HomeMy WebLinkAboutCD Small Cell 5G Wireless Communication Technology____________________________________________________________________________________
FOR CITY CLERK ONLY
Council Meeting: 12/3/2018
Disposition: Accepted report and provided direction to staff to prepare a draft ordinance and
resolution for consideration at the December 17, 2018 City Council Meeting
Agenda Item No: 7.a
Meeting Date: December 17, 2018
SAN RAFAEL CITY COUNCIL AGENDA REPORT
Department: Community Development Department
Prepared by: Paul A. Jensen (PJ/AG/CP/LG),
Community Development Director
City Manager Approval: _______ _______
TOPIC: SMALL CELL “5G” WIRELESS COMMUNICATION TECHNOLOGY
SUBJECT: REPORT ON SMALL CELL “5G” WIRELESS COMMUNICATION TECHNOLOGY TO
INCLUDE: A) PRESENTATION ON RECENT FEDERAL COMMUNICATION
COMMISSION (FCC) RULING REGARDING SMALL CELL FACILITIES; AND B)
REVIEW OF DRAFT ORDINANCE, REGULATIONS AND STANDARDS FOR
PERMITTING SMALL CELL FACILITIES. CITY CASE NOS. P18-016 & ZO18-004
RECOMMENDATION:
Accept report and direct staff to prepare an urgency ordinance and resolution for consideration at the
December 17, 2018 meeting.
EXECUTIVE SUMMARY:
On September 26, 2018, the Federal Communications Commission (FCC) adopted a Declaratory Ruling
and Third Report and Order geared toward speeding up deployment of small cell wireless facilities in the
public right-of-way (hereafter, the “FCC ruling”). Small cell wireless facilities are designed to
accommodate “5G” technology. The FCC ruling, which will go into effect in mid-January 2019, sets forth
limitations on state and local government regulation of small cell wireless facilities that are placed on
existing or new utility poles and street light standards located in the public right-of-way. The FCC ruling:
a) limits the level of local permitting and discretion; b) establishes “shot clock” rules (e.g., time limits and
deadlines) for processing and action on local permits; and c) limits the fees that can be charged for the
facilities. The FCC ruling makes no changes to the Telecommunication Act of 1996, which expressly
preempts state and local government from imposing regulations that may prohibit or have the effect of
prohibiting the ability of any entity to provide any interstate or intrastate telecommunications service . In
addition, this FCC ruling expressly prohibits regulation of the placement and modification of wireless
communication facilities based on radio frequency (RFR) emissions. The FCC ruling is slated to go into
effect on January 15, 2019. W hile the recent FCC ruling is being challenged, it is uncertain if there will
be a “stay” in the effective date of the order. Therefore, it is prudent for the City to address this matter
as soon as possible.
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The FCC ruling is significant in that there are several nuances in small cell wireless facilities technology
and application, which set them apart from other wireless communications facilities. For this reason, staff
has arranged to have Dr. Jonathan Kramer, attorney and specialist in wireless communication facility law
and engineering provide the City Council with a presentation on the FCC ruling. Further, although
comprehensive and effective, the City’s current wireless communication facility ordinance could be
updated to more fully address small cell wireless facilities located in the public right-of-way. With the
assistance of Dr. Kramer and the City Attorney, staff has prepared a draft ordinance and specialized,
small cell wireless facility regulations that are specific to responding to the FCC ruling (attached).
BACKGROUND:
Telecommunications Act of 1996
The Telecommunications Act of 1996 (the “1996 Act”) was the first significant overhaul
of telecommunications law in more than sixty years, amending the Communications Act of 1934. Signed
by President Clinton, the 1996 Act represented a major change in American telecommunication law,
since it was the first time that the internet was included in broadcasting and spectrum allotment. The
primary goal of the 1996 Act was deregulation of the converging broadcasting and telecommunications
markets and opening-up the markets to competition by removing regulatory barriers to entry. However,
in addition to deregulation, one key provision allowed the FCC to preempt state or local legal
requirements that act as a barrier to entry in the provision of interstate or intrastate telecommunications
service. The following are three of the sections of the 1996 Act that address state and local jurisdiction
preemptions:
•Section 253(a) prohibits state and local government regulations that “prohibit or have the effect of
prohibiting the ability of any entity to provide any interstate or intrastate telecommunications service.”
•Section 704(a) expressly preempts state and local government regulation of the placement,
construction, and modification of personal wireless service facilities on the basis of the environmental
effects of radio frequency (RFR) emissions to the extent that such facilities comply with the FCC's
regulations concerning such emissions. 47 U.S.C. §332(c)(7)(B)(iv).
•Section 704(a) requires a state or local government to act upon a request for authorization to place,
construct, or modify personal wireless service facilities within a reasonable time frame.
Since enactment of the 1996 Act, the FCC has issued guidelines for use in evaluating environmental
effects of radio frequency (RFR) emissions from cellular towers. The FCC guidelines incorporated
maximum permitted exposure (MPE) limits established by the Congressionally-chartered National
Council on Radiation Protection (NCRP). In addition, FCC decided to exempt certain types of towers from
environmental review based on a presumption that these towers comply with the MPE limits. While the
FCC was finalizing its 1996 MPE guidelines, the 1996 Act was passed. The FCC then issued the following
rule consistent with the 1996 Act:
“No State or local government or instrumentality thereof may regulate the placement,
construction, and modification of personal wireless service facilities on the basis of the
environmental effects of radio frequency emissions to the extent that such facilities comply with
the regulations contained in this chapter concerning the environmental effects of such emissions.”
Although RFR emissions cannot be regulated at a state or local level, the federal regulations allow the
state and local government to assess an individual wireless facility application to ensure that it is within
the FCC standards for public exposure (MPE limits). The United States Court of Appeals for the Second
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Circuit upheld the FCC guidelines setting health and safety standards on RFR emissions and prohibiting
local governments from considering health effects of cellular tower radiation in zoning decisions.
Since 1996, there have been no amendments in the federal legislation or the FCC guidelines that change
the status of state or local preemptions. However, the FCC has adopted specific “shot clock” regulations
to implement the 1996 Act, specifying the time limits a state and local agency must act on a wireless
communications facility application, namely a 90-day clock for reviewing co-location applications and a
150-day clock for reviewing siting applications other than co-locations.
Current Wireless Communication Facilities Ordinance
In response to the 1996 Act, in 2001, the City Council gave direction to staff to prepare a wireless
communications ordinance. A team of consultants (including legal counsel and a health consultant) was
hired to assist in this effort. Following expansive research and several community workshops, a draft
wireless communications ordinance was prepared based on the following goals and objectives:
➢To establish development standards that regulate the design and placement of wireless
communication facilities so that the visual character of the City is preserved, and to ensure the
protection of the public health and safety consistent with federal law and the FCC regulations;
➢To acknowledge the community benefit associated with the provision of wireless communication
services; and
➢To encourage the joint use of new and existing tower sites as a primary option rather than the
construction of new single-use towers for this purpose.
On April 5, 2004, the City Council adopted Ordinance No. 1823 establishing wireless communications
provisions in San Rafael Municipal Code (SRMC) Section 14.16.360, which can be accessed here (also
included in Attachment 1). This ordinance was updated in 2014 to address mandated “shot clock”
provisions setting specific deadlines and time limits for reviewing and taking action on applications for
wireless communication facilities.
Key Elements and Provisions of the Current Ordinance
The following is a brief summary of the key elements and provisions of the City’s current wireless
communication ordinance:
1.Applicability. The current ordinance applies to the placement of towers, antennas, and other
wireless communication facilities and/or reception facilities on public and private property.
2.Review Process. Applications for all wireless communication facilities are subject to either a
“ministerial review” or “discretionary review” process, which is required prior to securing
building/electrical permits and installation. The ministerial review, which is a City staff-level
clearance, is applicable to facilities that are “co-located” (grouped with other similar facilities on a
single structure) or building-mounted (e.g., placed on a building roof or concealed in a building
façade). The discretionary review requires the approval of a Zoning Administrator-level review of
a Use Permit and Environmental and Design Review Permit. The discretionary review is required
to new ground-mounted facilities (towers and monopoles) or significant additions to existing
facilities. Public notice of the permit applications and action is required for the discretionary
review, which is a notice to property owners and residents within 300 feet of the facility, or 1,000
feet if the facility includes a tower or monopole. Actions by the Zoning Administrator for the
discretionary review can be appealed to the Planning Commission.
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3.Fees. For the ministerial review process, a flat Telecommunication Fee of $398.00 and an
Administrative Design Review Permit fee of $1,167.00 are charged. For discretionary review (new
antenna sites), cost-recovery based fees are charged that include: a) $2,258.00 for an
Environmental and Design Review Permit, which increases to $4,693.00 if the application requires
Design Review Board review; and b) $2,476.00 for a Use Permit.
All construction-related work in the public right-of-way is subject to an Encroachment Permit,
which is processed and issued by the Public Works Department. The fee for this permit is
$246.00.
4.General Location Requirements. The code provisions note that the most desirable location of
new wireless communication facilities is co-location on existing buildings and facilities. The
following is the hierarchy of the general location standards:
a.“Preferred Locations,” from most preferred to least are industrial, public/quasi-public,
commercial and office zoning districts.
b.“Less Preferred Locations,” from most preferred to least are parks, open space and residential
zoning districts.
c.New monopoles or towers are prohibited in residential districts and designated open space
and conservation areas unless supported by technical information demonstrating service
need and subject to special findings.
5.Design Requirements.
a.Co-location is required as first priority. All new wireless communication facilities shall co -
locate with existing and/or planned new wireless communication facilities, whenever feasible.
Placement on light standards and utility structures (e.g., utility poles) is considered a con-
location.
b.Stealth design is required. Stealth design requires screening or other measures to reduce the
visual of the facilities so that they blend into the existing environment. One example would
be a façade-mounted antenna located within an architectural feature of a building.
c.Ground-mounted facilities, which include antenna, equipment, cabinets must be sited to be
screened from view by existing development, topography or vegetation.
d.Roof- and building-mounted facilities must be sited to appear as an integral part of the
structure and screened by a roof parapet or concealed behind an architectural feature such a
dormer, steeple or chimney.
6.Other Development Standards.
a.The height of a building-mounted antenna shall not exceed the height limits for the zoning
district in which they are located.
b.Towers and support structures are subject to the setback standards for the zoning district in
which they are located. Such structures are required to be located a minimum of 200 feet or
at least three times the height of the structure, whichever is greater from existing residential
units or vacant, residentially-zoned property.
7.Application Requirements. All Use Permit and Environmental and Design Review Permit
applications for discretionary review are subject to a long list of requirements. In addition to
detailed plans (site plan, design, elevations and specifications), the application must be
accompanied by the following:
a.An RFR study to demonstrate that the proposed facility (coupled with other wireless
communication facilities on “co-location” sites) is within the FCC standards for RFR emissions.
The RFR study requires a “peer” review by a City-hired, qualified RF engineer. When peer
review is triggered, the applicant is charged for this review.
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b.Photo simulations of the proposed facilities when proposed on sites that are highly visible from
public view.
c.An Alternative Site Analysis is required when the proposed facility is: 1) located within any
zoning district other than a commercial or industrial district; 2) located within 50 feet of a “Less
Preferred Location;” 3) lacks “stealth” design; or 4) not co-located with an existing approved
facility. The purpose of this analysis is for the applicant to prove and provide supporting
reasons why a “Preferred Location” is infeasible and rejected, why a co -location of building-
mounted location was not pursued, and why the proposed site is superior from a technical
standpoint to the others considered. The City always commissions a “peer” review on all
applications that include an Alternative Site Analysis.
d.A Noise Analysis. Facilities are typically accompanied by supported equipment such as
emergency generators, which are noise-producing.
8.Post-Approval Requirements.
a.Validation of Proper Operation. Within 45 days of commencement of operation, the applicant
must submit a report indicating the actual RFR levels of the operating facility.
b.Five-year Review. The City is required to conduct a five-year review of the approved wireless
communication facilities (discussed below). The code requires that the applicant/operator
participate in the five-year review and is responsible for the cost of the City performing an
RFR testing.
It is important to note that since the current ordinance applies to placing wireless communication facilities
on public and private property, small cell wireless facilities placed on utility poles and street light standards
in the public right-of-way are regulated under the current ordinance. Should an application for placement
of small cell facilities be made today, such application would be processed and assessed per the
provisions of the current ordinance. Therefore, the application would be required to be: a) reviewed for
consistency with the “General Location Standards,” which prescribe that residential and open space
areas be avoided (least preferred location); b) subject to submittal of an RFR report; and c) subject to the
specific design standards. Placement of small cell facilities on utility poles and street light standards are:
defined as “ground-mounted” facilities; and interpreted by the current ordinance as “co-location.”
Therefore, the applications would qualify for the “ministerial review” process described above.
The current ordinance is not adequate to address the recent FCC ruling (discussed below) for small cell
wireless facilities in the public right-of-way, which will go into effect in mid-January 2019. With this ruling,
there are a number of nuances in small cell facilities technology and application, which set them apart
from other wireless communications facilities. As discussed below, staff is recommending that an
independent set of regulations and provisions be adopted for small cell wireless facility review and
permitting.
Inventory of Existing Wireless Communication Facilities & Required Five-Year Review
As of October 2018, there are a total of 41 sites throughout the City that house active wireless
communication facilities for nine (9) carriers.1 Most of the sites are in light industrial and commercial
districts; however, four sites are in residential districts (see Attachment 3 for map). All the 41 sites
accommodate “co-location,” with each site housing two to four wireless communication facilities for
individual carriers. The 41 sites present a variety of building-mounted, roof-mounted, and utility pole-
mounted facilities; and one “mono-pine” structure.
Pursuant to SRMC Section 14.16.360, the City is required to conduct a 5-year review of all wireless
facilities in the City of San Rafael. The purpose of the 5-year review is to inspect each wireless site for
1 Nine telecommunication carriers: AT&T, T-Mobile, Cingular, Nextel, Verizon, Metro PCS, Sprint, Clearwire and ExtaNet
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 6
compliance with the approved Environmental and Design Review Permit and Use Permit conditions and
to get an updated RFR report. The last year review was conducted in 2008. The result showed that all
facilities complied with the FCC RF levels for maximum public exposure. However, of the sites surveyed,
12 were found to be out of compliance with specific approval conditions, such as required landscaping,
painting of conduits or missing stealth screens. Staff contacted each carrier and was able to bring the
sites into compliance.
Staff is gearing-up to begin the next 5-year review process in early 2019. We are in the process of hiring
a consultant (Marv Wessell, President, Global RF Solutions) to implement to 5-year review. Mr. Wessel
is currently reviewing our draft scope of work. Staff is updating our Master Wireless facility list and also
gathering the approved entitlements and plans to provide to Mr. Wessel. As implemented with the 2008
review, the cost for the five-year review would be borne by the telecommunication carriers.
Introduction of Small Cell Wireless Communication Technology
The FCC ruling establishes parameters for both fees and aesthetic standards as well as more stringent
“shot clock” regulations (see below for a more detailed discussion). The FCC ruling defines small cell
wireless facilities as follows:
1.Facilities that:
•Are mounted on structures 50 feet or less in height including the antennas;
•Are mounted on structures no more than 10% taller than adjacent structures; or
•Do not extend existing structures on which they are located to a height of more than 50 feet
or by more than 10 percent, whichever is greater;
2.Antennas that are no more than three (3) cubic feet in volume (not including associated antenna
equipment); and
3.All other wireless equipment associated with the structures is no more than twenty-eight (28)
cubic feet.
Examples of small cell facility application on utility poles and light standards
To date, the City has received no applications for small cell wireless facilities to accommodate 5G
technology.
Federal Communications Commission (FCC) Ruling
The FCC ruling clarifies and more specifically restricts the authority of state and local governments to
regulate small wireless facilities in the public right-of-way. The FCC states that it has issued its ruling to
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“reduce regulatory barriers to the deployment of wireless infrastructure and to ensure that our nation
remains the leader in advanced wireless services and wireless technology.” (FCC ruling, ¶29.)
The FCC ruling ties its regulations to the 1996 Act, which prohibits in Section 253(a), local regulations
that “may prohibit or have the effect of prohibiting the ability of any entity to provide any interstate or
intrastate telecommunications service.” (FCC ruling, ¶15.)
The FCC ruling clarifies that an “effective prohibition” under the statute occurs where a state or local legal
requirement “materially inhibits a provider’s ability to engage in any of a variety of activities related to its
provision of a covered service. This test is met not only when filling a coverage gap but also when
densifying a wireless network, introducing new services or otherwise improving service capabilities.”
(FCC ruling, ¶37)
Notably, the FCC ruling makes no change to existing law preempting state and local government
regulation of the placement, construction, and modification of personal wireless service facilities on the
basis of the environmental effects of RFR emissions, to the extent that such facilities comply with the
FCC's regulations concerning such emissions.
There have been numerous lawsuits filed challenging the FCC ruling. However, at present the rules set
forth in the FCC order are applicable and will go into effect in mid-January 2019 unless the litigation
results in a “stay,” meaning the rules are frozen through the litigation process.
The FCC ruling focuses on three substantive aspects of local regulation:
1. Limitations on Fees & Charges:
The FCC finds that state and local fees/charges associated with the deployment of wireless facilities
can unlawfully prohibit the provision of service. The FCC ruling thus provides that “fees are only
permitted to the extent that they are nondiscriminatory and represent a reasonable approximation of
the locality’s reasonable costs.” (FCC ruling, ¶32)
The FCC ruling limits what state and local governments can charge in fees to only those deemed “fair
and reasonable.” The FCC conducted a survey of 20 local jurisdictions finding that the following fee
levels comply with this “fair and reasonable” standard:
▪ $500.00 for non-recurring fees,2 including a single, up-front application for up to five small cell
wireless facility sites, with an additional $100.00 for each additional small cell wireless facility
site beyond the initial five sites.
▪ $1,000.00 for non-recurring fees for a new pole to support one or more small cell wireless
facility.
▪ $270.00 per year for all recurring fees3 including any right-of-way access fee (e.g.,
encroachment permit) or fee for attachment to a municipality-owned structure in the public
right-of-way.
The FCC ruling states that, in limited circumstances, a state or local agency can charge fees higher
than the above fees provided that: a) they are a reasonable approximation of the costs; b) the costs
themselves are reasonable; and c) they are not discriminatory.
2 Non-recurring fees are akin to the fees charged for a Use Permit and Environmental and Design Review Permit
3 A recurring fee would be akin to an annual fee charged for the encroachment into the public right-of-way
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2.Non-fee Regulations:
The FCC ruling also addresses other types of state and local land-use or zoning requirements that
may constitute an effective prohibition on the deployment of small wireless facilities, specifically
focusing on aesthetics (e.g. “stealth” designs or other means of camouflage, size of equipment, colors
of paint, etc.), undergrounding, and minimum spacing requirements.
These non-fee regulations must be:
▪reasonable, in that they are technically feasible and reasonably directed to avoiding or
remedying the intangible public harm of unsightly or out-of-character deployments;
▪no more burdensome than those applied to similar infrastructure deployments. “For example,
a minimum spacing requirement that has the effect of materially inhibiting wireless service
would be considered an effective prohibition of service.” (FCC ruling, ¶87); and
▪objective (must incorporate clearly-defined and ascertainable standards, applied in a
principled manner) and published in advance.
3.Time for Action on Applications (“Shot-clock”):
The FCC ruling establishes two new time limits, so-called “shot-clocks,” within which local entities
must act on small wireless facility applications, including multiple simultaneous or “batched”
applications. These time limits include all aspects of the application process, such as any required
pre-application meetings, permit reviews, and appeals. The new shot-clocks for small wireless facility
applications are:
•60 days: for collocations on any existing structure; and
•90 days: for attachment of small wireless facilities to a new structure
How are Other Marin & North Bay Cities/Towns Addressing the FCC Ruling?
A number of Marin and Sonoma County cities/towns have responded to initial planning for small cell
facilities and the FCC ruling by either adopting new regulations addressing such facilities or “doubling-
up” on regulations that were already adopted. The following table presents a list of the local jurisdictions
that have recently addressed this issue:
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Local Jurisdiction Adoption Date Key Regulations & Facts
Town of San Anselmo June 2018 Amended 1999 adopted wireless communication ordinance, adopting a
separate resolution addressing small cell facilities.
•Adopted policy establishes wireless facilities located in the public right -of-
way as the second-most preferred locations.
•Requires specific design criteria for wireless facilities in the public right -of-
way.
•Requires applicant (carrier) to hold a community meeting for new
installations.
City of Petaluma August 2018 Amended 1999 adopted wireless communication ordinance to address small
cell facilities. Specific criteria established for placement on light standards/poles
in the public right-of-way:
•Small cell facilities must be placed within the circumference and height of
the existing pole.
•Requires complete screening of the facilities and equipment must be place
underground.
•Prohibits installation in residential districts.
•Requires a separation between facilities of 1,500 feet from the nearest pole -
mounted facility and a setback of 500 feet from a residential district.
Town of Ross August 2018 Town previously did not have an adopted wireless communication ordinance or
regulations. New regulations adopted.
•Adopted regulations prohibit facilities in residential and downtown zoning
district.
•Facilities proposed in the public right-of-way subject to separate design
criteria.
•Limits height and width of facilities to a minimum necessary for property
function.
•Maximum height of 24 feet above the height of the existing utility pole and
7 feet above a street light standard.
•Requires equipment to be placed underground.
City of Mill Valley September 2018 City introduced an urgency ordinance to expand the list of procedures and
regulations previously adopted.
•Regulations now apply to both public and private property.
•Adopted design standards similar to those adopted by the Town of Ross.
•Prohibits wireless facilities in a residential zoning district.
•Requires a separation between facilities of 1,500 feet from the nearest pole -
mounted facility.
Town of Fairfax September 2018 Amended 1999 adopted wireless communication ordinance, adopting a
separate resolution addressing small cell facilities. Adopted regulations similar
to those adopted by the Town of San Anselmo.
Other jurisdictions are currently addressing this topic and responding to the FCC ruling. For example,
last month the Marin County Board of Supervisors announced it will join a coalition of public entities suing
the FCC in an effort to appeal its rules governing deployment of small cell wireless facilities. The lawsuit
is challenging the loss of local control specific to: a) regulating small cell facilities; b) the “shot clock”
provisions that mandate tight time lines for local review and action; and c) limitations on charging local
permit fees for facility review and action. Some jurisdictions, like the City of Sebastopol have adopted
an urgency ordinance establishing a 45-day moratorium on wireless facilities in the public right-of-way,
to allow the city to prepare regulations in response to the FCC ruling.
The City of Sacramento has taken an approach that involved direct collaboration with a number of the
wireless communication providers. Earlier this year, Sacramento approved the City of Sacramento –
Small Cell Design & Deployment Standards (see Attachment 5). The standards are very specific and
prescribed limiting small cell facility installations on mast arm street lights (Type 15- Caltrans), and include
some separation and setback requirements. The City of Sacramento Wireless Master Plan Update,
prepared by XG Communities, LLC (October 26, 2018) provides a roadmap on addressing small cell
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facilities moving forward. The goal of the City of Sacramento is to be “prepared for the future”, in order to
take advantage of a host of new and innovative technologies (driverless cars, connected health care
[“telemedicine”], and public safety) using “smart infrastructure”. In Sacramento, the entire small cell
wireless facility permitting process is done through their Public W orks Department, and they work closely
with the IT Department. The permit process is done through a “revocable license permit.” They also rely
on the “Small Cell Design and Deployment Standards.” Staff has been in communication with the City of
Sacramento’s Planning Division and IT Division to learn how they are handling the “5G” wireless
application. Our goal is to learn from their efforts as we start the process to update our Zoning Ordinance
with respect to design guidelines and permit implementation.
ANALYSIS:
City’s Limitations on RFR Standards Under FCC Ruling
As discussed above, the recent FCC ruling made no changes in the 1996 Act related to a local
jurisdiction’s ability to regulate or enforce RFR limits on small cell wireless or any other wireless
communication facility. Therefore, the City has no authority to approve or deny a small cell wireless facility
application on the basis of health risks unless such facility exceeds the FCC standards for public exposure
(MPE limits discussed above).
Regulations and Standards for Small Cell Wireless Facilities
To assure the City is prepared to evaluate new applications for small wireless facilities, staff has prepared
a draft ordinance and special procedures and regulations (including objective aesthetic standards) for
administering such facilities. The draft ordinance and special procedures and regulations (resolution) are
attached (Attachments 1 and 2).
Approaches Assessed & Considered by Staff
The following is a summary of the approaches studied and considered by staff in consultation with
Jonathan Kramer and the City Attorney’s Office:
1.Mirror the discretionary permit requirements of the current wireless communication ordinance. As
discussed above, the current wireless communication ordinance (SRMC Section 14.16.360),
prescribes that applications subject to discretionary review require the approval of both a Use
Permit and Environmental and Design Review Permit. Staff initially considered recommending
that these permits be required for small cell wireless facility installation to ensure maximum
discretion by the City. However, the FCC ruling explicitly states that small cell wireless
applications are allowed by-right in all zoning districts. Therefore, a Use Permit cannot be
required. The Environmental and Design Review Permit can be required for assessment of
aesthetics. For new pole installations and in “least preferred” locations, an Administrative Design
Review Permit is recommended to accompany the Telecommunications Permit application.
Pursuant to SRMC Section 14.25.060C, Administrative Design Review Permits do not require a
public notice or hearing.
2.Mirror the “Alternative Site Analysis” requirements of the current wireless communications
ordinance. The current wireless communication ordinance requires that an Alternative Site
Analysis be prepared for applications in “Less Preferred” locations such as residential districts.
This requirement places the burden of “need” on the applicant as the analysis must demonstrate
that that there are no other locations available to provide the same level of service coverage.
Essentially, this added analysis will discourage the applicant to pursue t he “Less Preferred”
location. This same requirement for small cell wireless facilities was considered by staff for
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applications in residential districts. However, the FCC ruling precludes the local municipality from
requiring the submittal of a coverage-based analysis for small cell wireless facilities.
3.Prohibit small cell wireless facilities in residential districts. It has been advised by Jonathan
Kramer and the City Attorney’s office that prohibiting small cell wireless facilities in residential
districts may be in violation of the FCC ruling. Therefore, an outright prohibition in the residential
districts is not recommended.
4.Consider a setback requirement between a small cell wireless facility and the closest
residence/residential structure or residential district. A 500-foot setback has been suggested by
community residents (EMF Safety Network), which has been adopted by the City of Petaluma.
Jonathan Kramer has advised that requiring a setback is problematic. As a utility, the Public Utility
Commission authorizes the wireless communication carriers to have “compulsory access to the
right-of-way.”
5.In residential districts, limit facility installation to major arterials and minor arterials (collector
streets). Staff finds that this limitation is worthy of consideration. Major and minor arterials that
are in residential districts tend to be wider streets where there is a greater opportunity and success
for aesthetic approaches such as strategic spacing and screening, and greater setbacks to
residences. General Plan 2020 Exhibit 22 identifies major and minor arterials (see Attachment 4).
6.Impose spacing/separation requirements. The FCC ruling does not preclude the City from
imposing spacing/separation requirements based on “aesthetic” considerations. However, a
spacing requirement cannot be based on RFR exposure, nor can it have the effect of materially
inhibiting wireless service. As discussed below, the draft procedures and regulations include a
recommendation for spacing/separation requirements. A minimum 300-foot separation between
small cell wireless facilities is recommended, as it provides a reasonable distance for visual
transition and minimizes visual proliferation. A 1,500-3,000-foot separation has been suggested
by community residents (EMF Safety Network), but this separation bears no relation to aesthetics.
7.Incentivize for complete concealment or stealth design. Staff believes that an incentive approach
to encourage maximum concealment of facilities is worthy of consideration. This approach would
encourage maximum concealment to permit closer spacing allowances. If not completely
concealed or stealth in design, require a greater separation between facilities.
8.Consider incorporating the City of Sacramento Small Cell Design & Deployment Standards. The
City of Sacramento Small Cell Design and Deployment Standards (Attachment 5) include some
very good measures to minimize the visual impacts of small cell wireless facilities. Several of the
standards are recommended by staff (discussed below and presented in Attachment 2).
Recommended standards include, among others: a minimum setback from facility to the closest
residence; placing antenna mountings in a concealed cannister; and a spacing requirement
between a new pole for wireless facilities and the existing utility pole or light standard.
9.Provide for direct appeals to the City Council. As discussed above, the FCC ruling: a) sets forth
limits on permit processing deadlines and fees; and b) limits state and local discretion in the
assessment of aesthetics. The processing deadlines can be extremely challenging for
discretionary permit applications, especially if the action is taken at a staff level. Discretionary
permits are afforded an appeal process that can be exhausted in several steps (Planning
Commission review and action, followed by final review and action by the City Council).
Exhausting the full appeal process can stretch-out numerous months because of noticing
requirements and set meeting dates for the Planning Commission and City Council. Given the
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 12
prescribed time limits set by the FCC ruling (shot clock), all appeals of staff actions should be
directly forwarded to the City Council (discussed below under proposed regulations).
Draft Ordinance and Resolution
As discussed above, staff recommends that the City establish a separate set of procedures and
guidelines that are specific to small cell wireless facilities. The following is a summary of the draft
ordinance and resolution (see Attachments 1 & 2):
1.Amend SRMC Title 14 (Zoning), Section 14.03.030 (Definitions) to add a new definition for “small
wireless facility.”
2.Amend SRMC Section 14.16.360 (Wireless Communication Facilities) to specifically include small
wireless facilities as part of the mix of wireless communication facilities.
3.Add new SRMC Section 14.16.361 (Small Wireless Communication Facilities). The text for this
new section acknowledges that small wireless facilities in the public right-of-way are unique and
subject to additional provisions and standards adopted by separate resolution of the City Council.
4.Adopt resolution setting forth policies, procedures, standards and limitations for small wireless
communication facilities. The draft resolution includes the following:
a.The “shot clock” time limits for processing and action on an application;
b.Application submittal requirements to mirror the submittal requirements in SRMC Section
14.16.360.
c.Requirement of co-location versus installation of new poles.
d.Requirements for “batched” or “grouped” applications.
e.In residential districts, limit installation to major and minor arterials as defined by General Plan
2020 Exhibit 22 (Attachment 4).
f.Separation requirements between small cell installations of 300 feet. If installed on existing
utility poles or light standards, waive the separation requirement if the antenna and boxes are
concealed in a canister or are flush-mounted on the pole.
g.Dimensional and stealth design requirements.
h.For new installations, requirement for a separation of 300 feet to the closest existing utility
pole or light standard.
i.A height standard requiring a clearance of equipment installation of a minimum of 10 feet from
grade and a maximum height of five feet above the existing pole.
j.Requirement for undergrounding of associated equipment.
k.Limiting signage to only signage required by the FCC.
l.To address the shot clock limitations for application processing, requirement that all appeals
be directly referred to the City Council.
As the FCC ruling will go into effect in mid-January 2019, staff is prepared to bring forward an urgency
ordinance at the next, December 17, 2018 City Council meeting. With adoption of an urgency ordinance,
the City will be prepared to process applications for small wireless facilities when the FCC ruling becomes
effective.
As discussed above, the FCC ruling sets limits on the fees that can be charged on small cell wireless
facility applications in the public right-of-way. An assessment of the City’s current fees relative to their
application for small cell wireless facilities in the public right-of-way is discussed under the Fiscal Impact
section of this report (below).
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 13
Environmental Review
Although this report is informational, it includes a draft ordinance and regulations for small cell wireless
facilities that could ultimately be adopted by the City Council (see Recommended Next Steps below).
The draft ordinance and regulations would be exempt from the California Environmental Quality Act
(CEQA) Guidelines per Section 15061(b)(3), which excludes projects from environmental review where
“it can be of certainty that there is no possibility that the activity in question may have a significant effect
on the environment.”
Regarding environmental review for individual small cell wireless facility applications, the FCC ruling limits
the local jurisdiction review of such facilities. It is expected that CEQA review for such applications would
be no different than for other wireless communication applications processed by the City. For current
applications, the ministerial review action is exempt from environmental review under CEQA Guidelines
Section 15268. If the current applications require discretionary review, the action is typically exempt from
review under CEQA Guidelines Sections 15301 (Existing Facilities) or 15303 (New Small Facilities).
Recommended Next Steps
As discussed above, the FCC ruling will go into effect in mid-January 2019. Therefore, it is prudent to
be prepared and move forward with a local ordinance and regulations that are specifically applicable to
small cell wireless facilities. It is recommended that the attached, draft urgency ordinance and
accompanying resolution outlining permitting and regulations will be scheduled for the December 17,
2018 City Council meeting for consideration. Staff will continue to work on a fee study to determine if the
current, non-recurring wireless communication facility fees need to be changed.
COMMUNITY OUTREACH:
Notice of this meeting was mailed to a list of stakeholders 15 days prior to this meeting (see Attachment
6 for meeting notice). Through the course of research on the FCC ruling and small cell technology, there
have been several avenues of outreach that have been implemented. This outreach has included
communications and meetings with the EMF Safety Network (network of Marin citizens/residents
concerned with the health risks associated with RFR emissions), other local municipalities, Marin General
Services Agency (MGSA), and the Verizon Community Engagement Team (CET). The following is a
summary of this outreach:
•EMF Safety Network- Over the past several months, City staff hosted three meetings with the
EMF Safety Network, Marin Education/Outreach and associated concerned residents. One of
the primary concerns of the EMF Safety Network is related to electromagnetic emission from
installation of wireless facilities (including small cell wireless). The meetings included a discussion
of what approaches are being taken by other local municipalities. The position of the EMF Safety
Network is that small cell wireless facilities designed to provide 5G technology should be
prohibited in residential districts and that there be strong spacing and separation requirements.
In these meetings, staff was presented a detailed presentation on the application of “fiber optics”
in-lieu of wireless communications, which is an alternative approach to high speed service.
Infrastructure for fiber optics is currently in-place in many areas of Marin County.
A detailed email with selected materials (suggested ordinance recommendations, articles on
health risks associated with small cell/5G technology) has been prepared and submitted by the
EMF Safety Network. This email and material are attached (see Attachment 7, correspondence
received). This letter includes a number of recommended requirements for permitting and
spacing, as well as prohibitions. As discussed above, in preparing the draft procedures and
regulations, staff considered some of the suggestions that were discussed in these meetings.
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 14
•Other Local Municipalities. Planning staff research revealed that the City of Sacramento has
rolled out a 5G Pilot Program as of October 1, 2018. The City has been actively working with XG
Communities, a telecommunications company that has in operation since 2015. This resulted in
a massive analysis of the wireless inventory and capacity needs in the City of Sacramento. The
goal was to have the City be “prepared for the future”, in order to take advantage of a host of new
and innovative technologies (driverless cars, connected health care (“telemedicine”), and public
safety using “smart infrastructure”. Staff has been in communication with staff from the City of
Sacramento’s Planning Division and IT Division to learn how they are handling the 5G wireless
application. Our goal is to learn from their efforts as we start the process to update our Zoning
Ordinance with respect to design guidelines and permit implementation.
•Marin General Services Agency. MGSA has Master License Agreements with Verizon and
Mobilitie for use of street light poles within the City. Marin General Services does not expect
application to begin rolling in anytime soon. However, the agreements establish a process for
allowing installation subject to some limitations, including:
o Only one carrier will be permitted per light pole except in unique situations;
o Carriers will be required to receive approvals from local jurisdictions before installation is
approved by MGSA; and
o Carriers will need to submit construction drawings and product specifications before
installation.
•Verizon Community Engagement Team. Staff has also been coordinating with Verizon, which has
created a new “Community Engagement Team”. This new department is specifically tasked to
work with both the local community and the public to answer questions about plans for small cell
and 5G projects. Verizon representatives have also stated that deployment of small cell facilities
is not expected anytime soon, and no specific site locations for %G application have been
selected at this time. Verizon has committed to work with the City in identifying equipment that
is considered suitable to the City and that can be used as a template for deployment. They noted
the following:
o Verizon is agreeable to comply with separation limits established by the City;
o Installation on light poles will likely include antennas as well as remote radio units (RRU);
o Verizon is interested in working with the City to identify appropriate placement;
o Undergrounding of equipment will not be proposed by the carriers due to complexity and
costs associated with undergrounding; and
o Fiber optic cable will be needed. The facility will tap into existing cable or install new if none
is available.
FISCAL IMPACT:
The proposed adoption of an urgency ordinance and resolution has no direct fiscal impact on the City of
San Rafael. However, the fees that are charged (both non-recurring and recurring) for small cell wireless
facility applications could have a fiscal impact on the City. Per the FCC ruling, the fees charged by the
City for small cell wireless facilities must be fair and reasonable. The “non-recurring” fees that are
presented in the FCC survey (discussed above) are below the fees that the City currently charges for
both minimal review (co-location) and new antenna site facilities. However, staff finds that for now,
application of our current fees are “fair and reasonable” and that they should be required for small cell
wireless facilities. The current wireless communication fees are based on a 2011 Cost of Services Study,
which found that: a) the Administrative Design Permit fee of $1,167.00 represents 97% cost recovery
(staff time to process and administer the application); b) the $398.00 Telecommunication Fee represents
100% cost recovery; and c) the more significant permits for new antennas/structures
($2,258.00/$4,693.00 for Environmental and Design Review Permit) cover approximately 80-85% of City
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 15
staff time. The $246.00 fee for a construction-related Encroachment Permit (“non-recurring” fee) is also
100% cost recovery. For now, staff recommends that there be no changes to the Master Fee Schedule,
but staff will conduct further study to determine if the fees should be changed.
OPTIONS:
The City Council has the following options to consider on this matter:
1.Accept the report and direct staff to return to the City Council at the December 17 , 2018 City
Council meeting with an urgency ordinance and resolution.
2.Direct staff to return with more information.
3.Take no action.
RECOMMENDED ACTION:
Accept report and direct staff to prepare an urgency ordinance and resolution for consideration at the
December 17, 2018 meeting.
ATTACHMENTS:
1.Suggested Amendments to San Rafael Municipal Code (SRMC) Title 14 -Zoning
2.Draft Resolution (containing regulations, standards and permitting)
3.Map of 41 existing, permitted wireless communication facilities
4.General Plan 2020 Exhibit 22- San Rafael Roadways and Arterials
5.City of Sacramento Small Cell Design & Deployment Standards
6.Public Meeting Notice
7.Correspondence received to date
ATTACHMENT 1
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Suggested Amendments to San Rafael Municipal Code (SRMC) Title 14 -Zoning
1.Chapter 14.03 - Definitions Amend the list of definitions in Section 14.03.030 by
amending and inserting new definitions, as shown below by strikethroughs for
deletions and underline/italics for insertions, in alphabetical order, as follows:
14.03.030 - Definitions.
“Small Wireless Facility” means a small wireless facility as defined by the FCC and that
meets the following requirements:
1.Meet one of the following mounting requirements:
a.are mounted on structures 50 feet or less in height including their antennas as
defined in section 1.1320(d), or
b.are mounted on structures no more than 10 percent taller than other adjacent
structures, or
c.do not extend existing structures on which they are located to a height of more
than 50 feet or by more than 10 percent, whichever is greater;
2.Each antenna associated with the deployment, excluding associated antenna
equipment (as defined in the definition of antenna in section 1.1320(d)), is no more than
three cubic feet in volume;
3.All other wireless equipment associated with the structure, including the wireless
equipment associated with the antenna and any pre-existing associated equipment on
the structure, is no more than 28 cubic feet in volume
Antenna equipment, means equipment, switches, wiring, cabling, power sources, shelters or
cabinets associated with an antenna, located at the same fixed location as the antenna, and,
when collocated on a structure, is mounted or installed at the same time as such antenna.
"Wireless communication facilities" means facilities regulated by the FCC that transmit
and/or receive electromagnetic signals for cellular technology, personal communication
services, enhanced specialized mobile services, paging systems, and radio and television
broadcast transmission facilities. Facilities include antennas, microwave dishes, parabolic
antennas, and all other types of equipment (but does not include small wireless facility, which is
defined separately under “Small Cell Wireless Facility”) used in the transmission or reception of
such signals; telecommunication towers or similar structures supporting said equipment;
associated equipment cabinets and/or buildings; and all other accessory development. These
facilities include amateur radio antenna structures that exceed thirty feet (30′) in height but do
not include government-operated public safety networks.
2.Chapter 14.16 (Site and Use Regulations)
Add Section 14.16.361 (Small wireless communications facilities) in its entirety as noted
below by underline/italics:
14.16.361 – Small wireless communication facilities.
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A.Purpose. This section establishes procedural requirements and standards to regulate the
streamlined review of small wireless communications facilities (as defined in section
14.03.030 of Chapter) within the public right-of-way or on public and private property to
minimize the potential safety and aesthetic impacts on neighboring property owners and the
community, and to comply with applicable state and federal regulations. To fulfill this
purpose, all small wireless facilities shall be reviewed in compliance with Policy Resolution
adopted by City Council and as may be revised.
3.Chapter 14.16 (Site and Use Regulations)
Amend Section 14.16.360 (Wireless Communications Facilities) as shown below by
strikethroughs for deletions and underline/italics for insertions:
14.16.360 - Wireless communication facilities.
A.Purpose. This section establishes standards to regulate the design and placement of
towers, antennas, and other wireless communication transmission and/or reception facilities
(hereinafter called wireless communication facilities) on public and private property,
including facilities within the public right-of-way to minimize the potential safety and
aesthetic impacts on neighboring property owners and the community, and to comply with
applicable state and federal laws, including the Federal Telecommunications Act of 1996.
This section does not apply to small cell wireless facilities as defined under Section
14.03.030, which are regulated by Section 14.16.361. To fulfill this its purpose, this section
is intended to:
1.Establish review and approval requirements, application submittal requirements, and
development standards to regulate the design and placement of wireless
communication facilities so as to preserve the visual character of the city and to ensure
public health and safety, consistent with federal law and Federal Communications
Commission (FCC) regulations.
2.Acknowledge the community benefit associated with the provision of wireless
communication services within the city.
3.Encourage the joint use of new and existing ground mounted facility monopole/tower
sites as a primary option rather than construction of additional single-use towers.
4.Allow the community development director, or delegated staff, to make certain
determinations under the provisions of this section.
B.Zoning Review Required.
1.Ministerial Review. A staff level ministerial review shall be required and obtained from
the community development director, and no discretionary use permit or environmental
design review planning permits shall be required, for the following types of wireless
communications facilities to assure compliance with the requirements of subsections
G, H, I, J, K, L and M of this section:
a.Co-located facilities on an existing approved monopole or tower structure (i.e.,
ground mounted facility) that utilizes or improves stealth design characteristics of
the facility, and/or does not substantially increase the visible height or overall
dimensions of the structure and/or ground lease area. The alteration or addition
shall not significantly change the appearance of the existing facility or its stealth
design features, or increase visual height, overall dimensions, or ground lease
area by more than ten percent (10%).
ATTACHMENT 1
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b. Building-mounted facilities, including modification to existing permitted facilities
that are architecturally compatible with and entirely integrated into the existing
building façade (i.e., stealth design). In general, to be deemed architecturally
compatible and entirely integrated with the building façade, the modification shall
utilize or improve existing roof-top screening solutions, shall not increase the
building height, and shall be flush with and designed to blend into the existing
building walls or facades.
c. Ministerial review shall not apply to modifications of monopoles or towers, new
building additions, extensions, projections, etc. made to existing facilities which the
community development director determines would increase the visual impacts of
the facility. This shall include extensions to height of a facility that exceeds the
height limits of the base zoning district. In such instances, an environmental and
design review permit shall be required for the stealth design modifications
pursuant to the provisions of Chapter 14.25.
2. Discretionary Review. A zoning administrator level use permit and an environmental
and design review permit shall be required for the following wireless communication
facilities pursuant to the requirements of Chapter 14.22, Use Permits, and Chapter
14.25, Environmental and Design Review Permits, consistent with the provisions of this
section:
a. New ground-mounted facilities (towers and monopoles) or significant additions
proposed to existing facilities that would increase its visual height, overall
dimensions and/or lease area (e.g., more than ten-percent increase in the existing
permitted height, overall dimension, lease area); and
b. Any facility which in conjunction with existing facilities in the area, exceeds the
Federal Communications Commission (FCC) standards for public exposure for
radio frequency radiation (RFR) emissions.
c. The community development director may determine that minor modifications to an
existing facility shall be subject to an administrative level design review. In general,
to be deemed a minor modification, the alteration or addition shall not significantly
change the appearance of the existing facility or its stealth design, or increase
visual height, overall dimensions, or ground lease area by more than ten percent
(10%).
d. The community development director may elevate the project for review and action
by the planning commission or refer a project to the design review board for its
recommendation, as determined necessary to assure that appropriate stealth
designs are being proposed to the maximum extent practicable, that the facility
location is suitable, that development appropriately responds to its setting, and that
the requirements of this section are substantially addressed.
C. Appeals. All discretionary decisions of the community development director, zoning
administrator, or the planning commission may be appealed in accordance with the
provisions of Chapter 14.28, Appeals.
D. Application Requirements. Applications for a use permit and/or an environmental and
design review permit shall be initiated by submitting all of the following information and any
revised application materials in the manner prescribed:
1. A completed application form, signed by the property owner or accompanied by a letter
of authorization that states the property owner has read and agrees to the filing of the
application as well as the specific conditions of application cited on the application
ATTACHMENT 1
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form, and accompanied by the required fee. Application procedures and processing
timeframes shall be in accordance with state law requirements and the procedural
guidelines established by the community development director.
2.Peer Review. Prior to accepting an application as complete, the city may require at its
sole discretion that a peer review of the project be conducted by a qualified RF
engineering consultant, as deemed necessary to confirm the adequacy of the RFR
study and/or the technical design requirements of the facility. The consultant shall be
selected by the city and paid for by the project applicant. Peer review is typically
required for new ground-mounted monopole or tower facilities, building mounted
facilities lacking stealth design, facilities proposed within the less-preferred residential
and open space areas, or RFR studies that are deemed to warrant further review.
3.Submittal/Re-submittal Meeting Required. Applications for a wireless antenna facility
must be made in person during the community development department, planning
division public counter hours. A pre-submittal meeting is encouraged, and a re-
submittal meeting shall be required. Applications and any subsequent resubmittals that
are not made in person and during scheduled times shall not be deemed accepted for
filing and will be returned.
4.Pre-application or Conceptual Review. A pre-application and/or conceptual review are
strongly recommended prior to submitting formal applications for new ground-mounted
monopoles or towers, new building mounted facilities or projects in less-preferred
residential and open space areas.
5.Revised applications. Unless waived by the community development director,
resubmitted applications that result in a substantially revised facility design, size, height
or location such that a new round of completeness review is warranted, shall be
required to be withdrawn and a new application shall be filed for the substantially
revised project.
6.Extensions of time. Applications deemed incomplete must be resubmitted within 30
days or they shall be deemed automatically withdrawn, unless the applicant has
requested a one-time extension in processing time to resubmit, not to exceed 90 days.
If the application is deemed automatically withdrawn, a new application shall be
required in order to proceed with the project.
7.Six (6) initial sets of materials and plans showing the following information:
a.Project Description. A complete project description, including the following
information on the proposed wireless communication facility:
i.Number and sizes of antennas and approximate orientation,
ii.Other technical information regarding transmission equipment such as
maximum power output and frequencies,
iii.Copy of FCC license,
iv.Heights of proposed facilities,
v.Equipment enclosure type and size,
vi.Materials and colors of antennas and any equipment enclosure,
vii.Description of towers or other structures necessary to support the proposed
facilities, and
viii.Description of lighting, signage and landscaping proposed.
ATTACHMENT 1
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b. Site Plan(s). A site plan, showing the overall property on which the facility will be
placed, and a detail site plan for the project area, as needed for large sites,
provided on a twenty-four-inch-by-thirty-six-inch (24″ x 36″) sheet of paper and an
eleven-inch-by-seventeen-inch (11″ x 17″) reduction, and including the following
information:
i. Vicinity map,
ii. Parcel lines of the subject parcel,
iii. Contextual map showing structures on adjacent properties,
iv. Location and names of adjacent streets and drives proposed to serve as
access to the facility,
v. Topography of the subject parcel and location of any drainages within or
adjacent to the site,
vi. Location of all existing buildings, structures, utilities, parking areas, significant
trees and other natural forms, or other features which might affect the
proposed use of the property,
vii. Setbacks of proposed structures and improvements from the property lines,
viii. Location and height of required cuts and fills for the grading of land and any
retaining walls proposed,
ix. Location of proposed development including all towers, structures, buildings,
utility line extensions, driveways or roads, and parking areas,
x. Schematic drainage and grading plan, and
xi. North arrow, graphic scale, the applicant's name, assessor's parcel number
and date prepared.
c. Elevations. Elevations showing all sides of the proposed facility set forth on a
twenty-four-inch-by-thirty-six-inch (24″ x 36″) sheet of paper, and an eleven-inch-
by-seventeen-inch (11″ x 17″) reduction, including the following information:
i. Elevations and sections of the site displaying site topography, proposed
facilities including towers, equipment shelter and existing buildings,
ii. Wall, roof, tower and antenna materials,
iii. Fencing, air conditioning units and outdoor lighting, if any,
iv. Rooftop or building features such as vents, chimneys and antennas, and
v. Building or tower height as measured from natural grade.
d. Photo-Simulations. Photo-simulations of the proposed facility from key public
viewpoints based upon consultation with city staff. Photo-simulations shall display
existing and proposed views in an eleven-inch-by-seventeen-inch (11″ x 17″), or
larger, format, with the dates shown when the base photo was taken.
e. Landscape Plan. A landscape and irrigation plan, showing all existing and
proposed improvements, location of proposed plantings and type of landscape
material, for proposed ground-mounted facilities including equipment cabinets.
8. Alternative Site Analysis. An alternative site analysis is required if the proposed facility
is:
ATTACHMENT 1
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a.Located within any district other than a commercial or industrial district;
b.Located within fifty feet (50′) of a "Less Preferred Location," as defined in
subsection (G)(2) of this section (i.e., parks, open space or residential zoning
district);
c.Lacking stealth design; or
d.Not co-located with an existing approved facility.
The alternative site analysis shall be presented in a narrative form with supporting
maps and other graphics that identify the other site locations considered and rejected
in favor of the proposed site. The applicant shall provide supporting reasons why the
alternate sites were infeasible and rejected, why co-location or building-mounted
location has not been pursued (if applicable), and why the proposed site is superior
from a technical or other standpoint to the others considered.
9.Future Co-Location. For new ground-mounted towers or monopoles, a signed
statement that the carrier, or its future successors, will cooperate with the city to allow
future co-location of antennas at the proposed site if it is approved and that t he carrier
has reviewed and agrees to comply with all post-approval requirements of this section.
10. Story Poles. Story poles or mock-ups may be required if deemed necessary by the
community development director.
11. Radio Frequency Radiation (RFR) Study and FCC Compliance Details. For the sole
purpose of verifying compliance with the FCC radio frequency emission standards, an
emissions report which measures the predicted and actual levels of electromagnetic
field radiation emitted by the proposed facility operating alone and in combination with
radiation emitted from other existing or approved facilities that can be detected at the
proposed facility site. Radiation measurements shall be based on all proposed
(applications filed and pending), approved, and existing facilities operating at maximum
power densities and frequencies. The study shall identify the existing and predicted
electromagnetic field radiation in table form, identify any measures required to comply
with the FCC standards for predicted exposure levels, provide a summary of the
conclusions of the report and provide details for any signage, barriers or similar
mitigation that is recommended or required. If mitigation is required, the details for
signage, barriers or other physical improvements shall also be included on the project
plans prepared for the facility. It is the responsibility of the applicant to determine the
location and power of existing facilities.
12.Noise Analysis. A noise analysis for emergency generators or other noise-producing
facilities.
Applications accepted as complete. Once an application has been accepted as complete, it
shall be promptly scheduled for hearings, and a decision shall be made based upon the quality
of the information presented by the applicant.
E.Exemptions. The following types of facilities are exempt from the provisions of this section:
1.Facilities for which zoning permit applications were approved by the city and/or building
permits were issued on or prior to the effective date of this section and which remain
valid (i.e., not expired) shall be exempt from the review and approval requirements of
this section, except for the requirements for validation of proper operation, monitoring,
and removal of abandoned facilities, and for proposed modifications to existing facilities
which shall remain applicable;
ATTACHMENT 1
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2. Facilities owned and operated by public agencies; and
3. Proposed facilities that would be located entirely within a building and only serve that
building.
F. Public Notice. Notice of a public meeting or hearing for a wireless communication facilit y
subject to a use permit and/or environmental and design review permit shall be given in
accordance with Chapter 14.29, Public Notice, except that a public notice shall be mailed to
all property owners within one thousand feet (1,000′) of any proposed facility that includes a
tower or monopole. Public hearing and notice shall not be required for minor modifications
made to existing facilities that the community development director determines, pursuant to
the provisions of Section 14.16.360.B.3, would require only an administrative level
environmental and design review permit.
G. General Location Standards. The most desirable location for new wireless communication
facilities is co-location on existing facilities or buildings. All wireless communication f acilities
shall be sited to avoid or minimize land use conflicts in compliance with the following
standards:
1. Preferred Locations. The following list of preferred locations for wireless
communication facilities is in order of preference from most to least preferred:
Industrial, public or quasi-public, commercial and office zoning districts are the
preferred locations.
2. Less Preferred Locations. The following less preferred locations are listed in order of
preference from most to least preferred: Parks or open space and residential zoning
districts.
3. Avoid Residential and Open Space Areas. New monopoles or towers shall not be
located within residential, designated open space or conservation areas unless
sufficient technical and other information is provided to demonstrate to the satisfaction
of the planning commission or zoning administrator that location in such areas is
appropriate, subject to the following findings:
a. The location of the proposed facility site is essential to meet the service demands
of the carrier and no other alternative co-location, existing development or utility
facility site, or type of antenna support structure is feasible. This shall be
documented by the applicant providing a list of the locations of preferred
technically feasible sites, the good faith efforts and measures taken by the
applicant to secure these preferred sites, and the specific reasons why these
efforts and measures were unsuccessful.
b. The use of a monopole for the proposed facility by itself or in combination with
other existing, approved, and proposed facilities will avoid or minimize adverse
effects related to land use compatibility, visual resources and public safety.
4. Avoid Significant Buildings and View Sheds. Wireless communication facilities shall not
be located on historically or architecturally significant structures unless visually and
architecturally integrated with the structure and shall not interfere with prominent vistas
or significant public view corridors.
H. Design Requirements.
1. Co-Location. All new wireless communication facilities service providers shall co-locate
with other existing and/or planned new wireless communication facilities whenever
feasible. Service providers are encouraged to co-locate with other existing facilities
such as water tanks, light standards and other utility structures where the co-location is
ATTACHMENT 1
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found to minimize the overall visual impact of the new facility. Co-location of small cell
wireless facilities on light standards/poles, traffic lights, or other structures located
within the public right-of-way shall be subject to requirements of Section 14.16.361.
2.Stealth Design. All wireless communication facilities shall have a stealth design to
screen or reduce visual impacts and blend the facility into the existing environment.
Examples of stealth design are facade-mounted antennas located within architectural
features, so they are screened from view, or an antenna design that mimics
architectural features so they appear to be architecturally integrated as a part of the
building design, or facilities with colors and materials to minimize visibility such as a
non-reflective finish in a color compatible with the surrounding area. Stealth tower,
monopole or building design should seamlessly integrate with its setting and/or building
façade. A seamless integration would include façade mounted facilities that are flush
with the existing building wall or window plane and that are finished to match the
existing textures and finishes, or a high-quality faux tree or similar monopole/tower
design that would match existing surrounding vegetation or site characteristics.
Referral to the design review board may be required to confirm whether a particular
design solution would clearly integrate into an existing building or site and meet the
intent of stealth design.
3.Ground-Mounted Facilities. All new ground-mounted wireless communication
equipment, antennas, poles, dishes, cabinet structures, towers or other appurtenances
shall be:
a.Co-located on existing structures to the extent feasible. Co-location is preferred
over new monopoles or other towers erected specifically to support wireless
communication facilities unless technical evidence demonstrates that there are no
other alternative sites or feasible support structures, or the use of a monopole or
tower would avoid or minimize adverse effects related to the view shed, land use
compatibility, visual resources and public safety.
b.Sited to be screened by existing development, topography or vegetation to the
extent consistent with proper operation of the wireless communication facility.
Additional new, irrigated vegetation, or other screening, may be required as a
condition of approval.
c.Designed using high-quality techniques to minimum surrounding vegetation or
features in order to blend into the site to the maximum extent practicable.
4.Roof and Building-Mounted Facilities. Roof and building-mounted antennas and
equipment shall be:
a.Sited and designed to appear as an integral part of the structure or otherwise
minimize their appearance. Placing roof-mounted antennas in direct line with
significant view corridors shall be avoided. Where appropriate, construction of a
rooftop parapet wall to hide the facility may be required.
b.Integrated architecturally with the design, color, materials and character of the
structure or otherwise made as unobtrusive as possible. If possible, antennas shall
be located entirely within an existing or newly-created architectural feature (e.g.,
cupolas, dormers, chimneys or steeples) so as to be completely screened from
view. To the extent feasible, building-mounted antennas shall not be located on
the front, or most prominent facade of a structure, and shall be located above the
pedestrian line-of-sight.
ATTACHMENT 1
1-9
c.Whenever possible, base stations, equipment cabinets, back-up generators, and
other equipment associated with building-mounted antennas shall be installed
within the existing building or underground. If this is not feasible, the equipment
shall be painted, screened, fenced, landscaped or otherwise treated architecturally
to minimize its appearance from off-site locations and to visually blend with the
surrounding natural and built environment.
5.Signage. No advertising signage or identifying logos shall be displayed on any wireless
communication facility except for small identification plates used for emergency
notification and legally required hazard warnings.
6.Waiver Request. A waiver from these requirements may be requested if the applicant
can show, by substantial evidence, that compliance with a particular requirement is
technologically infeasible or would result in an unreasonable interference with signal
quality. The applicant will be required to prove that there are no feasible alternatives to
the waiver request. A waiver request may be subject to peer review conducted by a
qualified RF engineering consultant selected by the city and paid for by the project
applicant.
I.Development Standards.
1.Height. The maximum height of building-mounted antennas shall be in compliance with
the height limitations for the zoning district in which they are located. An exception to
antenna height may be granted by the planning commission or zoning administrator if
the RFR exposures and aesthetic quality of the proposed facility are found to be
acceptable. Antenna structures, including towers and monopoles, and mechanical
screening features related to wireless communication facilities, shall be regulated
subject to Section 14.16.120 of this chapter.
2.Setbacks.
a.Towers, guy wires, and accessory structures, including equipment cabinets, shall
comply with the setback requirements of the applicable zoning district. Towers
and support structures shall be located a minimum of two hundred feet (200′) or at
least three (3) times the height of the tower, whichever is greater, from existing
residential units or vacant residentially zoned property.
b.Building-mounted facilities may be permitted to extend up to two feet (2′)
horizontally beyond the edge of the structure regardless of setback requirements
through the application review process, provided that the antenna does not
encroach over an adjoining parcel or public right-of-way or otherwise create a
safety hazard.
J.Lighting. Any exterior lighting shall be manually operated, low wattage, and used only
during night maintenance or emergencies, unless otherwise required by applicable federal
law or FCC rules. The lighting shall be constructed or located so that only the intended area
is illuminated, and off-site glare is fully controlled.
K.Landscaping. Wireless communication facilities shall be installed in a manner that
maintains and enhances existing vegetation and provides new landscape material to screen
proposed facilities through the following measures:
1.The emphasis of the landscape design shall be to visually screen the proposed facility
and stabilize soils on sloping sites. Introduced vegetation shall be native, drought
tolerant species compatible with the predominant natural setting of the adjacent area.
ATTACHMENT 1
1-10
2.Existing trees and other screening vegetation in the vicinity of the proposed facility
shall be protected from damage both during and after construction. Submission of a
tree protection plan prepared by a certified arborist may be required.
3.All vegetation disturbed during project construction shall be replanted with compatible
vegetation and soils disturbed by development shall be reseeded to control erosion.
4.Appropriate provisions for irrigation and maintenance shall be identified in the
landscape plan. The city may impose a requirement for a landscape maintenance
agreement as a condition of approval.
L.Noise. Wireless communication facilities shall be constructed and operated in a manner
that minimizes noise. Noise reduction shall be accomplished through the following
measures:
1.Wireless communication facilities shall operate in compliance with the noise exposure
standards in San Rafael Municipal Code Chapter 8.13, Noise.
2.Normal testing and maintenance activities shall occur between eight a.m. (8:00 a.m.)
and six p.m. (6:00 p.m.), Monday through Friday, excluding emergency repairs.
3.Backup generators shall comply with the same noise standards referenced in
subsection (L)(1) of this section and shall only be operated during power outages,
emergency occurrences, or for testing and maintenance.
M.Radio Frequency Radiation (RFR).
1.RFR Standards. Wireless communication facilities operating alone and in conjunction
with other telecommunication facilities shall not produce RFR in excess of the
standards for permissible human exposure as adopted by the FCC.
2.RFR Report. Applications for wireless communication facilities shall include a RFR
report, prepared by a qualified expert, which identifies the predicted and actual (if
available) levels of RFR emitted by the proposed facility operating by itself and in
combination with other existing or approved facilities which can be measured at the
proposed facility site. Measurements for RFR shall be based on all proposed,
approved, and existing facilities operating at maximum power densities and
frequencies.
N.Post-Approval Requirements.
1.Validation of Proper Operation. Within forty-five (45) days of commencement of
operations, the applicant for the wireless communication facility shall provide the
community development department with a report, prepared by a qualified expert,
indicating that the actual RFR levels of the operating facility, measured at the property
line or nearest point of public access and in the direction of maximum radiation from
each antenna, is in compliance with the standards established by the FCC for RFR.
2.Five-Year Review. The owner or operator of a wireless communications facility shall
participate in the measurement by the city of the RFR of the facility, which shall be
conducted on a five (5) year cycle. The requirement for a five-year review shall be
made a condition of approval for all wireless communication facilities. The city will
contract to perform the testing with a qualified expert and the owners or operators shall
bear the proportionate cost of testing for its facility. The city will establish procedures
for:
a.Scheduling the five-year review period;
b.Hiring an expert to perform RFR testing;
ATTACHMENT 1
1-11
c.Collecting reasonable fees; and
d.Enforcement actions for nonpayment of fees.
3.Notification of Abandonment of Use. The owner or operator of an approved wireless
communication facility shall remove any abandoned facilities or restore the existing
approved use of a facility within ninety (90) days of termination of use.
4.Changes Affecting RFR. Any operational or technological changes to an approved
wireless communication facility affecting RFR exposures shall be reported promptly to
the city, including any change of ownership. The city may require new RFR testing
within forty-five (45) days of notification.
5.Changes to FCC Standards. Owner or operators of all approved wireless
communication facilities shall make necessary changes or upgrades to their facilities in
order to comply with any newly adopted FCC standards for RFR. Upgrades to facilities
shall be made no later than ninety (90) days after notification of the changed FCC
standards and the owner or operator shall notify the city in writing that the upgrades
have been completed.
6.Co-Location and Facility Upgrade Agreement. Owners or operators of all approved
wireless communications facilities shall agree to make their facility available for co-
location with other carriers. Modifications to the facility design shall be allowed to
accommodate additional carriers on a site, as well as to restore, replace, or upgrade
any screening that is deemed obsolete and removed as a result of modifications made
to the primary site structure, or concurrent with any upgrades proposed to the subject
facility.
7.Owners or operators of all approved wireless communications facilities shall be
responsible for maintaining the effectiveness of screening of its facilities, in compliance
with project approvals. This shall include pursuing modifications of existing approvals,
as necessary, should changes be made to the site or primary structure that would
reduce the effectiveness of screening provided for the facility.
N.Definitions.
1.Ground Mounted Facility" means a monopole, tower or any structure built for the
sole or primary purpose of supporting FCC-licensed wireless communications
facility antenna and their associated facilities. Wireless antenna facilities and
equipment that are mounted onto an existing structure, including existing utility
poles, on private property shall be considered building mounted co-located on an
existing structure. Mounting of wireless facilities on light standards/poles, traffic
lights, or utility poles within the public right-of-way shall be governed by Section
14.16.361.
2."Base station" consists of "radio transceivers, antennas, coaxial cable, a regular and
backup power supply, and other associated electronics.
3."Lease area" means the defined area on the ground or on a building in which
wireless facility equipment is placed and/or enclosed.
ATTACHMENT 2
2-1
RESOLUTION NO. ____________
RESOLUTION OF THE SAN RAFAEL CITY COUNCIL ADOPTING POLICIES,
PROCEDURES, STANDARDS AND LIMITATIONS FOR SUBMITTAL AND REVIEW OF
SMALL WIRELESS COMMUNICATION FACILITIES WITHIN THE PUBLIC RIGHT-OF-
WAY AS SET FORTH IN THE SAN RAFAEL MUNICIPAL CODE SECTION 14.16.361
WHEREAS, on September 26, 2018, the Federal Communications Commission (FCC) adopted
regulations pertaining to small wireless facilities setting forth limitations on state and local government
regulation of small cell wireless facilities that are placed on utility poles and street light standards located
in the public right-of-way; and
WHEREAS, the FCC ruling: a) limits the level of local permitting and discretion; b) establishes
“shot clock” rules (e.g., time limits and deadlines) for processing and action on local permits; and c)
limits the fees that can be charged for the facilities; and
WHEREAS, the FCC ruling further established that any aesthetic regulations and fees required for
processing of small wireless facilities be published in advance.
NOW, THEREFORE, BE IT RESOLVED, that the City Council hereby adopts the following
Policies, Procedures, Standards, and Limitations for submittal and review of Small Cell Wireless
Facilities within the public right-of-way:
A.Purpose.
This Policy Resolution establishes procedural requirements and standards to regulate the streamlined
review of small wireless communications facilities within the public right-of-way or on public and private
property to minimize the potential safety and aesthetic impacts on neighboring property owners and the
community, and to comply with applicable state and federal laws. To fulfill this purpose, all small
wireless facilities shall be reviewed in compliance with this Policy Resolution adopted by City Council
and as may be revised.
B.Definition
“Small Wireless Facility” means a small wireless facility as defined by the FCC and that meets the
following requirements:
1.Meet one of the following mounting requirements:
a.are mounted on structures 50 feet or less in height including their antennas, or
b.are mounted on structures no more than 10 percent taller than other adjacent structures, or
c.do not extend existing structures on which they are located to a height of more than 50 feet
or by more than 10 percent, whichever is greater;
2.Each antenna associated with the deployment, excluding associated antenna equipment, is no more
than three cubic feet in volume;
3.All other wireless equipment associated with the structure, including the wireless equipment
associated with the antenna and any pre-existing associated equipment on the structure, is no more
than 28 cubic feet in volume
ATTACHMENT 2
2-2
“Antenna equipment” means equipment, switches, wiring, cabling, power sources, shelters or cabinets
associated with an antenna, located at the same fixed location as the antenna, and, when collocated on a
structure, is mounted or installed at the same time as such antenna.
“Pole” means a single shaft of wood, steel concrete, or other material capable of supporting any
equipment which is mounted thereon.
C.Applicability
This Policy Document applies to all small wireless facilities as defined above, proposed within the public
right-of-way.
D.Application Requirements
Applications for a Small Wireless Facilities shall be in one of the following ways:
Type of Installation Type of Application
Co-location in a preferred location Telecommunication Application
Installation of a New Pole Telecommunication Application
Environmental and Design Review Application
Any Installation in a Least Preferred Location Telecommunications permit Application
Environmental and Design Review Application
In addition, an encroachment permit shall be required for all work within the public right-of-way.
Submittal requirements for small wireless facilities shall be the same as required for submittal of other
wireless communications facilities outlined under section 14.16.360. In addition, applications for small
wireless facilities shall demonstrate compliance with Section H. Design Requirements and Limitations
outlined below.
E.REVIEW AUTHORITY AND APPEALS
The Planning Division shall have review authority over applications for Environmental and Design
Review for small wireless facilities. No notification or public hearing is required pursuant to SRMC
Section 14.25.060C (Administrative Design Review). The Planning Division’s decision on such
applications shall be subject to appeal directly to the City Council.
The Department of Public Works shall have review authority over encroachment permits within he public
right-of-way.
F.REQUIREMENTS FOR BATCHED PERMITS
An Applicant may submit batched applications. Batched applications include:
1.Simultaneous submittal of not more than Ten (10) applications for small wireless communications
Facilities, or
2.A single, consolidated application covering no more than ten (10) small wireless communications
facilities locations, provided that the proposed communications facilities are to be deployed to include
all of the following:
a.on the same type of structure;
b.within the same linear alignment; and
c.using the same or similar equipment;
ATTACHMENT 2
2-3
G. Application Fees
Applications for small wireless facilities shall include the following fees:
Type of Installation Fee Fee Description
Co-location in preferred location $ 398.00
$ 246.00
Telecommunication fee
Encroachment Permit
Installation of New Pole $ 398.00
$ 1167.00
$ 246.00
Telecommunication fee
Environmental and Design Review Fee
Encroachment Permit
Installation in least preferred
location
$ 398.00
$ 1,167.00
$ 246.00
Telecommunication fee
Environmental and Design Review Fee
Encroachment Permit
H. Zoning Review Required.
New small wireless facilities shall be processed within the time periods established by the FCC as
follows:
Review of applications to collocate a small wireless facility using an existing pole: 60 Days
Review of applications to deploy a small wireless facility using a new pole: 90 Days
I. Design Requirements and Limitations
Co-Location Co-location on an existing structure is encouraged as long as other
aesthetic and structural requirements can be complied with.
Preferred Locations Installation of small wireless antenna with the public right-of-way
shall be located in the preferred locations listed below in ordered by
preference:
▪ Adjacent to commercial, industrial and public quasi-public
districts
Less Preferred Locations Installation of small wireless antenna with the public right -of-way may
be located in the less preferred locations listed below:
▪ Right-of-ways adjacent to residential districts- permitted only
on streets identified as Arterial and Minor Arterial streets under
the General Plan 2020 Exhibit 22.
Least Preferred Locations Except as noted above, installation of small wireless antenna within
the public right-of-way adjacent to residential districts should be
avoided.
Installation on traffic signals
Not Permitted
Installation on existing poles
within the right-of-way
▪ Installation on existing or new pole shall consist of antenna and
radio relay units (rru) only.
▪ Separation requirements-
There no separation requirements for installation of small wireless
ATTACHMENT 2
2-4
antennas that meet the following criteria:
- Antenna shall be in a concealed canister located on the
top of pole
- The canister shall not exceed the width of the existing
pole by more than 6 inches
- associated cables and wires shall be concealed/ flush
mounted
- other associated equipment shall be installed
underground or
All other types of antenna used on top of or extending from pole
(e.g., rectangular box, panel), the minimum separation requirement
shall be 300 feet. All associated cables and wires shall be concealed
or flush mounted.
Installation of new poles
within the right-of-way
New poles shall be located no closer than 300 feet from an existing
utility pole or light pole and shall meet the following criteria
- Antenna shall be in a concealed canister located on the top of
pole
- The canister shall not exceed the width of the existing pole by
more than 6 inches
- associated cables and wires shall be concealed/ flush mounted
Installation of associated
equipment
Equipment associated with the small cell wireless facility shall be
undergrounded or screened from public view. Equipment and/or
screening shall not interfere with pedestrian path of travel line of
sight
Undergrounding
See above
Lighting New pole installations proposals shall include existing and proposed
lighting and electrical infrastructure and shall be design such that
uniform distribution of light is achieved.
Signage: Signage is not permitted except to comply with FCC regulations to
provide safety warnings.
Dimension limits: Small wireless facilities shall not exceed the width of an existing
structure.
Height limits: Pole mounted antennas shall comply with the following height
limits:
▪ minimum height of 10 feet from sidewalk
▪ maximum height of 5 feet above existing pole
ADA requirements: Installation on poles that violate any ADA access requirements shall
not be allowed.
Screening of antennas:
See installation limits on poles above
Noise: Wireless communication facilities shall be constructed and operated
in a manner that minimizes noise. Noise reduction shall be as
required under Zoning Code Section 14.16.360
Post-Approval Requirements.
forty-five (45) days review
Post-approval requirements shall be as required under Zoning Code
Section 14.16.360.
ATTACHMENT 2
2-5
Five-Year Review:
Radio Frequency Radiation
(RFR):
RFR Standards. Small wireless facilities operating alone and in
conjunction with other telecommunication facilities shall not
produce RFR in excess of the standards for permissible human
exposure as adopted by the FCC. Applications shall include RFR
report consistent with Zoning Code Seciton 14.16.360
BE IT FURTHER RESOLVED that any and all amendments to the Small Cell Wireless policies,
procedures, standards and limitations, as deemed necessary from time-to-time shall be adopted by
resolution of the City Council.
I, Lindsay Lara, Clerk of the City of San Rafael, hereby certify that the forgoing resolution was adopted
as a regular meeting of the City Council on the _____ day of December 2018.
AYES:
NOES:
ABSENT:
_______________________________________
LINDSAY LARA, City Clerk
ATTACHMENT 3
MAP OF 41 EXISTING, PERMITTED WIRELESS
COMMUNICATION FACILITY SITES
ATTACHMENT 4
GENERAL PLAN 2020
CIRCULATION ELEMENT EXHIBIT 22
SAN RAFAEL ROADWAYS AND ARTERIALS
ATTACHMENT 5
CITY OF SACRAMENTO
SMALL CELL DESIGN & DEPLOYMENT STANDARDS
City of Sacramento
Sma ll Ce ll Des ign & Dep loyment Standards
Below are the preferred design crite ria for a sm all ce ll , howev er othe r des igns may be approved
by t he Director of the Publi c Works o n a case by case b as is.
Po les
• Carri ers shou ld consider siting as mu ch as possible on existing infrastructure or Cit y
assets.
• Attac hments sh all be limited to ma st arm str ee t lights on Ca ltrans Type-15 Pol es.
o Attachments to hi sto ri c, ornamental, and neig hb orhood 20' mast arm poles sha ll
not be p ermitted.
o Attac hm ents to traffic signa l poles shall not be pe rmitted.
• Ne w m ast arm pole s (Ca ltrans Type-15) sha ll be des ign e d pe r t h e current City Sta ndard s,
to sea m l ess ly fit with th e ex i sting lighting system.
o New pole lo cations withi n t en {10) f ee t of ex isting utility or l ight po les shall not
be permitted.
o . A plan for a po le shall be su bmitted for review and approva l t h at shows the
' existing and propos ed streetl ight and el ectri ca l i rifrastru.ctu re and d esign ed in
such a w ay th at a un iform l ight distribution i s provid ed i n t h e subj ect area.
o Once approved and installed, t he new streetl ight pole and oth er infrastructure
w ill be' the property of the Ci ty of Sacramento.
• Po le locati on s where the tran sm ittin g ante nna is less th an ten {10) feet horizo n~al from
private prope rty (i.e. residential w indow, RT r ail OCS po les/ca bl es) shall not be
pe rmitted.
• Po les in violation of A DA access r equirem e nts shall not b e permitted. -
• Modification s to o rn amenta l streetli ght pol es for th e insta ll ation of photoce lls are the
carrier's responsib ility. All costs associated w ith fixi n g or repl acing t he damage to the
pole or any components of t h e po le that o cc ur during insta llation ar e to be pai d by t he
ca r rier.
• All el ec trical ci rcuits t hat incl ud e the decorative str eetlight pol es on Capito l M all , from
I
Tower Bridge to 8th St r ee t sh all be avoided for photocell m odification.
• Durin g a fiel d ve rification, if a pole foun dation is found to be in adequat e ba se d on the
dimensions and/or condition of the foundatio n not matching the p lans, field work s hall
be sto pped and the pl ans redes igned and res ubr.n itted with th e propose d foundation
details, co nduit and cond u ctor layo ut, anchor bolt pattern co nfirmatio n, si n gle line
diagra m an d site plan for City El ectrica l and Structu ra l Eng in ee rin g ap proval.
• In t he case wh ere a new pol e foundati on is required, wherever po ss ibl e reuse the
locati on fo r the existing foundation to pl ace t h e new pull box for the r elocated street
lig ht pol e.
Ap ril 6, 2018 pg . 1
City of Sacramento
Smal l Ce ll Design & Deployment Sta n dards
Equ i pmen t and Esth etics
• Equipment on pole shall contain antenna and stacked radio r el ay units (RRU} only. All
other eq uipm ent sho uld be low-profile, blended into the surroundin g environme nt, or
placed in another l ocation .
• Equipment and enclosures (not i_ncluding antenna) sha ll be of low-profil e form· factor.
They sha ll be mounted as close to the po le as allowed by applicab l e regu l ation and
manufacturer equ i pm ent standards anp shall not exten q more than 12" from the pole.
• Antenna shoul d be mounted in a concea led canister (cantenna} on the top of pole and
all equ ipm en t shoul d b e mounted flush to the pole.
• Antenna he ight shall not excee d 2'.
• Antenna width .sha ll not exceed 14.5" in diameter.
• Equipment and cab ling be l ow the anten~a needs to be shrouded. All equ ipment on each
pole sha ll be housed in a suitab l e enclosure to conceal components and cab ling from
public view. The enclosu re shall be coated in material and color m atching that of the
pole. The permittee sha ll regu larly maintain the enclosure and th e e quipment.
• No expose d m eter, meter pan or meter pedestal may be used. Metered panels and
sockets shall be mounted at 10' or higher from grad·e.
• Cabling bel ow radio relay units shal l enter the pole with no more than a five -inch gap
betwee n bottom of each radio rel ay un it and the bottom of the corresponding entry
hole on the pole. Conpu it connection at pole entry points shall utilize the sma ll est fitting
sizes ava il able . Sea li ng compounds, if utilized, sha ll b e tidy without excess bubbling and
painted to match pole .
• If drilling and cutting into City po les, hole s wil l b e structurally we lded and r einforce d.
Seams and bolts/screws at antenna an d shroud assembly area sha ll be fabricated a nd
insta ll ed in a m anner so as to reduce their vis ibility (e.g. flush mounting sc r ews ) from
sidewa lk leve l.·
• Retain fiber and power i nside the pole at the base.
• Ensure any l egs/handles are removed from RRU s and equipment lo gos are all removed.
• Util ize sig na ge (e.g. road, guide, informati ona l signage }, or other appropriate el ements,
in front of RRUs to reduce visibility for pole loc ation s in areas which define City (e.g.
hi storic distri cts)
• Remove all manufacturer decals and logos. Retain one Radio -Fre qu en~y (RF} warni ng
sti cker near antenna with sma ll est size and lowest visibility co lor all owed.
Radio Freq u en cy
• City RF engineer, Street Li ght and Signage Technicians or representatives sh all have
access to disconnect r ad io el ectrica l service for maintenance to str eet lights or RF
interference to pub l ic safety rad io syste m s.
Ap ril 6, 2018 pg. 2
City of Sacramento
Sma ll Ce ll Desig n & Deploym ent Sta n da r ds
• City RF engineer shall receive RF study ind i cat ing proposed location, frequency, and EIRP
will not interfere with Public Safety Radio Network.
• All wireless carri ers shall provide r ad io maintenance contact, who can be notified prior
to radio power being disconnected.
Sub m itta ls
• Each submittal sha ll includ e a noise study. Facilities may generate no more than 45
decibels within t hree feet of any residential dwel ling or City p ark boundary, and no
more than 55 decibels within ten feet of any commercial structures.
• Each submittal of new poles lo ca t e d w ithin 10' of roadway without curb and gutte r sha ll
include a vehicle impact study an d protective devices such as bollards.
• Subm ittals sha ll be prepared by qua lified professiona ls who are experi enced in the City
of Sacr amento and local stan dards. At the minimum, submittals sha l l meet the
fol lowing criteria:
o Photo simulations are clear, consistent , and realistically portray anten nas,
eq uipment, offset bracket systems, and cabling. Submitta ls ba se d on Google
Street Views are not acceptable.
o Include engin ee red drawings reflecting topographic/property maps processing
ROW, PUE, an d property line delineation.
o Private property access and ease m ents, if require, shall be supported by
agreeme nts granting the permittee such access or easements. The agreement
sh all hold the City harmless of any li ab ilities.
o Each submittal shall include a SM UD comm itment letter ap proving the electrica l
POC, co nn ecte d equ i pment spec ification sh ee t, location map, electrica l lo ad
calcu lation and certifi catio n that is stamped and signed by a licensed electrica l
engineer .
o Underground and over~ead utility shal l be located and confl icts identified.
o · Bore pits an d other work above surface in City ROW shall be repaired or replaced
according to City standards. .
• A comp l ete submittal package for small ce ll installation in the ri ght-of-way includes each
item li ste d b elow and must be its own PDF an d must the follow the associated naming
conve ntion below. Submit the app li cation files e lectronically to
DEP erlTiit@cityofsac ram ento.org .
o Revocable Permit Application
o Co n structi on Encroach m ent Permit Applicati on
o Radio Fr eq u ency Report
o Structura l Analysis prepared by a State of California Li censed Civil Engineer
o Constructio n Plans prepared in accordance with the City of Sacramento -
Department of Publi c. Works drawings stand ards. The insta ll ation of t he sma l l cel l
Apri l 6, 2018 pg. 3
City of Sac r a m ent o
Sm all Ce l l Des i gn & De ploym e nt St and ard s
equ ipment on all approved permits must be performed by an electric al
contractor holding a current C-10 lice nse, as i ss u ed by the Ca lifornia State
License Board .
o Ce r tificate of Li ability In surance for Contractor and Own er of Equipm ent
o Contractor's Lic ense (C -10) and Contact In formation
o Fie l d Wa lk Data Co ll ection Form
o SMUD Appl ication (in one PDF)
• Required information on pages 14-15 of SMUD Agreement
• Th e equipment OEM specificat ions
• Se lf-certification letter verified by a Profess ional Eng inee r showing
m aximum
• Upon review and ap prova l of a submitted app lication, the Encro achments Desk wi ll
contact the app licant to confirm the constru cti on schedule, review and approve
applicant's traffi'c control plan, and assign an inspector.
• Th e notice to proceed with construction activiti es (permit) will be issued at the pre-
constructi on meeting by the inspector assigned by the City. It is the respo nsibi lity of the
applicant or its contractor to coordinate th e date, time, and location of th e pre-
co nstruction meeting with the assig n ed in spector.
Apri l 6, ·2018 pg.4
ATTACHMENT 6
PUBLIC MEETING NOTICE
NOTICE OF PUBLIC MEETING – CITY COUNCIL
You are invited to attend the City Council meeting on the following proposed item:
PROJECT: Report on Small Cell (5G) Wireless Communication Technology – The City Council will receive a presentation from Dr. Jonathan
Kramer of Telecom Law Firm on Small Cell (5G) W ireless Technology, which will include the recent Federal Communication Commission (FCC)
rulings and their near-term and long-term impact on local jurisdiction permitting and discretionary authority. The Community Development
Department staff will also present a draft ordinance for regulating small cell facilities. The objectives of the draft ordinance are to: a) establish
procedural requirements and standards to regulate the new FCC’s streamlined review of small wireless communications facilities located within
the public right-of-way or on public and/or private property; and b) to minimize the potential safety and aesthetic impacts on neighboring property
owners and the community, and to comply with applicable state and federal laws.
State law (California Environmental Quality Act) requires that this project be reviewed to determine if a study of potential environmental effects is required. It has
been determined that this project, which is an informational report, will have no physical impact on the environment. The Report on Small Cell (5G) Technology is
classified as a discussion item, which qualifies for a Statutory Exemption from the provisions of the California Environmental Quality Act Guidelines under 14 CRR
Section 15262 [Feasibility and Planning Studies].
MEETING DATE/TIME/LOCATION: Monday, December 3, 2018, 7:00 p.m. City Council Chambers, 1400 Fifth Ave at D St, San Rafael, CA
FOR MORE INFORMATION: Contact Caron Parker, Project Planner at (415) 485-3094 or caron.parker@cityofsanrafael.org. You can also
come to the Planning Division office, located in City Hall, 1400 Fifth Avenue, San Rafael, CA 94901. The office is open from 8:30 a.m. to 4:30
p.m. on Monday, Tuesday and Thursday and 8:30 a.m. to 1:30 p.m. on Wednesday and Friday. You can also view the staff report after 5:00 p.m.
on the Friday before the meeting at http://www.cityofsanrafael.org/meetings
WHAT WILL HAPPEN: You can comment on the project. The City Council will consider all public testimony. As this item is an information
presentation, no formal action will be taken by the City Council. However, the City Council will be requested to provide direction on proceeding
with adoption of the draft ordinance.
IF YOU WANT TO COMMENT: You can send written correspondence by email to the address above, or by mail/hand delivery to the Community
Development Department, Planning Division, City of San Rafael, 1400 5th Avenue, San Rafael, CA 94901.
At the above time and place, all written correspondence received will be noted and all interested parties will be heard. If you challenge in court the matter described above, you may be
limited to raising only those issues you or someone else raised at the public hearing described in this notice, or in written correspondence delivered at, or prior to, the above referenced
public hearing (Government Code Section 65009 (b) (2)). Judicial review of an administrative decision of the City Council must be filed with the Court not later than the 90th day following
the date of the Council’s decision. (Code of Civil Procedure Section 1094.6) Sign Language and interpretation and assistive listening devices may be requested by calling (415) 485-3085
(voice) or (415) 485-3198 (TDD) at least 72 hours in advance. Copies of documents are available in accessible formats upon request.
Public transportation to City Hall is available through Golden Gate Transit, Line 22 or 23. Para-transit is available by calling Whistlestop Wheels at (415) 454-0964.To allow individuals
with environmental illness or multiple chemical sensitivity to attend the meeting/hearing, individuals are requested to refrain from wearing scented products.
ATTACHMENT 7
CORRESPONDENCE RECEIVED TO DATE
From:Kim Hahn
To:Paul Jensen
Cc:Victoria Sievers; Bob Berg; Alex Stadtner; Lindsay Lara
Subject:Recommendations for Urgency Ordinance in San Rafael: Dec. 3 Council Meeting
Date:Monday, November 26, 2018 12:04:48 PM
Attachments:Recommendations for an Urgency Ordinance in San Rafael.docx
Excerpt from Petaluma 2018 Small Cell Ordinance.docx
EHTrust cell tower studies.docx
mdsafetech.docx
Saferemr list.docx
Montgomery Co..docx
Small.Cell.Wireless.Equiptment.Policy.Approved.10.22.2018.BURLINGTON.MA.pdf
Permit Application Requirements.docx
Fiber Optic Cable vs. 5G Wireless Executive Summary.pptx
To: Paul Jensen, Community Development Director, San Rafael
From: Kim Hahn, Vicki Sievers, Bob Berg, Alex Stadtner
Re: Recommendations for Urgency Ordinance in San Rafael
Date: 11/26/18
Dear Paul:
Please find below the condensed form of the documents we brought to you on Monday,
November 19, for our meeting about the possible installation of 5G antennas in San Rafael.
You have requested that we send these as an email so that you may attach them to your Staff
Report for the December 3 City Council meeting.
You will see that the page we first called "List of Asks for San Rafael Urgency Ordinance"
has been updated and renamed "Recommendations for an Urgency Ordinance in San Rafael"
with inserts of the other four documents we gave you on 11/19/18:
• Excerpt from Petaluma 2018 Small Cell Ordinance
• Strong Opposition to 5G Halts Small Cell Bill in Montgomery County Maryland & Verizon
Drops Applications in Burlington
• Town of Burlington Policy; Applications for Small Cell Wireless Installations
• Permit Application Requirements
Note that we have also added some links and videos to help you understand the complexities
of our approach.
Thank you, Paul, for continuing to work with us to provide a clear path to the most restrictive
and protective Urgency Ordinance possible. We appreciate all the work that you and your
staff have put forth to date.
Best regards,
Kim Hahn
Vicki Sievers
Bob Berg
Alex Stadtner
P.S. Because of recent email communication mishap between Caron Parker and Vicki Sievers,
could you please let me know that you have received this email? Thank you in advance, Paul.
Sent from my hard-wired computer (with Ethernet cable and DSL modem), andairport card disabled.
11/26/18 Recommendations for an Urgency Ordinance in San Rafael, CA
• Height of small cell antenna tower:
• The case for vertical offsets of 150’:
According to Paul McGavin, whose website http://scientists4wiredtech.com/blog/ is a recognized
resource for electromagnetic radiation and 5G, a nine-year survey in Sebastopol, CA, of a low-cost
residence occupied by 40+ people shows serious health effects from antennas that are radiating into the
second story of residences. It is imperative that antennas be installed at a height of at least 150’ to
protect all residents. Cellular antennas of any size or shape need to have sufficient vertical and
horizontal setbacks from where people live, sleep and heal. Installing antennas less than 150’
off the ground may threaten safety, privacy, and property values.
• San Rafael could require that antennas be installed on applicant-owned and maintained poles
at least 150 feet higher than the highest roof within a 3000-foot radius of any wireless
telecommunication facility.
• San Rafael could require that the applicant install only equipment that has no chance of
outputting peak RF-EMR exposures any higher than 150 µW/m² anywhere people live
(metered as peak RF-EMR exposures outside on the ground or outside of the highest windows
of any building within a 3000- foot radius of any antenna).
• Distances:
• Distance from residence: 500' Small Cell Antenna setback from residential homes
(See attachment: “Excerpt from Petaluma 2018 Small Cell Ordinance,” p. 6 below)
• Distance between (“Separation of”) small cell antennas: 3000'
(View the YouTube video of Verizon CEO Lowell McAdam and Field Engineer
Jason L. as they demonstrate the 3000’ radius of a single 5G antenna:
https://www.youtube.com/watch?time_continue=4&v=FwAsr1pC13Q)
Clearly, any resident who is standing between two antennas positioned 3000’ apart will be
in the path of both. Documentation of safe human distance from any single antenna has been
shown to be 1500’. Therefore, any positioning of antennas closer than 3000’ apart will radiate
at double the FCC standards in any location between the two antennas.
(See the attachments:
• EHTrust cell tower studies (“Compilation of Research Studies on Cell Tower Radiation and
Health”)
• mdsafetech.docx
• Saferemr list.docx)
• Monitoring:
Require provider to supply 24/7 monitoring platform to City of San Rafael at provider's cost. The city
has the right to turn off antennas that exceed the stated compliance levels.
• ADA Compliance:
5G Small Cell Antennas must be ADA (a federal law) compliant, enabling removal of any 5G Small
Cell Antennas found to be causing harm to residents with EHS (Visit:
http://www.electrosmogprevention.org/smart-meter-resources-links/ada-accommodations-
info/recognition-of-the-electromagnetic-sensitivity-as-a-disability-under-the-ada/ )
• Zoning:
Add definitions and table titled "Implementing Zoning Ordinance" (IZO) from the Petaluma ordinance
(See attachment “Excerpt from Petaluma 2018 Small Cell Ordinance,” pgs. 6 and 7)
• Location within City Zones:
Limit 5G Small Cell Antennas to Industrial Zones - include definitions and examples for each
zone.
• Approach to a Protective Permit Process:
Revise existing permit process to include key points from the attached below:
“Montgomery Co.” (“Strong Opposition to 5G Halts Small Cell Bill in Montgomery County Maryland
& Verizon Drops Applications in Burlington”).
• Application and Re-certification Process:
View the finished product from Burlington, MA, and adopt resourceful ways to include procedures and
language that will protect the safety, aesthetics, and property values of San Rafael residents.
(See attachment:
“Small.Cell.Wireless.Equiptment.Policy.Approved.10.22.2018.BURLINGTON.MA.pdf”)
• Permit Application Requirements
Incorporate points from the attachment “Permit Application Requirements” to clarify and solidify
San Rafael’s permit application procedure for small cell installations.
(See attachment “Permit Application Requirements.”)
• Fiber Optic as a Sound Alternative to 5G
View the Fiber Optic PowerPoint, Condensed Version, to study the superior benefits of Fiber Optic
Cable and to learn how San Rafael can access the fiber backbone already installed by Zayo for
LucasFilm.
(See “Fiber Optic Cable vs. 5G Wireless Executive Summary.pptx”)
1
Excerpt from Petaluma 2018 Small Cell Ordinance
Section 2. Sections 14.44.020 and 14.44.090 of Chapter 14.44 -
Telecommunications Facility and Antenna Requirement of the PMC
are hereby amended to read as follows:
14.44.020 Definitions.
S. “Telecommunication facility” means a facility that transmits
and/or receives electromagnetic signals. It includes antennas,
microwave dishes, horns, and other types of equipment for the
transmission or receipt of such signals, telecommunication towers o r
similar structures supporting said equipment, equipment buildings,
parking area, and other accessory development.
1. “Telecommunications facility - exempt” includes but is not
limited to, the following unless located within a recognized Historic
District:
a. A single ground or building mounted receive-only radio or
television antenna including any mast, for the sole use of the
tenant occupying the residential parcel on which the radio or
television antenna is located; with an antenna height not
exceeding twenty-five feet;
b. A ground or building mounted citizens band radio antenna
including any mast, if the height (post and antenna) does not
exceed thirty-five feet;
c. A ground, building, or tower mounted antenna operated by
a federally licensed amateur radio operator as part of the
Amateur Radio Service, if the height (post and antenna) does
not exceed thirty-five feet
d. A ground or building mounted receive-only radio or
television satellite dish antenna, which does not exceed thirty-
six inches in diameter, for the sole use of the resident
occupying a residential parcel on which the satellite dish is
located; provided the height of said dish does not exceed the
height of the ridgeline of the primary structure on said parcel.
2
e. All citizens band radio antenna or antenna operated by a
federally licensed amateur radio operator as part of the
Amateur Radio Service which existed at the time of the
adoption of this chapter (September 1996).
f. Mobile services providing public information coverage of
news events of a temporary nature.
g. Hand-held devices such as cell phones, business-band
mobile radios, walkie-talkies, cordless telephones, garage
door openers and similar devices as determined by the
planning director.
h. City government owned and operated receive and/or
transmit telemetry station antennas for supervisory control
and data acquisition (SCADA) systems for water, flood alert,
traffic control devices and signals, storm water, pump stations
and/or irrigation systems, with heights not exceeding thirty-five
feet.
2. “Telecommunications facilities - major” are all telecommunication
facilities not clearly set forth and included in the definition of
exempt, minor or mini facilities.
3.“Telecommunications facility - mini” is an attached wireless
communication facility consisting, but not limited to, the following
unless located on a structure recognized as a historic landmark:
a. A single ground or building mounted receive-only radio or
television antenna including any mast, for the sole use of the
tenant occupying the parcel on which the radio or television
antenna is located; with an antenna height not exceeding
fifty feet;
b. A ground or building mounted citizens band radio antenna
including any mast, if the height (tower, support structure, post
and antenna) does not exceed seventy feet;
c. A ground, building, or tower mounted antenna operated by
a federally licensed amateur radio operator as part of the
Amateur Radio Service, if the height (post and antenna) does
not exceed seventy feet.
3
d. A ground or building mounted receive-only radio or
television satellite dish antenna, with diameter exceeding
thirty-six inches but less than eight feet in diameter, for the sole
use of the resident occupying a residential parcel on which
the satellite dish is located; provided the height of said dish
does not exceed the height of the ridgeline of the primary
structure on said parcel.
e. Exempt telecommunication facility located within a
recognized historic district.
f. City owned and operated antennae used for emergency
response services, public utilities, operations and maintenance
if the height does not exceed seventy feet.
If a facility does not meet these criteria then it is considered either
an “exempt”, “minor” or “major” telecommunication facility.
4. “Telecommunications facility - minor” means any of the
following:
a. Antennae which meet the definition of “mini” with the
exception of the height limit.
b. Telecommunications facilities less than thirty-five feet in
height and that adhere to Section 14.44.090 of Chapter 14.44
of the Petaluma Municipal Code.
c. A single ground or building mounted whip (omni) antenna
without a reflector, less than four inches in diameter whose
total height does not exceed thirty-five feet; including any
mast to which it is attached, located on commercial and/or
industrial zoned property.
d. A ground or building mounted panel antenna whose height
is equal to or less than four feet and whose area is not more
than four hundred eighty square inches in the aggregate (e.g.,
one-foot diameter parabola or two feet by one and one-half
foot panel) as viewed from any one point, located on
commercial or industrial zoned property. The equipment
cabinets shall be designed, placed and screened to be
4
unobtrusive and effectively unnoticeable.
e. More than three antennas, satellite dishes (greater than
three feet in diameter), panel antennas, or combination
thereof, are proposed to be placed on the commercial or
industrial parcel, including existing facilities.
f. Building mounted antennas which, in the opinion of the
planning director, are unobtrusive or undetectable by way of
design and/or placement on the building, regardless of
number, when located on commercial or industrial zoned
property.
g. Telecommunications facilities less than fifty feet in height, in
compliance with the applicable sections of this chapter,
located on a parcel owned by the city of Petaluma and
utilized for public and/or quasi -public uses where it is found by
the planning director to be compatible with the existing city
uses of the property.
h. Telecommunication facilities, including multiple antennas, in
compliance with the applicable sections of this chapter,
located on an industrial parcel and utilized for the sole use
and purpose of a research and development tenant of said
parcel, where it is found by the planning director to be
aesthetically compatible with the existing and surrounding
structures.
i. Telecommunication facilities located on a structure
recognized as a historic landmark.
If a facility does not meet these criteria then it is considered a
“major” telecommunication facility.
5. “Telecommunication facility - co-located” means a
telecommunication facility comprised of a single
telecommunication tower or building supporting one or m ore
antennas, dishes, or similar devices owned or used by more than
one public or private entity.
6. “Telecommunication facility - commercial” means a
telecommunication facility that is operated primarily for a business
5
purpose or purposes.
7. “Telecommunication facility - multiple user” means a
telecommunication facility comprised of multiple
telecommunication towers or buildings supporting one or more
antennas owned or used by more than one public or private entity,
excluding research and development industries with antennas to
serve internal uses only.
8. “Telecommunication facility - noncommercial” means a
telecommunication facility that is operated solely for a non-business
purpose.
9. “Telecommunications facility - small cell” means a
telecommunications facility that is pole mounted to existing public
utility infrastructure.
14.44.095 Small Cell facilities - Basic Requirements.
Small Cell facilities as defined in Section 14.44.020 of this chapter
may be installed, erected, maintained and/or operated in any
commercial or industrial zoning district where such antennas are
permitted under this title, upon the issuance of a minor conditional
use permit, so long as all the following conditions are met:
A. The Small Cell antenna must connect to an already existing
utility pole that can support its weight.
B. All new wires needed to service the Small Cell must be
installed within the width of the existing utility pole so as to not
exceed the diameter and height of the existing utility pole.
C. All ground-mounted equipment not installed inside the pole
must be undergrounded, flush to the ground, within three (3)
feet of the utility pole.
D. Each Small Cell must be at least 1,500 feet away from the
nearest Small Cell facility.
E. Aside from the transmitter/antenna itself, no additional
6
equipment may be visible.
F. Each Small Cell must be at least 500 feet away from any
residence.
G. An encroachment permit must be obtained for any work in
the public right-of-way.
Section 3. Section 7.090 of the IZO, Ordinance 2300 N.C.S., is
amended to read as follows:
7.090 - Telecommunications Facilities.
The following requirements apply to Telecommunications Facilities as
defined in the City’s Telecommunications Ordinance, Petaluma
Municipal Code Chapter 14.44.
A. Definitions. The types of facilities regulated by this section are
defined in the City’s Telecommunications Ordinance, Petaluma
Municipal Code Chapter 14.44.
B. Telecommunications facilities are allowed only as described in
Table 7.090(B).
Table 7.090B
Zoning District
Type of Telecommunications Facility
Exempt Mini Minor Major Small
OSP A A CUP CUP CUP
AG A A - - -
RR A A - - -
R1 A A
-
- -
7
R2 A A - - -
R3 A A - - -
R4 A A - - -
R5 A A - - -
C1 A A CUP CUP CUP
C2 A A CUP CUP CUP
8
MU1
A A A CU
P CUP CU
P
MU1
B A A CU
P CUP CU
P
MU1
C A A - - -
MU2 A A CU
P CUP CU
P
BP A A CU
P CUP CU
P
I A A CU
P CUP CU
P
CF A A CU
P CUP CU
P
C. Where a telecommunications facility is permitted by Table 7.090B,
the approval(s) required prior to the commencement of the
operation of a Telecommunications Facility are as prescribed in
subsections 1-4 below.
1. Exempt Facility. An Exempt facility is an Accessory Use and
no special permit is required, except when an Exempt facility is
located in a Historic District. An Exempt facility located in a
8
Historic District or on the site of a designated landmark is
considered a Mini Facility subject to administrative Historic and
Cultural Preservation approval as prescribed in Section 15.050.
2. Mini Facility. A Mini Facility is an Accessory Use subject to
administrative site plan and architectural review approval as
prescribed by Section 24.010. When a Mini facility is located in
a Historic District or on the site of a designated landmark, the
following special permits are required:
a. A Minor conditional use permit as prescribed in Section
24.030; and
b. Administrative Historic and Cultural Review as prescribed in
15.030.
3. Minor Facility. A Minor facility requires approval of a minor
conditional use permit as prescribed in Section 24.030 and
administrative site plan and architectural review approval as
prescribed in Section 24.010. When a Minor facility is located in
a Historic District or on the site of a designated landmark,
approval of a major conditional use permit as prescribed in
Section 24.030 and Historic and Cultural Preservation
Committee approval as prescribed In Section 15.030 are
required.
4. Major Facility. A major facility requires approval of a major
conditional use permit as prescribed in Section 24.030 and
Planning Commission approval as prescribed in Section 24.101.
5. Small Facility. A Small Cell Facility requires approval of a
minor conditional use permit as prescribed in Section 24.030
and administrative site plan and architectural review approval
as prescribed in Section 24.010. An encroachment permit for
public right-of-way work is also required. The right-of-way shall
be subject to the designation of the zone adjacent to the
right-of-way, for purposes of the Table 7.090(B) designation.
D. A Telecommunication facility shall comply with the development
standards (Tables 4.6 – 4.13) for the zoning district in which the
facility is located, the City’s Telecommunications Ordinance, and all
other applicable City requirements.
From EHTrust.org
https://ehtrust.org/science/cell-towers-and-cell-antennae/compilation-of-research-studies-on-cell-tower-radiation-and-health/
Compilation of Research Studies on Cell Tower
Radiation and Health
What Does the Published Research Say About Cell Tower Radiation and Health
American Academy of Pediatrics Website
“Electromagnetic Fields: A Hazard to Your Health?” on Cell Tower Radiation
“In recent years, concern has increased about exposure to radio frequency electromagnetic radiation
emitted from cell phones and phone station antennae. An Egyptian study confirmed concerns that living
nearby mobile phone base stations increased the risk for developing:
• Headaches
• Memory problems
• Dizziness
• Depression
• Sleep problems
Short-term exposure to these fields in experimental studies have not always shown negative effects, but
this does not rule out cumulative damage from these fields, so larger studies over longer periods are
needed to help understand who is at risk. In large studies, an association has been observed between
symptoms and exposure to these fields in the everyday environment.”
–American Academy of Pediatrics
Compilation of Research Studies on Cell Tower Radiation and Health
Zothansiama, et al. “Impact of radiofrequency radiation on DNA damage and antioxidants in peripheral
blood lymphocytes of humans residing in the vicinity of mobile phone base stations.” Electromagnetic
Biology and Medicine 36.3 (2017): 295-305.
• This study evaluated effects in the human blood of individuals living near mobile phone base
stations (within 80 meters) compared with healthy controls (over 300 meters). The study found
higher radiofrequency radiation exposures and statistically significant differences in the blood of
people living closer to the cellular antennas. The group living closer to the antennas had for
example, statistically significant higher frequency of micronuclei and a rise in lipid peroxidation
in their blood. These changes are considered biomarkers predictive of cancer.
Neurobehavioral effects among inhabitants around mobile phone base stations Abdel-Rassoul et al,
Neurotoxicology, 2007
• This study found that living nearby mobile phone base stations (cell antennas) increased the risk
for neuropsychiatric problems such as headaches, memory problems, dizziness, tremors,
depression, sleep problems and some changes in the performance of neurobehavioral functions.
Biological Effects from Exposure to Electromagnetic Radiation Emitted by Cell Tower Base Stations and
Other Antenna Arrays, Levitt & Lai, Environmental Reviews, 2010
• This review of 100 studies found approximately 80% showed biological effects near towers.
“Both anecdotal reports and some epidemiology studies have found headaches, skin rashes, sleep
disturbances, depression, decreased libido, increased rates of suicide, concentration problems,
dizziness, memory changes, increased risk of cancer, tremors, and other neurophysiological
effects in populations near base stations.”
Mortality by neoplasia and cellular telephone base stations. Dode et al. (Brazil), Science of the Total
Environment, Volume 409, Issue 19, 1 September 2011, Pages 3649–3665
• This 10 year study on cell phone antennas by the Municipal Health Department in Belo Horizonte
and several universities in Brazil found a clearly elevated relative risk of cancer mortality at
residential distances of 500 meters or less from cell phone transmission towers. Shortly after this
study was published, the city prosecutor sued several cell phone companies and requested that
almost half of the cities antennas be removed. Many antennas were dismantled.
Epidemiological Evidence for a Health Risk from Mobile Phone Base Stations Khurana, Hardell et al.,
International Journal of Occupational Environmental Health, Vol 16(3):263-267, 2010
• A review of 10 epidemiological studies that assessed for negative health effects of mobile phone
base stations (4 studies were from Germany, and 1 each from Austria, Egypt, France, Israel,
Poland, Spain) found that seven showed altered neurobehavioral effects near cell tower and three
showed increased cancer incidence. The review also found that eight of the 10 studies reported
increased prevalence of adverse neurobehavioral symptoms or cancer in populations living at
distances < 500 meters from base stations. Lower cognitive performance was found
in individuals living ≤ 10 meters from base stations. None of the studies reported exposure above
accepted international guidelines, suggesting that current guidelines may be inadequate in
protecting the health of human populations.
Health effects of living near mobile phone base transceiver station (BTS) antennae: a report from
Isfahan, Iran. Shahbazi-Gahrouei et al, Electromagnetic Biology Medicine, 2013.
• This cross-sectional study found the symptoms of nausea, headache, dizziness, irritability,
discomfort, nervousness, depression, sleep disturbance, memory loss and lowering of libido were
statistically increased in people living closer than 300 m from cell antennas as compared to those
living farther away. The study concludes that “antennas should not be sited closer than 300 m to
people to minimize exposure.”
Long-term exposure to microwave radiation provokes cancer growth: evidences from radars and mobile
communication systems. Yakymenko (2011) Exp Oncology, 33(2):62-70.
• Even a year of operation of a powerful base transmitting station for mobile communication
reportedly resulted in a dramatic increase of cancer incidence among population living nearby.
Association of Exposure to Radio-Frequency Electromagnetic Field Radiation (RF-EMFR) Generated by
Mobile Phone Base Stations (MPBS)with Glycated Hemoglobin (HbA1c) and Risk of Type 2 Diabetes
Mellitus , Sultan Ayoub Meo et al, International Journal of Environmental Research and Public Health,
2015
• Elementary school students who were exposed to high RF-EMFR generated by MPBS had a
significantly higher risk of type 2 diabetes mellitus relative to their counterparts who were
exposed to lower RF-EMFR.
How does long term exposure to base stations and mobile phones affect human hormone profiles?
Eskander EF et al, (2011), Clin Biochem
• RFR exposures significantly impacted ACTH, cortisol, thyroid hormones, prolactin for females,
and testosterone levels for males.
Investigation on the health of people living near mobile telephone relay stations: Incidence according to
distance and sex Santini et al, 2002 , Pathol Bio
• People living near mobile phone masts reported more symptoms of headache, sleep disturbance,
discomfort, irritability, depression, memory loss and concentration problems the closer they lived
to the installation. Study authors recommend that the minimal distance of people from cellular
phone base stations should not be < 300 m.
Navarro EA, Segura J, Portoles M, Gomez-Perretta C, The Microwave Syndrome: A preliminary Study.
2003 (Spain) Electromagnetic Biology and Medicine, Volume 22, Issue 2, (2003): 161 – 169
• Statistically significant positive exposure-response associations between RFR intensity and
fatigue, irritability, headaches, nausea, loss of appetite, sleeping disorder, depressive tendency,
feeling of discomfort, difficulty in concentration, loss of memory, visual disorder, dizziness and
cardiovascular problems.
Two Important Animal Studies on Radiofrequency Radiation
These studies indicate that government limits are non protective. Government limits are based on the
assumption that radiofrequency radiation is only harmful at thermal levels. However, the cancers
developed in animals in these studies at radiation levels that were non thermal.
Belpoggi et al. 2018, “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 base station environmental emission” Environmental Research Journal
• Researchers with the renowned Ramazzini Institute (RI) in Italy performed a large-scale lifetime
study of lab animals exposed to environmental levels (comparable to allowable limits from cell
towers) of RFR radiation and found the rats developed increased cancers- schwannoma of the
heart in male rats. This study confirms the $25 million US National Toxicology Program study
which used much higher levels of cell phone radiofrequency (RF) radiation, but also reported
finding the same unusual cancers as the Ramazzini- schwannoma of the heart in male rats. In
addition, the RI study of cell tower radiation also found increases in malignant brain (glial)
tumors in female rats and precancerous conditions including Schwann cells hyperplasia in both
male and female rats.
• “Our findings of cancerous tumors in rats exposed to environmental levels of RF are consistent
with and reinforce the results of the US NTP studies on cell phone radiation, as both reported
increases in the same types of tumors of the brain and heart in Sprague-Dawley rats. Together,
these studies provide sufficient evidence to call for the International Agency for Research on
Cancer (IARC) to re-evaluate and re-classify their conclusions regarding the carcinogenic
potential of RFR in humans,” said Fiorella Belpoggi PhD, study author and RI Director of
Research.
• The Ramazzini study exposed 2448 Sprague-Dawley rats from prenatal life until their natural
death to “environmental” cell tower radiation for 19 hours per day (1.8 GHz GSM radiofrequency
radiation (RFR) of 5, 25 and 50 V/m). RI exposures mimicked base station emissions like those
from cell tower antennas, and exposure levels were far less than those used in the NTP studies of
cell phone radiation.
• Watch Press Conference
Wyde, Michael, et al. “National Toxicology Program Carcinogenesis Studies of Cell Phone
Radiofrequency Radiation in Hsd: Sprague Dawley® SD rats (Whole Body Exposure).Statement on
conclusions of the peer review meeting by NIEHS, released after external peer review meeting and the
DNA damage presentation.
• This 25 million dollar study is the most complex study completed by the NTP and the world’s
largest rodent study on radiofrequency radiation exposure to date which found long term exposure
at non thermal levels associated with brain cancer and schwannomas of the heart in male rats. In
addition damage to heart was found in all exposure levels. The full report is expected to be
released in Fall 2018.
More Important Studies on Cell Tower Radiation
Cindy L. Russell, 5 G wireless telecommunications expansion: Public health and environmental
implications, Environmental Research, 2018, ISSN 0013-9351
• Radiofrequency radiation (RF) is increasingly being recognized as a new form of environmental
pollution. This article reviews relevant electromagnetic frequencies, exposure standards and
current scientific literature on the health implications of 2G, 3G, 4G and 5G.
• Effects can also be non-linear. Because this is the first generation to have cradle-to-grave lifespan
exposure to this level of man-made microwave (RF EMR) radiofrequencies, it will be years or
decades before the true health consequences are known. Precaution in the roll out of this new
technology is strongly indicated.
Noa Betzalel, Paul Ben Ishai, Yuri Feldman, The human skin as a sub-THz receiver – Does 5G pose a
danger to it or not?, Environmental Research, Volume 163, 2018, Pages 208-216, ISSN 0013-9351,
• Researchers have developed a unique simulation tool of human skin, taking into account the skin
multi-layer structure together with the helical segment of the sweat duct embedded in it. They
found that the presence of the sweat duct led to a high specific absorption rate (SAR) of the skin
in extremely high frequency band that will be used in 5G. “One must consider the implications of
human immersion in the electromagnetic noise, caused by devices working at the very same
frequencies as those, to which the sweat duct (as a helical antenna) is most attuned. We are
raising a warning flag against the unrestricted use of sub-THz technologies for communication,
before the possible consequences for public health are explored.”
Mobile phone infrastructure regulation in Europe: Scientific challenges and human rights protection
Claudia Roda, Susan Perry, Environmental Science & Policy, Volume 37, March 2014, Pages 204-214.
• This article was published in Environmental Science & Policy by human rights experts. It argues
that cell tower placement is a human rights issue for children.
• “We argue that (1) because protection of children is a high threshold norm in Human Right law
and (2) the binding language of the Convention on the Rights of the Child obliges States Parties
to provide a higher standard of protection for children than adults, any widespread or systematic
form of environmental pollution that poses a long-term threat to a child’s rights to life,
development or health may constitute an international human rights violation.
• In particular we have explained how the dearth of legislation to regulate the installation of base
stations (cell towers) in close proximity to children’s facilities and schools clearly constitutes a
human rights concern according to the language of the Convention on the Rights of the Child, a
treaty that has been ratified by all European States.
SAFETY ZONE DETERMINATION FOR WIRELESS CELLULAR TOWER Nyakyi et al, Tanzania
(2013)
• This research looked at the radiation that cell towers emit and states a safety zone is needed
around the towers to ensure safe sleeping areas. The authors state that “respective authorities
should ensure that people reside far from the tower by 120m or more depending on the power
transmitted to avoid severe health effect.”
A cross-sectional case control study on genetic damage in individuals residing in the vicinity of a mobile
phone base station. Ghandi et al, 2014 (India):
• This cross-sectional case control study on genetic damage in individuals living near cell towers
found genetic damage parameters of DNA were significantly elevated. The authors state,” The
genetic damage evident in the participants of this study needs to be addressed against future
disease-risk, which in addition to neurodegenerative disorders, may lead to cancer.”
Human disease resulting from exposure to electromagnetic fields, Carpenter, D. O. Reviews on
Environmental Health, Volume 28, Issue 4, Pages 159172.
• This review summarizes the evidence stating that excessive exposure to magnetic fields from
power lines and other sources of electric current increases the risk of development of some
cancers and neurodegenerative diseases, and that excessive exposure to RF radiation increases
risk of cancer, male infertility, and neurobehavioral abnormalities.
Signifikanter Rückgang klinischer Symptome nach Senderabbau – eine Interventionsstudie. (English-
Significant Decrease of Clinical Symptoms after Mobile Phone Base Station Removal – An Intervention
Study) Tetsuharu Shinjyo and Akemi Shinjyo, 2014 Umwelt-Medizin-Gesellschaft, 27(4), S. 294-301.
• Japanese study Showed Statistically Significant Adverse Health Effects from electromagnetic
radiation from mobile phone base stations. Residents of a condominium building that had cell
tower antennas on the rooftop were examined before and after cell tower antennas were removed.
In 1998, 800MHz cell antennas were installed, then later in 2008 a second set of antennas (2GHz)
were installed. Medical exams and interviews were conducted before and after the antennas were
removed in 2009 on 107 residents of the building who had no prior knowledge about possible.
These results lead researchers to question the construction of mobile phone base stations on top of
buildings such as condominiums or houses.
Effect of GSTM1 and GSTT1 Polymorphisms on Genetic Damage in Humans Populations Exposed to
Radiation From Mobile Towers. Gulati S, Yadav A, Kumar N, Kanupriya, Aggarwal NK, Kumar R,
Gupta R., Arch Environ Contam Toxicol. 2015 Aug 5. [Epub ahead of print]
• In our study, 116 persons exposed to radiation from mobile towers and 106 control subjects were
genotyped for polymorphisms in the GSTM1 and GSTT1 genes by multiplex polymerase chain
reaction method. DNA damage in peripheral blood lymphocytes was determined using alkaline
comet assay in terms of tail moment (TM) value and micronucleus assay in buccal cells (BMN).
Our results indicated that TM value and BMN frequency were higher in an exposed population
compared with a control group and the difference is significant. In our study, we found that
different health symptoms, such as depression, memory status, insomnia, and hair loss, were
significantly associated with exposure to EMR. Damaging effects of nonionizing radiation result
from the generation of reactive oxygen species (ROS) and subsequent radical formation and from
direct damage to cellular macromolecules including DNA.
Subjective symptoms, sleeping problems, and cognitive performance in subjects living near mobile
phone base stations, Hutter HP et al, (May 2006), Occup Environ Med. 2006 May;63(5):307‐13
• Found a significant relationship between some cognitive symptoms and measured power density
in 365 subjects; highest for headaches. Perceptual speed increased, while accuracy decreased
insignificantly with increasing exposure levels.
Oberfeld, A.E. Navarro, M. Portoles, C. Maestu, C. Gomez-Perretta, The microwave syndrome: further
aspects of a Spanish study,
• A health survey was carried out in La Ñora, Murcia, Spain, in the vicinity of two GSM 900/1800
MHz cellular phone base stations. The adjusted (sex, age, distance) logistic regression model
showed statistically significant positive exposure-response associations between the E-field and
the following variables: fatigue, irritability, headaches, nausea, loss of appetite, sleeping disorder,
depressive tendency, feeling of discomfort, difficulty in concentration, loss of memory, visual
disorder, dizziness and cardiovascular problems.
Bortkiewicz et al, 2004 (Poland), Subjective symptoms reported by people living in the vicinity of
cellular phone base stations: review,Med Pr.2004;55(4):345-51.
• Residents close to mobile phone masts reported: more incidences of circulatory problems, sleep
disturbances, irritability, depression, blurred vision and concentration difficulties the nearer they
lived to the mast.
• The performed studies showed the relationship between the incidence of individual symptoms,
the level of exposure, and the distance between a residential area and a base station.
Wolf R and Wolf D, Increased Incidence of Cancer Near a Cell-phone Transmitter Station, International
Journal of Cancer Prevention, (Israel) VOLUME 1, NUMBER 2, APRIL 2004
• A significant higher rate of cancer (300% increase) among all residents living within 300m radius
of a mobile phone mast for between three and seven years was detected.
• 900% cancer increase among women alone
• In the area of exposure (area A) eight cases of different kinds of cancer were diagnosed in a
period of only one year. This rate of cancers was compared both with the rate of 31 cases per
10,000 per year in the general population and the 2/1222 rate recorded in the nearby clinic (area
B). The study indicates an association between increased incidence of cancer and living in
proximity to a cell-phone transmitter station.
Changes of Neurochemically Important Transmitters under the influence of modulated RF fields – A
Long Term Study under Real Life Conditions(Germany), Bucher and Eger, 2011
• German study showing elevated levels of stress hormones (adrenaline, noradrenaline), and
lowered dopamine and PEA levels in urine in area residents during 1st 6 months of cell tower
installation. Even after 1.5 years, the levels did not return to normal.
The Influence of Being Physically Near to a Cell Phone Transmission Mast on the Incidence of Cancer
(Umwelt·Medizin·Gesellschaft 17,4 2004) Eger et al, 2004 (Germany)
• 200% increase in the incidence of malignant tumors was found after five years’ exposure in
people living within 400m radius of a mobile phone mast. The proportion of newly developing
cancer cases is significantly higher among patients who live within 400 meters of a cell phone
transmitter. Early age of cancer diagnosis.
Microwave electromagnetic fields act by activating voltage-gated calcium channels: why the current
international safety standards do not predict biological hazard. Martin L. Pall. Recent Res. Devel. Mol.
Cell Biol. 7(2014).
• “It can be seen from the above that 10 different well-documented microwave EMF effects can be
easily explained as being a consequence of EMF VGCC activation: oxidative stress, elevated
single and double strand breaks in DNA, therapeutic responses to such EMFs, breakdown of the
blood-brain barrier, cancer, melatonin loss, sleep dysfunction, male infertility and female
infertility.”
Pall ML. 2015. Microwave frequency electromagnetic fields (EMFs) produce widespread
neuropsychiatric effects including depression. J. Chem. Neuroanat. 2015 Aug 20.
• Non-thermal microwave/lower frequency electromagnetic fields (EMFs) act via voltage-gated
calcium channel (VGCC) activation.
• Two U.S. government reports from the 1970s to 1980s provide evidence for many
neuropsychiatric effects of non-thermal microwave EMFs, based on occupational exposure
studies. 18 more recent epidemiological studies, provide substantial evidence that microwave
EMFs from cell/mobile phone base stations, excessive cell/mobile phone usage and from wireless
smart meters can each produce similar patterns of neuropsychiatric effects, with several of these
studies showing clear dose–response relationships.
• Lesser evidence from 6 additional studies suggests that short wave, radio station, occupational
and digital TV antenna exposures may produce similar neuropsychiatric effects. Among the more
commonly reported changes are sleep disturbance/insomnia, headache, depression/depressive
symptoms, fatigue/tiredness, dysesthesia, concentration/attention dysfunction, memory changes,
dizziness, irritability, loss of appetite/body weight, restlessness/anxiety, nausea, skin
burning/tingling/dermographism and EEG changes. In summary, then, the mechanism of action
of microwave EMFs, the role of the VGCCs in the brain, the impact of non-thermal EMFs on the
brain, extensive epidemiological studies performed over the past 50 years, and five criteria testing
for causality, all collectively show that various non-thermal microwave EMF exposures produce
diverse neuropsychiatric effects.
From mdsafetech.org
https://mdsafetech.org/cell-tower-health-effects/
Scientific Literature
The number of cell towers worldwide has had exponential growth since the 1990’s. In the U.S. large
cell tower numbers have risen from about 900 in 1985 to over 308,334 cell sites in service in 2016.
This is according to the Cellular Telecommunications Industry Association (CTIA), established in
1984 just before the rollout of cell towers. The telecommunications industry places cell towers in
cities but also leases rooftops on schools, churches, businesses and apartment buildings with antennas
for one or more carriers. This co-location can create clusters of antennas with different frequencies in
close proximity to where people live and work. These base stations emit a continuous stream of
microwave radiofrequencies exposing residents to whole body exposures. More cell towers are being
proposed throughout the US now on a statewide and federal level to accommodate proposed 5G high
frequency telecommunications with cell towers about every 250 meters (~750 feet). See also 5G
Telecommunications Science or 5G Mobile Communications or Cell Towers and City
Ordinances or New Legislation Cell Towers
The rise in cell towers has been accompanied by scientific observations and reports of both human
health and environmental decline in many countries.
Adverse Health Symptoms Near Cell Towers
The majority of published studies in different countries have shown a relationship between distance
from base stations and a variety of health complaints. They have found that the closer to the towers
people live there is an increase incidence of reported symptoms including those below. These are the
same symptoms that people who have electrosensitivity experience.
• headaches
• insomnia
• dizziness
• irritability
• fatigue
• heart palpitations
• nausea
• loss of appetite
• feeling of discomfort
• loss of libido
• poor concentration
• memory loss
• neuropsychiatric problems such as depression.
Blood Cell Abnormalities Found
In a recent study from India by Zothansiama et al (2017), researchers examined abnormalities in
blood samples in people living at different distances from cell towers. They identified a significant
increase blood cell damage in those living within 80 meters of a cell tower versus those living greater
than 300 meters from a cell tower. They found 1) A significant increase in micronuclei, which are
small remnants of DNA nuclear material appearing within blood cells and a sensitive indicator of
genotoxicity and chromosomal abnormalities 2) An increase in lipid peroxidation indicating free
radical formation and cell membrane damage 3) A reduction in levels of internally produced
antioxidant capacity (glutathione, catalase and superoxide dismutase).
The author concluded “The present study demonstrated that staying near the mobile base
stations and continuous use of mobile phones damage the DNA, and it may have an adverse
effect in the long run. The persistence of DNA unrepaired damage leads to genomic instability
which may lead to several health disorders including the induction of cancer.” As more base
stations are deployed with higher density and with ubiquitous wireless devices at home it will be
difficult to find control groups that have not been significantly exposed. The Antenna Search website
allows people to identify registered cell towers in their area.
Blake Levitt, an award-winning medical and science journalist and former New York
Times contributor is author of Cell Towers-Wireless Convenience? or Environmental
Hazard? (2000) The book lists different chapters from different authors who contributed to a “Cell
Towers Forum: State of the Science/State of the law” environmental conference December 2, 2000.
Her book has valuable information on FCC safety guidelines, legal aspects of the
Telecommunications Act, cell tower sitings and case law.
Conclusions From Research
A brief review of some of the research listed is below. Wildlife is even effected by cell towers.
Santini, in 2002 French study, reported an increase in fatigue at 300 meters from the cell towers and
remaining symptoms at 200 meters. A follow up study by Santini in 2003 revealed that older subjects
reported more symptoms and were more sensitive. Duration of exposure of 1 to 5 years did not have
an effect on frequency of symptoms but after 5 years there was a significant increase in irritability
reported.
Navarro in 2003 indicates much lower levels of exposure cause adverse health symptoms. The
Navarro (2003) study on cell towers and “Microwave Syndrome” in Spain found that in those living
near cell towers symptoms occurred at low power. He looked at distance from the towers and
electromagnetic field exposures and concluded, ” Based on the data of this study the advice would be
to strive for levels not higher than 0.02 V/m for the sum total, which is equal to a power density of
0.0001 µW/cm² or 1 µW/m², which is the indoor exposure value for GSM base stations proposed on
empirical evidence by the Public Health Office of the Government of Salzburg in 2002.”
Wolf and Wolf , in 2004 investigated the rates of cancer versus distance from cell towers in small
towns in Israel. He found the rate of cancer incidence was 129 cases per 10,000 persons per year in
those living within 350 meters of a cell tower versus a rate of 16-31/10,000 in those living greater
than 350 meters from the cell tower. Eger et al. in 2004 also found an increase in the development of
new cancer cases within a 10 year period if residents lived within 400 meters of a cell tower. Their
results revealed that within 5 years of operation of a transmitting station the relative risk of cancer
development tripled in residents near the cell towers compared to residents outside the area.
Hutter 2006– In an Austrian study, Hutter in 2006 looked at cognitive performance, insomnia and
well being in relation to power density of radiofrequency radiation versus reported symptoms in those
in rural vs urban settings for more than a year. His study showed an increase in health effects with
higher radiofrequency exposure. Important conclusions were that these complaints were independent
of patients concern over health effects and that at levels well below current safety standards.
Shinjyo and Shinjyo in 2014- In an independent cell tower study from Japan, published in 2014,
researchers Shinjyo and Shinjyo looked at health effects of residents living in a condominium
complex from 1998-2009, noting health symptoms before placement of cell towers, during cell tower
functioning and after removal of different antennas on the rooftops. They found a significant
development of symptoms with placement of the cell towers and a significant reduction in symptoms
after removal. The most frequent symptoms were fatigue, loss of motivation, headaches, eye pain,
deteriorated eyesight, sleep disturbances, dizziness, jitteriness, rapid heat rate, muscle aches and nasal
bleeding.
Published Literature
• Impact of radiofrequency radiation on DNA damage and antioxidants in peripheral
blood lymphocytes of humans residing in the vicinity of mobile phone base stations.
(2017) Zothansiama et al. Electromagn Biol Med. 2017 Aug 4:1-11.
https://www.ncbi.nlm.nih.gov/pubmed/28777669
• Survey of People Living at the Vicinity of Cellualr Base Transmitting Stations in an
Urban and Rural Locality. (2016) Sivani Saravanamuttu. International Journal of Current
Research react-text: 55 8(3):28186-28193. March
https://www.researchgate.net/publication/301677652_SURVEY_OF_PEOPLE_LIVING_AT
_THE_VICINITY_OF_CELLULAR_BASE_TRANSMITTING_STATIONS_IN_AN_URB
AN_AND_A_RURAL_LOCALITY
• Effect of electromagnetic radiations from mobile phone base stations on general health
and salivary function. (2016) Singh,K et al. J Int Soc Prev Community Dent. 2016 Jan-
Feb;6(1):54-9. http://www.ncbi.nlm.nih.gov/pubmed/?term=PMC4784065
• Health effects of living near mobile phone base transceiver station (BTS) antennae: a
report from Isfahan, Iran.(2014) Shahbazi-Gahrouei D et al. Electromagn Biol Med. 2014
Sep;33(3):206-10 http://www.ncbi.nlm.nih.gov/pubmed/23781985
• Significant Decrease of Clinical Symptoms after Mobile Phone Base Station Removal –
An Intervention Study. (2014). Tetsuharu Shinjyo and Akemi Shinjyo.
http://www.slt.co/Downloads/News/1086/Shinjyo%202014%20Significant%20Decrease%20
of%20Clinical%20Symptoms%20after%20Mobile%20Phone%20Base%20Station%20Remo
val%20.pdf
• Health Implications of Electromagnetic Fields, Mechanisms of Action, and Research
Needs. (2014) Sarika Singh and Neeru Kapoor Advances in Biology. Volume 2014 (2014).
https://www.hindawi.com/archive/2014/198609/
• Subjective symptoms related to GSM radiation from mobile phone base stations: a
cross-sectional study. (2013) Enrique A Navarro. BMJ Open 2013;3:e003836.
http://bmjopen.bmj.com/content/3/12/e003836.full
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municipality, Minas Gerais state, Brazil. (2011) A Dode et al. Science of The Total
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• Wireless communication fields and non-specific symptoms of ill health: a literature
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50 http://www.ncbi.nlm.nih.gov/pubmed/21638215
• Report on Cell Tower Radiation. Submitted to Secretary, DOT, Delhi, India.(2010)
Kumar G. Electrical engineering Department. IIT Bombay, Powai,
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ear_to_a_Cell_Phone_Transmission_Mast_on_the_Incidence_of_Cancer
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From Saferemr.org
https://www.saferemr.com/2015/04/cell-tower-health-effects.html
Impact of radiofrequency radiation on DNA damage and antioxidants in peripheral blood
lymphocytes of humans residing in the vicinity of mobile phone base stations
Zothansiama, Zosangzuali M, Lalramdinpuii M, Jagetia GC. Impact of radiofrequency radiation on
DNA damage and antioxidants in peripheral blood lymphocytes of humans residing in the vicinity
of mobile phone base stations. Electromagn Biol Med. 2017 Aug 4:1-11. doi:
10.1080/15368378.2017.1350584.
Abstract
Radiofrequency radiations (RFRs) emitted by mobile phone base stations have raised concerns
on its adverse impact on humans residing in the vicinity of mobile phone base stations. Therefore,
the present study was envisaged to evaluate the effect of RFR on the DNA damage and
antioxidant status in cultured human peripheral blood lymphocytes (HPBLs) of individuals residing
in the vicinity of mobile phone base stations and comparing it with healthy controls.
The study groups matched for various demographic data including age, gender, dietary pattern,
smoking habit, alcohol consumption, duration of mobile phone use and average daily mobile
phone use.
The RF power density of the exposed individuals was significantly higher (p < 0.0001) when
compared to the control group. The HPBLs were cultured and the DNA damage was assessed by
cytokinesis blocked micronucleus (MN) assay in the binucleate lymphocytes. The analyses of
data from the exposed group (n = 40), residing within a perimeter of 80 meters of mobile base
stations, showed significantly (p < 0.0001) higher frequency of micronuclei (MN) when compared
to the control group, residing 300 meters away from the mobile base station/s.
The analysis of various antioxidants in the plasma of exposed individuals revealed a significant
attrition in glutathione (GSH) concentration (p < 0.01), activities of catalase (CAT) (p < 0.001) and
superoxide dismutase (SOD) (p < 0.001) and rise in lipid peroxidation (LOO) when compared to
controls. Multiple linear regression analyses revealed a significant association among reduced
GSH concentration (p < 0.05), CAT (p < 0.001) and SOD (p < 0.001) activities and elevated MN
frequency (p < 0.001) and LOO (p < 0.001) with increasing RF power density.
https://www.ncbi.nlm.nih.gov/pubmed/28777669
My note
All of the recorded RFR power density values in this study were well below the Federal
Communication Commission’s maximum permissible exposure limits in the U.S. for the general
population. These limits are are 6,000 mW/m2 [milliwatts per square meter] for 900 MHz and
10,000 mW/m2 for 1800 MHz radiofrequency radiation. In contrast, the highest recorded value in
this study was 7.52 mW/m2 of RFR. The “exposed individuals” who resided within 80 meters of a
cell antenna received an average of 5.00 mW/m2 of RFR in their bedrooms.
Excerpts
RFR may change the fidelity of DNA as the increased incidence of cancer has been reported
among those residing near mobile phone base stations (Abdel-Rassonl et al., 2007; Bortkiewicz
et al., 2004; Cherry, 2000; Eger et al., 2004; Hardell et al., 1999; Hutter et al., 2006; Wolf and
Wolf, 2004). RFR emitted from mobile base stations is also reported to increase the DNA strand
breaks in lymphocytes of mobile phone users and individuals residing in the vicinity of a mobile
base station/s (Gandhi and Anita, 2005; Gandhi et al., 2014). Exposure of human fibroblasts and
rat granulosa cells to RFR (1800 MHz, SAR 1.2 or 2 W/kg) has been reported to induce DNA
single- and double-strands breaks (Diem et al., 2005). Irreversible DNA damage was also
reported in cultured human lens epithelial cells exposed to microwave generated by mobile
phones (Sun et al., 2006). The adverse health effects of RFR are still debatable as many studies
indicated above have found a positive correlation between the DNA damage and RFR exposure;
however, several studies reported no significant effect of RFR on DNA strand breaks and
micronuclei formation in different study systems (Li et al., 2001; Tice et al., 2002; McNamee et al.,
2003;Maes et al., 2006). The potential genotoxicity of RFR emitted by mobile phone base stations
can be determined by micronucleus (MN) assay, which is an effective tool to evaluate the
genotoxic or clastogenic effects of physical and chemical agents. This technique has also been
used to quantify the frequencies of radiation-induced MN in human peripheral blood lymphocytes
(HPBLs) (Fenech and Morley, 1985; Jagetia and Venkatesha, 2005; Prosser et al., 1988; Yildirim
et al., 2010).
Six mobile phone base stations, operating in the frequency range of 900 MHz (N = 2)
and1800MHz (N = 4), erected in the thickly populated areas of Aizawl city were selected for the
present study… The power output of all the base stations is 20 W, with their primary beam
emitting radiation at an angle of 20°. Power density measurements (using HF-60105V4,
Germany) were carried out in the bedroom of each participant where they spent most of the time
and hence have the longest constant level of electromagnetic field exposure. Power density
measurement was carried out three times (morning, midd ay and evening), and the average was
calculated for each residence around each base station. The main purpose of the measurement
of power density was to ensure that RFR emission from each site did not exceed the safe public
limits and to determine any difference in power density between selected households that were
close to (within 80 m) and far (>300 m) from the mobile phone base stations. The safety limits for
public exposure from mobile phone base stations are 0.45 W/m 2 for 900 MHz and 0.92 W/m2 for
1800 MHz frequency as per Department of Telecommunications, Ministry of Communications,
Government of India, New Delhi guidelines (DoT, 2012).
… some residences are located horizontally with the top of the towers from which RFR are
emitted, making it possible to get an exposure at a short distance of 1–20 m, despite being
erected on the rooftop or in the ground. A minimum of two individuals were sampled from each
household and at least five individuals were sampled around each mobile base station.
Individuals sampled around each base station were matched for their age and gender (Table 1).
The exposed group consisted of 40 healthy individuals who fulfilled the inclusion criteria of being
above 18 years of age and residing in the vicinity of mobile phone base s tations (within 80 m
radius). The control group comprised of 40 healthy individuals matched for age and gender who
had been living at least 300 m away from any mobile phone base stations…. Sampling was also
done only from those residences who did not use m icrowave oven for cooking, Wifi devices and
any other major source of electromagnetic field as they are known to cause adverse effects
(Atasoy et al., 2013; Avendaño et al., 2012).
The groups matched for most of the demographic data such as age, gender, dietary pattern,
smoking habit, alcohol consumption, mobile phone usage, duration of mobile phone use and
average daily mobile phone use (Table 2). A highly significant variation (p < 0.0001) was
observed for the distance of household from the base station (40.10 ± 3.02 vs. 403.17 ± 7.98 in
m) between exposed and control groups.
The RF power density of the exposed group (2.80–7.52 mW/m2; average 5.002 ± 0.182 mW/ m2)
was significantly higher (p < 0.0001) when compared to the control group (0.014 –0.065 mW/m2;
average 0.035 ± 0.002 mW/m2). The highest power density was recorded at a distance of 1–20 m
(6.44 ± 0.31 mW/m2), which is significantly higher (p < 0.0001) than those at a distance of 21–40
m (4.79 ± 0.33), 41–60 m (4.48 ± 0.22) and 61–80 m (4.61 ± 0.10).
The highest measured power density was 7.52mW/m2. Most of the measured values close to
base stations (Table 1) are higher than that of the safe limits recommended by Bioinitiative
Report 2012 (0.5mW/m2), Salzburg resolution 2000 (1 mW/m2) and EU (STOA) 2001
(0.1 mW/m2). However, all the recorded values were well below the current ICNIRP safe level
(4700 mW/m2) and the current Indian Standard (450 mW/m2).
The exact mechanism of action of RFR in micronuclei induction and reduced antioxidant status is
not apparent. The possible putative mechanism of generation of DNA damage may be the
production of endogenous free radicals due to continuous exposure. RFR has been reported to
produce different free radicals earlier (Avci et al., 2009; Burlaka et al., 2013; Barcal et al., 2014;
Kazemi et al., 2015). Cells possess a number of compensatory mechanisms to deal with ROS
and its effects. Among these are the induction of antioxidant proteins such as GSH, SOD and
CAT. Enzymatic antioxidant systems function by direct or sequential removal of ROS, thereby
terminating their activities. An imbalance between the oxidative forces and antioxidant defense
systems causes oxidative injury, which has been implicated in various diseases, such as cancer,
neurological disorders, atherosclerosis, diabetes, liver cirrhosis, asthma, hypertension and
ischemia (Andreadis et al., 2003; Comhair et al., 2005; Dhalla et al., 2000; Finkel and Holbrook,
2000; Kasparova et al., 2005; Sayre et al., 2001; Sohal et al., 2002). Because of the significant
decrease in endogenous antioxidants and increased LOO among the exposed group, the extra
burden of free radicals is unlikely to get neutralized, and these surplus ROS may react with
important cellular macromolecules including DNA forming either DNA adducts or stand breaks,
which may be later expressed as micronuclei once the cell decides to divide. The decline in the
antioxidant status may be also due to the suppressed activity of Nrf2 transcription factor which is
involved in maintaining the antioxidant status in the cells.
The present study has reported that [radiofrequency radiation] increased the frequency of
[micronuclei] and [lipid peroxidation] and reduced [glutathione] contents, [catalase] and
[superoxide dismutase] activities in the plasma of the exposed individuals. The induction of
[micronuclei] may be due to the increase in free-radical production. The present study
demonstrated that staying near the mobile base stations and continuous use of mobile phones
damage the DNA, and it may have an adverse effect in the long run. The persistence of DNA
unrepaired damage leads to genomic instability which may lead to several health disorders
including the induction of cancer.
--
Biological effects from exposure to electromagnetic radiation emitted by
cell tower base stations and other antenna arrays
Levitt BB, Lai H. Biological effects from exposure to electromagnetic radiation emitted by cell
tower base stations and other antenna arrays. Environmental Reviews.18: 369 –395 (2010)
doi:10.1139 /A10-018.
Open Access Paper:
http://www.nrcresearchpress.com/doi/pdfplus/10.1139/A10-018?src=recsys
Abstract
The siting of cellular phone base stations and other cellular infrastructure such as roof-mounted
antenna arrays, especially in residential neighborhoods, is a contentious subject in land -use
regulation. Local resistance from nearby residents and landowners is often based on fears of
adverse health effects despite reassurances from telecommunications service providers that
international exposure standards will be followed.
Both anecdotal reports and some epidemiology studies have found headaches, skin rashes,
sleep disturbances, depression, decreased libido, increased rates of suicide, concentration
problems, dizziness, memory changes, increased risk of cancer, tremors, and other
neurophysiological effects in populations near base stations.
The objective of this paper is to review the existing studies of people living or working near
cellular infrastructure and other pertinent studies that could apply to long -term, low-level
radiofrequency radiation (RFR) exposures. While specific epidemiological research in this area is
sparse and contradictory, and such exposures are difficult to quantify given the increasing
background levels of RFR from myriad personal consumer products, some research does exist to
warrant caution in infrastructure siting. Further epidemiology research that takes total ambient
RFR exposures into consideration is warranted.
Symptoms reported today may be classic microwave sickness, first described in 1978.
Nonionizing electromagnetic fields are among the fastest growing forms of environmental
pollution. Some extrapolations can be made from research other than epidemiology regarding
biological effects from exposures at levels far below current exposure guidelines.
Excerpts
[Note: As of July 9, 2017, www.antennasearch.com, an industry website, reports 646,000 towers
and 1.89 million cell antennas in the U.S.]
In lieu of building new cell towers, some municipalities are licensing public utility poles throughout
urban areas for Wi-Fi antennas that allow wireless Internet access. These systems can require
hundreds of antennas in close proximity to the population with some exposures at a lateral height
where second- and third-story windows face antennas. Most of these systems are categorically
excluded from regulation by the U.S. Federal Communications Commission (FCC) or oversight by
government agencies because they operate below a certain power density threshold. However,
power density is not the only factor determining biological effects from radiofrequency radiation
(RFR).
An aesthetic emphasis is often the only perceived control of a municipality, particularly in
countries like America where there is an overriding federal preemption that precludes taking the
“environmental effects” of RFR into consideration in cell tower siting as stipulated in Section 704
of The Telecommunications Act of 1996 (USFCC 1996). Citizen resistance, however, is most
often based on health concerns regarding the safety of RFR exposures to those who live near the
infrastructure. Many citizens, especially those who claim to be hypersensitive to electromagnetic
fields, state they would rather know where the antennas are and that hiding them greatly
complicates society’s ability to monitor for safety.
Industry representatives try to reassure communities that facilities are many orders of magnitude
below what is allowed for exposure by standards-setting boards and studies bear that out
(Cooper et al. 2006; Henderson and Bangay 2006; Bornkessel et al. 2007). These include
standards by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) used
throughout Europe, Canada, and elsewhere (ICNIRP 1998). The standards currently adopted by
the U.S. FCC, which uses a two-tiered system of recommendations put out by the National
Council on Radiation Protection (NCRP) for civilian exposures (referred to as uncontrolled
environments), and the International Electricians and Electronics Engineers (IEEE) for
professional exposures (referred to as controlled environments) (U.S. FCC 1997). The U.S. may
eventually adopt standards closer to ICNIRP. The current U.S. standards are more protective
than ICNIRP’s in some frequency ranges so any harmonization toward the ICNIRP standards will
make the U.S. limits more lenient.
All of the standards currently in place are based on RFRs ability t o heat tissue, called thermal
effects. A longstanding criticism, going back to the 1950s (Levitt 1995), is that such acute heating
effects do not take potentially more subtle non-thermal effects into consideration. And based on
the number of citizens who have tried to stop cell towers from being installed in their
neighborhoods, laypeople in many countries do not find adherence to existing standards valid in
addressing health concerns. Therefore, infrastructure siting does not have the confidence of the
public (Levitt 1998).
The intensity of RFR decreases rapidly with the distance from the emitting source; therefore,
exposure to RFR from transmission towers is often of low intensity depending on one’s proximity.
But intensity is not the only factor. Living near a facility will involve long-duration exposures,
sometimes for years, at many hours per day. People working at home or the infirm can
experience low-level 24 h exposures. Nighttimes alone will create 8 hour continuous exposures.
The current standards for both ICNIRP, IEEE and the NCRP (adopted by the U.S. FCC) are for
whole-body exposures averaged over a short duration (minutes) and are based on results from
short-term exposure studies, not for long-term, low-level exposures such as those experienced by
people living or working near transmitting facilities. For such populations, these can be
involuntary exposures, unlike cell phones where user choice is involved.
The U.S. FCC has issued guidelines for both power density and SARs. For power density, the
U.S. guidelines are between 0.2–1.0 mW/cm2….
At 100–200 ft (about 30–60 meters) from a cell phone base station, a person can be exposed to a
power density of 0.001 mW/cm2 (i.e., 1.0 μW/cm2)….
For the purposes of this paper, we will define low-intensity exposure to RFR of power density of
0.001 mW/cm2
Many biological effects have been documented at very low intensities comparable to what the
population experiences within 200 to 500 ft (∼60–150 m) of a cell tower, including effects that
occurred in studies of cell cultures and animals after exposures to low-intensity RFR. Effects
reported include: genetic, growth, and reproductive; increases in permeability of the bl ood–brain
barrier; behavioral; molecular, cellular, and metabolic; and increases in cancer risk….
Ten years ago, there were only about a dozen studies reporting such low-intensity effects;
currently, there are more than 60. This body of work cannot be ignored. These are important
findings with implications for anyone living or working near a transmitting facility. However, again,
most of the studies in the list are on short-term (minutes to hours) exposure to low-intensity RFR.
Long-term exposure studies are sparse. In addition, we do not know if all of these reported effects
occur in humans exposed to low-intensity RFR, or whether the reported effects are health
hazards. Biological effects do not automatically mean adverse health effects, plus many biologi cal
effects are reversible. However, it is clear that low-intensity RFR is not biologically inert. Clearly,
more needs to be learned before a presumption of safety can continue to be made regarding
placement of antenna arrays near the population, as is the case today.
… The previously mentioned studies show that RFR can produce effects at much lower
intensities after test animals are repeatedly exposed. This may have implications for people
exposed to RFR from transmission towers for long periods of time.
… The conclusion from this body of work is that effects of long-term exposure can be quite
different from those of short-term exposure.
Since most studies with RFR are short-term exposure studies, it is not valid to use their results to
set guidelines for long-term exposures, such as in populations living or working near cell phone
base stations.
Numerous biological effects do occur after short-term exposures to low-intensity RFR but
potential hazardous health effects from such exposures on humans are still not well established,
despite increasing evidence as demonstrated throughout this paper. Unfortunately, not enough is
known about biological effects from long-term exposures, especially as the effects of long-term
exposure can be quite different from those of short-term exposure. It is the long-term, low-
intensity exposures that are most common today and increasing significantly from myriad wireless
products and services.
People are reporting symptoms near cell towers and in proximity to other RFR-generating
sources including consumer products such as wireless computer routers and Wi-Fi systems that
appear to be classic “microwave sickness syndrome,” also known as “radiofrequency radiation
sickness.” First identified in the 1950s by Soviet medic al researchers, symptoms included
headache, fatigue, ocular dysfunction, dizziness, and sleep disorders. In Soviet medicine, clinical
manifestations include dermographism, tumors, blood changes, reproductive and cardiovascular
abnormalities, depression, irritability, and memory impairment, among others. The Soviet
researchers noted that the syndrome is reversible in early stages but is considered lethal over
time (Tolgskaya et al. 1973).
The present U.S. guidelines for RFR exposure are not up to date. The most recent IEEE and
NCRP guidelines used by the U.S. FCC have not taken many pertinent recent studies into
consideration because, they argue, the results of many of those studies have not been replicated
and thus are not valid for standards setting. That is a specious argument. It implies that someone
tried to replicate certain works but failed to do so, indicating the studies in question are unreliable.
However, in most cases, no one has tried to exactly replicate the works at all.... In addition,
effects of long-term exposure, modulation, and other propagation characteristics are not
considered. Therefore, the current guidelines are questionable in protecting the public from
possible harmful effects of RFR exposure and the U.S. FCC should take steps to update their
regulations by taking all recent research into consideration without waiting for replication that may
never come because of the scarcity of research funding. The ICNIRP standards are more lenient
in key exposures to the population than current U.S. FCC regulations. The U.S. standards should
not be “harmonized” toward more lenient allowances. The ICNIRP should become more
protective instead. All standards should be biologically based, not dosimetry base d as is the case
today.
Exposure of the general population to RFR from wireless communication devices and
transmission towers should be kept to a minimum and should follow the “As Low As Reasonably
Achievable” (ALARA) principle. Some scientists, organizations, and local governments
recommend very low exposure levels — so low, in fact, that many wireless industries claim they
cannot function without many more antennas in a given area. However, a denser infrastructure
may be impossible to attain because of citizen unwillingness to live in proximity to so many
antennas. In general, the lowest regulatory standards currently in place aim to accomplish a
maximum exposure of 0.02 V/m, equal to a power density of 0.0001 μW/cm2, which is in line with
Salzburg, Austria’s indoor exposure value for GSM cell base stations. Other precautionary target
levels aim for an outdoor cumulative exposure of 0.1 μW/cm2 for pulsed RF exposures where
they affect the general population and an indoor exposure as low as 0.01 μW/cm2 (Sage and
Carpenter 2009). In 2007, The BioInitiative Report, A rationale for a biologically based public
exposure standard for electromagnetic fields (ELF and RF), also made this recommendation,
based on the precautionary principle (Bioinitiative Report 2007).
Citizens and municipalities often ask for firm setbacks from towers to guarantee safety. There are
many variables involved with safer tower siting — such as how many providers are co-located, at
what frequencies they operate, the tower’s height, surrounding topographical characteristics, the
presence of metal objects, and others. Hard and fast setbacks are difficult to recommend in all
circumstances. Deployment of base stations should be kept as efficient as possible to avoid
exposure of the public to unnecessary high levels of RFR. As a general guideline, cell base
stations should not be located less than 1500 ft (∼500 m) from the population, and at a height of
about 150 ft (∼50 m). Several of the papers previously cited indicate that symptoms lessen at that
distance, despite the many variables involved. However, with new technologies now being added
to cell towers such as Wi-Max networks, which add significantly more power density to the
environment, setback recommendations can be a very unpredictable reassurance at best. New
technology should be developed to reduce the energy required for effective wireless
communication.
In addition, regular RFR monitoring of base stations should be considered….
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Resources
Best Best & Krieger. Letter to EMF Safety Network: Local Authority Over Wireless Facilities in
Public Rights-of-Way. Apr 24, 2018. http://bit.ly/BBKletter04242018
Campanelli & Associates, P.C. Cell tower lawyers. http://www.anticelltowerlawyers.com/
Center for Municipal Solutions. Excellent resource re: regulation of cell towers & wireless
facilities. http://bit.ly/1GX4mPY
Karish G, Barket E (Best Best & Krieger). Issues of Local Control and Wireless Telecommunication
Facilities. Presented at League of California Cities City Attorneys’ Spring Conference, May 3, 2018.
22 pp. http://bit.ly/wirelesscontrol
League of Minnesota Cities. Cell Towers, Small Cell Technologies & Distributed Antenna
Systems. Nov 4, 2016. http://bit.ly/2k5PQz0
San Francisco Neighborhood Antenna-Free Union (SNAFU)
http://www.antennafreeunion.org/neighborhoodaction.htm
News
RCR Wireless News. Appeals Court rules that California cities have the right to block small cell
based on aesthetic concerns. Sep 16, 2016. http://bit.ly/2cE9GhN
Rouhan Sharma. A Towering Problem. Infrastructure Today, Feb 2016. http://bit.ly/1QcHSxO
Special Correspondent. "Radiation levels of mobile towers should be cut." The Hindu. Feb 7,
2016. http://bit.ly/1Pt5Sck
"Stating that the current level of radiation (electromagnetic field, EMF) emitted by mobile phone towers
was still high, Girish Kumar, Professor, Department of Electrical Engineering, IIT Bombay, on Saturday,
urged the Centre to reduce the radiation level further.
The mobile tower radiation had been reduced [in India] from 45,000 milliwatt per square metre to 450
milliwatt a few years ago. It should be reduced to 10 milliwatt, he said ...."
Note: The FCC allows the American general public to be exposed to up to 5,800 milliwatts per square
meter.
Lydia Beyoud. Not All ‘Small Cells' Created Equal, Say Municipalities in Wireless Siting Rules
Suit. Bloomberg BNA. Apr 27, 2015.
http://www.bna.com/not-small-cells-n17179925917/
"... the number of small cell and DAS installations is expected to grow exponentially in the next few years.
As many as 37 million small cell installations could be in place by 2017, and up to 16 million distributed
antenna system (DAS) nodes could be deployed by 2018, according to the FCC."
Joel Moskowitz. Press Release: Cell Tower Radiation Affects Wildlife: Dept. of Interior Attacks
FCC. Mar 2014.
http://www.saferemr.com/2014/03/dept-of-interior-attacks-fcc-regarding.html
Ianthe Jeanne Dugan and Ryan Knutson. Cellphone Boom Spurs Antenna-Safety Worries. Wall
Street Journal, Oct 2, 2014.
http://www.wsj.com/articles/cellphone-boom-spurs-antenna-safety-worries-1412293055
Strong Opposition to 5G Halts Small Cell Bill in
Montgomery County Maryland & Verizon Drops
Applications in Burlington
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Update from the East Coast on 5G
Strong Opposition to 5G Halts Small Cell Bill in Mo ntgomery County Maryland
Verizon Withdraws Small Cell Applications in Burlington, Massachusetts after Small
Cell Recertification Requirements Established
(Montgomery County MD) Strong opposition finally halted a proposed a zoning amendment that would
enable 5G small cells in close proximity to homes in Montgomery County Maryland neighborhoods.
Citizens, medical experts and community organizations worked in coalition raising concerns about health,
environment, property values and aesthetics after the measure was put forward. They testified in public
hearings and objected most to the provision that citizen’s rights to a public notice and hearing would have
been removed if a utility pole were in the front of their homes
The Montgomery County 5G Small Cell zoning amendment was being pushed by the Montgomery Cou nty
Executive Ike Leggett (who notable had previously states that cell towers were bad for the environment),
County Council President Riemer and Councilwoman Nancy Floreen.
In the final Council deliberations Montgomery County Councilman Hucker brought for ward an amendment
to the regulation that would give public notice and hearings to homeowners with a utility pole in front of
their homes. The County staff told him this was not allowed under law and that the county would be
preempted. However Councilman Hucker the presented documentation that in fact the county had the
authority to regulate both the approval procedure and the setbacks for small wireless facilities to be placed
in its ROW and in residential zones.
The Council was set to vote on the complete amendment at the next meeting and to discuss another
proposed amendment that would ban small cells near schools. However, the Council President then
removed the vote and discussion from the next Council meeting and issued a statement that, “Unfortunately
amendments were introduced that essentially sought to obstruct deployment of wireless infrastructure in the
future.”
Thus, the passing of the amendment that gave citizens notice and a hearing tai nted the otherwise industry
friendly bill and was no longer acceptable to industry as it would have forced them to give public notice
and hearings.
The Washington Post article, “Montgomery County lawmakers cancel vote on ‘small cell’ bill to regulate
5G network” headlines that “The council couldn’t agree on how close to allow antennas and equipment to
be installed near homes.”
(From Cecelia Doucette in Ashland Massachusetts) Meanwhile in Burlington, Massachusetts, Verizon
withdrew their small cell applications upon learning of newly established annual recertification requi rement
and associated fees as they did not wish to establish a precedent for recertification fees.
The Burlington, Massachusetts Small Cells Committee had proactively developed criteria in a new policy
for reviewing small cell applications which included an annual recertification of equipment installations,
with a fee assessed to the telecommunications vendor to pay for town employee time to oversee the
recertification process. The town established a website to share with the public each of the small cell
applications, letters of concern, staff comments and reports.
Burlington Cable Access Television covered the story at “Verizon Drops Small Cell Wireless Booster
Application in Face of Fees”
LEARN MORE ABOUT 5G
Get the Facts on 5g at EHT’s 20 Quick Facts About 5G to get updated on the issues.
Download a PDF of EHT Factsheet on 5G and Health. The factsheet is hyperlinked (blue text) to
research and sources. It is a great resource for policymakers. Read the research on 5G and health here.
What is the alternative? A safe wired solution is the future. Read “Re-Inventing Wires: The Future of
Landlines and Networks”.
Read also “WIRELESS SILENT SPRING” BY CINDY RUSSELL, MD. in Santa Clara Medical
Association Magazine.
Briefing by Dr. Martin Pall: “5G: Great risk for EU, U.S. and International Health! Co mpelling Evidence
for Eight Distinct Types of Great Harm Caused by Electromagnetic Field(EMF) Exposures and the
Mechanism that Causes Them”
PERMIT APPLICATION REQUIREMENTS
1) Create a new permit application specifically for telecommunications equipment. It should
include the following items on the permit application:
Name/address of installer
Name/address of equipment owner
Name/address of equipment operator
Name/address of any/all telecom corporations involved, or who will use this equipment
now or in the future
List any/all related permits from other agencies such as MTA, MGSA, CPUC, etc.
List all computer/telecommunications hardware items to be installed, including all support
equipment such as antennas, battery backup, smart meter, etc.
For each piece of hardware list the manufacturer name, model and version to be installed
list each software version to be installed.
Ask for detailed specs on both sustained, and maximum, output levels, specified in units of
both SAR and mW/m2 measured at both 100' and 500', at 6 different points around the
antenna (e.g. every 60 degrees around the antenna), and at different altitudes - ground, 5',
10', and at antenna height.
Answer question: Does hardware or software have the ability to upgrade its software
automatically? If so how? And how will the city know if this has been done?
Answer question: Does hardware or software have the ability to modify output levels? If so
how? And how will the city know if this has been done?
2) Establish additional conditions of the permit/process:
A) Each antenna/installation should be treated as a separate permit.
- Each permit will require notification to all neighbors within 3000' of the antenna.
- Each permit should be a separate line item on a city council or planning meeting agenda.
- No more than 5 permits will be considered at any single meeting.
B) Neither hardware nor software may be upgraded (automatically or otherwise) without
having to go through a full permit review, including re-notification of all neighbors within
3000', plus another planning or council agenda item.
FIBER OPTIC CABLE 5G WIRELESS
FIBER OPTIC CABLE IS A FASTER, BETTER, SAFER ALTERNATIVE THAN 5G WIRELESS
11-17-2018
VS.
WHAT ARE THE FOC BUILD-OUT OPTIONS? PART 2
•Public/Private Partnership –Competitive RFP Model,
Public Infrastructure = the Best Option
•Find a private partner that specializes in Public,
Public/Private and competitive “access network/last
mile” projects that can access the robust Marin
“dark fiber” backbone already installed by carrier
Zayo Group for Lucasfilm and other enterprises.
The access network developer/operator does the
lateral build-out to homes, and then operates it
along with additional items such as services and
support. The local government gains a revenue
center to fund other projects.
LET’S WORK TOGETHER TO
MAKE THE CITY OF SAN RAFAEL
THE BEST IT CAN BE!
THANK YOU!
From: Sidney N. Baskin
Sent: Saturday, November 24, 2018 2:45 PM
To: Gary Phillips John Gamblin
Kate Colin Maribeth Bushey
Andrew McCullough
Paul Jensen
Subject: 5G Technology
Dear County Members and Mr. Jensen,
While I understand the concern over Fifth Generation (5G) wireless services,
based on the information opposing this next generation of wireless technology,
I believe the campaign against 5G is pretty much a repeat of the opposition to
Smart Meter deployment we experienced several years ago. EMF in general is
something we live with daily, including our daily exposure from the Sun and I
agree we should all be aware of over exposure to it. Whether 5G or any other
source of EMF is a risk to public health should always be a consideration,
weighing the benefits against risks. When considering cell phone technology
and exposure to EMF, unfortunately, the closest source of exposure to EMF is
from the cell phone's transmission we hold to our ear. Cell phone bi-directional
transmission exposes us on a daily basis regardless of the frequency our
current devices we may be utilizing. We live in a world full of unavoidable EMF
exposure and we need to see more conclusive evidence and agreement from
the scientific community before condemning future generations of
communication. There is no doubt that EMF has an effect on all life on this
planet, however the public deserves an honest unbiased evaluation of EMF
from all current and future sources of exposure to it. There is much factual
information available on EMF exposure and I suggest reading it before
opposing or supporting new technological services, 5G being one of them. At
this point, I find much of the arguments for and against 5G not validated from
reputable sources at this time and we should not take a position opposing or
supporting deployment until valuable conclusive data is available. I would
encourage the San Rafael City Council to further thoroughly evaluate the
proposed migration to the next generation of cell service from both sides of
this argument before making their decision on this proposed advancement in
wireless communications.
Sincerely,
Sidney Baskin, San Rafael
-----Original Message-----
From: Lisa Moskow
Sent: Friday, November 23, 2018 12:11 AM
To: Gary Phillips John Gamblin
Kate Colin
Maribeth Bushey Andrew McCullough
Jim Schutz
Paul Jensen
Subject: Dec. 3rd meeting
Thank you for paying attention to our request to deny the application of 5G technology in San
Rafael.
Many of us have spent quite a bit of time researching technologies that are untested for safety
for human health. We would like to affirm our right to decide for ourselves when and if we
are ready to take on this kind of risk. State
“mandate" or no state “mandate”, we feel that we deserve to make these decisions on the city
and/or county level. It looks like several Marin cities have already passed no-5G ordinances
and adding San Rafael to this group will give us more power to act in the name of our own
health concerns.
I do plan to come to the next meeting on Dec. 5th.
Thank you, Sangita Moskow
From: Alex Stadtner
Sent: Tuesday, November 27, 2018 9:16 AM
To: Gary Phillips John Gamblin
Kate Colin Maribeth Bushey
Andrew McCullough
Paul Jensen
Subject: 5G rollout
Dear Mayor, Council Members and Mr Jensen,
Thank you for your careful consideration of an updated ordinance regarding small cell antennas
(“5G”). While these antennas may be called “small,” they are mighty in their ability to rapidly
increase the amount of non-ionizing radio frequency radiation (RFR) in our community. In addition to
the adverse impacts to aesthetics and property values these devices may bring, there is real concern
over the physiological impacts RFR has on the human body. For a compilation of peer-reviewed and
published journal articles on adverse health impacts of RFR, I direct you
here: http://www.bioinitiative.org/research-summaries/
I want internet that is FAST, RELIABLE, SECURE and SAFE! Who doesn’t?
Fortunately there is a viable alternative to 5G that wins in every category above. Please explore a
public-private-partnership to bring fiberoptic cable to our homes and offices in San Rafael. The
backbone of the infrastructure is already present in Marin, and we could really lead the way in terms
of internet speed, reliability and security if you grab this opportunity. I believe the big telephone
carriers will be extending fiberoptic as they rollout any new antennas and it’s a perfect opportunity
to piggyback on those efforts.
This is a unique opportunity being somewhat forced upon you by bigger industry forces. But it’s an
opportunity never-the-less.
Don’t be rolled over by the FCC and sacrifice our town’s aesthetics, property values and community
health. Instead seize this opportunity to make San Rafael a leader in high-speed internet!
Thank you for your consideration,
Alex
_____________
Alex Stadtner
President, MS, CIEC, BBEC, LEED, WELL
Healthy Building Science
Industrial Hygiene & Environmental Testing
Connect With Us! Blog | Facebook | Twitter
Certified B Corp
CA General B Lic: 1046058
Reply Time Warning: I am frequently days behind on email. If it’s urgent please call the
office.
From: Arthur D. Saftlas
Sent: Tuesday, November 27, 2018 8:56 AM
To: Gary Phillips John Gamblin
Kate Colin Maribeth Bushey
Andrew McCullough
Paul Jensen
Subject: We have to say NO to the FCC.
"Dear Council Members and Mr. Jensen,
We have to say NO to the FCC.
We are very concerned about serious adverse health and environmental
impacts caused by the microwave radiation emitted from "small cell"
antennas. Please prevent the installation of these dangerous antennas in
the City of San Rafael, especially in residential neighborhoods.
Sincerely,
Arthur Saftlas
VERIZON AND ATT 5G NEW CELL TOWERS ARE PLANNED 15-50 FEET FROM HOMES!
EMERGENCY ACTION NEEDED!
There will be one of these in front of every home, 200 feet apart, coming to your
neighborhood. The refrigerator size thing next to the woman is part of this "small cell
tower". Wake yourself up now and get involved to stop this scourge. Contact your County
Supervisors and City Council to loudly campaign against this.
The internet is full of information about the dangers of this 5G rollout. 4G is causing cancers, 5G
is 100X’s more powerful. Do your homework, but be aware the FCC is staffed with Big Tech, you
cannot trust anything they say. They have passed laws that say Health and Safety cannot be
considered about the installation of these towers.
THIS ALONE SHOULD TELL YOU ENOUGH!
From the National Institutes of Health. “The industry and FCC are pushing fast at both the state
and federal level to put forth legislation to take away home rule in our local municipalities so the
industry can install toxic 5G infrastructure before any more of the NTP study findings can be
reported out. The FCC and industry are not concerned with public health.”
https://hibr.nih.gov/workgroups/electromagnetic-fields-emf-and-electromagnetic-radiation-emr
Gov. Jerry Brown vetoed Senate Bill 649, which would have made it easier to install these
microwave radiation antennas. The industry is fast coming up with new laws to fast track these
terrible things. In spite of laws our City Councils here in Marin are deciding against some
installations, but not all.
Laws that are unjust must be disregarded; they can be nullified in court. Demand City Councils
say NO, and support them saying NO to this attack on everyone’s and especially your children’s
health and safety.
http://www.cellphonetaskforce.org/5g-litigation/
https://emfscientist.org/
https://ehtrust.org/science/top-experimental-epidemiological-studies/
My flyer to awaken you to 5G. I teach awakening to truths. Visit my website, 2b-one.com
For Immediate Release
October 31, 2018
County Joins Court Action on 5G Technology
Marin now among coalition of public agencies against FCC ruling for deployment
San Rafael, CA – The County of Marin is filing an action in the U.S. Court
of Appeals to challenge federal deployment of fifth-generation cellular
wireless service, widely known as 5G.
The Marin County Board of Supervisors reported out of a closed-session
meeting October 30 that it would file the action against the Federal
Communications Commission (FCC) and its September 26 order to
accelerate the buildout and installation of 5G technology. The Town of
Fairfax is the only other Marin County municipality to file such an action.
County Counsel reported that the County will join a coalition of public
entities represented by Spiegel & McDiarmid, LLP, that will appeal the FCC
order. In formal comments filed with the FCC last July, Spiegel &
McDiarmid argued that the wireless industry wants to transform the FCC
into “a regulator of state and local governments rather than a regulator of
communications service providers.” Now that the FCC has adopted the
industry-favorable rules, Spiegel & McDiarmid’s coalition will take those
arguments to court.
The County is taking the legal step to protest the federal government’s
seizing of local control on the deployment of 5G and how implementation
costs can be recovered. While local governments have always been
preempted from regulating based on radiofrequency (RF) radiation
concerns, local governments always have been able to regulate
neighborhood aesthetics and other safety matters. The new FCC ruling
handcuffs traditional areas of local regulation with new time limits and
constraints.
According to the FCC ruling, which is taking effect in January 2019,
cellular service providers will have access to local infrastructure at cost
rather than at fair-market-value. In addition, the FCC order shortens the
“shot clocks” and wireless permitting timelines, forcing local entities to act
on applications for deployments on existing structures within 60 days. On
new structures, municipalities would have 90 days to approve or deny
applications.
-more-
Contact:
Brian Washington
COUNTY COUNSEL
Marin County Civic Center
3501 Civic Center Drive
Suite 275
San Rafael, CA 94903
415 473 6117 T
CRS Dial 711
County Counsel website
Brian Case
DEPUTY
COUNTY COUNSEL
Marin County Civic Center
3501 Civic Center Drive
Suite 275
San Rafael, CA 94903
415 473 6117 T
CRS Dial 711
bcase@marincounty.org
County Counsel website
PG. 2 OF 2 5G technology requires the installation of a greater number of smaller
antennas because they have shorter range. The FCC ruling limits local
governments’ ability to say “no” to the cellular industry’s demands based
on aesthetic concerns about the antennas.
In recent Board meetings, several residents have voiced opposition to the
FCC ruling. Some cited health concerns of RF radiation, but data on health
impacts of 5G is inconclusive at this stage. In addition to cell phone
services, RF is commonly used in radio and television broadcasting,
microwave point-to-point links, satellite communications, and in
noncommunication devices such as microwave ovens and industrial
heaters.
Cell service providers are planning to conduct test markets in major cities
later this year, and the first 5G cell phones are expected to be released
next year. 5G technology allows a user to download an entire movie on a
phone or mobile device within seconds. Each generation of cellular
technology is defined partly by its transformative increase in speed but
also its incompatibility with the previous generation.
Once Marin’s filing is official, a U.S. Circuit Court of Appeals will generate
a briefing schedule for the multiple agencies involved and the matter will
be fully briefed. County Counsel expects oral arguments and a final ruling
sometime in 2019.
In addition to the County and the Town of Fairfax, the cities of San Jose
and Piedmont have filed similar actions against the FCC. Nationally, more
than 20 municipalities have filed, including Los Angeles and Seattle.
###
From: ArleneF@Yahoo.com
Sent: Tuesday, November 27, 2018 9:43 AM
To: Gary Phillips John Gamblin
Kate Colin Maribeth Bushey
Andrew McCullough
Paul Jensen Subject:
5G
Dear Council Members and Mr. Jensen,
I am very concerned about serious adverse health and environmental
impacts caused by the microwave radiation emitted from "small cell"
antennas. Please prevent the installation of these dangerous antennas in
the City of San Rafael, especially in residential neighborhoods. Also, please
encourage mayors and council members of other Marin cities to do the
same.
Sincerely,
Arlene F.
From: sonya sakaske
Sent: Tuesday, November 27, 2018 10:18 AM
To: Gary Phillips John Gamblin
Kate Colin Maribeth Bushey
Andrew McCullough
Paul Jensen
Subject: real estate and small cell antennae
Hi Council Members,
I am currently work in San Rafael and am house shopping in the Ross Valley and San Rafael. If small
cell antennae are installed in your fine city, I will not purchase real estate in San Rafael for health and
aesthetic reasons.
Mill Valley took an interesting step in prohibiting these towers in residential areas, I wonder if all
Marin cities will consider following their lead?
Thank you,
Sonya Sakaske, Pharmacist
--
Sonya
From:Victoria Sievers
To:Lindsay Lara
Cc:Kim Hahn; Bob Berg; Alex Stadtner; Victoria Sievers
Subject:For Dec. 3 Council Meeting back-up
Date:Wednesday, November 21, 2018 3:58:44 PM
Attachments:A 5G Future SCCMA Article Revision with References 6_4_17 PDF.pdf
Pall-Letter-to-CalLegis-FINAL-8-7-17.pdf
Wireless Silent Spring SCCMA Corrected Final Oct 28, 2018 PDF.pdf
Why San Rafael Residents Are Concerned.docx
CONTENTS for Dec. 3 .docx
Hi Lindsay,
Thanks for your kind clarification and able assistance!
I am sending five items, 1 through 5.
(6 through 11 will be part of Paul Jensens's Staff Report. Kim Hahn will cc you with those.)
The edited video for showing at the Dec. 3 Council meeting should be finished on Friday.
Kim will also send that link to you.
CONTENTS (attached Word doc)
1) Why San Rafael Residents Are Concerned About 5G (attached Word doc)
2) Dr. Sharon Goldberg, M.D., testifying before Michigan legislators:
https://www.youtube.com/watch?v=F0NEaPTu9oI
3) Dr. Martin Pall, PhD: Letter to CA legislators (attachment)
4) Dr. Cindy Russell, M.D.: 5G Wireless Future: "Will It Give Us A Smart Nation or . . ."
(attachment)
5) Dr. Cindy Russell, M.D: "Wireless Silent Spring" (attachment)
A very Happy Thanksgiving to you and yours.
Vicki
415 454-0104
CONTENTS
1) Statement: Why San Rafael Residents Are Concerned About 5G
2) Dr. Sharon Goldberg, MD, testimony before Michigan state
legislators, 2018.
Dr. Goldberg is an Integrative Internal Medicine physician and expert in environmental illness,
including effects of electric, magnetic and radio-frequency radiation. Her background includes
fifteen years as an academic Hospital Medicine physician and medical educator responsible for
the training of medical students and resident physicians. She was Assistant Professor at New
York City’s Mount Sinai Hospital, Albert Einstein College of Medicine and the University of
Miami Miller School of Medicine. Watch the video here:
https://www.youtube.com/watch?v=gdbM7OpJQ0k
3) Dr. Martin Pall, PhD, urgent Letter to California Legislators asking
them to oppose SB 649 (later vetoed by Governor Brown), which would
have streamlined the installation of close-proximity antennas.
Martin Pall is a Professor Emeritus of Biochemistry and Basic Medical Sciences at Washington
State University. He is a widely published and cited scientist on the biological effects of
electromagnetic fields and speaks internationally on the topic. His papers are discussed on over
360,000 websites. Dr. Pall is particularly expert in how wireless radiation impacts the electrical
systems in the human body.
4) Dr. Cindy Russell, MD, “A 5G Future: Will It Give Us A Smart
Nation or Contribute To An Unhealthy One?” Published in the Santa
Clara County Medical Association Bulletin, 2017.
Cindy Russell, M.D. is Executive Director of Physicians for Safe Technology and 23 -
year Chair of the Santa Clara County Medical Association (SCCMA/MCMS)
Environmental Health Committee since 1995, and VP of Community Health for the
SCCMA/MCMS since 2010. During that time she has authored many policy resolutions
related to reducing environmental toxins at the California Medical Association House of
Delegates.
5) Dr. Cindy Russell, “Wireless Silent Spring.” Santa Clara County
Medical Association Bulletin, 2018.
Publication examining adverse effects of radio-frequency radiation on wildlife, insects,
trees and firefighters.
WHY SAN RAFAEL RESIDENTS ARE CONCERNED ABOUT 5G
1. The federal government has provided only GUIDELINES for exposure to
wireless radiation. There are NO SAFETY STANDARDS in the U.S.
Despite pleas from experts, the FCC has not completed its investigation on
health effects, nor updated 22-year-old safety limits. The FCC has, however,
stated on its website that “there is no proof that cell phone radiation is
completely safe.” But FCC guidelines are based on thermal effects, despite
thousands of studies demonstrating non-thermal effects.
2. Countries in Europe and Russia have much lower safety limits of radiation
exposure because they recognize that adverse biological effects occur at
levels considerably below U.S. guidelines. Russia has safety standards of
exposure 100 times lower than ours and Switzerland’s safety standard is
1000 times lower.
3. Experts predict that 5G wireless technology will add to the burden of
chronic disease to which 2G-3G-4G radiation has already contributed. 5G
uses millimeter waves, a much higher frequency than that used by previous
generations. 5G bears a profound list of health effects on all biological
systems, including cells, bacteria, animals and humans. Resistivity to
antibiotics is of particular concern, as is impact to the skin. The skin is the
largest organ of the body, linked to the immune system and the nervous
system. It is particularly vulnerable to the frequency of radiation in 5G.
4. Wireless radiation from antennas is also linked to increased cancer risk.
The World Health Organization classifies wireless radiation as a “possible
human carcinogen,” and that classification is expected to soon move to
“probable” or “certain.” Glioblastoma (brain cancer) and acoustic neuroma
are just two types of tumors on the rise. The WHO claims that we can expect
more cancers in the future. The most recent and compelling evidence on
cancer comes from the U.S. government NIH National Toxicology Program,
a 10-year $25 million study that reveals conclusively that cell phone
radiation causes cancerous tumors of the heart and brain in rats. The
American Cancer Society called the results of this study “a paradigm shift.”
5. The World Health Organization recognizes a syndrome called
“electrosensitivity” that affects a growing percentage of the population. As
far back as 1971, Russian scientists presented to the WHO a comprehensive
series of symptoms, which they called “microwave sickness.” Wireless
radiation can cause headaches, fatigue, insomnia, heart arrhythmias,
disturbed sleep, concentration problems, memory impairment, breathing
difficulties, dizziness and many more symptoms. As with other types of
radiation, the dose is cumulative, and 5G will further increase that dose.
EHS people have suffered loss of finance, home, work, and inalienable
rights.
6. Pregnant mothers and children are especially at risk from wireless
radiation. Children’s brain tissues are more absorbent, their skulls are
thinner and their relative sizes are smaller than those of adults. Radiation
penetrates more deeply into children’s brains. If 5G were deployed in
neighborhoods near homes, schools, and playing fields, a particularly
vulnerable population would be exposed to yet another layer of untested
radiation.
7. The FCC website claims that ground-level power densities are low when
the antennas are attached to poles above us. However, if 5G is deployed in
neighborhoods, ground levels of radiation are irrelevant because antennas
would be at the level of bedrooms in second and third floor homes where
exposure levels would be high and dangerous.
8. 5G antennas are not omni-directional like 2G, 3G or 4G. 5G antennas use
phased arrays, which produce steerable, concentrated beams of waves that
can join transmissions from nearby antennas. When transmissions are
additive, they make dangerous high-level beams and areas of overlap where
rays are pulsing at different intervals, causing the mitochondria in every cell
of the human body to break down.
9. Residents would not be able to monitor their own exposure because no
simple meter or instrument to measure the levels of 5G waves is available.
All equipment to measure 5G is military grade, costing about $100,000 .
How could electromagnetically sensitive people know which locations
would be safe for them? Nobody would be capable of monitoring exposure
and no governmental oversight is planned.
10. Environmental effects from 5G are predicted, especially on pollinating
insects. In recent years, populations of insect pollinators have been greatly
reduced. Insects use radiofrequency waves to communicate amongst
themselves, and 5G is expected to bring increased threat to their already
compromised survival and to the resultant cascading effect on the food
sources of humans.
Focused concern on the part of both science and citizenry is raising serious
questions about the basic safety of our current technologies. Even these
technologies were not properly vetted before they were deployed on the
public. Adding an untested technology such as 5G into the already multi-
layered mix of electro-smog is at best irresponsible to us as adults but
arguably criminal when we subject our children to this potential carcinogen.
Dr. Ronald Kostoff, Georgia Institute of Technology researcher, is
particularly concerned about the additive effects of 5G in combination with
other toxins. “We do not have . . . long-term tests of combinations on human
beings . . . We don't have even short-term tests of these combinations. In
short, implementing 5G in the near future without this level of health
testing would be analogous to an inaugural commercial flight of an
advanced passenger aircraft that had never been flight-tested.
Dr. Beatrice Golombe, Professor of Medicine at UC San Diego, has said
about 5G deployment, “Many people will suffer greatly and needlessly, as a
direct result. Let our focus be on safer, wired and well-shielded technology
—not more wireless.”
Representing San Rafael Residents Opposed to 5G-Small Cell Antennas,
Vicki Sievers, EMF Safety Network, Marin Education/Outreach
Alex Stadtner, Building Biologist
Kim Hahn, Sun Valley
Bob Berg, Mont Marin
1
Martin Pall, PhD
August 7, 2017
Dear California Legislators,
I am Dr. Martin Pall, Professor Emeritus of Biochemistry and Basic Medical Sciences at
Washington State University. I am a published and widely cited scientist on the
biological effects of electromagnetic fields and speak internationally on this topic. I am
particularly expert in how wireless radiation impacts the electrical systems in our bodies.
I have published 7 studies showing there exists exquisite sensitivity to electromagnetic
fields (EMFs) in the voltage sensor in each cell, such that the force impacting our cells at
the voltage sensor has massive impact on the biology on the cells of our bodies [1-7].
These papers are discussed in over 360,000 web sites which can be easily found by
Googling (Martin Pall electromagnetic). I received my PhD at Caltech, one of the top
scientific institutions in the world.
EMFs act by activating channels in the membrane that surrounds each of our cells, called
voltage-gated calcium channels (VGCCs). The EMFs put forces on the voltage sensor
that controls the VGCCs of about 7.2 million times greater than the forces on other
charged groups in our cells [4,6,7]. This is why weak EMFs have such large biological
effects on the cells of our bodies! EMFs works this way not only on human and diverse
animal cells [1-7] but also in plant cells [7] so that this is a universal or near universal
mechanism of action.
Thousands of published studies show biological and health effects from
electromagnetic fields. We now know the mechanism that can explain these effects.
The mechanism is a function of the electromagnetics of each cell—not solely about
heating effects from the radiation (on which present FCC guidelines are based).
This new understanding [1-7] means we can debunk the claims of the wireless industry
that there cannot be a mechanism for effects produced by these weak EMFs. The 20
years plus of industry propaganda claims are false. Rather the thousands of studies
showing diverse health impacts of these EMFs can be explained. We now have a
mechanism, one that is supported by both the biology and the physics, both of which are
pointing in exactly the same direction. I am sending as a separate document a list of 134
reviews, each of which provides from 12 to over a thousand individual citations showing
health impacts of low intensity EMFs, EMFs that the telecommunications industry claims
cannot have such effects. These 134 reviews and thousands of primary scientific
papers they cite show that the industry propaganda has no scientific support
whatsoever.
The consensus among independent scientists on this is further confirmed by the 2015
(and later) appeal made to the United Nations and member states, stating that the current
EMF safety guidelines are inadequate because they do not take into consideration non-
thermal effects. This was signed by 225 scientists from 41 countries, each of whom had
2
published peer reviewed studies on EMF health effects – a total of 2,000 papers
published in this area by the signers, a substantial fraction of the total publications in this
area.
According to industry, the forces electromagnetic fields place on electrically-
charged groups in the cell are too weak to produce biological effects. However, the
unique structural properties of the voltage-gated calcium channel (VGCC) protein
can, it turns out, explain why the force on a cell’s voltage sensor from low-intensity
EMFs are millions of times stronger than are the forces on singly-charged groups
elsewhere in the cell.
It would be a disaster for the health of Californians to be exposed to the antennas
envisioned in SB.649. The State of California would be making a grave mistake to
proceed with supporting the commercial interests of the wireless industry with this
legislation. Legislators would best pause to understand the gravity of the biological
effects, and the ramifications for physical and mental health, as well as
consequences from continual damage to human DNA, and learn the facts from
scientists who are independent of the wireless industry, not from the industry
lobbyists who have a gigantic conflict of interest.
VGCC activation in cells produced by low intensity EMFs can explain long-reported
findings that electromagnetic fields and a wide range of biological changes and health
effects. The first 6 of these (see below) were well documented 46 years ago in the U.S.
Office of Naval Medical Research report, published in 1971 [8]. The others that follow
have been extensively documented subsequently in the peer-reviewed scientific literature:
1) Various neurological/neuropsychiatric effects, including changes in brain structure and
function, changes in various types of psychological responses and changes in behavior.
2) At least eight different endocrine (hormonal) effects.
3) Cardiac effects influencing the electrical control of the heart, including changes in
ECGs, producing arrhythmias, changes that can be life threatening.
4) Chromosome breaks and other changes in chromosome structure.
5) Histological changes in the testes.
6) Cell death (what is now called apoptosis, a process important in neurodegenerative
diseases).
7) Lowered male fertility including lowered sperm quality and function and also lowered
female fertility (less studied).
8) Oxidative stress.
9) Changes in calcium fluxes and calcium signaling.
10) Cellular DNA damage including single strand breaks and double strand breaks in
cellular DNA and also 8-OHdG in cellular DNA.
11) Cancer which is likely to involve these DNA changes but also increased rates of
tumor promotion-like events.
12) Therapeutic effects including stimulation of bone growth.
13) Cataract formation (previously thought to be thermal, now known not to be).
14) Breakdown of the blood-brain barrier.
15) Melatonin depletion and sleep disruption.
3
They may be low intensity but with regard to the VGCCs, electromagnetic fields
can have a tremendously powerful impact on the cells of our bodies. Furthermore,
published studies showing that calcium channel blocker drugs block or greatly lower
biological effects from electromagnetic fields confirm there is a VGCC activation
mechanism that is causing various effects. Higher frequency electromagnetic fields from
5G technologies on the horizon pose even greater biological concern than those to which
we are exposed today. We should be moving, instead, to wired technologies at every
opportunity, based on what we know in science today, not expanding and supporting the
proliferation of wireless.
I want to make several additional points very clear:
1. The Physics and the Biology are both pointing in the same direction. Both show
that EMFs act primarily via activating the VGCCs in the cells of our bodies.
2. DNA damage known to be produced by these EMFs occur in human sperm and
may also occur in human eggs, leading to large increases in mutation in any
children born. It is thought that an increase in mutation frequency of 2.5 to 3-fold
will lead to extinction because of accumulation of large numbers of damaging
mutations. We may already be over this level, and if so, simply continuing our
current exposures will lead to eventual extinction. Further increases in exposures
will be more rapidly self-destructive.
3. Pulsed EMFs are, in most cases, more biologically active and therefore more
dangerous than are non-pulsed (continuous wave) EMFs. All cordless
communication devices communicate via pulsations, because it is the pulsations
that carry the information communicated. All the industry claims of safety are
based on a theory (only thermal effects) that was known to be wrong back in 1971
[8] – and that was before many thousands of additional studies were published
providing massive confirmation that industry claims are false.
4. The industry is trying to move to much higher frequencies because these much
higher frequencies allow much higher pulsations and therefore much higher
transmission of information. However, these higher pulsation rates make these
ultra-high devices vastly more dangerous. This is part of the reasons why it is so
important to vote down SB.649.
5. None of our wireless communication devices are ever tested biologically for
safety – not cell phone towers, not cell phones, not Wi-Fi, not cordless phones,
not smart meters and certainly not 5G phones, or radar units in cars – before they
are put out to irradiate an unsuspecting public.
6. The telecommunications industry has corrupted the agencies that are supposed to
be regulating them. The best example of this is that the FCC which regulates
EMFs in the U.S. is a “captured agency”, captured by the industry it is supposed
to regulate, according to an 8 chapter document published by the Edmond J. Safra
Center for Ethics at Harvard University [9]. Is it any wonder, therefore, that the
industry keeps touting that their devices are within the safety guidelines set by the
FCC?
4
I urge you to do the right thing on behalf of the health of Californians and future
generations. Please let me know if I can provide further information. (503) 232-3883.
Sincerely,
Martin Pall, PhD (Caltech, 1968)
Professor Emeritus of Biochemistry and Basic Medical Sciences
Washington State University
Citations:
1. Pall ML. 2013 Electromagnetic fields act via activation of voltage-gated calcium channels to
produce beneficial or adverse effects. J Cell Mol Med 17:958-965.
2. Pall ML. 2014 Electromagnetic field activation of voltage-gated calcium channels: role in
therapeutic effects. Electromagn Biol Med. 2014 Apr 8.
3. Pall ML. 2015 Scientific evidence contradicts findings and assumptions of Canadian Safety
Panel 6: microwaves act through voltage-gated calcium channel activation to induce biological
impacts at non-thermal levels, supporting a paradigm shift for microwave/lower frequency
electromagnetic field action. Rev Environ Health 30:99-116.
4. Pall ML. 2015 Elektromagnetische Felder wirken über die Aktivierung spannungsabhängiger
Calciumkanäle, um günstige oder ungünstige Wirkungen zu erzeugen. Umwelt-Medizin-
Gesellshaft 28: 22-31.
5. Pall ML. 2015 How to approach the challenge of minimizing non-thermal health effects of
microwave radiation from electrical devices. International Journal of Innovative Research in
Engineering & Management (IJIREM) ISSN: 2350-0557, Volume-2, Issue -5, September 2015;
71-76.
6. Pall ML. 2016 Microwave frequency electromagnetic fields (EMFs) produce widespread
neuropsychiatric effects including depression. J Chem Neuroanat 75(Pt B):43-51. doi:
10.1016/j.jchemneu.2015.08.001. Epub 2015 Aug 21.
7. Pall ML. 2016 Electromagnetic fields act similarly in plants as in animals: Probable activation of
calcium channels via their voltage sensor. Curr Chem Biol 10: 74-82.
8. Naval Medical Research Institute Research Report, June 1971. Bibliography of Reported
Biological Phenomena (“Effects”) and Clinical Manifestations, Revised, ZR Glaser.
9. Captured Agency: How the Federal Communications Commission Is Dominated by the Industries
It Presumably Regulates, by Norm Alster. Published by Edmond J. Safra Center for Ethics,
Harvard University. An e-book under the Creative Commons 4.0 License:
https:/creativecommons.org/licences/by/4.0/
A 5G Wireless Future: Will it give us a Smart
Nation or Contribute to an Unhealthy One?
Dr. Cindy Russell
V.P. Community Health, SCCMA/MCMS
“It would greatly extend FCC’s current policy of the mandatory irradiation of the public
without adequate prior study of the potential health impact and assurance of safety. It would
irradiate everyone, including the most vulnerable to harm from radiofrequency radiation:
pregnant women, unborn children, young children, teenagers, men of reproductive age, the
elderly, the disabled, and the chronically ill.” —Ronald Powell, PhD, Letter to FCC on 5G
expansion (7)
BRAVE NEW WORLD OF COMMUNICATION
The use of mobile wireless technologies continues to increase worldwide. A new
faster 5th generation (5G) telecommunication system has recently been approved
by the Federal Communications Commission(FCC) with new antennas already
being installed and tested in Palo Alto and Mountain View. While it may give us
uber automation and instantaneous “immersive entertainment” a lot of questions
remain with regards to public health and safety of wireless devices. Will the
adoption of this new 5G technology harm directly or indirectly the consumers and
businesses it hopes to attract?
5G is the new promised land for wireless technology. It could connect us in our
homes, workplaces and city streets to over a trillion objects around the world. (96)
The Internet of Things (IoT) is primed to give us self-driving cars, appliances that
can order their own laundry soap, automation hubs that pay your bills, not to
mention fast movie downloads and virtual reality streaming from anywhere when
you are on the go. Companies are already asking local cities and counties to move
forward to create “Smart Cities” which have comprehensive digital connectivity by
installing a massive wireless sensor network of almost invisible small cell antennae
on light posts, utility poles, homes and businesses throughout neighborhoods and
towns in order to integrate IoT with IT. They state it will improve services, the
economy and quality of life. This communication network will form an expanded
electromagnetic microwave blanket above each city and county, permeating the
airspace and providing seamless connectivity where people and things will
exchange data.
Former Federal Communications Commission (FCC) chair Tom Wheeler called
this a “National Priority” and thus ushered in approval for the addition of this new
pervasive network of high frequency short wave millimeter broadband for
commercial use first planned in urban areas.
Developing a “Smart” World?
Engineers and physicists are busy working out the details of carrier frequencies
and the architecture of the new network. Manufacturing industries are already
developing commonly used products that feature wireless integration that will
connect to the densely clustered antennas. Marketing companies are now pushing
ads for “smart” devices for “smart” people in “smart” cities. Even the healthcare
industry is anticipating using some of these wearable devices for patients with
cardiac conditions or to do remote surgery in other parts of the world. Opening up
5G Spectrum access hopes to drive an explosion of new products. The economic
opportunities are obvious and business will be booming in the tech industry.
Concerns continue to rise however about the basic safety of our current use of
wireless technologies not to mention adding layers of newer microwave
frequencies that have not been tested for short term or long term safety. Important
questions have not been addressed while industry and government policy have
already moved forward.
• Why is the FCC streamlining permitting of 5G high frequency when they
have not completed their investigation on health effects nor updated safety
limits for low-intensity radio frequency radiation?
• Is the widespread “deployment” of this pervasive higher frequency small
cell distributed antennae system in our cities and on our homes safe for
humans and the environment?
• Will it add to the burden of chronic disease that costs our nation over a
trillion dollars annually? (105)
• Are we already digitally over connected, outsourcing our grey matter and
becoming a dysfunctional addicted nation because of it? (136,137,138)
• How will this affect our privacy, cyber security and the security of medical
records?
• Will we as physicians be able to recognize the emerging adverse health
effects of new millimeter technology and wearable technology let alone that
of current wireless devices?
“Over the past century, this natural environment has
sharply changed with introduction of a vast and
growing spectrum of man-made EM fields.” Adey
(135)
A Good Read: Federal Communications Commission 5G Letters
Letters to the FCC in 2016 responding to the 5G roll out with the addition of new
high frequencies were mixed. Industry generally applauded the FCC for its efforts
and discussed the growing demand for this technology along with a need for
flexible regulation to implement it. Some expressed concerns about interference
with other satellite systems. Some felt there should be maximum spectrum usage
opening up even higher frequencies that are only experimental now in order to help
“the underserved”. Others argued about opening this up to licensed versus
unlicensed uses. Industry did not mention any potential public or environmental
health hazards regarding the use of these new frequencies.
Raising a Red Flag to Push the Pause Button on 5G
Private citizens and Ph.D’s, however did raise a red flag at the FCC,
recommending a halt to infrastructure plans and more testing for health and
environmental reasons. They questioned the current FCC standards which are
outdated and not protective of human health. They asked “How will it affect
children, pregnant women and the elderly who are the most vulnerable in our
population?” While scientists gave ample evidence that precaution should prevail,
I found the most compelling letters were from those who describe their fear as
electro-sensitive people in an already dangerously high electromagnetic
environment for them.
Gimme Shelter: No Escape for Electro-Sensitive Individuals
Linda K. described her electrosensitivity with increased exposure to wireless
transmitters. In 1999, a cell tower was installed in her neighborhood 1000 feet
from her home. She began sleeping poorly but did not associate this with the cell
tower. In 2008, when she turned on a new wireless computer, she became dizzy,
nauseated, and couldn’t think. Symptoms ceased when the Wi-Fi card was
removed. When smart meters were installed in her neighborhood in 2012 (but not
on her home), she experienced severe insomnia. A month later she put together that
the cell tower had been the cause of her earlier poor sleep. About two years later
she noted an intense, uncomfortable feeling when walking by a nearby house and
later identified a Wi-Fi hotspot on a wire going from the utility pole to the house.
She stopped walking near the house. She wrote about her concerns and that the
new frequencies may add to her symptoms and inability to leave her house.
(54)
In another letter Veronica Z. noted “This is a notice of survival. What many of us
deal with currently is trying to survive in an environment that is hostile to us
biologically. We have lost all of our rights, our finances, our homes, our ability to
earn a living due to this ubiquitous exposure. We are being tortured every second
of every day and have been reduced to simply trying to survive the moments we
are alive. Others have been unable to do so and have opted to not stay living on
this planet of torture...There is no escape for people with severe sensitivities to this
deadly radiation.” (55)
Ask NASA: Is Electro-Sensitivity Real or Imagined?
Are these people telling the truth? Is this just psychological? You may wonder,
however, more and more people from all ages, professions and walks of life are
relating similar symptoms in the presence of wireless devices. Some children
reported these symptoms when their school adopted Wi-Fi.
Dr. Scott Eberle, a well respected Petaluma hospice physician, eloquently
described his development of electro-sensitivity in the November 2016 issue of the
SCCMA Bulletin. He goes to great lengths to continue his profession, interact with
his colleagues and maintain a healthy existence. (67)
We are exposed to increasing levels of microwave EMF in our daily lives. More
scientific evidence links biologic effects with increased reports of health related
effects including electro-sensitivity. In 1971 Russian scientists Gordon and
Sadchikova from the Institute of Labor Hygiene and Occupational Diseases
described a comprehensive series of symptoms which they called ‘microwave
sickness” and presented this at an international WHO meeting. (109)
In a 1981 NASA report, “Electromagnetic Field Interactions: Observed Effects and
Theories” microwave sickness was also described. The symptoms recorded were
headaches, eyestrain, fatigue, dizziness, disturbed sleep at night, sleepiness in
daytime, moodiness, irritability, unsociability, hypochondriac reactions, feelings of
fear, nervous tension, mental depression, memory impairment, pulling sensation in
the scalp and brow, loss of hair, pain in muscles and heart region, breathing
difficulties, increased perspiration of extremities. (63)
The Science of Electro-Sensitivity
Belpomme, in 2015, completed the most comprehensive study of electro-
sensitivity, investigating 1216 people: 71.6% with electrosensitivity, 7.2% with
chemical sensitivity, and 21.2% with both. They found an elevation in several
reliable disease biomarkers—each occurring within a range of 23% to 40% of all
cases—which prompted their conclusion that these sensitivities can be objectively
characterized and diagnosed and “appear to involve inflammation-related hyper-
histaminemia, oxidative stress, autoimmune response, capsulothalamic
hypoperfusion and pathologic leakage of the blood-brain barrier, and a deficit in
melatonin metabolic availability” (68)
The Science of EMF Biological Harm
The scientific literature abounds with evidence of non-thermal cellular damage
from non-ionizing wireless radiation for several decades. There are likely several
mechanisms both direct and indirect. Oxidative damage is one that has been well
studied. Effects have been demonstrated on cell membranes causing a shift in the
voltage gated calcium channels. Sperm studies have consistently found genotoxic,
morphologic and motility abnormalities in the presence of cell phone radiation.
DNA damage, blood brain barrier effects, melatonin reduction, nerve cell damage,
mitochondrial disruption and memory disturbances have been revealed. The
BioInitiative Report (139) has chronicled these effects and a growing wave of
PEER reviewed studies is building on that base daily. In 2011, the International
Agency for Research on Cancer classified radiofrequency as 2B carcinogen and
“possibly carcinogenic to humans”, the same category as DDT, lead and other
pesticides
The Latest Science: National Toxicology Program Study on Cell Phones and
Cancer
The most recent and compelling evidence has come from the 2016 National
Institutes of Health, National Toxicology Program. Called the NTP Toxicology
and Carcinogenicity Cell Phone Radiation Study, the 10 year $25 million research
revealed conclusively that there was a harmful effect from cell phone microwave
radiation. (124,125) The frequencies are similar to other wireless devices we
commonly use. The studies were robust, collaborative, well controlled and with
double the number of rats required to reveal a significant effect, if present. The
preliminary results of the study showed that RFR caused a statistically significant
increase in two types of brain tumors, gliomas and schwannomas. These were the
same two types of tumors shown to increase in human epidemiological studies on
long term use of cell phones. Dr. Lennart Hardell and others have demonstrated a
consistent pattern of increased incidence of ipsilateral (same side) acoustic
neuromas (vestibular schwannomas) and gliomas with each 100 hours of cell
phone use. (112-118) Another telling finding was that the control rats had much
lower than expected cancer rates. It is believed due to the fact the control rats were
in a controlled faraday cage and not exposed to normal ambient EMF that could
contribute to cancer.
Ron Melnik, PhD, Senior Toxicologist and Director of Special Programs in the
Environmental Toxicology Program at the National Institute of Environmental
Health Sciences (NIEHS) and designer of the study states, “The NTP tested the
hypothesis that cell phone radiation could not cause health effects and that
hypothesis has now been disproved. The experiment has been done and, after
extensive reviews, the consensus is that there was a carcinogenic effect.”
(124,125,126,127)
Health Effects of Millimeter 5G Wavelengths
The term "millimeter waves" (MMW) refers to extremely high-frequency (30-300
GHz) electromagnetic radiation. Millimeter Waves (MMW) used in the next-
generation of high-speed wireless technologies have shallow penetration thus
effect the skin surface, the surface of the eye or on bacteria, plants and small life
forms. Surface effects, however, can be quite substantial on an organism as
stimulation of skin receptors can affect nerve signaling causing a whole body
response with physiological effects on heart rate, heart rhythm, and the immune
system.
In a 1998 review article, Pakhomov (123) looked at the bio-effects of millimeter
waves. He reviewed dozens of studies and cites research demonstrating profound
effects of MMW on all biological systems including cells, bacteria, yeast, animals
and humans. Some effects were clearly thermal as millimeter microwaves are
rapidly absorbed by water which is abundant in living organisms. When
microwaves are absorbed the energy can cause tissue heating. Many of the
millimeter frequency studies however showed effects without heating of tissues
and at low intensities. Research was variable and showed both regenerative effects
and also adverse effects depending on frequency, power and exposure time.
Arrythmias
Chernyakov induced heart rate changes in anesthetized frogs by microwave
irradiation of remote skin areas. Complete denervation of the heart did not prevent
the reaction. This suggested a reflex mechanism of the MMW action involving
certain peripheral receptors.(28)
Heart Rate Variability
Potekhina found certain frequencies from 53-78 GHz band (CW) changed the
natural heart rate variability in anesthetized rats. He showed that some frequencies
had no effect (61 or 75 GH) while other frequencies (55 and 73 GHz) caused
pronounced arrhythmia. There was no change in skin or whole body temperature.
(69)
Teratogenic Effects
One study of MMW teratogenic effects was performed in Drosophila flies by
Belyaev. Embryos were exposed to 3 different GHz frequencies for 4-4.5 hours at
0.1 mW/cm2. He found that irradiation at 46.35 GHz, but not at 46.42 or 46.50
GHz, caused marked effects including an increase in morphological abnormalities
and decreased survival. It was felt the MMW disturbed DNA-protein interactions
at that particular frequency.(65)
Bacterial Affects and Antibiotic Resistance
Bulgakova in over 1,000 studies with 14 different antibiotics showed how MMW
exposure of S. aureus affects its sensitivity to antibiotics with different
mechanisms of action. The MMW increased or decreased antibiotic sensitivity
depending on the antibiotic concentration. (134)
Pakhomov warns, “Regardless of the primary mechanism, the possibility of
significant bio-effects of a short-term MMW irradiation at intensities at or below
current safety standards deserves consideration and further study. The possibility
of induction of adverse health effects by a local, low -intensity MMW irradiation is
of potential significance for setting health and safety standards and requires special
attention.” He called for replication of studies especially long term effects of
MMW.
His conclusions
1) Individuals or groups in a population, which would usually be regarded as
uniform, may react to MMW in rather different or even opposite ways
2) There seem to exist unknown and uncontrolled factors that determine the MMW
sensitivity of a specimen or a population. Irradiation could increase antibiotic
resistivity in one experiment and decrease it in the next one
3) Increased sensitivity and even hypersensitivity of individuals to MMW may be
real. Depending on the exposure characteristics, especially wavelength, a low-
intensity MMW radiation was perceived by 30 to 80% of healthy examinees.(123)
Cataracts
Prost in 1994 studied millimeter microwave radiation on the eye. He noted that
microwaves of different wave-lengths can induce the development of cataracts.
(13) His research found that low power millimeter waves produced lens opacity in
rats exposed to 10mW/cm2, a predisposing indicator of cataracts. (74)
Immune System
Kolomytseva, in 2002, looked at the dynamics of leukocyte number and functional
activity of peripheral blood neutrophils under whole-body exposure of healthy
mice to low-intensity extremely-high-frequency electromagnetic radiation (EHF
EMR, 42.0 GHz, 0.15 mW/cm2, 20 min daily). The study showed that the
phagocytic activity of peripheral blood neutrophils was suppressed by about 50%
in 2-3 h after a single exposure to EHF EMR.(131)
Chromatin Effects
Gapeve in 2003 showed for the first time that low-intensity extremely high-
frequency MMH electromagnetic radiation in vivo causes effects on spatial
organization of chromatin in cells of lymphoid organs. Chromatin is a complex of
DNA and proteins that forms chromosomes within the nucleus of eukaryotic cells.
He exposed mice to a single whole-body exposure for 20 min at 42.0 GHz and 0.15
mW/cm2. (132)
Gene Expression
Habauzit in 2013 looked at gene expression in keratinocytes with 60GHz exposure
at upper limit of current guidelines and concluded “In our experimental design, the
high number of modified genes (665) shows that the ICNIRP current limit is
probably too permissive to prevent biological response. (73)
Gaps in Data for Launching 5G Millimeter Devices
Commercial production often precedes research on consumer protection and health
effects. We have too many toxins that have escaped premarket safety protocols for
too long- lead, asbestos, smoking and our modern unregulated nanoparticles to
mention just a few. These affect our long term and short term health in ways we do
not even know. If we become ill, we do not question or identify the daily or weekly
chemical exposures that could have contributed to that cancer or arthritis or lung
disease or Alzheimer’s. We have too many toxins to sort it all out.
Research shows that wireless microwave radiation adds yet another dose of toxic
exposure to our daily lives. We cannot hear it or smell it or feel it. Yet it affects our
biology and our wellbeing with perhaps subtle affects. If we are electro-sensitive
then we are more likely to avoid exposure. Trees are even susceptible to EMF
harm and they cannot move away. (128) What about birds and bees and us?
Close Encounters: Google Glass, Virtual Reality and Wearable Wireless
Devices
If we are concerned about putting a cell phone to our ears for long periods of time
after reading about the NTP study then why aren’t we concerned about other
wearable devices? While very cool to use, Google Glass and Virtual Reality may
have dangerous consequences to our eyes, brain function or immune systems with
long term use, especially to children. What are the frequencies in these devices?
3G,4G, 5G or a combination of zapping frequencies giving us immersive
connection and entertainment but at a potentially steep price.
5G Research and Policy
Safety testing for 5G is the same as other wireless devices. It is based on heat. This
is an obsolete standard and not considering current science showing cellular and
organism harm from non-thermal effects. There is a large gap in safety data for 5G
biological effects that has been demonstrated in older studies including military.
New Recommendations to Protect Public Health
1) Do not proceed to roll out 5G technologies pending pre-market studies on health effects.
2) Reevaluate safety standards based on long term as well as short term studies on biological
effects.
3) Rescind a portion of Section 704 of the Telecommunications Act of 1996 which preempts
state and local government regulation for the placement, construction, and modification of
personal wireless service facilities on the basis of the environmental effects so that health and
environmental issues can be addressed.
4) Rescind portions of The Spectrum Act which was passed in 2012 as part of the Middle Class
Tax Relief and Job Creation Act, which strips the ability city officials and local governments to
regulate cellular communications equipment, provides no public notification or opportunity for
public input and may potentially result in environmental impacts.
5) Create an independent multidisciplinary scientific agency tasked with developing appropriate
safety regulations, premarket testing and research needs in a transparent environment with public
input.
6) Label pertinent EMF information on devices along with appropriate precautionary warnings.
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Wireless Silent Spring
Dr. Cindy Russell
VP Community Health SCCMA
Santa Clara County Medical Association Bulletin, October 2018
“Those who dwell among the beauties and mysteries of the
earth are never alone or weary of life.” Rachel Carson, Author Silent
Spring.
In The War on Insects: Nature Becomes Silent
Our ill-fated desire to control nature as well as our tendency to ignore our own
complicity in its destruction for profit was the focus of a seminal 1962 book,
“Silent Spring”. This publication is widely credited with ushering in the modern
environmental movement. (1) Rachel Carson, a marine biologist, and author of
“Silent Spring”, was first a lover of nature and a poet. Through her astute
observations of nature, careful documentation and gifted writing, she was able to
bring attention to the devastating and long lasting effects of pesticides which
continue to impact all wildlife and species, including humans.
Her book contains story after story showing the annihilation of birds, squirrels,
fish, earthworms, and beneficial insects after the introduction of ever more toxic
pesticides to fight invasive insects such as the Japanese beetle. Funds were endless
from the Department of Agriculture who declared that these pesticides were
perfectly safe as planes deposited hundreds of pounds of pellets into yards, schools
and farms. Water turned into poison and rivers of death for salmon and other
species. Bird populations of robins, pheasants, and meadowlarks plummeted along
with rabbits, muskrats and cats. Farm animals who were exposed withered and
many died. Dogs even fell ill. The Japanese beetle survived, however, as most
insects cleverly and rapidly become resistant to these chemicals, which can persist
in the soil and waterways for years. While species targeted biologic methods of
control and integrated pest management tools have been developed, more and more
pesticides have been created leaving us an economically profitable but toxic
legacy- DDT, Chlordane, Dieldrin, 2-4 D- Malathion, Glyphosate.
There are many similarities between the silent spring created in cities and farms
from pesticides and that of wireless technology with the rapid and widespread
adoption of cell towers. Let’s examine the effects of this technology that biologists
have found on wildlife and then compare the histories, mechanisms and impacts
between pesticides and wireless radiation.
Wireless Radiofrequency Affects Navigation of Birds and Bees
It is well known that magnetite, a form of iron ore, is found in a wide variety of
organisms. It has been shown that this substance is used to sense the earth’s low
energy magnetic field as a directional reference. (Cadiou and McNaughton 2010).
Magnetite acts as an internal compass. For over 50 years, scientists have known
that migratory birds use the earth’s magnetic field to navigate. As it turns out, a
diverse array of animal life also relies upon this geo magnetic field as their GPS for
breeding, feeding, migration and survival.
Biologists have unexpectedly discovered that wireless radiofrequency radiation
(RFR) disturbs internal magneto-receptors used for orientation. In addition, this
non ionizing radiation can have profound impacts on the natural environment by
disruption of other complex cellular and biologic processes in mammals, birds,
fish, amphibians, insects, trees, plants, seeds and bacteria. Reported adverse effects
from radiofrequency radiation that have been identified include abnormal behavior,
developmental abnormalities, diminished reproduction and increased mortality.
The effects of this radiation may not be immediately apparent with a slow decline
in the health of wildlife seen over time with cumulative exposure, adding a new
environmental toxin contributing to silent springs in cities, orchards and farms. The
more towers, the more additive mix of radiation frequencies saturating the
environment, creating an increasingly toxic air space. Non thermal biological
effects are not considered in current guidelines. Appropriate safety testing and
regulation of this technology is lacking, however, invention, commercialization
and deployment of cell towers marches on-1G, 2G, 3G, 4G, 5G.
The Skrunda Radio Location Case
Firstenberg (2017) in his fascinating and well-referenced book, The Invisible
Rainbow: A History of Electricity and Life, describes both observations and
biological controlled experiments performed, mostly in Europe, where a high
power early warning Radio Location Station tower was in place for over 25
years.(12) Studies performed during and after the tower was removed
demonstrated that it caused not only human symptoms including documented
memory, attention and motor deficits in children but also affected widespread
forest health with loss of birds, thinner growth rings on trees, poor seed
germination, loss of duckweed, among other effects. (3) When these towers were
removed, not only did the health of the local residents improve, the forest
recovered.
Bird Migration Disrupted More by Weak Magnetic Fields
Biologists have discovered that birds magnetic compass orientation appears more
vulnerable to weak broadband electromagnetic fields. Pakhomov (2017),
Schwarze (2016), Wiltschko (2015). A German scientist, Svenja Engles (2014)
lead the research project to confirm this effect. He and his German graduate
students exposed migratory European robins to the background electromagnetic
noise present in unscreened wooden huts at the University of Oldenburg city
campus and found the birds were confused and could not orient using their
magnetic compass. If grounded or screened with aluminum their orientation
reappeared, but disappeared again if broadband radiofrequencies were generated
inside the huts. He did not believe the effects at first and repeated the same double-
blinded experiment many times in 7 years and with different graduate students to
confirm the effect before publishing his results.
“And it’s not just pigeons— have you seen any sparrows or
parrots around, since these towers started springing up?”
K. Pazhaniappan, Secretary, New Madras Racing Pigeon Association (43)
When Homing Pigeons Can’t Find Home
Modern communications systems with a proliferation of cell towers in cities and
now in rural areas, create continuous pulsating artificial radiofrequency wave
mixtures that can alter local magnetic fields and thus impair bird migration and
orientation of pollinators. In a straight line of sight cell towers can transmit 20
miles or more. In 1998, soon after cell towers were installed in Pennsylvania,
pigeon races ended in disaster as up to 90% of birds were disoriented and lost their
navigational skills. This was reported in a New York Times article Dec 6, 1998,
When Homing Pigeons Don't Go Home Again. (2)
The problem of lost homing pigeons is becoming commonplace, leaving pigeon
racing aficionados very concerned. (6)(13) A 2013 British Pigeon Insider article
notes that pigeon keepers in England reported the loss of dozens of pigeons during
races, as well as abnormal frantic behavior near cell towers and declining pigeon
reproduction as cell towers have been reproducing in cities and farms. Another
article in Wired magazine cites one pigeon fancier who lost two-thirds of his
pigeons after a tower was installed next to his farm.
Fatal Attraction: Collisions with Cell Towers
The Audubon Society reports that each year up to 50 million birds, representing
230 different species, die in collisions with communication towers at night. (8)
This occurs when they hit the tall, antenna-sporting structures or associated guy
wires that support the cables. It has been found that at night birds are lured into the
deadly metal structures by the steady beam of red lights on the tops of the towers.
The lights are required by law for airline safety but the birds see this as a guiding
light and shift from using geomagnetic signals and instead head straight for the
beam.
An FAA study showed that small migratory birds become confused when they
reach the light and either hit the tower or they continue to fly around the tower
until exhausted and they fall to the ground. Flashing red lights seem to reduce the
number of fatal bird collisions. (11) Longcore (2013) studied the numbers and
types of birds killed by cell towers in the US and Canada and found “Neotropical
migrants suffer the greatest mortality; 97.4% of birds killed are passerines, mostly
warblers (Parulidae, 58.4%), vireos (Vireonidae, 13.4%), thrushes (Turdidae,
7.7%), and sparrows (Emberizidae, 5.8%). Thirteen birds of conservation concern
in the United States or Canada suffer annual mortality of 1–9% of their estimated
total population.” A 2015 FAA guideline strongly encouraged operators of all tall
cell towers to switch to flashing red lights by 2016. In November of 2016 about
750 tall towers (above 350 feet) had been switched, leaving about 15,000 more to
go, according to an American Bird Conservancy report. (24)
Cell Towers Not Healthy for Birds or Firemen
Government agencies, however, are becoming more aware. The Department of
Interior wrote a letter in 2014 to the National Telecommunications and Information
Administration regarding the DOI concerns about the First Responder Network
Authority (FirstNet) and their regulations regarding cell towers and the protection
of wildlife, especially migratory birds.(15) First Net is a public-private partnership
with AT&T and because of its stated duty to public safety it has significant
preemptions.(17) The DOI stated, “the proposals lack provisions necessary to
conserve migratory bird resources, including eagles. The proposals also do not
reflect current information regarding the effects of communication towers to
birds.” First net noted that the DOI “requested that FirstNet’s procedures include a
process for ensuring compliance with the Bald and Golden Eagle Protection Act
(‘BGEPA’), Migratory Bird Treaty Act (‘MBTA’), and Executive Order (E.O.)
13186, Responsibilities of Federal Agencies to Protect Migratory Birds.” (16)
The DOI is not the only one concerned about First Net towers. Although public
safety is important, what happens when the device intended for safety causes an
unintended threat to others? Some firemen have experienced a variety of
neurologic symptoms consistent with electrosensitivity (headaches, dizzyness,
brain fog, sleep deprivation, irritability) when cell towers were placed on their fire
stations. A pilot study of firemen was completed in 2004 and brain scans
confirmed those with symptoms had evidence of adverse brain alterations. Because
of this, the International Association of Firefighters has developed a policy to ask
for exemptions from cell tower placement on or adjacent to fire stations with new
cell tower legislation. (19) It is codified in California’s AB57(2015). (18)
“The exponential increase of mobile telephony has led to a
pronounced increase in electromagnetic fields in the
environment that may affect pollinator communities and
threaten pollination as a key ecosystem service.” Lazaro 2016
The Decline of Birds, Bees and Wildlife with Increasing
Radiofrequency Radiation
Researchers are now attributing wireless radiation from cellular communications to
be a significant contributing cause of bee “colony collapse disorder”, insect
disappearance, the decline in house sparrows in London (Balmori 2007) (Everaert
2007), as well as the steady deterioration of the worlds bird population with now
more than 40% of bird species under critical threat. Insects are not only important
pollinators, they are the base of the food chain for birds, amphibians, reptiles and
mammals. A Yale report highlights a 2014 study by Stanford professor Rudolfo
Drizo, which revealed that 42 percent of the 3,623 terrestrial invertebrate species
on the International Union for Conservation of Nature [IUCN] Red List, are
classified as threatened with extinction. He notes, “human impacts on animal
biodiversity are an under-recognized form of global environmental change.” (5)
Wireless Radiation and Colony Collapse Disorder
Bees are a critical pollinator species for agricultural productivity. (20) Of the 100
crops that provide 90% of the world's food supply, 71 are pollinated by bees,
according to the UN Environmental Program, #Friday Fact. (21) The report also
notes that to produce 1 kilogram of honey, a bee must visit four million flowers
and fly a distance equivalent to going around the Earth four times. Bee numbers
have plummeted in Europe, the United States and around the world in the last 2
decades. Contributing factors affecting the health and reproduction of bees include
pesticides, global climate change, loss of habitat and air pollution wit h new
research pointing towards microwave radiation as an important and yet
unrecognized cause for concern. Bees, as well as birds, contain magnetite
magneto-receptors in their abdomen.
Electromagnetic microwave radiation has been shown to disrupt bee behavior and
may cause worker bees to emit a piping signal to swarm. The bees have also
demonstrated aggression after 30 minutes of cell phone exposure. Favre (2017)
A cell phone placed next to a bee hive appears to cause a slow destruction of the
hive. (Dallo 2015) concludes in his research, “significant decrease in colony
strength, honey stores, pollen reserves, number of foragers returning to their hives
and egg laying capacity of queens in test colonies. Cell phone radiations disturbed
navigational skills of foragers.”
Lazaro (2016) looked at the effect of mobile communication antennas on the
abundance and composition of wild pollinators, including wild bees, hoverflies,
bee flies, remaining flies, beetles, butterflies, and wasps on two Greek islands with
variable distances from cell towers, carefully measuring the radiofrequency
radiation. He found negative effects in all groups except butterflies.
Belgian entomologist Marie-Claire Cammaerts (2017) has done a number of
studies on RFR and found that insects are particularly sensitive. She writes,”
Before the invention of the wireless technology, plenty of active insects fled on
crops, flowers, fruits, where they ate, drank, collected nectar, and numerous dead
insects were found crushed on cars. Nowadays, all this no longer occurs at such an
extent [2]. Bees may be particularly affected by manmade electromagnetism
[21,22,23]… When crossing such electromagnetic fields, bees may no longer
remember their way, may no longer fly in the correct direction, and may become
unable to go back to their hive.”
These are truly alarming findings and serve as a dire warning on further wireless
expansion, especially with regards to sensitive wildlife areas and agricultural rural
zones that depend on pollination.
“When crossing such electromagnetic fields, bees may no
longer remember their way, may no longer fly in the correct
direction, and may become unable to go back to their hive.”
Marie-Claire Cammaerts (2017)
5G Especially Harmful to Insects: The Resonance Effect and Phased
Arrays
Proposed 5G millimeter wavelengths are a similar size to insects and this creates a
damaging vibrational effect known as resonance on the organism. Resonance is a
well-known phenomenon in physics. A common example is that of a wineglass
which shatters when an opera star reaches a high C note, vibrating air molecules
matching the glasses natural oscillating frequency. In general, mechanical
resonance occurs when the frequency of an oscillation matches the systems or its
subcomponents natural frequency and this results in increasingly intensified
additive vibration with more energy being absorbed, causing more disturbance of
the system. At low power an effect is greatly magnified. Thielens (2018) looked at
this effect on 4 different insects exposed to electromagnetic fields from 2 to 120
GHz. He noted, “The insects show a maximum in absorbed radio frequency power
at wavelengths that are comparable to their body size…..This could lead to
changes in insect behaviour, physiology, and morphology over time due to an
increase in body temperatures, from dielectric heating.”
In addition, a newer technology previously used in the military for early warning
missile radar systems, PAVE PAWS, is incorporated into these 5G systems and
called phased arrays. (29) These powerful "beam steering" arrays scan back and
forth from tower to device for easier connection with an individual’s movement, to
detect the device, similar to the surface-to-air missile systems. (30) They are also
used in AM and FM Broadcast stations and planned for automotive sensors and
satellites. What effect will this increase in power and density of environmental
radiation have on our beneficial insects and pollinators?
Review Studies Point to Wildlife Harm
Balmori (2015) states in his latest review “Current evidence indicates that
exposure at levels that are found in the environment (in urban areas and near base
stations) may particularly alter the receptor organs to orient in the magnetic field of
the earth. These results could have important implications for migratory birds and
insects, especially in urban areas, but could also apply to birds and insects in
natural and protected areas where there are powerful base station emitters of
radiofrequencies.
Cucurachi (2012) in reviewing 113 peer-reviewed publications revealed, “In
about two thirds of the reviewed studies ecological effects of RF-EMF was
reported at high as well as at low dosages. The very low dosages are compatible
with real field situations, and could be found under environmental conditions.”
The Ministry of Environment and Forest in India (MOE 2010) examined all
available peer reviewed research on the impacts of wireless radiofrequency (RF)
on living organisms at the time, including birds and bees. They found that 593 of
the 919 articles showed adverse impacts. In each category of organism, over 60%
of the research indicated harm to that biological species.
“All life pulsates in time to the earth, and our artificial fields
cause abnormal reactions in all organisms.” Robert O. Becker, MD,
The Body Electric
Trees Damaged by Cell Towers
Aspen trees reproduce primarily from sprouting from the roots. If a stem dies,
another fresh shoot is sent up. “Clones” of tree stands are thus created that can live
hundreds to thousands of years. The health of Aspen tree stands is determined by
mature trees with shoots and saplings in between. In Colorado, Aspen trees have
been on the decline for decades but rapid mortality has been observed in clones
since 2004. (25) A preliminary experiment on trembling Aspen trees points to
ambient electromagnetic radiation from a variety of sources (cell towers, satellites,
RF from electric power generation) causing poor growth and smaller leaves.
Seedlings shielded from surrounding low level background RF radiation produced
vigorous shoot growth, no necrotic lesions and rich pigmentation in the leaves due
to anthocyanin production, versus unshielded seedlings which had a high
percentage of leaf necrotic tissue and a reduction in shoot length. (Haggerty 2009)
Waldmann-Selsam et al (2016) clearly demonstrated, in a robust 4 year study with
accurate RF emission testing, cell tower radiation causing the death of nearby trees
over time. He notes, “These results are consistent with the fact that damage
afflicted on trees by mobile phone towers usually start on one side, extending to
the whole tree over time.”
Are Bee Drones the Answer? “Smart” or Dumb Pollination?
Wireless technology, however convenient, has consequences. High tech has
invaded every corner of our lives and will soon be used in agriculture to pollinate
crops as bee colony collapse disorder worsens. In a CNN article “This 'bee' drone
is a robotic flower pollinator” The developer notes “It could conceivably be used in
large-scale farming, even in hydroponic farming." (22)
As cell towers and wireless systems proliferate, will we continue to ignore their
role in harming life sustaining ecosystems? Will we create dead zones in cities
where urban or rural farmers will not be able to grow food or have a vegetable
garden? Agriculture is already under siege from many other environmental threats.
Without bees there will be no pollination or honey. Without birds there will be no
seed dispersal.
The tech industry may advise us to use the very technology that is harming
ecosystems by using bee drones to pollinate our crops. Walmart has already filed a
patent for a robotic bee. (23) These high tech insects would be directed by 4G or
5G radiation to operate via the Internet of Things. Because the size of 5G
frequencies matches that of insects, this radiation acts as an insecticide (Yadav
2014). What about ownership of drones, privacy, security and adverse effects on
sensitive native bees and flowers, e-waste and energy consumption with the use of
these drones? Many questions with no answers but predictable negative
consequences. We have been there before with pesticides, asbestos, lead, mercury,
with new emerging toxins being regularly introduced. The fallout on public and
environmental health continues.
Scientists Appeal to the UN for Protective Health and
Environmental Standards
Scientists who study radiofrequency radiation note a serious lack of monitoring
and protocols to study the impacts of wireless technology and biologists are calling
for precaution in the placement of cell towers with further expansion of wireless
broadband. As of August 30, 2018, 244 EMF scientists from 41 nations have
signed an Appeal calling upon the United Nations, the WHO and the UNEP to
address the public health and environmental concerns raised in an extensive and
growing body of scientific evidence on the broad adverse impacts of wireless
radiation. (33)
“Everything is reversible because everything is unfortunately
of humankind’s making.” Tris Allinson, Bird Life’s senior global scientist,
on the decline of birds
Getting Smarter: Prevention Versus Treatment
Solving the real problems causing the decline in wildlife seems smarter than
always trying to develop a new and potentially more toxic industry to fix it.
Indeed, pesticides, habitat loss, over fishing, overhunting, overpopulation, global
climate change, environmental toxins, plastics in the ocean have had a devastating
impact on species. The World Wildlife Fund and the Zoological Society of London
reports that over half of the earth’s wildlife has been lost in the last 40 years. (27)
Prevention is far easier and more economical than treating a problem, especially if
the problem becomes irreversible (global climate change). Physicians prescribe
medications to treat chronic diseases of our modern culture. They are now
recognizing, however, that many of these synthetic medications, while useful, can
cause side effects that may be worse than the disease being treated. Current
medical care is focused more on cure or treatment than prevention or precaution,
causing continuing escalation of health care costs. Would it be better, instead, to
encourage lifestyle changes to promote health and wellness with a holistically
healthy diet, exercise and policies to reduce environmental toxic exposures?
What is a Safe Level of Radiofrequency? Standards Only Look at
Heat
Current guidelines for radiofrequency exposure are set at levels that cause tissue
heating, the assumed cause of harm from this radiation. The balance of scientific
evidence now indicates that there are significant adverse effects of this wireless
radiation at non-thermal levels. (Belpomme 2018) Environmental effects on
wildlife and plants confirms this. The mechanism has been found to be related to
calcium channel membrane effects and oxidation.
BioInitiative Report
Sage, Carpenter, Blank and other scientists note in the BioInitiative Report that
non-thermal bio-effects are clearly established. The Bioinitiative Report reviewed
studies looking at the lowest levels of non-thermal, non-ionizing radiofrequency
that did not cause harmful biological effects. Their conclusions, based on peer
reviewed research, indicated that there should be a “scientific benchmark of 0.003
uW/cm2 or three nanowatts per centimeter squared for ‘lowest observed effect
level’ for RFR is based on mobile phone base station-level studies.” They also
suggest “Applying a ten-fold reduction to compensate for the lack of long-term
exposure …or for children as a sensitive subpopulation,”. This would be a
recommended precautionary action exposure level of 0.0003 uW/cm2.
(Bioinitiative 2012) Our current U.S. guideline is 200 uW/cm2 to 1000 uW/cm2
for RF radiation depending on frequency. This is a substantial difference and
indicates a need for reevaluation of FCC safety standards and consideration of
published scientific research indicating non-thermal effects. (NTP 2018)
Independent Science Ignored
Professor Emeritus of Biochemistry at Washington State University Dr.
MartinPall, has written extensively on this subject. In a recent paper “5G: Great
Risk for EU, US and international Health”, he looked at eight distinct types of
harm from electromagnetic field exposure. This included DNA damage,
carcinogenicity, endocrine, nervous system and reproductive effects. Of 22 robust
independent research review papers on non-thermal EMF effects published on or
before 2013, 20 were ignored by the latest report of the European Commission’s
Scientific Committee on Emerging and Newly Identified Health Risks
(SCENIHR).
There is an urgent need for government agencies to adopt a realistic biologically
based radiofrequency exposure standard to replace the 20 year old thermal (SAR)
standard, which is far too permissive and not protective of human or environmental
health.
Wireless Silent Spring:
Parallels Between Pesticides and Wireless Radiation
In rereading Rachel Carson’s book, Silent Spring, I was struck by the many
similarities between pesticides and wireless radiation.
Both are Invisible
Pesticides act as an invisible poison that works on a cellular level and can abruptly
or slowly cause disease. You cannot see or taste it on your food or smell it as it
drifts through the neighborhoods and enters creeks.
Wireless radiation is similarly silent to most. You typically cannot hear, feel or see
radiofrequency radiation unless you are electrosensitive. Cellular and biologic
damage however is occurring.
Both are Universal in our Environment
Pesticides are routinely sprayed in homes, gardens, on trees, in forests to strike
insects far and wide. Biomonitoring studies nationwide and in California show
pesticides still present in blood, urine and breast milk. (California Biomonitoring)
(CDC Biomonitoring NHANES)
Wireless radiation is found almost ubiquitously in homes, businesses and schools
to connect us to the world and with each other instantaneously. This is supported
by well over 300, 000 cell towers in the U.S. not counting private cell towers. The
continuous pulsating waves of radiation stray into any nearby living organism, be it
human, pet or wildlife.
Life Long Exposures: Cradle to Grave
Pesticides and their sometimes more toxic residues are now found in all human
cord blood, urine and breast milk, and in children who do not eat organic foods.
(Bradman 2003) (Curl 2003) (Lu 2006) (Salama 2017) (CDC Biomonitoring)
Exposure to wireless radiation now begins in the fetus with cell towers along with
a host of wireless devices in the homes i.e. cell phones, Tablets, Wi-Fi routers,
smart meters, and now baby toys, smart cribs and wearable technology.
Non Selective Targets to Living Organisms with Indiscriminant
Harm
Pesticides are sprayed in large areas to kill a few flying insects but end up harming
all species and the balance of nature with ecosystem effects. (EPA Persistent
Organic Pollutants)
Wireless radiation is sprayed in all directions to find the intended device but also
penetrates all living organisms causing cellular damage with ecosystem effects.
(Balmori 2010), (Cucurachi 2012) (Sivani S and Saravanamuttu 2013) (NTP 2018)
Both Cause a Variety of Adverse Biological Effects
Pesticides can have many toxic biologic impacts and are associated with
malignant, neurodegenerative, respiratory, reproductive, developmental, and
metabolic diseases in humans. DDT and its metabolite DDE was found to cause
blindness in fish and can act as an endocrine disruptor, mutagen and carcinogen.
Women exposed to DDT before puberty are five times more likely to develop
breast cancer. Glyphosate is linked to cancer. (Creesey 2015) (Soto 2015)
(Mostafalou S and Abdollahi M 2013, 2017)
Wireless 2G radiation was found to cause DNA damage and increase the risk of
cancer of the heart, brain and adrenal medulla in a recent 10 year, $25 million
dollar National Toxicology Program study (NTP 2018). Non-ionizing radiation
from 3G and 4G cell towers have been found to cause nonspecific symptoms of
electrosensitivity in some living within 300 meters of a cell tower including
insomnia, dizziness, brain fog, fatigue, depression and heart palpitations. Cell
phone radiation has been associated with harm to the reproductive system,
neurologic system, immune system and hematologic system. (Bioinitiative Report
2014) (Oceana Report)
Both are Children of War
Pesticides were first developed as agents of chemical warfare. They happened to
kill the research insects and thus became commercialized for that purpose after the
war. We can now buy pesticides in the grocery store.
Radiofrequency microwave technology was developed in World War II. Known
as radar, it has many military uses including for surveillance, missile control, air
traffic control, moving target indication, weapons location and vehicle search. (39)
At the end of the war, microwave ovens were developed after an engineer
discovered a candy bar in his pocket had melted when he was near the magnetron
power source. (38) Millimeter technology (95GHz) has been developed for crowd
control (Active Denial System). (40) The recent health problems of Cuban,
Canadian and Chinese diplomats and their families has been attributed to
microwave radiofrequency radiation effects from either RF surveillance or
deliberate attacks. (36). Our homes typically have many wireless devices such as
cell phones, cordless phones, Wi-Fi, smart meters as well as microwave ovens.
Both are Biotoxic: Toxicity Through Oxidation
Pesticide toxicity can take various forms with a direct neurotoxic effect, DNA
damage, immune suppression and endocrine disruption through disturbance of
many cellular processes. (Mostafalou S and Abdollahi M. 2013, 2017) Newer
research on the mechanisms of toxicity of pesticides is focusing on oxidative
damage (free radical formation) as the result of a multistep process causing cellular
disruption, tissue damage, chronic disease and cell death. (Agrawal 2010)
Antioxidants have been shown to lessen the toxic effects of pesticides as well as
chemicals. (Akefe 2017)
Wireless radiofrequency radiation has also been shown to have a primary
mechanism of harm from oxidation. Yamenko (2016) looked at 100 studies of RF
radiation both in vivo and in vitro and found 93 showed oxidation as a mechanism
of toxicity. Research on antioxidants including curcumin, vitamin C, vitamin E,
melatonin show protection against the effects of non-ionizing radiation with a
reduction in oxidative stress.
Additive Toxic Mixtures More Harmful
Pesticide exposure does not happen in isolation. Typically, we are exposed to a
mix of pesticides in the food we eat. These pesticides circulate in our system for a
variable length of time from hours to years and can be stored in our fat or breast
milk. The toxic interactions can be long term. A conventional potato has 41
pesticides, 14 of which are classified as carcinogens. (44) EWG tested
strawberries and found about 22 pesticides in a conventionally grown berry.
Research has shown that mixes of chemicals and pesticides have additive and
synergistic toxic effects. For approval, however, these pesticides are studied only
one at time and without their “inactive” ingredients.
The more pesticides we are exposed to the greater the mix of adverse effects on the
immune system, reproduction, carcinogenicity, as our protective enzyme and
antioxidant mechanisms are overwhelmed. One pesticide can act as a mutagen, the
next an endocrine disruptor and the next suppress your immune system to promote
cancer. A true toxic triad of effects.
Wireless technology has continued to evolve and expand. The 1G analogue system
worked well but did not carry much data. While new generations have been
introduced to the marketplace to serve our unquenchable appetite for instant
wireless information and communication, the old will still be in place-2G, 3G, 4G.
With the latest proposed 5G technology and the Internet of Things, industry aims
to integrate this with other wireless generations, and even open up any remaining
radiofrequency spectrum, creating a blanket of mixed frequency wireless radiation
wildlife and humans will be exposed to.
Radiation emissions are not only from cell towers, but also in remotely-controlled
stratospheric balloons (Loon Project), far orbiting satellites and proposed low
orbiting satellites, greatly increasing ambient levels of electromagnetic
radiofrequency radiation (EMR). Like pesticides there has been inadequate
research examining the mix of frequencies we are exposed to. The 2018 NTP
study, which found clear evidence of carcinogenicity as well as DNA damage and
cardiomyopathy, looked only at 2G wireless technology. There are no government
plans for testing of 3G, 4G or 5G individually or in combination. Testing for
synergistic effects of wireless radiation and toxic chemicals has also not been
attempted. Despite a virtual research vacuum on 5G high frequency radiation,
federal and state legislation is being introduced and quickly approved to ensure the
rapid deployment of this technology by removing local jurisdiction and limiting
fees for cities and counties to use the public right of way. (32)
Sensitive Human Populations in Both
Pesticides appear more toxic to some people who do not have the metabolic
pathways to transform and excrete them. For organochlorine pesticides such as
DDT and Lindane it has been shown that there are genetic variations in human
cytochrome P450 metabolic systems which break down these pesticides, causing
increased risk of disease. (Docea 2017) Those pesticides workers with
paranoxonase genetic polymorphism, with a genetic inability to metabolize
pesticides, suffer chronic toxicity exhibited by nausea, dizziness, headaches,
fatigue and gait disturbance. Symptoms in those individuals with multiple chemical
sensitivity are similar. (Lee 2003) (Rossi 2018)
Wireless radiofrequency radiation is observed to cause non-specific symptoms
of headaches, dizziness, insomnia, nausea, irritability, depression and heart
palpitations in those who are electrosensitive. This was first reported by NASA in
military personnel working on radar and was called “microwave illness”. (NASA
1981) Although some studies claim this could be a psychologic condition,
researchers have identified a high correlation of symptoms to inflammatory and
other biomarkers which can aid the diagnosis. Classic symptoms of
electrosensitivity also occur in a high number of those living near cell towers and
when a cell tower is removed, symptoms resolve (Santini 2002, Navarro 2003,
Shinjyo 2014). Belpomme (2015) conducted a large clinical study and found
laboratory biomarkers that connect multiple chemical sensitivity to
electrosensitivity. It also has been noted that having these conditions causes
predictable isolation and fear which can lead to neuropsychiatric symptoms. (41)
“Doubt is our product since it is the best means of competing
with the “body of fact” that exists in the minds of the general
public. It is also the means of establishing a controversy.” (22)
Tobacco executive, from Doubt is Their Product, David Michaels
Industry Deception
Pesticides have been well protected by the industry that created them. An
investigation of over 20,000 documents including internal scientific studies,
meeting minutes and memos from federal regulatory agencies and manufacturers
was led by the Center for Media and Democracy and the Bioscience Research
Project resulting in “The Poison Papers” of 2018. (46) Concealment, political
manipulation, cover-up and collusion were found, along with suppression of
fraudulent independent research and secrecy of the toxic effects of chemicals and
pesticides.
Wireless telecommunications have been regulated by the Federal Communications
Commission (FCC) since the 1996 Telecommunications Act was passed. The
Environmental Protection Agency was relieved of their oversight duty of
radiofrequency radiation just prior to that. This1996 Act assumed, even before
testing, that there were no health or environmental effects of this radiation. It is
specified in the law that health and environmental effects cannot be used as an
argument to deny cell tower placement. This has hampered attempts to monitor or
identify health effects in the United States. Harvard’s Center for Ethics
investigation of the wireless industry, written by Norm Alster, resulted in a
publication called “Captured Agency: How the Federal Communications Industry
is Dominated by the Industries it Presumably Regulates”. (47) Highlighted is
industries exorbitant lobbying influence to the tune of about $400 million a year
according to the Center for Responsive Politics. A revolving door in Washington
was also noted with telecom industry executives filling the critical “independent”
government positions.
In her excellent book, “Disconnect”, Dr. Devra Davis documents industry
manipulation along with discrediting of scientists who have identified and
published literature on the adverse health effects of wireless radiation. (48)
Our Fate is That of Nature
We are just beginning to understand the fragile biologic complexities of the Earth’s
living creatures as we simultaneously document natures decline under the
dismissing hand of mankind. Many have warned that our fate will follow that of
nature. The expansion of wireless technologies for human convenience will require
more cell towers on every street corner. This will threaten natural ecosystems in
favor of immersive and invasive technology which is contributing to both negative
environmental, physical and mental health effects, especially on our youth. Instead
of increasing the number of cell towers, we need to be removing cell towers near
schools, homes, businesses and hospitals as well as in wildlife areas.
Safer Secure Alternatives: Fiberoptic, Cable and Landlines
The internet has become a necessity to most people. It can be provided in a safer
manner to reduce EMR exposure. Alternatives such as fiberopic networks and
cable exist that are faster, more fire resistant, use less energy and are cheaper in the
long run. (49) Traditional copper landlines are reliable in emergencies, cheap,
already built and connect everyone without risk. Why remove them? We can have
the benefits of faster, dependable and more private communications without
compromising public or environmental health.
Recommendations by Biologists and Scientists in a 2010 Report by the
Ministry of Environment and Forests in India to Protect Wildlife from EMR
(paraphrased) (MOE 2010)
1. Electromagnetic radiation (EMR) should be recognized as a pollutant
2. Create laws to protect urban flora and fauna from EMR
3. Create protected areas with no cell towers
4. Require bold signs on the dangers of radiation to be displayed on all cell tower structures.
5. Perform regular independent auditing of EMR/RF in urban localities-schools, hospitals,
residential, recreational and ecologically sensitive areas.
6. Require blinking red lights on cell towers to protect birds at night
7. Create laws to enable removal of existing problematic mobile towers to protect human or
environmental health
8. Require ecological assessment and review of sites identified for installing towers before
their installation in wildlife, ecologically sensitive or conservational important areas.
9. Strictly control of installation of mobile towers near wildlife protected areas, breeding
areas, bee colonies, zoos, and identify with scientific studies appropriate distances from
tower structures as part of pre installation review
10. The locations of cell phone towers and other EMF radiating towers along with their
frequencies should be made available on public domain. This information would help in
monitoring the population of birds and bees in and around the mobile towers and also in
and/or around wildlife protected areas.
11. Public consultation to be made mandatory before installation of cell phones towers in any
area. The Forest Department should be consulted before installation of cell phone towers.
The distance at which these towers should be installed should be studied case by case
basis.
12. The government should educate the public about the dangers of EMR and need for
precaution, placing signs in wildlife areas and zoos.
13. To prevent overlapping high radiations fields, new towers should not be permitted within
a radius of one kilometer of existing towers.
14. If new towers must be built, construct them to be above 80 ft and below 199 ft. tall to
avoid the requirement for aviation safety lighting. Construct un-guyed towers with
platforms that will accommodate possible future co-locations and build them at existing
‘antenna farms’, away from areas of high migratory bird traffic, wetlands and other
known bird areas.
Abundance of Life and Diversity or a Wireless Silent Spring?
Natures communication systems evolved using minute electromagnetic signals in
tune with the Earth and each other. They are being overwhelmed now with
manmade artificial electromagnetic radiation, that in combination with other well
established environmental threats spells disaster. Rachel Carson called for humans
to “act responsibly, carefully, and as stewards of the living earth.” Science and
observation is warning us that a thoughtful approach to all of man-kinds activities
is imperative, to favor the protection of biodiversity over profit, innovation or
convenience. We need to take a lesson from nature that acts slowly and
deliberately to create a healthy balance. Rapid shifts in technology are changing
our social structure and separating us from reality, each other and the natural
world. There are no limits to “disruptive” 21st century wireless technology nor any
meaningful safeguards. If we don’t slow down and think about the risks as well as
the benefits of high tech, will it quietly lead us to a wireless silent spring and then
to a silent Earth?
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