26110083168
https://www.fcc.gov/ecfs/filing/26110083168

Public Comment to the Federal Communications Commission Re: ET Docket No. 13-84 — Reassessment of FCC Radiofrequency Exposure Limits and Policies I am submitting this comment as a concerned resident and parent regarding the serious imbalance between federal telecommunications policy, public health protections, and the rights of local communities to determine whether wireless telecommunications infrastructure should be constructed near their homes and schools. The Telecommunications Act of 1996 fundamentally altered the ability of local governments to protect their communities from unwanted wireless infrastructure. Under Section 704, codified at 47 U.S.C. § 332(c)(7)(B)(iv), local governments are prohibited from regulating the placement, construction, or modification of wireless facilities based on the environmental effects of radiofrequency emissions when those facilities comply with FCC regulations. For nearly three decades, this restriction has placed residential communities in an extraordinarily difficult position. Residents may express concerns about long-term RF exposure, proximity to children, cumulative exposure from multiple installations, or the adequacy of existing safety standards, yet their elected local officials are severely restricted in their ability to consider those concerns when deciding whether to approve a tower. In practical terms, federal law has deprived communities of meaningful local authority over one of the very issues that matters most to them: whether continuous, involuntary RF exposure near their homes and schools presents an acceptable risk. As a resident in a suburban neighborhood marketed to buyers as a "healthy living" community, I have seen the number of cell towers near my home grow from approximately 40 towers four years ago, to over 100 towers currently. This includes three currently in progress, which were forced through administrative approvals without opportunity for public notifications and public hearing. Wireless communications development companies are abusing the liberal policies established under the Federal Telecommunications Act, forcing tower construction upon residential neighborhoods, against the will of the local community. Not only does this deprive the community of an opportunity to voice opposition, but it also takes away freedom of choice for exposure to something that the American Cancer Society cannot definitively declare "safe" or that it does not cause cancer, due to lack of long term studies to substantiate that it does not cause cancer. Further, the limited studies that exist, are based upon estimated exposure levels and not actual exposure levels, and are limited to exposure from one towers RF emissions, rather than considering the collective level of exposure from all sources. If someone already has 5 towers within 1,000 yards from their home, adding an additional tower is not necessarily within tolerable safety limits because the estimated exposure from the new tower does not consider the cumulative levels emitted from all towers and sources. Because populated areas have limited spaces to erect these towers, the wireless communication companies are aggressively targeting unincorporated areas, public utility easements, and even school grounds. Many school districts in Austin TX are entering into lease agreements with wireless communications companies, erecting towers on top of schools, which poses a risk to student health. My own children have a cell tower right on top of their middle school. I personally have a BRCA mutation and I am more susceptible to DNA damage from RF. I may have passed my gene to my children. It is wrong that there is RF exposure continually forced upon us in our own backyard, and we should have the right to refuse. There should be a moratorium on new cell tower construction in residential areas and school zones until such time that there is long term safety data definitively proving that it is completely safe with no risk. I recognize that reliable wireless communication is important. However, the public's need for connectivity should not automatically outweigh the rights of residents, parents, and communities to participate meaningfully in decisions affecting their immediate living environments. I am particularly concerned about the placement of wireless infrastructure on or near school properties. Schools should be places where children's health, safety, and welfare are the foremost considerations. Yet school districts and telecommunications companies may enter into arrangements allowing wireless infrastructure on educational property, potentially generating revenue while exposing surrounding families and students to an installation they may have little practical ability to oppose on RF health grounds. The fact that a telecommunications facility complies with existing FCC exposure limits should not automatically end the public health discussion, especially when those limits themselves are the subject of ongoing scientific and regulatory scrutiny. The 2021 decision in Environmental Health Trust v. FCC illustrates why public confidence cannot rest solely on the assertion that existing standards are adequate. The court found deficiencies in the FCC's explanation for retaining its RF exposure limits in light of issues raised in the administrative record, including noncancer health effects, children's health, and long-term exposure. Communities should not be legally prevented from considering potential RF health impacts while the federal agency responsible for establishing the governing exposure limits is still addressing questions concerning the adequacy of those standards. This creates a fundamental accountability problem: federal law restricts local governments from considering RF health concerns, while residents must rely on federal standards that they have no meaningful ability to challenge through the local tower approval process. I urge the FCC to take the following actions: Conduct a comprehensive, transparent, and independent reassessment of RF exposure standards, including long-term exposure, potential nonthermal biological effects, children's health, and cumulative exposure from multiple wireless installations. Give particular consideration to wireless facilities located near residences, schools, childcare facilities, and other locations where children and families spend substantial amounts of time. Require meaningful public disclosure of proposed antenna configurations, operating frequencies, projected RF exposure, and cumulative exposure from existing nearby facilities before new installations are approved. Establish stronger public participation and independent exposure-assessment procedures for wireless infrastructure proposed near residential neighborhoods and schools. Recommend that Congress revisit the preemption provisions of the Telecommunications Act of 1996 so that local governments can meaningfully consider RF exposure and public health concerns when evaluating proposed wireless facilities. Ensure that the burden of demonstrating compliance with scientifically justified safety standards rests with wireless infrastructure operators, rather than requiring individual residents to prove harm after a facility has already been constructed. I am not advocating for the elimination of wireless communication. I am advocating for a regulatory framework that recognizes that technological advancement and public health protections are not mutually exclusive. The wireless infrastructure landscape has changed dramatically since 1996. The number, density, configuration, and proximity of wireless installations to homes and schools have evolved, and federal oversight must account for those changes. No community should be forced to accept a wireless installation near its homes or schools without meaningful consideration of health and safety concerns simply because federal law prevents local officials from evaluating those concerns. The FCC has an obligation to ensure that the standards relied upon to override local decision-making are supported by a thorough, transparent, and current scientific assessment. I respectfully urge the Commission to address these concerns and to recognize the consequences that federal preemption has had on residential communities and families across the country. Thank you for considering my comment.