HomeMy WebLinkAboutTB Correspondence 2025CORRESPONDENCE LISTING
January 27, 2025
Please review the following correspondence and indicate, by placing your initials in the right-hand column
adjacent to the correspondence, that you wish to receive a copy. We can forward a copy to you via e-mail or
make a hard copy. Please indicate your preference next to your name at the bottom of this form.
Correspondence – Item Please place your
initials here if you wish
to receive a copy
Retention: Permanent
1. DEC Flood Insurance Study and Mapping
2.
3.
4.
Retention: Six-Year
1.
2.
1.
2.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Division of Water. Bureau of Flood Protection and Dam Safety
625 Broadway, Albany. New York 12233-3504
P: (518) 402-81851 F: (518) 402-9029
www.dec.ny.gov
January 8, 2025
Rod Howe, Town Supervisor
215 North Tioga St
Ithaca, NY 14850
Re; National Flood Insurance Program
Flood Insurance Study & Mapping
Tompkins County
Dear Supervisor Howe:
In reference to the Town of Ithaca and its participation in the National Flood Insurance
Program (NFIP), as the State Coordinating Agency for the National Flood Insurance
Program, we would like to ensure that your community maintains continued program
eligibility.
An updated Flood Insurance Study (FIS) and Flood Insurance Rate Maps (FIRMs)
establishing base flood elevations (BFEs) for the Town of Ithaca have recently been
completed by the Federal Emergency Management Agency (FEMA). To maintain
eligibility In the NFIP, you will need to adopt these new regulatory products into the
community's floodplain management regulations to meet the standards of Section
60.3(d) of the NFIP regulations (44 CFR) by June 18, 2025.
To avoid any possibility of program suspension, please submit a draft local law for
review by March 20, 2025, so that we may review to ensure it meets all necessary NFIP
requirements. Please allow two (2) to three (3) weeks for us to review your local law.
Once we have reviewed the local law, we will inform you of our findings.
Failure to enact required regulations on time will result in program suspension. A
community that is suspended from the program faces the following sanctions:
1.
2.
3.
4.
5.
No resident will be able to purchase a federally backed flood insurance policy.
Existing flood insurance policies will not be renewed.
No Federal grants or loans for development may be made in identified flood
hazard areas under programs administered by Federal agencies such as HUD,
EPA, and SBA;
No Federal disaster assistance may be provided to repair insurable buildings
located in identified flood hazard areas for damage caused by a flood.
No Federal mortgage insurance or loan guarantees may be provided in identified
flood hazard areas, this includes policies written by FHA, VA, and others.
NEWYORK
STATE or
OPPORTUNITY
Department of
Environmental
Conservation
Jo meet this deadlinei the final local law should be passed and submitted by no later
than May 19, 2025, along with the New York State Department of State filing forms and
filing acknowledgementJetter.
If FEMA does not^have an approved local law one month prior to the map's effective
date, your comrh'unity will receive a letter indicating that your community is eligible for
suspension from the NFIP, which will occur on the map's effective date - should the law
not be enacted by that time.
We strongly recommend replacement of existing flbodplain management regulations by
repealing your existing local law and enacting the enclosed new model local law. The
enclosed model has been updated to include federal and state program changes made
since the adoption of your existing regulations. Please complete the enclosed model
local law per the instructions. Note that Section 3.2 has already been completed to
correctly reference the revised Flood Insurance Rate Map panel(s). However, you will
still need to provide the physical street address where the Flood Insurance Study and
map panels will be kept on-file for public access.
The new FIRM maps may be enforced as soon as your new local law is effective; you
should receive final maps prior to their effective date. The model local law reflects
minimum NFIP regulatory standards. We are also providing optional language that you
may wish to include in your law to increase overall resistance to flood damages.
Additionally, FEMA offers a program - the Community Rating System (CRS), that
provides discounts to all flood insurance policy holders in a community that goes
beyond the minimum NFIP requirements for floodplain management. For more
information on how to apply for the CRS, contact our office.
Please note that should the Town of Ithaca elect to designate another entity (e.g. the
Tompkins County Code Enforcement Office) to act as their Local Administrator, an
Intermunicipal Floodplain Management Agreement (see enclosure), or equivalent, will
need to be completed and reviewed by our office prior to approval by FEMA.
To summarize, the key dates in the map adoption process are as follows:
Letter of Final Determination
starting the legal Map Adoption
Process:
December 18, 2025 182 days prior to
effective date
Final Draft Local Law Submitted
to DEC for Review:March 20, 2025 90 days prior to
effective date
Deadline for the Local Law to be
adopted by the Community to
prevent suspension elialbllitv:
May 19, 2025 30 days prior to
effective date
Deadline for Local Law be
adopted by community and
approved by DEC & FEMA to
avoid suspension:
June 18, 2025 Effective date of
maps
FEMA Suspension Date if Local
Law is not adopted by community
and approved by DEC& FEMA:
June 19,2025 Suspension date
Should you have questions concerning adoption of this regulation or any of the included
requirements, please do not hesitate to contact me directly.
Sincerely,
Brad Wenskoski, CFM
Environmental Program Specialist II - Floodplain Management
Bureau of Flood Protection and Dam Safety, Division of Water
New York State Department of Environmental Conservation
625 Broadway, Albany, NY 12233-3504
P: (518) 402-8280J^F: (518)_^2-9029 | brad.wenskoski@dec. nv.qov
www.dec.nv.aov j III
Enclosures: FEMA Letter contain final map information
NYSDEC Local Law for Flood Damage Prevention and Instructions
Intermunicipal Floodplain Management Agreement
Optional Additional Language
Cc w/o enclosures:
Ecc:
Paulette Rosa, Clerk
Marty Moseley, Building Inspector
Kelli Higgins-Roche. P.E., CFM. NFIP Coordinator. NYSDEC
Brienna Wirley, NYSDEC Western NY Flood Hub
Marianne Luhrs, FEMA Region II
Tonya Evans, FEMA Region II
Federal Emergency Management Agency
Washington, D.C. 20472
December 18, 2024
CERTIFIED MAIL n
RETURN RECEIPT REQUESTED
The Honorable Rod Howe
Supervisor, Town of Ithaca
215 North Tioga Street
Ithaca, NY 14850
IN REPLY REFER TO:
19P
Community Name:,
Community No.:
Map Panels Affected:
Town of Ithaca,
Tompkins County, NY
360851■
See FIRM Index
Dear Supervisor Howe:
This is to notify you of the final flood hazard determination for Tompkins County, New York
(All Jurisdictions), in compliance with Title 44, Chapter I, Part 67, Section 67.11, Code of
Federal Regulations (CFR). This section requires that notice of final flood hazards shall be sent
to the Chief Executive Officer of the community, all individual appellants, and the State
Coordinating Agency, and shall be published in the Federal Register.
-The statutory 90-day appeal period that was initiated for your community when the Department
of Homeland Security's Federal Emergency Management Agency (FEMA) published a notice of
proposed flood hazard determinations for your community in the local newspaper has elapsed.
FEMA did not receive any appeals of the proposed flood hazard determinations or submittals
regarding the Preliminary Flood Insurance Study (FIS) report and Flood Insurance Rate Map
(FIRM) during that time.
Accordingly, the flood hazard determinations for your community are considered final. The
fmal notice for flood hazard determinations will be published in the Federal Register zs soon as
possible. The FIS report and FIRM for your community will become effective on June 18, 2025.
Before the effective date, we will send your community final printed copies of the FIS report and
FIRM. For insurance purposes, the community number and new suffix code for the panels being
revised are indicated on the FIRM and must be used for all new policies and renewals.
Because the-FIS report for your community has been completed, certain additional requirements
must be met under Section 1361 of the National Flood Insurance Act of 1968, as amended,
within 6 months from the date of this letter.
It must be emphasized that all the standards specified in 44 CFR Part 60.3(d) of the National
Flood Insurance Program (NFIP) regulations must be enacted in a legally enforceable document.
This, includes adoption of the current effective FIS report and FIRM to which the regulations
apply, and other modifications made by this map revision. Some of the standards should already
have been enacted by your community in order to establish initial eligibility in the NFIP. Your
community can meet any additional requirements by taking one of the following actions in.this
Paragraph of the NFIP regulations:
1. Amending existing regulations to incorporate any additional requirements of 44 CFR Part
60.3(d);
2. Adopting all the standards of 44 CFR Part 60.3(d) into one new, comprehensive set of
regulations; or
3. Showing evidence that regulations have previously been adopted that meet or exceed the
minimum requirements of 44 CFR Part 60.3(d).
Also, prior to the effective date, your community is required, as a condition of continued
eligibility in the NFIP, to adopt or show evidence of adoption of the floodplain management
regulations that meet the standards of 44 CFR Part 603(d) of the NFIP regulations by the
effective date of the FIRM. These standards are the minimum requirements and do not
supersede any State or local requirements of a more stringent nature.
Many states and communities have adopted building codes based on the International Codes (I-
Codes); the model I-Codes (2009 and more recent editions) contain flood provisions that either
meet or exceed the minimum requirements of the NFEP for buildings and structures. The model
codes also contain provisions, currently found in an appendix to the International Building Code,
that apply to other types of development and NFIP requirements. In these cases, communities
should request review by the NFIP State Coordinator to ensure that local floodplain management
regulations are coordinated (not duplicative or inconsistent) with the State or Local building
code. FEMA's resource, Reducing Flood Losses through the International Code: Coordinating
Building Codes and Floodplain Management Regulations, 5th Edition (2019), provides some
guidance on this subject and is available at https:/Avww.fema.gov/emergency-managers/risk-
management/building-science/building-codes/flood.
Communities that fail to enact the necessary floodplain management regulations will be
suspended from participation in the NFIP and subject to the prohibitions contained in Section
202(a) of the Flood Disaster Protection Act of 1973 (Public Law 93-234) as amended, and 44
CFR Part 59.24.
To assist your community in maintaining the FIRM, we have enclosed a Summary of Map
Actions (SOMA) to document previous Letters of Map Change (LOMC) actions (i.e., Letters of
Map Amendment, Letters of Map Revision) that will be affected when the FIRM panels
referenced above become effective. If no LOMCs were issued previously for your community,
you are re9eiving a SOMA for informational purposes only.
Once the FIS report and FIRM are printed and distributed, the digital files containing the flood
hazard data for the entire county can be provided for use in a computer mapping system. These
files can be used in conjunction with other thematic data for floodplain management purposes,
insurance requirements, and many other planning applications. Copies of the digital-files of the
FIRM panels may be obtained by calling our FEMA Mapping and Insurance eXchange (FMIX),
toll free, at (877) 336-2627 (877-FEMA MAP) or by visiting the Map Service Center at
httpsr/Avww.msc.fema.gov. In addition, your community may be eligible for additional credits .
under our Community Rating System if you implement your activities using digital
mapping files.
For assistance with your floodplain management ordinance or enacting the floodplain
management regulations, please contact Kelli Higgins-Roche, P.E., CFM, NFIP State
Coordinator for New York by telephone at (518) 402-8185 or by email at
floodpIain@dec.ny.gov. If you should require any additional information, we suggest that you
contact the Director, Mitigation Division of FEMA, Region 2 at michael.foley3@fema.dhs.gov
for assistance. If you have any questions conceming mapping issues in general or the enclosed
SOMA, please call our FMIX at-the telephone number shown above. Additional information and
resources you may find helpful regarding the NFIP, and floodplain management can be found on
our website at https://www.fema.gov/flood-maps. Copies of these documents may also be
obtained by calling our FMIX.
Sincerely,
Luis Rodriguez, P.E.
Engineering'and Modeling Division
Risk Management Directorate | Resilience
Enclosure: Final SOMA
cc: Community Map Repository
Marty Moseley, Director of Code Enforcement, Town of Ithaca
bcc: William McDonnell, Mitigation Division Director, FEMA Region 2
Michael Foley, P.E., Risk Analysis Branch Chief, FEMA Region 2
Kelli Higgins-Roche, P.E., CFM, State NFIP Coordinator, New York State Department
of Environmental Conservation (NYSDEC)
Brienna Wirley, CFM, Western NY Flood Hub Floodplain Management Coordinators,
NYSDEC Region 6-9
Tolga Yilmaz, ARC Region 2 Service Center Lead
Somendra Chakravorty, CFM, ARC Region 2 PPP Lead
FEDD File
Case File
January 2025 - Town of Ithaca
*Please notefor the purpose of the NYS Assessment for the CAP-SSSE Tiered State Framework, this is the current
Model Local Law for NYS Communities thatfall under the 44 CFR 60.3D requirements*
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
LOCAL LAW FOR FLOOD DAMAGE PREVENTION
INSTRUCTIONS
The attached MODEL LOCAL LAW is designed to comply with the floodplain management requirements of
the National Flood Insurance Program contained in 44 CFR 60.3 (b, c, & d). The Department of Environmental
Conservation (DEC) has included several optional administrative provisions in the MODEL LOCAL LAW
which are strongly recommended for proper administration. Any changes made to this MODEL should be
reviewed by the community's attorney and either the DEC or the Federal Emergency Management
Agency (FEMA) before enacting. DEC and FEMA must be provided a list of any changes to this model
at the time of filing.
Department of State Filing Forms - insert all required information. Blank Local Law Filing Forms, including
instructions and an online interactive version, can be found at https://dos.nv.gov/local-law-filing.
The following sections must be completed by the community:
Page 1, Sect. 1.1 - Insert legislative body and the name of the community twice.
Sect. 3.2 - If you are enacting this Local Law to comply with FEMA requirements associated with new commu-
nit>' or county Flood Insurance Rate Maps, the Department of Environmental Conservation will include in this
package a replacement Page 7 with the mapping information filled out. Simply insert the name of the commu-
nit>' in Section 3.1 and insert the location where the Flood Insurance Study and/or maps are on file. Other
wise, follow the instructions for Page 7, below .
Sect. 3.1 - Insert the name of the community.
Sect. 3.2 - Complete (1) through (5) as necessary, according to the documents your community has been fur
nished by the Federal Emergency Management Agency (FEMA). Cross out or delete any unused subsections. .
Documents you may have received are:
(a) Flood Insurance Study report~a brown or buff colored booklet, which contains technical data on
flooding in the community-;
(b) Flood Insurance Rate Map (FIRM)-a map in either an 11 "xl 7" flat or a Z-foId (road map style) for
mat. If the map consists of more than one panel, an index panel is usually included. The FIRM shows
locations of areas of special flood hazard in the community; and,
(c) Flood Boundary and Floodway Map (FBFM)—a Z-folded sheet that shows the location of floodways
in the community.
If your community received only a single FIRM map, fill in (1). The community number, a six digit number
whose first two digits are 36, is required and is found in the lower right corner of the FIRM. The community
number may also have a letter suffix, which should also be included. Also include the "effective date" shown
on the map.
If you received a FIRM map with more than one panel, fill in (2). Be sure to show the community number and
the panel numbers (e.g., 361540 0001-0025) and the letter suffix, if one is shown. Also include the "effective
date" shown on the index panel.
If you received a Flood Insurance Study report, fill in (3) with the community's name, name of your county(s)
as shown on the report and date.
1
If you received a single FBFM, fill in (4).
If your community received a FBFM with multiple panels, fill in (5) with data from the index sheet.
If you are unsure what documents were sent to you, contact the DEC Regional Coordinator for your county or
the DEC Central Office (listed on page iv).
Sect. 3.2 - Insert the physical street address where the Flood Insurance Study and maps are on file.
Sect. 3.5 - Insert the name of the community.
Sect. 3.6 - Insert the name of the community.
Sect, 4.1 - Insert the title of the individual responsible for administering the local law, such as the Director of
Planning, Building Inspector, Code Enforcement Officer, etc. May not be the same as Sect. 6.1(1).
Sect. 4.2-2 - Insert fee amount (if so desired) and community name.
Sect. 5,1-2 - Insert the name of the communit}'.
Sect. 5.1-3 - Insert the name of the community in the six blanks.
Sect. 6.1(1) - Insert the name of the appeals board (in many instances the Zoning Board of Appeals serves this
role). It may be necessary to create a 3-5 person board to fulfill these duties. In accordance with TownA^il-
lage/City Law, for floodplain management provisions integrated into zoning regulations, the appeals
board may neither be the TownA^illage/City Board, nor have any common members, nor be the same
body as named in Sect. 4.1.
Sect. 6.1(2) - Insert the name of the appeals board.
Sect. 6il(3) - Same as 6.1(2).
Sect. 6.1(4) - Same as 6.1 (2).
Sect. 6.1(5) - Same as 6.1 (2).
Page Following Section 6.0: Insert date of enactment, the names of the governing body, community and
county, and the date on which the law becomes effective.
Attachment "A" (4 pages) to this document provides a recommended "Floodplain Development Permit Appli
cation" form. This form or its equivalent must be used in conjunction with Section 4.2 of this model local law.
Attachment "B" (1 page) to this document provides a recommended "Certificate of Compliance for Develop
ment in a Special Flood Hazard Area." This form or its equivalent should be used in conjunction with Section
4.4-7 of this model local law.
Please contact one of the DEC Central Office Program Coordinators listed on page iv should you have
any questions about filling in the blanks or if you find any errors or omissions to these instructions, content,
or attachments.
Optional Language is provided should your community wish to enact additional requirements to increase the
level of safety. Note that many of these options result in points that can result in discounts on flood insurance
premiums within communities that participate in FEMA's Community Rating System. Contact DEC for infor
mation about the Community Rating System.
NOTE: This document must be adopted in a manner that is legally enforceable.
2
File the indicated number of certified copies with each of the offices listed below. Follow all
instructions and use the official filing form.
1. SECRETARY OF STATE (1 copy)
State Records and Law Bureau
Department of State
One Commerce Plaza
Albany, New York 12231
2. DEC CENTRAL OFFICE (1 convl"
NYS Department of Environmental Conservation
Floodplain Management Section '
Attn: Brad Wenskoski, CFM
625 Broadway, 4**^ Floor
Albany, NY 12233-3504
(518) 402-8185
^Please submit one copy of the "Local Law Acknowledgement" to the DEC Central Office upon
receipt from the Department of State. However, to expedite approval of your Local Law, please send
a copy of the Local Law to the DEC Central Office immediately upon passage, prior to receipt of the
"Local Law Acknowledgement." If your community is applying for participation in the NFIP, also include
the Enabling Resolution-and the NFIP Application.
New York State Department of Environmental Conservation
Bureau of Flood Protection and Dam Safety 625 Broadway, 4"^ Floor, Albany, NY 12233-3504 (518)402-8185
Floodplain Management Coordinators
Central Office Floodplain Management Coordinators: Main Number, 518-402-8185, Email: floodDlain@dec.ny.QOV
KelliHiggins-Roche, PE,CFM: 518-408-0340 NYS NFIP Coordinator kelli.higgins-roche@dec.nv.gov
Bailey SaNwyer, CFM: Lead for Regions 1-4 518-402-9148 Environmental Program Spec. 1
Brad Wenskoski, CFM: Lead for Regions 5 - 6 518-402-8280 Environmental Program Spec. 2
Victoria Agens: Floodplain Coordinator 518-402-8135 Environmental Program Spec. 1
Western NY Flood Hub Floodplain Management Coordinators, Assisting with Regions 6-9
Karis Manning, PE: 585-226-5445 Chief, Western Flood Hub
Brienna Wirley, CFM: Lead for Regions 7 - 9 585-226-5465 Environmental Program Spec. 2
Devin Prine; Floodplain Coordinator 585-226-5434 Environmental Program Spec. 1
Regional Floodplain Management Coordinators
bailev.sawver(S)dec.nv.gov
brad.wenskoski@dec.nv.gov
victoria.agens@dec.nv.gov
karis.mannlng@dec.nv.gov
brienna.wirlev@dec.nv.gov
devin.prine@dec.nv.gov
Region Counties Regional Office Address Floodplain Management Coordi
nator
1 Nassau & Suffolk NYS DEC Region 1
SUNY @ Stony Brook
50 Circle Road
Stony Brook, NY 11790
Eric Star {631)444-0423
RyanPorclello (631)444-0425
eric.star(®dec.nv.BOv
rvan.DorciellofSdec.nv.BOV
2 Bronx, Kings, New York, Queens & Richmond
NYS DEC Region 2
1 Hunters Point Plaza
4740 21st Street
Long Island City, NY 11101
Jean Occidental
(718)482-4935
iean.occidentaliSdec.nv.BOv
3 South Westchester, Rockland
NYS DEC Region 3
220 White Plains Road.,
Suite 110
Tarrytown, NY 10591
Berhanu Gonfa, PE
(914)803-8143
berhanu.Bonfa(S)dec.nv.fiov
3 North Dutchess, Orange, Putnam, Sullivan, & Ulster NYS DEC Region 3
21 S. Putt Corners Rd.
New Paltz, NY 12561
Jacob Addeo
(845) 256-3019
Jacob.addeo@dec.nv.Bov
4 Albany, Columbia, Delaware, Greene. Montgom
ery, Otsego, Rensselaer, Schenectady & Schoharie
NYS DEC Region 4
1130 North Westcott Road,
Schenectady, NY 12306
David Sherman
(518)357-2379
david.sherman@dec.nv.gov
5 South Fulton, Hamilton, Saratoga, Warren & Washington
NYS DEC Region 5
232 Hudson St.
Warrensburg, NY 12885
Danielle Baldwin
(518)623-1215
danielle.baldwin(5)dec.nv.Bov
5 North Clinton, Franklin, & Essex
NYS DEC Region 5
232 Hudson St.
Warrensburg, NY 12885
Madisen Hetman (518)897-1263
William Bastian (484) 868-5000
madlsen.hetman(S)dec.nv.Eov
william.bastianfSdec.nv.Bov
6 South Herkimer and Oneida
NYS DEC Region 6
207 Genesee Street
Utica, NY 13501
Gavin Denison
(315)793-6378
Bavin.denison(a)dec.nv.sov
6 North Lewis, Jefferson, St. Lawrence
NYS DEC Region 6
190 Outer Main Street
Suite 103
Potsdam, NY 13676
Gavin Denison
(315)793-6378
Bavin.denison(5)dec.nv.Bov
7 South
Broome and Tioga: Ben lead
Chenango, Tompkins, and Cortland: Dan lead
NYS DEC, Region 7
1679 NY Route 11
Kirkwood, NY 13795
Ben Girtain Ptowe, PE
Dan Fuller, PE
(607)775-2545
beniamin.sirtainoloweOdec.nv.BOV
daniel.fuller(®dec.nv.Bov
7 North Cayuga, Madison, Onondaga & Oswego NYS DEC, Region 7
5786 Widewaters Parkway
Syracuse, NY 13214
Contact:
Brienna Wirley, CFM (Flood Hub)
8 South
Chemung, Schuyler, Southern Seneca, & Steuben
NYS DEC, Region 8
100 N. Main St., Suite 104
Elmira, NY 14901
Brad Chaffee
(607) 732-2214
bradlv.chaffeefSdec.nv.BOV
8 North Genesee, Livingston, Monroe, Ontario, Orleans,
Northern Seneca, Wayne & Yates
NYS DEC, Region 8
6274 E. Avon-Lima Rd.
Avon, NY 14414
Jonathan Tamargo
(585) 226-5451
ionathan.tamarBofSdec.nv.aov
9 Allegany, Cattaraugus, Chautauqua, Erie, Niagara
& Wyoming
NYS DEC, Region 9
700 Delaware Avenue
Buffalo, NY 14209
Taylor West (716)851-2660
Erin Kane (716)851-7169
tavlor.west@dec.nv.fiov
erin.kane@dec.nv.Rov
A local law for Flood Damage Prevention as authorized by the New York State Constitution,
Article IX, Section 2, and Environmental Conservation Law, Article 36
SECTION 1.0
STATUTORY AUTHORIZATION AND PURPOSE
1.1 FINDINGS
IThe ; of the Town of Ithaca finds that the potential and/or actual damages from flood
ing and erosion may be a problem to the residents of the Town of Ithaca and that such damages may in
clude: destruction or loss of private and public housing, damage to public facilities, both publicly and pri
vately owned, and injury to and loss of human life. To minimize the threat of such damages and to
achieve the purposes and objectives hereinafter set forth, this local law is adopted.
1.2 STATEMENT OF PURPOSE
It is the purpose of this local law to promote the public health, safety, and general welfare, and to mini
mize public and private losses due to flood conditions in specific areas by provisions designed to:
(1) regulate uses which are dangerous to health, safety and property due to water or erosion hazards, or
which result in damaging increases in erosion or in flood heights or velocities;
(2) require that uses vulnerable to floods, including facilities which serve such-uses, be protected
against flood damage at the time of initial construction;
(3) control the alteration of natural floodplains, stream channels, and natural protective barriers which
are involved in the accommodation of flood waters;
(4) control filling, grading, dredging and other development which may increase erosion or flood dam
ages;
(5) regulate the construction of flood barriers which will unnaturally divert flood waters or which may
increase flood hazards to other lands, and;
(6) qualify and maintain for participation in the National Flood Insurance Program.
1.3 OBJECTIVES
'The objectives of this local law are:
(1) to protect human life and health;
(2) to minimize .expenditure of public money for costly flood control projects;
(3) to minimize the need for rescue and relief efforts associated with flooding and generally undertaken
at the expense of the general public;
(4) to minimize prolonged business interruptions;
(5) to minimize damage to public facilities and utilities such as water and gas mains, electric, tele
phone, sewer lines, streets and bridges located in areas of special flood hazard;
(6) to help maintain a stable tax base by providing for the sound use and development of areas of spe
cial flood hazard so as to minimize future flood blight areas;
(7) to provide that developers are notified that property is in an area of special flood hazard; and,
(8) to ensure that those who occupy the areas of special flood hazard assume responsibility for their ac
tions.
SECTION 2.0
DEFINITIONS
Unless specifically defined below, words or phrases used in this local law shall be interpreted so as to give them
the meaning they have in common usage and to give this local law its most reasonable application.
"Accessory Structure" is a structure used solely for parking (two-car detached garages or smaller) or limited
storage, represent a minimal investment of not more than 10 percent of the value of the primary structure, and
may not be used for human habitation.
"Appeal" means a request for a review of the Local Administrator's interpretation of any provision of this Lo
cal Law or a request for a variance.
"Area of shallow flooding" means a designated AO, AH or VO Zone on a community's Flood Insurance Rate
Map (FIRM) with a one percent or greater annual chance of flooding to an average annual depth of one to three
feet where a clearly defined channel does not exist, where the path of flooding is unpredictable and where ve
locity flow may be evident. Such flooding is characterized by ponding or sheet flow.
"Area of special flood hazard" is the land in the floodplain within a community subject to a one percent or
greater chance of flooding in any given year. This area may be designated as Zone A, AE, AH, AO, A1-A30,
A99, V, VO, VE, or V1-V30. It is also commonly referred to as the base floodplain or 100-year floodplain. For
purposes of this Local Law, the term "special flood hazard area (SFHA)" is synonymous in meaning with the
phrase "area of special flood hazard."
"Base flood" means the flood having a one percent chance of being equaled or exceeded in any given year.
"Basement" means that portion of a building having its floor subgrade (below ground level) on all sides.
"Building" see "Structure"
"Cellar" has the same meaning as "Basement".
"Crawl Space" means an enclosed area beneath the lowest elevated floor, eighteen inches or more in height,
which is used to service the underside of the lowest elevated floor. The elevation of the floor of this enclosed
area, which may be of soil, gravel, concrete or other material, must be equal to or above the lowest adjacent ex
terior grade. The enclosed crawl space area shall be properly vented to allow for the equalization of hydrostatic
forces which would be experienced during periods of flooding.
"Development" means any man-made change to improved or unimproved real estate, including but not limited
to buildings or other structures, mining, dredging, filling, paving, excavation or drilling operations or storage of
equipment or materials.
"Elevated building" means a non-basement building (i) built, in the case-of a building in Zones A1-A30, AE,
A, A99, AO, AH, B, C, X, or D, to have the top of the elevated floor, or in the case of a building in Zones VI-
30, VE, or V, to have the bottom of the lowest horizontal structure member of the elevated floor, elevated above
the ground level by means of pilings, columns (posts and piers), or shear walls parallel to the flow of the water
and (ii) adequately anchored so as not to impair the structural integrity of the building during a flood of up to
the magnitude of the base flood. In the case of Zones A1-A30, AE, A, A99, AO, AH, B, C, X, or D, "elevated
building" also includes a building elevated by means of fill or solid foundation perimeter walls with openings
sufficient to facilitate the unimpeded movement of flood waters. In the case of Zones V1-V30, VE, or V, "ele
vated building" also includes a building otherwise meeting the definition of "elevated building", even though
the lower area is enclosed by means of breakaway walls that meet the federal standards.
"Federal Emergency Management Agency" means the Federal agency that administers the National Flood
Insurance Program.
"Flood" or "Flooding" means a general and temporaiy condition of partial, or complete inundation of normally
diy land areas from:
(1) the overflow of inland or tidal waters;
(2) the unusual and rapid accumulation or runoff of surface waters from any source.
"Flood" or "flooding" also means the collapse or subsidence of land along the shore of a lake or other body of
water as a result of erosion or undermining caused by waves or currents of water exceeding anticipated cyclical
levels or suddenly caused by an unusually high water level in a natural body of water, accompanied by a severe
storm, or by an unanticipated force of nature, such as a flash flood or an abnormal tidal surge, or by some simi
larly unusual and unforeseeable event which results in flooding as defined in (1) above.
"Flood Boundarj' and Floodway Map (FBFM)" means an official map of the community published by the
Federal Emergency Management Agency as part of a riverine community's Flood Insurance Study. The FBFM
delineates a Regulatory Floodway along water courses studied in detail in the Flood Insurance Study.
"Flood Elevation Study" means an examination, evaluation and deteimination of the flood hazards and, if ap
propriate, coiTesponding water surface elevations, or an examination, evaluation and determination of flood-
related erosion hazards.
"Flood Hazard Boundary Map (FHBM)" means an official map of a community, issued by the Federal .
Emergency Management Agency, where the boundaries of the areas of special flood hazard have been desig
nated as Zone A but no flood elevations are provided.
"Flood Insurance Rate Map (FIRM)" means an official map of a community, on which the Federal Emer
gency Management Agency has delineated both the areas of special flood hazard and the risk premium zones.
applicable to the community. .
"Flood Insurance Study" see "flood elevation study".
"Floodplain" or "Flood-prone area" means any land area susceptible to being inundated by water from any
source (see definition of "Flooding").
3
"Floodproofmg" means any combination of structural and non-structural additions, changes, or adjustments to
structures which reduce or eliminate flood damage to real estate or improved real property, water and sanitary
facilities, structures and their contents.
"Floodway" - has the same meaning as "Regulatory Floodway".
"Functionally dependent use" means a use which cannot perform its intended purpose unless it is located or
carried out in close proximity to water, such as a docking or port facility necessary for the loading and unload
ing of cargo or passengers, shipbuilding, and ship repair facilities. The term does not include long-term storage,
manufacturing, sales, or service facilities.
"Highest adjacent grade" means the highest natural elevation of the ground surface, prior to construction,
next to the proposed walls of a structure.
"Historic structure" means any structure that is:
(1) listed individually in the National Register of Historic Places (a listing maintained by the Depart- .
ment of the Interior) or preliminarily determined by the Secretary' of the Interior as meeting the re
quirements for individual listing on the National Register;
(2) certified or preliminarily determined by the Secretary of the Interior as contributing to the historical
significance of a registered historic district or a district preliminarily determined by the Secretary to
qualify as a registered historic district;
(3) individually listed on a state inventoiy of historic places in states with historic preservation pro
grams which have been approved by the Secretary of the Interior; or
(4) individually listed on a local inventory of historic places in communities with historic preservation
programs that have been certified either:
(i) by an approved state program as determined by the Secretaiy of the Interior or
(ii) directly by the Secretary of the Interior in states without approved programs.
"Local Administrator" is the person appointed by the community to administer and implement this local law
by granting or denying development permits in accordance with its provisions. This person is often the Build
ing Inspector, Code Enforcement Officer, or employee of an engineering department.
"Lowest floor" means lowest floor of the lowest enclosed area (including basement or cellar). An unfinished
or flood resistant enclosure, usable solely for parking of vehicles, building access, or storage in an area other
than a basement area is not considered a building's lowest floor; provided, that such enclosure is not built so as
to render the.structure in violation of the applicable non-elevation design requirements of this Local Law.
"Manufactured home" means a structure, transportable in one or more sections, which is built on a permanent
chassis and designed to be used with or without a permanent foundation when connected to the required utili
ties. The term does not include a "Recreational vehicle"
"Manufactured home park or subdivision" means a parcel (or contiguous parcels) of land divided into two
or more manufactured home lots for rent or sale.
"Mean sea level" means, for purposes of the National Flood Insurance Program, the National Geodetic Verti
cal Datum (NGVD) of 1929, the North American Vertical Datum of 1988 (NAVD 88), or other datum, to which
base flood elevations shown on a community's Flood Insurance Rate Map are referenced.
"Mobile home" - has the same meaning as "Manufactured home".
"New construction" means structures for which the "start of construction" commenced on or after the effective
date of a floodplain management regulation adopted by the community and includes any subsequent improve
ments to such structure.
"One-hundred-year flood" or "100-year flood" has the same meaning as "Base Flood".
"Principally above ground" means that at least 51 percent of the actual cash value of the structure, excluding
land value, is above ground.
(
"Recreational vehicle" means a vehicle which is: •
(1) built on a single chassis;
(2) 400 square feet or less when measured at the largest horizontal projections;
(3) designed to be self-propelled or permanently towable by a light dut}' truck; and,
(4) not designed primarily for use as a permanent dwelling but as temporary living quarters for recrea
tional, camping, travel, or seasonal use.
"Regulatory Floodway" means the channel of a river or other watercourse and the'adjacent land areas that
must be reserved in order to discharge the base flood without cumulatively increasing the water surface eleva
tion more than a designated height as detennined by the Federal Emergency Management Agency in a Flood
Insurance Study or by other agencies as provided in Section 4.4-2 of this Law.
"Start of construction" means the date of permit issuance for new construction and substantial improvements
to existing structures, provided that actual start of construction, repair, reconstruction, rehabilitation, addition
placement, or other improvement is within 180 days after the date of issuance. The actual start of construction
means the first placement of permanent construction of a building (including a manufactured home) on a site,
such as the pouring of a slab or footings, installation of pilings or construction of columns.
Permanent construction does not include land preparation (such as clearing, excavation, grading, or filling), or
the installation of streets or walkways, or excavation for a basement, footings, piers or foundations, or the erec
tion of temporary forms, or the installation of accessory buildings such as garages or sheds not occupied as
dwelling units or not part of the main building. For a substantial improvement, the actual "start of construction"
means the first alteration of any wall, ceiling, floor; or other structural part of a building, whether or not that al
teration affects the external dimensions of the building;
"Structure" means a walled and roofed building, including a gas or liquid storage tank that is principally above
ground, as well as a manufactured home.
"Substantial damage" means damage of any origin sustained by a structure whereby the cost of restoring the
structure to its before damaged condition would equal or exceed 50 percent of the market value of the structure
before the damage occurred.
"Substantial improvement" means any reconstruction, rehabilitation, addition, or other improvement of a
structure, the cost of which equals or exceeds 50 percent of the market value of the structure before the "start of
construction" of the improvement. The term.includes structures which have incurred "substantial damage", re
gardless of the actual repair work performed. The term does not, however, include either:
(1) any project for improvement of a structure to correct existing violations of state or local health, san
itary, or safety code specifications which have been identified by the local code enforcement official
and which are the minimum necessary to assure safe living conditions; or
(2) any alteration of a "Historic structure", provided that the alteration will not preclude the structure's
continued designation as a "Historic structure".
"Variance" means a grant of relief from the requirements of this local law which permits construction or use in
a manner that would otherwise be prohibited by this local law.
"Violation" means the failure of a structure or other'development to be fully compliant with the community's
flood plain management regulations.
SECTION 3.0
GENERAL PROVISIONS
3.1 LANDS TO WHICH THIS LOCAL LAW APPLIES
This local law shall apply to all areas of special fiood hazard within the jurisdiction of the
Town of Ithaca. Tompkins County
3.2 BASIS FOR ESTABLISHING THE AREAS OF SPECIAL FLOOD HAZARD
The areas of special flood hazard for the Town of Ithaca. Community Number 360851 are identified and
defined on the following documents prepared by the Federal Ernergency Management Agency.
(1) Flood Insurance Rate Map Panels:
36109C0177D, 36109C0179D, 36109C0181D, 36109C0182D, 36109C0183D, 36109C0184D,
36109C0187D, 36109C0189D, 36109C0191D, 36109C0192D, 36109C0193D, 36109C0I94D,
36109C0201D, 36109C0202D, 36109C0203D, 36109C0204D, 36109C0211D, 36109C0212D,
36109C0213D, 36109C0214D
whose effective date is June 18. 2025.
(2) A scientific and engineering report entitled "Flood Insurance Study, Tompkins County, New
York, (All Jurisdictions)," dated June 18. 2025.
The above documents are hereby adopted and declared to be a part of this Local Law. The Flood Insur
ance Study and/or maps are on file at:
3.3 INTERPRETATION AND CONFLICT WITH OTHER LAWS
This Local Law includes all revisions to the National Flood Insurance Program through June 26,2001, •
and .shall supersede all previous laws adopted for the purpose of flood damage prevention.
In their interpretation and application, the provisions of this local law shall be held to be minimum re
quirements, adopted for the promotion of the public health, safety, and welfare. Whenever the require
ments of this local law are at variance with the requirements of any other lawfully adopted rules, regula
tions, or ordinances, the most restrictive, or that imposing the higher standards, shall govern.
3.4 SEVERABILITY
The invalidity of any section or provision of this local law shall not invalidate any other section or provi
sion thereof.
3.5 PENALTIES FOR NON-COMPLIANCE
No structure in an area of special flood hazard shall hereafter be constructed, located, extended, con
verted, or altered and no land shall be excavated or filled without full compliance with the terms ofthis
local law and any other applicable regulations. Any infraction of the provisions of this local law by fail
ure to comply with any of its requirements, including infractions of conditions and safeguards established
in connection with conditions of the permit, shall constitute a violation. Any person who violates this lo
cal law or fails to comply with any of its requirements shall, upon conviction thereof, be fined no more
than $250 or imprisoned for not more than 15 days or both. Each day of noncompliance shall be consid
ered a separate offense. Nothing herein contained shall prevent the Town .of Ithaca from taking such other
lawflil action as necessary to prevent or remedy an infraction. Any structure found not compliant with the
requirements of this local law for which the developer and/or owner has not applied for and received an
approved variance under Section 6.0 will be declared non-compliant and notification sent to the Federal
Emergency Management Agency.
3.6 WARNING AND DISCLAIMER OF LIABILITY
The degree of flood protection required by this local law is considered reasonable for regulatory purposes
and is based on scientific and engineering considerations. Larger floods can and will occur on rare occa
sions. Flood heights may be increased by man-made or natural causes. This local law does not imply that
land outside the area of special flood hazards or uses permitted within such areas will be free from flood-
. ing or flood damages. This local law shall not create liability on the part of the Town of Ithaca any officer
or employee thereof, or the Federal Emergency Management Agency, for any flood damages that result
from reliance on this local law, or any administrative decision lawfully made there under.
SECTION 4.0
ADMINISTRATION
4.1 DESIGNATION OF THE LOCAL ADMINISTRATOR
The ^ is hereby appointed Local Administrator to administer and imple
ment this local law by granting or denying floodplain development permits in accordance with its provi
sions.
4.2 THE FLOODPLAIN DEVELOPMENT PERMIT
4.2-1 PURPOSE
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A floodplain development permit is hereby established for all construction and other development
to be undertaken in areas of special flood hazard in this community for the purpose of protecting its
citizens from increased flood hazards and ensuring that new development is constructed in a manner
that minimizes its exposure to flooding. It shall be unlawful to undertake any development in an
area of special flood hazard, as shown on the Flood Insurance Rate Map enumerated in Section 3.2,
without a valid floodplain development permit. Application for a permit shall be made on forms
furnished by the Local Administrator and may include, but not be limited to: plans, in duplicate,
drawn to scale and showing: the nature, location, dimensions, and elevations of the area in question;
existing or proposed structures, fill, storage of materials, drainage facilities, and the location of the
foregoing.
4.2-2 FEES
All applications for a floodplain development permit shall be accompanied by an application fee of
$ . In addition, the applicant shall be responsible for reimbursing the Town of
Ithaca for any additional costs necessary for review, inspection and approval of this project. The
Local Administrator may require a deposit of no more than $500.00 to cover these additional costs.
4.3 APPLICATION FOR A PERMIT
The applicant shall provide the following information as appropriate. Additional information may be re
quired on the permit application form.
. (1) The proposed elevation, in relation to mean sea level, of the lowest floor (including basement or
cellar) of any new or substantially improved residential structure to be located in a special flood
hazard area. Upon completion of the lowest floor, the permitee shall submit to the Local Adminis
trator the as-built elevation, certified by a licensed professional engineer or surveyor.
(2) The proposed elevation, in relation to mean sea level, of the lowest floor (including basement or
cellar) of any new or substantially improved non-residential structure to be located in Zones Al-
A30, AE, or AH or Zone A if base flood elevation data are available. Upon completion of the low
est floor, the permitee shall submit to the Local Administrator the as-built elevation, certified by a
licensed professional engineer or surveyor.
(3). The proposed elevation, in relation to mean sea level, to which any new or substantially improved
non-residential structure will be floodproofed. Upon completion of the floodproofed portion of the
structure, the permitee shall submit to the Local Administrator the as-built floodproofed elevation,
certified by a professional engineer or surveyor.
. (4) A certificate from a licensed professional engineer or architect that any utility floodproofing will
meet the criteria in Section 5.2-3, UTILITIES.
(5) A certificate from a licensed professional engineer or architect that any non-residential floodproofed
structure will meet the floodproofing criteria in Section 5.4, NON-RESIDENTIAL STRUCTURES.
(6) A description of the extent to which any watercourse will be altered or relocated as a result of pro
posed development. Computations by a licensed professional engineer must be submitted that
demonstrate that the altered or relocated segment will provide equal or greater conveyance than the
original stream segment. The applicant must submit any maps, computations or other material
required by the Federal Emergency Management Agency (FEMA) to revise the documents enumer
ated in Section 3.2, when notified by the Local Administrator, and must pay any fees or other costs
assessed by FEMA for this purpose. The applicant must also provide assurances that the convey
ance capacity of the altered or relocated stream segment will be maintained.
(7) A teclinical analysis, by a licensed professional engineer, if required by the Local Administrator,
which shows whether proposed development to be located in an area of special flood hazard may
result in physical damage to any other property.
(8) In Zone A, when no base flood elevation data are available from other sources, base flood elevation
data shall be provided by the permit applicant for subdivision proposals and other proposed devel
opments (including proposals for manufactured home and recreational vehicle parks and subdivi
sions) that are greater than either 50 lots or 5 acres.
4.4 DUTIES AND RESPONSIBILITIES OF THE LOCAL ADMINISTRATOR
Duties of the Local Administrator shall include, but not be limited to the following.
4.4-1 PERMIT APPLICATION REVIEW
The Local Administrator shall conduct the following permit application reyiew before issuing a
floodplain development permit:
(1) Review all applications for completeness, particularly with the requirements of subsection 4.3,
APPLICATION FOR A PERMIT, and for compliance with the provisions and standards of
this law.
(2) Review subdivision and other proposed new development, including manufactured home
parks to determine whether proposed building sites will be reasonably safe from flooding. If a
proposed building site is located in an area of special flood hazard, all new construction and
substantial improvements shall meet the applicable standards of Section 5.0,
CONSTRUCTION STANDARDS and, in particular, sub-section 5.1-1 SUBDIVISION
PROPOSALS.
(3) Determine whether any proposed development in an area of special flood hazard may result in
physical damage to any other property (e.g., stream bank erosion and increased flood veloci-
• ties). The Local Administrator may require the applicant to submit additional technical anal
yses and data necessaiy to complete the determination.
If the proposed development may result in physical damage to any other property or fails to
meet the requirements of Section 5.0, CONSTRUCTION STANDARDS, no permit shall be
issued. The applicant may revise the application to include measures that mitigate or elimi
nate the adverse effects and re-submit the application.
(4) Detennine that all necessary permits have been received from those governmental agencies
from which approval is required by State or Federal law.
4.4-2 USE OF OTHER FLOOD DATA
(1) When the Federal Emergency Management Agency has designated areas of special flood haz
ard on the community's Flood Insurance Rate map (FIRM) but has neither produced water
9
surface elevation data (these areas are designated Zone A or V on the FIRM) nor identified a
floodway, the Local Administrator shall obtain, review and reasonably utilize any base flood
elevation and floodway data available from a Federal, State or other source, including data
developed pursuant to paragraph 4.3(7), as criteria for requiring that new construction, sub
stantial improvements or other proposed development meet the requirements of this law.
(2) When base' flood elevation data are not available, the Local Administrator may use flood in
formation from any other authoritative source, such as historical data, to establish flood eleva
tions within the areas of special flood hazard, for the purposes of this law.
(3) When, an area of special flood hazard, base flood elevation, and/or floodway data are available
from a Federal, State or other authoritative source, but differ from the data in the documents
enumerated in Section 3.2, the Local Administrator may reasonably utilize the other flood in
formation to enforce more restrictive development standards.
4.4-3 ALTERATION OF WATERCOURSES
(1) Notification to adjacent municipalities that may be affected and the New York State Depart
ment of Environmental Conservation prior to permitting any alteration or relocation of a wa
tercourse and submit evidence of such notification to the Regional Administrator, Region II,
Federal Emergency Management Agency.
(2) Determine that the permit holder has provided for maintenance within the altered or relocated
portion of said watercourse so that the flood carrying capacity is not diminished.
4.4-4 CONSTRUCTION STAGE
(1) In Zones A1-A30, AE and AH, and Zone A if base flood elevation data are available, upon
. placement of the lowest floor or completion of floodproofing of a new or substantially im
proved structure, obtain from the permit holder a certification of the as-built elevation of the
lowest floor or floodproofed elevation, in relation to mean sea level. The certificate shall be
prepared by or under the direct supervision of a licensed land surveyor or professional engi
neer and certified by same. For manufactured homes, the permit holder shall submit the cer
tificate of elevation upon placement of the structure on the site. A certificate of elevation
must also be submitted for a recreational vehicle if it remains on a site for 180 consecutive
days or longer (unless it is fully licensed and ready for highway use).
(2) Any further work undertaken prior to submission and approval of the certification shall be at
the permit holder's risk. The Local Administrator shall review all data submitted. Deficien
cies detected shall be cause to issue a stop work order for the project unless immediately cor
rected.
4.4-5 INSPECTIONS
The Local Administrator and/or the developer's engineer or architect shall make periodic inspec
tions at appropriate times throughout the period of construction, to monitor compliance with permit
conditions and enable said inspector to certify, if requested, that the developmeht is in compliance
with the requirements of the floodplain d.evelopment permit and/or any.variance provisions.
10
4.4-6 STOP WORK ORDERS
(1) The Local Administrator shall issue, or cause to be issued, a stop work order for any floodplain de
velopment found ongoing without a development permit. Disregard of a stop work order shall sub
ject the violator to the penalties described in Section 3.5 of this local law.
(2) The Local Administrator shall issue, or cause to be issued, a stop work order for any floodplain de
velopment found non-compliant with the provisions of this law and/or the conditions of the devel
opment permit.. Disregard of a stop work order shall subject the violator to the penalties described
in Section 3.5 of this local law.
4.4-7 CERTIFICATE OF COMPLIANCE
(1) In areas of special flood hazard, as detemiined by documents enumerated in Section 3.2, it
shall be unlawful to occupy or to permit the use or occupancy of any building or premises, or
both, or part thereof hereafter created, erected, changed, converted or wholly or partly altered
or enlarged in its use or structure until a certificate of compliance has been issued by the Lo
cal Administrator stating that the building or land conforms to the requirements of this local
law.
(2) A certificate of compliance shall be issued by the Local Administrator upon satisfactory com
pletion of all development in areas of special flood hazard.
(3) Issuance of the certificate shall be based upon the inspections conducted as prescribed in Sec
tion 4.4-5, INSPECTIONS, and/or any certified elevations, hydraulic data, floodproofing, an
choring requirements or encroachment analyses which may have been required as a condition
of the approved permit.
4.4-8 INFORMATION TO BE RETAINED
The Local Administrator shall retain and make available for inspection, copies of the following:
(1) Floodplain development perinits and certificates of compliance;
(2) Certifications of as-built lowest floor elevations of structures, required pursuant to sub-sec
tions 4.4-4(1) and 4.4-4(2), and whether or not the structures contain a basement; ^
. (3) Floodproofing certificates required pursuant to sub-section 4.4-4(1), and whether or not
the structures contain a basement;
(4) Variances issued pursuant to Section 6.0, VARIANCE PROCEDURES; and, '
(5) Notices required under sub-section 4.4-3, ALTERATION OF WATERCOURSES.
SECTION 5.0
CONSTRUCTION STANDARDS
5.1 GENERAL STANDARDS
11
The following standards apply to new development, including new and substantially improved structures,
in the areas of special flood hazard shown on the Flood Insurance Rate Map designated in Section 3.2.
5.1-1 SUBDIVISION PROPOSALS
The following standards apply to all pew subdivision proposals and other proposed development in
areas of special flood hazard (including proposals for manufactured home and recreational vehicle
parks and subdivisions):
(1) Proposals shall be consistent with the need to minimize flood damage;
(2) Public utilities and facilities such as sewer, gas, electrical and water systems shall be located
and constructed so as to minimize flood damage; and,
(3) Adequate drainage shall be provided to reduce exposure to flood damage.
5.1-2 ENCROACHMENTS
(1) Within Zones A1-A30 and AE, on streams without a regulatory flopdway, no new construc
tion, substantial improvements or other development (including fill) shall be permitted unless:
(i) the applicant demonstrates that the cumulative effect of the proposed development,
when combined with all other existing and anticipated development, will not increase
the water surface elevation of the base flood more than one foot at any location, or,
(ii) the Town of Ithaca agrees to apply to the Federal Emergency Management Agency
(FEMA)for a conditional FIRM revision, FEMA approval is received and the applicant
provides all necessary data, analyses and mapping and reimburses the Town of Ithaca
for all fees and other costs in relation to the application. The applicant must also pro
vide all data, analyses and mapping and reimburse the Town of Ithaca for all costs re
lated to the final map revision.
(2) On streams with a regulatory floodway, as shown on the Flood Boundaiy and Floodway Map
or the Flood Insurance Rate Map adopted in Section 3.2, no new construction, substantial im
provements or other development in the floodway (including fill) shall be permitted unless:
(i) a teclmical evaluation by a licensed professional engineer demonstrates through hy-
drologic and hydraulic analyses performed in accordance with standard engineering
practice that such an encroachment shall not result in any increase in flood levels during
occurrence of the base flood, or,
(ii) the Town of Ithaca agrees to apply to the Federal Emergency Management Agency
(FEMA) for a conditional FIRM and floodway revision, FEMA approval is received
and the applicant provides all necessary data, analyses and mapping and reimburses the
Town of Ithaca for all fees and other costs in relation to the application. The applicant
must also provide all data, analyses and mapping and reimburse the Town of Ithaca for
all costs related to the final map revisions.
(3) In Zones A1-A30, AE and AH, and also Zone A if base flood elevation data are available,
if any development is found to increase or decrease base flood elevations, the
shall as soon as practicable, but not later than six months after the date such information
12
becomes available, notify FEMA and the New York State Department of Environmental Con
servation of the changes by submitting technical or scientific data in accordance with standard
engineering practice.
5.2 STANDARDS FOR ALL STRUCTURES
The following standards apply to new development, including new and substantially improved structures,
in the areas of special flood hazard shown on the Flood Insurance Rate Map designated in Section 3.2.
5.2-1 ANCHORING '
New structures and substantial improvement to structures in areas of special flood hazard shall be
anchored to prevent flotation, collapse, or lateral movement during the base flood. This require
ment is in addition to applicable State and local anchoring requirements for resisting wind forces.
5.2-2 CONSTRUCTION MATERIALS AND METHODS
(1) New construction and substantial improvements to structures shall be constructed with materi
als and utility equipment resistant to flood damage.
(2) New construction and substantial improvements to structures shall be constructed using meth
ods and practices that minimize flood damage.
(3) For enclosed areas below the lowest floor of a structure within Zones A1-A30, AE, AO or A,
new and substantially improved structures shall have fully enclosed areas below the lowest
floor that are useable solely for parking of vehicles,' building access or storage in an area other
than a basement and which are subject to flooding, designed to automatically equalize hydro
static flood forces on exterior walls by allowing for the entiy and exit of flood waters. De
signs for meeting this requirement must either be certified by a licensed professional engineer
or architect or meet or exceed the-following minimum criteria:
(i) a minimum of two openings of each enclosed area having a total net area of not less
than one square inch for every square foot of enclosed area subject to flooding;
(ii) the bottom of all such openings no higher than one foot above the lowest adjacent
finished grade and;
(iii) openings not less than three inches in any direction.
Openings may be equipped with louvers, valves, screens or other coverings or devices pro-
^ vided they permit the automatic ent^ and exit of floodwaters. Enclosed areas sub-grade on all
sides are considered basements and are not permitted.
5.2-3 UTILITIES
(1) New and replacement electrical equipment, heating, ventilating, air conditioning, plumbing
connections, and other seiwice equipment shall be located at least two feet above the base
flood elevation, at least tliree feet above the highest adjacent grade in a Zone A without an
available base flood elevation where permitted, or be designed to prevent water from entering
and accumulating within the components during a flood and to resist hydrostatic and
: 13
hydrodynamic loads and stresses. Electrical wiring and outlets, switches, junction boxes and
panels shall be elevated or designed to prevent water from entering and accumulating within
the components unless they conform to the appropriate provisions of the electrical part of the
Building Code of New York State or the Residential Code of New York State for location of
such items in wet locations;
(2) New and replacement water supply systems shall be designed to minimize or eliminate infil
tration of flood waters into the system;
(3) New and replacement sanitary sewage systems shall be designed to minimize or eliminate in
filtration of flood waters. Sanitary sewer and storm drainage systems for buildings that have
openings below the base flood elevation shall be provided with automatic backflow valves or
other automatic backflow devices that are installed in each discharge line passing through a
building's exterior wall; and,
(4) On-site waste disposal systems shall be located to avoid impairment to them or contamination
• from them during flooding.
5.2-4 STORAGE TANKS
(1) Underground tanks shall be anchored to prevent flotation, collapse and lateral movement during
conditions of the base flood.
(2) Above-ground tanks shall be:
a. anchored to prevent floatation, collapse or lateral movement during conditions of the
base flood or;
b. installed at or above the base flood elevation as shown on the Flood Insurance Rate Map
enumerated in Section 3.2 plus two feet.
5.3 RESIDENTIAL STRUCTURES
5.3-1 ELEVATION
The following standards apply to new and substantially improved residential structures located in
areas of special flood hazard, in addition to the requirements in sub-sections 5.1-1, SUBDIVISION
PROPOSALS, and 5.1-2, ENCROACHMENTS, and Section 5.2, STANDARDS FOR ALL
STRUCTURES.
(1) Within Special Flood Hazard Areas, new construction and substantial improvements shall
have the lowest floor (including basement) elevated to or above two feet above the base flood
elevation. "
(2) Within Zone A, if the Base flood elevation is not specified, a base flood elevation shall be de
termined by either of the following:
a. Obtain and reasonably use data available from a federal, state or other source plus 2 feef
of freeboard or:
14
b. Determine the base flood elevation in accordance with accepted hydrologic and hydraulic
engineering practices, plus freeboard. Determinations shall be undertaken by a registered
design professional who shall be documented that the technical methods used reflect cur
rently accepted engineering-practice. Studies, analyses, and computations shall be submit
ted in sufficient detail to allow thorough review and approval.
(3) . Within Zone AOj new construction and substantial improvements shall have the lowest floor
(including basement) elevated above the highest adjacent grade at least as high as the depth
number specified in feet on the community's Flood Insurance Rate Map enumerated in Sec
tion 3.2 plus two feet of freeboard, or not less than 3 feet if a depth number is not specified.
(4) Within Zones AH and AO, adequate drainage-paths are required to guide flood waters around
and away from proposed structures on slopes.
5.4 NON-RESIDENTIAL STRUCTURES
The following standards apply to new and substantially improved commercial, industrial and other non-
residential structures located in areas of special flood hazard, in addition to the requirements in sub-sec
tions 5.1-1, SUBDIVISION PROPOSALS, and 5.1-2, ENCROACHMENTS, and Section 5.2,
STANDARDS FOR ALL STRUCTURES. ' . "
(1) Within Zones A1-A30, AE and AH, and'also Zone A if base flood elevation data are available, new •
constmction and .substantial improvements of any non-residential structure shall either:
(i) have the lowest floor, including basement or cellar, elevated to or above two feet above the
base flood elevation; or ' • -
(ii) be.floodproofed so that the structure is watertight below two feet above the base flood ele
vation, including attendant utility and sanitary facilities, with walls substantially impermeable
to the passage of water. All structural components located below the base flood level must be
capable of resisting hydrostatic and hydrodynamic loads and the effects of buoyancy.
(2) " Within Zone AO, new construction and substantial improvements of non-residential structures
shall: n . "
(i) have the lowest floor (including basement) elevated above the liighest adjacent grade at
least as high as the depth number specified in feet on the community's FIRM plus two feet (at
least three feet if no depth number is specified), or
(ii) together with attendant utility and sanitary facilities, be completely floodproofed to that
level to meet the floodproofing standard specified in sub-section 5.4(l)(ii)
(3) If the structure is to be floodproofed, a licensed professional engineer or architect shall develop
and/or review structural design, specifications, and plans'for construction. A Floodproofing Certifi
cate or other certification shall be provided to the Local Administrator that-certifies the design and •
methods of construction are in accordance with accepted standards of practice for meeting the pro-
visions'of Section 5.4(l)(ii), including the specific elevation (in relation to mean sea level) to which
the structure is to be floodproofed.' .
(4) n Witliin Zones AH and AO, adequate drainage paths are required to guide flood waters around and
away from proposed structures on slopes.
15
(5) Within Zone A, when no base flood elevation data are available, the lowest floor (including n base
ment) shall be elevated at least three feet above the highest adjacent grade.
5.5 MANUFACTURED HOMES AND RECREATIONAL VEHICLES
The following standards in addition to the standards in Section 5.1, GENERAL STANDARDS, and Sec
tion 5.2, STANDARDS FOR ALL STRUCTURES apply, as indicated, in areas of special flood hazard to
manufactured homes and to recreational vehicles which are located in areas of special flood hazard.
(1) Recreational vehicles placed on sites within Zones A1-A30, AE and AH shall either:
(i) be on site fewer than 180 consecutive days,
(ii) be fiilly licensed and ready for highway use, or
(iii) meet the requirements for manufactured homes in paragraphs 5.5(2), (3) and (4).
A recreational vehicle is ready for highway use if it is on its wheels or jacking system, is attached to
the site only by quick disconnect type utilities and security devices and has no permanently attached
additions.
(2) A manufactured home that is placed or substantially improved in Zones A1-A30, AE, AH and Zone
A shall be elevated on a permanent foundation such that the bottom of the frame of the manufac
tured home chassis is elevated to or above two feet above the base flood elevation and is securely
anchored to an adequately anchored foundation system to resist flotation, collapse and lateral move
ment.
(3) Within Zone AO, the bottom of the frame of the manufactured home chassis shall be elevated above
the highest adjacent grade at least as high as the depth number specified on the Flood Insurance
Rate Map enumerated in Section 3.2 plus two feet (at least three feet if no depth number is speci
fied).
(4) The foundation and anchorage of manufactured homes to be located in identified floodways shall be
designed and constructed in accordance with Section 5.2-1, ANCHORING.
5.6 ACCESSORY STRUCTURES INCLUDING DETACHED GARAGES
The following standards apply to new and substantially improved accessory structures, including detached
garages, in the areas of special flood hazard shown on the Flood Insurance Rate Map designated in Sec
tion 3.2.
(1) The accessory structure must meet the definition of structure, for floodplain management purposes,
provided in 44 CFR § 59.1, where walled and roofed shall be interpreted as having two outside rigid
walls and a fully secured roof.
(2) The accessory structure should be small, as defined by the community and approved by FEMA, and
represent a minimal investment. Accessory structures of any size may be considered for a variance;
n however, FEMA considers accessory structures that meet the following criteria to be small and
therefore not necessarily in need of a variance, if the community chooses to allow it:
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n a. Located in an A Zone (A, AE, A1-A30, AR, A99) and less than or equal to the size of a one-
' n story, two-car garage.
I '
(3) Accessory structures must meet the standards of Section 5.2-1, ANCHORING,
(4) The portions of the accessory structure located below BFE plus two feet of freeboard must be con
structed with flood-resistant materials.
(5) Mechanical and utility equipment for the accessory structure must be elevated or dry floodproofed
to or above BFE plus two feet of freeboard.
(6) Within Zones AO and Zone A, if base flood elevation data are not available, areas below three feet
above the highest adjacent grade shall be constructed using methods and practices that minimize
flood damage.
(7) The accessory structure must comply with the floodway encroachment provisions of the NFIP.
(8) The accessory structure must be wet floodproofed to protect the structure from hydrostatic pressure.
The design must meet the NFIP design and performance standards for openings per 44 CFR §
60.3(c)(5) and must allow for the automatic entry and exit of floodwaters without manual operation
or the presence of a person (or persons).
SECTION 6.0
VARIANCE PROCEDURE
6.1 APPEALS BOARD
(1) The as established by the shall hear and decide ap
peals and requests for variances from the requirements of this local law.
(2) The shall hear and decide appeals when it is alleged there is an error in any
requirement, decision, or determination made by the Local Administrator in the enforcement or ad
ministration of this local law.
(3) Those aggrieved by the decision of the may appeal such decision to
the Supreme Court pursuant to Article 78 of the Civil Practice Law and Rules.
(4) In passing upon such applications, the , shall consider all technical evalua
tions, all relevant factors, standards specified in other sections of this local law and:
(i) the danger that materials may be swept onto other lands to the injury of others;
(ii) the danger to life and property due to flooding or erosion damage; '
(iii) the susceptibility of the proposed facility and its contents to flood damage and the effect
of such damage on the individual owner;
(iv) the importance of the services provided by the proposed facility to the community;
(v) the necessity to the facility of a waterfront location, where applicable;
17 .
(vi) the availability of alternative locations for the proposed use which are not subject to
flooding or erosion damage;
(vii) the compatibility of the proposed use with existing and anticipated development;
(viii) the relationship of the proposed use to the comprehensive plan and floodplain manage
ment program of that area;
(ix) the safety of access to the property in times of flood for ordinary and emergency vehicles;
(x) the costs to local governments and the dangers associated with conducting search and res
cue operations during periods of flooding;
(xi) the expected heights, velocity, duration, rate of rise and sediment transport of the flood
waters and the effects of wave action, if applicable, expected at the site; and
(xii) the costs of providing governmental services during and after flood conditions, includ
ing search and rescue operations, maintenance and repair of public utilities and facilities such
as sewer, gas, electrical, and water systems and streets and bridges.
(5) Upon consideration of the factors of Section 6.1(4) and the purposes of this local law, the
may attach such conditions to the granting of variances as it deems
necessary to further the purposes of this local law.
(6) The Local Administrator shall maintain the records of all appeal actions including technical infor
mation and report any variances to the Federal Emergency Management Agency upon request.
6.2 CONDITIONS FOR VARIANCES
(1) Generally, variances may be issued for new construction and substantial improvements to be
erected on a lot of one-half acre or less in size contiguous to and surrounded by lots with existing
structures constructed below the base flood level, providing items (i-xii) in Section 6.1(4) have been
fully considered. As the lot size increases beyond the one-half acre, the technical Justification re
quired for issuing the variance increases.
(2) Variances may be issued for the repair or rehabilitation of historic structures upon determination
that;
(i) the proposed repair or rehabilitation will not preclude the structure's continued designation
as a "Historic structure"; and
(ii) the variance is the minimum necessary to preserve the historic character and design of the
structure.
(3) Variances may be issued by a community for new construction and substantial improvements and
for other development necessary for the conduct of a flinctionally dependent use provided that:
(i) the criteria of subparagraphs 1, 4, 5, and 6 of this Section are met; and
18
(ii) the structure or other development is protected by methods that minimize flood damages
during the base flood and create no additional tlireat to public safety.
(4) Variances shall not be issued within any designated floodway if any increase in flood levels during
the base flood discharge would result.
(5) Variances shall only be issued upon a determination that the variance is the minimum necessary,
considering the flood hazard, to afford relief.
(6) Variances shall only be issued upon receiving written justification of:
(i) a showing of good and sufficient cause;
(ii) a determination that failure to grant the variance would result in exceptional hardship to
the applicant; and
(iii) a determination that the granting of a variance will not result in increased flood heights,
additional threats to public safety, extraordinary public expense, create nuisances, cause fraud
on or victimization of the public or conflict with existing local laws or ordinances.
(7) Any applicant to whom a variance is granted for a building with the lowest floor below the base
flood elevation shall be given written notice over the signature of a community official that:
. (i) the issuance of a variance to construct a structure below the base flood level will result in
increased premium rates for flood insurance up to amounts as high as $25 for $100 of insur
ance coverage; and
(ii) such construction below the base flood level increases risks to life and property.
Such notification shall be maintained with the.record of all variance actions as required in Section
4.4-8 of this Local Law.
19
. Be it enacted this day of , 20 by the
of the
County, New York, to be
effective
SEAL
ATTEST CLERK
20
Attachment A
MODEL FLOODPLAIN DEVELOPMENT
APPLICATION FORM
APPLICATION # Page 1 of 4
FLOODPLAIN DEVELOPMENT PERMIT APPLICATION
This form is to be filled out in duplicate.
SECTION 1: GENERAL PROVISIONS (APPLICANT to read and sign'):
1. No work may start until a permit is issued.
2.. The permit may be revoked if any false statements are made herein.
3. If revoked, all work must cease until permit is re-issued.
4. Development shall not be used or occupied until a Certificate of Compliance is issued.
5. The permit is invalid if no work is commenced within six months of issuance, and expires 2 years from date of issuance.
6. Applicant is hereby informed that other permits may be required to fulfill local, state and federal regulatory requirements.
7. Applicant hereby gives consent to the Local Administrator or his/her representative to make reasonable inspections required
to verify compliance.
8. I, THE APPLICANT, CERTIFY THAT ALL STATEMENTS HEREIN AND IN ATTACHMENTS TO THIS
APPLICATION ARE, TO THE BEST OF MY KNOWLEDGE, TRUE AND ACCURATE.
(APPLICANT'S SIGNATURE) ^ DATE
SECTION 2: PROPOSED DEVELOPMENT fFo be completed by APPLICANT)
NAME ADDRESS TELEPHONE
APPLICANT
BUILDER
ENGI
NEER
PROJECT LOCATION:
To avoid delay in processing the application, please provide enough information to easily identify the project location. Provide the
street address, lot number or legal description (attach) and, outside urban areas, the distance to the nearest intersecting road or well-
known landmark. A map attached to this application, and a sketch showing the project layout would be helpful.
11
APPLICATION # PAGE 2 of 4
DESCRIPTION OF WORK (Check all applicable boxes):
A. STRUCTURAL DEVELOPMENT
ACTIVITY STRUCTURE TYPE
□New Structure □Residential (1 -4 Family)
□Addition □Residential (More than 4 Family)
□Alteration □Non-residential (Floodproofing? □ Yes □ No)
□Relocation □Combined Use (Residential & Commercial)
□Demolition □Manufactured (Mobile) Home
□Replacement (In Manufactured Home Park? □ Yes □ No)
ESTIMATED COST OF PROJECT $
B. OTHER DEVELOPMENT ACTIVITIES:
□ Fill □ Mining □ Drilling □ Grading
□ Excavation (Except for Structural Development Checked Above)
□ Watercourse Alteration (Including Dredging and Channel Modifications)
□ Drainage Improvements (Including Culvert Work), Stormwater Control Structures or Ponds
□ Road, Street or Bridge Construction
□ Subdivision (New or Expansion)
□ Individual Water or Sewer System
□ Other (Please Specify)
After completing SECTION 2, APPLICANT should submit form to Local Administrator for review.
SECTION 3: FLOODPLAIN DETERMINATION (To be completed by LOCAL ADMINISTRATOR)
The proposed development is located on FIRM Panel No. , Dated .
The Proposed Development:
□ The proposed development is reasonably safe from flooding. Entire property is in Zone B, C or X.
□ The proposed development is in adjacent to a flood prone area.
100-Year fl ood elevation at the site is:
Ft. □ NGVD 1929/ □ NAVD 1988 (MSL)
□ Unavailable
□ See Section 4 for additional instructions for development that is or may be in a fl ood prone area.
SIGNED DATE
APPLICATION # page 3 of 4
SECTION 4: ADDITIONAL INFORMATION REOLIRED (To be completed by LOCAL ADMINISTRATOR)
The applicant must submit the documents checked below before the application can be processed:
□ A site plan showing the location of all existing structures, water bodies, adjacent roads, lot dimensions and proposed
development.
□ Development plans and specifications, dra\vn to scale, including where applicable: details for anchoring structures, pro
posed elevation of lowest floor (including basement), t>'pes of water resistant materials used below the first floor, details
of floodproofing of utilities located below the first floor, details of enclosures below the first floor, openings in founda
tion for entry and exit of floodwaters.
Other ^
□ Elevation Certificate
□ Subdivision or other development plans (If the subdivision or other development exceeds 50 lots or 5 acres, which
ever is the lesser, the applicant must provide 100-year flood elevations if they are not otherwise available).
□ Plans showing the watercourse location, proposed relocations, Floodway location.
□ Topographic information showing existing and proposed grades, location of all proposed fill.
□ Top of new fill elevation Ft. □ NO VD 1929/ □ NAVD 1988 (MSL)
□ PE Certification of Soil Compaction
□ Floodproofing protection level (non-residential only) □ NGVD 1929/ □ NAVD 1988 (MSL)
For floodproofed structures, applicant must attach certification from registered engineer or architect.
□ Other:
SECTION 5: PERMIT DETERMINATION (To be completed bv LOCAL ADMINISTRATOR)
I have determined that the proposed activity: A. □ Is
B. □ Is not
in conformance with provisions of Local Law # , (yr) . This permit is herby issued subject to the conditions at
tached to and made part of this permit.
SIGNED , DATE
If BOX A is checked, the Local Administrator may issue a Development Permit upon payment of designated fee.
If BOX B is checked, the Local Administrator will provide a written summary of deficiencies. Applicant may revise and resubmit an
application to the Local Administrator or may request a hearing from the Board of Appeals.
Expiration Date:
IV
APPLICATION # Page 4 of 4 .
APPEALS: Appealed to Board of Appeals? □ Yes □ No
■ Hearing date: ^
Appeals Board Decision — Approved? □ Yes □ No
Conditions:
SECTION 6: AS-BUILT ELEVATIONS CTo be submitted bv APPLICANT before Certificate of Compliance is issuedl
The following information must be provided for project sthictures. This section must be completed by a registered professional engi
neer or a licensed land surveyor (or attach a certification to this application). Complete 1 or 2 below. •
, I1. . Actual (As-Built) Elevation ofthe top of the lowest.floor, including basement ("in Coastal High Hazard Areas, bottom oflow-
est structural member of the lowest floor, excluding piling and columns) is: FT.
.□ - NGVD 1929/ □ NAVD 1988 (MSL).
Attach Elevation Certificate FEMA Form 81-31
2. Acmal (As-Built) Elevation of fl oodproofing protection is FT. □ NGVD 1929/ □ NAVD 1988 (MSL).
Attach Floodproofing Certificate FEMA Form 81-65 ,
NOTE: Any work performed prior to submittal of the above information is at the risk of the Applicant."
SECTION 7: COMPLIANCE ACTION tTo be completed bv LOCAL ADMINISTRATORS
The LOCAL ADME^TRATOR will complete this section as applicable based on inspection of the project to ensure compliance
with the community's local law for flood damage prevention. - • '
INSPECTIONS: DATE BY DEFICIENCiES? □ YES □ NO •
DATE BY DEFICIENCIES?□YES □ NO
DATE BY DEFICIENCIES?□YES □ NO
SECTION 8: CERTIFICATE OF COMPLIANCEfTo be completed bv LOCAL ADMINISTRATORS
Certificate of Compliance issued: DATE:^ ^^'
BY:
Attachment B
SAMPLE
CERTIFICATE OF COMPLIANCE
for Development in a* Special Flood Hazard Area
CERTIFICATE OF COMPLIANCE
FOR DEVELOPMENT IN A SPECIAL FLOOD HAZARD AREA
(Owner Must Retain This Certificate)
I
Premises located at:
Owner:
Owner's Address:
Permit No. Permit Date:
Check One:
New Building
^Existing Building
Fill
Other:
The Local Floodplain Administrator is to complete a. or b. below:
a. Compliance is hereby certified with the requirements of Local Law No. , (yr) .
Signed: Dated:
b. Compliance is hereby certified with the requirements of Local Law No. , (yr) , as modified by
variance no. , dated .
Signed: Dated:
11
INTERMUNICIPAL FLOODPLAIN
MANAGEMENT AGREEMENT
THIS AGREEMENT made as of the date of its execution by both parties is by and
between ^ ("County"), a municipal corporation under the laws of the State of
New York with offices at , New York and the TOWN OF
^, ("Town"), a municipal corporation under the laws of the State of New
York, with offices at .New York .
WHEREAS, the Federal Emergency Management Agency (FEMA) and the New York
State Department of Environmental Conservation (NYSDEC) have promulgated regulations
concerning the National Flood Insurance Program (NFIP), which, inter alia, require towns to
enact a local law adopting certain floodplain management regulations; and
WHEREAS, the local law must include the designation of a "Local Administrator" as
defined in such local law to administer and implement the provisions of the local law including
enforcement thereof; and
WHEREAS, the Town has or will adopt a local law naming the
" as the local administrator; and
WHEREAS, County has personnel trained in building code administration
and enforcement activities and has the knowledge and expertise to administer and enforce the
applicable floodplain management requirements; and ' .
WHEREAS, County is willing and able to assist the Town by undertaking
to act as the Local Administrator on behalf of the Town in accord with the Town floodplain
prevention local law; and
WHEREAS, the Town wishes to utilize the services offered by County to
effectuate the purposes of the local law; and
WHEREAS, pursuant to Article 5-G of the General Municipal Law the County and
Town, are authorized to enter into a Municipal Cooperation Agreement with respect to the
activities provided for herein.
NOW THEREFORE, in consideration of the mutual promises set forth herein the •
parties agree as follows:
1. County agrees to act as Local Administrator for the Town under the
Town's local law, which is incorporated herein by reference. The County will so act through
its County Code Enforcement Office.
2. The Town agrees to designate the n as its Local
Administrator under the Town local law for flood damage prevention.
3. The County and Town and their respective officials and employees will fully cooperate to
' effectuate the purposes of this agreement and the underlying floodplain management program
under the National Flood Insurance Program. Such cooperation shall include, but not be
limited to,, sharing information and data received from the federal and state governments,
meeting as necessary to facilitate the efficient administration of the applicable programs,
establishing procedures to identify personnel in each governmental unit who will
communicate information related to activities impacting floodplain issues within the Town.
4. The Town will timely provide County with documents, data, maps, communications from the
federal and state agencies, and related information concerning the floodplain management
program.
5. This agreement shall commence upon its full execution by both parties and continue through
December 31, and shall be automatically renewed for each calendar year thereafter
unless terminated as provided below.
6. Each party shall have the right to terminate this agreement upon one hundred and twenty
(120) days advance written notice to the other. Such notice shall be served by personal
delivery or certified mail to the address set forth above.
7. The Town shall save and hold harmless the County and shall assume all risk and liability for
damage to persons or property and for claims arising from the performance of the
Agreement, excepting the negligence of the County.
IN WITNESSETH WHEREOF, the parties have signed this Agreement on the dates set
forth below.
Dated;
Signature:
Printed Name:
Of the Board of.
TOWN OF
Dated:
Signature:
Printed Name:
Town Supervisor
Model Local Law for Flood Damage Prevention
Optional Additional Language
General Comments.
The Model Local Law for Flood Damage Prevention contains language that complies with the
floodplain management requirements of the National Flood Insurance Program (NFIP) contained
in federal regulations 44 CFR 60.3 through 44 CFR 60.6. These requirements are minimum
requirements for participation in the NFIP. The Federal Emergency Management Agency
(FEMA) has calculated that buildings built to these standards suffer 70% less flood related
damage than unprotected buildings. However, they can still suffer damage, so higher protection
levels are warranted in most instances. For example, floods can be higher than the base flood
elevation for various reasons, including larger storms, downstream obstructions, increased
watershed de\ elopment and floodplain filling. Setting higher standards protects against these
risks.
Many of the following techniques result in lower flood insurance premiums either directly or
through the Community Rating System (CRS). The CRS is a FEMA program that provides
discounts for communities that take measures that are beyond the minimum requirements of the
NFIP. CRS certification requires a community to accumulate at least 500 points. Flood
insurance policies within communities with over 500 CRS points receive a five percent discount
on each individual insurance premium. Flood insurance policies within flood hazard areas in
CRS communities receive an additional five percent discount for each additional 500 points.
Contact NYS DEC or visit the CRS Resource Center at http://training.fema.gov/emiweb/crs/ for
more information about the Community Rating System.
The following pages contain ideas for options to decrease your community's flood risk. These
are all optional. Each page contains an explanation of the measure and language that may be
used. Should your community decide to utilize any of these measures, please make sure that any
changes are brought to the attention of NYSDEC so that we may review the final language and
assure that it is compliant with FEMA's regulations.
For more information about techniques to reduce flood risk in your community, see the
publication "No Adverse Impact: A Toolkit for Common Sense Floodplain Management" by the
Association of State Floodplain Managers (ASFPM). The Toolkit may be viewed at
http://www.floods.org/NoAdverseImpact/NAI Toolkit 2003.pdf or ordered directly from
ASFPM by calling 608-828-3000. Questions about these materials may be addressed to the NYS
DEC Floodplain Management Section at 518-402-8185 or floodpIain@dec.us.gov.
Model Local Law for Flood Damage Prevention
Optional Additional Language
Compensatory Storage.
Explanation: Riverine floodplains and coastal floodplains inland from the "V" wave runup zone
are either approximate "A" zones, which have not had detailed engineering analyses or flood
elevations, or detailed "AE" zones or "A" zones with a number attached, that have detailed flood
elevation studies. In Riverine floodplains with detailed studies, there is usually also a floodway
analysis. Development is exeluded from the floodway unless an engineering analysis determines
that the development results in zero increase in the Base Flood Elevation (elevation of the 100-
year flood). However, development, including fill, is allowed in "A" zones outside of
floodways.
Flood Insurance Studies assume that when the entire riverine floodplain is filled outside of the
floodway, an increase of up to one foot in the Base Flood Elevation will occur at the location of
the encroachment. Some communities may wish to avoid that potential increase, and to also
make certain that an encroachment does not result in increased flood elevations upstream or
downstream of the development, by requiring developments that encroach into the floodplain to
provide compensatory flood storage.
The following language may be used for that purpose. Enforcement of the following policy
could result in up to 70 credits towards flood insurance discounts in communities that participate
in FEMA's Community Rating System (CRS).
To provide compensatory storage for any encroachment within a flood hazard area, add the
following language to your Local Law for Flood Damage Prevention. Note that your
community's section numbering may be different. Contact NYS DEC for assistance.
Add a new Part to Section 5.1-2: "Encroacliments".
Whenever any portion ofafloodplain is authorizedfor development, the volume ofspace
occupied by the authorized fill or structure below the base flood elevation shall be
compensated for and balanced by a hydraulically equivalent volume of excavation taken
from below the base flood elevation at or adjacent to the development site. All such
excavations shall be constructed to drain fi-eely to the watercourse. No area below the
waterline ofa pond or other body ofwater can be credited as a compensating excavation.
Model Local Law for Flood Damage Prevention
Optional Additional Language
Repetitive Damage.
Explanation: FEMA's Increased Cost of Compliance (ICC) flood insurance coverage provides
up to $30,000 towards elevating, floodproofmg, demolishing or relocating a structure that has
been substantially damaged or repetitively damaged. However, that coverage is only available to
a repetitively damaged structure within a community that has adopted an ICC definition in its
local law. Should your community wish to add a repetitive damage clause, a change must be
made in the "Substantial Damage" definition.
Should you wish to include the definition, an insured structure which has been damaged twice
within a ten year period for which the average damage equals or exceeds 25% of the market
value of the structure would qualify for up to $30,000 towards elevating, floodproofmg,
demolishing or relocating the structure. Even without the repetitive damage clause, an insured
structure that has been substantially damaged in a single flood event will qualify for this
■increased cost of compliance* coverage.'
Note that the $30,000 in additional insurance coverage is available only up to the total limit of
coverage under the National Flood Insurance Program. That limit is $250,000 for a residential
structure and $500,000 for a non-residential structure. The total insurance claim plus the ICC
claim may not exceed the above limits.
Should you'decide to include a repetitive damage clause, the municipality will be responsible for
keeping track of all flood related structural damages. Also, the requirement to bring a
repetitively damaged structure up to the flood code would hold whether or not the property
owner carries a flood insurance policy. This would apply to a building whether or not there has
been a change in ownership of the building. Should you have questions about this requirement,
please contact NYSDEC.
To add the definition, replace the definition on Page 6 of the model local law with the following
language:
Substantial Damage means damage of any origm sustained by a structure whereby the
cost of restoring the structure to its before damaged condition would equal or exceed 50
percent of the market value of the structure before the damage occurred. Substantial
damage also means flood-related damages sustained by a structure on two separate
occasions during a 10-year periodfor which the cost of repairs at the time of such flood
event, on the average, equals or exceeds 25 percent of the market value of the structure
before the damage occurred.
Model Local Law for Flood Damage Prevention
Optional Additional Language
Cumulative Substantial Improvement.
Explanation. Die NFIP allows improvements valued at up to 50% of the building's pre-
improvement value to be permitted without meeting the flood proteetion.requirements. Over the
years, a community may issue a succession of permits for different repairs or imprpvements to
the same structures. This can greatly increase the overall flood damage potential for the structure
and within a community. The community may wish to define "substantial improvement"
cumulatively so that once a threshold of improvement within a certain length of time is reached,
the structure is considered to be substantially improved and must meet flood protection
requirements.
Enforcement of the following policy could result in up to 110 credits towards flood insurance
discounts in communities that participate in FEMA's Community Rating System (CRS).
To add the requirement, replace the definition of "Substantial improvement on Page 6 of the
model law with the following language:
"Substantial improvement" means any reconstruction, rehabilitation, addition, or other
improvement ofa structure, the cost of which equals or exceeds 50 percent ofthe market
value of the structure before the "start ofconstruction" ofthe improvement. Substantial
improvement also means "cumulative substantial improvement. " The term includes
structures which have .incurred "substantial damage", regardless of the actual repair work
performed. The term does not, however, include either:
(!) any project for improvement ofa structure to correct existing violations of state or
local health, sanitary, or safety code specifications which have been identified by the
local code enforcement official and which are the minimum necessaiy to assure safe
living conditions; or '
(2) any alteration ofa "Historic structure", provided that the alteration will not preclude
the structure's continued designation as a "Historic structure".
In addition, there must be a definition for "Cumulative Substantial Improvement" as follows:
"Cumulative Substantial Improvement" means any reconstruction, rehabilitation,
addition, or other improvement ofa structure that equals or exceeds 50 percent ofthe
market value of the structure at the time ofthe improvement or repair when counted
cumulativelyfor 10 years.
The community may wish to decrease the 50-percent threshold to a lower number, or change the
ten-year tracking period. An alternative approach would be to remove the "cumulative
substantial improvement" language and instead decrease the 50-percent improvement threshold.
Model Local Law for Flood Damage Prevention
. Optional Additional Language
Critical Facilities.
Explanation: Certain special hazard or otherwise critical facilities should not be located within a
flood prone area due to the serious danger to life and health and widespread social or economic
dislocation that would result when the facility is subjected to flooding. Such facilities either
have the potential to create significant environmental or health risk, or are needed for community
support services during a disaster.
Requiring protection for critical facilities serves several puiposes: it reduces threats to life and
health; it reduces damage to vital public facilities; it reduces pollution of floodwaters by
hazardous materials; and it ensures that the facilities will be operable during most flood
emergencies.
The Community Rating System (CRS) provides 100 points to communities that prohibit critical
facilities within the 500-year floodplain.
To add the requirement, add a definition of "Critical Facilities" to page 3 of the Model Local
Law as follows:
Criticalfacilities means:
(1) Sfructiires orfacilities that produce, use, or store highly volatile, flammable,
explosive, toxic and/or water-reactive materials;
(2) Hospitals, nursing homes, and housing likely to contain occupants who
nmy not be sufficiently mobile to avoid death or injury during aflood;
(3) Police stations, fire stations, vehicle and equipment storage facilities, and
emergency operations-centers that are neededforflood response activities
before, during, and after a flood; and
(4) Public and private utility facilities that are vital to maintaining or restoring
normal services to flooded areas before, during, and after aflood.
Add a new Section 5.7 as follows:
5.7 Critical Facilities
In order to prevent potential flood damage to certain facilities that would result in
serious danger to life and health, or widespread social or economic dislocation, no
new criticalfacility shall be located within any Area ofSpecial Flood Hazard, or
within any 500-year flood zone shown as a B zone or a Shaded X zone on the
Community's Flood Insurance Rate Maps.
Model Local Law for Flood Damage Prevention
Optional Additional Language
Areas Behind Levees or below High Hazard Dams.
Explanation: Areas that are protected by levees that "provide at least three feet of protection
above the 100-year flood are usually not mapped as floodprone on FIRM'S. Such levees can fail
or overtop. There are also many areas that would be inundated by floodwaters should an
upstream dam fail or overtop. While the probability of levee or dam failure is low in most areas,
the consequences of such failure are large.
In the case of levees, a community may wish to apply flood elevation requirements to the levee
protected area as though the levee was not there. In the case of a dam, the community may have
access to an inundation" map in the event of a dam failure.
For a community to apply flood protection development standards to areas below dams or behind
levees, it must first have a map of the affected area. To include these areas, the definition of
"Area of special flood hazard" definition would have to be amended to include areas that the
community has identified through a map of levee protected areas and/or darri failure inundation
zones. In addition, Section 3.2, which adopts the Flood Insurance Rate Map and Flood Insurance
Study for the community, would have to be amended to include the appropriate maps.
CORRESPONDENCE LISTING
February 10, 2025
Please review the following correspondence and indicate, by placing your initials in the right-hand column
adjacent to the correspondence, that you wish to receive a copy. We can forward a copy to you via e-mail or
make a hard copy. Please indicate your preference next to your name at the bottom of this form.
Correspondence – Item Please place your
initials here if you wish
to receive a copy
Retention: Permanent
1. Life Long Appreciation Letter
2.
3.
4.
Retention: Six-Year
1.
2.
1.
2.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
Resident comments on construction variance extension
CORRESPONDENCE LISTING
February 10, 2025
Please review the following correspondence and indicate, by placing your initials in the right-hand column
adjacent to the correspondence, that you wish to receive a copy. We can forward a copy to you via e-mail or
make a hard copy. Please indicate your preference next to your name at the bottom of this form.
Correspondence – Item Please place your
initials here if you wish
to receive a copy
Retention: Permanent
1. Resident comment – Persons to be heard/ Zoning
2.
3.
4.
Retention: Six-Year
1. Lifelong Letter
2.
1.
2.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.town.ithaca.ny.us
CORRESPONDENCE LISTING
February 24, 2025
Please review the following correspondence and indicate, by placing your initials in the right-hand column
adjacent to the correspondence, that you wish to receive a copy. We can forward a copy to you via e-mail or
make a hard copy. Please indicate your preference next to your name at the bottom of this form.
Correspondence – Item Please place your
initials here if you wish
to receive a copy
Retention: Permanent
1. NYS Parks Prop. Interest Letter
2.
3.
4.
Retention: Six-Year
2.
1.
2.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
1.30 Day waiver - 381 Pine Tree Rd
CORRESPONDENCE LISTING
March 10, 2025
Please review the following correspondence and indicate, by placing your initials in the right-hand column
adjacent to the correspondence, that you wish to receive a copy. We can forward a copy to you via e-mail or
make a hard copy. Please indicate your preference next to your name at the bottom of this form.
Correspondence – Item Please place your
initials here if you wish
to receive a copy
Retention: Permanent
1. Stewart Resignation
2.
3.
4.
Retention: Six-Year
1.
2.
1.
2.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
CORRESPONDENCE LISTING
March 24, 2025
Please review the following correspondence and indicate, by placing your initials in the right-hand column
adjacent to the correspondence, that you wish to receive a copy. We can forward a copy to you via e-mail or
make a hard copy. Please indicate your preference next to your name at the bottom of this form.
Correspondence – Item Please place your
initials here if you wish
to receive a copy
Retention: Permanent
1. DOT – Speed Limit Reduction Request Approval Judd Falls
2. FEMA Letter
3. Resident Comment – Code Change Request
4. Resident Comment – Telecom Issues
Retention: Six-Year
1. Town of Ulysses – Comprehensive Plan Update
2.
1.
2.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
1
Paulette Rosa
From:Marie/Andrew Molnar <marieandrew93@gmail.com>
Sent:Monday, March 10, 2025 7:21 PM
To:Town Of Ithaca Clerks Department
Cc:CJ Randall; Chris Balestra; Marty Moseley; Rod Howe; Rich Depaolo
Subject:Code change proposal
Categories:Paulette
**WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or
attachments. Any questions please contact the IT department
Hello,
We are writing to formally propose a change to the Town's codes. Given the recent experience with
Verizon, as well as from towns around the country, one 'hole' that exists in our current wireless codes
is that telecom companies applying for new cell infrastructure are providing the very data needed to
prove they need additional antennas. This seems to be a case of the fox guarding the henhouse.
Currently, our code does not definitively charge a consultant with independently validating a
purported gap in voice phone service coverage. We believe doing so would facilitate the work of the
Board and staff to ensure the validity of the complex data presented on these applications. Thus, our
proposal below. The additions are in bold.
Could you please let us know what is the next step for this process?
Thank you.
Marie and Andrew Molnar
§ 270-219Q(1)
The Town, at the expense of the applicant, may employ its own consultants to examine the application and
related documentation. The consultants that the Town may retain include, but are not limited to, professional
structural and/or electrical engineers, attorneys, and other experts reasonably required by the Town to
competently and fully evaluate any application and the resulting construction. Such consultants may be
requested, among other matters, to make recommendations as to whether the criteria for granting approvals and
permits have been met, including whether the applicant's conclusions regarding a significant gap in coverage,
co-location, safety analysis, visual analysis, and structural inspection are valid and supported by generally
accepted and reliable engineering and technical data and standards and whether the personal wireless service
facility as constructed will be in compliance with the approved plans and in accordance with generally accepted
good engineering practices and industry standards. If an applicant claims a significant gap in service
coverage, the consultant shall provide independent field testing of the area in question to test the validity
of the gap of voice phone service. The timing of this testing shall not be communicated to the applicant.
On Mon, Mar 3, 2025 at 7:49 AMCJ Randall <cjrandall@townithacany.gov> wrote:
Hi Andrew,
2
Please submit any request in writing to the @Town Of Ithaca Clerks Department (copied). Generally
speaking, requests are directed to a associated committee (Codes & Ordinances Committee, Planning
Committee, Public Works Committee, etc.) Amendments to Town Code are at the discretion of the Town
Board.
C.J.
C.J. Randall, LEED AP ND
Director of Planning
Town of Ithaca
215 N Tioga St
Ithaca, NY 14850-4357
607-273-1721 x120
cjrandall@townithacany.gov
The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.
From: Andrew J. Molnar <andrewmolnar11@gmail.com>
Sent: Sunday, March 2, 2025 3:48 PM
To: CJ Randall <cjrandall@townithacany.gov>
Cc: Chris Balestra <CBalestra@townithacany.gov>
Subject: Update
**WARNING** This email comes from an outside source. Please verify the from address, any
URL links, and/or attachments. Any questions please contact the IT department
Hi CJ,
I hope you had a nice vacation away. Could you share the current process to amend our Town
codes?
Thank you.
Andrew
1
Paulette Rosa
From:Marie/Andrew Molnar <marieandrew93@gmail.com>
Sent:Tuesday, March 18, 2025 3:39 PM
To:Codes; Town Of Ithaca Planning; Town Of Ithaca Clerks Department
Cc:CJ Randall; Chris Balestra; Marty Moseley
Subject:Pertinent information as we move forward
Attachments:health effects.png; FactSheet Health v1.04.pdf; EU Scientist-Appeal-5G-Moratorium.pdf;
Air force study on emf.pdf; Safety-of-Wireless-Technologies-Ver5-020525.pdf
**WARNING** This email comes from an outside source. Please verify the from address, any URL links, and/or
attachments. Any questions please contact the IT department
Members of the Planning, Zoning, and Town Boards,
It seems that there may be members of the Ithaca Boards that are still skeptical about cell radiation negatively affecting
health. Since we will likely be dealing with this issue for the foreseeable future, we want to clear up any misinformation
that the telecom industry, and their allies in the media, have spent millions to spread. One example is the claim that
ionizing radiation can only cause damage through thermal effects. Yet, all the way back in 1988, the US Air Force
revealed that this non-ionizing radiation has nonthermal negative effects (attached): "Experimental evidence has
shown that exposure to low intensity radiation can have a profound effect on biological processes. The nonthermal effects
of RF/MW radiation exposure are becoming important measures of biological interaction of EM fields.” More older
military/government studies can be found here.
It is precisely because of the damaging nature of this radiation that our military has weaponized this radiation, in
the form of "Directed Energy Weapons."
The reality is that there there is significant research pointing to the deleterious health and environmental effects of
exposure to pulse-modulated, microwave radiation. Thousands of independent, peer-reviewed scientific studies have
proven that this radiation harms humans, causing cancer, neurodegenerative conditions, DNA damage, and a plethora of
other health issues. Children are 2-10 times more at risk than adults.
In an extensive 10-year $30 million study, the National Institutes of Health and the National Toxicology Program in 2015
concluded that there is indeed a clear link between this radiation and cancer.
Because of these dangers, insurance companies define electromagnetic fields as a "pollutant" in the "high risk" category
and will not cover them. EMF exclusion clauses are the industry standard.
Because of these studies, the World Health Organization places wireless radiation in the same category of
carcinogen as DDT and lead.
Verizon itself acknowledges the dangers. For example in an annual report to the SEC, Verizon states: “We are subject to
a significant amount of litigation, which could require us to pay significant damages or settlements…In addition, our
wireless business also faces personal injury and wrongful death lawsuits relating to alleged health effects of wireless
phones or radio frequency transmitters. We may incur significant expenses in defending these lawsuits. In addition, we
may be required to pay significant awards or settlements.”
More worrisome yet, is that most of these studies and conclusions are from existing cell phone radiation, the new "small
cell" technology associated with 5G requires significantly more transmitting stations than the current technology, causing
people to potentially be exposed to substantially more radiation than existing towers. And the shocking reality is that there
is NO ONE regulating the collective levels of radiation of all these overlapping signals. This is why thousands of doctors
and scientists are warning of the potential health and ecological implications of 5G. The Chair of the Russian National
2
Committee on Non-Ionizing Radiation Protection (the group that resolved the Chernobyl disaster), Professor Oleg
Grigoriev, compares the 5G rollout to a “slow Hiroshima”.
There are many other issues with EMF/RF. Studies are now showing the detrimental environmental effects of this
radiation, including on trees, animals, bees, and other insects, not to mention the significant increase of carbon
emissions of this new rollout.
In sum, there is a proven health and environmental risk with any cell antenna. While you cannot legally mention
this in public as Board members (an immoral and unbelievable contradiction to the very purpose of our codes),
you can certainly be aware of the facts. The future health of Ithacans relies on your being properly informed and
embodying the necessary courage to resist corporate pressure.
Thank you.
Marie and Andrew Molnar
PS: For more in-depth information, see the attached, as well as:
https://www.youtube.com/watch?v=8AfBFiQdgt8
https://www.youtube.com/watch?v=RV9Yk99iJdg
Safety of Wireless Technologies:
The Scientific View
February 2025
“Of the 36 chronic diseases and conditions that more than
doubled (1990-2015), the U.S. Navy study warned us of the
connection between wireless radiation and twenty-three of
those chronic diseases, predicting what has indeed happened
to the health of Americans.”
“By ignoring the earlier science, U.S. regulators failed to
protect the American people from the dangers of wireless
technologies. In doing so, they imposed millions of
unnecessary chronic exposure conditions on the American
public. By 2015, the 23 diseases the U.S. Navy predicted may
have added more than $2 trillion in annual health care costs
to the U.S. economy due to their negligence.”
Co-Authors:
Richard A. Lear. Richard Lear has authored six papers on chronic, germless disease and was the first to quantify the
cost and incidence of the U.S. Health Crisis between 1990 and 2015. His paper, “The Root Cause in the Dramatic
Rise of Chronic Disease”, was also the first to link a common biological profile: a dynamic and synergistic system of
7 bio-factors to all 36 of the fastest-growing chronic conditions in the U.S. Richard is a graduate with honors from
Brown University and founder of four technology companies. Contact: RichardLear@alumni.brown.edu
Camilla R. G. Rees, MBA. Camilla is Senior Policy Adviser, National Institute for Science, Law and Public Policy in
Washington, D.C., Founder, Manhattan Neighbors for Safer Telecommunications and CEO, Wide Angle Health, LLC,
a consultancy championing change agents. A graduate of Barnard College, Columbia University and Georgetown
University Graduate School of Business Administration, she is a published scientist on the effect of radiofrequency
radiation on the heart and brings four decades of business, investment analysis, strategic planning, communications,
and award-winning advocacy experience to support business and advocacy objectives.
Contact: Camilla@ManhattanNeighbors.org, www.CamillaRees.com
Safety of Wireless Technologies: The Scientific View
Wireless technologies have proliferated since 1990. Until now, the impact of wireless
technologies on society has been thought to be largely positive. Wireless technologies offer
convenience and empower mobility while delivering wire-free access and instantaneous
communications. More than 300 million Americans own at least one wireless device and tens of
billions of wireless devices are now in use globally.
We have come to believe that microwave radiation from wireless technologies is safe.
Widespread wireless devices like cell phones, tablets, computers, home appliances and even
wearables use microwaves just like a microwave oven. So, what does the science actually say?
Voice of the Science
There is an extensive history of scientific inquiry into the biological effects and disease
outcomes from low-level exposures to all types of electromagnetic radiation (EMR). The most
significant science links microwave and radiofrequency radiation with more than 140 biological
effects and dozens of seemingly unrelated diseases. The science speaks volumes if we listen.
What follows is a brief history of the landmark science.
1 | Page
Safety of Wireless Technologies: The Scientific View
Wireless technologies have proliferated since 1990. Until now, the impact of wireless
technologies on society has been thought to be largely positive. Wireless technologies offer
convenience and empower mobility while delivering wire-free access and instantaneous
communications. More than 300 million Americans own at least one wireless device and tens of
billions of wireless devices are now in use globally.
We have come to believe that microwave radiation from wireless technologies is safe.
Widespread wireless devices like cell phones, tablets, computers, home appliances and even
wearables use microwaves just like a microwave oven. So, what does the science actually say?
Voice of the Science
There is an extensive history of scientific inquiry into the biological effects and disease
outcomes from low-level exposures to all types of electromagnetic radiation (EMR). The most
significant science links microwave and radiofrequency radiation with more than 140 biological
effects and dozens of seemingly unrelated diseases. The science speaks volumes if we listen.
What follows is a brief history of the landmark science.
1 | Page
Voice of the Science
Safety of Wireless Technologies: The Scientific View
The U.S. Naval Medical Research Institute found 132 biological effects and diseases
from Microwave Radiation in 1971.
The U.S. Navy has long been concerned with the health impacts from wireless signals
generated by communications systems and radar. Beginning in the 1950’s, during the Korean
War, there were consistent reports of health impacts from sailors, who worked closely with
radar. A retrospective Veterans Administration report published in 1976 confirmed substantial
increases in health impacts for Navy personnel exposed to wireless signals. These included:
Reported Health Issue Exposed
Incidence %
Non-Exposed
Incidence %
% Increase Due
to Exposures
Musculoskeletal 16.9 11.9 42%
Systemic Conditions 0.7 0.2 250%
Respiratory 7.3 5.1 45%
Cardiovascular 6.7 4.2 60%
Digestive 7.8 6.76 15%
Lymphatic 0.4 0.3 33%
Endocrine 1.6 1.4 18%
Neurologic 2.3 1.6 44%
Mental Conditions 6.5 5.9 11%
Average Increase in
Incidence - Exposed
Sailors 58%
Data source: Robinette et al 1
In 1971, the U.S. Navy reviewed the global science on microwave radiation from wireless
signals. Lt. Colonel. Zorach Glaser, PhD documented the global science in the meta-study,
“Reported Biological Phenomena (Effects) and Clinical Manifestations Attributed to Microwave
and Radio-Frequency Radiation”.2 Glaser found 2,311 studies that link low-intensity microwave
signals and other EMR with biological impacts. The paper cites 132 different biological effects,
symptoms and diseases associated with wireless exposures. The majority of studies examined
microwave signals in the 1 to 4 gigahertz (GHz) range at low intensities. These types of wireless
exposures are virtually identical with those from modern devices and wireless sources such as
cell phones, WiFi, Bluetooth, smart meters, GPS, wearables, and wireless infrastructure.
2 “Bibliography of Reported Biological Phenomena (Effects) and Clinical Manifestations Attributed to
Microwave and Radio-Frequency Radiation”, Naval Medical Research Institute, October 1971
1 “Effects upon health of occupational exposure to microwave radiation (radar)”, C D Robinette, C
Silverman, S Jablon, American Journal of Epidemiology, 1980.
2 | Page
The U.S. Naval Medical Research Institute found 132 biological effects and diseases
from Microwave Radiation in 1971.
The U.S. Navy has long been concerned with the health impacts from wireless signals
generated by communications systems and radar. Beginning in the 1950’s, during the Korean
War, there were consistent reports of health impacts from sailors, who worked closely with
radar. A retrospective Veterans Administration report published in 1976 confirmed substantial
increases in health impacts for Navy personnel exposed to wireless signals. These included:
Reported Health Issue Exposed
Incidence %
Non-Exposed
Incidence %
% Increase Due
to Exposures
Musculoskeletal 16.9 11.9 42%
Systemic Conditions 0.7 0.2 250%
Respiratory 7.3 5.1 45%
Cardiovascular 6.7 4.2 60%
Digestive 7.8 6.76 15%
Lymphatic 0.4 0.3 33%
Endocrine 1.6 1.4 18%
Neurologic 2.3 1.6 44%
Mental Conditions 6.5 5.9 11%
Average Increase in
Incidence - Exposed
Sailors 58%
Data source: Robinette et al 1
In 1971, the U.S. Navy reviewed the global science on microwave radiation from wireless
signals. Lt. Colonel. Zorach Glaser, PhD documented the global science in the meta-study,
“Reported Biological Phenomena (Effects) and Clinical Manifestations Attributed to Microwave
and Radio-Frequency Radiation”.2 Glaser found 2,311 studies that link low-intensity microwave
signals and other EMR with biological impacts. The paper cites 132 different biological effects,
symptoms and diseases associated with wireless exposures. The majority of studies examined
microwave signals in the 1 to 4 gigahertz (GHz) range at low intensities. These types of wireless
exposures are virtually identical with those from modern devices and wireless sources such as
cell phones, WiFi, Bluetooth, smart meters, GPS, wearables, and wireless infrastructure.
2 “Bibliography of Reported Biological Phenomena (Effects) and Clinical Manifestations Attributed to
Microwave and Radio-Frequency Radiation”, Naval Medical Research Institute, October 1971
1 “Effects upon health of occupational exposure to microwave radiation (radar)”, C D Robinette, C
Silverman, S Jablon, American Journal of Epidemiology, 1980.
2 | Page
The U.S. Naval Medical Research Institute found 132 biological effects and diseases
from Microwave Radiation in 1971.
The U.S. Navy has long been concerned with the health impacts from wireless signals
generated by communications systems and radar. Beginning in the 1950’s, during the Korean
War, there were consistent reports of health impacts from sailors, who worked closely with
radar. A retrospective Veterans Administration report published in 1976 confirmed substantial
increases in health impacts for Navy personnel exposed to wireless signals. These included:
Reported Health Issue Exposed
Incidence %
Non-Exposed
Incidence %
% Increase Due
to Exposures
Musculoskeletal 16.9 11.9 42%
Systemic Conditions 0.7 0.2 250%
Respiratory 7.3 5.1 45%
Cardiovascular 6.7 4.2 60%
Digestive 7.8 6.76 15%
Lymphatic 0.4 0.3 33%
Endocrine 1.6 1.4 18%
Neurologic 2.3 1.6 44%
Mental Conditions 6.5 5.9 11%
Average Increase in
Incidence - Exposed
Sailors 58%
Data source: Robinette et al 1
In 1971, the U.S. Navy reviewed the global science on microwave radiation from wireless
signals. Lt. Colonel. Zorach Glaser, PhD documented the global science in the meta-study,
“Reported Biological Phenomena (Effects) and Clinical Manifestations Attributed to Microwave
and Radio-Frequency Radiation”.2 Glaser found 2,311 studies that link low-intensity microwave
signals and other EMR with biological impacts. The paper cites 132 different biological effects,
symptoms and diseases associated with wireless exposures. The majority of studies examined
microwave signals in the 1 to 4 gigahertz (GHz) range at low intensities. These types of wireless
exposures are virtually identical with those from modern devices and wireless sources such as
cell phones, WiFi, Bluetooth, smart meters, GPS, wearables, and wireless infrastructure.
2 “Bibliography of Reported Biological Phenomena (Effects) and Clinical Manifestations Attributed to
Microwave and Radio-Frequency Radiation”, Naval Medical Research Institute, October 1971
1 “Effects upon health of occupational exposure to microwave radiation (radar)”, C D Robinette, C
Silverman, S Jablon, American Journal of Epidemiology, 1980.
2 | Page
:
The U.S. Naval Medical Research Institute found 132 biological effects and diseases
from Microwave Radiation in 1971.
The U.S. Navy has long been concerned with the health impacts from wireless signals
generated by communications systems and radar. Beginning in the 1950’s, during the Korean
War, there were consistent reports of health impacts from sailors, who worked closely with
radar. A retrospective Veterans Administration report published in 1976 confirmed substantial
increases in health impacts for Navy personnel exposed to wireless signals. These included:
Reported Health Issue Exposed
Incidence %
Non-Exposed
Incidence %
% Increase Due
to Exposures
Musculoskeletal 16.9 11.9 42%
Systemic Conditions 0.7 0.2 250%
Respiratory 7.3 5.1 45%
Cardiovascular 6.7 4.2 60%
Digestive 7.8 6.76 15%
Lymphatic 0.4 0.3 33%
Endocrine 1.6 1.4 18%
Neurologic 2.3 1.6 44%
Mental Conditions 6.5 5.9 11%
Average Increase in
Incidence - Exposed
Sailors 58%
Data source: Robinette et al 1
In 1971, the U.S. Navy reviewed the global science on microwave radiation from wireless
signals. Lt. Colonel. Zorach Glaser, PhD documented the global science in the meta-study,
“Reported Biological Phenomena (Effects) and Clinical Manifestations Attributed to Microwave
and Radio-Frequency Radiation”.2 Glaser found 2,311 studies that link low-intensity microwave
signals and other EMR with biological impacts. The paper cites 132 different biological effects,
symptoms and diseases associated with wireless exposures. The majority of studies examined
microwave signals in the 1 to 4 gigahertz (GHz) range at low intensities. These types of wireless
exposures are virtually identical with those from modern devices and wireless sources such as
cell phones, WiFi, Bluetooth, smart meters, GPS, wearables, and wireless infrastructure.
2 “Bibliography of Reported Biological Phenomena (Effects) and Clinical Manifestations Attributed to
Microwave and Radio-Frequency Radiation”, Naval Medical Research Institute, October 1971
1 “Effects upon health of occupational exposure to microwave radiation (radar)”, C D Robinette, C
Silverman, S Jablon, American Journal of Epidemiology, 1980.
2 | Page
The U.S. Naval Medical Research Institute found 132 biological effects and diseases from Microwave Radiation in 1971.
The U.S. Naval Medical Research Institute found 132 biological effects and diseases
from Microwave Radiation in 1971.
The U.S. Navy has long been concerned with the health impacts from wireless signals
generated by communications systems and radar. Beginning in the 1950’s, during the Korean
War, there were consistent reports of health impacts from sailors, who worked closely with
radar. A retrospective Veterans Administration report published in 1976 confirmed substantial
increases in health impacts for Navy personnel exposed to wireless signals. These included:
Reported Health Issue Exposed
Incidence %
Non-Exposed
Incidence %
% Increase Due
to Exposures
Musculoskeletal 16.9 11.9 42%
Systemic Conditions 0.7 0.2 250%
Respiratory 7.3 5.1 45%
Cardiovascular 6.7 4.2 60%
Digestive 7.8 6.76 15%
Lymphatic 0.4 0.3 33%
Endocrine 1.6 1.4 18%
Neurologic 2.3 1.6 44%
Mental Conditions 6.5 5.9 11%
Average Increase in
Incidence - Exposed
Sailors 58%
Data source: Robinette et al 1
In 1971, the U.S. Navy reviewed the global science on microwave radiation from wireless
signals. Lt. Colonel. Zorach Glaser, PhD documented the global science in the meta-study,
“Reported Biological Phenomena (Effects) and Clinical Manifestations Attributed to Microwave
and Radio-Frequency Radiation”.2 Glaser found 2,311 studies that link low-intensity microwave
signals and other EMR with biological impacts. The paper cites 132 different biological effects,
symptoms and diseases associated with wireless exposures. The majority of studies examined
microwave signals in the 1 to 4 gigahertz (GHz) range at low intensities. These types of wireless
exposures are virtually identical with those from modern devices and wireless sources such as
cell phones, WiFi, Bluetooth, smart meters, GPS, wearables, and wireless infrastructure.
2 “Bibliography of Reported Biological Phenomena (Effects) and Clinical Manifestations Attributed to
Microwave and Radio-Frequency Radiation”, Naval Medical Research Institute, October 1971
1 “Effects upon health of occupational exposure to microwave radiation (radar)”, C D Robinette, C
Silverman, S Jablon, American Journal of Epidemiology, 1980.
2 | Page
Below is a sampling of the categories of biological effects, disorders and changes which Dr.
Glaser found, linking low level microwave radiation to 132 biological effects and diseases3.
More recently publications and review studies have linked wireless and other electromagnetic
fields with even more disease and health conditions. Here are findings from the BioInitiative
Report, a comprehensive 1,540-page report, first published in 2007, co-authored by a group of
29 international scientists.
The 2012 BioInitiative Report, which was also updated over 2014-2022, cites more than 2,200
scientific studies that associate low-level exposures from wireless technologies and other
sources of electromagnetic radiation (EMR) with dozens of diseases and biological effects in
humans4. Here is a sampling:
● Neurological
Effects
● Brain Cancer
● Fetal Effects
● Blood Brain
Barrier Damage
● Immune Effects
● DNA Damage
● Breast Cancer
● Biochemical
Imbalances
● Cancers:
Childhood
● Leukemia
● Decreased
Fertility
● Oxidative
Stress
A key section of the BioInitiative Report, called Henry Lai’s Research Summaries5, in Section 8,
may hold one of the most important keys to the wireless health effects connection. For
example, Lai reports that 263 out of 288 studies reviewed (91%) link wireless signals to
oxidative stress. Most of us know this as free radical damage. This means chronic exposures
from cell phones, WiFi and other wireless signals directly inflict changes in cells across our
delicate biochemistry. In particular, Dr. Lai’s review of the science documents the presence of
high levels of peroxynitrite and super oxide in dozens of studies. So why is this so important?
These two most pernicious molecules, and in particular the oxidative damages they inflict, are
known to radically undermine human health. Peer-reviewed studies show these two molecules
5 Henry Lai’s Research Summaries: https://bioinitiative.org/research-summaries/
4“BioInitiative Report 2012”, 29 Contributing authors, Behari, Bellieni, Belyaev, Blackman, Blank,
Carlberg, Carpenter, Davanipour, Gee, Fragopoulou, Grigoriev, Mild, Hardell, Herbert, Heroux, Kundi,
Lai, Liboff, Li, Margaritis, Nittby, Persson, Oberfeld, PInto, Rajamani, Sage, Salford, Sobel, Thomsen.
https://bioinitiative.org/participants/
3 See Appendix A for a more complete list of impacts found throughout numerous biological systems in
Dr. Glaser’s review of the scientific literature.
3 | Page
● Central Nervous System
● Autonomic Nervous
System
● Genetic/Chromosome
● Vascular Disorders
● Blood Disorders
● Psychological Disorders
● Enzyme/Biochemical
● Metabolic Disorders
● Endocrine System
● Physiological Function
● Gastrointestinal
Below is a sampling of the categories of biological effects, disorders and changes which Dr.
Glaser found, linking low level microwave radiation to 132 biological effects and diseases3.
More recently publications and review studies have linked wireless and other electromagnetic
fields with even more disease and health conditions. Here are findings from the BioInitiative
Report, a comprehensive 1,540-page report, first published in 2007, co-authored by a group of
29 international scientists.
The 2012 BioInitiative Report, which was also updated over 2014-2022, cites more than 2,200
scientific studies that associate low-level exposures from wireless technologies and other
sources of electromagnetic radiation (EMR) with dozens of diseases and biological effects in
humans4. Here is a sampling:
● Neurological
Effects
● Brain Cancer
● Fetal Effects
● Blood Brain
Barrier Damage
● Immune Effects
● DNA Damage
● Breast Cancer
● Biochemical
Imbalances
● Cancers:
Childhood
● Leukemia
● Decreased
Fertility
● Oxidative
Stress
A key section of the BioInitiative Report, called Henry Lai’s Research Summaries5, in Section 8,
may hold one of the most important keys to the wireless health effects connection. For
example, Lai reports that 263 out of 288 studies reviewed (91%) link wireless signals to
oxidative stress. Most of us know this as free radical damage. This means chronic exposures
from cell phones, WiFi and other wireless signals directly inflict changes in cells across our
delicate biochemistry. In particular, Dr. Lai’s review of the science documents the presence of
high levels of peroxynitrite and super oxide in dozens of studies. So why is this so important?
These two most pernicious molecules, and in particular the oxidative damages they inflict, are
known to radically undermine human health. Peer-reviewed studies show these two molecules
5 Henry Lai’s Research Summaries: https://bioinitiative.org/research-summaries/
4“BioInitiative Report 2012”, 29 Contributing authors, Behari, Bellieni, Belyaev, Blackman, Blank,
Carlberg, Carpenter, Davanipour, Gee, Fragopoulou, Grigoriev, Mild, Hardell, Herbert, Heroux, Kundi,
Lai, Liboff, Li, Margaritis, Nittby, Persson, Oberfeld, PInto, Rajamani, Sage, Salford, Sobel, Thomsen.
https://bioinitiative.org/participants/
3 See Appendix A for a more complete list of impacts found throughout numerous biological systems in
Dr. Glaser’s review of the scientific literature.
3 | Page
● Central Nervous System
● Autonomic Nervous
System
● Genetic/Chromosome
● Vascular Disorders
● Blood Disorders
● Psychological Disorders
● Enzyme/Biochemical
● Metabolic Disorders
● Endocrine System
● Physiological Function
● Gastrointestinal
Below is a sampling of the categories of biological effects, disorders and changes which Dr.
Glaser found, linking low level microwave radiation to 132 biological effects and diseases3.
More recently publications and review studies have linked wireless and other electromagnetic
fields with even more disease and health conditions. Here are findings from the BioInitiative
Report, a comprehensive 1,540-page report, first published in 2007, co-authored by a group of
29 international scientists.
The 2012 BioInitiative Report, which was also updated over 2014-2022, cites more than 2,200
scientific studies that associate low-level exposures from wireless technologies and other
sources of electromagnetic radiation (EMR) with dozens of diseases and biological effects in
humans4. Here is a sampling:
● Neurological
Effects
● Brain Cancer
● Fetal Effects
● Blood Brain
Barrier Damage
● Immune Effects
● DNA Damage
● Breast Cancer
● Biochemical
Imbalances
● Cancers:
Childhood
● Leukemia
● Decreased
Fertility
● Oxidative
Stress
A key section of the BioInitiative Report, called Henry Lai’s Research Summaries5, in Section 8,
may hold one of the most important keys to the wireless health effects connection. For
example, Lai reports that 263 out of 288 studies reviewed (91%) link wireless signals to
oxidative stress. Most of us know this as free radical damage. This means chronic exposures
from cell phones, WiFi and other wireless signals directly inflict changes in cells across our
delicate biochemistry. In particular, Dr. Lai’s review of the science documents the presence of
high levels of peroxynitrite and super oxide in dozens of studies. So why is this so important?
These two most pernicious molecules, and in particular the oxidative damages they inflict, are
known to radically undermine human health. Peer-reviewed studies show these two molecules
5 Henry Lai’s Research Summaries: https://bioinitiative.org/research-summaries/
4“BioInitiative Report 2012”, 29 Contributing authors, Behari, Bellieni, Belyaev, Blackman, Blank,
Carlberg, Carpenter, Davanipour, Gee, Fragopoulou, Grigoriev, Mild, Hardell, Herbert, Heroux, Kundi,
Lai, Liboff, Li, Margaritis, Nittby, Persson, Oberfeld, PInto, Rajamani, Sage, Salford, Sobel, Thomsen.
https://bioinitiative.org/participants/
3 See Appendix A for a more complete list of impacts found throughout numerous biological systems in
Dr. Glaser’s review of the scientific literature.
3 | Page
● Central Nervous System
● Autonomic Nervous
System
● Genetic/Chromosome
● Vascular Disorders
● Blood Disorders
● Psychological Disorders
● Enzyme/Biochemical
● Metabolic Disorders
● Endocrine System
● Physiological Function
● Gastrointestinal
Below is a sampling of the categories of biological effects, disorders and changes which Dr.
Glaser found, linking low level microwave radiation to 132 biological effects and diseases3.
More recently publications and review studies have linked wireless and other electromagnetic
fields with even more disease and health conditions. Here are findings from the BioInitiative
Report, a comprehensive 1,540-page report, first published in 2007, co-authored by a group of
29 international scientists.
The 2012 BioInitiative Report, which was also updated over 2014-2022, cites more than 2,200
scientific studies that associate low-level exposures from wireless technologies and other
sources of electromagnetic radiation (EMR) with dozens of diseases and biological effects in
humans4. Here is a sampling:
● Neurological
Effects
● Brain Cancer
● Fetal Effects
● Blood Brain
Barrier Damage
● Immune Effects
● DNA Damage
● Breast Cancer
● Biochemical
Imbalances
● Cancers:
Childhood
● Leukemia
● Decreased
Fertility
● Oxidative
Stress
A key section of the BioInitiative Report, called Henry Lai’s Research Summaries5, in Section 8,
may hold one of the most important keys to the wireless health effects connection. For
example, Lai reports that 263 out of 288 studies reviewed (91%) link wireless signals to
oxidative stress. Most of us know this as free radical damage. This means chronic exposures
from cell phones, WiFi and other wireless signals directly inflict changes in cells across our
delicate biochemistry. In particular, Dr. Lai’s review of the science documents the presence of
high levels of peroxynitrite and super oxide in dozens of studies. So why is this so important?
These two most pernicious molecules, and in particular the oxidative damages they inflict, are
known to radically undermine human health. Peer-reviewed studies show these two molecules
5 Henry Lai’s Research Summaries: https://bioinitiative.org/research-summaries/
4“BioInitiative Report 2012”, 29 Contributing authors, Behari, Bellieni, Belyaev, Blackman, Blank,
Carlberg, Carpenter, Davanipour, Gee, Fragopoulou, Grigoriev, Mild, Hardell, Herbert, Heroux, Kundi,
Lai, Liboff, Li, Margaritis, Nittby, Persson, Oberfeld, PInto, Rajamani, Sage, Salford, Sobel, Thomsen.
https://bioinitiative.org/participants/
3 See Appendix A for a more complete list of impacts found throughout numerous biological systems in
Dr. Glaser’s review of the scientific literature.
3 | Page
● Central Nervous System
● Autonomic Nervous
System
● Genetic/Chromosome
● Vascular Disorders
● Blood Disorders
● Psychological Disorders
● Enzyme/Biochemical
● Metabolic Disorders
● Endocrine System
● Physiological Function
● Gastrointestinal
Below is a sampling of the categories of biological effects, disorders and changes which Dr.
Glaser found, linking low level microwave radiation to 132 biological effects and diseases3.
More recently publications and review studies have linked wireless and other electromagnetic
fields with even more disease and health conditions. Here are findings from the BioInitiative
Report, a comprehensive 1,540-page report, first published in 2007, co-authored by a group of
29 international scientists.
The 2012 BioInitiative Report, which was also updated over 2014-2022, cites more than 2,200
scientific studies that associate low-level exposures from wireless technologies and other
sources of electromagnetic radiation (EMR) with dozens of diseases and biological effects in
humans4. Here is a sampling:
● Neurological
Effects
● Brain Cancer
● Fetal Effects
● Blood Brain
Barrier Damage
● Immune Effects
● DNA Damage
● Breast Cancer
● Biochemical
Imbalances
● Cancers:
Childhood
● Leukemia
● Decreased
Fertility
● Oxidative
Stress
A key section of the BioInitiative Report, called Henry Lai’s Research Summaries5, in Section 8,
may hold one of the most important keys to the wireless health effects connection. For
example, Lai reports that 263 out of 288 studies reviewed (91%) link wireless signals to
oxidative stress. Most of us know this as free radical damage. This means chronic exposures
from cell phones, WiFi and other wireless signals directly inflict changes in cells across our
delicate biochemistry. In particular, Dr. Lai’s review of the science documents the presence of
high levels of peroxynitrite and super oxide in dozens of studies. So why is this so important?
These two most pernicious molecules, and in particular the oxidative damages they inflict, are
known to radically undermine human health. Peer-reviewed studies show these two molecules
5 Henry Lai’s Research Summaries: https://bioinitiative.org/research-summaries/
4“BioInitiative Report 2012”, 29 Contributing authors, Behari, Bellieni, Belyaev, Blackman, Blank,
Carlberg, Carpenter, Davanipour, Gee, Fragopoulou, Grigoriev, Mild, Hardell, Herbert, Heroux, Kundi,
Lai, Liboff, Li, Margaritis, Nittby, Persson, Oberfeld, PInto, Rajamani, Sage, Salford, Sobel, Thomsen.
https://bioinitiative.org/participants/
3 See Appendix A for a more complete list of impacts found throughout numerous biological systems in
Dr. Glaser’s review of the scientific literature.
3 | Page
● Central Nervous System
● Autonomic Nervous
System
● Genetic/Chromosome
● Vascular Disorders
● Blood Disorders
● Psychological Disorders
● Enzyme/Biochemical
● Metabolic Disorders
● Endocrine System
● Physiological Function
● Gastrointestinal
Below is a sampling of the categories of biological effects, disorders and changes which Dr.
Glaser found, linking low level microwave radiation to 132 biological effects and diseases3.
More recently publications and review studies have linked wireless and other electromagnetic
fields with even more disease and health conditions. Here are findings from the BioInitiative
Report, a comprehensive 1,540-page report, first published in 2007, co-authored by a group of
29 international scientists.
The 2012 BioInitiative Report, which was also updated over 2014-2022, cites more than 2,200
scientific studies that associate low-level exposures from wireless technologies and other
sources of electromagnetic radiation (EMR) with dozens of diseases and biological effects in
humans4. Here is a sampling:
● Neurological
Effects
● Brain Cancer
● Fetal Effects
● Blood Brain
Barrier Damage
● Immune Effects
● DNA Damage
● Breast Cancer
● Biochemical
Imbalances
● Cancers:
Childhood
● Leukemia
● Decreased
Fertility
● Oxidative
Stress
A key section of the BioInitiative Report, called Henry Lai’s Research Summaries5, in Section 8,
may hold one of the most important keys to the wireless health effects connection. For
example, Lai reports that 263 out of 288 studies reviewed (91%) link wireless signals to
oxidative stress. Most of us know this as free radical damage. This means chronic exposures
from cell phones, WiFi and other wireless signals directly inflict changes in cells across our
delicate biochemistry. In particular, Dr. Lai’s review of the science documents the presence of
high levels of peroxynitrite and super oxide in dozens of studies. So why is this so important?
These two most pernicious molecules, and in particular the oxidative damages they inflict, are
known to radically undermine human health. Peer-reviewed studies show these two molecules
5 Henry Lai’s Research Summaries: https://bioinitiative.org/research-summaries/
4“BioInitiative Report 2012”, 29 Contributing authors, Behari, Bellieni, Belyaev, Blackman, Blank,
Carlberg, Carpenter, Davanipour, Gee, Fragopoulou, Grigoriev, Mild, Hardell, Herbert, Heroux, Kundi,
Lai, Liboff, Li, Margaritis, Nittby, Persson, Oberfeld, PInto, Rajamani, Sage, Salford, Sobel, Thomsen.
https://bioinitiative.org/participants/
3 See Appendix A for a more complete list of impacts found throughout numerous biological systems in
Dr. Glaser’s review of the scientific literature.
3 | Page
● Central Nervous System
● Autonomic Nervous
System
● Genetic/Chromosome
● Vascular Disorders
● Blood Disorders
● Psychological Disorders
● Enzyme/Biochemical
● Metabolic Disorders
● Endocrine System
● Physiological Function
● Gastrointestinal
Below is a sampling of the categories of biological effects, disorders and changes which Dr.
Glaser found, linking low level microwave radiation to 132 biological effects and diseases3.
More recently publications and review studies have linked wireless and other electromagnetic
fields with even more disease and health conditions. Here are findings from the BioInitiative
Report, a comprehensive 1,540-page report, first published in 2007, co-authored by a group of
29 international scientists.
The 2012 BioInitiative Report, which was also updated over 2014-2022, cites more than 2,200
scientific studies that associate low-level exposures from wireless technologies and other
sources of electromagnetic radiation (EMR) with dozens of diseases and biological effects in
humans4. Here is a sampling:
● Neurological
Effects
● Brain Cancer
● Fetal Effects
● Blood Brain
Barrier Damage
● Immune Effects
● DNA Damage
● Breast Cancer
● Biochemical
Imbalances
● Cancers:
Childhood
● Leukemia
● Decreased
Fertility
● Oxidative
Stress
A key section of the BioInitiative Report, called Henry Lai’s Research Summaries5, in Section 8,
may hold one of the most important keys to the wireless health effects connection. For
example, Lai reports that 263 out of 288 studies reviewed (91%) link wireless signals to
oxidative stress. Most of us know this as free radical damage. This means chronic exposures
from cell phones, WiFi and other wireless signals directly inflict changes in cells across our
delicate biochemistry. In particular, Dr. Lai’s review of the science documents the presence of
high levels of peroxynitrite and super oxide in dozens of studies. So why is this so important?
These two most pernicious molecules, and in particular the oxidative damages they inflict, are
known to radically undermine human health. Peer-reviewed studies show these two molecules
5 Henry Lai’s Research Summaries: https://bioinitiative.org/research-summaries/
4“BioInitiative Report 2012”, 29 Contributing authors, Behari, Bellieni, Belyaev, Blackman, Blank,
Carlberg, Carpenter, Davanipour, Gee, Fragopoulou, Grigoriev, Mild, Hardell, Herbert, Heroux, Kundi,
Lai, Liboff, Li, Margaritis, Nittby, Persson, Oberfeld, PInto, Rajamani, Sage, Salford, Sobel, Thomsen.
https://bioinitiative.org/participants/
3 See Appendix A for a more complete list of impacts found throughout numerous biological systems in
Dr. Glaser’s review of the scientific literature.
3 | Page
● Central Nervous System
● Autonomic Nervous
System
● Genetic/Chromosome
● Vascular Disorders
● Blood Disorders
● Psychological Disorders
● Enzyme/Biochemical
● Metabolic Disorders
● Endocrine System
● Physiological Function
● Gastrointestinal
Below is a sampling of the categories of biological effects, disorders and changes which Dr.
Glaser found, linking low level microwave radiation to 132 biological effects and diseases3.
More recently publications and review studies have linked wireless and other electromagnetic
fields with even more disease and health conditions. Here are findings from the BioInitiative
Report, a comprehensive 1,540-page report, first published in 2007, co-authored by a group of
29 international scientists.
The 2012 BioInitiative Report, which was also updated over 2014-2022, cites more than 2,200
scientific studies that associate low-level exposures from wireless technologies and other
sources of electromagnetic radiation (EMR) with dozens of diseases and biological effects in
humans4. Here is a sampling:
● Neurological
Effects
● Brain Cancer
● Fetal Effects
● Blood Brain
Barrier Damage
● Immune Effects
● DNA Damage
● Breast Cancer
● Biochemical
Imbalances
● Cancers:
Childhood
● Leukemia
● Decreased
Fertility
● Oxidative
Stress
A key section of the BioInitiative Report, called Henry Lai’s Research Summaries5, in Section 8,
may hold one of the most important keys to the wireless health effects connection. For
example, Lai reports that 263 out of 288 studies reviewed (91%) link wireless signals to
oxidative stress. Most of us know this as free radical damage. This means chronic exposures
from cell phones, WiFi and other wireless signals directly inflict changes in cells across our
delicate biochemistry. In particular, Dr. Lai’s review of the science documents the presence of
high levels of peroxynitrite and super oxide in dozens of studies. So why is this so important?
These two most pernicious molecules, and in particular the oxidative damages they inflict, are
known to radically undermine human health. Peer-reviewed studies show these two molecules
5 Henry Lai’s Research Summaries: https://bioinitiative.org/research-summaries/
4“BioInitiative Report 2012”, 29 Contributing authors, Behari, Bellieni, Belyaev, Blackman, Blank,
Carlberg, Carpenter, Davanipour, Gee, Fragopoulou, Grigoriev, Mild, Hardell, Herbert, Heroux, Kundi,
Lai, Liboff, Li, Margaritis, Nittby, Persson, Oberfeld, PInto, Rajamani, Sage, Salford, Sobel, Thomsen.
https://bioinitiative.org/participants/
3 See Appendix A for a more complete list of impacts found throughout numerous biological systems in
Dr. Glaser’s review of the scientific literature.
3 | Page
● Central Nervous System
● Autonomic Nervous
System
● Genetic/Chromosome
● Vascular Disorders
● Blood Disorders
● Psychological Disorders
● Enzyme/Biochemical
● Metabolic Disorders
● Endocrine System
● Physiological Function
● Gastrointestinal
Below is a sampling of the categories of biological effects, disorders and changes which Dr.
Glaser found, linking low level microwave radiation to 132 biological effects and diseases3.
More recently publications and review studies have linked wireless and other electromagnetic
fields with even more disease and health conditions. Here are findings from the BioInitiative
Report, a comprehensive 1,540-page report, first published in 2007, co-authored by a group of
29 international scientists.
The 2012 BioInitiative Report, which was also updated over 2014-2022, cites more than 2,200
scientific studies that associate low-level exposures from wireless technologies and other
sources of electromagnetic radiation (EMR) with dozens of diseases and biological effects in
humans4. Here is a sampling:
● Neurological
Effects
● Brain Cancer
● Fetal Effects
● Blood Brain
Barrier Damage
● Immune Effects
● DNA Damage
● Breast Cancer
● Biochemical
Imbalances
● Cancers:
Childhood
● Leukemia
● Decreased
Fertility
● Oxidative
Stress
A key section of the BioInitiative Report, called Henry Lai’s Research Summaries5, in Section 8,
may hold one of the most important keys to the wireless health effects connection. For
example, Lai reports that 263 out of 288 studies reviewed (91%) link wireless signals to
oxidative stress. Most of us know this as free radical damage. This means chronic exposures
from cell phones, WiFi and other wireless signals directly inflict changes in cells across our
delicate biochemistry. In particular, Dr. Lai’s review of the science documents the presence of
high levels of peroxynitrite and super oxide in dozens of studies. So why is this so important?
These two most pernicious molecules, and in particular the oxidative damages they inflict, are
known to radically undermine human health. Peer-reviewed studies show these two molecules
5 Henry Lai’s Research Summaries: https://bioinitiative.org/research-summaries/
4“BioInitiative Report 2012”, 29 Contributing authors, Behari, Bellieni, Belyaev, Blackman, Blank,
Carlberg, Carpenter, Davanipour, Gee, Fragopoulou, Grigoriev, Mild, Hardell, Herbert, Heroux, Kundi,
Lai, Liboff, Li, Margaritis, Nittby, Persson, Oberfeld, PInto, Rajamani, Sage, Salford, Sobel, Thomsen.
https://bioinitiative.org/participants/
3 See Appendix A for a more complete list of impacts found throughout numerous biological systems in
Dr. Glaser’s review of the scientific literature.
3 | Page
● Central Nervous System
● Autonomic Nervous
System
● Genetic/Chromosome
● Vascular Disorders
● Blood Disorders
● Psychological Disorders
● Enzyme/Biochemical
● Metabolic Disorders
● Endocrine System
● Physiological Function
● Gastrointestinal
may ultimately be at the heart of the recent explosion of several dozen chronic diseases and
conditions. Studies of other biological effects including neurological, DNA damage, gene
expression, fertility and reproductive effects are also included. DNA damage can lead to
cancer. Most studies showed biological effects. In particular, a list of ‘low-intensity’ studies is
also included. This list shows that biological effects, possibly adverse health effects, could
occur at a radiofrequency radiation intensity much lower than the present international
exposure guidelines, suggesting that new revised guidelines are needed.6
A year before the 2012 BioInitiative Report was published, in 2011, the World Health
Organization (WHO) warned: Microwave radiation from wireless can possibly cause cancer.7 In a
press release on May 31st, the WHO and the International Agency for Research on Cancer
(IARC) classified microwave and radiofrequency radiation from wireless technologies as a
possible human carcinogen (Group 2B).
In these three scientific reviews, above, that together cite more than 4,500 studies on wireless
risks, hundreds of scientists present evidence that at least 140 diseases and biological effects
are directly linked to exposures from low-level radiofrequency or microwave radiation.
Earlier we asked, “What does the science actually say?” If we stop and listen,
the voice of the science could hardly be any clearer.
While the weight of the science conveys a consistent and alarming message regarding the
dangers of low-level wireless exposures, the public perception is still that wireless technologies
are safe. Yet there is no single study that makes that case. Why?
With no evidence for safety and mounting evidence of risk,
how did we get here?
The answer to this knotty question is found in the carefully crafted messages by federal
agencies, industry groups, the media and clever spins on what the science actually says. But
that story is for another day. Instead, let’s first look at the evidence of what followed.
What happened to our health since the wireless revolution,
beginning in 1990?
7 IARC classifies Radiofrequency Electromagnetic Fields as a Possible Human Carcinogen
https://www.iarc.who.int/wp-content/uploads/2018/07/pr208_E.pdf
6 Note, a more recent update of Dr. Lai’s Research Studies (November 2024) was published in
”Electromagnetic Radiation Safety (2024). “Effects of exposure to electromagnetic fields: Thirty years of
research”. https://www.saferemr.com/2018/02/effects-of-exposure-to-electromagnetic.html#290
4 | Page
may ultimately be at the heart of the recent explosion of several dozen chronic diseases and
conditions. Studies of other biological effects including neurological, DNA damage, gene
expression, fertility and reproductive effects are also included. DNA damage can lead to
cancer. Most studies showed biological effects. In particular, a list of ‘low-intensity’ studies is
also included. This list shows that biological effects, possibly adverse health effects, could
occur at a radiofrequency radiation intensity much lower than the present international
exposure guidelines, suggesting that new revised guidelines are needed.6
A year before the 2012 BioInitiative Report was published, in 2011, the World Health
Organization (WHO) warned: Microwave radiation from wireless can possibly cause cancer.7 In a
press release on May 31st, the WHO and the International Agency for Research on Cancer
(IARC) classified microwave and radiofrequency radiation from wireless technologies as a
possible human carcinogen (Group 2B).
In these three scientific reviews, above, that together cite more than 4,500 studies on wireless
risks, hundreds of scientists present evidence that at least 140 diseases and biological effects
are directly linked to exposures from low-level radiofrequency or microwave radiation.
Earlier we asked, “What does the science actually say?” If we stop and listen,
the voice of the science could hardly be any clearer.
While the weight of the science conveys a consistent and alarming message regarding the
dangers of low-level wireless exposures, the public perception is still that wireless technologies
are safe. Yet there is no single study that makes that case. Why?
With no evidence for safety and mounting evidence of risk,
how did we get here?
The answer to this knotty question is found in the carefully crafted messages by federal
agencies, industry groups, the media and clever spins on what the science actually says. But
that story is for another day. Instead, let’s first look at the evidence of what followed.
What happened to our health since the wireless revolution,
beginning in 1990?
7 IARC classifies Radiofrequency Electromagnetic Fields as a Possible Human Carcinogen
https://www.iarc.who.int/wp-content/uploads/2018/07/pr208_E.pdf
6 Note, a more recent update of Dr. Lai’s Research Studies (November 2024) was published in
”Electromagnetic Radiation Safety (2024). “Effects of exposure to electromagnetic fields: Thirty years of
research”. https://www.saferemr.com/2018/02/effects-of-exposure-to-electromagnetic.html#290
4 | Page
Over 50 years ago the Navy revealed a compendium of science warning us of the potential
dangers of wireless back in 1971. With a burgeoning health crisis that has been rapidly
unfolding in the U.S., their research now seems prescient. Of course back then few even knew
about this topic, and outside of government fewer still were paying attention to it. At the time
wireless exposures to the general public were still very rare and low. This was decades before
cell phones and other wireless technologies proliferated. It really wasn’t until the 1990s when
the broader population began to use cell phones and to be chronically-exposed to
environmental wireless radiation that some began to ask the question:
Are wireless technologies really safe?
U.S. Chronic Disease Health Crisis
1990 marks the beginning of the current chronic disease health crisis in the U.S. This same year
roughly correlates with the beginning of the wireless revolution. Statistics culled from the
Centers for Disease Control (CDC), the National Institutes of Health (NIH), and PubMed are
staggering. Between 1990 and 2015, in a population of 321 million, the number of instances
of the 36 fastest-growing chronic diseases and medical conditions mushroomed beyond 704
million.8 In a single generation chronic, germless disease had exploded. Thirty-six diseases and
chronic conditions all more than doubled.
The annual cost in the U.S. to this unprecedented explosion of chronic disease exceeded $2.6
trillion at the time. It seems the average American suddenly had acquired 2.2 chronic health
conditions, up from less than one in 1990.
Many of these diseases and conditions were relatively unknown until the 1990s. Now many are
household names: ADHD, COPD, FMS (Fibromyalgia), MS (multiple sclerosis), IBS (irritable
bowel syndrome), ED (erectile dysfunction) and BPD (bipolar disorder) to name a few.
Other well-known conditions also exploded: Autism (+2,094%), Alzheimer’s (+299%), Sleep
Apnea (430%), Depression (+280%), Diabetes (+305%), and Hypothyroidism (+722%).
8 “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018,
https://www.researchgate.net/publication/303673576_The_Root_Cause_in_the_dramatic_rise_of_Chronic_Disease
5 | Page
T
Over 50 years ago the Navy revealed a compendium of science warning us of the potential
dangers of wireless back in 1971. With a burgeoning health crisis that has been rapidly
unfolding in the U.S., their research now seems prescient. Of course back then few even knew
about this topic, and outside of government fewer still were paying attention to it. At the time
wireless exposures to the general public were still very rare and low. This was decades before
cell phones and other wireless technologies proliferated. It really wasn’t until the 1990s when
the broader population began to use cell phones and to be chronically-exposed to
environmental wireless radiation that some began to ask the question:
Are wireless technologies really safe?
U.S. Chronic Disease Health Crisis
1990 marks the beginning of the current chronic disease health crisis in the U.S. This same year
roughly correlates with the beginning of the wireless revolution. Statistics culled from the
Centers for Disease Control (CDC), the National Institutes of Health (NIH), and PubMed are
staggering. Between 1990 and 2015, in a population of 321 million, the number of instances
of the 36 fastest-growing chronic diseases and medical conditions mushroomed beyond 704
million.8 In a single generation chronic, germless disease had exploded. Thirty-six diseases and
chronic conditions all more than doubled.
The annual cost in the U.S. to this unprecedented explosion of chronic disease exceeded $2.6
trillion at the time. It seems the average American suddenly had acquired 2.2 chronic health
conditions, up from less than one in 1990.
Many of these diseases and conditions were relatively unknown until the 1990s. Now many are
household names: ADHD, COPD, FMS (Fibromyalgia), MS (multiple sclerosis), IBS (irritable
bowel syndrome), ED (erectile dysfunction) and BPD (bipolar disorder) to name a few.
Other well-known conditions also exploded: Autism (+2,094%), Alzheimer’s (+299%), Sleep
Apnea (430%), Depression (+280%), Diabetes (+305%), and Hypothyroidism (+722%).
8 “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018,
https://www.researchgate.net/publication/303673576_The_Root_Cause_in_the_dramatic_rise_of_Chronic_Disease
5 | Page
Are wireless technologies really safe?
U.S. Chronic Disease Health Crisis
Thirty-six diseases and
chronic conditions all more than doubled.
Source: “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018
Yet, despite the massive amount of evidence to the contrary, the media, federal agencies and
the general public doggedly cling to the notion that wireless technologies are harmless (i.e.,
safe). Regulators have persistently claimed that the science showing biological effects is
“inconclusive.” Yet, no public figure or federal agency will officially proclaim, “wireless
technologies are safe.” Why?
The key problem is that federal agencies like the FCC and FDA reject science that considers
low intensity (non-thermal) biological effects of wireless and EMR. This means they refuse to
recognize the studies we just discussed. In fact, no study showing biological effects from
wireless is able to be considered if the wireless signal fails to clearly heat tissue. This thermal
effect limitation opens a convenient loophole. It allows regulators to ignore many thousands of
studies showing biological effects from presently permissible levels of wireless and other EMR.
It also allows regulators to enforce public exposure standards that were developed in the 1950s
at a time when exposures were extremely rare, and usually only found in military and industrial
settings, not population-wide exposures, as today!9
Biological Mechanism
9 Exposure guidelines were also updated In the 1980s, determined based on only two experiments in rodents
and monkeys, below, and confirmed in 1996. “Operant behavior and colonic temperature of Macaca mulatta
exposed to radio frequency fields at and above resonant frequencies”, J O de Lorge, 1984
https://pubmed.ncbi.nlm.nih.gov/6732879/ and “Observing-responses of rats exposed to 1.28- and
5.62-GHz microwaves”, J O de Lorge, C. Ezell, 1980
https://onlinelibrary.wiley.com/doi/abs/10.1002/bem.2250010208
6 | Page
Source: “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018
Yet, despite the massive amount of evidence to the contrary, the media, federal agencies and
the general public doggedly cling to the notion that wireless technologies are harmless (i.e.,
safe). Regulators have persistently claimed that the science showing biological effects is
“inconclusive.” Yet, no public figure or federal agency will officially proclaim, “wireless
technologies are safe.” Why?
The key problem is that federal agencies like the FCC and FDA reject science that considers
low intensity (non-thermal) biological effects of wireless and EMR. This means they refuse to
recognize the studies we just discussed. In fact, no study showing biological effects from
wireless is able to be considered if the wireless signal fails to clearly heat tissue. This thermal
effect limitation opens a convenient loophole. It allows regulators to ignore many thousands of
studies showing biological effects from presently permissible levels of wireless and other EMR.
It also allows regulators to enforce public exposure standards that were developed in the 1950s
at a time when exposures were extremely rare, and usually only found in military and industrial
settings, not population-wide exposures, as today!9
Biological Mechanism
9 Exposure guidelines were also updated In the 1980s, determined based on only two experiments in rodents
and monkeys, below, and confirmed in 1996. “Operant behavior and colonic temperature of Macaca mulatta
exposed to radio frequency fields at and above resonant frequencies”, J O de Lorge, 1984
https://pubmed.ncbi.nlm.nih.gov/6732879/ and “Observing-responses of rats exposed to 1.28- and
5.62-GHz microwaves”, J O de Lorge, C. Ezell, 1980
https://onlinelibrary.wiley.com/doi/abs/10.1002/bem.2250010208
6 | Page
Source: “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018
Yet, despite the massive amount of evidence to the contrary, the media, federal agencies and
the general public doggedly cling to the notion that wireless technologies are harmless (i.e.,
safe). Regulators have persistently claimed that the science showing biological effects is
“inconclusive.” Yet, no public figure or federal agency will officially proclaim, “wireless
technologies are safe.” Why?
The key problem is that federal agencies like the FCC and FDA reject science that considers
low intensity (non-thermal) biological effects of wireless and EMR. This means they refuse to
recognize the studies we just discussed. In fact, no study showing biological effects from
wireless is able to be considered if the wireless signal fails to clearly heat tissue. This thermal
effect limitation opens a convenient loophole. It allows regulators to ignore many thousands of
studies showing biological effects from presently permissible levels of wireless and other EMR.
It also allows regulators to enforce public exposure standards that were developed in the 1950s
at a time when exposures were extremely rare, and usually only found in military and industrial
settings, not population-wide exposures, as today!9
Biological Mechanism
9 Exposure guidelines were also updated In the 1980s, determined based on only two experiments in rodents
and monkeys, below, and confirmed in 1996. “Operant behavior and colonic temperature of Macaca mulatta
exposed to radio frequency fields at and above resonant frequencies”, J O de Lorge, 1984
https://pubmed.ncbi.nlm.nih.gov/6732879/ and “Observing-responses of rats exposed to 1.28- and
5.62-GHz microwaves”, J O de Lorge, C. Ezell, 1980
https://onlinelibrary.wiley.com/doi/abs/10.1002/bem.2250010208
6 | Page
Yet, despite the massive amount of evidence to the contrary, the media, federal agencies and the
general public doggedly cling to the notion that wireless technologies are harmless (i.e., safe).
Regulators have persistently claimed that science showing biological effects is “inconclusive.”
Yet, no public figure or federal agency will officially proclaim, “wireless technologies are safe.”
Why? The key problem is that federal agencies like the FCC and FDA reject science that considers
low intensity (non-thermal) biological effects of wireless and EMR. This means they refuse to
recognize the studies we just discussed. In fact, no study showing biological effects from wireless
is able to be considered if the wireless signal fails to clearly heat tissue. This thermal effect
limitation opens a convenient loophole. It allows regulators to ignore many thousands of studies
showing biological effects from presently permissible levels of wireless and other EMR. It also
allows regulators to enforce public exposure guidelines based on a thermal model that were
developed originally in the 1950s. At the time, exposures were extremely rare, and usually only
found in military and industrial settings, not population-wide exposures, as today!9
In fact, the FCC and FDA never actually established radiofrequency safety standards themselves.
Instead they adopted guidelines based on standards of two NGOs, the American National
Standards Institute (ANSI) and the Institute of Electrical and Electronics Engineers (IEEE),
essentially outsourcing responsibility to technical organizations without biological experience.
9 Exposure guidelines were also updated, again based on the thermal model, in the 1980s, determined
based only on two experiments in rodents and monkeys (see below), and also in 1996. “Operant behavior
and colonic temperature of Macaca mulatta exposed to radio frequency fields at and above resonant
frequencies”, J O de Lorge, 1984 https://pubmed.ncbi.nlm.nih.gov/6732879/ and “Observing-responses
of rats exposed to 1.28- and 5.62-GHz microwaves”, J O de Lorge, C. Ezell, 1980
https://onlinelibrary.wiley.com/doi/abs/10.1002/bem.2250010208
Source: “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018
Yet, despite the massive amount of evidence to the contrary, the media, federal agencies and
the general public doggedly cling to the notion that wireless technologies are harmless (i.e.,
safe). Regulators have persistently claimed that the science showing biological effects is
“inconclusive.” Yet, no public figure or federal agency will officially proclaim, “wireless
technologies are safe.” Why?
The key problem is that federal agencies like the FCC and FDA reject science that considers
low intensity (non-thermal) biological effects of wireless and EMR. This means they refuse to
recognize the studies we just discussed. In fact, no study showing biological effects from
wireless is able to be considered if the wireless signal fails to clearly heat tissue. This thermal
effect limitation opens a convenient loophole. It allows regulators to ignore many thousands of
studies showing biological effects from presently permissible levels of wireless and other EMR.
It also allows regulators to enforce public exposure standards that were developed in the 1950s
at a time when exposures were extremely rare, and usually only found in military and industrial
settings, not population-wide exposures, as today!9
Biological Mechanism
9 Exposure guidelines were also updated In the 1980s, determined based on only two experiments in rodents
and monkeys, below, and confirmed in 1996. “Operant behavior and colonic temperature of Macaca mulatta
exposed to radio frequency fields at and above resonant frequencies”, J O de Lorge, 1984
https://pubmed.ncbi.nlm.nih.gov/6732879/ and “Observing-responses of rats exposed to 1.28- and
5.62-GHz microwaves”, J O de Lorge, C. Ezell, 1980
https://onlinelibrary.wiley.com/doi/abs/10.1002/bem.2250010208
6 | Page
Low levels of electromagnetic energy can affect our health because humans are electrical
creatures. Our biological welfare depends critically on a delicate balance of electrical activity.
Our brains and hearts utilize electrical impulses to function. EKGs measure the electrical activity
of the heart and EEGs gauge the electrical activity in the brain. Trillions of cells exchange
electrical messages, which coordinate and orchestrate our body chemistry.
The key components of these bio-electrical communications, which include ions, neurons and
neurotransmitters, all depend crucially on low-level electrical energy. Even the cells in humans
are electrical, operating at around 70 millivolts. Nobel Prize-nominee Dr. Robert Becker, known
for his work and research in electrophysiology and electromedicine, details the electrical nature
of our bodies in his landmark book, The Body Electric.
So, given the electrical nature of our bodies, what happens to the integrity of the “body
electric” as levels of electrical energy swell all around us? In particular, when will the most
vulnerable to wireless: children, the elderly, and chronically ill persons—pass the tipping point
into a state of imbalance and dysregulation?
This question may already be answered by a phenomenon that has quietly unfolded between
1990-2015. Overall health in the U.S. substantially declined during this period, and there has
been a dramatic, initially unrecognized rise in four chronic disease categories: neurological,
auto-inflammatory, sleep insufficiency, and obesity.
7 | Page
Source: “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018 Yet, despite the massive amount of evidence to the contrary, the media, federal agencies and the general public doggedly cling to the notion that wireless technologies are harmless (i.e., safe). Regulators have persistently claimed that the science showing biological effects is “inconclusive.” Yet, no public figure or federal agency will officially proclaim, “wireless technologies are safe.” Why? The key problem is that federal agencies like the FCC and FDA reject science that considers low intensity (non-thermal) biological effects of wireless and EMR. This means they refuse to recognize the studies we just discussed. In fact, no study showing biological effects from wireless is able to be considered if the wireless signal fails to clearly heat tissue. This thermal effect limitation opens a convenient loophole. It allows regulators to ignore many thousands of studies showing biological effects from presently permissible levels of wireless and other EMR. It also allows regulators to enforce public exposure standards that were developed in the 1950s
at a time when exposures were extremely rare, and usually only found in military and industrial
settings, not population-wide exposures, as today!9
Biological Mechanism
9 Exposure guidelines were also updated In the 1980s, determined based on only two experiments in rodents
and monkeys, below, and confirmed in 1996. “Operant behavior and colonic temperature of Macaca mulatta
exposed to radio frequency fields at and above resonant frequencies”, J O de Lorge, 1984
https://pubmed.ncbi.nlm.nih.gov/6732879/ and “Observing-responses of rats exposed to 1.28- and
5.62-GHz microwaves”, J O de Lorge, C. Ezell, 1980
https://onlinelibrary.wiley.com/doi/abs/10.1002/bem.2250010208
6 | Page
Low levels of electromagnetic energy can affect our health because humans are electrical
creatures. Our biological welfare depends critically on a delicate balance of electrical activity.
Our brains and hearts utilize electrical impulses to function. EKGs measure the electrical activity
of the heart and EEGs gauge the electrical activity in the brain. Trillions of cells exchange
electrical messages, which coordinate and orchestrate our body chemistry.
The key components of these bio-electrical communications, which include ions, neurons and
neurotransmitters, all depend crucially on low-level electrical energy. Even the cells in humans
are electrical, operating at around 70 millivolts. Nobel Prize-nominee Dr. Robert Becker, known
for his work and research in electrophysiology and electromedicine, details the electrical nature
of our bodies in his landmark book, The Body Electric.
So, given the electrical nature of our bodies, what happens to the integrity of the “body
electric” as levels of electrical energy swell all around us? In particular, when will the most
vulnerable to wireless: children, the elderly, and chronically ill persons—pass the tipping point
into a state of imbalance and dysregulation?
This question may already be answered by a phenomenon that has quietly unfolded between
1990-2015. Overall health in the U.S. substantially declined during this period, and there has
been a dramatic, initially unrecognized rise in four chronic disease categories: neurological,
auto-inflammatory, sleep insufficiency, and obesity.
7 | Page
Biological Mechanism
Low levels of electromagnetic energy can affect our health because humans are electrical
creatures. Our biological welfare depends critically on a delicate balance of electrical activity.
Our brains and hearts utilize electrical impulses to function. EKGs measure the electrical activity
of the heart and EEGs gauge the electrical activity in the brain. Trillions of cells exchange
electrical messages, which coordinate and orchestrate our body chemistry.
The key components of these bio-electrical communications, which include ions, neurons and
neurotransmitters, all depend crucially on low-level electrical energy. Even the cells in humans
are electrical, operating at around 70 millivolts. Nobel Prize-nominee Dr. Robert Becker, known
for his work and research in electrophysiology and electromedicine, details the electrical nature
of our bodies in his landmark book, The Body Electric.
So, given the electrical nature of our bodies, what happens to the integrity of the “body
electric” as levels of electrical energy swell all around us? In particular, when will the most
vulnerable to wireless: children, the elderly, and chronically ill persons—pass the tipping point
into a state of imbalance and dysregulation?
This question may already be answered by a phenomenon that has quietly unfolded between
1990-2015. Overall health in the U.S. substantially declined during this period, and there has
been a dramatic, initially unrecognized rise in four chronic disease categories: neurological,
auto-inflammatory, sleep insufficiency, and obesity.
7 | Page
Source: “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018
Causative vs. Correlative
While the timing of the proliferation of wireless technologies and the explosion of chronic
disease correlates, how can we be sure wireless energy is the root cause? Critics remain
reluctant to acknowledge the evidence linking wireless and other EMR to disease. They say
there is no clear biological mechanism connecting the two. Meanwhile, decades of scientific
inquiry actually suggests there may be multiple biological pathways. But with no unifying
theory for a single biological mechanism connecting wireless signals to such a wide variety of
biological impacts, chronic diseases and health conditions, the argument appears to be a
stalemate.10 Until now.
In one study, Dr. Martin Pall, Ph.D., identifies just such a common biological mechanism. Pall’s
“Electromagnetic Fields Act Via Activation of Voltage-Gated Calcium Channels to Produce
Beneficial or Adverse Effects” (2013)11 outlines the process by which a bio-electrical mechanism
enables wireless signals to activate systemic biological chaos and unleash disease. He
describes electrically controlled ion channels in cell membranes that act like switches,
regulating the flow of ion and affected cell functions. Pall cites 23 studies that link
electromagnetic radiation (EMR) similar to that from wireless, with voltage-gated ion channels
switching on and off unpredictably, which in turn greatly increases calcium ion (Ca++) inflows
11 “Electromagnetic fields act via activation of voltage-gated calcium channels to produce beneficial or
adverse effects.” J Cell Mol Med. 2013 Aug; 17(8): 958–965.
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3780531/
10 Note, clarity on mechanism is not a necessary condition for accepting effects.
8 | Page
Source: “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018
Causative vs. Correlative
While the timing of the proliferation of wireless technologies and the explosion of chronic
disease correlates, how can we be sure wireless energy is the root cause? Critics remain
reluctant to acknowledge the evidence linking wireless and other EMR to disease. They say
there is no clear biological mechanism connecting the two. Meanwhile, decades of scientific
inquiry actually suggests there may be multiple biological pathways. But with no unifying
theory for a single biological mechanism connecting wireless signals to such a wide variety of
biological impacts, chronic diseases and health conditions, the argument appears to be a
stalemate.10 Until now.
In one study, Dr. Martin Pall, Ph.D., identifies just such a common biological mechanism. Pall’s
“Electromagnetic Fields Act Via Activation of Voltage-Gated Calcium Channels to Produce
Beneficial or Adverse Effects” (2013)11 outlines the process by which a bio-electrical mechanism
enables wireless signals to activate systemic biological chaos and unleash disease. He
describes electrically controlled ion channels in cell membranes that act like switches,
regulating the flow of ion and affected cell functions. Pall cites 23 studies that link
electromagnetic radiation (EMR) similar to that from wireless, with voltage-gated ion channels
switching on and off unpredictably, which in turn greatly increases calcium ion (Ca++) inflows
11 “Electromagnetic fields act via activation of voltage-gated calcium channels to produce beneficial or
adverse effects.” J Cell Mol Med. 2013 Aug; 17(8): 958–965.
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3780531/
10 Note, clarity on mechanism is not a necessary condition for accepting effects.
8 | Page
Source: “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018
Causative vs. Correlative
While the timing of the proliferation of wireless technologies and the explosion of chronic
disease correlates, how can we be sure wireless energy is the root cause? Critics remain
reluctant to acknowledge the evidence linking wireless and other EMR to disease. They say
there is no clear biological mechanism connecting the two. Meanwhile, decades of scientific
inquiry actually suggests there may be multiple biological pathways. But with no unifying
theory for a single biological mechanism connecting wireless signals to such a wide variety of
biological impacts, chronic diseases and health conditions, the argument appears to be a
stalemate.10 Until now.
In one study, Dr. Martin Pall, Ph.D., identifies just such a common biological mechanism. Pall’s
“Electromagnetic Fields Act Via Activation of Voltage-Gated Calcium Channels to Produce
Beneficial or Adverse Effects” (2013)11 outlines the process by which a bio-electrical mechanism
enables wireless signals to activate systemic biological chaos and unleash disease. He
describes electrically controlled ion channels in cell membranes that act like switches,
regulating the flow of ion and affected cell functions. Pall cites 23 studies that link
electromagnetic radiation (EMR) similar to that from wireless, with voltage-gated ion channels
switching on and off unpredictably, which in turn greatly increases calcium ion (Ca++) inflows
11 “Electromagnetic fields act via activation of voltage-gated calcium channels to produce beneficial or
adverse effects.” J Cell Mol Med. 2013 Aug; 17(8): 958–965.
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3780531/
10 Note, clarity on mechanism is not a necessary condition for accepting effects.
8 | Page
increasing intracellular calcium levels. EMR-triggered changes in calcium ion levels then lead to
increased levels of nitric oxide (NO) that generates the dangerous oxidative agent,
peroxynitrite (ONOO¯).
Peroxynitrite has been implicated in more than 60 chronic diseases by the National Institutes of
Health (NIH) paper “Nitric Oxide and Peroxynitrite in Health and Disease.”12 This paper details
the massive destructive capabilities of peroxynitrite, including at least 97 biochemical
disruptions. In an interview with the lead author of the paper, Dr. Pal Pacher, he agreed that
peroxynitrite is likely the “smoking gun” for chronic disease. Pacher has authored 260
peer-reviewed publications and is listed among the top 50 most-cited researchers in the world.
The connection between wireless technologies and peroxynitrite is pivotal. When peroxynitrite
levels rise in the body, biological systems are thrown into chaos. “The Root Cause in the
Dramatic Rise of Chronic Disease”13 details the association of peroxynitrite with the 36
fast-growing diseases, all of which have more than doubled since 1990. The article identifies a
system of six common biological markers for all these germless diseases. They are oxidative
stress, nitrative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial dysfunction,
and chronic systemic inflammation.
13 “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018.
https://www.researchgate.net/publication/303673576_The_Root_Cause_in_the_dramatic_rise_of_Chroni
c_Disease
12
Pacher P, Beckman JS, Liaudet L. “Nitric oxide and peroxynitrite in health and disease”. Physiol Rev
2007 Jan; 87(1)315-424
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2248324/
9 | Page
Source: “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018
Causative vs. Correlative
While the timing of the proliferation of wireless technologies and the explosion of chronic
disease correlates, how can we be sure wireless energy is the root cause? Critics remain
reluctant to acknowledge the evidence linking wireless and other EMR to disease. They say
there is no clear biological mechanism connecting the two. Meanwhile, decades of scientific
inquiry actually suggests there may be multiple biological pathways. But with no unifying
theory for a single biological mechanism connecting wireless signals to such a wide variety of
biological impacts, chronic diseases and health conditions, the argument appears to be a
stalemate.10 Until now.
In one study, Dr. Martin Pall, Ph.D., identifies just such a common biological mechanism. Pall’s
“Electromagnetic Fields Act Via Activation of Voltage-Gated Calcium Channels to Produce
Beneficial or Adverse Effects” (2013)11 outlines the process by which a bio-electrical mechanism
enables wireless signals to activate systemic biological chaos and unleash disease. He
describes electrically controlled ion channels in cell membranes that act like switches,
regulating the flow of ion and affected cell functions. Pall cites 23 studies that link
electromagnetic radiation (EMR) similar to that from wireless, with voltage-gated ion channels
switching on and off unpredictably, which in turn greatly increases calcium ion (Ca++) inflows
11 “Electromagnetic fields act via activation of voltage-gated calcium channels to produce beneficial or
adverse effects.” J Cell Mol Med. 2013 Aug; 17(8): 958–965.
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3780531/
10 Note, clarity on mechanism is not a necessary condition for accepting effects.
8 | Page
Source: “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018
Causative vs. Correlative
While the timing of the proliferation of wireless technologies and the explosion of chronic
disease correlates, how can we be sure wireless energy is the root cause? Critics remain
reluctant to acknowledge the evidence linking wireless and other EMR to disease. They say
there is no clear biological mechanism connecting the two. Meanwhile, decades of scientific
inquiry actually suggests there may be multiple biological pathways. But with no unifying
theory for a single biological mechanism connecting wireless signals to such a wide variety of
biological impacts, chronic diseases and health conditions, the argument appears to be a
stalemate.10 Until now.
In one study, Dr. Martin Pall, Ph.D., identifies just such a common biological mechanism. Pall’s
“Electromagnetic Fields Act Via Activation of Voltage-Gated Calcium Channels to Produce
Beneficial or Adverse Effects” (2013)11 outlines the process by which a bio-electrical mechanism
enables wireless signals to activate systemic biological chaos and unleash disease. He
describes electrically controlled ion channels in cell membranes that act like switches,
regulating the flow of ion and affected cell functions. Pall cites 23 studies that link
electromagnetic radiation (EMR) similar to that from wireless, with voltage-gated ion channels
switching on and off unpredictably, which in turn greatly increases calcium ion (Ca++) inflows
11 “Electromagnetic fields act via activation of voltage-gated calcium channels to produce beneficial or
adverse effects.” J Cell Mol Med. 2013 Aug; 17(8): 958–965.
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3780531/
10 Note, clarity on mechanism is not a necessary condition for accepting effects.
8 | Page
Causative vs. Correlative
increasing intracellular calcium levels. EMR-triggered changes in calcium ion levels then lead to
increased levels of nitric oxide (NO) that generates the dangerous oxidative agent,
peroxynitrite (ONOO¯).
Peroxynitrite has been implicated in more than 60 chronic diseases by the National Institutes of
Health (NIH) paper “Nitric Oxide and Peroxynitrite in Health and Disease.”12 This paper details
the massive destructive capabilities of peroxynitrite, including at least 97 biochemical
disruptions. In an interview with the lead author of the paper, Dr. Pal Pacher, he agreed that
peroxynitrite is likely the “smoking gun” for chronic disease. Pacher has authored 260
peer-reviewed publications and is listed among the top 50 most-cited researchers in the world.
The connection between wireless technologies and peroxynitrite is pivotal. When peroxynitrite
levels rise in the body, biological systems are thrown into chaos. “The Root Cause in the
Dramatic Rise of Chronic Disease”13 details the association of peroxynitrite with the 36
fast-growing diseases, all of which have more than doubled since 1990. The article identifies a
system of six common biological markers for all these germless diseases. They are oxidative
stress, nitrative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial dysfunction,
and chronic systemic inflammation.
13 “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018.
https://www.researchgate.net/publication/303673576_The_Root_Cause_in_the_dramatic_rise_of_Chroni
c_Disease
12
Pacher P, Beckman JS, Liaudet L. “Nitric oxide and peroxynitrite in health and disease”. Physiol Rev
2007 Jan; 87(1)315-424
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2248324/
9 | Page
11
increasing intracellular calcium levels. EMR-triggered changes in calcium ion levels then lead to
increased levels of nitric oxide (NO) that generates the dangerous oxidative agent,
peroxynitrite (ONOO¯).
Peroxynitrite has been implicated in more than 60 chronic diseases by the National Institutes of
Health (NIH) paper “Nitric Oxide and Peroxynitrite in Health and Disease.”12 This paper details
the massive destructive capabilities of peroxynitrite, including at least 97 biochemical
disruptions. In an interview with the lead author of the paper, Dr. Pal Pacher, he agreed that
peroxynitrite is likely the “smoking gun” for chronic disease. Pacher has authored 260
peer-reviewed publications and is listed among the top 50 most-cited researchers in the world.
The connection between wireless technologies and peroxynitrite is pivotal. When peroxynitrite
levels rise in the body, biological systems are thrown into chaos. “The Root Cause in the
Dramatic Rise of Chronic Disease”13 details the association of peroxynitrite with the 36
fast-growing diseases, all of which have more than doubled since 1990. The article identifies a
system of six common biological markers for all these germless diseases. They are oxidative
stress, nitrative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial dysfunction,
and chronic systemic inflammation.
13 “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018.
https://www.researchgate.net/publication/303673576_The_Root_Cause_in_the_dramatic_rise_of_Chroni
c_Disease
12
Pacher P, Beckman JS, Liaudet L. “Nitric oxide and peroxynitrite in health and disease”. Physiol Rev
2007 Jan; 87(1)315-424
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2248324/
9 | Page
increasing intracellular calcium levels. EMR-triggered changes in calcium ion levels then lead to
increased levels of nitric oxide (NO) that generates the dangerous oxidative agent,
peroxynitrite (ONOO¯).
Peroxynitrite has been implicated in more than 60 chronic diseases by the National Institutes of
Health (NIH) paper “Nitric Oxide and Peroxynitrite in Health and Disease.”12 This paper details
the massive destructive capabilities of peroxynitrite, including at least 97 biochemical
disruptions. In an interview with the lead author of the paper, Dr. Pal Pacher, he agreed that
peroxynitrite is likely the “smoking gun” for chronic disease. Pacher has authored 260
peer-reviewed publications and is listed among the top 50 most-cited researchers in the world.
The connection between wireless technologies and peroxynitrite is pivotal. When peroxynitrite
levels rise in the body, biological systems are thrown into chaos. “The Root Cause in the
Dramatic Rise of Chronic Disease”13 details the association of peroxynitrite with the 36
fast-growing diseases, all of which have more than doubled since 1990. The article identifies a
system of six common biological markers for all these germless diseases. They are oxidative
stress, nitrative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial dysfunction,
and chronic systemic inflammation.
13 “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018.
https://www.researchgate.net/publication/303673576_The_Root_Cause_in_the_dramatic_rise_of_Chroni
c_Disease
12
Pacher P, Beckman JS, Liaudet L. “Nitric oxide and peroxynitrite in health and disease”. Physiol Rev
2007 Jan; 87(1)315-424
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2248324/
9 | Page
increasing intracellular calcium levels. EMR-triggered changes in calcium ion levels then lead to
increased levels of nitric oxide (NO) that generates the dangerous oxidative agent,
peroxynitrite (ONOO¯).
Peroxynitrite has been implicated in more than 60 chronic diseases by the National Institutes of
Health (NIH) paper “Nitric Oxide and Peroxynitrite in Health and Disease.”12 This paper details
the massive destructive capabilities of peroxynitrite, including at least 97 biochemical
disruptions. In an interview with the lead author of the paper, Dr. Pal Pacher, he agreed that
peroxynitrite is likely the “smoking gun” for chronic disease. Pacher has authored 260
peer-reviewed publications and is listed among the top 50 most-cited researchers in the world.
The connection between wireless technologies and peroxynitrite is pivotal. When peroxynitrite
levels rise in the body, biological systems are thrown into chaos. “The Root Cause in the
Dramatic Rise of Chronic Disease”13 details the association of peroxynitrite with the 36
fast-growing diseases, all of which have more than doubled since 1990. The article identifies a
system of six common biological markers for all these germless diseases. They are oxidative
stress, nitrative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial dysfunction,
and chronic systemic inflammation.
13 “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018.
https://www.researchgate.net/publication/303673576_The_Root_Cause_in_the_dramatic_rise_of_Chroni
c_Disease
12
Pacher P, Beckman JS, Liaudet L. “Nitric oxide and peroxynitrite in health and disease”. Physiol Rev
2007 Jan; 87(1)315-424
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2248324/
9 | Page
Sitting at the heart of chronic disease, peroxynitrite is both an initiator and accelerator of the
system and is also independently associated with all 36 diseases.
Past the Tipping Point?
Statistics on chronic disease suggest millions of people may have already passed the biological
tipping point from exposure to wireless and other electromagnetic radiation. Increasing levels
of electromagnetic energy in the environment helps explain the dramatic rise in biological
dysregulation and chronic disease. In 2003, the World Health Organization (WHO) described
background levels of electromagnetic energy around the world as “many orders of magnitude
times higher” than the natural environment.14 Now, in typical U.S. cities, people are exposed to
wireless radiation levels 40-100 times higher than those described by WHO just over two
decades ago.
The Message Never Got Through
Despite warnings from hundreds of scientists and thousands of studies, linking wireless and
EMR to harmful biological effects and disease, the general public in the U.S. has not been
sufficiently informed. Somehow, the actual science did not make its way through the tight nets
of so many federal agencies.
The FCC, EPA and FDA have failed to warn us of the link between wireless radiation and our
health.
In 1971 the U.S. Navy already knew of the dangers of wireless radiation. They knew that these
microwave signals were not safe for humans. They had enough data to create safer warships
that protected sailors from stray radar signals. Thousands of scientists had tried to warn the rest
of us, producing 2,311 studies, reviewed by Dr. Glaser, showing that low-level wireless radiation
could disrupt our health in no less than 132 different ways. But the message never got through.
Brave New World
Back then, Navy leadership never imagined a world where a two-year old infant might be
playing with a wireless tablet, generating surges of 20,000 microwatts at gigahertz frequencies.
14 3rd International EMF Seminar in China: Electromagnetic Fields and Biological Effects, Guilin China,
October 13-17, 2003
https://www.scribd.com/document/59705174/Electromagnetic-Fields-and-Biological-Effects-3rd-International-EMF-Seminar-in-China
10 | Page
increasing intracellular calcium levels. EMR-triggered changes in calcium ion levels then lead to
increased levels of nitric oxide (NO) that generates the dangerous oxidative agent,
peroxynitrite (ONOO¯).
Peroxynitrite has been implicated in more than 60 chronic diseases by the National Institutes of
Health (NIH) paper “Nitric Oxide and Peroxynitrite in Health and Disease.”12 This paper details
the massive destructive capabilities of peroxynitrite, including at least 97 biochemical
disruptions. In an interview with the lead author of the paper, Dr. Pal Pacher, he agreed that
peroxynitrite is likely the “smoking gun” for chronic disease. Pacher has authored 260
peer-reviewed publications and is listed among the top 50 most-cited researchers in the world.
The connection between wireless technologies and peroxynitrite is pivotal. When peroxynitrite
levels rise in the body, biological systems are thrown into chaos. “The Root Cause in the
Dramatic Rise of Chronic Disease”13 details the association of peroxynitrite with the 36
fast-growing diseases, all of which have more than doubled since 1990. The article identifies a
system of six common biological markers for all these germless diseases. They are oxidative
stress, nitrative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial dysfunction,
and chronic systemic inflammation.
13 “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018.
https://www.researchgate.net/publication/303673576_The_Root_Cause_in_the_dramatic_rise_of_Chroni
c_Disease
12
Pacher P, Beckman JS, Liaudet L. “Nitric oxide and peroxynitrite in health and disease”. Physiol Rev
2007 Jan; 87(1)315-424
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2248324/
9 | Page
increasing intracellular calcium levels. EMR-triggered changes in calcium ion levels then lead to
increased levels of nitric oxide (NO) that generates the dangerous oxidative agent,
peroxynitrite (ONOO¯).
Peroxynitrite has been implicated in more than 60 chronic diseases by the National Institutes of
Health (NIH) paper “Nitric Oxide and Peroxynitrite in Health and Disease.”12 This paper details
the massive destructive capabilities of peroxynitrite, including at least 97 biochemical
disruptions. In an interview with the lead author of the paper, Dr. Pal Pacher, he agreed that
peroxynitrite is likely the “smoking gun” for chronic disease. Pacher has authored 260
peer-reviewed publications and is listed among the top 50 most-cited researchers in the world.
The connection between wireless technologies and peroxynitrite is pivotal. When peroxynitrite
levels rise in the body, biological systems are thrown into chaos. “The Root Cause in the
Dramatic Rise of Chronic Disease”13 details the association of peroxynitrite with the 36
fast-growing diseases, all of which have more than doubled since 1990. The article identifies a
system of six common biological markers for all these germless diseases. They are oxidative
stress, nitrative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial dysfunction,
and chronic systemic inflammation.
13 “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018.
https://www.researchgate.net/publication/303673576_The_Root_Cause_in_the_dramatic_rise_of_Chroni
c_Disease
12
Pacher P, Beckman JS, Liaudet L. “Nitric oxide and peroxynitrite in health and disease”. Physiol Rev
2007 Jan; 87(1)315-424
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2248324/
9 | Page
increasing intracellular calcium levels. EMR-triggered changes in calcium ion levels then lead to
increased levels of nitric oxide (NO) that generates the dangerous oxidative agent,
peroxynitrite (ONOO¯).
Peroxynitrite has been implicated in more than 60 chronic diseases by the National Institutes of
Health (NIH) paper “Nitric Oxide and Peroxynitrite in Health and Disease.”12 This paper details
the massive destructive capabilities of peroxynitrite, including at least 97 biochemical
disruptions. In an interview with the lead author of the paper, Dr. Pal Pacher, he agreed that
peroxynitrite is likely the “smoking gun” for chronic disease. Pacher has authored 260
peer-reviewed publications and is listed among the top 50 most-cited researchers in the world.
The connection between wireless technologies and peroxynitrite is pivotal. When peroxynitrite
levels rise in the body, biological systems are thrown into chaos. “The Root Cause in the
Dramatic Rise of Chronic Disease”13 details the association of peroxynitrite with the 36
fast-growing diseases, all of which have more than doubled since 1990. The article identifies a
system of six common biological markers for all these germless diseases. They are oxidative
stress, nitrative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial dysfunction,
and chronic systemic inflammation.
13 “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018.
https://www.researchgate.net/publication/303673576_The_Root_Cause_in_the_dramatic_rise_of_Chroni
c_Disease
12
Pacher P, Beckman JS, Liaudet L. “Nitric oxide and peroxynitrite in health and disease”. Physiol Rev
2007 Jan; 87(1)315-424
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2248324/
9 | Page
increasing intracellular calcium levels. EMR-triggered changes in calcium ion levels then lead to
increased levels of nitric oxide (NO) that generates the dangerous oxidative agent,
peroxynitrite (ONOO¯).
Peroxynitrite has been implicated in more than 60 chronic diseases by the National Institutes of
Health (NIH) paper “Nitric Oxide and Peroxynitrite in Health and Disease.”12 This paper details
the massive destructive capabilities of peroxynitrite, including at least 97 biochemical
disruptions. In an interview with the lead author of the paper, Dr. Pal Pacher, he agreed that
peroxynitrite is likely the “smoking gun” for chronic disease. Pacher has authored 260
peer-reviewed publications and is listed among the top 50 most-cited researchers in the world.
The connection between wireless technologies and peroxynitrite is pivotal. When peroxynitrite
levels rise in the body, biological systems are thrown into chaos. “The Root Cause in the
Dramatic Rise of Chronic Disease”13 details the association of peroxynitrite with the 36
fast-growing diseases, all of which have more than doubled since 1990. The article identifies a
system of six common biological markers for all these germless diseases. They are oxidative
stress, nitrative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial dysfunction,
and chronic systemic inflammation.
13 “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018.
https://www.researchgate.net/publication/303673576_The_Root_Cause_in_the_dramatic_rise_of_Chroni
c_Disease
12
Pacher P, Beckman JS, Liaudet L. “Nitric oxide and peroxynitrite in health and disease”. Physiol Rev
2007 Jan; 87(1)315-424
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2248324/
9 | Page
Sitting at the heart of chronic disease, peroxynitrite is both an initator and accelerator
of the system and is also independently associated with all 36 diseases.
increasing intracellular calcium levels. EMR-triggered changes in calcium ion levels then lead to increased levels of nitric oxide (NO) that generates the dangerous oxidative agent, peroxynitrite (ONOO¯). Peroxynitrite has been implicated in more than 60 chronic diseases by the National Institutes of Health (NIH) paper “Nitric Oxide and Peroxynitrite in Health and Disease.”12 This paper details the massive destructive capabilities of peroxynitrite, including at least 97 biochemical disruptions. In an interview with the lead author of the paper, Dr. Pal Pacher, he agreed that peroxynitrite is likely the “smoking gun” for chronic disease. Pacher has authored 260 peer-reviewed publications and is listed among the top 50 most-cited researchers in the world.
The connection between wireless technologies and peroxynitrite is pivotal. When peroxynitrite
levels rise in the body, biological systems are thrown into chaos. “The Root Cause in the
Dramatic Rise of Chronic Disease”13 details the association of peroxynitrite with the 36
fast-growing diseases, all of which have more than doubled since 1990. The article identifies a
system of six common biological markers for all these germless diseases. They are oxidative
stress, nitrative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial dysfunction,
and chronic systemic inflammation.
13 “The Root Cause in the Dramatic Rise of Chronic Disease”, R. Lear, ResearchGate 2016, 2018.
https://www.researchgate.net/publication/303673576_The_Root_Cause_in_the_dramatic_rise_of_Chroni
c_Disease
12
Pacher P, Beckman JS, Liaudet L. “Nitric oxide and peroxynitrite in health and disease”. Physiol Rev
2007 Jan; 87(1)315-424
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2248324/
9 | Page
12
Sitting at the heart of chronic disease, peroxynitrite is both an initiator and accelerator of the
system and is also independently associated with all 36 diseases.
Past the Tipping Point?
Statistics on chronic disease suggest millions of people may have already passed the biological
tipping point from exposure to wireless and other electromagnetic radiation. Increasing levels
of electromagnetic energy in the environment helps explain the dramatic rise in biological
dysregulation and chronic disease. In 2003, the World Health Organization (WHO) described
background levels of electromagnetic energy around the world as “many orders of magnitude
times higher” than the natural environment.14 Now, in typical U.S. cities, people are exposed to
wireless radiation levels 40-100 times higher than those described by WHO just over two
decades ago.
The Message Never Got Through
Despite warnings from hundreds of scientists and thousands of studies, linking wireless and
EMR to harmful biological effects and disease, the general public in the U.S. has not been
sufficiently informed. Somehow, the actual science did not make its way through the tight nets
of so many federal agencies.
The FCC, EPA and FDA have failed to warn us of the link between wireless radiation and our
health.
In 1971 the U.S. Navy already knew of the dangers of wireless radiation. They knew that these
microwave signals were not safe for humans. They had enough data to create safer warships
that protected sailors from stray radar signals. Thousands of scientists had tried to warn the rest
of us, producing 2,311 studies, reviewed by Dr. Glaser, showing that low-level wireless radiation
could disrupt our health in no less than 132 different ways. But the message never got through.
Brave New World
Back then, Navy leadership never imagined a world where a two-year old infant might be
playing with a wireless tablet, generating surges of 20,000 microwatts at gigahertz frequencies.
14 3rd International EMF Seminar in China: Electromagnetic Fields and Biological Effects, Guilin China,
October 13-17, 2003
https://www.scribd.com/document/59705174/Electromagnetic-Fields-and-Biological-Effects-3rd-International-EMF-Seminar-in-China
10 | Page
Sitting at the heart of chronic disease, peroxynitrite is both an initiator and accelerator of the
system and is also independently associated with all 36 diseases.
Past the Tipping Point?
Statistics on chronic disease suggest millions of people may have already passed the biological
tipping point from exposure to wireless and other electromagnetic radiation. Increasing levels
of electromagnetic energy in the environment helps explain the dramatic rise in biological
dysregulation and chronic disease. In 2003, the World Health Organization (WHO) described
background levels of electromagnetic energy around the world as “many orders of magnitude
times higher” than the natural environment.14 Now, in typical U.S. cities, people are exposed to
wireless radiation levels 40-100 times higher than those described by WHO just over two
decades ago.
The Message Never Got Through
Despite warnings from hundreds of scientists and thousands of studies, linking wireless and
EMR to harmful biological effects and disease, the general public in the U.S. has not been
sufficiently informed. Somehow, the actual science did not make its way through the tight nets
of so many federal agencies.
The FCC, EPA and FDA have failed to warn us of the link between wireless radiation and our
health.
In 1971 the U.S. Navy already knew of the dangers of wireless radiation. They knew that these
microwave signals were not safe for humans. They had enough data to create safer warships
that protected sailors from stray radar signals. Thousands of scientists had tried to warn the rest
of us, producing 2,311 studies, reviewed by Dr. Glaser, showing that low-level wireless radiation
could disrupt our health in no less than 132 different ways. But the message never got through.
Brave New World
Back then, Navy leadership never imagined a world where a two-year old infant might be
playing with a wireless tablet, generating surges of 20,000 microwatts at gigahertz frequencies.
14 3rd International EMF Seminar in China: Electromagnetic Fields and Biological Effects, Guilin China,
October 13-17, 2003
https://www.scribd.com/document/59705174/Electromagnetic-Fields-and-Biological-Effects-3rd-International-EMF-Seminar-in-China
10 | Page
Sitting at the heart of chronic disease, peroxynitrite is both an initiator and accelerator of the
system and is also independently associated with all 36 diseases.
Past the Tipping Point?
Statistics on chronic disease suggest millions of people may have already passed the biological
tipping point from exposure to wireless and other electromagnetic radiation. Increasing levels
of electromagnetic energy in the environment helps explain the dramatic rise in biological
dysregulation and chronic disease. In 2003, the World Health Organization (WHO) described
background levels of electromagnetic energy around the world as “many orders of magnitude
times higher” than the natural environment.14 Now, in typical U.S. cities, people are exposed to
wireless radiation levels 40-100 times higher than those described by WHO just over two
decades ago.
The Message Never Got Through
Despite warnings from hundreds of scientists and thousands of studies, linking wireless and
EMR to harmful biological effects and disease, the general public in the U.S. has not been
sufficiently informed. Somehow, the actual science did not make its way through the tight nets
of so many federal agencies.
The FCC, EPA and FDA have failed to warn us of the link between wireless radiation and our
health.
In 1971 the U.S. Navy already knew of the dangers of wireless radiation. They knew that these
microwave signals were not safe for humans. They had enough data to create safer warships
that protected sailors from stray radar signals. Thousands of scientists had tried to warn the rest
of us, producing 2,311 studies, reviewed by Dr. Glaser, showing that low-level wireless radiation
could disrupt our health in no less than 132 different ways. But the message never got through.
Brave New World
Back then, Navy leadership never imagined a world where a two-year old infant might be
playing with a wireless tablet, generating surges of 20,000 microwatts at gigahertz frequencies.
14 3rd International EMF Seminar in China: Electromagnetic Fields and Biological Effects, Guilin China,
October 13-17, 2003
https://www.scribd.com/document/59705174/Electromagnetic-Fields-and-Biological-Effects-3rd-International-EMF-Seminar-in-China
10 | Page
Nor did they imagine the average American home, or apartment, would be
flooded with upwards of 17 wireless signals, spraying microwaves at families 24/7.
Nor could they have imagined a day when millions would be wearing wireless watches and
Bluetooth earbuds, each transmitting at 2.5 billion cycles per second right into their brains and
bodies.
11 | Page
Sitting at the heart of chronic disease, peroxynitrite is both an initiator and accelerator of the
system and is also independently associated with all 36 diseases.
Past the Tipping Point?
Statistics on chronic disease suggest millions of people may have already passed the biological
tipping point from exposure to wireless and other electromagnetic radiation. Increasing levels
of electromagnetic energy in the environment helps explain the dramatic rise in biological
dysregulation and chronic disease. In 2003, the World Health Organization (WHO) described
background levels of electromagnetic energy around the world as “many orders of magnitude
times higher” than the natural environment.14 Now, in typical U.S. cities, people are exposed to
wireless radiation levels 40-100 times higher than those described by WHO just over two
decades ago.
The Message Never Got Through
Despite warnings from hundreds of scientists and thousands of studies, linking wireless and
EMR to harmful biological effects and disease, the general public in the U.S. has not been
sufficiently informed. Somehow, the actual science did not make its way through the tight nets
of so many federal agencies.
The FCC, EPA and FDA have failed to warn us of the link between wireless radiation and our
health.
In 1971 the U.S. Navy already knew of the dangers of wireless radiation. They knew that these
microwave signals were not safe for humans. They had enough data to create safer warships
that protected sailors from stray radar signals. Thousands of scientists had tried to warn the rest
of us, producing 2,311 studies, reviewed by Dr. Glaser, showing that low-level wireless radiation
could disrupt our health in no less than 132 different ways. But the message never got through.
Brave New World
Back then, Navy leadership never imagined a world where a two-year old infant might be
playing with a wireless tablet, generating surges of 20,000 microwatts at gigahertz frequencies.
14 3rd International EMF Seminar in China: Electromagnetic Fields and Biological Effects, Guilin China,
October 13-17, 2003
https://www.scribd.com/document/59705174/Electromagnetic-Fields-and-Biological-Effects-3rd-International-EMF-Seminar-in-China
10 | Page
Past the Tipping Point?
Sitting at the heart of chronic disease, peroxynitrite is both an initiator and accelerator of the
system and is also independently associated with all 36 diseases.
Past the Tipping Point?
Statistics on chronic disease suggest millions of people may have already passed the biological
tipping point from exposure to wireless and other electromagnetic radiation. Increasing levels
of electromagnetic energy in the environment helps explain the dramatic rise in biological
dysregulation and chronic disease. In 2003, the World Health Organization (WHO) described
background levels of electromagnetic energy around the world as “many orders of magnitude
times higher” than the natural environment.14 Now, in typical U.S. cities, people are exposed to
wireless radiation levels 40-100 times higher than those described by WHO just over two
decades ago.
The Message Never Got Through
Despite warnings from hundreds of scientists and thousands of studies, linking wireless and
EMR to harmful biological effects and disease, the general public in the U.S. has not been
sufficiently informed. Somehow, the actual science did not make its way through the tight nets
of so many federal agencies.
The FCC, EPA and FDA have failed to warn us of the link between wireless radiation and our
health.
In 1971 the U.S. Navy already knew of the dangers of wireless radiation. They knew that these
microwave signals were not safe for humans. They had enough data to create safer warships
that protected sailors from stray radar signals. Thousands of scientists had tried to warn the rest
of us, producing 2,311 studies, reviewed by Dr. Glaser, showing that low-level wireless radiation
could disrupt our health in no less than 132 different ways. But the message never got through.
Brave New World
Back then, Navy leadership never imagined a world where a two-year old infant might be
playing with a wireless tablet, generating surges of 20,000 microwatts at gigahertz frequencies.
14 3rd International EMF Seminar in China: Electromagnetic Fields and Biological Effects, Guilin China,
October 13-17, 2003
https://www.scribd.com/document/59705174/Electromagnetic-Fields-and-Biological-Effects-3rd-International-EMF-Seminar-in-China
10 | Page
The FCC, EPA and FDA have failed to warn us of the link between wireless radiation
and our health.
Nor did they imagine the average American home, or apartment, would be
flooded with upwards of 17 wireless signals, spraying microwaves at families 24/7.
Nor could they have imagined a day when millions would be wearing wireless watches and
Bluetooth earbuds, each transmitting at 2.5 billion cycles per second right into their brains and
bodies.
11 | Page
Nor did they imagine the average American home, or apartment, would be
flooded with upwards of 17 wireless signals, spraying microwaves at families 24/7.
Nor could they have imagined a day when millions would be wearing wireless watches and
Bluetooth earbuds, each transmitting at 2.5 billion cycles per second right into their brains and
bodies.
11 | Page
Nor did they imagine the average American home, or apartment, would be
flooded with upwards of 17 wireless signals, spraying microwaves at families 24/7.
Nor could they have imagined a day when millions would be wearing wireless watches and
Bluetooth earbuds, each transmitting at 2.5 billion cycles per second right into their brains and
bodies.
11 | Page
This was a simpler time when exposure to wireless was limited to AM/FM radio, airport radar
and the very occasional satellite passing overhead.
Lt. Colonel Zory Glaser of the U.S. Naval Medical Research Institute compiled the most
powerful indictment of wireless ever published. Astonishingly, this was more than 50 years ago.
The study predicted the U.S. Chronic Disease crisis two decades before it even started.
Of the 36 chronic diseases and conditions that more than doubled (1990-2015), the U.S. Navy
study warned us of the connection between wireless radiation and twenty-three, predicting
what has indeed happened to the health of Americans. It is true that other factors may have
also contributed to the chronic disease crisis in America. For instance, sugar consumption,
glyphosate, pesticides and other environmental factors all trigger the production of
peroxynitrite. Yet the depth and breadth of the science is overwhelming when it comes to the
undeniable connection between wireless radiation exposures and chronic disease.
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
1971
Fast-Growing
Conditions
Growth Rate
1990-2015
Reported
Cases
1990-2015
Similar Biological Effects Cited in
Navy Study in 1971
ADHD 139% 5,312,000 Lack of concentration
Anxiety 104% 40,000,000 Anxiety, Increased irritability
Asthma 142% 28,500,000 Increased blood histamine content
12 | Page
Nor did they imagine the average American home, or apartment, would be flooded with upwards
of 17 wireless signals, spraying microwaves at families 24/7.
Nor did they imagine the average American home, or apartment, would be
flooded with upwards of 17 wireless signals, spraying microwaves at families 24/7.
Nor could they have imagined a day when millions would be wearing wireless watches and
Bluetooth earbuds, each transmitting at 2.5 billion cycles per second right into their brains and
bodies.
11 | Page
This was a simpler time when exposure to wireless was limited to AM/FM radio, airport radar
and the very occasional satellite passing overhead.
Lt. Colonel Zory Glaser of the U.S. Naval Medical Research Institute compiled the most
powerful indictment of wireless ever published. Astonishingly, this was more than 50 years ago.
The study predicted the U.S. Chronic Disease crisis two decades before it even started.
Of the 36 chronic diseases and conditions that more than doubled (1990-2015), the U.S. Navy
study warned us of the connection between wireless radiation and twenty-three, predicting
what has indeed happened to the health of Americans. It is true that other factors may have
also contributed to the chronic disease crisis in America. For instance, sugar consumption,
glyphosate, pesticides and other environmental factors all trigger the production of
peroxynitrite. Yet the depth and breadth of the science is overwhelming when it comes to the
undeniable connection between wireless radiation exposures and chronic disease.
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
1971
Fast-Growing
Conditions
Growth Rate
1990-2015
Reported
Cases
1990-2015
Similar Biological Effects Cited in
Navy Study in 1971
ADHD 139% 5,312,000 Lack of concentration
Anxiety 104% 40,000,000 Anxiety, Increased irritability
Asthma 142% 28,500,000 Increased blood histamine content
12 | Page
This was a simpler time when exposure to wireless was limited to AM/FM radio, airport radar
and the very occasional satellite passing overhead.
Lt. Colonel Zory Glaser of the U.S. Naval Medical Research Institute compiled the most
powerful indictment of wireless ever published. Astonishingly, this was more than 50 years ago.
The study predicted the U.S. Chronic Disease crisis two decades before it even started.
Of the 36 chronic diseases and conditions that more than doubled (1990-2015), the U.S. Navy
study warned us of the connection between wireless radiation and twenty-three, predicting
what has indeed happened to the health of Americans. It is true that other factors may have
also contributed to the chronic disease crisis in America. For instance, sugar consumption,
glyphosate, pesticides and other environmental factors all trigger the production of
peroxynitrite. Yet the depth and breadth of the science is overwhelming when it comes to the
undeniable connection between wireless radiation exposures and chronic disease.
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
1971
Fast-Growing
Conditions
Growth Rate
1990-2015
Reported
Cases
1990-2015
Similar Biological Effects Cited in
Navy Study in 1971
ADHD 139% 5,312,000 Lack of concentration
Anxiety 104% 40,000,000 Anxiety, Increased irritability
Asthma 142% 28,500,000 Increased blood histamine content
12 | Page
This was a simpler time when exposure to wireless was limited to AM/FM radio, airport radar
and the very occasional satellite passing overhead.
Lt. Colonel Zory Glaser of the U.S. Naval Medical Research Institute compiled the most
powerful indictment of wireless ever published. Astonishingly, this was more than 50 years ago.
The study predicted the U.S. Chronic Disease crisis two decades before it even started.
Of the 36 chronic diseases and conditions that more than doubled (1990-2015), the U.S. Navy
study warned us of the connection between wireless radiation and twenty-three, predicting
what has indeed happened to the health of Americans. It is true that other factors may have
also contributed to the chronic disease crisis in America. For instance, sugar consumption,
glyphosate, pesticides and other environmental factors all trigger the production of
peroxynitrite. Yet the depth and breadth of the science is overwhelming when it comes to the
undeniable connection between wireless radiation exposures and chronic disease.
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
1971
Fast-Growing
Conditions
Growth Rate
1990-2015
Reported
Cases
1990-2015
Similar Biological Effects Cited in
Navy Study in 1971
ADHD 139% 5,312,000 Lack of concentration
Anxiety 104% 40,000,000 Anxiety, Increased irritability
Asthma 142% 28,500,000 Increased blood histamine content
12 | Page
This was a simpler time when exposure to wireless was limited to AM/FM radio, airport radar
and the very occasional satellite passing overhead.
Lt. Colonel Zory Glaser of the U.S. Naval Medical Research Institute compiled the most
powerful indictment of wireless ever published. Astonishingly, this was more than 50 years ago.
The study predicted the U.S. Chronic Disease crisis two decades before it even started.
Of the 36 chronic diseases and conditions that more than doubled (1990-2015), the U.S. Navy
study warned us of the connection between wireless radiation and twenty-three, predicting
what has indeed happened to the health of Americans. It is true that other factors may have
also contributed to the chronic disease crisis in America. For instance, sugar consumption,
glyphosate, pesticides and other environmental factors all trigger the production of
peroxynitrite. Yet the depth and breadth of the science is overwhelming when it comes to the
undeniable connection between wireless radiation exposures and chronic disease.
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
1971
Fast-Growing
Conditions
Growth Rate
1990-2015
Reported
Cases
1990-2015
Similar Biological Effects Cited in
Navy Study in 1971
ADHD 139% 5,312,000 Lack of concentration
Anxiety 104% 40,000,000 Anxiety, Increased irritability
Asthma 142% 28,500,000 Increased blood histamine content
12 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
Autism 2,094% 4,664,280
Altered fetal development, Alteration in
bio currents of the cerebral cortex,
Structural changes in cerebral cortex
Cataracts 480% 20,500,000
Cataracts
……………………
Chronic Fatigue 11,027% 8,077,200
Fatigue, Memory loss, Lack of
concentration, Headaches,
Sleeplessness, Depression
Depression 280% 20,304,560 Depression
Diabetes 305% 29,100,000 Blood glucose concentration
Erectile Dysfunction 150% 18,000,000 Impotence, Hypogonadism
Fibromyalgia 7,727% 6,346
Fatigue, Memory loss, Concentration,
Headaches, Sleep disorders,
Depression
Hypertension 223% 92,799,900 Hypertension
Hypothyroidism 702% 15 Thyroid enlargement
Insomnia 123% 48,396,250 Insomnia
Leukemia 588% 327,520 Leukopenia, Chromosome aberrations,
mutations, Neoplastic diseases, tumors
Lupus 787% 563,542
Fatigue, Memory loss, Lack of
Concentration, Headaches,
Sleeplessness, Depression
Melanoma 145% 996,587 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Sleep insufficiency 165% 100,825,520 Sleeplessness, Insomnia, Circadian
Rhythms
Squamous Cell Cancer 177% 322,762 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Stroke 262% 6,800,000 Thrombosis (blood clots)
Thyroid Dysfunction 233% 20,000,000 Thyroid enlargement
15 Incidence is included in the Thyroid Dysfunction category, below.
13 | Page
This was a simpler time when exposure to wireless was limited to AM/FM radio, airport radar
and the very occasional satellite passing overhead.
Lt. Colonel Zory Glaser of the U.S. Naval Medical Research Institute compiled the most
powerful indictment of wireless ever published. Astonishingly, this was more than 50 years ago.
The study predicted the U.S. Chronic Disease crisis two decades before it even started.
Of the 36 chronic diseases and conditions that more than doubled (1990-2015), the U.S. Navy
study warned us of the connection between wireless radiation and twenty-three, predicting
what has indeed happened to the health of Americans. It is true that other factors may have
also contributed to the chronic disease crisis in America. For instance, sugar consumption,
glyphosate, pesticides and other environmental factors all trigger the production of
peroxynitrite. Yet the depth and breadth of the science is overwhelming when it comes to the
undeniable connection between wireless radiation exposures and chronic disease.
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
1971
Fast-Growing
Conditions
Growth Rate
1990-2015
Reported
Cases
1990-2015
Similar Biological Effects Cited in
Navy Study in 1971
ADHD 139% 5,312,000 Lack of concentration
Anxiety 104% 40,000,000 Anxiety, Increased irritability
Asthma 142% 28,500,000 Increased blood histamine content
12 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
Autism 2,094% 4,664,280
Altered fetal development, Alteration in
bio currents of the cerebral cortex,
Structural changes in cerebral cortex
Cataracts 480% 20,500,000
Cataracts
……………………
Chronic Fatigue 11,027% 8,077,200
Fatigue, Memory loss, Lack of
concentration, Headaches,
Sleeplessness, Depression
Depression 280% 20,304,560 Depression
Diabetes 305% 29,100,000 Blood glucose concentration
Erectile Dysfunction 150% 18,000,000 Impotence, Hypogonadism
Fibromyalgia 7,727% 6,346
Fatigue, Memory loss, Concentration,
Headaches, Sleep disorders,
Depression
Hypertension 223% 92,799,900 Hypertension
Hypothyroidism 702% 15 Thyroid enlargement
Insomnia 123% 48,396,250 Insomnia
Leukemia 588% 327,520 Leukopenia, Chromosome aberrations,
mutations, Neoplastic diseases, tumors
Lupus 787% 563,542
Fatigue, Memory loss, Lack of
Concentration, Headaches,
Sleeplessness, Depression
Melanoma 145% 996,587 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Sleep insufficiency 165% 100,825,520 Sleeplessness, Insomnia, Circadian
Rhythms
Squamous Cell Cancer 177% 322,762 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Stroke 262% 6,800,000 Thrombosis (blood clots)
Thyroid Dysfunction 233% 20,000,000 Thyroid enlargement
15 Incidence is included in the Thyroid Dysfunction category, below.
13 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
Autism 2,094% 4,664,280
Altered fetal development, Alteration in
bio currents of the cerebral cortex,
Structural changes in cerebral cortex
Cataracts 480% 20,500,000
Cataracts
……………………
Chronic Fatigue 11,027% 8,077,200
Fatigue, Memory loss, Lack of
concentration, Headaches,
Sleeplessness, Depression
Depression 280% 20,304,560 Depression
Diabetes 305% 29,100,000 Blood glucose concentration
Erectile Dysfunction 150% 18,000,000 Impotence, Hypogonadism
Fibromyalgia 7,727% 6,346
Fatigue, Memory loss, Concentration,
Headaches, Sleep disorders,
Depression
Hypertension 223% 92,799,900 Hypertension
Hypothyroidism 702% 15 Thyroid enlargement
Insomnia 123% 48,396,250 Insomnia
Leukemia 588% 327,520 Leukopenia, Chromosome aberrations,
mutations, Neoplastic diseases, tumors
Lupus 787% 563,542
Fatigue, Memory loss, Lack of
Concentration, Headaches,
Sleeplessness, Depression
Melanoma 145% 996,587 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Sleep insufficiency 165% 100,825,520 Sleeplessness, Insomnia, Circadian
Rhythms
Squamous Cell Cancer 177% 322,762 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Stroke 262% 6,800,000 Thrombosis (blood clots)
Thyroid Dysfunction 233% 20,000,000 Thyroid enlargement
15 Incidence is included in the Thyroid Dysfunction category, below.
13 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
Autism 2,094% 4,664,280
Altered fetal development, Alteration in
bio currents of the cerebral cortex,
Structural changes in cerebral cortex
Cataracts 480% 20,500,000
Cataracts
……………………
Chronic Fatigue 11,027% 8,077,200
Fatigue, Memory loss, Lack of
concentration, Headaches,
Sleeplessness, Depression
Depression 280% 20,304,560 Depression
Diabetes 305% 29,100,000 Blood glucose concentration
Erectile Dysfunction 150% 18,000,000 Impotence, Hypogonadism
Fibromyalgia 7,727% 6,346
Fatigue, Memory loss, Concentration,
Headaches, Sleep disorders,
Depression
Hypertension 223% 92,799,900 Hypertension
Hypothyroidism 702% 15 Thyroid enlargement
Insomnia 123% 48,396,250 Insomnia
Leukemia 588% 327,520 Leukopenia, Chromosome aberrations,
mutations, Neoplastic diseases, tumors
Lupus 787% 563,542
Fatigue, Memory loss, Lack of
Concentration, Headaches,
Sleeplessness, Depression
Melanoma 145% 996,587 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Sleep insufficiency 165% 100,825,520 Sleeplessness, Insomnia, Circadian
Rhythms
Squamous Cell Cancer 177% 322,762 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Stroke 262% 6,800,000 Thrombosis (blood clots)
Thyroid Dysfunction 233% 20,000,000 Thyroid enlargement
15 Incidence is included in the Thyroid Dysfunction category, below.
13 | Page
The study predicted the U.S. Chronic Disease crisis two decades before it even started.
This was a simpler time when exposure to wireless was limited to AM/FM radio, airport radar
and the very occasional satellite passing overhead.
Lt. Colonel Zory Glaser of the U.S. Naval Medical Research Institute compiled the most
powerful indictment of wireless ever published. Astonishingly, this was more than 50 years ago.
The study predicted the U.S. Chronic Disease crisis two decades before it even started.
Of the 36 chronic diseases and conditions that more than doubled (1990-2015), the U.S. Navy
study warned us of the connection between wireless radiation and twenty-three, predicting
what has indeed happened to the health of Americans. It is true that other factors may have
also contributed to the chronic disease crisis in America. For instance, sugar consumption,
glyphosate, pesticides and other environmental factors all trigger the production of
peroxynitrite. Yet the depth and breadth of the science is overwhelming when it comes to the
undeniable connection between wireless radiation exposures and chronic disease.
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
1971
Fast-Growing
Conditions
Growth Rate
1990-2015
Reported
Cases
1990-2015
Similar Biological Effects Cited in
Navy Study in 1971
ADHD 139% 5,312,000 Lack of concentration
Anxiety 104% 40,000,000 Anxiety, Increased irritability
Asthma 142% 28,500,000 Increased blood histamine content
12 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971 Autism 2,094% 4,664,280 Altered fetal development, Alteration in bio currents of the cerebral cortex, Structural changes in cerebral cortex Cataracts 480% 20,500,000 Cataracts …………………… Chronic Fatigue 11,027% 8,077,200 Fatigue, Memory loss, Lack of concentration, Headaches, Sleeplessness, Depression Depression 280% 20,304,560 Depression Diabetes 305% 29,100,000 Blood glucose concentration Erectile Dysfunction 150% 18,000,000 Impotence, Hypogonadism
Fibromyalgia 7,727% 6,346
Fatigue, Memory loss, Concentration,
Headaches, Sleep disorders,
Depression
Hypertension 223% 92,799,900 Hypertension
Hypothyroidism 702% 15 Thyroid enlargement
Insomnia 123% 48,396,250 Insomnia
Leukemia 588% 327,520 Leukopenia, Chromosome aberrations,
mutations, Neoplastic diseases, tumors
Lupus 787% 563,542
Fatigue, Memory loss, Lack of
Concentration, Headaches,
Sleeplessness, Depression
Melanoma 145% 996,587 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Sleep insufficiency 165% 100,825,520 Sleeplessness, Insomnia, Circadian
Rhythms
Squamous Cell Cancer 177% 322,762 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Stroke 262% 6,800,000 Thrombosis (blood clots)
Thyroid Dysfunction 233% 20,000,000 Thyroid enlargement
15 Incidence is included in the Thyroid Dysfunction category, below.
13 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
Autism 2,094% 4,664,280
Altered fetal development, Alteration in
bio currents of the cerebral cortex,
Structural changes in cerebral cortex
Cataracts 480% 20,500,000
Cataracts
……………………
Chronic Fatigue 11,027% 8,077,200
Fatigue, Memory loss, Lack of
concentration, Headaches,
Sleeplessness, Depression
Depression 280% 20,304,560 Depression
Diabetes 305% 29,100,000 Blood glucose concentration
Erectile Dysfunction 150% 18,000,000 Impotence, Hypogonadism
Fibromyalgia 7,727% 6,346
Fatigue, Memory loss, Concentration,
Headaches, Sleep disorders,
Depression
Hypertension 223% 92,799,900 Hypertension
Hypothyroidism 702% 15 Thyroid enlargement
Insomnia 123% 48,396,250 Insomnia
Leukemia 588% 327,520 Leukopenia, Chromosome aberrations,
mutations, Neoplastic diseases, tumors
Lupus 787% 563,542
Fatigue, Memory loss, Lack of
Concentration, Headaches,
Sleeplessness, Depression
Melanoma 145% 996,587 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Sleep insufficiency 165% 100,825,520 Sleeplessness, Insomnia, Circadian
Rhythms
Squamous Cell Cancer 177% 322,762 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Stroke 262% 6,800,000 Thrombosis (blood clots)
Thyroid Dysfunction 233% 20,000,000 Thyroid enlargement
15 Incidence is included in the Thyroid Dysfunction category, below.
13 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
Autism 2,094% 4,664,280
Altered fetal development, Alteration in
bio currents of the cerebral cortex,
Structural changes in cerebral cortex
Cataracts 480% 20,500,000
Cataracts
……………………
Chronic Fatigue 11,027% 8,077,200
Fatigue, Memory loss, Lack of
concentration, Headaches,
Sleeplessness, Depression
Depression 280% 20,304,560 Depression
Diabetes 305% 29,100,000 Blood glucose concentration
Erectile Dysfunction 150% 18,000,000 Impotence, Hypogonadism
Fibromyalgia 7,727% 6,346
Fatigue, Memory loss, Concentration,
Headaches, Sleep disorders,
Depression
Hypertension 223% 92,799,900 Hypertension
Hypothyroidism 702% 15 Thyroid enlargement
Insomnia 123% 48,396,250 Insomnia
Leukemia 588% 327,520 Leukopenia, Chromosome aberrations,
mutations, Neoplastic diseases, tumors
Lupus 787% 563,542
Fatigue, Memory loss, Lack of
Concentration, Headaches,
Sleeplessness, Depression
Melanoma 145% 996,587 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Sleep insufficiency 165% 100,825,520 Sleeplessness, Insomnia, Circadian
Rhythms
Squamous Cell Cancer 177% 322,762 Chromosome aberrations, mutations,
Neoplastic diseases, tumors
Stroke 262% 6,800,000 Thrombosis (blood clots)
Thyroid Dysfunction 233% 20,000,000 Thyroid enlargement
15 Incidence is included in the Thyroid Dysfunction category, below.
13 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
Heart Disease -- 125,100,000
Myocardial necrosis, Cholesterol and
lipid changes; EKG changes;
Vagomimetic action of the heart;
Alteration of the heart rhythm
Autoimmune Disease * 221% 24,114,643 Changes in Oxidative processes
Celiac Disease 1,111% 60,000,000 Gastrointestinal disorders
Total Incidence of 23
chronic diseases (2015).
Each was predicted by the
U.S. Navy study in 1971 549,314,860
The 549 million figure above is the total number of reported incidences of 23 of the 36-fast
growing diseases and chronic conditions reported in 2015. These 23 were linked to biological
effects from wireless radiation documented in the U.S. Navy study in 1971.
By ignoring the earlier science, U.S. regulators failed to protect the American people from the
dangers of wireless technologies. In doing so, they imposed millions of unnecessary chronic
exposure conditions on the American public. By 2015, these 23 diseases the U.S. Navy
predicted may have added more than $2 trillion in annual health care costs to the U.S.
economy due to their negligence.
Putting the Puzzle Together
The science fits together like a puzzle with a series of interlinking components. At the heart of it
is our core innate immunity. In an effort to fight off foreign invaders, our immune system
14 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
Heart Disease -- 125,100,000
Myocardial necrosis, Cholesterol and
lipid changes; EKG changes;
Vagomimetic action of the heart;
Alteration of the heart rhythm
Autoimmune Disease * 221% 24,114,643 Changes in Oxidative processes
Celiac Disease 1,111% 60,000,000 Gastrointestinal disorders
Total Incidence of 23
chronic diseases (2015).
Each was predicted by the
U.S. Navy study in 1971 549,314,860
The 549 million figure above is the total number of reported incidences of 23 of the 36-fast
growing diseases and chronic conditions reported in 2015. These 23 were linked to biological
effects from wireless radiation documented in the U.S. Navy study in 1971.
By ignoring the earlier science, U.S. regulators failed to protect the American people from the
dangers of wireless technologies. In doing so, they imposed millions of unnecessary chronic
exposure conditions on the American public. By 2015, these 23 diseases the U.S. Navy
predicted may have added more than $2 trillion in annual health care costs to the U.S.
economy due to their negligence.
Putting the Puzzle Together
The science fits together like a puzzle with a series of interlinking components. At the heart of it
is our core innate immunity. In an effort to fight off foreign invaders, our immune system
14 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
Heart Disease -- 125,100,000
Myocardial necrosis, Cholesterol and
lipid changes; EKG changes;
Vagomimetic action of the heart;
Alteration of the heart rhythm
Autoimmune Disease * 221% 24,114,643 Changes in Oxidative processes
Celiac Disease 1,111% 60,000,000 Gastrointestinal disorders
Total Incidence of 23
chronic diseases (2015).
Each was predicted by the
U.S. Navy study in 1971 549,314,860
The 549 million figure above is the total number of reported incidences of 23 of the 36-fast
growing diseases and chronic conditions reported in 2015. These 23 were linked to biological
effects from wireless radiation documented in the U.S. Navy study in 1971.
By ignoring the earlier science, U.S. regulators failed to protect the American people from the
dangers of wireless technologies. In doing so, they imposed millions of unnecessary chronic
exposure conditions on the American public. By 2015, these 23 diseases the U.S. Navy
predicted may have added more than $2 trillion in annual health care costs to the U.S.
economy due to their negligence.
Putting the Puzzle Together
The science fits together like a puzzle with a series of interlinking components. At the heart of it
is our core innate immunity. In an effort to fight off foreign invaders, our immune system
14 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
Heart Disease -- 125,100,000
Myocardial necrosis, Cholesterol and
lipid changes; EKG changes;
Vagomimetic action of the heart;
Alteration of the heart rhythm
Autoimmune Disease * 221% 24,114,643 Changes in Oxidative processes
Celiac Disease 1,111% 60,000,000 Gastrointestinal disorders
Total Incidence of 23
chronic diseases (2015).
Each was predicted by the
U.S. Navy study in 1971 549,314,860
The 549 million figure above is the total number of reported incidences of 23 of the 36-fast
growing diseases and chronic conditions reported in 2015. These 23 were linked to biological
effects from wireless radiation documented in the U.S. Navy study in 1971.
By ignoring the earlier science, U.S. regulators failed to protect the American people from the
dangers of wireless technologies. In doing so, they imposed millions of unnecessary chronic
exposure conditions on the American public. By 2015, these 23 diseases the U.S. Navy
predicted may have added more than $2 trillion in annual health care costs to the U.S.
economy due to their negligence.
Putting the Puzzle Together
The science fits together like a puzzle with a series of interlinking components. At the heart of it
is our core innate immunity. In an effort to fight off foreign invaders, our immune system
14 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971 Heart Disease -- 125,100,000 Myocardial necrosis, Cholesterol and lipid changes; EKG changes; Vagomimetic action of the heart; Alteration of the heart rhythm Autoimmune Disease * 221% 24,114,643 Changes in Oxidative processes Celiac Disease 1,111% 60,000,000 Gastrointestinal disorders Total Incidence of 23 chronic diseases (2015). Each was predicted by the U.S. Navy study in 1971 549,314,860 The 549 million figure above is the total number of reported incidences of 23 of the 36-fast growing diseases and chronic conditions reported in 2015. These 23 were linked to biological effects from wireless radiation documented in the U.S. Navy study in 1971. By ignoring the earlier science, U.S. regulators failed to protect the American people from the dangers of wireless technologies. In doing so, they imposed millions of unnecessary chronic
exposure conditions on the American public. By 2015, these 23 diseases the U.S. Navy
predicted may have added more than $2 trillion in annual health care costs to the U.S.
economy due to their negligence.
Putting the Puzzle Together
The science fits together like a puzzle with a series of interlinking components. At the heart of it
is our core innate immunity. In an effort to fight off foreign invaders, our immune system
14 | Page
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971
Heart Disease -- 125,100,000
Myocardial necrosis, Cholesterol and
lipid changes; EKG changes;
Vagomimetic action of the heart;
Alteration of the heart rhythm
Autoimmune Disease * 221% 24,114,643 Changes in Oxidative processes
Celiac Disease 1,111% 60,000,000 Gastrointestinal disorders
Total Incidence of 23
chronic diseases (2015).
Each was predicted by the
U.S. Navy study in 1971 549,314,860
The 549 million figure above is the total number of reported incidences of 23 of the 36-fast
growing diseases and chronic conditions reported in 2015. These 23 were linked to biological
effects from wireless radiation documented in the U.S. Navy study in 1971.
By ignoring the earlier science, U.S. regulators failed to protect the American people from the
dangers of wireless technologies. In doing so, they imposed millions of unnecessary chronic
exposure conditions on the American public. By 2015, these 23 diseases the U.S. Navy
predicted may have added more than $2 trillion in annual health care costs to the U.S.
economy due to their negligence.
Putting the Puzzle Together
The science fits together like a puzzle with a series of interlinking components. At the heart of it
is our core innate immunity. In an effort to fight off foreign invaders, our immune system
14 | Page
At the heart of it is our core innate immunity. In an effort to fight off foreign invaders, our
immune system mounts a powerful defense consisting of free radicals and oxidative agents.
These biological weapons have evolved to disable what the immune system perceives as a
pathogen – a virus, bacteria, mold or parasite. Yet with wireless energy there is no pathogen
present. The ensuing events unfold, which appear as if the immune system attacks itself. But in
the case of wireless radiation, our immunity is reacting to invisible, unnatural, man-made energy.
Electromagnetic receptors send messages to the immune system signaling the battle is on.
U.S. Navy Study Predicted Today’s 23 Fast-Growing Chronic Diseases – in 1971 Heart Disease -- 125,100,000 Myocardial necrosis, Cholesterol and lipid changes; EKG changes; Vagomimetic action of the heart; Alteration of the heart rhythm Autoimmune Disease * 221% 24,114,643 Changes in Oxidative processes Celiac Disease 1,111% 60,000,000 Gastrointestinal disorders Total Incidence of 23 chronic diseases (2015). Each was predicted by the U.S. Navy study in 1971 549,314,860 The 549 million figure above is the total number of reported incidences of 23 of the 36-fast growing diseases and chronic conditions reported in 2015. These 23 were linked to biological effects from wireless radiation documented in the U.S. Navy study in 1971. By ignoring the earlier science, U.S. regulators failed to protect the American people from the dangers of wireless technologies. In doing so, they imposed millions of unnecessary chronic
exposure conditions on the American public. By 2015, these 23 diseases the U.S. Navy
predicted may have added more than $2 trillion in annual health care costs to the U.S.
economy due to their negligence.
Putting the Puzzle Together
The science fits together like a puzzle with a series of interlinking components. At the heart of it
is our core innate immunity. In an effort to fight off foreign invaders, our immune system
14 | Page
mounts a powerful defense consisting of free radicals and oxidative agents. These biological
weapons have evolved to disable what the immune system perceives as a pathogen – a virus,
bacteria, mold or parasite. Yet with wireless energy there is no pathogen present. The ensuing
events unfold, which appear as if the immune system attacks itself. But in the case of wireless
radiation, our immunity is reacting to invisible, unnatural, man-made energy. Electromagnetic
receptors send messages to the immune system signaling the battle is on.
The mechanism and path of causation for wireless health impacts has been laid out in the
science. Peer-reviewed science asserts the connection between wireless and more than 140
biological effects and diseases. This association has been extensively reported and confirmed
in more than 4,500 studies. While theories such as calcium ion channel disruption have not yet
been conclusively proven, the link between wireless signals and peroxynitrite production is
widely accepted. Henry Lai’s section in the BioInitiative Report documents 263 studies
connecting wireless signals with the production of peroxynitrite, super oxide and other free
radicals in the body. Meanwhile, Dr. Pal Pacher’s NIH paper links peroxynitrite with more than
97 biological disruptions and 50+ chronic diseases. Of the 704 million reported incidences of
the 36-fast growing disease in 2015, nearly 550 million were already associated with the
biological factors listed in the 1971 U.S. Navy study. We already knew the dangers of wireless
radiation.
Chain of Causation
Taken together, the research findings from NIH, the U.S. Navy, the BioInitiative Report, and
thousands of concerned scientists outline the following chain of causation:
Wireless signals trigger oxidative/nitrative stress in humans. In particular, calcium ion
messengers initiate the production of superoxide, peroxynitrite, and other free radicals. These
agents not only disrupt biological homeostasis, but evidence points to them creating a lethal
system of 7 synergistic biofactors that can both initiate and accelerate disease. This system of
dysfunction we’ll call “P-Factor.” Peroxynitrite sits at the epicenter. It includes systemic
inflammation, oxidative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial
dysfunction and nitrative stress. P-factor is shared by all 36 of the fastest-growing diseases in
the US.
Is P-factor the smoking gun for the current U.S. chronic disease health crisis?
15 | Page
Putting the Puzzle Together
mounts a powerful defense consisting of free radicals and oxidative agents. These biological
weapons have evolved to disable what the immune system perceives as a pathogen – a virus,
bacteria, mold or parasite. Yet with wireless energy there is no pathogen present. The ensuing
events unfold, which appear as if the immune system attacks itself. But in the case of wireless
radiation, our immunity is reacting to invisible, unnatural, man-made energy. Electromagnetic
receptors send messages to the immune system signaling the battle is on.
The mechanism and path of causation for wireless health impacts has been laid out in the
science. Peer-reviewed science asserts the connection between wireless and more than 140
biological effects and diseases. This association has been extensively reported and confirmed
in more than 4,500 studies. While theories such as calcium ion channel disruption have not yet
been conclusively proven, the link between wireless signals and peroxynitrite production is
widely accepted. Henry Lai’s section in the BioInitiative Report documents 263 studies
connecting wireless signals with the production of peroxynitrite, super oxide and other free
radicals in the body. Meanwhile, Dr. Pal Pacher’s NIH paper links peroxynitrite with more than
97 biological disruptions and 50+ chronic diseases. Of the 704 million reported incidences of
the 36-fast growing disease in 2015, nearly 550 million were already associated with the
biological factors listed in the 1971 U.S. Navy study. We already knew the dangers of wireless
radiation.
Chain of Causation
Taken together, the research findings from NIH, the U.S. Navy, the BioInitiative Report, and
thousands of concerned scientists outline the following chain of causation:
Wireless signals trigger oxidative/nitrative stress in humans. In particular, calcium ion
messengers initiate the production of superoxide, peroxynitrite, and other free radicals. These
agents not only disrupt biological homeostasis, but evidence points to them creating a lethal
system of 7 synergistic biofactors that can both initiate and accelerate disease. This system of
dysfunction we’ll call “P-Factor.” Peroxynitrite sits at the epicenter. It includes systemic
inflammation, oxidative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial
dysfunction and nitrative stress. P-factor is shared by all 36 of the fastest-growing diseases in
the US.
Is P-factor the smoking gun for the current U.S. chronic disease health crisis?
15 | Page
mounts a powerful defense consisting of free radicals and oxidative agents. These biological
weapons have evolved to disable what the immune system perceives as a pathogen – a virus,
bacteria, mold or parasite. Yet with wireless energy there is no pathogen present. The ensuing
events unfold, which appear as if the immune system attacks itself. But in the case of wireless
radiation, our immunity is reacting to invisible, unnatural, man-made energy. Electromagnetic
receptors send messages to the immune system signaling the battle is on.
The mechanism and path of causation for wireless health impacts has been laid out in the
science. Peer-reviewed science asserts the connection between wireless and more than 140
biological effects and diseases. This association has been extensively reported and confirmed
in more than 4,500 studies. While theories such as calcium ion channel disruption have not yet
been conclusively proven, the link between wireless signals and peroxynitrite production is
widely accepted. Henry Lai’s section in the BioInitiative Report documents 263 studies
connecting wireless signals with the production of peroxynitrite, super oxide and other free
radicals in the body. Meanwhile, Dr. Pal Pacher’s NIH paper links peroxynitrite with more than
97 biological disruptions and 50+ chronic diseases. Of the 704 million reported incidences of
the 36-fast growing disease in 2015, nearly 550 million were already associated with the
biological factors listed in the 1971 U.S. Navy study. We already knew the dangers of wireless
radiation.
Chain of Causation
Taken together, the research findings from NIH, the U.S. Navy, the BioInitiative Report, and
thousands of concerned scientists outline the following chain of causation:
Wireless signals trigger oxidative/nitrative stress in humans. In particular, calcium ion
messengers initiate the production of superoxide, peroxynitrite, and other free radicals. These
agents not only disrupt biological homeostasis, but evidence points to them creating a lethal
system of 7 synergistic biofactors that can both initiate and accelerate disease. This system of
dysfunction we’ll call “P-Factor.” Peroxynitrite sits at the epicenter. It includes systemic
inflammation, oxidative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial
dysfunction and nitrative stress. P-factor is shared by all 36 of the fastest-growing diseases in
the US.
Is P-factor the smoking gun for the current U.S. chronic disease health crisis?
15 | Page
mounts a powerful defense consisting of free radicals and oxidative agents. These biological
weapons have evolved to disable what the immune system perceives as a pathogen – a virus,
bacteria, mold or parasite. Yet with wireless energy there is no pathogen present. The ensuing
events unfold, which appear as if the immune system attacks itself. But in the case of wireless
radiation, our immunity is reacting to invisible, unnatural, man-made energy. Electromagnetic
receptors send messages to the immune system signaling the battle is on.
The mechanism and path of causation for wireless health impacts has been laid out in the
science. Peer-reviewed science asserts the connection between wireless and more than 140
biological effects and diseases. This association has been extensively reported and confirmed
in more than 4,500 studies. While theories such as calcium ion channel disruption have not yet
been conclusively proven, the link between wireless signals and peroxynitrite production is
widely accepted. Henry Lai’s section in the BioInitiative Report documents 263 studies
connecting wireless signals with the production of peroxynitrite, super oxide and other free
radicals in the body. Meanwhile, Dr. Pal Pacher’s NIH paper links peroxynitrite with more than
97 biological disruptions and 50+ chronic diseases. Of the 704 million reported incidences of
the 36-fast growing disease in 2015, nearly 550 million were already associated with the
biological factors listed in the 1971 U.S. Navy study. We already knew the dangers of wireless
radiation.
Chain of Causation
Taken together, the research findings from NIH, the U.S. Navy, the BioInitiative Report, and
thousands of concerned scientists outline the following chain of causation:
Wireless signals trigger oxidative/nitrative stress in humans. In particular, calcium ion
messengers initiate the production of superoxide, peroxynitrite, and other free radicals. These
agents not only disrupt biological homeostasis, but evidence points to them creating a lethal
system of 7 synergistic biofactors that can both initiate and accelerate disease. This system of
dysfunction we’ll call “P-Factor.” Peroxynitrite sits at the epicenter. It includes systemic
inflammation, oxidative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial
dysfunction and nitrative stress. P-factor is shared by all 36 of the fastest-growing diseases in
the US.
Is P-factor the smoking gun for the current U.S. chronic disease health crisis?
15 | Page
mounts a powerful defense consisting of free radicals and oxidative agents. These biological
weapons have evolved to disable what the immune system perceives as a pathogen – a virus,
bacteria, mold or parasite. Yet with wireless energy there is no pathogen present. The ensuing
events unfold, which appear as if the immune system attacks itself. But in the case of wireless
radiation, our immunity is reacting to invisible, unnatural, man-made energy. Electromagnetic
receptors send messages to the immune system signaling the battle is on.
The mechanism and path of causation for wireless health impacts has been laid out in the
science. Peer-reviewed science asserts the connection between wireless and more than 140
biological effects and diseases. This association has been extensively reported and confirmed
in more than 4,500 studies. While theories such as calcium ion channel disruption have not yet
been conclusively proven, the link between wireless signals and peroxynitrite production is
widely accepted. Henry Lai’s section in the BioInitiative Report documents 263 studies
connecting wireless signals with the production of peroxynitrite, super oxide and other free
radicals in the body. Meanwhile, Dr. Pal Pacher’s NIH paper links peroxynitrite with more than
97 biological disruptions and 50+ chronic diseases. Of the 704 million reported incidences of
the 36-fast growing disease in 2015, nearly 550 million were already associated with the
biological factors listed in the 1971 U.S. Navy study. We already knew the dangers of wireless
radiation.
Chain of Causation
Taken together, the research findings from NIH, the U.S. Navy, the BioInitiative Report, and
thousands of concerned scientists outline the following chain of causation:
Wireless signals trigger oxidative/nitrative stress in humans. In particular, calcium ion
messengers initiate the production of superoxide, peroxynitrite, and other free radicals. These
agents not only disrupt biological homeostasis, but evidence points to them creating a lethal
system of 7 synergistic biofactors that can both initiate and accelerate disease. This system of
dysfunction we’ll call “P-Factor.” Peroxynitrite sits at the epicenter. It includes systemic
inflammation, oxidative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial
dysfunction and nitrative stress. P-factor is shared by all 36 of the fastest-growing diseases in
the US.
Is P-factor the smoking gun for the current U.S. chronic disease health crisis?
15 | Page
mounts a powerful defense consisting of free radicals and oxidative agents. These biological weapons have evolved to disable what the immune system perceives as a pathogen – a virus, bacteria, mold or parasite. Yet with wireless energy there is no pathogen present. The ensuing events unfold, which appear as if the immune system attacks itself. But in the case of wireless radiation, our immunity is reacting to invisible, unnatural, man-made energy. Electromagnetic receptors send messages to the immune system signaling the battle is on. The mechanism and path of causation for wireless health impacts has been laid out in the science. Peer-reviewed science asserts the connection between wireless and more than 140 biological effects and diseases. This association has been extensively reported and confirmed in more than 4,500 studies. While theories such as calcium ion channel disruption have not yet been conclusively proven, the link between wireless signals and peroxynitrite production is widely accepted. Henry Lai’s section in the BioInitiative Report documents 263 studies connecting wireless signals with the production of peroxynitrite, super oxide and other free radicals in the body. Meanwhile, Dr. Pal Pacher’s NIH paper links peroxynitrite with more than 97 biological disruptions and 50+ chronic diseases. Of the 704 million reported incidences of
the 36-fast growing disease in 2015, nearly 550 million were already associated with the
biological factors listed in the 1971 U.S. Navy study. We already knew the dangers of wireless
radiation.
Chain of Causation
Taken together, the research findings from NIH, the U.S. Navy, the BioInitiative Report, and
thousands of concerned scientists outline the following chain of causation:
Wireless signals trigger oxidative/nitrative stress in humans. In particular, calcium ion
messengers initiate the production of superoxide, peroxynitrite, and other free radicals. These
agents not only disrupt biological homeostasis, but evidence points to them creating a lethal
system of 7 synergistic biofactors that can both initiate and accelerate disease. This system of
dysfunction we’ll call “P-Factor.” Peroxynitrite sits at the epicenter. It includes systemic
inflammation, oxidative stress, mitochondrial dysfunction, autonomic dysfunction, epithelial
dysfunction and nitrative stress. P-factor is shared by all 36 of the fastest-growing diseases in
the US.
Is P-factor the smoking gun for the current U.S. chronic disease health crisis?
15 | Page
Is P-factor the smoking gun for the current U.S. chronic disease health crisis?
The image below depicts the chain of causation:
Electrical energy from wireless technologies is conveyed in the form of microwave radiation.
The electromagnetic frequencies activate calcium ion messengers, which in turn signal the
human innate immune system. The perceived threat triggers free radical production like
superoxide (O2--), hydroxy free radical (OH) and peroxynitrite (ONOO--).16 These molecules
then set in motion as many as 97 biological disruptions, which are associated with, and appear
to be critical factors in, the etiology and persistence of all 36 fast-growing chronic diseases
listed above.
Elephant in the Room
16 Calcium and ROS: A mutual interplay, Agnes Görlach, Katharina Bertram, Sona Hudecova, Olga
Krizanova. Calcium communicates with a number of other systems and pathways; among them also with
reactive oxygen species (ROS), such as superoxide anion (O2•−), hydrogen peroxide (H2O2) and
hydroxyl radicals (HO•). https://www.sciencedirect.com/science/article/pii/S2213231715001007
16 | Page
The image below depicts the chain of causation:
Electrical energy from wireless technologies is conveyed in the form of microwave radiation.
The electromagnetic frequencies activate calcium ion messengers, which in turn signal the
human innate immune system. The perceived threat triggers free radical production like
superoxide (O2--), hydroxy free radical (OH) and peroxynitrite (ONOO--).16 These molecules
then set in motion as many as 97 biological disruptions, which are associated with, and appear
to be critical factors in, the etiology and persistence of all 36 fast-growing chronic diseases
listed above.
Elephant in the Room
16 Calcium and ROS: A mutual interplay, Agnes Görlach, Katharina Bertram, Sona Hudecova, Olga
Krizanova. Calcium communicates with a number of other systems and pathways; among them also with
reactive oxygen species (ROS), such as superoxide anion (O2•−), hydrogen peroxide (H2O2) and
hydroxyl radicals (HO•). https://www.sciencedirect.com/science/article/pii/S2213231715001007
16 | Page
The image below depicts the chain of causation:
Electrical energy from wireless technologies is conveyed in the form of microwave radiation.
The electromagnetic frequencies activate calcium ion messengers, which in turn signal the
human innate immune system. The perceived threat triggers free radical production like
superoxide (O2--), hydroxy free radical (OH) and peroxynitrite (ONOO--).16 These molecules
then set in motion as many as 97 biological disruptions, which are associated with, and appear
to be critical factors in, the etiology and persistence of all 36 fast-growing chronic diseases
listed above.
Elephant in the Room
16 Calcium and ROS: A mutual interplay, Agnes Görlach, Katharina Bertram, Sona Hudecova, Olga
Krizanova. Calcium communicates with a number of other systems and pathways; among them also with
reactive oxygen species (ROS), such as superoxide anion (O2•−), hydrogen peroxide (H2O2) and
hydroxyl radicals (HO•). https://www.sciencedirect.com/science/article/pii/S2213231715001007
16 | Page
The image below depicts the chain of causation:
Electrical energy from wireless technologies is conveyed in the form of microwave radiation.
The electromagnetic frequencies activate calcium ion messengers, which in turn signal the
human innate immune system. The perceived threat triggers free radical production like
superoxide (O2--), hydroxy free radical (OH) and peroxynitrite (ONOO--).16 These molecules
then set in motion as many as 97 biological disruptions, which are associated with, and appear
to be critical factors in, the etiology and persistence of all 36 fast-growing chronic diseases
listed above.
Elephant in the Room
16 Calcium and ROS: A mutual interplay, Agnes Görlach, Katharina Bertram, Sona Hudecova, Olga
Krizanova. Calcium communicates with a number of other systems and pathways; among them also with
reactive oxygen species (ROS), such as superoxide anion (O2•−), hydrogen peroxide (H2O2) and
hydroxyl radicals (HO•). https://www.sciencedirect.com/science/article/pii/S2213231715001007
16 | Page
Chain of Causation
16 Calcium and ROS: A mutual interplay. Agnes Görlach, Katharina Bertram, Sona Hudecova, Olga
Krizanova. Calcium communicates with a number of other systems and pathways; among them also
with reactive oxygen species (ROS), such as superoxide anion (O2•−), hydrogen peroxide (H2O2) and
hydroxyl radicals (HO•). https://www.sciencedirect.com/science/article/pii/S2213231715001007
The image below depicts the chain of causation:
Electrical energy from wireless technologies is conveyed in the form of microwave radiation.
The electromagnetic frequencies activate calcium ion messengers, which in turn signal the
human innate immune system. The perceived threat triggers free radical production like
superoxide (O2--), hydroxy free radical (OH) and peroxynitrite (ONOO--).16 These molecules
then set in motion as many as 97 biological disruptions, which are associated with, and appear
to be critical factors in, the etiology and persistence of all 36 fast-growing chronic diseases
listed above.
Elephant in the Room
16 Calcium and ROS: A mutual interplay, Agnes Görlach, Katharina Bertram, Sona Hudecova, Olga
Krizanova. Calcium communicates with a number of other systems and pathways; among them also with
reactive oxygen species (ROS), such as superoxide anion (O2•−), hydrogen peroxide (H2O2) and
hydroxyl radicals (HO•). https://www.sciencedirect.com/science/article/pii/S2213231715001007
16 | Page
The image below depicts the chain of causation: Electrical energy from wireless technologies is conveyed in the form of microwave radiation. The electromagnetic frequencies activate calcium ion messengers, which in turn signal the human innate immune system. The perceived threat triggers free radical production like superoxide (O2--), hydroxy free radical (OH) and peroxynitrite (ONOO--).16 These molecules then set in motion as many as 97 biological disruptions, which are associated with, and appear to be critical factors in, the etiology and persistence of all 36 fast-growing chronic diseases listed above.
Elephant in the Room
16 Calcium and ROS: A mutual interplay, Agnes Görlach, Katharina Bertram, Sona Hudecova, Olga
Krizanova. Calcium communicates with a number of other systems and pathways; among them also with
reactive oxygen species (ROS), such as superoxide anion (O2•−), hydrogen peroxide (H2O2) and
hydroxyl radicals (HO•). https://www.sciencedirect.com/science/article/pii/S2213231715001007
16 | Page
The image below depicts the chain of causation:
Electrical energy from wireless technologies is conveyed in the form of microwave radiation.
The electromagnetic frequencies activate calcium ion messengers, which in turn signal the
human innate immune system. The perceived threat triggers free radical production like
superoxide (O2--), hydroxy free radical (OH) and peroxynitrite (ONOO--).16 These molecules
then set in motion as many as 97 biological disruptions, which are associated with, and appear
to be critical factors in, the etiology and persistence of all 36 fast-growing chronic diseases
listed above.
Elephant in the Room
16 Calcium and ROS: A mutual interplay, Agnes Görlach, Katharina Bertram, Sona Hudecova, Olga
Krizanova. Calcium communicates with a number of other systems and pathways; among them also with
reactive oxygen species (ROS), such as superoxide anion (O2•−), hydrogen peroxide (H2O2) and
hydroxyl radicals (HO•). https://www.sciencedirect.com/science/article/pii/S2213231715001007
16 | Page
There is a huge elephant in the room. It is time to begin the honest dialogue on the potential
hazards of wireless. We can continue to deny the science but we cannot avoid the tragic
consequences of such denial. By denying non-thermal biological effects from microwave
radiation, those who are chartered to protect us – our government, our regulatory agencies and
our media – have shielded us from the crucial conversation about wireless technologies and our
health.
In the U.S., we’re facing a tipping point. Chronic disease is dramatically on the rise. Modern
stress symptoms from wireless technologies, like fatigue, depression, sleep issues, irritability,
mood swings, anxiety, joint pain, brain fog, memory issues, and poor learning, all of which are
associated with wireless signals, are plaguing our lives and that of our children. More than 54%
of children are suffering from a chronic condition17. Four new categories of disease have
suddenly exploded since the onset of the wireless revolution around 1990: autoimmune,
inflammatory, metabolic, and neurological diseases have become endemic. Millions of people
are suffering and not living up to their potential, while bearing the costs of underemployment,
financial hardships and health-related bankruptcies. Our nation has been slow to make the
connection between our decline in health and our rapidly intensifying electromagnetic
environment. As described above, the science is compelling, comprehensively warning us of
wireless risks. Meanwhile, the absence of evidence for safety from wireless technologies is
chilling.
17 “A National and State Profile of Leading Health Problems and Health Care Quality for US Children: Key
Insurance Disparities and Across-State Variations”, Christina D. Bethell PhD, MBA, MPH, Michael D.
Kogan PhD, Bonnie B. Strickland PhD, Edward L. Schor MD, Julie Robertson, Paul W. Newacheck DrPH
17 | Page
Elephant in the Room
There is a huge elephant in the room. It is time to begin the honest dialogue on the potential
hazards of wireless. We can continue to deny the science but we cannot avoid the tragic
consequences of such denial. By denying non-thermal biological effects from microwave
radiation, those who are chartered to protect us – our government, our regulatory agencies and
our media – have shielded us from the crucial conversation about wireless technologies and our
health.
In the U.S., we’re facing a tipping point. Chronic disease is dramatically on the rise. Modern
stress symptoms from wireless technologies, like fatigue, depression, sleep issues, irritability,
mood swings, anxiety, joint pain, brain fog, memory issues, and poor learning, all of which are
associated with wireless signals, are plaguing our lives and that of our children. More than 54%
of children are suffering from a chronic condition17. Four new categories of disease have
suddenly exploded since the onset of the wireless revolution around 1990: autoimmune,
inflammatory, metabolic, and neurological diseases have become endemic. Millions of people
are suffering and not living up to their potential, while bearing the costs of underemployment,
financial hardships and health-related bankruptcies. Our nation has been slow to make the
connection between our decline in health and our rapidly intensifying electromagnetic
environment. As described above, the science is compelling, comprehensively warning us of
wireless risks. Meanwhile, the absence of evidence for safety from wireless technologies is
chilling.
17 “A National and State Profile of Leading Health Problems and Health Care Quality for US Children: Key
Insurance Disparities and Across-State Variations”, Christina D. Bethell PhD, MBA, MPH, Michael D.
Kogan PhD, Bonnie B. Strickland PhD, Edward L. Schor MD, Julie Robertson, Paul W. Newacheck DrPH
17 | Page
There is a huge elephant in the room. It is time to begin the honest dialogue on the potential
hazards of wireless. We can continue to deny the science but we cannot avoid the tragic
consequences of such denial. By denying non-thermal biological effects from microwave
radiation, those who are chartered to protect us – our government, our regulatory agencies and
our media – have shielded us from the crucial conversation about wireless technologies and our
health.
In the U.S., we’re facing a tipping point. Chronic disease is dramatically on the rise. Modern
stress symptoms from wireless technologies, like fatigue, depression, sleep issues, irritability,
mood swings, anxiety, joint pain, brain fog, memory issues, and poor learning, all of which are
associated with wireless signals, are plaguing our lives and that of our children. More than 54%
of children are suffering from a chronic condition17. Four new categories of disease have
suddenly exploded since the onset of the wireless revolution around 1990: autoimmune,
inflammatory, metabolic, and neurological diseases have become endemic. Millions of people
are suffering and not living up to their potential, while bearing the costs of underemployment,
financial hardships and health-related bankruptcies. Our nation has been slow to make the
connection between our decline in health and our rapidly intensifying electromagnetic
environment. As described above, the science is compelling, comprehensively warning us of
wireless risks. Meanwhile, the absence of evidence for safety from wireless technologies is
chilling.
17 “A National and State Profile of Leading Health Problems and Health Care Quality for US Children: Key
Insurance Disparities and Across-State Variations”, Christina D. Bethell PhD, MBA, MPH, Michael D.
Kogan PhD, Bonnie B. Strickland PhD, Edward L. Schor MD, Julie Robertson, Paul W. Newacheck DrPH
17 | Page
The scientific view is clear:
Wireless technologies are not safe.
And we’ve known this for more than five decades. Now, one crucial question remains:
“When will we have the courage to listen to the science and finally act?”
18 | Page
“When will we have the courage to listen to the science and finally act?”
Wireless technologies are not safe.
The scientific view is clear:
Wireless technologies are not safe.
And we’ve known this for more than five decades. Now, one crucial question remains:
“When will we have the courage to listen to the science and finally act?”
18 | Page
APPENDIX A:
Following is a sampling of biological impacts from low-level wireless signals, which are
identified across 2,311 studies, compiled by the U.S. Navy in a survey of the global science in
1971: “Reported Biological Phenomena (Effects) and Clinical Manifestations attributed to
Microwave and Radio-Frequency Radiation":
Central Nervous System Effects
● Headaches
● Insomnia
● Restlessness
● EEG changes
● Cranial Nerve disorder
● Pyramid Track lesions
● Reflex disorders
● Vagomimetic Action of the
heart
● Seizures, convulsions
Autonomic Nervous System Effects
● Alteration of heart
rhythm
● Fatigue
● Structural alteration of
synapses (vagus nerve)
Genetic and Chromosomal Changes
● Chromosome
aberrations
● Mutations
● Mongolism
● Neoplastic Diseases
(tumors, cancer)
● Cellular changes
(somatic alterations)
Psychological Disorders
● Depression
● Impotence
● Anxiety
● Lack of concentration
● Dizziness
● Insomnia
● Increased irritability
● Memory loss
● Sleepiness
● Neurasthenia
● Hallucinations
● Increased fatigability
● Chest Pain
● Tremor of Hands
● Scalp sensations
Note, the first 10 disorders, above, are key symptoms of Chronic Fatigue, Fibromyalgia, Lupus and
psychological stress. Are these psychological or biologically-triggered symptoms, or both?
Blood Disorders
● Blood glucose increase
● Histamine content
(inflammatory marker)
● Decreased erythrocytes
● Sedimentation rate
● Cholesterol & Lipids
● Gamma globulin
● Alpha/beta globulin
● Total protein
concentrations
● Phagocytes
● Shortened lifespan of cells
● Blood and bone marrow
● Albumin/globulin ratio
● Hemolysis rate changes
19 | Page
The scientific view is clear:
Wireless technologies are not safe.
And we’ve known this for more than five decades. Now, one crucial question remains:
“When will we have the courage to listen to the science and finally act?”
18 | Page
The scientific view is clear:
Wireless technologies are not safe.
And we’ve known this for more than five decades. Now, one crucial question remains:
“When will we have the courage to listen to the science and finally act?”
18 | Page
APPENDIX A:
Following is a sampling of biological impacts from low-level wireless signals, which are
identified across 2,311 studies, compiled by the U.S. Navy in a survey of the global science in
1971: “Reported Biological Phenomena (Effects) and Clinical Manifestations attributed to
Microwave and Radio-Frequency Radiation":
Central Nervous System Effects
● Headaches
● Insomnia
● Restlessness
● EEG changes
● Cranial Nerve disorder
● Pyramid Track lesions
● Reflex disorders
● Vagomimetic Action of the
heart
● Seizures, convulsions
Autonomic Nervous System Effects
● Alteration of heart
rhythm
● Fatigue
● Structural alteration of
synapses (vagus nerve)
Genetic and Chromosomal Changes
● Chromosome
aberrations
● Mutations
● Mongolism
● Neoplastic Diseases
(tumors, cancer)
● Cellular changes
(somatic alterations)
Psychological Disorders
● Depression
● Impotence
● Anxiety
● Lack of concentration
● Dizziness
● Insomnia
● Increased irritability
● Memory loss
● Sleepiness
● Neurasthenia
● Hallucinations
● Increased fatigability
● Chest Pain
● Tremor of Hands
● Scalp sensations
Note, the first 10 disorders, above, are key symptoms of Chronic Fatigue, Fibromyalgia, Lupus and
psychological stress. Are these psychological or biologically-triggered symptoms, or both?
Blood Disorders
● Blood glucose increase
● Histamine content
(inflammatory marker)
● Decreased erythrocytes
● Sedimentation rate
● Cholesterol & Lipids
● Gamma globulin
● Alpha/beta globulin
● Total protein
concentrations
● Phagocytes
● Shortened lifespan of cells
● Blood and bone marrow
● Albumin/globulin ratio
● Hemolysis rate changes
19 | Page
APPENDIX A:
Following is a sampling of biological impacts from low-level wireless signals, which are
identified across 2,311 studies, compiled by the U.S. Navy in a survey of the global science in
1971: “Reported Biological Phenomena (Effects) and Clinical Manifestations attributed to
Microwave and Radio-Frequency Radiation":
Central Nervous System Effects
● Headaches
● Insomnia
● Restlessness
● EEG changes
● Cranial Nerve disorder
● Pyramid Track lesions
● Reflex disorders
● Vagomimetic Action of the
heart
● Seizures, convulsions
Autonomic Nervous System Effects
● Alteration of heart
rhythm
● Fatigue
● Structural alteration of
synapses (vagus nerve)
Genetic and Chromosomal Changes
● Chromosome
aberrations
● Mutations
● Mongolism
● Neoplastic Diseases
(tumors, cancer)
● Cellular changes
(somatic alterations)
Psychological Disorders
● Depression
● Impotence
● Anxiety
● Lack of concentration
● Dizziness
● Insomnia
● Increased irritability
● Memory loss
● Sleepiness
● Neurasthenia
● Hallucinations
● Increased fatigability
● Chest Pain
● Tremor of Hands
● Scalp sensations
Note, the first 10 disorders, above, are key symptoms of Chronic Fatigue, Fibromyalgia, Lupus and
psychological stress. Are these psychological or biologically-triggered symptoms, or both?
Blood Disorders
● Blood glucose increase
● Histamine content
(inflammatory marker)
● Decreased erythrocytes
● Sedimentation rate
● Cholesterol & Lipids
● Gamma globulin
● Alpha/beta globulin
● Total protein
concentrations
● Phagocytes
● Shortened lifespan of cells
● Blood and bone marrow
● Albumin/globulin ratio
● Hemolysis rate changes
19 | Page
APPENDIX A:
Following is a sampling of biological impacts from low-level wireless signals, which are
identified across 2,311 studies, compiled by the U.S. Navy in a survey of the global science in
1971: “Reported Biological Phenomena (Effects) and Clinical Manifestations attributed to
Microwave and Radio-Frequency Radiation":
Central Nervous System Effects
● Headaches
● Insomnia
● Restlessness
● EEG changes
● Cranial Nerve disorder
● Pyramid Track lesions
● Reflex disorders
● Vagomimetic Action of the
heart
● Seizures, convulsions
Autonomic Nervous System Effects
● Alteration of heart
rhythm
● Fatigue
● Structural alteration of
synapses (vagus nerve)
Genetic and Chromosomal Changes
● Chromosome
aberrations
● Mutations
● Mongolism
● Neoplastic Diseases
(tumors, cancer)
● Cellular changes
(somatic alterations)
Psychological Disorders
● Depression
● Impotence
● Anxiety
● Lack of concentration
● Dizziness
● Insomnia
● Increased irritability
● Memory loss
● Sleepiness
● Neurasthenia
● Hallucinations
● Increased fatigability
● Chest Pain
● Tremor of Hands
● Scalp sensations
Note, the first 10 disorders, above, are key symptoms of Chronic Fatigue, Fibromyalgia, Lupus and
psychological stress. Are these psychological or biologically-triggered symptoms, or both?
Blood Disorders
● Blood glucose increase
● Histamine content
(inflammatory marker)
● Decreased erythrocytes
● Sedimentation rate
● Cholesterol & Lipids
● Gamma globulin
● Alpha/beta globulin
● Total protein
concentrations
● Phagocytes
● Shortened lifespan of cells
● Blood and bone marrow
● Albumin/globulin ratio
● Hemolysis rate changes
19 | Page
APPENDIX A:
Following is a sampling of biological impacts from low-level wireless signals, which are
identified across 2,311 studies, compiled by the U.S. Navy in a survey of the global science in
1971: “Reported Biological Phenomena (Effects) and Clinical Manifestations attributed to
Microwave and Radio-Frequency Radiation":
Central Nervous System Effects
● Headaches
● Insomnia
● Restlessness
● EEG changes
● Cranial Nerve disorder
● Pyramid Track lesions
● Reflex disorders
● Vagomimetic Action of the
heart
● Seizures, convulsions
Autonomic Nervous System Effects
● Alteration of heart
rhythm
● Fatigue
● Structural alteration of
synapses (vagus nerve)
Genetic and Chromosomal Changes
● Chromosome
aberrations
● Mutations
● Mongolism
● Neoplastic Diseases
(tumors, cancer)
● Cellular changes
(somatic alterations)
Psychological Disorders
● Depression
● Impotence
● Anxiety
● Lack of concentration
● Dizziness
● Insomnia
● Increased irritability
● Memory loss
● Sleepiness
● Neurasthenia
● Hallucinations
● Increased fatigability
● Chest Pain
● Tremor of Hands
● Scalp sensations
Note, the first 10 disorders, above, are key symptoms of Chronic Fatigue, Fibromyalgia, Lupus and
psychological stress. Are these psychological or biologically-triggered symptoms, or both?
Blood Disorders
● Blood glucose increase
● Histamine content
(inflammatory marker)
● Decreased erythrocytes
● Sedimentation rate
● Cholesterol & Lipids
● Gamma globulin
● Alpha/beta globulin
● Total protein
concentrations
● Phagocytes
● Shortened lifespan of cells
● Blood and bone marrow
● Albumin/globulin ratio
● Hemolysis rate changes
19 | Page
Changes in Physiological Function
● Decreased fertility
● Altered rate of
calcification
(osteoporosis)
● Alteration: menstrual
activity
● Loss of anatomical
parts
● Structural changes in
cerebral cortex
● Alteration: blood flow
● Dehydration
● Alteration: diameter of
blood vessels
● EKG changes
● Myocardial necrosis
● Liver enlargement
● Sensitivity to light,
sound/ olfactory stimuli
● Altered color
recognition
● Altered sex ratio of
births (more females)
Gastrointestinal Disorders
● Anorexia
● Gastrointestinal
disorders
● Epigastric pain
● Constipation
● Altered secretion of
stomach (digestive
juices
Endocrine Gland Changes
● Hyperthyroidism
● Thyroid enlargement
● Altered adrenal cortex
activity
● Increased uptake of
radioactive iodine
● Altered pituitary
function
● Low T: Hypogonadism
(lower testosterone
production)
● Lower glucotcorticoidal
activity
● Decreased corticosteroids
in blood
● Change in glycogen
concentration in liver
● Alteration of ketosteroids in
urine
Enzyme and other biochemical changes
● Alteration: cell division
● Increased RNA in
lymphocytes
● Decreased RNA in
brain, liver, spleen
● Tissue cultures killed
● Pyruvic acid, lactic acid,
and creatinine excretion
● Protein denaturation
● Altered 17 - Ketosteroids
● Hyperglycemia
● Changes in:
○ Cholinesterase
○ Phosphatase
○ Transaminase
○ Amylase
20 | Page
Changes in Physiological Function
● Decreased fertility
● Altered rate of
calcification
(osteoporosis)
● Alteration: menstrual
activity
● Loss of anatomical
parts
● Structural changes in
cerebral cortex
● Alteration: blood flow
● Dehydration
● Alteration: diameter of
blood vessels
● EKG changes
● Myocardial necrosis
● Liver enlargement
● Sensitivity to light,
sound/ olfactory stimuli
● Altered color
recognition
● Altered sex ratio of
births (more females)
Gastrointestinal Disorders
● Anorexia
● Gastrointestinal
disorders
● Epigastric pain
● Constipation
● Altered secretion of
stomach (digestive
juices
Endocrine Gland Changes
● Hyperthyroidism
● Thyroid enlargement
● Altered adrenal cortex
activity
● Increased uptake of
radioactive iodine
● Altered pituitary
function
● Low T: Hypogonadism
(lower testosterone
production)
● Lower glucotcorticoidal
activity
● Decreased corticosteroids
in blood
● Change in glycogen
concentration in liver
● Alteration of ketosteroids in
urine
Enzyme and other biochemical changes
● Alteration: cell division
● Increased RNA in
lymphocytes
● Decreased RNA in
brain, liver, spleen
● Tissue cultures killed
● Pyruvic acid, lactic acid,
and creatinine excretion
● Protein denaturation
● Altered 17 - Ketosteroids
● Hyperglycemia
● Changes in:
○ Cholinesterase
○ Phosphatase
○ Transaminase
○ Amylase
20 | Page
Metabolic Disorders
● Glycosuria (sugar in urine)
● Altered: rate of Metabolic
process
● Increase in
Urinary Phenol
● Altered carbohydrate
metabolism
Vascular disorders
● Thrombosis (blood clot)
● Hypertension
Miscellaneous Effects
● Changes in circadian
rhythms
● Hair loss
● Brittleness of hair
● Metallic taste in mouth
● Sensations of buzzing,
vibrations, pulsations,
tickling about head and
ears
● Changes in optical
activity
● Sparking between
dental fillings
● Copious perspiration,
salivation diseases
Pearl Chain Effect
● Changes in intracellular orientation of subcellular particles
APPENDIX B:
A comparison of Radiofrequency Radiation Exposure Standards from around the world:
21 | Page
Microwatts/ square meter
US 5,800,000
Russia 100,000
China 60,000
Italy 50,000
Switzerland 42,000
Salzburg, Austria 1,000
Metabolic Disorders
● Glycosuria (sugar in urine)
● Altered: rate of Metabolic
process
● Increase in
Urinary Phenol
● Altered carbohydrate
metabolism
Vascular disorders
● Thrombosis (blood clot)
● Hypertension
Miscellaneous Effects
● Changes in circadian
rhythms
● Hair loss
● Brittleness of hair
● Metallic taste in mouth
● Sensations of buzzing,
vibrations, pulsations,
tickling about head and
ears
● Changes in optical
activity
● Sparking between
dental fillings
● Copious perspiration,
salivation diseases
Pearl Chain Effect
● Changes in intracellular orientation of subcellular particles
APPENDIX B:
A comparison of Radiofrequency Radiation Exposure Standards from around the world:
21 | Page
Microwatts/ square meter
US 5,800,000
Russia 100,000
China 60,000
Italy 50,000
Switzerland 42,000
Salzburg, Austria 1,000
Changes in Physiological Function
● Decreased fertility
● Altered rate of
calcification
(osteoporosis)
● Alteration: menstrual
activity
● Loss of anatomical
parts
● Structural changes in
cerebral cortex
● Alteration: blood flow
● Dehydration
● Alteration: diameter of
blood vessels
● EKG changes
● Myocardial necrosis
● Liver enlargement
● Sensitivity to light,
sound/ olfactory stimuli
● Altered color
recognition
● Altered sex ratio of
births (more females)
Gastrointestinal Disorders
● Anorexia
● Gastrointestinal
disorders
● Epigastric pain
● Constipation
● Altered secretion of
stomach (digestive
juices
Endocrine Gland Changes
● Hyperthyroidism
● Thyroid enlargement
● Altered adrenal cortex
activity
● Increased uptake of
radioactive iodine
● Altered pituitary
function
● Low T: Hypogonadism
(lower testosterone
production)
● Lower glucotcorticoidal
activity
● Decreased corticosteroids
in blood
● Change in glycogen
concentration in liver
● Alteration of ketosteroids in
urine
Enzyme and other biochemical changes
● Alteration: cell division
● Increased RNA in
lymphocytes
● Decreased RNA in
brain, liver, spleen
● Tissue cultures killed
● Pyruvic acid, lactic acid,
and creatinine excretion
● Protein denaturation
● Altered 17 - Ketosteroids
● Hyperglycemia
● Changes in:
○ Cholinesterase
○ Phosphatase
○ Transaminase
○ Amylase
20 | Page
Changes in Physiological Function
● Decreased fertility
● Altered rate of
calcification
(osteoporosis)
● Alteration: menstrual
activity
● Loss of anatomical
parts
● Structural changes in
cerebral cortex
● Alteration: blood flow
● Dehydration
● Alteration: diameter of
blood vessels
● EKG changes
● Myocardial necrosis
● Liver enlargement
● Sensitivity to light,
sound/ olfactory stimuli
● Altered color
recognition
● Altered sex ratio of
births (more females)
Gastrointestinal Disorders
● Anorexia
● Gastrointestinal
disorders
● Epigastric pain
● Constipation
● Altered secretion of
stomach (digestive
juices
Endocrine Gland Changes
● Hyperthyroidism
● Thyroid enlargement
● Altered adrenal cortex
activity
● Increased uptake of
radioactive iodine
● Altered pituitary
function
● Low T: Hypogonadism
(lower testosterone
production)
● Lower glucotcorticoidal
activity
● Decreased corticosteroids
in blood
● Change in glycogen
concentration in liver
● Alteration of ketosteroids in
urine
Enzyme and other biochemical changes
● Alteration: cell division
● Increased RNA in
lymphocytes
● Decreased RNA in
brain, liver, spleen
● Tissue cultures killed
● Pyruvic acid, lactic acid,
and creatinine excretion
● Protein denaturation
● Altered 17 - Ketosteroids
● Hyperglycemia
● Changes in:
○ Cholinesterase
○ Phosphatase
○ Transaminase
○ Amylase
20 | Page
Changes in Physiological Function
● Decreased fertility
● Altered rate of
calcification
(osteoporosis)
● Alteration: menstrual
activity
● Loss of anatomical
parts
● Structural changes in
cerebral cortex
● Alteration: blood flow
● Dehydration
● Alteration: diameter of
blood vessels
● EKG changes
● Myocardial necrosis
● Liver enlargement
● Sensitivity to light,
sound/ olfactory stimuli
● Altered color
recognition
● Altered sex ratio of
births (more females)
Gastrointestinal Disorders
● Anorexia
● Gastrointestinal
disorders
● Epigastric pain
● Constipation
● Altered secretion of
stomach (digestive
juices
Endocrine Gland Changes
● Hyperthyroidism
● Thyroid enlargement
● Altered adrenal cortex
activity
● Increased uptake of
radioactive iodine
● Altered pituitary
function
● Low T: Hypogonadism
(lower testosterone
production)
● Lower glucotcorticoidal
activity
● Decreased corticosteroids
in blood
● Change in glycogen
concentration in liver
● Alteration of ketosteroids in
urine
Enzyme and other biochemical changes
● Alteration: cell division
● Increased RNA in
lymphocytes
● Decreased RNA in
brain, liver, spleen
● Tissue cultures killed
● Pyruvic acid, lactic acid,
and creatinine excretion
● Protein denaturation
● Altered 17 - Ketosteroids
● Hyperglycemia
● Changes in:
○ Cholinesterase
○ Phosphatase
○ Transaminase
○ Amylase
20 | Page
Changes in Physiological Function
● Decreased fertility
● Altered rate of
calcification
(osteoporosis)
● Alteration: menstrual
activity
● Loss of anatomical
parts
● Structural changes in
cerebral cortex
● Alteration: blood flow
● Dehydration
● Alteration: diameter of
blood vessels
● EKG changes
● Myocardial necrosis
● Liver enlargement
● Sensitivity to light,
sound/ olfactory stimuli
● Altered color
recognition
● Altered sex ratio of
births (more females)
Gastrointestinal Disorders
● Anorexia
● Gastrointestinal
disorders
● Epigastric pain
● Constipation
● Altered secretion of
stomach (digestive
juices
Endocrine Gland Changes
● Hyperthyroidism
● Thyroid enlargement
● Altered adrenal cortex
activity
● Increased uptake of
radioactive iodine
● Altered pituitary
function
● Low T: Hypogonadism
(lower testosterone
production)
● Lower glucotcorticoidal
activity
● Decreased corticosteroids
in blood
● Change in glycogen
concentration in liver
● Alteration of ketosteroids in
urine
Enzyme and other biochemical changes
● Alteration: cell division
● Increased RNA in
lymphocytes
● Decreased RNA in
brain, liver, spleen
● Tissue cultures killed
● Pyruvic acid, lactic acid,
and creatinine excretion
● Protein denaturation
● Altered 17 - Ketosteroids
● Hyperglycemia
● Changes in:
○ Cholinesterase
○ Phosphatase
○ Transaminase
○ Amylase
20 | Page
Changes in Physiological Function
● Decreased fertility
● Altered rate of
calcification
(osteoporosis)
● Alteration: menstrual
activity
● Loss of anatomical
parts
● Structural changes in
cerebral cortex
● Alteration: blood flow
● Dehydration
● Alteration: diameter of
blood vessels
● EKG changes
● Myocardial necrosis
● Liver enlargement
● Sensitivity to light,
sound/ olfactory stimuli
● Altered color
recognition
● Altered sex ratio of
births (more females)
Gastrointestinal Disorders
● Anorexia
● Gastrointestinal
disorders
● Epigastric pain
● Constipation
● Altered secretion of
stomach (digestive
juices
Endocrine Gland Changes
● Hyperthyroidism
● Thyroid enlargement
● Altered adrenal cortex
activity
● Increased uptake of
radioactive iodine
● Altered pituitary
function
● Low T: Hypogonadism
(lower testosterone
production)
● Lower glucotcorticoidal
activity
● Decreased corticosteroids
in blood
● Change in glycogen
concentration in liver
● Alteration of ketosteroids in
urine
Enzyme and other biochemical changes
● Alteration: cell division
● Increased RNA in
lymphocytes
● Decreased RNA in
brain, liver, spleen
● Tissue cultures killed
● Pyruvic acid, lactic acid,
and creatinine excretion
● Protein denaturation
● Altered 17 - Ketosteroids
● Hyperglycemia
● Changes in:
○ Cholinesterase
○ Phosphatase
○ Transaminase
○ Amylase
20 | Page
Metabolic Disorders
● Glycosuria (sugar in urine)
● Altered: rate of Metabolic
process
● Increase in
Urinary Phenol
● Altered carbohydrate
metabolism
Vascular disorders
● Thrombosis (blood clot)
● Hypertension
Miscellaneous Effects
● Changes in circadian
rhythms
● Hair loss
● Brittleness of hair
● Metallic taste in mouth
● Sensations of buzzing,
vibrations, pulsations,
tickling about head and
ears
● Changes in optical
activity
● Sparking between
dental fillings
● Copious perspiration,
salivation diseases
Pearl Chain Effect
● Changes in intracellular orientation of subcellular particles
APPENDIX B:
A comparison of Radiofrequency Radiation Exposure Standards from around the world:
21 | Page
Microwatts/ square meter
US 5,800,000
Russia 100,000
China 60,000
Italy 50,000
Switzerland 42,000
Salzburg, Austria 1,000
Changes in Physiological Function
● Decreased fertility
● Altered rate of
calcification
(osteoporosis)
● Alteration: menstrual
activity
● Loss of anatomical
parts
● Structural changes in
cerebral cortex
● Alteration: blood flow
● Dehydration
● Alteration: diameter of
blood vessels
● EKG changes
● Myocardial necrosis
● Liver enlargement
● Sensitivity to light,
sound/ olfactory stimuli
● Altered color
recognition
● Altered sex ratio of
births (more females)
Gastrointestinal Disorders
● Anorexia
● Gastrointestinal
disorders
● Epigastric pain
● Constipation
● Altered secretion of
stomach (digestive
juices
Endocrine Gland Changes
● Hyperthyroidism
● Thyroid enlargement
● Altered adrenal cortex
activity
● Increased uptake of
radioactive iodine
● Altered pituitary
function
● Low T: Hypogonadism
(lower testosterone
production)
● Lower glucotcorticoidal
activity
● Decreased corticosteroids
in blood
● Change in glycogen
concentration in liver
● Alteration of ketosteroids in
urine
Enzyme and other biochemical changes
● Alteration: cell division
● Increased RNA in
lymphocytes
● Decreased RNA in
brain, liver, spleen
● Tissue cultures killed
● Pyruvic acid, lactic acid,
and creatinine excretion
● Protein denaturation
● Altered 17 - Ketosteroids
● Hyperglycemia
● Changes in:
○ Cholinesterase
○ Phosphatase
○ Transaminase
○ Amylase
20 | Page
Changes in Physiological Function
● Decreased fertility
● Altered rate of
calcification
(osteoporosis)
● Alteration: menstrual
activity
● Loss of anatomical
parts
● Structural changes in
cerebral cortex
● Alteration: blood flow
● Dehydration
● Alteration: diameter of
blood vessels
● EKG changes
● Myocardial necrosis
● Liver enlargement
● Sensitivity to light,
sound/ olfactory stimuli
● Altered color
recognition
● Altered sex ratio of
births (more females)
Gastrointestinal Disorders
● Anorexia
● Gastrointestinal
disorders
● Epigastric pain
● Constipation
● Altered secretion of
stomach (digestive
juices
Endocrine Gland Changes
● Hyperthyroidism
● Thyroid enlargement
● Altered adrenal cortex
activity
● Increased uptake of
radioactive iodine
● Altered pituitary
function
● Low T: Hypogonadism
(lower testosterone
production)
● Lower glucotcorticoidal
activity
● Decreased corticosteroids
in blood
● Change in glycogen
concentration in liver
● Alteration of ketosteroids in
urine
Enzyme and other biochemical changes
● Alteration: cell division
● Increased RNA in
lymphocytes
● Decreased RNA in
brain, liver, spleen
● Tissue cultures killed
● Pyruvic acid, lactic acid,
and creatinine excretion
● Protein denaturation
● Altered 17 - Ketosteroids
● Hyperglycemia
● Changes in:
○ Cholinesterase
○ Phosphatase
○ Transaminase
○ Amylase
20 | Page
Changes in Physiological Function
● Decreased fertility
● Altered rate of
calcification
(osteoporosis)
● Alteration: menstrual
activity
● Loss of anatomical
parts
● Structural changes in
cerebral cortex
● Alteration: blood flow
● Dehydration
● Alteration: diameter of
blood vessels
● EKG changes
● Myocardial necrosis
● Liver enlargement
● Sensitivity to light,
sound/ olfactory stimuli
● Altered color
recognition
● Altered sex ratio of
births (more females)
Gastrointestinal Disorders
● Anorexia
● Gastrointestinal
disorders
● Epigastric pain
● Constipation
● Altered secretion of
stomach (digestive
juices
Endocrine Gland Changes
● Hyperthyroidism
● Thyroid enlargement
● Altered adrenal cortex
activity
● Increased uptake of
radioactive iodine
● Altered pituitary
function
● Low T: Hypogonadism
(lower testosterone
production)
● Lower glucotcorticoidal
activity
● Decreased corticosteroids
in blood
● Change in glycogen
concentration in liver
● Alteration of ketosteroids in
urine
Enzyme and other biochemical changes
● Alteration: cell division
● Increased RNA in
lymphocytes
● Decreased RNA in
brain, liver, spleen
● Tissue cultures killed
● Pyruvic acid, lactic acid,
and creatinine excretion
● Protein denaturation
● Altered 17 - Ketosteroids
● Hyperglycemia
● Changes in:
○ Cholinesterase
○ Phosphatase
○ Transaminase
○ Amylase
20 | Page
Changes in Physiological Function
● Decreased fertility
● Altered rate of
calcification
(osteoporosis)
● Alteration: menstrual
activity
● Loss of anatomical
parts
● Structural changes in
cerebral cortex
● Alteration: blood flow
● Dehydration
● Alteration: diameter of
blood vessels
● EKG changes
● Myocardial necrosis
● Liver enlargement
● Sensitivity to light,
sound/ olfactory stimuli
● Altered color
recognition
● Altered sex ratio of
births (more females)
Gastrointestinal Disorders
● Anorexia
● Gastrointestinal
disorders
● Epigastric pain
● Constipation
● Altered secretion of
stomach (digestive
juices
Endocrine Gland Changes
● Hyperthyroidism
● Thyroid enlargement
● Altered adrenal cortex
activity
● Increased uptake of
radioactive iodine
● Altered pituitary
function
● Low T: Hypogonadism
(lower testosterone
production)
● Lower glucotcorticoidal
activity
● Decreased corticosteroids
in blood
● Change in glycogen
concentration in liver
● Alteration of ketosteroids in
urine
Enzyme and other biochemical changes
● Alteration: cell division
● Increased RNA in
lymphocytes
● Decreased RNA in
brain, liver, spleen
● Tissue cultures killed
● Pyruvic acid, lactic acid,
and creatinine excretion
● Protein denaturation
● Altered 17 - Ketosteroids
● Hyperglycemia
● Changes in:
○ Cholinesterase
○ Phosphatase
○ Transaminase
○ Amylase
20 | Page
Metabolic Disorders ● Glycosuria (sugar in urine)
● Altered: rate of Metabolic
process
● Increase in
Urinary Phenol
● Altered carbohydrate
metabolism
Vascular disorders
● Thrombosis (blood clot)
● Hypertension
Miscellaneous Effects
● Changes in circadian
rhythms
● Hair loss
● Brittleness of hair
● Metallic taste in mouth
● Sensations of buzzing,
vibrations, pulsations,
tickling about head and
ears
● Changes in optical
activity
● Sparking between
dental fillings
● Copious perspiration,
salivation diseases
Pearl Chain Effect
● Changes in intracellular orientation of subcellular particles
APPENDIX B:
A comparison of Radiofrequency Radiation Exposure Standards from around the world:
21 | Page
Microwatts/ square meter
US 5,800,000
Russia 100,000
China 60,000
Italy 50,000
Switzerland 42,000
Salzburg, Austria 1,000
Metabolic Disorders ● Glycosuria (sugar in urine)
● Altered: rate of Metabolic
process
● Increase in
Urinary Phenol
● Altered carbohydrate
metabolism
Vascular disorders
● Thrombosis (blood clot)
● Hypertension
Miscellaneous Effects
● Changes in circadian
rhythms
● Hair loss
● Brittleness of hair
● Metallic taste in mouth
● Sensations of buzzing,
vibrations, pulsations,
tickling about head and
ears
● Changes in optical
activity
● Sparking between
dental fillings
● Copious perspiration,
salivation diseases
Pearl Chain Effect
● Changes in intracellular orientation of subcellular particles
APPENDIX B:
A comparison of Radiofrequency Radiation Exposure Standards from around the world:
21 | Page
Microwatts/ square meter
US 5,800,000
Russia 100,000
China 60,000
Italy 50,000
Switzerland 42,000
Salzburg, Austria 1,000
Metabolic Disorders ● Glycosuria (sugar in urine)
● Altered: rate of Metabolic
process
● Increase in Urinary Phenol
● Altered carbohydrate metabolism
Vascular disorders
● Thrombosis (blood clot)
● Hypertension
Miscellaneous Effects
● Changes in circadian
rhythms
● Hair loss
● Brittleness of hair
● Metallic taste in mouth
● Sensations of buzzing,
vibrations, pulsations,
tickling about head and
ears
● Changes in optical
activity
● Sparking between
dental fillings
● Copious perspiration,
salivation diseases
Pearl Chain Effect
● Changes in intracellular orientation of subcellular particles
APPENDIX B:
A comparison of Radiofrequency Radiation Exposure Standards from around the world:
21 | Page
Microwatts/ square meter
US 5,800,000
Russia 100,000
China 60,000
Italy 50,000
Switzerland 42,000
Salzburg, Austria 1,000
Metabolic Disorders ● Glycosuria (sugar in urine)
● Altered: rate of Metabolic
process
● Increase in Urinary Phenol
● Altered carbohydrate metabolism
Vascular disorders
● Thrombosis (blood clot)
● Hypertension
Miscellaneous Effects
● Changes in circadian
rhythms
● Hair loss
● Brittleness of hair
● Metallic taste in mouth
● Sensations of buzzing,
vibrations, pulsations,
tickling about head and
ears
● Changes in optical
activity
● Sparking between
dental fillings
● Copious perspiration,
salivation diseases
Pearl Chain Effect
● Changes in intracellular orientation of subcellular particles
APPENDIX B:
A comparison of Radiofrequency Radiation Exposure Standards from around the world:
21 | Page
Microwatts/ square meter
US 5,800,000
Russia 100,000
China 60,000
Italy 50,000
Switzerland 42,000
Salzburg, Austria 1,000
Metabolic Disorders ● Glycosuria (sugar in urine)
● Altered: rate of Metabolic
process
● Increase in
Urinary Phenol
● Altered carbohydrate
metabolism
Vascular disorders
● Thrombosis (blood clot)
● Hypertension
Miscellaneous Effects
● Changes in circadian
rhythms
● Hair loss
● Brittleness of hair
● Metallic taste in mouth
● Sensations of buzzing,
vibrations, pulsations,
tickling about head and
ears
● Changes in optical
activity
● Sparking between
dental fillings
● Copious perspiration,
salivation diseases
Pearl Chain Effect
● Changes in intracellular orientation of subcellular particles
APPENDIX B:
A comparison of Radiofrequency Radiation Exposure Standards from around the world:
21 | Page
Microwatts/ square meter
US 5,800,000
Russia 100,000
China 60,000
Italy 50,000
Switzerland 42,000
Salzburg, Austria 1,000
Metabolic Disorders ● Glycosuria (sugar in urine)
● Altered: rate of Metabolic
process
● Increase in
Urinary Phenol
● Altered carbohydrate
metabolism
Vascular disorders
● Thrombosis (blood clot)
● Hypertension
Miscellaneous Effects
● Changes in circadian
rhythms
● Hair loss
● Brittleness of hair
● Metallic taste in mouth
● Sensations of buzzing,
vibrations, pulsations,
tickling about head and
ears
● Changes in optical
activity
● Sparking between
dental fillings
● Copious perspiration,
salivation diseases
Pearl Chain Effect
● Changes in intracellular orientation of subcellular particles
APPENDIX B:
A comparison of Radiofrequency Radiation Exposure Standards from around the world:
21 | Page
Microwatts/ square meter
US 5,800,000
Russia 100,000
China 60,000
Italy 50,000
Switzerland 42,000
Salzburg, Austria 1,000
Metabolic Disorders ● Glycosuria (sugar in urine)
● Altered: rate of Metabolic
process
● Increase in
Urinary Phenol
● Altered carbohydrate
metabolism
Vascular disorders
● Thrombosis (blood clot)
● Hypertension
Miscellaneous Effects
● Changes in circadian
rhythms
● Hair loss
● Brittleness of hair
● Metallic taste in mouth
● Sensations of buzzing,
vibrations, pulsations,
tickling about head and
ears
● Changes in optical
activity
● Sparking between
dental fillings
● Copious perspiration,
salivation diseases
Pearl Chain Effect
● Changes in intracellular orientation of subcellular particles
APPENDIX B:
A comparison of Radiofrequency Radiation Exposure Standards from around the world:
21 | Page
Microwatts/ square meter
US 5,800,000
Russia 100,000
China 60,000
Italy 50,000
Switzerland 42,000
Salzburg, Austria 1,000
AD-A282 886
AIL-TR-94-53
in-House Report
June 1994
RADIOFREQUENCYIMICROWAVE
RADIATION BIOLOGICAL EFFECTS AND
SAFETY STANDARDS: A REVIEW
Scfit M. Bolon
APWFOR PVJ&C.0FAWD,7R, J7iVNUNLAI7.rr.
Rome Laboratory
Air Force Materiel Command
GrAffin Mr Force Ban, New York
S94-24212 U.G 4Ao 1,3,, A.=.L
ju-0074 1
This report has been reviewed by the Rome Laboratory Public Affairs Office
(PA) and is releasable to the National Technical Information Service (NTIS). At
NTIS it will be releasable to the general public, including foreign nations.
RL-TR-94-53 has been reviewed and is approved for publication.
APPROVED: '
JOSEPH J. SIMONS, Chief
Wide Area Radar Surveillance Division
Surveillance & Photonics Directorate
FOR THE COMMANDER: 1 /'4 -.- .
LUKE L. LUCAS, Colonel, USAF
Aoeosslon toy_1Deputy Director, NTIS GrA&I T Surveillance & Photonics Directorate
DTIC TAB- 0Uannounoed [0
jast t tcatio
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REPORT DOCUMENTATION PAGE m V No oi-aPUM ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o 0704-0MNOW 61Ný410PIhpl 1~ 1f80A*
i =o ddmlsomes"26009 Sulin O t P0 ww
1. AGENY UKE ONLY #Aim U1# .M, DMOAIE FMF TV1, AND DATES COVERED
SJune 1994 In-House Jun 88 -May 93
4, 7MJEQAD ThJLl IL FUIN NUMBERS
RADIOFREQUECY/MICROWAVE RADIATION BIOLOGICAL EFFECTS PE -62702F
AND SAFETY STANDARDS: A REVIEW PR -4506
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Scott M. Bolen
7. PEWFORINS ORAMA7~A1ON NAME(8) AND A01NESNS) PERIORMING ORGANIZATION
Rome Laboratory (OCDS) REPORT NUMBER
26 Electronic Pky RL-TR-94-53
Griffiss AFB NY 13441-4514
2L i-:. F-ONT06 AGNC NAE N.0FAW PIDRNA ORING
Rome Laboratory (OCDS) AGENCY REPORT NUMBER
26 Electronic Pky
Griffiss AFB NY 13441-4514
11. MJPPLWMENTARY NO10
Rome Laboratory Project Engineer: Scott M. Bolen/OCDS (315) 330-4441.
S2san, OSSThJTo#MvALAUTY STATEMENT lab OSSTRIBJNON CODE
Approved for public release; distribution unlimited.
136 AS*7PAT#aTm waNn
The study of human exposure to radiofrequency/microwave (RF/MW) radiation has been
the subject of widespread investigation and analysis. It is known chat electro-
magnetic radiation has a biological effect on human tissue. An attempt has been
made by researchers to quantify the effects of radiation exposure on the human
body and to set guidelines for safe exposure levels. A review of the pertinent
findings is presented along with the American National Standards Institute (ANSI)
recommended safety standard (C95.1-1982) and the United States Air Force permissible
exposure limit for RF/140 radiation (AFOSH Standard 161-9, 12 Feb 87). An overview
of research conducted in the Soviet Union and Eastern Europe is also included in
this report.
14. SUBJECT7EM1 I .... m OFPA
RF/NW Hazards, RF/WM Exposure, 11/14W Safety Standards 36
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Radiofrequency/Micowave Radiation Biological Effects and Safety
Standards: A Review
Scott M. Bolen
June 1988
Abstract
The study of human exposure to radiofrequency/microwave radiation has been the
subject of widespread investigation and analysis. It is known that electromagnetic radiation
has a biological effect on human tissue. An attempt has been made by researchers to
quantify the effects of radiation on the human body and to set guidelines for safe exposure
levels. A review of the pertinent findings is presented along with the American National
Standards Institute (ANSI) recommended safety standard (C95.1-1982) and the United States
Air Force permissible exposure limit for RF/MW radiation (AFOSH Standard 161-9, 12
February 1987). An overview of research that was conducted in the Soviet Union and
Eastern Europe is also included in this report.
I. INTRODUCTION
In 1956, the Department of Defense (DOD) directed the Armed Forces to investigate
the biological effects of exposure to radiofrequency/microwave (RF/MW) radiation. The
Army, Navy, and Air Force Departments commissioned a Tri-Service Program under the
supervision of the Air Force to meet the DOD directive (14), [15]. The Rome Air
Development Center and the Air Research and Development Headquarters were ultimately
given rspmsibility to manage the program. On July 15-16, 1957 the first of four Tri-
Service Cmferences was held to discuss the effects of RF/MW radiation. These conferences
were the first major effort put forth by the scientific community to explore the biological
effects of exposure to RF/MW radiation [14]. Since then, researchers have discovered a
number of biological dysfunctions that can occur in living organisms. Exposure of the
human body to RF/MW radiation has many biological implications. The effects range from
innocuous sensations of warmth to serious physiological damage to the eye [1], [2], (5], [6],
[8], [15]. There is also evidence that RF/MW radiation can cause cancer (81.
The absorption of RF/MW radiated energy causes biological reactions to occur in the
tissue of the human body. In order to determine safe exposure levels and to understand the
effect of RF/MW radiation it is necessary to know the absorption characteristics of the
human tissue. The National Institute for Occupational Safety and Health (NIOSH) (8] has
reported several physical properties that account for energy absorption in biological
materials. Factors which govern energy absorption include: (1) strength of the external
en (EM) field, 2) frequency of the RF/MW source, 3) the degree of hydration
of die tissue, and 4) the physical dimensions, geometry, and orientation of the absorbing
body with respect to the radiation EM field (8]. There is some disagreement among
researchers in determining a specific measure for the dose of RF/MW radiation contracted by
I 1
biological materials. The most commonly accepted measure is the Specific Absorption Rate
(SAR). The SAR is defined as the rate at which RF/MW radiated energy is imparted to the
body -typically in units of watts per kilogram (W/Kg) [41. The deposition of energy
specfd in terms of milliwatts per square centimeter (mW/cm2) over the irradiated surface is
alo widely accepted [9].
Based on the known absorption rates and the inherent biological effects of RF/MW
radiated energy, researchers have put forth a number of standards regarding safe exposure
levels. In some instances standards recommended by different examining authorities are in
conflict. For example, the USAF Standard 161-9 (enacted 12 February 1987) allows for a
permissible exposure level of 10 mW/cm2 for persons working in restricted areas and 5
mW/cm2 for persons working in unrestricted areas [10]. The ANSI guideline specifies a
maximum safe exposure level of 5 mW/cm2 over the whole-body area for anyone in contact
with RF/MW radiation [9]. These differences reflect the way in which each examining
authority has interpreted the available RF/MW radiation exposure data.
II. BIOLOGICAL EFFECTS
Exposure to RF/MW radiation is known to have a biological effect on animals and
humans. Damage to major organs, disruption of important biological processes, and the
potential risk of cancer represent the dangers of RF/MW radiation to living organisms.
Pulsed radiation appears to have the greatest impact on biological materials (8].
The response of biological materials to the absorption of thermal energy is the most
pecepble effect of exposure to RF/MW radiation [7]. The energy emitted from an RF/MW
source is absorbed by the- human tissue primarily as heat. In this case, the radiated energy is
disposed in the molecules of the tissue. Dipole molecules of water and protein are stimulated
and will vibrate as energy is absorbed throughout the irradiated tissue area. Ionic conduction
will also occur in the same area where the radiation is incident. It is from these two natural
processes that radiant energy is converted into heat [11]. The thermal effect of continuous
wave (CW) and pulsed radiation is considered to be the same (13].
Nonthermal responses can be less noticeable and are often more difficult to explain
than themmal effects. These responses are related to the disturbances in the tissue not caused
by heating. Electromagnetic fields can interact with the bioelectrical functions of the
irradiated human tissue (8]. Research conducted in the Soviet Union and Eastern Europe
suggests that the human body may be more sensitive to the antheima effects of RF/MW
radiation [3].
There are many reported biological effects to humans and animals that are exposed to
RF/MW radiation. A review of the important findings is given in the following:
A. Heaing Ffm on die SkIn
Most RF/MW radiation penetrates only to the outer surface of the body. This is
especially true for RF/MW frequencies greater than 3 GHz where the likely depth of
penetration is about 1-10 mm (3]. At frequencies above 10 GHz the absorption of energy
will occur mostly at the outer skin surface. Since the therma receptors of the body are
contained primarily in this region, the perception of RF/MW radiation at these frequencies
2
may be similar to that of infrared (1R) radiation [3], [6].
In 1937, J. Hardy and T. Oppel published an investigative paper on the thermal
effects of IR radiation. Their findings were used by Om Gandhi and Abbas Riazi [6] to
explain the thermal effect of RF/MW radiation on the human body (the reference for Hardy
and Oppel can be found in [6]). Figure 1 shows the results obtained from the 1937 report.
As described by Gandhi and Riazi, the findings presented by Hardy and Oppel show that
senaidons of warmth begin to occur when the whole-body is irradiated at a CW power
density of about 0.67 mW/cm2 .Hardy and Oppel based their work on exposure to IR
radiation. From other published reports, Gandhi and Riazi noted that there is a correlation
between the radiating frequency of the incident RF/MW energy and the threshold for
percepion. For example, on an exposed area of the forehead of 37 cnm a perception of
warmth was reported for incident power densities of 29.9 and 12.5 mW/cm2 from sources
radiating at 3 and 10 GHz respectively [6].
Other observations made by Hardy and Oppel showed that when smaller body areas
were irradiated, larger power densities were required to stimulate the thermal receptors in the
skin. Gandhi and Riazi were able to confirm this result with reports from recent papers.
They found that irradiation of an exposed body area of 40.6 cm2 to a power density of about
21.7 mW/cm2 yielded the same thermal perception as did the irradiation of a smaller body
area of 9.6 cm2 to a power density of about 55.9 mW/cm2 .Hardy and Oppel reported that
thermal sensations occurred within about 3 seconds after irradiation of the body tissue. More
recent findings indicate a reaction time of closer to I second (6].
Gandhi and Riazi (6] have also reported that the depth of penetration of RF/MW
radiation has an impact on the power density threshold needed to stimulate the perception of
warmth. As a comparison, IR radiation will not penetrate the outer body surface as deeply
as RF/MW radiation emitted at a frequency of 2.45 GHz. Clinical observations have shown
that irradiation of the ventral surface of the arm by an RF/MW source radiation at 2.45 GHz
will cause a sensatki of warmth when the incident power density is about 26.7 mW/cm 2 .
For incident IR radiation a perception of warmth occurs at a power density of 1.7 mW/cm2 .
They estimated that at millimeter wavelengths the perception of warmth may occur at a
power density level of about 8.7 mW/cm 2 .
Exposure to higher levels of radiation can cause serious biological effects. Because of
the physical dimensions and geometry of the human body, RF/MW radiated energy is
nonuniformily deposited over the whole-body surface. Some areas on the skin and outer
body surface will absorb higher amounts of the radiated energy. These areas will be marked
by "hot spots" of high temperatures (7], [11], (16]. Experiments conducted on laboratory
animals have shown, that skin burns typically occur in the areas of hot spots. The
penetration of RF/MW radiation also causes skin burns to be relatively deep [11]. In
P erIments sponsored by the Tri-Service Commission, it was reported that RF/MW
radiation burns over the nrb cages of dogs caused severe subcutaneous damage that did not
visibly appear for weeks after the injury was sustained [20]. Burns can cause increased
vascular permeability. This can lead to significant losses of body fluids and electrolytes.
Serious burns can suffer fluid losses for a few days. Blood circulation can be altered in the
effected area and other biological functions could be indirectly affected [12].
B. Wfole-Body Hyperthennia
3
Thermal energy absorbed by the whole-body can cause a rise in body temperature.
When the human body is irradiated by an RF/MW source at an incident power density of 10
mW/cm2 there will be a rise in body temperature of about P C. The total thermal energy
absorbed at this power density is about 58 watts. Typically, at rest the human basal
metabolic nrt is about 80 watts and it is about 290 watts during periods of moderate activity.
Exposure of the human body to low power RF/MW radiation does not appear to impose any
appreciable thermal hazard. These figures were reported by The U.S. Department of Health,
Education and Welfare [3].
Adverse biological effects can occur when the body is subjected to high doses of
RF/MW radiation [161. In this instance large amounts of thermal energy can be absorbed by
the body. A dramatic influx of energy can overburden thermoregulatory mechanisms. If
excess heat cannot be exhausted the core temperature of the body will rise to a dangerous
level resulting in hyperthermia [12], [16]. The biological response to excess heat buil'up is
the dilation of blood vessels at the surface of the skin and the evaporation of water through
sweating. These are the primary mechanisms for heat dissipation. Hyperthermia can cause
severe dehydration and the loss of electrolytes such as sodium chloride. Other harmful
effects include fever, heat exhaustion, and heat fatigue. Heat stress is the most serious
consequence of hyperthermia. Cardiac failure and heat stroke can result from heat stress
[12].
It has also been noted that hyperthermia may cause injury to blood-brain barrier
(BBB) [19]. This barrier refers to the several biological materials that separate the essential
elements of the central nervous system from the blood [18]. High cerebral temperatures
exceeding 439C may damage the BBB. The result can be a disruption of blood vessel
continuity or integrity and degradation of the flow of blood and other body fluids in the brain
[191.
C. Local Hype/hermda
The nonuniform deposition of RF/MW radiated energy over the whole-body surface
causes the body to be heated unevenly. Local areas where temperatures rise above 41.6 0C
can experience damage to the tissue [161. In these areas it is possible that harmful toxins
could be released as result of the high temperatures. Heating can cause cell membranes and
blood capillaries to become more permeable. An increase in capillary permeability can lead
to a loss of plasma proteins. The denaturation of proteins can also occur within cells [111,
[16]. This can lead to changes in the physical properties and biological functions of proteins
[18]. Dernauration of proteins can also cause polypeptide and histamine-like substances to
become active [11], [16]. Histamines can stimulate gastric secretion, accelerate the heart
rate, and cause the dilation of blood vessels resulting in lower blood pressure [18]. Areas of
the body where blood circulation is poor or where thermal regulation is insufficient, are
more susceptible to injury [11].
D. Carcinogenic Fifects
The carcinogenic effects of exposure to RF/MW radiation are not well known. It is
difficult to clinically establish a link to cancer. The problem that researchers have in linking
4
RF/MW radiation to cancer is that the disease itself is prevalent and can be caused by a
variety of environmental factors. In fact cancer is the second leading cause of death in the
United States. There are, however, published reports that reveal some insights into the
carcinogenic nature of RF/MW radiation. Nonthermal effects may provide important clues
to the u 1dr 1nig of carcinogenic reactions in the human body [8],[32].
i. Pathological Reports
In 1962, S. Prausnitz and C. Susskind reported experimental results that showed an
increase in cancer among test animals exposed to RF/MW radiation. In the experiment, 100
male Swiss albino mice were irradiated by a 10 GHz RF/MW source at an incident power
density of about 100 mW/cm2 . The mice were exposed for 4.5 minutes/day, 5 days/week for
a total of 59 weeks. It was noted that irradiation caused the whole-body temperature of the
mice to rise about 3.3TC. Upon examination, it was found that 35% of the mice had
developed cancer of the white blood cells. The disease was observed as monocytic or
lymphatic leucosis or lymphatic or myeloid leukemia. Only 10% of a similar control group
had developed cancer [21].
There have been a few allegations that RF/MW radiation has induced cancer in
humans [8], [151. The NIOSH Technical Report [81 cites charges made in the early 1970's
against Philco-Ford and The Boeing Corporation that occupational exposure to RF/MW
radiation caused cancer among employees. One incident was reported at each company. At
Philco-Ford it was claimed that exposure caused a rare form of brain cancer to manifest in
one worker that eventually resulted in death. In each case, there was no scientific proof that
RF/MW radiation had induced cancer in the company employees. There was also a report
that EM fields induced cancer in an individual that worked at the U.S. Embassy in Moscow.
Again, there was no scientific evidence that supported the claim [8].
Recently, the Observer Dispatch, a local newspaper published in Utica, New York,
reported that a major study has just been completed in Sweden. The study concluded that
children who live near high power lines have a greater risk of developing leukemia than
children who live farther away from the power lines. The study involved 500,000 people
and provided some evidence to link the electromagnetic fields produced by low frequency
power lines to cancer. The researchers, however, cautioned against drawing firm
conclusions as a result of the research [33]
ii. ffect on Chromosomes
It has been observed that disturbances in chromosomic activity can cause cancerous
aberrations to occur in the human body. In 1974, a paper published by K. Chen, A. Samuel,
and R. Hoopingarner (reference found in [8]) reported that chromosomal abnormalities can
be linked to chronic myeloid leukemia. Serious genetic mutations can also result from such
abnormalities that can lead to malignancies in the tissue [8].
In 1976, A. A. Kapustin, M. I. Rudnev, G. I. Leonskaia, and G.I. Knobecva
(reference found in [17]) reported alterations in the chromosomes of bone marrow cells in
laboratory animals that were exposed to RW/MW radiation. They exposed inbred albino rats
to a 2500 MHz ,F/MW source at incident power density levels of 50 and 500 uW/cm2 .
Irradiation lasted for 7 hours/day for 10 days. Upon examination of the animals, they
"5
observed chromosomal anomalies that appeared in forms described as polyploidy,
aneuploidy, chormatic deletion, acentric fragments and chromatic gaps [17].
The NIOSH Technical Report [8] summarizes the findings of several researchers.
Chtomosomal and mitotic anomalies have been observed in a variety of animal and human
cells for varying exposures to RF/MW radiation. Pulsed and CW radiation ranging in
frequency from 15 to 2950 MHz and power densities from 7 to 200 mW/cm2 have caused
abnormalities to occur in chromosomes. The reported affects include: linear shortening of
the chromosomes, irregularities in the chromosomal envelope, abnormal bridges and
stickiness, translocations, chromosomal breaks and gaps, chromatid breaks, acentric
chromosomes, dicentric chromosomes, deletions, fragmentation, and ring chromosomes [8].
iii. Mutagenic Effects
Reported evidence indicates that biological interaction with EM fields can cause the
formation of mutagens in cells. In 1974, three Soviet researchers, Danilenko, Mirutenko,
and KIudrenko (reference found in [8]) published results showing a mutagenic effect of
RF/MW radiation. Mutagens were observed to form in cells that were irradiated by a pulsed
RF/MW source operating at 37 GHz and 1 mW/cm2 power intensity. They concluded that
irradiation of tissue by pulsed RF/MW sources causes cell membranes to become more
permeable to destructive chemical mutagens [8].
Results published in 1963 by G. H. Mickey (reference found in [8]) showed
hereditary changes to occur in drosphila germ cells that were exposed to pulsed modulated
RF/MW radiation for carrier frequencies between 5-40 MHz [8]. Evidence of RF/MW
induced teratogenesis in animals has also been reported by researchers. The effect of
exposure to CW radiation was observed by Rugh and McManaway in 1976 (reference found
in [8]). They found gross congenital abnormalities in rodent fetuses that were irradiated by a
2450 MHz RF/MW source at an incident power intensity of 107.4 mW/g [8].
iv. Lymphoblastoid Transformations
Lymphoblastoid Transformations refer to changes in the physical nature of
lymphoblasts. Mature lymphoblast cells (i.e. lymphocytes) participate in the immune system
of the body (18]. Lymphoblastoid transformations induced by RF/MW radiation appear to
be similar to transformations present in disorders contributing to abnormal growth in
lymphoid tissues and in certain types of leukemia. RF/MW radiation induced
transformations, however, do not appear to be malignant and are not likely to spread among
healthy cells (8].
W. Stodlink-Baranska reported (reference found in [8]) lymphoblastoid
transformations to occur when human lymphocyte cells were exposed to a 2950 MHz pulsed
RF/MW source at power density levels of 7 and 20 mW/cm 2 .In 1975, P. Czerski also
reported (reference found in [8]) observing lymphoblastoid transformations after irradiation
of purified human lymphocyte suspensions by an RF/MW source radiating at 2950 MHz for
variable power density levels. In addition, Czerski reported acute transformations occurring
in adult mice and rabbits that were irradiated by a pulsed RF/MW source radiating at 2950
MHz and at low power density levels of 0.5 and 5 mW/cm2 respectively [8].
6
v. Oncogemc Effects
Oncogenic effects have been linked to imbalances in the regulatory mechanisms of the
body. A 1974 report published by E. Klimkova-Deutschova (reference found in [8]) claimed
that persons exposed to RF/MW radiation experience biochemical reactions. The report
indicated alterations in fasting blood sugar levels, a decrease in the ability to dispose of
normal metabolic waste, and depressed serum levels of pyruvate and lactate. These
bioche mical reactions point to the possibility of regulatory malfunctions occurring in the
body. It has been suggested that certain regulatory imbalances may promote the growth of
tumors. A change in hormonal levels has been observed to cause oncogenic effects in tissues
that require hormonal balances to function properly. The presence of hormones in other
tissue areas may effect the development of existing tumors in those areas [8].
E. Cardiovascular Effects
Most of the cardiovascular effects of RF/MW radiation have been reported by
researchers in the Soviet Union and Eastern Europe. Soviet investigators claim that exposure
to low levels of RF/MW radiation that are not sufficient to induce hyperthermia can cause
aberrations in the cardiovascular system of the body [7].
One experiment performed on rabbits indicates that several types of cardiovascular
dysfunctions could be possible. An RF/MW source radiating at 2375 MHz was used to
irradiate rabbits for a test period of 60 days under varying field intensities. For field
strengths ranging from 3-6 V/M researchers noted a sharp increase in the heart rate of the
animals. This effect was observed to subside with time. Exposure to field strengths of 0.5-
1.0 V/M caused the heart rate to become slower than normal. No effect was reported for
rabbits that were exposed to EM field intensities below 0.2 V/M [17]. Other effects that
have been observed by Soviet researchers, are alterations in EKG and low blood pressure
(7], [17].
The NIOSH Technical Report [8] references a Soviet study published in 1974 by M.
N. Sadcikoiva that suggests some connection between RF/MW radiation exposure and the
potential for cardiovascular disturbances in humans. Researchers examined 100 patients
suffering from radiation sickness. It was found that 71 of the patients had some type of
cardiovascular problem. Most of these patients had been exposed to RF/MW radiation for
periods ranging from 5-15 years. A smaller group of patients exposed for shorter time
periods also experienced cardiovascular irregularities. The study concluded that there is a
probable link between exposure to RF/MW radiation and cardiovascular disease [8].
F. The North Karelian Project
In response to earlier Soviet reports, the World Health Organization (WHO) decided
to conduct a comprehensive study on the biological effects of exposure to RF/MW radiation.
In 1976, M. Zaret published the results of the study (reference found in [8]). The WHO
investigation focused on the population of North Karelia, a remote area of Finland that
borders the Soviet Union. This region was selected because of its close proximity to a then
Soviet early warning radar station. North Karelia is geographically located in the path of
intercontinental ballistic missiles that would originate from the midwest United States. To
7
detect these missiles, the Soviets constructed a number of high power tropospheric scattering
radar units adjacent to nearby Lake Ladoga. The operation of these units exposes the
residents of North Karelia to large doses of ground and scatter radiation. The WHO
negifound evidence linking exposure of RF/MW radiation to cardiovascular disease
and cancer. The North Karelian population suffered from an unusually high number of heart
attacks and cases of cancer. In addition, it was found that the affliction rate of these diseases
was much higher among residents living closest to the radar site [8].
G. Hematologic Effects
There is evidence that RF/MW radiation can effect the blood and blood forming
systems of animals and humans. Experiments conducted in the Soviet Union have indicated
changes in blood cell levels and alterations in the biological activities of hematologic
elements. Other investigators have reported similar effects [7], [8], [17].
The results of an experiment reported in 1979 by V. M. Shtemier showed a decrease
in the biological activity of butyryl cholinesterase in rats that were exposed to pulsed
RF/MW radiation (reference found in [17]). The experiment subjected 15 rats to a 3000
M&z pulsed RF/MW source with an incident power density of 10 mW/cm2 .The rats were
irradiated for I hour/day over several days. After 42 days, there was a loss of biological
activity of the butyryl cholinesterase enzyme caused by a decrease in the concentration of the
enzyme in the bloodstream of the rats [17]. Cholinesterase is a catalyst in the hydrolysis of
acetylcholine into choline and an anion. Choline is a useful enzyme that prevents the
deposition of fat in the liver [181.
In another experiment, 20 male rats were exposed to a 2376 MHz pulsed RF/MW
source with an incident power density of 24.4 mW/cm2. Each rat was exposed for 4
hours/day, 5 days/week for 7 weeks. Blood samples were taken periodically and examined
for anomalies. After repeated exposures, it was discovered that the number of lymphocytes
and leukocytes (white blood cells) in the bloodstream of the rats was lower than normal.
The biological activity of alkaline phosphatase in neutrophil leukocytes was also found to
increase when the rats were irradiated [17].
The results of several other experiments are summarized in the NIOSH Technical
Report [8]. RE/MW radiation has been observed to cause: an increase in the amount of
exudate in bone marrow, the transient disappearance of fat cells from bone marrow,
destruction and loss of essential bone marrow cells, underdeveloped marrow, a decrease in
the number of red blood cells, and an imbalance in the number of lymphocytes in the
bloodstream [8].
H. Effect to the Central Nervous System
There is documented evidence that exposure to RF/MW radiation can cause a
disturbance in the central nervous system (CNS) of living organisms [3], [8], [11], [17].
Soviet investigators claim that exposure to low-level radiation can induce serious CNS
dysfunctions. Experiments conducted in the Soviet Union and Eastern Europe have exposed
live subjects to radiation levels that are near or below the recommended safe levels
prescribed by the ANSI Standard and the USAF AFOSH Standard [17].
8
i. Pathological Repor
Soviet investigators claim that the central nervous system (CNS) is highly sensitive to
RP/MW radiation [3], [8], [11], [17]. The NIOSH Technical Report [81 summarized the
results of a pathological study published by A. A. Letavet and Z. V. Gordon in 1960. The
rreported that several CNS related disorders were discovered among 525 workers
exposed to RF/MW radiation. The symptoms were listed as: hypotension, slower than
normal heart rates, an increase in the histamine content of the blood, an increase in the
activity of the thyroid gland, disruption of the endocrine-hormonal process, alterations in the
sensitivity to smell, headaches, irritability, and increased fatigue. Other researchers have
acknowledged similar biological responses [8].
ii. Sovet Union Erpermenmal Resuls
Several experiments have been performed in the Soviet Union and Eastern Europe
that demonstrate a variety of biological effects that can occur in living organisms.
observations of laboratory animals subjected to low power EM fields showed alterations in
the electrical activity of the cerebral cortex and disruptions in the activity of neurons [17].
L. K. Yereshova and YU. D. Dumanski (reference found in [17]) exposed rabbits and
white male rats to a continuous wave 2.50 GHz RF/MW source. The animals were
irradiated for 8 hours/day over a period of 3 to 4 months at power density levels of 1, 5, and
10 uW/cr 2.It was observed that rabbits exposed to the 5 and 10 uW/cm 2 power density
levels suffered alterations in the electrical activity of the cerebra cortex and distufrb ces to
the conditioned reflex response. They concluded that exposure to RF/MW radiation caused
perturbations in the higher functioning centers of the CNS in the laboratory animals (17].
An experiment conducted by V. R. Faytel'berg-Blank and G. M. P;.revalov
demonstrated the biological effects of RF/MW radiation on the activity of neurons (reference
found in [17]. They subjected chinchilla rabbits to a 460 MHz RF/MW source at incident
power densities of 2 and 5 mW/cm2 .Only the heads of the rabbits were irradiated and
exposures lasted for 10 minutes. Exposure at the 2 mW/cm 2 power density level caused
neuronal activity to increase and evoked an electroencephalogram (EEG) activation reaction.
Neuronal activity was observed to decrease at the higher power density level. These results
indi'ated that RF/MW radiation can cause neurophysiological alterations in animals. These
biological responses may be dependent on the intensity of the radiation (17].
iii. Behavioral Effects
Exposure to RF/MW radiation has been observed to cause a disruption in the behavior
of animals. Experiments conducted on rats and nonhuman primates indicates that conditioned
responses can be altered as a result of irradiation. Researchers indicate that behavior may be
the most. sensitive biological component to RF/MW radiation [1], [7], [9], (29].
D. R. Justesen and N. W. King (reference found in [7]) reported experimental results
that demonstrated a degenerative behavioral effect in laboratory animals that were exposed to
RF/MW radiation. The results were published in 1970. They exposed rats to a 2450 MHz
multimodal resonating cavity system. Exposure was periodic with irradiation times lasting
for 5 minutes and recurring every 5 minutes. This cycle as sustained for 60 minutes. The
9
experiment tested the effect of irradiation at whole-body energy absorption rates of 3.0, 6.2,
and 9.2 W/Kg. It was observed that for a SAR of 6.2 W/Kg the behavioral performance of
the rats degraded significantly and activity usually terminated at the end of the 60 minute
exposr period [7.
In 1977, James Lin, Arthur Guy, and Lynn Caldwell [29] reported experimental
results that showed alterations in the behavioral response of rats that were exposed to
RF/MW radiation. White female rats were trained to execute a *head raising" movement in
return for a food pellet. The total number of such movements was counted during each
exposure session in order to quantify the effect of irradiation. The animals were exposed to
a 918 M]z RF/MW source at power density levels of 10, 20, and 40 mW/cm 2.Clinical
observation showed that baseline responses remained unchanged for irradiation at the lower
power density levels of 10 and 20 mW/cm2.At 40 mW/cmn, however, behavioral responses
decreased rapidly after 5 minutes of continuous exposure. After about 15 minutes of
exposure, behavioral activity terminated. It was determined that the peak energy absorption
at 40 mW/cm 2 was about 32 W/Kg and the average absorption was 8.4 W/Kg over the
whole-body surface [29].
iv. Synergetc Effect of Drugs RF/MW
Radlaton
In 1979, 1. R. Thomas et al. reported that psychoactive drugs and RF/MW radiation
may have a synergetic effect on living organisms (references for Thomas can be found in
[1D. Experiments were conducted on laboratory animals. Male albino rats were
administered dextroamphetamine and irradiated with a pulsed 2450 MHz RF/MW source at 1
W/cm? power intensity for periods of 30 minutes. It was found that the number of clinical
responses observed per minute in the rats diminished more rapidly under the stimulus of both
agents than in the control condition where just the drug was administered. This indicates that
the effects of RF/MW radiation may be enhanced by certain drugs [1].
v. Analeptic Effect in Animals
Pulsed RF/MW radiation was reported to have an analeptic effect in laboratory
animals. Experimental results presented by R. D. McAfee in 1971 showed that anethesized
animals could be awakened by irradiation from a pulsed 10 GHz RF/MW source. The
energy incident on the test animals was estimated to have a power density of between 20-40
mW/cm 2.Experiments conducted on rats showed that these animals were aroused from
states of deep sleep by irradiation. It was observed that the blood pressure of a rat decreased
simultaneously with the arousal response and that laryngeal spasms would occur when the rat
was awakened. McAfee reported that the laryngeal spasms would obstruct the airway
causing convulsions, asphyxiation, and eventually death. Other experiments performed on
rabbits, cats, and dogs showed that these animals could also be awakened by irradiation.
The larger animale, however, did not asphyxiate themselves, The blood pressure of the dogs
and cats was observed to rise as they were awakened. In all cases, the arousal response was
stimulated only when the head of the animal was irradiated. The body temperature of the
test animals was not observed to rise as a result of irradiation. This indicates that the
analeptic effect of RF/MW radiation may be nonthermal in nature [201.
10
L hnunaological Ffet
Exposure to RF/MW radiation has been observed to cause physical alterations in the
eusential cells of the immune system and a degradation of immunologic responses [7], [17].
E perimental results published by Soviet and Eastern European researchers indicate that
irradiation can cause injury and trauma to the internal body organs that comprise the immune
system. Even exposure to low levels of RF/MW radiation can impair immunologic functions
[17].
As discussed earlier, lymphoblasts can undergo physical alterations as a result of
irradiation. Lymohiblastoid mutagens are similar in structure to leukemia cells [8].
Lymphoblasts are the precursors to leukocyte cells that participate in the immune system
[181.
In 1979, N. P. Zalyubovskaya and R. I. Kiselev (reference found in [17]) reported
that exposure to RF/MW radiation caused serious damage to the immune system of
laboratory animals. They exposed mice to an RF/MW source radiating at 46.1 GHz with an
incident power intensity of I mW/cm2 for 15 minutes/day for 20 days, it was observed that
the number of leukocytes in the bloodstream of the mice decreased as a result of irradiation.
Effective quantities of enzymatic proteins in serum that combine with antigen-antibody
complex and antibacterial agents such as lysozyme were also reduced. Zalyubovskaya and
Kiselcv reported a decrease in the phagocytic activity of neutrophils and a diminished
resistance to infections caused by tetanic toxins. Immunity to typhoid and other tetanic
toxins induced by vaccination or by the administration of antitoxins was rendered ineffective.
Further examination of the mice .,iealed injury and trauma to the internal body organs.
Irradiation had caused physical,alterations in the thymus, spleen, and lymph nodes. The
lymphoid organs suffered a tal loss of mass [17].
J. Wect on the Eye
Clinical studies indicate that exposure to RF/MW radiation causes physiological
damage to the eye that can result in loss of sight. It has been observed that irradiation
causes the formation of cataracts in the lens of the eye. Tissue damage appears to be the
result of thermal trauma induced by the heating property of RF/MW radiation. Experiments
conducted on laboratory animals have demonstrated severe ocular damage as a result of
exposure [30], [31].
i. Ocular Sensidvy
Exposure of the eye to RF/MW radiation causes physical duress that can lead to
damage of the ocular tissue. The incident power intensity and the duration of radiation
exposure are factors that determine the amount of tissue damage. The lens of the eye
appears to be most susceptible to RF/MW energy radiated at frequencies between 1-10 GHz.
For this frequency range, it has been observed that lens fibers will suffer irreversible damage
to a greater extent than other ocular elements [30]. Lens fibers are elongated, thread-like
structures that form the substance of the lens [18]. In 1979, Stephen Cleary reported [30]
that cataracts are formed in the lens as a result of alterations in the paracystalline state of
lens proteins. Physical, chemical or metabolic stress may be responsible for opacification of
11
the lens [301.
U. &rpehmenu on Rabbid
Severe tissue damage has been observed in rabbits that have been exposed to RF/MW
radhat. Stephein Cleary [30] reports that intense radiation exposure can cause "immediate
tearing, injection, pupillary constriction, and anterior turbity" in the rabbit eye. Lens
opacities can occur when the eye is irradiated by a 2450 MHz RF/MW source at incident
power density levels of 100-300 mW/cm2 . At this exposure level, cataracts have been
observed to form 24-48 hours after irradiation [30]. In 1976, Kramer, Harris, Emery, and
Guy (reference found in [30 reported observing the formation of cataracts in rabbit eyes
that were exposed to 2450 MHz RF/MW radiation at an incident power density level of 180
mW/cur2 for an exposure time of 140 minutes [30].
Acute ocular damage and the formation of cataracts appears to be the result of local
hypesthermia of the eye. It has been observed, however, that trauma induced by heating of
the ocular tissue may be unique to the exposure effects of RF/MW radiation [30]. In 1975,
Kramer, Harris, Emery, and Guy (reference found in (30]) reported subjecting rabbits to
hyperthemia not induced by exposure to RF/MW radiation. Heating caused the intra-ocular
temperature of the eye to rise above normal. The retrolental temperature was reported to be
about 421C during the test period. Hyperthermia was sustained for approximately 30
minutes. Despite heating conditions that were similar to exposure from RF/MW radiation,
lens opacities did not occur in the rabbit eyes [301. Similar results have been reported by
other researchers [30]. These results indicate that hyperthermia alone may not be sufficient
to cause the formation of cataracts. Direct exposure to RF/MW radiation may be necessary
to induce opacities in the lens (30].
Mii. Cawrwcun Hwunra
Exposure to RF/MW radiation is known to cause cataracts in the human eye. Several
cases have been documented that report RF/MW induced cataracts in humans. Typically,
lens opacities have resulted from exposure levels that are greater than specified by the
various safety standards. However, minimum exposure levels sufficient to cause ocular
damage are not certain [301.
In 1970, Zaret, Kaplan and Kay (reference found in [30]) reported a large number of
cataracts induced in humans as result of occupational exposure. This report cited 42 cases of
chronic exposure to RF/MW radiation. They reported that workers suffered damage to the
posterior lens capsule. In one case, exposure periods lasted about 50 hours/week for 4
years. During most of the 4 year period the incident average power density level was
approximately 10 mW/cmI2 .For one 6 month period, however, power density levels may
have reached I W/crn [30].
In 1966, S. Cleary and B. Pasternack (refeence found in (30]) published the results
of an epidemiological study of military and industrial microwave workirs. It was reported
that minor alterations had occurred in the ocular lenses of the workers as a possible result of
chronic IF/MW radiation exposure. Defects were found in the posterior pole of the lens.
Cleary and Pasternack noted that the number of minor ocular defects was related to the
specific occupational duties of the workers. The greatest number of defects was found
12
among persons working in research and development jobs. The results of the study were
based on a comparison of the microwave workers with a similar control group. The
researchers concluded that exposure to RF/MW radiation had caused the lens of the eye to
age fwr than normal (30].
Similar cases of RF/MW radiation induced ocular damage have been reported by
other researchers. In one case, a 22 year old microwave technician was exposed 5 times
over a I month period to a 3 GHz radiation source. The incident power density level was
about 300 mWlcm2 and irradiation lasted approximately 3 minutes during each exposure
time. It was reported that the technician had developed bilateral cataracts as a result of
irradiation [30]. In another case, M. Zaret (reference found in [30]) reported that a 50 year
old woman had developed cataracts after intermittent exposure to a 2.45 GHz microwave
oven. The incident power density levels were about 1 mW/cm2 during operation of the oven
and as high as 90 mW/cnm when the oven door was opened [30].
K. Auadtory Effect
Individuals exposed to pulsed RF/MW radiation have reported hearing a chirping,
clicking or buzzing sound emanating from inside or behind the head. The auditory response
has been observed only for pulsed modulated radiation emitted as a square-wave pulse train.
The pulse width and pulse repetition rate are factors that appear to determine the type of
sound perceived [1], [31].
James Lin [31] reports that the sensation of hearing in humans occurs when the head
is irradiated at an average incident power density level of about 0.1 mW/cm2 and a peak
intensity near 300 mW/cm2 .Auditory responses have been observed for a frequency range
of 200-3000 MIHz and for pulse widths from 1-100 us [32].
MI. RF/MW ENERGY DEPOSITION
The absorption of RF/MW radiated energy
causes biological reactions to occur in living organisms. In order to understand the potential
effects of RF/MW radiation, it is important to quantify the absorption characteristics of
biological materials. Researchers have identified several principal factors that govern the
absorption of RF/MW energy by the human body. Experimental results have indicated that
clothing thickness, physical dimensions, degree of hydration, and the resonance frequency of
the human body are important parameters that determine the amount of energy absorbed by
the body [1], [8], [9], [16], [22].
A. Specfc Abwrption Rate (SAR)
The specific absorption rate (SAR) is a measure of the dose of RF/MW energy
abobdI by biological materials. It is intended to give a quantitative understanding to the
absotpon of energy. The SAR is defined as the amount of energy that is imparted to the
body as a function of body mass [4]. SAR's are usually expressed in terms of watts of
incident power per kilograms of irradiated body mass (W/Kg) [4], [9].
13
B. Deh of Erty Penenrdon
It is known that RF/MW radiated energy will be absorbed by the tissue of the human
body. The depth of energy penration into he tissue depends primarily on the wavelength
of the incident radiation and the water content of the tissue [3], [6].
Energy emitted in the millimeter-wave band is not likely to penetrate to more tha
about I or 2 mm into the tissue [6]. Essentially, PF/MW energy radiated at wavelengths
less than 3 centimeters will be captured in the outer skinsurface. RF/MW wavelengths from
3 to 10 centimeters will penetrate to a depth of about I to 10 mm. The greatest depth of
penetratin into the body will occur at wavelengths between 25 to 200 centimeters. At these
wavelengths RF/MW radiated energy can directly effect internal body organs and cause
erious injury. The human body is reported to be transparent to RF/MW radiated energy
emitted at wavelengths greater than 200 centimeters. Also, at frequencies above 300 M&z it
has been obsrved that the depth of energy penetration fluctuates rapidly with changes in
frequency. In genral, the depth of energy penetration into the body will decline as the
frequency of the incident radiation increases. At 10 GHz, the absorption of RF/MW energy
will be similar to IR radiation [3]. These figures were published by the U. S. Department
of Health, Educatin and Welfare [3].
The water content of the human tissue will also influence the depth of energy
penetration into the body. Millimeter-wave radiation is reported by Ghandi and Riazi [6] to
penetrate less than 2 am into the body because of the "Debye relaxation of the water
molecules" in the tissue [6]. The Debye Effect was observed by a Dutch physicist named
Peter Debye [23]. He dicovered that EM waves are absorbed by a dielectric because of
molecular dipoles present in the dielectric material [241. Water molecules are essentially
dipoles constructed from atoms of hydrogen and oxygen. Biological materials such as skin
ae dielectrics that consist mostly of water. Hence, thes dielectrics are rich in molecular
dipoles and are able to quickly absorb millimeter-wave radiation. Nigh frequency radiatiomemison are not expected to penetrate deeply into the human body [6].
C. OwAc Of eomeny
The orientation of the human body with respect to the incident EM field will
determine the amount of RF/MW energy that is absorbed by the tissue. Experimental results
published by Om Gandhi in 1980 indicate that the condition for maximum absorption occurs
when the electric field is parallel to the major axis of the body and the direction of the field
popegation is from arm to arm. Figure 2 shows the amount of energy absorbed versus the
radiating frequency for various EM field orientations [22].
D. 4Ft of the esmonnce Frequency
Researchers have reported that the human body will absorb the greatest amount of
RF/MW energy from sources radiating at the whole-body resonance frequency [1], [91, [22],
[25], [27]. The ANSI Standard [9] reports that the human body will absorb 7 times more
energy fron radiation emitted at the resonance frequency than at a frequency of 2450 MHz
[9]. Experiments conducted on fabricated human models have been used to determine the
x esvn frequency of the human body [221. Partial-body resonances have also been
14
observed by researchers. Computer simulation techniques have been used to estimate the
resomos frequency of the human head [261.
The free space whole-body resonance frequency is reported to be between 61.8-77
MHz for a Standard Model of Man [91, [22], (25]. The standard model depicts an average
mu standing 175 cm tall [9]. Experimental results tend to differ somewhat from numerical
calculations The ANSI Standard (9] reports the whole-body resonance frequency to be 70
MmZ [9]. Similarly, eprmental results presented by Hagman, Gandhi, and Durney [25]
indicate the resonance frequency to be between 68-71 MHz. However, calclations put forth
by the sm researches place the whole-body resonance at 77 MHz (25]. In 1980, Om
Gandhi reported that the maximum absorption of energy will occur at frequencies where the
free space wavelength (;0 of the incident radiation is about 2.50-2.77 times greater than the
major length (L) of the body (i.e. 9> 23.50L-2.77L). This formula puts the value of the
resMo t frequency between 61.8-68.5 MHz for a standard model of man. When the human
body is in contact with the electrical ground, the whole-body resonance frequency is reduced
to about 47 MHz (22]. Figure 3 shows the SAR versus the incident EM field frequency for
conditions of free space and grounding [22].
Numerical calculations have been presented by Hagman, Gandhi, D'Andrea, and
httej (261 that indicate the free space resonance frequency of the human head to be
about 375 MHz [26]. In a separate report, Gandhi determined that the head resonance will
occur when the free space wavelength of the incident radiation is about 4 times the diameter
of the head [22]. The condition for maximum energy absorption occurs when the direction
of the EM field propagation is parallel to the long axis of the body. This orientation differs
from the condition determined for RF/MW energy absorption by the whole-body. Figures 4
and 5 show the absorption of energy versus frequency for different EM field orientations
f26].
R FibctOf Clothng
Clothing can act as an impedance matching transformer for RF/MW radiation. In
1986, Gandhi and Riazi [6] reported that the coupling efficiency of clothing may be as high
as 90-95 percent for incident radiation in the millimeter-wave band. They determined that
the thickness of the clothing and frequency of the incident radiation are important factors in
the coupling condition. Figure 6 shows the relationship between clothing thickness and
coupling efficiency as a function of frequency. The authors note that wet or damp clothing
may actually reduce the amount of energy absorbed by the body because of the Debye
relaxation of the water molecules [6].
IV. RF/MW RADIATION EXPOSURE
STANDARDS
Exposure of living organisms to RF/MW radiation can have a potentially dangerous
biological effect. To ensure the public safety and to safeguard the workplace against
unneceuy IRF/MW radiation exposure, protective guidelines have been adopted by the
United States and several other nations. The maximum safe exposure levels recognized by
individual examining authorities tends to vary as a result of differing interpretations of the
15
available ItF/MW exposure data. There is a large distinction between permissible exposure
evels observed in the United States and the Soviet Union. East Block countries have set
mree stringent standards than nations in the West [3], (8], (11], [22].
A. ANS Stardwv C95.1-1982
In response to the need for a national RF/MW radiation protection guide, the
American Standards Association commissioned the Deparment of the Navy and The Institute
of Mectrical and Electronics Engineers to cooperate in formulating an acceptable standard for
sah radiation expsure levels. In 1960, the Radiation Hazards Standards Project was
established to coordinate the efforts of researchers. Since then, work has progressed and in
1982 a moden RF/MW radiation protection guide was established. The American National
Stadards Institute (ANSI) designated this guide as C95.1-1982 [9]. Presently, a new ANSI
guide is due for publication in May 1993. The new guide is entitled "ANSI/IEEE C95.1-
1992-. This guide will supersede C95.1-1982 when it is publishtd.
E. Reconmmendons
The ANSI C95. 1-1982 Standard specifies the maximum recommended RF/MW
raliatim exposure levels over a frequency range of 300 KHz to 100 GHz. Typically, the
standard calls for an exposure of no more than 5 mWIcm? for frequencies between 1500
MElz to 100,000 MIz. The reader should consult with the actual ANSI publication for the
detailed n --- Io. In addition, the standard limits the whole-body SAR to 0.4 W/Kg
and indicates that the qptial peak SAR should not exceed 8.0 W/Kg over any one gram of
Usmae For both CW and pulsed EM fields the exposure time should not exceed 6 minutes at
the meomended levels. 7hes maximum safe levels are not intended to apply to the
medical treatment of patients where irradiation is sometimes useful in combating diseases
lik cima'. The standard does pertain to the general public and to persons that work in
eletomgnMspetic environments. There are two exceptions to the recommendation: 1) at
frequencies between 100 KHz and 1 GHz the maximum exposure levels may be exceeded as
long as the stated SAR values are not violated and 2) at frequencies between 300 KHz and 1
GHz the exposure levels may be exceeded if the output power of the radiating device is less
than 7 W [9].
Ui. PflWOWphy
An explanation of the recommended maximum exposure levels is given as part of the
prolectiorguide. The ANSI Standard is intended to afford the best possible protection of
human life against RF/MW radiation exposure. The biological effect on the human body for
all ,F/MW frequencies and modulation schemes is not known, therefore, investigators
sought to interpret the available data in a way that would allow for the construction of the
best possible RF/MW radiation protection guide. Investigators emphasized studies that
tupoled harmful or potentially serious biological effects. Unlike past standards, researchers
agreed that the modern protection guide would also account for the nonthermal effects of
IF/MW rdiation [9].
16
The safe exposure levels expressed by the ANSI guideline were determined for far
field cexp e. The plane wave model used to specify the maximum exposure levels may
not be accurate to describe conditions in the near field. However, the power density levels
Sexprsd in the protection guide are not considered great enough to induce EM fields with
sufficent energy intensities capable of exceeding the recommend SAR's (91.
In selecting a measure for the dose of RF/MW radiation, it was recognized that the
SAR does not encompass all of the important factors necessary to determine safe exposure
levels. The modulation frequency and peak power of the incident EM field should also be
considered. Some of the investigators warned that extra care should be taken by persons that
are subjected to pulsed EM fields or by fields that are modulated near the whole-body
reWonance frequency [91
In assessing the biological effects, it was found that behavior was the most sensitive
biological component to RF/MW irradiation. It was observed that behavioral effects were
reveysble for exposure to carrier frequencies between 600 MHz and 2450 MHz when whole-
body SAR's were limited to between 4 and 8 W/Kg. For these SAR's, power densities were
calculated or measured to range from 10 mW/cm 2 to 50 mW/cm 2.Behavioral effects were
cnidered to be among the most serious consequences of exposure to RF/MW radiation [9].
It was established that in order to ensure an acceptable margin of safety the whole-
body average SAR should not exceed 0.4 W/Kg. Most of the researchers concluded that this
was a necessary and reasonable standard. The exceptions cited in the recommendations were
justified on the basis of the total rate of energy absorption by the human body. The Standard
repMo that small radio transceivers are able to emit EM fields that exceed the prescribed
power density levels. Such devices, however, are not expected to compromise the prescribed
maximum SAR levels. In general, compliance with the ANSI RF/MW protection guide is
the best safeguard against harmful biological effects [9].
B. USAF PEL. (AFOSH Standard 161-9, 12
Febniary 1987)
Since the early investigations of the Tri-Service Commission, the United States Air
Force has recognized the need to establish an RF/MW protection standard. The USAF
permissible exposure level (PEL) is specified in AFOSH Standard 161-9 enacted 12 February
1987. This standard stipulates maximum safe RF/MW radiation exposure levels over a
frequency range of 10 KHz to 300 GHz. The PELs are shown in Figures 7 and 8 [10].
In general, the USAF protection guideline agrees with the ANSI Standard except that
a distinction is made between exposure to persons in restricted and unrestricted areas. No
explanation for this policy is given in the USAF Standard. The PEL for restricted areas
shows only a slight alteration from the ANSI recommendation. For a frequency range of
1500-300,000 M-z the USAF PEL is given as 10 mW/cm2 .The PEL put forth by the
USAF is intended to Protec personnel from harm by limiting the whole-body SAR to 0.4
W/IKg. Exposure periods at the maximum safe levels should be limited to 6 minutes. It is
also recommended that exposure in the near zone to RFIMW sources radiating at less than 30
MHz may require a separate evaluation to determine safe exposure levels of irradiation [10].
C. Canwda Westem Furope
17
Concern over safe RF/MW radiation exposure levels has sparked controversy and
sharp debate in many countries around the world. The ANSI Standard is currently
reognized by most countries of the Free World including Canada, the United Kingdom,
Sweden, France, and West Germany [8], [22].
D. Saviet Union & Entern Euopean Standards
The RF/MW radiation exposure standards prescribed in the Soviet Union and Eastern
Europe are more cosmervative than standards adopted by countries in the West [31, [8], [11].
In the Soviet Union, permissible exposure levels for whole-body irradiation are specified for
various time intervals. RF/MW radiation exposures may not exceed 0.01 mW/cm2 for 3
hours/day, 0.1 mW/cm 2 for 2 hours/day, and 1.0 mW/cm2 for 15-20 minutes provided that
safety goggles be worn [3]. Czechoslovakia has recommended a maximum exposure level of
0.025 mW/cm2 for an average working day [8].
Investigators in the Soviet Union and Eastern Europe have placed a great emphasis on
the nondtema effects of biological exposure to RF/MW radiation. They contend that
eetm agei interactions with the bioelectrical and biochemical functions of the body
constitute a more serious health risk than effects from thermal heating. Nonthermal
disruptions have been observed to occur at power density levels that are much lower than are
necessary to induce thermal effects. Soviet researchers have attributed alterations in the
central nervous system and the cardiovascular system to the nonthermal effect of low level
.F/MW radiation exposure [3], [8].
The U. S. Department of Health, Education and Welfare [3] reports that the differing
standards put forth by the East and West may be attributed to philosophical differences in
basic research. Soviet investigators were intent on examining the effect of RF/MW radiation
on the conditioned reflex response of living organisms whereas their counterparts in the West
do not view this effect as an appropriate endpoint to research [3]. Recently, however,
researchers in the West have sought to account for nonthermal effects in modern permissible
RF/MW radiation exposure standards [9].
V. CONCLUSION
Exposure to RF/MW radiation is known to have a biological effect on living
organisms. Research conducted over the past 30 years has provided a basis for
ug the effect of irradiation of biological materials. Experimental evidence has
shown that exposure to low intensity radiation can have a profound effect on biological
.The nonthermal effects of RF/MW radiation exposure are becoming important
measures of biological interaction with EM fields. Modem RF/MW radiation protection
guides have sought to account for the effects of low level radiation exposure. Adherence to
the ANSI Standard [9] should provide protection against harmful thermal effects and help to
minimize the interaction of EM fields with the biological processes of the human body [9].
It is essentially the absorption of RF/MW energy that causes stress and trauma to
biolgical systems. The greatest amount of energy will be absorbed when the incident
radiation is emitted at the resonance frequency of biological material [9], [22]. In this
regard, RF/MW radiation emitted at nonresonant frequencies should be absorbed to the
18
off. s extent when the radiating mode is a pulsed signal. The generation of such signals
creates tranient responses that will match the resonant frequencies of biological materials.
N at pulsed RF/MW radiation may be more harmful to living organisms than CW
radiation emitted at nonresonant frequencies.
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[32] Glenn Coin, "Electricity and Cancer: Coincidence or Reality?", The Observer
Dispatch, pp 5B, Jan 24, 1993.
(33] Glenn Coin, 'An Invisible Intruder', The Observer Dispatch, pp IB & 5B, Jan
24, 1993.
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Mission. The mission of Rome Laboratory is to advance the science and
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appl teolloee;
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c. Provides a fu range of technical support to Air Force Materel
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d. Promes tranf s of technology to the private sector
e. Mantains Wading edge tecWho pertise in the areas of
surveflnce, communkatons, command and control, intelligence, reliability
science, egectr-magnetic technology, photonics, signal processing, and
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The thrust areas of technical competenc include: Survelance,
Communications, Command and Control, Intelligence, Signal Processing,
Computer Sience and Technology, Electrom Technology,
Photoracs and laiity Saences.
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5G Appeal
Scientist Appeal for 5G Moratorium 1
Scientists and doctors warn of potential serious health effects of 5G
September 13, 2017
We the undersigned, more than 180 scientists and doctors from 36 countries, recommend a moratorium
on the roll-out of the fifth generation, 5G, for telecommunication until potential hazards for human
health and the environment have been fully investigated by scientists independent from industry. 5G will
substantially increase exposure to radiofrequency electromagnetic fields (RF-EMF) on top of the 2G, 3G,
4G, Wi-Fi, etc. for telecommunications already in place. RF-EMF has been proven to be harmful for hu-
mans and the environment.
(Note: Blue links below are references.)
5G leads to massive increase of mandatory exposure to wireless radiation
5G technology is effective only over short distance. It is poorly transmitted through solid material.
Many new antennas will be required and full-scale implementation will result in antennas every 10 to 12
houses in urban areas, thus massively increasing mandatory exposure.
With ”the ever more extensive use of wireless technologies,” nobody can avoid to be exposed. Be-
cause on top of the increased number of 5G-transmitters (even within housing, shops and in hospitals)
according to estimates, ”10 to 20 billion connections” (to refrigerators, washing machines, surveillance
cameras, self-driving cars and buses, etc.) will be parts of the Internet of Things. All these together can
cause a substantial increase in the total, long term RF-EMF exposure to all EU citizens.
Harmful effects of RF-EMF exposure are already proven
Over 230 scientists from more than 40 countries have expressed their “serious concerns” regarding
the ubiquitous and increasing exposure to EMF generated by electric and wireless devices already before
the additional 5G roll-out. They refer to the fact that ”numerous recent scientific publications have shown
that EMF affects living organisms at levels well below most international and national guidelines”. Effects
include increased cancer risk, cellular stress, increase in harmful free radicals, genetic damages, structural
and functional changes of the reproductive system, learning and memory deficits, neurological disorders,
and negative impacts on general well-being in humans. Damage goes well beyond the human race, as there
is growing evidence of harmful effects to both plants and animals.
After the scientists’ appeal was written in 2015 additional research has convincingly confirmed se-
rious health risks from RF-EMF fields from wireless technology. The world’s largest study (25 million US
dollar) National Toxicology Program (NTP), shows statistically significant increase in the incidence of brain
and heart cancer in animals exposed to EMF below the ICNIRP (International Commission on Non-Ionizing
Radiation Protection) guidelines followed by most countries. These results support results in human epide-
miological studies on RF radiation and brain tumour risk. A large number of peer-reviewed scientific re-
ports demonstrate harm to human health from EMFs.
The International Agency for Research on Cancer (IARC), the cancer agency of the World Health Or-
ganization (WHO), in 2011 concluded that EMFs of frequencies 30 KHz – 300 GHz are possibly carcinogenic
to humans (Group 2B). However, new studies like the NTP study mentioned above and several epidemio-
logical investigations including the latest studies on mobile phone use and brain cancer risks confirm that
RF-EMF radiation is carcinogenic to humans.
5G Appeal
Scientist Appeal for 5G Moratorium 2
The EUROPA EM-EMF Guideline 2016 states that ”there is strong evidence that long-term exposure
to certain EMFs is a risk factor for diseases such as certain cancers, Alzheimer's disease, and male infertili-
ty…Common EHS (electromagnetic hypersensitivity) symptoms include headaches, concentration difficul-
ties, sleep problems, depression, lack of energy, fatigue, and flu-like symptoms.”
An increasing part of the European population is affected by ill health symptoms that have for
many years been linked to exposure to EMF and wireless radiation in the scientific literature. The
International Scientific Declaration on EHS & multiple chemical sensitivity (MCS), Brussels 2015, declares
that: "In view of our present scientific knowledge, we thereby stress all national and international bod-
ies and institutions...to recognize EHS and MCS as true medical conditions which acting as sentinel diseases
may create a major public health concern in years to come worldwide i.e. in all the countries implementing
unrestricted use of electromagnetic field-based wireless technologies and marketed chemical substances…
Inaction is a cost to society and is not an option anymore… we unanimously acknowledge this serious haz-
ard to public health…that major primary prevention measures are adopted and prioritized, to face this
worldwide pan-epidemic in perspective."
Precautions
The Precautionary Principle (UNESCO) was adopted by EU 2005: ”When human activities may lead
to morally unacceptable harm that is scientifically plausible but uncertain, actions shall be taken to avoid or
diminish that harm.”
Resolution 1815 (Council of Europe, 2011): ”Take all reasonable measures to reduce exposure to
electromagnetic fields, especially to radio frequencies from mobile phones, and particularly the exposure to
children and young people who seem to be most at risk from head tumours…Assembly strongly recom-
mends that the ALARA (as low as reasonably achievable) principle is applied, covering both the so-called
thermal effects and the athermic [non-thermal] or biological effects of electromagnetic emissions or radia-
tion” and to ”improve risk-assessment standards and quality”.
The Nuremberg code (1949) applies to all experiments on humans, thus including the roll-out of 5G
with new, higher RF-EMF exposure. All such experiments: ”should be based on previous knowledge (e.g., an
expectation derived from animal experiments) that justifies the experiment. No experiment should be con-
ducted, where there is an a priori reason to believe that death or disabling injury will occur; except, per-
haps, in those experiments where the experimental physicians also serve as subjects.” (Nuremberg code
pts 3-5). Already published scientific studies show that there is ”a priori reason to believe” in real health
hazards.
The European Environment Agency (EEA) is warning for ”Radiation risk from everyday devices" in
spite of the radiation being below the WHO/ICNIRP standards. EEA also concludes: ”There are many exam-
ples of the failure to use the precautionary principle in the past, which have resulted in serious and often
irreversible damage to health and environments…harmful exposures can be widespread before there is
both 'convincing' evidence of harm from long-term exposures, and biological understanding [mechanism]
of how that harm is caused.”
“Safety guidelines” protect industry — not health
The current ICNIRP ”safety guidelines” are obsolete. All proofs of harm mentioned above arise alt-
hough the radiation is below the ICNIRP "safety guidelines". Therefore new safety standards are necessary.
The reason for the misleading guidelines is that “conflict of interest of ICNIRP members due to their rela-
tionships with telecommunications or electric companies undermine the impartiality that should govern the
5G Appeal
Scientist Appeal for 5G Moratorium 3
regulation of Public Exposure Standards for non-ionizing radiation…To evaluate cancer risks it is necessary
to include scientists with competence in medicine, especially oncology.”
The current ICNIRP/WHO guidelines for EMF are based on the obsolete hypothesis that ”The critical
effect of RF-EMF exposure relevant to human health and safety is heating of exposed tissue.” However,
scientists have proven that many different kinds of illnesses and harms are caused without heating (”non-
thermal effect”) at radiation levels well below ICNIRP guidelines.
We urge EU:
1) To take all reasonable measures to halt the 5G RF-EMF expansion until independent scientists
can assure that 5G and the total radiation levels caused by RF-EMF (5G together with 2G, 3G, 4G,
and WiFi) will not be harmful for EU-citizens, especially infants, children and pregnant women, as
well as the environment.
2) To recommend that all EU countries, especially their radiation safety agencies, follow Resolution
1815 and inform citizens, including, teachers and physicians, about health risks from RF-EMF radia-
tion, how and why to avoid wireless communication, particularly in/near e.g., daycare centers,
schools, homes, workplaces, hospitals and elderly care.
3) To appoint immediately, without industry influence, an EU task force of independent, truly im-
partial EMF-and-health scientists with no conflicts of interest1 to re-evaluate the health risks and:
a) To decide about new, safe “maximum total exposure standards” for all wireless communication
within EU.
b) To study the total and cumulative exposure affecting EU-citizens.
c) To create rules that will be prescribed/enforced within the EU about how to avoid exposure ex-
ceeding new EU ”maximum total exposure standards” concerning all kinds of EMFs in order to pro-
tect citizens, especially infants, children and pregnant women.
4) To prevent the wireless/telecom industry through its lobbying organizations from persuading EU-
officials to make decisions about further propagation of RF radiation including 5G in Europe.
5) To favor and implement wired digital telecommunication instead of wireless.
We expect an answer from you no later than October 31, 2017 to the two first mentioned signatories about
what measures you will take to protect the EU-inhabitants against RF-EMF and especially 5G radiation. This
appeal and your response will be publicly available.
Respectfully submitted,
Rainer Nyberg, EdD, Professor Emeritus (Åbo Akademi), Vasa, Finland (NRNyberg@abo.fi)
Lennart Hardell, MD, PhD, Professor (assoc) Department of Oncology, Faculty of Medicine and Health, Uni-
versity Hospital, Örebro, Sweden (lennart.hardell@regionorebrolan.se)
1 Avoid similar mistakes as when the Commission (2008/721/EC) appointed industry supportive members for
SCENIHR, who submitted to EU a misleading SCENIHR report on health risks, giving telecom industry a clean bill to
irradiate EU-citizens. The report is now quoted by radiation safety agencies in EU.
5G Appeal
Scientist Appeal for 5G Moratorium 4
Signatories to Scientists’ 5G Appeal
Note: The endorsements are personal and not necessarily supported
by the affiliated universities or organizations.
EU and European Nations
AUSTRIA
Gerd Oberfeld, MD, Public Health Officer, Salzburg
BELGIUM
Marie-Claire Cammaerts, Dr, retired, Free University of Brussels, Bruxelles
BULGARIA
Marko Markov, Professor Emeritus, Ph.D. in biophysics, Sofia University, Research international
CYPRUS
Stella Canna Michaelidou, Dr, Chemist Expert on Environment, Health and Food Safety, President of the
Cyprus National Committee on Environment and Children's Health
FINLAND
Marjukka Hagström, LL.M, M.Soc.Sc., Senior researcher, The Finnish Electrosensitivity
Foundation, Turku
Osmo Hänninen, PhD, Professor Emeritus, Dept. of Physiology, Faculty of Medicine, University of
Eastern Finland; Editor-In-Chief, Pathophysiology, Kuopio
Georgiy Ostroumov, PhD (in the field of RF EMF), independent researcher
FRANCE
Marc Arazi, MD, Physician (Whistleblower on Phonegate international scandal), Nogent-sur-Marne
Dominique Belpomme, MD, MSc, Full Professor in Medical Oncology; Director of ECERI, Paris
University, Paris & European Cancer and Environment Research Institute, Brussels
Philippe Irigaray, PhD, Scientific Director, Association for Research on Treatment against Cancer
(ARTAC), Paris; European Cancer and Environment Research Institute (ECERI), Brussels
Vincent Lauer, Ing. ECP, Independent Researcher, La Chapelle sur Erdre
Annie J Sasco, MD, DrPH, Former Director of Research, French National Institute of Health
and Medical Research, Former Chief of Epidemiology for Cancer Prevention at the International
Agency for Research on Cancer and Former Acting Chief of Program for Cancer Control, World
Health Organization, Bordeaux
GERMANY
Franz Adlkofer, MD, Professor, Pandora-Foundation for Independent Research
Christine Aschermann, MD (retired) member of the Kompetenzinitiative e.V., Leutkirch
Mario Babilon, Dr. rer. nat., Professor, Baden-Wuerttemberg Cooperative State University Stuttgart
Wolf Bergmann, Dr. med., Kompetenzinitiative zum Schutz von Mensch, Umwelt und Demokratie
e.V., Freiburg
Rainer Frentzel-Beyme, MD, Professor emeritus, University of Bremen.
Helmut Breunig, Diploma degree in forestry, Specialty: Radio frequency injuries on trees around phone
masts, Osterode am Harz
Klaus Buchner, Dr. rer. nat., Professor, MEP – Member of the European Parliament,
Kompetenzinitiative zum Schutz von Mensch, Umwelt und Demokratie e.V., München
5G Appeal
Scientist Appeal for 5G Moratorium 5
Horst Eger, Dr. med., Ärztlicher Qualitätszirkel ”Elektromagnetische Felder in der Medizin -
Diagnostik, Therapie, Umwelt”, Naila
Karl Hecht, Dr, Professor of pathophysiology and neurophysiology (Emeritus of the Medical center
Charite), Berlin
Peter Hensinger, MA, diagnose:funk, consumer protection organisation, Stuttgart
Markus Kern, Dr. med., Kompetenzinitiative zum Schutz von Mensch, Umwelt und Demokratie
e.V., Kempten
Florian M. König, Dr.Sc. Man. Dir. & Science Header of the Company/Institute "Florian König
Enterprises GmbH”
Andrea Leute, Dr. med., Ärzteinitiative Mobilfunk Allgäu-Bodensee-Oberschwaben, Überlingen
Martin Lion, Dr. med., Allgemeinmedizin - Homöopathie, Ulm
Peter Ludwig, Dr. phil., Kompetenzinitiative zum Schutz von Mensch, Umwelt und Demokratie
e.V., Saarbrücken
Willi Mast, Dr., Arzt für Allgemeinmedizin und Innere Medizin, Gelsenkirchen
Joachim Mutter, Dr. med., Paracelsus Clinic / Switzerland, Kompetenzinitiative zum Schutz von
Mensch, Umwelt und Demokratie e.V., Murg
Gertraud Teuchert-Noodt, Dr., Professorin der Neurobiologie i.R., Universität Bielefeld
Peter Ohnsorge, Dr. med., European Academy for Environmental Medicine
Karl Richter, Dr. phil., Professor, Kompetenzinitiative zum Schutz von Mensch, Umwelt und
Demokratie e.V., St. Ingbert
Claus Scheingraber, Dr. med. dent., German Working Group Electro-Biology, Brunnthal,
Cornelia Waldmann-Selsam, Dr.med., Competence Initiative for the Protection of Humanity,
Environment and Democracy e.V., Bamberg
Werner Thiede, Dr. theol., Professor, Pfarrer der Evangelisch-Lutherischen Landeskirche in
Bayern und Publizist, Neuhausen
Helmut Wagner, Dr. med., Ophthalmologist, Stuttgart
Harald Walach, Professor, PhD in psychology, PhD in theory and history of science, Change Health Science
Institute, Berlin; affiliation: Witten-Herdecke University, Poznan Medical University, Poland
Ulrich Warnke, Dr.rer.nat., Academic Superior Council (retired) University of Saarland
Isabel Wilke, Diplom-Biologin, Editor ElektrosmogReport, Kassel/Berlin
Roland Wolff, Dipl.-Phys., Medical Physicist, Bremen
Ortwin Zais, PhD (Dr. med.), European Academy for Environmental Medicine
GREECE
Christos Georgiou, PhD, Member, Scientific Secretariat of ICEMS; Professor of Biochemistry, Biology De-
partment, University of Patras, Patras
Theodore P. Metsis, PhD, Electrical, Mechanical, Environmental Engineer, Consultant, Athens
ITALY
Domenico Agrusta, Medicine and surgery, specialist in dentistry (Odontostomatologia) self-
employed, Member of ISDE, Taranto
Fernanda Amicarelli, Full Professor in Applied Biology, Department of Life, Health and
Environmental Sciences, University of L’Aquila, L'Aquila
Fiorella Belpoggi, Dr., Director, Research Department, Ramazzini Institute, Bologna
Sergio Bernasconi, Full Professor of Pediatrics, former Director, Pediatric Department, Editor
emeritus: Italian Journal of Pediatrics, University of Parma
Dr Franco Berrino, MD, PhD, former Director, Department of Preventive and Predictive Medicine,
Istitutonazionale dei Tumori, Milan
Ernesto Burgio, MD, Pediatrician, ECERI – European Cancer and Environment Research Institute (Bruxelles)
Dr Franco Cherubini, Degree in medicine and surgery, Self-employed, Vetralla
Dott. Agostino Di Ciaula, President of Scientific Committee, Italian Society of Doctors for the
Environment - ISDE Italy, Arezzo
5G Appeal
Scientist Appeal for 5G Moratorium 6
Dott. Andrea Cormano, MD, Italian Society of Doctors for the Environment - ISDE, Benevento
Ugo Corrieri, Degree in medicine and surgery at Università Cattolica del S. Cuore, Teacher at
Scuola Romana di Psicoterapia Familiare, President of ISDE-Doctors for the Environment in Grosse-
to, Coordinator of ISDE-Doctors for the Environment for Central Italy, Grosseto- Rome
Dr Patrizia Difonte, Physician, Surgeon, General practitioner and occupational medicine,
Associazione Italiana Elettrosensibili, Lonate Pozzolo (Varese)
Anna Maria Falasconi, Medical Doctor, Primary Care Pediatrician, National Health System, Rome
Dott. Filippo Maria di Fava, Laurea in Medicina e Chirurgia, Libero professionista, Roma
Dr. Mario Frusi, MD, medico, Cuneo
Dr. Stefano Gallozzi, Astrophysician and technologist at the INAF Italian National Astrophysical Institute in
the Observatory, President of the Comitato di Tutela e Salvaguardia dell'Ambiente in Monte Porzio
Catone (ONLUS association), Rome
Dott. Roberto Gava, Pharmacologist and Toxicologist, ISDE, Padua
Teresa Pia Anna Maria Del Gaudio, Degree in Medicine and Surgery, specialist in pediatrics,
Medical Manager, ASL Salerno, Roccagloriosa (SA), Italy
Valerio Gennaro, MD, PhD, Head ,Liguria Mesothelioma Registry (COR Liguria), UO Clinical
Epidemiology (IST Nord - CBA); IRCCS Policlinico Ospedale San Martino National Cancer Research
Institute (IST), Genoa
Patrizia Gentilini, Degree in Medicine ( specialization in Oncology and Hematology). ISDE
(International Society Doctor’s for Environment), FORLI’
Livio Giuliani, PhD, Professor, Università dell'Abruzzo - Corso di Laurea in Fisiatria, Chieti
Angelo Levis, PhD. Professor, Biologist, University of Padua
Roberto Lucchini, MD, Professor of Occupational Medicine, University of Brescia
Salvatore Magazù,PhD, Full Professor of Experimental Physics, Dipartimento di Scienze
Matematiche e Informatiche, Scienze Fisiche e Scienze della Terra, Università di Messina
Fiorenzo Marinelli, PhD, Institute of Molecular Genetics (IGM), National Research Council (CNR), Member
of the International Commission for Electromagnetic Safety (ICEMS), Bologna,
Antonio Maria Pasciuto, Degree in Medicine and Surgery, Specialist in Internal Medicine,
President of ASSIMAS (Associazione Italiana Medicina Ambiente e Salute), Rome
Dott. Carlo Ratti, MD, Ordine dei Medici della SPEZIA, Genova
Ruggero Ridolfi, MD, Oncologist Endocrinologist, ISDE, Forlì-Cesena,
Dr. Med. Sandro Rinaldi, Laurea in medicina e chirurgia; specializzazione in Allergologia;
specializzazione in Ematologia. Medico di medicina generale convenzionato con l'Azienda
Sanitaria di Bolzano, Terlano (BZ)
Massimo Melelli Roia, MD, Italian Society of Doctors for the Environment - ISDE, Perugia
Dott. Roberto Romizi, President, Italian Society of Doctors for the Environment - ISDE, Arezzo
Dott.ssa Ida Santellocco, MD, Medico chirurgo, Pediatria, medico chirurgo - pediatra, Roma
Massimo Scalia, Coordinator of the Bioelectromagnetism Section of CIRPS (Interuniversity
Research Center for Sustainable Development)
Alessandro Solerio, Degree in Medicine and Surgery, Self-employed, homeopath, Sanremo
Franco Verzella, MD, physician, practice dedicated to autistic children, Bologna,
Myriam Zucca, Dr. ssa, Medical Director, Dermatology, Cagliari University Hospital, Sardinia
MALTA
Pierre Mallia, MD PhD CBiol MPhil MA(Law) DipICGP MMCFD MRCP FRCGP, Professor of Family
Medicine, Bioethics & Patients’ Rights; Chairperson National Health Ethics Committee,
Dept. of Health Coordinator Bioethics Research Programme, Univ. of Malta; President,
Malta College of Family Doctors
NETHERLANDS
Hugo Schooneveld, PhD, Retired Associate professor (Wageningen Agricultural University),
5G Appeal
Scientist Appeal for 5G Moratorium 7
Advisor to the Dutch EHS Foundation, former president of 'Stichting elektro-
hypersensitivity’, Wageningen
PORTUGAL
Paulo Vale, PhD, Auxiliary Researcher, Sea and Marine Resources Department, The Portuguese Sea and
Atmosphere Institute, Lisbon
SLOVAKIA
Igor Belyaev, PhD, Dr.Sc, Associate Professor, Cancer Research Institute, BMC SAS, Bratislava
Jan Jakus, MD, PhD, DSc., Professor, Jessenius Faculty of Medicine, Comenius University, Martin
Ladislav Janousek, PhD, Professor, Department of Electromagnetic and Biomedical Engineering
Faculty of Electrical Engineering, University of Zilina, Žilina
Michal Teplan, PhD, Institute of Measurement Science, Slovak academy of sciences, Bratislava
SPAIN
Alfonso Balmori, BSc, Master in Environmental Education, Biologist. Junta de Castilla y León,
Valladolid
José Luis Bardasano, PhD, Biologist and Physician, Prof. of Medical Bioelectomagnetism, Department of
Medicine and Medical Specialties, School of Medicine, University of Alcalá. Alcalá de Henares, Madrid
Pilar Muñoz-Calero, MD, President of the Fundación Alborada, Co-director of the Chair of
Pathology and Environment, Faculty of Medicine, Universidad Complutense de Madrid
(UCM), Madrid
Miguel Lopez-Lazaro, PhD, Associate Professor, Department of Pharmacology, Faculty of Pharmacy, Univer-
sity of Seville
María Elena López Martín, MD, PhD, Associate Professor of Human Anatomy, School of Medicine, Universi-
ty of Santiago de Compostela (USC)
Enrique A. Navarro, PhD, Professor, University of Valencia, Valencia
Claudio Gómez-Perretta, MD, PhD, Chief of Section, Hospital Universitario La Fe, Valencia
Ceferino Maestu Unturbe, Ph.D, Prof., Director of the Bioelectromagnetism Laboratory of the
Centre for Biomedical Technology (CTB), Polytechnic University of Madrid (UPM).
SWEDEN
Mikko Ahonen, PhD, researcher, Sundsvall
Michael Carlberg, MSc, Department of Oncology, Faculty of Medicine and Health, University
Hospital, Örebro
Mikael Eriksson, MD, PhD, Associate Professor, Department of Oncology, Skane University, Hospital, Lund
Lena Hedendahl, MD, Independent Environment and Health Research, Luleå
Olle Johansson, Associate Professor, Experimental Dermatology Unit, Department of Neuroscience,
Karolinska Institute, Stockholm
Gunilla Ladberg, PhD, Member of the Board of the Swedish association Vågbrytaren, Lidingö
Leif G. Salford, MD, PhD, Senior Professor of Neurosurgery, Director of the Rausing Laboratory for
Translational NeuroOncology, Lund University, Lund
Elsy-Britt Schildt, MD, PhD, Senior Consultant, Department of Oncology and Radiation, County Hospital,
Kalmar
Fredrik Söderqvist, PhD, Epidemiologist, Centre for Clinical Research, Uppsala University, Västerås
SWITZERLAND
Daniel Favre, Dr. phil., Biologist, Independent Researcher, Brent
Peter Meier, Dr.Med., Facharzt für Innere Medizin FMH, M.Sc. Präventivmedizin, Mitglied der European
Academy for Environmental Medicine, Sissach
5G Appeal
Scientist Appeal for 5G Moratorium 8
UK
Erica Mallery-Blythe, MD, BMBS, Founder of PHIRE (Physicians' Health Initiative for Radiation and
Environment) Trustee Radiation Research Trust, Medical Advisor ORSAA (Oceana
Radiofrequency Advisory Association), Medical Advisor ES-UK, Soton
David Gee, Visiting Fellow, Institute of Environment, Health and Societies, Brunel University,
London
Andrew Goldsworthy, BSc, PhD, Lecturer in Biology (retired), Imperial College London, Monmouth
Isaac Jamieson, PhD, DIC, RIBA, Dip AAS, BSc(Hons) Arch., Biosustainable Design, Aberdeen, UK. Interna-
tional Expert, Thammasat University, Pathumthani, Thailand.
Alasdair Philips, BSc, DAgE, Professional engineer, Powerwatch
Syed Ghulam Sarwar Shah, MBBS, MA, MSc, PhD , Post-Doctoral Research Fellow, Department of Occupa-
tional Health, Guy’s and St. Thomas’ NHS Trust; Honorary Research Fellow, Department of Clinical
Sciences, Brunel University, London
Sarah Starkey, PhD, Independent Neuroscience and Environmental Health Research
Andrew Tresidder, MD, MBBS, MRCGP, Somerset GP
Other Nations
ARMENIA
Sinerik Ayrapetyan, PhD, Professor, Life Sciences International Postgraduate Educational Center, UNESCO
Chair in Life Sciences, Yerevan, Head of Research Council and Chairholder of UNESCO Chair
AUSTRALIA
Priyanka Bandara, PhD, Environmental Health Consultant, Castle Hill/Sydney, NSW
Katherine Georgouras, OAM, DDM, FACD, Professor of Dermatology, (semiretired) ,Kenthurst NSW
Ray Kearney OAM, PhD, Honorary Assoc. Professor (retired), Department of Medicine, University of Sydney
Don Maisch, PhD, Independent researcher, author of ”The Procrustean Approach”, Lindisfarne,
Tasmania
May Murray, PhD, Independent Environmental Health researcher, Canberra
Elena Pirogova, PhD, Associate Professor, Biomed Eng, BEng (Hons) Chem En, Discipline of Electrical and
Biomedical Engineering, School of Engineering, RMIT University
Charles Teo, AM, MBBS, Professor, Neurosurgeon, Prince of Wales Private Hospital, Randwick, NSW, Syd-
ney
Steve Weller, BSc, Founding member of ORSSA, Brisbane
BRAZIL
Orlando Furtado Vieira Filho, PhD, Professor, Cellular & Molecular Biology, Federal University of Rio
Grande do Sul
Claudio Enrique Fernández-Rodríguez, PhD, MSEE, Professor, Federal Institute of Rio Grande do Sul, IFRS,
Canoas
Alvaro Augusto A. de Salles, PhD, Full Professor, Federal University of Rio Grande do Sul, UFRGS, Porto
Alegre
Francisco de Assis Ferreira Tejo (retired) D.Sc., Professor, Grupo de Eletromagnetismo Computacional e
Bioeletromagnetismo, Electrical Engineering Dept, Universidade Federal de Campina Grande
CANADA
Frank Clegg, CEO, Canadians for Safe Technology (C4ST); Former President of Microsoft Canada
Paul Héroux, PhD, Occupational Health Program Director, Department of Epidemiology, Biostatis-
tics and Occupational Health, McGill University Medicine, Montreal, PQ
Anthony B. Miller, MD, FRCP, Professor Emeritus, Dalla Lana School of Public Health, University of Toronto,
5G Appeal
Scientist Appeal for 5G Moratorium 9
Malcolm Paterson, PhD, Director, Research Initiatives, BC Cancer Agency Sindi Ahluwalia
Hawkins Centre for the Southern Interior, Kelowna, BC
Michael A. Persinger, PhD, Professor, Biomolecular Sciences, Behavioural Neuroscience and Human Studies,
Laurentian University, Sudbury, Ontario
Magda Havas, Associate Professor, Trent University, Canada
CHINA
Wenjun Sun, PhD, Professor, Bioelectromagnetics Key Laboratory, Zhejiang University, School of Medicine,
Hangzhou
Minglian Wang, M.M. , PhD, Associate Professor, College of Life Science & Bioengineering, Beijing Universi-
ty of Technology (BJUT), Beijing
COLOMBIA
Carlos Sosa, MD, University of Antioquia, Medellín
EGYPT
Nasr Radwan, Prof. Dr., Cairo University, Faculty of Science, Cairo
INDIA
Ganesh Chandra Jagetia, Professor, Just retired from Department of Zoology, Mizoram University,
Aizawl, Udaipur
Sareesh Naduvil Narayanan, PhD, Assistant Professor, Department of Physiology, RAK College of Medical
Sciences, RAK Medical & Health Sciences University, Ras Al Khaimah, UAE
R. S. Sharma, PhD, Head, Scientist - G & Sr. DDG, Div. of Reproductive Biology, Maternal & Child Health
and Chief Project Coordinator - EMF Health Project India, Indian Council of Medical Research, Ansa-
ri Nagar, New Delhi
IRAN
Amirnader Emami Razavi, PhD, Executive Manager and Principal Investigator of Iran, National Tumor Bank,
Cancer Institute of Iran, Tehran University of Medical Sciences
Dr. Masood Sepehrimanesh, PhD, Assistant Professor, Gastrointestinal and Liver Disease Research Center,
Guilan Universtiy of Medical Sciences, Rasht
ISRAEL
Iris Atzmon, MPH, Epidemiology, University of Haifa, Author of ”The Cellular, not what you
thought!", Haifa
Michael Peleg, M.Sc., Radio Communications Engineer and Researcher, Technion, Israel Institute of Tech-
nology, Haifa
Elihu D Richter, MD MPH, Professor, Occupational and Environmental Medicine, Hebrew
University-Hadassah School of Public Health and Community Medicine, Jerusalem
Yael Stein, MD, Hebrew University - Hadassah Medical Center, Jerusalem
Danny Wolf, MD, Pediatrician, Clialit Health Services Raziel, Netanya Herzelia
JAPAN
Hidetake Miyata, PhD, Associate professor, Department of Physics. Tohoku University
JORDAN
Mohammed Saleh Al Salameh, PhD, Professor, Department of Electrical Engineering, University of Science
& Technology, Irbid
KOREA (South)
Kiwon Song, PhD, Professor, Department of Biochemistry, Yonsei University, Seoul
5G Appeal
Scientist Appeal for 5G Moratorium 10
Young Hwan Ahn, MD PhD, Professor, Department of Neurosurgery, Ajou Univeristy School of
Medicine, Suwon
NEW ZEALAND
Damian Wojcik, MD, MBChB, Medical director/ Northland Environmental health Clinic, Whangare,
Northland
NIGERIA
Aneyo Idowu Ayisat, M.Sc., Lecturer, Environmental Biology Unit, Biological Science Department,
Yaba College of Technology, Yaba, Lagos
OMAN
Dr Najam Siddiqi, MBBS, PhD, Associate Professor of Anatomy, Oman Medical College, Sohar
RUSSIAN FEDERATION
Yury Grigoriev, Professor, M. Dr Sci., Federal. Medical Biophysical Center, Moscow
Maxim V. Trushin, PhD, Associate Professor, Kazan Federal University, Kazan
TURKEY
Osman Cerezci, Professor Dr., Dept. Electrical-Electronics Engineering, Sakarya University, Adapazarı
Suleyman Dasdag, PhD, Prof. Dr., Biophysics Department, Medical School, Istanbul Medeniyet University,
Uskudar, Istanbul
Onur Elmas, MD, PhD, Faculty of Medicine, Dept. Of Physiology, Mugla Sitki Kocman
University, Mugla
Ayse Inhan Garip, Assoc. Prof., School of Medicine, Biophysics Dept., Marmara Univ., Istanbul
Suleyman Kaplan, PhD, Professor, President of Turkish Society for Stereology, Board member of Journal
Chemical Neuroanatomy (Elsevier), Board member of Journal of Microscopy and Ultrastructure
(Elsevier), Department of Histology and Embryology, Ondokuz Mayıs University, Samsun
Fulya Kunter, Assistant Professor Dr., Dept. Electrical-Electronics Engineering, Marmara University, Istanbul
Selim Şeker, Professor Dr., Department of Electrical-Electronics Engineering, Bogazici University
Nesrin Seyhan, Prof. Dr., Gazi University Medical Faculty, Founder Head, Biophysics Department;
Founding Director, Gazi Non-Ionizing Radiation Protection Centre (GNRK), Ankara
UKRAINE
Olexandr Tsybulin, PhD, Department of Biophysics, Bila Tserkva National Agrarian University
Igor Yakymenko, Prof. Dr, Department of Biochemistry and Environmental Control
National University of Food Technologies, Kyiv
USA
David O. Carpenter, MD, Director, Institute for Health and the Environment, A Collaborating
Centre of the World Health Organization, University at Albany, Rensselaer, NY
Barry Castleman, ScD, Environmental Consultant, Garrett Park, MD
Devra Davis, PhD, MPH, Visiting Prof. Medicine, Hebrew University, Hadassah Medical Center & Ondokuz
Mayis University, Medical School (Turkey); Pres., Environmental Health Trust, Teton Village, WY
Paul Doyon, MA, MAT, EMRS, Independent Researcher, Doyon Independent Research, CA
Arthur Firstenberg, B.A., EMF researcher and author, president Cellular Phone Task Force,
New York
Beatrice A. Golomb, MD, PhD, Professor of Medicine, University of California, San Diego, CA
Peter F. Infante, DrPH, Managing Member, Peter F. Infante Consulting, LLC, VA
Toril H. Jelter, MD, MDI Wellness Center, CA
5G Appeal
Scientist Appeal for 5G Moratorium 11
Elizabeth Kelley, MA, Electromagnetic Safety Alliance, Tucson, AZ
Henry Lai, PhD, Professor Emeritus, University of Washington, Seattle, WA
B. Blake Levitt, medical/science journalist, former New York Times contributor, EMF researcher and author
Trevor G Marshall, ME, PhD, Director, Autoimmunity Research Foundation, CA
Ronald Melnick, PhD, Senior Toxicologist, (Retired RF-section leader) US National Toxicology Program,
National Institute of Environmental Health Sciences
L. Lloyd Morgan, Senior Research Fellow, Environmental Health Trust, Board Member,
International EMF Alliance (IEMFA), CA
S. M. J. Mortazavi, PhD, Professor of Medical Physics, Visiting Scientist, Fox Chase Cancer
Center, Philadelphia, PA
Joel M. Moskowitz, PhD, Director, Center for Family and Community Health, School of Public Health, Uni-
versity of California, Berkeley, CA
Martin Pall, BA, PhD, Professor Emeritus (Biochemistry and basic medicine), Pullman, WA
Jerry L. Phillips, PhD, Exec. Director, Excel Centers, Professor Attendant, Department of Chemistry & Bio-
chemistry, University of Colorado, Colorado Springs, CO
Camilla R. G. Rees, MBA, Health Researcher, Author ,"The Wireless Elephant in the Room”’ CEO, Wide An-
gle Health, Sr. Policy Advisor, National Institute for Science, Law & Public Policy, NY
Cindy Sage, MA, Sage Associates, Co-Editor, BioInitiative Reports, Santa Barbara, CA
Eugene Sobel, PhD, Professor (Retired), University of Southern California School of Medicine, CA
John G. West, MD, Director of Surgery, Breastlink, CA
4G/5G Wireless & “Small” Antennas Fact Sheet
Health Effects
There already exists an extensive body of scientific studies showing that microwave radiation
causes harm.1 All wireless devices communicate via pulsations. Pulsed electro-magnetic fields
(EMFs) are much more biologically active than non-pulsed. In order to transmit vast amounts of
information, 5G will be extremely highly pulsed, far more than 2G, 3G and 4G, leading to harm to
all living organisms.2 5G implementation will be in addition to the current use of 3G and 4G,
creating an exponential increase in radiation exposure than we now have. Like most medical
studies done to test drugs or evaluate chemicals and pesticides, the studies below were performed
using rodents or other mammals. Mammal cell physiology is directly applicable to humans.3
• 2008-2018 Landmark $30 Million 10-year study conducted by the US. National Toxicology
Program (NTP) of the NIH finds “Clear Evidence of Cancer” and DNA damage in rats and mice
exposed to 2 and 3G radiation. This was based on evidence of malignant gliomas in the brain
and malignant schwannomas of the heart. The study also showed benign adrenal gland
tumors, degeneration of heart tissue, decreased birth weights of rats exposed prenatally,
and DNA damage. This study was designed to determine whether radio-frequency radiation
from cell phones and other wireless devices could cause cancer. Published November, 2018.4
• The Italian Ramazzini Institute Study found that lab animals exposed to the radio-frequency
radiation emitted by distant cell towers had a greater chance of developing heart and brain
tumors than those which were not exposed,. This study funded in part by the U.S. Government
was the first large –scale study to show “clear evidence” of cancer risk from far-field
exposures. Published in 2018.5
• More than 240 scientists who have published peer-reviewed research on the biological and health
effects of non-ionizing EMFs “have shown that EMF affects living organisms at levels well
below most international and national guidelines. Effects include increased cancer risk,
cellular stress, increase in harmful free radicals, genetic damages, structural and functional
changes of the reproductive system, learning and memory deficits, neurological disorders,
and negative impacts on general well-being in humans…there is (also) growing evidence of
harmful effects to both plant and animal life.”6
• According to Dr. Cindy Russell, creator of the website, “Physicians for Safe Technology,”
“Scientific literature documents evidence of non-thermal cellular damage from wireless radiation
used in telecommunications to DNA integrity, cellular membranes, gene expression, protein
synthesis, neuronal function, the blood brain barrier, melatonin production, sperm damage
and immune dysfunction.”6
• Joel M. Moskowitz, Ph.D., Director of the Center for Family and Community Health in the
School of Public Health at the University of California, Berkeley writes that while the FCC
adopted radiofrequency radiation (RFR) exposure limits based largely on research from the
1980’s focused on short-term heating risks due to RFR exposure, the preponderance of peer-
reviewed research, more than 500 studies, have found harmful biologic or health effects
from exposure to RFR at intensities too low to cause significant heating.”7
• In addition, “The FCC’s RFR exposure limits regulate the intensity of exposure, taking into
account the frequency of the carrier waves but ignoring the signaling properties of the RFR.
Along with the patterning and duration of exposures, certain characteristics of the signal
(e.g., pulsing, polarization) increase the biologic and health impacts of the exposure.”7
v1.04 2020-03-16 mocoSafeG.org
4G/5G Wireless & “Small” Antennas Fact Sheet
Health Effects
• According to biochemist Dr. Martin Pall, the highly pulsed millimeter waves of 5G are
much more dangerous than the less-pulsed electro-magnetic fields that we are used to.
Many of the harmful effects are due to increased intracellular calcium throughout our
bodies, and when combined with the effects of highly pulsed millimeter waves, the results
are super-additive, potentially leading to very serious health problems.8
• Instances of sickness from 5G activation or close proximity to cell phone towers, 5G
towers :
1) Firefighters experienced changes in brain structure and function resulting in delayed
reaction time, lack of impulse control, difficulty maintaining mental focus, all validated
by diagnostic studies. Consequently, the International Association of Fire Fighters has taken
a position opposing the use of fire station as base stations for telecommunications towers.9
2) A new 2019 study shows that nearby cell tower radiation harms children’s brains,
resulting in significant decline in cognitive scores.9
3) The first reported injury from 5G comes from Geneva, Switzerland , where 5G was
launched in 102 locations. Residents “experienced loud ringing in the ear, intense
headaches, unbearable earaches, insomnia, chest pains.” July 201910 Even though the
Swiss canton (state) to which Geneva belongs has banned 5G, the antennas had already been
installed and the telecom company activated them anyway.11
References
1 https://www.5gcrisis.com/scientific-studies
2 Electromagnetic fields act via activation of voltage-gated calcium channels to produce beneficial or adverse
effects” by Martin Pall J Cell Mol Med 8/2013
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3780531/
3.”Science on 5G and Wireless Radiation” Interview with Dr. Devra Davis, 8/2019 president and founder of the
Environmental Health Trust, award winning internationally renowned scientist and founding director of the board
on environmental studies and toxicology of the National Academy of Sciences. She’s also current Visiting
Professor of Medicine in Israel and Turkey. Based on her book : Disconnect, Environmental Health Trust 2013
https://www.amazon.com/Disconnect-Truth-About-Phone-Radiation/dp/0991219902
4. https://ehtrust.org/wp-content/uploads/NTP-Factsheet.pdf, and at
https://www.ncbi.nlm.nih.gov/pubmen/316338/39
5 https://www.ncbi.nlm.nih.gov/pubmed/29530389 and https://www.ewg.org/release/italian
6 https://mdsafetech.files.wordpress.com/2016/11/a-5g-future-article-sccma-with-references-61617-pdf.pdf
Includes extensive references to scientific studies
7 “We Have No Reason to Believe 5G is Safe”, Joel M. Moskowitz, Ph.D., Scientific American, October 17, 2019.
https://blogs.scientificamerican.com/observations/we-have-no-reason-to-believe-5g-is-safe/
8 “Electromagnetic fields act via activation of voltage-gated calcium channels to produce beneficial or adverse
effects” by Martin Pall J Cell Mol Med 8/2013 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3780531/
9 https://mdsafetech.org/2019/09/28/firefighters-fighting-fires-and-now-cell-towers/
10 https://mdsafetech.org/2019/07/20/the-first-report-of-5g-injury-from-switzerland/
11 Regional Governments Standing Against 5G, Interview with Rapael Mahaim, Member of Parliament in Vaud,
Switzerland. www.5g.org.nz/2019/08/31/free-online-5g-crisis-summit-august-26-september-1-2019
NOTE: All journal-published medical studies listed above are peer-reviewed and therefore Supreme Court
admissible.
CORRESPONDENCE LISTING
April 14, 2025
Please review the following correspondence and indicate, by placing your initials in the right-hand column
adjacent to the correspondence, that you wish to receive a copy. We can forward a copy to you via e-mail or
make a hard copy. Please indicate your preference next to your name at the bottom of this form.
Correspondence – Item Please place your
initials here if you wish
to receive a copy
Retention: Permanent
1. Lifelong Letter
2. Solar RPT Letter Newfield Elmira Road- Sent in Error to TOI
3. Special Franchise Report for 2025
4.
Retention: Six-Year
1. DEC Letter for Public Sewer System
2.
1.
2.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
1
Paulette Rosa
From:CJ Randall <cjrandall@townithacany.gov>
Sent:Thursday, April 3, 2025 4:59 PM
To:Town Of Ithaca Clerks Department; Paulette Rosa
Subject:Fw: correspondence dated 3/13/2025 re RPTL 487
FYI per the letter I left on @Paulette's chair — thanks!
C.J.
From: Mariah Brown
Sent: Thursday, April 3, 2025 4:58 PM
To: CJ Randall
Cc: Rod Howe
Subject: Re: correspondence dated 3/13/2025 re RPTL 487
Thank you for pointing that out and I apologize for any confusion! I'll make sure that my team is aware of
this, too, so that we can avoid any other mixups in the future. It looks like there might have been a mixup
with the town lines back when we were still considering that other parcel on Elmira Road.
And thank you for providing a point of contact for the town of Newfield! I'll make sure that the notice goes
out again to the correct address
Have a nice day!
Mariah Brown
On Thu, Apr 3, 2025 at 4:30 PM CJ Randall <cjrandall@townithacany.gov> wrote:
Hi Mariah,
TPN 5.-1-4.2 (Tax Map attached) is on Elmira Road in the Town of Newfield, not the Town of Ithaca. I believe
the contact for the Newfield Town Clerk is townclerk@newfieldny.org.
C.J.
C.J. Randall, LEED AP ND
Director of Planning
Town of Ithaca
215 N Tioga St
Ithaca, NY 14850-4357
607-273-1721 x120
cjrandall@townithacany.gov
From: Mariah Brown
Sent: Thursday, April 3, 2025 3:58 PM
2
To: CJ Randall
Cc: Rod Howe
Subject: Re: correspondence dated 3/13/2025 re RPTL 487
Hi CJ,
Good afternoon!
For the property mentioned in the Notice of Intent Letter, I was told that one of the projects is actually
going to be cancelled. The only property where we plan to develop a solar project is tax ID: 5.-1-4.2 (this
site does not have a 911 address but it is on Elmira Road)
As for a phone call, I can speak sometime tomorrow afternoon - my phone number is (203) 962-1649. I
also want to give you a heads up that I will be working remotely tomorrow, so there might be a slow turn
around if I need to get in touch with someone else from my office (in case I am unable to provide
answers for everything discussed).
Please let me know what time works best for you!
Thank you,
Mariah Brown
On Wed, Apr 2, 2025 at 3:02 PM CJ Randall <cjrandall@townithacany.gov> wrote:
Hi Mariah,
Thanks for the update. Do you have a phone number at which I can contact you tomorrow (Thu 4/3)
afternoon or Friday (4/4) afternoon?
Please advise, thanks!
C.J.
C.J. Randall, LEED AP ND
Director of Planning
Town of Ithaca
215 N Tioga St
Ithaca, NY 14850-4357
607-273-1721 x120
cjrandall@townithacany.gov
From: Mariah Brown <mariah.brown@delawareriversolar.com>
Sent: Thursday, March 27, 2025 4:21 PM
To: CJ Randall <cjrandall@townithacany.gov>
Cc: Rod Howe <RHowe@townithacany.gov>
Subject: Re: correspondence dated 3/13/2025 re RPTL 487
3
**WARNING** This email comes from an outside source. Please verify the from address, any URL
links, and/or attachments. Any questions please contact the IT department
CJ,
Hello! I apologize for the delay in responding to your email. The RPTL 487 notice that was sent out is in
reference to sites on Elmira Road. I am currently working with our pre-development team to confirm
the correct tax ID(s)
I will let you know as soon as I hear back from them!
Thank you for your patience,
Mariah Brown
On Tue, Mar 25, 2025 at 12:01 PM CJ Randall <cjrandall@townithacany.gov> wrote:
Hi Mariah,
The Town is in receipt of the RPTL 487 correspondence dated 3/13/2025 relative to a location on Elmira
Road, however, it includes no detail on an address, tax parcel number, or the like.
Would you please send details on this proposed project at your earliest convenience? As mentioned
previously, I tried to call but there is no phone number listed on the letter. I just left a voicemail at 646-998-
6495 as that was the only phone number I could find associated with DRS.
Please advise, thanks!
C.J.
C.J. Randall, LEED AP ND
Director of Planning
Town of Ithaca
215 N Tioga St
Ithaca, NY 14850-4357
607-273-1721 x120
cjrandall@townithacany.gov
From: CJ Randall
Sent: Wednesday, March 19, 2025 9:20 AM
To: mariah.brown@delawareriversolar.com
Cc: Rod Howe
Subject: correspondence dated 3/13/2025 re RPTL 487
Hi Mariah,
The Town is in receipt of the RPTL 487 correspondence dated 3/13/2025 relative to a location on Elmira
Road, however, it includes no detail on an address, tax parcel number, or the like.
4
Would you please send details on this proposed project at your earliest convenience? I tried to call but there
is no phone number listed on the letter.
Please advise, thanks!
C.J.
C.J. Randall, LEED AP ND
Director of Planning
Town of Ithaca
215 N Tioga St
Ithaca, NY 14850-4357
607-273-1721 x120
cjrandall@townithacany.gov
RP-7114
(3/18)
Department of Taxation and Finance
Of¿ceofRealPropertyTaxServices
Municipal Report of Special Franchise
Activity
Please¿llinallblanks(enterNAifnotapplicable)
Part 1: Municipality name: SWIS code:
Prepared for calendar year ending:
Part2:Municipalboundaries
Inthemostrecentcalendaryear,werethereboundarychangesinyourmunicipality?YesNo
If Yes,datechangeoccurred
If Yes,fromwhichmunicipalitydidyourmunicipalityannexarea?
If Yes,whichmunicipalityannexedareafromyourmunicipality?
If Yes,pleasesubmitamapsuitablefordigitizingwhichclearlyhighlightstheboundarychange.Itshouldcontainatleastfour
GeographicRegistrationPointsandtheirmapunitvalues.Thesevaluesmustconformtoastandardcoordinatesystem(i.e.,State
PlaneFeet,Latitude&Longitude,UniversalTransverseMercator(UTM),etc.).ORPTSwillsendacopyofthismaptoeachspecial
franchiseownertodeterminethevalueofthepropertyaffected.
Part 3: New special franchise
Giveexactnameandaddressofanypublicutilitycompany,cabletelevisionsystem,orprivatepipelineownertowhomyouhave
grantedanewfranchiseauthorizinguseofpublicplaceinthemostrecentcalendaryear(notincludingrailroadsormunicipal
corporations).Pleaseattachacopyofthefranchise(requiredbyRealPropertyTaxLawsection602).Pleasechecktheappropriate
itembelowtoindicateifconstructionisinplaceoranticipatednextyear.Donotincludepropertylistedonlastyear’sspecialfranchise
taxroll.Ifnecessary,attachaseparatesheetforadditionalnamesandaddresses.
Name:
Address:
Constructionstatus:InplaceNextyear
Part4:Constructioninthepublicrightofway
Giveexactnameandaddressofanypublicutilitycompany,cabletelevisionsystemorprivatepipelineowner,whichhasconstructed
orplacedanypropertyin,under,uponoraboveanystreet,highwayorpublicplaceinthemostrecentcalendaryear.Pleasecheckthe
appropriateitemtoindicateifconstructionissubjecttoaspecialfranchise.Ifnecessary,attachaseparatesheetforadditionalnames
andaddresses.
Name:
Address:
Subjecttospecialfranchise?YesNo
Part 6: Signature of mayor, town supervisor, assessor, or authorized designee
Signature:Title: Date:
Name:Telephonenumber:
Of¿ceaddress:
Part 5: Comments
Please email to: ORPTS.Utility.Reports@tax.ny.govorfaxto(518)435-8631beforeApril15.
Or mail to: NYS TAX DEPARTMENT
ORPTS UTILITY REPORTING
W A HARRIMAN CAMPUS
ALBANY NY 12227-0801
IfnotusingU.S.Mail,seePublication55,Designated Private Delivery Services.
Town of Ithaca 503000
04/10/2025
No new infrastructure, just replacement of existing infrastructure of Gas, electric, and Charter Communications Cable
Supervisor 4/10/2025
Rod Howe (607) 273-1721
215 N. Tioga Street, Ithaca, NY 14850
CORRESPONDENCE LISTING
April 28, 2025
Please review the following correspondence and indicate, by placing your initials in the right-hand column
adjacent to the correspondence, that you wish to receive a copy. We can forward a copy to you via e-mail or
make a hard copy. Please indicate your preference next to your name at the bottom of this form.
Correspondence – Item Please place your
initials here if you wish
to receive a copy
Retention: Permanent
1. Resident Comment Ithaca Green Energy/Cornell Compliance
2. Garner Resignation
3.
4.
Retention: Six-Year
2.
1.
2.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
1.
1
Earth Day 2025
Town Board members
Ithaca, NY 14850
Via email
Dear Town Board members;
Today, attendees at the People’s Earth Day in Ithaca will call for Cornell University to comply with
Ithaca’s green energy code. We are writing as engineers, scientists, and environmental advocates to
support this call. The evidence strongly opposes Cornell administrator's sought-after exemption
from the fossil-fuel phaseout mandated by Ithaca’s Energy Code Supplement (IECS).
Ithaca’s progressive energy code is designed to help deliver on the Ithaca Green New Deal’s
emissions reduction goals for all new construction or major renovations. Cornell administrators
have requested amendments to the law. Their amendments have two separable main objectives:
(1) Allow buildings (new or renovated) to connect to Cornell’s district energy system.
The district energy system can flexibly support diverse, non-site-specific heat sources such
as electrified ground-source heat pumps (GSHP). Therefore, we support these amendments
so long as the heating load for any building change connected to the district energy system
is met with GSHP rather than gas, thereby fulfilling the intent of the IECS.
(2) Exempt Cornell’s district energy system and its gas-fired power plant from the
fossil-fuel phaseout that comes into effect January 1, 2026. Specifically, Cornell
administrators submitted changes to sections C407.7.2 (restricting the definition of the
fossil-fuel phaseout to exclude their system) and 302 (changing the definition of heating
plant to “limit the scope of the IECS” and exclude Cornell’s gas-fired power plant) [1-2]. The
practical result of these amendments would be that there is no longer any requirement to
reduce consumption of fossil fuels on Cornell’s central campus, in stark contrast to the rest
of Ithaca. We oppose these amendments.
Cornell is pursuing their requested exemption (2) from Ithaca’s fossil-fuel phaseout under the false
pretense that adding the heating load from new buildings to their gas plant will lead to fewer
emissions than electrifying buildings. This is incorrect, as outlined in the enclosed Executive
Summary of the white paper titled “Estimating the Operational Emissions of Cornell University Heat
Decarbonization Pathways.” We brought this evidence to Cornell administrators’ attention, but they
have so far declined to accommodate the evidence or pursue the correct methodology. Instead, they
have made a number of contradictory, incoherent changes to their argument while still advocating
for the predetermined conclusion that they should be free to continue expanding fossil-fuel use on
campus (see enclosures 2 and 3, TCCPI email and information sheets).
If successful, Cornell’s requested amendments would set a dangerous precedent for climate action
here and everywhere. Here in Ithaca, the faulty methodology that Cornell uses to exempt itself
2
would also exempt everyone else because it miscalculates the emissions benefits of electrification to
such an extent that Ithaca’s officials could no longer reasonably ask their residents to electrify. On a
larger scale, granting Cornell’s amendments would lend unwarranted legitimacy to Big Oil’s
misinformation. The claim that Cornell’s gas plant produces fewer emissions than electrification
uses the same wrong methodology to reach the same wrong conclusion as the American Gas
Association (see enclosures 4-5, op-eds). Big Oil promotes this misinformation to cripple America’s
energy transition. While Cornell (like Big Oil) stands to reap economic benefits from continued use
of their gas-fired plant, one would expect that Cornell (unlike Big Oil) would follow the standards of
science and actively counter misinformation, not propagate it. Correct modeling according to the
consensus in the academic and industry literature contradicts Cornell administrators’ claims:
expansion of gas-fired heating is not projected to be better for the climate than electrification of
heat.
Cornell’s requested amendments represent a minority viewpoint held by specific administrators at
Cornell. Meanwhile, the relevant faculty experts at Cornell, an author of the IECS, and many of the
relevant stakeholders strongly disagree with those amendments (see enclosures 6-7, petition and
Student Assembly Resolution). Cornell administrators still have not provided any modeling
evidence to support their claim that electrifying heat at Cornell would increase emissions. Instead,
they continue to make unsubstantiated claims while questioning the credibility of the white paper.
We find this pattern of non-transparency and resistance to evidence concerning.
We urge you to protect the integrity of our progressive energy code against Cornell’s misguided
amendments. Please ensure that no new load is added to Cornell’s gas plant and that Cornell
participates in Ithaca’s fossil-fuel phaseout along with the rest of us. Members of our team would be
happy to discuss any of these details further or give a presentation to your decision-making bodies.
In collaboration,
Anthony Ingraffea, Professor Emeritus of Civil and Environmental Engineering, Cornell University
Ian Shapiro, Member of the team that developed the Ithaca Energy Code Supplement
Fenya Bartram, Environmental Engineering ‘25, Cornell University
Adam Vinson, signing on behalf of the Cornell Student Assembly Environmental Committee
bethany ojalehto mays, signing on behalf of Cornell on Fire
Ace Dufresne, Ithaca High School climate organizer, signing on behalf of Sunrise Ithaca
Brian Eden, signing on behalf of Campaign for Renewable Energy
Matt Franke-Singer, signing on behalf of the Environmental Interests Circle at First Unitarian
Society of Ithaca
Margaret McCasland, signing on behalf of Families for a Livable Future Tompkins
Claire Nickell, signing on behalf of Extinction Rebellion Ithaca
Lani Lin-Kissick, Candidate for Cornell Board of Trustees and Director of Peaceful Planet
Dan Antonioli, Going Green
3
Postscript:
Cornell’s full set of requested amendments to the IECS also include two additional objectives: (1)
reclassify dormitories into the same category as hotels, so that dormitories would be exempt from
whole-building compliance with the energy code; and (2) revise the code’s energy use reduction
standards slightly downward to require less efficiency. Arguably, the practical effect of both sets of
amendments is to further water down the IECS. These amendments are orthogonal to our work in
the white paper but merit similar scrutiny.
Sources Cited:
1. Letter from Matthew Kozlowski (Cornell Facilities Engineering and Environmental and Energy
Services Section Manager) to Robert M. Fell-DeWalt (Supervisor of Buildings and Code Enforcement,
City of Ithaca Building Division) dated May 17, 2023. Available in the City of Ithaca Sustainability &
Climate Justice Commission Agenda for April 15, 2024:
https://www.cityofithaca.org/AgendaCenter/ViewFile/Agenda/_04152024-2852
2. Letter from Sarah Carson (Cornell Campus Sustainability Office) to Rebecca Evans (Sustainability
Director, City of Ithaca) dated March 13, 2024. Available in the City of Ithaca Sustainability & Climate
Justice Commission Agenda for April 15, 2024:
https://www.cityofithaca.org/AgendaCenter/ViewFile/Agenda/_04152024-2852
Enclosures:
1. Executive summary of the white paper on Cornell Heat Decarbonization Pathways
2. TCCPI Email from Professor Jacob Mays RE: Cornell Energy Team Presentation
3. Information sheets (2): Breakdown of key points regarding Cornell vs. IECS
4. Op-ed, “Cornell should not be exempt from Ithaca’s fossil-fuel phaseout”
5. Op-ed, “Cornell’s Energy Transition - a troubling delay on decarbonization”
6. Petition calling on Cornell to decarbonize
7. Cornell Student Assembly Resolution 20
To access a digital version of this packet
for reference or dissemination,
please scan the QR code or visit https://qrfy.io/fo8xaMzgJS
Executive Summary of the White Paper:
Estimating the Operational Emissions of Cornell University Heat
Decarbonization Pathways
Fenya Bartram, Environmental Engineering ‘25, Cornell University
Eric Potash, Institute of Sustainability, Energy, and Environment, University of Illinois Urbana-Champaign
bethany ojalehto mays, PhD, Independent researcher
Jacob Mays, Assistant Professor of Civil and Environmental Engineering, Cornell University
Anthony Ingraffea, Professor Emeritus of Civil and Environmental Engineering, Cornell University (technical
monitor)
Should Cornell be exempt from Ithaca’s fossil-fuel phaseout? Cornell University administrators have
submitted amendments to Ithaca’s progressive Energy Code Supplement (the IECS) that would
exempt its campus from Ithaca’s fossil-fuel phaseout on new construction and major renovations.
Cornell claims that transitioning to electrified heat pumps such projects would increase carbon
emissions relative to continued use of their gas-fired power plant. However, they have not provided
any modeling to substantiate that claim.
To better understand this problem, an interdisciplinary team of experts worked with Cornell on Fire
to model the emissions consequences of heat electrification at Cornell, producing an independent
white paper called “Estimating the Operational Emissions of Cornell University Heat
Decarbonization Pathways.” We develop a model to estimate the emissions from two heating
decarbonization pathways over the period 2026-2050: near-term decarbonization in compliance
with the IECS (using Ground Source Heat Pumps for new construction or renovations) versus
delayed decarbonization on exemption from the IECS (continuing to use Cornell’s gas-fired heat
plant for such projects). On both pathways, our model assumes that Cornell’s experimental
decarbonization technology Earth Source Heat (ESH) is successfully implemented by 2035.
We find that near-term decarbonization, as mandated by the IECS, confers significant emissions
benefits: compared to the delayed decarbonization pathway, Cornell would reduce operational
carbon emissions by 53–93% by implementing GSHPs in 2026, depending on the emissions
trajectory assumed for the New York power grid. Importantly, the emissions benefits of
electrification hold even in pessimistic scenarios where the NY grid energy transition is delayed.
The key difference between our model and Cornell’s is methodological: we followed the widespread
consensus in the academic and industry literature that long-run emission rates are appropriate to
building electrification decisions. Cornell’s prior analyses relied on short-run emission rates, an
unsound methodology known to overestimate the benefits of gas heating. The American Gas
Association uses this faulty method to mislead the public on the benefits of the energy transition.
Broader Implications (commentary by Cornell on Fire): Cornell’s lobbying to rewrite the IECS
participates in a broader pattern of discordant climate rhetoric and action. Cornell continues to
inaccurately represent their gas-fired power plant as “lower-carbon” and reports their emissions as
if methane gas has contributed to slashing campus emissions by 50% since 2008. Yet if they
reported upstream methane emissions accurately according to the NY Climate Act, as both Ithaca
and Tompkins County do, we would find that Cornell has not reduced emissions at all since 2008
[1]. Meanwhile, the steam-to-hot-water conversion designed to improve the efficiency of Cornell’s
district heating system is proceeding more slowly than anticipated, while Cornell has failed to invest
any significant sum in their flagship Earth Source Heat Project [2]. In a January op-ed in the Cornell
Daily Sun, President Kotlikoff construes Cornell’s amendments to the IECS as driven by the goal of
reducing load on the grid and their prioritization of Earth Source Heat as a campus decarbonization
strategy [3]. Yet Cornell is engaged in rapid campus expansion including eight major new
construction projects planned or ongoing in 2024 that cost over $337 million; by contrast, Earth
Source Heat would cost an estimated $250 million in total [4]. If Cornell wanted to avoid new load
on the grid and pursue decarbonization on the timescale that matters, Earth Source Heat would be
their chief priority – not more new buildings served by gas.
Sources Cited:
[1] Cornell on Fire (2024) What the climate cares about: The concerning state of Cornell’s Climate Action Plan.
An independent report by Cornell on Fire. Available online at:
https://www.cornellonfire.org/climate-action-report
[2] Anthony Ingraffea (2025) “Op-ed: Save the Earth Source Project.” The Cornell Daily Sun, February 26,
2025. Available online at:
https://www.cornellsun.com/article/2025/02/letter-to-the-editor-save-the-earth-source-heat-project
[3] Michael Kotlikoff (2025) “Op-ed: Cornell's Energy Transition.” The Cornell Daily Sun, January 21, 2025.
Available online at: https://www.cornellsun.com/article/2025/01/kotlikoff-cornells-energy-transition
[4] Cornell on Fire (2025) “CoF Post 2/13: A true story – decarbonization at a crossroads.” Available online at:
https://www.cornellonfire.org/blog/cof-post-213-a-true-story-decarbonization-at-a-crossroads
To read the full white paper on
Cornell’s decarbonization pathways,
please scan the QR code or visit
www.cornellonfire.org/decarbonization-report
TCCPI Email from Professor Jacob Mays RE: Cornell Energy Team
Presentation
An email commentary from Jacob Mays forwarded to the Tompkins County Climate Protection
Initiative (TCCPI) listserv by Peter Bardaglio on April 13, 2025, in follow-up to the Cornell Energy
Team’s presentation to TCCPI on March 28, 2025, where they argued for their IECS amendments.
I wasn't able to join the full call due to other commitments, but thought it would be worth offering
some clarifications. I am pleased that the team has decided to pursue a new methodology in
response to our paper, but fear that the new proposal to analyze and use an unconventional "future
short-run marginal emission rate (MER)" still falls short of best practice. Based on the chat log, I
believe the new proposal may be motivated by some misconceptions about long-run MERs. Bert
writes that "To claim that today's MER is not really what it is (based on physics) and apply some
hypothetical offset from the future to today, is not credible." He later adds that "[LRMER] reduces
the actual accounting of the actual physical emissions with a theory."
Since LRMERs do not in any way claim that today's MERs are anything other than they are, I am
unsure how to interpret the first quote. Clearly, a model of "future short-run MERs" is equally
dependent on modeling assumptions, so characterizing the Energy Team's changed approach as
based on "physics" and ours as hypothetical is likely to cause confusion--they are both projections
of unknown future outcomes. To state this differently, the SRMER approach focuses on physics
alone, while the LRMER approach also includes policy and economic factors; given the importance
of policy and economics in the evolution of the grid, excluding them from the analysis is not tenable.
As stated in January, in our view the primary challenge is ensuring that credible assumptions go into
the modeling of long-run marginal emissions rates, which is the accepted methodology among
researchers working in this area.
Bert and the team have made their skepticism of estimates published in the literature clear, but that
is not a valid justification to pursue a non-standard methodology. Further, some elements of the
presentation suggest that the team has not completely aligned on the methodology they will
ultimately pursue. As an example, in the presentation Sarah advocated the use of LRMERs in the
context of standalone buildings, proposing the unconventional "future short-run" methodology only
for district energy systems. While some aspects of the decision problem are indeed different for
district energy systems, none of those differences would justify the use of a different emissions rate
estimate. Meanwhile, Bert claims that "[t]he concept of a Long Term Marginal Emission Rate (MER)
is a theory that is not applicable in today's grid," suggesting that he thinks it shouldn't be used for
standalone buildings either. Since the team is just starting this new analysis, I hope that they can
pivot again and converge on a sound approach.
Jacob Mays
Assistant Professor, School of Civil and Environmental Engineering, Cornell University
MYTH VS. FACT
7 MYTHS about Cornell's attempt to change Ithaca's energy
law - CORRECTED (How to spot Cornell’s misunderstandings)
Starting in 2026, Ithaca's Energy
Code holds that fossil fuels cannot
be used to heat new buildings or
renovations. This makes us one of
the first American cities to require
all-electric building operations for a
zero-carbon future.
WHAT'S AT STAKE: Ithaca Green New Deal vs. Cornell Gas Plant
Cornell wants an exemption so they
can keep using their gas-fired power
plant to heat new buildings and
renovations. Cornell's exemption
replicates Big Oil's misinformation
and would set a dangerous precedent
that undermines climate action.
Why it's alarming: The false claim that decarbonization technologies like heat
pumps will increase emissions uses the wrong methodology to reach the wrong
conclusion - AND it replicates Big Oil's misinformation. NOT OKAY, CORNELL.
This is a debate between Cornell Incorporated (administrators) and Cornell
University (faculty experts). Administrators want to be exempt from Ithaca's
fossil-fuel phaseout; experts argue this is unsound. Here, we lay out the facts.
CORNELL'S OWN EXPERTS DISAGREE WITH THEM
1MYTH: Electrifying heat on campus
will increase emissions.*
*Based on 100% wrong methodology.
CORNELL INC SAYS
FACT: Electrifying heat on campus is
projected to decrease emissions.*
*Based on best available evidence.
CORNELL UNI SAYS
MYTH: Cornell should wait to electrify
heat until the grid is fully renewable.
FACT: We need to electrify now for the
renewable energy transition we need.
Why it's alarming: Is there uncertainty about the grid transition? Yes. Does that
justify fatalism or incorrect methods? No. The energy transition requires that we
electrify everything AND green the grid in parallel, not in sequence.
2
MYTH VS. FACT
Why it's alarming: Ithaca's Energy Code requires fossil-fuel phaseout for all heat
systems. It's absurd for Cornell to claim that building owners and home owners
should have to decarbonize while gas-plant owners get a free pass. Say what?!
MYTH: Cornell is special because
their new buildings do not install
new fossil-burning equipment
within the floor space.
FACT: Sure - it's a district energy
system. But Cornell's new buildings
DO create new gas demand served by
fossil-burning equipment on campus.
MYTH: Cornell doesn't need to
decarbonize now because Earth
Source Heat will fix everything.
FACT: Earth Source Heat may not
come online until 2035 - if at all. Even
then, it will not serve all of campus.
Why it's alarming: Using Earth Source Heat as a decoy to avoid Ithaca's
fossil-fuel phaseout equates to "promoting unproven technological solutions" to
sustain fossil fuel use. That's defined as climate obstruction.
Why it's alarming: Cornell Inc misunderstands or willfully ignores the real
implication of their argument: If Ithaca were to endorse Cornell's (and Big Oil's)
faulty short-run method, we would find that no one should decarbonize.
MYTH: Cornell's exemption will not
affect the rest of Ithaca: all of YOU
should still decarbonize.
CORNELL INC SAYS
FACT: The same faulty method that
Cornell uses to exempt themselves
would also exempt everyone else.
MYTH: District energy systems like
Cornell's should be exempt because
they have special features.
FACT: NONE of those features justify
exempting Cornell or their gas plant
from Ithaca's fossil-fuel phaseout.
CORNELL UNI SAYS
Why it's alarming: The experts who wrote Ithaca's Energy Code law knew full
well that Cornell operated a district energy system - AND they believed that it
should also be subject to Ithaca's fossil-fuel phaseout.
MYTH: Cornell claims they are not
asking for an "exemption" from
Ithaca's fossil-fuel phaseout law.
FACT: Cornell wants to change the
law so they can keep expanding
fossil fuel use while the rest of
Ithaca stops. This is an exemption.
Why it's alarming: Cornell is effectively lobbying to undermine ambitious regulations
and "normalize mitigation delay under the guise of pragmatic policy
recommendations." That meets the definition of climate obstruction.
3
4
5
6
7
MYTH VS. FACT
1
HOLD THE LINE
WE NEED A GREEN FUTURE: And we wrote it into law!
Ithaca's energy code is one of the
most progressive programs in the US
to have impact in the face of the
climate crisis.
HIGH STAKES. Ithaca's fossil-fuel phaseout is under threat
from Cornell. Help protect our climate energy law.
HOLD THE LINE on new new fossil fuels.
Ithaca's progressive energy code
requires that fossil fuels cannot
be used to heat new buildings or
renovations.
GREEN NEW DEAL
Cornell wants to exempt itself so it
can keep using its gas-fired power
plant to heat new buildings and
renovations.
Every building owner and home
owner in Ithaca is required to phase
out fossil fuels in new construction.
Cornell is arguing that gas-plant
owners should be exempt from
Ithaca's fossil-fuel phaseout.
CORNELL GAS PLANT
HOLD THE LINE on fairness, not a free pass. Why should gas-plant owners (of all
people) get a free pass?!
2
HOLD THE LINE
VS
BUILDING OWNERS GAS-PLANT OWNERSVS
We fought for Ithaca's green energy
code. Now Cornell wants to water it
down. We need to hold the line.
"I oppose Cornell's proposed amendment...The Ithaca Energy Code Supplement
requires that they not add new load to their existing plant."
-Ian Shapiro, author of the Ithaca Energy Code Supplement
FROM THE EXPERT WHO LITERALLY WROTE THE LAW
HOLD THE LINE on climate justice. Whether you feel threatened by floods,
wildfire smoke, or sea level rise, Ithaca's energy code is one of our key
strategies to make a difference for our grandchildren’s grandchildren.
3
4
Electrifying heat is an economic
commitment that each new building
owner makes to lay the groundwork
for a zero-carbon future.
Cornell hasn't been transparent about
the fact that its gas plant creates a
perverse economic incentive to stay
on gas rather than electrify.
HOLD THE LINE on transparency, not partiality. Cornell cares about their
"quadruple bottom line" - so why aren't they talking about the economics here?
COMMITMENT HEDGING BETSVS
HOLD THE LINE on science, not misinformation. Exempting Cornell from our
energy code would lend unwarranted legitimacy to the fossil fuel lobby.
Ithaca's Energy Code correctly
projects that electrification will
decrease emissions. This is equally
true for Cornell as for the rest of
Ithaca.
ENERGY TRANSITION
Cornell is using the same misleading
rhetoric as the fossil fuel lobby to try
to exempt itself. They are both wrong
because they use the wrong methods.
FOSSIL-FUEL LOBBYVS
HOLD THE LINE on community, not divisions. We must all do our part to phase
out fossil fuels - including Cornell.
Ithaca's Energy Code sets out
our community's legally-binding
vision for a better future. Cornell
is part of our community.
RESPONSIBILITY
Cornell may not pay taxes, but they
are still part of Ithaca. We condemn
Cornell's pretense of exceptionalism
and lack of accountability.
DUCKING OUTVS
Everybody else in Ithaca has to stop using gas in new construction projects.
So should Cornell. Cornell has had years to come up with a master plan for
decarbonization. No more delay accepted.
It is NOT OKAY to use faulty methodology, practice climate obstruction, or
replicate Big Oil's misinformation. All of Cornell's arguments for an exemption
are faulty. Cornell should stop replicating Big Oil's misinformation.
BOTTOM LINE:
Cornell is effectively lobbying to undermine ambitious
regulations and "normalize mitigation delay under the
guise of pragmatic policy recommendations." That
meets the definition of climate obstruction.
5
HOLD THE LINE
This op-ed is co-signed by 19 individuals and 5 organizations, listed below.
Lead authors are Robert Howarth, Anthony Ingraffea, Brian Eden, & Bethany
Ojalehto Mays.
In 2021, Ithaca made international headlines by becoming the first U.S. city to
vote to decarbonize every single building. With climate action now disrupted
at the federal level, Ithaca’s leadership on local climate action is more
important than ever. Ithaca’s progressive Energy Code Supplement (the IECS)
would phase out the use of fossil fuels in new construction and renovations
and set a model for cities everywhere. But that plan is now being undermined
by an unlikely actor: Cornell University.
Several weeks ago, Cornell’s Interim President Michael Kotlikoff penned an
op-ed in TheCornell Daily Sun arguing that decarbonizing campus with
electrified heat pumps would increase carbon emissions relative to
continued use of its gas-fired power plant. Unfortunately, it used the same
faulty argument that the American Gas Association (AGA) is using to cripple
America’s decarbonization efforts. The AGA misleadingly argues that the use
of natural gas in buildings is preferable for energy efficiency and emissions
reduction when compared to electric heat pump options. In an eerie parallel
to the oil and gas industry, Cornell is leveraging this faulty methodology to
change the IECS to exempt its campus from Ithaca’s fossil-fuel phaseout on
new construction and major renovations.
Cornell’s claim that decarbonizing heat on campus will increase emissions is
faulty because it relies upon short-run marginal emission rates. The
widespread consensus in the academic and industry literature is that
long-run marginal emission rates are appropriate for building electrification
decisions. The key question is: Should we adopt a long-run view and build
now for the renewable energy transition we need, or adopt a short-run
perspective and delay action until the grid has already largely transitioned?
Guest Opinion: Cornell Should
Not be Exempt From Ithaca’s
Fossil-Fuel Phaseout
Published in THE ITHACA TIMES | ithaca.com March 21, 2025
Focusing on short-run emissions is known to overestimate the benefits of gas heating
and underestimate the benefits of decarbonization – which is why the American Gas
Association uses this incorrect methodology to mislead the public on the energy
transition.
Cornell’s argument is wrong in an unusually high-stakes way because it replicates Big
Oil’s misinformation. Not only does Kotlikoff’s op-ed leverage unsound methodology to
reach the wrong conclusion – but it does so using exactly the same flawed reasoning
that Big Oil leverages in their attack on America’s energy transition. As a result, anyone
looking to Cornell for advice on the energy transition just got the wrong message. If it is
true that “all eyes are on Ithaca,” as the Rolling Stone reported, then that is a high-impact
mistake. It arms Big Oil’s climate hypocrisy and lends unwarranted credibility to their
false narrative.
Cornell’s public campaign to amend the IECS undermines years of hard work, research,
activism, and policy-making that brought us the IECS. If we were to adopt Cornell’s faulty
logic of using short-run emission rates for building electrification decisions, we would find
that the IECS is ineffective or even self-defeating, and so are other building electrification
mandates across most of the US.
Some of us co-authored or advised a white paper called “Estimating the Operational
Emissions of Cornell University Heat Decarbonization Pathways.” Using correct long-run
emissions methodology, we find that Cornell will reduce emissions by decarbonizing new
construction projects now, as mandated by the IECS. Even after accounting for special
features of Cornell’s district energy system and pessimism about New York’s progress
toward climate goals, the emissions benefits of near-term heat decarbonization persist.
We recently presented our findings to the larger community including Cornell.
Cornell’s argument for delaying decarbonization might be well intentioned, but good
intentions do not make good climate policy. And good intentions exist in context. At
Cornell, that context includes a University-owned Combined Heat and Power Plant that
creates economic incentives to remain on gas, and a Board of Trustees that answersto
and empowers key players in the oil and gas industry. This conflicted context makes it
even more critical for Cornell’s climate actions to be decisive, positive, and correct.
Cornell has an important role to play in leading the science and practice of the energy
transition. Cornell should champion Ithaca’s climate goals and participate in Ithaca’s
mandated fossil-fuel phaseout along with the rest of us. More than that, Cornell should
show the world how to rise to the challenge of the climate emergency by decarbonizing
and degrowing the university lifestyle while foregrounding perspectives from frontline
communities. Universities have a special obligation to act in line with their own scientists’
warnings about the direness of our situation. We cannot afford Cornell’s
business-as-usual approach to fake plastic grass fields made of fossil fuels, unchecked
campus expansion, heedless hypermobility, and now – delayed decarbonization.
Published in THE ITHACA TIMES | ithaca.com March 21, 2025
Two years ago, Rolling Stone noted that Ithaca is a college town “at the forefront of the
climate revolution.” Cornell should be leading that revolution. As scientists, activists,
and environmentalists, we hope to restore the active constructive relationship with
Cornell that flourished in the past. Let’s collaborate for the greater good.
SIGNATORIES
Robert Howarth, Atkinson Professor of Ecology and Environmental Biology
Anthony Ingraffea, Dwight C. Baum Emer. Professor of Civil & Environmental Engineering
Brian Eden, Policy Coordinator Campaign for Renewable Energy
Margaret McCasland, Cornell Alum, Cornell on Fire
bethanyojalehto mays, Cornell ‘08, Cornell on Fire
Ace Dufresne, Leader, Sunrise Ithaca
Sheila Out, Cornell ‘71
Regi Teasley, Campaign for Renewable Energy
Elisa Evett, Co-chair, Mothers Out Front Tompkins
Wendy Skinner, owner, IthacaSews
Joe Wilson, COPE (Coalition for Outreach, Policy & Education)
Carol Chock, Ratepayer and Community Intervenors
Juliette Ramírez Corazón, MPH, Cornell retiree
Todd Saddler, Extinction Rebellion Ithaca
Dan Antonioli, Going Green
Elan Shapiro, Climate Justice Coalition of Tompkins County
Peter McDonald, Sustainable Finger Lakes (interim chair)
Shimon Edelman, Professor, Cornell University
Marianne Krasny, Fall Creek resident and Cornell professor
ORGANIZATIONAL SIGN-ONS
Cornell on Fire
Extinction Rebellion Ithaca
Sunrise Ithaca
Campaign for Renewable Energy
Families for a Livable Future Tompkins (formerly Mothers Out Front Tompkins)
Published in THE ITHACA TIMES | ithaca.com March 21, 2025
This op-ed is co-authored by bethany ojalehto mays, a Cornell alum '08 and
former assistant professor turned activist., Robert Howarth, the Atkinson
Professor of Ecology and Environmental Biology, and Anthony Ingraffea, the
Dwight C. Baum Professor of Civil and Environmental Engineering, Emeritus.
As Interim President Kotlikoff pointed out in a recent op-ed in The Sun, we need
to take action on climate change. However, how he proposes Cornell does so is
troublingly flawed. He suggests that the University should not begin
decarbonizing campus heat in the near term because, on Cornell’s incorrect
analysis, switching to electrified heat will backfire by increasing greenhouse
gas emissions relative to continued use of Cornell’s gas-fired plant for heating.
Cornell’s argument is well-intentioned but wrong and sets a dangerous
precedent that severely undermines climate action here and everywhere.
Unwittingly, the Cornell president platformed a talking point for the American
Gas Association (henceforth referred to as Big Oil), which is based on the
wrong conclusion from the wrong choice of method: a short-run instead of a
long-run emission rate analysis. Decisions about building electrification need
to be based on a long-run perspective, not a short-run snapshot. The crux of
the matter is: Should we adopt a long-run view and build now for the
renewable energy transition we need, or adopt a short-run perspective and
delay action until the grid has already largely transitioned?
Cornell and Big Oil appear united in their approach: We should make
decarbonization decisions based on a short-run analysis.As Big Oil knows well,
this incorrect methodology dramatically underestimates the benefits of
decarbonization and would cripple progressive electrification laws in both the
short and long term, in Ithaca and most of the U.S.
Cornell is leveraging this misplaced argument to change Ithaca’s progressive
energy law (the Ithaca Energy Code Supplement, or IECS). Starting in 2026, the
IECS holds that fossil fuels cannot be used to heat any new buildings or major
renovations in Ithaca. Cornell believes their district energy system should be
RE: Cornell's Energy Transition,
A Troubling Delay on
Decarbonization
Published in THE CORNELL DAILY SUN | cornellsun.com February 14, 2025
exempt from the fossil-fuel phaseout, arguing that this would save emissions.
Except that is wrong.
To put it in technical terms: When making long-term decisions about campus
infrastructure, Cornell should use emissions estimates that account for the long-run
evolution of the power grid (“long-run marginal emission rates”), not short-run
emissions estimates that exclude grid evolution (“short-run marginal emission
rates”). In making its case against near-term heat decarbonization, Cornell rejects
the widespread consensus in the academic and industry literature that long-run
emission rates are appropriate and instead aligns with Big Oil’s deployment of
methodologically inappropriate short-run emission rates.
To be sure, Cornell’s intended messaging diverges from Big Oil’s: Namely, Cornell still
thinks everyone else should decarbonize. But the methodology that Cornell uses to
exempt themselves from Ithaca’s fossil-fuel phaseout would necessarily exempt
everyone else. If we were to adopt Cornell’s logic of using short-run emission rates
for building electrification decisions, we would find that the IECS is ineffective or even
self-defeating, and so are other building electrification mandates across much of
the US.
Here’s the twist: While Big Oil continues to present misleading public-facingclaims
that gas heating saves emissions, they have quietly updated their narrative
elsewhere. Between 2022 and 2023, the American Gas Association updated its
attack on Denver’s decarbonization law to use long-run (instead of short-run)
emission rates. That forced them to radically change their tune: They went from
incorrectly arguing in 2022 that Denver’s law would scarcely reduce emissions, to
correctly acknowledging in 2023 that it would reduce emissions by more than 50
percent. Now, Cornell is asking Ithaca to change its progressive energy code on the
basis of an inaccurate methodology that even Big Oil has been forced to disavow.
To correct this methodological error, we co-authored a white paper called
“Estimating the Operational Emissions of Cornell University Heat Decarbonization
Pathways.” We find that Cornell will reduce emissions by decarbonizing new
construction projects now, as mandated by the IECS. We presented our findings to
the larger community including Cornell.
Cornell is skeptical that long-run emission rates are too optimistic given challenges
to the New York energy transition. We accounted for that pessimism by modeling
delayed- and no-decarbonization scenarios to see how emissions are affected
Published in THE CORNELL DAILY SUN | cornellsun.com February 14, 2025
if climate goals are delayed or weakened. We still find significant benefits for
near-term decarbonization — even in the pessimistic case of a grid that is dirtier
than ours and has a weak decarbonization policy.
If Cornell maintains that our pessimistic scenarios are not pessimistic enough, then
we must ask: What climate leader bets thousands of tons of carbon pollution on the
fatalistic wager that New York’s energy transition will fail — not just a little, but
miserably? This is a high-stakes bet. More to the point: Cornell could make it more
likely that the energy transition will fail. Cornell’s choices about building
electrification actively affect the evolution of the grid and send signals to investors
about the decline (or not) of fossil fuel demand in the near future.
Bottom line: We do not find it reasonable for Cornell to reject all published estimates
of long-run emissions and instead revert to a methodologically incorrect short-run
emission rate known to downplay the benefits of decarbonization. This is bad
strategy for the BIG RED Energy Transition, bad policy for Ithaca and lends
unwarranted credibility to Big Oil’s false public narrative about America’s energy
transition.
We could not agree more with Kotlikoff that Cornell’s energy transition requires a
holistic approach focused on equitable solutions. Yes, Cornell needs to decarbonize
their buildings, but it also needs to decarbonize and degrow the entire university
system and lifestyle while foregrounding perspectives from frontline communities.
We are concerned that Cornell’s climate action does not match the scale or
urgency of the crisis, and there are gaps between Cornell’s climate rhetoric and
action. If Cornell is so concerned about the emissions consequences of adding new
load to the grid, then why are they expanding campus at such a great rate?
Cornell’s arguments for delayed decarbonization are well-intentioned. But good
intentions do not make good climate policy. And good intentions exist in context. At
Cornell, that context includes a University-owned Combined Heat and Power Plant
that creates an economic incentive to remain on gas, and a Board of Trustees that
answersto and empowers key players in the oil and gas industry. Cornell must
ensure its climate actions are clear, collective and commensurate with the crisis.
With allies in academic and activist circles, Cornell can and — will do — better.
Published in THE CORNELL DAILY SUN | cornellsun.com February 14, 2025
PETITION CALLING FOR
DECARBONIZATION AT CORNELL
to participate in Ithaca’s Green
New Deal and begin decarbonizing
heat on campus now. Delayed
decarbonization is incompatible with
the evidence and Ithacaʼs
progressive energy law. Cornell
should not be exempt from Ithacaʼs
fossil-fuel phaseout!
WE CALL ON CORNELL
Listed below are names from the
growing coalition of organizations and
individuals calling on Cornell to
decarbonize now and protect the
integrity of the Ithaca Energy Code
Supplement.
Extinction Rebellion Ithaca
Campaign for Renewable Energy
Cornell on Fire
Sunrise Ithaca
Families for a Livable Future Tompkins (formerly Mothers Out
Front Tompkins)
Environmental Interests Circle at First Unitarian Society of Ithaca
ORGANIZATIONAL SIGNATORIES
SIGNATORIES
This is a live petition.
Track progress and add your name by scanning the QR code above or visiting
www.cornellonfire.org/actionsevents/sign-the-call-to-decarbonize
Individual signatories on next page
PETITION CALLING FOR
DECARBONIZATION AT CORNELL
•Robert Howarth, Atkinson Professor of
Ecology and Environmental Biology
•Anthony Ingraffea, Dwight C. Baum
Professor of Civil and Environmental
Engineering, Emeritus
•Shimon Edelman, Professor of Psychology
•Marianne Krasny, Professor of Natural
Resources and the Environment
•Brian Eden, Policy Coordinator Campaign
for Renewable Energy
•Margaret McCasland, Cornell Alum,
Cornell on Fire
•bethany ojalehto mays, Cornell ʻ08,
Cornell on Fire
•Ace Dufresne, Leader, Sunrise Ithaca
•Sheila Out, Cornell ʻ71
•Regi Teasley, Campaign for Renewable
Energy
•Elisa Evett, Families for a Livable
Future-Tompkins (formerly Mothers Out
Front Tompkins)
•Wendy Skinner, owner, IthacaSews
•Joe Wilson, COPE (Coalition for Outreach,
Policy & Education)
•Carol Chock, Ratepayer and Community
Intervenors
•Juliette Ramírez Corazón, MPH, Cornell
retiree
•Todd Saddler, Extinction Rebellion Ithaca
•Dan Antonioli, Going Green
•Anne Rhodes
SIGNATORIES
Signatures continue to be collected.
Track progress and add your name by scanning the QR code on front page or
visiting www.cornellonfire.org/actionsevents/sign-the-call-to-decarbonize
INDIVIDUAL SIGNATORIES
•John Abel, Professor Emeritus, Civil &
Environmental Engineering
•Leila Wilmers, Visiting Lecturer,
Department of Sociology
•Paula Ioanide
•John Monkovic
•Justin Sluyter
•Matt Franke-Singer, Environmental
Interests Circle at First Unitarian Society
of Ithaca
•Madonna Stallmann, First Unitarian
Society of Ithaca
•Carol Whitlow
•Marie McRae, Fossil Free Tompkins
•Vidhi Srivastava
•Sophia Caporusso, student in the College
of Agriculture & Life Sciences, Cornell
University
•Madelyn Smith
•Corinna Loeckenhoff, Janet and Gordon
Lankton Professor of Developmental
Psychology
•Christine Tao
•Lyden Herth
•Riley Smith
•Elan Shapiro, Showing Up for Racial
Justice, Climate Justice Coalition of
Tompkins County
•Marianna Shvartsapel
•Bransen Fitzwater, Cornell student
Page 1 of 4
Resolution 20: Climate Renewal Vows 1
Abstract: Recognizing Cornell University's duty to address the global climate crisis, not only as 2
a moral imperative but also due to the tangible and negative impacts of neglecting climate-3
related issues on its operations, community, and reputation. 4
Sponsored by: Marissa Brucker ‘26, Jenna Saevitzon ‘25, Sierra Burror ‘25, Adam Vinson ‘25, 5
Lydia Blum ‘27, Eeshaan Chaudhuri ‘27, Christian Tarala ‘27, Eric Yao ‘27 6
Type of Action: Recommendation 7
Originally Presented: 12/05/2024 8
Current Status: Placed on the Second Readings Calendar, 12/05/2024 9
Whereas, recent IPCC reports1 indicate that human activities have caused approximately 1.1°C 10
of warming since 2011-2020, temporarily exceeding 1.5°C since the pre-industrial period (1850-11
1900). The past few years have been the hottest on record, and intensifying climate-related 12
catastrophes and increasing pressure on communities, economies, and ecosystems show signs of 13
getting perilously close to the long-term warming limit of 1.5°C outlined in the Paris Agreement; 14
Whereas, these effects are evident in New York State, with rising temperatures2 driving driving 15
changes in weather patterns that threaten agriculture, food security, and local economies reliant 16
on stable climatic conditions; 17
Whereas, as a self-proclaimed leading institution in climate science and sustainability3, Cornell 18
University has a unique responsibility to act in alignment with the urgency of the climate crisis, 19
safeguard the rights of students to a habitable future, and equip students with the tools and 20
knowledge to navigate the challenges of the crisis ahead; 21
Whereas, Cornell’s current Climate Action Plan4 fails to adequately address the urgency of the 22
crisis, as it lacks the bold, comprehensive measures needed to mitigate the immediate and long-23
term impacts of climate change on the university and broader community; 24
1 IPCC reports alarming warming throughout all regions across our planet emphasizing the impacts of humans on
environmental degradation and what needs to be done to combat this warming on all levels
2 The average temperature in the New York State region is expected to increase by about 5 to 11 degrees Fahrenheit by
the end of the century. Warmer winters and greater heat stress for animals and crops will increase production costs.
3 Cornell’s sustainability assessment score is disproportionately high compared to its initiated actions
4 Cornell’s current climate action plan states that they “aspire to create best practices by demonstrating scalable low-
carbon solutions on campus, advancing climate literacy and research initiatives, and accelerating impact through
Page 2 of 4
Whereas, prioritizing decarbonization in all future construction projects, reducing the demand 25
for energy and resources, actively revising campus policies to avoid high-carbon activities, and 26
ensuring all new construction undergoes rigorous oversight and certification under Leadership in 27
Energy and Environmental Design (LEED)5 standards are critical measures Cornell must 28
undertake; 29
Whereas, ensuring low-carbon, plant-based dining options, food waste donations, and 30
composting program expansion should be prioritized in dining halls to combat the annual 800 31
tons of food scraps6 and organic kitchen waste generated by Cornell dining halls and cafés, 32
promote environmentally friendly consumption habits, and align operations with climate goals; 33
Whereas, establishing additional composting drop-off sites in high-density student areas, such as 34
Collegetown, Hasbrouck Apartments, and Pleasant Grove Apartments, in partnership with the 35
Tompkins County Solid Waste Department, could further increase student participation in 36
composting, reduce organic waste sent to landfills, and support broader waste diversion efforts; 37
Whereas, students call for leadership that prioritizes climate initiatives at the forefront, as was 38
the case with past university presidents7 highlighting the need to appoint a full-time president 39
who prioritizes environmental issues on campus and in the greater Ithaca community, and to 40
enact broader institutional changes at the highest levels of university governance, including 41
expanding the Office of Sustainability, assigning a high-level administrator to promote climate 42
actions on campus, and establishing regular meetings between senior administrators and a 43
student climate advisory committee to ensure sustained and focused leadership on climate action; 44
Be it therefore resolved, Cornell University should adopt the following actions to enhance its 45
Climate Action Plan and fulfill its obligation to its students, community, and global leadership 46
role: 47
1. Leadership Commitment: Seek a full-time university president committed to addressing 48
campus and community environmental issues, ensuring that sustainability remains a core 49
institutional priority. 50
collaborative partnerships locally and globally.” Locally, they are committed to reducing Ithaca campus’ carbon
emissions to net zero by 2035, creating a living laboratory for low-impact behaviors, climate education, and research.”
5 LEED, a globally recognized rating system for measuring the sustainability of a building, is emphasized as an important
piece of consideration among Cornell’s construction initiatives, Cornell must maintain cooperation of these
requirements
6 Cornell currently generates tons of food waste that should get sent to compost sites or food donation programs.
7 In 2007, Cornell’s president sent out a statement emphasizing his goals as president to focus on Cornell’s climate
initiatives and other environmental initiatives
Page 3 of 4
2. Accelerate Decarbonization: Commit to halving carbon emissions (rather than net zero) 51
by 2030, and rapid decreases towards zero after that, integrating robust decarbonization 52
and resource consumption reduction strategies across all new campus construction and 53
existing infrastructure, without relying on offsetting. 54
3. Restructure for Low-Carbon Living: Actively shift campus policies and infrastructure 55
away from high-carbon activities while encouraging low-carbon alternatives, particularly 56
in dining, transportation, and housing.8 57
4. Expand Dining Sustainability: Expand low-carbon footprint meal options in dining 58
halls, strengthen food waste donation programs, and expand composting initiatives for 59
Cornell eateries and dense student living areas to minimize environmental impact. 60
5. Accurate Emissions Reporting: A comprehensive emissions baseline inventory should 61
include all significant emission sources, such as methane, to guide equitable and science-62
based climate goals.9 63
6. Advocate for Climate Equity: Mobilize academic and community resources to drive 64
climate resilience, prioritizing the voices of frontline and Indigenous communities in 65
adaptation efforts. 66
Be it further resolved, Cornell University and the Office of Student Government Relations 67
should commit to advocating for systemic legislative action and inspiring other institutions to 68
address the climate crisis with urgency (e.g. enhancing energy efficiency in various campus 69
operations or funding and supporting research specifically searching for climate solutions). 70
Be it finally resolved, Cornell University should affirm its responsibility to lead transformative 71
shifts toward climate justice, ensuring students’ rights to a habitable future while protecting the 72
community from the far-reaching impacts of inaction. 73
Respectfully Submitted, 74
Marissa Brucker ’26 75
8 Intensive air travel is incompatible with maximum emissions reduction plans, yet Cornell continues to lobby for
expansion of the Ithaca airport, which climate scientists have advised against. Viable land public transportation is
essential to reducing unnecessary emissions from car travel, yet Cornell fails to provide adequate support for the TCAT
bus system. Cornell students compose 75% of ridership, yet the university only makes up 33% of TCAT’s annual
budget, which has forced the company to cut routes, which harms the larger Ithaca community–to which Cornell does
not support in tax dollars.
9 Current Cornell Baseline Emissions reporting lists methane usage separately from total carbon emissions, which allows
them to simultaneously condemn natural gas usage, and makes it appear they emit less than they do by using methane.
Cornell has also used this split reporting to claim that they are making more progress towards their climate goals than
they are.
Page 4 of 4
Member, Environmental Committee, Student Assembly 76
Jenna Saevitzon ‘25 77
Member, Environmental Committee, Student Assembly 78
Sierra Burror ‘25 79
Member, Environmental Committee, Student Assembly 80
Adam Vinson ‘25 81
Executive Vice President of the Student Assembly 82
Lydia Blum ‘27 83
College of Agriculture and Life Sciences Representative, Student Assembly 84
Eeshaan Chaudhuri ‘27 85
Brooks School of Public Policy Representative, Student Assembly 86
Christian Tarala ‘27 87
Nolan School of Hotel Administration Representative, Student Assembly 88
Eric Yao ‘27 89
Undesignated Representative At-Large, Student Assembly 90
From: Lindsay Lustick Garner
Sent: Tuesday, April 22, 2025 2:14 PM
To: Marty Moseley
Cc: Debby Kelley
Subject: Re: Town of Ithaca Zoning Board of Appeals
Hi Marty,
I emailed Judy this morning and since I didn't hear back I called to follow up.
Judy is out of the office for a conference.
I emailed Susan last night asking since the decision was prior to my term if the suit would
require the involvement of the ZBA at the time of the decision. It seems it would include the
current ZBA.
I am not looking to continue my obligations due to the additional time commitment
effective immediately.
Regretfully,
Lindsay Lustick Garner
Licensed Real Estate Broker
Linz Real Estate
Cell Phone: 607-227-7456
Fax: 607-533-4238
Email: linzallo@hotmail.com
WWW.LINZREALESTATE.COM
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May 12, 2025
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Retention: Permanent
1. Kaufman Resignation
2. Flood Damage Local Law GML
3. NYS DOT Investigation School Speed Limit Extension Request
4.
Retention: Six-Year
1.
2.
1.
2.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
COMMISSIONER
Katherine Borgella
DEPUTY COMMISSIONER
M. Megan McDonald
121 E. Court St, Ithaca, N.Y. 14850 | Phone: (607) 274-5560 | tompkinscountyny.gov/planning
Creating and implementing plans that position Tompkins County communities to thrive.
May 2, 2025
C.J. Randall, Director of Planning
Town of Ithaca
215 North Tioga St.
Ithaca, NY 14850
Re: Review Pursuant to §239 -l, -m and -n of New York State General Municipal Law
Proposed Action: Flood Damage Prevention Local Law
Dear C.J. Randall:
This letter acknowledges your referral of the proposed action identified above for review by the
Tompkins County Department of Planning and Sustainability pursuant to §239 -l, -m and -n of the New
York State General Municipal Law.
We have determined the proposed action will have no significant county-wide or inter-community impact.
We look forward to receiving notification on the final action taken by your municipality within 30 days of
decision, as required by State law.
Sincerely,
Katherine Borgella, AICP
Commissioner of Planning and Sustainability
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May 29, 2025
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2.
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Retention: Six-Year
1.
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1.
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TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.town.ithaca.ny.us
CORRESPONDENCE LISTING
June 9, 2025
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Retention: Permanent
1. Resident – ESD Park and Parking Tickets
2.
3.
4.
Retention: Six-Year
1. NYS DOT Designation of Restricted Highway
2. 2025 BP Drinking Water Report
3. Lifelong 2024 Annual Report
4.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
This is linked on the
website for viewing
1
Paulette Rosa
From:Paulette Rosa
Sent:Tuesday, May 13, 2025 8:13 PM
To:Alex Feinberg
Subject:Re: Contact from website
Categories:Paulette
The posting and ticketing is a way to protect the town on liability issues. We are trying to provide a small
place to relax, first come first served. We cannot stop ticketing, although I am not aware of any instance
where we asked for it. The law or rules are the rules, and we can't ignore people who break them that
may then have an incident.
The town has many recreational trails and financially supports some City efforts, but lake frontage is
scarce, and what there is must be enjoyed safely and under NYS regulations ensuring that safety.
We do not get reports or any info on ticketing, but the sheriffs office started a dashboard that may give
that information or you could FOIL it I suppose.
Paulette
Get Outlook for iOS
From: Alex Feinberg <alexandernfeinberg@gmail.com>
Sent: Tuesday, May 13, 2025 2:56 PM
To: Paulette Rosa <PRosa@townithacany.gov>
Subject: Re: Contact from website
**WARNING** This email comes from an outside source. Please verify the from address, any URL
links, and/or attachments. Any questions please contact the IT department
Thank you for the information. Given that people swim there and park along the road anyways and are
unlikely to stop, giving out tickets feels like a recipe for exploitation and unfriendly interactions between
the police and civilians.
On Tue, May 13, 2025 at 2:42 PM Paulette Rosa <PRosa@townithacany.gov> wrote:
Good Afternoon,
The No Parking legislation along State Route 34 was requested and approved by the State and signs installed
last year based upon safety concerns involved with parking on that road including: infringing on site distance
views for cars entering or exiting driveway(s) and the ability to see people attempting to cross the road and the
narrowing of the traveling portion of the road when cars are parked along the side, also limiting any pedestrian
path along the road when needed and the availability of a "break down" area when needed.
There is also not supposed to be any swimming there, also posted, but it happens, and people could be ticketed
for that, again, due to safety concerns and NYS law.
We are aware this is a very small sized town park; there is nothing we can do about that given there is no open
space on the lake, that I am aware of, and even if there were, the price would probably be prohibitive.
2
Stewart Park is very close by with ample parking to enjoy the view and breeze off the Lake and I believe
TCAT has begun their multiple trips to Taughannock State Park for swimming and more.
Regards,
Paulette Rosa
Town Clerk
From: Town of Ithaca Contact Form
Sent: Tuesday, May 13, 2025 10:07 AM
To: Town Of Ithaca Clerks Department
Subject: Contact from website
**WARNING** This email comes from an outside source. Please verify the from address, any URL
links, and/or attachments. Any questions please contact the IT department
Alexander Feinberg Left a comment for your department. If you reply to this message it will be sent to:
alexandernfeinberg@gmail.com
This message was sent as Feedback inquiry.
Message follows:
Hi!
I was at East Shore Park yesterday (May 12), and, as is often the case on beautiful warm days, the
parking lot was full. Seeing a number of cars parked along East Shore Drive, I parked on the side of the
road, as I have in the past when the parking lot is full. There are no parking signs there, but I have never
received a ticket in the past, and I often see cars parked along that stretch. At around 1:30PM the sheriff
came by and asked anyone who was parked along the road to move their car or face getting a ticket. He
said they'd gotten a call. Since the cars along the road were not blocking traffic or causing a
disturbance, I imagine probably a nearby resident had called, upset that East Shore Park is not their own
personal property. The park is a popular spot, and one of the few areas on the lake near town that is
public. The parking lot is not large enough to accommodate the amount of people who want to use the
park. I think it's unfair to penalize people who want to be at the lake and parking isn't available.
Thank you!
CORRESPONDENCE LISTING
June 23, 2025
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Retention: Permanent
1. Letter of Map revision NYS
2.
3.
4.
Retention: Six-Year
1.
2.
3.
4.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
✓
al Emergency Management Agency
Washington,D.C.20472
June 11,2025
19-02-0019V
Town of Ithaca,
Tompkins County,NY
360851
June 19,2025
Case No.
Community:
The Honorable Rod Howe
Supervisor,Town of Ithaca
215 North Tioga Street
Ithaca,NY 14850 Community No.
Effective Date
LOMC-VALID
Dear Supervisor Howe:
On June 18,2025,the Department of Homeland Security’s Federal Emergency Management
Agency (FEMA)issued new or revised Flood Insurance Rate Map (FIRM)panels within your
community.This letter identifies the Letter of Map Change (LOMC)actions [i.e.,Letters of Map
Amendment (LOMAs)and Letters of Map Revision-based on Fill (LOMR-Fs)]for properties
and/or structures located in your community that are still valid as of the effective date shown
above.Any revalidation letters previously issued for your community have been superseded as of
the effective date listed above.
All effective LOMCs within your community have been reviewed,including LOMCs located in
areas not revised during this FIRM update.LOMAs and LOMR-Fs for which the original
determination has not been superseded by new or revised information will remain in effect until
superseded by a subsequent LOMC or by a revision to the FIRM panel on which the property
and/or structure is located.
The enclosed table lists the FEMA case number,issue date,project identifier,and FIRM panel
number for the LOMCs revalidated by this letter.Please refer to the original determination
document to obtain the details of the outcome for the properties and/or structures included in
the determination (such as flood zone,base flood elevations,property elevations,etc.).
Letters of Map Revision (LOMRs)previously issued for FIRM panels that were revised by the
recent map update for your community have either been incorporated into the revised FIRM or
have been superseded by the revised FIRM.LOMRs issued for FIRM panels that were not
revised by the recent map update for your community are not included on the enclosed table and
will remain in effect until superseded by a revision to that FIRM panel.
If there is a LOMC not on the enclosed list that you feel should have been revalidated,we
encourage you to submit the LOMC for re-determination.When requesting a re-determination,
we ask that a cover letter be sent along with a copy of the original determination letter to:LOMC
Clearinghouse,3601 Eisenhower Avenue,Suite 500,Alexandria,VA 22304-6426.
Re-determinations may also be requested online at https://www.fe ma.gov/online-lomc.
Page 1 of 3
Because these revalidated LOMCs will not be reprinted or distributed to primary map users,such
as local insurance agents and mortgage lenders,your community will serve as a repOsitoiy for this
information.We encourage you to disseminate the information reflected by this LOMG-VALID
letter throughout your community so that interested persons,such as property owners,local
insurance agents,and mortgage lenders,may benefit from the information.
Copies of previously issued LOMCs,if needed,may be obtained from your community’s map
repository,FEMA’s Map Service Center website located at https://msc.fema.gov,or by contacting
the FEMA Mapping and Insurance exchange (FMIX),toll free,at 1-877-FEMA-MAP (1-877-336-
2627).
For additional information or questions relating to LOMCs not listed on the enclosed table,or
mapping in general,please contact the FMIX at the number provided above.
Sincerely,
David N.Bascom,Acting Director
Engineering and Modeling Division
Risk Analysis,Planning and Information Directorate
LOMC Subscription Service Subscribers
Community Map Repository
Marty Moseley ^,Director of Code Enforcement,Town of Ithaca
cc:
Page 2 of 3
'\l
REVALIDATED LETTERS OF MAP CHANGE FOR TOWN OF ITHACA,NY
Community No.:360851CaseNo:19-02-0019V
June 19,2025
Date Issued IdentifierCaseNo.FIRM Panel Number
09-02-0816A 4/7/2009 853 Taughannock Road 36109C0184D
5/4/201111-02-1419A 885 Taughannock Road 36109C0184D
':5/ft/201111-02-1320A '883 taughannock Boulevard 36r09C0r84D-
11-02-2007A 7/13/2011 887 Taughannock Boulevard 36109C0184D
15-02-1196A 5/8/2015 Taughannock Blvd 36109C0184D
7/25/2016 1022 EAST SHORE DRIVE 36109C0182D16-02-1502A
21-02-0943A 6/7/2021 904 East Shore Drive 36109C0184D
361O9GO203D
9/10/2021 36109C0204D21-02-1 r68A 229 FOREST HOME DRIVE
23-02-0361A 4/17/2023 847 Taughannock Boulevard 36109C0184D
1
23-02-0666A 7/26/2023 835 Taughannock Boulevard 36109C0184D
.y
Page 3 of 3
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July 14, 2025
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Retention: Six-Year
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TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.town.ithaca.ny.us
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July 28, 2025
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Retention: Six-Year
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TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.town.ithaca.ny.us
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August 11, 2025
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TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.town.ithaca.ny.us
1. School Speed Zone Extension Request – Winthrop Dr - Denied
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TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
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August 25, 2025
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1.NONE
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September 8, 2025
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TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.town.ithaca.ny.us
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TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
1. NYSDEC Municipal Coalition Letter
PH notice re Carrowmoor Solar from IAD
Letter of Thanks for Supplies from Town of Richmondville
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September 29, 2025
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Intermunicipal Wastewater Agreement Partners
c/o Rod Howe, Supervisor
Town of Ithaca
215 North Tioga Street
Ithaca, NY 14850
Via US Mail, and Email as available
Carol Lamb-Lafay
Acting Deputy Commissioner
Water Resources
NYSDEC
625 Broadway, 4th Floor
Albany, NY 12233
Dear Acting Deputy Commissioner Lamb-Lafay,
We write collectively as the elected leadership of the six municipal signatories to the 2003
Intermunicipal Wastewater Agreement, who are either owners of, or wastewater
contributors to, the Ithaca Area Wastewater Treatment Facility (IAWWTF). Having been
authorized by our respective legislative bodies to do so, we hereunder state our strong
opposition to the SPDES permit modifications proposed by NYSDEC on the grounds that
the assumed violations they are designed to mitigate have not been proven to exist, as
required by the TMDL process outlined in NYSDEC technical guidance, and that the
unprecedented costs associated with compliance would be financially burdensome to our
ratepayers while yielding little to no environmental benefit. We encourage the Department
to focus the State’s limited resources on mitigating the proven phosphorus and sediment -
related impairments that have been apparent for decades but that continue to persist.
Background
The Ithaca Area Wastewater Treatment Facility (IAWWTF) located at the south end of
Cayuga Lake is a 13.1 million gallons -per-day (MGD) capacity treatment plant owned and
operated by the City of Ithaca, the Town of Ithaca and the Town of Dryden. The facility also
receives sewer flow indirectly from the Village of Cayuga Heights, the Village of Lansing,
and the Town of Lansing.
IAWWTF owners are currently developing a long-term capital improvement project (CIP).
As originally envisioned, owners expected to retain conventional biological treatment,
while focusing on modernization and replacement of aged and failing infrastructure. The
preliminary estimate of costs related to capital improvements ranged from 60 and 100
million dollars, depending on the chosen design. Costs will be divided among owners,
based on predetermined share, with a portion offset by anticipated water quality
improvement grants. Some of the costs will eventually be proportionally passed through to
non-owner users via independently negotiated agreements.
Proposed Permit Modifications and Costs
Without any corroborative ambient water quality sampling, biological sampling, evaluation
of point and non-point sources, or scientific analysis of the assimilative capacity of the
receiving water, NYSDEC is now proposing to add SPDES permit limitations for ammonia
and nitrite, based on limited effluent data and devised using numerical standards that are
designed to ensure the “protection of aquatic life.” However, the membrane bioreactor
technology required to meet the proposed permit limits would add 100 million dollars to
the project cost, which would have an enormous, unsustainable, and unjustifiable impact
on ratepayers in the stakeholder municipalities for decades to come.
NYSDEC Technical Guidance Requires a Wholistic Pollution Control Approach
The technical guidance document cited by permit writers to underpin the Water Quality
Based Effluent Limitations (WQBEL) for nitrite and ammonia (“TOGS 1.3.1”) specifies that
WQBEL permit limits must be devised in conjunction with a TMDL process similar to the
one that was recently completed for phosphorous. By any plain reading, that process
must quantify the sources of ammonia and nitrite in the south segment of the lake (an
approximately 1.4 square-mile area south of McKinney’s Point) and determine the
segment’s ability to assimilate the substances proposed for limitation. Only then could an
alleged violation be confirmed or disproven, sources identified, and mitigation strategies
appropriately weighted.
The aforementioned TMDL for ammonia and nitrite has not been undertaken, nor
contemplated, by NYSDEC, and any analysis that relies on additional segmentation of the
lake runs counter to the Department’s own guidance for waterbody segmentation. The
“Consolidated Assessment and Listing Methodology,” published in 2023, provides a
regulatory framework for waterbody segmentation. It specifically states that “Some very
large lakes, like Lake Champlain and the Finger Lakes are segmented in multiple
assessment units based on classification.”
NYSDEC does not propose a change in “classification” in the waters surrounding the
mixing zone. Instead it proposes a tiny new waterbody segment immediately surrounding
the zone, and appears to be contending that the TMDL process was followed for the newly
created zone. Similarly, the “reasonable potential analysis” relied upon by NYSDEC in its
SPDES Permit Fact Sheet to indicate that statistical modeling is potentially predictive of a
violation, is itself part of the TMDL process, not a substitute for one. TOGS 1.3.1 plainly
states that “The TMDL process… provides the basis for a "reasonable potential"
analysis; that is, does the proposed discharge of a pollutant have the reasonable potential
to cause or contribute to an excursion of water quality standards . If the answer is "yes",
the TMDL process is then used to determine the WǪBELs for all sources of that pollutant
to assure compliance with water quality standards.”
On a macro level, NYSDEC specifically dismissed nitrogen (nitrate) as a primary cause of
impairment in Cayuga Lake as recently as 2024 in its TMDL for phosphorus, and did not
make any recommendations regarding ammonia or nitrite. Coming to a statistically-based
conclusion that anything short of complete nitrification at a wastewater treatment plant
equals a water quality standards violation does not demonstrate that an applicable
narrative best-use-based standards violation exis ts.
As mentioned, the proposed permit limits are being devised with the objective of “the
protection of aquatic life.” However, there has been no corroborative biological
monitoring nor anecdotal evidence to suggest that organisms are under stress outside the
mixing zone (which, itself, has not been delineated). To the contrary, available data
indicates that annual inventories at the Cayuga Inlet fish ladder have not decreased in
population or size, and angler surveys show extremely high satisfaction with fishing in the
lake. In addition, synoptic dissolved oxygen sampling at four south -segment locations
analyzed over the past 15 years by Community Science Institute reveals that levels in the
south lake are quite high (approaching 9 mg/l) and consistent throughout the segment,
displaying no localized variation or decline at the point-source discharge monitoring
locations, generally indicating an overall healthy environment for aquatic life.
The assumptions underpinning the Department’s proposed modifications are particularly
concerning because they are purely theoretical and based on hypothetical variables such
as a dilution ratio and mixing zone dimensions that not only cannot be traced to t heir
mathematical origins, but have likely not been revisited since IAWWTF was rerated from 10
MGD to 13.1 MGD. It is not clear how NYSDEC would spatialize a new waterbody segment
surrounding a mixing zone without first delineating the shape or boundaries of the zone
through any quantifiable scientific processes.
Past Research Supports Retaining Conventional Treatment Technology
IAWWTF owners commissioned a comprehensive study in the mid-80’s to determine
whether its then-redesigned discharge would result in harmful levels of ammonia outside
the mixing zone. The study, conducted by Environmental Scientist, Liz Moran, concluded
that, “The analysis demonstrates that even under ‘worst case’ conditions, the
concentrations of un-ionized ammonia in the south end of the lake will not create toxic
conditions for fish outside of an acceptable mixing zone. Therefore, the new lake outfall of
the upgraded and rebuilt Ithaca Area Wastewater Treatment Facility is not creating
unacceptable water quality conditions."
Subsequent to the study, the plant was rerated from 10 MGD to 13.1 MGD. It is likely that
current mixing zone and dilution assumptions have not been adjusted to account for the
increase in maximum allowable flow. However, with the exception of phosphorus (which
has been greatly reduced), IAWWTF effluent parameters are similar to those that existed
during Ms. Moran’s study period. Therefore, it is reasonable to conclude that her general
findings are worth investigating today.
Conclusion
IAWWTF owners and users wholly support efforts to maintain and improve water quality in
Cayuga Lake. To that end, IAWWTF owners voluntarily invested in tertiary phosphorus
treatment in 2003, long before the TMDL for phosphorus was developed, and area
municipalities continue to collaborate to utilize vital wastewater infrastructure in an
efficient, regional approach. We urge the Department to avoid high cost-benefit-ratio
regulatory practices that would inadvertently disincentivize regional wastewater
management and encourage the proliferation of septic systems and sprawl development.
Municipalities and ratepayers encourage the efficient use of resources to advance the
goals of the TMDL for Phosphorus in Cayuga Lake, including the establishment of riparian
buffers, streambank stabilization, and greater investment in agricultural best management
practices. Given the enormous cost and questionable environmental benefit of the
potential permit modification, stakeholders will continue to advocate for the prioritization
of solving the problems that were quantified and published by NYSDEC foll owing decades
of research, and oppose the diversion of finite assets to address issues that have either
not been identified, not been confirmed, or were dismissed outright as non -problematic
during the development of the phosphorus TMDL. We urge NYSDEC to abide by its most
comprehensive regulatory procedures, which were created to ensure implementation of,
and compliance with, state and federal environmental law.
NYSDEC must determine whether the IAWWTF discharge is causing or contributing to
water-quality standards violations related to ammonia and nitrite by following its own
TMDL process. A permit modification with a price tag of 100 million dollars, based solely
on theoretical modeling in the absence of field corroboration, mandated while known
impairments continue to go unaddressed, is environmentally questionable and financially
prejudicial, particularly to the many disadvantaged and underserved communities reliant
on lAWWTF.
We look forward to collaborating on thorough, sensible solutions that balance evidence-
based regulatory practices with real-world financial realities and implementation
constraints.
Respectfully,
Robert Cantelmo, Mayor
City of Ithaca
Date:
Linda Woodard, Mayor
Village of Cayuga Heights
Date:
Rod Howe, Supervisor
Town of Ithaca
Ronny Hardaway, Mayor
Village of Lansing
Date:
Jason Leifer, Supervisor
TownofDryden
Date:Date:
Ruth Groff, Supervisor
Town of Lansing
Cc;
Amanda Lefton, Commissioner, NYSDEC
Anthony Luisi, Deputy Commissioner and General Counsel, NYSDEC
Dereth Glance, Director, NYSDEC Region 7
Monica Moss, Section Chief, North Section, NYSDEC
Thomas Vigneault, Water Resources Specialist, NYSDEC Region 7
The Honorable Anna Kelles, Assemblymember; 125^^ Assembly District
The Honorable Lea Web, New York State Senator, 52"^ Senate District
The Honorable Kathy Hochul, Governor of New York State
prejudicial, particularly to the many disadvantaged and underserved communities reliant
on IAWWTF.
We look forward to collaborating on thorough, sensible solutions that balance evidence-
based regulatory practices with real-world financial realities and implementation
constraints.
Respectfully,
_________________________Date:________
Robert Cantelmo, Mayor
City of Ithaca
_________________________ Date:________
Rod Howe, Supervisor
Town of Ithaca
_________________________ Date:________
Jason Leifer, Supervisor
Town of Dryden
_________________________ Date:________
Linda Woodard, Mayor
Village of Cayuga Heights
_________________________ Date:________
Ronny Hardaway, Mayor
Village of Lansing
_________________________ Date:________
Ruth Groff, Supervisor
Town of Lansing
Cc;
Amanda Lefton, Commissioner, NYSDEC
Anthony Luisi, Deputy Commissioner and General Counsel, NYSDEC
Dereth Glance, Director, NYSDEC Region 7
Monica Moss, Section Chief, North Section, NYSDEC
Thomas Vigneault, Water Resources Specialist, NYSDEC Region 7
The Honorable Anna Kelles, Assemblymember, 125th Assembly District
The Honorable Lea Web, New York State Senator, 52nd Senate District
The Honorable Kathy Hochul, Governor of New York State
09/20/25
CORRESPONDENCE LISTING
October 6, 2025
Please review the following correspondence and indicate, by placing your initials in the right -hand column
adjacent to the correspondence, that you wish to receive a copy. We can forward a copy to you via e-mail or
make a hard copy. Please indicate your preference next to your name at the bottom of this form.
Correspondence – Item Please place your
initials here if you wish
to receive a copy
Retention: Permanent
1. Land Trust Letter
2.
3.
4.
Retention: Six-Year
1.
2.
1.
2.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.town.ithaca.ny.us
Finger Lakes Land Trust
202 EAST COURT STREET • ITHACA, NEW YORK 14850 • WWW.FLLT.ORG
P {607} 275-9487 F (607) 275-0037 EINFO@FLLT.ORG
September 29, 2025
Rod Howe, Town Supervisor
Joseph Talbut, Parks Maintenance Manager
Town oflthaca
215 North Tioga Street
Ithaca, NY 14850
Dear Mr. Howe and Mr. Talbut;
On September 18, 2025, my co-worker, Margaret Royal], FLLT Conservation Easement
Steward, conducted the annual monitoring of the Town of Ithaca's Pine Tree Wildlife Preserve
(located along the East Hill Recreation Way, adjacent to the East Ithaca Nature Preserve), subject to
a conservation easement granted to the Finger Lakes Land Trust.
During the visit, Margaret noted routine trail maintenance. She said you have a new volunteer
who IS clearing invasives, which has been on your project list for some time. Otherwise, she did
not observe any changes in property use or issues of concern.
Best wishes for the fall, and please feel free to contact me if you have any questions about the
conservation easement or plans you may have for the property.
Sincerely,
Hailey Nase, Conservation Easement Stewardship Manager
TO CONSERVE FOREVER THE LANDS AND WATERS OF THE FINGER LAKES REGION,
ensuring scenic vistas, heal foods, clean water, and wild places for everyone
CORRESPONDENCE LISTING
October 27, 2025
Please review the following correspondence and indicate, by placing your initials in the right-hand column
adjacent to the correspondence, that you wish to receive a copy. We can forward a copy to you via e-mail or
make a hard copy. Please indicate your preference next to your name at the bottom of this form.
Correspondence – Item Please place your
initials here if you wish
to receive a copy
Retention: Permanent
1. NONE
2.
3.
4.
Retention: Six-Year
1.
2.
1.
2.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.town.ithaca.ny.us
CORRESPONDENCE LISTING
November 10, 2025
Please review the following correspondence and indicate, by placing your initials in the right-hand column
adjacent to the correspondence, that you wish to receive a copy. We can forward a copy to you via e-mail or
make a hard copy. Please indicate your preference next to your name at the bottom of this form.
Correspondence – Item Please place your initials
here if you wish to receive a
copy
Retention: Permanent
1. Resident Comment – Verizon Agreement
2. Resident Comment - Verizon Agreement
3. Resident Comment – Verizon
4.
Retention: Six-Year
1. Town of Ulysses PH Notice
2.
3.
4.
TOWN OF ITHACA
215 NORTH TIOGA STREET, ITHACA, N.Y. 14850
www.townithacany.gov
1
Paulette Rosa
From:CJ Randall <cjrandall@townithacany.gov>
Sent:Monday, October 27, 2025 3:29 PM
To:Town Of Ithaca Clerks Department
Subject:Fw: Verizon agreement is based on false information!
Attachments:Robert Berg, esq letter to the Town of Ithaca.pdf
I assume you may have received this from a Town Board member already, but just in case —
From: Andrew J. Molnar <andrewmolnar11@gmail.com>
Sent: Monday, October 27, 2025 3:19 PM
To: Rich Depaolo <rdepaolo@townithacany.gov>; Rod Howe <RHowe@townithacany.gov>; Pam Bleiwas
<pbleiwas@townithacany.gov>; Margaret Johnson <MJohnson@townithacany.gov>; Eric Levine
<elevine@townithacany.gov>; Rob Rosen <RRosen@townithacany.gov>; Susie Gutenberger
<SGutenberger@townithacany.gov>
Cc: aknauf@nyenvlaw.com <aknauf@nyenvlaw.com>; Chris Balestra <CBalestra@townithacany.gov>; CJ
Randall <cjrandall@townithacany.gov>
Subject: Verizon agreement is based on false information!
**WARNING** This email comes from an outside source. Please verify the from address, any URL
links, and/or attachments. Any questions please contact the IT department
Town Board,
I was extremely disheartened and angered to hear today of a secret settlement that the Town has negotiated with Verizon
to build a monstrous cell tower, against the overwhelming will of the public and the vote of the Zoning Board. This secrecy
and subsequent short notice has inhibited your citizens from consulting with our own lawyers. But, what I do know is that
you can deny this tower, based on 2 facts.
1. As the Zoning Board discussed, no "significant gap" has been proven (despite Verizon asserting this in the
court document). As we showed earlier this year, the FCC wireless coverage maps themselves, the authority
of coverage in this country, show that there is widespread coverage in the area of the proposed tower. The
FCC maps show, and local residents attest, there is NO GAP IN THIS AREA. If you look at the FCC map for the
area of the proposed tower in Ithaca, THEY HAVE 100% COVERAGE FOR 4G IN JUST ABOUT THE ENTIRE
AREA! This is the case both for 'outdoor stationary' AND 'in vehicle mobile' (though, to be clear, federal law does
not mandate constant coverage within vehicles) This is what I understood to be a reason that the Zoning Board
denied the tower.
Here is the FCC map: https://broadbandmap.fcc.gov/location-
summary/fixed?version=jun2024&location_id=fa27ba84-9346-43aa-9d02-
da5625c71ee5&addr1=1022%20ELLIS%20HOLLOW%20RD&addr2=ITHACA,%20NY%2014850&zoom=4
&br=r&speed=100_20&tech=1_2_3_4_5_6_7_8
Simply click on the "Mobile Broadband" tab on the right, and click on the check mark next to Verizon under
"4G LTE". It will turn green and show you the near coverage all around the area (screenshots below). The
purple hexagons show the coverage area for Verizon.
Keep in mind, federal law does not guarantee coverage for 5G services - only to provide phone service, which they
clearly have. If there's enough network coverage to make and receive cell calls, there's no significant gap in
coverage even if the carrier wants to increase its capacity or to improve the network's ability to transmit data. In
2
other words, just because they might have some 5G deficiencies, this does not constitute grounds to build
another antenna under federal law.
Because there is no gap, there is no public necessity for this tower, and thus Verizon's claim that the town has
failed to apply the "public necessity standard" is just legal misdirection and manipulation.
2. Regardless of the existence of non-existence of any service gaps, court decisions have been clear that any
town has the right to deny a tower based on aesthetics and/or property value concerns. So, Verizon's
manipulation here is against the law.
Verizon is simply trying to bully you with lies and force to do their will. I urge you to be courageous and vote down this
negotiation tonight. Minimally, I ask you to postpone any decision until we can have time to consult with our lawyers and
assist the Town with its defense.
Andrew Molnar
PS: According to the law, the Town is not responsible for paying attorneys' fees for the plaintiff. From our attorney:
"A wireless carrier can never sue for
and recover from a municipality monetary damages or attorneys' fees if the municipality refuses to allow the carrier to
build and operate a requested wireless communications facility, even if a
court eventually decides the municipality actually has violated the TCA. As to the latter point, the United States Supreme
Court has expressly held, in City of Rancho Palos Verdes v.
Abrams, 544 U.S. 113 (2005), that neither monetary damages nor attorneys' fees are available to a prevailing plaintiff in
an action brought under the TCA. So even if Verizon
does sue the Town in federal court for denying final site plan approval and a special use permit -- and the Town somehow
loses that lawsuit -- the Town can never be liable for monetary damages
or Verizon's attorneys' fees. The worst that could happen is that the Town would be required to grant final site plan
approval and to issue the special use permit for the project. Any fears or
implied threats that a wireless carrier will bankrupt the Town through litigation if the Town denies a permit for a wireless
communications facility are completely baseless."
PPS: Our attorney also refutes Verizon’s use of the Rosenberg case to bolster their case. See attached letter.
Law Office of Robert J. Berg PLLC
19 Carriage House Lane
Mamaroneck, New York 10543
(914) 522-9455
robertbergesq@aol.com
October 28, 2024
Members of the Planning Board
Fred Wilcox, Chair
Caitlin Cameron, Vice Chair
William Arms
Elizabeth Bageant
Cindy Kaufman
Sara Reynolds
Gary Stewart
Alternate member, Kelda McGurk
Town of Ithaca
215 N. Tioga Street
Ithaca, New York 14850
Attention: Christine Balestra, Senior Planner (cbalestra@town.ithaca.ny.us)
Re: Bell Atlantic Mobile Systems, LLC, d/b/a Verizon Wireless -
Application for Cell Tower Special Use Permit and Site Plan
Approval on Property Located at 111 Wiedmaier Court (Tax
Parcel No. 56.-4.1.22) in the Town of Ithaca ("Sunny View" Site)
Dear Chairman Wilcox and Honorable Members of the Town of Ithaca Planning Commission:
Introduction
I am the attorney for Ithacans for Responsible Technology and certain Town of Ithaca
residents and property owners, most of whom live in close proximity to 111 Wiedmaier Court,
the so-called "Sunny View" site on which Bell Atlantic Mobile Systems, LLC, d/b/a Verizon
Wireless ("Verizon"), proposes to construct and operate a 138-foot tall monopole cell tower
(including a four-foot tall lightening rod, nine associated antennas and equipment) in a proposed
50 foot by 50 foot compound. This site is on a private lot owned by S Roberts WC Land LLC.
This lot is located in a Medium Density Residential ("MDR") and Conservation ("C") zone.
I have been retained to assist my clients in challenging Verizon Wireless' application.
My clients are not opposed to cell towers generally speaking. Rather, they are opposed to the
irresponsible siting of a tall, unsightly, uncamouflaged industrial cell tower immediately
adjacent (400 feet) to a developed residential neighborhood in a conservation zone such as
2
Verizon is proposing. My letter demonstrates that Verizon has utterly failed to meet its burden of
proof under the Section 270-219 of the Town Code, supported by controlling federal case law in
the Second Circuit, that requires an applicant for a special use permit for a macro cell tower on
private property to (a) establish a significant gap in coverage in its wireless network in the area
where it proposes to site the cell tower; and (b) show that its proposed solution is the least
intrusive technologically feasible means of solving the demonstrated significant gap in coverage.
In summary, I show that Verizon's attorney misleadingly sets up a "straw man" "public
necessity" test for this Planning Board to consider when that test only applies to a Zoning Board
of Appeals' determination of an application for a "use variance," an iss ue which is outside of the
Planning Board's statutory authority and is not even at issue in Verizon's application. Moreover,
I explain that Verizon's RF expert fails to answer meaningfully the Planning Board's request that
Verizon analyze whether two shorter cell towers or other technology could "solve" Verizon's
purported significant coverage gap in place of Verizon's proposed single 138 -foot tall cell tower
at the Sunny View site. Finally, I illustrate one example of Verizon's failure to meet its burden
of proof in establishing that its application meets the criteria for site plan approval and issuance
of a special use permit under Section 270-219 of the Town Code -- I demonstrate that Verizon's
alternative site analysis is based upon a flawed, gerrymandered search area and a wholly
unexplained 1,000' AMSL maximum elevation restriction, and Verizon has rejected the four
alternative sites located therein without providing any detailed RF analysis for any of those sites.
In particular, my clients have asked me to reply to the Response to Planning Board
Comment 2 set forth in the letter from Jared C. Lusk, Esq., of the law firm Nixon Peabody, dated
October 22, 2024, to the Planning Board and the Zoning Board of Appeals on behalf of his client
Verizon. At the Planning Board's October 1, 2024 meeting on this application, the Planning
Board issued two comments to Verizon, and requested that Verizon provide the Board with
responses to those comments. Planning Board Comment 2 s tated:
Please analyze whether reliable service to the Sunny View coverage area can be
accomplished through two (2) shorter, less visible towers rather than the single 134'
tower as proposed or other technology.
In his October 22, 2024 letter, Mr. Lusk responds to Planning Board Comment 2 by
referring to Exhibit GG, a supplemental report from Verizon's RF design engineer, which Mr.
Lusk contends shows that neither two shorter cell towers nor the use of small cells are feasible to
provide reliable coverage to the Sunny View coverage area. That response, whatever its merits,
doesn't fully answer the question posed by the Planning Board. The Planning Board actually
asks a broader question -- whether any "other technology" or two shorter cell towers can provide
reliable service to the Sunny View coverage area rather than the proposed 134 -foot tall cell tower
(plus the four-foot high lightning rod). "Other technology" does exist, including the use of small
cell wireless communications facilities. Indeed, in his Preliminary Report, dated September 20,
2024, William P. Johnson, the Town's independent RF Engineering Consultant, addressed the
variety "of other approaches to deliver wireless communications that could avoid tall towers in a
given area." See Johnson Preliminary Report at Appendix G. Among these "other"
technologies, Mr. Johnson discusses Distributed Antenna Systems ("DAS"), micro cells, and
3
satellite-based systems. The use of these "other" technologies, especially small cell wireless
facilities attached to existing utility poles in the public right of way or on existing buildings, are
growing wildly. Elon Musk's satellite-based Starlink communications network is expanding
explosively and is revolutionizing wireless communications in rural and remote regions. Tall,
ugly, visually intrusive industrial cell towers are fast becoming albatrosses as rapidly developing
less intrusive and effective technologies are being deployed. Verizon's RF designer fails to
address the usability of such technologies, perhaps in conjunction with one or more shorter cell
towers, to "solve" Verizon's purported "coverage gap."
Turning to Verizon's Exhibit GG, the Supplemental Report, dated October 21, 2024,
submitted by Wasif Sharif, Verizon's RF Design Engineer, the report utterly fails to live up to
Mr. Lusk's billing. Mr. Sharif's analysis is entirely general and conclusory. He provides no
specific analysis of any alternative technological means to provide similar RF coverage to the
area purportedly to be served by Verizon's proposed 134-foot tall monopole cell tower at the
Sunny View site. Notably, Mr. Sharif fails to model any scenarios using "two (2) shorter, less
visible towers rather than the single 134' tower as proposed...," despite the Planning Board's
request for such an analysis. Instead, Mr. Sharif summarily dismisses the Planning Board's
perfectly reasonable request, stating: "When compared with a small cell site alternative (or a
cluster of smaller cell sites) in a rural area like this which is subject to significant terrain, large
geographic coverage area, and laced with foliage challenges the small cell coverage capability is
unsuitable. Small cells or smaller macro tower sites would be blocked (shadowed) by terrain and
foliage rendering them ineffective." That's a couple of conclusory statements. Mr. Sharif
provides no detailed engineering or topographic analysis at all. Mr. Sharif performs no modeling
of any possible small cell antenna deployments or of any other existing technologies. Verizon
simply fails to answer the Board's question.
Moreover, the RF engineer's thesis is actually implausible. I respectfully refer the
Planning Board Members to Google Maps and ask that you take a look at the Sunny View site.
Oddly, Verizon's selected site, the Sunny View site, sits at an elevation of only 824.4 feet AMSL
(above mean sea level). Though Verizon touts the need for the tallest possible tower to close its
purported network coverage gap (seeking the widest line of sight covereage), perhaps the chief
problem is that Verizon has selected a site that is 400 feet lower in elevation than nearby sites
north of Slaterville Road (Route 79) on the Eastern Heights or off of Snyder Hill Road. These
sites, just a couple of thousand feet away from the Sunny View site, would offer Verizon
tremendously enhanced line-of-sight coverage and would avoid the problematic, topographically
challenged steep cliffs and gorges from the Ithaca Reservoir northwest to the Second Dam and
towards Wells Falls.
It's hard to believe that a cell tower at the Sunny View site will provide adequate
coverage deep down by the creek bed in the twisty gorge leading to the reservoir. For some
reason, as I discuss below, Verizon's RF engineer has artificially constrained the maximum
AMSL elevation for the tower at 1,000'. There appears to be no Town Code requirement for
4
such an elevation limitation, and the Verizon RF engineer provides no explanation whatsoever --
which is highly suspicious.
Moreover, looking at the satellite image of the area on Google Maps, one sees a vast
higher elevation area north of Slaterville Road (Route 79) up to Snyder Hill Road which is
mostly undeveloped forest or rural land. There is no developed residential neighborhood on
those vast parcels. Further, the Finger Lakes Stone Quarry, an industrial mining site, at an
elevation of 1,200 feet, is present. What a perfect site for a cell tower! -- an existing industrial
quarry at an elevation four hundred feet higher than the Sunny View site.
Given the rural nature of the area -- and the paucity of residential properties in the area
(other than the development immediately adjacent to the Sunny View site) -- the need for a
macro cell tower at the Sunny View site seems dubious. The likely major need for better cell
coverage in this area is for drivers on the two main roads -- Route 79 and Snyder Hill Road. The
forests and fields in the area don't have much need for expanded cell phone coverage. This
strikes me as the perfect situation for using a series of small cell wireless antennas attached to
existing utility poles alongside the two main roads. That "solution" would provide fine cell
coverage for drivers on these roads and to the few residences that exist close to those roads. Of
course, Mr. Sharif never models such a solution.
Mr. Sharif's summary conclusions, with no actual modeling of any other possible
technologically feasible but less intrusive "solutions" to Verizon's putative coverage gap, are
grossly inadequate to meet Verizon's burden of proof on this Application. Respe ctfully, this
Planning Board should have its independent RF expert, Mr. Johnson, opine on this point.
Verizon Misstates the Legal Framework Underlying the Planning Board's
Consideration of the Application
A General Warning to the Planning Board
In the second part of Mr. Lusk's response to Planning Board Comment 2, he provides a
highly misleading analysis of the applicable law which he contends governs the Planning Board's
review of Verizon's permit application. Before I address Mr. Lusk's analysis, I respectfully offer
the Planning Board the following comments. I represent clients across the country who are
trying to protect their families, businesses, and communities from the uncontrolled and unsafe
deployment of wireless communications facilities within their municipalities. The wireless
industry is insatiable in its quest to blanket the entire nation in an endless, willy -nilly sprawl of
cell towers and small cell facilities, and is deaf to the concerns of the residents who live and
work near the industry's desired wireless communications facility sites .
According to statistics published by the Wireless Infrastructure Association on April 16,
2024, at the end of 2023, 153,400 purpose-built macro cell towers were in operation in the
United States. There were 244,800 macrocell sites, and 202,100 outdoor small cells in
5
operation, with 775,800 indoor small cell nodes in use. Verizon, as the largest wireless carrier, is
one of the worst offenders I come across when it comes to the irresponsible siting of cell towers.
Verizon simply doesn’t care what disruption its facilities cause to your community – the
degradation of views, the destruction of property values, the desecration of neighborhood
character, and the public safety dangers its towers pose to nearby persons and property from
icefall, falling debris, fire, and tower collapse.
You have been appointed to the Planning Board to safeguard the lives and properties of
your fellow residents and to protect the future of your Town from development that is
inconsistent with the Town’s Comprehensive Plan and Zoning Code. Your responsibilities under
Section 270 of the Town Code to oversee development in the Town and to ensure that the
Comprehensive Town Plan and Zoning Code are followed with respect to development projects
are very broad and important. Residents of the Town are fortunate that the Town Board had the
wisdom and foresight to enact a comprehensive wireless telecommunications code within the
Town Code that encourages -- yet responsibly regulates -- the placement, design, and
construction of wireless communications facilities within the Town of Ithaca, fully consistent
with the federal Telecommunications Act of 1996 (the "TCA") and State and federal law. See
Section 270-219. Personal wireless service facilities.
As Members of the Planning Board, you have the critical duty and responsibility to
ensure that Verizon has met its burden of proof in meeting the criteria set forth in Section 270-
219 of the Town Code. You sit as a regulatory board when reviewing a site plan and when
considering an application for a special permit. You act as the trier of facts and make factual and
legal determinations based on the evidence and legal arguments presented to you by the
applicant, by the Town's independent consultant, and by residents and other members of the
public, and their attorneys and/or witnesses. Your job is extremely important, and will greatly
impact the lives of your fellow residents and the future development of your town.
The applicant’s proposed 134-foot tall uncamouflaged, industrial cell tower will be a
blight upon the surrounding long-established residential neighborhood. The soaring cell tower
will be a glaring visual intrusion, destroying the rural residential viewshed of the immediate
neighbors, and decimating their property values. The industrial cell tower will be an eyesore to
travelers on adjacent Slaterville Road (Route 79). The cell tower will generate no revenues for
the Town. To suggest, as Verizon does, that the tower presents just a “minimal intrusion” to the
community, is a lie. You have to live here af ter Verizon moves on to desecrate the next
residential neighborhood.
I also warn you that Verizon may well try to intimidate this Board by threatening to bring
an action against the Town of Ithaca in federal court for violation of the TCA should this Board
deny Verizon's application for site plan approval and the special us e permit for its proposed cell
tower at 111 Wiedmaier Court. Verizon makes this threat -- and, indeed, acts upon it --
frequently. Many municipalities and their municipal attorneys buckle under these malicious
coercive efforts because they fail to understand the very broad powers that federal law provides
local governments to control the siting and operation of wireless communications facilities
within their boundaries. Moreover, they don't realize that a wireless carrier can never sue for
and recover from a municipality monetary damages or attorneys' fees if the municipality refuses
6
to allow the carrier to build and operate a requested wireless communications facility, even if a
court eventually decides the municipality actually has violated the TCA. As to the latter point,
the United States Supreme Court has expressly held, in City of Rancho Palos Verdes v.
Abrams, 544 U.S. 113 (2005), that neither monetary damages nor attorneys' fees are
available to a prevailing plaintiff in an action brought under the TCA. So even if Verizon
does sue the Town in federal court for denying final site plan approval and a special use permit --
and the Town somehow loses that lawsuit -- the Town can never be liable for monetary damages
or Verizon's attorneys' fees. The worst that could happen is that the Town would be required to
grant final site plan approval and to issue the special use permit for the project. Any fears or
implied threats that a wireless carrier will bankrupt the Town through litigation if the
Town denies a permit for a wireless communications facility are completely baseless.
Verizon's "Public Necessity" Legal Argument is Misplaced and Confusing
Verizon's lawyer, Mr. Lusk, in his October 22, 2024 Letter, argues: "Even if a 'two (2)
tower solution' were viable, however, applicable law prevents the Town from requiring Verizon
multiple facilities, when a single 134' wireless telecommunications facility will pr ovide reliable
coverage to the area." Mr. Lusk, invoking New York's "public utility" test, is attempting to
mislead you about the law and your duties thereunder.
While it is true that under New York case law (not the federal TCA), cell towers are
deemed to be "public utilities," that is for the limited purpose of relaxing the legal standard to
obtain a zoning "use" variance (not an "area" variance) from a zoning board. The New York
case law cited by Mr. Lusk has nothing to do with a local Planning Board's determination as to
whether a wireless communications facility applicant has met its burden of proof in meeting the
criteria for approval for a special use permi t called for under a municipality's zoning code
provisions for wireless communications facilities.
Nor does that New York "public utility" state case law have anything to do with whether
a local Planning Board's denial of an application for site plan approval and a special use permit
for a cell tower constitutes a violation of the federal TCA. That determination is governed by the
TCA itself and by federal case law interpreting the relevant provisions of the TCA.
Mr. Lusk's goal appears to be to confuse you by inserting a legal test that simply doesn't
apply to your consideration of the application before you. Let's unpack the "public utility" test
for cell towers under New York case law accurately. Most significantly, the “public utility”
legal standard does not apply to the Planning Board’s consideration of the applicant's
request for site plan approval and a special use permit. Rather, the test applies only to
requests for use variances under the zoning law. The Planning Board, of course, has no
power or authority to consider requests for zoning variances. That power is reserved for the
Town's Zoning Board of Appeals to which Verizon has already applied for an "area variance" for
this proposed tower since the proposed 138-foot tall tower greatly exceeds the height limit for
structures at the site under the zoning code.
The "public utility" legal standard was established by the New York Court of Appeals in
Consolidated Edison Co. v. Hoffman, 43 N.Y.2d 598 (1978), and was extended to the siting of
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cell towers by the Court of Appeals in Cellular Tel. Co. v. Rosenberg, 82 N.Y2d, 364, 372
(1993). In Consolidated Edison, the Court created a “public utility” exception to the traditional
“unnecessary hardship” standard that zoning boards utilize in determining whether an applicant
qualifies for a “use variance.” The traditional “unnecessary hardship” test sets forth the
following factors that a zoning board must consider before finding unnecessary hardship
warranting the granting of a use variance: (1) the land in question cannot yield a reasonable
return if used only for a purpose allowed in that zone; (2) the plight of the owner is due to unique
circumstances and not to the general conditions in the neighborhood which may reflect the
unreasonableness of the zoning ordinance itself; and (3) the use to be authorized by the variance
will not alter the essential character of the locality.” Rosenberg, 82 N.Y.2d at 372, quoting In
Matter of Otto v. Steinhilber, 282 N.Y. 71, 76 (N.Y. 1939).
The Rosenberg Court described the Consolidated Edison “public utility” exception test as
follows: "Instead [of meeting the traditional unnecessary hardship test], the utility must show
that modification is a public necessity in that it is required to render safe and adequate service,
and that there are compelling reasons, economic or otherwise, which make it more feasible to
modify the plant than to use alternative sources of power such as may be provided by other
facilities" (Matter of Consolidated Edison,43 N.Y.2d 598, 611, supra). The Court stated further
that "where the intrusion or burden on the community is minimal, the showing required by the
utility should be correspondingly reduced" (id., at 611). Matter of Consolidated Edison
(supra), applies to all public utilities. It also applies to entirely new sitings of facilities, as well as
the modification of existing facilities. The Rosenberg Court applied the test to the siting of cell
towers.
Rosenberg, 82 N.Y.2d at 372.
The Rosenberg tri-partite test for considering use variance applications for cell towers
under New York state law consists of the following: 1) have the applicants demonstrated the
existence of a significant coverage gap? 2) will the proposed facility resolve the significant
coverage gap? and 3) most importantly, will the proposed facility present a minimal intrusion
upon the community? See Cellco P’ship v. Town of Clifton Park, 365 F.Supp.3d 248, 257
(N.D.N.Y. 2019); Omnipoint Communications, Inc. v. Town of LaGrange, 658 F.Supp.2d 539,
556 (S.D.N.Y. 2009).
The state court cases Mr. Lusk then uses to illustrate his point only prove mine -- i.e., the
"public utility" test applies only when the local zoning board considers an application for a use
variance. In Nextel Partners, Inc. v. Town of Ft. Ann , 1 A.D.3d 89, 766 N.Y.S.2d 712 (3d Dep't.
2003), the appellate court simply affirmed the trial court's ruling annulling a Town Board's
decision to deny Nextel's application for a zoning use variance to build a 110-foot tall cell tower
as arbitrary and capricious under the Rosenberg test. In Sprint Spectrum, L.P. v. Zoning Bd. of
Appeals for the Town of Guilderland, 173 Misc.2d 874, 662 N.Y.S.2d 717 (Sup. Ct. Albany
1997), the trial court ruled that the Town of Guilderland's decision to deny a zoning use
variance to allow Sprint to construct a 100-foot tall cell tower in a residential neighborhood
where such structures are banned was arbitrary and capricious under the Rosenberg public utility
test. Indeed, the court made a point to emphasize that Rosenberg "established the current
requirements for the approval of use variances with respect to telecommunications towers."
8
In the instant matter, the issue of a zoning use variance is completely outside the scope of
the Planning Board's statutory duties. Moreover, even with respect to the Town's Zoning Board
of Appeals, Verizon's application does not seek a zoning use variance. That's because the Town
Code actually allows as a permitted use wireless communications facilities in all zoning districts
in Town, provided that the Planning Board, upon consideration of all the evidence -- pro and con
-- determines that the applicant successfully meets the criteria set forth in Section 270-219 of the
Town Code for site plan approval and issuance of a special use permit for the proposed cell
tower.
Respectfully, you Members of the Planning Board need to stay focused on your
responsibilities. Do not be misled by Mr. Lusk into a diversionary legal analysis that is not in
your bailiwick. You do not need to worry about the "public necessity" test. Nor should you be
distracted by Mr. Lusk's false suggestion that you are mandating that the applicant build two cell
towers of lesser height rather than the single 134-foot tall cell tower (plus the 4-foot tall lightning
rod) which Mr. Lusk claims is beyond the scope of your authority. Your "mandate" is only to
vote "yea" or "nay" on the Verizon's application for site plan approval and a special use permit,
with or without conditions. You can't require the applicant do anything, but you do have the
power to approve or disapprove of its application. Please don't fall into Mr. Lusk's trap.
You should be aware that the Town of Ithaca Town Code provisions regarding wireless
telecommunications facilities were carefully drafted to comply with the federal TCA and with
the controlling federal Second Circuit Court of Appeals decisions interpreting the TCA. As
such, Section 270-219 of the Town Code closely follows the guidance and legal tests of the
Second Circuit.
The TCA limits to some degree state and local regulation 'of the placement, construction,
and modification of personal wireless service facilities.' Omnipoint Commc'ns, Inc. v. City of
White Plains, 430 F.3d 529, 531 (2d Cir. 2005) (quoting 47 U.S.C. §332(c)(7)). Such regulation
'(I) shall not unreasonably discriminate among providers of functionally equivalent services; and
(II) shall not prohibit or have the effect of prohibiting the provision of personal wireless
services.' 47 U.S.C. §332(c)(7)(B)(i). "The Second Circuit has clearly stated that this subclause
'precludes denying an application for a facility that is the least intrusive means for closing a
significant gap in a remote user's ability to reach a cell site that provides access to land lines.''
Verizon Wireless of E. LP v. Town of Wappinger, 2022 WL 282552 (S.D.N.Y. Jan. 31, 2022), at
*12 (quoting Sprint Spectrum L.P. v. Willoth, 176 F.3d 630, 643 (2d Cir. 1999)). "If an
applicant's proposal is not the least intrusive means of closing a significant gap in coverage, a
local government may reject [the] application ... without thereby prohibiting personal wireless
services." T-Mobile Ne. LLC. v. Town of Ramapo, 701 F.Supp.2d 446, 456-57 (S.D.N.Y. 2009)
(internal quotations omitted); ExteNet Sys., Inc. v. Village of Plandome, 2021 WL 4449453
(E.D.N.Y. Sept. 29, 2021), at *20 ("[T]o be sure, [a] local government may reject an application
for construction of a wireless service facility ... without thereby prohibiting personal wireless
services if the service gap can be closed by less intrusive means." (Internal quotations omitted").
Section 270-219 of the Town Code expressly requires the Planning Board to consider the
evidentiary record while following these controlling federal legal standards. Section 270-
9
219(G)(2)(r) provides for the applicant to conduct an alternative site analysis; Section 270-
219(G)(2)(s) requires the applicant to conduct a significant gap analysis; and Section 270 -
219(G)(2)(t) provides for the applicant to demonstrate that its proposed wireless facility is the
least intrusive means of addressing the significant gap in coverage.
To meet its evidentiary burden of proof with respect to each of these subsections, the
applicant cannot simply make conclusory statements. The subsections each require the applicant
to provide evidentiary substantiation. While I was only very recently retained by my clients, I
have reviewed Verizon's submissions, and they fall woefully short of meeting Verizon's burden
of proof. Due to time and other constraints, I will focus on Verizon's alternative site analysis --
required under Section 270-219(G)(2)(r) -- and point out a number of glaring deficiencies in its
submission.
In my considerable experience representing clients in these matters, I find that all tower
developers tend to play the same phony game with respect to alternative site selection, but
Verizon tends to be the worst player. The game goes as follows: the tower developer's RF
engineer defines an extremely narrow search radius -- often 1/2 mile or less -- arguing that
topographical peculiarities and foliage considerations require that the cell tower be sited with in
the resulting small search zone. The reality is that the RF engineer typically locates the best site
for the carrier's RF needs using a computer software package, and the RF engineer has no
personal familiarity with the site; the search zone is gerrymandered to fall within the RF
engineer's narrow "best choice" area, and then the area is provided to a third party site
acquisition team whose mandate is to find a property owner who is willing to lease a portion of
his property very cheaply to the carrier and who doesn't give a damn about his neighbors. If the
site acquisition specialist is successful, then that "winning" site instantly becomes the only
technologically feasible site for the tower, and the other few alternative sites within the small
search zone are quickly discarded on pretextual grounds. While I say this slightly "tongue-in-
cheek," the sad truth is that this is really how the telecoms act.
Verizon's own alternate site analysis in the instant application proves my point. In its
application at Exhibit I, Verizon provides a "Sunny View Site" Site Selection Analysis, dated
September 19, 2023. The Site Selection Analysis was prepared by Brett Morgan of Airosmith
Development, a consultant to Verizon Wireless. The critical "search ring" was determined by
Tim Zarneke, a Verizon Wireless RF engineer, who describes its creation in his "Engineering
Necessity Case - 'Sunny View,'" submitted as an exhibit to Verizon's Application. According to
Mr. Zarneke, on page 14 of his report, "[a] Search Area is the geographical area within which a
new site is targeted to solve a coverage or capacity deficiency. Three of the factors taken into
consideration when defining a search area are topography, user density, and the existing
network." Mr. Zarneke imposes a very odd elevation constraint into his search area algorithm.
He states on the bottom of page 15: "The site needs to be located within the search area but also
at a ground elevation below the ridge of 1,150' or below [sic] to keep the site contained. The
proposed site is located at 824' AMSL which meets this requirement and is strategically located
within the ring to allow for Line of Sight (LOS) to the coverage objective area." At the top of
page 15, Mr. Zarneke states: "The below image is absent any coverage to help the viewer with
area orientation as well as visualizing the need for the below 1,000' AMSL (maximum ground
elevation requirement)."
10
Mr. Zarneke provides no explanation for the purported need to keep the proposed cell
tower site at an AMSL below 1,000' or below the ridge of 1,150'. The Town Code does not
appear to contain any restrictions on locating otherwise conforming cell towers or wireless
communications facilities at AMSLs of 1,000' or greater. The 1,000' AMSL maximum ground
elevation requirement has enormous ramifications -- it grossly limits the possible search radius to
the absurdly narrow radius defined by Mr. Zarneke. As I stated above, vast areas of land on the
Eastern Heights and along Snyder Hill Road are 400 feet higher in elevation than Verizon's
proposed Sunny View site. Yet Mr. Zarneke excludes them entirely from his search radius
because of his completely unexplained 1,000' AMSL maximum elevation constraint "to keep the
site contained" (whatever that means). The Planning Board needs to question Verizon
extensively about this apparently artificial constraint which I strongly suspect is intended to
gerrymander the boundaries of the search area in order to support the Sunny View site.
In my experience, if the Planning Board charges Mr. Johnson, its own independent
consultant, to come up with an appropriate search radius for a possible cell tower site, he will
determine one that is far more expansive than Mr. Zarneke's and one which opens up scores of
potentially feasible alternative sites. I respectfully urge the Planning Board to do so or to simply
to reject Mr. Zarneke's artificially narrow and seemingly unjustified search area.
Unsurprisingly, given the gerrymandered tiny search area concocted by Mr. Zarneke,
Verizon's site acquisition consultant found no existing towers or tall structures within the search
area, nor any municipally-owned properties in the search area. Mr. Morgan, the site acquisition
consultant, purportedly conducted a "comprehensive investigation of the Sunny View Search
Area" and found five private properties to analyze as potential sites for the proposed tower.
Interestingly, when Mr. Morgan reached out to the five property owners, each was initially
interested in leasing his property to Verizon for use as the cell tower site. (Often, some
landowners are not interested in tying up a portion of their land for 30 years or more -- and/or
restricting the development potential of their property -- for the small revenue stream offered by
a cell tower developer). But despite all the landowners' interest, after Mr. Morgan forwarded the
site information for each of the parcels to Verizon's RF engineer, Verizon's RF engineer
determined that none of the locations except for the Sunny View site would be adequate, as those
locations "would have not adequately covered the intended coverage area in the same capacity as
the selected location." That incomprehensible "word salad" is the entirety of the explanation Mr.
Morgan provides for the rejection of the four alternative sites. Verizon provides no RF analyses
for each rejected site demonstrating the veracity of the explanation. Simply put, the explanation
is completely inadequate to meet Verizon's burden of proof under the Town Code.
The foregoing represents just a taste of the litany of well-founded reasons why the
Planning Board should deny Verizon application for site plan approval and for a special use
permit. Please give me a call to discuss any questions you may have.
Best regards,
Robert J. Berg
/s/ Robert J. Berg
1
Paulette Rosa
From:Bob Babjak <bobbybabjak@gmail.com>
Sent:Monday, October 27, 2025 4:00 PM
To:Town Of Ithaca Clerks Department; Rod Howe; Rich Depaolo; Pam Bleiwas; Margaret
Johnson; Eric Levine; Rob Rosen; Rod Howe; Susie Gutenberger
Cc:CJ Randall; Chris Balestra; aknauf@nyenvlaw.com
Subject:111 Wiedmaier Ct. Settlement & Consent order - Major Issues!
**WARNING** This email comes from an outside source. Please verify the from address, any URL
links, and/or attachments. Any questions please contact the IT department
Dear Town Board,
I live at 106 Wiedmaier Ct., the house closest to the proposed Sunny View tower site at 111 Wiedmaier
Ct. over the last year I was very actively engaged, along with many local residents close to the tower site,
as well as concerned citizens from all over Ithaca, in opposing this project from being approved. We
showed up at every meeting presenting cogent, fact-based arguments as to why this project was not
necessary. We had reams of supporting data and precedents in Federal case law on our side. It was so
compelling that the Zoning Board denied a height variance to Verizon, as per the will of the residents of
the town.
Unfortunately, I found out today that a settlement was negotiated with Verizon that allows them to build
a slightly shorter tower at the same site, effectively reversing the Zoning Board's decision. I think this is
outrageous for many reasons, chief among them the fact that any knowledge of a lawsuit and settlement
in this case was kept from the public. Also that this "vote" on a settlement showed up on the agenda for
today's meeting in an "executive session" with no public comment and almost no time to digest the
details of the settlement, and formulate any type of recourse by the actual injured parties, i.e, the "near
residents."
I believe that this settlement is predicated on the false premise of an existing "coverage gap" in the area
around the Six Mile Creek Valley:
"WHEREAS, a significant gap in Verizon Wireless’ service capabilities exists in the Town and
surrounding areas (the “Service Gap”). Verizon Wireless maintains that the Project is needed to fill the
Service Gap"
A few relevant facts supporting this:
Fact #1: As town legal counsel Susan Brock has repeatedly pointed out, voice calls are the only
applicable standard per our code.
"The Ithaca Town Code definition in Section 270-219.B uses the 2nd Circuit’s definition of
Effective Prohibition: “Denial by the Town of a PWSF approval or permit for a personal wireless
service facility that is the least intrusive means of remedying a significant gap in personal wireless
service coverage (the ability of wireless telephones to make and receive voice calls to and
from landlines that are connected to the national telephone network).
2
Fact #2: Almost all voice calls and texting are done using the low-band frequencies.
Fact #3: According to Verizon's own maps submitted to the Planning Board and Zoning Board, there is
already widespread low-band coverage in the area they purport as having a "coverage gap".
Before any settlement is accepted, I believe the Board has a duty to refer the applicant's appeal of denial
to the 2nd Circuit court, as they are the ruling body per which the Town Code granting the ZBA authority
to legally deny the applicant's variance (based on the adequate coverage of wireless to landline calls in
the affected area) is based. Anything short of a ruling by the 2nd Circuit would be a failure of the Town to
defend our legally-protected sovereignty as codified by the Supreme Court.
I strongly urge you to consider these facts, as well as the overwhelming opposition to this project by the
citizens of The Town.
Thank you,
Bob Babjak
106 Wiedmaier Ct.
1
Paulette Rosa
From:CJ Randall <cjrandall@townithacany.gov>
Sent:Monday, October 27, 2025 4:06 PM
To:Town Of Ithaca Clerks Department
Subject:Fw: Proposed Verizon cell tower on Weidmaier
I assume you may have received this from a Town Board member already, but just in case —
From: Daniel Seib <danielcseib@gmail.com>
Sent: Monday, October 27, 2025 4:05 PM
To: Rich Depaolo <rdepaolo@townithacany.gov>; Rod Howe <RHowe@townithacany.gov>; Pam Bleiwas
<pbleiwas@townithacany.gov>; Margaret Johnson <MJohnson@townithacany.gov>; Eric Levine
<elevine@townithacany.gov>; Rob Rosen <RRosen@townithacany.gov>; Susie Gutenberger
<SGutenberger@townithacany.gov>
Cc: aknauf@nyenvlaw.com <aknauf@nyenvlaw.com>; Chris Balestra <CBalestra@townithacany.gov>; CJ
Randall <cjrandall@townithacany.gov>; andrewmolnar11@gmail.com <andrewmolnar11@gmail.com>
Subject: Proposed Verizon cell tower on Weidmaier
**WARNING** This email comes from an outside source. Please verify the from address, any URL
links, and/or attachments. Any questions please contact the IT department
Dear Town Board,
I am alarmed to just be hearing about a proposed action to allow the cell tower to go up on Weidmaier
Court. Our property is within 500 ft of this parcel and this is the first I am hearing of it…and the meeting to
approve this action starts in half an hour! Why wasn’t the public told about this? We have all been so happy
thinking that we had been heard in our concerns. Please do not approve this action. There is no need to have
the tower right there, it will be a horrible eyesore, and it will devalue all the nearby properties. I am trying to
rally my neighbors, but like I said, we just found out about this! Please vote no…we don’t need this and we
don’t want it!
Thank you for your consideration,
Daniel Seib and Family,
1581 Slaterville Road
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November 24, 2025
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TOWN OF ITHACA
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