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Palo Alto Whitewashes RF Microwave Radiation Exposure Hazards

Comparison of Average vs. Peak RF Microwave Radiation Exposure Readings

The red dots on this map represent locations of 19 so-called “small cell” antennas that are forcibly exposing Palo Alto residents, workers and visitors to extremely hazardous levels of Radio-Frequency Microwave Radiation (RF/MW radiation) 24/7/365
The screen of the HF-59B meter (equipped with a DG20_G10 -20 dB attenuator) shows peak RF/MW radiation readings of 72,000 to 123,000 microwatts per square meter (µW/m²) when standing on the sidewalk below the “Small Cells”. Applying the correction factor for the high-speed, pulsed, digital signals of 4G/LTE, the peak levels of 4G/LTE RF/MW radiation are actually over 720,000 to 1,230,000 µW/m², per the GigaHertz Solutions’ product manual and product video.

Tower Address Average by H&E Peak on meter screen* Peak is x higher
P01m Across from 514 High Street 1,200 µW/m² 123,000 µW/m² 103x
P02m2 Across from 471 Emerson Street 900 µW/m² N/A N/A
P03m Across from 470 Ramona Street 540 µW/m² N/A N/A
P04m Across from 450 Bryant Street 960 µW/m² 88,000 µW/m² 92x
P05m Across from 461 Florence Street 1,600 µW/m² 96,000 µW/m² 60x
P06m2 Across from 502 Waverley Street 1,900 µW/m² N/A N/A
P07m2 400 Hamilton Avenue 5,000 µW/m² N/A N/A
P08m 300 Hamilton Avenue 2,200 µW/m² N/A N/A
P09m2 635 Bryant Street 4,000 µW/m² 72,000 µW/m² 18x
P10m 158 Hamilton Avenue 2,400 µW/m² N/A N/A
P11m 100 Hamilton Avenue 2,600 µW/m² N/A N/A
P12m2 379 Lytton Avenue 4,000 µW/m² N/A N/A
P13m 181 Lytton Avenue 2,200 µW/m² 81,000 µW/m² 37x
P14m 245 Lytton Avenue 1,500 µW/m² N/A N/A
P15m 265 Lytton Avenue 1,600 µW/m² 114,000 µW/m² 71x
P16m 325 Lytton Avenue 2,800 µW/m² N/A N/A
P17m 437 Lytton Avenue 7,000 µW/m² N/A N/A
P18m 380 Hamilton Avenue 1,700 µW/m² N/A N/A
P19m 220 Hamilton Avenue 2,200 µW/m² 100,000 µW/m² 46x

  • H&E = Hammett and Edison, RF Microwave Radiation readings reported on 6/8/17; read original here.
  • µW/m² = microWatts per square meter; a microWatt is a millionth of a Watt and represents a rate of exposure, not total exposure over time.
  • * Applying the correction factor for the high-speed, pulsed, digital signals of 4G/LTE, the peak levels of 4G/LTE RF/MW radiation are 10x higher than what appears on screen, per the GigaHertz Solutions’ product manual and product video. The RF meter and the RF/MW Radiation specialist that completed these readings are detailed here.

In April 2017, a certified RF Microwave Radiation specialist completed accurate measurements of peak RF Microwave Radiation exposure levels using a precision instrument with a current certificate of calibration for the 19-Small-Cell Verizon/Crown Castle installation in downtown Palo Alto.

This work, we understand, resulted in the City of Palo Alto hiring Hammet and Edison (H&E) to complete a postmortem RF Microwave Radiation exposure assessment of these 19-Small-Cell Verizon/Crown Castle antennas.

Before the City embarked on this project, I spoke to Jodie Gerhardt by phone and I encouraged her to get the following raw data from H&E, so the City could accurately characterize the RF Microwave Radiation exposures in downtown Palo Alto:

  • A data log and plot of the power density of peak pulsed, data-modulated, Radiofrequency Microwave (RF/MW) Radiation, showing the actual peaks of RF/MW radiation over a 30 minute exposure for each so-called "Small Cell" antenna where people live and sleep near these microwave transmitters.

  • Both the peak and average readings of the RF/MW Radiation emitting from these antennas during different times of day: 9:00 am, Noon, 3:00 pm, 6:00 pm, 9:00 am and 3:00 am

  • RF/MW Radiation power density readings taken both outdoors and indoors where people walk, live and sleep.

Please read the following response to William Hammett’s 6/8/17 letter, quoted below.

Questions:

Before we consider Mr. Hammett’s analysis and letter a misleading whitewash, will the City of Palo Alto please answer the following questions?

  • Q1: At what time of the day were Mr. Hammett’s measurements taken?
  • Q2: For each location, how many minutes did Mr. Hammett take these measurements? More or less than 30 minutes, the standard for general public exposure RF Microwave radiation measurements?
  • Q3: Once we know the answer to Q2, do you then have a data log for all of the measurements during this time period?
  • Q4: Did you compare RF/MW radiation levels during different activities and at different times of day? We all know that network traffic varies by activity and throughout the day. Specifically, how did the average and peak readings compare during the following activities:

    • a: Beacon signals only, with no one in the office was connecting a device to the antenna on the light pole
    • b: While making a Verizon call
    • c: When sending/receiving a Verizon text
    • d: When streaming a video from the Verizon antenna
    • e: When downloading a software update from the Verizon antenna
  • Q5: What was the maximum instantaneous power/density RF/MW radiation reading (a configuration option available on the NBM-520 Broadband Field Meter)?
  • Q6: How do the maximum instantaneous power/density RF/MW radiation readings compare to the average readings?

We are entering into the public record in Palo Alto information challenging Hammett and Edison’s measurements and conclusions in Palo Alto, including a pattern of substandard work by H&E that we have encountered in other communities, such as H&E’s work for the Elk Grove School District in 2016. (https://youtu.be/CgldhZiA7jc)

Here is the 12/6/17 response to the 12/6/17 email from Hammett and Edison that they sent to defend their substandard RF Microwave Radiation exposure measurement work in Palo Alto:

12/6/17 Email to City of Palo Alto

December 6, 2017

Ms. Jodie Gerhardt jodie.gerhardt@cityofpaloalto.org
Manager of Current Planning
City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301-2531

cc: Mayor Gregory Scharff greg.scharff@cityofpaloalto.org
     Council Member Tom DuBois, tom.dubois@cityofpaloalto.org
     Council Member Eric Filseth, eric.filseth@cityofpaloalto.org
     Council Member Adrian Fine, adrian.fine@cityofpaloalto.org
     Council Member Karen Holman, karen.holman@cityofpaloalto.org
     Council Member Liz Kniss, liz.kniss@cityofpaloalto.org
     Council Member Lydia Kou, lydia.kou@cityofpaloalto.org
     Council Member Greg Tanaka, greg.tanaka@cityofpaloalto.org
     Council Member Cory Wolbach, cory.wolbach@cityofpaloalto.org
     ARB member Alexander Lew, arb@cityofpaloalto.org
     ARB member Peter Baltay, arb@cityofpaloalto.org
     ARB member Wynne Furth,arb@cityofpaloalto.org
     ARB member Robert Gooyer,arb@cityofpaloalto.org
     ARB member Kim Kyu, arb@cityofpaloalto.org
     Amy French, amy.french@cityofpaloalto.org
     Rebecca Atkinson, rebecca.atkinson@cityofpaloalto.org
     Jim Fleming, jim.fleming@cityofpaloalto.org

Re: Follow Up Questions to Hammett and Edison RF Microwave Radiation Exposure Analysis Were NOT Answered

Dear Ms. Gerhardt,

Will you please place this email/letter into the public record (both in the paper file and on the Palo Alto web site) for the current Small Cell applications for Palo Alto’s residential zones (Wireless 17PLN-00169)?

How does what Bill Hammett writes, quoted below, answer the following questions? Obviously, he is not answering the questions.

Q1: At what time of the day were Mr. Hammett’s measurements taken?
A1: Not answered.

Q2: For each location, how many minutes did Mr. Hammett take these measurements? More or less than 30 minutes, the standard for general public exposure RF Microwave radiation exposure measurements?
A2: Not answered. I can only assume H&E did not measure for the full 30 minutes required by the FCC for each antenna.

Q3: Once we know the answer to Q2, do you then have a data log for all of the measurements during this time period?
A3: Not answered. I can only assume H&E did not take a datalog for any of the current 19 small cells which was an error either on H&E’s part for not doing so or on the City of Palo Alto’s part for not asking H&E to do so.

Q4: Did you compare RF/MW radiation levels during different activities and at different times of day? We all know that network traffic varies by activity and throughout the day. Specifically, how did the average and peak readings compare during the following activities?
A4: Not answered. I can only assume that H&E made only one average measurement for each antenna based on a nominally-short (how short?) and non-FCC-compliant period of time. The data the City of Palo Alto received from Hammett & Edison are insufficient to accurately characterize the RF Microwave Radiation exposure environment in downtown Palo Alto.

  • a: Beacon signals only, with no one in the office was connecting a device to the antenna on the light pole
    a: Not answered.
  • b: While making a Verizon call
    b: Not answered.
  • c: When sending/receiving a Verizon text
    c: Not answered.
  • d: When streaming a video from the Verizon antenna
    d: Not answered.
  • e: When downloading a software update from the Verizon antenna
    e: Not answered.

Q5: What was the maximum instantaneous power/density RF/MW radiation reading (a configuration option available on the NBM-520 Broadband Field Meter)?
A5: Not answered. I can only assume H&E did not take any maximum instantaneous power/density RF/MW radiation readings, which was an error either on H&E’s part for not doing so or on the City of Palo Alto’s part for not asking H&E to do so.

Q6: How do the maximum instantaneous power/density RF/MW radiation readings and compare to the average readings?
A6: Not answered. I can only assume H&E did not take any maximum instantaneous power/density RF/MW radiation readings, so these comparisons are not possible with the insufficient data provided by H&E.

I strongly suggest that the City of Palo Alto ask a different firm repeat the work, so the City has the data to answer the important questions, above.

This is not the first time we have encountered Hammett and Edison declining to provide reasonable answers to clarifying questions about their work. We will enter substantial information into the public record about previous substandard work performed by Hammett and Edison in 2016 — and H&E’s refusal to answer any clarifying questions about this work, which you can view here, which is already in the public record. https://youtu.be/CgldhZiA7jc

I also suggest that the City of Palo Alto needs to look carefully at the methodology and the veracity of Hammett and Edison’s work that was performed on behalf of the City of Palo Alto.

It is clear that we did not get answers in time for 12/7/17 ARB meeting from either you, Jodie, or from Rebecca Atkinson; we hope to get more thorough, accurate and thoughtful answers to our questions from the City of Palo Alto in the next week or so.

Please read my other comments below.

On 12/6/17 @ 6:45 pm, Jodie Gerhardt wrote:

Given the quick turn around, below is the response H&E is able to give at this time.

Jodie

From: Bill Hammett [mailto:bhammett@h-e.com]
Sent: Wednesday, December 06, 2017 2:47 PM
To: Gerhardt, Jodie
Cc: Mail; French, Amy

Subject: Re: Follow Up Questions to Hammett and Edison RF Microwave Radiation Exposure Analysis

Jodie –

Hammett: Thanks for sending along certain questions regarding the compliance certification we had prepared for the City of Palo Alto, dated June 9, 2017, for the network of low-power antennas on light poles constructed by Crown Castle. [The gentleman] and I have already discussed these questions about our measurements.

Comment: The preceding statement is not true. I have never discussed with Bill Hammett the actual RF Microwave Radiation exposure measurements H&E made on behalf of the City of Palo Alto.

Hammett: It is important to put this issue into proper context, since [the gentleman] does not take exception to our conclusion that the Verizon operations from these antennas are in compliance with the FCC standard limiting human exposure.

Comment: The ‘perspective’ is that Hammett is merely avoiding answering the questions. The important point is that there is much more to consider than "compliance with the FCC standard limiting human exposure" to accurately understand and evaluate the pulsed, data-modulated, Radiofrequency Microwave Radiation exposures on the streets, sidewalks, parks and front yards in Palo Alto.

Hammett: Instead, he argues that the federal standard itself is inadequate and that therefore permitting jurisdictions should use some other criteria for evaluating possible human health risk from such facilities.

Comment: I am saying that the truth matters, regardless of which RF Microwave Radiation exposure guideline one chooses to follow.

Hammett: However, as you know, federal law would prohibit that, as local jurisdictions are preempted from applying any standard tighter than what the FCC has adopted.

Comment: The preceding statement by Hammett is also not true. The 1996 Telecommunications act, the Federal law to which he is referring, says the following (see my emphases in red): http://scientists4wiredtech.com/legislation/1996-federal-telecommunications-act-s-652/

SEC. 704. FACILITIES SITING; RADIO FREQUENCY EMISSION STANDARDS.

(a) National Wireless Telecommunications Siting Policy. — Section 332(c) (47 U.S.C. 332(c)) is amended by adding at the end the following new paragraph:

   (7) Preservation of local zoning authority. —

      (A) General authority. — Except as provided in this paragraph, nothing in this Act shall limit or affect the authority of a State or local government or instrumentality thereof over decisions regarding the placement, construction, and modification of personal wireless service facilities.

      (B) Limitations. —

         (i) The regulation of the placement, construction, and modification of personal wireless service facilities by any State or local government or instrumentality thereof —

            (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.

         (ii) A State or local government or instrumentality thereof shall act on any request for authorization to place, construct, or modify personal wireless service facilities within a reasonable period of time after the request is duly filed with such government or instrumentality, taking into account the nature and scope of such request.

         (iii) <<NOTE: Records.>Any decision by a State or local government or instrumentality thereof to deny a request to place, construct, or modify personal wireless service facilities shall be in writing and supported by substantial evidence contained in a written record.

         (iv) No State or local government or instrumentality thereof may regulate the placement, construction, and modification of personal wireless service facilities on the basis of the environmental effects of radio frequency emissions to the extent that such facilities comply with the Commission’s regulations concerning such emissions.

         (v) Any person adversely affected by any final action or failure to act by a State or local government or any instrumentality thereof that is inconsistent with this subparagraph may, within 30 days after such action or failure to act, commence an action in any court of competent jurisdiction. <<NOTE: Courts.>The court shall hear and decide such action on an expedited basis. Any person adversely affected by an act or failure to act by a State or local government or any instrumentality thereof that is inconsistent with clause (iv) may petition the Commission for relief.

      (C) Definitions. — For purposes of this paragraph —

         (i) the term ‘personal wireless services’ means commercial mobile services, unlicensed wireless services, and common carrier wireless exchange access services;

         (ii) the term ‘personal wireless service facilities’ means facilities for the provision of personal wireless services; and

         (iii) the term ‘unlicensed wireless service’ means the offering of telecommunications services using duly authorized devices which do not require individual licenses, but does not mean the provision of direct-to-home satellite services (as defined in section 303(v)).".

Comment: Nothing in the 1996 Telecommunications Act limits or affects the authority of a State or local government from regulating the operations of personal communications services, including power output and hours of operation of these Wireless antennas (Wireless 17PLN-00169). When regulating the operations of personal communications services, the State or local government can consider environmental effects, including health effects. Read the law.

One can read more background about this commercial/procedural RF Microwave Radiation exposure guideline here: http://scientists4wiredtech.com/regulation/rf-microwave-exposure-guidelines/

Hammett: I hope that this is helpful information, should the Architectural Review Board consider this issue at its meeting tomorrow morning.

Regards,

Bill

Hammett & Edison, Inc., Consulting Engineers
Regulatory Compliance Services for Wireless Telecommunications
RF Exposure, Noise, Interference & Coverage Studies
707/996-5200 office; 707/953-5200 cell

William Hammett Letter Begins

June 8, 2017

Ms. Jodie Gerhardt
Manager of Current Planning
City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301-2531

Dear Jodie:

Thanks for accompanying me on the recent visit to the offices at 635 Bryant Street in Palo Alto, across the street from City Hall. As you requested, our visit on May 25 was to assess the actual RF exposure conditions in those offices from operation of the Crown Castle directional antenna mounted on the light pole on the sidewalk in front of the two-story office building.

We met there with two people, Mr. David Saul [the owner of the building] and Ms. Ellen Ehrenpreis [the tenant on the second floor], whose office was on the second floor and at the front of the building, closest to the antenna. Using our Narda Type NBM-520 Broadband Field Meter with Type EF-0391 Isotropic Broadband Electric Field Probe (Serial No. D-0454), under current calibration by the manufacturer, we measured a maximum level of 0.0001 mW/cm2 attributed to the Crown Castle operation

Comment:

Google the following phrase: "mW/cm² to µW/m²" and use the calculator that appears to convert the Wireless industry-speak RF Microwave Radiation unit, mW/cm² — to the unit most often used by scientists who do active research in this field ,µW/m². Mr. Hammett, therefore, reports an average of 1,000 µW/m², which could be comprised of a series of RF Microwave Radiation micro-second peaks as high as 100,000 µW/m², as demonstrated here:

Next, let’s compare a range of 1,000 µW/m² – 100,000 µW/m² to RF Microwave Radiation exposure guidelines that are based on current scientific research:

BioInitiative, 2012: "A scientific benchmark of 30 µW/m² for lowest observed effect level for RFR is based on mobile phone base station-level studies. Applying a ten-fold reduction to compensate for the lack of long-term exposure (to provide a safety buffer for chronic exposure) or for children as a sensitive subpopulation yields a 3 to 6 µW/m² RF Microwave Radiation exposure guideline"

Similar scientifically-based RF Microwave Radiation Exposure Guidelines are published by the International Institute for Building-Biology & Ecology

No Hazard Slight Hazard Severe Hazard Extreme Hazard
< 0.1 µW/m² 0.1 µW/m² to 10 µW/m² 10 µW/m² to 1000 µW/m² > 1000 µW/m²

William Hammett Letter, Continues

this is some 10,000 times below the 1 mW/cm2 FCC public limit applying for exposures of unlimited duration. Therefore, compliance with the FCC standard is ensured for this location from the Crown Castle antenna, as installed and operating at the time of our visit.

As you will recall, Ms. Ehrenpreis described an earlier visit by a third party, who used bulky equipment

Comment:

The bulky equipment to which Mr. Hammett refers is the following professional RF/MW Radiation precision instrument with current calibration certificate: Gigahertz HFW-58B RF Meter, which was also specified on the original page that reports the irrefutable results: http://scientists4wiredtech.com/2017/04/palo-alto-4g-small-cells/

William Hammett Letter, Continues

and reported levels as high as “1,230,000 microwatts per square meter (μW/m2),” which would be 0.123 mW/cm2 in the more standard nomenclature. That figure is more than 1,000 times higher than what our calibrated meter indicated, though that, too, would comply with the FCC limit.

Comment:

This is nonsense. Mr. Hammett is implying the GigaHertz Solutions meter was not calibrated and was used by a person who lacked the training to properly operate it. Both of his implications are false. Hammett then proceeds to compare Apples to Oranges, in an apparent attempt to mislead. A careful reading of

. . . clearly explains the following readings taken on 4/21/17 in Palo Alto at specific locations, with photos to document the careful work:

  • Site P09m2: Bryant/Hamilton Streets, across from City Hall
  • The screen of the HF-59B meter shows a peak RF/MW radiation reading of 38,000 µW/m², while standing across the street, about 75 feet away from the "Small Cell". Applying the correction factor for high-speed pulsed digital signals (explained here), the peak levels of 4G/LTE RF/MW radiation are actually over 380,000 µW/m². This is an extreme health hazard.
  • Site P09m2: Bryant/Hamilton Streets, under the antenna
  • The screen of the HF-59B meter shows a peak RF/MW radiation reading of 72,000 µW/m², while standing on the sidewalk beneath the "Small Cell:. Applying the correction factor for high-speed pulsed digital signals (explained here), the peak levels of 4G/LTE RF/MW radiation are actually over 720,000 µW/m². This is an extreme health hazard.
  • Site P01m: High Street/University Avenue
  • The screen of the HF-59B meter shows a peak RF/MW radiation reading of 123,000 µW/m², while standing on the sidewalk beneath the “Small Cell”. Applying the correction factor for high-speed pulsed digital signals (explained here), the peak levels of 4G/LTE RF/MW radiation are actually over 1,230,000 µW/m². This is an extreme health hazard.

. . . no measurements are reported inside the second floor office, to accommodate Mr. David Saul’s request. The web pages also clearly explain the following conclusions:

  • https://youtu.be/owCeCC6B69k?t=4m8s
  • Dr. Paul Dart @ 5:35: "From 1953 to 1978, the Russians beamed microwave radiation into the US Embassy and researchers found that the US embassy personnel had a statistically significant increase in depression, irritability, concentration problems, memory loss, ear problems, skin problems, vascular problems and other health problems. The longer they worked there, the worse these problems were likely to be . . . the exposure levels inside the building were measured at between 20,000 to 280,000 µW/m²
  • Dr. Neil Cherry: "A highly remarkable result is the dose-response relationship for a range of illnesses. Despite the small numbers, the lack of long latency period and dilutionary factors, the Lilienfeld data shows significant increases in:

    • Cardiac problems
    • Neurological and psychological symptoms
    • Altered blood cell counts
    • Increased chromosome aberrations, and
    • Elevated cancer in children and adults
    • Sickness increasing in a dose-response manner with years of residence"
  • This irrefutable data in the public record and the scientifically-based RF/WM exposure guidelines from BioInitiative and the HBELC form the basis for concluding that peak RF/MW radiation levels measured on the streets of Palo Alto of 38,000 µW/m² to 1,230,000 µW/m² are an extreme health hazard. It is immaterial how these power density levels compare to any existing commercial/procedural guideline that the FCC adopted in August, 1996. The damages continue no matter what the FCC adopted as a guideline.

Think about it. Why, in 2017, are we still relying on a RF/MW radiation exposure guideline that was selected in 1996 and that is based on a scientifically invalidated and obviously outdated 1986 Review of only declassified research through 1982? This makes no sense.

The world has learned a great deal about the hazards of RF Microwave radiation exposures since 1982 and we have troves of now-declassified military research upon which to rely. The Wireless industry and the FCC are clinging to this "Emperor has no Clothes" RF/MW radiation exposure guideline because it leads to more profits for all in the Wireless industry, including Mr. Hammett.

William Hammett Letter, Continues

I did speak on the phone with that person on my drive home that afternoon; he is not an engineer and, while he promised to provide the specifications for the equipment he used, has not yet done so.

The specifications for the equipment that the certified RF/MW radiation specialist used have been published at the following web page for all to read, long before Mr. Hammett completed his work and reported it on 6/8/17. Did Mr. Hammett not do his research?

In any case, he discounts the FCC standard entirely, especially its measurement protocols.

Comment:

For the solid reasons, cited above, the measurements made and conclusions reached on 4/21/17 are accurate, despite what Mr. Hammett might be implying.

William Hammett Letter, Continues

Please let me know if any questions arise on the visit, our measurements, or the analysis.

Sincerely yours,

William F. Hammett