the federally mandated tests of: • "minimum practicable regulation", • "reasonable accommodation", • "the least regulation necessary", and • "regulation that will not impinge on the needs of amateur operators". Nor does it "facilitate and encourage amateur radio operation as a public benefit." Sincerely, Robert D. Swaney Enclosure cc: County Commissioners Ken Brinich, Esq. Fred Hopengarten, Esq. Philip Kane, Esq. Showing of Need for Height of Amateur Radio Antenna Support Structures Submitted on Behalf of Robert D. Swaney 62515 Stenkamp Road Bend, OR 97701 Prepared by James A. Nitzberg, BSEE 3314 Bert Koontz Road Taneytown, MD 21787 nitz@selectsa.com Page 1of15 TABLE OF CONTENTS Executive Summary 3 Outline 4 Background of the Author, James A. Nitzberg, BSEE 4 Communications Reliability 4 Definitions 4 Examples 4 Application to HF analysis 5 High Frequency (HF) Analysis of the Existing Installation 6 Procedure 6 Description of Parameters 6 Map Set 1 —14 MHz to Europe 8 Map Set 2 — 7 MHz to Europe 10 Map Set 3 — 3.5 MHz to Japan and Asia 12 High Frequency (HF) Communications Analysis Conclusions 15 Page 2 of 15 Executive Summary The purpose of this report is to show the need for antenna systems of sufficient height and dimensions to provide reliable High Frequency (HF), or `shortwave', communications, under the changing variables that impact Amateur Radio communications, for Robert D. Swaney, Amateur Radio Operator WS7N, located in Deschutes County, Oregon. This report studies three Amateur Radio antenna systems on two supporting structures. The heights of the two structures supporting them are 130' and 89' respectively. The three studies consider the existing location of the antennas on each study, compared to an antenna at a height of 30 feet. The following is a summary of the study scenarios: 1. 14 MHz: 4 element Yagi antenna at 89 feet. The target coverage area is Europe and the Middle East. 2. 7 MHz: 3 element Yagi at 125 feet, the target coverage area is Europe. 3. 3.5 MHz: Single element dipole antenna. The target coverage area is Japan. It is the conclusion of this report that these structures — which ideally should be taller — are an acceptable compromise adequate for moderate needs of the amateur radio operator when measured against commonly used engineering metrics. A height of 30 feet for any HF antenna (Deschutes County Planning Department has taken the position that this represents the maximum height permissible under the zoning bylaw) results in clearly unacceptable performance which cannot meet the needs of the amateur radio operator when measured against commonly used engineering metrics. Page 3 of 15 Outline This report is organized as follows: 1. Background of the author. 2. A brief discussion of communications reliability as pertaining to amateur radio. 3. An HF communications reliability study of the installation, using industry standard tools. 4. A reprint of a publication from the American Radio Relay League, "Antenna Height and Communications Effectiveness", that provides the basic technical background as to why higher antennas perform more reliably. Background of the Author, James A. Nitzberg, BSEE Mr. Nitzberg received his Bachelor's Degree in Electrical Engineering from the University of Delaware in 1985, specializing in digital signals and systems design. He has been a software professional for over 20 years and his experience covers all aspects of design, development, implementation and support for the complete software life cycle. Mr. Nitzberg is the Executive Vice President of Select* Associates, Inc. in Timonium, MD. Mr. Nitzberg has extensive experience in HF Terrain Analysis / Performance modeling, and has conducted studies on the effect of different antenna heights on system performance and geographic coverage area using the (US Government developed) Voice of America Coverage Analysis Program (VOACAP). Communications Reliability For the reader to meaningfully interpret the reliability study presented herein, a brief discussion of the major concepts and terms involved is relevant. The reader is also urged to review the document prepared by technical staff at the American Radio Relay League, "Antenna Height and Communications Effectiveness," which provides the physical explanation as to why radio communications reliability and effectiveness is strongly affected by antenna height. Definitions Reliability (REL) in a radio communications context, answers the question "How often, on average, can this communication take place at a specified `minimum acceptable level'?" Reliability is normally expressed as a percentage, and arriving at a specific value depends on the defmition of `Minimum Acceptable Level' (or M.A.L.) in use. Several different M.A.L.'s are commonly accepted in the engineering community. Examples Imagine watching a distant VHF or UHF analog TV station (not cable), which occasionally fades in and out. If we define the M.A.L. as 'a completely clear picture without snow or fuzziness', then the measured Reliability might be as low as 20-30%. On the other hand, if we are willing to accept an M.A.L. of 'we can just make out the picture,' then the measured Reliability might jump to 80-90% .. . Page 4 of 15 for the same picture. Or consider this real world example. Many areas of the communications industry (broadcasting and networking, to pick two) routinely use a Reliability figure of 99.99% (commonly referred to as the 'four nines'). In this case, the M.A.L. is usually 'the transmission (or network) is functioning, and of first quality' — nothing less. Being 'up' 99.99% of the time, conversely, means you are `down' no more than 0.01% or, equivalently, no more than 52 minutes per year. Radio amateurs do not, generally speaking, require such a high level of Reliability. Application to HF analysis Turning closer to our domain, High Frequency (HF) shortwave broadcasters, like the Voice of America or the BBC World Service, look for Reliability numbers in the 80-90% range when planning their time and frequency schedules, to achieve an area coverage goal. In their cases, the M.A.L. parameter (yardstick) is the Signal -to -Noise ratio, or SNR. This is basically the ratio of how loud the broadcast is in relation to background radio `hiss' and static levels. Commonly used numbers are anywhere from 40-70 dB (a higher number means better quality reception). In the analysis presented below, the Reliability threshold is set at 57%, using an SNR of 40 dB for Single Sideband (SSB) voice communication, and 24 dB for Morse code (CW) communications. These are very conservative (low) values for measuring acceptable communications quality HF radio communication is made possible by reflecting signals off of an ionized portion of the earth's atmosphere known as the ionosphere. The very nature of this communication is variable (i.e., not constant) and depends on many factors, including the time of year, time of day, solar (sunspot) activity, local noise sources and other geomagnetic and atmospheric conditions. In our test cases we have consistently used very conservative models and accepted a low Reliability (REL) factor (57%). • A Reliability threshold of 57% is equivalent to 4 days a week. Imagine if your cell phone or cable TV service worked only four days out of seven during the week — that would be a Reliability of 57%. If your cell phone or cable TV service worked only five days out of seven, that would be a Reliability of 71%. In the figures that follow, the Reliability contours are 14, 28, 43, 57, 71, and 86 percent, to correspond to easily understood levels of one to six days per week. • The M.A.L. (Minimum Acceptable Level) is expressed as a Signal -to -Noise Ratio (SNR). This value (40 dB) is commonly used in Amateur Radio; it is the minimum required SNR for a Single Sideband (voice) transmission. Single sideband transmissions sometimes require an SNR up to 50 dB or more, which would further lower the results presented here (i.e., require a larger/taller antenna system). In other words, in presenting the results here, the assumptions about required Reliability are very modest. A minimum Signal -to -Noise Ratio of 24 dB is used for CW (Morse code) transmission, when modeling the paths to Europe on low frequencies, such as 3.5 MHz. Page 5 of 15 High Frequency (111) Analysis of the Existing Installation Procedure For the High Frequency (HF or shortwave) radio spectrum, the reliability (REL) of a given path (say, Oregon to Europe) is commonly defined as the percentage of days that the signal at the receiver's end meets or exceeds a defined Signal -to -Noise ratio (SNR). The REL value depends on many parameters. Several directly or indirectly affect the "take -off' angle as described in the well documented American Radio Relay League (ARRL) publication which accompanies this report. Other parameters include transmitter power, local terrain, and the hourly and daily absorptive and reflective properties of the ionosphere. In this section, we use two industry standard software tools: High Frequency Terrain Analysis (HFTA) and the Voice of America Coverage Analysis Program (VOACAP), to predict the REL value for the existing location to Central Europe, using two different antenna heights and different radio frequencies. The process starts with terrain data entered for Deschutes County, Oregon to the desired geographic location fed as input to the HFTA (High Frequency Terrain Assessment) program from the American Radio Relay League. This program uses Mr. Swaney's terrain elevation and antenna parameters as input, and provides antenna gain and take -off (elevation) angle data as output. The output from HFTA is used as input to VOAAREA (a subset of VOACAP) to produce Area Coverage maps. VOACAP is an HF Propagation Analysis software tool developed by the U.S. Department of Commerce / Institute for Telecommunication Sciences, also in the public domain, and made possible by funding from the Voice of America (VOA), the U.S. Army, and the U.S. Air Force. Area Coverage is one of many calculations that VOACAP can perform. It displays a number of calculated quantities (including REL) for a specified transmitter to a specified reception area for a specified date, time of day, frequency, and sunspot level. The results appear as contours plotted on a world map background. As a visual aid, those areas that meet our criteria are in color, first green then yellow, while those areas which fail our criteria are shown in blue, grayscale or white. The output maps for the three studies mentioned above are shown below. Description of Parameters Several parameters were held constant for all cases; they are: • Transmitter location: the location in Deschutes County, Oregon. • Transmitter power: 1.4 kW (kilowatts). This is the maximum legal limit for amateur radio stations, less a small percentage to model transmission line loss. • Transmitter frequencies: 14 MHz (20 meters), 7 MHz (40 meters) and 3.5 MHz (80 meters). • Receiving antenna type: a 3 -element directional Yagi antenna, mounted at a height of 55 to 75 feet above the ground, depending upon the frequency. • Mean smoothed sunspot number: 100. This is an acceptable average over the entire sunspot cycle. • SNR threshold: 40 dB for SSB (voice) communications, and 24 db for CW (Morse code) communications. These are minimum accepted values for transmissions. Page 6 of 15 The two sets of transmitting antenna heights considered in each sample were: • The existing antenna system currently in place at their specified heights (marked ACTUAL). • A single reference yagi, of similar design, at 30 feet (marked LOW). The geographic target for each test was specified. These are some of the easier geographic targets to reach from Oregon, and it requires lower antenna heights than the more difficult paths to specific parts of Africa and portions of Asia. In the discussion that follows, 57% is used as the minimum acceptable reliability (REL) value, i.e. successful communications is defined as a path reliability of 57% or greater — four or more days a week out of seven -- of otherwise available time (blackout times are not included) under the changing variables that impact amateur radio communications. This is a very conservative service goal, as Snook v. Missouri City (Texas), an amateur radio case tried in the U.S. District Court, Southern District of Texas (2003), accepted a service reliability standard of 75-90%. Page 7 of 15 Map Set l —14 MHz to Europe Variable parameters: • Local time and date of simulation: December 01, 16:00 UTC. • Communication Mode: Single Sideband (SSB) Referring to Figure 1, signals to Warsaw, Poland, Helsinki Finland and other European countries meet the objective of 57% reliability with the existing at 89 feet however the criteria is not met for portions of Europe further east, such as Moscow, and Kiev. Referring to Figure 2, with a single antenna at 30 feet, the reliable coverage area is dramatically reduced. Areas previously covered, such as Helsinki, Finland and Warsaw, Poland are no longer meeting the desired 57% reliability criteria. Exit Print to, Clipboard Color Boundaries Parameter Help ick (x.y) location for readout BEND, OREGON [7N20EU89 1 1.4kW 29deg areadata 20W 10W OE 10E 20E 300 40E 50E 600 7011 70E 16ut 14.000MHz Dec 100ssn REL areadata\default\ws7n20eu1.V21 800 60N 90E Version 07.1025W 90E NOVOSIBIRSK, USSR 80E 5011 200 1000 1500 2000 30E 2500 40E 3000 3500 4000 50E 4500 5000[0! VOACAP Time availability SNR > Req SNR I%) 86 '71 57 43 29 14 14 Min= 0.00 Max= 94.90 CCIR coefficients 31x 31 gridsize NTIA/ITS Figure 1. To Europe, 14 MHz antennas at 89 feet (ACTUAL) Page 8 of 15 :Aro bit Print-to{lipbeard',Kolar ±Roundanes 'Parameter Help ick (icy) location for readout areadata BEND, OREGON [7N20EU30 ] 1.4kW 29deg l6ut 14.000MHz Dec 100ssn REL areadata\default\ws7n20eu2.V21 1014 OE 10E 20E 30E 40E SOE 60E 70N 70E 001 608 90E Version 07.1025W 90E 508 10E 0 Sao 20E 1000 1500 301 2000 2500 40E 3000 3500 50E 4000 4500 5000t06 VOACAP Time: availability SNR > Reg SNR [9] > 86 > 71 > 57 > 43 > 29 > 14 > 14 Min= 0.00 Max= 84.70 CCIR coefficients 31x 31 gridsize NTIA/ITS Figure 2: To Europe, 14 MHz, antenna at 30 feet (LOW) Page 9 of 15 Map Set 2 — 7 MHz to Europe Variable parameters for 7 MHz to Europe: • Local time and date of simulation: December 01, 04:00 UTC. This frequency (7 MHz) requires a dark, night-time path for long distance communications. • Communication Mode: Continuous Wave (CW) Referring to Figure 3 below, signals meet the objective with the existing antenna at 125 feet for 57% or greater reliability for a portion of Europe. Some areas of the Middle East have limited coverage. As seen in Figure 4, the LOW antenna coverage is unacceptable compared to the higher antenna in the existing installation. Many areas of Europe are well below acceptable reliability levels, and the entire Middle East now falls below the reliability criteria. • 4E* Print to Clipboard ' Color •Qoundaries Parameter Help Pick (xy) location for readout BEND, OREGON [7NEU125 ] 1.4kW 29deg 04ut 7.000MHz Dec 100ssn REL areadata areadata\default\ws7n7eu1.V21 308 708 108 OE 10E 20E 30E 40E 50E 708 70E 008 60N 90E 50N 100E 308 608 208 50N 108 40N 30N 208 100E 4010 HINA 90E 30N AR. 0iEt.HI, CCIR coefficients 31x 31 gridsize 2010 70E 10N 0E 0 1000 10E 2000 20E 3000 30E 4000 40E 5000 50E 10N 6000 60E 7000 0000000 Version 07.102SW VOACAP Time availability SNR > Req SNR [9] > 86 > 71 > 57 > 43 > 29 > 14 > 14 Min= 0.00 Max= 99.90 NTIA/ITS Figure 3. To Europe, 40 meters, Yagi at 125' (ACTUAL) Page 10 of 15 Exit Print to Clipboard Solor-¢oundaries Parameter °:Hdp • ick (x.y) location for readout areadata BEND, OREGON [7N40EU2 ] 1.4kW 29deg 04ut 7.000MHz Dec 100ssn REL areadata\default\ws7n7eu2.V21 301 70N 10W OE 10E 20E 30E 40E 50E 70N 70E 80E 60N 90E 50N 100E 0E 10E 20E 306 1000 2000 3000 4000 0 406 5000 50E 10N 6000 60E 7000 30N AR. abis 8I, CCIR coefficients 31x 31 gridsize 8000145 Version 07.1025W VOACAP Time availability SNR > Reg SNR It] > 86 > 71 > 57 > 43 > 29 > 14 > 14 Min= 0.00 Mas= 98.30 MIA/ITS Figure 4. To Europe, 7 MHz, single Yagi at 30' (LOW) Page 11 of 15 Map Set 3 — 3.5 MHz to Japan and Asia Variable parameters for 3.5 MHz to Japan and Asia • Local time and date of simulation: December 01, 15:00 UTC. This frequency (3.5 MHz) requires a dark, night-time path for long distance communications. • Communication Mode: Continuous Wave (CW) Referring to Figure 5 below, signals to Tokyo, Japan meet the objective with the existing antenna at 125', providing 57% or greater reliability. Areas further to the West, such as Shanghai, Peking, and Hong Kong, China do not meet the objective, and would require a higher antenna height for improved reliability. As seen in Figure 6, the LOW antenna coverage is unacceptable compared to the higher antenna — coverage is essentially non-existent to the target region. Page 12 of 15 Exit Print to Clipboards; Color $oundaries Parameter ick (xy) location for readout BEND, OREGON [7NJA1 ] 1.4kW 303deg 15ut 3.500MHz Dec 100ssn areadata 100E 110E REL areadata\default\ws7n80jal.V21 120E 130E 140E 150E 160E 170E Version 07.1025W 120E 0 500 1000 130E 1500 2000 140E 2500 3000 150E 3500 4000 4500 500080 VOACAP Time availability SNR > Reg SNR [9] 1 1 ] > 86 > 71 > 57 > 43 > 29 > 14 > 14 Min= 0.00 Max= 100.00 CCIR coefficients 31x 31 gridsize NTIA/ITS Figure 5. To Japan and Asia, 3.5 MHz, dipole at 125' (ACTUAL) Page 13 of 15 , :E it Print ,!to Clipboard': 4olor $oundndes parameter Help Pick {xy) location for readout areadata 100E BEND, OREGON (7N80JA2 j 1.4kW 303deg 15ut 3.500MHz Dec 100ssn REL areadata\default\ws7n80ja2.V21 110E 120E 130E 140E 150E 160E 170E Version 07.1025W 170E 405 �� �i� 4011 3011 s . vxvrseo " v 30N 110E 120E 4 500 1000 130E 1500 2000 140E 2500 3000 150E 3500 4000 4500 5000Et VOACAP Time availability SNR > Req SNR It] > 86 > 71 > 57 > 43 > 29 > 14 > 14 Min= 0.00 Max= 99.10 CCIR coefficients 31x 31 gridsize NTIA/ITS Figure 6. To Japan and Asia, 3.5 MHz, Dipole at 30' (LOW) Page 14 of 15 High Frequency (HF) Communications Analysis Conclusions The heights of the antenna support structures and antennas were analyzed for the purpose of determining whether they would meet the need of the radio amateur operator. Commonly used engineering metrics were employed to determine the effectiveness of communications. The 130 foot and 89 foot antenna support structures, which support the 14, 7 and 3.5 MHz antennas, marginally meet the need for reliable communications to Europe, Japan and Asia. Ideally, taller towers should be utilized to provide coverage at 7 and 3.5 MHz, however apparently Mr. Swaney is willing to live with his existing height structures, despite the limitations they present, as an acceptable compromise. Lowering any of the antennas to 30 feet does not meet Mr. Swaney's needs on any frequency and does not provide reliable coverage to the desired target geographic areas. Respectfully submitted, James A. Nitzberg, BSEE A reprint of "Antenna Height and Communications Effectiveness" follows. It is an engineering study by the technical staff of the American Radio Relay League (ARRL), and provides the basic technical background as to why higher antennas perform more reliably. Page 15 of 15 Antenna Height and Communications Effectiveness Second Edition A Guide for City Planners and Amateur Radio Operators By R. Dean Straw, N6BV, and Gerald L. Hall, K1TD Senior Assistant Technical Editor and Retired Associate Technical Editor Copyright ©1999 The American Radio Relay League, Inc. 225 Main Street Newington, CT 06111 Executive Summary Amateur radio operators, or "hams" as they are called, communicate with stations located all over the world. Some contacts may be local in nature, while others may be literally halfway around the world. Hams use a variety of internationally allocated frequencies to accomplish their communications. Except for local contacts, which are primarily made on Very High and Ultra High Frequencies (VHF and UHF), communicating between any two points on the earth rely primarily on high -frequency (HF) signals propagating through the ionosphere. The earth's ionosphere acts much like a mirror at heights of about 150 miles. The vertical angle of radiation of a signal launched from an antenna is one of the key factors determining effective communication distances. The ability to communicate over long distances generally requires a low radiation angle, meaning that an antenna must be placed high above the ground in terms of the wavelength of the radio wave being transmitted. A beam type of antenna at a height of 70 feet or more will provide greatly superior performance over the same antenna at 35 feet, all other factors being equal. A height of 120 feet or even higher will provide even more advantages for long-distance communications. To a distant receiving station, a transmitting antenna at 120 feet will provide the effect of approximately 8 to 10 times more transmitting power than the same antenna at 35 feet. Depending on the level of noise and interference, this performance disparity is often enough to mean the difference between making distant radio contact with fairly reliable signals, and being unable to make distant contact at all. Radio Amateurs have a well-deserved reputation for providing vital communications in emergency situations, such as in the aftermath of a severe icestorm, a hurricane or an earthquake. Short-range communications at VHF or UHF frequencies also require sufficient antenna heights above the local terrain to ensure that the antenna has a clear horizon. In terms of safety and aesthetic considerations, it might seem intuitively reasonable for a planning board to want to restrict antenna installations to low heights. However, such height restrictions often prove very counterproductive and frustrating to all parties involved. If an amateur is restricted to low antenna heights, say 35 feet, he will suffer from poor transmission of his own signals as well as poor reception of distant signals. In an attempt to compensate on the transmitting side (he can't do anything about the poor reception problem), he might boost his transmitted power, say from 150 watts to 1,500 watts, the maximum legal limit. This ten -fold increase in power will very significantly increase the potential for interference to telephones, televisions, VCRs and audio equipment in his neighborhood. Instead, if the antenna can be moved farther away from neighboring electronic devices— putting it higher, in other words—this will greatly reduce the likelihood of interference, which decreases at the inverse square of the distance. For example, doubling the distance reduces the potential for interference by 75%. As a further benefit, a large antenna doesn't look anywhere near as large at 120 feet as it does close-up at 35 feet. As a not -so -inconsequential side benefit, moving an antenna higher will also greatly reduce the potential of exposure to electromagnetic fields for neighboring human and animals. Interference and RF exposure standards have been thoroughly covered in recently enacted Federal Regulations. Page 1 Antenna Height and Communications Effectiveness By R. Dean Straw, N6BV, and Gerald L. Hall, K1 TD Senior Assistant Technical Editor and Retired Associate Technical Editor The purpose of this paper is to provide general information about communications effectiveness as related to the physical height of antennas. The intended audience is amateur radio operators and the city and town Planning Boards before which a radio amateur must sometimes appear to obtain building permits for radio towers and antennas. The performance of horizontally polarized antennas at heights of 35, 70 and 120 feet is examined in detail. Vertically polarized arrays are not considered here because at short-wave frequencies, over average terrain and at low radiation angles, they are usually less effective than horizontal antennas. Ionospheric Propagation Frequencies between 3 and 30 megahertz (abbreviated MHz) are often called the "short- wave" bands. In engineering terms this range of frequencies is defined as the high frequency or HF portion of the radio spectrum. HF radio communications between two points that are separated by more than about 15 to 25 miles depend almost solely on propagation of radio signals through the ionosphere. The ionosphere is a region of the Earth's upper atmosphere that is ionized primarily by ultraviolet rays from the Sun. The Earth's ionosphere has the property that it will refract or bend radio waves passing through it. The ionosphere is not a single "blanket" of ionization. Instead, for a number of complex reasons, a few discrete layers are formed at different heights above the earth. From the standpoint of radio propagation, each ionized layer has distinctive characteristics, related primarily to different amounts of ionization in the various layers. The ionized layer that is most useful for HF radio communication is called the F layer. The F layer exists at heights varying from approximately 130 to 260 miles above the earth's surface. Both the layer height and the amount of ionization depend on the latitude from the equator, the time of day, the season of the year, and on the level of sunspot activity. Sunspot activity varies generally in cycles that are approximately 11 years in duration, although short- term bursts of activity may create changes in propagation conditions that last anywhere from a few minutes to several days. The ionosphere is not homogeneous, and is undergoing continual change. In fact, the exact state of the ionosphere at any one time is so variable that is best described in statistical terms. The F layer disappears at night in periods of low and medium solar activity, as the ultraviolet energy required to sustain ionization is no longer received from the Sun. The amount that a passing radio wave will bend in an ionospheric layer is directly related to the intensity of ionization in that layer, and to the frequency of the radio wave. A triangle may be used to portray the cross-sectional path of ionospheric radio -wave travel, as shown in Fig 1, a highly simplified picture of what happens in propagation of radio waves. The base of the triangle is the surface of the Earth between two distant points, and the apex of the triangle is the point representing refraction in the ionosphere. If all the necessary conditions are Page 2 met, the radio wave will travel from the first point on the Earth's surface to the ionosphere, where it will be bent (refracted) sufficiently to travel to the second point on the earth, many hundreds of miles away. n �� /\ \ \ ...- / \ Actual T �/ \ Virtual Height Height Fig 1—A simplified cross-sectional representation of ionospheric propagation. The simple triangle goes from the Transmitter T up to the virtual height and then back down to the Receiver R. Typically the F layer exists at a height of 150 miles above the Earth at mid -latitudes. The distance between T and R may range from a few miles to 2500 miles under normal propagation conditions. Of course the Earth's surface is not a flat plane, but instead is curved. High -frequency radio waves behave in essentially the same manner as light waves—they tend to travel in straight lines, but with a slight amount of downward bending caused by refraction in the air. For this reason it is not possible to communicate by a direct path over distances greater than about 15 to 25 miles in this frequency range, slightly farther than the optical horizon. The curvature of the earth causes the surface to "fall away" from the path of the radio wave with greater distances. Therefore, it is the ionosphere that permits HF radio communications to be made between points separated by hundreds or even thousands of miles. The range of frequencies from 3 to 30 MHz is unique in this respect, as ionospheric propagation is not consistently supported for any frequencies outside this range. One of the necessary conditions for ionospheric communications is that the radio wave must encounter the ionosphere at the correct angle. This is illustrated in Fig 2, another very simplified drawing of the geometry involved. Radio waves leaving the earth at high elevation angles above the horizon may receive only very slight bending due to refraction, and are then lost to outer space. For the same fixed frequency of operation, as the elevation angle is lowered toward the horizon, a point is reached where the bending of the wave is sufficient to return the wave to the Earth. At successively lower angles, the wave returns to the Earth at increasing distances. Page 3 Fig 2—Behavior of radio waves encountering the ionosphere. Rays entering the ionized region at angles above the critical angle are not bent enough to return to Earth and are lost to space. Waves entering at angles below the critical angle reach the Earth at increasingly greater distances as the angle approaches the horizontal. The maximum distance that may normally be covered in a single hop is 2500 miles. Greater distances may be covered with multiple hops. If the radio wave leaves the earth at an elevation angle of zero degrees, just toward the horizon (or just tangent to the earth's surface), the maximum distance that may be reached under usual ionospheric conditions is approximately 2,500 miles (4,000 kilometers). However, the Earth itself also acts as a reflector of radio waves coming down from the ionosphere. Quite often a radio signal will be reflected from the reception point on the Earth back into the ionosphere again, reaching the Earth a second time at a still more distant point. As in the case of light waves, the angle of reflection is the same as the angle of incidence, so a wave striking the surface of the Earth at an angle of, say, 15° is reflected upward from the surface at the same angle. Thus, the distance to the second point of reception will be approximately twice the distance of the first. This effect is also illustrated in Fig 2, where the signal travels from the transmitter at the left of the drawing via the ionosphere to Point A, in the center of the drawing. From Point A the signal travels via the ionosphere again to Point B, at the right. A signal traveling from the Earth through the ionosphere and back to the Earth is called a hop. Under some conditions it is possible for as many as four or five signal hops to occur over a radio path, but no more than two or three hops is the norm. In this way, HF communications can be conducted over thousands of miles. Page 4 With regard to signal hopping, two important points should be recognized. First, a significant loss of signal occurs with each hop. Lower layers of the ionosphere absorb energy from the signals as they pass through, and the ionosphere tends to scatter the radio energy in various directions, rather than confining it to a tight bundle. The earth also scatters the energy at a reflection point. Thus, only a small fraction of the transmitted energy actually reaches a distant receiving point. Again refer to Fig 2. Two radio paths are shown from the transmitter to Point B, a one -hop path and a two -hop path. Measurements indicate that although there can be great variation in the ratio of the two signal strengths in a situation such as this, the signal power received at Point B will generally be from five to ten times greater for the one -hop wave than for the two -hop wave. (The terrain at the mid -path reflection point for the two -hop wave, the angle at which the wave is reflected from the earth, and the condition of the ionosphere in the vicinity of all the refraction points are the primary factors in determining the signal -strength ratio.) Signal levels are generally compared in decibels, abbreviated dB. The decibel is a logarithmic unit. Three decibels difference in signal strengths is equivalent to a power ratio of 2:1; a difference of 10 dB equates to a power ratio of 10:1. Thus the signal loss for an additional hop is about 7 to 10 dB. The additional loss per hop becomes significant at greater distances. For a simplified example, a distance of 4,000 miles can be covered in two hops of 2,000 miles each or in four hops of 1,000 miles each. For illustration, assume the loss for additional hops is 10 dB, or a 1/10 power ratio. Under such conditions, the four -hop signal will be received with only 1/100 the power or 20 dB below that received in two hops. The reason for this is that only 1/10 of the two - hop signal is received for the first additional (3rd) hop, and only 1/10 of that 1/10 for the second additional (4th) hop. It is for this reason that no more than four or five propagation hops are useful; the received signal eventually becomes too weak to be heard. The second important point to be recognized in multihop propagation is that the geometry of the first hop establishes the geometry for all succeeding hops. And it is the elevation angle at the transmitter that sets up the geometry for the first hop. It should be obvious from the preceding discussion that one needs a detailed knowledge of the range of elevation angles for effective communication in order to do a scientific evaluation of a possible communications circuit. The range of angles should be statistically valid over the full 11 -year solar sunspot cycle, since the behavior of the Sun determines the changes in the nature of the Earth's ionosphere. ARRL did a very detailed computer study in the early 1990s to determine the angles needed for propagation throughout the world. The results of this study will be examined later, after we introduce the relationship between antenna height and the elevation pattern for an antenna. Horizontal Antennas Over Flat Ground A simple antenna that is commonly used for HF communications is the horizontal half -wave dipole. The dipole is a straight length of wire (or tubing) into which radio-frequency energy is fed at the center. Because of its simplicity, the dipole may be easily subjected to theoretical performance analyses. Further, the results of proper analyses are well borne out in practice. For these reasons, the half -wave dipole is a convenient performance standard against which other antenna systems can be compared. Because the earth acts as a reflector for HF radio waves, the directive properties of any antenna are modified considerably by the ground underneath it. If a dipole antenna is placed horizontally above the ground, most of the energy radiated downward from the dipole is Page 5 reflected upward. The reflected waves combine with the direct waves (those radiated at angles above the horizontal) in various ways, depending on the height of the antenna, the frequency, and the electrical characteristics of the ground under and around the antenna. At some vertical angles above the horizon, the direct and reflected waves may be exactly in phase—that is, the maximum signal or field strengths of both waves are reached at the same instant at some distant point. In this case the resultant field strength is equal to the stun of the two components. At other vertical angles the two waves may be completely out of phase at some distant point—that is, the fields are maximum at the same instant but the phase directions are opposite. The resultant field strength in this case is the difference between the two. At still other angles the resultant field will have intermediate values. Thus, the effect of the ground is to increase the intensity of radiation at some vertical angles and to decrease it at others. The elevation angles at which the maxima and minima occur depend primarily on the antenna height above ground. (The electrical characteristics of the ground have some slight effect too.) For simplicity here, we consider the ground to be a perfectly conducting, perfectly flat reflector, so that straightforward trigonometric calculations can be made to determine the relative amount of radiation intensity at any vertical angle for any dipole height. Graphs from such calculations are often plotted on rectangular axes to show best resolution over particularly useful ranges of elevation angles, although they are also shown on polar plots so that both the front and back of the response can be examined easily. Fig 3 shows an overlay of the polar elevation - pattern responses of two dipoles at different heights over perfectly conducting flat ground. The lower dipole is located a half wavelength above ground, while the higher dipole is located one wavelength above ground. The pattern of the lower antenna peaks at an elevation angle of about 30°, while the higher antenna has two main lobes, one peaking at 15° and the other at about 50° elevation angle. Dipole, 1 -Wave High O. dB Dipole, 1/2 -Wave High 0 deg. Fig 3–Comparison of elevation responses for two dipoles: one %-wavelength high, and the other 1 -wavelength high. In the plots shown in Fig 3, the elevation angle above the horizon is represented in the same fashion that angles are measured on a protractor. The concentric circles are calibrated to represent ratios of field strengths, referenced to the strength represented by the outer circle. The circles are calibrated in decibels. Diminishing strengths are plotted toward the center. Page 6 You may have noted that antenna heights are often discussed in terms of wavelengths. The reason for this is that the length of a radio wave is inversely proportional to its frequency. Therefore a fixed physical height will represent different electrical heights at different radio frequencies. For example, a height of 70 feet represents one wavelength at a frequency of 14 MHz. But the same 70 -foot height represents a half wavelength for a frequency of 7 MHz and only a quarter wavelength at 3.5 MHz. On the other hand, 70 feet is 2 wavelengths high at 28 MHz. The lobes and nulls of the patterns shown in Fig 3 illustrate what was described earlier, that the effect of the ground beneath an antenna is to increase the intensity of radiation at some vertical elevation angles and to decrease it at others. At a height of a half wavelength, the radiated energy is strongest at a rather high elevation angle of 30°. This would represent the situation for a 14 -MHz dipole 35 feet off the ground. As the horizontal antenna is raised to greater heights, additional lobes are formed, and the lower ones move closer to the horizon. The maximum amplitude of each of the lobes is roughly equal. As may be seen in Fig 3, for an antenna height of one wavelength, the energy in the lowest lobe is strongest at 15°. This would represent the situation for a 14 -MHz dipole 70 feet high. The elevation angle of the lowest lobe for a horizontal antenna above perfectly conducting ground may be determined mathematically: 0 = sin-' 0.25 Where 0 = the wave or elevation angle h = the antenna height above ground in wavelengths In short, the higher the horizontal antenna, the lower is the lowest lobe of the pattern. As a very general rule of thumb, the higher an HF antenna can be placed above ground, the farther it will provide effective communications because of the resulting lower radiation angle. This is true for any horizontal antenna over real as well as theoretically perfect ground. You should note that the nulls in the elevation pattern can play an important role in communications—or lack of communication. If a signal arrives at an angle where the antenna system exhibits a deep null, communication effectiveness will be greatly reduced. It is thus quite possible that an antenna can be too high for good communications efficiency on a particular frequency. Although this rarely arises as a significant problem on the amateur bands below 14 MHz, we'll discuss the subject of optimal height in more detail later. Actual earth does not reflect all the radio-frequency energy striking it; some absorption takes place. Over real earth, therefore, the patterns will be slightly different than those shown in Fig 3, however the differences between theoretical and perfect earth ground are not significant for the range of elevation angles necessary for good HF communication. Modern computer programs can do accurate evaluations, taking all the significant ground -related factors into account. Beam Antennas For point-to-point communications, it is beneficial to concentrate the radiated energy into a beam that can be aimed toward a distant point. An analogy can be made by comparing the light Page 7 from a bare electric bulb to that from an automobile headlight, which incorporates a built-in focusing lens. For illuminating a distant point, the headlight is far more effective. Antennas designed to concentrate the radiated energy into a beam are called, naturally enough, beam antennas. For a fixed amount of transmitter power fed to the transmitting antenna, beam antennas provide increased signal strength at a distant receiver. In radio communications, the use of a beam antenna is also beneficial during reception, because the antenna pattern for transmission is the same for reception. A beam antenna helps to reject signals from unwanted directions, and in effect boosts the strength of signals received from the desired direction. The increase in signal or field strength a beam antenna offers is frequently referenced to a dipole antenna in free space (or to another theoretical antenna in free space called an isotropic antenna) by a term called gain. Gain is commonly expressed in decibels. The isotropic antenna is defined as being one that radiates equally well in all directions, much like the way a bare lightbulb radiates essentially equally in all directions. One particularly well known type of beam antenna is called a Yagi, named after one of its Japanese inventors. Different varieties of Yagi antennas exist, each having somewhat different characteristics. Many television antennas are forms of multi -element Yagi beam antennas. In the next section of this paper, we will refer to a four -element Yagi, with a gain of 8.5 dBi in free space, exclusive of any influence due to ground. This antenna has 8.5 dB more gain than an isotropic antenna in free space and it achieves that gain by squeezing the pattern in certain desired directions. Think of a normally round balloon and imagine squeezing that balloon to elongate it in one direction. The increased length in one direction comes at the expense of length in other directions. This is analogous to how an antenna achieves more signal strength in one direction, at the expense of signal strength in other directions. The elevation pattern for a Yagi over flat ground will vary with the electrical height over ground in exactly the same manner as for a simpler dipole antenna. The Yagi is one of the most common antennas employed by radio amateurs, second in popularity only to the dipole. Putting the Pieces Together In Fig 4, the elevation angles necessary for communication from a particular transmitting site, in Boston, Massachusetts, to the continent of Europe using the 14 -MHz amateur band are shown in the form of a bargraph. For each elevation angle from 1° to 30°, Fig 4 shows the percentage of time when the 14 -MHz band is open at each elevation angle. For example, 5° is the elevation angle that occurs just over 12% of the time when the band is available for communication, while 11° occurs about 10% of the time when the band is open. The useful range of elevation angles that must accommodated by an amateur station wishing to talk to Europe from Boston is from 1° to 28°. In addition to the bar -graph elevation -angle statistics shown in Fig 4, the elevation pattern responses for three Yagi antennas, located at three different heights above flat ground, are overlaid on the same graph. You can easily see that the 120 -foot antenna is the best antenna to cover the most likely angles for this particular frequency, although it suffers at the higher elevation angles on this particular propagation path, beyond about 12°. If, however, you can accept somewhat lower gain at the lowest angles, the 70 -foot antenna would arguably be the best overall choice to cover all the elevation angles. Page 8 Other graphs are needed to show other target receiving areas around the world. For comparison, Fig 5 is also for the 14 -MHz band, but this time from Boston to Sydney, Australia. The peak angle for this very long path is about 2°, occurring 19% of the time when the band is actually open for communication. Here, even the 120 -foot high antenna is not ideal. Nonetheless, at a moderate 5° elevation angle, the 120 -foot antenna is still 10 dB better than the one at 35 feet. Fig 4 and Fig 5 have portrayed the situation for the 14 -MHz amateur band, the most popular and heavily utilized HF band used by radio amateurs. During medium to high levels of solar sunspot activity, the 21 and 28 -MHz amateur bands are open during the daytime for long- distance communication. Fig 6 illustrates the 28 -MHz elevation -angle statistics, compared to the elevation patterns for the same three antenna heights shown in Fig 5. Clearly, the elevation response for the 120 -foot antenna has a severe (and undesirable) null at 8°. The 120 -foot antenna is almost 3.4 wavelengths high on 28 MHz (whereas it is 1.7 wavelengths high on 14 MHz.) For many launch angles, the 120 -foot high Yagi on 28 MHz would simply be too high. The radio amateur who must operate on a variety of frequencies might require two or more towers at different heights to maintain essential elevation coverage on all the authorized bands. Antennas can sometimes be mounted at different heights on a single supporting tower, although it is more difficult to rotate antennas that are "vertically stacked” around the tower to point in all the needed directions. Further, closely spaced antennas tuned to different frequencies usually interact electrically with each other, often causing severe performance degradation. Page 9 Antenna Response Versus Height 14 MHz, Boston to Europe 32 16 28 -„,+::-s 'tea 14 t.fi-*'r 24 - J •7/• v -,r s • 12 co 20 — �/ }�F `\ 10 • 216 / V' rt \4 /-- 8 0 12 — j r i y ! l 6 8--i 4 4-- \ :0 2 I I I I I I I III III I I III 0 i l��l l1�l,l.l. 1 In 1 1 1'1 1 1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 Elevation Angle, Degrees % of Openings -F 120' Yagi -- 70' Yagi -1-- 35' Yagi 1 Fig 4—Elevation response patterns of three Yagis at 120, 70 and 35 feet, at 14 MHz over flat ground. The patterns are overlaid with the statistical elevation - angles for the path from Boston to continental Europe over the entire 11 -year solar sunspot cycle. Clearly, the 120 -foot antenna is the best choice to cover the low angles needed, but it suffers some at higher angles. Other graphs are needed to show other target receiving areas around the world. For comparison, Fig 5 is also for the 14 -MHz band, but this time from Boston to Sydney, Australia. The peak angle for this very long path is about 2°, occurring 19% of the time when the band is actually open for communication. Here, even the 120 -foot high antenna is not ideal. Nonetheless, at a moderate 5° elevation angle, the 120 -foot antenna is still 10 dB better than the one at 35 feet. Fig 4 and Fig 5 have portrayed the situation for the 14 -MHz amateur band, the most popular and heavily utilized HF band used by radio amateurs. During medium to high levels of solar sunspot activity, the 21 and 28 -MHz amateur bands are open during the daytime for long- distance communication. Fig 6 illustrates the 28 -MHz elevation -angle statistics, compared to the elevation patterns for the same three antenna heights shown in Fig 5. Clearly, the elevation response for the 120 -foot antenna has a severe (and undesirable) null at 8°. The 120 -foot antenna is almost 3.4 wavelengths high on 28 MHz (whereas it is 1.7 wavelengths high on 14 MHz.) For many launch angles, the 120 -foot high Yagi on 28 MHz would simply be too high. The radio amateur who must operate on a variety of frequencies might require two or more towers at different heights to maintain essential elevation coverage on all the authorized bands. Antennas can sometimes be mounted at different heights on a single supporting tower, although it is more difficult to rotate antennas that are "vertically stacked” around the tower to point in all the needed directions. Further, closely spaced antennas tuned to different frequencies usually interact electrically with each other, often causing severe performance degradation. Page 9 Page 10 Antenna Response Versus Height 14 MHz, Boston to Sydney, Australia 32 % of Openings A 00 N q O A O000 28- 24 to 20 8.16 0 -1„' - 1 1 r }{ - r 1 1 0 - s ll,11 ,r- � X, \ r \� / \\ y 1� a 111 1 1 1 1 16 14 12 10 8 4 2 % of Openings -F 120' Yagi -+- 70' Yagi --rte 35' Yagi 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 , 0 1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 Elevation Angle, Degrees % of Openings -n- 120' Yagi f- 70' Yagi -v-- 35' Yagi 1 Fig 5—Elevation responses for same antennas as Fig 4, but for a longer -range path from Boston to Sydney, Australia. Note that the prevailing elevation angles are very low. Page 10 Antenna Response Versus Height 28 MHz, Boston to Europe 37 % of Openings A 00 N q O A O000 -f�f= i ItIiII;i1iiIi4Li;L:::; 16 12 6 I i P I'rIII 1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 Elevation Angle, Degrees 0 % of Openings -F 120' Yagi -+- 70' Yagi --rte 35' Yagi 1 Fig 6—Elevation angles compared to antenna responses for 28 -MHz path from Boston to Europe. The 70 -foot antenna is probably the best overall choice on this path. Page 10 During periods of low to moderate sunspot activity (about 50% of the 11 -year solar cycle), the 14 -MHz band closes down for propagation in the early evening. A radio amateur wishing to continue communication must shift to a lower frequency band. The next most highly used band below the 14 -MHz band is the 7 -MHz amateur band. Fig 7 portrays a 7 -MHz case for another transmitting site, this time from San Francisco, California, to the European continent. Now, the range of necessary elevation angles is from about 1° to 16°, with a peak statistical likelihood of about 16% occurring at an elevation of 3°. At this low elevation angle, a 7 -MHz antenna must be very high in the air to be effective. Even the 120 -foot antenna is hardly optimal for the peak angle of 3°. The 200 -foot antenna shown would be far better than a 120 -foot antenna. Further, the 35 -foot high antenna is greatly inferior to the other antennas on this path and would provide far less capabilities, on both receiving and transmitting. What If the Ground Isn't Flat? In the preceding discussion, antenna radiation patterns were computed for antennas located over flat ground. Things get much more complicated when the exact local terrain surrounding a tower and antenna are taken into account. In the last few years, sophisticated ray -tracing computer models have become available that can calculate the effect that local terrain has on the elevation patterns for real-world HF installations—and each real-world situation is indeed different. Page 11 Antenna Response Versus Height 7 MHz, San Francisco to Europe 32 16 28 — x. t' ° a �`� 14 24 — . Ka, A:12 20 —,iit' ,a-10 _ 016— O �.e .0 8 o g 0 12--- rtf 6 8 — ai v`X 4 :11LIjJJ!11._, * MI 1 1'1 1 1 +1 1 1 1 1 1 1 1 2 0 1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 Elevation Angle, Degrees % of Openings -F 120' Yagi -a- 70' Yagi -$- 35' Yagi e- 200' Yagi Fig 7—Comparison of antenna responses for another propagation path: from San Francisco to Europe on 7 MHz. Here, even a 120 -foot high antenna is hardly optimal for the very low elevation angles required on this very long path. In fact, the 200 -foot high antenna is far better suited for this path. What If the Ground Isn't Flat? In the preceding discussion, antenna radiation patterns were computed for antennas located over flat ground. Things get much more complicated when the exact local terrain surrounding a tower and antenna are taken into account. In the last few years, sophisticated ray -tracing computer models have become available that can calculate the effect that local terrain has on the elevation patterns for real-world HF installations—and each real-world situation is indeed different. Page 11 For simplicity, first consider an antenna on the top of a hill with a constant slope downward. The general effect is to lower the effective elevation angle by an amount equal to the downslope of the hill. For example, if the downslope is –3° for a long distance away from the tower and the flat -ground peak elevation angle is 10° (due to the height of the antenna), then the net result will be 10° – 3° = 7° peak angle. However, if the local terrain is rough, with many bumps and valleys in the desired direction, the response can be modified considerably. Fig 8 shows the fairly complicated terrain profile for Jan Carman, K5MA, in the direction of Japan. Jan is located on one of the tallest hills in West Falmouth, Massachusetts. Within 500 feet of his tower is a small hill with a water tower on the top, and then the ground quickly falls away, so that at a distance of about 3000 feet from the tower base, the elevation has fallen to sea level, at 0 feet. The computed responses toward Japan from this location, using a 120- and a 70 -foot high Yagi, are shown in Fig 9, overlaid for comparison with the response for a 120 -foot Yagi over flat ground. Over this particular terrain, the elevation pattern for the 70 -foot antenna is actually better than that of the 120 -foot antenna for angles below about 3°, but not for medium angles! The responses for each height oscillate around the pattern for flat ground — all due to the complex reflections and diffractions occurring off the terrain. At an elevation angle of 5°, the situation reverses itself and the gain is now higher for the 120 -foot -high antenna than for the 70 -foot antenna. A pair of antennas on one tower would be required to cover all the angles properly. To avoid any electrical interactions between similar antennas on one tower, two towers would be much better. Compared to the flat -ground situation, the responses of real-world antenna can be very complicated due to the interactions with the local terrain. Page 12 Terrain Towards Japan, K5MA West Falmouth, MA on Cape Cod ,on Feet Above Sea Level t 0 0 O 0 t . \ 'j-- 6-1-- \ TT , 0 1000 2000 3000 4000 5000 6000 7000 8000 9000 10000 Feet From Tower Base Fig 8—Terrain profile from location of K5MA, Jan Carman, in West Falmouth, MA, towards Japan. This is a moderately complicated real-world terrain on one of the highest hills on Cape Cod. The computed responses toward Japan from this location, using a 120- and a 70 -foot high Yagi, are shown in Fig 9, overlaid for comparison with the response for a 120 -foot Yagi over flat ground. Over this particular terrain, the elevation pattern for the 70 -foot antenna is actually better than that of the 120 -foot antenna for angles below about 3°, but not for medium angles! The responses for each height oscillate around the pattern for flat ground — all due to the complex reflections and diffractions occurring off the terrain. At an elevation angle of 5°, the situation reverses itself and the gain is now higher for the 120 -foot -high antenna than for the 70 -foot antenna. A pair of antennas on one tower would be required to cover all the angles properly. To avoid any electrical interactions between similar antennas on one tower, two towers would be much better. Compared to the flat -ground situation, the responses of real-world antenna can be very complicated due to the interactions with the local terrain. Page 12 Fig 10 shows the situation for the same Cape Cod location, but now for 7 MHz. Again, it is clear that the 120 -foot high Yagi is superior by at least 3 dB (equivalent to twice the power) to the 70 -foot high antenna at the statistical elevation angle of 6°. However, the response of the real-world 120 -foot high antenna is still up some 2 dB from the response for an identical antenna over flat ground at this angle. On this frequency, the local terrain has helped boost the gain at the medium angles more than a similar antenna 120 feet over flat ground. The gain is even greater at lower angles, say at 1° elevation, where most signals take off, statistically speaking. Putting the antenna up higher, say 150 feet, will help the situation at this location, as would adding an additional Yagi at the 70 -foot level and feeding both antennas in phase as a vertical stack. Although the preceding discussion has been in terms of the transmitting antenna, the same principles apply when the antenna is used for reception. A high antenna will receive low -angle signals more effectively than will a low antenna. Indeed, amateur operators know very well that "If you can't hear them, you can't talk to them." Stations with tall towers can usually hear far better than their counterparts with low installations. The situation becomes even more difficult for the next lowest amateur band at 3.5 MHz, where optimal antenna heights for effective long-range communication become truly heroic! Towers that exceed 120 feet are commonplace among amateurs wishing to do serious 3.5 -MHz long-distance work. Page 13 Antenna Response Versus Height 14 MHz, K5MA QTH to Japan 32 28 • ,:r- - 16 14 F A' e 1EJT 0 12 - `t k' 6 8-� 4 \r i4 2 0 'IIIIIIII1'1111In1lI 0 I 1 I 1 I I I I 1 I 1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 Elevation Angle, Degrees % Openings -0- K5MA, 70' -+- K5MA 120' -- 120' Flat 1 Fig 9—Computed elevation responses of 120- and 70 -foot high Yagis, at the K5MA location on Cape Cod, in the direction of Japan and over flat ground, for comparison. The elevation response of the real-world antenna has been significantly modified by the local terrain. Fig 10 shows the situation for the same Cape Cod location, but now for 7 MHz. Again, it is clear that the 120 -foot high Yagi is superior by at least 3 dB (equivalent to twice the power) to the 70 -foot high antenna at the statistical elevation angle of 6°. However, the response of the real-world 120 -foot high antenna is still up some 2 dB from the response for an identical antenna over flat ground at this angle. On this frequency, the local terrain has helped boost the gain at the medium angles more than a similar antenna 120 feet over flat ground. The gain is even greater at lower angles, say at 1° elevation, where most signals take off, statistically speaking. Putting the antenna up higher, say 150 feet, will help the situation at this location, as would adding an additional Yagi at the 70 -foot level and feeding both antennas in phase as a vertical stack. Although the preceding discussion has been in terms of the transmitting antenna, the same principles apply when the antenna is used for reception. A high antenna will receive low -angle signals more effectively than will a low antenna. Indeed, amateur operators know very well that "If you can't hear them, you can't talk to them." Stations with tall towers can usually hear far better than their counterparts with low installations. The situation becomes even more difficult for the next lowest amateur band at 3.5 MHz, where optimal antenna heights for effective long-range communication become truly heroic! Towers that exceed 120 feet are commonplace among amateurs wishing to do serious 3.5 -MHz long-distance work. Page 13 The 3.5 and 7 -MHz amateur bands are, however, not always used strictly for long-range work. Both bands are crucial for providing communications throughout a local area, such as might be necessary in times of a local emergency. For example, earthquakes, tornadoes and hurricanes have often disrupted local communications—because telephone and power lines are down and because local police and fire -department VHF/UHF repeaters are thus knocked out of action. Radio amateurs often will use the 3.5 and 7 -MHz bands to provide communications out beyond the local area affected by the disaster, perhaps into the next county or the next metropolitan area. For example, an earthquake in San Francisco might see amateurs using emergency power providing communications through amateurs in Oakland across the San Francisco Bay, or even as far away as Los Angeles or Sacramento. These places are where commercial power and telephone lines are still intact, while most power and telephones might be down in San Francisco itself. Similarly, a hurricane that selectively destroys certain towns on Cape Cod might find amateurs in these towns using 3.5 or 7.0 MHz to contact their counterparts in Boston or New York. However, in order to get the emergency messages through, amateurs must have effective antennas. Most such relatively local emergency situations require towers of moderate height, less than about 100 feet tall typically. Antenna Height and Interference Extensive Federal Regulations cover the subject of interference to home electronic devices. It is an unfortunate fact of life, however, that many home electronic devices (such as stereos, TVs, telephones and VCRs) do not meet the Federal standards. They are simply inadequately designed to be resistant to RF energy in their vicinity. Thus, a perfectly legal amateur -radio transmitter may cause interference to a neighbor's VCR or TV because cost-saving shortcuts were taken in Page 14 Antenna Response Versus Height 7 MHz, K5MA QTH to Japan '4 % of Openings A o N Q, O A V. N C - ly i�v..4,-*:.:+ lit.,,,, .e_ yam % 'R`v 18 16 14 12 10 .ty 6 4 2 u I 1' I-1 1 1 1.1111111 1 1 1 1 1 1 1 1 1 1 1 1 I I I I I 0 1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 Elevation Angle, Degrees % Openings -II- K5MA, 70' + K5MA 120' -+ 120' Flat I Fig 10—Elevation response on 7 MHz from K5MA location towards Japan on 7 MHz. The 120 -foot high Yagi is definitely superior to the one only 70 -feet high. The 3.5 and 7 -MHz amateur bands are, however, not always used strictly for long-range work. Both bands are crucial for providing communications throughout a local area, such as might be necessary in times of a local emergency. For example, earthquakes, tornadoes and hurricanes have often disrupted local communications—because telephone and power lines are down and because local police and fire -department VHF/UHF repeaters are thus knocked out of action. Radio amateurs often will use the 3.5 and 7 -MHz bands to provide communications out beyond the local area affected by the disaster, perhaps into the next county or the next metropolitan area. For example, an earthquake in San Francisco might see amateurs using emergency power providing communications through amateurs in Oakland across the San Francisco Bay, or even as far away as Los Angeles or Sacramento. These places are where commercial power and telephone lines are still intact, while most power and telephones might be down in San Francisco itself. Similarly, a hurricane that selectively destroys certain towns on Cape Cod might find amateurs in these towns using 3.5 or 7.0 MHz to contact their counterparts in Boston or New York. However, in order to get the emergency messages through, amateurs must have effective antennas. Most such relatively local emergency situations require towers of moderate height, less than about 100 feet tall typically. Antenna Height and Interference Extensive Federal Regulations cover the subject of interference to home electronic devices. It is an unfortunate fact of life, however, that many home electronic devices (such as stereos, TVs, telephones and VCRs) do not meet the Federal standards. They are simply inadequately designed to be resistant to RF energy in their vicinity. Thus, a perfectly legal amateur -radio transmitter may cause interference to a neighbor's VCR or TV because cost-saving shortcuts were taken in Page 14 the design and manufacture of these home entertainment devices. Unfortunately, it is difficult to explain to an irate neighbor why his brand-new $1000 stereo is receiving the perfectly legitimate transmissions by a nearby radio operator. The potential for interference to any receiving device is a function of the transmitter power, transmitter frequency, receiver frequency, and most important of all, the proximity of the transmitter to the potential receiver. The transmitted field intensity decreases as the inverse square of the distance. This means that doubling the height of an antenna from 35 to 70 feet will reduce the potential for interference by 75%. Doubling the height again to 140 feet high would reduce the potential another 75%. Higher is better to prevent interference in the first place! Recently enacted Federal Regulations address the potential for harm to humans because of exposure to electromagnetic fields. Amateur -radio stations rarely have problems in this area, because they use relatively low transmitting power levels and intermittent duty cycles compared to commercial operations, such as TV or FM broadcast stations. Nevertheless, the potential for RF exposure is again directly related to the distance separating the transmitting antenna and the human beings around it. Again, doubling the height will reduce potential exposure by 75%. The higher the antenna, the less there will any potential for significant RF exposure. THE WORLD IS A VERY COMPLICATED PLACE It should be pretty clear by now that designing scientifically valid communication systems is an enormously complex subject. The main complications come from the vagaries of the medium itself, the Earth's ionosphere. However, local terrain can considerably complicate the analysis also. The main points of this paper may be summarized briefly: The radiation elevation angle is the key factor determining effective communication distances beyond line -of -sight. Antenna height is the primary variable under control of the station builder, since antenna height affects the angle of radiation. In general, placing an amateur antenna system higher in the air enhances communication capabilities and also reduces chances for electromagnetic interference with neighbors. Page 15 Attachment B American Red Cross September 11, 2002 President .lint Haynie The American Radio Ifela 225 Main Street Newington, CT 06111- 4 4 dent dim Haynie: Si 9 t c,roiit`1 oars° t{Ooa Faits Oman, Each year, on average. the American Rod Cross provides se, ice. in over 62,000 emerge its in &ariou$ places around the United States, Whether flood, fires. earthquakes, hurricanes, or man made afisaste:rs, the American Red Cross is them: to respond. As our corporate slogan states "Together, we can save a life", When the Red Cross asks On help from America's radio hams we get at.. Every time we ask, radio t rtzs volunteer the use of their SYatlons, irtclatdirtg antennas, and they volunteer their time. For this, and for the results they achieve for victims of tragedies, we are grateful. Your membership helps us at the disaster scent or from their home running emergency communications, t v°cn in an era o{ links in disaster stricken t ttztattacaras ysternsequ:ivate s and satellite communications, amateur radio continues to provide . When the emergency arias, it is too Tata to build or transport hose available in the existing stock ofzraattctrr radio stations. We understand the; in smog tzc°y eorranzunu a2ti srts the rano € ( the key issues is to have trained y ctttortttaraie%ttors who have equipment and antennas set up for mast response, For this reason, we io Relay League when it sought preemption of zoning and other beat pplied, act to inhibit efe live communications, We applauded mmunicat ions f:`csanmission :recognized an obvious tact of phys cs that effective communications is c fico a funeiion of height, For these re as of station antenna systems to p through Memoranda of I.indcrstanding War 11, and still current today. We encs` their regal; ti€ ns so they will not American Red Cross, and the pcx>p conununicationss tisr�stz h vii Sincere", Red Cross strongly supports amateur radio. drive local and long distance comrstunications, h the: American Radio Relay League dating batik before municipalities and Home Owner Associations to employ the needs ofamateur radio opersatork In emergencies, the need what radio amateurs provide - effective le nzs Telecom rsaunicatiotas i'aa cervices T ether, roti save as ie Ham radio operators tune in hurricane help I csmonitor.com 1 of 2 http://www.csmonitor.com/2005/0915/p12s02-stss.htm ( FHE LCi RI AN SCIENCE 11.1QTOR from the September 15, 2005 edition - http://www.csmonitor.com/2005/0915/p12s02-stss.html Ham radio operators tune in hurricane help By Barbara W. Carlson I Contributor to The Christian Science Monitor NEWINGTON, CONN. - Richard Webb, an amateur radio operator, was asleep on his air mattress at University Hospital in New Orleans during the aftermath of hurricane Katrina when he was awakened at 5 a.m. by a hospital administrator. As Mr. Webb tells it, "He told me we had a lady who was in labor, who had swum five blocks in that dirty, nasty water to the hospital because she saw lights there - people with flashlights moving around." Medical personnel said the baby needed to be delivered by caesarean section. But the hospital had limited power, no running water, no way to sterilize instruments, no way to perform such surgery. "We figured we had two hours to get her medevacked out of there" before the lives of mother and child would be in danger. "So I got on the radio and was talking to a fellow who was with the Coast Guard auxiliary in Cleveland, Ohio. I was working with him to arrange a medevac." Choppers did arrive in time, Webb says. The woman and another patient in need were evacuated successfully. Because the hospital had no landing pad, the two had to be lifted out in baskets lowered from the helicopters. Webb, who lived in nearby Slidell, La., had been summoned to his hurricane post by the hospital's head of emergency management. He's one of about 750 amateur radio operators, or "hams," who have been in and out of the five hurricane states since day one: Louisiana, Mississippi, Alabama, and parts of northern Florida and Texas, where evacuees are taking shelter. At least a thousand other hams throughout the nation have been involved in some way, relaying messages or assigning hams to various locations. They're all volunteers, all unpaid, and they do what they do because they want to. They train for disaster work; their FCC radio licenses mandate public service. In typical disaster conditions, agencies like the Red Cross, Salvation Army, the Federal Emergency Management Administration (FEMA), and local government bodies call on a state ham leader for volunteers when usual channels of communication are down or jammed. Katrina was different: It was far more vast. For the first time, the nonprofit American Radio Relay League (ARRL) set up a website and database to facilitate assigning hams. Pamela Taylor, who works as an events manager in Hampton Beach, N.H., got a call from FEMA and headed south on Sept. 9. She was deployed to a shelter in Ocean Springs, Miss., near Gulfport, before moving to New Orleans. The shelter was a church, well -supplied and maintained, with an abundance of volunteers. Her job was to radio for special needs, anything from a doctor to paper plates. Nights sometimes brought an emergency or two when a resident had to be removed, usually for alcohol or drug problems. Hams worked with the National Weather Service before and during the hurricane. They still are receiving and transmitting messages in shelters and other locations, alerting emergency agencies that a community needs water, that an elderly woman needs an ambulance, or 9/14/2005 9:59 PM Ham radio operators tune in hurricane help I csmonitor.com http://www.csmonitor.com/2005/0915/p12s02-stss.htm that sanitary conditions are in crisis. An estimated 600,000 FCC -licensed amateur radio operators live in the United States; about 162,000 are members of the ARRL, which was founded in 1904 and is located here in Newington, Conn. Nearby Hartford is where Hiram Percy Maxim, the father of amateur radio, experimented at sending messages across the city and then relaying them across the country. Long before e-mail, there was amateur radio. It evolved over the last century so that today, ham operators communicate with one another around the world. Allen Pitts, for example, the ARRL's media -relations manager, says he has spoken to fellow hams in 213 foreign countries or "political entities." That's the hobby part of hamdom. The serious and vital part is seen in the Amateur Radio Emergency Service (ARES). Trained ham operators are ready with their "go kits" of equipment, batteries, and energy bars. ARRL coordinates the work of the emergency operators. Hams were at ground zero in New York within hours, they were in Florida for the multiple hurricanes last year, and they handled communications in the Northeast blackout of 2003. Hams are volunteers. When they set sail for disasters, they pay their own way. Sometimes employers give them a paid leave or reimburse expenses. Hams' sacrifices are real, but the rewards are often intangible. Mark Conklin of Tulsa got time off as a sales manager for an appliance company to relay messages. At first he handled communications between the state department of emergency management and the highway patrol. Next he was assigned to the 1,200 evacuees transplanted to an Oklahoma National Guard camp. At the camp, he talked to an elderly woman who was crying because she was happy - "communications" had been able to get a pair of glasses for her. "For the first time in a week," she said, "I can see." Full HTML version of this story which may include photos, graphics, and related links www.csmonitor.com 1 Copyright © 2005 The Christian Science Monitor. All rights reserved. For permission to reprint/republish this article, please email Copyright 2 of 2 9/14/2005 9:59 PM MSNBC - Ham radio operators to the rescue after Katrina http://msnbc.msn.com/id/9228945/print/1/displaymode/1098/ 1 of 2 MSNBC.com Ham radio operators to the rescue after Katrina Amateur radio networks help victims of the hurricane By Gary Krakow Columnist MSNBC Updated: 6:12 p.m. ET Sept. 6, 2005 With telephones down and wireless service disrupted, at least one group of people did manage last week to use technology to come to the rescue of those in need. Often unsung, amateur radio operators regularly assist in emergency situations. Hurricane Katrina was no exception. For the past week, operators of amateur, or ham, radio have been instrumental in helping residents in the hardest hit areas, including saving stranded flood victims in Louisiana and Mississippi. Public service has always been a large part of being an amateur radio operator. All operators, who use two-way radios on special frequencies set aside for amateur use, must be tested and licensed by the federal government, which then issues them a unique call sign. (Mine is W2GSK.) Ham operators communicate using voice, computers, televisions and Morse code (the original digital communication mode.) Some hams bounce their signals off the upper regions of the atmosphere, so they can talk with hams on the other side of the world; others use satellites. Many use short-range, handheld radios that fit in their pockets. When disaster strikes, ham networks spring into action. The Amateur Radio Emergency Service (ARES) consists of licensed amateurs who have voluntarily registered their qualifications and equipment for communications duty in the public service. In this disaster a number of ham emergency stations and networks have been involved in providing information about this disaster - from WX4NHC, the amateur radio station at the National Hurricane Center to the Hurricane Watch Net, the Waterway Net, Skywarn and the Salvation Army Team Emergency Radio Network (SATERN). On Monday, Aug. 29, a call for help involving a combination of cell telephone calls and amateur radio led to the rescue of 15 people stranded by floodwaters on the roof of a house in New Orleans. Unable to get through an overloaded 911 system, one of those stranded called a relative in Baton Rouge. That person called another relative, who called the local American Red Cross. Using that Red Cross chapter's amateur radio station, Ben Joplin, WB5VST, was able to relay a request for help on the SATERN network via Russ Fillinger, W7LXR, in Oregon, and Rick Cain, W7KB, in Utah back to Louisiana, where emergency personnel were alerted. They rescued the 15 people and got them to a shelter. Such rescues were repeated over and over again. Another ham was part of the mix that same Monday when he heard over the same Salvation Army emergency network of a family of five trapped in an attic in Diamond Head, La. The family used a cell phone to call out. Bob Rathbone, AG4ZG, in Tampa, says he checked the address on a map and determined it was in an area struck by a storm surge. He called the Coast Guard search -and -rescue station in Clearwater, explained the situation and relayed the information. At this point, the Coast Guard office in New Orleans was out of 9/14/2005 9:48 PM MSNBC - Ham radio operators to the rescue after Katrina http://msnbc.msn.com/id/9228945/print/1/displaymode/1098/ commission. An hour later he received a return call from the South Haven Sheriff's Department in Louisiana, which informed him a rescue operation was under way. Another search -and -rescue operation involved two adults and a child stuck on a roof. The person was able to send a text message from a cell phone to a family member in Michigan. Once again, the Coast Guard handled the call. Relief work is not just relegated to monitoring radios for distress calls. The organization representing amateur radio operators, The American Radio Relay League or ARRL, now is seeking emergency volunteers to help supplement communication for American Red Cross feeding and sheltering operations in Mississippi, Alabama and the Florida Panhandle — as many as 200 locations in all. Hams who wish to volunteer their time and services should contact the Hurricane Katrina volunteer registration and message traffic database. And, for the first time, the federal government will help hams help others. The Corporation for National and Community Service (CNCS) will provide a $100,000 grant supplement to ARRL to support its emergency communication operators in states affected by Hurricane Katrina. The grant will help to fund what is being termed "Ham Aid," a new program to support amateur radio volunteers deployed in the field in disaster -stricken areas. One last note for ham operators in the stricken area: The FCC has announced that it's extending amateur license renewal deadlines until October 31, 2005. © 2005 MSNBC Interactive © 2005 MSNBC.com URL: http://msnbc.msn.com/id/9228945/ 2 of 2 9/14/2005 9:48 PM COM PIJTER tORLD mW i Y You may retrieve this story by entering QuickLink# 56636 Ham radio volunteers help re-establish communications after Katrina Some 700 operators are already at work, with more on the way News Story by Todd R. Weiss SEPTEMBER 06, 2005 (COMPUTERWORLD) - Volunteer ham radio operators are coming to the aid of relief agencies and emergency officials to help with badly needed communications in areas of Louisiana, Alabama and Mississippi ravaged early last week by Hurricane Katrina. With power still out in much of the region and telephone service restored in limited areas (see "Cell operators restore some network service in New Orleans") of New Orleans, the Mississippi cities of Biloxi and Gulfport, and other hard-hit areas, ham radio operators have been asked by the American Red Cross and other agencies to supplement communications at more than 200 storm shelters in Mississippi, Alabama and the Florida panhandle. Some 700 ham radio volunteers from around the nation are already at work helping in the efforts, with more on the way, said Allen Pitts, a spokesman for the 157,000 -member American Radio Relay League Inc. (ARRL), a nationwide amateur radio organization based in Newington, Conn. "This is going to be a marathon, not a sprint," Pitts said. "We have people there; we have more people coming." On Sunday, the American Red Cross asked for about 500 more radio operators to assist at shelters and food kitchens set up to aid evacuees, he said. The volunteers are driving to needed areas and meeting with officials at staging areas in Montgomery, Ala., and in Oklahoma and Texas, where they are being dispatched to disaster shelters, Pitts said. The ham radio operators travel to the disaster areas using their own vehicles and pay their own way, he said. Many of the volunteers sprung into action even before the storm struck the Gulf Coast, broadcasting as part of a "Hurricane Watch -Net" three days before deadly Hurricane Katrina slammed into the coast on Aug. 29, Pitts said. Ham radio equipment can be used in disaster areas even when power is out and phone lines, relays and other communications systems are down because the radios run on their own battery or generator power, Pitts said. "Each one is a complete transmission and reception center unto itself," he said. "It works when other stuff is broken. You give an amateur radio operator a battery, a radio and a piece of a coat hanger and they'll find a way to make it work." The volunteers carry their own fuel for their generators and bring all the equipment they need. Used ham radio systems can be bought for as little as $100, while newer, state-of-the-art hardware can run as high as $5,000, he said. Ham radio operators can also use their equipment with laptop -based computer software to help re- establish e-mail access over the Internet to further assist with communications, Pitts said. Other disaster assistance agencies, including the Salvation Army, the Federal Emergency Management Agency, the U.S. Coast Guard and the Department of Homeland Security, have also sought help from ham radio operators, Pitts said. Late last week, the Washington -based Corporation for National and Community Service, a federal agency for volunteer service, announced a supplemental $100,000 grant to help ARRL volunteers with their expenses as they travel to and stay in the areas where hurricane victims are receiving assistance. "With the breakdown of regular communication channels caused by the storm, the services provided by volunteer ham radio operators [are] vitally important, both to organizations and to individuals seeking to connect with loved ones," agency CEO David Eisner said in a statement. "We're pleased to be able to provide this extra assistance at this critical time." The money will be used as part of the ARRL's "Ham Aid" program, established with a grant from the Corporation in 2002 to increase emergency certification training for ham radio operators. Mary Hobart, chief development officer at the ARRL, said in a statement that this marks the first time in the ARRL's 90 -year history that it will be able to reimburse some of the expenses incurred by members responding to disasters. Volunteer radio operators will be at various sites for the duration of this disaster response, which could run into several weeks or months, according to the group. Several ARRL members have already played key roles in the rescue efforts by connecting storm victims with emergency responders. In one such incident, a radio operator helped organize the rescue of 15 people stranded by floodwaters on the roof of a house in New Orleans, according to an ARRL statement. Source: http://www.computerworld.com/printthis/2005/0,4814,104418,00.html Copyright 2005 Ziff Davis Media Inc. All Rights Reserved ■ i I ■ ■ 1 1 I•■ ■ A 1 PC Magazine November 8, 2005 Tuesday OPINIONS 876 words Inside Track v24n19; John C. Dvorak The most overlooked participants in Katrina relief were the ham radio folks. Bush should give them all medals. Two weeks after Hurricane Katrina, it was reported that over 100 Internet networks were still down in Louisiana, as well as another dozen elsewhere that had been in the path of the hurricane. So much for the notion that the Web is impossible to kill. Hard to have an Internet with no power! WiMAX and other solutions are useless, too, though I suppose a generator would be useful for WiMAX. Whatever the case, the most overlooked participants in the Katrina relief effort were the ham radio folks, who were doing whatever they could as ad hoc emergency dispatchers, creating their own network within the system. These dedicated persons pride themselves on their ability to do worldwide communications under adverse conditions, and the ARRL (Amateur Radio Relay League) and its members, as well as others, were a big part of the aid effort. Of course, since amateur radio is anything but trendy in today's Xbox, gene -splicing world, there was zero coverage of its contribution in the mainstream press, and these people are not the world's greatest self -promoters. At least some of us are paying attention. Good work, guys! Bush should be giving medals to you all. Source: htto://www6.lexisnexis.com/publisher/EndUser?Action=UserDisplavFullDocument&orgid=574&to picld=100017534&docld=1:317616881 &start=1 as retrieved on Oct 13, 2005 13:09:10 GMT. Page 1 of 1 Kristen Maze From: LOREN RASMUSSEN [Iorenrasmussen@msn.com] Sent: Sunday, March 09, 2008 9:36 AM To: Kristen Maze Subject: Ham Radio 3-10-08 Kristen Maze, After attending two public meetings on this subject, it seems to me that this whole process has been brought about by one person who lives adjacent to a licensed ham and does not like the placement of that ham's antennas. I understand that this situation is being handled by current regulation. (no permit issued) Deschutes County already has regulations on the books specific to height limitations for structures. According to testimony at the two meetings that I attended, there are a very few of these towers in the county. Do we really need another ordinance regulating something that already is already covered by county code? Respectfully submitted, Loren Rasmussen Redmond KC7CWQ 3/10/2008 HENDRIX, BRINICH d`? BERTALAN, L.L.P. 716 NW Harriman St. Bend, Oregon 97701 541.382.4980 541.382.9060 fax March 5, 2008 ATTORNEYS AT LAW www.hxbri.com Our File: 3301.1 Kristen Maze Deschutes County Community Development 117 NW Lafayette Ave Bend, OR 97701 RE: Amateur Radio Towers Dear Kristen: Greg Hendrix, P.C. Ken Brinich, P.C.* Lisa N. Bertalan, P.C. *admitted Oregon & U.S. Patent Bar C.1.AR 0 3 2000 I have argued that the county's regulatory authority does not authorize it to impose, promulgate or enforce regulations establishing private aesthetic property interests such as the creation or preservation of private viewsheds. The County's authority to regulate height is limited to the authority confered on the County by PRB-1. This federal grant of regulatory authority allowsregulation to address the County's legitimate concerns. The use of the County's limited local regulatory authority to create private protected viewsheds is illegitimate and unjustified. Unless acquired by conveyance or grant, owners of real property have no right to an unobstructed view. In Oliver v. A.T. & T., 76 Cal. App. 4th 521, 525 (1999)(dispute over construction on adjacent lot of a 130 foot cell tower) the Court said: Since a landowner has no natural right to an unobstructed view, (Posey v. Leavitt (1991) 229 Cal. App.3d 1236, 1250), the size and shape of an otherwise lawful structure on one side of a boundary cannot be deemed either to damage (for purpose of inverse condemnation) or to interfere with the enjoyment (for purpose of nuisance) of that which is on the other side of the boundary. Otherwise, one person's tastes could form the basis for depriving another person of the right to use his or her property, and the law of nuisance would be transformed into a license to the courts to set forth neighborhood aesthetic standards. I bring this case to your attention because during the course of these proceedings I have stated that Mr. Auker does not own the view across Bob Swaney's property. The holding in Oliver supports my client's position. A similar rule is also reported in Washington stater See Collinson Y. John L. Scott, Inc. 55 VVn. App. 481, , 778 P.2d 534 (1989) (In the absence of a view easement or restrictive' covenant, landowner on Capitol Hill in Seattle has no right to an unobstructed view over adjoining property, and nuisance claim Kristen Maze Page 2 March 5, 2008 based on building construction that blocked plaintiff's view was properly dismissed). I have not found a reported Oregon case that states the rule so succinctly. The County's limited regulatory authority may be exercised only to address legitimate community health, safety, or aesthetic concerns. It may not be exercised to create a private right to an unobstructed view where none existed before. In the absence of a legitimate community aesthetic concern, there is no basis for a height regulation based upon aesthetics. The record before the Board is devoid of any evidence of a community concern over the aesthetic impact of amateur radio towers in Deschutes County. Consequently no regulation of amateur radio tower construction or siting should be adopted. Ken Brinich c: client Laurie Craghead County Commissioners Kristen Maze From: jajwbarton@coinet.com Sent: Wednesday, March 05, 2008 4:30 PM To: Kristen Maze Subject: Amateur radio towers Kristen Maze Deschutes County Planning and Zoning Regarding the proposed amateur radio tower regulations(file# TA -06-10), I want to bring to the attention of planners a point that did not seem to be addressed at the public hearings I attended. The majority of the operators attending the hearing indicated that their structures for supporting antennas were temporary and were frequently moved to accommodate varying needs. I believe that the regulations should not require a building permit or a planning process for these temporary structures. In addition, there should be clesr guidelines as to what is considered a permanent structure. Judith A. Barton KE7BHT 2406 NW Summerhill Dr. Bend, OR 97701 22920 Superior Ct. Bend, Or 97702-9271 February 29, 2008 Deschutes County Community Development Commission 117 NW Lafayette Bend, OR Re: Pending Code Amendments TA -06-10 Dear Commissioners, BY: F 2 9 2003 D LIVEREL BY: I am requesting that the Commission adopt only minor regulation of Amateur Radio towers, and that the general exemption for such towers from County Radio tower regulations be reinstated. I am certain that the Commission has much more important matters to consider than the unnecessary regulation of Amateur Radio stations. Amateur radio is already adequately regulated by the Federal Communications Commission, which has total jurisdiction over electromagnetic radiation sources. The only area open for local regulation is safety. Esthetics are a matter of personal opinion and cannot be justly regulated. The Eiffel tower is considered to be a thing of beauty by many Parisians even though it dominates the Paris skyline. To me, my tower is beautiful. If my neighbor disagrees then we two can settle the matter in or out of court. It is a personal matter. A large body of engineering knowledge and experience exists with regard to the failure mechanisms of towers, masts and columns, guyed and unguyed.1 The debris circle is roughly 1/3 of the original height of the structure. Thus, a setback of 1/3 of tower height from the property line is adequate protection. (Guy anchors need not be set back.) For example, there are two broadcast towers adjacent to Butler Market Road near 12th street in Bend. If one of these towers were to fall like a "matchstick" it could easily hit several houses across the street. However, towers do not fall like a "matchstick", they collapse. The number of towers or support structures employed by an amateur is related to the type of experimentation or operation he is engaged in. Thus it is an unnecessary restriction to limit their quantity. I would suggest that the County's regulation take some form such as the following. ' Merriman, Mansfield "Mechanics of Materials" 11th ed., Chapter IX, John Wiley & Sons, New York, 1916. Definition: Amateur radio station, as used herein, refers to a set of radio apparatus duly licensed by the F.C.C. as an amateur radio station, and under the control of an F.C.C. licensed amateur radio operator. General Exemption: Amateur radio stations are exempted from the County Radio regulations with the following exceptions. Safety Restrictions: The base of towers and other vertical structures over 30 feet in height shall be located a distance of at least 1/3 of their height from the property line. Guy anchors may be located adjacent to the property line. Signage Restriction: Lights (except those required by F.A.A. regulations) shall not be placed on amateur radio station towers. No signs, except cautionary notices shall be attached there to. Thank you for your consideration of this request. Sincerely, John E. Ogden, W9CZ Amateur Extra class, Commercial Radiotelephone 1 srt class (now General Radiotelephone), Radio Telegraph 2nd class (now obsolete), B.S. Mathematics, B.S. Physics, Registered Professional Engineer (California, retired) Page 1 of 1 Kristen Maze From: Darrell Fevergeon [daf@bendbroadband.com] Sent: Thursday, February 28, 2008 10:24 AM To: Kristen Maze Subject: Tower ordinance Kristen and Commissioners: We really do not know why so much time is spent on the Tower issue. Surely, there are more pressing things that our Descutes County needs to spend time and money on. It appears that the established FCC regulations, the follow-up Federal court cases and Oregon State laws are sufficient for us to realize proper tower policies already exist and work well all over this great country. We fear that you are heading to an expensive court battle wherein Descutes County will get it's hands slapped and cost both residents AND our county huge and unnecessary attorney and court costs. For what? We need our precious County resources to be spent on the many pressing and past -due needs not "protecting" views of trees and mountains. Since we do not have a radio tower and have no need of one, we obviously do not have a dog in this fight. We plead for fairness and reason. Please be reasonable and drop this silly "tower adventure" into areas already tred by others, and subsequently "fixed" in courts. We would appreciate greatly a response from our Commissioners. Most sincerely, Darrell & Bonnie Fevergeon 20911 Clear View Ct Bend OR 97702 2/28/2008 HENDRIX, BRINICH `ce2 BERTALAN, L.L.P. 716 NW Harriman St. Bend, Oregon 97701 541.382.4980 541.382.9060 fax February 26, 2008 ATTORNEYS AT LAW www.hxbri.com Our File: 3301.1 Kristen Maze Deschutes County Community Development 117 NW Lafayette Ave Bend, OR 97701 RE: Amateur Radio Towers Dear Kristen: Greg Hendrix, P.C. Ken Brinich, P.C.* Lisa N. Bertalan, P.C. *admitted Oregon & U.S. Patent Bar At the hearing last night Commissioner Luke asked for clarification whether the land owner has to sign an application. I understood him to ask whether a signature is required for a Building Permit application. It is my understanding that the landowner is required to sign for a land use application. I could not say for certain whether a landowner has to sign for a building permit application. Enclosed: arelDeschutes'Courity Building Division application forms for building permit review for a'New Dwelling, for Accessories/Additions Remodels, and for a Building Permit Application Checklist (printed from the Deschutes County Building Division website). These forms require the applicant to identify the landowner. They do not require or provide for the signature of the land owner. In fact no signature at all is required. I confirmed with a call to the Building Division that there is no requirement for the landowner to sign the application for a building permit. Laurie from the Building Division informs me that no signature is required for a building permit application. the Landowner's signature is required for a land use application. Regards, Kien Brinich enclosure c Laurie Craghead County Comniissibners client NEW DWELLINGS B# Property Information *Energy Path #: *Description of Project Property Address or Tax Lot # Street City State Zip Code # Bedrooms *Dwelling Height *Residence Sq Footage Garage Sq Footage Total Sq Footage *Water Source: Mater District DCommunity DWell DShared Well DCity DCistem Contact Information *Owner(s) Name *Phone *Owner's Mailing Address Street City State Zip Code *Contractor Name *CCB# *Contact Person Contact Phone Contact Fax Contact Cell *Contact Person Mailing Address Street City State Tip Code Electrical Information *Contractor: * License#: *Property for Sale, Rent or Lease? D YES DNO 'Temporary Power Needed? D Now D At Issuance *Temp Power Contractor: * License #: *Limited Enemy/Low Voltage (mark all that apply if using a different electrical contractor): Mechanical Information *Heat Source: *Contractor: * License #: DGas DElectric DBoth MOH DSolarSystem DWood DOther (specify): 25.1 Audio/Stereo System Under 100,000BTU 25.6 Landscape Irrigation Control 25.2 Burglar Alarm Baseboard Electric Wall Heaters? 25.7 Outdoor Landscape Lighting 25.3 Garage Door Opener Radiant Floor Water Heater 25.8 Vacuum System Exhaust Fans? —* 25.4 Fire/Security Alarm 25.9 Other (specify): Boiler over 200,000BTU 25.5 Healing/ThermostatNentilationlAir Conditioning Mechanical Information *Heat Source: *Contractor: * License #: DGas DElectric DBoth MOH DSolarSystem DWood DOther (specify): *If Gas, check all that apply: *Number of gas vents: Forced Air over 100,000BTU? Under 100,000BTU Heat Pump over 100,000BTU? tinder 100,000BTU Baseboard Electric Wall Heaters? Wood Stove, Pellet, Zero Clearance Fireplaces?_± Enter Qty Radiant Floor Water Heater Enter Qty Exhaust Fans? —* Radiant Floor Heating Closed w/ Potable Water Conn. Radiant Floor Healing Open Loop wl Potable Water Conn. Boiler over 200,000BTU Under 200,000BTU *If Gas, check all that apply: *Number of gas vents: 9f Propane:Contractor's Name: License # Plumbing Information *Contractor. *License #: *Distance from water source to dwelling: *Distance from dwelling to septic tank/sewer connection: # Bathrooms: t 1 Electrical Park & Rec S Limited use above chart DC's: Temp Mechanical Transportation SDC's: Plumbing Range Dryer Fumace Water Heater Free Standing Stove / Insert / Fire logs Barbeque Boiler Radiant Floor Water Heater Log Lighter 9f Propane:Contractor's Name: License # Plumbing Information *Contractor. *License #: *Distance from water source to dwelling: *Distance from dwelling to septic tank/sewer connection: # Bathrooms: t 1 Electrical Park & Rec S Limited use above chart DC's: Temp Mechanical Transportation SDC's: Plumbing ACCESSORIES / ADDITIONS REMODELS B# Property Information *Energy Path # *Description of Project: *New Structure Height:_ *Property Address or Tax Lot # Street City State Zip Code *Water Source: DWater District DCommunity DWeii DShared Well Deity DCistem "New Structure Sq Footage Contact Information *Owner(s) Name *Phone *Owner's Mailing Address Street City State Zip Code *Contractor Name *CCB# *Contact Person Contact Phone Contact Fax Contact Cell *Contact Person Mailing Address Street City State Tip Code Electrical Information *Contractor: * License # *New Service or Subpanel? DYES DN0 # of Amps: *Installing or Altering Circuits? DYES DN0 # of Circuits: *Limited Energy/Low Voltage (mark all that apply if using a different electrical contractor): Mechanical Information *Heat Source: Gas *Contractor: * License #: DElectric DBoth DOil DSolar System DWood DOther (specify): 25.1 Audio/Stereo System Under 100,000BTU 25.6 Landscape Irrigation Control 25.2 Burglar Alarm Baseboard Electric Wali Heaters? 25.7 Outdoor Landscape Lighting 25.3 Garage Door Opener Exhaust Fans? 25.8 Vacuum System 25.4 Fire/Security Alarm Radiant Floor Heating Open Loop w/ Potable Water Conn. 25.9 Other (specify): 25.5 Heating/Thermostat/Ventilation/Air Conditioning Mechanical Information *Heat Source: Gas *Contractor: * License #: DElectric DBoth DOil DSolar System DWood DOther (specify): *If Gas, check all that apply: *Number of as vents: Forced Air over 100,000BTU? Under 100,000BTU Heat Pump over 100,000BTU? Under 100,000BTU Baseboard Electric Wali Heaters? Wood Stove, Pellet, Zero Clearance Fireplaces? Enter Qty Exhaust Fans? Enter Qty Radiant Floor Heating Closed w/ Potable Water Conn. Radiant Floor Heating Open Loop w/ Potable Water Conn. Boiler over 200,000BTU Under 200,000BTU *If Gas, check all that apply: *Number of as vents: *If Propane:Contractor's Name: License #: Plumbing Information *Contractor. " License #: 'Installing/Altering/Relocating Water Line? # of feet: *Installing/Altering/Relocating Septic or Sewer Line? # of feet: Range Dryer Fumace Water Heater Free Standing Stove / Insert/ Fire logs Barbeque Boiler Radiant Floor Water Heater Log Lighter *If Propane:Contractor's Name: License #: Plumbing Information *Contractor. " License #: 'Installing/Altering/Relocating Water Line? # of feet: *Installing/Altering/Relocating Septic or Sewer Line? # of feet: t 1 Electrical Park & Rec S Limited use above chart DC's: Temp Mechanical _0_-1— Plumbing Transportation SDC's: Bathrooms Bath Sinks Dishwashers Water Heaters Tubs Showers Disposals Backflow Devices Kitchen Sinks Water Closets Washing Machines Other (specify): t 1 Electrical Park & Rec S Limited use above chart DC's: Temp Mechanical _0_-1— Plumbing Transportation SDC's: Deschutes County Building Safety Division 117 NW Lafayette Ave Bend OR 97701 (541)388-6575 FAX:385-1764 2000 Edition Oregon One & Two Family Dwelling Building Permit Application Checklist Contact Name Community Development Department Redmond Office La Pine Office 737 SW Cascade Ave 51590 Huntington Rd Redmond, OR 97756 La Pine OR 97739 385-1713 FAX:923-3097 536-5852 FAX:536-5851 Contact Address Job address The following items are required for plan review. revised 3an 2003 Team Phone# FAX # P r 0 v d e s N 1 Complete sets of legible plans drawn to scale, showing conformance to the applicable local and state _ .. building codes. Lateral design details and connections must be incorporated into the plans or on a separate full size sheet attached to the plans with cross-references between plan location and details. Plan review cannot be completed if copyright violations are evident. 2 Site/Plot plan drawn to scale. The plan must show: lot and building setback dimensions; property comer elevations (if there is more than 4 -ft. elevation differential, the site plan must show contour lines at 2 -ft. intervals for a distance away from the building necessary to show compliance with OTFDC Sec. 401); location of easements and driveway, footprint of structure (including decks), location of wells/septic systems. Utility locations, any known fill sites or landslide hazard areas, direction indicator, lot area, impervious area, existing structures on site, and surface drainage. 25 3 Foundation plan and Cross Section. Show footing and foundation dimensions, anchor bolts, any hold- downs reinforcing steel, connection details, vent size and location, and soil type. 26 4 Floor plans. Show all dimensions, room identification, door and window sizes and locations, location of smoke detectors, water heater, HVAC equipment, ventilation fans, plumbing fixtures, balconies and decks 30 inches above grade, etc. 27 5 Cross section (s) and details. Show all framing member sizes and spacing such as floor beams, headers, joists, sub -floor, wall construction, roof construction. More than one cross section may be required to clearly portray construction. Show details of all wall and roof sheathing, roofing, roof slope, ceiling height, siding material, footings and foundation, stairs, fireplace construction, thermal insulation, etc. 6 Elevation views. Provide elevations for new construction; minimum of two elevations for additions and remodels. Exterior elevations must reflect the actual grade if the change in grade is greater than 4 ft. at building envelope. Full size sheet addendums showing foundation elevations with cross-references are acceptable. 7 Wall bracing (prescriptive path*) and/or lateral analysis plans. Building plans must show construction details and locations of lateral brace panels; for non -prescriptive path analysis provide specifications and calculations to engineering standards. 8 Floor/roof framing plans are required for all floors/roof assemblies indicating member sizing, spacing and bearing locations, nailing and connection details. Show location of attic ventilation. 9 Basement and retaining wall cross section and details showing placement of reinforcing steel, drains and waterproofing shall be provided. Engineered plans are required for retaining walls exceeding 4' in height and basement walls not complying with the prescriptive code requirements. For engineer systems, see item 13, for "Engineer's calculations." 10 Beam calculations. Provide two sets of calculations using current code design values for all beams and multiple joints exceeding prescriptive code requirements, and/or any beam/joist carrying anon -uniform load. 11 Manufactured floor/roof truss design details. 12 Energy Code Compliance. Identify the prescriptive path or provide calculations. 13 Engineer's calculations when required or provide, (I.e. shear wall, roof truss, retaining walls exceed 4') shall be stamped by an engineer or architect licensed in Oregon and shall be shown to be applicable to the project under review by cross-reference to the applicable plan location. Jurisdictional specifics 23 Roof live load design criteria: Sisters, Redmond, Bend 25# - Sunriver 50# - La Pine 55# 24 25 26 27 rescnptive path is in reference to methods of application used as prescribed in the Oregon One & Two Family Dwelling Code. Checklist must be completed before plan review start date. Minor changes or notes on submitted pians maybe in blue or black ink Red ink is reserved for department use on#,. HENDRIX, BRINICH d� BERTALAN, L.L.P. 716 NW Harriman St. ATTORNEYS AT LAW Bend, Oregon 97701 www.hxbri.com 541.382.4980 541.382.9060 fax February 26, 2008 Our File: 3301.1 Kristen Maze Deschutes County Community Development 117 NW Lafayette Ave Bend, OR 97701 RE: Amateur Radio Towers Dear Kristen: Greg Hendrix, P.C. Ken Brinich, P.C.* Lisa N. Bertalan, P.C. *admitted Oregon & U.S. Patent Bar FEB 2 7 2008 At the hearing last night Mr. Auker suggested that amateur radio operators should be held to the same standards as applied to wireless telecommunications facilities owned and operated by the telecom industry. This proposal has no merit. Wireless telecommunications'facilities are owned' and operated' by for-profit iridustnes. Amateur radio is alhobby. `Iri 1'99'4 Congress‘passed'PublicTaw'103-408', aF Congressional-7oiiit i2esolutnon' recognizir'ng'the efforts-aiid coiitributions'of'airiafeur operators to the national welfare. A copy Public Law 103-408 text is enclosed. Congress thinks highly of amateur radio operators. After addressing amateurs' lack of any pecuniary interest, their contributions to the national welfare in times of disaster, and their enhancement of international goodwill, PL 103-408 provides: "regulation at all levels of government should facilitate and encourage amateur radio operation as a public benefit." Congress is telling local government that amateur radio operators are a community asset. The community should welcome and encourage the activities of amateur operators. Congress' mandate to local government is to accommodate and encourage amateurs. This mandate should be neither ignored or violated. Until 2001 the County recognized this mandate with the height limit exception for "radio projections" at §18.120.040A (2001 version of the code). This exception is a reasonable accommodation. The exception worked for years without complaint: Efforts to` abandon'this` exception lead tothe complexities` the' Commission iaw' at the: public hearing `on February 25, 2008. Attempts to regulate are'complicated by'factors'sucl 'asthe`numberand configuration of the antenna(s), the radio frequencies the operator intends to use, soil type, the water content of the "soil, the sunspot cycle, the time of day the operator intends Kristen Maze Page 2 February 26, 2008 to operate, the type of license issued to the operator, and whether the operator is licensed by another country. The list of factors goes on and on. On the other hand, compliance with the mandate is simple so long as the code excepts amateur radio facilities from height limits. The decision whether to regulate should be weighed against the need to regulate. Other than requiring a building permit, there is no need to regulate height. Unlike many other land uses, amateur radio generates no profits and imposes no impact on infrastructure or public services. No vehicle trips are generated by amateur radio facilities. No additional sheriff's patrols are required. There is no impact on fire protection services. No additional schools or roads are needed. In point of fact, amateur radio facilities make existing public services more efficient during time of disaster by substituting free communications facilities when other facilities have crashed. To the extent that amateur radio facilities need be sited to minimize public impact, the licensed amateur operators of Deschutes County have demonstrated that they are responsible self regulators. By locating tall towers outside urban areas, they have minimized their impact on the public's interest in scenic values. The County's desire to preserve scenic values is understandable. Amateur radio facilities do not threaten those values. As several witnesses testified, the number of towers in the County over 70 feet high is miniscule. An individual citizen's irritation with a tower in his private viewshed is insufficient to jeopardize or threaten the public's interest. While the planning division has pointed out that the Comp plan includes scenic values, no evidence of a threat to the public's interest has been received. Where minimum regulation is the standard, the County should consider the option of no regulation. Absent a threat to the County's scenic values, regulation is unjustified. The County's reasonable accommodation obligation can be met by adopting an ordinance drafted by legal counsel restating the height limit exception for amateur radio facilities. While Mr. Auker may be irritated by an amateur radio facility being constructed next door, his proposal to regulate amateurs as if they are multi -national telecom companies is without merit. If he believes his property rights have been violated, he may file his action in the Courts alleging abatement of a private nuisance. It is improper to seek redress for that claim before the County Commission. 2rds, n Brini� enclosure c: Laurie Craghead County Commissioners client Public Law 103 -408 --Joint Resolution of Congress to Recognize the Achievements of Radio Amateurs as Public Policy Public Law 103 -408 --Oct. 22, 1994 Public Law 103-408 103d Congress Joint Resolution To recognize the achievements of radio amateurs, and to establish support for such amateurs as national policy. Whereas Congress has expressed its determination in section 1 of the Communications Act of 1934 (47 U.S.C. 151) to promote safety of life and property through the use of radio communication; Whereas Congress, in section 7 of the Communications Act of 1934 (47 U.S.C. 157), established a policy to encourage the provision of new technologies and services; Whereas Congress, in section 3 of the Communications Act of 1934, defined radio stations to include amateur stations operated by persons interested in radio technique without pecuniary interest; Whereas the Federal Communications Commission has created an effective regulatory framework through which the amateur radio service has been able to achieve the goals of the service; Whereas these regulations, set forth in Part 97 of title 47 of the Code of Federal Regulations clarify and extend the purposes of the amateur radio service as a-- (1) voluntary noncommercial communication service, particularly with respect to providing emergency communications; (2) contributing service to the advancement of the telecommunications infrastructure; (3) service which encourages improvement of an individual's technical and operating skills; (4) service providing a national reservoir of trained operators, technicians and electronics experts; and (5) service enhancing international good will; Whereas Congress finds that members of the amateur radio service community has provided invaluable emergency communications services following such disasters as Hurricanes Hugo, Andrew, and Iniki, the Mt. St. Helens Eruption, the Loma Prieta earthquake, tornadoes, floods, wild fires, and industrial accidents in great number and variety across the Nation; and Whereas Congress finds that the amateur radio service has made a contribution to our Nation's communications by its crafting, in 1961, of the first Earth satellite licensed by the Federal Communications Commission, by its proof -of -concept for search rescue satellites, by its continued exploration of the low Earth orbit in particular pointing the way to commercial use thereof in the 1990s, by its pioneering of communications using reflections from meteor trails, a technique now used for certain government and commercial communications, and by its leading role in development of low-cost, practical data transmission by radio which increasingly is being put to extensive use in, for instance, the land mobile service: Now, therefore, be it Resolved by the Senate and House of Representatives of the United States of America in Congress assembled, SECTION 1. FINDINGS AND DECLARATIONS OF CONGRESS Congress finds and declares that -- (1) radio amateurs are hereby commended for their contributions to technical progress in electronics, and for their emergency radio communications in times of disaster; (2) the Federal Communications Commission is urged to continue and enhance the development of the amateur radio service as a public benefit by adopting rules and regulations which encourage the use of new technologies within the amateur radio service; and (3) reasonable accommodation should be made for the effective operation of amateur radio from residences, private vehicles and public areas, and that regulation at all levels of government should facilitate and encourage amateur radio operation as a public benefit. Approved October 22, 1994. Page 1 of 2 Kristen Maze From: Crownefenn5@aol.com Sent: Wednesday, February 27, 2008 10:14 AM To: Kristen Maze Subject: Ham radio objection To County Planning and Commissioners: We understand that you are still taking comments on the Ham Radio regulations. We firmly support stricter zoning and regulations on towers and poles related to wireless and ham radio activity. We own property near Stenkamp Road, in proximity to where Mr. David Neys resides. We are opposed to the towers that he has erected on his property and agree with Mr. Swaney (we do not know him personally) that the structures present an eyesore to those who have corridor views to the Cascades or other territorial views. It brings to mind the driving range/ golf facility poles and nets that were constructed near Home Depot in the late 90's, or so. It may have been legal at the time, but it was a mistake and devalued many home property values which had beautiful views before that misguided enterprise marred the landscape. And even though I did not live across from that driving range, I thought it was a mistake for Bend, as a whole, to have allowed it. Every citizen of Bend has to look at that mess, to this day. The same holds true for our area east of town which is just 5 miles from Costco. I drive by Mr. Neys's property and thank my lucky stars I do not live directly to the east of him because the towers are pronounced, and wouldn't you know it...smack dab in the middle of some gorgeous mountain views ... The towers are ugly and "in your face". I have never understood how he can have those towers when our building heights are restricted due to the air space for the Bend airport? ? ? We live in a relatively peaceful, rural area for a reason. The towers, as Mr. Swaney points out, remind one of the urban jungles some of us may have left behind. My husband is a 35 year resident of Bend who remembers when the town was small and these conflicts did not occur, for the most part....but we must face the reality that Bend has grown and will grow...and this requires smart zoning and regulations to mitigate and address some of the "old thyme" zoning issues. As populations expand, so must the "good neighbor" policies. My response to Mr. Neys' comparison to Awybrey Butte development is this: 1)His towers only really, in the end, serve him, not the general good of the County. Although I, too, would like to have the Buttes clear of communication towers and the density of homes we see, that is not how the City of Bend is zoned, nor organically grown. Importantly, the communication towers serve all of us, all of the time. This is not true of Mr. Neys' operation. The communication/ utilities had to have public hearings, provide lots of data/documentaion and make a clear case for their towers. Not so with ham radio operators. 2)Mr. Neys' views to the west and out to the mountains are still unobstructed...I would like to ask him if his neighbors to the west of him put up the same kind of junk in front of his living room windows...how would he like it? I will bet he would not be happy, and he would also claim that the obstruction devalues his acreage. We do not believe, for one minute, that the ham radio buffs contribute significantly, if at all, to the safety equation for the County. The Butte towers are designed to do that for our emergency personnel. For that matter, cell phones provide a high degree of individual safety communication for the vast majority of us. Ham radios and the corresponding towers are really all about a handful of individuals who have the ability to ruin property values for a large segment of the surrounding population. In the end, it is a hobby... with detrimental effects. Thank you for your time and consideration. 2/27/2008 Page 2 of 2 Mr. and Mrs. Phi Fenn Delicious ideas to please the pickiest eaters. Watch the video on AOL Living. 2/27/2008 Page 1 of 2 Kristen Maze From: Rex Auker [raauker@ykwc.net] Sent: Tuesday, February 26, 2008 4:00 PM To: Kristen Maze Subject: Re: Amateur Radio Kristen, I reviewed the Snook case. (Snook vs City of Missouri City, TX). At first glance, it appears to me that the procedures set forth by the Deschutes County Code Sections dealing with wireless telecommunications facilities, if applied to amateur radio, meet all the requirements brought to light by the Snook case. As I read it, the Snook decision says that each application for a permit to construct an amateur radio tower must be considered on it's own merits and must be based on the specific license of the ham operator and the intended use of the facility. It is procedurally permissible to require the applicant to clearly specify the the frequencies and band widths on which the tower will operate, the intended uses of the tower, considerations such as surrounding vegetation, topography, even the color of the paint, if they can have an effect on the capability of the antenna. Why? Because a legally defensible decision about reasonable accommodation cannot be made without that information. If the county chooses to question an application, then the county must have an independent evaluation conducted by someone with the technical competence to make an authoritative recommendation. Only then will there be enough data to support a finding about reasonable accommodation. When amateur radio operators claim that the procedures are too cumbersome, they have only themselves to blame. The decision in the Snook case took into consideration all sorts of information including the opinions voiced by the neighbors. If less information is gathered, then a decision to deny a permit could be challenged in court because the county failed to give adequate consideration to the matter of reasonable accommodation. When the amateur operators complain about being buried in a pile of administative debris, we need to remind them that it is a pile of debris that they themselves created every time they took a local government to court. The regulative strategy of the Deschutes County Code sections concerning wireless telecommunications facilities is very practical given the complexity of the issues involved. It states clearly what is permitted outright on any land parcel in any zone: wood monopole structures up to 45 feet or any sort of antenna built up to 15 feet above an existing building. Those sorts of structures are probably adequate for 60 or 70% of ham operators, and there is no limitation on the number of structures that can be built, nor will they likely interfere with irrigation and agriculture. The minority of hams who want to go taller or who want to build elaborate metallic structures are the ones who are more serious about the hobby, more technically competent and probably more affluent. If someone can afford to put up a 100 foot tower, at a cost that may approach 20 thousand dollars, that person can also afford to pay the administrative fees necessary for the county to process such a complex application. Also, if an application appears to be questionable, it is reasonable for the county to require a deposit up -front to cover the cost of an independent technical evaluation, sort of like the up -front deposit that is required when any other sort of permit is likely to go before a hearings officer. Please include this in the public record, and send a copy to the county attorney. --Rex Auker --- Original Message From: Kristen Maze To: Rex Auker 2/27/2008 Page 2 of 2 Sent: Tuesday, February 26, 2008 12:31 PM Subject: RE: Amateur Radio Rex, Here you go, I believe this is the case Ken Brinich referred to. I will try and get all the documents submitted for last night's public hearing on the County website today or tomorrow. Kristen Maze From: Rex Auker [mailto: raa u ker@ykwc. net] Sent: Tuesday, February 26, 2008 12:14 PM To: Kristen Maze Subject: Amateur Radio Kristen, At the hearing last night Mr. Brinnich, the attorney, said something about a ham radio case that occurred in Texas, Snook vs some city in Texas as I recall. Did he submit a copy of that case? If so, will it be published on the county website? I would like to read it. Anything you can do to help me find it will be appreciated, even if you can just give me the title of the case so I can research it myself. Thanks. Rex Auker 2/27/2008 Gene F. Walters 64839 Starwood Drive Bend, OR 97701 February 25, 2008 Rex A. Auker 62575 Stenkamp Road Bend, OR 97701 Subject: Amateur Radio Text Amendment TA -06-10 I have read over your letter dated February 25, 2008 and information at the website pertaining to this issue. As the president of our homeowners association I am concerned that the CC&Rs can be overridden to the detriment of our community. There has to be a balance between the rights of radio amateurs and the rights of homeowners. People in our community bought homes with the knowledge of the CC&Rs and the expectations of their neighbors. I fully support your efforts to have a controlled approach to this problem of elevated structures. I appreciate the efforts that radio amateurs provide, but there are ways that they can accomplish their goals without imposing upon their neighbors. Sincerely Yours, Gene F. Walters, President Starwood Association