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 Europe….”
“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/.
Dr. Manville’s memo is available at http://bit.ly/Manvillewildlife.
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