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Testimony of Timothy Cooper (Stop the Tower Coalition) before the National Capital Planning CommissionMarch 15, 2001STOP THE TOWER COALITION Testimony of Timothy Cooper, president Introduction The Stop the Tower Coalition would like to take this opportunity to express its appreciation to the National Capital Planning Commission for holding these hearings and most especially for including guidelines in the Comprehensive Plan on electro-magnetic radiation and antennas. The question of how best to deal with and manage the unprecedented buildup in antennas and antenna towers, not only in the District of Columbia, but also around the country, will have enormous implications for decades to come. We are therefore particularly gratified that the Comprehensive Plan has adopted the "prudent avoidance" principle with regard to the possible health implications of electromagnetic radiation. The wisdom of following this principle, we believe, will become increasingly apparent as the years pass and the harmful effects of amplified levels of electro-magnetic radiation become more and more apparent. Health Effects of Electro-Magnetic Radiation While it may be that currently there is no consensus in the medical community about the effects of a-thermal non-ionizing radiation on DNA structure, some studies have in fact demonstrated a casual link between chronic exposure to low levels of electro-magnetic radiation and DNA damage. Dr. Henry Lai, among others, maintains that long-term exposure to low levels of a-thermal non-ionizing radiation—the kind that is emitted from broadcast towers and cell towers-- is as damaging to DNA as short term exposure to high levels of radiation. For your review, I am enclosing a survey of reported biological effects from radio frequency radiation published by SAGE Associates, which includes reference to one of Dr. Lai's studies on the increase in DNA single and double strand streaks from RFR exposure. It also records various studies that have determined that as little as 0.16 uW/cm2 have adversely affected motor function, memory and attention of school children and changes in the immune system of individuals at levels equal to 30 – 50 uW/cm2. These levels are far below the current FCC standards of 200 uW/cm2. Indeed, the US has one of the high standards in the world, compared with such countries as Switzerland, Poland, Italy and Russia which have set their maximum standard at 10 uW/cm2. Precautionary Principle The Stop the Tower Coalition subscribes to the precautionary principles set forth at the Salzburg International Conference on Cell Tower Siting in Salzburg, Austria last June. It recommended that the siting of base stations should follow a protocol which incorporated the following: Advance information and active public involvement Inspection of alternative locations for sitings Protection of health and the public's well-being Considerations on conservation of land and townscapes Computation and measure of exposures Considerations on existing sources of HF-EMF exposure Inspection and monitoring after installation. The protocol also recommends the importance of exploiting all technical possibilities to ensure exposure is as low as achievable (ALATA-principle) and that new stations are planned to guarantee that the exposure at places where people spend longer periods of time be as low as possible. We believe that it is incumbent on this generation of leaders to be especially cautious about the possibility long-term health effects from electro-magnetic radiation, especially in light of the decades delay in determining the casual link between tobacco and cancer and lead gasoline and poor health. Electro-magnetic radiation is a particularly odious form of new pollutant because it is both invisible and odorless. Moreover, no one can hide from it. It is everywhere. Recommendations The Stop the Tower Coalition would like to make the following comments on the provisions of the Comprehensive Plan with regard to antennas and electro-magnetic radiation: First, we would recommend that rather than arrange for as noted in the
Comprehensive Plan the "joint-use of antennas and consolidating
antennas at one location (e.g., antenna farms) where possible", we
urge the Commission to promote cooperative use of existing antennas, or
shared antennas Second, while we recognize that the FCC has established guidelines for the construction of new cell antennas that serve the economic interests of the provider and promotes competition within the industry, we are not certain that it serves the public interest. The excess redundancy of antennas to create business competition at the expense of significantly increasing levels of electro-magnetic radiation pollution is certainly questionable. The promotion of business competition without regard to public health consequences will in the end only be a Prryhic victory for Congress. The public interest should come first. Third, we would urge the Commission to require applicants for antennas to carry out actual testing of field strengths of existing antennas in any proposed location and to compare those levels with existing FCC standards. We believe that while the FCC standards are too high compared with other countries, at the very least the current FCC standards should be observed. Unfortunately, the FCC is in no position to hold the industry accountable for any violations in standards. This is simply unacceptable. Antenna builders should be made to demonstrate that the cumulative effects of the existing antenna towers and any proposed antennas should conform to federal standards. This analysis should be carried out by objective third-parties certified to make such measurements. The sad fact is that the FCC cannot enforce and does not enforce its own standards, leaving the entire US population at risk. This should be viewed as inadequate In closing, we would again like to thank the Commission for including guidelines on electro-magnetic radiation and antennas. You have made a significant step forward in protecting the interests of the public.
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