Letter to the National Park Service from the Environmental Health Trust
This thirteen page letter to the National Park Service from the Environmental Health Trust, dated April 10, 2019, summarizes the scientific basis for major health and environmental concerns about a proposal to install wireless telecom facilities in Grand Teton National Park.
The letter summarizes research on harm to the environment and wildlife from wireless radiation exposure. Furthermore, it addresses the following topics: (1) research on harm to humans; (2) rapid increase in wireless radiation exposure; (3) inadequacy of the Federal Communications Commission’s exposure limits to protect humans; (4) greater susceptibility of children; (5) recent appeals from hundreds of experts to reduce exposure limits; and (6) other cell tower safety hazards. 

This well-documented letter (81 references) can be downloaded from the following link:
July 18, 2016

A Briefing Memo by Dr. Albert Manville

Albert M. Manville, II, Ph.D. A Briefing Memorandum: What We
Know, Can Infer, and Don’t Yet Know about Impacts from Thermal and Non-thermal
Non-ionizing Radiation to Birds and Other Wildlife — for Public Release. July
14, 2016.
In this memo, Dr. Manville reviews the scientific
literature that examines the impacts on wildlife from exposure to radio
frequency radiation. 
He observes that although the FCC has standards to protect
humans from the heating  (i.e., thermal) effects of wireless radiation exposure from cellular and broadcast towers,
no standards exist to protect wildlife from thermal or non-thermal effects:
“The radiation effects on
wildlife need to be addressed by the Federal Communications 
Commission (FCC), the
Environmental Protection Agency (EPA), the Department of Commerce, the U.S.
Fish and Wildlife Service (FWS) and other governmental entities.”
Dr. Manville concludes with the following statement:
“In summary, we need to better
understand … how to address these growing and poorly understood radiation
impacts to migratory birds, bees, bats, and myriad other wildlife. At present,
given industry and agency intransigence … massive amounts of money being spent
to prevent addressing impacts from non-thermal radiation — not unlike the
battles over tobacco and smoking — and a lack of significant, dedicated and
reliable funding to advance independent field studies, … we are left with few
options. Currently, other than to proceed using the precautionary approach and
keep emissions as low as reasonably achievable, we are at loggerheads in
advancing meaningful guidelines, policies and regulations that address
non-thermal effects….”
Dr. Manville recommends that the U.S. adopt the following recommendations because federally-protected wildlife species are currently in danger from RFR exposure:
“We desperately need to conduct
field research on thermal and non-thermal radiation impacts to wild migratory
birds and other wildlife here in North America, similar to studies conducted in
“Studies need to be designed to
better tease out and understand causality of thermal and non-thermal impacts
from radiation on migratory birds…. efforts need to be made to begin developing
exposure guidelines for migratory birds and other wildlife …”
“To minimize deleterious radiation
exposures, these guidelines should include use of avoidance measures such as those developed
by the electric utility industry for bird collision and electrocution avoidance
“Studies need to be conducted on
the use of “faux” branches (i.e., metal arms that mimic pine or fir branches)
on cell and/or FM towers intended to disguise the towers as trees, but provide
nesting and roosting opportunities for migratory birds including Bald Eagles,
which will almost certainly be impacted both by thermal and non-thermal
radiation effects.”
“Agencies tasked with the
protection, management, and research on migratory birds and other wildlife …
need to develop radiation policies that avoid or minimize impacts to migratory
birds and other trust wildlife species.”
“As Levitt and Lai (2010)
concluded, we do not actually need to know whether RFR effects are thermal or
non-thermal to set exposure guidelines. Most scientists consider non-thermal
effects as well established, even though the implications are not fully understood.”
“Given the rapidly growing
database of peer-reviewed, published scientific studies (e.g., 
http://www.saferemr.com, School
of Public Health, University of California, Berkeley), it is time that FCC
considers thermal and non-thermal effects from EMR in their tower permitting,
and incorporates changes into their rulemaking regarding ‘effects of
communication towers on migratory birds.’”
Dr. Albert Manville II is an adjunct faculty member at Johns
Hopkins University. He served as a senior wildlife biologist with the U.S. Fish
and Wildlife Service from 1997 to 2014.  He chaired the Communication Tower Working
Group, partnering with the communications industry, federal and state agencies,
researchers, and non-profit organizations. He testified more than 40 times
before Congress and other governmental bodies and published more 170 papers.
For more information, see http://advanced.jhu.edu/about-us/faculty/albert-manville/.