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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
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© 2017 Electromagnetic Safe
Planet, All rights reserved.
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