I am a concerned Indigenous American, Creek Nation, and a Board Director of the Community and Friends of …

I am a concerned Indigenous American, Creek Nation, and a Board Director of the Community and Friends of Seattle-Tacoma Pet Cemetery, a 501(c)(3) nonprofit. I submit these comments as an individual, not on behalf of the organization. I am a community member and advocate who is directly affected by a 100-foot industrial AT&T cell tower sited in a historic human and pet cemetery, and I write from firsthand experience. I have followed the permitting and legal record closely. The situation. The historic Seattle-Tacoma Pet Cemetery est. 1950 on Kent's West Hill is located in unincorporated South King County, Kent, Washington, in a community of color, immigrants, refugees, and low-income households. Humans, pets, K-9 officers, and service animals are buried here, some as whole families. Many cultural traditions exist here. In Indigenous cultures and spiritual traditions, animals are regarded as equally important as humans, deserving of the same dignity, honor, and respect in life and death. I hold that humans and animals call for the same and equal respect in life and death. In 2020, during the COVID-19 pandemic, Crown Castle installed a 100-foot industrial AT&T cell tower inside active Burial Block 13 with graves and mourners and 115 feet from neighboring homes in opposition to cemetery patrons, neighbors, and community members at large. It was installed in the wrong zone without a conditional use permit, in violation of King County Code and Washington State cemetery law. Additionally, Crown Castle did not disclose the human burials or the cemetery's historic significance on its permit application, and the project was pushed through the King County Department of Permitting and Environmental Review without addressing them. I have opposed its placement and operation since 2019. Why this matters to the issues before the Federal Communications Commission (FCC). The FCC is open to public comments for Cell Phone and Wireless Radio Frequency Radiation (RF) Health Effects and other Non-ionizing Electro Magnetic Frequency (EMF). I am talking about RF in this comment because that is the issue in the situation. The FCC's standards are the primary protection communities have against radio frequency radiation (RF) exposure. Under federal law, local governments generally cannot deny a cell tower based on RF health effects when it meets FCC limits. However, it is my understanding that communities can raise health concerns alongside other legitimate issues, such as zoning, permitting requirements, human remains, historic significance, etc. Our cemetery case involves all of these concerns. We should have the right to raise RF health concerns independently, without having to rely on other grounds for objection. If the FCC's standards are outdated, communities have limited recourse to protect residents, mourners, and their loved ones from potential RF exposure risks. Changes since 1996. The limits predate smartphones, small cells, etc., and constant connectivity. Towers now stand close to where people live and grieve, and people spend long periods near them. I ask the Commission to evaluate whether 1996 limits account for the ways that cell phones, cell towers, and the like are used and installed today including but not limited to chronic, daily, close-range RF exposure. Children and vulnerable people. Children live in the homes near this tower and visit the cemetery with their families. The record includes research showing children absorb more RF energy than adults (e.g., Fernández et al., 2018, Environmental Research). I ask the Commission to address children, pregnancy, and medically vulnerable people specifically. Long-term and non-cancer effects. The Commission should examine long-term, low-level exposure and non-cancer effects, including neurological, reproductive, and developmental effects, oxidative stress, and DNA damage, rather than relying on short-term heating thresholds. Animals and the environment. Pets, K-9 officers, and service animals are buried here, and wildlife lives on the grounds. The FCC has no wildlife-specific exposure limits. I ask the Commission to consider the research on effects on animals, insects, birds, and plants (e.g., Levitt, Lai & Manville, 2022, Reviews on Environmental Health, Parts 1–3). Testing and compliance. I ask the Commission to require independent, post-installation RF testing with public results that are easily accessible, so communities can verify compliance themselves at any time. There should be no barriers here. Why this is also a sacred space issue. Cemeteries are sacred regardless of a visitor's religion, meant to offer peace and tranquility, and dedicated in perpetuity to honor, remembrance, and love. A 100-foot industrial AT&T cell tower this close to graves and mourners intrudes on that purpose and raises serious concerns about exposure and potential harm to people and animals. My requests: • Update RF exposure limits based on a comprehensive review of current science, including but not limited to long-term, cumulative, and non-thermal effects, with specific protections for children, pregnancy, and vulnerable people. • Establish wildlife and environmental exposure standards, make them publicly accessible, and enforce them. • Modernize compliance testing and require public, independent post-installation testing. • Require easily accessible public records of tower locations, measurements, compliance, and complaints. • Adopt protective siting policies for sensitive places such as homes, schools, and cemeteries, and require disclosure of burial grounds and historic sites when towers are proposed. • Provide free advocates for the public to use to educate and support them in fighting for RF safety when necessary. • Stop giving away local control in cell tower permitting. Allow local jurisdiction and the public to decide if a cell tower siting plan is legal and appropriate and disallow it when necessary. • Support the retraction of permits when a cell tower or antennae modification application provides false information or omits information that is required for a complete application for consideration. I am not against cell towers. I support responsible telecommunications infrastructure and advocate for the safe, lawful, legal, ethical, and appropriate placement of cell towers. Not here. Not in an active, historic cemetery. Not among our beloved dead and those who come to mourn them. Thank you.