Testimony of Stephanie Smith Kinney before the National Capital Planning Commission
March 15, 2001
TESTIMONY IN FAVOR OF STRINGENT REGULATION FOR ANTENNA TOWERS
Stephanie Smith Kinney
February 22, 2001
I am a citizen who lives in an area of Washington, D.C., adversely impacted by the indiscriminate siting of telecommunication towers and antennae without regard to their aggregate impact on the health and welfare of the community, the urban landscape, civilized esthetic values and any sense of responsibility to the residents of the area. I am here tonight to support the idea that the Commission should seek to minimize the exposure of federal employees and the public to electromagnetic fields (EMFs) but to caution against a policy that would concentrate towers and antennae in a limited area, unless it happens to be uninhabited.
In an effort to become better informed about the issues surrounding the construction of a 750 foot tower in Tenleytown, I contacted one of the foremost EMR survey experts on the East Coast. I was taken aback to learn that current FCC regulations only apply to individual towers and that there are no provisions for taking into consideration the aggregate effects of concentrations of towers in a given area. This is particularly worrisome for people who live on high ground such as the Mt. Saint Alban rise in the District or other similar zones favorable for tower construction from a technical point of view.
I urge the Commission to bear in mind that from the standpoint of public health and safety, the issue is not just one of compliance of an individual tower with FCC EMR guidelines but also the cumulative or aggregate effect of multiple towers in a given area. To group towers in "tower farms," as has been proposed, will significantly increase the radiative intensity to which anyone who lives, works or frequents the affected area is subjected. Based on what I have learned about the potential additive impact of a 750 foot antenna tower in my area of town, there is cause for concern. Anyone wishing to raise a new tower should have to first demonstrate through appropriate, standard emissions survey techniques that the aggregate level of EMR emissions in an affected area will not surpass FCC guidelines. A prudent avoidance approach requires no less.
To be specific, sound planning for the district should first require due public notice for proposed antennae towers and community consultation. Given the proliferation of towers in the district, due consideration should be taken of their aggregate impact on the lives and health of area residents, students and employees. The burden of proof that the construction of a new tower will not adversely affect area residents should be on the company that wishes to build the tower.
If possible, I would like to see applicants for new tower and antennae permits be required to conduct "hot spot" surveys of the area in which they wish to construct and present this data with their application. Using standard calculations subject to technical peer review, applicants should be required to estimate the increase in radiative intensity that the full use of their proposed tower will create, i.e. the intensity that will result from the maximum number of antennae the tower can hold even if the initially projected number of antennae to be attached is less than that number. (One must assume that applicants intend to maximize their investment, especially when "speculative tower construction" is involved.)
Without regard to the cumulative impact of multiple towers, higher elevation areas in the District will become de facto "tower farms," a disturbing prospect made worse by any policy of encouraging such an approach. The Commission should consider the cumulative as well as individual impact of towers on human health and safety in the area, not to mention the impact on other important community values such as sound urban planning, esthetics and civilized residential and community environments.