Testimony for Montgomery County Planning Board Item 5 - MR2020013: PSSM at Fire Station 16
Re: the proposal for a 3rd cell tower, a 'Public Safety' tower at Blair High School in Silver Spring, which will be considered tomorrow (Thurs.) at a 10 a.m. meeting of the Montgomery County Planning Board. For those interested in attending the meeting--an extremely rare opportunity to have input on this decision before it's made, and one may sign up on the day of to speak-- the meeting is at: 8787 Georgia Ave, Silver Spring, MD 20910 at 10 AM.
As a parent of a student in MCPS and as a volunteer who has worked in schools across the county, I’ve been alarmed to see cell towers directly beside schools. In March 2019 in California, Sprint turned off a cell tower beside Weston Elementary School after 4 students and 3 teachers were diagnosed with cancer since 2016 (1).
Recently, I have been stunned not only to see 2 major cell towers with a combination of over 65 antennas close to Blair High School, but to learn of a proposed 3rd cell tower to be placed 50 feet from the playing fields of Blair and within 300 feet of homes and a daycare. I ask that you oppose the application for this 199 foot macro tower. While the tower serves an understandable purpose of public safety, I urge you to closely examine alternative sites that are not so close to schools and homes. Reasons to oppose this application follow:
1) Alternative Location is Available.
Cell towers of this magnitude should not be put close to sensitive locations including schools and a daycare center.(2, 3) Fortunately, a preferable site is available in an existing radio tower on a nearby public golf course, which could be modified to the specifications required for a macro tower with the County's 7 antennas to enhance public safety communications. A new tower could be put adjacent to the existing one if needed. The golf course location would be farther from the dense concentration of students and homes.
2) Public input is needed and adjacent property owners and stakeholders have not been sufficiently notified about this hearing.
Public input is essential in consenting to the placement of a macro tower that affects the visual landscape, property values, the health of residents, attendance at schools and willingness to visit nearby businesses. MCPS and the Board of Education have not approved a cell tower on school property since 2009; their approval for this 3rd tower near Blair is not required because of a loophole in the application process.
Students, teachers and parents from Blair High School and the daycare center near the fire station deserve to be notified about the public hearing for such a tower as it may affect the choices they make about attending school and workplaces in these locations; owners of nearby buildings should also be informed as the presence of this type of cell tower affects property values.(4, 5)
If a macro tower is approved in this location without sufficient notice for the public hearing, it will cause a loss of faith in the governing process and in the sense that the will of residents matters. In addition, too few firefighters and first responders have actually been informed about the effects of such cell towers so close to fire stations.
In California in 2015, a 25-year veteran fire Captain described the neurological damage of firefighters living by cell towers and the firefighters union successfully opposed the construction of cell towers on fire station property based on health effects including headaches, inability to sleep and cognitive impairment. (6) The International Association of Fire Fighters opposes the use of fire stations as base stations for cell towers and antennas due to the negative health impacts that firefighters have experienced, which are detailed on their website (7): https://www.iaff.org/cell-tower-radiation/
3) Equity: the placement of a 3rd cell tower at Blair seems unfair to students experiencing such a dense concentration of cell towers and RF (radio frequency) radiation in close proximity.
While cell towers have no business on school grounds and students should not be treated as guinea pigs, it is especially disturbing that over 80% of cell towers in MCPS schools are at schools where at least one-third of students are eligible for free and reduced price meals (FARMs) (8). So again in this application, the County would be placing a 3rd cell tower near Blair High School, with a student body with an approximately 50% ever-FARMS rate.
All students should have a safe space to play and watch sports in green space outdoors, such as in the ball fields beside the fire station, but that is also near the proposed site of the macro tower. Every part of the school campus is intended for student use. The close proximity of even the existing cell tower atop the fire station with 12 antennas on it is concerning in terms of the exposure of these students to RF radiation emissions.
4) Health impact. Students, teachers and residents would bear the burden of whatever health impact a nearby macro tower would have; they would be forced into accepting liability for decisions they may not have had the chance to weigh in on.
I am most disturbed by the proximity of this tower to students in the fields at Blair and at the nearby daycare center. The dense concentration of cell antennas emitting wireless RF radiation has a significant influence on young people at critical developmental stages, which may result in more lasting damage as they absorb this radiation. The growing body of evidence of the carcinogenic effects of exposure to wireless radiation may dissuade parents from sending their children to Blair and the nearby daycare center.
An extensive body of 100’s of scientific research articles documents the carcinogenic effects of radio-frequency (RF) radiation (9, 10). A Ramazzini Institute study in 2018 (11, 12), conducted below FCC exposure levels, documented the same type of cancerous brain glioma tumors and heart schwannoma tumors as were documented in the National Toxicology Program studies in the U.S. in 2018 (13, 14, 15, 16).
Despite a few of the 100s of studies being discounted, the vast majority point toward the carcinogenic role of RF radiation from cell towers and cell phones. While early studies about the cancer-causing role of cigarette smoking and asbestos were discounted, the body of evidence over time substantiated the carcinogenic role. It appears that those in the insurance industry have known for years about the potential carcinogenic effects of RF radiation from cell phones and towers. Lloyds of London was the last global insurer to exit the RF exposure market in 2015 and other carriers have refused for years to insure the telecommunications companies from claims based on the health impacts of wireless radiation from cell phones and towers.
Government entities may be absolved from liability as well. So in this current situation where the Planning Board is deciding about the placement of a macro tower in such close proximity to fire fighters, students, teachers and residents, residents who have barely weighed in on the issue of placing a 3rd tower near Blair HS may end up bearing the burden of whatever health impacts such a tower would cause to themselves and the bodies of their children.
5) A 'public safety' macro tower is likely to become a commercial tower over time, loaded with multiple commercial antennas. Applications for further antenna placement may be rubber stamped without notice to the public and opportunity for further input, and without offering readings of RF radiation output--in other words, with insufficient oversight by any governing agency to govern the impact of the tower emissions and operation on nearby students and residents.
Examples of Montgomery County's lack of oversight over existing wireless transmission facilities includes the inaction about the high radiation readings that 33 antennas are giving on top of the Park Ritchie residential building providing affordable housing in Takoma Park, and the inability of the county to remove an incorrectly placed, non-permitted cell tower in 2011 at 7800 Brickyard Rd. in Potomac, which remains in place.(17, 18)
The Blair High School community already has to deal with a cell tower on top of the fire station with 12 commercial antennas on it. Antennas have been continually added to this tower, and no hearing process is provided to the public to weigh in on these applications. On the other side of Blair, where a commercial tower is within 230 feet of the track and field where students and nearby residents exercise daily, a new 10 foot height extension and 8 additional antennas were recently approved, bringing the number of antennas for this tower to 55.
In addition to the regular expansion of the existing 2 towers, the proposed macro tower of 199 feet may have dozens of commercial wireless antennas added after it is constructed. The County's construction of the tower offers the loophole of allowing wireless companies to avoid the public hearing special exception/conditional use process with an objective hearing examiner, a process required for new macro telecommunication towers in Montgomery County. After a tower is built, it becomes a support structure that antennas can be attached to without public notice. If this were a privately owned tower, they could refuse to place additional antennas on it. But the County has not been willing to commit in writing to prohibiting placing additional private commercial antennas on the tower.
So in an application for a 'public safety' macro tower at a sensitive location, in proximity to schools and first responders, it should be acknowledged that this will likewise, in the long term, be a commercial tower serving commercial uses rather than serving foremost the needs of the students and residents. Their input will be avoided in this process.
I ask you to care about the students in this area as though they were your own children and to care about the firefighters as though they were your family members. I have a relative and friends who graduated from Blair; I have friends whose children attend Blair and friends who have children bound for Blair. Blair High School boasts an excellent magnet program that attracts students from across the county. It has built up an excellent educational reputation. At the same time, parents care about their children's health and the perception of an unhealthy environment for students will discourage parents from sending their students to Blair.
With two cell towers already in the Blair High School area, there seems little reason to add a 3rd tower so close to schools and homes, particularly given the existence of a preferable location for the public safety macro tower, at a golf course close by. Thank you for your consideration.
Notes
(2). Pearce, J.M. "Limiting liability with positioning to minimize negative health effects of cellular phone towers." Recommends locating towers at least 1,600 feet from schools to reduce liability. Environmental Research Vol. 181, Feb. 2020.
(3). Meo, Sultan Ayoub; Almahmoud, Mohammed; Alsultan, Qasem et al. "Mobile Phone Base Station Tower Settings Adjacent to School Buildings: Impact on Students' Cognitive Health." American Journal of Men's Health. Dec. 7, 2018.
(6) PMG, “Firefighters Living Next to Cell Towers Suffer Neurological Damage.” Includes link to testimony by David Gillotte of L.A. County Firefighters
(Scientists4wiredtech) 26 July 2018.
(7) International Association of Fire Fighters, "Cell Tower Radiation Health Effects." 2020.
(9) Grassroots Environmental Education, “Current Issues: Cell Phones and Wireless.” Compiles selected scientific articles on wireless radiation (Port Washington, NY: Grassroots Environmental Education) 2019. http://grassrootsinfo.org/emergingscience.php
(12) Falcioni, L., L.Bua, E.Tibaldi et al. “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 GSM base station environmental emission.” Environmental Research Vol. 165: pp. 496-503 (Aug. 2018). (Available from ScienceDirect/Elsevier).
https://www.sciencedirect.com/science/article/pii/S0013935118300367?via%3Dihub
(13) National Institute of Health (NIH), National Institute of Environmental Health Sciences (NIEHS). “Cell Phone Radio Frequency Radiation.” National Toxicology Program, which produced the mentioned studies, is at the NIEHS of the NIH. Oct. 2019.
https://www.niehs.nih.gov/health/topics/agents/cellphones/index.cfm
(15) National Toxicology Program mice studies. “NTP Technical Report on the Toxicology and Carcinogenesis Studies in B6C3F1/N Mice Exposed to Whole-Body Radio Frequency Radiation at a Frequency (1900 MHz) and Modulations (GSM and CDMA) Used by Cell Phones.” (Research Triangle Park, NC: National Toxicology Program) Nov. 2018.
(16) Melnick, Ronald L. “Commentary on the utility of the National Toxicology Program study on cell phone radiofrequency radiation data for assessing human health risks despite unfounded criticisms aimed at minimizing the findings of adverse health effects.” Environmental Research Vol. 168: pp. 1-6 (Jan. 2019). (Available from ScienceDirect/Elsevier).
(18) “Family Gets Cell Tower in Front Yard Despite Application Mistake! Montgomery County Brickyard Rd.” YouTube video, Montgomery County Council hearing re: ZTA 18-11, fall 2018. Length: 13:30, see 0:00 to 3:42. Montgomery County Citizens, 3 Oct. 2018.
