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HomeMy WebLinkAboutM-95-0335RESPONSE TO "REPORT ON RADIOFREQUENCY HAZARD AND INTERFERENCE FOR PROPOSED CELLULAR TELEPHONE COMMUNICATION TOWER -SITE M159, MIAMI, FLORIDA", PREPARED BY DR. BABIJ. Mark J. Hagmann I first heard of the proposed use of this site on Thursday April 27th, and first saw this report on Friday April 28th. It was not possible for me to communicate with Dr. Babij regarding his report because of a major health crisis in his family. I feel that it is improper for a private consultant to use the letterhead from Florida International University, and to use the name of the University on the cover of a report, because this implies endorsement by the University. Dr. Babij gave only his opinions as I, another Associate Professor in his department, will give mine. The report by Dr. Babij claims to give "worst case" values of the power flux density that would be produced in the Overtown community by the transmitter, then compares these values with the "Maximum Permissible Exposure" (MPE) values in their reference number 1, and finally concludes that these values are "well within the currently accepted national safety standard." The following are my specific objections to the report: 1. The report is incomplete because if fails to provide all of the data that would be required in order to verify the calculated values of power flux density (e.g. the antenna configuration and power distribution). 2. It is my understanding that if the cellular tower were installed, then various parameters including the transmitted power could be changed in the future because those parameters are only subject to the FCC regulations in force at the time and could not be limited by the City of Miami. Thus, there is no guarantee that the values of power flux density given in the report would not be exceeded. 3. The report claims to give "worst case" values, but fails to do so because it allows only for the intensification of the fields by ground reflections, and not for the additional intensification by reflections from buildings, cars, and other objects. (M. J. Hagmann and O. P. Gandhi, "Numerical Calculation of Electromagnetic Energy Deposition in Man with Ground and Reflector Effects," Radio Science, Vol. 1.4, November -December 1979, pp. 23-29) 4. The report concludes that the MPE specified in their reference number 1 would be exceeded at distances of 35 feet or less from the tower if the antenna were approached along the peak of the main beam of the antenna. This is inconsistent with their conclusion that the values of power flux density are "well within the currently accepted national safety standard". Furthermore, It appears that far -field approximations were used in all of the calculations for the report. The report fails to specify the antenna configuration, but if the antenna is sufficiently large then near -field corrections would be required at a distance of 35 feet. The near -field corrections would cause the power flux density to be significantly greater than the value which is reported. 5. The lower Muesttrrati6n totheMIlRe report shows that the power flux density at a height of 6 fe x di rWp.q J,&G, f8 q fr4Vpjlrhe tower is approximately 0.65% of the MPE, and the item c t1._40 1 1 1 Mf atty Hirai � 5 - 335 City Clerk C.S.. power flux density at a l �t of 26 feet, at a distance of 190 f(- :rom the tower would be approximately 2% of the MPE. If we consider that the electric field, rather than the power, is the cause for biological effects then we must take the square roots of these ratios to obtain 80/o and 14%, respectively, instead of the lower values which were reported. When viewed from this aspect it appears that the fractions of the limit set by the "currently accepted national safety standard" are considerably greater than those given in the report. 6. The "currently accepted national safety standard" given as their reference number 1, is "IEEE Standard for Safety Levels with respect to Human Exposure to Radio Frequency Electromagnetic Fields, 3 kHz to 300 GHz," IEEE C95.1-1991. I am listed on the third page of that reference as a member of the committee (IEEE-SCC28) that prepared this standard. I have observed that there is considerable disagreement among the bioeffects community, and the MPE values listed in that reference were reluctantly agreed to after much compromise. The disagreement within the scientific community is documented in the two papers "Flying Blind: The Making of EMF Policy", Science, October 5, 1990, and "Electromagnetic Fields: The Jury's Still Out", IEEE Spectrum, August 1990. After working closely with many biologists and physicians for a period of 18 years I firmly believe that at present there is not sufficient knowl- edge to determine what are safe levels for the exposure of humans to electromagnetic fields. Indeed, I am dismayed that the values of MPE tabulated in reference number 1 are taken so seriously. As an example of the differences in opinion, in the former Soviet Union the MPE for exposure of the general public was 0.010 mW/cm' (U.S.S.R.-1984), which is only 1.7 % of the MPE used in the report by Dr. Babij. 7. Some of the members of IEEE Standards Coordinating Subcommittee SCC28 have expressed their concern that it may be inappropriate for engineers to make standards for human exposure. This concern is documented in the paper "Flying Blind: The Making of EMF Policy", Science, October 5, 1990. Most of the problems commonly addressed by scientists and engineers involve systems that are much simpler than the human body. In these systems the flow of energy is relatively easy to follow, so we are used to the idea that the response of a system is proportional to the input power. The values of MPE in reference number 1 were obtained by assuming that a power of 4 Watts per kilogram is required for a significant response by the human body. In fact, the situation may be much more complex. For example, a variety of effects have been attributed to human exposure to the magnetic fields of power lines at a frequency of 60 Hz, and the values of adsorbed power from such exposure are extremely small. Experiments with animals at 450 MHz (within a factor of 2 of the frequencies used with cellular telephones) suggest that there is a depletion of calcium from brain tissue, and this effect has a power window. That is, the effect is actually stronger in a certain range of power than for either larger or smaller values (S. M. Bawin, W. R. Adey and I. M. Sabbot, Proc. Natl. Acad. Sci. U.S.A. 75, 6314, 1978). In conclusion, I do not believe that the report by Dr. Babij constitutes adequate proof that there would be no significant hazards from a cellular tower at this site, and I would strongly recommend that the facility not be built at this location. I have visited the site, and I am particularly concerned because of the high population density, including day care centers and a park, located quite close to where the tower would be built. Mar Hagmann Submitted into the public Apr 30, 1995 record in cc n rtee,: on with item P Z__*).on.� ') _ 5 —' 9 5 -- 335 Mka ty Hirai Ciry Clei:k IX, MARK J. HAGMANN PRESENT POSITION: Associate Professor, Department of Electrical and Computer Engineering, Florida International University, 1986-present. PREVIOUS PROFESSIONAL EXPERIENCE: Senior Staff Fellow, Biomedical Engineering and Instrumentation Branch, National Institutes of Health, Division of Research Services, 1982-1986. EDUCATION: Ph. D., Electrical Engineering, University of Utah, 1978, Dissertation Title: "Numerical Studies of Absorption of Electromagnetic Energy by Man". PROFESSIONAL SOCIETIES: Active member of 10 professional societies including the American Institute of Physics, American Physical Society, and the Institute of Electrical and Electronics Engineers (IEEE). HONORS AND AWARDS: Honorary member of the Electromagnetics Academy, Department of Electrical Engineering and Computer Science, Massachusetts Institute of Technology; Outstanding Achievement Award, Florida International University (1990); Member of Sigma Xi (honorary scientific research society). PUBLICATIONS: 72 papers in peer -reviewed journals and 61 papers in conference proceedings, primarily on his simulations and measurements of the interaction of electromagnetic energy with the human body; Chapters in 2 scientific books; 152 presentations at international symposia, and 43 invited guest lectures at various universities and laboratories in the U. S. and abroad. PATENTS: Inventor for 6 U. S. Patents, including a device for measuring the current induced in humans exposed to hazardous electromagnetic fields (U. S. 4,897,600). This was the first patent granted at Florida International University. COMMITTEE MEMBERSHIPS: Served on committees having the responsibility for setting standards limiting the exposure of humans to electromagnetic radiation. These include the IEEE Standards Coordinating Subcommittee SCC28, "Non -Ionizing Radiation"; the Subpanel on Electromagnetic Fields of the FEL Hazards Advisory Panel (SDIO/FELHAP) of U. S. Army Environmental Hygiene Agency (USAEHA); and Subcommittee C95.4 of the American National Standards Institute (ANSI). EXPERIENCE AS AN EXPERT WITNESS: Testified as an expert witness in courts at the federal and county level. Invited by the Committee on Environment and Public Works of the U. S. Senate to testify on the subject of "Health and Safety Problems in Collocation of H-3 with the Coast Guard Omega Station" in July of 1986. This testimony concerned the hazards associated with constructing a highway under the antenna of a high -power navigational transmitter. Submitted, into the public record in cox- i.L c-t a v, , ► h item ors_o� 9 5— 335 C jr Cje1.-1 J14",