2023-05-08 We need the Precautionary Principle NOW

1) Dr. Moskowitz shared a document published but not available to the general public. It was written by a former FCC Attorney, Erica Rosenberg, who is revealing the extent to which the FCC has been captured by the telecom industry. It is below in Letters.


&  4) – https://stopsmartmetersbc.com/2023-04-20-how-the-fcc-has-failed-to-protect-the-environment/

2) From EMR Australia, a very interesting interview discussing the need for the Precautionary Principle to be applied to EMF now rather than waiting for more evidence.

Wireless radiation — the new asbestos?

“Lyn McLean talks to David Gee, an expert in risk and precaution. In his work for the European Environment Agency, David compiled reports on 35 harmful environmental agents, including as X-rays, asbestos, lead, tobacco and CFCs – and now he shares his knowledge and experience about wireless radiation and suggests what we should be doing about it.”

  https://www.youtube.com/watch?v=LJQ-CLdNWWg    (58 min.)

3) Despite the fact that there is a major mis-statement in this letter, I am sharing it because it expresses concerns of many living on Salt Spring as well as in other communities where Rogers, Telus, and other telecoms are ignoring the ramifications of erecting towers and adding more transmitters near homes, schools and environmentally sensitive areas. . Mr. Proctor is wrong when he states that the cell tower that is already at this site is “relatively benign” compared to the new tower. All cellular/wireless RF/EMF is potentially dangerous, and the current transmitters most likely are 4G in the 900-2500Mhz range. These frequencies penetrate deeply, travel far and are very biologically active as shown by hundreds of studies.

(click on photos to enlarge)


Letters to the editor – Channel Ridge residents deserve support by Gillean Proctor – GI Driftwood (p.7) – May 03, 2023:




Environmental Procedures at the FCC: A Case Study in Corporate Capture

“An environmental and public lands policy attorney with over 30 years of experience, including in agencies, Congress, and academia, Erica Rosenberg worked at the FCC’s Wireless Telecommunications Bureau from 2014 to 2021; for the last six of those years, she was Assistant Chief of the Competition and Infrastructure Policy Division.”

Erica Rosenberg (2022). Environmental Procedures at the FCC: A Case Study in Corporate Capture. Environment: Science and Policy for Sustainable Development. 64:5-6, 17-27, DOI: 10.1080/00139157.2022.2131190.

No abstract

“With infrastructure including millions of miles of fiber optic cable and lines, thousands of towers, earth stations and satellites, and hundreds of thousands of small cells, 1 the telecommunications industry leaves a significant environmental footprint: wetlands filled, viewsheds marred, cultural resources damaged, and habitat destroyed. As the agency overseeing telecommunications, the Federal Communications Commission (FCC) regulates radio, TV, satellite, cable, and both wireline and wireless communications—and associated entities like Verizon, AT&T, and broadcast and radio corporations. It also plays a critical role in providing universal broadband and telecommunications access, and authorizing facilities associated with wireline and wireless build-outs. Yet the FCC fails to fulfill its mandatory duties under the National Environmental Policy Act (NEPA) in multiple and significant ways. 2 ….”

“Applicants and licensees submit no documentation of their determination that their project is categorically excluded, and the agency does not track categorically excluded actions. With the applicant conducting the initial environmental review of whether the project is categorically excluded by assessing the list of extraordinary circumstances (i.e., the NEPA checklist), as well as preparing the environmental assessment, the burden falls on the public to learn of the proposed action and to raise a potential effect.

But categorically excluded actions, including authorization of certain towers, do not receive public notice; only applications for towers that require registration (generally taller than 199 feet) are put on notice, and those may or may not have associated environmental assessments. In addition to towers under 200 feet not posing an air hazard, these stealth projects that the agency has no record of include small wireless facilities associated with 4G and 5G.

That the public has no access to this information is particularly problematic in the radio frequency context, where applicants are required to meet radio frequency emissions standards or submit an environmental assessment. If the applicants do analyze the checklist and radio frequency studies at all, they routinely categorically exclude small wireless facilities, despite growing public concern about radio frequency associated with such technologies. Without access to the documented checklist, the public has little to no basis on which to refute or comment on checklist conclusions on radio frequency. And given the streamlined process, citizens often find out about facilities only after they are built ….”

Conclusion: Prospects for a More Accountable FCC

Clearly, the FCC’s NEPA process falls short of what NEPA and Council on Environmental Quality require.

• It ignores major federal actions requiring environmental review, such as its distribution to industry of billions of dollars that support build-outs for updated wireless service, or improperly deems certain major federal actions non-major federal actions to circumvent NEPA.

• Its NEPA rules create an unsupported and overbroad categorical exclusion so that, for example, satellite licensing and submarine cable licensing are excluded from review.

• With little oversight or tracking, it delegates environmental review of NEPA determinations to industry proponents of the project.

• It fails to vigorously enforce its rules so that industry noncompliance is rampant.

• It fails to provide adequate notice and opportunities for public comment.

• It fails to make environmental documents, including radio frequency emissions studies, publicly available or readily accessible.

• It routinely ignores or dismisses public comments and concerns and places an unfair burden of proof on the public when it raises concerns.

These practices serve to facilitate deployment for carriers while ignoring environmental rules and the public. Besides environmental costs, the FCC’s approach bespeaks a lack of transparency and accountability that undermines good governance and erodes democracy. It also bespeaks an agency completely captured by the entities it is tasked with regulating.

Recent Biden-era NEPA implementing rules 60 require agencies to revisit their NEPA rules and procedures by September 2023. 61 They also require that the agencies have the capacity to comply with NEPA, 62 something the FCC has to date lacked. Perhaps when Council on Environmental Quality reviews the FCC’s procedures this time, it will scrutinize the rules more carefully and hold the agency to a higher standard for NEPA compliance.”


Sharon Noble, Director, Citizens for Safer Tech

“The scars of others should teach us caution.”     St. Jerome

Sent from my wired laptop with no wireless components. Practice Safe Tech.


Smart Meters, Cell Towers, Smart Phones, 5G and all things that radiate RF Radiation