San Francisco Small Distributed Antenna System Antenna Appeal

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Jun 15, 2017, 7:20:09 AM6/15/17

San Francisco Small Distributed Antenna System Antenna Appeal

I am appealing the approval of ExteNet's application for a personal wireless service facility site permit on the corner of 22nd Street and South Van Ness, right in front of 3089 22nd Street.  I am opposed to the approval process on the grounds that it is out of compliance with standards pertaining to health, safety, and the environment. The approved deployment of this 4G small cell antenna will substantially add to an already oversaturated and polluted environment created by already existing 4G cell towers. Even the description small cells is a marketing/branding misrepresentation, because small cells are full-power cell phone towers.  Where the use of cell phones is discretionary, this antenna will always be on, broadcasting and emitting radio-frequency microwave radiation twenty feet from the windows of Mission residents,  affecting everyone else within range whether or not they use a cell phone.  That is why this a disaster — no matter what government guideline you or the FCC quote to justify this assault.

(The Federal Communications Commission (FCC) maintains exclusive jurisdiction and control over the EMF spectrum and the airwaves, and sets the safety standards for telecommunications facilities. EMF emissions resulting from the proposed facility are well within those standards).
The antenna lies within a block and a half of Cesar Chavez Elementary School,  giving children no choice but to be exposed to this radiation.  How can you assure me that this antenna will do no harm?

Evidence has proven that there are adverse health effects from exposures to electromagnetic fields at current exposure levels.  Yet, and perhaps by design, resources to asses the evidence pointing to this public health risk are grossly inadequate.  There is evidence that current funding sources for research and assessment of EMF have biased the analysis and interpretation of research findings, consequently these funding sources have rejected evidence of possible public health risks.  Arguments that weak or low intensity EMF do not affect biological systems are not true.  Based on the review of the science, biological effects occur from extremely low frequency fields.  

The Federal Communications Commission (FCC) cannot be relied on to serve the public interest because it is regulatory captured agency, it is dominated by the industries it presumably regulates.  The FCC has allowed powerful moneyed interests to shape policies.  The wireless industry has been allowed to grow unchecked and virtually unregulated, with questions on public health impacts routinely ignored.  The wireless industry controls the FCC through a stranglehold that extends from its campaign spending in Congress, to its control of  Congressional oversight committees and persistent lobbying. 

Although it has taken sole responsibility for the radiation safety of personal wireless service deployment, the FCC has remained unaccountable for the health effects of radiation exposure.  The FCC is not protecting public health.  It's deferential compliance to the wireless industry has allowed it regularly bypass and steamroll local authorities.  In the same way, a coddled wireless industry intimidated and silenced the City of San Francisco in 2010 when voters passed the Cell Phone Radiation Law, a right-to-know safety ordinance warning cellphone users about health risks.  The CTIA Wireless  Association Political Action Committee, with its huge standing army of lawyers, used outright legal bullying as its favored tactic.  It sued the City of San Francisco.  The City, fearing a prolonged legal fight with an industry that generates hundreds of billions of dollars in annual revenue, backed down. 

Seeing the telecom industry roll over municipal laws, the president of the American Academy of Environmental Medicine wrote:

My heart sank as I saw big business once again put the FCC knife to the throats of the City Council and tell them they would have to sit and watch as the wireless industry raped and ravaged the community and there was nothing they could do...every citizen is being blasted on the cellular level with this radiation.  It may take two or three decades to manifest the cancer or dementia, but it is adversely affecting us all”.
Newly released public records show that California public health officials worked for five years on guidelines and warnings about the potential dangers of cell phones, revising their work 27 times with updated research before abandoning their efforts to make their concerns public.  The 27 versions show that health officials deleted a section that warned state employees with work-issued cell phones about the potential increased risk for brain cancer from use of the device over time.  The final version of the guidelines included a warning to the public about exposure to electromagnetic fields emitted by cell phones, but was never included. 

The FCC will grant federal preemption to any wireless provider that requests it, including ExteNet and its 3089 22nd Street client T-Mobile.  One would think the FCC would at least enforce its own emission standards.  But vast evidence of non-compliance exists.  Ten to twenty percent of  light, electric pole and rooftop antennas  exceed allowed radiation standards.  That means that they are emitting radiation in violation of FCC standards.  “There are dangers to the thousands of workers who come in close contact with cell phone antennas”, writes the rating agency A.M Best, which advises insurers on risk.
 “Thermal effects of the cellular antennas which act at close range are essentially open microwave ovens.  The effects include eye damage, sterility and cognitive impairment.  The continued exponential growth of cell towers will significantly increase exposure of these workers and others coming into close contact with high energy cell phone antenna radiation”.
Dr. Bill Curry found one in ten cell sites out of compliance.  He warned in his report that extreme microwave antenna hazards exist for omni-directional antennas located close to inhabited buildings, as well as for directional antennas which focus radiation into elevated homes.  The proposed small cell antenna for 3089 22nd would be very close to the window of the building's inhabitants.
“People who live near cell towers are in jeopardy”, the president of American Academy of Environmental Medicine warns. 
A troubling body of evidence suggests exposure to even low emission levels at typical cellular frequencies can have a wide range of negative effects.  In a 2010 review of research on the biological effects of exposure to radiation from cell towers, Blake Levitt and Henry Lai found that caution is needed in infrastructure siting.  The results of their study showed that the closer a person lived to a tower the greater the increase in physical symptoms and complaints.  At ten meters symptoms included nausea, loss of appetite, visual disruptions and difficulties in moving.  At 100 meters significant symptoms such as increase in memory loss, dizziness, depressive tendencies, concentration difficulties, lower libido, sleep disturbance and tremors were observed. Radiation levels are calculated from computer models produced by the wireless industry, not from actual site measurements.  The residents of 3089 22nd street and those in the vicinity are not privy to information on what DNA-busting frequencies and power densities are  invading their buildings and bodies from exposure to this antenna. 

Thus far the FCC has refused to acknowledge there may be wireless health risks, especially to children and pregnant women.  I don't believe that just because something can be done it should be allowed.  Murder and rape are doable but are prohibited and regulated.  Government regulators have a responsibility to examine the consequences of this technology and act to contain them.  But the FCC continues to convey the message: “you can study health effects all you want.  It doesn't matter what you find .  The buildout of wireless cannot be blocked or slowed by health issues”.

Mobilitie, a telecommunications company installing small cell antennas, like ExteNet, petitioned the FCC claiming, “robust deployment of wireless facilities and networks demonstrably serves the public interest. The FCC has found that all consumers want wireless and that wireless is now an essential public service”.  Contrary to Mobilitie and FCC's assumptions, not all Americans want their homes and neighborhoods polluted so that some people can have cell phone use.  On the contrary, the deployment of small cells serves the unbounded profit motive of telecom corporations such as ExteNet and T-Mobile.  A significant percentage of the population adamantly oppose being involuntarily exposed to more radiation for the benefit of telecommunications profits. 

In 2011 wireless radiation was classified as a possible 2B carcinogen by the International Agency for Research on Cancer at the World Health Organization.  If international scientists, doctors and others are warning that wireless radiation exposure is a threat to public and environmental health, why is the Department of Public Works facilitating the installation of these antennas?

International scientists and doctors advise reducing wireless radiation exposure to protect public and environmental health.  In 2016 the National Toxicology Program published a 25 million dollar study, one of the largest and most comprehensive studies on cell phone radiation and cancer.  In the study the rats exposed to cell phone radiation developed two types of cancers, glioma, a brain tumor, and schwannoma, a tumor in the heart. 

Over two hundred scientists  have signed the International EMF Scientist Appeal:
 “We are scientists engaged it the study of biological and health effects of non-ionizing electromagnetic fields.  Based upon peer-reviewed, published research we have serious concerns regarding the ubiquitous and increasing exposure to EMF generated by electric and wireless devices.  These include but are not limited to radio-frequency radiation emitting devices such as cellular and cordless phones and their base stations, wifi, broadcast antennas, et al”.
The BioInitiative Report, updated in 2012 and prepared by 29 authors from ten countries,
reviewed 2,000 studies and concluded:
EMF and RFR are preventable toxic exposures.  We have the knowledge and means to save global populations from multi-generational adverse health consequences by reducing both ELF and RFR exposures.  Proactive and immediate measures to reduce unnecessary EMF exposures will lower disease burden and rates of premature death”.
Based on current available literature, I feel justified to conclude that RF/MF electromagnetic fields radiation exposure can change neurotransmitter functions, bloodbrain barrier, morphology, electrophysiology, cellular metabolism, and gene and protein expression in certain types of cells, even at low intensities.

The deployment of a denser small cell antenna system is a major change to the environment, not a minor one and therefore should be subject to CEQA laws. There is no substantial evidence to support a determination that the deployment  fits CEQA exemptions.  Rather there is substantial evidence to support the argument that the deployment will create substantial environmental impacts. Telecom interests do not outweigh local, municipal, county and state jurisdiction. 

There is evidence that small cell emissions will negatively impact a wide range of living organisms. A study by the Centre for Environment and Vocational Studies of Punjab University noted that embryos of 50 eggs of house sparrows were damaged after being exposed to cell antennas radiation for 5-30 minutes.       

Studies show that insects are harmed by radiation. Food collection and response in an ant colony exposed to EMR found exposure caused colony deterioration and affected the insects' behavior and physiology.  Earthworms exposed to to electromagnetic fields caused DNA damage and other geotoxic effects.

The U.S. Department of the Interior states wireless radiation threatens birds and they criticize the FCC's radiation safety guidelines: 

“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.” Two hundred forty one bird species are at mortality risk from both tower collisions and from
exposure to the radiation towers emit. This includes birds that are endangered or  threatened, Birds of Conservation Concern, migratory birds, and eagles. Studies of radiation  impacts on wild birds documented nest abandonment, plumage deterioration and death.  Birds studied included House Sparrows, White Storks, Collared Doves, and other species.  Studies in laboratories of chick embryos documented heart attacks and death”.
Scientists in Germany studied tree damage in relation to electromagnetic radiation
from 2006-2015. They monitored, observed and photographed unusual or unexplainable
tree damage, and measured the radiation the trees were exposed to. “The aim of this study was to verify whether there is a connection between unusual (generally unilateral) tree damage and radiofrequency exposure.” They found significant differences between the damaged side of a tree facing a phone mast and the opposite side, as well as differences between the exposed side of damaged trees and all other groups of trees in both sides. They found no tree damage in low radiation areas. The scientists concluded,
“Statistical analysis demonstrated that electromagnetic radiation from mobile phone masts is harmful for trees.” 
Another study concluded that the top of trees dry up when they directly face cell antennas.
While independent scientific studies show the harmfulness of wireless radiation on nature, the FCC chooses strikingly patronizing language to slight and trivialize the many scientists and health and safety experts who‘ve found cause for concern. In a two page Web post titled ―Wireless Devices and Health Concerns, the FCC four times refers to either ―some health and safety interest
groups,―some parties or ―some consumers, and in each case rebutts their presumably groundless
concerns about wireless risk.  Instead of relying on the public's ignorance, the FCC should determine whether the current levels of EMR exposure is safe for the public. 

Finally, the precautionary principle needs to be adopted as your framework of guidelines for public exposure. 
Date:  June 1, 2017
Appeal for Permit Number: 16WR-0312
Address:  3089 22nd Street
I am appealing the issuance of Wireless Permit 16WR-0312 by the Department of Public Works Bureau of Street Use and Mapping issued to ExteNet Systems, Inc.  This permit should be denied because of the conditions set for th in this document.
Jackie Barshak
2067 10th Avenue
San Francisco, CA

 From EMR-Updates

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