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:
» 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 o»t 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 Ane» 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.
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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.
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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.
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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
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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 ..,..§46
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
»Y 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
-------
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 i«>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. § 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 \ £.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
-------
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
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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.
© 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
C«ll Phono
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106 10s 1010 10" 10" 10te 101S 1C;<> 1022 1C24 10*
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Ionizing radiation
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Figure Is The electromagnetic spectrum.
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 °F 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 90°, 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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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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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 ± 0.82 V/m; 1.48 (iW/cm2) than on
nests further than 300 m (0.53 ± 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 °C [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
DE GRUYTER
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 60°. 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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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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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
+10° 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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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 ± 0.05 V/m; Limnos:
0.21 ± 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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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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40 — Levitt et al.: EMF and wildlife
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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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42 — Levitt et al.: EMF and wildlife
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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 ± 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 ± 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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50 — Levitt et al.: EMF and wildlife
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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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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 °C,
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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60 — Levitt et al.: EMF and wildlife
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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.
-------
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.
-------
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.
-------
45 min; SAR 0.04
W/kg
Kele§and 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
-------
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
-------
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.
-------
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 (±6.46)
and 22.5 V/m
(±5.38), 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
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-------
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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.
Kele§ 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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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
-------
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 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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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,
« Legally required warning signs are posted,
• Any needed barriers are in place, and
« 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 i§p©rts 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 * ¦ {•;:* ;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 i®«s 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~§7# if Sttfcjtcfei to such a full analysis, will earn a failing grade.
* A report from Tech Wise Mo C c MP
M«igiWKff 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
£g
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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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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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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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. § 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. § 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
-------
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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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
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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
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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
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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.
S. 186 Wireless Radiation Commission
April 14, 2022
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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.
S. 186 Wireless Radiation Commission
April 14, 2022
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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.
S. 186 Wireless Radiation Commission
April 14, 2022
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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.
S. 186 Wireless Radiation Commission
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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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April 14, 2022
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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
S. 186 Wireless Radiation Commission
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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
-------
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
-------
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.
-------
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.
2
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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 , ¦ ¦ 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. § 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
23
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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. § 151.
37 Id. § 303(e).
24
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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. §§ 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).
25
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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. § 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.").
26
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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).
27
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APPENDICES
28
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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 »
~ microwaves
< »
visible
gamma
cosmic
x-rays rays
A ~
J
Jz
!fl
t
m
C^Ei) A
F
1
¦
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
33
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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
34
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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
35
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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.
37
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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
45
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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
46
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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.
47
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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
48
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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< ¦ 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\¦ « 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^¦ I«ih i, dio
is in German
• "'i11 'i1IIII '1 ¦ -II II ¦ -ii idon Report on Electromagnetic Fields
• 2009 Austrian Accident Insurance Institute Report on Health Risks from Cell
Phone Radiation "Nonthei m I II ll< ¦ I;- ^-1 II l< ¦ 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."
49
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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>i¦ nJ ll« •.inn;-1\i|Uii ¦ 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.
50
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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
67
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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.
72
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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
¦ See the NTP website which indicates radiofrequency radiation is associated
with "Clear evidence of tumors" -- the highest warning they can issue:
hi 11y 11ir-1ni« 11s.nih.gov/whatwe511'¦<, i¦ i tics/cellphones/index.html?utm
souirce=d11'« « i' .• n"1111 n i« *'ii 1111 j i !' i 11111 ¦ -in 11 • i; i i=ntpg- ¦ 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 ¦s://www.sciencediirect.c- ¦[11 ¦ :ien- ¦ >i i;u h | <11 ,•< " 1i i 1 !'¦ ,-¦ i
a
¦ 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 ¦s://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 ¦s://www.sciencediirect.c- ¦[11 ¦ :ien- ¦ -i i;k l< | l i i "t¦ 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:
hiiii¦s://www.sciencediirect.c- ¦[11 ¦ :ien- ¦ >i i;u h (in ,•»"»1 lyV i i ! '¦ ii
a%3Dihub
75
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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 »i 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 • ¦ ^ 1u 11, 1 it/842505-> ¦ 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 , ¦ 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 ¦ II 111 -i 1 ik les/10.1186/sl?' <11 <11 1
¦ See also abstracts for eight review papers and links to 40+ studies as
collected by Dr. Joel Moskowitz:
11111 s://www.- •!« 1" nil ¦ hiii ^«11; . ill, , 1 . .| hilt |-.||. nes-on-
sperm.html
76
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> These studies address male fertility issues and wi-fi:
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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'»-1
¦ A 2017 study, "Temporal trends in sperm count: a systematic review and
meta-regression analysis" shows sperm counts dropping dramatically:
hup, , adeinh ^up ¦ hh liiumip^ -i h< l< , A,| in h'-'y hi'im'iu! Jiimtx022/
!t >,>1 " ¦ Pi ii i ii| -I ¦ral-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-111¦ '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> '¦ in ¦ ¦ ¦ v/radiatic 11 understand In >lih < III' « P- hiinl
¦ 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 ^
¦ 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 ¦¦ 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 ¦ i< i im=t ml ii Ih. i liilliii ,
77
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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 many
who suffer immediate effects when exposed to wireless radiation. Health care
providers are now learning to diagnose and treat environmentally induced
electromagnetic sensitivity, or ES, also known as microwave sickness. Training for
doctors, nurses, first responders and others will be proved in the continuing
medical education (CME) accredited EMF Medical Conference 2021,
11111 >,• ,« n 11¦ onference2021.com/.
Those who suffer from ES can feel the radiation hitting various biological systems
when they encounter cell towers, small cell antennas, routers, access points,
cordless phones, smart meters, laptops, iPads, tablets, baby monitors, fluorescent
lights or any other devices pulsing signal. Patients experience a myriad of
immediate or latent symptoms that may include pain, tightening in the chest or
skull, altered heartbeat, tinnitus or ringing in the ears, headaches, nosebleeds,
insomnia, fatigue, diminished concentration, cognitive impairment, poor memory,
behavioral issues, anxiety, depression, anger, suicidal ideation and more.
Symptoms can disappear or diminish over time when exposure to
electromagnetic fields (EMFs) is eliminated.
Following is a sampling of the science and actions being taken by the medical
community, followed by recognition of ES by the Americans with Disabilities Act:
> Dominique Belpomme and Philippe Irigaray: "Electrohvpersensitivitv as a
Newly Identified and Character! ¦ J 11« iu^Io; iu 11 ¦thollogicall Disorder: How
to Diagu H v < 11 ¦ •!, -I h' I 'ii ¦ • eint It." /ntJ Mol Sci. 2020 Mar; 21(6): 1915.
- "Electromagnetic Field Sensitivity," Journal of Bioelectricity: Vol 10, No 1-2.
¦ l'< pNcaiiHi -I In; -iii i.'i't ii'I-.illi i!¦!ovocation study
- McCarty DE et al, (December 2011) "Electromagnetic hypersensitivity:
evidence for a novel neurological syndrome," IntJ Neurosci. 2011
Dec;121(12):670-6. Epub 2011 Sep 5 [View Authoi tract conclusions!
[ ]
- Nishimura T et al, (March 2011) "A 1-uT extremely low-frequency
electromagnetic field vs. sham control for mild-to-moderate hypertension:
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a double-blind, randomized study," Hypertens Res. 2011 Mar;34(3):372-7.
Epub 2011 Jan 20 [View Author's abstract conclusion ] f iw on Pubmedl
- See other EHS papers at Physicians for Safe Technology:
hiip,- , iml- •!< i< ¦ Hi 'i'ii •• I- nce/es-scien- ¦
> The United States Access Board's IEQ. Indoor Environmental Quality Project
indicates electromagnetic sensitivities may be considered disabilities under
the ADA:
11111 ¦s://www.access-b- ¦ -i ¦!; ¦ ¦ i ¦ < rch/comoleted-research/indoor-
en vi ronmenta l-qua litv/i ntrod u cti on
> The Access Board recommends the following accommodations:
11111 ¦s://www.access-b- ¦ -i ¦!; ¦ ¦ i ¦ < rch/comoleted-research/indoor-
environmental-Ci'" -hI, i -inni« i idations-for-aca-i dations
> Job Accommodation Network (JAN) is one of several services provided by
the U.S. Department of Labor's ¦ 'Hi I 11 ^ -hilii I injh¦, 11n mi I '¦ -lh
. JAN offers the following Accommodation Ideas for Electromagnetic
Sensitivity:
II1111 -> v II j 'ii' -I; • ¦ ¦ -I ¦ i her/electric. I II11 n iII
VULNERABILITY OF CHILDREN
¦ Bioelectromagnetics expert Dr. Om Ghandi published in IEEE Access, "Yes
the Children Are More Exposed to Radiofrequency Energy From Mobile
Telephones Than Adults":
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pe=Jouirnals%20%26%20Magazines
> Pall, M. L. (2016). "Microwave frequency electromagnetic fields (EMFs)
produce widespread neuropsychiatric effects including depression." Journal
of Chemical Neuroanatomy, 75(Pt B), 43-51.
http ij.org/10.1016/i.ichemne'» »15.08.001
¦ Warnke, U., & Hensinger, P. (2013). "Increasing incidence of burnout due to
magnetic and electromagnetic fields of cell phone networks and other
wireless communication technologies." (Original: Steigende „Burn-out"-
Inzidenz durch technisch erzeugte magnesche und elektromagnesche
Felder des Mobil- und Kommunikaonsfunks, Umwelt-medizin-gesellschaft,
26(1), 31-38.
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79
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> Martha Herbert, PhD, MD, a leading neuroscientist and autism expert,
"Findings in Autism (ASD) Consistent with Electromagnetic Fields (EMF) and
Radiofrequency Radiation (RFR)":
11111 > , I >i")initiative.org/wp-
D ¦!!1 * ml UpK-ads p^b ,M ¦ 'M N 11 11 I III I Jill i;-. Ill 11III,| III p.!|
¦ Dr. Toril Jelter, pediatrician and general practitioner, discusses EMF, Autism
and Child Behavior in an 8-minute video. She prescribes a two-week trial
with limited wi-fi exposure and patients often have remarkable results in
just a few days:
II ill 11'-s://www.voutube.com/wat-1 hi! 'i * ¦ ill I1
- Hugh Taylor, MD, Yale University discusses ADHD symptoms seen in mice
exposed to cell phone radiation:
://vimeo. com/73806192
- Studies have found adverse effects on offspring from prenatal exposure to
wireless radiation:
Imp •!< i. nil .hiii "'el ! i'6/inni ,-i •(< im hi i-ii-pregnancv-
and.html
¦ Dr. Toril Jelter, pediatrician and general practitioner, discusses EMF, Autism
and Child Behavior in an 8-minute video. She prescribes a two-week trial
with limited wi-fi exposure and patients often have remarkable results in
just a few days:
hi 11 ¦s://www.voutube.com/watch?v=' Mil 'i * ¦ ill II (llIk
- Barrie Trower, a former physicist with the British Royal Navy and expert in
radiation, explains in the following two-part lecture the dangers of using wi-
fi radiation. He is particularly concerned for the welfare of children and
fetuses:
| ill |; >P -I ill I ill m ¦ i '| 11 ' . *1 • III" ' 1 ••¦IlliK M •Mile
tube, com/watch ?v=UhcuSEHVOSM
¦ The ii 11 * ii ii" -in ¦ "!• in , ¦ 'III in mi - -I imental Medicine has issued an Open
Letter to the Superintendents imploring them to protect our children.
¦ The American Academy of Pediatrics (AAP), representing 60,000
pediatricians, in December 2012 urged Congress to protect children from
the dangers of wi-fi. "It is essential that any new standards for cell phones
or other wireless devices be based on protecting the youngest and most
vulnerable populations to ensure they are safeguarded through their
80
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lifetimes." The full letter is published here:
II1111'¦ • • • < Ik«i ii iiiik ¦-prevention i ¦ -i*. ¦ ll-phone-safetv-
can-academv-of-pediatrics-supports-rf-protection/
In addition to the biological effects of radiation on children, science is showing
excessive screen time is causing addiction, impairing our children's ability to
function and is degrading family and social relationships. Here is a sampling of
books that bring forth the science and safe technology solutions:
> Dr. Nicholas Kardaras, addiction expert, has clinically worked with more than
a thousand teens. He published the book Glow Kids which shows how screen
addiction is hijacking our kids and offers strategies to break the trance.
> Dr. Catherine Steiner-Adair offers The Big Disconnect, which takes one
through technology's impact at each stage of child development. Basically,
the left side of the brain where math and science are housed is still
developing on point. The right side, however, is not in many children. This is
where a child's ability to show empathy, employ coping strategies, make
eye contact, and self-sooth are housed. In humans, we need regular human
contact and deep meaningful interactions with loved ones and teachers to
develop these properly. Children also need unstructured time for
imaginative play to develop deep parts of our brains. Although well-
intended parents think providing their children with technology will give
them a leg up, the research is proving otherwise as we begin to see scores
dropping after upping technology time, and behavioral and mental health
issues are escalating.
¦ In Reset Your Child's Brain, Dr. Victoria Dunkley explains the myriad ways in
which children can be harmed by electronic screen syndrome (ESS).
Biologically, electronic screen exposure can cause a chronic fight or flight
response, and hit the same opiate receptors in the brain as drugs and
alcohol causing addiction. Children with attention issues and those with
autism are at higher risk of addiction. If not given appropriate time to rest
and regenerate, children begin to suffer chronically. Common symptoms
are irritability, depression and mood swings. As ESS progresses, mood
disregulation may combine with aggression causing some to be diagnosed
with bi-polar disease. Others may develop obsessive-compulsive behavior,
nightmares, panic attacks, tics, seizures, etc., as the effects take hold on the
brain. Dr. Dunkley demonstrates how freedom from electronic screens can
81
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change the brain and alleviate or significantly reduce many of these
symptoms. She offers a four-week plan to reverse the effects of ESS. See
also her article in Psychology Today.
- Paula Healy steps us through the psychological and neurological impact of
screentime in this 37 minute talk, How our Digital Obsession is Dumbing us
Down:
11111 ¦s://www.voutube.com/wat' II i ¦1 11 ¦ II 1 IIII111 -9rA&feature=voutu.be
> Dr. Marilyn Wedge explains how screens are impairing development
in "Virtual Autism" May Explain Explosive Rise in ASD Diagnoses:
¦ 1111IV ,' ' ' in '^in ln>nes-children-silicon-
3n=cllick&contentCollllection=undefined&contentPllacement
!' 11 n¦J11 ill, strc 'in 1 »ihi 1 &pgtvpe=collection&iregion=stireaim&inref=collecti
on% llie-bowles&ve irs i o n=II at est
¦ Silicon Valley Nannies Are Phone Police for Kids: Child care contracts now
demand that nannies hide phones, tablets, computers and TVs from their
charges.
11 hiiks://www.nyiiihi, • ¦ hm i< 1 ,-1 II, ,-iiI1ik on-vallev-nannies.html
82
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Appendix E
Challenges to the Radiation Exposure Standards
Set by U.S. Regulatory Agencies
Organizations Recommending Reducing Wireless Radiation Thresholds
I ., nj;,, > I i.. i II i, lliii,.!;, -in i iiii«;.ii |. | hi||.!|. .!¦ ..| -uentists
American Academy of Pediatric: I < 11, iiv * •llllin; Ih i i|u! • inn; r -Ji -Hihii
Standards
II 11 1 1 •• 'i111 I • I erts Nati( -i i -II 1 ¦> II '< • ¦ -In"I h -i i
II II III ^ ieniL-i r>| m al
llni, rnatioii -II i« i, "II II ihl- IIhi II if in hi hi m, 11f (3j3e -II ll"i •1 ¦.
t in d s 1111
I h< IIII III * 'II ll'i ¦ in ¦ II iiii ill • lb -I II • || >¦ villi ¦ !>¦ II lit ¦ ibro magnetic Fields
* i' inn • II I edit -II ociation
Scientis dian Doctor Appeal on 5G
Ont. 11" ¦ II1 i ¦ -I || >j» -II -i n' H -I ii i h ii II licrosoft Canada President
I li< I (ih.|-.< -in ¦ "Jen i ii II ii * hi ii i ii ii ii mi, , ^ .| i II, .i|i|i( I ir. n\.iihi, ni -II -im I in, i.-nig
Worcester School's Standing Cc nsulted with the Massachusetts
Department "II II i ¦idemiologv - Best Practice II liniini in; II .|uvui. k¦ I I
II i,-IIII ii .ii-.' 1 II i tional Ag' ii' IIhi II II in- mi I-! hi in, ni -II -ii H" xupational
IIII, -lili ,• -I, i II', ':om mends Moderg'1, M-, "II , ii« II, •• * hi hih iuhik -iioji
I, ¦ llinollogies by ChiU h ¦ 11
II i,-IIII ii .ii-.' 1 II i ¦tional Ag- n> IIhi II iu.J, II n- in hhui, ni -II nJ :cupational
IIII, •llilli,-'ll,i I', ¦:ommends Liiniiin • lh, Iv-pul 'linn',- II • idoshI' i¦¦ ri
Won U IIII, -III II i ¦ -ii;¦nizatioi illni, riiati- -n ¦! -'in, II ¦ ¦ ii II1, •< -iih.
New Jersey Educati- -in iatK-n II In ni mi ¦ IIII, -llilli ll'hll ,• Iiihiii II II, -Ironic
Devices
83
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Environment tinology, Exposures. Health
Effects
Irish Doctc Association
Bioinitiative Wot I iiii-- Mh-un 11 11 I \ iu-rt on Biologically Bast <> II • 1 >" hi ¦
Standards
IIIH< rnation -II |->| >< -II 1 ¦ ¦ 1 ¦ -i >1 ¦ ¦ ¦ -i 1 II -i 1II1 -inl 111 1. e. Scientists (4,503),
Enginec 11 • i * Medical Doctors >i, 1 iinii si 1 1 « II 'chologists.
Psychotherapists and Social Workers(9,663)
Gem 1 -11 II 11 11 * hi imental Organisation "Bui ul1 II '¦ 1 ii 101 1 1 ¦ ¦ 1 ¦ -|.1 ¦ > in
Hamburg
Germ -in II1 Ihi II '¦ :legatit-i 1 11 n II < n«:i 1*. hum II Iiul-iu II i« i,-« limn nn
IIII111 -iDQCirates Electro |.|.« >1. .| II v II«¦ 1 n •.:r1 > II !!« .'IllII1 ll'ivlkssioinal
Signatures
I Mi- pi 1 -in II U uj. -II Jatii ¦ ¦ 11 " * .nil",- 11 -iional Coinim! i* < Hiihe
Environment '-i nl * IInKl II!!« 'IllII1 II'("II -lie Health Dan,- ¦ 1 • II1 ¦ -i 11 1II i< 1 ¦.
voir Ik
California Pet ipsure to
T ""i" 'III > "i(i< ii' II iihih * ¦ IIII llh-nes
I In II' 'h • •!< Il'i"-ii" ¦ 1 III" .ill II1 II T'l "II" si on •!,• , in *-l II • ngers of Wireless
Radiatic gin a 11 cy
I mi 111 II I< Jik -II "*"dath"ii 'i"ll III -II * Hi 1 iges in the Law on Electromagnetic
Radiation Needed
II '¦ i> -ii 11 in hi ¦-II I '¦ "li -ii ii,- -i IIII "dassah Hebirc linn ¦ rsitv Hospital -
Stati tan Kerem
I li< iinii; -in ¦ -it in i-ll II in1 iiii hi 1 mental IMediu 111 n ll-v. Hiiniim nidations.
II < 11 er to the FCC
1 -ii" 'in II' -ii * ¦ -ii i:*(iiiii't r II T'l - I 'i ¦ iioii in h-in in •
Cleveland Clinic
Swiss Physicians Associati ironmental Protection -
Appll I In Il'i'' "iionary Principl- II- -ii Wireless Devices
84
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Swiss Physicians Associati imentall Protection -
II 'II ¦ lllllliilllli -II , II 1 ,'H II.-II • II « .!¦ II ,'l II • II 'II .-I, ;¦ llli" 1' >1IIII i ,* I Hi, II Mi; ¦ II • ¦ ¦! II 'on-
llonizing Radiation
IIii i.iain Cancer Organizati* -i i ¦' isorv to Keep Children Firt -i 11 II lobile
Phones
Hi, * (| > 111 ,• III -i ii on a II * 'I'liiiiiiii, , I'm II in- mi I-! hi 11, hi 'ii.! * I ill.' IIII, alth -
Recc-i ii ii ii ii i, ndatioi i !.¦ II', .h II i.- * I nU h ¦ n
Austrian Medical Association - Nicosia Declara
on
Austrian Medical Assoc ii -ih -i i II 'ii , I ik -II II 'i"lies to Decrease Wireless EMF
Radiatic ipsure
Santa CI -im * .¦»mii II I, .!i.: -II ociation Magazine
Connecticut Department of Pub e Safety Bulletin
Athens Medic -II • •ociatic-ii II I, sures to Protect Against Electromagnetic
Radiation
Canadian Parliament Standing Committee on Health of the House of
C
ncer Institute
LETTERS TO FDA
¦ Press rt II, v, • II ii.¦in iientists challenging radial ii.-in lliiiiniiL-
¦ 111 ,l" 1 l! •limn" I1"! 'I - I ii action signed bv several scientists.
¦ I¦! iaid Me III hi. II IIII ill II, 11, ii I. ¦ III i, II II4 . -i i I he Nation -II I icologv Program
study
¦ Allbei i II I ¦in1 ill, IIII ill \ ii ¦ limed Senior Will.lllill, ll-i.-l.-Jst. Division of Migratory
Bird Management. U.S. Fi h ' , iiII. >rk. Ireland II, n, ii to the
FDA
85
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¦ Igor Bell vat " ' ~ diobiollogv of the Cancer
Research Institute. Bioim Ju -II I \ • < -iuIIi * ¦ ni< i *-l illn lovak Academy of
Science letter to the FDA
" I v,|l I i'-'rou • IIIIiII\ II I- Mill 11 'nr.' i;-M ,
¦ Alfonso Balmori. BSc statement to the FDA
LETTERS AND OFFICIAL BRIEFINGS ON 5G
Briefing on 5G Health Impacts by Dr. Martin Pall: 1 m mi i I I I II i I 11,
U.S. and Internatior lllliing Evidence for Eight Distinct Types
ll'll "-,|l! I" 'iin 11 ,,I-M 1! 15 I I" 1 iioimagnetic Field (EMF) Expo.-i'i¦ • -in! illn
Mechai ;s Them"
November 19, 2018 - Magda Havas, BSc, PhD, Trent University,
Peterborough, Canada - Open II < n< i II U < J K- * msid- i II !!< >lih II ll< ¦ i,-
Associated with Radh- II i« M«l[t n- -nd II licrowave Radiation before
Deployment of 5G
November 19, 2018 - Paul Heroux, PhD, Professor of Toxicology and Health
Effects of Electromagnetism, McGill University Medicine, Montreal - Open
er
November 21, 2018 - Yuri Grigoriev, Dr. Sc. Med., Professor, Academician
of Russian Academy of Electrotechnical Sciences - Open Letter: From
Electromagnetic Smog to Electromagnetic Chao II -le •iiii- illn IIII • -id; ,.|
jUi'hill'i * I-!mim"Inil •ii'i'ii IIhi ll'iiillillii, II!!« 'Iili
December 7, 2018 - David 0. Carpenter, MD, Director, Institute for Health
and the Environment, University at Albany, State University of New York -
Opei i II < 11 <: ii i ¦ II In hi,- i < ii „• -I u" II U ii i ill m ii • «.| I \ -i llii -i i n hi ¦ ¦! the Brussels Capital
December 13, 2018 - Olle Johansson, PhD, associate professor / retired
from the Karolinska Institute, Stockholm, Sweden, and the Royal Institute of
Technology, Stockholm, Sweden - II < 11< ii ¦ ¦! * ¦ ¦incei ii i 'dressed to the
decision-mak' ii ¦ ¦! the Cii * - II Pi i i -sels
May 15, 2019- Magda Havas, BSc, PhD, Trent University, Peterborough,
Canada Hid • ii hh 1 ". -ih -di -ih llvilii -iiih iit with non-pi-lii II II III ¦ 'II IL
86
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LETTERS FROM ORGANIZATIONS AND OTHERS
II ii< r IrHiiii II r.iiiill * ll« ,;;g. former Presic'- mi II licrosoft, Canada
III ,l" 1 11 "in I I II 11 -cientisi • k- II In * h 'ilk • llvill inson/Mrs. Andrea
Dudlev-Ov « iii II'iiesi(i' iM ' * h ¦ II'ii¦ sid; mi ¦ -I II ¦ onomic Development. The
State , .| ¦ ,i[i, nns't , l\
II ii< ii II ii I-! ii i« ii ii , II 11 ii III | v lllli II4 ii- II Ii * h -i l< • II-i II insC'ii ' II Irs. A Dudley-
Owen President & Vice PresiM- mi ¦ 'II II ¦ HriHiiiik II '¦ veh-r-im ni, I In ,-H 'i< . "II
mh1'! rns< , r<
Lett, i IIii ¦ -iiiii I Mdl II l» iroux. IIIIill4 K- I he Stat' "II ¦ ii'ornsev. Re: 5G
II!!< •llilli II llll« ¦ i • ¦ -II II kctromagnetism (Detailed Reot i i' ,-(ihiniii< J k- 1 In
State , .| ¦ ,i[i, jrriS'i h Uvull II !!< h-u •, HI ill4
Letti ii In ¦ ¦in Anthon r II lillei, II III \ II lh 11 i •; in -i I'!¦ r Esq. ( hi" II
Mini i ¦ ii , I In ,•( 'I, ¦ n.| m(i, in,-, _, II \ 1 m
II< n< r Irnii II T'l - II 'i • :• or Colin Pritc II i -iJ k- Illn ,•( >1, • ¦ iu« i irise , \\ 1 ¦¦
Peel -ii ,-ih -in I¦ ¦ II I'll - • iii * 'i¦ ii11111ii,*,*ii¦ ¦ iii II > i m -cientisi- < •llliiir M •
Moratoi in"i11 * -i i 1 m * ¦ III ni< nnas. Septembc ii i ,\ 11
National Healli II i III Megrated Associates Octolb'» ii \ 11 II< 11< ii i* ¦
IVlontgc ncil
II< 11< ii II ii -ii 11 I11 II 'i ii hi i -ii i IIII -ii J. Ill I n ¦ m« pernor Jen ii II 'ii ii i * -i i, -II -! ¦
Beatrice Alexandi ,¦ ¦ «¦ -II- -ii i ill -, II III \ llllill1II « Hii« iiiill >« ir
17, 201?
Letti ii IIii¦ -iiiiJDr I\ml Hon llslliai in ¦ 'pposition i II'" 1 • > pi< mh< i 11
II 'i ii< r Irnii IY * inn" ll'ii,-sell in oppositioii ,-r " ! ¦
II 'i 11 < ii II ii 'i 'ii 11 IIII i ,-;_icic'i i * II" hi • 'II < I < 1 "111 in olio * in i" 'i >| 1 1
87
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Artie!• Iihm II 1 * iiiJ rni,-;,M III hi Imp ll,- ^¦ II 1 m 1, chnolo; , I >in" -i '"I
Santa Clara Bulk 20-23. "A 5G Wireless Future: Will It Give Us a
,-i" -i n II1 -Hihii hi * Hiii ibm, lu. in i lull, Ithv One?" bv Cindy Russell.
January 201?
II, ih ii IIii"i11 II 'I I II II IosIkowill I iiiii'ihi I, mi , IV. n hi ,-r " IP¦
Beatrice Alex, i r 'i ¦ >• -U -i i ih>, II III \ I'hi4II, mi, ii in ¦ -i positie 11 iu-,-r " ! ¦
II , IN II III Hill II 1 ,• 'III II IIIIIII l<: IIIIIIII
II , IN II III HI II II 1 Ii'II III I , , -t
II, 11 < r II ipi'! ii ii IIY II In1;II i •cullv to the ( M "II I ¦ -ii ¦ -ii ito
II, 11< ii IIii -ii11 I11 ,-i, i)hen Sinaii,• i¦ ¦ I¦ -i¦ -iito_( iii * *¦>'iiicilors in Opposition to
Item 26.21
K'lni I, ii, i Iihh 1 IM III, 'lih,, in- mi-ii hi in, mi 'iiu ii»,- fcice advoc -i, • -ii"
oirganizatic-i i,- i * ¦ 11, •, n -i * -i -ii n! II '¦ | resentatives in opposition to bills on
I ,||ll!' ii" loss radiation expansion II i" ¦ in ill j, ii i,\ 11
Ellie Marks Lettei i ¦ iirnoir Bro\ ii i,-V " ! ¦
II, ih ir llirHiii ih< Hi -n i-l II11"ii, • lb -i IIII, 'llilli II n n> ¦niments
II, 11 < ii II ii * -ii n II 11 mi * -ii imental Woirl mi i; • mi * ¦( n in u i, 'h 11
II, 11'< ii IIii -iin II 11 mi -ii imental Woirl mi i;• mi * ¦(n-> in"II \ > i
-\ V[l" ' nonal Institute for Scien- ¦ II • ' hiihllik IIv-Iik , II < n< ii i"
Appiropiriatioir
111 II1 nonal Institute for Scien- ¦ II • ' 11 n"I«Ik I\-Ik I, ii, i k- emblv
. 11 ! Ill -I ii- mail Institute for Scien- ¦ II • ' II11" II < II ii ^ I '..Ik , II, ill, ii iu-mh . i nor
Brown.
II, ih ir lirHiii ihe Sieri * luh, u; u,-i i1 , n > i
II , IN II UlHlii Mil, ,: II ill IIII ill i;; III i;* I 111 (11 < II(|||, 11 , 'nl
II, 11 '< ir II\\ ¦!iii I he American Association of Retired Peirs- -i i • i rII'', In"II, i",
2017
88
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II'i ill ii lliHiii II • 1 -IIu ¦ 'I'll IIII 11 II < Inn ¦inn "Mass ctvu •llii« • i- lull« II, in
Disti h i I*1 III hm |p \isa|-« 'I'll " !1, I("II >\ "t11
liability for
II Mn •• e From Microwave Radiation Exposure Sustained by Sen -i« rill " ! ¦
, ill l\ ,-liilli'i J ii- * •hli'iin • ,-H -ii'i 1, lull I"\ '«11
II 'i 11 'i ii II ii 'i "i 11 II • "'llllik« I'll IIII -ii ii II 'i II hi ii iii) •11'"!' ill ¦ 'ii roportionatelv
'i llll'i « i j he pot -ii in * • II ii II 'i ¦ ii in •' , ii- u,-i 11 I, "t > i
II 'i ii'i ii IIii'i-ii11 II II III ,• -11" I II i'i I'vgrll 'ii"! II ¦ ¦ illogical Qpticii II U I ork. July 06.
201?
II 'i ii'i ii h .-ii,- -in II i¦ ter Assembly Appropriation II« ih ii II n ¦ -i )ion
Exempi
II 'i 11 'i ii II ii - -ii 11 •( k- -ii i II 'i i 'i ii -ii h I II' adiatioi i II \ • <: -ii Jl i I ii nu1 in i * ¦! 1 -| :>i '-osition of
SB 649. June 22, 201?
Scientists For Wired Technology, 5/30/17: t and back
Scientists For Wired Technology 5/31/17:firont and back
ii i in nil -in HI -i hi mi i" Iiatit "111 "(tjuv, • ,-r " r>
Berkeley City Council Qppositioi i I< 11 er. April 111 , 11»11
SCIENTIFIC COMMENTS TO THE FCC
* 'Hiiiiii'i ni,- h T'l'ii 'll'il II I ll\"; " II, rllill \ lu" illi'i II * * 'I'll ,-p'i;« I ii'(" ii ii ii II rentiers
* 'I'liiiii'i ni,- II< Illi'i T'i ill ,-hii¦ II lit llilli" II'I Environmental Coum- ill k- ih< II * * hi
Si'". « i in" ii ii i II i'i»nt|' l- , lull i \ 111111 *
* 'i ¦ ii 11 ii 11 'i ii 11 ,* II" II4 ii lib" 11 II I 'in ill* I., lb. II * * I'll ,<|)edi linn II ii Hiiii";! •, lull _ i I,
2016
11 'i" IIIIIIIIII 'i II11 ,- II > II 4II I'i" II Mo-1 11 " III l""l|||'i II 'I 'I 'I ¦! I ,<|i'i . 11I (III11 II ll'HIllll'l,-, lull
2016
Comments by Dr. Yael Stein to the FCC on Spectrum Frontiers. July 09. 2016
* ¦ -ii i ii ii i ii 'i ni- II i II ii II '¦ ii . • II \ • is to the FCC on SiP'> « I ii n" ii 11 II ii *-i itiers
89
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Comments by Susan Clarke to the FCC on Spectrum Frontiers. July 14. 2016
C gntist Appeal Advisors to the FCC on Spectrum
Frontie
Letters bv Scientists and Doctor
90
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Appendix F
Wireless Exposure Limits in Different Countries
The exposure limits given below are from the web ivsicia Safe
Technology
Japan 600 microwatts/cm2 ICIANS
U.S.A. 450 microwatts/cm2 ' I OLOGY
Canada 450 microwatts/cm2 Physicians for Safe
Australia 450 microwatts/cm2 Technology
Austria 450 microwatts/cm2
France 450 microwatts/cm2
Germany 450 microwatts/cm2
Hungary 450 microwatts/cm2
Ireland 450 microwatts/cm2
Luxembourg 450 microwatts/cm2
Portugal 450 microwatts/cm2
Spain 450 microwatts/cm2
India 45 microwatts/cm2
China 40 microwatts/cm2
Russia 10 microwatts/cm2
Italy 10 microwatts/cm2
Bulgaria 10 microwatts/cm2
Poland 10 microwatts/cm2
Lichtenstein 10 microwatts/cm2
Switzerland 10 microwatts/cm2
Belgium 2.4 microwatts/cm2
Ukraine 2.5 microwatts/cm2
Cosmic <0.00000000001 microwatts/cm2
91
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Appendix G
Captured Agencies and Conflicts of Interest
Alster, Norm, Captured Agency: How the Federal Communications Commission Is
Dominated by the Industries It Presumably Regulates, Edmond J. Safra Center for
Ethics, Harvard University. The report can be accessed here.
Conflicts of Interest Among Those Who Set Radiation Limits
» In Europe, the public radiation limits are set by the International
Committee on Non-Ionizing Radiation Protection (ICNIRP). Investigate
Europe, a team of investigative journalists expose that ICNIRP members
have extensive conflicts of interest with industry. Dr. Joel Moskowitz
chronicles their findings, and additional studies that show ICNIRP scientists
are working for industry:
i'!!,''s://www, 11 1,1 ., 'm£ \ irps-exoo , 1 ,ielines~for~
radio.html
- The 98 page report, "The International Commission on Non-Ionizing
Radiation Protection: Conflicts of interest, corporate capture and the push
for 5G" was commissioned, coordinated and published in 2020 by two
Members of the European Parliament - Michele Rivasi and Klaus Buchner:
11i iI >- t • •!« ii ¦: nil " oiii "'mi i in iii iimi i s-exposure-guidelines-for-
radi
¦ Priyanka Bandara, Ph.D., and others in 2020 published 5G Wireless
Deployment and Health Risks: Time for a Medical Discussion in Australia
and New Zealand which cites conflicts of interest with industry and current
evidence of harm:
s://www.research " xrtij ' ' s Depllo
in* n( • iii'i" I !< 'h11 ll'ii-IIhim iu.ii • Medical Disci'--h-n in e,-ii .-h • an
d New Zealand
Conflicts of Interest at the World Health Organization
> In 2016 the authors of the Biolnitiative Report, which summarizes
thousands of peer-reviewed scientific studies showing wireless technology
is harmful, submitted a No-Confidence letter to the WHO's EMF program
manager because the committee no longer includes appropriate
representation from non-industry funded EMF scientific experts:
92
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II in 11 bioinitiative.org/bi- ¦ 111111 tive-working-group-issues-a-no-
confidence-letter-to-the-who-emf-program-manager/.
¦ The I 'ussian National Committee on Non-lonizii i I Jiation
Protection issued a similar letter in March 2017.
> Over 250 of the world's leading EMF scientists and biologists have signed a
formal appeal to the World Health Organization with a clear plan to inform
and protect the public from wireless radiation:
s://www.emfscientist.org/
> Columbia University's Dr. Martin Blank provides a three-minute
introduction to the Appeal that summarizes the
issue: http iiin : The head of the WHO's "International EMF Project" has heavy ties to the
telecom industry. Further, she does not have EMF scientific or medical
credentials and is not listening to the scientists proving electromagnetic
fields are hazardous. A former UN employee, Olga Sheean of Canada,
submitted a petition to get qualified leadership in place:
asheean.com/who-emf/.
> In 2017, the International Journal of Oncology published a report by Dr.
Lennart Hardell explaining the WHO has conflicts of interest with industry
and does not plan to take action to protect the public from non-thermal
electromagnetic radiation, even though the scientific and epidemiological
evidence of harm is well documented:
hi 11 ¦s://www.spandidos-Publicatioii,- ¦ *-in n > '•11 u<. n > i u > n>
- In 2020, the WHO's "International EMF Project" reopened its investigation
into Electromagnetic Fields:
II1111y y • • • In - nil j>i lli 'i iinil i¦ ieayhyill « he page/en/indexl.html
The WHO's "International EMF Project" is composed of those with close ties to
industry and is separate from the another WHO group that in 2011 determined
EMFs to be Group 2B: Possibly Carcinogenic to Humans. The latter group is the
"International Agency for Research on Cancer (IARC)" which has non-industry
funded scientific experts in the biological effects of EMFs. It remains to be seen
what will come of the investigation launched in 2020:
11111 >,• , ¦ I itrust.org/scientists-call-for-transparencv-at-the-world-health-
organization-' ml pi ¦ '
93
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Appendix H
Example of on RF rodiotion warning
m
-------
Appendix I
Example of o symbol for use on poles and other structures
located in public rights-of way that hold 5G antennae
EXISTS TO PERSONNEL
WHILE RADIATING
CONTACT OPERATORS
BEFORE
APPROACHING
ANTENNA
-------
Appendix J
Deleterious effects of impulsive radiation
While current FCC guidelines for non-ionizing radiation exposure are based upon
heating effects, there is a growing body of research showing that the impulsive
nature of high-speed data transmission can cause deleterious health effects at
considerably lower radiation levels. Three references that document the effect of
the impulsive radiation are given below:
[1] Belyaev, I., Dean, A., Eger, H. et al. "EUROPAEM EMF Guideline 2016 for the
prevention, diagnosis, and treatment of EMF-related health problems and
illnesses." Rev environ Health. 2016;31(3):363-397. Doi:10.1515/reveh-2016-
0011.
[2] B. W. G. (2012). "Bioinitiative 2012: A Rationale for Biologically-based
Exposure Standards for Low-Intensity Electromagnetic Radiation."
[3] McCarty, D. E., Carrubba, S., Chesson, A. L., Frilot, C., Gonzalez-Toledo, E., &
Marino, A. A. (2011). "Electromagnetic hypersensitivity: P Evidence for a novel
neurological syndrome." International Journal of Neuroscience, 121(12), 670-676.
96
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Appendix K
Siting restrictions for wireless antennae
The siting restrictions for cell phone towers already in force in the world were
intended to ensure the safety of vulnerable populations, like children and those
with illnesses.
India already prohibits placement of cell phone towers near schools or hospitals,
and Canada (Standing Committee on Health), as well as many European countries,
are looking into similar restrictions.
CALIFORNIA FIREMEN
California firemen are exempted from the forced placement of towers on or
adjacent to their stations, because of radiation health concerns.
"The International Association of Fire Fighters' position on locating cell
towers commercial wireless infrastructure on fire department facilities, as
adopted by its membership in August 2004, is that the IAFF oppose the use
of fire stations as base stations for towers and/or antennas for the
conduction of cell phone transmissions until a study with the highest
scientific merit and integrity on health effects of exposure to low-intensity
RF/MW radiation is conducted and it is proven that such sitings are not
hazardous to the health of our members."
II1,11 >• - - fsapi.fcc.f - ¦ III* it 11 i1''1 i 1 S "'t" 11 - hment%2020~
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ESTABLISHING SETBACK
To increase wireless data rates, the 5G industry seeks higher frequencies. These
frequencies distribute energy in a smaller fraction of the body and need higher
field intensities because of (1) poor penetration into structures, (2) absorption of
radiation by oxygen and water, (3) shrinking antenna apertures, as well as (4)
noise from an increasing number of extraneous sources.
For human users, this means increased power density exposures. In addition,
exposures will become more irregular because of beam-forming, as well as
originate from multiple sources (Multiple-Input Multiple-Output architecture).
Since there is no epidemiological or animal data, and very few laboratory results
using 5G, cautionary setbacks should be established by the municipalities based
upon past 3G and 4G systems.
The verdict on animal studies is expressed in reports by (1) the US National
Toxicology Program, (2) the Ramazzini Institute, and by older studies by (3) Chou
(1992) and (4) Repacholi (1997).
The verdict on epidemiology is expressed in two reports (ELF and RF) from the
International Agency for Research on Cancer {" possibly carcinogenic"), which
Agency is scheduled to review evidence on RF carcinogenicity between now and
2024.
Senator Blumenthal:
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US National Toxicology Program - Impact of Cell Phones:
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Ramazzini Institute - Impact of Base Stations:
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International Agency for Research on Cancer - ELF:
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International Agency for Research on Cancer - RF:
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Identification ¦ -I * -ii *. inogenic-Hazard 1 * ¦ II lit"i11 -ii i,- II U -i i-ionizing-Radiatiori II Miri
diofreauencv-Electromagnetic-Fields-2013
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Chou, 1992: ¦ jilev.com/cio . • ¦" ¦ 1 «i ' ' ¦" . ¦05
Repacholi, 1997: https://www.ncbi.nlm.nih.gov/Dubmed/9146709
As vulnerable individuals are exposed involuntarily every day in society to RF-
radiation, caution should be universally used and set according to the Largest
Observed Adverse Effect Distance (LOAED), using the experience from past and
current 2G, 3G, and 4G networks. A conservative LOAED should include all
observed health effects.
Best engineering practice would therefore apply a set-back requirement for new
cellular towers, including 5G micro-towers.
From the 17 documents referred to in this appendix, shown below in historical
order, this set-back for all new cell towers should be 500 meters which translates
to 1,640 feet.
All of these studies have been given support by a recent animal study from the
Ramazzini Institute that links to them, as well as to the US National Toxicology
Program result on cell phones.
REFERENCES
Paola Michelozzi, Alessandra Capon, Ursula Kirchmayer, Francesco Forastiere,
Annibale Biggeri, Alessandra Barca, and Carlo A. Perucci.
"Adult and Childhood Leukemia near a High-Power Radio Station in Rome,"
Italy. American Journal of Epidemiology, Vol. 155, No. 12, (2002) 1096-1103.
Michelozzi et al 2002 describe an increased risk for childhood leukemia at
distances up to 6 km from the powerful Vatican Radio transmitters near Cesano,
Italy, which led to compensation by decision of Italy's Supreme Court (relative risk
of 7 for lymphomas and myeloma, and 5 for non-Hodgkin's lymphoma and
leukemia).
II1111 y , | it "II :'i 11< > ii i« hi ii ill 11 ii mil i • •ov/12048223/
100
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R. Santini, P. Santini, P. Le Ruz, J. M. Danze, and M. Seignel. "Survey Study of
People Living in the Vicinity of Cellular Phone Basestations." Electromagnetic
Biology and Medicine. Vol. 22, No. 1, pp. 41-49, 2003.
Santini et al 2003 surveyed by questionnaire 530 people living or not in proximity
to cellular phone Base Stations (BSs) in France. Eighteen different symptoms
(Non-Specific Health Symptoms-NSHS), described as radiofrequency sickness,
were studied. Certain complaints are experienced only in the immediate vicinity
of BSs (up to 10 m for nausea, loss of appetite, visual disturbances), and others at
greater distances from BSs (up to 100 m for irritability, depressive tendencies,
lowering of libido, and up to 200 m for headaches, sleep disturbances, feeling of
discomfort). In the 200 m to 300 m zone, only the complaint of fatigue is
experienced significantly more often when compared with subjects residing at
more than 300 m or not exposed (reference group). For seven of the studied
symptoms and for the distance up to 300 m, the frequency of reported
complaints is significantly higher (P<0.05) for women in comparison with men.
11111 /www.tandfonline.com/doi/alb,- n1 i ibc-120020353
Michael Kundi, Hans-Peter Hutter. "Mobile phone base stations—Effects on
wellbeing and health." Pathophysiology 16 (2009) 123-135.
Kundi and Hutter 2009 comment that studying effects of mobile phone base
station signals on health have been discouraged by authoritative bodies like the
WHO. As a result, only few investigations of effects of base station exposure on
health and wellbeing exist. But two ecological studies of cancer in the vicinity of
base stations report both a strong increase of incidence within a radius of 350 and
400 m, respectively. It is suggested that power densities around 500-1000 nW/m2
must be exceeded in order to observe an effect.
liii|V , IP''Nni" "! ii" hi mini mil ;v i ' ,|[,i S1 i
Vini G. Khurana, Lennart Hardell, Joris Everaert, Alicja Bortkiewicz, Michael
Carlberg, Mikko Ahonen. "Epidemiological Evidence for a Health Risk from Mobile
Phone Base Stations." International Journal of Occupational and Environmental
Health. July 2010;16:263-267. DOI: 10.1179/107735210799160192.
Khurana et al 2010 provides a review of 10 BS proximity and neurobehavioral
effects, and three investigations of cancer. Eight of the 10 studies reported
increased prevalence of adverse neurobehavioral symptoms or cancer in
populations living at distances < 500 meters from BSs.
II1111 v t in III hi 11, J !!¦ hi ii ill in ii mil i ov/2061 ¦ Ml-.
101
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Adilza C. Dode, Monica M.D. Leao, Francisco de A.F. Tejo, Antonio C.R. Gomes,
Daiana C. Dode, Michael C. Dode, Cristina W. Moreira, Vania A. Condessa, Claudia
Albinatti, Waleska T. Caiaffa. "Mortality by neoplasia and cellular telephone base
stations in the Belo Horizonte municipality, Minas Gerais state, Brazil." Science of
the Total Environment 409 (2011) 3649-3665.
Dode et al 2011 provides the most detailed information. Belo Horizonte is the
third largest city in Brazil. It was been selected by the Population Crisis Committee
of the United Nations (UN, 2007) as the metropolis with the best quality of life in
Latin America. Its health system is considered very good, according to the Atlas of
Human Development (2000/United Nations Development Program).
In 2011, a 10-year study on cell phone antennas was released by the Municipal
Health Department and several local universities. The study was conducted in a
broad environmental context, aiming to verify if there is a spatial correlation
between the cellular telephony system BS location and the cases of death by
neoplasia during the period between 1996 and 2006. Three data banks were
used: 1. death by neoplasia documented by the Municipal Health Department; 2.
BS documented in ANATEL (Telecommunications National Agency); and 3. census
and demographic city population data obtained from official archives provided by
IBGE (Brazilian Institute of Geography and Statistics). The results show that
approximately 856 BSs were installed through December 2006.
Between 1996 and 2006, 7191 deaths by neoplasia occurred and, within an area
of 500 m from the BS, the mortality rate was 34.76 per 10,000 inhabitants.
Outside of this area, a decrease in the number of deaths by neoplasia occurred.
The greatest accumulated incidence was 5.83 per 1000 in the Central-Southern
region and the lowest incidence was 2.05 per 1000 in the Barreiro region. During
the environmental monitoring, the largest electric field measured was 12.4 V/m
and the smallest was 0.4 V/m. The largest power density was 407,800 nW/m2,
and the smallest was 400 |iW/m2.
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Ermanno Affuso, J. Reid Cummings, Huubinh Le. "Wireless Towers and Home
Values: An Alternative Valuation Approach Using a Spatial Econometric Analysis."
Journal of Real Estate Finance and Economics (2018) 56:653-676. DOI
10.1007/slll46-017-9600-9.
102
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Affuso et al 2018 examines the economic impact on home values. For properties
located within 0.72 kilometers of the closest tower, results
reveal significant declines of 2.46% on average, and up to 9.78% for homes within
tower visibility range compared to homes outside tower visibility range.
hi 11 s://link.springer.com/artick n > i< '<1 „ „• i i i S" <11 '''800-9
Falcioni L., L. Bua, E. Tibaldi, M. Lauriola, L. De Angelis, F. Gnudi, D. Mandrioli, M.
Manservigi, F. Manservisi, I. Manzoli, I. Menghetti, R. Montella, S. Panzacchi, D.
Sgargi, V. Strollo, A. Vornoli, F. Belpoggi.
Report of final results regarding brain and heart tumors in Sprague-Dawley rats
exposed from prenatal life until natural death to mobile phone radiofrequency
field representative of a 1.8 GHz GSM base station environmental emission.
Environmental Research 165 (2018) 496-503.
Falcioni et al 2018 conclude: the Ramazzini Institute findings on far field
exposure to RFR are consistent with and reinforce the results of the NTP study on
near field exposure, as both reported an increase in the incidence of tumors of
the brain and heart in RFR-exposed Sprague-Dawley rats. These tumors are of the
same histotype of those observed in some epidemiological studies on cell phone
users. These experimental studies provide sufficient evidence to call for the
reevaluation of IARC conclusions regarding the carcinogenic potential of RFR in
humans.
II1111 ¦s://www.avaate. org/1 MG/pdf/belpoggi-he -i I -in! II rain-tumors-base-station-
2018.pdf
J.M. Pearce. "Limiting liability with positioning to minimize negative health effects
of cellular phone towers." Environmental Research 181 (2020) 108845.
Pearce et al 2020 provides the most recent assessment and promotes a 500 m
set-back to limit future liabilities of the cell phone industry, based on correlation
with headaches, dizziness, depression and other neurobehavioral symptoms, as
well as increased cancer risk. It is almost inevitable that such economic impacts
will increase in the future.
hi 11! s://www.sciencedirect.o ¦[ 11 ¦ ien- ¦ >\\uh -Ik- piii ,•< "<1 i i"<"",'¦!!
Other References
Buchner K et al. (2011): [Modification of clinically important neurotransmitters
under the influence of modulated high-frequency fields - A long-term study under
true-to-life conditions]. In German. Abstract translation below.
103
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This long-term study over one and a half years shows a significant
activation of the 60 participants' adrenergic systems after the installation
of a regional mobile telephone transmitting station in the village of
Rimbach (Bavaria).
The values of the stress hormones adrenaline and noradrenaline grow
significantly during the first six months after starting the GSM transmitter;
the values of the precursor substance dopamine decreases substantially
after the beginning of the radiation (Wilcoxon test, p<0,0002). The initial
condition is not restored even after one and a half years. Due to the not
regulable chronic difficulties of the stress balance, the phenylethylamine
(PEA) values drop until the end of the research period (Wilcoxon test,
p<0,0001). The effects show a dose effect relation and are situated far
under the valid limits for technical high-frequency stress. Chronic
dysregulations of the catecholamine system have substantial health
relevance and cause health damages in the long run.
Wolf R, Wolf D. "Increased incidence of cancer near a cell-phone transmitter
station." IntJ Cane Prev 2004; 1 (2): 123-128. Publication unavailable online.
Conclusion according to the authors: Of the 622 people of area A, 8 cases of
different kinds of cancer were diagnosed in a period of one year (from July
1997 - June 1998). The cancer incidence rate was 129 cases per 10,000
persons per year in area A compared to 16/10,000 in area B and 31/10,000
in the town of Netanya. Relative cancer rates for females were 10.5 for
area A, 0.6 for area B and 1 for Netanya. The authors conclude that the
study indicates an association between increased incidence of cancer and
living in proximity to a mobile phone base station.
Eger H, Hagen KU, Lucas B, Vogel P, Voit H. [Influence of proximity to mobile
telephony transmitters on cancer incidence]. Umwelt-Medizin-Gesellschaft 2004;
17 (4): 326-332. In German. Author's conclusion translated below.
320 of 967 residents of Naila have been living in the inner circle at a
distance to the next base station of less than 400 m. The results showed an
increased risk for malignant tumors for patients living closer than 400 m to
the mobile telephony transmitter compared to patients living further away.
104
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In the years 1999 - 2004 the risk for malignant tumors tripled for patients
living in the proximity of the mobile telephony transmitter.
105
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Appendix L
Measurement of RF intensities
within frequency ranges throughout state
The majority of the Commission suggests this data include location, frequency
ranges, peak, and average power intensities of total combined RF emitted by
sources such as 3G, 4G, or 5G cellphone networks, Wi-Fi, smart meters, IOT
devices, and similar devices. The data should be collected in such a way as to
identify possible 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 zones) that are sought by people who wish to minimize their
exposure.
RF data collected and mapped should be archived and published on a state
website, accompanied by state-wide and regional aggregated averages for both
peak and 24-hour integrated microwatts/meter squared intensities. The state
should also publish benchmarks for comparison: a few readings from low-
intensity underdeveloped areas, and nearby some strong high-intensity sources
(base of a tower) for min-max comparison. The Bioinitiative 2012 recommends
that human peak exposure not exceed an RF intensity of 1,000 microwatts/meter
squared.
One use of this data will be buyers/renters of property or the public in general
using these benchmark values to make comparisons and form their own decisions
based on their comfort level. After a while, an extensive NH RF database will exist
to provide useful maps and data for future public health investigations.
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Appendix M
The enabling technology and scientific rationale
for automatically stopping cell phones from
operating when held against the body
The FCC testing procedure for certification of cell phones aims for a power
injection into the head below 1.6 Watts per kilogram of tissue. The accuracy of SAR
determinations is not very high (variation between laboratories), and some cellular
phones have been found to exceed this limit
(https://www.chicagotribune.com/investigations/ct-cell-phone-radiation-testing-
20190821-72qgu4nzlfda5kvuhteiieh4da-story.html).
A major problem is that the FCC testing procedure allows the phone to be tested
up to 0.98 inches (2.5cm) from the head, at which distance injection of energy
into the head is much reduced compared to when held against the head as is
done routinely by users. "Small print" instructions already present in many cell
phone manuals instruct users to hold cell phones at a distance from the head, in
full knowledge that this is not likely to be done.
In France, measurements by the National Frequency Agency (ANFR) revealed that
9 out of 10 mobile phones tested in 2015 under real use conditions (in contact
with the body) exceeded the legal limit, leading to extensive recalls
(https://www.phonegatealert.org/en/phonegate-scandal-where-are-we-three-
vears-after-the-alert-was-launched).
We provide here a simple change expected to reduce the number of
glioblastomas and other tumors in cell phone users by mandating that cell phones
turn off their radiation when held right against the head or body.
IMPLEMENTATION
A reliable method to reduce head exposure to
radiation is to configure the phone itself to
automatically shut off, protecting the user's brain.
Cellular phones already contain a small device called a
proximity sensor (shown at right is the miniature
107
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Sharp GP2AP002S00F), usually
located at the top of the
phone. The element on the left of
the sensor sends out pulsed
infrared which is detected by the
element on the right, if the phone
is near an object. The image
sequence at right shows how a
finger turns off the screen.
In present Android devices, the proximity sensor triggers as the user's face is close
to the screen, switching off the screen and preventing any errant soft-button
presses by the skin as weil as saving battery power.
Some Android devices can report the distance to another object in centimeters,
whereas others will simply report minimum and maximum values to denote near
and for, respectively. These functions are accessed through SensorMonoger and
Sensor classes from the Android Application Programming Interface (API).
Similarly, the iPhone proximity sensor (also using infrared) is designed to detect
any object near the screen and is used to put the display to sleep when the
iPhone is against the head, preventing unintentional display triggering.
Assigning to the user the task of keeping the phone away from the head is not
practical, The phone itself should disable its RF emissions if proximity is detected.
This means that the user could use the phone away from the head, in his hand, or
on a table in front of him. At the cost of a small change in personal habits, this
measure would instantly remove high SAR exposures from cell phone usage and
would remove the need for sophisticated assessment of exact SAR measurements
in close body proximity. Note that this phone adjustment does not prevent
alerting the user to incoming calls. But it does prevent the unit from
autonomously sending out data when held against the body. A number of
applications ("apps") have in recent years contributed to user exposures by
radiating data even without user intervention. This automatic data traffic tends to
increase and should only be permitted if the device is held away from the body.
Essentially, this software adjustment is an automated "Airplane Mode", designed
to protect users from radiation.
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JUSTIFICATION
For cellular phones, commonly held against the head, prolonged use has led to an
increase in a lethal form of brain cancer, glioblastoma, as well as with a more
benign tumor, acoustic neuroma, in 9 peer-reviewed studies, including one cohort
study.
• Brain Tumours: Rise in Glioblastoma Multiforme Incidence in England
1995-2015 Suggests an Adverse Environmental or Lifestyle Factor. Alasdair
Philips, Denis L. Henshaw, Graham Lamburn, and Michael J.O'Carroll.
Journal of Environmental and Public Health Volume 2018, Article ID
7910754, (https://doi.oiri ),
• Use of mobile phones and cordless phones is associated with increased risk
for glioma and acoustic neuroma. Lennart Hardell, Michael Carlberg, Kjell
Hansson Mild. Pathophysiology 20 (2013) 85-110.
11111 ts://www.sciencedirect.com/scieri' ¦ -i i:icle/abs/pii/S0928468012001101
Recent studies have also linked cell phone use to cancer.
The US National Toxicology Program,
11111y iMr- in- lis.nih.gov/ireM'111- -i¦ as/cellphones/index.himl.
the International Agency for Research on Cancer,
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Radiation-Pani ' II' • ;i )freauencv-Electromagnetic-Field: > l,\,
as well as individual large studies by Chou,
http ilinelibrary.wilev.com/doi/abs/10.1002/bem.2250130605,
Repacholi,
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as well as a collective opinion of scientists,
s://bioinitiative.org/.
Engineering analysis indicates that the dose delivered to the brain decreases
rapidly as distance between cellular phone and head rises. As shown below, it
109
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decreases by as much as 4 to 5 times, according to two separate analyses, as the
phone is moved 1 cm (0.4") away.
-1—i—i—i—i—i—i—i—i—
0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1
Phone Distance from Head (cm)
A comparative study of the distance tffMt of ha man headJhrm mobile phone radiation.
S. Iman Zonoorl, S. I aluib At-Din Makki, Abdorrryt Torabi.
International Journal of Microwave and Optica! Technology, I of. 10, Mo. I, January 201 J.
0 2 4 6 8 10 12
Distance (mm)
Design of law utr planar monopoly antenna
Jbr mobile wircltss communication applications.
Dalia M. E Ishcakh and Esmat A. A Mali alt.
Progress in Electromagnetics Research M, \'ol. 29, 137- 149, 2013.
While walkie-talkies of the past were used more distantly from the head, the
recent trend has been to reduce the size of cellular phones and to promote a style
of use identical to that of the telephone which is pressed against the ear. An
unfortunate consequence has been to deliver large doses of EMR to tissues of the
nervous system which have been shown to be adversely affected, as stated
above.
Without altering the function of cellular phones, it is technically possible to
seriously reduce exposure to the brain of users by altering how the phones are
held when emitting radiation, specifically by holding them away from the body.
no
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Appendix N
Research on the effects of wireless radiation on
trees, plants, birds, insects, pollinators, and wildlife
FCC limits were not developed to protect our flora or fauna. Wireless radiation
"safety" limits for trees, plants, birds, insects, pollinators, and wildlife simply do
not exist. No US agency nor international authority with expertise in science,
biology or safety has ever acted to review research and set safety limits on these
non-human species.
The Department of Interior wrote a letter in 2014 detailing several published
studies showing impacts of wireless radiofrequency radiation (RFR) to birds. It
stated the following:
There is a growing level of anecdotal evidence linking effects of non-thermal,
non-ionizing electromagnetic radiation from communication towers on nesting
and roosting wild birds and other wildlife in the U.S.
However, 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.
... third-party peer-reviewed studies need to be conducted in the U.S. to begin
examining the effects from radiation on migratory birds and other trust species.
Study results have documented nest and site abandonment, plumage
deterioration, locomotion problems, reduced survivorship, and death (e.g.,
Balmori 2005, Balmori and Hallberg 2007, and Everaert and Bauwens 2007).
Nesting migratory birds and their offspring have apparently been affected by
the radiation from cellular phone towers in the 900 and 1800 MHz frequency
ranges- 915 MHz is the standard cellular phone frequency used in the United
States.
In laboratory studies, T. Litovitz (personal communication) and DiCarloet al.
(2002) raised concerns about impacts of low-level, non-thermal electromagnetic
radiation from the standard 915 MHz cell phone frequency on domestic chicken
embryos- with some lethal results (Manville 2009, 2013a). Radiation at
extremely low levels (0.0001 the level emitted by the average digital cellular
telephone) caused heart attacks and the deaths of some chicken embryos
subjected to hypoxic conditions in the laboratory while controls subjected to
hypoxia were unaffected (DiCarlo et al. 2002).
Ill
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Albert Manville, former senior biologist of the US Fish and Wildlife Service wrote
"A BRIEFING MEMORANDUM: What We Know, Can Infer, and Don't Yet Know
about Impacts from Thermal and Non-thermal Non-ionizing Radiation to Birds and
Other Wildlife" published in Wildlife and Habitat Conservation Solutions, 2014 on
the impacts of RFR to birds and bees. India dropped their RF limits by l/10th
after a research review documented the majority of research studies found
adverse effects to wildlife, birds and bees.
Regarding bees and pollinators, the study "Exposure of Insects to Radio-
Frequency Electromagnetic Fields from 2 to 120 GHz" published in Scientific
Reports found insects (including the Western honeybee) can absorb the higher
frequencies that will be used in the 4G/5G rollout, with absorbed power increases
up to 370%. The researchers warn, "This could lead to changes in insect
behaviour, physiology, and morphology over time...." Research also has found
impacts to bees from wireless frequencies including inducing artificial worker
piping (Favre, 2011), disrupting navigation abilities (Sainudeen, 2011; Kimmel et
reducing colony strength e~2006). and impacts to honey bee
physiology (Kumar et al., 2011).
Research on trees has found that trees are harmed by RFR. A 9 year field study
(Waldmann-Selsam. C., et al 2016) found significant impacts to trees near cell
antennas and an investigation of 700 trees found damage starts on the side of the
tree with highest RF. A review on impacts to plants entitled, "Weak
radiofrequencv radiation exposure from mobile phone radiation on plants"
concluded, "a substantial amount of the studies on RF-EMFs from mobile phones
show physiological and/or morphological effects." A study on aspen seedings
found ambient RF in a Colorado setting were high enough to cause necrotic
lesions on the leaves, decrease leader length and leaf area, and suppress fall
anthocyanin production (Haggartv. 2010).
The European Scientific Committee on Health. Environmental and Emerging Risks
states, "The lack of clear evidence to inform the development of exposure
guidelines to 5G technology leaves open the possibility of unintended biological
consequences." Several literature reviews warn that non-ionizing EMFs are an
"emerging threat" to wildlife (Balmori, 2015, Curachi, 2013, Sivani, 2012).
112
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Research Studies
Waldmann-Selsam, C., et al. "Radio-frequency radiation injures trees around
mobile phone base stations." Science of the Total Environment 572 (2016):
554-69.
Breunig, Helmut. "Tree Damage Caused By Mobile Phone Base Stations An
Observation Guide" (2017).
Sivani, S., Sudarsanam, D. "Impacts of radio-frequency electromagnetic field (RF-
EMF) from cell phone towers and wireless devices on biosystem and
ecosystem - a review." Biology and Medicine, Volume 4, Issue 4, Pages 202-
216, 2012.
Haggerty, Katie. "Adverse Influence of Radio Frequency Background on Trembling
Aspen Seedlings." International Journal of Forestry Research, 2010.836278
(2010).
Halgamuge, M. "Weak radiofrequency radiation exposure from mobile phone
radiation on plants." Electromagnetic Biology and Medicine, vol. 36, no. 2,
2017, pp. 213-235.
Martin Pall. "Electromagnetic Fields Act Similarly in Plants as in Animals: Probable
Activation of Calcium Channels via Their Voltage Sensor." Current Chemical
Biology, Volume 10, Issue 1, 2016.
Shikha Chandel, et al. "Exposure to 2100 MHz electromagnetic field radiations
induces reactive oxygen species generation in Allium cepa roots." Journal of
Microscopy and infrastructure, 5.4 (2017): 225-229.
Halgamuge, M., Skafidas, E., Davis, D. "A meta-analysis of in vitro exposures to
weak radiofrequency radiation exposure from mobile phones (1990-20151."
Environmental Research, 2020; 184:109227.
doi:10.1016/J.ENVRES.2020.109227.
Halgamuge, M., Davis, D. "Lessons learned from the application of machine
learning to studies on plant response to radio-frequency." Environmental
Research, 2019. doi:10.1016/j.envres.2019.108634
Gustavino, B., et al. "Exposure to 915 MHz radiation induces micronuclei in Vicia
faba root tips." Mutagenesis 31.2 (2016): 187-92.
Halgamuge, Malka N., See Kye Yak, and Jacob L. Eberhardt. "Reduced growth of
soybean seedlings after exposure to weak microwave radiation from GSM
900 mobile phone and base station." Bioelectromagnetics 36.2 (2015): 87-95.
113
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"Tree Damage from Chronic High Frequency Exposure Mobile
Telecommunications. Wi-Fi. Radar. Radio Relay Systems. Terrestrial Radio, TV
etc" by Dr. Volker Schorpp (2011).
Shepherd et al. "Increased aggression and reduced aversive learning in honey
bees exposed to extremely low frequency electromagnetic fields." PLoS One,
2019 Oct 10.
Balmori, Alfonso. "Anthropogenic radiofrequencv electromagnetic fields as an
emerging threat to wildlife orientation." Science of The Total Environment
518-519 (2015): 58-60.
Balmori, A. "Electrosmog and species conservation." Science of the Total
Environment, vol. 496, 2014, pp. 314-6.
Cucurachi, C., et al. "A review of the ecological effects of radiofrequencv
electromagnetic fields (RF-EMF)." Environment International, vol. 51, 2013,
pp. 116-40.
Kumar, Neelima R., Sonika Sangwan, and Pooja Badotra. "Exposure to cell phone
radiations produces biochemical changes in worker honey bees." Toxicology
International, 18, no. 1, 2011, pp. 70-2.
Favre, Daniel. "Mobile phone induced honeybee worker piping." Apidologie, vol.
42, 2011, pp. 270-9.
"Briefing Paper on the Need for Research into the Cumulative Impacts of
Communication Towers on Migratory Birds and Other Wildlife in the United
States." Division of Migratory Bird Management (DMBM), U.S. Fish & Wildlife
Service, 2009.
"The potential dangers of electromagnetic fields and their effect on the
environment." Council of Europe Parliamentary Assembly, Resolution 1815,
2011.
Engels, S. et al. "Anthropogenic electromagnetic noise disrupts magnetic compass
orientation in a migratory bird." Nature, vol. 509, 2014, pp. 353-6.
Balmori A. "Possible Effects of Electromagnetic Fields from Phone Masts on a
Population of White Stork (Ciconia ciconia)." Electromagnetic Biology and
Medicine, vol. 24, no. 2, 2005, pp. 109-19.
Balmori, A. "Mobile phone mast effects on common frog (Rana temporaria)
tadpoles." Electromagnetic Biology and Medicine, vol. 29, no. 1-2, 2010, pp.
31-5.
114
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Appendix O
Meeting Minutes
115
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
9/16/19
9:00-10:00 am
LOB 202
Meeting called to order by Rep Abrami at 9:00 am.
In attendance: (9) IEach member discussed their backgrounds)
Rep. Patrick Abrami-speaker of the house appointee
Senator Tom Sherman-president of the senate appointee
Rep. Ken Weeks- speaker of the house appointee
Kent Chamberlin-UNH-appointed by the chancellor
Carol Miller-NH Business & Economic Affairs Dept.
Denise Ricciardi-public-appointed by the governor
Michelle Roberge-DHHS- Commissioner of DHHS appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Excused:(1)
Dr. Paul Heroux- Professor of Toxicology, McGill University- speaker of the house appointee
To be filled: (6)
AG or designee
2 members of the NH High Tech Council
1 member of NH Medical Society, specializing in environmental medicine/electromagnetic radiation
1 member of cell phone/wireless industry
1 member of Business and Industry Association
Agenda: (attached)
I. Member introductions and background
II. Election of Chair:
- Rep. Patrick Abrami was nominated by Senator Tom Sherman, seconded by Rep Gary
Woods. Vote was unanimous.
HI- Guiding Principles: (see attached and attached HB522)
- Senator Sherman: committee decorum protocol, ask permission of chair to speak or rebut.
IV. Statement of Purpose and Goals: (see attached)
Rep. Abrami: Why do we need state level? Fed is not doing much. States are pushing
back against the Federal government as small cells are rolled out in front of homes.
Because we cannot see it or feel it, except those who are sensitive, doesn't mean it is
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not an issue for health and the environment. A sixth goal was added to communicate
conclusions to all federal agencies with jurisdiction and the Office of the President.
V. Questions Needing Answers: (see attached)
-Senator Gray: We need to look at all radiation, not just 5G. Is it good or bad? Is is
frequency? Intensity? How much is too much? Think broadly, not just 5G.
-Senator Sherman: Applying Precautionary Principle is most important. We are not looking
for proof positive, but risk. Lack of knowledge does not equal safety. Is there potential harm
here? Public health policy is not black and white. The goal is to protect public health.
-Rep Woods: we need a good understanding of baseline ambient level and levels relative to
that.
-Kent Chamberlin: Concerns of cybersecurity and military issues and from sources not under
U.S. control, not just biological.
- Denise Ricciardi: Health epidemic avoidance, constitutional privacy issues, data collection.
Our job is to get to the truth for public health.
-Rep Abrami: Let it take us where it leads us. Root discussion is RF radiation. We cannot talk
about 5G without RF in general.
VI. List of organizations in which testimony will be requested, (see attached)
-Rep Abrami: There will be no problem bringing in people with tremendous science
credentials. I am hoping to get someone in to refute that. We need back and forth
discussion. The harder problem will be in getting people to testify rebutting findings.
Joel is research resource for the commission.
Discussion:
Rep Abrami: US National Toxicology findings, WHO, FCC. We need to understand FCC
standards and why they only test for thermal effects, ignoring biological effects. We may
need to skype people in as we do not have a budget for this.
Senator Sherman: who is making decisions at the FCC? Are they biased? What are their
qualifications? Request background on decision makers setting regulations state and fed
levels both.
Kent Chamberlin: limits are set very high compared to other countries who do look at
biological effects. What can we, as a state do if fed level decision makers aren't qualified
to be making those decisions?
Carol Miller: We should have an industry report for NH. Where are we at for 5G
deployment? How can we help mitigate for our constituents?
Rep Woods: in hearing testimony, has study been repeated? Look beyond credentials of
presenter.
Rep Abrami: Would like to hear from Industry on this. And insurance?
Kent Chamberlin: Can we look at where policies are done because of exposure to
radiation?
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Senator Gray: Insurance writes exclusions because it's an issue or may exclude on
Rumor?
VII. Meeting frequency, time & length.
-every 2-3 weeks, initially.
- two hours typically
- next meeting: Thursday, October 10,2019 8:30-10:30
- Kent Chamberlin will do brief presentation on waves.
- will need projector for slides.
- Dr Heroux may present if he is able to be at the next meeting.
VIII. Public comments:
-Jennifer White (Hancock,NH):
1. Jen and her son are RF sensitive. She manages two businesses out of her home.
Agree with Senator Gray it is a greater issue than just 5G. However, the issue with
5G is we can no longer have control over the safety of our home/property
environment. If that right is taken away, they will both suffer, as their own home
will no longer be a safe place.
2. Response to Senator Gray's statement about some radiation is helpful ie. Killing
cancer... Jen's mom had cancer. The radiation did kill that. But she lived 3 years
longer but died from Leukemia caused by the radiation to kill the cancer.
-Cherylyn Randolph LeBrun: (Loudon, NH): She has background in public health
nursing. Her concern is for children and our future children. Please consider the long term
effects on exposure to children who will have a much longer exposure than we have. Autism
is a big issue. Please focus on pediatric neurology.
IX. Meeting Adjourned at 10:05 am.
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HB 522 - VERSION ADOPTED BY BOTH BODIES
2019 SESSION
19-0261
05/01
HOUSE BILL 522
AN ACT establishing a commission to study the environmental and health effects of evolving 5G
technology.
SPONSORS: Rep. Abrami, Rock. 19; Sen. Sherman, Dist 24
COMMITTEE: Science, Technology and Energy
ANALYSIS
This bill establishes a commission to study the environmental and health effects of evolving 5G
technology.
Explanation: Matter added to current law appears in bold italics.
Matter removed from current law appears [in brackoto and otruclcthrough.]
Matter which is either (a) all new or (b) repealed and reenacted appears in regular type.
19-0261
05/01
STATE OF NEW HAMPSHIRE
In the Year of Our Lord Two Thousand Nineteen
AN ACT establishing a commission to study the environmental and health effects of evolving 5G
technology.
Be it Enacted by the Senate and House of Representatives in General Court convened:
1 New Subdivision; Commission to Study the Environmental and Health Effects of Evolving 5G
Technology. Amend RSA 12-K by inserting after section 11 the following new subdivision:
Commission to Study the Environmental and Health Effects of Evolving 5G Technology
12-K: 12 Commission Established. There is established a commission to study the environmental
and health effects of evolving 5G technology, which includes the use of earlier generation
technologies. JFifth generation, or 5G, wireless technology is intended to greatly increase device
capability and connectivity but also may pose significant risks to humans, animals, and the
environment due to increased radiofrequency radiation exposure. The purpose of the study is to
examine the advantages and risks associated with 5G technology, with a focus on its environmental
impact and potential health effects, particularly on children, fetuses, the elderly, and those with
existing health compromises.
12-K:13 Membership.
I. The members of the commission shall be as follows:
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(a) Three members of the house of representatives, including one member from the house science,
technology, and energy committee, and one member from the health, human services and elderly
affairs committee, appointed by the speaker of the house of representatives.
(b) Two members of the senate, appointed by the president of the senate.
(c) A member of the public, appointed by the governor.
(d) The attorney general, or designee.
(e) Two members of the New Hampshire High Technology Council, appointed by the council.
(f) One member representing the Business and Industry Association, appointed by the association.
(g) One member of the New Hampshire Medical Society who specializes in environmental medicine
and is familiar with electromagnetic radiation, appointed by the society.
(h) One member representing the university system of New Hampshire knowledgeable in
radiofrequency radiation, appointed by the chancellor.
(i) One member of the cell phone/wireless technology industry, appointed by the president of the
senate.
(j) The commissioner of the department of health and human services, or designee.
(k) One public member with expertise in the biological effects of radiofrequency radiation, appointed
by the speaker of the house of representatives.
II. Legislative members of the commission shall receive mileage at the legislative rate when
attending to the duties of the commission.
III. The members of the commission shall elect a chairperson from among the members. The first
meeting of the commission shall be called by the first-named house member. The first meeting of the
commission shall be held within 45 days of the effective date of this section. Seven members of the
commission shall constitute a quorum.
12-K:14 Duties and Reporting Requirement.
I. The commission shall:
(a) Examine the health and environmental impacts from radiofrequency (RF) radiation emitted from
the waves in the 30-300 gigahertz(GHZ) range of the electromagnetic spectrum, which falls
somewhere between microwaves and infrared waves, and which are required with the rollout of 5G
technology.
(b) Assess the health and environmental impacts of 5G technology, which requires small cell towers
to be placed at a distance of 250 meters from each other at telephone pole height from the ground
and will operate in conjunction with the 3G and 4G technology infrastructure.
(c) Receive testimony from the scientific community including but not limited to physicists and
electrical engineers, the medical community including but not limited to cellular experts and
oncologists, the wireless technology industry including but not limited to cell phone businesses and
businesses working on the development autonomous vehicles which will rely on 5G technology, as
well as other organizations and members of the public with an interest in 5G technology.
(d) Consider the following questions and the impact on New Hampshire citizens, municipalities, and
state government of:
(1) Why the insurance industry recognizes wireless radiation as a leading risk and has placed
exclusions in their policies not covering damages caused by the pathological properties of
electromagnetic radiation?
(2) Why do cell phone manufacturers have in the legal section within the devise 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, being 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?
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(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 worlds 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 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?
II. The commission shall prepare and publish an interim and final report of its findings and
recommendations. The reports shall:
(a) Outline the advantages of, and risks associated with, 5G technology running in conjunction with
the 3G and 4G technology infrastructure.
(b) Develop a strategy, if deemed necessary, to limit RF radiation exposure from 5G or lesser
generation technology relying upon electromagnetic waves.
(c) Include a public policy statement on 5G wireless systems, which either declares the technology
safe or outlines actions required to protect the health of its citizens and environment.
(d) Consider alternatives to 5G technology that will accelerate information flow speeds and volumes
without the use of electromagnetic waves that emit high levels of radiation.
(e) Provide any recommendations for proposed legislation developed by the commission.
III. The commission shall submit the interim report required under paragraph II to the speaker of
the house of representatives, the president of the senate, the house clerk, the senate clerk, the
governor, and the state library on or before November 1, 2019, and shall submit the final report on or
before November 1, 2020.
2 Repeal. RSA 12-K:12 - 12-K:14 and the subdivision heading preceeding RSA 12-K:12, relative to
commission to study the environmental and health effects of the evolving 5G technology, are
repealed.
3 Effective Date.
I. Section 2 of this act shall take effect November 1, 2020.
II. The remainder of this act shall take effect upon its passage.
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
10/10/19
8:30-10:30am
LOB 202
Meeting called to order by Rep Abrami at 8:30am.
In attendance: (13) IEach member discussed their backgrounds)
Rep. Patrick Abrami-speaker of the house appointee
SenatorTom Sherman-president of the senate appointee
Rep. Ken Wells- speaker of the house appointee
Kent Chamberlin-UNH-appointed by the chancellor
Carol Miller-NH Business & Economic Affairs Dept.
Denise Ricciardi-public-appointed by the governor
David Juvet-Business and Industry Association
Brandon Garod-AG designee, Asst. AG Consumer Protection
Bethann Cooley-CTIA, trade association for wireless industry and manufacturers
Michelle Roberge-DHHS- Commissioner of DHHS appointee
Dr. Paul Heroux- Professor of Toxicology, McGill University- speaker of the house appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Not present: (1)
Frank MacMillan ,Jr. MD-NH Medical Society Environmental Medicine
Agenda: (attached)
I. Approval of minutes from 9-16-19:
-minutes were approved with changes to be made for Rep. Wells name to be corrected and
to correct quote attributed to Kent Chamberlin in error.
II. Commission in agreement to broaden out to RF effects beyond just 5G.
111 • Dr. Kent Chamberlin Presentation: Electromagnetic Spectrum Physics: (see attached 6
pages)
All information/data is transmitted merely as Is and 0s.
Everything is electrical in the data transmission system.
Data rate= how fast you can send information= bandwidth, etc.
The higher the data rate, the higher the frequency.
Page 1 of 9
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Frequency is inverse relationship to wavelength. Increase frequency, the shorter the
wavelength.
The data rate can be no faster than half the speed of the oscillator for acoustic
transmission. Therefore, data cannot be sent very quickly at low frequencies.
Two fields are generated: Electric and Magnetic fields in electromagnetic transmission.
Antenna converts voltage to E/M waves or the reverse.
Wavelength is distance from peak to peak of the wave. The lower the frequency, the
greater the wave length, the larger the antenna needed. Need high frequency, shorten
wavelength to have smaller antenna.
We need high frequency for high data rate for small antenna for mobile devices.
2.45 Ghz Industrial scientific Medical band.
800 Mhz-2.7 Ghz currently for cell phones same as microwave oven frequency.
5G is proposed to be 86 Ghz, significantly higher, close to the invisible spectrum.
Photon Energy =frequency x Planck's constant= to find energy in photons of the
frequency.
Wave particle duality which is part of quantum physics is important to look at for health
effects.
Sherman: why doesn't my cell phone fry my hand like a microwave oven if I put my hand in it?
Chamberlin: 1.5 Kw for a microwave is more watts of power than your cell phone. Power drives the
heating. Increased power increases photons but energy remains constant. We need to look at Quantum
Physics and photons.
Rep Abrami: non ionizing vs ionizing?
Chamberlin: We need to look at photons for that. EMR can be represented as discrete packets of energy
called photons. If photon energy is great enough to detach electrons from molecules, you have ionizing
radiation or heating, if power is great enough. It is a fuzzy line between ionizing vs non ionizing
radiation. You will have heating if thermal radiation from microwaves is strong enough.
Sherman: if visible light is that far along the spectrum, why isn't it damaging?
Chamberlin: We know that it is. You are also exposed to UV rays in light like sun or tanning beds.
Woods: Can it be damaging but non-ionizing?
Wells: yes...an example of an egg frying.
Woods: Proton tunneling- protons go from one side to other of DNA which creates a misread or error.
Non-ionizing is in that category because hydrogen bonding can be flipped during proton tunneling.
Quantum physics. There is a probability it can go through the energy barrier. Be aware, because there
are other mechanisms by which energy levels can be damaging but non-ionizing.
Page 2 of 9
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Chamberlin: EMF simulation- if we increased the wavelength and it strikes something like wet wood,
some of the energy reflects back like radar. Some of it gets transferred into the wood or object. The
wave is getting smaller as it enters because it gives up heat and warms the wood. You get heating from
within and you do get heating from the outside.
Sherman: Does impact of reflected wave change the amplitude of the incoming wave?
Chamberlin: Yes. It causes a partial standing wave.
-High frequency supports higher data rates and allows for designs of convenient sized devices.
-Relatively (600 mw to 3 watts) low power of cell devices, supposedly won't cause heating.
- Signal loss increases with increasing frequencies which is why they need to be so close to towers.
-Cell phones adjust power output as needed. Cell works harder if signal is weak or antenna is covered. It
will pump more EM energy into the user. (22-45 miles) typical cell power distance ranges.
The closer your cell phone is to your body, the power is significantly greater. What goes through
someone's head while talking on cell phone? It uses your head as a ground plane before radiating
outside, standing waves and resonances within cavities like sinuses. This isn't good. We need to ask. If
it's harmful, what can we do about that?
Sherman: Are you saying that human tissue becomes part of antenna or diffuses power into tissue?
Chamberlin: Yes. Your head acts as antenna or ground plane. It excites current inside your skull and
causes heating. Is it significant heating? I don't know.
Abrami: original studies in 1990s studied thermal effects. Studies say potential biological effects. As a
Commission, we will be about science, not speculation.
Wells: Besides ionizing or non-ionizing radiation, other photo chemical reactions are at play. For
example, vitamin D or Plastic beach balls out in the sun. The red ones fade from photo chemical
reactions. It is consequential.
Sherman: Seacoast terrible cell service. Does that mean cellphones work at higher level then
Manchester? If that's the case, are we getting more of one kind of EMR from cell tower? Or cell phone?
Chamberlin: If cell tower is far away, will not get constant radiation. However, your cell phone will give
off higher radiation because it works harder to find the signal. But, we can choose to have a cell phone
off or not radiation constantly.
Cooley: with small cells, your phone battery is not working as hard to find signal and works at lower
power.
Sherman: what are you getting in exposure from that closer infrastructure?
Page 3 of 9
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Chamberlin: which is worse? Short high bursts? Or constant low level doses?
Roberge: On your slide, the higher the red in the brain, the higher the intensity?
Chamberlin: yes.
Denise: Does that explain the rise in brain cancer?
Chamberlin: It's a correlation but is that causation? I don't know that answer. We need to look at
epidemiology.
Wells: Brain Cancer and reproductive organs don't require big voltage to affect.
Woods: much of our tissue is ionized and that is a natural state. Your bones don't grow or heal unless
you have an ionized state. Biological tissue can operate in an ionized state.
Abrami: Some say it's safe because it's non-ionizing. But is that a true statement? That's why I bring that
up.
IV. Dr. Paul Heroux Presentation: Biological Effects of RF Radiation: (see attached 6 pages)
- Occasionally, we make mistakes in public health with uncertainty. Because we did not
recognize accurately the danger, In 2007, we changed chromium 6 from 100 to 5 which is a
factor of 20 that we misjudged safety. Workers under the old limits have 35% chance of
cancer from exposure. The new limits reduced to 4.5%.
-Risk is a part of life. We cannot have zero risk. Important to realize that legal exposure
limits are what is known at the time, for the exposed population, and if there are the
alternatives should be part of risk assessment for an agent.
-EMR standard came about after second WW. U.S. was the only country to produce a
standard because they were the only ones who had that capability. The military was the
source of deciding that heat would be the criteria.
- Navy, Air Force, Army: EMR enormous importance in time of war... would need radar to
survive. Applications involving military were given high priority at that time.
Colonel George Knauf of USAF and Dr. Herman Schwann, bio-physicist, were those making
decisions. At that time, it was perceived as non- patriotic to suggest any ban of use of Emfs
because of Cold War with what was considered a nefarious power. People gave green light
to military which was understandable at that time.
-Debating the danger of microwave: 1960-1990. There was a rift in science at that time.
Page 4 of 9
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-Biophysicist, Dr. Herman Schwann, using physics thermal guidelines for heating
experiments with short 30 minute exposures. His understanding was limited at that time.
-Biologist Allan Frey used biology based guidelines, microwave hearing, blood-brain barrier
leakage and chronic 24x7 exposure. Some research was fabricated to discredit his work.
Military point of view: yes there is doubt to risk but people in service get hurt all the time.
So we err on side of keeping armed forces with best technology available. Lots of things are
acceptable in times of war.
USAF standard from 1960 survived more or less in this form as standard today in the US.
Interestingly, USAF was 10mW/cm2; General Electric was lmW/cm2;Bell labs was
,lmW/cm2 and the Soviets .01mW/cm2.
Soviets based their standard on nervous system disturbances, not heating. They provided
two standards; a higher standard for their military and much lower standard for domestic
applications.
The US did not accept this difference. USAF, ANSI, IEEE, FCC...standards still based on
heating... as being the only dangerous agent. It's not easy to measure real exposure in high
frequency. This limited capabilities for biologists to be part of this process.
1966 Health Standards were ultimately developed by 15 people: 10 from military,1 oil,l
space, 1 General Dynamic, 1 US Treasury and only 1 from Public Health.
Very heavily biased to applications vs biological affects... are exposures for fighter pilot in
F16 appropriate for children in classrooms today?
In commerce and engineering, people are highly motivated to promote product. If someone
says, maybe there is a subtle affect related to your product that you have not investigated,
most companies will not have the desire nor resources to do so. This is not a recent story.
Adam Smith...warned if merchants have their way, they will act in such a way to promote
their product... beware. This has lead in the past to public health issues:
-Air pollution is one of these. Air pollution is visible. However, no one realized it until 1952
when 12,000 people died in four days...and that was what finally motivated people because
it was obvious.
-Lead: 1930s. They knew at the time it was toxic and GM could have decided to use ethanol
in fuel but they knew it could not be patented and you could not make more money. The
company decided to use lead instead. You may not die immediately, but your civilization will
be inferior as a result... 15 million US children lost 10 IQ points as a result of that decision.
Page 5 of 9
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-We should use alternatives, if they exist for public health.
-Today an average of three hours a day are spent on mobile phones, texting and internet
access. The cell phone has been an incredible success. Schwann or the Colonel did not
anticipate the situation we are in right now. This explosion in constant exposure should
have changed the risk assessment today.
-We are being exposed to chronic man made waves in a very short span of time. The reason
we adapted to the radiation of light is we have had millions of years to adapt. What is less
certain is if we are resistant to other forms of radiation like man made technological
radiation.
-RF exposure and Low Frequency exposure: all signals that carry data, function in bursts.
Many biological effects we detect, refer to modulation at LOW FREQUENCY (non thermal
and nonionizing). This is important.
What evidence do we have that this radiation is biologically active?
*Altered enzyme activity, biochemical changes, Oxidative Stress (ROS), pathological cell
changes, neuro-behavioral effects, DNA damage, Altered Gene Expression, Brain wave
changes, (hundreds of research papers)
Currently, 44% of the world is living under much lower standards vs. US and much of the
western world which have the highest standards allowed.
-How did IEEE react to these facts?
Engineers had the notion that public health people are trying to get grants based on the
success on the telecom industry. There was a great deal of suspicion as they used research
unfamiliar to them. Public health people, doctors and biologists realized they could not
bridge the gap between engineering and health.
Dr. Carpenter designed the Bioinitiative Report to establish a better standard. But this
group is lightweight compared to interests of industry. Academics are a loose group with
very limited means and the results had very little influence. The situation is starting to
change in Europe in particular in allowing the exposure to humans.
What is 5g? What does it mean?
-Slice spectrum into tiny bands changing 12.5 times per second your cell phone can change
frequency.
- Time domain multiple access in bursts.
Page 6 of 9
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-Space segmentation...instead of broadcasting in every direction use narrow beams, 3-10
degrees in width. Tom Wheeler of FCC said it's a wonderful new idea ...but Russians had in
1981 most sophisticated radar... already in military long time ago but what is new is beam
steering and beam focusing. This results in a lot more radiation and information being
broadcast for the Internet of Things. (IOT)
- Noise is important. IOT seems like a great idea but it will be a self-fulfilling prophecy. It will
be difficult to extract information from all the noise from all the waves constantly radiating.
-Some people think less penetration in the body will result from 5G...but UV causes skin
cancer at penetration of .1mm which is less penetration than 5g.
Abrami: pulsing?
-Amplitude modulation... allowed us to send voice over large areas... modulated with voice
of person. When FM came along, this allowed us large amount of stations but you had to
allow more power. Then, we changed from analog to digital or data as it can be compressed.
Now, it is sent as pulses. Are pulses more negative affect than waves? All indications are
that they are more biologically active. The irregularity of the pulse creates a challenge to the
organism. The organism is hit vs being pushed. Irregularity of the challenge to organism is
important.
-3G/4G cell phones... we had a lot of exposure to these pulses. These bursts are so useful
that this was not taken into account. You do not want your phone to use high frequency all
the time so you can save power.
Sherman: The difference between lOGhz and 50Ghz is less penetration but is there increase
in intensity of penetration?
Heroux: Yes.You will have more concentration of energy.
-Caution: Phone industry wants to get rid of SAR because they won't be able to sell them
because that concentration will raise the SAR above the limits. They will be illegal. They will
say power density should be the new standard. All that will do is change the location of the
cancer in the body as it will be more concentrated. Regulators are coming from the industry
to set standards for their products.
- RF in cars is a public health threat. They will become radiation intensive. Companies are
more concerned about "features" in car vs the biological effects.
-IOT is dream of engineers to put RF in anything that you can get information from. But they
are also taking information from people without authorization.
Page 7 of 9
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-We want the capacity but should a company be able to put that in a product without my
authorization or knowledge? It has to be controlled.
Abrami: Can you touch on autonomous vehicles? Colleges have grant money to look at it.
- It is NOT TRUE you need 5g for autonomous vehicles.
-Vision and laser scanning are being done at MIT. You need very rapid scanning but it is
being developed.
-Engineers are smart. If we tell them to do it safely, they will.
-You don't need 5g for remote medicine although they will say you do because of low
latency.
-In terms of humans, low latency does not mean much. It means a lot in a process in a
plant or with robots, but not humans.
-Is it possible to non thermally affect cancer cells? Yes. Dr. Heroux's research.
- ALL cancer cells react to artificial EMFs.
-Low level radiation, similar to cell phone at low frequency have same or higher power
of oxygen that can affect the body. 02 is fuel for body that generates ROS but we need
02. However, fields that produce larger effects like cell phones, we can CHOOSE not to
have.
-Organs that need the most oxygen are most affected. Cells die more by necrosis than
aptosis.
- In 1900s rates of disease and chronic disease very different than what we have now.
Abrami: has your research been replicated? Yes... there are hundreds of research papers to
support this.
Cell necrosis vs fibrosis:
Sherman: necrosis (cell death) to fibrosis (scarring)
Tissues most at risk...are brain, pancreas which has high levels of ROS already, diabetes.
-Non thermal effects... RF changes behavior of cells which is why we talk about children
and digital RF exposure in their lifetime. There are places now eliminating wifi from schools.
-Pregnant women, infants, children: cells replicate quickly, developing tissues are
vulnerable, microwaves penetrate young brains more deeply.
- Reproduction and sperm counts are very serious subject but I do not have time to cover all
effects.
-You don't need energy to affect biology, they are already ionized.
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- According to Prof Martin Blank: DNA becomes unstable from EMR.
Our bodies are electrical machines...the movement of protons tunneling and effect on ATP
synthase, which is one of the most sensitive places in the body result from EMR.
-Importance of cell phones are so great people are not willing to act on risk. We need to find
a way to maintain function and minimize the risk.
-If you expose brain to EMR: penetration of albumin in brain= egg white which carries toxins
so now you have toxins carried into the brain. Alan Frey detected permeation of blood
brain barrier. The lesions were occurring have pattern have no connection to simulation by a
physicist. It means there is penetration of albumin into the brain. 50% of protein in blood is
albumin. It is used to capture toxicants of all sorts so your body is not affected too rapidly.
It captures it and releases slowly so you aren't shocked. When albumin goes into brain, it
carries all toxins that you carry in body into your brain. It is not a good thing and happens
in a very short time.
Ramazzini & NTP studies.... Yes... DNA damage & cancer particularly, in nervous system.
Wells: EMR studies with plants? Yes...There is a lot of literature even with visible light. The
visible light is not a grave problem because we have evolved over millions of years... tissues
can adapt over time...rapid changes we cannot adapt to.
Abrami: We ran out of time. Dr. Heroux, you may finish your presentation at our next
meeting.
Next meeting will be Thursday, Oct 31st at 9 am.
Nov 1st,first draft report due
V. Meeting Adjourned at 10:30 am.
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
10/31/19
9:00-ll:15am
LOB 202
Meeting called to order by Rep Abrami at 9:00 am.
In attendance:(12)
Rep. Patrick Abrami-speaker of the house appointee
Senator Tom Sherman-president of the senate appointee
Rep. Ken Wells- speaker of the house appointee
Kent Chamberlin-UNH-appointed by the chancellor
Denise Ricciardi-public-appointed by the governor
David Juvet-Business and Industry Association
Brandon Garod-AG designee, Asst. AG Consumer Protection
Bethanne Cooley-CTIA, trade association for wireless industry and manufacturers
Michele Roberge-DHHS- Commissioner of DHHS appointee
Dr. Paul Heroux- Professor of Toxicology, McGill University- speaker of the house appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Not present: (2)
Frank MacMillan, Jr. MD-NH Medical Society Environmental Medicine
Carol Miller-NH Business & Economic Affairs Dept.
Agenda: (attached)
I. Approval of minutes from 10-10-19:
-minutes were approved with changes to be made for proper spelling of Bethanne Cooley
and Michele Roberge.
II. Webex (NIEHS) National Toxicology Program Study Presentation
Presented by Dr. Michael Wyde, toxicologist and Dr. John Bucher senior scientist and former
Director of NTP Division, in the Division of the National Toxicology Program at the National
Institute of Environmental Health Sciences (NIEHS), which is a part of the National Institute
of Health.
Interagency program (NTP) was established in 1978 with the: National Institute of
Environmental Health Sciences, National Institute of Occupational Safety and Health,
FDA (National Center for Toxicology Research).
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The NTP's mission is to evaluate agents of public health concern by developing and
applying tools of modern toxicology and molecular biology.
Their scope of work includes: research and testing agents of public concern; conduct
literature-analysis activities to identify cancer and non-cancer human health hazards;
develop new approaches to better predict how agents affect biological responses and
communicate results to multiple stakeholder groups through technical report series,
journal publication and the NTP website. ( https://ntp.niehs.nih.gov)
In 1999, the USFDA nominated radiofrequency radiation (RFR) of wireless
communication devices to NTP for study.
At that time, there were 100 million users. Today there are over 310 million Americans
and 5 Billion worldwide, exceeding the number of people.
Biological effects have been reported in cell-based tests and in laboratory animal
studies. However, animal studies have not consistently demonstrated increased
incidence of tumors at any site associated with exposure to cell phone RFR in lab
animals.
There are challenges and logistical issues associated with RFR study.
According to FCC, RFR limit is 1.6W/kg. Needed to design a new way to expose to RFR
for research. Study focused on 2G and emerging 3G technology at the time.
Used reverberation chambers as recommended by National Institute of Standards and
Technology (NIST): shielded room with RF antenna distributing frequency into the room
with uniform exposure. The benefit is that they could control and monitor the
exposure.
Three phase study: 5 day, 28 day and 2 year, alternating on/off for ten minutes at a time
and exposed to GSM and CDMA signals for both mice and rats.
NTP Findings:
• NTP's study on cell phone RFR is the most comprehensive assessment of health effects in
rats and mice from exposure to 2G and 3G cell phone RFR.
• There was CLEAR EVIDENCE that exposure to cell phone RFR caused malignant
schwannomas (heart tumors) in male rats.
• There was SOME EVIDENCE that exposure to cell phone RFR caused malignant gliomas
(brain tumors) and pheochromocytomas (adrenal gland tumors) in male rats in addition to
positive findings of DNA damage to hippocampus and equivocal findings in frontal cortex.
• In mice, equivocal evidence of carcinogenic activity in both male and female and positive
findings for DNA damage in the brain in males and blood cells in females.
• Positive findings for lower weight babies exposed in utero for rats and at five weeks for
mice.
• NTP uses a 4 level scale: no evidence, equivocal evidence, some evidence, clear evidence.
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• Final conclusions represent the consensus of NTP and a panel of external scientific experts
who peer reviewed the studies at a public meeting on March 26-28, 2018. Two technical
reports: TR 595 (2018) and TR 596(2018) Note: these findings should not be directly
extrapolated to human cell phone usage because they were done at higher exposure and to
the whole body during research.
• NTP Publications published in journals: 2017 in IEEE and in Bioelectromagnetics in 2018.
Goals for further study:
- Address issues raised in peer review and do follow up studies.
-Smaller scale exposure facility and quicker time frame to get data out.
-Use newer technology: 3G and 4G
- 5G uses different modulation schemes and frequencies above 60Ghz which behave differently.
- Evaluate DNA damage, establish biomarkers of exposure and probe biological mechanisms for
RFR induced effects.
-What role does DNA damage and repair play?
Questions:
Abrami: Was the level 1.6W/kg in 1999? Is it the same today?
Wyde: Yes. It is based on acute exposure based on tissue heating. NO changes have been made in
twenty years to the standard.
Abrami: If current standard is 1.6W/kg, where did damage start at the three levels you tested?
Wyde: Heart tumors were significant at 6W/kg showing clear evidence with some at lower exposures.
Abrami: That is well above the standard of 1.6W/kg and I am assuming phones are lower.
Wyde: Theoretically, 1.6 W/kg is the limit for phone which is what device is allowed not the exposure to
people. New evidence is that SAR from phones is actually higher than 1.6W/kg. Part of that is because
phones are not supposed to be next to your head.
Chamberlin: Reverberation chamber to have homogeneous 1.6 W/kg exposure, but how does that
correlate to holding phone next to your head for a human?
Wyde: You have pin point exposure to the head but we don't have data on what that exposure is to all
areas of the body at the same time. This is why we can't directly apply results to humans.
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Chamberlin: Frequencies for 5G. You mention 60Ghz but I heard 87-100Ghz which is much higher. That
is significant. We also have Beth here from industry.
Wyde: I defer to the expert. I am not aware of any intention to move above 60Ghz.
Cooley: I am not allowed to be privy to future deployment plans as a rep for CTIA. I only have
information that the public has because of antitrust laws.
Sherman: When we are in a network of wifi/phones like we are right now, is there a certain level of
radiation we are exposed to without even using our cell phone?
Wyde: Yes. That is one of our concerns in an increasingly wireless world. What is our background level
of exposure when we are sitting in a room surrounded by people with cell phones or a school with wifi?
The way we use devices has changed. It's not just a cell phone. Actual exposures is important, not just
what a device emits.
Sherman: So to get to 6W/kg in a human holding a cell phone to their ear, could they get to that level or
exceed it? Or is it well beyond any potential exposure a human would have?
Wyde: That exceeds what a device is capable of. But independent studies have looked at that showing it
exceeding 1.6W/kg.
Sherman: Does exposure increase with increasing 2G, 3G,4G and 5G capable phones?
Wyde: no. the G means generation. (Woods, Heroux shaking heads...YES it does)
Gray: Does the energy emitted by antenna that is absorbed fall off as a cubed function?
Wyde: No, not cubed but squared.
Gray: Area is two planes, three dimensional is cubed. I would think it would fall between those two
planes. I will explain later why I asked the question.
Wyde: That is not our area of expertise.
Chamberlin: I am not sure it's relevant.
Wells: Talking about intensity of field as opposed to photon energy. Photon energy definitely goes up as
frequency increases.
Ricciardi: DNA damage was found without a degree of body temperature change which means non
thermal effect. The FCC limits say that one degree of body heat is considered thermal heating. So what
does that say about the FCC limit? Does that mean that this is harmful?
Bucher: That's one of the things we need to look at in the future. One idea is that there is an inhibition
of the repair process. DNA damage happens all the time and is RFR slowing rate of DNA repair? We need
to look at that.
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Ricciardi: I am still not clear. Your study was designed to test non heating damage. You found damage
so doesn't that mean that FCC assumption that only heating can cause damage is incorrect and no
longer accurate? Would you agree?
Wyde: A lot of people believe unless you heat tissues, you won't see health effects with RF. This study
disproves that as we did not have over heating but we did see damage.
Abrami: Dr. Chamberlin hopefully will bring in someone from IEEE to help us understand how they
developed those standards.
Sherman: Was there any way to determine cumulative exposure rather than dose related? Or did you
not look at that?
Wyde: We did not look at that when we designed studies.
Woods: Question on the structure of cages? What was it made of? Were they metal? They look like a
faraday cage. Where was RF measured?
Wyde: That's a very good question. The chamber is stainless steel. Anything in the chamber was non
metal so it did not affect the signal. We did not want to heat anything or cause problems for the
animals. NIST took measurements to make sure there was uniformity in the whole space.
Abrami: what is a faraday cage?
Woods: Faraday cage is a metal mesh network that prevents RFR exposure to what is inside.
Woods: Why did you use rats and mice? Why were rats started in utero and mice at five weeks? Any
animal is much more sensitive in utero to damage. How much of result was attributed to in utero?
Bucher: Traditionally, all cancer studies use both rats and mice. We only use in utero exposure with rats
because it's harder to use hybrid mice in utero. By using both, we get more information than we would
normally.
Wyde: Part of the reason for in utero, is it mimics human exposure in utero.
Roberge: Were you able to see the difference where health effects occurred, with regard to various
levels, knowing your exposure was above the 1.6W/kg that a device is permitted to emit?
Bucher: We need to backup and understand what we were trying to do. We needed to make sure we did
not use thermal limits more than one degree of body temperature that animals could tolerate. Different
sized animals absorb different amounts. Rats because they are larger, could only be exposed to lower
levels because we saw the largest response on the largest animals. They were affected more with
strongest responses to RFR.
Roberge: Are you looking at synergistic effects of multiple frequencies in your future studies? Does that
influence exposure?
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Wyde: yes that is part of what we are looking at. How are people's exposures going to change with 5G?
That's very important as we move forward.
Chamberlin: Are the signals realistic by alternating regular modulation, since it's not realistic compared
to the pulsed or bursts we are exposed to now. Cell phones don't radiate continuously. Did you look at
that?
Wyde: We tried to create scenarios with spikes and ten minute on and off exposures. We had
modulating patterns that would mimic conversation on cell phones. We tried to create relevant
exposure scenarios.
Bucher: We used actual GSM and CDMA signals that spike. GSM modulation when signals are sent only
1/8 is the spike. That is what we used.
Abrami: Legislators are being faced with push back on small cell towers with 5G at street level and every
250 meters apart with millimeter waves.
Bucher: We are keeping close eye as 5G emerges.
Heroux: NTP study was designed quite a long time ago. Our situation is that we deploy things and the
time to assess health impacts is much larger than rapidly evolving technology.
Sherman: Can you recreate background daily exposure to what we might anticipate by increased
number of 5G towers in a neighborhood using this model? I would like to know BEFORE deployment.
Wyde: The technology is not capable of doing that with 5G frequency.
Bucher: Our exposure depends upon how we are positioned with respect to antenna. To study 5G and
combine with lower level exposure, is an enormously difficult scenario to recreate.
Wells: For base station towers 250 feet apart, the energy density is 5x higher than a cell tower. The
depth of penetration in tissue, the higher the frequency have higher photon energy, the amount of
energy being absorbed in a thin layer is significantly higher. Would you agree?
Bucher/Wyde: yes. We would agree. But power levels are lower.
Ricciardi: power levels are lower but it's in close proximity 24 hours a day, which is microwave radiation.
Would that not heat tissues over time? If so, would we assume 5G would not be safe?
Wyde: No. Our exposure is a function of distance and power levels and other factors .At this point, we
don't' know.
Chamberlin: Your category, Clear Evidence. Can you compare that to relative risk?
Wyde: No. clear evidence is a descriptor we use in our cancer studies. It does not relate to relative risk in
the human population.
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Chamberlin: Are you using P value of .05 as statistically significant value?
Wyde: We look at .05 as cutoff as statistical significance but often the clear evidence findings have a
lower P value.
Sherman: We should get their peer reviewed articles. They may have more data in them.
Chamberlin: It would be nice if they could compare it to smoking or something.
Ricciardi: There is an online library at: https://onlinelibrary.wilev.com They just published new
findings in October.
Woods: We need to be cautious because we cannot make one to one correlations with humans when
we look at these studies. For example: if aspirin (djoxin) was tested today, it would be banned because it
causes cancer in mice and rats. So we need to be careful when looking at these studies. Is there a
significant difference between a rat and a mouse?
Sherman: We have to be cautious before we extrapolate to humans but we can't test humans without a
long period knowing their cumulative exposure. You can't recreate it because it takes 20 years for
people to die before we know anything. Hopefully, we will take as much evidence as we have. Because
what we have seen in other industry settings with contaminants, we don't know until a lot of people die.
They cannot recreate this in a lab. It's a warning on both sides.
Woods: We have to be able to say, we don't know. Some of the other literature, they were criticized for
poor standards.
Ricciardi: Ramazzini Institute studies duplicated that study, using very low standards.
Wells: These are very difficult studies to do. The human body is an antenna. Larger animals are more
exposed. Humans are much larger than mice or rats. They are studying critters smaller than the
wavelength. When we talk about base stations for 4G transmitting at lOOwatts but KM away, that is
much less than the magnitude of intensity from 10's of meters away of 5G antenna, even if it's only 7
watts. A flaw in this study is that they are treating them as chemical exposures. The room has a uniform
feel but when it hits the skin, it's no longer uniform. Penetration depth is important. With 5G that's a
very thin piece of tissue getting a lot of penetration. It's difficult to study.
Heroux: Mice and rats are only superficially similar. They are used because they are cheap, easy to
handle. We know they are different and provide different information. Toxicologists know about these
things. That is why they design a model on how to use animals in these experiments, which is extremely
complex.
Cooley: What is on the towers is not line of sight technology. Small cells are. They are not beam forming.
We will talk about this at future meetings as well.
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Sherman: I have a comment on autonomous vehicles. People claim you need 5G for those. My nephew
is one of the lead engineers for the Google vehicle, Waymo and he said the very definition of
"autonomous" is autonomous. It does not or should not need wireless or power networks to depend
upon. I don't think the ongoing claim that autonomous vehicles need 5G, is true.
Heroux: I agree MIT as well has a car that does not rely on 5G. There are many ways autonomous
vehicles can operate using: vision, laser scanning, ultrasound. EMR is not required.
III. General Discussion:
We will hear from Prof. Eric Swanson, U. Pittsburgh provided from Bethanne Cooley at the
next meeting: Thursday, November 21st at 8:30am.
Interim report: Agreed upon with correction for non-ionizing statement to reflect properly
Ken Chamberlin's opinion from his presentation.
IV. Frank Clegg Video: Framing the Issue:
- Former CEO of Microsoft Canada, 40 years in technology sector.
- Current implementation of wireless is not safe.
-5G is not tested.
-Millimeter waves are used by the military for crowd control.
-We are advocates for safe technology, not, no technology.
-FCC is made up of previous telecom, lawyers and engineers not doctors.
-No oversight provided by FCC. Telecom industry is self-policing.
-1996 Telecom act prevents anyone from suing Telecom for health injury.
- Countries like China, Russia, Italy and Switzerland have safety limits lOOx safer for citizens.
- Today we have significant exposure in our homes, schools, work and public spaces.
-Many states and cities are questioning safety, while the Federal Govt and some other states
are fast tracking 5G.
-Many health and mental health effects, including permanent DNA damage.
-Individual, state and local rights are being passed over to telecom industry. That is a
significant and historic power shift in rights. Telecom has over 500 lobbyists.
-Swiss RE has designated 5G as a significant insurance risk.
-Convinced there are safer alternatives available so we can have technology safely.
- We need to advocate for change to allow industry to become more responsible.
-Most important thing you can do is to get educated and educate your family, friends, co-
workers, state, local and school officials. Knowledge is power and your power is in your
hands.
Abrami: If anyone has any questions for Frank Clegg, we can contact him to talk with us.
That video encapsulates a lot of the issues we are dealing with here.
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V.
Dr. Heroux Completion of Presentation of Biological Effect:
-Human evidence: two documents that are very detailed human evidence: ELF (power systems)
and RFR(communication). Both classified both high and low as possibly carcinogenic Class 2B.
IARC repeats old notion that there is no mechanism that supports this. They are great
epidemiologist but not cognizant of other things. Anthony Miller is worried about rollout of 5G
because he is seeing an increase in student 15-19 increase 1%/year in lethal brain tumors. He
would like IARC to go back to reclassify because IARC said there was a lack of animal studies but
there are many studies which was the reason for the Class 2B. How many will they ignore? He
would like it classified as a class I carcinogen.
-Another study shows with a cell phone one and off, that glucose metabolism is increased in the
brain when cell phone is on. This is not thermal or heat related but it is an effect.
- Also troubling evidence on increasing gray matter changes.
-Hypersensitive: those who feel its impacts. In Finland, there is software to plot a path from
where they live to where they want to go to minimize exposure to radiation. This software has
been downloaded 200,000 times. These people are very real. Contrary to what a lot of the
medical community is telling them, it's not in their mind. They are physical reactions and not
everyone has same effect, nor should they. That is typical of medicine. One of the reasons is
that many of them have variants in Glutathione enzyme which is a major detoxifier. EHS people
have variations in this enzyme lOx higher than non EHS. Genes will not allow them to produce
effective versions of glutathione transferase. The next generation will likely be more sensitive if
both parents have this variant. You see a lot of people with EHS, who also have multiple
chemical sensitivities because they share the same detoxification mechanisms.
Proton tunneling: basic mechanism of action of EMR on tissues. Ionizing argument is
beside the point. Biological systems are ionized. This is relevant. Stability of materials is
an illusion. Every molecule of water decomposes and recomposes. PH of pure water is 7.
This is based on the mobility of protons. In every living system, mobility of protons is
very important.
- Oxidative phosporylation is arguably the most important process in the body. Science
did its work on this very quickly after concerns of EMFs on this process. Essential
mechanisms of action were discovered of EMFs but ignored. A group of enzymes from
1-5 synthesize ATP. Protons and electrons have to move through our body. EMFs affect
the movement of theses affects function of enzymes. When protons and electrons are
free, they are vulnerable to EMR especially ELF components. Within Mitochondria, you
have a PH of 1. You have the highest electric field. If you apply EMF to this system, you
disrupt the flow of electrons and mainly protons. Entry channel is completely
hydrophilic. It has the same structure as ice and the way enzymes work is proton
tunneling. Through this, the proton is vulnerable to fields as small as 20 nano-tesla as
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confirmed in experiments. This is very vulnerable to EMR. The semiconductor industry
has devices that work on the same principle. If you reduce ATP activity, electrons have
to jump across distances and are vulnerable. There are 400 publications that talk about
these effects on enzymes from EMF. These electrons form ROS (reactive oxygen species)
and have a hard time functioning. The jumping of charges from one place to another
creates a lot of room to interfere with propagation of electrons that support
metabolism of cells. The science behind tunneling mechanism is... If you have a
quantum of energy of any frequency, you are going to have a change in probability to
jump from one place to another. This happens at levels way below thermal levels of FCC.
At Duke University in 1985, research showed changes the function of mitochondria but he was ignored.
Nobody reads science or a paper unless someone needs them. The mechanisms and science are there
but they are unknown.
I agree with Frank Clegg. We can get everything we want. You don't to fear you will lose your cellphone
or go back to the dark ages. We can do this very well. We know engineers can do this.
Woods: Buran zones are happening at mitochondria level.
Sherman: Can we get the digital link to the slideshow?
Abrami: We have a website now where all info is posted.
Sherman: When you talk about impacts at exposure much less than our limit, does is increase cell death
in terms of end organ damage?
Heroux: Biology is an electrical motor. We are electrical. Any field is possibly going to interfere with this.
Heroux: I exposed cells to radiation and see how cells died. It's not to kill them but does it change how
they die by being exposed to EMF. If you compare the power of fields in everyday life, their ability to kill
cells is higher than oxygen, creating ROS. ELF component of Telecommunication signals is a significant
component.
It increases cell death and diverts cells toward necrosis vs apoptosis. The cell doesn't have enough
(energy) ATP and it gives up and goes into necrosis. EMF has power to increase ROS leading to chronic
diseases with inflammation like Alzheimer's and Diabetes. So why add on to the load we already have
with ROS? We can control electric and magnetic exposure. If you ask at a hospital how many
Parkinson's, are related to EMF exposure? They say none and claim EHS people don't exist at all. It is a
part of chronic illness. I am not saying it's all of it but it is a part. We have just gotten used to these
illnesses. If you can decrease diabetes 20% by reducing this effect, you will save a lot of money in
medical care if you address this issue.
V. Meeting Adjourned at 11:15 am.
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
11/21/19
8:30-10:35am
LOB 202
Meeting called to order by Rep Abrami at 8:30 am.
In attendance: (11)
Rep. Patrick Abrami-speaker of the house appointee
Rep. Ken Wells- speaker of the house appointee
Kent Chamberlin-UNH-appointed by the chancellor
Denise Ricciardi-public-appointed by the governor
Brandon Garod-AG designee, Asst. AG Consumer Protection
Bethanne Cooley-CTIA, trade association for wireless industry and manufacturers
Michele Roberge-DHHS- Commissioner of DHHS appointee
Dr. Paul Heroux- Professor of Toxicology, McGill University- speaker of the house appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Carol Miller-NH Business & Economic Affairs Dept.
Not present: (3)
Frank MacMillan, Jr. MD-NH Medical Society Environmental Medicine
David Juvet-Business and Industry Association
Senator Tom Sherman-president of the senate appointee
Agenda: (attached)
I. Approval of minutes from 10-31-19:
-minutes were approved with comment from Rep Woods.
II. Dr. Eric Swanson: University of Pittsburgh. Professor of Physics Presentation
[Here at the request of CTIA but the opinions are his own)
There is a lot of misinformation and misunderstanding out there + fear of the unknown=
trouble.
Fear of the unknown is what links past worries like power lines and radio waves causing
cancer cellphones killing honey bees to the current ones about 5G and cellphones.
Millimeter waves (similar to 5G) are used in Russia therapeutically for over 50 diseases.
It is not plausible that the same radiation can both cause and cure 50 diseases. It does
neither. It does nothing.
It does not affect living things: and I have two main points.
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Ricciardi: Experiments with 5G on bees show that bees are affected. Bees absorbed more with higher
frequencies.(Scientific Reports: 2Ghz-120Ghz). This could lead to changes to insect behavior over time.
Can you confirm based on scientific evidence that these frequencies are safe for pollinators? What
credentials do you have to speak to this?
Swanson: It's scientifically not plausible that these waves have any effect on ANY living
thing. Biochemical response of a bee cell to EMR is the same as a rat cell and a human cell.
That is my scientific opinion. It's true that EMR does not do nothing.
As far as credentials... There are two aspects:
1. The radiation itself: we understand perfectly since 1875. There are no questions and no
ambiguity. This is where I come from.
2. The biological response: it's difficult to measure. It's complex and messy. We can explain
it all with general physics terms, not fancy biological terms.
Heroux: The IEEE standard is based on resonance between dimensions of humans and for example
(70MHz) frequency of radiation. Frequencies that match the size of the bees, the transfer of power will
be increased by a large factor. These parameters have been recognized by engineers, physicists, etc. not
just biologists. They fly everywhere, not walk on the sidewalks and are likely to go to areas where power
densities are very high. In my opinion, you are not showing much concern for the small pollinators that
we need to survive.
Swanson: I disagree with everything you said. If you want I can go into details of why. Resonance is in
fact related to size of important bio mechanical mechanisms inside of cells. There is a famous paper by
Robert Gadera (sp?) from twenty years ago showing these resonance effects just cannot occur. These
are not relevant to biology and cannot occur inside of cells. You said bees are attracted to these things. I
would love to see the study saying bees are attracted to radio transmitters. Bees are actually attracted
to flowers. It's true they don't walk on sidewalks. Transmitters are built where people live, not bees.
That means they are even more removed, not closer.
Woods: I want to clarify your idea that the Bees are like rats and humans. We know if we test
djoxin/aspirin today, rats get cancer but people do not. Can you please clarify what you mean that they
are the same? That seems to break down there.
Swanson: This is a good point. You have to be careful about comparison and I was talking about the
cellular level.
Woods: But chemicals are processed at the cellular level.
Swanson: If you are feeding aspirin to a rat vs to a human and if they normalize for the size, I would
expect the response of test subjects to be very similar. But it's not what we are talking about here.
Chemical reaction is far more energetic than reactions that are relevant to cellphones. Chemicals are
like taking a hammer versus a gently tweaking it, like a cellphone does.
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Chamberlin: On the previous slide, you mention exposure in some cases provides positive therapy. You
are saying that it can't be both helpful and harmful. I disagree. For example, sunshine is a form of
radiation. It is both beneficial like Vitamin D, etc. and harmful like skin cancer, depending upon
exposure. I disagree with the premise stated there.
Swanson: You are right. There is room for something like this to happen. Like I said, I don't find this
plausible and I have a reason why I don't find it plausible but I will get to that.
Abrami: On your electric towers slide, you said were definitive studies disproving health effects . We are
trying to get at is, are there definitive studies RF in general whether it's 3G, 4G or 5G. Right now I don't
know of any definitive studies saying whether 5G is good or bad. As a legislative body, we are trying to
understand. We are blessed with having people in the room who understand these things. We have to
be responsible to our public. If a small cell tower appears in front of their house, they will want to know,
where is the definitive study showing its safe?
Swanson: Valid question. But those studies were specific to those towers. I completely respect that as a
question.
Electromagnetic Basics:
Electromagnetic radiation is the best understood phenomenon in the universe.
It is not nuclear radiation.
It is completely described by three numbers (intensity, frequency, and polarization) which
makes it so well understood and so simple.
Electromagnetic spectrum is a continuum from zero to infinity.
Ricciardi: Are you saying that you do not believe a potential mechanism exists for non-ionizing radiation
to harm us?
Swanson: I will get to that in a minute. Do you mind?
Abrami: Let him cover non ionizing radiation and then ask your question.
Health Effects:
You are well aware that there are health effects on this spectrum.
UV radiation is dangerous. It's not good to get too many x rays. There are two scanners at
the airport and you should go through the mm wave scanner not the x ray scanner because
x rays are dangerous if you expose yourself to too many.
Gamma rays are very dangerous. They will outright kill you.
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Ionizing radiation is damaging because of how it damages things. Your body responds by
producing more melanin. DNA regulates reproduction of cells. You could mess with the
reproduction of your cell and you get cancer. You don't want to damage your DNA.
Shorter wavelength waves carry more energy.
Visible light is just below UV light. Threshold effect between UV light and visible light. We
can be in visible light all day and never get cancer because visible light is lower in energy. It
is only a bit lower. There is no gradual tailing off. There is a threshold. This threshold effect
between UV light and visible light was explained by Einstein in 1905. He won the Nobel Prize
for this. That's called non ionizing radiation.
There is a threshold 1.77ev and 2.25ev or minimal energy needed.
The important thing: is that there is a photo electric effect.
You need ionizing energy to remove an electron off its atom.
When we talk about non ionizing radiation, there is no cumulative effect and there is no
intensity effect and no effect on cancer.
Ionizing is above the threshold effect. Non- ionizing is below on the spectrum.
It doesn't matter how far below the threshold. Something could be just below threshold or
far below threshold. It doesn't matter. The threshold is only thing that matters.
Non Ionizing radiation has no known effect on the human body other than heat.
Heat is just heat and motion of molecules.
Abrami: I understand water vibrates to heat in microwave but you wouldn't put your head in a
microwave would you?
Swanson: I actually intend to put my head in a microwave next week.
Abrami: You are pulling my leg now, right?
Swanson: no. I am not going to have it at full power and will probably put my hand in. My point is, it's
regular heating and what I will feel is my hand getting warm and then I will take it out. It's just like
putting your hand on a radiator.
Wells: If radio frequencies that are non-ionizing have no effect, can you explain how radios work?
Swanson: they have no known health effects on tissue except for heating. EMR is absorbed by your skin.
About half of it is reflected by the body. Metals are special because the electrons are mobile. Our
electrons are attached to a molecule. They are hard to move except the salty water part of the cell. The
signal in the radio just turns into heat.
Ricciardi: Thank you for explaining that. Before I ask my question, I want to understand what you said. It
sounds like what you were saying is due to oxidative stress not heating. Did I understand that correctly?
Swanson: No. I didn't say any of those things.
Ricciardi: Well then. Are you saying there is no real potential harm for non-ionizing radiation?
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Swanson: To the degree that you don't cook yourself, yes.
Ricciardi: There are several studies and if you can debunk them. I have a copy for you.
Abrami: Dr Swanson, can you address these later for time sake during your section on studies?
Swanson: Yes. I will address generic, not these particular studies later.
Chamberlin: I just want to say it's quite a statement and in preparation for service on this commission, I
did a lot of work reading published peer reviewed journals and a lot of them DO say there are biological
effects. So I am assuming you will address those.
FCC Regulations:
I want to clarify misconceptions about the FCC.
The FCC does not conduct experiments. It sets regulatory limits based on the evaluation of
relevant literature made by many nation and international agencies.
One of these agencies is: IEEE which has a rigorous policy creation process.
I was very impressed with their methodology for how they come to their decisions.
They are very thorough. They have various working groups where reports go into a
committee called sub- committee four.
Sub-committee four has 125 members in it. They have a broad swath of expertise.
They looked at 2,200 papers.
5G is just part of the spectrum. It's the 30Ghz part of the spectrum. 5G is new. The physics
and biology of 5G is not.
You don't have to do studies at 5Ghz. Where do you draw the line? The difference between
4G and 5G is essentially meaningless when it comes to the response of humans to this
radiation.
FCC has two primary measures: Thermal behavior. IEEE determines thresholds of watts/kg.
FCC sets its limit 50x lower than the limit detected on animal studies. Based on that they
get the SAR (Specific Absorption Rate which should be less than 1.6w/kg) That is an
extremely conservative number. I mentioned a heating pad earlier that is roughly lOOw/kg.
Another method is the MPE (maximum permissible exposure) Effects on humans start at
lOOx higher than the limit.
Why are there two standards? BC at higher frequencies like 5G that does not penetrate as
far in the body so it's hard to measure so they use MPE.
5G is called small cell because they are low power and closer together and about 30 feet
high.
Your exposure is about .4% of the extremely conservative limit if you stand at the base.
It occurred to me that light is EMR and what would happen if the FCC regulated light? Or the
sun? They don't for obvious reasons. We can see light. They expect us to react responsibly.
For a 100W light bulb six feet away, you are at a quarter of the FCC allowable limit in terms
of thermal exposure. Three feet away, you are at the FCC limit.
If you stand outside in the sun, you are at 1600% of the FCC standard for exposure limit.
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The sun would be outlawed if the FCC regulated it.
Should we worry about standing under a 5G tower? I would say no.
Another example is the brain. It is a radio transmitter transmitting at the thermal end of the
spectrum far higher in energy than 5G. Your body is 85W machine. The brain is 15W. It uses
a lot of energy. The brain weighs about 1 kg. So I estimate an SAR of 15w/kg. So thinking
would also be outlawed by the FCC whose limit is 1.6w/kg.
Let's get to what is does to you. It heats the skin up. The higher the frequency, the less it
penetrates the skin and 5G is at the very surface.
10W/m2 is the FCC limit. Temperature rise at the surface of the skin. According to this
model (The Human Body and MM Wave Wireless Communication Systems accepted2015
IEEE International Conference) which shows a rise in temperature for different energy
densities. The SAR limit of 10W/m2 results in about .1 degree temperature rise.
You would have to climb the 5g pole and hug and wait for your skin to rise .1 degrees.
It would create more heat just in the energy to climb the pole. It's not magical stuff. It's just
heat energy.
Stepping outside or drinking a cup of coffee, you get a larger rise in temperature than
irresponsible behavior of climbing and hugging a 5G pole.
Cooley: When you showed the heights of the various towers and small cells, because there will be 5G
on towers as well. Can you speak to the difference of towers at 100-200 ft vs the small cells at 20-50 ft.
Can you talk about the exposure based on the higher it is, the exposure decreases? I am making an
assumption. If you use an average 150ft tower vs a 40ft small cell.
Swanson: If you are asking what would happen if the tower was 40ft instead of 20, then all of those
numbers would go down. If you double the height, you go down by a factor of 4 if you are standing right
under it. It's not that clean cut. With a higher tower, you have more powerful equipment. It's the same
thing with 5G. If it's a 40ft tower, there will be more powerful equipment on that small cell. You have to
take that into account. I am speculating that when engineers design the towers, they figure how to get
down to l/1000th of the FCC limit. According to research I just read, there are countries that measured
levels at l/1000th of the FCC limit. It wouldn't surprise me if it ends up being a wash if you double the
height.
Cooley: Please clarify a term you used, lens opacity. What is that?
Swanson: It's the beginnings of cataracts.
Roberge: When was the FCC limit set?
Swanson: This is an ongoing thing. I can partially answer this. I know that the IEEE did this in 1996 and
did it again in 2005. I believe the FCC monitors these new standards as they come out .But I don't know
that they had an official meeting to incorporate all of that. I believe there is something in the news
about reinstating a meeting.
Abrami: Yes. We have a paper on this.
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Swanson: I believe you know more than I do about this.
Roberge: When they set this, they were only looking at heat effects on the body. Do you know when
they look at this again and will that include other biological effects?
Swanson: I wouldn't quite put it that way. They looked at 2,200 papers. They don't just go, oh this one
deals with other effects and throw it into the garbage. They take all of it into account. Of course, the
things that you focus on are thermal effects because those are easily measurable. Other effects are
random.
Heroux: You describe the review process of the IEEE in glowing terms.
Swanson: Yes. It was glowing. I was very impressed.
Heroux: Were you there?
Swanson: Was I there? No.
Heroux: Are you a member of SC3 or SC4?
Swanson: No.
Heroux: You don't go to IEEE meetings?
Swanson: Nope
Heroux: So in other words, your description of this review process is based on what you were told.
Swanson: That's correct and from what I read. Yes.
Heroux: Ok. I was there. I can tell you that this process is far from impartial. I have personal experienced
it and if you want, I can tell you how it happened. At the time, I had designed an instrument that
measured pulsed EMF. I was part of an epidemiological study at McGill. It was found that all the
underground workers exposed to these fields and smoked, systematically died of lung cancer. ...All of
them. This was done by Armstrong a biostatistician who is now in London. I was charged with informing
IEEE of this. I was a member of SC4. I went when Eleanor Adair was presiding and I unfolded what had
happened. Eleanor Adair said we will form a committee and we will look at this. There was a separate
meeting. They wanted three members to join the president to study this. I was the one who designed
the instrument and the only one at the time who knew of the epidemiological study determining this. At
that meeting when they asked for volunteers, I raised my hand. Since only two other people did, I
thought I am going to be able to discuss this openly in an IEEE committee. I was never called. This
reflects the fact that your selection of the people controlling these committees and the literature that
you review is very partial. It's not for some conspiracy but because of the fact that there is a natural
tendency to assemble similar opinions in a given location. Are you aware that Eleanor Adair, who was
president of SC4 for years and yea, at the time that she was supposed to be a judge on whether non
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thermal effects occur, simultaneously published a paper in the open literature promoting the idea that
we should heat the people rather than houses.
Abrami: Dr. Heroux, is there a question you want to ask?
Heroux: Yes. The review process is very difficult to control and hard to be impartial. I have lived
through these difficulties. When you haven't lived through the process, it's very difficult isn't it? to be
entirely certain that it's entirely impartial? Would you agree?
Swanson: That is way too generic for me to agree.
Abrami: We are hoping to hear from IEEE, so we can form our opinion on that.
Swanson: Personally, if I formed a subcommittee I would not want one of the paper's authors on the
subcommittee. It would be biased.
Wells: can you give us an idea of the wattage of a 5G transmitter and handset?
Swanson: The handsets will be similar to current handsets that operate around a watt. The 5G
transmitters are much smaller than 4G. I ask this question many times and I always get the run around.
The reason is because different sites and different manufacturers have different specs. Roughly
speaking, it's 10-20 watts for the transmitter.
Wells: The function of 5G is communications so how would you relate data rate to intensity and
frequency?
Swanson: Those are good questions. One of the major goals of 5G is to increase data rates. Apparently,
everyone wants to watch their videos on their cellphones. That's why this higher frequency is needed.
The reason these need to be closer together is higher frequencies have trouble penetrating wet air. The
more humid it is, the harder it is to penetrate. So they tend to be closer together, low power, high
frequency.
Wells: The power density in w/ square meter. Is that a parameter that affects data rate?
Swanson: Yes. Actually it is. The stronger the signal, the more data you can push through. Dr.
Chamberlin can probably address this better.
Chamberlin: I wanted to get clarification on the setting of limits. You mention two ways. One is the IEEE
going through publications to find out what other people have established as safe limits. You also
mention there was an animal study where you expose some sort of animal to increasing amounts of
radiation until you saw a change in their behavior. Then, you use a factor of 50 below. Which is it? Do
they use both together?
Swanson: I didn't see a conflict there. Part of what IEEE is doing is looking at animal studies. That's one
of the things they look at. That's what the IARC looked at as well, animal studies. So they are looking for
any effect.
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Abrami: But, isn't it just thermal effects they are looking at?
Swanson: No. they look at everything under the sun. These guys review what scientists look at and the
only thing that actually sees something definitive is the thermal effects.
Chamberlin: But these are short term studies and that's my concern.
Swanson: They vary.
Swanson: I touched on it before and I will talk about this again on a famous NTP study later.
Ricciardi: I just wanted to clarify something on the FCC. I have a couple of documents stamped from the
federal government in 1985. A letter written from the EPA to the FCC and it says they have done the
studies on the heating of tissues and explained to the FCC that they needed to do studies on non
thermal effects because it can heat chronically low over time. Heating of tissues vs non heating of
tissues and only heating was studied when the EPA wanted to go further. The FCC responded by saying
they were taking this out of the hands of the EPA and putting it into the FCC's hands. So we no longer
have a health agency representing us doing those studies. The FCC is not a health agency.
Swanson: That's right. They are not. They have a committee and listen to what they tell them. They
know what they are talking about.
Ricciardi: I think these scientists that have done peer reviewed studies know what they are talking
about. How many peer reviewed studies have you done?
Abrami: we are going to get to the next topic.
Studies:
-Everything I have been telling you is consensus, mainstream science.
-There is no fringe aspect, controversy or conspiracy theories.
-In the internet age, it is possible to find a "respectable" source that says anything, from silly to ludicrous
to dangerous. There is the flat earth society, pizzagate, and we all know of black helicopters coming in
the night to take us all away. It is important to search out consensus views.
-Statements from National Bodies: FCC, FDA, Cancer Institute, Cancer Society (see slide)
-Statements from International Bodies: European Commission, WHO, Health Canada, UK Health
Protection Agency, Swedish Council for Working Life and Social Research, Norwegian Institute for Public
Health, Australian Radiation Protection and Nuclear Safety, (see slide)
- The Swedes and Norwegians say this is safe. They are most sensible people in the world.
-Here is the upshot. The rate of glioma, which is a rare brain tumor, has gone down in the US. The rate
of cellphone use has increased. There is no correlation at all. That is a very powerful statement.
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-There is a difference between doing physics and chemical studies and health and nutritional studies.
Health studies are very difficult to do and have them be reliable. There are conflicting claims. I can't tell
you how many times I have heard eggs are good for you, then they are bad for you then they are good
for you. I don't want to give you the idea that science is useless or these people are dumb. Neither of
these is true. It's just difficult to do studies on humans. Humans are not great subjects.
- Amgen tried to reproduce 53 landmark studies on cancer. They were only able to reproduce six of
them. Bayer Health was only able to reproduce 25% of 67 studies. It's just really difficult to do this stuff.
- Most cited paper of all time in medicine: Dr. John loannidis studying studies. He found that 80% of non-
randomized studies turn out to be wrong. There are many reasons for this: study biases (to make
splashy result), lack of blinding, difficulty working with human or animal subjects, the rarity of effects
being sought (trying to tease up very subtle stuff), the expense of dealing with many test subjects.
Example: NTP study
- One important aspect is the problem of Multiple Comparisons:
- For example, I am going to examine a lot of outcomes from smoking. I have to conduct my experiment
at a certain level of acuity. That's called a P-value. Industry standard for P-value is 5%. The P-value is the
probability of observing the effect seen, or greater, given that the null hypothesis is true. Let's say you
decide that cigarette smoke is not dangerous. That is the null hypothesis. Then you find your rats are
getting lung cancer. Then you would say the probability of rats not getting lung cancer is very low. That
implies that you are seeing something. I am going to assume a much tougher standard in my experiment
with a P-value of 1%. That means that if I have 100 subjects, one of them has to have the outcome.
What happens in the real world with P-values much higher than 1% is that you could have three studies
and they all have outcomes. You could have several different outcomes, not just the one you are
testing. What is then reported, are all of the outcomes when in fact it should be none. For
example...news clip about powerlines causing brain cancer, leukemia, breast cancer, birth defects,
reproductive problems, fatigue, depression, and many others. It's implausible that a single thing causes
many things.
A single exposure causing many outcomes is a sure sign of the multiple comparisons
problem! All of these studies find different things. If they don't start replicating each other,
you shouldn't pay attention to them.
NTP Studv-the claim:
There is clear evidence that RFR causes heart tumors in male rats
There is some evidence that RFR causes brain tumors in male rats
There are problems with the NTP Study: (see slides for detail)
The problem with the NTP study is the Multiple Comparison Effects.
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Heroux theory:
He claims that electric fields from cellphones disrupt proton transfer in water, thereby
"influencing the properties of water and the stability of DNA"
This is a valid scientific question. We should delve into it.
So what is going on here is something called the acid-base reaction which creates H30
molecules. There is about 1 H30 molecule per 10 million H20 molecules. The extra proton
can hop along chains of water molecules. This is called the Grotthuss mechanism. This is
normal and is a chemical reaction. What is the effect of an electric field on chemical
reactions?
There is a study by Boxer at Stanford using fields from 2,000,000 V/cm to 100,000,000 V/cm
to see a reaction. Cellphones max out at lV/cm!
So the physics of it and the chemistry of it say its fine but the magnitude of it says it's not
something to worry about. A cellphone is not sufficient to cause any chemical reactions.
Chamberlin Presentation: I need to correct or point out what he said.
Chamberlin claim: power per unit area becomes alarmingly large.
Significance of l/r2 Power relationship. The implication that having a cellphone in your
sports bra (per slide) is definitely not a good idea, I have a problem with. This is misleading.
There is something called the Frauenhofer distance. The near field and the far field have
different laws.
You need to compare to IEEE localized MPE at 30 Ghz. It's well below that.
I have to say this is not what is actually going to happen. What is actually going to happen is
very complicated. You have to simulate these on computers.
Abrami: We are running out of time. We need time for questions and responses from Dr. Heroux and Dr.
Chamberlin on your remarks. We may take you up on your offer to dial in at a future date. You
mentioned the WHO but the WHO categorized RF as a group 2B carcinogen. Can you tell me how that
works? You said the WHO said there is no problem but they have graded it like lead and thalidomide.
Swanson: Sure I can address. First a technical point. The reason there seem to be these conflicting
statements is it is actually the IARC which is a sub portion of the WHO that made that statement.
Abrami: There are many articles saying WHO.
Swanson: Just because they ascribe it to WHO, it's really IARC a sub portion. They do categorize it like
lead like you said but also things like coffee, sawdust are in that group.
Abrami: Ok . You made your point on that.
Swanson: This committee (IARC) like IEEE only smaller looked at literature and concluded Group 2B. The
standard for that is a very low bar. They made this on two things. The first is a data point on the
interphone study in Europe and a collection of studies from Swedish researcher Hardell. The other
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studies find no effect. I actually wrote to them and asked them, what are you doing??? What they said
was, we are applying the Precautionary Principle.
Abrami: Dr. Sherman would bring that up, the Precautionary Principle.
Swanson: I have written about this. I am fine with the principle. But you can go overboard. It would be
prudent not to go outside, not to get on a plane but I do it and accept the risks associated. One thing
about the data points on the phone study. They self -reported that the numbers are unreliable.
Abrami: So why then is there a legal notice on RF in your cellphone telling you to keep it away from your
body?
Swanson: It's not science. It's precautionary with a flavoring of legalese is what that is.
Abrami: So you are saying there is no science behind that legal notice?
Swanson: Correct. Yes.
Abrami: Let's talk about insurance industry. They recognize wireless radiation as a leading risk and place
exclusions not to cover it. What does the insurance industry know that we don't know?
Swanson: I am not qualified. I don't work in industry and don't talk to them.
Heroux: You make a great point of giving a lot of influence to the concept of ionization vs non ionization.
So if I take a copper atom in space and I want to extract an electron from it, it will take me a fair amount
of energy. Is that right?
Swanson: Yes.
Heroux: We call this the extraction energy from the atom. But if I take a group of copper atoms
together, how much field do I need to move the electrons in them?
Swanson: You don't need much. It's easy.
Heroux: It's called the degenerate fermi gas. The fact that you bring these atoms together changes
considerably the electrical properties of the material. So you agree with me that if you have a material
that has closely packed atoms and the electrons or protons move through the material then a small
electric field can influence the motion of charges.
Swanson: Yes. But so we are not confused. We are talking about metal and of course people are not
metal. There is an analogous effect on people though that I rarely ever mention where cooperative
effects can cause something below the ionization. However, it's extremely rare and I don't feel like I was
lying to you.
Chamberlin: I feel epidemiology is going to play an important part in the decisions of this commission.
Your slide on gliomas vs cellphone usage is pretty convincing and that may not be the issue. But
something that does concern me in the same time frame (1989-2005) is a 32% decline in male sperm
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count. That is major and significant. If you look at the studies that have been done, they are pretty
convincing even exposing people at low levels below .lW/kg. They are getting statistically significant
effects. I am not talking about P-values of .05 but of .001. I am wondering if you are aware of these and
it correlates very strongly to wireless networks and cellphones.
Swanson: There are a lot of studies who are going to see an effect and some are going to be statistically
significant. The real question is, are they reproducible? I don't look through all of these but every time I
do look at one, I see problems and I don't see reproduction every single time. It's just amazing. I thought
the NTP study...wow, this is a going to be a good study. Oh my god...they had problems. This always
happens. The existence of these studies doesn't surprise me and would concern me if they could be
reproduced but they can't. So I have to look at the consensus.
Chamberlin: There were 16 studies where statistics looked good and they all say the same thing. It's
global epidemiology 32% sperm count decrease.
Swanson: Let me address sperm count. I use this in my class. There is a problem with studies. They are
not based on same criteria or same subjects. About four years ago, the Danish Army did a study and
they completely debunked this. There was no effect.
Wells: The Boxer lab slide is that a static field not an RF?
Swanson: Yes. I believe it's a static field.
Ricciardi: You just made a comment that you don't buy into these studies because they aren't
reproduced. Many of these have been including the NTP study which was reproduced twice. What peer
reviewed studies have you done?
Swanson: I have not done animal studies. I do theoretical studies.
Ricciardi: I find it difficult that you can dismiss all these studies showing biological health effects from
cellphone radiation. The international EMF scientist appeal. That's 2,000 reproduced papers of studies
over and over again with 240 scientists studying the fields on biology and health. How do you argue that
health and regulatory agencies state that there is a scientific consensus that cellphones are safe when so
many experts disagree?
Swanson: That's a good question. This thing is called the 5G appeal. These are scientists and doctors in
Europe and North America saying let's slow down on 5G. So how many scientists and doctors are there
in Europe and North America? They have 260 people out of 26,000,000 that have signed. That's not
consensus.
Ricciardi: You misunderstood me. I wasn't talking about a petition. I was talking about 260 scientists
doing studies.
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Abrami: I think he stated his position already. We are short on time. If you could spend some time later
on the phone or webex maybe in a few months. We may have more questions for you and you can
finish. (He ended his presentation just before Nasim and Kim).
Next meeting: Friday, December 13th. 8:30 was agreed upon. We will have one speaker and then talk
through where we want to go next.
V. Meeting Adjourned at 10:35 am.
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
12/13/19
8:30-10:35am
LOB 202
Meeting called to order by Rep Abrami at 8:30 am.
In attendance:(10)
Rep. Patrick Abrami-speaker of the house appointee
Rep. Ken Wells- speaker of the house appointee
Kent Chamberlin-UNH-appointed by the chancellor
Denise Ricciardi-public-appointed by the governor
Michele Roberge-DHHS- Commissioner of DHHS appointee
Dr. Paul Heroux- Professor of Toxicology, McGill University- speaker of the house appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Carol Miller-NH Business & Economic Affairs Dept.
Senator Tom Sherman-president of the senate appointee
Not present: (4)
Frank MacMillan, Jr. MD-NH Medical Society Environmental Medicine
David Juvet-Business and Industry Association
Bethanne Cooley-CTIA, trade association for wireless industry and manufacturers
Brandon Garod-AG designee, Asst. AG Consumer Protection
Agenda:
I. Approval of minutes from 11-21-19:
Minutes were approved.
II. General Discussion:
Abrami: Recommendations will be based on general consensus.
Minority reports can be written by anyone if there is disagreement.
Focus: things that we can do as a state: from as simple as warnings...to ordinances.
There are things going on in our state right now. Dr. Sherman and I are cosponsors in smart
meter bill allowing opt out without having to pay a fee to do so.
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A. The electromagnetic spectrum discussion on terms such as: frequency, wave length, photon,
electron volts, etc. and comparison from radio to Gamma. Frequency is the inverse of wave
length.
B. Energy. Radio waves are the lowest electron volts. Gamma Rays are highest at 1.24MeV.Where is
the break point? None of this is linear. Science says ionizing radiation which expels electrons from
atoms or molecules, doesn't happen until UV rays. However, we have learned that it's actually
doing damage below that. The question is: Is the science still out on damage beyond "heat", which
is the FCC's standard? It seemed from one presentation that they looked at papers beyond heat so
we still want the FCC to talk with us. I will see what we can do.
Sherman: We may be able to inspire them with a nudge from one of our Senators. I would be happy to
do that.
Abrami: Kent, I took this from your presentation!
B. Photons: EMR can be represented by discrete packets of energy called Photons.
1. Increasing transmission power will increase the number of photons (although the energy in each
photon remains constant).
2. The energy in each photon is proportional to the frequency of the transmission.
3. If the photon energy is great enough to detach electrons from atoms and molecules, it is
referred to as ionizing radiation.
4. All the charts that I look at say that happens at UV level.
Wells: When you are ionizing radiation and you remove an electron, you are breaking a chemical
bond but you can break a chemical bond at much lower energies. That's why we can see. This is also
why humans can photo-synthesize vitamin D. They do it at energies much lower than UV.
Woods: Along those lines, we have to remember, and this is important. This is isolated episodes.
However, biological systems work collectively. They diffuse their base energy around parts of a
molecule. There is thermal activity already and sometimes can cause a disruption of a bond without
anything occurring from anything external. We have to remember that these are terms that we are
learning but they are for isolated singular entities. Some electrons are shared by biological systems
and are a very different process. We have to go from a single item to a collective and that's a big
jump. These are some of the experiments that Dr. Heroux is working with that tries to address that
biologic collective entity.
Sherman: One factor Transmission power: If I remember correctly, people in industry were saying
that each tower would be lower in power because there would be so many, is that correct? My
question is: if you increase power, there are more photons but the energy in the photon is
proportional to the frequency. So when you increase frequency to 5G but decrease transmission
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power, you will have fewer photons but they will each be higher energy. What does that mean to us
on the receiving end?
Wells: And the antenna is closer. As 5G single transmitter power density goes down but the number
of them is much larger and they are much closer. It's like little Christmas tree lights around the room
instead of just one bright one.
Sherman: Does that mean that the total amount of exposure will go up?
Wells: Yes.
Sherman: Because of the proximity of the antenna?
Wells: Yes.
Sherman: even though the power is down?
Wells: Yes.
Sherman: The photons will have more potency and you are closer to them.
Wells: They will have larger numbers. The total power of a 5G system has five orders of magnitude
which is 100,000 times more intense than a 4G system!
Abrami: This is something we have to focus on. Kent, do you have something to add to that?
Chamberlin: No. I agree with what's being said.
Heroux: Basically with the beam forming you tend increase the directionality. It's more focused.
With the old systems, they broadcast to a very wide area. So it's true that the new system 5G will
be less power input into the antenna. But the beams will be much more focused and the cellphone
will also have the ability. You are talking about very narrow beams that will be directed to you when
you use the system so that means increased levels of radiation because of this concentration. The
antenna is spending less power because it is not broadcasting everywhere.
Sherman: You just said something that I don't' think I put this together until now. When the
cellphone is 5G capable, is the antenna putting out the same level of radiation?
Heroux: It's going to put out the same type of radiation. They are miniaturized antenna in a chip that
is implanted inside the phone which you will hold so you will direct the beam to wherever it wants.
You will have a more concentrated energy coming from your phone. The radiation pattern will be
fundamentally different.
Sherman: So will it be 5G level radiation be coming out of your phone?
Heroux: Yes.
Abrami: Ken wants to talk about antennas after we get through this.
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C. Specific Absorption Rate: power absorbed by mass of tissue=energy is absorbed by the human
body when exposed to RF/EM field=Watts/kilogram. US cell phone standard is:
1.6Watts/kilogram or less.
D. IEEE/ICNIRP 209 standards are still the same basically what the FCC uses.
Dr. Swanson said that the FCC reviews biological standards as well, not just heat. We really need to
speak with FCC on this.
Chamberlin: I thought my question to Dr. Swanson was pretty direct. I asked him which of the two
approaches setting standards, did they use. One he described was on animal studies exposed to
increasing radiation until their behavior changed, divide that by fifty and you come up with a standard.
That was one way. He also said they relied on publications written but he didn't say which did they use?
He said both but I don't feel like I got my question answered. If it's the behavior in animals, then that is a
short term phenomena and does not address the concerns that we are looking at in this commission
where people are going to be bathed in electromagnetic radiation 24x7. I am really unhappy with where
we are, with finding out that piece of information.
Abrami: Dr. Heroux, I know you went back and forth with him on this and you were involved.
Heroux: Yes. The FCC cannot try to implement a national standard for radiation without claiming it is
taking everything into account. Yet, they don't have biologists on their staff. They have a tradition of
being a spectrum allocating agency which is very important for coordination in the country but they are
not biologists. A better body to ask is the IEEE. Again, the IEEE is heavily influenced by engineering
tradition and I would reinforce the argument of Dr. Woods. All of these things about physics are entirely
true and entirely valid. What what we cannot forget are that biological systems, the fact that we think
and we act are processes. These processes involve manipulations of electrical charges in our body. These
processes fundamentally move electricity around in our body. Those are unstable processes that can be
influenced by vanishingly small amounts of energy. Energy is an immensely valuable concept. But the
complexities of biology have been underestimated by engineers eager to serve the public with
applications and by the FCC eager to serve commerce.
Roberge: I asked Dr. Swanson a question related to the FCC standard as well. I thought I remembered a
conversation about the standard being focused strictly on heating rather than other biological effects.
That was my question with him, to understand are they strictly looking at effects of heat or are they
looking at other biological effects? I am not clear on his answer. I am not clear if the standard evaluated
other studies or just heat. I also thought it has been awhile since they set the standard.
Chamberlin: I would like to interpret what I heard him say. As long as you are below UV Ionizing
radiation, the only factor is heating. There is a question about how much heating you can tolerate. That
has been the industry mantra on radiation exposure for as long as I have been in the field. I believe that
is what they are using as the criteria.
Abrami: That standard hasn't changed much overtime, is my understanding.
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Sherman: I apologize. I could not be here for that meeting. We are talking about human health effects.
This bathing 24x7 is not just on the human environment. It's on the entire environment. Do any of you
know if there are any studies on plants or animals and others exposed to this?
Chamberlin: Yes. There is a study that shows that tree and plant health near cell towers is degraded
considerably. I have a paper that says that.
Ricciardi: There are many studies and a big study on the damage to bees. I did ask Dr. Swanson because
he dismissed the fact that it harms bees. So I handed him the study. It has a huge impact on the
environment.
Abrami: Let's pause on that one. There was a study done on bees using twelve hives. Half of the hives,
they put cellphones in and in all six, they did not come back to the hive. They got confused and you
wonder ...why is that? It must have to do with their navigational system. I always thought they had
sensors that pick up the Earth's magnetic field. All of a sudden we are going to cloud the Earth's natural
magnetic field with man-made different frequencies.
Ricciardi: This one is the exposure of insects to radiofrequency electromagnetic fields from (2-120Ghz),
published in Scientific Reports which is the first study to investigate into how insects including the
Western Honey bee absorb the higher frequencies to be used in 4 and 5G. The simulation showed
increases in absorbed power from 3% to 370% when insects were exposed. This could lead to changes in
insect's behavior, physiology and morphology, over time. I did ask Dr. Swanson, can you confirm that
these frequencies are safe for pollinators and what credentials he had to speak to this? I don't feel my
question was answered at all.
Abrami: This is one I feel we need to follow up on. I found studies on bees at low levels that impacted
the number of queen bees produced by 40% something like that, which is significant. Bees are our
health, food, etc. It's navigation, which can also be biological. I don't want any of us to sound like
alarmists. We want the facts to come out and we want to understand this. But on my list, I think bees
and probably migrating birds as well are important.
Wells: there has been a lot of work on homing pigeons, migrating birds and bees. They also use iron to
determine which orientation the EM field is. The effect is if you hit the frequency that will make that
move, you will make that sense blurry or obliterate the usefulness. There haven't been a lot of studies
determining what those frequencies are. However, if you confound the major pollinators, that puts all of
plant life in jeopardy.
Abrami: yes...that's oxygen and food.
Woods: It's important for us to ferret out in these studies which include 5G because our charge is 5G.
We know that that the photon energy is different. The comment that I heard him say was, how many G's
do you need to study? We need to study 5G. As we go through this, we need to make sure studies
include 5G. The energy is definitely different and we talked about that. Some of the studies do not
include 5G.
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Ricciardi: There is a recent study this year on 5G in France and Netherlands. They meaured the RF from
small cells increased radio emissions from the base stations while decreasing the radio emission from
the user. They found that in the area human sickness is well documented and has increased since it's
been installed. This is all involuntary exposure hanging in front of people's homes. With your phones,
you have the choice to turn off or not own. I have issues about choice and it's a privacy thing, too.
Abrami: The 1/R2 rule. Meaning the further away you are is a physics principle we need to talk about
too.
Issues:
Biological effects of non-ionizing radiation.
We need to make sure these studies are not flawed.
We need to find studies that are replicated.
We need to understand the FCC approach to standard setting. Are biological effects included or
not?
Impact on navigation of bees, birds and other living things such as interference with Earth's
magnetic field used for guidance (non-biological).
Energy level from cell towers and small cells based upon distance. What other factors?
Legislative activity, ordinances and the courts around the country and the world.
RF Communication security. It's scary what's going on in China. Facial recognition, etc. Pretty
soon you won't need any devices.
Insurance Issues: why is it insurance companies won't insure this stuff?
Smart meters on homes.
Precautionary Principle. Dr. Sherman, I know you think this should apply here.
Final report will have recommendations for future legislation or public health warnings based
upon solid facts. We will come to a consensus. Anybody can write a minority report on any part
they disagree with.
Sherman: One thing to consider is looking at all this frequency and power. Are we already beyond the
safe level? Is 4G not safe? Is what's out there now unsafe even before 5G?
Abrami: well, we are not going to take people's cell phones. That's not going to happen. To industry, it
means money. There are not definitive studies on 5G that there are not health effects. I asked Swanson
that. Where are the studies that say 5G is going to be safe? Show us the definitive studies.
Ricciardi: I asked him, are you saying that 4 and 5G are not harmful? He said yes. To Dr. Sherman's
comment about already being dangerous, your cell phones already have warnings buried in your phone
to not put them close to your head or ear. People really don't know that. It is dangerous. We aren't
going to get rid of phones. One solution we may want to consider a right to know law at the point of sale
because people will still buy them but they may use them more carefully, just like cigarettes are still sold
with a warning.
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Sherman: That's my point. If this commission finds out that maybe we have crossed that threshold into
what may be dangerous, I think transparency in sharing that knowledge is important. Also with 5G, one
of the concerns is everyone will be exposed whether you own a phone or not. Are we already at that
point with 4g whether you own a phone or not and is that exposure potentially toxic? That is something
where we can at least raise the question.
Ricciardi: Very good.
Heroux: I have a number of comments. I have been in this business for a long time and I want to
emphasize the importance of what has happening here and the influence that you are going to have.
You are not the FCC. You are not the IEEE. You are not the Chinese government. But, you are a public
body that has NO conflict of interest. You can claim that engineers have a conflict of interest because
they are pushing products. You can claim that the FCC has a conflict of interest. This body apparently has
none. It is looking at data and reality. The discussions that we are having today are incredibly rare. They
are usually held in private between individuals. Although New Hampshire has limited power
implementing laws and regulation, what you will recommend, will be heard. That can have tremendous
influence on the future. I see that responsibility on the shoulders of this committee, as huge....
planet wide, in my opinion. First point!
The frequency range of 5G can be very wide because industry is very flexible in what it does. Some
frequencies used in 5G are lower than some used in current systems. Some that have been allocated are
much higher. As Tom Wheeler would say, if someone tells you that they know what 5G is, run the other
way because not even industry, itself knows. So, we are forced to evaluate electromagnetic radiation
as a whole.
About scientific studies: All scientific studies are flawed. You would have to have unlimited money and
time to produce one that is not. The weakness of the overall process is that because you can criticize
ANY study, a committee that has a philosophy, can get rid of studies it doesn't like. This is a reality that
is inescapable. The philosophical attitude of the people assessing science is absolutely tantamount.
Another problem is that the reproducibility of experiments that you are familiar with in engineering or in
science is higher than what you have in biology. This is because biological objects are inherently
extremely variable. So when you impose the same standards of reproducibility on biology to those of
engineering or science, it's extremely unproductive, in my opinion.
The physicists have to bear the guilt of the atomic bomb. I am sorry to say this but electrical engineering
will have to bear the responsibility of 5G. In a sense, it's electrical engineering's atomic bomb. Probably
the people who can attenuate and manage this are here.
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III.Ken Wells: Presentation on 5G malign applications:
Culture of Safety:
It has been said in this room, that little research has been published on the hazard or the safety of these
frequencies. I have been involved in hobby auto racing as a driver, pit crew and safety corner worker. I
am used to cooperative safety culture that asks, what is the worst thing that could happen? Then you
work together to make sure that is very unlikely or impossible. I don't see that 5g is progressing that
way. I think we would be wise to take that same approach with high frequency radio frequency.
Is it possible for radio frequency to cause harm?
There is an RF weapon that's called "active denial system: that uses 3.25mm or 95 Ghz band of 5G. In
testing, it was able to create a burning sensation in the people it was aimed at in a tenth of a second. It
was able to create 1st and 2nd degree burns in less than a second. In one case a subject was hospitalized
for two days. So, yes RF radiation can cause harm. From this military experiment, we have evidence that
RF can cause pain and injury. I would like to explore what could happen if instead of a cooperative
safety culture that I spoke about, that a maligned player either foreign or domestic wanted to pursue a
nefarious use of this RF against a civilian population. In theory, could a 5G network of small cells, IOT
and devices be weaponized? I think so. This is the worst thing that can happen scenario that we must
render impossible.
Physical descriptors of RF. There are three major ones are used universally.
1. Photonic Energy that you can categorize in terms of frequency or wavelength.
2. The intensity of radiation: The brightness if you will. It expresses how much energy strikes an area in a
given time.
3. Duration of exposure. The IEEE standard 95.12019 is substantial and you should look in to that
document. The research in that describes a quantity called fluence which describes field strength times
the time you are exposed to it. It implies that pulses of RF should be separated by a few tens of seconds
to avoid damage. That is not currently incorporated in the standard but something I think we need to
pay attention to.
Absorption: waves transmit energy from place to place. EMR interaction with matter is frequency
dependent. It has three ways it shows that dependency. The first one is heating. Second, is quantum
effects with sharp bands particular frequencies that are strongly absorbed by particular atoms and
molecules. That is not so well studied.
Third, you have anisotropic effects. Those are not uniform in all directions. Those include things like
polarized emission and absorption, tunneling, and we don't really understand the biological role very
well. We know they are very important. We know that we can point to these in chlorophyll and DNA.
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Membrane bound biological processes like photosynthesis, oxidative phosphorylation (respiration),
reproductive fertilization and neurological processes are all things where we think these electronic
reactions are happening. There is even some theory by Roger Penrose and others doing research that
the human brain might even enlist what is not well understood called quantum entanglement. There
could be a role of chaos theory. As Dr. Herox said, very small electrical fields are involved in these
biological effects.
On page three, I took measurements from a cell tower. I happened to be hiking and got some readings
of a 4G Verizon tower. Dr. Swanson told us that the amount of power was hard to pin down. The
manufacturer said it was only about ten or twenty watts. I am not sure what we should believe. Since
there is so much variation on it, we need to be able to put a large error safety bar on these values. I am
most concerned about the layout of these small cell antennas which resemble a phased array.
A phased array is the way that modern radar picks its direction. Remember that old ones had oscillating
antennas. A phased array nothing moves but you change the characteristics of the antenna in order to
steer the beam. The hardware layout for small cell 5g antenna areas meets the requirements for a
phased array about a hundred meters apart over an entire city. Once this antenna is built, a maligned
operator using software could upload to the array to alter its function from the benign communications
function to a high powered steerable array either to disrupt communications or to actually be used like
this military device. Foster et al say in IEEE 95.1 "The use of multiple steerable beams from 5G base
stations will introduce new issues for compliance assessment for future RF exposure risk" which I think is
quite an understatement.
I don't think that we or the FCC, can effectively regulate either operating frequencies or power levels of
such an array because today's equipment hardware characteristics are completely transformed by
software. You need only to consider the VW "Dieselgate" cheat to see how software can be used to
hide or reveal deeply embedded nefarious capabilities of hardware. Since regulation of wave
parameters can't be done with this array, the phased array deployment has to be blocked by controlling
what kind of physical antenna can be built.
We could continue on our current path of allowing maligned foreign entities to sell us 5G equipment or
even components that go inside these things. How hard would it be for a remote operator over the
internet, to toggle the equipment from its benign communications into another role? This role may
operate on another frequency for espionage and surveillance, or to increase the power as a weapon and
deny us our Constitutional right for assembly. It would be easy if that maligned capability was built into
the hardware that we purchase as a Trojan horse. There is once piece of good news in this. The
atmosphere attenuates the signal fairly strongly.
There is a spectrum on the last page. In the mm band, there are really only a few windows. The military
application picks the biggest of the three peaks between 1-10 mm at 3.75mm and those are also the
same bands you want to use for communications. The Air Force began development of" Active Denial
System" in 2000. It used 3.25mm (95Ghz) RF as a crowd-control device whose range was "greater than
conventional small arms" (3km). In testing, it could cause "an instantaneous burning sensation" in .1 sec
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exposure, along with first and second degree blistering burns on human subjects for exposures of less
than 10 sees. One case required a two day hospitalization. It was tested as a 30MW mobile truck-
mounted "area denial" system in Afghanistan in 2007. Could a malign player (foreign or domestic cyber-
attacker) pursue a nefarious use of RFR against our civilian population? All of this suggests a couple of
avenues we could consider.
Prevent the rollout of antenna array that can be used as a phased array. Transmitters should be built
using MIL-SPEC US component suppliers, with the same degree of security and oversight used in
other weapons systems. Do any citizens in the US ever worry about their constitutional rights, or
oppression at the hands of their own government?
Abrami: We need to end here. We are going to have to follow up on your major points.
IV: Tim Schoechle PhD: National Institute for Science. Law and Public Policy presentation:
Schoechle: Computer and communications engineer for 45 years and on the faculty of the University
of Colorado for a number of years prior. I'm speaking now for the National Institute of Science, Law
and Public Policy think tank in Washington that writes on health and safety issues as well as
telecommunications and energy issues.
The purpose of this paper is to give an overview of current technology and both the technology and
the policy issues in telecommunication including internet, wired and wireless.
1934 the Telecom Act established the FCC which regulated broadcast radio and telephone service.
1986 The Bell Monopoly (AT&T) was broken up.
1996 Telecom Act revised the 1934 Act. Wired Communications were covered under Title II
(common carrier), leaving the wireless and cable essentially unregulated.
1990-2010 Wireless rolled out 2nd and 3rd generation wireless.
What developed out of that was the reincarnation of the Bell Monopoly that began around 2000
which resulted in today's duopoly of Verizon and AT&T. This is not the Bell AT&T.
A major point here is: the massive cost subsidization of wireless by diversion of fiber to serving
cellular network. One notable point is Verizon's abandonment of FIOS that it was marketing in 2000.
Abrami: You say there are two major players but what about T-Mobile?
Schoechle: Cable is the third player. It makes it more complicated because it's a wired service and
wireless. It's really a trio-poly. The rest is much smaller.
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Abrami: Talk about the flow of money and the diversion of subsidization. Are you talking about the
charge on landlines that were supposed to be used for optical fiber infrastructure?
Schoechle: The "Book of Broken Promises" is a 600 page book that describes in detail how this
diversion took place. The obligation was to upgrade wired infrastructure from the charges that
ratepayer money for on the telephone bill. That money was charged against the wired and used for
the wireless. It amounts to about 500 billion dollars. Basically, it made wireless look a lot more
profitable than it would be otherwise.
The drivers: the need to cell more phones and now its 5G. It's about selling equipment. There has
been a slowing on the sale of cellphones. The industry philosophy is planned obsolescence.
The new subsidy is YOUR public rights of way. It's a preemption of local property rights and rights of
way that give telecom a grant by right to public property. Over twenty states have adopted
legislation to take away the rights of localities which was inspired by if not written by the American
Legislative Exchange Council (ALEC). It was written to take away control of states and localities of
deciding on this equipment.
The FCC is a captured agency and presently chaired by a Verizon attorney, Chairman Agit Pai. It's
not surprising that it serves their purpose.
Surveillance Capitalism: There has been a transformation in the past twenty years that began in
2000 to a surveillance business model. This is really important if you want to understand the
telecommunications industry and particularly the IT industry.
It has gone from selling products and services to the new model of trading in personal data. The tail
is wagging the dog. The data is more important than what the equipment does. This was developed
by Google and refined in 2010. It has been adopted by Facebook, Microsoft, Amazon and now
Verizon, AT&T and the entire IT industry. There is a book called "The Age of Surveillance Capitalism"
by Shoshanna Zuboff of Harvard University. She has written a monumental piece that details how
this occurred and the social implications. You have to understand this to understand why
information technology is going where it is today. It is selling data, selling behavior and advertising
primarily. It is also selling behavior modification, which has political implications as we know. Selling
control of people is where this is headed.
Wireless devices and networks are complex and proprietary. I am going to compare wired and
wireless. The wireless is unregulated. It has progressed rapidly. It is extremely complex and changes
all the time. Wired networks that are copper or fiber are simple stable technologies and are open.
What you have is essentially a generation of wireless technology which is designed primarily to
gather data about you. Wired networks particularly optical fiber, are much more secure than
wireless.
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Some of the risks of the wireless industry:
- Loss of community rights, property rights and rights of way for private corporate gain.
-A loss of revenues that come out of that is essentially a forced subsidization of your community to
wireless by giving them stuff they would have to pay for.
-If 5G was not subsidized through this form, it would not be feasible.
-The loss of community environmental regulation is a critical factor. There are a lot of environmental
implications to this technology.
-Risk to personal privacy and corporate and government surveillance.
-Risk to public health and safety. Vast literature on this suppressed by industry or ignored by federal
regulators.
-Damage to the environment birds, bees, insects, plants, animals, tree, etc. particularly mm waves.
-The FCC limits are obsolete and they have no health expertise and have swept this under the rug.
What can states do?
Let's get fiber to everybody. Fiber should be the first priority. Fiber is a basic utility like sewer,
water, roads, etc. Wireless is an "adjunct service". The fiber should be owned and controlled by
the municipality. This should not be privatized. Fiber access is superior to wireless in every
respect except mobility. The fed has no policy on this and local power companies and rural
electric companies are stringing fiber optic. It offers speed, stability and better privacy, safety in
weather events, reliability and it's cheaper.
Internet access is a necessity to modern life. You can't operate government today without the
people having access to the internet.
Cellular wireless is an energy hog as well.
Community fiber would reduce the need for cellular wireless.
Enable community fiber.
Integration of distributed energy. Fiber will be needed for solar/storage and the future of the
electric grid.
Enable local control of cellular wireless facilities: Initiative in Colorado is repealing ALEX laws
passed in 2017 which preempts local legislation.
California just enacted CCPA (California Consumer Privacy Act). Take a look at this.
Health and safety studies of EMF need to be supported.
Enforcement of Environmental Protection laws. The appellate court just overturned part of the
FCC order on the basis of its failure to enforce NEPA, the Environmental Protection Act.
Antitrust enforcement and divestiture. The last thing we should do is allow merger between T-
Mobile and Sprint. Fifteen AG's from states have filed a separate lawsuit challenging this
merger.
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Read /'The Book of Broken Promises" and do something about it. There is a case proceeding in
the 10th district in Washington, DC in January on this investigation.
Support the Green New Deal: 1/ a distributive solar micro grid and 2/fiber smart grid and optical
fiber nationwide.
FCC has abdicated its responsibility to public health and safety as have other regulatory agencies.
FAA has failed to regulate creating a debacle which could sink Boeing.
California PUC has failed to regulate PG&E, one of the country's largest utilities and is in bankruptcy
largely due to the failure of regulators.
Another example of regulatory capture and the revolving door is now we have the FCC's failure to
investigate cellphone radiation, safety and their obsolete radiation limits which flies in the face of the
NIH Toxicology Program study that shows cellphones can cause cancer.
Abrami: You have reinforced many of the things we have been talking about in this commission. What
do you know about what is going on in China and their 5G rollout?
Schoechle: I submitted a paper," What is 5g and why do we care?" In it, it refers to China. It's a financial
driver in China and part of a surveillance state. It takes surveillance capitalism and the capitalists are the
government.
Abrami: So we should be concerned about the chips and things coming from China?
Schoechle: It's not just China. Korea is also a major manufacturer. They have become famous for LG, the
television that are watches you. Those televisions are sending information to Google and Facebook and
who knows where else on the internet. You don't even know that is happening.
Sherman: Is there somebody in the legislature in Colorado that you have been working with who has
been translating some of the work you have been doing into legislation or bills?
Schoechle: The majority leader is on board with this. I wrote a 20 page report named "Reclaiming local
control over cellular wireless facilities". I just sat down with a member of the House and went over that
in great detail. We are looking for a sponsor for that bill. We are in recess right now. I can give you more
detail on that if you want to follow up with me.
Sherman: That would be great. I am chair of Senate Health and Human Services. We try to not reinvent
the wheel. If there is legislation enacted or in process that seems to be working through the system in
Colorado that may be appropriate here in New Hampshire, we would like to take a look at that.
Schoechle: If you send me your contact information, I will try to facilitate that. The big focus in Colorado
last session was major changes in energy policy. Electricity, oil and gas have been a major political
debate in Colorado and we have made progress on that. Telecommunications will be in our next session.
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Heroux: In your report in section 3.3.3 pg. 34, you say most of these sources never turn off and cannot
be turned off. I believe you say this in context of IOT. Would you agree that the hardware switch on
these devices would allow a person to eliminate radiation and eliminate transmission of information if
the user wants to? Do you think it's feasible to implement or to legislate for such a device that would
restore an individual's right to privacy and manage his radiation exposure?
Schoechle: That is a good question. The trend in the consumer electronics industry is to develop
products that don't turn off. They look like they turn off and you think you turned it off but they are still
on. This is a problem from an energy standpoint and from a data standpoint. I think what you are
suggesting would be a good idea and we would have to look at how policy would influence the
consumer electronics industry.
Heroux: You could design it that the switch is only disabling the transmission. You make it unable to
send out data and you eliminate the radiation. You could also say that the fact that it is off, you do not
disable the other functions of the device. It is a matter of engineering. We all depend on engineering.
This type of switch could go a long way toward protecting privacy and making it possible for Electro-
sensitive people to survive. How can this be imposed? Do we need IEEE to promote this? Do we need
the Chinese government to promote this? How can this be achieved? You know industry well. If the goal
is to restore that kind of power to the individual, what is the path to achieving this?
Schoechle: That is a wonderful question. I will have to think about that. It's not so simple. Particularly,
with cloud data, the whole business model on these products is capturing that data. You are asking to
change the business model for a whole industry. I agree with you completely. We will have to think
that through very carefully but I think there is a path. Maybe the IEEE, but an organization called
Consumer Technology Association (CTA) is more likely. I am on the cyber security committee and that
would be a good focus for that. We are writing a new standard for consumer products. CTA2088. We
also have an international committee that works on this. There is a concept of residential gateway for
this as well. We could address it through standards and at least make that an option that people could
buy.
Heroux: Since realizing that you are the best person probably anywhere to do this, I assume that we can
count on your cooperation to further this idea perhaps in cooperation with the Committee in some form
or other.
Schoechle: Absolutely yes!
Miller: I would like to explore your statement on enabling community fiber. You also said community
fiber would reduce the need for cellular wireless. I am not sure I agree with that statement since we like
to be mobile and fiber is not mobile. The other thing is why do you say community fiber owned and
operated by municipalities?
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Schoechle: Well, because for the municipality, there is a political process for governing it. If it is
provided by a Century Link or Verizon, even if it's fiber, you don't have any control or assurances of net
neutrality or if it will be equitably distributed in the community. You don't have that control. It's not
something that should be privately controlled.
Miller: You go on to state that cooperative electric utility is a better model in some ways for smart grid
which would be enabling fiber to the premise. That is not community controlled either. That's controlled
by members through charter but not a community controlled network. So I am not sure what you
mean, totally controlled by municipality? Or partnered with an electric coop to disperse fiber? Can you
elaborate on that?
Schoechle: My first choice is municipal electricity and municipal fiber together. I consider the perfect
model as Longmont, Colorado. They have done both of those. They have the most advanced fiber
system in the country. That is preferred. But America is very diverse country. The rural electric
associations are called coops. It is possible to go through the coops in a democratic way unlike a private
corporation. They are like a Frankenstein monster, out of control and basically ungovernable.
We are looking at a new technology standard Ethernet cable Cat5 or Cat6 copper wire. This can carry
data over short distances at the same speed as fiber. This can also deliver DC power. You can plug
phones, computers to a USB connector throughout your home so you don't even have wireless in your
home. That is coming... a USB connector standard USB3 type C something like that. This will be the new
standard because this is the new internal wiring in cars will be gigabit ethernet.
Miller: This doesn't address mobile access. People want to be mobile.
Schoechle: I am saying it will lessen the dependence on mobile. Right now, if Verizon had their way, you
would only have mobile access whether you want to be mobile or not. If you have fiber, you will have
faster better service and when you are mobile, you have a mobile phone. I have a mobile phone and it's
an old flip phone. If I want to do data, I use my laptop plugged in at home. I am not going to do that in a
car driving around. People need the choice.
Sherman: I am not sure people would be quite so wedded to their phones if they were aware of the
health impacts to themselves and the environment. If you were to take that new USB technology, would
you be able to go to airplane mode on your phone and still have complete access to your phone? Would
an on/off switch shut down antenna? Like an airplane mode for television or CPAP machine which is
now wireless, as well? Would the concept of being able to shut down on all devices be what we are
talking about?
Schoechle: Yes. It's analogous to airplane mode. Airplane mode is to prevent radiation for interference
with aircraft systems. Right now many cell phones have a feature called wifi calling so you are not using
cellular calling but using fiber access or whatever so you are not using cellular wireless network. Of
course the cellular operators don't like that but all the phones now work that way. You could plug in
your phone when you get in the house and turn off your cellular antenna and still have phone access.
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Ricciardi: The town that I live in is entertaining fiber optics. We would have to put it on our ballot for the
people to vote. I have two questions: I have heard different things. If we put fiber optic in, would that
make it easier for 5G to come to our area? Would that give them a segway to attaching themselves?
Schoechle: That is a very good question. Many of my colleagues and I have arguments about this. Some
say you are just going to enable 5G sites by putting in fiber. Well, that's why it needs to be
democratically controlled by the people in the community.
Ricciardi: But my understanding is that the FCC can just allow them to come and put the 5G in. You
won't have a say as a municipality. If that is the case, we would just be making it easier for them.
Schoechle: They can't make you use their fiber. The FCC ruling is just about siting, not the use of fiber.
Ricciardi: Oh, so it could help you keep 5G away.
Schoechle: The issue is not whether there will be fiber or not. The issue is who is going to own it and
control it. That's the issue. If you put it in, you control it. If Verizon puts it in, they decide how it's used.
That doesn't stop them from putting in 5G but they have to put in their own. They don't get their
subsidy off of us.
Ricciardi: In the state of New Hampshire, our utilities are in the public right of way. There is a NH law
that I have looked into. I have been looking into an ordinance for this. That is a factor in our state. It is a
little difficult to overcome.
Schoechle: Yes. A lot of these laws were written that way and need to be revised. That's unfortunate.
The goal should be Local Control.
Heroux: I have a comment about mobility. We need mobility. The cellphone industry has paid little
attention to reducing exposure of users. There are some people who occupationally need to use the
cellphone. They don't even have a choice. In other words, I recognize the right of people to accept EMR
exposure if they want. However, there are people who do not have a choice to use the devices that are
on the market. It is possible to reduce the exposure of a person by a factor of about a hundred if you
make the proper engineering efforts to do so. You can have the exactly the same services you have now
but your risk would be reduced a hundred fold by design of the antenna and software adjustments to
the phone. There will be no loss of functionality however, an enormous loss of biological impact.
Industry in the past has not done it. It needs to be told.
Schoechle: I agree completely. That is a very good point.
Abrami: Here's the issue. 5G is a concept that means something different to every one of the phone
companies. They are all developing their own version of 5G which makes it hard to track. One thing for
this commission will be a Health issue potentially and definitely a political issue is the deployment of
these small cells at telephone pole heights in front of people's homes. That becomes a real intrusion.
Regardless of what the science says, many people will say, I don't want that. We already know the
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battles in our communities to put in a regular cellphone tower somewhere in the town, let alone a small
cell in front of a home.
What is your view on that? We have engineers, doctors and toxicologists on this panel so we are having
interesting conversations that really should be happening at the Federal level. What is going on in
Colorado? Are there deployments of these small cell towers?
Schoechle: Well, yes. Verizon is rolling out in Denver. The issue has not come to Boulder yet. But the
issue is what they have done with these ALEC laws and the FCC. They have lawyers that go around and
tell city councils and county commissioners... oh.... you need to change your codes now to be in
compliance with state and federal regulations. Our response is, let's change those. Of course that is a
bigger hill to climb. People are getting up in arms because they are seeing the permitting of these small
cells. Just the permitting has raised concern and communities are mobilizing around here. There are
over a hundred cities around the country that have bonded together to sue the FCC. They have had
some success. In November, there was a ruling in the 10th district. Industry wants to do this because 5G
will need a shorter range. People don't realize that 4G and 5G will be bonded together. You cannot
separate them. You will have both 4G and 5G. The new small cell sites being put in are 4G which will
become 5G as well when they figure out what that's going to be. The technical standards aren't finished,
the spectrum isn't allocated. 5G is an add- on to 4G which allows faster data transfer. It does not
support voice communication. It doesn't support a lot of the things that your present cellular supports.
They talk about 5G for autonomous vehicles. I think that is a bunch of hype. There are safety issues that
have not been addressed at all. It's marketing hype. The term 5G is a marketing term. It is not a
technical term.
Sherman: My nephew is an engineer on the autonomous car, Waymo .They have no dependence on the
internet. It is completely autonomous. So it's not just hype. It's a lie.
Schoechle: Right.
Abrami: Thank you for your time.
Schoechle: I would like to connect with the commenters. Thank you. I like the idea of technical standard
approach to devices.
V. Next meeting: January 10 8:30-10:30 Devra Davis and Theodora Scarato
We are now going into Legislative Session. We need to do meetings on Monday or Friday. What about
professors? Friday seems to work best.
VI. Meeting Adjourned at 10:35 am.
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
1/10/2020
8:30-ll:00am:
LOB 308
Meeting called to order by Rep Abrami at 8:30 am.
In attendance:(12)
Rep. Patrick Abrami-speaker of the house appointee
Rep. Ken Wells- speaker of the house appointee
Kent Chamberlin-UNH-appointed by the chancellor
Denise Ricciardi-public-appointed by the governor
Michele Roberge-DHHS- Commissioner of DHHS appointee
Dr. Paul Heroux- Professor of Toxicology, McGill University- speaker of the house appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Carol Miller-NH Business & Economic Affairs Dept.
Senator Tom Sherman-president of the senate appointee
Bethanne Cooley-CTIA, trade association for wireless industry and manufacturers
Brandon Garod-AG designee, Asst. AG Consumer Protection
Not present: (2)
Frank MacMillan, Jr. MD-NH Medical Society Environmental Medicine
David Juvet-Business and Industry Association
Agenda:
I. Approval of minutes from 12-13-19:
Minutes were approved. Unfortunately, the minutes were posted on our website prior to
approval. We will make sure that does not happen again.
Abrami: Discussion about subcommittees and members meeting outside of the regular
meetings. Small groups are allowed under the rule is 50%+l. If groups are larger, we will have
to develop subcommittees.
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II: Theodora Scarato. Executive Director Environmental Health Trust:
Environmental Health Trust is a scientific think tank. We coordinate with scientists all over the world on
issues such as wireless, climate change and environmental health issues. Dr. Davis has long worked on
climate change, toxic chemicals, environmental possible causes of breast cancer and toxins in the
environment. I have a lot in a power point. I hope it will be useful for you. I will not get to everything in
here as my focus will be on policy.
At EHT, we publish research and brief policy makers as well as develop educational campaigns for
people and for parents on how do you reduce exposure. I have a lot of materials. The most recent paper
I published was with Frank Clegg, former Microsoft Canada President. There are links to all of this and
more in the power point and it's all hyperlinked.
The Babysafe Project: There is a campaign that we have co developed with Grassroots Environmental
Education is called the Baby Safe Project. This campaign has been signed on to by over 240 doctors and
scientists and educators, to reduce exposure to pregnant women and developing babies because of
research showing brain impacts. Dr. Hugh Taylor, who presented at the press conference for this
campaign talked about his research showing damaged memory and increased hyperactivity after
cellphone radiation exposure to pregnant mice. There is other research that Dr. Davis will go into as well
showing impact on brain cells to what would be legal exposure limits of radiation.
Many pregnant women take the phone and rest it on the abdomen because they don't know. People
don't know to keep the device away from the abdomen or use safer technology and you won't get that
exposure. I have a quote from Dr. Taylor, chief of Obstetrics at Yale. That might be someone that you
would be interested in having to talk about his research. He has a quote:" I am deeply concerned about
growing exposure to cellphones." There is a video online at the BabySafe Project where you can watch
him talking about this with recommendations on how to reduce exposure.
Wireless and energy consumption: Health and environmental effects of 5G are not just about the
radiation, it's also the energy consumption from all of these devices and all of the additional small cells.
There is a French climate think tank report (The Shift Project) which talks about the explosion of energy
use. Even though there are energy efficiency gains, they are not keeping up with the amount of devices
and these new installations, which create an increase in energy use. They document that as well as the
environmental effects and every part of the life cycle of devices. For example: You have conflict
minerals, e-waste from disposing devices and energy use of the manufacturers. All of these are polluting
our environment. This report has a short two pager which is useful for the highlights.
Insurance coverage: I know that one of the questions of the commission is: why don't insurance
companies cover damages from electro- magnetic field exposure? As you probably know, in the annual
reports of almost all of telecom companies are statements to the shareholders such as " 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". "We currently do not maintain any significant insurance with respect to
these matters."
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We have a page on our website linking to all the annual reports with these statements. Why are
shareholders being warned of potential risks in the future and not people? I got involved almost a
decade ago because I am a parent. I did not believe this at all. I knew enough that I had to take some
time to dig in and here I am.
We have list on our website that we try to have a repository with compendiums of information that has
all the white papers of industry where the insurance companies rate EMF as a high emerging risk. The
SwissRE report just came out rated 5G mobile networks: the impact is high. The quote in this report with
regard to health effects is: "As the biological effects of EMF in general and 5G in particular are still being
debated, potential claims for health impairments my come with a long latency." I think that's most
people's concerns here.
The Harvard Center for Ethics Report: What's going on here? If there are all these studies showing
adverse effects, why isn't there the follow up that we would all expect from an exposure this great? In
this report, the investigative journalist talks about money that has gone to Congress and the way that
the FCC has former telecom executives as commissioners and also when you retire from the FCC, many
commissioners end up working for the industry. This is all documented and he also talks about the
correlation to Big Tobacco. "It is these hardball tactics that recall 20th century Big Tobacco tactics." This
report is from 2015 and I really want them to update it because so much has happened since in terms of
this issue with the revolving door. The title of the report is: How the Federal Communications
Commission Is Dominated by the Industries It Presumably Regulates by Norm Alster. There is also
published research that has found industry involvement affecting the quality of the results, the design of
the studies, sponsorship and publication bias just like there would be in most industries. The consulting
firms of Big Tobacco are now working with Big Tech. There is a report out that we are looking at a 12.3
trillion dollar market.
Revolving Door: This is a slide that I made showing the Former FCC Chair, Tom Wheeler was the former
head of CTIA, Ajit Pai, the current FCC Chair was formerly a Verizon counsel, Brendan Carr, FCC
Commissioner who was a former lawyer for Wiley Rein LLPP who represented the Wireless Industry in
suing San Francisco for their Cell Phone Right to Know Ordinance. Bruce Romano, Asst. Legal Chief in the
FCC's Office of Engineering and Tech went to the law firm of Wiley Rein representing the CTIA.
Short Timeline of US Regulatory Action on RF and Human Health: This is probably one of the most
important slides that I have. You don't have it in your packet.
Abrami: please give us your non PDF versions of your files that we can click hyperlinks.
Scarato: I will do that. This is just a short timeline. It does not have everything in it.
In the 1970s-1990s, the EPA had a robust research program tasked with developing RF safety limits.
1996: the EPA was defunded and told that they could not work on EMF as they were set to release their
phase one of safety limits which was on heating effects. The second phase was supposed to be on non-
thermal.
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1996 FCC adopted RFR exposure limits based largely on limits developed by industry and military
connected groups (ANSI/IEEE C95.1-1992 and NCRP's 1986 Report).
We adopted those limits without our experts setting what is a safe limit? What is a safe limit for long
term? What is a safe limit for children and pregnant women? Later in 2008, the National Academy of
Sciences did a report documenting gaps in our understanding of the issue. What is going to be the
impact of children exposed for a lifetime? That is my number one question. My background is as a social
worker and I directed programs in schools. I worked with a lot of kids who were born of crack addicted
parents. I know the differences between the kids. You have trauma, brain impacts from prenatal
exposure. Kids who have been adopted and we know their history. That's what really brought me into
this too. Knowing the challenges of my clients and knowing the impact that brain damage can have.
2001: GAO report and letters from experts in government saying there were problems with these limits.
Those were not responded to. In 2008/2009, there were Congressional hearings on cell phone radiation.
2012: GAO Report: " FCC cannot ensure it is using a limit that reflects the latest research on RF energy
exposure." Reassess RF limits and update phone compliance testing requirements.
2012: H.R. 6358 The Cell Phone Right to Know Act was proposed at the federal level and not passed.
When I found out cell phones emitted non ionizing radiation, I thought what?? Why didn't I know that?
My kids spent time on the phone because long distance was free and I spent hours on the phone talking
to my girlfriends. I just wish I had known and I could have made that decision.
2013: FCC open inquiry proceedings (in response to GAO 2012 report) We have links to the docket and
the submissions, doctors, scientists, industry, cities, lawyers.
2018: GAO listed status of the 2012 report as "closed/not implemented". But just recently, the FCC
issued an item closing the inquiry, saying there is not science that says we need to update our limits.
They based that on the FDA's opinion. There is a three page letter in the docket. You can see all of
these.
Abrami: Just so you know Theodora, one of our goals is to try to get someone from the FCC to actually
talk to us. We are a state. We are not the federal government. But I am not going to give up trying to
get someone from FCC to answer our questions.
Scarato: I would hope the FCC as well as the FDA would answer your questions. We have questions.
Scientists have been writing letters. I have a slide on letters that have not been responded to. I believe
the American people need to have answers to these questions. What the FCC did on Dec 4, 2019 was to
say there is no need to update the limits, "that we decline to revisit our RF exposure policy as it pertains
to children". "Similarly, the FDA maintains that the scientific evidence does not show a danger to any
users of cell phones from RF exposure, including children and teenagers" even though there was a
submission in the docket on damaged brain cells.
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There were submissions that said the testing of the phones should require zero spacing. They don't
think that they need to. They think the information in devices is adequate to inform people of these
issues. I think I am pretty smart and I did not know that information was there. I have a Samsung
Android and I cannot find my SAR testing easily at all. It is not in my phone. It is not listed online. The
only way is to go to the FCC and type in your model and make to figure it out. That is not adequate. I
would expect more of our government.
Gray: Mr. Chairman. I do object to some of this testimony. Let me explain why. A lot of the testimony
that we are getting right now is: somebody wrote a letter and we didn't get an answer. Somebody else
wrote a letter and we didn't get an answer. I have sat through many hearings on vaccines and listened
to this electromagnetic radiation all the way from when I was a teenager and we were worried about
the power lines. I would love to hear the data that you have got. The experts from the FCC have said
there is no scientific data out there. That's what I am interested in, the scientific data that deals with 5G,
because that is the crux of this committee. If there is data about the scientific problems with 5g then I
want to hear that but I don't want to hear that I wrote a letter and I didn't get an answer.
Abrami: Well, I don't disagree with you. We are trying to get at the essence of this. I want to talk to the
FCC directly and the IEEE. We are still trying to get at the facts. We have talked a lot about the science
on the commission probably more than any other state legislature. I am hearing conflicting things about
the FCC. Did they look at biological effects or not? I want to know. It would help us as a commission to
understand. As the Chair, I am not releasing a report if the FCC says X and we say Y without data to base
that on. People will ask, just like you did. What did you base that on? The FCC says its fine. That's why
we have to keep digging.
Sherman: I want to remind the commission that this is our guest. We don't usually shut down a guest
because we don't like what they are saying. I would ask that we let her speak as invited and you can be
your own filter for what she has to say rather than objecting to her testimony.
Woods: I understand the Senator's concern. But by the same token, even if we have scientific data, we
need to know what context or social context this has been interpreted and conveyed. That is just as
important to me. If we find that the FCC got a letter and didn't respond and we know there is a study
about that, then that non response is important. I understand that data is important but the context and
how it is conveyed is also important.
Abrami: The other thing Theodora, you are doing a great job laying this out. This commission is deep
into the weeds on this. We don't know all of what you are saying here. We are filling in gaps so continue
along your presentation. The other thing we will be talking about with Devra is we need to see that
some of these studies are replicated. We can't look at a study and say that's bad if it's not replicated. For
me to feel more comfortable, science has to be replicated.
Scarato: She is going to be talking about that. I had read the questions that your commission is tasked
with. I was basing my presentation from the policy side based on those questions. I am trying to explain
why and give you links to it. For example, the American Academy of Pediatrics sent a letter with
concerns to the FCC. I felt it was important to talk about this.
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Abrami: I agree. Public policy wise, like you said earlier, most people don't know you shouldn't keep it
on your body. I did not know that myself until about a year ago. As a commission, we would really like to
see what other states and municipalities are doing if you have that.
Scarato: I can fast forward to that.
Abrami: You may want to do that because we may run out of time.
Scarato: The Systematic Review: This is important. It is a gold standard and I want to point out that is
hasn't been done. When scientists are writing letters, one of the questions asked is where is the
systematic review? Where is the full report on all the studies and what they found and how to weigh
them by independent experts? What does the science say as to what is a safe level? I know that is a
question that you are looking at.
What do US Health Agencies say about NTP study? I am pointing this out because I think it's important
for the commission to see what different federal agencies are saying on their websites about this issue.
For example, on the National Cancer Institute, unless you know what you are doing, you would be hard
pressed to even know what this study found. All they say is, "primary outcomes observed...". This is not
what most of the American public would even know what that means. The FDA disagrees with findings
of NTP yet no systematic review, no report, no citations, no FDA peer review. The CDC says nothing
about NTP. EPA says nothing on NTP and sends you to the FCC. The EPA used to actually have
statements on their site. We watch all the sites and you can see what they previously said. They had a
statement about an open question of safety, but that's been changed.
2014 The Department of Interior letter states "however, the electromagnetic radiation standards used
by the FCC continue to be based on thermal heating, a criterion now nearly 30 years out of date and
inapplicable to today".
2002 EPA letter to the EMR network of VT: "federal health and safety agencies have not yet developed
policies concerning possible risk from long-term, non-thermal exposures"- Robert Hankin, EPA,2002.
FDA: Scientists 2019 letters to the FDA that have not been answered.
NTP: Ron Melnick is a 28 year NIH senior scientist, who lead the design of the NTP study. He has
published how there are unfounded criticisms of the NTP and addresses that.
The FCC said testing phones are zero mm is unnecessary. Women put their cellphones in their bra. I can
probably find three or four women on the street in DC who carry their phones in their bra because they
don't know. Phones are always radiating even when you are not on them. They say that operating
instructions are adequate. Kids don't know.
Abrami: Theodora, please for the sake of time, it would be great if you get to what states or
municipalities are doing.
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Scarato: Montgomery County, MD has a federal court challenge to the FCC. This was filed before the
FCC did its filing stating they don't need to update the limits. This case is still proceeding. How can the
FCC be streamlining 5G when they haven't completed their inquiry? The FCC should complete the 2013
review before issuing 5G streamlining order. See the links to Putting the cart before the horse-"FCC's 5G
first, safety second" policy by Albert Catalan, Eric Gotting and Timothy Doughty, the Journal of Local
Government Law. That's one of the lawsuits to know about. I have a link to the filing.
Cooley: Mr. Chairman and Ms. Scarato, I don't mean to interrupt but I think there needs to be some
clarification to that slide. The way that you characterize it is that Montgomery County is suing on RF
grounds. Montgomery County raised the RF issue in light of the FCC's state and local item with respect
to streamlining 5G facilities. I think that's an important clarification for the minutes. I hope I wasn't
disrespectful by interrupting you but I wanted to make that point.
Scarato: I hope I was clear on that. What they are saying is, how can you streamline 5G without having
finalized the inquiry preceding it or pushing something forward without having done the review?... not
that there is a health problem. That is what I meant if I wasn't clear on that.
Cooley: I believe that Montgomery filed again though after the FCC item on Dec 4th. I would like that to
be clarified.
Scarato: Oh. I know they are continuing their case.
Cooley: They are continuing their case. I am not disputing that.
Abrami: Theodora, you may want to check that out and get back to us.
Scarato: Yes. I will
Letters from Senators: We have links on our site of senators who have written letters to FCC and FDA,
asking for their review on 5G and their letters.
Lawsuits: I wanted to point out two lawsuits: 1/ Irregulators vs FCC and the Fegan Scott lawsuit.
Irregulators lawsuit alleges that there was money for maintenance of wired lines that was switched to
wireless. I am summarizing. The Fegan Scott lawsuit is about separation distance in phones.
NEPA decision: The FCC's action to streamline 5G, has stripped local authority with regard to
infrastructure. There was an appeal by the National Resources Defense Council and Native American
Tribes that was won. There needs to be compliance with NEPA (National Environmental Policy Act) for
small cell and wireless facilities. Cities and states have argued about amount of caps and leasing spots.
There are two separate cases. The FCC has vacated a part of their order saying they do not have to be in
compliance with NEPA. So now, small cells need to be certified it meets NEPA requirements. The NRDC
did a Q&A about what this means in terms of municipalities. I will provide a link to that.
Federal level: Three Bi Partisan bills on 5G passed the House at the federal level. (H. Res. 575, H.R. 2881,
H.R4500)
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Local ordinances: Cities and towns have been coming up with in order to address this because many
people say ,1 don't want these in my front yard and what do we do? Then they realize they don't have an
ordinance in place to handle it. They don't have a permitting process. They don't have any kind of
authority. Cities and towns are trying to find out what authority they have and make the most of it.
Examples: (City of Los Altos: installation of small cells on public utility easements in residential
neighborhoods is prohibited; 500 ft. set back from schools; 500 ft setback for multi-family residences in
commercial districts; 1500 ft separation between installations )(Petaluma: 1500 foot minimum
separation; No small cell shall be within 250 ft of any residence)(Bedford, NH: 750 foot setback in
residential) (Burlington, MA: annual recertification fees; applicant must pay for legal notices of public
hearing) (Fairfax, CA: small cells prohibited in residential zones; 1500 ft separation; city to study citywide
fiber optic cable network)
Example of issues that come up from lack of infrastructure and permitting/compliance: I will tell you
what happened in our town. On this slide, that small cell on private property is illegal even when it was
placed on private property six years ago. It was placed there even though the permit was for down the
road. The owner repeatedly testifies asking, can you please remove this from my property? Everyone
says they can't because no one has authority. It is still there. What is happening is that there isn't the
infrastructure that there needs to be to oversee the permitting process that needs to be done.
Community members started looking in to this and found several permits that were incomplete and
over a dozen that were placed where they shouldn't be placed. Then there is the whole issue on, why
can't this woman get that removed from her home? You could have a whole meeting on permitting,
review and compliance.
Sherman: I don't understand. We already have utility poles and rights of ways. If this is in violation, why
doesn't it fall into the utility right our way or violation thereof and why can't it be removed on existing
statute? For example, in Rye there are double telephone poles going in and they are failing to remove
the old poles. That's a violation of the right of way and now will be removed. I don't understand why
this would take five years if they are in violation of the right of way.
Scarato: I am not going to profess to know all of the details of it. You can watch her present just a few
months ago. Every jurisdiction has different policies.
Abrami: I know this isn't the science part of our discussion. 5G means something different to everyone.
Different companies are rolling out differently. We are concerned what's in those antennas, how much
power is coming from them, how far away should they be from each other, a home or business.
Eventually, we will get to that. From a policy stand point, we have to understand the science to be able
to make intelligent recommendations Just from an aesthetic standpoint, as a homeowner, I would be
upset too. We need to separate the aesthetics from a science too. Some people just don't want it for
aesthetic reasons. We are concerned about both because there will be push back. We are trying to get
ahead of the curve and understand the science.
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Scarato: We all had that question but it's quite complex because every antenna or small cell facility will
have different antenna depending on the network using a variety of frequencies. 4G is a backbone of
5G, as I understand it. There is a study that came out that I don't' know if Dr. Davis will talk about. There
is a study that looked at small cells in communities and communities without them and found there will
be an overall increase in environmental level. Industry will say it's negligible. Scientists looking at
biological effects will say it's important to consider, I believe. I don't want to speak for anyone but I
know that is what is being put forward. That's a good question. We aren't getting 5G but are getting 4G
and they put cells 2-10 homes.
Abrami: Usually, we hear of 5G in mm waves, further up the spectrum.
Scarato: But they aren't going to be using only mm waves. They are also using low, mid and high band
frequencies, at least from the CTIA report. All of those frequencies will be utilized in 5G depending on
the carrier and location. So, to say it's only mm waves is...
Abrami: Every company is different is my guess.
Scarato: What can cities do to retain their authority? Many cities want to retain as much authority as
possible related to 5G. There are now 120 cities in Italy passing resolutions on 5G. In Cyprus, they
removed wireless from pediatric units and provide safety information for parents. Internationally, is all
online on our website EHTrust.org.
Cooley: Thank you for your presentation. We can talk about what is happening internationally but the
US has a unique set of laws. In terms of what cities can do, we have to remember the FCC state and local
order is the law of the land. It went into effect in January 2019. Yes, it is being litigated. Oral arguments
are February 10th in the Ninth Circuit in Pasadena, CA. As we are looking at policy recommendations, we
have to remember there is federal law. There is also the Communications Act section 332, specifically
which we should delve into because other states are looking at what they can and cannot do in this
space. I want to frame that properly. Yes, there are ordinances around historic preservation, aesthetics
that cities can look at. But in terms of legal framework, I don't think New Hampshire would want to be
inviting litigation by recommending something that would perhaps run afoul of federal law. On that
slide, I wanted to make that point.
Scarato: I would expect that lawyers would assure that local, state and federal law was being evaluated
depending upon where you are. There is a lot that you can do and a lot that you can't do. There is a lot
that cities can do actually.
Cooley: Yes. Absolutely, I am not disagreeing with that. The only other point I wanted to make. You
mentioned a Federal Right to Know law that was introduced in Congress in the early 2000s and you
mentioned the San Francisco Right to Know Ordinance which you seem to allude could be something the
commission could look at.
Scarato: As I understand, San Francisco continued their arguments and decided to pull out because
whoever won would have to pay the court fees and it was not implemented.
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Cooley: That's correct. It was never implemented.
Scarato: Also, the Berkley cell phone law did pass which I did not talk about. It basically says that people
have the right to know when they buy a phone from a retailer that if it touches the body, it could exceed
FCC limits. The Supreme Court let it stand.
Cooley: It was not implemented.
Scarato: Right.
Roberge: On your slide that had cities with protective ordinances, you use the term facilities in terms of
setbacks for facilities. Are you referring to antennas?
Scarato: When I said facilities it refers to the installation of equipment and antenna.
Roberge: I just wanted to make sure we were talking about antenna and equipment not a facility as in a
building.
Sherman: I have a quick question. With multiple different networks and multiple different carriers in any
one municipality are there multiple different 5G networks being proposed? Does each one emit a
certain amount of radiation? If for example,you have TMobile and Verizon in same setting,what does
that mean for total exposure for the public? Is it double? How does that work?
Abrami: To add to that question. Currently, there are towers with multiple antenna, will there be
sharing?
Cooley: Yes, there will be sharing and Theodora made a great point. Carriers will be using different
frequencies. TMobile for example, their 5G will mostly be on their existing macro towers. So they are
going to be 200 feet in the air vs Verizon or AT&T who might be using the millimeter wave on that light
pole. It's not kind of a yes or no answer.
Sherman: If we are in Concord and we have TMobile, Verizon, AT&T all providing service, are we going
to have three different networks to which we are exposed all at the same time? Or is it one shared
network? The ultimate question is does it mean are we going to have 3X the 5G exposure? And what
does that mean?
Cooley: I am not an engineer but the answer is no. Depending on the facility being used, they are going
to have different power levels which will change the amount of non- ionizing being emitted. So, it's not
really apples to apples to say.... you've got one Verizon, one AT&T, one Sprint and one TMobile because
they are probably not all going to be on the same facility because they are using different spectrum
frequencies. So, it's not just to say, Yes.... You will increase by four. This is really an engineering
question.
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Scarato: While that's true, it's also true they don't want to share installations. It came up in Washington,
DC. They don't want to share a hotel but that means that different carriers don't want to share an
installation. Each will have its network rolled out. You will get the increases.
Cooley: But that's specific to DC. There are locations where hoteling does occur and carriers share one
pole. It's completely specific on the network needs and the spectrum being used.
Abrami: We have an engineer right here with a question.
Gray: I wanted to go back and defend my comments in the middle of the presentation. When a guest is
asked to come given the criteria, I expect certain things from that guest. I don't expect to get
bombarded with health things that are trying to tug on my heart strings, other information that doesn't
go back and say yes. We have this but here is the data that I can look at that says this is happening. I've
got a lot of people from Health and Human Services coming to talk to me about vaccines that say here is
anecdotal information that this person ended up with because of that vaccine. We go through this
whole presentation and we say, so what real data did they present at all that says here is this radiation,
this frequency of radiation, this level of radiation that caused these things and that is why we are
protecting you. So, when we go further than that and you say there are a bunch of cities out there who
have regulated placement of antennas. What information did they use to regulate that? If it's clearly
identified information then everybody across the country would have done it. Or is it because they were
scared? I am on the planning board and City Council in Rochester. There are people there who would
like to regulate all kinds of things. It's just like the environmental thing, global warming. Give me data.
Don't give me, I asked a question and I didn't get an answer.
Scarato: Dr. Davis will be talking about that data and all that data is on our website. Dr. Davis is
presenting the science. I am presenting the policy.
Abrami: Yes, Theodora. You did exactly what I asked you to do. I was trying to get a sense what's going
on around the country related to this in terms of ordinances and states taking action and all of that. We,
as a commission are doing a pretty good job of not taking things on face value. We are trying to
understand the science. This may have not met your needs today on this but we are trying to get as
much information on this as we can. I understand your position, Senator Gray. When I talked to Devra
the other day, I told her what I want to know is what studies have been replicated multiple times.
We will be meeting through October on this and we will continue to try to bring in the right people. We
have the outlines and the picture and we have a lot of filling in to do as a commission. Thank you for
your comments but our guests are our guests. As a commission, we do appreciate you coming here.
Wells: I just want to make a quick point from a moment ago, just to clarify the science of electric fields
and magnetic fields. When we talk about electromagnetic radiation, they are additive. It does not
depend on the frequency you are talking about. It does not depend upon what brand name it is or the
locality. It's called the superposition principle. If you have multiple carriers in an area, they will overlap
and add.
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Sherman: I think that answered my question.
Chamberlin: The 1996 Telecommunications Act says that health effects from exposure to radiation
cannot be used for objecting siting. How does that come into play or does it come into play in the
legislation you are familiar with?
Scarato: Well, it says that concerns about environmental effects cannot be used in the siting of facilities.
This was then interpreted by case law and lawsuits to be health concerns. If there is a community and
people only talk about health concerns and the city says because of these health concerns our citizens
have, we are not going to site the tower, then they can be sued. People say don't we have a right? How
can this be? (Section 704 of the 1996 Telecom Act) I didn't mention this, but at that time, this was the
most heavily lobbied bill in the United States. The lobbying only increased after. The amount of money
that went into that bill was pretty impressive. I would say that everyone should be able to have their
time in court to argue if they have been harmed.
Cooley: I would add that there is litigation just filed yesterday actually in Camden County, Georgia with
Verizon. They are suing on the merits of that very issue. The FCC has exclusive jurisdiction over
regulating anything that emits RF. So, if a locality does violate that, they may see litigation as we saw
yesterday.
Scarato: Several times companies or CTIA have sued and they haven't always won. They haven't always
talked about health issues but aesthetics and other things.
Sherman: For my part, I found this very helpful. So, thank you for coming. We are trying to make our
decisions on whether or not to move forward or how to move forward based on as much science as we
can. You have given us a nice framework on what others are doing in terms of implementing policy. With
your help, there has been for me a nice framework on what are the limits of our capacity to do so.
One of the most troubling parts to all of this and you are not the only one who has shared this with us,
so you are not alone is that it sounds like the FCC has sole jurisdiction over what happens with the
rollout of these networks, yet they are completely in bed with industry.
In the medical world, which I represent, we have a similar problem with pharma and their regulation
and the FDA. This is not something this commission can take on but you provided a framework in a nice
way to help us understand what are the limits of policy that we could actually consider and roll out if we
wanted to provide regulation. Thank you for coming and providing some of that perspective. I think we
need both policy and science. So this has been helpful.
Heroux: I would like to address you as representative of CTIA. I just want to drag you out of your
comfort zone. As a specialist, I have heard hundreds of reports of deleterious effects of electromagnetic
radiation, and you have sat very patiently as we outlined these things in sessions.
What about the positive effects of cellphone use? What I mean by that is, if because of wireless and a
cellphone, I can avoid a car trip and then perhaps a car accident. Then surely there are benefits to this,
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right? There are benefits to the use of wireless. Has the CTIA supported and documented the benefits
to using wireless? After all, we have to balance the negative with the positive.
Cooley: Thank you so much for that question. This is a policy question, right in my wheelhouse.
Absolutely, I will do a plug for CTIA.org. Accenture and Deloitte have done host of studies on the
benefits of what 5G will bring to this country. Nationally, 3 million new jobs, 500 billion contributed to
the US GDP.
Heroux: I am sorry. I don't mean about economic activity because that is dollars that can go one place or
another. I am talking about avoiding deaths and diseases. Surely, wireless has substantial capability. I
perceive that your industry has not documented these things in great detail but have been driven by an
alternative variable, which is commercial success. In other words, if things are bought, people want
them. So this is an index on how useful they are. My point is...we love potato chips but we can have
trans-fat potato chips. You see where I am going?
Cooley: Yes. The benefits of 5G for remote health care. If you live in a rural area and you don't want to
have to drive into the city or remote surgery. AT&T is doing some really exciting stuff. There is the first
5G hospital at Rush hospital in Chicago. There are absolutely benefits to consumers and society and
agriculture. Drones survey networks so we can see where people are without service. We need to save
them if their houses are on fire so we can communicate with first responders, so yes. There is a ton of
research on that and independent agencies as well. I would be happy to provide this commission with
those studies.
Heroux: Most of those things like remote surgery doesn't need 5G. It can use fiber optics. What I am
talking about is specifics. So you could come up with a report that would document the advantages of
wireless specifically independent of data transmission. We have not seen that much documentation on
this aspect of it. Ultimately, we will have to balance these things right?
Cooley: I am happy to share those use cases with the commission because I disagree.
Abrami: yes. I would agree.
Cooley: I am happy to share those reports we have right now and there are a host of reports coming out,
I think second quarter of this year that are not CTIA. We don't do the research. Other entities do the
research. I am happy to share those.
III.Devra Davis PhD. MPH. President. Environmental Health Trust (via speakerphone):
I have been working in science at some of the highest levels for many years. We started Environmental
Health Trust when I was at the University of Pittsburgh Cancer Institute, where I had set up the Center
for Environmental Pharmacology. I worked as a member of the President's Cancer Panel. I was
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confirmed by the Senate. So, I have been around for a while. I have written two books. The most
relevant and recent book is "Disconnect: The Truth About Cell Phone Radiation".
I am going to first explain that when it comes to getting information about any toxic agent whether it is
chemical or in this case, RF, we look at experimental studies including modeling of exposure. Please
understand that that is all we have for exposure. We can't go inside the brain and actually pick up
exposure when it comes to humans. What we can do is use computer simulations that are anatomically
based on models of the human brain including specific parts of it that are relevant. I will talk about
today, particularly the hippocampus. We can fairly accurately model those. Those models have been
validated and are used right now. Some of the models I am going to show you are used to set the
standards for surgery or approval of equipment by the FDA.
Then there is invivo testing which means whole animals. We take animals and expose them usually over
a period of several weeks or some time for two years. Rarely, are animals exposed from before birth to
their death.
Next we have invitro studies which look at cell cultures either animal or human cells to measure DNA
damage or other things that happen in cells. Those studies, I want to stress are done in order to predict
human effects and prevent them. That is why every drug that you take is subject to animal testing. The
same standards being applied to testing drugs have been applied to testing RF. Please keep in mind that
everything we know for certain causes cancer in people because we have data for example from
asbestos or arsenic will produce it in animals.
In terms of ecological studies, we can look at trees and grasses. There are experimental studies as well
on bees and other smaller animals.
Finally, we have epidemiology, the study of people and I am a fellow at the American College of
Epidemiology. I was also a member of the American College of Toxicology. So, I am familiar with both of
these overall approaches both, toxicology and epidemiology.
For epidemiology, cohort studies are the weakest form of analysis that we have. In the case of what we
are looking at for brain cancer, we cannot follow people through their entire lifetime with detailed
information. We therefore rely on case control studies of those with the disease and compare those to
others who do not have this disease but are otherwise similar.
The next slide shows you a child. It explains that because of the modelling studies that have been done,
we can conclude without question, that children will absorb more RF into the brain soft tissue inside the
skull and lOx more into the bone marrow of the skull, compared to adults.
Virtual reality simulations: I just showed that to you because virtual reality is a very cool and exciting
thing but the way it is often used is with wireless transmissions and when you have a microwave radio
right in front of the eyes and frontal lobe, you are getting greater exposure if you look carefully through
the top of the skull of the six year old on the right side. You can see much greater penetration into both
eyes and we are very concerned about the eyes of children right now from a number of exposures.
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Summary of the EU REFLEX Project: The European Union in about 2000, funded about ten million
dollars for twelve different research labs in seven countries. They were asked to look at the question of
whether or not the same radiation that would be received from cell phones could break DNA in a variety
of human cells and by the way including brain cells and human lymphocytes and fibroblasts. The
conclusion of that study, much to the surprise of the people doing it, was that they found clear evidence
of DNA damage. At the beginning, when they first found positive results, they assumed they had faulty
equipment. They had so much money that they went out and bought new equipment to test things.
Those of you with a medical backgrounds, which I am pleased to know are on your commission and also
part of your legal body there, understand that being able to buy new equipment means you have a lot of
money. The results shocked the researchers. They clearly showed changes in gene and protein
expression in several different cell lines. Interestingly, they did not show damage in the mature human
cell line. Damage was much greater in human fibroblasts and human cell lines that are less mature, stem
cells.
Abrami: Can you go back to that slide please? So, they replicated a study that was done in 1994 but it
was a 2004 study they replicated again?
Davis: Yes. In 1994, Lai and Singh produced a study showing damage to the brain of the rat from cell
phone radiation, DNA damage. They were shocked by the results. They did the study all over again.
When they were about to publish the results, the industry engaged in what was called "War Games".
That was the strategy and what it was called in 1994. Remember, in 1994, very few people used cell
phones (about 10%). People in industry understood the importance of this, went to the journal that
accepted the article for publication and tried to get it unaccepted. They went to the NIH and accused the
researchers of fraud and went to great lengths to conduct what they called War Games. That was 1994.
In 2004, when another group was asked to see if there was anything to this, they were confident they
would find nothing. In 2004, they replicated it.
Abrami: This is the EU REFLEX group.
Davis: The Comet Assay: Right but there's more. I'd like to show you more about the replication of the
DNA on deregulation of cell proliferation and exaggerated programmed cell death otherwise called
apoptosis and genotoxic effects all show from very little exposure. The next slide is a summary from
there (The Comet Assay). You can see the sham or the perfect cell on the left is a cell with no DNA
damage. When you have damage, you get a common tail. See the tail on the top right and the bottom.
In 1994, those tails were only measured by somebody looking at them and giving you an estimate of
what percent tail there was. Now we have much more sophisticated ways of automating the measure
and extent of that tail. The top right is damage from gamma radiation like you would get from massive
exposure from a CT scan which could happen in a pediatric CT scan where the scanner is not properly
set. The top left slide is your control. The far right on the top is the impact of gamma radiation from
xray like pediatric CT scan gives you that much exposure. The bottom right was what they achieved after
24 hours of exposure to mobile phone like radiation at 1.3 watts/kg.
Abrami: Is that continuous exposure for 24 hours?
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Davis: Yes. It was exposure like a cellphone. A cellphone is not continuous. Within four seconds, you get
huge changes in power density over time.
Abrami: I am trying to understand how far away that cellphone was from the eyes. This is eyes right?
Davis: No. These are not eyes. These are cells taken from the brain.
Heroux: It is slightly lower than the FCC SAR limit.
Davis: It was below the US current standard of 1.6 watts/kg.
Subsequent work confirms the REFLEX project. They showed clear evidence non- thermal microwaves
from mobile phones affected repair of DNA in human cells. They showed the same effects at the GSM
frequency of 915Mhz. These studies referenced at the bottom of the slide, were all produced
subsequent to the REFLEX Project from 2004, 2005 and 2009.
Abrami: so there are four other studies listed there?
Davis: That's correct.
Sherman: All of those corroborate the findings of DNA damage?
Davis: That is correct. Further, the next slide is from Lerchl.
Lerchl: Lerchl was widely known as a skeptic of any of this. In 2015, Lerhcl started with exposure at
conception. The rodent reproduces in three weeks. In a very short time, you can follow these animals
through their lifetime. Then the equivalent of early childhood, the animal was injected with a known
carcinogen, something that we know causes cancer (ENU). Then, those animals were subsequently
exposed to RF exposure. The levels of exposure were .04 watt/kg, .4 watts/kg and 2 watts/kg. What you
can see is that the control animal developed very few liver cancers. The ones exposed to the
carcinogens developed more. But the ones exposed to cellphone radiation developed far more. Much
to the surprise of the investigator, they were able to show that the mice exposed in the womb to a
known cancer agent, then exposed to cellphone, had significantly higher rates of cancer, tumors to the
lung and liver. The study was designed to replicate an earlier study by Tillman, also of Germany. When
he first presented his results, said they were remarkable. His study was ignored. Lerhcl found higher
rates of cancer in all of these mice. Also survival times of the animals were much lower of those who
were exposed. This was a very powerful replication as well and further replication because you had
asked me, Mr. Abrami about focusing on replications.
The NTP study: You already heard about this so I won't go into that. But, I want to remind you that what
is on the website of the National Toxicology Program right now summarizes this information. It states
clear evidence of tumors in the heart of male rats. I want to stress these are very rare cancers. I suppose
in a way, that's the good news. There was also some evidence of tumors in the brain of male rats, again
rare. There were multiple cancers in other organs, some of which did not achieve statistical significance
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but were still elevated. In the NTP study, they said, not only do we have evidence of cancer but
precancerous conditions of the heart, meaning damage to the heart. This is quite worrisome.
The publication that came out from NTP shows DNA damage to the frontal cortex of both rats and mice.
I want to stress that although the cancer showed up only in the rats, the DNA damage showed up in
both the rats and mice. There is clear evidence of replication of results of DNA damage. The cancer
results are also replications. This is not a one off study.
I want to stress something about the frontal cortex. It's really hard to get mice to make phone calls.
That is why the exposure has been carefully calculated not to increase the temperature of the animal
but to allow whole body exposure that simulates the kinds of exposures that can occur today.
Slide 14 and 15 give you a much more detailed analysis of NTP. Slide 14 looks at the tail of DNA using
computers now. In 1994, they had people who could just look at the tail. Now we have computers to do
it. They can score the number of cells in terms of the evidence of fragmentation of the DNA. Zero is
your control. You will have some fragmentation of DNA just because that's life. We are breathing. We
have sunlight. We get DNA damage all the time. If we are healthy, we eat our broccoli and sleep in the
dark, we will have repair of our DNA. This is showing that exposure to CDMA which is a type of
cellphone radiation. You get statistically significant damage indicated in the male rat hippocampus. The
hippocampus is what allows us balance, memory and impulse control. It has been well studied in many
different systems and shown to be damaged by exposure to cell phone radiation. Slide 14 is showing you
the rat and slide 15 is showing you the mice.
Slide 15 shows the effects to mice are in the frontal cortex. In the rat, it was the hippocampus. Slide 16
discusses the implication of the NTP result. Dr. Melnick was involved in setting up the study originally in
2008. The study was designed to test whether or not heat was the only effect. They set up a study that
did not heat up the animals. That design was carefully calculated by Swiss engineers using methods that
are validated, they were able to show results that I just showed you, increases in brain tumors, increases
in heart as well as DNA damage in multiple organs in both rats and mice.
Abrami: Is that the replicated study that was done?
Davis: Yes. Smith-Roe is the first author of that study that was just finally published in 2019. Dr. Melnick
and I and many others believe that the FCC by issuing its latest order saying we are going to be keeping
our 23 year old standard for RF is ignoring this body of evidence I just showed you and more. I would like
to show you a little bit more.
Gray: Before you leave that. The radiation that you applied is less than what it would take to heat. What
is that in relationship to normal radiation from a cellphone an inch away from the head?
Davis: Thank you for that question. It is the same radiation you would get from a phone and they did it
with ten minutes off and ten minutes on simulating the way we are exposed. As you may be aware, even
when a phone is in your pocket as long as it's turned on, it's constantly checking for signals from a
tower.
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Gray: I understood that it was the same radiation. What is the level of radiation? I want to know if the
radiation that I would get from a cellphone an inch away from head is a higher level than what these
rats and mice would have experienced just below the level that would cause heating.
Davis: Well as a matter of fact. I am really glad you asked that because the answer is we get more
exposure from our phones than these rats got. The reason we know that is because I assume you have
seen the results of the Chicago Tribune test. Have you?
Abrami: No.
Davis: Theodora, I think you should show them the 60 second video of the test from Chicago. Do you
have that? The Canadian Broadcasting Corporation, the French government and most recently the
Chicago Tribune have actually taken real phones and tested them. They have found that the phones
when in your pocket emit actually more radiation than the NTP study. The NTP test, tested the amount
that they are supposed to emit. The Chicago Tribune paid for independent testing at an FCC approved
lab. They took phones off the shelf and what you may not be aware of is that the way phones are tested
today. They are provided by the manufacturer to a test facility and they select the phone to be tested.
There is a whole scandal about that because as it turns out when you do that, of course the phones pass
the test. When you take phones that you can buy and test them next to the body, they all fail the
current test. (Nine out often of them to be precise) They fail it by as much as five fold in the United
States.
Sherman: That is significant, what she just said.
Scarato: I wanted to say that when you put a phone near your body, you are getting an intense localized
exposure near where the phone is. NTP did that at localized exposure, not the full body number. They
wanted to see what the intensity would do to the tissues. This is not a whole body number but a
localized number that we are talking about when we are comparing. The FCC occupational limit is 8.
Abrami: So, when they did the test and took the phones off the shelf what did they do?
Scarato: They measured the SAR levels at body contact and at 2mm and the French government
measured hundreds of phones and body contact and found excesses of the limit.
Abrami: Most of the public is putting it next to the body because they don't read the fine print.
Sherman: I am trying to get at what is the significance of exceeding by five fold in the Tribune test? What
does that mean to us?
Davis: The significance of the Chicago Tribune test should be that it would call for re-examining the
whole test approach.
Sherman: So we are basing the emissions coming from phones based upon the tests done by the
manufacturers under FCC guidelines but these independent tests in Europe and by the Chicago Tribune
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and Canada are showing no, that's not necessarily the case. We may be getting five times that exposure
of RF. Is that correct?
Davis: That is perfectly said. Thank you.
Scarato: in high exposure conditions.
Cooley: I just want to add to the record from that Chicago Tribune story which came out in August. The
FCC immediately opened an investigation to look into that. On December 19th, after doing their own
independent investigation, the FCC published a report saying they tested the same models and found all
of them compliant with the FCC exposure limits.
Sherman: This is the FCC that currently has every member as a member of industry, former, future or
current. Is that correct?
Cooley: The commissioners. If we are talking about the "Captured Agency" slide that Theodora had. The
commissioners don't do the testing.
Sherman: No. But they are the ones who approve what comes out. It's like an Editorial Board. Is that
correct?
Cooley: I don't know how or if they approve of a report. I don't know that process.
Davis: The protocol for the FCC was developed based on the assumptions that the only effects that
needed to be avoided were heating. The tests were developed 23 years ago when phones were solely
used by medical and business people. How many of you used a phone 23 years ago?
Sherman: I did.
Davis: Well, you are probably the physician in the room.
Sherman: yes.
Davis: My dad was a brigadier general and he also had one but very few people with normal jobs had
phones. It was only about 10%. That's when phone protocols were set up and they were set up to be
tested up to an inch away from the body because they would be in a holster which is the way people
had pagers and phones in those days. They didn't carry them. They had them in a holster.
Scarato: Can I clarify what Beth is saying here? When the FCC did their test after Chicago Tribune, they
tested at 5mm from the body. They didn't test at zero mm which was the whole point. They said they
are compliant but if you look at the test report, it says 5mm. Then the news headlines read," they are
compliant". But it says right on the report... 5mm. The issue is people have close contact.
Gray: The 5mm problem bothers me alright? The reason it bothers me is there are 2.54 mm per inch so
if I take 5mm, I am at a quarter of an inch or so and when I look at where the antenna is in the phone
because there is a spacing there, I would think that 5mm is probably a pretty good distance when I have
the phone right up to my ear.
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Davis: It turns out that the antenna in the old days were towards the head. The newer antennae are
toward the thyroid and lower. Your smart phone can have four or five antenna: One for data, one for
video, one for voice, one for satellite GPS which is not RF. You have multiple antennae now that are
located lower in the phone. We are now concerned that one of the explanations, not the only one but
one of the explanations for the increase in thyroid cancer could be cellphone radiation.
Ramazzini: (slide 18) I do very much appreciate the opportunity to speak to all of you. I am delighted and
honored to be able to speak to you and the fact that you exist really means a lot to all of us that have
been working on this issue for quite a while. I never imagined I would be spending a decade or more of
my life on this. I previously worked on lead and asbestos and I thought this would be a pretty simple
issue but it's not simple. Ramazzini did a study like Lehrcl but they took thousands of animals and
exposed them at different levels before and at conception and followed them until they died.
Their results on slide 19 was to show damage, the same type of damage that the NTP found at levels of
exposure to their animals that were far less than NTP. In particular, they showed a synergy between RF
and xrays (gamma radiation). This is really important because it shows there is an additive effect
between RF and gamma radiation (xrays).
Abrami: the Ramazzini study was an independent study basically in parallel?
Davis: yes. It is the equivalent of the NTP for Italy.
Uptake of glucose in the brain: Slide 20 is a summary of a paper that was published in JAMA by some of
the top researchers of the US government, the Director of the National Institute of Drug Abuse on the
effects of cellphone exposure to the uptake of glucose in the brain.
Slide 21 shows the study design. A person with two cellphones strapped to their head. The study was
done more than a decade ago. They had a PET scan which can measure the uptake of glucose in the
brain. The person with a phone strapped to their head did not know whether the phone had been
turned on or not.
Slide 22 is the results. If you look at the slide to the right, it shows the increase in glucose in the parts
the brain that got the most exposure. Look at the slides comparing glucose uptake when the phones
were turned off compared to the slide with the phones on. Look at the increased amount of glucose in
the exact part of the brain there was the exposure. Why is that important? Alzheimers has been called
diabetes of the brain because people with Alzheimers have too much glucose in the brain. Nobody
knows the consequence of having too much glucose in the brain from holding a phone next to your
head. It remains unknown. This study was subject to "War Games" as well.
Slide 23 explains part of what might be going on. You will see the control on the left without exposure.
The slide on the right shows little tiny dark spots of damage, indicating that the blood brain barrier has
been breached. At the bottom of the slide you will see references.
Abrami: is this a human brain? Or no?
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Davis: oh no. We can't do that. These are Sprague Dawley rats.
Davis: at the bottom of the slide you will see references to subsequent studies. The first study showing
this was in 1975. Alan Frey did that work. Cold War was still on and radar is a vital part of it and he was
basically told to stop doing research. All of that is documented in my book.
What happens when you have a cellphone in your pocket: I have done a Ted X talk that I think you will
find interesting. I make the point that sperm have to swim the equivalent of the distance from Los
Angeles to Hawaii in order to succeed in fertilizing an egg. Do you know why it takes at least a quarter of
a million sperm to make a healthy baby?
Abrami: why?
Davis: It's because they don't know how to ask for directions.
Abrami: I fell for that one.
Davis: When you get these slides on your own computers, you can simulate the exposure. Look at the
white in the control slide. That indicates either the nucleus or the border. On the exposed slide, you can
see that on some of the cells, the nucleus has been degraded and in many cases, the border is gone.
Again, indicating damage to the membrane. So, cellphone radiation damages the membrane of the
brain as well as the testes. I believe the eye, as well.
Abrami: I see the Cleveland Clinic quote there. Was this research done there?
Davis: Yes. Some of this research has been done there. Some of it has been done in Australia at their
equivalent of the Cleveland Clinic and other work has been done at other clinics. What's interesting is
that people doing this research started to do it two decades ago because they were concerned with the
number of doctors showing up having fertility problems. What they concluded in a cross sectional
analysis was that those who had the most beepers and things on their pelvis had the lowest sperm
count.
Recent study glioma on Slide 28: Summary of the most recent work I have done with Prof. Anthony
Miller who has himself authored more than 600 publications. It basically shows every study that has
looked at people who have regularly used phones for ten years or more, for an hour a day or more we
found an increase in glioma. More studies have been done now. The most recent study was released
this week.
Thyroid Cancer: The American Cancer Society supported a study of thyroid cancer. It was done at Yale
University that shows a double risk of thyroid cancer from those using phones that had specific SNPs
which are quite common. These SNPs have to do with repair like p53 and other things that have been
identified. The newer phones have antenna located closer to the thyroid. The study concludes that they
have found a link to an increase in cancer from regular cell phone use. It was just published this week.
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Effects on children's brains: Slide 31 tells you of the effects on the brains of children are substantial.
Here is a study that looked at the brain matter of preschool aged children, using MRI. I don't know how
they got approval for this study but they did. They concluded that there was degradation in the brain
white matter looking at microstructures with heavier regular screen use, which is further reason why the
American Academy of Pediatrics has said we must reduce exposure in young children.
Abrami: They based it on one study or the preponderance of evidence thus far?
Davis: Well, this is one study but it's a replication of many other findings on effects of attention,
behavior and learning in children.
Effects on memory in teenagers: Slide 32 looks at teenagers and again they find a deficit in memory of
kids. I will let Theodora talk to you about synergies on slide 33 they found in Korea. Mr. Abrami, you
had stressed you wanted replication. I am showing you these are all replications of results on adverse
effects on learning, behavior and attention from cell phone use in children.
Why so many conflicting studies? Slide 37: The answer is, follow the money. The majority of the studies
in this field have been funded by industry or the military. That's just a fact. Analyses of the studies show
that 75% of all the negative studies have been funded by industry or the military. Microwave News 2006
assessed funding bias. You don't need to be a statistician to know which way the wind blows.
Insurance Industry Slide 39 shows secondary insurance Swiss Re and Lloyds of London and others will
not cover damages from wireless devices or EMFs. They rank it in the same category they once ranked
asbestos.
Abrami: We were well aware of this fact. Have you spoken to anyone from the insurance industry about
this? Why don't they insure?
Davis: Several years ago I did. They run the numbers. They think there is sufficient scientific concern and
the 10K reports of wireless industry say they may face liabilities from lawsuits. There are lawsuits right
now on behalf of people with brain cancer that are still going through the courts. They have not been
thrown out and frankly I think they are going to win.
The last slide is the one of the cartoon. I just want to remind you. It had been very difficult to get people
to stop smoking in the environment of children because the science had been deliberately manipulated.
Unfortunately, that is what we are dealing with here as well. Why did the FDA reject the NTP? They
have not even given a reason.
Sherman: We kept hearing about the need expressed by federal agencies for a comprehensive review of
all the studies that have been done and yet that hasn't been done is my understanding. Is there any plan
for comprehensive review? If there is, would that review take into account funding sources? We know
from several other medical studies that the impact of funding is huge on conclusions and editorial
control of final conclusions on the studies.
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Davis: Environmental Health Trust, I can say is that we are the mouse that roared. We have managed in
the paper that I shared with you, Miller et al. That is the closest thing to a comprehensive analysis. That
was done in 2018 two years ago.
Abrami: We have to pause. Beth has to leave. I am thinking about the 14th of Feb for our next meeting.
Cooley: I am not available but I can see if someone internally is.
Davis: What is your schedule for completing your work?
Abrami: We have until October to have our report finalized.
Davis: Your work will be vitally important because there is a huge gap. The federal government has
abdicated it's authority for years. We have been really shocked at the appalling situation with the FDA. It
just flies in the face of science I have shown you just briefly here. I could have shown you even more on
male and female reproduction in animals. I could have shown you more effects on humans. This simply
indicates that there is a robust body of scientific evidence, including the study I just showed you that
just came out on the thyroid (Luo 2020). That study is putting another nail in this coffin. We know
industry knows how to make safer phones. The real question is for 5G, what does all this mean?
Sherman: Can we get a link to that?
Scarato: Yes, and also the bees because they look at MM waves specifically.
Abrami: Yes. We are interested in bees. That is an area we want to pursue.
Davis: I have a video in my slides of the bees. This study was done by bee experts with three hives. What
it showed was the hive with phone off and the control hive had no effect. The hive with the phone
turned on, those worker bees did not return and they stopped producing honey. Obviously, you are not
going to have a phone in a bee hive. But it's clearly indicating a susceptibility to this exposure.
Abrami: This has been very helpful. We are trying to get the facts and understand. Unfortunately, as a
commission, we don't have the resources of the federal government here in New Hampshire. We don't
get any funding to do anything other than us being here as volunteers. We are going to work as hard as
we can to get at the facts. We would like to hear from the FCC somehow or at least a member that was
in the room. You suggested that there may be someone that may be willing to chat with us.
Davis: I think he may be willing to do it without being identified by name. It is a tough business.
Abrami: Well, we will take him anonymous.
Davis: I will ask.
Sherman: I can talk to our federal delegation and see if they can twist some arms to get somebody here.
This is something Jeanne Shaheen should be able to compel.
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Davis: I fully agree by the way .The appalling thing is there isn't any staff member at the FCC now with
any training in this field of bio-electromagnetics.
Abrami: I would like to know in their last ruling, what they based their decision on?
Davis: Montgomery County if preparing to file suit against the FCC because in their statement, they
confirm the 23 year old standard. They do not show any recognition of the 1900 pages of scientific
evidence they received in response to their proposed rules. They asked the question: in advanced notice
of proposed rule-making, should we change our standards? They received hundreds of scientific
statements including from us stating that they should. In failing to review the 1900 pages, they are
violating the Administrative Procedure Act. I don't know if any members of your commission are a
lawyer.
Abrami: We have someone from the AG's office on our commission.
Davis: That's wonderful! I would like to talk to the AG and see if the state wants to join this lawsuit as an
Amicus. It doesn't cost any money. Montgomery County probably has a budget equal to your state.
Garod: have any other states joined?
Davis: We think California is going to. What I have been told by a reliable source who was at the
meeting, was that Ajit Pai said, I don't care about science. This is what we are doing. That is so arrogant.
Sherman: Are the FCC meetings public?
Davis: This one was certainly not.
Abrami: Devra, I will connect you two by email and you guys can have a chat.
Davis: and I will connect the AG person with the AG person in California.
Abrami: well, we will start with you talking to him. We are out of time now. We would appreciate maybe
down the road having another conversation with you.
Davis: I am happy to do that. The fact is that the federal government is failing in its duty to protect
public health. That's very unfortunate and therefore you guys are in a very important role. You really
are. I have been accused of being a closet Republican. The fact is it may take Republicans to do this
because the Democrats have been in bed with these guys for a long time. I hope I don't offend anybody.
Abrami: Let me see, about half anyway.
Davis: The fact is both Republicans and Democrats are both well supported by this industry.
Abrami: At the state level we do this on the cheap. We don't get any money.
Davis: I know you are a citizen legislature with real lives and real jobs and you are doing this as well and I
am truly grateful to each of you.
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Abrami: We are trying to do what we can do and to get the facts. We appreciate your time and
Theodora as well. I will connect you with Brandon our Asst. AG. Another other questions:
Woods: how do you know the level of scrutiny the FCC gave to the scientific information provided? You
say they didn't' look at it. How do you know that and what level of scrutiny did they give it?
Davis: I know that because of a person who was at the table when this happened.
Woods: Ok
Sherman: Is there any reference to the science?
Davis: No. it's as if all of it doesn't exist. Let me be clear, five years ago I brought a number of different
scientists who had done this research from Turkey and England to the FCC and met their so called
interagency group on RF radiation and briefed them. There is such a group. They have no power. They
have no authority. They have no statutory standing to do anything at all except to advise. I don't go into
the FCC to brief anyone any more. There is no one to brief. In fairness to the agency, they have huge
responsibilities to a lot of different things. This issue is one where yes, you want faster connections to
your services. You don't want you fire and police to rely on wireless. It's not reliable. Snow and rain can
interfere with it. When you have too many people trying to call, its slow. We cannot afford to have
emergency services, public health and the hospitals relying on wireless. It's not safe. We need wired
connections and we need to have a major push for fiber optic cable and broadband access to and
through the premises.
Abrami: We saw that on 911 in NYC.
Davis: From the point of view of the Dept of Defense, they have issued a report on this warning about
the vulnerabilities we face. Demanding wired connections for those that need them is the way to go. I
think those in public safety have to reset the conversation. If you are really going to protect public
health and safety, you've got to have it wired. It's the only secure connection you can have.
Scarato: I want to add to what Devra was saying about to the two questions about the FCC. How do we
know what the FCC did or did not review? There is actually an item the FCC released where they talk
about the decisions they made and based on what. As an example, Environmental Health Trust put in
countless submissions. We were one of the high submission groups and they didn't address our
submissions at all. They addressed some but the large majority of research on biological effects was not
addressed in any deep way that one would expect. On the NTP, they just said we are going with what
the FDA said. There is a three page paper on what the FDA says and there is only one paragraph on the
biological effects. Scientists would expect a more robust document that goes over you gave this study
but this scientist thinks this. That wasn't there.
My second question of who is doing a systematic review? The WHO EMF Project which is different than
the WHO International Agency for Research on Cancer, there have been a lot of criticisms of
transparency on the WHO EMF Project for many reasons of which I have a link to. They have been trying
to do a review and it's been mired in questions of transparency. Who are the experts? Who is picking
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the experts? Whereas, the International Agency for Research on Cancer, when they did their 211
determination that you are familiar with Class 2B possible, they vet the researchers for ties with industry
and I should add that they are now calling for a reevaluation for the carcinogenicity of RF and that
should be completed before 2024. That is model systematic review on everything.
Miller: I would argue that the solution that Devra is proposing does not solve the problem at all. Our
public safety entities all have fiber to the premises. They don't have access to fiber when they are on the
road. So mobility and interoperability are key.
Davis: Let me be clear. There is no 5G for voice. There is probably not going to be 5G for voice for
perhaps a decade or more because 5G as you all know is fast and short. It doesn't go very far. In order
for you to have 5g on the road, you need to bury it in the highway and people are proposing that by the
way. The 3G and 4G that you use now travel miles.
Miller: Are you saying that 5G is the only product or technology that causes radiation?
Davis: No.no.no.
Miller: So, it doesn't matter which generation, 3, 4 or 5. They all cause radiation. I think the mobility
factor is very important. So the solution needs to come elsewhere within the design of the devices and
not to be taken lightly.
Davis: I completely agree. That's why California issued safety advice about how to use cellphones more
safely which your commission should consider. The French government issued a guidance that will take
effect in July that said, the abdomen of teenagers and pregnant women should not be exposed to cell
phone radiation. That's the French government conclusion. We need to educate the public about how to
use cellphones more safely and we need to encourage cellphone designers to do frankly what many of
them are already doing to redo the software and the hardware so exposures are much less. There are
things that they are doing to do that. Within the industry, there are people I have talked to who say the
only problem is the lawyers, no offense again.
If they come out and say now we have got a safer phone and people will say, why didn't you make one
before? What about all these people who have tumors in their ears and tumors in their brain and other
problems that came from their phone? It's a huge liability problem for them. You are absolutely right.
We need safer phones. By the way, our twitter handle is @saferphones.
Abrami: We have had conversations about that in this commission recently as well. This shouldn't be
adversarial with industry. We should be shooting for the same goal. Let's make it safer.
Sherman: Devra, two of my close friends were Marianne Donovan and Ron Herberman.
Davis: oh my goodness. Two of my dearest friends.
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Sherman: I served on a board with them. But back when Ron was testifying and taking an awful lot of
heat for that in Congress, one technology that was available was a very lightweight shielding along the
skin side of cellphones to shield from RF from the antennas. Do you know what happened to that? It was
low cost and light weight and could have been incorporated into the phone without much difficulty.
Davis: That was a company called Pong but has been renamed. There are cases that have been devised
that do reduce the radiation somewhat.
Gee, then you know then what Ron went through. You know what happened to Ron who was such a
distinguished scientist. He told me had never experienced anything like that in his professional life.
Sherman: yes, I was there when that happened.
Abrami: Out of respect for everyone's time, we need to go.
IV. Next meeting: February 14th. 8:30-10:30 Agenda to be determined.
V. Meeting Adjourned at 11:00am.
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
2/14/2020
8:30-10:40 am:
LOB 202
Meeting called to order by Rep Abrami at 8:30 am.
In attendance:(10)
Rep. Patrick Abrami-speaker of the house appointee
Rep. Ken Wells- speaker of the house appointee
Kent Chamberlin-UNH-appointed by the chancellor
Denise Ricciardi-public-appointed by the governor
Michele Roberge-DHHS- Commissioner of DHHS appointee (Augustinus Ong attending for Michelle)
Dr. Paul Heroux- Professor of Toxicology, McGill University- speaker of the house appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Senator Tom Sherman-president of the senate appointee
Brandon Garod-AG designee, Asst. AG Consumer Protection
Not present: (4)
Frank MacMillan, Jr. MD-NH Medical Society Environmental Medicine
David Juvet-Business and Industry Association
Bethanne Cooley-CTIA, trade association for wireless industry and manufacturers
Carol Miller-NH Business & Economic Affairs Dept.
Agenda:
I. Approval of minutes from 1-10-20:
Abrami: Michelle is not here but we are allowing Augustinus Ong from the Radiological Health
Section of DHHS to sit in for her.
For us legislators, it's been an interesting past couple of weeks with most of us running non
stop. Bethanne Cooley could not be here and we knew about that. I am not sure about Carol
Miller. We are allowing Augustinus Ong to sit in for Michelle Roberge from DHHS. With regard
to the minutes, Bethanne Cooley sent me a note saying, she was incorrect to say that the San
Francisco Right to Know Ordinance was struck down. So I am going to adjust the minutes on
page 9/10 and take out those comments. I give her credit, she went back and checked and
found she was incorrect. With those corrections, minutes were approved.
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II: Denise Ricciardi- Outside call concern:
Ricciardi: I debated about this but I think in the interest of transparency, it is important to mention. I
received an email in my personal email which is not the email that I use for this commission, from Dr.
George Carlo in Washington. He said that he wanted to speak to me and thought he could be of help to
this commission. I called and I was uncomfortable and uneasy with the conversation and I asked him to
speak to our commission. He said that he could not do that, that he has to work under the radar. He
kept using the word "we" when talking with me and I asked him who is "we"? I asked him how did you
get my personal email? Oh, somebody gave it to me.
This went back and forth on the phone and we followed up via email and I used the right email that I use
for the commission. He asked, why can't you and some of the delegation come to Washington and talk
to me? I said because of Right to Know laws and transparency and I was very uncomfortable. I am not
implying anything... for the record. I did research him and do you mind if I just read this?
Public Health Scientist and Epidemiologist, is one of the world's leading experts on Electromagnetic
Radiation. But from 1993-1999 Dr. Carlo headed a 28.5 million dollar project funded by the
telecommunications industry. It went on to say that he studied cellphone health effects and discovered
that the risk of acoustic neuroma, a form of brain tumor was 50% higher in long term use of cell phones
and it goes on. I am just putting it into the record for the interest of transparency. I am not implying
anything. I just want it to be known.
Abrami: thank you. Are there any questions on that?
Heroux: Most of you are aware of Dr. George Carlo's past involvement?
Abrami: not really.
Heroux: He is an epidemiologist and a lawyer and at one time he was retained by the cellphone industry
in wireless technology research to devise a research program that would shed light on the effects of
cellphones. After he was recruited by the cellphone industry, it seems that things became very
complicated and nebulous so people have various takes on that but he is a very important central
character in this whole issue. But, I would say that his motives are a little bit uncertain for many people.
So, that is his history but he is a very central character in this issue.
Abrami: Did you ever ask him if he would be willing to speak with us here?
Ricciardi: Oh yes and I have it in email. He says he can't. He has to work under the radar that what he
says could be taken out of context. I just felt uncomfortable. I debated if I should address it or not but I
think it was the right thing to do in bringing it up. I hope you all agree.
Gray: I just want to remind the commission here that your task is 5G. It isn't 3G. It isn't 4G. Your task as
defined in legislation is 5G. If you are going to say other technologies you should relate it to that there
could be difference because of mm waves and get it back to the topic. Your task is not 4G or 3G. It's how
5G affects and whether we should do something about 5G.
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Abrami: We discovered early on and I didn't realize this when I wrote the bill for this commission, that
you can't talk about 5G without talking about 3G and 4G. We broadened it early on in our meetings. It
turns out that 5G is this nebulous thing. It depends upon what company you are talking about with 5th
generation. Will they use mm waves or not? I understand what you are saying Senator but it seems we
cannot talk about 5G without talking about the others.
Gray: Representative, there was the opportunity to put a bill in this term that would have expanded the
scope of this but we didn't. I am just trying to do what the law tells me. The law tells me this
commission is supposed to look at 5G. What is the health effect of 5G vs 4G? We talk about the size of
the wave. We talk about how that can affect and again, a lot of the things we have had as testimonies
don't deal with 5G at all. They deal with 4G technology, things that were studied and not using the
same size waves that we are talking about in 5G. Again, that is what our task is.
Abrami: If you go back to one of the earliest meetings and review those minutes, I said I believe if there
is no objection, I think we have to broaden this a bit. I have been on plenty of commissions that things
get broadened as they come up.
Today we are going to get at the towers that are 5G with Paul. We have conversation among us that the
technology is hidden in the antenna. So it's very hard for us to understand even that if this is proprietary
how much power, the configuration of the antennas and all that so ....
Ricciardi: It is my understanding that if 5G were to hang in front of everyone's home, that it can't solely
work on its own. It would be piggybacked with 4G. If I am correct in that, that's where they come
together.
Woods: Two aspects. Number one, looking at 5G is relatively new and research is not as robust but
looking at using 2, 3, 4G it's like any other research protocol. You look and say what does that tell us?
Then you look at mechanisms and then you say, let's look at 5G. It gives us a basis in which to look at 5G
and educates us for parameters that we need to verify. Secondly, we also need to understand what 4G
does because we haven't really gotten into synergies yet. Physical systems and biological systems for
sure become more complex with synergies. We really haven't but I am sure we will as we go along, talk
about synergies. I think those two things are important for us to look at both. I understand the concern
and we have to focus more as we go along in terms of decision making.
Gray: The things the good doctor has said is consistent with my statement. If you are going to talk about
other technologies, you need to say why 5G is going to be harmful, how it compares to it. Again, don't'
just throw out a study and say its cellphone technology, so it's bad.
Abrami: I agree. A lot of the testimony we have had is on cellphones themselves. Again, a cellphone is
communicating with whatever.
Wells: Just to reiterate something we talked about before. When we talk about electromagnetic
radiation, you talk about characterizing it by frequency, energy intensity and polarization. That's really
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what we need to talk about whether its brand name is 5G or 4G is immaterial. The characteristics of the
waves that we talk about are given by the physical parameters.
Abrami: To me, what we are discussing is all things RF radiation. Our goal is to try to understand this.
Where is the line drawn and where or if, are the health effects? We are in contest with FCC and FDA. We
are just a little state here but what keeps me going is there is enough compelling research out there
saying something that it seems we should pay attention to. Where we end up late summer or early fall,
I am not quite sure. We haven't started bringing this together. What can we do as a state? Where are
we heading with this? First of all there are a bunch of lawsuits out there right now against the FCC and
those things will play out. The other reason for the bill was to get ahead of the curve as a state on all the
push back that is going on around the country. I don't know whether that pushback is based on hysteria
or not. I don't know. But, there is pushback. Every day I get stuff sent to me like yesterday from
Huntington, NY. My brother lives there. I said to him, do you know anything about this? He said not
really. Are we straying off the theoretical parameters a little bit? Probably but I think we need to. Is
someone going to slap my wrist for doing that? I think you have to, in order to be able to discuss this
topic.
Chamberlin: Because 5G is an add-on to 4G, the more we understand about the preceding technologies,
the more we are going to understand about the impact of 5G technology. It is really important that we
look at the body of information that is out there on previous generations.
Heroux: With 5G, we have no epidemiology and relatively few studies. The other aspect is that there are
low, middle and high frequencies for 5G. As Mr. Wheeler of the FCC said, the technology is ill defined. So
we don't have a very precise target. They are going to be on common structures. To be well instructed
about health impacts, you have to know about EMR as a whole and experience we have is from earlier
generations, if we are going to epidemiology information as a goal at all.
Abrami: the studies of 3G and 4G impacts do impact what we are looking at. I appreciate the comments
but we have to plow forward. Obviously, in our report we are going to be addressing 5G but if we find
out that there are things we should mention in our report related to RF radiation, we should do that. We
are going to vote and I mentioned this once before. A House commission is different than a Senate
commission. You sign off on a report on a Senate Commission. We don't sign off. Your way of not
agreeing with the majority is to write a minority report. That's the way our commissions work.
III. Pat Abrami: Smart Meter Bill:
The next thing on the agenda, is this on topic or not on topic? We have heard some discussion about
smart meters. I was minding my own business one day when I overheard the prime sponsor of the
smart meter bill. I said we are doing 5G, sign me up. Senator Sherman signed up too. I think the
Representatives can understand, sometimes you look at a title and think I could contribute to this
bill. Unfortunately, I had not read the bill until just before the hearing a few weeks ago. It turns out
that the prime sponsor knew nothing about the topic. He was submitting it for a constituent. NH
has a statute on the books about smart meter gateway devices. That was passed eight years ago. It's
a pretty strict provision. My understanding of a gateway device is that it gets readings from your
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refrigerator and different appliances and that connects to your electric meter. My sense and I am
guessing now, is that this was more about security than RF radiation when they passed this bill. We
are big on security in legislature. If electric company wants to put one in your home, you have to
"opt in" not "opt out". That's a tougher climb. You have to sign a piece of paper that says, yes, I
want this device in my house. This was almost like a preemptive strike on something that someone
was anticipating.
Sherman: I remember the discussion on this. I think one of the problems was if you have a meter
that can be read by anybody because it's transmitted then this was mostly a privacy issue. If your
use goes up significantly, that's your business. I think the big concern was law enforcement being
able to tap into this.
Abrami: So it was a totally different angle.
Ricciardi: Do we have a law here in NH about privacy protection because that segways right into the
lack of privacy with 5G. I just wonder. Do we have anything in place?
Abrami: I don't know.
Sherman: I don't think we have a single law about privacy protection. Even the technology of license
plate readers being used by police was blocked in the Legislature. So we don't allow them to hold
onto the license plates after you go through the toll booths. We don't allow police to go into a
parking lot and do license plate scans. I don't think there is a single bill on privacy but I do know that
as bills come through there is a high level of scrutiny on how much personal freedom this might
impede.
Ricciardi: That should coincide with 5G then because that is surely a lack of privacy.
Abrami: When I read the literature on preparing because I testified on this bill. There were four
issues: One was privacy with the smart meter relaying to electric companies.
Chamberlin: I don't know if we are talking about the same bill but there is a current bill that came
before the House Science, Tech and Energy Committee about 5G smart meters and one of the
concerns was health, so they deferred to our commission.
Abrami: Yes. That's the one. I testified that day. You missed the hearing that day. The bill was filed
and what it did was mark up the existing statute basically taking away what we have. I testified in
the hearing and said this bill needs to be worked big time. It turns out that there are different
degrees of smart meters. There are like three layers of smart meters. Eversource came in and said,
wait a minute. We have a truck that drives around and it activates when we want to take a measure
that is very low level. It only pulses when it is signaled to pulse. Eversource saying wait a minute,
what are you doing to me and you would have to agree with that. Then there's is the electric coop,
which is bigger than you think. They have it and they say that theirs only pulses 14 times per day.
You can't really say there are any health affects because it pulses 14 times in a day. The continuous
pulse is the third. I think that's the one related when you read the list about health effects. So
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clearly, in your committee there wasn't enough evidence for them to consider so what they did was
they asked if our commission could take a look at this. So, if we have time, we will take a look at it.
Does it have to do with 5G? I don't know. But its continuous pulsing and people are concerned
about continuous pulsing.
Sherman: We actually have a new lawsuit in Rye. A resident is having to leave she said because of
the smart meter pulsing from a town building which is actually the school. She is suing the town for
cost of having to move to a new location. The concerns are already out there and are affecting
municipalities.
Abrami: The big thing especially apartment buildings where all the meters are in one spot, that's the
ones that I read are problematic. Supposedly there are ways of shielding that.
Wells: I think we should hear some testimony on that. I am very skeptical that a metal plate is going
to do anything except radiate on the other side. A faraday cage will keep the field out but it won't
keep it in.
Abrami: We have to bring in the right witness who knows this topic cold with the different types of
smart meters. They did the right thing. The bill was not ready to be passed and Science and Tech did
not have the time to fix it. They have 50-60 bills I think in their committee. They have a lot. That was
the smart meter update.
IV. Dr. Paul Heroux-Cell Tower Placement
Heroux: Essentially, this is about 5G. 5G will have as a primary consequence installation of a lot more
towers in our environment. The question is, what do we know about the impact of EMR coming out of
towers from the past? I did a short study trying to gather the written literature on this. I have a number
of articles that I will leave with you and I have as well an Italian film on the Vatican. What this film does
is help us gain historical perspective on how long conflicts relating to the radiation can drag on
throughout the years. The situation with the Vatican is still ongoing. They are going on trial for
manslaughter. This is something that is very old but persists today.
Essentially, we don't have epidemiological evidence obviously, on the impact of 5G towers because they
are very new and sometimes they are not even activated yet. Some of these units can function in one
mode or another. The experience we have is from towers of the past. I have assembled some
publications. There is a publication here by Michelozzi, 2002 that describes childhood leukemia up to a
distance of up to 6km from the powerful Vatican radio transmitter. The Vatican needs to broadcast
throughout the world. They have very interesting antenna. They are huge structures that rotate. Of
course the intensity of this radiation is very large which is why it seems that the epidemiologists have
detected health effects as far as 6km away. This is an extreme area of antenna not representative of cell
phone towers that we have in our immediate environment.
Abrami: That's an important point. They are their own little country. Do they have standards?
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Heroux: They have standards of radiation that are different than those of Italy. Of course the radiation is
coming across the border which is a problem we all have. Radiation from one in multi-family dwellings
impacts the neighboring family. This is not an uncommon problem. In the Vatican, you have a very
powerful transmitter with a very small population of people affected because it's mostly small cities and
countryside around these huge transmitters. But epidemiologists observed very high relative risk.
Abrami: Can you give us a sense though of how intense?
Heroux: It was at the legal limit for Italy.
Chamberlin: These are under 30Mhz aren't they?
Heroux: Yes. There are a number of antenna there and the relative risk was 7 for lymphomas and for
non- Hodgkin's lymphoma and leukemia 5 times. So there is very high intensity and very high relative
risk of these diseases.
Then Santini in 2002, this is a study that is remarkable in that it documents a number of health effects,
not only cancer but other neurological effects. But, it is weak because it was based on questions asked
of people, which is always much less reliable in terms of epidemiology. Of course the investigators tried
to do the best they can. This is not like the documentation of say a tumor but they said up to 300
meters, they could observe neurological effects from cell towers.
In 2010, Khurana provides a review of 10 base station proximity and neurobehavioral effects and
three investigations of cancers. He reports that 8 of the 10 studies report increased prevalence of
adverse neuro-behavioral symptoms or cancer in populations living a distance of less than 500 meters
from base stations.
Probably the most convincing evidence, I would say is from Dode in Brazil 2011. This is a study that if
you read it through, is performed in a way that is very open handed. They used tumor classifications and
sub-classifications from the international committees. They used public health records. They had the
cooperation of utilities as well as many universities and their documentation is very detailed. So, if one
is to be given weight, it should be that one. Essentially, they came to the conclusion that yes, they can
document these effects.
What is most striking, is they can also detect that if they install a cell tower near your home, within two
years, is when you will get the maximum incidence of cancer. They documented cancer because, unlike
neurological symptoms, cancer is not subjective especially when they are quantified by histology and by
international classification. This report of a large city in Brazil with a large population which is known to
have a public health system that documents. Within 500 meters of a base station and there are many
base stations that are documented, you will have increased incidences of cancer. These exposures are
much smaller than the FCC limit of course. They have a range of exposures that they measured within
the study. I think this, needs to be read.
In 2020, Pearce essentially provides the most recent assessment. Each of these studies of course goes
through a bibliography of its own. It promotes, again the 500 meter setback to limit future liabilities of
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the cellphone industry. He is talking mostly to the cell phone industry and saying if you want to limit
your liability in the future, you should respect the 500 meter distance.
In 2018, I have an article by Affuso which examines the economic impact on home values. If you are
within .72 kilometers or 720 meters of the base station, your home value goes down by up to 9.78%. As
the NTP studies are more widely known in the population, this is probably going to increase.
We do have studies of high intensity that have documented cancer at long ranges. We have studies over
large populations that also confirm the 500 meter danger zone. In other words, your health will not be
the same in terms of cancer and neurological impacts if you are within that zone. So when we are
considering 5G, we will be considering antennas that apparently will have more powerful output
because of this radiation goes less well through oxygen and water. It has focused beams to go through
structures to attain people who are hidden. So as a result, exposures will be more transient, more
focused and more intense. But we don't have epidemiology on that. We would have to wait 10 or 20
years before we have the information. Sadly, the only information we can rely on is information from
the past. I think that anyone should read the study on Belo Horizonte, the third largest city in Brazil will
see that this study was done very carefully and in my opinion is very convincing.
Ong: Dr. Heroux, in the Brazil study, was there any comparison between the pediatric incidents and the
types of pediatric cancers before installation of these towers and comparison of those rates and
incidents after these installations?
Heroux: I believe that all the cancers were classified according to international standards so some of
these classifications are specific to pediatric but the control were regions that had no cell towers that
were investigated at the same time.
Ong: But you mentioned earlier that the Belo Horizonte have very good cancer registry. So for the same
region, you will have the same data prior to the installation of towers vs. the rates after installation.
Heroux: I believe their data covers approximately ten years. I believe that they used the reports within
those ten years and discriminated between those near cell towers and those that were not.
Abrami: Well, what I think he is trying to say is, are there other reasons for this higher rate of cancer and
filter out the other effects that may cause it. I understand what you are trying to say.
Heroux: I guess you would have to read the study to satisfy yourself about these details.
Sherman: Getting at one of Senator Gray's concern, to fully understand. This study was done with
presumably 3G and 4G towers. Is that right?
Heroux: Yes. Those are similar to ones that you would see here.
Sherman: One of the things that you mentioned was that the peak cancer effect was within two years.
So we wouldn't have to wait twenty years to know. If we used this as a springboard for what is
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happening with 5G, it would be interesting to do a study in a city that has already implemented 5G then
you might be able to do the before and after registry.
Heroux: Yes, ideally but the wheels of government and science turn rather slowly in a sense. This was
done in 2010 but this technology is about 10-15 years old already...before you get the agreements
between the number of universities and public health systems and so on and so forth. But they have a
record of when the antenna was installed and when the cancer occurred which allows them to come up
with this statistic.
Abrami: This is the thing that has been nagging me about the small cell tower. We just don't know. That
is the whole premise of this. We just don't know and how do we get at that? Clearly, there is not money
supporting research.
Gray: Part of what we are hearing is that if there is a 500 meter limit then the amount of radiation is
very important in to the rates of cancer. I am accepting your data at face value okay? Now, we look at 5g
technology. We have smaller towers. We have less power. So that 500 meters may be 275 feet. You talk
about being able to submit a minority report. If I was to try to do the peer reviews about all the different
things that people have presented to this, I would be talking about billions of dollars. I go back to 1960's
when I was watching 60 Minutes talking about the EMR coming off high power lines going through the
Midwest affecting the cattle that we eat and we are all going to die because of it, okay? Again, I am just
trying to get you to stay on topic and the 500 meters... yes. There may be a component in there that the
amount of radiation nearness to it, you said 30 Mhz and below and 5G starts at 30Ghz and above...all of
these things affect what we are supposed to be looking at and the results we are going to get. The one
study that we were given that they talked about it wasn't fair to do whole body radiation on a particular
animal because that would have a much more devastating effect and all you have to do is find one cell
within that whole body that would react.
Abrami: we are not there yet. We are still working on this.
Sherman: We have had a lot of scientists around this table. I think nobody is pretending to come to any
conclusions at this point. But in science and in healthcare, we try to look at all available data which is
what we are doing. Some is going to be historical data that comes from other RF sources. I think it's
perfectly reasonable to look at other RF sources especially since those aren't going away. 5G isn't
coming in and replacing all of this as far as I understand it. 5G is coming in on top of 3G and 4G. So, I
think it would be a little bizarre for us to look at 5G in a vacuum without the understanding of the
current environment and the data on the current environment. I think with a cautionary tale that I hear
coming from Senator Gray is that doesn't necessarily mean that we can extrapolate data from 3 and 4G
and say that this is going to be the impact of 5G. Study commissions go where the data takes them and I
think we are doing that. I haven't heard of anybody coming to any conclusions yet. I think we are still
looking at data.
Ricciardi: I just wanted to mention that I believe I forwarded Rep. Abrami information on a town in the
Netherlands that put in the 5G, the town became rapidly ill. I can go back and find that. That is 5G and
that is evidence on human beings. And that is on topic.
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Chamberlin: That was a small study as I recall.
Ricciardi: Yes. They put it in and very shortly after the whole area became very ill.
Chamberlin: True. But somebody could claim that maybe it was a water problem as well. I am interested
in following up on that.... particularly, in places like South Korea where they have installed on a larger
scale. We need to keep our finger on the pulse there. If you find any more of those, forward them to the
rest of us.
Heroux: Can I have one last remark? Essentially, the tower question of course takes care of the general
environment but in relation to the new phones which will also have this and possibly more radiation
from these phones. The phones could be altered in a very simple way to simplify things for users in
terms of health impacts and even perhaps for industry. These cellphones are immensely useful. But one
of the problems is that when we hold them close to our body, they tend to over expose us to radiation.
There is all this controversy around the proper SAR. They can put 5 cameras and 10 antennas in the
most recent phones.
What you can do is put a proximity detector in a phone so that when it comes near to your body, it
doesn't work and doesn't radiate any more. This would mean that you could use your phone exactly as
before but the risk of overexposure of the phone would be severely reduced, in my opinion. You would
cut out all the extreme radiation putting it in your bra, your pants near your genitals or near your head.
This is something that is not done right now but technically it is far from impossible. It's relatively easy
to put in a distance detector and you would be instructed by your phone to expose yourself less. I think
from the point of view of industry that if it is told by government to do that, they don't incur any more
liability. If they do this on their own, their lawyers will tell them...hmmm.. you are admitting to
something that may not exist. This is a problem. But if it's imposed on them, you are solving a problem
for them as well.
V. General Discussion:
Abrami: Thank you. So I have amassed a list of potential speakers. I have reached out to most, but not
all of them yet. If there is no comment on the paper, it means I have not talked to them yet either by
phone or by email. Dr. Carpenter we will hear from in a minute. Dr. Martha Herbert can do something in
April or May. Dr. Sharon Goldberg has been in conversation with Michelle. You can read through the list.
I wanted to talk to Hardell because he is the former WHO fellow who is retired that was involved in this
whole thing. Kelting is retired and will be our speaker next month. Dr. James Lin, I am really interested
in. He is an electrical engineer but his appointment is in a medical school. He has published a lot in IEEE.
I talked to him the other day and told him he could do it by phone. He doesn't like to do it that way and
wanted to know if we could pay for his travel. I said, well, you don't understand. This is New Hampshire.
We don't have a budget! So he is thinking about it. I have not contacted everyone yet.
Dr. Chamberlin, I was going to talk to you if you have any need to have a fellow electrical engineer come
in for any kind of seminar series, maybe we could tie it to that.
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Chamberlin: I will check into that.
Abrami: I think this guy is worthwhile having. I have checked some of his papers. They are very technical
papers that he presents. I know that there are some others names that aren't on this list that people
are suggesting to me. I am going to warn you Senator, that Carpenter may be a little broad so bear with
us. He is aware of some legal actions in NY State. I know it would be great and I am trying to get more
focused on the technical. With this group, I think we know what the issues are. We understand the
science here.
We can start the discussion about the next meeting. March 6th won't work because Dr. Sherman, Sen.
Gray, and I are on the Seacoast Cancer Cluster Commission together that day. Beth told me that she
cannot make the 13th. On the 20th, Senator Sherman will be out of town.
Gray: On the 6th, you could do an afternoon meeting because the Cancer Cluster meeting will be over.
Sherman: I have a Seabrook working group on the opioid crisis so I can't be here.
Abrami: We could do the 20th. Out of fairness, I want to make sure we have Beth at the table.
Garod: I have a jury trial the week before that. There is a possibility it may not be over.
Abrami: Brandon, did you ever connect with Theo or whoever?
Garod: After you sent the email, I responded to her but have not heard back. I encouraged her to reach
out to me.
Ricciardi: So, you did reach out to Theodora? Ok.
VI. Dr. David Carpenter-University of Albany "What is 5G and what do we know about the health
effects of 5G?"
Abrami: David, welcome. You are in our meeting. We have someone who will move the slides for you.
Please introduce yourself.
Carpenter: I am David Carpenter. I have two titles here at the University of Albany part of the SUNY
system. I direct the Institute for Health and the Environment which is an interdisciplinary research
institute that is a collaborating center for the World Health Organization. I am also the Professor of
Environmental Health Sciences and the former Dean of the School of Public Health. I have been
involved in issues related to electromagnetic fields for a long time. I first came to NY as the director for
the state health Wadsworth laboratories. Two weeks before I arrived in New York, there was a
settlement between the state Public Service Commission and the State Power Authority asking the
question was there an elevation in cancer risk by high voltage power lines? As a new guy on the block, I
was given the responsibility of administering that program. We had 15 research projects funded by state
utilities. At the end of that project, we did find elevations in childhood leukemia in children living
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exposed to high magnetic fields. I became the spokesperson for New York State on that issue. Once you
touch a controversial issue like this, you never escape. It's never been my personal research but I have
been involved in this and published extensively on it. I have been on national and international
committees.
Abrami: What did NY State do about that?
Carpenter: Effectively nothing. They did establish a standard for the magnetic field for the edge of Right
of Ways. But they determined that standard by measuring the magnetic field at the edge of Right of
Ways and the standard was the highest one there so there wouldn't be any new magnetic fields greater
than those that were existing. This is really one of the problems with RF fields. We are all so dependent
on things like electricity and communication frequencies and nobody wants to restrict use of it and
hopefully not make it worse than it presently is. It's very difficult to restrict use.
Electromagnetic Spectrum:
Let's go to the second slide, the electromagnetic spectrum. The form of EMR that most people know is
visible light. At higher levels than that, we have the ionizing portion of the spectrum that includes x-rays
and gamma rays and these have enough energy to directly damage DNA, cause cancer and birth defects
and that sort of thing. Below the visible light, we have infrared radiation which is heat from the sun.
Without that, life on Earth would not be possible. Below the infrared, we have the communications
frequencies. It is important to note that the 5G that is being proposed is just below the infrared. It's
Gigahertz frequency. The electromagnetic spectrum is all packets of energy with different frequencies.
The higher the frequency, the more energy it contains. But the frequency is important. At the left of
the slide, the extremely low frequency that's the magnetic fields associated with electricity that I was
originally involved in.
Radiofrequencv (RF) EMFs:
The point is that these radio frequency EMFs are communication frequencies, everything from radio to
television to cell phones to radar. This exposure has increased enormously in the last number of years.
Now we have Wi-Fi everywhere. We have smart meters put on many of our homes. These are meters
that use RF waves to transmit your use to the utility. In the future, there are going to be ZigBee drives in
your refrigerator, dishwasher and every appliance and it's going to communicate your electricity use to
your smart meter. That's' going to make the kitchen and laundry room particularly hotbeds of exposure.
Driverless automobiles will use RF fields to see the car ahead and will enormously increase exposure to
these things. The microwave oven uses RF fields and most of these frequencies are in the microwave
range. Clearly, if you can cook your potato with a microwave, there is potential harm from exposure. But
most government agencies, certainly the Federal Communications Commission (FCC) has the position
(which I think is wrong) that there is no hazard from microwave exposure if it is at an intensity that is not
sufficient to cause tissue heating.
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RF in the Ambient Environment:
It used to be that RF environment was really radio and television. In the past few years we have
increased the RF in the ambient environment enormously and with the imminent rollout of 5G there is
going to be a great increase in human exposure. One punchline is that 5G has not been studied. It has
not been around long enough and we don't have any population of humans that have been exposed so
that we can determine whether it's really dangerous or not. We do know a lot about our existing 3G and
4G. As these generations develop, they go to higher and higher frequencies. Our cellphones, Wi-Fi,
smart meter are all 3G and 4G frequencies. What does this sudden increase in RF exposure suggest
regarding human health?
Health Risks to Humans from Existing RF:
We know very well that extensive use of a cellphone held to your head increases the risk of cancer.
Gliomas particularly, less so other forms of brain cancer, and particularly glioblastoma which is a very
malignant form of cancer. This is the cancer that killed Ted Kennedy, Beau Biden, John McCain, the
lawyer in the OJ Simpson case. I am not saying that it was definitely cell phone use that caused all their
cancer but these are people who undoubtedly used cell phones a lot. The cancers only occur on the side
of the head that people use the cellphones most of the time. In addition to the glio cancers, there is a
Schwannoma tumor of the auditory nerve that we see commonly called acoustic neuroma. It's not a
cancer but a tumor that grows in the bony cavity in the ear and causes problems. There are some
elevations in cancer of the parotid gland on the cheek and the thyroid gland. It seems likely that
excessive exposure to RFR at non thermal intensities increases the risk of a variety of cancers and what
is really critical is which part of the body is exposed.
National Toxicology Report/Ramazzini Intitute Study/Other:
Now the International Agency for Research on Cancer (IARC) which is part of the World Health
Organization (WHO) has rated communication frequencies as possible human carcinogens. This was a
number of years ago and one of the reasons why it wasn't a stronger reading in that there hadn't been
clear evidence that cellphone frequencies cause cancer in animals.
National Toxicology Program (NTP) which is part of the National Institute of Health (NIH), just last year
came out with the results of a two year study. It demonstrated that rats exposed to cellphone
frequencies develop schwannomas of the heart.
Abrami: Just so you know, we have talked to those folks.
Carpenter: Ok. Let's go on. The Ramazzini Institute did a similar study but at much lower intensities.
They found exactly the same thing. We now have good animal evidence in addition to human evidence.
There are other health effects that are well documented, particularly reduction in sperm counts and
infertility in men from abnormal sperm and some evidence of spontaneous abortion and premature
birth in women with excessive exposures. There is some evidence for cognitive alteration in children, if
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they are on their cellphone too long. It's difficult to understand if it's a direct effect of the radiation or
because kids aren't sleeping because they are talking all night.
Then there is the very controversial but pretty clearly real problem with Electro-hypersensitivity. Some
people, by no means all become the best way to say it is "allergic" to the RF fields. They develop
headaches, nausea, vomiting, and a sense that the brain isn't working properly. Sometimes they have
heart palpitations and a general feeling of ill health. This has been seen in adults and now fairly
frequently in children in school environments where there is intense Wi-Fi, much more controversial
than brain cancer.
Emerging wireless technologies:
5G (5th generation cellular technology) as I have said, is RF but at a higher frequency that we have at 3G
or 4G. It's being promoted widely just about everywhere. This is the whole concern of the Trump
administration with Huawei the Chinese company. The idea is that 5G when fully developed is going to
just change the way that life on Earth is done. It's going to be the Internet of Things, Smart Appliances,
Smart Cities, certainly self- driving vehicles and wearable devices. A lot of hype about this and a lot of
sense that somebody is going to make a pile of money and that this is going to be good for
communication at the much faster rate than we have currently with 3G/4G. The 5G frequencies will be
in the Ghz range which is higher than current 3G/4G which are lower than lGhz, in the MHz range.
Ultimately, the 5G can be up to 70 Ghz which is almost at the frequency of infrared radiation. It will be
lOOx faster than 4G, potentially add new jobs and a lot of economic growth. It's a higher speed greater
capacity.
Limitations of 5G:
The problems with 5G are several. Because it's at much higher frequency, the waves do not penetrate as
far as the 3G/4G waves do. They are easily blocked, even by weather. The radiation will not penetrate a
building. It will not go through glass and won't travel so far. This is a real problem so as 5G is being
implemented around the country and world, instead of the cell towers that have ranges of over
2,000km, the 5G will require mini cell towers to be placed in front of every 6-8 houses in urban areas.
The 5G will only have a range of 20—150 meters not kilometers. That means that as these are placed
everywhere, you are not going to be able to walk down a side walk anywhere without being
continuously exposed. Now if you are in your house, since the beam won't penetrate the house, that's
probably a good thing. Now one of the real problems however, as we are rolling out 5G, our current
infrastructure is 3G and 4G. These mini cell towers places all along the street are not just going to be
exclusively 5G, they are going to be 3G and 4G as well. While we haven't really studied health effects of
5G, I have already told you of health effects of 3G and 4G. This is going increase the exposure to 3G/4G
dramatically. These mini cell towers are going to be everywhere. That is a real problem totally
independent of the question what are the hazards of 5G.
Abrami: We have talked about these things in our commission. We are trying to get at what is in those
towers. It's really about the power. Let me ask you though, the issue with the small towers is you get
every company with different strategies of 5G. Can you discuss that a little bit?
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Carpenter: Well, I am not an expert on that. I know that each company has their own power also they
don't share their information very much. It is very difficult to get that information. They really don't
want the other companies to know what they are doing. I can't really answer that question. But I do
know that all of the ones being implemented right now are not exclusively 5G. I think the expectation is
probably pretty good that 5G is not as dangerous as 4G. That's because 5G is not likely to penetrate the
brain. It's not likely to cause brain cancer because it's going to be blocked by the skin. Now that raises a
whole series of other questions. What is going to be the effect on the skin? Is there going to be an
increase in skin cancer? Is there going to be alteration of sweat glands? We don't' really know that
answer. Again, my big concern is the greater exposure to the 4G frequencies which we know to be
hazardous in extreme exposure.
Abrami: This is the discussion that we are having. The towers are lower to the ground. They are right in
front of your house. There are science issues and all that but there are emotional and aesthetic issues
that people are pushing back on. Our understanding is that it is less power and we are trying to grapple
with how much damage compared to a large cell tower.
Carpenter: In the large cell tower, there have been studies showing increase in leukemia in people who
live close to the large cell towers. But the large cell towers direct the beam at the horizon. That's for the
purpose of having a reception over a very long distance. These small cell towers close to the ground are
going to have beams directed right at everybody. It's going to dramatically increase exposure relative to
that you would get from a large cell tower.
Abrami: It's the 1/R 2 rule right? The closer you are to the tower....
Carpenter: that's right. The question is ...whether the beam is directed or if it's like a radio transmission
tower which is 360 degrees. Our current cell towers have a focus beam at the horizon. For some reason,
people living very close to a cell tower probably get less exposure than people living some distance away
where the beam then sort of spreads down. These mini cell towers on a lamp post or wherever they are
on the street are going to be very close to the ground level and it's going to be impossible not to have
elevated exposure.
Abrami: Usually with cell towers, there is a radius around and there is nothing there. There are plenty of
studies showing the fire station concerns but these small cell towers are going to be right on the street
and low to the ground.
Carpenter: yes. I was actually in California for the Fire people opposed to towers on every fire station
just for that reason and they did block that plan.
Sherman: On these small cell towers that will have 5G and 4G, is it a lower power 4G since there are
going to be more and they are going to be closer and there is not going to be the same need to shoot at
the horizon? Or is it the same power as the big towers?
Carpenter: I don't actually know the answer to that question. I suspect it's going to be a lower power.
But, I don't actually have good knowledge of that.
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Abrami: Let's keep going.
Carpenter: The issue is there is no real research on 5G. There are a few animal studies now. Again like
any new technology, there are people making outrageous claims for hazard and others that make
outrageous claims for safety. So, I think we just don't know. But the issue of cancer from RFR, that is
very strong. The issue of effects especially on male fertility is very strong. The Electro-sensitivities are
certainly going to increase as people are exposed more.
Carpenter: Is there anything uniquely bad about 5G? I think the answer is no, other than the fact that
the way it's being implemented is going to increase exposure.
Who is protecting us?
The FCC has no health expertise. I visited them several years ago trying to push them to at least have
some cautions in their recommendations. They basically said, we don't have any health expertise, we
depend on other agencies for that. Then they don't have any other government agencies that are
pushing them. I am actually a plaintiff in a legal case against the FCC for their standard, which says that
there are no adverse health effects except those caused by tissue heating. That simply is not true.
Abrami: Can we pause on that for a second? Which suit is that? There are several out there now.
Carpenter: Well this is all fairly recent. Bobby Kennedy is the lead attorney on this suit. But there are
several out there. It's really sort of outrageous that the Federal Communications Act of 1996 specifically
prohibits placement of any cell tower based on concerns of health. This is a real problem for many
localities and states because this is federal law. You can object for other reasons but not for health
concerns.
How Strong is the Evidence of Harm?
The evidence is very strong for 3G and 4G, especially for cancer and effects on male fertility. It is less
strong on some of the other things but certainly enough evidence to merit concern.
There are so many sources of RF and the average rate of exposure to RF has increased over time. Since
2003, there has been an enormous increase as we have gone to just about wireless everything. The
latency for many of these health effects, especially cancer is going to be long. We know from ionizing
radiation that the latency is 20-30 years. One big concern is we roll out all these new sources of
exposure, what is going to the long term impact? We are seeing an increase in glioblastoma risk in the
US and around the world. Not so much in other brain cancers. Actually, some of the other brain cancer
rates are going down. But, there is reason to be concerned.
The conclusion is with 5G, you can download your movies faster. There may be other benefits. It is not
obvious to me what the other benefits may be to the individual, maybe to business, maybe to
government but it's just that we are rolling out 5G very rapidly without any good information as to
whether the risk might exceed the benefit.
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Abrami: Well, thank you on this. Let's talk about NYS. That is where you are based. Are you aware of
anything going on legislatively in New York? I thought I read that they may be thinking about forming a
commission like ours.
Carepenter: They haven't gotten past that. It's being rolled out across the state and there are a number
of legal actions. There have been a couple of meetings in the state assembly on the issue, but no
significant legislation has passed. There is a growing concern. It's interesting, one of the Vice President's
here at the University of Albany, asked me to give a talk for a public group and he knew nothing about
the issue until they put a mini tower in front of his house. That seems to be happening around the state.
Little information, if any and then the mini towers are placed and implemented and that gets people
pretty concerned. There is a fair bit of angst among the population but only the population where it's
being put out otherwise there is very little information.
Abrami: I just received something about Huntington, Long Island. I had seen this before, a public hearing
in their town council. For five years they have been complaining to the town officials and they are very
concerned because these small cell towers are going up in their community and a lot of people are
pushing back. We are seeing this across the country.
Carpenter: Sure. It's really across the world. I am being taken to Australia to talk about 5G this summer.
Abrami: We just heard that Switzerland put a hold on 5G until they understand the science a little
better.
Carpenter: Yes. I think one of the concerns is that there seems to be absolutely no benefit to the
ordinary individual maybe to business and industry. Other than the fact that you might be able to
download a movie more rapidly, what's the benefit?
Abrami: one of the things that I saw was autonomous vehicles but it turns out that the industry is not
going in that direction with the little towers along the road. It's going to built into the cars.
Carpenter: It's going to be built into the cars and likely to be lower frequency.
Ricciardi: I just wanted to clear up a question I have or make sure I understand it correctly. Although our
commission is tasked with the health effects of 5G, what I understand and correct me if I am wrong,
because it will actually be placed approximately every few homes and because it cannot work
independently and has to work with 3 and 4G, what's going to happen is whether we know much about
5G or not, the fact of the matter is everyone is going to be living under a cell phone tower and being
exposed to radiation continuously which can heat tissues over time. Is that correct, Dr. Carpenter?
Carpenter: Well, the last part I think probably is not correct. If you have low intensity to these, there
may be a level of heating that can't be measured but you would be constantly exposed but there would
not be any measurable increase in temperature. That's the debate with the FCC because there is this
enormous amount of information showing health effects at non thermal levels. But, I don't think
because you are continuously exposed at a low intensity that there would be a measurable increase in
temperature.
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Ricciardi: Okay, but you would be exposed continuously which would potentially precipitate other health
effects.
Carpenter: That's correct. I am sorry I probably should have prepared a more technical presentation. I
didn't realize that you were so well informed on this. We have a pretty good idea what the mechanism
of these damages is. The primary mechanism is that non thermal levels of RFR generate Reactive Oxygen
Species (ROS), commonly known as free radicals. If you remember in the NTP study, they demonstrated
direct DNA damage in those rats and these were clearly non thermal intensities.
There are many nasty things that generate ROS. In fact, our body generates them just as part of the
normal metabolism. We also have a whole series of enzymes in our body that are there to protect us
against them. Very clear evidence that non thermal levels of RFR cause the generation of these ROS. If
you are exposed continuously, then you have a continuous generation of those ROS. You don't need the
temperature rise, to cause harm. The ROS can damage proteins, lipids, carbohydrates and DNA. The
evidence is quite strong that this a common mechanism that then leads to a whole variety of other
changes. For example, changes in brain metabolism and blood flow to the brain and whole variety of
things. There is a good body of evidence that allows us understand how you might get damaged from
continuous exposure to RFR at levels that don't raise body temperature.
Sherman: Just a quick question. What you are describing is the epigenetic impact of non-thermal RF
levels. You are actually changing the DNA. Do you know of any evidence of people who are more
predisposed like family history like genetic makeup? In other words, is there anything in your genetic
makeup that would predispose you to increased risk of being within an RF field?
Carpenter: I don't know of any real study on RF fields. There is a very interesting study on the magnetic
fields from power lines. There is a study on electricity from China I believe that did look for different
genetic traits in children that developed leukemia from being near power lines and children exposed
who didn't develop leukemia. They did find there is a genetic susceptibility factor there. I would be
quite surprised if that weren't also the case with RF but I am not aware of anyone that has really studied
it.
Wells: On one of your slides, you talked about current 3G/4G cell towers having a range of 2,000 km. I
just wanted to check on that because my interest is not just on the transmitter power but the power
over the area and what that means in terms of the intensity in watts per square meter to which people
will be exposed. So, 2,000 km is the correct figure for 4G?
Carpenter: Well, yes. That's the correct figure. Of course not every cell tower has intensity that goes that
far. For example, in most urban areas you don't have that intensity. But in rural areas and so forth, you
have a higher intensity. That's also true when you use your cellphone. If you are a long way from the
tower, your cellphone automatically increases the intensity of the signal it sends back to the cell tower.
That 2,000 km is sort of the upper limit of a cell tower.
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Wells: If I can just follow up on that. You talk about 5G only penetrating skin. I was wondering if you
would comment on current SARs on Watts/kg versus intensities of watts/square meter. Which do you
think is the more appropriate way of looking at exposure?
Carpenter: well, certainly with 5G watts/square meter is more appropriate metric because we have no
reason to believe 5G is going to penetrate beyond the skin. The 5G is actually being used a little for
crowd control. If you have sufficient intensity with 5G, of course you have tissue heating. You can direct
a beam at someone who is trying to escape the police.
Abrami: Rep. Wells is all over that one!
Chamberlin: So, I have a question about the strength of the evidence that exists. Since getting on this
commission I have been reading a lot of papers and I find that there are lots and lots of papers out
there. You can't deny that there is a risk of harm. It's also somewhat overwhelming, the number of
papers that exist. Have there been attempts to bring that all together to these meta studies that you
mention? Where can I get access to them with high statistical confidence that a problem does exist?
Carpenter: That's a good question and it's a complicated one. The place where most of the evidence is
put together is in the Biolnitiative Report. I was the co-editor of that. But that report was criticized by
just about every national and international body, as being selective. In fact, it was not selective but we
have not had effectively any government agency with real credibility and that's true around the world
acknowledge the strength of the evidence that I think see and I think that you see. The problem is, first
of all you have a powerful industry that doesn't want their product tarred as being dangerous. Secondly,
we are all so happy with the benefits that come from modern technology that we don't want to hear
that it's potentially harmful. I am frankly baffled by the antagonism that the Bioinitiative Report has
received. It was criticized as not being peer reviewed. Well, the original report wasn't peer reviewed
but almost everything in it was published separately in peer reviewed scientific journals and passed
review. But it remains a very controversial subject.
Abrami: Can you send us that report? The chair has been corrected. We already have it.
Carpenter: It was originally published in 2007 and updated in 2012. There have been some additional
updates in 2014. It's huge and much more than anybody ever wanted to know and I think the individual
chapters on specific subjects. I think there is something like 3 or 4 thousand references in the report.
Abrami: Are you the prime author on this?
Carpenter: No. I was a co- editor. I had the major role in writing the public health chapter. But each of
the chapters was written by other people and actually Cindy Sage was my co- editor and was the power
behind it but I had a major role in identifying who would write chapters and so forth.
Chamberlin: As a follow up question, can you give us the sense of relative risk? Is the relative risk
something like 1.2 or something like 10? And do these have associated low e values?
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Carpenter: Well, I am involved in all kinds of hazard investigations. My major research actually is PCBs
and dioxin and pesticides. Some of my colleagues wouldn't agree with me but I don't think the relative
risk here is anywhere near as it comes from things like smoking and chemicals that are toxic but one has
to be careful about this because again, our exposure has increased so dramatically so recently. We have
evidence in links to cancer but in latency being long, what's going to happen twenty years from now?
You can look back at smoking and you can look back at PCBs and DDT and these things in the 60's and
70's were thought to be quite harmless. Now we know they increase the risk of all kinds of diseases.
That's why that last slide I mentioned the Precautionary Principle. At the moment I don't see that the
relative risk comes anywhere near the risk we have of other kinds of exposures but I am not sure that
it's not going to be viewed as much greater in the future. If you put a mini cell tower in front of every 8th
house, in every street in the US, who knows what the outcome is going to be in 20-30 years? The
cancers that we see are relatively rare. But they are also fatal when you get them.
Sherman: Dr. Carpenter, I am also a physician. I am a state senator here in NH. I sense some frustration
in your voice. One of the issues that we have been grappling with which is what Rep Abrami talked
about is PFAS how it's in our drinking water. But the similarities between both of these is that we have
very powerful and well- funded industry that is basically dismissing all science that is raising alarms in
both of these areas and one of the big concerns that I have is that well- funded would not be a good
description of the NH legislature and certainly not the people who are pushing back against industry.
You are in an academic setting and you are doing some really good work on this. Do you have any
suggestions on how we can lift up the Precautionary Principle before everything is installed and in place
and we have to wait 10-20 years to know that we have just done in an entire generation? Do you have
any models or any communities that you worked with that have been able to mitigate the influence that
some of these companies so we are not regretting down the road that we did not provide at least some
precautions as we move into this new era of RF exposure?
Carpenter: well, I certainly work with a number of communities that are trying to do that but I can't say
that it's been very successful. The big barrier here is the 1996 Federal Telecommunications Act. There
have been some communities where industry has sort of backed off hoping that the angst will go away
but in others, the telecommunications companies has basically taken legal action on the basis of the
Federal Communications act saying we have the right to put these in and you have no right to object to
it.
I think what I would really like to see is that provision in the Telecommunication act being invalidated. It
is outrageous that communities and states are prohibited by that regulation from opposing this kind of
development. We don't have that similar kind of thing with chemicals like PFAS and PFOA. This is a very
strange situation where we are prohibited from protecting the health of the public. You can debate how
hazardous this is but it should not be up to industry just doing anything it wants to and public and other
forms of government having no ability to block it.
Abrami: Let's go back to the Kennedy case. What are the two sides on this? Is it the FCC?
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Carpenter: The case is that the FCC by virtue of having this philosophy that there are no harmful effects
other than those caused from tissue heating is causing severe harm to the US population. The plaintiffs
are a public health person and a mother of a child that died of a brain tumor. There are a couple of
people that have Electro-hypersensitivity. The goal of the suit is to get the FCC to tighten the standard
of exposure for RFR.
Abrami: we are probably the most lax of most countries, right?
Carpenter: Oh yes, by far. There are other countries that are equally as lax but we are way more tolerant
of exposures than others. The Russians have had the lowest standards for the last fifty years. Now, I
don't know that they reinforce it that much. Our standards are just ridiculously high.
Abrami: What court is this going to?
Carpenter: I don't know. It's directed to a federal court but I am not clear where it's going to go yet. This
has all happened in the past couple of weeks. There are other suits pending too.
Abrami: The Environmental Health Trust that we head from a month ago. They have a suit as well
against the FCC. As a commission, we want to talk to the FCC and also where they get their guidance. If
the FCC says well, we listen to the FDA and FDA is saying there is no problem, I think that's part of the
suit the EHT is involved in. But IEEE is setting standards, right?
Carpenter: Engineers and electricians setting standards for health is pretty ludicrous.
Abrami: We would love to talk to someone from the FCC but that is proving to be a bit of a problem and
the FDA. EHT said what we should do is write a letter to the FCC with questions and the same thing to
the FDA with questions. They have been known to respond. I think we need to do that. If we can't bring
in a human being to testify, we can at least say we tried to elicit comments from the FCC. What I am
suggesting to everyone here, send me your questions. I will sort through them and we can talk about it
for the next meeting.
Carpenter: I think that is a very good plan.
Abrami: If you have any questions, send them to me, too. Someone in the back of the room would like
to talk.
Public speaker: I have one quick question. For all the doctors in the room, I recently saw a video with Dr.
Lena Pu who had done a blood test on a teacher who was in a classroom with Wi-Fi and the blood test
indicated after a day of exposure that the viscosity and quality of her blood had basically coagulated like
it was cooked. Would it be simple to do a study on people who say for a week have not been exposed to
any cellphone, Wi-Fi, television and do the blood test and then test again after exposure? I am
wondering if there are any other parameters besides cancer that should be looked at. I think blood
quality is pretty important and leads to all kinds of other stuff.
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Abrami: I thank you for your comment. We have been trying to explore the different research that is out
there. Does anybody recall anything on blood?
Heroux: Yes. The rouleaux formation is very well known. Even short term tests can show if you expose
blood to EMR and you have some but even if you show that to the FCC, they will say...so what?? This will
dissipate after some amount of time and the mechanism for that is probably that you have free
mitochondria in the blood actually. It's very new data. You have a lot of mitochondria floating freely in
the blood and they help the red blood cells to coagulate together. There is plenty of that kind of
evidence. What does it mean for the people in that class? If no one is willing to take that step, we are
wasting our time.
Abrami: In the classroom situation, we are talking about routers everywhere. One of the people who
testified for us when we got the bill passed was Cece Doucette who years ago was involved in getting
wireless technology into the school until she realized, what have I done? Now she is working to try to
undo some of it and have safer technology. There is no reason schools need these routers. They can be
hardwired for instance.
Carpenter: With hard wire, there is no exposure whatsoever.
Abrami: And actually speeds are better.
Sherman: Speeds and reliability.
Sherman: Do you know any blood impacts Dr. Carpenter?
Carpenter: There are colleagues in Paris that have done some very good work on measuring some things
in the blood that are markers of people that are electro-sensitive. They focus mostly on this electro-
sensitivity. Again, all the markers they are finding are related to these Reactive Oxygen Species (ROS).
Dominic Belpomme in Paris is the one who has done that. We have published with him and I can send
you the article with that information and I would be happy to do that.
Woods: We already know that blood can be temperature sensitive. There's cryoglobulin anemia in
people where if you put an ice cube on their skin, they get hives. This is a known entity and it's not
everybody. Again, it's a genetic variation. But it bespeaks a broader picture in fact that a lot of the
studies at least to my eye have been bulk tissue or bulk material investigations. What we are wrestling
with now is getting down to the molecular level instead of bulk tissue, we need to look at cellular and
molecular levels and that's what we are hearing here and what we have been surmising where we need
to go. We don't have a lot of these good molecular studies although we know mechanisms clearly can
take place already, like you mentioned the mitochondria and we have talked about other issues before
that get away from what the IEEE looked at and getting down to the molecular level. We are trying to
make that transition.
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Sherman: I have one question. We are mainly interested in human health impacts but we have heard
some rather frightening studies on environmental impacts. Can you comment on those Dr. Carpenter if
you have any expertise or knowledge about environmental impacts, specifically of 5G but since this is
going to be ubiquitous, the concern is this is also going to be 3G/4G... bees, insects, plants. Any
thoughts?
Carpenter: Well, there is some evidence for effects on bees for example, some concern that the demise
of the honey bee may be related to the RFR distorting their ability to find their way back to the hive.
Again, that evidence is somewhat weak. There is a tendency whenever there is a health problem,
whether its bees or humans, everybody has got their favorite villain to blame. I don't think that the
effect on honey bees is very strong. On the other hand, the suggestion that hives that are placed near
cell towers lose their population of bees relatively quickly. I had a high school student do a project with
me last summer. She was looking at the effects of cellphone radiation on the growth of plants. She used
wheat seed and had an active cellphone by one plot and an inactive by another. The active cellphone
resulted in poor growth of the wheat. So, there is some evidence but again it's not 100%. Again, I agree
the concern should be human health. Unlike many of the toxins that we have studied, I think we have
stronger evidence for human hazard than we do for plants, bees and animals. It should be humans we
care about. That's why I emphasize human research.
Abrami: There aren't research dollars coming this way.
Carpenter: They are not coming this way. They are not there at all. Again, that is the influence of the
industry.
Ricciardi: I just want to comment. Knowing whether we know all we need to know about 5G or not, it
disturbs me that we know it is going to work with 4G. We already know what that can do and living near
a tower can do. They roll out 5G in the state of New Hampshire and it is going to be in front of our
homes. Essentially, they are forcing our residents to live under a cell phone tower. I don't understand
that. We know 4G is not safe and they are going to hang together in front of people's homes.
Carpenter: That is exactly right.
Sherman: And there is nothing you can do about it.
Ricciardi: This is the "Live Free or Die" state here. Now that you are putting something in front of my
home that may make me ill, I am sorry, I just had to put that out there.
Abrami: Well, we can do what we can do as a state but there are laws that trump others. The 1996 law,
that's the real issue.
Ricciardi: Well we are certain that 4G will do harm. Whether 5G does or doesn't they will be hanging
together in front of my house. That's my point.
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Abrami: There is evidence. Yes. There is frustration with the current state of affairs. As a commission, I
think we are all more educated on it than three or four months ago. Dr. Carpenter, I really appreciate,
the dialogue was great. Thank you. If you send us that one article, that would be good.
Carpenter: Alright. I will do that right away.
Sherman: thank you so much.
Carpenter: My pleasure and I really appreciate the fact that your commission is looking into this.
Abrami: Ok. Thank you. That was a good summary and it sounds like we keep coming back to the same
thing. We know what the issues are and I would really appreciate any comments or questions please
send to me via email on the FCC and the FDA.
Sherman: For my part and this is not a part of the commission but I will reach out to our federal
delegation on the clauses in the FCC law. I don't see any reason why health effects should not be part of,
it doesn't matter what political party you are from. If there is a health impact or potential health impact,
it should be part of the decision of whether you can roll out new technology.
Abrami: Well, politically they figured it out if there were health effects, it would slow the whole thing
down. That is the political reality of what happened and here we are. I have been in meetings on just
regular cell towers in my town and know how hard it is to get just a regular cell tower up. People are up
in arms about that, let alone be in front of their house. Verizon was getting very upset with our town as
it took three or four locations before they said okay since they were concerned we would be sued by
Verizon. So, the last location, they said okay. This is where it is going to go, despite upset residents in
nearby areas. I was in these meetings and the neighbors were arguing health effects even with 4G
towers. They said no, can't talk about that. That's just the reality.
Sherman: One of the things that he said that struck me was essentially the further you are from the
source, the higher the energy that is going to be generated by your phone so while we worry about Rye
has the same issue. We can't seem to get a cell tower. We have spotty cell service all along the seacoast.
Does that mean that our cellphones are maxing out with our local exposure? Could the fact that you
don't have a cell tower nearby and have to have a more powerful transmission from your phone
increase your risk more than having a cell tower closer?
Gray: I can comment on that part. There is a decrease risk from radiation that comes from here. There is
an increased risk of the radiation that comes from the cell tower antenna. You are closer to the antenna,
you are getting more radiation. But with this, the power level of the phone goes down.
Sherman: That is what I am saying.
Abrami: I think we have concluded that from our meetings is that's the reality, the your cellphone works
harder, the further away the tower is, it's really working hard to make a connection and is continuously
trying to make that connection and will wear your battery out quicker too.
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Wells: I was wondering if we could take a look at that FCC act of 1996, The Federal Telecommunications
Act. If it's about cell tower placement with respect to health effects, there may be another way of
addressing this.
Abrami: Section 704. We will have it for the next meeting.
Heroux: It was interpreted in the courts as meaning "health" but the wording is "environmental" that
they use in the act itself.
Abrami: so the court interpreted the words.
Heroux: Yes. It's an interpretation.
Ricciardi: There was an incident in Bayville Elementary School in New York. You can research it. They put
the tower near the school and after five years, 30% of the students and teachers got different cancers
and three of the children died. They had a lawyer, I can't think of his name but you can google it. They
went to court over it and they definitely conclusively showed that it came from that tower but because
of that Telecommunications Act of 1996, nothing could be done about it.
Heroux: So the mechanism by which this occurred is very simple. In Washington, industry lobbied the
government elected officials for a uniform law that would implement prosperity, essentially. But they
confused communication with wireless and the deregulation of the industry when the breakup of AT&T
happened, made it very profitable to promote wireless vs. optical fiber. Essentially, those are all
unintended consequences that happened historically.
Abrami: there have been arguments from other speakers we have had here that on your phone bill, they
have been deducting money for wired communications (landlines) but that money has been diverted to
wireless.
Abrami: I will see everyone on the 20th. We won't see Senator Sherman.
Sherman: I will be here in spirit.
Ricciardi: Dr. Sherman so you will be getting someone to move forward with the FDA or FCC?
Sherman: yes, that gives me two things to talk about with our delegation. I will do both.
Ricciardi: Ok. Thank you.
VII. Next meeting: March 20,2020 8:30-10:30
Meeting Adjourned at 10:40 am.
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
7/1/20
1:00-3:00 pm EST
Via Zoom (https://unh.zoom.us/i/98794338097)
Via telephone-US ( +1 646 876 9923) ID: 987 9433 8097
In attendance: (11)
Rep. Patrick Abrami-speaker of the house appointee
Rep. Ken Wells- speaker of the house appointee
Kent Chamberlin-UNH-appointed by the chancellor
Denise Ricciardi-public-appointed by the governor
Michele Roberge-DHHS- Commissioner of DHHS appointee
Dr. Paul Heroux- Professor of Toxicology, McGill University- speaker of the house appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Senator Tom Sherman-president of the senate appointee
Brandon Garod-AG designee, Asst. AG Consumer Protection
Bethanne Cooley-CTIA, trade association for wireless industry and manufacturers
Not present: (3)
Frank MacMillan, Jr. MD-NH Medical Society Environmental Medicine
David Juvet-Business and Industry Association
Carol Miller-NH Business & Economic Affairs Dept.
Meeting called to order by Rep Abrami at 1:01 pm
Abrami: To respect everybody's time, I am going to start the meeting. This is the Commission to Study
the Environmental and Health effects of evolving 5G technology. This is the first time we are meeting
via Zoom. We have had a hiatus of about 4.5 months. The last meeting was February 14th. The State
House has been closed for many months and we finally got the green light to proceed via Zoom. We are
using Zoom, courtesy of University of New Hampshire through Kent Chamberlin who is the Chair of
Electrical and Computer Engineering Dept. Kent will go over some technical things then I will read a
paragraph about why we are doing it via zoom and not in person. Kent, I will turn it over to you.
Chamberlin: This is very brief. I am assuming most of you are pretty familiar with using Zoom. In your
upper right corner, you have speaker view or gallery view. You can play around with that if you want to
only see the speaker or the whole gallery. You may want to play with that. You won't hurt anything.
Also, if you are not speaking, please mute yourself. You will see the mute indicator on the lower left. If
you wish to speak, you can unmute yourself or push the space bar, say what you are going to say and
when you let up on the space bar, you will be muted again. It's a good idea if we all mute ourselves so
we have no background noise. Also, if you are dropped or have any problem, you can always rejoin the
session. That's really all I wanted to say on how to use Zoom. Anybody have any other comments on
how we might best use zoom?
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Abrami: Kent, we wanted to save the gallery squares for our members, our guest, Joel and Deb. How do
we do that?
Chamberlin: If you go to a block that only has a name on it and you right click, it should give you an
option to only show those who have their video turned on. This will reduce the clutter on your screen. Is
that working for people?
Anderson: I think there are several members who have their video turned off, Senator Gray and Senator
Sherman and Brandon Garod. So they may disappear off the screen as well. You won't see their names.
Just be aware of that.
Abrami: Ok. We will go with that. I have to read a public statement now:
As chair of the Commission studying Environmental and Health Effects of evolving 5G technology, I find
that due to the state of emergency called by the Governor as a result of the Covid 19 pandemic in
accordance with the Governor's emergency order number 12 pursuant to executive order 2020-04, this
public body is authorized to meet electronically. Please note that there is no physical location to
observe and listen contemporaneously to this meeting which was authorized pursuant to the Governor's
emergency order. However, in accordance with the order, I am confirming that we are providing public
access to the meeting via telephone and other public access via video means. We previously gave notice
to the public of the necessary information for accessing the meeting, including how do I access the
meeting via Zoom and via telephone. This information was printed in the House Calendar and Senate
Calendars.
Welcome everybody to the meeting. Most of our meeting is going to be hearing the presentation from
Dr. Herman Kelting, who has been so gracious to be flexible in his calendar. I reached out to him about
four months ago. He was going to be our next guest when we stopped doing our meetings because of
the virus. We will be following along his syllabus he sent to us. Before we hear from him, we have to
review the minutes of the last meeting which was February 14th.
I.Approval of minutes from 2-14-20:
Dr. Chamberlin gave me two corrections this morning. One on Page 5- one quote Dr. Chamberlin feels
was from Dr. Sherman. "I don't know if we are talking about the same bill"....
Sherman: As long as it's not inflammatory, I am happy to take credit.
Abrami: Also, on page 19, the last line Dr. Chamberlin said " low e values should be low p values".
Without objection, we will make those changes. Are there any other changes that people noticed from
those minutes? If not, instead of taking a vote, I will say without objection, we will approve the minutes
as changed. Ok with everybody? We are all set. The minutes are approved with those changes.
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II: Direction during the final months: We lost four and a half months and we need to discuss where we
go moving forward. I think this is going to be the last presentation on the science. In reviewing Dr.
Kelting's syllabus, it is a good refresher. There's a lot of good stuff in there that will get us going again
from the science standpoint. Most of us are in agreement, not all of us, that the FCC needs to look at the
biological effects. We have been trying to reach out to the FCC and FDA with no luck on this. With that
said, it's hard for us as a state government to change the FCC's mind on anything. But that does not
mean that we shouldn't focus on certain guidance for our cities and towns on the actions that they can
legally take to help mitigate any potential harm. I think that's where we need to spend the next four
months on looking at what is reasonable guidance that we can give. What really highlights this for me is
that about a month ago: Deb Hodgdon, who takes our minutes and me, who are both from the same
town were asked by our Planner to attend a zoom kind of meeting with our Planning Board. All the
meeting was really was to give the Planning Board an update on what's coming down the pike on 5G.
The two takeaways I got from that meeting are that most planning boards have no idea what 5G is and
they have no idea of any of the issues surrounding it. I thought we were just going to be observers in
the meeting but they asked me to give an update on 5G. They were very interested in what we had to
say. The other takeaway is that they are very interested in what we come up with as a Commission for
guidance. They are looking for some guidance as a town. We know that there is pushback in other towns
and other towns are doing things. I think we need to formulate what is reasonable and what can help
with this issue.
Denise Ricciardi who is on our Commission, is on the Board Leadership in the town of Bedford. They
have recently adopted ordinances that Denise was instrumental in drafting. We don't have time today
to talk about those. I have done research on what other towns around the country have done and there
are a variety of actions being taken. Whether they hold up to a legal standard is another discussion. But
towns and communities are trying to at least put some parameters around 5G. We should be looking at
those examples and working our way through to what we think is reasonable.
Now, understand as I have said over and over again, as a Commission in New Hampshire, we are going
to have differences of opinion among us as Commissioners. The way this is handled from the House is
that there can be a Majority Report and there can be a Minority Report. That's the way we handle these
things. We only have four months. Denise and I chatted earlier about, is there any way we can get an
extension? There really aren't many commissions that have reactivated since the shutdown. I will ask
leadership in the House whether we can get an extension. The problem we have is that it crosses over
into a whole new Legislature and we may be able to do something next year to continue our work. But I
think we have to assume our goal is still to have a report out by November 1st. If we think we still need
more time, we could see if we could get legislation passed but that will have to be the beginning of next
year.
Because there are a lot of us, what I would like to do is to form a subcommittee to start putting some
meat around the bone of ideas. Then present that to the full Commission for discussion. I think that is
probably the more efficient way of proceeding. I will be looking for volunteers of those willing to work
on that subcommittee. If you volunteer to be on the subcommittee, we will probably have to meet once
a week for an hour or two and I don't want to wait any longer than a month for the next Commission
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meeting. Because we lost 4.5 months, I can't see any other way to do this efficiently with the time we
have left. If everybody wants to be on it and is willing to work every week on it, that's one thing but I
don't want to have to ask everyone to do that. Tom?
Sherman: I think it's a great idea, Pat. I unfortunately, cannot be on it because I am chairing a
subcommittee for the drinking water/groundwater Commission. It's a great way to get this done as long
as it's representative and as long as all of us have ample time for feedback and input. Getting something
down as a framework for a report and allowing feedback and discussion as a full group is a great way to
do this.
Abrami: Well, the way I have done it in the past is there will be a lot of introductory stuff and all that but
there will be sections of the report. I am really looking at the recommendations section that we really
need to focus on. I don't want to put people on the spot here. I will just ask you to drop me a note if
you want to be on the subcommittee. Denise already volunteered and I think Kent may want to be
involved. Any others that want to help, that would be great. If I don't think we have enough, I may be
reaching out to you and asking again if that's ok.
III. Next Commission Meeting:
Everybody pull out your calendars. Let's talk about the Next Commission meeting now. How about the
27th?
Sherman: Patrick, I work on Mondays. We usually meet on Fridays.
Abrami: Can everybody do Friday, the 24th? I think we are good for our next Commission meeting to be
on Friday July 24th at 9 am via Zoom.
Ricciardi: Mr. Chairman, could I just bring something up for the record? All things being fair and equal,
our information is important. As you know, I wrote explicit questions with your permission to the FDA
and the FCC and still waiting for a response. At some point if we don't hear back, those are invaluable to
making these very important decisions that I think those questions should be put in the record.
Abrami: Ok. Without objection, does everyone agree we should put those questions asked of the FCC
and the FDA into the minutes of this meeting? Does anybody object to that? Ok so with that, we will put
the record of those questions asked of the FCC and FDA into this meetings minutes.
Ricciardi: thank you.
Abrami: I will share with you those questions after this meeting. By the way, we have been having a
problem getting things out the way we should. Because of the virus, the staff has not been as accessible
as they should to distribute things or post on our webpage. I am trying to be in catchup mode on the
things I thought were sent out but haven't been. So I am working on that. I apologize for that.
With that said, most of our meetings we have had, we have tried to get our arms around the science.
We have a group that understands the science to a good degree. Dr. Kelting has put together a
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presentation with 13 objections. When I looked at it, objections 7-11 are really at the heart of what we
want to talk about more. He can start a little earlier and go a little longer if need be because there is a
lot of material here. Dr. Kelting has been looking at this issue for many years and has published on this
issue and we welcome him. After his sections, we will pause for questions.
IV. Herman Kelting. PhD presentation (For more details, please refer to presentation materialsl
"I am grateful that you have invited me to testify on the safety of 5G/4G Small Cell Antennas placed in
residential and commercial areas which I. I object to 5G/4G SCAs based upon adverse health results. In
my testimony I will discuss the attributes of 5G/4G SCAs and 13 objections related there to; time will
permit me to discuss only a few research citations. Since 5G is new and has only limited historical
application even in 5G/4G SCAs, and 4G and prior generations well established, my research evidence
will emphasize the link between 4G and prior generations RFFR with injury to living organisms. I will also
discuss 4G emissions in the context of cell phone, Wi-Fi, macro cell phone base stations, etc. because
5G/4G SCAs add to already high levels of 4G emissions from many other sources. As a general rule, I
oppose air-borne, wireless emissions."
Attributes of 5G/4G that I will use in my objections to 5G/4G.
A. Two sets of antennas in a "5G/4G SCA": One beam forming on-demand 5G antenna and
three 4G antennas, the latter pulsating 24/7 RFFR sited at about every 100 meters in
residential neighborhoods. Movement of 5G source (e.g., cell phone) transfers signal to 4G
antenna. Hence, I have concluded that the purpose of 5G is not to get 5G into residential
neighborhoods but to bring 4G into neighborhoods to satisfy increased demand and
revenue. SCA wireless emissions may be avoided by hard wiring from street to homes.
B. 4G signals are being increasingly modulated, thereby more biologically active, and
potentially more harmful to living organisms. [Oram Miller]
1. Marginal harms to fetuses and young children are very severe from 4G/5G and all other
wireless communications with thin skulls, over adults who are also harmed.
2. All RFFR is a stimulant causing anxiety, depression, stress, and many other illnesses. Its
radiation places a forced on charged particle on our bodies, namely electrons.
3. Remember this: All manufacturing processes fail in the sense they operate outside the
engineering design: 5G/4G antennas may mal-function to create very high-power
densities and frequencies injuring those nearby, who will not know the extent of the
damage because they do not have meters. Even if one can prove harm with a meter,
damages are limited to the company's equity because insurance companies do not
insure injury from RFFR.
C. Power densities of SCAs have not been publicly disclosed.
Oram Miller indicates power densities from 5G/4G SCAs may be up to several hundred
thousand piW/m2.
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Objection #1: 28 llnesses/ 20 Symptoms known to be caused by or inferentiallv linked to RFFR.
[Letter from Herman Kelting to the secretaries of Health and Human Services and Homeland
Security; original letter dated October 3, 2019; Revision 1 dated January 8, 2019; Exhibit C Herman
Kelting. "United States Congressional Research and Legislative Proposals to Educate the American
People About the Power Density Safety of Wireless Communications (uW/m2)." Indian Journal of
Applied Research 8(1) (January 2018): p. 263-271 (hereinafter "IJAR Jan 2018"].
A. There are twenty-eight (28) Illnesses known to be caused by RFFR. These include
increased risk of brain damage to fetuses, miscarriages, cancer, children's behavioral
difficulties, ADHD, cancer of the brain, salivary gland, and breasts; leukemia, anxiety,
depression, stress, sleep disturbances, reduction in melatonin, cataracts, inflammation;
damage to the testes, sperm, blood brain barrier, DNA (damage through strand breaks),
eyes, heart, thyroid hormones, electromagnetic hypersensitivity (EMH), damage to the
autoimmune system,1 etc. [IJAR Jan 2018, p. 264-265] If a woman places her cellphone
in her bra for five years, there is about a 1.0 chance of developing breast cancer.
B. There are also twenty (20) symptoms reported by those living near 4G MCPBS (three 4G
antennas housed within 5G/4G SCAs) and earlier generations. These include sleep
disturbances, headache, depression, fatigue, dysesthesia (pain, itchy, burning from nerve
damage associated with neurological injury), concentration dysfunction, memory
changes, dizziness, irritability, anxiety, nausea, EEG changes, paranoid states, adverse
neurobehavioral symptoms, etc. [IJAR Jan 2018, p. 264)
C. Nine Determinants of Injury from Wireless Devices: This is a compilation that I have done
on the subject.
1. Distance from the RFFR-emittina device to a body organ. Since emissions from a device
spread out with distance, the closer a body organ is to the emitting device, the greater
the percentage of emissions hitting the body—if a cell phone is placed at the ear vs.
using speaker phone many inches away, a much higher percentage of total emission hit
the brain, salivary gland, and other nearby organs. The brain is obviously the most
vulnerable to injury. Storage of a cell phone in the bra for five years has an approximate
100% chance of resulting in breast cancer. 500 meters minimum distance from MCPBS
to humans and should be 1,000 meters for a two safety multiple.
2. Frequency modulation: RFFR signals (e.g., cell phones) utilize a high-frequency carrier
wave that is transmitted over long distanced with an attached modulated, lower
frequency that carries information. The modulation may utilize frequency or amplitude
modulation. Signal modulation is an extraordinarily complex technical process that may
cause injury to living organisms.
3. Peak (not average) power density of pulsed radiation transmitted to the body. Power
density is the far field (after joining of source magnetic and electric fields) measure of
RFFR strength measured by piW/m2 (micro watts per square meter). RFFR professionals
have concluded that it is pulsating peak power densities that create the most harm to
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living organisms; RFFR meters have options to measure instantaneous, maximum
(peak), and average maximum (peak) RFFR.
Peak densities vary widely based upon the nature of the RFFR-emitting device and signal
strength. I measured the far field of one cell phone at boot up of 500,000 nW/m2, which
can exceed 20,000 piW/m2 in normal operation depending upon signal strength and
other factors.
4. Spatial RFFR density from multiple sources. The spatial RFFR density is a measure of
pulsating radiation density from multiple pulsed RFFR devices such as cell phones, Wi-Fi,
cordless phones, wireless security systems, etc. in an enclosed space. It is
distinguishable from the metered power density per se because it is a function of the
number of RFFR emitters in an enclosure (e.g., Wi-Fi plus 25 cell phones in a classroom)
5. Meters understate harm from multiple nearby RFFR emitters. As the number of emitting
sources in an enclosure increases, the spatial density increases, but the power density
may increase little because of the random combinations of peak instantaneous power
densities from individual sources. To the best of my knowledge no one else has
discussed understatement of power densities from multiple nearby RFFR emitters.
6. RFFR source enclosed in material space- vs. outdoors-sourced RFFR. RFFR sourced within
an enclosure (autos, busses, aircraft, trains, elevators, drywall enclosures; metal is the
worst enclosure) reflects off the confining material surfaces making equal RFFRs more
harmful indoors than outdoors.
7. Age at first exposure to RFFR. Fetuses have thin, incomplete skulls with six separated
bones and RFFR will make direct, almost unimpeded contact with their brain through
the six thinner skull bones and cranial sutures between bones, which continue to age
two. Thereafter, children have thinner skulls for several years, and continue to receive
more RFFR than adults. The most dangerous situation is exposing a fetus or small child
to RFFR in a metal enclosure such as a car or crawling around a Wi-Fi-sourced RFFR.
"Children whose mothers used cell phones during pregnancy had 25% more
emotional problems, 35% more hyperactivity, 49% more conduct problems, and 34%
more peer problems." [Biolnitiative 2012, Section 1 "Summary for the Public 2014
Supplement, Evidence for Fetal and Neonatal Effects," citing Divan et. al. 2008]
8. Cumulative life-time exposure to RFFR. It is not age linear because younger people
suffer more than older people because of brain structure and skull structure.
9. Unique cellular and organ attributes and receptivity to RFFR. Each person has different
cellular and organ compositions and, thereby, different receptivity to RFFR
contamination.
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Objection #2: Evidence of mental illnesses of college and high school students.
A. 25% of college students and 20% of high school students (2018) are claiming mental
disabilities caused by anxiety, stress, and depression to take longer course and SAT
testing times and private testing rooms because they cannot tolerate the presence of
others. [IJAR Jan 2018, Exhibit G: Douglas Belkin. "Colleges Give the Disabled More
Leeway." Wall Street Journal 05.25.2018, A3; Exhibit H: Douglas Belkin and Tawnell
Hobbs. "More K-12 Students Get Special Help." Wall Street Journal. 07.05.2018, A4.] It is
known that anxiety, stress, and depression are caused by RFFR and from this knowledge I
deduced my inference that these mental disabilities are caused by cell phones and other
RFFR emitting sources.
B. College student depression rates increased from 30.9% in Fall 2013 to 39.3% in Fall 2017
("Felt so depressed that it was difficult to function.") [IJAR Jan 2018. Exhibit E: National
College Health Assessment Survey, p. 14]. It is known that RFFR causes depression.
Objection #3: Increases in suicides of young people
A. Actual suicides for 10 to 14-year age group declined from 242 in 1999 to 180 in 2007
and increased to 517 in 2017 = 11.1% Geometric mean (GM) increase for ten years
ending in 2017. [IJAR Jan 2018, Exhibit F]
B. Actual suicides for 15-24-year age group declined from 4316 in 2004 to 4140 in 2007
and then increased to 6252 in 2017 = 4.2% GM annual increase for ten years ending in
2017. [IJAR Jan 2018, Exhibit F]
C. College students who "Seriously considered suicide" increased from 6.0% in Fall 2010 to
12.1% in Fall 2017 [IJAR Jan 2018. Exhibit E: National College Health Assessment 2017,
p.14; IJAR Jan 2018, p. 266;] "Seriously considered suicides" doubled in 7 years: 10.5%
GM annual increase in "Seriously considered suicides".
D. Notice the similarity in IRR growth rates of 11.1% GM actual suicides for 10-14-year age
group and 10.5% GM for college students "Seriously considered suicide."
E. In my opinion, there is a near 100% chance the increase in actual and contemplation of
suicides are caused by RFFR from cell phones, Wi-Fi, MCPBS, and are additional
measures of a catastrophic health crisis NOW.
F. One medical doctor told me this: "Doctors know that cell phones cause suicide."
G. In my opinion, there is a catastrophic health crisis NOW that is being concealed.
1. Reported anxiety, depression, stress, and suicides to Secretaries of Health and
Human Services and Homeland Security in original letter dated October 3, 2018.
2. Secretary referred my charge to National Institute of Health immediately.
3. NIH rejected three days later and stated "no notice to sender."
4. HK reported NIH rejection of catastrophic health crisis to federal law enforcement
agency as an improper rejection of a catastrophic health crisis.
H. On May 27, 2020, HK accessed the CDC website for precise reference for the suicide
data in Exhibit F and was unable to find it after a 45-minute search. Then called CDC
and telephone responder looked for 45 minutes and could not find it. The WSJ has had a
number of articles on suicides and it appears to me that the historical suicide data for
1999 to 2016 has been removed from the CDC website.
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I made a number of predictions in my published article. I am just going to the last one.
Some of the others have already come true of course. The last one is that working lives
will decline from the mid- sixties to the mid- fifties as people have more exposure to cell
phones and radio frequencies. If that occurs, that is going to pretty much be a terrible
situation in an economic sense for the United States because of the additional time for
retirement payments plus the loss of the skills.
Objection #4: Species extinction from 5G/4G SCAs/RFFR [Letter from Herman Keltingto Mayor
Katrina Foley, Costa Mesa, CA. dated January 24, 2020 opposing 5G; HK presentation to Costa
Mesa City Council February 18, 2020]
A. Barry Trower: Physicist and well-known UK 5G weapons expert, who was associated with 5G
weapon systems used to injure Catholics in Northern Ireland stated:
1. Installation of 5G/4G SCAs will result in only one child in eight births being born normal
three generations (60 years) from date of 5G/4G SCAs installation.
2. He also indicated that the RFFR injures 4,500 electrical subsystems in the human body
by placing a force on charged particles.
B. Evidence of species extinction in five generations or less is supported by the following
scientific studies and other evidence: (ten supporting references follow but I will only refer
to a few because of time.)
1. A Greek study of the reproduction of rodent births exposed to RFFR resulted in
"...mice exposed to 0.168 nW/cm2 (1,680 piW/m2) became sterile after five
generations, while those exposed to 1.053 nW/cm2 (10,530 piW/m2) became sterile
after only three generations." [A Balmori, 194] "A progressive decrease in the
number of newborns per dam was observed, which ended in irreversible infertility"
[Magras IN, Xenos, TD. "Radiation Induced Changes in the Prenatal Development of
Mice." Bioelectromagnetics 18 (6) (1997): Abstract, 455-461 cited in A Balmori.
"Electromagnetic Pollution from Phone Masts." Effects on Wildlife."
Pathophysiology 16 (2009): 191-199, 194] (Foley 01.24.2020)
2. Study of 361 men in fertility clinic had reduced sperm count, motility, (moving
property through the female reproductive tract), viability, and normal morphology
(size and shape of sperm under microscope, >14% normal) as daily cell phone usage
increased from zero, < 2 hours/day, 2-4 hours daily, and to >4 hours daily usage
[IJAR Jan 2018, Ref 47,Agarwal, 2008], When you follow these decreases through
multiple generations you have the end of species. That is a 55% decline with an
increase in cell phone use from 0-4 hours/day.
CP Sperm
Group Usage Count Motility Viability WHO Morphology
% Normal
A
No use
85.89
67.80
71.77
40.32
B
< 2 H/D
69.03
64.57
68.21
31.24
C
2-4 H/D
58.87
54.72
57.95
21.36
D
>4 H/D
50.30
44.81
47.61
18.40
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3. Experiment showed that the reproductive capacity of the insect Drosophila
Melanogaster declined 36.4% (1 min), 42.5% (6 min), 49.2% (11 min), 56.1% (16
min), and 63.0% (21 minutes) exposure to a GSM 900 MHz carrier frequency and
217 Hz information frequency with exposure at a power density of 100,000 piW/m2
(10 nW/cm2). Again, this power density of 100,000 piW/m2 is far less than the
6,000,000 to 10,000,000 piW/m2 FCC MPE safe limits. This experiment showed the
important relationship between time of exposure to RFFR and injury to a living
organism. [Panagipoulos DJ et.al. "The Effect of Exposure Duration on the Biological
Activity of Mobile Telephony Radiation." Mutation Research 699 (2010): 17:22.2
4. Cell phones operating at 900 MHz were placed in three colonies of honeybees and
turned on for 10 minutes for ten days. After ten days the worker bees never
returned to the three test hives because the cell phones were "...frying the
navigational skills of honey bees and preventing them from returning back to their
hives." Production of eggs by the queens was reduced from 350 to 100 eggs/day.
The authors concluded that cell phone RFFR is a better explanation of Colony
Collapse Disorder than any other theory. [Sainudeen Sahib S. "Impact of mobile
phones on the density of honeybees." Journal of Public Administration and Policy
Research 3(4) (Apr 2011): 131-133.] (Sisolac 08.29.2019, 13-14)
There are others listed in my presentation but I think this is adequate for proof
C. Doctors and scientists opposing 5G/4G SCAs (There are others, but here is one)
Baden Wurttemberg. Germany October 23. 2019
Seventy (70) doctors in Baden Wurttemberg signed and 25 doctors in white coats delivered the
letter, "Doctors Warn Against 5G Mobile Communications" to the prime minister on October 23, 2019
asking for a moratorium on 5G small cell antennas because of harm to living organisms. They expressed
particular concern with "electro hypersensitivity (EHS)" which now affects 5-10 percent of their
population. One doctor-signatory in Baden Wurttemberg stated "To protect the population, we need
Wi-Fi free schools and a 5G moratorium!" In my opinion, we also need control over macro cell base
stations.
D. Many communities have stopped 5G or will not be producing it.
Haifa. Israel banned Wi-Fi in schools April 20. 2016
On April 20, 2016, Haifa, Israel banned Wi-Fi in schools because of the increase in EHS/EMH and
because many children were contemplating suicide. It is known that Jenny Fry, a UK teenager,
committed suicide because of Wi-Fi in her school.
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E. HK request for medical school research from a friend at (Stanford University) dated May 18,
2020 9:50 AM
Does RFFR make Covid-19 more virulent? Asked for Covid-19 (1) free of and (2) attached to host
cells to be placed under an electron microscope with a variable frequency/variable power
density RFFR to determine if the virus is more active under RFFR bombardment similar to
neurons being more active in an RFFR field What gave me this idea is that we know that six CA
firemen receiving brain and neurological injury from macro cell base station on the roofs of their
fire stations resulting in permanent excitement of brain neurons.( hich was outputting between
10-20,000 nW/m2)
Abrami: Herman, can we pause right here and see if there are any questions at this point. I think
what Herman is doing is adding to the list of papers and things that we have already heard
about and discussed in the past. He is highlighting some of the papers that are of interest to
him. Any questions or comments?
Chamberlin: I just have a question and it involves the bee study. We heard about the bee study
and saw the paper on it. This is of course, very convincing. If you put a cellphone in a beehive
and it's going to destroy the navigation abilities of the bees now that would be convincing. We
are looking for strong evidence. It kind of surprises me that this is a fairly simple study to do. Do
you know if it's been replicated?
Kelting: To the best of my knowledge, yes. In other words, there are other studies that have also
shown damage to bees with the application of radio frequency. What I have done in my work is
pick the best study available and I do not do exhaustive searches with additional support.
Chamberlin: Alright. Thank you.
Wells: I have a question as well. On objection 1, you list illnesses known to be caused by or
linked to radio frequencies and I am wondering, could these antennas be used or hacked to
cause deliberate injury in your opinion?
Kelting; yes, certainly. Remember, 5G is a beam form signal and that means when you turn on
your cell phone, there is a beam that envelopes your body about ten degrees wide and if they
combine that with facial recognition, they can do anything that they wish. They can change the
power of the beam because that's what they did to the Catholics in Northern Ireland. It's not
exactly the same because they can use higher frequencies but they can beam form and take out
people with facial recognition in the antenna system.
Abrami: We know in China, they are using facial recognition with their 5G. There are plenty of
reports showing that. Is that what you are hearing Herman?
Kelting: That sounds sensible but I am not totally familiar.
Abrami: Let's continue.
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Objection #5: Injury specifically from 5G
A. "Preliminary observations showed that MMM [millimeter waves > 30 GHz] increase the skin
temperature, alter gene expression, promote cellular proliferation and synthesis of proteins
linked with oxidative stress, inflammatory and metabolic processes, could generate ocular
damages, affect neuro-muscular dynamics...available findings seem sufficient to
demonstrate the existence of biomedical effects..." [Di Caula A. "Towards 5G
Communication Systems: Are There Health Implications?" International Journal of Hygiene
and Environmental Health 221(3) (Apr 22, 2018): 367-375
B. 5G transmits data in a very short time period, but there are indications that "...these bursts
may lead to short temperature spikes in the skin of exposed people." Research has also
shown that peak to average temperature ratios "...may lead to permanent tissue damage
after even short exposures highlighting the importance of revisiting existing exposure
guidelines." This means that current heat standards are too high and should be lowered.
[Neufeld E and N Kuster. "Systematic Derivation of Safety Limits for Timer-Varying 5G Radio
frequency Exposure Based on Analytical Models and Thermal Dose." Health Physics Sept 21,
2018.] [Letter from Herman Keltingto Nevada Governor Steve Sisolac, Nevada Senator
Nicole Cannizzaro, and Nevada Assemblywoman Shay Backus dated August 29, 2019
(Revision 02), 11-12],
C. 5G operates at the same frequencies (e.g. greater than 24 GHz) as the sweat duct, which is a
helical antenna operating at a high specific absorption rate in extremely high frequency
bands. This suggests 5G will heat the skin, one of the adverse consequences of 5G.
D. In an e-mail dated May 27, 2020 2:05 PM , Professor Joel Moskowitz stated "My note: This
review summarizes research on the effects of millimeter waves (>30 GHz) on the skin. None
of these studies has examined 5G millimeter waves. 5G employs specialized technology
including phased arrays, beam-forming, and massive MIMO (sending multiple data signals
simultaneously over the same radio channel). 5G millimeter waves may be more biologically
active and result in more adverse health effects than the earlier millimeter wave studies
found."
Objection #6: Injury from secondary, endogenous RFFR: Sommerfeld and Brillouin precursors
1. Sommerfeld and Brillouin precursors are induced, propagating transient RFFRs generated
endogenously in the human body (or other mediums) from an exogenous source RFFR with
a changed sinusoidal structure (about 6 times smaller amplitude) that displaces charged
particles in human tissue, thus damaging those particles. (A117). This means that
Sommerfeld and Brillouin Precursors are RFFR that propagate endogenously within the body
from a source exogenous to the body without attenuation and travel faster than the source
pulse. They induce movement of proteins, DNA, and ions of potassium, sodium, chloride,
calcium, and magnesium. (A117) These movements damage cells and organs [Albanese,R,
Blaschak, J, Medina, R, Penn, J. "Ultrashort Electromagnetic Signals: Biophysical Questions,
Page 12 of 34
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Safety issues, and Medical Opportunities." Aviation, Space, and Environmental Medicine.
May 1994: A116-A120 ("Albanese May 1994".; see also OMB No. 0704-0188 94-24875 AD-
A282 990 dated Jan 90-Aug 93; Jakobsen PK and Masud Mansuripur. "On the Nature of the
Sommerfeld-Brillouin Forerunners (or Precursors." Quantum Studies: Mathematics and
Foundations (November 8, 2019)] Thus, 5G beams immerse the body in a 10-degree RFFR,
enter the skin and breed new, induced RFFR that travel faster than the original pulse with
the radiation of the propagated RFFR damaging cells deep in the body just as 4G RFFR does.
2. Regarding the failure of FCC safety limits to consider Sommerfeld and Brillouin Precursors,
Albanese stated "However, IEEE C95.1, 1991 was developed from biomedical data on pulses
whose onset and offset times (or rise and fall times) were much slower than those shown in
Fig 2; the standard does not embody the precursors phenomenon. Thus, in practical term,
the sharp ultrafast category of pulses being discussed are not covered by IEEE C95.1-1991 or
by any other formal guideline known to us...Until the issue of tissue damage mechanisms
associated to pulses that cause precursors is fully studied, the authors recommend zero
human exposure to such unique precursor and gendering pulses." [Albanese May 1994,
A118]
Objection #7: FCC antenna safety standards applied to MCPBS ignore radiation injury to living
organisms at power densities many times lower than the FCC antenna safety standards.
A. FCC antenna safety standards: 6,000,000 to 10,000,000 piW/m2 based upon frequency.
1. These FCC safety limits ignore actual injury from radiation at much lower limits than
6,000,000 to 10,000,000 piW/m2. Six CA firemen received brain and neurological injury
from MCPBS on the roofs of their fire stations emitting 10,000 to 20,000 piW/m2. [Letter
to two secretaries Revision 01 dated 01.08.2019, Exhibit N]
Rep. Abrami, have you heard of this California study before?
Abrami: yes
B. International antenna safety standards:
Compare the safety of FCC safe limits of 6,000,000 to 10,000,000 piW/m2 with other
countries antennae safety limits. The wide range in country antenna safety limits means
no country really knows antenna safety limits and that the US, with the highest
antenna safety limits is clearly in conflict with all other countries in this list. [Remke,
Amar and Mahesh Chavan. "A Review on RF Exposure from Cellular Base Stations."
International Journal of Computer Applications. 104(12) (Oct 2014): 9-16]
Power density %US
Page 13 of 34
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Country or other geographical area
W/m2 nW/m2
USA public exposure guidelines at 1800 MHz
10
10,000,000
100%
India
9.2
9,200,000
92%
Canada (see Attachment)
3.0
3,000,000
30%
Australia
2
2,000,000
20%
Belgium
1.2
1,200,000
12%
New Zealand
0.5
500,000
5%
Exposure limit in CSSR, Belgium, Luxemburg
0.21
210,000
2.1%
Exposure limit in Poland, China, Italy, Paris
0.1
100,000
1.0%
Exposure limit in Italy in areas with duration hour
0.095
95,000
0.95%
Exposure limit in Switzerland
0.095
95,000
0.95%
Germany: Precautionary recommendation only
0.09
90,000
0.90%
Italy: Sensitive areas only
0.025
25,000
0.25%
Exposure limit in Russia, Bulgaria, Hungary
0.02
20,000
0.20%
Austria: Precautionary limit in Salsbury only
0.001
1,000
0.01%
Germany BUND 199
0.0009
900
0.009%
New South Wales, Australia
0.00001
10
0.0001%
(1) Building Biology Institute RFFR anomaly standards for up to for sleeping:
They consider 1,000 ) piW/m2 as an extreme anomaly. They suggest for
sleeping purposes that you have considerably less than 1,000) piW/m2
For example, I have shielding paint on two bedroom walls of my home
which brings me down to near zero.
None Slight Severe Extreme
a. Radio frequency field
radiation (High freq., EM
waves) nW/m2 <0.1 0.1-10 10-1000 >1000
C. RFFR power density meter readings from emissions of a MCPBS (MCPBS) taken 06.09.2020
by HK. MCPBS located 150 feet from about 100 two-story apartments with more apartments
adjacent and to the east of the front 100 apartments. Meter readings taken about 100 feet
from the MCPBS and 50 feet from apartments. Meter used: Safe Living Technology Safe and
Sound Pro II. ( Herman's research)
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1. Power density meter readings in piW/m2:
108,000 97,300
212,000 97,300
97,300 311,000
135,000 580,000
147,000 208,000
224,000
147,000
162,000
175,000
224,000
159,000
135,000
145,000
200,000
2. Descriptive statistics
Average
Stdev
Coefficient of variation
196,663 nW/m2Rounded 197,000 nW/m2
109,569 nW/m2
0.56
3. How would you like to live 150 feet from a MCPBS emitting an average power density of
197,000 piW/m2 when 6 CA firemen received brain and neurological injury from MCPBS
on the roofs of their fire stations emitting 10,000 to 20,000 piW/m2.
If you look at these statistics with the bolded very high values and recall that the
firemen were injured at between 10-20,000. These poor people in 100 apartments are
living within 50 feet of this power density.
Abrami: so Herman, this is interesting. I know a lot of people look at the readings based
upon an average. What is your feeling on an average v. what the peak would be?
Kelting: Perhaps, I was not clear on that. These are all peak readings. What I do is turn
on my meter and clear it and for 15-20 sees it registers peak, hold and gets the highest
peak and that's what I record on here. These are not averages. Averages are much
lower. Probably less than 10%. Peaks injure.
Sherman: Could I ask a question? So is it how long you are exposed to peak, is the
duration of exposure as important as the intensity?
Kelting: It's a combination of both. Remember now, you are talking about a macro cell
phone base station pulsating RFs, the peaks of which are within a 20-30 second interval
are as I recorded here. This goes on 24x7. Theoretically if you came back one hour later
or two days later, you are going to get about the same distribution and the same
Chamberlin: My question involves the bandwidth. Of course, the wider the bandwidth,
the greater the peak you will see because you will be looking at a superposition of a
greater number of frequencies. Do you happen to know the bandwidth?
Kelting: no. I do not. I only measure radio frequencies and that could probably be one of
the inadequacies of my work. But you have alerted me to that and I have a meter that
measures frequencies so perhaps in the future I can consider that.
averages..
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Abrami: But here's the thing. These are still within the FCC standards. Correct? The
question on the table is, is the FCC standard set too high?
Kelting: That's correct.
Kelting: On January 14, 2020 I wrote a letter to the Clark County Board of Commissioners on two sets of
macro towers and cell phone base stations. One was emitting up to 218,000 micro watts per square
meter about 100 yards from the two facilities which was about 100 feet from homes and the second
was power densities on a building with two antenna on top which were concealed incidentally. They
were emitting in the building up to 37,100 piW/m2 . That building is a Community Center.
D. Studies of harm from 4G MCPBS at power densities small fractions of FCC MPE limits,
1. In a study of 1000 individuals living for ten years within less than 400 meters from a GSM
cellular transmitter site in Germany, it was found that the likelihood of getting cancer was
three times greater than for those not near a cellular transmitter and that the patients fell
ill an average 8 years earlier. Radiation in the inner area was 100 times the radiation in the
outer area. The authors concluded it was necessary to monitor the health of individuals
living near high radio frequency emissions from cellular base stations. [Eger, Horst, Klaus
Uwe Hagen, et. al. "The Influence of Being Physically Near to a Cell Phone Transmission
Mast on the Incidence of Cancer." Umweit-Medizin-Gesellschaft 17(4) (2004): 7 pages],
(Sisolac 08.29.2019, 12-13)
2. An apartment building with two cell phone base stations on the roof had a mean power
density of 3,811 piW/m2 with a power density range of 15.2 nW/m2to 112,318 piW/m2. The
mean radiation was reduced by 98% when the power density from the two cell phone
base stations was disregarded. The authors concluded:
"Due to the current high RF radiation, the apartment is not suitable for long-term
living, particularly for children who may be more sensitive than adults...the
simplest and safest solution would be to turn them off and dismantle them."
[Hardell, Lennart, Michael Carlberg, et.al. "Radio Frequency Radiation from Nearby Base
Stations Gives High Levels in an Apartment in Stockholm, Sweden: A Case Report."
Oncology Letters 15(5) (May 2018): Pages 1-29], (Sisolac 08.29.2019, 12-13)
3. In Belo Horizonte, Brazil, it was found that deaths from neoplasia (i.e., abnormal growth of
tissue; cancer) increased with close proximity to cell phono base stations. For those living
within 100 meters of a CPBS, the death rate was a relative risk of 1.35, for 500 meters
1.08, and for 1000 meters 1.00. The death rate from neoplasia varied from 5.83 per 1000
individuals to 2.05 per 1000 individuals. Cell phone base stations were concentrated in
the Central Southern region and varied from 8,980 uW/m2 (0.898 piW/cm2) to 30,660
|iW/m2 (3.066 uW/cm2) in 2003. Brazilian power density standards were 4,513,400 piW/m2
(451.34 uW/cm2) at 900 MHz and 9,024,900 nW/m2 (902.49 uW/cm2) at 1800 MHz.
Page 16 of 34
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Notably, the death rate from neoplasia in Belo Horizonte occurred at power densities
much lower than the US standard of between 6,000,000-10,000,000 piW/m2. [Dode, AC,
Et.al. "Mortality by neoplasia and cellular telephone base stations in the Belo Horizonte
municipality, Minas Gerais state, Brazil" Science of the Total Environment 409 (2011):
3649-3665],
4. In a study of tree damage in Germany, it was discovered that cell phone base stations
damaged the sides of 60 trees facing the MCPBS. The median power density from the
MCPBS on the damaged side was 995 piW/m2 and on the undamaged side was 125 piW/m2
using peak and peak hold values. A power density of 995 piW/m2 is obviously far less than
the FCC safe threshold of 6,000,000 to 10,000,000 piW/m2. It is also a little less than the
Building Biology recommendations of less than 1,000. The authors quote from M.
Repacholi, head of the International EMF Project of the WHO (p. 567), who said in part:
[Waldmann-Selsam C, et.al. "Radiofrequency Radiation Injures Trees Around Mobile Phone
Base Stations" Science of the Total Environment. 572 (2016): 554-569.]
"Given that any adverse impact on the environment will ultimately affect human
life, it is difficult to understand why more work has not been done...research
should focus on the long-term, low level EMF exposure for which almost no
information is available"
5. In an Israel study of cancer rates near a cell phone base station, it was discovered that 3-7
years' exposure times had cancer rates 4.15 times the cancer rate in the entire population
and that the cancer rate for women was 10.5 vs. 1.0 for the whole town of Netanya. The
power densities were "far below" current guidelines of 5,300 uW/m2 (0.53 uW/cm2) for
thermal effects. [Wolf, et. al. "Increased Incidence of Cancer Near a Cell Phone Transmitter
Station." International Journal of Cancer Prevention. 1(2) (April 2004).]
6. In a Greek study of the reproduction of rodent births in response to a microwave power
density of 1,680 piW/m2 (0.168 nW/cm2) it was found that the rodents became sterile
after five generations and those exposed to 10,530 piW/m2 (1,053 piW/cm2) became sterile
after three generations. Note that these damaging-to-living-organisms' power densities
are considerably less than the FCC safe limit of 6,000,000-10,000,000 piW/m2. [Magras IN.
"Radiation induced changes in the Prenatal Development of Mice." Bio electromagnetics
18 (1997): 455-461 cited in A Balmori. "Electromagnetic Pollution from Phone Masts.
Effects on Wildlife." Pathophysiology 16 (2009): 191-199.,]
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Objection #8: FCC antenna safety standards disregard power densities emitted by body proximate
devices (i.e.. personal property).
A. There is only a heat standard for body proximate RFFR emitting devices and it has been
shown many times there is radiation injury even though the heat standard is met.
B. In a letter dated February 7, 2014, the Office of the Secretary of the Interior, stated:
"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."
Objection #9: RFFR meters understate power densities from multiple nearby RFFR emitters.
This means that when you meter an area with two or more emitters, the peak power
densities will not measure appropriately the addition of the second to the first and here is
why.
Assume two single 4G MCPBS emitting antennas each emitting peak power densities of
10,000 |iW/m2 with a combined theoretical peak of 20,000 piW/m2.
When you meter, you should probably get at some point a peak of 20,000 piW/m2. You will not get
that because antennas will be emitting unsynchronized peaks and lows. The probability of
measuring two MAX peaks of 10,000 piW/m2 each for a combined total power density of 20,000
|iW/m2 is zero. Thus, if we have a metered instantaneous peak of 8,000 piW/m2 for Antenna #1 and
a metered instantaneous peak of 4,000 piW/m2 for Antennas #2 for a combined instantaneous peak
of 12,000 piW/m2, 12,000 piW/m2 will be the peak for the two combined antennas, which is
12,000/20,000 piW/m2= 60% of the true combined peaks. You will likely never get the true a peak of
20,000 nW/m2
Abrami: Let's pause there. Does anybody have any questions? None. Ok keep going Herman.
Objection #10: Legal vs. equitable standards to measure safe human exposure limits. US statutes
and case law.
A. Legal Standard is from Telecommunications Act of 1995 Section 704(a)(7)(B)(iv) Public law 104
104th Congress 110 Stat 66:
"No state or local government...may regulate the placement, construction, and
modification of personal wireless facilities on the basis of the environmental effects of
radio frequency emissions to the extent that such facilities comply with the Commissions
regulations concerning such emissions." [Telecommunications Act of 1995 Section
704(a)(7)(B)(iv) Public law 104 104th Congress 110 Stat 66],
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In my opinion, Telecommunications Act sets a legal statutory, not equitable standard, for safety
unrelated to actual known injury. 704(a)(7)(B)(iv) is unconstitutional because it violates
equitable safe power densities.
B. It is essential that equitable standards of the National Environmental Policy Act not be
overridden by federal legislation. I believe there is a bill in Congress that is attempting to
override the National Environmental Policy Act (NEPA).
One of the fairly good cases is.
1. In United Keetoowah Band of Cherokee Indians in Oklahoma, Individually and on behalf of all
other Native American Indian Tribes and Tribal Organization et al Petitioners i/s Federal Communication
Commission et al No. 18-1129 decided August 9, 2019, the court was faced with the following issues and
factual situations and held as indicated:
2. Principal issue: Was the FCC order "Acceleration Wireless Broadband Deployment by
Removing Barriers to Infrastructure
(1) "All 'major Federal actions significantly affecting the quality of the human
environment' trigger environmental review under NEPA...42 USC §4332(C). Major
federal actions 'include actions ...which are potentially subject to Federal; control
and responsibility.'40 CFR §1508.18. Under the Commissions procedures
implementing NEPA, if an action may significantly affect the environment,
applicants must conduct a preliminary Environmental Assessment to help the
Commission determine whether 'the proposal will have a significant environmental
impact upon the quality of the human environment' and so perhaps necessitate a
more detailed Environmental Impact Statement 47 CFR §1.1308; see also 40 CFR
§1.1508.9. [7]
The summary of the legal issues that I have in this section is to emphasize equitable
standards not legal standards, which are unconstitutional.
Abrami: Let me pause you there Herman. So you are saying that for Indian
reservations, different rules can apply now?
Kelting: No. I am not saying that. First of all, I am not a legal expert on Indian
Reservations and outside of them. But what I have just quoted you from was from a
federal law that is not specific to Indian Reservations. It was applied to Indian
Reservations but is broadly applicable in my opinion, to all other circumstances as
well. In other words, the NEPA is broadly applicable to all situations where there is
environmental injury. That is why we need to use equitable standards not legal
standards.
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Abrami: So let's take section a/ The FCC granted licenses for the telecommunication
companies to install SCA on Indian lands without any historical preservation or
environmental review. So what did they do? What happened in this case?
Kelting: I don't know. I think the case was the DC court of appeals.
Objection #11: RFFR-emitting devices may interfere with reception of the Schumann Resonance
A. The Schumann Resonance is a set of Extremely Low Frequencies caused by lightening in
the ionosphere/atmosphere with a main frequency of 7.83 Hertz (cycles per second)
and harmonics of 14, 20, 26, 33, 39, and 45 Hertz. Those resonances are very similar to
the RFFR harmonics in the human brain.
B. Practical application of Schumann Resonance
Experiments with individuals living underground indicate they became depressed
until the Schumann Resonance was added to their environment. To give you an
illustration here, I used a bike helmet lined with a heavy duty tin foil and got a
severe headache several times. The tin foil of course should protect me from
outside frequencies. When I removed the tin foil, I did not get the severe headache.
My hypothesis was that maybe I had become separated from the Schumann
Resonance like underground humans and that separation caused the headache.
Abrami: Before you go on Herman, does anyone recall? Didn't we talk about the Schumann
Resonance somewhere along the line at one of our meetings? No? Ok. It sounded familiar.
Objection #12: 5G/4G SCA legislation does not provide a reasonable accommodation for
those with Electromagnetic Hypersensitive.
A. SCAs will be universally installed throughout cities and those who are EMH will have no
place to go for freedom from RFFR. Your choices will be stay in your home or suicide. There
is one lady who has EMH in a place where they have installed 5G and she has to have her
meals delivered to her in her house. She can't go outside.
B. Kalamata, Greece did a pilot study of 5G/4G and rejected it partially on the grounds of no
protection for EMH individuals.
Objection #13: Environmental power densities should be disclosed in transfers of interests in real
and personal property or in the use and occupancy of public buildings.
A. Objective: Inform the public of the quantity of power densities (piW/m2) in their
environment.
B. Regulatory issue #1: Power density disclosure to buyers and lessees of residential
real estate.
1. Power density disclosure of piW/m2 to buyers and renters by state law. State law
should require environmental assessments
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a. Meter immediately outside the housing unit. "Outside" means around the
outside the walls of the building including only the detached housing unit or
around the outside walls of a multistory building containing several housing
units all at ground level.
b. Meter inside the housing units within three feet of all interior walls during
ordinary working hours or evening hours as required by the buyer or lessee.
Date, day, and time must be shown on the inspection.
c. Estimate spillover RFFR from adjacent housing units if you are in an apartment
or a condominium. Turn off electricity in target housing unit and turn off all
RFFR devices. The remainder RFFR is from outdoors or from spillover RFFR from
an adjacent housing unit. Can estimate spillover RFFR my metering near party
wall. I have personally measured wifi once that was throwing off a million
(|iW/m2). I believe that was in the far field three feet away. That's terrible. That
means that across the party wall, those people are probably getting 900,000.
d. Measure of harm: Imagine a six-month old baby crawling on the floor with a
1,000,000 |iW/m2 Wi-Fi nearby in the same or spillover adjacent apt. Getting his
or her brain fried from grossly excessive RFFR/EF. That child is going to be
injured, perhaps for life.
Abrami: Herman, let's talk about this for a minute. The upper limit of the federal guideline is 10 million
|iW/m2 right? Or ten W/ m2 and your example is only one tenth of that FCC limit.
Kelting: Yes and my proposal in informing the public, does not include a safety standard within the
legislation. It will only say that every home and apartment will be metered and the results delivered to
the renter or the buyer. There will be no notice of what is safe or not safe. The purpose of that is to
avoid criticism in comparisons with the FCC. Let people start doing their own research and when they
do, then you are going to get complaints. I am thinking this is the golden arrow to defeat the FCC.
Abrami: Right. I think I understand what you are saying. Publish what the readings are and let people
make their own decisions.
Kelting: Exactly. It will come to a point where people will say, I am not going to buy your house because I
am getting 10,000 piW/m2 and over there at that house, I am only getting 20 or 30. I bought my house
in an area by metering first. I selected my house in an area with low radio frequencies, typically less than
10.
Abrami: Ok. That's something that the Commission will be thinking about.
C. Regulatory issue #2: Need power density disclosure and prohibition of use of RFFR
emitters in public buildings.
1. "Public buildings" mean all buildings that have unrestricted public access including
government buildings, retail stores selling personal property or services,
restaurants, exercise facilities, etc..
2. The disclosure should be made using a time-dynamic RFFR meter showing power
densities in piW/m2 with one time dynamic meter for the lesser of 10,000 square
feet of floor area or the actual space. This is so when you go in a building, you know
what the power densities are. Those densities will include any cell phones and
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wireless devices in the building. That's the beginning of managing radio frequencies
in buildings in my opinion.
3. Prohibit use of wireless devices in public buildings (e.g., government buildings,
schools, anyplace there are concentrations of people in an enclosure). I am also
suggesting this after being a government agent and working in government
buildings for thirty years of my life. Now that means that people won't be able to
talk to their children at three o'clock while at work or talk to their buddies. That will
reduce the power densities in buildings. Furthermore, there are issues of trespass.
When you have a cellphone that is emitting a beam that is hitting my body, you are
trespassing on me which, in my opinion is illegal under equitable standards.
D. Regulatory issue #3: Need power density disclosure to buyers of RFFR-emitting personal
property (e.g., cell phones, Wi-Fi, cordless phones, automobiles) at point-of-sale.
1. Electric field within about one inch of the item (near field), if not a moving vehicle
2. Power densities (i.e., piW/m2) within three feet (far field) of the device, if not a
moving vehicle.
3. For autos, meter inside vehicles in an environmentally near zero geographic area.
So in addition to the mpg on a car, there should be power densities in that car as well. The same thing
for wifi, cell phones, etc even though I recognize differentials in signal and signal availability is a factor.
That pretty much closes it. I would like you to comment on what you felt about this presentation.
Abrami: you summarized a lot of work that we had gone over before the shutdown. This is all good.
Some of the last comments about not having cellphones in buildings, that's a tough sell.
Kelting: yes. But if you start doing some other things like disclosure in rental and buying property, then
people will become acclimated and want disclosure.
Abrami: Well let's open this up.... New Zealand, for example, their standard is 500 piW/m2 or 5% of what
our standard is. We have talked about this many times. How can we be so high of a standard and other
countries take a totally different position? It's all over the board. Australia is 2,000,000 and Canada is
3,000,000. We have been discussing this a lot which is why we have been trying to get in touch with the
FCC to answer our questions. It is hard getting through to them.
Kelting: It's impossible because they are controlled by the telecommunications industry. What happens
with federal agencies is that eventually substantially all of them are controlled by the industries they
regulate because their managers are essentially appointed by those being regulated.
Abrami: yes. We have heard all those arguments. As a state we can't set up standards. All we can do is
warn and give guidance. I want to at least be able to say that we have tried to reach out to the FCC and
FDA and others because someone is going to say why didn't you talk to the FCC? We just have to be able
to say we tried and have gotten no response.
Chamberlin: At this point, after what I have read and after having other presenters before you and
hearing what you are saying, I am totally convinced that there are deleterious effects on health due to
radiofrequency exposure. I am sold. But, what I don't know is relative risk. In other words if I have a cell
phone and live near a cell tower what is my risk compared to say, smoking or driving a car? Do we have
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some dose relationship between exposure and risk? Am I ten times more likely to die from cancer if I
have a cellphone? Can you put some context behind this and give me some relative understanding of
how exposure is risky?
Kelting: My answer to that question is the probability of extinguishing humanity in sixty years if we
continue the rate we are going even without 5G is about 100%. We are in a process of destroying
humanity right now and the evidence is being concealed. My letter of complaint incidentally on that
case went to the Federal Bureau of Investigation.
Abrami: They didn't respond, I imagine.
Kelting: no.
Gray: I find objections to most of what Mr. Kelting has presented today. I can't count the number of
times in his presentation he said, in my opinion. I can't count the number of times he has referenced
studies that have been disproved by other things. I would admit that there probably is a radiation level
that I can probably reach that would be deleterious to humans but to talk about extinguishing the
human race, to talk about suicides and all these other things with studies that have not been
reproduced, have not been verified and are using high levels of radiation or animals or different species
that aren't humans who aren't affected the same way and taking that as gospel. I just can't get there.
Thank you.
Kelting: Senator, you could if you were Electromagnetically Hypersensitive as I am because I can feel the
junk.
Heroux: I think that to answer your question as to evidence that there is or isn't.... in order to assess the
health effect, you have to measure it and you have to believe that there is something to measure. In
relation to electromagnetic radiation, when the federal government through the FCC expresses an
opinion about risk that is so clear, that there is no risk below thermal levels, there hasn't been much
incentive to perform measurements. There are individuals who attempted to do this. So the only
variable with relatively reliable documentation is cancer. This is a variable that has a digital quality to it.
Either you have it or you don't. There are international bodies who measure this in a routine fashion.
What we have on this subject as you already know, are the two reports from International Agency on
Research on Cancer that says low frequency and radio frequencies are related to cancer as well as a
number of studies like this Brazilian study that I think is very convincing on the impact of cell phone
towers because not only do they determine from an established set of cancers but your probability of
dying from it is higher if you live near a cellphone tower. The problem essentially with Dr. Kelting's
presentation is that he goes to a large number of effects on which there is relatively little proof because
it hasn't been investigated in a very systematic way. So, we don't have the means to investigate
everything in detail but perhaps cancer is an exception. Thank you.
Abrami: Let's bring this back to 5G vs. cell phones or whatever. The real issue is our communities are
going to be asking for guidance on 5G. If they roll out small cells in any community, they will be rolling
them out in front of people's homes low to the ground and the great mystery to all of us is how much
energy is coming out of them and is it safe to walk near one of these? Obviously, industry is probably
saying yes, they are very safe. We wouldn't do it if it wasn't safe. There is enough evidence out there of
ills from RF radiation on all topics. You name it, there are plenty of studies. From the beginning, we have
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asked, have the studies been replicated? But to me, there is enough evidence of concern. We will all
have to put ourselves in the position of asking ourselves if the cell company came by and put an antenna
on top of my telephone pole that is 100 feet from my house, would I think that's a good thing or a bad
thing? At this point, I wouldn't be too excited about it because I am not 100% convinced that there is
not some concern for safety. Maybe it's not conclusive evidence as of yet but I think the body of
evidence will have to be built over time. That's the concern that we have to address for the state of
New Hampshire and for the communities and citizens in the communities. That's a tough thing to get
our hands around but that's what we are being asked to do.
Sherman: I was just going to second what you are saying. Whenever you are looking at studies of human
health especially with potentially deleterious exposures, one other that we are grappling with is PFAS.
How good are the studies on PFAS? Well, they are good enough to say everything is pointing in a bad
direction. Is there something that is absolutely unequivocal? We know that with Mesothelioma and
asbestos and bladder cancer and arsenic or smoking and lung cancer? No.
Is there something right now with 5G that says, boy this is really bad for us? I think it depends on who
you ask. But you have got a very large, very well- funded, very powerful industry saying, trust us. We
wouldn't do this if it were damaging or harmful to human health. It reminds me of some other industry
issues we have had in the past saying trust us and not trying to make sure the data is robust. Therefore
the data is suggesting that there is no harm. So we are left with the Precautionary Principle of public
health which is, we have enough evidence to be concerned but not enough evidence to be definitive as
far as I can see from sitting in on these things and what do we do?
I think the most troubling thing for me is that especially in New Hampshire but throughout the country,
there is a certain amount of choice of what we expose ourselves to. With 5G, that choice is gone. Unless
you want to stay in your home and wrap yourself in aluminum foil, you don't have that choice. You get
into people's personal choice. We have a choice whether or not to use a cellphone but we don't have a
choice if the 5G tower is going to be right outside our window because the FCC covers that. They are in
charge. That is what I find to be the single most troubling aspect to this. This isn't something I can
choose like what kind of drinking water I will be drinking. I can choose whether or not I smoke
cigarettes. In this case, I don't have a choice. The bees don't have a choice. The environment doesn't
have a choice. The trees don't have a choice. And if we get this wrong and the industry is wrong or is
suppressing knowledge, which we have seen before for example in tobacco. We could be screwed, to
use a medical term.
Patrick, I think you are on the right track which is saying how do we embrace what we have always
embraced in New Hampshire which is our personal choice as well as our personal responsibility and
recognize different people's interpretation of what is so far to me is not absolute data and what can we
come out of this with in terms of recommendations? I think one recommendation is you are not going
to go wrong if your community says, no 5G until we know it's safer but my concern is that we may not
be able to do that.
Abrami: There are communities that have said that. It becomes how long does that last before the
lawyers catch up with that and the company wins that argument. That's something that we have to
consider. Whatever we do we have to be pretty confident that it will cut muster and terms of legal
action or legal recommendation. I think there are things we can do to nibble around the edges on this. I
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think that's what we want to do as a subcommittee is to put some things together that we think might
be viable.
Sherman: I also wouldn't try to litigate this in any recommendations. I wouldn't guess where these
lawsuits are going to go if a town says no 5G or something like that. I think we can certainly recognize
that there is the risk of litigation or some would say with certainty if you try to close the door to 5G. I
find that very troubling that an entire community would not have ability to say no to something that has
some significant evidence that it may be harmful.
Kelting: How many of you own RF meters? For those of you who believe that RFs are safe, buy a meter
and defend its safety based upon what you meter.
Heroux: I can recommend for you a meter, the GQ EMF390 for about $200 you can get an ELF meter
that goes to about lOGhz and also has a frequency analyzer. It is truly a quantum leap in what is
available to the consumer. It is made by an American company. It can monitor the fields every second
for 24 hours and download it into your computer. So a lot of the measurements you are talking about
for protection of housing and buildings become feasible when you have that kind of sophistication
available to everyone.
Ricciardi: I wanted to make a couple of comments and thank Senator Sherman because I echo what he is
saying. There are a few things we have to remember. We definitely have enough science and evidence
to show that things are unclear and unsafe. But if we were to go and say, ok the Telecommunications
Act, the FCC has not provided us with proof that is safe. That is the problem. When you are putting 5G in
front of people's homes, we have to remember that it doesn't work alone. It has to have 4G with it so
essentially you are forcing someone to live in a soup of microwave radiation because the science is there
with the 4G. Really, that is unconstitutional.
In addition to that, we are not a town deciding whether we should roll out 5G or not. We are a group of
people that have been selected on what is the best thing to do for the state of New Hampshire. It
doesn't mean we have to talk about litigation because our job is to make strong recommendations on
our findings whether it's agreed upon or not but that's what we have been tasked to do. That's what we
have to do. We are making what we find to be an important decision for the state of New Hampshire.
Abrami: Yes. We do but again I still feel that they have to be, I don't want to say reasonable but that
would not violate federal law. I think that one of the recommendations may be that our federal
legislators need to do more. I think this is something we need to continue to discuss how far we want to
go with this.
Woods: I have a technical question. What chance are we going to have to sort of have an executive
session? I don't need to get into detail but some things that Paul and I have raised and Ken and Kent as
well. I think some of the basic science things need to be reiterated perhaps. Again, we don't know all of
the outcomes but if we can provide a little bit of discussion about the real basic science like we talked
about proton tunneling. Our presenter brought up the issue of precursors. I think that is an important
issue and I don't think people understand what a precursor is but that can have a significant impact from
a quantum mechanical perspective. We have done a couple of things. We have brought this down from
concern only about the ionizing radiation. We did point it out to one of our presenters no, that doesn't
count. You need to talk about the non- ionizing radiation. I think even though we don't have all of the
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answers, I think we can provide in our report the concerns that we have and point out that there is
some basic science at the quantum mechanical level that will support that. That needs to be done
because of A, B and C consequences.
Getting back to my original question, are we going to be able to do some exec sessions where we can
talk about that among ourselves and flesh out some of these other issues?
Abrami: We can't have exec sessions as a whole. They need to be public. We can meet as subgroups I
think up to 50%. I would love to see that actually of the more technical folks in the group. All this
information is great. We have gathered a lot of good information that we need to not lose. That should
be available in the report to all our communities in New Hampshire. Here are some of the facts that we
found so far.
Sherman: I was just thinking that maybe before you start your subcommittees maybe the next
Commission meeting could be free discussion among the Commission. There is enough resource here,
people with enough knowledge. I have some questions about some of the testimony both today and in
the past that I would love to just bounce off other Commission members.
Abrami: Tom, at this point I am not planning on inviting any other guest speakers because I think it's
time for us to do exactly what we are talking about here. We have to start talking among ourselves and I
see a lot of heads shaking yes. I think that is what we will definitely do next meeting.
Woods: That is sort of what I had in mind when I said exec session. I didn't mean exec per se but what
Tom is referring to about having an open discussion.
Sherman: And then the subcommittee could take that and I know there has been some really great
feedback from Commission members, great questions, and a lot of information. So having a session
where we can distill that down and then the subcommittee can then go get to work. We can get a little
clearer from all of us, where each of us is. Pat, I don't know maybe it would make sense for each of us to
maybe start out with saying where we are and then have a discussion after that of where we are as a
Commission.
Abrami: I think that is a good idea. Assume the next meeting will be two hours of discussion among
ourselves about where we are at. Everybody will have a chance to weigh in on their position. I think I
have a sense but you never know. Then we talk through what we think the structure of a report will look
like, too. I don't want to lose some of the knowledge that we have. The report will include the minutes
of these meetings as an attachment. Our minutes are quite extensive. I know when I did the report for
the marijuana Commission, that report was 200 pages long with all the attached minutes we had to it.
There is a lot of information in those minutes that I think is valuable.
Chamberlin: The reason I go back to relative risk is because with a number of things available to us there
is a risk associated that we decide is acceptable. Here is an example: We drive cars and yet we lose
30,000+ people per year with traffic accidents. They die but we consider that to be acceptable. With
something like 5G, it will clearly have benefits associated with it. Is the risk relatively low that we can go
ahead with it? Or is it such that we can't? That is the one thing that hasn't come out in all the testimony
that we have heard. How much of a risk is it? Is it comparable to smoking five packs of cigarettes a day? I
don't know. If we are going to get traction with this politically, we need to be able to impose the realism
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that this is a significant threat or perhaps it isn't. But that's one thing that I haven't yet found out in my
reading either. Can anybody shed any light on that?
Woods: To me, there are two parts to the risk. One is the relative risk and the other is exposure to risk.
With driving a car, you can take the back roads and stay off the highways but with 5G, you may not have
that choice. There is exposure risk vs. personal acceptance risk and that has to be differentiated as well.
Wells: Just a couple of things that Dr. Kelting said today that I wanted to make sure didn't get lost. He
talked about disclosure with real estate, etc. and also about RF trespass on my body or on my home. I
am thinking there might be a parallel here to 20th century strip mining in Pennsylvania where a farm
owner didn't own the mining rights and found himself sitting on a pile of gravel the next day. I am
wondering if there is some sort of precedent here that we should be looking at.
Abrami: Herman are you still on with us?
Kelting: Yes. I am here but I am not familiar with strip mining or the case law associated with it.
Abrami: Ken, I am not sure myself but that is a good question though.
Wells: The idea of signal trespass onto my property. Dr. Woods was just talking about whether you can
choose to expose yourself to the risk or not. In the case of driving, you can. Whether you decide to
smoke or not, you can. But this is more like a second hand smoke kind of thing. You can't protect
yourself from it under the current circumstances.
Abrami: the other thing is 5G hasn't really been rolled out extensively yet. The other problem we have
with 5G is that it's a marketing concept. Each company, it means something different. Ken, I know we
have talked about antennas. What's inside the antenna? How are they configured? I think one thing we
can grapple with is how much energy is coming out of the antenna. I think we have boiled it down to
that. The FCC standard is set so high that even if we said as a community there would be periodic
monitoring of the levels that seems like it's pretty high intensity to have on top of a pole twenty feet off
the ground. I think the industry would say no it's not that level of intensity coming out of that but we
don't know. A lot of that is proprietary information. We don't know what the intensities are going to be.
One of my thoughts was let's monitor. Let's say a community in agreement with the cellular company
says that it should not exceed FCC standards. But those standards are way high. The cellular company
shouldn't object to that since they feel that things are safe within the FCC limits. My instinct is that 10
W/m2 is very high level. As I said before, why did New Zealand set their standards at 5% of our levels? I
don't know. Maybe they are just being more cautious. But it makes you think. Why do some countries
have totally different standards than our standard? Some would say they are erring on the side of
caution as Tom would like to say. Well, how can they get away with their 5G at their standards and we
have standards set at 10 W/m2 ? These are conversations that should be happening at the federal level
really. We would love to talk to the FCC. We would love to have them on our zoom meeting right now
answering our questions.
Ricciardi: I just asked when you say that FCC says this is safe then why does the Telecommunications Act
say health cannot be a consideration? If it's so safe, why would that be in there?? Just a question.
Abrami: and it's a good one.
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Kelting: I would like to mention one thing here. For 4G, you could insulate your body with silver
embedded cloth. With 5G at the higher frequencies, you will be required to use tin foil only. It will go
right through cloth even with silver threads.
Gray: Beam forming is something that I don't know that we have explored very well. It would seem to
me that beam forming would cause very short time increases in radiation during the time the beam is
formed. But may reduce radiation during times when we are just in monitoring or not in beam forming
mode. Things like that are things that are unique to 5G. I don't think we have had sufficient discussions
to understand what would happen.
Kelting: When you connect the 5G, if you move your source, it automatically transfers to 4G. So what
you are really doing is communicating with 4G in all likelihood. The purpose as I indicated earlier, is that
they want to put 4G into residential neighborhoods so they can increase the capacity of the system. It's
not to get 5G in there.
Abrami: Help me out here. My understanding is that the 4G cell towers will be communicating with the
5G small cells, is that correct?
Heroux: 5G is an engineering concept that is designed to increase the capacity of the environment to
transport data. What industry is really adept at is to transport a lot of data through wireless and
essentially with the IOT concept, there is no limit to the opportunities there are to increase the amount
of data being transmitted whether you use beam forming or to broadcast it. All of these avenues will be
exploited and you will get to the maximum allowed standard ultimately in your environment. This is
something that is expected because engineers develop applications in as much as they have the
opportunity to do it. What is missing in here is that these agencies like the FCC are essentially blind on
impacts on the electro-sensitive people certainly and the other health impacts of this radiation. But the
intention of industry is to facilitate communications. Ultimately, wireless is a dead end. It's a little bit like
oil because the spectrum is limited and you have to have more and more expensive techniques to
transport more and more data. What we should be thinking about is society will need a lot more data.
Let's favor optical fiber over wireless because it is not only hygienic, very safe and it has a lot of virtues
not being promoted simply because of commercial reasons. Thank you.
Abrami: I just noticed we are getting a lot of chat comments. Kent, is there a way we can save the chat
messages?
Chamberlin: Yes. I will save them all.
Abrami: Some of it looks like they will be helpful. There is one that says China and Russia have science-
based standards on their evaluation that non thermal effects exist. There standards are certainly set a
lot lower than ours. European countries have set precautionary limits. If you can share this with me and I
can share it with everybody. There is one on India, which dropped its limits to one tenth of what it was
before. Parliament addresses issue of beam forming and measuring issues. There is a report that some
of the more technical members are interested in and we can have a discussion around. I guess I am not
that much of a Zoom expert. I should have been following some of this chat going on here. We will save
it and send it out.
Sherman: on the select committee, we incorporate the chat into our minutes. You may want to do that.
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Abrami: We have at least fifty people on and I was told there would be people on from around the
country, which is good. Herman. Thank you very much for sharing your information with us. It was very
helpful. I want to thank everybody. We are getting applause here from everybody. Again, I wish we
didn't have that pause for four and a half months. Got a little rusty here but I think we are back in the
groove.
Roberge: Rep Abrami, I have a clarifying question. This was a very helpful discussion. As I sort of prepare
for our next meeting on our position and open discussion. I need a little clarity on the charge of the
Commission because what I continue to hear and this is a little bit challenging is that 3G/4G and 5G
really aren't separate. They are necessary in order for the other to exist. My question is, as we begin to
think about recommendations, are we looking strictly at 5G? Is that the charge of the Commission? And
how do we differentiate that? That's where I am struggling.
Abrami: Thank you Michele for the question. If you go back to one of our early meetings and it's in the
minutes. We early on discovered that you can't talk about 5G without talking about 3G and 4G or RF
radiation in general. So, we have to talk about it all. We have learned that you can't uncouple 3/4G from
5G because they do interact with each other. We are going to try to focus on 5G but it's going to spill
over to the other technologies as well. Are there any other comments?
Thanks to Kent and UNH. We are using their zoom to hold this meeting. We used your space yesterday
too, for a House meeting. Kent and Ken were you there yesterday? I couldn't find you. Maybe I didn't
look hard enough.
Woods: Yes. I was here.
Wells: I was wearing a mask. It was hard to recognize me.
V. Zoom Chat from 7-1-20 Commission meeting:
00:26:12 Ken Wells: Does NH have any recourse to Communications Act of 1995 insistence
that municipalities and states cannot prohibit installation of antennas?
00:35:28 Ken Wells: Meeting again July 24 @9am via Zoom
01:22:30 EH Trust: I think the case is this: https://ehtrust.org/federal-court-overturns-fcc-
order-which-bypassed-environmental-review-for-5g-small-cell-wireless/
01:23:08 EH Trust: Here is the link to the case decision
https://www.cadc. uscourts.gov/internet/opinions.nsf/4001BED4E8A6A29685258451005085 C7/$file/18
-1129-1801375.pdf
01:49:22 Ken Wells: GQEMF390
01:49:45 Ken Wells: RF meter
01:57:10 Bruce L. Cragin, PhD: You just don't want to hear from any more physicists!
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01:59:12
Paul Heroux, Dr.
I am amazed that we could not get the FCC to appear.
02:00:09 Bruce L. Cragin, PhD: More good sense. Thanks for that.
02:00:59 EH Trust: The FDA should do a risk analysis f this type but has refused. Dr. Melnick
states this should be done https://ehtrust.org/statement-by-ronald-melnick-phd-on-the-national-
toxicology-program-final-reports-on-cell-phone-radiation/
02:01:34 EH Trust: "A quantitative risk assessment of the data from the NTP studies on cell
phone radiofrequency radiation needs to be performed by the FDA and that information should be used
by the FCC to develop health-protective exposure standards. In fact, it was the FDA that nominated cell
phone radiofrequency radiation to the NTP, and I quote "to provide the basis to assess the risk to human
health of wireless communication devices." Therefore, I urge the FDA to immediately conduct the risk
assessment of the NTP data."
02:04:06 EH Trust: Plus there should be an assessment of the impact to birds bees and
trees but none has been done. There is no health agency tasked to evaluate and develop a federal safety
standard regarding impacts to trees, bees and birds. It is a gap
02:06:01 EH Trust: Montgomery county - Maryland did monitoring and found FCC limits
were breeched until 10 feet around the antenna facility.
02:06:34 EH Trust: China and Russia have science based limits based on their evaluation.
That non thermal effects exist.
02:07:15 lori: State Law 12'K:11 e) needs to be amended to allow testing and monitoring of
RF . How can we even know if the FCC standards are being met without monitoring, sampling and
testing
02:08:10 EH Trust: Several European countries have set "precautionary" limits . I have
these details. And some of the documentation can be found here
https://ehtrust.org/policy/international-policy-actions-on-wireless/
02:08:51 EH Trust: China-
https://web.archive.org/web/20120413171654/http://www.salzburg.gv.at/Proceedings_(20)_Chiang.pd
f
02:09:09 EH Trust: Russia-
https://www.researchgate.net/publication/228104887_Scientific_basis_for_the_Soviet_and_Russian_ra
diofrequency_standards_for_the_general_public
02:10:23 EH Trust: India dropped their limits to 1/10 th pf what it was before because of
this report https://ecfsapi.fcc.gov/file/7520958381.pdf
02:10:29 EH Trust: asl understand it
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02:11:04 EH Trust: India published their findings as detailed here
https://ecfsapi.fcc.gov/file/7520943486.pdf
02:12:14 EH Trust: European Parliament reports adress the issue of beam forming and
measuring issues in this report
https://www.eu roparl.europa.eu/RegData/etudes/BRIE/2020/646172/EPRS_BRI(2020)646172_EN.pdf?f
bclid=lwAR3cDOTDOqGHpOmCWPnANN-Y6RBaaOeoQ4ZNOnuUwpVaLL8MIDtt6aKtiYM
02:13:57 Bruce L. Cragin, PhD: Don't confuse legislation with science!
02:14:11 EH Trust: European Report here also
https://www.europarl.europa.eu/RegData/etudes/! DAN/2019/631060/1 POL_IDA(2019)631060_EN. pdf
02:15:22 EH Trust: According to Belyaev 2019, "the health effects of chronic MMW
exposures may be more significant than for any other frequency range." The abstract states that, "
Various responses to non-thermal microwaves (MW) from mobile communication including adverse
health effects related to electrohypersensitivity, cancer risks, neurological effects, and reproductive
impacts have been reported while some studies reported no such effects. According to Belyaev 2019,
"the health effects of chronic MMW exposures may be more significant than for any other frequency
range." The abstract states that, " Various responses to non-thermal microwaves (MW) from mobile
communication including adverse health effects related to electrohypersensitivity, cancer risks,
neurological effects, and reproductive impacts have been reported while some studies reported no such
effects.
02:15:36 lori: Thank you for all your work
02:16:59 EH Trust: Brillouin precursors can be formed by high-speed data signal as
Microwave News 2002 pointed out "Introducing Brillouin Precursors: Microwave Radiation Runs Deep."
When a very fast pulse of radiation enters the human body, it generates a burst of energy that can travel
much deeper than predicted by conventional models. This induced radiation pulse, known as a Brillouin
precursor. Brillouin precursors can also be formed by ultrawideband radiation and, in the near future,
by high-speed data signals." The 2002 Microwave News article discusses the controversy over the Pave
Paws radar system which used phased array radiation. In 5G communication systems, the phased-array
antenna is one of the lead front-end components, https://microwavenews.com/news/backissues/m-
a02issue.pdf
02:17:29 EH Trust: ""When a very fast pulse of radiation enters the human body, it
generates a burst of energy that can travel much deeper than predicted by conventional models
(Oughstun 2017). This induced radiation pulse is known as a Brillouin precursor. Brillouin precursors can
be formed by ultrawideband radiation and by high-speed data signals as used in 5G."found in
https://ieeexplore.ieee.org/document/9002324
02:18:29 Augustinus.Ong: Thanks for the meeting.
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VI. Important questions need to be answered for NH 5G Commission:
(Questions included in the minutes sent by D. Ricciardi to FDA and FCC)
From: "Shuren, Jeff" fda.hhs.aov>
Date: June 24, 2020 at 4:28:49 PM EDT
To: Denise Ricciardi bedfordnh.ora>
Cc: OC Ombudsman OC.FDA.GOV>, Patrick Abrami gmail.com>
Subject: RE: Important questions NEED to be answered for N.H. 5G health task commission
[External]
Dear Ms. Ricciardi,
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 bedfordnh.org>
Sent: Tuesday, June 23, 2020 10:38 PM
To: Shuren, Jeff fda.hhs.gov>
Cc: OC Ombudsman OC.FDA.GOV>; Patrick Abrami gmail.com>
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
Radiofrequency Radiation and
Cancer< https://www.fda.gOv/media/135043/download < https://www.fda.gOv/media/135043/download > >
1. Why did the FDA only focus on cancer as a health effect?
1. 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
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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?
1. Did the FDA review in a systematic way the research on impacts to the nervous system?
1. 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?
2. Did the FDA review in a systematic way the research on impact to trees and plants?
1. Did the FDA review in a systematic way the research on impact to birds.
1. If the FDA did not investigate impacts to insects or trees, what US agencies have done so?
2. The FDA website page Scientific Evidence for Cell Phone Safety < https://www.fda.gov/radiation-
emittina-products/cell-phones/scientific-evidence-cell-phone-safetv < https://www.fda.gov/radiation-
emittina-products/cell-phones/scientific-evidence-cell-phone-safetv> > 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?
1. 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.
1. 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?
1. 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?
1. 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.
2. 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
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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
miscarriaae< https://www.nature.com/articles/s41598-017-16623-
8 > and but also increased
ADHD >,
obesity > and
asthma > in the woman's prenatally exposed children. A recent large
scale study
< https://www.sciencedirect.com/science/article/pii/S0013935120303662?fbclid = IwARI 1X 74FIT7v Rp09
WvbkE8AmAIBHAVU67yiKW8A6ZWPnPsLRioLxGsy1o#< https://www.sciencedirect.com/science/article/pii/
S0013935120303662?fbclid = lwAR11X 74FIT7v RpQ9WvbkE8AmAIBHAVU67viKW8A6ZWPnPsLRioLxGsv1o
#>> again found associations with cancer. Please clarify which US agency has jurisdiction over ELF-EMF
exposures?
1. 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.
The Right to Know Law (RSA 91 -A) provides that Town email communications regarding the business of
the Town of Bedford are governmental records which may be available to the public upon request.
Therefore, this email communication may be subject to public disclosure.
V. Next meeting via Zoom: July 24th 9-11
Meeting Adjourned at 3:02 pm.
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
7/24/20
9:00-11:00 am EST
Via Zoom (https://unh.zoom.us/j793912769762)
Via telephone-US ( +1 646 876 9923) ID: 939 1276 9762
In attendance:(12)
Rep. Patrick Abrami-speaker of the house appointee
Rep. Ken Wells- speaker of the house appointee
Kent Chamberlin-UNH-appointed by the chancellor
Denise Ricciardi-public-appointed by the governor
Michele Roberge-DHHS- Commissioner of DHHS appointee
Dr. Paul Heroux- Professor of Toxicology, McGill University- speaker of the house appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Senator Tom Sherman-president of the senate appointee
Brandon Garod-AG designee, Asst. AG Consumer Protection
Bethanne Cooley-CTIA, trade association for wireless industry and manufacturers
Carol Miller-NH Business & Economic Affairs Dept
Not present: (1)
David Juvet-Business and Industry Association
Meeting called to order by Rep Abrami at 9:03 am
Abrami: For the sake of time, I am going to open the meeting. This is the New Hampshire Commission to
Study the Environmental and Health effects of evolving 5G technology. I have a short version of
something I have to say. Due to the Covid 19 virus and the Executive order signed by the Governor this
public meeting is allowed to be conducted via Zoom. It is open to the public for viewing and was duly
posted as a zoom meeting. With that said, if you are not a member of the Commission, can you please
turn your cameras off and mute yourselves? That would be much appreciated.
I. Approval of minutes from 7-1-20:
The first order of business is the minutes. I sent them out about a week ago. By the way, Deb you did a
great job of compiling them once again. I did get an email from Michelle asking for two corrections. I
think we misunderstood for Augustus Ong, listed under attendees. Michelle was in attendance. Also, on
page 29, "this was a very helpful discussion". Those are the changes that I have gotten so far. Were
there any other changes? So without objection, the minutes are approved as amended.
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II: Around the table member thoughts:
Abrami: The first thing we are going to do today is go around the room. The zoom room if you will.
What we would like to do is talk about where we are at and the kind of recommendations, possibly that
we would like to see in the report and where you stand on the whole issue. I am envisioning the room
as it was at the State House and will go to my left. That means, Tom you are up first. Again, it's a general
discussion and your thoughts as to where we are at and what we should be doing.
Sherman: Thank you, Patrick. I think I said it and it was in the minutes from last time. My overriding
thoughts on this are that there is enough evidence to raise concern but I'm not sure there is enough
evidence to show causation between exposure and specific health impacts. So, what the means to me is
that there is more than ample evidence that a non-biased large scale study or studies needs to be done
to demonstrate that we are not going to be implementing an entire system of communications that
would put either human health or the environment at risk. I think of the Precautionary Principle. I also
recognize we have several other examples where industries have said to us, this is safe. I can think of my
own profession where we used to say, "Trust me. I'm a doctor".
I think we all know that phrase, trust by verify is the very least where we need to be. In this case, there
is ample distrust because the Commission has already seen the amount of industry influence on the
regulatory bodies. By the way, that's nothing new in Washington, DC or in some states. When I was in
Virginia, our entire oversight for agriculture was from people who had formerly been in the industry. So
when you think of some of the chemicals like glyphosate, people from the industry were regulating the
industry and we know where that gets us.
My overriding New Hampshire response to this is, I would like to see the ability of communities to
control their environment until such a time that an independent, scientifically based study or studies
have been done to demonstrate the safety of this technology. I think that is consistent with
Precautionary Principle of public health. I think it is consistent with the way many of us in New
Hampshire view our personal freedom. And I don't believe we have ever been shown a compelling need
to, right at this moment, on an urgent basis, implement 5G technology. I guess that's my summary
statement.
My plea would be to have to start working on these studies and to ask our federal delegation, as
they've done with PFAS, to start looking at where there has been exposure and what has been the
impact. And start funding some of these studies at a federal level outside of the different regulatory
agencies. I was really impressed by the consistency of response or I guess the consistent lack of
response from the EPA and the FDA. It's amazing to me, that they seem to not want to respond even to
a statutory state commission. So, I guess I'll close by saying the parallels to other exposures that we
have, are really clear. And the lessons that we've learned from something like PFAS, where a few years
ago, I started working on PFAS back in 2014. The industry knew about those dangers from the 1950s.
They continued to profit with manufacture until at least 2003 when DuPont pulled out. 3m continues to
and at this point, we have over a 100 communities and/or water systems in the state impacted and
those are just public systems. Now we're playing catch up. But at the exact same time this week coming
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out and Lancet are two, scientific articles looking at the data on PFAS and broadening the concern to
diabetes, obesity, breast cancer. None of which, we have talked about on our way through this. So here
we have an opportunity before the industry has an ability to expose us. To say, let's put the brakes on,
let's get the data. You show us that it's safe in independent studies, not funded by you, but funded by an
independent body and overseen by an independent body. And then we can move forward together to
implement this new technology. That's my feeling I and thank you for the opportunity.
Abrami: Thanks Tom. I forgot to mention that once we're done with the round table, I'm going to ask
Denise to just briefly discuss our non-response from the FDA in relation to the FCC. That is a discussion
that we need to have. The other thing is that this meeting is being recorded, so everybody knows, It's
pretty much for the ease of doing our minutes at the end for Deb. And that, any chat room discussions
that are going on will become part of the minutes. We did make them part of the minutes from last
meeting. Ok. Let's continue around the room here.
Wells: Yes. Thank you. In looking over the materials that we were previewing for this meeting, I came up
with a number of recommendations, about seven of them. And it seems to me, that there are three
levels of issues here. One is general RF radiation from Wi-Fi, 5G and all that. Then there specifically 5G
and then on top of that, and I would give it the highest priority is the 5G small cell antenna network,
which I think poses particular hazards. And I think that we should explore ways that New Hampshire can
take unilateral action to protect our population, our environment, our forestry industry, and also supply
the fastest broadband and communications to our population. I have a couple of things that I think
would be worthwhile here. If this type of technology is to be developed, the state of New Hampshire
could require that installers and owners of these systems carry enough insurance to cover the potential
claims of New Hampshire residents who are exposed. We should require also insurance to compensate
based on potential losses in the forestry industry, agriculture, hive losses, etc. Here's another separate
issue. It occurs to me there's a parallel here with 5G and the mining rights in coal country where farmers
found that they didn't own the rights to the mineral below them and their farms were turned into strips
of gravel. I think it's a private property and liberty issue.
Broadcasters must be specifically granted rights for their signal to intrude on private property. And if
they don't have those rights, they must not do that. Senator Sherman mentioned the problem that
many of the studies, clearly there are conflicts of interest. I think that, that following the example of
Jersey City and some others where they there's been a moratorium placed until, say, a UNH study is
completed when that is not funded by industry, but where there's a demonstrable freedom from
conflicts of interest.
Abrami: I guess there is some debate on whether Jersey City moratorium is in place or not.
Wells: Yes. I understand. I saw the petition that was circulated as a possible model. Then I wonder if the
state of New Hampshire can impose its own maximum intensity limits and require that equipment have
an accessible off switch if they're found to be out of compliance. And with that, I think I'll conclude my
remarks and listen to what others have to say.
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Abrami: Okay. That's very good, Ken. Thank you. There are some good points from both you and Tom so
far.
Chamberlin: So as I listen to the previous two speakers, I'm in agreement. I echo their concerns. And
essentially Sherman in particular, what you had to say is very much along the lines of what I feel both
what you said just now and what's in the minutes. My belief is that we have a serious issue with
exposure. The scientific data is pretty overwhelming. Although those data, the data is, is being
completely ignored by the regulatory bodies. And that's kind of the elephant in the room here is we
have a regulatory body that says that these standards set 30 to 50 years ago are acceptable. Yet the
evidence, scientific evidence suggests that it's not. So that clearly is something that we have to address,
explicitly in whatever report we have. Other issues, is the yes, we can ask for things like insurance. We
can mandate that the providers have insurance to cover any issues that may come about as a result of
this. The property rights, is also a good angle also.
But at this point, I don't feel like I need to see any more scientific evidence. I'm pretty convinced. Since I
got on this, I'd been reading article after article and that's pretty convincing that yes, there's a problem.
The one thing that we don't know that would be nice to know is the degree of risk. How much risk do
you encounter by having a cell phone? being near a cell phone tower? We need to, to get that. And I
think that we can and we should pursue something like a moratorium until we figure out and get
answers to some of these very important questions.
As was pointed out earlier, this is not new. We have seen these types of issues. That is where industry
just says it's no problem. This won't hurt you. We've seen that from smoking doctors, from the tobacco
industry. We've seen from the fossil fuel industry dealing with things like climate change, which they
knew 50 years ago that this would have an impact. So we keep seeing this pattern again and again. And
what happens is that the industry makes an investment before we're able to find out or to demonstrate
that whatever they're investing in, causes problems. And once they've made the investment, it's kind of
hard to turn back, but I think that we have this opportunity now to just move forward to come up with
moratorium so that they won't invest they won't get too much of an investment, won't get ahead of the
curve as it were, before we figure out how much of a risk this imposes. Thank you.
Abrami: Thank you, Kent. Good points.
Ricciardi: I, too concur with everyone who has spoken. I think the one thing we can agree on all of us is
that whether some of us believe it's unsafe and maybe some of us are uncertain. I think the biggest
thing we can agree on is that there's a lot of disagreement in the scientific community. I feel that the
science that we have seen and the evidence that has been brought before us and all of the materials
we've been reading and speakers we've been listening to. I am convinced have a serious issue. And I
really believe that it will harmful to just put this out. And I think we have to put stipulation on how
things should be. I feel that the state could impose mandatory hard wiring for technology. In the
meantime, continuing studies that are real studies. We're having a problem with the FCC. They haven't
changed anything after all these years. It's a captive agency. They are a non- health agency. I made some
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notes. We could as a suggestion, call for a halt to 5G and its infrastructure until RF limit has been set by
federal health and safety agencies. There is no health agency overseeing any of this.
Again, state could call for wired infrastructure which is safe, and actually is faster. Not only that, it's
safer in the ability to not be hacked. So, there are many measures there. We can call a halt until the
scientists determine how the adequate methods of measuring should be. We can also pass bills that
support further research for transparency and education on 5G and wireless devices to be used in the
Internet of Things. In my opinion, it would be completely irresponsible for this commission to just blindly
roll this out with all the compelling evidence. I don't want us to be like the PFAS or the tobacco industry.
And there are some huge differences with this than anything else. If this is put in front of every other
home, you are now robbed of your choice. You know, if you don't want to use a cellphone, you don't
have to use a cellphone. If you don't want to live near a tower, you can look to where you want to live.
This robs you of your choice. And that goes against our New Hampshire constitution. I have a full report
on all of this, but that's sort of the gist of it. Do you want me to go right into segue into the questions
that I've sent to the FCC and the FDA, or do that at the end?
Abrami: Why don't we do that at the end? I've got Carol Miller next.
Miller: Morning everyone. Here are my thoughts on this... I mean, the science is the science whether it's
true or false, it's overwhelming. Every article that I've read, it's just overwhelming. But having said all of
that, RF is RF. We've RF with 4G, 3G, Wi-Fi, whatever you name we have RF in our lives. And there are
people who are sensitive to RF. And depending on the degree of RF they're getting it could cause the
health issues or whatnot. We have some big challenges ahead of us. Cell services not regulated at the
state level. It's regulated at the federal level. So I'm not sure that towns in the state can dictate anything
to the Cell carriers. There are strict rules in place and we could be setting ourselves up for major
lawsuits. So that's where some of my concern goes.
My recommendations really are more practical. And I agree with everyone else's recommendations that
have been said so far. What can the industry itself, due to its devices and to its antennas and its system,
to reduce the effects of RF to the public? Is there a technology that can do that shielding in phones that
that creates less RF to the individual? And, and I think, it could be a costly solution for the industry. But if
we're going to have any effect by, I think that that's where we really need to focus our efforts, along
with all the other recommendations. Yes. Let's study it. I mean, it has been studied. We need to study it.
Can towns literally put a moratorium on it? I don't know. Can the state say that everybody has to have a
wired connection? I don't think so. So what we need to do is look at things that can be accomplished
and through this committee, get that information out there. And I'll close my comments.
Abrami: Somewhere along the line over the over the years a left turn was taken. We were heading on
the journey to fiber optics. And then then now we got, you know, the evolution of 5G. And we know
fiber optics is actually more robust. They carry more information and they're less likely to be hacked if
you will.
Miller: yeah, but that doesn't solve mobility problems. That's the lore that cell cellular coverage is. It's
the ability to have your phone on you and your data anywhere any time. But that does not mean to say
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that fiber isn't important. Fiber is the infrastructure of the future and where New Hampshire should be
funneling any investments, or all investments, right? (I like the thumbs up) to fiber connectivity and stop
putting band-aids on a sagging telecommunications infrastructure. I have very strong feelings about
that. But cellular is a different creature altogether. It actually needs fiber to be able to transport data, e
Everything comes into the wired network, even by cellular. So it's the mobility, the ease of use, it's the
instant connection, instant reach ability that the mobile industry has captured. And so therefore, there
needs to be some work on their part to abate all of this RF bubbling to the surface. And, you know, I
agree with everyone else, but I just wanted to offer a practical solution or I guess sound check to what
we're actually doing here.
Abrami: Thank you Carol. Beth Cooley, you are up.
Cooley: Alright, can you see me? Hear me? I am having some issues.
Abrami: I like those things behind you. Looks like Star Trek.
Cooley: Yes. I am in outer-space. Well, good morning everyone. I appreciate the opportunity to provide
our thoughts at this point in time. You know, in terms of recommendations at this point, my thoughts
are, I think we need more experts because everyone has been anti 5G at this point. And in fact, some of
the "experts", their research on this topic has been called "junk science", quote-unquote. So my first
recommendation and Rep. Abrami, you and I talked about this before the pandemic is Dr. Swanson
didn't get to finish his presentation back in November. So I'm sure he'd be happy to answer questions
because he ran out of time. I understand some folks may not agree with his point of view. But I think
Rep Abrami, you and I discussed offline that we want a balanced approach to this commission. So that's
sort of point one in terms of the experts in the science. I think the other side has some questionable
credentials. Second, I think it would be helpful. We sent around, I think maybe three weeks ago, a recent
study from the radiation safety journal on 5G a new study. I think it would be helpful to hear from the
authors of that as well. And Rep Abrami, if you're open to it, I'd be happy to see if we can do some
outreach to those authors. And that's sort of my first recommendation on the on the expert side.
I'm the first to admit I'm not an expert. CTIA is not an expert. We defer to those that are. We think we
need to hear from the people that are smarter than us.
Abrami: Beth, I've always said to you, I'm open to hearing from all sides. And you gave us Dr. Swanson
and he was sort of out of time, but we could probably dedicate some time more or any other experts
that you may have.
Cooley: Yeah, that would be great Rep Abrami. And I want to say they're not, you know, industry
experts. They're speaking their thoughts, their research. So I'd be happy to do that outreach.
The only other item I'd like to raise that I'm not sure that we've talked about. I think it's been
distributed. But it's important to note that other states have done this. They've done the research and
even your neighbors in Vermont and Connecticut have done this. And I think it's important to look at
those recommendations. Other states like Louisiana, Oregon, Hawaii have also done reports on this as
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well. So I believe some of those have been distributed, but I don't think we've talked about them. I know
there have been a lot of things distributed into this group in terms of articles and studies. So I'd just like
to highlight that other states are doing this too. And rather than re-invent the wheel, I think it would be
helpful to look at what they looked at.
Those are sort of my two recommendations at this point in time. I appreciate a given me the
opportunity.
Abrami: Well, Beth, if you have any documents from these other states that you could share with us,
that would be fine.
Cooley: Absolutely.
Abrami: Okay. Well, thank you.
Ricciardi: Can I interject to make a comment?
Abrami: Yes.
Ricciardi: Okay. Since Beth did bring that up, I actually have in front of me what other states have done.
And she referenced Hawaii. I can send this link out to everyone. Hawaii county planning board passed a
resolution to halt 5G. Farragut,Tennessee has a resolution calling on state and federal governments to
halt 5G until health risks are evaluated. The Washington DC advisory 3G/ 4G committee resolution
opposing small cell wireless and 5G technology, wants studies confirming safety. I have a whole list here
that does speak to what Beth just said. I'll make sure that committee gets that.
Cooley: Yeah, Denise, I think that's a good point to look at what other states have done, but I think it's
important to understand the context. For example, in Hawaii county, the council passed the resolution
this week. It's a nonbinding resolution. As you well know, it is illegal to stop infrastructure at the state
and local level on the basis of RF, as that is regulated at the federal level. So the Hawaii county
resolution that was passed is non-binding, and I believe Rep Abrami sent out our comments when it was
before the planning board a few weeks ago.
Abrami: Yes I sent it out and I also want to know if theses have teeth or not. That's the question, you
know, in the legislature we do resolutions to Congress and to the federal government but they're not
binding to anybody other than it's a statement of a position. In this case, we have a commission that
that's looked at this very closely. And that is a bit different than some of these other commissions from
other states. I would say we have more technically minded people on this commission and then some of
these other states may have, you may know more than I do about that Beth. Tom has his hand up.
Sherman: But I just have a quick question for Beth, you used the term "junk science". I was wondering
which science you were referring to when you called some science "junk science".
Cooley: So this wasn't a quote from me. Another scientist called one of our previous speakers, research
on cell phone RF issues, "junk science".
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Abrami: Okay. Thank you. Okay, we will move on now. Brandon Garod.
Garod: It's Brandon, that's ok. It's a very common mistake. So I am a little bit leery at this point of
continuing to hear from experts on either side because I think that we could call experts for the rest of
the Commission. I think we there is a difference of opinion. Some people think it's safe. Some people
think it's not safe. I think there is enough evidence to suggest that it might not be safe that we should as
a commission, have an obligation to flag that for the state. And you I don't think that hearing from more
experts is going to move us in one direction or the other in terms of a commission deciding definitively
yes, this is safe or no, this isn't safe. I think that there is some evidence it is not safe.
It is not, in my opinion, a foregone conclusion that this is definitely not safe, but if there is evidence to
suggest that it might not be safe, I think that it is important that it is thoroughly vetted and tested
before there's an enormous roll out in the state. And I think that's even more important, echoing what
Senator Sherman said at the beginning, which is that there really in my opinion, does not seem to be
immediate compelling need to have 5G in the state of New Hampshire at this point. My cell phone
works great, almost anywhere I am. I can get on Wi-Fi, almost anywhere I am. We're able to meet as a
commission remotely. We're able to do our jobs remotely. I'm not sure what the benefit is of having 5G
if it's not thoroughly vetted and tested and confirmed, definitively, to be safe before it's rolled out. It
would be great. You know, the faster things are, the better things work. Obviously, it's better for us
moving forward technologically as a society. But at this current juncture, I don't see an immediate
compelling need. I think that it's clear as a commission that we have some evidence that it's safe and
some evidence that it's not. And now it turns to, you know, what are we as a Commission going to do in
order to fulfill the task that we've been given as a commission, which is to make a recommendation.
And that's where I really struggle. Because like others have said, you know, I'm I think I'm the only
lawyer on this commission. I spent some time doing some legal research yesterday and in anticipation of
today's meeting. The Telecommunications Act of 1996 is very clear. The state cannot pass a law or
regulation that prohibits the telecommunications infrastructure from coming into the state. It is
preempted. It's completely regulated by the federal government. There's a carve-out for public health
and safety but that is limited because there's a lot of litigation that has come from that in terms of
whether that only applies to the state, or whether that can be attributed to local government as well,
towns and municipalities. And overwhelmingly, for the most part, it's only the state that can pass a
resolution that directly correlates to protecting the health and public safety. I don't think that the
science is there in order for us to pass any sort of law that would prohibit or inhibit 5G, in order to say
that it is in a direct correlation to protecting the health and wellness of citizens of New Hampshire. Any
sort of recommendation that is passing a law or passing a regulation or a barrier to entry is going to be
heavily, heavily litigated. And you know, whether it's successful or not, as, you know, is always an open
question. But I think that to the extent that we decide to recommend any sort of legal barrier, we need
to be prepared for that. That's going to result in a very long drawn-out legal battle.
I do certainly support any recommendations that we can make that are not likely to lead to extensive
litigation that we may not have a leg to stand on. I think that the public needs to be made aware of the
findings of this commission. I think that there needs to be more public awareness about the issues. And I
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think the people in New Hampshire have a right to know about the science and about the studies that
have been done. Anything we can do as a commission to increase public awareness even if it is like the
Hawaii resolution. Yes, it's non-binding. But it's something. It's at least the community saying, yes, we
have concerns about this. And this is what we're going to do to take the steps that we can in order to
make people aware and to do our part to say that we as a community have concerns. And I think that is
probably the sort of recommendations that we need to be looking at moving forward as a commission.
Abrami: Ok Brandon, that's great. When I speak at the end, I want you to react to one of the things I am
going to say whether we even think it has potential of being a legal issue. So thank you. Michelle
Roberge.
Roberge: I represent the department of Health and Human Services on this commission. We feel, where
this is regulated at the federal level, that certainly more work needs to be done at the federal level to
ensure that the standards are protective of public health. We know that the standard haven't been
reviewed for a number of years. We know that there are a lot of studies that have come out and
certainly more studies that we've heard, and what we're learning from this commission. More robust
studies need to be done to ensure that they are protective of public health.
So we really need to make sure that at the federal level those agencies that include FCC, FDA, EPA really
need to look at the science. I know there was a recent publication put out by FDA, I think it was in
February 2020. They did look at number studies but didn't move forward with a standard review but
again, more support of looking at those studies where they are not just looking at heat, but they're
looking at other biological effect as well. The department at that point is supportive of that. And that's
where we stand at this point. And I know there's other recommendations that are coming forth and that
would be something we'd have to reevaluate as we pull the report together.
And I know Representative Abrami and I shared in an email that where we are, our role in this
commission depending upon what recommendations that come out, being an executive agency put us in
a conflict of interest situation if the legislature tries to implement any of the these, we essentially could
be the body or agency that regulating it. We have to be careful of conflicts of interest. We definitely
agree that more needs to be done at the federal level where it is regulated.
Abrami: I did respond back to Michelle's request or query about specific recommendations. And given
that Michelle's representing the Department of Health and Human Services, there's concern whether
that's an official position of Health and Human Services. When I chaired the marijuana Commission, we
had a disclaimer that the recommendations in the report don't necessarily reflect the position of certain
state agencies. So, I'll share that language with everybody down the road. We can take a look at that.
And that's a problem with a commission when you have State agencies on them. They're between a rock
and a hard place. That will go for the AG's office as well. They have to be careful. Their input is very
valuable but it gets a little bit sticky once there are recommendations being made. Okay. Dr. Heroux.
Heroux: Yes. Thank you very much for the opportunity. I am going to propose some strong measures,
but I realized that we have to avoid conflict with the FCC. I also realize that the measures have to be low
cost and potentially reversible as well. So I think of this in terms of protecting various populations. So
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first, to protect people from radiation from portable phones, I think that we should make it a law that
cell phones do not work when they are held against the head, in other words using the proximity sensor.
This is a simple alteration in software that when you put your phone against the head, it stops radiating.
That means that you'd have to use your phone in front of you. So it doesn't change at all the
functionality of the phone, but it practically eliminates the strong radiation to the brain. When you
consider that the cost of assessing this SAR is from $50 to $200 thousand per phone. You eliminate a
whole area of conflict. Of course, industry is not very eager for this because it reduces emphasis on the
issue of heat from cell phones. But you maintain functionality. It's a very simple alteration. These
sensors are already there and you eliminate connections with glioblastoma or auditory tumors. So that's
one thing.
Now, to protect people from radiation from base stations, without making any comment on levels of
radiation, I think that a 500 meter hold back and there was a distance should be should be that much. If
you can deploy 5G with that kind of hold back, you know, fine. But we have data that shows that
proximity to these towers is a health risk.
Thirdly, to protect young children, I think we should adopt the same measures that were adopted just a
week ago in Russia in relation to wiring schools, limiting strongly the use of wireless, and forbidding the
installation of base stations near schools. This is something that they have concluded to be a good idea
on the basis of their most recent evidence.
Then to protect electro sensitive people, I think that we have to take measures that give them recourse,
in terms of protecting themselves. I think that we should maybe train a few physicians in New
Hampshire to become expert in this area so that they can confirm that some people are electro
sensitive. And when they are confirmed, they would be entitled to some form of protection.
Lastly, it would be a good idea to protect citizens and businessmen because if in the future radiation
becomes a stronger issue than before, some people who buy property might not be aware of the
radiation levels on the property that they are buying. And they may face big losses as a result of this
ignorance. So probably in New Hampshire, you already have specialists who are capable of assessing
radiation. Maybe there should be some sort of framework that would make it practical for these people
to give information on the levels of radiation in various places when there are transactions occurring.
And in this way, you could build a picture of exposure in the state, as well as give these businessmen
some form of protection. Thank you very much.
Abrami: Thank you, Paul. And Senator Gray.
Gray: morning. I am old enough to remember back in the late fifties when there was a big to do about
high tension power line and cows that would be grazing underneath the high-tension lines. Since then,
you know, we've done lots of studies on lots of different things dealing with the electro- magnetic
radiation. Part of what's going on here, in my opinion, is that we have created a fear. People don't like
change. And certainly if you have a fear of getting cancer, that is going to create strong emotion in
various people.
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I'm not saying that there are not people out there who are hypersensitive to RF. I am not saying there is
no problem with RF. I'm saying that most of the data out there that we see needs a good peer review.
And in some cases, those peer reviews that have been conducted, have pointed out flaws in that data.
There is a big problem when I hear, well, gee, the industry paid for a particular study and therefore that
study should be discounted. I don't believe that to be, you know, what should happen. Like any other
study, whether the industry pays for it or does not pay for it, it, you'd be peer-reviewed. And the results
of those peer reviews would tell you whether or not there is validity in the study, whether this study
should be questioned further on that. We don't have, and the studies that I've seen, and there's not that
many good scientific studies out there. That is, a lot of these articles that we've seen go back and
reference either the same studies or they are redone.
Let's go back. It's the fear of change that tends to make us believe that there is a bigger problem out
there than I believe that there is. Having the ability, if I own a piece of property and say, you can't
generate any RF signal that's going to come across my property, that's just never going to happen. Okay?
That's like saying you can't use perfume when the wind is blowing across my property because of the
smell the perfume. I mean, this borders on the absurd.
The photo that we saw with the tree and half of the foliage being gone and the cell tower there, I want
to tell you that that there was a new cell tower put up and there were two trees next to each other. One
of those trees had to be removed for the cell tower to operate properly. And you know what? It looked
very much like the picture that we saw. So, you know, a lot of this information I would claim is anecdotal
at best. The information needs a good peer review.
Right now, I don't know of any studies that are out there that have been using any of the technology
that 5G employs with the beam forming and all that, which would in my opinion, tend to decrease the
radiation that's normally being put out there. But we're not there. We're not in a place where we can
make a recommendation. And when you have somebody have insurance for this or that, I don't
particularly see that one either. I don't see that we have a good scientific basis to make much of a
recommendation at all.
Abrami: Thank you, Jim. Here's what we got before us. I think municipalities would be looking for us to
give them some guidance. That's at a level that this really plays out at. It's really cell companies coming
into a city or a town and saying we want permitting rights to put on top of telephone poles or install
new polls or small cells. I think the majority report really has got to focus back on the small cell towers
because that's the issue, that's the 5G. And as I've said over and over again, 5G mean something to
every cellular company. It is just a concept. Each interacts with 3G and 4G differently. And a lot of its
proprietary, so we have no idea what's inside those antennas and how those antennas are configured.
What we do know and we can measure once installed, is the power intensity coming out of those
towers. But we should say that a town should be able to say yes, we'll allow you to put in a cell tower
but want to be able to periodically measure the intensity coming out of those small cell towers. Gary,
did you just sign on?
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Woods: Yes, I did. I'm in Nashville and I don't know what happened. I saw the notice that Kent put out
to start at nine. Then, I got a notice that it was cancelled. My apologies.
Abrami: OK. Well, let me follow through and we will give you a chance to weigh in. Okay?
So, right now the, the standard's at, let's call it ten watts per meter squared is the US standard. But
some of the other countries have set the standard much lower than that. Australia is two watts per
meter squared. Canada is three watts per meter squared, but we're way up to ten watts per meter
squared. So, I would think at the very least, and I don't see why this would be a problem for us to say to
the cellular companies yeah, if you install these, a municipality has the right to monitor the intensity
coming out. And I don't know why cellular companies would have a problem with that. There's going to
be a working group where we'll put it in a recommendation from for the next meeting that we could go
one by one and have a discussion around each of these. All of the things that were mentioned today will
be grouped and, and then we will have to as a group at our next meeting really have that discussion
around each. But for today, we're just talking about ideas.
So again, this comment is for Beth. I don't know, why the cellular company would object to a town
being able to measure what's coming out of those towers and having us have that part of the agreement
with the town. If those towers are on our end are out of sync with what the standard is, then those
towers have to be turned off, something to that effect. So that's just one thought.
And one that Brandon, I'm going to have you weigh in on too is I looked at the documents that came
out from other municipalities of what they've tried to do. One states requiring permittees to defend and
indemnify the municipalities from any liabilities arising from installation, operation and maintenance of
small cell installations. But why would the cellular industry, if they feel this is safe, not be willing to sign
off on a permit that that allows this? Because it's the town that's bringing in the cellular companies and
the towns are going to be, why should we have our municipalities be unprotected if there is indeed
damage? We, as a commission are hearing both sides of this. And there could be. It's hard to say
definitively. We've all heard and I think everybody's kind of agreeing that there's evidence of potential
harm. But cellular companies are saying, no, there's no harm. And the FCC saying, no, there's no harm.
The FDA says, no, there's no harm. Well good. If there's no harm, then why hold our communities liable
for damages? So that's, that's one that I think we should we should be talking about.
I think we should be pressing the FCC. That's my third point. As a statutory commission, as Tom points
out, I would just stress with them why are standards set so high? We know there are no biological
effects that play into this standard. How can Australia or New Zealand be at .5 watts per meter squared
and successfully roll out 5G? They are going to roll it out,I would imagine, with a lot less power intensity.
Remember, those towers are going to be at the height of the telephone pole. Most of them are going to
be stuck on top of the telephone poles. We also know, as commissioners, that we see the push back
going on around the country. You know the industry likes it or not, there are a lot of people looking at
this getting the message out that there's this potential danger. So the public is aware of this and there's
going to be push back for communities on town selectmen and other boards to deal with this. My fourth
point, I agree with some of those that said that we should as one of the recommendations, which is kind
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of a neutral recommendation that we would share this with the federal government agencies that a
more robust study should be done on 5G. That should be pretty neutral.
Other communities have looked at simple ordinances and loopholes. How many streets are off limits?
Now, I don't know how enforceable that one really is. But some communities have that, are trying to do
that. Others have mentioned setbacks. I think Dr. Heroux mentioned that. There are towns that are
talking about setbacks, a 500 feet from residences, businesses, schools. Again, that's something that
that we could talk about. But if it's on top of a telephone pole in front of your house, you walk under the
telephone pole and that's where the greatest intensity is going to be right by the pole. That's something
that we will address.
Something that came up from the last speaker we had is requiring power density disclosures for renters
and buyers, public buildings, locations where general public may go. That's something that I think we
should discuss to see if we can make that into a recommendation of some kind. Another community
was trying to say, let's have all poles with 5G antenna have warning signs that RF radiation is being
emitted above. That's a simple thing. Again, I don't know why the industry would object to that. Some
people would want to know that there's RF radiation being emitted above. So those are some of the
things that we can look at as a group.
Brandon, in terms of the liability issue, do you have any comment on that?
Garod: What specific liability issue here you're asking about?
Abrami: Well, I'll read it again that some communities are requiring, permittees, meaning the cellular
companies, to defend and indemnify the municipality for any liabilities arising from permits and
installation, operation and maintenance of small cell installations. The point is to hold the municipality
harmless if someone could prove that they were damaged from the small cell towers.
Garod: I think that to the extent that municipalities are making that a condition of receiving a permit, it
would be a law or regulation that's specifically preempted by federal law. This is really where the rub is.
The communities, the municipalities, the towns, the cities... they're the ones that control the permitting.
You have to go through a permitting process and you have to be approved and any law that's passed,
that is a barrier to telecommunications coming in that's passed by state, is specifically preempted unless
you can meet one of a few carve outs. The carve outs create another barrier. Unless the state has
specifically delegated to the towns and municipalities, the ability to regulate telecommunications in any
capacity, that doesn't even apply. It's only the state that has the ability to use those carve outs as like a
safe haven for a law that serves as a barrier for telecom. And I'm not clear as whether New Hampshire
has delegated any of that authority to the municipalities. But there's a lot of litigation since this thing
was enacted in 1996 and it's usually a municipality trying to pass something. And the way that the
telecom companies are able to beat it is by saying that they're trying to say that it's for public health and
safety or for consumer protection, or to protect right of ways. Those are the specific carve-outs. But
unless this state has specifically delegated to those communities, you can't even use those carve outs as
a defense. I think there's a good chance that it would be preempted. Really, I'm not an expert. That's
basically what I've come up with so far.
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Abrami: I agree that the state legislature would have to enable the municipalities to do that. Is that
what you're saying?
Garod: If there was a specific delegation from the state of New Hampshire to the municipalities to be
able to regulate telecommunications coming in, in any capacity, then the municipalities would have to
show that any regulation that they passed, which served as a barrier to telecommunications coming in,
fits one of the few carve outs under the Telecommunications Act of 1996. And in trying to find a good
case to use as a standard, it's almost never been done.
Abrami: Ok, well, so that's why we have the AG's office is represented to give us those insights.
Sherman: Brandon, I have a question for you from what you said. Why do the telecommunications
industries have to come in and get a permit if everything is federal? On what basis could a town deny a
permit? So in other words, is the permitting process just a rubber stamp? If you don't permit, they're
going to take you to court. You know, they can come in any way with or without a permit with or
without municipal law, with or without state law. Is there anything that a municipality can do to stop the
installation of these antennae and 5G technology?
Garod: To answer your first question, which I believe was, why would they need a permit? They might
not under every circumstance. But imagine what the companies are trying to do is come into a town and
build several new towers, to build several new receiver or to build infrastructure they would have to
apply to the town for, you know, building permits or in order to do construction within the town. There
are laws that determine what sort of process you have to go through in order to be able to come into
the town and build something. If there is a specific limitation on telecommunications, being able to do
that, that is passed by the town...that's specifically what is preempted by federal law. Because federal
law determines when telecommunications can come in and what they can do. So it's frustrating because
you would think that at the municipal level that would be who is in the best position to determine
what's best for your individual town. I think what I can say for certain, I don't know if there's anything
that can be done, but what definitely can't be done is any sort of regulation that amounts to any sort of
barrier to telecom coming into the town and installing new infrastructure.
Sherman: So the follow-up would be if a town doesn't want 5G, they just deny the permit.
Garod: Well, I think you have to have a basis to do it. I'm not a local government guy, so I don't know.
Ricciardi: I can answer the question what Senator Sherman was asking. So the reason there is a
permitting process is each town has zoning laws in place. And the telecommunications company, when
they come into your town and they want to put a cellphone tower, they do have to show that there is a
need and that this is the only location and that they checked everywhere else. So it does go before our
zoning board here in Bedford. Everybody's zoning has different regulation. The zoning we have in place
is not a barrier to the telecommunications, but it is definitive things that we have put in place that are
allowable by law. So for example, we have the 750 foot setback from any residential neighborhood in
our town now and was put before the voters and voted on. So there are things like that that you can do.
The other thing that you can do that is legal, that we have just completed is a "wires and poles" town
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ordinance. So we did not single out the telecommunications. We did not say this is just to keep the rules
in place for them, but it is all utilities, wires, and poles. And in that section, there are some very strict
but allowable bylaw criteria. If 5G were to come and it's beyond our control because the FCC, so we put
allowable things in place. And when you do this, you're protecting the residents of your town. But you'r
making it more difficult, but it's across the board for all utilities. So by not singling out, then it can't be
done. Anyone on our commission, and your towns, I'd be happy to provide a copy of what we just
completed.
Abrami: Okay. Well, that that's something that I think would be helpful and that, you know, I think you
have some specific recommendations that we're going to vet as a group in the next couple of weeks.
Ken, do you have another leading question? I think Beth wants to respond. Would you mind if Beth
responds?
Cooley: Yeah, I think the only thing I'd add to Denise's comments in terms of what a locality can do,
technically, every locality should be complying with the FCC order that went into effect in January of 19.
There could also be state laws as well. We've got 29 states and Puerto Rico that have passed laws that
also need to be in compliance with their state law. But in terms of what Denise already outlined,
localities also have say over aesthetics. In the FCC order, so long as aesthetics are reasonable, objective,
and non-discriminatory. And that's what Denise was talking about when she was saying all utilities in the
right away. That's the nondiscriminatory part. So in terms of an ordinance, that's also what you can
outline is if everything in the right away is green, then we needed to be green and things like that. So
just to piggyback off of what Denise outlined, that's how the process works. You do need to get a
building permit. You can't just go in and build. Local governments also have the ability to deny a permit
on the basis of public safety issues. So for example, if you're doing sidewalk work and the sidewalk is no
longer wide enough for wheelchair that can be denied under ADA compliance. Public safety can also
circumstance can also be where if a small cell would impede the vision of a driver around learner or a
traffic light, things like that. So there's a process passing ordinances helpful to outline where control is
retained in terms of the build out, but we'd also be happy to work with you. There are other
communities in New Hampshire that have also passed small cell ordinances that we'd be happy to share.
So thank you Rep. Abrami for allowing me to comment.
Wells: Looking at this as a physicist, it seems to me that there is an artificial distinction made between
different types of RF emitters when in fact RF differs only in intensity and frequency and polarization
and so forth. I'd like to see if we could get someone to look into why telecom is subjected one set of
standards where say in FCC Class D, broadcast transmitter is limited to a certain number of megawatts
per square meter at the property line. And so I think that this is something to look into. Why is there an
inconsistency in what the power levels are allowed to be because the power levels on 5G are
astronomically higher than they are for broadcast.
Abrami: We will see what we can do there. Ken, thanks. Gary, what we've been doing is everybody's
been chiming in with some thoughts and potential recommendations to get the juices flowing here.
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Woods: I have some thoughts thinking more as a physicist and where we are and our understanding of
some of the basic processes or lack of understanding of the basic processes are, to me still troublesome.
I tried to think of this in a number of dimensions. One of which is what I call the sort of the "arc of
understanding". This is a little bit of sidebar, but hopefully it'll all come together in a second. When we
looked about the human body, we had gross anatomy, the dissected anatomy, microscopic anatomy,
cellular anatomy, chemical anatomy, synthetic biology. Then we focus down and then we've got the
genetic code with at all we got all the answers now. Well now we don't have all the answers even
though you have the genetic code. We know there's now epigenetics and we're learning more as we go
along. To me, we're at the sort of the almost gross anatomy levels with microwaves. We're still talking
about the impact from what we call a bulk material, irradiate a mouse total and see what happens. And
it doesn't give us an understanding of the potential mechanisms.
You say, well, why do we need to understand the mechanisms? Well, let's give an example of a tornado.
Sort of normal atmospheric conditions exist and all of a sudden a tornado appears because you've got a
very confluence of a lot of factors that come into play that can create an isolated event. And we see that
in a variety of things where seemingly normal processes result in a very abnormal event. And we know
how to look at that. Chaos theory from a mathematical perspective has done that. And I'm sure Dr.
Chamberlain probably teaches courses on for what are called Fourier transforms, where you'd take
seemingly very, very benign smooth waves, you put them together and you get this big spike. So these
things that occur and we're at that point, from my perspective, of beginning to understand the
confluence of these things at the molecular level. And so this arc of understanding has not come down
far enough for my perspective, for me to feel comfortable.
And I think there is a line in the Cyprus thing that I thought sort of synthesized my thoughts. And it said
"that the potential aggregation and dynamic interaction with other signals". I think that's really crucial
for us to understand. It's not just 5G coming in. And our last speaker talked about precursors, which is
sort of the same sort of thing. You have a signal coming in and then it turns out it interacts and creates a
different signal. And we'd make use of this in biology already in orthopedics. Being a retired orthopedic
surgeon, we use magnetic pulsed impulses to enhance bone healing. And that's you're creating a field at
the molecular level. Because we know our bone is basically what's called a piezoelectric material and it
depends on electrical currents to do its job and stay strong. That's why you go up in space. You don't
have gravity, that piezoelectric phenomenon doesn't exist. And you'd have bone loss. But that's an
example of the kinds of interactions.
Epigenomic part is another example. And a lot of these processes, and we touched on this very briefly
when the issue of proton tunneling came up. That's at an extraordinarily low energy level and secondary
internal processes make that occur and change all the time. And we know that things, simple, things like
the configuration of an enzyme is a configuration of proteins in general. It is highly dependent on these
hydrogen bonds, which are susceptible to proton tunneling. And as a consequence, all these processes
we have, we really don't have an idea of how these work and some of the secondary processes. We're
back up the "arc of understanding" at the bulk material level. And until we can get further down. And
we will eventually, but to me, we're not there yet. So I just wanted to offer that as a concern, At least
from my perspective, a concern of where we are in terms of the science. And I'll leave it at that.
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Abrami: That said. We don't know what we don't know. Thank you for dialing in from your vacation.
Everybody's had a chance to weigh in. And what let's talk about next steps here. What I mentioned, the
last meeting, I think we should form a work group to take these ideas.I asked for volunteers. I got
Representative Wells, Dr. Chamberlin, Denise Riccardi, Carol Miller, Dr. Heroux, and myself that will
meet as a work group, to at least put some ideas on paper. We threw a lot of the ideas around here
today. We have to do, as a group is take each one of those ideas and see if it will pass muster as a
recommendation in our report. And so that's what I think what we'll do. I will work with those people
and set up a meeting to do that and then maybe have to meet once or twice before our next meeting.
We're running out of time now. We have three months left. I did say I was going to try to follow up to
see if we get an extension on the date, but because we go to the next Legislature, I think they really
want us to have our report out by November first. So that's what we'll continue to shoot for. So any
objection to what I just said? I think that we've got a small work group that will work on this and put
recommendations on paper and will get that out to everybody.
And at the next meeting we'll go through each one of those and have a discussion around each one of
those to see if there's support for it or not support for it. And having the discussion, some of the
discussions we just had, the science discussions, but also the legal discussions as to what we can make
work for municipalities. What message we want to send to the federal government about this
delegation or other ways.
Sherman: I just wanted to remind everybody, you know many of us have served on many commissions
and committees. And I believe if there is a dissenting view to whatever the majority wants, there is the
capacity for Minority Report. Is that not correct?
Abrami: That's correct.
Sherman: So I'm just saying that not because I'm encouraging a Minority Report, but because for people
who haven't served on commissions or members of the public, the goal is to reach some level of
consensus, but perhaps not unanimity. And, and so we may end up with two reports and that's just the
way Commissions work.
Abrami: Yes. I think I mentioned that the past. Yes. That's the way commissions work. Okay. Which
brings us to Denise. I want you to just weigh in a little bit on the lack of the response to nonresponse
response we got from the FDA.
Ricciardi: So I sent several questions to the FDA and the National Cancer Institute regarding answers
that are very important to this commission and our decision making. The questions were ignored at first.
After I kept at it, I got a response that was not an answer to the question. I point blank, asked and
numbered the questions and said we need an answer to each question not linked to their website that
we already know that we already have. That's very frustrating. And that was the situation on both
counts with the FDA and the National Cancer Institute. So I tried to reach our United States senators
offices and finally yesterday I spoke with a staff member in constituent services. And I have forwarded
our questions to that office. And I feel at this point, it's going to take our U.S. senator to insist they
answer the questions. And I find it very telling that they don't want to answer them. We are a
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commission with a very important task and I don't understand why they want to answer these
questions. I'll give you an example. I'll read one of my questions. The FDA is aware that cell phones
violate the FCC SAR limits at body contact on high power. The FDA has written that because it's safety
factor and that's what they do. What is the safety factor for SAR the FDA relies on and at what SAR level
above the FCC limits will the FDA intervene? So they have written that that it is not safe on body
contact, but then they don't do anything about it. And why will they answer one simple question? That's
just an example. So that's where we're at. I'm still waiting.
Abrami: Tom, I'm going to ask you to help us out with that and try to get maybe Senator Shaheen or
someone to help us out with that.
Sherman: I am happy to.
Ricciardi: It's her office that I spoke with. It wouldn't hurt to have you follow up as well.
Sherman: I can call I their state directors. I reached out to them about the FCC and we didn't get
anywhere. It's not because they didn't try but because they didn't get a response. It's frustrating.
Abrami: So if, if the commission doesn't mind, you all remember Theodora from Environmental Health
Trust. She had reached out to me about the FCC and if you don't mind if we give it a few minutes and
then Beth, if there's anybody on this that from the industry that wants to respond, we will give them
that opportunity as well. So if you don't mind, we'll have Theodora spend a few minutes. We have about
a half hour left.
Scarato: Thank you so much. I had sent over and just wanted to make everyone aware of the
documentation that I received from the EPA with a lot of questions. Their response to my questions was
that the EPA's last review was in 1984 in terms of biological effects and they gave they cited that you
should all have a copy of the questions and the answers. Just to go over what the EPA said. I said what's
the research? Has EPA reviewed the research on damaged memory? They say they don't have a funded
mandate for radio frequency matters. And in regards to the birds, bees, and trees, what's really
important is that the limits were not set of course for birds, bees or trees and the EPA seem to confirm
that in the answers that they sent. Also in regards to the safety factor, I would note that I think this is a
really important question, so I'm glad it's being asked because it said that there's a 50 time safety factor.
But when it comes to phones against the body, is certainly couldn't possibly be a 50 times safety factor
for that in terms of the heating effect. So want to make sure you have that as well as the scientific
letters that were sent to the FDA in regards to their report, their literature review on only cancer. They
didn't look at other end points comprehensively. And you'll notice that Dr. Albert Manville, the former
fish and wildlife lead, who is now retired, wrote stating that the current FDA statement is irresponsible,
unfounded, and sets a dangerous precedent and so on. But please take a look at those letters that were
sent by the scientists regard to the FDA. So thank you.
Abrami: Thank you. I think I did send that out to everybody. And if I recall, each response to each one of
those was "that's not our mandate"....Something like that. Is that correct? Right. So we have got it
because Congress has mandated us look at this, something to that effect. Again, next steps are going to
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be getting the working together a couple of times. In terms of the next meeting, we could try to put a
stake in the ground and come up with a date while everybody's on the Zoom meeting here. Are people
on vacation? Are they staying local? August 28th? Who cannot make August 28th at 09:00 AM? Brandon
can't. I want to make sure the Working Committee has enough time to do what they have got to do.
Sherman: I'm on vacation on the 28th, but I can do it anyway. I could do Monday, the 31st if that
worked. I don't mind dialing in. It's no problem.
Okay. Okay. How about Monday the 31st? Anybody can't make money to 31st? Okay, why don't we
save that date, the 31st at 9 am. I'm going to reach out to the folks who volunteered and we'll come up
with some dates for us to get together in between. So well, we've got about 25 minutes. Is there any
other general discussion we would like to engage in? If not, I'd like to open this up to any other folks on
the on the Zoom meeting that our guests, if they'd like to weigh in. I would allow that now because we
have time. Does anybody else want to weigh in? Questions? Comments? suggestions?
Bloede: Yes. Oh, can I speak? I am Paul Bloede from Coloradans for Safe Technology. We had a meeting
recently, Zoom meeting with an attorney that I wonder if your organization is familiar with this national
level Attorney. His name is Julian Gresser. And he had a lot of comments about the legal state around
the country of this whole issue and I thought he was very incisive and we have a transcript now with his
presentation to us, we have that transcript just from last week as a PDF file. I didn't know if that would
be of interest. How I could get that file to any of you, should that be of interest?
Abrami: Can you get that to me?
Bloede: Yes. Do you have an email address?
Abrami: Yes. Use abrami.nhrep(5)gmail.com.
Bloede: Yes, definitely. I will get that out to you. I think you will find it interesting hopefully.
Abrami: I'll get it out the others. Okay, thank you. Cece?
Doucette: Thank you Rep Abrami. When I first started investigating the wireless radiation issue, I
thought as soon as we saw that it's especially harmful to children, that my school would have jumped up
immediately and shut off the wifi in schools.
Abrami: Cece, why don't you back up and explain your involvement in this.
Doucette: Okay. I spent several years at Ashland Public Schools in Massachusetts doing fundraising for
what we kept hearing our kids would need to succeed in the world. And that was basically the 21st
century classroom, which is an industry campaign to introduce wireless into our school systems. And I
had spent many years doing fundraising because our town didn't have the budget for that. I started
looking and an engineer friend of mine tipped me off that there could be harm. So I started my
investigation and I came up with a few studies that were saying no harm. I didn't understand at that
point that "no harm" is not the same thing as "safe", right? So I started looking a little bit deeper and
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then I start finding peer-reviewed studies all over the world showing great biological effects. And the set
of studies that got me on my feet were the sperm studies, where they've taken male human sperm and
expose it to a laptop with the antennas on. And it changed the DNA, it slowed the motility in it cause far
fewer sperm to be viable in just four hours of exposure.
We had just bought my youngest daughter a laptop going into high school. And of course she's using it
right on top of her reproductive organs. So that was the day that I got involved in this. I have helped
introduce legislation here in Massachusetts and I wish we were as swift as New Hampshire is. My bill has
been in play for six years. There are others on the utility smart meters that had been in play for eight
years. But even during this pandemic and the racial justice movement that's happening, our legislature is
finally advancing three of our bills, so we're hopeful that that will happen here.
Early on in my journey, others who talked to me about legal action and I don't know anything about
that. I didn't want to see lawsuits come into play. I just wanted us to do the right thing and especially
protect our children. But then I got to listen to a conversation with somebody who was referencing
Martin Luther King Jr. And what MLK was teaching us is that in order for important societal changes to
happen, it happens through three channels. 1. The public gets educated and speaks up and thank you to
Deb Hodgdon for being the catalyst in New Hampshire who then spoke to Rep Abrami, who then drove
down to my kitchen table here in Massachusetts. We had a long conversation about wireless. 2. There is
legal action that happens to hold those who have infringed upon our rights, accountable. 3. Public policy
ultimately catches up with the science or whatever else the issue is. So as much as it makes me
uncomfortable to think about legal action, it's part of how change happens.
So to our Attorneys General, I hope you will look at this as seriously as you looked at tobacco and do the
right thing, reach out to your colleagues and other states, get this conversation going. My understanding
is the industry has already set aside billions for the lawsuits that are going to happen. But we cannot
afford to continue to expose our children even during this pandemic, handing out hot spots without any
information on how to use technology safely. So I implore you as a mother, as a woman who fell down
this rabbit hole which I never wished to be in. But once you know the harm, you can't "un-know" it. And
we have to use every resource that is available to us to start protecting our children, especially right
now. So thank you for your time. I hope the commission will report out favorably something that we can
hold up with pride and say, thank you to New Hampshire for being our nation's leader. And then we can
follow suit in our states too.
Abrami: Thank you, Cece. Is there anybody else that would like to weigh in at all? Okay. I don't see any.l
I guess we will be adjourning. We will see everybody on August 31st at 9. And then, in the meantime
the subgroup will be meeting. Did I mention that we're recording the meeting? I thank everybody for
your time. Thank you to those who have tuned in from afar. Those on the Working Group, I will get an
email later today with some dates that we can get together. Okay. Is there a Motion to adjourn?
Woods: I was the latest but I will make a motion to adjourn.
Abrami: motion to second by Carol. Without objection, we're adjourned.
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V. Next meeting via Zoom: August 31st 9-11
Meeting Adjourned at 10:43 am
Text chat during Zoom meeting:
00:30:12 Bruce L. Cragin: ???
00:30:45 Bruce L. Cragin: ???
00:41:30 Bruce L. Cragin: Yes bring back Swanson!
00:43:58 Cece Doucette: Hawaii County Council just passed their 5G ban
00:45:51 Bruce L. Cragin: Ha
00:50:10 EH Trust: There have been attempts to overturn the Telecom Act section 704.
Some links her ehttps://ehtrust.org/policy/the-telecommunications-act-of-1996/
00:51:17 Christine.melkonian: YES, to public awareness
00:54:54 Cece Doucette: It was our state attorneys general banding together and suing the
tobacco industry that finally brought the toxic effects mainstream. Perhaps the Commission can
recommend that NH lead an effort for attorneys general to band together on wireless too, which if
successful, would help to provide the funding to put safe, fast, sustainable technology in place. I believe
NH still receives funding from the tobacco industry lawsuit today.
01:01:20 EH Trust: Also the Telecom Act Research continues to show effects from power
lines. See studies here https://ehtrust.org/science/research-on-magnetic-fields-extremely-low-
frequency-electromagnetic-fields-cancer-and-miscarriage/
01:02:08 EH Trust: Many countries have protective limits in regards to power lines, over a
dozen. They set limits at the level linked to cancer in children. But the US has no limit at all.
https://ehtrust.org/policy/international-policy-actions-on-wireless/
01:02:29 Bruce L. Cragin: Exactly, Sen. Gray. So much fearmongering.
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01:03:56 EH Trust: Two published studies by the Ramazzini Institute "Carcinogenic
Synergism of S-50 Hz MF Plus Formaldehyde in Rats" (2016) and "Life-span exposure to sinusoidal-50 Hz
magnetic field and acute low-dose y radiation induce carcinogenic effects in Sprague-Dawley rats"
(2016) found that ELF exposed rats had statistically significant increased incidence of several type of
malignant tumors when combined with a known
carcinogen.http://onlinelibrary.wiley.com/doi/10.1002/ajim.22598/full
01:04:44 Bruce L. Cragin: And here comes some more AAA
01:12:17 Bruce L. Cragin: Re. A., you're hearing ONE sde, not both.
01:33:08 Bruce L. Cragin: Physicians are not physicists.
01:33:27 Ken Wells: Bruce: This one is
01:33:48 Bruce L. Cragin: You, Ken? or Gary?
01:34:08 Ken Wells: Dr. Woods
01:34:35 Bruce L. Cragin: Thabk you. I will contact him.
01:37:54 Bruce L. Cragin: http://bobpark.physics.umd.edu/WN10/wnl21010.html
01:39:17 Bruce L. Cragin: Sorry, I meant https://quackwatch.org/related/signs/
01:44:10 Bruce L. Cragin: https://americanbeejournal.com/why-we-shouldnt-fear-5g/
01:45:48 EH Trust: The FDA scientists letters are found here https://ehtrust.org/doctors-
slam-fda-report-on-cell-phones-cancer-and-health-effects/
01:46:04 EH Trust: Dr. Manville https://ehtrust.org/press-statement-from-dr-albert-
manville-on-the-fda-report-on-cell-phone-radiation-2/
01:46:38 EH Trust: The EPA letter can be found here https://ehtrust.org/epa-birds-bees-
trees-5g-wireless-effects/
01:47:05 Bruce L. Cragin: "FDA scientists" or activist scientists?
01:47:24 EH Trust: The letter from scientists to the FDA.
01:47:42 Bruce L. Cragin: Yes that's more honest.
01:47:49 EH Trust: NIH scientists, experts internally signed, several on the world health
organization emf group
01:50:20 EH Trust: Several of the scientists are expert advisors to the World Health
organization who are asking the FDA to retract their flawed report on the studies.
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01:54:13
Christine.melkonian: YES
01:54:20 Bruce L. Cragin: I give up. You people are just lost. The idea that a commission of
legiislators has the scientific capability to meaningfully question the standards is ridiculous.
01:54:26 EH Trust: Resources on Wi-Fi in School https://ehtrust.org/wifi-in-schools-tool-
kit/
01:55:14 Ken Wells: Aug 31 at 9am
01:55:47 Christine.melkonian: Thank you so much
01:56:28 Cece Doucette: Thank you to the commission members and others, please feel free to
reach out if there is anything I may help with, c2douce@gmail.com
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
8/31/20
9:00-11:00 am EST
Via Zoom (https://unh.zoom.us/j795489344931)
Via telephone-US (1 312 626 6799 (US Toll) ID: 954 8934 4931)
In attendance:(12)
Rep. Patrick Abrami-speaker of the house appointee
Rep. Ken Wells- speaker of the house appointee
Kent Chamberlin-UNH-appointed by the chancellor
Denise Ricciardi-public-appointed by the governor
Michele Roberge-DHHS- Commissioner of DHHS appointee
Dr. Paul Heroux- Professor of Toxicology, McGill University- speaker of the house appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Senator Tom Sherman-president of the senate appointee
Brandon Garod-AG designee, Asst. AG Consumer Protection
Bethanne Cooley-CTIA, trade association for wireless industry and manufacturers
Carol Miller-NH Business & Economic Affairs Dept
Not present: (1)
David Juvet-Business and Industry Association
Meeting called to order by Rep Abrami at 9:05 am
Abrami: Due to the Covid 19 virus and the Executive order signed by the Governor this public meeting is
allowed to be conducted via Zoom. It is open to the public for viewing and was duly posted as a zoom
meeting. With that said, if you are not a member of the Commission, can you please turn your cameras
off and mute yourselves? That would be much appreciated. In addition the meeting is being recorded as
an aid to doing the minutes. All chat room discussions will be included in the minutes.
I. Approval of minutes from 7-24-20:
I have not received any comments or changes to the minutes. Are there any changes? Without
objection, we approve the minutes from that meeting.
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II: Proposed report format/ Procedural Discussion:
Abrami: We also sent out a copy of the agenda and the proposed final report format and
recommendations the work group has been working on. That's the primary reason for the meeting is to
talk about those and if there are any other recommendations. This is what I am thinking about the
report: Preamble, Definition of Terms, Physics, Study process (who we heard from, etc.), then a section
of the questions posed by the Commission in the legislation and the answers, our recommendations.
What we consider firm recommendations for lack of a better word and also listing some other things
that we decided not to make recommendations. There will also be appendices and supporting
documentation for the recommendations and of course the minutes will be attached to the report. This
is what I am thinking but I am open to any changes. Are there any questions on that?
Cooley: Rep Abrami, just one question on that. In the outline, where would a minority report or
dissenting opinion fit it?
Abrami: I will double check this but it's a separate report that gets attached to this report. I know there
will likely by a minority report which is fine. I will get clarification on that. It was easier when we were at
the state house and I could just walk over and ask but I will get clarification on that. OK?
Cooley: Yes, thank you.
Abrami: There is a work group that consists of seven members: Carol, Denise, Gary, Ken, Kent, Paul and
myself. There are seven of the twelve members that have been active. The working group met three
times. We started with a baseline often recommendations and we have done several iterations on
these. Obviously, these are open to discussion today whether you think they should or should not be in
the report, etc. Since I sent these to you I have gotten two updated versions that I sent to you this
morning. Sorry it was late. One is from Paul with some minor changes. One is from Jim with some major
changes. Hopefully, you have seen them.
Sherman: Pat, I also sent some minor edits to Paul's version this morning.
Abrami: ok. I didn't see those. So can you chime in when we get there? What we will do is take them
one at a time and have a discussion around each one. I had a communication with Beth about, do we
really want to take a vote on these today given that you have just received them this weekend. What we
can do is take a straw poll to see where we are on each one of them and not be an official vote. When
we do a final vote on these, if the majority votes yes, it will be in the report as a firm recommendation. If
not, then it's not. After that, we will have a vote on the report with everything in it. There are twelve
members that are active, so if it ends up 6-6, I will have to figure out what that means.
What I would like to hear from you today possibly three things. 1. I like it the way it's written. 2. I would
like to make some changes then I could support it. 3. No matter what, I don't think this recommendation
is needed. Certain members of the working group took charge of certain recommendations so I will ask
them to describe the recommendation and what the motivation was behind it. If there are any other
recommendations please let us know in this meeting and we can deal with those.
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Sherman: Before we go to Recommendation 1, can I just make a comment on the first paragraph?
Abrami: Sure
Sherman: This is a great sentence but it's very long. On the last one it says thus the commission ..." I
think it would be clearer if you had a period and the words, "given these considerations, the commission
yields". My feeling is that it's fine but I would have the last sentence be independent. That's in my edits
for what it's worth.
Abrami: I get it. That's a good one.
Wells: I submitted an edited version of this one and changed it into a bullet list.
Abrami: ok. Boy, I am behind in my email. I missed that one too.
Miller: Which document should we be looking at? The original and everyone can chime in with their
changes? I have multiple versions open and I don't know which one I am looking at any more. I think the
one that you sent was Revision 3. Correct?
Abrami: Yes. If you see red in there, that means there were changes.
Sherman: which one did you send?
Miller: It was Revision_3 5G Recommendations.docx
Gray: since we are commenting on the first paragraph, I took out a couple of different things in my
revision. I think that whoever puts this thing together at the end should consider removing and only
presenting facts and not things that aren't facts.
Abrami: What you are saying is that the things that you crossed out aren't factual.
Gray: Right. You talk about the whole insurance industry, well that's not true, ok? The insurance industry
if you leave it like that is more accurate. In the next sentence down you say "because of" instead of "due
to potential harm". Thank you.
Abrami: I agree with those. These are good ones.
Gray: The word "determined" is used many places. In my edits part of my suggestion is that we take that
out and replace it with the word "believe". The definition of determined is that it's found to be a fact or
conclusive. In the first paragraph of the report we say that none of this is found to be a fact so again...
take that word out and replace it with believe or a word of your choice. That would be a good revision.
Sherman: If you are anticipating a Minority Report, then wherever you have "the Commission has
concluded" should be changed to the Majority or this Majority of the Commission has concluded...
because you are going to have a Minority Report that has not concluded that necessarily. I think you will
be a little more accurate using that phrase in the Majority report. That's only if there is going to be a
Minority Report to recognize that the entire commission does not agree with this report.
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Abrami: That's a good point, Tom. I anticipate there is going to be a Minority Report.
Gray: I will write it.
Abrami: Ok. So we are going to have a Minority report. Anyone who wants input into it can send me
their comments.
Roberge: I haven't had a chance to talk with my leadership from DHHS on any of these
recommendations so I may have additional comments from a resource perspective once I have had a
chance to look these over with leadership. Also, I know we talked about this at the last meeting about
not formally taking a position on the recommendations just due to the role of the department. I think
we would just want to have a statement in the report reflective of that.
Abrami: right. It will say effectively that the recommendations do not necessarily reflect the position of
any agency, Attorney General's office or Dept of Health and Human Services.
Ill: Workgroup recommendations and discussion:
RECOMMENDATION 1- Propose a joint resolution of the NH Senate and House to the US
Congress and Executive Branch to require a review of the current radiofrequency (RF)
standards of the electromagnetic radiation in the 300MHz to 300GHz microwave spectrum,
used to measure exposure and health study to mitigate the health risks associated with the
use of cellular communications and data transmittal, promulgated by the Federal
Communications Commission (FCC).
Cooley: With the whole caveat that I received these Saturday morning and have not spoken with my
members or with legal dept. so that will be my disclaimer throughout all of this discussion. My one
question about this recommendation.... The first sentence of the last paragraph that says, " this
commission believes that EMR is on the path to be confirmed as a class I carcinogen, where does that
information come from? Is there a footnote? How is that assumption being presumed?
Miller: Recommendation 1 is a merger of something that I had written and Paul had written. That
particular phrase came from Paul. Can you speak to that?
Heroux: Essentially that would refer to an article by an epidemiologist Anthony Miller who is very active
with IARC. In other words, IARC has agreed to review the situation and in the last report what was
missing was animal evidence and its likely there will be an upgrade to the classification because you
have two major studies NTP and Ramazzini that now provide animal evidence.
Abrami: We need to refer to the papers either as a footnote or in the appendix.
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Cooley: I think a footnote, Mr. Chair might be helpful because this is someone who has not presented
before the Commission. I don't know who they are and it's the opinion of one person. I think backing up
that claim or allegation would be helpful.
Abrami: The gist of recommendation 1 and I don't know Beth, why your organization would not think it's
a good idea saying that we do have more to study. That's basically the thrust of this. There are a lot of
organizations asking for this. Carol, why don't you spend a few minutes on this.
Miller: This is a joint resolution of the New Hampshire Senate and House to the US Congress and
Executive Branch just requiring a review of the current RF standards and asking for a health study. The
un-highlighted text is just back up and could probably be moved to the appendix. I don't know if anyone
has any questions about that particular recommendation. I think it's pretty straight forward.
Sherman: I thought the recommendation was fine. It was straightforward but I thought there was a
clearer way to describe what we are trying to get done. The edit that I suggested would read: " Propose
a joint resolution of the NH Senate and House to US Congress and Executive Branch to require the FCC
to conduct or commission a review of the current RF standard of EMR in the 300Mz-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". I just think it's the active which makes it
clearer than passive.
Miller: So you are suggestion after the word "require" to put the "FCC" right there.
Sherman: yes and after the word, "spectrum" I would use the words "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".
Miller: I am ok with that. Anybody else have an opinion about that?
Abrami: That's fine with me. Does anybody have a problem with that?
Gray: Again, I have made many changes in my edits and I don't object to many of the words that Dr.
Sherman has put forward but I still think the rest of those paragraphs need to be looked at. When I read
this report for the first time, it was very clear to me that someone who was a very big proponent of
eliminating 5G or wifi, entirely, wrote this thing. That's not our job as a commission. I encourage you to
take a look at my edits. I tried not to gut your proposals but to make it more neutral while still putting
forth your proposals. Thank you.
Abrami: The work group will be meeting again on Friday. We have got our work cut out to try to pull all
of these together. I am sure some of your words are going to make it into the report, Jim. The bigger
question right now is who is opposed to having a joint resolution where we say that more study is
needed on this topic? Who is opposed to that? We can tinker with the words.
Gray: I am not opposed to having a study but I want you guys to know that the reality of having a joint
House/Senate Resolution is practically nil. The Senate has these resolutions and has determined that it's
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better for the citizens to go out individually contact their Congressmen than to do one of these
resolutions.
Abrami: It is our understanding on the House side that the Senate doesn't like joint resolutions. We
were trying to give it a little more umpf. No matter what we do, it will be a sell to whether it's just the
House, where we will have to get 201 members to agree to it. We thought it was important that as a
commission that at very least, we make a statement that further study is needed, bottom line. Having
the full House and Senate would give it more umpf than just the commission.
Ricciardi: I want to make two statements if I could with all due respect to everyone. I am going to speak
for the seven of us on the working group. I don't believe any of the six of you are against technology by
any means. We are for it and we presented solutions that are safer, quicker, better latency. I don't
appreciate that we are called out as saying we are against it. That's simply not true. I've got my
cellphone right here ok? I want to clear that up right now. We are not against it. We are against the way
it is now and we have shown a better solution as you get down into the recommendations.
The second thing is, we are tasked with a job based on the findings that we found. We don't sit here and
not put them forward because the Senate or the House won't go for it or we didn't do our job. Our job is
to present the truth. You don't, not present the truth because you are afraid of the outcome. The truth
is the truth. You place it there and see where it goes. The seven of us with the testimony, the evidence
and the science came to these conclusions. Anyone else who disagrees is allowed to and I respect their
opinion and they can follow up in a report. But I do think we should get through it so we all have a good
sense of where we are at. I am going to reiterate this. It is unconscionable to not tell the findings
because you are afraid it won't sit well with someone or won't pass. That's my two cents.
Abrami: Thank you, Denise.
Sherman: Pat, I have a few edits on the paragraphs following recommendation one if this is the right
time to mention them and they are minor. The words "living things" at the end of the second paragraph.
I would replace that with "organisms" which is a slightly more scientific term for living things. The
Obama-Biden plan to combat cancer, I am concerned about including that if it was never adopted by any
elected body. If it was 2008, was that a campaign plan they had in 2008 because certainly the FCC would
not be held to any campaign plan. My recommendation would be if it was adopted, then include it but if
it was a campaign platform, I would delete it and just have the first one which was the National Cancer
Act.
Miller: I am ok with that. I didn't write that particular piece.
Abrami: I think Tom has a good point, Paul. Was that ever enacted?
Heroux: I am trying to find out what type of formal approval this had but I think I should do it later.
Abrami: yes. Please do it later.
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Gray: Sometimes these things are done by Executive Orders. But the paragraph ahead of that, where
you talk about the FCC, all needs to be restructured also. Rewording that so it flows much better is
something that you should consider.
Sherman: I agree with Jim on that wording because rather than have the word "favorable" in that
paragraph with the Ninth Circuit Court, I would use what Jim said which was what the ruling was and
what it will result in. I haven't seen Jim's version of this but I would favor being as clear as possible. The
word "favorable" leaves a question as to who is it favorable to? Is it favorable to the FCC or the plaintiff?
Abrami: Carol, I am looking at you.
Miller: I am ok with removing that and I am not that invested in the surrounding documentation and it
should probably be moved to the appendix. With regard to this, there is a lot of information in there and
I think it just muddies the water.
Abrami: Ok, you heard all the comments Carol to modify.
Miller: If people send their recommendations directly to me, I am happy to do that or its going to get
lost in the shuffle. I have Senator Gray and Senator Sherman, who else had comments?
Cooley: I just had a footnote on the article by Anthony Miller.
RECOMMENDATION 2- Establish a State position that protects the State and all
its Municipalities from any liability from harm caused by small cell antennae
placed on the public rights-of-way. Specifically liability of the State of New
Hampshire and its municipalities connected to harm caused by claims of
personal damage or harm from the deployment of 5G small cell towers or the
attachment of 5G antennae on telephone poles, electric poles, lamp poles, or
other structures on the public right-of-way is by state statute transferred to the
Federal Government. The Federal Government shall be required to defend and
indemnify the municipality from any liabilities arising from permits and the
installation, operation, and maintenance of small cell installations.
Abrami: We had some discussion about this. This had to do with protecting our municipalities from
harm. Do we really want this recommendation or not because the feeling is that it will put citizens in a
bad position. I actually originally wrote this and Paul took it from there. Our communities are being
forced to deploy small cells at telephone height and I thought about holding them harmless. This was an
attempt to protect our municipalities, but what about people?
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Heroux: Well, this is a rather legal question. I think we all recognize the motive of Rep. Abrami's original
statement. But, if the federal government cannot be sued and if this recommendation goes nowhere,
what is the means by which we can support municipalities and individuals who might feel helpless in
relation to this problem in the sense of congealing their actions together and make sense of it and
rationalize it.
Woods: It seems as a discussion, we went over this very point and the complexities of having a liability
element in there as a recommendation. We wanted to include it but perhaps put it at the end as an
observation. And couch it in terms that we understand that this very well may be an issue that will come
to the fore that we did not have a recommendation but wanted to recognize that this is an issue that
will perhaps need to be addressed in the future.
Abrami: right. I put in my notes...discussing whether to demote to something less than a
recommendation.
Sherman: Brandon is with the AG's office. Could we get an opinion whether this is even possible? What's
happening is states and municipalities are being asked to approve these but based on FCC rulings, they
don't really have a choice. As a result, if the people of the town are harmed, and go after the
municipalities because they can't go after the federal government (FCC) then they are stuck. I am
concerned that municipalities will bear the brunt of liability without being able to say no to the request
from the cellular company. Do we have any wiggle room on this? Or is it something that is not worth
mentioning because there is nothing we can do about it? Can Brandon weigh in?
Garod: I'll do my best with the caveat that gets into the question of what is civil negligence and what
establishes the liability for civil negligence. That is pretty far outside the realm of what I typically do in
the consumer protection world. But, I had two initial thoughts when I looked at this. Because
municipalities are being forced to this and don't have a choice. To bring a suit for negligence there has
to be some sort of negligent action like setting aside the standard of care. If they are being forced, I
don't know how a community could be held liable for that. If they did have an option and did not do
their due diligence and allowed this to happen, that's a different story. It's very clear that other than
aesthetic regulation, the placement, design, size of something in a public space, municipalities have no
authority to say no to 5G technology being moved into their town. I don't think there is a huge risk of
liability for municipalities.
When I went back to the legislation, and looked at what the commission is supposed to do, I think this is
a bit of an outlier. I think it may be worth mentioning that there are concerns about who would be
liable. I don't see anything in the commission's tasks as to what steps we need to take legally protect
municipalities or the state from possible liability. It's more getting the information out there, developing
strategies to limit exposure, public policy statements rather than developing a plan to protect
municipalities from liabilities.
I think that likely if there are lawsuits in the future, that they will be directed at cellphone companies
who are pushing these things out aggressively without doing their research and they have
acknowledged the risk of harm as they recommend not putting it near your head but if they are then
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going to implement towers everywhere and not give anybody a choice, that's really their choice. I am
not sure that their choice and actions can be imparted onto municipalities that don't have an option and
trust the FCC that they are doing what they are supposed to be doing about safety. Those are my takes.
Ricciardi: The seven of you know that I have been against recommendation 2. I feel it's a dangerous
recommendation and we should omit it. State government needs to make these antenna safe not
indemnify or protect government from liability or responsibility when they allow them to be deployed
unsafely. We need state government to say no to these transmitters and challenge legal cases around
Section 704 of the 1996 Telecommunications Act that prevent them from even considering health and
safety. I don't think we should have Recommendation 2 in there at all.
Abrami: My original thought on this one is...the new twist is that these antennas are going to be in the
public Right Of Way. In the back of my head I'm thinking there is something different about these being
in the public Rights of Way. We have two, the municipal and the state ROW. We have town roads and
state roads. So, that's the game changer for me. That's what's different about this. We have no control
of those antennae and what's coming out of them. I am okay with eliminating #2 or demoting it.
Sherman: The real problem here, as Brandon said is that the municipality and the state can only object
on the basis of aesthetics. We should be asking our federal delegation to bring legislation that would
allow or expand the ability of municipalities and states to challenge the placement of 5G/small cell
technology based on concerns about health risk. That is getting to the meat of the problem here. The
reason that #2 exists is because municipalities and states have no ability to challenge FCC ruling on the
basis of health risk. To me, that's the crux of the problem. What needs to happen is we need to allow
local control with regard to health concerns for this technology. Local and state governments should
have some regulatory impact on whether or not this is rolled out.
I can't believe that the FCC can do this without any consideration of health impact. I would change #2 or
I would change the concern to: the Commission will write a letter to our federal delegation urging them
to bring federal legislation that would expand the ability of states and municipalities to object to
implementation or placement of 5G/small cell technology based on their concern for health risk. That's
the way I would take this, rather than going down the liability corridor which gets us into the issues that
Brandon was talking about.
Abrami: Right, the courts are not reviewing whether it's good or bad. They are just following 1996
statute.
Sherman: Frankly, if the industry wants to bring Xenon ray guns out that transmit data quickly, they can
do it if the FCC says they can do it. The FCC has the power to say, you have no right to object to
whatever technology that the telecommunications industry brings forward based on health risk. That's
it. That's the problem.
Heroux: what the FCC says is that certain levels of electromagnetic radiation and power density are not
harmful. It has a stranglehold on that because this was a main preoccupation of the engineering
community. It also says that you have to provide telecommunications service. But these two
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requirements leave a lot of ground for other arguments. I think aesthetics is a very weak word to
describe the leeway that you actually have. Without confronting the FCC, you can probably do lots of
things.
Chamberlin: My point is that we might want to wrap #2 into #1 since they are pushing for basically the
same thing having our federal delegation become involved in changing the policies for objecting to cell
tower placement.
Abrami: that's a possibility. Also, I should have mentioned this earlier. We had a discussion in the
working group about even using the term 5G but broadening that to a certain bandwidth of RF because
5G may be passe in a year or two with 6G. 5G is just a marketing concept. It's being rolled out differently
by all of the cell companies. Some are using small cell towers and others aren't. I don't want to burden
this here but we are looking for words to use in the report that would be broader then 5G.
Sherman: I would fully support that.
Wells: I agree and I can write some language about that.
Abrami: #2 won't stand the way it is and we will take a crack at it by either incorporating it in #1 or
coming up with some additional language here. Basically, the change that would have the most impact is
for the U.S. Congress to act. We all know that. That's a tough one. There are bills filed every once in a
while but they tend to go nowhere at the federal level but as New Hampshire we will throw our two
cents in. Or at least the Commission will.
RECOMMENDATION 3- Require the New Hampshire Department of Health and
Human Services or other New Hampshire agency to include links on its website
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. 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.
Chamberlin: the part that we were most recently looking at in our subcommittee is an establishment of
a registry that would be on a website. The reason for that registry would be for people to log their
concerns. How I became aware of this being at the University in electromagnetics, a number of calls
from concerned citizens get routed to me. I tell them what I know about exposure to electromagnetic
fields and they are sometimes concerned that they don't have an avenue for reporting their concerns. I
tell them that there is not much they can do about exposure at this point because of the 1996
Telecommunications Act and so they are stuck. Where do they go? Do they go to the FCC? That doesn't
seem to be a very productive avenue. I feel by having a registry, we can get a sense of how many people
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are concerned in the state of New Hampshire and to build essentially ammunition if there are a lot of
concerned people so we can go to the federal delegation and have them do something.
That's the second part that I really addressed and that is have a registry where citizens can report
concerns so we can get a sense of how many people do have concerns. If it's only one or two then
maybe the point is moot but if we are getting hundreds that's something that we should know. Paul, did
you want to address the other aspect of this?
Heroux: You are right. We wanted to give an access point to monitor this situation and the access point
could be for either individuals or organizations or a separate access point for both of these.
Gray: This is Jim. This recommendation first of all should not be for the Dept of Health and Human
Services. It should be for the state because we don't care what department it is as there may be a better
place to put it. It's more realistic if you have the state collect data. What we are talking about here is a
man year of effort and supervision and if the volume is high, maybe more than that. That would be a
budget issue and again, do we really want that and will the legislature approve it?
Abrami: we know most of these will have to go to the legislature for approval but first someone has to
file the bill. Those discussions will happen there. We decided that we want to make the
recommendations and let that process work through.
Chamberlin: I have done websites like this and to provide information and add links as we have done
with the website associated with the Commission. In terms of a registry, it could be something as simple
as a survey. I have created those in an afternoon. We could create a survey that is appended to the
website. I think we are talking about a man week as opposed to a man year worth of effort.
Heroux: I echo that comment because with automation today, it's fairly easy to create a link and a
person from within the state can access this link and file a pdf document automatically. If you have
many requests then you might face the labor of assessing these requests but as Kent pointed out, you
wait until you have many and then you know it's worth it. Thank you.
Roberge: As I said earlier, I have not had the opportunity to talk with leadership about this so I may have
some additional comments. One thing that I thought of and it's been talked about a little bit here is
funding for this. If the department is required to do a registry, there are obviously database
requirements and an evaluation component. One thing that concerns me is that if we are collecting this
information, at this point, we don't have any authority to do anything with it. That's somewhat
concerning to me because if we are collecting all of this information, what is the dept doing with it? I
know DES has been mentioned, I am not sure if they are appropriate either.
I know DHHS has a radiological program. It's a small program that is focused on ionizing radiation. We
license and inspect sources of ionizing radiation including x-ray machines in dental offices or hospitals or
industrial radiography in industry or a radioactive materials program. Again, that is focused on ionizing
radiation. The department also participates with Homeland Security Emergency Management and an
emergency response program specifically for Seabrook Station. Again, it's ionizing radiation. I'm not sure
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that DES is the correct agency. That being said, any additional requirements to do inspections,
monitoring or in this case PSAs and things like that, there is a funding mechanism that would be an
issue. If you had a registry, what are you doing with that data? Is it confidential? Will there be private
health information if people are talking about radiation sickness? How involved are we going to be with
these activities?
Also, I am not sure where the PUC falls in any of this. They do regulation of power lines so the
radiological health program does not do power lines. That falls under the Public Utilities Commission. I
am not sure where Telecommunications falls and if that would fall under PUC or not. I just wanted to
offer up those thoughts and certainly I am going to take this back to my program and I may have
additional thoughts to share at a future meeting or through email.
Abrami: It is my understanding that telecom is not really regulated like the utilities because it's not
considered a utility.
Sherman: I have a few thoughts. We have a commission to study environmentally triggered disease and
we have been working on this kind of database on that commission. We have been disrupted by Covid
and it's a senate commission so we have not been allowed to restart but what we have learned is DES
has a site where private property owners can put their well test results in. I don't believe that required
legislation or if they did that through rules. Individual well owners could enter their data into the site
and make it possible for DES to develop a database for private well owners.
There is also on the public health side, and Michelle knows there is an entire infrastructure of public
service and the ability to generate public service announcements. One concern I would have is with well
testing you have a certified report from a well tester. But with this, if you have people self- report with
what is on their digital read out on their EMF monitor that has not been verified. I would be concerned
about any agency being compelled to report non verifiable data. Just a few thoughts but this might be
something we could take up with the environmentally triggered disease commission. There might be a
softer language to recommendation 3 and I agree with Jim that we should not say which departments
would do this because it could be one of several departments.
Abrami: My concern is what data? What are people reporting? It's one thing if it's data but just feelings?
I don't know we have to be careful.... feelings based on what?
Chamberlin: We will talk more about data collection in another recommendation but for this one, this is
just a way for citizens to say I don't like the way the current legislation exists, Section 704 of the 1996
Telecom Act. Whenever people hear about it, they get very concerned about it because there is nothing
they can do because of this legislation. How many people are concerned would be helpful to us as we
move forward. If only a handful of people go on this registry and register a complaint, that tells us one
thing but if we have hundreds then that tells us something quite different. It would only be so people
who register could have their voices heard. Right now citizens who are concerned have no place to go.
They can write letters to the FCC as I have and very likely nothing will happen. This just makes it a state
initiative to identify people who are concerned so we perhaps can do something.
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Roberge: Is this appropriate for an advocacy group? I don't know that it's an agencies responsibility to
survey the feelings in New Hampshire. I would want to go back and talk to my leadership about this. Any
data that we hold, we would have to make sure that the data is safe and valid. I just wonder if it's more
something that an advocacy group would take on.
Abrami: Michelle, after you talk to your leadership, can you just drop me a note so I get a sense of
where they are?
Chamberlin: So, actually the registry was an add-on to the first part which is a website that contains
information about exposure to electromagnetic fields. This is informational and the add-on is to assess
how many people are concerned. So what about the first part does this seem to fall within the purview
of your organization?
Roberge: Before I make any comment on that, I would want to talk to my leadership. Right now, we are
knee deep in Covid, as you know. I would want to talk with them and I can come back and share with
this group what I learn.
Abrami: We have another six to go through and we have forty five minutes so we are going to move
along.
RECOMMENDATION 4- 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.
Abrami: Basically, with antenna being in the public right of way, I thought it wouldn't be a bad idea to
have the poles labelled to that effect as they may be on telephone poles or light poles, etc. Current
towers are usually surrounded by barbed wire fence or some structure around it at the base with a sign
saying....don't climb the fence. Obviously, there are different reasons for that. That's all this is, to label
the pole. Beware of the device on the top of the tower. Industry would have to label the poles. Can we
open that up for discussion please?
Cooley: Just more of a comment and again, I still have to talk to my membership and my legal
department. There are other entities in the public right of way that also use low level non ionizing
radiation. So, I question if this is discriminatory. In the public right of way, you do have utilities,
electricity lines and you also do have the cable industry deploying micro-wireless facilities also using 5G.
Again, I have to talk to my members and legal and I wonder if this is a discriminatory practice should the
commission endorse this in the majority report.
Abrami: So what you are saying is any device in the public rights of way emitting RF should have this
sign. That way, it's not discriminatory. Is that correct?
Cooley: I don't know. I will have to speak with my attorney. I flag that as a concern. There are other
entities in the right of way and this is targeting one.
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Abrami: Brandon, do you have any comment on this one?
Garod: It's close. I think it's dangerous to apply if it only discriminates against one type of entity then
it's definitely preempted. That's actually contrary to what the Portland case said. In the Portland case,
they found that different types of restrictions can be applied to different types of infrastructure. Really,
the key takeaway is if the effect of whether something discriminates against a particular company of
particular type of infrastructure would have the effect of prohibiting their entry into the state to provide
services, then that would be preempted. But, if it's simply requiring a certain type of infrastructure to
provide a warning that is consistent with the type of radiation that is emitted by that type of
infrastructure and placement of that type of infrastructure, I think there is an argument that could be
made that that is permissible and wouldn't be preempted.
All of this is sort of fuzzy. I think that is in line with the court when the court prohibited the FCC from
regulating too broadly a state or municipality's ability to regulate aesthetics that may be discriminatory
against one particular entity but as long as there is a reason for it and it's not prohibiting their entry, I
think there is an argument that can be made that it may not be preempted.
Sherman: I agree with Beth in a way. If there are multiple devices emitting RF, we should not have that
warning limited to the telecom. Maybe the warning should read that there is an RF emitting device on
this pole, no matter what that RF is. We know that cell towers look like. Right now, we don't know what
5G or small cells look like and we may not recognize that that emission is occurring from that pole.
Rather than being specific about the industry, we should be specific about that which we are trying to
protect the public from which is this level of RF exposure and that would get around Beth's concern. If
it's a cable company or telecommunications company or wireless company, the point is to identify that
that exposure is occurring.
Gray: The first thing you need to say is who is responsible for putting the sign up there. If it's the owner
of the antenna, you need to say that. Second, your problem with this recommendation is that you go
back to your preamble, nothing has been proven about the health effects so you are talking about
potential health effects. Do I have to put a warning on the side of my house because it has a transmitter
that transmits my water usage and electric usage to people who go by? Again, this needs to be looked at
carefully because it could be a whole lot of impact if it's not done right.
Abrami: That's good, Jim. Thanks. I will take a crack at modifying this one and we will talk about it again.
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RECOMMENDATION 5- Require that schools and public libraries 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.
Wells: This is mostly about schools and public libraries where the environment has already been fitted
out with wifi. There is strong evidence that the RF associated with wifi might have greater impacts on
young children. The Precautionary Principle would indicate that alternatives to RF would be preferred.
Two possibilities would be to go to hardwired connections to every device or use a different frequency
range and go up into the optical range where there are not likely to be any health effects to that. One of
the things that the state of New Hampshire could look into is that classrooms could be fitted out with a
device like Lifi which is an LED lighting fixture based optical data transmission. We need to look at how
we fund this but Carol recommended one possible fund may be the FCC's E-Rate program for
telecommunications and IT for schools and libraries. We figured if funding was procured then five years
would be a reasonable amount of time to complete a project.
One thing that I think is an important point to note is that the optical means for data transmission is
much faster than RF. So, essentially you would be saying, let's just skip RF and 5G and go into the next
generation directly.
Gray: Certainly the opposition report on this one would be that if you link it to funding, and
implementation, you take out the word, "require" and its better and the schools will do it because you
are paying for it and its better. I don't have a major thing on this except the word "require".
Abrami: So just encourage schools and libraries to look at alternatives including Lifi.
Gray: you would want to put in there that when public funds or whatever funds are available.
Abrami: right. The reason we put about the funding in there is that schools have spent a lot of money
putting this infrastructure in place and it would take a lot to reverse that course. Hardwire is an option
but Ken's suggestion of Lifi and our understanding at this point, is that it wouldn't be an expensive
option relatively speaking.
Wells: It appears that Lifi would be plug and play. It also involves an upgrade to a more cost efficient
lighting. You might actually come out ahead on this. We would have to look into what the actual costs
would be and savings but there is a possibility it would offset quite a bit of the cost with energy savings.
Gray: Just as a caution when you put something in your report that you don't have to do it until the
funding is available, you are already that it's not that bad. Certainly, the cheaper that you can make it
would mean that a parent of a child that is sensitive to electromagnetic radiation, could fund the
conversion of one classroom or whatever. Just think hard about this one if you go forward with it. What
if your data from studies proves that it's not harmful, then mandating is the wrong thing to do. In my
example, the funding will dry up if the radiation is not harmful.
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Wells: The E-Rate funding is not tied to harm. It's tied to telecommunications and IT in schools and
libraries. But it's a good point you raise about taking federal out of the description of the funding. It is
possible that you could get a charitable donation to convert school buildings. That's a good idea.
RECOMMENDATION 6-Establish new protocols for performing signal strength
measurements in areas around cell tower radiators to ensure compliance with
regulatory radiation thresholds and to evaluate signal characteristics known to
be deleterious to human health as has been documented through peer-reviewed
research efforts (e.g.,[l]). Those new protocols are to take into account the
impulsive nature of high-data-rate radiation that a growing body of evidence
shows to have a significantly greater negative impact on human health than
does continuous radiation. The measurements should be taken in regions
surrounding the tower that either are occupied or are accessible to the public.
Commissioning measurements are to be performed when the site is installed
and at regular intervals if required by state statute or municipal ordinance such
as those required by the town of Burlington, MA [2]. Measurements should also
be collected when changes are made to the tower that might affect its
radiation, such as changes in software controlling it. Measurements should be
performed under worst-case scenario conditions when the site is transmitting at
its highest levels.
Abrami: One thing as a state that I think we need to know is.... if these antenna generating RF are even
generating within FCC guidelines? This recommendation talks about what the state should be doing
about this.
Chamberlin: This recommendation really has two parts. The first is to come up with new protocols for
performing the measurements. The way we measure RF right now is the way we have been doing it for
50-60 years. It averages signals and does not take into account the summative effect of having multiple
transmitters. One thing the FCC guidelines do not take into account at all and that is, in the last thirty
years think of how many transmitters have been added to the RF spectrum. Now we are not being
illuminated by a single source like a local tv station. We are being radiated by cell towers, our own cell
phones, wifi and the way that measurements are taken now don't take the summative effect of those
radiation sources into account. The first part of recommendation six takes that into account and
prescribes a different way of performing these measurements. Also, what's being found is that it's not
the continuous radiation that has the greatest effect on us but it's the transient nature and impulsive
nature that has the greatest deleterious effect on health. The way this is worded, takes that into
account and specifies a new way of doing measurements.
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The second part says, you have to make the measurements and I could find no evidence that a cell
tower ever has to be measured unless maybe there is a report of someone thinking the radiation is too
great. The FCC doesn't have a commissioning for cell towers. I am familiar with this from working with
the FAA. Anytime you install anything, you always have a commissioning measurement to make sure it's
performing according to specs. The cell industry from what I have read has basically made calculations
about what power should be radiated from certain antennas and they say these calculated powers are
below the FCC threshold so we are good. However, I know from experience that you can get what is
called terrain or building focusing of electromagnetic waves that gives you far greater signals than you
would expect from simple calculations. The second part of this says whenever you commission a facility,
you have to go and make measurements under worse case scenarios and you have to do it using the
new protocols.
Just basically wanting to make sure that the towers are putting out the types of power that have been
calculated and that those powers are below the FCC thresholds.
Wells: Thank you, Kent. That's really excellent. I would make one suggestion though. When you talk
about focusing by buildings and terrain, could you also add beam forming?
Chamberlin: You mean beam forming from the antennas? I wasn't sure how much detail I should go into
but I am thinking when you set up a test protocol, you specify the beam forming will be at the location
of the receiver. It's actually buried in the worst case scenario statement.
Wells: right. I was just thinking that you acknowledged that the radiation can be focused by buildings
and terrain but it can also be focused deliberately.
Chamberlin: I will add that in. Thank you.
Roberge: I just had a question in terms of implementation of this recommendation. How do you envision
that? Is that something that the cell phone company would do after installation? Do you envision a
reviewing body of that or an independent analysis? It is unclear to me how this would be implemented.
Chamberlin: I was thinking it would be a third party or some independent measurement organization,
perhaps even the FCC.
Roberge: I come at this from a regulatory standpoint. If you put a requirement out there and a
measurement happens. It's fine if it all works out great but what happens if the measurement comes in
and it's not consistent with what requirements are or is it a true requirement? Or is this just a
recommendation? It's challenging to implement something like this if you don't have a true standard
and you don't have consistent measurement protocols. What happens if it's above? Who will be the
authority to make corrections or enforce? If you are thinking of this from an enforcement standpoint,
for instance if this cell tower measures above, what happens then? From an implementation standpoint
there can be challenges with that.
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If you are thinking of implementing this as a licensing or commissioning and enforcement of it then
there would be a cost associated with it establishing a protocol program whether it's on the federal level
or state level. Who is the regulating body for that? Just a couple of thoughts there.
Abrami: We talked about this. We can get lost in the weeds on the detail. This isn't words or legislation.
For that we would have to have a lot more detail than what you see here. We are saying we need a
better protocol and the state has the right to ask for an independent person to measure at the worst
case scenario that it's within FCC standards. This is not trying to change FCC limits on this. I understand
asking, who do we go to if it's out of compliance. It could go to the courts. Either this is a good idea or it
isn't a good idea. To me, this is a good idea. I don't have a comfort level that the industry is taking into
account all the other towers and RF soup in the area that they aren't really above the federal limit.
What we are saying as a commission is, we think it's a good idea to use and independent body to
measure and if it doesn't pass the test, then we as a state want to say you have to turn that tower off.
Now they may come back and say, it's not our tower, it's the one down the street. These are the
discussions that should be done at the federal level but it's not. We need to move forward with this
recommendation and then the detail comes in if someone picks this up to write a bill where we would
add more detail on some of the things you are bringing up Michelle.
Chamberlin: I can make this really brief. Cece linked in the text chat with some certification requirement
from Burlington, Mass. I will read that and see if I can add some of what they have done to our
recommendation and move forward with that.
Heroux: Actually, this kind of a situation has been taken into account in the past in relation to the tops of
buildings where you have forests of radiating structures and this is why advanced equipment that has
frequency analysis capability was created. If these locations exceed, for example thermal limits, there is
a requirement that says you have to have a power intensity reduction. But it has never been taken into
account for the general environment outside these facilities. Essentially, because it's assumed that
outside this region there is no hope that you will ever reach thermal levels. But if you are taking into
account crest measurements and peak characteristics, of course the situation can change very
substantially.
RECOMMENDATION 7- Require that any 5G antennae located on a public right-
of-way or new cellular phone antennae of any type, be set back 1,640feet (500
meters) from residences, businesses, and schools within a municipality
enforceable by the municipality during the permitting process unless all owners
of a residence or business or a school district waives this restriction.
Abrami: We went back and forth of this one in the work group. I will let Paul explain.
Heroux: Essentially, here there is no desire to challenge the FCC on power levels. There is no desire to
challenge the availability of wireless services. There is just a desire to have these towers with a setback
from dwellings where people live or work.
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Gray: Your 500 meters is .31 of a mile. The recommendation doesn't take into consideration anything
about the transmission, what the power level is at any particular point along that .31 of a mile. I went to
look up the things that were listed there and found it very difficult. It took me to Google Docs. I looked
also at our webpage to find them. Again, I think if you are going to include something like this then you
need to start getting into more detail. But a third of a mile would eliminate cell antennas. There are an
awful lot of people you can pack into a third of a mile.
Cooley: Again with the caveat that I need to discuss this with members and legal department. I do think
there is an argument that can be made that this violates section 332 of the Telecom Act. That is, you are
trying to tell providers where they can and cannot site facilities which could have the effect of impeding
service thus increasing the cost and providing a barrier to entry. You are saying where we can and
cannot go which has been ruled as a defacto moratorium and has been ruled unlawful. Again, I need to
run that up the chain but that is my initial impression.
Wells: this is a section where we need to make a distinction. It is referred to as 5G and we need to have
an RF definition. The thing that is unique about 5G is not the frequency or the power levels but the
proximity to people. This recommendation talks about a setback which is dealing with the unique quality
of 5G. It's very close to people. There are some other applications and implementations like smart
meters that might also fall into this. We need to come up with a definition of what sort of transmissions
we are talking about because to call it 5G is to give it a trade name rather than a physical definition.
RECOMMENDATION 8- Require power intensity disclosures for renters and
buyers and for public buildings (locations where the general public may go)
Wells: This recommendation requires power density disclosure for renters and buyers and also public
buildings. The idea here is that some agency of the state would also be a recipient of those readings so
the public has some idea of what they are exposed to. I understand that the objection has been made
many times that there is no safe threshold that has been specified. But we know that just as kitchen
appliances have an energy usage scale on them showing where they fall on the range of low energy and
high energy use, the same sort of scale could be understood by buyers and renters that perhaps less
intense energy is more desirable than more intense energy. They can figure out where they stand in that
continuum.
One other part that is important on this, in order to make this practical, the instruments used need to be
affordable and available. We have identified one particular example, the GQ 390 meter and the price is
under $200. Some agency of the state could loan them or real estate agents may find it's more
convenient to own their own.
On the state owned ones, it would be easy to get the manufacturer to verify they are all benchmarked
and consistent in their sensitivity.
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Abrami: the more thought I give to this one, there are really two pieces to this, the buyers and the
sellers and then any public place. I think any public place would be really unwieldy. But the buyers and
sellers, it's akin to getting a water test and a radon test. That's, basically what we are talking about.
Sherman: I have a concern. I see this running smack into the realtors. You and I have worked with them
in the past and I am just thinking of a pre-recommendation compromise and one thought would be
rather than requiring of a measurement and Michelle would probably tell us would require funding to
have this program. In other cases, haven't we required full disclosure if you have knowledge of issues on
the property. The seller would be required to disclose radon levels, lead paint, all of these other things.
Couldn't we say the owner would need to disclose potential RF exposure or known RF when you sell a
property?
Rather than putting in a whole new infrastructure, I think this is going to run into pushback at the fiscal
level and at the regulatory level. But a lesser would be to require any known exposure to RF or RF levels.
Gray: This one is so broad reaching. What happens when I change one of my routers? Do I have to go
retake the measurement and redo the posting? Again, we don't know what the safe level is. One of the
things that could be done if we did know what the safe level is would be to set a limit up to this. And I
know Dr. Chamberlin says it's the way we do beam forming and all that. This would be very difficult to
do.
Abrami: the real estate folks have already weighed in by the way. You can imagine which direction they
weighed in on.
Roberge: I was going to add in. Senator Sherman touched upon it. Depending upon how you envision
this being implemented, there could be costs associated if this gets delegated to an agency to
implement.
Chamberlin: we would definitely have to specify the conditions under which the measurements would
be taken. I would say that when you are going to take these measurements for real estate purposes, you
would turn off all internal sources so everyone would be on the same level playing field.
Abrami: Ken, you mentioned the Bio-initiative 2012 report, the 1,000 microwatts per meter squared.
Wells: There is a recommended maximum level by the Bio-initiative 2012 report of 1,000 microwatts per
meter squared. This is a pretty high level. This is a peak exposure. These meters could measure peak and
averages over 24 hours and could measure frequency. There is quite a bit of information that would be
available and I think it would be valuable for the agency that collects this. It would allow them the basis
for building a map of RF around NH and give them data for pursuing future public health investigations
about say cancer clusters in relation to transmission or cancer clusters that are not related to
transmission but perhaps some other environmental sources.
Abrami: This, ties back to Kent's proposal about a database but this would be real data. There could be
hotspots in a neighborhood or a town. All we are saying is, maybe before you buy a house, you want to
know about it. We went through this with radon and lead paint. The more we see radiation flying every
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which way, I think this is prudent. It doesn't have anything to do with the industry or the federal
government. It's just informing the buyer or the renter that you might be in a pretty hot zone.
Heroux: Actually, Senator Gray is right. If you install another antenna, the levels will change. Essentially,
this is what you are trying to determine by a number of these measurements to see what the evolution
in a particular place or state how radiation is evolving. These measurements are fundamentally fairly
easy to perform if they are performed by an instrument. They are probably preformatted so compiling
them could be relatively simple.
Woods: Going back to the fact that we could sort of massage this. The concept is very good and this is a
recommendation that says to the public besides the legislators in this report that this is an area that we
need to consider. Now, the details are going to be a morass to say the least. But I think as you pointed
out earlier Pat, these are areas that we see as a commission that need attention. As Tom said, the
realtors are going to have some input but I think that's for another day. To the Legislature and to the
public, we are saying we feel this is an important issue.
Ricciardi: I just wanted to say that maybe an RF map would be good for people who are already
microwave sick. That way they would know where the transmitters are the highest and could avoid
them.
Wells: I think that's a great idea. I just wanted to point out that Cece Doucette put something in the chat
that there is already an RF meter loan program in Ashland, MA through the public library. This would not
be hard to do. They are not terribly expensive.
Gray: It appears what you really ought to do after listening to Dr. Chamberlin, is split it into two. If you
are transferring real estate then taking measurements with wifi turned off etc. may be appropriate.
But if we are talking about posting for the public, then it's radiation when I walk into that building which
would include all the sources inside the building. It is unclear what you are really trying to do with this.
Are you trying to mix these two concepts together? You've got to remember that exposure for most
people would be a long term thing that would affect them and not a short term thing.
Abrami: I agree. I think I said this earlier. Comingling the purchase of property vs posting measurements
in public areas in the same recommendation is a tough one. If anything, we could split them out and
vote separately.
Wells: How about if I take the public building part of it and make that a separate part or possibility for
future consideration?
Abrami: that would probably be better.
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RECOMMENDATION 9- Require all new cell phones sold in New Hampshire come
equipped with a sensor that will stop the phone from radiating when positioned
against the body.
Heroux: This speaks to the fact that there is an opportunity in cell phones themselves, to mute the radio
emissions when the phone is held against the body. There are various ways of implementing this.
Initially, I presented it as the fact that the phone should be hardwired to do this. There are many other
ways to do this. The weakest way is to say we require that you can download an application that will
make your phone behave that way. The most sensible one might be to have a toggle on the phone or a
menu item that allows the phone to function in this manner. If you choose not to have your brain
radiated, you can choose that function on the phone itself. Between these extremes of you having it
hardwired or you having to do a lot of things to eliminate the radiation. Or there is another possibility
the phone could come with the toggle switch installed and you could disable it if you wish. That means
you choose and you agree that you believe that this risk is not substantial so you prefer to use the
phone against your head rather than avoid the risk.
Abrami: I think it has to be individual preference. We want to give those who are concerned about it a
chance to have something that will help them.
Wells: this is the first that I have heard of that last suggestion and I think that is a good one that the
phone is delivered to the customer with the safety option on and the user has the option of disabling
the safety function.
Sherman: One other option in this would be I believe this is true that they have this capacity but have
opted not to install it on phones, the idea of instrinsic shielding that would protect the customer from
radiation. There was a move about fifteen years ago to develop sleeves that you could put over your
phone to shield against the RF that was emitted toward your head. I like the toggle idea. I would not go
for the requirement that all phones shut down if you put them by your head. The toggle and personal
choice is a great option. Or the other part you could put in there would be the intrinsic shielding.
Gray: Are we creating a scenario where phones are not going to be sold in NH anymore?
Abrami: this is simply a recommendation to the cell phone manufacturers to consider.
Gray: We are not as big as the state of California who has driven emission regulations by state
regulation. I don't know that the cell phone industry is going to modify what is available to customers
because of the state of New Hampshire.
Abrami: the cellphone industry knows that holding the phone against your head may not be the best
thing because it's in their legal section. There must be a reason why they are saying that. So, if you
believe that then why don't you install an option where a user could turn it off. That's all we are doing as
a commission is recognizing this issue and making a recommendation. It's got to start somewhere. It's
my understanding that other states are following us on these proceedings. If we take that first step,
other states may also weigh in on it.
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Ricciardi: I just want to add to that is that our job is to protect the residents of New Hampshire. That's
what we are doing with these recommendations. Again, they are recommendations, not law. We have
to do that. With all due respect to everyone, here all opinions are appreciated but as we know, the
majority will write one report and those who are in disagreement are entitled to write their own. I
would caution on making too many changes to the one we did if the majority agrees with it. Since the
other report will be written anyway. Thank you.
Gray: The point that I was trying to make in a lot of this thing is that if we go right back to the first
paragraph and we say these things aren't proven. So to make recommendations that may impact the
cell phone may cost more in NH. There are reasons why we should be cautious in the recommendations
that we make.
Heroux : I take Senator Gray's point that New Hampshire is not as large as California and in some
instances may not have the same influence. But I have to say, I am a fan of New Hampshire and maybe
you are as big as you feel.
Wells: I just want to remind everyone about New Hampshire's role in MTBE. We are not without
influence.
Abrami: Let's do number ten. Eleven is still under consideration and twelve we can talk about next time.
RECOMMENDATION 10- Propose legislation that would facilitate the
implementation of fiber optic cable connectivity deployment and internal wired
connections to serve all commercial and residential properties statewide.
Abrami: it's just basically a statement that the state should promote fiber optic cable. Carol had to leave.
I am going to let her weigh on this next time. Members of the work group, I want to work on their
recommendations based on this input. Jim has some good comments in his as well as the others and
should take those into consideration. We are running out of time. Unfortunately, we lost almost four
months. I couldn't even get zoom time from the House. Good thing Kent has been gracious enough to
let us use the University of New Hampshire's zoom account.
I think we need to have more than a meeting a month.
Sherman: We are having trouble on the Senate side with all the zoom meetings we need to have. So if
we could have all the materials we need for the next meeting well in advance and preferably have a
longer meeting rather than three shorter meetings and just get the work finished as best as we can.
Abrami: I'd like to do it in three weeks. How about Tues the 22nd at 9? We will make it a 2.5 hour
meeting. Kent will set that up. Thank you everybody. We will make our way through this.
V. Next meeting via Zoom: Sept 22nd 9-11:30
Meeting Adjourned at 11: 15 am
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Text chat during Zoom meeting:
00:51:58 Paul Heroux, PhD: Identify Health Impacts of Environmental Factors: Barack Obama and
Joe Biden believe it is critical to understand the relationship between environmental factors and risk or
onset of disease, particularly cancer.
They support the efforts of Senators Clinton and Hatch to expand CDC biomonitoring programs, and as
president, Obama will expand the collaboration between the CDC and state public health agencies
across the country to increase understanding and improve treatment of individuals negatively affected
by environmental factors.
01:19:35 Cece Doucette: For Recommendation 2: Might NH consider taking a leadership role with
peers in all other states, share the Commission's final report, and encourage them to make a similar
request to their federal delegations? This approach might help to get meaningful action to protect the
public sooner rather than later since the 4G/5G small cells are going up in real time, and children are
being given wireless devices to access their education with no safety instructions.
01:29:43 Cece Doucette: Thank you, Dr. Sherman. It would be helpful to the public to label every
RF-emitting device, including utility smart meters and the collection devices mounted on poles outside
of residents' homes.
01:36:19 Cece Doucette: For Recommendation 5: Please vet all new technology through non-
industry funded scientific investigation before exposing our collective children. LEDs and Li-Fi may have
risks, but hard-wired technology to the premises with Ethernet cables and adapters is proven safe.
01:43:13 Cece Doucette: For Recommendation 6: Please see Burlington, MA Small Cell Policy,
which requires an annual recertification by an independent expert, and the wireless vendor pays the
town to complete the annual recertification.
http://www.burlington.org/town_government/small_cell_information.php
01:48:36 carol.a.miller: I apologize but I have a hard stop at 11am this morning. I will just
disconnect when that happens.
01:48:53 Beth Cooley: Same here
01:56:29 Cece Doucette: For Recommendation 8: We have modeled an RF meter lending
program at Ashland Public Library, MA. Others are emulating this too. It was based on kill-o-watt meters
put on loan in our libraries by the energy industry.
02:04:35 carol.a.miller: Again I apologize that I must leave the meeting now.
02:06:10 Cece Doucette: Thank you, Ken.
02:09:00 Brandon.H.Garod: I apologize put I have to leave for another meeting.
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02:09:26 Cece Doucette: Please consider adding a new recommendation to educate the public. I
drafted a fact sheet with the MA Department of Public Health, and have built a non-profit with quick on-
line courses that the public could take today and have the right to choose how they wish to use the
devices within their control. Please see https://www.wirelesseducation.org/store/l2/ and
https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxlbmRlcnN0YW5kaW5n
ZWlmc3xneDo20WYxMmNhY2ViNDcwMmQx
02:15:05 Cece Doucette: For Recommendation 9: Shielding can be helpful, but unless the shield
absorbs the radiation, it will deflect it back into the hand, other body parts, and other people/children in
the vicinity. We have seen hand cancers from cell phones too. See attorney Jimmy Gonzalez testimony
in Florida: https://www.youtube.com/watch?v=XitM4lkpvgo
02:17:31 Marty Feffer: Unfortunately, only humans will be able to make the choice to limit
their exposure to cell phone radiation with the ideas you are discussing. The natural world who are also
being irradiated, and have been, are suffering just as much, if not more, from exposure. Our
responsibilities run deep and wide if we honestly look at the complete picture.
02:21:09 denise ricciardi:to sign off
02:22:51 Paul Bloede: My apologies for asking if I was being spoken to, earlier; I hadn't studied
my notes from last time, closely enough, apparently, to realize there is a Paul who is truly a member of
the commission: Dr. Paul Heroux. Again, my apologies.
02:23:51 Marty Feffer: Thank you for your work. Inspiring to other states.
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
9/22/20
9:00-11:30 am EST
Via Zoom ( https://urih.zoom.us/j/95115866784)
Via telephone-US (1 301 715 8592 (US Toll) ID: 951 1586 6784)
In attendance:(13)
Rep. Patrick Abrami-speaker of the house appointee
Rep. Ken Wells- speaker of the house appointee
Kent Chamberlin-UNH-appointed by the chancellor
Denise Ricciardi-public-appointed by the governor
Michele Roberge-DHHS- Commissioner of DHHS appointee
Dr. Paul Heroux- Professor of Toxicology, McGill University- speaker of the house appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Senator Tom Sherman-president of the senate appointee
Brandon Garod-AG designee, Asst. AG Consumer Protection
Bethanne Cooley-CTIA, trade association for wireless industry and manufacturers
Carol Miller-NH Business & Economic Affairs Dept * (joined meeting in progress)
David Juvet-Business and Industry Association
Not present: (0)
Meeting called to order by Rep Abrami at 9:03 am
Abrami: Due to the Covid 19 virus and the Executive order signed by the Governor this public meeting is
allowed to be conducted via Zoom. It is open to the public for viewing and was duly posted as a Zoom
meeting. With that said, if you are not a member of the Commission, can you please turn your cameras
off and mute yourselves? That would be much appreciated. In addition the meeting is being recorded as
an aid to doing the minutes. All chat room discussions will be included in the minutes.
Since we are going to be taking some votes today, I am going to have to do a roll call. That is also a
requirement. The votes today will be in the order going to my left as we were seated in Concord for our
meetings. Please say where you are and if anyone else is in the room.
Tom Sherman-1 am here alone, Rye NH
Ken Wells-1 am in East Andover with my dog.
Kent Chamberlin-1 am in Durham, NH and I am alone.
Carol Miller- absent for roll call. (Joined meeting while in progress later)
Denise Ricciardi-1 am in Bedford and I am alone.
David Juvet-1 am at the BIA office in Concord. Others in the building but I am alone in my office.
Beth Cooley-1 am in Sarasota,FL and I am alone with the exception of my dog.
Brandon Garod-1 am at the AG's office, Concord. Others are in the building but I am alone in my office.
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Michelle Roberge-1 am alone in my office at DHHS, Hazen Dr. Concord.
Paul Heroux-1 am in Montreal and am home alone in my office.
Gary Woods-1 am in Bow, NH and am in my study at home alone.
Jim Gray-1 am alone here in Rochester alone in the kitchen having breakfast.
Pat Abrami- The Chair is here in Stratham, NH and I am home alone.
Ok. Thank you. So we have 12/13 present at the moment.
I. Approval of minutes from 8-31-20:
I have not received any changes to the minutes. Are there any changes that anyone wants to make?
Seeing none, I will say ...without objection, we approve the minutes from that meeting.
II: What remains for the Commission:
Abrami: I spoke to the Speaker this week to see if there was any wiggle room with the November 1st
date. He said it would be very difficult to change. So, my intuition is we strive to get to the November 1st
date to get the report done. Just keep that in the back of your mind. We have had a work group of seven
working on recommendations and we are going to vote up and down on those.
There will be a Minority Report. My goal is to give those involved with the Minority Report proper time
to react to the Majority Report in their report. My goal is to have the total report done by the middle of
October, if we can. We have a lot of pieces of it. Joel Anderson, staff member appointed to the
Commission will be helping put those pieces together.
So, that's where we are at. My goal is to have one or two more meetings. The Majority work group will
have to meet to put finishing touches on the report and get it to Jim and whoever wants to work with
Jim on the Minority report to give them a week or two. I am thinking the full Commission needs to meet
the third week in October just in case we need another week to do some adjusting.
Ill: Minority Report and Agency Disclaimer:
I sent out to everybody some sample reports of Minority reports. In this case, I think what we will do is
make the Minority report part of the report and it will be the last section where the Minority can say
what it's going to say. It will have a header that it's the Minority report. So it will be one report that will
include both.
As far as the agency disclaimer, Joel dug out my old marijuana Commission report. At the end, the
agencies had trouble saying they agree or disagree. Brandon, Carol and Michelle are the three that
work for the state. This is what I think it's going to sound like: Members of the Commission of the study
of the environmental and health effects of evolving 5G technology agree to the filing of the report by
the chairman. This action should not be construed in any way as an adoption of any particular position
of a commission member or the state agency or organization they represent on the underlying issue of
the deployment of 5G technology. It's as simple as that. I think this may make the members who feel
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uncomfortable more comfortable with their position on the report. Brandon and Michelle, any reaction
to what I just read?
Garod: I think at first glance, that language probably will work for DOJ but I would like the opportunity to
run it by the Attorney General to make sure that he is comfortable with it.
Roberge: I agree, same thing. I would like to run it by our folks here.
Abrami: I will retype it and send it so you have a hard copy to share with them.
I am going to move this along. We had a meeting and talked about most of these recommendations and
a few new ones did come up. It would take a lot to change a recommendation. If someone says, if you
change it this way or that way and I can vote for it, understand that the work group pretty much agreed
to the language here. Obviously, grammatical things will be accepted and if you have a real issue with a
particular recommendation, my sense is you would probably be in the minority report. I apologize in
advance, but I am going to move this fast. I just want to make sure we get this all in today so we can
move on to finalizing the report.
IV. Work Group Recommendations and Vote:
The rule is, we need to have a roll call vote on each of these per Joel and the folks that know about
these things. We are going to talk quickly about each of these and take a vote. When you vote, you will
vote ... yes, no or abstain. The majority of those who vote yes or no will make it into the majority report.
That's what the ground rule is. Is there any objection to that ground rule? I don't see any. Thank you.
If you read the intro to it, what the work group concluded is that (in my words) the science is conflicting
in some regards but there is enough science out there that's showing more study needs to be done on
this topic. Given that we tried to reach out to federal agencies and they didn't really answer our
questions and all the other things I mention in this intro, the conclusion of the majority is that we have
to use the Precautionary Principle here. You will find that we have softened some of the
recommendations from the last meeting. I am assuming that there may be enough that these are the
majority position but it may not be. It may be the minority. I kept the numbering the way it was so we
didn't confuse anyone even though we will be taking #2 off the table. After we are done voting, we will
reorder these for the report in a logical way.
Juvet: Mr. Chair, could I ask a process question before we start on each of the recommendations?
Abrami: Absolutely, Dave.
Juvet: As a part of voting, are you looking for just an up or down vote? Or can we, as members of the
commission explain why we are voting the way we are for the permanent record? I don't want to make
this process any longer than it needs to be. I just need some clarification.
Abrami: You can do that during the discussion.
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Sherman: I know we are going on the recommendations, but before we do, in the version I have which
says 5G commission recommendations at the top of it. I think it's the Sept 17th version. Is that the latest?
Abrami: yes.
Sherman: There is a sentence that to me does not make sense. Would this be an appropriate time for
me to point that out?
Abrami: Yes. Please.
Sherman: It's in the introduction, midway through. You will see the words, "the effect of the soup".
Then it says, "today, which will only be growing in the world of if the roll out continues is not known"
That phrase grammatically does not make sense to me. I don't know what the intent of that phrase was.
Abrami: if anything, the amount of RF will be expanding over time.
Gray: I took it as "the soup" is going to be growing, the amount of RF. That's what I took from it.
Sherman: But if I could just wordsmith that just to keep it simple.
Abrami: Yes. Absolutely.
Sherman: The effect of the soup of RF waves surrounding us today, which is likely to increase over time.
Perhaps, you could do something like that, because it was unclear.
Cooley: We will be providing comments to Senator Gray's Minority Report (CTIA). Second, I would just
like to publicly object to the entire introduction, most notably the first sentence. The Commission has
indeed not heard from many experts on both sides of the issue. As you recall, the Commission heard
from one pro-5G Physicist on November 20, 2019 who ran out of time. I do understand that the
pandemic did lose us many months. However, upon learning of new research during the summer
regarding the safety of 5G, I offered to reach out to the authors of that study and I was told in no
uncertain terms that there were to be no more experts. However, funny enough, I then hear of a so
called expert presenting before the working group at their Sept 11th meeting. We would just like as an
industry and CTIA to highlight that this biased approach and preordained outcome of the Commission
has not gone unnoticed, and we will be making these facts very clear to the General Court. Thank you,
Mr. Chair for the opportunity to speak.
Abrami: right and how many times did I say to you even before the virus, give me your best shot and any
time you want another speaker, let me know. It isn't like I didn't do that. We lost about four months
with the virus. The group argued that we really didn't have much time to hear additional testimony. Yes,
Paul suggested we hear from this lawyer, who wasn't a technical guy to possibly help us with some of
the language.
Ricciardi: I just want to address something since Beth has brought up the word "biased". I think you
represent the CTIA and having been in a lawsuit in Berkley, not wanting to have the fact that the
information about the proximity of the phone to the body that is hidden inside the information for the
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phone, not brought out, which was the lawsuit. That could be considered biased too, seeing that you are
on the Commission. Thank you.
Abrami: I understand. I had many emails about this, Beth. I batted them away. There were people out
there who wanted you off the Commission and I said absolutely not.
Cooley: Yes. I heard both the allegations and personal attacks against myself, CTIA and the industry.
Again, the facts will be made clear to the general court.
Abrami: That's fine.
Gray: This is Senator Gray. We need not to be defensive about comments that are made today and try to
rebut them. We just need to accept them as a comment and move on or we are not going to finish
anywhere near eleven.
Abrami: I agree, Senator. Again, that's what the Minority Report is for.
RECOMMENDATION 1- Propose a resolution of the House to the US Congress and Executive Branch to
require the Federal Communication Commission (FCC) to commission a 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 (TTA) 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
Commission believes that the FCC has not exercised due diligence in its mission to manage the
electromagnetic environment, failing to support technical means and investigations aimed at reducing
human exposures to electromagnetic radiation (EMR) in 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.
Abrami: First we had #1 as a joint resolution and I agree with Senator Gray, that the Senate does not like
joint resolutions and they would never do one. So, we put a resolution of the House. Basically, what #1
says is more health studies are needed. We broadened the range to include anything in that range, not
just 5G. Discussion?
Chamberlin: This is just wordsmithing. The section that says, "investigations aimed at reducing human
exposures to EMR". Well, we are not really trying to reduce radiation, necessarily. The wording that I
suggest is: "we want to set exposure limits that protect against negative health impacts". I would
suggest making that change.
Sherman: I have a change as well. It reads, "require the Federal Communication Commission (FCC) to
commission a review of the current radiofrequency (RF) standards". I would say, "an independent
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review". It's already been determined that the bulk of the FCC is comprised of Commissioners who have
spent a significant component of their career in the telecommunications business. So, for them to have
an in-house review of this, is like having the fox watch the hen house. That's true of any federal agency.
They would typically do an independent review.
Heroux: Is it necessary to point to the FCC? We know historically what the FCC does and they just
performed a review that they will just repeat. So, why not say the federal government?
Ricciardi: I agree with Paul. Also, the industry says that the biological effects are not health effects. We
know that it is so I think the wording has to be in there that you have to have clarification about the
impacts of biological effects.
Abrami: It's interesting that most of these changes are coming from the work group. So we are saying
the federal government.
Ricciardi: and add protect against the biological adverse effects.
Heroux: Yes. This is what I was suggesting.
Sherman: She is referring to the non bolded section. I would leave it because it's more inclusive the way
it is. It's in there twice already.
Sherman: Mine was independent review and Paul's was federal government. I kind of like leaving the
FCC.
Abrami: I didn't have a problem with the FCC either.
Woods: I would leave it as the FCC and I think the important part would be to have fabricated that it's
independent.
Sherman: Why don't we go ahead and vote on this one?
Abrami: So, keeping the FCC, adding independent review and changing to exposure limits to protect
against health impacts, any other discussion?
Juvet: Mr. Chair, before you call the roll I just want to let the Commission members know that I am going
to be voting against this recommendation. It states in the non bolded area that the commission believes
that the FCC has not exercised due diligence in its mission and my organization just doesn't believe that
is true. So, I will be voting against this recommendation.
Abrami: Ok. Thank you, Dave.
Gray: What I would put into the Minority Report on this one is that we don't have a problem with
further research. You could even fund the research from the federal government. The way you conduct
that research though and some of the other in here is what we would object to. In principle, the
research I am good with but the rest of it...no.
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Abrami: Thank you Jim.
Heroux: Just to be clear, I would vote for this recommendation whether it's FCC or federal government.
It's just with the federal government somebody would have to make the decision to ask the FCC, which
will be a further decision. But, both carry the same idea.
Abrami: Ok. Thanks, Paul. Ok. Here we go. I will call the roll: Tom Sherman (yes), Ken Wells (yes), Kent
Chamberlin (yes), Carol Miller (absent), Denise Ricciardi (yes), Dave Juvet (no), Beth Cooley (abstain),
Brandon Garod (abstain), Michelle Roberge (abstain), Paul Heroux (yes), Gary Woods (yes), James Gray
(no), Patrick Abami-Chair (yes). There are 7 (yes); 2(no); 3 (abstain) and 1 absent. The motion passes.
RECOMMENDATION 2- Establish a State position that protects the State and all its Municipalities from
any liability from harm caused by small cell antennae placed on the public rights-of-way. Specifically,
liability of the State of New Hampshire and its municipalities connected to harm caused by claims of
personal damage or harm from the deployment of 5G small cell towers or the attachment of 5G
antennae on telephone poles, electric poles, lamp poles, or other structures on the public right-of-way
is by state statute transferred to the Federal Government The Federal Government shall be required
to defend and indemnify the municipality from any liabilities arising from permits and the installation,
operation, and maintenance of small cell installations. Since the State of New Hampshire and its
municipalities are being forced by Federal Law to deploy 5G small cell towers and antennae on public
rights-of-way, the Commission has concluded that that the State and its municipalities should be held
harmless from any litigation claiming harm for any reason, including damage to health. The Committee
feels that this recommendation should not be of any burden to the Federal Government or to the
cellular industry and related industries who support the cellular industry, since they believe that 5G
technology is safe and thus there will be no harm caused by having these antennae so closely deployed
to the public on the public right-of-way. DEMOTED TO SOMETHING THE COMMISSION DISCUSSED
Abrami: The workgroup has decided to take this off the table. We kept it here for numbering purposes.
It will be demoted to a topic of discussion in the report saying the commission discussed this issue. The
position of the workgroup was to not include this recommendation. So are we ok just skipping this? If
you want to say something, raise your hand or just speak out. It's quicker. There is no one monitoring
this other than myself. Ok.
RECOMMENDA TION 3- Require that the most appropriate agency (agencies) of the State of New
Hampshire include links on its (there) 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. 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
compelling 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. Attachment XX shows an example of a
simple cell phone warning.
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The website must provide an option for visitors to register their concerns 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 contentious 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 concern about RF-radiation exposure there is on the part of New Hampshire citizens.
Abrami: This has to do with public information related to RF radiation in general and public service
announcements and postings of certain warnings. Kent, I think you and Carol worked on this.
Chamberlin: This is part of informing people about potential problems associated with exposure to
fields. Now a lot of people do not realize that there are any negative effects. This would be an
opportunity to provide warnings both on the signs and on the webpage indicating what those potential
hazards are. The other aspect of this is to allow people to provide an opportunity for New Hampshire
citizens to register their concerns about the current legislation, for example the Telecommunications Act
of 1996. It would be just a way for them to air their concerns. The data would be used to inform us or
the state about what the level of concern is. As I mentioned the last time, if only a handful of people are
concerned, then perhaps it's not that big of an issue. But my own experience having people call me at
the University to have me come out and make measurements and ask what they can do about cell tower
exposure. I haven't been able to send them any place where they got satisfaction. This would be an
opportunity to provide a registry for people to log concerns about exposure to RF fields.
Abrami: Kent, I think a lot of what you are saying relates to another recommendation. This was really
Carol's. This was more about public service announcements and things on the website.
Chamberlin: I am sorry. I did mention that but my apologies that does relate to another one.
Sherman: there is a typo in the second line: "their" is what it should be.
Juvet: I just have a question about the first sentence in the bold where we are suggesting that the most
appropriate agency or agencies of the state include links. As a commission that's been studying this, are
we unable to name which agencies we think should be responsible for this?
Abrami: Originally, we had DHHS but we decided that it could be more than one. It could be others like
environmental. So, we just kept it broad.
Heroux: In the version I have, the last paragraph, it does mention that the website must provide an
option for visitors, as Kent had indicated. Does this mean that this paragraph has been transferred
elsewhere? It means that there are links for people and perhaps by filling out a form.
Sherman: He is saying it reads that the website must provide an option for visitors to register their
concerns about current FCC exposure guidelines.
Chamberlin: The intent was not to go to the FCC but would be a registry for the state of New Hampshire.
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Heroux: What Kent is saying is that there is no way for any citizen who is concerned to voice that
concern and their situation and it is not wise for New Hampshire to be totally deaf to such a situation. It
could be fairly simple. There might be a standard form that can be uploaded and simply kept on file until
for some reason it is decided that this needs to be analyzed.
Juvet: Mr. Chair, can I make a comment on this point? Two things: If we are only allowing a vehicle to
only register concerns, you will get a very one sided point of view and I am wondering if that could be
changed to say register their opinions.
Abrami: I think you are correct.
Juvet: the second thing is more of a procedural thing. I am unclear if this is established, what happens
then? I am not quite clear on how this information will be used.
Abrami: The data could be accumulated and then interested parties would have a place to go to look for
opinions of the public.
Juvet: One final comment about midway through that paragraph, you are labelling the 1996
Telecommunications Act as "contentious". I think that is a little pejorative also and I would remove the
word "contentious".
Sherman: I would go one step further and take out that middle sentence because it is judgmental.
Abrami: you are suggesting that we take out the section that says: this registry should provide a
convenient and formal mechanism for the New Hampshire municipalities and residents to weigh in
concerning the contentious 1996 Telecommunication s Act.
Sherman: I would get rid of the word "contentious" no matter what. I agree with Dave. I would change it
as a way of people logging opinions rather than telling people what they should be discussing.
Abrami: Most of the public has no idea what the 1996 Telecommunications Act is. Municipalities would
because they are doing these sitings all the time.
Sherman: I would just get rid of" contentiou".
Gray: The first objection I have is the word "compelling" in the first non-bold sentence. If we look back
to the preamble, we say the science isn't all in and throughout this report I don't believe we should set
up a new division in the state anywhere that summarizes all this stuff and has action etc. But, we will put
all that into the Minority Report.
Sherman: I agree with Jim. We are saying we are going with the Precautionary Principle because we
don't know. So, saying "compelling" says we know. There is evidence that the public should be warned.
There is evidence but there is some editorial comment in this report that is stronger than what I am
comfortable with. Get rid of the word "compelling" and "contentious". I think it sounds a little less
judgmental and a little more acceptable to your audience.
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Juvet: Mr. Chairman, along those lines, in the very last sentence of the non bolded section says "the
primary use of this data collected on this registry will be to gauge the level of concern. I would be more
comfortable with "opinion" in place of "concern".
Abrami: I am ok with that as well. Are there any other changes?
Roberge: I request some qualifying language around "appropriate funding" if this was to go to a state
agency and the agency was required to do PSAs or whatever. There might be a funding issue that may
come up.
Sherman: Michelle, you make me smile.
Abrami: ... this cannot occur unless the legislature provides proper funding. Is that ok?
Sherman: you could say that the legislature fund the most appropriate agency in the state of New
Hampshire. The first step as Michelle is saying and those of us in the legislature know the first step is
you need the funding. You could put "supported by funding granted by the legislature".
Gray: When this goes to the legislature for adoption, it will get reviewed and if there is funding required,
it will be part of it. So, I don't even think you need to talk to the funding specifically. Thank you.
Wells: Back on the last item where we talked about the level of "opinion". I think it would be more
appropriate to say level of "interest" about RF radiation exposure on the part of the public.
Juvet: I don't have a problem with that. I agree.
Abrami: I think I got all the correct changes. We have the funding piece. We have the correction on the
"there" to "their". We got rid of "compelling". We got rid of "contentious". We replaced "concerns"
with "interest".
Juvet: Mr. Chair I am going to be voting against this recommendation and the reason why is related to
the budget and potential fiscal issues. I am not ready to commit the BIA to supporting that before we
have a chance to review the context of the entire budget.
Abrami: Remember, with any of these recommendations, it would take someone to put some of these in
bill form to propose to the legislature and make it through a difficult legislative process.
Juvet: I appreciate that but if I vote for this, it could be construed that the BIA is in favor of that as a part
of the overall budget. I'm not there yet.
Sherman: Could I just ask Dave a question? You do have the option of abstaining. If you are voting
against it, my interpretation is that you are opposed to this moving forward as a recommendation....that
the recommendation is something that the BIA could not agree to.
Juvet: Thank you, Senator. I agree with you. So, I will be planning to abstain on this one.
Cooley: I will be opposing this because of the implied risk of wireless radiation.
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Abrami: Any other discussion? I will make a motion that we accept this.
Sherman: I will second.
Abrami: I will call the roll: Tom Sherman (yes), Ken Wells (yes), Kent Chamberlin (yes), Carol Miller
(absent), Denise Ricciardi (yes), Dave Juvet (abstain), Beth Cooley (no), Brandon Garod (abstain),
Michelle Roberge (abstain), Paul Heroux (yes), Gary Woods (yes), James Gray (no), Patrick Abami-Chair
(yes). There are 7 (yes); 2(no); 3 (abstain) and 1 absent. The motion passes.
RECOMMENDATION 4- 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 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 harm by requiring
the owners of these antennae to inform the public of potential from RF-radiation harm. See Appendix
XX for an example symbol.
Abrami: We talked about his last time. The game changing with 5G, not all cell companies are rolling out
small cells in the right of way but some may be. For many, that's a game changer. All this is saying is that
if that is the case, there should be some sort of labelling that there is an antenna on top emitting RF
radiation. Beth, I know you had some concerns about this as there is RF related to power lines and all
that. The subgroup decided to keep this recommendation.
Juvet: Mr. Chair, I'm going to be voting against this recommendation. I think it sends a conflicting
message. I think it potentially makes NH different than every other state in terms of 5G rollout. I think if
this is an issue then it's something that should happen at the federal level as part of federal legislation
so the requirement is the same for all states. I can't support this recommendation.
Ricciardi: I just have a question. Is there any rule for participation in these groups? When someone
misses a lot of the meetings, I don't think they have all the information they need to make an informed
decision. It's just a question, Mr. Chair.
Abrami: Let's go way back. Dave and I chatted early on and certain days of meetings Dave could not
attend because of a conflict with his board meetings with the BIA. Plus we were into the science and I
know Dave was pretty eye rolling. So after the virus hit and we finally came back, I just assumed that
Dave didn't really want to participate. That was a false assumption on my part. Dave reached out to me
and said he is officially appointed to this commission. I cannot take him off this commission. None of us
can other than the person who appointed him. So, he is still a formal member of this commission and
yes he missed a lot of the meetings. The minutes are out there on our site. I don't want to make a big
deal about this.
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Sherman: Denise, I just want to point out the minutes and presentations are on the site. If you miss
commission hearings, you do have the ability to catch up. And I am assuming that anyone who is
participating in voting is up to date. That's what we do in commissions as we have that capacity. I am on
more than 20 commissions and committees right now. There is no way I can make every single hearing. I
agree with the Chair. We should move on and assume that Dave has done his due diligence and has
every right to vote as an appointed member.
Ricciardi: It was just a question. I wanted clarification. Thank you Senator.
Abrami: Just for the record, our minutes are basically almost verbatim of what's being said. They are
very extensive minutes. I move to call recommendation four for a vote. Tom?
Sherman: on the discussion side, I just have to say I have a concern about this one. First of all the
labelling, I agree with the industry that there are many sources of RF and I think the public should be
warned but I'm not completely comfortable with this one. I am going to hold off on seconding it and give
myself a few more minutes to think about it before we vote.
Woods: I will second it.
Gray: my problem with this one is we have regulations and if the emissions from the cell tower meets
the current and if we are saying that the future ones of our recommendation number one if it exceeds
those then a warning label might be appropriate but again, we haven't done the research from number
one. It meets current regulations and therefore the added expense of putting that sign on there and if
there is still anybody who climbs poles without a hydraulic lift then that sign could be hazardous to them
climbing that pole. For those reasons, I will not be supporting it.
Sherman: Patrick, the more I think about this one, the legibility of the sign, I have to agree. Right now
under current law, we have already said there needs to be more study. I really am uncomfortable with
this one. I think I am going to have to vote against it.
Wells: We have had quite a bit of discussion on this because the current standards don't talk about
energy density in watts per square meter. When you have antenna in the public right of way, there are
orders of magnitude closer to people than existing antennas. So, the RF exposure is very high.
Heroux: The other thing is that if you require it to have a full survey of all RF sources other than 5G, I
realize that this may seem discriminatory. Essentially, it's because there is densification that this has
provided and it would be a substantial task to inventory all sources of radiation and make sure that all of
them are labelled. But at the threshold of densification, I feel this is justified.
Abrami: any other discussion? Alright. I am going to call the roll: Tom Sherman (no), Ken Wells (yes),
Kent Chamberlin (yes), Carol Miller (absent), Denise Ricciardi (yes), Dave Juvet (no), Beth Cooley (no),
Brandon Garod (abstain), Michelle Roberge (abstain), Paul Heroux (yes), Gary Woods (yes), James Gray
(no), Patrick Abami-Chair (yes). There are 6 (yes); 4 (no); 2 (abstain) and 1 absent. The motion passes.
Abrami: Carol, were you here when I called for the vote?
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Miller: I am abstaining anyway.
Cooley: I'm sorry, a clarification on that last vote. So was it 6 (yes) 4(no) and 2(abstain) because Carol
was not here before the roll was called?
Abrami: yes.
Cooley: so was it 6-6 and does not pass?
Abrami: no. It's the majority of those who did not abstain.
Cooley: got it.
RECOMMENDATION 5- 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 infra-structure 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
required for transmission. Such optical data transmission using visible light offers giga-byte 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 (via say through the FCC's E-Rate program for telecommunications and IT in schools and public
libraries) is procured.
Abrami: so this one is encouraging the use of hardwire or optical connections within schools and public
libraries. I will let Ken spend a minute on it.
Wells: Schools and public libraries should migrate from RF wireless connections to either hardwired or
optical wireless connections within five years of when funding becomes available.
Abrami: Can you spend a second on LiFi?
Wells: yes. There has been adequate research that younger children are susceptible to RF radiation and
the alternative to using RF sources would be faster optical systems like LiFi or hardwired connections
which don't emit radiation. Lifi is a visible light. There is adequate evidence that living things are quite
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resistant to visible lights. The speed and security of optical is better than RF based communications. This
would be a step up in performance and security.
Abrami: The recommendation is also sensitive to the school districts have spent a lot of money already
on WiFi. Understanding that these things have cycles and there is obsolescence. We are suggesting that
when funding is available that this be looked at as an alternative to WiFi.
Sherman: Can I just wordsmith one thing? In the last paragraph of the non bolded section, there are
words that say: "via say through" I would replace that with: "e.g." and commas. It's a little slangy for a
commission report.
Gray: Going back up to the recommendation, I am not so sure that we need to say that they should
migrate. Also in the non bolded section it says "strong evidence". There are organizations out there that
sell that equipment and would be more than happy to help school districts migrate over. Should they?
Shouldn't they? It goes back to your first paragraph, what is an acceptable limit? If you say schools and
libraries should be assisted in migrating and you take out the word "strong" and it gets closer to
something that I can support.
Sherman: I like it the way it is and if Jim is not going to support it in any event then I would leave it the
way it is.
Miller: I would just notate "gigabit" not "giga-byte". It's just one word, gigabit.
Abrami: Ken, are you ok with that?
Wells: Yes, that's good.
Heroux: Mr. Chair, did you ask Carol where she was and if she was alone?
Miller: I am home alone except for the dog and he is on the deck.
Abrami: I will move for recommendation five. Tom?
Sherman: I will second.
Abrami: I am going to call the roll: Tom Sherman (yes), Ken Wells (yes), Kent Chamberlin (yes), Carol
Miller (abstain), Denise Ricciardi (yes), Dave Juvet (abstain), Beth Cooley (no), Brandon Garod (abstain),
Michelle Roberge (abstain), Paul Heroux (yes), Gary Woods (yes), James Gray (no), Patrick Abami-Chair
(yes). There are 7 (yes); 2(no); 4 (abstain). The motion passes.
RECOMMENDATION 6-Establish new protocols for performing signal strength measurements in areas
around cell tower radiators to ensure compliance with regulatory radiation thresholds and to evaluate
signal characteristics known to be deleterious to human health as has been documented through peer-
reviewed research efforts (e.g.,[l]). Those new protocols are to take into account the impulsive nature
of high-data-rate radiation that a growing body of evidence shows to have a significantly greater
negative impact on human health than does continuous radiation. The measurements should be taken
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in regions surrounding the tower that either are occupied or are accessible to the public.
Commissioning measurements are to be performed when the site is installed and at regular intervals if
required by state statute or municipal ordinance such as those required by the town of Burlington, MA
[2]. Measurements should also be collected when changes are made to the tower that might affect its
radiation, such as changes in software controlling it Measurements should be performed under worst-
case scenario conditions when the site is transmitting at its highest levels.
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 antennas, causing signal levels to be considerably higher than would be expected
in theoretical calculations unless those effects are taken into account. Further, if measurements are
performed using the protocols that are advocated, they will be sensitive to the impulses and summative
effects of other radiation sources such as nearby cell towers. The measurements being advocated will
require wideband equipment that is typically not used in the averaged signal measurements that are
currently used. Two peer-reviewed articles that address the effects of impulsive radiation on organisms
are [3] and [4],
[1] Belyaev I., Dean A., Eger H. et al. EUROPAEM EMF Guideline 2016 for the prevention, diagnosis, and
treatment of EMF-related health problems and illnesses. Rev environ Health. 2016;31(3):363-397.
Doi:10.1515/reveh-2016-0011.
[2] 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.
[3] B. W. G. (2012). Bionitiative 2012: A Rationile for Biologically-based Exposure Standards for Low-
Intensity Electromagnetic Radiation
[4 JMcCarty, D. E., Carrubba, S., Chesson, A. L., Frilot, C., Gonzalez-Toledo, E., & Marino, A. A. (2011).
Electromagnetic hypersensitivity: P Evidence for a novel neurological syndrome. International Journal of
Neuroscience,121(12), 670-676
Abrami: I will let Kent speak to this. It really discusses that there should be something more than the
average when we look at signal strength.
Chamberlin: this also has two parts. One is that it says you have to perform measurements on a cell
tower. At one point you need to do that at commissioning because there are factors that can cause
signals to be greater than what you would expect from simple calculations that the cell tower
manufacturers provide. Burlington, Mass has a requirement as a town ordinance saying you have to
perform these measurements regularly to make sure you have not exceeded guidelines.
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The next part relates to how you perform those measurements. The way that's been done for fifty years
is to look at averages. It turns out that it's not just the average power you're exposed to but it has to do
with the transient nature of that and the summative effects. The way the measurements are performed
now, if you were looking at a particular frequency, you would get a single value. It wouldn't see the
contributing effects of nearby transmitters. The way I am proposing it here is that you look at the
signals differently. You look at summative, the transient nature, the peak value which as I understand it,
are not being looked at right now.
Wells: I am just noticing in this version, the second sentence after the bold section talks about focusing
building terrain and antennas, but does not mention beam forming, which I think we discussed in one of
the earlier sessions.
Abrami: I think you are right. Where are you?
Wells: The second non bolded sentence. You can put it after building, terrain, beam forming and
antenna.
Heroux: Kent, this recommendation is very long. I wonder if somehow it could be a little bit remodeled
to make it crisper to understand. All the other recommendations could almost be used in a commercial.
Whereas this one, needs some wind to go through.
Abrami: I think you are right. Perhaps, some should be in the discussion part not the bold.
Gray: My objection to this recommendation is that it ought to be a subset of the study that you are
requiring in recommendation one. If you found there is a problem, then how do you mitigate that
problem?
Sherman: I kind of agree with Jim that this may be the cart before the horse. I don't disagree with this
recommendation. I will vote for it but it would be great to have some parenthetical phrase somewhere
in there that says depending on results of section one, or something like that.
Abrami: Ok. Why don't we say we are voting on the essence of this? Then we will vote again. I just want
a sense of this. Is that ok with everybody?
Wells: You can streamline it by taking the first and last sentence in the bold and relegating the rest to
the last paragraph.
Heroux: I would like to mention that this is very critical in the sense that this question is not something
that will come out of a new investigation. It has been around for fifty years. The point here is that if you
only look at biological effects over a gram and over averages, you blind yourself to reality. This is
essentially what this very important recommendation says.
Abrami: I think that's why we have it here actually. I am ok with trimming it down and taking the middle
part and moving it down below.
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Woods: Just to clarify. We are trying to work this which is fairly complicated. Are we going to have
another work session before the next full session?
Abrami: Yes. The work group is going to meet one more time because we have to talk about the rest of
the report and get that going. Let's get the essence of a yes or no on this. If it's a no, we won't bother
reworking it. We will have another vote specifically on this recommendation at the next full meeting.
Cooley: I will be voting no on this just because the FCC has its regulations in place here and they occupy
the field. That's clear in both federal statute and federal regulation. Also, this is seemingly implying that
wireless radiation is unsafe. Thank you.
Juvet: Mr. Chair, I would also like to let the commission that I will also be voting no on this. Again, this is
making New Hampshire and outlier. This is a regulation that should be handled at the federal level. I
think it sends a bad message about New Hampshire being serious about embracing the latest
technologies for economic development.
Woods: As far as the consideration for New Hampshire being an outlier, I would like to point out that
New Hampshire is the only state that does not have a mandatory safety belt law resulting in the loss of
about 27 lives per year because of disuse. We have no trouble being an outlier in that regard. So I think
that is perhaps something to consider the argument by itself to be an outlier perhaps should be put in a
broader context.
Abrami: We all have our opinions. Ok. I move recommendation 6. This is just the essence, not the final
words. We will vote on it one more time.
Chamberlin: I will second it.
Abrami: I am going to call the roll: Tom Sherman (yes), Ken Wells (yes), Kent Chamberlin (yes), Carol
Miller (abstain), Denise Ricciardi (yes), Dave Juvet (no), Beth Cooley (no), Brandon Garod (abstain),
Michelle Roberge (abstain), Paul Heroux (yes), Gary Woods (yes), James Gray (no), Patrick Abami-Chair
(yes). There are 7 (yes); 3(no); 3 (abstain). The motion passes.
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/business or school districts waive this restriction. Given these are local public rights-of-way
and under the jurisdiction of a municipality, the Commission feels empowering individuals impacted by
these antennae to be within states' rights to legislate such standards. This statute would return personal
freedoms back to the individual in being involved with decisions as to non-essential devices that are
being placed in front of their property.
Siting restrictions for cell phone towers already in force in the world were intended to ensure the safety
of vulnerable populations, like children and those with illnesses. India already prohibits placement of
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cell phone towers near schools or hospitals, and Canada (Standing Committee on Health), as well as
many European countries, are looking into similar restrictions. In California, firemen have been
exempted from the forced placement of towers on their stations, because of radiation health concerns.
There are plans to use higher frequencies in the future. These higher frequency transmitters have to
take into account:
1. Less signal penetration into structures
2. The atmospheres oxygen and water absorption of radiation
3. The shrinking antenna apertures
4. The noise from multiple extraneous sources
For human users, this means increased power density exposures. In addition, exposures will become
more irregular and originate from multiple sources (Multiple-Input-Multiple Output Architecture). As
vulnerable individuals are exposed ever day in society to RF-radiation, limits should be universally
applied, and set according to the Largest Observed Adverse Effect Distance (LOADE) using the
experience from the past and current uses of 2G, 3G, and 4G technology, since there is no
epidemiological experience with 5G.
An engineering practice would use a set-back requirement for new base-station cellular towers,
including 5G micro-towers. A conservative LOAED should include all observed health effects. From the
18 papers abstracted in Appendix XX, shown in historical order, this set-back for all new cell towers
should be 500 meters which translates to 1,640 feet. The actual set-back requirement should be
established by the municipality based upon a balance of the science and reasonable accommodation for
these antennae.
Abrami: Recommendation seven has to do with setbacks. I will let Paul speak to this one.
Heroux: There has been a lot of evidence in epidemiology that the proximity of cell phone towers
enhances cancer effects that happen at the maximum within two years of installation as well as a variety
of neurological effects that have been documented and so we believe that to bring densification to New
Hampshire represents by itself a risk. Cell phone towers should be distanced from where people live
whether they are vulnerable or not.
The non-bold section relays this information and says that there is evidence of health effects until 500
meters. In terms of best practice, this is what should happen.
Gray: This recommendation does not take into consideration any power level that is going out, beam
forming or other things. If we are going to do this, it can't be all cell towers have to be .31 miles away.
These new 5G are much less power. Unless you start to talk about power density and other
measurements in recommendation 6, then this really has no meaning.
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Cooley: As I expressed prior, this likely runs afoul of federal law. A state and locality cannot dictate
where a wireless network can or cannot be built particularly if it creates holes in coverage and that is a
barrier to entry. I will be voting no for that reason. I will also point out that there is a reference to
California and that firemen were exempted from "forced" placement of towers. That is actually an
incorrect statement. I have the legislative analysis that shows why the California firefighters were
exempt from AB 57 many years ago. I would just submit for the commission that that is an incorrect
statement. Thank you.
Heroux: 5G is something that is not yet defined and it will have beam forming which although the
individual towers consumes less power, it has a higher effective radiated power because of antenna
gain. So in the face of a new method of transmission, that is 5G that has yet to be defined by most
people who deploy it, we can only rely on the past to assess the health impacts of cellular systems. In
other words, we cannot be twenty years in the future to gauge as Senator Gray does suggest the health
impacts of 5G. We can only use our experience of the past and this is what this distance is based on.
Sherman: I have to agree with Beth on this one. If we are going to leave this intact and I know it's
weakening your recommendation, but I would change the word "require "to "encourage" because I
don't think you can do this kind of siting or require it. It's just a non-starter. I know that in Rye when we
talk about a new cell tower coming in, which there needs to be and will be, that is a very productive
negotiation between the town and Verizon and so I think "encourage" would be a way I could vote for
this. Correct me if I am wrong, but I think Beth had it right that this is federal statute and we can't do
this. So, it's a non-starter to put a recommendation that we can't do.
Abrami: I don't have a problem with encourage.
Sherman: I also want to make sure that we are accurate where Beth pointed out we were inaccurate.
Maybe at the next subcommittee work session, be absolutely confident that you are correct in what you
are talking about with California. If it's not clear, I would remove it.
Abrami: Beth, can you send us your documentation on that please and I will share it with the whole
group?
Cooley: Absolutely. It's directly from the California legislature.
Juvet: Mr. Chair, in light of changing that first word in the bold from "require" to "encourage", doesn't
that make the entire second sentence unnecessary? I don't understand how the municipality will have
the ability to enforce this.
Sherman: Dave, I think they can't anyway. I would get rid of the second sentence. I just don't think they
have the ability to do this.
Woods: I agree with the comments about what is currently available legalistically. However, I think part
of the concept of this report is what we think we would like to see obtained, a sort of wish list if you like.
Then the actual application or translation into legislation would take these factors into consideration. I
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have no trouble with the changes in view of honoring the legal aspect. But by the same token, I don't
think we should shy away from stating what we think should be the standard and let that be heard.
Sherman: One way to do that would be to state the goal in your first sentence and then state in your
second sentence how you would hope to get there.
Heroux: This could be done by the municipality.
Sherman: Well, as Gary said, you would need to have a statutory change probably at the federal level.
So you could encourage. That's what we are doing in my town because we arer working with the
industry and it's actually going to be fine. So, one way is to encourage. The other way is to ask for
Congress to change the law.
Heroux: I just proposed to say that this could be done by the municipality during the permitting process.
Sherman: I don't think they can do that right now.
Abrami: We will take that last sentence out and move forward with this.
Garod: I think I have to agree with Beth and Senator Sherman. I don't think there is anything wrong with
encouraging municipalities to consider these factors when they are negotiating the placement of towers
and when they are having a conversation about where it makes the most sense. But I think if you do
anything that is seen as encouraging them to require a certain placement, the commission would be
encouraging them to do something that is preempted by federal statute. I think the commission should
stay away from any type of recommendation that suggests that municipalities have the ability to simply
restrict where these towers are placed because I don't think they have the ability to do that.
Wells: Perhaps, when we revisit this in the workgroup, we can see whether this recommendation should
be linked to recommendation one which calls for the delegation to look at the federal law.
Sheman: I think we are tight on time. Should we move to recommendation eight and agree that this
needs work?
Abrami: Ok. No vote on number seven. The workgroup will work on it and maybe integrate it with
another recommendation. The next time the full commission meets, we will vote on it.
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 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 the RF power intensity
related to radio frequencies at a property which they will be purchasing or renting before the
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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 https://oplc.nh.gov/home-
inspectors/index.html
Wells: This recommendation puts in place training for home inspectors that is offered then by the Office
of Professional Licensure and Certification. Just as homeowners can request testing for radon or mold,
they should be able to request testing for RF exposure on their property or prospective property and
expect that the person doing the measurement has had training on the use of the equipment.
Abrami: the point is, we are not talking about making it mandatory. It deals with training inspectors to
be able to do the measurements. So if someone has concern, if they are RF sensitive or whatever and
they want they can go to somebody that's trained on how to do the measurements. This is totally
different than the original recommendation eight. Several people had concerns with the original
recommendation, myself included. If someone bought their home decades ago and cell towers were
put up, there is nothing they can do to mitigate that problem. If an inspector found lead paint or a
water problem, there are things they can do before the house is sold to mitigate that problem. This
addresses that if someone wanted testing done, that inspectors are trained.
Gray: With this one, I am sure that Beth is going to tell me that this assumes that radiation is bad and all
that. Again, non-mandatory, a state approved way to license. I don't have a problem with. They should
have a reliable place to go to get those measurements from a qualified person might be a better way to
go might be better.
Chamberlin: This is mostly on wording. In the second paragraph, the majority of the commission
believes the public has the right to discover etc., and it says "at a property that they will be purchasing
or renting before the transaction is closed". You know, that could be read as almost being a
requirement before the sale, which it isn't. Also, it implies that the time when you could get testing
done is when you are buying or selling something. I would like to keep it more general and that any
citizen that wants this done, can call upon this service. Can we reword this so it makes it clear that it is
voluntary and it is not necessarily tied to buying and selling of properties?
Wells: It should also be an option if you want as part of a building inspection as part of an agreement on
something you don't own yet. There is nothing about requirement in there. The seller could say no. I
refuse to have it inspected and go away and I will find another buyer.
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Heroux: I might have been the one to have suggested this and the actual intention was to avoid bursts of
demand as a result of some article and make the requirements for testing more evened out over time. I
recognize that it's true, if you are buying or selling something, this might be a variable of interest.
Abrami: We are running out of time. I know a few of you have to go but I would like to vote on this one.
Maybe the workgroup can work on the wording to make it clear it's voluntary. Is that okay?
Chamberlin: Yes. That addresses my concern.
Abrami: Then we can come back for another vote. Any workgroup changes will come back to the group
for another vote. I move to vote.
Wells: second.
Abrami: I am going to call the roll: Tom Sherman (yes), Ken Wells (yes), Kent Chamberlin (yes), Carol
Miller (abstain), Denise Ricciardi (yes), Dave Juvet (abstain), Beth Cooley (abstain), Brandon Garod
(abstain), Michelle Roberge (abstain), Paul Heroux (yes), Gary Woods (yes), James Gray (no), Patrick
Abami-Chair (yes). There are 7 (yes); 1 (no); 5 (abstain). The motion passes and will be revisited.
RECOMMENDATION 8A- 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. Appendix XX outlines in more detail the technical aspects of
this recommendation.
Wells: So 8A is what we would do with the data that home inspectors come up with. One of the things
would be that the State of New Hampshire would begin an effort to collect that data in such a way that
we can identify geographic areas of notably high RF exposure and places where RF exposure is
unusually low and this would be published in a database or a map. It could be used for future health
investigations or for people who are looking for places with lower RF exposure.
Abrami: We are also talking about the state taking this on to actually do some measurements,itself. Am I
correct on that Ken?
Wells: Yes. That could be a part of it. We talked about the way that Vermont did it. For the most part,
this recommendation talks about a low cost way of assembling the data by collecting the data from
licensed home inspectors.
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Abrami: I can see that being added to the data. That would probably take a long time to get a real
picture. The one thing we agreed on was we didn't want the general public taking their own
measurements because there is no control.
Wells: It says here that the state of New Hampshire should begin an effort to measure RF intensities
throughout the state. That does not preclude the state from having someone from the proper agency go
around and take measurements.
Abrami: The essence is we want the state to look at the mapping of RF radiation and if recommendation
8 goes through, that data would be collected as well. These would likely be part of the same legislation.
Gray: My objection to this goes back to the state having to go through this. We haven't proven that
there is a big problem yet. I would suggest that Kent work through the University system, get some
grant funding and fund this thing. They can do all the studying and data recording and all the
measurements that they want to but I don't believe that the state should be required to put together
the organization to go do this. Thank you.
Cooley: I will be opposing this 8A as it tries to undermine safety standards that are set by the federal
government with the potential to mislead residents that somehow RF within legal limits, is dangerous.
So, I will be voting no. Thank you.
Sherman: Just to respond to Beth's comments. Actually, I don't think that's the case at all. Suppose if we
find RF levels within the state that are exceeding federally acceptable levels. I am Chair of the
Commission on chronic illness that has been standing since 2014 or 2015, looking at the link between
human health and chronic illness. This kind of map is something we've been envisioning on all sorts of
things. DES and DHHS are actually looking at this in relation to arsenic and bladder cancer and we've
talked about expanding this. So these ideas of maps are not new. I think right now, it's a huge unknown.
If the state of New Hampshire were to do this or if somebody were to develop a map, I think it would be
very helpful. We may be surprised that we may have various RF exposure that far exceeds federal limits
but right now, we don't have any clue what those levels are.
So, I don't think that is correct, Beth. I think that this would be useful information making sure that
people are not unwittingly being exposed to levels that are beyond what our federal industry accepted
levels.
Abrami: Again, we don't say in this recommendation that we are setting different levels.
Roberge: I would just echo what I have said previously. If this intention is that this recommendation be
implemented by a state agency, then funding would be necessary. I don't know if you can build language
in there similar to recommendation three.
Abrami: The state of New Hampshire "should fund an effort"...how is that?
Wells: I think this could be done in conjunction with the training of the home inspectors. If it's part of
their training to do half a dozen measurements in locations the state is interested in.
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Juvet: Mr. Chair, starting out that statement with the state of New Hampshire clearly implies it's the
state.
Abrami: "The state of New Hampshire should fund or find resources to support the beginning of an
effort to measure RF..."
Wells: I am not comfortable with that. One of the advantages of having the state do it, is that the state
does not have a conflict of interest. I can imagine if there were entities that would have a conflict of
interest and the data collected may not be believed by everyone.
Abrami: Right. We talked about this last time Michelle. Obviously, this isn't going anywhere unless
legislation is passed. And if we want the state to do this, there would have to be funding as part of the
legislation. It would have to have budget dollars associated with it. Again, this is more of a statement of
what we would like to see happen.
Roberge: understood.
Abrami: I am going to say, just keep it the way it is. Is there any other discussion? I move
recommendation 8A.
Wells: second.
Abrami: I am going to call the roll: Tom Sherman (yes), Ken Wells (yes), Kent Chamberlin (yes), Carol
Miller (abstain), Denise Ricciardi (yes), Dave Juvet (abstain), Beth Cooley (no), Brandon Garod (abstain),
Michelle Roberge (abstain), Paul Heroux (yes), Gary Woods (yes), James Gray (no), Patrick Abami-Chair
(yes). There are 7 (yes); 2 (no); 4 (abstain). The motion passes.
RECOMMENDATION 9- Require all new cell phones sold in New Hampshire 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 Appendix XX for more detail 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 then 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.
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Abrami: Number nine has to do with cell phones and I will let Paul explain it.
Heroux: Essentially, there is in cell phones a system that blanks out the screen when it's close to the
head. This was originally intended to prevent the soft keys from being activated and the battery from
being spent unnecessarily. This software could also interrupt the radiofrequency radiation so that when
you bring it against your head so that half of the radiation that was previously broadcast into your head
does not exist. In other words, you could use your cellphone exactly as before but you would need to
hold it a certain distance from your head as instructed in most manuals sold with the cell phone. Or you
could place it in front of your face or place it on the table for example.
Abrami: So the internals of the cellphone can do this with an app, is that correct?
Heroux: Either an app or a modification in the embedded code that is in the phone.
Cooley: since I had to drop early from our last meeting, I didn't get to speak on this recommendation.
We are strongly opposed to this. Not only does science not require any of this. This is not necessary. The
FCC has a 50 fold safety factor and there is no safety risk. I would be remiss not to point out Berkeley.
The decision from last week in terms of compelled speech and First Amendment issues and I will just
leave it at that and I will be voting no on this.
Sherman: I am just concerned that when we carve out New Hampshire as a different market from the
rest of the entire world. To me, it's a little concerning. I am wondering if the intent here was to have
this software that could be enabled by the user rather than something that would be inflicted on them.
In other words, you go into your phone and you say I want this to automatically turn off when it's a
certain distance of my body. You have activated that software and that keeps it a choice issue. I think
that might be a little more doable. I worry about this one. I understand the intent and agree with the
intent. But I wonder if making it enabling rather than mandating might be a better way to go.
Heroux: As it is, it is a choice of the user, you have to realize. Of course if you don't have the software in
there to do this, you can't do it. In other words, every individual has the choice to accept this radiation
when it's against their head or to reject it. We have discussed this issue of choice before. I believe Rep.
Abrami brought it up and it was decided that adults should have the choice to use the phone and
irradiate their brain if they wish but that the facility to subtract themselves from this radiation should be
provided because it is technically very easy to do. In a sense, it is a negligence of industry not to have
provided this before.
Heroux: So, Paul what you are saying is that this would have the software not activated but present so if
the consumer chooses to use it.
Heroux: That is entirely right. If I may take off the gloves here.... The first thing that will happen from
industry is that when the software is included, they will instruct all their sales force to do a favor to the
buyer and say I will undo this for you. That's what I expect would happen because they do not want
even this capability to be known. I think this is unfair to users.
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Gray: If we continue to debate all of these instead of just accepting comments, we are never going to
get out of here. My comment on this one is that on recommendation three, we are already putting out
information on a site and using this as a hands free device which most cellphones do.
Abrami: the real essence of this recommendation is that it is possible to do this. I kind of agree with
Tom. If it's true that most phones can do this, do we encourage entrepreneurs to come up with apps
that allow people to buy and do this on their own? My understanding was that this existed in the
phones, sensors. The question becomes would an app be allowed by a third party to be put on a phone
to turn it off? There are many apps that go on phones, so I don't know. Do we need the cell phone
industry to bless this or not?
Again, we are making a statement here. I would almost say "encourage"
Sherman: How about this wording? "Encourage that all new cell phones sold, come equipped with
updated software that allows the user to automatically stop the phone from radiating when positioned
against the body.
Abrami: It would be a tough sell in NH now that I think about it. There are some states with different
emissions limits than others. The auto industry actually does comply with those different limits.
California has different fuel standards.
Sherman: But California has a slightly different market share then New Hampshire.
Abrami: you got that right. We are the rounding error. But we like to be first in stuff though. So, with
those two changes, any more discussion? I move recommendation nine.
Sherman: I will second.
Abrami: I am going to call the roll: Tom Sherman (yes), Ken Wells (yes), Kent Chamberlin (yes), Carol
Miller (abstain), Denise Ricciardi (yes), Dave Juvet (no), Beth Cooley (no), Brandon Garod (abstain),
Michelle Roberge (abstain), Paul Heroux (yes), Gary Woods (yes), James Gray (no), Patrick Abami-Chair
(yes). There are 7 (yes); 3 (no); 3 (abstain). The motion passes.
Abrami: I know that Denise has to leave at a quarter after. A couple of hers are coming up here at the
end. I know Gary has to leave too. I think what we may do ...
Woods: Mr. Chair I have number eleven and I think that should be pretty straight forward if you want to
do it that way.
Abrami: I think we will do it that way. We will do one more, number eleven. I will just have to call
another meeting. I said a potential of two more meetings so before I lose everybody, can we meet in
two weeks? The 8th or the 9th?
Sherman: Why don't we do 10-11:30 on Thursday, October 8th?
Abrami: Ok. Subgroup I will reach out to you
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Garod: I am sorry to be the one who jams everything up but I have a prescheduled meeting on the 8th at
11. I will be available for the first hour.
Abrami: We will book 1.5 hours but let's say it's going to be an hour meeting. If we just do the
recommendation votes, we should be able to get that done in an hour. Let's just do number eleven.
RECOMMENDATION 11- 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.
Woods: Basically, this just addresses the issue of further studies needed and addresses the issue of
transitioning from what are called in the physics world, bulk materials to the actual quantum mechanical
effects. We discuss these in a little bit of a peripheral way but have addressed such as proton tunneling
and other similar quantum mechanical effects which really represents the way that all radiation
interacts with molecular entities. That interaction is a base for cellular activity and as a consequence,
also organ and overall systems activity. Those are really needed and they are just now coming on line. I
think the bulk studies that have been done in the past, point out that we do need to look at this further.
They were inconclusive for a variety of reasons. That's the inherent difficulty with bulk material studies
especially when they are as complex as cells and organs. We need to encourage further looking at this.
Secondly, as this comes to the fore, there is a push in the medical community to identify exposure to
these frequencies as a clinical entity. The State Medical Society and National Medical Societies are
looking at this to try and colleague information in a way that will identify these as a potential
designation of a syndrome. Indeed, the ADA already recognizes the exposure as a disability. I think it
behooves the medical community to be thoroughly and completely engaged in this process to identify
that dimension. So everything from the study, from the quantum mechanical effects which we've
addressed to the clinical designation is needed.
Abrami: this is calling for the medical community to work on this. This one really has to do with RF
sensitivity more than anything else. Gary is already beginning to reach out to the medical community to
start addressing this in a more thorough way.
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Woods: This is primarily meant for the readers of this report to identify that in fact there are other
things in the works and we need to pay attention to those. The person reading the report will not only
understand the other dimensions outlined in the other recommendations but that we as a commission
recognize that this is a direction that we need to go and this is a direction that we need to go.
Sherman: I just had one little wordsmith in the first line. Gary would you object to after the word
further" basic science and clinical studies are needed" so that it captures the full spectrum of basic
science up to the clinical.
Woods: you could put it that way. The second portion of that, the medical community outlined that
studies are needed in conjunction with clinical studies.
Sherman: Ok.
Cooley: I will be voting no on this. Take a look at the World Health Organization statement on this. That
is why I will be voting no. Thank you.
Abrami: Any more discussion? Ok. I move recommendation eleven.
Heroux: I second.
Abrami: I am going to call the roll: Tom Sherman (yes), Ken Wells (yes), Kent Chamberlin (yes), Carol
Miller (abstain), Denise Ricciardi (yes), Dave Juvet (no), Beth Cooley (no), Brandon Garod (abstain),
Michelle Roberge (abstain), Paul Heroux (yes), Gary Woods (yes), James Gray (no) because I think it
should be a sub of recommendation one, Patrick Abami-Chair (yes). There are 7 (yes); 3 (no); 3
(abstain). The motion passes.
Abrami: thank you all. As far as the Minority Report, Jim and I traded emails back and forth about
whether a subcommittee is needed on the Minority Report. Joel doesn't think it's necessary but I know
you had some concerns Jim about 91A stuff.
Gray: If you form a group, then I have to follow 91A and publicize the meetings and all those other
things. If we don't have a quorum of the group then it can be informal. We can email back and forth and
then present it to the group as a recommendation.
Abrami: those who want to sign onto the Minority Report, you can give your suggestions to Jim and
correspond back and forth but there can't be meetings.
Gray: right. Forming a group would hinder me from writing the report. As long as I don't have quorum of
the whole group or any committee of the group, then we can get together and talk about it because that
small group cannot make decisions that are binding on anyone. Everyone should have a copy of what I
wrote to begin with. I think Beth would like me to put at least a paragraph in there about the FCC and
their requirements and I have no problem doing that. If other people want to communicate with me,
just use my legislative email: james.gray@leg.nh.us. We will certainly publish it out through Pat to the
rest of the group.
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Abrami: I am ok with that. Joel's counsel to me was it was ok if you guys interact. I just wanted to make
sure that was your understanding Jim.
Thank you everyone. I know some of you had to leave early. You know these commissions we have
people from industry, it's very difficult to get unanimous on any of this stuff. That's why we are doing it
the way we are doing it with the Minority Report. The legislature has recognized this and I ran into
similar things with the Marijuana Commission. There were differences of opinion that could not be
reconciled. The resolution that the legislature has is a Minority Report built into the total report so
people don't miss it in fairness. So that is where we are at. We will see everybody in a couple of weeks.
V. Next meeting via Zoom: October 8th 10-11:30 am
Meeting Adjourned at 11: 27 am
Text chat during Zoom meeting:
Chat from HB522 5G Commission Meeting, Sept 22, 2020
From Rick Maynard to Everyone: 09:02 AM Morning All.
From Deb Hodgdon to Me: (Privately) 09:04 AM thank you
From Cece Doucette to Me: (Privately) 09:08 AM Morning, Kent. If the Recommendations document has
changed from the one you sent me dated 9/17 in the file name, would you mind sending it to me?
Thanks.
From Me to Cece Doucette: (Privately) 09:09 AM We will be discussing the version that I sent you.
From Cece Doucette to Me: (Privately) 09:12 AM Supah, thanks!
From Cece Doucette to Me: (Privately) 09:29 AM Rec. 1, non-bold paragraph, first line: (TTA) should be
(TCA)
From Cece Doucette to Me: (Privately) 09:42 AM Rec. 2 bold section, line two, in parentheses, (there)
should be (their). Also, line 5, after "cell phones" might you consider adding, "and other wireless
devices"?
From Helene to Everyone: 09:47 AM We are very concerned about having a cellphone tower being
installed in less than 1/4 mile from the front of our home. We are listening to this meeting today so that
we can be active in this process to ensure that residents of NH have a seat at the table to ensure that we
have representation to protect our health and rights
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From Rick Maynard to Everyone: 09:48 AM Thank-you all. Take care, I have to go.
From EH Trust to Everyone: 09:49 AM Published research o cell towers here https://ehtrust.org/cell-
towers-and-cell-antennae/compilation-of-researchstudies-on-cell-tower-radiation-and-health/ research
on 5G https://ehtrust.org/scientific-research-on-5g-and-health/
From Helene to Everyone: 09:49 AM considering that we are currently in the process of dealing with our
Town and a Wireless Tower company that gained approval in a way that we feel was not appropriate.
None of the neighbors were included in the meeting and we are being told by the Town committee that
we never would have had any say in the tower being approved because of the current laws in our State,
regardless of our concerns
From EH Trust to Me: (Privately) 09:51 AM Can I record please . It is a public meeting. I requested to
record
From Cece Doucetteto Everyone: 09:52 AM Rec. 3, at the end of the bolded section, please consider
adding after "pregnant women" the other vulnerable populations, "the elderly and those with existing
health compromises."
From Me to EH Trust: (Privately) 09:54 AM I'm not able to grant permission to record during an active
meeting. However, verbatim minutes will be posted on our public website.
From EH Trust to Me: (Privately) 09:56 AM Thank you, I thought it was an open meeting so we could
From Helene to Everyone: 10:01 AM The biggest concern is that they are allowed to put numerous
antennae on top of the towers which can increase the emf emissions greatly. Please consider this.
From Cece Doucette to Everyone: 10:13 AM Do we have long-term studies on Li-Fi? Perhaps we can
modify the bold where it says, "optical connections" to "optical connections if proven biologically safe."
Rec. 5, second unbold paragraph, please be careful about recommending LEDs, many suffer negative
biological effects from them today.
From Helene to Everyone: 10:17 AM Here is a caveat; we have a cell tower going up in less than one
mile from 2 schools. What good is converting over to broadband or fiber optic technology (which is not
only better, but less risky for security purposes) when there is a cell tower with 10 - 20 antennae located
so close and children are exposed 5 days/week for 6-8 hours per day. Health concerns are not only for
children, but all people are susceptible to emissions. Many towns are now electing to not install towers
due to the findings from many studies and the notable increased health risks
From EH Trust to Everyone: 10:32 AM You can watch a news investigation that shows it was lobbying
from firefighters here https://www.youtube.com/watch?v=61h_vuBujwO&feature=emb_title Affidavit
of Susan foster https://ecfsapi.fcc.gov/file/7022117660.pdf
From Helene to Everyone: 10:32 AM Should we remind everyone that the FDA has approved numberous
medications in the past as SAFE, but they were not. Tobacco and asbestos were considered safe and
they were not. We have evidence from other countries that this technology is not safe, yet it is being
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shoved down our throats and to comment that NH would be an outlier is wrong and uninformed. Thank
you Dr. Heroux for pointing that information out. There should be several regulations implemented
keeping towers from close proximity to residential homes, schools and businesses. There are OTHER
safe options available and people should have the right to say NO to unsafe technology, especially until
it is found to be made safer.
From EH Trust to Everyone: 10:35 AM Resources on firefighters here https://ehtrust.org/firefighter-
unions-opposing-cell-towers/
antennas on forestations were carved out of the bills Fire stations AB57- Firefighters have gotten an
exemption to have cell towers on or adjacent to their facilities. This was codified in California's 2015
legislation AB57 . CA AB57 (2015) Legiscan Text of Bill. " Section 65964.1. (f) Due to the unique duties
and infrastructure requirements for the swift and effective deployment of firefighters, this section does
not apply to a collocation or siting application for a wireless telecommunications facility where the
project is proposed for placement on fire department facilities. " SB649- They also received an
exemption in California's SB649 (2018), a bill which was vetoed by GovernorBrown. SB 649 California
(2017) Wireless Telecommunications Facilities - 65964.2. "(a) A small cell shall be a permitted use
subject only to a permitting process adopted by a city or county pursuant to subdivision (b) if it satisfies
the following requirements: ....(3) The small cell is not located on a fire department facility."
From Cece Doucette to Everyone: 10:35 AM You can replace the firefighter passage with: Please note,
in 2004 the International Association of Fire Fighters adopted a formal Position on the Health Effects
from Radio Frequency/Microwave (RF/MW) Radiation in Fire Department Facilities from Base Stations
for Antennas and Towers for the Conduction of Cell Phone Transmissions. They oppose them, "until a
study with the highest scientific merit and integrity on health effects of exposure to low-intensity
RF/MW radiation is conducted and it is proven that such sitings are not hazardous to the health of our
members." They reaffirmed that stance in California's 2017 Senate Bill 649 which would take away
municipal home rule to place more wireless infrastructure in our communities, on poles in the public
rights of way, at street level every 4 to 12 homes. They included an exemption in the bill: Section 2
"65964.2. (a)...(3) The small cell is not located on a fire department facility." Every citizen should have
the same protections.
From EH Trust to Everyone: 10:36 AM The news investigation details the fire fighter position. You can
watch it all here https://www.youtube.com/watch?v=61h vuBujwO&feature=emb title
From NR to Everyone: 10:38 AM New Hampshire does have the legal right to "require" those setbacks.
According to the TCA of 1996 - 47 U.S.C. § 332(c)(7)(B)(i)(l) is very clear: in only prohibiting
discrimination between "providers of functionally equivalent services." "Functionally equivalent
services" are defined as those wireless services functionally equivalent to those being provided by the
"personal wireless service facilities" for which approval is sought. Therefore, a county zoning ordinance
that imposed different and stricter procedural requirements (e.g., conditional use) on wireless service
facilities than on facilities used for providing fiber to the home, cable TV, utilities, or other services
would not be in violation of the law. Moreover, 47 U.S.C. § 253 does not prohibit the county from
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imposing stricter procedural requirements on WTFs than on cable or other uses of facilities. Section 253
has three relevant parts. Section 253(a) creates the general rule that "[n]o State or local statute or
regulation, or other State or local legal requirement, may prohibit or have the effect of prohibiting the
ability of any entity to provide any interstate or intrastate telecommunications service". In turn,
subsections (b) and (c) are "savings clauses" that provide safe harbors to protect the ability of states and
localities to regulate zoning and construction of wireless facilities:
From NRto Everyone: 10:38 AM (b) State Regulatory Authority
Nothing in this section shall affect the ability of a State to impose, on a competitively neutral basis and
consistent with section 254 of this title, requirements necessary to preserve and advance universal
service, protect the public safety and welfare, ensure the continued quality of telecommunications
services, and safeguard the rights of consumers, (c) State and Local Government Authority Nothing in
this section affects the authority of a State or local government to manage the public rights-of-way or to
require fair and reasonable compensation from telecommunications providers, on a competitively
neutral and nondiscriminatory basis, for use of public rights-of-way on a nondiscriminatory basis, if the
compensation required is publicly disclosed by such government. From Helene to Everyone: 10:41 AM
Yes, Rep Abrami. Exactly what we are going through right now. From GARY WOODS to Me: (Privately)
10:41 AM will you be able to forward the "chat" to us? From Helene to Everyone: 10:42 AM Cell tower
will be erected within the hot zone of our home and we are being told that we have NO rights
From Deb Hodgdon to Me: (Privately) 10:46 AM kent see chat on state rights
From EH Trust to Everyone: 10:49 AM You can see how Switzerland measures RF and posts it fr all to
see here
https://map.geo.admin.ch/?topic=funksender&lang=en&bgLaver=ch.swisstopo.pixelkartefarbe&lavers=
ch.bakom.mobil-antennenstandorte-5g.ch.bakom.radio-
fernsehsender.ch.bakom.mobilantennenstandorte-gsm.ch.bakom.mobil-antennenstandorte-
umts.ch.bakom.mobil-antennenstandortelte&catalogNodes=403.408
From Me to GARY WOODS: (Privately) 10:51 AM Yes, I'll forward the chat after the meeting.
From Cece Doucette to Everyone: 11:03 AM
Most kids don't use cell phones against head, but they do have their cell phones, tablets and laptops on
their bodies. Please expand this to all wireless devices, not just cell phones.
From EH Trust to Everyone: 11:05 AM Phones exceed RF limits at body contact My daughter uses the
phone to her head. I think it should be for al wireless devices as well. Many lawyers and politicians and
coaches use cell phones to their head, and most people carry phones touching their body and in bras
From Cece Doucette to Everyone: 11:17 AM Doctors, nurses and others can be trained January 28-31 at
the EMF Medical Conference. There are IDC codes already established and in use today. There is an EMF
primer offered October 23-24. Health care providers and the general public are invited to register for
both, https://emfconference2021.com/
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WHO has reopened their investigation into in 2020 based on recent science showing cancers,
reproductive issues and other effects: https://www.who.int/peh-
emf/research/rf ehc page/en/indexl.html
From EH Trust to Everyone: 11:20 AM The Who EMF Project has no transparency as published research
shows here https://www.spandidospublications.com/10.3892/ijo.2017.4046 Whereas The Who IARC is
independent and scientists are vetted for conflicts of interest Our scientists letter to the EHO about the
"factsheets" they post online was never answered https://ehtrust.org/scientists-call-for-transparency-
at-the-world-health-organization-emf-project/ The Who refuses to answer these questions
From Cece Doucette to Everyone: 11:22 AM Yes, just like the FCC refuses to answer this Commission's
questions.
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
10/8/20
10:00 am-12:00 pm EST
Via Zoom ( https://urih.zoom.us/j/8760768986)
Via telephone-US (1 312 626 6799 (US Toll) ID: 876 076 8986)
In attendance:(13)
Rep. Patrick Abrami-speaker of the house appointee
Rep. Ken Wells- speaker of the house appointee
Kent Chamberlin-UNH-appointed by the chancellor
Denise Ricciardi-public-appointed by the governor
Michele Roberge-DHHS- Commissioner of DHHS appointee
Dr. Paul Heroux- Professor of Toxicology, McGill University- speaker of the house appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Senator Tom Sherman-president of the senate appointee
Brandon Garod-AG designee, Asst. AG Consumer Protection
Bethanne Cooley-CTIA, trade association for wireless industry and manufacturers
Carol Miller-NH Business & Economic Affairs Dept
David Juvet-Business and Industry Association
Not present: (0)
Meeting called to order by Rep Abrami at 10:03 am
Abrami: Due to the Covid 19 virus and the Executive order signed by the Governor this public meeting is
allowed to be conducted via Zoom. It is open to the public for viewing and was duly posted as a zoom
meeting. With that said, if you are not a member of the Commission, can you please turn your cameras
off and mute yourselves? That would be much appreciated. In addition the meeting is being recorded as
an aid to doing the minutes. All chat room discussions will be included in the minutes.
I. Approval of minutes from 9-22-20:
I have not received any changes to the minutes that I sent out about a week ago. Are there any changes
that anyone wants to make? Seeing none, I will say ...without objection, we approve the minutes from
that meeting.
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II: Agency Disclaimer:
I sent out the agency disclaimer that will be in the report. That is there especially for the agencies. I
think I heard back from two of you. I can't recall if I heard from all three of you. My sense is that the
language is okay with your leadership. I think most of you took it up the pole to your leadership. I think
you are all okay with that language. I am looking at Michelle, Carol and Brandon. Yes? Ok. So, we are
good there. That language will appear in the report.
Ill: Vote on Recommendations (6.7.8.10.12.13.14):
Some of these recommendations we voted on but said we would change some of the wording so we are
going to go back to them, discuss them and take another vote. We may have to revisit #9 as well. The
work group changed some of the wording.
I would like to work backwards so Brandon can at least hear the discussion on the ones we have not
discussed before and be involved in that vote. I sent the updated document out. It's the document
dated October 5th in the upper right hand corner. We will start with Recommendation #14. Denise,that
was yours.
RECOMMENDATION 14- 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 ofRF
wireless technologies. Concern comes from the fact that the FCC is projecting that 140,300 low orbit
satellites, 800,000 5G small cell antennae plus many additional macro towers will be 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.
Ricciardi: We had discussed doing something about the environmental impact with the expansion of
wireless technology. The reason I addressed it is because we have an act: the National Environmental
Policy Act (NEPA). That statute requires that the agency consider environmental concerns in their
decision making process. New Hampshire should be able to request for documentation to be provided
of such considerations for the impacts on our environment. That's why I wanted to use this NEPA to
reflect that.
Abrami: Any discussion? I don't see anyone. Ok. Without any discussion, I will move to vote. We will
take the votes as we did the other day. Is there a motion to accept the recommendation?
Cooley: Mr. Chair, before we do that. Are you guys getting feedback?
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Abrami: Yes. Someone is not muted. Please mute yourselves. Thank you, Beth. I was hearing that as
well. The static is gone now.
Ok. I need a motion that we accept the recommendation.
Ricciardi: I make the motion that we accept recommendation #14.
Chamberlin: I second it.
Sherman: Are we going to have discussion on this, Patrick?
Abrami: Yes. I did ask for discussion.
Sherman: I just want to clarify one word and that is "fact" in the second sentence. We have seen the
citation that the FCC is projecting 140,300 low orbit satellites. Is that from an FCC publication? I just
want to be sure that that is a verified fact and that the FCC has stated that.
Ricciardi: It is a fact that Ajit Pai stated that the FCC estimated 800,000 wireless facilities for 5G. That, I
know for sure.
Wells: Yes, the 14,300 is the number I have heard associated with the SpaceX operations. There is a
citation for the 800,000 in the chat.
Sherman: I just want to make sure that we have the documentation if someone asks, is that truly a fact?
This has come up on other recommendations. If you have the documentation that the FCC has projected
that, then I am fine with it the way it is.
Ricciardi: Yes and I am sending it. I am trying to make sure I don't miss anybody.
Gray: The relevance of this...are we saying that the radiation from those satellites are going to cause
damage to people, DNA, heating, all of those things? Yes. There may be that many satellites but what
relevance does that have to our committee? It's like the thing that you sent out the other day about Van
Halen having a metal guitar pick and he attributing that to his cancer and discounting all of the smoking
that he did for years and years. A lot of this stuff, although may be interesting, it is just anecdotal. It is
not a fact. It is not good science. It is not worthy of being talked about and reported in the minutes of
these meetings. Thank you.
Woods: I understand the Senator's comment on the relationship and how this recommendation #14
does not make that direct connection. This is basically an assessment of the degree to which the level of
radiation is increasing. The rest of the report relates to the basic science. This does not address basic
science and its relationship to cellular or organism impact. But, just a documentation of the prevalence
and so in that sense, I think it should remain.
Abrami: The third piece of this was additional macro towers to make the networks function. I would
imagine without much stretch of the imagination, there would be more macro towers. I know we got
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the low orbit satellites from somewhere because originally we had 140,000 and Ken, I think it was you
who said, it's 140,300.
Wells: I can look for a link on the satellite numbers.
Heroux: the point of the recommendation is that the FCC is avoiding a NEPA review, while modifying the
environment substantially. It doesn't qualify the consequences, it just says that the US formality is that is
normally fulfilled, has not been, by the FCC.
Abrami: Ok. While Ken is looking for that, let's hold on the motion and move to #13.
Wells: I found a news article from March of this year that the FCC has approved up to a million small cell
antennae for the Starlink network.
Woods: If I could clarify that Ken said antennae but the question was about satellites.
Abrami: Ken you keep looking. We will skip this one for now. Denise, please speak to #13.
RECOMMENDATION 13- 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 natural environment; trees, plants, birds, insects, and pollinators.
The majority of the Commission understands that current Federal safety limits set twenty-four years ago
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 humans to
5G cell antennae and associated 4G densified infrastructure. In fact, the wireless radiation from cell
antennae could exceed safe limits when leaves of trees and flying birds and, since they may have higher
exposure 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
XX.
Ricciardi: We all discussed that the State of New Hampshire should engage agencies with the
appropriate scientific expertise including ecological knowledge to develop RF radiation safety limits that
will protect the natural environment: trees, plants, birds, insects and pollinators. I like this
recommendation.
Abrami: I prefer that we have a discussion before we move to vote in case there are some slight
modifications that we can agree to. I will open this up to discussion.
Heroux: I thought we had agreed to remove the word "environment" and use the word "ecology".
Abrami: Yes. We did. What we agreed to was " including ecological knowledge".
Heroux: I think you should remove environment from there entirely and put: trees,plants, birds, insects
and pollinators.
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Abrami: get rid of "natural environment" is that what you are suggesting?
Heroux: yes.
Gray: One of the key things you cited is data from twenty three years ago. There is also both FDA and
FCC guidance that have been promulgated on this that's dated in "18/19 and '20 where they state that
they have reviewed the current science and nothing like that is even mentioned in this
recommendation. Again, I think you are giving the opposing argument short shrift on this and not
considering all the science that is out there.
Sherman: could I say something? Senator Gray and I and everyone in the legislature, understands that
federal limits and regulations may not necessarily reflect the latest science. The most recent example of
this is the EPA and their regulations on PFAS, which still is at 70 ppt. No scientist worldwide would say
that is adequate protection. So, we actually had a bill that we passed asking the DES through their
science and toxicology to go ahead and come up with maximum contaminant levels.
I, for one, always find it a little fascinating for us to say: well let's just trust the federal government to
do the right thing when we know they are not necessarily doing it. If we want to wordsmith the second
paragraph, that's fine but I think there is absolutely zero harm having the scientists that are part of our
state already and we have great ones at DHHS and DES to take a look at the science and perhaps come
up with their own recommendations for guidelines. Not only is there legislative and statutory precedent
for this kind of thing, we have selective trust of the federal government when it comes to these scientific
matters. We have generally erred on the side of saying: well, let's take a look at it ourselves. I would say,
let's vote on this one and move on.
Ricciardi: Thank you, Senator Sherman.
Gray: Again, I am not saying you are not going to put this recommendation in. I am saying that you say
the guidance out there is 23 years old, but you don't mention the documents from '18/19 and '20 that
affirm that they have conducted reviews that are of the current data that is out there. Unless you are
going to treat both sides fairly, then the report you get at the end has no meaning.
Abrami: If you read on, it says with the intention of only protecting humans from short term effects.
Obviously the first studies were done on humans, not birds, plants, insects and pollinators. I am ok
taking the 24 years out but as Tom said, even with that, the state doesn't necessarily trust what the
federal government has done.
Sherman: Mr. Chair, I have a fairly straightforward wordsmith that hopefully addresses Jim's concern. It
could say: "the majority of the commission understands that current federal safety limits were made
with the intention of only protecting humans from short term effects" They have looked at subsequent
science but they are the same so we don't have to get into that. We can just capture that by saying the
intention.
Abrami: right. Thank you for helping with that one. That was my feeling.
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Sherman: If there is no further discussion, we should move. We have to keep moving.
Abrami: we are up against a time clock here. That's why it may appear that I am rushing.
Roberge: Just a recommendation. In recommendation #1, we are asking our federal delegation to
require the FCC to look at the standards with respect to human health. I am wondering why we wouldn't
ask for them to look at the environmental impacts as well. An example of that was in my previous job at
DES, that at the EPA looking at the Clean Air Act and standards set by EPA, there is a primary health
based standard and a secondary environmental standard on things like sulfur dioxide and nitrogen
oxide. I am just suggesting that we add this on for recommendation #13.
Abrami: We had it separate to highlight that only human effects have been considered and I would like
to keep it separate.
Cooley: Just a comment and I don't me to belabor the point but this is more so for the minutes. States
do not have jurisdiction to set their own RF safety limits. That is the exclusive jurisdiction of the FCC. For
that reason, I will be voting no on this recommendation.
Abrami: Again, this is only to have the state study if it so wishes. This would be just like Tom was saying;
the state took the initiative to look at PFAS a little more closely. That's what we are doing here. We are
trying to add to the knowledge base.
Ricciardi: in 2018 and 2019, statements by the FDA are not about the birds, trees, and bees. If you look
at the FDA reports, they are only about tumors not environmental effects. As we said before, these are
just recommendations by our commission. Recommendations, do not go against the law as Senator
Sherman said, you would put legislation forward. With all due respect to everyone here, there is the
minority report. I don't feel that we should be constantly changing the one that the majority feels when
there will be a minority report. Thank you.
Gray: Again, Denise has her opinion. The thing is that this report should have the fair and equal
treatment of both sides of this issue. In paragraph one, you claim to have a fair and equal treatment of
both sides. Yet, on this recommendation before it was modified, you spoke to the 23 years and ignored
recent documentation issued by both the FCC and FDA. The FDA as far as I know is not in the business of
protecting the environment. I agree with that. But, then we didn't go look at other guidance out there to
see if it was relevant. All we are asking for is fair and equal treatment. There are experts that we would
like to present but we have not been able to do that because of time considerations and scheduling
problems with those experts.
If you are going to just put through recommendations on this issue that I feel are far and above what
should be done without looking at both sides of the science, then I might as well sign off this call and
resign from the commission because it's not doing me any good and it's not doing the citizens of New
Hampshire any good. You guys rail road this thing through. Fine. But we are not protecting the citizens
of New Hampshire and not providing the economic opportunities that a good and useful cell phone
system will provide them. It's just very frustrating.
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Abrami: Again, we lost four months due to the virus. I had a lot more speakers lined up and I kept saying
to Beth, come up with more speakers. There is no changing our end date on this.
Sherman: Mr. Chair, I just want to make sure the Jim knows that I hear what you are saying and the way
these commissions work is we try to be very respectful to everyone's opinion. We move forward as
much as we can together and the minority report is for any additional dissent or altering opinion. But
Denise, I think it's very appropriate for us to modify the final recommendations to fit as many people on
the commission as possible. I fully support making the change that Jim wanted which was getting rid of
the years and the timeline in the comment below. I hope we can move forward and bring this to a vote.
Ricciardi: I appreciate that and I understand. It's just the subcommittee has worked over and over again
all these iterations. But I do thank you for your comments.
Abrami: any other questions or comments on this? I would like to take this one to a vote.
Sherman: I am happy to move it to a vote.
Heroux: I second.
Abrami: It's going to be as shown and taking out the "natural environment" in bold and taking out "set
24 years ago" and adding "limits were made with the intention", in its place. We will go over all these
changes and do a final vote before we do a vote on the report. I will call the roll:
Tom Sherman: yes
Ken Wells: yes
Kent Chamberlin: yes
Carol Miller: abstain
Denise Ricciardi: yes
David Juvet: No, and I would like to comment. This implies that the state is going to be implementing its
own RF radiation safety limits which I think will invite a lawsuit. I can't support it.
Beth Cooley: no
Brandon Garod: abstain
Michelle Roberge: abstain
Paul Heroux: yes
Gary Woods: yes
Jim Gray: no
Page 7 of 37
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Pat Abrami: yes
Abrami: The motion passes, 7 yes, 3 no, 3 abstain.
Any information on the numbers for satellites, Ken?
Wells: Elon Musk has approval for 42 thousand but there are other satellite companies like OneWeb but
I don't know what the total number is. I would be fine if you want to remove that number of satellites or
just talk about the 42 thousand that SpaceEx has been approved for their Starlink project.
Abrami: I remember seeing articles when we first started this that there were two or three companies, I
think. If somebody could help me with that, I would appreciate it.
Heroux: You could put that the exact number will be updated by FCC documents. We know it's going to
be at least forty three thousand and it may be higher but I don't think that people will vote yes or no on
the basis of the exact number of satellites but rather on the impact of all these things.
Abrami: We can vote on the number as written with the intention that we find and have documentation
for it and all of these in the appendix and we can modify 140,300 low orbiting satellites before the last
meeting.
Sherman: I would recommend the following: I would take the sentence that starts with concern and un-
bold it and put it in the discussion. And change the part: concern comes from the FCC projection of
numerous low orbit satellites and 5G small cell antennae plus additional macro towers that will be
required for these networks to function. You still need documentation in there.
Wells: Citation 53 and 57 talk about FCC license approved.
Heroux: The satellite network is something very fluid. Some of these companies go bankrupt. Essentially,
there is a large uncertainty but I think that when the FCC mentions 800 thousand, it is their number and
it brings home the impact on the environment because "numerous" could be five. Five is not equal to
800 thousand. When we have a number that originates with the FCC, maybe it shouldn't be in bold
because it doesn't refer to a principle but at least it should be in the text underlying, in my opinion.
Gray: Again, the purpose of this commission is to study health and environmental impact. Are we saying
that every one of those satellites is affecting health or the environment? No. That's not possible. The
FCC has issued further guidance about whether there is a health effect and has said that they have
studied the current science out there and current reports that have been done by other people. Not
including a reference in this and many of the others to the fact of what the current position of the FCC
is, is one sided and not a fair and balanced part of the report. You can say whatever you want but we
need to present the facts on both sides, not the facts on one side. Trying to use the number of satellites,
the number of antennae, the number of this, the number of that and saying that that is going to affect
your health or the environment is purely trying to do fear mongering. Present the facts on both sides.
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Abrami: Let's not forget that we wrote to the FCC and the FDA questions that they did not answer. We
would love to have had them testify before us as well but that was not going to happen. They would not
even answer our questions.
Gray: the guidance is already there on the internet. I went and found it when I was preparing the current
minority report.
Ricciardi: It's a captive agency.
Sherman: I would just point out that if you look at the recommendation, it is not drawing any
conclusions, Jim. It's asking for further study. I don't think it's necessary that you have to say anything
when all you are asking is for further study so I disagree with you on this one. I do agree with Paul that if
you want to put a number in there that is a little more dramatic then numerous, you just need to be
sure that you have the source of that number documented. I am fine with a number as long as its source
is documented.
Woods: I agree that we should move forward with this. This is basically an assessment tool of identifying
prevalence. It's probably no different than the technology of putting roads in a hundred or so years ago.
We didn't' have roads or bridges and did not have to repair them. But now, we need to assess roads and
identify how many bridges we have that need repair. We are now in a different technology, wireless and
like roads and bridges we are trying to identify how many we have. We are not saying bridges or roads
are bad. We are trying to do an assessment of the prevalence of these items so that when we look at
whether they need attention or not, we will have some idea. Again, it's like trying to assess how many
bridges we have not whether they are good, bad or indifferent.
Wells: From a physics point of view, the number of antennas is relevant because if you have tens of
thousands of satellites and hundreds of thousands of small cell antennas and they are all emitting
energy, the energy density is increased by a factor of the number of antennas.
Abrami: Tom's suggested language moving it from the bold section to the explanation portion. Why
don't we do that and between now and the next meeting, if we can verify hard numbers we can put
them in the report. Is there any other discussion? Kent made motion to move the recommendation.
Denise seconded it. I will call the roll:
Sherman: no vote (not on screen)
Wells: yes
Chamberlin: yes
Miller: abstain
Juvet: no
Cooley: no
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Garod: abstain
Roberge: abstain
Heroux: yes
Wells: yes
Gray: no
Abrami: yes
I don't see Tom on the screen, so I will not count him. 6- yes, 3 -no, 3 -abstain. Motion passes.
RECOMMENDATION 12- 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 are sensitive to electromagnetic radiation emitted from devices used in the delivery of
in-building cellular, and fixed wireless services. A majority of the Commission suggests 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.
Miller: It's a simple recommendation for exposure signs to be posted in commercial and public buildings
especially in healthcare facilities. This is also to establish RF radiation free zones where employees and
visitors can seek refuge from the effects of the emissions. It's a pretty simple recommendation. Some
folks are doing it already. I can say that dentist's office tell you to shut your cell phones because it does
disturb the equipment. There it is and ready for discussion.
Gray: Are we going to include the report from the World Health Organization that says exposure to this
low level of radiation is not a factor and has not been scientifically tied to any syndrome? Is that going to
be included at all?
Miller: I don't know. If you think that would balance off this recommendation and would like it in the
appendix, I have no problem with that at all. Regardless of whether it's based in science or not, there are
many citizens that are sensitive to it. It's as simple as that, for me anyway.
Gray: Again, I am just trying to be fair. There are people out there who say they are sensitive to it but
there is no scientific tie in double blind studies that confirm that these people are actually suffering
effects of the radiation.
Heroux: and these people don't believe that.
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Miller: Right and it's just a recommendation. It's not required. We can add some NH citizens are
sensitive.... Regardless of the study and add the appendix note with that. However, you think the
justification for the bolded statement addresses both sides. You could put after the words: fixed wireless
services.... even though not substantiated through the World Health Organization Report.
Abrami: The lead in to all these recommendations is we are following the Precautionary Principle. All of
these would need NH legislative approval. The work group thought this was a reasonable
recommendation to make, understanding that it's a high lift to get it through the legislature and the
Governor to sign. We can add a line or two but Jim, you have the minority report. I know what you are
going to say about this one. You already told us.
Juvet: Just a question for people more knowledgeable about this than me. What exactly is involved with
businesses establishing RF free zones? What do they have to do in order to create that?
Miller: We had some examples where hospitals have rooms available for folks that were bothered by
the electromagnetic radiation. It's not just from antennas. It comes from computers and a variety of
places. I have experienced a customer coming into my business going, "whoa, I can feel everything in
here". That was one of hundreds that come in.
Juvet: I am just asking for clarification. You could use hospitals as an example. What did they have to do
to create that RF free zone?
Wells: From the physics point of view, you build a Faraday Cage. It's a lightweight metal lined box. It
could be similar to a screened porch with metal screening or aluminum foil. Repaper the wall with
aluminum foil and you are good.
Heroux: What you can do is survey the environment for the place where the fields are lowest and post
signs that you don't want active sources that are controlled by individuals and you may do this at a very
low cost. As Ken mentioned, you could also actively try to shield if you have some sources that are very
powerful that you want to get rid of in that location.
Abrami: We have somebody who is RF sensitive who says, my oral surgeon was very happy to move me
to a lower RF room and make sure no one had devices in the room.
Sherman: I think there is an easy fix on the sentence but I just want to caution Jim or others about citing
any traditional or organized medical site like WHO or otherwise... that because they say it isn't so, that it
isn't so. I am old enough to have been and I know others will recognize this but when I was growing up
in Madison, people who had fibromyalgia syndrome or symptoms or irritable bowel symptoms were
actually told by doctors, it's all in your head and come to find out, it's not. Studies were inadequate.
They missed the boat. Eventually, when we got the studies together, we recognized not only that the
symptoms real and reflected a true syndrome, but now they are mainstream diagnoses. The fact that RF
sensitivity is not fully recognized nationally or internationally, doesn't mean a thing to me.
What I would say is "many NH citizens report sensitivity to electromagnetic radiation" and leave it at
that. That's the reality. I suspect this will turn out to be a real well-documented syndrome eventually.
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The science is so much in its infancy right now. I would be very cautious about saying it doesn't exist. I
suspect that it does and we don't have the studies yet to prove it.
Abrami: Our recommendation #11 directs the medical community to start looking at this more
rigorously. I am ok with that change.
Gray: It still does not recognize that there have been scientific experiments conducted by the WHO that
was supposedly double blind and all the great things we are supposed to do when we do one of these
studies that said they cannot, and not to be insensitive to people who are suffering, but they couldn't
attribute it to electromagnetic radiation.
Sherman: I would just respond to that Jim, no physician in their right mind would depend upon a single
study to say that something does or does not exist or that a treatment does or does not work. Would
you agree with that, Gary?
Woods: Absolutely, we have seen as Tom has outlined time and again over the course of hundreds of
years, theories have been thrown out on a regular basis for a variety of reasons. This is just one more in
that long term step. We went through this with tobacco and we are doing the same thing again. In the
chat there are some references for the WHO organization the Jim refers to. The people in the chat seem
to be more familiar with it than I. There are two portions of the WHO organization. Some are associated
with industry and some are not. It has been pointed out, as we have pointed out in this commission, one
of the WHO organization provided the conclusion that radio frequency radiation was indeed a Class II
carcinogen. So to say that a WHO organization says there are no effects, would not be inclusive of all the
WHO organization findings.
Gray: Saying that it is a carcinogen, it doesn't take into consideration what the level of that radiation is.
The FCC's recommendations are 50 times less than what has been demonstrated in various studies. To
say that it's a carcinogen, yes at certain levels it is. When we treat cancer and have multiple doses of
radiation going into a patient, we do it at different aspects so the tissue in between is not affected. To
make that statement without some kind of a radiation limit, doesn't bode well for me.
Sherman: Mr. Chair, can we move the question?
Abrami: Are there any other comments? Ok, let's move the question. The only change is in the
descriptor, "many NH citizens report sensitivity". Tom, are you making the motion?
Sherman: yes.
Abrami: second?
Heroux: yes.
I will call the roll:
Sherman: yes
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Wells: yes
Chamberlin: yes
Miller: abstain
Ricciardi: yes
Juvet: abstain. I appreciate that this is a recommendation and not a mandate. On the other hand, I am
uncomfortable with sentences like "many NH citizens". I don't know what "many" means in the context
of the overall state population so I am on both sides of this one.
Cooley: abstain.
Garod: Brandon had to leave. He is gone.
Roberge: abstain.
Heroux: yes
Woods: yes
Gray: no
Abrami: yes
7-yes, 1-no,4-abstain. Motion passes.
We are going to go to #10.
RECOMMENDATION 10- 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, signal
reliability and 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.
Abrami: This is really a shout out to fiber optic connectivity.
Miller: It is simply adopting a statewide position, not a body but a position that strongly encourages
moving forward with deployment of fiber optic connectivity, internal wired connections and optical
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wireless to serve commercial and public properties statewide. That would just mean hard wired
connections or optical wireless as opposed to Wifi. Open for discussion.
Heroux: I am very in favor of this. I think in the modern world, having fast access to the internet is a
human right nowadays. This should be done in the most technologically advanced way, which is optical
fiber. There is both a technological aspect to this and a human aspect. I think this is very important.
Juvet: just a quick comment. I am actually prepared to vote for this recommendation because the BIA
believes in an "all of the above" approach for technology and communication. My question is in the text,
when you talk about comparisons with RF wireless transmissions, we are only mentioning things that
don't compare well with fiber optics. I am wondering if there are any advantages to wireless and if there
are, shouldn't that also be mentioned?
Abrami: The advantage would be mobility.
Miller: Well, not only mobility but cost. Being able to distribute wireless connections is a lot cheaper
than hardwiring connections.
Wells: The recommendation talks about fiber optic cable and in other recommendations, we talk about
wireless optical transmission. The major advantage RF has is its not tethered. It is possible to do optical
without being tethered. But that's not built into this recommendation but appears elsewhere.
Abrami: Well, yes it is in here.
Wells: oh yes. Now I see it. You are right.
Heroux: Lifi (optical wireless) has advantages of privacy over radio frequency or microwave (Wifi) which
is very leaky from the privacy point of view.
Cooley: I just want to note for the record that I will be voting no on this. We see this as discriminatory
and it doesn't take into account the realities of geography, topography and economic realities that may
limit the ability to provide fiber. By removing one type of technology altogether like wireless, you could
be exacerbating the digital divide and removing options for consumers to connect. Thank you.
Sherman: I just found one tiny point. I feel like the grammar police here but in the sentence with
"biologic effects in the human environment, doesn't make sense to me. The way I would say that is, "RF
wireless transmission lacks fiber optic characteristics including speed, security and signal reliability while
avoiding potential biologic effects on humans and the environment.
Abrami: Yes, you are right. I agree with you.
Gray: I have less of a problem with this recommendation with that change but it still assumes there is an
effect on humans and the environment. We are picking one technology over another that I am not sure I
am comfortable with.
Sherman: I would just add Jim, you are not picking it, but the majority of the commission feels this way.
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Gray: and as Senator Sherman knows, the people who elected me elected me to voice my opinion and
speak strongly in their defense.
Abrami: we respect that Jim.
Woods: This doesn't say anything about the biological being good or bad. It just says avoids it. Because
when you have radiation in the environment, there will be an effect on humans. It's like measuring the
bridges. We are just being cognizant that in fact, this is an exposure.
Juvet: Just a request from the commission. In my reading of this, the promotion of fiber is not meant to
exclude the development of Wifi but Beth makes a good point. Is there some way in the
recommendation that we could add the words, "where practical"? This would recognize that a lot of
areas of this state, we recognize the benefits of that but it's just not a practical option.
Abrami: I have no problem with that.
Juvet: I would insert "where practical" and delete, "to serve all commercial and public properties
statewide".
Wells: I just want to note, is it practical to put electricity I commercial and public properties? You are
talking about exactly the same type of installation for fiber optic.
Abrami: I think the practical consideration David was talking about was cost.
Wells: I am thinking of the Rural Electrification Act. You know it's surely more expensive to supply
service in low density areas, yet broadband is as necessary these days as electricity and running water. I
don't see that adding "where practical" in here is a necessary or a desirable qualifier.
Miller: Even though I will abstain from the vote on this and have written this, I think the idea behind
this... as far as cell service and all of that, everything has its place. This particular recommendation really
starts to get at the infrastructure of the future which regardless of mobile technology and everything
else is where New Hampshire needs to go. However you decide to wordsmith it, I would not like to see
the essence of that recommendation be diluted by it. That's my thought even though I will be
abstaining.
Heroux: I agree with Carol and I would like to point out that in some recommendations we talk about
the majority of the commission. We start the recommendation this way. I wonder if this wording is
appropriate. Why is it in some recommendations and not others when we will probably report how
many people voted for it and how many voted against? I don't see any recommendation in this report
that will be unanimous.
Sherman: I am just reflecting. As Ken was saying, maybe rather than using "where practical", and say
"wherever possible" captures what Carol was saying. It also captures the idea that if you can get electric
in there, you can get fiber optic in there. Even the top of Cannon Mountain has it. If you are on top of
Mount Washington and all you have is cell service and there is no electric and you are living on kerosene
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lamps, then maybe it's not possible. Practical can mean if it is $10 more to put in fiber optic, maybe it's
not practical because you already have cell. I think putting in "possible" captures the spirit of what Carol
was saying and also captures what Ken was saying. I am just putting it out there.
Abrami: I guess the one I have to ask is Dave.
Juvet: I would prefer practical. The senator says possible and what if it's ten thousand dollars more?
Anything is possible if you want to devote enough financial resources to it.
Miller: I wanted to go back and respond to Paul's comment about the majority of the commission. I
think we coined that phrase because of Senator Gray and the fact that we don't have 100% consensus
on a lot of these recommendations. It's nothing more than that.
Abrami: we have three options. Either don't change it; possible; or practical.
Juvet: Mr. Chair maybe I can make it easier on the commission and perhaps we should just be voting on
the original wording because I think it's going to get difficult if we are trying to find out which
wordsmithing we are more comfortable with. I am not sure it will change people's votes, ultimately. I
would like to withdraw my recommendation and we can just vote on the original wording.
Abrami: Ok. Thank you for that. What we are changing is, "while avoiding potential effects".
Wells: I would like to move that.
Woods: second.
We are voting on recommendation #10.
Sherman: yes
Wells: yes
Chamberlin: yes
Miller: abstain
Ricciardi: yes
Juvet: no
Cooley: no
Garod: absent
Roberge: abstain.
Heroux: yes
Woods: yes
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Gray: no
Abrami: yes
7- yes, 3-no, 2- abstain. Motion passes.
Juvet: Mr. Chair, I do need to drop off the zoom meeting now because I am leading one that starts in
about two minutes. Thanks everyone for all their work on this but I do need to leave at this point.
Abrami: Before you go, we are thinking of a meeting on Tuesday, the 27th one o'clock for at least two
hours.
Juvet: I am available on the 27th.
Abrami: Can anyone not make that? I will check with Brandon.
Ok moving backwards now to #8.
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 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 https://oplc.nh.aov/home-
inspectors/index.htm 1
Cooley: Mr. Chair, my notes say that language was supposed to be inserted making this voluntary.
Gray: My objection to this one is that we are putting it on the Office of Professional Licensure and
Certification to go and do something. I don't think we need the State of New Hampshire to do that at all.
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Abrami: Beth, we did add that if you go to the second paragraph..."on a voluntary basis".
Gray : if it's a voluntary program then OPLC shouldn't have to do that, take some advocacy group and
develop the thing and get certified through the advocacy group. I don't think it needs to be a function of
the state.
Sherman: Mr. Chair, I move that we adopt this recommendation as written.
Ricciardi: I second it.
Abrami: Ok. Let's go to the vote:
Sherman: yes
Wells: yes
Chamberlin: yes
Miller: abstain
Ricciardi: yes
Juvet: absent
Cooley: abstain
Garod: absent
Roberge: abstain.
Heroux: yes
Woods: yes
Gray: no
Abrami: yes
7- yes, 1-no, 3- abstain. Motion passes.
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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/business 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 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 shown in Appendix XX.
Abrami: #7 was rewritten after objections by Beth on the California firefighters. That was in the write up.
You sent us all the California Senate amendments. They say that "due to the unique duties and
infrastructure requirements for swift and effective deployment of firefighters, those provisions do not
apply to co- location or siting application for telecommunication facility where the project is proposed
for placement of fire department facilities." This is my read on this, they are carving out the fire stations
and the reason that they give is totally different from all the background history that says health effects.
They said it had to do with them interfering with their duties, not that it's health effects. They basically
said having towers on top of the building is going to interfere with the swift and effective deployment of
firefighters. To me, that's a sleight of hand what they are saying here. They are trying to skirt the federal
law with this. To me, it's a wink and a nod. Is that the way you read this, Beth?
Cooley: You can just read the statute itself. You can imply intention or read into it all you want but the
statute itself says it's got the FCC language in there that you know that states and localities cannot
consider RF emissions or the alleged health effect as a reason to deny a facility. You have to read the
statute as is. You can rely on innuendo or fake news coverage all you want but that's really all I have to
say.
Abrami: What I don't understand is how does the cell tower on the roof impact the duties for swift and
effective deployment of firefighters? I don't understand the logic.
Cooley: you have to read the statute in conjunction with the fact they are honoring federal law,
Abrami: That's the only way they can honor federal law. They are not going to say what the real issue
was. The real reason was fire fighters fought hard because of health effects. We don't have the time
digging into the logic of California legislature on this other than to get around the federal law and
appease the firefighters. I would ask that question.
Ricciardi: If you want, I can send you documents on how they lobbied on health effects.
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Abrami: we know there are documents on health effects but this is the only way they could skirt federal
law. If the FCC really wanted to take this on, they could. How does a cell tower on your roof impact the
swift deployment of firefighters?
Cooley: Mr. Chair, I don't think it changes the essence of the recommendation. I will be voting no and
you guys all know that. Your setback requirements are unlawful and essentially a prohibition of service.
Even if you conceded the California topic, which I am not, you read the statute as it's written. You still
have the underlying recommendation which is incredibly problematic.
Gray: The bottom line of this is that there is a federal preemption. Whether or not there is a California
law to do something, it doesn't matter. There is a federal prohibition against us doing that. That's the
bottom line and this recommendation should not be in the report.
Abrami: California proves that you can do a carve-around. That's what I am seeing here. They have
carved out a certain set of people. That's the way I view it.
Sherman: I just want to move to accept the recommendation as written.
Chamberlin: I will second it.
Sherman: yes
Wells: yes
Chamberlin: yes
Miller: abstain
Ricciardi: yes
Juvet: absent
Cooley: no
Garod: absent
Roberge: abstain
Heroux: yes
Woods: yes
Gray: no
Abrami: yes
7-yes, 2-no, 2- abstain. Motion passes.
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Abrami: Ok. We took number six and split it into 6A and 6B.
RECOMMENDATION 6A- 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 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 to be
empowered is to be 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 in 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.
Chamberlin: We split this into two separate recommendations. The change made to 6A was to add that
municipalities can take the antenna off line if it exceeds thresholds. It's one thing to take measurements
but what do you do about it if it's an issue? It also mentions that these measurements will be taken by
an independent contractor with the cost to be borne by the site installers. This only addresses
requirements that measurements be performed on the facility. We might want to discuss that first
because there is a part that Carol put in also talking about the control of the facility by the municipality.
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This part was added by Carol.
Federal Law and NH law grant to municipalities the power in 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.
Miller: This language comes from some presentations and attorney recommendations for towns. It
simply says that 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 their
municipalities. The municipalities should be proactive in this area. Through the exercise of zoning power
establish where and how and a process for compliance with existing guidelines for signal strength in the
surrounding coverage area. They can establish a hierarchy of siting values and compliance
acknowledgements so that the siting most favored by the municipalities is easiest siting for the wireless
applicant to obtain. Conversely, deciding which is least desirable should be the most difficult siting for
the applicant to obtain. The zoning ordinance should lay out those compliance requirements as part of
that zoning approval. It's just legalese legal speak for what the municipalities can indeed control within
their realm. Is there any discussion about that? It comes from Donahue, Tucker and Ciandella which
does a lot of work for municipalities across the state with regard to cable franchises and wireless siting
and all of the above.
Cooley: That new language is concerning to me because it's a clear outline of how to put up obstacles
for deployment. So a municipality is saying we want this site here over this one but the municipality has
no idea where coverage is needed or where there are coverage holes. That language is quite concerning
to me.
Gray: the problem I have with this one is you start off by talking about signal strength and being able to
shut down a site. If the facility is operating within the FCC goals, I don't think you have the ability to do
anything after that site has been established. And then we moved to this paragraph which talks about
siting the thing. That's very concerning. I can't think of powers here in the city of Rochester that have
gone through the planning and zoning process that haven't gotten a favorable decision because of the
strength of the law giving the FCC certain responsibilities.
Abrami: It assumes that the limits are above the FCC guidelines.
Heroux: Cultural acceptability of these installations and social acceptability to the people who use them
is very important and critical in my opinion.
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Abrami: I don't see anything wrong with us saying the municipality can measure whether sites are within
federal guidelines. If they are not, we are saying action can be taken by the municipality. That's all it is
saying.
Ricciardi: I just want to remind everyone that we are here to make recommendations based on what we
have learned over the course of all of these months and that is what we are doing. We wrote long
questions to the FCC, FDA, EPA. We did not get answers. They did not want to present. So we are using
from the presenters, from the science and from what we read, to make recommendations to help
residents in the state of New Hampshire. That's our job of this commission. This is just a
recommendation based on our findings. It's not a law.
Abrami: my concern is that right now, we put three or four cell towers near each other, how do we
know, who is the policeman on this? Maybe Beth knows this answer. Is the industry out there taking
measurements making sure they are within federal limits?
Cooley: I don't have a clear picture on that so I don't want to say publicly. I have heard different things
from different members of mine but I can look into that. I can follow up.
Gray: I wanted to comment on Denise's comment about the questions that were sent to the FCC. Many
of the issues she raised are already available on the FCC and FDA website. For a commission member to
send a letter off that did not even come from the whole commission in an approved list of questions to
the FCC doesn't meet the common sense test in this instance. That information is available. Maybe they
did not respond to Denise's letter...ok? Is the information that Denise asked for available on their
website? Yes. I went in and found it. We are not citing a lot of that information anywhere in our report.
Ricciardi: "We" gave specific questions that are not answered on the website. They did not answer them
and those are the answers to the question we were truly seeking to find.
Abrami: I did review them before she sent them out and we shared them with everyone. We can go
round and round on this one. Let's bring it to a vote. I need a motion.
Heroux: yes.
Wells: second.
Abrami: Ok. We are voting on 6A.
Sherman: yes but I have five minutes and then I have to leave at noon.
Wells: yes
Chamberlin: yes
Miller: abstain
Ricciardi: yes
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Juvet: absent
Cooley: no for the hierarchy siting language and I also need to leave at noon.
Garod: absent
Roberge: abstain.
Heroux: yes
Woods: yes
Gray: no
Abrami: yes
7- yes, 2-no, 2- abstain. Motion passes.
Abrami: let's try to do 6B. Were there any changes to this one?
Chamberlin: the only change that was made addresses taking new measurements that takes into
account the impulsive nature of radiation and the summative effects. What was asked for in the last
meeting of this group was that we take some of the references and put them in the appendix and that's
all that we really did on this one. I also mentioned that the development of those funding protocols
should be funded by the appropriate federal agency like NIH, FCC etc. We are in the process of creating
more references that support the statement that it's impulsive radiation more than continuous radiation
that has the deleterious effect on humans. That's the change and is in compliance with what was asked
in our previous meeting.
Gray: again the FCC I believe in the spring of 2019 addresses a lot of these topics in there. They reviewed
the science and found these effects are not true. You don't have any of that information in this report
that is anti to the opinion of the majority of the group.
Abrami: if no more discussion, I would like to get a motion on this one and vote before the two leave.
Chamberlin: So moved.
Heroux: Second.
Sherman: yes
Wells: yes
Chamberlin: yes
Miller: abstain
Ricciardi: yes
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Juvet: absent
Cooley: no because of the alleged assumption of negative health effects.
Garod: absent
Roberge: abstain.
Heroux: yes
Woods: yes
Gray: no
Abrami: yes
7-yes, 2-no, 2- abstain. Motion passes.
Abrami: I think that's it. I am going to have to pull this all together. I will rely on Joel to help me pull
pieces from one place to another and I will get it to you as soon as I can. I asked the work group to pull
together the appendices that go with these recommendations. The work group will meet once before
the final meeting and possibly reorder these in some logical way without losing the numbering.
Jim: as soon as I know the order, I will tell you and give you a map.
Gray: It doesn't appear we will have time if you aren't meeting until the 27th. We only have a few days to
do the minority report.
Abrami: I was assuming you would be working on the minority report in parallel based on the
recommendations.
Gray: we have been trying to do that but every time we get changes getting it back through the people
on the minority report is becoming a problem. Again, we will do our best.
Abrami: ok. The date is November 1st. If we need a little wiggle room we might be able to get it. Just
because we are meeting on that date does not mean we won't have the report out to everybody before
that date. Ok Jim? A lot of this is going to fall on me and Joel to get it pulled together. I will try to get it
to you a week ahead of that date so you can see what it looks like before then.
Gray: and I will do my best to get the thing to you as soon as I can.
Abrami: I know Jim. We are all under pressure having to campaign at the same time.
Workgroup next meeting: Monday, the 12th 10am-12 pm. Kent, will you set that up and the other one
as well?
Chamberlin: yes.
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Abrami: ok very good. Thank you.
IV. Next meeting via Zoom: October 27th 1-3pm
Meeting Adjourned at 12:03 pm
Chat from HB522 Commission Octob^n o . 0, 0 Meeting
From EH Trust to Everyone: 10:15 AM
800,000. We'll need an estimated 800,000 new cell sites by 2025.
https://docs.fcc.gov/public/attachments/DOC-354323Al.pdf
REMARKS OF FCC CHAIRMAN AJIT PAI
WHITE HOUSE 5G SUMMIT
WASHINGTON, DC
SEPTEMBER 28, 2018
Research showing impacts to trees sent to fee here Testimony of Albert M. Manville, II, Ph.D., C.W. B.,
and Principal, Wildlife and Habitat Conservation Solutions, LLC, on Behalf of Friends of Amazon Creek,
Before the City of Eugene City Planning Department in Opposition to AT&T/Crossfire's Application for a
"Stealth" Cellular Communications Tower in the Upper Amazon Creek Corridor / Testimony-of-Albert-
M.-Manville-for-Amazon-Creek.pdf Testimony of Albert M. Manville, II, Ph.D., C.W. B., and Principal,
Wildlife and Habitat Conservation Solutions, LLC, on Behalf of Friends of Amazon Creek, Before the City
of Eugene City Planning Department in Opposition to AT&T/Crossfire's Application for a "Stealth"
Cellular Communications Tower in the Upper Amazon Creek Corridor / Testimony-of-Albert-M.-
Manville-for-Amazon-Creek.pdf
From EH Trust to Everyone: 10:20 AM
https://ecfsapi.fcc.gov/file/10718080685516/Testimony-of-Albert-M.-Manville-for-Amazon-Creek.pdf
Trees https://ecfsapi.fcc.gov/file/1001669617135/Trees-in-Bamberg-and-Hallstadt-Documentation-
2006-2016.pdf
more on trees damaged https://ecfsapi.fcc.gov/file/1001669617135/RF-
Radiation%20iniures%20trees%202016.pdf
Published study A review of the ecological effects of radiofrequency electromagnetic fields / A review of
the ecological effects of radiofrequency electromagnetic fields (RF-EMF)
https://ecfsapi.fcc.gov/file/7520939746.pdf
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Published study Impacts of radio-frequency electromagnetic field (RF-EMF) from cell phone towers and
wireless devices on biosystem
and ecosystem - a review
https://ecfsapi.fcc.gov/file/7520943486.pdf
Impacts to insects from higher frequencies that are to be used in 5G. Here is a paper
https://ecfsapi.fcc.gov/file/121003066389Q/Exposure%20of%20lnsects%20to%20RadioFrequencv%20EI
ectromagnetic%20Fields%20from%202%20to%20120GHz%205g%20.pdf
From Cece Doucette to Everyone: 10:21 AM
Rec 13: Line 5, need to insert the word "were" between the words "limits" and "set".
From EH Trust to Everyone: 10:26 AM
The FDA info does not include ANY review of impacts birds or bees
in fact the FDA only looked at tumors and their "literature review" was only on tumors, not bees, not
trees, not birds
See the details on the FDA here https://ehtrust.org/expert-phvsicians-surgeons-and-scientists-call-for-
fda-to-retract-biased-anonymous-report-of-cancer-impacts-of-cell-phones/
These documents by the FDA have nothing to do with trees or birds or wildlife.
No, the EPA was defunded in 1996 AND never looked at environment
The letter I sent you from the EPA shows thats pollinators and trees and plants have NEVER been looked
at
From Ken Wells to Everyone: 10:28 AM
"Starlink " wiki cites reports of FCC approvals for up to 42,000 Starlink satellite antennas:
https://en.wikipedia.org/wiki/Starlink
From EH Trust to Everyone: 10:29 AM
Statement from Dr. Albert Manville on the FDA Report on Cell Phone Radiation
https://ehtrust.org/press-statement-from-dr-albert-manville-on-the-fda-report-on-cell-phone-radiation-
IL
From Cece Doucette to Everyone: 10:30 AM
The FCC is being sued for not addressing the scientific literature submitted to them showing biological
affects: The Environmental Health Trust and a coalition of other commentators in 2020 also filed a court
appeal challenging the FCC's order terminating its evaluation of the adequacy of FCC RF radiation limits.
https://ehtrust.org/action-alert-lawsuit-against-the-fcc/
Robert F. Kennedy, Jr.'s Children's Health Defense is also suing the FCC for negligence:
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https://childrenshealthdefense.org/news/robert-f-kennedv-ir-s-childrens-health-defense-submitted-
historic-case. Additionally, Dr. Jeffrey Shuren of the FDA has serious conflicts of interest, his wife is a
partner in a law firm that represents the wireless industry: https://www.5gcrisis.com/shuren-petition
From EH Trust to Everyone: 10:40 AM
The EPA letter that is on your record shows there is no standard for the environment. See it here the
EPA letter https://ehtrust.org/epa-birds-bees-trees-5g-wireless-effects/
Environmental Health Trust is suing the FCC . Read the brief here https://ehtrust.org/eht-takes-the-fcc-
to-court/
Please be sure to read the NRDC brief that showcases the lack of review regarding environmental
impacts here https://ehtrust.org/wp-content/uploads/20-1025-NRDC-amicus-brief.pdf
This Amicus brief also has the letter from the EPA that says What US agency has reviewed the research
on damage to trees from cell phone radiation? If so, when was it issued and send a link to the review.
Note this study showing damage from long term exposure to cell antennas. EPA Response: The EPA
does not have a funded mandate for radiofrequency matters, and we are not aware of any EPA reviews
that have been conducted on this topic. We do not know if any other US agencies have reviewed it.
Published research can be found here https://ehtrust.org/environmental-effects-of-wireless-radiation-
and-electromagetic-fields/
From Cece Doucette to Everyone: 10:41 AM
Senator Gray and others, you may wish to review the Mobile Communications and Health study
commissioned in 2000 by T-Mobil, the German parent company of T-Mobile. It concluded there are
many non-thermal biological effects well below public radiation exposure limit levels. They
recommended specific precautionary measures should have been taken, but they were not and the
industry continued to market hazardous products:
https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxlbmRlcnN0YW5kaW5n
ZWlmc3xneDo3MTE4NThkYmY3NmUzMzcO
From EH Trust to Everyone: 10:43 AM
Theodora Scarato of EHT asked "What US agency has reviewed the research on impacts to birds and
bees? If so, when and send a link to the review. I will note the latest research showing possible impacts
to bees from higher frequencies to be used in 5G." July 8, 2020, Lee Ann B. Veal Director, Radiation
Protection Division Office of Radiation and Indoor Air, Environmental Protection Agency of the United
States of America responded "EPA Response: The EPA does not have a funded mandate for
radiofrequency matters, and we are not aware of any EPA reviews that have been conducted on this
topic. We do not know if any other US agencies have reviewed it." Link to letter here
https://ehtrust.org/epa-birds-bees-trees-5g-wireless-effects/
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Statement by Wildlife Biologist Alfonso Balmori, BSc on the FDA Review of Cell Phone Radiation and
Cancer
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 am providing
examples of my published research below as examples of this scientific evidence. Read the letter with
studies at https://ehtrust.org/26684-2/
From EH Trust to Everyone: 10:47 AM
The FCC has NOT studied the issue. In fact they are using the lack of response by agencies to "prove'
there are not effects.
From Jen White to Everyone: 10:47 AM
I second the comment above!!
From Cece Doucette to Everyone: 10:48 AM
Senator Gray and others, please read Harvard Law School's Center for Ethics report, "Captured Agency:
How the FCC is Dominated by the Industries it Presumably Regulates." It likens FCC and industry
approach to the tobacco industry tactics: https://ethics.harvard.edu/news/new-e-books-edmond-i-
safra-research-lab
From EH Trust to Everyone: 10:53 AM
Research shows that the levels of RF will be increased with 5G infrastructure 4G densification . As an
example of how rapidly RF is increasing from wireless antennas, a 2014 published study looked at RF in
three European cities and found in just one year (between April 2011 and March 2012) that the total
RF-EMF exposure levels in all outdoor areas in combination increased by 57.1% in Basel by 20.1% in
Ghent and by 38.2% in Brussels (Urbinello 2014). "Exposure increase was most consistently observed in
outdoor areas due to emissions from mobile phone base stations."
https://www.sciencedirect.com/science/article/pii/S0013935114002254
2018 study published in Annals of Telecommunications found increased RF-EMF exposure from small
cell LTE networks in two urban cities in France and the Netherlands. Researchers measured the RF-EMF
from LTE (Long-Term Evolution) MC (macro cells meaning large cell towers) and SC networks (low-
powered small cell base stations) and found that the small cell networks increased the radio emissions
from base stations (called downlink) by a factor of 7-46 while decreasing the radio emissions from user
equipment exposure (called ) by a factor of 5-17. So while the devices themselves could emit less
radiation, the cell antennas will increase the levels from cell antennas (Mazloum et al., 2019). This study
shows the increased exposures would be involuntary. We can turn our phones off, but we cannot turn
off the antennas in the neighborhood. https://link.springer.com/article/10.1007%2Fsl2243-018-068Q-l
From EH Trust to Everyone: 10:54 AM
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An Australian study published in the Journal of Exposure Science & Environmental Epidemiology also
found that children in kindergartens with nearby antenna installations had nearly three-and-a-half times
higher RF exposures than children with installations further away by more than 300 meters (Bhatt et al.,
2016). https://www.ncbi.nlm.nih.gov/pubmed/27759027
From Cece Doucette to Everyone: 10:57 AM
Rec. 12: Can we include other essential services? These have been well defined for COVID-19, and the
public should be able to access those services too.
Senator Gray and others, the WHO determined RF is a Group 2B Possible Human Carcinogen in 2011.
Now that the animal studies have been completed and show cancerous tumors and DNA damage, the
WHO has re-opened its investigation in 2020: https://www.who.int/peh-
emf/research/rf ehc page/en/indexl.html
From EH Trust to Everyone: 10:58 AM
Research shows low level RF is tied to harm such as promoting tumors. And more
From Cece Doucette to Everyone: 10:58 AM
Please also note there are two WHO groups for EMFs, one is populated with those with industry ties, the
other has independent scientists: https://ehtrust.org/scientists-call-for-transparencv-at-the-world-
health-organization-emf-project/
From EH Trust to Everyone: 11:00 AM
The science shows it IS substantiated
https://www.researchgate.net/publication/305689940 EUROPAEM EMF Guideline 2016 for the pre
vention diagnosis and treatment of EMF-related health problems and illnesses
https://www.sciencedirect.com/science/article/abs/pii/S0013935120303388Pvia%3Dihub
Electromagnetic hypersensitivity (EHS, microwave syndrome) - Review of mechanisms
Peterborough, Canada
The City has an information sheet to help organizations accommodate individuals who have
electromagnetic hypersensitivity. They recommend - among other things:
Temporarily disable City owned WAP devices.
Turn off or minimize fluorescent and LED.
Notify attendees to set mobile phones to airplane mode. https://ehtrust.org/wp-content/uploads/EHS-
Tip-Sheet-Peterborough-5-8-2018.pdf
From Brandon.H.Garod to Everyone: 11:00 AM
I apologize but I have to leave for another meeting starting at 11:00
From Deb Hodgdon to Everyone: 11:00 AM
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my oral surgeon was very happy to move me to a low rf room and make sure no one had devices in the
room.
From EH Trust to Everyone: 11:03 AM
International
France: 13 Plaintiffs Win: The Tribunal de Grand Instance of Bordeaux ordered in favor of 13 of the 206
plaintiffs who had initiated a lawsuit against the installation of the electric meter created by Enedis.
https://www.femmeactuelle.fr/sante/news-sante/compteur-linky-la-iustice-donne-raison-a-13-
plaignants-electrosensibles-2077743
The word "unsubstantiated" should not be used.
Plus The WhO site being referenced is industry loyal and that is well documented in published research
https://www.spandidos-publications.com/10.3892/iio.2017.4046
Actually it IS recognized and has been in several ada cases
From Jen White to Everyone: 11:03 AM
Both myself and 10 year old son are RF sensitive. It's very real and not to be discredited. Thank you. -
Thank you Tom for saying that, much appreciated!
From EH Trust to Everyone: 11:04 AM
Austrian Medical Association
The Austrian Medical Association has developed a guideline for differential diagnosis and treatment of
health problems associated with outdoor and indoor electrosmog.
Guidelines of the Austrian Medical Association for the diagnosis and treatment of EMF related health
problems and illnesses (EMF syndrome) https://ehtrust.org/wp-content/uploads/The-Austrian-Medical-
Association-Guidelines-for-Diagnosis-and-Treatment-of-EMF-related-Health-Problems.pdf
Exposure to Nonionizing Radiation ICD 10 Medical Codes for Exposure to nonionizing radiation - ICD-10-
CM W90
"The ICD-10 code is the standard diagnostic tool for epidemiology, health management & clinical
purposes. It is used for medical code lookups by physicians, nurses, researchers, health information
managers, medical billing coders, health information technology workers, insurers & patient
organizations to classify diseases and other health problems recorded on many types of health records,
including death certificates. ICD 10 codes are also used by medical billers & payers for reimbursement
purposes."
Medicare Accepted ICD-10 codes under W90 for Exposure to other nonionizing radiation. These codes
can be used for all HIPAA-covered transactions.
From Cece Doucette to Everyone: 11:04 AM
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The public is welcome to join health care practitioners for the continuing medical education-accredited
EMF Medical Conference in January where you will learn the science. We do have the studies already to
prove wireless is harmful: https://emfconference2021.com/
From EH Trust to Everyone: 11:05 AM
2014:US Resident Provided Accomodations in Housing Case Regarding "Smart" Water Meters:
Mechanical Meter For Resident PLUS Neighbors
Not only was a resident provided a mechanical meter after filing in court and coming to an agreement
with the water authority; but in addition the neighbors of three adjacent properties also were provided
free opt outs for the switch to mechanical meters.
That is correct- this switch AWAY from water meters was made with NO charges- NO FEES. The legal
filing says that the Fair Housing Act prohibits discrimination based on disability.
Click here to see redacted HUD water meter agreement. https://ehtrust.org/wp-content/uploads/HUD-
meter-settlement-Redacted.pdf
2014; Los Angeles Unified School District Accommodated a Teacher Who Fell III After Wireless
Installation.
On September 18, 2014, LAUSD, the second largest public school district in the US, officially
accommodated teacher Ms. Anura Lawson by approving her request to have the Wi-Fi turned off in her
classroom during the 2014-2015 school year and alternatively approving a reassignment to a different
school site where Wi-Fi has yet to be installed.
Watch the video of her testimony to the LAUSD School District Here. Read her letter of accommodation
here. https://ehtrust.org/wp-content/uploads/LA-Teacher-Accomodation.pdf
From EH Trust to Everyone: 11:06 AM
We, physicians, acting in accordance with the Hippocratic Oath, we, scientists, acting in the name of
scientific truth, we all, medical doctors and researchers working in different countries worldwide,
hereby state in full independence of judgment,
that a high and growing number of persons are suffering from EHS and MCS worldwide; that EHS and
MCS affect women, men and children;
that on the basis of the presently available peer-reviewed scientific evidence of adverse health effects of
electromagnetic fields (EMFs) and various chemicals, and on the basis of clinical and biological
investigations of patients, EHS is associated with exposure to EMFs and MCS with chemical exposure..."
Excerpt from the 2015 Brussels International Scientific Declaration on Electromagnetic Hypersensitivity
and Multiple Chemical Sensitivity. Download http://www.ehs-
mcs.org/fichiers/1441982143 Statement EN DEFINITIF.pdf
Magda Havas PhD at the National Institute of Environmental Health Sciences
"Electrosmog, the missing link as it relates to cancer, reproductive problems and
electrohypersensitivity." https://www.voutube.com/watch?v=fqMCiEs9oxE&feature=emb logo
From EH Trust to Everyone: 11:09 AM
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The Who EMF project was started by industry funddscientist.
See EHT and others letter to The WHO EMF Project. They refuse to answer our letter and we have asked
numerous times about that factsheet on The Who site . https://ehtrust.org/scientists-call-for-
transparencv-at-the-world-health-organization-emf-proiect/
There is no 50 times safety margin. This is a false statement because research on FCC record shows it.
Read it here https://ecfsapi.fcc.gov/file/7520958286.pdf
From Cece Doucette to Everyone: 11:09 AM
The FCC limits are only based on heat exposure. The peer-reviewed non-industry funded independent
science shows there is significant harm at the non-thermal level. Please see the Bioinitiative Color Charts
for a summary of the science and findings of biological effects: https://bioinitiative.org/rf-color-charts/
From EH Trust to Everyone: 11:11AM
The 50 times margin was based on a study of rodents with a thermometer in their rectum and it has
been well disproved by science. Plus it is only about heating effects so it has nothing to do with cancer.
https://ecfsapi.fcc.gov/file/7520958286.pdf
In fact for carcinogens the safety limit can be up to 10,000 times the level that cancer was found
So even if there was a 50 times safety margin- it is not adequate protection.
From Cece Doucette to Everyone: 11:11 AM
Rec. 10: Can we expand this to bring hard-wired to residential premises too?
From Jen White to Everyone: 11:14 AM
https://www.emfanalvsis.com/fiber-optics-increasing-electrical-sensitivitv/ - Will low EMI fiber optics be
explored or discussed at some point?
From Cece Doucette to Everyone: 11:15 AM
Reliability is a factor too, in emergencies from storms, fires, etc., cell antennas often go down which
leaves the public vulnerable to not being able to call for emergency services.
From Jen White to Everyone: 11:17 AM
We have a wired internet system that is not fiber optic. This is preferred and residents should have a
choice, especially RF sensitive people such as myself.
From EH Trust to Everyone: 11:20 AM
There are no protections at the federal level to stop companies from using fiber for wireless purposes.
Remember that if fiber optic is laid on a road, then a company can use it for their small cell. There
should be federal protections in place to stop this.
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Wireless companies like fiber because then they can attach wireless antennas.
It should be wired to and through the premises. Please see this study on how to hardwire in buildings
https://www.sciencedirect.com/science/article/pii/S0360132319305347
From EH Trust to Everyone: 11:31AM
Please read about how wired technology uses more energy consumption compared to wired.
https://ehtrust.org/science/reports-on-power-consumption-and-increasing-energy-use-of-wireless-
systems-and-digital-ecosystem/
The California Association of Realtors' Property Sellers Questionnaire specifically "cell towers" listed on
the disclosure form for sellers of real estate. The seller must note "neighborhood noise, nuisance or
other problems from.. " and includes cell towers and high voltage transmission lines on the long list
problems. Click here to see the California Association of Realtors' Property Sellers Questionnaire (p. 3-4
under K. Neighborhood) https://ehtrust.org/wp-content/uploads/Real-Estate-Seller-Propertv-
Questionaire-reduced-12-17-l.pdf
From Paul Bloede to Everyone: 11:32 AM
I show a vote was taken on both 8 and on 8A, at the 9/22 meeting. Both were approved, with slightly
different tallies. 8 was voted in with 7 yes, 1 no, and 5 abstain.
From EH Trust to Everyone: 11:33 AM
2014 Survey by the National Institute for Science, Law and Public Policy (NISLAPP) in Washington, D.C.,
"Neighborhood Cell Towers & Antennas—Do They Impact a Property's Desirability?"
Home buyers and renters are less interested in properties located near cell towers and antennas, as well
as in properties where a cell tower or group of antennas are placed on top of or attached to a building.
94% said a nearby cell tower or group of antennas would negatively impact interest in a property or the
price they would be willing to pay for it.
Read the Press Release: Survey by the National Institute for Science, Law & Public Policy
https://electromagnetichealth.org/electromagnetic-health-blog/survev-propertv-desirabilitv/
Best Best and Krieger Letter to Ms. Marlene H. Dortch, Secretary Federal Communications Commission
September 19, 2018 "RE" Smart Communities and Special Districts Coalition - Ex Parte Submission:
Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment, WT
Docket No. 17-79; Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure
Investment, WC Docket No. 17-84" "A good example lies in the Commission's discussion of
undergrounding.62 The Commission at once appears to recognize that communities spend millions of
dollars on undergrounding projects, and that allowing poles to go up in areas where poles have been
take down has significant impacts on aesthetics (not to mention property values)."
From EH Trust to Everyone: 11:34 AM
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https://www.montgomervcountvmd.gov/cable/Resources/Files/Towers/cellTowerlnfo/Ex%20Parte-
Smart%20Communities%20and%20Special%20Districst%2009-19-18-c2%20(l).pdf
"Appraiser: Cell Tower Will Affect Property Values" New Jersey Patch on T Mobile Cell Tower
"Properties that are approximately close to the tower will suffer substantial degradation to their value
based on the nature of the unusual feature in the residential neighborhood." https://patch.com/new-
iersev/bridgewater/appraiser-t-mobile-cell-tower-will-affect-property-values
From Deb Hodgdon to Everyone: 11:34 AM
I know a home inspector who is very interested in being trained and licensed to do that
From EH Trust to Everyone: 11:37 AM
ConsumerWatch: 5G Cellphone Towers Signal Renewed Concerns Over Impacts on Health
In this news report below- California investigative reporter Julie Watts interviews firefighters and
California officials on the SB649 exemption for firefighters. It is very clear this is about health effects as
the firefighters state it
From Deb Hodgdon to Everyone: 11:37 AM
sounds like it interferes because you can't think quickly and efficiently
From EH Trust to Everyone: 11:39 AM
Read it here https://sanfrancisco.cbslocal.com/2018/01/25/consumerwatch-5g-cellphone-towers-
signal-renewed-concerns-over-impacts-on-health/
you can simply say that the firefighters lobbied because of health effects
Which is documented in numerous documents
The CBS story say So, following lobbying by firefighters, assemblyman Quirk and his co-author exempted
fire stations from their bill, making them one place cell companies couldn't put a tower."
read it here https://sanfrancisco.cbslocal.com/2Q18/01/25/consumerwatch-5g-cellphone-towers-signal-
renewed-concerns-over-impacts-on-health/
you could quote the CNS report https://sanfrancisco.cbslocal.com/2Q18/01/25/consumerwatch-5g-
cellphone-towers-signal-renewed-concerns-over-impacts-on-health/
From Cece Doucette to Everyone: 11:39 AM
Rec 7: There is a private property owner in Pittsfield, MA who just opted for a cell tower on the edge of
the property, which abuts a neighborhood of eights streets. Only three of the proposed 46 antennas
have been turned on, and children and adults are already experiencing headaches, insomnia, cognitive
impairment, and one little girl described it as, "Mommy, I feel all buzzy inside." The public needs to be
protected from all cell antennas regardless of whose property they are on. The epidemiological studies
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show similar biological effects within 1,500 or so feet from a cell antenna:
https://sites.google.com/site/understandingemfs/cell-towers
From Deb Hodgdon to Everyone: 11:40 AM
yes pat.
From EH Trust to Everyone: 11:42 AM
""This is the first piece of legislation that anyone is aware of where somebody got an exemption
because they were concerned about health. Did they tell you at all about the study?" we asked the
assemblyman.
Quirk's response: "All I know is that when the firefighters ask, I do what they ask me to do."
https://sanfrancisco.cbslocal.com/2Q18/01/25/consumerwatch-5g-cellphone-towers-signal-renewed-
concerns-over-impacts-on-health/
This is a study- although a few years old- details why restricting cell towers from schools is a human
rights issue https://ecfsapi.fcc.gov/file/1070795887708/Roda%26Perrv EnvSci%26Policv .pdf
From EH Trust to Everyone: 11:54 AM
The FCC is not actively taking measurements.
In fact a Wall Street Journal shows many sites exceed FCC limits
https://www.wsi.com/articles/cellphone-boom-spurs-antenna-safety-worries-1412293055 One in 10
sites violates the rules, according to six engineers who examined more than 5,000 sites during safety
audits for carriers and local municipalities, underscoring a safety lapse in the network that makes
cellphones hum, at a time when the health effects of antennas are being debated world-wide.
No, the FDAdoes not say anything about bees and trees
From Cece Doucette to Everyone: 11:54 AM
6A: Minor typo on the bold line, "...be empowered is to be immediately..." remove the words "is" and
"be".
From EH Trust to Everyone: 11:59 AM
If you go to the website by the FDA
you will see that in fact they have not looked at all the data
The FDa did not look at impacts to sperm or impacts to brain damage. That is all on the record
https://ehtrust.org/scientistsletter-calling-for-a-retraction-to-the-fda-report-on-cell-phone-radiation-
and-cancer/
From Jen White to Everyone: 11:59 AM
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If 5G moves forward in NH, Will there be any RF "safe zones" in residential areas where RF sensitive
residents live? If we have a 5G repeater outside of our home that is literally a sick sentence for my 10
year old son!
From EH Trust to Everyone: 12:03 PM
For the record https://www.sciencedirect.com/science/article/pii/S2542519618302213Pvia%3Dihub
Ronald N. Kostoff, Paul Heroux, Michael Aschner, Aristides Tsatsakis, Adverse health effects of 5G
mobile networking technology under real-life conditions, Toxicology Letters, Volume 323, 2020, Pages
35-40, https://www.sciencedirect.com/science/article/abs/pii/S037842742030028X
Thermal and non-thermal health effects of low intensity non-ionizing radiation: An international
perspective, Environmental Pollution, Volume 242, Part A, 2018, Pages 643-658, ISSN 0269-7491,
https://doi.Org/10.1016/i.envpol.2018.07.019 . https://www.ncbi.nlm.nih.gov/pubmed/30025338
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NH COMMISSION TO STUDY THE ENVIRONMENTAL AND HEALTH EFFECTS
OF EVOLVING 5G TECHNOLOGY
Meeting held:
10/27/20
1:00 -1:47pm EST
Via Zoom ( https://urih.zoom.us/i/8760768986)
Via telephone-US (1 312 626 6799 (US Toll) ID: 876 076 8986)
In attendance:(13)
Rep. Patrick Abrami-speaker of the house appointee
Rep. Ken Wells- speaker of the house appointee
Kent Chamberlin, Phd.-UNH-appointed by the chancellor
Denise Ricciardi-public-appointed by the governor
Michele Roberge-DHHS- Commissioner of DHHS appointee
Paul Heroux,Phd.- Professor of Toxicology, McGill University- speaker of the house appointee
Rep. Gary Woods-speaker of the house appointee
Senator Jim Gray-president of the senate appointee
Senator Tom Sherman-president of the senate appointee
Brandon Garod,Esq.-AG designee, Asst. AG Consumer Protection
Bethanne Cooley-CTIA, trade association for wireless industry and manufacturers
Carol Miller-NH Business & Economic Affairs Dept.
David Juvet-Business and Industry Association
Not present: (0)
Meeting called to order by Rep Abrami at 1:03 am
Abrami: Due to the Covid 19 virus and the Executive order signed by the Governor this public meeting is
allowed to be conducted via Zoom. It is open to the public for viewing and was duly posted as a zoom
meeting. With that said, if you are not a member of the Commission, can you please turn your cameras
off and mute yourselves? That would be much appreciated. In addition the meeting is being recorded as
an aid to doing the minutes. All chat room discussions will be included in the minutes.
I. Approval of minutes from 10-8-20
Let's start with the minutes from the October 8th meeting. I have not received any changes to the
minutes that I sent out about a week ago. Are there any changes that anyone wants to make? Seeing
none, I will say ...without objection, we approve the minutes from that meeting.
Page 1 of 11
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II: Agreed to Recommendation changes
Sherman: Pat, I think you need to do the "right to know" script and a call of the roll, don't you? Maybe
it's different for the House than the Senate.
Abrami: I am doing it with what I just read. The last meeting we voted on many of the
recommendations in the report and I want to go through to show you. Kent, can you pull up Page 9? I
am not going to be able to see you all as Kent will be sharing his screen. So members just jump in if you
have something to say.
Fourth line from the bottom, "principle" was spelled incorrectly and was corrected.
Recommendation #1 is the old 1. We agreed after the bold where you see Telecommunication Act, to
delete "TTA".
Recommendation #2 is the old 3. We changed "attachment" to "appendix". "There is" in the last line
was taken out as it made no sense.
Recommendation #3 is the old 4.The word "harm" was taken out three lines from the bottom as that
made no sense.
Recommendation #4 is the #5, the next to the last paragraph: five lines up: is required for "data".
Recommendation #5 is the old 6A. In the bold where it says, the municipality is... "to be" was deleted,
"in " was changed to "to".
Recommendation 6 is the old 6B: should show "as having" instead of "to have" significant impact. Joel,
please change that.
Recommendation 7 is the old 7. The "of" was inserted between right and property.
Recommendation 8 is the old 8.
Recommendation 9 is the old 8A.
Recommendation 10 is the old 9. "detailed" replaced detail.
Recommendation 11 is the old 10,
Recommendation 12 is the old 11,
Recommendation 13 is the old 12.
Recommendation 14 is the old 13.
Recommendation 15 is the old 14.
Those are the changes. Does anybody recall anything differently about any of these changes?
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Ill: Report walk through
Abrami: Kent, can you put the report back up? On this first page, Beth contacted me. We have Beth as
representing cell phone/wireless technology industry. We are going to put CTIA, representing the
wireless industry. Is that okay with you Beth?
Cooley: That's fine. Thank you.
Abrami: The next page is the disclaimer that all three agencies were okay with.
Miller: Before we move on, my title is incorrect as well. I am not representing the High Tech Council.
That no longer exists. It's the Tech Alliance but I am not representing them either. I am from the New
Hampshire Dept. of Business and Economic Affairs.
Abrami: Any others on title changes? Ok. Next we have the Table of Contents. We have a bit of
introductory discussion then a summary of observations and the recommendations that we went over.
We have chosen to insert the Minority Report in the report. We will get to the Minority Report in a
while. Then we have the Appendices and the Minutes, which are extensive. They are basically a total
recording of what happened in our meetings. As far as the introduction, I talk about the Commission
responsibilities and my view that it's an evolving role as we learned about the different technologies and
how 5G works with 4G and 3G. Our discussions evolved over time. Basically, it became all things RF
radiation. We talked about the various meetings that we had and who the main presenters were and
our big hiatus for four months. Then we have Questions posed by HB522. Then we have a section on
Summary and Observations. We actually got the reference to the 800,000 small cell towers from the
CTIA website.
IV:Discussion
Abrami: Any discussion?
Sherman: Pat, I just want to thank people both on the Majority and the Minority side for all the work
they put in. I think everybody in spite of their differences of opinion or their different interpretations of
the science. I think everybody has approached this with incredible fairness and collegiality. Thank you
for leading it and for all the work that everybody has done.
Abrami: I was going to say when we got to the Minority Report, Jim I think you did a great job on it. To
me, it makes the report even better having both sides represented in the report. The majority of the
members yielded to the precautionary principle because there are still a lot of unanswered questions. Is
there any other discussion?
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V: Report Vote
Let's vote on the majority report: Yes, No or Abstain.
Sherman: yes
Wells: yes
Chamberlin: yes
Miller: abstain
Ricciardi: yes
Juvet: no
Cooley: no
Garod: abstain
Roberge: abstain
Heroux: yes
Woods: yes
Gray: no
Abrami: yes
7-yes, 3-no, 3-abstain. This will be considered the Majority Report.
VI. Minority Report:
Abrami: Jim, we have to have a lead in. For example, Jim Gray and the others who want to sign on have
to let us know who they are. Jim do you want to go through this?
Gray: I am not going to go through a lot. One of the reasons that we got the report to you twenty four
hours before this meeting is so that you could look at it. It's the same things that I have been talking
about in the various meetings. The FCC and the FDA have on their websites a plethora of information
about the safety of 5G and 4G and 3G as they are used for the cell phone industry. The first page starts
off as a quick summary about the 50x safety factor that's in there and the rest. There are a lot of
references in there because we were trying to say that we are not making these things up. There is stuff
that is available on the FCC and the FDA websites. I can't remember if we left the WHO in there or not at
the end. Things tend to get a little confused right now with campaigning and everything else. You have
had a little time to review it. If anyone has questions, they can forward them to me. What I would do
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rather than having anyone on this zoom meeting say they support or don't support. It would certainly be
fine with me if someone wanted to notify you as the chair at some other point. I think I will leave it at
that.
Abrami: Any questions for Jim?
Juvet: no questions, Mr. Chair. I think you said those who want to sign onto the Minority Report that
they need to let you know. I wish to be signed on to the Minority Report.
Cooley: As would CTIA as well.
Abrami: Ok. Fine. So you don't have objection at the beginning to say the three of you are the Minority
members? Is that ok?
Gray: either at the beginning or at the end.
Abrami: I am going to yield to Joel.
Anderson: I think it is just as well to put it at the beginning. People will know upfront who the Minority
Report is from.
Gray: It can be as simple as, the undersigned not being able to agree with the majority, offer the
following report and then list the three names. Does that work for everyone?
Abrami: yes.
Anderson: Can it be instead that you endorse the report? Because you won't actually be signing it.
Abrami: House Commissions don't require signatures.
Juvet: Whatever the appropriate wording is, I am good with.
Abrami: Joel, after we do it, we can share it with the three Minority members.
Ricciardi: is it acceptable to read my comments?
Abrami: yes. It's appropriate.
Ricciardi: I genuinely appreciate everybody's point of view.
First, on foot note two, it addresses only thermal effects but if you see appendix D of the Majority
Report there is science showing harmful effects at the non-thermal level. I just wanted to draw attention
to that. In the Minority Report, it cites the IEEE papers but the IEEE does not have medical or biological
expertise. However even the IEEE has acknowledged harm at the non-thermal level in two papers which
I have sent to you. In 2016 IEEE acknowledged biological effects of non-ionizing microwaves in the IEEE
Power and Electronics magazine article. I wanted to also mention that the Minority Report makes
several references to the American Cancer Society but fails to provide links to the sources. Furthermore,
the American Cancer Society in 2016 called the NTP study a paradigm shifting of good science. The
Page 5 of 11
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public should also note that the American Cancer Society reports a sharp rise in colon and rectal cancer
among young adults at the very locations where many carry their cell phones. In footnotes 11 and 12,
the World Health Organization citations are out of date. In 2020, the WHO reopened its investigation
into the biological effects. Additionally, there are two groups at the WHO that report on EMFs. One is
represented by the industry. The other is represented by independent scientists with credentials
appropriate to weigh in on the biological effects. In footnotes 18 and 19, the Minority Report indicated
the rate of brain tumors in humans as being flat for the last twenty years. This is not true. Cancer
registries are typically five years behind and while overall cancer cases are not rising as they once did.
The following show dramatic growth where cell phones and wireless devices are used or stored on the
body or cell tower emissions. The incidence of glioblastoma is the deadliest type of brain tumor and I
have links to all of this that I have mentioned which I am going to forward to you. The last thing I want
to say is that industry tends to focus on the cancer rates as cancer takes the longest time to develop
during which time the industry can continue to promote toxic products. Other diseases are developing
more rapidly as shown in the Majority Report,in Appendix D, including infertility, neurological harm and
especially to children. With regard to the section on 5G mm waves, the IEEE is referenced yet again.
These are industry engineers who do not have the biological expertise. I just wanted that for the record.
Abrami: Ok. It will be in the minutes.
Heroux: Essentially, one thing I regret is I am addressing primarily the people of the Minority Report, is
that there was not more discussion between us. What I mean by this is technical discussion in looking at
the actual issues. I know that probably most of the people of the Minority Report felt very solid in their
opinions relying on legislation that was passed and I can understand that. In spite of our differences, I do
respect your opinion because this is your opinion. One last comment is that we were not provided the
material that would have led to this discussion. Perhaps the people who were in the Majority Report
could assemble more energy to present. In fact, the same amount of enthusiasm was not apparent on
the other side. I would like to remind the Commission that on January 10th meeting, there were
promises by the CTIA to provide us with reports that support the positive health impacts of cellphone
deployment. These reports did not materialize. Essentially, I think that the lopsidedness that is quoted in
the Minority Report is more a result of energy and initiative in providing evidence. Thank you.
Abrami: Ok. Any other comments at this point?
VII: Minutes of this Meeting:
Abrami: Let's talk about the minutes of this meeting. They will be in the report. Deb Hodgdon is going to
work very hard and we will get the minutes out to everybody. We will not have a meeting to approve
them. If you see something you think is incorrect, please email me. We want to get this report in by
November 1st with the minutes of this meeting included. Is that okay with everybody? Ok. Thank you.
Page 6 of 11
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VIII: Submission Process
Abrami: I talked to Jim about this. I think he is okay with us putting the Minority Report in the same style
type as the rest of the report. There will be a letter of transmittal. The report goes to the Governor, the
Speaker and the Senate President. There is a letter of transmittal that the House staff will put together.
There are no signatures on it just the letter of transmittal that goes on top of the report and it's sent
out. This report will be posted online on the Commission's website. We added that website to the
report so if anybody wanted to see the additional information or papers we posted there, things like
that will be available for the public. It's all about the minutes. No pressure Deb. If I stop talking, we can
get the minutes done sooner right?
IX. Commission Farewells
Abrami: First I want to say, it's been a pleasure working with all of you. We had a great group. There
were a lot of scientific minds in the room, legal, business. We didn't agree on everything as Tom said but
I think we all got along very well. I want to specifically point out Kent Chamberlin for coming to the
rescue. When we couldn't get bandwidth from the state to continue this Commission, he volunteered.
Or I asked him to volunteer! UNH's zoom capacity was great as well as setting up all those meetings and
being behind the scenes making the meetings go smoothly.
I want to thank Joel Anderson for his support behind the scenes. It was a lot of work especially when it
came to the report and I think I hinted at this when I sent something out. There was one night he
worked until ten o'clock at night to get the report ironed out. He proofed a lot of the report and found
links that were outdated or not working and corrected those. Thank you, Joel for going beyond the call
of duty.
And of course I want to point out Deb Hodgdon who has been doing our minutes since the beginning.
These minutes are more like a court transcription. I know she spends a lot of time going through and
preparing those.
I also want to thank the audience. I know we never formally opened it to the public which I had
promised. That has to do with the fact that we closed down for four months. We missed five meetings.
We were just cramped for time or we would have opened this up more to the public. But with zoom, we
were able to open it up to more than just ten or so people that would gather at the onsite meetings at
the statehouse. We have people from all over participating. Their comments in the zoom chat were
captured and added to the minutes.
I thank you all again. Does anybody want to make any closing comments?
Ricciardi: I just want to say that it was an honor to work with all of you. It really was and I am so proud of
the work that we have all done. So, thank you.
Heroux: To me, this commission is extremely memorable. I would like to congratulate the Chair on
bringing this difficult boat to port. I want to ensure all of you, especially those of the Minority Report
Page 7 of 11
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that you can contact me at any point in the future and you will have my full cooperation if you need my
help. Thank you.
Cooley: Will we be notified when the letter of transmittal is sent? Will the Commission know?
Abrami: We will make sure everyone gets notified. It will be out there electronically and we will let you
know where to go to find it.
Cooley: Thank you.
Abrami: Stay well. We are formally adjourned (1:47 pm)
Chat from -" 1 Isslon Meeting, Octol
From Beth Cooley to Me: (Privately) 01:23 PM
Should Herman's video be shown? just curious. I've directed my members to turn their videos off
From Theodora Scarato to Everyone: 01:27 PM
The World Health Organization EMF Project The World Health Organization EMF Project says "There is
no consensus."
Dr. Emilie van Deventer, Head of the World Health Organization's EMF Project was quoted in The Daily
Princetonian, "The data is gray. It's not black and white...There is no consensus, it's true."
"Furthermore, as I see it, the WHO EMF Project was not only hijacked by the ICNIRP but, from the
inception, it was set up as a front for the ICNIRP agenda of unifying exposure standards to RF-EMF, "
stated Dariuz Leszczynski PHD (a member of the EMF working group of the WHO/IARC who stated in
2020," ICNIRP is a private club. Its new members are selected by the current members where the
prerequisite of selection is the very close similarity of opinions on non-ionizing radiation health effects.
There are no published criteria for the selection of new members. Nobody checks whether the selected
experts are sufficiently good experts."
https://betweenrockandhardplace.wordpress.com/2020/09/08/leszczynski-there-is-something-utterlv-
wrong-with-the-icnirp-membership/
From Theodora Scarato to Everyone: 01:27 PM
Fact: There is no 50 times safety margin. The FCC is ignoring the science and promoting the myth of the
50 times safety factor despite being informed that it is not based on scientific fact.
Scientific data refutes the claim. The FCC says this factor is based on studies that show behavioral
disruptions to animals at 4 w/kg. However the EPA found thermal harm at 1 W/kg. The EPA stated in
2020 that the last time the agency did a research review was in 1984 as detailed in the 1984 EPA Report
The Biological Effects of Electromagnetic Fields. The EPA 1984 Report concludes with the summary that
Page 8 of 11
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"It has been concluded from this review that biological effects occur at SAR up to about 1 W/kg some of
them may be significant under certain environmental conditions." Therefore the level of harm of 4W/kg
used by IEEE and adopted by FCC is inaccurate. See the 1984 EPA report, Comments of Pong Research
Corporation, Environmental Working Group and Environmental Health Trust.
https://ehtrust.org/epa-1984-report-biological-effects-of-emfs/
From Theodora Scarato to Everyone: 01:28 PM
Furthermore, the Environmental Protection Agency typically uses safety factors in the 100s or 1000s
range for noncancer endpoints and for carcinogens, a threshold or nonthreshold approach is used
(National Research Council (US) Committee on Improving Risk Analysis Approaches Used by the U.S.
EPA).
https://www.ncbi.nlm.nih.gov/books/NBK214619/
Of key importance, even if there were a slim safety factor, the level chosen is about heating harm only.
It is thermally based and has nothing to do with biological harm from non thermal exposures that can
occur at far far lower RF exposures.
Furthermore these limits were not based on protecting trees, birds, insects or the natural environment.
Thus, flora and fauna are entirely unprotected.
The EPA 1984 Report concludes with the summary that "It has been concluded from this review that
biological effects occur at SAR up to about 1 W/kg some of them may be significant under certain
environmental conditions." Therefore the level of harm of 4W/kg used by IEEE and adopted by FCC is
inaccurate.
From Theodora Scarato to Everyone: 01:30 PM
There is no 50 times safety factor as a fact of science. The FCC is ignoring this science - ignoring the EPA
Ignoring facts
Despite the fact that the WHO EMF Project website seems to imply the research shows no harm, such
statements are unsubstantiated and are based on a house of cards. The fact is the WHO EMF Project
has yet to do a full evaluation of the recent research and the last monograph was in 1993. This is stated
on their website quite clearly "The World Health Organization is undertaking a health risk assessment of
radiofrequency electromagnetic fields, to be published as a monograph in the Environmental Health
Criteria Series. This publication will..update the monograph on radiofrequency fields (1993)."
https://www.who.int/peh-emf/research/rf ehc page/en/
Do not confuse the World Health Organization EMF Project with the The World Health Organization
International Agency for the Research on Cancer.
These are two separate entities. Unlike the WHO EMF Project (started by a scientist found to be
funneling industry money though a university), the WHO International Agency for Research on Cancer
(WHO/IARC) which is vetted for conflicts of interest and for whom scientists cannot be financially
connected to Telecom.
From Theodora Scarato to Everyone: 01:34 PM
Page 9 of 11
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In 2011, the WHO/IARC classified RF as a Class 2 B "possible" human carcinogen based primarily on
evidence from human studies that long-term users of mobile phones held to the head resulted in an
elevated risk of developing brain cancer. One major reason that the IARC rating was not at "probable" or
"known" was the lack of clear evidence from animal studies for exposure leading to cancer.
https://www.iarc.fr/wp-content/uploads/2018/07/pr208 E.pdf
In 2019, the advisory group of the International Agency for Research on Cancer (IARC) of the World
Health Organization released new recommendations to reassess as a "high priority" the cancer risks of
radiofrequency (RF) radiation between 2020-2024. The recommendations were published in The Lancet
Oncology on April 18, 2019.
https://www.thelancet.com/iournals/lanonc/article/PIIS1470-2045(19)30246-3/fulltext
CDC shows tumors increasing in children. Read it here https://ehtrust.org/cdc-finds-brain-liver-and-
thvroid-cancers-increasing-among-us-children-2001-2014/
From Theodora Scarato to Everyone: 01:35 PM
http://aspho.org/uploads/meetings/2018annualmeeting/Abstracts for Website.pdf
Centers for Disease Control and Prevention, Atlanta, Georgia, United States
link: http://aspho.org/uploads/meetings/2018annualmeeting/Abstracts for Website.pdf
"increased for non-Hodgkin lymphomas (except Burkitt lymphoma), central nervous system neoplasms,
renal tumors, hepatic tumors , and thyroid carcinomas..."
http://aspho.org/uploads/meetings/2018annualmeeting/Abstracts for Website.pdf
From EHT- Recently a reporter told EHT that this data seemed to be in contradiction to information
posted on the National Cancer Institute (NCI) website. The reporter asked how EHT could be stating that
CDC says brain cancers are rising in pediatrics when the reporter went online and found information
stating "the brain cancer rates were stable." He sent this link.
So we wrote the CDC scientist and the CDC scientist responded to EHT that that the NCI link sent by the
reporter refers to statistics that represent only 13.4% of the US population, whereas the new CDC
report uses the USCS database representing 98% of the US population.
From Theodora Scarato to Everyone: 01:37 PM
The European Scientific Committee on Health, Environmental, and Emerging Risks' "Potential effects on
wildlife of increases in electromagnetic radiation statement identified emerging issues (including 5G, E-
cigarette, and chronic diseases.) The Committee prioritized 5G impact as "high" noting the lack of
adequate research and citing studies documenting harmful effects such as Pall 2018, Di Ciaula 2018 and
Russell 2018. The report concluded "the lack of clear evidence to inform the development of exposure
guidelines to 5G technology leaves open the possibility of unintended biological consequences."
https://ec.europa.eu/health/sites/health/files/scientific committees/scheer/docs/scheer s 002.pdf
The 2020 Executive Summary of the Health Council of the Netherlands said clearly that there is no
information on mm-waves and human health:"...There has been almost no research into the effects of
exposure to frequencies around 26 GHz..."And they recommended against using higher frequencies
stating "...The committee recommends not using the 26 GHz frequency band for 5G for as long as the
potential health risks have not been investigated..."
Page 10 of 11
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From Theodora Scarato to Everyone: 01:37 PM
https://www.healthcouncil.nl/documents/advisorv-reports/2020/09/02/5g-and-health
From Cece Doucette to Everyone: 01:39 PM
When will the report be posted?
From Theodora Scarato to Everyone: 01:39 PM
Numerous governments also educate their citizens with recommendations to reduce cell phone
radiation, especially to the heads of children. Governments with policy and/or recommendations by
health authorities include Belgium, Switzerland, French Polynesia, Finland, Ireland, Germany, Greece,
Israel, Turkey, Singapore, France, United Kingdom, Russia, Denmark, India, Australia, Austria, Cyprus,
Canada, Italy, Korea and Croatia. 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." 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 tumours" and numerous municipalities have issued resolutions to follow Resolution
1815. https://ehtrust.org/policv/international-policv-actions-on-wireless/
From Cece Doucette to Everyone: 01:43 PM
Sincere gratitude to all for your dedication in seeking the truth and laying the path to transition to safe,
sustainable, fiscally responsible technology.
From Theodora Scarato to Everyone: 01:44 PM
Thanks beyond words for your incredible effort in putting forward scientific facts in a transparent
fashion.
Page 11 of 11
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www.dakotarural.org
Secretary Jennifer Granholm
US Department of Energy
1000 Independence Avenue SW
Washington, DC 20585
Sent via email; s|
Subject: Uranium Mining
Dear Secretary Granholm,
We, members of Dakota Rural Action, are writing to express our dismay that the DOE
appeare to be considering a Strategic Uranium Reserve. Dakota Rural Action is a
grassroots family agriculture and conservation group that organizes South Dakotans to
protect our family farmers and ranchers, and natural resources.
Putin s war against the Ukrainian people seems to have spurred urgent conversations
about banning uranium imports from Russia, thereby strengthening the hand of
uranium mining companies and their political pals elsewhere, who want subsidies to
make up for any supply shortfall. While understandable, this logic is flawed
scientifically and flawed from a perspective of environmental justice.
Keeping in mind that uranium is not classified as a strategic mineral, the entire idea of
a Strategic Uranium Reserve is only a thin mask of a name for bald-faced subsidies to
a mining sector that cannot feasibly stand on its own.
-------
Scientifically, according to the Argonne National Laboratories, "recycling used [spent]
nuclear fuel could produce hundreds of years of energy from just the uranium we've
already mined... Problems with older technology put a halt to recycling used nuclear
fuel in the United States, but new techniques developed....can address many of those
issues."
US nuclear plants get 16 percent of their uranium from Russia. Instead of subsidizing
an alternative supply stream, the older dangerous plants should be decommissioned
and replaced with power plants using renewable energy sources. More importantly, the
US must reduce its energy usage. A ban on Russian uranium should be seen as an
incentive to save energy and transition to renewables power, not as a motive to
reinforce the market for a material that has left us a legacy of unmanageable cleanup
issues. The taxpayers money that would go to the subsidies, should instead be used to
restore the radioactively dangerous old uranium mining sites that threaten communities
like ours in the Black Hills.
From the perspective of social justice, it is well understood that much of the uranium
mining in the US has occurred at the expense of rural poor and Indigenous
communities. The peoples of the Lakota, Havasupai, Hopi, Navajo, Ute, and other
nations have experienced deleterious health, economic, social, and spiritual effects of
uranium mining.
An examination of that history of uranium mining in this country reveals that public
po||cy has been disproportionately influenced by corporations with little commitment to
the environment, to Native treaty rights, or to the spiritual and economic treasures
embodied in our National Parks (cf. The Grand Canyon). In fact, these corporations
seem committed to Environmental INjustice, not to Environmental Justice.
We call on you and your administration to avoid the establishment f a Strategic
Uranium Reserve; to honor the recommendations of the White House Environmental
Justlce Council» and other plans and policy recommendations made by the current
administration; to mitigate climate concerns, to direct climate investments to frontline
communities; and to respectfully engage Indigenous communities in policies that affect
their sovereignty, health, and well being.
-------
Respectfully submitted for your consideration.
The Members of Dakota Rural Action
Brookings, South Dakota
Dusty Johnson, U.S. Representative
Michael Rounds, U.S. Senator
John Thune, U.S. Senator
Deb Haaland, Secretary of the Interior, Department of the Interior
Bryan Newland, Assistant Secretary, Indian Affairs
Brenda Mallory, Chair of the 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
White House Environmental Justice Interagency Council
Members of the White House Environmental Justice Advisory Council
-------
^THUNDER
Q/ALLEY
COMMUNtTY DEVELOPMENT CORPORATION
April 22, 2022
Secretary Jennifer M. Granholm
U.S. Department of Energy
1000 Independence Ave. SW
Washington DC 20585
Sent via Email: the.secretarvfa hq.doe.pov
Subject: Uranium Mining Concern
Dear Secretary Granholm,
Community Development Corporation would like to express our concern
bout the U.S. Depai tenent of Energy's consideration of a uranium reserve We are deeplv
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
potential y banning uranium imports from Russia, we cannot stress enough that any uranium
mining at the Pinyon Plame Mine (formally known as the Canyon Mine) located on federal lands
neai their reservation will have effects from not only their tribe but other tribes who mav
experiencing the same difficulty. A horrible war across the world should not be grounds for
he™the Unite^Stltes6' ^ ^ memberS' 38 wdl as 0ther mdlgenous communities located
Energy Fuels, Inc. currently operates the Pinyon Plain Mine (Canyon Mine) next to then-
reservation and on their Ancestral lands and traditional cultural property- Red Butte This mine
has a history of problems including that it pierced a major aquifer digging what it claimed would
be a diy mineshaft, and then sprayed the now-contaminated water into the national forest This
mine shou d not 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
UkrlTn PfTm "ft1' uUr department wi]1 essentially shift the sacrifice of lives in the war-torn
Ukraine for lives of the Havasupai tribal members. This is how serious we all see this issue We
are also m the understanding that when President Biden ran for office, he pledged to protect
tribal communities and restore tribal sovereignty. We need you to support this pledge to us
Liberation
-------
hunder Valley CDC is located in the Pine Ridge Indian reservation. Where the Oglala Sioux
lnbe has taken a stand against any uranium mining. Thunder Valley CDC and Oglala Lakota
yate know first-hand the damages that uranium mining can cause to the people as well as the
water aquifers. We ask the Department of Energy to uphold President Biden's pledge to protect
not only the Havasupai Tribe but all Indigenous nations and honor Tribal sovereignty. We need
you and others to hear our voice and take action for the first nations and Indigenous peoples of
the United States of America. We ask that you withhold participation of the Pinyon Plain Mline
(Canyon Mine) m any federal uranium program or funding to operate. Not doing so will place
our Indigenous tribes and the Havasupai tribe's existence in harm's way.
Sincerely,
Tatewin Means
Executive Director
Thunder Valley CDC
-------
TZlack "Hills
Clean Water Alliance
April 24,2022
Secretary Jennifer M. Granholm
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585
the.secretary@hq.doe.gov
RE: Strategic Uranium Reserve
Dear Secretary Granholm:
wite today as the Executive Director of a non-profit organization based in the Black Hills of South
ota and Wyoming and as an expert on uranium mining issues. For the last 40+ years I have
worked with others from our area to block new attempts to mine uranium and to protect this unique
ecological, historical, geological, and scenic place that is the treaty homeland of the Lakota people and
h°H 7°' r'^t0UriSm'md ^^reation economy. As a scholar, 1 have wrto
published, and spoken about uranium regulation and politics.
5 rn^'i Q7nec about u™ium ™ing here, having experienced it in the
hem 1 a n " abandoned uranium mines and prospects in our area have
been cleaned up Our water - including a major irrigation and recreation reservoir - is contaminated
with uranium and/or arsenic. The people of the Pine Ridge and Cheyenne River Indian Reservations
coexist with contaminated water, with virtually all of the water on Pine Ridge being highlv
contaminated with uranium. When large companies came to the Black Hills in the late 1970s the
people of our area ran them out, and uranium mining was stopped. Now we are fighting for o'ur water
tomine eC°n°my' 0Ur heaJth agam' as one c°mpany is exploring and a second is seeking licenses
We know that nuclear power is not carbon neutral, because we know that mining is one of the largest
ntributors to carbon emissions m the world. We know that uranium must be transported repeatedly
and enriched, and that the construction and decommissioning of nuclear power plants create carbon
emissions, and that storage and - maybe someday - disposal of high-level nuclear wastes will create
more carbon emissions. The only part of the nuclear chain that does not emit large amount oSrn
the power p ant. The nuclear industry has fooled a lot of people with their carefully-worded
language, but I hope you are not fooled. y woruea
P.O. Box 591 - Rapid City, South Dakota 57709 - www.bhcleanwaterallianrP.nr.,
605-787-2872 - nobhuraniumPRmail.mm - Facebook: Black Hills Clean Water Alliance
Twitter: Black Hills Clean Water Alliance -- Instagram: bhcleanwateralliance
-------
Moving toward a lower-carbon economy means moving away from uranium mining and nuclear
power.
Now we hear that some officials are pushing the idea of a new strategic uranium reserve. This makes
no sense from a carbon emissions point of view. It endangers our communities and our water - as well
as the water of other communities that might end up downstream or downwind from renewed uranium
mining. Nuclear power is vastly expensive and takes a decade or more to make a reality. We need
immediate solutions to the climate crisis, particularly as our area is already experiencing greatly
increased incidences of flooding.
We oppose the creation of the new strategic uranium reserve and ask the full federal government to put
a stop to this nonsense and to work instead toward a non-nuclear, carbon-minimizing future. The latter
path has great potential for our communities, our water, and our livelihoods.
Please feel free to contact me, if you have any questions. I appreciate your time, attention, and action.
Sincerely,
Lilias Jones Jarding, Ph.D.
Executive Director
Cc: Michael S. Regan, EPA Administrator
Deb Haaland, Secretary of the Interior, Department of the Interior
Brenda Ma]lory, Chair, White House Council on Environmental Quality
Gina McCarthy, National Climate Advisor
John Thune, Senator, South Dakota
Mike Rounds, Senator, South Dakota
Dusty Johnson, Representative At-Large, South Dakota
Joe Manchin, Senator, West Virginia
Raul Grijalva, Representative, District 3, Arizona
Cecilia Martinez, Ph.D., Senior Director for Environmental Justice, CEQ
Members of the White House Environmental Justice Ad visory Council
White House Environmental Justice Interagency Council
P.O. Box 591 - Rapid City, South Dakota 57709-
605-787-2872 - - Facebook: Black Hills Clean Water Alliance
Twitter. Black Hills Clean Water Alliance — Instagram: bhcleanwatera ilia nee
-------
Ogfala Sioux Tribe
Natural Resources Regulatory Agency
P.O. Box 320
Pine Ridge, SD 57770
Phone: (605) 867-5624
Fax: (605) 867-2818
Natural Resources Regulatory Agency
Water Resources Department
Administrator
Reno Red Cloud
ostnrrawrd@gwtc.net
J
Secretary, Jennifer M. Granholm
US Department of Energy
1000 Independence Ave. SW
Washington DC 20585
Subject: Oglaia Sioux Tribe's concerns with federal uranium mining reserve program.
The Oglaia Sioux Tribe, Natural Resources Regulatory Agency, was created by the Oolala Sioux Tribal
Council to prov.de guidance and technical assistance in the assertion of 1851 and 1868 Treaty and
reserved water rights. In regards to the compliance with Tribal law, in the protedion ^.Wation
n3sTpeS Si0UX - Water Resources to meet £
We provide guidance for our best management practices by utilizing traditional 'Lakota' knowledae for
adUvaSnceCm' If t *** US eC0n0mic< and *"*>' factors to SI9 and
advance the qua ity of our environment. We have a Tribal no nuclear policy, and oppose anv minino on
MUrJkfe home|and. We are impacted by 'Uranium Mining' from activity from the Black Hills SD and
Northwestern Nebraska for potential contamination of our surface and ground
The Oglaia Sioux Tribe, opposes the strategic uranium reserve program, by the US Department of1
If you should have any questions, please contact my office at your earliest convenience.
Respectfully,
Reno L. Red Cloud Sr.
Administrator
Oglaia Sioux Tribe, Natural Resources Regulatory Agency / Water Resources Department
-------
April 24,2022
Resolution
It's All About the Water
A Grassroots Movement in Fall River and Custer Counties
South Dakota
510 Jennings Avenue
Hot Springs, SD
WHEREAS, the Cheyenne River in Fall River County,. South Dakota is already contaminated with
uranium from old open pit mines NW ofEdgemont, we cannot afford any more contamination from
Powertech USA s proposed In Situ Leach mining,
WHEREAS we have intervened in eveiy Powertech USA permit process since 2012. There is no mining
as of today. Many permits are in litigation
thC Water fr°m the Cheyenne River is controlled in Angostura Dam for irrigation and flood
control. The uranium contaminated water flows northeast and into the Missouri. This waterway is
WHEREAS, an appl ication was sent to the EPA in Denver to clean up one of the old open pit uranium
mines. After two attempts by the EPA to assess the contamination, the case was closed as the pS
Manager refused access to private property. The mine continues to contaminate the water.
WHEREAS on April 12,2022 Pegasus Resources, another uranium mining company, purchased 147
lode mine claims on 3,037 acers in Fall River County for In Situ mining. y puicnased 14/
WHEREAS, uranium contamination of water has never been brought back to baseline, uranium in our
water and aquifers is a deadly risk to human and all life.
WHEREAS, the mining, processing, transportation, manufacturing of any uranium product radioactive
waste produce from mining and nuclear powerplants are all deadly. There is no safe storage of this
radioactive waste to date. U1 tn,s
WHEREAS Russian uranium imports are only 13% of our annual Reserve and there is nothing "Green"
or sustainable about Nuclear Power. Keep it in the ground.
^ RES0LVED' A" about tile Water opposes the creation of the Strategic
fnte^fSsotofLVED> Wi" '° ^ Mi°"S if needcd to the
Sarah Peterson
Organizer of If s All about the Water
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4/14/22, 4:53 PM
The drive to widen the digital divide - CalMatters
CAL MATTERS
COMMENTARY
The drive to widen the digital divide
OBY GUEST COMMENTARY
OCTOBER 20, 2021
illustration via iStock
IN SUMMARY
The American Legislative Exchange Council and telecoms are working in
tandem to ensure consumers in California and the U.S. do not get access
to world-class telecommunication services.
R\§ I arrif Hr+ona Crvorial tn ralMaHarc
https://calmatters.org/commentary/2021/ 10/the-drive-to-widen-the-digital-divide/?utm_source=CalMatters Newsletters&utm_campaign=ab94d9e62b-WHATMATTE... 1/4
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4/14/22, 4:53 PM
The drive to widen the digital divide - CalMatters
Larry Ortega is founder of Community Union Inc., a nonprofit corporation
that trains consumers living in the digital divide, and a 35-year veteran of the
technology sector.
uy lqi i y ui tu vuiitiulici j
For almost 30 years, America's telecom companies have been receiving
billions of dollars in rate increases and extra fees to finance the build-out of a
national fiber optic network. Along the way, they discovered that such a
network would hamper their opportunity to make a financial killing with
wireless technology. So in 2010, they stopped upgrading phone customers
with fiber optics, thus widening the digital divide and leaving millions of
Americans unconnected.
This is not just another digital divide story about rural or inner-city residents
who lack access to broadband services. This is a story about a skillfully
thought-out, well-financed scheme that involves the American Legislative
Exchange Council (ALEC). Koch Industries (the largest privately held
company in the U.S.) and a gang of lobbyists joining forces to write
legislation.
This legislation would use the levers of state government to fast-track the
deployment of an unregulated and a highly profitable wireless business. In
state after state, he same political forces that are legislating away voting
rights and increasing the power of corporations are pushing fast-track 5G
legislation under the guise of fixing the digital divide.
The wireless industry claimed that rapid deployment of 5G technology will
bring great new benefits to consumers, and just like that, almost every one
of our California legislators were on board. What the industry purposefully
omits is that fiber optics (wired) connections are 10.000 times faster than
5G. more secure, less expensive for the consumer and future-proof.
https://calmatters.org/commentary/2021/ 10/the-drive-to-widen-the-digital-divide/?utm_source=CalMatters Newsletters&utm_campaign=ab94d9e62b-WHATMATTE.
2/4
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4/14/22, 4:53 PM
The drive to widen the digital divide - CalMatters
In fact, it was the phone companies themselves that abandoned the
completion of fiber connections midstream, leaving millions of miles of "dark
fiber" in the ground. A lie
detailed how abandoning fiber optic upgrades to low-
income and rural areas left consumers with wireless-only options. This is a
well-known - and unethical - strategy called "harvesting."
These attacks on consumers by ALEC and the telecommunications industry
have been constant. Gov. Gavin Newsom faced off with telecom when he was
mayor of San Francisco. Federal Communication Commission Commissioner
Brendan Carr had fought the city's effort to ensure consumer protections.
Carr wrote the FCC's current regulations on 5G, known as Carrfs 5G Orders.
These orders obliterate state and local government oversight of
infrastructure build-out, throwing out both financial and physical safety
protocols, all in the name of a race to third place. Even when 5G can be
successfully deployed, iflllilLSRii and cable TV.
ALEC, Carr and the phone companies are working in tandem to ensure that
consumers in California and the U.S. do not get access to world-class
telecommunication services. Fiber optic upgrades would slash profits by
hundreds of billions of dollars, breaching telecoms' fiduciary duty to their
shareholders. The telecoms want no part of profit-slashing and therefore
have chosen to drive a strategy that ensures the persistence of a digital
divide.
Community groups, unions (such as the Communication Workers of
America) and parents who fear their children may be harmed by unregulated
deployment of wireless infrastructure are on to this nonsense. They recently
asked for, and were granted, the governor's veto on , one of
the ALEC bills. The effort was a massive grassroots undertaking. But while
this cohort of consumers and activists prevailed this time, it is not a
sustainable long-term strategy.
https://calmatters.org/commentary/2021/ 10/the-drive-to-widen-the-digital-divide/?utm_source=CalMatters Newsletters&utm_campaign=ab94d9e62b-WHATMATTE.
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4/14/22, 4:53 PM
The drive to widen the digital divide - CalMatters
The veto of SB 556 is a victory for local governments in California, but it's
only temporary. ALEC and friends have a history that has had a devastating
impact on families living with the digital divide, starting with 2012's
which the CPUC Network Exam points to as a culprit in exacerbating the
digital divide; followed by 2017's , which was vetoed by Gov. Jerry
Brown; and 2021's , which created a "deemed granted" law that puts
• Gov. Newsom signed AB 537 into law.
Consumers, telecoms and our legislators are charged with the task of
ensuring that all Californians have quality, high-speed, fiber optic access to
online resources, be they in the rural cities of Huron, Mendota or Firebaugh
or the inner-city MacArthur Park, Huntington Park or Leimert Park
neighborhoods of Los Angeles.
It is time for the governor to call for an investigation into why these ALEC
bills keep landing on his desk. Consumers deserve to know how it is that the
telecom industry's plans since 1993 to s
still have not been delivered. At no point did consumers agree to a more
expensive, less efficient wireless network. Wireless technology has its
application, but to reiterate, 5G is 10,000 times slower, requires higher
maintenance and Mill consume.Muctl more energy than fiber optics once
deployed, guaranteeing a larger, not smaller, carbon footprint.
We might begin by looking at increasing oversight of fiber optics deployed
under of the Communications Act of 1934 - a federal mandate that
all customers shall be served. This increased oversight, by itself, might be
able to close the digital divide.
© 2022 CALMATTERS.
PROUDLY POWERED BY NEWSPACK BY AUTOMATTIC
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Why should we be
concerned about
EMF exposure?
You see it everywhere:
"Free Wi-Fi." You fee! excited.
Comforted. Relieved. You
whip out your digital trifecta—
smartphone, tablet, laptop.
Yes! Connection! But there is
mounting scientific evidence
pointing to potentially harmful
biological effects from this
exact type of radiofrequency
radiation.
As Paleo biohackers, we
are committed to figuring
out how the body can run
most efficiently and reach
homeostasis, and we do this
through nutrition, movement,
mindfulness and our
environment—all based on
the wisdom of our ancestors.
We need only revisit John
Durant's The Paleo Manifesto
to intuit the problem with the
deluge of EMFs in our world:
"An organism is likely to thrive
in a habitat that resembles
its ancestral habitat." And
that includes our earth's
natural electromagnetism
and energy fields.2 But these
overabundant man-made
frequencies fly in the face of
that environmental constant.
So what is this fundamental
change in our habitat's energy
doing to our bioelectrical
bodies?
How do EMFs
harm?
We love our technology for
its convenience, productivity
and entertainment value, but
the sobering reality is there
are now hundreds of studies
from independent scientists
and health experts around
the world indicating biological
effects from both low-
frequency and radiofrequency
radiation. This type of
non-ionizing, non-thermal
radiation is not powerful
enough to break electrons out
of orbit, but it can nonetheless
interfere with normal body
processes. How exactly?
EMFs are an external bodily
stressor like any other. There
is a wealth of scientific
evidence showing that even
low levels of electromagnetic
fields can activate the body's
cellular stress response.5 This
assault on the cells stimulates
stress proteins,9 thereby
disrupting biological balance.
This all in turn prevents the
body from healing, causes
immune system imbalances,
disrupts metabolic function
and lowers disease
resistance.3 Not good—since
this is all the stuff we Paleo
folks vow to overcome.
The list of associated
health concerns with non-
ionizing EMF exposure is
significant, including (but
not limited to): brain cancer;
childhood and adult leukemia;
leakage of the blood-brain
barrier; genotoxic effects on
DNA damage; cognitive and
memory problems; increased
risk of neurodegenerative
disease; increased harm
of chemical toxins due to
combined exposure; low
But wait, aren't
there EMF safety
standards?
The question of EMF safety
levels continues to spark a
complex worldwide debate.
Christopher Buonocore,
BBEC, EMRS, of LifeSource
Environmental Solutions
explains why. In the U.S., the
Federal Communications
Commission (FCC) regulates
wireless technologies,
radio frequencies and all
associated devices. Yet
the current national safety
standards for maximum
allowable EMF exposures are
set by the FCC at 10,000,000
sperm count; learning
disorders and behavioral
problems; increased allergic
and inflammatory responses;
insomnia; decreased
melatonin production; and
risk factors for childhood
hyperactivity, learning and
behavioral disorders.1-3
Alarming, to say the least.
48 Ang/Sept 2016
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v—er-*Ti+-iecr u-^o'iicri*^ C-^iOlCgy
Ein/iroi/ne/i-fel CHoiSO'/"/"cinr
(&>%3>E^CZ.) MccH~Ue\*s Wk/e-fz-/te
©¦£-" X-\ve//i«'ViS nVes
EfVSF STANDS FOR
ELECTROMAGNETIC FIELD
ywe ;
surrounded by EM fields—both natural
and man-made. These fields have two
components: an electric field and a magnetic
field. The strength of EMFs is measured in
units of power density, and EMFs differ in
frequency and wavelength The spectrum of
EM fields ranges from extremely low (e.g.,
your blender's power cord) to very high (e.g.,
gamma rays).
RADIOFREQUENCY (RF)
refers to
invisible, man-made wireless technologies,
such as wireless routers, cellphones, cell
towers, cordless phones, smart meters, Wi-
Fi-enabled devices, e-readers and wearable
smart tech.
LOW-FREQUENCY/EXTREMELY
LOW-FREQUENCY (LF/ELF)
His electricity
generated from power lines, transformers and
electrical appliances.
I
refers to
contaminated signals, harmonics or high-
frequency micro-surges that ride on top of our
clean electrical current. Think about this like a
distortion. Examples include improper wiring,
the power grid, fluorescent lights, LED lights
and dimmer switches.
pW/m28—that's literally millions of times higher
than the 3 to 6 |jW/m2 precautionary level
presented by the 2012 Biolnitiative Report.1
So why is the FCC's level so high? Because
they based their recommendations on safety
standards issued by the American National
Standards Institute (ANSI), the Institute of
Electrical and Electronics Engineers, Inc.
(IEEE), and the National Council on Radiation
Protection and Measurements (NCRP).10 These
organizations only considered thermal effects
(i.e., heating) on the body when setting exposure
limits.3 Yet, as Mr. Buonocore explains, "there is
a substantial amount of peer-reviewed research
published nationally and internationally indicating
that much lower non-thermal levels have dramatic
biological effects." And it's at these non-thermal
levels where we find our wireless toys and
electronic devices.
Not to mention, U.S. federal regulations did
not consider cumulative or multiple overlapping
exposures—a serious problem when most of us
spend our days glued to a cellphone, while typing
on a laptop, all connected on a wireless network,
as we sit under LED lights, drive a car synced
with Bluetooth, and sleep in a house with a smart
meter, perhaps with a power transformer outside
the window. For the first time in the history of man,
we are surrounded by omnipresent, entire-body
exposures to artificial electromagnetic frequencies
in our homes, communities, schools, businesses,
restaurants, transportation systems and public
infrastructures.
In 2011, the International Agency for Research
on Cancer (IARC), part of the World Health
Organization (WHO), published a risk assessment
guideline that raised radiofrequency radiation to
"Group 2B: possibly carcinogenic to humans"—
meaning it could potentially be cancerous.
But is anyone actually sick from
this yet?
There is a small, but growing, percentage
of the world's population now suffering
from a multisystemic condition called
eiectrohypersensitivity (EHS). Individuals with
EHS experience a wide gamut of physiological
manifestations while in the presence of
electromagnetic fields (even at extremely weak
power densities). Symptoms of EHS worsen with
dose and duration of EMF exposure and include
headaches, heart palpitations, chest pains, skin —
Subscribe at: PaleoMagOnline.com/subscribe
Aug/Sept 2016 49
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A o£ fVioe o*yc.e .\-/- c.JverfiSe-^eTf \*/cLU -hUe Ue<*.c}li*\e ^X^oc^or-s Si'Viofc© CLc^^yels!"
(BBEC) —Christopher Buonocore, BBEC, EMRS, LifeSource Environmental Solutions
rashes, disturbed sleep, burning/tingling/numbness,
muscle aches, joint pains, nausea, restless leg
syndrome, tinnitus, vertigo, brain fog, memory
problems, cognitive dysfunction and more.46
When this condition is unmanaged, individuals
with EHS become significantly more sensitive
to increasingly smaller and shorter intensities of
EMF stimuli. Currently, management of EHS is
dependent upon strict avoidance of EMFs and
other environmental toxins. An individual will
usually go into remission once living in a low-EMF
and chemically pure environment. However, it
remains unclear if full recovery is possible, once
the individual re-enters an EMF-laden area.6
While EHS is not yet accepted as a legal
disability in the U.S., several countries classify
it as a "functional impairment," and the WHO
states that "the symptoms are certainly real...
EHS can be a disabling problem for the affected
individual."11 While exact numbers are hard to
pinpoint at this stage, it is estimated that roughly 3
to 5 percent of the world's population currently has
EHS, with approximately 35 to 50 percent mildly to
moderately affected by EMF pollution.4'6
The most severely debilitating cases of EHS
require the individual to break from our high-tech
society and live entirely off the grid. These so-
called "EMF refugees" seek solace in remote rural
locations and rapidly disappearing radiofrequency-
free "white zones" around the world—no easy
task given the expansion of community WMAX
and cellular networks, as well as the international
rollout of the smart grid.
What we should all learn as a takeaway from
EHS is this: These highly sensitive individuals
may be the proverbial "canaries in the coal mine."
If they can sense physical danger around our
wireless technologies and electrical fields, maybe
we should all heed the warning, as well.
So, what can we do about this?
If we're Paleo, that means we bypass the sugary-
sweet, neon-colored candies in the grocery store.
We skip the industrial foods in favor of our own
organically grown, locally sourced, unprocessed
meals. Retailers may line their shelves with
chemically infused, mega-marketed industrial foods,
personal care and home products, but that doesn't
mean we have to buy them, stock our pantries with
them or use them. So, the same self-mandated
bio-individual control can be implemented with
EMF devices and wireless technologies. Just
because it's everywhere, just because "everyone
else is doing it," and just because these products
don't come with a literal skull and crossbones label,
doesn't mean any of this is actually healthy for
us, nor does it mean that we "should" overindulge
when merely given the opportunity.
"Sensitive or not, anyone can benefit from
reducing these EMFs in the home environment.
It's a holistic health perspective... EMF is a
stressor on the body. Just like chemicals in the
environment, or the stress on our jobs, you want
to create a space where all of those stressors are
as low as possible, and that frees the body up to
do what it is supposed to do."
—Matthew Waletzke, BBEC, Healthy Dwellings
Good (and bad) vibrations
The seductive lure of modern technology
keeps us in this constant, unnatural feed cycle of
EMF hyper-exposure. As MIT Professor Sherry
Turkle writes in Reclaiming Conversation, "We
turn to our phones instead of each other. We
readily admit we would rather send an electronic
message or mail than commit to a face-to-face
meeting or a telephone call."7 Sure, our digital
technologies may be harming our interpersonal
relationships, but what if they're also harming
our bodies? We are here to nourish ourselves,
in mind, body and spirit. We may be living in
the "smart tech" era, but our ancestors had
some mega-smarts of their own. It's time we
disconnect from the constant barrage of artificial
EMFs, and reconnect to the natural rhythms
and vibrations our Earth intended. There is a
difference between surviving and thriving. And
we want to thrive.4'if
Alison Main is a freelance writer with a focus on natural living, clinical nutrition, and EMF
safety. Echoing her own wellness journey, she is passionate about helping others heal from
environmental illness through holistic tenets and Paleo philosophies. UncommonAlchemy.me
REFERENCES
1. Sage C, Carpenter DO. "Biolnitiative Report: A
Rationale for a Biologically-based Public Exposure
Standard for Electromagnetic Radiation." Biolnitiative
Working Group. 2012. http://www.bioinitiative.org/
2. Durant, J. The Paleo Manifesto: Ancient Wisdom for
Lifelong Health. Harmony Books, 2013.
3. Blank M. Overpowered: What Science Tells Us
About the Dangers of Cell Phones and Other WiFi-Age
Devices. Seven Stories Press, 2014.
4. Havas M. "Radiation from wireless technology af-
fects the blood, the heart, and the autonomic nervous
system." Reviews on Environmental Health. 28.2-3
(2013): 75-84. doi: 10.1515/reveh-2013-0004.
5. Blank M, Goodman R. "Electromagnetic fields
stress living cells." Pathophysiology. 16 (2009): 71-8.
6. Mallery-Blythe, E. "Electromagnetic Hypersensi-
tivity A Summary." 2014. http://electromagnetichealth.
org/electromagnetic-health-blog/ehs-mallery-blythe/
7. Turkle S. Reclaiming Conversation: The Power of
Talk in a Digital Age. Penguin Press, 2015.
8. Safe Living Technologies Inc. "EMR Exposure
Guidelines." http ://ww w. sit .c o/Ed u cati on/E M R- Exp o-
sureGuidelines.aspx
9. Buchner K, Eger, H. "Changes of Clinically
Important Neurotransmitters under the Influence
of Modulated RF Fields: A Long-term Study under
Real-life Conditions." Umwelt-Medizin-Gesellschaft.
24.1 (2011): 44-57.
10. Federal Communications Commission. "Radiofre-
quency Safety." https://www.fcc.gov/general/radio-fre-
qu en cy-safety-0
11. World Health Organization (WHO). "Electro-
magnetic Fields and Public Health. Electromagnetic
hypersensitivity."http: //www.wh o.int/peh-emf/publica-
tions/facts/fs296/en/
TIPS & TRICKS
GET SMART
ABOUTYOUR
SMARTPHONE.
©Never hold your
smartphone next to
your head. When
talking, use a wired
air tube headset or
speaker option, and
place the phone
away from your
body.
©Only use your
smartphone when
you have a good
signal. The weaker
the signal, the more
radiofrequency is
used to connect,
which increases
your exposure.
©Text more than
talk. Smartphones
use less radiation to
send a text versus
talking.
©Never put your
smartphone in your
pocket or directly
on your body. And
if you must, then
keep it turned off.
©Use a corded
landline at home
instead of your
smartphone when
making calls.
©Pregnant women
should keep their
smartphones (and
all wireless devices)
away from their
abdomen. New
parents? Move that
device away from
your baby's head
and body.
©Meet up
IRL! Drop your
smartphone, go
outside and
connect in person
when you can.
Reference:
Davis D. Disconnect:
The Truth About Cell
Phone Radiation.
Writers House LLC,
2013.
50 Aug/Sept2016
-------
"Children are not little adults and
are disproportionately impacted by all
environmental exposures, including cell
phone radiation. Current FCC standards do
not account for the unique vulnerability and
use patterns specific to pregnant women
and children."
—American Academy of Pediatrics, 2013
Don't run with scissors. Don't talk to
strangers. Don't play with matches.
Don't drink and drive. Don't do drugs.
Parents are eternally concerned about their
children's safety. From infancy to adolescence,
children are developing humans—physically,
behaviorally and intellectually. To emerge as
healthy, well-adjusted adults, kids need their
parents' protection. And when it comes to children
and wireless-tech safety, there's a lot parents
need to know.
What is Wi-Fi, Really?
We can't see Wi-Fi with the naked eye—but
we're surrounded by it, 24/7. Wreiess technology
encompasses our cell phones, tablets, cell towers,
smart meters, wireless-enabled laptops, baby
monitors, gaming consoles, e-readers, virtual-reality
toys and the emerging Internet of Everything.
The term "W-Fi" sounds harmless enough, right?
Its utterance like a baby's coo or cartoon slang. It
alliteratively conjures "Sci-Fi" flying cars and time
travel. But let's call wireless tech what it really is—
radiofrequency radiation, also called microwave
radiation.
Technically speaking, "Wi-Fi deploys pulse-
modulated microwave radiation (within the larger
radiofrequency spectrum) with a carrier frequency
that is similar to that used by a microwave oven
(about 2.45 gigahertz)."5 In 2011, the International
Agency for Research on Cancer classified
radiofrequency radiation as "possibly carcinogenic
to humans." This is the same category as lead, DDT,
and other pesticides.
-------
Who's at Risk?
Science shows that wireless radiation can cause a gamut of biological effects, from cancer and neurodegenerative
diseases to birth defects and infertility. And yet, outdated world-wide safety regulations only consider short-term heating
(i.e., thermal) and shock effects. They don't consider the chronic, non-thermal exposures of our wireless tech world.2
As a human population, we are all at risk from environmental exposures and toxins. But, the most vulnerable are children,
the developing fetus and pregnant women. A child's brain, nervous system and immune system are in development at these
critical periods. Despite this, "there is a growing, unchecked and unregulated availability of a range of transmitting equipment
specifically aimed at parents of babies and young people."2
Yes, this includes that wireless baby monitor (2 inches from your baby's head), that working cell phone in your toddler's
mouth, or that tablet broadcasting under your teen's pillow—all these seemingly innocuous devices can be hazardous to
your child's health.
"Around the world we are paying the price now for having delayed actions on
tobacco and asbestos after insisting on human harm before taking action. We
cannot afford to wait for definitive proof of human risks from radiation emitted
by wireless transmitting devices before taking steps to reduce exposures. The
absence of evidence of hazard is not proof of safety"—says Dr. Devra Davis,
president of the Environmental Health Trust and visiting professor at the Hebrew
University Hadassah Medical School and Ondokuz Mayis University, Turkey.
AMERICAN ACADEMY
OF PEDIATRICS CELL PHONE
SAFETY TIPS FOR FAMILIES
©Use tex{ messaging when possible,
and use cell phones in speaker
mode or with the use of hands-free
kits.
©Avoid carrying your phone against
the body like in a pocket, sock or
bra. Cell phone manufacturers
can't guarantee that the amount of
radiation you're absorbing will be at
a safe level.
©If you plan to watch a movie on
your device, download it first,
then switch to airplane mode
while you watch in order to avoid
unnecessary radiation exposure.
© Keep an eye on your signal
strength (i.e., how many bars you
have). The weaker your cell signal,
the harder your phone has to work
and the more radiation it gives off.
©Avoid making calls in cars,
elevators, trains and buses. The
cell phone works harder to get a
signal through metal, so the power
level increases.
©Remember that cell phones are not
toys or teething items.
Read more tips at:
HealthyChildren.org
REFERENCE:
+American Academy of Pediatrics. "Cell Phone
Radiation & Children's Health: What Parents
Need to Know." https://www.healthychildren.
org/English/safety-prevention/all-around/Pag-
es/Cell-Phone-Radiation-Childrens-Health.
aspx
Who is SAM?
Standing for "Specific Anthropomorphic Mannequin," SAM is a plastic model
of a head, which, in 1989, was made to represent the top 10 percent of U.S.
military recruits. That's a 220-pound man with a pretty large head.
SAR, another relevant acronym, stands for "Specific Absorption Rate"—a
measure of tissue-radiation exposure.9 The cell phone industry currently uses
SAM for compliance testing against safety guidelines and to certify the SAR for
mobile phone users.
However, research shows that a smaller head than SAM will absorb
significantly more radiofrequency radiation.12 Obviously, children's smaller heads
have a shorter distance to the brain center. Also, children's skulls and ears are
thinner, allowing radiation to penetrate farther. And children's brains contain
more fluid, and thus absorb more radiation.412
The SAR for a 10-year-old is up to 153 percent higher than the SAR for the
SAM model,1 yet there is no pre-market certification testing for SAR on a child-
equivalent head (or an adult's head smaller than SAM). And "when electrical
properties are considered, a child's head's absorption can be over two times
greater, and absorption of the skull's bone marrow can be 10 times greater
than adults."1
-I A
sid
An example of a test position used on tne specific Anthropomorphic
Mannequin, in this case with cell phone in tilted position on the left side.
+ https://biomedical-engineering-online.biomedcentral.co m/a rticles/10.1186/1475-925X-3-34.
What Does the Latest Science Say?
In May 2016, the National Toxicology Program released partial findings of
their $25 million study on cell phones and cancer. The results showed that
exposure to wireless radiation significantly increases the prevalence of highly
malignant heart and brain cancers in rodents.
"The findings of brain tumors (gliomas) and malignant Schwann cell tumors
of the heart in the NTP study, as well as DNA damage in brain cells of exposed
animals, present a major public health concern because these tumors occurred
in the same types of cells that had been reported to develop into tumors (gliomas
and acoustic neuromas) in epidemiological studies of adult cell phone users,"
Feb/Mar 2017 33
-------
SHOW US THE FINE PRINT
Cell phone companies issue
instructions to keep wireless devices
at specified distances from our bodies.
So, if you've got your mobile on your
ear, or your tablet on your abdomen,
you may be exposed to higher
radiation levels than those tested
as safe. But this information is often
buried in the fine print, sometimes
even buried in the device itself.
Here's a sampling of
manufacturer instructions:
C Baby Monitor Motorola MBP33
"The Baby unit shall be installed
and used such that parts of the
user's body other than the hands
are maintained at a distance of
approximately 20 centimeters (8
inches) or more."
C Samsung 3G Laptop
"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 exposure.
To ensure compliance with
radiofrequency exposure guidelines
the Notebook PC must be used
with a minimum of 20.8 centimeters
antenna separation from the body."
9 iPhone 6
"To reduce exposure to
radiofrequency energy, use a
hands-free option, such as the
built-in speakerphone, the supplied
headphones, or other similar
accessories. Carry iPhone at least
5 millimeters away from your body
to ensure exposure levels remain at
or below the as tested levels. Cases
with metal parts may change the
radiofrequency performance of the
device, including its compliance with
radiofrequency exposure guidelines,
in a manner that has not been tested
or certified."
Find your device at:
ShowTheFinePrint.orfJ
REFERENCE:
+Show Us The Fine Print. http://showthefine-
print.org/
explains Ron Melnick, Ph.D., senior toxicologist and director of Special Programs in the
Environmental Toxicology Program at the National Institute of Environmental Health
Sciences, National Institutes of Health, now retired.
In response to these results, the American Academy of Pediatrics issued new
recommendations for reducing exposure to cell phones and wireless devices. In an AAP
press release, Jennifer A. Lowry—M.D. and chair of the AAP Council on Environmental
Health Executive Committee—said: "They're not toys. They have radiation that is
emitted from them and the more we can keep it off the body and use (the phone) in
other ways, it will be safer."7
Microwave Tech in Schools
Computers and the Internet are vital learning tools. But the crux of the matter with
wireless tech is safety. And this rampant technology has never been tested for the long-
term, overlapping, cumulative exposures experienced in today's schools by the most
vulnerable population: children.
Students in schools are bombarded with wireless radiation from every conceivable
angle: their own personal devices, the devices of all nearby users in surrounding
classrooms, wireless devices in the school itself (routers, printers, smart boards,
etc.), and transmitters (i.e., cell towers) in close proximity outside the school. Plus, to
simultaneously handle the hundreds of devices needed to conduct its daily activities,
schools typically install stronger Wi-Fi systems. Most residential homes now have Wi-
Fi hubs and multiple devices per household member—meaning that when kids return
home, they get no respite.
"They're not toys. They have radiation that is emitted from
them and the more we can keep it off the body and use (the
phone) in other ways, it will be safer."
Consequently, in schools across the world, kids are getting sick from this
unprecedented level of wireless exposure. Dafna Tachover, founder of We Are The
Evidence—an advocacy group for those injured by wireless technology—is an attorney
in both Israel and New York. She regularly works with children and parents who have
developed electro-sensitivity to wireless tech. Symptoms commonly reported include:
headaches, nausea, vomiting, cognitive problems, tingling, severe exhaustion, noise
sensitivity, sinus pressure and nose bleeds.
In a case submitted to the Israeli Supreme Court, Tachover presented 200 children,
from six schools, who had become sick from wireless tech. In one particular school, 70
children from three classes started having symptoms after a second wireless router was
installed. Tachover uncompromisingly states: "Our school systems are creating the most
intense environment of radiation, and they're doing it to the most sensitive population. The
harm has already been proven. There's an epidemic of sickness in the schools."
After significant efforts, in April 2016 the city of Haifa, in Israel, ordered all Wi-Fi to be
disconnected in schools. In a press release, Haifa's mayor, Yona Yahav, is cited saying,
"When there is a doubt, when it comes to our children, there is no doubt."
This is a step in the right direction, but internationally there continue to exist countless
groups of concerned parents and researchers urging school administrations to adopt
best tech practices. Schools can get the same educational benefits from a wired
(fiber-optic and Ethernet) network, and in doing so, they wouldn't be putting an entire
generation of kids at risk.
There's No Wi-Fi in Narnia
Some schools are now rolling out virtual-reality curricula, like the Google Expeditions
Pioneer Program. Sure, it sounds cool to take a trip to Mars without leaving the
classroom. But, hold that virtual-reality visor up to a child's eyes, and what you've got
is a cell phone encased in a cardboard box, beaming microwave radiation directly into
a child's brain.
Whether used in school or at home, virtual-reality toys have never been pre-
market tested for health consequences. Dr. Mary Redmayne, a researcher at Monash
University in Australia, explains: "Children's brains are not fully myelinated and eyes
absorb radiation readily due to their high water content. Placing a two-way microwave
radiating device directly in front of young eyes is not a wise choice in my opinion."9
34 Feb/Mar 2017
-------
Schools can get the same educational benefits from a wired
(fiber-optic and Ethernet) network, and in doing so, they
wouldn't be putting an entire generation of kids at risk.
Theodora Scarato—Environmental Health Trust's director of Public Affairs and
Educational Resources—speaks to another angle regarding digital play. "The research
shows that simpler is often better in terms of toys. When you have a bunch of building
blocks, then a child can use their own creativity to imagine what these blocks are. But
when it's already pre-scripted, the child is using less creativity, because the choice has
already been taken away. You can only be as creative as the program application is.
And that is stifling. When I listen to children tell me about what they imagine in their
minds, I'm always blown away. A computer's drop down menu can't even come close."
Tech Addiction
"A representative survey of American tweens (8- to 12-year-olds) and teens (13- to
18-year-olds), documented that outside of school and homework, tweens spend almost
six hours per day (5:55 hours) and teens spend almost nine hours per day (8:56 hours)
using media."11
While "Tech Addiction" is not yet classified as a disorder in The Diagnostic and Statistical
Manual of Mental Disorders, the phenomenon is nonetheless being investigated by a host
of psychologists and researchers. Clinical psychologist Catherine Steiner Adair sheds light
on the impact of the omnipresent glowing screen within the family dynamic: "Everything
a baby needs from its environment between birth and 2 years comes from people, from
relationships with people and interactions with the environment—physically exploring,
playing, crawling, and interacting with others. When we triangulate our relationship with
our babies and tech, we compromise that essential connection."10
Further, "the development of empathy is a critical step in early childhood and over
a lifetime. Empathy is the caring glue that creates our humanity, our compassion."10
We learn empathy through direct human contact. This is thwarted when kids correlate
personal identity with their Xbox avatar or their Facebook status. The blood in Halo
isn't real; sad-face emojis aren't tears. When disconnected from real-life interaction,
kids don't learn accountability for negative actions or mean words. What kind of society
will emerge when our technology-obsessed youth is decoupled from the tangibility of
human consequences?
Like a Kid in a Candy Store
An apt allegory might be Roald Dahl's Charlie and the Chocolate Factory. Faced with
his tempting, addictive, untested, fantastical inventions, the story's overindulgent kids
were squeezed, colorized, ballooned and miniaturized, while their parents stood idly by
and watched—all for Mr. Wonka's industrial benefit and profit.
Kids today should not literally be left to their own devices. The proliferation of wireless
radiation is the biggest public health experiment ever conducted, and it's happening on
an entire generation of children. Do you want to experiment on your kids?
REFERENCES:
+1. Gandhi OP, Morgan LL, de Salles AA, Han Y, Herber-
man RB, et al. "Exposure Limits: The underestimation
of absorbed cell phone radiation, especially in children."
Electromagnetic Biology And Medicine 31.1 (2012):
34-51.
+ 2. Redmayne, M. "International policy and advisory re-
sponse regarding children's exposure to radio frequency
electromagnetic fields (RF-EMF)." Electromagnetic
Biology and Medicine 35.2 (2016): 176-85.
+ 3. Morris RD, Morgan LL, Davis DL. "Children Absorb
Higher Doses of Radio Frequency Electromagnetic Ra-
diation from Mobile Phones Than Adults." IEEE Access 3
(September 2015): 2379-2387.
+ 4. Gandhi, OR "Yes the Children Are More Exposed to
Radiofrequency Energy From Mobile Telephones Than
Adults." IEEE Access 3 (June 2015): 985-988.
+ 5. Carpenter, DO. "Human disease resulting from expo-
sure to electromagnetic fields." Reviews on Environmen-
tal Health 28.4 (2013): 159-72.
+ 6. American Academy of Pediatrics Letter to the Federal
Communications Commission calling for a review of
RF guidelines. 29 August, 2013. https://ecfsapi.fcc.gov/
file/7520941318.pdf
+ 7. AAP responds to study showing link between cell
phone radiation, tumors in rats. 27 May, 2016. http://
Subscribe at: PaleoMagOnline.com
www. aappubl ications. org/news/2016/05/27/Can-
cer052716
+ 8. Wyde M, Cesta M, Blystone C, Elmore S, Foster
P, et al. "Report of Partial Findings from the National Toxi-
cology Program Carcinogenesis Studies of Cell Phone
Radiofrequency Radiation in Hsd: Sprague Dawley SD
rats (Whole Body Exposures)." National Institute of Envi-
ronmental Health Sciences. Draft 23 June, 2016.
+ 9. "Stop Untested Microwave Radiation of Children's
Brains and Eyes EHT Scientists Urge Google." Environ-
mental Health Trust, http://ehtrust.org/stop-untested-mi-
crowave-radiation-of-childrens-brains-and-eyes-eht-sci-
e ntists- u rg e-g oog le/
+ 10. Steiner-Adair, C. The Big Disconnect: Protecting
Childhood and Family Relationships in the Digital Age.
Harper, 2013.
+ 11. 'Technology Addiction: Concern, Controversy, and
Finding Balance." Common Sense Media. 2016. https://
www. commonsensemedia.o rg/resea rc h/tech n o log y-ad -
diction-concern-controversy-and-finding-balance.
+ 12 . Fernandez-Rodriguez CE, De Salles AAA, Davis DL,
"Dosimetric Simulations of Brain Absorption of Mobile
Phone Radiation—The Relationship Between psSAR and
Age." IEEE Access 3 (Nov 2015): 2425-2430.
10 STEPS FOR PREGNANT
WOMEN TO LIMIT THEIR
WIRELESS RADIATION
EXPOSURE: ^
^ Avoid carrying your cell phone on
your body.
Avoid holding any wireless device
against your body when in use.
^ Use your cell phone on speaker
setting or with an "air tube"
headset.
^ Avoid using your wireless device in
cars, trains or elevators.
@1 Avoid cordless phones, especially
where you sleep.
^Whenever possible, connect to the
Internet with wired cables.
^ When using Wi-Fi, connect only
to download, then disconnect and
disable W-Fi.
@ Avoid prolonged or direct exposure
to nearby Wi-Fi routers.
Q Unplug your home W-Fi router
when not in use.
Sleep as far away from wireless
utility meters (i.e., "smart meters")
as possible.
REFERENCE:
+The Baby Safe Project. "Ten VMays to Re-
duce Your Wireless Exposure." http://www.
babysafeproject.org/reduce-your-exposure.
html.
-------
Environmental Pollution 242 (2018) 643 658
Contents lists available at
Environmental Pollution
journal homepage:
Thermal and non-thermal health effects of low intensity non-ionizing
radiation: An international perspective^
Dominique Belpomme a'b' \ Lennart Hardell a'c'2, Igor Belyaev a'd'e-Ernesto Burgio a'f,
David O. Carpenter a'g-h- *¦1
* European Cancer Environment Research Institute, Brussels, Belgium
b Paris V University Hospital, Paris, France
c Department of Oncology, Orebro University Hospital, Faculty of Medicine, Orebro, Sweden
d Department of Radiobiology, Cancer Research Institute, Biomedical Research Center, Slovak Academy of Science, Bratislava, Slovak Republic
e Laboratory of Radiobiology, Institute of General Physics, Russian Academy of Science, Moscow, Russian Federation
c Instituto Scientifico Biomedico Euro Mediterraneo, Mesagne, Italy
g Institute for Health and the Environment, University at Albany, Albany, NY, USA
h Child Health Research Centre, The University of Queensland, Faculty of Medicine, Brisbane, Australia
ABSTRACT
Exposure to low frequency and radiofrequency electromagnetic fields at low intensities poses a signif-
icant health hazard that has not been adequately addressed by national and international organizations
such as the World Health Organization. There is strong evidence that excessive exposure to mobile
phone-frequencies over long periods of time increases the risk of brain cancer both in humans and
animals. The mechanism(s) responsible include induction of reactive oxygen species, gene expression
alteration and DNA damage through both epigenetic and genetic processes. In vivo and in vitro studies
demonstrate adverse effects on male and female reproduction, almost certainly due to generation of
reactive oxygen species. There is increasing evidence the exposures can result in neurobehavioral dec-
rements and that some individuals develop a syndrome of "electro-hypersensitivity" or "microwave
illness", which is one of several syndromes commonly categorized as "idiopathic environmental intol-
erance". While the symptoms are non-specific, new biochemical indicators and imaging techniques allow
diagnosis that excludes the symptoms as being only psychosomatic. Unfortunately standards set by most
national and international bodies are not protective of human health. This is a particular concern in
children, given the rapid expansion of use of wireless technologies, the greater susceptibility of the
developing nervous system, the hyperconductivity of their brain tissue, the greater penetration of
radiofrequency radiation relative to head size and their potential for a longer lifetime exposure.
© 2018 Published by Elsevier Ltd.
ARTICLE INFO
Article history:
Received 6 April 2018
Received in revised form
31 May 2018
Accepted 4 July 2018
Available online 6 July 2018
1. Introduction
Electromagnetic fields (EMFs) are packets of energy that have no
mass. They vary in frequency and wavelength. At the high end of
the electromagnetic spectrum there are cosmic and X-rays that
have enough energy to cause ionization, and therefore are known
* This paper has been recommended for acceptance by Payam Dadvand.
* Corresponding author. Institute for Health and the Environment, University at
Albany, Renneselaer, NY 12144, USA.
E-mail address: dcarpciitcrSialbaiiy.edu (D.O. Carpenter).
1 These authors contributed equally to this work.
2 Current address: The Environment and Cancer Research Foundation, Orebro,
Sweden.
Iittps://doiorg/10.101 S/j.envpo 1.2018.07.019
0269-7491/© 2018 Published by Elsevier Ltd.
as ionizing EMFs. Below in frequency and energy are ultraviolet,
visible light and infrared EMFs. Excessive exposure to ultraviolet
EMFs poses clear danger to human health, but life on earth would
not be possible without visible light and infrared EMFs. Below these
forms of EMF are those used for communications (radiofrequency
or RF-EMFs, 30 kHz-300 GHz) and those generated by electricity
(extremely low-frequency or ELF-EMFs, 3 Hz-3 kHz). These EMFs do
not have sufficient energy to directly cause ionization, and are
therefore known as non-ionizing radiation. RF-EMFs at sufficient
intensity cause tissue heating, which is the basis of operation of the
microwave oven. However the question to be addressed here is
human health effects secondary to exposures to non-ionizing EMFs
at low intensities that do not cause measureable heating.
-------
644
D. Belpomme et al. / Environmental Pollution 242 (2018) 643—658
In spite of a large body of evidence for human health hazards
from non-ionizing EMFs at intensities that do not cause measure-
able tissue heating, summarized in an encyclopedic fashion in the
Bioinitiative Report (www.bioinitiative.org), the World Health Or-
ganization (WHO) and governmental agencies in many countries
have not taken steps to warn of the health hazards resulting from
exposures to EMFs at low, non-thermal intensities, nor have they
set exposure standards that are adequately health protective. In
2001 the International Agency for Research on Cancer (1ARC, 2002),
part of the WHO, declared ELF-EMFs to be "possibly carcinogenic to
humans", and in 2011 they made a similar declaration for RF-EMFs
(Baan et al., 2011; 1ARC, 2013). The classification of RF-EMFs as a
"possible" human carcinogen was based primarily on evidence that
long-term users of mobile phones held to the head resulted in an
elevated risk of developing brain cancer. One major reason that the
rating was not at "probable" or "known" was the lack of clear evi-
dence from animal studies for exposure leading to cancer. The US
National Toxicology Program has released preliminary results of a
study of long term exposure of rats to cell phone radiation which
resulted in a statistically significant increase in brain gliomas, the
same cancer found in people after long-term cell phone use, and
schwannomas, a tumor similar to the acoustic neuroma also seen
after intensive mobile phone use (Wyde et al., 201(3). Similar results
in rats have been reported in an independent study at the Ram-
azzini Institute with exposures similar to those from a mobile
phone base station (Falcioni et al., 2018). This evidence, in
conjunction with the human studies, demonstrates conclusively
that excessive exposure to RF-EMF results in an increased risk of
cancer. In light of this new evidence for cancer in rodents in
response to prolonged exposure to mobile phone frequencies, the
IARC rating should be raised at least to "probable" (Group 2A) if not
"known" (Group 1).
Unfortunately the International EMF Project of the WHO, which
is part of the Department of Public Health, Environment and Social
Determinants of Health in Geneva, has consistently minimized
health concerns from non-ionizing EMFs at intensities that do not
cause tissue heating (WHO, 2014). In this regard WHO has failed to
provide an accurate and human health-protective analysis of the
dangers posed to health, especially to the health of children,
resulting from exposure to non-thermal levels of electromagnetic
fields. The Department of Public Health, Environment and Social
Determinates of Disease takes its advice on the issues related to
human health effects of non-ionizing EMFs from the International
Commission on Non-ionizing Radiation Protection (ICNIRP). Almost
all members of the core group preparing the new Environmental
Health Criteria (EHC) document for the WHO are members of
ICNIRP (Starkey, 201(3; Hardell, 2017), a non-goverment organiza-
tion (NGO) whose members are appointed by other members. In
spite of recent efforts to control for conflicts of interest, ICNIRP has a
long record of close associations with industry (Maisch, 2006).
When queried as to why the WHO would take recommendations
from such a group, WHO staff replied that ICNIRP is an official NGO
which works closely with the WHO. Why this should exclude other
scientific research groups and public health professionals is un-
clear, particularly since most members of ICNIRP are not active
researchers in this field. We are particularly concerned that a new
WHO EHC document on RF-EMFs is scheduled to be released soon,
and that the members of the EHC Core Group and the individuals
whose assistance has been acknowledged are known to be in denial
of serious non-thermal effects of RF-EMFs in spite of overwhelming
scientific evidence to the contrary (Starkey, 201(3; Hardell, 2017).
Others have dismissed the strong evidence for harm from ELF-
and RF-EMFs by arguing that we do not know the mechanism
whereby such low energetic EMFs might cause cancer and other
diseases. We have definitive evidence that use of a mobile phone
results in changes in brain metabolism (Volkow et al., 2011). We
know that low-intensity ELF- and RF-EMFs generate reactive oxy-
gen species (ROS), alter calcium metabolism and change gene
expression through epigenetic mechanims, any of which may result
in development of cancer and/or other diseases or physiological
changes (see www.bioinitiative.org for many references). We do
not know the mechanisms behind many known human carcino-
gens, dioxins and arsenic being two examples. Given the strength of
the evidence for harm to humans it is imperative to reduce human
exposure to EMFs. This is the essence of the "precautionary
principle".
There are a number of reasons for our concern. In the past the
major exposure of the general population to RF-EMFs came from
radio and television signals. Now there are almost as many mobile
phones as there are people in the world, all of them being exposed
to RF-EMFs. There are mobile phone towers everywhere, and in
many developing countries there are no land-lines that allow
communication without exposure to RF-EMFs. There is rapid
movement in many developed countries to place small cell trans-
mitting devices (5G) operating at higher frequencies (24—70 GHz)
every approximately 300 m along sidewalks in residential neigh-
borhoods. There are other significant sources of exposure, coming
from WiFi, smart meters and soon from automobiles operating
without a human driver. Therefore human exposure has increased
dramatically in recent years, and continues to increase rapidly.
While we already are seeing harm from these exposures, the degree
of harm will only increase with time because of the latency that is
known to occur between exposure and development of diseases
such as cancer.
Standards for protection of human health from EMFs vary
greatly around the world. Many countries set standards based on
the false assumption that there are no adverse health effects of RF-
EMFs other than those that are caused by tissue heating. This is the
case in North America, Australia and some European countries.
Many countries from the former Soviet Union have much more
restrictive standards. However information from cellular and hu-
man studies show biological effects that constitute hazards to hu-
man health at exposure levels that are often exceeded during daily
life.
This report follows a recent non-official meeting in Geneva with
WHO representives, where the authors urged WHO to acknowlege
low intensity effects of ELF-EMFs and non-thermal health effects of
RF-EMFs. This report does not attempt to present a complete
overview of the subject [see the Bioinitiative Report (www.
bioinitiative.org) for that] but rather to provide a holistic picture
of the processes explaining most or all of the adverse effects of EMF
exposures. It summarizes the evidence for cancer resulting from
exposure to EMFs, and identifies other diseases or pathological
conditions such as Alzheimer's disease and hypofertility that have
been shown to be associated with excesive exposure to low-
intensity EMFs. We also focus on electrohypersensitivity (EHS) in
both children and adults and cognitive and behavioural problems in
children resulting from the increasing exposure. Finally we discuss
what is known about the mechanisms whereby non-thermal EMF
radiation can cause disease with special reference to EMF-related
free radical production and epigenetic and genetic mechanisms.
2. Mobile phone use and the risk for glioma, meningioma
and acoustic neuroma
The brain is the main target for exposure to RF-EMF radiation
during use of handheld wireless phones, both mobile and cordless
phones (Cardis et al., 2008; Gandhi et al., 2012). An increased risk
for brain tumors has been of concern for a long time. The results of
the Swedish National Inpatient Register have documented an
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645
increasing incidence of brain tumors in recent years (Carlberg and
Hardell, 2017). In May 2011 RF radiation in the frequency range
30 kHz—300 GHz was evaluated to be a Group 2B, i.e. a "possible"
human carcinogen, by IARC (Baan et a!., 2011; 1ARC, 2013). This was
based on an increased risk for glioma and acoustic neuroma in
human epidemiological studies. In the following an updated sum-
mary is given of case-control studies on brain and head tumors;
glioma, meningioma and acoustic neuroma. The Danish cohort
study on 'mobile phone users' (Johansen et a!, 2001; Schiiz et a!.,
2006) is not included due to serious methodological shortcom-
ings in the study design, including misclassification of exposure
(see Soderqvist et a!., 2012a).
2.1. Glioma
Glioma is the most common malignant brain tumor and rep-
resents about 60% of all central nervous system (CNS) tumors. Most
of these are astrocytic tumors that can be divided into low-grade
(WHO grades I-II) and high-grade (WHO grades III-IV). The most
common glioma type is glioblastoma multiforme (WHO grade IV)
with peak incidence in the age group 45—75 years and median
survival less than one year (Ohgaki and Kleihues, 2005). Three
research groups have provided results in case-control studies on
glioma (interphone, 2010; Coureau et al, 2014; Hardell and
Carlberg, 2015). Hardell and colleagues have published results
from case-control studies on use of wireless phones and brain tu-
mor risk since the end of the 1990s (Hardell et al., 1990; for more
discussion see Carlberg and Hardell, 2017).
A random effects model was used for meta-analyses of pub-
lished studies, based on test for heterogeneity in the overall group
("all mobile"). Note that only the Hardell group also assessed use of
cordless phones. Thus their reference category included cases and
controls with no use of wireless phones in contrast to the other
studies investigating only mobile phone use. In "Fable 1 results for
highest cumulative use in hours of mobile phones is given. All
studies reported statistically significant increased risk for glioma
and the meta-analysis yielded an odds ratio (OR) = 1.90 [95% con-
fidence interval (CI) = 1.31—2.76]. For ipsilateral mobile phone use
the risk increased further to OR = 2.54 (95% CI = 1.83—3.52) in the
meta-analysis based on 247 exposed cases and 202 controls.
Carlberg and Hardell (2014) found shorter survival in patients
with glioblastoma multiforme associated with use of wireless
phones compared with patients with no use. Interestingly mutation
of the p53 gene involved in disease progression has been reported
in glioblastoma multiforme in patients with mobile phone use >3 h
per day. The mutation was statistically significantly correlated with
shorter overall survival time (Akhavan-Sigari et al, 2014). Further
support for the increased risk of glioma associated with mobile
phone use has been obtained in additional analyses of parts of the
Interphone study (Cardis et al, 2011; Grell et al, 201(3; Momoli
et al, 2017).
2.2. Meningioma
Meningioma is an encapsulated, well-demarked and rarely
malignant tumor. It is the most common benign tumor and ac-
counts for about 30% of intracranial neoplasms. It develops from the
pia and arachnoid membranes that cover the CNS. It is slowly
growing and gives neurological symptoms by compression of
adjacent structures. The most common symptoms are headaches
and seizures. The incidence is about two times higher in women
than in men. Meningioma develops mostly among middle aged and
older persons (Cea-Soriano et al, 2012). Carlberg and Hardell
(2015) included meningioma in their case-control studies. The re-
sults of the meta-analysis for cumulative exposure in the highest
category are given in "Fable 2. In total there was an increased (but
not statistically significant) risk for cumulative exposure but the
increased risk was statistically significant for ipsilateral use of
mobile phones (OR = 1.49, 95% CI = 1.08—2.06).
2.3. Acoustic neuroma
Acoustic neuroma, also called vestibular schwannoma, is a
benign tumor located on the eighth cranial nerve from the inner ear
to the brain. It is usually encapsulated and grows in relation to the
auditory and vestibular portions of the nerve. It grows slowly and
due to the narrow anatomical space may give compression of vital
brain stem structures. First symptoms of acoustic neuroma are
usually tinnitus and hearing problems. Results for use of mobile
phones in Interphone (2011) and Hardell et al (2013) are given in
"Fable 3. Statistically significant increased risk was found for cu-
mulative ipsilateral use >1640 h yielding OR = 2.71 (95%
CI = 1.72-4.28).
The study by Moon et al (2014) was not included in the meta-
analysis because data on cumulative mobile phone use with
numbers of cases and controls were not given. Support of an
increased risk was seen in the case-case part of the study (Moon
et al, 2014) and also in the report by Sato et al (2011). Pettersson
et al (2014) made a case-control study on acoustic neuroma in
Sweden not overlapping the Hardell et al (2013) study. An
increased risk for the highest category of cumulative use of both
mobile phone (>680 h OR= 1.46, 95% CI = 0.98—2.17) and cordless
phone (>900 h OR =1.67, 95% CI = 1.13—2.49) was found.Petters-
son et al (2014) was not included in the meta-analysis due to the
many scientific shortcomings in the study, e.g. laterality analysis
was not made for cordless phone, the numbers in the laterality
analysis for mobile phone are not consistent in text and tables and
the 'unexposed' reference category included subjects using either
mobile and cordless phone, which is clearly not correct (Hardell
and Carlberg, 2014).
Table 1
Numbers of exposed cases (Ca) and controls (Co) and odds ratio (OR) with 95% confidence interval (CI) for glioma in case-control studies in the highest category of cumulative
hours of mobile phone use.
All
Ipsilateral
Ca/Co
OR
95% CI
Ca/Co
OR
95% CI
Interphone 2010
Cumulative use >1640h
210/154
1.40
1.03-1.89
100/62
1.96
1.22-3.16
Coureau. et al., 2014
Cumulative use >896 h
24/22
2.89
1.41-5.93
9/7
2.11
0.73-6.08
Carlberg and Hardell, 2015
Cumulative use >1640h
211/301
2.13
1.61-2.82
138/133
3.11
2.18-4.44
Meta-analysis
Longest cumulative use
445/477
1.90
1.31-2.76
247/202
2.54
1.83-3.52
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D. Belpomme et al. / Environmental Pollution 242 (2018) 643—658
Table 2
Numbers of exposed cases (Ca) and controls (Co) and odds ratio (OR) with 95% confidence interval (CI) for meningioma in case-control studies in the highest category of
cumulative hours of mobile phone use.
All
Ca/Co
Ipsilateral
OR
95% CI
Ca/Co
OR
95% CI
Interphone 2010
Cumulative use >1640h
Coureau et al., 2014
Cumulative use >896 h
Carlberg and Hardell 2015
Cumulative use >1640h
Meta-analysis
Longest cumulative use
130/107
13/9
141/301
284/417
1.15
2.57
1.24
1.27
0.81-1.62
1.02-6.44
0.93-1.66
0.98-1.66
46/35
6/4
67/133
119/172
1.45
2.29
1.46
1.49
0.80-2.61
0.58-8.97
0.98-2.17
1.08-2.06
Table 3
Numbers of exposed cases (Ca) and controls (Co) and odds ratio (OR) with 95% confidence interval (CI) for acoustic neuroma in case-control studies in the highest category of
cumulative hours of mobile phone use.
All Ipsilateral
Ca/Co OR 95% CI Ca/Co OR 95% CI
Interphone 2011
Cumulative use >1640 h 77/107 1.32 0.88-1.97 47/46 2.33 1.23-4.40
Hardell el al., 2013
Cumulative use >1640 h 27/301 2.40 1.39-4.16 19/133 3.18 1.65-6.12
Meta-analysis
Cumulative use >1640 h 104/408 1.73 0.96-3.09 66/179 2.71 1.72-4.28
2.4. In summary
Based on case-control studies there was a consistent finding of
increased risk for glioma and acoustic neuroma associated with use
of mobile phones. Similar results were found for cordless phones in
the Hardell group studies, although such use was not reported by
the other study groups. The findings are less consistent for me-
ningioma although somewhat increased risk was seen in the meta-
analysis of ipsilateral mobile phone use. A longer follow-up time is
necessary for this type of slow growing tumor.
The results on glioma and acoustic neuroma are supported by
results from animal studies showing co-carcinogenic and tumor
promoting effects from RF-EMF (Tillmann et al., 2010; Lerchl et al.,
2015). Recent results from the National Toxicology Program (NTP)
study showed genotoxicity of RF radiation in rats and mice exposed
to RF-EMF (Smith-Roe et al., 2017). That result supports previous
findings of DNA strand breaks in rat brain cells exposed to RF-EMF
(Lai and Singh, 1997).
Of importance also is that the results in the NTP and Ramazzini
studies both demonstrated an increased incidence of tumors of the
same type, glioma and malignant schwannoma, as has been seen in
humans with mobile phone use (Wyde et al., 201(3; Falcioni et al.,
2018). Acoustic neuroma (vestibular schwannoma) is a similar
type of tumor as malignant schwannoma, although benign. In fact,
rates of brain tumors are increasing in Sweden and use of wireless
phones has been suggested to be the cause (Hardell and Carlberg,
2017).
3. Other diseases and pathological conditions attributed to
exposure to low-intensity EMFs
The evidence for harm from RF-EMF is strongest for cancer as a
consequence of intensive mobile phone use, especially gliomas,
glioblastomas and acoustic neuromas. But there is other evidence
for elevation in risk of leukemia among children living near to very
high intensity radio transmission towers (Michelozzi et al., 2002;
Ha et al., 2007). This is particularly interesting because leukemia is
the cancer most associated with elevated exposure to ELF-EMFs
arising from power lines (Ahlbom et al., 2000; Greenland et al.,
2000). There is some evidence for elevations in breast cancer risk
among women who wear their mobile phones in their bra (West
et al., 2013). Heavy use of a mobile phone was associated with
significantly elevated rates of ipsilateral parotid tumors in studies
from both Israel (Sadetzki et al., 2007) and China (Duan et al., 2011).
No increased risk was found in a Swedish study, but the results
were limited by low number of participants and lack of data on
heavy and long-term use of wireless phones (Soderqvist et al.,
2012b).
There are other significant human health hazards of concern.
There is strong animal and human evidence that exposure to RF-
EMFs as well as ELF-EMFs reduces fertility in both males
(reviewed by McGil! and Agarwal, 2014) and females (Roshangar
et al., 2014). An association between spontaneous abortion and
non-thermal EMF exposure including ELF-EMFs was reported in
several case-control studies (Dodge, 1970; Juutilainen et al., 1993; Li
et al., 2017). The increased use of mobile phones and increased
exposure coming from WiFi, smart meters and other wireless de-
vices has been paralled in time with male hypofertility and sperm
abnormalities in semen (Rolland et al., 2013). These effects maybe
related to holding an active wireless laptop in a man's lap or having
an active mobile phone on their belt, but more study is needed.
There is evidence that isolated human sperm exposed to RF-EMFs
are damaged by generation of reactive oxygen species (Agarwal
et al., 2009).
There are other diseases or physiologic alterations which have
been reported to be associated with exposure to non-thermal EMFs
in humans and in animals (Belyaev et al., 201(3). Alzheimer disease
has been shown to be significantly associated with chronic ELF-EMF
occupational exposure in prospective epidemiological studies
(Garcia et al., 2003; Davanipour and Sobei, 2009). Exposure to RF-
EMFs has been reported to increase neuropsychiatric and behav-
ioural disorders (Johansson et al., 2010; Divan et al., 2012), trigger
cardiac rhythm alteration and peripheral arterial pressure insta-
bility (Havas, 2013; Saili et al., 2015), induce changes in immune
system function (Lyle et al., 1983; Grigoriev et al., 2010; Sannino
et al., 2011, 2014) and alter salivary (Augner et al., 2010) and
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647
thyroid (Koyu et al., 2005; Mortavazi et al., 2009; Pawlak et al.,
2014) function. There is an urgent need for more study of these
diseases or biological alterations in relation to exposure to both
ELF- and RF-EMFs.
4. An emerging concern: cognitive and neurobehavioral
problems in children
Children, and especially fetuses, are more vulnerable than adults
for most environmental exposures (Sly and Carpenter, 2012). This is
because their cells are rapidly dividing and their organ systems are
not mature. As a result, events that perturb cellular function early in
life can result is abnormalities that last. There is a building body of
evidence indicating that exposure to RF-EMFs has adverse effects on
cognition and neurobehavior, especially in children and adolescents.
Concern about the particular sensitivity of children to RF-EMFs
emitted from mobile phone was first raised in 2000 by a British in-
dependent expert group (iEG, 2000) that noted that the increased
sensitivity to EMFs of children could be due not only to the natural
vulnerability of the developing nervous system, but also to the
smaller head size and thickness of the skull. These factors, plus the
higher conductivity of the young nervous system, result in greater
penetration of RF-EMFs into the brain (Gandhi et al., 1996). Of
concern is the fact that any adverse effects during development may
have life-long consequences and that young people, because they
will have a longer life span, will receive a greater cumulative expo-
sure than adults (Kheifets et al., 2005; Hansson Mild et al., 2006).
There are several reasons to be concerned. Animal studies have
shown that in utero RF-EMF exposure from mobile phones affects
fetal programming and leads to alteration in neurodevelopment
and behavior of offsprings (Aldad et al., 2012; Zhang et al., 2015).
Exposure of young rats to non-thermal intensities impairs learning
and spatial memory secondary to a deleterious impact of EMFs on
hippocampal, pyramidal or cortical neurons. Similar detrimental
cognitive and behavioural defects were also observed in adult an-
imals exposed to low-intensity.
EMFs (Bas et al., 2009; Deshrnukh et al., 2015; Kumari et al.,
2017; Shahin et al., 2017). The exposure induces markers of
oxidative stress and inflammation in the brain (Dasdag et a!, 2012;
Megha et al., 2015).
There are human data consistent with these animal studies.
Divan et al. (2003) reported that prenatal and to a lesser degree
postnatal exposure to cell phones is associated with emotional and
hyperactivity problems in 7-year old children. This finding was
confirmed in a second replicative study involving different partic-
ipants (Divan et a!, 2012). Birks et al. (2017) used data from studies
in five cohorts from five different countries (83,884 children) and
concluded that maternal mobile phone use during pregnancy
increased the risk that the child will show hyperactivity and inat-
tention problems. A meta-analysis involving 125,198 children
(mean age 14.5 years) reported statistically significant associations
between access to and use of portable screen-based media devices
(e.g. mobile phones and tablets) and inadequate sleep quality and
quantity and excessive daytime sleepiness (Carter et al., 2016). Early
life exposure to lead has long been known to cause a reduction in
cognitive function and shortened attention span (Needleman et al.,
1979). Two studies have shown that prenatal (Choi et al., 2017) or
postnatal (Byun et al., 2017) mobile phone exposure results in
greater neurobehavioral effects in children with elevated lead
levels than those seen with elevated lead alone. These results raise
concern that EMFs may have synergistic actions with other envi-
ronmental contaminants known to cause a reduction in intelligence
quotient (IQ) and attention, such as polychlorinated biphenyls,
methyl mercury, environmental tobacco smoke and probably
others (Carpenter, 2006).
Finally the problem should be considered at the societal,
worldwide level. Many adolescents (Lenhart, 2015) and even very
young children and infants (Kabali et al., 2015) use cordless devices
immoderately, to such a point that the common intensive use of
devices in children and adolescents has been ascribed as an
addiction (Paz de la Puente and Balmori, 2007; Roberts et al., 2014).
The specific absorption rate (SAR)-based ICNIRP safety limits
were established on the basis of simulation of EMF energy ab-
sorption using standardized adult male phantoms, and designed to
protect people only from the thermal effects of EMFs. These as-
sumptions are not valid for two reasons. Not only do they fail to
consider the specific morphological and bioclinical vulnerabilities
of children, but also they ignore the effects known to occur at non-
thermal intensities. The same criticisms apply to other so called
"independent" advisory groups or agencies, such as the Advisory
Group of Non-Ionizing Radiation in the UK (AGN1R, 2012), the
French Agency for Food, Environmental and Occupational Health &
Safety in France (ANSES, 2013), and the Scientific Committee on
Emerging Newly Identified Health Risk (SCENIHR, 2009), all of
whom deny the detrimental health effects of low intensity, non
thermal EMF exposure and make recommendations based only on
thermal SAR considerations.
Although several scientific authorities, such as the US American
Academy of Pediatrics (AAP, 2013), and the Russian National
Committee on Non-Ionizing Radiation Protection (RNCN1RP, 2011)
have made specific recommendations to not allow the use of mo-
bile phones by children and to limit their use by adolescents, un-
fortunately these age categories remain a target for marketing of
mobile phone devices [http://www.who.int/peh-emf/project/
niapnatreps/RUSSIA%20repoit%202008.pdf]. The RNCNIRP has
warned that if no rational, health-based safety limits are adopted
for children and adolescents and no measures are taken to limit the
use of cordless devices, we can expect disruption of memory, de-
creases in learning and cognitive capabilities, increases in irrita-
bility, sleep disturbance, and loss of stress adaptation in this
population. There will also be long-term effects, including an in-
crease in brain cancer, infertility, EHS, Alzheimer disease and other
neurodegenerative diseases (RNCNIRP, 2011; Markov and Grigoriev,
2015). National and international bodies, particularly the WHO, will
bear major responsiblity for failing to provide specific science-
based guidance and recommendations so as to avoid such global
health threats.
5. Electrohypersensitivity, microwave illness or idiopathic
environmental intolerance attributed to electromagnetic
fields
There is a segment of the human population that is unusually
intolerant to EMFs. The term "electromagnetic hypersensitivity" or
"electrohypersensitivity (EHS)" to describe the clinical conditions
in these patients was first used in a report prepared by a European
group of experts for the European Commission (Bergqvist et al.,
1997). Santini et al. (2001, 2003) reported similar symptoms
occurring in users of digital cellular phones and among people
living near mobile phone base stations.
In 2004, because of the seemingly increasing worldwide preva-
lence, WHO organized an international scientific workshop in Prague
in order to define and characterize EHS. Although not acknowledging
EHS as being caused by EMF exposure, the Prague working group
report clearly defined EHS as "a phenomenon where individuals
experience adverse health effects while using or being in the vicinity
of devices emanating electric, magnetic or electromagnetic fields"
(www.who.int/pehemf/EHS_ProceedingsJune2006.pdf). Following
this meeting, WHO acknowledged EHS as an adverse health condi-
tion (WHO, 2005).
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D. Belpomme et al. / Environmental Pollution 242 (2018) 643—658
According to the Prague Workshop recommendations, it was
proposed to use the term "idiopathic environmental intolerance
(IEI) attributed to electromagnetic fields" (IEI-EMF) because of the
lack of a proven causal link with EMF exposure (Hansson Mild et al.,
2006). This pathological disorder is identical to what has been
previously described under the term "microwave illness"
(Carpenter, 2015).
This syndrome is characterized by fatigue, chronic pain and
impaired cognitive function (see the Paris appeal, http://appel-de-
paris.com/71ang—en}. The precise mechanism(s) whereby envi-
ronmental exposure to either ELF- or RF-EMFs can cause the
development of this syndrome are still uncertain. However several
lines of experimental and clinical data are sufficiently strong so as
to indicate that ELF-EMFs and RF-EMFs exposure is associated with
adverse biological and clinical health effects in humans as well as
animals (Rea et al., 1991; McCarty et al., 2011; Belpomme et al.,
2015; Hedendahl et al., 2015; lrigaray et al., 2018a). The preva-
lence of EHS has been estimated to range 1—10% in developed
countries (Hallberg and Oberfeld, 2006) but appears today to be
around 3% (Huang et al., 2018).
Since WHO official reports on mobile phone exposure and
public health (WHO, 2014) and more particularly on EHS (WHO,
2005), much clinical and biological progress has been made to
identify and objectively characterize EHS, as was summarized
during the international scientific consensus meeting of the 5th
Paris Appeal Congress that took place in May 2015 in Brussels at the
Royal Belgium Academy of Medicine (iSD, 2015). EHS has many
characteristics in common with other IEI pathological disorders,
including chronic fatigue syndrome, fibromyalgia, Gulf War Illness
and especially the syndrome of multiple chemical senssitvity
(MCS), which Belpomme et al. (2015) have shown to be associated
with EHS in many patients who report being electro hypersensitive.
5.1. Bioclinical identification and characterisation of
electrohypersensitivity
In a prospective study involving systematic face-to-face ques-
tionnaire-based interviews and clinical physical examinations of
nearly two thousand patients who self-reported having EHS or EHS
and MCS, Belpomme and colleagues reported that EHS is a well-
defined clinico-biological entity, characterized by the progressive
occurrence of neurologic symptoms, including headache, tinnitus,
hyperacusis, superficial and/or deep sensibility abnormalities, fi-
bromyalgia, vegetative nerve dysfunction and reduced cognitive
capability. These symptoms are repeatedly reported by the patients
to occur each time they are exposed to EMFs, even of weak in-
tensity. They result in chronic insomnia, fatigue, emotional lability
and depressive tendency (Belpomme et al., 2015; lrigaray et al.,
2018b).
Fable 4 presents the detailed symptomatic picture which was
obtained during face-to-face interviews with subjects with EHS in
comparison to those with both EHS and MCS and to a series of
apparently healthy control subjects that showed no evidence of
EHS and/or MCS. As shown in the Table, the symptoms reported are
consistent with those in other published questionnaire-based
studies of EHS patients (Dodge, 1970; Johansson et al, 2010;
Nordin et al, 2014; Medeiros and Sanchez, 2016; Roosli, 2008). The
clinical symptoms observed in EHS or EHS/MCS patients are sta-
tistically significantly much more frequent that those in apparently
normal controls. Although many of these symptoms are non-
specific, the general clinical picture resulting from their associa-
tion and frequency strongly suggests that EHS can be recognized
and identified as a specific neurological disorder.
Because of the multiple and relatively common symptoms and
the lack of recognized objective diagnosis criteria, studies on EHS
were left with only the patient's self-reported interpretation for
many years. As a result, EHS has unfortunately been considered to
be a psychiatric disease of unknown origin. This helps explain why
most mainstream public health and societal bodies claim there is
not sufficient data proving that the clinical symptoms experienced
and reported by EHS patients are caused by EMF exposure. There-
fore they refuse to acknowledge EHS as a true neuropathological
disorder. This negative point of view was supported by some blind
or double blind studies showing that most individuals who report
they suffer from EHS were not able to identify when they were
exposed to either EMFs or sham controls (Rubin et al, 2011; Eltiti
et al, 2015). However other studies have found that EHS subjects
can identify EMF exposure in a statistically significant manner
when they are blinded to whether or not the exposure was on (Rea
et al, 1991; McCarty et al, 2011).
To account for these seemingly negative results a nocebo effect
was suggested (ANSES, 2017). However there is presently no
consensus on a biological mechanism through which a nocebo ef-
fect could occur (Medeiros and Sanchez, 2016; Chrousos and Gold,
1992; Jakovljevic, 2014). Moreover, results obtained in a carefully
designed psycho-clinical study in self-reporting EHS patients are
not consistent with an initial nocebo response to perceived EMF
exposure, even though it is plausible that after the onset of the
disease such phenomena may intervene secondarily through an
acquired learning and conditioning process (Dieudonne, 2016). In
addition, a meta-analysis of cross sectional studies has documented
a 38% greater risk of development of headaches among mobile
phone users than non-users, and an increasing risk of headache
with longer daily call duration (Wang et al, 2017).
Belpomme, lrigaray and colleagues recently identified several
biomarkers in EHS and/or MCS patients which allow physicians to
identify and objectively characterize EHS as a true somatic patho-
logical disorder, discounting the hypothesis of a causal psychoso-
matic or nocebo-related process. These came in part from a
prospective clinical and biological analysis of a series of several
hundred consecutive cases of individuals who self-reported that
they suffered from EHS or both EHS and MCS (Belpomme et al,
2015) and more recently from the prospective anlaysis of an addi-
tional series of EHS patients (lrigaray et al, 2018a). Table 5 sum-
marizes the different biomarkers that have been measured in the
peripheral blood of these patients and the results which have been
obtained based on the EHS and EHS/MCS patient groups. Note that
among the different markers, the 6-hydroxymelatonin sulfate/
creatinine ratio in urine appears to be the best marker to be used in
medical practice since it has been found to be decreased in all cases
evaluated to date (Belpomme et al, 2015).
By measuring different major oxidative stress-related bio-
markers, such as thiobarbituric acid reactive substances (TBARS),
oxided glutathione (GSSG) and nitrotyrosine (NTT) in EHS patients,
lrigaray et al (2018b) have recently shown that near 80% of the EHS
patients present with detectable oxidative stress biomarkers
(Fig. 1). More than 40% of EHS patients present with at least one
positive biomarker, 20% with two and 15% will all three of the
biomarkers investigated. This indicates that in addition to the
inflammation-related biomarkers previously associated with EHS,
EHS patients are also characterized by exhibiting biomarkers of
oxidative stress (Belpomme et al, 2015; lrigaray et al, 2018a,b).
The significance of the different biomarkers measured in the
peripheral blood of EHS and EHS/MCS patients is that these results
imply that these patients present with some degree of oxidative/
nitrosative stress, inflammation and autoimmune response.
Increased levels of several of these markers (notably protein S100B
and NTT) may reflect hypoxia-associated oxidative stress-induced
blood brain barrier (BBB) opening. It has been previously hypoth-
esized that opening of the BBB can be caused by environmental
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D. Belpomme et al. / Environmental Pollution 242 (2018) 643—658 649
Table 4
Clinical symptom occurrence in EHS and EHS/MCS patients in comparaison with normal controls*'.
EHS EHS/MCS pb Normal controls p pd
Headache
88%
96%
0.065
0%
<0.0001
<0.0001
Dysesthesia
82%
96%
0.002
0%
<0.0001
<0.0001
Myalgia
48%
76%
<0.0001
6%
<0.0001
<0.0001
Arthralgia
30%
56%
<0.001
18%
0.067
<0.0001
Ear heat/otalgia
70%
90%
<0.001
0%
<0.0001
<0.0001
Tinnitus
60%
88%
<0.0001
6%
<0.0001
<0.0001
Hyperacousis
40%
52%
0.118
6%
<0.0001
<0.0001
Dizziness
70%
68%
0.878
0%
<0.0001
<0.0001
Balance disorder
42%
52%
0.202
0%
<0.0001
<0.0001
Concentration/Attention deficiency
76%
88%
0.041
0%
<0.0001
<0.0001
Loss of immediate memory
70%
84%
0.028
6%
<0.0001
<0.0001
Confusion
8%
20%
0.023
0%
0.007
<0.0001
Fatigue
88%
94%
0.216
12%
<0.0001
<0.0001
Insomnia
74%
92%
0.001
6%
<0.0001
<0.0001
Depression tendency
60%
76%
0.022
0%
<0.0001
<0.0001
Suicidal ideation
20%
40%
0.003
0%
<0.0001
<0.0001
Transitory cardiovascular abnormalities
50%
56%
0.479
0%
<0.0001
<0.0001
Occular deficiency
48%
56%
0.322
0%
<0.0001
<0.0001
Anxiety/Panic
38%
28%
0.176
0%
<0.0001
<0.0001
Emotivity
20%
20%
1
12%
0.176
0.176
Irritability
24%
24%
1
6%
<0.001
<0.001
Skin lesions
16%
45%
<0.0001
0%
<0.0001
<0.0001
Global body dysthermia
14%
8%
0.258
0%
<0.0001
<0.007
a This data results from the clinical analysis of the 100 first clinically evaluated cases issued from the already published series of EHS and/or MCS patients who have been
investigated for biological markers [Belpomme eta L, 2015]. It has been compared symptomatically with data obtained from a series of 50 apparently normal subjects matched
for age and sex, used as controls.
b Significance levels (p values) obtained for compararison between the EHS and EHS/MCS groups.
c Significance levels (p values) obtained for compararison between the EHS and normal control groups.
d Significance levels (p values) obtained for compararison between the EHS/MCS and normal control groups.
Table 5
Patient mean values and standard deviations of biomarker levels in comparison with normal reference values as well as the percentage of patients with abnormal values in the
peripheral blood in subjects with EHS or both EHS and MCS (Belpomme et al., 2015).
Biomarker and Normal reference values
Patients groups
EHS Mean ± SD % Above normal
EHS/MCS Mean h
z SD % Above Normal'1
hs-CRP < 3 mg/1
10.3 + 1.9
15%
6.9 +/1.7
14.3%
Vitamine D > 30 ng/ml
20.6 + 0.5
69.3%
14.5 + 1.3
70.1%
Histamine< 10nmol/l
13.6 + 0.2
37%
13.6 + 0.4
41.5%
IgE< 100 Ul/ml
329.5+43.9
22%
385 + 70
24.7%
S100B <0.105 ng/1
0.20 + 0.03
14.7%
0.17 + 0.03
19.7%
Hsp 70 <5 ng/ml
8.2 + 0.2
18.7%
8 + 0.3
25.4%
Hsp 27< 5 ng/ml
7.3 + 0.2
25.8%
7.2 + 0.3
31.8%
Anti-O-myelin auto-antibodiesb
Positive
22.9%
Positive
23.6%
24-h urine 6-OHMS/creatinine ratio >0.8l
0.042 + 0.003
100%
0.048 + 0.006
100%
hs-CRP, high-sensitivity C-reactive protein; IgE, Immunoglobulin E; S100B, S 100 calcium binding protein B; Hsp 27, heat shock protein 27; Hsp 70, heat shock protein 70; anti-
O-myelin auto-antibodies, auto-antibodies against O-myelin; 6-OHMS, 6-hydroxymelatonin sulfate.
a There is no statistically significant difference between the two groups of patients for the different biomarkers analyzed, suggesting that EHS and MCS share a common
pathological mechanism for genesis.
b Qualitative test.
c Data restricted to those not on neuroleptic medication as the simultaneous use of several psychotherapeutic drugs may also be associated with a decrease of this 24-h
urine ratio by modifying melatonine metabolism.
stressors, be they chemicals or EMFs. This may have occurred in
these patients, as has been shown to occur in several (but not all)
animal experiments involving EMF exposure (Oscar and Hawkins,
1977; Persson et a!,, 1997; Eberhardt et a!,, 2008; Sirav and
Scyhan, 2009). Comparable data using metabolic and genetic bio-
markers were also obtained in another large series of EHS patients
(Dc Luca et a!., 2014). Overall these data indicate that the clinical
use of biomarkers allows the objective characterisation and iden-
tification of EHS and MCS as two etiopathologic facets of a unique
pathological disorder, and also allows insight into the genesis of
these two diseases.
The development of new imaging techniques has also greatly
increased our ability to objectively characterize EHS and MCS. Us-
ing ultrasonic cerebral tomosphygmography (UCTS) (Parini et a!,,
1984), EHS- and EHS/MCS-patients were found to have a statisti-
cally significant decrease in mean pulsometric index in several
middle cerebral artery-dependant portions of the temporal lobes,
especially in the capsulo-thalamic area, which is part of the limbic
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D. Belpomme et al. / Environmental Pollution 242 (2018) 643—658
90
80
70
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D. Belpomme et al. / Environmental Pollution 242 (2018) 643—658
651
bioinitiative.org). These include induction of oxidative stress, DNA
damage, epigenetic changes, altered gene expression and induction
including inhibition of DNA repair and changes in intracelluar cal-
cium metabolism. Both low-intensity ELF-EMF and non-thermal
RF-EMF effects depend on a number of physical parameters and
biological variables and physical parameters, which account for the
variation in health outcomes (Belyaev, 2015; Belyaev et al., 1999).
Importantly, the most severe health effects are observed with
prolonged chronic exposures even when intensities are very low
(Belyaev, 2017). The physics of non-equilibrium and non-linear
systems and quantum mechanics are at least in part the basis of
the physical mechanisms responsible for the non-thermal molec-
ular and biological effects of non-thermal EMF radiation (Belyaev,
2015), although a detailed report on these actions is beyond the
scope of this review.
Lower RF-EMF intensity is not necessarily less bioactive or less
harmful. Non-thermal EMF effects can be observed at intensities
which are very close to ordinary background levels and quite
similar to intensities emitted by mobile phone base stations. There
are time windows for observation of non-thermal EMF effects
which may be dependent upon the endpoint measured, the cell
type and the duration and power density of exposure. Non-thermal
RF-EMF effects are affected by static magnetic fields and electro-
magnetic stray fields, which result in the variation of non-thermal
EMF effects from mobile phones because of adjacent electrical
appliances, power lines and other sources of ELF and static mag-
netic fields, including changes in the geomagnetic field (Gapeev
et al., 1999a and b).
Cell-to-cell interactions potentiate the response to non-thermal
EMFs (Belyaev et al., 1996). Biological responses to EMFs have been
shown to be influenced by sex and age (Zhang et al., 2015; Sirav and
Seyhan, 2016). Physiological parameters such as the stage of cell
growth, oxygen, divalent ions and temperature are important
Environnemcntal stressors
resident microglia cells
Astrocytes and
mastocytes
Cerebral
hypoperfusion
/hypoxia
*
J J histamine
and other mediators
1 primary local
inflammatory
response
X
oxidative stress
BBB disruption
transmigration of
circulating inflammatory
cells
Inflammation
amplification
capsulothalamicneuroinflammation
mainly involvingthe limbic system and
the thalamus
Fig. 2. Hypothetical EHS/MCS common etiopathogenic model based on neuro-
inflammation and oxidative/nitrosative stress-induced blood brain barrier disruption
(Belpomme et al., 2015).
variables affecting cellular responses to EMFs (Liburdy and Vanek,
1987; Sannino et al., 2011).
6.1. Combined exposures
EMFs at non-thermal intensities may interfere with other
environmental stressors, showing an interplay of molecular path-
ways and resulting in either beneficial or detrimental health effects,
depending on the nature and conditions of co-exposures
(Novoselova et al., 2017; Ji et al., 2016). One example is the
demonstration that RF-EMF exposure modulates the DNA damage
and repair induced by ionizing radiation (Belyaev et al., 1993).
Another example is the synergistic of exposure to lead and EMFs on
cognitive function in children described above (Choi et al., 2017;
Byun et al., 2017). These co-exposure factors should be considered
when assessment of detrimental effects, including carcinogenicity,
is performed.
Not all of the effects of EMFs on the nervous system and other
organs are necessarily harmful. The best example of a positive ef-
fect is the well-documented and clinically useful benefit of applied
magnetic fields to promote bone healing (Bassett, 1994). Both ELF-
EMF (Zhang et al., 2015) and RF-EMF (Arendash et al., 2010) have
been reported to slow cognitive decline in rodent models of Alz-
heimer's disease. Some human studies report a facilitating effects of
cognitive performance (Lee et al., 2001) while Koivisto et al. (2000)
reported an increase in response time and vigilance tasks but a
decrease in mental arithmetric tasks. These studies clearly show
that EMFs have biological effects at non-thermal intensities, but
suggest that not all biological effects are necessarily harmful.
6.2. Duration of exposure and dose intensity
Such parameters as power density, dose, and duration of
exposure have been analyzed for development of reliable safety
standards, which would protect against the detrimental health ef-
fects of chronic exposure to RF-EMFs at non-thermal intensities.
Some studies show no effect under fixed short-term exposures, but
this does not imply that there are no effects from longer-term ex-
posures (Choi et al., 2014). Exposure in studies showing RF-EMF
effects was on average twice the duration as those with no signif-
icant effects (Cucurachi et al., 2013). The response to non-thermal
EMFs depends on both power density and duration of exposure.
Importantly, the same response is observed with lower power
density but prolonged exposure as at higher power density and
shorter exposure (Nordenson et al., 1994). While SAR is a good
surrogate for thermal RF effects from acute exposures, many
studies have shown that SAR should be either replaced by "dose-
specific absorption" or power density complimented by duration of
exposure for description of non-thermal RF effects (Belyaev, 2015).
Recent studies have provided more evidence for the greater
importance of dose and duration of exposure than SAR alone for
biological and health effects from long-term exposures to non-
thermal RF-EMFs (Furtado-Filho et al., 2015).
6.3. Oxidative stress
Non-ionizing radiation does not have sufficient energy to
directly break chemical bonds, and therefore the DNA damage that
occurs with non-ionizing EMF exposures is primarily a conse-
quence of generation of reactive oxygen species (ROS), resulting in
oxidative stress. There are numerous animal experiments which
clearly demonstrate that non thermal EMFs can cause oxidative
stress (Esmekaya et al., 2011; Burlaka et al., 2013), particularly in
the brain (Shahin et al., 2017; Dasdag et al., 2012; Megha et al.,
2015; Furtado-Filho et al., 2015). Oxidative stress is known to
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D. Belpomme et al. / Environmental Pollution 242 (2018) 643—658
play a central role in development of cancer and aging and serves as
a signaling agent in the inflammatory response (Holmstrom and
Finkel, 2014).
The brain is a particularly important organ for sensitivity to
EMFs. Brain cancer resulting from EMF exposures is a serious
concern, and EHS is a disease of the central nervous system. Several
mechanisms at the cellular and molecular levels have been re-
ported that may be the basis of these non-thermal RF-EMF effects
on brain function. ELF- and/or RF-EMF exposure at embryonic or
early postnatal stages can alter in vivo synaptic efficacy and plas-
ticity of neurons (Balassa et a!, 2014), a finding which was further
supported by in vitro studies showing a significant decrease in the
differentiation of neural stem cells into neurons (Eghlidospour
et al., 2017), the alteration of transcript levels of neuronal
differentiation-related genes and impairment of neurite outgrowth
of embryonic neural stem cells exposed to ELF- or RF-EMFs (Ma
et al., 2014). These observations support the conclusion that low-
intensity but prolonged exposure to non-thermal EMFs may have
adverse effects on neurogenesis during development and indicate
how important it is to protect the fetus and young child from
excessive exposure to all mobile devices.
Animal studies have documented that 900 MHz or 2.45 GHz non
thermal RF-EMF exposure in rats, either short term or chronic, can
trigger neuronal dysfunction and even apoptosis of hippocampal
pyramidal cells (Bas et a!., 2009; Shahin et a!., 2017) and cerebellum
Purkinje cells (Sonmez et al., 2010) through induction of oxidative
stress. Exposure of pregnant dams elicited EMF oxidative stress-
induced neuronal pathologic changes in offspring (Odaci et a!.,
2016). Such pathological changes could be due to ROS-induced
opening of the BBB (Norda! and Wong, 2005) and/or to ROS-
associated brain hypoxia caused by a decrease in EMF-induced
BBF and/or EMF-induced hemoglobin deoxygenation (Mousavy
et a!, 2009; Muehsam et a!., 2013). The resulting hypoxia may
induce metabolic neuronal dysfunction as in the case of EHS pa-
tients (Belpomme et al., 2015) but also neuronal cell death by either
apoptosis or necrosis as in the case of Alzheimer's disease and other
forms of dementia (Bell and Zlokovic, 2009).
While some consider the laboratory data on EMFs as being
inconsistent, showing either detrimental or no effects and on
occasion even beneficial effects, the vast majority still show detri-
mental effects. For example Henry Lai in the Bioinitiative Report
Research Summaries Update of November 2017, Chapter 6 on
Genotoxic Effects, reported that i) of 46 studies on ELF genotoxicity
with the comet assay as the end point, 34 studies (74%) showed
detrimental effects, ii). Of 189 total studies on ELF and oxidative
stress, 162 (87%) showed a positive correlation, and iii) of 200
studies on RF and free radicals, 180 (90%) showed detrimental ef-
fects. One reason for variability between laboratory studies is the
strong dependence on low-threshold EMF effects on a number of
physical and biological variables (Belyaev, 2010).
6.4. Genetic and epigenetic mechanisms
Genetic effects are the most direct cause for carcinogenicity.
This is true both for genotoxic changes caused by exposure to
EMFs and existing polymorphic genetic differences within a
population that increase susceptibility to cancer. DNA can no
longer be considered to be unaffected by environmental EMF
levels, as many studies have shown that DNA can be activated and
damaged by EMFs at levels that have been considered to be safe
(Blank and Goodman, 1999).
The primary mechanism through which low-intensity EMFs can
alter DNA is through ROS production. Lai and Singh (2004) first
reported that a 2 h exposure of rats to 60 Hz EMFs at 0.1—0.5 mT
resulted in DNA strand breaks in neurons, and provided evidence
that this effect was mediated by free radical formation and blocked
by free radical scavengers. Vijayalaxmi and Prihoda (2009) in a
meta-analysis of 87 publications found a biologically small but
statistically significant difference between DNA damage in ELF-
EMF-exposed somatic cells as compared to controls, and reported
evidence for epigenetic changes for some outcomes. For ELF-EMFs
this breakage effect was stronger when exposure was intermittent
rather than continuous (Nordenson et al., 1994).
Yang et al. (2003) have reported an OR = 4.31 (95% CI
l.;-)4 12.OS": for leukemia in children living within 100 m of a high
voltage powerline if they had a certain polymorphism of a DNA
repair gene.
Exposure to RF-EMFs can also induce DNA damage under spe-
cific conditions (Markova et al, 2005). Tice et al (2002) and
Vijayalaxmi et al (2013) reported DNA damage and micronuclei
formation in cultured human leukocytes and lymphocytes upon
exposure to RF-EMF signals of at least 5W/kg. Not all cell types
showed similar responses. Schwartz et al (2003) reported micro-
nucleus changes in fibroblasts but not lymphocytes exposed to
1950 MHz EMFs. Kesari et al (2014) also demonstrated DNA strand
breaks in the brains of rats exposed for 2 h per day for 60 days to a
3G mobile phone. Changes in DNA secondary structure (Seniin,
1995; Diem et al, 2005) and chromosome instability (Mashevich,
2003) have been observed upon exposure to RF-EMFs emitted by
mobile phones.
Epigenetic changes, rather than genetic changes in DNA, may
underlie many or even most of the biological effects of non-thermal
EMFs (Sage and Burgio, 2017). Non-thermal EMFs are epigenetic
stressors which can alter gene expression by acting through
physical or biochemical processes and be reflected as chromatin
remodeling (Belyaev et al, 1997), histone modification (Wei et al,
1990) or altered microRNA (Dasdag et al, 2015) at intensities far
below those that cause measureable tissue heating.
Chromatin plays a key regulatory role in controlling gene
expression and, more particularly, the access of transcription fac-
tors to DNA. It has been shown that extremely low intensity RF-EMF
exposure, i.e. at intensities comparable to that of mobile phone and
towers, results in changes in chromatin conformation and gene
expression (Belyaev et al, 1997; Belyaev and Kravchenko, 1994;
Belyaev et al, 2008; Belyaev et al, 2009). In a large number of cells
and tissues, compaction of chromatin in specific loci may lead to
gene silencing, loss of histone regulatory effects and DNA repair
capacity (Wei et al, 1990). Belyaev and collaborators (Markova
et al, 2005; Belyaev et al, 2009) have shown that exposure to
RF-EMFs emitted by GSM mobile phone alters chromatin confor-
mation in human lymphocytes and inhibits formation of p53-
binding protein 1 (53BP1) and phosphorylated histone H2AX (y-
H2AX) DNA repair foci.
EMFs in both the ELF and RF ranges may epigenetically affect
DNA by inducing the expression of stress response genes and
consequently the synthesis of chaperone stress proteins (Blank and
Goodman, 2011a and b). A specific gene sequence has been iden-
tified that acts as a sort of antenna, specifically sensitive and
responsive to EMFs (Blank and Goodman, 2011b). This is a gene
sequence coding for HSP70, a protein belonging to a family of
conserved, ubiquitously expressed "heat shock proteins" that sense
danger signals and protect cells from the most disparate stress
conditions. This is an unambiguous demonstration that EMF
exposure even at non-tissue heating intensities has the potential to
be harmful to cells and organisms. The HSP70 promotor contains
different DNA regions that are specifically sensitive to diverse
stressors, thermal and non-thermal. The EMFs are specifically
perceived by the sequences sensitive to non-thermal stimuli. Dur-
ing the process of HSP70-response induction, EMFs can activate
directly the HSP70 gene promoter (Rodrequez-De la Fuente et al,
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D. Belpomme et al. / Environmental Pollution 242 (2018) 643—658
653
2010) which contains a magnetic field-responsive domain (Lin
et al, 1999, 2001).
EMF-related HSP70 and HSP27 stress responses have been
detected in the hippocampus of rats exposed to non-thermal EMFs
(Yang et a!,, 2012). Shahin et al. (2017) reported that mice exposed
to 2G mobile phones continuously for four months showed
elevated ROS, lipid peroxidation, total nitrate and nitrite concen-
trations and malondialdehyde levels in homogenates of different
tissues, and decreased levels of several antioxidant enzymes. These
observations justify the use of these markers to characterize EHS in
patients who report that they are sensitive to EMFs.
The EMF effects have been suggested to be mediated by the
mitogen-activated protein kinase (MAPk) cascades, which is a
central signaling transduction pathway which governs all stress-
related cellular processes occurring in response to extracellular
stimuli (Friedman et a!., 2007). It has been shown that long term
exposure of cells to mobile phone frequencies or to ELF-EMFs
(Goodman et a!., 2009) activates the extracellular-signal regulated
kinase (ERK), which is one of the four MAPk cascades so far
identified.
Non-thermal RF-EMFs may also alter expression of other genes.
As long ago as Byus et a!., 1988 showed that 450 MHz RF increased
ornithine decarboxylase activity in hepatoma cells. Markova et al.
(2005) exposed human fibroblasts and mesenchymal stem cells
to mobile phone RF-EMFs with analysis of tumor suppressor p53
binding protein 1. Formation of 53BP1 foci was inhibited in both
cells types, but the stem cells always showed a greater response.
Fragopoulou et al. (2011) exposed mice to either a typical mobile
phone or a wireless DECT base station and analyzed the brain
proteome. They found significant alteration in 143 specific proteins
(ranging from a 0.003 fold downregulation to up to a 114-fold
overexpression.) Luo et al. (2013) exposed pregnant women un-
dergoing a first trimester abortion to a mobile phone applied to the
abdomen and performed a proteomic analysist of placental villous
tissue. They report 15 proteins which were significantly altered by
at least 2- to 2.5-fold in exposed women as compared to control
women. Twelve of these proteins were identified. Yan et al. (2008)
exposed rats to mobile phones 6 h per day for 126 days, and found
upregulation of specific mRNAs that regulated several proteins,
including calcium ATPase, neural cell adhesion molecule, neural
growth factor and vascular endothelial growth factor. EMFs at non
thermal levels may not only alter the expression of many proteins
but also may directly affect protein conformation (Fragopoulou
et a!., 2011; Bohr and Bohr, 2013; Beyer et a!., 2013) and modify
enzyme activity (Vojisavljevic et al., 2010), so altering the regu-
lating capacity of the epigenome. These are epigenetic, not genetic,
effects (Sage and Burgio, 2017).
Non-thermal EMF exposure can epigenetically interfere with
the differentiation and proliferation programs of stem cells in fetal
and adult tissues through ROS production (Wolf et al., 2007; Falone
et al., 2007; Ay§e et al., 2010; Park et al., 2014). Stem cells are the
most sensitive cells to EMF exposure (Eghlidospour et al., 2017;
Markova et al., 2010) and this is particularly the case for neural stem
cells of the hippocampus (Leone et al, 2014).
The endogenous natural ionic currents and electrical fields in
the human body (Jaffe and Nuccitelli, 1977) are vulnerable to the
oscillary properties of non-thermal EMFs. These consequently may
cause detrimental effect on cell differentiation and proliferation in
adult tissues (Levin, 2003) in addition to the effects on cell differ-
entiation, proliferation and migration in the fetus (Wolf et al., 2007;
Ay§e et al, 2010; Leone et al, 2014). Fetal programming cannot be
reduced to only genetic programs. Developmental processes are
essentially epigenetic (Leone et al, 2014), and exposure to epige-
netic stressors such as non-thermal EMFs are much more
dangerous for the fetus than for the adults.
6.5. Calcium regulation
There has long been evidence that EMFs alter several aspects of
calcium function. This is important because calcium regulates many
different aspects of cell function. Bawin and Adey (1976) reported
that very weak ELF-EMFs trigger efflux of calcium from isolated
chick brain, although the implications of this observation were not
clear. Later they reported a similar action of RF-EMFs (Adey et al,
1982). Pulsed low-frequency EMFs promote bone healing and
promote calcium uptake into bone (Spadaro and Bergstrom, 2002)
and osteoblasts (Zhang et al, 2010). 50 Hz EMFs increase the
number of voltage-gated calcium channels in neuroendocrine cells
(Grasso et al, 2004) and presynaptic nerve cell terminals (Sun et al,
2018). Wei et al (2015) found that ELF-EMFs also altered the fre-
quency of calcium transients in cardiomyocytes and decreased
calcium concentrations in sarcoplasmic reticulum. These changes
in calcium in heart muscle may be the basis for the cardiovascular
effects reported in humans on exposure to EMFs (Havas, 2013). In
spite of numerous studies reporting altered calcium metabolism
upon exposure to both ELF- and RF-EMFs, the overall implications
of these effects are still not clear. However, some have suggested
(Ledoigt and Belpomme, 2013) that calcium activation of proteins
could be the initial event that results in altered protein configura-
tion, leading to generation of ROS and ultimately activating the
molecular pathways to cancer.
7. Public Health Implications of Human Exposure to EMFs
The incidence of brain cancer in children and adolescents has
increased between 2000 and 2010 (Ostrom et al, 2015). Gliomas
are increasing in the Netherlands (Ho et al, 2014), glioblastomas
are increasing in Australia (Dobes et al, 2011) and England (Philips
et al, 2018) and all brain cancers are increasing in Spain
(Etxeberrua et al, 2015) and Sweden (Hardell and Carlberg, 2017).
The latency period between initial exposure and clinical occurrence
of brain cancer is not known but is estimated to be long. While not
all reports of brain cancer rates show an increase, some do. The
continually increasing exposure to EMFs from all sources may
contribute to these increases. The prevalence of EHS is unknown,
but various reports suggest that it is between 1 and 10% of the
population (Hallberg and Oberfeld, 2006; Huang et al, 2018). Male
fertility has been declining (GeofFroy-Siraudin et al, 2012; Levine
et al, 2017). EMFs increase the risk of each of these diseases and
others. Alzheimer's disease is increasing in many countries
worldwide and its association with ELF-EMF occupational exposure
has been clearly demonstrated through several independent
epidemiological studies (Davanipour and Sobel, 2009; Sobel et al,
1996; Qju et al, 2004) and a meta-analysis of these studies
(Garcia et al, 2008). A recent meta-analysis (Huss et al, 2018) has
reported an increased risk of amyotrophic lateral sclerosis in
workers occupationally exposure to ELF-EMFs.
Safety limits for RF exposure have been based (until today) on
the thermal effects of EMFs. But these standards do not protect
people, particularly children, from the deleterious health effects of
non-thermal EMFs (Naziroglu et al, 2013; Mahmoudabadi et al,
2015). Each of these diseases is associated with decrements in
health and quality of life. Brain cancer patients often die is spite of
some improvement in treatment, while EHS patients present with
increased levels of distress, inability to work, and progressive social
withdrawal. The ability for humans to reproduce is fundamental for
the maintenance of our species.
The scientific evidence for harm from EMFs is increasingly
strong. We do not advocate going back to the age before electricity
or wireless communication, but we deplore the present failure of
public health international bodies to recognize the scientific data
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D. Belpomme et al. / Environmental Pollution 242 (2018) 643—658
showing the adverse effects of EMFs on human health. It is
encouraging that some governments are taking action. France has
removed WiFi from pre-schools and ordered Wi-Fi to be shut off in
elementary schools when not in use (http://www.telegraph.co.uk.
news/2017/12/ll/france-ipose-total-ban-mobile-phones-schools/).
The State of California Department of Public Health has issued a
warning on use of mobile phones and offered advice on how to
reduce exposure (State of California, 2017). There are many steps
that are neither difficult nor expensive that can be taken to use
modern technology but in a manner that significally reduces
threats to human health.
It is urgent that national and international bodies, particularly
the WHO, take this significant public health hazard seriously and
make appropriate recommendations for protective measures to
reduce exposures. This is especially urgently needed for children
and adolescents. It is also important that all parts of society,
especially the medical community, educators, and the general
public, become informed about the hazards associated with expo-
sure to EMFs and of the steps that can be easily taken to reduce
exposure and risk of associated disease.
Appendix A. Supplementary data
Supplementary data related to this article can be found at
https://doi.Org/10.1016/j.envpol.2018.07.019.
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Date; August 24,2021
Resolution No. 2021-135
RESOLUTION
L I E MOUNTAIN TRIBAL COUNCIL
REFERENCE; Opposition to the Proposal by United States National Nuclear Security
Administration, Department of Energy to Establish a Strategic Uranium Reserve and
Authorization to Submit Comments in Opposition
WHEREAS. the Constitution and By-Laws of the Utc Mountain Ute Tribe, approved June 6, 1940
and subsequently amended, provides in Article til that the governing body of the Utc Mountain Ute
Tribe (•'Tribe") is the Ute Mountain Ute Tribal Council and sets forth in Article V the powers of the
Tribal Council exercised in this Resolution;
WHEREAS, the Tribal Council is responsible for protecting and promoting the best interests of the
communities and the members of the Tribe and the resources of the Reservation;
WHEREAS, the White Mesa community sits three miles south, of the White Mesa Mill owned and
managed by Energy Fuels Resources (USA) which process radioactive waste materials, such as
uranium, and has not only far exceeded the period of time for its operations, but has accepted and
processed materials that were not a part of its original design and has gone beyond the purposes for
which the Mill operates;
WHEREAS, the operations of the White Mesa Mill has had severe health impacts on the residents
of White Mesa and should cease entirely;
WHEREAS, in the Consolidated Appropriations Act, 2021, $75,000,000 is set aside for the
Department of Energy for a Uranium Reserve Program;
WHEREAS, the Department of Energy, through the National Nuclear Security Administration, has
published a Request lor Information from the public and has set a deadline of September 10,2021,
to receive comments (See Fed.Reg. Vol. 86, No. J 52 pp 44007 to 44009);
WHEREAS, the action taken by this Resolution is in the best interests of the Tribe.
Resolution No. 2021-135
Re: Opposition to the Proposal by United St ates National Nuclear Security Administration, Department of Energy to
Establish a Strategic Uranium Reserve and Authorization to Submit Comments in Opposition
Page 1 of2
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NOW THEREFORE BE IT RESOLVED that the Tribal Council hereby opposes the creation of a
Uranium Strategic Reserve and directs the Tribe's Justice Department and Environmental
Programs Department to respond to the request for information by September i 0, 2021; and
BE IT FINALLY RESOLVED that the Chairman of the Ute Mountain Ute Tribe is authorized to
sign this Resolution and to take such further action as may be necessary to carry out the intent of
this Resolution.
The foregoing Resolution was duly adopted this 24th day of August, 2021.
Manuel Heart, Chairman
Ute Mountain Ute Tribal Council
CERTIFICATION
This is to certify that there was a quorum of 6 Tribal Council Members present at the
official meeting of the Ute Mountain Ute Tribal Council held on August 24, 2021. that 5 voted
for this Resolution, that 0 opposed with 0 abstaining, and that this Resolution was, therefore,
dulv adopted,
-• yv\
Marilynn House, Council Secretary
Ute Mountain Ute Tribal Council
Resolution No. 2021 -135
Re: Opposition to the Proposal by United States National Nuclear Security Administration, Department of Energy to
Establish a Strategic Uranium Reserve and Authorization to Submit Comments in Opposition
Page 2 of2
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The WASHINGTON
SPECTATOR
JANUARY/
FEBRUARY 2022
VOL. 48, NO. 1 ISSN 0887-428X
© 2022 The Public Concern Foundation
washingtonspectator.org
Federal Court Instructs FCC
to Review Electromagnetic
Radiation Standards
By Barbara Koeppel
FOR 25 YEARS—THROUGH FIVE DEMOCRATIC AND
Republican administrations—the Federal Communica-
tions Commission has refused to revise the regulations it
set in 1996 that address what level of radiation from cell phones
should be considered safe- Labeled radio-frequency radiation
(RFR), these emissions are .discharged from all wireless devices,
Wi-Fi networks, and the thousands of towers stretched across the
United States that transmit
and receive the signals.
The FCC's power is pro-
methean. R is the sole U.S.
agency that .determines 111«•
acceptable RFR exposure
from wireless devices for
people nf all ages, wildlife,
and the environment. And
it insists its original 1996
limits are fine,
However, scientists
who've reviewed hundreds
of studies published over
the last two decades claim
the FCC ignores: critical
findings that show a "sta-
tistically significant" link
between heavy cell phone
use (10 or more years) and brain and thyroid tumors, especially
on the side of the head where people hold their phones. Profes-
sional groups such as the American Academy of Pediatrics and
the California Medical Association have asked the !•'(.'(to update
its numbers.
The scientists and physicians worry that the FCC simply
repeats the indus-
try's line that; all is
well—which is par-
ticularly troubling
since millions more
people around the
world are exposed
each year. In the
ALSO INSIDE:
4 Interest Rate Hikes—The Editors
5 Republican Tax Cuts—Steven Pressman
6 Turkish Elections—Alexandra de Cramer
8 Measures to Minimize RFR Exposure
United States, for example,: only 44 million people had cell
phones in 1996; today, the number has soared to about 300 mil-
lion, and that doesn't include the tablets, watches, and other
wireless products that increase RFR exposure exponentially.
Thus, in 2019, the Environmental Health Trust (EHT), Con-
sumers for Safe. Cell Phones, Children's Health Defense., and 11
other petitioners sued the FCC. They argued that although the
U.S. Government Accountability Office told the FCC in 2013
to review its 1996 limits in light of new research, six years later,
the FCC was still repeating its all is safe mantra. In a 2019 press
release, the FCC said that "after a thorough review of the record,
we find it appropriate to maintain the existing radiofrequency
limits, which are among the most stringent in the world for cell
phones."
At the least, this assurance is doubtful. The lawsuit against
the FCC argues precisely the opposite: that the Commission
has not reviewed ""llie
record,'* Also, researchers
point out that countries
such as Italy, Switzerland,
France. Israel, China,
India, and Russia have
more stringent limits than
the United States; regard-
ing the use of Wi-Fi in
schools and day care cen-
ters, and on acceptable
levels of radiation emis-
sions from Cell towers.
In addition, some have
banned all cell phone ads
pitched to children.
The lawsuit notes that
the FCC even ignored
Photo by Bedr&om ^mark 10-year,
$30 million National Toxicology Program study carried out under
the National Institutes of Health—which produced unequivo-
cal results in 2019. Having exposed rats and mice to cell phone
radiation for two years, the NTP researchers reported "clear
evidence of cancer in the male rats' heart cells, some; evidence
of increased brain gliomas (brain cancer), and adrenal gland
tumors, DNA damage in the brains of male and female rats and
mice, and lower birth weights of female rats' offspring. "
Two years after the suit was filed, the U.S. Court of Appeals
of the D.C, Circuit ruled in August 2021 that the PC'C had to
reexamine the research to determine if its regulations should be
updated. Further, the court called the commission's behavior
"arbitrary and capricious," since it had ignored evidence of the
harm to children's brains which are not fully developed) and to
1
-------
JANUARY/FEBRUARY 2022
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Barbara Koeppel
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Editor and Publisher
Hamilton Fish
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male and female reproductive systems. It also ruled
that because the FCC never produced regulations
about radiofrequency radiation's effects on wildlife,
it had "completely failed" to address the evidence
of potential environmental harm.
However, the court did not set a date for the
FCC to comply—which meant the commission
could retain its old regulations indefinitely. Also,
the court did not address the issue of whether RFR
exposures cause cancer; instead it said the FCC had
passed the "minimum legal requirement" to assure
it had evaluated the research on cancer and radia-
tion exposure. Thus, scientists are concerned that
the FCC will again find ways to defer serious exami-
nation of the voluminous literature on the subject.
Flow could this be, given the NTP findings and
other research? To bolster its no-cancer claims,
the FCC points to a letter the U.S. Food and
Drug Administration wrote the commission, which
claimed the NTP results weren't relevant to humans
since the study was done on rats and mice (although
10 years earlier, the FDA itself had approved the
animal study). Dr. Joel
December 2020), studies over the past 20 years
have found strong evidence of brain tumors and
leaks in the blood-brain barrier, acoustic neuromas
(tumors on the nerves leading from the inner ear
to the brain), thyroid tumors, and cognitive impair-
ment. They also showed a link to male infertility:
when men carried phones in their pants' pockets,
their sperm were weakened and reduced. Also,
physicians and scientists found that some indi-
viduals are particularly sensitive to RFR radia-
tion, which can cause tinnitus, vertigo, headaches,
fatigue, and loss of memory. Early this month,
some experts studying the U.S. diplomats' and CIA
agents' "Havana Syndrome" symptoms suggested
they could be related to radiofrequency radiation.
Hie latest evidence
Moskowitz, director of
the Center for Family
and Community Health
at the University of Cal-
ifornia, Berkeley and a leading authority on radio-
frequency radiation, says, "The FDA wrote a biased
review of the research regarding cancer risk from
cell phone radiation."
Also, the FCC cited reports from organizations
that have undeclared conflicts of interest (ties to
the wireless industry), which contest the cancer
links. Dr. Ronald Melnick, the lead designer of
the NTP study, has published two articles stating
that the results from these groups' reports were
"unfounded."
In fact, the FCC failed on several fronts. Besides
ignoring the NTP study, the commission dismissed
the American Academy of Pediatrics' request for
regulations that reflect the special effects RFR
have on children and pregnant women. It never
explained why it ignored research that showed chil-
dren's brains absorb higher levels of the radiation.
Instead, it has insisted for 20-plus years that RFR
is only harmful if it overheats the human body by
at least one degree centigrade. This is a red her-
ring, since wireless devices don't emit the kind of
radiation that produces higher temperatures. Also,
the FCC didn't consider the effects of long-term
exposures.
Many researchers insist these links have been
proven. As noted in an earlier article in this jour-
nal ("Wireless Hazards," Washington Spectator.
Theodora Scarato, the executive director of the
Environmental Health Trust, says that since the
FCC had not yet responded to the court's August
ruling by last November, the EHT asked the com-
mission to consider
[Dr. Joel Moskowitz:] "Hie FDA wrote a additional studies that
biased review of the research regarding cancer were completed after
risk from cell phone radiation." 2019, when the suit
was filed.
For example, in late 2019, the European Par-
liamentary Research Service said that electromag-
netic fields (EMFs) emitted by 2G, 3G, and 4G cell
phones (which operate at 450 to 6,000 megahertz)
are "probably carcinogenic for humans," particu-
larly in causing gliomas, acoustic neuromas, and
meningiomas (slow-growing, mostly nonmalignant
brain tumors).
In 2020, Yoon-Jung Choi and Joel Moskow-
itz (the lead authors) and three other scientists
reviewed 46 "case-controlled studies" and pub-
lished their findings in "Cellular Phone Use and
Risk of Tumors: Systematic Review and Meta-Anal-
ysis," in the November International Journal of
Environmental Research ancl Public Health. Mos-
kowitz says, "This study updated our earlier analysis
published in 2009." Evidence from the new study,
he says, links cell phone use to increased tumor
risk. The researchers' numbers are compelling:
1,000 or more hours of cell phone use, or about 17
minutes a day over 10 years, was associated with a
statistically significant 60 percent increase in brain
tumor risk.
Also in 2020, Devra Davis (an epidemiolo-
gist and co-founder of the Environmental Health
Trust), Aaron Pilarcik (a biophysicist at the Worces-
ter Polytechnic Institute), and Anthony Miller (an
epidemiologist specializing in cancer etiology and
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WASHINGTONSPECTATOR.ORG
an adviser to the World Health Organization) reviewed data on
colon and rectal cancer from the U.S. Centers for Disease Con-
trol, the U.S. SEER Program at the National Cancer Institute,
and the Iranian National Cancer Registry. They found that the
colon cancer risk for adults born in the 1990s had doubled and
the rectal cancer risk had increased fourfold by the time they
were 24 years old—when compared to those born 60 years ago.
They hypothesized that cell phone radiation could play a role
in the increased risk and recommended the FCC set limits to
reduce the exposure. Their study. "Increased Generational Risk
of Colon and Rectal Cancer in Recent Birth Cohorts Under Age
40—the Hypothetical Role of Radiofrequency Radiation from
Cell Phones," was published in the Annals of Gastroenterology
and Digestive Disorders.
In 2020, Henry Lai (a retired University of Washington sci-
entist) reviewed the research on genetic effects and found that
exposure to RFR can break DNA strands and affect the central
nervous system. The review, "Genetic Effects of Non-Ionizing
Electromagnetic Fields" was published in the December 2020
issue of Electromagnetic Biology and Medicine.
In 2021, Henry Lai, with Albert Manville (a biologist formerly
at the U.S. Fish and Wildlife Service) and Blake Levitt (an envi-
ronmental journalist), studied the effects of cell phone towers in
various countries, comparing data from the 1980s to the present.
They found that the toxic effects of EMFs on cells and genes had
altered "the wildlife's orientation and migration patterns, their
ability to find food, mate, reproduce, build nests and dens, and
maintain and defend their territory." Yet the FCC has still set no
standards for long-term, low-level EMF exposure on wildlife.
The scientists' three-part research was published in Reviews on
Environmental Health, "Effects of Non-Ionizing Electromag-
netic Fields (EMF) on Flora and Fauna."
Also in 2021, the journal Andrologia published a study by
Iranian scientists who found DNA fragmentation in sperm and
recommended that men keep cell phones "away from the pelvis
as much as possible."
Further, from 2015 to the present, the French government
has tested the radiation from cell phones when people hold them
next to their bodies. Their findings are dramatic: They reported
exposures to RFR up to 11 times higher than those approved in
FCC guidelines. Thus, the government passed a ministerial order
in 2019 urging the public to limit children's cell phone use and
"keep the phones away from the belly of pregnant women and
the lower abdomen of adolescents."
Moreover, the National Institutes of Health and the American
Cancer Society funded a study in 2019 and 2020 at Yale Univer-
sity that found increased thyroid cancer among heavy cell phone
users.
The accompanying table enumerates many of the ways that
doctors and vigilant public jurisdictions have identified to help
people reduce the health risks that could be associated with expo-
sure to RFR and cell phone radiation emissions.
The EHT's Scarato reminds readers concerned about RFR
emissions exposure to "contact their senators and representa-
tives to raise the issues with the committees." In the Senate, the
Committee on Commerce. Science, and Transportation, along
with its Subcommittee on Communications. Media, and Broad-
1 1
band oversees the FCC. In the House, the FCC reports to the
Energy and Commerce Committee and its Communications and
Technology Subcommittee. Public pressure on the members
of these committees will help to prod the FCC to review the
research and respond to the ruling of the Court of Appeals. ¦
Barbara Koeppel is a Washington, D.C.-based investigative
reporter who covers social, economic, political, and foreign
policy issues.
PROTECT YOURSELF FROM
WIRELESS RADIATION
The California Department of Public
Health recommends these precautions:
• Use headsets—not ear buds—but remove them
when not talking, since even headsets release
small amounts of radiation when not in use.
• Text instead of talk.
• Carry phones away from your body in backpacks,
tote bags, handbags, and briefcases.
• Keep phones away from your head when streaming.
• Download movies instead of streaming them.
• Don't use cell phones when reception is poor
and they show just one or two bars—in subways,
cars, basements, or rural areas. Under such
circumstances cell phones often need vastly more
energy to communicate with cell towers and other
phones, and radiation levels intensify.
• Men should not carry phones in pants' pockets.
Cleveland Clinic Center for Male Fertility
researchers found this weakened and reduced
sperm, which can cause infertility.
Go to page 8 for more information
3
-------
JANUARY/FEBRUARY 2022
(Continuted from page 3)
PROTECT YOURSELF FROM WIRELESS RADIATION
Countries must adopt tough laws
• Belgium and France banned companies from
designing phones to appeal to children.
• Israel and Cyprus banned Wi-Fi in day care centers
and kindergartens, requiring connections be wired.
Israel limited Wi-Fi use in first and second grades
to three hours a week.
• France ordered cities to map the locations
of antennae, measure their radiation levels, and
tell the public. Also, it banned ads showing people
holding phones next to their heads and ordered
companies to list phones' exposure levels. If they
don't, they can be fined up to 75,000 euros.
• India ordered companies to remove towers located
near hospitals and schools.
• Israel ordered companies to list phones' radiation
levels.
• Geneva (Switzerland) placed a moratorium on
the rollout of 5G.
Scientists also recommend these steps:
• Use corded landlines at home, but put satellite
or cordless handsets on speakerphone, since they
emit even more radiation than cell phones.
• Push for laws to protect children.
• Get states to create expert commissions to study
radiation emissions' effects. New Hampshire's
commission recommended that towers and
antennae be placed farther from schools and
homes.
8
-------
April 14, 2022
Via e-mail
White House Environmental Justice Advisory Council
U.S. Environmental Protection Agency
1200 Pennsylvania Ave. NW Washington, D.C. 20460
whejac@epa.gov
Dear White House Environmental Justice Advisory Council members:
Earthjustice writes to thank the White House Environmental Justice Advisory Council
(WHEJAC) for your role in ensuring that the Biden Administration places the concerns of
impacted and underrepresented communities front and center as they work to ensure
communities in need see 40% of the benefits of critical federal investments through the Justice40
initiative. WHEJAC plays a unique and important role, as community members and
environmental justice champions who have the ear of various arms of the Administration.
Because of this unique position, we hope that WHEJAC will be able to communicate to
President Biden, Vice President Harris, the Council on Environmental Quality (CEQ), and the
White House Interagency Council on Environmental Justice (Interagency Council) the necessity
of not squandering the unique moment we find ourselves in regarding equitable access to clean
water. With lead service line replacement enjoying massive support to the tune of a $15 billion
dollar investment in the bipartisan Infrastructure Investment and Jobs Act, the administration
must recognize that now is the time to require the U.S. Environmental Protection Agency (EPA)
to take bold, decisive action. We urge WHEJAC to communicate the necessity of 1) a
transformative Lead and Copper Rule Improvement (LCRI), and 2) equitable disbursement of
the aforementioned $15 billion to communities around the country based on need.
I. A Transformative Lead and Copper Rule
As WHEJAC members well know, the significance of drinking water as a lead exposure
pathway is often underestimated. EPA modeling has shown that drinking water can constitute up
to 80% of many U.S. children's lead exposures. Yet, the existing Lead and Copper Rule (LCR)
itself is not anchored in science, is fundamentally broken, and is rarely enforced. Hazardous lead
exposure of children as a result of drinking water has been documented throughout the US, not
only by water systems that have a "lead action level exceedance," but also by many that do
not. It is no accident that the lead crises in Washington DC, Flint, MI, Newark, NJ, and
Clarksburg, WV, all occurred while the water systems claimed their water was safe.
Accordingly, we recommend that WHEJAC urge EPA to take bold action by committing
to propose a reformed, improved LCR by early 2023 and to finalize that rule by early 2024.
EPA must also ensure that 100 percent of all lead service lines are removed within 10
years. Attached as an appendix to these comments are specific recommendatons contained in a
sign-on letter joined by Earthjustice and over 50 other partners including many community and
-------
environmental justice goals. Mere tweaks to the existing flawed framework of the LCR and the
reforms to it finalized during the Trump administration will not deliver the protection or justicr
that communities dealing with years of dangerously elevated lead levels require from the federal
government.
II. Ensuring IIJA funding for Lead Service Line Replacement is decided based on
need
The funding provided to EPA through IIJA - including the $15 billion for lead service line
replacement (LSLR) — is distributed to communities through the Clean Water and Drinking
Water State Revolving Funds (CWSRF and DWSRF, or SRFs collectively). The SRFs depend
on an outdated formula to determine how much funding from the SRFs go to each state. Among
other flaws, the allocation does not factor in how many lead services exist in each state. As a
result, certain states project to receive more funding for LSLR than they need, in proportion to
how many lead service lines are in their state, and others with greater need will receive an
inadequate share of this historic investment.
To avoid this inequitable outcome, we urge WHE JAC to recommend that EPA take two
steps within their authority:
1. Complete, this year, the Drinking Water Infrastructure Needs Survey and Assessment
(DWINSA). The analysis of the needs for lead service line replacement is needed in time
to determine the FY23 allocations of funds under IIJA, as required by the America's
Water Infrastructure Act of 2018.
2. Separate within the Drinking Water State Revolving Fund (DWSRF) three separate sub-
funds: (1) the $15 billion in IIJA for lead service lines; (2) the $4 billion for emerging
contaminants "with a focus on" PFAS; and (3) the $11.7 billion in general DWSRF
funding. EPA should then separately allocate funding from these three sub-funds based
upon the needs for each category assessed in the DWINSA.
Thank you for your dedication to environmental justice and equitable access to clean water. Your
efforts and partnership are critical to ensuring the Biden administration follows through on their
promise to set us on the path to removal of all lead service lines across the country in ten years.
Sincerely,
Julian Gonzalez
Legislative Counsel
Earthjustice
-------
Appendix: April 12 Letter to EPA from environmental and community groups
April 12, 2022
The Honorable Michael Regan
Administrator
US Environmental Protection Agency
1200 Pennsylvania Avenue NW
Washington, DC. 20004
Dear Administrator Regan,
We write to thank you and the White House for continuing to raise awareness and take action related to
the lead crisis plaguing communities across the country. As a result of our collective efforts, the issue of
lead service line replacement has become a priority for President Biden. And the U.S. Environmental
Protection Agency (EPA) promised in December 2021 to overhaul and strengthen the health protections
in its Lead and Copper Rule (LCR) for drinking water. EPA has also publicly committed to taking
advantage of the $15 billion in lead service line replacement funding provided by Congress in the
Infrastructure, Investment, and Jobs Act to begin an unprecedented push to, in the words of our
President, "begin to replace poisonous lead pipes—so every child—and every American—has clean
water to drink at home and at school." A multi-pronged strategy using distribution of Congressionally
appropriated funds, interagency coordination, collaboration with states, media outreach, and
strengthening EPA's rules governing lead exposure is exactly what is needed to get the lead out of our
communities.
All of these initiatives, all of this media attention, and all of the community engagement this
Administration has spearheaded will be undermined, however, if EPA does not issue a transformative
further revised LCR. The significance of drinking water as a lead exposure pathway is often
underestimated. EPA modeling has shown that drinking water can constitute up to 80% of many U.S.
children's lead exposures.1 Yet, the LCR itself is not anchored in science, is fundamentally broken, and is
rarely enforced. Hazardous lead exposure of children as a result of drinking water has been documented
throughout the US, not only by water systems that have a "lead action level exceedance," but also by
1 See Lindsay W Stanek et al., Modeled Impacts of Drinking Water Pb Reduction Scenarios on Children's
Exposures and Blood Lead Levels, 54 Environ Sci Technol 9474, 9474-82 (Aug. 2020); Ronnie Levin et al.,
The Urban Lead (Pb) Burden in Humans, Animals and the Natural Environment, 193 Environ Res (Feb.
2021)
-------
many that do not. It is no accident that the lead crises in Washington DC, Flint, Ml, Newark, NJ, and
Clarksburg, WV, all occurred while the water systems claimed their water was safe. EPA itself has
acknowledged that there are "significant opportunities to further improve upon" the LCR and the recent
revisions to it "to achieve increased protection of communities from lead exposure through drinking
water." 86 Fed. Reg. 71,574, 71,577 (Dec. 17, 2021). EPA must take bold action and should commit to
propose a reformed, improved LCR by early 2023 and to finalize that rule by early 2024.
EPA must ensure that 100 percent of all lead service lines are removed within 10 years to achieve the
Biden Administration's bold goal to "Replace All Lead Pipes in the Next Decade," as promised by the Vice
President in her December 2021 announcement of the Administration's Lead Pipe and Paint Action Plan.
The Trump LCR revisions, which the Biden Administration allowed to go into effect in December 2021,
extended the allowable timeframe for replacement to up to 33 years for systems required to replace
LSLs.
The LCR must be revamped so that it meets the SDWA's requirements and goals to protect health. If EPA
retains treatment technique,2 the LCR must "prevent known or anticipated adverse effects on the health
of persons to the extent feasible,"3 which it does not currently do. More specifically, EPA should shift its
focus to prevention, rather than "testing and fixing," given the dangers associated with lead, the
variability of lead in drinking water, and the long-term benefits and cost savings associated with such an
approach.
Under its current approach, remedial action is premised on extremely limited water sampling at a
miniscule number of homes and often only once every few years. Due to the sporadic nature of lead
release in drinking water, the very limited testing of tap water under the LCR does not provide an
adequate snapshot of the actual public health threat from lead service lines and other lead-bearing
plumbing materials. Further, no meaningful remediation is required until the lead levels in at least 10
percent of sampled homes exceed 15 parts per billion ("ppb") at the time of sampling, even though any
level of lead presents a health risk at any time. That construct knowingly and systematically sacrifices 9
percent of homes—which in New York City, for example, equates to almost 800,000 homes—regardless
of how high the lead levels in their drinking water are at the time of sampling. In many jurisdictions, it
likely sacrifices a far higher percentage of homes with significant lead-in-water contamination that the
extremely limited LCR testing missed. Up to 12 million homes are served by LSLs and the majority of US
homes have other lead-bearing plumbing; risking the health of that many people is unconscionable.
With respect to schools and childcare centers, the LCR's shockingly limited testing requirements (i.e.
2 As many of the signatories of this letter have noted in previous correspondence, the SDWA requires EPA to
establish a Maximum Contaminant Level (MCL) for lead because it is feasible to ascertain lead levels in drinking
water. See 42 U.S.C § 300g-l(b)(7)(A). However, the agency has made it clear that it has no intention of
establishing an MCL for lead, so we discuss how an LCR treatment technique should be strengthened in this letter.
3 42 U.S.C § 300g-l(b)(7)(A).
-------
only a one-time test of 5 outlets per school and two outlets in a childcare center) are inadequate,
scientifically unsound (i.e., one-time testing is not appropriate for determining the "safety" of any single
tap), and likely to mislead parents and staff into believing there is not a lead problem when there might
very well be serious contamination.
A new LCR treatment technique must, at minimum:
• Mandate full and equitable removal of lead service lines at utility expense to be completed
within 10 years for all water systems at no cost to homeowners. The rule should:
o Tightly limit - and over time eliminate - the number of service lines permitted to be
characterized as "lead status unknown" in a lead service line inventory;
o Prioritize replacement in communities disproportionately exposed to lead from other
sources.
• Improve LCR compliance sampling in lead service line homes by requiring more frequent, more
widespread, and more representative sampling including both 1st- and 5th-liter samples for
lead. The higher of the two samples should trigger corrective action.
• Require corrective actions to be health protective. To accomplish this, an LCR must:
o Require system-wide action at as low a 90th percentile lead level as feasible, no higher
than 5 parts per billion;
o When system-wide action is mandated, require water systems to:
¦ Immediately provide lead certified filters, as well as installation and training
assistance to all homes with known or possible lead service lines and/or
elevated lead levels (i.e. exceeding LAL) and then do a comprehensive
investigation of the lead source;
¦ Fully replace all lead service lines as quickly as possible, at no cost to the
consumer, as even filter efficacy depends on a number of factors.
o Ensure that customers served by small water systems are protected by regulatory
standards as stringent as those applying to larger utilities.
• Establish a prevention-oriented approach to stop lead contamination of water in schools and
child-care facilities. To accomplish this, an LCR must:
o Shift away from relying mainly on a "test-remediate" paradigm where our kids go to
learn and play each day;
-------
o Use all appropriate policy levers to drive utilities, schools and child care centers to
implement a "filter first" approach so that all water outlets used for cooking and
drinking at schools and childcare facilities are equipped with filtration stations, point of
use filters, or filtered water pitchers certified to remove lead.
o Installing water filtration stations in schools is significantly less expensive4 than
inaccurate testing regimes, and more protective of public health with the added benefit
of filtering out other contaminants of concern in school drinking fountains.
The LCR and EPA have also failed the public in terms of education by allowing public water systems to
hide behind statements of "compliance" with the complex and non-health protective LCR, and by
misleading people into believing their water presents no harmful exposure to lead, when, in reality, it
may dispense exceedingly high concentrations of the contaminant. Given the commitment of this
administration to environmental justice and community engagement, a new LCR framework should
mandate resident-led community advisory councils provided with sufficient technical expertise and
resources, and it must center public education that is complete and accurate. For example, EPA should
broaden and strengthen public education and notification requirements to explain the widespread
nature of lead in drinking water, the limitations of lead testing, and health impacts in all populations but
especially including the most vulnerable - fetuses and infants dependent on reconstituted formula.
Such outreach should also include steps people can take to decrease their families' exposure to lead,
such as using filters certified to remove both soluble and particulate lead.
For decades, advocates across the country have conveyed the urgency of this crisis at every turn, and
another round of "tweaking" the LCR will not only undercut the historic investments in lead service line
removal Congress recently authorized but, more importantly, it will condemn another generation of
families to exposure to dangerous levels of lead in drinking water. We are hopeful that EPA will propose
changes that our communities need, and we look forward to working with the agency as this urgent
process unfolds.
Sincerely,
A Community Voice - Louisiana
Alabama Rivers Alliance
Alabama State Association of Cooperatives
American Indian Mothers INC
4See "Ml Lawmakers Introduce Lead in Water Protections for Kids" https://www.nrdc.org/experts/cyndi~
roper/mi-lawmakers-introduce-lead-water-protections-kids
-------
BioRegional Strategies
Campaign for Lead Free Water
Center for Biological Diversity
Center for Neighborhood Technology (CNT)
Choctawhatchee Riverkeeper
Citizens for Clean Water Sycamore Illinois
Clean and Healthy New York
Waterway Advocates
Coalition on Lead Emergency
Community Water Center
Detroit Mercy Law Environmental Law Clinic
Earthjustice
East Chicago Calumet Coalition Community Advisory Group
Environmental Coalition for Water Justice
Environment America Research & Policy Center
Environmental Transformation Movement of Flint
Flint Rising
Food & Water Watch
Freshwater For Life Action Coalition
Green & Healthy Homes Initiative, Inc
GreenLatinos
Idaho Conservation League
Immigrants & Minorities Unify Services Association
League of Conservation Voters
Little Village Environmental Justice Organization
Metropolitan Planning Council
Milwaukee Riverkeeper
Natural Resources Defense Council
NC League of Conservation Voters
-------
New Beginnings UMC
Newburgh Clean Water Project
Nourishing Our Mind
Ohio Environmental Council
Passaic River Coalition
Pennsylvania Council of Churches
Portland Advocates for Leadfree Drinking Water
Portland Harbor Community Coalition
RE Sources
River Guardian Foundation
River Network
Rural Coalition
Saint Joseph's Carpenter Society
Sierra Club
St Francis Prayer Center, Flint Ml
The Water Collaborative of Greater New Orleans
U.S. PIRG
United Parents Against Lead
Washington Environmental Council
Water You Fighting For?
Waterway Advocates
We the People of Detroit
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healthy
11 May 2022
White House Environmental Justice Advisory Council (WHEJAC)
Docket Number EPA-HQ-OA-2021-0683
whejac@epa.gov
Re: Comments to the WHEJAC, May 2022
Thank you for the continued opportunities to offer comments to the
WHEJAC. I have commented before, and i plan to continue to comment until
we see changes occurring in our Gulf Coast environmental justice and climate
justice communities. I work for Healthy Gulf1, a Gulf of Mexico regional
environmental non-profit. We work on behalf of communities and
ecosystems, for the health of both. WHEJAC solicited responses around
disaster relief. I want to respond with a disaster justice lens.
(1) What type of support is needed for disadvantage communities to
participate in federal disaster preparedness or relief programs?
Support is needed in the form of cash or direct deposit money (method
should be of the recipient's choosing). People need money to be made
available to them regardless of their income, race, home ownership status,
immigration status, etc. Assistance must be made available for anyone
affected, not only people that are under a mandatory evacuation order.
People that 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.
Also, related, housing for unhoused people and for renters is essential.
Housing for people that are displaced is essential. In many cases after
Hurricane Ida, it took 4 months or more for people to get a FEMA trailer. After
Hurricane Laura, people are still living in FEMA trailers two years after the
storm, and now those people who don't have anywhere else to go are being
told they have to pay exorbitant rent in order to stay in the trailer. I've heard
from Hispanic residents of Texas that they received zero assistance after
Hurricane Harvey, and had to find places to stay and repair their houses with
1 Healthy Gulf's purpose is to collaborate with and serve communities who love the Gulf of Mexico by
providing research, communications and coalition-building tools needed to reverse the long-pattern of
over exploitation of the Gulf's natural resources.
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no recognition and no financial support or other support. FEMA needs to
provide quick assistance, and needs to continue that assistance until the
recipients are safely housed once again in permanent housing. Assistance
finding a new rental should be made available, as should longer term, high
quality housing (as opposed to a temporary trailer).
There must be absolutely 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, white recipients of awards. This is disgraceful and must be changed.
If FEMA can't dispense funds equitably, move this job to another agency or
outsource it so that funds are dispensed equitably and expediently. Perhaps
an
Disaster relief agencies need to recognize tribes and tribal members,
especially those that are not recognized at the federal level, but are
recognized at the state level or are not officially recognized at all. Indigenous
people on the Gulf Coast should be prioritized for relief money and rebuilding
or relocation support (based on their preference), as opposed to affluent
white people.
Furthermore, disaster relief should include money, housing, food,
transportation and support, ongoing until the needs have been completely
met, for either rebuilding or relocation. The same is true for renters.
There is also no recognition from any disaster by the federal government of
the individual and collective trauma that occurs during and after a storm, and
the support needs that arise around that. Myself and thousands of others on
the Gulf Coast plead with you that all of these items be addressed, swiftly.
(4) 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?
Do not issue permits to new or expanding fossil fuel facilities including but
not limited to LNG export terminals, petrochemical plants and pipelines.
Please stop fueling climate disasters and the social large-scale trauma that
results, disproportionately affecting Black, Indigenous, Creole and other
people of color, as well as people with low income. Please consider
reparations for Indigenous people and anyone descended from enslaved
people in the United States. Please consider a "universal basic disaster
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income" for the months of housing and working disruption that occurs after a
storm.
I've already commented in previous letters to WHEJAC about our requests for
the Gulf Coast in terms of disaster justice, but i'll restate some of those here.
My requests include safe housing and evacuation, food security and what i'm
calling "universal basic disaster income". Furthermore:
1. WHEJAC should demand that the EPA (and other agencies) and the
corporations ensure the human rights of clean water and clean air, by:
a) telling people what's in their water and b) telling people what's in
their air.
2. WHEJAC should recommend that the agencies and the White House
revoke and/or deny permits for those facilities in the fossil fuel industrial
complex that add pollution or climate injustice to environmental justice
communities (especially new and expanding facilities).
3. WHEJAC should insist that every environmental analysis of each project
involve a rigorous cumulative impacts analysis.
4. Require states and counties/parishes to track cases of cancer and other
illnesses (including COVID-19) that can be exacerbated by pollution by
location or locations where the person lives (as opposed to the hospital
they are treated at), and make this data is anonymized but publicly and
readily available.
5. Require agencies like USCG, EPA, FEMA and NOAA to openly coordinate
after a disaster especially in industrial zones, and to share with the
public what's in the air and water.
6. Implementation of a Gulf Coast investigation group as Advisor
McCarthy agreed to at the WHEJAC meeting on 11/17/21
7. Require that greenhouse gas (GHG) emissions be taken into account in
NEPA.
8. Ensure that rigorous Environmental Justice review (including
cumulative impacts) is conducted as a part of NEPA, including
- Set out clear methodology for designation of an EJ area,
and local revisions/petitions to be incorporated
- WHEJAC should create methods for EJ analysis and
community identification that are much more rigorous
than what is currently used by the US Army Corps of
Engineers, the Federal Energy Regulatory Commission and
other agencies
9. Establish Just Transition plans for the Gulf Coast (and the nation)
informed by regional Green New Deal goals
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Thank you for your consideration. Please act swiftly and decisively to lift up
the Gulf Coast communities that have long suffered, and provide remediation
and justice.
(submitted via Docket at regulations.gov and email)
Best regards,
Naomi Yoder, Staff Scientist
Healthy Gulf
PO Box 66226
Houston, TX 77266
naomkaihea lthvqulf.org
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April 14, 2022
Submission to: White House Environmental Justice Advisory Council
• Via Docket ID No. EPA-HQ-OA-2022-0050 at http://www.regulations.gov
• Via https://www.epa.gov/environmentaljustice/forms/white-house-environmental-justice-
advisory-council-whejac-public-comment
• Via email to whejac@epa.gov
Subject: The Climate and Economic Justice Screening Tool (CEJST or "Tool")
Chair Brenda Mallory of the White House Council on Environmental Quality (CEQ) has stated that "The
Climate and Economic Justice Screening Tool (CEJST or 'Tool') will help Federal agencies ensure that the
benefits of the nation's climate, clean energy, and environmental programs are finally reaching the
communities that have been left out and left behind for far too long."1
The Tool is a good starting point to address issues of clean energy and environmental issues, particularly
relating to unserved or underserved communities (the "Communities") and environmental justice.
A major component that should be added to the 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
those Communities and (2) the amount of fiber optics deployed, and needed to deploy, in those
Communities to close the digital divide.
What is emitted from wireless infrastructure, cell towers and cell phones is referred to as wireless radio-
frequency radiation (RFR), electro-magnetic radiation (EMR), electro-magnetic fields (EMF) or microwave
radiation. "ElectroSmog refers to all man-made electromagnetic radiation created and present in our
surrounding environment."2
Energy Consumption and Pollution
from Wireless Infrastructure and Devices
The environmental footprint of wireless infrastructure contributes more to global warming than it does in
preventing it.3 Wireless is not so "green."4 As far back as 2013, it was predicted that the "wireless cloud"
would produce "an increase in carbon footprint from 6 megatonnes of C02 in 2012 to up to 30 megatonnes
of C02 in 2015, the equivalent of adding 4.9 million cars to the roads," with up to 90% of this consumption
"attributable to wireless access network technologies ... "5 More recently, energy consumption for wireless
1 https://www.whitehoyse.gov/ceq/news-ypdates/2022/02/18/ceq-pyblishes-draft-climate-and-economic-iystice-
screening-tool-kev-component-in-the-implementation-of-president-bidens-iustice4Q-initiative/.
2 http://www.emfrf.corii/electrosmoe/
3 https://ehtrust.org/wp-content/uploads/5G-and-Climate-Change-Flyer-EHT.pdf.
4 Environmental Health Trust, "5G is Not So Green ..." https://mvemailxqnstantcontact.com/Studies-Confirm-5G-4G-
Wjjj-lncrease-Radiation-Exposure.html?soid=1116515520935&aid=2ptEVCn03-U.
5 https://ehtrust.org/wp-content/uploads/5G-and-Climate-Change-Flyer-EHT.pdf.
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infrastructure has been reported at ten times that of fiber (with 5G requiring 2 to 3.5 times the energy
needed for 4G towers).6 Energy consumption from 5G "is expected to increase 61x between 2020 to 2030
due to the energy demands of powerful network elements like massive MIMO7 and edge servers [and] the
proliferation of 5G cell sites ,.."8
By contrast, fiber optics has "[l]ower energy consumption, reduced waste and sustainable architecture,
characteristics that make fiber infrastructure an environmentally advantageous choice."9 "Fiber has a
minimal ecological impact, reduces waste, consumes very little energy and helps decrease greenhouse gas
emissions."10
In terms of pollution, even the telecommunications industry has referred to wireless RFR as a pollutant in
their product protection plans for which they disclaim liability for personal injury. For example, an industry
brochure for consumers for cell phone insurance protection states:
"Pollutants means any... gaseous, or thermal irritant or contaminant including... artificially
produced electric fields, magnetic field, electromagnetic field, sound waves, microwaves and all
artificially produced ionizing or non-ionizing radiation ..."n
Similar definitions for pollution are in the product protection plans for other telecommunications
companies.12
Two of the largest insurance companies in the world (i.e., Lloyd's of London and Swiss Re) have declined to
insure telecom companies for any liability for personal injury that results from RFR exposures.13,14,15
Insurance companies, reviewing potential RFR injuries to the public from a risk analysis perspective, have
assessed RFR as "high" risk by the insurance industry and is, therefore, excluded from coverage. The
insurance industry acknowledges the high potential of claims of RFR injuries from the public arising from
RFR exposure.
6 https://www.emfacts.com/2020/09/5g-base-stations-use-up-to-three-and-a-half-times-more-energy-than-4g-
infrastructure/.
7 MIMO means Multiple-Input Multiple-Output and "is a wireless technology that uses multiple transmitters and
receivers to transfer more data at the same time" by combining "data streams arriving from different paths" in
contrast to Single-Input Single-Output (SISO) technology which "can only send or receive one spatial stream at a
time." See, https://www.intel.com/content/www/us/en/support/articles/000005714/wireless/legacy-intel-wireless-
products.html.
8 https://ehtrust.org/report-5g-to-increase-energy-consumption-by-61-times/?
9 https://www.cablineinstall.coni/cable/fiber/article/16465344/how-fiber-can-help-make-yoyr-network-greener
10 Fiber Optic Broadband, A Greener Internet Solution, https://www.otelco.com/a-greener-internet-solution/.
11 https://ehtrust.org/wp-content/uploads/device-protection-brochure-nationwide.pdf:
12 liltps://clitrust.or|»/'kcy-issiics/clcct.roiiicigiictic-Hclcl-irisuraricc-po 1 ic\''-cxc 1 iisions/, hUps://chtrusl.org/\vp-
conlcnl/uploads/ATT-Multi-Dcvicc-Protcction-Pack-Insurancc.pdf, hUps://chtrusl.org/\vp-conlcrUAiploads/Sprint-
1 nsu ranee ~T e rins-a nd-Co ndi lio ns-Dow nloadcd-2019. pdf.
13 https://5etechnoloevnews.coni/insyrance-companies-can-refyse-claims-related-to-electromaenetic-radiation-
illnesses/
14 https://ehtrust.org/wp-content/uploads/Swiss-Re-SONAR-Publication-2Q19-excerpt-l.pdf, pg. 29.
15 https://ehtryst.ore/kev-issyes/reports-white-papers-insyrance-indystry
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Minority and rural communities have historically been affected by environmental hazards. Those mistakes
should not be amplified by their exposure to wireless RFR in close proximity to their homes, schools and
businesses. Fiber optics to the premises (FTTP) is the superior choice for these Communities, for digital
inclusion and environmental equity to bridge the digital divide.
Facts and Statements by U.S. Preeminent Scientists and Experts
In the Area of RFR Research
As shown by the following facts and statements by the United States' preeminent scientists and experts in
the area of wireless RFR research, it has become well established that wireless radiation exposure produces
or has the recognized potential of producing biological effects.
1. In 2011, the World Health Organization's (WHO) International Agency for Research on Cancer (IARC)
classified wireless radiation as a Group 2B possible carcinogen.16 This conclusion was based upon an
increased risk of malignant brain cancer (glioma) identified in those who used cell phones for over 10
years for an average of 30 minutes per day.
Anthony B. Miller, M.D., Senior Epidemiologist, IARC, states in a 2018 updated assessment to the 2011
IARC classification of wireless radiofrequency radiation (RFR), "When considered with recent animal
experimental evidence, the recent epidemiological studies strengthen and support the conclusion
that RFR should be categorized as carcinogenic to humans (IARC Group 1).17
2. "Since 2011, the scientific evidence linking wireless to cancer has significantly increased and today
several published reviews conclude that the current body of evidence indicates cell phone radiation is
proven Group 1 human carcinogen (Miller et al 2018, Peleg et al 2018 Carlberg and Hardell 2017,
Belpomme et al 2018)." 18
3. Christopher J. Portier, Ph.D., former director of the National Center for Environmental Health at the
Centers for Disease Control and Prevention (CDC) and a scientific advisor for the WHO, reviewed the
most recent body of scientific research and literature to look at the feasibility of RFR causing specific
brain tumors in humans and concluded in March, 2021:
• "Given the human, animal and experimental evidence, I assert that, to a reasonable degree
of scientific certainty, the probability that RF exposure causes gliomas and neuromas is high."
19
16 https://www.iarc, who, int/wp-content/uploads/2018/07/pr208 E.pdf
17 https://www.sciencedirect.com/science/article/abs/pii/S0Q13935118303475
18 https://ehtrust.org/scjence/whoiarc-posjtion-on-wirejess-and-health/
19 https://www.saferemr.com/2021/03/expert-report-bv-former-us-government. jitmj?m=l
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4. Linda Birnbaum, Ph.D., former Director of the U.S. NIEHS and former Director of the National
Toxicology Program (NTP) spanning across the Department of Health and Human Services organizations
which involves NIH, FDA and CDC, has stated:20
• "Effects from [wireless] radiofrequency radiation (RFR) such as genetic toxicity,
immunotoxicity, oxidative stress, changes in gene and protein expression, changes in cell
differentiation and proliferation, and increased permeability of the blood brain barrier
were reported in these [scientific] publications(pg. 8).
• "The phase I [NTP] studies established that non-thermal levels (<1°C or no detectible change
in temperature) of RFR exposure had toxicological implications in biological systems." (pg. 9).
• "The NTP found and published evidence of DNA damage after only 90 days of exposure." (pg.
9).
• "Overall, the NTP findings demonstrate the potential for RFR to cause cancer in humans. The
independent peer review of the entire proceedings carried out by toxicologists, pathologists
and statisticians independent of the NTP staff conducted March 26-28, 2018, concluded that
there was 'clear evidence of cancer/.....exposure to RFR is associated with an increase in DNA
damage." (pg. 11).
NOTE: NTP refers to the National Toxicology Program.21 Since completion of the $30 million NTP study
(originally sponsored by the FDA to research possible biological effects of RFR), the results have been
replicated by the Ramazzini Institute22 in another study using exposures below the FCC thermal
thresholds 23 (simulating emissions from cellular base stations and wireless transmitters).
5. In 2021, the U.S. D.C. Circuit Court of Appeals in EHT et al v. FCC ruled that the FCC's 2019 decision to
maintain their 26 year old thermal-based exposure "safety" guidelines demonstrated that the FCC was
acting in an "arbitrary and capricious" manner "in its complete failure to respond to comments
concerning environmental harm caused by RF radiation" below the current FCC limits.24
The Court further ruled that, "The factual premise—the non-existence of non-thermal biological
effects—underlying the current RF guidelines may no longer be accurate." The Court pointed out that
the FCC had ignored the scientific evidence documenting biological harm at non-thermal levels (i.e., at
levels hundreds and even thousands of times below the current FCC wireless exposure "safety"
guidelines). Indeed, thousands of scientific studies of biological hazards from RFR and hundreds of
personal accounts of injuries from RFR were in the FCC docket which the FCC ignored, and which the
D.C. Circuit Court of Appeals admonished the FCC that it cannot ignore.
20 https://ehtrust.org/wp-content/uploads/20-1025-Amicus-Brief-Joe-Sandri.pdf
21 https://ntp.niehs.nih.gov/whatwestudy/topics/cellphones/index.html
22 https://pubmed.ncbi.nlm.nih.gov/29530389/
23 https://ehtrust.org/worlds-largest-animal-studv-on-cell-toyyer-radiation-confirms-cancer-link/
24 https://www.cadc.uscourts.gov/internet/opinions.nsf/FB976465BF00F8BD85258730004EFDF7/$file/20-1025-
1910111.pdf
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The ruling called into question the underlying basis for the FCC's extremely high thermal-only "safety"
threshold and ruled in favor of health and safety advocates who sued the FCC.
6. Ronald Melnick, Ph.D., retired NIEHS senior toxicologist who won the American Public Health
Association's 2007 David P. Rail Award for public health advocacy states:
"/ strongly feel health and regulatory agencies should promote policies that reduce cell phone
radiation exposure, especially for children and pregnant women. The agencies in the U.S. say, "if
you are concerned" rather than "we are concerned." Agencies should be clear and
straightforward educating the public on "here is what you should do."
"The risk can be greater for children than adults due to the increased penetration of the radiation
within brains of children and the fact that the developing nervous system is more susceptible to
tissue damaging agents."25
7. The American Academy of Pediatrics, a non-profit professional organization of 60,000 primary care
pediatricians, pediatric medical subspecialists, and pediatric surgical specialists, stated in a letter to the
FCC on July 12, 2012:
"Children... are not little adults and are disproportionately impacted by all environmental
exposures, including cell phone radiation. In fact, according to IARC, when used by children, the
average RF energy deposition is two times higher in the brain and 10 times higher in the bone
marrow of the skull, compared with mobile phone use by adults."26
8. New Hampshire formed a State Commission to examine whether wireless radiation is harmful to
human health. The majority of that New Hampshire State Commission came to the conclusion that
exposure to wireless radiation is harmful to human health and the environment. The commission was
convened through bipartisan legislation27 that was signed by the governor. Commission membership
included unbiased experts in fields relating to health and radiation exposure, and they issued their Final
Report in November 2020.28
You can hear directly from grassroot communities the health problems that they have been experiencing
from RFR radiation. An example is in Pittsfield, MA where long-time residents and their children suffered
from serious physical ailments after the installation of a wireless cell tower near their homes, and from
which they had to evacuate.29 The Pittsfield, MA Board of Health recently issued an emergency order to a
telecommunications carrier to show cause why a cease and desist order should not be issued against the
25 https://www,youtube,com/watch?v=zSx yDzxvM8&t=2295s
26 https://ehtrust.org/wp-content/uploads/American-Academv-of-Pediatrics-letter-to-the-FCC-Julv-12-2012.pdf
27 https://legiscan.com/NH/text/HB522/2019
28 http://www.gencourt.state.nh.us/statstudcomm/committees/1474/reports/5G%20final%20report.pdf
29 https://ehtrust.org/statement-by-courtney-gilardi-after-pittsfield-board-of-health-votes-to-send-cease-and-desist-
o rd e r-f o r-ve rizon-cell-tower/.
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carrier to turn off a cell tower based on health effects and injuries sustained by residents as a result of the
cell tower.30 There have been other reports of health effects from cell towers.31
Fiber Optics as the Best Solution to Bridge the Digital Divide
For Unserved and Underserved Communities
These Communities are disproportionately affected by lack of, or insufficient access to, broadband
coverage in order to access the Internet and phone service. Middle mile fiber optics infrastructure has
been built in many areas with middle mile fiber running past rural communities without serving them,
hence the "digital divide."
Fiber to the premises (FTTP)32 is the superior service for bridging the digital divide so that these
Communities are not left behind. Former FCC Chair Tom Wheeler called fiber "future proof," and wireless
only as a last resort, not a first resort, in his testimony to Congress in March, 20 21.33 Wheeler stated that
despite approximately $40 billion of government subsidies "over the last decade," those subsidies "have
failed to deliver the goal of universal access to high-speed broadband ... because it failed to insist on
futureproof technology, ... and focused more on the companies being subsidized than the technology being
used or the people who were supposed to be served."34
Digital inclusion and digital equity are important for these Communities. To ensure digital inclusion and
digital equity for the Communities, broadband should be affordable and have the capacity and scalability to
meet increasing user demands for these Communities over its economic life, including performance, speed,
low latency, capacity and reliability. Fiber best meets these demands. Wireless is less reliable and less
scalable to meet future customer demands and has higher operational expense.35
Fiber is more affordable, scalable from symmetrical (upload and download) speeds of 100 Mbps to lGbps
to lOGbps, has a longer life span of 25-50 years and is safer and more cybersecure, has lower operational
expenses,36 and is available at more affordable prices. By contrast, wireless typically requires equipment
upgrades, constant maintenance and re-investments about every 5 years. An example of fiber deployment,
30 httpsi//ehtryst.ore/wp-content/yploads/Pittsfield-Health-Board-Cell-Tower-Order-to-Verizon-April-ll-2022-FlNAL-
REDACTED,pdf; see also, https://ehtrust.org/the-first-cease-and-desist-order-against-verizon-cell-tower-to-be-sent-
on-friday-by-by-board-of-health-pittsfield-ma/.
31 Cell Tower Health Effects httpsi//www.saferemr.com/2015/04/cell-tower-health-effects.html, Center for Family
and Community Health, School of Public Health, University of California, Berkeley.
32 Reinventing Wires by Timothy Schoechle, PhD, National Institute for Science, Law and Public Policy,
https://electromagnetichealth.org/wp-content/uploads/2018/02/Relnventing-Wires-l-25-18.pdf.
33 Tom Wheeler's Testimony to Congress,
https://energycommerce.house.gov/sites/democrats.energycommerce.house.gov/files/documents/Witness%20Testi
mony_Wheeler_FC_2021.03.22.pdf.
34 Id.
35 "To Reduce Network Operating Expenses, Choose FTTH," Masha Zager, July 2020,
https://www.bbcmag.com/broadband-applications/to-reduce-network-operating-expenses-choose-ftth
36 https://optics.fiberbroadband.org/Full-Article/reduce-network-operating-expenses-choose-ftth.
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consumers in Hudson County, TN have multiple service options, which include speeds of up to 1000 Mpbs
(1 Gbps). Pricing and capacity are scalable and provide for 300 Mpbs at $57.99/month and 1 Gbps at
$67.99, in each instance symmetrical speeds.37 Wireless technology is not able to effectively compete with
similar high-speed Internet, with the FCC only requiring 25 Mbps download / 3 Mbps upload speeds.38 39
The Fiber Broadband Association has shown that consumers prefer the symmetrical speeds that fiber
provides.40 As the largest fiber optics trade association in the U.S. states, "If it isn't fiber, it isn't
broadband."41
An example of substantial long term cost savings using fiber broadband is Chanute, KS which "operates a 10
Gbps fiber-optic broadband ring." This fiber network "connects schools and other community anchor
institutions with gigabit networks ... The network generates $600,000 per year for Chanute's Electric Utility
... This ... has demonstrated that communities can meet their own telecommunications needs with smart
public investments — they did not wait for national corporations to solve their problems." City Manager
J.D. Lester refers to municipal broadband as 'the great equalizer for Rural America'...'"42
An example of a rural area which achieved access, digital equity and digital inclusion is rural eastern
Kentucky. Peoples Rural Telephone Cooperative (PRTC) completed a 100% all fiber-to-the-premises
buildout in 2014, a Gigabit-capable internet available to every home and business in the counties of
Jackson and Owsley, Kentucky.43
FTTP would provide the best capacity for remote learning for children and students, and more reliable
access to medical and other services for the elderly and disabled during emergencies or severe weather
when wireless service is more likely to be interrupted. FTTP would also prevent the exclusion of those
disabled or suffering from wireless RFR who cannot be near wireless infrastructure or wireless Internet.
These residents should have equal access to broadband - a necessary service - in a manner that does not
injure them and that does not otherwise put them in harm's way. After all, people cannot adopt a
technology that is not being made available to them or that is injuring them. Those suffering from wireless
RFR tend to be in these Communities.
Conclusion
The CEJST should incorporate metrics of monitoring the levels of electrosmog from wireless structures and
levels of fiber optics deployment in the Communities "to help Federal agencies ensure that the benefits of
the nation's climate, clean energy, and environmental programs are finally reaching the communities that
have been left out and left behind for far too long." Fiber optics deployment for FTTP would ensure the
37 https://bestnejghborhood.org/tv-and-internet-hamilton-countv-tn/.
38 https://www.allconnect.com/blog/internet-speed-classifications-what-is-fast-internet.
39 https://www.fcc.gov/reports-research/reports/broadband-progress-reports/2018-broadband-deployment-report.
40 https://www.broadbandworldnews.com/document.asp?doc_id=773546.
41https://s3.amazonaws.com/files.fiberbroadband.org/download/3555.4237?AWSAccessKeyld=AKIAIZGD7FMLIYLBZN
IA&Expires=1650065068&Signature=CfFGHmOkZaAovAfuGmXXs2hDpKo%3D.
42 In Kansas, Rural Chanute Built Its Own Gigabit Fiber and Wireless Network," Christopher Mitchell 10-2-21,
https://ilsr.org/chanute-rural-gigabit/.
43 https://www.soar-ky.org/prtc/.
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best connectivity, digital inclusion, environmental equity, as well as safety for the environment and for the
health of the Communities.
Respectfully submitted,
Wired Broadband, Inc.
Virginians for Safe Technology, LLC
Consumers for Safe Cell Phones
Connecticut for Responsible Technology
Manhattan Neighbors for Safer Telecommunications
Last Tree Laws Massachusetts
5G Free Rhode Island
Safe Technology Minnesota
The Leto Foundation
5G Free California
mocoSafeG.org for Montgomery County, MD
New Yorkers 4 Wired Tech
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Submission for White House Environmental Justice Advisory Council
Docket ID No. EPA-HQ-OA-2022-0050
RE: Public Comment period on federal disaster preparedness and relief and community resilience
May 25, 2022
Dear WHEJAC members,
Thank you for this opportunity to provide public comment relevant to federal disaster preparedness and
relief and community resilience.
Human Rights Watch is an international organization based in New York that investigates human rights
abuses in over 100 countries including in the United States. Over the past two years our women's rights
division has worked with several partners to better understand how the climate crisis is worsening the
maternal health crisis in the US defined by inequities between Black, Indigenous, and other women of
color on the one hand and white women on the other.
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.
Hurricane Maria1
1
"Pregnancy in the Path of Hurricanes: Remembering Puerto Rico," Human Rights Watch commentary, September 6, 2019,
https://www.hrw.org/news/2019/09/06/pregnancy-path-hurricanes-remembering-puerto-rico.
1
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In the wake of Hurricane Maria in Puerto Rico in 2017, Human Rights Watch research found that
pregnant women struggled to access care including prenatal checkups. Women near their due date
when the hurricane struck struggled to locate their doctor. We spoke to Mariel Alvarez, herself a doula
who was a few weeks from her own due date when Hurricane Maria crashed down on Puerto Rico. She
had hemorrhaged in two earlier births, and both were early deliveries that required emergency care. As
the country plunged into darkness and chaos in the wake of the storm, Alvarez grew increasingly
anxious. "I was really afraid that I might die after giving birth," she said. With broken roads, and
hospitals overwhelmed as blackouts roiled the island, she gave birth at home a few weeks later. She
relied on her doula skills and a friend to stem her own bleeding, which, like the first two, was excessive.
During our research in Puerto Rico, we also found that access to sexual and reproductive health care,
including safe abortion care and contraceptive choice aside from condoms, although even these were
sometimes hard to access, was generally lacking in the aftermath of the storm. Mothers also sometimes
struggled to breastfeed without access to lactation support. Puerto Rican organizations, including Taller
Salud and InterMujeres, have also drawn attention to the problem of domestic violence in the wake of
the storm.
Extreme Heat as an Emerging Reproductive Justice Issue
A significant body of research over the past 15 years (please see document attached with this
submission for more information) shows an association between heat exposure and preterm birth, low
birth weight and still birth. A smaller body of work suggests that exposure to high temperatures may be
linked to pregnancy complications and other adverse health consequences for pregnant people.2
Increasing exposure to heat threatens to worsen an already-existing maternal health crisis in the US,
where rates of serious maternal illnesses are increasing in prevalence, and preterm (or premature) birth
have been on the rise for several years.3 The crisis is centered by racial inequities in maternal health and
birth outcomes; rates of maternal illnesses, preterm birth, low birth weight and still birth are all
significantly higher for Black as compared to white women.4 Exposure to extreme heat and other climate
change impacts worsens disparities between those who get to have a healthy pregnancy and newborn
and those who do not.
The studies suggest that US government policymakers and healthcare workers will need to do more to
protect pregnancy and newborn health from increasing and more intense heatwaves, and generally
hotter days and nights across the US, and from other climate-related harms. Aside from sometimes
including pregnant people on "vulnerable population" lists (for example, New York City,5 and the
2 Emma V. Preston, Claudia Eberle, Florence M. Brown, et al., "Climate factors and gestational diabetes mellitus risk - a systematic review."
Environmental Health 19, 112 (2020): accessed May 24, 2022, doi: 10.1186/sl2940-020-00668-w; Jiyoon Kim, Ajin Lee, and Maya Rossin-Slater,
"What to Expect When it Gets Hotter," American Journal of Health Economics, vol. 7 no. 3 (2019): accessed January 20, 2022, doi:
10.1086/714359; Yanji Qu, Wangjian Zhang, Ian Ryan, et al., "Ambient extreme heat exposure in summer and transitional months and
emergency department visits and hospital admissions due to pregnancy complications," Science of The Total Environment, vol. Ill (2021):
accessed May 24, 2022, doi: 10.1016/j.scitotenv.2021.146134.
3 Centers for Disease Control and Prevention, What's New, "New Releases for Birth Data," https://www.cdc.gov/nchs/nvss/new_nvss.htm
(accessed May 24, 2022).
4
Ibid.
"Extreme Heat and Your Health," New York City Health, https://wwwl.nyc.gov/site/doh/health/emergency-preparedness/emergencies-
extreme-weather-heat.page (accessed May 24, 2022).
2
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National Weather Service/National Oceanic and Atmospheric Administration6) we have not seen any
significant federal or other government efforts to address this problem.
The marginalization of pregnancy in efforts to reduce health harms from extreme heat is still prevalent.
Human Rights Watch conducted a review in 2020 and found that most plans by local, state, and federal
authorities in the US to respond to heat extremes and climate change miss the threat that extreme heat
poses to pregnancy, particularly for low-income and Black and brown people. Human Rights Watch
reviewed 105 official heat safety web pages, climate action plans, heat plans, heat advisories, disaster
plans, and sustainability initiatives for 18 large US cities, including the 15 most populous, with a total of
32 million people. As of August 2020, only two of these documents, from Chicago and Philadelphia,
explicitly addressed the danger heat poses during pregnancy. Since the review was conducted, New York
City, Miami and possibly other cities have included pregnancy. Concerns about the dangers of heat for
pets, in contrast, were found 37 times.
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
6
"Heat Safety Tips and Resources/' National Weather Service and National Oceanic and Atmospheric Administration
https://www.weather.gov/safety/heat (accessed May 24, 2022).
3
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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.
Please contact Skye Wheeler, wheelesghrw.org, 646 203 2539 for any questions.
Yours sincerely
Skye Wheeler
Senior Researcher
Women's rights division, Human Rights Watch
4
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For the White House Environmental Justice Advisory Council (WHEJAC)
May 11, 2022 COMMENTS of the SAVERGV Advocate for Underserved Communities
» 1. What type of support is needed for disadvantage communities to participate in federal
disaster preparedness or relief programs? (Assuming VCEs are one sort of disaster here.)
Meetings with Native tribe representatives and others (Vecinos, and Sierra Club)
jointly suing Cameron County for excessive beach closures to enable SpaceX to build a till-
unpermitted huge Super Heavy Starship, the largest ever from Earth, and challenging Next
Decade and other companies planning LNG plants. Our topics: Evacuation planning in
anticipation of not only hurricanes, but in the event of a Vapor Cloud Explosion? Our
Emergency Services (fire, police, EMTs) have not been trained to respond to such needs as
VCEs produce, evacuations, public information, serious burns and massive fires in which
the whole sky is ignited due to pools of invisible Methane, lighter than other components
of air, and lying above the other layers, trapping heat in, bringing extreme heat to a
microclimate which becomes irreversibly damaged, burned beyond recovery, as are all
other living things in the huge blast zone. Small fires below ignite the Methane above,
exploding beyond possible remediation.
Appoint an Ombudsman to check on whether funding is getting to appropriate
parties directly. Meet with colonias (for ideas of how, see
https://www.proyectoazteca.org), Vecinos Para el Bienestar de la Comunidad Costera,
Shrimpers, as well as the Esto'k Gna Tribal Nation of Texas, (Carrizo Comecrudo)
representatives whose sacred site is in this LNG construction region at "Garcia Pasture"
surrounded by an irreplaceable upland loma.
Help prevent, mitigate, and adapt to climate disasters through massive new native
tree planting and use of other Eco-System Services nature provides for us which we could
never afford or geo-engineer. Use the Eco-System Services planning process now in force
in Houston area and surrounding forests. We have, prior to COVID, had Rio Reforestation
projects where buses full of students and many community organizations came out to help
plant native trees, shrubs, and replacements for invasive alien species like Salt Cedar in
disturbed areas. But such grassroots programs need to be enhanced and restarted,
reproduced and widely advertised as both educational and important restorations.
Help us stop all pending LNG Projects due to their huge carbon footprints, esp.
Methane (main ingredient of all natural gas). Do not allow Sec'y Granholm to reach the
limit of LNG permitted (30 B cubic meters) but stay with the 15 billion c.m. by end of this
year, on top of 12 million c.m. of LNG already exported.
2. How can Federal disaster relief and aid programs better serve disadvantaged communities
that have historically received fewer federal benefits?
Be sure the funding is getting to the neediest, and to homeowners on board with
renewables. The utility companies, in March, changed the plan so that they need not truly
pay back solar energy producers even if beyond the amount used, so customers cannot run a
credit in their utility bill even if they have supplied electricity to the grid as agreed when
their solar loans were made and the arrays and batteries were installed.
Report back to communities locally (Who is the accountability person?) whether the mere $
30 million for Weatherization PREPAREDNESS has been made available, so contractors can
go ahead and install he 3.5 billion in the Bi-Partisan Infrastructure Bill for Weatherization
Assistance. Many of our underserved minority communities have no literacy or education on
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energy conservation issues, insulation, or weatherization. 1 heir homes are not in good
enough repair even to have weatherization installed. So we do need that 30 million to
other weatherization to help resist extreme storms, floods, etc, or climate change that is
now worsening, with Rio Grande City (not just India and Pakistan) at 114 degrees recently
already and man more 100-degree days measured in recent years! Would this be thru HUD?
Which agencies with a local presence? Ann Cass and her organization, Proyecto Azteca,
https://provectoazteca.wixsite.com/provectoazteca/our team and others, need to be
integrated into a larger loop.
We need people to coordinate and promote e $3,5
billion of Weatherization and the $30 million of weatherization preparedness. As 1 learned
from my experience in the domestic violence prevention and crisis center community, and
other grant writing 1 have done, non-profits often have more vicious competition amongst
themselves for the little funding available than profit-making corporations, who appear to
cooperate better. The Dallas Fed Study had focused on 6 Border Community Counties, the
results of which are largely still true. Most colonia residents are not new immigrants, but
40% live below the poverty line, with 20% more at the poverty level. The garden hose and
'• ' : :: j fig fCpIaCCd SlOWly by W3tef
filtration, and improved water and sewage infrastructure projects across Texas,
¦v.voutube.
Here in the Rio Grande Delta ("Valley") ot Texas, we need similar grant coordination as
'hat Houston
o deal with
rising coastal waters among other problems facing the shrimpers and fishermen and -
women in this region, https://houstonwilderness.org/cgo-program. And see also
: :r.. :ild be used in
addition to the "Mitigation Plan" filed by TX LNG for a project we are resisting. They will
replace just over 40 acres of wetlands their LNG production and export facility will destroy,
according to legal requirements under the 404 (USACE) Clean Water Act provisions, but this
does nothing to mitigate the GHGs, the huge carbon and water footprint, of the LNG
project. Since the scope of the USACE review and comments purports to include only
:h a "channel
ppose the LNG projects (TX and
jr local tribe, the scope of the public
¦ : ¦ .ource of pollution: Methane, a deadly
:: : >ur sacred, fragile eco-system with
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Falcon and several newly listed species c sea grasses, and estuarian communities.
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We need support for proposing, as more adequate mitigation for LNG projects,
something along the Brownsville Ship Channel like the Houston Ship Channel Trees II
Riparian Enhancement of Ecosystem Services fHSC .. multi-year
collaborative project by Houston Wilderness and m partners, focused
on large-scale tree plantings along the 25 miles of the Houston Ship Channel, targeting
native tree species that are ranked in priority based on their respective levels of air pollution
absorption ( and P1V1) as well as water absorption and erosion control -
called "Super i icq, hk n* i nEES One-Pager can be found here.
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3. What process steps and information would help eliminate these disparities?
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4. 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?
-------
1 hank you for your to our hurting needs here in the Lower Rio Grande
Valley,
For 8AVERGV, with appreciation for your work, and hope for our many underserved here,
Sarah Bishop Merrill, M.S., Ph.D.
Harlingen, IX
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PUBLIC COMMENTS ON FEDERAL DISASTER PREPAREDNESS AND RELIEF
AND COMMUNITY RESILIENCE WITH AN ANTI-TRAFFICKING LENS
The Sunita Jain Anti-Traffieking (SJI) at Loyola Maramount University Loyola School of Law
and Leanne McCallum applaud the White House Environmental Justice Advisory Council
(WHEJAC) in its intent to understand equity issues for marginalized communities in the context
of federal disaster preparedness and community resilience. These joint comments will focus on
the intersectionality of federal disaster preparedness, historically disadvantaged communities,
and human trafficking.
The Sunita Jain Anti-Trafficking Initiative (SJI) at Loyola Maramount University
Loyola Law School (LLS) builds upon the school's legacy of research, policy innovation,
and inclusion in the law. SJI is part of LLS's Anti-Racism Center and Loyola
Social Justice Law Clinics. SJI is an evidence-based community informed think tank
that intentionally fills gaps in human trafficking prevention with an intersectional
approach through systemic change and policy innovation. A core value of SJI is that policy
recommendations must be guided by the lived experiences of trafficking survivors. Therefore,
SJI supports survivor consultants whose intersectional trafficking experience reflect SJI's core
values of racial justice, climate justice, immigrant justice, economic justice, and government
accountability.
Leanne McCallum Desselle is a leader in the anti-trafficking field whose work centers on
establishing evidence-based, human rights driven anti-trafficking responses. Leanne"s expertise
is informed by her professional experience facilitating multi-disciplinary human trafficking
initiatives, and also her research on the topics of exploitative labor and human trafficking.
Currently, Leanne is the Strategic Proj ects Manager for the Louisiana Alliance of Children's
Advocacy Centers. The cornerstone of her role is to act as Project Manager for the Louisiana
Child and Youth Trafficking Collaborative (LCYTC), a statewide program to establish multi-
disciplinary teams to respond to cases of human trafficking. Previously, she worked as the Task
Force Coordinator for the Greater New Orleans Human Trafficking Task Force. She has been a
featured expert speaker and consultant for local and national organizations, including: the
International Association of Chiefs of Police, the U.S. Bureau of Justice Assistance, the U.S.
Office for Victims of Crime, Freedom Network USA, National Human Trafficking Training and
Technical Assistance Center, and the HEAL Network.
THE INTERSECTION OF DISADVANTAGED COMMUNITIES, FEDERAL
DISASTER RELIEF PREPAREDNESS, AND HUMAN TRAFFICKING
Preventing trafficking and preventing inequity in disaster relief assistance for disadvantaged
communities is one in the same. Inequity in federal disaster relief preparedness fosters conditions
that make historically marginalized communities vulnerable to trafficking. These historically
marginalized were already not just vulnerable to trafficking before the onset of a natural disaster,
but less likely to be identified as a victim and access the legal protections and benefits afforded
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by trafficking survivors. The more effective and direct the disaster relief assistance is, the less
likely someone from a disadvantaged community will be vulnerable to trafficking.
A. Background on Disadvantaged Communities & Anti-Trafficking Efforts
In order to understand how federal disaster preparedness can better serve disadvantaged
communities while addressing human trafficking, it is necessary to understand the
intersectionality of federal anti-trafficking efforts that disparately impact the very same
disadvantaged communities. The National Action Plan to Combat Human Trafficking
(hereinafter "NAP") defines human trafficking as "a crime of exploiting a person for compelled
labor, services, or commercial sex act(s)" via force, fraud, and coercion[l]. Although the U.S.
government is heralded as having the most comprehensive domestic anti-trafficking legislative
framework in the world, human trafficking survivors from black, brown, and non-citizen
communities (especially those with intersecting identities like disability, LGTBQIA, etc.) are
simultaneously rendered more vulnerable to trafficking while being excluded or lacking
meaningful access to protections and benefits for survivors[2]. These communities are more
likely to experience historical and systemic discrimination as well as encounter the criminal legal
system and be treated as criminals and not victims due to the multi-faceted failure of law
enforcement agencies (hereinafter "LEA") in anti-trafficking efforts.
Moreover, the U.S. government's carceral approach to anti-trafficking (and subsequent focus on
the criminal as opposed to civil legal system) combined with the consistent failure to provide
equal resources and prioritization to labor trafficking has resulted in two general inequities. First,
the weak framework of federal worker protections for laborers in informal economies, who tend
to be non-citizens from communities of color, directly makes them even more vulnerable to
trafficking. Second, labor trafficking cases are under-investigated because criminal law is ill-
equipped to prosecute "coercion" based trafficking claims and civil agencies like the Department
of Labor (DOL), and the U.S. Equal Employment Opportunities Commission (EEOC) are not
provided resources and directives to report, investigate, and prosecute labor trafficking. Lastly,
the expansion of criminal and immigration enforcement systems and their exacerbating overlap
have only further subjected black, brown, and non-citizen communities (and thereby survivors)
to greater risk of vulnerability to trafficking, state-sanctioned surveillance, and exploitation.
B. Background on Natural Disasters and Human Trafficking
The connection between natural disasters and trafficking in the U.S. impacts two groups: the
communities that live in areas that experience a natural disaster and the individuals that come to
the impacted area to engage in disaster relief work (hereinafter "disasters relief workers[3]").
In the U.S., there are multiple reports of spikes in sex and labor trafficking for residents in an
area that experienced a natural disaster[4]. The NAP explains that particular factors make
individuals more vulnerable to trafficking such as "difficult economic conditions, instability in
housing, substance abuse issues, lack of family support to isolate victims and make them wholly
dependent upon their traffickers." In the face of a sudden on-set natural disaster, entire
communities experience these issues. The International Organization for Migration explains how
these exact factors show up in a natural disaster[5]:
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" A sudden-onset disaster can cause unexpected loss of land and lives, and
destruction of means of livelihoods, instantly plunging those without safety
nets into poverty. In the immediate aftermath of a disaster, displacement is
likely to occur, giving space for traffickers to operate and exploit affected
people, their desire for safety and search for means of income to help restore
their lives. This may lead to either a sharp rise in human trafficking if the
region already witnessed exploitation or the creation of a new "hotspot" for
human trafficking."
The Center for Disease Control and Prevention[6] has also clarified that natural
disasters make people more vulnerable to trafficking because they are rendered
homeless (one of the top risk factors for trafficking as reported by survivors to the
National Human Trafficking Hotline[7]), disconnected from their emotional and social
support networks, and unable to safely earn income and be self-sufficient.
Furthermore, natural disasters also require extensive and long-term restoration work.
Disaster relief workers are individuals who work primarily in the industries of
construction, debris clean-up efforts, hospitality, and maid service industries in the
wake of a natural disaster[9]. This labor force is unique in that disaster restoration
work requires "a large number of workers that is instantly mobile and open to arduous
and dangerous work [10]." The limited data from Hurricane Katrina, Irma, and Harvey
highlight that the vast majority of resilience workers moved into the effected area for
the work, identify as Latino or Hispanic, and are undocumented[l l].In an extensive
survey by the National Day Labor Organizing Network (NDLON) of 171 day laborers
after Hurricane Idea, 83% of workforce in Hurricane Ida was undocumented.
Furthermore, construction, environmental remediation, and landscaping contractors
were responsible for 65% of the jobs worked by day laborers[12].
Several human rights organizations and investigative journalists[13] have documented the
extensive intersectional issues disaster relief workers face because they are undocumented, new
to the area and isolated from their support systems, non-English speaking, rely on their employer
for basic needs like food, water, and sometimes shelter since they are uniquely in a disaster zone,
and in dire need of economic security.
C. The Importance of Effective and Accessible Disaster Relief in Mitigating Trafficking
Disaster relief can provide the safety net that disadvantaged communities need in order to bypass
the factors that lead to exploitation and trafficking: basic necessities like food and water, short
and long term housing, financial security, connections to case management services, etc. If
disaster relief efforts fail or continue to be inequitable, low income communities of color will be
vulnerable to force, fraud, and coercion in order to have access to those very factors.
Furthermore, if they are forced to undertake criminal activity as part of their trafficking
experiences (which can range from prostitution, felony level assault, to theft), survivors from
communities of color are more likely to be labeled as criminals and not victims by law
enforcement and other actors in the criminal legal system. For non-citizens, racial profiling
proliferates non-citizen arrests made by local LEAs and ICE, with the added burden that an arrest
can trigger placement in removal proceedings or immigration detention.
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No one suffers more at this intersection than young black girls [32], They are statistically more
likely to be treated as criminals and not victims in comparison to any other racial group. They are
arrested at exorbitantly higher rates for prostitution, have their cases adjudicated through the
juvenile justice system, and are more likely to be detained in a locked facility than their white
counterparts. Black non-citizens are more likely to remain in detention longer than other
migrants, pay significantly higher bonds for release, and make up 24% of all solitary
confinement detentions even though they make up only 4% of those in ICE custody.
QUESTION 1
What type of support is neededfor disadvantaged communities to participate in federal disaster
preparedness or relief programs?
The appropriate question for WHEJACK to ask is not about the kind of support needed to
encourage participation, but why should disadvantaged communities participate and trust
agencies in the first place given the legacy of racial and economic inequity in federal disaster
relief preparedness?
The legacy of slavery, segregation, racist immigration policies permeate the contemporary
discussion of effective disaster relief preparedness. Historically marginalized communities
(which are irrefutable black, brown, and low-income with other intersectional identities) are
more likely to live in disaster zones with inadequate public transportation options as a direct
result of redlining, less likely to qualify and receive insurance and federal aid, and more likely to
be criminalized in criminal and civil enforcement systems for survival crimes post disaster.
Furthermore, the reality style cable news television coverage on Hurricane Katrina made clear to
the world ".. .that the U.S. has not resolved fundamental domestic disparities and inadequacies.
Katrina did not create these inequities; it simply added an important reminder that they are
deeply embedded and constitutive of American political, economic, and social life[14]).
However, almost twenty years after Hurricane Katrina, The New Orleans Data Center[15] tells
us that the underlying factors of race and economic inequality remain the same. Low-income
populations and communities of color continue to live in the parts of the Greater NOLA that are
most flood-prone and prone to all forms of severe weather. They continue to be the least likely to
be able to evacuate for dangerous weather even though they're most likely to experience it. As
evidenced by Hurricane Ida, people from mostly white affluent neighborhoods were more likely
to receive disaster relief than low-income populations from communities of color.
The trust between federal agencies and disadvantaged communities is not something to be
"rebuilt," but earned. SJI and LMD strongly suggest that trust earning efforts be envisioned
along the lines of Federal Emergency Management Agency (FEMA)'s definition of equity and
guiding equity principle- to ensure that all people are helped before, during and after disasters,
based on their specific needs.
SJI and LMD suggest the following:
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1. Invest in long-term relationships with a variety of grassroots CBOs that prioritize
intersectionality and are run, operated, and staffed by people with lived experiences on
the issues in the community that they serve.
Federal disaster relief agencies and personnel must engage in long-term, ongoing, and frequent
meetings with local practitioners and impacted communities before the onset of a natural
disaster. It is necessary for federal agencies to understand the legitimacy of the mistrust of
disadvantaged communities as well as the gaps that CBOs have filled when disaster relief efforts
have not reached these communities. Federal agencies must understand that impacted
communities are more likely to trust CBOs over them because CBOs have delivered results and
are from the communities they serve.
For example, when farmworkers in wildfire regions in California were not receiving N95 masks
from employers despite a local mandate, the Mixteco/Indigena Community Organizing Project
distributed around 15,000 masks directly to workers, the bulk of which were donated by the local
public health department 16], Another example is the work of New Orleans Worker's Center for
Racial Justice, The National Guestworker Alliance, and Resilience Force1. In the aftermath of
Hurricane Harvey and Ida, they have engaged in grassroots worker and immigration know-your-
rights sessions directly on work place sites, created pathways for undocumented disaster relief
workers to testify before local and state government committees, provided laminated badges on-
site to workers who lack identification to avoid harassment and potential immigration concerns,
retrieved passports from Sheriff Offices so that workers could report without facing immigration
consequences, contacted the Department of Labor to file wage and hour claims, and formed
multi-ethnic coalitions to exert pressure on government agencies to take on civil lawsuits against
corporations.
2. To encourage non-citizens to participate in relief programs, federal agencies must (a)
eliminate or minimize immigration enforcement and (b) work alongside trusted CBOs to
educate immigrant communities on new laws surrounding federal benefits and
immigration law. These efforts will in turn mitigate trafficking while encouraging non-
citizen trafficking survivors to report their victimization.
Although SJI and LMD recognize that the Biden Administration is trying to undo the punitive
immigration policies under the Trump Administration, ultimately non-citizens still fear coming
forward to seek state and federal benefits in a natural disaster[17].
The Trump Administration's xenophobic rhetoric, public charge rule[18], and emphasis on
deportation in removal proceedings continue to isolate non-citizen communities. For example,
The Protecting Immigrant Families Coalition/BSP Research Survey makes clear that the Trump
public charge rule continues to have a powerful "chilling effect" on immigrant families. Nearly
half (46%) of families who needed assistance during the COVID-19 pandemic abstained from
applying for assistance due to concerns over how doing so could impact their immigration status.
Furthermore, more than two in five respondents believe "applying for assistance programs could
1 See generally McCallum, L. (2020). Reflections from the Field: Disparate responses to labour exploitation in post-Katrina
Louisiana. Anti-Traffieking Review, (15), 21-41. https://doi.org/10.14197/atr.201220152:
https://www.newyorker.com/magazine/2021/11/08/the-migrant-workers-who-follow-climate-disasters
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cause immigration problems," and 34% were unsure of the consequences of using public
assistance programs. Awareness was especially low among AAP1 communities.
The fear of immigration consequences for seeking public assistance is only exacerbated in
natural disasters which have always corresponded with an increase in immigration enforcement
and surveillance.
Most major natural disasters have created a simultaneous need for cheap labor for dangerous
work, which can be supplied by undocumented immigrants and an increase in DHS, ICE, and
other LEA surveillance and enforcement. In the aftermath of Hurricane Katrina, DHS announced
it deployed 750 officials to the Gulf Coast, which included Detention and Removal Staff as a
"security effort" to enact a "zero tolerance policy" towards migrant workers[19]. Black and
immigrant laborers have repeatedly reported harassment on the street while working from law
enforcement throughout multiple disasters. This situation was only exacerbated when law
enforcement was deputized by ICE to undertake immigration enforcement. During Hurricane
Michael, the Bay County Sheriffs Office staged a series of undercover sting operations where
resilience workers were arrested for felony charges of "contracting without a license during a
state of emergency," turned over to ICE, and deported. Throughout these operations, the
employers themselves were never held accountable.
As discussed in Question 4, SJI and LMD strongly suggest that immigration enforcement efforts
be suspended in the aftermath of a natural disaster. This will send a clear message from the
federal government that it wants to help non-citizens as opposed to subjecting them to civil and
criminal enforcement.
As discussed above, federal agencies should meaningfully invest in relationships with CBOs,
who in turn can continue serving as trusted messengers to non-citizen communities.
All of these efforts will mitigate the factors that make marginalized communities vulnerable to
exploitation and trafficking in the wake of a natural disaster. Individuals will not feel as socially
isolated, will receive government verified information by people from their own communities
who they trust, have a meaningful understanding of their rights as they navigate a sudden loss of
economic security, and feel safer coming forward to report victimization to at least CBOs.
3. To encourage sex and labor trafficking survivors to come forward, federal agencies must
not rely on law enforcement agencies (LEAs) to identify survivors, avoid criminalizing
survivors (including in the civil immigration system), work with CBOs doing grassroots
know-your-rights work with marginalized communities, and work directly with former
survivors on messaging and external engagement.
Despite a plethora of data indicating the failure of LEAs to identify survivors, state and federal
agencies still rely on them to do so. Freedom Network, ACLU, and CAST have submitted
information on this at length. USC's International Human Rights Clinic's Report on LEAs and
sex trafficking underscores that LEAs simply arrest large numbers of sex workers who are
primarily black women. Physical and sexual abuse by LEAs to arrestees from marginalized and
intersectional communities (particularly black, non-citizen, and LTBQIA[1]) is well
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documented[2], particularly towards sex workers. CBOs have also reported how state and local
LEAs engage in abuse during investigations of AAPI massage parlors.
[1] https://scholarship.law.wm.edu/cgi/viewcontent.cgi?article=1462&context=wmjowl
[2] https://www.bwjp.org/assets/documents/pdfs/webinars/dhhs-police-sexual-misconduct-a-
national-scale-study.pdf
QUESTION 2
How can Federal disaster relief and aid programs better serve disadvantaged communities that
have historically receivedfewer federal benefits?
SJI and LMD recommend the following for relief and aid programs to better serve historically
marginalized and disadvantaged communities, particularly to mitigate exploitation and
trafficking:
1. Shift to an intersectional approach in understanding the multiple and overlapping
identities of disadvantaged communities
In order to better serve disadvantaged communities, federal disaster relief and aid programs must
understand the intersectional identities of the communities they purport to serve.
The concept of intersectionality describes the ways in which systems of inequality based on
gender, race, ethnicity, sexual orientation, gender identity, disability, class and other forms of
discrimination "intersect" to create unique dynamics and effects. From a policy perspective, the
underlying idea is that all forms of inequality are mutually reinforcing and must therefore be
analyzed and addressed simultaneously to prevent one form of inequality from reinforcing
another.
The consequence of not integrating environmental justice with racial, economic, and immigrant
justice is the fostering of conditions for exploitation and trafficking. For example, in LMD's
experience on the ground post Hurricane Ida in Southeast Louisiana, federal disaster aid workers
were limited in their ability to identify and assist immigrant labor trafficking survivors. Despite
knowing that immigrant workers were doing roofing repairs and building reconstruction under
exploitation circumstances, state and federal aid workers did not have the tools or training to
screen for labor exploitation, offer resources to the workers, did not speak Spanish or any
indigenous language, and had limited interpretation services available. The result was
unaddressed labor trafficking and exploitation of disaster relief workers after Hurricane Ida.
2. Lower the barriers for disadvantaged communities to rapidly receive financial support
SJI and LMD understand that FEMA Equity Plan does address the need to understand the
barriers to receive financial support and lower them. However, there is little in the plan that
addresses how individuals with limited online capacity and education will be able to get the
financial support they qualify for.
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For example, many FEMA applicants have to complete a Small Business Association Loan
request to get reimbursement for destroyed property even if they don't want a loan, but just need
financial assistance. This is an example of an undue burden that is purely administrative and
harder to complete for low-wage workers, people with limited access to Wifi, Non-English
speakers, and those with limited education. Obviously, these would be individuals from
disadvantaged communities.
Another example is the failure of the Blue Tarp Campaign, particularly in Houston, Texas[20]
and following Hurricane Ida in Louisiana. Distribution of State and Federal aid from the Blue
Tarps happened at a slow trickle. Homeowners were at risk of losing insurance coverage for not
conducting mitigation efforts even though they were not provided the financial aid they were
promised to undertake the mitigation efforts.
Economic insecurity and loss of livelihood have always been a primary factor in rendering
people vulnerable to trafficking and exploitation. The faster and more effective the federal aid in
a disaster relief, the less likely disadvantaged communities will be vulnerable to the force, fraud,
and coercion of traffickers.
3. Institutionalize a direct, frequent, and ongoing presence with disadvantaged communities
to ensure approaches are effective and community-driven rather than prescriptive.
Disadvantaged communities should be directly asked what they need before, during, and after a
natural disaster. Federal agencies need to engage in long term, frequent, and direct conversations
with CBOs and community members, which in turn creates a space of trust and open
communication.
4. Protections for disaster relief survivors must extend to disaster relief workers
Despite the fact that disaster relief workers are undertaking the arduous, dangerous, and
hazardous labor of rebuilding America, federal disaster relief and aid programs have yet to
meaningfully extend protections and benefits to disaster relief workers. Without an accessible
framework for worker rights that are specific to the circumstances of disaster relief workers, the
U.S. government will continue two inadvertently foster conditions that encourage trafficking and
exploitation with impunity.
SJI and LMD suggest the following to ensure that disaster relief workers are protected from
exploitation and trafficking:
(i) FEMA must coordinate with DOL, OSCHA, and EEOC to
strengthen worker protections and trafficking reporting, investigation, and
prosecution.
FEMA has historically not provided cash assistance or Disaster Unemployment Assistance to
people that are undocumented. However, it has not coordinated with other federal agencies
(i.e. DOL, OSCHA, EEOC) which have the jurisdiction to work with non-citizen
communities on worker's rights, exploitation, and trafficking. SJI and LMD believe that this
coordination should be aligned with FEMA's Equity Principle of protecting workers before,
during, and after a natural disaster. These civil federal agencies should be appropriated with
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enough resources, training, interpreters, and other staff to (at minimum) build long-term
relationships with CBOs that work with non-citizen resilience workers, deploy rapid response
teams directly to natural disasters to accommodate the influx of workers, and expedite legal
claims to earn the trust of the community.
(ii) State and Federal prosecution response to trafficking must shift
from a criminal to civil legal system in the wake of a natural disaster
Despite the fact that there are more reports of labor trafficking than sex trafficking to service
providers[21], labor trafficking remains woefully under-investigated. Moreover, civil agencies
with jurisdiction to undertake labor trafficking claims lack the resources and directives to report,
investigate, and prosecute these claims. For example, despite the fact that there were nine
successful civil litigations on behalf of disaster relief workers and zero criminal cases, there was
only one Spanish speaking interpreter for the entire State Department of Labor for Louisiana.
The majority of labor trafficking claims are premised on the concept of "coercion" under the
Trafficking Victims Protection Act, which is difficult to prosecute in a criminal legal
framework[22],
(iii) DHS must stop relying on ICE to identify labor trafficking
survivors and turn to CBOs instead
As specified in their own reports and trainings[23], the many members of federal law
enforcement agencies believe that undocumented workers will readily report their victimization
to an immigration,despite the fact that some of these agencies are charged with conducting
arrests and raids for their very detention, deportation, and separation from their families. The
U.S. government has evidence of the limitations of identifying victims of labor exploitation
through ICE, yet these practices continue. Also, the U.S. government continues to prioritize ICE
for survivor identification knowing that employers use this realistic fear of law enforcement and
immigration retaliation to subject undocumented immigrants to labor trafficking when that is
exactly what ICE does.
Government agencies continue to use words like "mistrust" and "hesitation" in describing why
disaster relief workers fail to approach law enforcement agencies for help. It highlights a lack of
understanding of the lived experiences of undocumented workers in the U.S. More importantly,
it highlights that U.S. policy prioritizes immigration enforcement over worker rights while
expecting migrant workers to readily comply with the very enforcement priorities that harm
them.
QUESTION 3
What process steps and information would help eliminate these disparities?
SJI and LMD recommend the following steps to help eliminate disparities:
1. Federal Agency Trainings on disaster relief should include human trafficking survivors
whose victimization resulted from a natural disaster.
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Federal agencies in charge of equity should include sex and labor trafficking survivors (including
disaster relief workers) at all parts of policy planning to ensure that the most vulnerable
communities are included and conditions fostering exploitation and trafficking are mitigated.
Survivors and their communities should be treated as experts with lived experience. They are the
best individuals to convey the intersectionality of their identities, the barriers they continue to
face in accessing disaster relief programs, and what solutions would be the most accessible and
meaningful to them.
2. FEMA's Equity plan must specify a methodology and implementation for language
access:
Although FEMA's Equity Plan addresses the need to "address any language barriers that could
present administrative burden to individuals with limited English proficiency," there is no further
information on how FEMA plans to do that. FEMA must thoughtfully articulate a methodology
for picking the languages it chooses to provide access to, how it will verify the accuracy of the
information, etc. to ensure that the language access program is effective. SJI and LMD strongly
recommend including non-english speakers from disaster prone areas at every stage of the
development of the language access program.
There are a plethora of examples of how language access plans have failed in understanding the
communities they purport to serve. For example, during the 2017 Thomas fire, Ventura County
used Google Translate to share emergency information in Spanish throughout the first days of
the crisis, resulting in grievous mistakes, including translating "wildfire" into the Spanish word
for "hairbrush." Issues with translation can also confuse mandatory evacuation orders, a tool
crucial to moving residents to safety[24 |. Another example is in Sonoma County, where more
than 100,000 of the state's farmworkers are Indigenous and speak Mixtech and not Spanish, but
disaster relief FAQs were provided only in Spanish[25|.
3. Invest in equitable access to technology
As explained supra, disadvantaged communities will not have equal access to wifi, internet, etc.
as wealthier counterparts. Equitable access to information about evacuation orders, safety
protocols, aid applications that are online etc. will strengthen someone's connection to social and
economic support, mitigating their chances for exploitation and trafficking.
4. Ensure that disaster relief websites, hotlines, online portals for application etc. remain
accessible at a variety of times to accommodate a wide range of people.
Websites operated by state and federal governments with information about disaster relief aid
have consistently crashed in the first week of major natural disasters like the Dixie Wildfire as
well as Hurricane Katrina, Ida, and Harvey. The delay in accessing critical information about
evacuation measures, safety protocols, and disaster relief aid can be prevented if federal agencies
invest in a robust 24/7 technical assistance program.
QUESTION 4:
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The following is a list of steps Federal Agencies and the White House can take in addressing the
intersectionality of disadvantaged communities, climate change, natural disasters, federal disaster
relief preparedness, and vulnerability to trafficking:
THE DEPARTMENT OF LABOR and EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
1. DOL and EEOC must be funded to have enough staff, training, and resources to address
labor exploitation and trafficking in the wake of a natural disaster
Neither the state nor federal DOL and/or EEOC have been funded or prioritized in a way that
would enable them to investigate, prosecute, and protect labor exploitation or trafficking victims
before, during, or after a natural disaster. A robust State and Federal Department of Labor that
works alongside marginalized communities, workers, and survivors is necessary in order to:
• Have extensive survivor-led trainings on what constitutes force, fraud, and coercion
under the TVPRA. Most agencies focus on identifying the kind of trafficking as opposed
to the elements of trafficking itself
• Evaluate what solutions worked and didn't work for different marginalized communities
• Meaningfully extend the legal protections afforded to labor trafficking survivors under
the TVPRA
• Encourage non-citizen communities to engage with civil federal agencies for wage and
hour and trafficking investigations
2. DOL/EEOC should be included in FEMA's Equity Plan as a viable solution to including
disaster relief workers and non-citizen communities
The FEMA Equity Plan notably fails to mention the DOL or EEOC at all even though FEMA is
the agency in charge of coordinating all federal disaster relief efforts across federal agencies.
THE DEPARTMENT OF HOMELAND SECURITY
1. ICE must expand the Protected Area Memo
ICE should expand the existing provision under Protected Areas Memorandum[26] to include "
a place where disaster or emergency response and relief is being provided, which includes all
work and workers associated with disaster restoration relief...". Although the "Protected Areas
Memorandum" includes " a place where disaster or emergency response and relief is being
provided," ultimately the provision only protects people receiving services and not disaster relief
workers. An expansion of this provision for disaster relief workers would delegitimize the
coercive power of threats of detention deportation for undocumented workers. It sends a message
from the federal government to workers that "their safety and well being are paramount[27],"
which can potentially encourage more non-citizen survivors to report trafficking and cooperate in
investigations.
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2. DHS Trainings to FEMA on survivor identification should include disaster relief
trafficking survivors
The 30-minute or 1 hour training[28] is done by DHS's Blue Campaign and is a general
overview of what trafficking is. It is not specific to disaster relief workers, what trafficking looks
like in the rebuilding process, or include appropriate referrals. It does not focus on the issues of
subcontracting from larger disaster relief firms backed by private equity initiatives, the physical
health issues they face as a result of disaster relief work, the trust they place in worker rights
organizations and CBOs, their fear of government agencies, etc. Lack of information about
resilience workers and the nuances of their exploitation make it highly unlikely that FEMA will
be able to identify vulnerable populations and fill gaps in their trafficking prevention work that
are applicable. Resilience workers should be part of the training from brainstorming to delivery
to communicate the nuances of their exploitation and fears.
FEMA
1. Expansion of shelter and food policy for disaster relief workers
FEMA can expand its policy on shelter and food for emergency/response personnel to include
disaster relief workers. Disaster relief workers exist in the same environment as the communities
impacted by the natural disaster, meaning they also have limited access to functioning
transportation, internet, grocery stores, etc. They are also isolated from their normal support
structures coupled with reliance on their employer for basic necessities like food, shelter, and
water makes workers more vulnerable to trafficking. Having another easily accessible avenue for
basic necessities could mitigate potential exploitation.
2. Include human trafficking survivors in FEMA policy planning
The FEMA Equity Plan[29] cites several opportunities for community consultation. SJI and
LMD strongly suggest that survivors be included at every point in the policy planning process to
ensure that the needs of most vulnerable communities are meaningfully addressed. For example,
survivors can be included in the following ways in the FEMA Equity Plan:
• The Equity Enterprise Steering Group (particularly in the new strategic plan subgroup
• The restructuring of the Public Assistance Delivery Manager Program (which provides
technical assistance to historically underserved communities)
• The Recovery Support Function Leadership Group which focuses on equity and recovery
in disaster relief
• As leaders in FEMA's "external engagement" plan to undertake community surveys,
focus groups, mailers, door to door canvassing etc. Survivor to survivor peer leadership
and engagement is a powerful and effective tool in connecting with vulnerable
communities that distrust federal agencies and in reaching actively trafficked individuals.
3. Specify methodology and implementation plan for language access:
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FEMA must update its equity plan to clarify the specific methodology and implementation on
language access to answer the following:
• How will FEMA determine the exact barriers before, during, and after a natural
disaster?
• How will FEMA assess which languages should be provided in-person for disaster
field offices and via the national FEMA hotline?
• What systems will FEMA put in place to ensure that the non-English materials are
both available to potentially impacted communities, and are accurate?
• What kind of formal evaluations will FEMA undertake with non-english speaking
communities before, during, and after a disaster relief to ensure that the information
provided was accessible?
4. Reporting data for FEMA's Individual Action Program should be aggregated to include
Non-English speakers.
5. Expand FEMA Equity Plan to include individuals that are not direct disaster assistance
applicants but still impacted by the same natural disaster.
SJI and LMD commend the explicit emphasis in the FEMA Equity Plan to gather "feedback and
recommendations" from disaster assistance applicants before, during, and after a natural disaster.
However, there is no mention in the plan on how to evaluate which communities still
encountered barriers in accessing disaster assistance and why. Without an explicit plan to address
this caveat, trafficking survivors (and especially disaster relief workers) will not be able to
meaningfully access disaster relief benefits or protections.
THE WHITE HOUSE
SJI and LMD applaud the Biden Administration in bringing an intersectional whole-of-
government approach to environmental justice, trafficking, and marginalized communities. In
order to reduce disparities in disaster relief and trafficking, the White House can undertake the
following:
• Pathway to Citizenship for Essential Workers: Disaster relief workers qualify as essential
workers. Under both Democratic and Republican administrations, lack of immigration
status has always been considered a vulnerability to trafficking. The potential of
immigration status would send a message to non-citizen workers that they have legal
rights across the sectors of employment, immigration, and climate change. It would also
send a message to traffickers (both individual and large-scale corporations) that they can
no longer exploit such a vulnerable population.
• Expedite "Internet for All" programs to ensure that states prone to natural disasters have
affordable internet access: As discussed supra, reliable internet access is essential for
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federal and state agencies to provide services and for marginalized communities to access
up-to-date information on immediate disaster relief services. Currently, to participate in
some of the programs, states must submit a letter of intent and a planning funds budget.
However, hurricane season is already underway and wildfire season is approaching in a
few ways. The application process should be expedited for states prone to 2022 climate
disasters.
• Include disaster relief workers on the U.S. Advisory Council on Human Traffickingr31"|:
The whole-of-government approach to workers rights, climate change, immigration, and
trafficking should be guided by the lived experiences of vulnerable communities. The
U.S. Advisory Council on Human Trafficking is supposed to directl advise the
President's Interagency Task Force and the Senior Policy Operating Group. There is now
way for the White House to understand the intimate and nuanced intersectionality of
disaster relief and trafficking without the guidance of survivors at the highest level of
government.
[1] https://www.whitehouse.gov/wp~content/uploads/2021/12/National-Action-Plan-to-Combat-
Huroan-Trafficking.pdf: see also 22 U.S.C. §7102(4); 18 U.S.C. § 1591; 22 U.S.C. §7102(11);
18 U.S.C. § 1591
[2] See generally (E)racing Childhood: Examining the Racialized Construction of "Childhood"
and "Innocence" in the Treatment of Sexually Exploited Minors. 62 UCLA L. Rev. 1586 (2015)
[4] https://www.huffpost.com/entry/haryey-imia-and-maria-natural-disasters-and-
human b 59d55cdbe4b085c51090ad63;
https://www.antitraffickingreview.org/index.php/atijournal/article/view/487
[6] https://www.cdc.gov/disasters/human_trafficking_info_for_shelters.html
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[7] https://polarisproject.org/blog/2017/09/natural-disasters-and-the-increased-risk-for-human-
trafficking/
[8] https://nhttac.acf.hhs.gov/sites/defaultyfiles/2020-
02/Trafficking%20Prevention%20and%20Disaster%20Response%20Literature%20Review.pdf
[9] Moreover, the racial origins of weak labor protections for disaster relief workers have
historically always been overlooked. Black men and migrants have routinely been overlooked.
Black men and migrants have routinely Moreover, the racial origins of weak labor protections
for disaster relief workers have historically always been overlooked. Black men and migrants
have routinely been forced (sometimes at gun point at the behest of the U.S. government) to
undertake exceptionally hazardous and dangerous work in the aftermath of a natural disaster. In
1900, black men were forced at gunpoint by white soldiers to perform grotesque disaster
restorations, including dumping corpses into the sea. In 1928, 75% of deaths from the Great
Okeechobee Hurricane in Florida were migrant agricultural workers, many of them black6.
Although the structure of the disaster relief industry has transformed in both the private and
public sector, ultimately the exploitation and lack of meaningful protection of black and brown
essential workers endures.
[10] https://www.newyorker.com/magazine/2021/ll/08/the-migrant-workers-who-follow-
climate-disasters
[11] Id.
[12] https://ndlon.org/wp-content/uploads/2022/04/Recovering-from-Climate-Disasters-Report-
2.26.22.pdf
[13]
[14] http://jcia.aciajj.org/files/2012/02/Miller-and-Rivera-2.pdf
[15] https://www.datacenterresearch.org/topic/housina/
[16] https://www.nasw.org/article/wildfire-concerns-grow-farm-workers-remain-vulnerable
[17] https://www.nytimes.com/2020/03/18/us/coronavirus-immigrants.html
[18] https://www.nilc.org/wp-content/uploads/2020/03/Public-Charge-What-Advocates-Need-to-
Know-Now.pdf
[19] https://www.newyorker.com/magazine/2021/ll/08/the-migrant-workers-who-follow-
climate-disasters
[20] https://www.houstonpublicmedia.org/articles/news/2016/12/29/181149/the-ordeal-of-a-
houston-senior-citizen-who-lived-under-a-blue-tarp-for-eight-years/
[22] Kim, Kathleen, Psychological Coercion in the Context of Modem-Day Involuntary Labor:
Revisiting United States v. Kozminski and Understanding Human Trafficking. University of
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Toledo Law Review, Vol 38, No. 3, 2007, Loyola-LA Legal Studies Paper No. 2007-40,
Available at SSRN: https://ssrn.com/abstract= 1021819
[23] https://nhttac.acf.hhs.gov/sites/defaultyfiles/2020-
02/Trafficking%20Prevention%20and%20Disaster%20Response%20Literature%20Review.pdf
[24] https://www.nasw.org/article/wildfire-concems-grow-fami-workers-remaiii-vulnerable;
https://www.latimes.com/opinion/story/2021-10-28/farmworkers-immigrants-wildfires-
california-climate-cri si s
[25] https://www.latimes.eom/opinion/story/2021-10-28/farmworkers-immigrants-wildfires-
california-climate-cri si s
[26] https://www.dhs.gov/sites/default/files/publications/21_1027_opa_guidelines-enforcement-
actions-in-near-protected-areas.pdf
[27] https://ndlon.org/wp-content/uploads/2022/04/Recovering-from-Climate-Disasters-Report-
2.26.22.pdf
[28] There is a 30 minute training that is publically available online but FEMA policy states that
the training is 1 hour, https://nhttac.acf.hhs.gov/sites/default/files/2020-
02/Trafficking%20Prevention%20and%20Disaster%20Response%20Literature%20Review.pdf
[29] https://www.fema.gov/sites/default/files/documents/fema_equity-action-plan.pdf
[30] https://www.dhs.gov/sites/default/files/publications/dhs-case-management-pilot-program-
[31] The United States Advisory Council on Human Trafficking, established by the Justice for
Victims (Ticking Act (JVTA), enacted on May 29, 2015, provides a formal platform for
trafficking survivors to advise and make recommendations on federal anti-trafficking policies to
the President's Interagency Task Force to Monitor and Combat Trafficking in Persons (PITF).
Each member is a survivor of human trafficking, and together they represent a diverse range of
backgrounds and experiences. The Council is appointed by the President for two-year terms.
https://www.state.gov/u-s-advisory-council-on-human-trafficking/
[32] https://www.whitehouse.gOv/briefing-room/statements-releases/2021/04/27/fact-sheet-
biden-harri s-admini strati on-i ssues-an-executive-order-to-rai se-the-minimum-wage-to-15 -for-
federal -contractors/
[33] https://www.scientificamerican.com/article/advisers-rebuke-feroa-for-racial-disparities-in-
disaster-aid/; see also https://19thnews.org/2021/10/after-storms-batter-louisianas-parishes-
black-women-lead-the-way/
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ENVIRONMENTAL
HEALTH TRUST
Wireless is an Environmental Justice Issue
We recommend the following priority actions:
• Launch and develop an EPA's research program on EMFs and develop safety limits that protect
people, wildlife, trees and plants so that ensuring levels of EMFsin environment are safe is an
agency-wide responsibility.
• Air should be designated as a wildlife habitat.
• Levels of electromagnetic radiation and impacts to humans and wildlife must be included in all
environmental assessments.
• Develop a comprehensive framework for considering cumulative impacts related to
telecommunications infrastructure in communities and wireless networks in schools and the
workplace
• Build the capacity of underserved communities to provide their experience to EPA related to
telecommunications siting and wireless networks.
• Develop EPA's internal capacity to engage underserved communities regarding EMF impacts.
• Implement clear and accountable processes to act based on communities" input.
• Integrate participatory (community) science into EPA's research and program implementation and
include EMFs.
• Ensure an evaluation of climate impacts and equity impacts for all new proposed
telecommunications infrastructure by developing a framework for evaluation that communities
can use locally.
European Parliament requested a research report "Health Impact of 5G" released in July 2021 concluding
that commonly used RFR frequencies (450 to 6000 MHz) are probably carcinogenic for humans and
clearly affect male fertility with possible adverse effects on the development of embryos, fetuses and
newborns. 5G will increase ambient levels of wireless radiofrequency radiation. Peer-reviewed research
has demonstrated a myriad of adverse effects from wireless radiofrequency radiation including increased
brain cancer, DNA damage, oxidative stress, immune dysfunction, altered brain development, damaged
reproduction, sleep changes, hyperactivity, and memory damage. (MORE RESEARCH HERE)
Higher Environmental Levels of Radiofrequency Radiation
• Urban areas have more people and more smartphones, as well as more cell towers. The higher
density of wireless networks (more wireless antennas and base stations) results in higher levels of
environmental radiofrequency radiation levels.
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• Cell towers have been found to be more often placed on schools in lower income areas. Wealthy
communities are more aware of this issue and often immediately organize to halt proposed cell
towers at schools.
• Low income families and renters have less ability to move/mitigate exposures.
Cell antennas are being put up in front of apartments and renters are not being informed nor are they a
part of the decisionmaking process.
Financial inequity limits ability to reduce environmental and personal exposures
• Private schools will get private funding to install wired networks and reduce RF exposures.
• While often wealthier, educated families inform their children to decrease exposure (like keep the
phone away from your brain) and have the financial means to purchase adapters and hardwire
computers, people with less financial means remain uninformed about wireless radiation. Even
when families in under-resourced communities are aware, they do not have the money to buy the
hardware needed for safer technology and lack the resources to fully implement RF reduction
strategies. Many families are struggling to get any internet access at all and are not in a privileged
position to choose wired technologies over wireless in their home.
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Networks Often Tested in Urban Areas/Schools
• Schools in low income areas are used as test beds for industry to try out new wireless products
such as 5G and virtual reality despite no research indicating it will support academic achievement
of the students.
• Urban areas are 5G Test Cities.
Occupational Exposures to Pregnant Women are Unmitigated
• As an occupational health issue, many people have limited ability to reduce RFR without risking
losing their jobs.
Health care inequalities will further exacerbate health inequities
• Health care inequalities will further exacerbate health inequities as people in under resourced
communities will receive unequal care for the damages from exposure to RFR.
• Communities with higher environmental exposures to toxic chemicals, heavy metals (such as
lead) and air pollution will have disproportionate impacts from RFR exposure as research
shows a synergistic effect between EMFs and toxic agents.
• Racial/ethnic minorities are 1.5 to 2.0 times more likely than whites to have most of the major
chronic diseases. Oxidative stress is understood to play a role in the development of many chronic
diseases as well as cancer. Research reviews ( Schuermann and Mevissen. 2021. Yakvmenko et
al. 2016) repeatedly find that non-ionizing EMF exposure can cause oxidative stress by the
increase in free radicals.
• Research links non-ionizing radiation with diseases that minority communities already have have
higher rates of such as obesity, asthma and diabetes. As another example, African American
women face a significantly higher risks of having a miscarriage and replicated research links non
ionizing radiation to increased miscarriage risk.
• Health care inequalities will further exacerbate health inequities as people in under-resourced
communities will receive unequal care for the damages from chronic disease caused by or
exacerbated by RFR and other non ionizing electromagnetic radiation exposure.
5G and the Internet of Things will increase energy consumption and exacerbate climate change
A 2022 review by the University of Sussex Business School entitled "The energy use implications of 5G:
Reviewing whole network operational energy, embodied energy, and indirect effects" published in
Renewable and Sustainable Energy Reviews finds that the notion that 5G is green technology is not
currently backed up by a strong, publicly available, fully transparent evidence base. The researchers did a
literature review to examine whole network level assessments of the operational energy use implications
of 5G, the embodied energy use associated with 5G, and indirect energy use effects associated with
5G-driven changes in user behaviour and patterns of consumption and production in other sectors of the
economy. The authors warn that ,"the widespread adoption of unlimited data subscriptions for 5G users
and the facilitation of advanced and data-intensive mobile services such as VR and more sophisticated
mobile gaming could "encourage energy-intensive user practices, contribute to ever-growing levels of
data traffic, and counteract the energy-saving potential of 5G efficiency improvements."
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5G requires millions of new cellular antennas called "small cells" -basically shorter cell towers- to be
built in neighborhoods directly in front of our homes. These 5G antennas are to connect with billions of
new wirelessly connected "smart" devices referred to as the Internet of Tilings (IOT).
Wireless companies are well aware that 5G will increase overall energy consumption
David Bruno, an expert in electromagnetic pollution, obtained a document from the National Frequencies
Authority (ANFR) concerning the installation of an Orange relay antenna site in Marseille. According to
him, "the colossal power of 5G antennas is to be feared". He analyzed the Orange document and found
the 5G relay antennas in the 3400 to 3800 MHz band will by themselves emit electromagnetic radiation
twice as strong as the sum of the relay antennas of 2G, 3G and 4G technologies combined and in the near
future, people living near relay antennas will be exposed to power density levels in W / m2, at least 3
times higher than those of today."
The energy consumption will rise sharply due to the ever increasing IOT energy demands at every stage
of the lifecycle of 5G equipment, from device manufacture to data centers to data transmissions, and
networks.
• 70.2 million "small cell" tower bases to be installed by 2025.
• 500 billion devices are expected to be connected to the Internet by 2030.
• 8.9 billion mobile phone subscriptions worldwide by 2024.
• 60% growth a year in production of wireless peripherals (Wi-Fi/ Bluetooth speakers, appliances,
wearables).
• 7 fold increase in mobile data traffic globally projected between 2017 and 2022.
In economics, the Jevons Paradox is when technological progress increases the efficiency with which a
resource is used, however demand and consumption increase as well. Thus- the end result is overall
increased use of the resource, despite efficiency gains.
5G will impact tree health contributing to climate change.
Trees play a vital role in mitigating climate change, sequestering millions of tons of carbon that would
otherwise pollute our climate. The installation of 5G equipment often requires heavy paining and
digging. This will clearly impact the canopy and root system of our trees.
Numerous news reports document that trees are being felled, heavily trimmed and roots are damaged
from the 5G rollout. 5G means millions of new short cell towers PLUS more macro towers- the tall cell
towers to tie together the new networks.
In Washington DC, the Sierra Club and numerous tree groups testified to City Councilmembers in
opposition to the 5G rollout due to the impact to trees. Who will manage the tree trimming? Who will
ensure their protection? There has been no environmental impact study to determine the impact to trees
from the trimming and digging.
In 2020, forty residents and demonstrators gathered at Saint-Cadou in the town of Sizun ( Finistere ) to
block the installation of a 5G antenna belonging to the Telecom company Free, reports Le Tele gramme as
loggers were proceeding to fell about twenty trees in area where the antennas were to be located.
Protesters climbed the trees. Images here.
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Iii 2021, news reports document how a federal judge denied a request from residents for a temporary
restraining order to halt the cutting down of trees to make room for a 95-foot cell tower in New York.
Court rulings worldwide have conformed that internet connections are more valued than trees. Precedent
setting cases have ailed that property owners can be forced to trim or remove trees that are blocking their
neighbours' broadband reception. In 2018 Justice Fitzgerald (New Zealand) ruled that "undue interference
with a wifi signal" caused by trees could constitute an "undue interference with the reasonable use and
enjoyment" of someone's land.
• Washington DC Sierra Club Testimony
Numerous environmental groups have written letters and appeals on the issue of the unfettered energy
consumption and the harm to trees, bees and wildlife. Greenpeace France released a position on 5G as
creating "digital pollution" that will increase carbon emissions, increase e-waste, strip the earth of natural
resources and contribute to human tragedies on a global scale. A major environmental group in Spain
Ecologists in Action issued a position on 5G calling for precaution and " in view of the deployment of
5G and the transformations that will accompany it, it is inevitable to ask ourselves: what kind of world do
we want to live in: a hyper-digitalized, robotized, monitored, controlled and manipulated society, or a
society where human relations, care, the common good and democratic debates on key issues for our
future take precedence? In other words, what will we put at the center: life or the machine?"
A Letter from Environmental Working Group To California State Officials states "there is already
adequate existing sound science for government to proceed with caution on the roll-out of the new
technology. In particular, the results of the $25 million National Toxicology Program study (2016) that
showed tumors in rats caused by a typical amount of heavy cell phone use are to be reckoned with."
The Green Party of California, the Sierra Clubs of California, Washington DC, and Montgomery County
Maryland and Montgomery County Maryland 350 have taken positions for protecting trees/environment
and addressing the energy consumption of 5G networks.
• Green Party of California
• California Sierra Club Letter
• Washington DC Sierra Club Testimony
• Montgomery County Maryland Sierra Club Letter
• Montgomery County Maryland 350 Letter on Small Cell Legislation
• Ecologists in Action on 5G
• Letter on small cell streamlining bill from Greenlining Institute
• Greenpeace France Position on 5G
• Letter from Environmental Working Group
REPORTS
High Council for the Climate Report "Controlling the carbon impact of 5G"(2020)
German Environment Agency 2020 Report "Fibre optic video transmission is nearly 50 times more
efficient than UMTS"
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The Shift Project, "LEAN ICT: TOWARDS DIGITAL SOBRIETY": OUR NEW REPORT ON THE
ENVIRONMENTAL IMPACT OF ICT" ( 2019) PDF Summary
Cell Tower and Small Cell Safety Issues
The cell tower industry has a poor track record for safety, compliance and safety and people working on
towers or buildings are at risk.
• Read Beware the Dangers from AM Radio and 5G Transmission Sites ("PDF) published in Tree
Care Industry Magazine January 2021 on the hazards faced by tree care workers in increasing
proximity to the ever-expanding universe of antennas, both regular radio and 5G/wireless.
• An October / ill Street Journal article reported that "One in 10 sites violates the rules,
according to six engineers who examined more than 5,000 sites during safety audits for carriers
and local municipalities, underscoring a safety lapse in the network."
• According to the US Labor Department, the rate of cell tower worker accidents has sharply risen
over the last few years as towers are being built at a rapid pace with minimal regulations and
worker safeguards in place . The Occupational Safety and Health Administration (OSHA) is
currently investigating the "alarming increase in preventable injuries and fatalities at
communication tower work sites."
• Tn 2.013 the Tnt.ema.tiona.1 Brotherhood of Electrical Workers wrote the FCC in 2013 that, "ensuring
compliance with existing FCC RF human exposure limits by the FCC licensee is not effective and
cannot/is not being enforced." Concerned about the health of their workers and consistent reports
of injuries from the lack of enforcement, they state, "When there is a hazard, the hazard creator
has a duty to warn others against the hazard." (Electrical workers are suffering internal injuries
from the radiation as they are doing unrelated work but are unaware of a poorly marked antennae
closeby. If you stand in front of these radiation beams you will be injured.)
• The EM Radiation Policy Institute wrote the FCC in 2013 with documentation of Failure to
Regulate Antennas and the Lack of FCC Monitoring of Compliance with FCC RF Safety Policies
stating that "the FCC does not monitor compliance and does not take any effective enforcement
action against violators." See examples of fires, collapse and accidents Here
Wireless networks in the workplace pose risks.
People working in retail stores, hospitals, security, transportation, construction, education and food
service are increasingly using phones and wireless networks as part of the job. While people in desk jobs
may be able to make changes that reduce exposure, many people have no choice in the matter. They are
also not being informed by their employer of ways to reduce exposure to the phones and devices they
must use at work.
Cell towers are increasingly on school properties, especially in low income areas.
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• In Montgomery County, the school cell towers are concentrated on schools with higher minority
and FARM (free and reduced meals) rates (See Map showing high minority schools with cell
towers clustered on the area). Parents in schools with higher white and more affluent populations
have organized and swiftly and successfully fought off the towers.
• For example, watch the video of the Wootten high school parent meeting where parents in a
wealthier community (majority white county) who stopped a cell tower within 24 hours after the
meeting with principal . Then compare that meeting to how the process unfold in schools with a
more diverse population. In contrast to the more affluent white communities, parents in lower
income communities need to work for months to halt school cell towers and sometimes the cell
tower goes up despite their strong opposition. See a meeting at Parkland Middle School where the
parent leadership and community repeatedly expressed opposition but the tower kept moving
forward. The administration often ignores opposition in low income communities and the peolpe
are treated like nuisances rather than stakeholders. Also watch a video of Greenbelt MD in Prince
Georges County ( a majority African American county) where parents in a cell tower meeting are
told that "some of you would never be happy. "
• Many low income areas lack the community resources to be aware that a cell tower has been
proposed. For example in the county of Prince George's County -some community meetings have
had one participant attend the cell tower community meeting and some PTA's were not notified
until after leases for cell towers were signed. As research shows these towers can decrease
property value by up to 20%, cell towers on school grounds change the landscape of the nearby
residential community, create stigma and further lower property values.
Most people are not aware that hundreds of researchers who have published research in the field of
bioelectromagnetics are calling for urgent policy action due to the mounting scientific evidence
confirming adverse effects.
• 255 scientists who have published in the field signed the EMF Scientists Appeal which states
"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."
• 419 scientists and doctors have signed the European Union 5G Appeal which states, "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."
• Over 3,500 medical doctors signed onto a 2020 Consensus statement that wireless RF has been
proven to damage biological systems at intensities below government limits ("See signatures here.
PDF of Consensus Statement).
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• Examples of Numerous Appeals by Medical Professionals: International Society of Doctors for
Environment. Cyprus Medical Association, the Vienna Austrian Medical Chamber and the
Cyprus National Committee on Environment and Children's Health. Belgium Doctors Appeal.
Canadian Doctors. Cyprus Medical Association. Physicians of Turin. Italv. the German Doctors
Appeal. International Appeal to Stop 5G on Earth and Space. Letter to President Trump. Letter to
President Biden and Chilean Doctors.
There have been appeals and position statements for decades. Read a full list here.
• Numerous expert reports conclude that safety is not assured.
° Tlic New Hampshire State Commission 5G Report has 15 recommendations to protect
the public
o The Pittsburgh Law Review: The FCC Keeps Letting Me Be: Why Radiofreauencv
Radiation Standards Have Failed to Keep Up With Technology explains how the FCC
and FDA have failed to develop adequate safety limits,
o The Harvard Press Book "Captured Agency: How the Federal Communications
Commission is Dominated bv the Industries it Presumably Regulates" details how
wireless companies are using the Big Tobacco playbook and how the FCC is a captured
agency.
The challenge is an international one.
"Given that treatment for a single case of brain cancer can cost between $100,000 for radiation
therapy alone and up to $ 1 million depending on drug costs, resources to address this illness are
already in short supply and not universally available in either developing or developed countries."
- Swedish review strengthens grounds for concluding that radiation from cellular and cordless
phones is a probable human carcinogen
Appendix
Letter to Montgomery County Council that was not responded to after the county proposed a law to
remove public hearings and public notice regarding 5g small cells.
Dear County Councilmembers,
Our organizations recently became aware of the potential climate implications of the Zoning Text
Amendment - ZTA 19-07 - Telecommunications Towers - Limited Use.
We are concerned that the increase in the number of 4G and 5G small cell towers in neighborhoods could
result in an increase in energy use and greenhouse gas emissions in Montgomery County, as well as a
significant reduction in the tree canopy throughout the county. These impacts would prevent the County
from achieving our goals identified in the Emergency Climate Mobilization Resolution No. 18-974 to
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reduce our greenhouse gas emissions by 80% by 2027 and by 100% by 2035. Additionally, we are
concerned that these same climate impacts will disproportionately worsen the negative effects on
communities of color, people of low income and other vulnerable households in the County. See the list of
studies and reports identifying these outcomes and concerns.
Section G-8 of the County's Climate Action Plan, which is entitled Evaluate and Update County
Planning, Policy, and Operations Activities to Reduce Greenhouse Gases states that "Climate-related
contracts should require equity-enhancing measures that proactively engage and improve the
socioeconomic conditions of communities disproportionately impacted by systemic inequities such as low
income, race, and/or imiigration status, and communities considered most vulnerable to the impacts of
climate change. This action also includes establishment of a climate impact statement to evaluate all
pending bills, budgets, plans and land use decisions."
As a result, before any vote on ZTA 19-07 takes place, we ask the County Council to provide both a
climate impact statement and a racial equity and social justice statement on the implications of this
proposed ZTA.
Additionally, we ask that you support County Executive Marc Elrich's proposal on June 29, 2021 to
convene a working group comprised of a diverse group of stakeholders, including industry, residents,
municipalities and homeowner/tenant associations, non-profit organizations and executive and council
staff for a limited time, perhaps 75 -90 days, to allow for the opportunity for a more complete discussion
of the issues after which their recommendations can be presented to the Council.
We appreciate your consideration of these requests. We look forward to hearing from you very soon.
Best regards,
350.org MoCo
Bethesda Green
Biodiversity for a Livable Climate
Cedar Lane Ecosystems Study Group
Cedar Lane Unitarian Universalist Church Environmental Justice Ministry
Give a Shift
Glen Echo Heights Mobilization
Montgomery Countryside Alliance
One Montgomery Green
Takoma Park Mobilization Environment Committee (TPMEC)
TAME Coalition (Transit Alternatives to Mid-County Highway Extended)
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The Climate Mobilization, Montgomery County Chapter
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I, Richard Moore, Co-Chair of the White House Environmental Justice Advisory Council, certify
that this is the final meeting summary for the public meeting held on May 11, 2022, and it
accurately reflects the discussions and decisions of the meeting.
Richard Moore
I, Peggy Shepard, Co-Chair of the White House Environmental Justice Advisory Council, certify
that this is the final meeting summary for the public meeting held on May 11, 2022, and it
accurately reflects the discussions and decisions of the meeting.
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