NEW SANTA FE COUNTY CODE ALLOWS CELL TOWERS WITH NO APPLICATIONS, NO SETBACKS NO LAWS RULING CONSTRUCTION OR LIABILITY and AGAINST FEDERAL LAWS

Dates: 01/01/1970 Dates: 01/01/1970 Location:

NEW SANTA FE COUNTY CODE ALLOWS CELL TOWERS WITH NO APPLICATIONS, NO GUIDELINES, NO PROTECTIONS OR LIABILITY FOR FALLING ON NEIGHBOR’S HOMES OR PROPERTIES, & AGAINST FEDERAL LAWS  [Full Code wording and analysis below.]

cell tower afire above tree line

PLEASE TAKE 5 MINUTES TO SAVE LIVES AND PROPERTY IN SANTA FE — just copy/paste and email

In the US, every year 12 cell towers fall and 4 cell towers erupt into flames –WITH NO SETBACKS OR LAWS RULING CONSTRUCTION, this could fall on your home or family.

Just copy/paste the wording below to the Commissioners–legally they must all receive the same information.

Kathy Holian  : kholian@santafecountynm.gov

Liz Stefanics: lstefanics@santafecountynm.gov

Daniel Mayfield: dmayfield@santafecountynm.gov

Robert A. Anaya: ranaya@santafecountynm.gov

Miguel M. Chavez: mchavez@santafecountynm.gov

THE PROBLEM:  the new Santa Fe County Sustainable Land Development Code (SLDC) was naively based on UN Agenda 21, a formula based on urbanization in order to make natural resources more “sustainable,” but which is destructive to the rural environment, organic farming and lifestyle New Mexicans value. This includes taking away rights to independent water systems and allowing “mixed use” (industrial and strip mall businesses) in rural residential areas. In terms of cell towers, we are very concerned that:

1. No application or guidelines are required. However, the 2012 Federal Wireless Facilities Deployment Act, Section 6409, mandates there will be no limit to height or number of antennas added once a cell tower is built.

(1) “a State or local government may not deny, and shall approve, any eligible facilities request for a modification of an existing wireless tower or base station …(2) …the term ‘‘eligible facilities request’’ means any request for modification of an existing wireless tower or base station that involves… (A) collocation of new transmission equipment….”

 2. There are no setback provisions or proof required that the proposed antenna supporting structure is designed so that, in the event of structural failure, the facility will collapse within the boundaries of the leased lot. In the US, one cell tower a month collapses. Every 3 months a cell tower bursts into flame.

3. There are no provisions for who will pay for deaths and/or damages caused by a cell tower falling or erupting into flame in a rural area.

4. The Appraisal Institute (the largest global professional organization for appraisers with 91 chapters) performed a sales analysis that showed prices of properties were reduced by around 21% after a cell phone base station was built in the nearby area.

Because the FCC regulations specifically limits radiation levels for the general population and the FCC does not test these levels, only towns and counties can formulate their codes to have them tested. Most cell towers, when tested, show they are up to 700% higher than the allowed FCC level. Therefore many US jurisdictions* have added to their code these two simple sentences:

“1. That the TeleCom must pay for periodic, random testing, by a third party engineer selected by the county.

2. If the tower is found to be over the FCC limit, the TeleCom must pay to pull it down.”

————————————————————————————-

cell tower afire w two layers of antennasPlease call or email your Commissioner to add these protective provisions.

Letter to Santa Fe County Commissioners below. Please copy/paste or compose your own wording.

 

 

 

The Sustainable Land Development Code is on line here:

http://www.santafecountynm.gov/userfiles/SLDC/ClickableSLDCwithOrdinance.pdf

 

Kathy Holian  : kholian@santafecountynm.gov

Liz Stefanics: lstefanics@santafecountynm.gov

Daniel Mayfield: dmayfield@santafecountynm.gov

Robert A. Anaya: ranaya@santafecountynm.gov

Miguel M. Chavez: mchavez@santafecountynm.gov

Honorable Commissioners Holian, Stefanics, Mayfield, Anaya and Chaves:

As a citizen of Santa Fe County, I am very concerned by the lack of governance, applications, liability, and engineering requirements that are usually required for the process of siting cell towers. Please add the two simple sentences below that many US jurisdictions have found invaluable:

“1.That the TeleCom must pay for periodic, random testing, by a third party engineer selected by the county.

2. If the tower is found to be over the FCC limit, the TeleCom must pay to pull it down.”

 

RURAL NEW MEXICO TARGETED FOR INDUSTRY

This new Code also targets rural NM, forcing industrial use in our rural residential communities. 100% of all acequia lands are targeted for “mixed use” like strip malls and industry. This is NOT our tradition or why we choose to live in Northern New Mexico.

For more info: Devin Bent, PhD, Santa Fe, NM devin.bent@gmail.com, 505-699-9042

 

Summary and detailed clauses of proposed County Code re: unregulated cell towers


TO: Honorable Commissioners Kathy Holian, Liz Stefanics, Daniel Mayfield, Robert A. Anaya, and Miguel M. Chavez:

I am impressed with Santa Fe County Sustainable Land Development Code (SLDC) and congratulate the Board and County Staff for creating this massive forward-looking document. However….
There are serious conflicts between the SLDC and both Federal Law [Section 6409 of the ‘‘Middle Class Tax Relief and Job Creation Act of 2012] and FCC Guidelines regarding communication towers. My concern is that the Santa Fe County Sustained Land Development Code (SLDC) assumes that the County has the right to approve or reject any addition to the height or width of an existing antenna tower. According to Federal Law, you will not have that power and not be able to protect your constituents from additions to existing towers unless you modify the SLDC.
Five additional providers (antennas) could raise a 29 ft tower to 130 ft and increase the width of the tower to 40 ft. There is no proof required that the new larger tower is designed to withstand sustained winds of 110 mph and/or a 15-second wind gust of 130 mph. Note that adding more antennas increases the weight bearing load and the wind load on the original tower base. Also, more than five providers could make the tower taller than 130 ft.There are no setback provisions required. Original setbacks are meaningless after an addition to a tower. There is no proof required that the proposed antenna supporting structure has been designed so that, in the event of structural failure, the facility will collapse within the boundaries of the lot on which it is located. Falling, burning towers happen in the USA.Forward thinking communities have solved these issues:Because the FCC regulations limit the radiation levels from these towers for the general population and because the FCC does not test these levels, only towns and counties can require in their codes to have towers tested. Most cell towers, when tested, are up to 700% higher than the allowed FCC level. Usually, each cell antenna radiates at the FCC limit.

Proposed SLDC code:

1.The tower owner or Telecom must pay for periodic, random testing, by a third party engineer selected by the County, to measure the radiation from the tower.

2. If the tower is found to be over the FCC limit, the tower owner or Telecom must pay to take the tower down.

These conditions limit the number of antennas that can be mounted on a tower and thus limit it’s height because each individual antenna probably radiates at the FCC radiation limit.

Approximately one cell tower falls every month and one cell tower catches fire every three months in the USA. I searched the internet and found that, in recent years, TV, radio and newspapers have reported on the average 1 cell tower per month falling somewhere in the USA, and 1 cell tower fire every three months in the USA. These are probably underestimates because they do not include all tower collapses or fires. No organization is tasked with recording or tallying these events, and, thus, there is no comprehensive list. For example, during Hurricane Sandy almost all the cell towers on the East Coast (25% of the US total) stopped working. I could not find any reports about how many fell, but there must have been many. The SLDC code could be amended to require that a clear fall zone around all cell towers of, at least, 130 ft.

See a short video of a burning collapsing tower on YouTube at: http://www.youtube.com/watch?v=0cT5cXuyiYY&NR=1,

Look at the photos and note the Fire equipment used to put out a cell phone tower fire in LILBURN, GA. See: http://www.cbs46.com/story/16175764/cell-phone-tower-on-fire-in-lilburn


​Burning cell tower in Lilburn, GA. December 2011.

As written, the SLDC permits the construction of wireless communication antenna supporting structures (cell towers) of unlimited height without County approval by expanding existing towers. The SLDC allows that antenna supporting structures (towers) less than 30 ft in height are approved without submitting an application to the County (SLDC 10.17.2.1.). However, under Federal Law and FCC regulations this 29 ft tower could be extended in height without County approval.

Section 6409 (a) (1) of the ‘‘Middle Class Tax Relief and Job Creation Act of 2012’’ (see appendix A.) says that once a Communication tower is approved and installed for one communications provider, any other communications provider may not be denied application to install their antenna on that tower if the dimensions of the tower are not substantially changed. (The law is more general than this.)

Unfortunately, “substantially changed” is not defined in the Law and the FCC defines substantially changed as an increase in height of 20 ft or 20%, whichever is larger (see Appendix B.) (The 20 ft-20% rule). The FCC also says that the tower width can be extended to 40 ft.

Thus, if the transmission equipment in a 29 ft tower were modified 5 times for the addition, say, of 5 new antennas belonging to other communications providers, the tower height could be increased without County approval to 130 ft:

0. 29 ft – original height
1. 49 ft – 1st 20 ft addition
2. 69 ft – 2nd 20 ft addition
3. 89 ft – 3rd 20 ft addition
4. 109 ft – 4th 20 ft addition
5. 130 ft – 20% addition

Beyond 130 ft. more antennas or larger replacement antennas could increase the height at 20% per antenna. Also, the width of the original tower can be extended to 40ft. to accommodate the newer antennas. Such changes increase the weight bearing load and the wind load on the original tower base.

The County could limit the total height by restricting the total radiation from the tower to the FCC limit and by requiring the tower owner to pay for periodic, random testing, by a third party engineer selected by the County, to measure the radiation from each tower. If the tower is found to be over the FCC limit, the tower owner or Telecom must pay to remove the tower.

The method of the example shown above for a 130 ft tower can be applied also to towers that initially exceed 30 ft and for which applications are made and approved by the County.

The FCC states that “wireless tower” is not limited to cell phone towers but includes all radio towers: “we believe the scope of a “wireless” tower or base station under Section 6409(a) is not intended to be limited to facilities that support “personal wireless services” under Section 332(c)(7). “–see Appendix B.

Setback provisions cannot be enforced for expanded towers. The SLDC has setback provisions for towers (more than 30 ft tall) to prevent them from falling on neighboring properties; the tower must be set back from the property line by the tower height. However, because of the impact of the Middle Class Tax Relief and Job Creation Act of 2012 and FCC guidelines, these provisions cannot be enforced for additions to the towers and do not apply to towers less that 30 ft tall.

Thus, the way the SLDC is written, a home owner may find a 130-ft. burning tower falling into their yard. An internet search shows that one cell tower falls in the USA each month. Also one cell tower catches fire every three months. (See: Appendix C) Some of the towers that burn also fall. See a short video of a burning collapsing tower on YouTube at: http://www.youtube.com/watch?v=0cT5cXuyiYY&NR=1,

Look at the photos and note the Fire equipment used to put out a cell phone tower fire in LILBURN, GA. See: http://www.cbs46.com/story/16175764/cell-phone-tower-on-fire-in-lilburn

Increasing the tower height requires additional support to the base of the tower so that it can withstand the increased weight and the additional wind load of the additional height and antennas. In 2007 the Malibu wild fires, which destroyed 49 homes and two outbuildings and damaged 27 other residences, was started when one existing tower fell in 75 mile an hour winds after being over loaded by the addition of a new antenna. The new antenna caused the tower to collapse.

Details: The following sections of the SLDC are impacted by Federal Law and the FCC guidance.

1. Problems: Substantially is not defined. See Appendix B for FCC definition of substantially. Towers shorter than 30 ft. do not require an application. Require an application for towers shorter than 30 ft.10.17.2. Applicability; Exceptions. This §10.17 shall apply to the installation, construction, or modification of any wireless communication facility located within the County, with the following exceptions:10.17.2.1. Any antenna supporting structure with an overall height of thirty (30) feet or less;10.17.2.6. A modification to an existing antenna supporting structure or base station involving: (a) collocation of new transmission equipment; (b) removal of transmission equipment; or (c) replacement of transmission equipment, provided that such modification does not substantially change the physical dimensions of such structure or base station;

2. Problem: Supposition that all communication antenna supporting structure (tower) applications include all antennas to be mounted on the structure. Does not account for Federal Law and FCC guidelines that say that after tower is built, additional antennas must be approved.

10.17.3.3. Application Requirements.

2. If the application is for an antenna supporting structure, the applicant also shall comply with the pre-application meeting requirements of the SLDC. This provision is not applicable to replacement antenna supporting structures. Prior to the pre-application meeting, the applicant shall provide the following information regarding the proposed facility:

a. Location;
b. Overall height;
c. Number of antennas proposed, including those of other providers;

Type or types of wireless communication to be provided; and
e. Proof that the letters of coordination were mailed as required by §10.17.4.10 regarding accommodation of future collocations.3. Problem: Impossible to make the following calculations and renderings because information about additional antennas is unknown.Table 10-4: Submittal Requirements for Wireless Communication FacilitiesProof that the proposed facility is designed to withstand sustained winds of 110 mph and a 15-second wind gust of 130 mph.

Proof that the proposed antenna supporting structure has been designed so that, in the event of structural failure, the facility will collapse within the boundaries of the lot on which it is located.

A stamped or sealed structural analysis of the facility prepared by a professional engineer, certified by the State of New Mexico indicating the proposed and future loading capacity of the facility.

Photo-simulated post-construction renderings of the proposed facility,
equipment enclosures, and ancillary appurtenances as they would look after construction from locations to be determined by the participants during the preapplication conference.

Antenna heights and power levels of the proposed facility and all other facilities on the subject property.

4. Problem: FCC guidelines prevent these height restrictions for additions to the antennas. For example, a 50 ft extension could be added to a 250 ft AM antenna. Also, is broadcast antenna defined?

10.17.4.1. Height. Except for amateur radio antennas, the overall height of any antennasupporting structure may not exceed 149 feet, except as provided in this section. Antenna supporting structures proposed within a designated notification height boundary of an airport, private airport, aircraft landing strip or helicopter landing facility, as specified on
the Airspace Notification Map, will be limited to the height specified, based on the proposed facility’s distance from the runway or landing facility. Proposed broadcast antenna supporting structures that have received a construction development approval from the Federal Communications Commission may be constructed in accordance with
the following:

1. AM broadcast antenna supporting structures may not exceed 250 feet in overall height; and

2. Except as provided in 10.17.4.1.1 above, the overall height of a broadcast antenna supporting structure may not exceed 500 feet.

5. Problem: Original setbacks are meaningless after an addition to a tower.

10.17.4.2. Setbacks.

1. Antenna supporting structures, equipment enclosures, and ancillary
appurtenances shall meet the minimum setback requirements for the zoning district in which they are proposed.

2. Antenna supporting structures shall be set back a distance equal to their overall height from the lot line of any lot that contains a residential use or that is within a residential zoning district. If more than one of the setback requirements applies to an antenna supporting structure, the more restrictive requirement will govern.

3. Setback requirements for replacement antenna supporting structures may be reduced by an amount not to exceed 50 percent of that required by this chapter,
but in no case may a replacement structure be placed any closer to a lot line than the antenna supporting structure it is replacing. No waiver or variance will be granted pursuant to this paragraph unless the applicant demonstrates that the existing structure cannot be replaced in compliance with this chapter without a waiver.

Please fix these problems to prevent burning cell and radio towers from falling into our yards. There are serious conflicts between the SLDC and both Federal Law [Section 6409 of the ‘‘Middle Class Tax Relief and Job Creation Act of 2012] and FCC Regulations regarding communication towers. Five additional providers could raise a 29 ft tower to 130 ft and increase the width of the tower to 40 ft without County approval. No application is required for towers shorter than 30 ft. Original setbacks are meaningless after an addition to a tower. Approximately one cell tower falls every month and one cell tower catches fire every three months in the USA. The FCC states that “wireless tower” is not limited to cell phone towers but includes all radio towers.

These conflicts with Federal law and the FCC can be fixed by adding the following provisions into the SLDC.

For all radio towers, including those shorter than 30 ft:

1.The tower owner (or Telecom) must pay for periodic, random testing, by a third party engineer selected by the County, to measure the radiation from each tower.
2. If the tower is found to be over the FCC limit, the tower owner (or Telecom) must pay to remove the tower.3. Require an application for all communication towers, regardless of height.4. Require that a clear fall zone around all cell towers of, at least, the initial height plus 5 times 20% of the initial height.Numbers 1 and 2 limit the number of antennas mounted on a tower because, usually, each antenna broadcasts at the maximum FCC limit.

These four changes will minimize the impact of Section 6409 (a) (1) of the ‘‘Middle Class Tax Relief and Job Creation Act of 2012’’ and FCC guidelines on the health and welfare of our County. I refer County staff to a similar document for the city of Calabasas, CA (see:

http://www.cityofcalabasas.com/pdf/agendas/council/2012/042512/item6-attachment-g.pdf

and

http://www.cityofcalabasas.com/pdf/wireless/Wireless_Facility_Ordinance-w_CC_Changes052312.pdf and

http://www.cityofcalabasas.com/pdf/wireless/Andrew-Campanelli-Report.pdf

and

http://www.cityofcalabasas.com/pdf/wireless/Andrew-Campanelli-Report-2.pdf

Sincerely,

David M. Stupin, Ph. D.

Appendices

Appendix A.
excerpt from Middle Class Tax Relief and Job Creation Act of 2012

complete document available at:
https://www.govtrack.us/congress/bills/112/hr3630/text

SEC. 6409. WIRELESS FACILITIES DEPLOYMENT.
(a) FACILITY MODIFICATIONS.—
(1) IN GENERAL.—Notwithstanding section 704 of the Telecommunications Act of 1996 (Public Law 104–104) or any other
provision of law, a State or local government may not deny,
and shall approve
, any eligible facilities request for a modification
of an existing wireless tower or base station that does not substantially change the physical dimensions of such tower or base station.

Appendix B.

see the complete document at:
https://apps.fcc.gov/edocs_public/attachmatch/DA-12-2047A1.pdfExcerpts from the
WIRELESS TELECOMMUNICATIONS BUREAU OFFERS GUIDANCE ON INTERPRETATION OF SECTION 6409(a) OF THE MIDDLE CLASS TAX RELIEF AND JOB CREATION ACT OF 2012
DA 12-2047January 25, 2013

What is a “wireless tower or base station”?
Section 6409(a) by its terms applies to any “wireless” tower or base station. By contrast, the scope of Section 332(c)(7) extends only to facilities used for “personal wireless services” as defined in that
section.11 Given Congress’s decision not to use the pre-existing definition from another statutory provision relating to wireless siting, we believe the scope of a “wireless” tower or base station under
Section 6409(a) is not intended to be limited to facilities that support “personal wireless services” under
Section 332(c)(7).
 [Section 332 probably refers to 47 U.S. Code § 332 – Mobile services — Communications Act of 1934 (47 U.S.C. 332)]

May a state or local government require an application for an action covered under Section
6409(a)?

Section 6409(a) states that a state or local government “may not deny, and shall approve, any eligible facilities request….” It does not say that a state or local government may not require an application to be
filed. The provision that a state or local government must approve and may not deny a request to take a covered action, in the Bureau’s view, implies that the relevant government entity may require the filing of
an application for administrative approval.

What does it mean to “substantially change the physical dimensions” of a tower or base station?
Section 6409(a) does not define what constitutes a “substantial[] change” in the dimensions of a tower or base station. In a similar context, under the Nationwide Collocation Agreement with the Advisory Council on Historic Preservation and the National Conference of State Historic Preservation Officers, the Commission has applied a four-prong test to determine whether a collocation will effect a “substantial increase in the size of [a] tower.”4 A proposed collocation that does not involve a substantial increase in size is ordinarily excluded from the Commission’s required historic preservation review under Section 106 of the National Historic Preservation Act (NHPA).5 The Commission later adopted the same definition in the 2009 Declaratory Ruling to determine whether an application will be treated as a collocation when applying Section 332(c)(7) of the Communications Act of 1934.6 The Commission has also applied a similar definition to determine whether a modification of an existing registered tower requires public notice for purposes of environmental review.7

Under Section I.C of the Nationwide Collocation Agreement, a “substantial increase in the size of the tower” occurs if:

1) [t]he mounting of the proposed antenna on the tower would increase the existing height of the tower by more than 10%, or by the height of one additional antenna array with separation
from the nearest existing antenna not to exceed twenty feet, whichever is greater
, except that the mounting of the proposed antenna may exceed the size limits set forth in this paragraph if necessary to avoid interference with existing antennas; or

2) [t]he mounting of the proposed antenna would involve the installation of more than the standard number of new equipment cabinets for the technology involved, not to exceed four, or more than one new equipment shelter; or

3) [t]he mounting of the proposed antenna would involve adding an appurtenance to the body of the tower that would protrude from the edge of the tower more than twenty feet, or more than the width of the tower structure at the level of the appurtenance, whichever is greater, except that the mounting of the proposed antenna may exceed the size limits set forth in this paragraph if necessary to shelter the antenna from inclement weather or to connect the antenna to the tower via cable; or

4) [t]he mounting of the proposed antenna would involve excavation outside the current tower site, defined as the current boundaries of the leased or owned property surrounding the tower and any access or utility easements currently related to the site. Although Congress did not adopt the Commission’s terminology of “substantial increase in size” in Section 6409(a), we believe that the policy reasons for excluding from Section 6409(a) collocations that substantially change the physical dimensions of a structure are closely analogous to those that animated the Commission in the Nationwide Collocation Agreement and subsequent proceedings. In light of the Commission’s prior findings, the Bureau believes it is appropriate to look to the existing definition of “substantial increase in size” to determine whether the collocation, removal, or replacement of equipment on a wireless tower or base station substantially changes the physical dimensions of the underlying structure within the meaning of Section 6409(a).

What is a “wireless tower or base station”?

A “tower” is defined in the Nationwide Collocation Agreement as “any structure built for the sole or primary purpose of supporting FCC-licensed antennas and their associated facilities.”8 The Commission has described a “base station” as consisting of “radio transceivers, antennas, coaxial cable, a regular and backup power supply, and other associated electronics.”9 Section 6409(a) applies to the collocation, removal, or replacement of equipment on a wireless tower or base station. In this context, we believe it is reasonable to interpret a “base station” to include a structure that currently supports or houses an antenna, transceiver, or other associated equipment that constitutes part of a base station.10 Moreover, given the absence of any limiting statutory language, we believe a “base station” encompasses such equipment in any technological configuration, including distributed antenna systems and small cells.

Section 6409(a) by its terms applies to any “wireless” tower or base station. By contrast, the scope of Section 332(c)(7) extends only to facilities used for “personal wireless services” as defined in that section.11 Given Congress’s decision not to use the pre-existing definition from another statutory provision relating to wireless siting, we believe the scope of a “wireless” tower or base station under Section 6409(a) is not intended to be limited to facilities that support “personal wireless services” under Section 332(c)(7).
May a state or local government require an application for an action covered under Section 6409(a)?Section 6409(a) states that a state or local government “may not deny, and shall approve, any eligible facilities request….” It does not say that a state or local government may not require an application to be filed. The provision that a state or local government must approve and may not deny a request to take a covered action, in the Bureau’s view, implies that the relevant government entity may require the filing of an application for administrative approval.1 Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. 112-96, H.R. 3630, 126 Stat. 156 (enacted Feb. 22,
2012) (Tax Act).

2 Id., § 6409(a).

3 Although we offer this interpretive guidance to assist parties in understanding their obligations under Section 6409(a), see, e.g., Truckers United for Safety v. Federal Highway Administration, 139 F.3d 934 (D.C.Cir. 1998), the Commission remains free to exercise its discretion to interpret Section 6409(a) either by exercising its rulemaking
authority or through adjudication. With two exceptions not relevant here, the Tax Act expressly grants the Commission authority to “implement and enforce” this and other provisions of Title VI of that Act “as if this title is a part of the Communications Act of 1934 (47 U.S.C. 151 et seq.).” Tax Act § 6003.

4 47 C.F.R. Part 1, App. B, Nationwide Programmatic Agreement for the Collocation of Wireless Antennas, § I.C (Nationwide Collocation Agreement).

5 See 16 U.S.C. § 470f, see also 47 C.F.R. § 1.1307(a)(4) (requiring applicants to determine whether proposed facilities may affect properties that are listed, or are eligible for listing, in the National Register of Historic Places).

6 See Petition for Declaratory Ruling to Clarify Provisions of Section 332(c)(7)(B) to Ensure Timely Siting Review and to Preempt Under Section 253 State and Local Ordinances that Classify All Wireless Siting Proposals as Requiring a Variance, WT Docket No. 08-165, Declaratory Ruling, 24 FCC Rcd. 13994, 14012, para. 46 & n.146 (2009) (2009 Declaratory Ruling), recon. denied, 25 FCC Rcd. 11157 (2010), pet. for review denied sub nom. City of Arlington, Texas v. FCC, 668 F.3d 229 (5th Cir.), cert. granted, 113 S.Ct. 524 (2012); 47 U.S.C. § 332(c)(7).

7 See 47 C.F.R. § 17.4(c)(1)(B); National Environmental Policy Act Compliance for Proposed Tower Registrations WT Docket No. 08-61, Order on Remand, 26 FCC Rcd. 16700, 16720-21, para. 53 (2011).

Appendix C. Cell Towers Collapse and Fire Survey

These tables can be found in another format at:

http://www.electronicsilentspring.com/primers/cell-towers-cell-phones/cell-tower-fires-collapsing/

Cell Tower 1 Collapse per Month 2014 6 22 v6.pdf
Burning Cell Towers 4 burning per Year 2014 6.pdf

David Stupin, PhD

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