WHITE HOUSE ENVIRONMENTAL JUSTICE

ADVISORY COUNCIL

MAY 2022 MEETING SUMMARY

VIRTUAL PUBLIC MEETING
May 11,2022

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TABLE OF CONTENTS

PREFACE	3

AGENDA	5

1.0	WHEJAC Meeting	7

1.1	Welcome, Introductions & Opening Remarks	7

1.2.1 Brenda Mallory, Chair - The Council on Environmental Quality (CEQ)	8

1.3	WHEJAC Climate Resilience Workgroup Update & Discussion	9

1.4	Public Comment Period	16

1.5	WHEJAC Business Meeting Reflection & Conversation	28

1.6	Closing Remarks & Closing	32

APPENDIX A:	33

APPENDIX B	41

APPENDIX C:	55

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PREFACE

The White House Environmental Justice Advisory Council is established by Executive Order
14008, titled "Tackling the Climate Crisis at Home and Abroad" (issued on January 27, 2021).
As such, this is a non-discretionary committee and operates under the provisions of the Federal
Advisory Committee Act (FACA), 5 U.S.C. App. 2.

The WHEJAC will provide independent advice and recommendations to the Chair of the Council
on Environmental Quality (CEQ) and to the White House Interagency Council on Environmental
Justice (Interagency Council), on how to increase the Federal Government's efforts to address
current and historic environmental injustice, including recommendations for updating Executive
Order 12898. The WHEJAC will provide advice and recommendations about broad cross-cutting
issues related, but not limited to, issues of environmental justice and pollution reduction, energy,
climate change mitigation and resiliency, environmental health and racial inequity. The
WHEJAC's efforts will include abroad range of strategic scientific, technological, regulatory,
community engagement, and economic issues related to environmental justice.

The duties of the WHEJAC are to provide advice and recommendations to the Interagency
Council and the Chair of CEQ on a whole-of-government approach to environmental justice,
including but not limited to environmental justice in the following areas:

•	Climate change mitigation, resilience, and disaster management.

•	Toxics, pesticides, and pollution reduction in overburdened communities.

•	Equitable conservation and public lands use.

•	Tribal and Indigenous issues.

•	Clean energy transition.

•	Sustainable infrastructure, including clean water, transportation, and the built
environment.

•	National Environmental Policy Act (NEPA) enforcement and civil rights.

•	Increasing the Federal Government's efforts to address current and historic environmental
injustice.

EPA's Office of Environmental Justice (OEJ) maintains summary reports of all WHEJAC
meetings, which are available on the WHEJAC website at:

https://www.epa.gov/environmentaliustice/white-house-environmental-iustice-advisory-council.
Copies of materials distributed during WHEJAC meetings are also available to the public upon
request. Comments or questions can be directed via e-mail to wheiac@epa.gov

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Committee Members in Attendance

•	Richard Moore, Co-Chair, Los Jardines Institute

•	Peggy Shepard, Co-Chair, WE ACT for Environmental Justice

•	Carletta Tilousi, Vice-Chair, Havasupai Tribal Council

•	Catherine Coleman Flowers, Vice-Chair, Center for Rural Enterprise and Environmental
Justice

•	Angelo Logan, Moving Forward Network

•	Rachel Morello-Frosch, PhD, UC Berkley

•	Miya Yoshitani, Asian Pacific Environmental Network

•	Kim Havey, City of Minneapolis

•	Kyle Whyte, PhD, University of Michigan

•	Tom Cormons, Appalachian Voices

•	LaTricea Adams, Black Millennials for Flint

•	Harold Mitchell, ReGenesis

•	Juan Parras, Texas Environmental Justice Advocacy Services

•	Maria Belen-Power, GreenRoots

•	Maria Lopez-Nunez, Ironbound Community Corporation

•	Nicky Sheats, PhD, Kean University

•	Ruth Santiago, Latino Climate Action Network

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AGENDA



THE COUNCIL ON ENVIRONMENTAL QUALITY
WHITE HOUSE ENVIRONMENTAL JUSTICE ADVISORY COUNCIL
VIRTUAL PUBLIC MEETING

AGENDA

May 11, 2022



P.M. - 7:45 P.M.

3:00 p.m. - 3:15 p.m.

INTRODUCTIONS & OPENING REMARKS

o Karen L. Martin, Designated Federal Officer - U.S. Environmental Protection Agency
o Richard Moore, White House Environmental Justice Council Co-Chair - Los Jardines Institute
o Peggy Shepard, White House Environmental Justice Council Co-Chair - WE ACT for

Environmental Justice

o Catherine Coleman Flowers, White House Environmental Justice Council Vice Chair - Center

for Rural Enterprise and Environmental Justice
o Carletta Tilousi, White House Environmental Justice Council Vice Chair - Havasupai Tribe

3:15 p.m. - 3:30 p.m.

OPENING REMARKS

o Brenda Mallory, Chair - The Council on Environmental Quality

3:30 p.m. - 4:30 p.m.

WHEJAC CLIMATE RESILIENCE WORKGROUP UPDATE & DISCUSSION

o Maria Lopez-Nunez, Workgroup Co-Chair - Ironbound Community Corporation
o Miya Yoshitani, Workgroup Co-Chair - As/an Pacific Environmental Network

4:30 p.m. - 4:45 p.m.

BREAK

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4:45 p.m. - 6:15 p.m.

PUBLIC COMMENT PERIOD

Members of the public will be given three (3) minutes to present comments relevant to the current
charge of the WHEJAC Climate Resilience Workgroup. The charge includes the following
questions:

ป Wfio' *ype of support >s needed tor dlsadvar i+aqe communities to participate in federal
disaster prepa-ednes1. or -eiief programs?

•	How c an Federal disaster relief and aid pre atoms be+*er serve disadvantaged communities
tnar rave historically received fewer fedeiol benefits?

•	W^cr p-ocess steps and infer maTiun would help elim> io:e these disparities?

•	WhaT sTeps can Federal agencies and the White House +ake to reduce d'sparities in climate
c hange impacts for commt nit'es Includ'ng bi t r oปt limited to risks 'torn, extreme heat,
flood, wildfire d-ought and coastal challenges*

6:15 p.m. - 6:30 p.m.

BREAK

6:30 p.m.-7:30 p.m.

WHEJAC BUSINESS MEETING REFLECTION & CONVERSATION

The WHEJAC will use this time to reflect on the meeting proceedings and public comment period;
provide workgroup updates: discuss action items and finalize next steps.

o Karen L. Martin, Designated Federal Officer-U.S. Environmental Prctection Aneป cy
o Richard Moore. White House Environmental Justice Council Co-Chair -. - , — -e
o Peggy Shepard, White House Environmental Justice Council Co-Chair Wt

o Catherine Coleman Flowers White House Environmental Justice Council Vice Chair - Center for

Rural Enterprise and Environmental Jusrice
o Carletta Tilousi White House Environmental Justice Council Vice Chair - Havasupai Tribe

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WHITE HOUSE ENVIRONMENTAL JUSTICE ADVISORY COUNCIL (WHEJAC)

Virtual Public Meeting
May 11,2022

MEETING SUMMARY

The White House Environmental Justice Advisory Council (WHEJAC) convened via Zoom
meeting on Wednesday, May 11, 2022. This synopsis covers WHEJAC members' deliberations
during the two-day meeting. It also summarizes the issues raised during the public comment
period.

1.0	WHEJAC Meeting

This section summarizes WHEJAC members' deliberations during the one-day meeting,
including action items, requests, and recommendations.

1.1	Welcome, Introductions & Opening Remarks

Karen Martin, Designated Federal Officer (DFO), U.S. EPA, welcomed attendees and made
announcements. She stated that everyone is in listen and view mode only, and public
commenters are invited to speak later that afternoon. She noted that Spanish translation and
closed captioning are available. She turned the meeting over to Richard Moore, the WHEJAC
co-chair, for opening remarks.

Richard Moore introduced himself and thanked everyone for their hard work and participation.
He recognized that a lot of issues are affecting both rural and urban communities. He assured
everyone that this WHEJAC understands that this moment in history is crucial and take this work
extremely serious. He stated that he's looking forward to the public comments and hearing the
report back in the discussion that will take place.

Peggy Shepard introduced herself and assured everyone that the WHEJAC takes the public
comments very seriously. She stated that they listen and incorporate those into the
recommendations to the administration. She stated that the screening tool and some other issues
from the working groups will be discussed.

Catherine Coleman Flowers introduced herself and stated that she looked forward to hearing
public comments and getting closer to reaching the goals.

Carletta Tilousi introduced herself and stated that she looked forward to hearing everyone's
comments on some of the work that they've been asked to do. She said that she is looking
forward to the presentations addressing the beta version of the Climate and Environmental
Justice Screening Tool and the federal government agency's implementation of the Justice40
Initiative.

DFO Martin invited the Council members to briefly introduce themselves and state their
affiliations. She informed the Council that the quorum was met.

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Co-Chair Moore reminded everyone that WHEJAC is a historical moment in the life and the
history of many that have been involved in this environmental and economic justice struggle for
a long time. He informed everyone that, at this moment, over 200,000 acres in New Mexico are
on fire and that is affecting many rural and grass-root communities, forcing them to evacuate. He
noted that his group just returned from delivering supplies to those camped out on the side of the
road, in rest areas and in other people's homes and yards. He reminded everyone to remember
those that are suffering and going through injustice. He turned the meeting over to Brenda
Mallory, the chair of CEQ.

1.2.1 Brenda Mallory, Chair - The Council on Environmental Quality (CEQ)

Brenda Mallory thanked Mr. Moore for the powerful reminder and grounding everyone in why
they're here and what they're doing. She thanked everyone for inviting her to the meeting, the
WHEJAC members for their time and dedication and everyone for participating, especially new
attendees.

Ms. Mallory stated that it's been about a year now since the WHEJAC produced a very robust set
of recommendations on the Justice40 Initiative, the Climate and Economic Justice Screening
Tool, and revisions to Executive Order 12898. She thanked the group and recognized what a
significant contribution and significant sacrifice had to be made to participate in that activity.
She stated that over the past year, those recommendations have been used on numerous
occasions in guiding policymaking and decision making across the federal government. She
also announced that CEQ will soon be providing a comprehensive, government-wide response to
those recommendations to give a sense of what has taken place since the recommendations were
made.

Ms. Mallory announced a few updates. She stated that first on staffing, the two new hires at
CEQ — Amanda Aguirre, senior advisor to her on environmental justice; and Jess Ennis, CEQ's
Director of Public Engagement — were doing a great job in implementing the president's agenda.
She announced that Dr. Jalonne White-Newsome will be starting soon at CEQ as the Senior
Director for environmental justice. She gave Dr. White-Newsome's background and stated that
the Council will get a chance to meet her at the next public meeting once she has started.

Ms. Mallory also updated the Council on the Climate and Economic Justice Screening Tool. She
stated that CEQ extended the public comment period on the beta version of the tool to
Wednesday, May 25th, because extending the comment period would help to deliver robust
feedback from the public and tribal nations, capturing the reality on the ground. She stated that
the tool will be a living document that continues to reflect information that advances the overall
goals of the president's program, and it is critical to the Justice40 Initiative.

Ms. Mallory clarified that, while they are still accepting public feedback, federal agencies have
already started implementing the Justice40 Initiative. She stated that they are relying on the
interim guidance instructions that was put out in July of 2021, and hoping that, with the tool,
everyone will be operating on a consistent framework.

Ms. Mallory informed the Council that of the formal written response to WHEJAC, which will

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be made public, that focuses on three next steps. She explained that the first is the need of
administrative support, expert support, financial support, and additional resources to fulfill its
mission. She stated that they are continuing to ensure that CEQ staff attend WHEJAC public
meetings and provide support as needed in the workgroups.

Ms. Mallory explained the second step is on the revisions to Executive Order 12898. She stated
that since receiving the WHEJAC's recommendations last year, they have been working to
develop a durable, impactful, and effective approach to updating the executive order given that
the deliberative process for developing this executive order is still ongoing. She stated that
details cannot be shared publicly at this point, but they plan to schedule a meeting of the
WHEJAC Executive Order 12898 Workgroup to provide an update on the status of that work.

Ms. Mallory explained the final step. She stated that over the coming weeks, CEQ will unveil a
new website that will include information on the White House Environmental Justice
Interagency Council, the Justice40 Initiative, et cetera. She stated that they will continue to add
more to the website over time but hopes that the website will serve as a space for ongoing and
clear communication about the administration's work.

Ms. Mallory stated that there is critical work happening at CEQ and across the federal
government to advance environmental justice, but they can't work alone. She stated that they
need WHEJAC's help, ideas and partnership.

Co-Chair Moore stated that slowly but surely, progress is being made. He thanked Ms. Mallory
for her time and commitment and the CEQ staff for their hard work. He transitioned the meeting
to the next agenda item.

1.3 WHEJAC Climate Resilience Workgroup Update & Discussion

Maria Lopez-Nunez asked for better attendance and membership in the workgroup. She stated
that they wanted to hear stories from members about climate resiliency and federal agencies that
may have failed communities before, during and after disasters.

Miya Yoshitani reiterated that request and stated that they wanted to ensure that the workgroup
develop recommendations for federal agencies to shift, change and transform their approach to
disaster response and disaster preparedness. She stated that they want recommendations to
reflect the realities that communities have faced and that communities should not just survive but
thrive through the climate crisis.

Ruth Santiago reminded everyone that in September of 2017, Puerto Rico was impacted by two
category four and five hurricanes: one was a direct hit and the other very close. She stated that
the devastation mostly impacted the electric grid, especially transmission lines, poles, wires and
substations and that the response from FEMA has not been one that promotes resilience. She
stated that recently there was an announcement about $1 billion worth of FEMA funding for
public lighting and for rebuilding.

Ms. Santiago noted that FEMA is approving the use of the $1 billion to rebuild the centralized
interconnected poles, like public lighting poles, wires and towers rather than doing, for example,

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solar and battery-powered public lighting in Puerto Rico. She explained that there is another 11
or 12 billion that FEMA has allocated for the electric system in Puerto Rico, and none of it is for
renewable or community-based projects that will lessen the burden on the environmental justice
communities, mostly in southeastern PR. She stated that those plants keep operating with what
FEMA is funding right now and that doesn't align with the Biden administration's Executive
Order 14008 that created the WHEJAC and is supposed to address the climate crisis central to
environmental Justice. She stated that it doesn't comply with the National Environmental Policy
Act and there was no environmental justice analysis for this huge funding that FEMA is about to
start dispersing.

Nicky Sheats reminded everyone of Hurricane Sandy and the response from FEMA and others.
It was reported that a lot of attention was paid to what happened in coastal areas but a lot of
things happened to EJ communities as well. He explained that there was a roundtable created,
called the Sandy Climate Justice roundtable, and it included the New Jersey EJ Alliance,
representatives from EJ communities, and organizations. He explained that the group felt that
the government didn't seem comfortable working with these groups in close partnership and
relegated these groups to tasks they thought were just good communication, even though the
groups were doing much more. He stated that they also found that EJ groups wanted to work on
a neighborhood level, like developing emergency and resiliency plans with the participation and
the guidance of community groups and community residents, whereas FEMA and the
government tended to think of the community level as the municipal level, so they had a larger
scale than what the group wanted to work on.

Kyle Whyte reminded everyone that the Anishinaabe people in the Great Lakes region are
exposed to a number of different disasters, including flooding, but also other types of disastrous
habitat changes that affect our economies and cultures. He stated that this is referring to well
over 30 tribal nations in the Great Lakes region, numerous communities that depend on tribal
self-governance to support their way of life of well-being and also native people that are living in
urban areas. He noted that in terms of tribal government, it's extremely problematic that some
tribes may have a single person who is responsible for all facets of disaster response and
preparedness, whereas the U.S. federal government will have multiple people serving that
particular media. He explained that there are some organizations out there as well as some tribal
staff that have made great strides in different parts of the country to fix this problem, but the
inequalities continue and it's completely unfair and unjust that tribal governments do not have
the same access to federal funds that states do. He stated that other governing entities are also
supposed to juggle numerous cultural, social, economic and political issues of great complexity
even for very small tribal communities. He noted that it seemed as if tribes were a lesser form of
government even though they are sovereign and not given access to commensurate resources for
staffing and response preparedness.

Vice-Chair Flowers reminded everyone that, especially in rural communities, people who are
renting or living in mobile homes can't get help during a disaster, so that eliminates help for the
most vulnerable. She stated that she has read about corporations buying up rental properties and
sometimes these mobile homes are overpriced to the point that what they're being offered to
replace their homes would never put them back in a newer one because the homes are so
overpriced.

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Ms. Flowers stated that while she was at a conference, a woman who lives near Aspen in
Colorado stopped her and said that a lot of migrant families are living in mobile homes because
they can't afford housing in expensive places like Colorado with the resorts and a lot of them are
also EJ communities.

Ms. Flowers stated that wildfires are starting in places that they've never had before. She asked,
what's going to happen to those families? She asked if the government is prepared to offer help
to families that are also victims of wildfires when they lose their homes in these disasters and
how are we going to get to climate resilience? She also asked how do we deal with disaster
preparedness and provide relief for those that are most vulnerable, especially those who rent or
who live in overpriced homes?

Maria Belen-Power stated that in Chelsea and East Boston, Massachusetts, she's seen a lot of
those investments going to communities that are white and wealthy and she sees EJ communities
bearing the burden of that transition. She stated that substations are being placed next to jet fuel
that is in overcrowded neighborhoods of black and brown residents, especially non-English
speaking immigrants. She stated that it seems like because there was a WHEJAC created, all the
problems are solved and that everything has changed and, meanwhile, these inequalities continue
to be impacting people every day.

Ms. Belen-Power stated that Chelsea was the hardest hit city from COVID in the entire
commonwealth of Massachusetts and their rates were five times higher than the state average.
She added that it was uncovered last week that the Department of Transportation of
Massachusetts has been dumping asbestos in the community for an entire year. She emphasized
that the idea that these things are a thing of the past, that we've moved on, that there's a new
administration and that a WHEJAC was created, is a false understanding of what's actually
happening on the ground in EJ communities today. She noted that as we transition to a clean
energy economy, that is an unjust transition because the burdens of that infrastructure are being
placed in black and brown communities and communities of color and in non-English speaking
communities where immigrants live.

Co-Chair Moore agreed with the previous comments about the wildfires and the total disregard
and disrespect for sovereign nations. He also reminded everyone that many in EJ communities
don't have insurance when a disaster occurs. He stated that the U.S. government needs to be held
not only accountable but responsible for what's taking place in many EJ communities. He stated
that the U.S. Forest Service needs to be held responsible and accountable for what's taking place
presently in the northeastern part of New Mexico.

Angelo Logan lifted up a comment that resiliency has a connotation that EJ communities are
resilient in that they can continue to survive under extreme circumstances. He stated that it
should be recognized that it's not just about continuously putting the burden on the communities
and that they are resilient because it is happening to them.

Vice-Chair Tilousi reminded everyone that the tribes around the Grand Canyon have been
experiencing a lot of flooding in the past 25 years. She stated that when they've gone into
disaster mode, they asked FEMA to come in and help and their response was pretty slow. She
stated that FEMA told her tribe that the tribe has a lot of logistical planning that needs to be done

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such as developing an emergency operations center, having an organizational chart and doing an
assessment. She stated that in the meantime, the community was walking through contaminated
sites like sewer pipes that were broken. She stated that relief is needed immediately. She felt
that at the time they were caught in this long logistical process while the people needed help
immediately and there was a lot of back and forth. She stated that they were told by FEMA to go
through the state emergency operation center and the community had a difficult time getting
services.

Ms. Lopez-Nunez stated that it seems like communities are expected to develop infrastructure
while in the middle of a disaster. She continued with the next topic of disaster preparedness and
relief questions in response to their charge. She stated that inherent discrimination and
diminishing of communities are embedded even in the way we talk about disasters.

Ms. Yoshitani stated that there will be a discussion in the workgroup specifically about the
terminology when they have more time to discuss it. She stated that there were four original
charge questions and they wanted to address the one with disaster preparedness and relief — what
type of support is needed for disadvantaged communities to participate in federal disaster
preparedness or relief programs?

Ms. Yoshitani stated that they were concerned with the way that the question was framed. She
explained that it sounded like blame to the communities in that somehow environmental-justice-
impacted communities are the ones that need to change to receive the accountability,
responsibility, benefits and resources of the federal government. She stated that this should be
shifted and directed back to federal agencies and the federal government's approach. She
suggested a more general charge question; what changes need to be made to federal agencies to
ensure the equitable distribution of resources for federal disaster preparedness and relief
programs?

Ms. Yoshitani highlighted four areas to consider when forming recommendations. She explained
that the first is funding impact and stated, for instance, how do we ensure that recovery funding
doesn't perpetuate polluting and equitable systems in housing, energy and other infrastructure?
She stated that the example that Ms. Santiago gave earlier points to this question to formulate
recommendations. She stated that they have a few recommendations, and they would love to
hear more from the Council.

Ms. Yoshitani stated the second area, community participation. She asked how can FEMA and
other agencies reach communities they often leave behind? She stated that they've heard some of
the stories already about how the federal government agencies have and have not related to
communities. She stated that they would like to hear how agencies need to improve the way that
they are communicating and responding to communities.

Ms. Yoshitani stated the third area, accessibility. She asked who are the most marginalized
groups who have been the worst impacted or left out of FEMA funding/programs? She asked
what recommendations ensure the accessibility of the most marginalized communities and all
communities for the resources, not just through FEMA, but through the federal government for
disaster preparedness and response?

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Ms. Yoshitani stated that the fourth area is around legal accountability and asked how can we get
federal agencies to follow existing executive orders and existing law? She asked how can we
ensure that the federal government is responding to and communicating and delivering both
preparedness and relief in disasters? She asked how can we then ensure that the government are
following all existing regulatory and executive orders and existing law? She noted that there are
a lot of existing laws in place that should be protecting and ensuring a more equitable response,
but they're not being followed. Ms. Lopez-Nunez invited any recommendations for addressing
or changing the charge question and for the screening tools that can apply to disaster
preparedness and community climate resilience.

Ms. Santiago suggested that, if the Biden administration's policy is to electrify or decarbonize
the electric grid by 2035, FEMA could earmark funds specifically for that and not for rebuilding
the same thing, like fossil fuel electric projects or anything that enables that. She noted that this
could include things like energy conservation, efficiency, demand response programs, locally
sited community-based renewables, and battery energy storage systems.

Ms. Santiago also suggested that other agencies provide funding for energy projects and bring
down the matching portion for community-based projects. She explained that this would go a
long way to allowing a non-profit organizations, workers, co-ops, and other groups that are
community-based to do energy projects. She stated, for example, HUD sometimes has a $10
million minimum capital base that an organization needs to have. She noted that EJ communities
don't have that kind of money so that hurdle is impossible to overcome.

Ms. Santiago noted in terms of accessibility, large outside corporations are attracted to disaster
recovery work. She stated that they are not locally based and do not hire local help and, if they
do, they are paid a minimum wage. She stated that they usually take the funds and don't reinvest
substantial amounts of it, so the money does not have a multiplier effect within the local
economies. She stated that FEMA, HUD, and other agencies need to make sure that they're
working with local groups and organizations, especially non-profits, worker-owned and co-ops.

Dr. Sheats addressed the community participation area. He stated that there should be
community-level resiliency plans. He stated that to make this work accessible to local
community groups, they need funding and resources to ensure the community members and local
community groups can put together these plans and work on these issues in their local
community.

Dr. Sheats addressed the question; how do we ensure the recovery funding doesn't perpetuate
polluting and inequitable systems? He explained that to reduce pollution in these communities,
they need to come at it from the cumulative impact framework. He asked is there a cumulative
impacts problem or multiple sources of pollution? He asked is there a plan to address it and if in
the recovery plan, will pollution be reduced or made worse?

Dr. Sheats shared an example in New Jersey where the Passaic Valley Sewage Commission
wants to make the sewage plant more resilient and part of what is planned is to build a power
plant that will have local air pollution emissions attached to it. He stated that if this was viewed
from a cumulative impacts framework, there would be no support for a power plant with local air
pollution attached to it.

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Ms. Yoshitani stated that there was a recommendation coming out of the workgroup regarding
existing cumulative hot spots and that the affected communities have added protection of any
additional polluting infrastructure funded with public funds in a regulatory way that prevents
other infrastructure, be it private investments or public.

Ms. Yoshitani discussed another area of the charge question. She stated that community climate
resilience is a separate set of questions, but there's obviously a lot of overlap and similarity. She
noted that when thinking about the infrastructure that needs to be built in communities that is
equitable, positive multiplier effects for local economies are their goal for climate resilience.
She stated that the idea is not to reinforce the cumulative burden in communities, but that
communities end up stronger through community efforts or the federal government's efforts.

Ms. Yoshitani clarified that the impacts are not just in terms of weather-related disasters and that
there are fires, flooding, and sea level rise. She stated that there are also the related economic
impacts of climate disaster like the rising prices of energy, food, housing, and the transportation
system. She noted that because the root causes and the impacts are so interrelated, the
workgroup is asking for recommendations for an interrelated government approach.

Ms. Santiago shared that, in terms of funding access, one of the things that can provide access is
for public supply of essential services and specifically with public utilities. She stated, for
example, if they have a funding source for resiliency measures or mitigation measures, then that
can be widely available to low and middle-income communities. She noted that public entities
should have funding that is earmarked for resiliency measures like renewable energy or housing
improvements and that will provide access, especially to low- and middle-income people.

Rachel Morello-Frosch said that, in terms of community participation, one approach would be
trying to learn from states that have already been doing some of this work to engage
communities in planning for climate impacts and enhancing community resilience. She asked
are there lessons to be learned from California strategic growth council programs as they have
sought to support community planning for climate change impacts through allocation of different
kinds of grants and support directly for projects. She stated that there are potential models out
there that could be scaled up from which federal programs could learn a lot without having to
start from scratch.

Co-Chair Shepard said that, in terms of funding access, once we identify those disadvantaged
communities through the screening tool, federal grants can be made specifically for community-
based organizations to develop community planning processes and climate action plans very
specifically. She stated that there has not been many municipalities, even when they have
money, really reaching out to communities for that kind of planning. She noted that some years
ago, EPA made grants available to states to develop environmental justice plans and some of the
states that had the earlier programs really took advantage of that grant program.

Ms. Shepard stated that once there are state environmental justice plans or city advisory groups,
you will find that the states then begin to develop EJ grant programs that fund things like
community-based planning or community resilience plans. She noted that the National Institute
of Environmental Health Sciences in the past develop grants that are community-academic-

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partnership oriented. She shared that EPA some years ago had a CUP grant that stood for
Community-University Partnerships. She explained that it was a grant that allowed communities
to partner with academic institutions to begin gathering data to provide the kind of research that
communities identified.

Ms. Shepard explained that a lot of these models have been in place through the federal
government in years past, but they were discontinued. She noted that those approaches need to
be brought back to begin to develop some more innovative interagency approaches. She stated
that there has not been an approach where several agencies got together to develop more of an
intersectoral approach. She explained that with the Interagency Working Group that's been
established through CEQ, that would be an opportunity for DOT to get together with the HUD
and EPA to look at transit hubs that can do transit-oriented development that may be in a flood
zone. She noted that they are all kinds of ways for the agencies to come together to provide
funds and have a more resources to pinpoint particular problems.

Vice-Chair Tilousi stated that one of the things they had trouble gaining access to were the
FEMA funds for the homes. She noted that a lot of the homes were flooded and because these
families on the reservation didn't have insurance for their homes, it was difficult for them to get
any recovery. She stated that the tribe decided to insure all the homes in case this happened
again. She also suggested that FEMA could do an assessment on estimated damage and give the
funding directly to the tribe.

Ms. Yoshitani agreed that there are a lot of stories about the barriers that are put up by any of
these programs to make low-income communities and disadvantaged communities go through
unsurmountable obstacles to try to get access to even the small amounts of resources that are
available.

Ms. Lopez-Nunez turned the topic to the Climate and Economic Justice Screening Tool. She
explained that the definition given for basic things like climate, sustainability and housing were a
big flag for them. She added that there were three thresholds: expected agricultural loss,
expected building loss and population loss. She stated that a lot were missing like the overlays
about flooding vulnerabilities, vulnerabilities to fires or the heat island effect. She noted that it
should be a one-stop tool for everything, including what programs the communities qualify for.

Ms. Santiago stated that the potential impacts from natural disasters should be included in the
tool. Dr. Sheats agreed that more indicators specific to climate, like the heat island effect and air
pollution, should be included. Ms. Santiago added a climate threshold for water, both potable
water or water for human consumption and for other needs. She stated, for example, the sea
level rise can lead to saltwater intrusion into groundwater bodies. She noted that communities,
especially coastal communities, that depend on groundwater will see a decrease in their supplies
and droughts will impact all kinds of water bodies, superficial and groundwater.

Dr. Morello-Frosch concurred with the drought threat. She explained that in addition to
seawater intrusion into groundwater resources, areas highly prone to drought and domestic well
communities have wells that are running dry. She stated that data is getting better at predicting
places where access threats are likely to be acute, particularly in the foreseeable future as
precipitation diminishes and groundwater goes lower. She suggested contacting a group called

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Toxic Tides based in California to explain their work in sea level rise and flooding threats to
hazardous facilities and low-lying coastal areas. She also reminded them that places where
you're likely to have groundwater getting pushed up more with sea level rise can reactivate
toxics embedded in the soil in some of these legacy sites that haven't been adequately cleaned.

Kim Havey asked if they had looked at or considered having any health indicators as part of that
screening tool. Ms. Yoshitani added that cumulative impacts of all of these different indicators
should be included as well as include race as an indicator. Ms. Lopez-Nunez invited everyone
to email or reach out to the group to give more feedback.

DFO Martin announced the break with the public comment period to follow.

1.4 Public Comment Period

On May 11, 2022, the WHEJAC held a public comment period to allow members of the public
to discuss environmental justice concerns in their communities. A total of 23 individuals
submitted verbal public comments to the WHEJAC and an additional 49 individuals had signed
up to speak but were not in attendance. Each speaker was allotted three minutes.

DFO Martin welcomed everyone back from the break. She reminded everyone of the
procedures for the public comment period. Co-Chair Moore reminded everyone that there are
many staff members from various organizations on the call. He stated that the public comment
period is a very important piece of the work of the WHEJAC Council. He explained that they
prioritized hearing from people that have not testified before as a public speaker. He noted that
if more than one person registers to speak from the same organization, the first one that
registered will be heard first and then the others as time allows.

1.4.1 Melissa Miles - New Jersey Environmental Justice Alliance (New Jersey)

Melissa Miles stated that, before she was ED of an environmental organization, she was a parent
experiencing the impacts of having children in a neighborhood burdened by the cumulative
impacts of pollution and climate change. She stated that she and her children marched from the
Ironbound Community Corporation in Newark, New Jersey, to the gates of the Covanta Essex
incinerator a mile and half away in the snow. She said she did that because Covanta never takes
a break from burning trash and poisoning the air.

She explained that they were accompanied by dozens of other children concerned about their
health and their futures. Children should not have to defend themselves against the inaction of
government bodies who fail to adequately protect them year after year and decade after decade.
Due to the extreme danger they pose to communities, the EPA is legally obligated to review and
revise standards for incinerators every five years under the Clean Air Act. But the EPA has
repeatedly failed to update these standards. She explained that the EPA has not updated these
standards in over 15 years since 2006. In the last 30 years, the EPA has only revised its
incinerator standards twice, not the legally required six times. The EPA has failed to regulate
incinerators, and this failure has exposed us to lead, other heavy metals, and particulate matter.
It's also exposed them to the psychological harm of feeling like, even though they are organized
and fighting back, decision-makers don't care about them.

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She spoke about that, as a result of industries like Covanta, the Ironbound has been nearly
ghettoized as wealthier white residents of Newark were able to move to the surrounding suburbs
leaving behind many black and brown residents who were unable to move. As a matter of fact,
some of the closest housing to the incinerator is low-income housing, where many of the
neighborhood's longstanding black and Puerto Rican families live. EPA's failure to regulate
incineration in an old, outdated, and unnecessary industry that robs states of both clean energy
funding and their creativity to design new and better systems is nothing short of neglect of the
communities that they have sworn over and over again to protect. They need urgent action. Will
generations have to march against the same aging and outdated incinerator 20 years from now?
She hopes that by speaking to the WHEJAC her community will finally see action and pressure
EPA to regulate this dirty industry now.

1.4.2	Jonathan Smith - Earthjustice (New York, New York)

Johnathan Smith stated that Earthjustice represents environmental justice groups dealing with
the scourge of waste incinerators. The vast majority, 80 percent, of these incinerators are in EJ
communities. For decades, EPA has let these incinerators pollute more than the Clean Air Act
allows. On a per-megawatt basis, incinerators emit more pollution than coal plants, and they can
be some of the biggest local emitters. EPA admitted nearly 15 years ago that the current
incinerator emission limits were not calculated the way that the Clean Air Act requires, and EPA
admitted that these limits needed to be redone. The Clean Air Act deadline for EPA to update the
standards passed over ten years ago, but EPA has not proposed or finalized any updates to the
incinerator standards since. It is unacceptable for EPA to continue to delay fixing standards that
allow too much pollution in EJ communities. He urged WHEJAC to call on the Biden
administration to prioritize its long-overdue update of these incinerator standards.

1.4.3	Whitney Amaya - East Yard Communities for Environmental Justice (Long Beach,
California)

Whitney Amaya called attention to the incinerator that has been burning trash for almost 35
years in her community, even though better waste prevention and resource management
strategies exist. Agencies that are meant to hold these polluters accountable and that are meant to
protect the air they breathe have failed them over and over. The EPA is supposed to update
incinerator emission standards every five years, which, if they would have been doing their job,
means they would have six revisions by now. But the EPA has only reviewed emissions
standards once back in 2006, which is 16 years ago. Meanwhile, the incinerator in her
community has been spewing out more toxic pollution than they're legally allowed to base on
standards that they know aren't health-based.

She explained that, on top of this, the incinerator is able to work away without any repercussions
to the dangers they're causing because they're able to exploit start-up, shutdown, and malfunction
exemption loopholes. Their communities knew back then when they were flooded with trash
burner proposals that incinerators are not the answer. They are false solutions, just like the new
age pyrolysis and gasification incinerators are. Burning trash emits harmful pollutants and
contributes to the poisoned air they're already breathing impacting our respiratory system, our
reproductive system, and causing cancer. They need the EPA to stop ignoring their communities

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and to do its job in protecting the environment and public health by updating the emission
standards for incinerators. As the leading voice of environmental justice, she hopes that this body
will make this a top priority and elevate this issue to the EPA and the Biden administration.

1.4.4	Ann Cass - Proyecto Azteca (San Juan, Texas)

Ann Cass stated that they have many problems in the Rio Grande Valley, and she doesn't feel
that EPA is doing much about it. Finally, after 40 years, they were able to fix a sewer plant that
was by a colonia because the youth leaders in the colonia took over. But FEMA is just really a
problem. Every time they have a disaster claim, the Texas Rio Grande Legal Aid has done a
great job in suing them, which is the only recourse they have. FEMA admitted that they have
secret rules, such as not going up on roofs or underneath the house, to determine damage. A lot
of them did not speak Spanish. A lot of them knew nothing about construction. The group finally
got FEMA to use drones to examine the roofs.

She explained that colonias that have septic tanks are also troublesome. Every time it rains, they
flood, and the fluids come up to their yard. Her county health department, TCEQ, and the water
supply corporation says they don't have any money to put sewer in there, but they get absolutely
no assistance from EPA. It's just very frustrating to get things to happen, and it just takes decades
to get something moved.

1.4.5	Skye Wheeler - Human Rights Watch (New York)

Skye Wheeler stated that over the past two years, her group has become increasingly interested
in how the climate crisis is worsening the maternal health crisis in the U.S., defined by inequities
between black, indigenous, and other women of color on the one hand and white women on the
other. She explained that pre-term birth rates, as one example, have generally been rising over
the past years and are twice as bad for black women as for white women. Like other human and
civil rights organizations, they are excited that WHEJAC is focused on how best to protect
disadvantaged communities and how resources should be best allocated to make sure
disadvantaged communities can best participate in federal disaster preparedness and relief
programs.

She stated that, although her group strongly supports the efforts to promote an environmental
justice approach to climate change, they also request a reproductive justice approach as well and
explicitly press for resources to protect pregnancy and newborn health, as well as other sexual
and reproductive health care to prevent the climate crisis from worsening the gap between who
gets to have a healthy pregnancy and newborn and who does not. Her group recommends
including comprehensive sexual and reproductive health as a central part of disaster preparation
and response. This includes ensuring ongoing access to comprehensive contraceptive choice and
access to safe abortion care as well as maternal, perinatal, and newborn healthcare, including
lactation support. All these things were missing in the aftermath of Hurricane Maria in Puerto
Rico, for example.

She explained that ensuring reproductive justice organizations, doulas, midwives, and lactation
consultants are properly equipped and resourced to provide emergency support, including
through government grants, is key to promoting reproduction justice. They would also like to see

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frontline maternal health workers, like doulas and midwives, included in planning for disasters.
They should be properly compensated for this work as often these lifesaving workers are poorly
or undercompensated for their work, especially when they work in communities marginalized by
historical and current racism.

She added that extreme heat exposure is an ongoing health hazard. But the impacts on pregnancy
health are poorly understood by both pregnant people and families and providers. Public health
campaigns on the dangers of extreme heat should include pregnant people. Subsidized assistance
for cooling devices or improved housing should include pregnant people as well as other
"vulnerable populations." Pregnancy accommodations at work, such as additional bathroom
breaks or water breaks for pregnant people, should be better protected.

1.4.6 Sneha Ayyagari - The Greenlining Institution (Oakland, California)

Sneha Ayyagari stated that Greenlining has over a decade of experience providing input on the
development and implementation of California's CalEnviroScreen mapping tool that was used to
inform the CEJST's tool. They also have deep relationships with California and national
environmental justice communities and groups. She emphasized four points in regard to the tool.

She noted that, number one, the CEJST should use race as an indicator. Race is the number one
predicting factor for proximity to citing near hazardous locations. Low-income communities of
color are disproportionately burdened by poverty and pollution. If the CEJST aims to address
these climate and economic disparities, it must use race as an indicator and, at the very least,
should use proxy indicators for race and use an analysis that ensures that ratings are predictive of
racial and economic burdens while considering cumulative impacts.

She went on to explain number two. The CEQ's process for engagement with frontline
communities should be stronger, should provide transparency into the process for working with
frontline communities, and explain why certain feedback is included or not. The CEQ should
also provide funding for technical assistance and capacity building, particularly for communities
so they can easily participate in the development and implementation of the tool.

She explained number three. The CEQ should be clearer about how different states and federal
tools can coordinate in finding disadvantaged communities. Having multiple tools can lead to
inconsistent definitions and duplication. Community-based organizations in local government
agencies do not always have the capacity to track multiple comment periods for each tool.
Combining and streamlining these processes can help develop better tools for communities to
use their time and input. They also want to ensure that there's updated data for rural, tribal, and
island communities where there's historically poor data and recommend that agencies work to
eliminate algorithmic bias in climate investment.

She concluded with the last point. The tool should include indicators for climate change risk,
adoptive capacity, and sensitivity data to make sure that they identify the most climate-
vulnerable communities, reduce disparities, and improve federal disaster relief programs for the
communities that need it the most. California is working on a streamlined, comprehensive, and
accessible mapping platform that identifies communities that are most vulnerable to climate
change impacts. A similar approach can be implemented at the federal level to address past

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injustices and ensure a more equitable future moving forward. She stated that she will provide
detailed written comments on the tool.

1.4.7	Vithal Deshpande (City of Somerville, Massachusetts)

Vithal Deshpande stated that his city, Somerville, is located near the Atlantic Ocean and is one
of the densest cities in the United States with a population of over 80,000 population in an
approximately four and a half square mile area. Flood incidences are expected to increase in
Somerville from this decade onwards. This will be an additional burden on the local
disadvantaged community. This will be true with other disadvantaged communities sharing
similar geography and other demographic characteristics across the United States. The U.S. EPA
has developed environmental justice indexes. They are related to ongoing pollution issues and
don't address the wider environmental impact issues, such as extreme weather conditions and
floods. There are several actions required to integrate the EJ policy on data collection,
development, public education, and more.

He stated that, as the saying goes, unless we measure, we can't manage. Hence, he proposed
improvising the existing system and include data collection related to the climate change impacts
in the EPA's EJ indexes. This should provide an additional layer of information about the
impacts that EJ communities and the local governments face. This will formalize the strategies
for the local to national level to address adverse climatic impacts. The climate change effort
should not be presented or functionally be separate from these other efforts. This should include
others with expertise in their field in the important conversation. Disaster relief programs are too
complicated, require too much paperwork, and present too many opportunities for conflicts due
to concerns about individuals issuing duplicate benefits. So, it needs to be simplified also. He
recommended that FEMA, HUD, and other agencies coordinate on this topic to ensure resources
are directed and coordinated towards the communities that really need it.

1.4.8	Paul Gallay - Columbia University Climate School Resilient Coastal Communities
Project (New York, New York)

Paul Gallay stated that his group interviewed 10 to 12 organizations within the New York metro
area as to what they think the answers are as to what type of support is needed for disadvantaged
communities to participate more effectively in federal disaster preparedness. The organizations
answered that only through a fundamental systemic change in these processes can communities,
governments, and academic institutions working in true partnership foster just and restorative
resilience projects.

He explained that communities are considering whether to decline to participate in future
planning processes if the government does not show how their participation can actually foster
change. Those communities ask, will I be heard and supported? Will my concerns become your
concerns? Will anything change because I took the time to engage? And will that change take
root and grow over time? Communities need to be brought into the actual decision-making
process and ultimately be asked to share leadership on project design with governments.
Government expertise and community expertise need to work together. Governments should help
build awareness, identify, and reach out to at-risk, marginalized, and disempowered
communities, build capacity, provide guidance as to how average communities can access the

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resources they need to protect more effectively, and most importantly help communities build
their own table, support the creation of their structures to assure that they will have meaningful
opportunities to form input into government's resilience planning.

1.4.9	Angelle Bradford - Sierra Club Delta Chapter (Louisiana)

Angelle Bradford stated that, when she reflects on the many years of hurricane and tornado
responses in south Louisiana, she first thinks of the relief programs and how heavily means-
tested they are. South Louisiana folks, right off the bat, know that these processes are
discriminatory towards those who do not either say the right thing with the staff member that
screens them or those of us who are renters versus homeowners expect to receive less if any
assistance at all. In the days after Hurricane Ida last year, it felt like the lessons from Hurricane
Katrina in 2005 were just not apparent nor taken into account. The federal systems do not
integrate well with the state-level systems. And, as a result, there is so much room for confusion,
misinformation, and the appeals process for financial support becomes the default for so many
folks in need of assistance.

She noted that the truth is, however, you will not be able to indefinitely afford to bail out
Louisiana as they set records for hurricanes and climate change or any of the south just as you
will not be able to indefinitely bail out the west with wildfires. Since this is a reality, the
insurance programs for floods need to be affordable and realistic. The strength of structures that
will be impacted by tornados needs to be fortified by codes and requirements. And you need to
work with other agencies to build in more safeguards for renters, not just homeowners, as a lot of
south Louisiana communities and families are renters, not homeowners. You have to work with
the states to create the best, safest housing that lives in harmony with the land and water but also
with the realities of climate change and extreme weather. Everything from the building codes
and where they are allowing folks to live, including the danger zones, has to be made as safe as
possible if lived within at all.

1.4.10	Julia Cohen - Plastic Pollution Coalition (DC)

Julia Cohen stated that the production, transportation, use, and disposal of plastic and the
extraction and refining of its petrochemical ingredients are major drivers of the climate crisis in
the U.S. and around the world and most greatly impact EJ communities. The U.S. plastics
industry's contribution to climate change is on track to exceed that of coal-fired power plants in
this country by 2030. Increased frequency, incidence, and severity of extreme weather and
storms, sea level rise, coastal erosion and ocean acidification, hotter temperatures, bigger
wildfires, more droughts, freshwater insecurity, and other dangerous phenomenon imperil people
and the ecosystems we rely on to survive.

She continued with much of the U.S.'s plastic and petrochemical-producing industrial plants and
other infrastructures along the plastics pipeline are sited in historically underserved, BIPOC,
rural, and low-income communities that are also worse hit by the accelerating effects of the
climate crisis. Hurricanes, flooding, and dangerous heat are affecting Cancer Alley. The extreme
flooding, droughts, and massive shifts in precipitation are affecting the Ohio River Valley, where
plastic and petrochemical production, especially fracked gas, is still growing. Climate change
increases the vulnerability of plastic and petrochemical infrastructure to flooding, fires,

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explosions, and other disasters that can and have claimed the lives of many people. At least one-
third of all hazardous chemical facilities in the U.S. are at high risk of experiencing disasters as a
result of climate-driven floods, wildfires, and storms. Residents of fenceline communities face
serious physical and emotional health risks linked to constant exposure to stress and chemicals.

She ended with fenceline communities living near landfills, illegal dumps, and incinerators are
constantly subjugated to polluted air, soil, and drinking water. Near these landfills, they're
experiencing constant truck, train, and barge traffic and stored waste. Hurricane Ida's the most
recent example of worsening storms affecting these communities, and the greater risk of fire and
explosions are increasing as well. So, preventing the deadly effects of plastic and petrochemical
production in the climate crisis will save lives. We need to stop the petrochemical expansion
now, and we need the EPA and other government agencies to include the entire plastic supply
chain and life cycle in all EJ and climate efforts.

1.4.11	JV Valladolid - ICC (Newark, New Jersey)

JV Valladolid stated Newark is home to a rate of asthma three times higher than anywhere else
in New Jersey, home to four other superfund sites, and also home to already three fracked gas
power plants. To live in an environmental justice community is to wake up to an unbearable
stench of burning garbage and to encounter potholes and the sounds of diesel trucks moving in
and out to be able to access industry. We know all too well the ways in which her community is
impacted and the way that their children are sacrificed on a daily basis. We understand all too
well that they are being exposed to emissions that are known to be cancer-causing, cause
cardiovascular issues, cause reproductive issues, and this is just a short list of the cumulative
impacts that they are concerned about.

She explained that currently, Newark is fighting a fourth gas power plant, the Passaic Valley
Sewerage Commission, utilizing FEMA funds in the name of resiliency and further harming her
community and putting them at risk. They are asking that the EPA move to prioritize standards
on waste incinerators like the 30-year-old Covanta garbage incinerator and community, which is
now over ten years out of compliance with the Clean Air Act. They're looking to leadership like
yours to help them move that the EPA prioritize communities like hers. The EPA's failure to
update incineration standards sends a clear message that their lives don't matter as much. They
are looking to your support in lifting their voices to the administration and ask that the EPA
consider communities like hers for their benefit in the future.

1.4.12	Sebastian Caicedo - Florida Rising (Miami, Florida)

Sebastian Caicedo stated that his community has dealt with an incinerator next to their homes
for the past 20 years. They have talked to many residents that have been affected in so many
ways. He explained that there are nine public schools in this community alone where thousands
of children are exposed to many potential health issues, some of which are headaches, nausea,
dizziness, and trouble breathing. Now Miami-Dade County is considering building a bigger one
at the same location or a location nearby. This can become a bigger problem for the entire
community of Miami as this could and will dictate the future of the environmental policies for
our county. They, the residents of Miami-Dade County, deserve better. His children deserve
better, and their children hopefully will deserve better. They are asking for your assistance on

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that.

1.4.13	Rebeca Velazquez - Mujeres Luchadoras Progresistas (Oregon)

Rebeca Velazquez (through an interpreter) stated farmworkers face climate impacts every day.
She lives in Oregon and is out in the hot and cold weather. In 2020, there were massive fires
where people had to be evacuated. She explained that she and her husband had to stop working
for two weeks because of the air contamination from the fires. Because they could not work, it
caused them a lot of stress and fear because bills could not be paid. There was no financial help.
She asked the federal government to guarantee help arrives to all the affected people without
their work or their immigration status.

1.4.14	Francisca Aparicio - Alianza Nacional de Campesinas (Oregon)

Francesca Aparicio (through an interpreter) stated she is also a farmworker in Oregon. During
the summer of 2020, the fires affected the farm working community and the community that
works outdoors. Despite the heat and the smoke, the farmers went out to work in the field. As a
community worker, she had the opportunity to assist and listen to the community, taking all the
necessary equipment so they could be protected from the smoke, like masks and other resources.
Farmworkers did not stop working because they needed to work to provide for their families.
The farms were full of smoke, and some farmworkers were working without any protection
whatsoever or adequate protection to protect themselves from the contaminated air because of
the smoke that was unbearable. The employers don't have the resources to protect us. People
have passed away in their work areas because of the extreme heat.

She asked for laws to protect the workers that work outdoors, for example, the gardeners, the
construction workers, the farmworkers, et cetera. They need laws that will protect and for the
employers to comply. The farmworkers do not have training on how to take care of themselves
in extreme temperatures. It is also very important that the federal resources come to the
communities. She invited anyone, if they are willing, to accompany one of the workers who
work outdoors so they can understand the need that the community has.

1.4.15	Elia Cordero - Mujeres Luchadoras Progresistas (Oregon)

Elia Cordero (through an interpreter) stated that she also works in Oregon as a farmworker. She
explained that because of the pandemic quarantine, they had to stop working for about two
months. Financially, they had a hard time because the rent and bills don't stop coming in. When
they were able to finally go back to work, she was not able because she had COVID. She had to
stay home for another month, and her rent and bills were behind. She explained that, as a
farmworker, they have a salary that is not enough to save. When she went back to work, she was
full of debts and depressed because she did not know how she was going to cover her debts. Two
months later, the fires came, and they had to stop working for two weeks as well.

She explained that the biggest tragedy of all was not being prepared to survive through all these
disasters. They started evacuating people, and they didn't have enough places for people to stay.
The government is not ready, even though they know that this happens every year. To top it off,
they had a freeze. Trees came down and broke the electricity cables. For ten days, they did not

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have electricity. They couldn't cook, bathe, or use the heater. They don't have community
assistance. She asked for help and resources for the farmworkers. They are the most vulnerable
and affected ones.

1.4.16	Leticia Pascual - Mujeres Divinas (New York)

Leticia Pascual (through an interpreter) stated that she lives in the north part of New York and
works in an apple field. The fieldworkers have to deal with the cold weather. The climate is
below zero. If they don't trim the trees, the fruit will not grow. This year there was a lot of wind
and snow. They were unable to work because the wind would make the snow blow into their
faces, and they couldn't see very well. One day, the temperature went up and the snow became
ice. They couldn't work either because of the dangerous ice. She would like programs to help the
farmworkers have funds when they are unable to work, for the boss to give this information, and
for the agencies to speak Spanish.

1.4.17	Gina Romero - Florida Rising (Miami, Florida)

Gina Romero (through an interpreter) stated that she is speaking out about the incinerators in
her community. EPA has not regulated the incinerators, and this has made many communities at
unnecessary risk. She explained how the air is not pure which causes them to be nauseous, gives
them asthma and dizziness, and affects the brain and health. They live with animals, like rats and
snakes. Her city is in the center of contamination. This is a community where 11 municipalities
come and throw their trash so it can be burned. There is a mountain of ash that constantly come
in the windows and doors. Burning trash gives off carcinogens that are toxic, and their residents
are constantly being exposed to these ashes. The incinerator is 0.2 miles away.

She explained that the population has increased since this incinerator started. There are nine
schools. At the present time, there 51,800 residents that are living here. It's 710 square miles. The
problem is that the company wants to renew a contract for 20 more years. There are 600 to 800
diesel trucks that come through the neighborhood daily. The traffic is chaos. The smells are
unbearable with the chemical, toxic gases.

She asked the EPA to intervene and do something. This does not support the executive order on
January 2021 regarding public health and the environment and the restoration of science to attack
the climate crisis in the country.

1.4.18	Aditi Varshneya - Global Alliance for Incinerator Alternatives (New York)

Aditi Varshneya urged WHEJAC to take action against solid waste incineration and call on the
EPA to take overdue regulatory action to protect communities forced to breathe in the dioxins,
mercury, lead, and particulate matter created by waste burning facilities in our neighborhoods.

She explained that 80 percent of municipal solid waste incinerators are located in low-income
communities and in communities of color. The EPA is aware that incinerators are hazards to
human health, and they are legally obligated to review and revise the standards for incinerators
every five years under the Clean Air Act. However, the EPA has repeatedly failed to update
these standards, exposing families to the slow violence of toxic air pollution and its long-term,

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multigenerational health impacts, which include cancer, respiratory illness, and cardiovascular
disease.

She described why incineration's devastating toll on human health is expensive. Baltimore's
Wheelabrator incinerator, for example, cost the city $55 million in emergency hospital visits,
medical treatments, and lost workdays due to health problems related to it each year. The EPA's
current standards do not meet Clean Air Act requirements, and they need to do right by frontline
communities and by other young people by actually following through on their legal obligations.

She explained that she lives on river opposite of the Covanta incinerator in Newark (mentioned
earlier). So, her community's trash gets burnt at a toxic incinerator just across the river in another
working-class black and brown community. They're angry that they are forced to essentially
poison families that look like theirs with their incinerated waste because the federal government
has failed to do what it promised.

She ended with it's the EPA's responsibility to make sure that incinerators do not continue to
operate like this. Waste incinerators are also the dirtiest form of energy on the grid today.
Incinerators emit 3.8 times as many greenhouse gases compared to the rest of the energy units on
the grid. So, moving away from incineration is not only key to protecting community health but
also building a more resilient energy system. She urged them to make incineration and the
frontline communities forced to live with these dangerous facilities a priority.

1.4.19 Odette Wilkens - Wired Broadband, Inc. (New York, New York)

Odette Wilkens stated wireless radiation from cellphones, cell towers, and 5G antennas placed
in close range to homes, schools, medical facilities, and businesses have injured people. They are
electromagnetically sensitive disabled. 5G and cell towers are being forced onto residents
without notice, without their consent, and with the FCC telling the communities that their hands
are tied. She explained that the number of people suffering from wireless radiation is relatively
high. People are sleeping in their cars, sleeping in tents away from their homes, and evacuating
their homes, including Pittsfield, Massachusetts, where a cell tower was making residents so sick
that they evacuated their homes and children were vomiting in their beds. There has been no
safety testing of 5G.

She noted that there are hundreds of grassroots organizations trying to protect themselves. They
are all being ignored by the FCC, the FDA, HUD, EPA, and there may be others. There are a
number of cases regarding the deployment of 5G. The FCC has also refused to update its
wireless safety emission guidelines since 1996 and, in 2019, decided that the guidelines did not
need to be updated. She asked, would you board a plane whose safety guidelines have not been
updated since 1996? In 2011, the WHO classified it as a possible human carcinogen. And now,
with updated scientific assessments, in 2018 it supports the conclusion that wireless radiation is a
human carcinogen. Wireless is not clean energy. She stated that the FCC, FDA, HUD, EPA, and
other agencies need to protect the health of the American public that they have been charged to
do.

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1.4.20	Naomi Yoder - Healthy Gulf (Texas)

Naomi Yoder addressed the support needed for disadvantaged communities to participate in
federal disaster preparedness or relief programs. She explained that people need money to be
available to them regardless of their income, race, color, home ownership status, et cetera.

People who are undocumented, underemployed, unemployed, and unhoused are especially at
risk, and some cannot qualify for a bank account. So, they need cash payments to be made
available. Assistance needs to be available for anyone affected, not only people that are under a
mandatory evacuation order. There were thousands of people in Orleans Parish who were
displaced without any type of financial assistance. There should be no discrimination in
assistance payments. Multiple journalists have reported that low-income people and people of
color receive less money, and their awards take longer to arrive than those of more affluent and
white recipients of awards. If FEMA can't dispense those funds equitably, please move this job
to another agency or outsource it so that the funds are dispensed equitably and expediently.

She added that housing for people that are displaced is essential. In many cases after Hurricane
Ida, it took four months or more for people to get a FEMA trailer or adequate housing. She will
submit the rest of her comments on the docket.

1.4.21	Dave Arndt - Private Citizen (Baltimore, Maryland)

Dave Arndt commented on the intersection of climate, environmental, and social injustice. He
explained that, unfortunately, all this injustice is burdened on the black, brown, and low-income
areas. This is really all done by plan and design, which he didn't know about until recently. In
the Brooklyn, Cherry Hill, and Curtis Bay neighborhoods of Baltimore, there are two
incinerators within five miles, three RMP facilities, a chemical factory, a working port that
drives heavy-duty truck traffic through the neighborhoods, plus several very large distribution
centers which amplifies the truck traffic. These neighborhoods are in low-lying areas that are on
the Baltimore Harbor, an area known for nuisance flooding and tidal surges caused by hurricanes
and nor'easters. There's also a new phenomenon of rapid flooding due to impermeable surfaces,
old storm drainage, and lack of trees. Unfortunately, this area is struggling with basic services, so
there is no disaster preparedness let alone relief and community resilience planning.

He stated that, if a disaster happened today, residents are on their own. They don't even get
warnings or notifications of what they should do, such as stay in place or evacuate. This all takes
time, money, and expertise, which is not available to these communities. These neighborhoods
are designated really as sacrifice zones. For decades, companies have profited while the health
and wellbeing of the residents were of no concern. The first step that the federal government can
do is not only to allocate funds but to drive a pilot program to show how to implement a
community-driven plan to reimagine neighborhoods to be model communities of environmental,
social, and climate justice. The second thing is to do it now. Finally, all Americans need to be
aware of and understand systemic racism, sacrifice zones, and climate-induced disaster risk and
preparedness.

1.4.22	John Mueller - Private Citizen (Tulsa, Oklahoma)

John Mueller stated that he has submitted comments about fluoridation at five previous

26


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WHEJAC meetings and has spoken at three of them. He asked the government to provide safe
drinking water. Fluoridated drinking water imposes a higher risk of harm to health in
environmental justice communities and can increase the leaching of lead from lead pipes and
plumbing fixtures. He also asked to increase Medicare reimbursement levels so that more
dentists will provide desperately needed oral health care in disadvantaged communities and
ban the addition of fluoridating chemicals to public water supplies. Banning the addition of
fluoridation chemicals will have zero funding requirements forever. He had previously submitted
a 2015 report on fluoridation and environmental justice to the Environmental Justice Interagency
Working Group. The authors of that report from the Fluoride Action Network have been drafting
a 2022 update to that report in light of the current peer-reviewed science published since 2015.
He will be submitting additional material and updated report upon its release.

1.4.23 Joni Arends - Concerned Citizens for Nuclear Safety (Santa Fe, New Mexico)

Joni Arends asked that, with the fires around EJ communities and the wealthy areas, will there
be equitable resources in both locations to rebuild, restore the forest and its waterways, and
replace livestock, et cetera? He explained that, related to the wildfires, there is open burning and
open detonation of hazardous waste and depleted uranium at Los Alamos National Laboratory.
Pollutants from LANL open burning and open detonation have been found in the soil and in
surface and groundwater that flows to the Rio Grande.

He explained that the National Academy of Sciences conducted a review of the open burning and
open detonation activities at Department of Defense and Department of Energy sites and made
recommendations for alternatives to open burn and open detonation, such as static denotation
chambers that capture and treat toxic emissions. Concerned Citizens for Nuclear Safety request
that the Board supports the National Academy of Scientists' recommendations for alternatives to
open burn and open detonation as a matter of homeland security. They also request that the
Board review the equity issues related to emergency preparedness, response, and distribution of
relief from these two fires in northern New Mexico.

DFO Martin reminded everyone that the public has until Wednesday, May 25th to submit any
public comments in writing via email or the form that's on the website. Co-Chair Moore
reminded everyone that redefining environmentalism and conservationism, which actually took
place at the First People of Color Summit, is the combination of the testimony that they've heard
today and the ongoing testimony that they've heard since the existence of the WHEJAC Council
and beyond. He explained that the first is that they've heard legacy environmental justice
communities testifying over and over and over to other government entities, including the
NEJAC and other federal advisory committees. Secondly, they've heard of legacy environmental
chemicals that the people have been consistently impacted by. Then, again, they've heard about
rural communities, farmworkers, and other workers. That's what's the redefinition of
environmentalism and conservationism and the intersections between environmental and
economic justice. Lastly, he stated that one of the most difficult challenges for grassroots
communities has been running proactive and reactive agendas at the same time. That's what the
communities are consistently faced with. Systemic racism is the issue. Environmental and
economic justice is the goal. DFO Martin announced it was time for a break.

27


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1.5 WHEJAC Business Meeting Reflection & Conversation

The WHEJAC will use this time to reflect on the meeting proceedings and the public comment
period, discuss and deliberate action items, and finalize the next steps. DFO Martin welcomed
everyone back from the break and turned the meeting over to Co-Chair Shepard.

Co-Chair Shepard stated that she's glad to hear about Ms. White-Newsome's appointment and
can't wait to meet her at the next meeting. She stated that she enjoyed the presentation from the
Climate Resilience Workgroup and informed the members that more people are needed to join
that group. She noted that there was a robust public comment period hearing some similar issues
they've heard before, but also some newer ones. She stated that they will certainly ensure that a
process has been developed to follow up on those public comments.

Ms. Shepard explained that the first part of the business meeting is going to focus on the Climate
and Economic Justice Screening Tool. She stated that they want to discuss whether they need to
move the June 29th-30th meeting to July. She reminded everyone that they are not going to
discuss actual recommendations but discuss whether or not they want to take additional time to
provide comments to CEQ from either the WHEJAC as a group or focus on individual comments
to CEQ by the May 25th deadline.

Ms. Shepard informed everyone that CEQ will continue to update the tool over the next several
months and that would allow WHEJAC to vote on and approve recommendations at future
WHEJAC meetings and submit them to CEQ. She stated that the Screening Tool Workgroup
can use some additional time to develop draft recommendations from all of the comments that
have been shared in the public meetings and also incorporate comments from the public. She
stated that in order to give the Screening Tool Workgroup more time, they would have to
consider moving the June 29th-30th public meeting.

Ms. Shepard explained that moving the meeting out until July will allow the workgroup
additional time to finalize the draft recommendations for the final WHEJAC vote and the
transmittal to CEQ. She noted that if that is chosen, DFO Martin could send out a poll to find a
new meeting day.

Dr. Sheats explained that he thought the timeline to submit was sometime in June. He stated
that there are several meetings scheduled for this month and the next. DFO Martin confirmed
the dates. Dr. Sheats recommended moving the meeting to July. Dr. Morello-Frosch wanted
to get access to the public comments and agreed that moving the meeting might be best. DFO
Martin stated that they needed time to draft the recommendations. She stated that she would
share the public comments received. She stated that there is another set of recommendations that
the staff has worked on for the Scorecard for J40 and for the Climate and Economic Justice
Screening Tool as well as additional comments for the Climate Resilience Workgroup. She
noted that all three workgroups have meetings through June and those recommendations need to
be seen by the whole body for review before going final. She explained that pushing the meeting
to July would give the body time to review and at that July meeting all the recommendations
could be finalized. Co-Chair Shepard asked DFO Martin to send out a poll to set the meeting
date. DFO Martin confirmed.

28


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Co-Chair Shepard asked for any reflections on the public comment period. She commented
that she thought the incinerator in Newark was a little bit more under control, but it sounds like
it's still out of control and out of compliance. Dr. Sheats stated that it's not only the incinerator
in Newark, but there are also incinerators in Camden and Rahway that they are concerned about.
He proposed that WHEJAC actually write a letter to the appropriate entity urging them to update
the incinerator standards as soon as possible. He volunteered to work on that letter and asked for
help writing it.

Co-Chair Shepard asked if the NEJAC has perhaps done a letter or anything on this issue? She
stated that perhaps there have been public comments at the NEJAC meetings as well. She
suggested connecting with the NEJAC to find out if they've done any letters and maybe there
could be something combined effort. DFO Martin stated that the NEJAC's DFO is Fred
Jenkins, and they can communicate with him. She stated that the NEJAC chairs are interested in
wanting to work with the WHEJAC and this may be one of those issues they could work on
together. She stated that she would give an update at the next full committee meeting on what
they learned. Co-Chair Shepard agreed.

Juan Parras stated that he was not surprised by the farmworker's issues because of climate
change. He stated that it reminded him of the days that Cesar Chavez was protesting and trying
to address issues impacting farmworkers. He explained that, as the climate changes and it gets
hotter and colder, those are going to be the primary ones that are being impacted. He stated that
farmworkers supply a lot of needs, like food and harvesting, that everyone takes for granted. He
explained that when you live it and work in it every day, you hear it louder and clearer, and it
also has a lot of impact on immigrants. He stated that a lot of the populations that do this are
migrant workers that are seasonal workers that come and go, but yet they're being impacted by
it.

LaTricea Adams stated that the comments about farmworkers' maternal and children's health
resonated with her. She reminded everyone that she proposed a special workgroup around
maternal and children's health and was suggesting that again.

Ms. Belen-Power stated that she was also struck by the number of incinerator-affected
communities that were all testifying across the country. She thought the public speakers weren't
really testifying against the incinerators, but against EPA and EPA failing to do its job for 16
years. She stated that the intersection of issues is evident and climate change is adding a layer to
it. She noted that there are also pre-existing issues in the community like maternal health,
hazardous material, and labor conditions.

Chair Shepard asked DFO Martin if there is any sense that the EPA has been thinking about
updating incinerator standards? DFO Martin stated that she can get someone from EPA to get
an answer and an update.

Ms. Santiago stated that she heard quite a few comments about FEMA and failures in disaster
relief to overburdened and disadvantaged communities. She suggested sending them a letter or
meeting with them to talk about how they need to consider reasonable alternatives to comply
with NEPA and then help provide real resilience in communities impacted by disasters.

29


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Co-Chair Shepard asked that when thinking about Scorecard, would seem to be something that
would be consider?

Vice-Chair Tilousi said that she also heard a lot about the incinerators, and she thinks the
problem is there's no enforcement. She requested further research on that to see whether that's
the situation and to provide the proper information if this body decides to do a support letter.
She stated that lack of enforcement on polluting companies might be a trend going across the
country.

Co-Chair Shepard stated that it's definitely a trend in most states. She explained that, when
they're cutting their budget, they cut the enforcement personnel in the state regulatory agencies.
She shared when she and others were in NEJAC they had an enforcement roundtable. She stated
that they went on a roadshow to a variety of states and brought all of those regional officials
there and had community residents come and talk about the lack of enforcement. She stated that
it sounds like NEJAC needs to make something like that happen again because this was very
helpful. She shared going to one in North Carolina with a big issue for the CAFOs at that time
and, unfortunately, that issue continues today.

Ms. Shepard stated that the Council has been asked to evaluate how the administration is
advancing environmental justice. She stated that the bedrock of that is certainly enforcement and
what's been done there. She noted that that is not something they have had a lot of discussions
about in the workgroups but that is a bedrock issue if they're going to talk about advancing
environmental justice throughout all government policies.

Co-Chair Moore stated that one observation was that, when people were testifying, they really
were kind of homing into recommendations and suggestions about how to move forward. He
noted that there was a report that was put out by the NEJAC council during that time on
enforcement. He stated that unfortunately, there are recommendations in that report that still are
alive and well today as they were then. He also supported bringing the chairs from both councils
together to work on issues.

Dr. Sheats stated that Mr. Logan (through a text) wanted to join whatever group that is formed
to write the letter about the incinerator and echoed the remarks that were made about the
incinerators.

Mr. Parras noted that in all the time that they've had meetings with the national EPA, they've
never had meetings with the regional administrators. He asked if there is a possibility of actually
hosting or having a meeting with all regional administrators and seeing how connected they are
to all the issues that have been brought up over the past and what they've done? He suggested
some kind of report card from all the regional administrators or at least a conversation with them
about issues impacting communities. Co-Chair Shepard agreed.

DFO Martin replied that that's a specific EPA issue. She explained that, since the WHEJAC
reports to the CEQ, that can be a recommendation put forward through CEQ to the IAC since
EPA is a part of the IAC. Or that's a recommendation to the NEJAC to do that. She stated that
since they're dealing with multiple federal agencies, it wouldn't just be EPA regional
administrators; they would be dealing with all of those federal agencies which all have different

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regions which are different from EPA regions. Chair Shepard stated that she tends to forget
that a lot of the federal agencies have regional offices. She asked if all of them have regional
offices or just some? DFO Martin answered that they all have regional offices, but they're
different than EPA's ten regions.

Ms. Belen-Power stated that she is hearing the same theme from the public commenters, like the
farmworkers and the incinerator issue. She agreed that there's a huge disconnect between
experiences on the ground and what they're hearing from the administration about Justice40
being implemented. She stated that there needs to be — either through tours or through meeting
with the administrators — some way to connect what's happening on the ground.

Co-Chair Shepard stated that she read an article that demonstrates Texas not using the
resilience money equitably. She reiterated the top concern of EJ communities; will the money
actually get to the disadvantaged communities? She stated that they are seeing that play out in
real time. She stated that she wonders whether the agencies are really considering what they're
going to do in that instance.

DFO Martin noted that those issues should be raised when they meet with the IAC. She stated
that all of those agencies that were mentioned are a part of that. She stated that some of those
topics should be raised with them, and they need to start having those conversations on how to
work through some of these issues. Co-Chair Shepard reminded everyone that the meeting was
the next day, and those agencies will be there, and they can bring up some of these issues to them
in person.

Lucas Brown, U.S. Digital Service, stated they do anticipate releasing the tool this summer. He
stated that it would be updated once a year after its initial release. He stated that he has heard in
previous conversations a very strong desire from the WHEJAC to move very quickly to getting
agencies using the CEJST to direct benefits to disadvantaged communities, to issuing updated
guidance to Justice40 in the CEJST and to move as fast as possible on that.

Mr. Brown stated that he wonders if there was a possible way to get the best of both worlds of
having time for the Council to put together the suite of full recommendations and also have some
early feedback to help his agency get to Version 1.0. He stated that with the Scorecard Working
Group, they split the recommendations into two reports. He stated that there could be feedback
on items that could go into Version 1.0 and do a quick public meeting to approve them and then
spend more time and research on the things that are a little bit longer-term, 2.0, like collecting
new data sources and things that wouldn't be available this summer. He stated that he wanted to
open up the conversation about how to meet both goals of having time and space for the
recommendations and moving quickly towards Justice40 and CEJST implementation. Co-Chair
Shepard asked what that deadline would be? Mr. Brown answered that there is no firm
deadline, but would prefer it be earlier rather than later, maybe the end of June. He admitted that
he hadn't run this past his colleagues, so this is him speaking with his sense of the timelines.
DFO Martin replied that that is a conversation they should have with the workgroup.

Dr. Morello-Frosch appreciates the desire to incorporate their recommendations in this
Versionl.O and to try and accelerate it. She stated that she is also concerned because they did a
lot of hurry up and wait previously. She stated that the Council is asking for an extra two weeks

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to a month to be able to do due diligence, particularly to incorporate the feedback. Mr. Brown
acknowledged that that timeline is extremely reasonable and that there has been some hurry up
and wait in the past and that has been really challenging. Co-Chair Shepard stated that the
workgroup will be taking this up tomorrow and making some decisions about the timing going
forward.

Amanda Aguirre, Senior Advisor to CEQ Chair, stated that she and Mr. Brown will be at that
meeting. She stated that she doesn't anticipate having a deadline by the meeting because several
EOP partners have to decide on a series of policies and other updates related to the tool. She will
keep in touch with the workgroup about the deadline.

1.6 Closing Remarks & Closing

Co-Chair Shepard reminded everyone that this is DFO Martin's last meeting. DFO Martin
thanked everyone and said that she will miss everyone and that it has been a great experience and
that she has really enjoyed working with everyone. Co-Chair Shepard introduced Victoria
Robinson who will replace DFO Martin. Ms. Robinson introduced herself and stated that she
has been quite impressed with the work that DFO Martin and her team have been doing to fully
support the Council's efforts and the workgroup's presentation. She stated that she looks forward
to working with everyone.

Co-Chair Shepard thanked everyone for their hard work in preparing and running the meeting.
She introduced Amanda Aguirre to give a few closing remarks. Ms. Aguirre stated that, on
behalf of CEQ and the entire Environmental Justice Team, everyone has their sincere
appreciation and gratitude. She acknowledged DFO Martin's hard work. She reiterated CEQ's
commitment to pushing this ambitious but long overdue environmental justice agenda forward.
She reminded everyone that the comment period for the screening tool is still open until May
25th.

Co-Chair Moore thanked DFO Martin and everyone for a fruitful meeting.

Vice-Chair Tilousi stated that what's happening across the country seems to be getting worse
and she is always committed to trying to move things faster. She stated that people in the
communities are still suffering as heard again today. She stated that the more that they set
timelines and goals and objectives to move forward, the more they will see some goals being
accomplished. She stated that this is what she would like to see in the new team that has been
brought on board and she looks forward to trying to remain on track and move forward.

DFO Martin stated that, even though she will be moving offices, she will still be around. She
stated that it has really been a great experience helping build this Council. She thanked everyone
for their time and efforts, and she adjourned the meeting.

[ I llI MEETING WAS ADJOURNED]

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APPENDIX A:

Attendee List

I'irsl Name

l.asl Name

Oiuanizalion

Sara

Adelsberg

Deloitte

Fran

Aguirre

Unite North Metro Denver

M. Carlo

Altman

USDA/NRCS

Susan

Alzner

shift7

Whitney

Amaya

East Yard Communities for Environ Justice

John G.

Andrade

Old Bedford Village Development, Inc.

KT

Andresky

Breathe Free Detroit

Patrick

Andrews

FEMA

Stephanie

Anthony

Louisiana Democracy Project & La. NAACP

Francisca

Aparicio

Alianza Nacional de Campesinas

Joni

Arends

Concerned Citizens for Nuclear Safety

Jo Ann

Armenta

Purpose Focusd Alternative Learning

Dave

Arndt

Self

Natassha

Arreola

Allianza nacional de campesinas

Magdalena

Ayed

The Harborkeeepers

Sneha

Ayyagari

The Greenlining Institute

Sarah

Bailey

Flint Public Health Youth Academy

Richard

Baldauf

US EPA

Adrienne

Bandlow

Department of Commerce

Erica

Bannerman

Government

Ellen

Barfield

Beyond Extreme Energy

Nastassia

Barnes

FEMA

Edlynzia

Barnes

U.S. EPA

Claire

Barnett

HEALTHY SCHOOLS NETWORK

Sean

Bath

NO A A

Kathryn

Becker

NM Environment Department

Hormis

Bedolla

Alianza Nacional de Campesinas

Casandia

Bellevue

Earthjustice

Mitchell

Berge

Private Citizen

Dr. P. Qasimah

Boston

Tallahassee Food Now

Angelle

Bradford

Sierra Club Delta Chapter

Andrea

Braswell

Center for Environmental Health

Laura

Bretheim

University of Minnesota - Graduate Student

Emily

Brooks

USGS

Janice

Brown

NA

Doug

Brune

USEPA Region 7

Margot

Buckelew

Nonpoint Source Management Branch

33


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Dominique

Burkhardt

Earthjustice

Michael

Burns

Community and College Partners Program

Mike

Buza

Sierra Club: Nepessing Group

Sebastian

Caicedo

Florida Rising

Rev. James L

Caldwell

Coalition of Community Organizations

Stacey

Callaway

Ecology

Shashawnda

Campbell

South Baltimore Community Land Trust

Karen

Campblin

VSC naacp ktcPLAN

Morgan

Capilla

US EPA

Ari

Caramanica

USD A

Elvira

Carvajal

Alianza Nacional de Campesinas

Ann

Cass

Proyecto Azteca

Ester

Ceja

Idaho Transportation Department

Brian

Chalfant

Pennsylvania Department of Environ. Protection

Lois

Chang

CEEJH

Roxana

Chavez

Alianza Nacional de Campesinas

Claudia

Clifford

TCEQ

Stephanie

Coates

EDF

Julia

Cohen

Plastic Pollution Coalition

Deborah

Cohen

USEPA

Kimberlie

Cole

Strata-G LLC

Jasmin

Contreras

EPA

Elia

Cordero

Mujeres Luchadoras pregresistas

Helen

Cortes

USD A FS

Farrah

Court

TCEQ

Justin

Cowling

American Academy of Nursing

Kelly

Crawford

DOEE

Bria

Crawford

Environmental Protection Agency

Jasmine

Crenshaw

Earthjustice

Rebecca

Curry

Earthjustice

Molly

Daniels

Environmental Incentives

Bryan

Davidson

Tennessee Department of Environment and
Conservation

Dawn

Davis

INL

Rachel

Davis

Ministry of the Sisters of St. Joseph of Peace

Vithal

Deshpande

City of Somerville

Shantray

Dickens

FAA Civil Rights

Katharine

Donnachie

Private Citizen

Cece

Donovan

EcoLogix

Kevin

Doran

Western Governors' Association

Lori

Dowil

Corteva

Melinda

Downing

U.S. Department of Energy

Martha

Duggan

NRECA

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Jeannie

Economos

Farmworker Association of Florida

Chris

Elder

GSA

Amanda

Eller

Emerson Collective

Tania

Ellersick

USDA Forest Service

Norman

Emerson

Emerson and Associates

Lena

Epps-Price

US EPA

Michael

Esealuka

Healthy Gulf

Carole

Excell

Waverley Street

Cathy

Eylem

P&G

Ericka

Farrell

EPA

Ni colette

Fertakis

EPA

Timothy

Fields

Senior Vice President

Kate

Fishier

EPA

Blanca

Flores

Alianza Nacional de Campesinas

Victoria

Flowers

Oneida Nation

Mariana

Fontaine Osegura

Alianza Nacional de Campesinas

Florence

Francis

GSA

James

Free

US DOC NO A A

Lauren

Freelander

AT SDR

Claudia Araceli

Fritz

Center for Neighbrhoods

Paul

Gallay

Columbia Climate School

Emily

Gallo

HNTB

Anushi

Garg

University of Maryland

Danny

Garza

Mexican American Political Association

Beatriz

Gatica

Mujeres Divinas

Venu

Ghanta

Duke Energy

Olivia

Glenn

U.S. EPA

Leo

Goldsmith

ICF

Sheryl

Good

EPA Region 4

Amelia

Gooding Cheek

IERG

Vanessa

Gordon

USDA

Genesis

Granados

Air Alliance Houston

Justin

Gray

HUD

Daria

Grayer

AAMC

Manna Jo

Greene

Hudson River Sloop Clearwater

Ardie

Griffin

Emerald Cities Collaborative

Elisabeth

Grinspoon

USDA Forest Service

Grant

Gutierrez

Dept. of Ecology

Brandi

Hall

ADOT

Yvonka

Hall

Northeast Ohio Black Health Coalition

Stephanie

Hammonds

WVDEP-DAQ

Ben

Harms

USDA Forest Service

Leah

Harnish

American Waterways Operators

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Clea

Harrelson

NSF

Emily

Harris

FCC AG

Jill

Harrison

University of Colorado Boulder

Declan

Hayes

EPA

GRO

Health Center

GRO Health Center

Tom

Helme

Valley Improvement Projects (VIP)

Carey

Hengstenberg

Vermont Department of Environ. Conservation

Jenelle

Hill

EPA

Jack

Hinshelwood

VDH

Janice

Horn

Tennessee Valley Authority

Melissa

Horton

Southern Company

Jennifer

Hosier

University of Maryland, College Park

Lee

11 an

NYC Mayor's Office of Environmental
Remediation

Yvonne

Ivey

Booz Allen Hamilton

Zainab

Jah

National Birth Equity Collaborative

Julie

Jimenez

Private Citizen

Victoria

Johnson

Jacobs Engineering

Cassandra

Johnson

MDEQ

Doris

Johnson

DEEP

Tara

Johnson

USEPA

Nicole

Johnson

SLR International Corporation

kim

jones

EPA

Danielle

Jones

Mecklenburg County Air Quality

Sean

Joyner

U.S. Depart of Housing and Urban Development

Miriam

Juarez

Alianza Nacional de Campesinas

Kira

Kaufmann

USFS

David

Kay

Cornell

Zach

Keith

The Williams Companies, Inc.

Joseph

Keller

APA

Danielle

Kelton Sopko

Private Citizen

David

Keys

Calthos

Chet

Kibble

Environmental technical services

Rabi

Kieber

US EPA R2

Denae

King

Texas Southern University

John

Kinsman

Edison Electric Institute

Suzanne

Kline

CA State Water Board - Drinking Water -
SAFER

Abby

Klinkenberg

Bureau of Reclamation

Elizabeth

Kloeckner

academic

David

Kluesner

U.S. EPA Region 2

Renee

Kramer

North Carolina Depart of Environmental Quality

Fran

Kremer

USEPA

Emma

Kurnat-Thoma

Georgetown University NHS

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Deb

Kutska

Cook County Depart of Environment &
Sustainability

Paul

La Farga

San Diego Association of Governments
(SANDAG)

Kim

Lambert

U.S. Fish and Wildlife Service

Katie

Lambeth

EGLE

Zulima

Leal

North American Development Bank

Brian

Lewis

CDC

Keisha

Long

SC DHEC

David

Lonnberg

shift7

Olivia

Lopez

Ocean Conservancy

Michelle

Lovejoy

Environmental Defense Fund

Yaitza

Luna-Cruz

NASA HQ

Caitlin

Macomb er

WRI

Krista

Mantsch

GAO

James

Markoe

US Bank

Linda

Martin

Private Citizen

Brendan

Mascarenhas

American Chemistry Council

John

Mataka

Grayson Neighborhood Council

Alexandria

McBride

Waverley Street Foundation

Mary

McCarron

Ohio EPA

Wendy

McCarville

USAF

Caitlin

McHale

National Mining Association

Benjamin

McKenzie

CDC/ AT SDR

Reginald

McKinley

EPIC

Ameesha

Mehta-Sampath

US EPA Region 2

Danielle

Mercurio

VNF

Sarah

Merrill

SAVERGV

Melissa

Miles

New Jersey Environmental Justice Alliance

Melissa

Minor

General Services Administration

Amir

Mirsajedin

CDC

Lena

Moffitt

Evergreen Action

Chris

Moore

Eastman Chemical Co. - Kingsport, TN

Karli

Moore

Stanford University

Daisy

Morgan

USDA Forest Service

Bri

Morris

NAACP General Member

Terrence

Mosley

DOE

John

Mueller

Private citizen

Melissa

Muroff

Delaware County District Attorney's Office

Knowledge

Murphy

Multnomah County/Office of Sustainability

Christine

Murphy

American Academy of Nursing

Ayako

Nagano

NEJAC

Jake

Narciso-Stevens

Climastry

Christina

Ndoh

US EPA

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Pedro

Nieto

USD A

Gregory

Norris

ACES 4 Youth- Area Consortium of Educati

Avriel

Null

Tennessee Valley Authority

Yamiles

Nunez

Alianza Nacional de Campesinas

Maya

Nye

Coming Clean

Francisco

Ollervides

Ocean Conservancy

Mary

Olson

shift7

Laura

Olson

Jacksonville State University

Rachel

Olugbemi

US EPA - Region 01

Alex

Owutaka

US EPA

Anthony

Paciorek

Michigan United

Sarah

Packer

Center for Environmental Health

sangha

Padhy

Ramapo college

Anthony

Pahnke

Alianza Nacional de Campesinas

Maria

Painter

Mountain View Community Action

Leticia

Pascual

Mujeres Divinas

WILLIAM B

PATTERSON

East Bay Municipal Utility District (EBMUD)

Nestor

Perez

Earthjustice

Pamela

Perez

California State University Northridige, CSUN

Carina

Perez Europa

Oregon Physicians for Social Responsibility

Sophie

Pesek

RFF

Edith

Pestana

CTDEEP

Andrew

Pike

Virginia Department of Transportation

Melanie

Plucinski

Native Organizers Alliance

Deneine

Powell

City of MKE

Diane

Prather

USD A FS

Marguerite

Pridgen

CSH

Hugo

Prieto

EC A, Energy Coordinating Agency

Lei a

Rainey Brown

Northwest Area Indian Health Board

Elise

Rasmussen

Washington State Department of Health

Brian

Redder

AMWA

Dawn

Reeves

Inside EPA

Maria

Renteria

Alianza Nacional De Campesinas

Forest

Replogle

Mid-Region Council of Governments

Abdiel

Reyna

Texas RioGrande Legal Aid

Derek

Rice

None

Caroline

Ridley

US EPA ORD

Eletha

Roberts

EPA

Christina

Robichaud

US EPA

Victoria

Robinson

U.S. EPA

Martina

Roes

DZNE

Madeleine

Rohrbach

AAN

Marlene

Rojas

Alianza Nacional de Campesinas

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Gina

Romero

Florida Rising

Jena

Roscoe

Operation HOPE

Adrienne

Runnebaum

The Giving Grove

Abby

Ruskey

University of California - Merced

Dagmara

Saini

City Of Stockton

Andrea

Salazar

Michaels Energy

Elyse

Salinas

US EPA

Isabel

Segarra Trevino

Harris County Attorney

Mario

Sengco

U.S. EPA

Helen

Serassio

EPA

Kathryn

Sessions

Health and Environ Funders Network (HEFN)

Khalil

Shahyd

Natural Resources Defense Council

Donna

Shanklin

ACES

Nayyirah

Shariff

Flint Rising

Natalie

Shepp

Pima County Department of Environ Quality

Christopher

Shuey

SRIC and UNM-CEHP

Maria

Sisneros

US EPA region 6

Carolyn

Slaughter

APPA

Jonathan

Smith

Earthjustice

Megan

Smith

Shift7

Chris

Snyder

Passero Associates

Dan

Solitz

Private citizen

Jessica

Specht

FEMA

Gianna

St.Julien

Tulane Environmental Law Clinic

Joyce

Stanley

US Department of the Interior

Susan

Stilson

EPA

Robyn

Strickland

Oklahoma Corporation Commission

Feleena

Sutton

Aera Energy

Crystal

Swazy-Wallace

USD A

Theresa

Taylor

US Dept. of Interior - Bureau of Reclamation

Lorraine

Thiebaud

CalNEHJ

Nicholas

Tobenkin

Quanta Services

Mily

Trevino-Sauceda

Alianza Nacional de Campesinas

Raina

Turner-Greenlea

Black Sustainability, Inc.

Marisa

Valdez

AES Clean Energy

JV

Valladolid

ICC

Aditi

Varshneya

Global Alliance for Incinerator Alternatives

Jumana

Vasi

Midwest EJ Network

Gloria

Vaughn

EPA

rebeca

Velazquez

Mujeres luchadoras Progresistas

Marline

Vignier

HHS/OASH

Cristina

Villa

Department of the Interior

Cliff

Villa

University of New Mexico

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Randi

Walker

NYS Department of Environ Conservation

Carla

Walker

World Resources Institute

Walter

Walker

Greeley and Hansen

Tiffany

Wallace

USDA/FPAC

Stephen

Walls

NRDC

Margaret

Walls

Resources for the Future

Brett

Walton

Circle of Blue

Roxanne

Welch

USEPA

Kimberly

Wells

EEG

Sharad

Wertheimer

Woonasquatucket River Watershed Council

Jabbar

Wesley

Spire Inc.

Skye

Wheeler

Human Rights Watch

Chad

Whiteman

U.S. Chamber of Commerce

Wesley

Wiggins

U.S. EPA

Odette

Wilkens

Wired Broadband, Inc.

William

William

USEPA

Jane

Williams

California Communities Against Toxics

Beattra

Wilson

usda

Stiv

Wilson

Peak plastic foundation

Monica

Wilson

GAIA

Michael

Wohlstadter

East-West Gateway Council of Governments

Leah

Wood

Washington State Department of Health

Janene

Yazzie

NDN Collective

Naomi

Yoder

Healthy Gulf

Chris

Young

NACD

Rachel

Zander

Department of Natural Resources

Gregory

Zimmer

GFL Environmental Inc.

Pamela

Zimmerman

DOE Hanford

Ronald

Zorrilla

Outdoor Promise

Steven

Zuiss

Koch

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APPENDIX B

Online Submitted Written Public Comments

Northeast -1

Maine, Massachusetts, Rhode Island, Connecticut, New Hampshire, Vermont,

New York, Pennsylvania, New Jersey, Delaware, Maryland, DC
Full Name (First and Last): Odette Wilkens
Name of Organization or Community: Wired Broadband, Inc.

City and State: Forest Hills, NY

Brief description about the concern: Please see submission being sent by email on 4-15-22. Fiber optics
to the premises is a superior service and is "future-proof" as Tom Wheeler, former FCC Chair, testified in
Congress in March 2022, and will best serve unserved and underserved communities in bridging the
digital divide to achieve digital inclusion and digital equity, while preserving the health of residents in
those communities.

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

A major component that should be added to the Climate and Economic Justice Screening Tool is a metric
to measure in those Communities (1) the level of electrosmog generated, or that would be potentially
generated, from wireless infrastructure in unserved and underserved communities and (2) the amount
of fiber optics deployed, and needed to deploy, in unserved and underserved communities to close the
digital divide.

Full Name (First and Last): Cecelia Doucette

Name of Organization or Community: Massachusetts for Safe Technology
City and State: Ashland, MA

Brief description about the concern: Today's wireless technology consumes inordinate amounts of
energy, and the constant pulsations of radiofrequency microwave radiation biologically harms children,
adults and the environment.

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

Include responsible technology deployment with fiber-optics to the premises, with Ethernet connections
indoors to devices. Ensure the Climate and Economic Justice Screening Tool includes responsible
technology. Thank you for accepting public comment on the Climate and Economic Justice Screening
Tool, and for the work you are doing to ensure parity in all of our communities. Please include in your
tool responsible deployment of technology. Here in Massachusetts wireless radiation has become an
environmental and racial justice issue. For example: The wireless industry targeted Worcester, an
environmental justice community, for their utility "smart" grid program. They installed toxic electric
meters that pulse wireless radiation at ratepayers 24x7 and many have become ill. In Brockton,
Massachusetts, another underserved community, Verizon launched a 5G test pilot, radiating citizens at
close range with small cell antennas. Sprint then gave Brockton school children tablets that emit
wireless radiation at the students, with no safety instructions. Industry is prone to installing cell towers
at close range in underprivileged areas. Savvier towns are updating their zoning by-laws to prohibit
wireless communication facilities in residential and other sensitive areas. Following a two-year

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investigation, the Pittsfield, MA Board of Health issued this month a groundbreaking Emergency Order
to Verizon to remove a cell tower that made 17 children and adults sick and caused the pollinators to
disappear. As you are likely learning, wireless technology wastes inordinate amounts of energy too, and
inflicts great harm to the environment. I welcome you to read the attached submission to the
Massachusetts Senate Committee on Ways and Means. It lists 10 top reasons why investment in any
further wireless infrastructure buildout should be stopped, and why every citizen should have access to
hard-wired internet to the premises and be taught to simply use cables and adapters indoors to their
devices for far superior internet service. We realize wireless radiation harms are new to many, and I
would be honored to speak with you and your colleagues further to help connect the dots on this urgent
issue. We cannot continue to allow the wireless industry to immerse our society in electrosmog, we
must take responsibility at the federal level and we look to your leadership.

Last year, the Department of Energy asked for responses to an RFI on a potential Strategic
Uranium Reserve, our groups responded. We understand the DOE may be now moving towards
an RFP. We would like to reiterate that a SUR will put communities, especially Indigenous
Communities whom we work to support, at serious risk of harm, including to their cultural
resources, health and drinking water. Attached to this email are 10 letters and resolutions from
communities and tribes opposed to a SUR as a result of operations that could ramp up if a
reserve program is implemented according to the limitations outlined in the RFI last year (e.g.
existing facilities on federal land sacred to tribes/connected to tribal resources, and uranium
produced from alternate feed processing adjacent to a tribal community), and a letter from the
community raising the need for urgent regulatory actions in the face of uranium mining threats
brought about by a SUR. We consider this to be a serious environmental justice
issue. A SUR, will effectively subsidize uranium operations that are already causing harm to
communities. This is in direct conflict with the commitments President Biden made to tribal
communities during his first week in office.

We would like to request a meeting to discuss concerns around a SUR and protections that must be
advanced for domestic uranium mining. Blaine Miller-McFeeley

Dear White House Council on Environmental Quality,

The draft environmental justice screening and mapping tool that aims to identify communities
that are underserved and overburdened with pollution. Better identifying such communities
would allow for more equitable and effective investment, program implementation, and
environmental enforcement, improving outcomes for climate, conservation, and public health
policies. The National Wildlife Federation commends CEQ for bringing attention to the need for
improved analytics that can help target investments, programs, and enforcement to where they
are most needed. We also have suggestions for improvement, which we have submitted to the
docket — Please see the attached. You may also be interested in this Baltimore Sun op-ed from
Dr. Sacoby Wilson, head of the Center for Community Engagement, Environmental Justice and
Health at the University of Maryland, who recently issued a report in collaboration with NWF
that offered detailed EJ screening and mapping tool recommendations. Thank you for your work
to promote environmental and climate justice! Please feel free to reach out with any questions.

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Dear White House Environmental Justice Committee,

On behalf of the City of Somerville, we would like to submit the following comments to the White House
Environmental Justice Advisory Council (WHEJAC) for members' consideration: Somerville is one of the
highly-dense Cities in the United States, with a population of above 80,000 in an approximately four and
a half square mile area. Due to its proximity to the Atlantic Ocean, 5-foot flood incidences are expected
to increase in Somerville from this decade onwards. This will be an additional burden on the local
disadvantaged community. The USEPA has developed 12 Environmental Justice Indexes. They are
related to ongoing pollution issues and don't address the broader environmental impact issues such as
extreme weather conditions and floods. We propose improving the existing system and including data
collection related to climate change impacts in the EPA's EJ Indexes. What type of support is needed for
disadvantaged communities to participate in federal disaster preparedness or relief programs?

We propose a disaster preparedness education throughout school programs, target preparedness, and
mitigation investments in communities with disadvantaged populations. Providing more targeted
outreach after disasters is essential to assist underprivileged people with relief programs. FEMA has
done some work in this space through their ICPD program on efforts like the Emergency Financial First
Aid Kit, but this has seen limited adoption by organizations around the

country: https://www.fema.gov/emergency-financial-first-aid-kit How can Federal disaster relief and aid
programs better serve disadvantaged communities that have historically received fewer federal
benefits? They can start by limiting the distribution of aid and relief to populations that don't need it.
Disaster relief programs are too complicated and require too much paperwork. They potentially
generate conflicts due to concerns about individuals receiving duplicative benefits from federal/state
agencies or insurance. Too much effort to prevent fraud, waste, and abuse ultimately leads to extensive
waste. What process steps and information would help eliminate these disparities? Consider
implementing user-centered design approaches to disaster aid, similar to what has been done with
other safety net initiatives. In addition to the above specific suggestions, we suggest having greater
coordination with FEMA, HUD, and other agencies. Thanks Vithal Deshpande

Full Name (First and Last): Skye Wheeler

Name of Organization or Community: Human Rights Watch

City and State: Washington DC

Brief description about the concern: This maternal health crisis is rightfully a priority concern for the US
government. Preterm birth rates, as just one example, have generally been rising over the past years,
and are twice as bad for Black women than for white women. However, our view - echoed by many
academics and health workers working in the intersection between maternal and environmental health
- is that there is not yet adequate attention on the environmental health impacts on pregnant people.
Epidemiological literature shows exposure to extreme heat, hurricanes, wildfire smoke and other
climate change impacts and climate change-related disasters is linked with preterm birth and other
adverse birth outcomes. Like other human rights and civil rights organizations, we are excited that your
questions focus on how best to protect disadvantaged communities and how resources should be
allocated to make sure they can best participate in federal disaster preparedness and relief programs.
We strongly support your efforts to promote an environmental justice approach to climate change-
related and other disasters in the US. However, we also request that you promote a reproductive justice
approach as well and explicitly press for resources to protect pregnancy and newborn health to help
prevent the climate crisis worsening the gap between those who get to have a healthy pregnancy and
newborn and those who do not.

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What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

We would like the WHEJAC to consider recommending the following to government leadership on
climate change and other environmental justice issues: Ensuring access for all women and girls to
comprehensive sexual and reproductive health is a central part of disaster preparation and response.
Ensure ongoing access to comprehensive contraceptive choice for all women and girls, access to safe
abortion care for women and girls, and maternal, perinatal, and newborn health care, including lactation
support. This includes, but is not limited to, people living in shelters and in displacement after disaster.
Undocumented people should also be able to access emergency health services. Ensure that
reproductive justice organizations, doulas, midwives, other community birth workers, and lactation
consultants are equipped with information and access to authorities managing disaster preparedness,
response and recovery and are financially resourced to provide support to pregnant people and other
community members, including in response to domestic violence and gender-based violence. Grants for
community-based reproductive justice organizations, birth workers and other relevant groups should
include help to pregnant people and community members prepare for disasters and help families and
pregnant or postpartum people during disasters and recovery periods including by linking them to
emergency assistance and other resources, including for survivors of domestic violence. Ensure
organizations receiving government grants provide reproductive justice training and implicit bias
training for disaster and recovery staff. Find other ways to "mainstream" reproductive justice in disaster
and recovery work. Fund studies to improve understanding of (a) how disasters in the US impact
maternal and newborn health, (b) what interventions may better protect maternal and newborn health
from disasters, and (c) inequitable exposures and impacts for already-marginalized communities.
Reproductive justice organizations, doulas, midwives, and others serving low-income and other at-risk
communities should be included in disaster planning and resilience-building, including community
awareness building campaigns. However, these individuals and organizations should be appropriately
compensated for helping prepare communities for disasters. Frontline maternal health workers like
doulas do lifesaving work in low-income communities or communities marginalized by historical and
current racism but are often poorly compensated. Public health campaigns on the dangers of extreme
heat should include pregnant people, should be available in multiple languages and for people with
disabilities. Subsidized assistance, for example to support access to cooling devices or improved housing,
should include pregnant people as well as other populations at-risk from environmental health hazards
and climate impacts. Pregnancy accommodations at work, for example additional bathroom breaks or
water breaks for pregnant people working in hot indoor or outdoor environments, should be protected.
Ongoing work by the Department of Labor to design a federal heat rule, the "Heat Injury and Illness
Prevention in Outdoor and Indoor Work Settings Rulemaking" process, should fully include heat impacts
on pregnancy health and the final rule should be strong enough to protect pregnancy health. Thank you
so much for your reply. By all accounts, the vandalism and ATV motor cross riding, inside OLD NORTH
CEMETERY, is beyond disgrace. So again, thank you for your quick, thoughtful response. We are also
looking forward to hearing from you about the flags to be placed on the light posts on Main Street. The
CT Freedom Trail has these flags, which will be a monumental historical attraction, on the 6 light poles,
on Main Street. In my previous email, I also mentioned that we would like to want the banners of the
29th Colored Volunteer Infantry Regiment, also placed on these poles. Truthfully, this should not be a
problem to anyone, especially since you have banners on the light posts, surrounding Bushnell
Park. Mark, it's these small, respectful recognitions, that will improve to be big for the renewed
landscape of the community. Furthermore, these light poles are directly across the street from Sand
Everywhere School, the predominantly Black, segregated, elementary school. I'm not sure if the City of
Hartford sees the value of the North End, but our young Black students deserve the opportunity to learn
about the Black Civil War Heroes, buried across the street, from their school. With that said, we believe

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that these banners should be displayed on the light posts, by June 17, 2022. In fact, this show of
reference and support, is warranted to commemorate Connecticut's first year of Juneteenth becoming a
state holiday. To that point, the CT Freedom Trail Commission is presenting their plaque to the 29th
Colored Volunteer Infantry Regiment on June 18th. And frankly speaking, we have 30 days to
accomplish this task (fence closings and banners on Main Street). Without making any excuses, this is a
very realistic timeframe. In addition to the above, our group also has a few suggestions and
improvements, for the cemetery. #1. It should only be open from dusk to dawn, just like the other parks
and cemeteries in the city. Even more importantly, cameras should be installed at the front entrance to
identify, and to help, the homeless person(s), living in the cemetery. We think cameras should also be
placed at the former back entrances on Mather and Bethel Streets. In addition, the city should invest in
signs informing everybody that the cemetery is on the NATIONAL HISTORIC REGISTRY. People need to
know that security cameras are installed in several locations around the national monument. There
should also be visible signs that informs the public that, any violators will be prosecuted. #2. We would
also like to know what happened to the approximately $1.5 million dollar grant that was given to
Hartford to restore Old North Cemetery. It was about 10 years ago, but there is no obvious
renovations, or upkeep of any past renovations. These funds, and other available funds are critically
important for our proposed renovations and restorations. Again, we sincerely appreciate working with
you, and the City of Hartford, in our mission to restore Old North Cemetery to its well-deserved, national
glory and prominence. As you do know; this historic landmark is on the National Registry of Historic
Sites. Therefore, taking the necessary steps to make the cemetery, as such -- will attract scores of
visitors. Mark, we can meet with you to give you pictures of the 29th CV Infantry Regiment, so you can
get them transferred into Bushnell Park, light post size, banners. Please let me know your available
times, early next week. Again, we are so excited and grateful for our partnership with the great city of
Hartford, Connecticut.

Connecticut 29th Muaier.

connpctlcuthistory wg

Southeast -2

West Virginia, Virginia, Kentucky, Tennessee, North Carolina, South
Carolina, Georgia, Alabama, Mississippi, Arkansas, Louisiana, Florida
Full Name (First and Last): Antonio Alarcon
Name of Organization or Community: Moder 45 Doral
City and State: Doral ,FL

Brief description about the concern: There is a very powerful nauseating odor. We were celebrating my
son b_ day but we hat to ho back inside the strong odor and ash was so strong that make it impossible
to be outside please we need help. Incinerators

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:
Please help us removing incinerator of Covanta from our back yard.

This 29th (Colored) Regiment CVI 33-star US
"National" flag was presented to the unit March 8,
18M, in Fair Haven, CT - Courtesy of the
Connecticut Office of Legislative Management,
from the book Qui Transtulit Sustinet by oeraldine
Caughman

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My name is Corylee Gutierrez, I live in Doral Fl 33178, There is a very powerful nauseating odor. We
were planning to be outside in the backyard with friends and it is impossible to be outside. We fear for
our health. You have to do something about this for this makes it impossible living in Doral. " Please take
urgent action ! Regards Corylee Gutierrez. Incinerators

Full Name (First and Last): Guillermo E Lefeld

Name of Organization or Community: Vintage Estates Community

City and State: DORAL, Florida

Brief description about the concern: We have been suffering from very intense air pollution (intense
odors) that have been getting worse and worse and our local representative don't seem to care. Our life
quality have been affected as sometimes cannot be outside due to the intense nauseating smell coming
most likely from an old garbage incinerator nearby. This is really affecting the lives of a great deal of
people and politics or some other interests seem to be on the way.

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

We need the White House Council to know that local governments, specifically the county and the
county commission are hurting the people of city of Doral in Florida by not paying attention to a big
issue. This is not a partisan thing, it is the health of tens of thousands of Americans being at risk for the
negligence and who knows what type of interest of the county leadership. We need federal legislation
to protect our citizens from negligent local governments that endanger their lives. We need action! This
is getting worse.

Full Name (First and Last): Kay Zadra

Name of Organization or Community: Vintage Estate

City and State: Doral Florida

Brief description about the concern: The smell is strong and the air is polluted

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

Please shut down the garbage burner in Doral Fl because it is killing out families

Full Name (First and Last): Cesar Abarca

Name of Organization or Community: Doral Environmental Justice Community
City and State: Doral, Fl 33178

Brief description about the concern: We live under constant exposure to nauseating odor, particle
matters , and ashes. Our community is just 300 meters from the Covanta garbage incinerator. Our
population in the nearby area are 50000 people. We visited Covanta and found they are not monitoring
and controlling the (HEP) nor they have been audit by EPA Our social life is disrupted by this
contamination. Our health is under threat by the contamination. Our investment risk is very high(high)

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

-We don't want a ZGarbage Incinerator in our area, -EPA should give an opinion on the Miami Dade
County plans to build a new incinerator in Doral Environmental Justice Community. Distance standards
for a Covanta should be no less than 3 from residential areas -MDC Covanta standards are set based on
the age of the Garbage Incinerator not on the hazard they are for our community.

-ZEPA is not implemented operationally the institution guidelines regarding Recycling, etc.

Full Name (First and Last): Josef Correia

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Name of Organization or Community: Pinnacle at Park Central
City and State: Doral, Florida

Brief description about the concern: The continuance use of incinerator in Doral is no longer
acceptable. First the technology is outdated, there are newer methods for zero waste and this is what
we need to strive for, just as we are doing with the zero emissions from cars by moving to hybrid
vehicles and electric vehicles. Second of all, when the incinerator was built, the area around it was
industrial, then by the same county (Miami Dade) that approved the incinerator, also approved
residential construction around the incinerator. They obviously do not care about the health of the
residents of Doral or any cities near us. The emissions from the incinerator and ash travel from miles,
therefore impacting a lot of residents and commercial area.

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

We advise for you to look into it and realize that incinerator technology is outdated and that there are
better methods that not only produce more energy recovery but also do not impact the health of
humans and earth. It's time we the country's resources to be truly green as possible instead of just
letting some counties and areas profit from business deals that only produce income for them and
literally DO NOT CARE about human life and/or planet.

Full Name (First and Last): Raul Arias

Name of Organization or Community: Landmark

City and State: Doral, Florida

Brief description about the concern: Here in the city of Doral, and specifically in the Landmark
community, we have been severely affected by the Covanta Waste Management site that causes
terrible odors and diseases through all the population that is emanated daily by this place. Our
communities have been asking for years to move this facility our of Doral where it doesn't affect citizens
that live around, but we haven't been heard, but surprisingly there's a plan now to not only leave the
current facilities but build another trash management plant right next to Covanta which will generate
more problems and bad quality of life for all of us citizens of Doral city. Incinerators

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

The renewal of the lease of Covanta needs to be not extended and the permissions for the creation of a
new facilities here in Doral need to be revoked. This is affecting all residents in this city, and it's a severe
health problem for anyone that lives in this city.

Full Name (First and Last): Eduardo Moreno

Name of Organization or Community: Landmark at Doral

City and State: Doral, FL.

Brief description about the concern: The Doral community has grown significantly while a Waste
Incineration Plant operated by COVANTA contaminates de air with bad odors and ashes.

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

Remove the COVANTA plant from the city of Doral and build a new, updated one on another location.

Full Name (First and Last): Claudia Martinez
Name of Organization or Community: Covanta
City and State: Doral

Brief description about the concern: Smells bad.

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What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

Contaminating.

Full Name (First and Last): 27 Names used the same public comments

•	Odel Torres

•	Pilar

•	Veruschka Jaimes

•	Jorge Andres Besereni Karaz

•	FabioVitale

•	Raul Arias

•	Juan De Maqua

•	SuiJim

•	Juan De Maqua

•	Margarita Wong

•	Hector Villalobos

•	Marlon Pareja

•	Dirla Pareja

•	Maria Casado

•	Maria Abreu

•	Eduardo Briceno

•	Javier Guerra

•	Lucia Sirah

•	Jose Ginestra

•	Jose Antonio Grullon Matias

•	Orlando salas

•	Yasmin Balzan

•	CARMEN TABARES

•	Maria Obediente

•	Elimer Gonzalez

•	Vivian Ginestra

•	Roberto Fernandez

Name of Organization or Community: Landmark of Doral, Fl
City and State: Doral, Fl

Brief description about the concern: To whom may I concern, lama resident of the Landmark
community in Doral, right west from the Covadonga recycling plant, located just southwest of the plant.
I am someone that love this community. We have spent many hours dealing with this facility, especially
when the smell is too strong. Years ago people usually talked to the plant folks and most of the time the
smell went away. The Covanta Incinerator facility was established back in 1982, a first class facility
capable of using waste disposal to produce energy, however after forty years their technology is no
longer the greatest. They can't no longer control the smell with just a phone call. I believe none of you
are driving a 40-year-old car, it is time to put this beast to sleep, it had surpassed it's useful life and new
technology shall replace it. Please help us by telling the county not to make a huge environmental
mistake, we asked the county before October 1, to cancel the renewal permit, this action will give Doral
residents a cleaner air, without the smell, the heavy traffic of garbage trucks, and environmental
violations. Of course, the county is trying to pass a new resolution to build a new facility right by the

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same location. We are asking all of you to please ask the county to reconsider relocating the new plant
somewhere else in the county and spare Doral residents of having this new plant in our backyard. If this
is a great recycling facility, I am sure any city would love to have it in their neighborhood. Just remember
waste disposal is not a Doral problem, it's a countywide problem. Lastly we ask you to urge the county
to look for other recycling options that may work better and cost much much less. Thanks for the
opportunity.

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

Stop construction of the new recycling plant in Doral, FL and find new recycling methods that don't
affect the quality of air.

Full Name (First and Last): Heli Valero

Name of Organization or Community: Florida Rising

City and State: Doral, Florida

Brief description about the concern: We live at Doral, FL, when we bought, we already know about the
trash problem but we never expected that the city will approved 20 more years and a new plant inside
the old one, it's insane that this can happened to us. Covanta incinerator problem

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

Please revoke any authorization and find another place to build the new factory, far away from Doral,
we are alone in this battle, we need to breathe clean air for our children and ourselves. As a father I beg
your help. Thanks.

Full Name (First and Last): Giselle Ojeda

Name of Organization or Community: Landmark Doral

City and State: Doral, Fl

Brief description about the concern: Waste is creating environmental issues causing allergic reaction to
residents and health hazards. There is a Coventa waste company located just northeast of our
community. The air is polluted causing bad smell, allergies and water contamination. Incinerators

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

Remove plant or make it environmentally safe. To relocate the plant as their lease expires at the end of
the year. Local politicians want to keep it. However is causing a health hazard for all of us, including kids
and pets.

Full Name (First and Last): Renatta Barzana

Name of Organization or Community: Landmark at Doral

City and State: Doral Florida

Brief description about the concern: I am asking all of you to please ask the county to reconsider
relocating the new plant somewhere else in the county and spare Doral residents of having this new
plant in our backyard. If this is a great recycling facility, I am sure any city would love to have it in their
neighborhood. Just remember waste disposal is not a Doral problem, it's a countywide problem. Lastly, I
ask you to urge the county to look for other recycling options that may work better and cost much less.
Incinerator

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

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I am asking all of you to please ask the county to reconsider relocating the new plant somewhere else in
the county and spare Doral residents of having this new plant in our backyard. If this is a great recycling
facility, I am sure any city would love to have it in their neighborhood. Just remember waste disposal is
not a Doral problem, it's a countywide problem. Lastly, I ask you to urge the county to look for other
recycling options that may work better and cost much less.

Full Name (First and Last): Maria Evangelista
Name of Organization or Community: Vintage Estates
City and State: Doral Florida

Brief description about the concern: Constant exposure to trash odor. This situation is getting stronger
every day and sometimes we have to cancel our kids swimming classes because of this nauseating odor.

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

Remove the garbage incinerator

My mom has lived in Louisa, VA 23093 for 60 years. I have been trying to get help, but it was difficult
due to COVID. I have included photos and videos of the emissions, smoke, ash and dust coming from the
plant. You also see how close they are to us. (Not sent to WHEJAC) They are currently operating off a
temporary permit and try to get a permanent permit. I apologize for the difference format. The letter
below is what I sent to DEQ: I have recently learned that a permit application is pending regarding the
Boxley Zion-Crossroads asphalt plant in Louisa. I would like to request a formal public notice and an
opportunity for public comment on the pending permit application. Given the plant's proximity to my
property and home (just 50 feet away), a public comment opportunity would allow me, my family, and
neighbors to voice our concerns. Some of the harms I plan to share, experienced as a direct result of the
Boxley Zion-Crossroads asphalt plant, are: ODOR: The plant emits an odor that not only smells like tar
and chemicals, but also threatens my own and my family's health. The plant's fumes have caused my
mother to suffer headaches and caused me to experience a burning sensation in my nose and throat.
When I sought medical advice about these ailments, my nurse informed me that the plant's emissions
are hazardous, and recommended that my mother and I double mask, limit time outdoors, and change
clothes after being outdoors. NOISE: When the plant operates, it generates a loud, persistent hum,
audible from inside my home. The trucks entering and exiting the plant also produce excessive noise by
beeping when backing up, using air brakes, and slamming their tailgates. DUST: The plant's operations
generate a considerable about of dust that comes onto my property, caking the ground, our cars, and
everything else in a layer of dust. The odor, noise, and dust created by the plant are prohibiting me and
my family from able to enjoy our property. We are no longer unable to work from home and cannot
host cookouts or invite family over. Thank you for your consideration. Please reply to this email so I can
be sure that DEQ has received it. We need help and assistance. I am very concerned health wise,
environmental and also my mom feels she is being push out of her home. She have worked hard to buy
her land and build her home. How would anyone feel you cannot go outside to breath fresh air and
cannot be able enjoy your home? It is a strong statement made when Tamera Thompson made she have
worked DEQfor 30 years and never seen a facility built this close to a home or business. Why our local
supervisor not respond to anyone? I am sure they wouldn't want this in their back yard. Your assistance
will be greatly appreciated. Thank you, Theresa Coffey

Midwest -3

Ohio, Indiana, Michigan, Illinois, Missouri, Wisconsin, Minnesota, Iowa,

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Kansas, Nebraska, South Dakota, North Dakota

"The Department of Defense currently operates 38 toxic burn sites in the U.S., mostly in low-
income, rural communities. At these sites, the military collects excess, obsolete, or unserviceable
munitions, including bullets, missiles, mines, and the bulk explosive and flammable materials
used to manufacture them, and destroys them by adding diesel and lighting them on fire, or by
blowing them up. Last fiscal year, the Department of Defense destroyed 32.7 million pounds of
explosive hazardous waste on U.S. soil using these methods, known as open burning and open
detonation." Laura Olah / Safe Water Around Badger

My name is Katherine Andresky, I live in Detroit, Mi, anishinaabe territory, near the now closed
Detroit incinerator and I'm a member of BFD. I'm here today to urge you to prioritize regulation
of solid waste incinerators and chemical recycling facilities by calling on the EPA to take long-
awaited regulatory action to protect communities like mine across the nation. Because the EPA
has failed to regulate incinerators, it exposed my neighbors and family to unnecessary risks while
our incinerator operated until 2019. Our facility has shut down from years of advocacy calling
out leaking stacks and nearly 1000 odor and clean air violations. Yet, if the EPA would have
done its job, it would have saved so many lives. My small 8 by 6 block neighborhood
association, located one mile downwind of the Detroit incinerator lost over 22 members to
COVID because even though our facility shut down, the lax regulations of this facility for 33
years caused a lifetime of respiratory and cardiovascular problems that my community still lives
with. COVID hit us hard because the EPA did not do its job regulating facilities like these,
causing us to breathe in small particles of trash. Incinerators are often located in overburdened EJ
communities and burn tons of plastic per year. It is important to remember that the fossil fuel
industry is causing harm from the time the oil is taken out of the ground to the time these single
use plastic products end up in landfills or burned in an incinerator. What's worse is that these
billion dollar industries think that pyrolysis and gasification, so called chemical recycling
facilities can stop our plastic problem by burning it. That just creates another problem with our
health that the fossil fuel industry does nothing to address. These chem recycling industries that
heat plastics to make fuel need to be regulated as incinerators. Burning plastics does not solve
our plastic problem, it makes the health of our communities and the environment worse. If these
facilities are not more strictly regulated, they will continue to increase cancer risks in young
women like my friend Emily who just had a mastectomy at age 38, because she lived near this
incinerator and breathed in the hormone altering burnt-plastic pollution that illegally leaked from
our stacks for years. The EPA is currently legally obligated to review and revise standards for
incinerators every 5 years under the Clean Air Act, but the EPA has repeatedly failed to update
these standards, increasing cancers, asthma, and heart problems to my friends and family. These
regulations are vital to protecting neighboring communities from dangerous incinerators. It's
indefensible to let incinerators operate any longer without stronger and more meaningful
oversight of their dangerous operations. Communities like mine have been waiting far too long
for updated regulations and no community can afford to wait any longer. — 3 min max - As a
leading voice for environmental justice, I urge you to make waste incinerators, chemical
recycling technologies, and the frontline communities living near them a top priority by
following the regulations that are listed within the Clean Air Act. I also urge your strong support
of FY 2023 Interior, Environment & Related Agencies bill to direct the EPA to consider climate
and environmental justice impacts of chemical recycling technologies in their ongoing rule-
making process regarding the regulatory treatment of pyrolysis and gasification units under

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Section 129 of the Clean Air Act. You have the power to elevate this issue with the Biden
Administration and get the EPA to finally move ahead with these vital and long-overdue
regulations and protections our communities demand and deserve.	

To the Honorable leaders of WHEJAC: Chair Brenda Mallory, Co-chair Richard Moore, Co-chair Peggy
Shepherd, Vice-chair Catherine Flowers, Thank you for last week's 2-day informational meeting on the
EPA Screening Tool regarding the Justice40 Initiative and Disaster Response. I'm submitting these
comments on behalf of Just Transition Northwest Indiana, a grassroots organization working to support
EJ communities in Northwest Indiana. For the past two years, Just Transition Northwest Indiana has
been organizing with the NAACP LaPorte County Branch, Northwest Indiana Ministers' Conference,
Earthjustice, and the Hoosier Environmental Council on various local EJ issues. My first point: The
Midwest advisory panel for WHEJAC is composed solely of 3 representatives from Minnesota. This is not
a fair representative sample of Midwest environmental justice communities. Northwest Indiana is a
major industrial pollution hotspot for the entire U.S. According to the Assessment of Environmental
Justice Needs in Northern Lake County Communities, a 2018 report by the Hoosier Environmental
Council, the City of Gary alone has 52 CERCLA/Superfund sites, 423 hazardous waste sites, and 460
underground storage tanks. Yet, this predominantly Black and Brown community continues to be
inundated with industry permit requests for new developments that will threaten the health of
residents and the environment of the entire Region. I urge you to read the linked report for complete
statistics and analysis. Alongside the NAACP Gary Branch, community members have formed Gary
Advocates for Responsible Development (GARD) to fight back against these environmental assaults in
their neighborhoods. Whiting, Indiana, is home to the largest BP refinery in the U.S., and the group BP
Whiting Watch attempts to watchdog the facility. Our primary focus at Just Transition NWI is the
community of Michigan City, Indiana, where 2 million tons of toxic coal ash waste are leaking into Lake
Michigan and neighboring Trail Creek at NIPSCO's Michigan City Generating Station. The Michigan City
community is predominantly Black, Brown, and low-income, with / of the residents living below the
federal poverty level. The coal ash at the NIPSCO site is slated to stay there indefinitely because it is
considered a "legacy" or inactive landfill and not covered under the federal CCR Rules. This emergency
along the lake will have an ongoing devastating impact on community health, the environment, and the
economy if not rectified. NIPSCO has for decades dumped its coal ash waste into pits along and on the
lake. In the Town of Pines, directly west of Michigan City, the community recently received a consent
decree from the Department of Justice to clean up NIPSCO's contamination stemming from the Yard 520
landfill, now an Alternative Superfund site. NIPSCO knowingly dumped its toxic coal ash there and
offered it as road and yard fill for the town, homes, and playgrounds. The town still has not been fully
remediated, and 38 homes have been deprived of a municipal water hookup after NIPSCO's ash
poisoned their wells. 70 residents are obligated to NIPSCO to provide them with bottled water. This is a
classic example of misuse of power and the fox guarding the henhouse. This low-income town could
desperately use a community point person from EPA for outreach and technical assistance. Even though
a consent decree was issued, they still have difficulty navigating what's to come. The Town of Pines is an
example of how "administrative burden" works to undermine environmental progress. No one there has
the capacity nor training to deal with the situation they are victims of, and once again, the polluting
industry is off the hook. We fear that NIPSCO will continue its free reign in Michigan City if its legacy
waste is allowed to remain on Lake Michigan, negating any repurposing of that area for the population
to use for community benefit. Furthermore, the city of Chicago is home to many BIPOC-led groups, more
specifically Little Village Environmental Justice Organization (LVEJO) and Southeast Environmental Task
Force (SETF), both of which are doing incredible EJ work on the ground there, in addition to Clean Power
Lake County (CPLC) in Waukegan, Illinois. Please consider inviting representatives from all the
organizations mentioned in this email to weigh in on any and all federal EJ programs! My second point:
We have also spearheaded legislative efforts, but our progress has been inhibited in a highly

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conservative supermajority-controlled, regulated utility state. The supermajority sits on billions in a
"rainy day" fund, while the Indiana Department of Environmental Management (IDEM) and the DNR
have had their funds stripped down to barely operational. Commissioner Bruno Pigott recently left his
post as IDEM Commissioner to join EPA and is well aware of the tangled situation here. In the Indiana
General Assembly, the House and Senate Environment Committees refused to hear almost all
environmental bills in committee. The year before last, no environmental bills were heard. Instead, they
were amended into best-case scenarios for industry. Still, this is the state we are supposed to trust with
federal funds coming in. This is an untenable plan for Indiana. We appreciate your recognition of states
like ours struggling with this stranglehold. We are gravely concerned that any EJ funding whether
through the Infrastructure Plan or Justice40 Initiative that becomes available to the State of Indiana will
be deliberately misappropriated. We urge you to have boots-on-the-ground representatives in EJ
communities like Michigan City, Gary, Indiana, Chicago, and Waukegan, and select members of these
organizations to be a part of WHEJAC Midwest representation.

Thank you for your consideration. Sincerely, Susan Thomas

Southwest -4
Texas, Oklahoma, New Mexico, Arizona
Full Name (First and Last): Sarah Bishop Merrill
Name of Organization or Community: SAVERGV
City and State: Boca Chica, TX

Brief description about the concern: Our human and endangered species populations here are
underserved. We are currently needing help resisting 2 more LNG export terminals and their related
pipelines, all of which will have a huge Carbon Footprint, worsening extreme heat (114 degrees F.
already the Valley in Rio Grande City this week!), fire danger, drought, heat stress for outdoor workers,
and species extinction. In this comment, I stress the need to deliver funding for the Weatherization
preparedness, and then Weatherization Assistance money in the Bi-Partisan Infrastructure legislation, to
our indigent and lower income communities. Another concern we need you to refer to agencies is that
in permitting LNG and pipelines, their cumulative atmospheric effects (Methane, VCEs, GHGs increasing
even if wetlands destruction is mitigated), and the impact on Climate Change of continuing these fossil
fuel projects. Since our underserved communities, in colonies, the shrimp industry and our tribal
community, are especially vulnerable to flooding here, when septic systems flood and leak, causing
cholera outbreaks among other trouble, we need to develop, with your help, Eco-System Services
research and plans like those in Wilderness Houston, whose website is linked here.

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

Help us encourage the Energy Department to stop new LNG projects, not to produce the full 30 billion
Cu Meters permitted by limiting or banning new LNG projects, which have a huge carbon footprint.

Also, let EPA review these projects, not just FERC and USACE. Force the permitting agencies to consider
the cumulative effects in terms of GHGs and climate change, -excessive warming and flooding, - not just
whether more wetlands are preserved, as mitigation. Expand concept of MITIGATION to include
mitigation and adaptation to extremes of Climate Change. Stop LNG and preserve the quality of air and
life for our underserved populations, who will not be employed in these LNG plants. Also, facilitate
funding to train construction contractors to construct sustainable construction with adequate insulation
AND ventilation and filtration systems, in homes, schools, and workplaces, on a larger scale than
Proyecto Azteca has produced so far. Housing for our underserved populations needs construction and
improvement, retrofitting, and weatherization.

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West -5

Colorado, Wyoming, Montana, Idaho, Washington, Oregon, Utah, Nevada,

California, Alaska, Hawaii

I was on the virtual public meeting for 3 and a half hours waiting to speak on public comment.

There was only one person from California who spoke. The rest were from East coast and

Oregon. This is very disturbing to a member of the community from the Central Valley. Next

time recognize the Central Valley!!! John X Mataka

Full Name (First and Last): Laura Rosenberger Haider

Name of Organization or Community: Fresnans Against Fracking

City and State: Fresno, CA

Brief description about the concern: Some residents of Fresno, CA are showing signs of Arsenic
poisoning including muscle cramps, dehydration, peripheral neuropathy, pain or swelling in feet and
hands or wrist, tingling, peripheral vascular disease, headaches, confusion, drowsiness tumors, skin
lesions, low kidney function, loss of night vision, anemia, diarrhea, nausea, cognitive problems, hearing
loss, cardiovascular problems, epilepsy, strokes, hair loss On a blood test for arsenic, my results were at
the high end of the range. In addition, I'm allergic to the TCP in Fresno tap water and it makes me
thirsty. There is a poultry farm with high PM 2.5 emissions in SW Fresno and a biomass plant in SE
Fresno. The old leaky Raisin City Oilfield is on our aquifer recharge zone.

What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:

Ban new oil wells and reduce fossil fuel production to decrease climate change that is reducing our
supply of fresh water. Distribute free Organic vegetable juice (without toxic metal pollution) on the
streets of Fresno County, especially in SW Fresno. Also distribute free PM 2.5 masks in every store there.
Keep repairing our filtered water machines that are often broken or vandalized by those who don't care
about human lives. Some parts of Fresno County don't have nearby filtered water machines.

Dockett/No Location

Why is an Asphalt Company being allow to circumvent appropriate channels? They are building
the plant across the road from a low income housing community that is primarily black and
already experiencing major lung ailments due to environmental hazard's exposure (would
burning/smoke emissions plant). The asphalt is being built on the southern border of a township
but will have adverse effects to the residents in the city but does not have to comply with city
regulations! It tried to build the plant a few years ago in an all-white township, but the residents
protested and this is the result. A very sneaky way to circumvent community opposition. This
seems to be an epic failure of the monitoring system!

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APPENDIX C:

Additional Submitted Written Public Comments

Appendix #

5G Tree Care Industry Journal i-2021.clocx,pof„„							..2

0414-2022. Proaerty Vanagenent Cos. J5YK Disf'bi t'on ^etter.pcf				6

Elecfortagnetic Fields Linked to ftstnma in Kids.pcf			<3

EMF arid W'ldire Pa-t 2.pdf							li

EN DAL. M It- to DOE F'NAl.pdf						145

EkuIo i-'ng-Rsc:al-Eq uity-ancf-Social-J jst'te-'rr p3cts-of-CelHowers-3nd-ZTA-19-07.pdf								148

FW CHmate 8 Economic Justice Screening Tool Vay 25, 2022,udf	......................................151

JSC and NPN a comments to WHEJAC on federa1 disaster relief, pdf					153

Letter to 5ecretary G-annolm re Uranium M r"ng Concern 3-25-22.od*...„.	......................................160

MACD 2022-05-25 WHEJAC Conriients.pdf..,									...163

NRX et si te EPAw att Itr2 fv'av 2022.pdf.					......168

NWF Comments CEO tool RR,adr														176

RWPRCA It'to DOE zhal.pdf							179

S- 156 W reless Radiation History' "esthiories and U'ger.cy.pcf 						........132

State New Hatrpsnire 5G final report,pdf												......194

SjR Letters and Resolutions F \AL 4-29-22.ad'											5S4

~ne drive to wiaen tne digital divide -CalMatters.pdf									...593

"HE HAZARDS OF n E^EC-ROMAGNE~IC ZIELDS |EMrS).3df				..................................597

"he Kids Are Not All R gftlecn Health Al son Main .pdf.......					................................600

~nerm si and non-thermai healtn efects oc low "ntensity non-~er"nr,g 'saiat'on- An inse^national

perspective,ad*'																....604

L'MUT_Resoibtion2D21-135_Oppos tion_Str3tegic_Jr3r1ium_Reserve.pdf 		...620

W5sn ngton-Spectatcir-56 2022Fjil article .pdf					622

WHEJAC ^etter 4-14-22.ad""					.....626

WHEJAC Meeting Comments HG NJV 20220511.paf			6J4

WHEJAC Subrr s; on 4-14-22 =INA.,pdf			638

WHEJAC submission May 25 2022.pdf										..,..ง46

WHEJACpdf																		...650

WHEJACK $11 and LMD Comment Submisston.pdf						.....654

Wireless is an Environmental Justice Issue.pdf				 ,670

55


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Appendix #

5G Tree Care Industry Journal l-2021.docx.pdf	2

04142022.Property Management Cos. JSYK Distribution Letter.pdf	6

Electromagnetic Fields Linked to Asthma in Kids.pdf	8

EMF and Wildlife Part 2.pdf	11

ENDAUM Itr to DOE FINAL.pdf	145

Exploring-Racial-Equity-and-Social-Justice-lmpacts-of-Cell-Towers-and-ZTA-19-07.pdf	148

FW Climate & Economic Justice Screening Tool May 25, 2022.pdf	151

JSC and NPNA comments to WHEJAC on federal disaster relief.pdf	153

Letter to Secretary Granholm re Uranium Mining Concern 3-25-22.pdf	160

NACD 2022-05-25 WHEJAC Comments.pdf	163

NRDC et al to EPA w att Itr 2 May 2022.pdf	168

NWF Comments CEQtool RFI.pdf	176

RWPRCA Itr to DOE Final.pdf	179

S. 186 Wireless Radiation History Testimonies and Urgency.pdf	182

State New Hampshire 5G final report.pdf	194

SUR Letters and Resolutions FINAL 4-29-22.pdf	584

The drive to widen the digital divide - CalMatters.pdf	593

THE HAZARDS OF in ELECTROMAGNETIC FIELDS (EMFS).pdf	597

The Kids Are Not All Right Tech Health Alison Main .pdf	600

Thermal and non-thermal health effects of low intensity non-ionizing radiation- An international

perspective, pdf	604

UMUT_Resolution2021-135_Opposition_Strategic_Uranium_Reserve.pdf	620

Washington-Spectator-5G 2022FuII article .pdf	622

WHEJAC Letter 4-14-22.pdf	626

WHEJAC Meeting Comments HG NJY 20220511.pdf	634

WHEJAC Submission 4-14-22 FINAL.pdf	638

WHEJAC submission May 25 2022.pdf	646

WHEJAC.pdf	650

WHEJACK SJI and LMD Comment Submission.pdf	654

Wireless is an Environmental Justice lssue.pdf	670


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Rick Howland. Beware the dangers from AM radio and 5G transmission sites. Tree Care Industry Journal. Jan 2021. pp.
14-18. http://digimag.tcia.org/publication/?m=54984&i=687824&p=l&ver=html5

BEWARE

ปY RECK HOWLAND

the Dangers from AM Radio
and 5G Transmission Sites

As if tree care isn't dangerous
enough, there's an increasing
safely threat that hasn't yet got-
ten much attention - radio waves. Radio
waves are everywhere, and have been
since the dawn of the universe. Man-
made ones have been around for more
than a century. starting with the wireless
telegraph. But with ever-more sophis-
ticated uses of the radio spectrum and
increased use of aerial equipment -
aerial lifts and cranes - in proximity to
the source of radio waves, serious injury
becomes a concern.

The latest threat is the proliferation of
the so-called 5G, or Fifth Generation,
cellular-phone networking that promises
faster data speeds and greater reliability
using multiple technologies, including
mini-cell sites at the neighborhood level
on utility poles. But working too closely
or too long near one of these mini instal-
lations or near a high-power radio trans-
mitter can be dangerous in several ways,
specifically resulting in burns or, in some
rare circumstances, electric shock.

The industry has experienced incidents
related to radio-frequency (RF) radia tion

A small-cell-site round,
omni-directional antenna
atop a pole. Photo courtesy
of Lucas Tree,

John Haehnel, director of safety and
training for Tree Tech, Inc., a dual-
accredited, 38-year TCIA member com-
pany headquartered in Foxboro. Massa
chusetts, can speak to the dangers from
experience, and lias the scars to prove it,

Tins past September, Haehnel and his
utility line-clearance crew were working
just outside of Boston with an all-terrain

"! got zapped,
maybe from
the AM tower
or the 5G. We
are running into
that more and
more"

John Haehnel

crane within the proximity - about soo
yards - of several AM radio lowers and a
SG cell-transmission installation, "1 got
zapped," he reports, "maybe from the
AM tower or thegG, We are running into
that more and more,"

Haehnel. who happened to be filling in
for the vacationing crane operator that
day, states that, as one of his crew was
getting ready to go aloft, the worker re-
ported something was wrong and that
he felt as if he was being shocked. (This
phenomenon is described in numerous
Federal Communications Commission
[FCC | documents.)

Haehnel had the crane boom out about
no feet or more. "1 had the crane's ball
down to lie in the worker, walked over
to it. got to within a foot-and-a-half
and got zapped by the bail." He says the
lightning-like flashovcr resulted in first-
and second-degree bums and a scar
to one hand. '"Hie ball was so hotr you
could not touch it"

Initially. Haehnel thought the situation
might be something electrical with the
crane, until the nearby radio towers ex-
plained it. "Ironically, I had just done a


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The equipment
cm this pole
is part of the
small-cell site.
There is usually
information ort
the p ole about
who owns it
and contact
information,
as well as
caution signs,
Photo courtesy
of Tree Tech.

small-scale, $G safety presentation just
two weeks prior," he says, adding, "but
from where we were, we could riot see
the bigsC antenna," which is part of a sG
network, not just thesmall local sues.

Haehnei reports that they later discov
ered four or five AM antennas and the big
sG antenna Installation nearby. "We had
scoped out the site and put the crane
ball nest to the tree, but we could not see
the towers from ground level," he say s.

Because of this incident, Haehnel's crew
shut down the job and left the site.

When he got "gapped." initially the ef-
fect did not seem too bad, Haehnei says.
"It was like an electric burn Hashed over
my left hand like a first-degree burn,"
The next day, Ha eh is el says, "the middle
finger had developed a second degree
bum and there was a hole in my finger,"
which accounts for the scar.

Background

The American Cancer Society (ACS)
says of radio frequency, "Some people

can have significant RF exposure as part
of ".heir jobs. This includes people who
maintain antenna towers that broadcast
communication signals and people who
use or maintain radar equipment"

TCIA has found this also includes aerial
lilt and CTane operators performing tree
care, mostly utility-line clearance, but
potentially residential crews as well.

The ACS continues, "If KF radiation is
absorbed by the body in large enough
amounts, it can produce heat. This can
lead to burn and body-tissue damage.
Although RF radiation is not thought to
cause cancer fay damaging the DMA in
cells the way ionizing radiation does (for
example. X-rays), there has been con-
cern that in some circumstances, some
forms of non-ionizing radiation might
still have other effects on cells that
might somehow result in cancer."

The FCC. in multiple published docu-
ments. refers to both the dangers from
RF exposure mentioned above and
the rare but potential danger of elec
trscal shock from radio waves. Though


-------
speculation on some level continues, si
is clear and proven thai undei certain
conditions, radio waves can burnyou.

The goad news is that the FCC and in-
ternational health organizations such
as the World Health Organization
(WHO) report there is little to no evi-
dence that the devices we use daily that
employ electromagnetic fields (EMF)
energy, such as microwave ovens and
cell phones, pose a major threat, The
bad news is, thai is not ihe case for
the higher RF-energy waves at or near
broadcast sites.

According to the FCC. "Biological effects
can result from exposure to Rf energy.
Biological effects that result from heal-
ing of tissue by RF energy are often re
forced to as "thermal" effects. It has been
known for many years that exposure to
very high levels of RF radiation can be
harmful due to the ability of RF energy
to heat biological tissue rapidly, This is
ihe principle by which microwave ovens
cook food. Exposure to very high RF
intensities can result in heating of bi-
ological tissue and an increase m body
temperature. Tissue damage in humans
could occur during exposure to high RF
levels because of the body's inability to
co pe with or dissipate the excessive heal
that could be generated. Two- areas of the
body, the eyes and the testes, are partic-
ularly vulnerable to RF heating because
of the relative Jack of available blood
flow 10 dissipate the excess heal load,"
(For more on the subject, see https://
www.fce.govyersgifH'emig-teehnology
/electromagnetic-compatibility division
/radio-frequency-safety/faq/rf-safety

AM radio tower also a danger

Another case was reported by Daniel
Mayer, owner of Mayer Tree Service, Inc.,
a 28-year TCIA member company based
in Essex, Mass,, that occurred whale
worsting on the picturesque and historic
campus of Endicott College in nearby
Salem. Mass.

"It's the same thing," he begins. "We did
not know we were working near the col-
lege's campus radio tower. 1 was feeling
energy in the crane ball and we were get-
ting anting on the machine, so we folded
(he crane and called an Inspector." Mayer
says one's first instinct is to suspect elet
trical problems with the machine, but in-
vestigators soon found the situation was

precipitated by the campus radio lower
during broadcasting. To draw an anal-
ogy. Mayer notes, "it's very much like the
effect on the rigging of a sailboat arcing
during an electrical storm."

Mayer recounted the Incident to Jay
Sturm, president of and a crane'safety
specialist with Cratlesitn, a training
company and nine-year TCIA Cor-
porate Member company based in
Bellingham, Mass., and subsequently
forwarded a copy of a video recording
of ihe incident to Sturm for analysis
That helped determine that the prob-
lem was. indeed, radio frequency re-
lated and not equipment. Sturm says
this is a growing concern among crane
Operators in all fields.

A new threat

-Jnieresiing timing," says Timothy
Walsh, director of corporate safety at
The Davey Tree Expert Company, when
asked about this topic. "People are )ust
becoming aware of this situation."

Walsh says Davey Tree, an accredited, 48-
year TCIA member company headquar
tered in Kent, Ohio, recently worked with
an expert on the subject, who explained
the hazards and how to identify these so-
called small-cell 5C installations. "Right
now. as an industry, we jusi do not yet un-
derstand the risk. So we also do not know
of any formal processes that exist" to deal

with the situation when it arises. Walsh
says.

He adds tliat Davey Tree is in the pro-
cess of developing operational proto-
cols, but emphasizes. "This is all so new.
it seems everyone got all excited about
the new sG system and forgot about ad-
dressing the potential hazards.

"We are formalizing a plan, and we do
have safety alerts and tailgate meetings
about the subject," Walsh says, caution-
ing. "There is conflicting information,
but we want to understand the hazards
and make our people aware of them.

"We have not yet had an incident,"
Walsh continues, noting the company
does tree work for commercial and
residential properties, with a separate
group working around power and com -
municattons lines where, he states,
"there is more potential for exposure."

If we do not know exactly what radio-
frequency waves can do to a tree care
crew working in proximity to such an
Installation, what can bedone lo remain
safe?

Says HaehneL "We talk to our teams
about what happened and instruct our
sales team as to what to look for," he say s,
referring to towers and small-cell-site in
stallations, He says aerial neighborhood
views (Including sources such as Google)

The caution sign on the lower-
right side of the pole shown here
warns of the dangers of small-cell
sites. Photo courtesy of Tree Tech.


-------
can be very helpful in identifying towers,
a ad the sC- small si tes are easily spotted
"on utility poles in front of homes along
the street, They look like a metal can at-
tached to a pole." Haehnel notes.

"Actually, when working near an AM-
radio broadcast site, we can contact the
FCC. which can get the broadcast power
turned down while we are working,"
Haehnel says.

He maintains thai all such sites have
contact information tags on them that
identify the owner. Usually it requires
24 to 43 hours lead time to shut off the
power to that site, he explains, adding
that, "There should be no service inter-
ruption to sG users, since the carrier can
switch temporally to another cell site."

Gerry Breton, CTSF, safety and training
director for Lucas Tree Expert Company.
Inc., a dual-accredited, 41-year TC1A
member company headquartered in Fal-
mouth. Maine, says. "The Industry as just
getting familiar with RF challenges. The
issue is popping up in New England, but
is not prevalent yet during this stage of
the switch to gG."

He's attended several briefings on the
subject, which review FCC and OSHA
updates. Breton says there are some
things to become aware ot some
quite unanticipated - especially when
working around these new sG installa-
tions. He notes that in addition to being
marked with the name of the owner/ser-
vice provider, each site (usually a utility
pole) wilt have numerous warning no-
tices about working in and around the

antennas, indicating safe positioning
and proximity for that antenna type and
other safety information-

Breton reports the situation is so im-
portant that. "We reviewed with our
supervisors what these installations are;
what they look like and where they are
located at the top of utility-distribution
poles. Mow when we're out planning
our jobs, we pay close attention to how
close vegetation is to the antennas.

"If our work plan indicates we will be
working near this small-cell site, we
know we must reach out to the cell pro-
vider," he continues. Breton suggests
copying one of his techniques, which is
to contact a few providers long before
any jobs are planned to understand the
processes needed to shut down a cell
site if work is needed at that site.

Breton acknowledges that RF expo-
sure is snore a potential hazard for line
workers and line-clearance contractors,
but "even tree care crews working in
and around small-cell areas wilt need a
hazard-assessmem protocol. When you
hive a tree crew working at the roadside
and they may be trimming around a
small-cell site, it is important to scope it
out," he says. "If you're outside the dan-
ger zone, no action is required." If there
is potential danger, Breton says, "work
ers are to notify their supervisor who,
m turn, is to notify the carrier to shut
down the site.

"It is important to note that there is no
cost to shut down a site." he stresses.

In an aside that many may not con
sider. Breton warns of some unfore-
seen dangers, One risk ts during a
storm response when you are provid-
ing vegetation clearing. You need to
know if those units, whether they are
still standing or are on the ground, are
disconnected either by the storm or
by the utility "The sites are powered
by tao volts." Breton reports, adding
that even if regular poweT is out in a
neighborhood, some sites have their
own emergency backup and the cell
antenna may still be capable of broad
casting, meaning it can be live with
electric power.

So, one thing we know is that not all
radio waves are benign, and it takes
knowledge to recognize potential risks.
Another thing is that there is a lot of
information available online, not only
are there resources such as seminars
on the subject, but also there is a net-
work of tree care safety professionals
open to sharing information, and that
includes with those who may be the
competition

To view a wiifeo dtmtintlrrttmg tht racfio-
(requencyrelated arcing rfiscussed here, go to
tcimagJcio.org and. under zh< Resources tafe.
click videos' Or; under the Ctrm-rii Issuir Jufe
click t'wuii Digimsg, rfuvi go la this page and
click here.

Did iซ>u Itie rhis ar
(kit or find if useful*

Scon the Qfi cade to
provide you r feed-
back or, in the digital
version of this issue.

-ciicSr /sere


-------
#^osr%

9 A Vo

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON. D C. 20460

Office of

Enforcement and
Compliance Assu ra n ce

Re: Property Management Companies

Dear Madam or Sir,

This letter is intended to notify you of an action by the U.S. Environmental Protection Agency
(EPA) that discusses the compliance responsibilities of certain property management companies
(PMCs) under the Toxic Substances Control Act (TSCA) lead-based paint Renovation. Repair
and Painting Rule (RRP Rule).

If you are affiliated with an organization that includes PMCs that may be affected, then we
encourage you to share this information with your members or associates.

WHAT ACTION WAS TAKEN?

On March 21, 2022, EPA withdrew two Frequently Asked Questions (FAQs) that addressed
PMC compliance responsibilities under the RRP Rule: FAQ #23002-13650 and # 23002-18348.
As of that date, the two FAQs are no longer in effect, and therefore PMCs cannot rely on
them as EPA's views about PMC compliance responsibilities under the RRP Rule. In other
words, with the withdrawal of these two F AQs, EP A will be assessing compliance by PMCs with
the RRP Rule as it would for any other entity. The withdrawal of the F AQs does not change the
RRP Rule, including its definition of "renovation."

EPA first published notice of the Agency's intent to withdraw the two FAQs on November 4,
2021. Among other things, the notice explains that:

"Consistent with the RRP rule, any individual or entity (including PMCs) is subject to the
RRP rule requirements when they perform or offer to perform renovation, repair or
painting activities for compensation in housing and child-occupied facilities built before
1978, and therefore must be a certified firm "

In the November 4 notice, EPA requested public comment on the planned action. EPA received
and considered public comments regarding the planned action. Additionally, in November and
December 2021, EPA widely distributed information about the November 4 notice to trade
associations, community and non-profit organizations and others that might be affected by or
interested in the planned action.


-------
On January 11, 2022, EPA affirmed that the Agency would withdraw the two FAQs, effective
March 21, 2022. EPA made this information available through an official announcement and

press release.

WHO DOES THF ACTION AFFECT?

EPA's action affects PMCs that perform, offer to perform, or claim to perform renovations for
pre-1978 residential housing and child-occupied facilities.

WHAT MUST AN AFFECTED PARTY DO TO COMPLY WITH THF RRP RULE?

PMCs subject to the RRP Rule must possess RRP certification from EPA (or from an authorized
state or tribe), among other compliance requirements under the RRP Rule. Those requirements
include ensuring that renovations comply with lead-safe work practices, and that a certified
renovator is assigned to each covered renovation and properly discharges the duties specifically
assigned to certified renovators by the rule. Also, all PMCs subject to the RRP Rule need to
ensure that they, their employees and any outside renovation contractors they engage comply
with RRP Rule requirements. Finally, a PMC that works in an authorized state/tribal area should
confirm with the relevant authorities whether the state/tribal program requires additional action.

A PMC that is subject to the RRP Rule but has not yet obtained certification from EPA (or from
an authorized state/tribe) should promptly apply to obtain certification. (Merely applying for
certification does not prevent potential enforcement for violations.)

ARE THERE POTENTIAL PENALTIES FOR NON-COMPLIANCE WITH THF RRP
RULE?

Yes. Failure to comply with the RRP Rule may result in enforcement and potentially significant
civil penalties. See 15 U.S.C. ง 2615.

Highlights of recent RRP enforcement actions are available online.

WHERE CAN YOU FIND MORE INFORMATION?

Information about RRP Rule requirements is available online.

If you have questions about this letter or the regulatory requirements, then please contact James
Miles at miles.j ames@epa.gov.

Sincerely,

MANUEL	Diqitally signed by MANUEL

CaAn7 r\i-,na Digitally signed by Saenz, Diana	RONQUILLO

JCICI \ ฃ.f L/lCll I CI Date: 2022.04.14 15:13:03 -04W	RONQUILLO	Date: 2022.04.14 15:41:48 -04W

Greg Sullivan	Manuel Ronquillo

Director	Acting Deputy Director

Waste and Chemical Enforcement Division	Federal Facilities Enforcement Office

Office of Civil Enforcement


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10/2/2018

Electromagnetic Fields Linked to Asthma in Kids

MD

Electromagnetic Fields Linked to Asthma
in Kids

Study: Mom's Exposure During Pregnancy Raises Kids' Asthma Risk
By Brenda Goodman, MA

FROM THE WEBMD ARCHIVES

Aug. 1, 2011 - Researchers seeking to explain the rising number of asthma cases in
children have fingered a new suspect: electromagnetic fields (EMFs), energy that can't
been seen or felt that is generated by household appliances, electronic devices, cars, and
power lines.

In a study, they found that babies born to women who are exposed to stronger EMFs
during pregnancy had more than triple the risk of developing asthma compared to babies
born to women exposed to weaker EMFs.

In other words, about 13% of children born to women in the group with the lowest EMF
exposures developed asthma compared to about 33% of children born to women who had
high EMF exposures.

"That's a striking figure," says David Savitz, PhD, a professor of community health and
obstetrics and gynecology at Brown University in Providence, R.I. "That magnitude of
association we don't see very often. If it was correct, and that's a big 'if,' that would be
really startling."

Savitz, who has studied the health effects of electromagnetic fields but was not involved in
the research, says that while the finding is interesting, there's no reason to give up using a
hair dryer or microwave just yet.

He says that unlike contaminants like cigarette smoke or lead that are known to be
dangerous, there's little evidence that low-frequency EMFs, the kind measured in the
study, are harmful.

"This has been very, very thoroughly studied, and it really is questionable whether it
causes any health effects at any reasonable level," Savitz tells WebMD. "It's certainly not
something that falls into the category of a known hazard."

But Savitz and others acknowledge that all research has to start somewhere.

"There are a lot of important topics that started out looking pretty flaky and pretty unlikely.
There was a time when it made no sense that smoking could be bad for you," he says.

Other experts agree.

https://vvvvvv.vvebmd.com asthma news 20110801 electromagnetic-fields-linked-asthma-kids?print=true

1/3


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10/2/2018	Electromagnetic Fields Linked to Asthma in Kids

"The study appears to be well executed and the finding is surprising," says Jonathan M.
Samet, MD, a pulmonologist and epidemiologist at the Keck School of Medicine at the
University of Southern California in Los Angeles.

Samet recently led a World Health Organization panel that concluded that EMFs from cell
phones and other wireless devices could possibly cause cancer.

The current study didn't account for EMFs from cell phones or wireless networks, which
emit higher-energy frequencies than were measured in the study.

Samet says that based on what we know about the development of asthma, it's hard to
understand how EMFs might play a role. Repeating the study, he says, will be an
important next step.

Previous studies have shown that EMFs may adversely affect the immune system.

Linking EMFs to Asthma in Kids

Researchers asked pregnant women who were members of the Kaiser Permanente
Northern California health plan to wear magnetic field sensors around their waists for 24
hours.

The sensors took readings every 10 seconds, recording magnetic field levels of everything
the women came into contact with during the day.

The sensors measured low frequency magnetic fields, which are generated by things like
refrigerators, vacuum cleaners, hair dryers, cars, power lines, stoves, microwaves,
computers, nearly anything that can be plugged in or runs on a motor.

They did not measure magnetic fields generated by cell phones or wireless networks,
which operate at higher frequencies.

The sensors generated a total of 8,640 readings for each mother and baby.

Researchers then ranked those readings from the highest to lowest and picked out the
middle number as a way to judge exposure.

Researchers don't know why some women had higher exposures while others had lower
exposures, but Savitz says roughly 10% to 20% of households in the U.S. would meet the
criteria for high EMF exposures used in the study.

Researchers then followed the women and their children for up to 13 years.

Children were considered to have asthma if a doctor diagnosed them with the condition
twice in the same year.

Compared to children of mothers in the low magnetic field group, who developed asthma
at rates that were roughly comparable to the national average, those in the high group had
a 350% increased risk of getting the condition, while those in the medium group had a
74% increased risk.

The association remained even after researchers adjusted their data for things that might
independently influence the development of asthma in kids, like age, sex, early birth, low

https://www.webmd.com/asthma/news/20110801/electromagnetic-fields-linked-asthma-kids?print=true

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10/2/2018	Electromagnetic Fields Linked to Asthma in Kids

birth weight, breastfeeding, and a family history of the condition.

Researchers say women who are worried about EMFs can do simple things to lower their
exposure.

"The problem with EMF is that you can't see, smell it, you can't touch it," says study
researcher De-Kun Li, MD, PhD, a reproductive and perinatal epidemiologist at the Kaiser
Permanente Division of Research in Oakland, Calif. "But you can avoid those sources that
we know about."

"The great thing about EMF is that distance really helps," Li says. For example, "When you
turn the microwave on, don't stand right next to it. Try to, when you use a hair dryer, try to
use it far away from your tummy as much as you can."

In the case of can openers, opting for a hand crank device, rather than an electric one, can
lower EMF exposure.

In the case of vacuum cleaners, the study may be a good excuse to hand off the job to
your partner.

The study is published in the Archives of Pediatric and Adolescent Medicine.

WebMD Health News | Reviewed by Laura J. Martin, MD on August 01,2011

Sources ^

SOURCES:

Li, D. Archives of Pediatric and Adolescent Medicine, Aug. 1,2011.

News release, Archives of Pediatric and Adolescent Medicine.

De-Kun Li, MD, PhD, reproductive and perinatal epidemiologist, Kaiser Permanente Division of Research, Oakland, Calif.

David Savitz, PhD, professor of community health and obstetrics and gynecology, Brown University, Providence, R.I.

Jonathan M. Samet, MD, pulmonologist and epidemiologist, Keck School of Medicine, University of Southern California, Los Angeles.

ฉ 2011 WebMD, LLC. All rights reserved.

https://www.webmd.com/asthma/news/20110801/electromagnetic-fields-linked-asthma-kids?print=true

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DE GRUYTER

Rev Environ Health 2021; aop

Review Article

B. Blake Levitt*, Henry C. Lai and Albert M. Manville II

Effects of non-ionizing electromagnetic fields on
flora and fauna, Part 2 impacts: how species
interact with natural and man-made EMF

https://doi.org/10.1515/reveh-2021-0050
Received April 20, 2021; accepted May 26, 2021;
published online July 8, 2021

Abstract: Ambient levels of nonionizing electromagnetic
fields (EMF) have risen sharply in the last five decades to
become a ubiquitous, continuous, biologically active envi-
ronmental pollutant, even in rural and remote areas. Many
species of flora and fauna, because of unique physiologies
and habitats, are sensitive to exogenous EMF in ways that
surpass human reactivity. This can lead to complex endog-
enous reactions that are highly variable, largely unseen, and
a possible contributing factor in species extinctions, some-
times localized. Non-human magnetoreception mechanisms
are explored. Numerous studies across all frequencies and
taxa indicate that current low-level anthropogenic EMF can
have myriad adverse and synergistic effects, including on
orientation and migration, food finding, reproduction,
mating, nest and den building, territorial maintenance and
defense, and on vitality, longevity and survivorship itself.
Effects have been observed in mammals such as bats, cer-
vids, cetaceans, and pinnipeds among others, and on birds,
insects, amphibians, reptiles, microbes and many species of
flora. Cyto- and geno-toxic effects have long been observed
in laboratory research on animal models that can be
extrapolated to wildlife. Unusual multi-system mechanisms
can come into play with non-human species — including in
aquatic environments — that rely on the Earth's natural
geomagnetic fields for critical life-sustaining information.
Part 2 of this 3-part series includes four online supplement
tables of effects seen in animals from both ELF and RFR at

Corresponding author: B. Blake Levitt, P.O. Box 2014, New Preston,
CT, 06777, USA, E-mail: blakelevitt2@gmail.com and
blakelevit@cs.com

HenryC. Lai, Department of Bioengineering, University of Washington,
Seattle, WA, USA, E-mail: hlai@uw.edu

Albert M. Manville II, Advanced Academic Programs, Krieger School
of Arts and Sciences, Environmental Sciences and Policy, Johns
Hopkins University, Washington DC Campus, USA,

E-mail: amanvill@jhu.edu

vanishingly low intensities. Taken as a whole, this indicates
enough information to raise concerns about ambient expo-
sures to nonionizing radiation at ecosystem levels. Wildlife
loss is often unseen and undocumented until tipping points
are reached. It is time to recognize ambient EMF as a novel
form of pollution and develop rules at regulatory agencies
that designate air as 'habitat' so EMF can be regulated like
other pollutants. Long-term chronic low-level EMF exposure
standards, which do not now exist, should be set accordingly
for wildlife, and environmental laws should be strictly
enforced — a subject explored in Part 3.

Keywords: cell phone towers/masts/base stations; Earth's
geomagnetic fields; magnetoreception, radiofrequency
radiation (RFR); nonionizing electromagnetic fields (EMF);
plants; wildlife.

Introduction: electromagnetic
fields — natural and man-made

In Part 1 of this three-part series, rising ambient EMF levels
were explored. Part 2 focuses specifically on the unique
magnetoreception physiologies found in wildlife as well as
the mechanisms by which they interact with the Earth's
natural geomagnetic fields and man-made EMF at in-
tensities now commonly found in the environment. Part 2
Supplements contain tables of studies showing effects at
extremely low intensity exposures comparable to today's
ambient levels.

Energy is a part of nature affecting every living thing in
positive, negative and neutral ways. The Earth itself is a
dipole magnet with a north and a south pole. All living
things have evolved within the protective cradle of the
Earth's natural geomagnetic fields. In fact, magnetic os-
cillations emanate from the Earth's molten iron core
around 10 times per second (10 Hz) where relaxed but alert
human thought/brainwaves occur between 8 and 14 Hz.

In addition to the Earth's natural emanations, vast
Schumann Resonances (SR) that constantly circle the globe


-------
2 = Levitt et al.: EMF and wildlife

DE GRUYTER

were theorized in 1952 by physicist Windfried Otto Schu-
mann and reliably measured in the 1960s [1, 2J. SR are a
global electromagnetic phenomenon caused by a complex
relationship between lightening at the Earth's surface and
the ionosphere. Excited by the 2,000 thunderstorms that
occur globally at any given time and approximately 50
flashes of lightening every second, the space between
Earth and the ionosphere 60 miles (97 km) above it form a
resonant cavity and closed waveguide [3|. Schumann
Resonances occur in the ELF bands between 3 and 60 Hz
with distinct fundamental peaks around 7.83 Hz. Since the
1960s, scientists have discovered that variations in the
resonances correspond to seasonal changes in solar ac-
tivity, the Earth's magnetic environment, in atmospheric
water aerosols and various other earth-bound phenomena,
including increased weather activity due to climate
change. There are an estimated 1.2 billion lightening
flashes globally each year, 25 million in the U.S. alone [4],
not all of which are of sufficient length to contribute to the
resonances.

Many behavioral aspects in biology are thought to be
synchronized with both the Earth's natural fields and the
Schumann Resonances. Many species rely on the Earth's
natural fields for daily movement, seasonal migration,
reproduction, food-finding, and territorial location, as well
as diurnal and nocturnal activities. Human circadian
rhythms, mainly regulated by light targeting signaling

pathways in the hypothalamic suprachiasmatic nucleus,
are known to be finely tuned to the Earth's day/night cycles
as well as natural seasonal variations, as are most species
[5-8]. Artificial ELF-EMF is also known to adversely affect
human circadian clocks, possibly through modulation in
circadian clock gene expression itself [9].

Nonionizing electromagnetic fields (EMF; 0-300 GHz)
include all the frequencies that fall between visible light
below the ultraviolet range and the Earth's natural static
fields. The nonionizing bands are used in virtually everything
involved with communications and energy propagation so
useful in modern life, including electric power production/
distribution, all wireless technologies and accompanying
infrastructure for cell phones, WiFi, baby/home monitoring
systems, 'smart'grid/meters, all 'smart' technology/devices,
2-through-5G Internet of Things, AM/FM broadcast radio and
television, shortwave and HAM radio, surveillance/security
systems, satellites, radar, many military applications,
and myriad medical diagnostic tools like MRI's, to name
but a few (see Figure 1).

In its natural state, very little radiofrequency radiation
(RFR) reaches the Earth's surface. Aside from the Earth's
natural extremely low frequency (ELF) direct current (DC)
magnetic fields, lightening and sunlight would primarily
comprise our normal exposures to the electromagnetic
spectrum. Most harmful radiation coming from outer space is
blocked by the Earth's magnetosphere. But now, for the first

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The electromagnetic spectrum is divided into ionizing and nonionizing radiation. Ionizing radiation falls at and above the ultra violet range in
the light frequencies. Examples of ionizing radiation include gamma rays, cosmic rays, X-rays and various military and civilian nuclear
activities. It is the nonionzing bands that we have completely filled in with modern technology.


-------
DE GRUYTER

Levitt et al.: EMF and wildlife — 3

time in evolutionary history, we have infused the Earth's
surface with a blanket of artificial energy exposures with no
clear understanding of what the consequences may be.

And although "natural," not all energy is alike. Man-
made exposures contain propagation characteristics — such
as alternating current, modulation, complex signaling char-
acteristics (e.g., pulsed, digital, and phased array), unusual
wave forms (e.g., square and sawtooth shapes), and at
heightened power intensities at the Earth's surface that sim-
ply do not exist in nature. These are all man-made artifacts. In
our embrace of technology, we have completely altered the
Earth's electromagnetic signature in which all life has
evolved, in essence bypassing the magnetosphere's protec-
tion. And because so much of wireless technology is satellite
based, increasing exposures are no longer just ground-
generated. All atmospheric levels are now affected by
increasing ambient exposures (see Part 1 and Part 1 Supple-
ment). This is especially true in the lower atmosphere, which
is 'habitat' (beyond mere oxygen and clean air standards) for
all species that mate, migrate, and feed in the air — including
birds, mammals (such as bats), insects and some arachnids.

Species extinctions

There has been an unprecedented rate of biodiversity
decline in recent decades according to the International
Union for Conservation of Nature [10] which maintains a
"Red List of Threatened Species" that is considered the
world's most comprehensive source on the global conser-
vation status of animal, fungi and plant species — all
critical indicators of planetary health.

IUCN's 2018 list showed that 26,000 species are threat-
ened with extinction, which reflected more than 27% of all
species assessed. This was greatly increased from their 2004
report that found at least 15 species had already gone extinct
between 1984 and 2004, and another 12 survived only in
captivity. Current extinction rates are now at least 100 to 1,000
times higher than natural rates found in the fossil record.

The more recent May 2019 report by the Intergovern-
mental Science and Policy Platform on Biodiversity and
Ecosystem Services, Paris, France [11] projected that at least 1
million plant and animal species worldwide are at imminent
threat of extinction if our current human actions and activities
are not immediately reversed. A review of 73 reports by
Sanchez-Bayo and Wyckhuys [12] found those rates had
greatly accelerated. The authors noted that biodiversity of
insects in particular is threatened worldwide with dramatic
declines that could lead to a 40% extinction of insect species
over the next several decades. In terrestrial ecosystems they
found Lepidoptera, Hymenoptera, and Coleoptera (dung

beetles) were most affected, while in aquatic ecosystems
Odonata, Plecoptera, Trichoptera and Ephemeroptera have
already lost a considerable proportion of species. Affected
insect groups included niche specialist species, as well as
common and generalist species, many of which are critically
important for pollination, as well as seed, fruit, nut and honey
production, and natural pest control, among others of
immeasurable economic and ecological value.

Humans are the primary cause for most declines via
habitat destruction/degradation; over-exploitation for food,
pets, cattle and medicine; artificially introduced species;
pollution/contamination; pesticides; and disease. Climate
change is increasingly established as a serious threat, as well
as agricultural practices like monoculture crops for cattle
feed, biofuels, and timber. New pesticides and weed killers
introduced within the last 20 years, using neonicotinoids,
glyphosphate, and fipronil, are especially damaging since
they are long-lasting and capable of sterilizing soil of bene-
ficial microorganisms, including worms and grubs, which
can then extend to areas far beyond applications sites.

One example of multi-factorial damage includes the
iconic American Monarch butterfly (Danansplexippus) which
is found across America and Southern Canada and generally
geographically divided into eastern and western migratory
groups by the Rocky Mountains. That species has declined by
a full 99.4% in the west since the 1980s — 85% of that being
since 2017 [13,14]. According to the Center for Biological Di-
versity [15], the eastern monarch population has shrunk by
90% in the past two decades. Massive habitat loss, wildfires,
climate change, droughts, enhanced storm ferocity, and the
1990s introduction of Monsanto "Roundup Ready" crops
capable of surviving herbicides that kill other weeds —
including milkweed, which monarchs need for breeding and
as their sole food supply along their migratory routes — are
thought to be the primary culprits.

Here, we argue, environmental EMF should be added
to this list since many insects and other living species have
sensitive receptors for EMF, e.g., monarchs were found to
have light sensitive magnetoreceptors in their antennae
that serve as an inclination compass when daylight is
absent [16]. RFR is also known to alter the time period
needed for a butterfly to complete morphogenesis, plus
gastrulation and larval growth can be accelerated [17]. And
the devastating loss of pollinating insects like honey bees
and other wild pollinators may also be related to environ-
mental EMF (see "Insects" below.)

Anecdotally, many people recall when there were
significantly more insects and far more abundant wildlife.
Since about 1980, there has been a steady, almost imper-
ceptible, biodiversity diminishment among many species
globally [18-20]. In 2018, scientists estimated that the


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largest king penguin colony shrank by 88% in just 35 years
[21] due in major part to effects from climate change, while
according to the International Scientific Committee for
Tuna and Tuna-like Species in the North Pacific Ocean,
over 97% of bluefin tuna have disappeared from the
world's oceans, primarily due to industrial overfishing but
exacerbated by oil spills, contamination, and climate
change. Tree and cave-dwelling bats until recently were
common, including in the Eastern United States. Now with
the massive impacts from White-nosed Syndrome (a fatal
bat fungal disease), annual wind-turbine bat collision
mortality estimated at nearly 1 million per year in the U.S.
alone [22, 23], and pesticide use, few bats are seen. Bats
species are also sensitive to EMF. Impacts from EMF as now
seen in extensive reviews add only yet another troubling
variable for all wildlife [24-36].

Since all food webs are uniquely tied together, there are
negative cascading effects across all ecosystems. Birds that
eat insects are hard hit: 8-in-10 partridges have disappeared
from French farmlands while there has been a 50-80%
reduction in nightingales and turtledoves respectively in the
UK. Since 1980 the number of birds that typically inhabit
Europe's farmlands has shrunk by 55%, while in the last 17
years, French farmland-bird counts dropped by a full third.
Intensified agricultural practices are thought responsible,
with loss of insects being the largest contributor [12, 37]. In
the United States, of the 1,027 species of migratory birds
currently protected under the Migratory Bird Treaty Act of
1918, an estimated 40% are in decline based on breeding bird
surveys [38], Christmas Bird Counts [39], and other moni-
toring tools [22, 23]. This trend is comparable to what is
happening globally. What role EMF plays in these declines is
unclear but remains a disturbing possibility. Nor do we un-
derstand the limits of tolerance any given species has for
environmental disturbance — some show high flexibility
while others thrive only within the narrowest ranges.

One estimate of Earth's species finds that since 1970,
wild animal populations have been reduced on average by
60%. Popularly called the "sixth mass extinction" [40], the
term connotes the sixth time in the Earth's history that
large numbers of species have rapidly disappeared over a
relatively short period, this time due to human activity, not
asteroid strikes or volcanic activity. Though not officially
so-designated, many now refer to this most recent
geologic/ecosystem period as the "Anthropocene" — the
Age of Man [41-46].

Insect populations have been especially hard hit with
extinctions eight times faster than that of mammals, birds
and reptiles [12]. Insect total mass is falling by an estimated
2.5% per year, suggesting they could vanish by the next
century. And what affects insect populations affects

everything in the food web in one way or another. Loss of
insect diversity and abundance can cause devastating ef-
fects throughout food webs and endanger entire ecosys-
tems [12]. In Europe, Hallmann et al. [47] found a more than
75% decline over 27 years in total flying insect biomass in
63 protected areas, many throughout Germany. There was
an 82% decline in mid-summer flying insect mass. Many
European insect species migrate from distances as far away
as Africa. The researchers noted that changes in weather,
land use, and habitat characteristics alone cannot explain
the overall decline and that there may be more than one
unrecognized factor involved in evaluating declines in
overall species abundance. That unrecognized factor may
be the steadily rising ambient EMF that directly parallels
these declines (see Part 1, Supplement 1).

Similar alarming invertebrate declines were discovered
in the Western Hemisphere in 2017 when American ento-
mologist Bradford Lister, after 40 years, revisited the El
Yunque National Forest in Puerto Rico to follow up on a study
begun in 1976 [48]. In the ensuing decades, populations of
arthropods, including numerous flying insects, centipedes
and spiders, had fallen by 98% in El Yunque, a pristine
tropical rainforest within the U.S. National Forest System.
Insectivores — including birds, lizards, and toads — showed
similar declines, with some species vanishing entirely. After
controlling for factors like habitat degradation or loss and
pesticide use, the researchers concluded that climate change
was the primary factor since the average maximum temper-
ature in that rainforest had increased by 4 ฐF during that
period. They did not factor in the large U.S. military VLF
installation in Aquada that communicates with submarines
all over the world, or the multiple sweeping over-the-horizon
phased array radar units aimed at Puerto Rico from coastal
sites in the U.S. that irradiate deep into that forest, or the
multiple NOAA Doppler weather radar sites scattered all over
the small island to track hurricanes, or the many cell towers
there too.

These global declines are truly alarming with impli-
cations for planetary health as well as human and wildlife
integrity. Many who study this say that climate change
alone is not the only factor and that something new is going
on [47]. The question is: could steadily rising environ-
mental EMF, as one of the most ubiquitous but unrecog-
nized new environmental genotoxins introduced since the
1980s, be contributing to these unprecedented species
losses, beginning with insects but now manifesting in other
species too? The upper microwave bands couple maxi-
mally with some insects the size of fruit flies and are
capable of creating devastating resonance and other ef-
fects. Historically, radiofrequency radiation (RFR) impacts
to insects were among the first biological effects to be


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Levitt et al.: EMF and wildlife — 5

studied [49] with the hope of discovering new forms of
insect control [50]. All insect metamorphic developments
have been studied, including egg, larva, pupa, and adult
stages. One hypothesis holds that some adult species
are more sensitive than at larval stages because adult
appendages act as conducting pathways to the body
(see "Insects" below).

It is these exact frequency bands between 30 kHz and
3 GHz used in telecommunications technology that have
been on the rise during this period. And 5G is on the hori-
zon which may specifically target insect populations (see
Part 1).

Species sensitivity to EMFs

Other species have vastly more complex electromagnetic
sensing tools than humans, as well as unique physiologies
that evolved to sense weak fields. Many species are highly
sensitive to the Earth's natural electromagnetic fields, as well
as geographic and seasonal variations. In fact, it appears that
most living things — including many species of mammals,
birds, fish, and bacteria — are tuned to the Earth's electro-
magnetic background in ways once considered as "super-
powers" but are now known to be physiological, even as
mechanisms are still imperfectly understood. For example,
many animals have been observed sensing earthquakes long
before human instruments detect them, including snakes and
scorpions that seek shelter; cattle that stampede; birds that
sing at the wrong times of day; and female cats that frantically
move kittens [7].

This ability is likely due, in part, to numerous species
reacting to changes in the Earth's magnetic field and
electrostatic charges in the air detected through a naturally
occurring mineral called magnetite found in many species
[51, 52]. In fact, honey bees are able to detect static mag-
netic field fluctuations as weak as 26 nT against back-
ground earth-strength magnetic fields that are much higher
[53] and to sense weak alternating fields at frequencies of
10 and 60 Hz [54]. Magnetite reacts a million times more
strongly to external electromagnetic fields than any other
known magnetic material. Authors Kobayshi and Kirch-
vink [52] and Kirchvink et al. [53, 54] hypothesized results
were consistent with biophysical predictions of a
magnetite-based magnetoreceptor. Other mechanisms,
like radical pair mechanisms and cryptochromes, may also
be responsible (see "Mechanisms" below).

Much has been written about magnetoreception — the
term used to describe how species sense electromagnetic
fields — which is well established but not well understood.
Many species use information about the Earth's natural

fields for migration, mating, food-finding, homing, nest-
ing, and numerous other activities. Migratory bird species
[55,56], honeybees [57], fish [58], mammals [59], bats [60],
numerous insect species [61], mollusks [62], and even
bacteria [63] are known to sense Earth's magnetic fields in
various ways. Magnetoreception may enable some bird
species to actually see the Earth's fields [64].

Some insect and arachnid species (e.g., Trichobothria)
can detect natural atmospheric electric fields [65] which
trigger ballooning behavior — e.g., climbing to the highest
place, letting out silk, and traveling on wind currents using
hair-like Trichobothria that detects airborne vibrations,
currents, and electrical charge. Some have been found as
high as 2.5 mi (4 km) in the sky, dispersing over hundreds of
kilometers. Morley and Robert [65] found that the presence
of a weak natural vertical e-field elicited ballooning
behavior and takeoff in the spiders; their mechano-sensory
hairs function as putative sensory receivers which are
activated by natural weak electric-fields in response to
both e-field and air-flow stimuli. The researchers hypoth-
esized that atmospheric electricity was key to the mass
migration patterns of some arthropod fauna.

Even soil nematodes (Caenorhabditis elegans) orient to
earth-strength magnetic fields in their burrowing behav-
iors and a recent study by Vidal-Gadea [66] found thatweak
static fields slightly above Earth's natural fields determined
stem cell regeneration in flatworms (Planaria) [67].

Large ruminant mammalian species also orient to the
Earth's fields. Grazing cattle and deer were first observed
aligning to geomagnetic field lines by Begall et al. [68].
Using satellite imagery, field observations, and measuring
"deerbeds" in snow, they noted that domestic cattle across
the globe, as well as grazing and resting red (Cervus alphas)
and roe (Capreolus capreolus) deer, consistently align their
body axis in a general north-south direction and that roe
deer also orient their heads northward when grazing or
resting. Burda et al. [69] discovered, however, that man-
made ELF-EMF disrupted the north-south alignment with
the geomagnetic field in resting cattle and roe deer when
they found body orientation was random on pastures un-
der or near power lines, with the disturbed pattern dimin-
ishing with distance from conductors. Cattle exposed to
various magnetic field patterns directly beneath or near
power lines exhibited distinct patterns of alignment. They
concluded there was evidence for magnetic sensation in
large mammals, as well as overt behavioral reactions to
weak ELF-MF in vertebrates, implying cellular and mo-
lecular effects. Slaby et al. [70] also found cattle align along
a north-south axis but suggested that such alignment may
depend on herd density as the affect disappeared in herds
with higher numbers. Fedrowitz [71] expanded this to


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include bovine sensitivity to other weak ELF-EMF from
powerlines but with observed effects due to combined
electric and magnetic fields rather than the electric field
exposure alone (see "Bovines"below).

Cerveny et al. [72] found red fox (Vulpes vulpes) use
geomagnetic fields during hunting. Even domestic dogs
were found by Hart et al. [73] to be sensitive to small varia-
tions in the Earth's orientation in their excretion habits,
preferring a general north-south axis for both defecation and
urination depending on geomagnetic field changes. And
Niefiner et al. [74] found dogs and some other species may
actually "see" geomagnetic fields through blue-light sensing
photoreceptor proteins in their eyes called cryptochromes.

According to the US/UK World Magnetic Model [75],
sensitivity to the geomagnetic field may further complicate
issues for migratory species (e.g., some turtles, sea ani-
mals, birds, and insects) because the Earth's magnetic
north pole is shifting faster than at any time in human
history. Compared to the period between 1900 and 1980, it
has greatly accelerated to about 30 mi (50 km) distance per
year — moving west from over Canada's Ellesmere Island,
its traditional allocation for most of recorded history —
toward Russia [76]. Magnetic north fluctuates according to
changes in the Earth's molten core, unlike true north which
aligns according to the Earth's axis. This trend may indi-
cate a coming pole reversal with north and south trading
places, something that occurs approximately every
400,000 years with the last being about 780,000 years ago.
Some animals may be capable of recalibrating navigational
cues but that remains to be seen. Since some migratory bird
species may see geomagnetic fields through special re-
ceptor cells in their eyes and via other mechanisms, they
could be thrown off course. It is unclear how many other
species also see geomagnetic fields but some crustaceans
and several insect species, especially those with compound
eye structures consisting of thousands of ommatidia — tiny
independent photoreception units with a cornea, lens, and
photoreceptor cells that orient in different directions and
distinguish brightness and many more bands of color than
humans — are good candidates. Compared to single-
aperture eyes, compound eyes have a very large view angle
that can detect fast movement and in some cases light
polarization.

In aquatic environments, some lakes have more than
200 species of fish that use some form of electromagnetism
to locate food and reproduce. Electric eels can deliver a
500-V zap to kill prey. Sharks have an array of electro-
magnetic sensors. These include: magnetic field receptors
in their mouths, eyes that are 10 times more sensitive than
humans, and their perception of tiny electric neuronal
discharges from the moving muscles in prey (including

humans) guides their attacking/feeding behavior (see
"Fish"below). Sharks are often attracted by low-level
electromagnetic fields surrounding underwater electric
cables and are sometimes electrocuted when they mistake
the conduit for living prey and bite into it. Many fish have
lateral lines on either side of their bodies that are composed
of magnetite, which allows fish to swim in synchronous
schools [52].

Many other animals evolved special receptor organs to
detect environmental EMF. The duck-billed platypus
(Ornithorhynchus anatinus), a semi-aquatic primitive egg-
laying mammal, has thousands of electric sensors on its
bill skin. As noted in Lai [77], using these electroreceptors
and interacting with another type of mechanoreceptor, a
platypus can detect an electric field of 20 (iV/cm [78] —
equivalent to that produced by the muscles of a shrimp.
The information is processed by the somatosensory cortex
of the platypus to fix the location of prey. This type of
electroreception is common in the three species of mono-
tremes: platypus, and long (Zaglossus bruijni) and short-
bill (Tachyglossus aculeatus) echidna. Electric fish (elas-
mobranchs) emit EMF that covers a distance of several
centimeters [79, 80]. This allows location of potential prey
by comparing its electrical properties with that in its im-
mediate vicinity. Their electroreceptors have been shown
to detect a field of 5 nV/cm. Such EMF-sensing systems are
highly sensitive and efficient but also highly vulnerable to
disruption by unnatural fields. Organisms that use the
geomagnetic field for migration have the capability not
only to detect the field but also the orientation of the field.

Anthropogenic light frequencies affect wildlife in ways
we have only recently grasped. Ecological studies have
found that artificial light-at-night is disrupting nocturnal
animals in devastating ways, including disorientation and
disruption in breeding and migration cycles in turtles,
flying insects, birds, butterflies and a host of other wildlife
including mammals [81-84]. As much as 30% of nocturnal
vertebrates and over 60% of invertebrates may be affected
by artificial light [85]. Illumination reflected off of clouds
known as "sky glow" can produce unnaturally bright
conditions at night from various wavelength spectra that
impact different species, with the potential to alter the
balance of species interactions [86, 87]. It has been found
that changing the color of the light can help some species
yet harm another [88]. For instance, low-pressure sodium
lights that have more yellow in their spectrum reduce moth
deaths around the bulbs, but salamanders cannot navigate
from one pond to the next under yellow or red light. Some
frogs have been observed to freeze for hours, even after
lights have been turned off, and to suspend both feeding
and reproduction [83].


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Levitt et al.: EMF and wildlife — 7

One of nature's great mysteries involves "natal homing
behavior" — the ability of some animal species to return to
their original location of birth in order to reproduce,
sometimes over great distances. Natal homing behavior
is known in sea turtles [89]; eels [90]; and salmon [91],
among other species. The underlying mechanism, though
imperfectly understood, involves such species "remem-
bering" the geomagnetic field configurations of their
birthplace via a process known as "imprinting," and thus
can locate and return to it even if they are thousands of
miles/kilometers away at reproduction time. Apparently,
newborns of these species are imprinted with the memory
of the intensity and the inclination angle of the local
geomagnetic field. This information is then later used to
locate their place of birth where they return to breed.

The question is whether man-made EMF could distort
this imprinting memory in later locating the site. For example,
what if RFR-emitting facilities are located near turtle breeding
sites? Could that interfere with imprinting? There is some
evidence from Landler et al. [92] of adverse effects in turtles.
The researchers found that RFR could disrupt a natural
orientation, establish its own orientation, and reverse
completely a natural orientation, indicating a need for
research to further investigate as we simply do not know the
full effects to other species from anthropogenic EMF.

Energy conduction in different
species: unique physiologies and
morphologies

The unique physiology and morphology of non-human
species create additional complexities. For instance,
quadrapedal species with four feet on the ground have
different and potentially more efficient conductivity than
bipedal species with two feet. One example is bovine
heightened sensitivity to increased ground current near
high tension lines [93, 94] and cell towers [95-97]. Also,
bodies that are predominately parallel to the ground,
which includes most four-legged mammals, rather than a
perpendicular upright gait, conduct EMF in different ways
than vertical species like humans, apes, and other pri-
mates. Species that hug the ground, like snakes, sala-
manders, and frogs, have unique exposures to ground
currents, especially on rainy nights when water, as a
conductive medium, can increase exposures [98]. This may
make some species more sensitive to artificial ground
current caused by electric utility companies using the Earth
as their neutral return back to the substation for excess

alternating current on their lines instead of running addi-
tional neutral lines on utility poles [99].

Hair and whiskers and related appendages in various
species are known to detect small variations in electro-
magnetic fields as well as water and weather alterations
[100]. In fact, ants have been observed to use their
antennae as "EMF antennas" when subjected by re-
searchers to external electromagnetic fields, aligning
themselves to "channel" RFR away from the colony [7].
Species such as birds, as well as some insects with com-
pound eyes structures, can see vastly more colors than
humans, while cats, dogs, and owls, for instance, hear
many more sound frequencies at incredibly low levels.

Magnetoreception mechanisms:
electroreceptor cells, magnetite,
cryptochromes/radical pairs

According to Lai [77], "...in order for an environmental
entity to affect the functions of an organism, the following
criteria have to be met: the organism should be able to
detect the entity; the level of the entity should be similar to
those in the normal ambient environment which is gener-
ally much lower than the level of the entity used in
experimental studies; and the organism must have
response mechanisms tuned to certain parameters of the
entity that allow immediate detection of the presence and
changes of the entity. Thus, a variation of the entity would
be detected as an aberrant input and trigger a response
reaction. In order to understand how man-made EMF af-
fects wildlife, the above criteria must be considered,
including multiple sensory mechanisms that vary from
species to species."

The questions are: How do diverse species detect weak
natural geomagnetic signals, distinguish the subtle inter-
nal microcurrent and magnetic fields inherent to all
biology from external fields, then get beyond both internal
and external background noise to make use of that elec-
tromagnetic information?

There are three primary mechanisms used to under-
stand magnetoreception:

(1)	Magnetic induction of weak electrical signals in
specialized sensory receptors [101].

(2)	Magnetomechanical interactions with localized de-
posits of single-domain magnetite crystals [52, 102,
103].

(3)	Radical-pair photoreceptors, which may be the most
plausible [104-111].


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In the induction model (mechanism 1), according to Lin
[102], the first category of electrodynamic interactions with
weak magnetic fields is epitomized by elasmobranchs,
including sharks, rays, and skates, with heads that contain
long jelly-filled canals with high electrical conductivity
known as the Ampullae of Lorenzini. As these fish swim
through the Earth's geomagnetic lines of flux, small
voltage gradients are induced in these canals with electric
field detections as low as 0.5 (iV/m [101] The polarity of the
induced field in relation to the geomagnetic field provides
directional cues for the fish. However, in birds, insects, and
land-based animals, such cells have not been found,
indicating this may not be a universal mechanism but
rather are environment/species-specific factors [111].

The magnetomechanical model (mechanism 2) in-
volves the naturally occurring iron-based crystalline min-
eral called magnetite found in most species [52]. Its
function is most simply demonstrated in magnetotactic
bacteria [63] with high iron content where biogenic
magnetite is manufactured in 20-30 single domain crystal
chains [112]. Orientation is patterned according to the
geomagnetic field. Blakemore et al. [113] found that mag-
netotactic bacteria in the northern hemisphere migrate
toward the north pole of the geomagnetic field whereas the
same strains migrate toward the South Pole in the southern
hemisphere. At the equator, they are nearly equally divided
in north- and- south seeking orientations [114]. And they all
migrate downward in response to the geomagnetic field's
vertical component, which, in aqueous environments may
be essential for their survival in bottom sediments.

Among the many species where magnetite has been
found include the cranium and neck muscles of pigeons
[115,116]; denticles of mollusks [117,118]; and the abdom-
inal area of bees [119]. Tenforde [103] delineated other
species with localized magnetite, including dolphins,
tuna, salmon, butterflies, turtles, mice, and humans.

The third mechanistic model (mechanism 3) getting
research attention today involves a complex free-radical-
pair reaction and conversion of the forms of electrons
(singlet-triplet inter-conversion) in a group of protein
compounds known as cryptochromes. Cryptochromes
have been found in the retinas of nocturnal migratory
songbirds by Heyers et al. [55] and Moller et al. [56],
showing complex communication with the brain for
orientation when relying on magnetoreception. Gegear
et al. [61] found cryptochromes to be a critical magneto-
reception component in fruit flies (Drosophila mela-
nogaster). As noted in Lai [77], cryptochrones are also
present in the retinas of some animals [120]. RFR [121] and
oscillating magnetic fields [122] have been reported to
disrupt the migratory compass orientation in migratory

birds. There are also reports that indicate the presence of
cryptochromes in plants, which may be responsible for the
effect of EMF on plant growth [123]. Cryptochromes are also
known to be involved with circadian rhythms [56,124]. For
an excellent review on plausibility, theories, and com-
plexities of cryptochrome/radical pairs, see Ritz et al. [111].

Many species likely use a combination of these
mechanisms as well as more subtle influences as yet un-
detected. The vector of the geomagnetic field may provide
the directional information, while intensity and/or incli-
nation provide the positional information needed for
orientation. In behavioral studies [125,126], Wiltschko et al.
found that birds used both magnetite and cryptochrome
mechanisms when they responded to a short, strong
magnetic pulse capable of changing magnetization of
magnetite particles, while their orientation was light-
dependent and easily disrupted by high-frequency mag-
netic fields in the MHz range indicating radical pair pro-
cesses. These findings suggest that along with
electrophysiological and histological studies, birds have a
radical pair mechanism located in the right eye that pro-
vides compass-like directional information while magne-
tite in the upper beak senses magnetic intensity, thus
providing positional information. However, Pakhomov
et al. [122] pointed out that the songbird magnetic compass
can be disrupted by an oscillating 1.403-MHz magnetic
field of 2-3 nT, at a level that cannot be explained by the
radical-pair mechanism.

Light plays a significant role [127], which is of envi-
ronmental concern today as more technology moves to-
ward using the infrared bands for communications and the
increase of satellites create artificial/unfamiliar star-like
lights in the night sky that are potentially capable of
impacting night migration patterns. There is other evi-
dence that species use a combination of photoreceptors
and magnetite-based magnetoreception. As mentioned
above, in birds the two mechanisms exist side by side,
mediating different types of magnetic information as
needed, such as flight on sunny vs. cloudy days or
nocturnal flights, and they can be easily disrupted [106,
128-130]. Birds may co-process visual information with
magnetic information and be able to distinguish between
the two [131,132]. This function likely occurs in the eye or
higher avian brain areas via light-dependent information
processing and radical pair cryptochromes [131,133]. Birds'
magnetic compass is an inclination compass and RFR
fields in the Larmor frequencies near 1.33 MHz were found
to disrupt birds' orientation in an extremely sensitive
resonance relationship. Blue-light absorbing photopig-
ment cryptochromes have been found in the retinas of
birds. RFR appears to directly interfere with the primary


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Levitt et al.: EMF and wildlife — 9

processes of magnetoreception and disable the avian
compass as long as the exposure is present [126,128].

Mammals have also demonstrated magnetoreception
indicating radical-pair mechanisms. Malkemper et al. [134]
found that the surface-dwelling wood mouse (Apodemus
sylvaticiis) built nests in the northern and southern sectors of
a visually symmetrical, circular arena, using the ambient
magnetic field, or in a field rotated by 90ฐ, indicating the
animals used magnetic cues. When the mice were also tested
in the ambient magnetic field with a superimposed radio
frequency magnetic field (100 nT, 0.9 to 5 MHz frequency
sweep), they changed preference from north-south to east-
west nest building. But unlike birds that have been found
sensitive to a constant Larmor frequency exposure at
1.33 MHz, that range had no effect on mice orientation. In-
dividual animal physiology clearly plays a role in how
various species respond. Malewski et al. [135] also found that
the Earth's magnetic field acts as a common directional in-
dicator in five species of subterranean digging rodents. And
for the first time, research also found that human brain
waves exhibit a strong response to ecologically-relevant ro-
tations of Earth-strength magnetic fields [136].

We need far better understanding of magneto-
reception's neural, cellular, and molecular processes
because the ultimate question is, given our constant rising
background levels of EMF, is this ambient noise reaching a
tipping point beyond which species simply cannot "hear?"
Are we artificially overwhelming living species' ability to
function with innate natural biological sensors that
evolved over eons in a far more "electro-silent" world? The
electroreception mechanisms described above — electro-
receptors, magnetite, and cryptochrone/radical-pairs —
enable living organisms to detect the presence and imme-
diate changes in environmental fields of very low intensity.
And thus they can be easily disturbed by the presence of
unfamiliar low-intensity man-made fields.

Electrohypersensitivity in humans has also shown
instantaneous response to EMF at low intensity [137]. Ac-
cording to Lai [77], one wonders whether the underlying
mechanisms of electrohypersensivity are similar to those
described above. Electrohypersensitivity may be a remnant
of the evolutionary responses of living organisms to elec-
tromagnetic fields — particularly magnetic fields — in the
environment. Similarities include responsiveness to very
low-field intensity; the response is persistent and built into
the physiology of an organism; and the response is imme-
diate and reacts quickly to the fields. Cryptochrome-free
radical mechanisms maybe involved. Some people are more
sensitive than others. Perhaps non-sensitive people can
tolerate and compensate for effects, and/or have lost
responsiveness to natural magnetic fields and thus have

become evolutionarily aberrant. Electrosensitivity is an issue
in need of more careful and systematic study and has yet to
be broadly highlighted as a health or public welfare concern.

One recent theory by Johnsen et al. [138] postulates that
magnetoreception in animal species may be "noisy" —
meaning that the magnetic signal is small compared to
thermal and other receptor noise, for instance. They specu-
late that magnetoreception may serve as a redundant "as-
needed" source of information, otherwise animal species
would use it as their primary source of information. Many
species, they note, preferentially exploit non-magnetic cues
first if they are available despite the fact that the Earth's
geomagnetic field is pervasive and ever-present. They
speculate that magnetic receptors may thus be unable to
instantaneously attain highly precise magnetic information,
and therefore more extensive time-averaging and/or other
higher-order neural processing of magnetic information is
required. This may render . .the magnetic sense inefficient
relative to alternative cues that can be detected faster and
with less effort." Magnetoreception may have been main-
tained, however, they said by natural selection because the
geomagnetic field may sometimes be the only available
source of directional and/or positional information.

We already know that some species use various
mechanisms to detect EMFs as noted throughout this pa-
per. With new environmental factors from anthropogenic
causes, such as artificial light-at-night, air/water pollution,
climate change impacting visibility as environmental cues,
and rising background RFR — all of which can obscure
natural information — magnetoreception may, in fact,
become more necessary as an evolutionary survival tool as
time goes on, not less.

Other mechanisms of biological
significance: DNA — direct and
indirect effects

(See Part 2, Supplements 1 and 2,
for tables of ELF and RFR genetics
studies)

A significant biological effect in any toxicology research
involves the basic genetics of an exposed organism. Ge-
netic effects consist mainly of gene expression, chromatin
conformational changes, and genotoxicity. All such effects
can influence normal physiological functions. Relevant to
this paper is the fact that genetic effects are found at EMF
levels similar to those in ambient environments, far below


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levels from communication devices and infrastructure (see
Part 1, Supplement 1).

DNA, the fundamental building block of all life, is a
molecular double helix that is coiled, twisted and folded
within the nucleus of each living cell. It is essentially
identical among species with variations only in number
and specific genes along chromosomes on DNA's twisted
chains that distinguish various species and their charac-
teristics from one another. DNA damage repeatedly seen in
one species can therefore be extrapolated to other species,
although not all species react the same to external stimuli.

Many factors, both endogenous and exogenous,
damage DNA which is then normally repaired by DNA
enzymes. But an absence of adequate repair can result in
the accumulation of damaged DNA, which will eventually
lead to aging, cell death (apotosis) and/or cancer. DNA
breaks occur as both single and double strand events;
double strand breaks are difficult to repair correctly and
can lead to mutations. DNA damage from endogenous
factors can include free radical formation from mitochon-
drial respiration and metabolism; exogenous factors
include chemicals, ionizing and nonionizing radiation,
and ultra violet light among others [139]

In several early studies, Lai and Singh [140,141] found
both double and single strand DNA breaks in the brain cells
of rats exposed to RFR for 2 h at 2,450 MHz, and whole body
SAR levels of 0.6 and 1.2 W/kg. The effects were interest-
ingly blocked by antioxidants [142] suggesting free radical
involvement, which could indicate an indirect cause for
DNA damage (see below). The low-intensity genetic effects
listed in Part 2 Supplements 1 and 2 are at 0.1 W/kg and
less. Therefore, the Lai and Singh [140,141] RFR studies are
not included in those Supplements. Very similar effects
have also been found by Lai and Singh [143, 144] with
60-Hz magnetic field exposure.

There has also been much study of ELF genetic effects.
As discussed in Phillips et al. [139], numerous studies
found that ELF-EMF leads to DNA damage [143-158]. Two
studies [159,160] showed that ELF also affects DNA repair
mechanisms. Sarimov et al. [161] found chromatin confor-
mational changes in human lymphocytes exposed to a
50-Hz magnetic field at 5-20 (iT. EMF-induced changes in
cellular free radicals are also well studied [77,162].

Others investigated DNA damage early on but without
the availability of today's more sensitive assays. Sarkar
et al. [163] exposed mice to 2,450-MHz microwaves at a
power density of 1 mW/cm2 for 2 h/day over 120,150, and
200 days. They found DNA rearrangement in the testis and
brain of exposed animals that suggested DNA strand
breakage. Phillips et al. [164] were the first to use the comet
assay to study two different forms of cell phone signals —

multi-frequency time division multiple access (TDMA) and
integrated digital enhanced network (iDEN) — on DNA
damage in Molt-4 human lymphoblastoid cells using
relatively low intensities of 2.4-26 W/g for 2-21 h. The
authors reported seeming conflicting increases and de-
creases in DNA damage, depending on the type of signal
studied, as well as the intensity and duration of exposure.
They speculated the fields could affect DNA repair mech-
anisms in cells, accounting for the conflicting results.

In a recent literature review of EMF genetic effects by
Lai [165], analysis found more research papers reporting
effects than no effects. For RFR, 224 studies (65%) showed
genetic effects while 122 publications (35%) found no ef-
fects. For ELF and static-EMF studies, 160 studies (77%)
found effects while in 43 studies (23%) no effects were seen.

Research now points to the duration, signaling charac-
teristics, and type of exposure as the determining factors in
potential damage [164,166], not the traditional demarcation
between ionizing and nonionzing radiation. Long-term, low-
level nonionizing radiation exposures common today are
thought to be as detrimental to living cells as are short-term,
high-intensity exposures from ionizing radiation. Effects
may just take longer to manifest [167]. Nonionizing EMF at
environmental levels does cause genetic damage. These
have also been shown in humans exposed to environmental
levels of EMF in both ELF and RFR ranges [168-171].
Conceivably, similar genetic effects could happen in other
species living in similar environments.

This body of genetics work goes against the pervasive
myth that low-level, low-intensity nonionizing radiation
cannot cause detrimental genetic effects. That premise is in
fact the bedrock belief upon which vested interests and
government agencies rely in support of current exposure
standards. But in fact, biological systems are far more
complex than physics models can ever predict [6, 8,172]. A
new biological model is needed because today's exposures
no longer fit that framework [173] for humans and wildlife.
Enough research now indicates a reassessment is needed,
perhaps including the very physics model used to back
those traditional approaches (see Part 1).

Direct mechanisms: DNA as fractal
antennas, cell membranes, ion
channels

DNA as fractal antennas

There are several likely mechanisms for DNA damage from
nonionizing radiation far below heating thresholds, both


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Levitt et al.: EMF and wildlife — 11

direct and indirect, intracellular, intercellular, and extra-
cellular. Such mechanisms potentially apply to all wildlife.
One direct mechanism theorizes that DNA itself acts as a
fractal antenna for EMF/RFR [174], capable of receiving
information from exogenous exposures.

According to Blank and Goodman [174], DNA has
interesting electrical characteristics due to its unique
structure of intertwined strands connected by rungs of
molecules called nucleotides (also called bases), with each
rung composed of two nucleotides (one from each strand)
in bonded pairs. The nucleotides are held together by
hydrogen bonds in close proximity that results in a strong
attraction between the two strands. There are electrons on
both molecular surfaces making the symmetrical nucleo-
tides capable of conducting electron current along the
entire DNA chain, a phenomenon called electron transfer.
This makes DNA a most efficient electrical conductor,
something not lost on nanotechnology researchers.

DNA may also act as an efficient fractal antenna due to
its tightly packed shape within the cell nucleus. Blank and
Goodman [174] characterized DNA properties in different
frequency ranges, and considered electronic conduction
within DNA's compact construction in the nucleus. They
concluded that the wide frequency range of observed in-
teractions seen with EMF is the functional characteristic of
a fractal antenna, and that DNA itself possesses the two
structural characteristics of fractal antennas — electronic
conduction and self symmetry. They noted that these
properties contribute to greater reactivity of DNA with EMF
in the environment, and that direct DNA damage could
account for cancer increases, as well as the many other
biological effects seen with EMF exposures.

A fractal is a self-repetitive pattern of sometimes geo-
metric shapes, marked by a larger originating design pro-
gressing to small identical designs with a potentially
unlimited periphery. Each part of the shape looks like the
whole shape. Fractal designs are quite common in nature,
e.g., in snail/mollusk shells, some deciduous tree leaves and
conifer needles, pine cones, many flowering plants, some
reptile scales, bird feathers and animal fur patterns, snow-
flakes, and crystals forming on cold winter glass windows.
Minerals — both inert and biological — can also be fractals.

The varying sizes within fractals are what make them
inherently multi-frequency. By mimicking nature, repeti-
tive fractal patterns are also designed into mechanical
transceiver antennas that radiate in multiband frequencies
with more or less efficiency [175]. Cell phones, WiFi, digital
TV, and many other transceivers use fractal antennas to
operate.

The complex twisted shape and coiled structure of
DNA — small coils coiled into larger coils, or coiled coils,

which Blank and Goodman [174] note that no matter how
far you zoom in or out, the shape looks the same — is the
exact structure of a fractal that maximizes the length of an
antenna within a compact space while boosting multi-
frequency signals. As such, DNA may be acting as a hidden
intracellular biological fractal capable of interacting with
exogenous EMF across a range of frequencies. In fact, one
of DNA's fundamental functions may be specifically to
interact with exogenous natural energy and as such may be
more sensitive to EMF than other larger protein molecules
within any living system. Once thought safely tucked away
and protected within the nucleus, DNA may be acting as a
most efficient electrical conductor at the nexus of all life.
This interesting theory, unfortunately, has not been fol-
lowed up by others to test its biological validity although
fractals have been mimicked widely in technology.

Cell membranes/ion channels

Another direct effect from EMF is at the cell membrane
itself. While DNA is life's fundamental building block, cells
are DNA's complex electron-coherent architectural
expression. The cell's membrane is far more than just a
boundary. It is rather the most important ordering tool in
the biological space between intracellular and extracel-
lular activities, "... a window through which a unitary
biological element can sense its chemical and electrical
environment" [176]. And it is replete with microcurrent.

The cell's outer surface contains molecules that receive
innumerable electrochemical signals from extracellular
activities. Specific binding portals on the cell membrane
set in motion a sequence leading to phosphorylation of
specific enzymes that activate proteins for cellular 'work.'
That includes everything from information processing in
the central nervous system, mechanical functions such as
muscle movements, nutrient metabolism, and the defense
work of the immune system, among many others including
the production of enzymes, hormones, antibodies, and
neurotransmitters [177]. Complex microcurrent signaling
pathways exist from the cell's outside to the inside via
protein intramembraneous particles in the phospholipid
plasma membrane. These convey information on external
stimuli to the cell's interior to allow cellular function.

The cell membrane also has electrical properties.
Microcurrent constantly moves from the interior to the
exterior and vice versa of the cell membrane. According to
Adey and Sheppard [176], some of these properties influ-
ence proteins that form voltage gated membrane channels,
which is one way that cells control ion flow and membrane
electromagnetic potential essential to life. There are


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specific windows that react according to frequency,
amplitude, and duration differences, indicating a
nonlinear and non-equilibrium character to exogenous
exposures on cells [177-185].

Some pulsed fields are more biologically active than
non-pulsed fields and different forms of pulsing also create
different effects. As far back as 1983, Goodman et al. [186]
found pulsed weak electromagnetic fields modified bio-
logical processes via DNA transcription when a repetitive
single pulse and the repetitive pulse train were used. The
single pulse increased the specific activity of messenger
RNA after 15 and 45 min while the pulse train increased
specific activity only after 45 min of exposure. Digital
technology simulates pulsing and is the most common
form of environmental exposure today.

Cellular calcium ion channels have long been of in-
terest and may be particularly sensitive targets for EMFs
due to possible increased calcium flux through the chan-
nels which can lead to secondary responses mediated
through Ca2+/calmodulin stimulation of nitric oxide syn-
thesis, calcium signaling, elevated nitric oxide (NO), NO
signaling, peroxynitrite, free radical formation, and
oxidative stress — many with implications to DNA as hy-
pothesized by Pall [187]. Calcium is essential to signal
transduction between cells and is significant to everything
from metabolism, bone/cell/blood regeneration, hormone
production and neurotransmissions among many others.
These cellular calcium responses to EMF indicate an arti-
ficial change in the signaling processes at the cell mem-
brane — considered a switchboard for information between
the exterior environment and intracellular activities that
guide cell differentiation and control growth [188].

Pall [187] cited 23 studies of effects to voltage gated
calcium channels (VGCC) and noted nonthermal mecha-
nisms were the most likely since many studies showed ef-
fects were blocked by calcium channel blockers (widely
prescribed for heart irregularities having nothing to do
with thermal issues). Pall [189] noted that many other
studies showed EMF changes in calcium fluxes and intra-
cellular calcium signaling. He hypothesized that alter-
ations in intracellular calcium activity may explain some of
the myriad biological effects seen with EMF exposure,
including oxidative stress, DNA breaks, some cancers,
infertility, hormonal alterations, cardiac irregularities, and
diverse neuropsychiatric effects. These end points need
further study and verification.

There is much to be learned about calcium effects as
studies are contradictory. Changes in free radicals (see
below) also affect calcium metabolism. There are more
studies showing EMF effects on free radicals than calcium
changes. Calcium activates the nitric oxide free radical

pathway but there are only a few studies of this pathway
following EMF exposure — less than 5% of EMF-oxidative
change studies are on nitric oxide mechanisms. Also of
interest is the fact that power density and frequency win-
dows were seen in early research at rising harmonic in-
crements along the electromagnetic spectrum beginning in
the ELF bands [190-195]. Observed effects were quite dra-
matic in what researchers described as calcium efflux or
'dumping' from cells. The most dramatic effects were seen
at 180 Hz in the ELF range. This appears to contradict Pall's
work [189] cited above as increased calcium efflux is the
opposite of what Pall's hypothesis would predict, e.g.,
calcium influx. With more research both calcium influx and
efflux effects may be found to be caused by different vari-
ables and/or EMF exposures.

In addition, exogenous signaling characteristics are
also important to how cells react to both ELF and RFR
ranges. Building on the work that demonstrated carrier
waves of 50 and 147 MHz, when sinusoidally amplitude
modulated at 16 Hz ELF in in vitro chick brain tissue [190,
191] and in live awake cat brain models [196] that created
frequency windows for calcium efflux, Blackman et al.
[194] additionally found that signaling characteristics were
also significant. Research showed that calcium efflux
occurred only when tissue samples are exposed to specific
intensity ranges of an ELF-modulated carrier wave; un-
modulated carrier waves did not affect ion efflux. Black-
man et al. [194] further wrote that cells may be capable of
demodulating signals. The authors reported that 16-Hz si-
nusoidal fields, in the absence of a carrier wave, altered the
efflux rate of calcium ions and showed a frequency-
dependent, field-induced enhancement of calcium-ion
efflux within the ranges 5-7.5 V/m and 35-50 V/m (peak-
to-peak incident field in air) with no enhancement within
the ranges 1-2,10-30, and 60-70 V/m. This body of work
indicates that living cells interact with, and are capable of
taking direction from, exogenous fields in far more com-
plex ways than ever imagined, at intensities barely above
background levels. This work may be particularly impor-
tant to new technology that turns previously wired ELF
frequencies into wireless applications, such as "wireless
electricity" to charge electric cars.

Blackman et al. [197] found for the first time a link
between the ELF/EMF being studied and the density of the
natural local geomagnetic field (LGF) in the production of a
biological response. Calcium efflux changes could be
manipulated by controlling the LGF along with ELF and
RF-EMF exposures. In a local geomagnetic field at a density
of 38 (iT, 15- and 45-Hz electromagnetic signals had been
shown to induce calcium ion efflux from the exposed tis-
sues, whereas 1- and- 30-Hz signals did not. Bawin and


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Levitt et al.: EMF and wildlife — 13

Adey [190] found a reduction in efflux when using an
electric field; Blackman et al. [194] found an increase when
using an electromagnetic field, thus identifying/isolating
for the first time the significance of the magnetic field
component in exposure parameters. Building on the win-
dow ranges noted above, Blackman et al. [197] demon-
strated that the enhanced calcium efflux field-induced
15-Hz signal could be rendered ineffective when the LGF is
reduced to 19 jiT with Helmholtz coils. In addition, the
ineffective 30-Hz signal became effective when the LGF
was altered to 1<25.3 [iT or to +76 [iT. The results demon-
strated that the net intensity of the local geomagnetic field is
an important cofactor in biological response and a poten-
tially hidden variable in research. The results, they noted,
appear to describe a resonance-like relationship in which
the frequency of the electromagnetic field can induce a
change in calcium efflux proportional to LGF density (see
Liboff [198,199] below for more detail).

The bottom line is that changes of this magnitude at
the cellular level — be it directly to DNA within the nucleus
or via voltage gated channels at the cell's membrane — can
lead to direct effects on DNA within and across species. The
evidence cited above illustrates the degree, likelihood, and
variety of impacts from EMF directly on cellular physiology
that are capable of affecting DNA in all living systems in
myriad ways.

Indirect mechanisms: free radicals,
stress proteins, resonance, Earth's
geomagnetic fields

Free radicals

An indirect, or secondary, mechanism for DNA damage
would be through free radical formation within cells, which is
the most consistently reported with both ELF and RFR ex-
posures under many different conditions in biological sys-
tems. According to Phillips et al. [139], free radicals may also
interact with metals like iron [142,151,152,158] and play a role
in genotoxic effects from something called the Fenton ef-
fect — a process "...catalyzed by iron in which hydrogen
peroxide, a product of oxidative respiration in the mito-
chondria, is converted into hydroxyl free radicals, which are
very potent and cytotoxic molecules" [139].

The significance of free radical processes may even-
tually answer some questions regarding how EMF interacts
with biological systems. There are about 200-300 papers
showing EMF effects on free radicals [77, 168, 200]. Free

radicals are important compounds involved in numerous
biological functions that affect many species. Increases in
free radicals explain effects from damage to macromole-
cules such as DNA, protein, and membrane lipids;
increased heat shock proteins; neurodegenerative dis-
eases; and many more.

Yakymenko et al. [168] published a review on oxidative
stress from low-level RFR and found induced molecular ef-
fects in living cells, including significant activation of key
pathways generating reactive oxygen species (ROS), activa-
tion of peroxidation, oxidative damage in DNA, and changes
in the activity of antioxidant enzymes. In 100 peer-reviewed
studies, 93 confirmed that RFR induced oxidative effects in
biological systems and that their involvement in cell
signaling pathways could explain a high pathogenic range
of biological/health effects. They concluded that low-
intensity RFR should be recognized as one of the primary
mechanisms of biological activity of nonionizing radiation.
In a follow-up study, Yakymenko et al. [200] investigated
the oxidative and mutagenic effects of low intensity GSM
1,800 MHz RFR on developing quail embryos exposed in
ovo (0.32 (iW/cm2,48 s On, 12 s Off) during 5 days before and
14 days through the incubation period. They found statisti-
cally significant oxidative effects in embryonic cells that
included a 2-fold increase in superoxide generation rate, an
85% increase in nitrogen oxide generation, and oxidative
damage to DNA up to twice the increased levels of 8-oxo-dG
in cells of 1-day old chicks. RFR exposure almost doubled
embryo mortality and was statistically significant. They
concluded that such exposures should be recognized as a
risk factor for living cells, including embryonic integrity.

Lai [77] focused a review on static magnetic field
ELF-EMF and found that changes in free radical activities
are one of the most consistent effects. Such changes can
affect numerous physiological functions including DNA
damage, immune system and inflammatory response, cell
proliferation and differentiation, wound healing, neural
electrical activities, and behavior. Given that many species
have proven sensitive to natural static geomagnetic fields
and use such information in critical survival skills, some
wildlife species may also be adversely affected via free
radical alterations from anthropogenic exposures. But Lai
[77] noted the inherent contradictions from EMF-induced
changes in free radicals, particularly on cell proliferation
and differentiation since those processes can affect cancer
development as well as growth and development. Induced
free-radical changes may therefore have therapeutic ap-
plications in killing cancer cells via the generation of the
highly cytotoxic hydroxyl free radical by the Fenton Re-
action (noted above), thereby creating a non-invasive low-
side-effect cancer therapy.


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Stress proteins

Another potentially indirect effect to DNA is via protein
synthesis required by all cells to function. A living animal
converts animal and plant proteins that it ingests into other
proteins needed for life's activities — antibodies, for
instance, are a self-manufactured protein. DNA is critical to
protein synthesis and can create in humans about 25,000
different kinds of proteins with which the body can then
create 2,000,000 types in order to fully function.

There are many different classes of proteins. These
include stress proteins stimulated by potentially harmful
environmental factors to help cells cope and repair damage
due to factors like acute temperatures, changes in oxygen
levels, chemicals/heavy metals exposure, viral/bacterial
infections, ultraviolet light and other ionizing and
nonionizing radiation exposures [124].

The presence of stress proteins indicates healthy repair
action by an organism and is considered beneficial up to a
point as a protective mechanism. According to Blank and
Goodman [201], "The 20 different stress protein families are
evolutionarily conserved and act as 'chaperones' in the cell
when they 'help' repair and refold damaged proteins and
transport them across cell membranes. Induction of the
stress response involves activation of DNA." Stress proteins
are also considered a yardstick to determine what living
cells experience as stress that requires remediation in the
first place — something not always obvious, especially with
subtle environmental exposures like low-level EMF barely
above natural background levels.

Whether an effect is thermal or nonthermal, adverse or
simply observed biologically, has been subject to fierce
debate for decades; thus tissue-heating DNA pathways are
also central to this paper. Heat as a cellular stressor was
first observed in the 1960s by Italian researcher Ferruccio
Ritossa in fruit flies (D. melanogaster) when experimental
temperatures were accidentally raised by a few degrees
and he observed enlarged chromosomes at particular sites.
(Drosophilae are often used in research because they only
have four pairs of chromosomes, are relatively easy to work
with, have a fast breeding cycle, and lay numerous eggs.)
As cited in Blank [124], as Ritossa's observation became
better understood, with effects subsequently seen over
decades in animals, plants and yeast cells, it came to be
called the "heat shock response." Extensive research
established that the heat shock response lead to the for-
mation of a unique protein class — heat shock proteins
(HSP) that repair other proteins from potentially fatal
temperature damage, as well as assist cells to be more
thermo-tolerant. Research has gone on to prove that cells

produce other similar proteins to various stressors, now
generally called stress proteins but most are still catego-
rized as "HSP" from the original demarcation.

Goodman and Blank [202, 203] found that EMF is a
cellular stressor even at low intensities in the absence of
elevated temperatures. They found the protein distribution
patterns synthesized in response to ELF-EMF resembled
those of heat shock with the same sequence of changes even
though the energy of the two stimuli differed by many orders
of magnitude. Their results indicated that ELF-EMF stimu-
lates a similar gene expression pathway as that of thermal
shock and is itself a cellular stressor. Of particular signifi-
cance is the fact that over-expression of stress genes is found
in a number of human tumors and is characteristic of a va-
riety of neoplasia [202]. Increased stress proteins are seen in
numerous animal model studies pertinent to wildlife.

Blank and Goodman [201] further noted that both ELF
and RFR activate the cellular stress response despite the
large energy difference between them; that the same
cellular pathways respond in both frequency ranges; and
that models suggest that EMF can interact directly with
electrons in DNA. They note that low energy EMF interacts
with DNA to induce the stress response while the increased
energy in RFR can lead to DNA strand breaks. As such, this
makes the stress response a frequency-dependent direct and
indirect cause of DNA damage — a significant finding. They
concluded that exposure standards should not be based on
exposure intensity alone but on biological responses long
before thermal thresholds are met or crossed.

Resonance and geomagnetic fields

There are other important direct and indirect ways that EMFs
interact with and effect biological systems, including various
forms of resonance — cyclotron, electron paramagnetic,
nuclear, and stochastic — as well as through inherently
produced biological materials such as magnetite found in
bird brains and many other species (see below).

Resonance is the phenomenon that occurs when a
certain aspect of a force (like a frequency wave) matches a
physical characteristic (like a cell or whole living organ-
ism) and the power inherent in the force is transferred to
the physical object causing it to resonate or vibrate. Within
the object, the resonance is self-perpetuating. The classic
example is of an opera singer hitting high C in the presence
of a crystal goblet for a sustained period until it shatters.

Following the work of Blackman et al. [197] who found
the Earth's local geomagnetic fields (LGF) could influence
calcium ions moving through membrane channels (see


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Levitt et al.: EMF and wildlife — 15

above), Liboff [198,199] proposed that cyclotron resonance
was a plausible mechanism for coupling interactions be-
tween the LGM and living cells. Liboff found cyclotron
resonance consistent with other indications that showed
many membrane channels have helical configurations;
that the model could apply to other circulating charged
components within the cell; and that cyclotron resonance
could lead to direct resonant electromagnetic energy
transfer to selected cell compartments.

All resonance is based on a relationship. Cyclotron reso-
nance is based on the relationship between a constant mag-
netic field and an oscillating (time-varying) electric or
magnetic field that can affect the motion of charged particles
such as ions, some molecules, electrons, atomic nuclei, or
DNA in living tissue. Living systems are filled with charged
particles necessary for life, including calcium, sodium,
lithium, and potassium ions that all pass through the cell
membrane and are capable of affecting DNA. Cyclotron
resonance occurs when an ion is exposed to a steady mag-
netic field (such as the Earth's) which causes the ion to move
in a circular orbit at a right angle to the field. The speed of the
orbit is determined by the charge and mass of the ion and the
strength of the magnetic field. If an electric field is added that
oscillates at exactly the same frequency and that is also at a
right angle to the magnetic field, energy will be transferred
from the electric field to the ion causing it to move faster. The
same effect can be created by applying an additional mag-
netic field parallel to the constant magnetic field. This is
important because it provides a plausible mechanism for how
living cells interact with both natural and artificial fields, and
explains how vanishingly low levels of EMFs can create major
biological activity when concentrated on ion particles. It also
points to living systems' ability to demodulate — or take di-
rection from — certain aspects of electromagnetic information
from both natural and artificial exposures [7]. Resonance
should not be underestimated. It applies to all frequencies
and is not based on power density alone.

Another subtle energy relationship in biology is called
stochastic resonance that has been determined to be sig-
nificant in how various species interact with their natural
environments, in some instances for their survival. Sto-
chastic resonance is a phenomenon where a signal below
normal sensing can be boosted by adding wide-spectrum
white noise signals. The frequencies in the white noise that
match the original signal's frequencies will resonate with
each other and amplify the original signal while not
amplifying the rest of the white noise. This increase in what
is called the signal-to-noise ratio makes the original signal
more prominent. Some fish, for instance, can "hear"
predators better in the noise of running water than in still
water due to stochastic resonance (see "Fish" below.).

The signal-to-noise ratio has been a prominent aspect
of EMF research with some scientists long holding that
energy exposures below the body's natural signal-to-noise
ratio could not possibly damage living tissue. But the most
recent research that finds effects to DNA from low
intensity EMF indicates that many variables affect biolog-
ical processes, often in nonlinear patterns far below the
signal-to-noise ratio. Some of the most cutting edge
research — with an eye toward treating human in utero
birth defects and adult limb regeneration — is being done
by manipulating the electric charge across cell membranes
(called membrane potential) via intentional manipulation
of genes that form ion channels. Pai et al. [204] found that
by putting ion channels into cells to raise the voltage up or
down, they could control the size and location of the brain
in embryonic African clawed frogs (Xenopus laevis), thus
demonstrating the importance of microcurrents on mem-
brane potential in growth and development. The research
group also studied endogenous bioelectricity on clawed
frog brain patterning during embryogenesis, noting that
early frog embryos exhibit a characteristic hyperpolar-
ization of cells lining the neural tube. Disruption of this
spatial gradient of the transmembrane potential (^mem)
diminished or eliminated the expression of early brain
markers in frogs, causing anatomical mispatterning,
including absent or malformed regions of the brain. This
effect was mediated by voltage-gated calcium signaling
and gap-junctional communication. The authors hypoth-
esized that voltage modulation is a tractable strategy for
intervention in certain classes of birth defects in humans
but they did not make the leap to potential environmental
damage to other species from such ambient exposures.

In general, whether direct, indirect, or synergistic, to
understand ambient effects to wildlife, one also needs to
know if effects are cumulative, what compensatory
mechanisms a species may have, and when or if homeo-
stasis will deteriorate to the point of no return [205]. In
looking at environmental contaminants, we have histor-
ically focused on chemicals for both direct and indirect
effects such as endocrine disruption. But primary bio-
logical manifestation is more physical than chemical
since the only thing that distinguishes one chemical from
another on the Periodic Table is the amount of electrons
being traded up and down on the scale. Chemicals are
actually secondary manifestations of initial atomic prin-
ciples, not the other way around. Plus, the synergistic
effects of the Earth's natural fields can no longer be dis-
missed as an interesting artifact that is not biologically
active or relevant. All living systems are first and foremost
expressions of biological energy in various states of
relationship.


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For a Table of more low-level effects studies on DNA,
see Part 2, Supplements 1 and 2.

What the studies show

The literature is voluminous on EMF effects to nonhuman
species, going back at least to the 1930s using modern methods
of inquiry. We have, after all, been using animal, plant, and
microbial models in experiments for decades. We may in fact
know less about effects to humans than to other species.

In this paper, we focused on exposures common in
today's environment. In Part 1, Rising Background Levels,
we defined low level RFR as power density of 0.001 mW/
cm2 (1 (iW/cm2), or a SAR of 0.001 W/kg. Part 2 Supple-
ments 3 and 4 contain extensive tables with pertinent
studies that apply to fauna and flora, respectively. The
sections that follow in Part 2 on individual species include
selected studies of particular interest to how EMF couples
with, and potentially affects, wildlife. In most studies, as
illustrated in Part 2, Supplement 3, the intensity of the
incident EMF was provided in ^iW/cm2 or V/m. To be
consistent throughout the paper, we converted intensity in
the studies to ^iW/cm2. However, such conversion (i.e. V/m
to (iW/cm2) tends to overestimate the exposure level and
does not represent the full picture. Therefore where studies
provided the amount of energy absorbed, e.g., the specific
absorption rate (SAR), they were also included in Supple-
ment 3 (in W/kg). Very low levels of energy absorption have
shown effects in all living organisms studied.

Levitt and Lai [167] reported numerous biological ef-
fects from RFR at very low intensities and SARs comparable
to far-field exposures within 197-492 ft (60-150 m) from
cell towers. Included were in vivo and in vitro low-intensity
RFR studies. Effects included genetic, growth and repro-
ductive changes; increased permeability of the blood brain
barrier; changes in stress proteins; behavioral responses;
and molecular, cellular, genetic, and metabolic alter-
ations. All are applicable to migratory birds, mammals,
reptiles, and other wildlife and to plant communities, and
to far-field exposures in general. (An update of that table
appears in Part 2 Supplement 3.) It is apparent that envi-
ronmental levels of RFR can elicit biological/health effects
in living organisms. Although there are not enough data on
low-intensity effects of static ELF-EMF to formulate a
separate table, some effects of low-intensity static ELF-EMF
are also described throughout this paper. ELF genotoxic
effects can be found in Part 2, Supplement 2 and ELF in
flora are also listed separately in Part 2, Supplement 4.

Effects, however, do not easily translate from the lab-
oratory to the field. Cucurachi et al. [31] reported on 113

studies with a limited number of ecological studies. The
majority were conducted in laboratory settings using bird
embryos or eggs, small rodents, and plants. In 65% of the
studies, effects from EMF (50% of the animal studies and
about 75% of the plant studies) were found at both high
and low intensities, indicating broad potential effects.
But lack of standardization among the studies and limited
sampling size made generalizing results from organism to
ecosystem difficult. The researchers concluded that due to
the number of variables, no clear dose-response relation-
ship could be determined. Nevertheless, effects from some
studies were well documented and can serve as predictors
for effects to wild migratory birds and other wildlife.

As noted elsewhere throughout this paper, living or-
ganisms can sense and react to very low-intensity electro-
magnetic fields necessary for their survival as seen, for
instance, in studies by Nicholls and Racey [206, 207] on
bats and many others. Bats are already in serious trouble in
North America from white-nosed syndrome and commer-
cial wind turbine blade collisions. Due to the increased use
of tracking radars for bird and bat studies, impacts will
likely only increase [22, 23]. Presence of low levels of RFR
from tracking radars could adversely affect bat foraging
activity, which in turn could affect the composition of in-
sect populations in the vicinity. Many insects, including
honey bees (Apis mellifera var) and butterflies also depend
on the Earth's electromagnetic fields for orientation and
foraging. Presence of exogenous RFR can disturb these
functions. This is particularly relevant for pollinator in-
sects, such as bees and butterflies. Pollinators are essential
in producing commercial crops for human consumption,
including almonds, apples, pears, cherries, numerous
berry crops, citrus fruits, melons, tomatoes, sunflowers,
soybeans, and much more. The strongest disruptive effect
to insect pollinators occurs at 1.2 MHz known as the Larmor
frequency [208] which is related to radical pair resonance
and superoxide radical formation. This is an important
indication that effects from RFR are frequency-dependent.

Lai [77], citing Shepherd et al. [209], noted that EMF
can disrupt the directional sense in insects. The fact that
many animals are able to differentiate the north and south
poles of a magnetic field known as the polarity compass
[68, 73, 134, 210, 211] indicates they are susceptible to
having that important sense impaired. These polarity
compass traits confer survival competitiveness to organ-
isms but are of particular concern since directional cues
can be easily disturbed by man-made EMF [69,134, 212].

Bird migration also depends on proper sensing and
orientation to natural electromagnetic fields. A study by
Engels et al. [213] showed that magnetic noise at 2 kHz-
9 MHz (within the range of AM radio transmission) could


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Levitt et al.: EMF and wildlife — 17

disrupt magnetic compass orientation in migratory Euro-
pean Robins (Erithacus rubecula). The disruption can occur
at a vanishingly low level of 0.01 V/m, or 0.0000265 (iW/cm2.
Similar effects of RFR interference on magnetoreception
have also been reported in a night-migratory songbird [214]
and the European Robin [126]. Migration is already a taxing
and dangerous activity for birds; adding another potential
negative impact to bird survival is troubling.

Lai [77] also noted that another consideration is the
"natal homing behavior" exhibited in some animals that
return to their natal birth places to reproduce. These
include sea turtles [89] eels [90]; and salmon [91]. New-
borns of these animals are imprinted with the memory of
the intensity and the inclination angle of the local
geomagnetic field, later used to locate their place of birth
when they return to breed. There are indications that man-
made EMF can distort this imprinting memory to locate the
site (see "Fish" and "Turtles"below). This has important
consequences to the survival of particular species since it
interrupts their reproductive processes.

It is clear that biological effects can occur at levels of
man-made RFR in our present environment, thereby
conceivably altering delicate ecosystems from a largely
unrecognized danger.

Mammals

The majority of EMF laboratory research, some going back
to the 1800s, has been conducted on a variety of mammal
species using mice, rats, rabbits, monkeys, pigs, dogs, and
others. (The second and third most used models are on
insects and yeast respectively.) Thus, with varying degrees
of confidence, we know a significant amount about how
energy couples with, and affects, laboratory mammalian
species across a range of frequencies. However, this evi-
dence does not automatically transfer at the same confi-
dence level regarding how this vast body of research
applies to wildlife, including mammalian species.

There is unfortunately a dearth of field research on
EMF effects to wildlife. Referenced below, however, are
many potential indicator studies. The effects seen include
reproductive, behavioral, mating, growth, hormonal,
cellular, and others.

Rodents

Rodents are the most frequently used mammalian species
in laboratory research across a range of frequencies and
intensities. While studies are inconsistent, there are

enough troubling indications regarding potential EMF
implications for wildlife.

In the RFR range, there have been several reviews of
fertility and other issues in rodent models with citations too
numerous to mention here — see La Vignera e al. [215] and
Merhi [216] — but some stand out as potentially pertinent to
wildlife.

Magras and Xenos [217] investigated effects of RFR on
prenatal development in mice, using RFR measurements
and in vivo experiments at several locations near an "an-
tenna park," with measured RFR power densities between
0.168 and 1.053 (iW/cm2. Divided into two groups were 12
pairs of mice, placed in locations of different power den-
sities, and mated five times. One hundred eighteen new-
borns were collected, measured, weighed, and examined
macro- and microscopically. With each generation, re-
searchers found a progressive decrease in the number of
newborns per dam ending in irreversible infertility. How-
ever, the crown-rump length, body weight, and number of
lumbar, sacral, and coccygeal vertebrae, was improved in
prenatal development of some newborns. RFR was below
exposure standards and comparable to far-field exposures
that mice could experience in the wild.

Aldad et al. [218], in a laboratory setting, investigated
cell phone RFR (800-1,900 MHz, SARof 1.6 W/kg) exposures
in in-utero mouse models and effects on neurodevelopment
and behavior. They found significant adult behavioral effects
in prenatally exposed mice vs. controls. Mice exposed in-
utero were hyperactive, had decreased memory and anxiety,
and altered neuronal developmental programming. Exposed
mice had dose-response impaired glutamatergic synaptic
transmission onto layer V pyramidal neurons of the pre-
frontal cortex. This was the first evidence of neuropathology
in mice from in-utero RFR at cell phone frequencies, now the
most prevalent in the environment. Effects persisted into
adulthood and were transmissible to next generations. Such
changes can affect survival in wild populations.

Meral et al. [219] looked at effects in guinea pigs (Cavia
parcels) from 900 MHz cell phone frequency exposures on
brain tissue and blood malondialdehyde (MDA), gluta-
thione (GSH), retinol (vitamin A), vitamin D(3) and
tocopherol (vitamin E) levels, as well as catalase (CAT)
enzyme activity. Fourteen male guinea pigs were randomly
divided into control and RFR-exposed groups containing
seven animals each. Animals were exposed to 890- to-
915 MHz RFR (217 Hz pulse rate, 2 W maximum peak power,
SAR 0.95 W/kg) from a cellular phone for 12 h/day (11 h
45 min stand-by and 15 min spiking mode) for 30 days.
Controls were housed in a separate room without cell
phone radiation. Blood samples were collected through
cardiac puncture; biochemical analysis of brain tissue was


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18 — Levitt et al.: EMF and wildlife

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done after decapitation at the end of the 30-day period.
Results found MDA levels increased (p<0.05), and GSH
levels and CAT enzyme activity decreased, while vitamins
A, E and D(3) levels did not change significantly in the
brain tissue of exposed animals. In blood samples of the
exposed group, MDA, vitamins A, D(3) and E levels, and
CAT enzyme activity increased (p<0.05), while GSH levels
decreased (p<0.05). They concluded that cell phone radi-
ation could cause oxidative stress in brain tissue of guinea
pigs but more studies were needed to determine if effects
are harmful and/or affect neural functions.

Lai et al. [220] found that Sprague-Dawley rats exposed
to RFR during water maze testing showed spatial working
memory deficits compared to controls. But similar studies
[221-223] did not find performance effects in spatial taste or
alterations in brain development after similar exposures.
However, subsequent studies in the last two decades have
shown memory and learning effects in animals and
humans after RFR exposure [224].

Several studies also investigated RFR behavioral effects
in rodent models on learning, memory, mood disturbances,
and anxiety behaviors with contradictory results. Daniels
et al. [225] found decreased locomotor activity, increased
grooming and increased basal corticosterone levels in rats
exposed to RFR for 3 h per day at 840 MHz, but no significant
differences were seen between controls and test animals in
spatial memory testing or morphological brain assessment.
The researchers concluded that RFR exposure may lead to
abnormal brain functioning.

Lee et al. [226, 227] looked specifically at effects on
pregnant mice and rat testicular function from combined
RFR mobile network signal characteristics used in wide-
band code division multiple access (W-CDMA) or CDMA
used in 3G mobile communications. Experiments showed
no observable adverse effects on development, reproduc-
tion, or mutation in tested subjects. And no significant ef-
fects were seen by Poulletier de Gannes et al. [228] in in-
utero and post-natal development of rats with wireless fi-
delity (WiFi) at 2,450 MHz. Also, Imai et al. [229] found no
testicular toxicity from 1.95 GHz W-CDMA.

One extremely high frequency (EHF) study comparable to
5G on a mouse model by Kolomytseva et al. [230] looked at
leukocyte numbers and the functional activity of peripheral
blood neutrophils. In healthy mice, under whole-body expo-
sures to low-intensity extremely-high-frequency electromag-
netic radiation (EHF, 42.0 GHz, 0.15 mW/cm2, 20 min daily)
found that the phagocytic activity of peripheral blood neu-
trophils was suppressed by about 50% (p<0.01 as compared
with the sham-exposed control) in 2-3 h after the single
exposure. Effects persisted for 1 day and thereafter returned to
normal within 3 days. But a significant modification of the

leukocyte blood profile was observed in mice exposed to EHF
for 5 days after exposure cessation. Leukocytes increased by
44% (p<0.05 as compared with sham-exposed animals). They
concluded that EHF effects can be mediated via metabolic
systems and further said results indicated whole-body low-
intenstiy EHF exposure of healthy mice had a profound effect
on the indices of nonspecific immunity. These low levels will
be common near 5G infrastructure.

In well-designed non-rodent mammal field studies,
Nicholls and Racey [206, 207], found that foraging bats
showed aversive behavioral responses near large air traffic
control and weather radars. Four civil air traffic control (ATC)
radar stations, three military ATC radars and three weather
radars were selected, each surrounded by heterogeneous
habitat. Three sampling points were carefully selected for
matched habitats, type, structure, altitude and surrounding
land class at increasing distances from each station. Radar
field strengths were taken at three distances from the source:
close proximity (<656 ft/200 m) with a high EMF strength
>2 V/m (1.06 (iW/cm2), an intermediate line-of sight point
(656-1,312 ft/200-400 m) with EMF strength <2 V/m, and a
control location out of radar sight (>1,312 ft/400 m) regis-
tering 0 V/m. Bat activity was recorded three times for a total
of 90 samples, 30 within each field strength category.
Measured from sunset to sunrise, they found that bat activity
was significantly reduced in habitats exposed to an EMF
greater than 2 V/m compared to 0 EMF sites, but such
reduced activity was not significantly different at lower EMF
levels within 400 m of the radar. They concluded that the
reduced bat activity was likely due to thermal induction and
an increased risk of hyperthermia. This was a large field
study near commercial radar installations with mostly high
intensity exposures but low-level effects cannot be excluded
given known magneto-sensitivity in bats.

In another field study using a small portable marine
radar unit significantly less powerful than their earlier
measured field study, Nicholls and Racey [207] found the
smaller signal could also deter bats' foraging behaviors.
First, in summer 2007, bat activity was compared at 20
foraging sites in northeast Scotland during experimental
trials with radar switched on, and in controls with no radar
signal. After sunset, bat activity was recorded for a period
of 30 min with the order of the trials alternating between
nights. Then in summer 2008, aerial insects were sampled
at 16 of the sites using two small light-suction traps, one
with a radar signal, the other a control. Bat activity and
foraging were found significantly reduced when the radar
signal was unidirectional, creating a maximized exposure
of 17.67-26.24 V/m (83-183 (iW/cm2). The radar had no
significant effect on the abundance of insects captured by
the traps despite reduced bat activity.


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Levitt et al.: EMF and wildlife — 19

Balmori [231] also noted significantly reduced bat ac-
tivity in a free-tailed bat colony (Tadarida teniotis) where
the number of bats decreased when several cell towers
were placed 262 ft (80 m) from the colony.

In the ELF range, Janac et al. [232] investigated ELF/MF
effects — comparable to powerline and stray voltage
ground current — on motor behavior patterns in Mongolian
gerbils (Meriones unguiculatus) and found age-dependent
changes in locomotion, stereotypy, and immobility in 3-
and 10-month-old males. Animals were continuously
exposed to ELF-MF (50 Hz; 0.1, 0.25 and 0.5 mT) for seven
days with behavior monitored for 60 min in the open field
after the 1st, 2nd, 4th, and 7th day (to capture immediate
effects), as well as three days after exposure (to capture
delayed effects). They found that exposure to 3-month-old
gerbils increased motor behavior (locomotion and stereo-
typy), and therefore decreased immobility. In the 3-month
old gerbils, ELF/MF also showed a delayed effect (except at
0.25 mT) on stereotypy and immobility. In 10-month-old
gerbils, ELF/MF of 0.1, 0.25 and 0.5 mT induced decreased
locomotion, a slight increase in stereotypy, and pro-
nounced stimulation of motor behavior. Increased motor
behavior was observed three days after exposure, indi-
cating long lasting effects. Researchers concluded that in 3-
and 10-month-old gerbils, specific temporal patterns of
motor behavior changes were induced by ELF/MF due to
age-dependent morpho-functional differences in brain
areas that control motor behavior.

The above is a very small sample of rodent studies. See
Part 2 Supplements 1 and 2 for more genetic effects to ro-
dents, and Supplement 3 for additional studies.

Bovines

Due to domestication and easy accessibility, there are
numerous studies of dairy cows (Bos taurus) which appear
particularly sensitive to both natural and man-made EMFs.
Fedrowitz [71] published a thorough review with citations
too numerous to mention here. Noted in the review is the
fact that bovines, although easily accessible, are difficult to
study with precision due to their size, which creates
handling and dosimetric complexities. Also noted are that
bovines today are at their milk- and beef-production
physiological limits, and that the addition of even a weak
stressor may be capable of altering a fragile bovine phys-
iological balance. It is clear in the Fedrowitz review that
cows respond to environmental exposures from a broad
range of frequencies and properties, even as some studies
lack good exposure assessment. RFR exposure created
avoidance behavior, reduced ruminating and lying times,

and alterations in oxidative stress enzymes among other
problems, while ELF-EMF found contradictory evidence
affecting milk production, fat content, hormone imbal-
ances and important changes in other physiological pa-
rameters. Cows have also been found sensitive to stray
voltage and transient harmonics with problematic milk
production, health, reproduction and behavioral effects.

The question is how much of this body of work could
translate to other ruminants and large mammals on-field or
in the wild such as deer/cervids — behaviorally, repro-
ductively, and physiologically. Stray voltage and ELF-EMF
near powerlines, and rural area RFR from both ground-
based and satellite transmitters, for instance, may affect
wild migratory herds and large ungulates in remote areas
that go undetected.

Bovines and RFR

Loscher and Kas [233] observed abnormal behavior in a dairy
herd kept in close proximity to a TV and radio transmitter.
They found reduction in milk yield, health problems, and
behavioral abnormalities. After evaluating other factors, they
concluded the high levels of RFR were possibly responsible.
They removed one cow with abnormal behavior to another
stable 20 km away from the antenna, resulting in normali-
zation of behavior within five days. Symptoms reappeared
when the cow was returned to the stable near the antennas. In
a later survey, Loscher [234] also found effects of RFR on the
production, health and behavior of farm animals, including
avoidance behavior, alterations in oxidative stress parame-
ters, and ruminating duration.

Balode [59] obtained blood samples from female brown
cows from a farm close to, and in front of, the Skrunda Ra-
dar - located in Latvia at an early warning radar system
operating in the 156-162 MHz frequency range — and samples
from cows in a control area. They found micronuclei in pe-
ripheral erythrocytes were significantly higher in the exposed
cows, indicating DNA damage.

Stark et al. [235] investigated short-wave (3-30 MHz)
RFR on salivary melatonin levels in dairy cattle, with one
herd at a farm located at 1,640 ft/500 m (considered
higher exposure) and a second control herd located 13,123
ft/4,000 m from the transmitter (considered unexposed).
The average nightly magnetic field strength readings
were 21-fold greater on the exposed farm (1.59 mA/m)
than on the control farm (0.076 mA/m). At both farms,
after initially monitoring five cows' salivary melatonin
concentrations at 2-h intervals during night dark phase
for 10 consecutive days, and with the short-wave trans-
mitter switched off during three of the 10 days (off phase),
samples were analyzed using a radioimmunoassay. They


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20 — Levitt et al.: EMF and wildlife

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reported that mean values of the two initial nights did not
show a statistically significant difference between
exposed and unexposed cows and concluded that
chronic melatonin reduction was unlikely. But on the first
night of re-exposure after the transmitter had been off for
three days, the difference in salivary melatonin concen-
tration between the two farms (3.89 pg/ml, CI: 2.04, 7.41)
was statistically significant, indicating a two-to-seven-
fold increase of melatonin concentration. They
concluded that a delayed acute effect of EMF on mela-
tonin concentration could not be excluded and called for
further trials to confirm results.

Hassig et al. [95] conducted a cohort study to evaluate
the prevalence of nuclear cataracts in veal calves near mobile
phone base stations with follow-up of each dam and its calf
from conception through fetal development and up to
slaughter. Particular emphasis was focused on the first
trimester of gestation (organogenesis). Selected protective
antioxidants (superoxide dismutase, catalase, glutathione
peroxidase [GPx]) were assessed in the aqueous humor of the
eye to evaluate redox status. They found that of 253 calves, 79
(32%) had various degrees of nuclear cataracts, but only 9
(3.6%) of calves had severe nuclear cataracts. They concluded
that a relationship between the location of veal calves with
nuclear cataracts in the first trimester of gestation and the
strength of antennas was demonstrated. The number of an-
tennas within 328-653 ft (100-199 m) was associated with
oxidative stress and there was an association between
oxidative stress and the distance to the nearest base station.
Oxidative stress was increased in eyes with cataract (OR per
kilometer: 0.80, confidence interval 95 % 0.62, 0.93). But the
researchers further concluded that it had not been shown that
the antennas actually affected stress. Hosmer-Lemeshow
statistics showed an accuracy of 100% in negative cases with
low radiation, and only 11.11% accuracy in positive cases with
high radiation. This reflected, in their opinion, that there are a
lot of other likely causes for nuclear cataracts beside base
stations and called for additional studies on EMF during
embryonic development.

Hassig et al. [96] further examined a dairy farm in
Switzerland where a large number of calves were born with
nuclear cataracts after a mobile phone base station was erected
near the barn. Calves showed a 3.5 times higher risk for heavy
cataracts if born there compared to the Swiss average. All usual
causes for cataracts could be excluded but they nevertheless
concluded that the incidence remained unknown.

Bovines and swine: ELF-EMF, stray electric current

Bovines appear unusually sensitive to ELF-EMF from stray
current caused by both normal industrial and faulty

grounding methods near high tension transmission lines
close to dairy farms. Stray current can cover large areas and
occurs when current flows between the grounded circuit
conductor (neutral) of a farm and the Earth through dairy
housing equipment like metal grates. It typically involves
small, steady power frequency currents [99], not high
transient shocks, although that also can sometimes occur
under wet weather conditions. According to Hultgren [236],
dairy cattle can perceive alternating currents exceeding
1 mA between the mouth and all four hooves with behav-
ioral effects in cows usually occurring above 3 mA. Stray
current can act as a major physical stressor in cows and
other animals [237]. This may also be happening in wild
migratory species moving through such areas.

At the request of dairymen, veterinarians, and county
extension agents in Michigan, U.S., Kirk et al. [238] inves-
tigated stray current on 59 Michigan dairy farms. On 32
farms, stray current sources were detected. Where voltage
exceeded 1 V alternating current, increased numbers of
dairy cows showed abnormal behavior in the milking fa-
cility and increased prevalence of clinical mastitis. Re-
covery from the stray current-induced abnormalities was
related to the type of abnormality and the magnitude of the
exposure voltage.

Burchard et al. [239] in a small but well-controlled
alternating exposure study of non-pregnant lactating Hol-
stein cows found a longer estrous cycle in cows exposed to a
vertical electric field of 10 kV/m and a uniform horizontal
magnetic field of 30 (iT at 60 Hz, compared to when they were
not exposed. Rodriguez et al. [240] also found that exposure
to EMF may increase the duration of the bovine estrous cycle.
Burchard et al. [241] evaluated effects on milk production in
Holsteins exposed to a vertical electric field of 10 kV/m and a
uniform horizontal MF of 30 (iT at 60 Hz and found an average
decrease of4.97,13.78, and 16.39% in milk yield, fat corrected
milk yield, and milk fat, respectively in exposed groups, and
an increase of 4.75% in dry matter food intake. And Buchard
et al. [242] in two experiments investigated blood thyroxine
(T4) levels in lactating pregnant and non-lactating non-
pregnant Holstein cows exposed to 10 kV/m, 30 (iT EMF and
found a significant change depending on the time of blood
sampling in exposed groups. They concluded that exposure
of dairy cattle to ELF-EMF could moderately affect the blood
levels of thyroxine.

Hillman et al. [93, 94] reported that harmonic distor-
tion and power quality itself could be another variable in
bovine sensitivity to stray current. They found behavior,
health, and milk production were adversely affected by
transients at the 3rd, 5th, 7th, and triplen harmonic cur-
rents on utility power lines after a cell tower was found
charging the ground neutral with 10+ V, causing the


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Levitt et al.: EMF and wildlife — 21

distortion. After installing a shielded neutral isolation
transformer between the utility and the dairy, the distor-
tion was reduced to near zero. Animal behavior improved
immediately and milk production, which had been sup-
pressed for three years, gradually returned to normal
within 18 months.

Swine (Sus scrofa domesticus) — like rats and mice —
have demonstrated aversive behavior to ELF-EMF electric
fields. Hjeresen et al. [243] found miniature pigs, exposed
to 60-Hz electric fields (30 kV/m for 20 h/day, 7 days/week
up to 6 months) preferred an absence of the field during a
23.5-h period by spending more time out of the electric field
than in it during sleep periods. And Sikov et al. [244], as
part of a broad study of Hanford Miniature swine on
reproductive and developmental toxicology (including
teratology) over three breeding cycles found a strong as-
sociation between chronic exposure to a vertical uniform
electric field (60-Hz, 30-kV/m, for 20 h/day, 7 days/week)
and adverse developmental effects vs. control. They
concluded that an association exists between chronic
exposure to strong electric fields and adverse develop-
mental effects in swine (75% malformations in exposed vs.
29% sham) in first generation with consistent results in two
subsequent generations.

Avian

Birds are important indicators of ecosystem well-being and
overall condition. Even subtle effects can be apparent due
to their frequent presence in RFR areas. Their hollow
feathers have dielectric and piezoelectric properties,
meaning they are conductive and capable of acting as a
waveguide directing external RFR energy directly and
deeply into avian body cavities [245-249]. Their thin skulls
have both magnetite and radical pair receptors (see
"Mechanisms" above) and they are highly mobile — often
traveling across great migratory distances of tens to as
much as a hundred thousand kilometers round-trip per
year, resulting in potential multi-frequency cumulative
effects from chronic near, middle, and far-field exposures.
Avian populations are declining worldwide, especially
among migratory species. This means that birds may be
uniquely sensitive to adverse effects from environmental
RFR since their natural habitat is air and they often fly at
lateral levels with infrastructure emissions, bringing them
that much closer to generating sources.

Tower and building construction, as direct obstacles,
are known hazards to birds. One tower at 150 feet (46 m)
above ground level is thought to account for as many as
3,000 songbird deaths per month in migratory pathways

during peak migration [250] and communication tower
collisions have been documented to kill more than 10,000
migratory birds in one night at a TV tower in Wisconsin
[251, 252]. It has been known for years that the songbird
populations of North America and Europe are plummeting.
Only recently were towers considered a significant factor.
But is the problem solely due to obstacles in direct migra-
tory pathways or is something else involved?

RFR from towers may be acting as an attractant to birds
due to their singular physiology. Avian eyes and beaks are
uniquely magnetoreceptive with both magnetite and crypt-
chrome radical pair receptors. One definitive study by Beason
and Semm [253] demonstrated that the common cell phone
frequency (900-MHz carrier frequency, modulated at 217 Hz)
at nonthermal intensities, produced firing in several types of
nervous system neurons in Zebra Finches (Taeniopygia gut-
tate). Brain neurons of irradiated anesthetized birds showed
changes in neural activity in 76% of responding cells, which
increased their firing rates by an average 3.5-fold vs. controls.
Other responding cells exhibited a decrease in rates of
spontaneous activity. The Beason and Semm study [253]
could explain why birds may be attracted to cell towers, a
theoretical premise they previously observed with Bobolinks
(Dolichonyx oryzivorus; [254]).

RFR may also act as an avian stressor/irritant. Early
work by Wasserman et al. [255] in field studies on 12 flocks
of migratory birds subjected to various combinations of
microwave power density and duration under winter con-
ditions at Monomet, MA, using birds from two additional
flocks as controls, showed increased levels of aggression in
some of the irradiated birds.

Other research indicated a range of effects capable of
broad adverse environmental outcomes. Laboratory
studies by Di Carlo et al. [256] found decreases in heat
shock protein production in chick embryos. The re-
searchers used 915-MHz RFR on domestic chicken em-
bryos and found that exposure typical of some cell phone
emissions reduced heat shock proteins (HSP-70) and
caused heart attacks and death in some embryos. Con-
trols were unaffected. In replicated experiments, similar
results were found by Grigor'ev [257] and Xenos and
Magras [258]. Batellier et al. [259] found significantly
elevated embryo mortality in exposed vs. sham groups of
eggs incubated with a nearby cell phone repeatedly
calling a 10-digit number at 3-min intervals over the
entire incubation period. Heat shock proteins help
maintain the conformation of cellular proteins during
periods of stress. A decrease in their production
diminishes cellular protection, possibly leading to can-
cer, other diseases, heart failure, and reduction in pro-
tection against hypoxia and ultraviolet light.


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Not all results are adverse. Tysbulin et al. [260, 261]
investigated both short and prolonged GSM 900 MHz cell
phone signal exposure on embryo development in Quail
(Coturnix coturnix japonica), irradiating fresh fertilized
eggs during the first 38 h and 14 days of incubation using a
cell phone in connecting mode continuously activated
through a computer system. Maximum intensity of incident
radiation on the egg's surface was 0.2 mW/cm2. Results
found a significant (p<0.001) increase in differentiated
somites in 38-h exposed embryos and a significant (p<0.05)
increase in total survival of embryos in eggs after 14 days
exposure. They also found the level of thiobarbituric acid
(TBA) reactive substances was significantly (p 0.05-0.001)
higher in the brains and livers of hatchlings from exposed
embryos and hypothesized that a facilitating effect exists
due to enhanced metabolism in exposed embryos via per-
oxidation mechanisms. They concluded low-level
nonthermal effects from GSM 900 MHz to quail embryo-
genesis is possible and that effects can be explained via a
hormesis effect induced by reactive oxygen species (ROS).

Signaling characteristics such as pulsing vs. contin-
uous wave are also important. Berman et al. [262], in a
multi-lab study of pulsed ELF magnetic fields found a
highly significant incidence of abnormalities in exposed
chick eggs vs. controls. And Ubeda et al. [263] found irre-
versible damage to chick embryos from weak pulsed
ELF-EMF magnetic fields that are common in the environ-
ment today. Initial studies on freshly fertilized chicken
eggs were exposed during the first 48 h of post-laying in-
cubation to pulsed magnetic fields (PMFs) with 100 Hz
repetition rate, 1.0 |aT peak-to-peak amplitude, and 500 (is
pulse duration. Two different pulse waveforms were used,
with rise and fall times of 85 [is or 2.1 (is. A two-day expo-
sure found significant increased developmental abnor-
malities. In follow-up research, after exposure, eggs were
incubated for an additional nine days without PMFs. Em-
bryos removed from eggs showed an excess of develop-
mental anomalies in the PMF-exposed groups compared
with the sham-exposed samples. There was a high rate of
embryonic death in the 2.1 |as rise/fall time. Results indicate
PMFs can cause irreversible developmental changes, con-
firming that a pulse waveform can determine embryonic
response to ELF magnetic fields common today.

Between 1999 and 2005, Fernie et al. for the first time
investigated various potential reproductive effects on a
captive raptor species — the American Kestrel (Falco
sparverius) — from ELF-EMF equivalent to that of wild
nesting pairs on power transmission lines. In a series of
studies, captive pairs were typically bred under control or
EMF exposure over 1-3 breeding cycles. In 1999, Fernie
et al. [264] investigated photo phasic plasma melatonin in

reproducing adult and fledgling kestrels, finding that EMFs
affected plasma melatonin in adult male kestrels, sup-
pressing it midway through, but elevating it at the end of
the breeding season. In long-term, but not short-term EMF
exposure of adults, plasma melatonin was supressed in
their fledglings too which could affect migratory success.
Molt happened earlier in adult EMF-exposed males than in
controls. EMF exposure had no effect on plasma melatonin
in adult females. In avian species, melatonin is involved in
body temperature regulation, seasonal metabolism, loco-
motor activity, feeding patterns, migration, and plumage
color changes important for mate selection. Melatonin also
plays a key role in the growth and development of young
birds. The researchers concluded it is likely that the results
are relevant to wild raptors nesting within EMF exposures.

In 2000 Fernie et al. [265] focused on reproductive
success in captive American Kestrels exposed to ELF-EMF,
again equivalent to that experienced by wild reproducing
kestrels. Kestrels were bred one season per year for two
years under EMF or controlled conditions. In some years
but not others, EMF-exposed birds showed a weak asso-
ciation with reduced egg laying, higher fertility, larger eggs
with more yolk, albumen, and water, but thinner egg shells
than control eggs. Hatching success was lower in EMF pairs
than control pairs but fledging success was higher than
control pairs in one year. They concluded that EMF expo-
sure such as what kestrels would experience in the wild
was biologically active in a number of ways leading to
reduced hatching success.

Also in 2000, Fernie et al. [266] further investigated
behavioral changes in American Kestrels to ELF-EMF,
again in captive birds comparable to nesting pairs that
commonly use electrical transmission structures for nest-
ing, perching, hunting, and roosting. The amount of EMF
exposure time of wild reproducing American Kestrels was
first determined at between 25 and 75% of the observed
time. On a 24-h basis, estimated EMF exposure in wild
species ranged from 71% during courtship, to 90% during
incubation. Then effects of EMFs on the behavior of captive
reproducing kestrels were examined at comparable expo-
sures of 88% of a 24-h period. Additionally, captive kestrels
were exposed to EMF levels experienced by wild kestrels
nesting under 735-kV power lines. There appeared to be a
stimulatory/stress effect. Captive EMF females were more
active, more alert, and perched on the pen roof more
frequently than control females during courtship. EMF fe-
males preened and rested less often during brood rearing.
EMF-exposed male kestrels were more active than control
males during courtship and more alert during incubation.
The researchers concluded that the increased activity of
kestrels during courtship may be linked to changes in


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Levitt et al.: EMF and wildlife — 23

corticosterone, but not to melatonin as found in earlier
work [264], but said the behavioral changes observed were
unlikely to result in previously reported effects in
EMF-exposed birds as noted above. They added that
behavioral changes of captive EMF-exposed kestrels may
also be observed in wild kestrels, with uncertain results.

In 2001 Fernie and Bird [267] looked at ELF-EMF
oxidative stress levels in captive American Kestrels using
the same test parameters described above to see if ELF-EMF
exposure elicited an immune system response. In captive
male kestrels bred under control or EMF conditions
equivalent to those experienced by wild kestrels, short-
term EMF exposure (one breeding season) suppressed
plasma total proteins, hematocrits, and carotenoids in the
first half of the breeding season. It also suppressed eryth-
rocyte cells and lymphocyte proportions, but elevated
granulosa proportions at the end of the breeding season.
Long-term EMF exposure (two breeding seasons) also
suppressed hematocrits in the first half of the reproductive
period. But results found that only short-term
EMF-exposed birds experienced an immune response,
particularly during the early half of the breeding season.
The elevation of granulocytes and the suppression of ca-
rotenoids, total proteins, and melatonin [264] in the same
kestrel species indicated that the short-term EMF-exposed
male kestrels had higher levels of oxidative stress due to an
immune response and/or EMF exposure. The researchers
noted that long-term EMF exposure maybe linked to higher
levels of oxidative stress solely through EMF exposure.
Oxidative stress contributes to cancer, neurodegenerative
diseases, and immune disorders. And in 2005, Fernie and
Reynolds [268] noted most studies of birds and EMF indi-
cate changes on behavior, reproductive success, growth
and development, physiology and endocrinology, and
oxidative stress — with effects not always consistent or in
the same direction under EMF conditions. The entire body
of work by this research group has implications for all wild
species that encounter a wide range of EMFs on a regular
basis.

In field studies on wild birds in Spain, Balmori [269]
found strong negative correlations between low levels of
microwave radiation and bird breeding, nesting, roosting
and survival in the vicinity of communication towers. He
documented nest and site abandonment, plumage deteri-
oration, locomotion problems, and death in Wood Stories
(Mycteria americana), House Sparrows (Passer domes-
ticus), Rock Doves (Columba livia), Magpies (Pica pica),
Collared Doves (Streptopelia decaocto), and other species.
While these species had historically been documented to
roost and nest in these areas, Balmori [269] did not observe
these symptoms prior to construction and operation of the

cell phone towers. Results were most strongly negatively
correlated with proximity to antennas and Stork nesting
and survival. Twelve nests (40% of his study sample) were
located within 656 ft (200 m) of the antennas and never
successfully raised any chicks, while only one nest (3.3%),
located further than 984 ft (300 m) never had chicks.
Strange behaviors were observed at Stork nesting sites
within 328 ft (100 m) of one or several cell tower antennas.
Birds impacted directly by the main transmission lobe
(i.e., electric field intensity > 2 V/m) included young that
died from unknown causes. Within 100 m, paired adults
frequently fought over nest construction sticks and failed
to advance nest construction (sticks fell to the ground).
Balmori further reported that some nests were never
completed and that Stories remained passively in front of
cell site antennas. The electric field intensity was higher on
nests within 200 m (2.36 ฑ 0.82 V/m; 1.48 (iW/cm2) than on
nests further than 300 m (0.53 ฑ 0.82 V/m, 0.074 (iW/cm2).
RF-EMF levels, including for nests <100 m from the an-
tennas, were not intense enough to be classified as thermal
exposures. Power densities need to be at least 10 mW/cm2
to produce tissue heating of even 0.5 ฐC [270]. Balmori's
results indicated that RFR could potentially affect one or
more reproductive stages, including nest construction,
number of eggs produced, embryonic development,
hatching and mortality of chicks and young in first-growth
stages.

Balmori and Hallberg [271] and Everaert and Bauwens
[272] found similar strong negative correlations among
male House Sparrows (Passer domestics) throughout mul-
tiple sites in Spain and Belgium associated with ambient
RFR between 1 MHz and 3 GHz at various proximities to
GSM cell base stations. House Sparrow declines in Europe
have been gradual but cumulative for this species once
historically well adapted to urban environments. The
sharpest bird density declines were in male House Spar-
rows in relatively high electric fields near base stations,
indicating that long-term exposure at higher RFR levels
negatively affected both abundance and/or behavior of
wild House Sparrows. In another review, Balmori [25] re-
ported health effects to birds that were continuously irra-
diated. They suffered long-term effects that included
reduced territorial defense posturing, deterioration of bird
health, problems with reproduction, and reduction of
useful territories due to habitat deterioration.

Birds have been observed avoiding areas with high
and low-intensity EMF, in daylight as well as nocturnally.
An early study by Southern in 1975 [273] observed that gull
chicks reacted to the U.S. military's Project Sanguin ELF
transmitter. Tested on clear days in the normal geomag-
netic field, birds showed significant clustering with


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24 — Levitt et al.: EMF and wildlife

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predicted bearing corresponding with migration direction,
but when the large antenna was energized they dispersed
randomly. He concluded that magnetic fields associated
with such conductors were sufficient to disorient birds.
Larkin and Sutherland [274] observed that radar tracking of
individual nocturnal migrating birds flying over a large
alternating-current antenna system caused birds to turn or
change altitude more frequently when the antenna system
was operating than when it was not. The results suggested
that birds sense low-intensity alternating-current EMF
during nocturnal migratory flight.

In a well-designed, multi-year avian study of magneto-
disruption, Engels et al. [213] investigated environmental
broadband electromagnetic 'noise' emitted everywhere
humans use electronics, including devices and infra-
structure. They found migratory birds were unable to use
their magnetic compass in the presence of a typical urban
environment today. European Robins (E. rubecula),
exposed to the background electromagnetic 'noise' present
in unscreened wooden huts at the University of Oldenburg
campus, could not orient using their magnetic compass.
But when placed in electrically grounded aluminum-
screened huts, creating Faraday cages that attenuated
electromagnetic 'noise' by approximately two orders of
magnitude, their magnetic orientation returned. The re-
searchers were able to determine the frequency range from
50 kHz to 5 MHz was the most disruptive. When grounding
was removed, or additional broadband electromagnetic
'noise' was deliberately generated inside the screened and
grounded huts, birds again lost magnetic orientation
abilities. They concluded that RFR's magneto-disruption
effects are not confined to a narrow frequency band. Birds
tested far from sources of EMFs required no screening to
orient with their magnetic compass. This work documented
a reproducible effect of anthropogenic electromagnetic
ambient 'noise' on the behavior of an intact vertebrate. The
magnetic compass is integral to bird movement and
migration. The findings clearly demonstrated a nonthermal
effect on European Robins and serves as a predictor for
effects to other migratory birds, especially those flying over
urban areas. Such fields are much weaker than minimum
levels expected to produce any effects and far below any
exposure standards.

Intensity windows in different species have also been
found where effects can be more extreme at lower in-
tensities than at higher ones due to compensatory mech-
anisms such as cell apotosis. Panagopoulos and Margaritas
[34] found an unexpected intensity window at thermal
levels around 10 mW/cm2 RFR — not uncommon near cell
towers — where effects were more severe than at intensities
higher than 200 mW/cm2. This window appeared at a

distance of 8-12 in (20-30 cm) from a cell phone antenna,
corresponding to a distance of about 66-98 ft (20-30 m)
from a base station antenna. This could be considered a
classic nonlinear effect and would apply to far-field expo-
sures. Since cell base station antennas are frequently
located within residential areas where birds nest, often at
distances 20-30 m from such antennas, migratory birds,
non-migratory avifauna, and other wildlife may be
exposed up to 24-h per day.

Concerns also apply to impacts from commercial radio
signals on migratory birds. The human anatomy is reso-
nant with the FM bands so exposure standards are most
stringent in that range. High intensity (>6,000 W) com-
mercial FM transmitters are typically located on the highest
ground available to blanket a wider area. Low powered FM
transmitters (<1,000 W) can be placed closer to the human
population. High intensity locations, which can be multi-
transmitter sites (colloquially called "antenna farms") for
other services, also provide convenient perches and nest
sites for migratory birds. FM digital signals, which simulate
pulsed waves, pose additional health concerns to migra-
tory birds. This creates a dangerous frequency potential for
protected migratory birds such as Bald Eagles with wing-
spans that extend to about 6 ft (1.83 m) — a resonant match
with the length of the FM signal — creating a potential full-
body resonant effect for both humans and Bald Eagles.
Birds could experience both thermal and non-thermal
effects.

All migratory birds are potentially at risk, including
Bald Eagles, Golden Eagles, birds of conservation concern
[275], federal and/or state-listed bird species, birds na-
tionally or regionally in peril, as well as birds whose pop-
ulations are stable. Sadly, addressing these concerns —
beginning with independent research conducted by sci-
entists with no vested interest in the outcomes — has not
been a priority for government agencies or the communi-
cations industry.

Insects and arachnids

Insects are the most abundant and diverse of all animal
groups, with more than one million described species
representing more than half of all known living species,
and potentially millions more yet to be discovered and
identified. They may represent as much as 90% of all life
forms on Earth. Though some are considered pests to farm
crops and others as disease vectors, insects remain
essential to life and planetary health. Found in nearly all
environments, they are the only invertebrates that fly, but
adults of most insect species walk, while some swim.


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Levitt et al.: EMF and wildlife — 25

Because of these different environmental adaptations,
different species will encounter different EMF exposures in
varying degrees. For instance, ground-based walking in-
sects may be more susceptible to effects from 60 Hz stray
current while flying insects may be more susceptible to
wireless exposures. However, all species tested have been
affected across a range of the nonionizing electromagnetic
bands.

Most insects have an exoskeleton, three-part body
consisting of a head, thorax, and abdomen, three pairs of
jointed legs, compound eye structures capable to seeing
many more colors, widths, and images than humans, and
one pair of antennae capable of sensing subtle meteoro-
logical changes and Earth's geomagnetic fields. They live
in close harmony with the natural environment for survival
and mating purposes. The most diverse insect groups co-
evolved with flowering plants, many of which would not
survive without them. Most insect species are highly sen-
sitive to temperature variations and climate alterations as
they do not dissipate heat efficiently.

Nearly all insects hatch from eggs that are laid in
myriad ways and habitats. Growth involves a series of
molts and stages (called instars) with immature stages
greatly differing from mature insects in appearance,
behavior, and preferred habitat. Some undergo a four-
stage metamorphosis (with a pupal stage) and others a
three-stage metamorphosis through a series of nyphal
stages.

While most insects are solitary, some — like bees,
termites and ants — evolved into social networks, living in
"cooperative" organized colonies that can function as one
unit as evidenced in swarming behaviors. Some even show
maternal care over eggs and young. They communicate
through various sounds, pheromones, light signals, and
through their antennae such as during the bees' "waggle
dance" (see below).

As far back as the 1800s, even though testing methods
were primitive by today's standards, researchers were
curious about electromagnetism's effect on insect devel-
opment, particularly teratogenicity [276]. Research on EMF
across frequencies and insect populations has been
ongoing since at least the 1930s with an eye toward using
energy as an insecticide and anti-contaminant in grain,
typically at high intensity thermal exposures that would
not exist in the natural environment. Mckinley and Charles
[277] found that wasps die within seconds of high fre-
quency exposure. But not all early work was strictly high
intensity, or all effects observed due to thermal factors.

There were interesting theories introduced by early
researchers regarding how energy couples with various
insect species. Frings [278] found larval stages are more

tolerant to heat than adult insects with appendages that
can act as conducting pathways to the body, and that the
more specialized the insect species, the more susceptible
they appear to microwave exposure. Carpenter and Liv-
ingstone [279] studied effects of 10 GHz continuous-wave
microwaves at 80 mW/cm2 for 20 or 30 min, or at 20 mW/
cm2 for 120 min on pupae of mealworm beetles (Tenebrio
molitor) — clearly within thermal ranges. In control groups,
90% metamorphosed into normal adult beetles whereas
only 24% of exposed groups developed normally, 25%
died, and 51% developed abnormally. Effects were
assumed to be thermally induced abnormalities until they
simulated the same temperature exposure using radiant
heat and found 80% of pupae developed normally. They
concluded that microwaves were capable of inducing
abnormal effects other than through thermal damage.

Fruit flies

Insects at all metamorphic stages of development have
been studied using RFR including egg, larva, pupa and
adult stages. Much work has been done on genetic and
other effects with fruit flies (D. melanogaster) because of
their well-described genetic system, ease of exposure, large
brood size, minimal laboratory space needed, and fast
reproductive rates. Over several decades Goodman and
Blank, using ELF-EMF on Drosophila models, found effects
to heat shock proteins and several other effects ([201]; and
see "Mechanisms" above). It is considered a model com-
parable to other insects in the wild approximating that size.
D. melanogaster may be the most lab-studied insect on
Earth, although honey and related bee species, due to their
devastating losses over the last decade and significance to
agriculture, are quickly catching up.

Michaelson and Lin [50] noted that RFR-exposed in-
sects first react by attempting to escape, followed by
disturbance of motor coordination, stiffening, immobility
and eventually death, depending on duration of exposure
and insect type. For example, D. melanogaster survived
longer than 30 min while certain tropical insects live only a
few seconds at the same field intensity. Also noted were
concentration changes in many metabolic products and
effects to embryogenesis — the period needed for a but-
terfly to complete metamorphosis — with accelerated
gastrulation and larval growth [17]. Michaelson and Lin
[50] cited several negative studies with D. melanogaster
exposed with continuous-wave RFR between 25 and
2,450 MHz on larval growth [280, 281] and mutagenicity
[282]. This was after Heller and Mickey [283] found a tenfold
rise in sex-linked recessive mutations with pulsed RFR


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26 — Levitt et al.: EMF and wildlife

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between 30 and 60 MHz. It was among the earliest studies
that found pulsing alone to be a biologically active
exposure.

As reported in Michaelson and Lin [50], Tell [284]
looked at D. melanogaster's physiological absorption
properties and found that a group of 6-day old male wild-
type flies, exposed to 2,450 MHz for 55 min at an intense
field caused a dramatic 65% reduction in body weight. This
was thought to be from dehydration. They then sought to
calculate the fruit fly's absorption properties in relation to
plane electromagnetic waves and found that a fly has only
a 1/1,000th effective area of its geometric cross section and
thus is an inefficient test species for absorbed microwave
radiation. However, they concluded that fruit flies were
responsive to absorbed energy at thermal levels as a black
body resonator at a power density of 1.044 x 104 mW/cm2,
corresponding to a thermal flux density of 0.562 x 10 3 cal.
These are levels found in close proximity to broadcast fa-
cilities and cell phone towers today.

More recent investigations of RFR by Weisbrot et al.
[285] using GSM multiband mobile phones (900/
1,900 MHz; SAR approximately 1.4 W/kg) on D. mela-
nogaster during the 10-day developmental period from egg
laying through pupation found that non-thermal radiation
increased numbers of offspring, elevated heat shock
protein-70 levels, increased serum response element (SRE)
DNA-binding and induced the phosphorylation of the nu-
clear transcription factor, ELK-1. Within minutes, there was
a rapid increase of hsp70, which was apparently not a
thermal effect. Taken together with the identified compo-
nents of signal transduction pathways, the researchers
concluded the study provided sensitive and reliable bio-
markers for realistic RFR safety guidelines.

Panagopoulos et al. [286] found severe effects in early
and mid-stage oogenesis in D. melanogaster when flies
were exposed in vivo to either GSM 900-MHz or DCS
1,800-MHz radiation from a common digital cell phone, at
non-thermal levels, for a few minutes per day during the
first 6 days of adult life. Results suggested that the decrease
in oviposition previously reported [287-289] was due to
degeneration of large numbers of egg chambers after DNA
fragmentation of their constituent cells which was induced
by both types of mobile phone radiation. Induced cell
death was recorded for the first time in all types of cells
constituting an egg chamber (follicle cells, nurse cells and
the oocyte) and in all stages of early and mid-oogenesis,
from germarium to stage 10, during which programmed
cell death does not physiologically occur. Germarium and
stages 7-8 were found to also be the most sensitive
developmental stages in response to electromagnetic stress
induced by the GSM and DCS fields. Germarium was also

found to be more sensitive than stages 7-8. These papers,
taken collectively, indicate serious potential effects to all
insect species of similar size to fruit flies from cell phone
technology, including from infrastructure and transmitting
devices.

Fruit flies have also been found sensitive to ELF-EMF.
Gonet et al. [290] found 50 Hz ELF-EMF exposure affected
all developmental stages of oviposition and development
of D. melanogaster females, and weakened oviposition in
subsequent generations.

Savic et al. [291] found static magnetic fields influenced
both development and viability in two species of
Drosophila (D. melanogaster and D. hydei). Both species
completed development (egg-to-adult), in and out of the
static magnetic field induced by a double horseshoe mag-
net. Treated vials with eggs were placed in the gap between
magnetic poles (47 mm) and exposed to the average mag-
netic induction of 60 mT, while control groups were kept
far from the magnetic field source. They found that expo-
sure to the static magnetic field reduced development time
in both species, but only results for D. hydei were statisti-
cally significant. In addition, the average viability of both
species was significantly weaker compared to controls.
They concluded a 60 mT static magnetic field could be a
potential stressor, influencing on different levels both
embryonic and post-embryonic fruit fly development.

Beetles

Other insect species also react to both ELF-EMF and
RF-EMF. Newland et al. [292] found behavioral avoidance
in cockroaches (Periplaneta americana) to static electric
fields pervasive in the environment from both natural and
man-made sources. Such fields could exist near powerlines
or where utilities ground neutral lines into the Earth. They
found insect behavioral changes in response to electric
fields as tested with a Y-choice chamber with an electric
field generated in one arm of the chamber. Locomotor
behavior and avoidance were affected by the magnitude of
the electric fields with up to 85% of individuals avoiding
the charged arm when the static e-field at the entrance to
the arm was above 8-10 kV/m. Seeking to determine
mechanisms of perception and interaction, they then sur-
gically ablated the antennae and cockroaches were unable
to avoid electric fields. They concluded that antennae are
crucial in cockroach detection of electric fields that thereby
helps them avoid such fields. They also noted that cock-
roach ability to detect e-fields is due to long antennae
which are easily charged and displaced by such fields, not
because of a specialized detection system. This leads to the


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Levitt et al.: EMF and wildlife — 27

possibility that other insects may also respond to electric
fields via antennae alone.

Vacha et al. [208] found that cockroaches (P. americana)
were sensitive to weak RFR fields and that the Larmor fre-
quency at 1.2 MHz in particular had a "deafening effect" on
magnetoreception. The parameter they studied was the in-
crease in locomotor activity of cockroaches induced by peri-
odic changes in geomagnetic North positions by 60ฐ. The
onset of the disruptive effect of a 1.2 MHz field was found
between 12 and 18 nT whereas the threshold of a field twice
the frequency (2.4 MHz) fell between 18 and 44 nT. A 7 MHz
field showed no significant effect even at maximal of 44 nT.
The results suggested resonance effects and that insects may
be equipped with the same magnetoreception system
as birds.

Prolic et al. [293] investigated changes in behavior via
the nervous system of cerambycid beetles (Morimus fune-
reus) in an open field before and after exposure to a 50 Hz
ELF-MF at 2 mT. Experimental groups were divided into
several activity categories. Results showed activity
increased in the groups with medium and low motor ac-
tivity, but decreased in highly active individuals. High in-
dividual variability was found in the experimental groups,
as well as differences in motor activities between the sexes
both before and after exposure to ELF-MF. They assumed
activity changes in both sexes were due to exposure to ELF-
MF. Only a detailed analysis of the locomotor activity at 1-
min intervals showed some statistically significant differ-
ences in behavior between the sexes.

Ants

Ants are another taxa found sensitive to EMF. Ants comprise
between 15 and 25% of the terrestrial animal biomass and
thrive in most ecosystems on almost every landmass on
Earth. By comparison, the total estimated biomass (weight) of
all ants worldwide equates to the total estimated biomass of
all humans. Their complex social organization in colonies,
with problem-solving abilities, division of labor, and both
individual and whole colony communication via complex
behavioral and pheromone signaling may account for their
success in so many environments. Some ant species (e.g.,
Formica rufa-group) are known to build colonies on active
earthquake faults and have been found to change behavior
hours in advance of earthquakes [294], thus demonstrating
predictive possibilities. Ants can modify habitats, influence
broad nutrient cycling, spread seeds, tap resources, and
defend themselves. Ants co-evolved with other species which
led to many different kinds of mutual beneficial and antag-
onistic relationships.

Ants (e.g., Solenopsis invictus) are long known to be
sensitive to magnetic fields both natural and manmade
[295]. Ants (e.g., Atta colombica), like birds, have been
found to be sensitive to the Earth's natural fields and to use
both a solar compass on sunny days as well as a magnetic
compass when there is cloud cover [296]. Jander and Jander
[297] similarly found that the weaver ant (Oecophylla sppj
had a more efficient light compass orientation with a much
less efficient magnetic compass orientation, suggesting
that they switch from the former to the latter when visual
celestial compass cues become unavailable. There is evi-
dence from Esquivel et al. [298] that such magneto-
reception is due to the presence of varying sized magnetite
particles and paramagnetic resonance in fire ants (Sol-
enopsis spp). But Riveros and Srygley [299] found a more
complex relationship toward a magnetic compass rather
than the presence of magnetite alone when leafcutter ants
(Atta columbica) were subjected to a brief but strong
magnetic pulse which caused complete disorientation
regarding nest-finding. They found external exposures
could interfere with ants' natural magnetic compass in
home path integration, which indicated evidence of a
compass based on multi-domain and/or super-
paramagnetic particles rather than on single-domain par-
ticles like magnetite.

Acosta-Avalos et al. [300] found that fire ants are
sensitive to 60 Hz alternating magnetic fields as well as
constant magnetic fields, changing their magnetic orien-
tation and magnetosensitivity depending on the relation
between both types of magnetic fields. Alternating current
had the ability to disrupt ant orientation, raising the
question of effects to wild species from underground wir-
ing and the common practice of powerline utility com-
panies using the Earth as a neutral return pathway to
substations, creating stray current along the way [99].

Camelitepe et al. [301] tested black-meadow ants'
(Formica pratensis) response under both natural geomag-
netic and artificial earth-strength static EMFs (24.5 (iT).
They found that under the natural geomagnetic field, when
all other orientational cues were eliminated, there was
significant heterogeneity of ant distribution with the ma-
jority seeking geomagnetic north in darkness while under
light conditions ants did not discriminate geomagnetic
north. Under artificial EMF exposure, however, ant orien-
tation was predominantly on the artificial magnetic N/S
axis with significant preference for artificial north in both
light and dark conditions. This indicated EMF abilities to
alter ant orientation.

Ants are also shown to react to RFR [302, 303]. Cam-
maerts et al. [304] found that exposures to GSM 900 MHz at
0.0795 (iW/cm2 significantly inhibited memory and


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28 — Levitt et al.: EMF and wildlife

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association between food sites and visual and olfactory
cues in ants (Myrmica sabuleti) and eventually wiped out
memory altogether. Subsequent exposure, after a brief re-
covery period, accelerated memory/olfactory loss within a
few hours vs. a few days, indicating a cumulative effect
even at very low intensity. The overall state of the exposed
ant colonies eventually appeared similar to that exhibited
by honey bee (Apis mellifera) colony collapse disorder.
Although the impact of GSM 900 MHz radiation was greater
on the visual memory than on the olfactory memory, the
researchers concluded that such exposures — common to
cell phones/towers — were capable of a disastrous impact
on a wide range of insects using olfactory and/or visual
memory, including bees. Many ant species (e.g., Lasius
neglectus, Nylanderia fulva, Camponotus spp, Hymenoptera
formicidae, Solenopsis invicta, among others) are attracted
to electricity, electronic devices, and powerlines, thereby
causing short circuits and fires. One hypothesis [305] is that
the accumulation of ants in electrical equipment may be
due to a few foraging "worker ants" seeking warmth and
finding their way into small spaces, completing electrical
contacts which then causes a release of alarm exocrine
gland pheromones that attract other ants, which then go
through the same cycle. In their study, they found that
workers subjected to a 120 V alternating-current released
venom alkaloids, alarm pheromones and recruitment
pheromones that elicited both attraction and orientation in
ants as well as some other unknown behavior-modifying
substances. But given how ants are affected by EMFs in
general it is likely that an attractant factor is also involved,
not just warmth and small spaces.

There is evidence that ants use their antennae as
"antennas" in two-way electrochemical communications.
Over 100 hundred years ago, Swiss researcher Auguste
Forel [306] removed the antennae of different species of
ants and put them together in one place. What would have
normally evoked aggressive behaviors among the different
species did not occur and they got along as if belonging to
the same colony. To Forel this indicated an ability of ant
antennae to help different ant species identify each other.

Two mechanisms in ants have long been known for
chemical receptivity as well as electromagnetic sensitivity.
Recently Wang et al. [307] found evidence that chemical
signals located specific to antennae vs. other body areas
drew more attention from non-nest mates. When cuticular
hydrocarbons (CHCs) were removed by a solvent from
antennae, non-nest mates responded less aggressively
than to other areas of the body, indicating that antennae
reveal nest-mate identity, conveying and receiving social
signals. Regarding magnetoreception, magnetic measure-
ments [308-310] found the presence of biogenic magnetite

was concentrated in antennae and other body parts of the
ant Pachycondyla marginata. De Oliveira et al. [311] also
found evidence of magnetite and other magnetic materials
imbedded in various locations of antennae tissue in
P. marginata indicating that antennae function as magne-
toreceptors. The amount of magnetic material appeared
sufficient to produce a magnetic-field-modulated mecha-
nosensory output and therefore demonstrated a magneto-
reception/transduction sense in migratory ants.

Ticks

Ticks are members of the order Arachnida, shared with
scorpions and spiders. Recent papers in a tick species
(Dermacentor reticulates) mirrors an attraction to some
frequencies but not others. Vargova et al. [312, 313] found
that exposure to RFR may be a potential factor altering both
presence and distribution of ticks in the environment.
Studies were conducted to determine potential affinity of
ticks for RFR using radiation-shielded tubes (RST) under
controlled conditions in an electromagnetic compatibility
laboratory in an anechoic chamber. Ticks were irradiated
using a Double-Ridged Waveguide Horn Antenna to RF-EMF
at 900 and 5,000 MHz; 0 MHz served as control. Results
found that 900 MHz RFR induced a higher concentration of
ticks on the irradiated arm of RST whereas at 5,000 MHz ticks
escaped to the shielded arm. In addition, 900 MHz RFR had
been shown to cause unusual specific sudden tick move-
ments during exposure manifested as body or leg jerking
[312]. These studies are the first experimental evidence of RFR
preference and behavioral changes in D. reticulates with im-
plications for RFR introduced into the natural environment by
devices and infrastructure. In a further study, Frqtczak et al.
[314] reported that Ixodes ricinus ticks were attracted to
900 MHz RFR at 0.1 (iW/cm2, particularly those infected with
Rickettsia (spotted fever).

RFR may be a new factor in tick distribution, along
with known factors like humidity, temperature and host
presence, causing concentrated non-homogenous or
mosaic tick distribution in natural habitats. Tick preference
for 900 MHz frequencies common to most cell phones has
possibly important ecological and epidemiological conse-
quences. Increasing exposures from use of personal de-
vices and infrastructure in natural habitats where ticks
occur may increase both tick infestation and disease
transmission. Further studies need to investigate this work,
given the ubiquity of ticks today, their northward spread
due to climate change in the Northern Hemisphere, and the
increasing and sometimes life-threatening illnesses they
transmit to humans, pets, and wildlife alike.


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Levitt et al.: EMF and wildlife — 29

Monarch butterflies

The American Monarch butterfly (D. plexippus) has fasci-
nated researchers for over 100 years as it is the only insect
known to migrate in multi-generational stages [315-319],
with the ability to find their exact birthplace on specific
milkweed plants (Asclepias spp.) at great distances across
land and oceans.

Monarchs (D. plexippus), found across Southern Can-
ada, the United States, and South America, are generally
divided by the Rocky Mountains into eastern and western
migratory groups. Their population has precipitously
declined by 99.4% since the 1980s (85% of that since 2017)
and by 90% in the past two decades in both western and
eastern populations [13,15]. These steep declines are from
numerous anthropogenic causes and may have already
crossed extinction thresholds, thereby leaving us bereft not
only of their beauty and inspiration, but also the perfect
model for long-distance animal migration study in general.

Monarch butterflies are among North America's most
beloved invertebrates. They have for centuries navigated
thousands of miles/kilometers in an iconic fall migration
from southern Canada and the mid- and northeastern U.S.
to a small area of about 800 square miles (2,072 square
kilometers) in Central Mexico where they once wintered
over in the millions in small remote oyamel fir forests. By
the time they reach their final destination, some will have
traveled distances exceeded only by some migratory
seabird species. The monarch is the only insect known to
migrate annually over 3,000 miles (4,828 km) at ~ 250 miles
(402 km) per day in the fall from the Canadian border to
Mexico, and in the springtime back again. Similar to some
bird species, it is the only butterfly known to have a two-
way migration pattern. Monarchs are only followed by
army cutworm moths (Euxoa auxiliaris) which may migrate
several thousand kilometers to high elevation sites in the
Rocky Mountains to escape lowland heat and drought.

But monarchs are more interesting than for this one
amazing migrational feat alone. How they do this is a long-
standing mystery since their entire lifecycle, including
their two-stage spring return migration, is multi-
generational indicating genetic factors in directional
mapping since the final return fall migration south cannot
be considered "learned." Several multifaceted mecha-
nisms must come into play, as well as little understood
complexities in how those mechanisms cooperate and
trade off with each other under different environmental
circumstances. Monarchs also go from solitary insects
during early developmental stages confined to specific
locations, then exhibit social insect behaviors after the
third generation has reached northern latitudes and turned

south during the final fall migration. And all of this hap-
pens in a brain the size of a grain of sand.

Reppert et al. [320] published an excellent review in
2010 on the complexities of monarch migration, noting "...
recent studies of the fall migration have illuminated the
mechanisms behind the navigation south, using a time-
compensated sun compass. Skylight cues, such as the sun
itself and polarized light, are processed through both eyes
and likely integrated in the brain's central complex, the
presumed site of the sun compass. Time compensation is
provided by circadian clocks that have a distinctive molecular
mechanism and that reside in the antennae. Monarchs may
also use a magnetic compass, because they possess two
cryptochromes that have the molecular capability for light-
dependent magnetoreception. Multiple genomic approaches
are being utilized to ultimately identify navigation genes.
Monarch butterflies are thus emerging as an excellent model
organism to study the molecular and neural basis of long-
distance migration." Reppert and de Roode [321] updated that
information in 2018.

Although it has been known for some time that mon-
archs use a circadian rhythm time-compensated direc-
tional sun compass [316,322-338], many questions remain
about its dynamics and concerns regarding effects from
radiation.

Monarch antennae are known to contain magnetite
[339, 340] and cryptochromes [335, 336, 341, 342] — both
understood to play a role in magnetoreception (see
"Mechanisms"above). One early study by Jones and Mac-
Fadden [343] found magnetic materials located primarily
in the head and thorax areas of dissected monarchs. More
recently, Guerra et al. [16] found convincing evidence that
monarchs use a magnetic compass to aid their longest fall
migration back to Mexico. Those researchers used flight
simulator studies to show that migrants possess an incli-
nation magnetic compass to assist fall migration toward
the equator. They found this inclination compass is light-
dependent, utilizing ultraviolet-A/blue light between 380
and 420 nm and noted that the significance of light
(<420 nm) for an inclination compass function had not
been considered in previous monarch studies. They also
noted that antennae are important for an inclination
compass since they contain light-sensitive magneto-
sensors. Like some migratory birds, the presence of an
inclination compass would serve as an orientation mech-
anism when directional daylight cues are impeded by
cloudy or inclement weather or during nighttime flight. It
may also augment time-compensated sun compass orien-
tation for appropriate directionality throughout migration.
The inclination compass was found to function at earth-
strength magnetic fields, an important metric.


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30 — Levitt et al.: EMF and wildlife

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The question remains: Can the magnetic compass in
monarchs be disrupted by anthropogenic EMF like it does
with geomagnetic orientation in migratory birds [213]. There is
some indication this is possible. Perez et al. [330] found
monarchs completely disorient after exposure to a strong
magnetic field (0.4-T MF for 10 s, or approximately 15,000
times the Earth's magnetic field) immediately before release
vs. controls. This is a high exposure but within range of man-
made exposures today very close to powerlines.

Bees, wasps, and others

Pollinators, bees in particular, are keystone species
without which adverse effects would occur throughout
food webs and the Earth's entire biome were pollinators to
disappear. Because of their central role and accessibility
for research, bee studies have created a wealth of infor-
mation, including regarding anthropogenic EMFs.

Bees — especially honey and bumble bees — are
another iconic insect species beloved for their role in
pollination; honey, propolis, royal jelly and beeswax pro-
duction; their critical importance to our food supply; and
their crucial role in global ecological health and stability.
Found on every continent except Anarctica wherever there
are flowering plants requiring insect pollination, there are
over 16,000 known species of bees in seven different bio-
logical families, consisting of four main branches. Some
species live socially in colonies while others are solitary.
The western honey bee (Apis mellifera) is the best known
and most studied due in part to its central role in agricul-
ture. Bees feed on nectar for energy and pollen for protein/
nutrients, and have co-evolved with many plant species in
astoundingly complex ways. They are also highly sensitive
to both natural and anthropogenic EMFs. Beeswax itself
has electrical properties [50].

Human apiculture has been practiced since the time of
ancient Egyptian and Greek cultures and bees have been
closely studied since the 1800s. Almost all bee species,
including commercially raised and wild species, are under
decades-long multiple assaults. These include from pesti-
cides, herbicides, climate change, various bacterial/viral
diseases, infestations from parasitic mite species —
particularly Apis cerana, Varroa destructor and Varroa
jacobsoni beginning in the mid-1980s — and predation
from introduced species that attack bees directly (e.g., the
invasive giant bee-eating hornet Vespa mandarinia), as
well as alter plant ecology over time to adversely affect bee
food supply. Some have suggested that vanishing bees may
also have to do with premature aging due to environmen-
tally caused shortened telomeres [344].

Whole colony collapse disorder (CCD) is the most
dramatic manifestation of domesticated bee demise in
which worker bees abruptly disappear from a hive without
a trace, resulting in an empty hive with perhaps a
remaining queen and a few worker bees despite ample
resources left behind. Few, if any, dead bees are ever found
near the hive. CCD was first described in the U.S. in 2006 in
Florida in commercial western honey bee colonies. Van
Englesdorp et al. [345] quantified bee losses across all
beekeeping operations and estimated that between 0.75
and 1.00 million honey bee colonies died in the United
States over the winter of 2007-2008. Up until that survey,
estimates of honey bee population decline had not
included losses occurring during the wintering period,
thus underestimating actual colony mortality.

The same phenomenon had been described by bee-
keepers in France in 1994 [346] — later attributed to the
timing of sunflower blooming and the use of imidacloprid
(IMD), a chlorinated nicotine-based insecticide or "neon-
icotinoid" being applied to sunflowers for the first time there
[347]. Similar to DDT but considered safer for mammals
including humans, neonicotinoids are a slow-release class of
neurotoxins that block insect nervous systems via acetyl-
choline receptors, interfering with neuronal signaling across
synapses. Sublethal doses can interfere with bee navigation.

Since then similar phenomena have been seen
throughout Europe [348] and some Asian countries. Causal
hypotheses included all of the above factors with varying
foci on pesticide classes like neonicotinoids and geneti-
cally modified crops, but no single agent adequately ex-
plains CCD. Bromenshenk et al. [349] however, identified
pathogen pairing/co-infection with two previously unre-
ported RNA viruses — V. destructor-1, and Kakugo viruses,
and a new irridescent virus (IIV) (Iridoviridae) along with
Nosema ceranae — in North American honeybees that were
associated with all sampled CCD colonies. The pathogen
pairing was not seen in non-CCD colonies. Later cage trials
with IIV type-6 and N. ceranae confirmed that co-infection
with those two pathogens was more lethal to bees than
either pathogen alone. Still many questions remain.

There are two national surveying groups in the U.S. —
the U.S. Department of Agriculture (USDA) which began
surveying managed bee populations in 2015 but funding
was cut in late 2019; and the Bee Informed Partnership
(BIP), a non-profit that coordinates with research facilities
and universities. Prior to USDA's funding cuts, managed
colonies decreased from CCD by 40% [350] with an addi-
tional 26% over the same quarter in 2019 [351]. BIP's survey
period for April 1, 2018 through April 1, 2019 found U.S.
beekeepers lost an estimated 40.7% of their managed
honey bee colonies. The previous year had similar annual


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Levitt et al.: EMF and wildlife — 31

losses of 40.1%. The average annual rate of loss reported by
beekeepers since 2010-11 was 37.8% [352].

Also in the U.S., for the first time in 2016, seven species of
Hawaiian yellow-faced bees (Hylaeus anthracinus,
Hylaeus longiceps, Hylaeus assimulans, Hylaeus facilis,
Hylaeus hilaris, Hylaeus kuakea, and Hylaeus mana) were
added to the federal endangered species list, as well as the
rusty patched bumble bee (Bombus affinisi) which, prior to the
late 1990s, had been widely dispersed across 31 U.S. states
[353]. Mathiasson and Rehan [354] examined 119 species in
museum specimens in New Hampshire going back 125 years
and concluded that 14 species found across New England
were on the decline by as much as 90%, including the lesser
studied leafcutter and mining bees that nest in the ground,
unlike honeybees that nest in commercial hives or in trees,
shrubs, and rock crevices in the wild.

Worldwide, many bee and other pollinator pop-
ulations have also declined over the last two decades.
Managed honey bee (Apis mellifera) colonies decreased by
25% over 20 years in Europe and 59% over 58 years in North
America, with many wild bumble bee populations in
Europe and North America having gone locally extinct
[355-358]. But while dramatic range contractions have
been seen, not all bees in all places are declining; some
populations are growing depending on opportunistic and
species-adaptability factors. For many species data are still
insufficient, of poor quality, or nonexistent [359]. In addi-
tion, bee declines can affect flora survival. Miller-
Struttmann et al. [360] recorded flower declines of 60%
with 40 years of climate warming in alpine meadows —
areas largely protected from land-use changes. Insects are
highly sensitive to temperature changes.

A comprehensive UK survey of pollinator species [361]
found that of 353 wild bee and hoverfly species across
Britain from 1980 to 2013, 25% had disappeared from the
places they had inhabited in 1980. Further estimates found
a net loss of over 2.7 million in 0.6 mi (1 km) grid cells across
all species. Declining pollinator evenness suggested losses
were concentrated in rare species. Losses linked to specific
habitats were also identified, with a 55% decline among
wild upland species while dominant crop pollinators
increased by 12%, possibly due to agricultural business
interventions. The general declines found a fundamental
deterioration in both wider biodiversity and non-crop
pollination services.

There is no question that the huge diversity of polli-
nator species across the planet is suffering and that losses
could be catastrophic with an estimated 90% of wild plants
and 30% of world crops in jeopardy [362].

There is a likelihood that rising EMF background levels
play a role. Bees have been known for decades to have an

astute sense of the Earth's DC magnetic fields [363, 364]
and rely on that perception for survival. For centuries
beekeepers had noticed curious movements in bee hives
but Austrian ethologist Karl von Frisch finally interpreted
that activity in the 1940s, winning the Nobel Prize in 1973
for what came to be known as the honey bee "waggle
dance." Through complex circles and waggle patterns,
bees communicate the location of food sources to other
members of the hive, using the orientation of the sun and
the Earth's magnetic fields as a gravity vector, "dancing"
out a map for hive members to follow like nature's own
imbedded GPS. Bees also detect the sun's direction through
polarized light and on overcast days use the Earth's mag-
netic fields, likely through the presence of magnetite in
their abdominal area, and employ complex associative
learning and memory [365].

Building on the earlier work of Gould et al. [119],
Kobayashi and Kirschvink [52] noted that biogenic
magnetite in honey bees is located primarily in the anterior
dorsal abdomen. When small magnetized bits of wire were
glued over those areas, it interfered with bees' ability to
learn to discriminate magnetic anomalies in conditioning
experiments, while nonmagnetized wire used in controls
did not interfere [366]. Kirschvink and Kobayashi [367]
found that when pulse-remagnetization techniques were
used on bees trained to exit from a T-maze, that north-
exiting bees could be converted to a south-exiting direction
similar to what was observed in magnetobacteria and
artificial reorientation by Blakemore [113]. Honeybees
could also be trained to respond to very small changes in
the geomagnetic field intensity [368]. Valkova and Vacha
[369] discussed the possibility that honey bees use a
combination of both radical pair/cryptochromes and
magnetite to detect the geomagnetic field and use it for
direction like many birds.

Given these sensitivities, bees may be reacting nega-
tively through muti-sensory mechanisms to numerous
sources of anthropogenic multi-frequency interference.
Bumble bees (Bombus terrestris), a solitary species, and
honey bees (Apis mellifera), a social hive species, are
known to detect weak electric fields in different behavioral
contexts, using different sensory mechanisms. Bumble bee
e-field detection is likely through mechanosensory hairs
[370-372] while honey bees reportedly use their antennae
[373] that are electro-mechanically coupled to the sur-
rounding e-field, taking place in the antennal Johnston's
organ. Greggers et al. [373] found that honey bee antennae
oscillate under electric field stimulation that can then
stimulate activity in the antennal nerve. The latter occurs
due to bees being electrically charged, and thus subject to
electrostatic forces. Erickson [374] found different surface


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potentials in bees when leaving or entering hives, and
Colin et al. [375] found seasonal variability between posi-
tive and negative charges in resting bees. It has also been
shown that honey bees with removed or fixed antennae are
less able to associate food reward with electric field stimuli
and that bees emanate modulated electric fields when
moving their wings (at about 230 Hz) and body (at about
16.5 Hz) during the waggle dance [373].

Electro-ecological interplay between flowers and
pollinators has also been known since the 1960s and is
critical to pollen transfer from flowers to bees [376-378].
It is known that as bees fly through the air, they accu-
mulate a positive charge. Flowers, on the other hand,
which are electrically grounded through their root sys-
tems, tend to have a negative charge in their petals
created by surrounding air that carries around 100 V for
every meter above ground. The accumulating positive
charge around the flower induces a negative charge in its
petals which then interacts with the positive charge in
bees. In fact, bees do not even need to land on flowers for
pollen transfer to occur; pollen can "jump" from the
flower to the bee as the bee approaches due to charge
differentials between the two. Thus, it appears that bees
and flowers have been "communicating" via electric
fields all along [379]. Bees can also learn color discrimi-
nation tasks faster when color cues are paired with arti-
ficial electric field cues similar to those surrounding
natural flowers, but did not learn as readily in an elec-
trically neutral environment [370].

This evidence points to floral e-fields being used in a
co-evolutionary symbiotic relationship with bees. Clarke
et al. [370, 371] even found that bumblebees can distin-
guish between flowers that give off different electric fields
as floral cues to attract pollinators. Like visual cues, floral
electric fields exhibit complex variations in pattern and
structure that bumblebees can distinguish, contributing to
the myriad complex cues that create a pollinator's memory
of floral food sources. And because floral electric fields
can — and do — change within seconds of being visited by
pollinators, this sensory ability likely facilitates rapid and
dynamic "information exchange" between flowers and
their pollinators. Bumblebees can even amazingly use
electric field information to discriminate between nectar-
rewarding and unrewarding flowers [370].

Bees, locusts: ELF-EMF

Bees are also known to be sensitive to anthropogenic
ELF-EMF. In 1973,Wellenstein [380] found that high ten-
sion powerlines adversely affected honey bees in wooden
hives. This in part prompted the Bonneville Power

Administration, an American federal agency operating in
the Pacific Northwest under the U.S. Department of Energy
(U.S. DOE), to investigate in 1974 [381-384] the effects of
transmission lines on people, plants, and animals,
including honey bees. The industry group, Electric Power
Research Institute, also followed up on bee research [385,
386]. Both of those studies confirmed that transmission line
electric fields can affect honey bees inside wooden hives as
wood is a poor insulator and current can be induced when
hives are placed in electric fields whether metal is present
or not. The strength of the current inside the hive was
influenced by the electric field strength, hive height, and
moisture conditions with effects noticeable when induced
current exceeded 0.02-0.04 mA. Depending on hive
height, this occurred in field strengths between 2 and 4 kV/
m. Effects included increased motor activity with transient
increase in hive temperature, excessive propolis produc-
tion (a resinous material used by bees as a hive sealer),
decreased colony weight gains, increased irritability and
mortality, abnormal production of queen cells, queen loss,
decreased seal brood, and poor over-winter colony survival
[387]. Impacts were most likely caused by electric shocks
inside the hives [386, 388]. Effects were mitigated with
grounded metal screen/shielding of hives [385]; however,
bees appeared unaffected by magnetic fields which
permeate metal shielding. The authors concluded that the
shielding results indicated that bees were unaffected by
flying through an external electric field up to 11 kV/m but
noted that the study design could not reveal if subtle effects
were occurring.

A more recent study of electric fields by Migdal [389]
focused on honey bee behavioral effects on walking,
grooming, flight, stillness, contact between individuals,
and wing movement. They found that the selected fre-
quency, intensity, and duration of exposure effects bees'
behavioral patterns. Bees were exposed for 1, 3 and 6 h to
E-fields at 5.0 kV/m, 11.5 kV/m, 23.0 kV/m, or 34.5 kV/m
(with controls under E-field <2.0 kV/m). Within the
exposed groups, results showed that exposure for 3 h
caused decreased time that bees spent on select behaviors
as well as the frequency of behaviors, whereas after both 1
and 6 h, the behavioral parameters increased within the
groups. The researchers concluded that a barrier allowing
behavioral patterns to normalize for some periods was
indicated although none of the exposed groups returned to
reference values in controls which adhered to normal
behavioral patterns. Bees may have compensatory win-
dows that appear to be both time and intensity dependent
for E-fields. The significance of this study is that bees must
accomplish certain activities — like flight frequency and
the honey bee 'waggle dance' noted above — that are


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Levitt et al.: EMF and wildlife — 33

critical for life expectancy and survival. Even slight
sequential disturbances may have cascading effects.

In an early-1988 study, Korall et al. [390] also found
effects to bees from magnetic fields (MF). Bursts compa-
rable to some of today's pulsed exposures of artificial MF at
250 Hz — the frequency of buzzing during the waggle
dance — were applied parallel to natural EMF field lines
and induced unequivocal 'jumps' of misdirection by up to
+10ฐ in bees during the waggle dance. This alone could
cause directional confusion in hives. Continuous fields of
250 Hz with bursts perpendicular to the static MF however
caused no effects. They concluded that a resonance rela-
tionship other than classic resonance models was indi-
cated (see "Mechanisms" above). This early work has
implications for subsequent digital pulsing and all wireless
broadband technology.

More recent work on honey bees and ELF-EMF by
Shepherd et al. [209] in 2018 found that acute exposure to
50 Hz fields at levels from 20-100 |aT (at ground level un-
derneath powerline conductors), to 1,000-7,000 |aT
(within 1 m of the conductors), reduced olfactory learning,
foraging flight success toward food sources and feeding, as
well as altered flight dynamics. Their results indicated that
50 Hz ELF-EMFs from powerlines is an important envi-
ronmental honey bee stressor with potential impacts on
cognitive and motor abilities.

Some wasp species have also been found sensitive to
ELF-EMF. Pereira-Bomfim et al. [391] investigated the
magnetic sensitivity of the social paper wasp (Polybia
paulista) by analyzing wasp behavior in normal geomag-
netic fields and in the presence of external magnetic fields
altered by either permanent magnets (DC fields) or by
Helmholtz coils (AC fields). They evaluated the change in
foraging rhythm and colony behavior, as well as the fre-
quency of departing/homeward flights and the behavioral
responses of worker wasps located on the outer nest sur-
face. They found that the altered magnetic field from the DC
permanent magnet produced an increase in the frequency
of departing foraging flights, and also that wasps grouped
together on the nest surface in front of the magnet with
their heads and antennae pointing toward the perturbation
source, possibly indicating a response to a potential threat
as a defense strategy. Controls showed no such grouping
behavior. The AC fields created by the Helmholtz coils also
increased foraging flights, but individuals did not show
grouping behavior. The AC fields, however, induced wasp
workers to perform "learning flights." They concluded that
for the first time, P. paulista demonstrated sensitivity to an
artificial modification of the local geomagnetic field and
that mechanisms may be due to both cryptochrone/radical
pairs and magnetite.

Another flying insect model — desert locust (Schisto-
cerca gregaria) — was found susceptible to entrainment by
ELF-EMF. In a complex study, Shepherd et al. [392]
analyzed acute exposure to sinusoidal AC 50 Hz EMF (field
strength range: 10 to 10,000 |aT) vs. controls on flights of
individual locusts tethered between copper wire coils
generating EMFs at various frequencies and recorded on
high-speed video. Results found that acute exposure to
50 Hz EMFs significantly increased absolute change in
wingbeats in a field-strength-dependent manner. Applying
a range of ELF-EMF close to normal wingbeat occurance,
they found that locusts entrained to the exact frequency of
the applied EMF. They concluded that ELF exposure can
lead to small but significant changes in locust wingbeats,
likely due to direct acute effects on insect physiology (vs.
cryptochrome or magnetite-based magnetoreception) and/
or behavioral avoidance responses to molecular/physio-
logical stress. Wyszkowska et al. [393] also found effects on
locusts — exposure to ELF-EMF above 4 mT led to dramatic
effects on behaviour, physiology and increased Hsp70
protein expression. Such higher exposures may be found
near high tension lines.

Bees: RF-EMF

The effects of RF-EMF on bees is of increasing interest since
that is the fastest rising EMF environmental exposure of the
past 30 years [369]. Beginning in the early 2000s, studies of
cell phones placed in the bottom of hives began to appear.
Honey bees showed disturbed behavior when returning to
hives after foraging and under various RFR exposures
[394-396]. Early methodologies, however, were not well
designed or controlled. For instance, Favre [397] found
increased piping — a distress signal that honey bees give
off to alert hive mates of threats and/or to announce the
swarming process. Both active and inactive mobile phone
handsets were placed in close proximity to honey bees with
sounds recorded and analyzed. Audiograms and spectro-
grams showed that active phone handsets had a dramatic
effect on bee behavior in induced worker piping. This study
was criticized by Darney et al. [398] for using music in the
active RFR exposure which may have introduced a variable
capable of affecting bee piping in response to the added
sound alone.

In a complex study, Darney et al. [398] tested high
frequency (HF) and ultra high frequency (UHF) used in
RFID technology in order to develop a method to auto-
matically record honey bees going in and out of hives. They
glued RFID tags onto individual bee dorsal surfaces that
were detected at the hive entrance by readers emitting HF
radio waves. They then looked for possible HF adverse


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34 — Levitt et al.: EMF and wildlife

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effects on honey bees' survival. Eight-day-old honey bees
were exposed to HF 13.56 MHz or UHF 868 MHz RFR for 2 h
split into ON and OFF periods of different durations. Dead
bees were counted daily with cumulative mortality rates of
exposed and non-exposed honey bees compared seven
days after exposure. Two out of five experimental condi-
tions found increased mortality, once after HF and once
after UHF exposure, with OFF duration of 5 min or more,
after which they recommended limiting honey bee expo-
sure to RFR to less than 2 h per day. They also curiously
concluded that the RFID parameters they used for moni-
toring hive activity presented no adverse effects but the
multifrequency peak exposures and RFID attachments
need further study in light of other works on RFID effects
(see Part 1 for discussion of RFID.)

In another study using an active cell phone attached to
hive frames, Odemer and Odemer [399] investigated RFR
effects on honey bee queen development and mating suc-
cess. Control hives had an inactive cell phone attached.
After exposing honey bee queen larvae to GSM 900 MHz
RFR during all stages of pre-adult development (including
pupation), hatching of adult queens was assessed 14 days
after exposure and mating success after an additional
11 days. They found that chronic RFR exposure signifi-
cantly reduced honey bee queen hatching; that mortalities
occurred during pupation but not at the larval stages; that
mating success was not adversely affected by the irradia-
tion; and that after exposure, surviving queens were able to
establish intact colonies. They therefore determined that
mobile phone radiation had significantly reduced the
hatching ratio but not mating success if queens survived,
and if treated queens successfully mated, colony devel-
opment was not adversely affected. Even though they
found strong evidence of mobile phone RFR damage to
pupal development, they cautioned its interpretation,
noting that the study's worst-case exposure scenario was
the equivalent of a cell phone held to a user's head, not at a
level found in typical urban or rural hive settings. They
concluded that while no acute negative effects on bee
health were seen in the mid-term, they also could not rule
out effects on bee health at lower chronic doses such as
found in ambient environments, and urgently called for
long term research on sublethal exposures present in major
city environments.

Sharma and Kumar [400] found similar abnormalities
in honey bee behavior when they compared the perfor-
mance of honey bees in RFR exposed and unexposed
colonies. Two of four test colonies were designated and
each equipped with two functional cell phones — a high
exposure — placed on two different hive side walls in call
mode at GSM 900 MHz. The average RFR power density

was measured at 8.549 (iW/cm2 (56.8 V/m, electric field).
One control colony had a dummy phone; the other had no
phone. Exposure was delivered in 15 min intervals, twice
per day during the period of peak bee activity. The
experiment was performed twice a week during February
to April. It covered two brood cycles with all aspects of
hive behavior observed, including brood area comprising
eggs, larvae and sealed brood; queen proficiency in egg-
laying rate; foraging, flight behavior, returning ability;
colony strength including pollen storage; and other var-
iables. Results included a significant decline in colony
strength and egg laying and reduced foraging to the point
where there was no pollen, honey, brood, or bees by the
end of the experiment. One notable difference in this
study was that the number of bees leaving the hive
decreased following exposure. There was no immediate
exodus of bees as a result of exposure — instead bees
became quiet, still, and/or confused "...as if unable to
decide what to do..." the researchers said. Such a
response had not been reported before. The authors
concluded that colony collapse disorder is related to cell
phone radiation exposures.

Vilic et al. [401] investigated RFR and oxidative stress
and genotoxicity in honey bees, specifically on the activity
of catalase, superoxide dismutase, glutathione S-trans-
ferase, lipid peroxidation levels and DNA damage. Larvae
were exposed to 900 MHz RFR at field levels of 10, 23, 41
and 120 V m_1 for 2 h. At a field level of 23 V m 1 the effect of
80% AM 1 kHz sinusoidal and 217 Hz modulation were also
investigated. They found that catalase activity and the lipid
peroxidation levels significantly decreased in larvae
exposed to the unmodulated field at 10 V m_1 (27 (iW/cm2)
compared to the control. Superoxide dismutase and
glutathione S-transferase activity in honey bee larvae
exposed to unmodulated fields were not statistically
different compared to the control. DNA damage increased
significantly in larvae exposed to modulated (80% AM at
1 kHz) field at 23 V m_1 (140 (iW/cm2) compared to control
and all other exposure groups. Their results suggested that
RFR effects in honey bee larvae manifested only after
certain EMF exposure conditions. Interestingly, they found
that increased field levels did not cause a linear dose-
response in any of the measured parameters, while
modulated RFR produced more negative effects than the
corresponding unmodulated field. They concluded that
while honey bees in natural environments would not be
exposed to the high exposures in their experiments, the
results indicated additional intensive research is needed in
all stages of honey bee development since the cellular ef-
fects seen could affect critical aspects of bee health and
survival.


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Levitt et al.: EMF and wildlife — 35

Kumar et al. [402] also found biochemical changes in
worker honey bees exposed to RFR. A wooden box was
designed with glass on the front and back and wire gauze
for ventilation on two sides for both exposed bees and
controls. Cell phones (same make, model, and network
connection) were kept in listen-talk mode for 40 min. At
intervals of 10, 20 and 40 min, 10 exposed and 10 control
bees were collected at the same times. Hemolymph was
then extracted from the inter-segmental region of bee ab-
domens and analyzed. Results included increased con-
centration of total carbohydrates in exposed bees in the
10 min exposure period compared to unexposed bees.
Increasing the exposure time to 20 min resulted in a further
increase in the concentration, but exposure at 40 min had a
reverse effect with declines in carbohydrate concentration
although it was still higher than controls. Hemolymph
glycogen and glucose content also showed the same
exposure pattern — increase in content up to 20 min after
which a slight decline that was still higher than controls.
Changes in total lipids/cholesterol — the major energy re-
serves in insects — can affect numerous biological pro-
cesses. Some lipids are crucial membrane structure
components while others act as raw materials in hormones
and pheromones. Changes in these parameters are signif-
icant to every biological activity, including reproduction.
Also of interest in this study was that as exposure time
increased, the bees appeared to have identified the source
of disturbance. There was a large scale movement of
workers toward the talk-mode (with higher RFR exposure
during transmission function) but not the listening mode.
Bees also showed slight aggression and agitation with
wing beating. The researchers hypothesized that this
increased activity could be responsible for increased en-
ergy use thereby accounting for the decrease in concen-
tration of carbohydrates and lipids in the 40 min exposed
sample. The researchers concluded that cell phone radia-
tion influences honey bee behavior and physiology.
Sharma [403] had also reported increased glycogen and
glucose levels in exposed honey bee pupa.

It must be pointed out that the cell phone emission
conditions used in some experiments are questionable, in
particular where there was no detail regarding how the
phones were activated to achieve emission.

Not all studies demonstrated adverse effects. Mall and
Kumar [404] found no apparent RFR effects on brood rearing,
honey production or foraging behavior in honey bees in hives
with cell phones inside or near a cell tower; and Mixon et al.
[405] also found no effects of GSM-signal RFR on increased
honey bee aggression. They concluded that RFR did not
impact foraging behavior or honey bee navigation and
therefore was unlikely to impact colony health.

Although there are several anectodal reports of insect
losses near communication towers, there are only a
handful of ambient RFR field studies conducted on in-
vertebrates thus far. In the first large survey of wild polli-
nating species at varying distances from cell towers, Lazaro
et al. [406] found both positive and negative effects from
RFR in a broad range of insects on two islands (Lesvos and
Limnos) in the northeastern Aegean Sea near Greece.
Measured ambient RFR levels included all frequency
ranges used in cell communications; broadcast RFR is
absent on the islands. RFR values did not significantly
differ between islands (Lesvos: 0.27 ฑ 0.05 V/m; Limnos:
0.21 ฑ 0.04 V/m; v3 2 = 0.08, p=0.779) and did not decrease
with the distance to the antenna, possibly, they hypothe-
sized, because some sampling points near the antenna may
have been outside or at the edge of the emission lobes. They
measured RFR at four distances of 50,100, 200 and 400 m
(164, 328, 656, and 1,312 ft, respectively) from 10 antennas
(5 on Lesvos Island and 5 on Limnos Island) and correlated
RFR values with insect abundance (numbers of insects)
and richness (general health and vitality) — the latter only
for wild bees and hoverflies. The researchers conducted
careful flowering plant/tree- and- insect inventories in
several low-lying grassland areas, including for wild bees,
hoverflies, bee flies, other remaining flies, beetles, butter-
flies, and of various types. Honey bees were not included in
this study as they are a managed species subject to
beekeeper decisions and therefore not a wild species. On
Lesvos 11,547 insects were collected and on Limnos 5,544.
Varied colored pan traps for both nocturnal and diurnal
samples were used. Results found all pollinator groups
except butterflies were affected by RFR (both positively and
negatively) and for most pollinator groups effects were
consistent on both islands. Abundance for beetles, wasps,
and hoverflies significantly decreased with RFR but overall
abundance of wild bees and bee flies significantly
increased with exposure. Further analysis showed that
only abundance of underground-nesting wild bees was
positively related to RFR while wild bees nesting above
ground were not affected. RFR effects between islands
differed only on abundance of remaining flies. On species
richness, RFR tended to only have a negative effect on
hoverflies in Limnos. Regarding the absence of effects seen
in butterflies, they hypothesized that the pan trap collec-
tion method is not efficient for collecting butterflies (but-
terflies accounted for only 1.3 % of total specimens), and
that a different sampling method might produce a different
result. They concluded that with RFR's negative effects on
insect abundance in several groups leading to an altered
composition of wild pollinators in natural habitats, it was
possible this could affect wild plant diversity and crop


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36 — Levitt et al.: EMF and wildlife

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production. They further said the negative relationship
between RFR on the abundance of wasps, beetles and
hoverflies could indicate higher sensitivity of these insects
to EMFs. Potentially more EMF-tolerant pollinators, such
as underground-nesting wild bees and bee flies, may fill the
vacant niches left by less tolerant species, thus resulting in
their population increases. Another possible explanation is
that EMFs may have particularly detrimental effects on
more sensitive larval stages, and if so, larvae developing
above ground (many beetles, wasps, hoverflies) may be
more vulnerable than those developing underground since
the former could be exposed to higher radiation levels.

In another field study, Taye et al. [407] placed five
hives from December to May at varying distances of 1,000,
500,300, 200 and 100 m (3,280,1,640, 984, 656 and 328 ft,
respectively) from a cell tower in India to measure flight
activity, returning ability, and pollen foraging efficiency in
honey bees (Apis cerana F). They found most effects closest
to towers with the least returning bees at 100 m distance
from the tower. Maximum foraging and return ability to the
colonies was seen at 500 m, followed by 1,000 m and in
descending order at 300 and 200 m, with the fewest
returning bees at 100 m from the tower. The study also
found that if bees returned, the pollen load per minute was
not significantly affected.

Vijver et al. [408] however challenged the accuracy of
distance from towers that is often used as a proxy for EMF
gradients such as the study above. In a field study in The
Netherlands, the researchers tested exposure to RFR from a
cell base station (GSM 900 MHz) on the reproductive ca-
pacity of small virgin invertebrates during the most sensi-
tive developmental periods spanning preadolescent to
mating stages when reproductive effects would most likely
be seen. Careful RFR field measurements were taken to
determine null points in order to see if distance from
emitters is a reliable RFR exposure model in field studies.
They exposed four different invertebrate hexapod species.
Springtails (Folsomia Candida), predatory 'bugs' (Onus
laevigatus), parasitic wasps (Asobara japonica), and fruit-
flies (D. melanogaster) were placed in covered pedestal
containers within the radius of approximately 150 m of a
900 MHz mobile phone base station for a 48-h period. Six
control groups were placed within 6.6 ft (2 m) of the
treatment groups and covered in Farady cages. After
exposure, all groups were brought to the laboratory to
facilitate reproduction with resulting fecundity and num-
ber of offspring then analyzed. Results showed that dis-
tance was not an adequate proxy to explain dose-response
regressions. After complex data synthesis, no significant
impact from the exposure conditions, measures of central
tendency, or temporal variability of EMF on reproductive

endpoints were found although there was some variability
between insect groups. As seen in other studies, distance is
often used to create a gradient in energy exposures in
studies but this study found the intensity of the transmitter
and the direction of transmission to be more relevant, as
did Bolte and Eikelboom [409,410]. The direction and tilt of
the transmitter determines whether the location of interest
in field studies is in the main beam. In some instances, the
closer promixity to the transmitter provided lower readings
than further away, which they found between two loca-
tions. They also noted that the organisms selected in the
study were small in size; springtails have a body length on
average of 2 mm; wasps are about 3 mm, insect sizes from
1.4 to 2.4 mm, with the largest organisms tested being fe-
male fruit flies at about 2.5 mm length and males slightly
smaller. Due to size, limited absorption and little energy
uptake capacity, none of these insects are efficient whole-
body receptors for 900 MHz waves with a wavelength of
approximately 13 in (33 cm). But they further noted that this
was a linear regression study and that biological effects are
often non-linear. However, finding no distinct effects did
not exclude physiological changes. They concluded that
because of RFR exposure's increasing ubiquity, urgent
attention to potential effects on biodiversity is needed.

The issue of insect size, nonlinearity, and antenna tilt/
direction are factors of critical importance with 5G radia-
tion which will create extremely complex near- and- far-
field ambient exposures to species in urban and rural en-
vironments alike, not only from a densification of small cell
antennas close to the ground but also from increased sat-
ellite networks circling in low Earth orbits (see Part 1). The
range of frequencies used for wireless telecommunication
systems will increase from below 6 GHz (2G, 3G, 4G, and
WiFi) to frequencies up to 120 GHz for 5G which, due to
smaller wavelengths, is therefore a better resonant match
for small insects. An alarming study by Thielens et al. [411],
drawing on numerous robust studies of RFR's decades-
long use as a thermal insecticide, modeled absorbed RFR
in four different types of insects as a function of fre-
quency alone from 2 to 120 GHz. A set of insect models
was obtained using novel Micro-CT (computer tomogra-
phy) imaging and used for the first time in finite-
difference time-domain electromagnetic simulations.
All insects showed frequency-dependent absorbed po-
wer and a general increase in absorbed RFR at and above
6 GHz, in comparison to the absorbed RFR power below
6 GHz. Their simulations showed that a shift of 10% of the
incident power density to frequencies above 6 GHz
would lead to an increase in absorbed power between
3-370% — a large differential of serious potential
consequence to numerous insect species.


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Levitt et al.: EMF and wildlife — 37

Using a similar approach, Thielens et al. [412] focused
on the western honey bee (Apis mellifera) with RF-EMF,
using a combination of in-situ exposure measurements
near bee hives in Belgium and numerical simulations.
Around five honey bee models were exposed to plane
waves at frequencies from 0.6 to 120 GHz — frequencies
carved out for 5G. Simulations quantified whole-body
averaged RFR absorbed as a function of frequency and
found that the average increased by factors of 16-121
(depending on the specimen) when frequency increased
from 0.6 to 6 GHz for a fixed incident electric field strength.
A relatively small decrease in absorption was observed for
all studied honey bees between 12 and 120 GHz due to
interior attenuation. RFR measurements were taken at 10
bee hive sites near five different locations. Results found
average total incident RFR field strength of 0.06 V/m; those
values were then used to assess absorption and a realistic
rate was estimated between 0.1 and 0.7 nW. They
concluded that with an assumed 10% incident power
density shift to frequencies higher than 3 GHz, this would
lead to an RFR absorption increase in honey bees between
390 and 570% — a frequency shift expected with the
buildout of 5G.

The two previous studies alone should give pause
regarding environmental effects to invertebrates in these
higher 5G frequency ranges.

Kumar [413] noted that RFR should be included as
causal agents of bee CCD and that test protocols need to be
standardized and established. Standardization is critical
since many studies conducted with cell phones in hives are
of very uneven quality and only indicative of potential ef-
fects. Placing cell phones in hives and assuming that RFR is
the only exposure is inaccurate and misleading. ELF-EMFs
are always present in all telecommunications technology,
using pulsed and modulated signals [414]. All of these
characteristics have been found to be highly biologically
active apart from frequency alone. Such studies are likely
capturing ELF effects without identifying them. All aspects
of transmission, including transmission engineering itself
from towers, need to be considered to determine accurate
exposures and delineate causative agents. Vibration and
heat must also be considered — cell phones in transmission
mode could raise hive temperature quickly and bees are
highly temperature sensitive. Due to "waggle dance" spe-
cifics in creating foraging "roadmaps," bees should not be
artificially relocated from hives to determine return ability
after EMF exposure. They may be confused by relocation
alone, adversely affecting their return abilities. Such tests
also involve only one stressor when there are multiple
stressors on insect species today. Understanding such co-
factors is critical in determining accurate data and

outcomes [415, 416]. Translating laboratory studies to field
relevance has always been problematic but understanding
EMF effects to insects has become urgent with ever
increasing low-level ambient exposure from devices and
infrastructure, especially in light of the new 5G networks
being built. There are numerous variables that studies have
yet to factor in. All of the above indicates a critical need to
standardize experimental protocols and to take electro-
ecology far more seriously, especially regarding aerial
species in light of 5G.

Aquatic environments

There are fundamental electrical differences in conduc-
tivity (how well a material allows electric current to flow)
and resistivity (how strongly a material opposes the flow of
electric current) between air and water. Through water,
EMF propagation is very different than through air because
water has higher permittivity (ability to form dipoles) and
electrical conductivity. Plane wave attenuation (dissipa-
tion) is higher in water than air, and increases rapidly with
frequency. This is one reason that RFR has not traditionally
been used in underwater communication while ELF has
been. Conductivity of seawater is typically around 4 S/m,
while fresh water varies but typically is in the mS/m range,
thus making attenuation significantly lower in fresh water
than in seawater. Fresh water, however, has similar
permittivity as sea water. There is little direct effect on the
magnetic field component in water mediums; propagation
loss is mostly caused by conduction on the electric field
component. Energy propagation continually cycles be-
tween electric and magnetic fields and higher conduction
leads to strong attenuation/dissipation of EMF [98].

Because of these essential medium differences, electro-
receptor mechanisms in aquatic species may be very different
than those previously described in aerial species since air is a
less conductive and resistive medium with less attenuation.
That is why RFR travels more easily and directly through air.
In aquatic species electroreception may be a result of trans-
mission via water directly to the nervous system through
unique receptor channels called Ampullae of Lorenzini [371].
In frogs, amphibians, fish, some worm species and others,
receptor channels may be through the skin as well as via
mechanisms more common in aerial species such as in the
presence of magnetite (see "Mechanisms" above). There can
be great variation in electroreceptive sensitivities in species
inhabiting the two fundamentally different environments.
Some amphibian species, however, have physical charac-
teristics that span both mediums and therefore varied mag-
netoreception mechanisms.


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Amphibians: frogs, salamanders,
reptiles: regeneration abilities

Amphibians are the class of animals that include frogs,
toads, salamanders, newts, some reptiles, and caecilians.
The common term 'frog' is used to describe thousands of
tailless amphibian species in the Order Anura. There are over
6,300 anuran species recorded thus far, with many more
likely disappearing today due to climate change and other
factors before we even knew they existed. Informal distinc-
tions are made between frogs (thin-skinned species) and
toads (thick, warty skins) but such distinctions are not used
for taxonomic reasons. While the greatest concentration of
diverse frog species is in tropical rainforests, they are widely
found all over the world from the tropics to subarctic regions.
Most adult frogs live in fresh water and/or on dry land while
some species have adapted to living in trees or underground.
Their skin varies in all manner of colors and patterns, from
gray/green and brown/black to bright reds/yellows.

Frog skin is smooth and glandular — something of
concern given nascent 5G technology (see Part 1) — and can
secrete toxins to ward off predators. Frog skin is also semi-
permeable which makes them highly susceptible to dehy-
dration and pollutants. With radical weather shifts due to
climate change and unpredictable swings between
abnormal droughts followed by flooding in previously
weather-stable regions, environmentally sensitive am-
phibians like frogs are considered bell-weather species.
Frequently, time may be insufficient for some local/
regional species to regenerate in between radical weather
cycles, leading to population collapse.

Since the 1950s, there has been a significant decline in
frog populations with more than one third of species today
considered threatened with extinction while over 120 spe-
cies are already believed to have gone extinct since the
1980s [10, 417, 418]. This amphibian decline is considered
part of an ongoing global mass extinction, with population
crashes as well as local extinctions creating grave impli-
cations for planetary biodiversity [419]. Amphibian
extinction results are from climate change [420-422];
habitat loss/destruction [423, 424]; introduced species
[425]; pollution [426], parasites [423, 427]; pesticides, her-
bicides and fungicides [428-430]; disease [431-435]; and
increased ultraviolet-B radiation [436-439] among others.
Anthropogenic sound pollution may also affect amphibian
call rates and therefore impact reproduction [440] and
artificial night lights affect male green frog (Rana clamitaus
melanota) breeding [441]. Nonionizing electromagnetic
fields may also play a role [442].

McCallum [443] calculated that the current extinction
rate of amphibians could be 211 times greater than their
pre-anthropogenic natural "background extinction" rate
with the estimate rising 25,000-45,000 times if endan-
gered species are also included in the computation. Today,
declining amphibian populations are seen in thousands of
species across numerous ecosystems, including pristine
forested areas [418] and declines are now recognized
among the most severe impacts of the anthropocene era
[417, 442],

In addition, the number of frogs with severe malfor-
mations often incompatible with survival has risen
sharply. Deformities are a complex issue related to physi-
ology, anatomy, reproduction, development, water qual-
ity, changing environmental conditions, and ecology in
general. Any time deformities are observed in large seg-
ments of wildlife populations there are indications of
serious environmental problems [442]. Amphibian mal-
formations are presumed due to an aggressive infectious
fungal disease called Chytridiomycosisy, caused by the
chytrid fungi Batrachochytrium dendrobatodis and Batra-
chochytrium salamandrivorans [432-435], and by parasites
like Ribeiroia ondatrae [427]. Chytridiomycosis has been
linked to dramatic amphibian declines and extinctions in
North, Central, and South America, across sections of
Australia and Africa and on Caribbean islands like
Dominica and Montserrat. First identified in the 1970s in
Colorado, U.S., it continues to spread globally at an
alarming rate. Some populations witness sporadic deaths
while others experience 100% mortality. There is no
effective measure to control the disease in wild pop-
ulations. Herbicides like glyphosate used in Roundup™
and atrazine, an endocrine disruptor, have also been found
to cause severe malformations in both aquatic and land
amphibian species from farmland pesticide/herbicide/
fungicide runoff [428-430].

Frogs are known to be highly sensitive to natural and
manmade EMF. Much research into the electrophysiology
of frogs has been conducted because they are good lab
models for human nervous system research, readily
available, and easily handled. As far back as 1780, the
Italian physicist Luigi Galvani discovered what we now
understand to be the electrical basis of nerve impulses
while studying static electricity (the only kind then known)
when he accidentally made frog leg muscles contract while
connected to the spinal cord by two different metal wires
[444]. Galvani thought he had discovered "animal
magnetism" but had actually discovered direct current and
what later became known as a natural "current of injury"—
the process by which an injured limb, for instance, pro-
duces a negative charge at the injury site that will later turn


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Levitt et al.: EMF and wildlife — 39

to a positive charge at the same site in some species as
discovered in the 1960s by Robert 0. Becker [444-451]. The
earliest curiosity about natural current continued
throughout the 1800s on various aspects of EMF and later
throughout the 1920s to 1940s in pioneering researchers
Elmer J. Lund [452-454] and Harold Saxon Burr [455-457]
who worked to establish the first unified electrodynamic
field theory of life, using hydra, frog, and salamander
models among several others because of their morpho-
genic properties [458]. While frogs do not regenerate limbs
the way salamanders do, both are so similar in taxonomy
that curiosity was high in the early pioneers cited above
throughout the 1960s to 1990s about what fundamentally
allowed limb regeneration in one species, by not the other.
Much was learned in the process about amphibian elec-
trophysiology and cellular microcurrent in wound healing,
as well as the electrophysiological properties of cellular
differentiation, and eventually dedifferentiation pertinent
to all contemporary stem cell research. Today the impli-
cations of this early work have gained new interest and
targeted research regarding endogenous microcurrent and
limb regeneration potential in humans, as well as dedif-
fentiation/stem cell/morphogenesis in general for cancer
treatment and other healing modalities. For a thorough
review of studies on morphogenesis see Levin [459].

Ubiquitous low-level ambient EMFs today match some
of the natural low-level microcurrent found critical to the
fundamental processes of amphibian growth, reproduc-
tion, morphogenesis, and regeneration, lending new
meaning to the early research that defined amphibian
electrophysiology. We just need to make far better use of it
to understand what role, if any, today's ambient exposures
may be contributing to amphibian losses. (To compare
tables between rising ambient EMF levels and low level
effects in wildlife, see Part 1, Supplement 1; and Part 2,
Supplement 3.)

Amphibian and reptile magnetoreception

How amphibians perceive natural and manmade EMF is
similar to other species reviewed above and for amphibian
mechanism reviews see Phillips et al. [460,461]. Like many
bird and insect species, evidence indicates that amphib-
ians perceive the Earth's geomagnetic fields by at least two
different biophysical magnetoreception mechanisms:
naturally occurring ferromagnetic crystals (magnetite),
and light-induced reactions via specialized photo-receptor
cells (cryptochromes) that form spin-correlated radical
pairs. Like birds, both mechanisms are present in some
amphibians. Cryptochromes provide a directional

'compass' and the non-light-dependent magnetite pro-
vides the geographical 'map.'

In a thorough discussion of many magnetoreception
studies in anura and urodela species, Diego-Rasilla et al.
[462] found evidence that Iberian green frog tadpoles
(Pelophylax perezi) had a light-dependent magnetic com-
pass, and Diego-Rasilla et al. [463] also found that tadpoles
of the European common frog (Rana temporaria) are
capable of using the Earth's magnetic field for orienting
along a learned y-axis. In these studies, they investigated if
this orientation is accomplished using a light-dependent
magnetic compass similar to that found in the earlier ex-
periments with other species of frogs and newts [460,
462-470] or from some other factor. They concluded that
the magnetic compass provided a reliable source of direc-
tional information under a wide range of natural lighting
conditions. They also compared their findings to studies
[470] that showed the pineal organ of newts to be the site of
the light-dependent magnetic compass, as well as to recent
neurophysiological evidence showing magnetic field
sensitivity located in the frog frontal organ which is an
outgrowth of the pineal gland. They hypothesized this
work could indicate a common ancestor as long ago as 294
million years.

To determine if orientation using Earth's magnetic
fields changed according to seasonal migration patterns,
Shakhparonov and Ogurtsov [471] tested marsh frogs
(Pelophylax ridibundus) in the laboratory to see if frogs
could determine migratory direction between the breeding
pond and their wintering site according to magnetic cues.
Adult frogs (n=32) were tested individually in a T-maze
127 cm long inside a three-axis Helmholtz coil system
(diameter 3 m). Maze arms were positioned parallel to the
natural migratory route and measured in accordance with
the magnetic field. Frogs were tested in the breeding
migratory state and the wintering state, mediated by a
temperature/light regime. Frog choice in a T-maze was
evident when analyzed according to the magnetic field
direction. They moved along the migratory route to the
breeding pond and followed the reversion of the horizontal
component of the magnetic field. The preference was seen
in both sexes but only during the breeding migratory state.
They concluded that adult frogs obtained directional in-
formation from the Earth's magnetic field.

Diego-Rasilla et al. [472] found similar evidence in two
species of lacertid lizards (Podarcismuralis and Podarcis
lilfordi) that exhibited spontaneous longitudinal body axis
alignment relative to the Earth's magnetic field during sun
basking periods. Both species exhibited a highly signifi-
cant bimodal orientation along the north-northeast and
south-southwest magnetic axis. Lizard orientations were


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significantly correlated over a five-year period with
geomagnetic field values at the time of each observation.
This suggested the behavior provides lizards with a con-
stant directional reference, possibly creating a spacial
mental map to facilitate escape. This was the first study to
provide spontaneous magnetic alignment behavior in free-
living reptiles although studies of terrapins have also
found such spontaneous magnetic alignment [92,323,473].
Nishimura et al. [474, 475] also found sensitivity to
ELF-EMF (sinusoidal 6 and 8 Hz, peak magnetic field
2.6 (iT, peak electric field (10 V/m) in a lizard species
(Pogona vitticeps) as demonstrated by significant increased
tail lifting — a reproductive behavior. Interestingly, this
tail-lifting response to ELF-EMF disappeared when the
parietal eye was covered, suggesting that the parietal eye
contributes to light-dependent magnetoreception and that
exposure to ELF-EMFs may increase magnetic-field sensi-
tivity in the lizards. A further experiment [476] showed that
light at a wavelength lower than 580 nm was needed to
activate the light-dependent magnetoreception of the pa-
rietal eye.

Amphibians: RF-EMF

Most frogs spend significant time on land but lay eggs in
water where they hatch into tadpoles with tails and inter-
nal gills. However, some species bypass the tadpole stage
and/or deposit eggs on land. Frogs are thus subject to ex-
posures from both land-based and aquatic environments.
A frog's life cycle is complete when metamorphosis into an
adult form occurs. Many adverse effects do not appear until
after metamorphosis is completed but problems have been
found throughout the entire life cycle after exposures to
both ELF-EMF and RFR.

Most early research on frogs (other than the Becker
et al. regeneration inquiries noted above) was conducted at
high thermal levels rarely encountered in the environment
but some are included here because they helped delineate
amphibian electrophysiology with effects later supported
in low-level research. Some early work did use frog models
to investigate cardiac effects with lower intensity expo-
sures. Levitina [477] found that intact frog whole-body
exposure caused a decrease in heart rate, while irradiation
of just the head caused an increase. Using VHF frequency
RFR at a power density of 60 (iW/cm2, ,4=12.5 cm, Levitina
attributed the cardiac changes to peripheral nervous sys-
tem effects but according to Frey and Siefert [478], because
of the wavelengths used in that study, little energetic body
penetration would be expected. They said a skin receptor
hypothesis was therefore reasonable.

Following on Levitina's work, Frey and Seifert [478] —
using isolated frog hearts, UHF frequencies that penetrate
tissue more efficiently and low intensity pulse modula-
tion — found that pulsed microwaves at 1,425 GHz could
alter frog heart rates depending on the timing of exposure
between the phase of heart action and the moment of pulse
action. Twenty-two isolated frog hearts were irradiated
with pulses synchronized with the P-wave of the ECGs;
pulses were of 10 s duration triggered at the peak of the
P-wave. Two control groups were used without RFR ex-
posures with no effects noted. They found heart rate ac-
celeration occurred with pulsing at about 200 ms after the
P-wave. But if the pulse occurred simultaneously with the
P-wave, no increases were induced. Arrhythmias occurred
in half the samples, some resulting in cardiac cessation.
Clearly from this study, RFR affected frog heart rhythm and
could cause death.

A more recent work by Miura and Okada [479] found
severe vasodilation in frog foot webs from RFR. In a series
of three experiments using 44 anesthetized frogs (X. laevis)
at thermal and non-thermal intensities, researchers
exposed foot webs to pulsed RFR in three parameters with
the monitor coil set at 1V peak-to-peak: 100 kHz 582-3 mG
and 174.76 V cm-1; 10 MHz 7.3 mG and 2.19 V cm-1; 1 MHz
539 mG and 16.11 V cnT1. They found not only dilated ar-
terioles of the web which had already been re-constricted
with noradrenaline, but also dilated arterioles under non-
stimulated conditions. Vasodilatation increased slowly
and reached a plateau 60 min after radiation's onset. After
radiation ceased, vasodilation remained for 10-20 min
before slowly subsiding. Vasodilation was optimum when
pulsation was applied 50% of the total time at a 10 kHz
burst rate at 10 MHz. Effects were non-thermal. The pattern
of vasodilation induced by warm Ringer solution was
different from the vasodilatory effect of weak RFR,
involving the level of intracellular Ca2+. They hypothesized
that since Ca2+ ATPase is activated by cyclic GMP which is
produced by the enzymatic action of guanylate cyclase,
RF-EMF may activate guanylate cyclase to facilitate cyclic
GMP production. They concluded the study indicates for the
first time that RFR dilates peripheral resistance vessels by
neither pharmacological vasodilator agents nor physical
thermal radiation, but that the precise mechanisms of acti-
vation of guanylate cyclase by RFR at the molecular level
required further study. Vasodilation and constriction affects
every part of the body and can affect all organ systems.

Prior to this, Schwartz et al. [480] found changes in
calcium ions in frog hearts in response to a weak VHF field
that was modulated at 16 Hz. This would be an exposure
common in the environment. Calcium ions are critical to
heart function.


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Levitt et al.: EMF and wildlife — 41

Balmori [24-30, 442] and Balmori and Hallberg [271]
have focused widely on EMF effects to wildlife, with two
papers on amphibians. Balmori [442], in a review, noted
that RFR in the microwave range is a possible cause for
deformations and decline of some amphibian populations,
and Balmori [481] in 2010 found increased mortality in
tadpoles exposed to RFR in an urban environment. In the
2010 study, tadpoles of the common frog (Rana temporaria)
were exposed to RFR from several mobile phone towers at a
distance of 459 ft (140 m). Two month exposures lasted
through egg phase to advanced tadpole growth prior to
metamorphosis. RF and MW field intensity between 1.8 and
3.5 V/m (0.86-3.2 (iW/cm2) were measured with three
different devices. Results determined that the exposed
group (n=70) had low coordination of movements and
asynchronous growth that resulted in both large and small
tadpoles, as well as a disturbing 90% high mortality rate. In
the control group (n=70) a Faraday cage was used under
the same conditions. Controls found movement coordina-
tion to be normal and development synchronous with
mortality rate at a low 4.2%. These results indicated that
RFR from cell towers in a field situation could affect both
development and mortality of tadpoles. Prior to this study,
Grefner et al. [482] also found increased death in tadpoles
(Rana temporaria L.) exposed to EMF, as well as higher
mortality rates, and slower less synchronous development.

Mortazavi et al. [483] found changes in muscle con-
tractions in frogs exposed to 900-MHz cell phone radiation
for 30 min; gastrocnemimus muscles were then isolated
and exposed to a switched on/off mobile phone radiation
for three 10-min intervals. The authors reported
RFR-induced effects on pulse height and latency period of
muscle contractions. SARs of the nerve-muscle preparation
were calculated to be 0.66 (muscle) and 0.407 (nerve)
W/kg.

Rafati et al. [484] investigated the effects of RFR on
frogs from mobile phone jamming equipment emitting RFR
in the same frequencies as mobile phones. (Although
illegal in many countries, jammers are nevertheless used to
interfere with signals and stop communication.) The study
sought to follow up on reports of non-thermal effects of
RFR on amphibians regarding alterations of muscle
contraction patterns. They focused on three parameters:
the pulse height of leg muscle contractions, the time in-
terval between two subsequent contractions, and the la-
tency period of frog's isolated gastrocnemius muscle after
stimulation with single square pulses of 1V (1 Hz). Animals
in the jammer group were exposed to RFR at a distance of
1 m from the jammer's antenna for 2 h while the control
frogs were sham exposed. All were then sacrificed and
isolated gastrocnemius muscles were exposed to on/off

jammer radiation for three subsequent 10 min intervals
(SAR for nerve and muscle of the different forms of jammer
radiation was between 0.01 and 0.052 W/kg). Results
showed that neither the pulse height of muscle contrac-
tions nor the time interval between two subsequent con-
tractions were affected, but the latency period (time
interval between stimulus and response) was statistically
significantly altered in the RFR-exposed samples. They
concluded the results supported earlier reports of non-
thermal effects of EMF on amphibians including the effects
on the pattern of muscle contractions. Control sham
exposed samples showed no effects.

Amphibians, reptiles: ELF-EMF

Amphibians are highly sensitive to ELF-EMF. An early-1969
study by Levengood [485] using a magnetic field probe
found increased high rates of teratogenesis in frogs (Rana
sylvatica) and salamanders (Ambystoma maculatum). Two
identical probes using different field strengths were
employed — both operated in the kilogauss region with
high field gradients. Amphibian eggs and embryos were
exposed at various stages of development with gross ab-
normalities found in developing larvae vs. control. At the
hatching stage severe abnormalities were noted in both
anuran and urodele larvae from probe-treated eggs.
Hatching abnormalities included microcephaly, altered
development, and multiple oedematous growths. In probe-
treated frogs there was a delay in the appearance of a high
percentage of malformations until the climax stage of
metamorphosis. Until that stage, the larvae were of the
same appearance as control specimens, thus camouflaging
the damage after just a brief treatment of early embryos.
The frog abnormalities at metamorphosis differed from
those in the hatching tadpoles and consisted mainly of
severe subepidermal blistering and leg malformations
including formation of multiple deformed limbs incom-
patible with life. Over 90% of the morphological alterations
at metamorphosis climax were also found to be associated
with deformed kidneys. The gastrula stages of develop-
ment appeared to be the most sensitive in the delayed-
effects category. While this was a high-field exposure
experiment, it is an intensity that is found in some envi-
ronments today especially near high tension lines and in
abnormal ground current situations.

Neurath [486] also found strongly inhibited early em-
bryonic growth of the common leopard frog (Rana pipiens)
by a high static magnetic field with a high gradient (IT) —
an exposure sometimes found in the environment — while
Ueno and Iwasaka [487] found abnormal growth and


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increased incidence of malformations in embryos exposed
to magnetic fields up to 8T but exposures that high are
typically near industrial sites and rarely found in nature.

Severini et al. [488] specifically addressed whether
weak ELF magnetic fields could affect tadpole develop-
ment and found delayed maturation in tadpoles. Two co-
horts of X. laevis laevis (Daudin) tadpoles were exposed for
60 days during immaturity to a 50 Hz magnetic field of
63.9-76.4 [iT rms (root mean square, average values)
magnetic flux density in a solenoid. Controls were two
comparable cohorts remotely located away from the sole-
noid. The experiment was replicated three times. Results
showed reduced mean developmental rate of exposed co-
horts vs. controls (0.43 vs. 0.48 stages/day, p< 0.001)
beginning from early larval stages; exposure increased the
mean metamorphosis period of tadpoles by 2.4 days vs.
controls (p< 0.001); and during the maturation period,
maturation rates of exposed vs. control tadpoles were
altered. No increases in mortality, malformations, or tera-
togenic effects were seen in exposed groups. The re-
searchers concluded that relatively weak 50 Hz magnetic
fields can cause sub-lethal effects in tadpoles via slowed
larval development and delays in metamorphosis. Such
exposures are found in the environment today in some
locations and even though the changes were small,
coupled with climate change, such sub-lethal effects may
impact some wildlife populations in some environments.

In similar followup work, Severini and Bosco [489]
found sensitivity to small variations of magnetic flux den-
sity (50 Hz, 22-day continuous exposure, magnetic flux
densities between 63.9 and 76.4 (iT) in tadpoles exposed to
a stronger field vs. controls exposed to a weaker field. A
significant delay in development of 2.5 days was found in
exposed vs. controls. They concluded the delay was caused
by the slightly different magnetic flux densities with results
suggesting a field threshold around 70 ^T in controlling the
tadpole developmental rate.

Schlegel in 1997 found European blind cave salaman-
ders (Proteus anguinus) and Pyrenean newts (Euproctus
asper) to be sensitive to low level electric fields in water
[490]. And Schlegel and Bulog [491] in followup work
found thresholds of overt avoidance behavior to electric
fields as a function of frequency of continuous sine-waves
in water. Nine salamanders from different Slovenian pop-
ulations of the urodele (P. anguinus) that included three
specimens of its 'black' variety (P. anguinus parkelj)
showed thresholds between 0.3 mV/cm (ca 100 nA/cm2)
and up to 2 mV/cm (670 nA/cm2), with the most reactive
frequencies around 30 Hz. Sensitivity included a total fre-
quency range below 1 Hz (excluding DC) up to 1-2 kHz with
up to 40 dB higher thresholds. These are ranges that may

be found in the wild near high tension lines and utility
grounding practices near water, by some underwater ca-
bling, and by some RFR transmitters.

Landesman and Douglas in 1990 [492] found some
newt species showed accelerated abnormal limb growth
when pulsed electromagnetic fields were added to the
normal limb regeneration process. While normal limb
regeneration found normal regrowth patterns in 72% of
specimens, 28% were abnormal. Abnormalities included
loss of a digit, fused carpals, and long bone defects which
occurred singly or in combination with one another. When
exposure to a PEMF was added for the first 30 days post-
amputation, followed by a 3-4 month postamputation
period, a group of forelimbs with unique gross defects
increased by an additional 12%. Defects (singly or in
combination) included the loss of two or more digits with
associated loss of carpals, absence of the entire hand
pattern, and abnormalities associated with the radius and
ulna. The researchers offered no explanation. Exposure
intensities were similar to those used to facilitate non-
juncture fracture healing in humans.

Komazaki and Takano in 2007 [493] found accelerated
early development growth rates with 50 Hz, 5-30 mT
alternating current exposures in the fertilized eggs of Jap-
anese newts (Cynops pyrrhogaster). The period of gastru-
lation was shortened via EMF-promoted morphogenetic
cell movements and increased [Ca2+]j. They said their re-
sults indicated that EMF specifically increased the [Ca2]j of
gastrula cells, thereby accelerating growth. This study only
observed through the larval stages and they did not see any
malformations under EMF exposures, which they attrib-
uted to possible differences in the intensity and mode of
EMF.

With amphibians and some reptiles demonstrating
high sensitivity to natural background EMF for important
breeding and orientation needs, amphibians living in
aquatic, terrestrial, and aerial environments (i.e. tree frog
species) may be affected from multi-frequency anthropo-
genic EMF in ways we do not fully understand. There are
potential effects — especially from 5G MMW that couple
maximally with skin — to all aspects of their development
and life cycles, including secondary effects.

Fish, marine mammals, lobsters,
and crabs

Aquatic animals are exquisitely sensitive to natural EMF
and therefore potentially to anthropogenic disturbance.
The Earth's dipole geomagnetic field yields a consistent


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Levitt et al.: EMF and wildlife — 43

though varying source of directional information in both
land and aquatic species for use in homing behavior,
orientation during navigation and migration. This infor-
mation is used both as a 'map' for positional information as
well as a 'compass' for direction [494-497]. Aquatic species
are known to be sensitive to static geomagnetic fields, at-
mospheric changes and sunspot activities [498]. For recent
comprehensive reviews on magnetic field sensitivity in fish
and effects on behavior, see Tricas and Gill [36] and Krylov
et al. [33]. Some biological 'magnetic maps' may be
inherited [499]. And for a recent extensive discussion of the
Earth's natural fields and magnetoreception in marine
animals with a focus on effects from electromagnetic sur-
veys that use localized strong EMFs to map petroleum de-
posits under seabeds, see Nyqvist et al. [498] and below.

As mentioned above, because of the difference in
conductivity of water and other factors, the way some
aquatic species sense EMF may rely on unique modes of
physiological perception, as well as those employed by
terrestrial animals. There may also be sensory combina-
tions not yet understood in some aquatic and semi-aquatic
species. For instance, what role does the neural conduc-
tivity of whiskers (vibrissae) in seals, sea lions and walrus
play other than for food finding? Aquatic species' dense
network of whiskers is larger with greater blood flow than
terrestrial species and can contain 1,500 nerves per follicle
vs. cats at 200 per follicle. Seal whiskers also vary
geometrically from terrestrial species and the largest part
of the seal brain is linked to whisker function. Seals use
whiskers to map the size, shape and external structure of
objects and can find prey even when blindfolded. Their
whiskers are also sensitive to weak changes in water mo-
tion [100]. But are they also using them as a location or
directional compass in relation to the geomagnetic field?
That has yet to be studied.

Unique sensory differences in aquatic species have long
been documented. Joshberger et al. [500] noted that in 1,678
Stefano Lorenzini [501] was the first to describe a network of
organs in the torpedo ray that became known as the Ampullae
of Lorenzini (AoL). Its purpose was unknown for 300 years
until Murray [502] measured AoL's electrical properties in
elasmobranch fish — sharks, rays and skates. Later work [101,
503-508] confirmed and greatly added to this knowledge.
Researchers now know that AoL is likely the primary mecha-
nism that allows elasmobranch fish to detect and map a po-
tential prey's physiology via the very weak changes in electric
fields given off by prey's muscle contractions.

Individual ampullae are skin pores that open to the
aquatic environment with a jelly-filled canal leading to an
alveolus containing a series of electrosensing cells. Within
the alveolus, the electrosensitive cells of the ampullae

communicate with neurons and this integration of signals
from multiple ampullae is what allows elasmobranch fish to
detect electric field changes as small as 5 nV/cm [503, 506,
509,510]. The AoL jelly has been reported as a semiconductor
with temperature-dependence conductivity and thermoelec-
tric behavior [500, 509, 510], as well as a simple ionic
conductor with the same electrical properties as the sur-
rounding seawater [503,506]. Josberger et al. [500] attempted
to clarify what AoL's role is in electrosensing by measuring
AoL's proton conductivity. They found that room-
temperature proton conductivity of AoL jelly is very high at
2 ฑ 1 mS/cm — only 40-fold lower than some current state-of-
the-art manmade proton-conducting polymers. That makes
AoL the highest conductive biological material reported thus
far. They suggested that the polyglycans contained in the AoL
jelly may contribute to its high proton conductivity.

Other aquatic magneto-sensory mechanisms more in
harmony with terrestrial animals include the presence of
ferromagnetic particles in magnetite — tiny naturally pro-
duced magnets that align with the Earth's magnetic field,
allowing for species' direction and orientation. Magnetite ap-
pears to transmit necessary information through a connection
with the central nervous system [340, 497, 511]. A magnetite-
based system is plausible for cetaceans [512,513] as magnetite
has been found in the meninges dura mater surrounding the
brains of whales and dolphins [514,515]. There is also evidence
that local variations/anomalies in the geomagnetic field in
certain underwater topographies may play a role in live ceta-
cean standings [516,517] which indicates a magnetic compass
based on magnetite. And free-ranging cetaceans have shown
evidence of magnetoreception-based navigation, e.g., Fin
whale migration routes have been correlated with low
geomagnetic intensity [513].

Recently, Granger et al. [518] found correlations in data
between 31 years of gray whale (Eschrichtius robustus)
strandings and sunspot activity, especially with RF 'noise'
in the 2,800 MHz range. The 11-year sunspot cycle strongly
correlates with the intense releases of high-energy particles
known as solar storms which can temporarily modify the
geomagnetic field, and in turn may modify orientation in
magnetoreceptive species. Solar storms also cause an in-
crease in natural broadband RF 'noise'. They examined
changes in both geomagnetic fields and RF 'noise' and
found RF to be a determinant. Further, they hypothesized
that increased strandings during high solar activity is more
likely due to radical pair mechanisms which are more
reactive with RFR than magnetite, which appears more
reactive to ELF-EMF. Two previous studies also found
correlations with cetacean strandings and solar activities
[519, 520]. Both mechanisms may come into play under
different circumstances or act in synergy.


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Kremers et al. [512] investigated the spontaneous
magnetoreception response in six captive free-swimming
bottlenose dolphins (Tursiops truncates) to introduced
magnetized and demagnetized devices used as controls.
They found a shorter latency in dolphins that approached
the device containing a strong magnetized neodymium
block compared to a control demagnetized block identical
in form and density and therefore indistinguishable with
echolocation. They concluded that dolphins can discrimi-
nate on the basis of magnetic properties — a prerequisite
for magnetoreception-based navigation. Stafne and
Manger [521] also observed that captive bottlenose dol-
phins in the northern hemisphere swim predominantly in a
counter-clockwise direction while dolphins in the southern
hemisphere swim predominantly in clockwise direction.
No speculation was offered for this behavior.

How salmon navigate vast distances — from their
hatching grounds in freshwater river bottoms to lakes
during juvenile growth, then the open ocean during
maturity, and with a final return to their neonatal birthing
grounds to spawn and die (for most anadromous salmo-
nids) — has fascinated researchers for decades. Research in-
dicates they may use several magneto-senses to accomplish
this, including inherited mechanisms [522], imprinting [499,
522], a magnetic compass [499, 522, 523], and biomagnetic
materials. Salmon have been found to have crystal chains of
magnetite [524]. One recent study found that strong magnetic
pulses were capable of disrupting orientation in salmon
models [525], indicating a magnetite-based mechanism. In
salmon, the migration process is complicated by the fact that
the ability to sense geomagnetic fields can be altered by
changes in salinity between fresh and salt water, thus
pointing to multi-sensory mechanisms [499].

Speculation that salmon use the geomagnetic field in
some capacity for their iconic migration goes back decades
[526]. Quinn [527] found evidence that sockeye salmon
(Oncorhynchus nerka) frey use both a celestial and magnetic
compass when migrating from river hatching to lakes. Put-
man et al. [499], who have written extensively on this subject,
focused on how salmon navigate to specific oceanic feeding
areas — a challenge since juvenile salmon reach feeding
habitats thousands of kilometers from natal locations. The
researchers experimentally found that juvenile Chinook
salmon (Oncorhynchus tshawytscha) responded to magnetic
fields similar to latitudes of their extreme ocean range by
orienting in directions that would lead toward their marine
feeding grounds. They further found that fish use the com-
bination of magnetic intensity and inclination angle to assess
their geographic location and concluded that the magnetic
map of salmon appears to be inherited since the fish had no
prior migratory experience. These results, paired with

findings in sea turtles (see below), indicate that magnetic
maps are widespread in aquatic species and likely explain the
extraordinary navigational abilities seen in long-distance
underwater migrants [499].

It is less likely that light-sensing radical pair crypto-
chromes play much of a role in aquatic species though
some hypothesize the possibility [528]. Krylov et al. [33],
however, noted that there are no anatomical structures or
neurophysiological mechanisms presently known for
radical pair receptors in the brains of fish and that since
light decreases with water depth and fish are capable of
orienting in complete darkness using the geomagnetic
field, their opinion was that it is too early to say fish have
magnetoreception mechanisms based on free radicals,
light-dependent or otherwise.

Fish, lobsters, crabs: ELF-EMF

For several reasons having to do with differences in con-
ductivity in water vs. air (see above), RFR is of far less
concern in aquatic environments at present than is ELF.
With the ever-increasing number of underwater cables
used for everything from transcontinental data/commu-
nications to power supplies for islands, marine platforms,
underwater observatories, off-shore drilling, wind facil-
ities, tidal and wave turbines among others, many new
sources of both AC and DC electric current are being
created in sea and freshwater environments alike. Ac-
cording to Ardelean and Minnebo writing in 2015 [529],
almost 4,971 mi (8,000 km) of high voltage direct current
(HVDC) cables were present on the seabed worldwide, 70%
of which were in European waters, and this is only ex-
pected to grow dramatically as new sources of renewable
energy are built to replace fossil fuels globally.

Curiosity about potential adverse effects from cable-
generated ELF-EMF on all phases of fish life has also
grown, especially in benthic and demersal species that
spend significant time near cables in deeper bottom envi-
ronments for egg laying, larvae growth, and development
for most, if not all, of their adult lives.

Fey et al. [494, 495] and Ohman et al. [530] noted that
there are two types of anthropogenic exposures created by
cables: high voltage direct current (HVDC) that emits static
magnetic fields, and three-phase alternating current (AC
power transmission) that emit time-varying electromag-
netic fields. The density of electric current near underwater
cables on the sea floor can vary significantly depending on
the type of cable and whether they are positioned on the
sea bottom or buried [36, 530]. Noticeable magnetic field
changes can occur within meters but generally not more


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Levitt et al.: EMF and wildlife — 45

than several meters from the cable. However, Hutchinson
et al. [531], in a robust field study and extensive review,
found surprisingly stronger and more complex exposures
than anticipated (see below).

Since fish are highly sensitive to static magnetic fields
(MF), it is important to delineate static fields from anthro-
pogenic alternating current EMF in aquatic studies. In
freshwater species under laboratory conditions, Fey et al.
[494] found similar results to those of salmon studies
(noted above) in northern pike (Esox lucius) exposed to a
static magnetic field from DC cables (10 mT) during the
embryonic phase and in the first six days of post-hatching.
No statistically significant MF effect was seen on hatching
success, larvae mortality, larvae size at hatching, and
growth rate during the first six days of life. However, sig-
nificant MF effects were seen on hatching time (one day
earlier in a magnetic field than in control), yolk-sac size
was smaller, and yolk-sac absorption rate was faster. They
interpreted the faster yolk-sac absorption in a magnetic
field as an indication of increased metabolic rate but added
that even if some negative consequences were expected as
a result, that the actual risk for increased northern pike
larvae mortality seemed negligible. Though higher than
10 mT magnetic field values are hazardous for fish larvae,
they added such values do not occur in the natural envi-
ronment even along underwater cables.

But in follow-up work of longer duration the same
general research group reached a different conclusion. Fey
et al. [495] studied effects on eggs and larvae of rainbow
trout (Oncorhynchus mykiss) exposed to a static magnetic
field (MF) of 10 mT and a 50 Hz EMF of 1 mT for 36 days
(i.e., from eyed egg stage to approximately 26 days post
hatching). They found that while neither the static MF nor
the 50-Hz EMF had significant effects on embryonic/larval
mortality, hatching time, larval growth, or the time of
larvae swim-up from the bottom, both fields did however
enhance the yolk-sac absorption rates. While they said this
was not directly related to a MF effect, it was shown that
larvae with absorbed yolk-sacs by the time of swim-up were
less efficient in taking advantage of available food at first
feeding and gained less weight. They concluded that these
exposures could negatively affect the yolk-sac absorption
rate thereby hampering fish in important feeding activities
needed for fast weight gain and increased survival. In an
additional study, Fey et al. [532] observed that rainbow
trout reared in a laboratory for 37 days and exposed to a
static MF (10 mT) or a 50-Hz EMF (1 mT) showed defects in
otolith of the inner ear which is responsible for hearing and
balance in fish. The authors concluded that underwater
construction and/or cables that emit a MF of 10 mT or
higher can affect living organisms within a few meters

distance, especially species like trout in settled life stages
on the sediment bottom during early development.

Zebrafish (Danio rerio) are often used in EMF research in
toxicology and developmental biology investigating effects
on humans because the genomes are so similar. Li et al. [533]
studied ELF-MF on the development of fertilized zebrafish
embryos divided into seven groups. Embryos of experi-
mental groups were continuously exposed to 50-Hz sinu-
soidal MF with intensities of 30,100,200,400, or 800 |aT for
96 h. The sham group was identical but without ELF-MF
exposure. Results showed that ELF-MF caused delayed
hatching and decreased heart rate at early developmental
stages but no significant differences were seen in embryo
mortality or abnormality. Acridine orange staining assays
showed notable signs of apoptosis in the ventral fin and
spinal column and transcription of apoptosis-related genes
(caspase-3, caspase-9) was significantly up-regulated in
ELF-MF-exposed embryos. They concluded that ELF-EMF
demonstrated detrimental effects on zebrafish embryonic
development, including on hatching, decreased heart rate,
and induced apoptosis, although such effects were not a
mortal threat. The lower range exposures of this study are
found in some aquatic environments.

Sedigh et al. [534] investigated effects on zebrafish
exposed to static magnetic fields. Exposures of 1-week acute
and 3-week subacute exposures to different static magnetic
fields at 2.5, 5, and 7.5 mT were measured on stress indices
(Cortisol and glucose), sex steroid hormones (17(3-estradiol
and 17-a hydroxy progesterone) and fecundity. They found a
significant change in Cortisol, glucose, 17(3-estradiol (Ez) and
17-a hydroxy progesterone (17-OHP) levels with increased
intensity and duration of exposure and concluded that static
magnetic fields at higher intensities showed harmful effects
on the reproductive biology of zebrafish during both acute
and subacute exposures.

Recent laboratory research by Hunt et al. [535] used the
transparent glass catfish (Kryptopterus vitreolus) found in
slow moving waters in Southeast Asia as a model to
investigate magnetoreception. The study used Y-maze
chambers, animal tracking software and artificial intelli-
gence techniques to quantify effects of magnetic fields on
the swimming direction of catfish. They placed a perma-
nent Neodymium Rare Earth Magnet (11.5 x 3.18 x 2.2 cm)
with a horizontal magnetic flux of 577 mT at the magnet's
surface at 10 cm from the end of one of the Y-maze arms and
found that catfish consistently swam away from magnetic
fields over 20 |aT. The catfish also showed adaptability to
changing magnetic field direction and location. The mag-
netic avoidance was not influenced by school behavior.
Sham exposures produced no avoidance. Such exposures
might be found near some underwater cables.


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To further elucidate findings of species reactions near
underwater cables and fill in knowledge gaps since the
2011 Tricas and Gill review [36], Hutchinson et al. [531]
conducted both field and laboratory modeling studies of
both AC and DC fields on the American lobster (Homarus
americanus) and the little skate (Leucoraja erinacea). They
noted that in previous studies, while behavioral responses
had been seen, findings were unable to determine if sig-
nificant biological effects (e.g., population changes)
occurred. The American lobster was modeled because it is a
magnetosensitive species [536] and concern existed that
EMF from cables might restrict movements and/or migra-
tion. Lobsters may migrate up to 50 mi (80 km) one way
from deep waters to shallow breeding grounds. The little
skate was used as a model for the most electro-sensitive
taxa of the elasmobranchs, which may be attracted by/to
the EMF of cables, particularly for benthic species, thereby
altering their foraging or movement behavior. Both models
were therefore thought indicative of potential EMF im-
pacts. In this robust field study, the researchers found that
the American lobster exhibited a statistically significant
but subtle change in behavioral activity when exposed to
the EMF of the HVDC cable (operated at a constant power of
330 MW at 1,175 Amps). The little skate exhibited a strong
behavioral response to EMF from a cable powered for
62.4% of the study with the most frequently transmitted
electrical current at 16 Amps (at 0 MW, 37.5% of time), 345
Amps (100 MW, 28.6%) and 1,175 Amps (330 MW, 15.2%).
They concluded that for both species, the behavioral
changes have biological relevance regarding how they will
move around and are distributed in a cable-EMF zone, but
they noted that the EMF did not constitute a barrier to
movements across the cable for either species.

Of interest in this study were the actual field readings
near cables. Unexpected significant AC magnetic and electric
fields did not match computer models and were observed to
be associated with both of the DC power cables studied. The
maximum observed AC values along the cable axis were
0.15 (iT and 0.7 mV/m for the magnetic and electric fields
respectively for one cable, and 0.04 (iT and 0.4 mV/m
respectively, for the other cable. Also, the cross section of the
EMF peaks exhibited by the DC subsea power cables were
broader than anticipated at both studied. The DC and AC
magnetic fields reached background levels on either side of
the cable on a scale of c.a.5 and 10 m from the peak observed
value respectively, whereas the AC electric fields reached
background on a scale of 100 m (328 ft) from the peak value.
Peak observed values occurred almost directly above the
cable axis location; there was an offset of 3.3 ft (<1 m) where
the cable was twisted. The researchers noted that this
observation of AC fields, with broad areas of EMF distortion

being associated with DC cables, increased the complexity of
interpreting the studies of EMF's biological effects from DC
cables. The AC electric fields associated with the AC sea2shore
cable (1-2.5 mV/m) were higher than the unanticipated AC
electric fields produced by the DC cables (0.4-0.7 mV/m). The
magnetic field produced by the AC sea2shore cable (range of
0.05-0.3 (iT) was -10 times lower than modeled values
commissioned by the grid operator, indicating that the three-
conductor twisted design achieves significant self-
cancellation. This entire aspect of the study indicates the
need for accurate field assessment, not just computer
modeling, and well-designed systems since anomalies occur.

Nyqvist et al. [498] in a thorough review, focused on
marine mammals and the use of underwater electromag-
netic surveys that map petroleum deposits in seabeds via
strong induced EMFs in varied directional applications.
They found that EMFs created during such active surveying
were within the detectable ranges of marine animals and
the fields can potentially affect behavior in electro-
perceptive species, but they noted that effects should be
limited to within a few kilometers as the electric and
magnetic fields created attenuate rapidly. They added that
in migrating marine animals, exposures are of short
duration and most are close to naturally occurring levels
but cautioned that lack of studies is a concern, especially
for the most sensitive elasmobranchs at highest risk for
disturbance to electric fields. They also noted that with
induced magnetic fields, animals using magnetic cues for
migration or local orientation during certain time-windows
for migration, orientation, or breeding, could be most
affected by this surveying technology.

Taorimina et al. [537] studied both static and time-
varying magnetic fields on the behavior of juvenile Euro-
pean lobsters (Homarus gammarus). Using two different
behavioral assays, day-light conditions to stimulate shel-
tering behavior and exposures to an artificial magnetic
field gradient (maximum intensity of 200 |aT), they found
that juvenile lobsters did not exhibit any behavioral
changes compared to non-exposed lobsters in the ambient
magnetic field. No differences were noted on the lobsters'
ability to find shelter or modified their exploratory
behavior after one week of exposure to anthropogenic
magnetic fields (225 ฑ 5 (iT) which remained similar to
behavior in controls. They concluded that neither static nor
time-varying anthropogenic magnetic fields at those in-
tensities significantly impacted the behavior of juvenile
European lobsters in daylight conditions, but they noted
that evidence exists showing magnetosensitivity changes
during different life stages in lobster species, and that since
their modeling was on juveniles, their study was therefore
an incomplete picture requiring further study.


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Levitt et al.: EMF and wildlife — 47

Scott et al. [538] focused on ELF-EMF effects on
commercially important edible/brown crab species (Can-
cer pagurus) and what they found was startling. In labo-
ratory tanks, they simulated EMF (with Helmholtz coils,
2.8 mT evenly distributed, assessments during 24 h pe-
riods) that would be emitted from sub-sea power cables
now commonly used at offshore renewable energy facil-
ities. They measured stress related parameters ((L-lactate,
D-glucose, haemocyanin and respiration rate) along with
behavioral and response parameters (antennal flicking,
activity level, attraction/avoidance, shelter preference and
time spent resting/roaming). They found that although
there was no EMF effect on haemocyanin concentrations,
respiration rate, activity level or antennal flicking rate,
there were significant changes in haemolymph L-lactate
and D-glucose natural circadian rhythms, indicating al-
terations in hormones. Crabs also showed an unusually
high attraction to EMF-exposed shelter areas (69%)
compared to control shelter areas (9%) and significantly
reduced their time roaming by 21%, with adverse impli-
cations for food foraging, mating, and overall health. They
noted that EMF clearly altered behavior. Crabs spent less
time roaming around the tank and more time in a shelter in
direct contact with the EMF source, indicating natural
roaming/food-or-mate-seeking behavior had been over-
ridden by attraction to EMF. In fact, crabs consistently
chose an EMF-exposed shelter over a non-exposed one and
were always drawn to the EMF. The results appear to
predict that in benthic areas surrounding EMF-emitting
cables, there will be an increase in the abundance of
Cancer pagurus present. They noted that such potential
crab aggregation around benthic cables and the subse-
quent physiological changes in L-lactate and D-glucose
levels caused by EMF exposure, is a concern regarding
feeding rates, mating, and especially egg incubation
directly in increased EMF environments. They concluded
that long term investigations are needed regarding chronic
EMF exposure, especially on egg development, hatching
success and larval fitness, and added that EMF emitted in
marine environments from renewable energy devices must
be considered as part of the study of cumulative impacts
during the planning stages.

Clearly ELF-EMF can affect myriad aquatic species at
intensity levels found in proximity to underwater cables at
environmental intensities.

Fish: RF-EMF

As mentioned, RFR is of minimal environmental concern
for fish since aquatic environments, while highly

conductive mediums, also highly attenuate EMF at higher
frequencies. This may change in the near future as new
technologies now exist that may surpass these obstacles [98],
thereby introducing for the first time novel new RFR expo-
sures underwater. Longer wave wireless ELF with expanded
ranges are used in anthropogenic sonar (sound navigation
ranging), primarily for military applications. These travel
easily through water and are known to adversely affect ce-
taceans and other species that rely on their natural sonar for
communication, migration, reproduction and food finding.
But sound waves are not considered "EMF" in the strict sense
of the term; since the focus of this paper is EMF, sound waves
are tangential here. But acoustic damage, especially to ceta-
ceans from military and commercial applications, is well
documented and ELF cables used for underwater military
submarine communications can have significant EMF expo-
sures near cables. Just because this paper does not address
impacts from sound waves in detail does not mean they are
without serious effects.

There are, however, three recent studies of RFR on
zebrafish included here because it is plausible that such
exposures could exist near shallow aquatic environments
under some circumstances. Nirwane et al. [539] studied
900-MHz GSM RFR effects on zebrafish (D. rerio) neuro-
behavioral changes and brain oxidative stress as a model
for human exposures to cell phones. Exposures were
applied daily for 1 h, 14 days, with SAR 1.34 W/Kg. They
found 900-MHz GSM radiation significantly decreased so-
cialization and increased anxiety as demonstrated by sig-
nificant increased time spent in bottom areas, freezing
behaviors, and duration and decreased distance travelled,
as well as decreased average velocity and number of en-
tries to the upper half of the tank. Exposed zebrafish spent
less time in the novel arm of a Y-Maze indicating significant
impaired learning compared to the control group. Expo-
sure also decreased superoxide dismutase (SOD) and
catalase (CAT) activities while increased levels of reduced
glutathione (GSH) and lipid peroxidation (LPO) were
encountered indicating compromised antioxidant defense.
Post-exposure treatment with melatonin in the water,
however, significantly reversed the induced neuro-
behavioral and oxidative changes.

Piccinettia et al. [540] investigated in vivo effects on
embryonic development in zebrafish at 100 MHz thermal
and nonthermal intensities via a multidisciplinary proto-
col. Results found 100 MHz RFR affected embryonic
development from 24 to 72 h post fertilization in all the
analyzed pathways. Most notably at 48 h post fertilization,
reduced growth, increased transcription of oxidative stress
genes, onset of apoptotic/autophagic processes and a
modification in cholesterol metabolism were seen. EMF


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48 — Levitt et al.: EMF and wildlife

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affected stress by triggering detoxification mechanisms. At
72 h post fertilization, fish partially recovered and reached
hatching time comparable to controls. The researchers
concluded that EMF-RFR unequivocally showed in vivo
effects at non-thermal levels.

Dasgupta et al. [541] used embryonic zebrafish models
at 3.5 GHz SAR = 8.27 W/kg and exposed developing
zebrafish from 6 to 48 h post fertilization, then measured
morphological and behavioral endpoints at 120 h post
fertilization. Results found no significant impacts on mor-
tality, morphology or photomotor response but noted a
modest inhibition of startle response suggesting some
levels of sensorimotor disruptions. They concluded that
exposures at low GHz levels are likely benign but never-
theless entailed subtle sensorimotor effects. Such effects
can affect fish survival in various ways, including inhibited
response time to predators, among others. This study was
done with an eye toward potential human bioeffects at
frequencies used in 4 and 5G technology. It was also con-
ducted at intensities higher than the focus of this paper.

If new technology overcomes the conductivity/atten-
uation limitations of aquatic environments and introduces
more RFR to aquatic species, studies like those cited above
may soon have more environmental relevance, even at
higher intensities than explored here.

Turtles

Oceanic sea turtle migration joins that of other renowned
long-distance migratory species like salmon and over-land
monarch butterfly treks, spanning thousands of kilometers
and traversing multiple complex environments throughout
their life cycles. Sea turtles have long been known to use
geomagnetic fields for orientation [542, 543]. Freshwater
species (e.g., Chelydra serpentina) have also been shown to
have a magnetic sense capable of artificial disruption [92]
as do terrestrial box turtles (Terrapene Carolina; [544]).

Sea turtles demonstrate natal homing behavior — the
ability to return over great distances to their exact birth
location to reproduce [89] and because of anthropogenic
disruptions of nesting grounds along beaches, this repro-
ductive homing drive imperils them today. The underlying
mechanism is still imperfectly understood but involves
'imprinting' of the intensity and inclination angle of the
geomagnetic field at the birth location [545]. The informa-
tion is then later used in maturity to return to their place of
origin.

Sea turtles are by far the most studied models for turtle
magnetoreception, especially by the Lohmann Laboratory
at the University of North Carolina, U.S. [323, 546-558].

Irwin and Lohmann [559] discussed the advantages
and disadvantages of various research approaches used to
investigate magnetic orientation behavior in turtles. These
include the use of large magnetic coil systems in laboratory
settings to generate relatively uniform fields over large
areas [560] which allow the magnetic field to be artificially
altered and carefully controlled to determine changes in
behavioral orientation. This approach, however, is un-
suited for manipulating exposures around animals in
natural environments or for studying localized body mag-
netoreceptors, which in turtles are still a mystery. Another
approach is to attach a small magnet or electromagnetic
coil to an animal to disrupt magnetic orientation
behavior — a far easier approach in hatchlings than in
juvenile or mature free-swimming species. They note that if
the imposed field from an attached magnet or coil is strong
enough to interfere with the Earth's field, behavioral
orientation changes [116, 544, 561] and the performance of
a conditioned response [367, 562] can be observed. This
latter approach has been used in field studies for the pur-
pose of blocking access to normal magnetic information
[544, 561, 563-565] and to localize magnetoreceptors by
disrupting the field around a specific terrapin body part
[562]. This technique's disadvantage, however, is that
fields rapidly change with distance from the source, mak-
ing it difficult to quantify the fields that the animal actually
experiences.

Most sea turtle studies have involved large magnetic
coil systems but Irwin and Lohmann [559] attached small
magnets greater in strength than the Earth's fields to two
groups of loggerhead sea turtle hatchlings (Caretta caretta
L.) under laboratory conditions in which turtles are known
to orient magnetically [473,546,548-550]. They found that
magnetic orientation behavior in hatchling turtles can be
disrupted via small magnets attached to the carapace
which then create exposures over the entire body. They
concluded that such an approach can be used to finally
determine local magnetoreceptors by varying the location
of the magnet and using smaller, weaker magnets that alter
the field only around specific anatomical target sites.

In loggerhead sea turtles, there is evidence of an
inclination compass [473,550] that is functionlly similar to
the bird magnetic compass reported in European Robins
[566, 567]. Lohmann and Lohmann [550] investigated an
inclination compass in sea turtles and found it was a
possible mechanism for determining latitude. Also inves-
tigated were detection of magnetic intensity [551]; natural
regional magnetic fields used as navigational markers for
sea turtles [557]; and sea turtle hatchlings' mapping abili-
ties [545]. Sea turtles are also known to have magnetite in
their heads [104, 568]. Studies with young sea turtles have


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Levitt et al.: EMF and wildlife — 49

shown that a significant portion of their navigational
abilities involve magnetoreception following hatching
[569] — imprinting with the Earth's magnetic field being
one of several cues hatchlings use as they first migrate
offshore [546, 554]. The magnetic fields that are unique to
different areas at sea eventually serve as navigational
markers to guide swimming direction to important migra-
tory routes. As juveniles mature, they form topographical
magnetic maps where they live that direct them to specific
regions. But it has remained largely unknown if mature
turtles, specifically nesting females, use such mechanisms
in open-sea homing as this magneto-sense may change
over time.

Field studies are notoriously difficult with large spe-
cies at sea but Papi et al. [564] studied mature green turtles
(Chelonia mydas) during their post-nesting migration over
1,243 mi (2,000 km) from their nesting grounds on Ascen-
sion Island in the middle of the Atlantic Ocean back to their
Brazilian feeding grounds. They were investigating
whether mature female turtles use an inclination compass
and geomagnetic fields for direction, or by inference (once
that sense is disturbed) by some other means as yet
determined. Papi et al. [564] attached very strong DC
magnets — significantly stronger than the Earth's fields —
to disturb and overcome natural magnetoreception, and
thereby determine if they could still navigate back to As-
cension Island. Controls had nonmagnetic brass bars
attached and some had transmitters glued to their heads.
All had tracking devices that communicated with satellites,
thus creating strong multi-frequency static and pulsed RFR
exposures. Seven turtles were each fitted with six powerful
static magnets that produced variable artificial fields sur-
rounding the whole turtle, making reliance on a geomag-
netic map impossible. The study's travel courses were very
similar to those of eight turtles without magnets that had
been tracked via satellite over the same period in the pre-
vious year. No differences between the magnetically
exposed test turtles and untreated turtles were found
regarding navigational performance and general course
direction. They concluded that magnetic cues were not
essential to turtles on the return trip and speculated that
perhaps other factors such as smell or wave current di-
rection may come into play.

Luschi et al. [563], like Papi et al. [564], also investi-
gated the role of magnetoreception and homing in mature
sea turtles but used a different design and found very
different results. In a large field study in the Mozambique
Channel, 20 mature pre-nesting green turtles were also
equipped with both strong magnets and satellite tracking
devices. The turtles were gathered at their nesting beach on
Mayotte Island before egg-laying and transported to four

open-sea sites 62-75 mi (100-120 km, respectively) away.
There were five releases of four turtles each with three
different treatments: turtles magnetically 'disturbed' only
during transportation with magnets removed before
release; those treated only during the homing trip with
magnets attached just prior to release; and controls with
nonmagnetic brass discs attached to their heads. Treated
turtles had very strong moveable magnets attached to their
heads to induce varying magnetic fields around them
either at the nesting beach at the start of the relocation
journey or on the boat just prior to release for the homing
trip. All groups had satellite transmitters attached to their
carapaces, thereby creating in the opinion of the authors of
this paper, an additional exposure that was not considered
as a variable. The researchers also included ocean currents
in their assessments, estimated by using oceanographic
remote sensing measurements. All but one turtle eventu-
ally returned to Mayotte to complete delayed egg-laying.
But treated turtles, whether treated during transportation
or homing, took significantly longer to reach the destina-
tion vs. controls — a surprising finding. Most homing
routes showed very long circuitous curved and looping
patterns before reaching their target. Control paths were
direct. Both treated turtle groups were clearly impaired by
the MF exposure, indicating significant recovery time
needed between exposure and correcting positional
behavior. The researchers hypothesized the existence of a
navigational role for geomagnetic information being
gathered by those turtles in the passive transportation
group, as well as the possibility that magnetic disturbance
during transportation may have persisted for some time
after the removal of the magnets in that group, thus
rendering the two treated groups functionally equivalent
during their homing journeys. They also noted that expo-
sures may have physically altered magnetite particles, thus
creating a longer lasting effect but they said that since long-
lasting after-effects of magnet application have not been
described, this theory could neither be inferred nor
dismissed.

Lohmann [323] reviewed both of the above studies and
added that in addition to the two causal hypotheses of
Luschi et al. [563] regarding their unexpected findings of
turtle circuitous migration routes, another explanation
would include the positioning of the satellite transmitters
in the Papi et al. [564] study on turtle heads vs. on the
carapace of the Luschi models. He added that since satel-
lite transmitters also produce magnetic fields capable of
disrupting magnetoreception, and since the Papi group
also attached satellite transmitters on the heads of several
control turtles, that re-analyzing the Papi study using only
turtles with satellite transmitters placed on the carapace


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like the Luschi study could show evidence consistent with
the hypothesis that adult turtles exploit magnetic cues in
navigation. He concluded that sea turtles, like all other
animals studied to date, likely exploit multiple cues for
navigation since even with artificial magnetic disturbance
causing impaired performance, the magnets in either study
did not prevent turtles from eventually reaching their
target beaches. This implies that turtles can also rely on
other sources of information [570, 571] such as celestial
compasses, wave direction [572], or olfactory cues like
other species — a significant finding.

The sum total of the studies mentioned above is that
sea turtle species are highly sensitive to Earth's fields and
are capable of adapting to subtle anthropogenic
disruption.

Turtles: RF-EMF

Turtles may also be senstitive to RFR, especially during
incubation while on land, and/or initial hatchling stages if
they are exposed to anthopogenic RF-EMF that could
distort the imprinting memory they use in later life to locate
their birthsite beaches again. For example, if a radar or
communications base station is installed on or near the
beach of a nesting site, could that affect the initial
"imprinting" process? Perhaps augment imprinting and
make return easier? Or conversely overwhelm the subtle
imprinting process at the start and make return impos-
sible? If the latter is valid, such technology could lead to
extinction of sensitive species since it interrupts the
reproduction process. In the very least, in sensitive species,
disorientation might result as discussed above.

To characterize the underlying compass mechanisms
in turtles, Landler et al. [92] studied freshwater juvenile
snapping turtles' (Chelydra serpentine) ability for sponta-
neous magnetic alignment to the Earth's geomagnetic
fields. Using exposure to low-level RFR near the Larmor
frequency (1.2 MHz) that is related to free radical pair for-
mation, turtles were first introduced to the testing envi-
ronment without the presence of RFR ("RF off, RF off") and
they were found to consistently align toward magnetic
north. But when subsequent magnetic testing conditions
were initially free of RFR, then included an introduced
signal ("RF off, RF on"), they became disoriented. Thus,
introduction of a RFR field could affect the turtles' align-
ment response to the natural magnetic field. The RFR field
used was only 30-52 nT (1.43 MHz). In the following reverse
scenario, when the turtles were initially introduced to the
testing environment with RFR present but then removed
("RF on, RF off"), they became disoriented when tested

without RFR. And with RFR on in both cases ("RF on, RF
on"), they aligned in the opposite direction toward mag-
netic south. Clearly test turtles were affected by the expo-
sures. The researchers concluded that the sensitivity of the
spontaneous magnetic alignment response of the turtles to
RFR was consistent with a radical pair mechanism (see
"Mechanisms" above). In addition, they concluded that the
effect of RFR appeared to result from a change in the
pattern of magnetic input, rather than elimination of
magnetic input altogether. Their findings indicated that
turtles, when first exposed to a novel environment, form a
lasting association between the pattern of magnetic input
and their surroundings, and that they may form a larger
internal GPS-like mapping ability when they meet any new
magnetic reference framework based on natural magnetic
cues, from multiple sites and localities.

They also showed that RFR at or near the Larmor fre-
quency (1.2-1.43 MHz) had the ability to disrupt snapping
turtle natural orientation, establish its own novel orienta-
tion, and completely reverse a natural orientation, leading
back to the complex questions asked above regarding
imprinting and possible reproductive disruption. Although
the Landler et al. study [92] was conducted in a freshwater,
non-homing species, snapping turtles are long-lived with a
low reproduction success rate. Even small disruptions to
this species from anthropogenic sources could have an
outsized population effect over time. If this freshwater
species is any indication of potential RFR effects, re-
searchers need to further investigate RFR in long-distance
migrating turtle species that imprint on land. We simply do
not know the full range of possible effects across fre-
quencies with which turtle species come in contact at
vulnerable points throughout development and lifetimes.

Nematodes and smaller biota

There are reports of sensitivity to EMF in lesser taxa as well.
EMF is known to affect numerous other species including:
nematodes (Earth and aquatic worms), mollusks (snails),
amoeba (single-celled organisms), molds, algae, pro-
tozoans, yeast, fungi, bacteria, and viruses (to a limited
extent) — with ramifications for creation of antibiotic
resistant bacteria strains. Below are some representative
examples of observed effects.

Nematodes

Common soil-based nematode species like C. elegans serve
as a useful whole-organism model for genetic and


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Levitt et al.: EMF and wildlife — 51

multicellular organism investigations. They are routinely
used as a research model to investigate key biological
processes including aging, neural system functioning, and
muscle degeneration, to name a few. This species' genetic
and phenotypic traits are extremely well documented and
they can thus be used as important proxies for quantitative
analyses [573]. Nematodes have a short lifespan, are her-
maphrodites, and demonstrate effects quickly. As lab
models they are used primarily for information that can be
applied to humans but we can also glean important in-
formation and extrapolate to environmental exposures
under certain circumstances. Healthy soil worm pop-
ulations are critical to soil health upon which we all
depend.

Hung et al. [574] investigated static magnetic field
(SMF) effects on life span and premature aging in
C. elegans. Nematodes were grown in SMFs varying from
0 to 200 mT. They found that SMF's accelerated develop-
ment and reduced lifespan in wild-type nematodes. They
also found increases in heat shock proteins that were se-
lective and dose dependent.

Vidal-Gadea et al. [66] investigated magnetic orienta-
tion in C. elegans to identify magnetosensory neurons and
found that they orient to the Earth's geomagnetic field
during vertical burrowing migrations. Well-fed worms
migrated up, while starved worms migrated down. Pop-
ulations isolated from around the world were found to
migrate at angles to the magnetic vector that would verti-
cally translate to their native soil, with northern- and
southern-hemisphere worms displaying opposite migra-
tory preferences in conjunction with natural geomagnetic
fields. They also found that magnetic orientation and ver-
tical migrations required the TAX-4 cyclic nucleotide-gated
ion channel in the AFD sensory neuron pair while calcium
imaging showed that these neurons respond to magnetic
fields even without synaptic input. They hypothesized that
C. elegans may have adapted magnetic orientation to
simplify their vertical burrowing migration by reducing the
orientation task from three dimensions to one.

C. elegans have also demonstrated sensitivity to elec-
tric fields via electrotaxis (also known as galvanotaxis)
which is the directed motion of living cells or organisms
guided by an electric field or current and often seen in
wound healing. Sukul and Croll [575] found that nema-
todes exposed to an electrical current (0.02-0.04 mA, po-
tential differences 2-6 V) demonstrated a directional
sensorily-mediated orientation toward the current at first,
but at 2 mm from the electrode, individual worms increased
reversing behaviors which then remained uniform as they
moved in a constant direction parallel to the exposure. A
few which did not reverse direction died (presumably from

electrocution) at 6 V or 0.4 mA. They concluded that adult
C. elegans move directionally at selected combinations of
voltage and potential differences and that electrophoresis
could be eliminated.

Gabel et al. [576] also investigated electric field effects
on directionality on C. elegans with an eye toward better
understanding how the nervous system transforms sensory
inputs into motor outputs. They used time-varying electric
fields modulated at 100 Hz across an agar surface with a
defined direction and amplitude up to 25 V/cm. They found
that the nematodes deliberately crawl toward the negative
pole in an electric field at specific angles to the direction of
the electric field in persistent forward movements with the
preferred angle proportional to field strength. They also
found that the nematodes orient in response to time-
varying electric fields by using sudden turns and reversals
(normal reorientation maneuvers). They also found that
certain mutations or laser ablation that disrupt the struc-
ture and function of amphid sensory neurons also dis-
rupted their electrosensory behavior and that specific
neurons are sensitive to the direction and strength of
electric fields via intracellular calcium dynamics among
the amphid sensory neurons. This study showed that
electrosensory behavior is crucial to how the C. elegans
nervous system navigates and can be disrupted at some
intensities found in the environment.

Maniere et al. [573] also found C.elegans was sensitive
to electric fields and that when submitted to a moderate
electric field, worms move steadily along straight trajec-
tories. They hypothesized that imposing electric fields in
research settings was an inexpensive method to measure
worms' crawling velocities and a method to get them to
self-sort quickly by taking advantage of their electrotactic
skills.

An early RFR study of C elegans by Daniells et al. [577]
found this species to be a useful model for investigating
stress-responses. In the majority of investigations, they
used 750 MHz with a nominal power of 27 dBm; controls
were shielded and all temperatures were strictly
controlled. Stress responses were measured in terms of
beta-galactosidase (reporter) induction above control
levels. Response to continuous microwave radiation
showed significant differences from 25 degrees C in con-
trols at 2 and 16 h, but not at 4 or 8 h. Using a 5 x 5 multiwell
plate array exposed for 2 h, the 25 microwaved samples
showed highly significant responses compared with a
similar control array. Experiments in which the frequency
and/or power settings were varied suggested a greater
response at 21 than at 27 dBm, both at 750 and 300 MHz
indicating a nonlinear effect, although extremely variable
responses were observed at 24 dBm and 750 MHz. Lower


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power levels tended to induce greater responses — the
opposite of simple heating effects. They concluded that
microwave radiation causes measurable stress to trans-
genic nematodes via increased levels of protein damage
within cells at nonthermal levels.

Tkalec et al. [578] found oxidative and genotoxic ef-
fects in earthworms (Eisenia fetida) exposed in vivo to RFR
at 900 MHz, at 10, 23, 41 and 120 V m(-l) for 2 h using a
Gigahertz Transversal Electromagnetic (GTEM) cell. All
exposures induced significant effects with modulation
increasing such effects. Their results also indicated anti-
oxidant stress response induction with enhanced catalase
and glutathione reductase activity, indicating lipid and
protein oxidative damage. Antioxidant responses and
damage to lipids, proteins and DNA differed depending on
EMF level, modulation, and exposure duration.

Aquatic and semi-aquatic worm species also show
sensitivity to EMF. Jakubowska et al. [579] investigated
behavioral and bioenergetic effects of EMF at 50 Hz, 1 mT
fields (comparable to exposures near underwater cables) in
polychaete ragworms (Hediste diversicolor) that live and
burrow in the sand/mud of beaches and estuaries in intertidal
areas of the North Atlantic. While they found no attraction or
avoidance behavior to EMF, burrowing activity was enhanced
with EMF exposure, indicating a stimulatory effect. Food
consumption and respiration rates were unaffected but
ammonia excretion rate was significantly reduced in
EMF-exposed animals compared to control conditions at only
geomagnetic fields. The mechanisms remained unclear. The
authors said this was the first study to demonstrate effects of
environmentally realistic EMF values on the behavior and
physiology of marine invertebrates.

Van Huizen et al. [67] investigated effects of weak
magnetic fields (WMF) on stem-cells and regeneration in
an in vivo model using free-swimming flatworms (Planaria
sspj that are capable of regenerating all tissues including
the central nervous system and brain. This regeneration
ability is due to the fact that about 25% of all their cells are
adult stem cells (ASC). Injury is followed by a systemic
proliferative ASC response that initially peaks at ~ 4 h,
followed by ASC migration to the wound site over the first
72 h when a second mitotic peak occurs. Like salamander
regeneration (see "Amphibians" above) this activity pro-
duces a blastema — a group of ASC cell growth that forms
the core of new tissues. Full regeneration of damaged
planaria tissues or organs occurs through new tissue
growth and apototic remodeling/scaling of old tissues
within 2-3 weeks. Following amputation above and below
the pharynx (feeding tube), they exposed amputation sites
to 200 (iT WMF. At three days post-amputation, they found
that 200 (iT exposure produced significantly reduced

blastema sizes compared to both untreated and earth-
normal 45 (iT field strength controls, indicating a WMF
interference effect to regeneration. They also found that the
200 (iT exposure was required early and had to be main-
tained throughout blastema formation to affect growth,
and that shorter, single-day exposures failed to affect blas-
tema size. In addition, they found weak magnetic fields
produced field strength-dependent effects. These included
significant reductions of blastema size observed from 100-
400 (iT, but conversely, a significant increase in outgrowth
occurred at 500 (iT. They hypothesized that WMF effects were
caused by altered reactive oxygen species (ROS) levels, which
peak at the wound site around 1-h post-amputation and are
required for planarian blastema formation. This study shows
that weak anthropogenic magnetic fields can affect stem cell
proliferation and subsequent differentiation in a regenerative
species, and that field strength can increase or decrease new
tissue formation in vivo. This is a significant finding for
regenerating species of all kinds, and may affect non-
regenerating species as well. Sea lamprey eels (Petromyzon
marinus), a fish species, are also known to regenerate even
after multiple amputations [580].

Mollusks, amoeba, molds, algae,
protozoans

Mollusks (marine versions are called chitons) are long known
to manufacture magnetite in their teeth and to use fields
weaker than the geomagnetic field for kinetic movement and
direction [52,117, 340, 524]. Lowenstam [118] first discovered
that magnetite was the major mineral in the teeth of marine
chitons, thought to give teeth their natural hardness. But
Ratner [62] discovered chitons use magnetite as a magnetic
compass when he found a number of chiton species have
radulae (tongues) that are covered by ferro-magnetic
(magnetite) denticles. The radulae of Acompapleura gran-
ulata and Chiton squamosis were also found to be ferro-
magnetic but the shells were not. Live specimens of a chiton
(Chaetopleura apiculata) that also have ferro-magnetic
radulae were found to rotate more and move farther in a
magnetic field weaker than in the Earth's stronger geomag-
netic field, indicating a nonlinear directionality. Ratner
concluded that chitons are responsive to magnetic fields and
demonstrate kinetic movements within them.

Some snails are sensitive to EMFs. Nittby et al. [581]
observed analygesic effects in land snails (Helix pomatia)
caused by GSM-1900 RFRs when snails lost sensitivity to
pain on a hot plate test after nonthernal exposure to RFR.

Smaller organisms have also long shown effects from
EMF. Goodman et al. [582] found delays in mitotic cell


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Levitt et al.: EMF and wildlife — 53

division in slime mold (Physarum polycephalum) with
ELF-EMF exposures. Friend et al. [583] found perpendic-
ular and parallel elongation of the giant amoeba Chaos
chaos (Chaos carolinensis) in alternating electric fields over
a wide frequency range (1 Hz-10 MHz) with characteristic
changes as a function of frequency. Marron et al. [584]
found effects on ATP and oxygen levels in another species
of slime mold (P. polycephalum) after exposures to 60 Hz
sinusoidal electric and magnetic fields. Luchien et al. [585]
found a stimulating effect on the productivity of the algal
biomass (Chlorella sorokiniana) for a magnetic field of
50 Hz but an inhibitory effect at 15 Hz in these microalgae.

Protozoans, thought to be more related to animals than
microbes, also show sensitivity to EMF. Protozoans, as
single-celled eukaryotes, are generally larger than bacteria
which are classified as prokaryotes. The two organisms are
structurally different: bacterial cells lack a nucleus while
protozoa contain organelles such as mitochondria. Bacte-
ria generally absorb nutrients through their cell walls while
protozoa feed on bacteria, tissue, and organic matter and
can be both infectious and parasitic. These protozoa
include human parasites that cause diseases such as
amoebic dysentery, malaria, giardiasis, leishmaniasis,
trichomoniaisis, toxoplasmosis and others. Animal species
are also affected by protozoans which can severely weaken
and shorten their lifespans.

Rodriguez-de la Fuente et al. [586] tested ELF-EMF
(60 Hz, 2.0 mT for 72 h) on two infectious protozoans, Tri-
chomonas vaginalis and Giardia lamblia, and found growth
alterations in both species which they attributed to alter-
ations in cell cycle progression and cellular stress. Cam-
maerts et al. [587], used RFR (GSM 900-MHz at 2 W vs.
control) on protozoans (Paramecium caudatum) and found
individuals moved more slowly and sinuously than usual
and that their physiology was affected. Paramecia became
broader, pulse vesicles had difficulty expelling content to
the outside of their cells, cilia moved less efficiently, and
trichocysts became more visible — all effects that indicate
poor functioning or cell membrane damage. They hy-
pothesized that the first impact of RFR could be to cell
membranes.

Clearly there are multiple effects at all levels docu-
mented in lower taxa from multi-frequency exposures that
are now found in the environment.

Yeast and fungi

Yeast is often used in lab models, especially since 1996
when a complete genomic sequence of Saccharomyces
cerevisiae was created. In fact it is now considered a

"premier model" [588] for eukaryotic cell biology as well as
having helped establish whole new fields of inquiry such as
"functional genomics" and "systems biology" which focus
on the interactions of individual genes and proteins to
reveal specific properties of living cells and whole
organisms.

EMF research is rich with studies using yeast models
too numerous to fully analyze here. However we include a
small sample of recent EMF research with potential sig-
nificance to environmental exposures.

Lin et al. [589] investigated glucose uptake and tran-
scriptional gene response to ELF-EMF (50 Hz) and RFR
(2.0 GHz) on several strains of budding yeast (S. cerevisiae).
Results determined that ELF-EMF and RFR exposure can
upregulate the expression of genes involved in glucose
transportation and the tricarboxylic acid (TCA) cycle, but
not glycolysis pathways, thus showing that such exposures
can affect energy metabolism which is closely related with
cellular response to environmental stress. Glucose meta-
bolism is fundamental to all living cells' need for energy,
with related significance to many disease states including
most cancers.

In a magnetic field study by Mercado-Saenz et al. [590],
premature aging and cellular instability were found in
yeast (S. cerevisiae) exposed to low frequency, low in-
tensity sinusoidal magnetic fields (SMF continuous expo-
sure at 2.45 mT, 50 Hz) and pulsed magnetic fields (PMF
1.5 mT, 25 Hz, 8 h/day). Chronological aging was evaluated
during 40 days and cellular stability was evaluated by a
spontaneous mutation count and the index of respiratory
competence (IRC). They found exposure to PMF produced
accelerated aging while SMF did not, and decreased
mitochondrial mutation during aging was also seen with
PMF. No alterations in respiratory competence were
observed for either SMF or PMF exposures. They concluded
that exposure to PMF accelerated chronological aging and
altered the spontaneous frequency of mitochondrial mu-
tation during the aging process, whereas the SMF used had
no effect, thus showing abnormal effects on cell activity
from pulsed exposures.

Because yeast cells are known to be sensitive to mag-
netic fields, some industrial and therapeutic applications
to human health have been investigated. These in-
vestigations serve to illuminate what we know about yeast
and fungal reactions to EMF in general, as well as specific
uses. For industrial applications, Wang et al. [591] inves-
tigated low level static magnetic fields (SMF) on mold
(Aspergillus versicolor) growth which can have high im-
pacts on metal corrosion in environmental conditions
conducive to mold growth. This is especially problematic
in fine electronic circuit boards produced today. Using a


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10 mT static magnetic field (SMF) perpendicular to the
surface of printed circuit boards, they found the magnetic
field inhibited mold growth and surface corrosion which
were slowed down, unlike control boards without applied
magnetic fields where mold formed a spore-centered
corrosion pit that then led to macroscopic regional uni-
form corrosion. This demonstrated changes in cell/spore
growth at a low intensity exposure that can be found in the
environment.

Also with an eye toward commercial possibilities, Sun
et al. [592] found that a polysaccharide of Irpex lacteus (a
white-rot fungus found widely in the environment which
breaks down organic materials but also is commercially
used to treat nephritis in humans) was sensitive to low-
intensity ELF-EMF as demonstrated by increased biomass
and polysaccharide content, as well as induced malformed
twists on the sample cell surfaces. Polysaccharides are
carbohydrates with a large number of sugar molecules
used as energy sources in living cells. They identified
varying changes in multiple differentially expressed genes
after exposure to alternating current EMF (50 Hz, 3.5 mT,
3 h per day, for 4 days). They found initial sharp increases
in growth rates in exposed samples that were then marked
by significant declines in EMF's influence over time,
although there were also important lasting effects. Global
gene expression alterations from EMF indicated pleiotropic
effects (capable of affecting multiple proteins or catalyzing
multiple reactions) were related to transcription, cell pro-
liferation, cell wall and membrane components, amino
acid biosynthesis and metabolism. Polysaccharide
biosynthesis and metabolism were also significantly
enriched in the EMF-exposed samples. They concluded
that EMF significantly increased amino acid contents and
was therefore deemed a suitable method for increasing
fermentation of microorganisms, presumably for com-
mercial use. However, the significance of this study to
environmental exposures relates to the multiple ways that
ELF alternating current common to electric power gener-
ation changed yeast gene expression. There is at least one
clinical case of a different strain of I. lacteus taking on a rare
infectious and dangerous quality in an immuno-
compromised human [593]. The question is: can now-
ubiquitous ELF-EMF contribute to potentially emerging
new forms of yeast contagion?

The same question arises with Candida albicans and
other pathogenic yeasts that have rapidly developed
resistance to antifungal medications. C. albicans can live
harmlessly in human microflora, but certain lifestyle cir-
cumstances or immunosuppression can turn it into an
opportunistic pathogen. It can also infect some non-human
animals. While chronic mucocutaneous candidiasis can

infect the skin, nails, and oral and genital mucosae, under
high host immunodeficiency C. albicans can enter the
bloodstream and induce systemic infections with mortality
between 30 and 80% [594]. There has been increasing
resistance of C. albicans to traditional antifungal agents,
such as fluconazole and amphotericin B [595, 596]. Resis-
tance mechanisms include overproduction of membrane
drug efflux transporters and/or changes in gene expression
[597].

Two investigations in search of new therapeutic stra-
tegies were conducted using EMF. Sztafrowski et al. [594]
investigated the use of static magnetic fields (SMF, 0.5 T) on
C. albicans cultures in the presence of two commonly used
antifungal medications. Their aim was to assess whether
SMF had any impact on general viability of C. albicans
hyphal transition and its susceptibility to fluconazole and
amphotericin B. They found reduction of C. albicans hy-
phal length in EMF-exposed samples. They also found a
statistically significant effect on C albicans viability when
SMF was combined with amphotericin B. They hypothe-
sized that this synergistic effect may be due to the plasma
membrane binding effects of amphotericin B and that SMF
could influence domain orientation in the plasma mem-
brane. They concluded, with caution, that the use of a SMF
in antifungal therapy could be a new supporting option for
treating Candidas infections.

Novickij et al. [598] also focused on therapeutic pos-
sibilities given the multi-drug resistance and side effects to
antifungal therapies. Their aim was to optimize the
electroporation-mediated induction of apoptosis using
pulses of varied duration (separately and in combination
with formic acid treatment) and to identify yeast apoptotic
phenotypes. They focused on nonthermal nanosecond
pulsed electric fields (PEF 3 kV, 100 ns -1 ms squarewave;
and 250, 500, 750 ns duration 30 kV/cm PEF, 50 pulses,
1 kHz) as a therapeutic alternative and/or to enhance ef-
fects in combination with conventional treatments. In three
yeast models, S. cerevisiae (as control) and drug resistant
Candida lusitaniae and Candida guilliermondii, they found
that nanosecond PEF induced apoptosis in all three strains.
Combining PEF with a weak formic acid solution improved
induced apotosis and inactivation efficacy in the majority
of the yeast population. Yeast cells showed DNA breaks
and other changes. They concluded that PEF could be a
useful new non-toxic protocol to treat some fungal diseases
and minimize tissue damage.

Choe et al. [599] studied ion transportation and stress
response on a yeast strain (K667) to ELF-EMF (60 Hz,
0.1 mT, sinusoidal or square waves), specifically investi-
gating internal ionic homeostasis via the cell membrane
involving metal ions and cation transports (cations are


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Levitt et al.: EMF and wildlife — 55

ionic species of both atoms and molecules with a positive
charge). They found significantly enhanced intracellular
cation concentrations as ELF-EMF exposure time
increased, as well as other changes. This study has impli-
cations for soil health as yeast can be an integral aspect of
how healthy organic soil matter is formed. They concluded
that EMF and yeast could also play a role in the bioreme-
diation processes in metal-polluted environments.

Lian et al. [600] studied effects of ELF-EMF (50 Hz, 0-
7.0 mT) and RFR (2.0 GHz, 20 V/m, temperature at 30 ฐC,
average SAR single cell/0.12 W/kg) on two budding yeast
strains (NT64C and SB34) and prion generation/propaga-
tion. They found under both EMF exposures that de novo
generation and propagation of yeast prions (URE3) were
elevated in both yeast strains. The prion elevation
increased over time and effects were dose-dependent. The
transcription and expression levels of heat shock proteins
and chaperones were not statistically significantly elevated
after exposure but levels of reactive oxygen species (ROS),
as well as superoxide dismutase (SOD) and catalase (CAT)
activities were significantly elevated after short-term, but
not long-term exposure. This work demonstrated for the
first time that EMF exposure could elevate the de novo
generation and propagation of yeast prions, supporting the
researcher's hypothesis that ROS may play a role in the
effects of EMF on protein misfolding. ROS levels also
mediate other broad effects of EMF on cell function. They
concluded that effects of EMF exposure on ROS levels and
protein folding may initiate a cascade of effects negatively
impacting many biological processes.

The effects of EMF on protein folding cannot be over-
stated. Proteins must fold into proper three-dimensional
conformations to carry out their specific functions — intact
proteins are critical to the existence of all life. Misfolding
not only impairs function but leads to disease. Folding
inside of cells does not happen spontaneously but rather
depends on molecular helpers called chaperones. Protein
misfolding has been implicated in Alzheimer's, Parkin-
son's, and Huntington's diseases, among others. The
devastating Creutzfeldt-Jakob disease is caused by prion
misfolding in the brain, which causes abnormal signaling
in neurons that eventually leads to paralysis and death.
Wildlife can also suffer from prion diseases such as chronic
wasting in deer, elk, and other cervids, and cattle can suffer
from so-called "mad-cow" disease. The two studies from
above [599, 600] have implications for how such diseases
are spread through soil with possible links to environ-
mental EMFs.

It is clear from the above that ELF-EMF and RF-EMF,
using multiple signaling characteristics, are biologically
active in both temporary and permanent ways in yeast/

fungi species with wide environmental implications across
numerous taxa.

Bacteria

Strains of bacteria are known to be magnetotactic and use
geomagnetic fields for direction. Blakemore [63] was the
first to suggest in 1973 that bacteria in North American
saltwater marsh muds use magnetite as a sensor when he
discovered not only that bacteria were highly attracted to
an external magnet but they also had magnetite crystals
that caused them to align with the lines of the Earth's
magnetic fields. This was also discovered to be geo-
location specific to the North Pole in northern samples and
South Pole-seeking in southern species [52, 63, 511]. The
bacteria showed "mud-up" and "mud-down" behavior
along magnetic field gradients when mud was disturbed,
indicating a magnetic compass. Since that early work, a
whole new field called electromicrobiology has developed
with discoveries that include some electro-active bacteria
being responsible for magnetite formation, with others
creating their own electric "wires" in mud flats with im-
plications for new technologies [601].

Among the more troubling EMF effects are bacterial al-
terations with pressing implications for antibiotic resistance.
Since the 1940s [602], nonthermal effects were documented
in bacterial, viral, and tissue cultures with applied low-
repetition 20-MHz pulses. Most studies spanning the 1940s
though the 1980s focused on EMF's ability to kill microbes
and fungi in human food sources at high intensity, conse-
quently most research was focused on thermal intensities.
That work still continues today as microwaves have been
shown to be an efficient means for killing microbes [50]. But
microbes also react to much lower nonlethal intensities and
recent work finds effects from both ELF and RFR.

The common bacteria Escherichia coli, which can live
harmlessly in the gut of humans and many other animal
species, can also turn virulent and kill through food-borne
illnesses. E. coli comes in many strains, is well studied, and
now considered the most genetically and physiologically
characterized bacterium. E. coli encounter varied and
numerous environmental stressors during growth, sur-
vival, and infection, including heat, cold, changes in Ph
levels, availability of food/water supplies, and EMF. Along
with other bacteria, they respond by activating groups of
genes and heat shock proteins (see "Mechanisms" above)
which can eventually lead to stress tolerance for survival
purposes. But induced stress tolerance can also lead to
increased virulence, as well as enhanced tolerance to other
stressors that confer cross-protection [603].


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Salmen and colleagues [604, 605] published papers of
EMF effects on bacterial strains documenting the growing
investigation of microbes related to antibiotic resistance
with many findings stressing responses to EMF [606-610].
Cellini et al. [611] investigated E. coli's adaptability to
environmental stress induced by ELF exposures to 50-Hz
magnetic fields at low intensities (0.1,0.5,1.0 mT) vs. sham
controls. They found exposed samples and controls dis-
played similar total and culturable counts, but increased
cell viability was observed in exposed samples re-
incubated for 24 h outside of the test solenoid compared
to controls. Exposure to 50 Hz EMF (20-120 min) also
produced a significant change in E. coli morphotype with a
presence of coccoid cells aggregated in clusters after re-
incubation of 24 h outside of the magnetic field-solenoid.
Atypically lengthened bacterial forms were also noted,
indicating probable alteration during cell division. Some
differences in RNA-AFLP analysis were also seen for all
intensities evaluated. They concluded that exposure to
50-Hz ELF-EMF is a bacterial stressor as evidenced by its
immediate response in modifying morphology (from
bacillary to coccoid) and inducing phenotypical and tran-
scriptional changes. Despite this stressor effect, it was also
seen that exposed samples significantly increased
viability, suggesting the presence of VBNC cells. They
concluded that further studies were needed to better un-
derstand ELF-EMF in bacterial cell organization. They did
not extrapolate to the obvious — that E. coli was changed in
an abnormal way but nevertheless strengthened in
viability — a recipe for antibiotic resistance.

Crabtree et al. [612], in a small human study, investi-
gated the biomic relationship of human bacteria exposed to
both static magnetic fields (SMF) and RFR. Using laboratory
culture strains and isolates of skin bacteria collected from
the hand, cheek, and chin areas of four volunteers who had
different (self-reported) cell phone use histories, they found
varied growth patterns of E. coli, Pseudomonas aeruginosa,
and Staphylococcus epidermidis under static magnetic fields
on different bacterial species. Isolates of skin microbiota
showed inconsistent growth among the test subjects, likely
due to their differing cell phone usage histories (classified as
heavy, medium and light) and other variables. The growth of
Staphylococci was increased under RFR in certain in-
dividuals while in others growth was suppressed. This was
complicated by the different body areas tested, some with
higher chronic exposures such as the hands, as well as other
variables when one test subject used an antibacterial face
wash. Volunteers in the heavy use category showed less
bacterial growth on the hands, possibly due to microbe
habituation. Overall, and despite the small sample, they
concluded RFR can disrupt the balance in skin microbiota,

making it more vulnerable to infection by specific opportu-
nistic and/or other foreign pathogens. They noted that both
SMF and RF-EMFs have significant but variable effects on
the growth of common human bacteria; that bacterial
growth was either unaffected, increased, or suppressed
depending on the species of bacteria; and that bacterial re-
sponses seemed to be determined by historic exposure to
RF-EMF and life style. This study, even with inherent limi-
tations, indicates changes in microbes with EMFs and may
prove a novel way to study bacteria with significance for
real-life exposures to humans and animals alike.

Salmen et al. [605] also found highly variable results
from RFR (900 and 1,800 MHz) effects on DNA, growth rate,
and antibiotic susceptibility in Staphylococcus aureus,
Staphylococcus epidermidis, and P. aeruginosa. Using an
active cell phone handset, they exposed bacteria to 900
and 1,800 MHz for 2 h, then injected samples into a new
medium where growth rate and antibiotic susceptibility
were evaluated. Regarding DNA, they found no differences
in S. aureus and S. epidermidis when exposed to 900 and
1,800 MHz vs. controls, but P. aeruginosa showed changes
in DNA band patterns following such exposures. Regarding
growth rates, with the exception of a significant decrease
after 12 h exposure to 900 MHz, no significant effects on
growth of S. aureus and S. epidermidis were seen. But the
growth of P. aeruginosa was significantly reduced
following exposure for 10 and 12 h to 900 MHz, while no
significant reduction in growth followed exposure to
1,800 MHz. Regarding antibiotic susceptibility, in the
drugs studied (i.e., amoxicillin 30 mg, azithromycin 15 mg,
chloramphenicol 10 mg, and ciprofloxacin 5 mg), with the
exception of S. aureus treated with amoxicillin (30 mg),
EMF-exposure had no significant effect on bacterial
sensitivity to antibiotics. This study shows variability
among bacterial species not only to different frequencies
common in the environment today but also to changes in
sensitivity to some antibiotics but not others. There may
have been design problems with this study, however.

Several studies investigated WiFi signals on bacterial
strains. Taheri et al. [610] assessed exposure to 900-MHz
GSM mobile phone radiation and 2.4-GHz RFR from com-
mon WiFi routers to see if cultures of Listeria mono-
cytogenes and E. coli resulted in altered susceptibility to 10
different antibiotics. They found narrow windows in which
microbes became more resistant: For L. monocytogenes no
significant changes in antibacterial activity between
exposed and nonexposed samples — except for Tetracy-
cline (Doxycycline) — were noted. For E. coli, however,
there was a significant change in antimicrobial activities
suggesting RFR exposures can influence antibiotic sus-
ceptibility of E. coli more than in Listeria. For window and


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Levitt et al.: EMF and wildlife — 57

pronounced effects, they found L. monocytogenes exhibi-
ted different responses to each antibiotic. For Doxycycline,
the window occurred after 6 h exposure to WiFi and mobile
phone-RFR. After 9 h of exposure to WiFi for Ciprofloxacin
and Sulfonamide (Tremethoprin/sulfamethoxazole), bac-
teria tended to become more resistant. By contrast, the
pattern for Levofloxacin and Penicillin (Cefotaxime/Def-
triaxone) showed increased sensitivity. For E.coli, the
pattern of the response to WiFi and mobile phone RFR was
the same: maximum antibiotic resistance was seen be-
tween 6 and 9 h of exposure but after 12 h, a stress response
lead to a return to preexposure conditions indicating an
adaptive reaction. Taheri et al. [609] found similar
nonlinear window effects and differences in growth rates in
Klebsiella pneumonia, while Mortazavi et al. [613] found
similar window effects in E coli. In addition, they saw sig-
nificant increased growth rates after radiation exposures in
both Gram-negative E. coli and Gram-positive
L. monocytogenes. They concluded that such window ef-
fects can be determined by intensity and dose rate; that
exposure to RFR within a narrow window can make mi-
croorganisms resistant to antibiotics; and that this adap-
tive phenomenon is a human health threat. The same can
be inferred for many non-human species.

Said-Salman et al. [614] evaluated non-thermal effects
of WiFi at 2.4 GHz for 24 and 48 h (using a WiFi router as the
source) on the pathogenic bacterial strains E. coli 0157H7,
S. aureus, and S. epidermis for antibiotic resistance,
motility, metabolic activity and biofilm formation. Results
found that WiFi exposure altered motility and antibiotic
susceptibility of E. coli but there was no effect on S. aureus
and S. epidermis. However, exposed cells (vs. unexposed
controls) showed an increased metabolic activity and bio-
film formation ability in E. coli, S. aureus and S. epidermis.
They concluded that WiFi exposure acted as a bacterial
stressor by increasing antibiotic resistance and motility of
E. coli, as well as enhancing biofilm formation in all strains
studied. They indicated the findings may have implications
for the management of serious bacterial infections.

Movahedi et al. [615] also investigated antibiotic
resistance, using short-term exposure to RFR from a mobile
phone simulator (900 MHz, 24 h) on P. aeruginosa and
S. aureus against 11 antibiotics. They found significant
changes in structural properties and resistance to the
numerous antibiotics studied. P. aeruginosa was resistant
to all antibiotics after 24 h of exposure vs. non-exposed
controls while S. aureus bacteria were resistant to about
50%. They also found structural changes in all exposed
samples and increased cell wall permeability.

In a field study near cell towers, Sharma et al. [616]
looked at changes in microbial diversity and antibiotic

resistance patterns in soil samples taken near four different
base stations with control samples taken >300 m away.
Stenotrophomonas maltophilia, Chryseobacterium gleum,
and Kocuria rosea were isolated and identified in soil
samples collected near the exposed zones. They found
greater antibiotic resistance in microbes from soil near
base stations compared to controls, with a statistically
significant difference in the pattern of antibiotic resistance
found with nalidixic acid and cefixime when used as
antimicrobial agents. They concluded that cell tower ra-
diation can significantly alter the vital systems in microbes
and make them multi-drug resistant.

Researchers have also investigated ELF-EMF effects on
bacterial growth and antibiotic sensitivity. Segatore et al.
[608] investigated 2 mT, 50 Hz exposures on E. coli ATCC
25922 and P. aeruginosa ATCC 27853 and found EMF
significantly influenced the growth rate of both strains,
notably at 4, 6, and 8 h of incubation. The number of cells
was significantly decreased in exposed bacteria vs. con-
trols. And at 24 h incubation, the percentage of cells
increased (P. aeruginosa ~ 42%; E. coli ~ 5%) in treated
groups vs. controls which suggested to the researchers a
progressive adaptive response. However, they saw no
remarkable change in antibiotic sensitivity. Potenza at al.
[617] also found effects at high-intensity static magnetic
fields at 300 mT on growth and gene expression in E.coli
but that would be a high environmental exposure.

Viruses

There is a paucity of research on viral species and EMF,
likely due to the fact that viruses lack ferromagnetic ma-
terials, are difficult to study, and don't make good general
lab models other than to investigate their direct impact on
specific in vivo end points. Virology research thrives in its
own specialized niche and has not been used for basic
modeling like so many other living life forms as noted
throughout this paper. There is long-standing debate on
whether viruses are even alive.

However, one wide-ranging discussion by Zaporozhan
and Ponomarenko [618] hypothesized a possible complex
mechanistic link between influenza pandemics, natural
sun spot cycles, and non-thermal effects of weak magnetic
fields via cryptochromes/radical pairs, gene expression
pathways, and stress-induced host immunological alter-
ations favorable to influenza epidemics. Noting that
most — though not all — major influenza epidemics
occurred in time intervals starting 2-3 years before and
ending 2-3 years after maximum solar activity, they hy-
pothesized that solar cycles are able to both regulate and


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entrain processes of biological microevolution in viral
species (among others), as well as influence human bio-
rhythms in synergistic ways that could lead to influenza
epidemics. Although others have also noted links between
influenza pandemics and sunspot activity — possibly
based on changes in migratory bird patterns as viral vec-
tors [619-621]— and some have linked sun spots with other
adverse human health events, these effects remain of in-
terest but are still hypothetical. UV radiation, which is not
covered in this paper, is known to suppress cell-mediated
immunity and is therefore capable of adversely affecting
the course of a viral infection in some mammal species.
Ambient EMF in lower frequency ranges may also be
reducing immune viability across species which can
theoretically foster opportunistic virulence. Far more EMF
research needs to be conducted on viruses; one fruitful
approach might be synergistic investigations in virus-
infected plant species.

The previous studies of microbes show a pattern of
sensitivity in microorganisms to EMF with associations that
encompass a wide range of critical changes, including
consistent stress responses, alterations in growth and
viability, cell membrane alterations, and clear patterns of
how easily antibiotic resistance forms in microbial life to
now ubiquitous EMF levels.

Plants (see Part 2, Supplement 4,
for a table of flora studies: ELF, RFR)

Plants have evolved in highly sensitive ways to natural and
manmade EMF in all phases of germination, growth and
maturation [31]. Magnetoreception, which is well docu-
mented in animals such as birds, has also been described
in plants [622] and plant species can respond to subtle
changes in EMF in the environment, including in whole
plant communities [623]. They may even 'communicate'
and gather various kinds of 'information' via electrical
signals in neuron-like cells in root tips and elsewhere [624].
Some hypothesize [625] that a form of vibrational and
acoustic sensitivity around 220 Hz may play a role in plant
life, although not everyone agrees [626].

Almost all vegetation is subject to complex multi-
frequency fields due to their soil-based root systems and
high water content, plus above-ground ambient RFR ex-
posures makes plants uniquely susceptible to effects near
transmission towers [623, 627]. Many EMF studies have
found both growth stimulation as well as dieback. The
presence of numerous RFR-emitters in the German and
Swiss Alps is thought to have played a role in the

deforestation there [628]. The 'browning' of treetops is
often observed near cell towers, especially when water is
near tree root bases [25]. Treetops, with their high moisture
content and often thick vegetative canopy, are known RFR
waveguides. In fact, military applications utilize this
capability in treetops for communication signal propaga-
tion in remote areas and for guidance of low-flying
weapons systems [629].

How flora interacts with EMF is still a mystery but a
clear pattern has emerged in researching the database for
this paper: static ELF-EMF has largely been found benefi-
cial to plant and seed growth [630] while RFR is detri-
mental. Plants clearly have magnetoreception in their
stationary condition. The normal ground state of magnetic
fields for plants is the relatively constant natural
geomagnetic field that averages between 25 and 65 [iT
depending on location and seasonal variations [631]. At-
mospheric changes, such as thunderstorms and lightning,
can cause intermittent changes in ambient magnetic fields.
These activities are also generally associated with rain-
water critical to virtually all plant life. Plants can detect
these changes and prepare for growth using the upcoming
rainfall. Trees are seen extending their branches skyward
long before rain actually occurs and such changes match
alterations in tree polarities [632].

There are many studies showing an increase in the
growth rate in plants, such as studies of seed germination
exposed to alternating magnetic fields. Plants also respond
similarly to high intensity static magnetic fields. This may
mean that the physiological mechanism in plants that
causes magnetic field-induced growth is finely tuned to a
certain intensity of magnetic flux. Any variation in in-
tensity or shape of the ambient magnetic field could acti-
vate or hinder this growth mechanism.

Lightning, for instance, generates fast and intense
electromagnetic pulses (EMP). EMP has consistently been
shown to cause biological effects [633] with just one pulse.
Plants may have mechanisms so sensitive that they can
detect the energy of EMP from kilometers away. The pulse
causes a transient change in the environmental magnetic
field that may be detected by one or more of the mecha-
nisms mentioned in the "Mechanisms" section above, as
well as discussed below. EMP has been closely investigated
for military applications for its ability at high intensities to
disable electronics. While much of the military-supported
research finds no biological effects from EMP exposure,
non-military supported research does show effects. This
parallels the same findings in industry vs. non-industry
research patterns [165, 634].

There is a long history on the study of effects of EMF
exposure on plant growth, notably, the work of the Indian


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Levitt et al.: EMF and wildlife — 59

scientist Sir Jagadish Bose (1858-1937) who proposed the
electric nature of plant responses to environmental stimuli
and studied effects of microwaves on plant tissues and
membrane potentials [635]. Interestingly, Bose investi-
gated the effects of millimeter waves [636] now applicable
to 5G technology. Bose, arguably, was a pioneer of wireless
communication.

Another early pioneer in EMF effects on plants was
Harold Saxon Burr (1889-1973) at Yale University who
investigated the electric potential of trees in two tree spe-
cies (a maple and an elm) located on one property and
another maple tree for comparison growing 40 miles
(64 km) away. Measurements of numerous parameters
were taken using embedded electrodes that recorded
hourly from 1953 to 1961 [637]. Simultaneous records of
temperature, humidity, barometric pressure, sunlight,
moon cycles, sunspot activity, weather conditions,
atmospheric-potential gradients, earth-potential gradi-
ents, and cosmic rays were correlated with tree potentials.
Burr also installed equipment that measured the potential
between electrodes in the Earth (about 10 miles apart) and
the potential gradient of the air, and found that the air and
Earth potentials fluctuated exactly with the phase of the
tree potentials although the trees were not always syn-
chronous. Burr ultimately found that the electrical envi-
ronment correlated closely with tree potentials in a kind of
entrainment to diurnal, lunar and annual cycles. Meteo-
rological parameters did not correlate in any immediate
way other than when passing thunderstorms elicited
anomalous behavior in the trees in direct parallel to mea-
surements with the Earth electrodes. This follows the the-
ory noted above that plants can sense EMP and take
immediate information from it.

There are no other long-term field studies as detailed
as Burr's of magnetic field effects on a plant species.
However, another field study of RFR in Latvia [638]
measured effects directly on trees near the Skrunda Radio
Location Station, an early warning radar system that
operated from 1971 to 1998. The system operated in the 156—
162 MHz frequency range transmitting from four pulsed
two-way antennas that had operated continuously for over
20 years by the time of the study. In permanent plots in pine
forest stands, at varying distances from the radar station
and in control areas, tree growth changes were measured
and analyzed using retrospective tree ring data. They
found a statistically significant negative correlation be-
tween the relative additional increment in tree growth and
the intensity of the electric field with the radial growth of
pine trees diminished in all plots exposed to RFR. The
decreased growth began after 1970, which coincided with
the initial operation of the station and was subsequently

observed throughout the period of study. The effects of
many other environmental and anthropogenic factors were
also evaluated but no significant effects on tree growth
were correlated. This may have been the first detailed field
study of plants and RFR.

Many studies of EMF and plants are today conducted in
laboratories and have often focused on growth promotion
to create higher yields of food-producing plants. Effects of
static EMF, pulsed EMF, ELF-EMF, and RF-EMF have been
reported. There are, in fact, over 200 studies on plants and
EMF alone — too numerous to review here. See Part 2,
Supplement 4, for a Table of studies on plant seedlings and
development based on the types of EMF's tested.

As noted in Supplement 4 and in Halgamuge [627],
frequently static and ELF-magnetic fields generally
improve plant growth whereas RFR retards it. This is the
opposite of results from animal and animal-cell culture
experiments in which ELF-MF usually produces the same
effects as RFR. It is interesting to note that Hajnorouzi et al.
[639] and Radhakrishma et al. [640] proposed that MF de-
creases environmental stress in plants whereas Vian et al.
[641, 642] considered RFR as a systemic stressor. A major
morphological difference between animal and plant cells is
that plant cells have a cell wall that is an active physio-
logical organelle which regulates growth and cell division
and controls cellular communications. The cell wall con-
tains a considerable amount of water [643]. Is it possible
that absorption of RFR by cell-wall water causes a micro-
thermal effect that adversely affects plant cell functions
and even causes cell death, whereas thermal effects are not
likely to occur with ELF-EMF exposure.

Some plant roots have been found sensitive to both
ELF and RFR. Belyavskaya [644] found a strong cyto-
chemical reaction in pea root cells after exposure to low
level magnetic fields. Kumar et al. [645] found cyto- and
genotoxicity in root meristems of Allium cepa with
900-MHz and 1,800-MHz RFR. Chandel et al. [646] studied
cytotoxic and genotoxic activity on DNA integrity in root
meristems of A. cepa using 2,100-MHz RFR and found
exposure caused DNA damage with a significant decrease
in HDNA accompanied by an increase in TDNA while TM
and OTM did not change significantly compared to con-
trols. Biological effects were dependent on the duration of
exposure with maximum changes seen at 4 h.

In a series of studies, Stefi et al. [647-649] investigated
the effects of long term RFR exposure from the base units of
common cordless DECT phone systems (pulsed trans-
mission mode 1,882 MHz, 24 h/day, 7 d/week) on various
plant species (Arabidopsis thaliana, Pinus hatepensis,
Gossypium hirsutum respectively) and found structural and
biochemical alterations. Compared to controls in Faraday


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cages, exposed plant biomass was greatly reduced and leaf
structure was only half as thick. Leaves were thinner and
possessed greatly reduced chloroplasts which contributed
to overall reduced vitality. Root systems were also
adversely affected. They concluded that RFR is a stressor
and noxious to plant life. A study of similar design [650] did
not find the same effects on maize (Zea mays) which they
attributed to that plant's structural differences although
chloroplasts were severely affected (see also Kumar et al.
[651]).

Jayasanka and Asaeda [652] published a lengthy re-
view that focused on microwave effects in plants. Studies
indicate effects depend on the plant family and growth
stage involved; and exposure duration, frequency, and
power density, among other factors. They concluded that
even for short exposure periods (<15 min to a few hours),
nonthermal effects were seen that can persist for long pe-
riods even if initial exposures were very short. In addition,
they noted that since base stations operate 24 h/day,
neither short exposures nor recovery periods are possible
in natural habitats as plants are continuously exposed
throughout their life cycles. They said that variations in the
power density and frequency of microwaves exert complex
influences on plants, and that clearly diverse plant species
respond differently to such factors. They concluded it is
necessary to rethink the exposure guidelines that currently
do not take nonthermal effects into consideration.

There are numerous reports of adverse RFR effects on
mature flora. Waldman-Salsam et al. [653] reported leaf
damage in trees near mobile phone towers/masts. In a
detailed long-term field monitoring study from 2006 to 2015
in two German cities, they found unusual and unexplain-
able tree damage on the sides of trees facing the towers and
correlated it to RFR measurements vs. control areas
without exposures. They found that tree-side differences in
measured values of power flux density corresponded to
tree-side differences in damage. Controls, which consisted
of 30 selected trees in low radiation areas without visual
contact to any phone mast and power flux density under
50 (iW/m2, showed no damage. They concluded that
nonthermal RFR from mobile phone towers is harmful to
trees and that damage that affects one side eventually
spreads to the whole tree.

Vian et al. [642] published a review of plant in-
teractions with high frequency RFR between 300 MHz and
3 GHz and noted that reports at the cellular, molecular, and
whole plant scale included: numerous modified metabolic
activities (reactive oxygen species metabolism, a- and
^-amylase, Krebs cycle, pentose phosphate pathway,
chlorophyll content, and terpene emission among others);
altered gene expression (calmodulin, calcium-dependent

protein kinase, and proteinase inhibitor); and reduced
growth (stem elongation and dry weight) after nonthermal
RFR exposure. They said changes occur in directly exposed
tissues as well as systemically in distant tissues and pro-
posed that high-frequency RFR be considered a genuine
environmental factor highly capable of evoking changes in
plant metabolism.

Halgamuge [627] also published a review that found
weak non-thermal RFR affects living plants. The author
analyzed data from 45 peer-reviewed studies of 29 different
plant species from 1996 to 2016 that described 169 experi-
mental observations of physiological and morphological
changes. The review concluded that the data substantiated
that RFR showed physiological and/or morphological ef-
fects (89.9%, p<0.001). The results also demonstrated that
maize, roselle, pea, fenugreek, duckweeds, tomato, onions
and mungbean plants are highly sensitive to RFR and that
plants appear more responsive to certain frequencies be-
tween 800 and 1,500 MHz (p<0.0001); 1,500 and 2,400 MHz
(p 0.0001); and 3,500 and 8,000 MHz (p=0.0161). Hal-
gamuge [627] concluded that the literature shows signifi-
cant trends of RFR influence on plants.

There is particular concern for impacts to flora and 5G
since millions of small antennas mounted on utility poles,
transmitting in MMW and other broadband frequencies,
already are — or will soon be — in very close proximity to
vegetation, creating both near- and -far field exposures. As
noted in Halgamuge [627], the following are some studies
investigating GHz frequencies already in use or planned for
5G that found significant effects on plants: Tanner and
Romero-Sierra [654] on accelerated growth of Mimosa plant
(10 GHz, 190 mW/cm2, 5-10 min); Scialabba and Tambur-
ello [655] on reduced hypocotyls growth rate in radish
(Raphanus sativus) (10.5 GHz, 8 mW or 12.658 GHz, 14 mW
for 96 h); Tafforeau et al. [656] induced meristem (actively
dividing group of cells) production in Linum usitatissimum
(105 GHz for 2 h at 0.1 mW/cm2); and Ragha et al. [657]
(9.6 GHz, 30 min) found germination depended on expo-
sure parameters on Vigna radiata, Vigna aconitifolia, Cicer
arietinum and Triticum aestivum plants. This is an area in
immediate need of further investigation given the results
from the previous studies.

A thorough review of RFR effects to trees and other
plants was published by Czerwinski et al. [622] who re-
ported that ecological effects on whole plant communities
could occur at a very low exposure level of 0.01-10 (iW/
cm2 — certainly comparable to limits examined in this
paper. They focused on frequencies between 0.7 and
1.8 GHz and included multiple complex indicators for plant
types, biometrics, and environmental factors. It was the
first comprehensive paper that extended beyond using


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Levitt et al.: EMF and wildlife — 61

narrower research methods. They noted that although the
literature on the effects of RFR on plants is extensive, not a
single field study had assessed the biological response at
the level of a whole plant community, biome, or ecosystem,
but rather focused mostly on short-term laboratory studies
conducted on single species. They said, "...This disso-
nance is particularly striking in view of the fact that alter-
ations in a plant community's structure and composition
have long been considered to be well founded, sensitive
and universal environmental indicators." The paper serves
as a predictive model for complex future field studies on
larger ecosystems.

Interesting EMF synergistic effects were found with
static magnetic fields and bacteria in plants. Seeking non-
chemical methods to improve seed germination after pro-
longed periods of storage when seed viability can deteri-
orate, Jovicic-Petrovic et al. [658] studied the combined
effects of bacterial inoculation (Bacillus amyloliquefaciens
D5 ARV) and static magnetic fields (SMF, 90 mT, 5 and
15 min) on white mustard (Sinapis alba L.) seeds. Their
results found that biopriming with the plant growth-
promoting B. amyloliquefaciens increased seed growth by
40.43%. Seed response to SMF alone was dependent on
treatment duration. While SMF at 5 min increased the
germination percentage, exposure at 15 min lowered seed
germination compared with the control. However, the
negative effect at the longer exposure was neutralized
when combined with the bacterial inoculation. Both
germination percentages were significantly higher when
SMF was combined with the bacteria (SMF, 5 min, + D5
ARV; and SMF, 15 min + D5 ARV; 44.68 and 53.20%,
respectively) compared with control. They concluded that
biopriming and SMF treatment gave better results than
bacterial inoculation alone. The highest germination per-
centage — 53.20% of germinated seeds — was seen with the
bacterium and 15 min exposure to 90 mT, demonstrating a
synergistic effect. They concluded that such techniques
can be used for old seed revitalization and improved
germination.

Even aquatic plants have been found sensitive to
artificial electric fields. Klink et al. [659] assessed electric
field exposures on growth rates and the content of trace
metals of Elodea canadensis. Plants were exposed in a
laboratory to an electric field of 54 kV/m for seven days.
Plant length and Fe, Mn, Ni, Pb, and Zn were measured.
Results showed the applied electric fields slightly
enhanced root growth. They also found changes in mineral
absorption; Mn and Ni were significantly lower while Pb
and Zn were significantly higher in exposed plants. Fe
content did not differ between control and exposed plants.
They concluded that electric fields had potential use for

phytoremediation in trace metal contaminated waters. This
study also has implications for long term aquatic plant
health in general.

Also working with electric fields, Krai et al. [660] found
fascinating regeneration in plant root tips in Arabidopsis at
varying electric field exposures and time durations with the
weaker exposures producing the most growth. They found
that imposed electric fields can perturb apical root regen-
eration and that varying the position of the cut and the time
interval between excision and stimulation made a differ-
ence. They also found that a brief pulse of an electric field
parallel to the root could increase by up to two-fold the
probability of its regeneration, perturb the local distribu-
tion of the hormone auxin, and alter cell division regula-
tion with the orientation of the root towards the anode or
the cathode playing a role.

While mechanisms are still unclear regarding how
EMFs affect plants, oxidative effects appear to play a sig-
nificant role. Oxidative changes have been reported in
many studies in plants after exposure to EMF [578, 639,
661-671]. EMF-related stress has been proposed by Vian
et al. [641, 642], Roux et al. [672, 673], and Radhakrishma
et al. [640]. Other mechanisms affecting plants such as
ferromagnetism, radical-pairs, calcium ions and crypto-
chromes have also been proposed [674, 675].

It is apparent that plant growth and physiology — with
their root systems anchored in the ground while their
'heads' manifest in the air — are affected by exposure to
EMF in complex synergistic ways and that they are sus-
ceptible to multi-frequency exposures throughout their life
spans.

Conclusion

Effects from both natural and man-made EMF over a wide
range of frequencies, intensities, wave forms, and
signaling characteristics have been observed in all species
of animals and plants investigated. The database is now
voluminous with in vitro, in vivo, and field studies from
which to extrapolate. The majority of studies have found
biological effects at both high and low-intensity man-made
exposures, many with implications for wildlife health and
viability. It is clear that ambient environmental levels are
biologically active in all non-human species which can
have unique physiological mechanisms that require natu-
ral geomagnetic information for their life's most important
activities. Sensitive magnetoreception allows living or-
ganisms, including plants, to detect small variations in
environmental EMF and react immediately as well as over
the long term, but it can also make some organisms


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62 — Levitt et al.: EMF and wildlife

DE GRUYTER

exquisitely vulnerable to man-made fields. Anthropogenic
EMF may be contributing more than we currently realize to
species' diminishment and extinction. Exposures continue
to escalate without understanding EMF as a potential
causative and/or co-factorial agent. It is time to recognize
ambient EMF as a potential novel stressor to other species,
design technology to reduce exposures to as low as
reasonably achievable, keep systems wired as much as
possible to reduce ambient RFR, and create laws accord-
ingly — a subject explored more thoroughly in Part 3.

Research funding: None declared.

Author contributions: All authors have accepted
responsibility for the entire content of this manuscript
and approved its submission.

Competing interests: Authors state no conflict of interest.
Informed consent: Not applicable.

Ethical approval: Not applicable.

Part 2: supplements

Supplement 1: Genetic Effects of RFR Exposure
Supplement 2: Genetic Effects at Low Intensity Static/
ELF EMF Exposure

Supplement 3: Biological Effects in Animals and Plants

Exposed to Low Intensity RFR

Supplement 4: Effects of EMF on plant growth

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Supplementary Material: The online version of this article offers sup-
plementary material (https://doi.org/10.1515/reveh-2021-0050).


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Part 2. Supplement 1.

Genetic Effects at Low Level RFR Exposure

RFR studies

Power density/SAR
(<0.1 W/Kg)

Effects observed

Aitken et al. (2005)

Mice to 900-MHz
RFR for 7 days at 12
h/day; SAR 0.09 W/kg

Mitochondrial genome damage in
epididymal spermatozoa.

Akdag et al. (2016)

Male Wistar-Albino
rats to 2400 MHz RFR
from a Wi-Fi signal
generator for a year;
SAR 0.000141 (min)-
0.007127 (max) W/kg

DNA damage in testes.

Alkis et al. (2019a)

Rats exposed to 900
MHz (brain SAR
0.0845 W/kg), 1800
MHz (0.04563 W/kg),
and 2100 MHz
(0.03957 W/kg) RFR
2 h/day for 6 months

Increased DNA strand breaks and
oxidative DNA damage in brain.

Alkis et al. (2019b)

Rats exposed to 900
MHz, 1800 MHz, and
2100 MHz RFR 2
h/day for 6 months;
maximum SAR over
the rat 0.017 W/kg

DNA strand beaks and oxidative
DNA damage in testicular tissue.

Atasoy et al. (2013)

Male Wister rats
exposed to 2437 MHz
(Wi-Fi) RFR; 24 h/day
for 20 weeks;
maximum SAR 0.091
W/kg

Oxidative DNA damage in blood
and testes.

Beaubois et al. (2007)

Leaves of tomato plant
exposed to 900-MHz
RFR for 10 min at
0.0066 mW/cm2

Increased expression of leucine-
zipper transcription factor (bZIP)
gene.

Belyaev et al. (2005)

Lymphocytes from
human subjects
exposed to GSM 915
MHz RFR for 2 h ;
SAR 0.037 W/kg;

Increased condensation of
chromatin.

Belyaev et al. (2009)

Human lymphocytes
exposed to UMTS cell
phone signal (1947.4
MHz, 5 MHz band

Chromatin affected and inhibition
of DNA double-strand break.


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width) for 1 h; SAR
0.04 W/kg



Bourdineaud et al.
(2017)

Eisenia fetida
earthworms exposed
to 900 MHz for 2 h;
SAR 0.00013-0.00933
W/kg

DNA genotoxic effect and
HSP70 gene expressions up
regulated.

Campisi et al. (2010)

Rat neocortical
astroglial to CW 900
MHz RFR for 5, 10, or
20 min; incident
power density 0.0265
mW/cm2

Significant increases in DNA
fragmentation.

Chaturvedi et al.
(2011)

Male mice exposed to
2450 MHz RFR, 2
h/day for 30 days;
SAR 0.03561 W/kg

Increased DNA strand breaks in
brain cells.

Deshmukh et al.
(2013)

Male Fischer rats
exposed to 900 MHz
(0.0005953 W/kg),
1800 MHz (0.0005835
W/kg), and 2450 MHz
(0.0006672 W/kg)
RFR for 2 h/day, 5
days/week for 30 days.

Increased DNA strand breaks in
brain tissues.

Deshmukh et al.
(2015)

Male Fischer rats
exposed to 900 MHz
(0.0005953 W/kg),
1800 MHz (0.0005835
W/kg), and 2450 MHz
(0.0006672 W/kg)
RFR for 2 h/day, 5
days/week for 180
days.

Increased DNA strand breaks in
brain tissues.

Deshmukh et al.
(2016)

Male Fischer rats
exposed to 900 MHz
(0.0005953 W/kg),
1800 MHz (0.0005835
W/kg), and 2450 MHz
(0.0006672 W/kg)
RFR for 2 h/day, 5
days/week for 90 days.

Increased DNA strand breaks in
brain tissues.

Eker et al. (2018)

Female Wistar albino
rats exposed to 1800-
MHz RFR for 2 h/day

Caspase-3 and p38MAPK gene
expressions increased in eye
tissues.


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for 8 weeks; SAR 0.06
W/kg



Furtado-Filho et al.
(2014)

Rats of different ages
(0-30 days) exposed to
950 MHz RFR for 0.5
h/day for 51 days (21
days of gestation and
6-30 days old): SAR
pregnant rat 0.01-0.03
W/kg; neonate 0.88
W/kg, 6-day old 0.51
W/kg, 15-day old 0.18
W/kg, 30-day old 0.06
W/kg.

Decreased DNA strand breaks in
liver of 15-day old and increased
breaks in 30-day old rats..

Gulati et al. (2016)

Blood and buccal cells
of people lived close
(<400 meters) to a cell
tower; 1800 MHz,
Maximum power
density (at 150 meters)
0.00122 mW/cm2,
some subjects lived in
the area for more than
9 yrs

Increased DNA strand breaks in
lymphocytes and micronucleus in
buccal cells.

Giirler (2014)

Wistar rats exposed to
2450 MHz RFR 1
h/day for 30
consecutive days;
power density 0.0036
mW/cm2

Increased oxidative DNA damage
in brain and blood.

Hand et al. (2013)

Pregnant rats exposed
1 h/day on days 13-21
of pregnancy to 900-
MHz RFR at power
density 0.0265
mW/cm2

Testicular tissue of 21-day old
offspring showed increased DNA
oxidative damage.

He et al. (2016)

Mouse bone marrow
stromal cells exposed
to 900 MHz RFR 3
h/day for 5 days; SAR
4.1 x 10"4 W/kg
(peak), 2.5 x 10-4
W/kg (average)

Increased expression of PARP-1
mRNA

Hekmat et al. (2013)

Calf thymus exposed
to 940 MHz RFR for

Altered DNA structure at 0 and 2
h after exposure.


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45 min; SAR 0.04
W/kg



Keleงand Slit (2021)

Pregnant rats exposed
to 900-MH RFR at
0.0265 mW/cm2; 1
h/day from El3.5 until
birth; thoracis spine of
offspring examined.

Down regulation of H3K27me3
gene, am epigenetic modification
to the DNA packaging protein
Histone H3 in motor nerons.

Kesari and Behari
(2009)

Male Wistar rats
exposed to 50 GHz
RFR for 2 h/day for 45
days; SAR 0.0008
W/kg

Increased in brain tissue DNA
strand.

Kumar R. et al. (2021)

Male Wistar rats
exposed to 900, 100,
2450 MHz RFR at
SARs of 5.84 x 10"
4 W/kg, 5.94 x 10"
4 W/kg and 6.4 x 10"
4 W/kg respectively
for 2 h per day for 1-
month, 3-month and 6-
month

Microwave exposure with
increasing frequency and
exposure duration brings
significant (p < 0.05) epigenetic
modulations which alters gene
expression in the rat
hippocampus. Global DNA
methylation was decreased and
histone methylation was
increased.

Kumar S. et al. (2010)

Male Wistar rats
exposed to 10-GHz
RFR for 2 h a day for
45 days, SAR 0.014
W/kg

Increased micronucleus in blood
cells.

Kumar S. et al. (2013)

Male Wistar rats
exposed to 10 GHz
RFR for 2 h a day for
45 days; SAR 0.014
W/kg

Increased micronucleus in blood
cells and DNA strand breaks in
spermatozoa.

Marinelli et al. (2004)

Acute T-
lymphoblastoid
leukemia cells
exposed to 900 MHz
RFR for 2-48 h, SAR
0.0035 W/kg

Increased DNA damage and
activation of genes involved in
pro-survival signaling.

Markova et al. (2005)

Human lymphocytes
exposed to 905 and
915 MHz GSM
signals for 1 h; SAR
0.037 W/kg

Affected chromatin conformation
and 53BPl/gamma-H2AX foci

Markova et al. (2010)

Human diploid VH-10
fibroblasts and human

Inhibited tumor suppressor TP53
binding protein 1 (53BP1) foci


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adipose-tissue derived
mesenchymal stem
cells exposed to GSM
(905 MHz or 915
MHz) or UMTS
(1947.4 MHz, middle
channel) RFR for 1, 2,
or 3 hr; SAR 0.037-
0.039 W/kg

that are typically formed at the
sites of DNA double strand break
location.

Megha et al. (2015 a)

Fischer rats exposed to
900 and 1800 MHz
RFR for 30 days (2
h/day, 5 days/week),
SAR 0.00059 and
0.00058 W/kg

Reduced levels of
neurotransmitters dopamine,
norepinephrine, epinephrine, and
serotonin, and downregulation of
mRNA of tyrosine hydroxylase
and tryptophan hydroxylase
(synthesizing enzymes for the
transmitters) in the hippocampus.

Megha et al. (2015b)

Fischer rats exposed to
900, 1800, and 2450
MHz RFR for 60 days
(2 h/day, 5
days/week); SAR
0.00059, 0.00058, and
0.00066 W/kg

Increased DNA damage in the
hippocampus

Nittby et al. (2008)

Fischer 344 rats
exposed to 1800 MHz
GSM RFR for 6 h;
SAR whole body
average 0.013 W/kg,
head 0.03 W/kg

Expression in cortex and
hippocampus of genes connected
with membrane functions.

Odaci et al. (2016)

Pregnant Sprague -
Dawley rats exposed
to 900 MHz RFR 1 h
each day during days
13 - 21 of pregnancy;
whole body average
SAR 0.024 W/kg

Testis and epididymis of offspring
showed higher DNA oxidation.

Pandey et al. (2017)

Swiss albino mice
exposed to 900-MHz
RFR for 4 or 8 h per
day for 35 days; SAR
0.0054-0.0516 W/kg

DNA strand breaks in germ cells.

Pesnya and
Romanovsky (2013)

Onion (Allium cepa)
exposed to GSM 900-
MHz RFR from a cell

Increased the mitotic index, the
frequency of mitotic and
chromosome abnormalities, and


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phone for 1 h/day or 9
h/day for 3 days;
incident power density
0.0005 mW/cm2

the micronucleus frequency in an
exposure-duration manner.

Phillips et al. (1998)

Human Molt-4 T-
lymphoblastoid cells
exposed to pulsed
signals at cellular
telephone frequencies
of 813.5625 MHz
(iDEN signal) and
836.55 MHz (TDMA
signal) for 2or 21 h.
SAR 0.0024 and 0.024
W/Kg for iDEN and
0.0026 and 0.026
W/kg for TDMA)

Changes in DNA strand breaks

Qin et al. (2018)

Male mice exposed to
1800-MHz RFR 2
h/day for 32 days,
SAR 0.0553 W/kg

Inhibition of testosterone
synthesis might be mediated
through CaMKI/RORa signaling
pathway.

Rammal et al. (2014)

Tomato exposed to a
1250-MHz RFR for 10
days at 0.0095
mW/cm2

Increased expression of two
wound-plant genes.

Roux et al. (2006)

Tomato plants
exposed to a 900-MHz
RFR for 2-10 min at
0.0066 mW/cm2

Induction of stress gene
expression.

Roux et al. (2008)

Tomato plants
exposed to a 900-MHz
RFR for 10 min at
0.0066 mW/cm2

Induction of stress gene
expression.

Sarimov et al. (2004)

Human lymphocytes
exposed to GSM 895-
915 MHz signals for
30 min; SAR 0.0054
W/kg

Condensation of chromatin was
observed.

Shahin et al. (2013)

Female mice (Mus
musculus) exposed to
continuous-wave 2.45
GHz RFR 2 h/day for
45v days; SAR 0.023
W/kg

Increased DNA strand breaks in
the brain.


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Sun Y. etal. (2017)

Human HL-60 cells
exposed to 900 Hz
RFR 5 h/day for 5
days; peak and
average 0.00041 and
0.00025 W/kg,
respectively.

Increased oxidative DNA damage
and decreased mitochondrial gene
expression.

Tkalecetal. (2013)

Earthworm (Eisenia
fetida) exposed to
comtinupus-wave and
AM-modulated 900-
MHz RFR for 2 - 4 h;
SAR 0.00013,
0.00035, 0.0011, and
0.00933 W/kg

Increased DNA strand breaks.

Tsybulin et al. (2013)

Japanese Quail
embryos exposed in
ovo to GSM 900 MHz
signal from a cell
phone intermittently
(48 sec ON/12 sec
OFF) during initial 38
h of brooding or for
158 h (120 h before
brooding plus initial
38 h of brooding):
SAR 0.000003 W/kg

The lower duration of exposure
decreased DNA strand breaks,
whereas higher duration resulted
in a significant increase in DNA
damage.

Vian et al. (2006)

Tomato plants
exposed to a 900-MHz
RFR for 10 min at
0.0066 mW/cm2

Induction of mRNA encoding the
stress-related bZIP transcription
factor.

Yakymenko et al.
(2018)

Quail embryos
exposed to GSM 1800
GHz signal from a
smart phone (48 s
ON/12 s OFF) for5
days before and 14
days during
incubation, power
density 0.00032
mW/cm2

Increased DNA strand breaks and
oxidative DNA damage.

Zong et al. (2015)

Mice exposed to 900
MHz RFR 4 h/day for
7 days; SAR 0.05
W/kg

Attenuated bl eomyci n-i nduced
DNA breaks and repair.


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Part 2. Supplement 2.

Genetic Effects at Low Intensity Static/ELF EMF Exposure

Static and ELF EMF
Studies

magnetic flux density

Effects observed

Agliassa et al. (2018)

Arabidopsis thaliana
(thale cress) exposed
to 0.00004 mT static
magnetic field for 38
days after sowing

Changes in gene expression in
leaf and floral meristem.

Baeketal. (2019)

Mouse embryonic
stem cells exposed to
hypomagnetic field
(<0.005 mT) up to 12
days

Induced abnormal DNA
methylation.

Bagheri Hosseinabadi
et al. (2020)

Blood samples from
thermal power plant
workers; mean levels
of exposure to ELF
magnetic and
electric fields were
0.0165 mT (ฑ6.46)
and 22.5 V/m
(ฑ5.38), respectively.

DNA strand breaks .in
lymphocytes.

Barauna et al. (2015)

Chromobacterium
violaceum bacteria
cultures exposed to
ELF-EMF for 7 h at
0.00066 mT

Five differentially expressed
proteins detected including the
DNA-binding stress protein.

Belyaev et al. (2005)

Human lymphocytes
exposed to 50 Hz
magnetic field at 0.015
mT (peak) for 2 h
(measurements made
at 24 and 48 h after
exposure).

Induced chromatin conformation
changes.

Dominici et al. (2011)

Lymphocytes from
welders (average
magnetic field
exposure from
personal dosimeters
0.00781 mT (general
environmental level
0.00003 mT)

Higher micronucleus frequency
correlated with EMF exposure
levels; decreased in sister
chromatid exchange frequency.


-------
Heredi a-Roi as et al.
(2010)

Human non-small cell
lung cancer cells
(INER-37) and mouse
lymphoma cells (RMA
E7) (transfected with a
plasmid with hsp70
expression when
exposed to magnetic
field and contains the
reporter for the
luciferases gene)
exposed to a 60-Hz
magnetic field at 0.008
and 0.00008 mT for
20 min.

An increased in luciferase gene
expression was observed in
INER-37 cells.

Liboff et al. (1984)

Human fibroblasts
dring the middle of S
phaseexposed to 15
Hz-4 kHz sinusoidal
MF

Enhanced DNA synthesis at
between 5-25 |j,T

Sarimov et al. (2011)

Human lymphocytes
exposed to 50-Hz
magnetic field at
0.005-0.02 mT for 15-
180 min

Magnetic field condensed relaxed
chromatin and relaxed condensed
chromatin.

Villarini et al. (2015)

Blood leukocytes from
electric arc welders
presumably exposed to
50-Hz EMF (mean
0.0078 mT; range:
0.00003-0.171 mT)

Decreased DNA strand beaks.

Wahab et al. (2007)

Human peripheral
blood lymphocytes
exposed to 50 Hz
sinusoidal (continuous
or pulsed) or square
(continuous or pulsed)
magnetic fields at
0.001 or 1 mT for 72
h.

Increase in the number of sister
chromatid exchange/cell

Zendehdel et al.
(2019)

Peripheral blood cells
of male power line
workers in a power
plant. The median
value of the magnetic

Increased in DNA strand breaks.


-------
field at the working
sites was 0.00085 mT.

References: Table 2

Agliassa C, Narayana R, Bertea CM, Rodgers CT, Maffei ME. Reduction of

the geomagnetic field delays Arabidopsis thaliana flowering time through downregulation of

flowering-related genes. Bioelectromagnetics. 39:361-374, 2018.

Baek S, Choi H, Park H, Cho B, Kim S, Kim J. Effects of a hypomagnetic field on DNA
methylation during the differentiation of embryonic stem cells. Sci Rep. 9:1333, 2019.

Bagheri Hosseinabadi M, Khanjani N, Atashi A, Norouzi P, Mirbadie SR, Mirzaii M. The effect
of vitamin E and C on comet assay indices and apoptosis in power plant workers: A double blind
randomized controlled clinical trial. MutatRes. 850-851:503150, 2020.

Barauna RA, Santos AV, Gra9as DA, Santos DM, Ghilardi R Junior, Pimenta AM, Carepo MS,
Schneider MP, Silva A. Exposure to an extremely low-frequency electromagnetic field only
slightly modifies the proteome of Chromobacterium violaceum ATCC 12472. Genet Mol Biol.
38:227-230, 2015.

Belyaev IY, Hillert L, Protopopova M, Tamm C, Malmgren LO, Persson BR, Selivanova G,
Harms-Ringdahl M. 915 MHz microwaves and 50 Hz magnetic field affect chromatin
conformation and 53BP1 foci in human lymphocytes from hypersensitive and healthy persons.
Bioelectromagnetics 26:173-184, 2005.

Dominici L. Villarini M. Fatigoni C. Monarca S. Moretti M. Genotoxic hazard evaluation in
welders occupationally exposed to extremely low-frequency magnetic fields (ELF-MF). Int J
Hyg Environ Health. 215:68-75. 2011.

Heredia-Roias J A. Rodriguez de la Fuente AO. Alcocer Gonzalez JM. Rodriguez-Flores LE.
Rodriguez-Padilla C. Santovo-Stephano MA. Castaneda-Garza E. Tamez-Guerra RS. Effect of
60 Hz magnetic fields on the activation of hsp70 promoter in cultured INER-37 and RMA E7
cells. In Vitro Cell Dev Biol Anim. 46:758-63. 2010.

Liboff AR, Williams T Jr, Strong DM, Wistar R Jr. Time-varying magnetic fields: effect on
DNA synthesis. Science 223:818-820, 1984.

Sarimov. R.. Alipov. E.D.. Belyaev. I.Y. Fifty hertz magnetic fields individually affect chromatin
conformation in human lymphocytes: dependence on amplitude, temperature, and initial
chromatin state. Bioelectromagnetics. 32:570-579, 2011.

Villarini M, Dominici L, Fatigoni C, Levorato S, Vannini S, Monarca S, Moretti M. Primary
DNA damage in welders occupationally exposed to extremely-low-frequency magnetic fields
(ELF-MF). Ann Ig. 27:511-519, 2015.


-------
Wahab MA, Podd JV, Rapley BI, Rowland RE. Elevated sister chromatid exchange frequencies
in dividing human peripheral blood lymphocytes exposed to 50 Hz magnetic fields.
Bioelectromagnetics. 28:281-288. 2007.

Zendehdel R. Yu IJ. Haiipour-Verdom B. Paniali Z. DNA effects of low level occupational
exposure to extremely low frequency electromagnetic fields (50/60 Hz). Toxicol Ind Health.
35:424-430, 2019.


-------
Part 2. Supplement 3
Biological Effects in Animals and Plants Exposed to Low-Intensity RFR





SAR
(W/kg)

Power density (|iW/cm2)

Effects reported

Aitken et al. (2005)

Mice exposed to
900 MHz RFR,
12/day. 7 days

0.09



Genotoxic effect in sperm.

Akdag et al. (2016)

Rats exposed to
2400 MHz RFR
from a Wi-Fi signal
generator for a year

0.000141
(min)-
0.007127
(max)



DNA damage in testes.

Alimohammadi et al.
(2018)

pregnant mice
exposed to 915
MHz RFR; 8h/day,
10 days.



0.045

Offspring had increased
fetal weight, enlarged liver
and tail deformation

Alkis et al. (2019a)

Rtas exposed to
900;1800;and
2100 MHz RFR; 2
h/day. 6 months

Brain SAR:
900 MHz -
0.0845;
1800 MHz-
0.04563;
210 MHz-
0.03957



DNA single strand break
and oxidative damages in
frontal lobe.

Alkis et al. (2019b)

Rats exposed to
900;1800;and
2100 MHz RFR; 2
h/day. 6 months

maximum
SAR over
the rat body
0.017



DNA strand beaks and
oxidative DNA damage in
testicular tissue.

Atasoy et al. (2013)

Rats exposed to
2437 MHz (Wi-Fi)
RFR; 24 h/day for
20 weeks

maximum
SAR 0.091



Oxidative DNA damage in
blood and testes.


-------
Balmori et al. (2010)

Frog (Rana
temporaria)
exposed to 88.5 -
1873.6 MHz, cell
phone base station
emissions; 2
months from egg
phase to tadpole



0.859-3.25
(1.5-3.8 V/m)

Retarded development
and increased mortality
rate.

Balmori et al (2015)

White stocks lived
within 200 m of a
Phone mast, GSM-
900 MHz and DCS-
1800 MHz signals



1.48

Affected reproduction rate.

Bartosetal. (2019)

Cockroach exposed
to broadband RF
noise



429 nT

Light-dependent slowing
of circadian rhythm.

Beaubois et al. (2007)

Tomato plant
exposed to 900-
MHz RFR for 10
min



6.6

Increased expression of
leucine-zipper
transcription factor (bZIP)
gene in leaves.

Bedir et al. (2018)

Rat exposed to
2100 MHz RFR, 6
or 19 h/day, 30
days

0.024



Oxidative stress-mediated
renal injury.

Belyaev et al. (1992)

E. coli exposed to
51.62-51.84 and
41.25-41.50 GHz
RFR, 5-15 min



1

Suppressed radiation-
induced repair of genome
conformation state.

Belyaev et al. (2005)

915 MHz GSM
signal, 24 & 48 hr

0.037



Genetic changes in human
white blood cells

Belyaev et al. (2009)

915 MHz, 1947
MHz;

GSM, UMTS
signals
24 & 72 hr

0.037



DNA repair mechanism in
human white blood cells

Bourdineaud et al.
(2017)

Earthworm (Eisenia
fetida) exposed to
900 MHz RFR, 2 hr

0.00013-
0.009



DNA modification.


-------
Burlaka et al. (2013)

Japanese quail
embryos exposed to
GSM 900 MHz
RFR; 158-360 hr



0.25

Oxidative DNA damage
and free radical formation

Capri et al. (2004)

900 MHz, GSM
signal, 1 hr/day, 3
days

0.07



Cell proliferation and
membrane chemistry

Cammaerts and
Johansson (2015)

Brassicaceae
lepidium sativum
(cress d'alinois)
seed exposed to 900
and 1800 MHz
RFR, 4, 7, and 10
days



0.007-0.01

Defect in germination.

Cammaerts et al.
(2013)

Ants exposed to
GSM signal for 180
h



0.1572

Affected food collection
and response to
pheromones.

Cammaerts et al.
(2014)

Ants exposed to
GSM signal for 10
min



0.5968

Affected social behavior.

Campisi et al. (2010)

Rat neocortical
astroglial cells
exposed to 50-Hz
modulated 900 Mhz
RFR, 5-20 min



26

Free radical production
and DNA fragmentation.

Czerwinski et al.
(2020)

Plant community
exposed to cell
phone base station
radiation



0.01-0.1

Biological effects
observed.

Chaturvedi et al.
(2011)

Rat brain cells
exposed to 2450
MHz RFR, 2 h/day
for 30 days

0.03561



Increased DNA strand
breaks.

Comelekoglu et al.
(2018)

Rat sciatic nerve
exposed to 1800
MHz RFR, 1
hr/day, 4 weeks

0.00421



Changes in electrical
activity, increased catalase,
and degeneration of
myelinated fibers.


-------
De Pomerai et al.
(2003)

Protein exposed to
1 GHz RFR,
24 & 48 hr

0.015



Protein damages

Deshmukh et al.
(2013)

Rats exposed to
900, 1800, and
2450 MHz RFR;
30 days

0.0006-
0.0007



DNA strand breaks in
brain.

Deshmukh et al.
(2015)

Rats exposed to
900, 1800, and
2450 MHz RFR;
180 days

0.0006-
0.0007



Declined cognitive
functions, increased brain
HSP70 and DNA strand
break.

Deshmukh et al.
(2016)

Rats exposed 900,
1800, and 2450
MHz; 90 days

0.0006-
0.0007



Declined cognitive
functions, increased brain
HSP70 and DNA strand
break in rats

Dutta et al. (1984)

human

neuroblastoma cells
exposed to 915
MHz RFR,
sinusoidal AM at
16 Hz

0.05



Increase in calcium efflux.

Dutta et al. (1994)

Escherichia coli
cultures containing
a plasmid with a
mammalian gene
for enolase were
exposed for 30 min
to 147 MHz RFR
AM atl6 or 60 Hz

0.05



Enolase activity in
exposed cultures RFR at
AM at 16 Hz showed
enhanced activity
enhanced, and AM at 60
Hz showed reduced
activity. (Modulation
frequencies. 16 and 60 Hz,
caused similar effects.)

Eker et al. (2018)

Rats exposed to
1800 MHz RFR, 2
hr/day for 8 weeks

0.06



Increased caspase-3 and
p38MAPK expressions in
eye.

Fesenko et al. (1999)

Mice exposed to
8 .15- 18 GHz
RFR, 5 hr to 7 days,
direction of
response depended
on exposure
duration



1

Changes in immunological
functions.


-------
Forgacs et al. (2006)

Mice exposed to
1800 MHz RFR,
GSM-217 Hz
pulses, 576 |j,s pulse
width; 2 hr/day, 10
days

0.018



Increase in serum
testosterone.

Fr^tczak et al. (2020)

Ticks exposed to
900 MHz RFR



0.1

Ticks attracted to the RFR,
particularly those infected
with Rickettsia (spotted
fever).

Friedman et al. (2007)

Rat and human cells
exposed to 875
MHz RFR, 30 min



5

Activation of signaling
pathways.

Furtado-Filho et al.
(2014)

Pregnant rats
exposed to 950
MHz RFR for 0.5
h/day for 51 days
(21 days of
gestation and 6-30
days old)

SAR

pregnant rat

0.01-0.03

W/kg;

neonate 0.88
W/kg, 6-day
old 0.51
W/kg, 15-
day old 0.18
W/kg, 30-
day old 0.06
W/kg



Decreased DNA strand
breaks in liver of 15-day
old and increased breaks in
30-day old offspring.

Gandhi et al. (2015)

People who lived
within 300 m of a
mobile-phone base
station.



1.15

Increased DNA damage in
lymphocytes, more in
female than in male
subjects.

Garaj-Vrhovac et al.
(2011)

Operators of two
types of marine
radars (3, 9.4, and
5.5 GHz); average
time on job 2-16 yrs

0.0005-
0.004 (time
averaged)



Increased genetic damages
in blood lymphocytes


-------
Gremiaux et al. (2016)

Rose exposed to
900 MHz RFR, 3x
39min every 48 h at
2 stages of
development

0.00072



Delayed and reduced
growth.

Gulati et al. (2016)

People lived close
(<400 meters) to a
cell tower; 1800
MHz,, some
subjects lived in the
area for more than 9
yrs



Maximum power density
(at 150 meters) 1.22

Increased DNA strand
breaks in lymphocytes and
micronucleus in buccal
cells.

Gulati et al. (2020)

DNA damage in
human lymphocytes

Cells

exposed to

UMTS

signals at

different

frequency

channels

used by 3 G

mobile

phone

(1923,

1947.47,

and 1977

MHz) for 1

or 3 h; SAR

0.04 W/kg



DNA damage found only
in cells exposed to 1977-
MHz field.

Gupta et al. (2018)

Rtas exposed to
2450 MHz RFR;
lh/day 28 days

0.0616



Cognitive deficit, loss of
mitochondrial functions,
activation of apoptotic
factors in hippocampus;
affected cholinergic
system.

Gurler et al. (2014)

Rats exposed to
2.45 GHz RFR, 1
h/day, 30 days



3.59

Increased DNA damage in
brain.


-------
Halgamuge et al.
(2015)

Growth parameters
of soybean
seedlings

GSM 217
Hz-

modulated
(4.8 x 10"7,
4.9 x 10"5,
and 0.0026
W/kg) SAR
or CW
(0.00039
and 0.02
W/kg) 900-
MHz RFR
for 2 h



Modulated and CW fields
produced different patterns
of growth effects. There
was an amplitude effect
and extremely low-level
modulated field (4.8 x 10"7
W/kg) affected all
parameters.

Hand et al. (2013)

Pregnant rats
exposed 1 h/day on
days 13-21 of
pregnancy to 900-
MHz RFR



26.5

Testicular tissue of 21-day
old offspring showed
increased DNA oxidative
damage.

Hand et al. (2018)

Rats exposed to 900
MHz RFR, 1 h/day
to postnatal day 60.

0.0067



Changes in morphology
and increase in oxidative
stress marker in testis.

Hassig et al. (2014)

Cows exposed to
916.5 MHz signal
similar to GSM
base station, 30
days 16 h 43 min
per day



38.2

Changes in redox enzymes
(SOD. CAT, GSH-px

He et al. (2016)

Mouse bone
marrow stromal
cells exposed to
900 MHz RFR 3
h/day for 5 days

2.5 x 10"4



Increased expression of
PARP-1 mRNA

Hekmat et al. (2013)

Calf thymus
exposed to 940
MHz RFR, 45 min

0.04



Conformational changes in
DNA.


-------
Ivaschuk et al. (1997)

Nerve growth
factor-treated PC 12
rat

pheochromocytoma
cells 836.55 MHz
TDMA signal,
20 min

0.026



Transcript levels for c-jun
altered.

Ji et al. (2016)

Mouse bone-
marrow stromal
cells exposed to 900
MHz RFR, 4 hr/day
for 5 days



120

Faster kinetics of DNA-
strand break repair.

Keleง et al. (2019)

Rats exposed tp 900
MHz RFR; lh/day,
25days

0.012



Higher number of
pyramidal and granule
neurons in hippocampus.

Kesari and Behari
(2009)

Rats exposed to 50
GHz RFR; 2hr/day,
45 days

0.0008



Double strand DNA breaks
observed in brain cells

Kesari and Behari
(2010)

Rats exposed to 50
GHz RFR; 2 hr/day,
45 days

0.0008



Changes in oxidative
processes and apoptosis in
reproductive system.

Kesari et al. (2010)

Rats exposed to
2450 MHz RFR at
50-Hz modulation,
2 hr/day, 35 days

0.11



DNA double strand breaks
in brain cells

Kumar et al. (2010a)

Rats exposed to 10
GHz RFR, 2h/day
45 days

0.014



Cellular changes and
increase in reactive oxygen
species in testes

Kumar et al. (2010b)

Rats exposed to 10
GHz RFR, 2 h/day,
45 days; or 50 GHz,
2h/day, 45 days

0.014(10
GHz)

0.0008 (50
GHz)



Genetic damages in blood
cells.


-------
Kumar et al. (2013)

Rats exposed to 10
GHz RFR for 2 h a
day for 45 days

0.014



Increased micronucleus in
blood cells and DNA
strand breaks in
spermatozoa.

Kumar et al. (2015)

maize seedlings
exposed to 1899
MHz RFR, 0.5-4 h



33.2

Retarded growth and
decreased chlorophyll
content.

Kumar et al. (2021)

Epigenetic
modulation in the
hippocampus of
Wistar rats

Rats

exposed to
900 MHz,
1800 MHz,
and 2450
MHz RFR at
a specific
absorption
rate (SAR)
of 5.84 x 10"
4 W/kg, 5.94
x 10"4 W/kg
and 6.4 x
10"4 W/kg
respectively
for 2 h per
day for 1-
month, 3-
month and
6-month
periods.



Significant epigenetic
modulations were
observed in the
hippocampus, larger
changes with increasing
frequency and exposure
duration.

Kwee et al. (2001)

Transformed human
epithelial amnion
cells exposed to
960 MHz GSM
signal, 20 min

0.0021



Increased Hsp-70 stress
protein.

Landler et al. (2015)

Juvenile snapping
turtle (c. serpentina)
exposed to 1.43
MHz RFR, 20 min



20-52 nT

Disrupted magnetic
orientation.


-------
Lazaro et al. (2016)

50, 100, 200, 400 m
from ten mobile
tel ecommuni cati on
antennas



0.0000265 -0.106

Distance-dependent effects
on abundance and
composition of wild insect
pollinators

Lerchl et al. (2008)

383 MHz

(TETRA), 900 and
1800 MHz (GSM)
24 hr/day, 60 days

0.08



Metabolic changes in
hamster.

Lopez-Martin et al.
(2009)

Pulse-modulated
GSM and
unmodulated
signals; 2 hr

0.03-0.26



c-Fos expression in brain
of picotoxin-induced
seizure-prone rats

Magras and Xenos
(1997)

Mice in 'antenna
park'-TV and FM-
radio, exposure
over several
generations



0.168

Decrease in reproductive
functions.

Marinelli et al. (2004)

Human leukemia
cell exposed to 900
MHz CW RFR
2 - 48 hr

0.0035



Cell's self-defense
responses triggered by
DNA damage.

Makova et al. (2005)

human white blood
cells exposed to 915
and 905 MHz GSM
signal,

1 hr

0.037



Altered chromatin
conformation.

Markova et al. (2010)

in human diploid
VH-10 fibroblasts
and human adipose-
tissue derived
mesenchymal stem
cells exposed to
GSM (905 MHz or
915 MHz) or
UMTS (1947.4
MHz, middle
channel) RFR for 1,
2, or 3 hr;

0.037-0.039



Inhibited tumor suppressor
TP53 binding protein 1
(53BP1) foci that are
typically formed at the
sites of DNA double strand
break location.


-------
Megha et al. (2015 a)

Rats exposed to 900
and 1800 MHz
RFR for 30 days (2
h/day, 5 days/week)

0.00059 and
0.00058



Reduced levels of
neurotransmitters
dopamine, norepinephrine,
epinephrine, and serotonin,
and downregulation of
mRNA of tyrosine
hydroxylase and
tryptophan hydroxylase
(synthesizing enzymes for
the transmitters) in the
hippocampus.

Megha et al. (2015b)

Rats exposed to
900, 1800, and
2450 MHz RFR for
60 days (2 h/day, 5
days/week)

0.00059,
0.00058,
and 0.00066



Increased DNA damage in
the hippocampus.

Monselise et al. (2011)

Etiolated duckweed
exposed to AM
1.287 MHz signal
form transmitting
antenna



0.859

(1,8-7.8 V/m)

Increased alanine
accumulation in cells.

Navakatikian and
Tomashevskaya (1994)

Rats exposed to
2450 MHz CW and
3000 MHz pulse-
modulated 2 |LXS
pulses at 400 Hz,
Single (0.5-12 hr)
or repeated (15-60
days, 7-12 hr/day)

0.0027



Behavioral and endocrine
changes, and decreases in
blood concentrations of
testosterone and insulin.
CW-no effect

Nittby et al. (2007)

Rats exposed to 900
MHz GSM signal,
2 hr/wk, 55wk

0.0006



Reduced memory
functions.

Nittby et al. (2008)

Rats exposed to 915
MHz GSM signal, 6
hr

0.013

(whole body
average);
0.03 (head)



Altered gene expression in
cortex and hippocampus.


-------
Novoselova et al.
(1999)

Mice exposed to
RFR from 8.15-18
GHz, 1 sec sweep
time-16 ms reverse,
5 hr



1

Changes in Functions of
the immune system.

Novoselova et al.
(2004)

Mice exposed to
RFR from 8.15-18
GHz, 1 sec sweep
time-16 ms reverse,
1.5 hr/day, 30 days



1

Decreased tumor growth
rate and enhanced survival.

Novoselova et al.
(2017)

Mice exposed to
8 .15 -18 GHz RFR,
1 Hz swinging
frequency, 1 hr



1

Enhanced plasma
cytokine.

Odaci et al. (2016)

Pregnant Sprague -
Dawley rats
exposed to 900
MHz RFR 1 h each
day during days 13
- 21 of pregnancy

0.024



Testis and epididymis of
offspring showed higher
DNA oxidation.

Ozsobaci et al. (2020)

Human kidney
embryonic cells
(HEK293) exposed
to 3450 MHz RFR,
1 h



1.06

Changed oxidative enzyme
activity and increased
apoptosis.

Panagopoulos and
Margaritis. (2010a)

Flies exposed to
GSM 900 and 1800
MHz RFR, 6
min/day, 5 days



10

'Window' effect of GSM
radiation on reproductive
capacity and cell death.

Panagopoulos and
Margaritis. (2010b)

Flies exposed to
GSM 900 and 1800
MHz RFR, 1-21
min/day, 5 days



10

Reproductive capacity of
the fly decreased linearly
with increased duration of
exposure.

Panagopoulos et al.
(2010)

Flies exposed GSM
900 and 1800 MHz
RFR, 6 min/day, 5
days



1-10

Affected reproductive
capacity and induced cell
death.

Pandey et al. (2017)

Mice exposed to
900-MHz RFR for

0.0054-
0.0516



DNA strand breaks in
germ cells.


-------


4 or 8 h per day for
35 days







Pavicic et al. (2008)

Chinese hamster
V79 cells exposed
to 864 and 935
MHzCWRFR, 1-3
hrs

0.08



Cell growth affected.

Perov et al. (2019)

Rats exposed to 171
MHz CW RFR,
6h/day, 15 days

0.006



Stimulation of adrenal
gland activity.

Persson et al. (1997)

Rats exposed to 915
MHz RFR -CW and
pulse-modulated
(217-Hz, 0.57 ms;
50-Hz, 6.6 ms) 2-
960 min.

0.0004



Increase in permeability of
the blood-brain barrier.
CW more potent.

Pesnya and
Romanovsky (2013)

Onion exposed to
GSM 900-MHz
RFR from a cell
phone for 1 h/day
or 9 h/day for 3
days.



0.5

Increased mitotic index,
frequency of mitotic and
chromosome
abnormalities, and
micronucleus frequency.

Phillips et al. (1998)

Human leukemia
cells exposed to
813.5625 MHz
(iDEN); 836.55
MHz (TDMA)
signals,

2 hr and 21 hr

0.0024



DNA damage observed.

Piccinetti et al. (2018)

Zebrafish exposed
to 100 MHz RFR,
24-72 h post-
fertilization

0.08



Retarded embroyonic
development.

Postaci et al. (2018)

Rats exposed to
2600 MHz RFR, 1
h/day, 30 days

0.011



Cellular damages and
oxidative damages in liver.


-------
Pyrpasopoulou et al.
(2004)

Rats exposed to 9.4
GHz GSM
(50 Hz pulses, 20
|lxs pulse length)
signal, 1-7 days
postcoitum

0.0005



Exposure during early
gestation affected kidney
development.

Qin et al. (2018)

Mice exposed to
1800-MHz RFR, 2
h/day for 32 days

0.0553



Inhibition of testosterone
synthesis.

Rafati et al. (2015)

Frog gastroenemius
muscle exposed to
cell phone jammers;
1 m away, 3x 10
min periods

For different
jammers: 0.0
1-0.05



Latency of contraction of
prolonged.

Ranmal et al. (2014)

Tomato exposed to
1250-MHz RFR for
10 days.



9.5

Increased expression of
two wound-plant genes.

Roux et al. (2006)

Tomatoes exposed
to 900-MHz RFR
for 2-10 min



6.6

Induction of stress gene
expression in tomato.

Roux et al. (2008a)

Tomatoes exposed
to 900 MHz RFR



6.6

Changes in Gene
expression and energy
metabolism.

Roux et al. (2008b)

Tomato plants
exposed to 900
MHz RFR (>30
min)



6.6

Changes in energy
metabolism in leave of
tomato plant.

Salford et al. (2003)

Rats exposed to 915
MHz GSM, 2 hr

0.02



Nerve cell damage in
brain.

Sarimov et al. (2004)

Human
lymphocytes
exposed to 895-915
MHz GSM signal,
30 min

0.0054



Chromatin affected similar
to stress response.


-------
Schwarz et al. (2008)

Human fibroblasts
exposed to 1950
MHz UMTS signal,
24 hr

0.05



Changes in genes.

Shahin et al. (2013)

Mice exposed to
2450 MHz RFR, 2
h/day for 45 days

0.023



Increased DNA strand
breaks in the brain.

Singh et al. (2012)

Hung beans
exposed to 900
MHz RFR, 0.5-2 h



8.54

Reduced root length and
number of roots per
hypocotyls.

Sirav and Seyhan
(2011)

Rats exposed to
CW 900 MHz or
1800 MHz for 20
min

CW 900

MHz

(0.00426

W/kg) or

1800 MHz

(0.00146

W/kg)



Increased blood-brain
barrier permeability in
male rats, no significant
effect on female rats.

Sirav and Seyhan
(2016)

Rats exposed to
pulsed-modulated
(217 Hz, 517 us
width) 900 MHz or
1800 MHz 6 RFR
for 20 min

0.02



In male rats, both
frequencies increased
blood-brain barrier
permeability, 1800 MHz is
more effective than 900
MHz; in female rats, only
900 MHz filed caused an
effect.

Somosz et al. (1991)

Rat embryo 3T3
cells exposed to
2450-MHz 16-Hz
square modulated
RFR

0.024



Increased the ruffling
activity of the cells, and
caused ultrastructural
alteration in the cytoplasm.
CW was less effective.

Soran et al. (2014)

Plants exposed to
GSM and WLAN
signals



10 (GSM)
7 (WLAN)

Enhanced release of
terpene from aromatic
plants; essential oil
contents in leaves
enhanced by GSM
radiation but reduced by
WLAN radiation in some
plants.


-------
Stagg et al. (1997)

Glioma cells
exposed to 836.55
MHz TDMA
signal, duty cycle
33%, 24 hr

0.0059



Glioma cells showed
significant increases in
thymidine incorporation,
which may be an
indication of an increase in
cell division.

Stankiewicz et al.
(2006)

Human white blood
cells exposed to 900
MHz GSM signal,
217 Hz pulses-.577
ms width, 15 min

0.024



Immune activities of
human white blood cells
affected.

Sun Y. et al. (2017)

Human HL-60 cells
exposed to 900 Hz
RFR, 5 h/day for 5
days

peak and
average
SAR 4.1 x
10"4 and 2.5
x 10"4 W/kg



Increased oxidative DNA
damage and decreased
mitochondrial gene
expression.

Szymanski et al.
(2020)

Human cells
exposed to Pulse-
modulated 900
MHz RFR, two 15-
min exposure

0.024



Human blood
mononucleus cells
demonstrated high
immunological activity of
monocytes and T-cell
response to concanavalin
A.

Tkalec et al. (2013)

Earthorm exposed
to continuous-wave
and AM-modulated
900- MHz RFR for
2 - 4 h

0.00013,
0.00035,
0.0011, and
0.00933



Increased DNA strand
breaks.

Tsybulin et al. (2012)

Japanese Quail
embryos exposed to
GSM 900 MHz
signal during first
38 h or 14 days of
fertilization



0.2

Enhanced development
and survival in Japanese
Quail embryos probably
via a free radical-induced
mechanism.

Tsybulin et al. (2013)

Japanese Quail
embryos exposed to
GSM 900 MHz
signal, 48 sec on/12
sec off; 38 or 158 h

0.003



Decreased DNA strand
break at 38 h and increased
in 158h exposure in cells.


-------
Vargova et al. (2017)

Ticks exposed to
900 MHz RFR



0.07

Ticks showed greater
movement activity, with
jerking movement of
whole body or first pair of
legs.

Vargova et al. (2018)

Ticks exposed to
900 MHz and 5000
MHz RFR



0.105

In a tube with half shielded
for RFR, ticks exposed to
900 MHz concentrated on
exposed side, and escaped
to shielded side when
exposed to 5000 MHz

Velizarov et al. (1999)

Human epithelial
amnion cells
exposed to 960
MHz GSM signal,
217 Hz square-
pulse, duty cycle
12%, 30 min

0.000021



Decreased proliferation

Veyret et al. (1991)

Exposure to 9.4
GHz 1 |lxs pulses at
1000 pps, also with
or without
sinusoidal AM
between 14 and 41
MHz, response only
with AM
modulation,
direction of
response depended
on AM frequency

0.015



Changes in functions of
the mouse immune system.

Vian et al. (2006)

Tomato plants
exposed to 900
MHz RFR



6.6

Stress gene expression in
plant.


-------
Vilicetal. (2017)

Oxidative effects
and DNA damage
in honey bee (Apis
mellifera) larvae



Honey bee larvae were
exposed to 900-MHz at
unmodulated field at 27
(iW/cm2 and modulated
(80% AM 1 kHz
sinusoidal) field at 140
(iW/cm2, for 2 hr.

Oxidative effect with
exposure to unmodulated
field. DNA damage
increased after exposure to
modulated field.

Waldmann-Salsam et
al. (2016)

Mobile phone mast,
long-term exposure



>0.005

Damages to trees

Wolkeetal. (1996)

Heart muscle cells
of guinea pig
exposed to 900,
1300, 1800 MHz,
square-wave
modulated at 217
Hz; Also 900 MHz
with CW, 16 Hz, 50
Hz and 30 KHz
modulations

0.001



Changed calcium
concentration in heart
muscle cells.

Yakymenko et al.
(2018)

Quail embryos
exposed to GSM
1800 GHz signal
from a smart phone
(48 s ON/12 s OFF)
for5 days before
and 14 days during
incubation



0.32

Increased DNA strand
breaks and oxidative DNA
damage.


-------
Yurekli et al. (2006)

945 MHz GSM,
217 Hz pulse-
modulation
7 hr/day, 8 days

0.0113



Free radical chemistry.

Zong et al. (2015)

Mice exposed to
900 MHz RFR, 4
h/day for 7 days

0.05



Attenuated bleomycin-
induced DNA breaks and
repair.

Author Note: Many of the biological studies are acute, mostly one-time, exposure experiments,
whereas exposure to ambient environmental man-made EMF is chronic. Acute and chronic
exposures will likely end up with different consequences. Living organisms can compensate for
the effect at the beginning of exposure and growth promotion in plants could be a result of over-
compensation. After prolonged exposure, a breakdown of the system could occur, leading to
detrimental effects. This sequence of response is basically how a living organism responds to
stressors. The timeline of response depends on the physiology of an organism and also the
intensity of exposure

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Supplement 4. Effects of EMF on plant growth



Experimental conditions

Results







STATIC MAGNETIC
FIELD





Abdani Nasiri et al.(2018)

medicinal sage; 15-30 mT, 5
min

enhanced growth

Baghel et al. (2016)

soybean; 200 mT, lh,

increased growth

Bahadir et al. (2018)

sweet pea ; 125 mT, 24-72 h

promoted germination

Bhardwaj et al. (2012)

cucumber; 100-250 mT, 1-3 h

increased germination rate,
length of seedling and dry
weight

Cirkovic et al. (2017)

wheat; 340 mT, 16 h

increased growth rate

Florez et al. (2007)

maize; 125 and 250 mT, 1 min
to 10 days

increased growth rate

Jovicic-Petrovic et al. (2021)

White mustard seed, 90 mT,
5 or 15 min

suppressed germination, but
synergistic with a plant

growth-promoting bacterial
strain Bacillus
amyloliquefaciens D5 ARV

Kataria et al. (2020)

soybean; 200 mT, 1 h

stimulated germination and
promoted growth

Kim et al. (2016)

agricultural plants ; 130-250
mT, 4 days

increased stem and root
lengths

Patel et al. (2017)

maize; 200 mT, 1 h

enhanced germination

Payez et al. (2013)

wheat; 30 mT, 4 days

promoted growth

Razmioo andAlinian (2017)

Cumin seed; 150, 250 500
mT or IT for min

improved germination,
growth and oil and essential
contents

Shabrangy et al. (2021)

barley seeds, 7 mT, 1,3, or 6
h

Improved seed germination
rate, root and shoot lengths,
and biomass weight

Vashisth and Joshi (2017)

maize; 50-250 mT, 1-4 h

enhanced seed growth

Vashisth and Nagarajan
(2008)

chickpea; 0-250 mT, 1-4 h

increased speed of
germination, seedling length
and dry weight

Xu et al. (2013)

rock cress, removal of the
local geomagnetic field (-45
HT)

suppressed growth







PULSED MAGNETIC
FIELD






-------
Bhardwaj et al. (2016)

green pea; 100 mT, 1 h, 6-
min on/off

enhanced germination and
growth

Bilalis et al. (2012)

corn; 3 Hz; 12.5 nT, 1 x 10"6
wave duration, 0-15 min

promoted plant growth and
yield

Efthimiadou et al. (2014)

tomato; 3 Hz, 12.5 mT, 1 x
10"6 s duration, 0-15 min

enhanced plant growth

Radhakrishnan et al. (2012a)

soybean; 1 Hz, 1.5 j_iT, 5
h/day for 20 days

improved plant growth

Radhakrishnan et al. (2012b)

soybean; 10 Hz, 1.5 j_iT, 5
h/day for 20 days

improved plant growth







ELF MAGNET FIELD





De Souza et al. (2008)

lettuce; 60-Hz, 120-160 mT,
1-5 min

enhanced growth and final
yield

Fischer et al. (2004)

sunflower and wheat; 16.67
Hz; 20 (j,T, 12 days

increased fresh and dry
weights and growth rate

Huang and Wang (2008)

Mungbean; 10-60 Hz
modulated, 12 h, 6.38-16.20
liT

20 and 60 Hz, enhanced
growth; 30, 40 and 50 Hz
inhibited growth

Leelapriya et al. (2003)

cotton; 10 Hz, 0.1 mT, 5 h/day
for 20 days

enhanced germination

Naz et al. (2012)

okra; 50 Hz, 99 mT, 3 and 11
min

increased germination

Novitskii et al. (2014)

radish; 50 Hz, 500 |j,T,5 days

stimulated lipid formation

Shine et al. (2011)

soybean; 50 Hz, 0-300 mT,
30-90 min

improved germination
parameters and biomass

Yano et al. (2004)

radish; 60 Hz, 50 j_iT plus a
parallel 48-[jT static magnetic
field, 10-15 days

decreased CO2 uptake , fresh
and dry weights and leaf area







RFR





Cammaerts and Johansson
(2015)

Garden cress; 900 and
1800 MHz, 0.007-0.01

(j,W/cm2, 10 days

decreased germination

Gremiaux et al. (2016)

rose, 900 MHz, 0.00072
W/kg, 3 hr once or 3 times,
every 48 hr

delayed and reduced growth

Halgamuge et al. (2015)

Soybean seedling. 900 MHz
GSM pulsed or CW, 0.45
mW/cm2, 2 h

GSM radiation reduced
outgrowth of epicotyls; CW
exposure reduced outgrowth
of roots and hypocotyls.

Kumar et al. (2015)

maize; 1800 MHz, 0.5-4 h,
33.2 |iW/cm2

retarded growth and reduced
chlorophyll content


-------
Mildaziene et al. (2019)

sunflower seed; 5.28
MHz, 5, 10, 15 min 0.74
mT

Changes in phytohormone
balance, development and
leaf protein expression

Payez et al. (2013)

wheat; 10 KHz, 4 days, 25
mW/cm2

reduced water intake,
increased speed of growth,
reduced seeding vigor index I

Senavirathna et al. (2014)

Parrot feather (Myriophyllum
aquaticum), 2000 MHz, 0.142
mW/cm2, 1 h

Reduction in growth

Singh et al. (2012)

Mung bean; 900 MHz, 8.54
[j,W/cm2, 0.5-2 h

reduced root length and
number of roots per
hypocotyls

Tkalec et al. (2009)

Onion; 400 and 900
MHz, 2h, 446 (iW/cm2

induced mitotic aberrations
due to impairment of the
mitotic spindle

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magnetic field. Bioelectromagnetics. 38:151-157.

Vashisth, A., and Nagarajan, S. 2008. Exposure of seeds to static magnetic field
enhances germination and early growth characteristics in chickpea (Cicer arietinum
L.). Bioelectromagnetics 29: 571-578.

Xu, C., Wei, S., Lu, Y., Zhang, Y., Chen, C., and Song, T. 2013. Removal of the
local geomagnetic field affects reproductive growth in Arabidopsis. Bioelectromagnetics.
34:437-442.

Yano, A., Ohashi, Y., Hirasaki, T., Fujiwara, K.2004. Effects of a 60 Hz magnetic field on
photosynthetic CO2 uptake and early growth of radish seedlings. Bioelectromagnetics. 25:572-
581.


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Secretary Jennifer M. Granholm

U.S. Department of Energy

1000 Independence Ave. SW

Washington DC 20585

Sent via Email: the.secretary@hq.doe.gov

April 29, 2022

Subject: Uranium Mining Concern
Dear Secretary Granholm:

Eastern Navajo Dine Against Uranium Mining (ENDAUM) is writing to express concern about
the U.S. Department of Energy's consideration of a "strategic uranium reserve." ENDAUM was
formed in 1994 in response to a proposed in situ leach (ISL) uranium mining project in the Dine
(Navajo) towns of Crownpoint and Churchrock, New Mexico. The proposed ISL project, called
the Crownpoint Uranium Project (CUP), targets uranium ore bodies in important underground
sources of drinking water for our towns and if begun, would destroy the sole source of drinking
water for the town of Crownpoint.

As a member of the Multicultural Alliance for a Safe Environment, we previously submitted
comments to you on October 13, 2021 in response to the RFI. We are deeply concerned with
ongoing discussions taking place to increase uranium mining in the United States due to Russia's
invasion of Ukraine. While we understand the United States' position on potentially banning
uranium imports from Russia, we cannot stress enough that any corporate subsidies that prop up
the domestic uranium mining industry will have significant, long term and devastating effects on
our communities and Indigenous communities across the country. A horrible war in Europe
should not be used as an excuse to harm our communities, other Dine communities under threat
of new uranium development, and other Indigenous communities located here in the United
States.

The Crownpoint Uranium Project is currently owned by a Canadian mining company Laramide
Resources, through its U.S. subsidiary NuFuels, Inc. While part of the CUP is on tribal lands
and therefore ostensibly ineligible to participate in the federal uranium program, part of the CUP
is on private land adjacent to tribal lands, yet still within Dine communities. Allowing the CUP

1


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to participate in a U.S. uranium mine reserve program under your Department will essentially
shift the sacrifice of lives in the war-torn Ukraine for lives of the Dine tribal members. This is
how serious we see this issue. President Biden ran for office pledging to protect tribal
communities and restore tribal sovereignty. We need you to support his pledge to us and not
allow the Crownpoint Uranium Project to participate under any federal uranium program. Doing
so would cut directly against President Biden's pledge and promises.

Further, the United States has a duty under its trust responsibility to protect our Dine
communities. We live in the year 2022, and the voice of our people should not go unheard.

While we appreciate prior statements from the Department of Energy that there is no intention to
initiate or expand mining "on Tribal lands, expand the Office of Legacy Management's (LM)
Uranium Leasing Program, or expand access to additional uranium deposits located on other
Federal lands," the Department misses a key understanding of the true issues involved. Most of
the potential damage to tribal interests occurs from activities on traditional aboriginal territories,
sacred sites, and lands adjacent to tribal lands, not "on tribal lands" itself. This is where the
federal trust responsibility should be at its strongest. Indian tribes, like the Navajo Nation, rely
on the federal government to protect its people from the harmful effects of uranium mining. It
should not matter where the mining occurs.

We have lived in our homeland, between the Four Sacred Mountains, in what are now the states
of New Mexico, Arizona, Colorado and Utah, for hundreds of years and the single largest threat
to our survival over these millennia has been the uranium industry. Mining for uranium not only
harms the surface environment but also contaminates our groundwater resources. Widespread
contamination from historic uranium development has already proven disastrous to the health of
our people. Subsidizing future uranium development on and near the Navajo Nation and at sites
within our traditional territory may well extinguish the Dine as a People. Polluting our land, air
and water with new uranium production will not only add additional health burdens, it will also
adversely affect our very identity as Dine. Our relationship with our land, air and water is sacred
and inextricably tied to our individual and collective identity.

We urgently ask the Department of Energy to uphold President Biden's pledge and promise to
protect the Navajo Nation and restore tribal sovereignty. We need you and others to hear our
voices. We ask that you prohibit participation of the Crownpoint Uranium Project and any other
future uranium development within the boundaries of the Four Sacred Mountains in any federal
uranium program or from accepting any federal funding to operate.

Respectfully,

/s/ Jonathan Perry
Jonathan Perry
Executive Director

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Eastern Navajo Dine Against Uranium Mining
President, Becenti Chapter

/s/ Rita Capitan	

Rita Capitan
ENDAUM Founder
President, Crownpoint Chapter

/s/ Larry King	

ENDAUM Member
President, Churchrock Chapter

Cc:

The Honorable Sen. Martin Heinrich

The Honorable Sen. Ben Ray Lujan

The Honorable Rep. Teresa Leger Fernandez

The Honorable Jonathan Nez, Navajo Nation President

Deb Haaland, Secretary of the Interior

Michael Regan, Administrator, U.S. EPA

Dr. Earthea Nance, Regional Administrator, EPA Region VI

National Environmental Justice Advisory Council

White House Environmental Justice Advisory Council

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RACIAL EQUITY<& SOCIAL JUSTICE: CELL TOWERS A>D ZTA19 07*

• Vulnerable households are disproportionately placed at risk by Montgomery County's lax
practices for reviewing and monitoring antennas on multi family dwellings. ZTA 19 07
exacerbates that gross inequity, rather than reducing or eliminating it.

Over a recent one year period, the Montgomery County	;ee greeolighted

applications for atieast ?0 rooftop wireless facilities at residential buildings that predicted levels
of exposure to radio frequency (RF) radiation that would exceed the limits set by the Federal
Communications Commission (FCC) for the general public In fact, the predicted or simulated
excesses for these applications ranged from just over the federal limits to as much as 114 times
the FCC limits.

Most of these multi-family homes provide relatively affordable shelter in our high priced County
and also disproportionately seive residents of color and immigrant communities. The high
predictions of RF radiation thus pose serious issues of euviionmental injustice, given how little
attention the County has paid to date to ensure that residents and workers at these locations are
not being illegally exposed to harmful levels of RF radiation that exceed federal limits.

All the applications were favorably recommended by the Tower Committee with no plan by any
agency in theCounty — not the Tower Committee, the Department of Permitting Services (DPS),
or the Department of Housing and Community Affairs (DHCA) — to ever inspect the sites to
make sure these buildings comply writh federal regulations governing RF emissions.

The FCC has provisions intended to assure that:

~	Hazardous rooftops are tightly restricted,

ซ Legally required warning signs are posted,

•	Any needed barriers are in place, and

ซ In general, residents and workers are not exposed to RF radiation over federal limits.

But the FCC has no program for verifying that prescribed safety measures are applied. All the
FCC requires to bring a wireless site into '"compliance'" is die proper placement of signs — in
English - and/or barriers around die antennas to warn the general public and workers not to get
too close. A ^barrier" could be a fence, a chain, a rope — or just painted stripes on the rooftop

All the County requires of the applicants is to promise to do those thing?. The County has no
inspection regime for wrireless safety at multi family buildings In fact, th e County has no
process for verifying the accuracy of the compliance reports related to their RF emissions that
applicants may (or may not) submit or, for that matter, the accuracy and completeness of
anteona inventories that applicants choose to use in preparing simulations Errors in applications
go undetected

Furthermore, any over-exposures in residents' actual living spaces — on balconies, at windows,
or inside apartment units — constitute violations of federal law. And yet no County agency has
any process to ever me a sure whether residents and workers at these multii-family
dwellings are being exposed to'harmful levels of RF radiatiion, in excess of federal limits!


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ZTA 19-07 iงpฉrts these orgeat problems, ami tie evidence they reveal of how extremely

inept the County's overall process is for reviewing fie safety of wireless facilities. Instead,
this ZTA would extend Ac risks of this broken process to affect all residents - in feci, adding
new risk to those already living under rooftop antennas. They could face antennas on poles
directly across from tick windows as well - someiaiig that is not currently allowed in the
residential zones where many of these multi-family dwellings are located.

•	By shrinking setbacks from homes. ZTA 19-07 imposes inequitable harms and n,ks on
oar most modestly-scaled residential neighborhoods.

Imposing a routine setback of 30 feel across all County residential and imal neighboilioods
sounds equitable. But a liitie critical thinking uncovers the systemic flaw in that assumption: A
cell tower that is 30 feet from a home on a small lot is likely to be far closer to the front porch
high-rise balcony, or iedroom windows of that dwelling than it is for homes sited much further
back on more spacious - tai often more expensive - properties That means, of cowrie, that the
constant new exposure to the health risks of RF radiation wmdd also be higher, as distance from
the antennas matters greatly.

Property mines are also mom Mfmly to go down disproportionately in modestly scaled
neighborhoods. The visual impact mi oilier aesthetic downsides of stects lined with cell toweis
- including tree pcuning and tec removals to clear "lime of stglif for 5G cellular transmission -
would also be more intense and unappealing for homes on small lots that are much closer to
right-of-way poles than for homes which set much further back from the road. More spacious
front yards w ould visually shield the latter from tic unattractive paraphernalia of wireless
facilities, including bulky equipment boxes at ground level or mounted on poles, mi from the
sad aftermath of butchered trees near the rights-of-way.

ii other words, residents who own or rent smaller properties, with homes closer to the rights-of-
way, will bear m unfair share of all the unpleasant consequences of ZTA 19-07 That will be Ac
case whether or not the household can afford - or desires - 5G serv ice from, the particular
telecom earner that has commandeered the use of the right-of-way in front of their home.

•	ZTA 19-07, contrary to the wireless industry's favorite talking	has nothing to do
with ending digital inequities in our County. That goal requires affordable, equitable
access to high-speed, secure, reliable, and safe Internet sen*#.

But the proposed zoning change includes not a single requirement or incentive for the wireless
industiy to expand such access to vulnerable households in the County who are currently
straggling, or unable, to afford or access such service.

In fact, the shift to 5G requires more expensive service and more expensive devices, which are
not likely to be as accessible to families of limited means as previous generations of cither wired
or wireless service. So no y, •/!! ... 1 !• f * ฆ {•;:* ;i d:, \ w

If the County is serious about that goal, it should scale up and fully fund, as the priority it

deserv es to be. a plan to extend the County's own internal FiberNet Internet service, free or at a
much reduced cost, to vulnerable households that find it difficult or impossible to afford fast.


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secure, reliable, and safe Internet service - which is wired Internet service - in any other way.
Ending inequities requires providing affordable, equitable access to fiber-optic connections to
the premises of all homes - including individual households in multi-unit dwellings. C ounty
efforts to increase access to digital literacy education are also important.

•	ZTA 19-07 reaffirms the horrific provision the County Council passed in 2018, allowing
cell t#wers just 10 feet -10 feet! — from multi-family residences in areas zoned for mixed
commercial and residential use. It does nothing to correct that inequity.

Environmental justice demands immediate action on the part of the County Council to fix. that
unfair exception. All residents - home renters and home owners, regardless of the zone they five
in - deserve far more protective setbacks than either that 2018 loophole or this radically bad
ZTA provide from lie health and safely hazards and other negative impacts that too-close cell
towers pose. (Note, however, that many, if not most, multi-family residences in the County ate
actually in the residential zones that would be affected by the added new injustices that ZTA 19-
07 would impose )

•	What ZTA 19-07 is really about is the County - under intense pressure from a powerful
industry - bending over backward to speed up that industry's roll out of a dens# network
of small cell towers in residential neighborhoods. And ioimg so bj eliminating meaningful
public participation in itcisteiis about siting and regulating them. That iฎซs not bode well
for vulnerable households.

If the history of rubberstampmg applications for cell towers in the County is any guide,
locations with hi Act ratios of Black and Brown residents, immjpanf fanmies, and residents
with limited means are likely to suffer the most from the lack of protections m tins ZTA for
public participation in decision-making.

Note, for example, that even for special, "conditional-use" permits. ZTA 19-07 requires prior
notification to families who awn homes, but not to fannies who rent homes near proposed cett
towers. And Acre is nothing in the ZTA requiring notifications in multiple languages. English
appears to be the assumed default. Such obvious inequities, which would be codified in the

(much reduced) notification provisions m this ZTA. are unacceptable.

The points explored above are by no means the kind of full, official analysis of the racial-
equity and social-justice impacts of ETA 19-07 that fit County Council should pursn#
before voting on this zoning change, However, the exploration here clearly indicates that
ZTA lt~ง7# if Sttfcjtcfei to such a full analysis, will earn a failing grade.

* A report from Tech Wise Mo C c MP
MซigiWKff Cotatty; MD.
tafi>@lechw]seflDMo>iadL<^


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FENCELINE
WATCH

lilt nr. ro 41

A HOUSTON BASED
ENVIRONMENTAL JUSTICE ORGANIZATION

Mx. Yvette Arellano
Executive Director,
Mr. Shiv Srivastava
Policy Research

Submitted electronically via:

wheiac(a\epa.gov subject: WHEJACMay 2022Meeting
WHEJAC comment submission form

Chair Brenda Mallory
Council on Environmental Quality
705 Jackson Place NW
Washington, DC 20503
Dock ID No.EPA-HQ-OA-2022-0050

Re: Comments on WHEJAC, Climate and Economic Justice Screening Tool, Docket No.EPA-HQ-
OA-2022-0050

My name is Yvette Arellano and I am the founder and director of Fenceline Watch, a Houston community
based environmental Justice effort dedicated to the eradication of toxic multigenerational harm on
communities living along the fenceline of industry. I am also a resident of an environmental justice
community in the East End of Houston. We appreciate the WHEJAC and EPA for extending the public
comment across multiple platforms.

After a review of the Climate and Economic Justice screening tool, we have identified critical issues around
user ease and understanding. I would first preface these issues by stating that I have been an avid user of
the EJSCREEN for over five years. As a participant in the EPA workshops and walk-throughs, I have been
a proponent of EPAs efforts supporting EJSCREEN in my community outreach. I welcomed another vital
EPA Climate and Economic Justice tool until I became overly frustrated at the lack of information and
muddled data delivery. My comment will touch on three critical issues with the CEJ beta project on barriers
for users of all expertise levels, linguistic isolation, and demographic, and the removing ambiguity in the
health burden factor.

I. BARRIERS TO USE OF CEJ SCREENING TOOL

Unlike EJSCREEN, users cannot download site-specific data points and add the rich layers to create a
complete picture. EJSCREEN provided a visual component filled with charts called the explore reports
function while also offering an in-depth report called the Printable Standard Report. Both types of reports
provided information in discernable forms for larger groups of community members. Additionally,
presenting data in percentiles without a visual component creates confusion about how a health factor
affects a community.1 In numerous reports, EPA itself has acknowledged the importance of

"Communicating with groups of individuals with varied levels of understanding and
different learning styles requires a diverse approach"2

1 https://archive.epa.gov/water/archive/web/html/vms62.html

2https://www.epa.gov/sites/default/files/2017-Ql/documents/tech memo 5 dec 30 2016.pdf

Fenceline Watch | Houston TX 77011 | Fencelinewatch.org

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F

WATCH J

M

ฃg

This tool only allows the downloading of data sources in massive packets requiring a community member
to open zip files. After exploring these massive files, it is clear that the target audience for the downloadable
information is not for community members and grassroots advocates like myself.

II. LINGUISTIC ISOLATION, HISTORIC ECONOMIC AND ENVIRONMENTAL
HARM & TRACKING PROGRESS

At Fenceline Watch, one of our pillars of work with our communities is language justice. Although we
appreciate EPA identifying linguistic isolation in census tracts, this does not go far enough. Unlike its
predecessor EJSCREEN the CEJ tool falls short in excluding ethnicity. The erasure of ethnicity ignores the
amount of time a community has been impacted by systemic and institutional discriminatory practices that
limit certain groups' economic mobility. Moreover, it limits the agency's ability to track the impact of
specific services in environmental justice communities of color.

III. NOT LEGACY CONTAMINATION BUT HEALTH BURDENS

Identifying RMP zones and Proximity to Hazardous Waste Facilities under the Legacy Pollution category
gives users a misrepresentation in whether the danger is current or past. Similarly, PM 2.5 in the Air is
under Clean Energy and Engery Efficiency without giving users a clear understanding of why. These factors
must be reclassified as Health Burdens to profile community issues. The Health Burden category also
requires a more robust data set that includes a community's low-birth-weights, uninsured rates and disabled
populations. These three additional health burdens are significant indicators of community health.

If the CEJ tool is targeted for specific audiences with an identified goal of resourcing communities, it
should be clearly stated. Otherwise, the EJSCREEN provides a wealth of information that EPA and
environmental justice efforts have poured time, resources and dedication to enriching. I appreciate the
extended opportunity to file comment with EPA and appreciate the efforts of all of those who are
advocating tirelessly to improve public resources to give us a better understanding of the conditions and
vulnerabilities our communities face.

Respectfully,

Yvette Arellano
Pronouns: They/Them

Executive Director. Fenceline Watch
Fencelinewatch@gmail. com

Fenceline Watch | Houston, TX 77011 | Fencelinewatch.org

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JUST SOLUTIONS

Collective

NPNA

NATIONAL PARTNERSHIP

FOB NEW AMERICANS

May 25, 2022

White House Environmental Justice Advisory Council (WHEJAC)

Docket Number EPA-HQ-OA-2022-0050

RE: Request for public comments relevant to federal disaster preparedness and relief and
community resilience

Dear WHEJAC members,

The Just Solutions Collective and the National Partnership for New Americans thank you for the
opportunity to submit this joint comment. We are submitting a letter to address WHEJAC's request for
public comments relevant to Federal disaster preparedness and relief and community resilience.

The Just Solutions Collective (JSC) works to broaden and deepen the understanding of equitable and
effective environmental and climate justice policies and projects to build the capacity of BIPOC and
frontline communities to replicate, scale, and build support for justice-centered solutions. JSC is
building a national disaster resilience policy and research program leveraging disaster expertise in our
staff and our partnerships with BIPOC Community-based organizations who have responded to
disasters and have dealt firsthand with the limits of federal disaster relief.

The National Partnership for New Americans (NPNA) is a network of 60 of the country's largest
statewide and regional organizations building power for immigrant communities. NPNA advances an
immigrant equity and inclusion agenda through policy, advocacy, and service programs that create vast
opportunities for immigrant and refugee communities to achieve full civic, social, and economic
justice. NPNA leads the new Climate Justice Collaborative, a project at the intersection of climate and
migration, to advocate for immigrant and refugee communities on the frontlines of climate change in
the U.S. and for the rights of climate-displaced people seeking safety in the U.S.

We are grateful for the work of members of the WHEJAC. Please let us know if we can provide any
additional information about our recommendations and comment below.

Sincerely,

Cristina Munoz De La Torre

Director of Programs Research
Just Solutions Collective

Ahmed Gaya and Stephanie Teatro

The Climate Justice Collaborative at the
National Partnership for New Americans


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The Just Solutions Collective and the National Partnership for New Americans submit the
following recommendations as public comment in response to the WHEJAC's questions:

•	What type of support is neededfor disadvantaged communities to participate in federal
disaster preparedness or relief programs?

•	How can federal disaster relief and aid programs better serve disadvantaged
communities that have historically receivedfewer federal benefits?

•	What process steps and information would help eliminate these disparities?

•	What steps can federal agencies and the White House take to reduce disparities in
climate change impacts for communities, including, but not limited to risks from, extreme
heat, flood, wildfire, drought, and coastal challenges?

Extensive research and reporting have been done on the deep disparities in federal disaster aid
programs, including FEMA's Individual Assistance program, the Hazard Mitigation Grant
Program, and HUD's Community-Development Block Grant for Disaster Recovery. As shown in
several case studies, low-income households. Black, Latinx, Indigenous, and communities of
color, renters, and elderly communities are less likely to receive adequate amounts of federal
disaster assistance despite having similar disaster damage as more affluent white
communities'These disparities exist for both individual recipients, whole communities, and
local government recipients, such as counties that have higher proportions of low-income and
communities of color. It clearly indicates systemic inequities that exist in federal programs,
especially along the lines of income and race.

As reported in the New York Times4, "[t]he impact from this disparity is long-lasting. White
people in counties with significant disaster damage that received FEMA help saw their personal
wealth jump years later while Black residents lost wealth, research published in 2018 shows."

The disparity in federal assistance is due to systemic inequities in its implementation, including
basing disaster assistance on property values, which are subject to the structural racism
embedded in real estate, federal programs not placing significant allocations for renters,
landlords being poorly incentivized to quickly repair properties and avoid rent spikes after a
disaster, and many other issues that are currently being investigated.

1	Domingue, S. J., & Emrich, C. T. (2019). Social Vulnerability and Procedural Equity: Exploring the Distribution
of Disaster Aid Across Counties in the United States. American Review of Public Administration, 49(8), 897-913.
doi: 10.1177/0275074019856122

2	Elliott, James R, Phylicia Lee Brown, and Kevin Loughran. "Racial Inequities in the Federal Buyout of Flood-
Prone Homes: A Nationwide Assessment of Environmental Adaptation." Socius: Sociological Research for a
Dynamic World 6 (2020): Socius : Sociological Research for a Dynamic World, 2020-02, Vol.6.

3	Munoz, C. E., & Fate, E. (2016). Unequal Recovery? Federal Resource Distribution after a Midwest Flood
Disaster. International journal of environmental research and public health, 13(5), 17.
doi:10.3390/ijerphl3050507https://www.nytimes.com/2021/06/07/climate/FEMA-race-climate.html

4	https://www.nytimes.com/2021/06/07/climate/FEMA-race-climate.html


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Centering equity in climate adaptation and addressing environmental injustice are essential for
reducing disparities of climate impacts. Disaster recovery efforts and investments in resilience
and hazard mitigation should not increase environmental injustice and should not lead to
displacement of low-income and communities of color.

Ensuring equitable outcomes in disaster recovery will require much deeper structural reforms
than increasing support and access. But in response to the questions posed by WHEJAC here we
offer our experience and findings on the barriers that B1POC communities and immigrant
communities in particular face in accessing disaster recovery programs.

These recommendations are written with an understanding that broader structural reforms are
required to address the deep inequities and outcomes in our nation's disaster recovery
programs.

Inequities in the structure of federal programs

The highly bureaucratic process of disaster declarations and disaster assistance distribution limits
the access to these resources for low-income and communities of color. We find there is a need
to coordinate efforts federally, to evaluate programs with regards to equity and accountability,
and to increase access to assistance through community-based efforts and organizations.

Implementation, Evaluation, and Accountability of Federal Programs

To ensure federal disaster recovery efforts do not exacerbate inequities, federal agencies should
conduct annual equity assessments of each of their programs and determine progress on specific
equitable outcomes. In addition, there should be a measure indicating the extent to which federal
agencies incorporate recommendations from community-based advisory councils. The
implementation of all equity plans, assessments, and evaluations should be sufficiently
resourced, transparent, and take into account community input.

For example, FEMA recently released an Equity Action Plan, where it recognizes its need to
"build more equitable outcomes, reduce administrative burdens, increase eligibility for
underserved and vulnerable applicants, increase access, and improve external messaging5".
However, neither the equity plan or FEMA's Strategic Plan defined specific equitable outcomes.
The Equity Plan and Strategic Plan lacked many of the recommendations included in FEMA's
National Advisory Council (NAC) 2020 report6, including the recommendation that FEMA
should define equity to mean "providing] the greatest support to those with greatest need to
achieve a certain minimum outcome. It is separate from equality, which is providing the same
resources to everyone regardless of need." Overall, the Equity Action Plan and the Strategic Plan

5	https://assets.performance.gov/cx/equity-action-
plans/2022/EO%2013985_FEMA_Equity%20Action%20Plan_2022.pdf

6	https://www.fema.gov/sites/default/files/documents/fema_nac-report_ll-2020.pdf


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seem to be less robust than the NAC 2020 report specifically around equity. Advisory councils
can only provide advice and their recommendations are not mandated. However, the extent to
which these agencies accept and implement advisory recommendations into their programs
should be measured as part of agency and program evaluations. Further, it should be
standardized that agencies provide an explanation for each recommendation that is not accepted
or modified.

Targeted Outreach and Support Program to Streamline Applications

Federal agencies such as FEMA and HUD should establish interagency, targeted programs
specifically aimed to help the most disadvantaged communities gain access to their disaster
relief programs and streamline the application processes.

Eligibility assessments for all federal disaster relief programs, within and across federal
agencies, should be streamlined into a single intake process, helping applicants to understand
the variety of recovery programs they are eligible for. This would reduce the application
burden, miscommunication, and prolonged wait times for application results. Outside of
eligibility for federal programs, this intake process could also be a hub for referrals to other
local service providers for any other needs such as food, clothes, childcare, etc.

These programs would be most effective with dedicated staffing and sufficient resources; by
centering equity, cultural competency, and diversity; and by maintaining strong partnerships
with other federal agencies and community-based organizations and service providers.

We acknowledge this recommendation is aligned with components of the Biden
Administration's executive order, Putting the Public First: Improving Customer Experience
and Service Delivery for the American People, and urge its implementation.

Federal investment in Community-Based Organizations

The disaster declaration process and the distribution of federal assistance is highly bureaucratic.
Disaster relief works through systems that are inaccessible and marginalizing to low-income and
communities of color. In addition, low-income and communities of color lack relationships,
access, and trust with federal and state level agencies and offices. These result in inaccessible
systems of disaster relief.

On the other hand, BIPOC frontline communities have deep and more trusted relationships with
community-based organizations, especially BIPOC-led organizations7. These relationships have
been built and nurtured through providing essential social services and community-building
spaces long before disaster strikes. These organizations are often among the first responders in

7 https://www.justsolutionscollective.org/blog-posts/the-unique-role-of-bipoc-frontline-environmental-justice-cbos-
in-disaster-resilience


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the wake of a disaster because of their deep roots in a community and existing service
infrastructure.

Often these organizations are responding without dedicated staffing or funding, but quickly
stand-up services to respond to the most urgent needs of their constituents. With more capacity
and dedicated resources from federal agencies (including funding, training, and technical
assistance), and if given authority to act as direct intermediaries between disadvantaged
communities and state and federal relief programs, the organizations' services could be scaled
and leveraged to dramatically increase access and participation in federal disaster relief programs
for low-income and BIPOC communities.

These organizations can play an essential role in increasing access to federal disaster relief for
disadvantaged communities across a variety of functions, including community outreach and
education and direct application assistance. Many organizations also have physical spaces, that
are familiar and comfortable to community members, that can be used as a site to distribute or
coordinate federal recovery programs. The model of Resilience Hubs developed by the Asian
Pacific Environmental Network in California are a model that could be resourced and replicated
across the country.

Federal disaster relief programs and the agencies should directly build relationships with BIPOC
and frontline CBO and intermediaries before a disaster to learn more about vulnerable
communities, build their capacity, and provide technical assistance to identify and deliver
disaster relief to most disadvantaged communities.

Addressing disparities at the individual and community level

Low-income households, communities of color, the elderly, people with disabilities, renters,
and rural communities often do not receive equitable amounts of federal disaster assistance,
accounting for disaster damage and other related impacts. Immigrant communities, especially
undocumented immigrants, and individuals with Limited English Proficiency, also face
unique and compounding barriers and are often left behind in response and recovery.

Language Access

Across every stage of disaster preparedness, rapid response, and recovery, there should be
robust language access plans to ensure that individuals with Limited English Proficiency are
safe and have access to emergency services and recovery programs. Federal agencies should
work with state and local governments and community partners to ensure that all services and
information are provided in the languages most commonly spoken in that area.


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There is also a need for significant investment in culturally competent community education,
including through trusted messengers, and that it is communicated and advertised in channels
that will reach disadvantaged populations and non-native English speakers.

Federal responders delivering services to LEP communities should either use qualified
interpreters or work with local CBOs and agencies with appropriate language competency.
Language access mandates should be accompanied by an allocation of sufficient resources to
carry them out, including funding for CBOs who support federal, state, and local governments
with language access.

Immigration Status Barriers

There are an estimated 11 million undocumented immigrants living in the United States.

There are large populations of undocumented community members in states that frequently
experience disasters, including nearly three million residents of California, nearly 800,000
residents of Florida, and nearly two million residents of Texas8.

All disaster recovery benefits should be made available to all members of a community that
are impacted by a disaster, regardless of immigration status. Currently, undocumented people
and some other non-citizens are ineligible for many essential federal disaster recovery
benefits and programs.

Due to confusion about status requirements, many non-citizens and mixed-status households
may not apply for the benefits that they are eligible for. Even when individuals or households
understand their eligibility, they may choose not to apply based on fears of immigration or
other financial consequences. For example, how receiving benefits may impact the credit
score of the applicant, whether a U.S. citizen minor who applies on behalf of the household
would be able to serve as a sponsor for their family members residency applications in the
future, the likelihood of triggering the public charge rule, and other immigration
consequences. These concerns should also be explicitly addressed in application forms and
websites and through targeted communication.

Use of Immigration Enforcement & Military Personnel

Undocumented immigrants and mixed-status families often avoid encounters with
government agencies, out of fear that the interaction may result in detention or deportation. In
the context of disasters, these fears will lead many to refuse to seek help, safety, or relief.
Strengthening and expanding policies to prohibit immigration enforcement activities in
disaster zones, including but not limited to CBP and ICE's protected areas policy, - protecting
disaster victims, first responders, recovery workers, and volunteers - are essential to
increasing equitable recovery from disasters. Similar to eligibility requirements, these

8 Population estimates from the Migration Policy Institute: migrationpolicy.org/programs/us-immigration-policy-
program-data-hub/unauthorized-immigrant-population-profiles


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prohibitions must be communicated broadly through trusted messengers before, during, and
after disasters.

Even if they are performing disaster response duties and not enforcement operations, the
presence of uniformed law enforcement, ICE, CBP, and military personnel for disaster relief
can heighten trauma and increase mistrust for many individuals recovering from a disaster.
For many immigrant communities, seeing uniformed ICE And CBP agents as first responders
in a disaster will deter people from seeking critical emergency services and recovery support.

Increased Relief and Recovery Dollars for Renters and Multi-Family Homes

Disaster recovery and relief programs should be updated to reflect the realities and diversity
of American households, including increasing the amount of assistance that is available to
occupants of damaged properties.

Many low-income communities, immigrants, and communities of color are renters and not the
owners of affected properties. Renters should be given sufficient resources to recover from a
disaster, even if the owner/landlord is given separate resources to repair the property. Policies
to prevent rent spikes and renter displacements after disasters should also be expanded and
strengthened. In addition, assistance amounts should account for multi-generational & multi-
family unit households. Application and assessment systems that are based on a model of
traditional, single-family-occupied homes do not provide sufficient or equitable support and
relief to many communities.


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HAVASUPA! TRIBAL COUNCIL

3SI -440-2731 * F

1

March 25, 2022

Secretary Jennifer M. Granholm
U.S. Department of Energy
1000 Independence Ave, SW
Washington DC 20585

Sent via Email: the secretary@hq.doe. gov

Subject: Uranium Mining Concern
Dear Secretary Granholm,

The Havsuw Baaja. the People of the Blue-Green Water (Havasupat Tribe) is
writing to you again to express the concern about the U.S. Department of Energy's
consideration of a uranium reserve. We previously submitted a letter to you on October
4, 2021 in response to the RFI. We are deeply concerned with ongoing discussions taking
place to increase uranium mining in the United States due to Russia's invasion of Ukraine.
White we understand the United States' position on potentially banning uranium imports
from Russia, we cannot stress enough that any uranium mining at the Piriyon Plain Mine
(formerly known as the Canyon Mine) located on federal lands near our reservation will
have devastating effects for our Tribe. A horrible war across the world should not be
grounds for harming the Havasupai Tribe, its members, and other Indigenous
communities located here in the United States.

Energy Fuels. Inc. currently operates the Pinyon Piain Mine (Canyon Mine) next
to our reservation and on our aboriginal lands and traditional cultural property - Red Butte.
This mine has a history of problems, including that it pierced a major aquifer digging what
if claimed would be a dry mineshafi and then sprays the now-contaminated water into
the national forest. This mine should riot be eligible for participation in any federal program
or to receive funding to operate, Allowing the Pinyon Plain Mine (Canyon Mine) to
participate in a U.S. uranium mine reserve program under your Department will
essentially shift the sacrifice of lives in the war torn Ukraine for lives of the Havasupai
tribal members. This is how serious we see this issue. President Biden ran for office
pledging to protect tribal communities and restore tribal sovereignty. We need you to
support his pledge to us and not allow the Pinyon Plain Mine (Canyon Mine) to participate
under any federal uranium program. Doing so would cut directly against President Biden s
pledge and promises.


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Letter to Secretary J, Granholm
Re; Uranium Mining Concern
March 2,5, 2022
Page 2

Further, the United States has a duty under its trust responsibility to protect the
Havasupai Tribe. We live in the year 2022, and the voice of our people should not go
unheard. Our Tribe, our members, our land, our water should not be sacrificed when this
vast country has other uranium deposits located in areas where mining does not pose a
serious threat to the human element.

While we appreciate prior statements from the Department of Energy that there is
no intention to initiate or expand mining "on Tribal lands, expand the Office of Legacy
Management's (LM) Uranium Leasing Program, or expand access to additional uranium
deposits located on other Federal lands," the Department misses a key understanding of
the true issues involved. Most of the potential damage to tribal interests occurs from
activities on aboriginal territories, sacred sites, and lands adjacent to tribal lands, not "on
tribal lands" itself. This is where the federal trust responsibility should be at its strongest
point. Indian tribes, like the Havasupai Tribe, rely on the federal government to protect
its people from the harmful effects of uranium mining. It should not matter where the
mining occurs.

We have lived in our homeland, deep in the Grand Canyon, for thousands of years
and the single largest threat to our survival over these thousands of years has been the
uranium industry. Mining for uranium not only harms the surface environment but also
contaminates our groundwater resources. Our Tribe's sole source of water comes from
the very aquifers that sit directly below the Pinyon Plain Mine (Canyon Mine) on our
aboriginal lands. If you permit the Pinyon Plain Mine (Canyon Mine) to supply uranium
under any federal uranium reserve program then our water aquifers that supply our
drinking water and life in the canyon will be contaminated and our existence as a Tribe,
as we have known it since time immemorial, will die; not to mention one of the seven
natural wonders of the world will be contaminated along with the Colorado River. Why
put all of this at risk?

We urgently ask the Department of Energy to uphold President Biden's pledge and
promise to protect the Havasupai Tribe and restore tribal sovereignty. We need you and
others to hear our voices. We ask that you withhold participation of the Pinyon Plain Mine
(Canyon Mine) in any federal uranium program or funding to operate. Not doing so, will
place our existence as a Tribe in harm's way,

Sincerely,

Thomas Siyifp

Chairman, Havasupai Tribe

Cc: Havasupai Tribal Council

2


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Letter to Secretary J. Granholm
Re: Uranium Mining Concern
March 25, 2022
Page 3

Denten Robinson, Havasupai General Counsel

Mark Kelly, U S Senator

Kyrsten Sinema, U.S. Senator

Joe Manchm. U.S. Senator

Raul Grijalva. U.S. Representative

Tom O'Halleran, U.S. Representative

Deb Haaland, Secretary of Interior, Department of Interior

Bryan Newland. Assistant Secretary, Indian Affairs

Brenda Mallory, Chair of White House Council on Environmental Quality

Gina McCarthy, National Climate Advisor

Michael S, Regan, EPA Administrator

Cecilia Martinez, PhD, Senior Director for Environmental Justice, CEQ
Corey Solow. Deputy Director for Environmental Justice, CEQ
White House Environmental Justice Interagency Council
Members of the White House Environmental Justice Advisory Council

3


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N/it;on/ AsMHialion of v'onson * Oistncfv

May 25th, 2022

Dear White House Environmental Justice Advisory Council,

Re: EPA-HQ-OA-2022-0050

The National Association of Conservation Districts (NACD) represents America's nearly 3,000
locally-led conservation districts, working with millions of landowners and operators to help
them manage and conserve land and water resources on private and public lands. Established
under state law, conservation districts share a single mission: to work cooperatively with federal,
state, and local resource and land management agencies, and private sector interest groups to
provide technical, financial, and other assistance to help landowners and operators apply
conservation to the landscape. Because conservation districts were created to be the link between
the federal government's various natural resource agencies and local communities across the
country, conservation districts work hand-in-hand with all levels of government to ensure that
local resource needs help inform major decisions.

Executive Order 14008 Tackling the Climate Crisis at Home and Abroad, Sec. 223 - Justice40
initiative established the goal of directing 40 percent of certain Federal investments to benefit
disadvantaged communities. Executive Order 14008 also established the White House
Environmental Justice Advisory Council (WHEJAC) to offer recommendations to the Chair of the
Council on Environmental Quality (CEQ) and the White House Environmental Justice Interagency
Council (IAC). The WHEJAC advises on how the federal government can increase its support of
disadvantaged communities in the areas of resilience, disaster management, conservation, clean
water infrastructure and beyond.

On April 13, 2022, the WHEJAC published its intent to hold a public meeting to discuss climate
resilience and consider recommendations to better serve disadvantaged communities through
federal disaster relief funding. For more than 75 years, conservation districts have served as leaders
in locally-led efforts to conserve our nation's natural resources and address local natural resource
needs in the face of natural disasters and extreme weather by working with private landowners and
other members of the community.

Understanding Local Resource Needs

NACD supports tailored technical assistance to best fit the unique needs of different
communities across the country. Grassroots efforts to engage local community members and
leaders is necessary to understand how communities may have been excluded from past funding
opportunities and what barriers still exist in that community to access existing programs. Many
communities across the United States and its territories are impacted by low-income levels, high
unemployment rates, and limited access to state or federal resources. These obstacles, as well as


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N/it;on/ AsMHialion of v'onson * Oistncfv

other historical barriers, put communities at a disadvantage, and can result in excluding them
from participating in programs. For the purposes of cost-sharing requirements, some federal
programs have specific parameters to determine if a community is considered to be a
disadvantaged community or Limited Resource Area (LRA). To determine the amount of
support required for disadvantaged communities to participate in federal programs, and to
ascertain how those programs can better serve those communities, outreach and capacity
building must be done at the local level. Program parameters and eligibility flexibility is also key
to ensuring that local needs can be addressed across unique circumstances. Providing flexibility
within program requirements is key to helping each community address their unique
environmental concerns.

In addition to recognizing the varying needs of each community, it is also important to consider
the barriers that exist for individuals to access these programs, as opposed to larger groups or
local governments. Community organizations and governments often do not have the time nor
resources necessary to focus on all individual needs. To address this issue, it is important that
that community-based organizations, such as conservation districts, are provided the tools and
resources necessary to build the capacity needed to meaningfully participate in these programs.
Whether individuals lack financial resources, training, or land, it is critical to consider the needs
of all stakeholders in order to support the entire community.

Disaster preparedness planning should include the input from all community stakeholders. It is
imperative that all stakeholders have a seat at the table when establishing plans for community
preparedness to properly account for all available resources in the community, and to avoid
excluding groups from project eligibility or future funding opportunities. It is also critical to
ensure that a diverse set of stakeholders from across the community are included in discussions
to develop program parameters and funding eligibility requirements.

Programmatic Barriers

The United States Department of Agriculture (USDA) Natural Resource Conservation Service's
(NRCS) Emergency Watershed Protection Program works to protect vulnerable infrastructure
and land from future flood and soil erosion damage and does not require a disaster declaration
from federal or state government officials. Through this program, NRCS provides financial and
technical assistance for activities such as debris removal and streambank repair.

Rigid project requirements and a lack of resources or funding to meet sponsor requirements can
act as barriers to EWPP participation. Increasing the flexibility of project and sponsor
requirements could serve to bolster participation and increase access to project benefits for many
LRAs. Under current program requirements, sponsors are required to support maintenance and
provide match requirements, which is difficult for many sponsors. For communities that have
been designated as LRAs, NRCS covers 90 percent of construction costs. However, this support
does not cover expenses to submit the application nor maintenance costs after the conclusion of


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N/it;on/ AsMHialion of v'onson * Oistncfv

the project. More extensive support is required for many LRAs take advantage of EWPP
benefits.

Program eligibility requirements also restrict participation under the property requirement by
limiting the participation of some rural areas due to lower concentrations of man-made
structures. Despite the damage that weather events may inflict on other structures in the area,
protection cannot be supported under current EWPP eligibility requirements. Providing
additional flexibility for projects would help to protect more watersheds from severe damage.

The Watershed Rehabilitation Program (REHAB) supports public health and addresses safety
concerns by providing assistance to sponsors to rehabilitate aging dams that are past their
designed lifespans. This program also has several barriers that reduce participation, notably
among LRAs and other historically underserved communities. Some areas with low incomes,
housing values, or high unemployment may not have received funding or resources needed to
build eligible watershed infrastructure in the first place. It is important to consider the kinds of
communities these projects support explore opportunities for the program to better support
disadvantaged communities.

The Federal Emergency Management Agency's (FEMA) Building Resilient Infrastructure
and Communities (BRIC) Program offers support for communities to mitigate hazards and
reduce the risks posed by natural disasters. Participants of these programs often experience
similar barriers to program access across several different kinds of disasters, including floods and
wildfires.

Lack of coordination between all stakeholders during the planning stages of BRIC reduces
overall participation in the program. Expanding coordination within the community and across
all levels of government can increase the number of stakeholders participating in hazard
mitigation planning and ultimately bolster the implementation of mitigation activities. Disjointed
coordination among relevant entities restricts eligibility for local stakeholders who may lack
capacity or training to support these activities independently, but who offer valuable
contributions to the process at large. In addition to expanding coordination between these groups,
it may also be useful to develop a disaster plan template or program to help stakeholders develop
the expertise required to implement plans independently. Groups that would traditionally lack
adequate staffing or training to develop a plan on their own would then be able to develop a
template to address resource concerns in their area.

The U.S. Forest Service's Good Neighbor Authority (GNA) and other federal programs that
address forestry and wildfire related natural disasters can raise barriers stemming from a lack of
coordination. The GNA is an important program that allows non-federal stakeholders and
partners, such as conservation districts, to conduct forest management and clearing on federal
lands. Partners participating in this program can experience low demand for harvested products
and insufficient training opportunities for natural resource and forest management professionals.
The lack of adequate staffing, training, and demand for forest products requires partners to
individually source markets for harvested products and train their own staffs. This places lower-


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N/it;on/ AsMHialion of v'onson * Oistncfv

income communities at a disadvantage, as they do not have the capacity or financial resources to
consistently support these efforts. Large-scale disasters often involve a large influx of
management workers, which are difficult to manage without strong structures and plans in place.
Additionally, communities with fewer financial resources may be less likely to participate in this
program due to the limited availability of timber sales for future GNA activities.

USDA's Forest Service's Community Wildfire Defense Grants present a great opportunity to
help vulnerable and low-income communities across the country mitigate the many risks posed
by wildfires. This program provides funding to communities at high risk of wildfire to develop
and begin the implementation of wildfire plans. The testing of prescribed practices is an
important part of verifying program effectiveness and ensuring community preparedness, but it
can also act as a barrier to community participation. Some communities do not have adequate
resources or funding to carry out testing effectively and may need additional support. While
testing exercises are critical, lower-income communities may see this as a barrier to
participation.

The USD A' Forest Service supports urban forestry through their Urban and Community
Forestry Program, which provides funding to state agencies to implement projects, sometimes
with the help of local partners. To be eligible for funding, states must have a full-time
coordinator, provide technical assistance to communities, convene a Community Forestry
Council, and create a strategic plan to guide their work. State agencies and their partners should
be encouraged to engage with local stakeholders during this process. Activities supported by this
program may include landscape scale restoration, invasive species work, education, and
outreach. Efforts to support urban forestry can also play a significant role in mitigating the
effects of disasters and extreme weather, such as through canopy cover to prevent extreme heat.
To fully harness the potential of urban forestry to combat extreme heat, it should considered in
the strategic planning stages at the state and local levels. Underserved areas have a lower
percentage of urban canopy cover, which makes their residents more susceptible to health issues
caused by extreme heat. Promoting urban forestry practices in underserved areas can provide
substantial environmental and health benefits to those communities.

Conclusion

In conclusion, there are several areas where barriers repeatedly appear and can impact a
sponsoring entity's ability to contribute financially or meet other programmatic requirements.
The first area in which overall more focus and support is needed is in staffing capacity and
training. Many of these programs include complex application processes and the implementation
of funding often requires specialized experience that may not be present in all sponsor offices.
More support from the funding agency is needed to support these sponsors by providing training
and guidance throughout the application and implementation process. Accessing the resources
for these programs often requires substantial dedication of staff time and an understanding of the
complicated application systems. Information and program resources should be accessible to


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N/it;on/ AsMHialion of v'onson * Oistncfv

easily understood by stakeholders from all backgrounds. Historically, long and difficult
application forms and convoluted communications have discouraged communities that do not
have adequate staff and resources from applying for federal disaster assistance programs.
Expanding outreach, education, resources could encourage consistency among regions and make
it easier to address common issues. Additionally, more focus in needed to support the training
and hiring of a diverse workforce. It is important to emphasize recruiting a diverse and skilled
workforce to ensure natural resource management professions are accessible by all communities
across the country. Capacity issues also continue to be a concern. Sponsors may not have the
resources to dedicate staff to completing program applications or to continue maintenance of
projects after completion. We must ensure that all communities, regardless of their
socioeconomic standing, have the ability to participate in these important programs.

Due to the broad impact of natural disasters such as floods, wildfire, extreme heat and coastal
challenges, actions to decrease disparities cannot be done on a community-by-community basis.
These impacts are rarely limited to a single community and it is important that federal programs
provide equitable access and support to protect against and prepare for natural disasters.
Addressing climate resilience and preparing communities for natural disasters starts at the local
level. It is critical that both communities and individuals are provided with equitable
opportunities to benefit from federal programs. If individuals across a community are supported
and provided with the opportunity to participate in federal programs, the community as a whole
will benefit.

Thank you for the opportunity to participate in this process and submit comments on federal
support to underserved communities through programs on disaster preparedness and community
resilience. We appreciate your consideration and look forward to continuing to work with you to
strengthen federal programs.

Sincerely,

Michael Crowder
President

National Association of Conservation Districts


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NRDC

May 2, 2021
Via Electronic Mail

Ms. Lee Ann Veal, Director
U.S. Environmental Protection Agency
Radiation Protection Division
1200 Pennsylvania Avenue, N.W.

Washington, DC 20460
Veal.Lee@epa.gov

RE: NRDC, et al., Next Request to EPA to Recommence and Finalize In Situ Leach
Uranium Rulemaking.

Dear Director Veal:

Over a year ago the Natural Resources Defense Council (NRDC), the New Mexico
Environmental Law Center, Earth Works, Powder River Basin Resource Council, Earthjustice,
Southwest Research & Information Center, Concerned Citizens for Nuclear Safety, the
Multicultural Alliance for a Safe Environment and the Grand Canyon Trust wrote to you in
hopes that the Biden Administration U.S. Environmental Protection Agency (EPA) would move
forward on the long delayed revisions for 40 C.F.R. ง 192, the overdue first set of meaningful
environmental protections for the in situ leach (ISL) uranium recovery industry.1 As of this date,
EPA has yet to re-issue a new proposed set of standards and time grows short and pressures
mount. We urge the agency to reissue a strong set of draft uranium recovery standards for public
comment as soon as possible.

As a first matter and putting it directly at the front so there can be no mistaking or
mischaracterizing this letter - the undersigned, each and every one, entirely concur with the
policy position that the United States should explicitly ban imports of uranium from the Russian
Republic. The dreadful military assault on Ukraine and its people outstrips every consideration
and we stand with the civilized world in making every effort to restrict every possible form of
commerce in the hopes of ending this war as soon as possible. Further, we have every
expectation that the uranium supply from the Russian Republic will not be used in our domestic
market for years, potentially decades, and even though it provides only 16 percent of that market,
proper planning should inform how we address this small gap in supply.

Unfortunately, rather than undertaking careful analysis to address an incremental supply
issue, industry champions that have worked for years to restrict EPA's efforts at new uranium

1 See 40 CFR Part 192: Proposed Rulemaking and Background Documents, found online at

https://www.epa.gov/radiation/40-cfr-part-192-proposed-Riiemaking-and-backgroniid-docnments.


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NRDC el al., Letter to Director Veal

Request to Re-propose ISL Uranium Rule, Docket #EPA-HQ-2012-0788-0001
May 2, 2022
Page 2 of 5

protections are attempting to force the Department of Energy (DOE) to move forward with an ill
thought out strategic uranium reserve under the guise of limiting Russian and Chinese uranium
imports.2

Again, banning Russian uranium imports is the right thing to do. But EPA's role in this
profound moment is also clear, especially if it's the case that some measure of the domestic
uranium recovery industry may be artificially revived, whether it comes in the form of a uranium
reserve or direct subsidies for purchase of domestic uranium.3 Any ban on Russian uranium must
be accompanied by EPA finally moving forward on environmental standards that ensure U.S.
uranium mining projects don't foul precious underground aquifers and water supplies or sicken
and kill wildlife. It's long past time for EPA to issue the uranium mining standards that were put
on hold in 2018.4 We are well into the second year of a Biden Administration and yet EPA still
provides no public timeline on when it might conclude its review and take action.

The current situation places in even more stark relief the need for EPA to act. Years ago
EPA addressed why, especially with the onset of artificially spurred domestic recovery, leaving
the current situation in place is untenable:

Groundwater is one of our nation's most precious resources ... Groundwater is
also a valuable and dwindling resource, particularly in western states where most
ISR activities are anticipated. EPA views protecting groundwater as a
fundamental part of its mission. Particularly in cases where groundwater is
directly threatened by an activity, as it is by the ISR technology, EPA believes it
has a special duty to ensure that the authority of all applicable federal statutes
(e.g., UMTRCA and the SDWA) are used to help protect the groundwater and
that appropriate standards to protect public health, safety and the environment are
developed and implemented.

Proposed Rule at 4171.

2	See Senator Cramer's National Opportunity to Restore Uranium Supply Services In America (NO RUSSIA) Act of

2022, https://www.cramer.senate.gov/news/press-releases/sen-cramer-coHeagiies-introdnce-legislation-to-establish-
strategic-uranium-reserve-increase-domestic-production. (Also, China supplies a de minimis percentage to the US
market, so we are unsure of the basis for its inclusion in the proposal).

3	See the recently introduced legislation from Senators Manchin and Risch, International Nuclear Energy Act of

2022, littps://www.energy.senate.gov/2022/4/manehin-riseh-introdnee-the-inteniational-nnetear-energy-act-off-
2022#:~:text=The%20International%20Nuclear%20Energy%20Act%20wouM%20provide%20the%20necessary%2
Ore sources. nuclear%20plants%20across%20the%20globe.

4	Specifically, we reference 40 C.F.R. ง 192, 80 Fed. Reg. 4156-4187 (Jan. 26, 2015) (EPA-HQ- OAR-2012-0788)
("first draft rule"). That rule would have been finalized by the end of the Obama Administration, but as it was likely
to be the subject of attack under the Congressional Review Act, the EPA wisely took another course to preserve its
future options - at the close of the Obama Administration, the EPA re-proposed an updated set of revisions at 82
Fed. Reg. 7400-7430 (Jan. 19, 2017) ("second draft rule") (together "proposed rules"). The Trump Administration
subsequently withdrew any effort to provide any protections and shelved the rule. 83 Fed. Reg. 54,543 (Oct. 30,
2018).


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NRDC el al., Letter to Director Veal

Request to Re-propose ISL Uranium Rule, Docket #EPA-HQ-2012-0788-0001
May 2, 2022
Page 3 of 5

Continued delay in re-issuing and implementing the Proposed Rule is particularly
concerning because of the environmental justice implications that ISL mining raises. The
majority of ISL mining occurs or is proposed in low-income communities and communities of
color, particularly Native communities. The health effects and natural resource destruction from
historic uranium development already overburden these communities. Further delay in
implementing the Proposed Rule would be antithetical to the Administration's stated
commitment to environmental justice and equity. Additionally, we are aware of several
expressions of concern from indigenous and vulnerable communities across the West about new
uranium recovery and potential reserves that have been directed to several different parts of the
administration.5 We remind EPA that all methods of uranium recovery carry with them a
disproportionate and contaminating burden. Moving forward with all speed on the long awaited
ISL uranium rule is only one important step. Simply, any creation of a uranium reserve or
marked increase in direct subsidies to the industry in order to artificially ramp up the domestic
market will dramatically affect scarce sources of western groundwater and associated vulnerable
communities, endangers over the long term iconic western landscapes, and further creates a host
of potential security concerns.

And so, we again request another meeting with you, Director Veal, and also Deputy
Administrator McCabe, as she was the relevant Assistant Administrator during the final months
of President Obama's tenure and it was under her authority that EPA sought to finalize the
carefully crafted and protective standards we seek. If it would substantially delay any
opportunity for a meeting, then we are happy to schedule separately and at a slightly later date
with the Deputy Administrator. In either case, we request EPA provide precise answers on the
timing for the agency's review of necessary steps on this overdue rule. Specifically, when will
the agency conclude its review and on what timeline is the agency attempting to finalize the rule?
And if it is not taking these steps and is not able to present its timeline, we'd like to understand
the Biden EPA's policy basis for such a drastic departure from the positions held prior to the
Administration of former President Trump.

We look forward to hearing from you.

Sincerely,

/s/(electronic signature)	

Geoffrey H. Fettus
Senior Attorney

Natural Resources Defense Council

/s/(electronic signature)	

Eric Jantz
Staff Attorney

New Mexico Environmental Law Center
1405 Luisa St., STE 5
Santa Fe, NM 87505
Ph: 505-989-9022 x 120

ei antz@nmelc.org

1152 15th St. NW, #300
Washington, D.C. 20005
(202) 271-4037
gfettus@nrdc. org

5 See, as one example, the attached April 29, 2022 letter from Eastern Navajo Dine' Against Uranium Mining to
Energy Secretary Granholm.


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NRDC el al., Letter to Director Veal

Request to Re-propose ISL Uranium Rule, Docket #EPA-HQ-2012-0788-0001
May 2, 2022
Page 4 of 5

/s/(electronic signature)

Aaron Mintzes
Senior Policy Counsel
Earthworks

1612 K St. NW, Suite 904
Washington, DC 20006
919-302-6393 (cell)

amintzes@earthworks.org

/s/(electronic signature)

Shannon Anderson
Attorney

Powder River Basin Resource Council
934 N. Main St., Sheridan, WY 82801
307-672-5809

sanderson@powdeiTiverbasin.ore

/s/(electronic signature)

/s/(electronic signature)

Blaine Miller-McFeeley

Senior Legislative Representative

Earthjustice

1001 G Street NW, Suite 1000
Washington, DC 20001
(202) 745-5225

bmcfeelev@earthiustice.org

Chris Shuey, MPH

Director, Uranium Impact Assessment
Program

Southwest Research and Information Center

P.O. Box 4524

Albuquerque, NM 87196

office 505-262-1862

cell 505-350-0833

sric.chris@gmail.com

/s/(electronic signature)

Amber Reimondo

Energy Director

Grand Canyon Trust

4401 Alcott St.

Denver, CO 80211

(303) 477-1486

apaul@grandcanyontrust.org

/s/(electronic signature)

Joni Arends
Executive Director

Concerned Citizens for Nuclear Safety
P. O. Box 31147
Santa Fe, NM 87594-1147
505 986-1973

/s/(electronic signature)	

Susan Gordon
Coordinator

Multicultural Alliance For A Safe

Environment

P.O. Box 4524

Albuquerque, NM 87196

505-577-8438

sgordon@swuraniumimpacts.ore

/s/(electronic signature)	

Lilias Jarding, Ph.D.

Executive Director

Black Hills Clean Water Alliance

P.O. Box 591

Rapid City, SD 57709

605-787-2872

nobhuranium@gmail. com


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NRDC el al., Letter to Director Veal

Request to Re-propose ISL Uranium Rule, Docket #EPA-HQ-2012-0788-0001
May 2, 2022
Page 5 of 5

CC: Janet McCabe, Deputy Administrator; Dan Utech, Chief of Staff; Alison Cassady, Deputy
Chief of Staff for Policy; Jonathan Edwards, Director, Office of Radiation & Indoor Air;
Matthew Tejada, Office of Environmental Justice


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Secretary Jennifer M. Granholm

U.S. Department of Energy

1000 Independence Ave. SW

Washington DC 20585

Sent via Email: the.secretary@hq.doe.gov

April 29, 2022

Subject: Uranium Mining Concern
Dear Secretary Granholm:

Eastern Navajo Dine Against Uranium Mining (ENDAUM) is writing to express concern about
the U.S. Department of Energy's consideration of a "strategic uranium reserve." ENDAUM was
formed in 1994 in response to a proposed in situ leach (ISL) uranium mining project in the Dine
(Navajo) towns of Crownpoint and Churchrock, New Mexico. The proposed ISL project, called
the Crownpoint Uranium Project (CUP), targets uranium ore bodies in important underground
sources of drinking water for our towns and if begun, would destroy the sole source of drinking
water for the town of Crownpoint.

As a member of the Multicultural Alliance for a Safe Environment, we previously submitted
comments to you on October 13, 2021 in response to the RFI. We are deeply concerned with
ongoing discussions taking place to increase uranium mining in the United States due to Russia's
invasion of Ukraine. While we understand the United States' position on potentially banning
uranium imports from Russia, we cannot stress enough that any corporate subsidies that prop up
the domestic uranium mining industry will have significant, long term and devastating effects on
our communities and Indigenous communities across the country. A horrible war in Europe
should not be used as an excuse to harm our communities, other Dine communities under threat
of new uranium development, and other Indigenous communities located here in the United
States.

The Crownpoint Uranium Project is currently owned by a Canadian mining company Laramide
Resources, through its U.S. subsidiary NuFuels, Inc. While part of the CUP is on tribal lands
and therefore ostensibly ineligible to participate in the federal uranium program, part of the CUP
is on private land adjacent to tribal lands, yet still within Dine communities. Allowing the CUP

1


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to participate in a U.S. uranium mine reserve program under your Department will essentially
shift the sacrifice of lives in the war-torn Ukraine for lives of the Dine tribal members. This is
how serious we see this issue. President Biden ran for office pledging to protect tribal
communities and restore tribal sovereignty. We need you to support his pledge to us and not
allow the Crownpoint Uranium Project to participate under any federal uranium program. Doing
so would cut directly against President Biden's pledge and promises.

Further, the United States has a duty under its trust responsibility to protect our Dine
communities. We live in the year 2022, and the voice of our people should not go unheard.

While we appreciate prior statements from the Department of Energy that there is no intention to
initiate or expand mining "on Tribal lands, expand the Office of Legacy Management's (LM)
Uranium Leasing Program, or expand access to additional uranium deposits located on other
Federal lands," the Department misses a key understanding of the true issues involved. Most of
the potential damage to tribal interests occurs from activities on traditional aboriginal territories,
sacred sites, and lands adjacent to tribal lands, not "on tribal lands" itself. This is where the
federal trust responsibility should be at its strongest. Indian tribes, like the Navajo Nation, rely
on the federal government to protect its people from the harmful effects of uranium mining. It
should not matter where the mining occurs.

We have lived in our homeland, between the Four Sacred Mountains, in what are now the states
of New Mexico, Arizona, Colorado and Utah, for hundreds of years and the single largest threat
to our survival over these millennia has been the uranium industry. Mining for uranium not only
harms the surface environment but also contaminates our groundwater resources. Widespread
contamination from historic uranium development has already proven disastrous to the health of
our people. Subsidizing future uranium development on and near the Navajo Nation and at sites
within our traditional territory may well extinguish the Dine as a People. Polluting our land, air
and water with new uranium production will not only add additional health burdens, it will also
adversely affect our very identity as Dine. Our relationship with our land, air and water is sacred
and inextricably tied to our individual and collective identity.

We urgently ask the Department of Energy to uphold President Biden's pledge and promise to
protect the Navajo Nation and restore tribal sovereignty. We need you and others to hear our
voices. We ask that you prohibit participation of the Crownpoint Uranium Project and any other
future uranium development within the boundaries of the Four Sacred Mountains in any federal
uranium program or from accepting any federal funding to operate.

Respectfully,

/s/ Jonathan Perry
Jonathan Perry
Executive Director

2


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Eastern Navajo Dine Against Uranium Mining
President, Becenti Chapter

/s/ Rita Capitan	

Rita Capitan
ENDAUM Founder
President, Crownpoint Chapter

/s/ Larry King	

ENDAUM Member
President, Churchrock Chapter

Cc:

The Honorable Sen. Martin Heinrich

The Honorable Sen. Ben Ray Lujan

The Honorable Rep. Teresa Leger Fernandez

The Honorable Jonathan Nez, Navajo Nation President

Deb Halland, Secretary of the Interior

Michael Regan, Administrator, U.S. EPA

Dr. Earthea Nance, Regional Administrator, EPA Region VI

National Environmental Justice Advisory Council

White House Environmental Justice Advisory Council

3


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National Wildlife Federation

National Advocacy Center

1200 G Street NW, Suite 900 • Washington, DC 20005 • 202-797-6800

April 22, 2022

Chair Brenda Mallory
Council on Environmental Quality
730 Jackson PI NW
Washington, DC 20506

RE: Comments on CEQ's Climate and Economic Justice Screening Tool Beta Version (docket number CEQ-2022-
0002)

Dear Chair Mallory:

The National Wildlife Federation (NWF) is America's largest and most trusted conservation organization. We represent
over six million members, supporters, and affiliates and work across the country to protect people and preserve wildlife
habitats. NWF thanks CEQ for the opportunity to comment on the Climate and Economic Justice Screening Tool Beta
Version. NWF is a strong proponent of using geospatial tools to further environmental and climate justice.

Climate and environmental justice screening and mapping tools are important in their own right for providing data-driven
evidence to support community voices on environmental injustices and climate vulnerabilities. But it is a missed
opportunity when they are not meaningfully incorporated into policy. A comprehensive screening tool is one that not only
includes environmental and demographic indicators, but also measures factors such as economic progress, health, and
resiliency—it is only with these kinds of indicators that we have a holistic, accurate understanding of environmental
justice, and climate equity and justice.

The Climate and Economic Justice Screening Tool is intended to "help Federal agencies identify disadvantaged
communities that are marginalized, underserved, and overburdened by pollution" to aid in the implementation of
Executive Order 14008, including the Justice40 Initiative, as stated on the Screening Tool's website. Below, the National
Wildlife Federation outlines key recommendations that address these monumental goals and will aid the Administration in
achieving Justice40 and we encourage CEQ to carefully evaluate and consider them for inclusion in the Screening Tool.

Include Race as a Socioeconomic Indicator

A multitude of studies have shown that race is the most important predictor of the distribution of environmental hazards.
These include, a 2010 study by Crowder and Downey in the American Journal of Sociology, a 2015 study by Cushing et
al. in the American Journal of Public Health and a 2017 study by Clark et al. in Environmental Health Perspectives among
many others. We understand that the use of race-neutral criteria is intended to aid the tool in surviving legal challenges,
however we cannot expect proxy indicators to be sufficient in addressing the tangible, historical, and routine federal
discrimination and divestments in communities of color.


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Based on the Beta Version of CEQ's Screening Tool and existing indicators, as the number of non-white residents in a
census tract increases, a tract becomes more likely to be considered disadvantaged. This illustrates that by prioritizing
communities with the greatest pollution burdens the tool automatically prioritized communities of color. However, the
system also flags about 3,500 census tracts where 20 percent or fewer residents identify as non-white and leaves out more
than 2,200 tracts where 80 percent or more of the population identify as non-white. Some census tracts are surrounded by
disadvantaged tracts but aren't being flagged as disadvantaged by the Screening Tool (barely exceeding the cut off in the
income criteria), despite suffering from similar issues on the ground.

Therefore, we propose that these criteria are not serving as an effective enough proxy for race, leaving many communities
in need without the designation of a 'disadvantaged community' and that race should be included as a separate
socioeconomic criterion.

Utilize Multiple Levels of Spatial Granularity

To build off of the previous recommendation, the use of census tract level data is helpful and granular enough to capture
certain disparity 'hotspots', however the Screening Tool should utilize and overlay other levels of granularity such as the
county and zip code levels in the designation of disadvantaged communities as well. By taking all of this data into account
in identifying disadvantaged communities, fewer areas that may surround census tracts that are flagged as disadvantaged
but aren't flagged themselves, despite facing similar issues, may be counted within the tool as well.

Incorporate Cumulative Impacts

In order to be flagged as a disadvantaged community within the Screening Tool, a census tract must meet an income
metric and one of the eight environmental/climate metrics. The Screening Tool as it is currently designed does not allow
for examining the cumulative effects of various environmental, health, and socioeconomic burdens— and how they might
combine to create a greater burden than each indicator alone might suggest. Disadvantaged communities do not
experience each indicator in isolation and within the category of 'disadvantaged' there is significant variation in the types
of burdens each community faces and in the cumulative burden. CalEnviroScreen is a great example of a screening tool
that provides assessments of cumulative impacts, in this case across communities in California.

In an analysis of the Climate and Economic Justice Screening Tool, the World Resources Institute found that nearly 79
percent of the population living in a community flagged as disadvantaged are in census tracts that meet the threshold for
five or fewer indicators. However, about 1 million people live in the 2 percent of communities above the threshold for 11
or more indicators. Therefore, the people within this latter group face the most acute burden due to the interactions of
individual indicators, but are rated with the same level of priority.

To address long-standing environmental and health burdens, including disparities compounded by racial and
socioeconomic injustice, a realistic assessment of the combined effects of multiple stressors in communities is required.

Include Future Climate Impact Projections

The Screening Tool uses historic data on natural hazards and losses to assess vulnerability, while using frequency of past
events, severity of their damages, and weighting recent years more heavily in those measurements. As these hazards work
to exacerbate existing inequalities, leaving low-income and minority populations more exposed to risks and racial
disparities in the administration of recovery funds, relying on historical data will not provide an accurate picture of the
most vulnerable communities. This is further demonstrated by the U.S. Government Accountability Office's 2017 report,
Climate Change: Information on Potential Economic Effects Could Help Guide Federal Efforts to Reduce Fiscal
Exposure.


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Extreme weather events will become more frequent, intense, and impact broader swaths of the country. The latest IPCC
report warns that if warming exceeds 1.5 degrees C in tropical regions for example, the combined effects of heat and
drought may trigger sudden and significant losses in agricultural yields. This would increase heat-related mortality while
labor productivity decreases, so people will not be able to work harder to overcome drought-related losses. Together,
these impacts will lower families' incomes while raising food prices — a devastating combination that jeopardizes food
security and exacerbates health risks. Considering future climate projections of all indicators within the Screening Tool is
essential so that we may be aware of potential future conditions and can use the information to mitigate future harms and
losses.

Additional Recommendations & Resources

Our recent publication in collaboration with Center for Community Engagement, Environmental Justice, and Health at the
University of Maryland. Gaps in Environmental Justice Screening and Mapping Tools and Potential New Indicators.
includes a list of policy recommendations to help ensure EJ screening and mapping tools inform decision-making at the
federal and state levels, and are used to target attention - including investment and enforcement actions - to communities
that need it the most.

This report provides additional recommendations in response to the questions posed in the Federal Register notice,
including recommendations for additional datasets that would enhance and improve upon the set of indicators currently in
the tool, key indicators for further consideration, and a collaborative problem-solving model to help ensure an equitable
application to policy and decision-making. The report is also attached to these comments.

Conclusion

The National Wildlife Federation appreciates the CEQ's request for comment and input on the development of the
Climate and Economic Justice Screening Tool and we look forward to further supporting the development of the
Screening Tool and in advancing climate equity and justice.

Sincerely,

Simone Lightfoot

Associate Vice President for Environmental Justice and Climate Justice

Shannon Heyck-Williams

Senior Director for Climate and Energy Policy


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veetso^

c/o oda

Secretary Jennifer M. Granholm

U.S. Department of Energy

1000 Independence Ave. SW

Washington DC 20585

Sent via Email: the.secretary@hq.doe.gov

May 2, 2022

Subject: Uranium Mining Concern
Dear Secretary Granholm:

The Red Water Pond Road Community Association (RWPRCA) is writing to express concern
about the U.S. Department of Energy's consideration of a "strategic uranium reserve." The Red
Water Pond Road community is located near Churchrock, Navajo Nation, New Mexcio, between
three Superfund sites related to historic uranium exploitation: the Northeast Churchrock Mine,
the Kerr-McGee/Quivira Mine and the UNC uranium mill. Consequently, members of the
RWPRCA have been exposed to unsafe concentrations of radiation and toxic heavy metals for
decades.

As a member of the Multicultural Alliance for a Safe Environment, we previously submitted
comments to you on October 13, 2021 in response to the RFI. We are deeply concerned with
ongoing discussions taking place to increase uranium mining in the United States due to Russia's
invasion of Ukraine. While we understand the United States' position on potentially banning
uranium imports from Russia, we cannot stress enough that any corporate subsidies that prop up
the domestic uranium mining industry will have significant, long term and devastating effects on
our communities and Indigenous communities across the country. A horrible war in Europe
should not be used as an excuse to harm Dine (Navajo) communities and other Indigenous
communities located here in the United States under threat of new uranium development.

President Biden ran for office pledging to protect tribal communities and restore tribal
sovereignty. We need you to support his pledge to us and not allow any new uranium
exploitation projects in or near the Navajo Nation, including within traditional Dine territory, to


-------
participate under any federal uranium program. Doing so would directly contradict President
Biden's pledge and promises.

While we appreciate prior statements from the Department of Energy that there is no intention to
initiate or expand mining "on Tribal lands, expand the Office of Legacy Management's (LM)
Uranium Leasing Program, or expand access to additional uranium deposits located on other
Federal lands," the Department misses a key understanding of the true issues involved. Much of
the potential damage to tribal interests occurs from activities on traditional Indigenous territories,
sacred sites, and lands adjacent to tribal lands, not "on tribal lands" itself. This is where the
federal trust responsibility should be at its strongest. Indian tribes, like the Navajo Nation, rely
on the federal government to protect its people from the harmful effects of uranium mining. It
should not matter where the mining occurs.

We have lived in our homeland, between the Four Sacred Mountains, in what are now the states
of New Mexico, Arizona, Colorado and Utah, for hundreds of years and the single largest threat
to our survival over these millennia has been the uranium industry. Mining for uranium not only
harms the surface environment but also contaminates our groundwater resources. Widespread
contamination from historic uranium development has already proven disastrous to the health of
our people. Subsidizing future uranium development on and near the Navajo Nation and at sites
within our traditional territory may well extinguish the Dine as a People. Polluting our land, air
and water with new uranium production will not only add additional health burdens, it will also
adversely affect our very identity as Dine. Our relationship with our land, air and water is sacred
and inextricably tied to our individual and collective identity.

We urgently ask the Department of Energy to uphold President Biden's pledge and promise to
protect the Navajo Nation and restore tribal sovereignty. We need you and others to hear our
voices. We ask that you withhold participation of all future uranium development within the
boundaries of the Four Sacred Mountains in any federal uranium program and prohibit any future
uranium development within the boundaries of the Four Sacred Mountains from receiving
federal funding to operate.

Respectfully,

/s/ Edith Hood
Edith Hood

Red Water Pond Road Community Association

2


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Cc:

The Honorable Sen. Martin Heinrich

The Honorable Sen. Ben Ray Lujan

The Honorable Rep. Teresa Leger Fernandez

The Honorable Jonathan Nez, Navajo Nation President

Deb Haaland, Secretary of the Interior

Michael Regan, Administrator, U.S. EPA

Dr. Earthea Nance, Regional Administrator, EPA Region VI

National Environmental Justice Advisory Council

White House Environmental Justice Advisory Council

3


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f

Massachusetts

TECHNOLOGY

April 14, 2022

Senator Michael J. Rodrigues, Chair
Senate Committee on Ways and Means
24 Beacon Street, Room 212
Boston, MA 02133

Dear Senator Rodrigues and Members of the Senate Committee on Ways and Means,

You have before you a bill critically urgent to the Commonwealth's public safety and climate
change efforts: Senator Cyr's S.186 Resolve relative to disclosure of radio frequency
notifications.

The Backstory

When my daughters were in school, we kept hearing about the 21st Century Classroom and how
our children would need this new technology to succeed in today's world. Our town budgets
could not afford this so I spent eight years fundraising to bringing wireless technology into
Ashland Public Schools as the President of the Ashland Education Foundation and later as the
district's grant coordinator. I was honored to serve alongside Senator Spilka in these efforts.

Then an electrical engineer friend tipped me off there could be biological harm from the
electromagnetic fields (EMFs) of radiofrequency microwave radiation used to carry the signals
and data back and forth between our devices and the routers and cell towers with which they
communicate.

I am a technical writer by trade so I began to research the peer-reviewed science and was
astounded to discover there are literally thousands of studies all over the world documenting
extensive harm to both people and the environment. Then I tried to help others:

First, through a long and difficult School Committee process in 2014, I helped Ashland Public
Schools become the first in the nation to implement Best Practices for Mobile Devices. Although
we have a sign hanging in all of our classrooms to turn off the devices and the wi-fi when not in
use, they are not enforcing it and the children continue to be radiated. Our administrators are
waiting for higher authorities to tell them to remove this electropollutant from the classroom.

Second, after three attempts I secured a grant to place a radiofrequency radiation (RF) detection
meter on loan in the Ashland Public Library so residents can measure these invisible exposures
and safeguard their loved ones. This has become a model program deployed by the Newton and
Pittsfield libraries, and others across the country.


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Third, I showed Senator Spiika and Puja Mehta the science and Ashland's school sign, then
measured the radiation coming off of Karen's cell phone and Puja's laptop. Both devices sent
the RF meter off the charts into to the red zone. Senator Spiika put me with Aaron Carty and
together we wrote the nation's first commission bill to investigate wireless radiation. It was
assigned to the Joint Committee on Public Health in 2015.

I arranged for world leading EMF scientists, doctors, public health experts, technologists and
injured citizens to send in testimony. The bill was advanced by Public Health but sent to study by
Health Care Finance. In 2017, Karen introduced the bill as a Resolve under her own name and
again it advanced but Senate Ways and Means sent it to study. In the third session Karen was
elected Senate President and no longer introduced legislation.

Senator Cyr's Bills

Fortunately, by then, Senator Cyr had introduced two bills to address wireless radiation risks
too. One would form a commission and the other would protect children from handheld
devices.

Did you know the current Resolve S. 186 was written by the Joint Committee on Consumer
Protection and Professional Licensure? When Senator Cyr first filed these bills in 2017, I once
again arranged for world leading doctors, scientists, technologists and injured citizens to send in
testimony.

When Consumer Protection saw the evidence of harm coming in and after I walked Chairs
L'ltalien and Chan through the issue, they assigned a research analyst to investigate further. Jay
Santos asked what I considered to be the top 10 reasons to pass these bills and I provided him
with a list.

They did their due diligence and verified the facts, then in 2018 Consumer Protection wrote S
2431 to form a commission to investigate wireless radiation. Although the bill has been voted
out of committee favorably each session since, it has failed to pass.

In the meantime, Massachusetts began battling unprecedented epidemic proportions of
anxiety, depression, insomnia and other mental health deteriorations in both children and
adults. Our pollinators began to disappear, climate change escalated. The science shows
wireless radiation is a major contributing factor. It is a neurotoxin and it kills insects, and
wireless systems consume lOx more energy than the responsible technology solution of fiber-
optics to and through the premises.

Yet Massachusetts continues to allow the wireless industry to immerse our families and
environment in electropollution at alarming rates. The message is not no technology, it's safe
technology, and we know how to get there.

Much has advanced with wireless radiation science, public policy, and legal actions since 2017
when Consumer Protection wrote what is now before you as Resolve S. 186.

Here are today's top 10 urgent reasons to pass Resolve S. 186 and form an expert commission
this session, perhaps as an emergency measure:

S. 186 Wireless Radiation Commission

April 14, 2022

Page 2 of 12


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1. Massachusetts Used to Lead the Nation

We are falling behind. For nearly a decade Massachusetts led the nation with many bills to
address the wireless radiation issue. This session alone, we have 20 bills filed to form a
commission to investigate, protect children in schools, require a no-fee opt-out from utility
"smart" meters and more.

Our public record is solidly populated with the facts to enable you to act to protect the
Commonwealth. Here is a 600-page compilation of testimonies I produced in 2018 and gave to
Senator Spilka and Dennis Giombetti. I will forward under separate cover many of the
testimonies that have come in this session too so you are empowered with the current public
record on wireless radiation risks and remediation solutions.

In ten years Massachusetts has yet to pass a wireless radiation bill. However, armed with the
same facts as we've brought forth in the Commonwealth, New Hampshire passed a law to
investigate in just seven months.

2. New Hampshire's Groundbreaking Commission Report

New Hampshire has already done the hard work to enable Massachusetts to now follow suit.

Citizens harmed by wireless radiation introduced NH Rep. Patrick Abrami to the science. He is an
engineer, and as such had only been taught you must have heat from a wireless antenna to have
harm. The FCC public radiation limits were set in 1996 to these thermal, or heating effects and
that is what is still in place today.

Rep. Abrami did his due diligence though and personally began investigating the peer-reviewed
scientific literature. He discovered a vast body of science showing extensive harm at the non-
thermal level, meaning our FCC guidelines allow far too much radiation to protect the public or
the environment.

He then met with me and his constituent and we helped him connect the dots further on the
magnitude of wireless harm.

In 2019, Rep. Abrami introduced NH HB.522, a bipartisan bill to form a commission to answer
the following eight questions:

1.	Why does the insurance industry recognize wireless radiation as a leading risk and has placed
exclusions in their policies not covering damages by the pathological properties of
electromagnetic radiation?

2.	Why do cell phone manufacturers have in the legal section within the device saying keep the
phone at least 5mm from the body?

3.	Why have 1,000s of peer-reviewed studies, including the recently published U.S Toxicology
Program 16-year $30 million study, that are showing a wide range of statistically significant DNA
damage, brain and heart tumors, infertility, and so many other ailments, been ignored by the
Federal Communication Commission (FCC)?

S. 186 Wireless Radiation Commission

April 14, 2022

Page 3 of 12


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4.	Why are the FCC-sanctioned guidelines for public exposure to wireless radiation based only
on the thermal effect on the temperature of the skin and do not account for the non-thermal,
non-ionizing, biological effects of wireless radiation?

5.	Why are the FCC radiofrequency exposure limits set for the United States 100 times higher
than countries like Russia, China, Italy, Switzerland, and most of Eastern Europe?

6.	Why did the World Health Organization (WHO) signify that wireless radiation is a Group B
Possibly Carcinogenic to Humans category, a group that includes lead, thalidomide, and others,
and why are some experts who sat on the WHO committee in 2011 now calling for it to be

placed in the Group 1, which are known carcinogens, and why is such information being ignored
by the FCC?

7.	Why have more than 220 of the world's leading scientists signed an appeal to the WHO and
the United Nations to protect public health from wireless radiation and nothing has been done?

8.	Why have the cumulative biological damaging effects of ever-growing numbers of pulse
signals riding on the electromagnetic sine waves not been explored, especially as the world
embraces the Internet of Things, meaning all devices being connected by electromagnetic
waves, and the exploration of the number of such pulse signals that will be created by
implementation of 5G technology?

Following compelling expert testimonies akin to what we have in MA, the NH House Committee
on Science, Technology and Energy advanced the bill to the Senate Committee on Health and
Human Services which also voted it out favorably. Governor Sununu signed HB. 522 into law and
within seven months of the bill's introduction New Hampshire formed a commission composed
of highly qualified medical doctors, scientists, physicists and engineers as well as state agency
representatives and members of the wireless industry.

They reviewed thousands of peer-reviewed studies from all over the world documenting very
serious biological harm to children, adults and the environment, from low-level, non-thermal,
non-ionizing exposures and posted their findings on the NH State website.

In a publicly transparent process, they also interviewed world-leading microwave radiation
scientists and doctors, the retired President of Microsoft Canada, World Health Organization
advisors, and industry representatives as well.

They repeatedly invited the FCC and FDA to meet with them and our federal agencies refused,
signaling that this issue needs to be addressed at the state level. Investigation revealed these
agencies are captured by industry.

Even during the COVID-19 pandemic, New Hampshire kept the wireless investigation a priority
and their work culminated in the groundbreaking New Hampshire Final Report on Commission to

Study the Environmental and Health Effects of Evolving 5G Technology.

The 390-page report is thorough yet easy to read. The Summary and Recommendations are all
in the firsts 17 pages and the bulk of the document is comprised of the appendices which

S. 186 Wireless Radiation Commission

April 14, 2022

Page 4 of 12


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contain the science and other supporting facts, as well as minutes from their 13 publicly
accessible meetings.

The report also contains a minority report written by industry in pages 18-27 before the
appendix begins. This is the industry playbook which the majority of commission members saw
right through after investigating the facts. The minority report is something of a gift though, as it
contains the messaging routinely given by wireless representatives to our towns, legislators and
the public. Commission members Senator Denise Ricciardi and Dr. Paul Heroux counter many of
the points of disinformation from the minority report on pages 384-5 of the electronic copy, or
pages 5 and 6 of 11 in the final meeting minutes of Appendix O.

New Hampshire makes 15 recommendations to engage federal delegates to protect the
public and the environment, and in the meantime at the state level educate the public,
label all RF emitting equipment, measure exposures, establish setbacks, and begin
transitioning away from harmful wireless technology to fiber to and through the
premises.

The NH commission report is the strongest fact-based investigation in the nation. In December
2020 the European Parliament began an investigation into wireless radiation, especially 5G.

They held a two-hour session with six representatives from industry and science. In the final
minute the moderator recommends emulating the NH commission's process and report.

The New York legislature now has S.5926 and A.06448 to emulate the New Hampshire report,
and many other states have made inroads toward responsible technology too.

MA would do well to get going on this ASAP. We are falling behind and it is showing in the
declining health of our populace and environment.

Note: the Oregon legislature tasked the Oregon Health Authority (OHA), through an emergency
law, to investigate wireless radiation, especially as it impacts children in schools. A good report
was drafted at the same time NH did its review, but unfortunately, as an in-depth journalism
investigation reveals, the credible science was scrubbed from the final report by industry-
friendly OHA authorities which has left Oregon's children immersed in toxic levels of radiation -
just as Massachusetts' children are today.

New Hampshire has taken next steps and in January introduced HB. 1644 to begin implementing
the commission's report recommendations, starting with prohibiting new cell towers or small
cells within 500 meters /1,640' of homes, schools, parks, medical facilities, senior centers, etc.
That is the distance where the science indicates the increased death rate slope begins to go
down. The bill also establishes an industry funded state-level registry of harm.

Following public testimony their House Committee on Science, Technology and Energy
unanimously voted not to kill the bill, and has formed a bipartisan 8-member Interim Study
committee to decide how to move forward. They will execute their work starting this spring.

S. 186 Wireless Radiation Commission

April 14, 2022

Page 5 of 12


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3. Legal Actions:

In 2019, when the FCC ignored 11,000 pages of scientific, medical and citizen evidence of harm
entered into the public record and reaffirmed its toxic levels of public radiation exposure, the
FCC was sued by the Environmental Health Trust and others.

In August 2021, the 9th District Circuit Court of Appeals in D.C. ruled the FCC was arbitrary and
capricious in its decision to continue to expose the public to today's levels of wireless radiation
and remanded it back to the FCC to reassess their radiation limits, especially as they impact
children and the environment. This is where it stands today, the proverbial fox still watching the
hen house.

Knowing the FCC will aim to drag this out indefinitely, the non-profit Americans for Responsible
Technology has consulted with leading attorneys in telecom law and filed an Imminent Hazard
Petition with the FDA. Massachusetts resident and business owner Robert Strayton is a co-
petitioner as he was injured by a cell tower installed next to his home in Chappaquiddick.

The Massachusetts Association for Boards of Health now includes cell tower risks in the last four
pages of the Legal Handbook and Public Health Guidebook for Massachusetts Boards of Health.

There are many Massachusetts lawsuits too, here are a few examples:

•	Citizens in Hull are trying to protect their homes from 5G small cell installations

•	Pittsfield residents have sued for lack of proper notification to residents of applications
for cell towers

•	Parents in Southborough sued under ADA for the harm done to their son by the wireless
radiation emissions at the prestigious Fay School; for the first time in U.S. history, the
courts recognized biological harm at the non-thermal level; Rep. Carolyn Dykema has
had bills for years to protect all students in schools, see this session's H. 115.

•	Cambridge successfully won a suit when industry failed to adhere to due process

•	Boston joined mayors in other states in suing the FCC and wireless industry for usurping
local control

•	Cape residents worked with Barnstable to sue for protections from close-range cell
antennas mounted in a church steeple

•	Ashfield residents successfully sued to stop a cell tower

Please know Boston has been trying to avert wireless risks for years. In 2013, the cities of Boston
and Philadelphia filed a submission to the Federal Communications Commission (FCC)

(Dockets #13-84 and #03-137) that accused the FCC and federal health agencies of negligence
for failing to investigate whether electrosensitive persons are harmed by wireless radiation.

S. 186 Wireless Radiation Commission

April 14, 2022

Page 6 of 12


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In 2020, the City of Boston filed a submission to the FCC's 19-226 docket stating, "Boston
believes that the concerns of the public are real and that the Commission has done a disservice
to itself, local government, consumers, and even the wireless industry in failing to understand
and respond to the broadly shared mistrust of the safety of RF emissions." See the full
submission here.

Many towns in Massachusetts are rising up against harmful utility "smart" meters as well as
close range cell towers and small cell antennas being imposed in their communities. See the
News page at Massachusetts for Safe Technology for articles from communities across the
Commonwealth. See also the Events page for educational forums and performances being held
to educate the public.

A few examples are:

•	Residents worked with their town in Lenox to stop cell tower antennas from being installed
on top of The Curtis, the state-owned housing for senior citizens and the disabled

•	Citizens in Wayland years ago worked with their town to put a 900' setback in their zoning
code to protect residential areas, which allowed them to lawfully deny an industry
application in recent years to put a cell tower on their rod and gun club, which abuts a
neighborhood.

•	Burlington, MA adopted a small cell policy requiring all 5G antennas to be recertified each
year and the vendor would have to pay for it. Verizon withdrew their small cell applications.
Americans for Responsible Technology incorporated this into their sample ordinance being
brought by citizens to their municipalities all over the country.

•	Dover-Sherborn parents staved off two cell towers on the high school

•	Westwood parent succeeded in having the schools refuse to renew cell tower leases on the
roof of the middle school

•	Pittsfield, after a two-year investigation, this week broken ground as the first Board of
Health in the nation to issue a cease-and-desist order to Verizon to remove a cell tower

activated the first week of the pandemic. Children and adults immediately became ill and
symptoms worsened over time to the point where residents have had to abandon their
homes. The pollinators have also disappeared. Rep. Patricia Farley-Bouvier lives in this
neighborhood and testified before the Joint Committee on Consumer Protection and
Professional Licensure on the need for Massachusetts to address the wireless issue.

Our citizens and towns should not have to fight these battles. The Commonwealth needs to take
a stand to protect all citizens from wireless radiation. Passing S. 186 ASAP would be a good start.

4. Havana Syndrome & Public Exposures

Much has been reported lately on Havana Syndrome, where U.S. diplomats and their families
have experienced extensive harm from microwave radiation exposures.

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This is the SAME microwave radiation deployed widely today in the public sector via wireless
technology. Harmful electromagnetic fields (EMFs) of radiofrequency microwave radiation are
continually pulsed from our own cell phones, earbuds, routers, tablets, laptops, wearables, baby
monitors, gaming devices, Roku, Chromecast, Alexis, appliances, automobiles and all electronics
geared for the Internet of Things (loT).

At the community level, this radiation is emitted 24x7 from utility "smart" meters for electric,
gas, propane, water and solar systems. Toxic emissions are constantly radiated by cell towers
plus macro cell antennas mounted on buildings. The electropollution is growing exponentially
with 5G small cells being installed at bedroom height inside neighborhoods in the public
accessway. 5G adds a whole new layer of harmful beam-forming radiation on top of the existing
3G and 4G pulses, upping the total body burden of electropollution to new heights.

Our bodies did not evolve to adapt to these extremely high levels of man-made radiation, and
with constant exposure we can never get a break to do proper cell repair and regeneration.

5.	The Science: Human Harm

Wireless technology was developed for use by our militaries, starting with radar systems and
then biological warfare. Now declassified military studies indicate our government knew of the
biological harm decades ago, long before wireless technology products were sold to the public.

The industry has known too. See this 2000 report from T-Mobil. the German parent company of
our T-Mobile.

The science has continued to advance and thousands of peer-reviewed studies published in
highly credible journals report wireless radiation causes cancers, DNA damage, infertility,
ADD/ADHD, autism, and Alzheimer's disease coming on at earlier and earlier ages.

In the short-term, the science documents wireless radiation is a neurotoxin and
immunosuppressant which contributes significantly to our escalating rates of anxiety,
depression, anger, insomnia, headaches, nosebleeds, pain, nausea, skin abnormalities, heart
irregularities, cognitive impairment and behavior issues.

The science indicates children, fetuses, the elderly and those with existing health compromises
are even more vulnerable than the general population.

6.	The Science: Flora and Fauna

There is another large body of science documenting the environmental impact of blanketing our
world in radiation signals that are 1,000,000,000,000,000,000 times greater than the earth's
natural electromagnetic field. Pollinators are disappearing, birds' navigation systems are
disoriented, and every ecosystem is impacted.

As if it weren't bad enough what we are doing with electropollution here on the ground, the
industry is now launching thousands of 5G satellites into the sky to blanket every corner of the
earth with wireless radiation beams connecting to devices on the land. Soon there will be no
place left to go without being radiated unless we take bold action.

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7. Climate Impact

The engineering community reports wireless systems consume IQx more energy than the safer,
responsible technology solutions of fiber to and through the premises. As far back as 2012 a
Greenpeace analyst reported if the telecom industry were a country, it would be the fifth
largest consumer of energy in the world. If 5G and the Internet of Things are allowed to
proliferate, energy consumption is expected to multiply exponentially.

8.	Data Security and Privacy

When our data is sent through the air using microwaves, it is easily hacked. When signal is run
through secure cables, it is not. As you are likely aware, this goes beyond personal data as
intruders can shut down our whole grid by hacking into wireless systems more easily.

Another privacy issue is that utility "smart" meters can harvest private data from ratepayers'
usage patterns which can then be sold to third party vendors interested in selling the ratepayer
products, or used by criminals to detect when you are not home and plan their break-ins
accordingly. Massachusetts should not be investing in more wireless infrastructure for grid
modernization. We should work with the utility companies to install meters that are hard-
wired to the premises and forego any wireless transmitters. Rep. Tommy Golden's H. 3309
could be amended accordingly.

9.	5G Good for Telecom, Bad for the Public and Environment

Wireless technology is highly profitable and has a short life, thereby creating a repeated revenue
stream for industry as upgrades and replacement cycles are imposed. The e-waste is terrible for
our planet, from the human atrocities inflicted to mine the many minerals needed in each
wireless product, to the mounds of unrecyclable materials in the landfills.

With 5G, the industry intends to put a cell tower called a small cell at bedroom, right inside our
neighborhoods at the curb in the public accessway on poles or wires.

PC Magazine and others report there is no need for 5G, it is not delivering the promised faster
speeds than what already exists with 4G. Fiber to and through the premises will always deliver
far superior speeds and reliability than anything wireless can ever deliver.

The wireless industry is also buying up the entertainment industry as they promote 5G for faster
streaming services and content development. This is yet another new revenue stream.

Unless towns have updated their zoning bylaws, the industry is already putting these toxic small
cells at close range in many towns. See the map of Boston installations.

As this two-minute clip from Boston25 News indicates, Verizon has installed small cells up
Fenway Park too, where they are radiating thousands of spectators at close range. They've
gotten into Gillette Stadium too.

10.	Major Breakthroughs in the Medical Community

Many children and adults are suffering from microwave sicknesses and being misdiagnosed
because doctors and the public have been kept in the dark by the powerful wireless industry.

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When we first introduced MA legislation, we had no way of training health care practitioners to
recognize, diagnose, treat and prevent these environmentally-induced illnesses.

Martha's Vineyard environmental medicine practitioner Dr. Lisa Nagy co-chaired the first U.S.
Electromagnetic Fields Conference in 2019. In 2021 another expanded international EMF
Medical Conference was held with world leading doctors, scientists and public health experts. I
was honored to present state and local policy at both conferences.

Doctors, nurses, first responders and other health care providers can now earn 24.5 continuing
medical education credits through affordable self-paced on-line training (note, the CME/CE
opportunity expires in May, so if your medical team isn't trained, you might want to strongly
encourage them to register for the conference by May 1. Remember, the damage from this
radiation is cumulative in our tissues; those feeling fine today may hit a tipping point
tomorrow and if their doctors aren't trained, they will be misdiagnosed and continue to
suffer). The public is also welcome to enroll at a reduced rate to learn directly from the experts.

It was very unsettling to hear from several of the doctors that their patient load increases when
utility "smart" meters go in, and when cell towers and small cells are installed at close range.
They further indicated that with the increasing electropollution damaging the gray and white
matter of the brain, we can anticipate increases in societal crimes including mass shootings.

Dr. Lisa Nagy and I worked with the Massachusetts Medical Society for two years, and in
December 2021 they converted our Resolution: Wireless Communications Public Safety
Standards Reevaluation to a policy statement:

That the Massachusetts Medical Society supports continuing research, including quality
epidemiologic studies, by appropriate agencies and entities to produce evidence-based data on
the effect(s) of radio frequency radiation on human health. If indicated, study findings should
be used to revise and update public health standards for safe limits of human exposure to
radio frequency radiation.

See also the 1997 Boston Physicians' and Scientists' Petition to Avert Public Exposures to
Microwaves.

Growing Urgency for All

If we do not stop the industry, they will continue to install close-range cell towers next to our
homes, and now directly on our schools too.

Please see this website of the captured Federal Department of Education: School District
Wireless Network Models. You will see they are now targeting school buildings and buses for
toxic cell tower/antenna installations, as well as mounting them directly on home rooftops, at
the curb at bedroom height, and on water towers inside neighborhoods.

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The industry targeted our children through their 21st Century Classroom campaign with the goal
of having a one-to-one device in the hands of every child. They know once you have a child as a
consumer, you often get to keep them for life.

The Pittsfield adults and children have had to flee this type of cell tower infrastructure to
survive. If the industry succeeds in rolling out the plans on the DOE website, where will anybody
go?

The radiation will be unlivable everywhere, plus the children will continue to be radiated
every hour of every school day, even on the playgrounds and fields. Again, wireless radiation is a
neurotoxin and we are already at epidemic levels of anxiety and depression with the amount of
radiation currently in most schools and homes today.

Even pre-pandemic our schools were unable to resolve the escalation of mental health issues,
and now we've given every student in the Commonwealth a toxic wireless tablet to access
their education -- with no safety instructions to hard-wire with an inexpensive adapter to an
Ethernet cable, and turn off the multiple radiation antennas.

Please see this private three-minute video demonstrating the toxic radiation exposure levels
from a student's school-issued Chromebook, and how to very easily hard-wire and turn off the
radiation. The radiation was at 25,000 microwatts per square meter and the science indicates
we should be at 10 or less indoors, and at 0.1 in our sleeping areas.

A Boston resident and I measured the radiation in the North End, on Hanover Street where small
cells have been installed. We got readings as high as 600,000. The science indicates we should
be at 1,000 or less outdoors, and that is assuming we have a clean home environment where
our bodies can do proper cell repair and regeneration while we sleep. With a cell tower outside
or utility "smart" meters mounted in or on our homes, there is no escape.

As a recent paper identified, this radiation is causing Alzheimer's to develop at earlier and
earlier ages now too. What will become of our workforce if we continue to do nothing in
Massachusetts?

The Solution

Transitioning to responsible technology is not rocket science:

• Education is key to shift the social norm from industry's push for all-wi-fi-all-the-time to
responsible, superior hard-wired connections.

We should aim for As Low As Reasonably Achievable levels of wireless radiation for the
devices under our control as well as for community infrastructure including utility
"smart" meters, cell towers, small cell antennas and satellites. This ALARA principle is
already used by the CDC for ionizing radiation. It's time to instate this as a guiding
principle for wireless non-ionizing radiation too.

Dr. Bob Knorr at the MA DPH and I co-wrote EMF fact sheets which I was told would be
released in 2016 and they never were. My non-profit Wireless Education has since

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created easy half-hour on-line training courses for Schools & Families, as well as for the
Corporate workplace. Environmental Health Trust has developed a treasure trove of
resources as well. We are poised to quickly train the entire Commonwealth as soon as
political will allows. I and others have presented to the DESE board, and former Interim
Deputy Commissioner Wulfson told me they are waiting for higher authorities to tell
them what to do. We need your leadership, Senator Rodrigues.

•	Bring fiber-optics or high-speed cable to the premises (which most already have), and

simply connect to the internet indoors via Ethernet cables and adapters to devices. Then
turn off the radiating antennas in each device. The signal is much faster and more
reliable through cables, privacy is better protected, and hard-wiring consumes far less
energy than wireless systems. See Reinventing Wires: The Future of Landlines and
Networks for guidance to steer public policy and community development.

•	Funding may be possible through the ARPA broadband funds. We also already paid the
industry to bring fiber to the premises years ago which they failed to fully deliver. They
instead took much of that funding and used it to build out their inferior, highly
profitable wireless networks. The Irregulators have sued, and paved the way for
Massachusetts to recoup that funding. Click here for further information.

It's time to do what is best for our towns, not what the insatiable wireless industry would
deceptively lead us to do. The retired President of Microsoft Canada, Frank Clegg, presented to
the MA State House in 2015. and in his recent NH testimony he indicated wireless technology is
past its prime. The future lies in hard-wired technology to and through the premises for
primary connectivity as other countries are already beginning to do, and it is up to governments
to move industry there.

We understand the industry has already set aside billions for their injustices just as big tobacco
did. They are expecting to be held accountable as damage to the populace and environment are
simply the cost of doing business for them.

Please exercise your lawful duty ASAP to hold them accountable so we can all live safely in our
homes and communities. Begin by ensuring Resolve S. 186 passes this session and in the interim
take meaningful action to inform and protect the public while public policy catches up to the
science.

Please do not hesitate to reach out if Massachusetts for Safe Technology can support your
efforts further.

Kind regards,

Cecelia (Cece) Doucette, MTPW
Director, Massachusetts for f	.hnology

Education Services Director, Wireless Education
31 Fatima Drive, Ashland, MA 01721
508-881-3878, MA4SafeTechggmail.com

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State of New Hampshire

GENERAL COURT

CONCORD

MEMORANDUM

DATE:	November 1, 2020

TO:	Honorable Christopher T. Sununu, Governor

Honorable Stephen J. Shurtleff, Speaker of the House
Honorable Donna Soucy, President of the Senate
Honorable Paul C. Smith, House Clerk
Honorable Tammy L. Wright, Senate Clerk
Michael York, State Librarian

FROM:	Representative Patrick Abrami, Chair

SUBJECT:	Final Report on Commission to Study the

Environmental and Health Effects of Evolving 5G Technology
(RSA 12-K: 12-14, HB 522, Ch. 260, Laws of 2019)

Pursuant to RSA 12-K: 14, III, enclosed please find the Final Report of the Commission to Study
the Environmental and Health Effects of Evolving 5G Technology.

If you have any questions or comments regarding this report, please do not hesitate to contact
me.

I would like to thank those members of the commission who were instrumental in this study. I
would also like to acknowledge all those who testified before the commission and assisted the
commission in our study.

Enclosures

cc: Members of the Commission


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Final Report of the

Commission to Study
The Environmental and Health Effects of
Evolving 5G Technology

(HB 522, Chapter 260, Laws of 2019, RSA 12-K:12—14)

Membership

Name

Rep. Patrick Abrami (Chair)
Rep. Kenneth Wells
Rep. Gary Woods
Sen. James Gray
Sen. Tom Sherman
Denise Ricciardi
Brandon Garod, Esq.

Carol Miller
David Juvet
Kent Chamberlin, PhD
Bethanne Cooley
Michele Roberge
Paul Heroux, PhD

Organization/Representing

NH House of Representatives
NH House of Representatives
NH House of Representatives
NH Senate
NH Senate
Public

Attorney General's Office

Department of Business and Economic Affairs

Business and Industry Association

University of New Hampshire

CTIA-wireless communications industry

Department of Health and Human Services

McGill University Medicine

November 1, 2020


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Members of the Commission to Study the
Environmentai and Heaith Effects of
Evoiving 5G technoiogy agree to the filing of
this final report by the Chairman. This action

should not be construed in any way as an
adoption of any position by any Commission
member or state agency or organization they
represent on the underlying issue of the
deployment of 5G technology.


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Table of Contents

INTRODUCTION	1

Commission Responsibilities and Evolving Role	1

Summary of Commission Meetings	3

Questions Posed in HB 522	4

SUMMARY AND OBSERVATIONS	6

RECOMMENDATIONS	9

MINORITY REPORT	18

APPENDICES	28

Appendix A Electromagnetic Spectrum	29

Appendix B Correspondence with federal agencies	30

Appendix C Answers to the specific questions posed by HB 522	46

Appendix D Sampling of Scientific Studies Pertaining to Cellphone Radiation	75

Appendix E Challenges to the Radiation Exposure Standards Set by U.S. Regulatory Agencies	83

Appendix F Wireless Exposure Limits in Different Countries	91

Appendix G Captured Agencies and Conflicts of Interest	92

Appendix H Example of an RF radiation warning	94

Appendix I Example of a symbol for use on poles and other structures located in public rights-of way
that hold 5G antennae	95

Appendix J Deleterious effects of impulsive radiation	96

Appendix K Siting restrictions for wireless antennae	97

Appendix L Measurement of RF intensities within frequency ranges throughout state	106

Appendix M The enabling technology and scientific rationale for automatically stopping cell phones
from operating when held against the body	107

Appendix N Research on the effects of wireless radiation on trees, plants, birds, insects, pollinators,
and wildlife	Ill

Appendix O Meeting Minutes	115


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INTRODUCTION

Commission Responsibilities and Evolving Role

The Commission to Study the Environmental and Health Effects of Evolving 5G
Technology came about from the passage and signing into law of	. The

Legislature, after hearing testimony of potential health risks and the political
ramifications of small cell antennae being deployed on the public rights-of-way
throughout New Hampshire, agreed that a Commission be formed to take a
deeper look at this evolving technology. For the record, 5G stands for the 5th
Generation of wireless communication. This technology utilizes frequencies in the
millimeter wave range of the electromagnetic spectrum. See Appenc for a
chart showing this spectrum.

What the Commission learned early on in its work is that you cannot talk about
5G without talking about the earlier generations 3G and 4G. Then the Commission
embraced the concept of the Internet of Things (loT) which is a world in which all
electronic devices communicate via electromagnetic waves. This led to discussion
of routers and other internal technologies. The devices receiving and sending
signals via electromagnetic waves also became part of the discussion. So as the
presentations and discussions went on, the Commission concluded that all things
emitting radio frequency (RF) radiation needed to be considered together
because of the interaction of all these waves. We also discovered early on that 5G
means something different to each of the major cellular companies ranging from
how 5G antennae interact with other generation antennae to whether small cell
towers in the public right-of-way will be needed. The conclusion by many experts
is that 5G is a marketing concept centered around speed of data transmission
using many different engineering strategies.

At the heart of the discussion was the research as to whether non-ionizing
radiation causes biological effects on humans as well as other living organisms,
either animal or plant. No one argues that ionizing radiation from the high energy
and frequency ultraviolet, x-ray, and gamma ray end of the electromagnetic
spectrum are a danger to all living things. Of concern to the Commission, and
internationally, are the electromagnetic waves in the microwave range of energy
and frequency. There is mounting evidence that DNA damage can occur from

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radiation outside of the ionizing part of the spectrum.1,2'3' 4 The Commission
heard arguments on both sides of this issue with many now saying there are
findings showing biological effects in this range. This argument gets amplified as
millimeter waves within the microwave range are beginning to be utilized.

Then the Commission was presented with varying facts about the Federal
Communication Commission (FCC) having total say over this issue as granted to it
by Congress in the Telecommunication Act of 1996. In brief, this Act says, among
many other things, that the siting of any antennae cannot be denied due to health
concerns. Many on the Commission are concerned that this Act did not
contemplate small cell towers being located on the public rights-of-way in front of
people's homes. In addition, the FCC, using the science that they receive from
other agencies and scientific/engineering associations, has set the allowable
power intensity that can be emitted from these antennae. Testimony shows these
limits are set well above many other industrialized nations. There are concerns by
many Washington, DC watchers that the FCC is a captive agency whose
Commission members come from the industry they are overseeing. These are the
realities that can only be altered by Congressional action. As a New Hampshire
Commission, as we moved through the Commission process, many of the
members concluded we could first encourage our federal delegation to enact
changes and second, assuming the federal realities cannot be changed,
recommend protective measures that will stay within the current federal
framework.

As far as the FCC and federal agencies, we made several attempts to have them
testify before the Commission. The Commission was disappointed that they did
not reply to these requests, because we thought it important for completeness of
our work to hear from these agencies. When the agencies did not reply, we asked
several agencies to answer very specific written questions. Instead of answering

1	Aitken RJ, Bennetts LE, Sawyer D, Wiklendt AM, King BV. "Impact of radio frequency electromagnetic radiation on
DNA integrity in the male germline." InterJAndrol 28:171-179, 2005, https://pubmed.ncbi.nlm.nih.gov/15910543/

2	Akdag MZ, Dasdag S, Canturk F, Karabulut D, Caner Y, Adalier N. "Does prolonged radiofrequency radiation
emitted from Wi-Fi devices induce in various tissues of rats?" J Chem Neuroanat, 75(Pt B):116-122, 2016,

https://pybirTiedl.ncbi.nlirn.niilh.gov/26775760/.

3	Akdag M, Dasdag S, Canturk F, Akdag MZ. "Exposure to non-ionizing electromagnetic fields emitted from mobile
phones induced DNA damage in human ear canal hair follicle cells." Electromagn Biol Med. 37(2):66-75, 2018.

4	Al-Serori H, Ferk F, Kundi M, Bileck A, Gerner C, Misik M, Nersesyan A, Waldherr M, Murbach M, Lah TT, Herold-
Mende C, Collins AR, Knasmiiller S. "Mobile phone specific electromagnetic fields induce transient DNA damage
and nucleotide excision repair in serum-deprived human glioblastoma cells." PLoS One. 13(4):e0193677, 2018.

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our specific questions, the responses directed Commission members to certain
locations on websites for what turned out to be more general information on
topics of public interest. The communications with these agencies are contained

in Append

Summary of Commission Meetings

The Commission met a total of 13 times over a period from September 2019 to
October 2020. Unfortunately, due to the Covid-19 pandemic, all activity at the NH
State House came to a halt from mid-March to mid-June this year. This meant
that the Commission missed four meetings and thus heard from fewer experts on
this topic than planned. It is important to stress that the Chair was planning to call
additional witnesses from the scientific community as well as the
telecommunication industry. When we resumed meeting, starting with one on
July 1, all remaining meetings were conducted via Zoom. After our July 24th
meeting, a work group consisting of seven members was formed to start
formulating recommendations for the full Commission to consider. This work
group met approximately every other week through the finalization of this report
at the end of October. The table below summarizes the full Commission meeting
dates and who the main speakers were.

I lllll III MlWil ll II

1

9/16/19

Organizational meeting

2

10/10/19

Electromagnetic Spectrum Physics Presentation

Dr. Kent Chamberlin, Chair of UNH Electrical and Computer Engineering
Department

Presentation on Biological Effects of RF radiation

Dr. Paul Heroux, Professor of Toxicology, McGill University

3

10/31/19

National Toxicology Program Study on RF-Radiation
Michael Wyde, PhD

Framing the Issue Video

Frank Clegg, Former Microsoft Canada President

4

11/21/19

Non-Existence of RF-Radiation Biological Effects Argument
Eric Swanson, PhD, University of Pittsburgh.

5

12/13/19

Reinventing Wires and 5G in Colorado

Tim Schoechle, PhD, Colorado State University

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6

1/10/20

Studies Showing RF-Radiation Biological Effects

Devra Davis, PhD, MPH, Founder/President Environmental Health Trust
(EHT)

The Landscape Nationally and Internationally Surrounding RF-Radiation,
Theodora Scarato, Executive Director EHT

7

2/14/20

What is 5G and What Do We Know About the Health Effects of 5G
David Carpenter, MD, Director, Institute for Health and the Environment,
University of Albany

COVID-19 NH STATE HOUSE CLOSURE

8

7/1/20

13 Objections To 5G/4G

Herman Kelting, PhD, Retired Las Vegas, NV

9

7/24/20

Around the table discussion of where we are and next steps. Established a
work group to formulate recommendations.

10

8/31/20

Presentation of work group recommendations and discussion. Discussed
that a minority report would be required.

11

9/22/20

Discussion and voting on first half of recommendations

12

10/8/20

Discussion and voting on second half of recommendations

13

10/27/20

Review and vote on final report.

There are extensive minutes of all of these meetings that are included at the end
of this report in Appendix O. In addition, the Commission has maintained a
webpage on which is posted the various documents and links to information that
it has collected during the course of its study, including many of the presentations
provided during the meetings.

Questions Posed in HB 522

There were eight questions asked in the legislation creating the Commission.
Research by the Commission has resulted in lengthy answers with supporting
credits. With that we are showing the questions asked in the body of this report
only, with the answer to each question shown in	. The questions are as

follows:

1.	Why does the insurance industry recognize wireless radiation as a leading
risk and has placed exclusions in their policies not covering damages by the
pathological properties of electromagnetic radiation?

2.	Why do cell phone manufacturers have in the legal section within the
device saying keep the phone at least 5mm from the body?

3.	Why have 1,000s of peer-reviewed studies, including the recently published
U.S Toxicology Program 16-year $30 million study, that are showing a wide

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range of statistically significant DNA damage, brain and heart tumors,
infertility, and so many other ailments, been ignored by the Federal
Communication Commission (FCC)?

4.	Why are the FCC-sanctioned guidelines for public exposure to wireless
radiation based only on the thermal effect on the temperature of the skin
and do not account for the non-thermal, non-ionizing, biological effects of
wireless radiation?

5.	Why are the FCC radiofrequency exposure limits set for the United States
100 times higher than countries like Russia, China, Italy, Switzerland, and
most of Eastern Europe?

6.	Why did the World Health Organization (WHO) signify that wireless
radiation is a Group B Possibly Carcinogenic to Humans category, a group
that includes lead, thalidomide, and others, and why are some experts who
sat on the Who committee in 2011 now calling for it to be placed in the
Group 1, which are known carcinogens, and why is such information being
ignored by the FCC?

7.	Why have more than 220 of the world's leading scientists signed an appeal
to the WHO and the United Nations to protect public health from wireless
radiation and nothing has been done?

8.	Why have the cumulative biological damaging effects of ever-growing
numbers of pulse signals riding on the electromagnetic sine waves not been
explored, especially as the world embraces the Internet of Things, meaning
all devices being connected by electromagnetic waves, and the exploration
of the number of such pulse signals that will be created by implementation
of 5G technology?

The answers to these questions have been embraced by the majority of the
members of the Commission.

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SUMMARY AND OBSERVATIONS

House Bill 522 established "a Commission to study the environmental and health
effects of evolving 5G technology." The Commission that was convened as a result
of this legislation is comprised of thirteen members with backgrounds that
include physics, engineering electromagnetics, epidemiology, biostatistics,
occupational health, toxicology, medicine, public health policy, business, and law.
The Commission also has representation from the telecommunications industry.
The Commission began its work on September 16, 2019 and submitted this report
on November 1, 2020.

The Commission recognizes that cellular and wireless communications is very
important to the citizens of New Hampshire. The rollout of wireless services and
new products in the industry can be key to enhancing public safety, economic
opportunity, and healthcare. Regardless of the evidence presented and the risks
associated with RF electromagnetic field effects, business and residents alike
want 100% coverage and seamless connectivity. The majority of the Commission
believes that some balance can be struck to achieve the benefits of technology
without jeopardizing the health of our citizens.

To become acquainted with the issues relevant to 5G radiation exposure and
health, the Commission heard from ten recognized experts in the fields of physics,
epidemiology, toxicology, and public policy. All but the presenter representing the
Telecommunications Industry (the transcript of that presentation can be found in
the Commission's minutes of Nov 21st) acknowledged the large body of peer-
reviewed research that shows that the type of RF-radiation generated by wireless
devices can have a deleterious effect on humans, especially children, as well as
animals, insects, and vegetation (see Appendix id).

The Commission was unable to meet for four months due to the shutdown of the
NH State House caused by COVID-19. While this loss of time did limit the number
of presenters that could be accommodated, the majority of the Commission did
not believe that additional presenters were necessary because the information
provided by the ten experts was deemed sufficient.

5G is moving forward because of its potential benefits and because of assurances
by federal regulatory agencies that 5G technology is not harmful. However, those

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assurances have themselves come into question because of the thousands of
peer-reviewed studies documenting deleterious health effects associated with
cellphone radiation exposure. Most of the federal regulatory agencies' radiation
exposure limits were established in the mid-1990s before the studies were carried
out, so they did not take those studies into account when setting exposure limits.
In addition, the initial exposure limits were developed at a time before wireless
devices, and the radiation associated with them, became ubiquitous. Not only are
wireless devices far more prevalent than in the past, but these radiating devices
are typically carried in direct, or near direct, contact with peoples' bodies.

Further, the total radiation exposure for individuals is compounded by the
radiation from nearby sources, including others' devices, cell towers, wireless
routers, Bluetooth devices, etc. Because of the large number of radiating devices
in today's environments, exposure for people is many times greater than when
radiation thresholds were established, and the nature of today's radiation (high-
data-rate signals) has been shown to be more harmful than the lower-data-rate
signals that were prevalent before.

The significant disconnect between the regulatory agencies' pronouncements
that cellphone radiation is safe and the findings of thousands of scientific studies
was one of the major issues that the Commission sought to address. The
Commission is not alone in wrestling with this issue as many others (see
Appendix E) have challenged the radiation thresholds specified. It is to be noted
that the only country with higher radiation thresholds than the U.S. is Japan (see
Appendix F), and a large number of independent scientists have concluded that
the thresholds for Japan and the U.S. are unsafe.

A likely explanation as to why regulatory agencies have opted to ignore the body
of scientific evidence demonstrating the negative impact of cellphone radiation is
that those agencies are "captured" (see Harvard University publication entitled,
"Captured Agency: How the Federal Communications Commission Is Dominated
by the Industries It Presumably Regulates" linked in Appeinc ). This report
documents how the leadership roles in some agencies (the FCC in particular) are
filled by individuals with strong industry ties and hence are more focused on
industry interests than the health of citizens. As is shown in other sections of this
report, federal legislation uses policy set by the regulatory agencies to wrest
control of wireless facility placement from individuals, cities, and states.
Consequently, some of the Commission's recommendations call for a

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reassessment of the makeup and policies of federal regulatory agencies.

Current policies in place by federal regulatory agencies (such as section 704 of the
Telecommunications Act of 1996) are tailored to prevent local objections to cell
tower siting that are based upon health or environmental concerns, and this
leaves citizens with little legal recourse regarding equipment placement.

Industry projects that over 800,000 small cell towers5 will be necessary to
implement 5G. Many are being erected in the public rights-of-way in New
Hampshire neighborhoods and mounted on new poles, streetlights, and utility
poles directly in front of homes. However, because of the rules currently in place,
individuals and municipalities cannot use health or environmental concerns as a
reason to object.

The majority of the Commission has endorsed the 15 recommendations
presented in this report. These recommendations are not in prioritized order,
and each should be given equal consideration. The objective of those
recommendations is to bring about greater awareness of cell phone, wireless and
5G radiation health effects and to provide guidance to officials on steps and
policies that can reduce public exposure. We also recommend partnering with our
federal delegation to facilitate the reevaluation of radiation exposure guidelines
and policies by federal agencies (i.e., the FCC, FDA, NASA, NOAA, FAA, EPA, etc.)
to protect people, wildlife, and the environment from harmful levels of radiation.

Since the Commission could not reach full agreement on all that is contained in
this report, the minority of the Commission has been given the opportunity to
express its opinion as provided in the Minority Report.

5 The number of projected cell towers for 5G was taken from the CTIA website: "There are 154,000 cell towers
today. To meet growing mobile data demands and win the Race to 5G Accenture projects we will need to install
hundreds of thousands of small cells in the next few years. S&P Global Market Intelligence projects more than
800,000 small cells deployed by 2026."

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RECOMMENDATIONS

The Commission has heard from many experts on both sides of the argument
concerning the health and environmental effects of 5G and RF-radiation in
general; reviewed countless study reports; attempted to get direct answers to our
specific questions from the FCC and other federal agencies to no avail; has
become aware of a number of lawsuits against the FCC for not accounting for
biological effects in the setting of their standards; is still not certain why the
standards for acceptable RF-radiation are set so much higher in the United States
than other industrialized nations; is concerned that the modulation of frequencies
and the combined effect of "the soup" of RF-waves surrounding us today, which
will likely increase with time; is aware that there is much research showing
potential health risks and understands that much more research is required; is
cognizant that our country historically has been beset by examples of products
being declared safe only later to be proven unsafe; and is very aware that the
World Health Organization and the whole insurance industry are hedging their
bets against RF-radiation because of potential harm. Given these considerations,
the majority of the Commission yields to the precautionary principle in
formulating many of these recommendations. These recommendations cover a
broad range of topics. One topic given much consideration had to do with liability
from potential harm caused by small cell antennae placed on the public rights-of-
way. A majority of the Commission could not agree upon a recommendation
surrounding this topic.

RECOMMENDATION 1- Propose a resolution of the House to the US Congress
and Executive Branch to require the Federal Communication Commission (FCC)
to commission an independent review of the current radiofrequency (RF)
standards of the electromagnetic radiation in the 300MHz to 300GHz microwave
spectrum as well as a health study to assess and recommend mitigation for the
health risks associated with the use of cellular communications and data
transmittal. The Telecommunications Act of 1996 was adopted before the health
risks and biological effects of RF-radiation to the human body were fully known to
the scientific community as well as the public. The majority of the Commission
believes that the FCC has not exercised due diligence in its mission to manage the
electromagnetic environment by not setting exposure limits that protect against
health effects. They have failed to support technical means and investigations
aimed at reducing human exposures to electromagnetic radiation (EMR) in

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telecommunications systems and optimize wireless modulations to reduce
biological and health impacts. Commissioned research should study the health
effects and should be conducted by an independent research organization with
standards which have been mutually agreed to by all the stakeholders. The FCC
shall then ensure that the findings and recommendations are adequately
disseminated to the public.

RECOMMENDATION 2- Require that the most appropriate agency (agencies) of
the State of New Hampshire include links on its (their) website(s) that contain
information and warnings about RF-radiation from all sources, but specifically
from 5G small cells deployed on public rights-of-way as well as showing the
proper use of cell phones to minimize exposure to RF-radiation, with adequate
funding granted by the Legislature. In addition, public service announcements
on radio, television, print media, and internet should periodically appear,
warning of the health risks associated with radiation exposure. Of significant
importance are warnings concerning the newborn and young as well as
pregnant women. Even without further study, there is evidence that the public
should be warned of the potential dangers of RF-radiation and be told simple
steps to lessen the risks of unnecessary exposure. Appendi: shows an example
of a simple RF-radiation warning.

The website must provide an option for visitors to register their opinions about
current FCC exposure guidelines. In particular, this registry should provide a
convenient and formal mechanism for New Hampshire municipalities and
residents to weigh in concerning the 1996 Telecommunications Act Section 704
that disallows using radiation-related health concerns as a reason to challenge cell
phone tower siting. The primary use for the data collected on this registry will be
to gauge the level of interest about RF-radiation exposure on the part of New
Hampshire citizens.

RECOMMENDATION 3- Require every pole or other structure in the public rights-
of-way that holds a 5G antenna be labeled indicating RF-radiation being
emitted above. This label should be at eye level and legible from nine feet away.

In the view of the Commission, the State of New Hampshire has the right to warn
the public of potential harm of 5G antennae deployed in the public rights-of-way.
Large cell towers all currently have fencing around them at their base to protect
the public. This will not be the case with small cell towers or any pole with an

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antenna on top in the public right-of-way. These public rights-of-way are the
jurisdiction of our municipalities and not of the Federal Government. The
Telecommunication Act of 1996 did not contemplate antennae being placed on
the public rights-of way of municipalities. Thus, the State of New Hampshire has
the right to warn the public by requiring the owners of these antennae to inform
the public of potential harm from RF-radiation. See Appeine for an example
symbol.

RECOMMENDATION 4- Schools and public libraries should migrate from RF
wireless connections for computers, laptops, pads, and other devices, to hard-
wired or optical connections within a five-year period starting when funding
becomes available. There is strong evidence that the younger the child the more
susceptible they are to the negative impacts of RF-radiation. Hard-wired
connections or optical wireless do not subject children to RF-radiation. The
Commission is aware that school districts and public libraries have invested much
in wireless infrastructure and that a movement to radiation-less connections
would require additional investment of resources.

New optical networking solutions for the classroom and office spaces (such as
LiFi) offer faster, healthier, and more secure connections than RF-based WiFi. This
technology utilizes visible light, which organisms can withstand without any harm
at far higher intensity levels (such as direct sunlight) than is required for data
transmission. Such optical data transmission using visible light offers gigabit
speed, as well as plug-and-play replacement of current RF WiFi routers. The
optical wireless system can be incorporated in an upgrade to cost-efficient LED
room lighting which can save schools and public libraries significant energy
dollars.

The hard-wiring and/or optical projects should be completed within five years
from when the federal funding (e.g., through the FCC's E-Rate program for
telecommunications and IT in schools and public libraries) is procured.

RECOMMENDATION 5- Signal strength measurements must be collected at all
wireless facilities as part of the commissioning process and as mandated by
state or municipal ordinances. Measurements are also to be collected when
changes are made to the system that might affect its radiation, such as changes
in the software controlling it. Signal strength is to be assessed under worst-case

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conditions in regions surrounding the tower that either are occupied or are
accessible to the public, and the results of the data collection effort is to be
made available to the public via a website. In the event that the measured
power for a wireless facility exceeds radiation thresholds, the municipality is
empowered to immediately have the facility taken offline. The measurements
are to be carried out by an independent contractor and the cost of the
measurements will be borne by the site installer. It is recognized that theoretical
calculations show that existing FCC guidelines will be met by standard cell tower
configurations. However, there are cases where the radiation from towers can be
focused by buildings, terrain, and beamforming antennas, causing signal levels to
be considerably higher than would be expected in theoretical calculations unless
those effects are taken into account. Collecting field measurements provide the
only valid approach for determining whether exposure guidelines have been met.
It is to be noted that some municipalities (e.g., the town of Burlington, MA [1])
have ordinances requiring measurements at cell towers.

Federal law and NH law grant to municipalities the power to enact zoning rules
regulating the placement of personal wireless service facilities within the
geographic boundaries of the municipalities. Municipalities should be proactive in
this area and, through the exercise of zoning power, establish where, how, and a
process for compliance with existing FCC guidelines for signal strength in the
surrounding coverage area. Municipalities should establish a hierarchy of siting
values and compliance acknowledgements so that the siting most favored by the
municipality is the easiest siting for the wireless applicant to obtain and,
conversely, the siting which is least desirable should be the most difficult siting for
the applicant to obtain. The zoning ordinance should lay out the compliance
requirement as part of the zoning approval.

[1] Burlington, MA zoning Bylaw Wireless Facilities section 8.4.6.2 - "Annual RF
emissions monitoring is required for all sites by an independent RF engineer to be
hired with Planning Board approval and at the applicant's expense. Test results
will be submitted to the Town as soon as available, and not later than the close of
the calendar year. Annual testing of electromagnetic emission shall be required to
ensure continual compliance with the FCC regulations."

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Recommendation 6- Establish new protocols for performing signal strength
measurements in areas around wireless facilities to better evaluate signal
characteristics known to be deleterious to human health as has been
documented through peer-reviewed research efforts. Those new protocols are to
take into account the impulsive nature of high-data-rate radiation that a
growing body of evidence shows as having a significantly greater negative
impact on human health than does continuous radiation. The protocols will also
enable the summative effects of multiple radiation sources to be measured.
Contemporary approaches to performing signal level measurements do not
provide a means to evaluate signal impulsiveness or the contribution of multiple
radiation sources because of equipment limitations. The measurement protocols
proposed will employ wideband equipment that is currently available but is not
typically used to measure compliance with radiation safety limits. References that
address the deleterious effects of impulsive radiation on organisms are given in
Appenc . The development of the proposed protocols should be funded by the
appropriate federal agency (e.g., NSF, NIH, FCC, etc.) and should be facilitated by
New Hampshire's federal delegation.

RECOMMENDATION 7- Require that any new wireless antennae located on a
state or municipal right-of-way or on private property be set back from
residences, businesses, and schools. This should be enforceable by the
municipality during the permitting process unless the owners of residences,
businesses, or school districts waive this restriction. Local public rights-of-way
are under the jurisdiction of municipalities, and the Commission feels that
municipalities should uphold the rights of individuals impacted by antennae. The
Commission also supports the right of property owners to manage decisions on
non-essential devices being placed in front of their property.

The Commission believes that it is important to prioritize citizen safety,
particularly as 5G is an upgrade, rather than the provision of wireless service to
unserved areas. Additional rationale for this recommendation is shown in

Appendix IK.

RECOMMENDATION 8- Upgrade the educational offerings by the NH Office of
Professional Licensure and Certification (OPLC) for home inspectors to include RF
intensity measurements. Home inspectors currently operate as private
contractors who may be hired by citizens or enterprises to measure such things as

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radon, to collect water quality samples, or search for mold or insect damage.
Home inspectors routinely supply test results to both their clients and
government entities.

The majority of the Commission believes the public has the right to discover, on a
voluntary basis, the RF power intensity related to radio frequencies at a property
which they will be purchasing or renting before the transaction is closed. Also, the
proprietors of publicly accessible venues may wish to reassure the public about
the RF power intensity within their establishments, by posting the data collected
by a state-approved inspector. In addition, such testing should be paid for by the
party requesting it and the testing itself should be performed by a professional
who owns or rents the test equipment and has met the state requirements for
training of home inspectors regarding RF measurements.

The majority of the Commission proposes that home inspectors be offered
training by NH OPLC on how to measure on-site peak and 24-hour average RF
intensities. Measurements of frequencies and intensities will be performed using
low-cost equipment (such as GQ-390 meters). [Description of existing home
inspector training offered for radon, mold, etc. may be seen at
hup , ฆ ฆ i'lc.nh.gov/home~inspectors/index.htm1

RECOMMENDATION 9- The State of New Hampshire should begin an effort to
measure RF intensities within frequency ranges throughout the state, with the
aim of developing and refining a continually updated map of RF exposure levels
across the state using data submitted by state-trained home inspectors. The

data should be collected in such a way as to identify geographic areas of notably
high RF exposure, places where RF signal for wireless communication is
inadequate (dead spots), and places where RF is unusually low (white spots)
sought by people who wish to minimize their RF exposure. One possible use of
this data will be buyers/renters of property or the public, in general, using
benchmark values to make comparisons and make their own decisions based on
their comfort level with RF exposure. After a while, an extensive New Hampshire
RF database will exist to provide useful maps and data for future public health
investigations. Append outlines in more detail the technical aspects of this
recommendation.

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RECOMMENDATION 10- Strongly recommend all new cell phones and all other
wireless devices sold come equipped with updated software that can stop the
phone from radiating when positioned against the body. The Commission has
been made aware that cell phones contain proximity sensors that will allow a cell
phone to only radiate signals when a certain distance from the body, for example,
held in the fingers or placed on a table. This does not change the functionality of
the device, only the way it is used, specifically not held against the head or body.
Implementation is a software update in the cell phone, as these phones already
have a proximity detector to turn off the screen and soft keys when an obstacle is
present. With this change, the screen and the RF circuit are automatically turned
off. This removes the problems of brain cancers (glioblastomas and acoustic
neuromas) and the issue of SAR limits for the industry. See pendix M for more
detailed references to the science behind this recommendation. Cell phones
should come set with this inhibition, with instructions in the manual on how to
disable it. There should be a soft button on the unit to easily re-enable the
radiation inhibition, for example if the unit is handed to a child. In all cases, it
should be easier to enable the restriction than to disable it. Cellular phones
marketed specifically for children should stop radiating when positioned against
the body under all circumstances. The installation of such proximity sensors is also
encouraged in laptops and tablets.

RECOMMENDATION 11- Promote and adopt a statewide position that would
strongly encourage moving forward with the deployment of fiber optic cable
connectivity, internal wired connections, and optical wireless to serve all
commercial and public properties statewide. The majority of the Commission
believes that fiber optic transmission is the infrastructure of the future. When
compared, RF wireless transmission lacks fiber optic characteristics: speed,
security, and signal reliability while avoiding biological effects on humans and the
environment.

The State should encourage partnerships between towns to make this happen
and encourage our federal delegation to support grant money to assist with such
deployments when it comes to funding fiber optic cable deployment, especially in
rural locations.

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RECOMMENDATION 12- Further basic science studies are needed in conjunction
with the medical community outlining the characteristics of expressed clinical
symptoms related to radio frequency radiation exposure. Further studies are just
beginning to explore the quantum mechanical mechanisms which are the
fundamental basis for understanding the biological changes occurring during the
interaction of radio frequency radiation and molecules. These mechanisms can
affect cells, tissues, and whole organs, as well as accumulate over time.

The majority of the Commission feels the medical community is in the ideal
position to clarify the clinical presentation of symptoms precipitated by the
exposure to radio frequency radiation consistent with the Americans with
Disabilities Act (ADA) which identifies such a disability. The medical community
can also help delineate appropriate protections and protocols for affected
individuals.

All of these endeavors (basic science, clinical assessment, epidemiological studies)
must be completely independent and outside of commercial influence.

RECOMMENDATION 13- Recommend the use of exposure warning signs to be
posted in commercial and public buildings. In addition, encourage commercial
and public buildings, especially healthcare facilities, to establish RF-radiation
free zones where employees and visitors can seek refuge from the effects of
wireless RF emissions. Many NH citizens report sensitivity to electromagnetic
radiation emitted from devices used in the delivery of in-building cellular and
fixed wireless services. A majority of the Commission suggests that owners of
commercial and public buildings, especially healthcare facilities, voluntarily place
signage at entrances concerning RF-levels and RF-free zones within these
structures so those entering the building are aware.

RECOMMENDATION 14- The State of New Hampshire should engage agencies
with appropriate scientific expertise, including ecological knowledge, to develop
RF-radiation safety limits that will protect the trees, plants, birds, insects, and
pollinators. The majority of the Commission understands that current federal
safety limits were made with the intention of only protecting humans from short
term effects, but not protecting flora or fauna from harm. The State of New
Hampshire needs to ensure our natural environment and wildlife are protected by
effective safety standards. Tree limbs, birds, and pollinators will be closer than

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humans to 5G cell antennae and associated 4G densified infrastructure. In fact,
the wireless radiation from cell antennae is very high in a plume surrounding the
antennae. It could exceed FCC limits for several feet in this area, yet this is the
exact area where leaves of trees, birds, and pollinators live. Thus, they may have
higher exposures being in direct line of sight of wireless RF beams. When
pollinators are impacted so are all forms of vegetation that depend on them for
reproduction. Research on this issue is shown in Appendix IN.

RECOMMENDATION 15- The State of New Hampshire should engage our Federal
Delegation to legislate that under the National Environmental Policy Act (NEPA)
the FCC do an environmental impact statement as to the effect on New
Hampshire and the country as a whole from the expansion of RF wireless
technologies. Concern comes from the FCC projection that there will be
numerous low orbit satellites and 5G small cell antennae, plus many additional
macro towers required for these networks to function. The majority of the
Commission is concerned that any new large-scale project that will densify
antennae networks to this extent truly requires an environmental impact study.
The NEPA statute requires that the agency consider environmental concerns in its
decision-making process. NH should be provided documentation of such
considerations. Until there is Federal action, NH should take the initiative to
protect its environment.

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MINORITY REPORT

The following members, being unable to agree with the majority

of the Commission, endorse this Minority Report:

Senator James Gray, David Juvet, and Bethanne Cooley

Contrary to the position taken in the Recommendations section, the science
related to radiofrequencies, wireless devices, and health is well studied and well
known: The consensus of the U.S. and international scientific community is that
there are no known adverse health risks from the levels of RF energy emitted at
the frequencies used by wireless devices (including cellphones) and facilities
(including small cells). Some of those who presented to the NH 5G Commission
have sought to sow confusion, but the facts demonstrate otherwise.6 First, when
setting limits for the RF emissions of wireless devices, the Federal
Communications Commission ("FCC") intentionally provided a significant safety
margin—50 times below the threshold at which adverse effects have been
observed in laboratory animals.7 And in its 2019 order, the FCC assessed the
available science, including studies related to the safety of 5G networks, and
based on the relevant scientific research, concluded that wireless devices and
small cells are safe when they adhere to the FCC's current RF exposure limits, as
required by law. Second, numerous, independent analyses of peer-reviewed
studies conducted over several decades by national and international
organizations conclude that there are no known health risks to humans from RF

6	Commission discussions indicated that the Commission was comprised of many individuals who had
preconceived opinions about the safety of RF devices and wireless technology in general. Due to many factors,
experts in favor of wireless technology were cut short in participating. For example, an additional expert in favor of
wireless technology was offered as a speaker during the summer and the Commission indicated no additional
experts would be permitted. However, after that request was denied, an "expert" opposed to RF devices and
wireless technology spoke at a subcommittee meeting of the majority. In addition, the Commission heard only a
portion of expert Eric Swanson's testimony and failed to consider in a balanced fashion the well-developed reviews
of the science from the U.S. and international health and safety organizations. Thus, in this report we have cited
those authorities even though the Commission did not include them as part of the formal record.

7	The threshold for adverse effects was set at the level at which heating caused a "disruption of observable
behavior" in animals. See Proposed Changes in the Commission's Rules Regarding Human Exposure to Radiofrequency
Electromagnetic Fields, First Report and Order, Further Notice of Proposed Rulemaking, and Notice of Inquiry, 28
FCC Red. 3498, 3582 H 236 (2013) ("FCC NOI") ("exposure limits are set at a level on the order of 50 times below
the level at which adverse biological effects have been observed in laboratory animals as a result of tissue heating
resulting from RF exposure"); IEEE Standard for Safety Levels with Respect to Human Exposure to Electric,

Magnetic, and Electromagnetic Fields, 0 Hz to 300 GHz, IEEE Std C95.1-2019, Annex B Sec. B.5.3.3 and Annex C Sec.
C.2.1 (2019) ("Typically, the effect observed has been a decreased rate of responding or decreased reaction
time.").

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energy emitted by wireless devices and infrastructure. Thus, the scientific
consensus as evaluated by experts, international standard-setting bodies, and
federal health and safety agencies is that wireless devices and base stations at the
FCC's RF exposure levels is safe.

Given the scientific consensus, it is our opinion that the Recommendations exceed
what a reasonable response should be to the evidence on this issue. This Minority
Report purposely chose not to highlight each recommendation but instead
highlights findings from federal agencies, including the FCC and the Food and
Drug Administration (FDA), studies conducted by leading international and
national health organizations, the IEEE and the scientific community at-large. It
will also note the federal preemption issues associated with the
Recommendations. Given the scientific consensus, it is our opinion that the
Recommendations have no basis in scientific fact, are irresponsible, and will
subject the state and any localities implementing these Recommendations to
needless and expensive challenges that will drain time and resources from more
important and credible priorities.

THE FCC SAFETY REGULATIONS

FCC limits govern RF energy from antennas used in all wireless devices including
cellular transmissions from cellphones, cell towers, and 5G small cells. The FCC
based these limits on recommendations from the scientific community and expert
non-government organizations; the FCC limits currently cover frequencies from
100 kHz to 100 GHz, including the "millimeter wave" or "mmW" frequencies.8
These guidelines—based on internationally-recognized scientific organizations-
set limits for the maximum amount of RF exposure from wireless devices and
include a significant margin of safety.9 Specifically, the FCC has set its limit for a
consumer device's Specific Absorption Rate—the measurement for RF emissions
for consumer devices such as cellphones—"at a level on the order of 50 times
below the level at which adverse biological effects have been observed in
laboratory animals."10 The agency explained that this 50-fold factor can well

8	NPRM, 34 FCC Red at 11742 H 120.

9	Testimony of Christopher C. Davis, Professor of Electrical and Computer Engineering, University of Maryland,
Hearing on S.B. 637 and S.B. 894 Before the Mich. H. Comm. on Energy Policy, 2018 Leg., 99th Sess., at 4:17 (May
29, 2018) ("Professor Davis Testimony"),

http:://www. hou se.imii.gov/Slhairedyiideo/PllayViideoAirchiive. html?video=ENER-052918-2.mp4.

10	FCC NOI at H236 (emphasis added).

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accommodate a variety of variables such as different physical characteristics and
individual sensitivities—and even the potential for exposures to occur in excess of
[FCC] limits without posing a health hazard to humans."11 In reality, wireless
devices and antennas typically operate well under FCC thresholds.12

Further, all wireless devices sold in the U.S. must go through a rigorous approval
process to ensure they meet the science-based guidelines set by the FCC.13 The
FCC's testing regime requires cellphones to be tested under "the most severe,
worst-case (and highest power) operating conditions for all the frequency bands
used in the USA for that cell phone" to ensure that they meet the limits under
everyday (non-worst-case) conditions.14 The FDA stands in full support of the
adequacy of the FCC's standards. The Director of the FDA's Center for Devices and
Radiological Health wrote in 2018: "[B]ased on our ongoing evaluation of this
issue and taking into account all available scientific evidence we have received,
we have not found sufficient evidence that there are adverse health effects in
humans caused by exposures at or under the current radiofrequency energy
exposure limits."15

HEALTH ORGANIZATIONS AND FDA STUDIES

International health organizations have also studied the effects of RF exposure
and determined that there is no risk from RF emissions from modern wireless
device usage. The World Health Organization ("WHO") concludes "[considering
the very low exposure levels and research results collected to date, there is no

11	Id.; see also Targeted Changes to the Commission's Rules Regarding Human Exposure to Radiofrequency
Electromagnetic Fields, Resolution of Notice of Inquiry, Second Report and Order, Notice of Proposed Rulemaking,
and Memorandum Opinion and Order, 34 FCC Red 11687, 11696 H14 (2019) ("Order") ("[0]ur existing exposure
limits are set with a large safety margin, well below the threshold for unacceptable rises in human tissue
temperature.").

12	See Professor Davis Testimony (6:00-7:45) (discussing the 50-fold safety factor and typical emissions from small
cells); Christopher C. Davis, Professor of Electrical and Computer Engineering, University of Maryland, Hearing on
S.B. 637 and S.B. 894 Before the Mich. H. Comm. on Energy Policy, 2018 Leg., 99th Sess., Written Testimony at 2
(May 29, 2018), http://www.wirelesshealthfacts.com/wp-content/yploads/2019/06/Davis-Testimony.pdf
(observing that "RF exposure levels from wireless base stations are invariably far below the FCC limits").

13	See generally 47 C.F.R. ง 1.1307; id. part 2 Subpart J; Order, 34 FCC Red at 11697-742 HH 17-118.

14	FCC, Consumer Guides, Health, Safety and Emergencies, Specific Absorption Rate (SAR)for Cell Phones: What It
Means for You (emphasis in original), https://www.fcc.gov/consumers/guides/specific-absorption-rate-sar-cell-

phomes-what-it-means-you (last updated Oct. 15, 2019).

15	News Release, FDA, Statement from Jeffrey Shuren, M.D., J.D., director of the FDA's Center for Devices and
Radiological Health on the recent National Toxicology Program draft report on radiofrequency energy exposure
(Feb. 2, 2018) ("Shuren Statement"), https://www.fda.gov/news-events/press-announcements/statement-ieffrey-
shuren-md-id-director-fdas-center-devices-and-radiological-health-recent-national.

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convincing scientific evidence that the weak RF signals from base stations and
wireless networks cause adverse health effects."16 The WHO has also concluded
that "research has not been able to provide support for a causal relationship
between exposure to electromagnetic fields and self-reported symptoms, or
'electromagnetic hypersensitivity'".17 Likewise, both the United Kingdom Health
Protection Agency Independent Advisory Group on Non-Ionizing Radiation and
Swedish Council for Working Life and Social Research agree that RF exposure
below guideline levels consistent with FCC limits do not cause health effects.18

The majority also justifies its recommendations by referencing "the problems of
brain cancers (glioblastomas and acoustic neuromas) and the issue of specific
absorption rate (SAR) limits for the industry." Some have raised questions with
respect to cancer and tumors, but experts in cancer have repeatedly found no link
between mobile devices and cancer. For example, the National Cancer Institute
reported that: "although many studies have examined the potential health effects
of non-ionizing radiation from radar, microwave ovens, cell phones, and other
sources, there is currently no consistent evidence that non-ionizing radiation
increases cancer risk in humans."19 Likewise, the American Cancer Society
explained that the "RF waves given off by cell phone towers don't have enough
energy to damage DNA directly or to heat body tissues. Because of this, it's not
clear how cell phone towers might be able to cause cancer."20

Earlier this year, the FDA released a large-scale review of published literature to

16	WHO, Electromagnetic fields and public health: Base stations and wireless technologies, Backgrounder (May
2006), https://www.who.int/peh-emf/publications/facts/fs304/en/.

17	WHO, Electromagnetic fields and public health: mobile phones, Backgrounder (Oct. 8, 2014) ("WHO Mobile
Phones Fact Sheet"), https://www.who.int/news-room/fact-sheets/detail/electromagnetic-fields-and-public-

health-irnobiile- phones.

18	See Health Protection Agency Independent Advisory Group on Non-Ionizing Radiation, Health Effects from
Radiofrequency Electromagnetic Fields (RCE-20), at 3 (Apr. 2012),

https://webarchive.nationalarchives.gov.Uk/20140722075005/http://www.hpa.org.uk/webc/HPAwebFile/HPAweb
C/1,3171,3,332 ("The evidence suggests that RF field exposure below guideline levels does not cause acute
symptoms in humans, and that people, including those who report being sensitive to RF fields, cannot detect the
presence of RF fields."); Anders Ahlbom, et al., Radiofrequency Electromagnetic Fields and Risk of Disease and III
Health: Research during the last ten years, Swedish Council for Working Life and Social Research, at 6 (2012),
https://forte.Se/app/uploads/sjtes/2/2015/ll/10-v-rf-report.pdf ("Extensive research for more than a decade ...
has found no evidence for health risks below current exposure guidelines.").

19	National Cancer Institute, Cell Phones and Cancer Risk, (Jan. 9, 2019) https://www.cancer.gov/about-
cancer/causes-prevention/risk/radiation/cell-phones-fact-sheet.

20	American Cancer Society, Cell Phone Towers (emphasis omitted) ("ACS Cell Phone Towers"),

https://www.canceir.oirg/canceir/canceir-cayses/iradliation-exposyire/cellylair-plhone-toweirs.lhtirnll (last visited
October 7, 2020).

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"assess any possible causal relationship between [RF energy] exposure and the
formation of tumors."21 After examining approximately 125 animal studies and 70
epidemiological studies, the FDA stated that "there are no quantifiable adverse
health effects in humans caused by exposures at or under the current cell phone
exposure limits."22 As Dr. Jeffrey Shuren, Director of the FDA's Center for Devices
and Radiological Health, observed in 2018: "Even with frequent daily use by the
vast majority of adults, we have not seen an increase in events like brain
tumors."23 Courts too, after hearing extensive testimony, have determined that
there is "no sufficiently reliable and relevant scientific evidence in support of
either general or specific causation" that cellphone use caused the plaintiffs brain
cancer.24 Dr. Otis Brawley, chief medical officer of the American Cancer Society,
explained that "[t]he incidence of brain tumors in human beings has been flat for
the last 40 years.... That is the absolute most important scientific fact."25

THE SCIENCE AROUND EXPOSURES FROM 5G TECHNOLOGY

The majority has expressed concern with exposures from 5G technology using
millimeter wave ("mmW") bands and on the proliferation of small cell network
architecture, and whether there are studies demonstrating that 5G does not
create risks to human health.

Although 5G represents a new frontier for wireless communications, mmW
frequencies do not. mmW frequencies are well understood by the international
scientific community. The Institute of Electrical and Electronics Engineers ("IEEE")
has assembled a list of dozens and dozens of studies on mmW frequencies. The
IEEE's RF exposure standards over the last thirty years have cited 85 different
mmW studies, the earliest was published in 1976 and the most recent in 2018.26

21	FDA, Review of Published Literature between 2008 and 2018 of Relevance to Radiofrequency Radiation and
Cancer, at 4 (Feb. 2020), https://www.fda.gov/media/135043/download.

22	Id. at 5.

23	Shuren Statement.

24	Newman v. Motorola, Inc., 218 F. Supp. 2d 769 (D. MD 2002), aff'd per curiam Newman v. Motorola, Inc., 78
Fed.Appx. 292 (4th Cir. 2003); see also Murray v. Motorola, Inc., Memorandum Opinion and Order on Expert
Witness Admissibility, Case No. 2002 CA 001371A (Aug. 8, 2014).

25	Lauran Neergaard & Seth Borenstein, Cross talk: Federal agencies clash on cellphone cancer risk, Associated
Press (Nov. 1, 2018), https://apnews.com/4da5flcdfd774af29143ff3f5ccffa0b; see also IEEE Std C95.1-2019 at 16
n.8 ('The preponderance of epidemiologic evidence does not provide a sufficient basis for concluding that adult
brain cancer is positively associated with mobile telephone use and, by implication, with RF exposures.").

26	CTIA, Resources, Millimeter Wave Studies Cited by IEEE, http.;//www.wirelesshealthfacts.com/wp-
content/uplloads/2020/01/Miilllliiirneteir-Wave-Studiies.pdf (last visited October 7, 2020).

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Common equipment such as "airport scanners, automotive collision avoidance
systems and perimeter surveillance radar security systems" all use mmW
technology.27

Acting responsibly, scientists and engineers continue to research RF exposure,
including RF exposure with 5G technology. IEEE's Committee on Man and
Radiation just completed a comprehensive review of 5G systems concluding that,
based on the evidence to date, "the likelihood of yet unknown health hazards at
exposure levels within current limits to be very low, if they exist at all."28 The
authors explained that "one can expect that exposures from 5G networks will not
differ greatly from those associated with present generation networks" because,
like "previous generations of cellular systems: [5G must] provide a signal that is
strong enough to be useful within a given cell but not so strong as to cause
interference to users in nearby cells."29 In other words, 5G base stations are
limited in their power because of the potential for those emissions to cause
interference with other base stations.

The American Cancer Society explained that "[w]hile [5G] RF waves are higher
frequency (higher energy) than those used by older generations, they are still
forms of non-ionizing radiation, so they still lack the ability to directly damage
DNA."30 Further, "these higher frequency RF waves are less able to penetrate the
body than lower frequency waves, so in theory they might be less likely to have
any potential health effects."31

5G will also take advantage of small cell network architecture, which results in
more base stations operating at lower power levels. A recent overview of
exposure from small cells determined that such "[f]ixed small cell wireless
communication installations ... that operate in compliance with the regulations of
the FCC will produce RF exposures well within the recommended exposure limits
of the FCC, ICNIRP [International Commission on Non-Ionizing Radiation
Protection], and IEEE."32 Further, "[r]esearch to date does not provide a reliable

27	Joan Conrow, Three reasons why 5G is unlikely to cause harm, Cornell Alliance for Science, (June 26, 2020),
https://allianceforscience.cornell.edu/blog/2020/06/three-reasons-whv-5g-is-unlikely-to-cause-harm/.

28	Id.

29	Id.

30	ACS Cell Phone Towers

31	Id.

32	William H. Bailey, Wireless 5G Radiofrequency Technology: An Overview of Small Cell Exposures, Standards and

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scientific basis to conclude that the operation of these facilities will cause or
contribute to adverse health effects in the population."33

In March 2020, ICNIRP released updated, modernized guidelines that expressly
cover the new frequencies that 5G will use. Announcing their release, ICNIRP
Chairman, Dr. Eric van Rongen, advised that "[t]he most important thing for
people to remember is that 5G technologies will not be able to cause harm when
these new guidelines are adhered to."34 The FCC's rules are also designed to
protect health and safety, and prevent harm. Indeed, the FCC notes that "the
possibility that a member of the general public could be exposed to RF levels in
excess of the FCC guidelines is extremely remote."35

FEDERAL PREEMPTION

The majority makes several recommendations related to mandated warnings,
labeling, compliance regulations, and zoning requirements based on health and
safety concerns. These recommendations are not warranted based on the science
discussed above, but are also not viable because federal law preempts state and
local action that conflicts with the FCC's determination that compliant devices
and equipment are safe. Congress determined that the FCC should be the
"central[] authority" for regulating communications in the U.S.36 This charge
includes the regulation of "the kind of apparatus to be used" for wireless radio
communications and "the emissions" that such equipment may produce.37 The
FCC promulgated its RF exposure rules to ensure that they protect human health
nationwide as technology evolves, relying on sound scientific research of
government and other expert organizations.

The FCC acted in its role as, in the words of the Supreme Court, the "exclusive"

Science, at 7, Exponent (Apr. 2020), http://www.wirelesshealthfacts.com/wp-content/uploads/2020/04/Bailey-5G-

Whitepapt	iO.pdf.

33	Id.

34	Media Release, International Commission on Non-Ionizing Radiation Protection, New Guidelines Released by the
International Commission on Non-Ionizing Radiation Protection (ICNIRP), at 2 (Mar. 11, 2020),

https://www.icniirp.oirg/cirTis/uploadl/piresentations/ICINIIRIP Media Release 110320.pdf.

35	FCC Consumer Guide, Human Exposure to Radio Frequency Fields: Guidelines for Cellular Antenna Sites, at 2
(Oct. 15. 2019), https://www.fcc.gov/sites/default/files/human exposure to radio frequency fields -

guidelines for cellular antenna siites.pdf.

36	47 U.S.C. ง 151.

37	Id. ง 303(e).

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arbiter in the "technical matters" of radio,38 which includes control for any
environmental effects, including, among other things, RF emissions.39 For
example, the FCC recognized that "very high levels of RF radiation can be harmful
due to the ability of RF energy to heat biological tissue rapidly."40 Accordingly, the
FCC's rules limit RF exposure to humans "from all transmitting facilities,
operations, and devices it regulates."41

By way of background, the FCC first adopted RF exposure rules in the 1980s and
has updated its rules in response to new scientific evidence.42 In 1996, Congress
reaffirmed the FCC's authority to set standards on RF emissions to provide
"adequate safeguards of the public health."43 The FCC updated its RF exposure
rules and relied on sound scientific research of government and other expert
organizations. In particular, the FCC synthesized "submissions from the
Environmental Protection Agency ("EPA"), the Food and Drug Administration
("FDA"), the Occupational Safety and Health Administration ("OSHA"), and the
National Institute for Occupational Safety and Health ("NIOSH")."44 Several courts
have examined and affirmed the FCC's process to develop its RF exposure limits.45
The Third Circuit observed that "the FCC is well positioned to solicit expert
opinions and marshal the scientific data to ensure its standards both protect the
public and provide for an efficient wireless network."46 And courts have
confirmed that the agency has done so. For example, the D.C. Circuit upheld the

38	Head v. New Mexico Bd. ofExam'rs in Optometry, 374 U.S. 424,430 n.6 (1963) (observing that the
"Commission's jurisdiction over technical matters ... is clearly exclusive").

39	Robbins v. New Cingular Wireless LLC, 854 F.3d 315, 319-20 (6th Cir. 2017) (noting that Congress "delegate[ed]
the task of setting RF emission levels to the FCC"). Of course, government entities can and have participated in the
notice-and-comment aspect of the FCC's rulemaking. See, e.g., City of Boston, Massachusetts, ET Docket No. 19-
226 (filed June 17, 2020).

40	FCC, RF Safety FAQ, What Biological Effects Can Be Caused By RF Energy?, https:://www.fee.gov/eirigiineeiriing-
technologv/electromagnetic-compatibilitv-division/radio-frequency-safetv/faq/rf-safetv#Q5 (last visited October 7,
2020).

41	Letter from Thomas M. Johnson, Jr., General Counsel, FCC, to Joseph H. Hunt, Assistant Attorney General, DOJ,
N.D. Cal. No. C 19-05322 WHA, at 3 (Apr. 13, 2020) (citing 47 C.F.R. งง 1.1307, 1.1310, 2.1091, 2.1093) (emphasis
added), https://docs.fcc.gov/public/attachments/DOC-363717Al.pdf.

42	Letter from Thomas M. Johnson, Jr. General Counsel, FCC, to Joseph H. Hunt, Assistant Attorney General, DOJ,
N.D. Cal. No. 3:15-cv-02529 EMC, at 3-5 (June 22, 2020) (examining the adoption and evolution of the
Commission's RF exposure rules).

43	Id. at 4-5 (quoting H.R. Rep. No. 204,104th Cong., 1st Sess. Pt. 1, at 94 (1995)).

44	Cellular Phone Taskforce v. FCC, 205 F.3d 82, 88 (2d Cir. 2000).

45	See, e.g., id. at 89 (rejecting an APA challenge to the FCC's RF emissions decisions in the 1996 and 1997
proceedings).

46	Farina v. Nokia Inc., 625 F.3d 97, 126 (3d Cir. 2010); see also id. at 129 (confirming the Commission's
expertise to select an appropriate standard for RF limits).

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agency's reliance on the views of expert agencies.47

Every court since 2005 that has addressed this issue has held that federal law
preempts state action that challenges the safety of wireless devices including
zoning decisions based on safety concerns. The Telecommunications Act itself has
an express preemption provision that prohibits state or local regulation of cellular
equipment based on alleged health effects.48 Courts have also struck down state
law regulation of RF emissions from cell phones based on alleged health effects as
impliedly preempted by the FCC's regulation.49 And most recently, a United States
District Court in the Ninth Circuit held that federal law preempts the City of
Berkeley's Ordinance requiring warnings at the point of sale.50 Preemption,
therefore, would invalidate many of the Recommendations, which if adopted,
would subject the state and localities to expensive challenges and litigation, and
almost certain defeat.

The minority does not oppose individuals or communities who want to convert to
technology that better suits their needs, so long as those decisions do not conflict
with the FCC's goal of the rapid deployment of wireless technology. We also do
not oppose communities providing individuals with information about how to
reduce their exposure to RF emissions, consistent with what the FCC already
does. While individuals should have access to equipment to measure the levels in
apartments they are contemplating renting or homes they want to purchase,
testing should not be mandated. Access to the testing or the equipment to
conduct the test could be provided by various groups such as home inspectors,
real estate agents and the county cooperative extension. Similarly, we do not
agree to establishing a State funded oversight group or state funding of the
measurement equipment. Nor do we believe, as a practical matter, that any of

47	EMR Network v. FCC, 391 F.3d 269, 272-73 (D.C. Cir. 2004).

48	47 U.S.C. ง 332(c)(7)(b)(iv); See, e.g., Cellular Phone Taskforce, 205 F.3d at 96 (interpreting the TCA to preempt a
state and local government's power to regulate the placement, construction and modification of personal wireless
services facilities on the basis of health effects of RF emissions); Santa Fe Alliance for Public Health and Safety v.
City of Santa Fe, N.M., 2020 WL 2198120, at *7 (D.N.M. May 6, 2020) (noting the TCA explicitly preempts states
and local governments from considering environmental effects of RF emissions in siting decisions).

49	Farina, 625 F. 3d at 129 ("there is no indication ... that either Congress or the FCC traditionally viewed state
regulation of RF emissions as a necessary complement to federal regulation"); Murray v. Motorola, Inc., 982 A.2d
764, 777-778 (D.C. 2009) ("insofar as Plaintiffs' claims rest on allegations about the inadequacy of the FCC's RF
radiation standard or about the safety of their FCC-certified cell phones, the claims are preempted under the
doctrine of conflict preemption.").

50	CTIA - The Wireless Association v. City of Berkeley, No. 15-cv-02529-EMC, 2020 WL 5576135 (N.D. Cal. Sept. 17,
2020) (holding the Berkeley Ordinance "overwarns and stands as an obstacle to the accomplishment of balancing
federal objectives by the FCC.").

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the Recommendations have any chance of receiving funding.

The minority feels strongly that the full body of literature of the science on
wireless technology was ignored. Furthermore, the Commission neglected to
carry out its mandate to study "...the advantages and risks associated with 5G
technology."51 Had this been done, the Commission would have been made
aware of the significant economic and societal benefits that 5G is predicted to
provide.52 The minority has strong concerns that should the majority's conclusions
regarding 5G safety - despite their complete odds with the overwhelmingly
majority of verified scientific evidence - lead to the enactment of any of the
majority's recommendations, the citizens of New Hampshire would be deprived
of the enormous benefits of wireless innovation in a time when wireless
connectivity could not be more important.

51	See HB 522: http://gencourt.state.nh.us/bill Status/billText.aspx?sy=2019&id=267&txtFormat=pdf&v=current
(last visited October 14, 2020).

52	Accenture predicts deploying the next generation of high-speed 5G wireless networks could create up to three
million jobs and add approximately $500 billion to U.S. GDP through direct and indirect potential benefits,
https://newsroom.accenture.com/content/1101/files/Accenture 5G-Municipalities-Become-Smart-Cities.pdf (last
visited October 14, 2020).

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APPENDICES

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Appendix A Electromagnetic Spectrum

THE ELECTROMAGNETIC SPECTRUM

SELF ELF	VLF LF/ MF/ HF/ VHF/ UHF SHF EHF

30KHZ	3GHz 5GHz 300GHz 430-750THZ 30PHz 3EHz 300EHz

non-ionizing

f (frequency) = C (speed of light) / A (wavelength)

ionizing

very radio frequency

low	spectrum

frequency *

4	ป

~ microwaves
< ป

visible

gamma

cosmic

x-rays rays
A		~

J

Jz

!fl

t

m

C^Ei) A

F

1

ฆ



Wi

m

CRT
monitors

TV

cell

microwave ovens

WiFi satellites

mobile
AM/FM

phones	baby monitors

wireless

cordless

. 	 smart meters

towers	phones

sunlight

radioactive
sources

cell

medical
x-rays

9 Terahertz (THz) 10-12 Petahertz (PHz) 10-15 Exahertz (EHz) 10-18 Zetahertz (ZHz) 10-21 Yotahertz (YHz) 10-24


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Appendix B

Correspondence with federal agencies

Correspondence between Councilwoman Denise Ricciardi, a member of the
New Hampshire Commission on 5G, and Dr. Barrington and Dr. Hoover of the
National Cancer Institute

Begin forwarded message:

From: NCI Information < nciinfo@nih.gov >

Date: July 30, 2020 at 2:51:16 PM EDT

To: New Bedford Councilmember Denise Ricciardi of the New Hampshire 5G Commission
Subject: Important questions that need to be answered.

Reply-To: "NCI Information" < nciinfo@nih.gov >

Subject: Important questions that need to be answered.

Response By Email (NCI Agent) (07/30/2020 11:51 AM)

Dear Ms. Ricciardi:

I received your follow-up inquiry requesting an answer to each question listed in your email.
Please see below:

Councilmember Denise Ricciardi - Question 1. What is the National Cancer Institute opinion
on the safety of 5G, 4G and cell towers? If you have one, please share your scientific
documentation.

Response from the National Cancer Institute:

As a Federal research agency, the NCI is not involved in the regulation of
radiofrequency telecommunications infrastructure and devices, nor do we make
recommendations for policies related to this technology. The Food and Drug
Administration (FDA) and the Federal Communications Commission (FCC) are the
responsible federal agencies with authority to issue opinions on the safety of these
exposures. Rather, NCI gathers and reviews published findings of well-conducted
studies with a focus on cancer in humans in the medical literature and makes
summaries available on its website and fact sheets.

According to the FCC certain agencies in the Federal Government have been
involved in monitoring, researching or regulating issues related to human exposure
to radiofrequency radiation. These agencies include the FDA, the Environmental
Protection Agency (EPA), the Occupational Safety and Health Administration
(OSHA), the National Institute for Occupational Safe and Health (NIOSH), the
National Telecommunications and Information Administration (NTIA) and the
Department of Defense (DOD).

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Councilmember Denise Ricciardi - Question 2. Has NCI staff done a systematic research
review of the research on wireless radiation?

Response from the National Cancer Institute:

Experts at the NCI review the research on radiofrequency radiation and other types of
non-ionizing radiation electromagnetic fields (EMFs) in order to maintain our fact
sheets on these topics. Other federal agencies have the responsibility to formally
review the research on these exposures, specifically the FDA and FCC.

Councilmember Denise Ricciardi - Question 3. What is the NCI opinion on the safety of
cell phones? If you have one, please share your scientific documentation.

Response from the National Cancer Institute:

The FDA and FCC are the responsible federal agencies with authority to issue
opinions on the safety of these exposures. As a Federal research agency, the NCI is
not involved in the regulation of radiofrequency telecommunications infrastructure
and devices, nor do we make recommendations for policies related to this
technology.

The NCI gathers and reviews published findings of well-conducted studies in the
medical literature on cell phones and cancer risk. The NCI fact sheet" Ceil Phones
and Cancer Risk" outlines the available evidence from human and animal studies
regarding cancer risk and cell/mobile telephones. It includes references and the
citations are at the bottom of the document.

Councilmember Denise Ricciardi - Question 4. Does the NCI recommend that parents
teach their children to reduce exposure to cell phone radiation? Does the NCI think it is not
necessary to take precautions and that information on reducing exposure is only for
"concerned" people? Or does the NCI recommend all parents educate their children to
reduce exposure and that they themselves reduce exposure to their children?

Response from the National Cancer Institute:

As noted above, the NCI does not make recommendations or issue guidelines. The fact
sheet "Cell Phones and Cancer Risk" does include information from the FDA about ways
cell phone users—children, teenagers or adults—can reduce their exposure to
radiofrequency radiation. The FDA suggests that cell phone users reserve the use of cell
phones for shorter conversations or for times when a landline phone is not available; and
use a device with hands-free technology, such as wired headsets, which place more
distance between the phone and the head of the user.

Councilmember Denise Ricciardi - Question 5. Did the NCI review in a systematic way the
research on impacts of wireless and cell towers to trees and plants? If not, what agency is
responsible for ensuring wireless signals are safe for trees and plants?

Response from the National Cancer Institute:

The NCI is not charged with researching the impact of wireless technology and cell
towers on trees and plants. NCI is not aware of any Federal agency mandated to

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ensure wireless signals are safe for trees and plants.

Councilmember Denise Ricciardi - Question 6. Did the NCI review in a systematic way the
research on cell towers and how wireless antennas impact birds. If not, what agency is
responsible for ensuring wireless signals are safe for birds?

Response from the National Cancer Institute:

The NCI is not charged with researching the impact of wireless technology and cell
towers on birds. The NCI is not aware of any Federal agency mandated to ensure
wireless signals are safe birds.

Councilmember Denise Ricciardi - Question 7. Did the NCI review in a systematic way the
research on impact to bees and insects. If not, what agency is responsible for ensuring
wireless signals are safe for insects and bees?

Response from the National Cancer Institute:

The NCI is not charged with researching the impact of wireless technology on bees
and other insects. The NCI is not aware of any Federal agency mandated to ensure
wireless signals are safe for bees and other insects.

Councilmember Denise Ricciardi - Question 8. Does the NCI only focus on cancer as a
health effect?

Response from the National Cancer Institute:

Yes. In addition, by law, U.S. population-based cancer registries must collect
information on benign brain tumors and the NCI fact sheet "Cell Phones and Cancer
Risks" describes findings for meningioma, acoustic neuroma and other benign brain
and central nervous system tumors.

Councilmember Denise Ricciardi - Question 9. The NCI does not present the findings of
the NTP as "clear evidence of cancer" but simply states of the findings that "The primary
outcomes observed were a small number of cancers of Schwann cells in the heart and non-
cancerous changes (hyperplasia^ in the same tissues for male rats, but not female rats, nor
in mice overall." Why doesn't the NCI present the findings of DNA damage on their webpage
as it is published and was found in rats and mice. In addition cardiomyopathy was found.
Why isn't this presented on the NCI webpage?

Response from the National Cancer Institute:

The focus of the fact sheet "Cell Phones and Cancer Risk" is limited to cancer risk. As
you noted, the fact sheet provided an overview of the primary outcomes found in the
National Toxicology Program (NTP) study. These findings are reported on the NTP
website A link to this information was included in the fact sheet for those who wish to
know more about the NTP study.

Councilmember Denise Ricciardi - Question 10. The FDA disagrees with the National
Toxicology Program findings of clear evidence of cancer. What is the NCI position on the
determination of "clear evidence"?

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Response from the National Cancer Institute:

The NCI does not comment on the cancer evaluation criteria of other organizations or
how researchers use these definitions in their analysis. You may find useful a critical
evaluation of the NTP study that was conducted by the International Commission on
Non-Ionizing Radiation Protection (ICNIRP).

Councilmember Denise Ricciardi - Question 11. Is there evidence that heating can cause
cancer? That elevated temperatures can induce cancer?

Response from the National Cancer Institute:

There is no current evidence that elevated temperatures or heating is a risk factor for
cancer.

Councilmember Denise Ricciardi - Question 12. Has the NCI reviewed in a systematic
way the research on impacts to the nervous system?

Response from the National Cancer Institute:

The NCI fact sheet on "Cell Phones and Cancer Risk" provides a summary review of
most epidemiologic studies of cell phone use and brain and other central nervous
system tumors. Most of the studies are case-control studies. Details are provided on
the three most impactful studies, including the 13-country, case-control Interphone
study, the large national Danish cohort study, and the Million Women United Kingdom
cohort study.

Councilmember Denise Ricciardi - Question 13. Does the NCI believe the current limits
protect the public, children, pregnant women and medically vulnerable from health effects
after long term exposure. Please provide documentation for each group, children, pregnant
women and medically vulnerable that shows research ensuring safety.

Response from the National Cancer Institute:

The NCI does not regulate issues related to human exposure to radiofrequency
radiation.

Councilmember Denise Ricciardi - Question 14. We know that the NCI is aware that cell
phones can violate FCC SAR limits at body contact on high power. The FDA has written that
because there is a safety factor. What is the safety factor for the SAR the FDA relies on? Do
you know?

Response from the National Cancer Institute:

The FDA shares regulatory responsibilities for cell phones with the FCC. The FCC
certifies wireless devices, and all phones that are sold in the United States must
comply with FCC guidelines on radiofrequency exposure. The FDA also has the
authority to take action if cell phones are shown to emit radiofrequency energy at a
level that is hazardous to the user.

In addition, the FDA is responsible for protecting the public from harmful radiation

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emissions from consumer products such as microwave ovens, televisions, and
computer monitors. You may wish to contact the FDA's Center for Devices and
Radiological Health's Office of Compliance at 301-594-4654, for information about
SAR guidelines used in cell phones.

Councilmember Denise Ricciardi - Question 15. Will the NCI be taking action to inform the
public about this? If not, please explain why not.

Response from the National Cancer Institute:

NCI staff are committed to regularly reviewing the published findings of well-conducted
studies on cancer and making them available on a timely basis to the public through our
online fact sheets. As noted above, the NCI continues to make this information available
on its website Cancer gov , the Institute's primary resource in informing the public about
cancer research. The NCI gathers and reviews published findings of well-conducted
studies in the medical literature on cell phones and cancer risk. The NCI fact sheet "Cell
Phones and Cancer Risk" outlines the available evidence from human and animal
studies regarding cancer risk and cell/mobile telephones. As also noted above, the NCI
has conducted a review of the research on radiofrequency radiation

and other types of non-ionizing radiation electromagnetic fields (EMFs), available in the
fact sheet

"Electromagnetic Fields and Cancer." NCI will continue to update these factsheets
as new relevant studies are published in the peer-reviewed literature.

Our sister agencies, the FDA as well as the FCC, retain responsibility for reviewing
guidance on safety concerns and informing the public if those circumstances change.

Councilmember Denise Ricciardi - Question 16. What actions specifically is the NCI doing
now in regards to 5G and cell phone radiation in terms of research review?

Response from the National Cancer Institute:

As noted above, the NCI regularly reviews the published findings of studies on cancer
and makes them available to the public.

Additionally, given the multi-year latency of brain tumors and most other solid tumors
and the need to carefully consider the optimal study design, it would be premature to
begin development of a protocol for studying the relation between 5G exposures and
cancer risk before 5G systems are implemented. We are in close communication with
other epidemiologists and dosimetrists working on radiofrequency exposures and
cancer risks. We continue to carefully monitor research in this area.

Councilmember Denise Ricciardi - Question 17. Does the NCI evaluate the safety of 5G
cell antennas? If so how? If not, what health agency is ensuring that 5G cell antennas are
safe for people, wildlife and trees.

Response from the National Cancer Institute:

The FCC is responsible for developing guidelines for human exposure to

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radiofrequency electromagnetic fields, which includes antennas.

Councilmember Denise Ricciardi - Question 18. Cell phones and wireless devices emit
several types of nonionizing radiation in addition to radiofrequency radiation. For example the
devices emit magnetic fields and when a pregnant woman holds a laptop on her lap the
measured fields can be high even into the baby. What agency ensures safety related to
extremely low frequency (ELF-EMF) electromagnetic fields- also nonionizing? Currently we
have no federal limit, no federal guidelines and confirmed associations with cancer and many
other health effects. Kaiser Permanente researchers have published several studies linking
pregnant women's exposure to magnetic field electromagnetic fields to not only increased
miscarriage and but also increased ADHD , obesity and asthma in the woman's prenatally
exposed children. A recent large-scale stud y again found associations with cancer. Where is
the NCI presentation of this research for the public?

Response from the National Cancer Institute:

As noted above, the FDA is responsible for protecting the public from radiation
emissions from consumer products such as microwave ovens, televisions, and
computer monitors. You may wish to contact the FDA's Center for Devices and
Radiological Health's Office of Compliance at 301-594-4654, for information about
research on this topic.

Our sister institute, National Institute of Child Health and Human Development
(NIC another part of the NIH, investigates human development throughout the
entire life process, with a focus on understanding disabilities and important events that
occur during pregnancy. You may wish contact to the NICHD for information about
radiofrequency radiation exposure and human development. NICHD can be contacted
by email at NICHDInformationResourceCenter@mail.nih.gov 

NCI staff are committed to regularly reviewing the published findings of well-conducted
studies on cancer and making them available on a timely basis to the public through our
online fact sheets.

Councilmember Denise Ricciardi - Question 19. Wll the NCI be sharing and
recommending how to reduce ELF- EMF Exposure? Please clarify which US agency has
jurisdiction over ELF-EMF exposures? Please clarify which US agency has authority to set
limits for ELF-EMF exposures? As far as we know there is no limit in the USA for this type of
exposure.

Response from the National Cancer Institute:

According to the fact sheet "Electromagnetic Fields and Cancer" sources of ELF-
EMFs include power lines, electrical wiring, and electrical appliances such as shavers,
hair dryers, and electric blankets.

As noted above, the NCI is not responsible for setting limits for ELF-EMF or any other
exposure. Manufacturers of electronic radiation emitting products sold in the United
States are responsible for compliance with the sral Food. Drug and Cosmetic Act
(FD&C Act). Chapter V

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Subchapter C - Electronic Product Radiation Control.

The U.S. Congress created the National Institute of Environmental Health Sciences'
(NIEHS) EMF Research and Public Information Dissemination (RAPID) Program in
1992 to study whether exposure to EMFs produced by the generation, transmission, or
use of electric power posed a risk to human health. Although this program has ended,
the NIEHS continues to study EMFs. For more information, please see the NIEHS
website.

Councilmember Denise Ricciardi - Question 20. Who are the NCI staff who have
expertise on this issue at the NCI? What NCI staff is in the Interagency workgroup and
where can we access the minutes and work of this group?

Response from the National Cancer Institute:

The content on the NCI's website Cancer gov related to this topic is authored and
maintained by NCI staff. The information on this site is science-based, authoritative,
and up to date. Medical experts, cancer researchers, and editors review the content
before it is published to the website.

Within the NCI, several research divisions conduct or fund extramural research to
discover the genetic and environmental determinants of cancer and new approaches to
cancer prevention, including the impacts of ionizing and nonionizing radiation.
Epidemiologists also monitor cancer incidence trends for potentially relevant
malignancies using U.S.-based cancer registries such as the North American
Association of Central Cancer Registries and the Surveillance, Epidemiology, and End
Results Program, and periodically review the scientific peer-reviewed literature in this
area.

If you are compiling a list of EMF experts to contact, it is important to note that NCI
scientists receive many requests for interviews or for advice with projects. All such
inquiries should be directed to the NCI Office of Communications and Public
Liaison through the NCI contact paqe< mailto:https//www.cancer.qov/contact> ;
found on Cancer gov

Councilmember Denise Ricciardi - Question 21. The FCC decided not to update their
limits on wireless but the NCI did not submit an opinion to the FCC. Why not?

Response from the National Cancer Institute:

As noted above, the NCI does not make recommendations for policies on wireless
technology.

Councilmember Denise Ricciardi - Question 22. Wll the NCI be submitting an opinion to
the FCC about the higher frequencies to be used in 5G?

Response from the National Cancer Institute:

As noted above, the NCI does not make recommendations for policies on wireless
technology.

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Councilmember Denise Ricciardi - Question 23. The American Cancer Society funded
research by Yale that found cancer after cell phone radiation exposure. See it here Thyroid
Cancer, Genetic Variations, and Cell Phones Linked in New Yale School of Public Health
Study What is the NCI opinion?

Response from the National Cancer Institute:

NCI staff are committed to regularly reviewing the published findings of well-conducted
studies on cancer and making them available on a timely basis to the public through our
online fact sheets.

Councilmember Denise Ricciardi Question 24. Will you be updating your webpage with
information on thyroid cancer and on genetic susceptibility as found by the Yale study?

Response from the National Cancer Institute:

Response from the National Cancer Institute: NCI staff are committed to regularly
reviewing the published findings of well-conducted studies on cancer and making
them available on a timely basis to the public through our online fact sheets.

Sincerely yours,

Bill Robinson

Office of Communications and Public Liaison National Cancer Institute

Customer By CSS Email (Denise Ricciardi) (07/19/2020 06:55 AM)

Hello.

You did not satisfy the commission. We requested you answer each question point by point.
Not a paragraph that does NOT properly answer the questions.

Please go back and answer the questions number one provide the answer number two
provide the answer and so on. Please expedite this request, it is urgent for commission.

Thank you,

Denise Ricciardi

Subject: Important questions that need to be answered.

Response By Email (NCI Agent) (07/16/2020 11:39 AM)

Dear Ms. Ricciardi:

Your email to Dr. Amy Berrington and Dr. Robert Hoover of the National Cancer Institute
(NCI) regarding 5G has been forwarded to this office for reply. In your email, you asked
questions about the status of research of the health and environmental effects of 5G (fifth-
generation) wireless network technology on people and the natural world and which Federal
agencies regulate this technology. We can offer information that you may find useful.

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The NCI, part of the National Institutes of Health, is the Federal government's principal
agency for cancer research and training. Part of the NCI's mission includes gathering and
disseminating information about cancer, including risk factors, to the public and medical
community through its website, fact sheets, and the NCI's Cancer Information Service (CIS).
The fact sheets "Cell Phones and Cancer Risk" and "Electromagnetic Fields and Cancer"
outline the available evidence from human and animal studies regarding cancer risk and
cellular/mobile telephones and low- to medium-frequency electromagnetic fields.

The National Toxicology Program (NTP) investigated the health effects in animals exposed to
radiofrequency (RF) radiation modulations used in 2G and 3G cell phones. According to the
lead toxicologist of the studies, Michael Wyde, Ph.D., "5G is an emerging technology that
hasn't really been defined yet. From what we currently understand, it likely differs dramatically
from what we studied." This comment can be found in the NIH news release about the NTP
final reports.

The NCI is committed to reviewing published findings of well-conducted studies in the medical
literature and making them available to the public. Sometimes the results of a research study
can yield inconsistent and even unanticipated results. Nonetheless, in this way, hypotheses
are thoroughly evaluated.

As a Federal research agency, the NCI does not regulate RF electromagnetic field (EMF)
exposure or establish guidelines. Within the Federal government, the U.S. Federal
Communications Commission (FCC) authorizes or licenses most RF telecommunications
services, facilities, and devices used by the public, industry and state and local governmental
organizations. The FCC is required by the National Environmental Policy Act of 1969, among
other things, to evaluate the effect of EMF emissions from FCC-regulated transmitters on the
quality of the human environment. This includes cell phones and towers. The FCC Policy on
Human Exposure web page includes links to several organizations that have
recommendations for human exposure to EMF.

In addition, the U.S. Food and Drug Administration (FDA) shares regulatory responsibilities for
cell phones with the FCC. Although cell phones can be sold without FDA clearance or
approval, the agency monitors the effects the phones have on health. The FDA has the
authority to take action if cell phones are shown to emit RF energy at a level that is hazardous
to the user. The FDA recently provided an updated assessment of the current limits of RF
energy based on the currently available scientific evidence (see Letter from the FDA to the
FCC on Radiofrequency Exposure).

Sincerely yours,

Bill Robinson

Office of Communications and Public
Liaison National Cancer Institute

38


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Customer By CSS Email (Denise Ricciardi) (07/10/2020 07:25 AM)

Hello,

I serve in New Hampshire on a health study commission. We need these questions answered

each one, one by one.

Questions to Dr. Barrington and Dr. Hoover of the National Cancer Institute

1.	What is the National Cancer Institute opinion on the safety of 5G, 4G and cell towers? If
you have one please share your scientific documentation.

2.	Has NCI staff done a systematic research review of the research on wireless radiation?

3.	What is the NCI opinion on the safety of cell phones? If you have one please share
your scientific documentation.

4.	Does the NCI recommend that parents teach their children to reduce exposure to cell phone
radiation? Does the NCI think it is not necessary to take precautions and that information on
reducing exposure is only for "concerned" people? Or does the NCI recommend all parents
educate their children to reduce exposure and that they themselves reduce exposure to
their children?

5.	Did the NCI review in a systematic way the research on impacts of wireless and cell towers
to trees and plants? If not what agency is responsible for ensuring wireless signals are safe
for trees and plants? 6. Did the NCI review in a systematic way the research on cell towers
and how wireless antennas impact birds. If not, what agency is responsible for ensuring
wireless signals are safe for birds?

7.	Did the NCI review in a systematic way the research on impact to bees and insects. If not,
what agency is responsible for ensuring wireless signals are safe for insects and bees?

8.	Does the NCI only focus on cancer as a health effect?

9.	The NCI does not present the findings of the NTP as "clear evidence of cancer" but simply
states of the findings that" The primary outcomes observed were a small number of cancers
of Schwann cells in the heart and non-cancerous changes (hyperplasia^ in the same
tissues for male rats, but not female rats, nor in mice overall." Why doesn't the NCI present
the findings of DNA damage on their webpage as it is published and was found in rats and
mice. In addition cardiomyopathy was found. Why isn't this presented on the NCI webpage?

10.	The FDA disagrees with the National Toxicology Program findings of clear evidence of
cancer. What is the NCI position on the determination of "clear evidence"?

11.	Is there evidence that heating can cause cancer? That elevated temperatures can induce
cancer?

12.	Has the NCI reviewed in a systematic way the research on impacts to the nervous
system?

13.	Does the NCI believe the current limits protect the public, children, pregnant women and

39


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medically vulnerable from health effects after long term exposure. Please provide
documentation for each group, children, pregnant women and medically vulnerable that
shows research ensuring safety.

14.	We know that the NCI is aware that cell phones can violate FCC SAR limits at body
contact on high power. The FDA has written that because there is a safety factor. What
is the safety factor for the SAR the FDA relies on? Do you know?

15.	Wll the NCI be taking action to inform the public about this? If not, please explain why
not.

16.What	actions specifically is the NCI doing now in regards to 5G and cell phone radiation
in terms of research review?

17.	Does the NCI evaluate the safety of 5G cell antennas? If so how? If not, what health
agency is ensuring that 5G cell antennas are safe for people, wildlife and trees.

18.	Cell phones and wireless devices emit several types of non ionizing radiation in addition to
radiofrequency radiation. For example the devices emit magnetic fields and when a
pregnant woman holds a laptop on her lap the measured fields can be high even into the
baby. What agency ensures safety related to extremely low frequency (ELF-EMF)
electromagnetic fields- also non ionizing? Currently we have no federal limit, no federal
guidelines and confirmed associations with cancer and many other health effects. Kaiser
Permanente researchers have published several studies linking pregnant women's
exposure to magnetic field electromagnetic fields to not only increased miscarriage and but
also increased ADHD, obesity and asthma in the woman's prenatally exposed children. A
recent large scale study again found associations with cancer. Where is the NCI
presentation of this research for the public?

19.	Wll the NCI be sharing and recommending how to reduce ELF- EMF Exposure? Please
clarify which US agency has jurisdiction over ELF-EMF exposures? Please clarify which US
agency has authority to set limits for ELF-EMF exposures? As far as we know there is no
limit in the USA for this type of exposure.

20.	Who are the NCI staff who have expertise on this issue at the NCI? What NCI staff is in the
Interagency workgroup and where can we access the minutes and work of this group?

21.	The FCC decided not to update their limits on wireless but the NCI did not submit an
opinion to the FCC. Why not?

22.	Wll the NCI be submitting an opinion to the FCC about the higher frequencies to be used in
5G.

23.	The American Cancer Society funded research by Yale that found thyroid cancer after
cell phone radiation exposure. See it here: https://medicine.yale.edu/news-article/22332/

https://protect-us.mimecast.eom/s/K3TvCmZnOMf1 oANt4 What is the NCI opinion?

24.	Wll you be updating your webpage with information on thyroid cancer and on genetic
susceptibility as found by the Yale study?

Thank you for your cooperation.

Denise Riccciardi

40


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Letters between Councilwoman Denise Ricciardi, a member of the New Hampshire
Commission on 5G, and Dr. Shuren of the FDA

Note: The FDA did not answer the questions as asked and did not respond to the
request to testify to the Commission

•	June 23, 2020 Denise Ricciardi writes the FDA a detailed list of questions regarding
their statements about cell phone radiation.

•	Jul 15, 2020 FDA writes Denise Ricciardi a short two paragraphs that does not answer
the questions.

•	July 15, 2020 Denise Ricciardi writes back to the FDA stating that her questions are
not answered.

•	No additional answers have been provided by the FDA.

•	March 2, 2020: The FDA also did not respond to the March 2020 request to testify to
the 5G Commission.

July 15, 2020 Denise Ricciardi to the FDA

Hello,

This does not answer our specific numbered questions. Please go back and revisit the
questions as requested.

Thank you,

Denise Ricciardi

On Jul 15, 2020, at 5:31 PM, Meister, Karen G < Karen.Meister@fda.hhs.gov > wrote:

July 15, 2020 Letter from FDA to Councilwoman Denise Ricciardi of the New Hampshire
Commission on 5G

On Jul 15, 2020, at 5:31 PM, Meister, Karen G

Ka re in. Meiste r@fd a. Ihi Ihi s. q o v > wrote:

Dear Ms. Ricciardi,

Thank you for contacting the Food & Drug Administration (FDA) with your concerns regarding
exposure to non-ionizing electromagnetic energy. Your inquiry was forwarded to the
Intergovernmental Affairs (IGA) team in the Office of the Commissioner. We understand that
you are a member of New Hampshire's "Commission to Study the Environmental and Health
Effects of Evolving 5G Technology," and that you are gathering information.

As you may know, FDA shares regulatory responsibilities for cell phones with the Federal

41


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Communications Commission (FCC). Under the law, FDA is responsible for, among other
things: consulting with other federal agencies on techniques and programs for testing and
evaluating electronic product radiation and collecting, analyzing, and making available
scientific information on the nature and extent of the hazards and control of electronic
product radiation. FDA's website provides information about cell phones, including the
Agency's current assessment on the safety of exposure to non-ionizing electromagnetic
fields. See https://www.fda.gov/radiation-emitting-products/home-business-and-entertainment-
products/cell-phones The website includes an update to the scientific evidence evaluated by
FDA (see Ihttps:// www.fda.gov/radiation-emittinq--products/cell--phones/scientific--evidence--cell"
phone-safety, as well as suggestions for those that may still be concerned about non-ionizing
energy exposure (see https://www.fda.gov/radiation-emitting-products/cell-phones/reducing-
radio-frequencv-exposure-cell-phones).

FDA's doctors, scientists and engineers continually monitor the scientific studies and public
health data for evidence that radio frequency energy from cell phones could cause adverse
health effects. FDA also works with national and international health agencies to ensure the
weight of scientific evidence is appropriately evaluated.

We hope this information is helpful to answer your questions. Best regards.

Karen Meister, J.D.

Acting Director, Intergovernmental Affairs
Senior Advisor, Office of Legislation
Office of the Commissioner/OPPLIA
U.S. Food and Drug Administration
(301) 796-8916 office
(240) 494-6228 (work cell)

From: "Shuren, Jeff' < Jeff.Shuren@fda.hhs.gov >

Date: June 24, 2020 at 4:28:49 PM EDT
To: Denise Ricciardi

Cc: OC Ombudsman	@OC.FDA.GOV >, Patrick Abrami < abrami.nhrep@gmail.com >

Subject: RE: Important questions NEED to be answered for N.H. 5G health task commission

Thank you for reaching out to me. I have forwarded your questions to the FDA's
Intergovernmental Affairs Staff who handles inquiries from State and local governments. I have
included Karen Meister, their Acting Director, on this email, as well.

Best regards, Jeff

-—Original Message

From: Denise Ricciardi

Sent: Tuesday, June 23, 2020 10:38 PM

To: Shuren, Jeff < Jeff.Slhyiren@fda.lhlhs.gov 
-------
Subject: Important questions NEED to be answered for N.H. 5G health task commission

Dear Dr. Shuren,

We would appreciate an answer to these questions regarding cell phone radiation. If you

could number them one by one it would help with clarity of your response.

Regarding the FDAs report "Review of Published Literature between 2008 and 2018 of

Relevance to Radiofreguencv Radiation and Cancer"

1.	Why did the FDA only focus on cancer as a health effect?

2.	The FDA said of the National Toxicology Program findings that the FDA was unsure if the
tumors were a causal effect or if these results were "due to weakening of the immune
response due to animal stress from cyclic heating and thermoregulation." Does the FDA
think that cancer could be an effect of whole body heating, that cancer is a thermally
induced effect? If so, what other studies show that heating causes cancer?

3.	Did the FDA review in a systematic way the research on impacts to the nervous system?

4.	At the Commission, a study on how millimeter waves interact with insects was discussed.
Did the FDA review in a systematic way the research on impact to bees, insects and
pollinators?

5.	Did the FDA review in a systematic way the research on impact to trees and plants?

6.	Did the FDA review in a systematic way the research on impact to birds.

7.	If the FDA did not investigate impacts to insects or trees, what US agencies have done so?

8.	The FDA website page Scientific Evidence for Ceil Phone Safety has a section entitled "No
New implications for 5G". Does the FDA believe that 5g is safe or that 5G has the same
health issues as 3 and 4G? What is the FDA opinion on the safety of wireless?

9.	What is the FDA opinion on FCC limits in terms of long term health effects. Does the FDA
believe the current limits protect the public, children, pregnant women and medically
vulnerable from health effects after long term exposure.

10.	The FDA is aware that cell phone can violate FCC SAR limits at body contact on high
power. The FDA has written that because there is a safety factor. What is the safety factor
for the SAR the FDA relies on. At what SAR level above FCC limits will the FDA intervene?

11.	What actions specifically is the FDA doing now in regards to 5G and cell phone radiation in
terms of research review? How often will the FDA be releasing reports?

12.	Will the FDA be evaluating the safety of 5G cell antennas? If so how? If not, what health
agency is ensuring that 5G cell antennas are safe for people, wildlife and trees.

13.	Cell phones and wireless devices emit several types of non ionizing radiation in addition to
radiofrequency radiation. For example the devices emit magnetic fields and when a
pregnant woman holds a laptop on her lap the measured fields can be high even into the
baby. What agency ensures safety related to extremely low frequency (ELF-EMF)

43


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electromagnetic fields- also non ionizing? Currently we have no federal limit, no federal
guidelines and confirmed associations with cancer and many other health effects. Kaiser
Permanente researchers have published several studies linking pregnant women's
exposure to magnetic field electromagnetic fields to not only increased miscarriage and but
also increased ADHD , obesity and asthma in the woman's prenatally exposed children. A
recent large-scale study again found associations with cancer. Please clarify which US
agency has jurisdiction over ELF-EMF exposures?

14. Will the FDA be initiating any research studies on 5G and health effects?

We as a health study commission on 5G take these duties very seriously. We are unbiased
and we are seeking all answers and facts. We are requiring your answers to the above
questions.

Thank you,

Denise Ricciardi

Committee Member appointed by Governor Sununu.

Additional Emails related to the questions:

From: "Meister, Karen G" iren.Meister@fda.hhs.gov >

Date: July 14, 2020 at 2:12:10 PM EDT To: Denise Ricciardi

Subject: FW: Important [External]

Hi Ms. Ricciardi-

We apologize for not responding sooner. Dr. Shuren forwarded your inquiry to our office
because the Intergovernmental Affairs staff in the Office of the Commissioner handles inquiries
from state and local governments like yours. We hope to get you a response very shortly.
Thank you for your patience.

Karen

Karen Meister, J.D.

Acting Director, Intergovernmental Affairs
Senior Advisor, Office of Legislation
Office of the Commissioner/OPPLIA
U.S. Food and Drug Administration
(301) 796-8916 office
(240) 494-6228 (work cell)

(703) 201-6952 (personal cell-1 will call you back on work phone)

Original Message

From: Denise Ricciardi

Sent: Tuesday, July 14, 2020 9:08 AM

To: Shuren, Jeff < Jeff.Shuren@fda.hhs.gov >

Cc: Patrick Abrami

Subject: Important

44


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We have received no answers for our questions for the 5G health study commission in New
Hampshire. Please advise!

Original Message
From: Denise Ricciardi

To: CDRHSpeakerLiaison@fda.hhs.g 3RHSpeakerLiaison@fda.hhs.gov >:;

iieff.shyiriren@fda.hhs.qovllvndsav.lllloyd.hhs.gov


Cc: IPatiriielk..AIbirairn ii@

Subject: Study commission HB522 New Hampshire
Sent: Wed, Mar 4, 2020 2:43 pm

Good afternoon,

Governor Sununu in the State of New Hampshire has tasked a group of us to study the health
effects of the 5G rollout.

We are composed of a wide variety of talents. Including Physicians, toxicologists,
scientists, epidemiologists, physicists, engineers, the telecom industry and more.

We have been meeting since last October and have had many experts provide testimony.

To complete our findings in an unbiased fashion. It is essential to have a qualified member of
the FDA and the FCC present to our commission.

We are making history in New Hampshire. Many other States are watching. Our results
will have a profound effect.

When can we count on your participation on such an important issue.

Thank you,

Denise Ricciardi

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Appendix C

Answers to the specific questions
posed by HB 522

1. Why does the insurance industry recognize wireless radiation as a leading risk
and has placed exclusions in their policies not covering damages caused by the
pathological properties of electromagnetic radiation?

As shared with the Commission, insurers rank 5G, wireless, and electromagnetic
radiation as high risk based on their white papers which compare the risk to
asbestos where it may take decades to know the full extent of health impacts.

Scarato shared a 2019 report by Swiss Re Institute53 which classifies 5G mobile
networks as an "off-the-leash" "HIGH" risk, meaning a high-impact emerging risk
that will affect property and casualty claims in more than three years' time. The
Swiss Re report states on page 29:

To allow for a functional network coverage and increased capacity
overall, more antennas will be needed, including acceptance of
higher levels of electromagnetic radiation. In some jurisdictions, the
rise of threshold values will require legal adaptation. Existing
concerns regarding potential negative health effects from
electromagnetic fields (EMF) are only likely to increase. An uptick in
liability claims could be a potential long-term consequence.

Potential impacts:

•	Cyber exposures are significantly increased with 5G, as attacks
become faster and higher in volume. This increases the
challenge of defense.

•	Growing concerns of the health implications of 5G may lead to
political friction and delay of implementation, and to liability
claims. The introductions of 3G and 4G faced similar
challenges.

53 Swiss Re Institute, New Emerging Risk Insights, 2019

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•	Information security and national sovereignty concerns might
delay implementation of 5G further, increasing uncertainty for
planning authorities, investors, tech companies and insurers.

•	Heated international dispute over 5G contractors and potential
for espionage or sabotage could affect international
cooperation, and impact financial markets negatively.

•	As the biological effects of EMF in general and 5G in particular
are still being debated, potential claims for health impairments
may come with a long latency.

A Business Insurance analysis54 also examined mass tort exposures that may have
the potential to cause major difficulties for commercial policyholders and their
insurers. It includes workers' overexposure to radio frequency waves from
rooftop wireless transmitters as a potential future claim and states that research
"has shown biological effects from lower-level 'nonthermal' exposure, and people
exposed at lower levels have reported headache, dizziness, nausea, mood
disorders, mental slowing, and memory loss." Most insurance plans do not cover
electromagnetic fields (EMF) and they have "electromagnetic field exclusions."

For example the California State University Risk Management Authority
(CSURMA) Self Insured Program states:

We will not pay for loss or damage caused by or resulting from any of
the following:

Artificially generated electrical, magnetic or electromagnetic energy
that damages, disturbs, disrupts or otherwise interferes with any: (1)
Electrical or electronic wire, device, appliance, system or network; or
(2) Device, appliance, system or network utilizing cellular or satellite
technology. But if fire results, we will pay for the loss or damage
caused by that fire if the fire would be covered under this coverage
form. For the purpose of this exclusion, electrical, magnetic or
electromagnetic energy includes but is not limited to: (1) Electrical
current, including arcing; (2) Electrical charge produced or conducted

54 Businesslnsurance.com, "The Next Asbestos: Five emerging risks that could shift the liability landscape," May 13,
2011.

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by a magnetic or electromagnetic field; (3) Pulse of electromagnetic
energy; or (4) Electromagnetic waves or microwaves.

Even AT&T Mobile Insurance55 excludes loss from pollutants. Their policy states,
"Pollutants" means: Any solid, liquid, gaseous, or thermal irritant or contaminant
including smoke, vapor, soot, fumes, acid, alkalis, chemicals, artificially produced
electric fields, magnetic field, electromagnetic field, sound waves, microwaves,
and all artificially produced ionizing or non- ionizing radiation and waste."

Crown Castle states in their 2020 Annual Report:

If radio frequency emissions from wireless handsets or equipment on
our communications infrastructure are demonstrated to cause
negative health effects, potential future claims could adversely affect
our operations, costs or revenues.

The potential connection between radio frequency emissions and
certain negative health effects, including some forms of cancer, has
been the subject of substantial study by the scientific community in
recent years. We cannot guarantee that claims relating to radio
frequency emissions will not arise in the future or that the results of
such studies will not be adverse to us.

Public perception of possible health risks associated with cellular or
other wireless connectivity services may slow or diminish the growth
of wireless companies, which may in turn slow or diminish our
growth. In particular, negative public perception of, and regulations
regarding, these perceived health risks may slow or diminish the
market acceptance of wireless services. If a connection between
radio frequency emissions and possible negative health effects were
established, our operations, costs, or revenues may be materially and
adversely affected. We currently do not maintain any significant
insurance with respect to these matters.

55 AT&T Mobile insurance Policy, 2014, p. 4

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Wireless companies from AT&T56 to Nokia to T-Mobile to Verizon Wireless have
issued similar warnings57 to their own shareholders.

Contained in	port are the following statements: "What

is the risk? Electro-magnetic signals emitted by mobile devices and base stations
may be found to pose health risks, with potential impacts including: changes to
national legislation, a reduction in mobile phone usage or litigation" and "EMF
health related risks - EMF found to pose health risks causing reduction in mobile
usage or litigation." The report also included EMF is a "Principal Risk" rated as
high in the graphic on pages 38 - 39.

Additional Insurance Reports that Rank Wireless and Electromagnetic Fields as
"High Risk"

•	2016 Austrian Accident Insurance Institute (AUVA) ATHEM Report 2

"Investigation of atherin -II < ll< ฆ i • "II < lectromagneticfieU,- in nn-hih
c	lations."

•	2014 Swis I • ,	II i II' II port: New emerging iri:- II in:-lights.

•	2013 AM Best Briefing,	inollogies Pose Significant Risks with

>ible Long-Tail Losses.

•	2011 Business Insurance White Paper, "1 In 1U • i ,-h< -tos: Fi\ฆ ซ im ii;in;-
risks that couU ,-lnH 11 m Ii -hilii I ndscape."

•	2011 Austrian Accident Insurance Institute (AUVA) ATHEM Report 1,

Investigate •!i *-l -illn rni.ill, ||, , i;- ,,\ , lectiromagnetic fieM - in 111^ฆ Iซih i, dio
is in German

•	"'i11 'i1IIII	'1 ฆ -II II ฆ -ii idon Report on Electromagnetic Fields

•	2009 Austrian Accident Insurance Institute Report on Health Risks from Cell
Phone Radiation "Nonthei m I II ll< ฆ I;- ^-1 II l< ฆ iiromagnetic Radiatic-i i in I he

one Frequency Range."

•	2011 Business Insurance Article "Geis	nine White. "Insurers exclude

risks associated with electromagnetic radiation."

56	AT&T 2016 Annual Report

57	EHTrust.org, "Corporate Company Investor Warnings In Annual Reports 10k Filings Cell Phone Radiation Risks."

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2. Why do cell phone manufacturers have in the legal section within the device
saying keep the phone at least 5mm from the body?

5G will have multiple antennas for 5G as well as 4G, Wi-Fi, Bluetooth, and other
technology. All of these antennas emit wireless radiation. Even if you are not on
the phone, it has continuous emissions.

Phones are premarket tested for cell phone radiation exposures with a separation
distance from the phone and the body phantom. This legal section states the
exact separation distance the manufacturers used when testing the phone for
compliance. As the 2012 GAO Report "I • |u1>iฆ nJ llซ •.inn;-1\i|Uii ฆ inn mi;- IU;ir

ones Should Be Reassessed" states, "The specific minimum separation
distance from the body is determined by the manufacturer. In addition, the U.S.
government does not perform independent cell phone compliance testing,
allowing each manufacturer to submit their own SAR testing results to the FCC."

If phones are used in positions closer than this manufacturer's stated distance,
the cell phone user could potentially receive excessive cell phone radiation SAR
levels which violate the FCC regulatory limits. Several reports in the US and
internationally have confirmed that when phones are tested at body contact, the
measured SAR will exceed FCC limits.58,59,60,61 Theodora Scarato presented this
information to the Commission including an analysis by Professor Om Gandhi
which examined data from 450 cell phone models from the French government
agency, ANFR, the national radiation assessment bureau, indicating that phones
can emit 11 times over the US FCC limit and 3 times over European/ICNIRP limits.

FCC Does Not Require Body Contact Tests for Cell Phone Radiation

As stated in the 2012	rt, "Some consumers may use mobile phones

against the body, which FCC does not currently test, and could result in RF energy
exposure higher than the FCC limit." The GAO report also directed the FCC to
review their cell phone testing protocol because they found these protocols could

58	Gandhi, O. P. (2019). "Microwave Emissions From Cell Phones Exceed Safety Limits in Europe and the US When
Touching the Body." IEEE Access, 7, 47050-47052. doi:10.1109/access.2019.2906017

59	Gandhi, Om P., and Gang Kang. "inaccuracies of a plastic" pinna" SAM for SAR testing of cellular telephones
against IEEE and ICNIRP safety guidelines." IEEE Transactions on Microwave Theory and Techniques 52.8 (2004).

60	Gandhi, Om P. "Yes the children are more exposed to radiofrequencv energy from mobile telephones than
adults." IEEE Access 3 (2015): 985-988.

61	Kang, Gang, and Om P. Gandhi. "SARs for pocket-mounted mobile telephones at 835 and 1900 MHz." Physics in
Medicine and Biology 47.23 (2002): 4301.

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allow for consumers to receive SAR levels that possibly exceed the "on the body"
exposure guidelines.

Cell phone manufacturers are not required by the FCC to test cell phones for cell
phone radiation compliance in positions which mimic direct contact between the
phone and the body. In the USA, manufacturers can set distances of up to 25 mm
when they perform SAR radiation testing for their phones and they are still within
the law.

In contrast, in Europe the law has changed to ensure phones are tested at least at
5 mm and no more. This happened after France ANFR released radiation
measurements for hundreds of cell phones tested independently by the
government of France. The ANFR found the radiation levels were so high that
most tested phones exceeded European cell phone radiation limits, showing
radiation levels up to three times higher than the limits! ANFR has posted the
information on their website.

Several phone models have been taken off the European market or software
updated to reduce the radiofrequency radiation. The first withdrawal of cell
phones from the market due to cell phone radiation levels dates back to April
2018, with the 100,000 Hapi 30 phones marketed by Orange, followed by the
Neffos XI TP902 (May 2018), the Echo Horizon Lite (Oct 2019), and the
announcement on May 20 of the withdrawal of the Razer Phone 2 devices.

After the release of the ANFR tests that found phones violated limits in body
contact positions, a new European Directive 2014/35/UE called RED, applicable
from June 2016, changed the regulations so that now all phones in the European
Union are SAR tested at a distance no greater than 5 mm.

Furthermore, the French ministries of Health, Ecology and Economy issued a joint
press release on October 25, 201962 announcing France will ask the European
Commission to further strengthen the SAR tests requirements to be carried out in
a body contact position of 0mm from the body phantom. This would ensure that
tests mimic the way people use cell phones today, touching the body.

62 Buzyn A. "The Government is taking action to limit exposure to the emissions of certain mobile phones and to
better inform the public." Ministere Des Solidarites Et De LaSante. Published 2019. Accessed July 8, 2020.

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FCC SAR Limits

The FCC regulates RF energy emitted from FCC-regulated transmitters and has
implemented a certification program to ensure that ail mobile phones and
wireless devices sold in the United States comply with the agency's limit on RF
radiation exposure.

Before a cell phone model is permitted to go on the market for sale, its
manufacturer performs Specific Absorption Rate (SAR) tests to evaluate the
radiation levels. SAR values are expressed in terms of watts per kilogram (W/kg)
and are intended to measure the amount of cell phone radiofrequency radiation
absorbed by the body when using a wireless device.

Ceil Phone Radiation SAR Limits in the USA

The FCC and Health Canada limit for cell phone radiation exposure to the public
from cellular telephones is a SAR level of 1.6 watts per kilogram averaged over 1
gram of tissue. For extremities such as the wrists, ankles, hands, ears, and feet,
the allowable SAR limit is much higher and is 4.0 W/kg averaged over 10 grams of
tissue.63

Image from FCC Presentation64

Whole-Body

October 2005

SAR

Occupational/Controlled Exposure Limits (W/kg)



Whole-Body

Partial-Body

Hands, Wrists, Feet and Ankles



0.4

8.0

20.0

General Population/Uncontrolled Exposure Limits (W/kg)

Partial-Body
1.6

Hands, Wrists, Feet and Ankles
	4.0	

Whole-Body SAR is averaged over the entire body.

Partial-body SAR is averaged over any 1 g of tissue in the shape of a cube.

SAR for hands, wrists, feet and ankles is averaged over any 10 g of tissue in the shape of a cube.

SAR limits are not applicable above 6.0 GHz; MPE limits for field strength and power density
should be applied. Categorical exclusion of routine MPE evaluation for mobile transmitters does
not apply to portable devices operating above 6.0 GHz.

TCB Workshop

63	Radio Frequency Safeti | Federal Communications Commission. Accessed July 8, 2020.

64	https://transition.fcc.gov/oet/ea/presentations/files/oct05/RF Exposure Concepts Support KC.pdf

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There also is an occupational SAR limit for cell phones, allowing much higher
exposures. The US FCC occupational limit is a SAR level of 8 watts per kilogram
averaged over 1 gram of tissue. For extremities such as the wrists, ankles, hands,
ears, and feet, the allowable SAR limit is much higher and is 10.0 W/kg averaged
over 10 grams of tissue.

According to the FCC65 the "occupational/controlled exposure limits are
applicable to situations in which persons are exposed as a consequence of their
employment, who have been made fully aware of the potential for exposure and
can exercise control over their exposure."

Thus, the manufacturer's recommended distance for cell phones is a defined
number of millimeters. The specific distances for each phone varies and can be
found in the cell phone's instruction/user manual. Furthermore, the
recommended distance for wireless laptops, Wi-Fi routers, smart security
systems, smart speakers and printers is generally 20 centimeters (approximately 8
inches) as stated in the user manual. The FCC states that "mobile devices are
transmitters designed to be used in such a way that a separation distance of at
least 20 centimeters is normally maintained between the transmitter's radiating
structure(s) and the body of the user or nearby persons."

The CTIA has argued that "there is no reliable evidence proving that current
testing protocols fail to ensure compliance with RF standards." This is stated in

the CTIA submission to the US Federal Communications Commission regarding the
FCC Proceeding on Human Exposures to Radiofrequency Radiation. CTIA also
stated, "a zero-measuring requirement would not accurately mimic real usage or
increase safety."

The French data release refutes these CTIA and FCC statements because they
found SAR levels were in violation of limits when phones were tested in body
contact positions at highest power levels.

65 Chan K. Overview of RF Exposure Overview of RF Exposure Concepts and Requirements Concepts and
Requirements, http://grouper.ieee.org/groups/scc34/sc2/wgl/appr_memo.html. Accessed July 8, 2020.

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Examples of the Manufacturer's Instructions

Here are some examples of the radiofrequency statement for phones as well as
other wireless devices people use every day.

Samsung
Health and
Safety

Information

"Body-worn operations are restricted to belt-clips, holsters or
similar accessories that have no metallic component in the
assembly and must provide at least 1.5cm separation between
the device and the user's body."

iPhone 11

Pro Max

"During testing, iPhone radios are set to their highest
transmission levels and placed in positions that simulate uses
against the head, with no separation, and when worn or carried
against the torso of the body, with 5mm separation."

Nokia 8110
4G Phone
(2019
Manual)

"This device meets RF exposure guidelines when used against
the head or when positioned at least 5/8 inch (1.5 centimetres)
away from the body. When a carry case, belt clip or other form
of device holder is used for body-worn operation, it should not
contain metal and should provide at least the above stated
separation distance from the body."

Safetv &

regulatory
information
(Pixel & Pixel
XL 2016)

"Body worn operation: Pixel complies with radio frequency
specifications when used near your ear or at a distance of 0.4 in
(1.0 cm) from your body. Pixel XL complies with radio frequency
specifications when used near your ear or at a distance of 0.4 in
(1.0 cm) from your body. Ensure that the device accessories,
such as a device case and device holster, are not composed of
metal components. Keep the device away from your body to
meet the distance requirement."

Samsung 3G
Laptop

Manual

"Usage precautions during 3G connection: Keep safe distance
from pregnant women's stomach or from lower stomach of
teenagers. Body worn operation: Important safety information
regarding radiofrequency radiation (RF) exposure. To ensure
compliance with RF exposure guidelines the Notebook PC must
be used with a minimum of 20.8 cm antenna separation from
the body."

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Owlcam
Manual with
RF

Instructions

"Caution exposure to radiofrequency radiation, to comply with
FCC RF exposure compliance requirements for mobile
configurations, a separation distance of at least 20 cm must be
maintained between the antenna of this device and all persons."

PlavStation 3

"This equipment complies with FCC/IC radiation exposure limits
set forth for uncontrolled equipment and meets the FCC radio
frequency (RF) Exposure Guidelines in Supplement C to OET65
and RSS-102 of the IC radio frequency (RF) Exposure rules. This
equipment should be installed and operated with at least 20 cm
(8 in) and more between the radiator and person's body
(excluding extremities: hands, wrists, feet and legs)."

Amazon Echo

"Information Regarding Exposure to Radio Frequency
Energy...This device should be installed and operated with a
minimum distance of 20cm between the radiator and your body.
The remote control meets the RF exposure requirement of low
power devices under portable operation. Nevertheless, it is
advised to use the Products in such a manner that minimizes the
potential for human contact during normal operation."

Panasonic
DECT Home
Cordless
Phone

"FCC RF Exposure Warning: To comply with FCC RF exposure
requirements, the base unit must be installed and operated 20
cm (8 inches) or more between the product and all person's
body."

HP Printer

"In order to avoid the possibility of exceeding the FCC radio
frequency exposure limits, human proximity to the antenna shall
not be less than 20 cm (8 inches) during normal operation."

Apple Watch

"During testing, Apple Watch radios are set to their highest
transmission levels and placed in positions that simulate use
against the head, with 10mm separation, and on the wrist, with
no separation. When placing Apple Watch near your face, keep
at least 10mm of separation to ensure exposure levels remain at
or below the as-tested levels."

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Apple iPod
Touch

"During testing, iPod radios are set to their highest transmission
levels and placed in positions that simulate use near the body,
with 5mm separation.

To reduce exposure to RF energy, use the supplied headphones
or other similar accessories. Carry iPod at least 5mm away from
your body to ensure exposure levels remain at or below the as-
tested levels."

Nokia 8110
4G Phone
(2019
Manual)

"This device meets RF exposure guidelines when used against
the head or when positioned at least 5/8 inch (1.5 centimetres)
away from the body. When a carry case, belt clip or other form
of device holder is used for body-worn operation, it should not
contain metal and should provide at least the above stated
separation distance from the body."

Apple Has Changed Their Text and No Longer Clearly Instructs Users to Keep the
Phone at a Distance But Does Share the Test Distance

In 2015 the Apple iPhone 6 manual had the following statement. "Carry iPhone at
least 5mm away from your body to ensure exposure levels remain at or below the
as-tested levels." While this sentence was still on their website on March 2. 2017,
it was removed by November 9. 2017. Similarly, the iPhone 7 was released in
2016, along with the same online instructions to carry it "5 mm away from your
body" which disappeared from the Apple website by November 9. 2017.

Apple's website still includes information that cell phones are tested with a
separation distance. However, the text is absent of clear instructions to
consumers. Years ago, iPhone 3 filings to the FCC stated "iPhone's SAR
measurement may exceed the FCC exposure guidelines for body-worn operation
if positioned less than 15 mm (5/8 inch) from the body (e.g. when carrying iPhone
in your pocket)." Apple clearly stated, "When using iPhone near your body for
voice calls or for wireless data transmission over a cellular network, keep iPhone
at least 15 mm (5/8 inch) away from the body."

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Investigations Find Cell Phones Violate Cell Phone Regulatory Limits When the
Phone is Tested at Body Contact

Chicago Tribune Cell Phone Radiation Tests

Tests paid for by the Tribune and conducted according to federal guidelines at an
accredited lab, produced a surprising result: Radiofrequency radiation exposure
from the iPhone 7 — one of the most popular smartphones ever sold —
measured over the legal safety limit and more than double what Apple reported
to federal regulators from its own testing. These tests measured radio frequency
radiation SAR levels at 2mm from the body. Chicago Tribune Cell Phone Test
Report

During Commission proceedings the CTIA countered that the FCC tested the
phones the Chicago Tribune had reported to exceed SAR levels and released a
report that found them to not to violate SAR limits. However, if you go to the FCC
report on SAR measurements it shows that the FCC used a separation distance
(on page 9)66. The Chicago Tribune report specifically investigated phones at a
distance of 2mm from the body. The FCC Report did not replicate the Chicago
Tribune tests at 2mm but instead used the manufacturers separation distances
which vary from 5 mm to 15mm.

Canadian Broadcasting Corporation

A 2017 investigation by the Canadian Broadcasting Corporation found radiation
levels higher than government standards after they tested popular cell phones in
a US FCC certified laboratory.

French ANFR

Professor Om Gandhi, one of the engineers who developed radiofrequency limits
years ago, published an analysis of the data from 450 cell phone models from the
French government agency, ANFR, the national radiation assessment bureau,
indicating that phones can emit 11 times over the US FCC limit and 3 times over
European/ICNIRP limits.

3. Why have 1,000s of peer-reviewed studies, including the recently published
U.S. Toxicology Program 16-year $30 million study, that are showing a wide
range of statistically significant DNA damage, brain and heart tumors,

66 FCC. Results of Tests on Cell Phone RF Exposure Compliance.: 2019. Accessed July 8, 2020.

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infertility, and so many other ailments, been ignored by the Federal
Communication Commission (FCC)?

There has not been a scientific review of the research by a US agency for more
than two decades.

Just recently in December 2019, the FCC determined that there was no need to
review the radiofrequency limits. The FCC based this decision largely on a letter
by the FDA. In the spring of 2020, the FDA released a research review, but it was
not a systematic full evaluation of health effects, but instead only focused on
cancer and criticized studies that found effects. FDA has not done experimental
research on impacts to humans, birds, bees, trees, and wildlife. The FDA review
does not systematically evaluate RF levels and impacts to birds, bees, and trees.

Most importantly, as the FCC states, there are no federally developed safety
limits67 and there is no US health agency developing such safety limits in the US.

There is not a single health/safety/environmental agency investigating,
researching or monitoring impacts to birds, bees, trees, and wildlife. In addition,
regulatory limits for exposure to radiofrequency radiation have never been
developed for birds, bees, trees, and wildlife. This is why the US Department of
the Interior sent a letter to the National Telecommunications and Information
Administration in 201468 reviewing several research studies showing harm to
birds and concluding that "the electromagnetic radiation standards used by the
Federal Communications Commission (FCC) continue to be based on thermal
heating, a criterion now nearly 30 years out of date and inapplicable today."

A now retired US Fish and Wildlife Service wildlife biologist and former lead on
telecommunications impacts, Dr. Albert Manville, has written to the FCC on
impacts to birds and higher frequencies to be used in 5G and authored numerous
publications detailing research showing harm to birds.69,70,71 "Now as a private

67	Wireless Devices and Health Concerns | Federal Communications Commission. Accessed July 8, 2020.

68	Washington DC, Veenendaal ME. Department of Interior Letter. United States Department of the Interior OFFICE
OF THE SECRETARY.

69	ECFS Filing Detail, https://www.fcc.gov/ecfs/filing/1060315601199. Accessed July 8, 2020.

70	Albert M. Manville Ph.D. Former U.S. Fish and Wildlife Service Senior Biologist. "Memorandum on the Bird and
Wildlife Impacts of Non-ionizing Radiation." Environmental Health Trust. Accessed July 8, 2020.

71	Manville AM. "Collisions, Electrocutions, and Next Step : Bird Strikes And Electrocutions At Power Lines,

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wildlife consultant and part-time adjunct professor for Johns Hopkins University, I
also continue to study the impacts of radiation on human health, welfare and
safety, including impacts from millimeter-wide radiation frequencies on humans
from 5G. The race to implement 5G and the push by FCC to approve the related
5G license frequencies to industry are very troubling and downright dangerous."

He has testified72 about the impacts of cell towers on birds that "the entire
thermal model and all FCC categorical exclusions for all the devices we see today,
rests on the incorrect assumption that low-level nonionizing nonthermal radiation
cannot cause DNA breaks because it is so low power. The evidence to the
contrary is clear and growing laboratory animals and wildlife."

Most recently Manville wrote the FDA regarding the FDA statements of "safety"
in regards to cell phone radiation that, "as a certified wildlife biologist and Ph.D.
environmental scientist who has studied the impacts of radiation on migratory
birds, other wildlife, and humans since the late 1990s, the statement credited to
the FDA is preposterous, without any scientific credibility, and at a minimum
deserves a retraction by the FDA. There currently are well over 500 scientific,
peer-reviewed papers addressing impacts of non-ionizing, non-thermal radiation
on laboratory animals — many of the studies directly applicable to human health
and safety."73

In addition, no "safe" level has been scientifically determined for long term
impacts for children or pregnant women. While they are "designed" to address
children, the reality is that no such research existed at the time of the limit
development that actually considered children's unique vulnerability which
includes their developing brain and immune system. The EPA clarified that current
FCC limits do not account for long term exposures74 in 2002 stating, "Federal
health and safety agencies have not yet developed policies concerning possible
risk from long term, nonthermal exposures." Current FCC human exposure limits
"are thermally based, and do not apply to chronic, nonthermal exposure
situations" and adequate scientific evaluations of the full impact on sensitive

Communication Towers, And Wi "" ' ines: State Of The Art And State Of The Science • Next Steps Toward

Mitigation."; 2002.

72	Manville AM. IPCWB. Declaration of: Albert M. Manville. II. PhD. C.W.B.. Published 2018. Accessed July 8, 2020.

73	Statement From Dr. Albert Manville On The FDA Report On Cell Phone Radiation. Environmental Health Trust.
Accessed July 8, 2020.

74	Washington DC. United States Environmental Protection Agency. 2002 http://www.epagov. Accessed July 8,
2020.

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populations such as children, pregnant women, and the elderly has yet to be
completed.

Background on US FCC Radiofrequency Human Exposure Limits

The FCC is not a health and safety agency and in fact never developed health
based federal safety standards as we have with other environmental exposures.

Although there used to be a robust research effort in the United States in the
'60s, 70s, and '80s, it was defunded. In fact, the US EPA was tasked to develop
proper safety standards and was in process of developing two tiered guidelines on
both thermal and biological effects in the mid-nineties. However, funding was cut
and in 1996 the EPA was fully defunded from work on electromagnetic radiation.
Then the FCC promulgated limits for human exposure to radiofrequency radiation
based on the American National Standards Institute (ANSI), the Institute of
Electrical and Electronics Engineers, Inc. (IEEE) - ANSI/IEEE C95.1-1992 guidelines
and the National Council on Radiation Protection and Measurements (NCRP)

NCRP Report 1986. The limits have remained largely unchanged since 1996.

In 2008 the National Academy of Sciences National Research Council Report "The
Identification of Research Needs Relating to Potential Biological or Adverse Health
Effects of Wireless Communications Devices" documented critical research gaps
and called for the need to increase understanding of any adverse effects of long
term chronic exposure to RF/microwave energy on children and pregnant women.

In 2008 the Congressional hearing "Health Effects of Cell Phone Use" of the US
House Oversight and Government Reform Subcommittee on Domestic Policy had
testimony from several experts including David Carpenter, Ronald B. Herberman
M.D., Robert Hoover, Darrell Issa, and Julius P. Knapp II.75

In 2009 a Senate Appropriations Subcommittee held a hearing on the "Health
Effects of Cell Phone Use" and had testimony from several experts including John
Bucher, Devra L. Davis, Thomas "Tom" Harkin, Dariusz Leszczynski, Olga Naidenko,
and Siegal Sadetzki.76

75	2008 Congressional Hearing: Health Effects of Cell Phone Use

76	2009 Hearing link to transcript

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A 2012 report by the Government Accountability Office "Exposure and Testing
Requirements for Mobile Phones Should Be Reassessed" urged the FCC to
"formally reassess and, if appropriate, change its current RF energy (microwave)
exposure limit and mobile phone testing requirements related to likely usage
configurations, particularly when phones are held against the body" because
without such a reassessment, the "FCC cannot ensure it is using a limit that
reflects the latest research on RF energy exposure." The report stated that the
FCC RF limits adopted in 1996 did not reflect the way people use their phones,
particularly when phones are held against and touching the body. The report led
the FCC to launch an official inquiry77 in 2013 to explore whether it should modify
its radiofrequency exposure standards. The FCC noted, "we specifically seek
comment as to whether our current limits are appropriate as they relate to device
use by children." The FCC docket asked these important questions: Are US cell
phone and cell tower radiation limits safe for humans? Do children need special
protections? Should companies change the way they test the radiation from
phones because phones are tested with a separation distance between the phone
and the body? The FCC received over a thousand submissions.78

In 2019, the FCC issued a report and order79 that closed the inquiry. It stated,
"First, we resolve a Notice of Inquiry that sought public input on, among other
issues, whether the Commission should amend its existing RF emission exposure
limits. After reviewing the extensive record submitted in response to that inquiry,
we find no appropriate basis for and thus decline to propose amendments to our
existing limits at this time. We take to heart the findings of the Food & Drug
Administration (FDA), an expert agency regarding the health impacts of consumer
products, that "the weight of scientific evidence has not linked cell phones with
any health problems."

Scientists are calling for the FDA to retract their report that is now used as proof
of safety. Due to the fact that the FDA later in 2020 released a report criticizing
studies that found harm and provided no research demonstrating safety, several
expert scientists wrote to the FDA.

77	Review of RF Exposure Policies I Federal Communications Commission

78	ECFS filings results. Accessed July 8, 2020.

79	FCC- FCC 19-126. https://www.fda.gov/Radiation. Accessed July 8, 2020.

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"I find it shocking that the FDA would casually dismiss the carcinogenicity findings
from the National Toxicology Program (NTP) studies on cell phone radiation in
experimental animals, when it was the FDA that requested those studies in the
first place 'to provide the basis to assess the risk to human health/ and when an
expert peer-review panel carefully reviewed the design and conduct of those
studies and then concluded that the results provided "clear evidence of
carcinogenic activity," stated Ronald Melnick PhD who led the design of the $30M
NTP study. Melnick sent a letter to the FDA documenting the scientific
inaccuracies in their review.

"When I worked as a wildlife biologist for the U.S. Fish & Wildlife Service for 17
years, I collaborated with the late Dr. Ted Litovitz in 2000. Dr. Litovitz and his
colleagues studied the impacts of low-level, non-thermal radiation from the
standard 915 MHz cell phone frequency on chicken embryos. In their laboratory
studies, control/non-treated embryos suffered no effects, but some of the
treated/irradiated embryos died — at levels as low as 1/10,000 the normal level
of cell phone radiation exposure to humans. This was an eye-opener!" stated
Albert M. Manville, II, Ph.D.; retired Senior Wildlife Biologist, Division of Migratory
Bird Management, U.S. Fish & Wildlife Service, Washington.

"The FDA review omits an evaluation of the science on wireless radiation impacts
to trees and wildlife. Electromagnetic radiation is a form of environmental
pollution which may hurt wildlife. I have co-published research entitled

"Radiofrequencv radiation injures trees around mobile phone base stations"
finding harm to trees near base stations (cell antennas) in a long term field
monitoring study in two cities, " stated biologist Alfonso Balmori, BSc who sent a

statement to the FDA.

Letters which have been sent to the FDA include:

•	Letter calling for a retraction signed by several scientists.

•	Ronald Melnick PhD's letter to the FDA on the National Toxicology Program
study

•	Albert Manville PhD, retired Senior Wildlife Biologist. Division of Migratory
Bird Management. U.S. Fish & Wildlife Service. Wash. DC HQ Office (1?
years); Senior Lecturer. Johns Hopkins University

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•	Prof. Tom Butler of the University College in Cork. Ireland's letter to the
FDA

•	Igor Belvaev, PhD. Dr. Sc. Head. Department of Radiobiology of the Cancer
Research Institute. Biomedical Research Center of the Slovak Academy of
Science letter to the FDA

•	Paul Heroux PhD. McGill University

•	Alfonso Balmori, BSc statement to the FDA

•	Additional Statements by Experts

The FCC is considered a Captured Agency with Undue Influence by Telecom

Several experts who provided testimony to the Commission detailing how several
FCC Commissioners have industry ties. Several cited the Harvard Press Book

"Captured Agency: How the Federal Communications Commission is Dominated
by the Industries it Presumably Regulates" by Norm Alster which documents the
financial ties between the FCC, Congress and industry and how wireless
companies have bought "inordinate access to—and power over—a major US
regulatory agency." The investigation puts forward that there is a "revolving
door" between industry and regulators, meaning that persons are moving from
positions in the wireless industry to positions in government and vice versa. In
addition, the book documents the large financial Investment by
telecommunications companies into public relations efforts, designing and
publishing contradictory science, pushing for minimal regulation, lobbying via
"non-profit" associations, and "hyper aggressive legal action and research
bullying."

Examples of the revolving door at the Federal Communications Commission
include:

•	Tom Wheeler: In 2013, President Obama appointed Tom Wheeler to head
the FCC. Wheeler, a fundraiser for Obama in the 2008 election, was a

lobbyist and head of the Cellular Telecommunications and Internet
Association (CTIA). As head of the wireless industry, Wheeler was accused
of suppressing science. A 2003 inductee into the Wireless Hall of Fame (yes,
there is such a thing), Wheeler laid the groundwork for 5G. pushing through
regulations to strip local authority.

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•	Ajit Pai: In 2017, President Trump appointed Ajit Pai, a former Verizon

Lawyer to head the FCC. Pai had already been a member of the
commission, having been appointed by President Obama in 2011 — upon
the recommendation of Senate Majority Leader Mitch McConnell — to fill a
"Republican" seat on the five-member board.

•	Brendan Carr: FCC Commissioner Brendan Carr was appointed by President
Trump. He too is a former lawyer for Wiley Rein and helped sue the San
Francisco over the city's cell phone ordinance. Carr's wife is the staff
director for the U.S. House Ways and Means Committee's Oversight
Subcommittee.

•	Former FCC chairman Julius Genachowski is now a managing director of the
U.S. buyout team at Carlyle Group. The team's focus is on acquisitions and
growth investments in global technology, media, and telecom, including
Internet and mobile.

•	Meredith Attwell Baker: Former FCC Commissioner Meredith Attwell Baker
is now head of the CTIA - The Wireless Association. She is a former lead
lobbyist for Comcast.

•	Michael Powell: Former FCC commissioner Michael Powell is now president
& CEO of NCTA - The Internet & Television Association.

•	Bruce Romano: Former legal chief in the FCC's Office of Engineering and
Technology. Bruce Romano is now at the law firm of Wiley Rein.

representing the CTIA.

•	Thomas M. Johnson, Jr.: Thomas M. Johnson, Jr. is general counsel of the
FCC appointed by Ajit Pai and previously worked for the law firm Gibson,
Dunn & Crutcher LLP which represented the CTIA - The Wireless Association
who sued the City of Berkeley in federal court, seeking to topple the city's
recently enacted cell phone right to know ordinance mandating disclosure
of possible radiation hazards associated with use of cellphones.

In addition, published research has documented conflicts of interest in the
experts that governments refer to.

•	The International Journal of Oncology published "World Health
Organization, radiofrequency radiation and health - a hard nut to crack

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(Review)"80 in 2017 detailing conflicts of interest with ICNIRP and the WHO
EMF Project, both started with industry support.

•	The American Journal of Industrial Medicine published "Secret ties to
industry and conflicting interests in cancer research"81 in 2006 about
industry funding of studies such as the Danish Cohort cell phone studies
that are often put forward as showing no harm.

•	Molecular and Clinical Oncology published "Appeals that matter or not on a
moratorium on the deployment of the fifth generation, 5G, for microwave
radiation"82 in 2020 details how ICNIRP is referred to as "a private German
non-governmental organization. ICNIRP [that] relies on the evaluation only
of thermal (heating) effects from RF radiation, thereby excluding a large
body of published science demonstrating the detrimental effects caused by
non-thermal radiation."

4. Why are the FCC-sanctioned guidelines for public exposure to wireless

radiation based only on the thermal effect on the temperature of the skin and
do not account for the non-thermal, non-ionizing, biological effects of wireless
radiation?

In 1996, just as the EPA was set to release their Phase 1 of safety limits, the EPA's
RFR efforts were defunded, halting all EPA research. That year the FCC adopted
RFR exposure limits based largely on limits developed by industry/military
connected groups (ANSI/IEEE C95.1-1992 and NCRP's 1986 Report).

These FCC limits are only based on protecting against heating (thermal) effects
from short-term exposures. They do not account for non-thermal biological
effects or the effects of long-term, chronic exposures. Furthermore, adequate
scientific data on children's unique vulnerability to RFR was not available at that
time. The US still has no federally developed safety limits, and there has been no
systematic review of the scientific research to develop safety limits that
adequately protect the public from long-term exposures.

80	Hardell L "World health organization, radiofrequencv radiation and health - A hard nut to crack (Review)." IntJ
Oncol. 2017;51(2):405-413. doi:10.3892/ijo.2017.4046

81	Hardell L, Walker MJ, Walhjalt B, Friedman LS, Richter ED. "Secret Ties to Industry and Conflicting Interests in
Cancer Research." Am J Ind Med. 2006. doi: 10.1002/ajim.20357

82	Hardell L, Nyberg R. "Appeals that matter or not on a moratorium on the deployment of the fifth generation. 5G.
for microwave radiation." Mol Clin Oncol. 2020; 12(3):247-257. doi: 10.3892/mco.2020.1984

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Due to the lack of evaluation for long term safety and research that linked
neurological impacts in firefighters to cell antenna exposure, the International
Association of Fire Fighters has long opposed83 cell antennas on fire stations
stating that, "fire department facilities, where fire fighters and emergency
response personnel live and work are not the proper place for a technology which
could endanger their health and safety. The only reasonable and responsible
course is to conduct a study of the highest scientific merit and integrity on the
RF/MW radiation health effects to our membership and, in the interim, oppose
the use of fire stations as base stations for towers and/or antennas for the
conduction of cell phone transmissions until it is proven that such sitings are not
hazardous to the health of our members." The International Association of Fire
Fighters passed a resolution84 that they oppose cell towers on fire stations in 2004
and it remains in effect today.

5. Why are the FCC radiofrequency exposure limits set for the United States 100
times higher than countries like Russia, China, Italy, Switzerland, and most of
Eastern Europe?

The following countries have cell tower network radiofrequency radiation limits
(maximum permissible limits) below ICNIRP and FCC limits: Belarus, Bulgaria,
China, Lithuania, Poland, Russia, Belgium, Chile, Greece, India, Israel, Italy,
Liechtenstein and Switzerland.85 86 87 88 89

The exposure guidelines developed by the FCC and International Commission on
Non-Ionizing Radiation Protection (ICNIRP) were principally designed to protect
against adverse thermal effects and were largely based on studies of short-term
exposures to animals at high power levels. However, countries such as India,

83	Cell Tower Radiation Health Effects - IAFF. https://www.iaff.org/cell-tower-radiation/. Accessed July 8, 2020.

84	https://ecfsapi.fcc.gov/file/109281319517547/20-Attachment%2020-

%20Firefighters%201nter%20Resolution%20Against%20Cell%20Towers.pdf

85	https://apps.who.int/gho/data/node.main.EMFLIMITSPUBLICRADIOFREQUENCY7lang-en

86	Wu T, Rappaport TS, Collins CM. "Safe for Generations to Come." IEEE Microw Mag. 2015;16(2):65-84.
doi: 10.1109/MMM. 2014.2377587

87	Chiang, Huai. "Rationale for Setting EMF Exposure Standards." Zhejiang University School of Medicine,
Microwave Lab, China, as referenced by Wu 2015

88	"Comparison of international policies on electromagnetic fields (power frequency and radiofrequency fields)."
Rianne Stam, National Institute for Public Health and the Environment

89	Mary Redmayne (2016). "International policy and advisory response regarding children's exposure to radio
frequency electromagnetic fields (RF-EMF)." Electromagnetic Biology and Medicine, 35:2,176-185, DOI:
10.3109/15368378.2015.1038832

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China and Russia have much lower limits and are considered "science based."90
They are well below any thermally significant levels to address their own
countries research indicating adverse non-thermal health effects.

•	USSR and Russian standards were based on many areas of research
including impacts to the nervous system and immune system as
documented in the "Scientific basis for the Soviet and Russian
radiofrequencv standards for the general public." Their exposure limits are
set based on protecting against possible biological consequences which is
different than limits by the FCC and ICNIRP, which bases their limits on the
lowest RF exposure that causes any "established" adverse health effect.
Russia limits consider children to be more sensitive to EMFs and in need of
"special consideration when developing exposure limits." According to the
ICNIRP, the following health hazards are likely to be faced in the near future
by children who use mobile phones: disruption of memory, decline in
attention, diminished learning and cognitive abilities, increased irritability,
sleep problems, increase in sensitivity to stress, and increased epileptic
readiness. For these reasons, special recommendations on child safety from
mobile phones have been incorporated into the current Russian mobile
phone standard.91

•	China's cell tower limits are based on science showing effects which include
behavioral, neurological, reproductive abnormalities, and DNA damage.92

•	India dropped their RF limits by l/10th of ICNIRP after a 2010 Government
Report_documented the majority of research studies found adverse effects
to wildlife, birds and bees.93 An August 2012 Advisory by the Ministry of
the Environment and Forests refers to the "negative effects" and makes a
series of recommendations to the government.94 The findings of the report
were later published in the journal Biology and Medicine which concludes
that, "based on current available literature, it is justified to conclude that
RF-EMF radiation exposure can change neurotransmitter functions, blood-
brain barrier, morphology, electrophysiology, cellular metabolism, calcium

90	Wu T, Rappaport TS, Collins CM. "Safe for Generations to Come." IEEE Microw Mag. 2015; 16(2):65-84.
doi: 10.1109/MMM. 2014.2377587

91	"Scientific basis for the Soviet and Russian radiofrequencv standards for the general public."

92	Prof. Dr. Huai Chiang. "Rationale for Setting EMF Exposure Standards." Accessed July 8, 2020.

93	"Report on Possible Impacts of Communication Towers on Wildlife Including Birds and Bees." Ministry of
Environment and Forest, Government of India, 2010.

94	Government of India Ministry of Environment and Forests Office. "Advisory on the use of Mobile Towers to
minimize their impact on Wildlife including Birds and Bees." 2012

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efflux, and gene and protein expression in certain types of cells even at
lower intensities".95

Many European countries have RF limits much lower than ICNIRP as part of their
precautionary approach to decision-making. In 2011 the Parliamentary Assembly
of the Council of Europe issued Resolution 1815: "The Potential Dangers of
Electromagnetic Fields and Their Effect on the Environment",96 a call to European
governments to "take all reasonable measures" to reduce exposure to
electromagnetic fields "particularly the exposure to children and young people
who seem to be most at risk from head tumors." The Resolution calls for member
states to:

•	Implement "information campaigns about the risk of biological effects on
the environment and human health, especially targeting children and
young people of reproductive age."

•	"For children in general, and particularly in schools and classrooms, give
preference to wired Internet connections, and strictly regulate the use of
mobile phones by schoolchildren on school premises."

Resolution 1815 specifically states that governments "Reconsider the scientific
basis for the present standards on exposure to electromagnetic fields set by the
International Commission on Non-Ionizing Radiation Protection, which have
serious limitations, and apply ALARA principles, covering both thermal effects and
the athermic or biological effects of electromagnetic emissions or radiation."

6. Why did the World Health Organization (WHO) signify that wireless radiation is
a Group B Possibly Carcinogenic to Humans category, a group that includes
lead, thalidomide, and others, and why are some experts who sat on the WHO
committee in 2011 now calling for it to be placed in the Group 1, which are
known carcinogens, and why is such information being ignored by the FCC?

In 2011 wireless radiofrequency radiation was classified as a "Possible Human
Carcinogen" by the International Agency for Research on Cancer (IARC) of the
WHO based on research that found an increased risk for glioma, a malignant type

95	Sivani S, Sudarsanam D. "Impacts of Radio-Frequency Electromagnetic Field (RF-EMF) from Cell Phone Towers
and Wireless Devices on Biosvstem and Ecosystem - a Review." Biology and Medicine Vol 4.; 2012.
www.biolmedonline.com. Accessed July 8, 2020.

96	Resolution 1315: "The Potential Dangers of Electromagnetic Fields and Their Effect on the Environment."

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of brain cancer, associated with wireless phone use.97 The WHO/IARC Class 2B
classification includes wireless radiation from any transmitting source including
cellphones, baby monitors, tablets, cell towers, radar, other Wi-Fi, etc. The
classification applies to RF-EMF in the range of 30 KHz to 300 GHz emitted from
any equipment- not just cell phones. This fact is detailed in the Lancet's published
statement and in the related press release in 2011.

Precautions for cell phones were recommended by then IARC Director
Christopher Wild in the WHO/IARC press release for the Class 2B Carcinogen
classification with quotes from Wild as stating, "Given the potential consequences
for public health of this classification and findings, it is important that additional
research be conducted into the long-term, heavy use of mobile phones. Pending
the availability of such information, it is important to take pragmatic measures to
reduce exposure such as hands-free devices or texting."

After the 2011 classification, the WHO/IARC issued a monograph documenting all
the research underpinning the 2011 classification.98

The 2013 published monograph also references children's higher exposures as
compared to adults and states, "the average exposure from use of the same
mobile phone is higher by a factor of 2 in a child's brain and higher by a factor of
10 in the bone marrow of the skull."

The reason that scientists are calling for a change to the classification is that since
the 2011 classification, the evidence for adverse effects in the published research
has increased. Cancer is only one of the issues that have been investigated. Here
are some of the studies often mentioned by scientists:

•	The National Toxicology Program studies on cell phone radiation in animals
found clear evidence of carcinogenic activity, in male rats and DNA damage

in the nontal cortex of the brain in male mice, the blood cells of female
mice, and the hippocampus of male rats.

•	The multicenter case-control study Coureau et al. 2014 found statistically
significant positive association between brain tumors and cell phone use in
the heaviest cell phone users when considering life-long cumulative
duration.

97	IARC classifies Radiofrequencv Electromagnetic Fields as possibly carcinogenic to humans

98	Monograph on Non-Ionizing Radiation. Part 2: Radiofrequencv Electromagnetic Fields.

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•	An animal study Lerchl 2015 replicated a previous study that found at very
low levels, radiofrequency can promote tumors.

•	Falcioni et al. 2018 found a statistically significant increase in the incidence
of heart Schwannomas in male rats exposed to radiofrequency radiation at
levels below FCC limits.

•	Yale research funded by the American Cancer Society" found thyroid
cancer associated with cell phone use in people with genetic susceptibility.

•	Additional Yale research100 found prenatal radiofrequency radiation
exposure led to higher hyperactivity, poorer memory, and altered brain
function in mice,101 corroborating prior published research findings of
altered brain development after exposure.

•	A 2018 study102 looking at hundreds of adolescents found memory damage
in the brain receiving some of the higher radiofrequency cell phone
radiation exposures.

•	A 2015 review study103 found among 93 of 100 currently available peer-
reviewed studies dealing with oxidative effects of low-intensity RFR,
confirmation that RFR induces oxidative effects in biological systems.

The evaluation by some scientists that wireless is carcinogenic due to this
increased body of published research can be found in Hardell and Carlberg 2017
and Miller et al. 2018.

Several scientists who were members of the WHO IARC 2011 monograph
classification have publicly stated that the evidence on the carcinogenicity of RF
has increased and that the classification of "possible carcinogen" is outdated and
should be upgraded based on increased evidence of adverse effects.

99	Jiajun Luo et al. "Genetic susceptibility may modify the association between cell phone use and thyroid cancer: A
population-based case-control study in Connecticut." Environmental Research (2019).

100	Aldad, T., Gan, G., Gao, X., & Taylor, H. (2012). "Fetal Radiofrequency Radiation Exposure From 800-1900 Mhz~
Rated Cellular Telephones Affects Neurodeveiopment and Behavior in Mice." Scientific Reports, 2(1).
https://doi.org/10.1038/srep00312

101	Cell phone use in pregnancy may cause behavioral disorders in offspring

102	Foerster, M., Thielens, A., Joseph, W., Eeftens, M., & Roosli, M. (2018). "A Prospective Cohort Study of
Adolescents' Memory Performance and Individual Brain Dose of Microwave Radiation from Wireless
Communication." Environmental Health Perspectives, 126(7), 077007. https://doi.org/10.1289/ehp2427

103	Yakymenko, I., Tsybulin, O., Sidorik, E., Henshel, D., Kyrylenko, O., & Kyrylenko, S. (2015). "Oxidative
mechanisms of biological activity of low-intensity radiofrequency radiation." Electromagnetic Biology and
Medicine, 35(2), 186-202.

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•	Dr. Lennart Hardell in Case-control study of the association between
malignant brain tumours diagnosed between 2007 and 2009 and mobile
and cordless phone use: "This study confirmed previous results of an
association between mobile and cordless phone use and malignant brain
tumours. These findings provide support for the hypothesis that RF-EMFs
play a role both in the initiation and promotion stages of carcinogenesis."

•	Dr. Chris Portier: "A careful review of the scientific literature demonstrates
there are potentially dangerous effects from RF," stated Portier, a recently
retired CDC Director, Center for Environmental Health and the Agency for
Toxic Substances and Disease Registry in his official call for invoking the
precautionary principle with wireless radiation in a 2015 conference. See
also a poster presentation he penned for the conference here.

•	Dr. Igor Belyaev: "There are many publications showing health effects of
radiofrequency radiations. Approximately half of all published papers show
such effects." (National Press Club. 2012. He has published findings of
adverse effects in several publications.)

•	Dariusz Leszczynski, WHO IARC expert, former Finnish government
researcher stated in 2015 "The IARC-WHO classification of cell phone
radiation is misrepresented by the industry. Classification of cell phone
radiation as 'a possible carcinogen to humans' means that there are enough
studies indicating that it might cause cancer and that we urgently need
more research to clarify this issue. The strongest evidence that it might be
causing cancer comes from three epidemiological studies. In 2011, only two
sets of studies were available - Ell's Interphone study and a series of
studies from Lennart Hardell's group in Sweden. Recently, CERENAT study
from France published in 2014, similarly indicated that persons using cell
phones for more than ten years and for half hour per day are at a higher
risk for developing brain cancer. In fact now the evidence is sufficient to
consider cell phone radiation as a probable carcinogen - Group 2A in lARC's
scale of carcinogenicity."

•	Ronald Melnick, retired NTP staff scientist has written extensively on this
topic and states in Health Physics 2020, "The NTP studies show that the
assumption that RF radiation is incapable of causing cancer or other
adverse health effects other than by tissue heating is wrong."

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• Anthony B. Miller, who served as an editorial reviewer of the 1ARC
monograph, has also written that if an IARC panel were to review the
science at this point they would conclude that it should be reclassified as
category 1, a human carcinogen.

In 2019, an advisory group of the International Agency for Research on Cancer
(IARC) of the World Health Organization, consisting of 29 scientists from 18
countries, released new recommendations to reassess as a "high priority" the
cancer risks of radiofrequency radiation between 2020-2024. The
recommendations were published in The Lancet Oncology on April 18, 2019.

7. Why have more than 220 of the world's leading scientists signed an appeal to
the WHO and the United Nations to protect public health from wireless
radiation and nothing has been done?

Over 393 scientists and doctors from 35 countries have signed on to a declaration
called the 5G Appeal,104 sent to officials of the European Commission, calling for a
moratorium on the increase of cell antennas for planned 5G expansion because
"5G will substantially increase exposure to radiofrequency electromagnetic fields
(RF-EMF) on top of the 2G, 3G, 4G, Wi-Fi, etc. for telecommunications already in
place. RF-EMF has been proven to be harmful for humans and the environment."

In addition, the 5G Appeal references the 2015 Scientistic Appeal to the United
Nations published in the European Journal of Oncology105 now signed by 253
scientists who have published research on electromagnetic radiation which states
that, "numerous recent scientific publications have shown that EMF affects living
organisms at levels well below most international and national guidelines. Effects
include increased cancer risk, cellular stress, increase in harmful free radicals,
genetic damages, structural and functional changes of the reproductive system,
learning and memory deficits, neurological disorders, and negative impacts on
general well-being in humans. Damage goes well beyond the human race, as
there is growing evidence of harmful effects to both plant and animal life."

104	The 5G appeal - 5G Appeal 5G Appeal. Accessed July 8, 2020.

105	EMFscientist.org - International EMF Scientist Appeal. Accessed July 8, 2020.

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Why has nothing been done?

The Scientific Appeal states that "the various agencies setting safety standards
have failed to impose sufficient guidelines to protect the general public,
particularly children who are more vulnerable to the effects of EMF." The
International Commission on Non-Ionizing Radiation Protection (ICNIRP)
guidelines do not cover long-term exposure and low-intensity effects, yet they are
used by many governments as safety limits. The EMF scientists contend that the
ICNIRP guidelines are insufficient to protect public health.

Dr. Lennart Hardell published a paper entitled, "Appeals th; ' ter or not on a
moratorium on the deployment of the fifth generation. 5G. for microwave
radiation" explaining how ICNIRP is a private German non-governmental
organization of 13 people that "relies on the evaluation only of thermal (heating)
effects from RF radiation, thereby excluding a large body of published science
demonstrating the detrimental effects caused by non-thermal radiation." He
contends that ICNIRP has disregarded research and that their safety guidelines
are obsolete and protect the industry, not health. Hardell describes the
communications between decision makers and the scientists and concludes that
"the majority of decision makers are scientifically uninformed on health risks from
RF radiation." In addition, they seem to be uninterested in being informed by
scientists representing the majority of the scientific community, i.e., those
scientists who are concerned about the increasing evidence or even proof of
harmful health effects below the ICNIRP guidelines (www.emfscientist.org).
Instead, they rely on evaluations with inborn errors of conflicts, such as ICNIRP.

8. Why have the cumulative biological damaging effects of ever-growing

numbers of pulse signals riding on the back of the electromagnetic sine waves
not been explored, especially as the world embraces the Internet of Things,
meaning all devices being connected by electromagnetic waves, and the
exploration of the number of such pulse signals that will be created by
implementation of 5G technology?

There are extensive data gaps regarding human exposure to wireless devices and
the complexity of the waves we are exposed to. Most studies have not adequately
explored all of these characteristics but instead only focus on power density.

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"Adverse Health Effects of 5G Mobile Networking Technology Under Real Life
Conditions"106 published in Toxicology Letters states "the typical incoming EMF
signal for many/most laboratory tests performed in the past consisted of single
carrier wave frequency; the lower frequency superimposed signal containing the
information was not always included. This omission may be important. As
Panagopoulos states: "It is important to note that except for the RF/microwave
carrier frequency, Extremely Low Frequencies - ELFs (0-3000 Hz) are always
present in all telecommunication EMFs in the form of pulsing and modulation.
There is significant evidence indicating that the effects of telecommunication
EMFs on living organisms are mainly due to the included ELFs.... While ~50 % of
the studies employing simulated exposures do not find any effects, studies
employing real-life exposures from commercially available devices display an
almost 100% consistency in showing adverse effects" (Panagopoulos, 2019).
These effects may be exacerbated further with 5 G: "with every new generation

of telecommunication devices	the amount of information transmitted each

moment	is increased, resulting in higher variability and complexity of the

signals with the living cells/ organisms even more unable to adapt"
(Panagopoulos, 2019)."

This is an area that requires adequate research before deployment.

106 Kostoff RN, Heroux P, Aschner M, Tsatsakis A. "Adverse health effects of 5G mobile networking technology
under real-life conditions." Toxicol Lett. 2020;323:35-40. doi: 10.1016/j.toxlet.2020.01.020

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Appendix D

Sampling of Scientific Studies Pertaining to Cellphone Radiation

CANCER

2018 U.S. National Toxicology Program (NIP) & Italian Study Confirm Cell
Phones Cause Cancer

ฆ	See the NTP website which indicates radiofrequency radiation is associated
with "Clear evidence of tumors" -- the highest warning they can issue:

hi 11y 11ir-1niซ 11s.nih.gov/whatwe511'ฆ<, iฆ i tics/cellphones/index.html?utm

souirce=d11'ซ ซ i' .• n"1111 n iซ *'ii 1111 j i	!' i 11111 ฆ -in 11 • i; i i=ntpg- ฆ 1111II ;•' .• n"1111 i< ir

ellphone

>	In the following article, study designer and former NTP Senior Scientist
Ronald L. Melnick, PhD., counters with facts the industry spin intended to
downplay the NTP study findings:

hi iii ฆs://www.sciencediirect.c- ฆ[11 ฆ :ien- ฆ >i i;u h | <11 ,•< " 1i i 1 !'ฆ ,-ฆ i
a

ฆ	In January 2020 the National Institutes of Environmental Health (NIEHS)
published the following article from NTP scientist Michael Wyde,

Ph.D., confirming brain, heart and adrenal tumors and that more research
is underway to understand the impact of adding 5G millimeter waves to the
existing exposures from 2G, 3G and 4G radiation:
hi i ii ฆs://factoir.niehs.nih.gt	l iHiiinuiiit, mi i hi -act/5g~

technology/inde

>	See study findings by the Ramazzini Intstitute study in Italy, which
corroborates the NTP study findings:

hi iii ฆs://www.sciencediirect.c- ฆ[11 ฆ :ien- ฆ -i i;k l< | l i i "tฆ ii
a%3 Dili ub

>	Longtime World Health Organization advisor Anthon'	, and
other experts, confirm radiofrequency (RF) radiation from any source now
fully meets the World Health Organization criteria to be classified as a
"Group 1 carcinogenic to humans" agent:

hiiiiฆs://www.sciencediirect.c- ฆ[11 ฆ :ien- ฆ >i i;u h (in ,•ป"ป1 lyV i i ! 'ฆ ii
a%3Dihub

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>	BioMed Research International published a peer-reviewed study by Michael
Carlberg, MSc, and Lennart Hardell, M.D., Ph.D. concluding "RF radiation
should be regarded as a human carcinogen causing glioma."

hi 11 s://www.hindawi.com/iM ปi 11 him i 11 , ' 1

>	In 2018 IEEE Microwave Magazine published, "Clear Evidence of Cell Phone
RF Radiation Cancer Risk" by Dr. James Lin:

hi 11y , I- ^explore.!- , , * -i • ฆ ^	1u 11, 1 it/842505-> ฆ 1 > -i 1 1

Dr. Lin's article is also available in full here:
http://www.avaate.org/lf If/llin 2018.pdf

INFERTILITY

>	Dr. Martin Pall's 2018 paper, "5G: Great risk for EU, U.S. and International
Health! Compelling Evidence for Eight Distinct Types of Great Harm Caused
by Electromagnetic Field (EMF) Exposures and the Mechanism that Causes
Them" indicates much of the damage from wireless radiation is cumulative
and some becomes irreversible.

His paper includes 16 scientific reviews (each referencing multiple
individual peer-reviewed published studies) which include a wide variety of
changes leading to lowered male fertility, lowered female fertility,
increased spontaneous abortion, lowered levels of estrogen, progesterone
and testosterone, and lowered libido.

The European Academy of Environmental Medicine provides Dr. Pall's
paper here:

11111 v , ฆ 11 'ropaem.eu/attachments/article/131/2018-04 EU-EMF2018-

5US.pdf

- See the 2018 paper, "Radiations and male fertility":

https: //if be i. bi 01m ed cent in ฆ II	111 -i 1 ik les/10.1186/sl?' <11 <11 1

ฆ See also abstracts for eight review papers and links to 40+ studies as
collected by Dr. Joel Moskowitz:

11111 s://www.- •!ซ 1" nil ฆ hiii ^ซ11; . ill, , 1 . .| 		hilt |-.||. nes-on-

sperm.html

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>	These studies address male fertility issues and wi-fi:

hup	II i1 II" il II i IIII11 II i IIII i 1' *1' pi'hi i h U 11 11 I I 1111 !

II Hi 11 ">	ii i" II \i ii illii 11 ii mil i • | ii 11" -i I ii les/PMC3778601/

hi 11 s://www.nchi i ih 11 ii mil i • ov/pubmed/28967'ป-1

ฆ	A 2017 study, "Temporal trends in sperm count: a systematic review and
meta-regression analysis" shows sperm counts dropping dramatically:

hup, , adeinh ^up ฆ hh liiumip^ -i h< l< , A,| in h'-'y hi'im'iu! Jiimtx022/

!t >,>1 " ฆ Pi ii i ii| -I ฆral-trends-in-sperm-count-a-svstfe ii 11 i ii -review

- Kaiser Permanente scientists completed a study that concluded non-
ionizing radiation more than doubles the risk of miscarriage:

11hi iks://www.ncIt-ii ii illii in ii mil i 'v p-111ฆ 'i iides/PI\ h ' 11 1 i1

>	The EPA provides an understanding of how DNA mutations from radiation
affect what we pass on to our offspring genetically:

1111p>	'ฆ in ฆ ฆ ฆ v/radiatic 11 understand In >lih < III' ซ P- hiinl

ฆ	The following link provides an audio track from a 2013 conference led by
leading U.S. experts in, "Cell Phones & WiFi - Are Children, Fetuses and
Fertility at Risk?"

11ffp 'glectromagnetichealth.org/electromagnetic-health-M- ,-eiiiin -ii

in ii o ^

ฆ	Barrie Trower, PhD, "WiFi Report - Humanity At The Brink," September
2013, shows how wi-fi exposure now will affect fertility in the future:

Imp	• > engine • i in-- h h;- h >i 11> I ii i ฆฆ ver-wifi-repci I hum nil ,

at-the-brink/

>	A quick search of the National Institutes for Health (NIH) PubMed
database on "emf fertility" returns a multitude of other studies from
around the world:

hi ip	in- hi nhii nih ••'i'- in piiihiii! J ฆ i< i im=t ml ii Ih. i liilliii ,

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ELECTROMAGNETIC SENSITIVITY

While adverse effects of long-term exposure to wi-fi radiation, like cancer,
infertility and DNA damage may not surface in some for years, there are ma