ATTACHMENT NO. 1
May 3'd, 2023
City of Fontana City Council Mayor - Acquanetta Warren Council Member - Phillip Cothran 8353 Sierra Avenue Mayor Pro Tem - Peter Garcia City Clerk - Germaine Key Fontana, CA 92335 Council Member - John Roberts City Treasurer - Janet Koehler-Brooks Council Member - Jesus Sandoval
RE: Master Case (MCN) No. 22-054 and Administrative Site Plan (ASP) No. 22-013 "The applicant, Eukon Group, is proposing to install wireless telecommunications equipment consisting of twelve (12) panel antennas, fifteen (RRUs) on an existing Southern California Edison transmission tower and ancillary wireless equipment located at ground level within a block wall enclosure.
Dear Members of the Fontana City Council,
I am writing to appeal the decision made at the Public Hearing on April 4, 2023 regarding the proposed telecommunications equipment install at North of Terra Vista Drive, east of Condor Avenue (APN:
0239-101-17).
During the first and second public hearings, residents addressed many hazards this project would expose our neighborhoods to. These hazards are detailed and supported by peer-reviewed studies and industry experts and reports (Please see attached files). I believe that the decision to approve the project to move forward for the second time was based off inadequate information. AT&T and the City of Fontana did not disclose all the requested information to the public before or during the public hearing. I will submit additional scientific studies, news reports, and information that refutes what the AT&T representatives and experts and the City of Fontana Planning department presented at the public hearing on April 4h. Below were some of the hazards we are still concerned about:
1. Fire & Wind Hazard & Equipment Collapse 7. Inform to Consent
2. Real Estate Devaluation & Property Blight 8. Criminal Activity (Aesthetic Issues) 9. Health & Medical Risks (Increased
3. Noise Nuisance Radiation)
4. Insurance Risk 10. Security Risks, Cyber Crime & Fraud
5. Environmental Impact 11. Worker Deaths, Accidents, & Suicides
6. Seismic Activity
These hazards are detailed below with citations and links to information. This information was previously submitted to the Planning Director and Planning Commission. Apparently, none of the above hazards raised any concerns to either of these departments. However, I feel that many areas were overlooked. We did not see evidence of proper testing from independent industry experts, confirmation of legitimate FCC safety certificates/licenses (we were not shown any documentation), and it was not Appeal of Master Case (MCN) No. 22-054 and
Administrative Site Plan (ASP) No. 22-013 Page 1
justified that there is an actual need for additional telecom equipment installed in this particular area.
Did AT&T provide proof that a significant gap in coverage actually exists in the location where they propose to install this wireless facility? Was a drive test conducted? Currently, there are over ninety (90) towers and 118 antennas within a three mile radius of this proposed site.
Additionally, we were not shown any data that AT&T's equipment meets the safety guidelines. In fact, the issue of simultaneous exposure to multiple frequencies was not addressed. This new equipment will emit non-ionizing radiation; this absolutely heightens the exposure that the existing SCE transmission tower radiation already emits. How is this issue being mitigated? Has this been tested on similar project sites with the same setup? How do residents know this even meets the FCC's outdated safety guidelines? We know the FCC does not come out and test every site. Is AT&T testing this site? It is your job as elected officials to protect the communities you serve. Planning departments have failed us.
They allowed this project to move forward, without having these vital concerns addressed for our community. I ask that the City Council pick up where the Planning Director and Planning Commission left off and protect our neighborhoods from these risks.
Please see below the explanation and details on the above hazards we are facing from this telecommunications install:
1. Fire, Wind, and Equipment Collapse - Our neighborhood is located in a high risk fire and wind zone.
There have been several fires in this vicinity within the last few years. Fire and wind hazards and equipment collapse are real risks associated with telecommunications equipment. Strong winds like the ones Fontana has most of the year, can cause damage to cell towers and communications equipment, causing fires and falling debris. According to OSHA (Occupational Safety and Health Administration), cell phone tower accidents involving falling debris and equipment, represents one of the most common causes of tower-related injuries in the country. In addition, telecommunications equipment can easily overheat or fail due to surges, equipment failure, and extreme weather. This can create arcs and spark a fire, particularly during high wind and wildfire conditions. This risk is especially concerning given the constant wildfires and wind storms in our area. As it states on the City of Fontana's website "Fire is and always has been a natural part of this landscape. Wildfires are now a year-round reality in San Bernardino County. This means that both firefighters and residents have to be on heightened alert for the threat of wildfire. It's not a question of if but when the next wildfire will occur." By denying this telecommunications equipment project in our neighborhoods, this would show that Fontana means what it says about fire preparedness and safety.
According to a study by the National Fire Protection Association (NFPA), cell tower fires are becoming increasingly common due to aging electrical equipment and poor maintenance practices. All electrical equipment will fail; the question is will the failure cause an unnecessary and unexpected fires? This equipment will be installed in a field area with dry brush and vegetation. Since this equipment will be directly installed on an existing high powered electricity transmission tower, this increases the risk of electrical malfunctions. Another issue is the backup power source. Backup generators are typically required for these telecom facilities to operate. That means a fuel source like gasoline or diesel, which is highly flammable, would need to be used to power the generator. This adds to the fire hazard since our homes are only yards away. North Fontana is also known for having strong constant winds that make Appeal of Master Case (MCN) No. 22-054 and
Administrative Site Plan (ASP) No. 22-013 Page 2
fires move fast and erratic. Going forward with this project greatly endangers the lives of our firefighters, residents, homes, and valuables.
Susan Foster, who is a utility & fire prevention consultant, medical writer, and honorary firefighter, has written a white paper on fire risks from telecommunications equipment in areas of Southern California.
Quoting from her white paper:
CELL TOWER FIRES ARE ELECTRICAL FIRES: Here is what happens when a cell tower catches on fire.
Electrical fires cannot be fought through conventional means. That means the firefighters can arrive on scene and do nothing except put short bursts of water on the surrounding area. They cannot touch a blazing CELL TOWER with water because to do so is to risk electrocution. The fire department will call the utility company to cut power. Most of the firefighters I interviewed specifically related to fighting cell tower fires said they are trained to let a cell tower fire burn itself out while they wait for utilities to cut the power. Imagine a 5G cell in somebody's front yard, or attached to the light post at the corner of a property. Imagine a Santa Ana wind with 50, 60, 70 mile an hour gusts. It takes the utilities 10 to 30 minutes on a good day to get the power shut off. It can take up to two hours if distribution and/or transmission lines are attached to the same monopole.
Susan also mentions that a list of toxic substances that may develop during arcing or fire that may impede fire suppression efforts. "The intense heat of an electrical arc may turn non-hazardous substances into hazardous substances. Special protective equipment may be required. Electric arcs instantly reach temperatures of thousands of degrees. Normally non-hazardous material may become hazards. Metals may vaporize and damage lungs. Arcing or fire may create a pressure wave that can imperil life, health and property."
2. Real Estate Devaluation & Property Blight (Aesthetic Issues) - Property values go down when cell towers and communications equipment are in sight of the home. This has been reported by national real estate firms. According to a survey published in Realtor Magazine, 94% of potential homebuyers and renters do NOT want to live near properties that are located by cell towers, and would pay LESS for a property in close vicinity to cellular antennas and telecommunications equipment. 79% of the respondents said they would NEVER purchase or rent such a property. Real estate organizations show that a price drop between 15 - 20% happens when cell towers and communications equipment are next to homes. According to HUD, Appraisal & Property Requirements, "The appraiser must indicate whether the dwelling or related property improvements is located within the easement serving a high-voltage transmission line, radio/TV transmission tower, cell phone tower, microwave relay dish or tower, or satellite dish (radio, TV cable, etc)."
The California Association of Realtors' Property Sellers Questionnaire specifically lists "cell towers" on their disclosure form for sellers of real estate. The seller must note "neighborhood noise, nuisance or other problems..." and this includes cell towers and high voltage transmission lines that are included on the long list of problems. The equipment can also be an eyesore, detracting from the aesthetics of the neighborhood.
Appeal of Master Case (MCN) No. 22-054 and
Administrative Site Plan (ASP) No. 22-013 Page 3
On the City of Fontana's website, blight is defined as "Buildings in which it is unsafe or unhealthy for persons to live or work." This telecommunications equipment will make living and working from home unsafe and unhealthy due to the above mentioned safety hazards. Blight also refers to property that is unattractive or unsightly. Having (12) twelve antennas, (15) fifteen RRUs, plus ground level ancillary equipment, and a block wall will be an unattractive addition. This will block our mountain view and ruin our skyline. This unsightly and bulky equipment will add unnecessary objects in plain sight, creating a junkyard in the sky, set on the existing transmission tower. Many of us purchased our homes for the mountain views we have from our yards and do not want these views obstructed.
3. Noise Nuisance - Noise nuisance is another concern. The constant hum of AC units and generators can be a nuisance for nearby residents, particularly at night when noise levels are typically lower.
Studies have also shown that prolonged exposure to noise can have negative effects on health, including increased stress levels and sleep disturbances. The existing transmission tower already generates noise.
How much more nuisance sound will be created from the added telecommunications equipment?
4. Insurance Risk - Due to the high risk fire zone we live in, some home insurance companies have dropped coverage in our area. For the ones who will insure our homes, they charge homeowners double the rates. My fear is that once the insurance companies get wind of this new equipment installation, knowing the many hazards, will either drop us as clients, or raise prices even higher! Telecommunications equipment can increase the risk of property damage and liability claims, leading to higher insurance premiums for homeowners. In addition, telecom companies are not insured for RF radiation, Insurance authorities classify Electromagnetic Radiation and 5G as "High Risk" and basically clarify that damages (medical, property, etc.) will not be covered. Lloyd's of London is one of the world's largest insurance companies who excludes any liability coverage for claims; "Directly or indirectly arising out of, resulting from or contributed to by electromagnetic fields, electromagnetic radiation, electromagnetism, radio waves or noise."
5. Environmental Impact - The construction and operation of telecommunications equipment can have a negative impact on our local environment. We live right next to a wilderness area. "Science continues to reveal biological harm to ALL living organisms, including animals, plants, trees, insects, and bacteria, from radiofrequency EMR exposure with levels at or below current U.S. safety guidelines." "Affects of non-ionizing electromagnetic fields on flora and fauna" in the journal "Reviews on Environmental Health," points out that the FCC has long ignored studies on the harmful impact of wireless [equipment] on wildlife. The 150 page study of over 1,200 peer reviewed studies finds that birds, insects and animals are uniquely sensitive to wireless radiation. It identifies low-level wireless as a pollutant and warns against escalating radiation levels with 5G technologies. The researchers highlight the FCC's failure to protect the environment.
In 2013, a group from the Institute of Environmental Sciences in the Netherlands published a thorough review of the ecological effects of RF-EMF, based on 113 published, peer-reviewed studies. They found that wireless radiation had a significant effect on birds, insects, other vertebrates, and multiple organisms and plants in 70% of the studies.
Appeal of Master Case (MCN) No. 22-054 and
Administrative Site Plan (ASP) No. 22-013 Page 4
6. Seismic Activity - Seismic activity is also a concern. The installation of equipment in earthquake- prone areas like Fontana can increase the risk of damage to both the equipment and nearby buildings.
According to the California Earthquake Authority, San Bernardino County has a 75% likelihood of one or more magnitude 7.0+ earthquakes striking our area. Our notable fault lines are the San Andreas & San Jacinto. "A large part of the region's population lives within 50 miles of the San Andreas and could be exposed to very strong levels of ground shaking in a major earthquake." We are on a fault line in this area. That means when an earthquake strikes, electrical equipment can be damaged causing fires, and send falling debris from the tower that can damage our homes, injure people, and cause fatalities.
7. Inform to Consent - Once telecommunications equipment has been installed, additional equipment can be added without resident's knowledge, or any way to oppose it. This will leave residents vulnerable to unchecked amounts of radiation and property devaluation, and health risks. "Cell towers have 2G, 3G, and 4G antennas. 5G antennas are being added to base stations worldwide. After a cell tower is erected, new antennas can be easily added and generally without any (or minimal) public participation in the decision-making process. 5G antennas can be mounted on both shorter so-called "small cells" and larger "macro" towers."
8. Criminal Activity - Telecommunications equipment can attract criminal activity, such as theft and vandalism, which can lead to additional security risks for nearby residents. Cell towers and telecommunications equipment are known to be vandalized for their expensive copper cable and valuable electronic components. If any of the components are compromised, it could not only lead to an increased fire risk, but also falling equipment.
9. Health & Medical Risks (Increased Radiation) - Exposure to increased radiation has been linked to an increased risk of cancer and other health problems. Studies have shown that prolonged exposure to radiation from cell towers can have negative effects on health. Studies have shown that people living in close proximity to cell towers and telecommunications equipment have increased risks for many health issues, including but not limited to:
• Cancers (leukemia, kidney, liver, brain tumors, • Cardiovascular Effects (Heart blood, etc.) Arrhythmia, Palpations,
• DNA Damage & Gene Expression Changes, Lipid Cardiomyopathy) Abnormalities (Double DNA strand breaks) Tinnitus
• Cognitive Decline, Developmental Disorders, & .. Effects Fetuses Learning Issues in Children Fertility
• Oxidative Stress • Electromagnetic Sensitivity
Neurological/Cognitive Effects (Dizziness, • Implanted Medical Devices Issues Headache/Migraines, Nausea, Memory Loss, & • ETC.
Fatigue)
There is already an existing SCE (Southern California Edison) transmission tower that emits its own radiation and electrical pollutants. We do not need simultaneous exposure to multiple microwave frequencies if this telecommunications equipment is added.
Appeal of Master Case (MCN) No. 22-054 and
Administrative Site Plan (ASP) No. 22-013 Page 5
The FCC has not updated safety standards for RF & EMF for over 25 years! We do not truly know the safe distance and true radiation this telecommunications equipment emits without new studies and research. We do not want to be guinea pigs and find out years later the devastating effects this equipment will have on our families and friends. The FCC does not take into account the synergistic impact of combined toxic exposures, long-term cumulative exposure impacts, and critical windows of development in children.
10) Security Risks, Cyber Crime & Fraud - The installation of telecommunications equipment can create additional security risks for nearby residents, particularly if the equipment is located near schools or other sensitive locations. "The costliest risk, and the one least thought of, is vulnerability to cyber crime and fraud. The base transceiver stations (BTS) of cell towers can be compromised by hackers who break into the code. With monitoring software installed on the BTS, these "bad actors" could monitor cell phones and text messages, as well as any digital traffic that passes through the tower. In other words, the base station can be used by hackers to spy on Internet users, and even to steal personal identification data."
11. Worker Deaths, Accidents, and Suicides - The installation and maintenance of telecommunications equipment can be dangerous work, particularly if proper safety procedures are not followed. Workers are at high risk of having accidental falls. There are documented reports of people climbing these towers in order to jump off. Additionally, a site's security fence is only a minor deterrent to would-be intruders.
I believe that the proposed location for the telecommunications equipment is not appropriate. I urge the Planning Commission to consider alternative locations that are away from residential neighborhoods, parks, and schools to ensure that we are at a safe distance from these risks. I also recommend that the commission take action to protect the health and safety of its residents by implementing stricter regulations regarding the placement of telecom equipment. It is important to note that there are several cities in California and across the US that have created strict municipal codes against telecom equipment. I believe it is time for the City of Fontana to follow suit. Thank you for your attention to this important matter.
•
Appeal of Master Case (MCN) No. 22-054 and
Administrative Site Plan (ASP) No. 22-013 Page 6
References
1. Fire & Wind Hazard & Equipment Collapse:
Californians for Safe Technology
Fire Risk in California
https://cal4safetech.org/fire-risk#caf4a9ff-23a1-4d64-abOf-ab99772f7e87 Foster, Susan. November 15, 2022. "Protecting La County's Future: How Fire Risks from Telecommunications Equipment, Climate Challenges & a Dangerous Shift Away From Environmental Review Threaten Los Angeles County's Future" Environmental Health Trust
Cell Tower Safety Risks Fires and Collapse
https://ehtrust.org/cell-tower-safety-risks-fires-and-collapse/
2. Real Estate Devaluation:
City of Fontana
FAQ: Redevelopment - What is blight?
https://www.fontana.org/FAQ.aspx?searchTerms=blight&TID=0 HUD - U.S. Department of Housing and Urban Development
Hazards & Nuisances: Overhead High Voltage Transmission Towers and Lines HUD Archives: HOC Reference Guide - Hazards & Nuisances: Overhead High Voltage Transmission Towers and Lines (Page 1-18f)
REALTOR Magazine
"Cell Towers, Antennas Problematic for Buyers" REALTOR Magazine, July 25, 2014 https://ehtrust.org/wp-content/uploads/Real-Estate-Seller-Property-Questionaire-reduced-12- 17-1.pdf
PA Association of Realtors
Do Neighborhood Cell Towers Impact Property Values?
Do neighborhood cell towers impact property values? - Pennsylvania Association of Realtors® (parealtors.org)
Appeal of Master Case (MCN) No. 22-054 and
Administrative Site Plan (ASP) No. 22-013 Page 7
3. Noise Nuisance:
EPA (US Environmental Protection Agency)
EPA Identifies Noise Levels Affecting Health and Welfare https://www.epa.gov/archive/epa/aboutepa/epa-identifies-noise-levels-affecting-health-and- welfare.html
Nuisances
Chapter 18 - NUISANCES | Code of Ordinances | Fontana, CA | Municode Library
4. Insurance Risk:
Environmental Health Trust
Insurance Authorities Rate 5G and Electromagnetic Radiation as "HIGH RISK" https://ehtrust.org/key-issues/reports-white-papers-insurance-industry/ Moms Across America
EMF Insurance
https://www.momsacrossamerica.com/insurance issue
5. Environmental Impact:
PubMed.Gov & NIH (National Library of Medicine
Effects of non-ionizing electromagnetic fields on flora and fauna, part 1. Rising ambient EMF levels in the environment
Effects of non-ionizing electromagnetic fields on flora and fauna, part 1. Rising ambient EMF levels in the environment - PubMed (nih.gov)
Effects of non-ionizing electromagnetic fields on flora and fauna, Part 2 impacts: how species interact with natural and man-made EMF - PubMed (nih.gov) Effects of non-ionizing electromagnetic fields on flora and fauna, Part 3. Exposure standards, public policy, laws, and future directions (degruyter.com)
6. Seismic Activity Risk:
Foster, Susan. November 15, 2022. "Protecting La County's Future: How Fire Risks from Telecommunications Equipment, Climate Challenges & a Dangerous Shift Away From Environmental Review Threaten Los Angeles County's Future" California Earthquake Authority
California Earthquake Risk Map & Faults by County
https://www.earthquakeauthority.com/California-Earthquake-Risk/Faults-By-County
7. Inform to Consent:
Environmental Health Trust
Top Facts on 5G: What You Need to Know About 5G Wireless and Small Cells https://ehtrust.org/key-issues/cell-phoneswireless/5g-internet-everything/20-quick-facts-what- you-need-to-know-about-5g-wireless-and-small-cells/
Appeal of Master Case (MCN) No. 22-054 and
Administrative Site Plan (ASP) No. 22-013 Page 8
8. Criminal Activity:
Environmental Health Trust
Cell Tower Safety Risks Fires and Collapse
https://ehtrust.org/cell-tower-safety-risks-fires-and-collapse/ WirelessEstimator.com
Cops collar the nation's first cell tower terrorist accused of setting fire to two California sites https://wirelessestimator.com/articles/2020/cops-collar-the-nations-first-cell-tower-terrorist= accused-of-setting-fire-to-two-california-sites/
USA Telecom Insurance Services
Risks for Cell Towers in 2019
https://usatelecomins.com/risks-for-cell-towers-in-2019/
9. Health and Medical Risks:
Physicians for Safe Technology
Cell Tower Radiation Health Effects
Physicians for Safe Technology | Cell Tower Radiation Health Effects (mdsafetech.org) Environmental Health Trust
Peer Reviewed Published Research on Cell Tower Radiation, Base Station Radiation and Heath Effects
Compilation of Research Studies on Cell Tower Radiation and Health - Environmental Health Trust (ehtrust.org)
Safer EMR
Cell Phones, Cell Towers & Wireless Safety (UC Berkeley) https://www.saferemr.com/2019/03/cellphones-cell-towers-wireless.html Physicians for Safe Technology
Cell Tower Radiation Health Effects
https://mdsafetech.org/cell-tower-health-effects/
ResearchGate
Impact of radiofrequency radiation on DNA damage and antioxidants in peripheral blood lymphocytes of humans residing in the vicinity of mobile phone base stations (PDF) Impact of radiofrequency radiation on DNA damage and antioxidants in peripheral blood lymphocytes of humans residing in the vicinity of mobile phone base stations (researchgate.net)
10. Security Risk, Cyber Crime & Fraud:
WKBN 27 First News
Expensive Cable Lines Stolen from Local Cell Tower
Expensive cable lines stolen from local cell tower | WKBN.com Appeal of Master Case (MCN) No. 22-054 and
Administrative Site Plan (ASP) No. 22-013 Page 9
USA Telecom Insurance Services
Risks for Cell Towers in 2019
https://usatelecomins.com/risks-for-cell-towers-in-2019/
11. Worker Death, Accidents, & Suicides:
Environmental Health Trust
Cell Tower Safety Risks Fires and Collapse
https://ehtrust.org/cell-tower-safety-risks-fires-and-collapse/ Appeal of Master Case (MCN) No. 22-054 and
Administrative Site Plan (ASP) No. 22-013 Page 10