ATTACHMENT 13
was actually submitted. So the approval was based on, "trust us, but we won't show you our work, reviewed by people we paid." Per my other mail (different thread), the Applicant confirms that given the orientation and distance of these 9 antennas to the adjacent homes, exposure will be at 83-85% of maximum, or excessive, radiation levels, as measured against Office of Engineering and Technology Bulletin 65, aka OET-65. The Bulletin was not provided, but I was able to locate it here (see Appendix A, p. 67 for exposure level limits):
https://transition.fcc.gov/oet/info/documents/bulletins/oet65/oet65.pdf What the Applicant does not include is that exposure levels in OET-65 are defined at most with 30 min. of exposure. Per Sunny Talwar's questions at today's meeting, whose 2nd bedroom windows would be facing directly at the site at eye level, is how exposure risks are determined with 24/7 exposure, not just 30 min. It cannot be accepted at face value that the Applicant is being sincere with their statements or thorough with their analyses that everything is compliant with FCC guidelines without releasing the data to back it up. Note, the Applicant had already provided in their earlier material that David Allen Burgess was their consultant who performed their RF Emissions Evaluation. As you saw, David Burgess responded via video on today's call. But there was no account by him on RF exposure or safety. Any subsequent site reviews must include released analysis around RF exposure risks, and reviewed by an independent resource or agency.
Lastly, Councilmember Patino's concerns about litigation by the Applicant if a permit denial is actioned must be considered. But as outlined below in this thread, the permit relies on a CEQA exemption that should be invalid in this case, as the site size is beyond the exemption limits. Per CEQA Section 15303, an exemption is limited to 2500 sq. ft. The combined project size is 2679 sq. ft. So the City would have grounds for denial outright, pending complete CEQA compliance. From today's meeting, the Planning Commission said this objection was reviewed, and did not apply, but they did not provide more information around their conclusion. I think this exemption invalidation needs to be reconsidered more closely, and more transparently.
Thank you All again for your support in making sure Union City does the right thing as best it can for its people. This is the Leadership our City needs and deserves.
Eugene Ho and Jean Hsien
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City take steps to ensure that local environmental balance is not further disrupted by technological infrastructure.
Community and Aesthetic Concerns:
The presence of a large antenna structure near residential properties can also impact property values and the visual character of our neighborhood. Many residents, myself included, value Union City’s family-friendly, environmentally conscious atmosphere. I believe there are alternative sites — such as commercial or industrial zones — where this installation would be more appropriate and less disruptive.
Request for Action:
I respectfully request that the City:
1.Reconsider the proposed location of this antenna installation.
2.Conduct or commission an independent environmental and health impact assessment before proceeding.
3.Provide a transparent opportunity for public comment and community input prior to any approval.
Thank you for your attention to this matter. I trust that Union City will prioritize the wellbeing of its residents and the protection of our local environment in making its decision.
Sincerely,
Sooraj Ram