Council Members:

I encourage you to pass this ordinance tonight.

My interest is in minimizing the exposure of Hoboken residents to harmful levels of radiation.

This can only be accomplished indirectly and imperfectly because the City and State are pre-empted from regulating cell phone transmitters based upon health effects as long as FCC radiation guidelines are not exceeded.  Unfortunately, these guidelines are far too lax:  they are approximately 5000 times higher than those recommended by experts in the field, and allow radiation levels 100 times higher than those that have been shown to produce negative health effects, including cancer.

But the 1996 Federal Communications Act that prevents the City from protecting residents from dangerous levels of radiation that comply with FCC regulations does allow cities to enforce FCC compliance and to regulate cell phone antennas in other ways, for other reaqsons, that can be useful in protecting health.

This ordinance, e.g., requires that cell phone service providers MINIMIZE the number of cell antenna sites and erect them preferentially in non-residential areas.  The ordinance also requires that evidence that antenna site minimization and placement criteria are being met by requiring providers to map an inventory of existing antenna sites and to prove that their proposed new antenna sites are appropriately placed to conform with the ordinance.

I have done some preliminary calculations and have discovered:

(1.)  that the placement of antennas in cell tower use variance applications recently approved by the Zoning Board expose near neighbors to levels of radiation that create potential health hazards and, in one case (329-333 Jackson St., Verizon Wireless applicant), the site produced radiation levels at 50 feet, potentially within proximity of neighboring windows, which may actually have exceeded the FCC danger thresholds of 500 microwatt/sq.cm.

(2.)  that it is safe to erect cell antenna sites on residential roofs ONLY IF there is a limited power output so that only a limited number of phones are served per site.  (E.g. 44 sites, each serving 23 phones, would be required to provide service to 1000 cell phones if the nearest neighbor is 50 feet away.)  Unfortunately, the cell phone service providers do not do it that way: because the antennas they erect in residential neighborhoods are designed to service too many phones, their radiated signals are too strong for safety.

(3.)  that if the antenna sites are moved away from residential areas, then more phones may be served per site, as the ordinance and the providers both desire, and the nearest residents to the site are exposed to safer levels of radiation.  (E.g. if the antenna sites are moved 250 feet (about one short block) away from residents, then only 9 sites, each servicing 115 phones, can service a total of 1000 cell phones, with good reception for the user and safety for the nearest resident.)

In order to optimize the placement of cell phone antenna sites, it is very important to have an accurate INVENTORY of the existing sites, their power output, and the number of phones they are servicing.  This is required by the ordinance BEFORE permission is given to erect more antenna sites.  This information can be used for two purposes:

(1.)  City health officials can verify that FCC guidelines have not been, and will not be, violated by existing and proposed installations.  This can only be accomplished if the cumulative impact of all antenna sites are taken into account.

(2.) This data can be used to minimize the number of antenna sites needed to safely service all cell phone users by optimizing their placement.  This good not only for the public, whose health risk will be reduced, it will be good for the cell phone service provider, who will be able to service their customers with a minimum number of installations, power, and cost.

I am willing to work with health and zoning officials in deciding which data is needed for a complete and proper inventory of antenna sites and for optimizing the placement of the antenna sites to insure public safety and sufficient signal strength for cell phone operation.

But it is essential that the installation and placement of telecommunications transmitters be immediately brought under the regulation of law to protect our community.  This ordinance is a start.

Thank you for your kind attention.