|October 18, 2002||Print Close|
From: Jerry Ulcek
Sent: Monday, August 12, 2002 4:21 PM
Subject: Re: Categorical Exclusion
>>> "Greg Kechter" 08/12/02 04:27PM >>>
In working with a client I am trying to make absolutely sure that what I am telling them is correct. If you could advise me in the following areas I would greatly appreciate it.
The client says they are categorically exempt.
I say this exemption is from performing routine environmental assessments, however they must still make sure they meet the MPE limits. This could be done with calculations in many if not most cases. On co-located sites particularly rooftops they must also determine if the site is in compliance and whether or not they are a 5% contributor.
Are these statements made by myself accurate?
RSI - University Office
Yes, the statements you made are correct. All licensees must comply with the MPE limits given in Section 1.1310 of the rules, there are no exceptions. Categorical exclusions are given to those licensees that under most situations would not cause a compliance problem by themselves. They are still bound by the MPE requirements though. As soon as the licensee co-locates with another, the licensee must take into account existing fields caused by these entities. If there are areas that exceed 100% of the applicable limit then those that are contributing more than 5% of the applicable standard limit are responsible for compliance. The last licensee to a site is always responsible for making sure that fields they add (even if under 5%) will not cause the site to become non-compliant.
(303) 231-5205 ext. 205
IMPORTANT FCC PROVISIONS ON OCCUPATIONAL RFR SAFETY JERRY ULCEK FCC
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