FCC Ex Parte Comment for WT Docket 17-79

September 17, 2018

Ms. Marlene H. Dortch
Secretary Federal Communications Commission
445 12th Street SW
Washington, District of Columbia 20554

RE: Accelerating Wireline Broadband Deployment by Removing Barriers to Infrastructure Investment, WC Docket No. 17-84; Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment, WT Docket No. 17-79

Dear Ms. Dortch,

As director of Maryland Smart Meter Awareness (MSMA) and as researcher and creator of https://www.whatis5g.info, I would like to add to the record MSMA’s strong opposition to the Order Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment, which represents a complete reversal of FCC’s mandate to regulate the wireless industry and replaces it with an Order that instead regulates the public and local municipalities.

As stated in my original comments, the vast majority of people still don’t know what 5G is; don’t know that wireless radiation emitting antennas will be placed in front of homes throughout the US; and remain uninformed about the adverse health impacts of wireless radiation. Without this knowledge, there can be no due process.

Wireless antennas in residential areas will impact the health, safety, and quality of life of us all so profoundly that to vote through this Order without adequate public understanding and input would be a clear violation of our rights. At the very least, the Commission should postpone this vote until November to allow sufficient time for the public to review and comment on the 100-page Docket.

The densification of our communities with wireless “small cells”, the Internet of Things, “Smart” Cities, and whatever other applications industry dreams up, would render public spaces inaccessible to people with Electromagnetic Sensitivity (EMS), and some may even be forced from their homes. Would anywhere be left safe for them? It would appear that forced densification of communities with radiation emitting towers would present a clear ADA violation.

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ADA Rights Ignored in FCC WT Docket 17-79

From https://www.fcc.gov/ecfs/search/filings?q=filers.name:(Merry%20Callahan)&sort=date_disseminated,DESC

June 17, 2017

Hello FCC,

Please include my comment in opposition to proceedings on the expediting and expansion of 5G networking onto public right of way and poles, and the stand-down of copper-lines in both urban and rural areas. I request that a 30-day extension to comments be granted on these proceedings, WT Dockets 17-84 & 17-79, with a 30-day extension to replies on comments.

Further, I request a moratorium on these and other expansion of networking policy recommendations by FCC until such time that evidence can be shown that these two docket items, and expansions like them when implemented, can comply with the Americans with Disabilities Act and 42 U.S.C 12101 et seq.

I am an acknowledged member of the protected class with the characteristic of ‘disabled by electromagnetic sensitivities’ (EMS), which is recognized by The Access Board. https://www.access-board.gov/research/completed-research/indoor-environmental-quality/introduction.

Exposure to cellular technology violently exacerbates my genetic vertigo disease and exacerbates my life threatening upper cervical spinal column and brain stem injury and the pervasive nerve damage remaining after recovery. This effect on damaged, or amputated nerves and autonomic nervous system injury and genetic damage such as mine is well known, and is specifically referenced in appendices and testimony at the ADA’s site.

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Scott Wiener Paints Ajit Pai as Telecom Shill

California Net Neutrality Fight Escalates

by Dell Cameron 9/14/18 | Original Gizmodo article here,

The feud between federal Republican officials and the architects of California’s recently passed (but as of yet unsigned) net neutrality legislation intensified Friday, with State Senator Scott Wiener, the bill’s principal author, accusing the FCC of being bought and paid for by the telecom industry. Wiener, a Democrat of San Francisco, returned fire in a statement after Ajit Pai, chairman of the Federal Communications Commission, referred to Wiener’s Senate Bill 822 as an “egregious” example of net neutrality proponents “pushing state governments to regulate the internet.”

FCC Chairman Ajt Pai said in a speech Friday at the Maine Heritage Policy Center

“Last month, the California state legislature passed a radical, anti-consumer Internet regulation bill that would impose restrictions even more burdensome than those adopted by the FCC in 2015. In a way, I can understand how they succumbed to the temptation to regulate. After all, I suppose a broadband pipe might look to some like a plastic straw.”

Wiener countered after the speech, saying that, unlike the FCC, California isn’t run “by the big telecom and cable companies.”

CA State Senator Scott Wiener:

“Pai can take whatever potshots at California he wants. The reality is that California is the world’s innovation capital, and unlike the crony capitalism promoted by the Trump Administration, California understands exactly what it takes to foster an open innovation economy with a level playing field,”

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Across the U.S., 5G Runs Into Local Resistance

By Drew FitzGerald, Sept. 13, 2018 } Original Wall Street Journal article here.

City officials also complain they don’t have enough staff to handle the applications. But state and federal authorities are in the carriers’ corner.

Small cells, essential for 5G service, include the conspicuous, as in Santa Rosa, Calif. , where the box on the ground was removed after complaints but those on the pole remained; and the less conspicuous (center) and well camouflaged (right), both in Nashville.

Residents of Denver’s Riviera apartments were surprised earlier this year when a roughly 30-foot-tall green pole appeared a few feet in front of their building entrance. The pole, installed by Verizon Communications Inc. and laden with cellular antennas, was designed to improve cellphone service in the area, but the residents complained about the placement.

Months later, it was gone. But that was just a small taste of what’s to come across the country: Millions of Americans will soon encounter similar poles or notice antennas sprouting on existing structures, like utility poles, street lamps and traffic lights, all over their neighborhoods. All four national cellphone companies are pushing to build out their networks with a profusion of small, local cells to keep their data-hungry customers satisfied and lay the groundwork for fifth-generation, or 5G, service.

Those plans face pushback in many places, and not just from residents. Officials in some cities say they don’t have enough staff to process applications for dozens or even hundreds of new installations. In some smaller towns, officials say they lack the expertise to review the new technology, though they’re working fast to get up to speed.

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Mayors, Counties Balk at FCC 5G Streamlining Proposal

By Jason Plautz, Sept. 13, 2018 | Original article here.

Dive Brief:

  • The U.S. Conference of Mayors (USCM) said in a statement that it would sue the Federal Communications Commission (FCC) if the commission does not change a proposed policy that would preempt local control in a bid to streamline installation of 5G wireless infrastructure.
  • The National Association of Counties is also opposing the proposal, telling POLITICO it would "effectively prevent local governments from properly examining the impact that construction, modification or installation of broadcasting facilities may have on public health, safety and welfare of the local community."
  • The proposal from FCC commissioner Brendan Carr would bar municipal laws prohibiting deployment of 5G small cells and would set deadlines for municipalities to approve or disapprove applications to install small cells or build new poles. The plan is set for a vote on Sept. 26.

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Mill Valley Blocks Small Cells Over Health Findings

By Michelle Robertson, September 11, 2018 | Adapted from this SF Gate article

Mill Valley has yet to receive a single proposal to deploy 4G or 5G so-called "Small Cell" towers within town limits. That has not stopped city officials from blocking the installations in residential areas altogether. Most telecommunications companies say that the future is 5G, but that future will not be coming to the residential zones in this upscale town in Marin County.

The Mill Valley City Council voted unanimously last week to block deployments of 4G and 5G towers in the city’s residential areas by activating an urgency ordinance. The legislation, which is active immediately, allows authorities to enact regulations protecting the health and safety of residents. San Anselmo and Ross have already adopted similar ordinances.

Mill Valley Mayor Stephanie Moulton-Peters told the Marin Independent Journal.

"The urgency ordinance has standards to limit and prohibit the installations of devices in residential neighborhoods, but there is more that we can do,"

The paper said residents from all over Marin "packed the council chambers" to urge officials to prevent cell phone companies from building 4G and 5G towers on utility and light piles in the city’s residential areas.The public’s opposition to the towers was supported by substantial information entered into the public record reporting, neurological, cardiac and other health problems, associated with exposures to RF electromagnetic microwave radiation (RF-EMR) at levels far below the outdated Federal RF-EMR exposure guidelines

According to the EMF Safety Network, the consequences of 24/7 exposures to RF microwave radiation include

  • DNA damage
  • Headaches
  • Learning and memory disorders
  • Sleep problems and fatigue
  • Melatonin suppression
  • Increased rates of heart and brain cancer

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AT&T Will Introduce Mobile 5G in 12 Cities in 2018

From Sept. 10, 2018 Press release here.

2018: Seven Initial Cities (all over)

. . . where AT&T has already announced plans to launch mobile 5G in 2018

  1. Atlanta, GA
  2. Charlotte, NC
  3. Dallas, TX
  4. Indianapolis, IN
  5. Oklahoma City, OK
  6. Raleigh, NC
  7. Waco, TX

2018: Five More Cities (some parts only)

. . . where AT&T AT&T plans to introduce mobile 5G in 2018

  1. Houston, TX
  2. Jacksonville, FL
  3. Louisville, KY
  4. New Orleans, LA
  5. San Antonio, TX

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Mill Valley joins effort to constrain 5G proliferation

By Adrian Rodriguez, September 9, 2018 | arodriguez@marinij.com | Original Marin Independent Journal here.

The city of Mill Valley has enacted an urgency ordinance to regulate “small cell” towers amid concerns that cellphone companies want to grow their 5G networks and install new equipment in Marin.

Mill Valley Mayor Stephanie Moulton-Peters:

“We do intend to do more work and studies to craft a permanent ordinance within the next year. The urgency ordinance has standards to limit and prohibit the installations of devices in residential neighborhoods, but there is more that we can do.”


Mill Valley City Council: General Public Comment — Adverse Effects of 4G/5G Densification

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Health Implications of 4G and 5G Telecom Systems

by AgostinoDi Ciaulaab, Division of Internal Medicine, Hospital of Bisceglie (ASL BAT), Bisceglie, Italy, International Society of Doctors for Environment (ISDE), Arezzo, Italy | Adapted from this International Journal of Hygiene and Environmental Health Abstract


  • RF-EMF and RF-EMR exposure is rising and health effects of are under investigation.
  • Both oncologic and non-cancerous chronic effects have been reported.
  • 5G networks could have health effects and will use MMW, which has been scarcely studied.
  • Adequate knowledge of RF-EMF and RF-EMR biological effects is needed in clinical practice.
  • Underrating the problem could lead to a further rise in noncommunicable diseases.


The spread of radiofrequency electromagnetic fields (RF-EMF) and radiation (RF-EMR) is rising and health effects are under investigation. RF-EMF and RF-EMR promote oxidative stress, a condition involved in cancer onset, in several acute and chronic diseases and in vascular homeostasis. The World Health Organization’s International Agency for Research on Cancer (IARC) classified RF-EMF in 2011 as Group 2B “possibly carcinogenic to humans”. More recent studies suggest reproductive, metabolic and neurologic effects of RF-EMF and RF-EMR, which are also able to alter bacterial antibiotic resistance.

In this evolving scenario, although the biological effects of 5G communication systems are scarcely investigated, an international action plan for the development of 5G networks has started, with a forthcoming increment in devices and density of both 4G and 5G Close Proximity Microwave Radiation Antenna – Wireless Telecommunications Facilities (CPMRA-WTFs), aka "Small Cells", which are not small at all, when one considers the power output of the from the deployed grid.

Preliminary observations show that exposures to RF-EMR from millimeter waves (MMW) are the following:

  • increase skin temperature,
  • alter gene expression,
  • promote cellular proliferation
  • promote synthesis of proteins linked with oxidative stress, inflammatory and metabolic processes
  • generate ocular damages,
  • affect neuro-muscular dynamics.

Available findings seem sufficient to demonstrate the existence of biomedical effects, to invoke the precautionary principle, to define exposed subjects as vulnerable and to revise existing RF-EMF and RF-EMR exposure limits. An adequate knowledge of pathophysiological mechanisms linking RF-EMF and RF-EMR exposures to health outcomes should be useful in the current clinical practice, particularly in considering the evidences pointing to extrinsic factors as heavy contributors to cancer and to the progressive epidemiological growth of noncommunicable diseases.

FCC Seeks to Expedite Deployment of 5G Wireless Networks

Agency expected to Vote to approve plan to override local rules on 9/26/18

By John D. McKinnon Sept. 4, 2018 } Original Wall St. Journal article here.

WASHINGTON — Federal regulators will vote in three weeks on a plan to accelerate next-generation 5G wireless networks around the U.S. by overriding some local rules that could hold up deployment. The plan is expected to win approval from the Federal Communications Commission at a meeting in late September. FCC Commissioner Brendan Carr, a Republican, announced the new 5G deployment plan in a speech in Indianapolis on Tuesday.

FCC Commissioner Brendan Carr Announces FCC’s Next Steps on 5G:
9/26/18 Vote to Streamline Small Cell Deployment

FCC Commissioner Brendan Carr:

I am announcing today the next steps in the FCC’s efforts to bring more broadband to more Americans. On September 26, 2018, the FCC will vote on a proposal designed to support small cell deployment. It contains four main ideas.

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