Electronic Comment Filing System

L ·'<·r............ ... 'iii' .,"'"'\ I ' ..,.... J 9~T30t99J TwinPeaks Improvement Association Midtown Terrace HomeownersAssocia~£r in San Francisco, California . 'I f:!Lf COPy P.O. Box 31022 ? San Francisco ? California ? 94131 ORIGINAL October 27,1997 M.M.q1.. 1 Notice of Proposed Rule Making BiG ;; 2%Re: Federal Communications Commission c/o Secretary of the FCC 1919 M Street N. West Washington, D.C. 20554 Dear Sirs and Madams: Please be advised that the residents of San Francisco are preserving their rights to appeal the proposed FCC Rule # 97-ttL Several extra-ordinary , compelling and unusual circumstances regarding the placement of transmission towers in San Francisco's urban center, as well as other areas of the country prone to seismic activity, strongly necessitate the need for local planning agencies to retain zoning and regulatory control over the placement of digital transmission towers and other similar structures in their communities. Please be advised that Sutro Tower, an analog transmission tower is the first transmission tower of its size (977 feet on a 1080 foot base) to be located less than 250 feet from reservoirs containing approximately 55 million gallons of water, 800 residences, two elementary schools, churches, at least one firehouse, and several children's playgrounds. The Sutro Tower is surrounded in a 360 degree radius by these structures. What is most alarming about the placement of the Sutro Tower in San Francisco is that the owners of the Sutro Tower failed to adequately maintain the Tower structure. The vice-president and general manager of Sutro Tower, Mr. Eugene Zastrow, admits that "the Sutro Tower was neglected for a period of twenty years". Because of the neglect and the fact that Sutro Tower is inundated by corrosive fog, the Sutro Tower had to undergo massive sandblasting to stem the rust damage which impaired the integrity of Sutro Tower's stability. The legislation in FCC 97-llIr-fails to address the fact that many tower operators have not adequately maintained their structures. Broadcasters have forgotten that it is not a right, but rather a privilege to hold an FCC broadcasting license. The FCC must not ignore the fact that Tower operators have not properly tended to the structural stability of their towers. Clearly, the lack of adequate maintenance and repair, can not be ignored when the broadcaster is operating such a massive structure in an urban setting. Local zoning agencies and planners, local officials, and local residents are best suited to confront the enormous problems associated with tower maintenance and placement in their communities. The US Constitution specifically provides that the the non-enumerated powers, not specifically delegated to the federal government, shall be controlled by the States. Thus, issues of health, safety, and welfare are Constitutionally protected. This is one such case. Be advised that San Francisco is currently living in the wake of the 1989 Lorna Prieta Earthquake. As a result of thisdes~rucutiv~earthquake, San Francisco has taken affirmative steps to regulate masonaty brick type structures and make proactive changes in an attempt to prevent massive loss of life due to structural failure and collapse. Transmission towers are structures that pose similar problems. It is imperative that our local agencies retain the ability to determine whether it is appropriate to place a massive steel tower in the middle of San Francisco, in light of all of these considerations, when a comparable site, located outside the city center could equally serve the purposes of th'e FCC's digital expansion. This cite is located on Mount San Bruno. Although the structural stability of the Sutro Tower and the effect of its collapse during seismic activity and landslides is of paramount concern to San Francisco's residents, additional local zoning and planning concerns buttress support for allowing local planning agencies to retain control over transmission towers in our community. This response to proposed FCC Rule 97-tltincludes exerpts and representative samples of over 330 surveys and letters regarding the environmental impact of the Sutro Tower in San Francisco's urban setting. Additionally, over 500 people have already signed petitions voicing their concern about Sutro Tower in San Francisco. Please do not pre-empt our Constitutional Rights in an attempt to expedite the transition from analog to digital transmission. The concerns of the residents are grounded in the reality that San Francisco must take adequate, affirmative measures to protect the lives of its citizens. Any objection voiced with respect to an Environmental Impact Report regarding Sutro Tower's planned conversion of its analog tower, is reserved as an objection to proposed FCC Rule 97-296. ThaTIk you for your attention to this matter. Nancy Hogan - President TPIA Steve Nahm - President MTHA ':r'· '/\, * . To: Secretary of the Federal Communication~~pyORIGINAl ..~"~. From: Twin Peaks Improvement Association I tL.l' ., Midtown Terrace Homeowners Association~Q\ .) Re: Notice of Proposed Ruling making FCC 97-!!If) I eZ- .~", M~'"".j " l> Dear Secretary and Commissioners: /; This letter is in response to the above proposed ruling regarding the placement of' DTV antennae. In the San Francisco Bay Area, the main center for communications is Sutro Tower, a 977 foot structure built over 25 years ago on land owned by ABC Broadcasting, to serve the purposes of transmitting line of sight analog signals for the fourth largest media market in the United States. As you can see from the enclosed comment letters, the owners of Sutro Tower, Inc., who represent the four major broadcasters in the Bay Area, plan to attach their new DTV antennae to the existing tower. While we welcome the introduction of DTV to the Bay Area, we have serious reservations about the continued operation of such a large transmission tower as Sutro Tower located in the middle of a densely populated urban area. The DTV signal has identical penetration from Mt. San Bruno, an area already containing numerous existing transmission towers on 2000 acres of open space. The site in San Bruno is ready and willing to take the DTV signal. A EIR comment statement from their attorney is also attached. In their comments, the project sponsor states that the FCC has "mandated" that DTV be placed on Sutro Tower. Is this correct? If so, it would appear that local input regarding safety is moot, and that the FCC has already overruled local safety concerns. Can this interpre\ation be correct? . As you are aware, California has experience a series of major seismic events in the past dozen years, each one increasing in intensity. The cost in lives and property damage, and especially the need for FEMA funds, increases with each earthquake. Should the FCC overrule local and state regulations which allow communities to take into account the safety and suitability of locating a towers in the middle of densely populated neighborhoods, the cost could be catastrophic, both to the local community and to the taxpayers of the United States. I urge you to review the enclosed comments regarding seismic safety and its relevance to the placement of transmission towers in California. Although we can understand the need to speed up the DTV process, the Federal Government, and the FCC in particular, should not be used to circumvent local and state safety codes and basic siting guidelines in order to expedite individual private commercial operators at the expense of public safety concerns. Nancy Hogan - President TPIA Steve Nahm - President MTHA P.O. Box 31022 San Francisco, California 94131 .-,.;: ----.--'~~....,.-----..............-.,....-------.....-~--_... New FCC rule would ban local controls on ern'ergingtech. I OPPOSE ANY EXPANSION OF sumo ToWER FOR THE FOLLOWING REASONS: A suitable site ford~talTV antennae already exists on Mt. San Bruno such that Mount Sutro will be obsolete and no longer needed. I am concerned about a reduction in property values In adjacent neighborhoods. I am concerned about the collapse of the Tower in the event of an earthquake I am concerned about the collapse of the Tower In the event of a landslide as well as the weight ofthe Tower on the hill-side. I am concerned about the structural fa1lure of the tower. I am concerned about proJecttles from the Tower strtkingmy neighborhood. (ie metal siding, bolts, wires. cables. tools. etc.) I am concetned.about any additional interference with telephones. radios, N's. etc. which l1mlt the use and enjoyment of my home. I am concerned about the unknown health effects of combined analog and digital electromagnetic radiation. I oppose continued use or additions to Sutro Tower absent the completion of an Independent reliable epidemiological study pertaining to any and all related health effects which Sutro Tower and or ItseXlllsslons are responsible for introducing into my residential neighborhood. I oppose continued use or additions to Sutro Tower absent the completion of a comprehensive disaster preparedness plan by the City and County of San Francisco pursuant to the Master Plan whtch wUl examIne the potential impacts ofthe tower on emergency response. upon the lives and health of the residents, and the mItigation plans needed tobe put Into place to combat the effects of the Sutro Tower on any emergency or evacuation plans. I am concerned about the unknown effects of the tower upon emergency disaster' plans and upon the structuraltntegrtty ofneighbortng reservoirs. A i.. -( Sutto Tower is visually obtrusive and would like to see 1t phased out. Name.£ «L \})&6~ Address di: 53G.At«~oaJ0Je,- San Francisco, Callfomta94\~+-~..\a\ Pleaae send.me a copy ofthe Revised EDt prior to approval. 8uch that I may comment upon It. In addition. pleue add my name to the U8t of"Intereeted Partlea" re.ardln. any "'uepertainin. to Sutro Tower. Inc. Signed: C, .l .CJ,,* Date:C\-6-c.tl-- (over) In the past, Sutro Tower baa Impacted my Ufe and or the lives of tbe occupants in my residence tn· the followla.,JIlanner : n Noise from: n Night Repairs n Day Repatrs ~Cables blowing. Guy Wires GRuet froIn Tower on property ?(sandblasting Dust/Debris n Bolts. small objects fal11ng o Metal siding falling on property o Metal siding falltng near property n Painting Dnpplng.on House n Paint Dripping on Car or other / n Other: ,), 5tli" I~V\S\~~ 1 A!Wtlonal Commentl. 9uestfons.·and Conpems Beaardln, SUlfO TOWer:: ~\-~~f~~~~t~~~~~0~ A Wr..\i'ct-'0\Atv,,*·C\.lM~/\,D~vl~G\'*'-J' _ TelevisIon Receptionlnterf~rence ? Radio Reception Interference n Short Wave Radlolnterference GTaplng ofRadio Or Cassettes Interference n VCR Playing Clarity n VCR Taping Cla.rlty a Telephone Clarity ~Answering Machine Clarity n Garage Door Malfunction n Spontaneous Power Surges n Car Alann Malfunction n Other: ------- (over) IOP~ANY EXPANSION OF 8UTRO TOWER FOR THB FOLLOWING REASONS: ~A suitable site for dlgital1V antennae already exists on Mt. San Bruno such that .~Sutro will be obsolete and no longer needed. /1 8111 concerned about a reduction In property values In adjacent neighborhoods. ~amconcerned about the collapse of the Tower In the event of an earthquake ~concerned about the collapse of the Tower In the event of a landslIde as well .~eweight of the Tower on the hill·slde. ~Iam concerned about the structural failure of the tower. ~~concerned about proJectlles from the Tower str1k1ng my neighborhood. (le metal Siding. bolts. Wires, cables. tools, etc.) ~concerned about any additional tnterference With telephones. radios, ./ WIS. etc. which llmlt the use and enjoyment of my home. ~~concerned about the unknown health effects of combined analog and digital electromagnetic radiation. ~opposecontinued use or additions to Sutro Tower absent the completion of an independent relIable epldem1010gtcal study pertaining to any and all related health effects which Sutro Tower and or Its emissions are responsible for introducing into my residential neighborhood. LIoppose continued use or additions to Sutro Tower absent the completion of a comprehensive·disaster preparedness plan by the City and County of San Francisco pursuant to the Master Plan which will examine the potential Impacts of the tower on emergency response. upon the lIves and health of the reSidents, and the mItigation plans needed to be put Into place to combat the ~ectsofthe Sutro Tower on any emergency or evacuation plans. ~~~concerned about the unknown effects of the tower upon emergency disaster' plans and upon the structurallntegrtty of neighboring reServoirs. Sutro Tower Is visually obtrusive and would ltke to see It phased out. Name::LS: c\" LV, Q"..Ide~3-;:-, (3~e '" f Ie - I " "~ \ __....d-"""~t"'\. eo --- .. h..-_.s .«... J Addre8s.l..SJ Vl , \c", \pc· San Francisco. Callfom1a 94 U L..f RlLpI~'"toijiprovaltsuch that I may b;-opb--le Y Dame to tbe U.t of "Interested tro Tower, IDC. --:";::~r---':::"'-~:"':::::::::~::=::::::::~_jDate:1/]/ 71- il ha tbeput, Sutro Tower hulmpacted my Ufe and or the IIvea of the occupants in myrealdence In tbe foUowtQ',lDuD,er : 2D PWelllng :: 1. Elecbptpftinetic :: 2. UseAAd El)jomaept :: n Noise from = n Night RepaIrs noay RepairS n Cables blowing. Guy Wires n Rust from Tower on property n Sandblasting Dust/Debris n Bolts. small objects fa.lllng n Metal siding falling on property n Metal siding fal11ng near property n Painting Dripping on House n Paint Dripping,on Car or other n Other: -------- n TeleVlstonRecepUonInterf~rence n Radio Reception Interference n ShortWave Rad10 Interference n Taping ofRadio Or Cassettes Interference n VCR Playing Clarity n VCRTaping C18l1ty ~eJephoneClarity n Answering Machine Clarity n Garage Door MalfunctJon n Spontaneous Power Surges (1i)Car Alarm Malfunction n Other: ------- 6dCWlonal COmmegt?? Qu!tfSlgD8, yd CoScems Regardig,Sutro Tower:: (, , '., I, ',)' ../ (over) I am concerned about the.unknown effects of the tower upon emergency disaster' plans and upon the structuraltntegnty of neighboring reselVOtrs. I OPPOSE ANY EXPANSION OF SUTRO TOWER FOa. THE FOLLOWING REASONS: A suitable site for dtgJta]1V antennae already eXists on Mt. San Bruno such that Mount Sutto wtll be obsolete and no longer needed. lam concerned about a reduction In property values tn adjacent neighborhoods. I am concerned about the collapse ofthe Tower In the event of an earthquake I am concerned about the collapse ofthe Tower in the event of a landsUde as well as the weight of the Tower on the hill-side. lam concerned about the structural fallure ofthe tower. I am concerned about projectiles from the Tower strtklng my neighborhood. lie metal siding, bolts, wires, cables. tools. etc.) I am concerned about any addttionalinterference with telephones. radios. N's. etc. which l1In1t the use and enjoyment of my home. I am concerned about the unknown health effects ofcombined analog and digital electromagnetic radiation. I oppose continued u.seor additions to Sutro Tower absent the completion of an tndependent reUable epidenliologlcal study pertaining to any and all related health effects which Sutto Tower and or Its emIssions are responsible for introducing into my residential neighborhood. I oppose continued use or additions to Sutra Tower absent the completion of a comprehensive disaster preparedness plan by the CIty and County of San Francisco pursuant to the Master Plan which W1ll exantlne the potential impacts of the tower on emergency response, upon the Uves and health of the residents. and the mitigation plans needed to be put into place to combat the effects ofthe Sutto Tower on any emergency or evacuation plans. X- x.. Sutro Tower is Visually obtrusive and would like to see it phased out. Name~0S/~SCt1jt'-'j'Ch Address Ltl GnLlsiph£ "leY, san FranclSCO. Ca1Ifornla 94lJY Please Mod me a copy 01 tbe.ReYfsedBIR prior to approval. auch tbat I may comment upon It. In additiOn. pleueadd.my name to tbe Uat of "Interested Partie." reprcUol any INue pettalnlll' to Sutro Tower. Inc. Signed: $cf:Vr-xJ1n· &!PwWC/0 Date: o/JH7 -,. . .. , ", " 'I act7CX~./U4~£-i Invv.~~~ ~1-'. £4 :h1.1J4-- ' """"H"""~ I OPPOSE ANY EXPANSION OF SUTRO TOWER FOR THE FOLI"OWING REASONS: A sUitable site for digitalTV antennae already exists on Mt. San Bruno such that Mount Sutro wlll be obsolete and no longer needed. I am concerned about a reduction in property values in adjacent neighborhoods. I am concerned about the collapse of the Tower in the event of an earthquake I am concerned about the collapse of the Tower In the event of a landslide as well as the wetght of the Tower on the hill-side. I am concerned about the structural fallure ofthe tower. I am concerned about projectiles from the Tower strtklng my neighborhood. (Ie metal siding. bolts. wires. cables. tools. etc.) We, the undersigned residents of San Francisco, have not been adequately informed or advised about the proposed addition of Digital Television to Sutro Tower. We request that this project be halted until a full, adequate, and independent analysis of the substantial environmental impacts, as well as the alternatives to the project, are made. Please circulate the revised copy of the Draft EIR dated July 9, 1997 for public review and comment. Name Address Phone Date Petition Circulated ---------------_._----------------- Association P. O. 'Bo/t31002 San J"ramisco, CalijcJrTtw9~131 October 10, 1997 Hand Delivered L.jl... ' I - '::lal" rrc:lflt.;l'=''-'-' ".1:. , ." (' , .~ .-,\-, ;; Ms. Joan McQuarrie, Chief Building Inspector Department of Building Inspection 1660 Mission Street San Francisco, CA 94103 Dear Mr. McQuarrie: Re: Sutro Tower Digital TV Antenna Permit· ApplicatlOn 9718925 - 9/25/9i This letter is in reference to the above building permit application, filed on September 25, 1997. Please be advised that the enclosed letter from Lloyd 5. Cluff, former Chairman of the California Seismic Safety Commission, raises serio\.t:> gl.lestions regarding the stability of Sutro Tower during a large e'lrtllquilke, ;\lld puts the City on notice that, in his opinion, the addition of DTV antennat> to Sutro Tower would be "foolhardy" without a full dynamic analysis conducted by structural engineers fully knowledgeable of the new seismicengine~ringdata from the Loma Prieta, Northridge, and Kobe earthquakes. Mr. Cluff has spoken with~1r.John Osteraas, Principle Engineer, Failure Analys~ Associates, Menlo Park. Mr. Osteraas is willing and able to perform anal'al)'s~::-that we feel would be appropriate for the Sutro Tower. The only prudent course of action for the City is to conduct such an analysis, inasmuch as the City considers Sutro Tower to be an "essential facility," and it is located within 5 miles of the San Andreas fault, in the midst of a highly populated RHI-D neighborhood, and adjacent to three of the City'S main reserVoirs, a large elementary school and a fire station. Thank you for you prompt attention to this matter. Sincerely, J. I,· .-,~, Nancy C. Hogan, President (415) 621-3341 I, cc: Robert Passmore, Zoning Administrator Judith Boyajian, Esq., Office of the City Attorney 'FROU GRAHAM&JAMES LLP SF September 10. 1997 (TUE) 9. 23 9/ ,f::-. ,)., ; i: >: .'''i, oJ i,' ? .1". lrrahaln & Jan1es LLP ? ? ? RECEIVED A C8hlOfrn$Reais~arQrs Limited Llanil,h'P."'nt:·:':-·h~ ~1'l:-;udJnGJlfCltfUJCr-,...! C¢.rporatlojr:~ SEP 1 0 1997 VIA MESSENGER Ms. Hillary E. Gltelman Environmental Review Officer San Francisco Planning Department 1660 Mission Street, Fifth Floor San Francisco, California 94103·2414 Re: Sutro Tower Digital Television (OTV) Draft Environmental Impact Report. 96,544E, dated July 9,1997 Dear Ms. Gitelman: This firm represents Watson Communication Systems, Inc, ("Watson"). which is the owner and operator of the telecommunication tower site located on San Bruno Mountain In San Mateo County. We are writing on behalf of Watson to provide comments on the Sutro Tower Digital Television (DTV) Draft Environmental Impact Report - 96.544E, dated July 9, 1997 (the "Draft EIR"). especially to correct the inaccuracies and misleading statements in the record concerning San Bruno Mountain as an alternative to the proposed Sulro Tower project (the "Project"). PRELIMINARY STATEMENT AND SUMMARY As an Initial matter, we must express our grave concern and conclusion that the Draft EJR has substantial defiCiencies and consequently fails to comply with the Qtandards of the California Environmental Quality Act, Cel. Pub. Res. Code Sections 21 000~.HQ. (UCeQA"), the CeQA Guidelines and other applicable legel standards. The Draft EIR thus is legally inadequate. The City and County of San Francisco Planning Department and related agencies (the "City") therefore must reject the Project under CEQA, the City's Discre tionary Review Policy for Sutro Tower adopted July 14, 1988, Resolution No. 11399 ("Resolution No. 11399"), and other applicable authorities. Attorney~ One.Mlillll(il·r:~P101:~ SUllo~OO Sao Francls:o CA ~t':';'~:9c~czee Fa_(~'5~3.';;~;:; j.reclltl Grahao\ & J301.' I I L'oi A..,;e'?? New~or~ ('::,f1Cf~O\;l~.~) P.,IO"'l:~ Sacram.'IO S.o.:"I~r:tr.:.s.:-: sume W'$hll·19~:I"I.:': atlf.~~ Ta:")'c. D."c<>J)~(jr~haUi ll: J:uues 8;l1'".i!l-oO ... H-=,r"vjf.,jn~ Jd.... a.'1c. M6IDOur:;~ P.':I- .'\fflli3ttl1 om.:", 51' .. ssais. e.... c.f"art?Sl ?~OMGRA~V.&JAMESLLP SF Ms. Hillary E. Gitelman San Francisco Planning Department September 10, 1997 Page 2 In brief summary. the Draft EIR is legally insufficient for the following reasons, discussed in more detail below: ? Inadequate and Mlaleadlng Project Description: The Draft EIR fails ade quately to describe the full extent of the Project as required by CEQA. The Project description is also Inaccurate and misleading. Certain assumptions on which that de8cr1ptlon are based l particularly concerning Federal Communica tions Commission eFCC") mandates. are inaccurate. The City and the public thus cannot fully assess the environmental impacts of the Project. ? Inadequate and Inaccurate Delcription of Alternatives, Particularly the San Bruno Mountain Altematlv.: The Draft EIR fails to consider the alternatives to the Project fully and edequately. In particular, the description of the San Bruno Mountain Alternative. which is the primary alternative, is inadequate and inaccurately portrayed. San Bnma Mountain is both a viable and an environmentally superior alternative. As explained below. the site is viable because Watson already has one tower at the site which could accom modate DTV broadcasting and has obtained approval from the County of San Mateo for an additional tower which could accommodate DTV broad casting. Such a tower couldb~constructed well within the FCC timetable, provided that the FCC timely grants exemptions to the five kilometer rule, discussed below. Moreover. as conceded by the Project sponsor, none of the identified environmental Impacts of the Project (including potential health risks. visual Quality, noise. transportation. and the like) would be experienced by City residents by Installing DTV on San Bruno Mountain instead of on Sutro Tower (DEIR page 6-6). Relying on the cited 1993 Browne report, the Draft EIR acknowledges that "DTV signals from San Bruno Mountain would be able to serve all of San Francisco" (Draft EIR [IIDEIR"] page 6-5). Thus the Draft E1R itself eatabli8hes that the City could be equally well served by DTV trans missions from the more remote San Bruno Mountain location instead of Sutro Tower, without compromising DTV signal quality for the City. For these reasons. as further discussed below, the San Bruno Mountain alternative to provide DTV to the City is both a viable and environmentally superior alternative to the proposed Project. :ROM GRAHAM&JAMES LLP SF Ms. Hillary E. Gitelman Ssn Francisco Planning Department September 10, 1QQ7 Page 3 ? Failure to Identify and AddrGSS Significant Environmental Impacts and Mltlg.tlon Measures: The Draft EIR is also insufficient for failing to identify any of the several significant impacts which will result from implementation of the Project and for failing to discuss corresponding mitigation measures. The Draft EJR's failure to analyZe the above topics in a legally adequate fashion violates CECA. CEQA Guidelines, §§ 15120.15121. 15123. 15126. If significant new information is added to the Final EIR in response to these and other comments to address the del1clencies noted, then the City must re-notice and re circulate the EJR before certification pursuant to CEQA. Cal. Pub.Re~,Code § 21092.1: CEQA Guidelines, § 15088.5. These comments and the anticipated comments of other interested parties. as indicated at the July 24, 1997, hearing, make recirculation appropriate In this case. !d. SPECIFIC COMMENTS I. THE DRAFT EIR IS INADEQUATE AND MISLEADING BECAUSE IT FAILS TO ACCURATELY DeSCRIBE THE FULL EXTENT OF THE SUTRO TOWER PROJECT FOR DTV, AS REQUIRED BY CEQA. Under CECA. the Project must be fully, accurately, and adequately described. CEQA Guidelines §§ 15124, 15147, Notwithstanding this statutory mandate, the Draft EIR does not fully or adeQuately describe the Project. and is fraught with inaccuracies and misleading statements. Some suchst~tementsundercut the premises on which the Project Is proposed. A. The Project Description Is Inaccurate and Misleading Because ThQ FCC Has Not Mandated The DN Implementation Requlrementa Asserted In The Draft EIR Or Designated Sutro Tower As The Preferred Location For DTV Transmission The summary of the Project (Section 1.0) is inaccurate and misleading in describ ing the purported need for the Project to comply with FCC requirements. Thus substantial doubt is cast on whether the Project sponsor has established a genuine need for the Project. First. the Project sponsor miSleadingly asserts (1) that the Project IS being proposed to comply with the FCC mandate that ".ali television broadcast stations in - :~'OMrr- ''';A'!& 'AMPc: '; p r'J:; .:l I unA.? lY.~_'- L_. C>. Ms. Hillary E. Gitelman San Francisco Planning Department September 10,1997 Page 4 the United States Implement DTV signal broadcasting" (DEIR page 1-1, para graph 2, last sentence: emphasis added) and (2) that the FCC deadline for begInning DTV signal broadcasts in the Bay Area is October 1998 (DEIR page 1~ 1, paragraph 3). The impression thus given is that the Project is needed to provide OTV transmission for all television stations in the Bay Area by October 1998. This is incorrect. In actuality. the FCC's initialimp)ement~tjonrequirement applies only to the affiliates of the four major networks. .5i.ii Fifth Report and Order, FCC 97..116, April 3, 1997, MM Docket No. 87-208, at 11 76. Further, the applicable FCC deadline for major network affiliates in the top thirty markets (including the Bay Area) is May 1, 1999, several months later !.han the Project sponsor asserts. ld. Other commercial stations need not construct OW facilities until May 1. 2002, and non-commercial stations have until May 1. 2003 to construct facilities. J.d. The October 1998 deadline asserted in the Draft EIR is thus wholly miSleading. The only relevance of October 1998 is that it represents a XQlyotary commitment by three stations which currently transmit NTSC signals from Sutro Tower to implement DTV in order to capitalize on an anticipated, and well-publicized. pre-Christmas television set sale demand. (Se,e attached "Broadcasting & Cable Magazine" article dated July 21, 1997.) The Draft EIR also is written in such a way as to imply. improperly, that the FCC has required that DTV broadcasts be located at Sutra Tower because DTV broad casts mutt be made from a location no greater than five kilometers from the site of the existing NTSC broadcasts (DEIR page 1-1). This is incorrect. The fivQ kilo meter radius requirement Is Intended to give fleXibility tobroadca~ters,In fact, the FCC may grant exemptions to the cited five kilometer requirement.~Sixth Report and Order, FCC 97-115, April 3, 1997, MM Docket No.87~268("Sixth Order"), at 1f 102. 1 Most disturbing, however, is the gro5sly misleading and inaccurate statement In the Draft EIR that the FCC has designated $utro Tower as the~preferredlocation" for DTV transmission and/or has "required" DTV antenna installation at Sutro 1 If e 8tation wishes to locate it5 facilities outside the five kilometer radius. it must apply for approval from the FCC to move the facilities with a SectionV~D application form. Appendix D to the Sixth Order. which includes thecompl~tion of a series of engineering surveys to determine that no interference occurs with other channels. (Sti Draft EIR at 6-4, paragraph 2.) -,flU 1'f"A':~Mo.lAM~"'T l"I SF :n.v~¥~U'n hn. ..ct... .w~L ... r Ms. Hillary E. Gitelman San Francisco Planning Department September 10, 1997 Page 5 Tower. s.u DEIR page 2-1, paragraphs 2 and 3;~a1s.Q DEIR page 1-3. para graph 3, first sentence. Contrary to the express statements in the Draft EIR. the fCC has not mandatQgjhat DIY be broadcast from Sutra Tower The FCC has never made - nor js J1 emoowered to make ---any determination that "thA Sutro lower location d ., was .. , designated as the I:lrjme facility for television broadcasting for San Erancisco stations" (DEIR page 2-1, paragraph 2. first sentence). That statement iscomplete~~.Indeed, before Sutro Tower was built, television stations were transmitting their signals from San Bruno Mountain and several continue to do so. Notwithstanding television broadcast coverage from Sutro Tower for NTSC transmission, the Project sponsor itself has acknowl edged the DTV signals from San Bruno Mountain can serve all of Si3n Francisco (DEIR page 6-5). B. The Project Description Is Inadequate Because The Physical Description and Discussion of Project Characteristics Are Inaccurate, Incomplete, and Misleading. The physical description of the Project is deficient in that it suggests that the Project consists merely of the addition of a 125-foot beam which would be added to the tower at Level 6, approximately 755 feet above the base of the tower, with ten DTV antennas attached (DEIR page 1·3, second paragraph; page 2-8). Lacking in the Project description - although required by CEQA - are integral elements of the Project, including physical description of the ten proposed new antennas; auxiliary antennas, which are not presently proposed but which may be installed in the future (DEIR page 2-8): the seismic upgrade to Sutro Tower which recently received a categorical exemption from CEQA by the City but which is integral to the Project; and electrical use and tenant improvements (DEIR page 2 10). This approach results in impermissible segmentation. CEQA does not permit a Project sponsor to segment a Pro1ect to avoid full disclosure of the Project's sig nificant impacts as a whole. CEQA GUidelines, §§ 15126, 15165, 15378(a), (c). Each of the inadequacies identified here is discussed briefly below. First, the Draft EIR Is deficient for falling to describe and discuss tne impacts of the related antennss. First; there is no description of the size of the ten new DTV ?ROW.G~~HAM&JAMES~LPSF Ms. Hillary E. Gitelman San Francisco Planning DQpartment September 10, 1997 Page 6 l~'!·-\ ," \. '01-.11 r., r"''-'',-r 'j. L: ,;! antennas and their diagrams and other visual depictions are insufficient. 2 The text's cryptic statement that "no auxiliary antennas are proposed at 1hls tim-.e" (emphasis added) suggests that the Project may actually be much larger in scope. To the extent that auxiliary antennas are a fundamental part of the overall DTV system, or are anticipated to be added in a foreseeable time frame, they should be included within the Project description, and the foreseeable impacts they may have must be evaluated under CEQA. CEQA Guidelines, §§ 15126(a). 15165 Because auxiliary antennas are already in use at Sutro Tower for NTSC broad casting, it is not merely speculative to assume that auxiliary antennas may be installed in the foreseeable future for DN. Further, the Draft EIR is misleading and inaccurate by omitting discussion of the related seismic upgrade to Sutra Tower\ which the City Planning Commission determined was eligible for a categorical exception under CEQA.(~Ietterof City and County Planning Department dated June 6. 1997, attached.)3 The 2 Figure 4, "DTV Antenna Front View" (DEIR at page 1·9), contains little detail and does not present a clear picture 8S to how the new 125-foot beam will be viewed by the public. Figures 7 and 9 (DEIR at pages 3-30 and 3-32, respectively) do not provide adequate pictures either. In particular, no side view is presented. tc show the full impact of the eddltion and protrusion of the proposed beam. Also omitted from the photo montages in Figures 7 and 9 is any clear visual depiction of the ten digital antennas which are to be mounted on the 125-foot beam. Further, there Is no evidence in the record to support the statement that the proposed "antennas that would be added to accommodate the Sutro Tower DTV project would not be readily noticeable, or create a substantial change in the appearance of the existing tower" (DEIR at page 3-28). In addition\ that statement does not account for .all visual changes associated with the Project. Accordingly, the comments related to "Visual Quality Effects" (DEIR at pages 1 6 and 3-27 to 3-28) provide a misleading and incomplete picture of the visual effects of the proposed antennas and the proposed new 125-foot beam. In addition, the pictures do not depict the other "tenant improvements" which will necessarily be part of the new DTV antenna project. and which could have significant visual effects. 3 We understand that the Planning Commission approved of this exemption at a hearing on June 19. 1997. -,. 0 1 'GRA··AlU~.TAMEI" . Tp~F ::1. Nt T, n l\lO(.J i) L....~ Me. Hillary E. Gitelman San Francisco Planning Department September 10,1997 Page 7 (\ r f".l 9" 'j, L: ! Project sponsor applied for this upgrade separately, although it is an integral part of the DTV Project implementation. This -approach constitutes impermissible segmentation under CECA. CECA Guidelines, §§ 15126, 15165, 15378(a), (c); Laurel Heights Improyement Association of San Francisco, Inc. y, Regents 9JJbQ universitY of California, 47 Cal. 3d 376 (1988). It also is misleading to the public thus to attempt to minimize the full extent of the Project and thus the fUll extent of the expected significant impacts. The Draft EIR also fails in its Project description to adequately address anticipated _increased electrical use. installation. and operation. Again without appropriate description or analysis of the potential Significant impacts, the Draft EIR cursorily refers to unspecified tenant improvements by stating that the Project may "require additional building and electrical permits to allow Sutro Tower tenants to "make necessary improvements in their leased space to accommodate OTV equipment' (DEIR page 2..10). As a result of these omissions and/or misstatements in the Project description. the Project sponsor has failed to meet the requirements of CEQA. CEQA Guidelines, §§ 15124, 15127. Further, as noted above, Project segmentation is impermissible under CEQA. CEQA Guidelines. §§ 15126. 15165, 15378(a), (c). The Draft EIR is thus legally inadequate. C. The "Project L.ocation" Discussion Contains Misleading Statements Concurring Sutro Tower's Feasibility. Also misleading is the Draft EIR's statement concerning "Project Location" (DEIR page 2·3. paragraphs 2-3. second sentence). that the Mount Sutro site "is the most feasible-site In San Francisco from which radio and television signals can be broadcast without shadowing from other higher locations." Even assuming that this statement is correct that a more suitable site is not available within the City. It ignores San Bruno Mountain as a more desirable altemative physically located outside the City, but which could serve the City. In addition, this discussion is irrelevant because ·shadowing" is only an issue with NTSC transmission, not with DTV transmission. Most relevant is the conclusion of the 1993 Browne report. relied upon by the Project sponsor, that for all three stations analyzed, DTV s;goal§ from San Bruno Mountain would be able to _Sfm'e all of San(ran~ (DEIR pages 6-1 to 6-5). The Draft EIR thus acknOWledges that the funC1flmental ?ROM GRAHAM&jAMES LLF SF Ms. Hillary E. Gitelman San Francisco Planning Department September 10,1997 PageS (~pr\ \ j, \/ ??0/ I) ,.,.' (')7,~1"' 'j,e, '; if::C purpose of the Project, le.... DTV transmission, can be accomplished from San Bruno Mountain. D. The Draft EIR Falla To Addross Thea Impact Of Resolution No. 11399. CEQA requires a Project description to include all required governmental approvals, CeQA Guidelines, § 15124, CeQA also reQuires that an EIR discuss any inconsistencies between 8 proposed project and applicable general or regional plans. CeOA Guidelines, § 15125(b). Although the Draft EIR contains a fleeting reference to the City's Discretionary Review Authority pursuant to Resolution No. 11399 (Section 2.4.2, "Approvals," at DEIR page 2-10, last paragraph). it fails to address its significance and evades the fact that the currentfy proposed Project is inconsistent with its principles. Resolution No. 11399 was enacted in 1988 as a response to the City's grave con cerns regarding an earlier proposed expansion of the Sutro Tower, That earlier propOsal was less extensive than the current proposal in that it involved a building permit application to expand the transmission building at the base of Sutro Tower to accommodate the transmission equipment, including antennas, for two additional television stations. The City Planning Department determined at that time that suctl an expansion would be an addition not in general conformity with the plans and exhibits approved as a part of the original 1969 Conditional Use Permit far Sutro Tower (Resolution No. SgS7). Thus, on June 16, 1988, the City Planning Commission held a public hearing to determine whether Sutro Tower could be granted conditional use approvel for the proposed expansion. Based on testimony received at the hearing about the potential health impacts associated with the proposed expansion. the Planning Commission was prepared to find (and had drafted a motion so to indicate) that the expansion would not pass the test set forth in City Planning Code Section 303. That section provides that a conditIonal use may be authorized only after making findings that, among other things, the proposed use will not be detrimental to the health, safety, convenience. or general welfare of persons residing ·or working in the vicinity and would not adversely affect the Clty's Master Plan (ae.e Resolution No. 11399, page 2). The Planning Commission's proposed motion indicated that "in the face of testimony Ms. Hillary E. Gitelman San Francisco Planning Department September 10. 1997 Page 9 received regarding the possible health hazards ... the Commission could not with clear conscience make the reQuired Code Section 303 finding," ld. Before the written motion could be finalized, however, the project proponent revoked its application. As a result. the Planning Commission adopted Resolution No. 11399 because of its substantial concems about future proposed expansions and the potential detrimental effects thereof. to ensure that the Commission would have a policy of discretionary review over any and all proposed expansions at Sutro Tower. J.d. Given the significantly more extensive scope of expansion proposed by the current Project (to expand substantially the capacity of at least ten stations), plus new seismic-related construction, the Planning Commission would presumably have similar concerns today about the public safety and the potential incon sieteney with the City's Master Plan. The Draft EIR does not address why the Project, as currently proposed. should be viewed any differently from the consideration given to thee~rliF'JrI1roposed expansion. The Draft EIR also does not address the consistency or lack of con. sistency with the MasterPlan.~In short, the Draft EIR is defic4ent in not address ing these issues. II. THE DRAFT EIR IS INADEQUATE BeCAUSE IT MISCHARACTERIZES AND INACCURATELY PORTRAYS THE AL.TERNATIVES TO THE PROJECT. INCL.UDING THE SAN BRUNO MOUNTAIN ALTERNATIVE. Section 6.1. "Introduction," to the llAltematives" in the Draft EIR improperly states CEQA's requirement for analyzing alternatives and its applicability to the proposed Project. In general. an EIR must describe a range of reasonable alternatives to the Project or Project location that could feasibly attain the basic Project objec tives.. CEQA Guidelines. § 15126. Further. the EIR should focus on alternatives capable of reducing the proposed Project's significant environmental effects. CeCA Guidelines, § 15126(d). The misstatements on DEIR page 6-1. second ~The conclusory statement in Section 3.3 that "[t]he current project would not obviously or substantially conflict with any such policy" (DEIR page 3-33) is Inadequate, particularly in view of the Resolution. ?~OMGRAHAM&JAMES LLP SF Ms. Hillary E. Gitelman San Francisco Planning Department September 10, 1997 Page 10 paragraph, are generally based upon the faulty conclusions that (i) there are no significant impacts from the proposed Project. and (ii) alternatives such as San Bruno Mountain cannot provide DTV service to City residents. A. The No Project Alternative Section Contains Misleading Statements. Section 6.2. "No Project Alternative." contains misleading and irrelevant state ments whIch imply, and may erroneously frighten the public into believing. that if DTV is not placed on Sutro Tower, then San Francisco would suffer some undescribed harm a6 no longer being the I'primary city of license" for the television stations (CEIR page 6·3). This statement of opinion by the Project sponsor is simply false and appears designed to obscure from the public the environmental benefits of an off-site location. The FCC rules regarding the city of license guarantee the City coverage rights regardless of facility location. 47 CFR § 73.685{a). Thus, the City's status would be unaffected by the implementation of DTV at a site other than Sutro Tower (such as San Bruno Mountain). Further. the discussion of the Project sponsor's reasons for rejection of the No Project Altemative mischaracterlzes the FCC's requirements in that it suggests that Sutro Tower must provide "concurrent" NTSC and DTV transmission to comply wtth FCC rules (DEIR page 6-3). The FCC doas not have any such requirement. Rather, the FCC requires that certain network affiliates transmit NTSC end 01'/ concurrently for a specified time period. but those broadcasters are not required to transmit D1V from the exact same location as their NTSC transmissions. se.e above discussion concerning the five kilometer radius rule and possible QxamptionQ. B. The Draft EIR Mischaracterizes And Inaccurat91y Portrays The San Bruno Mountain Alternative, Which Is An Environmentally Superior Alternative. The Draft EIR, in Seotion 6.3, "Off-Site Altematives/' contains many factual misstatements and inaccuracies which may negatively influence the EIR decision making process jf not rectified - particularly concerning the most viable, and environmentally superior. alternative, San Bruno Mountain. In attempting to justify the PrOject sponsor's conClusion that the San Bruno Mountain Alternative is not Ms. Hillary E. Gltelman San Francisco Planning Department september 10, 1997 page 11 1"'";:""\ ~lV~)9 r." 'f... ., L ? ,,: J '"" .;' the environmentally superior alternative. the Draft EIR contains statemGnts which are flatly wrong and misleading to the public. First. the Draft EIR attempts to discredit the San Bruno Mountain location by including an incomplete and misleading excerpt from a statement by Mr. Jay Watson, President of Watson. regarding NTSC transmission. As noted previously, NTSC coverage from Sutro Tower and San Bruno Mountain is not identical, but such service from San Bruno Mountain to the City is certainly not inferior. Second, NTSC coverage Is Irrelevant to the issue of DTV coverage because of the difference between the two technologies. More importantly, the Draft EIR ~and~W2Q.Q the 1993 Browne report which established that fnr aU Ibm station analyzed, "D7Y sjgnals from San Bruno 'iiould be able to serve all ofSon Franc/sco· (DEIR page 6-5). The Draft EIR also asserts. without references to any study or other factual substantiation. that the maximum RFR levels at San Bruno Mountain would increase 11.7 percent of the FCC 96 Guidelines if DTV were added I as contrasted with a rise of 1.6 percent for Sutro Tower (DEIR page 6-6). Nevertheless. the Draft EIR also acknowledges that impacts related to the Project would not occur with the San Bruno Mountain Alternative (DEIR page 6-6). ThUS. the Project sponsor acknowledges that with acceptance of the San Bruno Mountain Altematlve, there would be no RFR impact on the City and thus no impact on the resident$ and workers located near Sutro Tower, compared with the identified impacts resulting from OTV plocement at Sutro Tower. The Draft EIR also suggests that the FCC prefers Sutro Tower. by referring vaguely to the FCC's "finding" in its "initial authorization of the existing Sutro Tower site" (DEIR page 6-7). As stated earlier. there was no such FCC finding and transmission at San Bruno Mountain has been ongoing for many years. The Project sponsor also falsely claims that the alternatives cannot provide adequate facilities for the existing television stations at Sutro Tower. As discussed above, San Bruno Mountain can provide adequate facilities for the television stations ·required to broadcast DTV on the FCC timetable. Further. contrary to the Project sponsor's assertions. and as established above, there would be no lesser household coverage in San Francisco if 01\1 is transmitted from San Bruno Mountain. ~;OMG~A¥~M&JAMESLLP SF Ms. Hillary E. Gitelman San Francisco Planning Department September 10, 1997 Page 12 Similarly, in an apparent effort to discredit the San Bnmo Mount2in AlternatlvG, the text states that it Is at a lesser elevation than Sutro Tower and would present "greater potential hazards to airspace navigation" (DEIR page6~7).In fact, the addition of DTV at San Bruno Mountain would pose no threat to aviation. The existing towers at San Bruno Mountain (elevation approximately 1,300 feet) are fully within FAA height reQuirements. Any new tower which Watson may construct to add addttional DTV capacity presumably would be FAA approved so long as it Is not higher than Watson's tallest existing tower (325 feet). The Project proponent has assertad, in rejecting the San Bruno Mountain Alterna tive, that It is at "lesser relative elevation" (DEIR page 6-7}. However. the impact of height differs significantly between NTSC and DTV transmission. The FCC has two distinct sets of rules for each of these methods of transmission.~47 e.F.R. § 73.684 (NTSC); § 73.623(e) (DTV). Thus, it is inappropriate to base conclusions about DTV eover;ge on the experience of NTSC. After eliminatJng the physical reasons asserted above by the Project sponsor for rejection of the San Bruno Mountain Alternative, the remaining reasons for the sponsor's rejection of the San Bruno Mountain Alternative are, bluntly, economic. The Project sponsor asserts that if DTV is located elsewhere, then Sutro Tower could be rendered useless for its principal function of television broadcasting. In this rapidly changing era of teleeommunicatlons. with a constant influx of develop ments in technology. this assertion Ie by no mesns a foregone conclusion. All of the potential uses of OTV cannot currently be predicted with specificity. as broadcasters explore different uses of the new spectrum. including the use of multiple channels within the digital frequency allotment. In any event, the potential for economic loss ifthe Project Is not approved does not compel the conclusion, in the face of factual corrections to the record, that the Sutro Tower Project is environmentally superior to the alternatives presented, including the San Bruno Mountain Altemative. III. THE DRAFT EIR IS INADEQUATE BECAUSE IT FAllS ADEQUATELY TO DISCUSS SIGNIFICANT ENVIRONMENTAL IMPACTS AND REQUIRED MITIGATION MEASURES, IN CONTRAVENTION OF CEQA. The Project sponsor has conceded in the Draft EIR that none of the impacts identified if the Project were approved and implemented would occur jf the San Bruno Mountain Alternative ware adopted instead. Therefore. we do not discuss -~'oul'~A"AM&'AMj;'!'\ Ll prill ; t\ N, \Jr. n. J ,.~.. u. Ms. Hillary E. Gitelman San Francisco Planning Department September 10, 1997 Page 13 in detail the shortcomings of the Draft EIR in failing to identify or adequately to discuss significant environmental impacts. Of course, CEQA requires that signifi cant impaots be discussed in an EIR. CEQA Guidelines, §§ 15126, 15130(a). Contrary to CEQA, the Draft EIR cursorily concludes that U[t]he proposed project would not result in any potentially significant effects that could not be avoided if the project is implemented" (at page 5-1). At a minimum, the impacts discussion is incomplete because the Project description is inaccurate and incomplete. as discussed above. Therefore, the EIR must be augmented to discuss further the potential impacts on public health. existing zoning andplans,~land uses, transportation, and the like. Because. based on the Draft EIR, the full scope of the Project has not been and cannot be assessed, its significant impacts have not been discussed as required. Thus, this incomplete analysis has resulted in the erroneous conclusion that no 5 For example. the Draft EIR has insufficient discussion of the ProJect's alleged compatibility with existing zoning and plans, including the City's Master Plan, which provides policies concerning land use and physical environmental issues. First, the "compatibility" of the Project with such plans cannot be fully assessed because of the incomplete. Project description. Moreover, the Draft EIR con cludos. without anyeub~tantivediscussion, that the Project "'would not obviously or substantially conflict with any such policy [related to physical environmental issues in the City's Master Plan]" (DEIR page 3·33). The record lacks support for such a conclusion. At a minimum, en inference is drawn that there is some conflict with these plane. The City made a previous determination that the 1988 proposed expansion of Sutro Tower would conflict with specific goals contained in the City's Master Plan. Therefore, the Project proponent should be expected thoroughly and specifically to explain why a further proposed expansion of Sutro Tower does not present an inherent conflict with the goals of the City's Master Plan. Finally, under CeQA the presence of any conflict between a project and adopted environmental plans and goals of the community will normally have a tlignificant effect on the environment (CECA Guidelines. Appendix G, subpart (a». Conversely. the absence of any conflict will not preclude a finding that a significant environmental offect exists. Thus, the lack of adequate discussion on compatibility with the Master Plan demonstrates but one fundamental conflict with the Project sponsors determination that no significant impacts are associated with the Project. ?~OMGRAEAM&JAMES LLP SF Ms. Hillary E. Gitelman San Francisco Planning Department September 10, 1997 Page 14 ,i·e .. , ... mitigation measures are required. The EIR must provide for adequate mitigation measures for the significant impacts identified in these and other comments. For the foregoing reasons, Watson urges the City to reject the Draft EIR as legally insufficient under CEQA. Thank you for your consideration of these comments. RespectfulIy aubmltted I jJ ~((.:)UA~f;_ Gilda R. Turitz 3'~ of GRAHAM & JAMES LLFl GRT/reb Enclosures CC: Mr. Jay S. Watson (with enCloeures) -I Maureen Bennett, Esq. (with enclosures) Our File: 30408.00017 '.. . , LAW OFFICE OF REED W. SUPER . . 1535 MISSION STREET . SAN FRANCISCO, CALIFORNIA 94103 ' tel: 415-565-0882 fax: 415-680-2450 September 10, 1997 . VIA HAND DELIVERY Hillary Gitleman, . Environmental Review Officer Planning Department . 1660 Mission, Street, 5 1b Floor San Francisco, CA 94103-2414 Re: Sutro TowerDigital'T~levision(pTY) . Draft Environmental Impact Report (No. 96.544E) Dear Ms. Gitelman: Irei>resent the Twin Peaks ImprovementAssoci~tion(TPIA) and the Midtown Terrace. Homeowners Association (MTHOA) with regard to the above-referenced project. :This coIimi et1 t letter is submitted on behalfofTPIA and MTHOAto inform the CitY that the Draft 'Environmental Impact Report (DEIR) for the proposed Sutro Tower Digital relevision (DTV) project (the"Project"), fails to comply with the requirements ofthe California Environmental ' Quality Act, Public Resources Code § 21000 et seq. ("CEQA"), andthe CEQA Guidelines, California Code ofRegulations, title 14, § 15000 et seq. and therefore must undergo, substantial ' revision and be recirculated for public comment before it may be legally certified by the City. ' As discussed below, the DEIR for the proposed Project, both'in process and in product, is , wholly inadequate, with the result that decision-makers and the public are depnved ofinformation they require in order to assess the project fairly. CEQA requires an EIR to be an informationaI ' document which will inform public agency decision-makers and the public generally ofthe' significant effects ofa project, identify possible ways to minimize those effects, and evaluate ,project alternatives: The DEIR for the DTV Project fails to fulfill any ofthese fundamental goals. The DEIR provides insufficient detail on the scope ofthe'Project and adverse impacts, incorrectly assumes without evidence that impacts are insignificant, fails to identify effective mitigation , measures, and fails to adequately consider alternatives that are capable ofmitigating the Project's significant impacts. . ' Many ofthe specific deficiencies in the DEIR have been and are being communicated to, the City directly by my clients and other parties. This' letter is intended to supplement and amplify those comm.ents. " ,Hillary Gitleman , September 10. 1997 Page 2 EXECuTIvE SUMMARY The DTV DEIR suffers from several systemic problems which undermine the accuracy and legitimacy ofthe entire document. Sutro Tower (the "Tower") was built prior to the enactment ofCEQA has thus never before, been subjected to environmental review. However. as the Proponent acknowledges. the Tower is a "deteriorated structure" which does not "meet current~etystandards." It was designed in accordance with "safetystan~ardsappli~lejn . 1969. Thirty years later, after decades ofexposure arid corrosion. the Tower is no longer at peak structurai integrity and seismic safety." (See Exhibit A hereto, and discussion below.)· Thus. this proposed DTVProjeet. which will add significant weight and windload to the Tower. must be evaluated in the context ofoverall structural and safety concerns for the Tower. But the DEIR. does not do so. Instead. it focuses on radiofrequency radiation (RFR). which is a red herring to , the extent that RFR deflects attention from the numerous other environmental issues. The DEIR improperly segments environmental review ofthe DTV antenna installation from the related structural improvements. The proposed seismic and structural improvements are not categorically exempt from CEQA because, as acknowledged by the CitY and the'Proponent. they will facilitate the DTV installation and may therefore cause significant adverse environmental effects. In addition, DEIR's descriptions ofthe Project and its environmental setting are . , inadequate because the project objectives are overly narrow, key elements ofthe proposal are omitteq, and important aspects ofthe Project's setting are not described. The narrow Project objectives set forth in tRis DEIR exclude, by definition, any alternative sites. This defeats one of the central purposes ofCEQA. In addition, the deteriorated condition ofthe Tower and the details ofthe beam and antenna installation process, including auxiliary antennas and transformers. are not discussed in the DEIR. 'Fu'rther, the RFR data is not current, and the DEIR. fails to disclose,the proximity ofthe Tower to schools, two reservoirs and a dedicated greenbelt. The OEIR fails to analyze potentially significant adverse project impacts such as collapse , or structural failure ofthe Tower, conflicts with the Community Safety element ofthe General ? Plan and Plaiming Commission Resolution No. 11399 (which found any expansion ofthe Tower's facilities would be detrimental to nearby residents). The OEIR. also fails to analyze significant and adverse cumulative impacts from theProject including noise, visual impacts and interference with electronic equipment. Because the OEIR's significant impact analysis is fundamentally flawed, the OEIR improperly concludes that no mitigation measures are required. The OEIR also violates CEQA because it fails to analyze any alternatives whichcould obtain the objectives ofthe Project. However, San Bruno Mountain is a feasible, environmentally superior alternative for DTV broadcasts which must be meaningfully analyzed.. For all ofthese reasons, the OEIR must be substantially revised and recirculated for additional public comment. Hillary Gitlemari September 10, 1997' Page') I. DISCUSSION .mE DEIR IMPROPERLY SEGMENTS ENVIRONMENTAL REVIEW OF THE DTV ANTENNA INSTALLAnON FROM THE RELATED STRuCTURAL IMPROVEMENTS. . ",:' . , . CEQA requires lead agencies todefine the project under consideration as "the whole ofan action." (CEQA Guidelines'§ 15378(a).) An EIR must therefore analyze 'all phases ofa project, . including reasonably foreseeable future expansion that may result from the initial phase. -(CEQA. . GUidelines §1S'126~Laurel Heights ImproVement Ass'D, v, Regents QfUniv. ofCal. (1988) 47 _' . Cal.3d 376.) Thisrequir~mentis necessary so "environmental considerations don~tbecome. submerged by chopping a large project into many little ones --_each with a minimal potent;ial. " . impact on the environment - which cumulatively may have disastrous consequences." (Bozung v' .' LocAl Agency Form, Coromn ofVentura County, (1975) 13 Cal,3d ,263,283-84~City ofSantee: ·v. CountyofSan Diego (1989) 214 Cal.App,3d 1438, 1452.) A public agency may not segment a' larger project into two or more.small projects thereby mas,king-environmentalconsequences~. 'CEQA prohibits such a "piecemeal" approach. <Kings County Farm Bureau v. City ofHword (1990) 221 Cal.App.3d 692. 720.) The City is currentlypro.~essingtwo reiated applications submitted by Sutro Tower, Inc. (the "Proponent"). In addition to the DTV antenna installation which is the subject ofthe DEIR, the Proponent is also seeking a building permit to authorize seismic and structural improvements' to the Tower. (See Exhibit A, hereto, containing correspondence between the, Cityan~the, Proponent regarding the proposed structural improvements.) As the Proponent's attorney acknowledges in her May 9. 1997 letter. the Tower is 'a "deteriorated structure"which does not "meet current safety standards." (Exhibit A.) The Tower was desiglled in accordance with "safety standards applicable in 1969. Thirty years later, after decades ofexposureandcorro~ion, the Tower is no longer at peak _structural integrity and seismic safety." (Ibid.) The 'proposed improvements include bolting steelplates~dsteel angles to the Tower to reinforce its legs arid ,other members. (Exhibit A,5-14-971ette~from GCA Strategies.) . .. These structural improvements are not categoriclllly exempt from CEQA because they will facilitate the DTV installation and may therefore 'cause a significant adverse environmental effect: . Indeed, the upgrades are closely related to the DTV proposal. It would strain credulity to maintain that the'structural upgrades, which will cost $500,000 and are proposed at the same time as the antenna project. are coincidental and unrelated to DTV. The seismic and structural work is necessary because the DTV antennas and their massive support beam will add significant weight and windload to the deteriorated Tower. . . , , ·Indeed, both the City and the-Proponent have acknowledged in'writing that the two projects are closely related. According to the Proponent's engineering firm, the design studies for , , Hillary Gitleman September 10, 1997 Page 4 the upgradeswere based on the addition of"future equipment such as 'an HDTV antenna'; and "the structural upgrades '" [will] allow[] for the addition ofHDTV antenna in the future." '(Exhibit A. 4/22/97 letter from Kljne Towers.) LikeWise, the City has determined, as stated in its May 24, 1996 letter to the Proponent, that "[tlhe structural improvements proposed for Sutro . Tower are necessary to permit existing stations to install ATV antenna." (Exhibit A.) There is no eviden~or analysis suggesting thatth~detenorated Tower could accept the new DTV antetina and beam and' be in compliance with applicable reglilations without the upgrades.In.faet~the opposite is true. A~tegoricalexemption may not be utilized to evade CEQA compliance when there is ariy , reasonable possibiijty that the agency'sactionmay have a significant direct <?r indirectefIecton the environment. (CEQA Guidelines § 15300.2(c); Wildlife Alive v. Chickering (1976) 18 Cal.3d 190, 206.. ). Thus, courts find the lise ofa categorical exemption improperfor regulatory actions which may appear to be environmentally protective, ifa fair argument can be made that the project may ultimately have a significant environmental effect. (See Dunn-Edwards Corp. v.Bay, Area Air Quality Management District (1992) 9 Cal.App.4th 644, 654-55..) In Dunn-Edwards, a regulatory agency tightened emissions standards for volatile organic ' compounds (VOCs) in archiiecturalcoatings and claimed (as does the Proponent here) that such ,action was categorically exempt U1ider as an environmentally protective measure. (9Cal.AppAth 652-655.) The court found the agency's use ofa categorical exemption improper because the record contained evidence that the lowered emissions standard might prompt the use ofmore' ' coats and more frequent applications ofthe lower quality produCi:ts, thereby causing an'increase in : overall VOC emissions. (lQ. at p. 657-58.) Because ofthe potential for adverse environmental ' effect, environmentai~eviewwas required, and the agency's action constituted a prejudicial abuse ofdiscretion. (Ibid.) The situation here is also similar to that in McQueen v: Board ofDirectors ofthe Midpenisula Regional Open Space Dist. (1988) 202 Cal.App.3d 1136, where the agency defined its project too narrowly in its notice ofexemption. The Court ofAppeal held that the use ofthe exemption for a land purchase was improper because no mention wasmad~ofthe agency's simultaneous adoption ofa use and management plan for the property. The narrow project definition was an example of"the fallacy ofdivision," which can cause an agency 'to overlook a ' project's cumulative impacts "by separately focusing on isolated parts ofthe whole." (202 Cal.App.3d at p. 1144.) As in the Dunn-Edwards and McQueen cases, even though the 'proposed structural upgrades are ostensibly to improve the Tower's safety and might not have adverse impacts if viewed in a vacuum, there is substantial evidence that they may nevertheless have significant adverse environmental effects because they will facilitate the DTV project. Thus, the upgrade activities are'not categorically exempt and environmental review in full compliance with CEQA is , . Hillary Gitleman September 10, 1997 PageS required prior to their approval. . Even ifthe upgrades could be properly described as a separate project, they would" still need to be discussed in the DTV EIR in the context ofa cumulative impacts analysis as a "closely related past, present, [or] reasonably foreseeable probable future project." (CEQA Guidelines § " 15355:) ." ." ." " . As a result, the upgrades mu"st be analyzed~the same EIR as the DTV project so that the "''whole ofthe action" is reviewed in asingle environmental document. Comprehensive " environrriental review is necessary so that the effectiveness ofthe structural work Can be properly assessed With regards to the seismic safety and integrity ofthe Tower,. in light ofthe proposed installation ofnew DTV equipment. n. IN ADDmON, THE PROJECT DESCRIPTION IS INADEQUATE BECAUSE . . . .THE PROJECT OBJECTIVES ARE OVERLY NARROW, AND KEY ELEMENTS OF THE PROPOSAL ARE OMI'rrED. CEQA requires that an EIR contail:\ a description ofthe proposed project including~ alia the project's characteristics and objectives. (Guidelines § 15124.) "An aCcurate, stable, finite project description is the sine qua non ofan informative and legally sufficient EIR."·(County oflnyo v. City ofLos Angeles (1977) 71 Cal.App.3d 185,193~see also Discussion following CEQA Guidelines § 15124.) Thus where a·project description is curtailed, distorted or omits important aspects ofthe·project, the pIRs entire analysis will be fundamentally flawed and the· ·EIR cannot be legally certified under CEQA. (San Joaguin RaptorlWildlife Rescue Center v. County ofStanislaus (1994) 27 Cal.App.4th 713, 727; Santiago County Water District v. County ofOrange (1981) 118 CaI.App.3d 818, 829.) The project description in the DTV EIR is inaccurate, overly narrow, and omits key . "aspects ofthe project. To start with, as discussed above, the implementation ofthe structural and seismic upgrades must be included in the project description and analyzed in the EIR. In addition, the project description is also inadequate as follows: " o The project objectives are drawn overly narrowly. The"DEIRstatesthat the fundamental project objective is to enable Sutro Tower to provide cQncurrent DTV and NTSC broadcast signals. This objective is- too narrow because it forecloses consideration of feasible alternative sites or projects which is impermissible under CEQA (See, e.g.,.Kings County Farm Bureau v. City ofHanford (1990)221 Cal.App.3d 692, 735-37; Cil)' of Carmel-By-The-Sea v. U.S. D.O.T., (9th Cir. 1996) 95 F.3d 892,903-08~Save the Niobara River Assoeiation, Inc. v. Andrus (D.Neb. 1977) 483 F.Sl,lPP. 844, 862.) This issue is further discussed below in Section VII ofthis letter. Hillary Gitleman Septemper 10, 1997 . Page 6 o The DEIR fails to provide the weight or constituent materials ofthe i25-foot long beam, or to explain how it will be hoisted 755 feet up the Tower.. The DEIR also fails to explain how this beam (which is 3 feet wide by 3 feet deep and astall as a 12-story building) will be attached to the Tower. The OEIR states simply that "[n]o power impact tools·are anticipated to be necessary for'the installation process." (OEIR at p. 1-3.) However, no other information is given regarding the installation process or what tools will be used. Will the beam be welded to the Tower" Bolted to the Tower? Tied to the Tower? Will additional moorings, cables or trusses be added? How will the antennas be attached to'the . beam? What safety precautions, ifany, will be taken during the installation process to ensure 'that construction debris, tools, paint chips, etc do not fallon nearby residents or . into the nearby reservoirs? The OEIR is entirely silent on these issues. However, such information is necessary so that reviewers and users'ofthe EIR can assess the safety and , adverse impacts ofthe installation process and the long-term impacts ofhaving this, . additional 1,125 cubic foot beam plus its new antennas suspended an eighth ofa mile· . above the neighborhood. ' o The DEIR is ambiguous as to whether auxiliary DTV antennas will also be installed. The existing NTSC antennas have "stand-by" auxiliary antennas which broadcast when the regular antennas malfunction or are undergoing regular bi-monthly maintenance. (OEIR at p. 2-8.) Thus, it is reasonably foreseeable that the DTV antennas will also reqUire auxiliaries. Installation and operation ofauxiliary DTV antennas should be included in this project description. Likewise, the "additional data services"w~chthe EIR states can be .. accommodated by the OTV antennas should also be described and included in the project· description. ' o The OEIR also fails to explain the "necessary [tenant] improvements" which it states may require additional building and electrical permits. The project description mustd~scribe and analyze the additional facilities, activities and permits necessary for the television ' station tenants to operate and maintain OTV and NTSC broadcasts simultaneously. In addition, since DTV allows multiple programs to be broadcast on a single channel, the, existing stations 'may "sublet" broadcast capacity to other users. Thus, the possibility ofa significant expansion oftenants and tenant activities should·be considered. This is particularly important in light ofCity Planning Commission Resolution No. 11399 which found that expansion ofthe transmission building at the base ofthe Tower and the addition ofnew antennas would, require a new conditional use pem;Ut and be "detrimental to the health, safety, convenience or general welfare" ofnearby residenis. o The OEIR states that two 'additional on-site electrical transformers would need to be added (one for each 12 kilovolt feeder line) to serve the Tower. However, it fails to describe the installation, operation and maintenance ofthese transformers. ' Hillary Gitleman .' .. September 10, 1997 Page 7 CEQA requires that that the full scope andobjectives ofthe proposed project·be adequately defined at the outset ofenvironmental review and remaincoi1sist~ntthroughout the review process. .'11A curtailed or distorted project description may stultify the objectives ofthe' reporting process.. Only through an accurate view ofthe project may affected outsiders and public decision-makers balance the proposal's benefit against its enVironmental co$t, consider , . , mitigationmeasures,~assessthe advantage ofterminating the'proposal (i.e., the 'no project" , altC?mative)and weigh other alternatives in the balance." (County ofInyo, 71 Cal.App.3d. at pp.. 192-193.) . Because the project description is' not accurate or complete in11gbtoft~ecurrent' circumstances, the OEIR is legally inadequate and. may not be certified. An adequate OEIR would fully and accurately describe the whole ofthe activities under 'consideration, not just selected aspects ofit. . . . m. ,THE DEIR'S DESCRIPTION OF THE PROJECT'S ENVIRONMENTAL 'SETTI:NG IS INCOMPLETE AND RELIES ON STALE DATA. "An EIR must include a description ofihe environment in the vicinity oftheproject, 'as it exists-before the commencement ofthe project, from both a local and a regional perspective." (CEQA Guidelines §15125~see also Environmental Planning and Infounatlon Council v. County' . ofEI Dorado (1982) 131 Cal.App.3d 350, 354.) However, the DTV DEIR's environmental ' - . setting discussion is deficient because it fails to adequately discuss existing environmental conditions, especially with regard to the structural integrity and seismic safety ofthe Tower. As a result, the OEIR is so obviously incomplete as to not meet the minimum requirements for disclosure. ,'. . . , Examples ofthe deficiencies in the DEIR'senvi~onmentalsetting description are as -follows: o The structural condition and seismic integrity ofthe rower are not described. This is a particularly glaring omission in light ofthe statements ofthe Proponent's attorney that the' Tower is a "deteriorated structure" which "after decades ofexposure and corrosion, ... is no longer at peak. structural integrity and seismic -safety" and does not"~eetcurrent s8fety standards." (Exhibit A.) The'DEIR must describe in detail the condition ofthe· Tower in terms ofits stability, seismic' safety, metal fatigue, rust, corrosion, falling, paint ,chips, and . related issues. The currently applicable safety standards, pursuant to the City'~Municipal Code, California Building code, Unifoqn Building Code(UBC)~-andElectronic Industries Association (EIA) TIA·222-F wind speed standards, ata minimum, should be set forth in Hillary Gitleman . September 10, 1997 Page 8 the DEIR.. Such regulations are briefly refeiencedin the letter fromth~Proponent's engineering firm~nExhibit A hereto, but are not addressed in the DEIR. These and any. other applicable standards must be explained, as well as whether the Tower currently· " complies with them. What earthquake magnitude can the Tower in its present condition '. withstand without damage? A description ofsuch issues is a necessary part ofthe .. . . environmental bas.eliile discussion so that the incremental Project effects ofadding'weight and windload to the Tower can be· properly assessed. o The description ofadjacent land uses fails to identify tWo nearby public schools, tWo reservoirs at the base ofthe Tower, and the greenbelt, Sutro Forest, to the north and west ofthe Tower. No surVeys for animal species ofconcern (i.e., endangered, tlu:eatened, etc) has been conducted. The City's emergency response and evacuation plans and routesfor. the area should also be described. o The existing noise levels in the vicinity ofthe Tower must be quantified during a range of wind conditions. Simply stating that "[w]ind flowing through Sutro.Tower on windy days· has been perceived as a .loud noise by some residents in the vicimty ofSutro Tower" (OEIR at p. 3-36) is not insufficient. . o The OEIR acknowledges that "[r]esidents in the vicinity ofthe Tower have complained about interference ofthe television/radio broadcasts with televisi()n and radio reception and with car theft alann systems." (OEIR at p.. 3-37.)However~.nomentionis made of. interference with other equipment, such as computers, garage door openers, cellUlar . phones and beepers. o The OEIR should reference and describe the City's Planning Commission Resolution No.. 11399 (1988) as an "adopted environmental plan[] and goal[] 'ofthe communitY." (CEQA Guidelines Appendix G, subd(~).)In Resolution 11399, the Planning Commission stated .(1 ) that there. is "substantial public' concern surrounding the issue' ofelectromagnetic' radiation" from theTower~(2) that the Planning Commission "could not, with clear conscience, make the required Code section 303 finding that ... [a proposed expansion of transmission facilities at the Tower] would 'not be detrimental to the health, safety, convenience ofgeneral welfare ofpersons residing or working in the viCinity: '" . . o ·Even though the OEIR states that the main area ofcontroversy involvesradiofrequ~ncy. radiation (RFR), it relies on incomplete, non-current data on the existing levels ofRFR ,levels in the vicinity of the Tower. RFR was measured at a mere ten locations in , December 1996 and there is·no indication as to whether the regular or auxiliary antennas were operating that day. The bulk ofthe data relied on in the' EIR (480 locations measured'in 1988) is 9 years old, and was, conducted with equipment that is less sensitive than that used today (i.e., a Holaday ill-3001 meter was used .rather than an ID-3004): Hillary Gitleman September 10, 1997 Page'9 (DEIR at p. 3-6.) In addition, there has been an expansion oftransm1ssions from'the. Tower since 1988, particularly with regard to cellular antennas. The EIR also refers to subsequent measurements taken'by Hammett & Edison in 1991 and 1993, but fails to provide the results. In addition, no mention is made ofany relay or transmission towers that may exist in local off-site locations. It is crucial to have extensive, accurate and . current data ofthe existing RFR levels on which to base. the analysis ofadditional RFR Because the OEIR lacks a proper description ofthe environmental setting, .it is inadequate' .as a matter oflaw. (See San Joaquin Raptor, supra, 27 CaI.App.4th at p. 729.) Fl;lrthennore, ·the inadequate description ofthe environmental setting also makes unreliable: (1) the determination ofwhether all the environmental impacts 'ofthe project have been identified and analyzed in the' OEIR~(2) all comparisons with alternativesites~and (3) a determination that all environmental impacts have been mitigated to insignificance.. (Ibid.) The OEIR's failure to acCurately and completely describe the project's environmental setting renders the document uncertifiable. IV. tHE DEIR FAll..S TO ANALYZE POTENTIALLY SIGNlFICANTADVERSE PROJECT IMPACTS. . An EIR must identify and focus on the significant environmental effects ora proposed . project. (Pub. Res. Code §§ 21100(b)(I); 21061; CEQA Guidelines '§§15126(a), 1514l.} EIRs . should be "prepared with a sufficient degree ofanalysis to provide decision-makers with information which intelligently takes account ofenvironmental consequences." '(CEQA . Guideline.s § ISIS.I.) Identification ofa project's significant environmental impacts is a central purpose ofan EIR and is necessary to implement CEQA's policy that public.agencies should not approve projects ifthere are feasible mitigation measures ofproject alternatives available to . reduce or avoid the impacts. (Pub. Res. Code §§ 21002, 21002.1(a).) In judging the legal sufficiency oran EIR, the focus is on "adequacy, cOmpleteness and a good faith effort at full disclosure." A number ofcourt decisions have developed criteria for determining what constitutes a "reasonable" effort to analyze a projects' potential impacts. Kings County Farm Bureau v, City ofHanford (1990) 221 CaI,App.3d 692 is particularly instructive on this point. That opinionemphasizes that anEIR must support with rigorous analysis arid . substantial evidence the conClusion that environmental impacts wili be insignificant. .(Ibid.) The DEIR for the DTV Project lacks such support for its conclusions. To' begin' with the DEIR's analysis ofsignificant environmental effects is fundamentally flawed because, as discussed above, the scope ofthe project analyzed is inaccurate and unduly narrow, and the baseline environmental'setting is not fully and~ccuratelyevaluated and described. In addition, the DEIR's analysis is' also inadequate in at least the followiIl:8 area,s: .' Hillary Gitleman September 10, 1997 Page 10 . . o No analysis is conducted as to whether, inlight'ofth~Tower's deteriorated condition 4ncf lack cif structuralintegrity, the DTY installation project may increase the ·risk ofconapse orfailure ofthe Tower during an earthquake, storm or other adverse climatic event. Such a discussion is necessary and should focus on a range ofpossibilities from a single acute , event.such as a major earthquake, as well as the long term chronic stresses ofmetal ' ' fatigue, rust, corrosioll; excessive weight on the'Tower; and windload. , , o The potential ofan accident or electrical problem with theTow~t() spark a fire in the , adjacent greenbelt should be evaluated and discussed. ' o The OEIR's conclusory statement that "none ofthe proposed modifications~othe Tower would be expected to change [the] exiSting noise condition" (OEIR at p. 3-36J'is unsupported by facts or analysis in the OEIR because.no measurement ofexisting noise was conducted and no evaluation ofchanges to witidflow through the Tower has been ,conducted. . . 0, The OEIR incorrectly states that "potential conflicts with the ICity's] Master Plan are considered by decision makers independently ofthe environmental review process." (OEIR at p. 3-'33.) However,'to the contrary,assessing whether a project will oon.tljct with the local general plan or other adopted plans is a fundamental part ofthe CEQA process. (See CEQA Guidelines, Appendix G, Subd. (a), (z) [project will nornially have a significant effect on the environment ifit will conflict'with adopted environmental goals of ' the community'or interfere with emergency response or evacuation plans].) In this case, the DTY Project conflicts with: a) Planning Commission Resolution No. 11399 which stated that the expansion of antennas or transmission facilities at the Tower would not meet the applicable standard that it "'not be detrimental to the health, safety, convenience or general welfare ofpersons residing or working in the vicinity"'; and b) The newly adopted Community Safety element ofthe San Francisco General Plan, which provides that the City must "[a]ssess the risks presented by ... potentially hazardous structures and reduce, the risks to the extentpo~ible.", (Policy 2.5.) In addition, the same General Plan element requires the City to "[a]ssure that new construction meets current structural and life safety standards." (Policy 2.1.) The policies are designed to further the objective of "reduc[ing] structural and non-structural hazards to life safety, minimize 'prop,erty damage and resulting'social, cultural and econoInic dislocations resulting from future disasters." (Objective 2.) In that the DEIR fails to analyze seismic and structural issues in any detail, it IS impossible to even determine the consistency ofthe Project with these'and other policies and Hillary Gitleman September 10, 1997 Page.ll objectives ofthe General Plan's.CommunitySaf~tyelement. o The DEIR's analysis ofROR is also flawed in several ways. For one thing, no analysis is made ofthe consequences ofoperating main and auxiliary DTSC and DTV antennas, or any combination ofthem, simultaneously. Some ofthe auxiliary antennas generate more RF energy than the mair:t antennas and are closer to sensi.tive~eceptors.. o The DEIR. states that approximately SOO,!o more energy may be 'necessary to operate the DTV antennas along with the existing transmitters (1,OOO-I,SOO KVA in addition to 3,040 KVA currently used). (DEIR at p. 3,;,39.) As discussed above, two transformers will be added. The DEIR also states that people near a power line~ein its "induction" zone (i.e., within a fraction ofa wavelength from the source) and thatcontrov~rsysurrounds reports ofthe adverse effects on humans from exposure to the electric and n:tagnetic fields '. present in homes from power lines and appliances. (OEIR at p. 3-4.) However, the DEIR fails to analyze the adverse impacts, related to EMF among other things, ofincreasing the -_ power use at the site by SO% and two new transformers with homes only 2S0 feet away. ' o The DEIR's conclusion that the existing interference with car alarms causedby AM and FM signals is not expected to change.fails to address interference with otper electronic equipment which is caused by the transmission oftelevision,. radio and other data services . from the Tower. v. THE DEIR FAn.s TO ANALYZE SIGNIFICANT AND ADVERSE CUMULATIVE IMPACTS FROM THE PROJECT. An EIR must analyze and discuss significant cumulative impacts ofthe project. (CEQA Guidelines'§ 15130; see also Pub. Res. Code § 21083(b).) Cumulative impacts are "two or more individual effects which, when viewed together, are considerable or which compound or inc.rease other environmental impacts." (CEQA Guidelines § 15355.) The individualeffects~ybe, changes resulting from a single project or a number ofseparate projects. (CEQA Guidelines § 15355(a).) The cumulative impacts analysis is vital in preventing impacts which are individually minor but cumulatively considerable from overwhelming the enviromnent. An EIR's ciimulat.ive impacts analysis must address"th~change in the environment which results from the incremental impact ofthe project when added to other closely related past, present, and reasonably foreseeable probable future projects," (CEQA Guidelines § 15355..) The cumulative impacts analysis must .include reasonably anticipated future activities ofa project or associated with a project. (Discussion following CEQAGuidelines § 15130.) .' As mentioned above, even ifthe structural and seismic upgrades could be considered a separate project, they would nevertheless need to be discussed andconsidered inJhis EIR as a closely related past, present, orrea~oilablyforeseeable probable future project. - Hillary Gitleman · September 10, 1997 ·Page 12 . In addition, the DEIR must assess whether individqal impacts from this project which are not found to be significant alone may become significant when viewed in conjunction with other · existing impacts: (See Kings County Farm Bureau v. City ofHanford (1990) 221 Cal.App.3d 692, 718-21, [holding that an EIR must find cumulative Impacts are significant whentliey inake a · small contribution to an existing unacceptable environmental condition].) Thus; a.proper an8lysis would require that the OEIR start by quantifying and evaluatingth~.existingsiiuation in the·· vicinity ofthe Tower with· respect to seismic, strueturaJ and windload issues, lioise, visu8.I impacts, interference and other concerns. Then the analysis must address whether the Project will ... add to any ofthese adverse situations even incrementally. Ifso, theOEIR~ustdeem the Project· to have a significant cumulative environmental impact. A:nd, ofcourse, ifthe Project's contribution to an impactare~changes an acceptable situation into an unacceptableon~then a significant cumulative impact must also be acknowledged. The OEIR does not contain any analysis ofcumulative impacts.· Thus, the OEIR must be . revised to add such an analysis regarding issues such as, without limitation, the following: o The OEIR must assess the currentst~cturaland ·seismic stability ofthe Tower under ·existing and projected weight and windload conditions. Ifthe integrity oftheTowe~is insufficient~ow,then any addition ofweight-and windload fromthe OTVantennawill exacerbate this preexisting unacceptable situation and must be considered cumulatively .significant. . o The OEIR must likewise assess the current noise levels in the viciriity ofthe Tower caused by wind through the Tower during a range ofconditions. Ifthese noise levels are significant, then any measurable addition to these levels must be also considered . significant. o The OEIR states that the simplicity and design features ofthe Tower are currently "visually compromised by the. busy feel ofthe unclad orange trusses, which form ·the antenna's platform,. and the number ofcables sup'porting thet~eeantennas." (OEIR at p. 3-27:) It also states that the proposed new set ofantennas would be noticeable~'upon. relatively close inspection, when in proximity to the Tower." (DEIR at .p. 3-28.) ·In that the Tower's- appearance is visually compromised now, the addition ofnew antennas.will only increase the "busy feel" ofthe Tower, as viewed by the neighboring residents who live in close proximity. The visual impact must be considered cumulatively considerable. o .There is atso an existing unacceptable environmental situation regarding ttie Tower's . interference with electronic equipment. As discussed above, this interference occurs not only with TV, radio and car alarms, but also with computer and other equipment. To the extent that the proposed DTV transmission would increase the risk ofsuch 4tterference in· any way, this too must be considered a cumulative impact ofthe Project. Hillary Gitleri1an September 10, 1997 Page 13 . '... . VI. THE DEIR IMPROPERLY CONCLUDES THAT NO MITIGATION MEASURES ARE REQUIRED. In addition to assessing the significant impacts ofa project, EIRs must also set forth and· describe mitigation measures to eliminate or minimize those effects. (Pub: Res. Code§' 21002. 1(a); 21100(b)(3); CEQA Guidelines § 15126(c).) Mitigation measures must be designed to minimize, reduce; rectify or compensate for the project's sigilificant iQlpacts. (CEQA Guidelines § 15370.) Indeed, this is one ofthe main functions ofan EIR. '(Pub.Re~.Code § 21002.1(a).) , In this case, the DEIR's conclus.ion that no mitigation measures are required is . fundamentally flawed because, as explained above, (1) there are indeed significant adverse impacts from this Project; and (2) the DEIR lacks adequate analysis to detemiine whether'there are other significant adverse environmental effects. The DEIR must be revised to properly analyze significant impacts and to then set forth and describe feasible mitigation measUres for tpese . impacts. YD. THE DEIR'S ANALYSIS OF ALTERNATIVES VIOLATES CEQA BECAUSEIr 'FAILS TO ANALYZE ANY. ALTERNATIVES WHICH COULD OBTAIN THE OBJECTIVES OF THE PROJECT, AS THOSE OBJECTIVES ARE ' CURRENTLY DEFINED,DESP~THE EXISTENCE OF A FEASmLE, , ENVIRONMENTALLY SUPERIOR ALTERNATIVE FOR DTV BROADCASTS. CEQA requires that an EIR describe "a range ofreasonable' alternatives to the project ... which could feasibly attain most ofthe basic objectives ofthe project butwould. avoid or· substantially lessen any ofthe significant effects ofthe project", and evaluate the comparative merits ofthe alternatives. (CEQA Guidelines § 15126(d).) As discussed above, the DEIR's project objectives are too narrow because the fundamental objective is currently defined to require locating the DTV antennas at Sutro, Tower. (DEIR at pp. 2-1, 6-3, 6-7.) As a result, it is impossible for any alternative site to meet the Project's fundamental objective.. Such "outcome-forcing" manipulation ofobje~ivesin order to disfavor all alternatives to the proposed project is not tolerated by the courts. (Se.e, e.g., Carmel By-The-Sea, supra, 95 F.3d at 905; Kings County, supra, 221 Cal.App)d 735-37;; Save the Niobara, supra, 483 F.Supp. at 862.) A project applicant's privately held goals cannot control an agency's decision on the reasonable range ofalternatives; reasonable alternatives must be . considered "even ifthey substantially impede the project or are more costly." (San Bernardino Audubon, supra, 155 Cal.App.3d at 750.) Thus, the Project's fundamental objectives must be broadened to a more reasonable scope, such as "To comply with the FCC's DTV mandate" or "To serve all ofSan Francisco with DTY" Hillary Gitleman September 10, 1997 . Page "14 Iflogical and feasible.a1ternative sites exist, ignoring them violates CEQA's mandate that projects not be approved ifalternatives may lessen or avoid impacts. (See Citizens Of Goleta Valley v. Board ofSupervisors (1988) 187 Cal.App.3d 1167, 1179-80 ("Goleta f'); SAn .. Bernardino Valley Audubon Soc'y v.County ofSan Bernardino (1984) 155 Cal.App.3d 738,750; see also Laurel Heights Improvement Association v.RegentsofCalifomia (1988) 47 Cal."3d 376, 403-04.) . The San Bruno Mountain'site is afeasible alternative location. (CEQA Guidelines § . 15126(d)(5)(B)(2).) As the DEIR itself states, "DTV signals from San Bruno Mountain would be able to serVe aU ofSan Francisco." (OEIR·at p. 6-5.)· The OEIR, however, obfuscates this fact by making several inaccurate statements about the San Bruno Mountain site. (See comments submitted by Watson CommuniCations Systems, Inc.) AS a result, this site cannot ber~jected simply because itdoes not meet the overly narrow objective oflocating DTY at Sut£O Tower. Moreover, the San Bruno Mountain alternative is environmentally superior. (CEQA . Guidelines § 15126(d)(5)(8)(1).) Because it is in a designated open space area, locating DTY antennas at San Bruno Mountain would not have the significant impacts including seismic, structural, noise, visual, RFR, interference and other adverse.effects which result from the Tower's close proximity to residential land uses and other sensitive receptors. It is not accept·able to simply state, as the DEIR does, that "[I]fan off-site alternative was constructed and· implemented, impacts identified for the proposed project at Sutro Tower would; instead Qccur at the alternative site location." (OEIR at p. 6-5.) This unsupported statement is ludicrous because the nature and severity environmental impactsar~largely dependent on the setting in which a . project is implemented. As a result, once the Project's objectives are appropriately broadened to allow for consideration ofalternative sites, the DEIR must evaluate and compare the San Bruno . Mountain alternative, relative to its oWn environmental context, in a meaningful way. (CEQA Guidelines § 15126(d)(3).) vm. THE DEIR MUST BE SUBSTANTIALLY REVISED AND RECIRCULATED FOR ADDITIONAL PUBLIC COMMENT. Where a lead agency adds significant new information to an EIR after public review and prior to final certification, CEQA requires that the agency issue a new notice and recirculate the EIR to the public and public agencies for additional comment and consultation. (Pub. Res. Code . § 21092.) The revised~nvironmentaldocument must be subjected to the same critical evaluation that occurs in the draft stage. (Sutter Sensible Planning, Inc. v. Board ofSupervisors (1981) 122 Cal.App.3d 813,822.) Inlight ofthe foregoing discussion; there is substantial new information concerning the . project, its environmental setting, impacts, mitigation measures and alternatives which must be Hillary Gitleman . September 10, 1997 Page 15 added to'the DEIR. in· order to make'it adequate under CEQA. Once this information is added, the revised DEIR. must be" recirculated to, the public and public agencies so that they are not :denied~'an,opportunity to test, assess, and evaluate the data and make an informed judgment as to th~Validity ofthe conclusions to be drawn therefrom." (Sutter Sensible Planning, 122', ' Cal.App.3d"a~p. 822.) , In' addition,r~cuJation'is also necessary because, dunng the~nimentperiodf~r:this DEIR. certain files for the Sutto Tower site which were requested by my clients were apparently· missing from the City's file "storage and,were therefore unavailable. (See~xhibitB, 7/29/97 letter from Planning Department.) The public must have access to background matenals so·that they can fully comment on the DEIR during the public comment period. . . '. - , CONCLUSION ' The DEIR is uniDforrnative, inadequate andunc~rtifiablein its present form: Consequently, Twin Peaks Improvement Association and the MidtoWnTerra~eHomeowners' , A!spciation respeCtfully request that the City respond to their comments, "substantially revise tlJe· Sutro Tower DTV DEIR. accordingly, and recirculate the resulting,DEIR. for additional ,public . comment, as required by CEQA. In addition, please include this comment letter and its , attachments in the administrative record for the Project. Thank you for considering~Yclients' concerns. Yk Reed W. Super Encls: Exhibit-A Exhibit B SFBG News http://www.stbg.comlnews/32/05/features/sutro.html , .' N October 29, 1997 Tower trick Residents say Sutro Tower's owners are covering up seismic safety questions. By Savannah Blackwell WHEN SAN Francisco's Planning Department sent out a notice in June that Sutro Tower's owners were planning to make the giant television and radio structure more safe in case of an earthquake, neighboring residents were relieved. They thought the consortium owning the tower was finally addressing their long-standing fear that the looming, 977-foot structure needed stabilization. So they didn't bother to turn out for a June 19 public hearing. They wish they had known then what they know now. The seismic upgrade, it turns out, wasn't just a safety plan. It appears to be part of a much larger program to add new high-tech digital-TV antennae to the tower. And those new antennae could make the tower unstable. Sutro Tower Inc. -- a consortium of local broadcasters including KRON, KPIX, KGO, and KTVU -- has been planning for some time to add the new antennae, and the neighbors have been fighting the plans (see "Tower of Power," 11/6/96). But last spring lobbyists for the tower consortium changed their tack. They appeared to have dropped the heavy new antennae from the immediate agenda, and they put forward a plan for "voluntarily" upgrading the tower's stability. Ifnew antennae were ever added, the lobbyists argued, they would be much lighter and nothing to worry about. In fact, the notice about the hearing on the seismic upgrade stated that any decision on adding new antennae to the tower would be a separate issue, to be decided at a later date. Neighbors say they were duped. "We believe now [the hearing] was part of a two-part project," Twin Peaks SFBG News http://www.sfbg.comlnews/32/05/features/sutro.html Improvement Association (TPIA) member Christine Linnenbach told the Bay Guardian. "Had we known that the plans submitted for this alleged seismic upgrade were directly related to Sutro Tower's expansion into digital television, we would have been out there in full force." There's no doubt that the sort of equipment Sutro officials were initially discussing -- a 25,OOO-pound, 125-foot-Iong digital transmission pole with antennae attached -- would require structural improvements on the tower. According to a 1995 analysis by Kline Towers of Columbia, S.c., ifthe legs of the tower weren't strengthened, the additional digital television equipment would cause "leg failure." But Sutro lobbyists say that stabilizing the tower isn't necessary. "As it turned out, the advanced television antennae are much lighter than originally forecast," Sutro Tower lobbyist Robert McCarthy told the Bay Guardian. "We decided it was the wiser course to voluntarily seismically upgrade the tower ..., which I thought would have been pleasing to the neighbors." But there's more to the story: voluntarily stabilizing the tower would be noncontroversial and wouldn't require the same level of environmental review as would hanging heavy digital-television equipment on the tower. By making the stabilization appear to be a separate project, Sutro officials were able to win City Hall's approval this summer. And the fact is, the Bay Guardian has learned, the heavy antennae are still part of the project. In an Oct. 27 interview Deborah Stein, one of McCarthy's partners, said the lighter antennae McCarthy mentioned are not what Sutro Tower has in mind. She said Sutro is still planning to hang the heavy pole -- because it will be more durable. The neighbors, who are furious, feel the Sutro lobbyists tricked them. "What they're doing is basically making an end run around City Hall," Linnenbach told the Bay Guardian. The blackout The handling ofthe hearing, and what residents see as Sutro's attempts to avoid a complete environmental review, points to an alarming trend in the planning SFBG News http://www.stbg.comlnews/32/0S/features/sutro.htn process, Sutro's critics say. Well-heeled lobbyists are increasingly able to manipulate the system for the benefit of their corporate clients. Through their lobbying firm, GCA Strategies, Stein and McCarthy have spent $56,272 since the beginning of 1996 to influence legislation related to the Sutro Tower permits. Sutro's critics also say the mainstream press has effectively blacked out the issue. Linnenbach said her group has repeatedly asked the San Francisco Chronicle and the San Francisco Examiner to write stories about Sutro's latest plans. To date, the Chronicle has not written anything and the Examiner has run only one short piece. The residents suspect a conflict of interest: the Chronicle ownsKRON, a part owner of Sutro Tower, and the Examiner is the Chron's partner in a joint operating agreement. In September, KGO's Dr. Dean Edell even urged listeners to support Sutro's digital project. (The mainstream news blackout of Sutro Tower is nothing new. On Sept. 27, 1971, the Bay Guardian ran an article with the headline "It's Taller than Transamerica, as Tall as the Eiffel Tower, Almost as Tall as the Empire State Building, but You'll Never See It on KRON, KPIX, KGO, or KTVU." The story blamed local broadcasters' and dailies' blackout of Sutro's plans to construct the tower as part of the reason the original tower project was approved.) Fair hearing? The notice ofthe hearing posed a problem for residents seeking to assert their rights, Linnenbach told the Bay Guardian. "Notice needs to be factually accurate and fair such that San Franciscans have a reasonable opportunity to be heard," Linnenbach said. "The June hearing notice does not meet these requirements, because the city's notice clearly stated that the seismic project is completely unrelated to Sutro's digital television project." Department of Planning zoning administrator Robert Passmore said that Sutro does not yet have approval to proceed with the digital project. Residents say Passmore has told them that if they can prove that digital and the SFBGNews http://www.stbg.comlnewsI32f05/features/sutro.htr current analog technology are significantly different, Sutro Tower could face a hearing on the appropriateness of having the tower in a residential area in the first place. Indeed, residents marked a victory when the Planning Commission decided in July to extend the public comment period ofthe environmental impact report for the digital project from Aug. 11 to Sept. 11. Planner Paul Maltzer, who is handling the Sutro matter, told the Bay Guardian that if planning officials decide that substantial new evidence and information has been put forward, they may choose to restart the EIR process. Shaky ground Residents say that Sutro Tower Inc. should perform a thorough analysis of whether the tower with the added weight of the heavy digital-transmission pole would withstand an earthquake. In a Sept. 10 letter to the Planning Department, Lloyd Cluff, who lives near Sutro Tower and who is past chair ofthe California Seismic Safety Commission, urged planners to require Sutro Tower Inc. to conduct a "dynamic analysis" of what would happen to the upgraded tower in the event of an earthquake. The 1995 Kline Towers analysis relied on 1991 Uniform Building Codes, which did not take into account effects of the 1989 Loma Prieta earthquake, the 1994 L.A. earthquake, and a 1995 earthquake in Kobe, Japan, in which many steel-frame structures similar to Sutro Tower collapsed or were severely damaged. "The failure of modem steel-frame structures during the Northridge [L.A.] and Kobe earthquakes sent a shock wave through the steel industry," Cluff wrote. Stein told the Bay Guardian that testing or studies other than the radiation and fall zone testing already planned as part of the seismic stabilization would be unnecessary. "Sutro Tower is one of the most seismically stable structures in the city," she told the Bay Guardian. "Structural stability is a technical science -- not one that should be affected by public opinion." But in September 1992, Sutro Tower's vice president and general manager, Eugene Zastrow, admitted that attention had not been paid to the problem of corrosion at the tower for 20 years. "Continued neglect would lead to SFBG News http://www.sfbg.comlnewsl32/05/features/sutro.htr even more serious problems in the future," he wrote in a Sept. 24, 1992, letter to neighbors. California seismic safety commissioner Craig D. Comartin wrote in a May 1997 report that in the Kobe earthquake, most steel structures set in concrete and built before 1971 (as is Sutro Tower) collapsed. Concerns about the tower's stability have compounded residents' long-standing worries that radiation from the tower is impairing their health. Ramona Albright, of the Committee to Investigate Electromagnetic Radiation, told the Bay Guardian she believed that the additional digital equipment would add significantly to the amount of radiation emitted by the tower. "Research indicates that in animal studies, rats avoid digital fields," Albright said. "We have an unusually high cancer rate in San Francisco. We also have [that] telecommunications tower. " Return to top I Home - - - .... ..... - - ..... .... ? ? ? ? ? ?? City and County of San Francisco Planning Department SUTROTOWER DIGITAL TELEVISION (DTV) DRAFT ENVIRONMENTAL IMPACT REPORT 96.544E July 9,1997 Draft EIR Publication Date: July 9, 1997 Draft EIR Public Hearing Date: JUly 24, 1997 Draft EIR Public Comment Period: July 9 to August 11, 1997 Written Comments should be sent to: Hillary E. Gitelrnan The Environmental Review Officer Planning Department 1660 Mission Street. 5 th floor San Francisco. California 94103-2414 - ..... ..... - "- - I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I , liltillllllll Place Postage Here Planning Department Office ofEnvironmental Review 1660 Mission Street San Francisco, California 94103-2414 Attention: Paul Maltzer, EIR Coordinator 96. 544E: Sutro Tower DTV EIR Please cut along dotted line, and fill in blanks on the opposite side ofthis page. - ..... ..... ..... ..... "- ? Return Request Required for Final Environmental Impact Report Signed: Please Print Your Name and Address Below Please send me a copy ofthe Final EIR. TO: Planning Department Office ofEnvironrnental Review REQUEST FOR FINAL ENVIRONONMENTAL IMPACT REPORT I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I ._--------------------------------------------~ ? ? ? ? ? ?? City and County of San Francisco Planning Department SUTROTOWER DIGITAL TELEVISION (DTV) DRAFT ENVIRONMENTAL IMPACT REPORT 96.544E July 9,1997 Draft EIR Publication Date: JUly 9, 1997 Draft EIR Public Hearing Date: JUly 24, 1997 Draft EIR Public Comment Period: JUly 9 to August 11. 1997 Written Comments should be sent to: Hillary E. Gitelman The Environmental Review Officer Planning Department 1660 Mission Street, 5 th floor San Francisco, California 94103-2414 TABLE OF CONTENTS Section Page 1.0 SUMMARY 1-1 2.0 PROJECT DESCRIPTION 2-1 2.1 PROJECT SPONSOR OBJECTIVES 2-1 2.2 PROJECT LOCATION 2-3 2.3 PROJECT CHARACTERISTICS 2-3 2.4 PROJECT SCHEDULE, COST, AND APPROVAL 2-10 REQUIREMENTS 2.4.1 SCHEDULE AND COSTS 2-10 2.4.2 APPROVALS 2-10 2.4.3 GENERAL PLAN 2-11 3.0 ENVIRONMENTAL SETTING AND IMPACTS 3-1 3.1 PUBLIC HEALTH EFFECTS 3-1 3.1.1 BACKGROUND INFORMATION 3-1 3.1.2 APPROACH AND METHODOLOGY 3-5 3.1.3 ENVIRONMENAL SETTING 3-7 3.1.4 PUBLIC HEALTH EFFECTS 3-13 3.2 VISUAL QUALITY 3-26 3.2.1 ENVIRONMENAL SETTING 3-26 3.2.2 VISUAL QUALITY EFFECTS 3-27 3.3 COMPATffiILITY WITH EXISTING ZONING AND PLANS 3-33 3.4 LAND USE 3-34 3.5 POPULATION 3-34 3.6 TRANSPORTATION AND CIRCULATION 3-35 3.7 NOISE 3-35 3.8 AIR QUALITY/CLIMATE 3-36 3.9 PUBLIC SERVICES AND UTILITIES 3-37 3.10 BIOLOGICAL RESOURCES 3-37 3.11 GEOLOGY AND SOILS 3-38 3.12 WATER 3-38 3.13 ENERGY / NATURAL RESOURCES 3-39 SUlJO \ sut-des.doc 11 07/07/97 TABLE OF CONTENTS (Continued) Section Page 3.14 CULTURAL RESOURCES 3-39 3.15 GROWTH INDUCING EFFECTS 3-39 3.16 HAZARDOUS MATERIALS 3-40 4.0 MITIGATION MEASURES 4-1 5.0 SIGNIFICANT ENVIRONMENTAL EFFECTS THAT CANNOT BE 5-1 AVOIDED IF THE PROPOSED PROJECT IS IMPLEMENTED 6.0 ALTERNATIVES 6-1 6.1 INTRODUCTION 6.2 NO PROJECT ALTERNATIVE 6.3 OFF-SITE ALTERNATIVES 6-1 6-1 6-3 7.0 DRAFT EIR DISTRIBUTION LIST 7-1 8.0 APPENDICES 8-1 APPENDIX A: RADIOFREQUENCY LEVELS 8-2 APPENDIX B: BIOLOGICAL EFFECTS OF RADIOFREQUENCY B-1 RADIATION APPENDIX C: EIR REQUIREMENT C-l 9.0 GLOSSARY 9-1 9.1 DEFINITIONS 9-1 9.2 ACRONYMS 9-5 10.0 EIR AUTHORS AND CONSULTANTS; ORGANlZATIONS AND 10-1 PERSONS CONSULTED 10.1 EIR AUTHORS 10-1 10.2 PERSONS CONSULTED 10-1 Sutro EIR \ TOC 111 01/01191 TABLE OF CONTENTS (Continued) Section LIST OF TABLES TABLE 1: EXISTING AND PROPOSED SUTRO TOWER BROADCAST 2-7 STATIONS TABLE 2: COMPARISON OF EXISTING RADIOFREQUENCY POWER 3-9 DENSITY WITH EXISTING CALCULATED VALUES TABLE 3: COMPARISON OF EXISTING MEASURED RADIOFREQUENCY 3-15 POWER DENSITY WITH FUTURE CALCULATED VALUES LIST OF FIGURES FIGURE 1 FIGURE 2 FIGURE 3 FIGURE 4 FIGURE 5 FIGURE 6 FIGURE 7 FIGURE 8 FIGURE 9 Sutro EIR \ TOC SITE LOCATION SITE PLAN SUTROTOWERBROADCASTANTENNAS DTV ANTENNA FRONT VlEW LOCATIONS OF RFR MEASUREMENTS CLOSE-UP VlEW OF SUTRO TOWER, EXISTING CLOSE-UP PHOTOMONTAGE OF SUTRO TOWER, WITH ANTENNAS VIEW OF SUTRO TOWER FROM MARKET STREET AND DIAMOND STREET, EXISTING PHOTOMONTAGE OF SUTRO TOWER FROM MARKET STREET AND DIAMOND STREET, WITH ANTENNAS 2-4 2-5 2-6 2-9 3-8 3-29 3-30 3-31 3-32 01107197 tn m o -t (5 Z 1.0 SUMMARY INTRODUCTION Sutro Tower is an existing 977-foot tall steel structure/tower which includes antennas for ten television stations and four FM radio stations. Visible from most areas of San Francisco, the Tower is located on an approximately 4-acre parcel on the east peak ofMount Sutro in central San Francisco. This Draft EIR examines the potential environmental effects of a proposed project to install Digital Television (DTV) antennas onto Sutro Tower. A new DTV antenna system able to accommodate the 10 television stations that broadcast from Sutro Tower would be attached to a new 125 foot long beam., which would extend down from a location near the top of Sutro Tower. The project is being proposed to comply with the Federal Communications Commission (FCC) mandate that all television broadcast stations in the United States implement DTV signal broadcasting. The current FCC deadline for beginning DTV signal broadcasts in the Bay Area is October, 1998. FCC rules also specify that unless otherwise exempted, DTV broadcasts must be from a location no greater than five kilometers from the site of the existing National Television Systems Committee (NTSC) broadcasts (Sutro Tower), and that the antennas should generally be at the most central point, at the highest elevation available. If the proposed project is approved there would be an overlap period tentatively set for 9 years during which both DTV and the existing NTSC television signals would be broadcast from Sutro Tower. Thereafter, the NTSC signal would be terminated and only DTV signals would be transmitted. The main area of controversy surrounding the proposed project involves the potential for adverse health effects from radiofrequency radiation (RFR). Sutro Tower presently emits RFR from NTSC television signal broadcasts. During the period of overlap, when both DTV and NTSC signals would be broadcast, RFR would increase above existing levels. After the NTSC signal broadcasts are terminated, RFR would drop below existing levels. [NOTE: A glossary ofdefinitions and acronyms used in this EIR is included as Section 9.0, below.] Swro \ summary 1-1 01106197 1.0 Summary The proposed project would emit electromagnetic waves in the frequency range of 500 - 734 megahertz. These wavelengths are millions of times shorter than those generated by electric power lines. Accordingly, the interactions with biological bodies differ between exposure to RFR and exposure to electric and magnetic fields generated by power line frequencies. A Technical Report on the Biological Effects ofRadiofrequency Radiation and Possible Health Effects of RFR on Humans from Sutro Tower DTV Broadcasts has been prepared and is included as Appendix B to the EIR. This technical report was authored by two experts in the field of RFR and additional contributions were made by another expert. The report was peer reviewed by the San Francisco Department ofPublic Health (DPH) and an independent expert working as a consultant to DPH. The general conclusions of this technical report have been summarized in the main body ofthe EIR. The technical report presents information on a representative sampling of the large number of studies that have been conducted on the potential biological effects of RFR. Included in the report are analyses ofa variety of potential adverse effects, based on studies of humans, other animals, and animal cells and tissues. Some past researchers have published reports concluding that there is the potential for adverse health effects from RFR. In reviewing these past studies, the technical report for this EIR concludes that either 1) the adverse effects identified were the result of a thermal effect (a hazardous increase in body or cell temperature) which resulted from RFR levels greater than those that would be generated by the proposed project; or 2) taken collectively, there is little or no reliable scientific evidence to indicate that the proposed project would have adverse health effects, and the substantial weight of reliable scientific evidence indicates that there would not be any adverse effects from RFR levels at or below those permitted in the FCC 96 Guidelines. The proposed project, during the period of overlapping signal transmission, would emit RFR up to a maximum of about 14 percent ofthe levels permitted by the FCC 96 Guidelines. While concluding that the results of many investigations provides confidence that exposure to RFR at or below the levels prescribed in the FCC 96 Guidelines is unlikely to be harmful, the technical report acknowledges that some ofthe mechanisms ofinteraction ofRFR with various biological entities are not fully understood, and life processes are complex. Even though the report cautions that it is not scientifically possible to guarantee absolutely that exposure to RFR at relatively low levels will not result in the appearance ofharmful effects for many in the Sutro \ summary 1-2 07/06/97 1.0 Sumrnarv future, the substantial weight of reliable scientific evidence indicates that there would not be any adverse health effects from the proposed project. The remainder ofthis Summary section provides a synopsis ofthe information contained in the main body ofthe EIR. 1.1 PROJECT DESCRIPTION Sutro Tower is an existing 977-foot tall steel structure/tower which includes antennas for ten television stations and four FM radio stations. The television stations currently broadcast National Television Systems Committee (NTSC) signals. The project would install a new antenna system able to accommodate a second set of broadcasts from the ten existing television stations on Sutro Tower. A new 125-foot long beam about 3 feet wide by 3 feet deep would be added to the tower at Level 6, about 755 feet above ground level, and extend down from that point (see Figure 4, page 2-9). The ten antennas would be attached to this one new beam. The beam would be brought to the site by truck., already manufactured, in three sections. Each ofthe three sections would be hoisted up the tower and installed in place. No power impact tools are anticipated to be necessary for the installation process. The second set of antennas would broadcast Digital Television (DTV) signals, as required by the Federal Communications Commission (FCC), from Sutro Tower in addition to the NTSC signals until such time as the FCC required termination of the NTSC signals (currently set at May 2006). Rather than the analog signals currently used by the broadcast industry, DTV codes the signal information into a digital system, similar to that used in a computer. The DTV system can carry the same type of programming as seen on TV today, and could also carry additional data services. DTV would also allow stations to send multiple programs simultaneously on a single channel. This would mean that additional signals from 500 to 734 megahertz (MHz) radiofrequency (RF) range would be broadcast from Sutro Tower during the period of overlapping DTV and NTSC broadcasts. After termination of NTSC signals, the DTV signals would replace the existing NTSC signals and the RFR emitted from Sutro Tower would drop below existing levels. Sutro \ sut-des.doc 1-3 07106197 1.0 Summary In addition to the regular radiofrequency emissions from Sutro Tower, most of the stations have "stand-by" auxiliary antennas on the tower. These auxiliary antennas can be used to broadcast TV signals if the regular antennas are unable to operate. Currently these antennas are used on an infrequent basis when work needs to be done on the main antennas. They would continue to be used in this fashion during the period of overlapping DTV and NTSC broadcasts. The auxiliary antennas are mounted at the first rung of Sutro Tower (also referred to as Level 2, see Figure 3, page 2-5) and generally emit less power than the main antennas, although three auxiliary antennas emit more power. No demolition would occur on site. 1.2 MAIN ENVIRONMENTAL EFFECTS Public Health Effects Sutro Tower emits radiofrequency radiation, and concern exists about health effects from exposure to various forms of radiation. Conclusions presented herein regarding health effects of radiofrequency radiation are based upon a Technical Report (included in Appendix B) by experts who reviewed the published studies and literature to ascertain potential health effects on humans and other animals. This report was peer reviewed by both the San Francisco Department ofPublic Health and an independent expert retained by the Health Department. The 1992 ANSI/IEEE Guidelines first established a threshold level ofRFR exposure at which it was generally agreed that adverse health effects, including thermal effects, could occur. A safety factor of 50 times (i.e., divide the lowest established level known to cause an adverse effect by 50) was established for uncontrolled environments (public exposure). These guidelines were subsequently adopted into the FCC 96 Guidelines. The Technical Report, the Department of Public Health, and an independent expert all agree that the substantial weight of reliable scientific evidence indicates that human exposure at or below levels of RFR prescribed by the FCC 96 Guidelines would not be harmful to human health. While substantial weight ofscientific research has indicted that no adverse health effects would result at low power levels (i.e., less that the FCC 96 Guidelines), some findings have been contrary. '''''''''''''''''''"-'''\ SUllo \ sut-des.doc 1-4 07/06197 1.0 Summary The Appendix B Technical Report includes an in-depth analysis of a variety of potential adverse effects, based on studies ofhumans, other animals, and animal cells and tissues. More specifically, the technical report examined studies on eye damage in animals; auditory effects in animals; mutagenesis, cytogenetic effects and carcinogenesis; teratogenesis; nervous system; immunology and hematology; physiology and biochemistry; behavior and learning; RFR and drugs; and cellular and subcellular effects. The technical report concluded that in spite ofthe findings ofparticular studies to the contrary, the substantial weight of reliable scientific evidence indicates that there would not be any adverse health effect from the maximum RFR levels that would result from the proposed project. In reviewing these past studies, the technical report for this EIR concludes that either 1) the adverse effects identified were the result of a thermal effect (a hazardous increase in body or cell temperature) which resulted from RFR levels greater than those that would be generated by the proposed project; or 2) taken collectively, there is little or no reliable scientific evidence to indicate that the proposed project would have adverse health effects, and the substantial weight of reliable scientific evidence indicates that there would not be any adverse effects from RFR levels at or below those permitted in the FCC 96 Guidelines. The closest residence is about 250 feet away from the base of the tower, and over 800 feet from the closest antenna. The closest public roadway is about 150 feet from the tower. The highest measured and calculated levels ofexisting public exposure to RFR from Sutro Tower, at a sensitive receptor (residence) is at Farview Court, approximately one block from the tower. The calculated level of 0.025 milliwatts per square centimeter (mW/cm 2 ) is at about 12.7 percent of the FCC 96 Guidelines. Other sensitive receptors live about one block or more from the tower. The average existing radiofrequency level at a distance of 1 kilometer (about ten blocks) of Sutro Tower is 0.0034 mW/cm 2 , which is about 1.7 percent of the FCC 96 Guidelines for public exposure. With the addition of DTV antennas, the maximum exposures from broadcast emissions from the proposed project at the closest sensitive receptor would be at about 0.029 mW/cm 2 or 14.3 percent of the allowable maximum of the FCC 96 Guidelines. These levels in turn drop off rapidly with increased distance from Sutro Tower. Once the NTSC signals are no longer broadcast, then the power densities would drop below existing power levels. Experimental SUll"O \ sut-des.doc 1-5 07106197 1.0 Summary data indicate that relatively low-level RFR exposure is not cumulative. At the levels due to project implementation, adverse health effects are not anticipated. RFR would not be expected to impact a person from the general population wearing a pacemaker due to distance from the source and the types ofRFR broadcast. Regarding types of RFR emitted, public exposure would be at a fraction of the federal safety standard and would not lead to heat-related (thermal) RFR effects. Worker Safety Effects The proposed DTV antennas present the same potential health and safety impacts that currently exist at Sutro Tower. No differences in hazards associated with radio or NTSC television broadcasts would occur with project implementation, although more workers could be exposed to hazards and/or existing workers could be exposed to hazards with greater frequency, ifany additional maintenance was required related to the new antennas. Visual Quality Effects The project would provide an additional antenna system between about 630 and 755 feet above the base of the tower. These new DTV antennas would be located between the north and south legs on the east face of the Sutro Tower structure itself, and would not protrude from the tower on any facade. While the existing tower may be considered by some to be visually intrusive, the proposed antennas would not be generally noticeable in the context of the tower's details such as cross-bracing, cable ties, trusses, and existing antennas. 1.3 MITIGATION MEASURES Although no mitigation measures would be necessary because no potentially significant effects have been identified, some actions are required by law which would serve to reduce impacts. These include: complying with the FCC 96 Guidelines, Federal Communications Commission (FCC) and CaVOSHA limits for personnel exposure to RFR, and CAL/OSHA worker safety regulations. Sutro \ sut-des.doc 1-6 07106197 1.0 Summarv 1.4 ALTERNATIVES No Project Alternative This alternative would entail no immediate change to the site or to Sutro Tower. If the No Project Alternative was implemented, none of the impacts associated with the project would occur. Sutro Tower would continue as a visible presence in the neighborhood. It would continue to operate and to emit RFR from television broadcasts into the vicinity ofthe Tower, until such time as the FCC decides to discontinue NTSC television broadcast signals. The possibility exists that once the NTSC television broadcasts cease, Sutro Tower would be utilized for other permitted communication uses or would shut down. Effects from demolishing the tower may then result. On-site impacts would temporarily be less at Sutro Tower ifthe DTV antennas were not added to the tower. Temporary construction noise impacts would not occur on the Sutro Tower site, nor would construction impacts due to traffic and air quality. Temporary construction jobs for installing the antenna would also not occur. Visual changes to the tower would not occur with this alternative. RFR emissions would be less with this alternative and would be completely eliminated if the tower was demolished. If Sutro Tower was reutilized for other permitted communications, then RFR emissions at these different frequency ranges would be emitted from the tower. Off-Site Alternatives Due to the nature ofradiofrequency, antennas transmitting television signals need to be sited at relatively high locations. Television signals follow a virtual line-of-sight path from broadcasting antenna to television receiver. These signals do not readily bend around solid obstacles. Thus any hills or highrise building between the antennas and the receIvers (television sets) would impair and possibly block reception ofthe broadcast signals. Television antennas tend to be located at the highest natural site close to the city oflicense so that the television broadcasts can be received by television sets. The FCC requires that a Sutro \ sut-des.doc 1-7 07106197 1.0 Summary certain level ofservice be maintained in the city oflicense (FCC Rules, Section 73.685(a». No obstructions may exist in the path of the broadcast signal, and service to the city must be by direct signal. Relays or booster facilities may not be used to achieve the required level of seTVlce. In the San Francisco Bay Area, three of the highest sites are currently used for television broadcasting: Sutro Tower, San Bruno Mountain, and Mount Diablo. In addition to a relatively high natural site, towers are usually constructed from which the television signals can be broadcast. The towers help to insure that receivers (televisions) would not have reception blocked due to hills or highrise buildings. Signals broadcast from Sutro Tower, San Bruno Mountain, and Mount Diablo are not interchangeable because oftheir distance from each other and the cities oflicense. New DTV channel allotment rules specify that each station's DTV transmitting antenna location must be within 5 kilometers ofthe existing NTSC transmitter sites (FCC Rules, Rules, Section 73.622(d)(1), 47 C.F.R. Section 73.622). Exemptions to this rule may be used for alternatives located farther than 5 kilometers, if an engineering study can show that there will be no additional interference to any other station. Mount Diablo would not be an acceptable alternative location for the DTV antennas because Sutro Tower stations cannot broadcast from that site without interfering with signals from some Sacramento stations and thereby may violate FCC non-interference requirements. In addition, Mount Diablo would not be an acceptable alternate location for the DTV antennas because Oakland and other East Bay cities would be shadowed from direct reception ofsignals broadcast from Mount Diablo. Antennas on San Bruno Mountain could not adequately broadcast NTSC signals to all neighborhoods of San Francisco. Thus NTSC broadcasts would necessarily continue from Mount Sutro under this alternative, while DTV signals would be broadcast from San Bruno Mountain. This could entail each of the television stations to have additional personnel and two sets of test equipment monitoring the broadcasts to each other, one for each location during the 9-year period ofbroadcasting both DTV and NTSC signals. Sutro \ sut-dcs.doc 1-8 07/06197 1.0 Summary Ifan off-site alternative was constructed and implemented, impacts identified for the proposed project at Sutro Tower would instead occur at the alternative site location. For example, on San Bruno Mountain, new towers would need to be constructed, while at Sutro Tower the existing tower could remain in use. All on-site construction-related impacts identified for the Sutro Tower area under the proposed project would instead be experienced at the alternative location on San Bruno Mountain. Temporary installation noise impacts would not occur on the Sutro Tower site, nor would installation impacts due to traffic and air quality. Temporary construction jobs in San Francisco installing the antenna would also not occur. No impacts would occur due to operation of either this alternative or the project on land use, population, transportation, noise, air quality, public services and utilities, biology, water, hazardous materials, energy, geology, seismicity and soils, cultural resources, and growth inducing effects. Visual changes to the tower would not occur with this alternative. Near the likely site of a new tower at San Bruno the maximum RFR levels would rise from about 22.7 to 34.4 percent of the FCC 96 Guidelines, an increase of 11.7 percent of the guidelines. This contrasts with the increase in maximum RFR levels near Sutro Tower from 12.7 to 14.3 percent of the FCC 96 Guidelines, an increase of 1.6 percent of the guidelines. San Bruno Mountain is surrounded by public open space, and residential land uses are not located as close as for Sutro Tower. Other impacts associated with tower construction and/or antenna installation would also occur on the alternative site. These impacts would be temporary, and would likely fall within the range ofimpacts typically associated with small- to medium-scale construction projects. Long term visual impacts would not be substantial since other towers and antennas already existing on San Bruno Mountain. Sutm \ sut-des doc 1-9 07106197 In m n -e S Z II) 2.0 PROJECT DESCRIPTION 2.1 PROJECT SPONSOR OBJECTIVES Sutro Tower, Inc. is the owner of the Sutro Tower communications facility located in San Francisco. Sutro Tower, Inc. has operated this facility continuously since the initial construction under a Conditional Use authorization issued by the City and County of San Francisco on March 10, 1966. The Federal Communications Commission (FCC) determined that the Sutro Tower location provides the maximum television broadcast coverage for home reception in the San Francisco area due to a high and central location, and was therefore designated as the prime facility for television broadcasting for San Francisco stations. Sutro Tower, Inc. was accordingly organized as a cooperative venture between its four San Francisco television station owners and is required by FCC authorization to make its facility optimally accessible for such use consistent with signal non-interference and other technical, engineering and practical constraints. The fundamental objective of Sutro Tower, Inc. as project sponsor is to comply with the FCC's legal mandate for all commercial television broadcast stations in the United States, including all such stations currently broadcasting from Sutro Tower, to implement Digital Television (DIV) signal transmission in accordance with FCC deadlines (scheduled for October 1998) for this federally designated next generation of technology for television broadcasting. This fundamental objective includes a number of elements including the following: 1. Enabling Sutro Tower, Inc. and its commercial broadcast television station users, and its two noncommercial broadcast television users (KQED-IV 9 and KMTP-TV 32) to: NOTE: A glossary with definitions and acronyms used in this EIR is included below as Section 9.0. Sutro\ SUI-<lescnpllon 2-1 01106191 2.0 Project Description (i) comply with the DTV implementation standards, technical specifications and timetables (scheduled for October 1998) established in the FCC's long-running proceeding for this purpose (FCC Mass Media Docket No. 87-268); (ii) provide optimal broadcast television signal placement for San Francisco and surrounding Bay Area communities; and (iii) provide maximum community broadcast service from the television stations at Sutro Tower, by maximum household signal reception or "reach," consistent with FCC Rules (47 CFR Sections 73.682-73.687). 2. Maintain minimum broadcast signal interference with and separations between other television and non-television broadcasters and communications service providers, in accordance with the FCC's Rules (47 CFR Sections 73.610-73.612); 3. Consistent with such signal non-interference requirements, utilize a joint stack antenna configuration or other technical antenna configuration involving a single source location for as many of the existing Sutro Tower television broadcast signals as possible for DTV service; 4. Maintain compliance with applicable health and safety laws and standards for television broadcasting, including the human exposure standards for radiofrequency radiation (RFR); 5. Maintain future flexibility for the accommodation of technical improvements in broadcast communications technology, avoiding technical constraints that would limit compliance with or implementation of future regulatory and technological development; and 6. Maintain the signal non-interference and operational efficiency characteristics of a single-site broadcast location for the existing standard-technology ("NTSC") broadcast signals and the coming DTV broadcast implementation. Suuo \ sut-des.doc 2-2 01106191 2.0 Project Description 2.2 PROJECT LOCAnON Sutro Tower is an existing 977-foot tall steel structure/tower which includes antennas for ten television stations and four FM radio stations. Sutro Tower is located on an approximate four acre parcel on the east peak ofMount Sutro. Figure 1 shows the site location. Low density residential uses generally surround the project site. The project site is about 3,000 feet south of Kezar Stadium and Golden Gate Park, and south of the University of California at San Francisco. The project site is on Lot 3 of Assessor's Block 2724. Refer to Figure 2 for the site plan. Access to the project site is from La Avanzada Street. The site is roughly surrounded by Dellbrook Avenue, Clarendon Drive, Panorama Drive, Farview Court, and Clairview Court. Mount Sutro is one of the highest points in San Francisco with an elevation of 908 feet. The site is the most feasible-site in San Francisco from which radio and television signals can be broadcast without shadowing from other higher locations. (Hammett & Edison, 1993) The 977 foot-tall tower is located at an elevation of about 834 feet above sea level. The total height to the top ofthe tower above sea level is about 1,811 feet. 2.3 PROJECT CHARACTERISTICS Sutro Tower has antennas for ten television stations and four FM radio stations. Figure 3 shows where the existing antennas are located on Sutro Tower. The television stations currently broadcast National Television Standards Committee (NTSC) signals. Please refer to Table 1 for the frequency range in megahertz (MHz or one million hertz) for each of the existing television and radio stations, and for the proposed project. The project would install a new antenna system able to accommodate a second set of broadcasts from the ten existing television stations on Sutro Tower. The second set of antennas would broadcast DTV signals from Sutro Tower in addition to the NTSC signals until such time as the FCC required termination of the NTSC signals (see project sponsor's objectives, above). Rather than the analog signal currently used by the broadcast industry, DTV codes the signal information into a digital system, similar to that used in a computer. The Sutro \ sut-des.doc 2-3 01106/97 Woodward-Clyde Consultants I ST. : E :z: ::r:: l- t.: "; 00 Project No. 961005NA Sutro Tower DTV ErR SITE LOCATION ! -N- m 0 500 1000 I I I feet Figure 1 961005NA-3000/120396/graphicslmci 2-4 '-- -----------------"'--_._--_._-------------------------------_. ------------------------ ---'--- () til Ci1 ::J a. o ::J I ~z~ I 370' Gate Guard Station / / / / / / / / / Main Building 104' [,....--------' .....---+-- 144' 300' \??--------- 370' --------?? -------------------------.---".----- -------------\---------- / G&age \ ('/~;j1~"g,'\ / ..... Sutro \9' \ I Tower Footings " V Parkin~ / / \600'- :/ il ;\ \ \ \ \ \ \ Dellbrook tll E t!: o c: tll a.. (not to scale) Source: Sutro Tower, Inc. Woodward-Clyde Consultants Project No. 961005NA Sutro Tower DTV EIR SITE PLAN Figure 2 961 005NA-3200/063097/wcclgraphicSimCi 2-5 -------------------- ----- 977 Feet AGL KKSF (FM) <top two boys) KFOG (FM) (botton boy) --'l'ir---.-1' KPST- TV (66) -----11 KOED (9) l,o-'rIr----..., Chon 26 <Inoperative) 111\+-------1 KMTP (32) KOIT-FM f-----H-- KSOL-FMI------D~~SIZJ K T VU (2) 1----It --1EI-"* KRON-TV (4)/KPIX (5)1----+- KGO-TV (7)1-1---- KOFY-TV (20)1----I,+/IUI KCNS (38)1-1--- KBHK-TV (44)f---.-{ Level 4 (557 Feet AGU Level 5 (657 Feet AGU Level 6 (762 Feet AGU Level ::3 <382 Feet AGU Standby Antennasl L I 2 KTVU eve KRON-TV <187 Feet AGU KPIX KOIT-FM KFOG (FM) KGO-TV KOED (TV) KOFY-TV K8HK-TV KPST-TV KSOL-FM KKSF-FM Site Elevation North Latitude 37 45 20 West Longitude 122 27 05 Note: AGL =Above Ground Level (not to scale) Source: Sutro Tower, Inc. Woodward-Clyde Consultants Project No. 961005NA Sutro Tower DTV EIR SUTRO TOWER BROADCASTING ANTENNAS Figure 3 96100SNA-3200/063097/wcclgraph,cslmci 2-6 TABLE 1 EXISTING AND PROPOSED SUTRO TOWER BROADCAST STATIONS Effective Call Letters Channel Frequency Location Radiated Number (MHz) at Tower Power Existing VHF TV Stations KTVU 2 54-60 West Stack 100kW KRON 4 66-72 West Stack 100kW KPIX 5 76-82 West Stack 100kW KGO 7 174-180 South Stack 316 kW KQED 9 186-192 North Stack 316 kW Existing UHF TV Stations KOFY 20 506-512 South Stack 3,470 kW KMTP 32 578-584 North Stack 1,333 kW KeNS 38 614-620 Below level 6 5,000 kW KBHK 44 650-656 South Stack 5,000 kW KPST 66 782-788 North Stack 3,470 kW Existing FM Radio Stations KOIT 243 96.5 Above level 5 33.0 kW KSOL 255 98.9 Below level 5 6.0kW KKSF 279 103.7 Below level 6 7.8kW KFOG 283 104.5 Below level 6 7.9kW Proposed DTV Stations KRON 57 728-734 DTVPole 1,000 kW· KBHK 45 656-662 DTV Pole 197 kW· KOFY 19 500-506 DTV Pole 141 kW· KPIX 28 554-560 DTV Pole 1,000 kW· KMTP 33 584-590 DTV Pole 50kW· KTVU 56 722-728 DTV Pole 1,000 kW· KCNS 39 620-626 DTV Pole 209 kW· KPST 30 566-572 DTVPole 56kW· KQED 34 590-596 DTV Pole 736 kW· KGO 24 530-536 DTVPole 594 kW· Existing Ancillary Transmitting Stations Microwave (about 20) 2-23 GHz Various 1-10 W Private Radio (about 40) 160-950 MHz Various 10-100 W ? This is the authorized power. Some stations may run at lower power levels. Notes: MHz = megahertz; GHz = gigahertz; W = watts; kW = kilowatts Source: Sutro Tower, Inc., 1997; Hammett & Edison, 1997 Sutro \ sut-description 2-7 07/07197 2.0 Project Description DTV system can carry the same type of programming as seen on TV today, and could also carry additional data services. DTV would also allow stations to send multiple programs simultaneously on a single channel. With DTV, additional signals in the FCC DTV range of 500 to 734 megahertz (MHz) radio frequency (RF) range would be broadcast from Sutro Tower, during the period of overlapping DTV and NTSC broadcasts (estimated to be until May 2006). Thereafter, the DTV signals would replace the existing NTSC signals. Figure 4 shows the location ofthe proposed DTV antennas on Sutro Tower. A new 125-foot long beam about 3 feet wide by 3 feet deep would be attached to Level 6 of the tower about 755 feet above the base of the tower. The beam would be attached to the east face of Sutro Tower and would hang down vertically to a height ofabout 630 feet above ground level. The antennas would be attached to this new beam. The beam would be brought to the site by truck, already manufactured, in three sections. Each ofthe three sections would be hoisted up the tower and installed in place. No power impact tools are anticipated to be necessary for the installation process. In addition to the regular radiofrequency emissions from Sutro Tower, most of the stations have "stand-by" auxiliary antennas on the tower. These auxiliary antennas can be used to broadcast TV signals if the regular antennas are unable to operate. Currently these antennas are used on an infrequent basis (about six times a year for about one-half hour between 9 a.m. and noon) when work needs to be done on the main antennas. The auxiliary antennas are mounted at the first rung (Level 2) of Sutro Tower and generally emit a fraction of the power of the main antennas, although three auxiliary antennas emit more power. No additional auxiliary antennas are proposed at this time. If auxiliary antennas are installed in the future, the frequencies broadcast would be identical to frequencies broadcast from the main antennas, but the power densities would be lower. No demolition would occur on site. Sutro \ sut-des.doc 2-8 07106197 LEG B DTV ANTENNA / LEG ( _ 657 FT. AGL LEVEL =5 _557 FT. AGL LEVEL =4 (not to scale) Source: Sutro Tower, Inc. Woodward-Clyde Consultants 961005NA·3200/120396/wcclgraphicsimci Project No. 961005NA Sutro Tower DTV EIR DTV ANTENNA FRONT VIEW 2-9 Figure 4 2.0 Project Description 2.4 PROJECT SCHEDULE, COST, AND APPROVAL REQUIREMENTS 2.4.1 Schedule and Costs The project sponsor expects environmental review and project review to be completed in September 1997. If the project is approved and city permits issued, the new set of antennas could be delivered to the site within about one week. The new set of antennas could be installed on the tower in about six weeks. Estimated installing cost ofthe new antennas would be about 400,000 dollars (1997). 2.4.2 Approvals Following publication of the Draft EIR, there will be a written comment period and a public hearing before the City Planning Commission to solicit public comment on the adequacy and accuracy of information presented in the Draft EIR. Following that comment period, responses to written and oral comments will be prepared. The EIR will be revised as appropriate and presented to the City Planning Commission for certification as to its accuracy, objectiveness, and completeness. No local permits may be issued before the EIR is certified as final. The project will require an electrical permit by the City and County of San Francisco to increase electrical use by the project. An additional onsite electrical transformer would need to be added to each oftwo 12 kilovolt feeder lines that currently serve the tower. (PG&E, 1996) The project may also require additional building and electrical permits to allow Sutro Tower tenants to make necessary improvement in their leased space to accommodate DTV equipment. No amendments to the eXlstmg conditional use to operate the tower would be required pursuant to Zoning Administrator determinations of 1988 and 1996. However, pursuant to City Planning Commission Resolution No. 11399, adopted July 14, 1988, the City Planning Commission would hold a public hearing to review the proposed project under its Discretionary Review authority. Sutro \ sut-<les.doc 2-10 07/06197 2.0 Project Description In addition to approval of necessary permits by the City and County of San Francisco, Digital Television implementation at Sutro Tower will require the following: 1. Each existing television broadcaster operating at Sutro Tower must obtain its individual DTV station license from the FCC, a process which the FCC completed in April 1997; 2. In conjunction with such DTV licensing, the FCC would assign a channel number and power limit to each DTV station (in many if not all cases, a station's DTV channel number would be different from its existing channel number): 3. Each DTV station would be required under FCC rules to begin DTV broadcasting within a prescribed period oftime; and 4. Any changes in tower height or configuration which would change the tower profile for purpose of airspace navigation must be notified and handled in accordance with the rules of the FCC and the Federal Aviation Administration (FAA). However, no such tower profile changes are anticipated or proposed in order to implement DTV at Sutro Tower. 2.4.3 General Plan The project would be reviewed by the City Planning Commission in the context of applicable objectives and policies of the San Francisco General Plan. The following are some of the objectives and policies that may be relevant to the proposed project. Objective 2 of the Commerce and Industry Element states: "Maintain and enhance a sound and diverse economic base and fiscal structure for the city." Policy 1 ofthis objective states: "Seek to retain existing commercial and industrial activity and to attract new such activity to the city." Objective 12 of the Residence Element states: "To provide a quality living environment." Policy 1 of this objective states: "Assure housing is provided with adequate public improvements, services and amenities." SUlrO \ sut-des.doc 2-11 07/06/97 2.0 Project Description In the Environmental Protection Element, Objective 4, Policy 4: "Promote the development of nonpolluting industry and insist on compliance of existing industry with established industrial emission control regulations." Objective 7, Policy 2 states: "Protect land from changes that would make it unsafe or unsightly." REFERENCES PG&E, Mark Feiling, Industrial Power Engineer, telephone conversation, December 10, 1996. William F. Hammett, Principal, Hammett & Edison, Inc., letter to Eugene Zastrow, Vice President and General Manager, Sutro Tower, Inc., July 13, 1993. Sutro ., sut-des.doc 2-12 07/06197 3.0 ENVIRONMENTAL SETTING AND IMPACTS INTRODUCTION This section combines discussion ofthe environmental setting and analysis ofimpacts by topic. Setting and impacts are combined by topic so as to more readily ascertain project impacts. The analysis ofpublic health effects is based on two technical studies prepared for the project. 1. Hammett & Edison, Inc. analyzed existing and proposed radiofrequency levels in the vicinity of Sutro Tower in a study called Sutro Tower, Inc. San Francisco, California, Engineering Analysis ofRadiofrequency Exposure Conditions with Addition ofDigital TV Channels. This study is included as Appendix A of this EIR. and is used as the basis for analysis ofradiofrequency levels that would result due to the project. 2. Two experts, Peter Polson, Ph.D. and Louis N. Heynick, M.S., prepared a technical report for this project on whether exposure to radiofrequency radiation (RFR) adversely affects humans and other animals, which is called Biological Effects ofRadiofrequency Radiation (RFR): Possible Health Effects ofRFR on Nearby Humans from Sutro Tower Digital Television Broadcasts. Additional contributions were made by another expert. This report was also peer reviewed by the San Francisco Department of Public Health and an independent expert retained by the Health Department. This report is included as Appendix B ofthis EIR. and is the basis for analysis of health effects that could occur due to RFR exposure from the project. 3.1 PUBLIC HEALTH EFFECTS 3.1.1 Background Information Properties ofElectromagnetic Frequencies Electromagnetic waves come in two forms: ionizing and nonionizing electromagnetic waves. Nonionizing waves are further categorized as visible light and infrared radiation, Sutro EIR \ sut 3-1 3-1 07/06/97 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) radiofrequency radiation (RFR), and extremely low frequency (ELF) electric and magnetic fields. RFR and ELF are further discussed below. Ionizing Radiation The shortest wavelengths, or highest frequencies, are ionizing electromagnetic radiation. The frequencies are the highest (above 1.5 x 10 15 Hertz) of all electromagnetic waves. (The hertz is the unit for measuring frequency [in cycles per second] of the electromagnetic wave.) Ionizing radiations, such as ultraviolet light, X-rays, and radioactive emissions, has higher energy levels than nonionizing radiations. In essence, ionizing radiation absorbed by a molecule yields enough energy to expel an electron from the molecule (ionize it), leaving it positively charged and thus enhancing the interactions of the molecule with its neighbors. Such interactions can alter the functions ofbiological molecules fundamentally and irreversibly in living organisms. Moreover, the damage caused by ionizing radiation can be cumulative. No ionizing radiation is present at Sutro Tower or planned as a part ofthe project. As indicated above, RFR is a type of nonionizing radiation. As such, any potential health or other effects of ionizing radiation are not relevant to the analysis ofpotential effects from RFR. Nonionizing Radiation Nonionizing radiation consists ofvarious forms ofelectric and magnetic fields. Such fields occur both naturally, among them the earth's magnetic field and the electric fields in the atmosphere (most prominent during storms), and artificially by electric generation and wireless communications. The energy level ofthese waves is too low to eject electrons from (or ionize) atoms or molecules. Radiofreguency Radiation QUR) Television broadcasts involve electromagnetic energy at certain frequencies. Broadcast antennas are powered by an alternating electrical current. The rate at which the current alternates (or SulrO ElR \ Silt 3-1 3-2 07106/97 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) changes from positive to negative), determines the frequency, expressed in hertz (Hz) or in millions ofhertz (megahertz; MHz) or billions ofhertz (gigahertz; GHz). RFR includes electromagnetic waves or radiowaves in the frequency range up to 300 gigahertz (GHz or 1 billion cycles per second). These radiowaves are a form of nonionizing radiation. The wavelengths are longer than for ionizing radiation, and are used for transmission of radio and television signals such as the radiofrequency waves from Sutro Tower. The energy content of individual quanta in RFR is so much smaller than ionizing radiation that relatively high rates (in relatively large numbers ofquanta per unit time) are necessary to produce a physiologically significant amount of heat. 1 RFR heating immediately ends on stopping the exposure. Exposure levels to RFR are generally referred to as "power densities" (the rate at which energy is available over a region of space) and are expressed in terms of milliwatts per square centimeter (a milliwatt is one-thousandth of a watt). In general, power density levels from a radiofrequency source decrease according to the inverse square principle; at twice the distance from the source, a point will receive one-fourth ofthe level ofradiation exposure. Sutro Tower currently emits RFR with a frequency range between 54-788 MHz during television and radio broadcasts. This RFR is the type ofelectromagnetic waves that is specifically analyzed in the Technical Report and within the text ofthis EIR Extremely Low Frequencies (ELF) Within the class of nonionizing radiations, a basic difference exists in interaction between RFR and electric and magnetic fields at extremely low frequencies (ELF) (usually 60 Hz in the U.S.), such as those used in the transmission of electric power from generating stations to substations and thence to the ultimate consumers of electricity. The wavelength corresponding to 60 Hz is 1 physiolo2ically si2nificant amount of heat: An energy input sufficient to stimulate a change or changes in thermoregulatory body functions such as sweating, breathing rate, and blood flow rate, or to cause changes in cellular functions such as firing rates of nerve cells and beating rates ofheart cells, or to cause changes in biochemical functions such as activity levels of enzymes and amounts of proteins produced by cells. Sutro EIR \ sut 3-1 3-3 07106197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) more than 3,100 miles. Thus, people near a power line are in its "induction" zone (meaning at distances of only a fraction ofa wavelength. By contrast, the wavelength corresponding to 626 megahertz (MHz), which is the midband frequency of the Sutro DTV broadcast transmitter, is approximately 1.6 ft. Controversy surrounds reports of the adverse effects on humans from exposure to the electric and magnetic fields present in homes from the power lines supplying electricity to the house, the electric fields from operating appliances within the home, and those from any nearby high-voltage power lines. Radio and television frequencies such as are broadcast from Sutro Tower are millions oforders ofmagnitude higher (shorter waves) than electric power line frequencies. Thus the interactions with biological bodies differ between radio/television signals and power line frequencies. No extremely low frequencies are emitted from Sutro Tower for broadcasting television and radio signals. Electricity is used to power operations at Sutro Tower, including to operate the transmitters and receivers. As for any consumer of electricity, extremely low frequencies would be used. RFR Regulatory Safety Guidelines In 1991, the Institute ofElectrical and Electronic Engineers (IEEE) issued a set ofguidelines for human exposure to RFR developed by the American National Standards Institute (ANSI). In 1992, these guidelines were adopted by ANSI, and are referred to as ANSI/IEEE Guidelines (1992). The standards were based on a relatively large body of scientific investigation and literature which generally concluded that the principal concern regarding health effects from exposure to RFR was associated with an increase in body temperature. Another conclusion inherent within the standards is that exposures below 4 watts per kilogram of body weight (4.0 W/kg) do not cause a hazardous increase in body heat. This level is approximately the level achieved by exposure to 10 milliwatts per square centimeter (10 mW/cm 2 ). The standards then applied a safety factor of50 times in "uncontrolled environments" (general public exposure) and a factor of 10 times for "controlled environments" (workplace exposure). Hence, the resulting standards for the frequency range from 30 to 300 MHz are 0.2 mW/cm 2 for general public exposure, and 1 mW/cm 2 for workplace exposure. Sutro EIR \ sut 3-1 3-4 07106197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) In December 1996, the FCC adopted revised guidelines (FCC 96 Guidelines) which place limits on RFR exposure.. These guidelines are generally based on recommendations found in NeRP Report 86 and are identical to the 1992 ANSII/EEE Guidelines in the radio and television frequency range which are currently broadcast and the range proposed to be broadcast from Sutro Tower. These RFR exposure guidelines were designed to protect the health of human beings exposed, either accidentally or voluntarily to RFR in the environment or the workplace. These guidelines are based on consideration of RFR exposures which may be acute or chronic, thermal (heat-based) or nonthermal. The FCC 96 Guidelines cover the frequency range from 300 kHz to 100 GHz. RFR currently emitted from Sutro Tower falls within this range with: (1) television and radio broadcasts between 54-788 MHz, (2) private radio transmissions between 160-950 MHz, and (3) microwave transmissions between 2-23 GHz. In the FCC adopted DTV frequency range (460-806 MHz), the maximum permissible power densities for exposure in uncontrolled environments are in the range 383-672 microwatts per square centimeter (0.38-0.67 milliwatts per square centimeter). For occupational exposures over the range of 54 to 806 MHz the lowest maximum permissible incident freespace power density is 1.0 milliwatts per square centimeter squared, applicable for the frequency range 30-300 MHz, with a 6 minute averaging time. Over the range 300 to 806 MHz, the maximum permissible power density ranges from 1.00 to 2.69 milliwatts per square centimeter squared. These are the frequency ranges relevant to Sutro Tower. Other exposure guidelines are also discussed in the Appendix B Technical Report. For general population exposures, the maximum permissible power densities are one-fifth as great. 3.1.2 Approach and Methodology Public Health Effects Approach and Methodology The Appendix B Technical Report reviewed papers selected as being representative ofthe many thousands published in scientific journals, typically after peer review, through mid-1996 with additions up to mid-1997. Papers were selected which made major contributions towards resolving major biophysics and physiology questions regarding RFR, which have been addressed 5ulro EIR \ sut 3-1 3-5 07106197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) in numerous research studies. Studies which show potential health effects were chosen along with subsequent studies responding to the same questions. With a few exceptions, presentation at scientific symposia or abstracts thereof have been excluded on the assumptions that they were not peer-reviewed or that detailed peer-reviewed account of such studies may appear subsequently. The selected papers were then analyzed for the adequacy of their analyses and their relevance to Sutro Tower. If a study found no relationship of disease or death with exposure to R.FR, the findings were "negative." Ifa study found a relationship ofdisease or death with exposure to RFR, the findings were "positive." Information from this report is summarized within the EIR text. Radiofreguency Levels Approach and Methodology To gather data for this EIR, Hammett & Edison, Inc. conducted a study, Sutro Tower, Inc. San Francisco, California, Engineering Analysis of Radiofrequency Exposure Conditions with Addition ofDigital TV Channels. The study characterizes radiofrequency radiation (RFR) levels in the vicinity ofSutro Tower. This study is included as Appendix A. In 1988, Hammett & Edison measured RFR at 480 locations within a 3/4 mile radius of Sutro Tower, using a calibrated Holaday Instruments Broadband Exposure Meter, Model 1ll-3001. Hammett & Edison has taken subsequent measurements in 1991 and 1993. On December 5, 1996, Hammett & Edison took spot measurements at ten locations using a Holaday Instruments Broadband Exposure Meter, Model 1ll-3004, which had been calibrated on October 14, 1996. This meter is more sensitive than the previously used Holaday 1ll-3001. A representative of the San Francisco Department of Public Health accompanied Hammett & Edison during the RFR measurements. Figure 5 shows where the measurements were taken. Hammett & Edison wrote a computer program which calculated potential RFR at 8,900 locations across San Francisco, including at 3,150 points within an approximate 1Y2 mile radius of the tower, calculating both existing conditions (NTSC broadcasts only) and proposed conditions NTSC plus DTV broadcasts). For purpose of predictive analysis, the calculations assumed a Su~oEIR \ sut 3-1 3-6 07/06197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) higher power lever for DTV than could probably be installed and operated at Sutro Tower. An analysis of the two sets of data shows that the calculated 1996 existing levels were higher and therefore more conservative than the actual measured levels recorded in 1988, 1991, 1993, or spot-checked in 1996. The program then calculated power density for each station, and fractions contributed by each were summed at 8,900 points. (See Appendix A for the methodology.) 3.1.3 Environmental Setting RFR Levels in the Vicinity ofSutro Tower Table 2 shows measured and calculated existing energy levels and power densities in relation to the FCC 96 Guidelines for the ten locations shown on Figure 5. Ofthe ten locations measured for RFR in December 1996, the highest RFR level measured was 0.0229 milliwatts per square centimeter (mW/cm 2 ) at location 2. The highest existing RFR level calculated was 0.0247 mW/cm 2 , also at location 2 (see Figure 5). This calculated value was at 11.5 percent ofthe FCC 96 Guidelines. The approximate power density at distances from Sutro Tower as a percent of the FCC 96 Guidelines follows: Approximate Power Density 10 - 15% 5- 10% 1 - 5% 0.5 - 1% <0.5% Approximate Distance from Sutro Tower at tower to about one city block about two city blocks about nine city blocks about 18 city blocks more than 18 city blocks The highest measured and calculated levels of existing public exposure to RFR from Sutro Tower, at a sensitive receptor (residence) is at Farview Court, approximately one block from the tower. The calculated level of 0.025 mW/cm 2 is at about 12.7 percent of the federal safety standard. Other sensitive receptors live about one block or more from the tower. The average existing radiofrequency level at a distance of 1 kilometer (about ten blocks) of Sutro Tower is 0.0034 mW/cm 2 , which is about 1.7 percent ofthe federal safety standard for public exposure. Sutro EIR \ sut 3-\ 3-7 07/06/97 o 0.1 0.2 0.3 0.4 0.5 ! I I ! ! I mile Source: Hammett &Edison, Inc. 1997; AAA, San Francisco, CA 1979 Woodward-Clyde Consultants Project No. 961005NA Sutro Tower DTV EIR LOCATION OF RFR MEASUREMENTS Figure 5 961 OOSNA-3200/031797/wccJgraphicslgos.mci 3-8 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) TABLE 2 COMPARISON OF EXISTING RADIOFREQUENCY POWER DENSITY WITH EXISTING CALCULATED VALUES Measurement Measured Calculated Location" Power Density b, c Power Density d % FCC Guidelines e. ( g 1 0.0229 0.0247 11.4 2 0.0234 0.0269 11.5 3 0.0077 0.0171 6.98 4 0.00076 0.0066 2.54 5 0.0014 0.0095 3.88 6 0.0020 0.0035 1.64 7 0.00011 0.0011 0.47 8 0.00038 0.0009 0.41 9 0.00045 0.0007 0.32 10 0.00013 0.0014 0.53 a b c d c f g Measurement locations are shown on Figure 5, page 3-8. These were selected arbitrarily at various distances from Sutro Tower. These values are in mW/cm 2 (milliwatts per centimeter squared). Power densities were measured on December 5, 1996, with Holaday ID-3004 Broadband Exposure Meter. Calculations are based on formulas in Appendix A. Percent ofstandard is based on applicable limits for public exposures ofunlimited duration. Standard is based on applicable limits for public exposures of unlimited duration and the power densities are in mW/cm 2 , Power densities under the FCC 96 Guidelines range from 0.2 mW/cm 2 for Channel 2 up to 0.522 mW/cm 2 for Channel 66. Source: Hammett & Edison, 1997 Sutro ElR \ sut 3-1 3-9 07/06197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) Most of the stations at Sutro Tower have stand-by "auxiliary" antennas on the Tower, too, so that they can continue to serve the public iftheir main antennas on top ofthe Tower should fail or ifwork needs to be done on those antennas. The auxiliary antennas are mounted mostly at the first rung ofthe Tower, and some handle less power than the main antennas. Table 1, page 2-7 in Section 2.0, lists those stations having auxiliary facilities at Sutro. Because ofthe lower UHF powers and/or the changed positions ofthe energy sources, the power density in the neighborhoods near Sutro Tower from the auxiliary antennas is often lower than that from the main antennas. In some cases, the shorter distance to the antennas might dominate, and the exposure level form the auxiliary antennas might exceed that ofthe main antennas. In all cases, though, the total RF energy under any condition ofauxiliary operation is less than what the government allows for continuous exposure, and is intermittent and short-term in nature. No new auxiliary facilities are currently proposed for the DTV stations, and it is likely that none will be constructed until the end of the FCC transition period for all stations to have switched over to new DTV broadcasting capabilities, and terminated NTSC broadcasts. Worker Health and Safety For a facility that emits RFR, the occupational environment presents potential hazards to the workers. These hazards include accidents (i.e., cuts, bruises, falling) and potential exposure to RFR at close range. The types of occupational hazards seen at Sutro Tower are routine for television and radio broadcast towers. Laws and Regulations State and federal regulations exist regarding worker safety. Cal/OSHA and the Federal Communications Commission (FCC) have both established limits for personnel exposure to RFR. The FCC limits are more stringent than the Cal/OSHA requirements. See Section 3.1.3, RFR Regulatory Safety Guidelines, for a discussion specific to the FCC 96 Guidelines which apply to occupational RFR exposure. Sutro EIR \ sut 3-\ 3-10 07/06197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) RFR Protection Rules at Sutro Tower Sutro Tower, Inc. has set up RFR protection rules for personnel who work on the tower. The rules contained herein were adopted in May, 1996, and are expected to be modified from time to time as safety issues evolve. A program of independent measurements has been implemented which requires taking measurements anytime the facility plans to make a change in the facility which is likely to increase exposure. In addition, every time one ofthe broadcast stations is required to renew its operating license, it must takeRFR measurements. Warning signs are posted at the entrances to areas where exposure levels may exceed permissible levels without protective clothing. Access to tower locations above Level 4 (see Figure 3 in Section 2, Project Description, page 2 6) during main antenna operation is not allowed. The only exception is for personnel wearing complete body RF protective clothing including suit, hood, gloves and boots on the main walkways on levels 5 and 6 and the catwalk above level 6. Access to tower locations above ground, up to the bottom of Level 3 is not allowed during auxiliary antenna operation. Auxiliary antenna operation is signaled by the flashing red light in the lobby, outside the front door, at the foot of the elevator steps, and on Level 2 outside the elevator door. All stations have installed and must maintain a dry contact closure indicating auxiliary antenna operation which activates a visual and aural auxiliary antenna alarm system. The aural alarm is a siren at the foot ofthe tower elevator steps and on Level 2 which sounds for approximately one minute whenever an auxiliary antenna is energized. When the alarm is activated all workers on the outside ofLevel 2 have been instructed to immediately cease work and proceed as rapidly as possible to the interior ofthe level. Further movement will be at the direction ofthe Sutro Tower manager or designated coordinator. The visual alarm, which operates at all times during auxiliary operation, is discussed above. Working or climbing on energized antennas is not allowed under any conditions. Sullo EIR \ sut 3-1 3-11 07/06197 Environmental Setting and Impacts 3. 1 Radiofrequency Radiation (RFR) Under all conditions, only authorized personnel may ride the tower elevator to any location as long as the restrictions described above are observed. The elevator must not be operated with safety interlocks defeated. Riders are allowed only inside the elevator car. The Elevator operator must have received operator training. The weight limit of 750 pounds must not be exceeded. The Level 4 elevator interlock must be kept on except when used by people wearing proper RF protective clothing including suit, hood, gloves and boots. Personnel must carry a Sutro Tower portable two-way radio which is in contact with a person carrying a Sutro Radio whenever that person is on the tower or in the elevator. The radio must be tested before ascent. All stations must notify Sutro Tower, Inc. in advance of scheduled maintenance operations on auxiliary antennas. Sutro Tower, Inc. will coordinate scheduled auxiliary antenna operation with scheduled maintenance activities. Stations must coordinate with Sutro Tower, Inc. in-a advance ofany maintenance or installation activity planned on the second level. Sutro Tower, Inc. will determine which antennas pose a potential hazard to the proposed maintenance work and will notify affected stations of the proposed schedule. During the work period the affected stations will not energize their auxiliary antennas without first receiving clearance from Sutro Tower, Inc. All stations will supply a prioritized list of names and phone numbers ofpeople to notify when auxiliary antenna restrictions are necessary. Worker Safety Compliance Once a month Sutro Tower, Inc. usually conducts a safety inspection of the premises. The results of these inspections are discussed at monthly safety meetings where progress toward fixing any safety problems is reported. (Sutro, 1996) In 1996, one reported accident occurred at Sutro Tower. One ofthe employees was injured by a sliver ofmetal lodging in his eye. (Lincoln, 1997) Swo EIR \ sut 3-1 3-12 07106197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) 3.1.4 PUBLIC HEALTH EFFECTS RFR Levels Resulting from Implementing the Sutro Tower DTV EIR Project This section is based on the study conducted by Hammett & Edison, Inc. which is included as Appendix A ofthis EIR. Regarding distance, the closest residence is about 250 feet away from the base ofthe tower, and over 800 feet from the closest antenna. The closest public roadway is about 150 feet from the tower. As noted in the Environmental Setting discussion, the highest calculated level of existing radiofrequency power emissions at a sensitive receptor near Sutro Tower is at Farview Court, approximately one block from the tower. The maximum existing radiofrequency power emission of about 0.025 mW/cm 2 currently resulting from radio and television broadcasts from Sutro Tower, is at about 12.7 percent ofthe allowable maximum under the FCC 96 Guidelines. With the addition of DTV antennas, the broadcast emissions at the closest sensitive receptor would result in RFR levels of about 0.029 mW/cm 2 or 14.3 percent of the allowable maximum under the FCC 96 Guidelines. These levels in tum drop offrapidly with increased distance from Sutro Tower. (Refer to Table 3 for a comparison of existing to proposed RFR at ten other selected locations.) Once the NTSC signals are no longer broadcast, then the power densities would drop below existing power levels. Summary ofPotential Biological Effects DTV service is expected to use average effective radiated powers that are below the present NTSC analog system peak power. This means that a DTV station would radiate a signal with an average effective radiated power that is about one-eighth (12 percent) of the present average power radiated by the traditional television technology. As a consequence, with introduction of DTV, public exposure to RFR due to the DIV signal alone would actually be only a fraction of the present values associated with the NISC system. However, in view of the manner in which the FCC has decided that the DTV system shall be implemented in the U.S., an approximate 9 year period will result in which DIV signals will be broadcast simultaneously with the current NTSC signals. During this period of overlap, the additional DTV service will slightly increase SUlro EIR \ sut 3-1 3-13 07/06197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) ambient environmental RF fields from the television service. In terms of average RF field exposure levels, this will amount to an anticipated 12 percent increase. Following the introductory period for DTV, the older NTSC system signals will be eliminated, leaving only the lower DTV signals. This will result in an overall drop in environmental RF fields in the long term due to DTV broadcasting. The Appendix B Technical Report analyzed literature and studies which investigated potential health effects on humans and other animals. In summary, the general conclusion ofthe Technical Report is that to the extent that health effects have been identified, they have been associated with RFR levels that were high enough to have thermal effects (cause a hazardous increase in body temperature). The 1992 ANSI/IEEE Guidelines first established a threshold level ofRFR exposure at which it was generally agreed that adverse health effects, including thermal effects, could occur. A safety factor of 50 times (i.e., divide the lowest established level know to cause adverse effect by 50) was established for uncontrolled environments (public exposure). These guidelines were subsequently adopted into the FCC 96 Guidelines. Hence, the maximum public exposure levels resulting from the proposed project would be 50 times lower than the lowest level at which thermal effects were found to occur. The Technical Report, the San Francisco Department of Public Health, and an independent expert all conclude that although there is controversy surrounding health effects, the substantial weight of scientific evidence indicates that human exposure at or below levels ofRFR prescribed by the FCC 96 Guidelines would not be harmful to human health. As mentioned in the section above, the maximum exposures from the proposed project would be at about 14.3 percent of the FCC 96 Guidelines. These levels in tum drop off rapidly with increased distance from Sutro Tower. Experimental data indicate that relatively low-level RFR exposure is not cumulative. At the levels expected from project implementation, adverse health effects are not anticipated. Concerns have been expressed regarding the effect ofRFR on pacemakers. RFR would not be expected to impact a person from the general population wearing a pacemaker, due to distance Sutro EIR \ sut 3-1 3-14 07106197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) TABLE 3 COMPARISON OF EXISTING MEASURED RADIOFREQUENCY POWER DENSITY WITH FUTURE CALCULATED VALUES Measurement Existing Measured Location a Power Density b, C Measurement locations are sho\W on Figure 5, page 3-7. These were selected arbitrarily at various distances from Sutro Tower. These values are in mW/crn1 (milliwatts per centimeter squared). Power densities were measured on December 5, 1996, with Holaday ID-3004 Broadband Exposure Meter. Calculations for existing values are for NTSC broadcasts and are based on formulas in Appendix A. Percent ofstandard is based on applicable limits for public exposures ofunlimited duration. Standard is based on applicable limits for publie exposures of unlimited duration and the power densities are in mW/em 2 . Power densities under the FCC 96 Guidelines range from 0.2 mW/cm 2 for Channel 2 up to 0.522 mW/em 2 for Channel 66. Calculations for future values include DTV and NTSC broadcasts and are based on formulas in Appendix A. The percent increase is based on the change between the existing calculated RFR emissions and the future calculated emissions. This takes into account any physical anomalies that could occur due to actual conditions. 1 2 3 4 5 6 7 8 9 10 a b c d e f g b 0.0229 0.0234 0.0077 0.00076 0.0014 0.0020 0.00011 0.00038 0.00045 0.00013 Existing Calculated Future Calculated % Power 0/0 FCC Power 0/0 FCC Increase 1 Density d Guidelines e. r. 8 Density h Guidelines" f 0.0247 11.4% 0.0275 12.1% 6.1% 0.0269 11.5% 0.0295 12.2% 6.1% 0.0171 6.98% 0.0181 7.23% 3.6% 0.00663 2.54% 0.00693 2.62% 3.1% 0.00951 3.88% 0.0105 4.12% 6.2% 0.00350 1.64% 0.00372 1.70% 3.7% 0.00110 0.470% 0.00120 0.494% 5.1% 0.000880 0.407% 0.000883 0.408% 0.25% 0.000700 0.316% 0.000892 0.368% 16% 0.00139 0.529% 0.00150 0.558% 5.5% Source: Hammett & Edison, 1997 Suvo EIR \ sut 3·1 3-15 07106197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) from the source and the type of RFR broadcast. Even at these closest possible locations (about 150 feet to the nearest roadway and about 250 feet to the nearest residence), RFR levels are not expected to affect operation of a pacemaker because neither DTV or NTSC TV have low frequency pulses ofthe type to which pacemakers are most sensitive. While the substantial weight of scientific research has indicted that no adverse health effects would result at low power levels (i.e., less than the FCC 96 Guidelines), some findings have been contrary. The Technical Report includes an in-depth analysis of studies that have found some potential adverse health effect and generally concludes that those studies do not refute the general conclusion that the FCC 96 Guidelines establish safe RF exposure levels. The Technical Report concludes that the adverse effects identified were the result of a thermal effect (a measurable increase in body or cell temperature); or the studies were either not reliable (for reasons stated in the reports such as flawed methodologies, lack of appropriate controls, etc.); or that the evidence for adverse effects was inconclusive and in contradiction with the substantial weight of reliable scientific evidence which indicated that there would not be any adverse effect from RFR levels at or below those permitted in the FCC 96 Guidelines. A brief narrative summarizing the areas ofresearch, the findings ofthe studies, and the conclusion ofthe Technical Report is presented below. As mentioned above, the full text of the Technical Report prepared for this project, Biological Effects ofRadiofrequency Radiation (RFR): Possible Effects ofRFR on Nearby Humans from Sutro Tower Digital Television Antennas is contained in Appendix B. Note that next to each topic heading is the section number that corresponds to the topic heading of the Technical Report. Epidemiologic I Occupational Studies (see Appendix B, Sections 3.1 and 3.2) Epidemiologic studies look at relatively widespread disease occurring in a population or community at a particular time. These studies did not conduct experimental research, rather they collected data through interviews, medical records, personal histories, etc. Epidemiologic studies reviewed for this report were all prepared to determine health effects on people. Health effects analyzed included mortality, cancer and brain tumor incidence, and other general health effects. Other epidemiologic studies analyzed whether chronic exposure of mothers to RFR during SwoEIR \ sut 3-) 3-16 07/06197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) pregnancy or of fathers to RFR would cause anomalies or birth defects including Downs Syndrome in their offspring. One epidemiologic study was conducted for possible cancer effects due to RFR from Sutro Tower. (Selvin, et aI., 1992) The Study found no evidence by any ofthree methods that specific childhood cancers were more common near Sutro Tower than elsewhere in the City of San Francisco. Subsequent RF measurements were taken by Dr. Raymond Neutra and Dr. Michael Yost ofthe California Department ofHealth Services who were accompanied by representatives of the community and the San Francisco Department of Public Health. These measurements showed that the study area did not have higher than normal RFR levels. Taken collectively, epidemiologic studies analyzed yielded little or no reliable scientific evidence that chronic exposure to RFR at levels within current exposure guidelines is hazardous to human health or that chronic exposure ofmothers during pregnancy or offathers to RFR at levels at or below federal standards would cause anomalies in their offspring. Thus, the substantial weight of reliable epidemiologic evidence indicates that broadcast transmissions from the Sutro Tower DTV project, which would emit RFR at a maximum of about 14.3 percent of the emissions allowable by the current federal standards at the closest sensitive receptor, are unlikely to cause cancer, birth defects, or other human health effects to people in the general population. RFR and Ocular Changes (see Appendix B, Sections 3.3 and 4.1) Ocular effects means eye damage such as cataracts. Epidemiologic studies based on military records, questionnaires, and surveys have been conducted to ascertain effects on the human eye. Through experimental studies ofretinal examinations, people exposed to radar equipment and to various types of electronic equipment have been compared to people who have not been so exposed. In addition, eye damage to animals has also been studied experimentally. On occasion, accidental exposure to relatively high RFR levels has occurred to workers close to RFR sources, but this would not be anticipated to occur to nearby sensitive receptors. One of the studies reviewed for this EIR reported that when exposure to relatively high RFR levels SUlrO EIR \ sut 3-1 3-17 07106/97 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) occurred, vision was not affected in any of the subjects, although ophthalmologic examinations showed various eye abnormalities. Taken collectively, the studies on potential ocular (eye) effects yielded little or no reliable scientific evidence that chronic exposure to levels of RFR below the federal standards would cause damage to human eyes. The substantial weight of reliable experimental and epidemiologic evidence indicates that broadcast transmissions from the Sutro Tower DTV project which would emit RFR at a maximum ofabout 14.3 percent ofthe emissions allowable by the current federal standards at the closest sensitive receptor is unlikely to cause effects to the eyes of people in the general population. Auditory Effects (see Appendix B, Sections 3.4 and 4.2) Auditory effects means the perception of RFR as audible clicks in the head. Studies have been conducted on both humans and other animals. Experimental evidence indicates that an RFR pulse can produce a temperature difference in the head that is large enough to generate a transient pressure wave. This wave is then transmitted by bone conduction to the middle ear, and is perceived as sound. Persons with impaired hearing are unable to hear such clicks, and animals with nonfunctioning inner ears do not exhibit RFR-pulse-induced responses. Epidemiologic and experimental studies have concluded that the perceived click is not the result ofdirect brain stimulation from RFR, but is a thermal impact ofRFR emissions several thousand times stronger than project emissions at the nearest sensitive receptor. Taken collectively, these studies on potential auditory effects yielded no reliable scientific evidence that chronic exposure to levels ofRFR below the federal standards would cause hearing effects or damage to humans. Thus, the substantial weight of reliable experimental and epidemiologic evidence indicates that broadcast transmissions from the Sutro Tower DTV project that would emit RFR at a maximum of about 14.3 percent of the emissions allowable by the current federal standards at the closest sensitive receptor is unlikely to cause hearing effects to the general population. Sutro EIR \ sut 3-1 3-18 07/06/97 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) RFR Shock and Bum Effects (see Appendix B, Section 3.5) The ANSI/IEEE (1992) Guidelines and FCC 96 Guidelines include maximum exposure limits for avoidance ofRFR shock and bum effects. However, such effects are not relevant to the Sutro Tower DTV project because the proposed DTV frequencies (500-734 MHz) are higher than 100 MHz, the practical limiting frequency for which shock and burn effects occur. Mutations, DNA Altering and Carcinogenic Effects (see Appendix B, Section 4.3) Mutation effects means that mutations to animal cells occur. DNA altering effects means that changes to DNA would occur. Carcinogenic effects means cancer causing effects. Little or no reliable experimental evidence exists that exposure to RFR induces mutations in bacteria, yeast, or fruit flies. Regarding mammalian tissues, some of the studies of carcinogenic effects that yielded negative results (no relationship of disease or death with exposure to RFR) and others that yielded positive results (relationship of disease or death with exposure to RFR) were questionable because ofthe likelihood ofthe presence ofuncontrolled non-RFR factors. Collectively, the various RFR-bioeffects investigations provide little or no reliable scientific evidence that exposure of RFR at levels within current standards produces mutations or DNA altering effects, or that such RFR induces or promotes any form of cancer. Thus, the substantial weight of reliable scientific evidence is that exposure to RFR from the Sutro Tower DTV broadcasts, which would be at a maximum of about 14.3 percent of the federal standards at the closest sensitive receptor, are unlikely to cause any ofthese effects in the general population. Potential Anatomical Aberrations in Developing Fetuses (see Appendix B, Section 4.4) Some studies have analyzed the potential for RFR induced effects on anatomical aberrations in developing fetuses. Anatomical aberrations mean alterations in development and birth defects which occur in fetuses before birth. Experiments on animals indicate harmful changes upon exposure to RFR levels high enough to increase temperature several degrees. One study found that RFR thermal effects yielded lower weights of their live fetuses, but this has not been replicated. For mice, evidence exists that anatomical aberrations would occur only at thermal levels that are close to killing the pregnant females. Sulro EIR \ sut3·j 3-19 07/06/97 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) Thus, the only reported potential anatomical aberrations in developing fetuses are those related to thermal exposure effects of RFR. The project would not result in thermal-related RFR effects. The substantial weight of reliable scientific evidence is that because the project would be at a maximum of about 14.3 percent of the federal standards at the closest sensitive receptor, it is unlikely to cause fetal development effects in the general population. Central Nervous System Effects (see Appendix B, Section 4.5) Central nervous system effects include RFR effects on the blood-brain barrier, the central nervous system, and the brain. Studies have been done on animals. In vitro studies ofthe central nervous system found no effects except when there were exposures at thermal RFR levels. Changes in the central nervous system were seen at relatively low specific absorption rates in two studies, but their significance with regard to possible human health hazards is unclear. Taken collectively with other results that indicated effects ascribable to local increases in brain temperature, it is unlikely that exposure to RFR levels that do not raise local brain temperatures in humans would cause adverse effects. One study (Sanders et al., 1984) found effects in rat brains at 200 MHz and 591MHz~its findings are relevant to the RFR from the Sutro Tower DTV broadcasts which would emit RFR in the 500-734 MHz range. However, as noted in Appendix B, the equivalent power densities used in the study were higher than those currently and proposed to be emitted from Sutro Tower (13.8 milliwatts per square centimeter compared to less than 0.03 milliwatts per square centimeter). Evoked responses are electrical responses in the central nervous system or brain as a result of electrodes, sounds, or flashing lights stimulating brain activity. Little or no reliable scientific evidence exists that evoked responses of people would be affected at Sutro Tower by RFR because levels would be below current exposure guidelines. There are contradictory findings about the RFR-induced calcium-efflux effect (involving altering the amount ofcalcium binding to cells and tissues). Resolution of this issue is not likely in the foreseeable future. This effect, ifvalid, appears to be a non-thermal effect. However, little or no Sutro EIR \ sut 3-1 3-20 07/06197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) reliable scientific evidence exists that any health effects are associated with the calcium efflux effect. The results of one researcher indicate that pulsed and continuous wave RFR affect rat behavior and neurochemistry in the absence ofbiologically important changes in temperature. There is no evidence that the effects observed in these laboratory studies are pathological. It should be noted that the experiments have not been replicated by other researchers. The project would not result in thermal effects nor expose people to power densities greater than allowed by federal guidelines. The substantial weight ofreliable scientific evidence is that because the closest sensitive receptor would be exposed at a maximum of about 14.3 percent of the allowable emissions under the FCC 96 Guidelines, RFR from the project would not result in these possible human health hazards. Effects on the Immune and Blood Systems (see Appendix B, Sections 4.6 and 4.7) Effects on the immune and blood system are effects on white and red blood cells. Experimental studies have been conducted with animals. The most recent studies have shown that where exposure to RFR adversely affected white blood cells or resulted in hemoglobin loss and/or potassium-ion loss, the effects were ofthermal origin (i.e., due to elevation oftemperature). Thus, the only potential effects from RFR exposure on the immune and blood systems are those related to thermal effects. The substantial weight of reliable scientific evidence is that because the project would be at a maximum of about 14.3 percent of the federal standards at the closest sensitive receptor, it would not cause thermal effects in the general population and would not be expected to result in immune or blood system effects. Contrasts among various lifespan studies analyzed involve not only different exposure intensities, but pulsed versus continuous waveforms, various frequency, and various animal species. These differences prevent drawing a general conclusion about effects on lifespan, but there appears to be a tendency towards enhanced lifespan for mildly thermal (elevated temperature) exposures but reduced lifespan when RF exposure is combined with chemical carcinogens. There is little or no reliable scientific evidence for effects on lifespan or immune function at exposure levels below the FCC 96 Guidelines. Sutro EIR \ sut3-1 3-21 07/06197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) Physiology and Biochemistry Effects (see Appendix B, Section 4.8) Physiology and biochemistry effects include those related to the heart, heart rate, body temperature regulation, blood cells, organ functions, and hormones. Experimental studies have been conducted with animals. Various effects ofRFR on the heat regulatory systems ofmammals and on their behavioral responses due to RFR induced thermal effects are evident. Because the effects of RFR on the hormone systems of animals are ascribable to increased body heat, to stresses engendered by the experimental situation, or to both, no clear evidence exists that such effects would occur in humans exposed to RFR at levels which do not produce increases in body temperature. In experimental studies, when non-conducting electrodes were used, heart rates were altered only at RFR levels that yielded rises in temperature or otherwise added thermal burdens to the animal. Little or no valid experimental evidence has been found to suggest that the functions of hearts or specific tissues therefrom are affected by exposure to RFR in the absence oftemperature increases. Various studies in which cardiovascular effects were sought from exposure of live animals to RFR only resulted in impacts at thermal-inducing RFR levels, as evidenced by increased respiratory rates and other manifestations ofheat stress. Also, no relation between blocked blood flow and RFR exposure was found, an indication that humans with heart problems are unlikely to be affected by exposure to RFR at or below the FCC 96 Guidelines maximum allowable levels. Hormone system and heart rate effects, and other cardiovascular effects were altered at only RFR levels that yielded thermal effects. No thermal effects would be anticipated due to project implementation. The substantial weight of reliable scientific evidence is that because the project would be at a maximum of about 14.3 percent of the federal standards at the closest sensitive receptor, it is unlikely to cause such effects in the general population. RFR Effects on Animal Behavior (see Appendix B, Section 4.9) Effects on animal behavior means the potential for an animal to change its behavior as a result of exposure to RFR. Evidence exists that changes in behavioral patterns induced by RFR are due to thermal effects, either to minimize the absorption of heat in normal or warm ambient environments or to obtain warmth in relatively cold environments. Sutro EIR 'aut 3-1 3-22 07/06197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) Little or no reliable experimental evidence exists of adverse effects at heat producing levels that are within the compensatory capabilities ofthe thermoregulatory systems ofthe animals. Ofnote is that reasonably accurate thresholds for RFR-induced behavioral changes were determined for several animal species including, primate species, and that those thresholds served as the primary basis for the ANSI/IEEE (1992) human-exposure guidelines and subsequent FCC 96 Guidelines. The results of studies on disruption of performance or learned behavior by RFR were relatively well-ordered, and findings were consistent with consequences ofthe added thermal burden from RFR exposure. The substantial weight of reliable scientific evidence is that because the project emissions would be at a maximum of about 14.3 percent of the federal standards at the closest sensitive receptor, it would not cause thermal effects in the vicinity of Sutro Tower which would affect animal or human behavior. RFR and Drugs (see Appendix B, Section 4.10) Drug effects include both psychoactive drugs and alcohol-related effects. Experiments were conducted on animals. Investigations that sought interactions between RFR exposure and psychoactive drugs, yielded unclear or inconsistent results. At relatively low RFR levels, the role of heat regulation in the results is unclear and the occurrence of relatively high local specific absorption rates in the brain cannot be ruled out. The studies generally found no synergistic effects (enhanced effects) between alcohol consumption and exposure to RFR except at relatively high doses of alcohol and power densities about 40 times higher than would occur with the project. It seems unlikely that the effects of psychoactive drugs prescribed by physicians or the effects of alcohol consumed recreationally would be altered by exposure to RFR levels below the maximums permitted in FCC 96 Guidelines. Drug-related effects occur, only at power densities much greater than would occur with the project. The substantial weight of reliable scientific evidence is that because the project emissions would be at a maximum of about 14.3 percent of the federal standards at the closest sensitive receptor, it would not be expected to cause drug related RFR effects in the general population. Sutro EIR \ sut 3-1 3-23 07106197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) Cellular and Subcellular Effects (see Appendix B, Section 4.11) Cellular and subcellular effects were studied by experiments on animal cells. In general, research on possible RFR effects on microorganisms or cells derived from macroorganisms is used for eliciting possible mechanisms of direct interaction of RFR with such biological entities or their constituents at nonthermallevels. However, the relevance ofsuch findings (negative or positive) to possible effects of RFR exposure on intact animals and ultimately the significance of such findings with regard to possible hazards ofRFR to humans has not been established. The results of such research to date have not provided any reliable scientific evidence that humans chronically exposed to RFR levels at or below the maximum given in the FCC 96 Guidelines would experience effects to cells. Thus, the substantial weight of reliable scientific evidence is that because the project would be at a maximum ofabout 14.3 percent of the federal standards at the closest sensitive receptor, it is unlikely to cause cellular effects in the general population. Worker Safety Effects The proposed DTV antennas present the same potential health and safety impacts that currently exist at Sutro Tower. (Refer to the worker health and safety section of Section 3.1.3, Environmental Setting.) The levels of RFR would increase on site for an interim period before the NTSC broadcasts cease. Then RFR levels would be less than they currently are. No differences in hazards associated with radio or NTSC television broadcasts would occur with project implementation. Workers following the safety regulations and wearing appropriate safety dress would have the same potential for health effects whether the project was constructed or not. This is because the types of hazards would be identical to current hazards and the potential for impacts to an individual would not change. However, if additional workers access the tower then these new additional workers would be at new risk. In addition, if existing workers access the tower with increased frequency, the potential risk would increase for them. The foreseeable impact would be a potential increase in the frequency or time period to conduct maintenance on the tower due to an increase in the number of antennas. This would continue the need for implementing existing safety procedures. Sutro EIR \ SUI 3-1 3-24 07/06197 Environmental Setting and Impacts 3.1 Radiofrequency Radiation (RFR) In May 1996, radiofrequency protection and elevator use rules were amended in response to past concerns about worker safety. The current safety procedures would be adequate to address potential worker safety impacts at Sutro Tower, as evidenced by the worker safety record at Sutro Tower. REFERENCES Penelope Lincoln, Office Manager, Sutro Tower, Inc., conversation, January 4, 1997. S. Selvin, Ph.D., J Schulman, Ph.D., and D.W. Merrill, Ph.D., "Distance and Risk Measures for the Analysis of Spatial Data: A Study of Childhood Cancers," Soc Sci Med 34(7):769 77, 1992. Sutro Tower, Inc., Documentation ofSafety Meetings, January 1996 to December 1996, (Sutro). Sutro EIR \ suI 3-1 3-25 07/06197 Environmental Setting and Impacts 3.2 Visual Quality 3.2 VISUAL QUALITY 3.2.1 Environmental Setting Sutro Tower is the San Francisco Bay Area's tallest structure, standing 977 feet from its base to the top ofits antennas. Located near the top ofMount Sutro, the television and radio tower reaches a maximum height of 1,811 feet above sea level. The tower is situated within stands of mature Eucalyptus, which partially screens the initial 150 to 200 feet of the tower's base and also its ancillary structures. From some vantage points the tower appears as a relatively large structure set within the urban context and from other points it appears as a lone hilltop tower. (See Figures 6-9, pages 3-29 to 3-32, below.) The tower's height and location also make it visible from surrounding neighborhoods, yet it is often obscured by fog (at least partially), especially on summer days. On clear days, the tower's basic hourglass shape and structural lines can be seen from most of the City and from many points around the Bay. As a relatively large structure on a permanent hilltop, the tower is considered by some to be visually intrusive. With the exception of the University of California at San Francisco Medical Center, nearby neighborhoods are predominantly comprised of single-family houses, relatively small multi family housing structures, and neighborhood-serving commercial facilities. Some structures, particularly around the Twin Peaks area, are detached single-family houses set in a vegetated hillside environment. Most buildings are under four stories and set in the relatively dense urban fabric with varied topography. Numerous well-maintained Victorian and Spanish Eclectic-style structures lend architectural character to nearby neighborhoods, although many unarticulated-box shaped buildings are also found in the neighborhoods. In general, the neighborhood streetscapes are visually rich and tend to draw the eye toward street level activity and building facades, but the tower is noticeable from surrounding areas. From neighborhoods adjacent to Mount Sutro, the tower's details, such as cable tie-downs and cross bracing are noticed upon direct observation. At further distances these elements start to blend in with the sky or the tower's main structural elements The tower starts to be perceived more as an object on the Mount Sutro land mass. SUlro \ visual-3 3-26 01106191 Environmental Setting and Impacts 3.2 Visual Quality The tower, itself - a three-legged, free-standing hourglass-shaped structure - has a number of design features. Considerations of size, form. and function contribute to its visual characteristics. Sutro Tower's total height of 977 feet combines about 767 feet of primary structure (the tower itself) topped by three 207-foot tall antennas. For comparison, the Eiffel Tower is 1,010 feet tall. The tower's legs (trusses clad with steel shingles) are 150 feet apart at the ground and slope inward at five degrees to the waist (the most slender portion) of the tower. At the waist the legs are about 60 feet apart; thereafter, the legs slope outward until reaching the antenna platform. The antennas, placed 100 feet apart, align with the ends of the legs, and appear as prongs directed toward the sky. Five horizontal trusses connect the legs and form five structural bays; although visually the tower appears as four proportional bays, one above the waist and three blow. Cables provide "x shape" lateral bracing at each structural bay and lateral support for each antenna (similar to how ship masts or tent poles are supported). An original concept design which is similar in appearance to the Seattle Space Needle, the Space Needle's designer inspired the final form of Sutro Tower. The original concept had a more slender feel and was intended to be a singular neutral color. The final design was created by the architectural and engineering firm Albert C. Martin & Associates of Los Angeles. The final three-legged design offers greater structural and seismic stability than the earlier design. The relatively distinctive white and international orange color bands were required by the Federal Aviation Administration (FAA). In addition to making the tower more visible to aircraft, the color bands create a graphic quality to the design. The eye is drawn to the orange color bands, while white painted portions of the structure tend to blend in with the sky, especially when the weather is cloudy, foggy, or overcast. The simplicity of the hourglass shape, however, is visually compromised by the busy feel of the unclad orange trusses, which form the antenna's platform, and the number of cables supporting the three antennas. Below the antenna platform, the tower's hourglass form is visually stable. 3.2.2 Visual Quality Effects The project would provide a new beam with the proposed antennas attached between about 630 and 755 feet above the base of the tower. These new DTV antennas would be located SUIrO \ VlSual-3 3-27 07106197 Environmental Setting and Impacts 3.2 Visual Quality between the north and south legs on the east face of the Sutro Tower structure itself, and would not protrude from the tower. As can be seen in Figures 6-9, the beam with the antennas attached would not generally be noticeable. The antenna structure would be the most visible of the changes to Sutro Tower. Thus, in the context of the tower's details such as cross-bracing, cable ties, trusses, and existing antennas, the proposed new set of antennas would be noticeable only upon relatively close inspection, when in proximity to the tower. The new antenna structure would also be painted the same color as the tower. Refer to Figures 6 and 7 for a close-up view of Sutro Tower and a photomontage from the same vantage point. Figure 8 shows a view of Sutro Tower from the comer ofMarket Street and Diamond Street and Figure 9 shows a photomontage from the same location. As can be seen in the photomontages, the antennas that would be added to accommodate the Sutro Tower DTV project would not be readily noticeable, or create a substantial change in the appearance ofthe existing tower. REFERENCES Engineering News Record, January, 11, 1973, page 17 San Francisco History Center, San Francisco Main Library, 6 th floor, various newspaper and magazine clippings on file under Sutro Tower. SUITO \ visual-3 3-28 07/06197 w N 10 Source: Square One Film + Video 6 Figure CLOSE-UP VIEW OF SUTRO TOWER, EXISTING Woodward-Clyde Consultants 961005NA I Sulro Tower DTV EIR Project No. 961005NA-32001040297/wcclgraphlcslgos,mci W I W o Source: Square One Film + Video CLOSE-UP PHOTOMONTAGE OF SUTRO TOWER, WITH DTV ANTENNAS 96 i OCSNA "3200 i D53097 i wcc/graprllcslgos,lnCt - -- ------~---_._-- Project No. j 961005NA Sulro Tower DTV EIR - -_.._-,----------_. _W_~o_d_w_ar_d-_Cly_d~.E.?_ns"!~_ta_nt_s_ Figure 7 J Source: Square One Film + Video Woodward-Clyde Consultants ._- -_?..- 961 005NA·'3200/040297/wccJgraphicsJgos,fIlCI Project No. 961005NA Sutro Tower DTV EIR VIEW OF SUTRO TOWER FROM MARKET STREET AND DIAMOND STREET, EXISTING Figure 8 .) .) ) Source: Square One Film + Video 961 oosNA·3200/063097/wcc!graphicslgos,mcl ~ojectNo. I 961005NA I Sutro Tower DTV EIR L Woodward-Clyde Consultants PHOTOMONTAGE OF SUTRO TOWER WITH DTV ANTENNAS FROM MARKET STREET AND DIAMOND STREET ...L..-.. ._- Figure 9 Environmental Setting and Impacts 3.3 to 3.16: Other Issues 3.3 Compatibility with Existing Zoning and Plans The site is classified as P (public Use) by the City Zoning Maps. The existing facility is permitted to operate at this location under a current conditional use (CD) authorization. An amendment to the CU would not be necessary for the project because the additions proposed include adding an antenna structure and increasing electrical capacity on the site. These additions do not include major remodeling of the tower, expansion of the transmitter room at the base of the tower or a change in use. These alterations and the operation of the new antennas have been determined by the Zoning Administrator to be consistent with the existing permitted use. (passmore, 1988, 1997). The proposed project would also be consistent with the zoning for the site. However, pursuant to City Planning Commission Resolution No. 11399, adopted July 14, 1988, the City Planning Commission will hold a publil;:: hearing to review the proposed project under its Discretionary Review authority Environmental plans and polices are those, like the Bay Area Air Quality Plan, which directly address environmental issues and/or contain targets or standards which must be met in order to preserve or improve characteristics of the City's physical environment. Thecum~ntproposed project would not obviously or substantially conflict with any such adopted environmental plan or policy. The City's Master Plan, which provides general policies and objectives to guide land use decisions, contains some polices which relate to physical environmental issues. The current project would not obviously or substantially conflict with any such policy. In general, potential conflicts with the Master Plan are considered by decision makers independently of the environmental review process, as part of the decision whether to approve or disapprove a proposed project. Any potential conflict not identified here could be considered in that context, and would not alter the physical environmental effects ofthe proposed project. In November 1986, the voters of San Francisco approved Proposition M, the Accountable Planning Initiative, which added Section 101. 1 to the City Planning Code to establish eight Priority Polices. These polices are: preservation and enhancement of neighborhood-serving retail uses; protection of neighborhood character; preservation and enhancement of affordable housing; discouragement of commuter automobiles; protection of industrial and service land uses from commercial office development and enhancement of resident employment and Sutro EIR \ sutJ-3+ 3-33 07/06/97 Environmental Setting ;and impacts 3.3 to 3.16: Other Issues business ownership; maximization of earthquake preparedness; landmark and historic building preservation; and protection of open space. Prior to issuing a permit for any project which requires an Initial Study under CEQA, and prior to issuing a permit for any demolition, or conversion, or change of use, and prior to taking any action which requires a finding of consistency with the Master Plan, the City is required to find that the proposed project or legislation is consistent with the Priority Policies. Goals and policies in the General Plan that relate to the project are discussed in Section 2, Project Description. 3.4 Land Use The site is a four-acre parcel located on the east peak of Mount Sutro. The site had been graded in the past for construction ofthe tower and ancillary structures, and the portion of the site where the facilities are located is relatively level. Existing facilities include the 977-foot high tower, a main building, a garage and storage area, and surface parking. The site is fenced and a guard station is located at the entrance to the facility. Land uses immediately adjacent to the site consist of single-family residences. The area is designated low-density residential in the City's General Plan. Other nearby land uses include open space and neighborhood recreation, community facilities (University of California Medical Center), and some neighborhood commercial uses. Since the project involves no change in use of the existing facility, it would not affe:ct existing land uses nearby or cause any displacement ofexisting or planned land uses. Once the new set ofantennas has been installed, the change at the site would not be apparent (also see discussion ofvisual impacts in Section 3.2, pages 3-27 to 28). No land use impacts on adjacem or nearby properties would be considered likely. 3.5 Population The proposed project would not displace any housing or commercial enterprises and therefore would not displace residents or businesses. During antenna installation, approximately four to six construction-related jobs would be created for about six weeks. No changes to Bay Area Sutro EIR \ sut3-3+ 3-34 07/06197 Environmental Setting and Impacts 3.3 to 3.16: Other Issues population would be anticipated from immigration of workers for these temporary short-term jobs. 3.6 Transportation and Circulation The site is accessible via Dellbrook Avenue and La Avanzada Street. Dellbrook is a residential street that intersects with Clarendon Avenue. La Avanzada Street is a paved, private road that leads to the site, and would be used to access the site to haul the pre-fabricated antenna sections and other assembly materials. About three to four semi-trailer trucks would haul the materials and antennas to the site over one day at the beginning ofthe project. Following that, the only construction-related vehicular traffic to the site would be construction workers' vehicles. The magnitude of this short-term increase would not affect traffic and circulation in the vicinity ofthe site. 3.7 Noise The project area is characterized by moderate nOIse levels. The nearest nOIse sensitive receptors are residents of homes on Dellbrook Avenue, Palo Alto Avenue, and Farview Court. The closest residents are located about 250 feet from the base ofthe tower. Construction activities would generate short-term noise. Relatively high levels of noise would not likely result because construction activities would not include pile driving or the use of impact tools; the loudest anticipated construction noise would be 85 decibels (dBA) at 50 feet from the noise source. In addition, some noise would result from construction trucks that would bring pre-fabricated sections ofthe antennas to the site. Since attachment of the antenna structure would be conducted about 755 feet above ground and the closest sensitive receptor is located about 250 feet from the base of the tower, the closest sensitive receptor to this noise source would be located about 800 feet away. Noise generated during assembly on the tower of 85 dBA (the sound that would be generated by the noisiest anticipated construction equipment) at a distance of 50 feet from the source is expected to lessen (attenuate) to daytime ambient noise levels of about 61 dBA at the nearest Sutro EIR \ sutJ·3+ 3-35 07/06/97 Environmental Setting and Impacts 3.3 to 3.16: Other Issues sensItIVe receptors (residents). I That sound is roughly equivalent to normal speech or a dishwasher at ten feet. With windows closed at the nearest residence, these noise levels from construction would be reduced by about 15 elBA. Attachment of the antenna structure would occur for approximately 6 weeks. Project-related noise would occur during weekdays, and would be limited to daytime hours, in compliance with the San Francisco Noise Ordinance which prohibits construction work at night (from 8:00 p.m. to 7:00 a.m.). The construction contractor would be required to instruct the crews to minimize noise levels to the extent possible and to make sure that all equipment is adequately muflled. Due to the duration of constructiol\ noise impacts would be short-term. Noise impacts would therefore be limited. Wind flowing through Sutro Tower on windy days has been perceived as a loud noise by some residents in the vicinity of Sutro ToweL None of the proposed modifications to the tower would be expected to change this existing noise condition. 3.8 Air Quality/Climate The project would not affect air quality locally or on a regional level. No ground disturbing activities are proposed that could generate dust. The existing road to Sutro Tower is paved and would be used to haul sections of the antenna and structural components to the site; therefore dust emissions would not result from the vehicular traffic. No major construction diesel-powered equipment would be needed at the site that could generate fuel emissions. The proposed antenna structure would be attached about 755 feet above ground surface within the existing Sutro tower structure. Neither it nor the new beam would increase either the height or the bulk ofthe structure. The project would not alter wind, moisture or temperature in the area, or cause any kind of effect on wind direction. 1 The rate of attenuation (lessening of noise) is about six decibels (dBA) for every doubling of distance from a point source. Thus 85 dBA at 50 feet would attenuate to 79 dBA at 100 feet, 73 dBA at 200 feet. 67 dBA at 400 feet, and 61 elBA at 800 feet. .., ..,r Environmental Setting and Impacts 3.3 to 3.16: Other Issues 3.9 Public Sen-ices and Utilities The project would require increased electrical capacity on the site in order to accommodate additional energy to broadcast the DTV signals. Electricity to the site currently is supplied by two 12-kilovolt feeder lines. Each underground feeder line serves a 1,500 kilovoltamp (KYA) electrical transformer on the Sutro Tower site. With project implementation, a second 1,500 KVA transformer would be added to each of the existing underground feeder lines. No additional feeder lines (underground wires) to the site would be added for the project. (PG&E, 1996) Residents in the vicinity of Sutro Tower have complained about interference ofthe television! radio broadcasts with television and radio reception, and with car theft alaml systems. Commercial radio and television broadcasting involve amplitude modulation (AM) or frequency modulation (FM) in which modulation ofthe carrier ("station frequency") is created by the speech, music or picture content of the program. Broadcast modulation contains a constantly changing assortment offrequencies which can lead to the existing interference with television and radio reception, and with car theft alarm systems. DTV uses a form of modulation which is different from both existing forms of AM and FM because both video and audio signals are represented by a digital code. However, the existing interference would not be expected to change with addition ofthe DIV broadcasts. Since the project would have no effect on population, it would not result in any new demands on utilities and services due to population increase. The project would not displace or affect utilities. 3.10 Biological Resources The project would not affect biological resources for two reasons: (1) sensitive biological resources (plant and wildlife species) are not present at the site, and (2) no ground-disturbing activities are proposed for project construction. Environmental Setting and Impacts 3.3 to 3.16: Other Issues 3.11 Geology and Soils The existing tower was constructed on site based on soils and foundation studies conducted by Dames & Moore (Dames & Moore, 1966, 1969). The hill is capped by a fractured and weathered chert formation which tilts steeply downward in a westerly direction. During the 1966 study, chert was encountered in one boring, tightly jointed sandstone in a second, and highly fractured and decomposed sandstone was encountered in a third. Dames & Moore concluded that the rock formations encountered in the test borings would provide adequate support for both downward and uplift loads. According to the pamphlet "Questions & Answers About Sutro Tower" the center of gravity of the tower is 13 feet below the ground due to the weight ofthe concrete foundation. (Sutro Tower, 1991) Construction of the existing self-supporting tower was completed in 1973 and was built in accordance with the 1969 San Francisco Municipal Building Code and the Electronic Industries Association Standards RS-222-A bringing the tower up to current codes to withstand 70 mph basic wind speeds and current earthquake loading standards. (The tower had originally been constructed to withstand 50 mph basic wind speeds.) The tower legs, haunch diagonals, and diagonals are being reinforced to bring the tower structure into compliance with current codes. The existing foundations and seismic loading are adequate and would not require additional reinforcing to the concrete foundations for project implementation. (Kline, 1995) No impacts from earth shaking are considered likely. The project would not affect soils so as to cause soil compaction or erosion because no ground-disturbing activities are proposed 3.12 Water The project would not affect quality and quantity of surface or groundwater resources at the site. The tower is currently painted with water-resistant paints that are not known to leach into surface water during storm events. The new set of antennas and beam would be similarly treated, and would therefore not be expected to affect surface water quality. Since no ground disturbance is proposed, water quality impacts from eroSIon and sedimentation would not likely occur. To avoid discharge of oil or other pollutants from any Environmental Setting and Impacts 3.3 to 3.16: Other Issues construction equipment on site, the construction contractor would be required to check and conduct maintenance on all equipment before bringing these to the site. Water quality impacts during construction would therefore be unlikely. 3.13 Energy / Natural Resources The project would use between 1,000 and 1,500 KVA of energy for project operation. Broadcasts from Sutro Tower currently use about 3,040 KVA ofenergy. The transformers are designed to be able to safely handle about 50 percent more KVA than their stated sizes. (pG&E, 1996). Because federal regulation is anticipated to require dual broadcasting of NTSC and DTV signals, this operational use would not be considered wasteful. Once dual broadcasting ceases, then energy use would drop back to approximately current levels. The project would use fuel to haul materials to the site and to operate construction equipment. The limited use of energy resources (mostly gasoline and diesel) for project installation would not be considered a wasteful use. The use of other natural resources would not occur. 3.14 Cultural Resources The site has been disturbed by construction in the past, in particular to build Sutro Tower and its ancillary buildings. There is no record of historical or archaeological resourct::s a the site. Impacts to cultural resources are also considered unlikely because the project would not involve ground disturbing activities. 3.15 Growth Inducing Effects The project would add new television antennas to broadcast duplicate signals for each television station. No secondary growth would be anticipated due to this project. Regarding installation effects, no changes to Bay Area population would be anticipated for the temporary short-term jobs. Sutro EIR \ sut3-3+ 3-39 07/06/97 Environmental Setting and Impacts 3.3 to 3.16: Other Issues Additional electric capacity would be accommodated by adding a new transformers to existing 12 kilovolt feeder lines. The transformers would be able to accommodate the project only, and not other additional growth. The project would be installed in a developed urban area., and no expansion to the municipal infrastructure not already under consideration would be required to accommodate new development and increased employment due to, or induced by, the project. 3. 16 Hazardous Materials The project would not affect any potential subsurface hazardous materials that could exist on site because no subsurface construction would occur. Relatively minor amounts of hazardous substances such as paints and cleaners would be used for installing the antennas. Because these substances would be used by qualified construction personnel versed in OSHA safety regulations, they would not be anticipated to result in impacts. Operation of the tower would emit radiofrequency radiation which is discussed in Section 3.1 oftrus EIR. REFERENCES PG&E, Mark Feiling, Industrial Power Engineer, telephone conversation,Decemb(~rla, 1996. Donald F. Javete, Dames & Moore, "Soils Investigation, Proposed Television Transmitter Tower, Mount Sutro, San Francisco, California, for the American Broadcasting Company," January 21, 1966. (Dames & Moore) Donald F. Javete, Dames & Moore, "Foundation Investigation, Proposed Transmitter Facilities, Mount Sutro, San Francisco, California, for the American Broadcasting Company," July 24, 1969. (Dames & Moore) 'Ll1(\ Environmental Setting and Impacts 3.3 to 3.16: Other Issues Jean-Alain LeCordier, P.E., "HDTV Analysis of Sutro Tower, San Francisco, California," Kline Towers, Division of Kline Iron & Steel Co., Inc., Columbia, SC, February 28, 1995. (Kline) Robert Passmore, Zoning Administrator, San Francisco Department of City Planning, telephone conversation, February 10, 1997 Sutro Tower, Inc., "Questions & Answers About Sutro Tower," 1991. Sutro EIR \ sut3-3+ 3-41 07/06/97 4.0 MITIGATION MEASURES Although no mitigation measures would be necessary because no potentially significant effects have been identified, some actions are required by law which would serve to reduce potential impacts of the project. These include: complying with the FCC 96 Guidelines, Federal Communications Commission (FCC) and CaVOSHA limits for public and personnel exposure to RFR, and CAL/OSHA worker safety regulations. Sutra EIR \ sut-4 4-1 07106197 5.0 SIGNIFICANT ENVIRONMENTAL EFFECTS THAT CANNOT BE AVOIDED IF THE PROPOSED PROJECT IS IMPLEMENTED In accordance with Section 21067 of the California Environmental Quality Act (CEQA), and with Section 15040, 15081 and 15082 of the State CEQA Guidelines, the purpose of this chapter is to identify impacts that could not be eliminated or reduced to an insignificant level by mitigation measures included as part of the proposed project, or by other mitigation measures that could be implemented, as described in Chapter 5, Mitigation Measures. The findings of significant impacts are subject to final detennination by the City Planning Commission as part ofits certification process for the EIR. This chapter in the Final EIR will be revised, ifnecessary, to reflect the City Planning Commission's findings. The proposed project would not result in any potentially significant effects that could not be avoided ifthe project is implemented. Sutro EIR \ sut-S 5-1 07/06197 (I) m o -t (5 Z aI 6.0 ALTERNATIVES 6.1 INTRODUCTION This chapter identifies alternatives to the proposed project and discusses environmental impacts associated with these alternatives The project sponsor's reasons for rejecting the alternative in favor 0 the project are also presented. Regardless of the sponsor's reasons for rejection, the City Planning Commission could disapprove building permits, and recommend that the sponsor consider other alternatives. The Commission does not have jurisdiction over regulation of antennas or DTV station broadcasts from Sutro Tower. The FCC has purview over all television antennas and broadcasts. In formulating project alternatives, the CEQA standard of analyzing alternatives that would lessen potentially significant project effects and whose effects can be reasonably ascertained was considered. However, the project would not result in any significant environmental effects. Thus no alternatives were formulated regarding significant effects. Off-site alternatives were considered in this analysis, based upon whether another site could feasibly deliver DTV signals to the required service community. 6.2 NO PROJECT ALTERNATIVE Description This alternative would entail no immediate change to the site or to Sutro Tower. The proposed additional antennas would not be brought to the site for installation on the tower, and the electrical system would not be upgraded. Eventually Sutro Tower would no longer broadcast television signals, because once the FCC determines that NTSC signals are no longer to be broadcast, then Sutro Tower would not continue broadcasting the signals. Sutro EIR \ sut-6 6-1 07/06/97 6.0 Alternatives Impacts If the No Project Alternative was implemented, some of the impacts associated with the project could occur while others would be avoided. Sutro Tower would continue as a visible presence in the neighborhood. It would continue to operate and to emit existing levels ofRFR into the vicinity of the Tower, until such time as the FCC decides to discontinue NTSC television broadcast signals. It is unknown whether operation ofthe radio stations alone would be able to pay the operating costs of Sutro Tower. The possibility exists that once the NTSC television broadcasts cease, Sutro Tower would be utilized for other pennitted communication uses or would shut down. Effects from demolishing the tower may then result. On-site impacts would temporarily be less at Sutro Tower ifthe DTV antennas were not added to the tower. Temporary installation noise impacts would not occur on the Sutro Tower site, nor would installation impacts due to traffic and air quality. Temporary construction jobs for installing the antenna would also not occur. No impacts would occur due to operation of either this alternative or the project on the following: land use, population, transportation, noise, air quality, public services and utilities, biology, water, hazardous materials, energy, geology, seismicity and soils, cultural resources, and growth inducing effects. (please refer to Figures 6 to 9 in Section 3.2.2, Visual Quality Effects, pages 3-29 to 3-32), would not occur with this alternative. If Sutro Tower was not utilized for any other communication use, RFR emissions would be less with this alternative, than with the proposed project. If Sutro Tower was reutilized for other pennitted communication uses with this alternative, then RFR emission could be the same as from the DTV project, increase, or decrease, depending upon the technological use. If Sutro Tower was to be demolished, then the emission of RFR would be less with this alternative. Sutro EIR \ sut-6 6-2 07/07/97 6.0 Alternatives Project Sponsor's Reasons for Rejection This alternative was rejected by the project sponsor because it would not attain the project's fundamental objective, of preparing Sutro Tower to provide concurrent DTV and NTSC broadcast signals in an effort to comply with FCC rules. In the sponsor's opinion, the television stations would cease operating at Sutro Tower once the NTSC signals were no longer broadcast, :and San Francisco would no longer be the primary city of license for the television stations. In the event that the No Project Alternative is implemented, in order to follow FCC rules, an alternative site would need to be chosen and a new broadcast tower would likely need to be constructed. Please refer to Section 6.3 below for the sponsor's reasons for rejecting an off-site alternative. 6.3 OFF-SITE ALTERNATIVES Regulatory Framework / Description FCC Rules, Section 73. 685(b) states that "Location of the antenna at a point of high elevation is necessary to reduce to a minimum the shadow effect on propagation due to hills and buildings which may reduce materially the intensity of the station's signals. In general, the transmitting antenna of a station should be located at the most central point at the highest elevation available .... The location should be so chosen that line-of-sight can be obtained from the antenna over the principal community to be served _..." Due to the nature of radiofrequency, antennas broadcasting television signals need to be sited at relatively high locations. Television signals follow a virtual line-of-sight path from broadcasting antenna to television receiver. Especially at UHF frequencies, these signals do not readily bend around solid obstacles. Thus any hills or highrise building between the antennas and the receivers (television sets) would impair, and possibly block reception of the broadcast signals. Television antennas tend to be located at the highest natural site close to the city of license so that the television broadcasts can be received by television sets. The FCC requires that a certain level ofservice be maintained in the city oflicense (FCC Rules, Section 73.685(a». No major obstructions may exist in the path ofthe broadcast signal, and service to the city must be Sutro EIR \ sut-6 6-3 07106197 6.0 Alternatives by direct signal. Relays or booster facilities may not be used to achieve the required level of service. In the San Francisco Bay Area, three of the highest sites are currently used for television broadcasting: Sutro Tower, San Bruno Mountain, and Mount Diablo. In addition to a relatively high natural site, towers are usually constructed from which the television signals can be broadcast. The towers help to insure that receivers (televisions) would not have reception blocked due to hills or highrise buildings. Signals broadcast from Sutro Tower, San Bruno Mountain, and Mount Diablo are not interchangeable because oftheir distance from each other and the cities oflicense. New DTV channel allotment rules specify that each station's DTV transmitting antenna location must be within 5 kilometers ofthe existing NTSC transmitter sites (FCC Rules, Rules, Section 73. 622(d)(1), 47 C.F.R. Section 73.622). Exemptions apply to this rule which may be used for alternatives located farther than 5 kilometers, if an engineering study can show that there will be no additional interference to any other station. Regarding the Mount Diablo alternative, currently Channel 42, which is licensed to Concord, and Channel 64, which is licensed to Stockton, are the only two television broadcast stations on Mount Diablo. Signals from Mount Diablo would come into San Francisco at about a 2 0 angle, while signals from Sutro Tower arrive from at about 4 0 to about 90 0 making the signals more likely to be received without blockage within San Francisco. Mount Diablo would not be an acceptable alternative location for the DTV antennas because some Sutro Tower stations cannot broadcast from that site without interfering with signals from Sacramento stations and thereby may violate FCC non-interference requirements. In addition, Mount Diablo would not be an acceptable alternate location for the DTV antennas because Oakland and other East Bay cities would be shadowed from direct reception of signals broadcast from Mount Diablo. Regarding a San Bruno Mountain alternative, because of proximity of San Bruno Mountain to the San Francisco International Airport, the tower heights for the antennas are limited to 325 feet due to concerns by the Federal Aviation Administration (FAA). NTSC broadcasts from San Bruno Mountain would therefore be unable to adequately serve San Francisco residents for all television stations. (Watson, 1997) A map in a report from John F.X. Browne & Sutro EIR \ sut-6 6-4 07/06197 6.0 Alternatives Associates, shows that residents on the far side of Mount Sutro would not be able to receive NTSC Broadcasts for one of the three stations analyzed (Browne, 1993) This same report shows that for these three stations, DTV signals from San Bruno Mountain would be able to serve all of San Francisco. Because antennas on San Bruno Mountain could not adequately broadcast NTSC signals to all neighborhoods of San Francisco, NTSC broadcasts would continue from Mount Sutro under this alternative until NTSC broadcasts were stopped by the FCC, while DTV signals would be broadcast from San Bruno Mountain. This could entail each of the television stations to have additional personnel and test equipment monitoring the broadcasts. This alternative would include construction ofone or more approximate 325-foot tall towers in the vicinity of the existing broadcasting tower on San Bruno Mountain on which DTV antennas would be installed. Mount Davidson and Twin Peaks were ruled out as possible alternative sites due to potential land use conflicts, and also because it was determined not be practicable to demolish Sutro Tower and construct another tower at a new location so close to the existing site Impacts If the DTV antennas were installed on San Bruno Mountain, then the television stations now broadcasting from Sutro Tower would likely move their NTSC antennas to the same new location for cost savings of personnel, and/or they would possibly remove them after the FCC no longer required dual broadcasts ofDTV and NTSC signals. Thus eventually Sutro Tower could have no television stations broadcasting signals, only the radio stations. It is unknown whether operation ofthe radio stations alone would be able to pay the operating costs of Sutro Tower. The possibility exists that once the NTSC television broadcasts ceased, that Sutro Tower would be utilized for other permitted communication purposes or shut down. Effects from demolishing the tower could then result. Ifan off-site alternative was constructed and implemented, impacts identified for the proposed project at Sutro Tower would instead occur at the alternative site location. For example on Sutro EIR \ sut-6 6-5 07/06197 6.0 Alternatives San Bruno Mountain, new towers would need to be constructed, while at Sutro Tower the existing tower could remain in use. All on-site construction-related impacts identified for the Sutro Tower area under the proposed project would instead be experienced at the alternative location on San Bruno Mountain. There would also be temporary construction impacts for building a new tower or towers on San Bruno Mountain. Temporary installation noise impacts would not occur on the Sutro Tower site, nor would installation impacts due to traffic and air quality. Temporary construction jobs in San Francisco installing the antenna would also not occur. No impacts would occur due to operation of either this alternative or the project on land use, population, transportation, noise, air quality, public services and utilities, biology, water, hazardous materials, energy, geology, seismicity and soils, cultural resources, and growth inducing effects. Visual changes to the tower (please refer to Figures 6 to 9 in Section 4.3, Visual Quality Effects, pages 3-29 to 3-32), would not occur with this alternative. Near the likely site of a new tower at San Bruno the maximum RFR levels would rise from about 22.7 to 34.4 percent of the FCC 96 Guidelines, an increase of 11.7 percent of the guidelines. This contrasts with the increase in maximum RFR levels near Sutro Tower from 12.7 to 14.3 percent of the FCC 96 Guidelines, an increase of 1. 6 percent of the guidelines. San Bruno Mountain is surrounded by public open space, and residential land uses are not located as close as for Sutro Tower. Other impacts associated with tower construction and/or antenna installation would also occur on the alternative site. These impacts would be temporary, and would likely fall within the range ofimpacts typically associated with small- to medium-scale construction projects. Long term visual impacts would not be substantial since other towers and antennas already existing on San Bruno Mountain. Impacts related to the project would not occur at Sutro Tower with this alternative. In addition, San Francisco would have no jurisdiction over this alternative. Sutro EIR \ sut-6 6-6 07/06197 6,0 Alternatives Project Sponsor's Reasons for Rejection This alternative was rejected by the project sponsor because it would not attain the project's fundamental objective, of preparing Sutro Tower to provide concurrent DTV and NTSC broadcast signals in an effort to comply with FCC rules, The project sponsor further believes that it would not be possible to satisfy the project objective by attempting to implement Digital Television at an alternate project site for the following reasons among others: 1. Consistent with the FCC's finding in its initial authorization of the eXlstmg Sutro Tower site, there is no equivalent alternative site for relocation of this large group of San Francisco-based television stations, and any alternative sites are inferior in their suitability for television broadcasting by San Francisco stations due to: (1) inability to provide adequate facilities for all ten TV stations now at Sutro Tower; (2) being non centrally located; (3) being at lesser relative elevation; (4) providing lesser household coverage over the geographically varied terrain of the San Francisco area due to signal blocking, degradation and reflection by surrounding land forms; and (5) presenting greater potential hazards to airspace navigation In this connection, the Sutro Tower location for the ten existing Sutro Tower, Inc, stations optimally satisfies the FCC's transmitter location specifications, as set forth in Section 73,685(b) ofthe FCC's Rules: "Location ofthe antenna at a point ofhigh elevation is necessary to reduce to a minimum the shadow effect on propagation due to hills and buildings which may reduce materially the strength of the station's signals, In general, the transmitting antenna of a station should be located at the most central point at the highest elevation available To provide the best degree of service to an area, it is usually preferable to use a high antenna rather than a low antenna with increased transmitter power. The location should be so chosen that line-of sight can be obtained from the antenna over the principal community to be served; in no event should there be a major obstruction in this path The antenna must be constructed so that it is clear as possible of surrounding buildings or objects that would cause shadow problems, It is recognized that Sutro EIR \ sut-6 6-7 07106197 6.0 Alternatives topography, shape of the desired service area, and population distribution may make the choice of a transmitter location difficult." 2. The FCC's DTV implementation plan contemplates the interim, temporary concurrent broadcasting ofboth DTV and NTSC signals by television stations for a short period of years, followed by the termination ofNTSC television program broadcasting in favor of DTV-only television broadcasting. Thus, location of DTV broadcasting at an alternative site could render Sutro Tower useless within a few years for its principal function of television broadcasting depriving Sutro Tower, Inc. of its substantial property and investment value. 3. Even if there was an adequate or satisfactory alternate site, which in the sponsor's opinion there is not, to locate the DTV broadcast operation of Sutro Tower, Inc. television stations at the alternative site would require numerous regulatory, legal and construction-related approvals, activities and resulting delays, including but not limited to the following: (I) each individual television station would need to engineer the alternate location, apply for an FCC license at that location, secure necessary land use permits and approvals and other local, state, and feral permits, licenses and authorization; and (2) a new broadcast tower or towers would need to be designed, permitted" approved, and constructed. It is unlikely that these activities could be undertaken and completed in the short time frame specified by the FCC for DTV broadcasting to begin, therefore forcing Sutro Tower, Inc.'s San Francisco television broadcast stations to violate the FCC's DTV implementation rules and requirements. When the Sutro Tower project itself was first undertaken in the 1960s, the time consumed in the permitting, approval and construction process extended for many years, and it was not until 1973 that actual broadcasting was able to begin at Sutre Tower. Given the evolution of land use law and regulation since that time, and the possible need for more than one additional tower at more than one alternative site to be constructed, the time to complete such a project now could only be substantially greater. In addition, DTV studies indicate that the greatest national impediment to stations' compliance may be the need for construction of new broadcast towers for DTV use Sutro ErR \ sut-6 6-8 07/06/97 6.0 Alternatives where needed, because there are over 1,500 U.S full power TV stations operating, but fewer than five tower contractor companies in the U.S. which are technically capable of building tall TY towers. Sutro Tower, Inc.'s project objective eliminates any need for new tower construction, whereas any project alternative is expected to require new construction and thus this additional substantial delay with likely resulting FCC rule violations as to the DTY deadlines. 4. Providing for DTV implementation at Sutro Tower as contemplated by the sponsor's intended project will not require the construction of any new tower, nor any increase in the height of the existing tower. Rather, it will require only the attachment to the existing tower of a single, integrated stack antenna for all DTV stations, and related tower strengthening and reinforcement to accommodate the additional antenna mounting. In contrast , as noted, any alternative site for the project will likely require the construction or substantial enlargement of tower facilities at the alternative sites(s). Thus any project alternative would, in its elf, necessarily create substantially greater environmental impacts than the modest modification required for Sutro Tower to accommodate the new DTV antenna unit REFERENCES Jay Watson, President, Watson Communications, telephone conversation, January, 30, 1997. John F.x. Browne & Associates, "HDTV Coverage Analyses San Francisco Market," July 1993. Sutro EIR \ sut-6 6-9 07/06/97 FEDERAL AND STATE AGENCIES Northwest Information Center California ArchaeologIcal Inventory Department ofAnthropology Sonoma State University Rohnert Park, CA 94928 Attn: Christian Gerike California Department ofTransportation Transportation Planning P.O. Box 23660 Oakland, CA 94623-0660 Attn: GarvAdams REGIONAL AGENCIES Association ofBay Area Governments P.O. Box 2050 Oakland. CA 94604 Attn: Sally Germain Regional Water Quality Control Board 2101 Webster Street Oakland. CA 94612 Attn: Steven Hill CITY AND COUNTY OF SAN FRANCISCO Department ofBuilding Inspection 1660 Mission Street San Francisco, CA 94103 Attn: Frank Chiu, Superintendent Landmarks Preservation Advisory Board 1660 Mission Street San Francisco, CA 94103 Attn: Mark Paez Mayor's Office ofCommunity Development 25 Van Ness Ave., Suite 700 San Francisco, Ca 94102 Attn: Pricilla Watts i.O DRAFf EIR DISTRIBUTION LIST Marcia Rosen, director Mayor's Office ofHousing 25 Van Ness Ave. # 600 San Francisco. CA 94102 Bureau ofEnergy Conservation Hetcb Hetcby Water & Power 1155 Market Street, 4th Floor San Francisco, CA 94103 Attn: John Deakin, Director Public Utilities Commission 1155 Market Street San Francisco, CA 94102 Attn: Anson B. Moran, General Manager Recreation & Park Department McLaren Lodge, Golden Gate Park Fell and Stanyan Streets San Francisco, CA 94117 Attn: Deborah Leamer Police Dept., Planning Division Hall ofJustice 850 Bryant Street San Francisco. CA 94103 Attn: Lt. James Molinari San Francisco City Planning Commission 1660 Mission Street San Francisco, CA 94103 Attn: Linda Avery, Secretary Susan Lowenberg Hector Chinchilla Cynthia Joe Larry Martin Beverly Mills Dennis Antenore Richard Hills Division ofGeneral Engineering Services 30 Van Ness Avenue, 5th Floor San Francisco, CA 94102 Sutro EIR \ sut-7 7-1 07/06/97 San Francisco Department ofPublic Works Bureau of Street Use and Mapping 875 Stevenson Street, Room 465 San Francisco, CA 94103 Attn: Denise Brady San Francisco Department ofParking & Traffic Traffic Engineering Division 25 Van Ness Avenue San Francisco, CA 94102 Attn: Bond Yee San Francisco Fire Department Division of Planning & Research 260 Golden Gate Avenue San Francisco, CA 94102 Attn: Howard L. Slater San Francisco Municipal Railway MUNI Planning Division 949 Presidio Avenue, Room 204 San Francisco, CA 94115 Attn: Peter Straus San Francisco Real Estate Department 25 Van Ness Avenue, 4th floor San Francisco, CA 94102 Attn: Anthony Delucchi, Director ofProperty Water Department Distribution Division 425 Mason Street San Francisco, CA 94102 Attn: Hans Bruno, Assistant Manager San Francisco Dept. ofHealth Bureau ofEnvironmental Health 1390 Market Street, Suite 822 San Francisco, California 94102 Attn: Richard Lee San Francisco Dept. ofElectricity & Telecommunications 901 Rankin Street San Francisco, CA 94124 Attn: Edward Harrington Sutro EIR \ sut-7 7-2 7.0 Draft EIR Distribution List GROUPS AND INDIVIDUALS AIA San Francisco Chapter 130 Sutter Street San Francisco, CA 94104 Attn: Bob Jacobvitz Richard Mayer Artists Equity Assn. 27 Fifth Avenue San Francisco, CA 94118 William F. Dietrich Baker & Mckenzie Two Embarcadero Center 24th Floor San Francisco, CA 94111 John Bardis Sunset Action Committee 1501 Lincoln Way, #503 San Francisco, CA 94122 Alice Suet Barkley, Esq. 30 Blackstone Court San Francisco, CA 94123 Bay Area Council 200 Pine Street.Suite 300 San Francisco, CA 94104-2702 Albert Beck Eco/Plan International 310 B Salem Street Chico, CA 95928 Breitman Co. 120 Howard Street, Suite 440 San Francisco, CA 94105 Attn: Frank Young Georgia Brittan 870 Market Street, Room 1119 San Francisco, CA 94102 07/06/97 Brobeck, Phleger, Harrison One Market Plaza San Francisco. Ca 94105 Attn: Susan R. Diamond Cahill Contractors. Inc. 425 California Street, Suite 2300 San Francisco. CA 94104 Attn: Jay Cahill Chicago Title 388 Market Street, 13th Floor San Francisco, CA 94111 Attn: Carol Lester Chickering & Gregory 615 Battery Street, 6th Floor San Francisco, CA 94111 Attn: Ken Soule Chinato\\n Resource Center 1525 Grant Avenue San Francisco. CA 94133 David Cincotta 1388 Sutter Street, Suite 900 San Francisco. Ca 94102 Coalition For San Francisco Neigborhoods Mrs. Dorice Murphy 175 Yukon Street San Francisco, CA 94114 Cushman & Wakefield ofCalifornia, Inc. Bank of America Center 555 California Street, Suite 2700 San Francisco, CA 94104 Attn: Wayne Stiefvater, Lawrence Farrell Catherine DeVincenzi 22 Iris Ave. San Francisco CA 94118 Goldfarb & Lipman One Montgomery Street West Tower, 23rd Floor San Francisco, CA 94104 Attn: Paula Crow Sutro EIR \ sUI-7 7-3 7.0 Draft EIR Distribution List Do\\nto\\TI Association 582 Market Street San Francisco, CA 94105 Michael Dyett Blayney-Dyett 70 Zoe Street San Francisco. CA 94103 EIP Associates 601 Montgomery Street, Suite 500 San Francisco, CA 94111 Enviromnental Science Associates. Inc. 301 Brannan St.. Suite 200 San Francisco, CA 94107 Fan & Associates, Architecture & Planning, Inc. 580 Market Street, Suite 300 San Francisco, CA 94104 Attn Robert Fan Farella. Braun & Martel 235 Montgomery Street San Francisco. CA 94104 Attn: Sandra Lambert Food and Fuel Retailers For Economic Equality 770 L Street. Suite 960 Sacramento, CA 95814 Attn: Doug Stevens, State Coordinator The Foundation for SF's Architectural Heritage 2007 Franklin Street San Francisco, CA 94103 Attn: David Bahlman, Executive Director Gladstone & Vettd, Attorneys at Law 177 Post Street, Penthouse San Francisco, CA 94108 Attn: Steven L Vettel Gensler and Associates 550 Kearny Street San Francisco, CA 94103 Attn: Peter Gordon 07/06/97 Greenwood Press, Inc. P.O. Box 5007 Westport, Conn 06881-9900 Attn: Eric LeStrange Gruen. Gruen & Associates 564 Howard Street San Francisco. CA 94105 Valerie Hersey Munsell Brown 950 Battery San Francisco, CA 94111 Sue Hestor Attorney at Law 870 Market Street, Room 1121 San Francisco, CA 94102 The Jefferson Company 3652 Sacramento Street San Francisco, CA 94118 KaplanlMcLaughlinlDiaz 222 Vallejo Street San Francisco, CA 94111 Attn: Jan Vargo Ernest Kohn 497 Dellbrook Ave. San Francisco, CA 94131 George Linn 53 Aquavista Way San Francisco, CA 94131-1232 Larry Mansbach 44 Montgomery Street San Francisco, CA 94104 Mrs. G. Bland Platt 362 Ewing Terrace San Francisco, CA 94118 Dennis Purcell Coblentz, Caben, McCabe and Breyer 222 Kearny Street, 7th Floor San Francisco, Ca 94108 C' .....-.... I:'JD \ ...... -, 7-4 7.0 Draft EIR Distribution List CliffMiller 970 Chestnut Street, #3 San Francisco, CA 94109 Morrison & Foerster 345 California Street San Francisco, CA 94104 Attn: Jacob Herber Steve Nahm MTHOA 282 DeUbrook Ave. San Francisco, CA 94131 National Lawyers Guild 558 Capp Street San Francisco, CA 94110 Attn: Regina Sneed Nichols-Bertn2U1 142 Minna Street San Francisco, CA 94105 Attn: Louise Nichols Page & Turnbull 724 Pine Street San Francisco, CA 94109 Patri-Burhage-Merken 400 Second Street, Suite 400 San Francisco, CA 94107 Attn: Marie Zeller Perini Corporation 75 Broadway San Francisco, CA 94111 Attn: Christopher Scales Pillsbury, Madison & Sutra PO. Box 7880 San Francisco, CA 94120 Attn: Maril)1l L. Siems Planning Analysis & Development 50 Francisco Street San Francisco, CA 94133 Attn: Gloria Root San Francisco Building & Construction 07/06/97 RamsaylBass Interest 3756 Grant Avenue. Suite 301 Oakland, CA 94610 Attn: Peter Bass James Reuben Reuben & Alter 655 Montgomery St., 16th Floor San Francisco, CA 94111 Capital Planning Dept., UCSF 145 Irving Street San Francisco, CA 94122 Attn: Bob Rhine David Rhoades & Associates 400 Montgomery Street, Suite 604 San Francisco. CA 94104 Herb Lembcke. FAlA Rockefeller & Assoc. Realty L.P. Four Embarcadero. Suite 2600 San Francisco, CA 94111-5994 Rothschild & Associates 244 California Street, Suite 500 San Francisco. CA 94111 Attn: Thomas N. Foster Royal Lepage Commercial Real Estate Services 353 Sacramento Street, Suite 500 San Francisco, CA 94111 Attn: Richard Livermore San Francisco Beautiful 41 Sutter Street, #709 San Francisco, CA 94104 Attn: Donna Casey, Exec. Director Solem & Associates 545 Mission Street San Francisco, CA 94105 Attn: Olive Lewis Square One Film & Video 725 Filbert Street San Francisco. CA 94133 C' .....__ 1:"Tn \ _??? .., 7.0 Draft EIR Distribution List Trades Council 2660 Newhall Street. # 116 San FranCISCO. CA 94124-2527 Attn: Stanley Smith San Francisco Chamber ofCommerce 465 California Street San Francisco, CA 94104 San Francisco Labor Council 660 Howard Street San Francisco, CA 94105 Attn: Walter Johnson San Francisco Planning & Urban Research Assoc. 312 Sutter Street San Francisco, CA 94108 San Francisco Tomorrow 54 Mint Street, Room 400 San Francisco, CA 94103 Attn: Tony Kilroy John Sanger, Esq. 1 Embarcadero Center, 12th Floor San Francisco. CA 94111 Sierra Club 730 Polk Street San Francisco. CA 94109 Sedway Cooke Associates 300 Montgomery Street, Suite 200 San Francisco. CA 94104 Shartsis Freise & Ginsburg One Maritime Plaza, 18th Floor San Francisco, CA 94111 Attn: Dave Kremer Skidmore, Owings & Merril 333 Bush Street San Francisco, CA 94104 Attn: John Kriken Jerry Tone, Montgomery Capital Corp. 244 California St. San Francisco. CA 94111 07106197 Ramona Albright Twin Peaks Council 120 Graystone Terrace San Francisco, CA 94114 Doris Linnenbach Twin Peaks Improvement 155 St. Germaine Ave. San Francisco, CA 94114 Kent Bach, President Twin Peaks Improvement Assoc. P.O. Box 31002 San Francisco. CA 94131 Elizabeth Kantor, Co-President Twin Peaks East Neighbhd Assn. P.O. Box 14025 San Francisco, CA 94114 Jon Twitchell Associates 4419 Moraga Ave. Oakland, CA 94611 Joel Ventresca 1278 44 th Avenue San Francisco, CA 94122 Stephen Weicker 899 Pine Street, # 1610 San Francisco, CA 94108 Steefe1, Levitt & Weiss 199 - 1st Street San Francisco. CA 94105 Attn: Robert S. Tandler Calvin Welch, Council ofCommunity Housing Organizations 409 Clayton Street San Francisco, CA 94117 Eunice Willette 1323 Gilman Avenue San Francisco, CA 94124 Sutro EIR \ sut·7 7-6 7.0 Draft EIR Distribution List Bethea Wilson & Associates Art In Architecture 2028 Scott, Suite 204 San Francisco, CA 94115 Belinda Greene One Maritime plaza Suite 300 San Francisco, CA 94111 Pat Vaughay 2742 Baker Street San Francisco, CA 94123 John Bam: 1627 - 10 th Ave. San Francisco, CA 94122 Margaret Verges 3041 Pine Street San Francisco, CA 94115 Edith McMillan 647 - 28 th Avenue San Francisco, CA 94121 MEDIA Associated Press 1390 Market Street, Suite 318 San Francisco, CA 94102 Attn: Bill Shiffman San Francisco Bay Guardian 2700 - Nineteenth Street San Francisco, CA 94110 Attn: Patrick Douglas, City Editor San Francisco Business Times 275 Battery Street, Suite 940 San Francisco, CA 94111 Attn: Tim Turner San Francisco Chronicle 925 Mission Street San Francisco, CA 94103 Attn: Elliot Diringer 07/06/97 San Francisco Examiner P.O. Box 7260 San Francisco, CA 94120 Attn: Gerald Adams The Sun Reporter 1366 Turk Street San Francisco, CA 94115 Tenderloin Times 146 Leavenworth Street San Francisco, CA 94102 Attn: Rob Waters LIBRARIES Document Library City Library - Civic Center San Francisco, CA 94102 Attn: Kate Wingerson Stanford University Libraries Jonsson Library ofGovernment Documents State & Local Documents Division Stanford, CA 94305 Government Publications Department San Francisco State University 1630 Holloway Avenue San Francisco, CA 94132 Hastings College ofthe Law - Library 200 McAllister Street San Francisco, CA 94102-4978 Institute ofGovernment Studies 109 Moses Hall University of California Berkeley, CA 94720 ABUTTING PROPERTY OWNERS San Francisco Real Estate Department 25 Van Ness Avenue, Suite 400 San Francisco, California 94102 "7-7 7.0 Draft EIR Distribution List Occupant 562 Dellbrook Avenue San FranCISCo, California 94131 Mr. and Mrs. James Singares 240 Palo Alto Avenue San Francisco, California 94114-2123 Pacific Coast Construction Company 1655 Southgate Avenue Daly City, California 94015-2303 Mr. and Mrs. James Finn 590 Dellbrook Avenue San Francisco, California 94131-1161 Occupant 532 DeUbrook Avenue San Francisco, California 94131 Barbara Prato, et al. 526 Dellbrook Avenue San Francisco. California 94131-1161 Anthonv Chao. et al. 22434 Salem Avenue, # A Cupertino, California 95014-0956 Occupant 586 Dellbrook Avenue San Francisco, California 94131 Mr. and Mrs. Walter Lunny 580 Dellbrook Avenue San Francisco, California 94131-1161 Patricia Bozin, et al. 574 Dellbrook Avenue San Francisco. California 94131-1161 Robert Anderson, et al. 65 Woodacre Drive San Francisco, 94132-1624 Lois Jahn, et al. 570 Dellbrook Avenue San Francisco, California 94131-1161 07106197 Occupant 548 Dellbrook Avenue San Francisco, California 9413 1 Mr. and Mrs. Tai Horiuchi 566 Dellbrook Avenue San Francisco, California 94131-1161 George Burke, et al. 56 Turquoise Way San Francisco, California 9413 1-1641 Mr. and Mrs. Robert Irving 164 Canyon Road Fairfax.. California 94930-2209 PROJECT SPONSOR Mr. Eugene Zastrow Sutro Tower, Inc. One La Avanzada Street San Francisco, California 94131 PROJECT ENGINEER Mr. William F. Hammett Hammett & Edison, Inc. P.O. Box 280068 San Francisco, California 94128 PROJECT ATTORNEY Ms. Debra Stein GCA Strategies 655 Montgomery Street 17 th floor San Francisco, California 94111 OUTSIDE PEER REVIEW Dr. Chung-Kwang Chou 11 East Longden Avenue Arcadia, California 91006 ~lIt..n J::'IR \ c.lIt.7 7-8 7.0 Draft EIR Distribution List 07/06/97 Sutra EIR \ S-appendJces APPENDIX A: RADIOFREQUENCY LEVELS 8-1 8.0 APPENDICES 07106197 Sutro Tower, Inc. San Francisco, California Engineering Analysis of Radio Frequency Exposure Conditions with Addition of Digital TV Channels January 3, 1997 © 1997 All rights reserved. HE HAMMED' & EDISON, INC. CONSULTING ENGINEERS SAN FRANCISCO Sutro Tower, Inc. ? Digital Television ? San Francisco, California Statement of William F. Hammett, Consulting Engineer The independent consulting fmn of Hammett & Edison, Inc., Consulting Engineers, has been retained on behalf of the City and County of San Francisco to evaluate the impact on people of radio frequency ("RF') exposure resulting from the addition of new digital television ("DTV") antennas at Sutro Tower. Background Sutro Tower is the best TV broadcasting site in San Francisco. Signals from the 10 TV ~~ stations located there reach all areas of San Francisco and most of the surrounding counties, too. There are also 4 FM radio stations located at Sutro Tower, plus a few low-power radio facilities. The broadcast stations are summarized in the attached Figures 1A and 1B. Allowable Exposure to RF Energy The U.S. government has set limits on the amount of RF energy that people can be exposed to. Those limits* are based on decades of research by hundreds of researchers from universities, government programs, our military, and private companies. Basically, a level of RF energy was found that caused monkeys and apes to stop their trained exercises and to go to areas with lesser amounts of the energy. The standards for human workers have been set 10 times tighter than what first affected monkeys and apes, and the standards for the public have been set about 50 times tighter. All the studies in this report are based upon the tighter, public levels. Another important part of the government limits is that there was no "cumulative" effect of RF energy. So long as levels do not exceed the levels that bothered monkeys and apes, it made no difference whether you got a lot or a little RF energy, or whether you got it for a little while or for a long time. How the Stations Work In order for the stations to reach people's radios and TV sets, they must send out energy. Each station sends out energy on its own frequency, assigned by the government. Microwave ovens use similar frequencies, but they concentrate the * Derived from the NCRP Report No. 86 (1986) and the ANSIlIEEE Standard C95.1-1992. HE HAMMETT & EDISON, INC. , CONSULTING ENGINEERS SAN FRANCISCO 961217 Page 1 of 4 Sutro Tower, Inc. ? Digital Television ? San Francisco, California energy onto the food put into them. Broadcast stations aredifferent~they spread out the energy, to reach as many people as possible, each with just a little bit of the energy. Radios and TV sets are very sensitive and do not need much energy to pick up the stations' signals. What is Digital Television Digital Television ("DTV") is a new TV channel that the government is requiring all TV stations to add, if they want to stay in business. Eventually, all TV stations are supposed to give back to the government the channel they have now" Unfortunately, the TV sets you have now will pick up the DTV channel but will not be able to de-code the DTV signal, so you will have to buy new TV sets. The stations at Sutro Tower want to use the Tower for their new DTV signals, too. They plan to add a long antenna onto one side of the Tower, for all the stations to use. The government has not yet decided how much power the new stations can have. For doing these studies, we have assumed higher power levels than could probably be installed, so that the results will be good no matter what the government finally decides. Calculations Calculating the total energy from the stations at Sutro Tower is easy for a computer to do. By telling it how the different stations operate,t the computer will answer with numbers for the energy at any particular point in San Francisco. Doing this for the stations there now, we find that the stations meet the federal exposure limits at all locations. Figure 2 is a map of the levels for the existing TV and FM stations at Sutro Tower, calculated as a percentage of the government limits and shown by particular shades or colors. The energy from the stations does not go over the government limits, as shown by the lack of any red coloring on the map. The computer can also tell us what happens when the stations add their DTV signals, too. Figure 3 is a map of this case. Again, the energy from the existing stations plus the new DTV channels does not go over the government limits, as shown by the lack of any red coloring on this map. t The position and type of the transmitting antenna on the Tower, the power itse~ndsout, and the frequency of the station. See the Appendix for a more detailed description. HE HAMMETT & EDISON, INC. 961217 , CONSULTThlG ENGINEERS SA."l FRANOSCO Page 2 of 4 Sutro Tower, Inc. ? Digital Television ? San Francisco, California Figure 4 is a print-out of the actual numbers for both cases, which can be used to find the calculated number for locations within about 2 kilometers of Sutro Tower. From Figures 3 and 4 can be derived the following table that shows the approximate energy levels at certain distances from Sutro Tower. These are about the same whether or not the DTV channels are included: Approximate Power Density <0.5% 0.5 -1% 1-5% 5-10% >10% >100% Approximate Distance from Sutro Tower more than 1.8 kIn (about 18 city blocks) less than 1.8 km (about 18 city blocks) less than 0.9 km (about 9 city blocks) less than 0.2 km (about 2 city blocks) less than 0.1 km (about 1 city block) does not reach any publicly accessible areas Measurements The computer program is supposed to give high, "worst-case" numbers. This way, we can be sure that, if the program says it's OK, it will be, at least for the Sutro stations. We have checked this by visiting some locations in San Francisco and comparing the measurements to the numbers in Figure 4. We used a meter specially designed for this purpose* and a representative from the San Francisco Department of Public Health came along to watch. The data in Figure 5 shows that, at all the locations we measured, the actual numbers were always less than what the calculations had said. Therefore, we would expect that the calculations when the stations add their DTV channels will also remain less than the calculations and less than the government limit. Auxiliary Operation Most of the stations at Sutro Tower have "stand-by" auxiliary antennas on the Tower, too, so that they can continue to serve the public if something bad should happen to their main antennas on top of the Tower or if work needs to be done on those antennas. The auxiliary antennas are mounted mostly at the first rung of the Tower and generally can only put out a fraction of the power of the main antennas. Because of these differences, the energy from them in the neighborhoods near Sutro Tower is different, * Holaday Instruments Broadband Exposure Meter, Model HI-3004, calibrated on October 14, 1996. ~.._.. - -- - Sutro Tower, Inc. ? Digital Television ? San Francisco, California too. In some cases, it is less and sometimes it is more. In all cases, though, the total RF energy is less than what the standards would allow. Conclusion The stations operating from Sutro Tower do not generate RF energy in excess of the federal limits in publicly accessible areas. On that basis, there is presumed to be no health risk for persons who live or work nearby or in any other part of San Francisco as a result of the Tower and the operation of its tenants. The same study methods show that the addition of Digital Television channels at Sutro Tower also will not generate RF energy in excess of the federal limits. Finally, the stations at Sutro can not vary their power very much, nor increase power, so there is no point in measuring the RF energy levels from Sutro more than once:, after the DTV stations are added, until such time as other changes might be made. Attachments The following attached figures were prepared under my direct supervision: 1. Summary of stations at Sutro Tower 2. Map of RF levels for existing stations 3. Map of RF levels for existing stations plus DTV channels 4. Table of values from Figures 2 and 3 5. Measurement data and comparison with calculations. For more information, there are appendices describing the FCC exposure standard and computer program: HE HAMMETT & EDISON, INC. , CONSULTING ENGINEERS SAN FRANOSCO Appendix A. Appendix B. January 3, 1997 w~,'0:.~Jtj~/---,- William F. Hammett, P.E. 961217 Page 4 of 4 Sutro Tower, Inc. ? Digital Television ? San Francisco, California Proposed Tower Configuration, showing Broadcast Antennas 977 feet , Proposed ~~~~17DTV pole HE View Looking West HAMMETT & EDISON, INC. CONSULTING ENGlNEERS SAN FRAl\lascO 961217 Figure lA Sutro Tower, Inc. ? Digital Television ? San Francisco, California Summary of Stations at Sutro Tower NTSC TV Stations (Existing) Peak Visual Antenna Effective Call Channel Frequency Location Radiated Power Mlldulation KTVU(TV) 2 54-60 MHz West stack 100kW analog KRON-TV 4 66-72 West stack 100 kW analog KPIX(TV) 5 76-82 West stack 100kW analog KGO-TV 7 174-180 South stack 316 kW analog KQED(TV) 9 186-192 North stack 316 kW analog KOFY-TV 20 506-512 South stack 3470 kW analog KMTP(TV) 32 578-584 North stack 1333 kW analog KCNS(TY) 38 614-620 Below level 6 5000 kW analog KBHK-TY 44 650-656 South stack 5000 kW analog KPST-TV 66 782-788 North stack 3470 kW analog Digital TV Stations (Proposed) Average Antenna Effective Call Channel Frequency Location Radiated Power Modulation KRON-TY 18 494-500 MHz DTY pole 500 kW digital KBHK-TY 19 500-506 DTY pole 500kW digital KOFY-TY 24 530-536 DTY pole 500kW digital KPIX(TV) 28 554-560 DIY pole 500 kW digital KMTP(TY) 30 566-572 DIY pole 500kW digital KTYU(TY) 34 590-596 DIY pole 500 kW digital KCNS(TY) 39 620-626 DIY pole 500 kW digital KKPST-TV 51 692-698 DIY pole 500 kW digital KQED(TV) 57 728-734 DIY pole 500kW digital KGO-TV 61 752-758 DIY pole 500 kW digital FM Radio Stations (Existing) Antenna Effective Call Channel Frequency Location Radiated Power Modulation KOIT-FM 243 96.5 MHz Above level 5 33.0 kW analog KSOL(FM) 255 98.9 Below level 5 6.0 analog KKSF(FM) 279 103.7 Below level 6 7.8 analog KFOG(FM) 283 104.5 Below level 6 7.9 analog HE HAMMETT & EDISON, INC. CONSCLT~GENGINEERS SA:-'; FR.".:-.;CISC;) 961217 Figure IB Sutro Tower, Inc. ? Digital Television ? San Francisco, California Map of Calculated RF Power Density - Existing Sutro TV and FM Stations - __~...---, r---------------- \ , ', ----- '-_1 ,----------------- ------------------------------------------------------------- © 1996 Hammett & Edison, Inc. 2 1 0 KM 1 < 0.5%~FCC Standard Calculations based upon FCC OST Bulletin No. 65 and digital terrain elevation database; see Appendix. Maximum calculated value is 1:2.7% of FCC Standard. HE HAMMETT & EDISON, INC. CONSULTING ENGINEERS SAN FRA1\iCISCO 961217 Figure 2A Sutro Tower, Inc. ? Digital Television ? San Francisco, California Map of Calculated RF Power Density - Existing Sutro TV and FM Stations - 0.2 MI 0.0 0.2 0.4 0.6 0.8 1.0 1.5 1.0 o.s 0.0 KM 0.5 _ ??II~i05;M*tl!'!iti\11·qO.5%lr---<-o.--5~DFCC Standard Calculations based upon FCC OST Bulletin No. 65 and digital terrain elevation database; see Appendix. Maximum calculated value is 12.7% of FCC Standard. HE HAMMETI & EDISON, INC. CONSULTIN--.. ENGINEERS SAN FRANCISCO 961217 Figure 2B Sutro Tower, Inc. ? Digital Television ? San Francisco, California Map of Calculated RF Power Density - Existing Sutro Stations with OTV Channels - -_.....----, r---------------- \ , ' ,~I '-_ ,----------------- ------------------------------------------------------------ ©1996 Hammett & Edison, Inc. 0.5 MI 0.0 0.5 1.0 1.5 2.0 2.5 5 4 3 2 0 KM I _It??-I''''''''!)i;[I''''''''!;l~,~I''''''''!!~!!''I'''i~$'''''''}''!'''''''}.,..........S-........l%"!"""'.......,.1-1........-O.5....~"!"""'o"'1--<-o.--5~-o--I FCC Standard Calculations based upon FCC OST Bulletin No. 65 and digital terrain elevation database; see Appendix. Maximum calculated value is 14.3% of FCC Standard. HE HAMMETT & EDISON, INC. CONSULTING ENGINEERS SAN FRANCISCO 961217 Figure 3A Sutro Tower, Inc. ? Digital Television ? San Francisco, California Map of Calculated RF Power Density - Existing Sutro Stations with DTV Channels - 0.2 MI 0.0 0.2 0.4 0.6 0.8 1.0 1.5 1.0 .....__0_.5_ 0.0 KM 0.5 '!lIii;S.eN:lm;~il""'>T=tt5%-""1< D.s£] FCC Standard Calculations based upon FCC OST Bulletin No. 65 and digital terrain elevation database; see Appendix. Maximum calculated value is. 14.3% of FCC Standard. HE HAMMETT & EDISON, INC. CONSULTING ENGINEERS SAN FRA.'lJCISCO 961217 Figure 3B Sutro Tower, Inc. ? Digital Television ? San Francisco, California Grid Lines for Tabulation of RF Power Density Calculations -22 -24 0.2 MI 0.0 0.2 0.4 0.6 0.8 1.0 1.5 1.0 0.5 0.0 KM 0.5 HE Distances shown are in hundreds of meters from Sutro Tower. HAMMETf & EDISON, INC. CONSULTING ENGINEERS SAN FRANOSCO 961217 Figure 4A Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S Existing WithDTY ~ N-S Existin~WithDTY -2000 -2400 0.0878% 0.135% 1900 -1700 0.101% 0.117% -2000 -2300 0.0868% 0.134% -1900 -1600 0.0758~; 0.0860% -2000 -2200 0.0917% 0.139% -1900 -1500 O.0543~; 0.0598% -2000 -2100 0.0960% 0.143% -1900 -1400 0.0383% 0.0407% -2000 -2000 0.0968% 0.143% -1900 -1300 0.0664% 0.0712% -2000 -1900 0.0981% 0.134% -1900 -1200 0.106% 0.118% -2000 -1800 0.100% 0.125% -1900 -1100 0.133% 0.150% -2000 -1700 0.0974% 0.112 % -1900 -1000 0.119% 0.126% -2000 -1600 0.0871% 0.0975% -1900 -900 0.109% O. ::'11% -2000 -1500 0.0824% 0.0902% -1900 -800 0.106% 0.107% -2000 -1400 0.0861% 0.0929% -1900 -700 0.127% 0.128% -2000 -1300 0.104% 0.116% -1900 -600 0.127% 0.127% -2000 -1200 0.125% 0.144% -1900 -500 0.098H 0.0991% -2000 -1100 0.131% 0.145% -1900 -400 0.0443'~ 0.0447% -2000 -1000 0.109% 0.113 % -1900 -300 0.040n 0.0413% -2000 -900 0.100% 0.102% -1900 -200 0.0947'~ 0.0957% -2000 -800 0.106% 0.107% -1900 -100 0.0550% 0.0559% -2000 -700 0.112% 0.113% -1900 0 0.0617% 0.0631% -2000 -600 0.111% 0.112% -1900 100 0.116% 0.119% -2000 -500 0.107% 0.108% -1900 200 0.235% 0.240% -2000 -400 0.0406% 0.0409% -1900 300 0.275% 0.280% -2000 -300 0.0365% 0.0369% -1900 400 0.255% 0.259% -2000 -200 0.0970% 0.0979% -1900 500 0.268% 0.271% -2000 -100 0.0791% 0.0801% -1900 600 0.271% 0.274% -2000 0 0.0924% 0.0940% -1900 700 0.261% 0.263% -2000 100 0.144% 0.148% -1900 800 0.264% 0.267% -2000 200 0.222% 0.226% -1900 900 0.253% 0.259% -2000 300 0.257% 0.260% -1900 1000 0.240% 0.248% -2000 400 0.252% 0.255% -1900 1100 0.255% 0.266% -2000 500 0.249% 0.252% -1900 1200 0.247% 0.260% -2000 600 0.244% 0.245% -1900 1300 o .23H 0.244% -2000 700 0.235% 0.236% -1900 1400 0.217% 0.231% -2000 800 0.248% 0.250% -1900 1500 O.203~; 0.218% -2000 900 0.248% 0.251% -1900 1600 0.192~; 0.210% -2000 1000 0.237% 0.242% -1900 1700 o.183~5 0.204% -2000 1100 0.237% 0.244% -1900 1800 0.179~5 0.205% -2000 1200 0.225% 0.234% -1900 1900 o.180~5 0.213% -2000 1300 0.211% o .221% -1900 2000 0.185\5 0.224% -2000 1400 O. ':"97% 0.209% -1900 2100 0.193 1 5 0.239% -2000 1500 0.193% 0.207% -1800 -2400 o . 116\!; 0.176% -2000 1600 0.193% 0.212% -1800 -2300 0.113!!; 0.173% -2000 1700 0.189% 0.214% -1800 -2200 o . 116!!; 0.177% -2000 1800 0.188% 0.218% -1800 -2100 o.122'~ 0.182% -2000 1900 0.191% 0.226% -1800 -2000 0.129'~ 0.188% -2000 2000 0.196% 0.237% -1800 -1900 0.140~ 0.199% -2000 2100 0.200% 0.246% -1800 -1800 0.146% 0.193% -1900 -2400 0.0959% 0.149% -1800 -1700 0.110% 0.130% -1900 -2300 0.0981% 0.151% -1800 -1600 0.0644% 0.0747% -1900 -2200 0.101% 0.155% -1800 -1500 0.0372% 0.0411% -1900 -2100 0.105% 0.159% -1800 -1400 0.0207% 0.0216% -1900 -2000 0.107% 0.160% -1800 -1300 0.0393% 0.0408% -1900 -1900 0.112% 0.159% -1800 -1200 0.0915% 0.0961% -1900 -1800 o . 114% 0.148% -1800 -1100 0.142% 0.161% East-West and North-South are meters from Sutro Tower. Power density is in % of FCC Standard for public exposure. HE HAMMEIT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRANCISCO Figure 4B Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S Exi stin 2 WithPTV E-W N-S Existine WithPT\, -1800 -1000 0.149% 0.166% -~700-300 0.308% C.311% -1800 -900 0.148% 0.155% -1700 -200 0.212% 0.216% -1800 -800 0.145% 0.148% -:'700 -100 0.175% 0.179% -1800 -700 0.188% 0.189% -1700 0 0.138% 0.141% -1800 -600 0.185% 0.186% -1700 100 0.106% 0.109% -1800 -500 0.133% 0.134% -1700 200 0.262% 0.265% -1800 -400 0.126% 0.127% -1700 300 0.360% 0.363% -1800 -300 0.125% 0.126% -1700 400 0.350% 0.353% -1800 -200 0.122% 0.124% -1700 500 0.329% 0'.331% -1800 -100 0.0528% 0.0537% -1700 600 0.325% 0.327% -1800 0 0.0495% 0.0504% -1700 700 0.331% 0.334% -1800 100 0.0959% 0.0976% -1700 800 0.301% 0.307% -1800 200 0.261% 0.265% -1700 900 0.293% 0.306% -1800 300 0.329% 0.334% -l700 1000 0.300% 0.324% -1800 400 0.281% 0.284% -1700 1100 0.290% 0.317% -1800 500 0.304% 0.307% -1700 1200 0.283% 0.310% -1800 600 0.315% 0.317% -1700 1300 0.277% 0.304% -1800 700 0.309% 0.311% -1700 1400 0.260% 0.286% -1800 800 0.277% 0.282% -1700 1500 0.243% 0.265% -1800 900 0.255% 0.264% -1700 1600 0.226% 0.246% -1800 1000 0.247% 0.262% -·1700 1700 0.215% 0.235% -1800 1100 0.269% 0.288% -·1700 1800 0.202% 0.226% -1800 1200 0.265% 0.284% -·1700 1900 0.192% 0.220% -1800 1300 0.247% 0.265% --1700 2000 0.189% 0.224% -1800 1400 0.225% 0.242% .-:700 2100 0.195% 0.239% -1800 1500 0.207% 0.225% --1600 -2400 0.:23% 0.194% -1800 1600 0.194% 0.212% ·-1600 -2300 0.143% 0_218% -1800 1700 0.175% 0.195% --1600 -2200 0.151% 0.226% -1800 1800 0.169% 0.193% --1600 -2100 0.155% 0.228% -1800 1900 0.170% 0.201% ·-1600 -2000 0.160% 0.229% -1800 2000 0.168% 0.205% ·-1600 -1900 0.174% 0.239% -1800 2100 0.176% 0.221% -1600 -1800 0.182% 0.242% -1700 -2400 0.117% 0.182% -1600 -1700 0.168% 0.220% -1700 -2300 0.125% 0.192% -1600 -1600 0.0918% 0.109% -1700 -2200 0.132% 0.200% -1600 -1500 0.0428% 0.0463% -1700 -2100 0.138% 0.204% -1600 -1400 0.0213% 0.0218% -1700 -2000 0.141% 0.205% -1600 -1300 0.0183% 0.0185% -1700 -1900 0.149% 0.210% -1600 -1200 0.0182% 0.0183% -1700 -1800 0.157% 0.215% -1600 -1l00 0.0306% 0.0311% -1700 -1700 0.154% 0.198% -1600 -1000 0.108% o.1l4% -1700 -1600 0.0726% 0.0841% -1600 -900 0.258% 0.272% -1700 -1500 0.0346% 0.0370% -1600 -800 0.375% 0.384% -1700 -1400 0.0206% 0.0212% -1600 -700 0.404% 0.408% -1700 -1300 0.0208% 0.0211% -1600 -600 0.390% 0.392% -1700 -1200 0.0330% 0.0338% -1600 -500 0.396% 0.399% -1700 -1100 o.1l8% 0.124% -1600 -400 0.433% 0.436% -1700 -1000 0.180% 0.197% -1600 -300 0.423% 0.428% -1700 -900 0.253% 0.267% -1600 -200 0.356% 0.362% -1700 -800 0.346% 0.353% -1600 -100 0.379% 0.386% -1700 -700 0.315% 0.317% -1600 0 0.318% 0.324% -1700 -600 0.273% 0.275% -1600 100 0.206% 0.209% -1700 -500 0.255% 0.257% -1600 200 0.333% 0.336% -1700 -400 0.318% 0.320% -1600 300 0.406% 0.408% East-West and North-South are meters from Sutro Tower. Power density is in % of FCC Standard for public exposure. HE HAMMETT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRANOSCO Figure 4C Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S Existin~WitbPTV ~ N-S Existin~WithPTV -1600 400 0.389% 0.391% -1500 1100 0.331% 0.364% -1600 500 0.368% 0.370% -1500 1200 0.312% 0.356% -1600 600 0.355% 0.356% -1500 1300 0.294% 0.345% -1600 700 0.347% 0.350% -1500 1400 0.275% 0.325% -1600 800 0.335% 0.342% -1500 1500 0.267% 0.311% -1600 900 0.330% 0.345% -1500 1600 0.264% 0.300% -1600 1000 0.328% 0.354% -1500 1700 0.242% 0.271% -1600 1100 0.310% 0.344% -1500 1800 0.228% 0.254% -1600 1200 0.297% 0.336% -1500 1900 0.217% 0.242% -1600 1300 0.286% 0.326% -1500 2000 0.203% 0.234% -1600 1400 0.270% 0.307% -1500 2100 0.191% 0.227% -1600 1500 0.260% 0.291% -1400 -2400 0.157% 0.243% -1600 1600 0.250% 0.275% -1400 -2300 0.172% 0.260% -1600 1700 0.233% 0.255% -1400 -2200 0.185% 0.275% -1600 1800 0.217% 0.240% -1400 -2100 0.196% 0.284% -1600 1900 0.204% 0.231% ··1400 -2000 0.205% 0.282% -1600 2000 0.199% 0.233% -1400 -1900 0.224% 0.289% -1600 2100 0.197% 0.238% -1400 -1800 o.227% 0.280% -1500 -2400 0.133% 0.212% -1400 -1700 0.180% 0.222% -1500 -2300 0.166% 0.249% -1400 -1600 0.157% 0.192% -1500 -2200 0.170% 0.254% -1400 -1500 0.136% 0.163% -1500 -2100 0.174% 0.254% -1400 -1400 0.111% 0.127% -1500 -2000 0.183% 0.257% -1400 -1300 0.0395% 0.0421% -1500 -1900 0.212% 0.279% -1400 -1200 0.0209% 8.0215% -1500 -1800 0.215% 0.272% -1400 -1100 0.0170% 0.0174% -1500 -l700 0.171% 0.216% -1400 -1000 0.0566% 0.0614% -1500 -1600 0.134% 0.168% -1400 -900 0.196% 0.213% -1500 -1500 0.0745% 0.0870% -1400 -800 0.376% 0.396% -1500 -1400 0.0243% 0.0255% -1400 -700 0.508% 0.520% -1500 -1300 0.0202% 0.0205% -1400 -600 0.538% 0.544% -1500 -1200 0.0137% 0.0138% -1400 -500 0.513% 0.516% -1500 -1100 0.00557% 0.00563% -1400 -400 0.545% 0.549% -1500 -1000 0.0422% 0.0440% -1400 -300 0.560% 0.565% -1500 -900 0.186% 0.198% -1400 -200 0.567% 0.572% -1500 -800 0.320% 0.332% -1400 -100 0.552% 0.555% -1500 -700 0.443% 0.450% -1400 0 0.536!!; 0.541% -1500 -600 0.495% 0.499% -1400 100 0.523!!; 0.529% -1500 -500 0.497% 0.500% -1400 200 0.505!!; 0.510% -1500 -400 0.493% 0.496% -l400 300 0.496% 0.500% -1500 -300 0.512% 0.518% -1400 400 O.496~; 0.499% -1500 -200 0.567% 0.575% -1400 500 0.45n 0.459% -1500 -100 0.553% 0.562% -1400 600 0.442% 0.445% -1500 0 0.518% 0.525% -1400 700 0.445% 0.453% -1500 100 0.487% 0.491% -1400 800 o.416\~ 0.431% -1500 200 0.483% 0.486% -1400 900 0.388\~ 0.407% -1500 300 0.456% 0.459% -1400 1000 0.36H 0.384% -1500 400 0.422% 0.424% -1400 1100 0.340!5 0.368% -1500 500 0.421% 0.422% -1400 1200 0.325!5 0.365% -1500 600 0.402% 0.404% -1400 1300 0.315% 0.369% -1500 700 0.372% 0.376% -1400 1400 0.290!fi 0.348% -1500 800 0.375% 0.385% -1400 1500 0.275'fi 0.331% -1500 900 0.363% 0.381% -1400 1600 0.265'fi 0.314% -1500 1000 0.348% 0.371% -1400 1700 0.256% 0.295% East-West and North-South are meters from Sutro Tower. Power density is in % of FCC Standard for public exposure, HE HAMMETT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRANosco Figure 4P Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S Existing WithDTV E-W N-S Existing WitbD1V -1400 1800 0.247% 0.279% -1200 -2100 0.196% 0.286% -1400 1900 0.235% 0.263% -1200 -2000 0.208% 0.288% -1400 2000 0.202% 0.229% -1200 -1900 0.195% 0.255% -1400 2100 0.185% 0.218% -1200 -1800 0.174% 0.218% -1300 -2400 0.187% 0.283% --1200 -1700 0.155% 0.187% -1300 -2300 0.196% 0.293% -1200 -1600 0.148% 0.181% -1300 -2200 0.200% 0.295% --1200 -1500 0.163% 0.203% -1300 -2100 0.207% 0.297% --1200 -1400 0.196% 0.243% -1300 -2000 0.217% 0.297% -·1200 -1300 0.250% 0.304% -1300 -1900 0.221% 0.284% --1200 -1200 0.359% e.434% -l300 -1800 0.209% 0.258% --1200 -1100 0.645% 0.798% -1300 -1700 0.174% 0.210% --1200 -1000 0.672% 0.763% -1300 -1600 0.156% 0.189% --1200 -900 0.639% 0.690% -1300 -1500 0.157% 0.190% '-1200 -800 0.616% 0.653% -1300 -1400 0.183% 0.221% --1200 -700 0.596% 0.624% -1300 -1300 0.0998% 0.114% --1200 -600 0.610% 0.623% -1300 -1200 0.0729% 0.0800% --1200 -500 0.646% 0.650% -1300 -1100 0.110% 0.120% -1200 -400 0.626% 0.629% -1300 -1000 0.207% 0.230% -1200 -300 0.614% 0.617% -1300 -900 0.350% 0.378% -1200 -200 0.617% 0.623% -1300 -800 0.485% 0.515% -1200 -100 0.595% 0.600% -1300 -700 0.554% 0.576% -1200 0 0.582% 0.587% -1300 -600 0.576% 0.586% -1200 100 0.578% 0.581% -l300 -500 0.567% 0.570% -1200 200 0.583% 0.586% -1300 -400 0.590% 0.592% -1200 300 0.567% 0.569% -1300 -300 0.585% 0.589% -1200 400 0.519% 0.520% -130e -200 0.566% 0.571% -1200 500 0.537% 0.540% -1300 -100 0.563% 0.567% -1200 600 0.521% 0.531% -1300 0 0.561% 0.564% -1200 700 0.492% 0.516% -1300 100 0.555% 0.559% -1200 800 0.471% 0.504% -1300 200 0.547% 0.551% -1200 900 0.452% 0.489% -1300 300 0.534% 0.537% -1200 1000 0.432% 0.470% -1300 400 0.509% 0.511% -l200 1100 0.401% 0.435% -1300 500 0.498% 0.50H -1200 1200 0.378% 0.413% -1300 600 0.488% 0.494% -1200 1300 0.363% 0.405% -1300 700 0.481% 0.495% -1200 1400 0.349% 0.405% -1300 800 0.451% 0.471% -1200 1500 0.328% 0.400% -1300 900 0.422% 0.447% -1200 1600 0.308% 0.386% -1300 1000 0.394% 0.421% -1200 1700 0.308% 0.381% -1300 1100 0.365% 0.395% -1200 1800 0.299% 0.357% -1300 1200 0.348% 0.382% -l200 1900 0.281% 0.326% -1300 1300 0.337% 0.384% -1200 2000 0.252% 0.287% -1300 1400 0.316% 0.376% -1200 2100 0.228% 0.261% -1300 1500 0.297% 0.365% -1l00 -2400 0.159% 0.272% -1300 1600 0.282% 0.346% -1100 -2300 0.188% 0.309% -1300 1700 0.278% 0.332% -1100 -2200 0.171% 0.286% -1300 1800 0.274% 0.316% -1100 -2100 0.158% 0.252% -1300 1900 0.261% 0.296% -1100 -2000 0.165% 0.237% -1300 2000 0.223% 0.252% -1100 -1900 0.132% 0.168% -1300 2100 0.201% 0.232% -1100 -1800 0.115% 0.139% -1200 -2400 0.211% 0.318% -1100 -1700 0.123% 0.151% -1200 -2300 0.217% 0.326% -1100 -1600 0.138% 0.176% -1200 -2200 0.202% 0.303% -1100 -1500 0.159% 0.212% East-West and North-South are meters from Sutro Tower. Power density is in % ofFCC Standard for public exposure. HE HAMMETT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRANOSCO Figure 4E Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S Existin~WithDIV .--UL N-S Existin2 WithDTV -1100 -1400 0.186% 0.252% -1000 -700 0.621% 0.654% -1100 -1300 0.274% 0.344% -1000 -600 0.604% 0.623% -1100 -1200 0.426% 0.503% -1000 -500 0.588% 0.601% -1100 -1100 0.603% 0.685% -1000 -400 0.614% 0.617% -1100 -1000 0.643% 0.735% -1000 -300 0.374% 0.375% -1100 -900 0.635% 0.715% -1000 -200 0.120% 0.121% -1100 -800 0.645% 0.689% -1000 -100 0.295% 0.297% -1100 -700 0.639% 0.663% -1000 a 0.532% 0.537% -1100 -600 0.640% 0.654% -1000 100 0.620% 0.625% -1100 -500 0.643% 0.652% -1000 200 0.594% o.597% -1100 -400 0.595% 0.598% -1000 300 0.599% 0.600% -1100 -300 0.605% 0.608% -1000 400 0.622% 0.624% -1100 -200 0.568% 0.572% -1000 500 0.569% 0.577% -1100 -100 0.569% 0.574% -1000 600 0.535% o.551% -1100 0 0.564% 0.569% -1000 700 0.514% 0.539% -1100 100 0.566% 0.570% -1000 800 0.496% 0.523% -1100 200 0.575% 0.579% -1000 900 0.483% a.521% -1100 300 0.586% 0.588% -·1000 1000 0.476% 0.531% -1100 400 0.588% 0.589% -1000 1100 0.468% 0.526% -1100 500 0.559% 0.563% -1000 1200 0.450% 0.503% -1100 600 0.527% 0.536% -1000 1300 0.425% 0.475% -1100 700 0.503% 0.521% -1000 1400 0.398% 0.450% -1100 800 0.484% 0.516% -1000 1500 0.382% 0.440% -1100 900 0.469% 0.515% -1000 1600 0.365% 0.450% -1100 1000 0.455% 0.505% -1000 1700 0.323% 0.418% -1100 1100 0.439% 0.485% -1000 1800 0.290% 0.384% -1100 1200 0.413% 0.458% -1000 1900 0.266% 0.346% -1100 1300 0.388% 0.429% -1000 2000 0.270% 0.331% -1100 1400 0.374% 0.423% -1000 2100 0.257% 0.302% -1100 1500 0.354% 0.419% -900 -2400 0.160% 0.285% -1100 1600 0.335% 0.420% -900 -2300 0.157% 0.294% -1100 1700 0.320% 0.412% -900 -2200 0.225% 0.375% -llOO 1800 0.300% 0.378% -900 -2100 0.275% 0.432% -1100 1900 0.272% 0.332% -900 -2000 0.238% 0.366% -1100 2000 0.257% 0.302% -900 -1900 0.195% 0.284% -llOO 2100 0.246% 0.284% -900 -1800 0.188~; 0.263% -1000 -2400 0.157% 0.277% -900 -1700 0.225~; 0.300% -1000 -2300 0.167% 0.298% -900 -1600 0.267% 0.344% -1000 -2200 0.191% 0.324% -900 -1500 0.304~) 0.388% -1000 -2100 0.200% 0.319% -900 -1400 0.333~50.442% -1000 -2000 0.2.91% 0.279% -900 -1300 0.472~\ 0.600% -1000 -1900 0.150% 0.201% -900 -1200 0.569~5 0.706% -1000 -1800 0.139% 0.177% -900 -1100 0.589% 0.708% -1000 -1700 0.155% 0.195% -900 -1000 0.62115 0.697% -1000 -1600 0.178% 0.227% -900 -900 0.649!~ 0.712% -1000 -1500 0.204% 0.268% -900 -800 0.648!~ 0.732% -1000 -1400 0.239% 0.324% -900 -700 0.614'f; 0.658% -1000 -1300 0.359% 0.461% -900 -600 O.604'~ 0.631% -1000 -1200 0.501% 0.605% -900 -500 0.576~ 0.592% -1000 -1100 0.583% 0.664% -900 -400 0.628% o.631% -1000 -1000 0.618% 0.692% -900 -300 0.291% 0.292% -1000 -900 0.637% 0.710% -900 -200 0.0495% 0.0496% -1000 -800 0.652% 0.721% -900 -100 0.209% 0.210% East-West and North-South are meters from Sutra Tower. Power density is in % ofFCC Standard for public exposure. HE HAMMElT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN fRANCISCO Figure 4F Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S Existin~WithDTV _E-W N-S Existin2 - WithDTV -900 0 0.558% 0.56:"% -800 700 0.670% 0.720% -900 100 0.705% 0.708% -800 800 0.651% 0.708% -900 200 0.646% 0.647% -800 900 0.593% 0.652% -900 300 0.632% 0.633% -800 1000 0.528% 0.569% -900 400 0.627% 0.630% -800 1100 0.525% 0.588% -900 500 0.596% 0.609% -800 1200 0.522% 0.610% -900 600 0.569% 0.597% -- 800 1300 0.509% 0.599% -900 700 0.545% 0.581% -800 1400 0.483% 0.557% -900 800 0.527% 0.563% -800 1500 0.431% 0.501% -900 900 0.51:% 0.545% -800 1600 0.372% 0.438% -900 1000 C.500% 0.548% -800 1700 0.351% 0.441% -900 1100 0.492% 0.560% -800 1800 0.319% 0.441% -900 1200 0.486% 0.557% -800 1900 0.286% 0.407% -900 1300 0.471% 0.539% -800 2000 0.253% 0.355% -900 1400 0.434% 0.492% -800 2100 0.237% 0.312% -900 1500 0.409% 0.469% -700 -2400 0.154% 0.255% -900 1600 0.387% 0.466% -700 -2300 0.172% 0.309% -900 1700 0.331% 0.425% -700 -2200 0.242% 0.412% -900 1800 0.291% 0.398% -700 -2100 0.323% 0.516% -900 1900 0.267% 0.369% -700 -2000 0.325% 0.512% -900 2000 0.280% 0.362% -700 -1900 0.292% 0.457% -900 2100 0.260% 0.319% -700 -1800 0.272% 0.400% -800 -2400 0.156% 0.279% -700 -1700 0.287% 0 .. 385% -800 -2300 0.173% 0.317% -700 -1600 0.401% 0.503% -800 -2200 C.211% 0.373% -700 -1500 0.497% 0.616% -800 -2100 0.248% 0.423% --700 -1400 0.517% C.701% -800 -2000 0.266% 0.430% -700 -1300 0.527% 0.674% -800 -1900 0.236% 0.361% -700 -1200 0.555% 0.643% -800 -1800 0.216% 0.312% -700 -HOO 0.627% 0.724% -800 -1700 o.227% 0.306% -700 -1000 0.688% 0.814% -800 -1600 0.351% 0.438% -700 -900 0.689% 0.810% -800 -1500 0.449% 0.551% -700 -800 0.649% 0.716% -800 -1400 0.453% 0.599% -700 -700 0.642% 0.684% -800 -1300 0.473% 0.594% -700 -600 0.708% 0.741% -800 -1200 0.518% 0.597% -700 -500 0.830% 0.858% -800 -1100 0.616% 0.695% -700 -400 0.903% 0.916% -800 -1000 0.649% 0.744% -700 -300 1. 02% 1. 02% -800 -900 0.631% 0.721% -700 -200 1. 05% 1.05% -800 -800 0.603% 0.659% -700 -100 1.19% 1.19% -800 -700 0.610% 0.647% -700 0 1. 05% 1.05% -800 -600 0.652% 0.679% -700 100 0.721% 0.724% -800 -500 0.714% 0.734% -700 200 0.807% 0.809% -800 -400 0.743% 0.749% -700 300 0.815% 0.819% -800 -300 0.711% 0.713% -700 400 0.783% 0.801% -800 -200 0.691% 0.692% -700 500 0.831% 0.858% -800 -100 0.816% 0.8::;0% -700 600 0.780% 0.818% -800 0 0.655% 0.657% -700 700 0.684% 0.731% -800 100 0.349% 0.350% -700 800 0.643% 0.695% -800 200 0.500% 0.501% -700 900 0.599% 0.656% -800 300 0.533% 0.536% -700 1000 0.561% 0.623% -800 400 0.465% 0.472% -700 1100 0.559% 0.620% -800 500 0.609% 0.625% -700 1200 0.559% 0.645% -800 600 0.672% 0.705% -700 1300 0.550% 0.662% East-West and North-South are meters from Sutro Tower. Power density is in % ofFCC Standard for public exposure. HE HAMMETT & EDISON, INC. 961217 CONSUl.TING ENGINEERS SAN FRANCISCO Figure 4G Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S ExistiDl~WithDTY ~ N-S Existio2 WithDTV -700 1400 0.509% 0.596% -600 2100 0.268% 0.350% -700 1500 0.458% 0.539% -500 -2400 0.0120% 0.0159% -700 1600 0.409% 0.482% -500 -2300 0.364% 0.505% -700 1700 0.395% 0.495% -500 -2200 0.512% 0.691% -700 1800 0.351% 0.482% -500 -2100 0.465% 0.655% -700 1900 0.300% 0.431% -500 -2000 0.400% C.616% -700 2000 0.274% 0.386% -500 -1900 0.388% 0.578% -700 2100 0.250% 0.332% -500 -1800 0.390% 0.531% -600 -2400 0.113% 0.156% -500 -1700 0.395% 0.506% -600 -2300 0.180% 0.302% -500 -l600 0.474% 0.608% -600 -2200 0.306% 0.480% -500 -1500 0.527% 0.710% -600 -2100 o.411% 0.615% -500 -1400 0.536% 0.780% -600 -2000 0.387% 0.591% -500 -1300 0.613% 0.789% -600 -1900 0.351% 0.539% -500 -1200 0.692% 0.814% -600 -1800 0.336% 0.480% -500 -1100 0.734% 0.910% -600 -1700 0.351% 0.465% -500 -1000 0.723% 0.866% -600 -1600 0.418% 0.537% -500 -900 0.745% 0.883% -600 -1500 0.483% 0.623% -500 -800 0.835% 0.959% -600 -1400 0.524% 0.744% -500 -700 0.878% 0.958% -600 -1300 0.569% 0.743% -500 -600 0.958% 1.02% -600 -1200 0.609% 0.720% -500 -500 1.12% 1.18% -600 -1100 0.653% 0.779% -500 -400 1.27% 1. 32% -600 -1000 0.721% 0.865% -500 -300 1. 48% 1.50% -600 -900 0.748% 0.885% -500 -200 1.72% 1.73% -600 -800 0.718% 0.807% -500 -100 1. 72% 1. 73% -600 -700 0.711% 0.767% -500 0 1. 72% 1.73% -600 -600 0.792% 0.836% -500 100 1.74% 1.75% -600 -500 0.985% 1.02% -500 200 1.81% 1. 83% -600 -400 1.15% 1.18% -500 300 1.80% 1. 82% -600 -300 2..26% 1.27% -500 400 1. 55% 1. 62% -600 -200 1. 27% 1.27% -50C 500 1. 40% 1. 48% -600 -100 1. 43% 1.44% -500 600 1. 07% 1.15% -600 0 1. 58% 1.59% -500 700 0.712% 0.784% -600 100 1.58% 1.58% -500 800 0.723% 0.781% -600 200 1. 40% 1. 41% -500 900 0.688% 0.752% -600 300 1.32% 1. 33% -500 1000 0.660% 0.767% -600 400 1. 32% 1. 36% -500 1100 0.660% 0.745% -600 500 1.17% 1.21% -500 1200 0.628% 0.708% -600 600 0.903% 0.951% -500 1300 0.580% 0.698% -600 700 0.679% 0.726% -500 1400 0.577% 0.708% -600 800 0.642% 0.694% -500 1500 0.524% 0.630% -600 900 0.614% 0.672% -500 1600 0.454% 0.535% -600 1000 0.609% 0.692% -500 1700 0.427% 0.530% -600 1100 0.599% 0.672% -500 1800 0.384% 0.519% -600 1200 0.595% 0.674% -500 1900 0.343% 0.497% -600 1300 0.587% o.710% -500 2000 0.2TI% 0.400% -600 1400 0.534% 0,642% -500 2100 0.259% 0.339% -600 1500 0.486% 0.578% -400 -2400 0.00760% 0.00853% -600 1600 0.446% 0.524% -400 -2300 0.4513% 0.638% -600 1700 0.428% 0.537% -400 -2200 0.651% 0.861% -600 1800 0.374% 0.511% -400 -2100 0.551% 0.746% -600 1900 0.315% 0.454% -400 -2000 0.469% 0.707% -600 2000 0.296% 0.415% -400 -1900 0.427% 0.620% East-West and North-South are meters from Sutro Tower. Power density is in % ofFCC Standard for public exposure. HE HAMMETT & EDISON, INC. 961217CONSULTING ENGINEERS SAN FRANCISCO Figure 4H Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DlY Channels E-W N-S Existin~WrthDTV -UL N-S Existin~WithDTV -400 -1800 0.428% 0.568% -300 -1100 0.843% l.18% -400 -1700 0.460% 0.579% -300 -1000 0.834% 0.980% -400 -1600 0.498% 0.649% -300 -900 0.817% 0.943% -400 -1500 0.539% 0.747% -300 -800 0.863% 1.07% -400 -1400 0.589% 0.850% -300 -700 1.10% 1. 26% -400 -1300 0.642% 0.791% -300 -600 1. 34% 1.48% -400 -1200 0.720% 0.851% -300 -500 1.51% :.65% -400 -1100 0.811% 1.07% -300 -400 1. 78% 1.92% -400 -1000 0.789% 0.938% -300 -300 2.14% 2.27% -400 -900 0.778% 0.911% -300 -200 2.69% 2.77% -400 -800 0.834% 1. 00% -300 -100 3.55% 3.58% -400 -700 0.993% 1.11% -300 0 4.39% 4.40% -400 -600 1.14% 1.24% -300 100 4.16% 4.18% -400 -500 1. 29% 1. 38% -300 200 3.37% 3.45% -400 -400 1. 48% 1. 56% -300 300 2.84% 3.00% -400 -300 1.77% 1. 82% -300 400 2.36% 2.53% -400 -200 2.14% 2.17% -300 500 1.86% 2.04% -400 -100 2.47% 2.48% -300 600 1.54% 1.70% -400 0 2.76% 2.77% -300 700 1.23% 1. 34% -400 100 2.78% 2.79% -300 800 1. 01% 1.12% -400 200 2.51% 2.54% -300 900 0.876% 0.982% -400 300 2.23% 2.29% ·-300 1000 o.797% 0.906% -400 400 1. 89% 1. 99% -300 1100 0.673% 0.786% -400 500 1. 66% 1.79% -300 1200 0.649% 0.755% -400 600 1. 30% 1. 42% -300 1300 o. 661% 0.780% -400 700 0.909% 0.998% -300 1400 0.603% 0.744% -400 800 0.856% 0.941% -300 1500 0.567% 0.679% -400 900 0.787% 0.878% -300 1600 0.531% 0.631% -400 1000 0.736% 0.857% -300 1700 0.469% 0.585% -400 1100 0.678% 0.780% -300 1800 0.407% 0.562% -400 1200 0.650% 0.742% --300 1900 0.374% 0.527% -400 1300 0.633% 0.755% -300 2000 0.343% 0.449% -400 1400 0.593% 0.735% -300 2100 0.315% 0.388% -400 1500 0.551% 0.664% ·-200 -2400 0.00151% 0.00193% -400 1600 0.499% 0.590% -200 -2300 0.00590% 0.00720% -400 1700 0.442% 0.551% -200 -2200 0.125% 0.162% -400 1800 0.394% 0.541% -200 -2100 0.696% 0.938% -400 1900 0.362% 0.518% -200 -2000 0.741% 0.966% -400 2000 0.303% 0.417% -200 -1900 0.519% 0.688% -400 2100 0.281% 0.355% -200 -1800 0.479% 0.616% -300 -2400 0.00517% 0.00574% -200 -1700 0.517% 0.643% -300 -2300 0.179% 0.263% -200 -1600 0.513% 0.678% -300 -2200 0.482% 0.646% -200 -1500 0.548% 0.775% -300 -2100 0.624% 0.834% -200 -1400 0.630% 0.871% -300 -2000 0.572% 0.815% -200 -1300 0.682% 0.801% -300 -1900 0.470% 0.656% -200 -1200 0.755% 0.906% -300 -1800 0.457% 0.597% -200 -1100 0.839% 1.17% -300 -1700 0.511% 0.636% -200 -1000 0.823% 0.967% -300 -1600 0.512% 0.675% -200 -900 0.847% 0.972% -300 -1500 0.543% 0.764% -200 -800 1. 03% 1.21% -300 -1400 0.623% 0.883% -200 -700 1.17% 1. 33% -300 -1300 0.665% 0.793% -200 -600 1. 40% 1.59% -300 -1200 0.739% 0.890% -200 -500 1.87% 2.11% East-West and North-South are meters from Sutro Tower. Power density is in % ofFCC Standard for public exposure. HE HAMMEIT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRANCISCO Figure 4J Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and EXisting with DTV Channels E-W N-S Ex.istin~WithDTV E-W N-S Existin~With DT\' -200 -400 2.26% 2.52% -100 300 4.02% 4.5H -200 -300 2.76% 3.02% -100 400 3.32% 3.74% -200 -200 3.53% 3.75% -100 500 2.28% 2.57% -200 -100 4.84% 4.86% -100 600 1. 76% 1.97% -200 0 6.11% 6.13% -100 700 1.49% 1. 65% -200 100 5.90% 5.97% -100 800 1. 25% :.38% -200 200 4.72% 4.92% -100 900 0.998% :'.10% -200 300 3.92% 4.29% -100 1000 0.812% C.893% -200 400 3.16% 3.47% -100 1100 0.737% 0.858% -200 500 1.86% 2.08% -100 1200 o.691% 0.809% -200 600 1. 51% 1.68% -100 1300 0.656% 0.754% -200 700 1.51% 1. 66% -100 1400 0.653% 0.792% -200 800 1.10% 1. 22% -100 1500 0.607% 0.721% -200 900 0.897% 0.997% -100 1600 0.539% 0.633% -200 1000 0.801% 0.892% -100 1700 0.510% 0.627% -200 1100 0.679% 0.795% -100 1800 0.435% 0.589% -200 1200 0.653% 0.764% -100 1900 0.382% 0.525% -200 1300 0.654% 0.757% -100 2000 0.400% o.496% -200 1400 0.610% 0.746% -100 2100 0.373% 0.444% -200 1500 0.574% 0.685% 0 -2400 0.0128% 0.0138% -200 1600 0.536% 0.633% 0 -2300 0.0227% 0.0275% -200 1700 0.504% 0.623% a -2200 0.151% 0.198% -200 1800 o.431% 0.587% 0 -2100 0.512% 0.712% -200 1900 o.377% 0.525% 0 -2000 0.627% 0.836% -200 2000 0.392% 0.493% 0 -1900 0.673% 0.924% -200 2100 0.364% 0.436% 0 -18000.678~; 0.906% -100 -2400 0.00302% 0.00346% 0 -1700 O.584~; 0.704% -100 -2300 0.00813% 0.00982% 0 -1600 O.596~5 0.768% -100 -2200 0.125% 0.167% 0 -1500 0.62815 0.858% -100 -2100 0.650% 0.897% 0 -1400 0.665\5 0.869% -100 -2000 0.690% 0.909% 0 -1300 0.813\5 0.937% -100 -1900 0.599% 0.801% 0 -1200 0.909;5 1.07% -100 -1800 0.579% 0.751% 0 -1100 0.890'5 1.18% -100 -1700 C.551% 0.672% 0 -1000 0.980!5 1.15% -100 -1600 0.558% 0.729% 0 -900 1. 06% 1. 20% -100 -1500 0.591% 0.822% 0 -800 1.15% 1.28% -100 -1400 0.645% 0.870% 0 -700 1. 52% 1. 69% -100 -1300 0.741% 0.865% 0 -600 1.87% 2.08% -100 -1200 0.825% 0.983% 0 -500 2.22% 2.47% -100 -1100 0.856% :'.16% 0 -400 2.64% 2.95% -100 -1000 0.905% :'.07% 0 -300 3.87% 4.35% -100 -900 0.966% 1.10% 0 -200 7.63% 8.73% -100 -800 1.09% 1. 23% a -100 9.26% 10.3% -100 -700 1.37% 1.53% 0 0 10.9% 12.3% -100 -600 1.67% 1.88% 0 100 11. 0% 13.1% -100 -500 2.02% 2.31% 0 200 5.95%, 6.74% -100 -400 2.39% 2.73% 0 300 4.00%; 4.47% -100 -300 3.25% 3.69% 0 400 3.24% 3.59% -100 -200 5.32% 5.89% 0 500 2.55% 2.82% -100 -100 6.72% 6.93% 0 600 1. 93% 2.13% -100 0 8.09% 8.33% 0 700 1.42% 1. 56% -100 100 8.15% 8.63% 0 800 1. 30% 1.42% -100 200 5.37% 5.91% 0 900 1.06\5 1.16% East-West and North-South are meters from Sutro Tower. Power density is in % of FCC Standard for public exposure. HE HAMMETT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN l'RANosco Figure 4K Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and EXisting with OTV Channels E-W N-S Existin~WithDTV E-W N-S Existin~WithPTV 0 1000 0.822% 0.896% 100 1700 0.516% C.629% 0 1100 0.795% 0.918% 100 1800 0.444% 0.596% 0 1200 0.732% 0.848% 100 1900 0.392% 0.519% 0 1300 0.665% 0.759% 100 2000 0.412% 0.496% 0 1400 0.692% 0.836% 100 2100 0.383% 0.451% 0 1500 0.637% 0.755% 200 -2400 0.125% 0.159% 0 1600 0.542% 0.631% 200 -2300 0.132% 0.:71% 0 1700 0.514% 0.628% 200 -2200 0.211% 0.290% 0 1800 0.439% 0.591% 200 -2100 0.348% 0.494% 0 1900 0.387% 0.523% 200 -2000 0.556% 0.750% 0 2000 0.406% 0.496% 200 -1900 0.553% 0.743% 0 2100 0.378% 0.448% 200 -1800 0.567% 0.710% 100 -2400 0.0987% 0.119% 200 -1700 0.618% 0.725% 100 -2300 0.0828% 0.101% 200 -1600 0.590% 0.726% 100 -2200 0.138% 0.179% 200 -1500 0.624% 0.823% 100 -2100 0.294% 0.394% 200 -1400 0.690% 0.849% 100 -2000 0.674% 0.873% 200 -1300 0.811% 0.901% 100 -1900 0.694% 0.938% 200 -1200 0.881% 1.02% 100 -1800 0.652% 0.854% 200 -1100 0.862% 1.11% 100 -1700 0.603% 0.722% 200 -1000 0.860% 1.01% 100 -1600 0.596% 0.756% 200 -900 0.998% 1.14% 100 -1500 0.634% 0.851% 200 -800 1. 48% 1.71% 100 -1400 0.680% 0.860% 200 -700 1.67% 1. 84% 100 -1300 0.838% 0.946% 200 -600 1. 96% 2.10% 100 -1200 0.937% 1. 09% 200 -500 2.38% 2.52% 100 -1l00 0.935% 1. 21% 200 -400 3.23% 3.44% 100 -1000 0.963% 1.08% 200 -300 4.82% 5.20% 100 -900 1. 04% 1.14% 200 -200 7.19% 7.80% 100 -800 1. 28% 1.51% 200 -100 7.23% 8.06% 100 -700 :.48% 1. 65% 200 0 7.30% 8.16% 100 -600 1. 82% 1. 98% 200 100 7.12% 7.88% 100 -500 2.47% 2.67% 200 200 4.90% 5.39% 100 -400 3.01% 3.20% 200 300 3.53% 3.85% 100 -300 4.45% 4.74% 200 400 2.82% 3.00% 100 -200 8.50% 9.01% 200 500 2.06% 2.18% 100 -100 11.1% 12.0% 200 600 1. 68% 1.78% 100 0 12.7% 14.3% 200 700 1.48% 1.57% 100 100 2.1.9% 13.8% 200 800 1.13% 1. 20% 100 200 6.46% 6.91% 200 900 0.951% 1.02% 100 300 4.21% 4.46% 200 1000 0.841% 0.907% 100 400 3.25% 3.49% 200 1100 0.754% 0.838% 100 500 2.11% 2.28% 200 1200 0.720% 0.805% 100 600 1. 64% 1.78% 200 1300 0.700% 0.804% 100 700 1. 42% 1.55% 200 1400 0.668% 0.788% 100 800 1.13% 1. 22% 200 1500 0.610% 0.717% 100 900 0.960% 1. 04% 200 1600 0.542% 0.620% 100 1000 0.832% 0.902% 200 1700 0.491% 0.592% 100 1100 0.801% 0.912% 200 1800 0.427% 0.569% 100 1200 0.746% 0.852% 200 1900 0.391% 0.513% 100 1300 0.679% 0.776% 200 2000 0.395% 0.471% 100 1400 0.698% 0.836% 200 2100 0.369% 0.432% 100 1500 0.641% 0.756% 300 -2400 0.117% 0.148% 100 1600 0.542% 0.626% 300 -2300 0.166% 0.211% East-West and North-South are meters from Sutro Tower. Power density is in % ofFCC Standard for public exposure. HE HAMMETT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRA."JCISCO Figure 4L Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S Existinl: WithDTV ~ N-S Existin~WithDIV 300 -2200 0.267% 0.372% 400 -1500 o.441% 0.542% 300 -2100 0.401% 0.588% 400 -1400 0.498% 0.564% 300 -2000 0.514% 0.703% 400 -1300 0.687% 0.759% 300 -1900 0.509% 0.662% 400 -1200 0.780% 0.858% 300 -1800 0.537% 0.659% 400 -1100 0.743% 0.860% 300 -1700 0.604% 0.709% 400 -1000 0.776% 0.890% 300 -1600 0.543% 0.662% 400 -900 0.935% Lon 300 -1500 0.557% 0.71.5% 400 -800 1. 69% :.93% 300 -1400 0.643% 0.762% 400 -700 1. 82% 2.07% 300 -1300 0.763% 0.839% 400 -600 2.05% 2.38% 300 -1200 0.827% 0.941% 400 -500 2.71% 3.19% 300 -1100 0.788% 0.982% 400 -400 3.33% 3.71% 300 -1000 0.790% 0.939% 400 -300 3.43% 3.72% 300 -900 0.955% 1.11% 400 -200 3.06% 3.26% 300 -800 1. 74% 1. 96% 400 -100 3.55% 3.95% 300 -700 1.87% 2.05% 400 0 3.91% 4.44% 300 -600 2.06% 2.21% 400 100 3.65% 4.09% 300 -500 2.54% 2.68% 400 200 2.87% 3.13% 300 -400 3.43% 3.69% 400 300 2.33% 2.55% 300 -300 4.55% 4.95% 400 400 1. 92% 2.16% 300 -200 4.98% 5.47% 400 500 1. 62% 1.77% 300 -100 4.75% 5.39% 400 600 1.44% 1. 53% 300 0 4.66% 5.27% 400 700 1. 36% 1. 42% 300 100 4.52% 5.00% 400 800 1.10% 1.15% 300 200 3.55% 3.97% 400 900 0.906% 0.957% 300 300 2.79% 3.10% 400 1000 0.759% 0.823% 300 400 2.38% 2.55% 400 1100 0.755% 0.805% 300 500 1. 89% 2.00% 400 1200 0.712% 0.763% 300 600 1.61% 1. 69% 400 1300 0.657% 0.740% 300 700 1. 46% 1.52% 400 1400 0.646% 0.720% 300 800 1.13% 1.19% 400 1500 O.604!~ 0.682% 300 900 0.949% 1.01% 400 1600 O.545'~ 0.609% 300 1000 0.823% 0.886% 400 1700 0.479% 0.560% 300 1100 0.724% 0.786% 400 1800 0.419% 0.536% 300 1200 0.706% 0.771% 400 1900 0.389% 0.495% 300 1300 0.706% 0.805% 400 2000 0.380% 0.449% 300 1400 0.648% 0.745% 400 2100 0.364% 0.417% 300 1500 0.594% 0.688% 500 -2400 0.0992% 0.119% 300 1600 0.546% 0.618% 500 -2300 0.115% 0.141% 300 1700 0.481% 0.571% 500 -2200 0.243% 0.316% 300 1800 0.419% 0.548% 500 -2100 0.435% 0.585% 300 1900 0.391% 0.507% 500 -2000 0.512% 0.652% 300 2000 0.380% 0.451% 500 -1900 0.531% 0.638% 300 2100 0.360% 0.417% 500 -1800 0.558% 0.650% 400 -2400 0.0796% 0.103% 500 -1700 0.521% 0.615% 400 -2300 0.148% 0.185% 500 -1600 0.416% 0.504% 400 -2200 0.246% 0.336% 500 -1500 0.427% 0.500% 400 -2100 0.393% 0.561% 500 -1400 0.519% 0.574% 400 -2000 0.519% 0.684% 500 -1300 0.637% 0.692% 400 -1900 0.536% 0.664% 500 -1200 0.698% 0.756% 400 -1800 0.553% 0.664% 500 -1100 0.698% 0.767% 400 -1700 0.569% 0.679% 500 -1000 0.650% 0.699% 400 -1600 0.458% 0.569% 500 -900 0.700% 0.765% East-West and North-South are meters from Sutro Tower. Power density is in % ofFCC Standard for public exposure. HE HAMMETT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRANasco Figure 4M Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density EXisting Stations, and Existing with DTV Channels E-W N-S Existin~WithDTV E-W N-S Existin~WithDTV 500 -800 0.986% 1.14% 600 -100 1. 95% 2.16% 500 -700 1.27% 1. 58% 600 a 1.75% 1. 99% 500 -600 1. 73% 2.18% 600 100 1. 68% 1.91% 500 -500 2.51% 2.83% 600 200 1.71% 1. 87% 500 -400 2.59% 2.95% 600 300 1. 65% 1.78% 500 -300 2.60% 2.88% 600 400 1.Q% 1. 54% 500 -200 2.59% 2.77% 600 500 1. 33% 1. 46% 500 -100 2.53% 2.80% 500 600 1.19% :.3H 500 0 2.46% 2.80% 600 700 1. 02% 1.13% 500 100 2.30% 2.60% 600 800 0.899% C.982% 500 200 2.17% 2.36% 600 900 0.837% C.904% 500 300 1. 95% 2.11% 600 1000 0.831% 0.902% 500 400 1. 62% 1.79% 600 1100 0.753% 0.810% 500 500 1.45% 1. 60% 600 1200 o.718% 0.784% 500 600 1. 32% 1. 44% 600 1300 0.695% 0.768% 500 700 1.19% 1.27% 600 1400 0.654% 0.706% 500 800 0.996% 1. 06% 600 1500 0.546% 0.594% 500 900 0.874% 0.928% 600 1600 0.424% 0.472% 500 1000 0.811% 0.875% 600 1700 0.436% 0.502% 500 1100 0.744% 0.788% 600 1800 0.374% 0.460% 500 1200 0.706% 0.760% 600 1900 0.319% 0.392% 500 1300 0.684% 0.761% 600 2000 0.333% 0.387% 500 1400 0.661% 0.721% 600 2100 0.331% 0.369% 500 1500 0.577% 0.637% 700 -2400 0.0441% 0.0458% 500 1600 0.471% 0.523% 700 -2300 0.0282% 0.0312% 500 1700 0.462% 0.534% :00 -2200 0.0613% 0.0723% 500 1800 0.398% 0.498% 700 -2100 0.209% 0.248% 500 1900 0.346% 0.432% 700 -2000 0.603% 0.700% 500 2000 0.354% 0.417% 700 -l900 0.555% 0.613% 500 2100 0.347% 0.392% 700 -1800 0.476% 0.515% 600 -2400 0.0825% 0.0931% 700 -1700 0.472% 0.550% 600 -2300 0.0680% 0.0803% 700 -1600 0.398% 0.474% 600 -2200 0.164% 0.205% 700 -1500 0.423% 0.491% 600 -2100 0.376% 0.479% 700 -1400 0.492% 0.554% 600 -2000 0.530% 0.648% 700 -1300 0.590% 0.660% 600 -1900 0.536% 0.618% 700 -1200 0.702% 0.768% 600 -1800 0.532% 0.600% 700 -llOO 0.763% 0.816% 600 -1700 0.488% 0.573% 700 -1000 o.719% 0.819% 600 -1600 0.405% 0.482% 700 -900 0.694% 0.807% 600 -1500 0.425% 0.490% 700 -800 0.680% 0.757% 600 -1400 0.513% 0.566% 700 -700 0.695% 0.744% 600 -1300 0.598% 0.641% 700 -600 0.721% 0.771% 600 -1200 0.666% 0.709% 700 -500 0.767% 0.857% 600 -1l00 0.702% 0.751% 700 -400 0.752% 0.789% 600 -1000 0.621% 0.665% 700 -300 0.923% 0.972% 600 -900 0.626% 0.683% 700 -200 1. 69% 1. 89% 600 -800 0.752% 0.843% 700 -100 1. 66% 1. 85% 600 -700 0.910% 1.10% 700 0 1. 60% 1. 80% 600 -600 1.19% 1.46% 700 100 1. 55% 1.74% 600 -500 1.61% 1. 80% 700 200 1. 56% 1. 71% 600 -400 1. 56% 1. 73% 700 300 1. 47% 1. 58% 600 -300 1. 76% 1. 92% 700 400 1. 32% 1.41% 600 -200 2.25% 2.42% 700 500 1.15% 1.25% East-West and North-South are meters from Sutro Tower. Power denSity is in % of FCC Standard for public exposure. HE HAMMETI & EDISON, INC. 961217 CON~TINGENG~E~ SAN FRAI"'1OSCO Figure 4N Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S Existin~WithDTV . E-W N-S EJtistin~WitbDTV 700 600 1. 00% :'.12% 80C 1300 0.651% 0.715% 700 700 0.893% 0.991% 800 1400 0.555% 0.606% 700 800 0.835% 0.976% 800 1.500 0.462% 0.516% 700 900 0.813% 0.933% 800 1600 0.383% 0.449% 700 1000 0.806% 0.880% 800 1700 0.359% 0.428% 700 1100 0.802% 0.900% 800 1800 0.321% 0.387% 700 1200 0.747% 0.825% 800 1900 0.294% 0.349% 700 1300 0.654% 0.719% 800 2000 0.313% o.352% 700 1400 0.594% 0.641% 800 2100 0.320% 0.349% 700 1500 0.513% 0.557% 900 -2400 O.0822~50.0936% 700 1600 0.435% 0.494% 900 -2300 O.0850~5 0.0929% 700 1700 0.387% 0.452% 900 -2200 0.189% 0.217% 700 1800 0.341% 0.411% 900 -2100 0.342% 0.398% 700 1900 0.314% 0.377% 900 -2000 0.397% 0.438% 700 2000 0.316% 0.362% 900 -1900 0.441% o.477% 700 2100 0.316% 0.349% 900 -1800 0.466% 0.503% 800 -2400 0.0587% 0.0642% 900 -1700 0.465% 0.516% 800 -2300 0.0452% 0.0488% 900 -1600 0.406% 0.467% 800 -2200 0.116% 0.134% 900 -1500 0.382% 0.467% 800 -2100 0.294% 0.347% 900 -1400 0.412% 0.535% 800 -2000 0.445% 0.494% 900 -1300 0.576% 0.737% 800 -1900 0.489% 0.531% 900 -1200 0.756% 0.943% 800 -1800 0.482% 0.518% 900 -1100 0.804% 0.999% 800 -1700 0.457% 0.524% 900 -1000 0.793% 0.941% 800 -1600 0.379% 0.456% 900 -900 0.757% 0.878% 800 -1500 0.379% 0.465% 900 -800 0.680% 0.851% 800 -1400 0.449% 0.552% 900 -700 0.629%; 0.696% 800 -1300 0.602% 0.73:% 900 -600 0.55H 0.578% 800 -1200 0.750% 0.885% 900 -500 0.478% 0.487% 800 -1l00 0.775% 0.875% 900 -400 O.282~5 0.288% 800 -1000 0.739% 0.867% 900 -300 0.284% 0.299% 800 -900 0.719% 0.850% 900 -200 0.704\5 0.807% 800 -800 0.671% 0.799% 900 -100 0.935% 1. 05% 800 -700 0.644% 0.708% 900 0 0.983 5 5 1.09% 800 -600 0.580% 0.608% 900 100 0.961% 1.07% 800 -500 0.526% 0.537% 900 200 0.954% 1. 05% 800 -400 0.338% 0.344% 900 300 0.932'% 1. 02% 800 -300 0.356% 0.372% 900 400 0.889% 0.969% 800 -200 0.884% 1.01% 900 500 0.844% 0.907% 800 -100 1.16% 1. 31% 900 600 0.790% 0.866% 800 0 1.22% 1.37% 900 700 0.764% 0.911% 800 100 1.19% 1. 33% 900 800 0.764% 0.875% 800 200 1.18% 1. 30% 900 900 0.766% 0.895% 800 300 1.16% 1. 25% 900 1000 0.767% 0.958% 800 400 1.11% 1. 20% 900 1100 0.745% 0.883% 800 500 0.987% 1.07% 900 1200 0.690% 0.801% 800 600 0.884% 0.977% 900 1300 0.619% 0.691% 800 700 0.820% 0.961% 900 1400 O.51~)% 0.583% 800 800 0.798% 0.935% 900 1500 0.394% 0.468% 800 900 0.791% 0.905% 900 1600 0.297% 0.372% 800 1000 0.789% 0.908% 900 1700 0.31~)% 0.389% 800 1100 0.784% 0.918% 900 1800 0.298% 0.363% 800 1200 0.733% 0.828% 900 1900 0.281% 0.330% East-West and North-South are meters from Sutro Tower. Power density is in % ofFCC Standard for public exposure. HE HAMMETf & EDISON, INC. 961217 CONSULTING ENGINEERS SA1'1 FRANOSCO Figure 4P Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S Existin~WithDlV ~ N-S Existin~WithDTV 900 2000 0.300% 0.335% 1100 -1900 0.379% 0.429% 900 2100 0.307% 0.333% 1100 -1800 0.411% 0.468% 1000 -2400 0.121% 0.135% 1100 -1700 0.544% 0.624% 1000 -2300 0.167% 0.189% 1100 -1600 0.596% 0.688% 1000 -2200 0.253% 0.290% 1100 -1500 0.538% 0.642% 1000 -2100 0.355% 0.408% 1100 -1400 0.434% 0.550% 1000 -2000 0.398% 0.442% 1100 -1300 0.381% 0.542% 1000 -1900 0.398% 0.435% HOO -1200 0.424% 0.639% 1000 -1800 0.425% 0.463% 1100 -1100 0.595% 0.806% 1000 -1700 0.504% 0.550% l100 -1000 0.746% 0.870% 1000 -1600 0.544% 0.607% 1100 -900 0.789% 0.905% 1000 -1500 0.506% 0.593% 1100 -800 0.758% 0.914% 1000 -1400 0.390% 0.512% 1100 -700 0.714% 0.803% 1000 -1300 0.486% 0.653% 1100 -600 0.695% 0.764% 1000 -1200 0.623% 0.830% 1100 -500 0.714% 0.780% 1000 -1100 0.775% 1. 03% l100 -400 0."741% 0.816% 1000 -1000 0.847% 0.995% 1100 -300 0.758% 0.855% 1000 -900 0.818% 0.936% 1100 -200 0.760% 0.884% 1000 -800 0.729% 0.892% 1100 -100 0.798% 0.955% 1000 -700 0.644% 0.709% 1100 a 0.762% 0.911% 1000 -600 0.603% 0.653% 1100 100 0.672% 0.792% 1000 -500 0.611% 0.673% 1100 200 0.663% 0.766% 1000 -400 0.578% 0.656% 1100 300 0.654% 0.736% 1000 -300 0.632% 0.735% 1100 400 0.636% 0.702% 1000 -200 0.917% 1. 04% 1100 500 0.609% 0.675% 1000 -100 0.886% 0.991% 1100 600 0.616% 0.683% 1000 0 0.854% 0.960% 1100 700 0.660% 0.740% 1000 100 0.832% 0.949% 1100 800 0.690% 0.817% 1000 200 0.823% 0.929% 1100 900 0.708% 0.848% 1000 300 0.775% 0.861% 1100 1000 0.687% 0.833% 1000 400 0.672% 0.736% 1100 1100 0.622% 0.754% 1000 500 0.716% 0.780% 1100 1200 0.577% 0.698% 1000 600 0.7:"3% 0.785% 1100 1.300 0.542% 0.698% 1000 700 0.709% 0.818% 1100 1400 0.481% 0.640% 1000 800 0.725% 0.839% 1100 1500 0.308% 0.431% 1000 900 0.736% 0.897% 1100 1600 0.172% 0.264% 1000 1000 0.729% 0.927% 1100 1700 0.211% 0.292% 1000 1100 0.697% 0.832% 1100 1800 0.227% 0.293% 1000 1200 0.640% 0.745% 1100 1900 0.237% 0.286% 1000 1300 0.574% 0.678% 1100 2000 0.26H 0.295% 1000 1400 0.473% 0.584% 1100 2100 O.268~1 0.292% 1000 1500 0.327% 0.430% 1200 -2400 0.0433% 0.0449% 1000 1600 0.216% 0.304% 1200 -2300 0.0146% 0.0156% 1000 1700 0.257% 0.333% 1200 -2200 0.101% 0.116% 1000 1800 0.269% 0.333% 1200 -2100 0.382'~ 0.453% 1000 1900 0.275% 0.323% 1200 -2000 0.375% 0.439% 1000 2000 0.276% 0.309% 1200 -1900 0.394% 0.471% 1000 2100 0.276% 0.299% 1200 -1800 0.452% 0.549% 1100 -2400 0.0554% 0.0576% 1200 -1700 0.607% 0.738% 1100 -2300 0.0463% 0.0489% 1200 -1600 0.627% 0.764% 1100 -2200 0.164% 0.186% 1200 -1500 0.571% 0.698% 1100 -2100 0.382% 0.443% 1200 -1400 0.489% 0.600% 1100 -2000 0.398% 0.450% 1200 -1300 0.391% 0.539% East-West and North-South are meters from Sutro Tower. Power density is in % ofFCC Standard for public exposure. HE HAMMETT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRANosco Figure 4Q Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels -BY-. N-S Existin~WithDTV . E-W N-S Existin~WithDTV 1200 -1200 0.410% 0.625% :300 -500 0.722% 0.846% 1200 -1100 0.556% 0.745% 1300 -400 0.763% o .919% 1200 -1000 0.670% 0.774% 1300 -300 0.760% 0.944% 1200 -900 0.731% 0.838% 1300 -200 0.730% 0.904% 1200 -800 0.761% 0.898% 1300 -100 0.680% 0.807% 1200 -700 0.768% 0.877% 1300 0 0.644% 0.757% 1200 -600 0.760% 0.857% 1300 100 0.620% 0.730% 1200 -500 0.732% 0.823% 1300 200 0.606% 0.725% 1200 -400 0.782% 0.877% 1300 300 0.574% 0.679% 1200 -300 0.783% 0.894% 1300 400 0.520% 0.596% 1200 -200 0.729% 0.857% 1300 500 0.542% 0.606% 1200 -100 0.739% 0.896% 1300 600 0.546% 0.602% 1200 0 0.700% 0.850% 1300 700 0.536% 0.603% 1200 100 0.621% 0.732% 1300 800 0.595% 0.687% 1200 200 0.608% 0.707% 1300 900 0.606% 0.714% 1200 300 0.598% 0.678% 1300 1000 0.553% 0.670% 1200 400 0.578% 0.643% 1300 1100 0.47H; 0.626% 1200 500 0.562% 0.624% 1300 1200 O.418~; 0.608% 1200 600 0.569% 0.630% 1300 1300 0.383~5 0.581% 1200 700 0.600% 0.661% 1300 1400 0.32n 0.495% 1200 800 0.655% 0.762% 1300 1500 0.232% 0.333% 1200 900 0.674% 0.790% 1300 1600 0.153% 0.213% 1200 1000 0.629% 0.745% 1300 1700 0.130% 0.187% 1200 1100 0.565% 0.694% 1300 1800 0.159% 0.212% 1200 1200 0.512% 0.663% 1300 1900 0.226% 0.277% 1200 1300 0.484% 0.680% 1300 2000 0.288% 0.320% 1200 1400 0.425% 0.596% 1300 2100 0.313% 0.340% 1200 1500 0.278% 0.391% 1400 -2400 0.0414% 0.0436% 1200 1600 0.155% 0.231% 1400 -2300 0.0277% 0.0284% 1200 1700 0.165% 0.239% 1400 -2200 0.0437% 0.0461% 1200 1800 0.188% 0.251% 1400 -2100 0.0533% 0.060n 1200 1900 0.223% 0.273% 1400 -2000 0.0211% 0.0242% 1200 2000 0.263% 0.297% 1400 -1900 0.153% 0.193% 1200 2100 0.281% 0.306% 1400 -1800 0.553% 0.757% 1300 -2400 0.0608% 0.0670% 1400 -1700 0.539% 0.741% 1300 -2300 0.00696% 0.00785% 1400 -1600 0.42'7% 0.558% 1300 -2200 0.0648% 0.0765% 1400 -1500 0.414% 0.529% 1300 -2100 0.322% 0.402% 1400 -1400 0.476% 0.578% 1300 -2000 0.323% 0.410% 1400 -1300 0.464% 0.583% 1300 -1900 0.463% 0.585% 1400 -1200 0.471% 0.664% 1300 -1800 0.611% 0.778% 1400 -1100 0.516% 0.687% 1300 -1700 0.669% 0.856% 1400 -1000 0.549% 0.642% 1300 -1600 0.601% 0.774% 1400 -900 0.588% 0.670% 1300 -1500 0.567% 0.70n 1400 -800 0.634% 0.714% 1300 -1400 0.543% 0.648% 1400 -700 0.602% 0.687% 1300 -1300 0.510% 0.641% 1400 -600 0.612% 0.714% 1300 -1200 0.511% 0.716% 1400 -500 0.687% 0.804% 1300 -1100 0.549% 0.728% 1400 -400 0.692% 0.830% 1300 -1000 0.610% 0.703% 1400 -300 0.682% 0.838% 1300 -900 0.660% 0.754% 1400 -200 0.665% 0.824% 1300 -800 0.712% 0.817% 1400 -100 0.657% 0.822% 1300 -700 0.734% 0.844% 1400 0 0.645% 0.808% 1300 -600 0.736% 0.853% 1400 100 0.618% 0.747% East-West and North-South are meters from Sutro Tower. Power denSity is in % of FCC Standard for public exposure. HE HAMMETT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRANOSCO Figure 4R Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DlV Channels E-W N-S Existing WlthrrrY E-W N-S Existing WithDTY 1400 200 0.546% 0.648% 1.500 900 0.298% 0.335% 1400 300 0.524% 0.621% J.500 1000 0.132% 0.148% 1400 400 0.526% 0.612% 1500 1100 0.210% 0.280% 1400 500 0.543% 0.623% 1500 1200 0.243% 0.380% 1400 600 0.544% 0.627% 1500 1300 0.219% 0.373% 1400 700 0.520% 0.601% 1500 1400 0.167% C.311% 1400 800 0.529% 0.605% 1500 1500 0.144% 0.248% 1400 900 0.326% 0.370% ::'500 1600 0.141% 0.206% 1400 1000 0.141% 0.155% 1500 :700 0.187% 0.261% 1400 1100 0.271% 0.364% :"500 1800 0.226% 0.279% 1400 1200 0.328% 0.519% 1500 1900 0.250% 0.292% 1400 1300 0.296% 0.482% 1500 2000 0.279% 0.316% 1400 1400 0.220% 0.374% 1500 2100 0.278% 0.318% 1400 1500 0.166% 0.261% 1600 -2400 0.0960% 0.107% 1400 1600 0.133% 0.185% 1600 -2300 0.0616% 0.0675% 1400 1700 0.147% 0.222% l600 -2200 0.0577% 0.0624% 1400 1800 0.185% 0.244% 1600 -2100 0.0581% 0.0627% 1400 1900 0.236% 0.280% 1600 -2000 0.0588% 0.0643% 1400 2000 0.286% 0.319% 1600 -1900 0.136% 0.158% 1400 2100 0.292% 0.324% 1600 -1800 0.254% 0.330% 1500 -2400 0.0557% 0.0591% 1600 -1700 0.292% 0.418% 1500 -2300 0.0514% 0.0529% 1600 -1600 0.289% 0.394% 1500 -2200 0.0433% 0.0451% 1600 -1500 0.311% 0.399% 1500 -2100 0.0308% 0.0330% 1600 -1400 0.385% 0.466% 1500 -2000 0.0168% 0.0182% 1600 -1300 0.396% 0.483% 1500 -1900 0.2.12% 0.133% :600 -1200 0.402% 0.524% 1500 -1800 0.386% 0.524% 1600 -1100 0.418% 0.554% 1500 -1700 0.393% 0.555% 1600 -1000 0.478% 0.599% 1500 -1600 0.339% 0.455% 1600 -900 0.506% 0.584% 1500 -1500 0.352% 0.455% 1600 -800 0.456% 0.511% 1500 -1400 0.433% 0.525% 1600 -700 0.470% 0.533% 1500 -1300 0.428% 0.530% 1600 -600 0.454% 0.526% 1500 -1200 0.435% 0.59:'..% 1600 -500 0.393% 0.475% 1500 -1100 0.473% 0.631% 1600 -400 0.481% 0.579% 1500 -1000 0.510% 0.618% 1600 -300 0.544% 0.662% 1500 -900 0.539% 0.616% 1600 -200 0.544% 0.675% 1500 -800 0.542% 0.604% 1600 -100 0.549% 0.677% 1500 -700 0.523% 0.591% 1600 0 0.537!f; 0.659% 1500 -600 0.524% 0.606% 1600 100 0.508% 0.654% 1500 -500 0.551% 0.651% 1600 200 0.500% 0.648% 1500 -400 0.590% 0.708% 1600 300 0.502% 0.638% 1500 -300 0.605% 0.745% 1600 400 0.502% 0.620% 1500 -200 0.596% 0.755% 1600 500 O.475~6 0.571% 1500 -100 0.613% 0.755% 1600 600 0.469% 0.548% 1500 a 0.607% 0.761% 1600 700 0.479% 0.546% 1500 100 0.574% 0.735% 1600 800 0.458% 0.513% 1500 200 0.511% 0.625% 1600 900 0.372% 0.427% 1500 300 0.505% 0.611% 1600 1000 0.276% 0.338% 1500 400 0.522% 0.631% 1600 1100 0.214% 0.273% 1500 500 0.521% 0.623% 1600 1200 0.187% 0.268% 1500 600 0.518% 0.608% 1600 1300 0.173% 0.292% 1500 700 0.506% 0.575% 1600 1400 0.160% 0.289% 1500 800 0.493% 0.552% 1600 1500 0.165% 0.287% East-West and North-South are meters from Sutro Tower. Power density is in % of FCC Standard for public exposure. HE HAMMETT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRANOSCO Figure 45 Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with OTV Channels E-W N-S ExistiDl~WithDJY E-W N-S Existin~WithDTY 1600 1600 0.182% 0.276% 1800 -2300 0.0718% 0.08SH 1600 1700 0.242% 0.306% 1800 -2200 0.192% 0.241% 1600 1800 0.272% 0.322% 1800 -2100 0.364% 0.482% 1600 1900 0.272% 0.317% 1800 -2000 0.421% 0.569% 1600 2000 0.271% 0.319% 1800 -1900 0.470% 0.645% 1600 2100 0.270% 0.324% 1800 -1800 0.428% 0.586% 1700 -2400 0.0843% 0.0965% 1800 -1700 0.321% 0.438% 1700 -2300 0.139% 0.156% 1800 -1600 0.206% 0.254% 1700 -2200 0.191% 0.231% 1800 -1500 0.189% 0.224% 1700 -2100 0.241% 0.311% 1800 -1400 0.261% 0.313% 1700 -2000 0.304% 0.401% 1800 -1300 0.286% 0.349% 1700 -1900 0.382% 0.504% 1800 -1200 0.293% 0.369% 1700 -1800 0.427% 0.570% 1800 -1100 0.274% 0.363% 1700 -1700 0.366% 0.505% 1800 -1000 0.308% 0.403% 1700 -1600 0.271% 0.360% 1800 -900 0.360% o.451% 1700 -1500 0.259% 0.326% 1800 -800 0.414% 0.503% 1700 -1400 0.317% 0.385% 1800 -700 0.395% 0.462% 1700 -1300 0.349% 0.424% 1800 -600 0.358% 0.429% 1700 -1200 0.354% 0.447% 1800 -500 0.326% 0.414% 1700 -1100 0.326% 0.435% 1800 -400 0.318% 0.426% 1700 -1000 0.377% 0.485% 1800 -300 0.337% 0.472% 1700 -900 0.428% 0.513% 1800 -200 0.390% 0.597% 1700 -800 0.439% 0.508% 1800 -100 0.445% 0.637% 1700 -700 0.410% 0.470% 1800 0 0.459% 0.599% 1700 -600 0.368% 0.434% 1800 100 0.442% 0.544% 1700 -500 0.323% 0.404% 1800 200 0.417~ 0.528% 1700 -400 0.347% o.447% 1800 300 0.412% 0.517% 1700 -300 0.378% 0.496% 1800 400 0.409~5 0.503% 1700 -200 0.419% 0.590% 1800 500 0.399% 0.477% 1700 -100 0.487% 0.646% 1800 600 0.384% 0.452% 1700 0 0.504% 0.626% 1800 700 0.366'!; 0.430% 1700 100 0.486% 0.587% 1800 800 0.364% 0.435% 1700 200 0.457% 0.552% 1800 900 0.364% 0.446% 1700 300 0.447% 0.534% 1800 1000 0.351% 0.448% 1700 400 0.442% 0.520% 1800 1100 0.328% 0.430% 1700 500 0.435% 0.505% 1800 1200 0.309% 0.410% 1700 600 0.420% 0.484% 1800 1300 0.296% 0.388% 1700 700 0.392% 0.454% 1800 1400 0.314% 0.391% 1700 800 0.410% 0.471% 1800 1500 0.320% 0.380% 1700 900 0.394% 0.462% 1800 1600 0.313% 0.367% 1700 1000 0.355% 0.434% 1800 1700 0.293% 0.345% 1700 1100 0.302% 0.394% 1800 1800 0.276% 0.331% 1700 1200 0.262% 0.368% 1800 1900 0.265% 0.329% 1700 1300 0.240% 0.355% 1800 2000 0.269% 0.347% 1700 1400 0.269% 0.379% 1800 2100 0.279% 0.369% 1700 1500 0.284% 0.374% 1900 -2400 0.0121% 0.0134% 1700 1600 0.294% 0.361% 1900 -2300 0.0170% 0.0199% 1700 1700 0.300% 0.352% 1900 -2200 O.0~i97% 0.0712% 1700 1800 0.288% 0.338% 1900 -2100 0.178% 0.222% 1700 1900 0.272% 0.324% 1900 -2000 0.413% 0.548% 1700 2000 0.266% 0.329% 1900 -1900 0.465% 0.648% 1700 2100 0.272% 0.344% 1900 -1800 0.363% 0.502% 1800 -2400 0.0329% 0.0373% 1900 -1700 0.251% 0.342% East-West and North-South are meters from Sutro Tower. Power density is in % ofFCC StaTuiard for public exposure. HE HAMMElT & EDISON, INC. 961217 CONSUl.TING ENGINEERS SAN FRANOSCo Figure 4T Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S Existin~WithDTY E-W N-S Existin~WithDTY 1900 -1600 0.151% 0.176% 2000 -900 0.351% 0.433% 1900 -1500 0.13 8% 0.156% 2000 -800 0.343% 0.440% 1900 -1400 0.220% 0.262% 2000 -700 0.353% 0.465% 1900 -1300 0.230% 0.284% 2000 -600 0.359% 0.484% 1900 -1200 0.243% 0.308% 2000 -500 0.345% 0.471% 1900 -1100 0.261% 0.336% 2000 -400 0.295% 0.449% 1900 -1000 0.279% 0.364% 2,000 -300 0.262% 0.432% 1900 -900 0.316% 0.412% 2000 -200 0.263% 0.416% 1900 -800 0.384% 0.489% 2000 -100 0.371% 0.492% 1900 -700 0.402% 0.509% 2000 0 0.393% 0.514% 1900 -600 0.385% 0.491% 2000 100 0.300% 0.453% 1900 -500 0.354% 0.457% .2000 200 0.348% 0.513% 1900 -400 0.330% 0.473% 2000 300 0.357% 0.507% 1900 -300 0.331% 0.514% 2000 400 0.337% 0.474% 1900 -200 0.395% 0.582% 2000 500 0.329% 0.458% 1900 -100 0.426% 0.593% 2000 600 0.328% 0.450% 1900 0 0.423% 0.590% 2000 700 0.331% 0.445% 1900 100 0.394% 0.581% 2000 800 0.321% 0.420% 1900 200 0.387% 0.518% 2000 900 0.314% 0.394% 1900 300 0.394% 0.513% 2000 1000 0.313% 0.378% 1900 400 0.384% 0.493% 2000 1100 0.336% 0.391% 1900 500 0.367% 0.469% 2000 1200 0.339% 0.386% 1900 600 0.360% 0.462% 2000 1300 0.323% 0.364% 1900 700 0.36:% 0.466% 2000 1400 0.306% 0.346% 1900 800 0.336% 0.434% 2000 1500 0.289% 0.333% 1900 900 0.324% 0.416% 2000 1600 0.273% 0.326% 1900 1000 0.323% 0.411% 2000 1700 0.266% 0.334% 1900 1100 0.320% 0.400% 2000 1800 0.269% 0.352% 1900 1200 0.322% 0.393% 2000 1900 0.278% 0.378% 1900 1300 0.325% 0.386% 2000 2000 0.286% 0.398% 1900 1400 0.323% 0.375% 2000 2100 0.285% 0.401% 1900 1500 0.312% 0.360% 2100 -24000.0823~; 0.0918% 1900 1600 0.293% 0.342% 2100 -2300 0.0657% 0.0731% 1900 1700 0.273% 0.330% 2100 -2200 0.0239% 0.0279% 1900 1800 0.264% 0.332% 2100 -2100 0.0226% 0.0275% 1900 1900 0.267% 0.351% 2100 -2000 0.272% 0.357% 1900 2000 0.278% 0.373% 2100 -1900 0.388% 0.524% 1900 2100 0.286% 0.392% 2100 -1800 0.356% 0.469% 2000 -2400 0.0342% 0.0367% 2100 -1700 0.278% 0.362% 2000 -2300 0.0414% 0.0439% 2100 -1600 0.269% 0.333% 2000 -2200 0.0163% 0.0184% 2100 -1500 0.276% 0.326% 2000 -2100 0.0196% 0.0237% 2100 -1400 0.288% 0.329% 2000 -2000 0.404% 0.530% 2100 -1300 0.307% 0.343% 2000 -1900 0.468% 0.641% 2100 -1200 0.329% 0.363% 2000 -1800 0.355% 0.476% 2100 -1100 O.353~; 0.389% 2000 -1700 0.246% 0.329% 2100 -1000 0.352~; 0.397% 2000 -1600 0.229% 0.279% 2100 -900 O.349~5 0.405% 2000 -1500 0.244% 0.282% 2100 -800 0.344% 0.414% 2000 -1400 0.276% 0.315% 2100 -700 0.34H 0.430% 2000 -1300 0.297% 0.337% 2100 -600 0.347'!i 0.460% 2000 -1200 0.316% 0.361% 2100 -500 0.352% 0.491% 2000 -1100 0.333% 0.388% 2100 -400 0.283% 0.429% 2000 -1000 0.345% 0.414% 2100 -300 0.227% 0.375% East-West and North-South are meters from Sutro Tower, Power density is in % of FCC Standard for public exposure. HE HAMMETT & EDISON, INC. 961217 CONSU'1.TING ENGINEERS SAN FRANCISCO Figure 4U Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-SExistin~WithDTV .~N-5Existin~ WithPTY 2100 -200 0.197% 0.324% 2200 500 0.333% 0.431% 2100 -100 0.140% 0.185% 2200 600 0.329% 0.407% 2100 0 0.145% 0.190% 2200 700 0.321% 0.382% 2100 100 0.197% 0.306% 2200 800 0.336% 0.387% 2100 200 0.278% 0.437% 2200 900 0.331% 0.373% 2100 300 0.320% 0.489% 2200 1000 0.314% 0.350% 2100 400 0.324% 0.479% 2200 1100 0.293% 0.324% 2100 500 0.326% 0.463% 2200 1200 0.285% 0.316% 2100 600 0.325% 0.440% 2200 1300 0.285% 0.324% 2100 700 0.324% 0.415% 2200 1400 0.274% 0.322% 2100 800 0.328% 0.401% 2200 1500 0.272% 0.332% 2100 900 0.323% 0.378% 2200 1600 0.276% 0.352% 2100 1000 0.313% 0.356% 2200 1700 0.284% 0.375% 2100 1100 0.320% 0.357% 2200 1800 0.289% 0.396% 2100 1200 0.317% 0.352% 2200 1900 0.285% 0.404% 2100 1300 0.306% 0.343% 2200 2000 0.276% 0.401% 2100 1400 0.289% 0.330% 2200 2100 0.265% 0.389% 2100 1500 0.276% 0.325% 2300 -2400 0.190% 0.239% 2100 1600 0.268% 0.331% 2300 -2300 0.173% 0.217% 2100 1700 0.271% 0.352% 2300 -2200 0.193% 0.259% 2100 1800 0.279% 0.377% 2300 -2100 0.230% 0.322% 2100 1900 0.286% 0.399% 2300 -2000 0.284% 0.393% 2100 2000 0.285% 0.407% 2300 -1900 0.324% 0.437% 2100 2100 0.276% 0.399% 2300 -1800 0.337% 0.445% 2200 -2400 0.158% 0.190% 2300 -1700 0.329% 0.424% 2200 -2300 0.108% 0.':'33% 2300 -1600 0.320%, 0.403% 2200 -2200 0.0820% 0.0977% 2300 -1500 0.30n 0.379% 2200 -2100 0.0862% 0.':'02% 2300 -1400 0.300% 0.358% 2200 -2000 0.186% 0.240% 2300 -1300 0.297% 0.346% 2200 -1900 0.294% 0.391% 2300 -1200 0.29415 0.335% 2200 -1800 0.350% 0.458% 2300 -1100 0.28115 0.317% 2200 -1700 0.314% 0.403% 2300 -1000 0.298\5 0.333% 2200 -1600 0.291% 0.364% 2300 -900 0.308!5 0.345% 2200 -1500 0.281% 0.340% 2300 -800 0.309!5 0.347% 2200 -1400 0.286% 0.332% 2300 -700 0.327't 0.370% 2200 -1300 0.297% 0.335% 2300 -600 0.332% 0.384% 2200 -1200 0.313% 0.347% 2300 -500 0.329% 0.390% 2200 -1l00 0.331% 0.364% 2300 -400 0.317% 0.387% 2200 -1000 0.333% 0.368% 2300 -300 0.277% 0.353% 2200 -900 0.338% 0.379% 2300 -200 0.206% 0.281% 2200 -800 0.352% 0.403% 2300 -100 0.111% 0.139% 2200 -700 0.340% 0.401% 2300 0 0.108% 0.13 6% 2200 -600 0.339% 0.415% 2300 100 0.188% 0.259% 2200 -500 0.346% 0.442% 2300 200 0.289% 0.373% 2200 -400 0.278% 0.389% 2300 300 0.330% 0.410% 2200 -300 0.214% 0.332% 2300 400 o.3Ei% 0.386% 2200 -200 0.164% 0.270% 2300 500 0.316% 0.377% 2200 -100 0.0552% 0.0782% 2300 600 0.317% 0.369% 2200 0 0.0544% 0.0773% 2300 700 0.319% 0.362% 2200 100 0.137% 0.217% 2300 800 0.301% 0.339% 2200 200 0.220% 0.336% 2300 900 0.293% 0.328% 2200 300 0.288% 0.411% 2300 1000 0.289% 0.325% 2200 400 0.322% 0.435% 2300 1100 0.272% 0.308% East-West and North-South are meters from Sutro Tower. Power density is in % of FCC Standard for public exposure. HE HAMMEn & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRANOSCO Figure 4V Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and EXisting with OTV Channels E-W N-S Existin~WithDTV ~N-SExistin~ WlthDTY 2300 1200 0.261% 0.300% 2400 1900 0.264% 0.375% 2300 1300 0.259% 0.305% 2400 2000 0.254% 0.367% 2300 1400 0.279% 0.338% 2400 2100 0.248% 0.358% 2300 1500 0.287% 0.359% 2500 -2400 0.272% 0.346% 2300 1600 0.289% 0.374% 2500 -2300 0.286% 0.372% 2300 1700 0.292% 0.390% 2500 -2200 0.288% 0.379% 2300 1800 0.286% 0.396% 2500 -2100 0.291% 0.388% 2300 1900 0.275% 0.393% 2500 -2000 0.296% 0.395% 2300 2000 0.264% 0.385% 2500 -1900 0.305% 0.404% 2300 2100 0.255% 0.374% 2500 -1800 0.314% 0.412% 2400 -2400 0.231% 0.295% 2500 -1700 0.323% 0.417% 2400 -2300 0.232% 0.301% 2500 -1600 0.332% 0.421% 2400 -2200 0.256% 0.348% 2500 -1500 0.339% 0.421% 2400 -2100 0.282% 0.392% 2500 -1400 0.340% 0.415% 2400 -2000 0.302% 0.413% 2500 -1300 0.318% 0.386% 2400 -1900 0.317% 0.426% 2500 -1200 0.303% 0.365% 2400 -1800 0.325% 0.429% 2500 -1100 0.298% 0.361% 2400 -1700 0.331% 0.429% 2500 -1000 0.276% 0.333% 2400 -1600 0.334% 0.423% 2500 -900 0.266% 0.321% 2400 -1500 0.331% 0.410% 2500 -800 0.274% 0.329% 2400 -1400 0.322% 0.391% 2500 -700 0.266% 0.320% 2400 -1300 0.304% 0.362% 2500 -600 0.268% 0.323% 2400 -1200 0.289% 0.339% 2500 -500 0.284% 0.343% 2400 -1100 o.279% 0.325% 2500 -400 0.282% 0.341% 2400 -1000 0.278% 0.320% 2500 -300 0.273% 0.332% 2400 -900 0.279% 0.321% 2500 -200 0.258% 0.317% 2400 -800 0.283% 0.324% 2500 -100 0.209% 0.266% 2400 -700 0.290% 0.335% 2500 0 0.211% 0.267% 2400 -600 0.298% 0.346% 2500 100 0.261% 0.319% 2400 -500 0.307% 0.360% 2500 200 0.276% 0.334% 2400 -400 0.303% 0.358% 2500 300 0.277% 0.335% 2400 -300 0.280% 0.336% 2500 400 0.274% 0.333% 2400 -200 0.229% 0.283% 2500 500 0.276% 0.334% 2400 -100 0.163% 0.195% 2500 600 0.270% 0.326% 2400 0 0.160% 0.193% 2500 700 0.254% 0.308% 2400 100 0.222% 0.277% 2500 800 0.258% 0.313% 2400 200 0.289% 0.348% 2500 900 0.258% 0.313% 2400 300 0.307% 0.364% 2500 1000 0.255%; 0.312% 2400 400 0.297% 0.353% 2500 1100 0.274% 0.336% 2400 500 0.297% 0.350% 2500 1200 0.28H5 0.346% 2400 600 0.293% 0.343% 2500 1300 0.282% 0.349% 2400 700 0.283% 0.330% 2500 1400 0.277\5 0.349% 2400 800 0.277% 0.320% 2500 1500 0.279 5 5 0.359% 2400 900 0.271% 0.313% 2500 1600 0.284!!i 0.374% 2400 1000 0.266% 0.310% 2500 1700 0.274'% 0.370% 2400 1100 0.269% 0.316% 2500 1800 0.263% 0.363% 2400 1200 0.265% 0.316% 2500 1900 0.254% 0.355% 2400 1300 0.265% 0.321% 2500 2000 0.249% 0.350% 2400 1400 0.280% 0.346% 2500 2100 0.246% 0.344% 2400 1500 0.291% 0.369% 2600 -2400 0.297% 0.367% 2400 1600 0.296% 0.388% 2600 -2300 0.298% 0.373% 2400 1700 0.285% 0.385% 2600 -2200 0.297% 0.377% 2400 1800 0.274% 0.381% 2600 -2100 0.296% 0.380% East-West and North-South are meters from Sutra Tower. Power density is in % of FCC Standard for public exposure, HE HAMMElT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRA.'1OSCO Figure 4W Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with OTV Channels E-W N-S Existin2 WitbDTV ~ N-S Existin2 WithDTV 2600 -2000 0.294% 0.381% 2700 -1300 0.315%0.393~ 2600 -1900 0.298% 0.386% 2700 -1200 0.322% 0.405% 2600 -1800 0.304% 0.392% 2700 -1100 0.320% 0.404% 2600 -1700 0.312% 0.400% 2700 -1000 0.317!t; 0.404% 2600 -1600 0.324% 0.410% 2700 -900 o.313!ti 0.403% 2600 -1500 0.327% 0.409% 2700 -800 0.30n 0.399% 2600 -1400 0.317% 0.393% 2700 -700 0.302~i 0.399% 2600 -1300 0.319% 0.394% 2700 -600 O.292~; 0.393% 2600 -1200 0.324% 0.399% 2700 -500 O.278~; 0.381% 2600 -1100 0.325% 0.402% 2700 -400 0.278% 0.378% 2600 -1000 0.305% 0.379% 2700 -300 0.277% 0.375% 2600 -900 0.295% 0.369% 2700 -200 0.268% 0.363% 2600 -800 0.298% 0.376% 2700 -100 0.252% 0.345% 2600 -700 0.283% 0.359% 2700 0 0.250% 0.342% 2600 -600 0.270% 0.346% 2700 100 0.262% 0.356% 2600 -500 0.263% 0.340% 2700 200 0.266% 0.361% 2600 -400 0.272% 0.352% 2700 300 0.263% 0.359% 2600 -300 0.277% 0.356% 2700 400 0.258% 0.355% 2600 -200 0.268% 0.345% 2700 500 0.263% 0.364% 2600 -100 0.224% 0.301% 2700 600 0.265% 0.364% 2600 0 0.224% 0.301% 2700 700 0.258!5 0.351% 2600 100 0.268% 0.344% 2700 800 0.260!5 0.349% 2600 200 0.271% 0.348% 2700 900 0.272'5 0.359% 2600 300 0.261% 0.338% 2700 1000 0.283'5 0.371% 2600 400 0.248% 0.323% 2700 1100 0.267% 0.350% 2600 500 0.253% 0.330% 2700 1200 0.258% 0.337% 2600 600 0.260% 0.338% 2700 1300 0.253% 0.329% 2600 700 0.268% 0.344% 2700 1400 0.257% 0.333% 2600 800 0.262% 0.335% 2700 1500 0.247% 0.322% 2600 900 0.265% 0.338% 2700 1600 0.235% 0.310% 2600 1000 0.276% 0.349% 2700 1700 0.237% 0.314% 2600 1100 0.274% 0.347% 2700 1800 0.235% 0.313% 2600 1200 0.280% 0.354% 2700 1900 0.237% 0.314% 2600 1300 0.286% 0.362% 2700 2000 0.251% 0.327% 2600 1400 0.275% 0.351% 2700 2100 0.258% 0.332% 2600 1500 0.263% 0.342% 2800 -2400 0.294% 0.353% 2600 1600 0.255% 0.338% 2800 -2300 0.298% 0.359% 2600 1700 0.260% 0.349% 2800 -2200 0.300% 0.361% 2600 1800 0.256% 0.347% 2800 -2100 0.300% 0.363% 2600 1900 0.250% 0.340% 2800 -2000 0.300% 0.364% 2600 2000 0.248% 0.336% 2800 -1900 o.297% 0.363% 2600 2100 0.251% 0.336% 2800 -1800 0.297% 0.364% 2700 -2400 0.300% 0.364% 2800 -1700 0.299% 0.368% 2700 -2300 0.300% 0.367% 2800 -1600 0.290% 0.357% 2700 -2200 0.298% 0.368% 2800 -1500 0.287% 0.355% 2700 -2100 0.297% 0.369% 2800 -1400 0.296% 0.368% 2700 -2000 0.295% 0.370% 2800 -1300 0.303% 0.381% 2700 -1900 0.296% 0.373% 2800 -1200 0.306% 0.389% 2700 -1800 0.299% 0.378% 2800 -1100 0.299% 0.385% 2700 -1700 0.305% 0.385% 2800 -1000 0.308% 0.400% 2700 -1600 0.307% 0.384% 2800 -900 0.310% 0.408% 2700 -1500 0.306% 0.381% 2800 -800 0.301% 0.404% 2700 -1400 0.304% 0.378% 2800 -700 0.311% 0.423% East-West and North-South are meters from Sutro Tower. Power density is in % ofFCC Standard for public exposure. HE HAMMElT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRANOSCO Figure 4X Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S Existing WithDTV ~ N-S Existin~WithDTY 2800 -600 0.309% 0.429% 2900 100 0.287% 0.422% 2800 -500 0.299% 0.423% 2900 200 0.286% 0.421% 2800 -400 0.293% 0.415% 2900 300 0.285% 0.422% 2800 -300 0.287% 0.407% 2900 400 0.284% 0.422% 2800 -200 0.282% 0.400% 2900 500 0.258% 0.388% 2800 -100 0.280% 0.397% 2900 600 0.247% 0.369% 2800 0 0.277% 0.394% 2900 700 0.244% 0.358% 2800 100 0.275% 0.392% 2900 800 0.244% 0.352% 2800 200 0.275% 0.393% 2900 900 0.237% 0.337% 2800 300 0.277% 0.398% 2900 1000 0.221% 0.311% 2800 400 0.281% 0.404% 2900 1100 0.228% 0.314% 2800 500 0.281% 0.402% 2900 1200 0.220% 0.300% 2800 600 0.270% 0.385% 2900 1300 0.209% 0.282% 2800 700 0.250% 0.354% 2900 1400 0.205% 0.271% 2800 800 0.254% 0.355% 2900 1500 0.208% 0.271% 2800 900 0.264% 0.361% 2900 1600 0.218% 0.279% 2800 1000 0.268% 0.360% 2900 1700 0.214% 0.274% 2800 1100 0.252% 0.338% 2900 1800 0.218% 0.276% 2800 1200 0.234% 0.314% 2900 1900 0.226% 0.283% 2800 1300 0.220% 0.295% 2900 2000 0.232% 0.287% 2800 1400 0.234% 0.305% 2900 2100 0.244% 0.299% 2800 1500 0.231% 0.300% 3000 -2400 0.271% 0.325% 2800 1600 0.223% 0.291% 3000 -2300 0.281% 0.332% 2800 1700 0.21'% 0.284% 3000 -2200 0.292% 0.342% 2800 1800 0.217% 0.283% 3000 -2100 0.299% 0.348% 2800 1900 0.225% 0.290% 3000 -2000 0.299% 0.347% 2800 2000 0.250% 0.315% 3000 -1900 0.314% 0.361% 2800 2100 0.260% 0.324% 3000 -1800 0.323% 0.369% 2900 -2400 0.283% 0.339% 3000 -1700 0.318% 0.365% 2900 -2300 0.292% 0.347% 3000 -1600 0.316% 0.366% 2900 -2200 0.298% 0.353% 3000 -1500 0.306% 0.360% 2900 -2100 0.302% 0.357% 3000 -1400 0.287% 0.347% 2900 -2000 0.304% 0.360% 3000 -1300 0.278% 0.345% 2900 -1900 0.292% 0.347% 3000 -1200 0.273% 0.345% 2900 -1800 0.285% 0.340% 3000 -1100 0.272% 0.350% 2900 -1700 0.286% 0.343% 3000 -1000 0.273% 0.360% 2900 -1600 0.284% 0.343% 3000 -900 0.274% 0.370% 2900 -1500 0.284% 0.347% 3000 -800 0.274!f; 0.379% 2900 -1400 0.291% 0.359% 3000 -700 O.279~; 0.396% 2900 -1300 0.284% 0.357% 3000 -600 0.277% 0.404% 2900 -1200 0.283% 0.361% 3000 -500 0.272% 0.405% 2900 -1100 0.292% 0.378% 3000 -400 0.275'~0.410% 2900 -1000 0.286% 0.377% 3000 -300 0.275% 0.410% 2900 -900 0.287% 0.386% 3000 -200 0.272% 0.407% 2900 -800 0.297% 0.407% 3000 -100 0.269% 0.404% 2900 -700 0.293% 0.411% 3000 0 0.267% 0.402% 2900 -600 0.288% 0.412% 3000 100 0.26=,% 0.400% 2900 -500 0.283% 0.413% 3000 200 O.26~l%0.399% 2900 -400 0.295% 0.431% 3000 300 0.262% 0.397% 2900 -300 0.298% 0.434% 3000 400 0.258% 0.393% 2900 -200 0.294% 0.429% 3000 500 0.243% 0.375% 2900 -100 0.291% 0.427% 3000 600 0.239% 0.366% 2900 0 0.289% 0.424% 3000 700 0.238% 0.356% East-West and North-South are meters from Sutro Tower. Power density is in % ofFCC Standard for public exposure. HE HAMMETT & EDISON, INC. 961217 CONSULTING ENGINEERS SAN FRANOSCO Figure 4Y Sutro Tower, Inc. ? Digital Television ? San Francisco, California Tabulation of Calculated RF Power Density Existing Stations, and Existing with DTV Channels E-W N-S Existing WithDTV E-W N-S Ex.istin~WithDTV 3000 800 0.228% O.33t.% 3000 900 0.222% 0.319% 3000 1000 0.218% 0.307% 3000 1100 0.212% 0.293% 3000 1200 0.211% 0.287% 3000 1300 0.213% 0.283% 3000 1400 0.207% 0.270% 3000 1500 o.207% 0.264% 3000 1600 0.213% 0.267% 3000 1700 0.223% 0.276% 3000 1800 0.229% 0.282-% 3000 1900 0.233% 0.283% 3000 2000 0.234% 0.283% 3000 2100 0.240% 0.289% East-West and North-South are meters from Sutro Tower. Power density is in % of FCC Standard for public exposure. HE HAMMETI & EDISON, INC. CONSULTING ENGINEERS SAN FRANCISCO 961217 Figure 4Z Sutro Tower, Inc. ? Digital Television ? San Francisco, California Comparison of Measured RF Power Density with Calculated Values Measurement Measured Calculated Location 1 Power Density 2 Power Density 3 % FCC Standard 4 1 0.0229 mW/cm 2 0.0247 mW/cm 2 11.4% ') 0.0234 0.0269 11.5.... 3 0.0077 0.0171 6.98 4 0.00076 0.00663 2.54 5 0.0014 0.00951 3.88 6 0.0020 0.00350 1.64 7 0.00011 0.00110 0.470 8 0.00038 0.000880 0.407 9 0.00045 0.000700 0.316 10 0.00013 0.00139 0.529 I Selected arbitrarily at various distances from Sutro Tower; shown on Figure 2 2 Measured on December 5, 1996, with Holaday HI-3004 Broadband Exposure Meter 3 Based on formulas in Appendix B; see also Figure 4 4 Based on appliable limits for public exposures of unlimited duration HE HAMMETf & EDISON, INC. , CONSULTING ENGINEERS SA,'J FRANOSCO 961217 Figure 5 National Council on Radiation Protection and Measurements Report No. 86 (Published 1986) "Biological Effects and Exposure Criteria for Radiofrequency Electromagnetic Fields" Radio Frequency Protection Guide Frequency Electromagnetic Fields _ Contact Currents Applicable Electric Magnetic Equivalent Far-Field (mA) Range Field Strength Field Strength Power DenSity (MHz) (V/m) (Nm) (mW/cm 2 ) 0.3 - 1.34 614 614 1.63 1.63 100 100 200 1.34 - 3.0 614 823.8/f 1.63 2.19/f 100 /80/1' 200 3.0 - 30 1842/f 823.8/f 4.89/f 2./9/f 900/[: 180/1' 200 30 - 300 61.4 27.5 0.163 0.0729 1.0 0.2 no limit 300 - 1,500 3.541f 1.591J Ifll06 1]7238 fJ300 f/1500 no limit 1.500 - 100,000 137 61.4 0.364 0.163 5 I no limit Note: f is frequency of emission, in MHz. Occupational Exposure --- Public Exposure - - - Power Densitv (mW/cn"; ) 1000 100 10 - 1 - 0.1 - HE Contact 1000 - Current (rnA) 100- I I I r I r 0.1 1 10 100 10 3 1()4 10 5 Frequency (MHz) HAMMETI & EDISON, INC. CONSULTING ENGINEERS SAN FRA."lCJSCO NCRP StandaTl Appendix I- Calculation Methodology Determination by Computer of Compliance with Human Exposure limitations The U.S. Congress has required of the FCC that it evaluate its actions for possible significant impact on the environment. In Docket 79-144, the FCC adopted the radio frequency protection guide of the American National Standards Institute Standard C95.1-1982, "Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields. 300 kHz to 100 GHz." Exposures are to be averaged over a six-minute period. In 1992, ANSI published a revised standard, C95.1-1992, which defined "controlled" and "uncontrolled" environments, setting for the latter limits generally five times more restrictive. The C95.1-1992 controlled (i.e., occupational) limits are approximately the same as in C95.1 1982. In Docket 93-62, the FCC adopted the exposure limits for field strength and power density recommended in Report No. 86, "Biological Effects and Exposure Criteria for Radiofrequency Electromagnetic Fields," published in 1986 by the National Council on Radiation Protection and Measurements. a standard very similar to C95.1-1992. The effective date for applying this standard to FCC licensees is September 1, 1997. The FCC Office of Science and Technology Bulletin No. 65 (October 1985) gives the formula for calculating power density from an individual radiation source: S - 2.56 x 1.64 x 100 x RFF2 x [O.4xVERP + AERP] . mWI 2 power density - 41tD2 ,10 cm , where VERP = total peak yisual ERP for NTSC TV stations, in kilowatts, AERP = total gural (or gverage for DTV stations) ERP, in kilowatts, RFF = relative field factor at the direction to the actual point of calculation, and D = distance from the center of radiation to the point of calculation, in meters. The factor of 2.56 accounts for the increase in power density due to ground reflection. The factor of 1.64 is the gain of a half-wave dipole relative to an isotropIC radiator. The factor of 0.4 converts peak visual ERP (for NTSC TV stations) to an average RMS value: for FM stations, of course, and for DTV stations the value of VERP is zero. The factor of 100 in the numerator converts to the desired units of power density. The above formula, by itself, is adequate for calculating the power density from RF sources that have line of-sight to the calculation point. The signal levels produced by radio and TV stations are affected by the nature of the terrain between the source (i.e., Sutro Tower) and the reception point. For instance, an intervening hill may considerably attenuate the signal at those points that are blocked by it. Although transmitting sites are generally high to minimize the effects of terrain. there will still be some locations where reception is impaired due to terrain obstruction. For those locations where terrain obstruction is significant, the result of the above "free space" formula must reduced by a loss factor based upon the degree and type of blockage. The Terrain Integrated Rough Earth Model (HTIREM") is used to calculate the amount of attenuation due to terrain effects. This model evaluates the profile between the source and each receive site and, based on the geometry of the profile, selects automatically the most probable propagation model to calculate the loss. For this project, a custom computer program has been developed to calculate the power density as a fraction of the NCRP Public Limit at some 8,900 points in San Francisco. The operation of the program is as follows: first, the antenna height, relative field factors due to the antenna azimuth and elevation pattern, and effective radiated power are input for each station at Sutro Tower. The program then calculates for each station the vertical terrain profile to each calculation point, and determines the amount of additional loss, if any, to be added. Due to the large height of Sutro Tower, about 85% of the calculation points are within line of-sight, and the formula above was applied without modification. For the remaining points, a loss factor was added to the result. The calculated power density for each station is then converted to a fraction of the applicable NCRP-86 public limit, which ranges from 0.2 mW/cm 2 for the FM stations and the VHF TV stations to 0.521 mW/cm 2 for UHF Channel 66 Finally, the fractions contributed by each station are summed at each point. HE HAMMEn' & EDISON, INC. CONSUl.TING ENGINEERS SAN FRANCISCO Methodology Appendix B 8.0 Appendice::. APPENDIX B: TECHNICAL REPORT BIOLOGICAL EFFECTS OF RADIOFREQUENCY RADIAnON (RFR) POSSIBLE HEALTH EFFECTS OF RFR ON NEARBY HUMANS FROM SUTRO TOWER DIGITAL TELEVISION BROADCASTS July 9, 1997 Peter Polson, Ph.D AUSA Research Cupertino, California and Louis N Heynick, M. S Consultant Palo Alto, California Prepared for S Maxwell and Woodward-Clyde Consultants Oakland, California Contributions by: Asher Sheppard Peer Reviewed by: C.K Chou Sutra' appendIces 07/06/97 Appendix B Biological Effects of RFR TABLE OF CONTENTS Section 1.0 INTRODUCTION 1.1 RFR SAFE1Y GUIDELINES 1.2 DIGITAL TV MODULATION PATTERN 1.3 DTV SERVICE EFFECTIVE RADlATED POWER 2.0 INTERACTIONS OF RFR WITH BIOLOGICAL ENTmES 2.1 THERMAL INTERACTIONS AND SARS 2.2 NONTHERMAL INTERACTIONS AND SARS 2.3 RFR AND POWERLINE-FREQUENCY FIELDS 3.0 SUMMARY OF CURRENT KNOWLEDGE ABOUT RFR BIOEFFECTS 3.1 EPIDEMIOLOGIC/OCCUPATIONAL STUDIES 3.2 CONGENITAL ANOMALIES 3.3 RFR AND OCULAR CHANGES IN HUMANS 3.4 AUDITORY EFFECTS IN HUMANS 3.5 RFR SHOCK AND BURN 4.0 STUDIES OF RFR EFFECTS IN ANIMALS 41 EYE DAMAGE BY RFR IN ANIMALS 4.2 AUDITORY EFFECTS IN ANIMALS 43 MUTAGENESIS. CYTOGENETIC EFFECTS. AND CARCINOGENESIS 4.3.1 Mutagenic And Cytogenetic Effects In Microorgamsms and Fruit Flies 4.3.2 Mutagenic. CytogenetIc and DNA Effects in Mammals and Mammalian Tissues and Cells 4.3.3 Cancer Induction or Promotion in Ammal Experiments 43.4 In VItro Cancer Initiation or Promotion 4.4 TERA.TOGENESIS 4.4. 1 Insects 4.4.2 Birds 4.4.3 Mice and Hamsters 4.4.4 Rats 4.4.5 Nonhuman Primates 45 NERVOUS SYSTEM 4.5.1 Blood-Brain-Barrier Effects 4.5.2 Neural Tissues: In Vitro Studies 4.5.3 Histopathology and Histochemistry ofthe Central Nervous System: In VIVO Studies 8-1 B-1 8-7 B-8 B-8 8-Q B-I0 B-l1 8-12 B-12 8-20 B-23 B-25 B-26 B-26 B-26 B-27 8-28 B-28 B-28 B-30 B-34 B-34 B-35 B-35 B-36 B-37 B-38 B-38 B-39 B-40 B-40 Appendix B Biological Effects of RFR TABLE OF CONTENTS Section 4.5.4 EEG- and Evoked-Response Changes 4.5.5 Calcium Efflux 4.5.6 Cellular Effects of Modulated RFR 4.5.7 BehavioraL Neurochemical and Neuropharmacologic Effects of Pulsed and CW Microwaves on Rats 4.6 IMMUNOLOGY AND HEMATOLOGY: IN VITRO STUDIES 4.6.1Leukoc~teStudies 4.6.2 ErythrOCyte Studies 4.7 IMMUNOLOGY AND HEMATOLOGY: IN VIVO STUDIES 4.7.1 Effects of Exposures on Immunological Parameters 4.7.2 Effects of Chrome Exposure on Health. Longevity, and Resistance to Disease 4.8 PHYSIOLOGY AND BIOCHEMISTRY 4.8.1 Metabolism and Thermoregulation 48.2 Endocnnolog) 4.8.3 Cardiovascular Effects 4.8.3.1 In Vl/ro Studies 4.8.3.2 In VIVO Studies 49 RFR EFFECTS ON NATURALISTIC BEHAVIOR. REFLEX ACTIVITY. LEARNING. AND PERFORMANCE OF TRAINED TASKS 4.91 Rodents 4.9.2 Nonhuman Primates 4.10 RFR AND DRUGS 4.11 CELLULAR AND SUBCELLULAR EFFECTS - STRUCTURES AND CONSTITUENTS OF MICROORGANISMS AND OTHER SINGLE-CELL SYSTEMS B-41 8-42 B-44 8-45 B-46 8-46 B-47 B-48 B-49 B-49 B-50 8-51 8-52 8-54 8-54 8-56 B-58 8-58 8-61 B-65 8-68 5.0 UNRESOLVED ISSUES 8-69 6.0 MISCONCEPTIONS 8-70 7.0 GENERAL CONCLUSIONS B-70 7.1 ACTUAL OR PRESUMED EXPOSURE OF HUMANS 8-71 7.2 STUDIES WITH ANIMALS 8-72 73 STUDIES 'W1TH ANIMAL CELLS AND TISSUES B-72 8.0 REFERENCES 8-73 1.0 INTRODUCTION This Technical Report contains analyses ofthe potential bioeffects ofRFR and their relevance to possible health effects of exposure to the RFR from the Sutro Tower Digital TV transmitters on human populatlons in its vicinity. The analyses are based on reviews of papers selected as being representative ofth,eman~ thousands published in scientific journals, typically after peer review, through about mid-1997 With a fe". exceptions, presentations at scientific symposia or abstracts thereof have been excluded on the assumptions that they were not peer-reviewed or that detailed peer-reviewed accounts ofsuch studies may appear subsequently. Some analyses included here were derived from three general reviews: Heynick (1987), and Heynick and Polson (1996a, 1996b). Assessed in the first repmi: were more than 500 detailed re:views and analyses of research papers published through about mid-I 986 . The report by Heynick and Polson (1996a) includes analyses ofpapers on RFR teratogenesis derived from Heynick (1987) but also analyse:s of papers on that topic published subsequently. Similarly, included inHe~.nickand Polson (1996b) are analyses of epidemiologic studies and studies on RF exposures ofhuman volunteers. Both 1996 reports were completed in 1994. The first section below summarizes RFR human-exposure guidelines adopted or under consideration by several organizations, and places the RFR levels expected from the Sutro Tower Digital TVtr~UlSmittersin relation to those guidelines. The proposed ten new Sutro Tower Digital TV transmitters will operate m the frequency band from 500 to 734 MHz (Hammett and Edison, 1997). Electromagnetic energy at such frequencies occupies a portion ofthe spectrum which is referred to as microwaves. Because there is no possibility that members ofthe general public would be expose:d to RFR levels higher than allowed by the guidelines, this report pays particular attention to scientific information relevant to exposures below the safety guideline limits. Current safety standards are based on scientific data for exposures oVler a range of mtensitles. some ofwhich are well above the levels permitted by safety standards The mam value of research conducted at high levels is the formulation of a solid basis for safety guidelines. but such data arc sometimes important in assessing biological responses found in research conducted at lower intenSIties 1.1 RFR SAFETY GUIDELINES Terms such as "safety standards" and "exposure standards" generally refer to, and are frequently used interchangeably \\ith. specifications or guidelines on maximum permissible exposure levels to electromagnetic fields. Guidelines differ for exposures to the: general public and for exposures occurring in occupations settings where persons are aware ofthe presence of RFR. In both situations. the safety levels are usually expressed as maximum permissible incident field intensities and/or power densities in specific frequency ranges averaged over specified exposure penods In most guidelines for human exposure to RFR. the maximum permissible exposures (MPEs) are stated in terms ofthe maximum allowable incident power densities. expressed in milliwatts per square centimeter (mW/em") or in watts per square meter (W/m c , with 1 W/m" == 0.1 mW/cm"). Such MPEs are selected on the basis ofthe highest values of "specific absorption rate" (SAR) that were found not to be harmful to animals in experimental studies. SAR is defined as the rate at which RFR energy is absorbed in any small volume ofa body. and is usually expressed in watts per kilogram (Wlkg) ofthe mass in that volume (or sometimes in milliwatts per gram, with 1 mWJg == I W/kg). For any specific value of incident power density, the SAR thus defined varies with location \\'lthin the body, so it is often called the "local SAR" Guidelines are based primarily on "whole-body" exposure. Spatial averages are obtained from internal SARs when an entire silhouette ofa body facing a source is exposed. but separate consideration is given for partial-body exposures to RFR from sources vcr\' close to the body Appendix B Biological Effects of RFR Modem RFR safety standards reflect a historical process which may be noted in the following summanes ofstandards developed in recent decades. In 1982, the American National Standards Institute (ANSI) issued guidelines for human exposure to RFR. prepared by its Subcommittee C95.IV (ANSI. 1982). Those guidelines were frequency-dependem and applicable to both occupational exposure and exposure of the general public. They covered thefrequenc~ range from 300 kHz to 100 GHz and were based on a whole-body SAR limit of 4 Wlkg. This criterion was based on many RFR-exposure studies on animals published in the scientific literature up to that tIDle which showed hazardous effects for whole-body exposures above 4 W/kg, but no demonstrable hazardous effects below 4 W/kg. A safety factor of 10 was applied, reducmg the maximum allowable whole-bod: SAR to 0.4 Wlkg. For frequencies where body dimensions are similar to the wavelength ofthe RFR.. the body absorbs energy resonantly and SAR varies significantly with frequency. As a resull for certam frequencies the limits on incident power density were dependent on frequency. The lowest limiL I mW/cm:, was for the range 30-300 MHz, within which resonant absorption ofRFR by the human body is highest. In recognition ofthe need to set limits for intense exposures ofshort duration. a 6-minute period was set as the time over which exposures may be averaged. Therefore, an exposure lasting three minutes could be at twice the level of a continuous exposure. The American Conference ofGovernmental Industrial Hygienists published threshold limit valU(:s (TLVs) also based on 4 Wlkg with a safety factor of 10, but intended for occupatIOnal exposures only (ACGIH. 1984). Those TLVs were intended for use in the practice of industrial hygiene only by persons trained In that discipline. The l-mW/cm: lowest limit in the 1982 ANSI guidelines was also specified in ACGIH (1984), but extended only from 30 to 100 MHz and rose \\ith a slope moo at 100 MHz to 10 mW/cm" at I GHz. The difference was based on the premise that children. who have hIgher whole-body resonant frequencIes than adults (see SectIOn 2.1), are not likely to be occupationally exposed to RFR Also, the lower frequency limit for the IOO-mW/cm: TLV of the ACGIH gUIdelines was at 10 kHz instead of300 kHz. As noted above. the 1984 ACGIH gUIdelines were based on whole-body SAR. but they did not provide Iimlts for the occurrence of RF shocks or bums under some conditions (essentially unn:lated to whole-body exposure). Instead. the guidehnes suggested procedures for aVOiding such potential hazards In 1986. Scientific Committee 53 ofthe National Council on Radiation Protection and Measun;:ments (NCRP) had issued its report (NCRP. 1986), which contained recommendations ofspecific exposure limits for the frequency range 300 kHz to 100 GHz. Those limIts were also based on 4 W/kg, but wi.th a safety factor of 50 for the general population rather than 10. The corresponding lowest incident-power-density limit was 0.2 mW/cm c for the frequency range 30-300 MHz. The limits in ANSI (1982) (embodying the safety factor of 10) were recommended for occupational exposure. The fivefold lower value for the general population relatIve to I mW/cm: (the lowest value in me 1982 ANSI guidelines) was based on the assumption that the general public is exposed continuously (168 hours per week) and that the ratio of 40 hours in the work week to 168 hours IS approximately 0.2. The Implication was that exposure at low levels. such as at the hmits prescribed in ANSI (1982), could be cumulative and potentially harmful to the more sensitive subpopulations of the general public, such as infants, the aged, and the infinn. However, the eXlstence of RFR threshold levels appears to have been Ignored, and there is no experimental evidence that those subpopulations would be at any greater risk from chronic exposure at or below the Iinuts specified in ANSI (1982). Since 1995, the NCRP has been engaged in reviewing its recommendations on RFR-exposure hmlts, using findings in papers published in scientific journals after those considered in the preparatIOn of the NCRP (1986) document. {'I",J(\£./Q'7 Appendix B. Biological Effects of RFR The International Non-Ionizing Radiation Committee ofthe International Radiation Protection AssocIation (IRPNINIRC), with representatives from Australia. France. Federal Republic of Germany. Italy. Netherlands, Sweden. the United Kingdom, and the United States. published guidelines (IRPA, 1988) for exposure ofthe general public and occupatiOnally to RFR in the frequency range 0.1-300 GHz Environmental health criteria issued bv the World Health On!arnzation (WHO. 1981) served as the -~ rationale. The limits for occupational exposure, averaged over any 6-mmute period. are sho'WTI in Table 1. In the range 10 MHz upward. they are based on a whole-body SAR of0.4 W /kg. and are expressed as limits on the RMS electric field (E) and magnetic field (H) and their equivalent plane v..·ave power densities (P oG ) For 10 MHz and lower, the linuts are stated solely as root-mean-square (RMS) electric and magnetic fields. TABLE 1: IRPAJINIRC (1988) MAXIMUM PERMISSIBLE LIMITS FOR OCCUPATIONAL EXPOSURE TO RFR Frequency f E H Peq (MHz) (Vim) (Nm) (W/m 2 ) 0.1-1 614 1.6/f > 1-10 614/f 16/f > 10-400 61 0.16 10 >400-2000 3(-Jf) 0.008(-Jf) £'40 >2000-300.000 137 0.36 50 1 £/400 For part-body exposure in the range 10 MHz upv..·ard. the maximum SARs are 20 W/kg in the extremities (hands. V.TIsts. feet. and ankles) and 10 W/kg in any other part of the body. The lImits for exposure of the general publIc. shO\\TI In Table: 2. are based on a whole-body SAR of 0.08 W/kg (a fifth ofthe occupational SAR). also averaged over <JJ1Y 6-minute period. TABLE 2: IRPAJINIRC (1988) MAXIMUM PERMISSIBLE LIMITS FOR GENERAL PUBLIC EXPOSURE TO RFR Frequency f E H Peq Peq (MHz) (Vim) (Nm) (W/m 2 ) (mW/cm") 01-1 87 O.23/(-Jf) > 1-10 87/(-Jf) 0.23/("Jf) > 10-400 27.5 0.073 2 0.2 >400-2000 1.375(-Jf) 0.0037(-Jf) f/200 f/2000 >2000-300000 61 0.16 10 I The IRPAIINIRC guidelines (1988) also specified a maximum body-to-ground current of200 rnA and suggested limits on pulsed RFR per se. About shocks and bums, the guidelines state: "Hazards ofRF burns should be eliminated by linuting currents from contact with metal objects In most situations this Appendix B. Biological Effects of RFR may be achieved by reducing the E values from 614 to 194 V/m in the range from O. I to I MHz and from 614/fto 194/...Jf) in the range from> I to 10 MHz ... In general, RF burns will not occur from currents on point contact of 50 rnA or less." About pulsed RFR. the guidelmes suggested that the pulse pOWf:rdensi~ (averaged over the pulse duration) not exceed 1000 times the specified average plane wave power denslt;. limits. or that the peak field strengths not exceed 32 times the specified field strengths. In 1991, Standards Coordinating Committee (SCC) ofthe Institute ofElectrical and Electronic Engineers (IEEE), which had taken over the functions of ANSI Subcommittee C95.IV in 1988, issued a revision of the 1982 ANSI guidelines. Those revised guidelines were adopted by ANSI in 1992 and are cited herein as ANSIJIEEE (1992). The ANSIIIEEE (1992) guidelines cover the frequency range from 3 kHz to 300 GHz and separately state maximum allowable RF exposure in "uncontrolled environments" (generally accessible by the ge:neral public) and "controlled environments" (such as occupational exposure). Both are based on a maXImum whole-body SAR of 4 Wlkg, above which possibly hazardous RFR-bioeffects have been demonstrated m studies with laboratory animals. Wherever the guidelines for controlled and uncontrolled enVlTonments differ. the differences reflect application ofmore conservative safety factors for uncontrolled enVlfonments The limits for uncontrolled environments are based on a safety factor of 50 (to 0.08 W/kg). From 100 to 300 MHz. the limit on averaged powerdensi~IS 0.2 mW/cm:: the limitrises in accordance \\1th the formula f/1500 from 0.2 mW/cm: at 300 MHz to 10 mW/cm: at IS GHz. and is 10 mW/cm: in the frequency range 15 to 300 GHz (\\1th the frequency fin MHz)In the frequency range from 3 kHz to 134 MHz. the averaging time is 6 minutes. and between 3.0 MHz and 3 GHz. it IS 30 minutes. In the transition range 1.34-30 MHz. the averaging time is given by f2/03 (nsmg from 6 to 30 minutes \\1th frequency) Between 3 GHz and 15 GHz. however. the averaging tIme IS gIven by 90,000/[ thus decreasing with frequency to 6 minutes again at 15 GHz. Between 15 GHz and 300 GHz. the formula for averaging time is (616.000)/f:. thus decreasmg to only about 10 seconds at 300 GHz. The lImits for controlled environments are based on a safety factor of 10 (to 0.4 W/kg). For frequencIes between 100 MHz and 300 MHz. the limit on average power density is 1.0 mW/cm:; the limit rises in accordance \\1th £1300 from 10 mW/cm: at 300 MHz to 10.0 roW/em: at 3 GHz, and is 10.0 mW/cm: in the frequency range 3-300 GHzThe values are to be averaged over any 6-minute period, but (unlike for uncontrolled environments) for the entIre frequency range up to IS GHz On the other hand. the formula for averaging time in the range 15-300 GHz is again glVl:n by (6l6.600)/f : Also included in the ANSIJIEEE (1992) guidelines are ma.ximum allowable values for RF current flow induced \\ithin the feet ofa person immersed in an RF field or by the person's contact with an inanimate object (e.g. a fence or vehicle) electrically charged by ImmerSIOn In an RF field. The ANSIJIEEE (1992) guidelines are currently undergoing the (nominally 5-year cyclic) examination for reaffirmation or revision of its proviSIOns by the IEEE see 28, based on critical analyses ofthe research papers in current databases on RFR-bioeffects published In SCientific journals For more than a decade. the Environmental ProtectIOn Agency (EPA) had been planning to issue RF exposure guidelines for the general population, but has not done so to date In 1995, the EPA announced its intention to issue general-population guidelines for exposure to levels of RFR that can cause thermal effects, but shelved that plan shortly afterward. In the absence ofan overall mandatory Federal exposure Sutro EIR '. AIlDendix B R-4 f\7/f\{..!l)7 Appendix B Biological Effecl:s of RFR standard (but not necessarily for that reason), various state, county. and municipal bodies have promulgated ordinances on exposure ofthe general public to RFR that are usually more stringent than those of ANSI (1982) or ANSlJlEEE (1992). In 1985, the Federal CommunicatIOns Commission (FCC) had adopted the ANSI (1982) guidelines as a standard applicable to persons or non-governmental organizations licensed by the FCC to operate RFR transmitters, thus rendering it a mandatory rather than a voluntary federal standard. On 8 April 1993, the FCC issued a "NOTICE OF PROPOSED RULE MAKING" (FCC. 1993) to consider the adoption ofthe ANSIJIEEE (1992) standard to replace the ANSI (1982) standard In that notice, the FCC had requested comments and recommendations from various federaL state. and local municipal bodies: industrial organizations. including those in the wireless communIcations businesses: and committees engaged in preparing or revising exposure guidelines. In a "REPORT AND ORDER" dated I August 1996 (FCC, 1996), the FCC noted receipt ofover 100 responses. including recommendations from the EPA that the FCC adopt a mixwre ofthe exposure lomts recommended in the NCRP (1986) document and those in the ANSI( 1982) standard. to the ex1:ent such hmlts pertam to its jurisdictional areas. The stated basis for USf: ofthe exposure limits recommended in NCRP (1986) is that where they differ from those in ANSIJIEEE (1992), they would be more protective of the general public. This point has been questioned because ofthe lack ofsupporting evidence. Several opposing responses submitted by various other organizations and individuals (including agencies m the Department ofDefense) were CIted but not discussed in FCC (1996). A major objection in some ofthose responses was to the use ofthe NCRP (1986) recommendations. Thus. as detailed in FCC (1996). that agency has accepted many (but not aU) ofthe recommendations by the EPA. and has adopted the standards for occupatIOnal/controlled andgeneral~populationJuncontrolled exposures shown respectively In Tables 3 and 4 TABLE 3 FCC (1996) MAXIMUM PERMISSIBLE LIMITS FOR OCCUPATIONAL/CONTROLLED EXPOSURE TO RFR Frequency f E H P eq * Averaging Time (MHz) (V/m) (Nm) (mW/cm::) (mmutes) 0.3-3.0 614 1.63 100 6 30-30 I842/f 4.89/f 900/f2 6 30-300 614 0.163 1.0 6 300-1500 £1300 6 1500-100 000 5 6 *P eq = Free-space equivalent power density Appendix B Biological Effects of RFR TABLE 4: FCC (1996) MAXIMUM PERMISSIBLE LIMITS FOR GENERAL POPULATIONfUNCONTROLLED EXPOSURE TO RFR Frequency f E H Peq* Averaging Time (MHz) (V/m) (Nm) (mW/cm") (minutes) 0.3-1.34 614 1.63 100 30 1.34-30 824/f 2.19/f 180/fl 30 30-300 27.5 0.073 0.2 30 300-1500 £'1500 30 1500-100000 1.0 30 *peq = Free-space equivalent power density Among the major similarities and differences between the FCC (1996) and ANSIfIEEE (1992) standards are: 1) Both standards are largely based on a whole-body SAR of4 W!kg, reduced by specific: safety factors. 2) The FCC (1996) standard only covers the frequency range from 300 kHz to 100 GHz, whereas the frequency range ofthe ANSlIlEEE (1992) standard is from 3 kHz to 300 GHz. 3) In both standards, the lowest maximum permissible mcident free-space power density for occupational/controlled exposures is 1 mW/cm2 for the frequency range 100-300 MHz, with an averagmg tune of 6 minutes 4) Similarly in both standards. the lowest maximum pCffillssible incident free-space power denSity for general-publIc/uncontrolled exposures is 0.2 mW/cm2 (reduction factor of 5) for the same frequency range, with an averaging time of 30 minutes 5) In both standards. the MPEs for occupational/controlled exposures in the frequency range 300 1500 MHz are the same. fJ300 The MPEs for the frequency range 1500-3000 MHz in the ANSlIlEEE (1992) standard are also given by £1300. nsing to 10 mW/cm2 at 3.0 GHz, and remaining at that value to 300 GHz However, the MPEs In FCC (1996) rise to only 5 mW/cm2 at 1.5 GHz and remain at that value to 100 GHz Ithe upper frequency limit ofFCC (1996)]. 6) For general-publIc/uncontrolled exposures in the frequency range 3000-15000 MHz [3-15 GHz], the ANSIIIEEE (1992) standard prescribes the formula m500, yielding 10 mW/cm2 at 15 GHz, a value also specified for the range 15-300 GHz. In the FCC (1996) standard, the fonnula fJl500 is applicable only in the range 300-1500 MHz, rising to 10 mW/cm2 at 1.5 GHz and remaining at that value to 100 GHz. 7) Contrary to the point offered in FCC (1996) about providing more protection to the general public (by use ofNCRP. 1986), the averaging times in ANSIfIEEE (1992) for general-public/uncontrolled exposures in the frequency range 30-100 GHz are progressively shorter than 30minutl~Swith increasing frequency, thus rendering the MPEs of ANSllIEEE (1992) more stringent than those Appendix B Biological Effects of RFR recommended in FCC (1996). At 15 GHz. for example. the total maximum pennissible energy denslt\ equivalent to 5 mW/cm":. for 30 minutes is 9 J/cm c (FCC. 1996), whereas for 10 mW/cm: for 6 minutes it is only 3.6 J/cm-:' (ANSIJIEEE, 1992). Such total-energy calculations are pertment pnmarily to incident RFR in the form of very short individual pulses of extremely high peak power density. In such cases. the corresponding average power denSIties per pulse would be inversely proportional to the averagmg time. Formal protests about adoption of the exposure standard contained in the FCC (1996) document have been filed by vanous organizations. including the Department of Defense. Those protests have been djrected primarily toward the absence ofscientific justification for the preference in the use ofthe 10-year-<lId NCRP (1986) document over the ANSIJIEEE (1992) standard (where they differ), against the alleged improper procedures used in the adoption ofthe new FCC standa.rd. and questions ofjurisdiction among the federal agencies. On December 24, 1996, the FCC released a First Memorandum Opinion and Order, FCC 96-487. e:\.1ending the transition period for detennining compliance with their new standard from January 1. 1997. to September 1, 1997. 1.2 DIGITAL TV MODULATION PATIERN \\!hen RFR is used for heating. as in the case ofdiathermy. microwave ovens, and industrial processes such as glue curing, plastic sealing. and induction heating. modulation is unimportant. RFR used for these purposes is classified as continuous wave (CW) and is unmodulated (although inadvertent amplitude modulation can occur) Radar systems use pulse-modulated RFR having pulse widths that are typically in the range ofone to several microseconds with repetitIOn rates of several hundreds or thousands of pulses per second. Pulse modulation is a particular type of amplitude modulation (AM). but is not often labeled as AM. Specialized biologic research studies (e.g., calcium efflux studies. see Section 4.4.5. below) have used AM RFR v.ith sinusoidal modulation at single frequencies such as 10. 16.30,60. or 120 Hz. A complete specification ofthis type of AM requires the carrier frequency. modulation frequency. depth ofmodulation. and peak envelope amplitude Commercial radio and television broadcasting involve AM or frequency modulation (FM) in which modulation ofthe carrier ("station frequency") is created by the speech. music or picture content ofthe program. Unlike single frequency AM used in some research. broadcast modulation contains a constantly changing assortment offrequencies. As a consequence. AM stations broadcast over a narrow range of frequencies (sidebands) centered on the ongmal camel' frequency. The carrier is the only frequency when there is no modulation. that is. ifthe station's voice or music program is silent. Frequency modulation is the second form of modulation for commercial broadcasting In this case the speech and musical frequencies are encoded as shifts in carrier frequency Like an AM station. an FM station occupies a band of frequencies surrounding the carrier. Television Signals occupy a band of frequencies in which both AM and FM modulation are used. The AM part of the signal is used for the picture information and the FM part for the sound. Appendix B BiologIcal Em:cts of RFR Digital TV uses a fonn ofmodulation which is different from both existing forms of AM and FM becausl.: both video and audio SIgnals are represented by a digital code. The code is expressed by eight different amplitude levels ofa brief pulse which, unlike the case for radar, is followed by another pulse in a stead\ stream ofpulses of varying amplitude. However, as is true for all other modulation schemes. DTV reqUIres a band of frequencies adjacent to the carrier frequency. The modulation scheme is called 8-level vestigIal sideband, where "vestigial sideband" refers to an engineering techruque which eliminates an unnecessar: sideband in order to make most efficient use ofthe spectrum. The rapid, nearly random sequence of shIfhng amplitudes has a noise-like character which is unlike the single-frequency AM used in biological research and is more like the signal generated by conventIOnal TV. However, a prominent feature of conventIOnal TV signals is the regular appearance of relatively strongs~nchronizingpulses for the raster scanning of the picture at 30 frames per second These contribute modulations at 60 Hz and 15.75 kHz. In the case of DTV. there is a single pilot tone which occurs at a frequency of 12.9 kHz and it is at a low level compared \\lth the total SIgnal, that is. it adds only 0.3 dB to the total transmitted power of the DTV signal Based upon this comparison of modulation characteristics. DTV signals are distinct from all signal~"pes used in health-related research. However, based on spectral and temporal properties. DTV bears resemblance to fonns of RFR used in existing research. In order ofdecreasing degrees of resemblance. DTV resembles standard broadcast TV signals, broadcast FM signals, broadcast AM signals. CW sources, and radar. Because commercial AM radio operates at frequencies several hundred times lower than DTV, exposures near AM towers and near the Sutro DTV tower are not especially similar. It should also be noted that radar systems employ a range of frequencies mcluding frequencies lower and higher lthan DTV and use a range ofpower levels. Traffic radar requires relatively low level signals whereas long-range military surveillance needs higher power. The various~"pesof radar use avane~of pulse widths and repetitIon patterns. These features make biologIcal and epIdemIOlogical studIes of radar exposure least relevant to DTV 1.3 DTV SERVICE EFFECTIVE RADIATED POWER DTV service IS expected to use average effectIve radIated powers that are below the present NTSC analog system peak power. This means that a DTV station would radiate a signal \vith an averageeffi~ctive radiated power that is about one-eighth (12 percent) of the present average power radiated by the traditional television technology As a consequence. \\-lth introduction ofDTV, public exposure to RFR due to the DTV signal alone would actually be only a fraction ofthe present values associated with the NTSC system. However, in view ofthe manner in which the FCC has deCIded that the DTV system shall be implemented in the U. S.. an approximate 9 to 15 year penod will result in which DTV signals will be broadcast simultaneously with the current NTSC signals During this period ofoverlap, the additional DTV service will slightly increase ambient environmental RF fields from the television service In tenns of average RF field exposure levels. this will amount to an anticipated 12 percent increase 2.0 INTERACTIONS OF RFR WITH BIOLOGICAL ENTITIES The interactions of RFR inCIdent on a biologIcal body are dependent on the electromagnetic properties of the body's constituents and their distributIon within the body However, except in a number ofspecies with special sensing abilities, most tissues are essentially nonmagnetic, so any effects depend primarily on the interactions of the internal electrical field component of the RFR (generated from both the incident electric and magnetic field components) \\ith the dielectric (resistive and capacitive) properties of the body. as well as on the RFR's characteristics (its frequency, power density. polarization). Sutro EIR \ Appendix B B-R Appendix B. Biological Effe:cts of RFR The refractive index ofany material is related to Its dielectric constant. RFR is reflected and refracted at boundaries betweenregio~of differing dielectric properties, such as at the air-surface interface of abod~. for the same physical reasons as those that apply to light incident at an air-glass interface. Such transmissions and reflections also occur at internal boundaries between constituents haVing diffe:rent dielectric properties, thereby affecting the variation ofelectric fidd v.ith internal location. The fraction ofthe incident power density that enters a body undergoes progressive attenuation\-\ith depth because ofenergy absorption. The extent ofsuch attenuation is termed the "penetration depth" or "skm depth" For an ideal specimen consisting ofa single, uniformly distributed constituent, and with the RFR directed perpendicularly to its surface, the penetration depth is the distance into the specimen at which the power density is diminished, by absorption, to about 14% of its entrance value In the RFR-bioeffects literature, the energy absorbed by a body from an incident electromagnetic field IS usually quantified by SAR (defined above). The local SAR at any site within a body depends on the characteristics ofthe incident RFR (carrier frequency, modulation, amplitudes and directions of its components) and on the properties ofthe body and location ofthe site. For bodies of complex shape and large internal spatial variations in properties, local SAR values are difficult to determine by experiment or by calculation. Instead, the whole-body SAR representing the spatial average SAR for the body, is often used because it can be determined v.ithout information about internal variations in local SARs. Researchers have calculated whole-body SARs for models of relatively simple geometry such as spheroids, ellipsoids, and cylinders that have weights and dimensions approximately representative of various species, including humans. Others have experimentally verified such calculations by exposing physical models in various orientations to linearly polarized plane-wave RFR and determining distributions of heal: produced therein. Details of such dOSimetry investigations are discussed in the Techmcal Report. Many Important results oftheoretIcal and experimental mvestlgations have been presented in four handbooks Issued by the U.S. Air Force. Durney (1986), the last handbook issued, summarizes the data in previous editIOns and contains other pertinent information as wdl Ofparticular interest are the plots of calculated whole-body SAR versus frequency for prolate-spheroIdal models ofan "average" man, woman, and 5-year-old child for exposure to I mW/cm c in three onentatlOns. 21 THERMAL INTERACTIONS AND SARS For exposure ofany given model to linearly polarized plane-wave RFR. the largest value of whole-body SAR occurs when the longest dimension of that model is parallel to the electric-field component ofthe RFR and \vhen the wavelength ofthe RFR is about 2.5 times the longest dimension ofthat model (or conversely, the longest dimenSIOn is 0.4 ofa wavelength). The adjective "resonant" is used for that wavelength or for its corresponding frequency; at resonance, the model absorbs RFR energy much like a lossy half-wave dipole antenna. That exposure arrangement is called the E-polanzaton Exposures at other orientations vield lower SARs. Specifically, the resonant frequency for the average man is about 70 MHz (when insulated from ground). At this frequency, the whole-body SAR is about 0.2 Wlkg for an incident plane-wave power density of I mW/cm c This SAR is about one-sixth ofhis resting metabolic rate or one-twentieth to one-ninetieth ofhis metabolic rate when doing exercises ranging from walking to sprinting. By calculation, exposure ofa man at this SAR (to I mW/cm C ) for, say, 1 hour would produce a mean temperature increase ofabout (12°C if Sutro EIR . AppendIX B B-9 07/06/97 Appendix B. Biological Effects of RFR no heat-removal mechanisms were operating (conduction. convection. radiation). Actual temperature Increases would be smaller with such heat-exchange mechanisms present. In addition, the compensation provided by the thermoregulatory systems of live mammals may prevent any nses in body temperature Similarly, the resonant frequency for a prolate-spheroidal model of an average woman IS about 80 MHz. and her mean SAR is about the same as for the average model man. For the model of a 5-year-old child. the resonant frequency is about 110 MHz, and the resonant SAR is about 0.3 W/kg per mW/cm: By contrast, the resonant frequency for a prolate-spheroidal model ofa medium rat is about 650 MHz. and the resonant whole-body SAR is about 0.8 W/kg per mW/cm 2 rIllese values and those for otherlaborato~ animals used ill RFR-bioeffects studies are important in assessing the results of such animal studies relative to possible effects in humans At the Sutro Tower Digital TV transmitters' frequencies, which are above the resonant frequencies of humans, the whole-body SAR of an average adult ill the E-polarization is only about 0.02 W/kg per mW/cm:. Therefore. a I-hour continuous exposure of an average adult to 500 MHz at, say, 0.1 mW/cm: would cause a theoretical temperature rise ofonly 0.002°C, a completely negligible change. The Sutro Tower Digital TV exposures, in publicly accessible areas, will therefore give rise to negligible temperature changes. RFR pulses ofappropriate characteristics are knO\\TI to be perc{:ived by some humans as apparent sound (the RFR-auditory effect). Pulsed RFR has also been reported to produce other effects, such as alterations of the blood-brain barrier and behavioral changes in animals. Other researchers were unable to confirm that pulsed RFR at nonthermal time-averaged levels alters the BBB or adversely affects behavior. There is no experimental evidence that theRFR-audito~'effect IS harmful to humans or animals nor are the Sutra Tower DTV signals capable of producing theRFR-audito~effixt Some researchers who used RFR amplitude-modulated at specific low frequencies--primarily below about 30 Hz but up to about 400 Hz- have reported biological effects from the amplitude modulation per se. notably the calcium-efilux effect. and have regarded those reports as evidence of possibly harmful nonthermal RFR bioeffects. It should be noted that speculations about the implications for hazards associated with altered cellular calcium have not yet been demonstrated by experiment and purported mechanisms for the calcium efflux effect r,emain controversial (Myers and Ross, 1981: Albert et aL 1987: Halle. 1988: Sandweiss. 1990: Adailr. 199 L Prasad et aL 1991). See section 4.5.5 for additional discussion of the literature on calcium efflux and sectIOn 4.56 for other research on the effects of modulated RF 2.2 NONTHERMAL INTERACTIONS AND SARS As just shO\\TI, it is impossible that there would be a biologically significant change in body temperature as a result ofexposures to the public from Sutro Tower Digital TV RFR. In the absence ofany hazard from heat. nonthermal interactIOns remain the main focus of Inquiry into potential adverse effects of Sutro Tower RFR In past RFR research. a relatively important area of study involved modulated RFR signals. Because reported effects depended on speCific forms of amphtude modulation and not overall SAR, this research was identified with potential nonthermal mechanisms of interaction. In order to use RFR for communications, the signal must be modulated. but there are many forms of modulation and these can differ greatly. Neither the type of modulation ofthe proposed Sutro Tower Digital TV signals (8-level vestigial side-band) nor ofeXlstmg Sutro Tower TV signals (amplitude-modulated for video information Sutro EIR ' Appendix B B-IO 07/(j6/97 Appendix B. Biological Effects of RFR and frequency modulated for audio information) matches or closely resembles the type of modulatIOn used in past biological research with modulated RFR In the conte>..1: of possible nonthermal interactions. the term "local SAR" denotes the rate of energy absorption at any local site \\ithin a biological object and does not necessarily indicate that such absorption occurs with a measurable increase in temperature, Rather. it is a useful measure ofthe local field strength resulting from RF exposure, especially at internal field strengths too low to produce heat at biologically significant rates, Specific absorption rates are generally unaffected by modulation. Under similar exposure conditions. the whole-body SARs obtained with amplitude-modulated (AM) RFR at any given carrier frequency and average power density are the same as those of continuous-wave (CW) RFR or frequency-modulated (FM) RFR However. ill specific laboratory research studies it may be uncertain ifthe experimenter assured that SARs under AM conditions were fully equivalent to CW conditions. Adey ( 1993) reviewed research and theoretical ideas concerning biological effects of ELF and RF electnc and magnetic fields \\ith emphasiS on mechanistic models for nonthermal interactions. The author suggested such models will establish nonlinear. nonequilibnum physical and biochemical processes as key features ofthe transduction of RFR signals at the plasma membranes ofcells. Adey presented a model based on the observation that currents in tissues were concentrated in the space surrounding cells and thereby exposed cell membranes to a current flow along the membrane surface. This is ill contrast to the transmembrane current flows associated with cell electrical activity and cell membrane ion charmels Adey reviewed previous research concerning biologIcal effects of weak AM RFR The cited reports from a number of laboratones were in the areas of development central nervous system function - panicularl: neuroendocrme function. Immune system function. cell gro\\th regulation. tumor promotion. gene expressIOn. and stimulated healing of fractured bone. Several Ideas were given as possible mechanisms for cell detectlon of weak AM RFR These included resonant interactions vvith ion binding. magnetically sensitive free radical chemistry. the biochemistry of lron-eontalIung enzymes, dark solitons. electron transfer reactIOns on protems. second messenger systems III cells. and cooperative bmding of calcIUm Ions This paper presented no expenmental research data and was almost entirely non-quantitatlve in nature. Speculative papers ofthiS type can be useful guides to understanding expenmental results and for the design of future expenments. but can have only an indirect role III assessillg risks from exposures to RFR 2.3 RFR AND POWERLINE-FREQUENCY FIELDS Nonionizing fields consist of vanous forms of electric and magnetic fields. Such fields occur both naturally. among them the earth's magnetic field and the electric fields in the atmosphere (most prominent during storms). and by electric generation for vanous uses Some reports claiming deleterious effects on humans from exposure to the electric and magnetic fIelds present In homes from the power line:s supplying electncity to the house. the fields from operatlng appliances within the home. and those from any nearby hIgh-voltage power lines, have generated some concerns. A recently published report by the U.S National Research Council (1996), which examined some 500 SCientific studies. IS reassuring in that it concluded that no clear. convincmg evidence exists to show that residential exposures to electric and magnetic fields are a threat to human health In this Technical Report. only the RFR emissions from the Sutro Tower Digital TV transmitte:rs antenna are pertinent. Nevertheless. in considenng any possiblebiocffi~ctsofthe RFR from the Sutra Tower Sutra EIR Appendix B B-li 07'0(,'97 Appendix B. Biological Effects of RFR DigItal TV transmmers. it is important to recognize the distinction between fields at powerline fre:quencles and RFR at the frequencies such as those from the Sutra Tower DigItal TV system. Specifically. U.S. power sources operate at 60 Hz. The corresponding wavelength (dIstance from one peak ofthe electric field to the next peak) IS more than 3.100 mIles. so people near a powerhne are in its induction zone (meaning at distances of only a tmy fractIOn of a wavelength). within which terms such as "propagation" and "radiation" do not apply. Instead. the electric and magnetic fields from such a source may induce currents in the body. and any possible effects of each field need to be considered separatel: By contrast. the Sutro Tower Digital TV system IS planned for operation at frequencies about 8.330.000 12.230.000 times higher than 60 Hz, and the corresponding wavelengths are only about 2 - 1.3f<~etThus. outside the boundary fence ofthe Sutro Tower site. people would be many wavelengths from the source. and 10 the regIOn where the fields are propagating at the speed of light. People at such distances and beyond would be in the antenna's "far-field" region, in which the Ilntensity falls off with the square of the distance (inverse-square law). In such radiation. the electric (E) and magnetic (H) vectors are at nght angles to each other and to the propagation direction. and their magnitudes have a fixed numerical ratio to one another (EIH=377 ohms. "the impedance of free space"). so the intensity ofthe RFR can be stated in terms ofthe intensity of either E or H alone. 3.0 SUMMARY OF CURRENT KNOWLEDGE ABOUT RFR BIOEFFECTS Most of the evidence for biological effects of RFR is denved from the results ofexperiments in which vanous mammals (including human volunteers) and nonmammals (e.g.? birds. insects. bacteria. other mIcroorganisms) were exposed to RFR and specific bIOlogical effects were sought Also studied were tissues such as excised organs and neurons. blood. single cells. cultures of cells. and subcellular components kept alive artificially Evidence is also derived from epidemiologic studies ofthe general population and studies of those occupationally exposed to RFR. However. such results are indirect or mferential because the RFR-exposure levels and their durations are usually not kno\'\'n WIth any degree of accuracy. 1\ionetheless. becausc of the particular relcvance given studies of human beings. the discussion below treats a number of epidemiological studies WIth a moderate degree of technical detail. 3.1 EPIDEMIOLOGIC/OCCUPATIONAL STUDIES Among the early epidemIOlogic studies done in Eastern European countries on possible detrimental effects assOCIated With exposure to RFR were those of pazderova (1971). pazderova et al. (1974). KJimkova Deutschova (1974). Kalyada et al. (1974), Sadchikova (1974). and Siekierzynski (1974). In general. mixed findings were reported. includings~mptomatologysuch as "asthenic syndrome" and "microwavc sickness" that were not generally recognized or supported by subsequent epidemiologiC studies in Western countnes. Robinette and Silverman (1977) eXamIned the decedence records of 19,965 Navy veterans ofthe Korean War. classified those with specific titles as havmg had Significant occupational exposure to RfR., and compared them With the decedence records of 20.726 Naval men who, by their titles, presumably had little occupational exposure to RFR The data showed no statisticalII) significant differences between exposed and control groups in the deaths from all disease. respectively 1 6% and 1.5%. both of which v,'ere significantly lower than for the age-specific general population Sutro EIR· Appendix B B-12 07106 f 97 Appendix B. Biological Effects of RFR Lilienfeld et al. (1978) conducted a study ofthe health ofthe U.S. personnel assigned to the Mos(:ow embassy during the period from 1953 to 1976 during which time the embassy was irradiated by RFR at varymg intensities (5 to 18 IlW/cm2) and frequencies (0.6 to 9.5 GHz). The study was undertaken in response to questions about possible health effects from prolonged exposures to these lm...-Ievel emissions The authors, after expending considerable efforts in tracing employees and dependents, identified 1,827 employees and 1,228 dependents as having been at the Moscow~:mbassy.The control population consisted of 2561 employees and 2,072 dependents who had been assigned to the embassies and consulate:s in various Eastern European countries during the same period. Periodic tests for RFR at those control sites showed only background levels of I f.1W/cm 2 . Based on available medical records and returned health questionnaires, no discernible differences were found between Moscow and control groups in total mortality or mortality from specific causes, nor were there any mortality differences between the Moscow and control groups of adults or dependent children The mortality rates for the Moscow and control groups were lower than for the U.S. population at large. except for cancer-related deaths. which were fractionally higher among Moscow-female (8 of I~deaths) than control-female employees (14 of31 deaths). Regarding the latter, the authors remarked: "It is difficult to attach any significance to the relatively proportion of cancer deaths in females because ofthe small numbers of deaths involved u in one of two studies, Lester and Moore (1982a) endeavored to establish an association between mortality from cancer and proximIty ofthe decedents to Air Force bases in the United States. The authors' assumption was that persons living in census tracts closest to the bases were most exposed to RFR from military radar. An accounting was made of shielding from the radar that might have occurred because of variations in terrain. The authors found a correlatIOn between cancer mortality and radar exposure. Polson and Merritt (1985) found this study to be flawed by incorrect assembly ofthe data base. When they mdependently assembled the data base correctly and analyzed It. they found that the cancer incidence for either sex in counties that had Air Force bases did not slgnificantlv differ from the incidence in counties that did not have Air Force bases In the other study, Lester and Moore (I982b) sought to determme whether there was a geographic pattern of cancer incidence in the city ofWichita. Kansas which included a number of Air Force bases with operational radar The authors sought to determme \vhether specific sources of RFR could be ndentified and related to any such pattern. They derived a formula purported to associate RF exposure with cancer Incidence, which was based on erroneous assumptions and which yielded levels havmg no relation to actual exposure levels. Thus. their finding of an association of cancer incidence in Wichita and exposure to the RFR from the two airports was unwarranted. Hamburger et al. (1983) sought to determine whether physical therapists might have adverse health effects from exposures to emissIOns from various diathermy urnts dunng patient treatments. They analyzed the responses from male members ofthe American Physical Therapy Association (ACTA) to a mailed questIOnnaire on their history oftreatments of patient With microwave and shortwave diathem1Y Also considered were the use of infrared and ultrasound diathermv. Three mailings ofquestionnaires yielded a population sample consisting of3004 respondents. Those respondents were divided into subgroups according to exposure across and within the energies of the modalities above. However, the smallness of several groups necessitated merging them into other groups to ensure more meaningful statistical results. yielding nme subgroups The reported prevalence rates for the Sutro EIR ' Appendix B B-13 07/06/97 Appendix B. Biological Effects of RFR entire cohort were below the rates for the general population, and no one subgroup showed markedly lug.her rates relative to the total rates. When the authors recast and analyzed new subgroups based on those who used more than one modality (a method that resulted in double-eountmg of some subjects), they reported a significant association ofheart disease with short-wave exposure. However. that result pertamed to only 4 of 90 contingency tables, rendering the finding no better than chance. Burr and Hoiberg (1988) compared the hospitalization rates of 1063 Naval pilots, who primarily flew "electronically modified aircraft", with an age-matched control group of 2126 pilots who flew other types of aircraft. A major difference between the two groups was that the pilots ofthe test group were presumed to be subjected to greater potential risks from exposure to ionizing radiation (such as at lugh altitudes) and nomonizing radiation (e.g., from onboard antennas. electronic equipment) than the control group. Although there were significant differences between the groups in mortality and hospitalization rates. neither group had any hospitalizations for conditions related to ionizmg or nonionizing radIation. Djordjevic et al. (1979) did a clinical study of322 radar workers who had been occupationally exposed for 5 to 10 years to pulsed microwaves at average power densities less than 5mW/cm~in Yugoslavia. with 220 controls. The numbers and percentages ofthe exposed and control subjects diagnosed for various ailments were tabulated. The most prevalent diagnosis was for "NeurOCirculatory Asthenia" in 15.2% ofthe exposed subjects and 13.2% ofthe control subjects. a nonsigmficant difference. Nonsignificant differences were also observed in electrocardiograms (EKGs). blood tests. and various subjective complam1ls. The authors concluded that prolonged occupational exposure to mIcrowaves did not affect the health ofthe radar workers. In a later study, Djordjevic et aI. (1983) presented the results of a IS-year clinical study of 500 workers occupationally exposed to RFR In the centimeter-wave band from high-power radars for about 2 hours daily at levels usually less than 5 mW/cm:, \\ith 350 controls for companson. Most prevalent was the dIagnosis "Neurovegetative Dystoma", but the authors noted that none of the differences between the groups was significant However. the absence of statistical data In the two DJordjevic et aI. papers dimmlshes the credibility ofthose negative findings. Also. neither "Neurocirculatory Asthenia" nor "Neurovegetative Dystoma," the major diagnoses therem, are disorders recognized in Western medicmc. In a detailed report, Milham (1983) analyzed the infonnation on age and year of death in Washington State of 429,926 male decedents for 1950-1979 and 25.066 female decedents for 1974-1979, and presented cause-of-death analyses (160 causes) for 219 male and 5 I female occupational categories. The author used the "proportional mortality ratIO" (PMR), for v.:luch the sum of the PMRs for all occupattons considered must be 100% Use ofthe PMR is questionable because it does not directly measure the risk or probability ofa person in a population dymg from a specific disease as does a cause-specific mortality rate. Morc commonly used is the "standardized mortality ratio" (SMR). because it represents the percentage of actual deaths for each cause relative to the expected number of deaths from that cause, independent of any other SMR. Among the mortality patterns. those for the workers in II occupations presumed to have been occupatIOnally exposed to magnetIc and/or electrical fields were analyzed, and the PMRs for "acute leukemIa" and "all leukemia" were calculated, for a total of22 categories. For those 22 categones, 3 PMRs were lugh at the 1% significance level and 2 PMRs were high at the 5% level. Ofthe remaining 17 PMRs, 13 were elevated, 3 were depressed, I was unchanged, but none was statistically significant Sutro EIR " Armendix B B-14 nilO(../Qi AppendLx B. Biological Effects of RFR Because the PMRs must sum to 100%, the 5 significantly high PMRs may reflect abnormally low PMRs ill 3 ofthe 11 occupatIons, a point explicitly recognized by the author. Thus. little credence can be given to the author's claim that the higher PMRs for acute leukemia and for all leukelllia are associated v.ith exposure to electric and magnetic fields. Szmigielski et al. (1982) presented epidemiological data from workers in the Polish military who had RF exposure in the period 1971-1980 with the finding of about a lhree-fold enhanced risk especially for cancers ofthe hematopoietic system. MorbidIty rates were found strongly correlated \"ith exposure duration and tumors ofthe same type occurred earlier among RFR exposed groups. These observations were reported more fully for a cohort ofmilitary workers from 1971 to 1985 by Szmigielski (1996) who found an odds ratio of 2.07 (95% CI = 1.12-3.58) for all cancer mortality for workers in all age-groups who were exposed to radiofrequency and microwave energy. Although the number ofcases was sometimes small. the odds ratio for various specific tumor types were strongly elevated. The odds ratio for hematopoietic and lymphatic tumors was 6.31 (95% CI = 3.12-14.32). with particularly high ratios for chronic myelocytic leukemia (odds ratio 139.95% CI = 6.72··22.12), myoblastic leukemia (odds ratio 8.62.95% CI = 3.54-13.67) and non-Hodgkin's lymphoma (odds ratio 5.82, 95% CI = 2.11-9.74). Odds ratios for colorectal cancer and cancer ofthe esophagus and stomach were elevated to statistically significant levels of3.19 (95% CI = 1.54-6.18) and 3.24 (95% CI:= 1.85-5.06), respectively. The results of this retrospective study ofa large occupational cohort are striking for the number ofhematopoietic malignancies for which the odds ratios were elevated \"'Ith strong statistical reliability.lnterpfl;~tationofthe data is limited by the relatively scant information on exposure. It would be difficult, ifnot impossible. to assess individual exposures from measurements made at several military posts. The author reiP0rts that although some military sites had exposures to pulse-modulated RFR at intensities of0.2 to 0.6 mW/cm:. and some occasionally exceeded 0.6 mW/cm:, 80 to 85% of all military posts were exposed to pulsed fields below 02 mW/cm: There was only "a marginal" exposure to CW fields It is important to note that Szmlglelski reported that brief periods of overexposure were quite frequent and that it v,'as not possible to control for exposures to solvents. a potential confounding cause ofhematopoietIc cancers Milham (1985, 1988a) comprised two studies ofthe records ofdeceased amateur radio operaltOrs who had been members of the American Radio Relay League (ARRL) III Washington State and California. the "silent keys" compiled in the ARRL publication QST In the first study. information was obtained for a total of 1.691 decedents in the two states. Statistical analysis yielded a PMR of 281 for acut(:. chronic. and unspecified myelogenous leukemia (16 deaths found versus 57 deaths expected. p<O.Ol); the PMR for monoc~toticleukemia was only 77 (well below 100). and was 0 for lymphatic leukemia. Thus, the PMR for all leukemias was 191 (24 deaths versus 12.6 expected. p<O.OI). In the second study, Milham extracted the names of 67.829 males in Washington State and California listed as lIcensed III the 1984 US Federal Communications Commission Amateur Radio Station and/or Operator file The list was searched for deaths during a 5-year period. which yielded a total of 2.485 decedents. In this study, the author did use the calculated SMRs. Because the total expected deaths in both states from all causes was 3,479, the 2.485 deaths of licensees yielded an SMR of 71, with a 95% confidence interval of 69-74. showing significantly lower death rates for licensees than for the general population. This was also true for the categories "all CIrculatory diseases" (which yIelded the largest number ofdeaths) and "all malignant neoplasms". The only subcategory of malignant neoplasms that yielded an SMR that significantly exceeded 100 was "otherI~mphatictissue". for which there were 43 deaths versus 27 expected: the SMR was 162, with a 95% confidence interval of 117-218. The subcategory "leukemia" had 36 deaths versus 29 expected. for an SMR of 124, but the 9YYo confidence interval was 87-172, rendering SUlro EIR Appendix B B-15 07 1 06/97 Appendix B Biological Effeccs of RFR this result statistically nonsignificant. The author also had considered nine subdivisions or sub subdivisions of "leukemia" and found that of36 deaths, 15 were for "acute myeloid" leukemia versus 8:' of the 29 expected. These values yielded an SMR of 176 with a 95% confidence interval of 103-285, an apparently statistically significant result. This finding should be considered ",,'ith respect to the small number ofdeaths. Thus, despite claims to the contrary by the author, the results ofthis study do not offer convmcing confirmation ofthose in Milham (1983). Thomas et al. (1987) analyzed the risk ofbrain tumor mortality for men occupationally exposed to RFR. lead, and soldering fumes in the petrochemical industry in northem New Jersey, Philadelphia and its surrounding counties, and the gulf coast of Louisiana. Death certificates were obtained for men who had died from brain tumors or other tumors ofthe central nervoussy~tem.One control for each case: was selected from men matched in age and year of death and area of residence, but who had died from causes other than brain tumor. Analyses ofthe estimated maximum-likelihood relative risk (RR)show~:d sigruficantly elevated RRs for astroc)tic brain tumor among men classified as exposed to RFR in jobs involving the design, manufacture, installation. or maintenance of electronic or electrical equipment. RRs were not elevated for exposure to RFR m other types ofJobs. On the other hand, the RRs were also higher for electronics workers classified as not having been exposed to RFR. Elevated RRs were also Ireported for those exposed to soldering fumes, but the variations with presumed exposure level were not large. However, nearly all ofthose exposed to soldering fumes were engaged in electronics manufacturing and repair jobs. On the basis ofthe results. the authors suggested that simple exposure to RFR is not the responsible agent for excess bram tumor nsk. Cantor et al. (1995) sought to determine whether a relationship exists between the incidence of female breast cancer and occupational exposure in the US. to various substances, ionizing radiation. amd radiofrequency and microwave electromagnetic fields. The authors obtained more than 2.5 million mortality records that were coded for occupation from 24 states for the years 1984-1989. For 59 j 15 white and black female decedents. breast cancer \\'as listed as the underlying cause ofdeath. Four controls per case were randomly selected from all noncancer deaths and were frequency-matched in age. gender. and race After excluding homemakers, there remamed totals of33,509 case \\'omen and 117,794 control women. The authors tabulated 31 potential \vorkplace-cxposure agents and created a job-cxposure matrix. Two ofthose 31 categones were for radiofrequency electromagnetic fields and microwave fields. The exposure-probability and the exposure-level results were tabulated separately for the white and black women. The odds ratios (DRs) for almost all ofthe agents hsted were well below 1.2, but for several ORs, the 95% confidence intervals (CIs) exceeded 1.00. As an mterestmg example, the largest exposure probability OR in white women was for solder: 2.97 wltha 95% CI of 13-6.6, but there were only II cases and 19 controls. The authors recognized the many lImItations of their study, and stated It . .In this investigation, we found no association with either ionizing or nonionizing radiation It The nsk ofbram tumor was studied in a relatively large cohort of U.S. Air Force personnel. a fraction of which had exposure to RFR. extremely low frequency fields or ionizing radiation, based on occupational records. The methods for estimating which jobs had potential for relatively large RF exposures to RFR were based on records ofincidents ofoverexposure (above 10 mW/cm 2 ) This technique led to identification of nearly all jobs involving maintenance and repair of RFR devices, including radar units. After adjusting for an effect of socioeconomic status on brain tumor incidence. the odds ratio for brain tumor was 1.39 (95 % CI = 1.0 1-1.90). This is a weak association which of marginal statistical significance. There was a similar, but not statistically signIficant association for exposures to extremely low frequency electric and magnetic fields. By contrast exposures to ionizing radiation showed no Appendix B. Biological Effects of RfR association \\ith brain tumor, but, regardless ofany type ofexposure, senior officers (representmg the highest socioeconomic ranking) had a brain tumor risk of330 195% Cl = 1.99-5.45), a moderate risk with clear statistical significance. Selvin and colleagues (Selvin et aI., 1992) analyzed the clustermg ofspecific childhood cancers in the population ofSan Francisco for the purpose of determining ifthere was clustering of childhood cancer near Sutro Tower over the fifteen year period 1973 to 1988. In order to obtain data with the greatest possible statistical power. the authors evaluated population density throughout theci~'which was divided into census tracts. The average distance to the tower for a child resident in the city ("person at risk") was 3 718 km. a value consIstent with the dImensions ofthe City ofSan Francisco (approximately 11 km in either the east-west or north-south directions). Selvin et al. (1992) determined that neither childhood leukemia (51 cases), childhood brain cancer (35 cases), nor childhood lymphatic cancer (37 cases) was morec~ommon near the tower than elsewhere in the city. This result was found '''1th two types ofdistance analysis. one using actual distances from the tower and another using distances which were transfonned to take population density into account SelVin et al. (1992) also did a third analysis which estimated relative risks for a childhood population near the tower in comparison with children living further from the tower. In order to calculate relative risk it was necessary to divide the childhood population into "exposed" and "unexposed" groups In order to get the best distance for distinction between "exposed" versus "unexposed" cases (that is. the statistically most powerful cutoffdistance), the authors devised a model for exposure and tested it for various assumptions about true risk and cutoff distance. They detennined that a distance of3.5 km was best on statistIcal grounds. In using this distance. the relative risk analYSIS compared an "exposed" group ofapproximately 45% ofthe population under 21 years of age against the remammg 55% The results agreed with the two distance-based analyses and gave no evidence for increased childhood cancer risk for any ofthe three cancer categones. In summary. Selvm et al. (1992) found no evidence by any ofthree methods that specific childhood cancers were more common near Sutro Tower than elsewhere lo the City of San Francisco As the authors noted, this conclusion needs to be taken with the understandmg that potential biases and confounders were not controlled in their analYSIS. In addition. like all such work. this study could not have detected an excess in childhood cancers below a minimum level. According to a graph presented by the authors, the study had good statIstical power (>90% chance ofdetecting excess risk) If the true risk were about four to five. Therefore, the negative results ofthis study are evidence that proximity to Sutro Tower is not associated with a risk ratio for each of the three childhood cancers of greater than four to five, but smaller risks might not have been identified. The inCIdence of cancer and cancer deaths over the years 1972 to 1990 was analyzed in 3 regions near Sydney. Australia havlOg TV towers in comparison With 6 other nearby regions without TV towers (Hocking et a!. 1996) The calculated power densities were from 0.2 to 8 flW/cm" at 4 km from towers and 002 /-lW/cm" at 12 km. In bmary comparisons for the zone v.ithin 4 kIn versus the zone from 4 to 12 km, there v,ere statistically significant increases in risks for total leukemia incidence for all ages (odds ratio 1.24. 95% Cl = 1.09-1.40) and leukemia incidence In children (odds ratio 1.58 95% Cl = 1.07-2.34). Leukemia mortality in children also had a higher odds ratio of 2.32 (95% CI = 100-2.41). Brain cancer was not higher for these comparisons. The authors' InterpretatIOn ofthe data is that childhood leukemia was increased among children living close to TV towers. Conclusions from an ecological study design such as this can be in error for many reasons. These include the effects ofchance in studies with relatively small n '"'f Appendix B. Biological Effects of RFR numbers. socioeconomic and envi.ronmental cancer risk factors which may be correlated v,'ith homes located near TV towers but which have nothing to do wi.th RFR. and incomplete and incorrect assessments of exposure. Exposures can be expected to vary at least as widely as indicated by the calculated values Cited in this stud\'. It is difficult to interpret data for which exposure levels for the "exposed group-, vary over a forty-fold range. For example, it is probable that some subjects WIthin the 4 to 12 kIn zone had exposures greater than others within the 4 kIn zone. Correction for such exposure misclassification could lead to higher or lower odds ratios which, for the number ofleukemia ca-ses involved in this study and the relatively small observed increases in risk, might alter the conclusion However, the finding for childhood leukemia mortality IS of moderate strength and if in error. other factors known to influence ecological study designs may be of importance. The occurrence ofa cluster of 12 childhood leukemias in an area of Oahu. Hawaii during the 13 year penod from 1979 to 1990 stimulated a study by Maskarinec et aL (1994) to determine ifenvironmental or familial factors might be causally associated with those childhood leukemias. There was particular interest in 7 ofthe cancers which occurred in just 3 years (1982-1984) and were ofunusual types in comparison WIth most childhood leukenuas. The standardized Incidence ratio for all leukemia cases was 2.09 (95%, CI = 1.08-3.65). The ratios for some specific leukenua types were also greater than one, particularlly a ratio of 3.73 (95% CI = 1.20-8.71) for acute nonlyrnphoc:vtic leukemia (5 cases), a relatively uncommon childhood leukemia. Data obtained since 1985 indicate that there has been no excess ofleukemias. The radio towers of interest broadcast at 23.4 kHz. a frequency more than 20,000 times lower than any Sutra Tower DTV transmission. The authors did not indicate if radio enusslOns differed for the periods before and after 1985. If not, it would be difficult to understand why leukemia rates would drop even ifRF exposures were unchanged unless RFR was not a true risk factor for leukemia in this cluster. The influence of possible confounding factors such as exposure to petroleum products. iOnIZIng radiation and socioeconomic status ",ere not given. But some related mformation was obtamed by questionnaire and these factors seemed to be unImportant. Honolulu. Hawaii was the site of an ecological study of cancer rates for 1979 to 1983 ill census tracts near broadcasting towers (Hawaii Department of Health. 1986) The results showed significantly higher rates for all cancers after adjustIng for age and race (but not both together). However it was not possible to adjust for smoking. diet or occupational exposures. The SIR for males in the nine census tracts with radio towers was 145 and for females 1.27 whereas SIRs for two non-tower tracts were 1.05 (males) and 0.85 (females). The authors noted that leukemia rates (based on a small number of cases) were not significantly hIgher. The authors adopted a 99 percent confidence mterval In the standardized incidence rate: for determination of statistical significance (P <001). This report. which has not been published in the scientific literature. has no information on RF exposures in the census tracts with radio towers. nor a description of the emissions from those towers As the authors state, an ecological study design such as this where exposures are not well-defined is unlikely to be productive. The results ofthis study are oflittle value in assessing any potential hazards of exposure to RFR Two recent studies by Dolk et al.(l997a~1997b) illustrate the difficulties of epidemiologic research concerning cancer clusters (see glossary) and studies using ecological designs. In the first (Dolk et aI., 1997a), the authors found greater risk of leukemia among adults Jiving near to the Sutton Coldfield radio transmitter site in England where the mast had both TV and FM radio antennas. For adults living v,'ithin 2 kIn of the mast, leukemia risk was significantly higher (odds ratio = 1.83.95% CI = 1.22-2.74) and risk fell with distance from the transmitter There v..'ere 23 leukemias in the group within 2 kIn and odds ratios also were greater than 1.0 for most leukemia subtypes. although the small numbers made it difficult to Sutro EIR Appendix B B-IX 0710(;/97 Appendix B. BIOlogIcal Effects of RFR assess the statistical confidence for each subtype. Total cancers were slightly higher than expected for people older than 15 years of age ill homes within both 2 krn and 10 krn from the mast. Childhood cancer rates were not higher than expected. One indication that these findings were not a statistical oddity is that findings were consistent for two mdependent time periods. 1974-1980 and 1981-1986. Maximum total power density (summed over frequencies) at 2.5 m above ground were 1.3 IlW/cm: for TV and 5.7 IlW/cm= for FM. These exposures fell within applicable safety guidelines for public exposure. There were also three industrial sources of pollution within the zone from 3 to 7 km from the mast The authors concluded that "there was an excess of adult leukemia within the vicinity ofthe Sutton Coldfield TVIFM transtnlttcr in the period 1974-1986." The authors also concluded. "No causal implications regarding radio and TV transmitters can be dra\\'I1 from this finding, based as it is on a single 'cluster' investigation." In order to confirm the validity and generality ofthis finding the same researchers conducted similar analyses ofthe incidence ofadult leukemia. melanoma, and bladder cancer for 20 additional TV and Fr..,1 broadcast stations in Great Britain (Dolk et ai, 1997b). The results ofthis study were almost entirely negative: the odds ratio for homes within 2 kIn ofthe transmitter was 0.97 (95% CI =0.78-1.21) and for homes with 10 krn the odds ratio was 1.03 (95% CI = 1.00-1.07). When the risk of leukemia was evaluated with respect to distance. there was a borderline finding that risk declined with distance, consistent with the Sutton-Coldfie1d data. Odds ratios for non-leukemia cancers were not elevated near the transmitters nor was there a decline in odds ratio with distance. The authors concluded that the pattern and magnitude of risk associated ....ith residence near the Sutton Coldfield transmitter did not appear to be replicated around other transmitters. These studies involve exposures which are more like those from the proposed Sutro Tower digital TV transmissions than nearly all other availablen~search,although there are distinctions in the frequencies and modulation patterns. Public health deCIsions on risk require information from a variety ofsources and usually several epidemiology studies. The conflicting results ofthe two studies by Dolk et a1. (1997a: b) illustrate the need for this approach lest true risks be ignored or unconfirmed risks be accepted as iftrue. It is seen that most of the epidemiologic studies (including some that reported negative findings) were flawed for various reasons. such as absence of adequate data on RF exposure levels and durations. use of occupational categories as indicative ofRF exposure. use of population samples that were too small, utilization of mailed self-administered questionnaires to acquire data. lack of or inappropriate statistical treatment ofthe data, or incorrect assembly ofdata bases. It would be misguided to take the results from the foregoing group ofstudies as evidence on the safety of"RFR" because ofthe wide disparities in presumed exposure as well as generally poor exposure assessment A few studies directly address populations near radio and TV towers. but none concerns signals from DTV transmitters operating in the range from approximately 500 to 800 MHz. None of the epidermologic studies individually provides strong evidence that any particular level or type of RF exposure is carcinogenic. nor does the group ofstudies lead to thIS conclusion. However. there is sufficient evidence from occupational research studies to continue investIgations ofthe risk for hematopoietIc cancers 111 hIghly exposed groups On the other hand. the evidence for adverse health effects in the general population which is exposed to much lower levels from broadcasting towers is much weaker and, by itself, does not lead to a conclusion that there is an excess risk associated with such exposures. Those data which do suggest t:ffects from low level exposure involve low risk levels and it may be difficult to design studies with good exposure assessment which could make reliable evaluations of risk. Thus. taken collectively. the epidemiologic studies yielded little or no reliable evidence that chronic exposure to RFR at levels withm current exposure guidelines is hazardous to human health. Sulto ErR \ Appendix B B-19 071()6197 Appendix B. Biological Effects of RFR 3.2 CONGENITAL ANOMALIES Two studies were done that sought a possible relationship between the occurrence of Down's syndrome (once called "mongolism") and presumed exposure ofthe fathers to RFR from radars during milItary service. In the first study, Sigher et al. (1965) examined the data. from Baltimore hospital records and interviews with parents on 216 Caucasian children with Down's syndrome. The case children were matched ''lith 216 control children, as were the parents. One significant finding was that the percentage of case mothers that had received fluoroscopy before the birth ofthe case child was significanth' higher than for the control mothers, as were the percentage ofcase mothers \vho had received at least onethl~rapeutlc ionizing radiation exposure. The difference in the percentages ofcase and control fathers that had served in the military was nonsignificant, but a higher percentage of case fathers had a close association \\ith radars as technicians or operators than the control fathers. The authors therefore ascribed the higher incidence ofDown's syndrome primarily to greater exposure ofthe case mothers to ionizing radjation, but suggested the possibility ofa relationship between Down's syndrome and paternal radar exposure. In the second study, Cohen et al. (1977) reexamined the data m the first study plus the data on 128 additional matched pairs. They concluded that their findings did not confirm the suggestion ofa possible association between incidence of Do\\n's syndrome and excess radar exposure ofthe fathers Peacock et al. (1971), in seeking a possible association between the incidence ofbirth defects in Alabama with the proximity ofmilitary bases, examined a state-\'.ide file of birth certificates by counties They calculated an overall rate of 10.3 newborns with anomalies per thousand births. a rate comparable to those III other registnes However. a more detailed study ofthe data showed that there were l7 anomalies per thousand births formilita~·personnel in the six-eounty area sUITounding Fort Rocker. whereas the anomaly rate for civilian births was only 6 8 per thousand. Subsequently, Peacock et al. (1973) reassessed the premIse, bu!: with data spanning four years mstead of the 17 months examined previously. Also. the data were corrected and rendered more accurate than previously, and a more precise test ofthe reliability of mferences was performed that did not rely on the questionable use of a normal approxjmation. The authors then repeated the analyses for the Fort Rocker area and specifically for Lyster Hospital (withm Fort Rocker) In additIOn, as a "control" test, they compared the fetal death anomaly rates in the military hospitals at Fort Rucker and Eglin Air Force Base (which they designated as "radar bases") with those ofthreemllita~·hospitals in bases with mmimal radar net\vorks. Those results confirmed that the total anomaly rate and the rates for several specific anomalies were abnormally high at Lyster Hospital. In addition. the numbers offetal deaths for Lyster and for the hospital at Eglin Air Force Base were comparable and "constitute evidence that the problem may be assOCiated '\lth radar". Burdeshaw and Schaffer (1977) reexamined the Alabama birth records. but compared the data for Coffee and Dale Counties (within which Fort Rucker IS located) with the data from each ofthe other 65 Alabama counties on a score and rank basis instead of the statewide averages. They found little evidence of unusually high incidence of congenital anomalies in the Fort Rucker area. The increased incidence of congenital anomalies at Lyster Hospital was found to be attributable to a higher than normal reportmg rate of one physician who apparently included "birth defects" not regarded as such by other physicians SulTo EIR \ Appendix B B-20 07107'97 Appendix B Biological Effects of RFR Kallen et al. (1982) performed a study of 2,043 infants born to Swedish physiotherapists assumed to have been occupationally exposed to vanous agents such as chemicals. drugs, X-rays, and RFR. The results showed fewer dead or malformed infants than in the general population The data base was larg,e. so the negative findings are statistically credible. The authors noted that this excellent outcome could have been because the health ofthe physiotherapists may have been better than for the general population, a "healthy worker" effect. They hypothesized that more ofthe relatively few females in the general population who had dead or malformed infants had been subjected to possibly hazardous exposure than those who had normal babies. Accordingly. they also performed a case-eontrol study m which they selected 37 infants who had major malformations or had died perinatally. Each such infant was compared with two normal infants matched for maternal age, parity. and season of delivery. The presumed exposures of the case and control mothers were estimated from answers to a questionnaire. The results indicated that the number of case: mothers who had used shortwave equipment was barely higher than for the controls, with statistical probability just within the border of significance (p=0.05). However, it should be noted that the diflhence could have been nonsignificant (p>005) if one or two answers to the questionnaire were based on faulty recalL so the finding IS questIOnable. Taskinen et al. (1990) did a study ofall registered physiotherapists in Finland who had become pregnant during the study period, to determine whether their occupational exposure to various modalities used for patient treatment, including RFR.. is asSOCiated with the mcidence of spontaneous abortIOn or of congenital malformations in their offspring The subjects were those who had been treated for spontaneous abortion or had a malformed child. Data from the responses to questIOnnaires mailed to 1.329 female physiotherapists on their exposure to various modalities. including ultrasound or shortwaves. and their physical exertions were studied. Based on specific selection critena, the final populations analyzed were 204 cases of spontaneous abortion \\lth 483 matched controls. :md 46 births of congemtally ma.lformed infants with 187 matched births of normal infants For assessing the exposures ofthe therapists. the authors classified the equipments used in treating patients. Exposure duration was defined as the amount oftime the therapist handled the equipment during operation while standing at distances of I meter or less. The authors used linear logistic regression for individually matched data, and evaluated significance in terms of odds ratios (ORs) relative to estimates based on a normal distribution. From the data gathered, ultrasound exposure was most often reported (lIS cases and 256 contmls) Analysis showed that handling ultrasound equipment for at least 20 hours per week increased the risk of spontaneous abortion significantly (p<0.05). but those subpopulations were small (9 cases and 8 controls. Administering electric therapies for at least 5 hours per week aliso showed a significant increase of spontaneous-abortion risk. Physical exertIOn by the therapists \\as the only other factor that showed a significant increase ofspontaneous-abortion risk. Specifically. heavy lifting (weights exceeding 10 kg) and/or transfer of patients 50 or more times a week yielded a significantly higher OR From an analysis by pregnancy duration. heavy lifting durmg pregnancies 10 weeks or shorter was the only factor that contributed to a significant risk for spontaneous abortIOn. On the other hand, for pregnancies exceeding 10 weeks, significant risks were indicated for using deep-heat-therapy equipment (including those emitting shortwaves) for 5 or more hours a week SimIlar results were obtained for ultrasound and Sutro EIR iwpendix B B-21 07/07/97 Appendix B Biological Em:cts of RFR infrared heating for 10 or more hours a week. The authors regarded these results and the absence of significant risk increases for pregnancy durations 10 weeks or shorter as indicative ofa dose-response relationship. Heavy lifting was a significant factor again, but for both ranges ofpregnancy duration Among the results for congenital malformations (46 cases and 187 age-matched controls) was a signific:l11t risk mcrease for administering shortwave deep-heat therapy for J-4 hours per week but not for 5 or more hours a week. The authors suggested that bias due to selective recall cannot be excluded in this part ofthe study, but discounted such bias in the spontaneous-abortion part. No significant risk increase was seen for congenital malformations from the use of microwaves. In the absence ofany data on exposure levels and their variations with time and patient-treatment site, the authors' use ofthe term "dose" as in "dose-response relationships" is meaningless quantitatively. and their remarks about vanous other points in their discussion are obscure at best. Thus. at least \\;th n:gard to RFR, little ifany credence can be given to either the positive or negative findings ofthis study. Larsen et al. (1991) performed a study ofpossible reproductive hazards among Danish female physiotherapists from exposure to RFR. The subjects were members ofthe Umon of Danish Physiotherapists who had delivered infants or rruscarried. The data for spontaneous abortions, subfecundity, stillbirth or infant death within one year, prematurity, and low birthweight yielded ORs that were nonsignificantly different from 1. The only major positive finding was an unexpected low ratio of boys to gIrls for the physiotherapists exposed to high-frequency radiation. The statistical treatments ofthe data in this study were extensive. but as with other epidemiologic studies. the absence of measurements ofthe actual RFR levels to \vhich the physiotherapists were exposed and the vague estimates ofexposure duratIOns vitiate the credibility of the single pOSitive finding as well as the negative findings. In addition, as rcmarked by thc authors. the results are based on sparse data and must be mterpreted With caution Ouellet-Hellstrom and Stewart (1993) mailed questionnaires to 42.403 female physical therapists in 1989 whose names were obtained from the American Physical Therapy Association, to assess for possible effects ofoccupatIOnal use of microwave and shortwave diathermy at conception time, and specifically whether an excess risk of miscarriage was associated with exposure to RF and microwave radiation just before conception or during the first tnmester of pregnancy. A total of I.753 case pregnanclcs and 1,753 matched control pregnancies were studied Case and control therapists who had not worked dunng the 6 months prior to and during the first tnmester were classified as unexposed Therapists ofeach group were classified as exposed if they had been working and had reported using microwave or shortwave diathermy during that time interval. Ofthe 1,759 pregnancIes in each group. there were 209 cases (11.9%) and 167 controls (9.5%) who had any exposure. The authors remarked that for all pregnancies. the OR mcreased \vith the number ofexposures and that the trend was significant. However. the 95% CI for the most-exposure durations (more than 20 hours a month) encompassed 1.00, and the 95% CI for the cases and controls WIth exposures less than 5 hours a month also encompassed 1.00. rendering those ORs nonSignificant Moreover, the percentages ofexposed and control cases were too small yield much statistical power Nevertheless, the authors concluded that the women were at increased risk of miscarriage from reported use of microwave diathermy six months pnor to and during the first trimester of pregnancy. but not from shortwave diathermy Thus, both the positive and negative findings of this study are dubious Sutro EIR AppendIX B B-22 07106/97 Appendix B. Biological Effects of RFR Collectively there is little or no scientifically reliable evidence that chronic exposure ofmothers during pregnancy or of fathers to RFR at levels at or below the ANSlIIEEE (1992) maxllTlum exposure gUidelmes would cause any anomalies in their offspring. 3.3 RFR AND OCULAR CHANGES IN HUMANS The cornea and lens ofthe eye are vulnerable to RFR at high levels because oftheir surface location and because any heat produced by the RFR is removed less effectively than from other regIOns ofthe eye Indeed. there are several documented early cases of inadvertent exposure to RFR at levels high enough to cause cataracts, and safety measures to avoid such exposure have been defined. It is not possible that members ofthe public would be exposed to Sutro Tower RFR levels high enough to affect the cornea and lens ofthe eye. Cleary et al. (1965) examined Veterans Administration hospital records to detennine whether the incidence of cataracts could have been related to occupational RF exposure. They selected 2.946 Army and Air Force veterans ofWorld War II and Korean War, and used military occupational specialties (MOSs) to classif~yeach veteran as a radar worker, a nonradar worker. or one whose specialty could not be discerned. Selected for comparison were 2.164 records ofveterans hospitalized for other ailments. In the radar group. they found only 19 persons with cataracts. 2,625 persons \'oithout cataracts, and 100 persons with uncertain occupations. In the comparison group, only 21 had cataracts, 1.935 did not. and uncertam occupations for the remaining 83 persons. The small numbers of persons \-vith cataracts in both groups yIelded no basis for an association between RF exposure and cataract causation. Cleary and Pasternack (1966) analyzed the responses to a questionnaire on occupatIOnal histones of personnel then currently employed at 16 microwave installations. to differentiate controls from exposure cases They thereby selected 736 \'.orkers as occupatIonally exposed to RFR.. and 559 workers from the same locations and occupational envIronments (other than RFR) as controls. The authors then derived relative-exposure scores by asslgmng weights to specific factors related to the types and proXImity of the equipment used and usage durations Using a linear regressIOn model. the authors found that the major increase in eye score with time was due to physiological aging ofthe lens. Aurell and Tengroth (1973) investigated 98 persons engaged in mdustrial development of radar equipment Ofthose, 68 had been exposed to microwaves (unspecified frequencies. levels, or durations). compnsing persons testing radar eqUipment and measunng microwave radIations from various klystrons; lhe remaining 30 persons were from experimentallaboratones. The control group consisted of 30 people from the same mdustry who had never been exposed as far as knO\'ol1 Two eye specialists exammed the groups for VIsual acuity. their lenses. and their retinas without knowledge oftheir occupation or exposure. Bar graphs ofthe numbers ofthose with opacities larger than 0.5 mm in diameter or with a large concentration of smaller opacities were displayed for those less than 26 years old, and for the 5-year age subgroups 26-30 to 56-60 years However, there were no control persons older than 41 years. Those younger than 26 years in both groups had no such opacities. Of the 20 persons in the exposed subgroup 26-30 years old. 6 had opacitIes versus 2 ofthe 15 controls. The corresponding numbers for those 31-35 years old respectively were 5 of 14 exposed versus none of 4 controls. Similarly, for those 36-40 years old, the corresponding values were 6 of 15 exposed persons versus I of 2 controls, Sutro EIR Appendix B B-23 07/06/97 AppendIx B. Biological Effects of RFR and 2 of 6 exposed persons versus none of2 controls in the age group 41-45 years As seen. however. the numbers of exposed and control persons in each age group were small Sought in the retinal examinations were lesions ofthe central region of the fundus that resembled the chorioretina\ scars after inflammatory reactions. The results indicated that 19 ofthe 68 exposed people in the testing group exhibited such lesions. compared with only I ofthe 30 in the control group. It is difficult to lend credence to the findings ofthis study, because ofthe small numbers ofpersons in each 5-year-age subgroup and the absence of control persons older than 41 years. About the latter. the authors did state: "In the higher age group--over 41 years--it is impossible to separate lens opacities dm: to microwave exposure from a senile cataract because no controls older than 41 years were examined." However. unclear is why they did not do so, and why only 30 pt:rsons were selected as controls versus the 98 exposed Also, absent were any exposure-level measurements and estlmates of exposure durations Appleton and coworkers initiated surveys in which they examined the eyes of personnel at Anny posts ",'here vanous types ofelectronic communication. detection, guidance. and weather equipment were under development. test. and use. In Appleton and McCrossan (1972), they presented results of semiannual examinations conducted between 1968 and 1971 of 226 people employed at Fort Monmouth, New Jersey After determining the visual acuity ofeach person. they examined their eyes, and recorded: (1) the number, location. and shape of opacities. if present: (2) similarly for vacuoles: (3) similarly for "posterior subcapsular iridescence" (PSCI). an identifiable polychromatic luster, and (4) absence of all three, results termed "negative". The experimental group (91 persons) were individuals who had histories of working directly with microwaves as test-development personnel or operators ofsuch equipment The controls were those employed at the Army post but who denied ever having worked \\ith or been near such equipment (135 persons) The groups were diVIded into subgroups. WIth one subgroup each for the 10-year age spans 20 29 through 60-69 years: the size of each subgroup and the number of persons in each ofthe four exammatton categones above were tabulated In those categories. comparisons ofthe experimental with the control persons in each age subgroup showed several higher percentages. several lower percentages. and several with no difference. Particularly noteworthy were the larger percentages of negatIve resuIts (absence of all three categories) for the three younger subgroups (20 to 49 years old) of the experimental group than in the corresponding subgroups of the control group. and the converse for the two older subgroups (50-69 years old). The authors did not present any statistical analysis, so whether the differences were significant or not could not be assessed. However. they concluded that the results did not provide any chnical evidence to support the assumption that cataracts that develop m personnel performing duties near Ir11lcrowave generating equipment are a result of microwave exposure. In Appleton ( 1973). the authors added. to the Fort Monmouth data, the results for personnel at White Sands Missile Range, NM. and Fort Bliss, TX. and those subsequently obtained for personnel at Tobyhanna Depot. PA, and Fort Huachuca. AZ, thereby yielding pooled totals of 605 experimental and 493 control personnel. The findmgs for the larger data base were basically similar to those of the first survey. The final results were tabulated in Appleton et al. (1975a), which encompassed 1.542 experimental and 80 I control subjects. who were exammed semiannually from \968 to 1973. The authors concluded that lens damage due to microwave radiation from military equipment has not occurred. Sutro EIR- AppendIX B B-24 07 1 06/97 Appendix B. Biological Effects of RFR Shacklett et al. (1975) did a similar study of 477 military personnel and civilians with knov.n histories of working near microwave-generating equipment at eight Air Force bases. The authors secured detailed work histories ofthe individuals. the types ofmicrowave equipment involved. and times spent working around each type. The controls were 340 age-matched persons. with no individual who had a CUTTent or past history of work with microwave-generating equipment mcluded. The presence ofocular effe:cts or their absence was recorded, using criteria similar to those of Appleton and coworkers The tabulated results showed surprisingly high percentages of all three criteria in each age group of both the exposed and control groups, with a trend toward increases with age. but no significant RFR-related differences Hollows and Douglas (1984a) examined the lenses of 53 radiolinemen who were occupationally exposed to RFR by erecting and/or maintaining radio, television, and repeater towers throughout Australia. The RFR frequencies ranged from 0.558 to 527 MHz. which includes the Sutro Tower Digital TV transmitters frequencies. The subjects included workers who had maximal cumulative RF exposure but none with cataracts or who had cataracts removed. Measurements ofpower density close to work areas yielded values in the range 0.08 mW/cm: to 4,000 mW/cm:. The results were statistically compared v.;th those for 39 age-matched controls from the same Australian states who had never been radiolinemen. The primary ocular finding was "posterior subcapsular cataract (PSC)" in either or both eyes of 11 ofthe 53 radiolinemen (21 %) as compared with 3 of 39 controls (8%): alternatively. PSC was found in both eves of 19 ofthe 106 eyes (18%) ofthe radiolinemen as compared \\'ilh 6 ofthe 78 control eyes (8%) The former difference was nonsignificant (p=0.086) at the 5% level and the latter was barely significant (p=0.043). Also reported. however. was nuclear sclerosis. atypl~of lens opacity possibly attributable to exposure to solar radiation. in 50 (47%) radiolinemen and 34 (44%) ofthe controls. so the contribution of RF exposure to the results is unclear. The various epidemiologiC studies on potential ocular effects yielded little or no SCientifically reliable evidence that chronic exposure to low levels of RFR (below current exposure gUldehnes or thresholds determined from animal studies) would cause damage to human eves. On rare occasions. accidental exposure to relatively high RFR levels has occurred. For example, Hocking et al. (1988) reported on the exposure of 2 radiolinemen to 4.1-GHz RFR at 4.6 mW/cm: and 7 radiolinemen at less than 0.15 mW/cm: for up to 90 minutes from an inadvertently activated open waveguide. Ophthalmologic examinations oftheir eyes showed various eye abnormalities in both groups, but vision was not affected in any ofthe subjects 34 AUDITORY EFFECTS IN HUMANS Some humans near some types ofpulsed radar transmitters have perceived single pulses or pulse trains of RFR as audible clicks in the head. Frey and coworkers were the first 10 the U.S. to study this effect. but their theory that it was due to direct brain stimulation by the RFR pulses was disproved by later studies. instead. much experimental evidence supports the conclUSIOn that an RFR pulse can produce a sharp temperature difference at a boundary between regions of diSSimilar dielectric properties in the head. a difference large enough to generate a transient elastic wave that is transmitted by bone conduction to the middle ear, to be perceived as sound. Persons with impaired hearing are unable to hear such clicks. and animals with nonfunctionmg inner ears do not exhibit RFR-pulse-induced evoked responses in the brainstem. It is not possible that members ofthe public would be exposed to Sutro Tower RFR levels high Sutro EIR Appendix B 8-25 07/06/97 Appendix B. Biological Effects of RFR enough to produce such audible clicks nor do the DTV signals have the characteristics required for the RFR auditory effect. Cain and Rissman (1978) used 3.0-GHz RFR pulses to investigate the RFR-auditory effect in eight human volunteers. The subjects were gIVen standard audiograms for both air-eonducted and bone-eonducted sound, and the binaural hearing thresholds were detennined for seven ofthem Then the subjects were presented~ith5-~s,10-~s,15-~s.and20-~sRFR pulses at I pulse every 2 seconds. Each subject wore foam ear muffs during exposure. to reduce the ambient noise level (to 45 dB) In brief summary, only 3 subjects could perceive15-~spulses. with a pulse-power-density threshold as low as 300 roW/cm c : one subject could hear10-~spulses, with 225 mW/cm c as the threshold: and the thresholds for the other subjects were much higher than 300 mW/cm 2 Thus. 300 roW/cro c can be taken as the nominal pulse-power-density threshold for humans to hear pulses having durations ofabout I0~sor longer. It is worthy of note that the human volunteers had beenl~xPOSedto pulses of 3. O-GHz RFR at peak power densities as high as 2,500 mW/cm c with no apparent ill effects. It is also important to notc that because single pulses of specific characteristics can be perceived. it is not meaningful to calculate tlme averaged power densities for two or more widely spaced pulses and to cite such low average values as evidence that the RFR-auditory effect is nontherrnal. 3.5 RFR SHOCK AND BURN People could experience electric shock or tissue burns when coming very near or in contact v'lith metallic objects in the vicinity of transmitters that emit RFR at frequencies below about 100 MHz. The ANSllIEEE (1992) guidelines mclude maximum exposure limits for avoidance of such effects The RF shock effects occur at frequencies lower than Sutro Tower Dnl frequencies and would not be relevant to effects from Sutro Tower 4.0 STUDIES OF RFR EFFECTS IN ANIMALS 4.1 EYE DAt-.1AGE BY RFR IN ANlt-.1ALS Many experiments with animals, such as by Carpenter and coworkers and Guy and coworkers, indicate that ocular damage from RF exposure is a gross thennal effect. Both groups of researchers detennmed thresholds for ocular damage by plotting the power density versus the shortest exposure duration that caused lens opacities. The resulting curves were rectangular hyperbolas, indicating an inverse relationship between pov,,'er density and minimum duration. Their curves leveled off horizontally (asymptotically) at an average power density that represents the threshold for ocular damage that may occur for indefinitely long exposure durations. In particular, Guy et al. (1975a) reported a threshold for eye damage in rabbits of roughly 150 mW/cm c for exposure durations of 100 mmutes or longer. Also especially noteworthy in that study were that exposure to RFR at levels that yield a temperature rise within the eye ofabout 5°C or more are necessary for thennal eye damage. and that no damage occurs from such RFR levels ifthe eye is cooled during exposure. Kramar, P, C Harris, AF Emery, and AW Guy (1978) were unable to produce cataracts 10 monkeys using 2,450 MHz diathenny C applicator even up to 500 mW/cm 2 As noted before, Sutra Tower DTV RFR levels to which the public could be exposed are below the threshold for thennal damage to the eye. '''''''/fl£:.ICI'"'T Appendix B Biological Effects of RFR The results of Stewart-DeHaan et al. (1985) on exposure of lenses to pulsed RFR also are evidence for the thermal basis ofeye damage by RFR. Noteworthy is a similar study by Creighton et al (1987) with continuous wave (CW) as well as pulsed RFR, because the pulsed RFR yielded almost 5 times greater depth oflens damage than the CW RFR under corresponding exposure conditions. The exposure: by Foster et al. (1986) ofthe heads of rabbits to the dominant electnc field (TE IO mode) in a waveguide system at 2,45-GHz RFR, with the left eye of each rabbit toward the source and its right eye as the control. yielded a threshold power density of285 mW/cm: for ocular damage. The equivalent free-space electric-field mtensity (in the TE IO mode) was 704 mY/cm. Kues et al. (1985) reported that exposure ofthe eyes of anesthetized monkeys to 2.45-GHz CW RFR in weekly 4-hour sessions at 30 mW/cm: yielded moderate-to-major changes in the numbers ofcomealleslOns seen \\ith a specular microscope. The authors determined the local SAR to be 7.8 Wlkg. Exposures at 5. la, or 20 mW/cm: did not cause any damage. This study and a later one by Kues and coworkers (1992) appeared to indicate that exposure to pulsed RFR caused more damage than CW RFR at 2.45..GHz. The authors also found that pulsed RFR at 10 mW/cm: and 15 mW/em: caused iris damage in the form of increased vascular leakage through the blood-aqueous barrier In the later study, they investigated the effects oftimolol maleate and pilocarpine on the reported RFR induced iris vascular leakage. Either drug was administered just before RF exposure. and sodium fluorescein was used as the tracer. The results were scored as 1 for no fluorescein leakage, through 4 for Significant leakage within the first 3 minutes after tracer injection. For each drug, a relationship between the RFRidrug-response score and the power density was not readily discernible. For example, ",ith neither drug, the mean score was 1.0 (no effect) for 5 mW/em: and for sham exposure: the mean scores for 10 and 15 mW/cm: were 2.1 and 2.8, both significantly higher than for sham exposure but not significantly different from each other. For timolol. the mean scores for 0,5. 10. and 15 mW/cm: \\fere respectively 1.0,2.7,2.7, and 35: the latter three scores were all significantly higher than for sham exposure. but the scores for 5 and 10 mW/cm: were the same. despite the 2: 1 power-density difference. Similar results were obtamed for pilocarpme Also ambiguous were the mean scores for eIther drug versus its absence at fixed power densities. The adequacy ofthe exposure technique and use ofthe same monkeys in more than one aspect ofthe study have been questioned, as has the apparent reversibility ofthe corneal effect. even though the corneal endothelium ofthe pnmate IS not knO\\TI to repair Itself through cell division. Kanumura et al. (1994) endeavored to reproduce the findings of Kues et al. (1985) by exposing monkeys without anesthesia for 4 hours to 2.45-GHz CW RFR at pow,:r densities in the range 15.9-43.0 mW/cm 2 The results showed no eye abnormalities. even at levels exceedmg the 30-mW/cm: threshold reported by Kues et at. (1985). 4.2 AUDITORY EFFECTS IN ANIMALS Animals as well as humans are able to perceive RFR pulses as apparent sound. The findings ofnumerous studies with experimental arumals indicates that such perception of RFR pulses is due to the induction of thermoelastic waves in the head, rather than by direct brain stimulation by the RFR. As indicated in Section 3.4, because single pulses ofspecific characteristics can be perceived, it is not meaningful to "-lIfrn FTl;J ,Ann~rli'VR Appendix B. Biological Effects of RFR calculatetime~averagedpower densities for two or more widely spaced pulses and to cite such lov. average values as evidence that the RFR-auditory effect is nonthermal 4.3 MUTAGENESIS. CYTOGENETIC EFFECTS. AND CARCINOGENESIS Studies were carried out on various microorganisms, insects. and mammals toward determining ,,,,hether RFR is mutagenic or carcinogenic. The fruit fly and several spec:ies of microorganisms were used in tests for such RFR effects because their short life spans permit the study of many generatIOns. well charactenzed mutatIOn-prone strains are available in large numbers. and baseline data exist on such strains for vanous non-RFR mutagenic agents. In some aspects. carcinogenesis and mutagenesis have been found to be correlated. and many chemicals have been screened for potential cancer-causing properties by testing whether they produce mutations In specific bacteria. For example, agents found to be mutagemc for the bacterium Salmonella are also likely to be carcinogenic. However. not all mutagenic effects are possible indicators ofcarcinogenic effects and not all carcinogenic effects are necessarily due to mutagenesIs. AJso studied were possible mutagemc effects ofRFR In mammals and mammalian tissues 4.3.1 Mutagenic And Cytogenetic Effects In Microorganisms and Fruit Flies In a study by Blackman et aL (1976) with E. coli bacteria, in whIch mutations can be detected readily, no significant differences in genetic activity were found between cultures exposed to either 1.7-GHz at 2 mW/cm: or to 245-GHz RFR at 10 or 50 mW/cm:. Dutta et aL (1979) obtained similar results with cultures of Salmonella exposed to 245-GHz RFR at 20 mW/cm: Also. Anderstam et aL (1983) exposed strams ofboth E. coli and Salmonella to '27. 12 MHz or 245 GHz Many of the changes were statistically nonslgmficant. but the overall trend was toward an RFR-mduced mcrease in growth. Other results were both Increases and decreases III mutant counts relative to controls. but most ofthe differences "...'ere not significant. Pay et aL (1972) exposed male fruit flies for 45 minutes to 2.45-GHz RFR at 6 mW/cm: and 1then mated them WIth virgin female fruit flies. No SIgnificant differences were found between exposed and control groups in mean generation times or brood sizes. Hamnerius et al (1979) exposed fruit fly embryos ofa stram prone to a change In eye pigmentatIon to 245-GHz RFR at about 200 mW/cm: for 6 hours There were no significant differences between exposed and unexposed flies in sUT\-wal rate or numbers of mutations. Based on findings such as those above. there IS no experimental evidence that exposure to RFR induces mutations in bacteria. yeasts, or fruit flies 4.3.2 Mutagenic, CytogenetIc and DNA Effects in Mammals and Mammalian Tissues and Cells The "dominant lethal test" (the occurrence of mutations that result in death of the embryo) has been used to assess whether RFR level IS mutagenic. A study by Varma and Traboulay (1976), in which this test was used. showed that exposure of male rodents to 1.7-GHz CW RFR at levels that produce frank heating of the testes (l0-50 mW/cm:) tend to reduce fertility, but that such levels were not mutagenic. Experiments on male fertility in rats by Berman et al. (1980) yielded no eVIdence ofan increase ofdomirumt lethal mutations from 245-GHz RFR at power densities up to 28 mW/cm: McRee et al. (1981) found no Sutro EIR \ Anoendix B R-7R Appendix B. Biological Effects of RFR statistically significant effects ofexposure ofmice to 2.45-GHz RFR at 20 mW/cm: on the induction of sister chromatid exchanges, another sensitive technique for assaying genetic damage from mutagens and carCInogens. An extensive study by Meltz et al. (1990) on exposure ofleukemic mouse cell cultures to pulsed 2.45-GHz RFR. either alone or in combination with the chemical mutagen proflavin, yielded negative findings: The RFR In combination with proflavin produced no statistically significant increase in induced mutant frequency relative to the results for treatment with proflavin alom:. In addition, RF exposure alone~ielded no evidence of mutagenic action. Garaj-Vrhovac et al. (1992), assuming that RFR is a mutagen, exposed samples ofhuman blood to 7 7 GHz CW RFR at levels in the range 0.5-30 mW/cm: and analyzedl~mphocytestherefrom for chromosomal aberrations. They appeared to have obtained positive effects, but the absence of important information regarding their methodology and data treatment limit the reliability ofthese findings. nus is also the case for a study by Fucic et al. (1992) in which the authors reported changes in the size distributionsofl:-mphoc~temicronuclei in blood samples from humans occupationally exposed to X-rays, mIcrowaves. or vinyl chloride monomer. Ray and Behari (1990) reported various effects on rats ofexposure to 7.5-GHz pulsed RFR at about 0.6 mW/cm: average power density and about 1000 mW/cm: peak power density. Also, Sarkar et a.l. (1994), using the same exposure apparatus as Ray and Behari (1990), exposed mice to 2.45-GHz CW RFR at I mW/cm: for up to 200 days, and reported changes in DNA samples isolated from the brains and testes The findings ofboth studies are questionable for reasons similar to those above Among the most provocative recent research has been studies of DNA breakage fOllowing 2-hour long exposures of rats to CW and pulsed RFR (2.45 GHz). After exposure was completed. the rat brain was studied by the "comet assay'" a relatively recent technique in which, following disruption ofthe cell's plasma membrane. nuclear DNA IS made visible along \\ith any DNA fragments which may have resulted from damage to DNA. DNA fragments occur naturally because ofthe action of chemically active metabolic by-products (free radicals) and as the result of environmental chemicals and radiation. The comet assay reveals DNA damage at relatively low levels ofexposure to ionizing radiation and chemical age:nts. The comet assay gets its name from the appearance under the microscope of a central cloud of undamaged DNA with a faint tail containing DNA fragments which had be(:n dra\',n from the nucleus by an electric field. Depending on experimental methods, the comet assay can be used to measure fragments from single stranded or double-stranded DNA. Damage to double-stranded DNA is considered a better indication of potential damage to chromosomes and other adverse effects whIch, it can be speculated. could kad to degenerative diseases or cancer. The studies ofsmgle- and double-strand breaks (Lai and Singh, 1995. 19(6) indicated longer DNA comet tails for bram cells exposed to 2450 MHz microwaves at athermal SARs (0.6 or 1.2 W/kg) The study of single-stranded DNA indicated generally stronger effects for pulsed RFR in comparison with CW fields and stronger effects at the higher SAR However. CW RFR had an effect observable shortly after exposure whereas the effects ofpulsed RFR were observable only 4 hours later. The 1996 study was conducted only at 1. 2 W/kg. but tested for both single- and double-strand breaks. In this study both types of DNA were affected, but there was no difference betweenthl~effects of pulsed and CW fields. The temporal pattern ofthe effects on smgle-strand DNA was inconsistent with expectatIons based on acute DNA damage followed by repair Critics ofthese experiments have also challenged the ex1:reme alkaline conditions used for preparation of the tissues for analysis of single-strand Sutro EIR Appendix B B-29 07/06/97 Appendix B. Biological Effects of RFR breaks and contradictions between the results and expectations dra\\n from prior research on chemicals and IOnizmg radiation. One may speculate that DNA damage ofthe type observed could led to disruptions ofcell functions. cell death and perhaps cancer. but there is no conclusive eVidence that any ofthese potential effects occurs It remains to be seen if the observed DNA damage can be replicated by others. whether a non-themlal mechanism exists to understand the effects. and how to evaluate any relevance for health effects in exposed animals and human beings. Finally. it would be necessary to evaluate the potential for harm unde:r ordinary conditions of exposure. In particular. Sutro Tower RFR emissions are weaker than the 1 to 2 m\Vlcm 2 fields used in this study of rats and. at most, are at frequencies one-third as high as used by Lai ;md S10gh Cleary et al. (1990) studied the gro\\th ofcultured brain tumor cells which had previously been exposed for 2 hours to RF fields at 27 or 2450 MHz. The exposure levels ranged from 5 to 74 Wlkg, but the authors considered these in vitro exposure to be nonthemlal because the apparatus maintained temperature constant by use ofa circulated coolant. Cell growth was estimated by a radioactive technique that measures DN A synthesis. The finding claimed by Cleary et al. was that cell grovo.th rates were affected up to 5 clays after exposure. that is in cells several generations removed from the cdls exposed originally. There was no direct evidence that the indirect measurement of enhanced DNA synthesis was accompanied by an actual change in cell numbers. The authors also speculated that cell cycle kinetics were affected. again without direct evidence. DNA synthesis was affected most (up to a 25-fold mc:rease) by 2.45 GHz RF energy at a SAR = 25 W/kg. with lesser effects for exposures at both higher and lower levels. This study was the fi::>cus of much interest because of claims that it demonstrated a nonthermal effect on the growth ofbrain tumor cells and therefore might be a clue that RF energy in general stimulates cell growth. Stimulation of cell gro\\th rate is a hallmark of many substances that cause cancer and therefore there was the suggestion of a possible link from this result in vitro to cancer III humans. particularly for brain tissue of people exposed to the RF energy of cellular telephone fields. A number ofcautlOnary statements should be considered In order to evaluate thIS line of speculation Clear\ et al (1990) did not show a direct effect on ceIl growth and the observed changes in the radioactive counts may have other explanations: the exposure levels exceeded allowable safety guidelines and may have introduced local temperature increases despite aggressive heat removaL the bram cancer cells used in thIS research are rarely used in scientific research so that their growth properties are not wellkno\'vn~and most importantly, it is not possible to infer effects on a human being as a result offindings made in studies of cancer cells in the laboratory. In summary. some ofthe studies that yielded negative results and others that yielded positive results were questionable because of the likelihood of the presence of uncontrolled non-RFR factors or ofother kinds of artifact. In general, there is little if any reliable scientific eVIdence that exposure ofmammals or mammalian tissues to low levels of RFR (e.g., within current exposure guidelines) produces mutagenic or cytogenetic effects therein. 4.3.3 Cancer Induction or Promotion in Animal Experiments Possible association between chronic RF exposure and the incidence ofcancer has been reported in a number ofepidemiologic studies (see Section 3.1). but for the reasons stated there, little credence can be given to such findings On the other hand. other studies specifically directed toward determining whether RFR induces or promotes cancer in animals have been perfonned. Sutro EIR ADoendix B n'7/n(,IQ'7 Appendix B. Biological Effects of RFR In an early study by Prausnitz and Susskind (1962) in which 200 mice were exposed to 9.3-GHz pulsed RFR at 100 mW/cm 2 the authors had indicated the occurrence ofleukemia (a mistaken descnptJOn) m both , the exposed and control mIce, but in more ofthe exposed mice than the control mice. In a subsequent reanalysis ofthe primary data, Roberts and Michaelson (1983) concluded that the Prausnitz and Susskind (1962) study provided no evidence that chronic RF exposure does or does not induce cancer. A study by Skidmore and Baum (1974), in which biological effects were sought from exposure to electromagnetic pulses (EMP) [resembling the RFR from a nuclear blast], yielded negative findings Almost continuous exposure of20 female rats to EMP for 38 weeks at a peak electric field of447 kV/m produced no mammary tumors at age I year. Also exposed to the EMP were 50 male mice ofa strain kno~nto be susceptible to spontaneous leukemia development between 6 and 12 months ofage. After 33 weeks ofexposure, 42 ofthe EMP-exposed mice and 24 ofthe unexposed control mice survived and were examined for leukemia. Examination ofthe survivors showed that 9 ofthe 42 exposed mice (21%) were leukemic whereas 11 ofthe 24 control mice (46%) were leukemic. However, the sample sizes were too small to ascribe statistical validity to that difference in percentages. Unclear is why about halfofthe control mice had died, a possible indication that uncontrolled non-RFR factors were present. Chronic exposures to CW 2450 MHz RFR were reported to enhance the development of mouse skin tumors (Szudzinski et ai., 1982). These tumors were initiated by repeated applications of a cancer-eausing chemical to the skin of exposed and control mice. In correspondence~iththe more rapid appearance of tumors, exposed mice survived for markedly shorter periods oftime. Whereas the mean survival time for control mice was 331 days, the time for animals exposed to 5 mW/cm 2 (SAR 2 Wlkg) was 268 days and among animals exposed to 15 mW/cm 2 (SAR 6 W/kg). mean survival was only 165 days. This protocol and the results indicated that the RF exposures acted as a tumor promoter~itha clear dose-response relation. In another ann ofthe study, the authors found that pre-exposure of mice to 10 mW/cm 2 (SAR 4 W/kg) for 1. 2 or 3 months before the carcinogen applications also enhanced tumorgro~thand reduced lifespan. As the authors suggested. this protocol and results fit the pattern expected for an agent whIch mhiblts immune system functIon. AdditIOnal studIes are needed to demonstrate such an effect on the Immune system and a positive finding would conflIct \\'Ith other data on Immune function (see section 4.6) The authors stated that the power densitIes were too low to cause detectable mcrease of body temperature, but it appears body temperatures were not measured. Szrnigielski et al. (1982) investigated whether exposure to 2 45-GHz RFR at 5 or 15 mW/cm 2 : would decrease the resistance to lung cancer cells injected before exposure of Balb/c mIce (a naturally resistant strain): increase the incidence ofbreast tumors in femaleC~HlHeAmice (a strainkno~nto have high spontaneous incidence ofsuch tumors); and mcrease the inCidence ofskin cancer in male Balb/c mice depilated and painted with a chemical carcinogen (BP) The latter protocol on skin tumors is the same as used by Szudzinski et al. (1982) and some data appear to ben~peatedin both studies. For comparison, other groups of mice were sham exposed or raised under confinement conditions kno\W to cause a chronic stresss~ndrome In the lung-eancer part ofthe study, the numbers of neoplastic nodules for those exposed at 5 mW/cm 2 and for those stressed by confinement were comparable. and were between those for the groups exposed at 15 mW/cm 2 and the sham-exposed controls, a positive finding However, since confinement stress alone was found to increase tumor incidence, it seems likely that the added heat stress from the higher RFR level was responsible for the increases in tumor incidence and not any presumed intrinsic carcinogenic properties of RFR. The results for the breast-eancer part, presented in tenns ofthe mean cancer development times and Sutro EIR .. Appendix B B-31 07106197 Appendix B. Biological Effects of RFR mean survival times in 50% ofthe mice, were analogous. as were those in the skin-eancer part ofthe stud: Again, the RFR-induced increases in skin-eancer incidence at 15 mW/cm 2 relative to 5 mWIcm: and confinement stress were probably due to the heat stress at the hIgher RFR level rather than froman~ intrinsic properties ofthe RFR. Szmigielski et a1. (1986) provided a critical review ofthe world literature on immune cell and immune system responses. They concluded that there was "no convincing evldence" for effects on immune cells tested in vitro under non-thennal conditions. Based upon this observation they argued that the reported in vivo effects are caused by effects on endocrine factors and other means for regulation of the immune system. They also suggest the possibility ofa nonspecific stress reaction. Szmigielski et a1. (1986) reported additional studies on tumor development involving the carcinogens dl ethyl-nitroso-amine (DENA) and methyl cholanthrene which led to the conclusion that RFR was not a carcinogen but did function as a tumor promoter. A study showing enhanced cAMP levels in cells was, according to the authors, evidence for nonspecific stress. 10 summary of animal studies with low level (non thennal) RFR. the authors concluded that tumor promotion was a "general phenomenon" Santini et a1. (1988) sought to determine whether low-level exposure ofblack mice would affect the development ofB16 melanoma from cells injected into the animals or survival times. The authors exposed one group of 15 mice to 2.45-GHz CW RFR at 1 mW/cm 2 for 6 daily sessions per week. 2.5 hours each day, until death (up to 690 hours total). Another group \...as slffiilarly exposed to 2.45-GHz pulsed RFR at the same average power density. A third group was sham exposed as controls. No statistIcally significant differences were found among the three groups either in tumor development or survival Tumor development might have been affected either by a direct influence on the tumor cells. or through effects on the Immune system or general health. This study provides e'vldence that RF exposure did not affect the progression oftumors by any mechanism In a comprehensive study by the University ofWashington by Chou, CK. AW Guy. LL Kunz. RB Johnson. J Crowley, and JH Krupp (1992) on health and longeVIty. 100 rats v,'ere exposed unrestramed in indIVIdual cylindrical waveguides to 2.45 GHz RFR at 0.4 to 0.15 mW/cm 2 over the lifetimes ofthe exposed animals (except those \\ithdrav..n for interim tests and those that expired before the end ofthe exposure regimen). and 100 rats were concurrently sham exposed. After 13 months. 10 each ofthe RFR-exposed and sham exposed rats were euthanized (the interim kill). as were 10 ofthe 12 RFR-exposed and 10 ofthe II sham exposed rats that had SUrvived to the end of the 25-month exposure regimen (the terminal kill). The whole body average SAR of 04 Wlkg was the basIS for the ANSI 1982 RF safety guidelines and is the basis for current ANSlIIEEE C95.1-1992 standard for the controlled envIronment Only 3 benign neoplasms occurred in rats younger than I year. and those were in the sham group. During the second year. benign neoplasm incidence rose rapidly \....Ith age for both the RFR and sham groups, but the differences between the groups at each age of death were nonSIgnificant No primary malignant lesions were found in the rats of either group younger than 1 year, but were found in 2 RFR-exposed and 2 sham-exposed rats at ages 13-18 months, in 9 ofthe RFR group and I ofthe sham group at ages 19-24 months. and in 7 ofthe RFR group and 2 ofthe sham group at ages 25-30 months. Thus, without regard to age, totals of 18 rats with malignancies were found in the RFR group and 5 rats in the sham group, a difference noted by the authors to be statistically significant. However, they indicated that the incidence of each specific primary malignancy In the RFR group was similar to the incidence of c ..'t_..... t:'JO', -\_....~A:?. 0 Appendix B. Biological Effects of RFR that malignancy reported in the literature for untreated rats ofthe same strain. Also, the lifespan of the two groups was the same; 12 out of 100 exposed and 11 out of 100 control lived until the last day ofthe experiment. They stated: "The finding here of excessive malignancies in the exposed animals is provocatIve: however, when this single finding is considered m lIght ofother parameters evaluated. it is questionable ifthe statistical difference reflects a true bIOlogical acti\;ty" The low energy of RFR precludes damage to DNA such as is produced by x-rays and other forms of radioactivity. As a result, researchers have placed emphasis on the questions concerning the possibility that RFR might enhance tumors by promoting the growth ofcells which had already been started along the path to cancer. A part ofthe long and variable sequence of events which follows initiation ofthecancl~rprocess IS identified as "tumor promotion" Wu and colleagues (WU et a1. 1994) reported on groups of mice exposed to a chemical initiator of colon cancer in combinatIOn \\ith a chemical cancer promoter aJ1d 2450 MHz RFR at a power density of 10mW/cm~(average SAR 10-12 W/kg). Despite the relatively high levels of exposure there was no evidence that exposures over a five month period for 3 hours daily. 5 days per week. had any influence on colon tumor incidence. size or severity. Modem genetic techniques permit new types ofexperimentation through the study ofgenetically alterecl cancer-prone mice. An Australian research team made long-term exposures to a group of 101f(~rnalemice from a strain oftransgenic mice into whose genome the Piml gene had been inserted (Repacholi, et aL (1997). This genetic alteration predisposes the mice to a higher rate ofT-eelllymphomas. A useful feature ofthis model is that the tumors in these nuce closely resemble spontaneously arising lymphomas. Exposures to pulse-modulated 900 MHz RFR ofthe type used for the GSM type ofcellular telt:phone transmission were conducted for two 30 minute periods daily for up to 18 months. Compared to a group of 100 controls. the nsk oflymphoma among exposed mice was more than doubled (OR = 2.4) wilth a high degree of statistIcal confidence (P = 0.006.95% CI = I 3-4)). Interpretation ofthis result is made difficult by some of the features of the experiment. First. exposures were made in an unusual apparatus which permItted a v.ide range of exposures to individual mice and a ten-fold range in average e:xposures to each group of five exposed mIce (0.13 to 14 W/kg). Although It appears that the mice received, at most. mildly thermal exposures. a better understandmg ofthe exposures IS needed. Second. unlike pnor studies with this model system. the mice were allowed to live past the age at whichIymphoc~ticlymphomas occurred with the result that the majority ofl)mphomas in exposed and control mice were ofthe non I~mphoblastictype (including a preponderance of B-eelllymphomas) and arose after the mice were 10 months of age. Among the controls there were 22 total lymphomas ofwhich 19 were non-lymphoblastic and 3 lymphoblastic. Among the exposed animals there were 43 totall)mphomas ofwhich 37 were non l)mphoblastic and 6 lymphoblastic. If only I)mphoblastic tumors were considered, the results of this expenment would be negative Third. a further complication for the study was the occurrence ofsevere obesity among both control and exposed mice which could may have influenced absorption ofenergy and the animal's ability to diSSipate RFR heating. Fourth. about 10% ofmice developed a severe kidney disease which. in combination with RFR might have influenced the progress ofthe cancer. Finally, it is not known if results such as these from genetically altered mice have any direct bearing on carcinogenesis. particularly I~mphomagenesisin humans who, so far as known, do not carry an activated Piml gene. These and other questions should be addressed in studies which attempt to replicate the findings and understand its mechanisms It should be noted that the pulsed RF fields use:d 10 the Australian study differ from Sutro Tower DTV signal wavefonns and have power denSities (ranging from 0.26 to 1.3 mW/cm 2 ) which exceed those found an)where in the environment of Sutro Tower (q. \ calculated power densities, section 3. 14 of the EIR) Appendix B. Biological Effects of RFR Collectively. the various RFR-bioeffects investigations lead to the conclusion that exposure ofeither mammalian or nonrnammalian subjects to RFR at levels \\ithin current exposure guidelines does not produce mutations or cytogenetic effects. Experiments also show that RFR does not induce or promote specific cancers in animals. However. expenmental results m rats exposed to pulsed RFR. mIce treated \\lth cancer-eausing chemicals. and recent results with genetically altered mice leave open the possibility that under particular experimental conditions RFR at levels which do not cause biologically important degree oftissue heating may influence the course ofthe cancer process. In the absence of confirmed results. in light of contradictory elements in the research results. and because there are conflicting data showing RFR is not carcinogenic, it is not possible either to firmly dismiSS nor accept the hypothesis that RFR can influence cancer. Results with cultured mammalIan cells. however. support the conclusion that RFR is not a carcinogenic agent. Upon consideration ofavailable scientific evidence. and in view ofthe the signal characteristics for Sutra Tower RFR emissions and the relatively low levels ofexposure, the experimental evidence leads to the conclUSIOn that exposure to RFR from the Sutro Tower Digital TV transmitters would not cause mutations. c~togeneticeffects nor cancer in the general population 4.3.4 In Vitro Cancer Initiation or Promotion Balcer-Kubiczek and Harrison (1991) exposed cultures of mouse-embryo-fibroblast cells for 24 hours to 2.45-GHz RFR alone at an SAR of 0.1, I, or 4.4 W!kg, or to the RFR at 4.4 W!kg before or after exposure to X-rays at 0.5, 1, or 1.5 Gy. After such treatments. they incubated the cultures with or \\;thout a knO\\TI tumor promotor (TPA) and then assayed them for the incidence of neoplastic transformations by counting the number oftransformed foci in culture dishes RF exposurc alone produced no cvidence oftumor promotion. but the mean neoplastic transformation Incidence was higher for the RFR-exposed cultures incubated \\ith TPA. The results were regarded by the authors as indicating that RFR acts to initIate neoplastIC transformation. However. the numbers of fOCI found relative to the numbers of dishes treated were small. the counting was apparently not done \\;thout prior knowledge of the treatment of each dish. and the numbers of dishes used for each treatment differed considerably. The latter pomt raIses the question whether the authors may have increased the number of dishes for each treatment until they obtained adequate percentages of fOCI for statistical analysis Also open to questIOn is how well were the culture temperatures controlled. particularly at 44 W!kg 44 TERATOGENESIS Teratogenesis refers to the causatIOn ofanatomical aberrations (terata) in a developing fetus. but more generally also mcludes fetal death and/or resorption and postnatal abnormalities In the offspring. Such effects occur naturally at low rates In most mammals, and relatively little is known about their causes. In a few cases, however, specific agents have been sho\\TI to cause significant effects, and hence the possibility that such effects could occur from exposure to RFR IS an appropnate matter of public concern The term is usually applied to mammalian fetuses and IOfants. but effects on nonrnammalian subjects also have been sought. Sutro EIR ' Appendix B B-34 07/06/97 Appendix B. Biological Effects of RFR 4.4. 1 Insects Various studies were done with pupae ofthe darkling beetle. In studies by Carpenter and Livstone (1971) at 10 GHz and by Lindauer et al. (1974) and Liu et al. (1975) at 9 GHz, in which pupae wereI~XPOSedat relatively high power densities, the percentages ofabnormal beetles were much higher than from sham exposed pupae. Carpenter and Livstone (1971) also reported that the percentages ofabnormal beetles were much higher from RFR-exposed pupae than from pupae conventionally radiantly heated to the same temperature, which led the authors to conclude that abnormal development ofRFR-exposed pupae could not be explained as a thermal effect. However, Pickard and Olsen (1979) found that the percentages of abnormal control beetles obtained from two different suppliers differed significantly, in part because the food given by each supplier to the larvae from which their pupae were derived differed from one another. an indication that uncontrolled non-RFR factors may have been present in the experiments. In addition. Olsen and Hammer (1982). in using scanning thermography on RFR-exposed pupae, found large variations of local SAR~ithinthem that would not occur with the radiant heating used by Carpenter and Livstone (1971) Thus. the non-thermal hypothesis of Carpenter and Livstone (1971) remained unproved 4.4.2 Birds McRee and coworkers performed a variety ofstudies on Japanese quail. in which the effects of exposure to 2.45-GHz RFR of arrays of eggs were examined. Among the dfects sought were: hatchabilit), percentages of dead and deformed chicks, body-weight and organ-weight deficiencies between RFR-exposed and sham exposed chicks, and adult-bird fertility. Some studies yielded no significant differences betwet:n exposed and control groups: in others. Significant differences ill various endpoints were found. but were ascribable to temperature rises withm the eggs during RF exposure As an example of positive findings, McRee et a1. (1983) reported lower fertility and lower spelID motility and counts m quail hatched from fertile eggs exposed to 2.45-GHz CW RFR continuously at 5 mW/cm: (mean SAR 4 W!kg) during the first 12 days of IOcubation. However, the spatial variation of temperature Wlthm eggs exposed at relatively high SARs, e.g. 4 W!kg, can 'be large, thereby yieldlOg spatial-maximum temperatures higher than the basically uniform temperatures within conventionally incubated eggs. Also, Gildersleeve et a1. (1987a), in an extension ofthe McRee et aL (1983) study, investigated the reproductive performance of quail from eggs that had been exposed at the same RFR level during the first 12 days of embryogenesis. The results showed that such exposure during embryogenesis did not affect any of the endpoints they studied. which included: hatchabiltty. mortality after hatching, egg production, 'egg v,·eight. fertility ofthe initial groups, and reproductive performance oflhe progeny. Negative findings were also obtained by Spiers and Baummer (1991) Studies were done on chicken and turkey eggs by Hills et a1. (1974), Fisher et a1. (1979), and Saito et a1. ( 1991). Hills et a1. (1974) exposed groups ono fertile chicken eggs at various stages of devdopment to 60-GHz CW RFR at a spatial mean power density of 0.2 mW/cm 2 . In another experiment, there were 25 turkey eggs per group. The results showed no significant effect on the hatchability or the growth of chickens or turkeys up to two weeks ofage. The exposure methodology and dosimetry aspects ofboth the Fisher et al (1979) and Saito et al (1991) studies were flawed, rendering their findings meaningless. In summary, exposure to RFR ofthe eggs or after hatching of various species of birds yielded significant teratogenic effects of various kinds, but only at levels that caused temperature elevations well above those Sutro EIR \ Appendix B B-35 07106 1 97 Appendix B Biological Effects of RFR normally used for incubation. However, no experimental e\idence v.<lS found to support the hypothesis that RFR is intrinsically teratogenic and there is no evidence that non-thermal RF exposures can be teratogemc 44.3 Mice and Hamsters Many teratogenesis studies were done with mice or hamsters as the subjects, with mixed results. The following are representative examples. Rugh et a1. (1974, 1975) exposed groups ofCF-l female mice to 2.45-GHz RFR at 138 mW/cm" (SAR about 123 W/kg) for various durations, and determined that the mean dose (power density x duration) per unit body mass for lethality was about 11 cal/g or 46.1 J/g. Among their findings were fetuses '",ith bram hernia (exencephaly, an effect consistently produced in CF-l mice by exposure to ionizing radiation) The percentages per litter offetuses with brain hernia were plotted versus total dose. Exencephaly was absent in at least 45 litters, spanning the total dose range from 34 to 7.8 cal/g; 2 litters had 60%, the highest incidence, at about 7 cal/g; and the remainder (about 50 litters) had intermediate percentages, in the range 43-7.8 cal/g From exposure at a sublethal level [123 mW/cm"; SAR about 110 Wlkg] on the gestation day ofhighest sensitivity to ionizing radiation, the authors remarked that they could not find any teratogenesis threshold Reanalysis oftheir data, however, showed the existence ofathn~shold:At mean doses less than about 3 cal/g or power densities less than about I mW/cm", 100% oftbe fetuses examined were normal. Significant numbers ofabnormal fetuses were obtained at RFR levels above that threshold. but the dependence on dose was obscure. Chemovetz et a1. (1975) found that absorption of about 5 cal/g IS not teratogenic to mice. a threshold conSiderably higher than the 3-eal/g value above In addition. they found that the mean total-dose lethality ofthe dams was about 5.7 cal/g. an indication that teratogenesis would occur in pregnant mice only at levels that are close to lethality for the dams. Na\\Tot et al. (198 I) found that handling ofnuce: prior to exposure affected the results relative to those for unhandled mice Their data also mdicated that the power density or whole-body-SAR threshold for teratogenic effects 10 CD-I mice is about 30 mW/cm" or 40 W/kg. A study by Stavinoha et al. (1975) involving exposure of mice for 20 minutes to 10.5-MHz, 19.27-MHz, or 26.6-MHz RFR pulses at an electric field strength of 5.8 kV/m showed essentially no differences between mice exposed at each frequency and control mice in subsequent daily weights at corresponding ages up to 21 days. Berman and coworkers carried out a number of studies. \..-ith exposures at power densities up to 28 mW/cm: (22.2 Wlkg). In Berman et a1. (1978), the numbers of litters with one or more anomalous fetuses terms of 10 types ofanomalies were tabulated. For most ofthe specific anomalies, either the numbers of litters affected were too small for statistical treatment or no RFR-related pattern was apparen1t. Berman et al. (1978, 1982a, 1982b, 1984) found consistently smaller mean body weights of live fetuses from mice and Syrian hamsters exposed to 245-GHz RFR at 280 mW/cm 2 In summary. various teratogenic effects have been produced in mice and hamsters by exposure to RFR, but as with birds, only at levels that yielded temperatures elevated well above normal. SUlro EIR \ Appendix B B-36 07/06/97 Appendix B. Biological EffecL<: of RFR 4.4.4 Rats Chernovetz et al. (1977) exposed pregnant rats to 2.45-GHz RFR at 31 W!kg and to infrared radiation OR) at 47°C to produce the same colome temperature rise of3.5°C as the RF exposure. Control rats were sham exposed. The percentages of livmg fetuses per dam were lower in the RFR group than m the IR and control groups. No structural abnormalities were evident in any ofthe formed fetuses, but severe edema and hemorrhagic signs were endemic in the IR and RFR groups Shore et al. (1977) and Berman et al. (1981) found little evidence for RFR-teratogenic effects in rats. but did find significant deficits in mean body weights of neonates from exposed rats relative to controls. Berman et al. (1981) concluded that the rat is an inappropriate model for determining whether RFR wouId be teratogenic to humans in exposure situations not lethal for the: mothers, and suggested thatthl~mouse IS more suitable for that purpose. Lary et al. (1983) observed teratogenic effects in rats exposed to 27 .l2-MHz fields (not in the Sutro Tower Digital TV transmitters frequency band) at 55 Aim and 300 V/m (SAR about 11 W/kg). but of seven!) that increased with colonic temperature. The largest changes were seen for prolonged exposure to maintam colonic temperature at 42.0 °C The authors ascribed thoseem~tsto the hyperthermia induced by the RFR. A subsequent study by Lary et al. (1986) with the same RFR indicated the existence of a colonic temperature threshold of41.5 °C for birth defects and prenatal death. Tofani et al. (1986) reported teratogenic effects in rats exposed to 27. 12-MHz RFR (not in the Sutro Tower Digital TV transmitters frequency band) at field strengths of 20 Vim and 0.05 Aim (eqUIvalent power densi!)' 0.1 mW/cm:: author-estimated SAR about 0.000 II W/kg). They had charactenzed the effects as nonthermal and due to long-term exposure. but Lu and Michaelson (1987) took issue \\;th the exposure apparatus and methodology used and With the findings. Bro\\n-Woodman and Hadley (1988). usmg two different diathermy units, reported that treatment of pregnant rats to 27 .12-t\-lliz RFR (not in the Suno Tower Digital TV transmitters frequency band) at levels supposedly too 1m\" to raise core temperatures v-.ith one umt increased the mean number oflive embryos and decreased the percentage of resorptlOns \\;th increasing power.. whereas the opposite trends were obtained for treatment v-.;th the other unit. Little ifany credibih!) can be given to the finding ofnon-thl~rmal-RFR­ induced teratogenicity in this study, or to a similar study by Brown-Woodman et a! (1988). From the results ofa third study, Brown-Woodman et al. (1989) stated: "It would appear that breeding behavior, hormonal cycling andlor the survivability ofthe eggs before Implantation must be affected by the pre breeding exposure of the rats to RF radiation." However. they did not provide enough data to permit evaluatIOn of their statistical treatment ofthe results Also. the lack of adequate dosimetric data (SARs and their temporal and spatial vanatIOns). rendered It dIfficult to ascribe any credibility to their findings. In the first ofa pair of studies, Jounce et al. (1982a) ex.posed pregnant rats to 915-MHz CW RFR at 10 mW/cm" for 6 hours per day on gestation days 1 to 21. The mean SAR over the gestation pt:riod was 3.57 W/kg. No statistically significant differences were found between the RFR-exposed and thre:e distinct control groups in mean litter size or mean 21-day-old fetal weight, or in organ-to-body-weight ratios for any ofthe organs. In Jensh et al. (l982b) (the companIOn study], half of the initial (Fla) offspring ofthe exposed and unexposed dams were killed at age 90 days and examined for histopathology. Tbe other rats were cross-bred in various combinations of ex.posed and control males and females, and the resulting litters Appendix B. BiologIcal Effects of RFR (F2) were examined prenatally for teratogenesis. In the cross-bred females. there were no significant RFR related differences in mean maternal weight. percentage of resorptlons. or 10 F2 fetal weight or htter SlZ;,? In the second pair of studies. Jensh et al. (l983a. 1983b) used 2.45-GHz RFR. and obtained similar negative findings. This was also true for Jensh et al. (l984a. 1984b) [the third pair ofstudies]. performed \\-1th 6-GHz RFR at 35 mW/cm 2 (about 7.3 W/kg). except for the mean fetal weight at term. which was significantly lower for the RFR group than for the concurrent-control (sham) group. However. the weight differences among the three control groups were also significant which could indicate that the lowe:r mean fetal weight ofthe RFR group may not have been RFR-induced. Perhaps the most important finding of these studies was the absence of any terata in Fla. FIb. and F2 offspring from prolonged exposure ofrats (8 hours per day throughout their first pregnancy) to 6-GHz RFR In summary. the only relatively consistent findings in pregnant rats at RFR levels that produced significant body-temperature elevations were the differences in neonate body weight between RFR-exposecl and sham exposed dams, but such findings were not found in all such studies. 4.4.5 Nonhuman Primates Kaplan et al. (1982), exposed 33 pregnant squirrel monkeys near the beginning ofthe second trimester to 2.45-GHz RFR within special microwave caVIties for 3 hours/day. 5 days/week. until partuntion, in which possible effects were sought on mother-offspnng behaVIoral patterns and the EEG. The whole··body SARs were 0.034,0.34, or 3.4 Wlkg (plane-wave equivalent to O. L Land 10 mW/cm 2 ). After parturition. 18 of the RFR-exposed dams and their offspring were exposed to the RFR for 6 more months: then the offspring were exposed without the dams for still another 6 months. An unexpected excess of infant deaths occurred. but the: total number of animals involved was small. In a subsequent investigation v.ith infant mortality as the basic endpoint, in which enough animals for an adequate statIstical treatment ofthe results were used. the previous finding of an excess of unexpected infant deaths could not be confirmed. The authors did not proVIde any data. but as stated in a note added in proof to Kaplan et al (1982). the differences between RFR-cxposed and control groups in the numbers of abortions. stillbIrths. live bIrths. or 10fants that subsequently died were not significant. Taking the RFR-teratogenesis studies collectively, the findings indicate that such effects can occur in both nonmanunalian and mammalian subjects from RF exposure, but only at levels that produce significant temperature rises The results for manunals sho"..· that increases in maternal body temperature that exceed specific thresholds (41.5°C in rats) are necessary to cause teratogenic effects The experimental evidence indicates that RFR is not intrinsically teratogenic and that nan··thermal RF exposures are not teratogenic. 4.5 NERVOUS SYSTEM Concern has been expressed that direct (nonthermal) interactions of RFR with the central nervous system (CNS) could produce deleterious physiological effects It has been postulated that such effects may be manifested as alterations in behavior. passage of foreign agents from the blood vessels in the brain into the surrounding tissue by opening ofthe blood-brarn barrier (BBB), changes in the histopathology and histochemistry ofthe nervous system and ofthe electroencephalogram (EEG), and changes in the efflux of calcium from brain tissue. Sutro EIR ' Appendix B B-38 07/06/97 Appendix B. Biological Effi;cts of RFR 4.5.1 Blood-Brain-Barrier Effects In most organs and tissues ofthe body, various molecules in the blood can freely diffuse into thl:: tissues around capillaries However. to protect the bram from invasIOn by blood-borne microorganisms and toxic substances. the BBB in most regions of the brain allows little or no movement of large fat-insoluble molecules from the blood mto the surrounding brain tissues The BBB can be "opened" by certain agents (such as ionizing radiation or excessive heat) or by chemical substances (e.g.. dimethyl sulfoxide). Studies have been conducted to determine ifRFR can alter the permeability ofthe BBB in arumals to substances of large molecular weight. The preponderance ofnegative sCientific experimental findings indicates that exposure to pulsed or CW RFR at low levels would not alter the human BBB. Early studies by Frey et a1. (1975) and Oscar and Hawkins (1977) \\1th rats can be disregarded because of eVidence ofartifacts in the methods used in their experiments. Moreover. Merritt et aI. (1978) and Ward and Ali (1985) were unable to reproduce those findings, and Preston et a1. (1979) showed that certain specific RFR-induced changes in the brain could be interpreted wrongly as BBB alterations. Preston and Prefontaine (1980) and Gruenau et al. (1982) obtained negative findings regarding RFR-induced alteratIOns ofthe rat BBB. In several studies, Albert and coworkers used light microscopy and electron microscopy to examine brain slices from hamsters exposed to RFR. The results were questionable because leakage ofthe tracer used was found in slices from control animals as well as from exposed animals. Four comprehensive studies by Williams et al. (1984a, 19Mb. 1984c. 1984d) in which several different tracers and methods were used for detecting BBB penetration In the rat also yielded negative findings. Neilly and Lin (1986) showed that disruption of the rat BBB at high RFR levels is due to elevation ofbrain temperature. In addition. they found that high doses of ethanol inhibit BBB disruption by moderating the mcreases m brain temperature produced by the RFR. In view ofthis convincingly negative pattern of results It is therefore surprising to find that a recent study by Salford et al. (1994) reported highly statistically significant effects of 2 hour exposures to rats at SARs between 0 016 and~W/kg. Both CW and pulsed waveforms at q 15 MHz were used \vith similar results Microscopic evidence for leakage across the BBB was scored by an observer who appeared not to be blinded to the treatment condition. Statistically significant results (odds ratIO == 3.8. P==0.0004) were reported for all pulse rates (8 to 200 per second) and for CW fields. BBB breakdown showed no dose response for SARs from 0.016 to 2.5 Wlkg. but was more pronounced at 4-5 Wlkg The relatively extreme degree of BBB breakdo\\11 found by Salford et al. (1994) and the absence of dose-response suggests greater stress on the exposed animals than was the case in comparable research Conditions for the control animals were not described and they do not appear to have been treated by sham exposure in the same apparatus as was used for exposure. It is difficult to accept the accuracy ofthe reported results in view of omissions and defiCiencies in the experimental procedure (lack of blindmg ofthe observer. lack ofshams, possible thermal or confinement stress to the exposed animals), the high degree of BBB leakage which was inconsistent with similar research, the apparent absence ofa defined experimental protocol for the histological and statistical analyses. and uncertain mformatlon about actual exposures to brain tissue for the particular test apparatus used In summary, the uncertainties in most earlier research on this tOpiC hinge on whether significant artifacts were introduced by the kmds of biological techruques used. For example, the results of several studies have sho\\TI that exposure to RFR may alter the size of vascular and extravascular volumes and cerebral blood flow rate. thereby yielding apparent but not real changes in BBB permeability Much credence can be Sutro EIR AppendIX B B-39 07/06/97 Appendix B. Biological Effects of RFR given to the findings ofmore recent studies in which positive controls (knO\\ll BBB-altering agents) were used. In conclusion. hyperthermic levels of RFR clearly can alter the permeability ofthe BBB. but there IS little or no scientifically reliable evidence that RF exposure at levels that do not increase brain temperatur;: does so. 4.5.2 Neural Tissues: In Vitro Studies RFR effects have been sought in neural tissues excised and kept alive in appropriate solutions while undergoing RF exposure. Courtney et al. (1975) excised superior cervical ganglia from rabbits.. immersed each ganglion in a physiological solution., and treated each for alternating I-minute intervals ofl~xposure and no exposure to 2.45-GHz CW RFR at a power density up to about 300 mW/cm: (660 W/kg) Dunng treatment, each ganglion was stimulated with 100-300 !-is pulses at I pps, and the response latencies for s~naptIctransmission were measured. No significant differences were found m the mean response latencies measured during and between exposures. Chou and Guy (1978) also obtained negative results with the rabbit vagus nerve and the cat saphenous nerve. as well as the rabbit superior cervical ganglion Among histochemical effects sought were RFR-induced alteratIOns in the activities ofenzymes acetylcholinesterase (AChE) and creatine phosphokinase (CPK) in rabbit blood. Olcerst and Rabinowitz (1978) found that 2.45-GHz RFR significantly decreased AChE activity, but only at an RFR level sufficient to denature AChE (about 125 mW/cm2). Also, Galvin et al. (1981c) observed that 2.45-GHz RFR did not affect the activity ofeither AChE or CPK at SARs up to 100 W/kg. Zakharova et al. (1993) sought effects ofamplitude-modulated ()DO-MHz RFR on spontaneous impulse actiVIty in 500-!-im-thick frontal slices ofthe gumea-pig sensorimotor cortex. and Miura et al. (1993) sought to determme whether exposure of rat-cerebellum preparatIOns to bursts of 10-MHz RFK each lasting 200 !-is and spaced at 200-!-is intervals, would increase the productIOn ofcyclic GMP. Because of questions on methodology in both studies. little if any credence can be given to their positive or negative findings. Thus. the findings of the credible studies above were negative except for exposures to clearly thermal RFR levels. 4.5.3 Histopathology and Histochemistry ofthe Central Nervous System: In Vivo Studies InvestigatIOns were also carned out on neural tissues excised from animals after they had been exposed to RFR. Sanders et al. (1980) found decreases in the concentratIOns ofadenosine triphosphate (ATP) and creatine phosphate (CP) in the rat brain from exposure ofrats to 59 I-MHz CW RFR at 5 or 13 mW/crn: relative to those ofsham-exposed rats. The difference in results for the two RFR levels was nonsignificant, but they concluded that the changes could not be ascribed to general tissue hyperthermia (but they did not exclude local hyperthermia) Instead. they remarked that the data support the hypothesis that RFR inhibits the electron transport chain functIOn m bram mitochondria. thereby decreasing brain energy levels Sanders et al. (1984) performed similar experiments. but at 200 MHz and 2,450 MHz as well as at 591 t-.rnz, all at 13.8 mW/cm: Local SARs. determined \\ith a non-perturbing probe in the brain of a dead rat during exposure ofthe carcass. were about 0.6,2.6, and 5.1 W/kg, respectively The results for 200 MHz and Sutro EIR' Appendix B 8-40 07 1 06/97 Appendix B Biological Effects of RFR 591 MHz were similar, but no changes were detected for 2.450 MHz. from which the authors suggested that the effect is frequency-dependent. The experiments were performed on anesthetlZed rats. with consequent lowering ofbrain temperatures Whether similar results would occur in the absence of anesthesIa has not been detennined. Although some points in those studies are open to questioIl. the positive findings are worthy offurther investigation Albert et al. (\ 981) noted that prenatal development of the manunalian brain depends on migration of nerve cells, and that a readily identifiable cell class in the cerebellum called Purkinjecells arises dunng the second halfofgestation. They reported lower mean counts ofPurkinje cells In 40-day-old rat pups exposed to RFR for 5 dayS in the womb to 2.45-GHz RFR at 10 mW/cm: than for sharn-exposed pups. results are open to question because ofthe large variations in SAR (0.8 to 6 Wlkg, 2 Wlkg estimated mean) due to movement ofthe dams during exposure. Merritt and Frazer ( 1975) obtained negative findings in mean bram concentrations ofvarious neurotransmitters and their metabolites assayed m mice exposed to predominantly electric or magnetIc fields at 19 MHz. However, the authors noted that at 19 MHz. a mouse absorbs very little energy from either field. Lai et al. (1988) investigated the effects of exposure to 2.45-GHz CW and pulsed RFR at \vhok-body SARs ofabout 0.6 Wlkg on choline uptake in various regions ofthe rat brain. using circularly polanzed RFR in individual cylindrical waveguides and plane-polarized RFR in a miniature anechoic exposure chamber. The spatial mean SAR in the rat head was about 077 Wlkg in the waveguides (with the rat facing the source). and 0.56 Wlkg in the anechoic chamber. Both positive and negative findings were obtained. The authors suggested that the differences m results for CW and pulsed RFR in certain brain regions could be ascribed to the RFR auditory effect. They did not suggest specific mechanisms for results In other regions where CW and pulsed RFR had SImilar effects In summary. histochemical changes in the CNS were seen at relatively low SARs by Sanders and coworkers (1985) and Lai et al. (1988). but their significance WIth regard to possible human health hazards IS not clear and needs further investIgation Taken collectively With other expenmcntal results in whIch the effects observed were ascnbed to local increases In braIn temperature. It seems unlikely that exposure to RFR levels that do not increase local braIn temperatures would cause deleterious histopathologic or histochemical effects in the human central nervous system. 45.4 EEG- and Evoked-Response Changes Investigations have been carried out to ascertain the effects of RFR on the electroencephalogram (EEG) and on the evoked responses (EVs) by visual or auditory stImulI Basic problems ·WIth most ofthe early studies. such as those of Baranski and Edelwejn (1968. 1975) and Takashima et al. (\979). were the use of metallic electrodes to record EEGs or EVs during exposure to RFR: theIr presence probably caused enhancement of the Incident fields at the electrode sItes. and artifactual data in the recordings due to pickup ofthe fields by the leads from the electrodes to the instrumentatIOn. The findings ofearly studies can be discounted because of such use. On the other hand. EEG measurements taken after completion of RF exposure may be less definitive because of interpretation problems stemming from the time consumed in attaching the electrodes and the variability In theIr placement. Moreover, any transient effects that may occur during RF exposure would disappear when exposure ceases. The latter points are applicable to the negative findings of Kaplan et al (1982) on monkey EEGs. Sutro EIR \ AppendIX B B-41 07 1 06197 Appendix B. Biological Effects of RFR In several studies, such as those by Tyazhelov et a!. (1977) and Chou and Guy (1979a), effort was made ro minimize artifact occurrence by design of electrodes and leads from materials having high resistlvltles comparable to those for tissue. When such electrodes 'were Implanted before exposure and were present during exposure, no significant differences in EEGs or evoked responses between control and RFR-exposed animals were obtained, as exemplified in a study by Chou et al (l982). Thus. there is little or no evidence that the EEG or evoked responses ofpeople will be affected by RFR at levels below current exposure guidelines. 4.5.5 CalcIUm Efflux Increased release of calcium from brain tissue of newly hatched chickens was observed when the tissue was exposed to 147-MHz or 450-MHz RFR at levels in the range 1-2 mW/cm" only ifthe RFR was amplitude modulated at certain relatively low frequencies. The authors reported that. under specified exposure conditIOns, more calcium ions were exchanged between the exposed brain hemisphere and the fluid bathing it in comparison with the unexposed hemisphere (the "calcium-efflux effect"). The maximum effect was seen for modulation at 16 Hz and no effect was seen for unmodulated (CW) 147-MHz or 450-MHz RFR Bawin et a!. (1975) described the basic experimental protocol for chick brain studies. Subsequently. others conducted studies with chick brain (Blackman et aI., 1979. 1985), rat brain (Shelton and Merritt. 1981. Merritt et a!.. 1982), cat brain (Adey et aI., 1982). subcellular fragments isolated from synapse regions of nerve cells(s~naptosomes)(Lin-Liu et al.. 1982), frog heart (Schwartz et a!.. 1990). toad heart (Wood et a!.. 1992). atnal stnps of frog heart (Schwartz and Mealing. 1993), and cultured cells (Dutra et al.. 1984. 1989. 1992, 1994) These various studies were conducted under a number of experimental conditions and produced a variety of results which permit the overall conclusion that, when observable, the calcium efflux phenomenon is relatively small in magnitude and has proven difficult to replicate. The results from the Bawin and Blackman groups led to their conclusion that calcium efflux effects occurred only within narrow ranges of modulatIon frequency ("frequency wmdows") and power denSity ("power windows") Blackman conducted an extensive senes of calcIUm efflux studies usmg 1m" frequency magnetic fields \vithout any RFR. The low frequency studies showed a harmOniC senes of frequency wmdows and multiple power \\mdows and indicated that there was an interaction between the applied magnetic fields and static magnetic fields such as the earth's magnetic field. The vaiidIty ofthe calcium efflux effect has remained in contention. Some observers hold that small. variable effects such as those reported in the various calcium efflux experiments are not truly effects of exposure to RFR but mstead are over-mterpretations ofnois~' data or perhaps the result of procedural errors The calcium efflux effect is relatively important for discussions ofRFR biological effects because. if valid, it is an effect which does not involve temperature elevation; that IS, it is a non-thennal effect. Calcium ions are required for several cell functions and also serve as one of the principal agents for regulation ofcell biochemical activity. For this reason. an effect on calcIUm metabolism might be an indication of interference in cell functions. However. there has so far not bee:n a demonstration of any physiological change nor any hamlful effect of RF exposure caused by altered cellular calcium. There is no experimental evidence that the effect. if it does exist. is harmful to humans or intact animals. To better appreciate the quality of the data and reasons for controversy. specific findings from some ofthe literature on calcium efflux and RF exposure are reported in the following paragraphs Bawin et a!. (1975) also compared the effects of RF exposure on calcium efflux v-ii.th those from chick brams that were mtentionally poisoned with sodiumc~anide which stops metabolic activity, including Sutro EIR AppendIX B B-42 07/06/97 Appendix B. Biological Effects of RFR membrane transport processes. The results showed that for 16-Hz modulation, although theml~effluxes from the normal and poisoned brains were both significantly higher than their respective controls. the differences bet"..een poisoned and normal brains for each exposure condition were not statistlca.lly significant. The absence of any differences between nonnal and poisoned brains appeared to mdlcate that no calcium had moved across cell membranes. i.e. that the calc:ium efflux effect did not involvl;: transmembrane calcium transport. Bawin and Adey (1976) performed experiments to ascertain whether the previously observed calcium efflux from amplitude-modulated 147-MHz fields was due to the carrier frequency or to the amplitude modulation itself. They exposed chick-brain preparations to sinusoidal fields at frequencies of 1. 6. 16. or 32 Hz [in the extremely low frequency (ELF) and sub-ELF ranges] instead ofto I47-MHz fields amplitude-modulated at those frequencies. The exposures wen: for 20 minutes at peak electric fields of.5. 10.56. and 100 Vim. The results indicated that the effect with ELF and sub-ELF fields was opposIte to that with amplitude-modulated I47-MHz fields: decreases rather than increases of calcium efflux were obtained. with maximum effect \\-ith 6 and 16 Hz at 10 VIm. These data also indicated the existence ofa field-amplitude "window": calcmm-efflux decreased \\-ith exposure to 6 and 16 Hz field by a statistically SIgnificant amount at 10 and 56 Vim, but not at lower and higher levels (5 or 100 Vim). Other research. such as the study in chick bram with amplitude modulated 147 MHz fields by Albert et at., 1987, and the studies \\-ith pulse-modulated RFR and rat brains by Shelton and Merritt (1981) and Merritt et al. (1982) reported no effects on calcium. Several ofthe recent studies that reported positive findings suggest that magnetic fields, primarily at power line frequencies (as well as the earth's direct current [dc] field). contribute to the effect. Adey et al. (1982) presented the results of a studyof4~Ca-efflux from the cortex ofthe paralyzed but awake cat No experimental data obtained for the RFR-exposed and sham-exposed animals were given (other than mention oftheir use III a curve-fitting method) nor were they directly compared for statistically SIgnificant differences The absence of such data imply that the differences in calcium efflux between the RFR-exposed and sham-cxposed cats were in the mean-squared deVIatIOns from the ideal efflux curve and the cyclic variations about the idealized linear fits to the data. but not between the values themselves at corresponding times. nor their means over time. Blackman et al. (1982). noting that their calcium-efflux changes (increases) in chick brams were opposite in sign to those found by Bawlll and coworkers (reductions) at frequencies III the same range. hypothesized that magnetic fields. pnmarily those at powerline frequencies (as well as the earth's DC field). contributed significantly to the effect. However. the expenmental findings of Blackman et al. (1985b) with magnetic fields were obscure. Blackman et al. (1991) subsequently reported that calcium efflux can be reduced, enhanced, or nullified by appropriately varying the temperature ofthe chick-brain samples before and during exposure. The authors hypothesized the existence of a temperature-wmdow effect (one that occurs only within a narrow temperature range). However, It is noteworthy that little if any efforts were taken in previous investigations by Blackman and coworkers to measure or control sample temperatures although environmental temperatures were controled. An alternative, opposmg hypothesis is that altered calcium efflux is a temperature effect not related to RF exposure Sutro EIR . Appendix B B-43 07106197 Appendix B Biological Effects of RFR In view ofthe apparently contradictory findings about the RFR-induced calcium-efflux effect. the controversy over its existence is likely to be unresolved ill the foreseeable future. However. ifthe effect 15 indeed proved to exist, there is no experimental eVidence that any health effects are associated \\ith the calcium efflux effect. 4.5.6 Cellular Effects of Modulated RFR The possibility of modulation-dependent effects has been studied in a variety oftest systems. These studies are controversial because many ofthe results lead to a conclusion that biological effects can occur athermally and particularly as a result ofamplitude modulation at low frequency. Although the Sutro Tower DTV transmissions would not incorporate this mode ofmodulation, this topic is worthy of discussion as an illumination of current RFR research. Byus et al. (1984) found reduced enzyme activity inl~mphocytesexposed to a 450 MHz RFR modulated at 16, 40 and 60 Hz, but not at other modulation frequencies. A body of research with modulated RF fields concerns the gro\\-th-regulatinge~meODC (ormthine decarboxylase). Byus et al. (1988) examined three cell lines (liver tumor. ovary cells and skin cancer cells) for effects of modulated RFR on ODC. For 16-Hz modulation, ODC activity was increased in all three cell lines. ODC activity in liver cells was increased by modulation at 10, 16 and 20 Hz. but not at 5. 60 and 100 Hz, demonstrating a frequency "window" centered near 16 HzB~11S et al. (1988) investigated whether the ODC effect was related to enhanced DNA synthesis. but found no effects of 450 MHz fields (lmW/cm:. amplitude modulated) on DNAs~nthesisIn hepatoma cells. Cain et al. (1997) studied the effects of RFR modulated by the pulsed. digItal signal used for a type of cellular telephone commUDlcatlons known as TDMA. Results reponed in abstract form indIcated no effects m one cell line (the C6 rat bram cancer line), but a 50% reduction in ODC actiVity for a mouse fibroblast cell line only when exposed to the hIgher level of exposure and only at 3 and 4 hours after stimulation of ODe actiVIty. but not at 2 hours. However. thiS "hIgher" level ofexposure. 8.40 mW/cm:.was Identified With a low (nontherman SAR of 78 J.lW/g Exposures at 078 j.lW/g had no effect. It can be noted that the reported transient reduction in ODe actIvity would suggest an inhibition of gro\\th and is contrary to most reported effects of RFR on ODC Litovitz et al. (1993) used a mouse fibroblast cell line in experiments \vhich confirmed the occurrence of enhanced ODe activity, but in this case using 9 I 5 MHz RFR ,md modulatIOn frequencies near 60 Hz The most important outcome ofthe Lltovitz (1993) experiments was the observation that an effect on ODe activity required that the modulation frequency be undisturbed for a mmimum ofabout five to ten seconds. There was, for example, no effect on ODe activity when the frequency was shifted from 55 to 65 Hz more rapidly than once every five seconds. This result shov.ed that the charactenstic time for the interaction of the modulated field with the biological system was several seconds, much longer than the time needed for most biochemical activities. Later studies on the same cell line from the Litovitz laboratory showed that the most favorable condition for an increase in ODe activity was an 8 hour exposure to a 60-Hz amplitude modulated RFR.. with a weaker effect of 50 Hz square-wave modulation (i.e., 50-Hz pulses), and no effects for amplitude modulation by speech, 60-Hz FM modulation. nor for CW signals (Penafiel et aI., J997) The experiments which made comparisons of vanous types ofmodulation were conducted with 835 MHz RFR and for exposures that lasted from 2 to 24 hours and the pOSitive findings occurred with a relatively high degree ofstatistical reliability, for example. p(,() 0 l in many cases <;:.Iltr..... J:'TD \ .\ ................. ; ... 0 Appendix B. Biological Effects of RFR Overall, data from two laboratories are in general agreement that ODC activity levels are transiently affected by low-frequency modulated RFR in the absence of any noticeable heatmg. There is noI~videnceto suggest that the changes in ODC activity are linked to hannful effects on cells or potentially hannful effects in animals or human beings Other research also may be evidence for modulation-dependent effects. Czerska et al. (1992) observed that pulsed RFR enhanced a naturally-occurring cell transformation in white blood cells to greater extent than CW fields. An electrophysiological study ofheart cells showed that pulse-modulated RFR had effects \..-hich differed from the effects ofCW RFR (Seaman and DeHaan, 1993) Dutta et al. (1994) reported modulation-dependent effects on a cell enzyme and Samosy et al (1991) reported that pulsed fidds caused effects on cell surface charge and cell shape which were different from effects produced by CW fields of similar strength. Low frequency modulation was reportedly required for an effect ofnonthermal microwaves on the chemical binding ability oftwo brain neurotransmitters according to a recent research in the Russian scientific literature (Iurinskaia et aI., 1996). Not all studies have found modulation-<iependent effects. For example, Pakhomov et al. (l995) found no differences in effects on heart cell electrical actlvIty for a variety ofpulse modulated fields. 4.5.7 Behavioral, Neurochemical and Neuropharmacologic Effects of Pulsed and CW Microwaves on Rats Lai and colleagues studied rat brain responses to pulsed and CW RFR in experiments on rat behavior (typically. success in learning a maze) and rat brain neurochemistry (for review Lai, 1992). The overall outcome of research conducted over a period of over 10 years is that both pulsed (2 usec, 500 pps) and CW mIcrowaves (2450 MHz). at levels generally accepted to be nonthermal (I mW/crn2. SAR = 0.6 W/kg). affect specific learning behaviors and neurotransmitteracti\~ty.Effects were found for the neurotransmItter acetylcholine in certain brain regions but not others. The distinction between the effects of ew and pulsed RFR depended on which brain regions were examined. Neurochemistry research indicated that effects on particular bram opioids caused effects on those nerve cells \",hich respond to the transmitter substance acetylcholine Because of similar findings in studIes of stress in rats. Lai and his coauthors suggested that the first event to influence the nervous system was a stress-like response SImilar to the responses caused by crowding and loud nOise Among the findmgs from this senes ofexperiments was the report by Lal et al. (1984) that pulsed mICrowave exposures at a level causing a low level of whole-body heating (SAR = 0.6 Wlkg) appeared to affect eNS control of body temperature in rats gIVen pentobarbital, a drug that inhibits normal thermoregulatory response. Another finding v,-as that MW-exposed rats had body temperatures higher than those of sham-exposed rats. but because body temperature changes depended on whether the head or rump was more strongly irradiated, Lai et al. (1984) concluded there were both thermal and central nervous system effects A later study by Lai et al. (1989) demonstrated three effects on the central nervous system of rats exposed to pulsed microwaves: I) biochemical changes III choline uptake and its blockade by naltrexone (a blocker of central nervous system acetylcholme responses); 2) neurophysiological changes (changed numbers of muscarimc receptors): and 3) impaired rat behavior (learning on the radial arm maze) The tests were done at one SAR level (SAR = 0.6 Wlkg, 2450 MHz) for various exposure durations and repetitions Drugs which block central nervous system acetylcholine receptors also blocked the effect of pulsed microwaves on acetylcholine receptors (Lai et aI., 1991). Lai et al. (\ 994) provided more evidence for a microwave effect on acetylcholine receptors because the inhibitIOn in maze performance caused by micrO\vaves could be reversed by a drug (physostigmine) which activates acetylcholine receptors and thereby counteracts the mIcro\VaVe inhibition of responses to acetylcholine. RFR exposures in this study were to a pulsed mIcrowave signal (0.6 Wlkg) for 45 min prior to performance on the maze. Although subtle thermal effects cannot be ruled out in all aspects ofthIS research. the overall results indicate that pulsed and ew RFR affect rat behavior and neurochemIstry in the absence of bIOlogically important changes in temperature There is no evidence that the effects observed in SUlrO EIR Appendix B B-45 07106/97 Appendix B Biological Effects of RFR these laboratory studies are pathological It should be noted that the experiments done by Lai et al. han: not been replicated by other researchers. 4.6 IMMUNOLOGY AND HET-v1..A.TOLOGY: IN~7TROSTUDIES Many reports indicate that RFR has specific effects on the unmw1e systems of mammals. Most reported effects were detected after exposure at power densities ofabout 10 mW/cm: and Iughec a few effects have been found from exposure to levels as low as about 0.5 mW/cm:. In most ofthe studies, the mecharusms for the effects were not investigated. and many ofthe results were not consistent with one another Early studies were done to detennine whether RF exposure can transfonn cultures of lymphocytes (onc type of leukocyte or white blood cell) into Iymphoblasts (cells in active mitosis or division). In such studies. samples oflymphoc)tes taken from the body were cultun:d. exposed to RFR (or exposed and then cultured), and examined for possible effects induced by the RFR. Usually, such cells were cultured \\lth and without a mitogen, a chemical agent that can stimulate transfonnation of cells into lymphoblasts. In later studies. more subtle effects on various types ofleukoc)tes were sought. as were possible effects of RF exposure on red blood cells (erythrocytes). 4.6.1 Leukocyte Studies Much early work investigating possible effects of RFR on cultures of white blood cells exposed in Vitro suffered from inadequate control of cell temperature during exposure. In later studies in which effective temperature control was exercised. no significant differences were found In various endpoints between RFR-exposed cultures and control cultures that were held at thc same temperature. In studies where thc culture temperature was elevated by RFR. the effects observed wcre clearly ofthennal origin. Among the endpoints were the percentages of cell viability. lymphoblast transfonnation: synthesis of DNA. RNA. and total protein Also assayed were production of alpha-Interferon induced in cells infected with mfluenza ViruS. and mitogen-Induced production of gan1ma-Interferon Smialowicz (1976) exposed suspensions of mouse-spleen cells to 2A5-GHz RFR at 10 mW/cm:~(SAR about 19 W/kg) for 1,2. or 4 hours. Other suspensions held at :noc (without RF exposure) for the same durations served as controls FollO\\ing treatment. the specimens were cultured with and without each of four different mitogens No signifIcant differences were seen between RFR-exposed and control specimens treated for corresponding durations The percentage viability of the specimens. measured right after each treatment. also showed no significant differences betweenexpos~:dand control cultures. Hamrick and Fox (1977) exposed cultures ofrat lymphocytes W11th and WIthout a mitogen to 2.45-GHz RFR at 5.10, or 20 mW/cm: (07. IA. or 2.8 Wlkg) for 4.24. or 44 hours, and assayed them fiar lymphoblast transfonnation by the uptake of tntium-labeled thymIdine in the cells. The differences in thymidine uptake between the mItogen-stimulated cultures and non-stimulated cultures for each RFR level and duration were large as would be expected. but the differences between the RFR- and control cultures were nonsignificant Roberts et al. (1983) exposed human mononuclear leukoc\te cultures to 2A5-GHz RFR for 2 hours at 4 W/kg, \\ith no attempt to remove heating due to the RFR. Other cultures were sham exposed, and untreated cultures served as controls Mean viability of all three groups increased and decreased with time, Sutro EIR \ Appendix B B-46 07.106/97 Appendix B Biological Effects of RFR but the differences among the groups were not significant. Similar results were obtained at 0.5 W/kg and at intermediate SARs. There were also no significant differences among the groups in DNA.~~A.and total protein synthesis, or in the production of alpha-interferon induced by infecting gell cultures with influenza ViruS or in mitogen-induced production ofgamma-interferon. Roberts et al (1987) obtained similar negative findings with influenza-infected human mononuclearleukoc~tecultures exposed to pulsed or CW 2.45-GHz RFR at 4 W/kg. Lyle et al. (1983) investigated whether 450-MHz RFR at 1.5 mW/cm: (SAR not indicated) would affect the toxic activity ofa specific type ofmurine T-lymphocytes (effector cells) against a specific kind of lymphoma cells (target cells). The authors prepared radioactively tagged mixwres ofthe two cell types and performed 4-hour garnma-eounting assays while the mix'tUres were being exposed to the RFR. The results indicated that the toxic activity ofthe effector cells was reduced by 17-24%. However. similar percentages (l5-25~~)were observed in 4-hour assavs done in the absence ofthe RFR if the effector cells had been exposed to the RFR for 4 hours before mixing them with the target cells. This result led the aUl:hors to surmise that the changes in Cytotoxicity observed in the previous experiments were due to actions ofthe RFR on the effector cells. After exposing effector cells to the RFR for 4 hours. the authors also did the 4 hour assays ofmixtures (in the absence ofRFR) at 1,4.9, and 12.5 hours. They observed 20%. 13%. 12%. and no mhibition, indicating diminution ofthe effect of the RFR on the effector cells with the time interval after exposure. Sultan et al (1983a) investigated the effects ofcombinations of RFR with hyperthermia on the antigen antibody activityofB-lymphoc~tes.Mouse B-lymphocytes were exposed to 2.45-GHz RFR at levels III the range 5-100 mW/cm: (2.25-45 Wlkg) at temperatures within the range 37°C-42.5°( Antigen-·antibody activity was seen in more than 90% ofcells exposed to RFR and heat-treated at 37°C. but III less than 60% ofcells heat-treated at 41 0C. and in less than 5% of those heat-treated at 42.5 °C The authors concluded that the mechanisms ofsuch inhibition activity are thermal in ongin. with no apparent effects of 2.45-GHz RFR for exposed and control samples held at the same temperal:ure Similar results were obtainedb~ Sultan ct al (I983b) \\ith 147-MHz amplitude-modulated RFR In the range 0 1-48 mW/cm: (0004-20 Wlkg) In summary, much ofthe early work seeking possible effects of exposing suspensions ofvarious classes of Ieukoc~testo RFR suffered from the lack ofadequate control of cell temperature during exposure. In subsequent studies in which effective control over suspension temperature dunng RF exposure was exercised, the differences in results between exposed and control cultures treated for the same durations and held at the same temperature were not significant. In studies where elevation ofculture temperature by RFR or conventional means did affectleukoc~tesadversely. the effects were clearly ofthermal origm. 46.2 Erythrocyte Studies Sought in various studies of RFR interactions with samples of red blood cells (RBCs) taken from anmlals or humans v,'ere hemolysis (loss of hemoglobin) and alterations III cell membrane function, palticularly effects on movement of sodium Ions (Na' ) and potassIUm Ions (K' ) across the cell membrane. Peterson et al (1979) heated suspensions of rabbit RBCs by conventional means or with 2.45-GHz RFR at 10-140 mW/cm" (46-644 Wlkg) while continuously mOnitoring the suspensIOn temperatures, and assayed the suspensions for loss ofhemoglobin (Hb) and K' after either treatment. For RBCs warmed to only 3.7°C above room temperature with 10 mW/cm: (46 Wlkg) or by conventional heating for 45 minutes. no Sutro EIR , Appendix B B-47 01/06/97 Appendix B BiologicalEff~ctsof RFR additional Hb or K+ was released. By contrast. when RBCs were rapidly warmed from room temperature to 37°C by either technique. the heatederythroc~teslost significantly more ofboth Hb and K+ than RBCs held at room temperature. The other results showed that both Hb and K+ were lost in equal amounts In all experiments in which RFR-heated and conventionally heated RBCs were warmed at the same rate to the same final temperature, indicatmg that the effect was thermal. The authors noted that their results were in agreement with those of Liu et al. (1979), who reported no significant differences in loss ofHb or K+ from rabbit RBCs heated to 37°C by 2.45-GHz, 3-GHz, or 39:' GHz RFR or by conventional techniques, and with similar results ofHamrick and Zinkl (1975) with 245 GHz,3 GHz. and conventional heating. However, they indicated that theIr findings differed from those of Baranski et al. (1971, 1974) and Ismailov (1971), who reported increased hemolysis and efflux ofK- from rabbit RBCs exposed to I-GHz or 3-GHz RFR at power densities as low as I mW/cm" Peterson et al. (1979) also exposed samples ofhuman RBCs to :noc with 2.45-GHz RFR at 90 mWIcm: (412 W/kg) for 8 minutes and maintaining them there for 37 minutes by exposure at 30 mW/cm 2 (137 W/kg). Unlike the results for the rabbit RBCs, no significant differences among the groups were seen in either hemolysis or K- release. Absence ofthose effects in hum,m RBCs may indicate that RFR-induced changes in rabbit blood may not be reflected in similar effects with human blood. Brov,n and Marshall ( 1986) sought nonthermal effects of RFR on grO\\<tb and differentiation of the murine erythroleukemic (MEL) cell line. Notmg that MEL cells form Hb and exhibit other forms oferythroid differentiation in response to the inducer hexamethylene bisacetamide (HMBA). they exposed HMBA cultured MEL cells for 48 hours to 1.18-GHz RFR at an SAR of 18.5 W/kg, 36.3 W!kg. or 692 W!kg. Dunng exposure. the incubatIOn temperature was held at 37.4O( Control cultures were held a1t the same temperature in a water bath. No significant differences were found among the cultures exposed at each RFR level and their corresponding control cultures m rate ofcell growth, cell differentiation, or the amounts of hemoglobin produced Also, the mean values for each endpoint did not vary significantly with RFR level. Subtle effects on the membranes of RBCs were sought by OIcerst et al. (1980), Allis and Sinha (198 L 1982), Shnyrov et al. (1984), Liburdy and Penn (1984). Liburdy and Vanek (1985). and Kim et al. (1985), who used various treatments and detectIOn methods In most such studies. RFR effects at the temperatures where phase transitions In the membranes are believed to occur were investigated, with mixed results. (Phase transitIOns are changes ofstate involvmg energy mput or output that does not mcrease or decrease temperature. such as at the freezmg and boiling points of water) However. any relationship between such effects and possible health consequences has not been established In summary, in early studies of RF exposure ofe~throc)t~s.hemolysis and potassium-ion (K+') efflux were reported for rabbite~throc~tesexposed at average power denSities as low as 1 mW/cm" However, in later investigations, Hb and K- losses from rabbite~throc)tesresulting from heating with RFR to 37°C did not differ significantly from the losses obtamed \vith conventional heating The threshold SAR for effect was found to exceed 46 W!kg. 4.7 IMMUNOLOGY AND HEMATOLOGY: IN VIVO STUDIES Studies of immunological effects of RFR in live animals can be divided into those in which changes in specific immunological parameters were sought--the subject of this section--and those in which effects of SUlro EIR \ Appendix B B-48 07106/97 Appendix B Biological Effects of RFR RFR on the health ofthe subjects and their resistance to disease,~'ereexamined. discussed in the ne\.1 section, 4.7, I Effects of Exposures on Immunological Parameters Studies seeking changes in immunological parameters from exposing animals to RFR~ieldedmixed results Some researchers, such as Huang et aL (1977), Huang and Mold (1980). Wiktor-Jedrzejczak et aL (1977). and Sulek et aL (1980) found that RF exposure ofmammals increased the proliferation ofleukoc~tes(white blood cells), or subclasses ofleukocytes (such as T-I~mphocytesorB-I~mphoc~tes).or production of antibodies (relative to controls) 10 response to antigens injected into the animals. but with few exceptions the measured or estimated SARs were well in excess of I WIkg. However. other researchers. such as Lin et al. (1979). Smialowicz et al. (1981, 1982a. 1982b). Ortner et al. (1981). and Wong et aL (1985) obtained negative results. In most such studies. cells cultured v.ithout or \\ith mitogens (chemical agents that stimulate mitosis) were assayed. Smialo\\icz et al. (1983) [(Jund that exposure ofmice to 245-GHz RFR at 30 mW/cm 2 (21 Wlkg) transiently decreased the activity of natural killer (NK) cells in the spleen against mouse-lymphoma cells. but the effect was not seen at 15 mW/cm: or 5 mW/cm: (10.5 Wlkg or~5 Wlkg). Collectively, the positive findmgs were probably thermailly induced. rather than due to any nonthermal interactions of RFR. 4.7.2 Effects of Chronic Exposure on Health, Longevity. and Resistance to Disease More directly relevant to possible RFR effects on the human immune system would be studies in \vhich animals are chronically exposed to RFR (preferably over \lrtually their entire lifetimes) to detennine whether such exposure adversely affects their health. longeVity. and resistance to natural disease: or expenmental challenge ".ith various microorganisms or toxins therefrom Some studies indicated that animals exposed to RFR for relatively short penods can v.lthstand bacterial infection bener thaT! sham exposed animals However. fe\\ studies involving chrome RF e)i:posure have been carned out or repeated b\ other laboratories. The Prausnitz and Susskind (1962) study (discussed in Section 43.3), in which 200 mice werei~XPOSedfor 4.5 minutes a day, 5 days a week, for 59 weeks to 9.3-GHz pulsed RFR at roughly 45 Wlkg appeared to show that such exposure was beneficial. but probably because the resulting 33°C daily rise in body temperature was protective against the presence of pneumoma in the mouse colony. Liddle et al. (1987) found that the survIVal rate of mice injected with Swph.vlocoCCllS and then exposed to 2.45-GHz RFR at 10 mW/cm: (6.8 Wlkg) for 5 days (4 hours a day) 10 ambient temperatures III the range 19-40°C was higher than in sham-exposed mice, supporting the benefiCial effects of RFR found by Prausnitz and Susskind (1962). Above 31°C, the survival rates ofthe RFR-cxposed mice dropped sharply. to 0% at 37°C. and similar results v.ere seen for the sham-exposed mICe above :;4°C (no survivors at 40°C). both findings ascribed to hyperthermia. Probably the most comprehensive chronic RF exposure mvestigation to date was a University of Washington study (also discussed in Section 433). in which 100 rats each were concurrently sham exposed and exposed to 2.45-GHz RFR at 0.4 to 0.15 mW/em: over the lifetimes ofthe exposed animals (except those ""ithdrav.n for interim tests and those that expired before completion of the exposure regimen). Immunologic tests of 10 each RFR-cxposed and sham-exposed rats withdrawn after 13 months showed counts of splemc T-l~mphoc~tesandB-I~mphoc~testhat were significantly higher for tlile RFR than the sham group. an effect ascribed to stimulatIOn of the Ivmphoid system by the RFR. However, this SUIrO EIR AppendiX B B-49 Appendix B Biological Effects of RFR effect was absent in similar tests on treatment completion: the absence was ascribed to unmunosenescenc:: Rat longevity was not affected by the RFR at corresponding Hmes dunng the exposure regimen. Toler et aL (1988) concurrently exposed 100 rats each to 435-MHz pulsed RFR for about 22 hours a day. 7 davs a week, for 6 months at I mW/cm: average power density (time-averaged SAR about OJ Wlkg) Blood samples drawn at various times were assayed for the stress hormones ACTH, corticosterone. prolactin in the plasma; for plasma catecholamines; and for hematologic parameters, including hematocnt and various blood cell counts. Heart rates and arterial blood pressure were also monitored. The results indicated no significant RFR-induced differences between groups m any ofthose endpomts. In comparison with the above negative findings with nonthermal exposures and beneficial effects of hyperthermic exposures, Liddle et aL (1994) found a Significant reduction ofabout 20% in lifetime among rruce exposed to 2.45 GHz CW RF at 10 mW/cm: (SAR = 6.8 Wlkg. a mildly hyperthermic dose rate). but a slIghtly longer lifespan for exposure to 3 mW/cm: (SAR = 2.0 Wlkg), although the lifespan enhancement \vas not at a statistically signficant level. In the work by Liddle et a1 (1994) groups of 25 female mice were exposed from age 35 days to the end of life for I hour per day, 5 days per week. Mean lifespan was reduced from 706 days to 572 days for the 10 mW/cm: group and increased to 738 days for the 3 mW/cm: group. The causes ofdeath were not determined so it is not possible to determine ifany particular diseases occurred differentially between exposed and control animals or ifthe differences in lifespan reflected a difference m aging ofthe animal as a whole. This study had two interesting outcomes: mildly hyperthermic whole body exposures might adversely affect lifespan and an exposure just one-third as great showed a trend toward enhanced lifespan. If accurate, these findings imply complex effects on the orgarusm m the absence of severe stress or significant changes in body temperature. The observation of slightly increased lifespan in mice exposed at 3 mW/cm: is noteworthy when considering two other studies (Chou et al . 1992: Spaulding et aL. 1971) where small. statistically nonsignificant increases in lIfespan also were observed among the exposed rats and mice. But. note for companson the study by Szudzinski e:t al (1982) (sectIOn 4 5) which showed reductions in the lifespan of mice tn.:ated with a chemical which causes skin cancer lTI con1unction with RFR at a frequency and specifiC absorptIOn rates Similar to those used by Liddle et al (1994). In view of recent attentIOn to the possibihtv of damage to DNA by RFR (Lal and Sll1gh. 1996: 1996) it is possible to speculate that lifespan effects might occur during nonthermal exposures as a result ofsubtle DNA damage such as that associated with neurodegenerative diseases The contrasts among the various lifespan studies discussed above mvolve not only different exposure mtensities. but pulsed versus CW waveforms. frequency. and different animal species. These differences prevent dra\\ing a general conclusion about effects on lifespan. but there appears to be a tend,:ncy towards enhanced lifespan for mildly thermal exposures but reduced li£espan when RF exposure is combined with chemical carcinogens There is little or no evidence for effects on lifespan or immune function at exposure levcls below the protective exposure guidelmes These effects arc relatively slight and it IS not knovm If there are any such effects ill humans exposed to sulllo\\t:r kvds of RFR 4.8 PHYSIOLOGY AND BIOCHEMISTRY The literature on physiological and biochemical effects associated with exposure to RFR is extensive. Many ofthe reported effects were associated with other events (c.g., changes in hormonal levels or stress adaptation), some are questionable for various reasons. and the medical significance of others is unclear. Sutro F1R \ Annenniv R R-'i() f\""1/nI:./O'"1 Appendix B. BiologIcal Effects of RFR 4.8.1 Metabolism and Thennoregulation Several studies were done in which effects of RFR were sought on the metabolic and thennoregulator: systems ofprimates. Bollinger (1971) exposed rhesus monkeys to 10.5-MHz or 19.3-MHz RFR (m the Sutro Tower Digital TV transmitters frequency band). each monkey at successively higher levels up to 600 mW/cm: (estimated SARs about 0.2 and 0.6 W/kg), or to 26.6-MHz RFR at up to 300 mW/cm: (about 06 W/kg). No thennal stress, heart-rate increases, or other influences on electrical events of the heart cycle due to the RFR were observed. Also, no significant differences were found between exposed and control monkeys in hematologic and blood-ehemistry analyses done before and after exposure. Differences in the mean counts of monoc)'tes and eosinophils were seen, but were ascribed to conditions unrelated to the RFR Exammations for gross pathology and histopathology indicated no RFR-induced abnormalities. Frazer et al. (1976) measured the skin and rectal temperatures of rhesus monkeys during exposure to 2(1 MHz RFR at 500, 750, or 1000 mW/cm: and found that the monkeys were in thennal equilibrium even at 1000 mW/cm:. Similar findings with 20-MHz RFR at 1270 mW/cm: were obtained by Krupp (1977) Krupp (1978) also conducted a foHow-up study on 18 ofthe previously exposed rhesus monkeys and found no RFR-related variations from nonnal values of hematologic and biochemical blood indices or in the physical conditions of the monkeys. Ho and Edwards (1979) used oxygen-eonsumption rate as an indicator ofstress in mice exposed to 245 GHz RFR in a wavegUide system that permitted continuous monitoring ofwhole-body SAR during exposure. Exposures were for 30 minutes, during which oxygen-eonsumption rates and SARs 'were determined at 5-minute intervals The results showed decreased mean SARs from 56 to 39 W/kg during exposure Clearly the mice sought to diminish their thennal burdens by altenng their body con:5guratlons during exposure so as to mimmlze their RFR-absorptlOn rates: their rates of oxygen consumptIOn also decreased. and returned to nonnal after exposure cessatIOn. Stern et al. (1979) trained fur-elipped rats in a cold chamber to press a lever that turned on an infrared lamp. Dunng exposure to 2A5-GHz RFR at increasmg levels m the range 5-20 mW/cm: (1-4 W/kg). the rats progressively decreased the rate at which they turned on the lamp. Adair and Adams (1980), in one of several studies of voluntar:-: and physiological thennoregulation. trained sqUIrrel monkeys to regulate the ambient temperature (T.) in an exposure chamber by adjusting the flow of air at various temperatures mto the chamber. and monitored theIr skin and rectal temperatures. During exposure to 245-GHz RFR at 7 mW/cm: (II W/kg) and higher. the monkeys altered the air flow to reduce the T., and their skin and rectal temperatures remamed stable. even at 22 mW/cm: (3.3 W/kg). Bruce Wolfe and Adair (1985) also showed that squirrel monkeys were able to vary the RFR level as a source of thennahzing energy and to select air streams at loDe and 50 0 e to regulate the T., and thereby maintam nonnal rectal temperature Adair et al. (1985) exposed trained squirrel monkeys for 15 weeks, 40 hours a week, at 1 mW/cm 2 or 5 mW/cm: (0.16 or 0.8 W/kg) and environmental temperatures of25°(, 30°C, or 35°C. At 1 mW/cm: and 25°C or 30 0 (, the monkeys made no change in preferred T?. However. at I mW/cm 2 and 3SC'C or at 5 mW/cm: and all three environmental temperatures. the monkeys selected cooler environments (T. s 10C to 3°e Im,ver). Before. during. and after treatment, physiologIcal changes were assessed periodically Foot sweating was higher at 35 0 (, but \\'as not enhanced by exposure to the RFR at either level. Colonic temperature was not affected, but skin temperature varied III an unpredictable manner. Some decreases in Sutro EIR AnoendlX B B-51 07/0tl")7 Appendix B Biological Effects of RFR body mass were seen at 5 mW/cm: No significant RFR-induced changes in blood indices or in other physiological characteristics were found Lotz (1985) exposed rhesus monkeys to 225-MHz RFR (near their whole-body resonance) at leve:ls in the range 1.2-15.0 mW/cm: (0.8-10.2 W!kg) and to 1.29-GHz RFR (v"'ell above resonance) at 20.28. and 3X mW/cm: (2.9, 4.0, and 5A W!kg). The criterion for RFR tolerance was defined as a rectal temperature not exceeding 41.5°C. The average rectal-temperature increases with 225-MHz RFR at 2.5 and 5.0 mW/cm: (1.7 and 3A W!kg) ",'ere 0.4°C and 1. 7°C, but the monkeys could not tolerate exposure for more than 90 minutes to 7.5 mW/cm: (5.1 W/kg) or higher. No changes were observed in Circulating cortisol levels for exposures at 5 mW/cm: or less. The mean rectal-temperature rises with 1.29-GHz RFR at 20. 28, and 38 mW/cm: (2.9, 4.0, and 5A W!kg) were OA, 0.7. and 1.3°C These results confirmed that RF exposure near resonance is most effective for producing hyperthermia In summary. it is evident that heating is the basis for the various effects of RFR on the autonomic thermoregulatory systems of mammals and on their behavioral thermoregulatory responses to RFR Especially note\vorthy are the results for primates because oftheir far greater physiological slmilantles to humans than the other animals studied. 4.8.2 Endocrinology Exposure of mammals to RFR has yielded rather inconsistent effects on the endocrine system. In general. effects are apparently related to either the heat load associated with RFR or the stress induced by RFR. and possibly to other circumstances. Lotz and Michaelson (1978) first "gentled" rats before RF exposure by weighing and handling each rat at least 4 times a week. and equilibrating it by taking its colonic temperature and putting it into an exposure cage for 3-5 hours for several days. Three-hour tests of theeff~~ctsof such equilibration showed a rapid nse ofcolonic temperature and the corticosterone (CS) level 10 the blood to a plateau during the first 30 mmutes. followed by a return to baseline values by the end ofthe 180 minutes. thus demonstrating the need for such equilibration pnor to exposure. The authors then exposed unanesthetized gentled rats to 2A5-GHz RFR for 30, 60. or 120 minutes at levels up to 60 mW/cm: (96 W!kg). and measured their colonic temperatures and CS levels after exposure. Thirty minutes after exposure at 13 mW/cm: (2.1 W!kg), the mean colonic temperature showed a small but SIgnificant nsc. and at the higher RFR levels. it increased in rough proportion to the level The mean CS level rose slightly for up to 120 mmutes after exposure at 13 mW/cm e ? up to 60 minutes at 20 mW/cm:. and 30 mmutes at 30 mW/cm e All other rises in CS level were significant and highly correlated with the colonic temperature nses. The estimated thresholds for adrenal axis stimulation were 30-50 mW/cm: (4.8-80 Wlkg) for 60-minute exposures and 15-20 (2.4·-3.2 W!kg) mW/em: for 120-mmute exposures. The latter range IS somewhat less than half the resting metabolic rate ofthe rat. Cairnie et al. (1980) showed that exposure of unanesthetized mice for 16 hours to 2.45-GHz RFR at 50 mW/em: (60 W!kg) produced significantly higher rectal temperatures. but the testis temperatures of the exposed mice did not differ Significantly from those for the sh;un-exposed mice. indicating that the thermoregulatory system of the testes was able to compensate for the increased thermal burde:n from RFR at close to lethal levels. The authors also exposed conscious rnIce for various durations to 2.45-GHz RFR at levels in the range 21-37 mW/em e . after \"'hICh they examined testicular cells for damage and counted total and abnonnal sperm. The corresponding ranges ofwhole-body and testicular SARs were 25 ]-44.5 Appendix B Biological Effi:.:cts of RFR Wlkg and 8.4-14.8 Wlkg, respectively. There were no significant differences between RFR-exposed and sham-exposed mice in mean percentages ofdamaged testicular cells. sperm counts, or percentages of abnormal sperm. Lotz and Podgorski (1982) implanted a catheter in the jugular veins of rhesus monkeys for monitoring levels ofcortisol, thyroxine (T 4 ), and growth hormone (GH) They collected blood samples from each monkey hourly for 24 hours and measured colonic temperature with an indwelling probe. At the same clock time during the 24-hour period. each monkey was exposed for 8 hours to 1.29-GHz RFR at 20. 28. or 38 mW/cm c (2. L 3.0. or 4.1 Wlkg). The authors noted that the resting metabolic rate (RMR) of a rhesus monkey is 2.4 Wlkg. For sessions at 20 mW/cm c and 28 mW/cm c , the mean plasma-eortisollevels did not differ significantly from those for sham exposure, but they rose significantly above control level during sessions at 38 mW/cm 2 . The levels then diminished to control values, indicating that the effect was transient. The authors suggested that a threshold existed between 28 and 38mWIcm c (3.0 and 4.1 W!kg), that the rises were associated with rectal-temperature elevations ofabout I. 7°C. and that the results support the hypothesis that adrenocortical effects of RFR are thermally induced. For all RFR levels. no significant differences in mean GH or T4 levels were seen at corresponding times during RFR and sham sessions Lebovitz and Johnson (1983) exposed unanesthetized male rats for 9 days (6 hours a day) to 13-GHz RFR at a whole-body SAR of6.3 Wlkg, which produced a mean core-temperature rise of 15°C. Following treatment completion, groups of rats were weighed and euthanized at intervals corresponding to 05. 1.2. and 4 cycles ofspermatogenesis. Spermatids resistant to homogenization were counted in the light testis. and daily sperm production was calculated. The left testis was processed for examinatIOn by hght mIcroscopy There was no signIficant difference In the weight ofseminal vesicles between RFR-exposed and sham-exposed rats. indicating that the RF exposure \vas not deleterious to testosterone productIOn. a findmg supported by histological evaluatIOns by light microscopy. LebOVItz and Johnson (1987) also investigated the same endpomts In unrestrained rats exposed once for 8 hours to 1.3-GHz CW RFR at 9 Wlkg. selected to yield a core-temperature nse of 45°C. said to be lethal for chronic exposure. In addition. they assayed trunk blood for follicle-stimulating hormone and leutinizing hormone. No significant differences were found in the endpoints. except for a declme In epididymal sperm count 26 days (2 cycles of spermatogenesis) after the RF exposure. However. they remarked that. in view of the negative results in the many other endpoints examined. that single positive result is hIghly questionable. They also indicated that a differential sensitivity of germ cells at thIS stage of maturation had been reported for conventional heating ofthe testes. Lu et al. (1985). noting inconsistencies in the findings of various investigators. described their studies with male Long-Evans rats from two different suppliers. Among theIr findings was that exposure of rats from both supplIers to 2.45-GHz RFR for 2 hours at 25,30. or 40 roW/cm c yielded higher levels of the hormone T 4 in blood serum than for sham exposure. but were not significantly affected at 20 mW/cm c or lower. However. because they had found that the normalT~concentratIons for the rats were higher than for the rats from one supplier, those and other results were reevaluated by separately comparing T 4 1e:vels for the RFR-exposed rats from each supplier with sham-exposed rats from that supplier. When that companson was made, they found no significant RFR-induced changes InT~concentration They remarked: "From the viewpoint of environmental health. changes in serum thyroxlm: cannot be used as an indicator ofa past history of microwave exposure due to its lImIted magnitude of response and its sensitivity to extraneous factors." SUlrO EIR \ Appendix B 8-53 07/06/97 Appendix B. Biological EffecLS of RFR Accinni et al. (1988) investigated possible effects of RF exposure on the rabbit kidney Tn vivo.The~ exposed the renal areas of white rabbits to 27.l2-MHz RFR with a standard diathermy apparatus The electric and magnetic field intensities. measured with portable E-field and H-field probes within the empt' exposure cage, were 800-1100 Vim and 1.5-3 AIm. The exposures were done on 5 consecutive days a week for 3 weeks. Rectal temperatures increased during exposure to final temperatures that never exceeded 41°C. On treatment end, the kidneys were removed from 7 RFR-exposed and 2 sham-exposed rabbits to search for early changes. The kidneys ofthe remaining rabbits were excised 5 months after treatment to search for any long-term effects. In the kidneys removed at treatment end, mild to moderate changes in the Juxtamedullary zone were observed by light and electron microscopy. Those changes were characterized by small areas oftubular degeneration and atrophy, and by focal and segmental glomerular degeneration and sclerosis By electron microscopy. various lesions and early regenerative features were detected in the tubules. No tubular lesions were found in the kidneys ofthe rabbits examined 5 months later. a finding ascribed by the authors to the active regenerative processes detected in the earlier phase. The authors remarked that the effects of RFR heatmg in their study, which yielded temperatures that never exoeeded 41°C. were not likely to have had a determinant role in causing the observed renal lesions Most ofthe studies of possible effects ofRFR on endocrine systems were conducted on rodents. Studies that reported positive findings also yielded indications that the effects were largely due to increases In the thermal burdens ofthe animals. In many studies. observed alterations in endocrine function may have been significantly influenced by stresses in the animals For this reason. the results of studies that reduced stress by acclimatmg animals to handling and the experimental situation are notable. Although some effects of RF exposure on the endocrine svstem appear to be straightforward and predIctable from physiological considerations. other. marc subtle effects may be worthy ofadditional study (eg. those related to the interactIOns among the pituitary. adrenal.th~Toid_and hypothalamus glands. and/or theIr secretions) Part ofthe problem m mterpretmg such results appears to be related to the uncertamties about stress mechanIsms and vanous accommodatIOns to such mechanisms Animals placed in novel situatIOns are much more prone to exhibit stress responses than those adapted to experimental situations. In summary, because the effects ofRFR on the endocnne systems ofanimals are largely ascribable to increased thermal burdens. to stresses engendered by the expenmental situation, or to both, there is no clear evidence that such effects would occur In humans exposed to RFR at levels which do not produce significant increases in body temperature 4 8.3 Cardiovascular Effects Few mvestlgations have been carried out on possible effects of RFR on the human heart. However. various studies have been performed on hearts (or parts thereof) excised from animals. and others have been conducted on the hearts of live animals. 4.8.3.1 In Vitro Studies Frey and Seifert (1968) exposed excised beating frog hearts to 10-J.ls pulses of 1425-GHz RFR at 60 mW/em e peak. Because the RFR pulses were triggered at the peak of the P wave of the electrocardiogram C.d....... t:'fn"'~__~_.rL?. 0 Appendix B. Biological Effects of RFR (EKG), and at 100 and 200 milliseconds (ms) after the peak. the time-averaged power density was very small. The results for the zero and 100-ms delays were Inconclusive, but a sIgnificant increase In heart rate (tachycardia) was seen for the 200-ms delay. The tachycardia was a possible artifact of exposure from metal electrodes. Clapman and Cain (1975) and Liu et a!. (1976) endeavored to reproduce the results above, but could not do so. Moreover, Liu et a!' (1976) opened the thorax of frogs and exposed the heart ofeach frog in situ to lOO-J.1s pulses of 1.42-GHz or lO-GHz RFR Again. negative results were obtamed. Lords et al. (1973) exposed turtle hearts submerged in Ringer's solution to 960-MHz CW RFR.. usually for 30 minutes. in a capacitor system at applied powers in the range 0-500 mW Bradycardia was seen from about 50 to 200 mW, and tachycardia at higher powers. The authors estimated that about 3.3% ofthe power was absorbed by the heart and that the temperature increase in the heart at 100 mW was about 0.2°e. They also found that conventionally heating the Ringer's solution (,,,,ithout RFR) produced tachycardia, so they hypothesized that the bradycardia seen in the lower power range resulted from RFR induced neurotransmitter release by remnants ofthes~mpatheticandparas~mpatheticnervous systems m the heart preparation. Tinney et a!' (1976) confirmed the hypothesis ofLords et a!' (1973). They showed that the RF exposure did not produce bradycardia if propranolol hydrochloride (which blocksthl~ sympathetic nervous system) or atropine (which blocks theparas~mpatheticnervous system) is added to Ringer's solution. Reed et a!. (1977) also observed bradycardia in isolated rat hearts exposed to the same frequency for 10 minutes at SARs in the range 1.5-2.5 W/kg, but not ifthey used the same blocking agents. Galvin et al. (1981 b) isolated cardiac muscle cells from the quail heart and exposed them in suspension for 90 minutes to 2.45--GHz CW RFR ""ithin a special water-filled-waveguide system at 37°e. The exposures were at mean SARs of L 10, 50, or 100 W/kg. After exposure. suspension samples were examined for the mtegnty ofthe cardiac cells. using thet~1Jan-blueexclUSIon test (An intact cell will exclude this VItal stain) The remainder of each suspenSion was centrifuged. the iluids were assayed for the release of cr1Z)mes creatine phosphokinase (CPK) and lactic acid dehydrogenase (LDH). and the residual pellets were resuspended. Pellets from some expenments were processed for exammation by electron mICroscopy. T~1Jan-blueexclusion was not affected by exposure at 1Wlkg, but the suspensions exposed at 10.50. and 100 W/kg exhibited successIvely larger 10creases 10 percentages of cells permeable to the stain relative to their respective control suspensions. CPK release was not affected at any SAR. However. LDH release increased monotonically v.ith SAR. but the increases relative to controls were nonsignificant e.l(cept at 100 W/kg. By electron microscopy. the ultrastructure ofheart cells exposed at 1, 10. and 50 W/kg, as well as control cells, appeared normal. However. cells exposed at 100 W/kg showed increased cytoplasmic vacuolizatIon and chromatin clumping, but the intercellular Junctions remained intact. Evidently the positive results ofthis studY were thermally induced. . . Galvin et a!' (1982a) also isolated atna ofspontaneously beatmg rat hearts. suspended the atria in tubes continuously perfused with solution. and exposed the specunens mdividually for 30 minutes to 2.45-GHz CW RFR at 2 or 10 W/kg in the water-filled waveguide system at 37°e or 22°e. Contractile force and beat rate were recorded periodically before. during, and after exposure At 37°e and 10 WIkg, the beat rate of each specimen expressed as a percentage of its own rate at the start ofexposure was not significantly different from 100%. At noc also, there were no significant differences in average beat rates benveen corresponding control atria. Average contractile force at 37°e was 640 mg for control atria and those exposed at 2 and 10 W/kg At 22°e. it was 1.200 mg These findings for Isolated heart atria support the conclusion of Galvin and McRee (198Ia), discussed below, that exposure of intact animals to ew RFR at the stated RFR levels has no influence on the myocardium or its neural components. Appendix B Biological Effects of RFR Yee et aL 1984 demonstrated that faster decreases in beat rate of RFR-exposed isolated frog hearts than those in the absence of RFR occurred only in hearts whose beat rates were recorded v.ith a glass electrode filled with a potassium-ehloride solution or with a metal-wire electrode: such effects were absent ",ith an ultrasound probe, a tensIOn transducer, or a glass electrode filled with physiologic (Ringer's) solution In summary, the authors of an early study reported the induction of tachycardia in isolated beating frog hearts by RFR pulses in synchrony \\'ith the EKG, but other researchers could not confirm this finding In either isolated hearts or in live animals. In some studies, RFR was reported to produce tachycardia (heart rate increase) III excised frog or turtle hearts, whereas bradycardia(heart-rate decrease) was reported in others. Such positive findings were shown to be suspect. because of the use of attached or indwelling electrodes that probably introduced artifacts. Various kinds ofelectrodes were investigated. and special types were developed that were not perturbed by RFR or did not perturb the local RF fields. Studies m which such nonperturbing electrodes were used shov.. ed that heart rates were altered only at RFR levels that produced rises in temperature or otherwise added thermal burdens to the animal. In other studies, effects ofRF exposure were sought on the release ofthe enzymes creatine phosphokinase (CPK) and lactic acid dehydrogenase (LDH), and on the integrity ofthe cells from cardiac muscles isolated from the quail heart using the trypan blue exclusion test. Stain exclusion was not affected by exposure at 1 W/kg, but muscles exposed at 10, 50, and 100 W/kg showed successively larger increases in pt:rcentages ofcells permeable to the stam The release ofCPK was not affected at any SAR. Hov..·ever. the release of LDH increased with SAR, but the increases were not signIficant relative to controls except at 100 W/kg. In yet another study. RF exposure had no effect on beat rates or contractile forces ofheart atria isolated from rats. Thus, little or no reliable experimental evidence exists that excised hearts or tissues therefrom are affected by exposure to RFR other than by thermal effects 4.8.3.2 In VIVO Studies Presman and Levitina (1963a. 1963b) were two t:arly studies In\~'hichlive rabbits were exposed for 20 mmutes to 2.4-GHz CW RFR at 7-12 mW/cm: or to 3-GHz pulsed RFR at 3-5 mW/cm" average power density, 4.3-7.1 W/cm c pulse power density. During each exposure and for 10 minutes before and afterward. the EKGs of the rabbIts were recorded with plate electrodes. Neither tachycardia nor bradycardia was observed during exposure ofthe entire dorsal surface. but tachycardia was seen during the first 5 minutes after exposure. followed by bradycardia. However, dorsal exposure ofthe head only or of the back only produced SIgnificant tachycardia during exposure. with head exposure yielding the greater effect. Bradycardia was also seen during exposure in three ventral aspects No original data were presented. only relative differences of means The presence of metal electrodes during exposure undoubtedly introduced artifacts of suffiCIent size to render the results meaningless Kaplan et al. (1971) and Birenbaum et al. (1975) tried to replicate the studies of Presman and Levitina (1962a) but were unable to do so. Kaplan et al (1971) found no significant difference between the heart rates of rabbits during or after exposure and the rates during no exposure. Birenbaum et al. (1975) found that changes in heart rate and respiration rate v,,'ere the same for RFR and infrared radiation (IR). but subcutaneous temperature increased more rapidly and rose to higher values for the IR exposures. Phillips et al. (1975) exposed rats to 2.45-GHz RFR for 30 mmutes at 0,45. 6.5, or 11.5 W/kg. Nonsignificant bradycardia was seen at 4.5 W/kg: mild but SIgnificant bradycardia developed within 20 Sutro EIR Appendix B B-56 07106/97 Appendix B Biological Effects of RFR minutes at 6.5 W /kg, followed by recovery in 2 hours: pronounced bradycardia occurred abruptly at II 1 W/kg. after which the heart rates rose to values well above those of controls and persisted at the higher levels to the end ofthe test period. Incomplete heart block was evident. with recovery \',ithm 60 mmutes after exposure end Chou et a1. (1980) exposed rabbits dorsally or ventrally 20 minutes per day for 10 days to CW or pulsed 2.45-GHz RFR at 5 mW/cm: (average). Highest SARs for dorsal exposure were 086 W/kg in the bram and 0.09 W/kg in the heart: for ventral exposure, they were 0.24 and 0.30 W/kg. The rabbits were aiso exposed dorsally to RFR pulsess~nchronizedto heart rate WIth a delay time of O. 0.1. or 0.2 se'conds relative to the R wave ofthe EKG (measured with carbon-loaded Teflon electrodes) No significant differences were seen between heart rates during the periods of ,exposure and nonexposure. Rabbits were also exposed to CW RFR at 80 mW/cm:. Galvin and McRee (1981) surgically produced myocardial ischemia (MI) [inadequate blood supply to the heart] in cats and sham exposed or exposed the hearts to 2.45-GHz CW RFR at 30 W/kg with an applicator. Cats without MI were similarly treated. Before and during the exposure of each cat. mean artenal blood pressure, cardiac output. heart rate. and EKG were measured. and blood samples were assayed for concentration ofplasma protein and CPK activity. After exposure, the hearts were excised and assayed for creatine phosphokinase (CPK) activity. The results for both the MI and non-MI cats indicated no SIgnificant differences in mean arterial blood pressure. cardiac output. or heart rate between RFR exposed and sham-exposed groups, and no synergy of Ischemia and RF exposure The eXCised hearts of the RFR and sham groups showed no significant differences In plasma or tissue CPK actiVIty Thus. localized exposure ofeither the undamaged or ischemic heart to the RFR in VIVO had no effect on the myocardium or its neural components--results at variance with those for eXCIsed hearts exposed to RFR Galvin and McRee (1986) cannulated a femoral artery in anesthetized rats to permit continuous recordmg of mean arterial blood pressure and removal ofblood samples. After the rats recovered. the me:an arterial blood pressure and vanous cardIOvascular. biochemIcal. and hematologiC indices ofeach rat were recorded dunng exposure to 2.45-GHz CW RFR. No SignifIcant differences were found between RFR-exposed and sham-exposed rats In initial heart rates or In any ofthe blood parameters assayed. but during the first hour of exposure, the mean heart rate of the RFR group decreased about 10%. a significant drop. and remamed there (with smaller variations) dunng the rest ofthe penod The authors surmised that the bradycardia was due to reduction of metabolic rate to compensate for the heat from the RFR. In summary. various studies in which cardiovascular effects were sought from exposure of animals to RFR In VIVO yielded negative findings except at RFR levels that clearly were hyperthermal, as evidenced by much increased respiratory rates and other manifestatIOns of heat stress. Also. in a study of cats surgically gIven myocardial ischemIa (MI). no significant differences were seen for both MI and non-MI cats between RFR-exposed and sham-exposed groups in mean artenal blood pressure. cardiac output, or heart rate. Also. nos~nergyof ischemIa and RF exposure was found. an mdlcation that humans with hean problems are most unlikely to be affected by exposure to RFR at or belo\'; the ANSIJIEEE (1992) or FCC (1996) maximum allowable levels. Sulro EIR Appendix B B-57 07/06 1 97 Appendix B. Biological EffecIs of RFR 4.9 RFR EFFECTS ON NATURA.LISTIC BEHAVIOR. REFLEX ACTIVln'.LEAR.~ING. ANDPERFORMANCEOFT~EDTASKS Numerous studies have been conducted on possible effects of RF exposure on various kinds of animal behavior. Representative papers on this tOpIC have been selected for dIscussion in thIS section Possibk mteractive effects of exposure to RFR and drugs on behavIOr and physiologic responses of anImals are discussed in Section 4.10. 4.9. I Rodents Justesen and King (1970) trained food-deprived rats to lick a specially designed nozzle a prescribed number oftimes (usually 40. termed an FR-40 schedule) to receive a drop ofdex.-trose-water solution. TIle rats were then exposed to 2.45-GHz RFR at temperatures ranging from 22°C to 26°C within a modified commercial microwave oven. Each session consIsted of alternating 5-minute intervals of RFR and no RFR at equivalent power densities up to 15mW/cm~(mean SAR about 45 W/kg) for 60 minutes total. The FR schedules were made more complex by the use of a 525-Hz tone as alternating reinforcement and extinction components presented at random intervals during a session At 4.6 Wlkg. the mean number of reinforcement responses decreased to about a third ofthe number in the absence of RFR. decreases primarily ascribed to cessation of responding, especially near session end, probably associated 'with warmmg of the rats. At 0.8 or 16 Wlkg and with more complex FR-20 schedules. none ofthe rats responded much above baseline levels. Rectal temperatures taken after exposure at 425 W/kg showed nses of more than 2°e Histological examination ofthe RFR-exposed rats and other untreated rats showed no significant differences indicative ofadverse effects ofthe RFR Hunt et al. (\975) sham-exposed and exposed rats to 2.45-GHz RFR for 30 minutes at 6.3 Wlkg within a modified microwave oven. after which their exploratory movements were recorded Both groups showed decreasmg activity The RFR group's actIvity dimmished faster than for the sham group. but the actlVlties of both groups became comparable toward sesSIOn end. Rats were also trained to swim a 6-meter channel forth and back repeatedly during a 24-hour penod. and each rat was scored for its median swim speed for each successive block of20 traverses after exposure for 30 minutes at 6.3 or II Wlkg. Right after exposure at 6.3 W/kg, the mean speed ofthe RFR group was comparable to that ofthe sham group for the first 200 traverses. it then decreased for the next 100 traverses. but then became comparable to the sham group again. The colonic temperatures ofthe II-Wlkg group immediately after exposure indicated severe hyperthermia (41°C or hIgher) despite partial relief by water immersion. and its performance after exposure was clearly Impaired by the hyperthermIa. However. testing after a I-day delay showed recovery. The performance ofthe 63-W/kg group was similar to that of the sham group for about 200 traverses, but was below mean control speed for about the next 100 traverses, after which both groups performed comparably once more. Colome temperatures measured Immediately after treatment showed that those exposed at 11 W/kg were rendered severely hyperthermIc (4 I°C or higher). with partial relief by water immersion for those tested right after exposure At II W/kg. the performance of the group tested right after exposure was clearly impaired by the hyperthermia. desplle the partial rehef from water immersion HO\vever, when the I I-W/kg group was tested I day later It showed recovery from the hyperthermia and yielded results similar to those of the 6 3-W/kg group The authors also trained water-depnved rats to press a lever in a complex task to obtain small quantities of sacchann-flavored water. after which groups were exposed for 30 minutes at O. 6.5. or 11 W!kg on Sutro EIR \ Apnendix B 8-58 (J7f(lh/97 Appendix B. Biological Effects of RFR successive days and tested immediately each day for 30 minutes. The results were given in tem1S of the percentages oferrors ofomission or commission versus elapsed tune at 5. 15, and 25 minutes oftestmg Follov.wg sham exposures, the mean errors ofonussion v,ere 10-15%; after 6.5 W!kg, they were 36% at 5 minutes oftesting, but dropped to the sham-exposure range at 15 and 25 minutes After 11 W/kg. however, the percentages were all much higher than sham-exposure values No significantdiffi~renceswere found in mean errors ofcommission among the treatments. Monahan and Ho (1976) demonstrated that mice tend to lean against the waveguide wall instead of stay in the middle ofthe waveguide. Thus with this behavior they minimIze their absorption of 2.45-GHz CW RFR in a waveguide held at 24°C because the electric field diminishes to zero at the wall. The absorptIOn decreases were determined from the decreases of SAR \\ith tune as calculated from measureme:nts of fOr\vard and reflected power in the waveguide. Lin et al. (1977), Schrot et. al. (1980), Gage and Guyer (1982). and Lebovitz (1981. 1983) studied the effects of RFR on rats trained to perform various behavioral tasks. The results of Lin et aL (1977) v,ith food-deprived rats exposed to 918-MHz RFR at 10, 20. or 40 mW/cm: (2.1. 4.2, or 8.4 W!kg)! shov,'ed Significant changes in performance rate only for 8.4 W!kg. at which those rats exhibited heat stress. mcluding panting, fatigue, and foaming ofthe mouth. Schrot et. al. (1980) found that rats trained in a more complex task involving responses to auditory stimuli and sequences oflever presses responded \\ith higher error-responding rates. lower sequence-eompletion rates. and changes in the nomnal acquisition pattern when exposed to pulsed 2.8-GHz RFR at an average power density of 10 mW/cm: (1.7 W!kg) than at 5 mW/cm: (0.85 W!kg): below 5 mW/cm:. the rats but were basically unaffected Gage and Guyer (1982) trained rats to do a complex task to receive food pellets. after which they exposed the rats to 2.45 GHz RFR for i5.5 hours at 8 or 14 mW/cm: (1.6 or 28 W!kg) at ambient temperature at 22°e. 26°C. or 30°C without access to food or water At treatment end. the rats were given water for i 0 minutes and then tested. At each temperature. their response rates decreased With Increasing RFR level. Lebovitz (i981) concurrently sham-exposed and exposed groups of food-depnved rats in individual waveguides to 13-GHz pulsed RFR Each waveguide contaIned a bar and means for illumimtmg the bar as a Visual cue and for delivering a food pellet. Pnor to exposure. food-depnved rats were tramed to press their bars in a complex schedule of illumination to receive food pellets. One group each was exposed at 1.5.36. or 67 W!kg The response rates at various intervals ofthe group exposed at i.5 W!kg for 8 weeks were stable and not Significantly different from those ofits sham group at corresponding intervals. This was also true for the group exposed for 9 weeks at 3.6 W!kg. also showed no significant differences in SD response rates The group exposed for 6 weeks of at 6.7 W/kg also showed no significant differences in overall response rates. but its response rates at specific intervals were significantly lower than for its sham group, differences ascnbcd to fewer in bar pressings neaJr the end of those behavioral sessions. The author noted that 6.7 W/kg IS t.he approximate restmg metabolic rate for a 240-g rat. so exposure at that level doubled ItS heat diSSipatIOn reqUirements. Thus. he concluded that themnal factors were probably involved in those differences Lebovitz (1983) obtained similar findmgs WIth 1.3-GHz CW RFR at 5.9 W/kg and 6.7 W/kg pulsed RFR (The small SAR difference was necessitated by equipment limitations.) The author noted the themnai basis for the behavioral changes and a threshold of about 3_5 W/kg Irrespective of whether the RFR was CW or pulsed. SUlro ErR Appendix B B-59 07/06/97 Appendix B. Biological Effects of RFR D'Andrea et al. (1986a) exposed one group of rats to 2.45-GHz CW RFR at 0.5 mW/cm: (0.14 Wlkg) for 7 hours a da\' on 90 consecutive davs. totaling 630 hours. Another group was sham exposed. No . . significant differences were found in daily measures ofbody masses or intake offood and water. Monthh tests of each rat for its threshold reactivity to electric footshocks of varied mtensity v"ithin a gridded-floor chamber showed no significant differences from those for sham-exposed rats After the 90 days of treatment, halfthe rats in each group were assessed for open-field behavior. shuttlebox perfonnance. and lever pressing for food pellets on an interresponse time schedule. Major changes were seen in dally tnals of the open-field tests, but no significant differences were ascribable to RF exposure. Shuttlebox performance was tested using a tone and a white light as a compound conditional stimulus (C5). and electric shock as an unconditional stimulus (UC5). Two days after shuttlebox testing. the rats were deprived offood and were trained to press a lever mice \-\ithin a progressively tighter specific time interval between the presses to obtain a food pellet. The shuttlebox responses were highly variable. but overalL the differences were not statistically significant. The results ofthis study and oftwo similar studies in the same laboratory (D'Andrea et al.. 1986b: DeWitt et al.. 1987) were not fully consistent but showed little if any statistIcally significant differences between RFR-exposed and sham-exposed rats However. the authors suggested that the threshold for behavioral responses to 245-GHz RFR in rats may be 10 the range 0.5-2.5 mW/cm: (0.14-070 Wlkg). Mitchell et al. (1988) exposed rats to 245-GHz CW RFR at 10 mW/cm: (2.7 Wlkg) for 7 hours in mdividual plastIC cages that penmtted free movement Right after treatment. each rat was tested for vertical and horizontal spontaneous locomotor activity. acoustic startle response. and retention ofa shock motivated passIve avoidance task. Lower actiVIty was seen in the RFR-exposed rats than the sham exposed rats. especially during the second half oftest sessions The mean of startle responses ofthe RFR exposed rats was significantly lower than for the sham-exposed rats Immediately after the staI1le-response test. each rat was placed in the lighted smaller part of a gated. two-ehamber shuttle box. the larger part of which \\as dark and eqUIpped to deliver an elcctnc shock If the rat moved Into the larger chan1ber \vithm 2 minutes. it was given a I-second shock: if it stayed in the smaller chamber for more than 2 minutes. it \\as removed and not testcd further A week later. retention ofthe shock experience \vas tested 10 the box The dIfferences in aVOidance actiVity between the RFR and sham groups were not significant. Akyel et al. (1991) trained rats on three behavioral schedules to press a lever for food pellets. after which each rat was exposed once a week for IO minutes to pulses of !25-GHz RFR at I-MW peak forward power. The average forward power was held constant. dunng any session. at 4, 12.36. or 108 W. obtained by changing the pulse repetition frequency. Each rat was given all four RFR levels in a weekly quaSI-random order. The correspond1Og whole-body doses or specific absorptions (SAs) and whole-body SARs respectIvely ranged from 05 to 140 kJlkg and 084 to 23.0 Wlkg. Testing of each rat was begun in less than 80 seconds after exposure end. At the threc lov,cr RFR levels. no slgmficant differences 10 any of the behaVIOr schedules were seen. At the highest level (140 kJ/kg. 23.0 W/kg), however. the rats trained on two of the schedules failed to reach baseline performance and those on the third schedule displayed variable effects. Those exposures caused an average rise of 25°C in colonic temperature The authors concluded that those behavioral changes were them1ally induced Walters et al. (1995) exposed rats to ultrawideband (UWB) RFR pulses of duration 7-8 nanoseconds at very high peak powers at a repetition rate of 60 pps for 2 minutes, and measured their rectal temperatures just before and after RFR- and sham exposure The band\-\idth was about 0.25-2.50 GHz and the peak electric field strength was 250 kV/m at 0.25 GHz. (far-field equivalent power density 1.7 GW/cm\ One c {:.{\ Appendix B. Biological Effects of RFR behavioral test was s\\IDuning perfonnance to exhaustion, gIven the rats one day before treatment and again three hours after treatment. In the test, each rat was requIred to swim in cylindrical container at a water depth of 45 em until the time in seconds when the rat was unable to break the water surface for I () seconds. For the test, a lead weIght was affixed to the tail of each rat corresponding to 3% of iltsbod~ weight. The rats were also given a functional observational battery (FOB) oftests consisting of 29 physiological and behavioral measures that yield continuous, rank order, count. descriptive, and quantal data. Blood was collected at 2 and 48 hours after treatment and assayed for four serum enzymes sho\\TI to be sensItive to narrow-band microwave-induced stress. Brain slices from RFR-exposed and sham-exposed rats were stained and examined by light microscopy for expression of c-fos protein (the product ofthe c-fos proto oncogene). A group of rats injected with hypertonic saline solution served as positive controls No significant differences were evident between RFR-exposed and sham-exposed rats in the sv.1mming tests or in any ofthe other tests. The authors remarked that c-fos protein expression would be expected to be the most sensitive test for RFR effect, because It is mduced in response to many stimuli including light. heat stress, electrical stimulation ofthe brain. and cerebral ischemia. Negative results were also obtained ill rhesus monkeys by Sherry et al. (1995) \'lith the same RFR source (next section) In summary, many of the studies on avoidance behavior mdicate that RFR could be a noxious or unpleasant stimulus. There is much evidence, however, that changes in such behavioral patterns induced by RFR are responses by the thermoregulatory systems ofthe anJIDals. either to minimize absorption of heat in normal or warm ambient environments (including high levels of humidity) or to obtain warmth in relatively cold environments. Behavioral effects involvmg pulsed microwaves can be due to the auditory response ofthe animal. The results of studies on dIsruption of performance or learned behavior by RFR were variable. However, most of the findings showed that the behavioral changes were ascribable to the added thermal burden imposed by the RFR 49.2 Nonhuman Prunates Galloway (1975) trained rhesus monkeys in a discriminative beha\;oral task to press one or more ofthree levers on panels when the panels were selectively lit. to receive a food pellet. After training, the head of each was exposed to 2.45-GHz RFR at estimated mean head SARs of7. 13.20.27. and 33 Wlkg. The RFR was administered for 2 minutes just before each behaVIOral session but terminated earlier ifthe monkey began to convulse. In addition, monkeys were exposed at 13 Wlkg for 5 daily I-hour schedules of 2 minutes on and 1 minute off, totaling 40 minutes of exposure per day. Convulsions occurred for all exposures at 33 Wlkg, and often at 20 Wlkg. No effects on dlscnminatlve behavior were evid'ent at the lower RFR levels v,'hich IS a relatively large change in effects. In a repeated-acquisition test. each monkey was required to press the correct lever for each of four illumination stimuli in the proper sequence, which was changed each day. In sessions just before RF exposure, a slight learning trend (diminishing error rate) was seen. but the changes were too small to ascribe significance thereto. This was also true for the results at all RFR levels except 33 W/kg, for which the error rate at session start was highest. Thus. except possibly for the latter result, the RFR had no effect on this behavioral paradigm. Surra EIR Appendix B B-61 n7/nf./Q7 Appendix B Biological Effects of RFR Cunitz et a1. (1975) trained a 3-kg and a 5-kg rhesus monkey on a complex serial reactIOn program. after which the head of each monkey was inserted through a hole in the bottom of a 383-MHz resonant cant:" \\1th the monkey facing a diamond array consisting of the ends of four light pipes mounted through the cavity's side \vall. To light any pipe. the monkey was required to move a lever to the left. right. up. or do~nto correspond~iththe position ofthat pipe end in the diamond. Each monkey was exposed to 383 MHz RFR at successively higher input powers up to 15 W (at estimated head SARs up to 33 W/kg and 2U W/kg respectively for the two monkeys). The larger monkey \....as also exposed at 17.5 W (23 W/kg) The lowest SARs for diminished performance by the two monkeys were about the same: 22 and 23 W/kg Scholl and Allen (1979) trained rhesus monkeys in a visual-tracking task that required each monkey to move a lever to hold a continuously moving spot within a prescribed clear area on the screen of a display mOnitor. The spot was moved electronically in a specific pattern. and lever responses generated continuous difference signals (errors) The central15~oofthe screen was clear and comprised the on-target area Th: monkey received a 0.I-second electric shock for each I second accumulated outside the clear area. After training, the monkeys were exposed to horizontally polanzed. 1.2-GHz CW RFR at 10 mW/cm: and 20 mW/cm: (measured at the center ofthe head in the absence ofthe monkey) for 2 hours a day at 2-da\ intervals until each was exposed for 120 minutes at each level. ThIS polarization and frequency were selected to provide half-wave resonant absorption in the monkey head The corresponding head SARs were 0.8 and 1.6 W/kg. Each daily session comprised 40 \'v'ork trials of 1.5 minutes each. alternating with similar rest periods. The endpomt scored \vas the adjusted root mean square (ARMS) ofthe tracking error for each trial. expressed as a percentage ofthe total target area. Of720 data points collected during a total of 36 hours of RF exposure, only 4 points were outside the 95% confidence limits. fewer than expected by chance. Clearly. the performances ofthe monkeys were not diminished by the exposure Whether the apparent performance improvement observed wasRFR~rclatedcould not be ascertamed De Lorge (1976) trained 3 rhesus monkeys to perform a task in which each was required to press a kver 10 front of its right arm. thereby producing either a lo\\-frequency tone to Signal that no food pellet IS availabk. or a higher-frequency tone for which the monkey had to press a kvcr In front of its left arm to receive a pellet. During I-hour sessions, pellets were made available at variable mtervals (VIs) around 30 seconds (VI-30-s schedule). During the 2-hour training seSSions., pellets were made available on a VI-60-s schedule. After traimng. the monkeys were exposed frontally to 2.45-GHz RFR at levels in the range 4-72 mW/cm: measured at head height. The estimated head SARs were 0.4-7.2 Wlkg. Sessions ofVl-30-s behavior v,,'cre conducted on each monkey lastmg 1 hour. dunng 30 minutes ofwhich it was being exposed at a head SAR of 0.4 or 1.6 W/kg. At either RFR level. the performances ofthe monkeys werre not affected by the RFR. which led to the use of the VI-60-s schedule dunng 2-hour test sessions. In the 2-hour sessions. the monkeys were exposed for I hour at levels in the range 16-7.2 Wlkg. One of them was also exposed at 1.6 W/kg during the entire 2-hour sessIOns No significant departures from control rates were exhibited by 2 monkeys at 6.2 Wlkg. and at 52 Wlkg for the third monkey. At 62 Wlkg, the performance ofthat monkey was about 80% of its mean control performance. De Lorge (1979) also trained four squirrel monkeys in I-hour sessions to press either the right or the left lever on top ofa chair to obtam a food pellet. Initially, cach successive lever press resulted in the alternate activation ofa red light and a blue light in front ofthe monkey When consistent performance was achieved. the contmgencies were changed so that press of the left lever was rewarded only when the blue light was on. with right-lever presses continuing to alternate the red and blue lights Each monkey was then exposed from above to 2.45-GHz RFR at levels in the range 10-75 mW/cm" SARs were estimated to have Appendix B Biological Efft;;cts of RFR been 0.5 to 3.75 W/kg. In 41 daily sessions, exposures were done during the middle 30 minutes of I-hour test sessions. with the other two 15-minute periods used to obtain baseline data. In the next 53 sessions. the session duration was 2 hours, and the RF exposures were during the middle 1 hour Neither the 30-mmute nor the 60-minute exposure regimens caused any obvious permanent phYSical changes in any of the monkeys. Among the various performance measures, only the rate of right-lever responses showed an RFR-induccd change. This measure showed a slight trend toward lower rates with increasmg RFR level, to a minimum ofabout 90% ofthe mean control value at 60mW/cm~(3.0 W/kg). and a slightly higher value (C)2%) at 70 mW/cm~(3.5 W/kg). The behaVIoral effects of I-hour exposures were similar to those of 30-mmute exposures but more pronounced. No consistent behavioral changes occurred below 50 mW/cm: (2.5 W/kg); above that level, the effects increased with RFR level. The author concluded that the behavioral changes seen in the squirrel monkeys were temporary and clearly related to hyperthermia. Consistent changes were seen when rises in rectal temperature exceeded 1°C, which corresponded to a threshold between 40 and 50 mW/cm: (2.0-2.5 W/kg). De Lorge (1984) similarly trained food-deprived rhesus monkeys to do a task in which eachm()nke~was to press a lever in front of its right hand (an observing response), which produced a low tone to signal that no food pellet will be delivered, or a high tone to signal availability ofa pellet. No tones were presented without a lever press, and nght-lever presses during the presence ofeither tone did nothmg. After stabk performance was attained, each monkey was frontally exposed during I-hour sessions to vertically polarized 225-MHz CW RFR (near whole-body resonance). or to pulsed RFR at 1.3 GHz or 5 8 GHz (both above whole-body resonance). The SAR ranges were 2.0-44 W/kg for 225 MHz. 2.6-124 W/kg for 13-GHz. and 0.34-4.7 W/kg at 5.8 GHz Reductions m obsenmg-response rates occurred at levels of \.3 GHz RFR above a threshold of 6.5 W/kg For example, one monkey exhibited decreases m observmg-response rates during exposure to 1.3-GHz RFR at 50 mW/cm: (6.5 W/kg) and higher. and the rate reduction became larger toward the laner part of each session as the RFR level was raised Also, the observmg-response patterns became increasingly erratic during sessions--an effect most pronounced at 225 MHz (near resonance), at which they paused for as much as 15 minutes and often stopped responding at all for the last halfofa session at 10mWfcm: (4 W/kg). As a more definitive index of behavioral change than the individual cumulative records, the author plotted the mean and standard error (SE) ofthe ratio ofthe observing-responses during each RFR session at each frequency to the values during the preceding sham session versus the power density. The results for each frequency yielded a threshold power denSity for significant behaVIOral alterations that rose with frequency 75 mW/cm: at 225 MHz. 63 mW/cm: at 1.3 GHz, and 140 m\V/cm: at 5.8 GHz. However, the correspondmg threshold whole-body SARs varied up and dOW11 with frequency: respectively 3 W/kg. 8.2 W/kg. and 4.3 W/kg, presumably because of the frequency-dependent differences in penetration depth and absorption properties. The detection-response rates on the food lever were not consistently affected by RF exposure at an) frequency. No effect was observed for 225 MHz or 5.8 GHz; for 13 GHz, a decreased detection-response ratc was observed occasionally only at 83 mW/em" or higher However, plots ofthe mean ratio of detection-response latencies during RF exposure to those during sham exposure versus power density showed values slightly but significantly higher than I at all three frequencies and at most power denSities. Sutro EIR \ Appendix B B-63 07/06197 Appendix B. Biological Effects of RFR At each frequency. the mean ratio changed both upward and downward V,lth power density. but with an overall downward trend. Postreinforcement pause (a pause after a reinforced detection-response) was also affected. The mean ratIo for exposure to 225-MHz RFR to that for sham exposure was 10 in the range 5-7.5 mW/cm:. but rose slgnificantly to 1.5 at 10 mW/cm:: With 1.3 GHz, the changes were both upward and dov,llward. but nonsignificant up to 63 mW/cm:. at which the mean ratio was l.3. Above 63 mW/cm::. it decreased to 1.1 at 93 mW/cm::; but the latter ratio was still significantly larger than 1.0 The only significant change for 5.8 GHz v,'as at 150 mW/cm::. to 1.06. a smaller increase than for the other frequencIes The mean colonic temperature at the start ofthe I-hour sessions rose an average of 0.15°C dunng the sham-exposure sessions. For 225 MHz. the rises were linear v.lith RFR level. from O.goC at 5 roW/em:: to 2.FC at 10 mW/cm::. For 1.3 GHz, they were smaller. and for 58 GHz. they were even more gradual The author's estimates ofthe absolute thresholds for the disruption ofobserving-response rates for each frequency were: 8.1 mW/cm:: for 225 MHz. 57 mW/cm:: for 1 3 GHz. 67 mW/cm: for 2.45 GHz (from de Lorge, 1976), and 140 mW/cm: for 5.8 GHz--values that increased \\'ith RFR frequency. Howe:ver. the corresponding SARs, 3.2 Wlkg, 7.4 Wlkg, 6.7 Wlkg. and 4.3 Wlkg, varied both upward and dO\\1lward \vith frequency, perhaps reflecting penetratlon-depth differences and absorption properties again D'Andrea et al. (1989) trained food-deprived rhesus monkeys to operate three levers (left, right, center) in vanous sequences to obtain food pellets. The sessions were 60 mmutes long The task during each session comprised three successive IO-mmute schedules of lever presses. followed by repetition ofthe same three schedules. In the first 10-minute schedule. the monkey was reqUired to Withhold responding for 8 seconds after the start ofa tone. and then to respond only withm the ne:\.i -+ seconds: the correct response during those 4 seconds was 2 presses of the left lever withm 2 seconds of each other. The authors called this ;:Ul mterresponse-tIme (IRT) schedule. The second 1O-mmute penod was devoted to a tIme-discrimination (TO) schedule. in which a press ofthe center lever in the presence of blue light randomly yielde:d white light ofshort or long duration. At the end ofeither duration. the white light was replaced with red aJild green light When the red and green light were present. the monkey. to obtain a p,:t. had to press the nght lever if the preceding whIte light was of short duration. or the left lever If the prec-:dmg white light was of long duratIon. During the third lO-mmute penod. a fixed-mterval (FI) schedule was used in which the monkey was presented with a continuous tone ofhIgher frequency. and its first press ofthe right lever after 55 seconds yielded a pellet During the 60-minute sessions. each monkey was sham exposed or exposed from above to pulses of 13 GHz RFR at a pulse power denSIty of 131.8 W/cm:: The peak SAR was 15.0 W/kg in the head and 8.3 W/kg in the whole body. The pulse repetition rates ranged from 2 pps to 32 pps, with corresponding average power denSIties of 092 mW/em: to 14.80 mW/em:: No SIgnIficant differences were seen between sham exposures and RF exposures 10 <Uly ofthe behaVIOral responses Sherry et a!. (1995). in a study similar to Walters et al (1995) with rats, used the Primate Equilibnum Platform (PEP) to investigate whether exposure to the RFR from anultra\\~deband(UWB) transmitter would alter the behavior of rhesus monkeys. The PEP proVIdes a continuous compensatory task: The animal is seated in a restraint chair that rotates on the pitch axis about the animal's center of gravity Sutro ErR '.-\pp~dixB B-64 07/06/97 Appendix B. Biological Effects of RFR Random perturbations in pitch are generated by a computer at unpredictable intervals. Large variations tn platform position occur with no monkey present wlth a standard deviation of 12 -15 0. While seated in the restraint chair. the monkey is required to manipulate a Joystick control to compensate for the variatIOns In pItch. Whenever the platform position deviates by more than 15° from the horizontaL the monkey is gnen a mild electric shock to the tail A well-trained monkey can reduce the variation to 2-4° and receive less than I shock per hour. Six unanesthetized adult male rhesus monkeys were trained to perform the PEP task. Although there were charactenstic baseline differences among them, the level achieved by each was e:\.tremely stable. For thIS study, the monkeys were tested for 1 hour per test at least four months before exposure to RFR and at least t\vice weekly dunng the experiments. The RF exposures were done within an anechoic chamber. \\ith each monkey in a restraining chair facing the boresight ofthe transmitter antenna. The RFR consisted of 2-5 nanosecond pulses at a repetition rate of 60 pps administered for 2 minutes (7200 pulses total) The bandwidth ofeach pulse was 100 MHz to 1.5 GHz, with the highest power in the band 250-500 MHz and a peak E-field strength of250 kV/m. Each monkey was exposed twice. with 6 days between exposures. and was tested for 1 hour after each exposure and at 24-hour intervals for the ne:\.'1 five days At the maximum field strength available and the highest repetition rate, no core-temperature increase was detected, so no SAR data could be collected. However. theoretical calculations using the pulse characteristics of the RFR yielded a whole-body SAR of 0.5 W!kg. The only significant effects were for individual differences among the subjects and changes of each during the 12 five-minute intervals of each hour oftest with no effects due to the RF exposures per se. The authors remarked that the changes with time during the 12 five-minute intervals were due to a tendency for performance to decline during the course oftest sessions. independent ofexposure. The authors also indicated that time constraints m the use ofthe equipment did not permit sham exposures to control for the passage of time. Last they mentioned the concerns about human exposure to ultrashort nsetime RFR raised by Albanese et al. (1994) after completion of this study. and the response to Albanese ct al. (1994) by Merritt et al. (1995) Memtt et al. (1995) mdIcated that the expenmental results of this study and the one by Walters et aL (1995) with rats (see Section 4.91) do not support any special human safety concerns about such RFR. In summary, RF exposure can alter the behavior of non-human primates. but primarily at levels high enough to produce behavioral thermoregulatory responses (voluntary or non-voluntary). but then: is little or no experimental evidence ofadverse effects at thermogenic levels that are within the compensatory capabilities ofthe thennoregulatory systems ofthe arumals. It is worthy ofemphasis that the behavioral findings ofthe primate studies are more relevant than those with the other animal species with regard to possible effects of RFR on human behavior. because the tasks the pnmates had to learn were far more complex, and because their physiologies and intelligences are much closer to those of humans. It is also noteworthy that reasonably accurate thresholds for RFR-induced behavioral changes were detennined for each primate species. and that those thresholds served as the pnmary basis for the ANSUIEEE (1992) human-exposure guidelines. 4.10 RFR AND DRUGS Thomas et al. (1979) trained food-deprived rats to press a bar for a food pellet. After stable basdine patterns were achieved, an effect-versus-dose function for the psychoactive drug chlordiazepoxide f.\lItrn FIR \Ann~ni\.·Q Appendix B. BiologIcal Effects of RFR (tradename Librium). given 30 minutes before a session. was established. This function showed that the respondmg rate rose with mcreased drug dose up to 10 mg/kg. attaming two-to-three tunes the baseline ratc at that dose. At still higher doses. the responding rate decreased with dose. attaming zero at 40 mg/kg The rats were then exposed to 2.45-GHz pulsed RFR at I-W/cm= peak. l-mW/cm: average (0.2 Wlkg) during the 30 minutes before each bar-pressing seSSiOn. which was started right after drug injection RF exposure yielded the same shape ofeffect-versus-dose functIOn. but the magnitudes were generally hIgher by a factor of about 2. However. RF exposure ill the absence of any drug injection produced no difference In responding rate. The results ofthis investigation are unequivocal. but the mechanisms are obscure. For example. although average power density and whole-body SAR were low. local SARs in brain regions that are the G:1.rget areas for central actions of chlordiazepoxide may have been sufficiently high for a thennally potentiating effect It is also conceivable that with the pulse parameters used. the pulses may have been perceived (RFR heanng effect) dunng the 30-minute pre-session period If so. however. it is not clear whether or how .any influence of this effect would have carried over Into sessions during which the RFR was absent. Thomas and Maitland (1979) also trained 6 food-deprived rats to depress a lever on a different behaVIOral schedule. After such training, 3 of the rats were dosed with the psychoactive drug d-amphetamine once a week and exposed for 30 minutes (single-exposure conditIOn) to the 2.45-GHz pulsed RFR (0.2 Wlkg). Their behavior was observed for I hour right after exposure for any direct drug-RFR interaction. For seeking cumulative action ofthe RFR, the other 3 rats were dosed Wlth d-amphetamine once a week and exposed for 4 days a week. 30 mmutes per day (multiple-exposure condition). except on drug-inJection days. On those days. their behavIOr was observed for 30 minutes after injectIon The sessions were conducted for 13 weeks. and mcluded sham exposures and sahm: mJections for all 6 rats For the smgle-exposure conditIOn. the mean response rates (in total responses per minute) after saline injection and sham exposure. and after saline injection and RF exposure. were comparable to baseline performances. However. when those 3 rats were gIVen d-amphetamine and sham-cxposed. their mean response rates Increased with drug dose to a maXImum at 2.0 mg/kg. with consequent reductions in the frequency of correct responses that yIelded remforcement. At higher drug doses. the mean response rates dropped sharply. to zero for 4.5 mglkg By contrast. theIr mean response rates after dosing with the drug and exposure to RFR increased to values significantlY hIgher than for the corresponding doses 'with sham exposure. with maximum at 0.5 mg/kg. Those results mdicate that RF exposure after injection ofa gIVen dose of d-amphetamine yielded behaVIOr similar to that WIth a larger dose and no RF exposure For the rats studIed under the multiple-exposure conditIOn. the dose-response functions with and WIthout mUltiple RF exposures were qualitatively SImilar to those with and \\;thout single RF exposures Thomas et al. (1980) described similar research with the drugs dIazepam and chlorpromazine. Diazepam (tradename Valium) has been WIdely prescribed as a tranquilizer and muscle relaxant. Chlorpromazine IS used as a sedative and as an antiemetic. Four food-depnved rats oftwo strains were trained on a schedule of remforcement. After training. dose-effect functions for diazepam were determined in one strain and for chlorpromazme in the other stram. For all 4 rats given Chlorpromazine. performance decreased with increasing dose. The response rates stayed within the baseline vanability for doses up to abollt I mg/kg and declined for higher doses. For those given diazepam, the drug caused slight increases in response rate at doses up to about 2.5 mglkg. WIth decline at higher doses. The authors then exposed each lrat for 30 minutes to 2.8-GHz pulsed RFR at 0.2 Wlkg nght after admmistering each drug. and tested the rats at Appendix B Biological Effects of RFR exposure end. The RFR did not alter the effects ofcWorpromazine or diazepam, as contrasted with cWordiazepoxide and d-amphetamine. The differences in findings are difficult to reconcile. Pappas et aL (1983) exposed rats to 2.7-GHz pulsed RFR for 45 minutes (SAR 0.75.2.23 and 3 Wlkgl. to determine whether the RFR would affect stereotypy (persistent senseless movements) produced by injection of pentylenetetrazol alone. During a I-hour sessIOn after exposure and starting 4 minutes after pentylenetetrazol injection, each rat was observed for the nonnal behaviors (immobility. rearing, forward walking) and for 3 abnormal behaviors (backward walking. circling, head swaying) for I minute every 5 minutes The difference in average score for each ofthe SIX behaVIOrs between RFR and sham groups was nonsignificant. Lai et aL (1984) described experiments to determine any effects in rats ofthe RFR used by Pappas et al (1983) on ethanol-induced hypothermia and ethanol consumptIOn For the first experiment, 15 rats were RFR-exposed and 14 rats were sham-exposed for 45 minutes in separate waveguides. Right after exposure ofeach rat. its colonic temperature was measured. it was injected with an ethanol solution (3 g/kg ofbody weight in 25% of water by volume). and its colonic temperature was measured again at 15-minute intervals for 120 nunutes. The mean colonic temperatures ofthe RFR-exposed and sham-exposed rats right after exposure (and before ethanol injection) were 38.2°C and 38.3°(, a nonsignificant difference, as would be expected at the low RFR level used (0.6 Wlkg). Within 5 minutes after ethanol injection. ataxia developed but the righting reflex was not affected. The mean temperature reductions versus time after ethanol Injection for the two groups showed that the alcohol-induced hypothermia had occurred in the RFR group at a slower rate than in the sham group. One could speculate that the RFR had affected the thermoregulatoy system so as to partly compensate for the hypothermic effects ofethanol in a time dependent manner related to the rate of ethanol metabohsm In the ethanol-eonsumption expenments. drinking water was removed from the home cages. and 24 hours later. the rats were given 90-mmute sessionsdail~for 9 days On session days 1. 2. and 3. the rats were Illserted III the waveguides for 45 minutes With the RFR source on "standby" At thiS time. a bottle contaming a 10% sucrose solution was Inserted III each wavegUIde and the amount consumed during the remaming 45 minutes was measured. The day-4 procedure was the same except that half the rats (24) were selected randomly and exposed to the RFR for the full 90 mmutes. and the other 24 rats were similarly sham exposed. On days 5-7. the procedure was the same as on days 1-3. except that a 15% ethanol + 10% sucrose solution was used to render the ethanol more palatable On day 8, 24 randomly-selected rats (group I) were exposed to RFR the other 24 rats (group II) were sham exposed for 90 minutes. and the amounts ofthe sucrosc-ethanol solution consumed dunng that period wcre measured. On day 9. the group roles \vere reversed: group I was sham exposed. group II was RFR exposed, and fluid consumption was noted. For days 1,2, and 3 (during which all 48 rats were sham-exposed and offered the sucrose solution), mean sucrose consumption rose significantly each successive da) On day 4. however, (when half were RFR exposed and the others sham exposed for 90 minutes). the mean sucrose consumptions for the 2 groups did not differ significantly from each other or from the day-3 value For days 5, 6, and 7 (when all 48 rats were sham-exposed and offered the sucrose-ethanol solution), the mean sucrose-ethanol consumption varied up and do\\n with time. For day 8 (when group I was exposed to RFR and group II was sham ex.posed). the sucrose-ethanol consumption by group II did not change significantly but that of group I significantly mcreased For day 9 (when group II was RFR exposed and "-'/()£.10-r Appendix B Biological Effects of RFR group I was sham exposed). consumption by group 11 significantly increased. Thus. although the RF exposure had no apparent effect on consumption ofsucrose alone. it apparently increased consumption of the sucrose-ethanol mixture. In summary, the investigations that soughts~nergIsmsbetween RFR and psychoactIve drugs such as diazepam. chlorpromazine, chlordiazepoxide, and dextroamphetamine, yielded unclear or inconsistent results. In some studies, the changes in drug dose-response relationship were subtle and not necessarily induced by the RFR. In most ofthe studies that yielded RFR-induced changes in drug response. whole body SARs of0.6 Wlkg or average pow'er densities of I mW/cm" or higher coupled \\ith relatIvely high drug dosages were necessary, In still other studies. the results were negative (no effects). At relatively 10\\ RFR levels. the role ofthermoregulation in the results is unclear and the occurrence of relatively high local SARs in the brain cannot be ruled out Noteworthy were the negative findings ofs)nergistic effects between alcohol consumption and exposure to RFR except at relatively high doses ofalcohol Specifically, the normalized ethanol doses given rats (3 glkg of body weight in 25% ofwater by volume), if consumed by humans. would render them extremely mebriated. An exception is the apparently RFR-related higher sucrose-ethanol consumption for reasons not yet understood, reported in the study by Lai et al. (1984) In general, it seems unlikely that the effects of psychoactive drugs prescribed by physicians or the effects of recreationally consumed alcohol would be altered by exposure to environmental levels of RFR. 4.11 CELLULAR AND SUBCELLULAR EFFECTS--STRUCTURES AND CONSTITUENTS OF MICROORGANISMS AND OTHER SINGLE-CELL SYSTEMS Various studies ofcellular and subcellular effects of RFR have been discussed above under other specific topics such as the BBB, immunology. and hematology. Described m this section are findings rdated to other possible RFR effects on cells and their constituents Many ofthe early studies on microorganisms produced results that were taken as evidence of nonthermal effects of RFR. The existence of resonances at frequencies above 30 GHz was postulated on theoretical grounds, and several studies by Webb and coworkers were conducted that appeared to confirm that hypothesis. However, later studies by Cooper and Amer (1983) and by Gandhi et aL (1988). in which more sophisticated engineering and biological techniques were used and artifacts were reduced significantly, yielded results that did not confirm earlier findmgs of resonances or other evidence of nonthermal effects at such frequencies. The apparent absorption resonances in the range of 2 to 9 GHz reported by Swicord and Davis (1983) for aqueous solutions of DNA mokcules denved from E coli wen: regarded as indicatIve ofdirect action of RFR with such molecules. Later attempts by Edwards et al (1985) and Gabriel et al. (1987) to reproduce such findings, however, yielded negative results Moreover. analytical and experimental results were obtained indicating that such resonances were most likely artifactual. associated with the probes and measurement methodology used In general. research on possible RFR effects on microorganisms or cells derived from macroorganisms is important for eliciting possible mechanisms ofdirect mteraction of RFR with such biological entities or their constituents at levels that can be characterized as nonthermal. However, the relevance of such findings (negative or positive) to possible effects of exposure of intact animals to RFR and ultimately the n..,/f\L:.IO"'1 Appendix B. Biological Effects of RFR sIgnificance ofsuch findings with regard to possible hazards ofRFR to humans has not been established Such research to date has not provided any scientific evidence that humans chronically exposed to low-k\d RFR would experience cellular effects. 5.0 UNRESOLVED ISSUES The potential biological effects of RFR at frequencies up to 300 GHz have been assessed from representative peer-reviewed studies published in the scientific literature. The preponderance ofevidence mdicates that chronic exposure ofthe general public to the RFR levels prevailing in the environment is not hazardous to human health. Nevertheless, there are several basic uncertainties, summarized below. regarding biological effects ofRFR. (1) Many ofthe epidemiologic studies seeking possible bioeffects of RFR were extensive and \vell done. but contained flaws or uncertainties in varying degrees, such as imprecise assignment of individuals to exposure and control groups; frequent difficulties in obtaining accurate medical records. deathcl~rtificates. or responses to health questionnaires for individuals included in both the exposure and controlgroups~and most important, the uncertainties about the RFR frequencies, levels, and exposure durations for those selected for inclusion in exposure groups and the amount ofexposure received by those selected for inclusion in control groups. (2) Applying results on laboratory animals to humans, though essentiaL is an expedient that contains fundamental problems and uncertainties due to the basic differences between humans and other species, particularly non-primates. Investigations ""ith nonhuman primates could narrow some ofthe interspecies gaps considerably, but often at prohibitive costs. thus limiting the number and extent ofsuch c)(perimental InvestigatlOns. Large rcductlons in such problems and uncertainties seem unlikely m the near future (3) The results of many expenmental investigations indicate existence ofthreshold levels of RFR for vanous blOeffects. These thresholds provide confidence that exposure to levels that are appreciably below them are most unlikely to be deleterious However. most expenmental data that mdicate the eXistence of thresholds were obtained by the use ofsingle or repetitive exposures of relatively short durations and/or time periods. Although it is difficult to conceive ofmecharusms whereby RF exposures at weB below threshold values over a long time could be cumulative. and the few theories that have been proposed have not been experimentally verified. relatively few investigatIOns have been done in which anImals were continuously exposed to such low levels during most of their lifetimes. The high costs ofsuch chronic exposure studies and the low probability that any positIve effects will be found are important reasons why such studies are not gIven high prionty by funding agenCIes. (4) Some ofthe basic mechanisms of interaction of RFR \\lth various biological entities are not yet fully understood A few effects at low RFR levels have been charactenzed by some investigators as nontherrnal, but other investigators have not been able to experimentally confirm the existence ofsuch effects. Whatever the nature of such reported effects, the gap between them and possibly hazardous effects on humans or animals from exposure to such low RFR levels is extremely wide. Factors such as large body masses and dimenSIOns relative to the RFR wavelengths. penetration depths and internal field distributions of the RFR and changes in orientation or configuration of the body during exposures to RFR can vastly moderate such interactIOns or remove them entirely Moreover. life processes per se are extremely complex. For these reasons, this gap IS not likely to be reduced to any great extent in the foreseeable future. n LCI Appendix B. Biological Effects of RFR 6.0 MISCONCEPTIONS Popular medIa often do not make the important distmction between RFR (nonionizing radiatiOn) and ionizmg radiation, so concern is frequently raised in the general public, with no scientific basis, that RFR can gIve rise to hazardous effects knO\\TI to be caused by IOrnzing radiation. In essence, any quantum of Ionizing radiation absorbed by a molecule yields up enough energy to expel an electron from the molecule (ionize it), leaving it positively charged and thus strongly enhancing the interactions ofthe molecule with its neighbors. Such interactions can alter the functions ofbiological molecules fundamentally andinreversibl~ m living organisms. Moreover, the damage caused by iornzmg radiatIOn can be cumulative. By contrast, the energy in a quantum of RFR is so much smaller than in a quantum of ionizing radiation that the primary effect ofRFR quanta is to agitate molecules rather than ionize them. The absorptIon of RFR quanta at very high rates (in large numbers per unit time) is necessary to producephysiologicall~ significant heat. Moreover, such RFR molecular agitation begins to diminish immediately on cessation of exposure. For the latter reason, exposure to low levels ofRFR (well below thresholds) is not cumulatIve. Within the class ofnonionizing radiations, there IS also a basic difference in interaction between RFR (3 kHz to 300 GHz) and electric and magnetic fields at extremely low frequencies (ELF), such as those used in the transmission ofelectric power from generating statIons to substations and thence to the ultimate consumers ofelectricity (usually 60 Hz in the U.S.). As noted in Section 2.3. the wavelength corresponding to 60 Hz is more than 3, 100 miles. By contrast. the wavelength corresponding to 734 MHz (the top frequency ofthe Sutro Tower Digital TV transmitters) is only 1.3 feet. Thus, people near a powerline are in its induction zone (meaning at distances of only a tiny fraction ofa wavelength), within which terms "propagation" or "radiation" do not apply Rather. the electric and magnetic fields from such a source may induce currents in the body. and the effects of each field need to be consideredseparatel~ It is also necessary to distinguish between an effect and a hazard. For example, a person's metabolism can be Increased harmlessly by mild exercise. Analogously. an effect produced at RFR Intensities that yIeld heat that can be easily accommodated withm the thennoregulaton capabilitIes ofa person may not necessarily be deletenous. Also. any effects produced thereby are generally reversible However. the thermoregulatory capabilities of any given species may be exceeded at high RFR intensities. so compensation for such effects may be inadequate Thus. exposure at such intensities can cause thermal distress or even irreversible thennal damage. Likewise. non-thermal exposures might produce an effect. but it would remain to be sho\\TI ifthere was a hazard associated with an\' such effect It is also important to note that it is not scientifically possible to guarantee absolutely that exposure to RFR at low levels that do not cause deleterious effects for relatively short exposures will not result in the appearance of deleterious effects many years III the future As noted above. however, the large body of experimental data mdicate the eXIstence ofthreshold levels for variOUS RFR bioeffects and that low-level exposures are not cumulative. 7.0 GENERAL CONCLUSIONS The IEEEfEMBS CommIttee on Man and Radiation report states: "Although a substantial body of data exists on the presence or absence of bIological effects of RFEM. the IEEE realizes that some controversy still remains, and it is generally acknowledged that the data ba<;e is incomplete. In summary, smce there is a contmuing increase in the beneficial uses of RFEM fields, there remains a need for continued Sutra EIR >. Anoendix B B-70 Appendix B Biological Effects of RFR research to ensure that human exposures at levels specified in present exposure standards are safe The position ofthe IEEE Committee on Man and Radiation is that there is no cause for concern regarding the environmental levels ofRFEM fields to which the general population are routinely exposed. Based on present knowledge, human exposure at or below the permissible levels recommended by the IEEE and other organizations is not harmful to human health. 7.1 EXPOSURE OF HUMAN BEINGS Assessments of risk to human beings must give weight to findings ofwell performed studies involving actual or presumed human exposure to RFR despite the limitations ofsuch studies. The import:mce of human experience is emphasIzed by problems and uncertainties created by the need to extrapolate both exposure and biological responses from various animal species to human beings. In the specific case ofRFR from the proposed Sutro Tower Digital TV broadcasting, there are no studies involving precisely this technology nor is there an extensive body ofevidence from studies ofexposures to the general population from broadcasting towers. This review considered several epidemiological studies with varying degrees of relevance. For the purposes ofthis report. relevance is assessed by the frequency of transmissions, modulation type, and power density ofexposures to members ofthe general public. Although accurate information on these parameters is often lacking, these criteria serve, for example. to distinguish exposures to military radar from exposure to radio and television broadcasting. and to distinguish occupational exposures, which may involve some high level overexposures, from exposures to the general public. The three epidemiological studies ofgreatest relevance are in recent studies by Hocking (1996) and Dolk et al (1997a: 1997b) which investIgated cancer incidence. but no other health effects, in the general public near broadcasting towers The Dolk et ai. (1997a: I997b) research on Bntish TV and FM broadcasting towers provided conflicting evidence for adult leukemia Incidence when one tower sIte was evaluated In comparison \\lth data from twenty other sites ThIs expenence mdicates that caution is needed for mterpretatlon ofthe Australian study (Hocking. 1996) whIch found excess leukemIa among residents ncar broadcasting towers in one locale There are other contradictIOns unlike the fmding in Australia of a stronger correlation \\ith childhood leukenua, neither Bntish study mdicated a statistically significant excess risk for childhood cancer. The conclusions dra\\TI from these few studies. whether positive or negative. are limited by the relatively small numbers of cases. These three studies indicate no consistent disease pattern among residents near broadcastmg tmvers and therefore support the conclusion that no such association is likely. However, these studies stimulate questions which, it can be anticipated, will be addressed in future research. Two more studies concern general population exposures ncar broadcastmg towers. The first study, which was not published in a scientific Journal, concerned Hawaii residents living near broadcast towers operating at unspecified frequencies (State of Hawaii Department of Health, 1986). The second study examined cancer among residents near a transmitter operating at a frequency of 23.4 KHz, a frequency lower than DTV broadcast frequencies (Maskarenic et aL 1994). The report of positive correlations with all cancer. but not leukemia, in one ofthese studies, and a correlation with leukemia in the other, illustrates an apparent inconsistency between these two studies. For this reason. and because one study involves a cancer cluster which ended more than a decade ago, and because of lmutations in exposure assessment. and in light ofadditional epidemiological concerns discussed in section 3. I. these studies are not valuable for assessing potential risks from Sutro Tower RFR. Sutro fIR, Appendix B B-71 07/06/97 Appendix B Biological Effects of RFR The several occupational studies reviewed in this report are limited in ways already described. Some reported evidence for a possible increase In cancer nsks for occupational exposures. particularly those involving exposures to military personnel. These exposures include many types of RFR including vanous forms of pulse-modulated fields used for radar. These latter exposures are different in modulation and power density from exposures to DTV signals to the public near the Sutro Tow·er. In most studies.exc~ss risks. where noted. were small in magnitude and required further investigation to assess the possible influence ofthose factors which can lead to erroneous results in epidemiological investigations. A study by Lester and Moore (1982) which sought to assess potential risk to the general population living near radar installations on Air Force bases was flawed and no useful conclusion could be dra\\TI. There has not been. so far as known. a follow-up investigation on this tOpiC Epidemiological studies ofthe general population and workers have not provided reliable evidence of harmful health effects from RFR exposures characterized by the frequency, modulatlOn pattern. and power density associated ....ith Sutro Tower DTV emissions. Neither the available epidemiologic research. nor studies \\ith human volunteers. provided scientifically reliable e\;dence that chronic exposure to RFR at levels within the ANSI/IEEE (1992) or FCC (1996) exposure guidelines have detrimental health effects 7.2 STUDIES WITH ANIMALS Taken collectively. most ofthe experimental investigations ofthe effects ofRF exposure in animals indicate that effects do occur. but at levels that were associated \\lth the heat produced by the RFR. and that exposure to relatively low RFR levels such as the allowable maxima specified in the ANSI/IEEE ( 1992) or FCC (1996) guidelmes. are not likely to produce any hcalth effects in humans. Animal studies have been done with continuous wave. pulse-modulated RFR. and. rarely. amplitude modulated RF. There IS no consensus that modulation IS an important factor in effects on animals. In some studies. the mIcrowave heanng effect may explam apparent differences m the outcomes of c:xpcriments With contmuous wave versus pulsed RFR. hut It rcmams a possibility that somc olltcomes differ \\'lth modulatIOn. 73 STUDIES WITH ANIMAL CELLS AND TISSUES Studies ofeffects in vitro support the influence oftemperature change but also indicate that some experimental tests appear sensitIve to modulatIon characteristICS In other research studies there was no difference between effects of continuous wave or modulated RFR ofthe same SAR Studies ofthe calcium efflux effect and related phenomena indicated a dependence on amplitude modulation frequency. powa denSIty and signal duration ("coherence time") In vitro studlcs are of unquestioned importance for an understanding ofthe mechanisms of interaction. However, in the absence of demonstrations ofhazardous exposure conditions related to modulation characteristics in man or animals. and in the absence ofa deleterious effect directly related to effects observed in VItro, It must be concluded that the research done in VItro has not demonstrated any likely heal::1 hazards for exposures to specific frequencies, waveforms or modulation patterns. Furthermore. 10 vitro research has not demonstrated any deleterious efff:cts with continuous wave and pulsed RFR in the absence oftemperature mcreases of several degrees. In vitro studies have not identified non-thermal mechanisms of interaction which appear to be related to potential hazards to anm13ls and human beings. Appendix BRefcrcn.::.::~ 8.0 REFERENCES Accinni. L., C. De Martino. and G. Mariutti (1988) EFFECTS OF RADIOFREQVENCY RA..DIATION ON RABBIT KIDNEY A MORPHOLOGICAL AND IMMUNOLOGICAL STUDY Exp. Mol. Pathol., Vol. 49. No 1, pp.22~37 ACGIH (1984) THRESHOLD LIMIT VALVES (TLV) FOR CHEMICAL SUBSTANCES AND PHYSICAL AGENTS IN THE WORK ENVIRONMENT WITH INTENDEDCH..A.l~GESFOR 1983-84 Ann. American Conference of Governmental Industrial Hygienists. Vol. 8. pp. 190-191 Adair, E.R. and B.W. Adams (1980) MICROWAYES MODIFY THERMOREGULATORY BEH..AVIOR IN SQUIRREL MONKEY Bioelectromagnetics, Vol. 1, No. 1. pp. 1-20 Adair. E.R.. D.E. Spiers. R.O. Rawson, BW. Adams. D.K. Shelton. P.J. Pivirotto. and G.M. Akel (1985) THERMOREGULATORY CONSEQUENCES OF LONG-TERM MICROWAVE EXPOSURE AT CONTROLLED AMBIENT TEMPERATURES Bioelectromagnetics, Vol. 6, No 4. pp. 339-363 Adair. R.K. (1991) CONSTRAINTS ON BIOLOGICAL EFFECTS OF WEAK EXTREMELY-LOW-FREQUENCY ELECTROMAGNETIC FIELDS Phys Rev. A. Vol 43. No.2. pp 1039-1048 Adey, W.R.. S.M. BawIn. and AT Lawrence (1982) EFFECTS OF WEAK AMPLITUDE-MODULATED MICROWAVE FIELDS ON CALCIUM EFFLUX FROM AWAKE CAT CEREBRAL CORTEX BlOclectromagnetlcs. Vol. 3. No.3. pp. 295-307 Adey, WR (1993) BIOLOGICAL EFFECTS OF ELECTROMAGNETIC FIELDS. J Cell Biochem 51(4):410-416 AkyeL Y .. E.1.. Hunt. C GambrilL and C Vargas. Jr. (1991) IMMEDIATE POST-EXPOSURE EFFECTS OF HIGH-PEAK-POWER MICROWAVE PULSES ON OPERANT BEHAVIOR OF WISTAR RATS BlOclectromagnetlcs. Vol 12. No 3. pp. 183-ICJ) Albanese. R., J Blaschak. R. Medina. and J Penn (1994) ULTRASHORT ELECTROMAGNETIC SIGNALS BIOPHYSICAL QUESTIONS. SAFElY ISSUES, AMD MEDICAL OPPORTUNITIES AVlat.. Space. and Environ Med.. pp A 116-A 120 Albert. E.N. (1977) LIGHT AND ELECTRON MICROSCOPIC OBSERVATIONS ON THE BLOOD-BRAIN BARRIER AFTER MICROWAVE IRRADIATION Sutro EIR \ references B-73 07/07/97 Appendix B· Rcfcn:ncc, In D.G. Hazard (ed.), SYMPOSIUM ON BIOLOGICAL EFFECTS AND MEASUREMENT OF RADIO FREQUENCY!MICROWAYES. C.S. Department of Health. Education. and Welfare. HEW Publlcallon (FDA) 77-8026. pp 294-304 Albert. E.N. (1979) REVERSIBILITY OF MICROWAYE-INDUCED BLOOD-BRAIN BARRIER PERMEABILITY Radio Sci, Vol. 14. No. 6S, pp. 323-327 Albert. E.N. and 1.M. Kerns (1981) REVERSIBLE MICROWAVE EFFECTS ON TIIE BLOOD-BRAIN BARRIER Brain Res .. Vol. 230, pp. 153-164 Albert. EN.. M.F. Sherif. N.J. Papadopoulos. F.J. Slaby. and 1. Monahan (1981) EFFECT OF NONIONIZING RADIATION ON THE PURKINJE CELLS OF TIIE RA.T CEREBELLUM Bioelectromagnetics, Vol. 2. No.3. pp. 247-257 Albert. E.N., FJ. Slaby, and J. Loftus (1987) EFFECT OF AMPLITUDE-MODULATED 147 MHz RADIOFREQUENCY RADIATION ON CALCIUM ION EFFLUX FROM AVlAN BRAIN TISSUE Radiat. Res., Vol. 109, No.!. pp. 19-27 Anderstam, B.. Y Hamnerius, S. Hussain, and L Ehrenberg (1983) STtJDIES OF POSSIBLE GENETIC EFFECTS IN BACTERIA OF HIGH FREQUENCY ELECTROMAGNETIC FIELDS Hereditas. Vol. 98, pp. 11-32 ANSI (1982) ANSI C95.1-1982: SAFETY LEVELS WITH RESPECT TO HUMAN EXPOSURE TO RADIO FREQljENCY ELECTROMAGNETIC FIELDS. 300 kHz TO 100 GHz Published by the Institute of Electncal and Electrolllcs Engmeers. NY ANSI/IEEE (\992) C95.\-199\: IEEE STANDARD FOR SAFEIT LEVELS WITH RESPECT TO HUMAN EXPOSURE TO RADIO FREQUENCY ELECTROMAGNETIC FIELDS. 3 kHz TO 300 GHz The Institute of Electrical and Electromcs Engmeers. 0.:ew York. j\)' \ 00 \ 7 Appleton. B. and G.c. McCrossan (1972) MICROWAYE LENS EFFECTS IN HUMANS Arch. Ophtha!.. Vol. 88, pp. 259-262 Appleton, B. (1973) RESULTS OF CLINICAL SURVEYS FOR MICROWAVE OCULAR EFFECTS US Dept of Health. Education. and Welfare. Washington, D C, HEW Publication (FDA) 73-803\ Appleton. B., S. Hirsch, R.O KInIOn. M Soles. G.c. McCrossan. and RN. Neidlinger (1975a) MICROWAYE LENS EFFECTS IN HUMANS II RESULTS OF FIVE-YEAR SURVEY Arch. Ophthalmol., Vol. 93, pp. 257-258 Sutro EIR references B-74 07103/')7 Appendix B· References Aurell. E. and B. Tengroth (1973) LENTICULAR AND RETINAL CHANGES SECONDARY TO MICROWAVE EXPOSURE Acta OphthaL, Vol. 51. No.6, pp 764-771 Balcer-Kubiczek, EX. and G.H. Harrison (1991) NEOPLASTIC TRANSFORMATION OF C3H!lOT-l/2 CELLS FOLLOWING EXPOSURE TO 120 Hz MODULATED 2.45-GHz MICROWAVES AND PHORBAL ESTER TUMOR PROMOTER Radiat. Res.. Vol 126, No.1, pp. 65-72 Baranski. S. and Z. Edelwejn (1968) STUDIES ON THE COMBINED EFFECT OF MICROWAYES AND SOME DRUGS ON BIOELECTRIC ACTIVITY OF THE RABBIT CENTRAL NERVOUS SYSTEM Acta Physio1ogica Po1onica. Vol. 19, No.1, pp 31-41 Baranski, S. and Z. Ede1wejn (1975) EXPERIMENTAL MORPHOLOGIC AND ELECTROENCEPHALOGRAPHIC STUDIES OF MICROWAYE EFFECTS ON THE NERVOUS SYSTEM In P.W. Tyler (ed.). Ann. N.Y. Acad. Sci., Vol. 247, pp. 109-116 Bawin. S.M., L.K. Kaczmarek, and W.R. Adey (1975) EFFECTS OF MODULATED VHF FIELDS ON THE CENTRAL NERVOUS SYSTEM In P.W. Tyler (ed.), Ann. NY. Acad. Sci., Vol. 247. pp. 74-81 Bawin. S.M. and W.R. Adey (1976) SENSITIVITY OF CALCIUM BINDING IN CEREBRAL TISSUE TO WEAK ENVIRONMENTAL ELECTRIC FIELDS OSCILLATING AT LOW FREQUENCIES Proc Nat. Acad. Sci.. Vol. 73. No.6. pp. 1999-2003 Berman. E.. J.B. Kino. and H.B Carter (1978) OBSERVATIONS OF r..·10USE FETUSES AFTER IRRADIATION WITH 2.45 GHz MICROWAVES Health Phys, Vol. 35. pp. 791-80 I Berman. E., H.B. Carter, and D House (1980) TESTS OF MUTAGENESIS AND REPRODUCTION IN MALE RATS EXPOSED TO 2450-MHz (CW) MICROWAVES Bioelectromagnetics. Vol. I. No 2. pp 65-76 Berman. E.. H.B. Carter, and D House (1981) OBSERVATIONS OF RAT FETUSES AFTER IRRADIATION WITH 2450-MHz (CW) MICROWAVES l Microwave Power. Vol. 16. No. L pp. 9-13 Berman. E.. H.B. Carter. and D. House (1982a) REDUCED WEIGHT IN MICE OFFSPRING AFTER IN UTERO EXPOSURE TO 2450-MHz (CW) MICROWAVES Bioelectromagnetics. Vol 3, No.2. pp. 285-291 Berman, E.. H.B. Carter. and D House (1982b) OBSERVATIONS OF SYRIAN HAMSTER FETUSES AFTER EXPOSURE TO 2450-MHz SUlro EIR. references B-75 07/03 1 97 Appenclix B References MICROWAVES J. Microwave Power, Vol. 17, No.2, pp. 107-112 Bennan. E. and H.B. Carter (1984) DECREASED BODY WEIGHT IN FETAL RATS AFTER IRRADIATION WITH 2450-MHz (CW) MICROWAVES Health Phys., Vol. 46, No.3, pp. 537-542 Bennan. E.. H.B. Carter.. and D. House (1984) GROWTH AND DEVELOPMENT OF MICE OFFSPRING AFTER IRRADIATION IN UTERO WITH 2.450-MHz MICROWAVES Teratology. Vol. 30. pp.393-402 Birenbaum. L.. IT. Kaplan, W. Metlay, S.W. Rosenthal, and M.M. Zaret (1975) MICROWAVE AND INFRA-RED EFFECTS ON HEART RATE. RESPIRATION RATE AND SUBCUTANEOUS TEMPERATURE OF THE RABBIT J. Microwave PO\\,er, Vol. 10. No I. pp. 3-18 Blackman. e.F., M.e. Surles. and S.G. Benane (1976) THE EFFECT OF MICROWAVE EXPOSURE ON BACTERIA: MUTATION INDUCTION In CC Johnson and M.L. Shore (eds.), BIOLOGICAL EFFECTS OF ELECTROMAGNETIC WAVES. U.S Dept of Health. EducatIOn. and Welfare, WashIngton. DC.. HEW Publication (FDA) 77-8010, Vol. I. pp. 406-413 Blackman. CF.. J.A: Elder, CM. WeiL S.G. Benane. DC Eichinger, and D.E. House (1979) I~DUCTIONOF CALCIUM-ION EFFLUX FROM BRAIN TISSUE BY RADIO-FREQUENCY RADIATION' EFFECTS OF MODULATION FREQUENCY AND FIELD STRENGTH RadiO SCI, Vol. 14. No 6S. pp 93-98 Blackman. CT. S.G. Benane. L.S. Kinney. WT. Joines. and D.E House (1982) EFFECTS OF ELF FIELDS ON CALCIUM-ION EFFLUX FROM BRA.IN TISSUE IN VITRO Radiat. Res .. Vol. 92. pp 510-520 Blackman, CT. S.G. Benane. J.R. Rabinowitz. D.E House. and WT. Joines (1985) A ROLE FOR THE MAGNETIC FIELD IN THE RADIATION-INDUCED EFFLUX OF CALCIUM IONS FROM BRAIN TISSUE IN~7TR() Bioelectromagnetics. Vol. 6. No.4. pp. 327-337 Blackman CF. Benane SG. House DE, Joines \VT (1985) EFFECTS OF ELF (1-120 HZ) AND MODULATED (50 HZ) RF FIELDS ON THE EFFLUX OF CALCIUM IONS FROM BRAIN TISSUE IN VITRO Bloelectromagnetics 6( 1): I-II Blackman CF., Kinney L.S., House D.E., Joines WT. (1989) MOLTIPLE POWER-DENSITY WINDOWS AND THEIR POSSIBLE ORIGIN Bioelectromagnetics 10(2):115-128 Blackman. C.F.. S.G Benane. and D.E. House (1991) THE INFLUENCE OF TEMPERATURE DURING ELECTRlC- AND MAGNETIC-FIELD-lfNDUCED Sutro EJR', references B-76 07/03/97 Appendix B' References ALTERATION OF CALCIUM-ION RELEASE FROM IN T<7TRO BRAIN TISSUE Bioelectromagnetics. Vol. 12. No.3. pp. 173-182 Bollinger, J.N. (1971) DETECTION AND EVALUATION OF RADIOFREQUENCY ELECTROMAGNETIC RADIATlOt\ INDUCED BIOLOGICAL DAMAGE IN MACACA MULAITA Final report submitted by Southwest Research Institute. San Antonio. Texas. to the USAF School of Aerospace Medicine, Brooks AFB. Texas Bro\\n, R.F. and SV. Marshall (1986) DIFFERENTIATION OF MURINE ERYTHROLEUKEMIC CELLS DURING EXPOSURE TO MICROWAVE RADIATION Radiat. Res., Vol. 108, No.1. pp. 12-22 Bro\\n-Woodman. P.D.C. and lA. Hadley (1988) STUDIES OF THE TERATOGENIC POTENTIAL OF EXPOSURE OF RATS TO 27.12 MHz PULSED SHORTWAVE RADIATION 1 Bioelectricity. Vol. 7, No.1. pp. 57-67 Bro\\n-Woodman, P.D.C., J.A. Hadley, J. Waterhouse, and W.S Webster (1988) TERATOGENIC EFFECTS OF EXPOSURE TO RADIOFREQUENCY RADLA.TION (2712 MHz) FROM A SHORTWAVE DIATHEPJvtY UNIT Indust. Health. Vol. 26, No 1. pp 1-10 Brmm-Woodman. P.DC.. J.A Hadley, L. Richardson. D. Bright. and D. Porter (1989) EVALUATION OF REPRODUCTIVE FUNCTION OF FEMALE RATS EXPOSED TO RADIOFREQUENCY FIELDS (27.12 MHz) NEAR A SHORTWAVE DIATHERMY DEVICE Health Phys .. Vol 56. NO.4. pp 521-525 Bruce-Wolfe. V. and E.R. Adair (1985) OPERANT CONTROL OF CONVECTIVE COOLING AND MICROWAVE IRRADIATION BY THE SQUIRREL MONKEY Bioelectromagnetics. Vol. 6. No.4, pp 365-380 Burdeshaw. J.A. and S. Schaffer (1977) FACTORS ASSOCIATED WITH THE INCIDENCE OF CONGENITAL ANOMALIES A LOCALIZED TNVESTIGATION Fmal Report. Report No XXIII. 24 May 1973-31 March 1976. Contract No 68-02-0791. EPA 600/1-77 016. March 1977 Burr. R.G. and A Hoiberg (1988) HEALTH PROFILE OF U.S NAVY PILOTS OF ELECTRONICALLY MODIFIED AIRCRAFT AviaL Space, and Environ. Med. February 1988 B~usC.V., Kartun K.. Pieper S.. and Adey WR (1988) INCREASED ORNITHINE DECARBOXYLASE ACTIVITY IN CULTURED CELLS EXPOSED TO LOW ENERGY MODULATED MICROWAVE FIELDS AND PHORBOL ESTER TUMOR PRODUCTS. Cancer Research 48:4222-4226 Sutro EIRr~fcrencesB-77 07/03/97 Appendix BRcfcrcn~c' Bvus CV, Lundak R.L., Fletcher R.M.. and Adey W.R. (1984) AiTERATIONS IN PROTEIN KINASE ACTIVITY FOLLOWING EXPOSURE TO CULTURED HUMAN LYMPHOCYTES TO MODULATED MICROWAVE FIELDS Bioelectromagnetics 5:341-351 Cain, CA. and W.J. Rissman (1978) MAMMALIAN AUDITORY RESPONSES TO 3.0 GHz MICROWAVE PULSES IEEE Trans. Biomed. Eng.. Vol. 25. No.3, pp. 288-293 Cain CD. Thomas D. L Ghaffari M. Adey W R (1996) 837 MHZ DIGITAL CELLULAR TELEPHONE RF FIELDS AND INDUCED O}U'.;ITHINE DECARBO:XYLASE ACTIVITY IN C3HI0Tl/2 CELLS (MEETING ABSTRACT) Bioelectromagnetlcs Society, 18 th Annual Meeting, Victona. Bntish Columbia. Canada. p. 53 Cairnie, A.B.. D.A. HilL and H.M. Assenheim (1980) DOSIMETRY FOR A STUDY OF EFFECTS OF 2.45-GHz MICROWAVES ON MOUSE TESTIS BlOelectromagnetics, Vol. L No.3, pp. 325-336 Cantor, K.P .. P.A. Stewart L.A. Brinton, and M. Dosemeci (1995) OCCUPATIONAL EXPOSURES AND FEMALE BREAST CANCER MORTALITY IN THE UNITED STATES 1. Environ. Med., Vol. 37, No.3. pp. 336-348 Carpenter. R.L and E.M. Livstone (1971) EVIDENCE FOR NONTHERMAL EFFECTS OF MICROWAVE RADIATION: ABNORMAL DEVELOPMENT OF IRRADIATED INSECT PUPAE IEEE Trans. Microwave Theory Tech.. VoL 19. No.2. pp. 173-178 Chemovetz. M.E.. D.R. Justesen. N.W. Kmg. and J.E Wagner (1975) TERATOLOGY. SURVIVAL. AND REVERSAL LEAIU\lIj\;G AFTER FETAL IRR.\DIATION OF MICE BY 2450-MHz MICROWAVE ENERGY 1 Microwave Power. Vol. 10. No 4, pp. 391-409 Chemovetz. M.E., D.R. Justesen. and A.F Oke (1977) A TERATOLOGICAL STUDY OF THE RAT MICROWAVE AND INFRARED RADIATIONS COMPARED Radio SCi. VoL 12. No. 6S. pp 191-197 Chou, C-K. and A.W. Guy (1978) EFFECTS OF ELECTROMAGNETIC FIELDS ON ISOLATED NERVE AND MUSCLE PREPARATIONS IEEE Trans. MicrO\vave Theory Tech., Vol. 26. No.3, pp 141-147 Chou, C-K. and A.W. Guy (1979) CARBON ELECTRODES FOR CHRONIC EEG RECORDINGS IN MICROWAVE RESEARCH J. Microwave Power, Vol. 14, No.4, pp. 399-404 Chou. C.-K., LF. Han, and AW Guy (1980) MICROWAVE RADIATION AND HEART-BEAT RATE OF RABBITS J. Microwave Power. Vol. 15. No.2, pp. 87-93 Sutro EIR' references B-78 07/03'97 Appendix B References Chou, C-K., A.W. Guy, J.B. McDougall, and L.-F. Han (1982) EFFECTS OF CONTINUOUS AND PULSED CHRONIC MICROWAVE EXPOSURE ON RABBITS Radio Sci.. Vol. 17, No. 55, pp 185-193 Chou, C-K., A.W. Guy. LL Kunz, RB Johnson. JCrowle~.and JH Krupp LONG-TERM, LOW-LEVEL. MICROWAVE IRRADIATION OF RATS Bioelectromagnetics 13(6): 469-496,1992 Clapman. R.M. and CA. Cain (1975) ABSENCE OF HEART-RATE EFFECTS IN ISOLATED FROG HEART IRRADIATED WITH PULSE MODULATED MICROWAVE ENERGY J Microwave Power. Vol. 10, No.4, pp. 411-419 Cleary. 5.F., B.S Pasternack. and GW. Beebe (1965) CATARACT INCIDENCE IN RADAR WORKERS Arch Environ. Health, Vol II. pp. 179-182 Cleary. SF. and B.S. Pasternack (1966) LENTICULAR CHANGES IN MICROWAVE WORKERS Arch. Environ. Health, Vol. 12. pp. 23-29 Cohen. RH., A.M. Lilienfeld. S Kramer, and L.C Hyman (1977) PARENTAL FACTORS IN DOWN'S SYNDROME-RESULTS OF THE SECOND BALTIMORE CASE~ONTROLSTUDY In EG. Hook and I.H. Porter (eds). POPULATION GENETICS-STUDIES IN HUMANS. A,:ademlc Press. New York. pp 301-352 Cooper. M.S. and KM. Amer (1983) THE ABSENCE OFCOHERE~TVIBRATIONS IN THE RAMAN SPECTRA OF LIVING CELLS Phys Lett.. Vol 98A. No.3. pp 138-142 Courtney. K.R.. 1.e. Lin. A.W Guy. and C-K. Chou (1975) MICROWAVE EFFECT ON RABBIT SUPERIOR CERVICAL GANGLION IEEE Trans. Microwave Theory Tech.. Vol. 23. No 10. pp R09-813 Creighton. M.O.. L.E Larsen. Pl Stewart-DeHaan. JH Jacobi. M. Sanwal. J.e. Baskerville. H.E Bassen. D.O. BrO\\TI, and l.R. Trevithlck (1987) IN v7TRO STUDIES OF MICROWAVE-INDUCED CATARACT II. COMPARISON OF DAMAGE OBSERVED FOR CONTINUOUS WAVE AND PULSED MICROWAVES Exp. Eye Res .. Vol. 45. pp. 357-373 Cunitz, R.L W.O. Galloway. and CM. Berman (1975) BEHAVIORAL SUPPRESSION BY 383-MHz RADlATION IEEE Trans. Microwave Theory Tech. Vol. 23. No.3. pp. 313-316 Czerska E. M. Elson E. C. DaVIS C. e. Swicord M. L, Czerski P (1992) EFFECTS OF CONTINUOUS AND PULSED 2450-MHZ RADIATION ON SPONTANEOUS LYMPHOBLASTOID TRANSFORMATION OF HUMAN LYMPHOCYTES IN VITRO Bioelcctromagnetics 13(4):247-259 Sutro EIR\ references B-79 07/03/97 D'Andrea. I.A.. lR. DeWitt, O.P Gandhi, S. Stensaas. J.L. Lords. and H.C. Nielson (l986al BEHAVIORAL AND PHYSIOLOGICAL EFFECTS OF CHRONIC 2.450-MHz MICROWAVE .., IRRADIATION OF THE RAT AT 0.5 mW/cm":' Bioelectromagnetics, Vol. 7. No.1, pp. 45-56 D'Andrea. lA.. I.R. DeWitt, R.Y. Emmerson. C. Bailey, S. Stensaas, and O.P Gandhi (1986b) - .., INTERMITTENT EXPOSURE OF RATS TO 2450 MHz MICROWAVES AT 2.:- mW/cm- BEHAVIORAL AND PHYSIOLOGICAL EFFECTS Bioelectromagnetics. Vol. 7. No.3, pp. 315-328 D'Andrea. J.A., B.L. Cobb. and 1.0. de Lorge (1989) LACK OF BEHAVIORAL EFFECTS IN THE RHESUS MONKEY: HIGH PEAK MICROWAVE PULSES AT 1.3 GHz BlOelectromagnetics. Vol. 10, No.1, pp. 65-76 de Lorge, J.O. (1976) THE EFFECTS OF MICROWAVE RADIATION ON BEHAVIOR AND TEMPERATURE IN RHESUS MONKEYS In c.c. Johnson and M.L. Shore (eds.), BIOLOGICAL EFFECTS OF ELECTROMAGNETIC WAVES. U.S Dept. ofHealth, Education. and Welfare. Washington. D.C. HEW PublIcation (FDA) 77-8010. Vol 1. pp. 158-174 DeWitt. J.R.. J.A. D'Andrea. R.Y. Emmerson. and O.P. Gandhi (1987) BEHAVIORAL EFFECTS OF CHRONIC EXPOSURE TO 0.5 mW/cm l OF 2.450-MHz MICROWAVES Bioelectromagnetics, Vol 8. No 2. pp. 149-157 DJordJevic. Z.. A. Kolak. M. StoJkovic. N. Rankovic. and P RJstic. (l97Q) A STUDY OF THE HEALTH STATUS OF RADAR WORKERS AVIatIOn. Space, & EnViron Med.. Vol 50. No.4. April 1979. pp. 396-398 Djordjevic, Z .. A. Kolak. V. Djokovic, P. RJstic. and Z. Kelechevlc (1983) RESULTS OF OUR IS-YEAR STUDY INTO THE BIOLOGICAL EFFECTS OF MICROWAVE EXPOSURE AViatIOn. Space. & Environ. Med.. June 1983. pp. 539-542 Dolk H et al. (1997) CANCER INCIDENCE NEAR RADIO AND TELEVISION TRASMITTERS IN GREAT BRITAIN. PART I. SUTTON COLDFIELD TRANSMITTER Am J EpidemlOl 145. 1-9 Dolk H et al. (1997) CANCER INCIDENCE NEAR RADIO AND TELEVISION TRASMITTERS IN GREAT BRITAIN. PART n. ALL HIGH-POWER TRANSMITTERS Am J Epidemiol 145.10-17 Durney, C.H.. H. Massoudi, and M.F. Iskander (1986) RADIOFREQUENCY RADIATION DOSIMETRY HANDBOOK [FOURTH EDITION] USAF School of Aerospace Medicine. Brooks AFB, TX.Report USAFSAM-TR-85-73 Sutw EIR' references 8-80 07/03/97 Append.tx BRef~rcnc~.;; Dutta, S.K., W.H Nelson. C.F. Blackman. and DJ Brusick (1979) LACK OF MICROBIAL GENETIC RESPONSE TO 245-GHz CW AND 8.5- TO Q6-GHz PULSED MICROWAVES J. Microwave Power. Vol. 14. No 3, pp. 275-280 Dutta S.K.. Das K.. Ghosh B., and Blackman C.F. (1992) DOSE DEPENDENCE OF ACElYLCHOLINESTERASE ACTIVITY IN NEUROBLASTOMA. CELLS EXPOSED TO MODlJLATED RADIO-FREQUENCY ELECTROMAGNETIC RADIATION Bioelectromagnetics 13(4):317-322 Dutta S.K.. Gosh B.. and Blackman C.F. (1989) RADIOFREQUENCY RADIATION-INDUCED CALCIUM ION EFFLUX ENHANCEMENT FROM HUMAN AND OTHER NEUROBLASTOMA CELLS IN CULTURE Bioelectromagnetics 10(2): 197-202 Dutta S.K., Venna M .. and Blackman C.F. (1994) FREQUENCY-DEPENDENT ALTERATIONS IN ENOLASE ACTIVlTI' IN ESCHERICHIA COLI CAUSED BY EXPOSURE TO ELECTRIC AND MAGNETIC FIELDS. Bioelectromagnetics 15(5):377-383 Edwards. MJ. (1978) CONGENITAL DEFECTS DUE TO HYPERTHERMiA. Adv. Vet Sci. Compo Med.. Vol. 22. pp. 29-52 Edwards. G.S .. c.c. Davis. J.D Saffer. and M.L Swicord (1985) MICROWAVE-FIELD-DRIVE~ACOUSTIC MODES IN DNA Biophys. L Vol. 47. pp. 799-807 EPA (1990) EVALUATION OF THE POTENTIAL CARCINOGENICITI' OF ELECTROMAGNETIC FIELDS US. Environmental Protection Agency. Office of Health and EnVIronment Assessment. Washington. DC 20460. Workshop Review Draft Report EPN600/6-901005B EPA (1992) AN SAB REPORT: POTENTIAL CARCINOGENICITI' OF ELECTRIC AND MAGNETIC FIELDS REVIEW OF THE ODDS POTENTIAL CARCINOGENICITI' OF ELECTROMAGNETIC FIELDS BY THE RADIATION ADVISORY COMMITTEE'S NONIONIZING ELECTRIC AND MAGNETIC FIELDS SUBCOMMITTEE Report EPA-SAB-RAC-92-0 13.29 January 1992 FCC (1993) NOTICE OF PROPOSED RULE MAKING ET Docket No. 93-62, 8 FCC Rcd 2849 FCC (1996) REPORT AND ORDER IN THE MATTER OF GUIDELINES FOR EVALUATING THE ENVIRONMENTAL EFFECTS OF RADIOFREQUENCY RADIATION. ET DOCKET NO 93-62 FCC 96-326 Sutro EIR. references 8-81 07/03197 Appendix B' Rcfcrcn-:c, Fisher, P.D., J.K. Lauber, and W.AG. Voss (1979) THE EFFECT OF LOW-LEVEL 2450 MHz CW MICROWAVE IRRADLA..TlON A.ND BODY TEMPERATURE ON EARLY EMBRYONAL DEVELOPMENT 11\ CHICKENS Radio Sci., Vol. 14, No. 6S, pp. 159-163 Foster, M.R., E.S. Ferri, and GJ. Hagan (1986) DOSIMETRIC STUDY OF MICROWAVE CATARA..CTOGENESIS Bioelectromagnetics, Vol. 7, No.2. pp. 129-140 Frazer. JW., J.H. Merritt. SJ. Allen. R.H. Hartzell. J.A. Ratliff, AT Chamness. RE Detwiler.. and T McLellan (1976) THERMAL RESPONSES TO HIGH-FREQUENCY ELECTROMAGNETIC RADIATION FIELDS l'SAF School of Aerospace Medicme, Brooks AFB. Texas. Report SAM-TR-76-20. September 1976 Frey, AH. (1961) AUDITORY SYSTEM RESPONSE TO RADIO-FREQUENCY ENERGY Aerospace Med.. Vol. 32. pp. 1140-1142 Frey, AH. (1962) HUMAN AUDITORY SYSTEM RESPONSE TO MODULATED ELECTROMAGNETIC ENERGY J. Appl. PhyslOl., Vol. 17. No.4. pp. 689-692 Frey, A.H. (1967) BRAIN STEM EVOKED RESPONSES ASSOCIATED WITH LOW-INTENSITY PULSED UHF ENERGY J Appl. PhyslOl. Vol. 23. No 6. pp. 984-988 Frey. A.H. and E. Seifert (1968) PULSE MODULATED UHF ENERGYILLU~lINATIONOF THE HEART ASSOCIATED WITH CHANGE IN HEART RATE LIfe SCI.. Vol. 7. No. 10. Part II. pp 505-512 Frey. A.H.. S.R. Feld, and B. Frey (1975) NEURAL FUNCTION AND BEHAVIOR: DEFINING THE RELATIONSHIP In P.W Tyler (ed.). Ann. N.Y. Acad. Sci .. Vol. 247. pp 433-43Q Fucic. A.. V Garaj-Vrhovac, M Ekara. and B. Dimitrovic (1992) X-RAYS. MICROWAVES AND VINYL CHLORIDE MONOMER: THEIR CLASTOGENIC AND ANEUGENIC ACTIVITY. USING THE MICRONUCLEUS ASSAY ON HUMAN LYMPHOCYTES Mutat. Res. Vol 282. No 4. pp 265-271 Gabnel. c.. E.H. Grant. R Tala. P.R. Bro\\11. B Gestblom. and E Noreland (1987) MICROWAVE ABSORPTION IN AQUEOUS SOLUTIONS OF DNA Nature, Vol. pp. 145-146.328. QJuly 1987 Gage. M.I. and W.M. Guyer (1982) INTERACTION OFA~mIENTTEMPERATURE AND MICROWAVE POWER DENSIn' ON SCHEDULE-CONTROLLED BEHAVIOR IN THE RAT Radio Sci., Vol. 17, No 55. pp 179-184 Sutro ErR· referffices B-82 (7/0)/97 Appcndi, B RcL:r::n.:c, Galloway. W.O. (1975) MICROWAVE DOSE-RESPONSE RELATIONSHIPS ON TWO BEHAVIORAL TASKS In P.W. Tyler (00.), Ann N.Y Acad. Sci.. Vol. 247. pp. 410-416 Galvin. M.J. and OJ. McRee (1981) INFLUENCE OF ACUTE MICROWAVE RADlATION 01\ CARDIAC FUNCTION IN NORMAL AND MYOCARDIAL ISCHEMIC CATS 1. Appl. Physiol: Respiratory. EnvironmentaL and ExerCise PhysioL Vol 50. No.5. pp931-q~5 Galvin. M.J.. OJ. McRee. CA. HaiL J.P. Thaxton. and CR. Parkhurst (1981a) HUMORAL AND CELL-MEDIATED IMMUNE FUNCTION IN ADULT JAPANESE QUAIL FOLLOWING EXPOSURE TO 245-GHz MICROWAVE RADIATION DURING EMBRYOGEN't BlOelectromagnetics. Vol 2. No.3, pp. 269-278 Galvin. M.J.. CA. HaiL and OJ. McRee (l981b) MICROWAVE RADIATION EFFECTS ON CARDIAC MUSCLE CELLS IN V1TRO Radial. Res .. Vol. 86, pp 358-367 Galvin. M.J., D.L. Parks. and OJ. McRee (l981c) INFLUENCE OF 2.45 GHz MICROWAVE RADIAnON ON ENZYME ACTIVITY Radial. Environ. Biophys., Vol 19, pp. 149-156 Galvin. M.J., M.S. Dutton. and 0.1. McRee (1982) INFLUENCE OF 2.45-GHz CW MICROWAVE RADIATION ON SPONTANEOUSLY BEATING RAT ATRIA Bioelectromagnetics. Vol. 3. No.2. pp 219-226 Galvin. M.J and OJ. McRee (1986) CARDIOVASCULAR. HEMATOLOGIC, AND BIOCHEMICAL EFFECTS OF ACUTE VENTRA.L EXPOSURE OF CONSCIOUS RATS TO 2450-MHz (CW) MICROWAVE RADIATION BlOelectromagnetlcs. Vol. 7. No 2. pp. 223-233 Gandhi, O.P.. M.J. Hagmann, D.W. Hill. L.M. Partlow. and L. Bush (1980) MILLIMETER WAVE ABSORPTION SPECTRA OF BIOLOGICAL SAMPLES Bioelectromagnetics, Vol I. No.3. pp. 285-298 Garaj-Vrhovac. V.. A Fucic. and B Horvat (1992) THE CORRELATION BETWEEN THE FREQUENCY OF MICRONUCLEI AND SPECIFIC CHROMOSOME ABERRATIONS IN HUMAN LYMPHOCYTES EXPOSED TO MICROWAVE RADIATION IN HTRO Mutat. Res., Vol. 281. No.3. pp 181-186 Gildersleeve. R.P .. M.J. Galvin. D.I. McRee. J.P Thaxton. and CR. Parkhurst (1987) REPRODUCTION OF JAPANESE QUAIL AFTER MICROWAVE IRRADIATION (2.45 GHz CW) DURING EMBRYOGENY Bloelectromagnetics. Vol. 8. No I, pp 9-21 Grayson JK (1996) RADIATION EXPOSURE. SOCIOECONOMIC STATUS. AND BRAIN TUMOR RISK IN THE US Sutro EIR· references B-83 07103/97 Appendix B Rckr.... n..:..:' AIR FORCE: A NESTED CASE-CONiROL STUDY Am J EpidemlOl 143(5):480-486 Gruenau. SP. KJ. Oscar. MT Folker. and Sl Rapopon (1982) ABSENCE OF MICROWAVE EFFECT ON BLOOD-BRAIN BARRIER PERMEABILIn' TO C 1-+_ SUCROSE IN THE CONSCIOUS RAT Exper. NeurobioL Vol. 75, pp 299-307 Guy. A.W.. 1.c. Lin. P.O Kramar. and A.F. Emery (1975a) EFFECT OF 2450-MHz RADIATION ON THE RABBIT EYE IEEE Trans. Microwave Theory Tech.. Vol. 23. No.6. pp. 492-498 Halle. B. (1988) 01\ THE CYCLOTRON RESONANCE MECHANISM FOR MAGNETIC FIELD EFFECTS ON TRANSMEMBRANE ION CONDUCTMTY BlOelectromagnetics, Vol 9. NO.4. pp 381-385 Hamburger. S., 1.N Logue. and P.M. Silverman (1983) OCCUPATIONAL EXPOSURE TO NON-IONIZING RADLA.TION AND AN ASSOCIATION WITH HEART DISEASE: AN EXPLORATORY STUDY J Chron. Dis .. Vol 36. No II. pp. 791-802 Hammett and Edison (1997) ENGINEERING ANALYSIS OF RADIO FREQUENCY EXPOSURE CONDITIONS WITH ADDITIONOF DIGITIAL TV CHANNELS Technical Repon prepared for Sutro Tower. Inc Hammett and Edison. Inc .. Consulting Engineers. San Francisco Hamnerius. Y . H. Olofsson. A. Rasmuson. and B Rasmuson (l(79) A NEGATIVE TEST FOR MUTAGENIC ACTION OF MICROWAVE RADIATION IN DROSOPHILA MELANOGASTER MutatIOn Res .. Vol 68. No.2. pp. 217-223 Hamrick. PE and S.S Fox (1977) RAT LYMPHOC'riES IN CELL CULTURE EXPOSED TO 2450 MHz (CW) MICROWAVE RADIATION J. Microwave Power. Vol. 12. No.2. pp. 125-132 Heynick. LN. (1987) CRITIQUE OF THE LITERATURE ON BIOEFFECTS OF RADIOFREQUENCY R.A..DIATION A COMPREHENSIVE REVIEW PERTINENT TO AIR FORCE OPERATIONS USAF School of Aerospace MedIcine. Brooks AFB. TX. Report USAFSAM-TR-87-3 Hevnick. LN. and P Polson (1996a) R.A.DIOFREQUENCY RADIATION AND TERATOGENESIS: A COMPREHENSIVE REVIEW PERTINENT TO AIR FORCE OPERATIONS USAF Armstrong Laboratory. OccupatIOnal and Emlronmental health Directorate. RadlOfrequency Radiation Division. Brooks AFB. TX 78235-5324. Final Report ALiOE-TR-1996-0036, June 1996 Sutro EJR' refer"tlces B-84 07/03/97 Appendix B Refer", l!.::'", Hemick. L.N and P. Polson (1996b) HUMAN EXPOSURE TO RADIOFREQUENCY RADIATIO"\:. A COMPREHENSIVE REVIEW PERTINENT TO AIR FORCE OPERATIONS USAF Annstrong Laboratory. Occupational and Environmental health Directorate. Radiofrequency Radiation Division. Brooks AFE. TX 78235-5324. Final Report AL/OE-TR-1996-0035. June 1496 Hills. G.A.. P.A. Kondra. and M.A.K. Hamid (1974) EFFECTS OF MICROWAVE RADIATIONS ON HATCHABIUn' AND GRO\\-TH IN CHICKENS AND TURKEYS Can. J. Animal Sci. Vol. 54. pp. 573-578 Ho. H.S. and W.P. Edwards (1979) THE EFFECT OF ENVIRONMENTAL TEMPERATURE AND AVERAGE DOSE RA.TE OF MICROWAVE RADIATION ON THE OXYGEN-CONSUMPTION RATE OF MICE Radiat. Environ. Biophys., Vol. 16. pp. 325-338 Hocking. B.. K. Joyner. and R. Fleming (1988) HEALTH ASPECTS OF RADIO-FREQUENCY RADIATION ACCIDENTS--PART I: ASSESSMENT OF HEALTH AFTER A RADIO-FREQUENCY RADIATION ACCIDENT 1. Microwave Power & EM Energy. Vol. 23, No.2. pp. 67-74 Hockmg B, Gordon I. R. Grain H. L. Hatfield G. E. (1996) CANCER INCIDENCE AND MORTALITY AND PROXIMIn' TO TV TOWERS l\.'1ed J Aust 165(11-12):601-605 Hollows. F C and J B Douglas (1984) MICROWAVE CATARACT IN RADIOLINEMEN AND CONTROLS Lancet. Vol 2. No. 8399. 18 August 1984. pp. 406-407 Huang. AT.. M.E. Engle, JA. Elder. J.B Kinn. and T.R Ward (1977) THE EFFECT OF MICROWAVE RADIATION (2450 MHz) ON THE MORPHOLOGY AND CHROMOSOMES OF LYMPHOCYTES RadIO Sci .. Vol. 12, No. 6S. pp 173-177 Huang. AT. and N,G Mold (1980) IMMUNOLOGIC AND HEMATOPOIETIC ALTERATIONS BY 2.450-MHz ELECTROMAGNETIC RADIATION BlOclectromagnetlcs, Vol. 1. No L pp. 77-87 Hunt. E.L.. NW. King. and RD Phillips (1975) BEHAVIORAL EFFECTS OF PULSED MICROWAVE RADIATION In PW Tyler (ed.). Ann. NY Acad Sci. Vol 247. pp 440-45) IRPA (1988) GUIDELINES ON LIMITS OF EXPOSURE TO RADIOFREQUENCY ELECTROMAGNETIC FIELDS IN THE FREQUENCY RANGE FROM 100 kKZ TO 300 GHz Health Phys .. Vol. 54, No 1. pp. 115-123 Iurinskaia M. M. Kuznetsov V. I. Galeev A. 1. Kolomytkin 0 V (1996) REACTION OF THE BRAIN RECEPTOR SYSTEM TO THE EFFECT OF LOW INTENSITY R-R~ AppendIx B Refer:':l:;':":' MICROWAVES (IN RUSSIAN) BlOfizika 4l(4):859-865 Jensh. RP.. 1. Weinberg. and R.L. Brent (1982a) TERATOLOGIC STUDIES OF PRENATAL EXPOSURE OF RATS TO 9IS-MHz MICROWAVE RADIATION Radiat. Res., Vol. 92, pp. 160-171 Jensh, R.P .. W.H. Vogel. and RL. Brent (l982b) POSTNATAL FUNCTIONAL ANALYSIS OF PRENATAL EXPOSURE OF RATS TO 915 MHz MICROWAVE RADIATION 1. Am Call ToxicoL ValL No.3. pp 73-90 Jensh. R.P., l. Weinberg. and R.L. Brent (l983a) AN EVALUATION OF THE TERATOGENIC POTENTIAL OF PROTRACTED EXPOSURE OF PREGNANT RATS TO 2450-MHz MICROWAVE RADIATION: L MORPHOLOGIC ANALYSIS AT TER.,\1 J. TOXICO!. Environ. Health, Vo!. 11, pp. 23-35 Jensh. RP.. W.H. Vogel. and RL Brent (l983b) AN EVALUATlON OF THE TERATOGENIC POTENTIAL OF PROTRACTED EXPOSURE OF PREGNANT RATS TO 2450-MHz MICROWAVE RADIATION: II POSTNATAL PSYCHOPHYSIOLOGIC ANALYSIS J Toxico!. Environ. Health. Vol II. pp. 37-59 Jensh. R. P. (1984a) STUDIES OF THE TERATOGENIC POTENTIAL OF EXPOSURE OF RATS TO 6000-MHz l\lICROWAVE RADIATION--L MORPHOLOGIC ANALYSIS AT TERM RadIaL Rl:s .. Vol 97. NO.2. pp. 272-281 Jensh. R.P. (l984b) STUDIES OF THE TERATOGENlC POTENTIAL OF EXPOSURE OF RATS TO 6000-MHz MICROWAVE RADIATION--II. POSTNATAL PSYCHOPHYSIOLOGIC EVALUATIONS Radiat. Res.. Vol. 97. No 2. pp 282-30 I Justesen. D.R. and N.W King (1970) BEHAVIORAL EFFECTS OF LOW LEVEL MICROWAVE IRRADIATION IN THE CLOSED SPACE SITUATION In SF Cleary (cd.), BIOLOGICAL EFFECTS AND HEALTH IMPLICATIONS OF MICROWAVE RADIATION. L'S Dept. of Health. EducatIon. and Welfare. Washington. D.C. HEW Publication BRHJDBE 70-2. pp 154-179 Kallen. B. G. Malmquist. and U. Moritz (1982) DELIVERY OUTCOME AMONG PHYSIOTHERAPISTS IN SWEDEN IS NON-IONIZING RADIATION A FETAL HAZARD') Arch. Environ. Health. Vol. 37, No.2, pp. 81-85 Kamimura. Y.. K-i. Saito, T Saiga. and Y Amemiya (1994) EFFECT OF 2.45 GHz MICROWAVE IRRADIATION ON MONKEY EYES [LETTERI Appendi:-; B Refere;<e, IEICE Trans. Commun. Special Issue on Biological Effects of Electromagnetic Fields. Vol E77-B. '\0 6. pp.762-765 Kaplan. IT.. W Metlay. M.M. Zarct. L. Birenbaum. and SW Rosenthal (1071) ABSENCE OF HEART-RATE EFFECTS IN RABBITS DURING LOW-LEVEL MICROWAVE IRRADIATION IEEE Trans. Microwave Theory Tech.. Vol. 19. No.2. pp 168-\ 73 Kaplan. 1.. P Polson, e. Rebert. K. Lunan. and M. Gage (1982) BIOLOGICAL AND BEHAVIORAL EFFECTS OF PRENATAL AND POSTNATAL EXPOSURE TO 2450-MHz ELECTROMAGNETIC RADIATION IN THE SQUIRREL MONKEY Radio Sci. Vol 17. No. 5S, pp. 135-144 Kramar P. C Harris. AF emery. and AW Guy (1978) ACUTE MICROWAVE IRRADlATION AND CATARACT FORMATION IN RABBITS AND MONKEYS. J Microwave Power 13:239 Krupp. J.H. (1977) THERMAL RESPONSE IN MACACA MULAITA EXPOSED TO 15- AND 20-MHz RADIOFREQUENCY RADlATION USAF School of Aerospace Medicine. Brooks AFB. Texas. Report SAM-TR-77-16. September 1977 Krupp. JH. (1978) LONG-TERM FOLLOWUP OF MACACA MULAITA EXPOSED TO HIGH LEVELS OF 15-.20-. AND 26-MHz RADIOFREQUENCY RADIATION USAF School of Aerospace Medicine. Brooks AFB. Texas. Report SAM-TR-78-3. January I Q78 Kues. H.A.. L.W. Hirst. G.A. Lutty. S.A. D'Anna. and GR Dunkelberger (1985) EFFECTS OF 245-GHz MICROWAVES ON PRIMATE CORNEAL ENDOTHELIUM BlOciectromagnetlcs. Vol. 6. No.2. pp. 177-188 Kues. H.A. and J.e. Monahan (1992) MICROWAVE-INDUCED CHA.NGES TO THE PRIMATE EYE Johns Hopkins APL Digest, Vol. 13. No. I. pp 244-255 Kues. H.A.. J.e. Monahan. SA D'Anna. OS. McLeod. GA Lutty. and S Koslov (1992) INCREASED SENSITIVITY OF THE NON-HUMAN PRIMATE EYE TO MICROWAVE RADIATION FOLLOWING OPHTHALMIC DRUG PRETREATMENT Bioelectromagnetics. VoL 13. No.5, pp 379-393 Lal. H .. A Horita, e.-K. Chou. and A.W. Guy (1984) ETHANOL-INDUCED HYPOTHERMIA AND ETHANOL CONSUMPTION IN THE RAT ARE AFFECTED BY LOW-LEVEL MICROWAVE IRRADIATION Bioelectromagnetics, Vol. 5, No.2, pp 213-220 Lai. H.. A Horita. and AW. Guy (1988) ACUTE LOW-LEVEL MICROWAVE EXPOSURE AND CENTRAL CHOLINERGIC ACTIVITY STUDIES ON IRRADIATION PARAMETERS Bioelectromagnetlcs, Vol. 9 No 4, pp. 355-362 Sutro EIR\ references B-87 07/03/97 Appendix BR;:L:r":Il~":~ Lai H, MA Carino. A Horita, and AW Guy (1989) LOW-LEVEL MICROWAVE IRRADIATION AND CENTRAL CHOLINERGIC SYSTEMS Pharmacol Biochern Behav 33(1 ): 131-138 Lai H (1992) RESEARCH ON THE NEUROLOGICAL EFFECTS OF NONIONIZING RADIATION AT THE UNIVERSITY OF WASHINGTON Bioelectromagnetics 13(6):513-526 Lai H. Carino MA. Horita A. Guv AW (1992) OPImD RECEPTOR SUBTYPES THAT MEDLA.TE A MICROWAVE-INDUCED DECREASE IN CENTRAL CHOLINERGIC ACTIVITY IN THE RAT BlOelectromagnetics 13 :23 7-246 Lai H, Horita A, Guy AW (1994) MICROWAVE IRRADIATION AFFECTS RADIAL-ARM MAZE PERFORMANCE IN THE RA.T Bioelectromagnetics 15(2 ):95-1 04 Lai H. Singh NP (1995) ACUTE LOW-INTENSITY MICROWAVE EXPOSURE INCREASES DNA SINGLE-STRA...ND BREAKS IN RAT BRAIN CELLS. Bioekctromagnetics 16(3):207-210 Lai H. Smgh NP (1996) SINGLE- AND DOUBLE-STRAND DNA BREAKS IN RAT BRAIN CELLS AFTER ACUTE EXPOSURE TO RA.DIOFREQUENCY ELECTROMAGNETIC RADIATION 1m J Radiat BIOI 69:513-521 Larsen. AI. J Olsen. and O. Svane (1991) GENDER-SPECIFIC REPRODUCTIVE OUTCOME AND EXPOSURE TO HIGH-FREQUENCY ELECTROMAGNETIC RADIATION AMONG PHYSIOTHERAPISTS Scan. 1. Work EnViron Health. VoL 17. No.5. pp 324-329 Lary. J.M.. D.L. Conover. PH. Johnson. and J.R. Burg (1983a) TERATOGENICITY OF 27. 12-MHz RADIATION IN RATS IS RELATED TO DURATION OF HYPERTHERMIC EXPOSURE BlOelectromagnetlcs, Vol. 4, No 3, pp. 249-255 La~.1.M.. DL. Conover. and PH Johnson (1983b) ABSENCE OF EMBRYOTOXIC EFFECTS FROM LOW-LEVEL (NONTHERMAL) EXPOSURE OF RATS TO 100 MHz RADIOFREQUENCY RADIATION Scand. J. Work Envlfon. Health. Vol 9, pp. 120-\27 La~·.J.M.. DL. Conover. PH Johnson. and R.W Hornung (\986) DOSE-RESPONSE RELATIONSHIP BETWEEN BODY TEMPERATURE AND BIRTH DEFECTS IN RADIOFREQUENCY-IRRADIATED RATS Bioelectromagnetlcs. Vol. 7. No 2. pp. 141-149 Lebovitz. R.M. (\ 981) PROLONGED MICROWAVE IRRADIATION OF RATS EFFECTS ON CONCURRENT OPERANT Sutro EIR· references B-88 07i()3 1<)7 BEHAVIOR BlOelectromagnetics, Vol. 2. No.2, pp. 169-185 Lebovitz. R.M. (1983) PULSE MODULATED AND CONTINUOUS WAVE MICROWAVE RADIATION YIELD EQUIVALENT CHANGES IN OPERANT BEHAVIOR OF RODENTS Physiology and Behavior, Vol. 30. No.6. pp. 891-898 LebovItz. R.M. and L. Johnson (1983) TESTICULAR FUNCTION OF R.A1'5 FOLLOWING EXPOSURE TO MICROWAVE RADIATIOl\ BlOelectromagnetics. Vol. 4. No.2. pp 107-114 LebovItz. R.M. and L. Johnson (1987) ACUTE. WHOLE-BODY MICROWAVE EXPOSURE AND TESTICULAR FUNCTION OF RA. TS Bioelectromagnetics. Vol. 8, No. L pp. 37-43 Lcster.J.R. and D.F. Moore (1982a) CANCER MORTALITY AND!~JRFORCE BASES 1 Bioelectricity. Vol. 1. No. L pp. 77-82 Lester. J.R. and D.F. Moore (1982b) CANCER INCIDENCE AND ELECTROMAGNETIC RADIATION J. Bioelectncity. Vol. L No L pp 59-76 Liburdy. R.P. (1977) EFFECTS OF RADIO-FREQUENCY RADIATION ON INFLAMMATION Radio SCI.. VoL 12. No. 6S. pp 179-183 Liburdy. R.P and R.L. Magm (1985) MICRO\VAVE-STIMULATED DRUG RELEASE FROM LIPOSOMES Radiat Res .. Vol. 103. pp. 266-275 Liddle CG. Putnam JP. Huey OP (1994) ALTERATION OF LIFE SPAN OF MICE CHRONICALLY EXPOSDED TO 2.45 GHZ CW MICROWAVES BlOelectromagnetics 15(3): 177-181 Liddle. e.G.. J.P Putnam, and O.H. Le\\ter (1987) EFFECTS OF MICROWAVE EXPOSURE AND TEMPERATURE ON SURVIVAL OF MICE INFECTED WITH STREPTOCOCCUS PNEUMONIAE Bioclectromagnetics, Vol. 8. No 3. pp. 295-302 Lilienfeld. A.M.. J. Tonascia. S Tonascia. C.H Libauer. G.M Cauthen. J.A. Markowitz. and S. Weida (1978) FOREIGN SERVICE HEALTH STATUS STUDY EVALlATION OF STATUS OF FOREIGN SERVICE AND OTHER EMPLOYEES FROM SELECTED EASTERN EUROPEAN POSTS Final Report. July 31. 1978. Contract No. 6025-619073. Dept of EpIdemiology, School of Hygiene and Public Health. The Johns Hopkms UnIversIty. BaltImore. MD Sutro EIR reference!' B-89 07103197 Appendix B. Refcrcn.:cs Lin. J.e.. A.W. Gu\'. and L.R. Caldv..·ell (1977) THERMOGRAPHiC AND BEHAVIORAL STUDIES OF RATS IN THE NEAR FIELD OF q IX-MHz RADIATIONS IEEE Trans. Microwave Theory Tech.. Vol. 25. No 10. pp. 83:3-836 Lin. J.e.. J.e. Nelson, and M.E. Ekstrom (1979) EFFECTS OF REPEATED EXPOSURE TO 148-MHz RADIO WAVES ON GRO\\;TH AND HEMATOLOGY OF MICE Radio Sci .. Vol. 14. No. 6S, pp 173-179 Lin. J.e. and M.F. Lin (1982) MICROWAVE HYPERTHERMIA-INDUCED BLOOD-BRAIN BARRIER ALTERATIONS Radiat. Res .. Vol. 89, pp. 77-87 Lindauer. G.A., L.M. Liu. G.W. Skewes. and FJ. Rosenbaum (1974) FURTHER EXPERIMENTS SEEKING EVIDENCE OF NONTHERMAL BIOLOGICAL EFFECTS OF MICROWAVE RADIATION IEEE Trans. Microwave Theory Tech., Vol. 22. No.8. pp. 790-793 Litovitz TA, Krause D. Penafiel M. Elson E. Mullins JM (1993) THE ROLE OF COHERENCE TIME IN THE EFFECT OF MICROWAVES ON ORNITHINE DECARBOX'YLASE ACTIVITY Bioelectromagnetics 14(5):395-403 Liu. L.M.. F.J. Rosenbaum. and W.F. Pickard (1975) THE RELATION OF TERATOGENESIS IN TENEBRIO MOLITOR TO THE INCIDENCE OF LOW LEVEL MICROWAVES IEEE Trans MicrO\vave Theory Tech.. Vol 23. No. II. pp 929-q31 LIU. L.M.. FJ. Rosenbaum. and W.F. Pickard (1976) THE INSENSITIVITI' OF FROG HEART RATE TO PULSE MODULATED MICROWAVE ENERGY 1. MicrO\vave Power. Vol II. No.3, pp. 225-232 Lords. J.L.. e.H. Durney. A.M Borg. and e.E. Tinney (1973) RATE EFFECTS IN ISOLATED HEARTS INDUCED BY MICROWAVE IRRADIATION IEEE Trans. MicrO\vave Theory Tech, Vol 21. No 12, pp. 834-836 Lotz. W.G. and S.M. MIchaelson (1978) TEMPERATCRE AND CORTICOSTERONE RELATIONSHIPS IN MICROWAVE-EXPOSED RATS J App! PhyslO!: Respiratory. Environmental. and Exercise PhyslOl., Vol 44. No 3, pp 438-445 Lotz, W.G. and R.P. Podgorski (1982) TEMPERATURE AND ADRENOCORTICAL RESPONSES IN RHESUS MONKEYS EXPOSED TO MICROWAVES J Appl. Physio!: Respiratory. Environmental. and Exercise Physiol., Vol 53. No 6. pp 156:5-1571 Lotz. W.G (1985) HYPERTHERMIA IN RADIOFREQUENCY-EXPOSED RHESUS MONKEYS: A COMPARISON OF Sutro EIR \ references 8-90 07/03/97 Appendix B Rc!ercn.;c'- FREQUENCY AND ORIENTATION EFFECTS Radiat. Res., Vol. 102. pp 59-70 Lu. S-T., N. Lebda. S.M. Michaelson, and S. Pettit (1985) SERUM-THYROXINE LEVELS IN MICROWAVE-EXPOSED RATS Radiat. Res .. VoL 101, pp. 413-423 Lu. S.-T. and S.M Michaelson (1987) COMMENTS ON "EFFECTS OF CONTINUOUS LOW-LEVEL EXPOSURE TO RADIOFREQUENCY RADIATION ON INTRAUTERINE DEVELOPMENT IN RATS" Health Phys.. Vol. 53. No.5. p 545 Lyle. D.B. P. Schechter. W.R. Adey. and R.L Lundak (1983\ SUPPRESSION OF T-LYMPHOCYTE CYTOTOXICITY FOLLOWING EXPOSURE TO SINUSOIDALLY AMPLITUDE-MODULATED FIELDS Bioelectromagnetlcs. VoL 4. No 3. pp. 281-292 Maskarinec G. Cooper J. Sv.·yger L (1994) INVESTIGATION OF INCRESAED INCIDENCE IN CHLDHOOD LEUKEMIA NEAR RADIO TOWERS IN HAWAII: PRELIMINARY OBSERVATIONS J Environ Pathal Taxicol Oncal 13(1):33-37 Maskarinec G. Cooper J (1993) INVESTIGATION OF A CHILDHOOD LEUKEMIA CLUSTER NEAR LOW-FREQUENCY RADIO TOWERS IN HAWII (ABSTRACT) Am J Epidemiol 138(8)666 McRee. D.L PE Hamnck. and J. Zinkl (1975) SOME EFFECTS OF EXPOSURE OF THE JAPANESE QCAIL EMBRYO TO 245-GHz MICROWAVE RADIATION In PW Tyier (ed.). Ann NY Acad. SCI.. VoL 2'+7. pp. 377-390 McRee. OJ. and P.E. Hamrick (1977) EXPOSURE OF JAPANESE QUAIL EMBRYOS TO 2 45-GHz MICROWAVE RADIATION DURING DEVELOPMENT RadiaL Res .. VoL 7 L No.2. pp. 355-366 McRee. 0.1 .. G. MacNichols. and GK Livingston (1981) INCIDENCE OF SISTER CHROMATID EXCHANGE IN BONE MARROW CELLS OF THE MOUSE FOLLOWING MICROWAVE EXPOSURE RadiaL Res .. Vol. 85. pp 3'+0-348 McRee. 0.1.. IP Tha:\.'ton. and CR. Parkhurst (1983) REPRODUCTION IN MALE JAPANESE QUAIL EXPOSED TO MICROWAVE RADIATION DURING EMBRYOGENY Radial. Res.. Vol. 96. No J. pp. 51-58 Meltz. M.L. P Eagan. CR. Hams. and ON Erwin (1988) DOSIMETRY CONSIDERATIONS IN FAR FIELD MICROWAVE EXPOSURE OF MAMMALIAN Sutro EIR ref"r"nc.:s B-91 (J7!OV97 Appendi~B RefcrCI1':':' CELLS PhyslOL Chern.. Phys .. & Med. NMR. 20. pp. 23-30 Meltz. ML. P Eagan. and D.N Emin (1990) PROFLAVIN AND MICROWAVE RADIATION ABSENCE OF A MUTAGENIC INTERACTIO\ Bioelectromagnetics. VoL 11, No 2, pp. 149-157 Merritt. J.H. and JW. Frazer (1975) EFFECT OF 19 MHz RF RADIATION ON NEUROTRAJ""'J"SMITTERS IN MOUSE BRAll\; USAF School of Aerospace Medicme. Brooks AFB. Texas, Report SAM-TR-75-28 Merritt. J.H. AT Chamness. and S.J. Allen (1978) STUDIES ON BLOOD-BRAIN BARRIER PERMEABILIn' AFTER MICROWAVE-RADIATION Rad. and Environ. Biophys., VoL 15, pp. 367-377 Merritt. J.H.. W.W. Shelton. and AF. Chamness (1982) ATTEMPTS TO ALTER 45CA2+ BINDING TO BRAI1\ TISSUE WITH PULSE-MODULATED MICROWAVE ENERGY Bioelectromagnetics, VoL 3, No 4. pp. 475-478 Merritt. J.H.. 1.L Kid. and W.D. Hurt (1995) CONSIDERATIONS FOR HUMAN EXPOSURE STANDARDS FOR FAST-RISE-TIME HIGH PEAK-POWER ELECTROMAGNETIC PULSES AviaL Space. and Environ. Med.. VoL 66. No 6. pp. 586-589 Milham. S. Jr. (1983) OCCUPATIONAL MORTALITY IN WASHINGTON STATE: 1950-1979 DHHS (NIOSH) Publication No 83-116. October 1983. Contract No. 210-80-0088. US Department of Health and Human ServIces. National Institute for OccupatIonal Safety and Health. Cmcinnati. Ohio MIlham. S.. Jr (1985) SILENT KEYS: LEUKAEMIA MORTALITY IN AMATEUR RADIO OPERATORS Lancet. No. 8432. 6 April 1985. p. 812 Milham. S .. Jr. (1988a) INCREASED MORTALITY IN AMATEUR RADIO OPERATORS DUE TO LYMPHATIC AND HEMATOPOIETIC MALIGNANCIES Am. J. Epidem.. Vol. 127, No. L pp 50-54 Milham. S. Jr. (1988b) MORTALIn" BY LICENSE CLASS IN AMATEUR RADIO OPERATORS Am. 1. Epidcm.. VoL 128. No 5. pp. 1175-l176 Mitchell. c.L.. Dl. McRee. N.J. Peterson. and H.A Tilson (1988) SOME BEHAVIORAL EFFECTS OF SHORT-TERM EXPOSURE OF RATS TO 2.45 GHZ MICROWAVE RADIATION Bloelectromagnetics. Vol 9. No 3. pp 259-268 Sutro EIR\ references B-92 0703/97 Appendix B: References Miura, M., K. Takavama, and J. Okada (1993) INCREASE IN NITRIC OXIDE AND CYCLIC GMP OF RAT CEREBELLUM BY RADIO FREQUENCY BURST-lYPE ELECTROMAGNETIC FIELD RADIATION J. Physio!.. Vol. 461, pp. 513-524 Monahan, J.c. and H.S. Ho (1976) MICROWAVE INDUCED AVOIDANCE BEHAVIOR IN THE MOUSE In c.c. Johnson and M.L. Shore (eds.), BIOLOGICAL EFFECTS OF ELECTROMAGNETIC WAVES, U.S. Dept. of Health, Education, and Welfare, Washington, D.C., HEW Publication (FDA) 77-8010, Vol I, pp. 274-283 Myers, R.D. and D.H. Ross (1981) RADIATION AND BRAIN CALCIUM: A REVIEW AND CRITIQUE Neurosci. Biobehav. Rev" Vol. 5, No.4, pp 503-543 National Research Council (1996) POSSIBLE HEALTH EFFECTS OF EXPOSURE TO RESIDENTIAL ELECTRIC AND MAGNETIC FIELDS COmmIttee on the Possible Effects ofElectromagnetic Fields on Biologic Systems, National Aca.demy Press, Washington, DC. 337 pages Na\\Tot. PS., DJ. McRee, and R.E. Staples (1981) EFFECTS OF 2.45 GHz CW MICROWAVE RADIAnON ON EMBRYOFETAL DEVELOPMENT IN MICE Teratology. Vol. 24, No.3. pp. 303-314 NCRP (1986) BIOLOGICAL EFFECTS AND EXPOSURE CRITERIA FOR RADIOFREQUENCY ELECTROMAGNETIC FIELDS Report No. 86, NCRP Publications, Bethesda, MD 20814 Neilly, J.P. and J.c. Lin (1986) INTERACTION OF ETHANOL AND MICROWAVES ON THE BLOOD-BRAIN BARRIER OF RATS Bioelectromagnetics, Vol. 7, No.4, pp. 405-414 Okerst. R.B. and J.R. Rabinowitz (1978) STUDIES ON THE INTERACTION OF MICROWAVE RADIAnON WITH CHOLINESTERASE Radial. Environ Biophys., Vol 15, pp. 289-295 Olsen, R.G. and W.c. Hammer (1982) THERMOGRAPHIC ANALYSIS OF WAVEGUIDE-IRRADLATED INSECT PUPAE Radio Sci., Vol. 17, No. 5S, pp. 95-104 Ortner. M.L MJ. Galvin, and D.1. McRee (1981) STUDIES ON AClrrE IN HVO EXPOSURE OF RATS TO 2450-MHz MICROWAVE RADIATION 1. MAST CELLS AND BASOPHILS Radiat. Res" Vol. 86, pp. 580-588 Sutro EIR. refcrences B-93 0703'97 Appendix B: References Oscar, KJ. and TO. Hawkins (1977) MICROWAVE ALTERATION OF THE BLOOD-BRAIN BARRIER SYSTEM OF RATS Brain Res.. Vol. 126, pp. 281-293 Ouellet-Hellstrom, R. and W.F. Stewart (1993) MISCARRIAGES AMONG FEMALE PHYSICAL THERAPISTS WHO REPORT USING RADIO AND MICROWAVE-FREQUENCY ELECTROMAGNETIC RAnIATION Am. J. EpidemioL Vol. 138. No. 10, pp. 775-786 Pakhomov A. G, Dubovick B. V, Degtyariov I. G, Pronkevich A. N (1995) MICROWAVE INFLUENCE ON THE ISOLATED HEART FUNCTION I. EFFECT OF MODULATION Bioelectromagnetics 16(4):241-249 Pappas. B.A.. H. Anisman, R. lngs. and D.A. Hill (1983) ACUTE EXPOSURE TO PULSED MICROWAVES AFFECTS NEITHER PENlYLENETETRAZOL SEIZURES IN THE RAT NOR CHLORDIAZEPOXIDE PROTECTION AGAINST SUCH SEIZURES Radial. Res., Vol. 96, No.3, pp 486-496 Pay. TL., E.C. Beyer, and C.F. Reichelderfer (1972) MICROWAVE EFFECTS ON REPRODUCTIVE CAPACIn' AND GENETIC TRANSMISSION IN DROSOPHILA MELANOGASTER J. MicrO\....ave Power. Vol. 7, No.2. pp. 75-82 Peacock PB., J.W. Simpson. CA. Alford, Jr. and F. Saunders (1971) CONGENITAL ANOMALIES IN ALABAMA 1. Med. Assoc. Ala.. Vol. 41. No. I. pp. 42-50 Peacock. P.B., S.R. Williams. and E. Nash (1973) RELATIONSHIP BETWEEN THE INCIDENCE OF CONGENITAL ANOMALIES AND THE USE OF RADAR IN MILITARY BASES Final Report Report No. III. Project No. 3118. November 1973. Contract No. 68-02-0791 submitted by Southern Research Institute to EPA (unpublished) Penafiel LM, Litovitz T Kruase D. Dest A, Mullins JM (1997) ROLE OF MODULATION ON THE EFFECT OF MICOWAVES ON ORNITHINE DECARBOXY"LASE ACTIVITI' IN L929 CELLS BlOelectromagnetics 18(2): 132- 14 1 Peterson. OJ.. L.M. Partlow, and O.P. Gandhi (1979) AN INVESTIGATION OF THE THERMAL AND ATHERMAL EFFECTS OF MICROWAVE IRRADlATION ON ERYTHROCYTES IEEE Trans. Biomed. Eng.. Vol. 26. No.7. pp. 428-436 Phillips. R.D.. E.L. Hunt. R.D Castro. and NW. King (1975) THERMOREGULATORY, METABOUC. AND CARDIOVASCULAR RESPONSE OF RATS TO MICROWAVES J Appl. PhYSIOL Vol. 38. No.4. pp. 630-635 Sutro EIR references B-94 07'03/97 Appendix B Referen.::.:> Pickard. W.F. and R.G. Olsen (1979) DEVELOPMENTAL EFFECTS OF MICROWAVES ON TENEBRIO: INFLUENCES OF CULTURING PROTOCOL AND OF CARRIER FREQUENCY Radio Sci .. Vol 14. No. 6S. pp. 181-185 Polson. P. and J.H. Merritt (1985) CANCER MORTALITY AND AIR FORCE BASES A REEVALUAnON J. Bioelectricity. Vol. 4, No.1, pp 121-127 Prasad. AV.. M.W Miller. E.L Carstensen. Ch Cox. M. AzadnIV. and A.ABra~man(1991) FAlLURE TO REPRODUCE INCREASED CALCIUM UPTAKE IN HUMAN LYMPHOCYTES AT PURPORTED CYCLOTRON RESONANCE EXPOSURE CONDITIONS Radiat Environ. Biophys. Vol 30. pp 305-320 Prausnitz. S and C. Susskind (1962) EFFECTS OF CHRONIC MICROWAVE IRRADLJ\TION ON MICE IRE Trans. Bio-Med. Electron.. pp. 104-108 Presrnan. A.S. and N.A Levitina (1963a) NONTHERMAL ACTION OF MICROWAYES ON CARDIAC RHYTHM--COMMUNICATION I A STUDY OF THE ACTION OF CONTINUOUS MICROWAVES Bull. Exp. BioI. Med.. Vol. 53. No. 1, pp. 36-39, (Engl. Transl. ofpp. 41-44 of 1962a Russ. pub\.) Presman. AS and N.A Levitma (l963b) NONTHERMAL ACTION OF MICROWAVES ON THE RHYTHM OF CARDIAC CONTRACTIONS IN ANIMALS--REPORT II. INVESTIGATION OF THE ACTION OF IMPULSE MICROWAVES Bull. Exp BioI Med.. Vol 53. No 2. pp. 154-157 (Engl Transl ofpp 39-43 of 1962b Russ pubU Preston. E.. EJ. Vavasour. and H.M Assenheim (1979) PERJv1EABILITI' OF THE BLOOD-BRAIN BARRIER TO MA!'.'NITOL IN THE RAT FOLLOWING 2450 MHz MICROWAVE IRRA.DlATION Brain Res. Vol. 174. pp. 109-117 Preston. E. and G Prefontainc (1980) CEREBROVASCULAR PERMEABILITY TO SUCROSE IN THE RAT EXPOSED TO 2.450-MHz MICROWAVES 1. Appl. Physio\.:Respirato~.Environmental. and ExerCIse Physio\. Vo\. 49. No.2. pp 218-223 Ray. S. and J. Behari (1990) PHYSIOLOGICAL CHANGES IN RATS AFTER EXPOSURE TO LOW LEVELS OF MICROWAVES Radial. Res. Vol. 123. No.2. pp. 199-202 Reed. J.R.III. J.L Lords, and C.H. Durney (1977) MICROWAVE IRR>\DIATION OF THE ISOLATED RAT HEART AFTER TREATMENT WITH ANS BLOCKING AGENTS Radio Sci. Vol. 12. No 6S. pp. 161-165 Repacholi MH. Basten A. Gebski C, Noonan D. Finnie 1. Harris AW (1997) LYMPHOMAS INE~-PIMI TRANSGENIC MICE EXPOSED TO PULSED 900 MHZ Sutro EIR' rderences B-95 07/03 1 97 ELECTROMAGNETIC FIELDS Radiation Research 147:631-640 Roberts. NJ.Jr and S.M. Michaelson (1983) MICROWAVES AND NEOPLASIA IN MICE: ANALYSIS OF A REPORTED RISK Health Phys .. Vol. 44, No.4, pp. 430-433 Roberts, NJ.Jr, S.-T. Lu. and S.M. Michaelson (1983) HUMAN LEUKOCYTE FUNCTIONS AND THE U. S. SAFETY STi\NDARD FOR EXPOSURE TO RADIO-FREQUENCY RADIATION SCience. Vol. 220,15 April 1983, pp. 318-320 Roberts. NJJr.. S.M. Michaelson. and S.-T. Lu (1987) MITOGEN RESPONSIVENESS AFTER EXPOSURE OF INFLUENZA VIRUS-INFECTED HUMAN MONONUCLEAR LEUKOCYTES TO CONTINUOUS OR PULSE-MODULATED RADIOFREQUENCY RADIATION Radial. Res .. Vol. 110. No.3. pp 353-361 Robinette, C.D. and C. Silverman (1977) CAUSES OF DEATH FOLLOWING OCCUPATIONAL EXPOSURE TO MICROWAVE R-\DIATION (RADAR) 1950-1974 In D.G. Hazzard (ed.), SYMPOSIUM ON BIOLOGICAL EFFECTS AND MEASUREMENT OF RADIOFREQUENCYIMICROWAVES, Dept. of Health. Education. and Welfare. Washington. DC. HEW Publication No. (FDA) 77-8026 Rugh. R.. E.!. Ginns, H.S. Ho. and W.M. Leach (1974) ARE \1ICROWAVES TERATOGENIC) In P Czerski. K. Ostrowski. ML Shore. C. Silverman. MJ Suess. and B Waldeskog (eds.). BIOLOGIC EFFECTS AND HEALTH HAZARDS OF MICROWAVE RADIATION, Polish Medical Publishers. Warsaw. pp 98-107 Rugh. R. E.I. Ginns. H.S. Ho. and W.M Leach (1975) RESPONSES OF THE MOUSE TO MICROWAVE RADIATION DURING ESTROUS CYCLE AND PREGNANCY Radlat. Res .. Vol. 62, pp. 225-241 Saito, K.. K. Suzuki, and S. Motoyoshi (1991) LETHAL AND TERATOGENIC EFFECTS OF LONG-TERM LOW-INTENSITY RADIO FREQUENCY RADIATION AT 428 MHz ON DEVELOPlNG CHICK EMBRYO Teratology. Vol. 43, pp. 609-614 Salford. L.G., A Brun. K. Sturesson. J.L. Eberhardt. and BR.R. Persson (1994) PERMEABILITY OF THE BLOOD-BRAIN BARRIER lNDUCED BY 915 MHz ELECTROMAGNETIC RADIATION. CONTINUOUS WAVE AND MODULATED AT 8.16.50. AND 200 Hz Microscopy Research and Technique. VoU7. pp 535-542 Sanders, A.P .. OJ. Schaefer, and WT. Joines (1980) MICROWAVE EFFECTS ON ENERGY METABOLISM OF RAT BRAIN Bioelectromagnetics, Vol. I. No.2, pp 171-181 Sutro EIR\ references B-96 07/03/97 Append!.\: BRcfcrcll~~' Sanders. A.P. and WT. Joines (1984) THE EFFECTS OF HYPERTHERMIA AND HYPERTHERMIA PLUS MICROWAVES ON RAT BRAIN ENERGY METABOLISM BlOelectromagnctics. Vol. 5. No.1. pp. 63-70 Sanders, A.P., W.T. Joines, and JW. Allis (1984) THE DIFFERENTIAL EFFECTS OF 200. 591. AND 2.450 MHz RAnIATION ON RAT BRAIN ENERGY METABOLISM Bioclectromagnetics, Vol. 5, No.4. pp. 419-433 Sanders. A.P., WT. Joines. and JW. Allis (1985) EFFECTS OF CONTINUOUS-WAVE. PULSED. AND SINUSOIDAL-AMPLITUDE-MODVLATED I\IICROWAVES ON BRAINE~ERGYMETABOLISM Bioclectromagnctics, Vol. 6. No I. pp. 89-97 Sandweiss. J (1990) ON THE CYCLOTRON RESONANCE MODEL OF ION TRANSPORT BlOelectromagnetics. Yol. 11. No 2, pp 203-205 Santini. R., M Hosru. P Deschaux. and H. Pacheco (1988) BI6 MELANOMA DEVELOPMENT IN BLACK MICE EXPOSED TO LOW-LEVEL MICROWAVE RADIATION Bioeiectromagnetics. Vol. 9. No. I. pp. 105-107 Sarkar. S. S Ali. and J. Behari (1994) EFFECT OF LOW POWER MICROWAVE ON THE MOl'SE GENOME. A DIRECT DNA ANALYSIS ;v1utation Res. Yo\. 320. Nos. 1-2. pp 141-147 ScholL D.M and SJ Allen (\ 9 7 9) SKILLED VISUAL-MOTOR PERFORMANCE BY MONKEYS IN A 1.2-GHz MICROWAVE FIELD RadIO Sci .. VoL 14. No 6S. pp 247-252 Schroe J.. J.R. Thomas. and R.A Banvard (1980) MODIFICATION OF THE REPEATED ACQUISITIOI\ OF RESPONSE SEQUENCES IN RATS B'r' LOW-LEVEL MICROWAVE EXPOSURE Bioelectromagnetics, Va\. I. No I. pp 89-99 Schwartz. JL. J Delorme. and G.AR. Mealing (1983) [ABSTRACT! EFFECTS OF LOW-FREQUENCY AMPLITUDE MODl'LATED RADIOFREQUENCY WAYES ON THE CALCIUM EFFLUX OF THE HEART BlOphys. L Vol 41. p. 295a Schwartz J-L. House DE.. and Mealing GAR (1990) EXPOSURE OF FROG HEARTS TO CW OR AMPLITUDE-MODULATED VHF FIELDS SELECTIVE EFFLUX OF CALCIUM IONS AT 16 HZ Bioelectromagnetics 11(4):349-358 Schwartz J-L and Mealing G.A.R. (1993) CALCIUM-ION MOVEMEJ\T AND CONTRA.CTILITY IN ATRIAL STRIPS OF FROG-HEART SUlro EIR rcfc-r"n"", B-97 07;03197 Appendix B· Rcfcrcn::cs ARE NOT AFFECTED BY LOW-FREQUENCY-MODULATED, 1 GHZ ELECTROrvl<\GNETIC RADIATION Bioelectromagnetics 14(6):521-533 Seaman RL. DeHaan RL, (1993) INTER-BEAT ll\TERVALS OF CARDIAC-CELL AGGREGATES DURING EXPOSURE TO 245 GHZ CWo PULSED, AND SQUARE-WAVE-MODULATED MICROWAVES Bloelectromagnetics 14(1 ):41-55 Selvin S, Schulman 1, Merrill OW (1992) DISTANCE AND RISK MEASURES FOR THE ANALYSIS OF SPATIAL DATA: A STUDY Of CHILDHOOD CANCERS. Soc Sci Med 34(7):769-77. Shacklett. D.E., TJ. Tredici. and D.L. Epstein (1975) EVALUATION OF POSSIBLE MICROWAVE-INDUCED LENS CHANGES IN THE UNITED STATES AIR FORCE Aviation. Space. and Environ Med.. November 1975. pp 1403-1406 Shelton. W.W., Jr. and J.H. Merritt (1981) IN~7TROSTUDY OF MICROWAVE EFFECTS ON CALCIUM EFFLUX IN RAT BRAIN TISSUE Bioelectromagnetics, Vol 2, No 2. pp. 161-167 Sherry. C.J .. D.W. Blick. T.J. Walters. G.c. BrO\"l1. and MR. Murphy (1995) LACK OF BEHAVIORAL EFFECTS IN NON-HUMAN PRIMATES AFTER EXPOSURE TO CLTRAWlDEBAND ELECTROMAGNETIC RADIATlON IN THE MICROWAVE FREQUENCY RANGE RadiaL Res .. Vol 143. pp 93-97 Shore. l\1.L.. R.P. Felten. and A. Lamanna (1977) THE EFFECT OF REPETITIVE PRENATAL LOW-LEVEL MICROWAVE EXPOSURE ON DEVELOPMENT IN THE RAT In D.G. Hazzard (ed.), SYMPOSIUM ON BIOLOGICAL EFFECTS AND MEASUREMENT OF RADIO FREQUENCY/MICROWAVES, U.S Department of Health. Education. and Welfare. HEW Publication (FDA) 77-8026. pp 280-289 Skidmore. W.O. and S.J Baum (1974) BIOLOGICAL EFFECTS IN RODENTS EXPOSED TO 10 MILLION PULSES OF ELECTROMAGNETIC RADIATION Health Phys. Vol 26, No.5, pp. 391-398 SmialoWlcz. R.J. (1976) THE EFFECT OF MICROWAVES (2450 MHz) ON LYMPHOCYTE BLAST TRANSFORMATION IN VITRO In c.c. Johnson and M.L Shore (eds.). BIOLOGICAL EFFECTS OF ELECTROMAGNETIC WAVES, US Dept. of Health. Education. and Welfare. HEW Publication (FDA) 77-8010. Vol L pp. 472-483 Smialowlcz. R.L C.M Wei!. P Marsh. M.M RJddlc. R.R Rogers. and B.F Rehnberg (1981) BIOLOGICAL EFFECTS OF LONG-TERM EXPOSURE OF RATS TO 970-MHz Sutro ElR references B-98 07/03/97 Appendix B Rcfcrca.::c' RADIOFREQUENCY RADIATION Bioelectromagnetics. Vol. 2. No.3, pp. 279-284 Smialowicz. R.J .. M.M. Riddle. R.R. Rogers. and G.A Stott (1982a) ASSESSMENT OF IMMUNE FUNCTION DEVELOPMENT IN MICE IRRADIATED IN LITERO WITH 2450-MHz MICROWAVES J. Microwave Power, Vol. 17. No.2, pp. 121-126 Smialowicz. R.L e.M. Weil, J.B. Kinn. and 1.A Elder (1982b) EXPOSURE OF RATS TO 425-MHz (CW) RADIOFREQUENCY RADlATION EFFECTS 01\ LYMPHOCYTES 1. Microwave Power. Vol. 17. No.3. pp. 211-221 Smialowicz. RJ., RR Rogers, RJ. Gamer, M.M. Riddle, RW. Luebke. and D.G. Rowe (1983) MICROWAVES (2.450 MHz) SUPPRESS MURINE NATURAL KILLER CELL ACTIVITi Bioelectromagnetics. Vol. 4. No 4. pp 371-381 Somosy. Z.. G. Thuroczy, T. Kubasova. 1. Kovacs. and L.D. Szabo (1991) EFFECTS OF MODULATED AND CONTINUOUS MICROWAVE IRRADIATION ON THE MORPHOLOGY AND CELL SURFACE NEGATIVE CHARGE OF 3T3 FIBROBLASTS Scanning MICroscopy. Vol. 5. No.4. pp. 1145-1155 Spiers, D.E. and S.e. Baummer (1991) THERMAL AND METABOLIC RESPONSIVENESS OF JAPANESE QUAIL EMBRYOS FOLLOWING PERIODIC EXPOSURES TO 2.450-MHz MICROWAVES Bioelectromagnetics. Vol 12. No.4. pp. 225-239 State of Hawaii Department of Health. Environmental Epidemiology Program ( 1986) CANCER INCIDENCE IN CENSUS TRACTS WITH BROADCSTING TOWERS IN HONOLULl:. HAWAII Report to the City Council. City and County of Honolulu. HawaJl Stavinoha, W.B., A Modak. M.A Medina, and AE. Gass (1975) GROWTH AND DEVELOPMENT OF NEONATAL MICE EXPOSED TO HIGH-FREQUENCY ELECTROMAGNETIC WAVES USAF School of Aerospace Medicme. Brooks AFB. Texas: Fmal Report SAM-TR-75-51 on Contract F41609-74-C-OOI8. submitted by University ofTexas Health SCIence Cemer. San Antonio. Texas Stern. S.. L. Margolin. B. Weiss. S-T Lu. and S.M Michaelson (1979) MICROWAVES: EFFECT ON THERMOREGULATORY BEHAVIOR IN RATS SCience. Vol. 206. 7 December 1979. pp 1198-1201 Stevens. KG. (1987) ELECTRIC POWER USE AND BREAST CANCER A HYPOTHESIS Am. 1. EpidemioL Vol. 125. pp 556-561 Stewart-DeHaan. P.L M.O. Creighton. LE Larsen. J.H JacobI, M. Sanwal. J.e. Baskerville. and JR Trevithick (1985) Sutro EIR· references B-99 07103/97 Appendix B Rcfcrcr;;.:c, IN 17TRO STUDIES OF MICROWAVE-INDUCED CATARACT RECIPROCITY BETWEEN EXPOSURE DURATION AND DOSE Rf\TE FOR PULSED MICROWAVES Exp. Eye Res .. Vol. 40. pp. 1-13 Sulek. K .. C.J. Schlagel. W. Wiktor-Jedrzejczak. H.S Ho. W M Leach. A Ahmed. and J.NWood~ (1980) BIOLOGIC EFFECTS OF MICROWAVE EXPOSURE: I THRESHOLD CONDITIONS FOR THE INDUCTION OF THE INCREASE IN COMPLEMENT RECEPTOR POSITIVE (CR+) MOUSE SPLEEN CELLS FOLLOWING EXPOSURE TO 2450-MHz MICROWAVES Radiat. Res. Vol. 83, pp 127-137 Sultan. MY, CA. Cain. and W.A.F. Tompkins (1983a) EFFECTS OF MICROWAVES AND HYPERTHER.,\1IA O,\; CAPPING OF ANTIGEN-ANTIBODY COMPLEXES ON THE SURFACE OF NORMf\L MOUSE B LYMPHOCYTES Bioelectromagnetics. Vol. 4, No 2. pp. 115-122 Sultan. M.F., CA Cain. and W.A.F. Tompkins (l983b) IMMUNOLOGICAL EFFECTS OF AMPLITUDE-MODULATED RADIO FREQUENCY RADIATION: B LYMPHOCYTE CAPPING Bioelectromagnetics. Vol. 4, No 2. pp. 157-165 Swicord. M.L. and CC Davis (1983) AN OPTICAL METHOD FOR INVESTIGATING THE MICROWAVE ABSORPTION CHARACTERISTICS OF DNA AND OTHER BIOMOLECULES IN SOLUTION BlOc!ectromagnctlcs. Vol. 4. No I. pp. 21-42 Sznuglelski. S . A Szudzinski. A Pietraszek. M Biclec. M JanIak. and 1.1'. Wrembel (1982) ACCELERATED DEVELOPMENT OF SPONTANEOUS AND BENZOPYRENE-INDUCED SKIN CANCER IN MICE EXPOSED TO 2450-MHz MICROWAVE RADIATION Bloclecrromagnetlcs. VoL 3. No 2. pp. 179-ILll Szmigielski S. Bielec M. Lipski S. Sokolska G (1988) IMMUNOLOGIC AND CANCER-RELATED ASPECTS OF EXPOSURE TO LOW-LEVEL MICROWAVE AND RADIOFREQUENCY FIELDS (CHAPTER 25) In Marino AA (cd): "Modem Bioelectricity" New York Marcel Dekker 861-925 Szmlglelski S (1996) CANCER MORBIDITY IN SUBJECTS OCCUPATIONALLY EXPOSED TO HIGH FREQUENCY (RADIOFREQUENCY AND MICROWAVE) ELECTROMAGNETIC RADIATION The Science of the Total Environment 180:9-17 Szudzinskl A. Pietraszek A. Janiak M. Wrembel J. Kalczek M. Szmiglclski S (1982) ACCELERATION OF THE DEVELOPMENT OF BENZOPYRENE-INDUCED SKIN CANCER IN MICE BY MICROWAVE RA.DIATION Arch Dt:nnatol Res 274303-312 Takashima. S.. B Onaral. and H.P. Schwan (1979) EFFECTS OF MODULATED R.F ENERGY ON THE EEG OF MAMMALIAN BRAINS Rad and Environ. Biophys.. VoL 16. pp. 15-27 Sulra EIR references B-I00 07llJ3/97 Append!\ BRcl;;,~:;.;:,> Taskinen. H.. P. Kvvronen. and K. Hemminki (1990) EFFECTS OF UL1iASOUND. SHORTWAVES. AND PHYSICAL EXERTION ON PREGNAl\CY OUTCOME IN PHYSIOTHERAPISTS J Epidemiol. Community Health. Vol. 44. pp 196-201 Thomas. J.R. and G. Maitland (1979) MICROWAVE RADIAnON AND DEXTROAMPHETAMINE EVIDENCE OF COMBINED EFFECTS ON BEHAVIOR OF RATS RadIO SCI. Vol. 14. No. 6S, pp. 253-258 Thomas. l.R.. L.S. Burch. and SS Yeandle (1979) MICROWAVE RADIATION AND CHLORDIAZEPOXIDE SYNERGISTIC EFFECTS ON FIXED INTERVAL BEHAVIQR SCience. Vol. 203. pp 1357-1358 Thomas. J.R.. l. Schrot. and R.A. Banvard (1980) BEHAVIORAL EFFECTS OF CHLORPROMAZINE AND DIAZEPAM COMBINED WITH LO\\" LEVEL MICROWAVES Neurobehav. Toxico!' Vol. 2. pp 131-135 Thomas. T.L.. P.D. Stolley. A. Sternhagen. ETH Fontham. ML Bleecker. PA. Stewart. and Rl\ Hoover (1987) BRAIN TUMOR MORTALITY RISK AMONG MEN WITH ELECTRICAL AND ELECTRONICS JOBS A CASE-CONTROL STUDY J Nat. Cancer Inst.. Vol 79. No 2. pp 233-238 Tinney. CE.. JL Lords. and CH Durney (1976) RATE EFFECTS IN ISOLATED TURTLE HEARTS INDUCED BY MICROWAVE IRRADIATION IEEE Trans Mlcro\\ave Thea,", Tech.. Vol 24. No. I. pp 18-24 Tofani. S.. G. Agnesod. P. Ossola. S Femni. and R. Bussl (1986) EFFECTS OF CONTINUOUS LOW-LEVEL EXPOSURE TO RADIOFREQUENCY RADIATION ON INTRAUTERINE DEVELOPMENT IN RATS Health Phys .. Vol. 51. No.4. pp 489-499 Toler, J.? V. Popovic. S Bonasera. P. Popovic. C. Honeycutt. and D. Sgoutas (1988) LONG-TERM STUDY OF 435 MHz RADIO-FREQUENCY RADIATION ON BLOOD-BORNE END POINTS IN CANNULATED RATS--PART II METHODS. RESULTS AND SUMMARY J Microwave Power & EM Energy, Vol. 23. No 2. pp 105-136 Tyazhelov. \lV., R.E. Tigranian. E.O. Khizhmak. and IG Akoev (1979) SOME PECULIARITIES OF AUDITORY SENSATIONS EVOKED BY PULSED MICROWAVE FIELDS Radio Sci .. Vol 14. No. 6S, pp 259-263 T~nes.T. and A. Andersen ( 1990) ELECTROMAGNETIC FIELDS AND MALE BREAST CANCER Lancet. Vol. 336. No. 8730. P 1596 Su\ro EIR· reference<; B-IO I 07/03/97 Appendix B Ref;2r,::nccc Vanna, M.M. and EA. Traboulay. Jr. (1976) EVALUATION OF DOMINANT LETHAL TEST AND DNA STUDIES IN MEASURING MUTAGENICITY CAUSED BY NON-IONIZING RADIATION In c.c. Johnson and M.L Shore (cds.), BIOLOGICAL EFFECTS OF ELECTROMAGNETIC WAVE5i. LIS Dept. ofHealth, Education. and Welfare, Washmgton, DC. HEW PublicatIOn (FDA) 77-lWIU. \01 L pp. 386-396 Walters, T.L P.A. Mason. CJ. Sherry. C. Steffen, and JH Merritt (1995) NO DETECTABLE BIOEFFECTS FOLLOWING ACUTE EXPOSURE TO HIGH PEAK POWER ULTRA-WIDE BAND ELECTROMAGNETIC RADIATION IN RATS AnaL Space. and Environ. Med.. VoL 66. NO.6. pp. 562-567 \Vangler, RB.. P.M. Bradley, W.D. Clift, D. Davidson, L Higgms. K. Sandstrom, and R. Stephens (l Cl85) LEUKAEMIA RISK IN AMATEUR RADIO OPERA.TORS Lancet. 29 June 1985, p. 1516 Ward. TR. and J.S. Ali (1985) BLOOD-BRAIN BARRIER PERMEATION IN THE RAT DURING EXPOSURE TO LOW-POWER 1.7-GHz MICROWAVE RADIATION Bioelectromagnetics. VoL 6. No 2, pp. 131-143 Webb, SJ. and D.D. Dodds (1968) INHIBITION OF BACTERIAL CELL GROWTH BY 136 GC MICROWAYES Nature. Vol 218. pp. 374-375. 27 April 1968 Webb. SJ. and A.D. Booth (1969) ABSORPTION OF MICROWAVES BY MICROORGANISMS Nature. VoL 222.21 June 1969. pp. 1199-1200 Webb. SJ and ME Stoneham (1977) RESONANCES BETWEEN 100 AND 1000 GHz IN ACTIVE BACTERIAL CELLS AS SEEN BY LASER RAMAN SPECTROSCOPY Phys. Lett.. VoL 60A. No.3, pp 267-268 Webb. S.L ME Stoneham. and H Frohlich (1977) EVIDENCE FOR NON-THERMAL EXCITATION OF ENERGY LEVELS IN ACTIVE BIOLOGICAL SYSTEMS Phys. Lett.. VoL 63A, No.3. pp. 407-408 WHO (1981) RADIOFREQUENCY AND MICROWAVES World Health Organization EnVIronmental Health Criteria 16 Wik'tor-Jedrzcjczak. W .. A. Ahmed. P Czerski, WM Leach. and K.W. Sell (1977) IMMUNE RESPONSE OF MICE TO 2450-MHz MICROWAVE RADIATION OVERVIEW OF IMMUNOLOGY AND EMPIRJCAL STUDIES OF LYMPHOlD SPLENIC CELLS Radio Sci. VoL 12. No. 6S. pp 209-219 Sulro EIR· references B-I02 07103/97 AppendIx B Reler;:nc.> Williams. W.M .. W. Hoss. M. Formaniak and S.M. Michaelson (l984a) EFFECT OF 2450 MHz MICROWAVE ENERGY ON THE BLOOD-BRAIN BARRIER TO HYDROPHILIC MOLECULES. A. EFFECT ON TIIE PERME..<\BIUn' TO SODIUM FLUORESCEIN Bram Res. Rev .? Vol. 7. pp. 165-170 Williams. W.M .. M. del Cerro. and S.M. Michaelson (l984b) EFFECT OF 2450 MHz MICROWAVE ENERGY ON THE BLOOD-BRAIN BARRIER TO HYDROPHILIC MOLECULES B. EFFECT ON THE PERMEABILITY TO HRP Bram Res Rev. Vol. 7. pp 171-18\ Williams. W.M .. 1. Platner. and S.M. Michaelson (l984c) EFFECT OF 2450 MHz MICROWAVE ENERGY ON THE BLOOD-BRAIN BARRIER TO HYDROPHILIC MOLECULES. C. EFFECT ON THE PERMEABILITY TO [14CJ SUCROSE Brain Res. Rev .. Vol. 7. pp. 183-190 Williams. W.M.. S.-T. Lu. M del Cerro. and S.M Michaelson (l984d) EFFECT OF 2450 MHz MICROWAVE ENERGY ON THE BLOOD-BRAIN BARRIER TO HYDROPHILIC MOLECULES D BRAIN TEMPERATURE AND BLOOD-BRAIN BARRJER PERMEABILITY TO HYDROPHILIC TRACERS BraIn Res Rev .. Vol. 7. pp 19\-212 Wong. L.S. and N.S. Allen (1985) EFFECTS OF RADIOFREQUENCY ELECTRIC FIELDS ON CYTOPLASMIC STREAMING IN NITELLA Ennron Experim. Botany. Vol. 2:5. No. 1. pp. 17-22 Wood AW. Lubinas V.Jo~nerKH. Hocking BA (1992) CALCIUM EFFLUX FROM TOAD HEART A REPLICATION STUDY In Blank M (ED) "Elccrficlty And MagnetIsm In BloIog:- And l\kdlcmc" San Francisco San FranCISCo Press. Inc 482-484 Wu. KY.. H. Chiang. BJ. Shao. N.G. Li. and Y.D. Fu (1994) EFFECTS OF 245-GHz MICROWAVE RADIATION AND PHORBOL ESTER 12-0-TETRA.-DECANOYLPHORBOL-13-ACETATE ON DIMETHYLHYDRAZINE-INDUCED COLON CANCER IN MICE Bioclcctromagnetics. Vol. 1:5. No 6. pp. 531-538 Ycc. K.-C. C-K Chou. and AW Guy (1984) EFFECT OF MICROWAVE RADIATION ON THE BEATING RATE OF ISOLATED FROG HEARTS Bioelectromagnetics. Vol. :5. No 2. pp. 263-270 Zakharova. N.M .. S.l. Alckseyc\'. and MN Zhadin (1993) EFFECT OF ULTRAHIGH FREQUENCY RADIATION ON THE SPONTANEOUS IMPULSE ACTIVITY OF SURVIVING CEREBRAL CORTEX SLICES Biophys .. Vol. 38. No.3. pp. 52\-525 [Transl. ofBiofizika. Vol 38. No 3. pp. 520-523 (1993») Sulro EIR· references B-I03 0703197 Zaret. M.M (1974) CATARACTS FOLLOWING USE OF MICROWAVE aVE\: NY State J. Med.. Vol. 74. No. I L pp. 2032-2048 Append!\: B RcfcfCI1. _. SUlrO EIR' reference<; B-I04 07 '01197 SUlr0 appendices APPENDLX C: EIR REQUIREMENT C-l 8.0 Appendices 07/()6/97 NOTICE THAT AN ENVIRONMENTAL IMPACT REPORT IS DETERMThi'ED TO BE REQUIRED Date of this Notice: March 15, 1997 Lead Agency: Planning Department, City and County of San Francisco 1660 Mission Street Street - 6th Floor, San Francisco, CA 94103-2414 Agency Contact Person: Paul Maltzer Project Title: 96.544E· Sutro Tower Digital Television Antennas Project Contact Person: Debra Stein, GCA Strategies Telephone: (415) 558-6391 Project Sponsor: Sutro Tower, Inc. / Project Address: At Sutro Tower, on top of Mount Sutro Assessor's Block(s) and Lot(s): 2724/3 City and County: San Francisco Project Description: Proposed addition of a new 125-foot-long beam, with digital television antennas attached. to Sutro Tower. The existing Sutro Tower reaches a maximum height of about 975 feet. The proposed new beam and antennas would be attached to the tower between the north and south legs, on the east face. at a height ranging from about 630 feet to 755 feet above ground. The project is proposed in response to a Federal Communications Commission mandate that commercial television broadcast stations shift to DIgital Television signal transmission as the next generation of technology for television broadcasting. The proposed antennas would be subject to a Discretionary Review hearing by the City Planning Commission. THIS PROJECT MAY HAVE A SIGNIFICANT EFFECT ON THE ENVIRONMENT AND AN E!'iVIROi'ol\1E1\'TAL IMPACT REPORT IS REQUIRED. This determination is based upon the criteria of the Guidelines of the State Secretary for Resources, Section 15063 (Initial Study), 15064 (Determining Significant Effect), and 15065 (Mandatory Findings of Significance), and the following reasons, as documented in the Environmental Evaluation (Initial Study) for the project, which is attached. Deadline for Filing of an Appeal to the City Planning Commission of this Determination that an EIR is ~equire..,d:April~,1997. An appeal requires: 1) a letterspec~fyi~&whyan E should not be prepared, and; ~)a $_09.00 fillng fee. . / /_~=1H~::::::-- ( HiHaty E. Gi\..clman Environmental Review Officer 96.544E· SUTRO TOWER DIGITAL TELEVISION ANTENNAS SUMMARY OF POTENTIALENVIR01'l~1ENTALEFFECTS The proposed project, as described in the attached Notice. is the addition of a new 125-foot-long beam, with new Digital TV Antennas, near the top of Sutro Tower. The project is proposed in response to a Federal Communications Commission mandate that commercial television broadcast stations shift to Digital Television signal transmission as the next generation of tecnnology for television broadcasting. The new beam and antennas would hang down from the upper cross beam on Sutro Tower, between the north and south legs of the tower, on the east face. The beam would be situated from approximately 630 to 755 feet above ground level. Pursuant to California Environmental Quality Act Guidelines Section 15060, the Planning Depanment has determined that an Environmental Impact Report (EIR) will be required for the proposed project, and will begin preparation of said EIR. Potential environmental effects related to the following environmental features and issues will be considered in the EIR: public health effects VISUal quality/aesthetics land use/zoning public services and utilities, including interference with other transmission signals energy nOIse transponation all' quality/climate biology geology and soils hazardous materials water quality/supply issues archaeological and historic resources population and growth inducement Construction related, or temporary effects, will be considered as well as operational, or permanent effects. Mitigation measures for potential impacts which are identified will be discussed, as appropriate. Possible Alternative projects will also be discussed and analyzed in the EIR. til m o ~ o z co 9.0 GLOSSARY 9.1 DEFINITIONS anechoic. Typically a chamber lined with material that absorbs sound or radiofrequency energy and does not reflect it asthenic syndrome. Condition of generalized weakness, not commonly utilized as a diagnostic category in the United States. artifact. An erroneous finding in a scientific investigation often as the result of an unintended contamination or influence or an improper procedure; eg a high fever was found but it was a result of a mistaken procedure that left the thermometer in the sunlight bradycardia Decrease in heart rate. calcium efflux Involving altering the amount of calcium binding to cells and tissues cancer clusters Observations in a localized population of a higher number of a specific cancer (e.g, leukemia, brain tumor, etc.) or total cancer than is expected from data for the general population as a whole; such clusters may be the result of either the non-random fluctuations which occur in any statistical sampling or a true causal factor in the local population; a simple demonstration of such clustering occurs upon inspection ofthe number of salt crystals in several small circular regions after scattering salt on a surface-some regions will have many more crystals than others although, and because, the overall scatter was random; investigations of cancer clusters often do not lead to an identified causal agent because clusters occur with surprising frequency in large populations (e.g., countY-Wilde, state wide or nation-wide groups) or perhaps because of unidentified transient events (e.g., infectious disease or a toxic release); however, a fundamental premise of epidemiology is that disease in certain groupings of people (including clusters) have a cause which lies in factors of the environment, diet, genetic composition, or lifestyle Sutro EIR glossa" 9-1 07'0(, '')7 9.0 Glossar;. carcinogenic. Capable of causing cancer cohort Entire group or set of subjects used in an epidemiologic investigation. control. To test or verify by a parallel standard or other standard ofcomparison decibel (dB). A relative unit for the measurement of the amplitude of aquantity~typically used to measure the strength of radiofrequency power, radiofrequency radiation (electromagnetic fields), and the amplification factor of an electronic amplifier; the decibel IS one-tenth of a bel; the decibel is defined as a logarithmic quantity so that 3 decibels represents a factor of about 2, 10 decibels represents a factor of 10. 20 decibels represents a factor of 100, 30 decibels a factor of 1000, etc. denature To treat by chemical or physical means so as to alter its original state. diathermy. The localized elevation of temperature in body tissues by radiofrequency electric currents, microwaves. or ultrasound for therapeutic purposes direct current (DC) An electric current that remains steady and does not change strength or direction over time dosimetry. The measurement of dose; in radiofrequency research calculations and measurements of exposure in terms of power density and SAR electric field Radiation from an electric source electromagnetic field (EMF) The form of energy which surrounds an electric charge; especially the energy surrounding a device such as an antenna errors of commission An act of the subject making the wrong choice during an experiment. extremely low frequency (ELF) The portion of the electromagnetic spectrum from zero to 300 Hz Sutro EIR , glossarY 9-2 07!O(,'97 9.0 Glossal! field The form of energy arising from a localized source of charge or current _.~- fluoroscopy. Examination bv means of X-ra\' against a screen coated with a fluorescent substance. gene A region of DNA in the cell nucleus containing specific hereditary traits glomerular. Ofthe inner portion of the kidney handling. Holding/treating laboratory animals so they become accustomed to humans hemolysis. Loss ofhemoglobin, cell breakdown. hertz (H). Unit for measuring frequency of an alternating electric current or any repetitive activity. One hertz equals one cycle per second. histopathologic Pertaining to the cells and tissues of diseased or abnormal tissue hormone. Chemical substances, often produced by glands in the body that are circulated in the blood to control cellularfunctions~ego pituitary gland hormones carry messages from the brain to cells in the bod\' hyperthermia. Elevation of tissue temperature above normal by absorption or generation of heat~muscle activity; hot environments and microwave irradiation are typical means to achieve hyperthermia. in vitro. Within an artificial environment, especially for cells and tissues tested in glass or plastic vessels in vivo. Within a living organism iODlzmg radiation. frequencies are the highest (above 10J9 hertz) of all electromagnetic waves. It yields enough energy 10 expel an electron from a molecule. Sutro [IR glossarY 9-3 07/06/97 9.0 Glossary juxtamedullary. Area around the medulla. the inner portIOn ofthe kidney. kilovolt (kV). One thousand volts. lossy. Capable of dissipating energy and producing heat. magnetic field (MF) A moving electric charge exerts a force on other moving charges. field produced by an electric current microwaves. Electromagnetic radiation with a frequency above 300 MHz and below 300 GHz~a form ofnonionizing radiation mitosis. Process of cell reproduction or division. modulation. Time-varying changes in a radiofrequency emission which permit encoding of information for purposes like radio, cellular telephones, television, fax transmissions. and computer connections via a modem; modulation may involve changing signal amplitude. frequency. or phase; pulse modulation is a special class of amplitude modulation in which the signal is shifted from zero (off) to full power (on) and may be combined with additional forms of modulation during the on time. mutagenic. Causing mutations to cells. non-iomzmg radiation. Energy level of these electromagnetic waves is too low to eject electrons from (or ionize) atoms or molecules phase. Timing of an alternating (AC) electric current. prolate-spheroidal Sphere elongated along its polar axis promoter. This is an agent that accelerates growth of malignant tumors sham. Imitation; feigned Sulro EIR glossan 9-4 07106 1 ')7 9.0Glossa~ physiologically significant amount of heat. An energy input sufficient to stimulate a change or changes in thermoregulatory body functions such as sweating, breathing rate, and blood flow rate, or to cause changes in cellular functions such as firing rates of nerve cells and beating rates of heart cells, or to cause changes in biochemical functions such as activity levels ofenzymes and amounts ofproteins produced by cells tachycardia. Increase in heart rate terata ,-\natomical aberrations. teratogenic Causing anatomical aberrations thermal levels. Levels related to heating of a body or cells. thermoelastic. Deformation of a substance within its elastic range due to heat change. voltage Measure of electric tension which is measure in volts (V) watt Equal to the power in a circuit of one ampere flo\\s across a potential difference of one volt. 9.2 ACRONYMS AChE. Acetylcholinesterase ACTH adrenocorticotrophic honnone A/m. amperes per meter AM. amplitude-modulated ANSI Amencan National Standards Institute ARRL American RadIO Relay League ARMS. adjusted root mean square ATP. adenosine triphosphate BBB. Blood-bram barrier Cl confidence interval Sutro EIR glossary cm" square centimeter CNS. central nervous system CS condItIOnal stimulus CS cortIcosterone CW contmuous-wave dB decibel DENA di-ethyl-nitroso-amine DTV dIgItal teleVIsion EEG electroencephalogram ELF extremely low frequency 9-5 07'0(,'97 EMF. electromagnetic field EMP. electromagnetic pulse EPA. Environmental Protection Agency FCC. Federal Communications Commission Fl. fixed-interval FM. frequency modulation FOB. functional observational battery GHz gigahertz (I billion hertz) GMP. guanosine triphosphate Hb. hemoglobin HMBA. hexamethylene bisacetamide Hz. hertz IEEE. Institute of Electrical and Electronic Engineers INIRC. International~on-IonizingRadiation Committee IR. infrared radiation IRPA. International Radiation Protection Association IRT. interresponse-time Jig Joules per gram K + potassium Ion kg. kilogram (1,000 grams) kHz. kilohertz (1.000 hertz) LDR lactic acid dehydrogenase MEL murinee~throleukemlc MPE. maximum permissible exposure MHz. megahertz (1,000,000 hertz) MI. m\ocardial infarction 9.0 Glossary mW milliwatt (one thousandth ofa watt) mV millivolt '-I'a+ sodium ion NK. natural killer NTSC. National Television Standards CommlUcc OR odds ratio OSHA Occupational Safety Health Adnunistratlon PEP Primate Equilibrium Platform pps. pulses per second PSC posterior subcapsular cataract PSCI posterior subcapsular iridescence RBC red blood cell RFR radiofrequency radiation RMS. root mean square RR. relative risk SAR. specific absorption rate Sec. Standards Coordinating Committee SD standard deviation SMR standardIzed mortality ratio TD time discrimmation TLV threshold limit value TPA I=~-O-tetradecanoylphorbol-13-acetatc~ tumor promotmg agent f.1W microwatt (one millionth ofa watt) f.1W/cm2 microwatt per square centimeter liCS. unconditional stimulus UWB. ultra\'oideband Vim volts per meter W1m 2 watts per square meter SUIrO EIR gIos.'ar:- 9-6 07 / 0(,/97 10.1 EIR AUTHORS Lead Agency 10.0 EIR AUTHORS AND CONSULlANTS: ORGANIZATIONS AND PERSONS CONSULTED Square One Productions 725 Filbert Street San Francisco. California lJ4133 Hartmut Gerdes San Francisco Department of City Planning 1660 MlsslOn Street. 5 tn floor San Francisco. California 94103-2414 Envuonmental Review Officer Hillary Gitelman EIR Supervisor and Coordinator Paul Maltzer EIR Consultants Woodward-Clyde Consultants 500 12 th Street. Suite 200 Oakland. California 94607 Steve Kellogg Gwen Rodrigues Maxwell & Associates 1522 Grand View Drive Berkelc~.California 94705 ProJect Manager Sally E Maxwell Peter Polson. Ph.D. AUSA Research Cupertino. California Dr. Asher Sheppard Asher Sheppard Consulting 108 Orange Street. Suite 8 Redlands. California 92373 LoUIS N Hevnick. M.S. Palo Alto. California Origins 110 Lmden Street Oakland. California 94607 Arnold Mammarella Alexandra MamTIetz Sutro EIR sUI-lO 10-1 10.2 PERSONS CONSULTED Project Sponsor Sutro Tower. Inc 250 Palo Alto Avenue San Francisco. California 94114 Eugene Zastrow. Vice President and General Manager Pro,ject Engineer Hammett & Edison. Inc. POBox 280068 San FranCISCo. California lJ4128 \Villiam F Hammett Project Attorney GCA Strategies 655 Montgomery Street. 17!h floor San Franeisco. California 941 II Debra Stein Other City Agencies San Francisco Department of Public Health Bureau of EnVironmental Health 1~YOMarket Street. SUite 822 San Fr;:mclsco. California 94102 Larry Meredith. Deputy Director Richard J. Lee. Sf Industrial Hygiemst Outside Peer Review Dr. Chung-Kwang Chou I I East Longden Avenue Arcadia. California 9) 006 07/06197 Others Consulted Mark Feiling, Industrial Power Engineer PG&E Penelope Lincoln, Office Manager Sutra Tower, Inc. Robert Passmore, Zoning Administrator San FrancIsco Dept. of City Planmng Jay Watson, President Watson Commurucations Sutro EIR '. SUI-! 0 10-2 10.0 ElR Authors and Consuitam:, 07106/97 September 4, 1997 Ms. Hillary E. Gitelman Environmental Review Officer Planning Department 1660 Mission Street, 5th Floor San Francisco, CA 94103-2414 ... "'t. Dear Ms. Gitelman: Re: Addition of DTV transmitters to Sutro Tower. j .~..""" I~1 .~)~~\'i ,.J.J It is with great disappointment that I find myself obliged to write this letter to strongly oppose the~dilion of [)TV to Sutro tower. The disappointment is not the letter itself but the fact that certain 8ntities~" (individuals and businesses) intentionally plan to harm a complete society, including childt'en, infants, even yet-to-be-born II1fants, for some financial return: and the law protects them! 100 The danger 1am referring to has several shapes and forms. The health negative impact of Radio Frequency Radiation (RFR) has been well documented Although not proven 'beyond the shadow of the doubt', I am sure that everyone IS aware of such danger. One thing I am certain of is that no one (including yourself) accepts to use his or her own family to tesl the RFI{ theories With all due respect to all studies done in this domain, let's look at the tobacco scandal (ane! their 'health reports') and learn: let's not wait on this issue as 1l1l1g as we did in the tobacco case. :\nother risk source is the structure of the tower itself I don't think this needs much explanation: a 980-foOl steel tower. on a hill, In an earthquake area, next to a huge water reservoir, and surrounded by houses, schools. da\Tare centers. pla\ grounds. and fire 'lations. rhe long term survival in this area seems less rrllbable than winning the Illttery Please. please, pleas,' reject the Sutro Tower Plan 1greatly thank YllU for taking the time to read this letter and hope that you'll do the humanly right thing. Sincerely, t~(/l(i Li/~Itt;) / i\louJn I\boul-Ilosn cc Steve Nahm, Nancy Hogan ;.; ,> \ '. I ! - - Lloyd S. Cluff 33 Mountain Spring Avenue San Francisco, California 94114 Fax (415) 564-6697 Tel. (415) 564-9371 September 10, 1997 Hillary E. Gitelman Environmental Review Officer Planning Department 1660 Mission Street, 5th Floor San Francisco, CA 94103-2414 Dear Ms Gitelman: Subject: Earthquake Safety of Sutro Tower (in response to the Sutro Tower Digital Television (DTV) Draft Environmental Impact Report) I am writing this letter to express my concern about the stability of the Sutro Tower during a large earthquake, and the safety of residents who live in the vicinity of the tower. I am concerned for two reasons: (1) the Sutro Tower is 5 miles from the San Andreas fault and about 14 miles from the Hayward fault. A 1990 US Geological Survey report concluded there is a 70 percent chance of a magnitude 7 or greater earthquake from these two faults in the next two decades, and (2) I am an earthquake expert who has considerable knowledge and experience regarding seismic safety, and I live in the proximity of the Sutro Tower. My Professional Credentials I have been a practicing professional in San Francisco in the earthquake field for more than 35 years. My experience includes work in geology, seismology, earthquake engineering, seismic safety, and public policy in California and elsewhere worldwide. I have investigated most major earthquakes around the world to learn first-hand of the performance of engineered structures during destructive earthquakes. I also have been involved in the technical evaluation of the siting, design, construction, and earthquake performance of numerous critical and essential facilities (the Sutro Tower is in these categories). I have had the honor of serving as a Commissioner on the California Seismic Safety Commission for the past 12 years, and served as Commission Chairman from 1988 to 1990 and from 1995 to 1997. I was a member of the California Telecommunications Seismic Risk Task Force from 1991 to 1992, wherein we considered the safety and performance of telecommunications facilities during earthquakes. The National Academy of Sciences appointed me Chairman of Lloyd S. Cluff Hillary E. Gitelman Re: Sutro Tower Draft EIR September 10, 1997 Page 2 the National Research Council's Committee for the Symposium on Practical Lessons from the Lorna Prieta Earthquake. I was inducted into the National Academy of Engineering in 1978, and named a Fellow of the California Academy of Sciences in 1992. I have served as the President of the Earthquake Engineering Research Institute (1993 to 1995) and the President of the Seismological Society of America (1982 to 1984). I would be pleased to furnish a complete professional resume on request. MyConcems Based on investigations of more than 25 destructive earthquakes from 1957 through 1987, it was thought in the scientific and engineering community that well-designed and well-constructed steel structures, such as the Sutro Tower, always performed well; our confidence in the safety and resiliency of steel structures during earthquakes was very high. Since 1988, this confidence has deteriorated to an all-time low; presently, there is great debate about the adequacy and safety of many existing steel structures during large nearby earthquakes. The confidence in the seismic safety of steel structures (including structures such as the Sutro Tower) began to erode after our investigations of the earthquake in Armenia in 1988. I was one of the experts invited by the Academy of Sciences of the Soviet Socialist Republics of Armenia and Georgia to assist them in their evaluation of the devastating Armenian earthquake. Although at magnitude 6.7 it was considered a moderate earthquake, it killed more than 25,000 people and destroyed many of the engineered structures within about 15 miles of the energy release. Attachment 1 is a photograph of a destroyed telecommunications (military, microwave, television, and telephone) tower similar to but smaller than the Sutro Tower. It snapped off about 20 feet above its base during the earthquake. Nearby, there was another such tower that had sustained similar damage. Our first rationalization of much of the earthquake damage from the Armenian earthquake was the inferior design and construction practices throughout the Soviet Union. Therefore, \\'hile surprising, the photographs I took of the toppled telecommunications towers did not attract much attention; we still had confidence in the earthquake performance of steel structures built in this country. The towers were about 10 km from the earthquake energy release, at the edge of what has become known as the "near source" or "near-field" zone; a zone where, depending on the circumstances, earthquake ground motion acceleration and velocity can be very severe. These forces are so severe in fact, that surprising damage recently lloyd S. Cluff Hillary E. Gitelman Re: Surro Tower Draft EIR September 10,1997 Page 3 has been documented where none was expected by even the most competent structural engineers, including damage to moderate-to-tall steel structures and steel-reinforced concrete structures. Less than a year after the Armenian, on October 17, 1989, the magnitude 7.0 Lorna Prieta earthquake struck the San Francisco Bay Area. The earthquake was centered 60 miles from San Francisco and Oakland, therefore, it cannot be considered a test of our modern earthquake design and construction codes and standards, even though we were surprised at the damage to freeways, the Bay Bridge, and some of our modem steel-framed buildings. Attachment 2 i.s a photograph of a toppled KGO radio tower (for the emergency radio broadcast system) that I took during a helicopter reconnaissance after the Lorna Prieta earthquake. The damage to the tower was a surprise and an embarrassment to KGO, because the emergency broadcast system was lost when it was needed most. It also surprised designers of steel towers, because steel-frame structures were expected to perform well during earthquakes. What we know now (but was not at first revealed by some steel-frame building owners), is that a number of Bay Area steel-frame buildings suffered serious damage during Lorna Prieta. On January 17, 1994, the moderate, magnitude 6.7 Northridge earthquake struck southern California. Not only did more freeway structures collapse, but investigations revealed that many steel-frame buildings suffered serious damage. Hundreds of millions of dollars have been spent by building owners in an attempt to correct the fractured steel buildings and bring them back to an acceptable level of safety. So far, the best structural engineers in the world do not understand why more than 200 steel-frame buildings were seriously damaged in the Los Angeles area. The City of Los ..<\ngeles requires steel frame structures to be inspected and repaired; however, they are in a quandary because the structural engineering profession has yet to reach consensus as to what to do about the steel-frame earthquake stability problem. Exactly one year later, on January 17, 1995, a magnitude 6.9 earthquake struck Kobe, Japan, resulting in the loss of more than 5000 lives and the destruction of thousands of modern buildings. Some of the seriously damaged buildings experienced the same types of steel-frame damage as observed followi.ng the Northridge earthquake. Out of twelve recently built steel bridges along Osaka Bay, nine were damaged and could not be used during the emergency response phase following the earthquake, and several of the bridges experienced such severe damage that they took almost a year to repair at a cost of hundreds of millions of dollars. The failure of modem steel-frame structures during the Lloyd S. Cluff Hillary E. Gitelm.an Re: Sutro Tower Draft EIR September 10,1997 Page 4 Northridge and Kobe earthquakes sent a shock wave through the steel industry. Changes Underway in Seismic Design Standards On May 8, 1997, I chaired a public hearing on behalf of the Seismic Safety Commission (SSC) in Sacramento to discuss the progress on the near-source effects issue. There are major revisions in progress in the Uniform Building Codes (see Attachment 3, Craig D. Comartin testimony, page 2). I have also attached the testimony of Dr. Charles A. Kircher at the May 8 hearing (Attachment 4). The last 13 pages of Dr. Kircher's testimony document the building code changes that are in progress. I have also attached a paper by Dr. Paul Sommerville (Attachment 5) on Forward Rupture Directivity in the Kobe and Northridge Earthquakes, and Implications For Structural Engineering. This paper was referenced in the testimony of some of the presenters during the SSC hearing on May 8, 1997. On July 10, 1997, the sse hearing on Near-Source Effects On Tall Structures continued. I have attached three items from this part of the hearing: Attachment 6, memo from Fred Turner dated June 30, 1997; Attachment 7, Testimony of Farzad Naeim; and Attachment 8, Testimony presented by Gil Davis entitled "Faulty Towers?" I suggest you review these attachments, as ~heyare very pertinent to the expansion and eventual safety of Sutro Tower. Conclusions and Recommendations It is clear we can expect a major earthquake in the Bay Area in the near future. It also is clear that the state of practice of earthquake engineering is in the process of major changes. The codes that were used when the Sutro Tower was designed and built and the 1991 codes used in the most recent analysis are outdated and are being replaced. It would be foolhardy to add a major new 125 foot beam to the tower without considering the new data from the Lorna Prieta, Northridge, and Kobe earthquakes. There are many residents, a school, and hoVO reservoirs within the fall zone of this tower. The prudent course of action is to have a full dynamic analysis conducted by structural engineers fully knowledgeable of the new data. Because the effects of topographic ground-motion amplification and near-source directivity must be included, the dynamic analysis likely will use a seismic demand input several times larger than the demand ground motions used in the current analysis. Lloyd S. Cluff Hillary E. Gitelman Re: Sutro Tower Draft EIR September 10, 1997 Page 5 The results of this dynamic analysis must be independently peer-reviewed by a knowledgeable structural engineer, as well. I would be pleased to discuss this further to assist in resolving the issue of the seismic safety of the Sutro Tower. Sincerely, ~i~ Lloyd S. Cluff Attachments 1 through 8 cc: Gene Zastrow, Sutro Tower 1-' Attachment 3 CRAIG D. COMARTIN Consulting Professional Engineer, Inc. California Seismic Safety Commission May 8, 1997 For the past hventy five years I have been a Structural Engineer, primarily in California. Currently my practice is small and specialized in seismic issues. I am Stanford University's seismic consultant for their $250M program for evaluation and mitigation. I have had primary responsibility for managing the development and application of their performance based design standards including site specific near-source ground motion. As Senior Structural Consultant to the Applied Technology Council, I am involved in the formulation of performance based standards for the seismic design, evaluation, retrofit, and repair of buildings. I am also studying the effects of and recovery from the Kobe earthquake with the support of the National Science Foundation. Finally, I am an officer and director of the Earthquake Engineering Research Institute, a membership organization devoted to a multidiscipline approach to seismic issues. From this perspective, I offer the following observations: Near-source effects are real. Kobe is the definitive example. No other earthquake has struck so directly on such a densely populated, modem, urban environment. The consequences are stunning over 5000 dead, 300,000 homeless, total loss now measured as exceeding a quarter of a trillion dollars. Within 5 km of the fault rupture, 35% of all buildings collapsed or had severe damage; and less than 10% of all collapsed or severely damaged buildings were located outside this near-source zone. Irregular, nonductile, and poor quality buildings are the worst risks. None of the types of damage observed in Kobe is surprising. Soft stories, plan irregularities, and set-backs are evident in most of the collapses. Nonductile concrete and, regrettably now, nonductile steel details were major contributors. Lack of design and construction quality, as always, greatly exacerbated some situations. These risks are pervasive in the existing building stock, even if corrected eventually for new construction. An event similar to Kobe will occur in California. EERl recently published Scenario for a Magnitude 7.0 Earthquake on the Hayward Fault in which experts from California frankly present their opinions on the consequences of such an event. The parallel with Kobe, particularly with respect to 7683 Andrea Avenue, Stockton, California 95207 Email: comartin@leland.stanford.edu (209)472·12" FAX:(209)472-72~ Kobe Building Damage Statistics as a Function of Building Height .J I "1 ? Collapse ~ Severe Moderate Minor j l~ " .. J .~.._~_ _ : __ . ~ J .~_ __~__.. _._ .. _ _.J _.. _ _.._~__ _._ _ _ _ _ .~_ __.l __L _~__ __._~__. .!.?......................................_ -. : '. , ?????????????????????????????????? __ ???? _._ ?????????????????????_ ???????_ ???????????4> ????????????????????????????????????????????????????????? [ ~ 1 I' I ~ l- I t-_~. 1 ? o 100 350 400~co---~~---:--------,----:----,----,---;--~.----,--J .......__ ___~.?...................:.?....................................... Jj ,- j.~ L . 1 I r I- 300 I >- i r I- 50 L . ...... o 150 .. i ~~ E ::: Z ~ co = :a 200 .- :s ~ 1 2 3 4 5 6 7 8 9 10 Number of Stories Figure 3.5.4 Damage distribution of steel buildings. Reinforced Concrete Structures 40 --------------------------- ,.- i ~=~~::"":":"=--:: :{{ Slight D;.tm:.lgc or :\0D;.tm:.l~'': \ hnor D:.lmage ::2 \ lacerate D;.tm:.l!:!c Colbp~1.?or Se\'ere Dam:.lgc .. I ' N"""i""""'i,."q ,.~.,.~.,.,.~.,.,.,.,." ~.,.~.~.~.~.,.~.~.~.~.. - , - : o 5 10 15- - o <ll ..::::l C ::J Z rJl OJ C U ::J co U Q) OJ C'Cl E C'Cl o Up to 1971 1972-1981 Construction Period 1982 or Later Steel Structures 40 i- - L- 20 r:- _ .. - j Slight D:.lmage or :\0 Damage Minor Dama2:e :.laderate D:.ll11age Collapse or Severe Damage ..... ..... ~ J ~ '- J r 15 t- . 25 t-- ,.. 30 =- . 35 L .. ·························....······· .... Q) .c E ::J Z 10~-- _ -: 5H~m_~ o Up to 1971 1972 - 1981 Construction Period 1982 or Later Figure 3.8.3 Damage level of RC and Steel structures with respect to the year of constructi 162 Attachment 4 ASCE Structures Congress '96 Apri115-19,1996 Chicago, nJinois The Kobe Earthquake: Ground Shaking, Damage and Loss Charles A Kircher, Ph.D, P.E.1 Abstract In the early morning ofJanuary 17, 1995, violent shaking ofthe earth below Kobe, Japan tragically altered the lives ofmillions ofpeople and caused destruction on a massive scale. Over 5,000 people were killed, 35,000 injured and 300,000 left homeless. More than 150,000 buildings were destroyed by the earthquake and ensuing fire. Damage to highway and railway structures closed all major transportation arteries through the Kobe corridor, and severe ground failure crippled thePort ofKobe which handles 300-!o ofJapan's foreign trade. The Hyogo prefectural government has estimated approximately (US) $100 billion in direct damage to buildings and infra..stTUcture. JntroductiQn Japan is divided into nine political regions and 47 prefectures. Kobe is located in the Kansai region in the southern part ofthe Hyogo Prefecture, just west ofOsaka. Kobe is subdivided into 9 wards, 7 ofwhich are densely populated and lie on a narrow strip of land (Kobe corridor) bordered on the northwest by mountains and on the southeast by Osaka Bay. Two large man-made islands (port and Rokko) provide Kobe with additional land and harbor space. Neighboring towns are continuous along the bay between Kobe and Osaka The northern tip of sparsely-populated Awaji Island is located just southwest ofKobe. At the time ofthe earthquake, the population ofKobe was about 1.5 million people (about 580,000 households), and the combined population of other cities located in the southern portion ofthe Hyogo Prefecture was about 2.0 million. The total population living in areas exposed to strong ground shaking was about 4.0 million (mcluding an additional 0.5 million people from the western edge ofOsaka). The number of buildings exposed to strong ground shaking may be estimated by assuming that there is about I building per 5 people (i.e., about 700,000 buildings felt lPrincipal, Kircher & Associates, Mountain View, California 1 Kircher Tt"'t· I;~,,·n~1J7_t:' strong ground shaking in the Hyogo PrefectUre). Table 1 summarizes population and building data for Kobe and vicinity [EERI, 1995]. Table 1. Population and Bnllding Dan (EERI, 1995] Areas Affected Population Number of by Earthquake (x 1 Million) Buildings Hyogo Prefecture Kobe 1.5 300,000 Other Cities 2.0 400,000 Total 3.5 700,000 Osaka Prefecture 0.5 100,000 Total (All Areas) 4.0 800,000 Ground Shakine and Failure Japanese seismological reports describe the earthquake magnitude as Richter magnitude M 7.2 (M.. = 6.9), with the hypocenter ofthe main shock occurring at a depth ofabout 15 to 20 kilometers [AU, 1995]. Based on aftershock data., the length offault rupture is estimated to be about 50 km., extending from the northern tip of Awaji Island, directly through the Kobe cOrridor, to within about 15 km of Osaka. SuIfuce expression offault rupture was observed prominently on Awaji Island, but did not appear to occurin Kobe. Figure I identifies areas affected by the earthquake and shows a "near-fault zonet! boundary that encloses all areas within 5 Ian ofthe surface projection offault rupture. Soil conditions contnbuted significantly to the effects ofground shaking (and ground failure). Soil depth across Kobe varies rapidly from the mountains on the northwest side ofthe Kobe corridor to the coastline approximately 3 km to the southeast. The soil profile changes from rock at the edge ofthe mountains to deep alluvium and fill at the coastline. The area ofstrongest .shaking intensity, Japanese Shindo 7 (MMI X-XlI), was found to be concentrated in a 20 Ion long by 1 k:m wide band running directly through the center ofthe Kobe corridor, where the soil depth is neither shallow nor deep_ Soil failure due to liquefaction W3S a major feature ofthis earthquake, causing large pennanent ground dIsplacements lPG!Js) along the coastline and on the two man-made islands. PGDs of0.5 meter were typical on these islands. Lateral spreads also occurred. often as part ofthe failure ofan earth-retaining structure along the waterfront. Distortion and settlement oftbe ground was also observed in the center 2 Kircher ofKobe (m the areas ofstrongest shaking), although ground settlement in these areas usually appeared to be the result of soil consolidation. rather than liquefaction. Ground shaking felt in Kobe was intense, but typical of ground motion recorded nearfault rupture. Soil effects contributed to the intense shaking in cen:ain areas, but the primary cause ofstrong shaking felt throughout Kobe was the proximity ofthe city to fault rupture. Near·source ground shaking records from Kobe contain a few very strong long-period pulses, similar to near-source records from other earthquakes (e.g., 1994 Northridge earthquake). These pulses caused large displacements in the ground (and large displacements ofweak or flexible structures). The duration ofground shaking was relatively short, with very strong shaking lasting not more than about 5 to ] 0 seconds. Osaka City Figure 1. Areas Affected by the Kobe Earthquake (courtesy ofRMS, Inc., Menlo Park., California) Building Construction Allied bombing destroyed Kobe during World War II, so most buildings in Kobe were constructed since the v:ar. Although these buildings may be considered "modern,If design practices, codes., and construction methods have changed significantly in the last 50 years. Changes in design practices and the seismic codes 3 Kircher ofJapan are similar in many ways to changes in the seismic codes and practices ofthe United States. For example, Japanese seismic codes were significantly improved in the early 19705 and again in the early 1980s, about the same time that United States seismic codes were revised. Residential and commercial constrUction may be grouped roughly into three simple categories based on size: low-rise (I-story and 2-story houses), smaIler commercial and residential buildings (up to about 3 stories in height) and larger commercial and residential buildings (from 3-stories to 60 meters in height). These three groups do not include industrial structures (which are important to Kobe's maIl1.lfucturing economy) and very tall (greater than 60 meters) commercial buildings which are typically newer structures built to special seismic provisions. The majority oflow-rise residemial buildings are built ofeither Shinkabe or Okabe construction (i.e., traditional Japanese house construction). More recent residences also include some stud-wall wood bwldings and prefabricated units, The traditional Japanese house has a heavy clay tile roof; often set in a thick layer ofmud, timber framing, and walls ofeither tied bamboo and mud (Shinkabe) or loosely-spaced wood slats (Okabe) with stucco or other cover. Smaller commercial and residential buildings are often used for mixed occupancy (businesses on the first-floor, residences above). Typically, these buildings are built with Okabe construction, but may use steel (bar joist) framing in place oftirnber. Ofthe t1rree categories ofconstruction" the larger commercial and residential (mid-rise apartmem) buildings are the most similar to buildings found in the United States. Post-W3r construction oflarger buildings in Japan was dominated by the use of concrete, which include both reinforced-concrete (Re) and steel reinforced concrete (SRC) buildings. SRC buildings have a light steel frame encased in concrete that typically extends over only panial height ofthe building, with reinforced--concrete framing !.hove thAt clcvuion. Stedbuilding~inclUUl; uut11 Ul wx:d flume, often with relatively light bracing in the older designs, and moment frame construction. Steel moment frames often have shop-welded beam stubs (so-called column trees) that are spliced to beams in the field with bolted connections. Bui1din~Damsw;e The Kobe earthquake conapsed or severely damaged more than 150,000 buildings. While fire destroyed whole neighborhoods in some areas ofKobe, ground shaking was the primary cause ofbuilding damage. Ground fuilure due to liquefaction also contributed to building damage, panicularly near the harbor and on Rocco and Port Islands. However, engineered buildings were typically constructed on deep foundations whi<:h in mos:tca~e-spro'"'''''''':;ldP'lI1~tP~llppnrt~e~ln~f~illlrecine to ground settlement. Table 2 summarizes building damage based on a report prepared by the Architectural Institute of Japan [AU, 1995]. AU data are based on extensive building-by building surveys of the hardest hit areas of Kobe, grouping observed Kircher damage into one ofsix damage states: collapse, severe, moderate, minor, slight and none. Collapse indicates fuilure or overturning ofthe entire strUctUre or complete failure of a single story; severe damage indicates extensive structural damage, permanent deformation and possible collapse during an aftershock. Damage states focus on structural damage, since detailed swveys ofnonstruetura1 components and contents were not performed. It is important to note in Table 2 that collapsed buildings in Osaka account for only 1% of all buildings that collapsed during the earthquake, even though Osaka is located within 15 km to 30 Ian offault rupture and contains a greater number ofthe same type ofbuildings as those destroyed in Kobe, Table 2. Collapse, Severe Damage and Fire Damage IAIJ, 1995] Area Affected Nwnber ofBuildings by Earthquake Collapse Severe Damage Fire Damage Hyogo Prefecture Kobe 54,949 31,783 7,377 Other Cities 26,257 31,043 79 Total 81,206 62,826 7,456 Other Prefectures 885 5,217 0 Total (All Areas) 82,091 68,043 7,456 Table 3 summarizes collapse and~eredamage ofbuildings in the Hyogo Prefecture, distinguishing between buildings located very close to fault rupture (i.e., buildings located within the 5 Jan "near·fault zone" shown in Figure 1) and all buildings located in the region It is important to Dote in Table 3 that more than 90% ofthe 144,032 buildings with either collapse or severe damage were located within 5 Ian offmlt rupture and that these buildings account for about 35% ofall buildings located in the "near-fault zone." Table 4 crudely subdivides buildings with collapse and severe damage by occupancy type: low-rise residential, smaller commercial/residential and larger commerciaL'residential. Low-rise residential occupancy dominates the number of buildings destroyed, estimated to be over 11 0,000 residences (out of an estimated total population ofabout 300,000 residences). The population of smaller commercial and residential buildings with collapse or severe damage is estimated to be between 9,000 and 18,000 buildings (out ofan estimated total population of60,000 buildings) and the population of larger commercial and residential buildings with collapse or severe damage is estimated to be betWeen 1,000 and 2,000 buildings (out of an estimated total population of about 10,000 buildings). The latter estimate is 5 Kircher consistent with the AU survey results which found 1,067 buildings with collapse or severe damage out of a total of 4,530 steel., RC or SRC buildings surveyed [AU, 19951 Table 3. Building Damage by Proximity to Fault [AD. 1995] Area Affected Number Of Fraction ofBuildings byEarthquake Total Collapse Severe Collpase or Damage Severe Damage All Wards/Cities 700,000 81,206 62,826 144,032 ofHyogo Prefecture (- 20% ofAll) Wards/Cities 375.000 77.259 54,096 131,355 Within 5 kIn ofFault (- 35%< 5 km) Fraction of Buildings -55% -95% -85% -90% Within 5 Ian ofFault Table 4. Building Damage by Occupancy (Areas Within 5 Ian ofFault) Occupancy Class Total Number Number ofBuildings with ofBuildings Collapse or Severe Damage Low-Rise > 300,000 > 110,000 Residential (> gO%) (- 35% ofClass) Smaller Commercial - 60,000 9,000 - 18,000 and Residential (- 15%) (15% to 30% ofClass) Larger Conunercial -10,000 1,000 - 2,000 and Residential «5%) (10'% to 20% ofClass) All Occupancy Classes 375,000 131,355 The AU survey also provides information on the distribution of damage by structure type. For each ofthree levels of damage, Figure 2 shows that building damage was distributed almost evenly between steel structures and reinforced concrete (RC)/steel reinforced concrete (SRC) structures. 6 Kircher 5000 4500 4000 ... e.Q .5 3500 :s! ·S 3000 m ~2500 o :z 2000 1500 1000 500 o ? Steel Buildings mRC/SRC Buildings Collapse! Moderate Minorl Total Severe Slight Figure 2. Building Damage by Structure Type [ALl, 1995} Information on the distribution ofbuilding damage by age ofconstruction is available from Obayashi Corporation [Obayasbi, 1995]. Obayashi is one ofJapan's major engineering and construction companies that has designed and built many ofthe larger buildings in Kobe. After the earthquake. teams of engineers from Obayashi performed detailed surveys ofbuildings which included "tagging" buildings as either green (safe for use), yellow (limited entry) or red (unsafe/closed). Since these buildings were buili by Obayashi, their age and other properties were known to them. A total of 332 bwldings were surveyed as of March 1995, of which 112 were designed before 1972, 66 were designed between 1972 and I 980, and 154 were designed after 1980. Figure 3 illustrates the distribution ofgreen-, yellow- and red-tag buildings by period of design: pre-1972, 1972-1980 and post-1980. As Figure 3 shows, red tagged buildings represented about 30% of the sample population of pre-1972 buildings, about 15% of 1972-1980 buildings and about 5% ofpost-1980 buildings. Overall, about 15% ofall buildings surveyed were given red tags by Obayasro, a fraction consistent with the 10% to 20% range ofTable 4 that represents the fraction oflarger commercial/residential buildings with collapse or severe damage. The statistics on building damage by the period ofdesign illustrate the benefits ofimproved seismic codes and design practices, but also contain implicit infonnation on struetural features that influence bt.nlding performance. In general, larger buildings with partial or :full collapse could be characterized as having: (1) large inelastic displacement demand due to inadequate strength, (2) soft-story or torsional response due to structural irregularity and (3) key element failure due to lack ofductility. The improved perfonnance ofnewer designs is the result ofJapanese seismic: codes (and design practices) that have, in general, increased design strength, reduced structural irregularity and improved ductile detailing ofelements 7 Kircher 100% 800/0 60% 40% 20% ? Red Tags til Yellow Tags _Green Tags Pre- 1972- Post- All 1972 1980 1980 Figure 3. Building Damage by Design Age (Obayashi. 1995] Loss Due to Bwlding Damage Building damage is ofinterest to engineers and researchers, but loss in terms ofcasualties (deaths and injuries), loss offunction (e.g., loss ofshelter) and direct and indirect financial loss are ofgreater interest to society [UNCRD, 1995]. In terms of casualties, this earthquake killed about 5,400 people, more than 900.10 ofwbom died as a resuh ofbeing crushed or trapped under collapsed buildings. Over one-halfofthose killed were over age 60 and about two-thirds were women, typically victims ofthe first-floor collapse ofthe traditional Japanese residence. Non fatal injuries are estimated at about 35,000. Although these numbers are high, they represent only a fraction ofthe 250,000 people exposed to building collapse (80,000 collapsed buildings with about 3 people per building). On the average, there were about 2 deaths and 10 injuries per 100 people exposed to building collapse. Building collapse or severe damage forced large numbers ofpeople out of their homes. About 70% ofthe earthquake victims that were evacuated from their homes and apartments could not return due to the extent ofdamage to the buildings. Some victims found temporary shelter with neighbors, friends or relatives, or at hotels in other cities. Schools., connnunity centers., city halls and other public facilities (not too severely damaged) were used for temporary shelter in Kobe immediately following the earthquake. Homeless refugees seeking shelter reached 310,000 during the week after the earthquake [UNCRD, 1995]. This demand on temporary shelter is likely much less than the number ofpeople who lost shelter. Considering that there were more than 150,000 buildings collapsed or severely damaged, loss of shelter likely affected more than 500,000 people. 8 Kircher Direct economic loss is estimated to be at least (US) $100 billion, otwhlch (uS) $60 billion is attnbuted to bUlldmg damage lUNCW,199~].nl~tUtal replacement value ofthe 800,000 buildings located in the area ofstrong shaking may be estimated to be about (US) $200 billion, assuming an average building cost of Mn\lll~'JI~:"I'.';·;·-'I11llll1l1ltJ" IILII.lny Ulull" , ill ..i", T"lulIlI,ll.lnnncl.'l t.;rpioalh- ooot morc to build thnn United Staten hom86 dlole~ohigher~Oitiofr:t;\n~t111M;nn,6.. tnt.ll! building loss of(US) $60 billion represents about 25% ofthe total replacement value ofbuildings in the area ofstrongest shaking, consistent with the 20% fraction ofall buildings that collapsed or were severely damaged (Table 2). In fact, building loss of (US) $60 billion may be low, considering that this number likely does not fully include financial loss incurred in buildings with moderate, minor or slight damage (damage that is widespread throughout the region and includes costly nonstruetural repairs). Conclusion The Kobe eanhquake caused more building damage and related loss than any other earthquake to date. The primary reason for extensive building damage and related loss was the unfortunate location ofa densely populated urban region very close to £wlt rupture. ~~hherme \evel Oilground~haluJ1glIUILlt~dl~l!I!Jl !uePl~!\eUi!am~ynUUlU be a surprise to earthquake engineers. Although locally intense, the ground shaking is similar to ground shaking that has been recorded during othet'earthqtt;tlc~at !\ites near fiwlt rupture. Th!ll~glt!1lU,~.iUl.Io'IioJ\;OWl.,;1lny in F:o;:>l:-<;" rr.rf"nT'TT'lncl nn .......n~ldhit~~Qd UWllll. JllUll" UUWIU LO..IU1Ll.Illt III IUIII??, 1111.111111 ",' ? I ' .._---((1.. J --0-- 1 _ configuration and sufficient ductility protected. life safety,wbi1~Sll uctures with inadequate strength, irregular configurations and/or nonductile construction often collapsed or suffered severe damage. Estimated dollar loss of (US) $60 billion (about 25% of total building replacement cost) suggests generally peor building performance in tenns ofdamage controL References Architectural Institute ofJapan (AU), 1995, "Preliminary Reconnaissance Report of UU.I 1~9)Mj'u~uh,.lI1'T??u1J1.l~oI,I,U~'oI"ll1r"'I"In~}i.hrn,tin"J TnJlrn, Jnl'n.n Earthquake Engineering Research Institute (EER1), 1995. "The Hyogo-Ken Nanbu Earthquake, January 17, 1995, Preliminary Reconnaissance Report," EERI 95-04, Oakland, California. Obayashi Corporation Technical Research Institute (Obayaspj), 1995) "Preliminary Report on The 1995 Southern Hyogo Prefecture Earthquake," Tokyo, Japan. United Nations Centre for Regional Development (UNCRD), 1995, "A CaU to Arms, Report ofthe 17 January 1995 Great Hanshin Earthquake," Nagoya, Japan. SMIP97: Utilization of Strong-Motion Data Ground Shaking Criteria 1997 Codes and Beyond Charles A. Kircher. Ph.D?? P.E. Kircher &Associates Robert E. Bachman, S.E. Fluor Daniel Inc. May 8,1997 NEW CODe PROV1SIONS - GROUND MOllON ? Seismic Codes - Past, Present and Future - Source Documents ? Ground Motion - SEAOCIUBC Criteria ? 1994 UBCISEAOC Requirements ? 1997 UBC/SEAOC Requirements - Project '97 (BSSC SDPG) Proposal for the 1997 NEHRP Provisions 1 2 PRE·1980 SEISMIC CODES AND SOURCE DOCUMENTS 1980 ·1999 SEISMIC CODES AND SOURCE DOCUMENTS ,. 1N1"ERNA110NAL CODE COUNCIL (1994) 1CIJodaao ..~.!es C-ltbacueu-:n 3 4 ? 'II '.-..__ ? -.., "''-' -.,.. P 1 ..-.. ... - FUTURE SEISMIC CODES AND SOURCE DOCUMENTS (2000) ? ...'41---------........... .. 1 ~..A...at. e-.....EaJb-n 1994 SEAOCIUBC CRITERIA EXAMPLE SPECiRA AND DESIGN LATERAL FORCE 5 0.6 1 Peliod (Seconds) 1.2 1.1 1 0.1 0.1 fU VIW OJ! 000.1 OA 0.3 0.2 0.1 o o ZCSpectnJm SEAOC/UBC Spectrum (Zone 4., Soil Type 2) Sealri Wall (Row =8) EXAMPLE PARAMETERS: Standard oc:eupanc:y (I =1.0) SeismicZone" (Z = 0.4) Soil Type~(S .. 1.2) VNI ? Z(1.25SfT2Q)11Rw < 2.75Z11Rw VNI c (O.60fT'212)JR., «: 1.1JR., Moment Frame (Rw -= 12) 1.1 % IChdacr" ",-'_e. C_ItlDc£a~ 6 - " ,,-, -, "-,,, r ,. -~,,,- ..... 1997 SEAOCIUBC Criteria EXAMPLE SPECTRA AND DESJGN LATERAL FORCE 0", 1 1"' 2 PeJiocl (Seeoncls) EXAMPLE PARAMETERS: Standard Occupanc::y 0-1.0) seismicZone 4. SoD Type Se Not N_rSource (N - 1.0) VtW e <;JRT < 2.5CAIR SEAOCIUBC spec::tril'......,-_\l_'tW_._O_._56_IRT~_<_1_.0-,.1R_--, (Zone ..... SOli Sc. d,> 10km) Bearing Wall (R e A.5) 1.2 1.1 1-+-_"';'-'-_ U 0.1 VlW 0.7 U Wo.s 0.4 0.3 0.2 Moment Frame (R = 8.5) 0.:t===::::=::~===:;:===~ o KInWer. A..-twta C lItee EaP-cn 7 COMPONENTS OF THE Rw FACTOR Penod TT .~ (ALLOWABLE STRESS DESJGN ? 1994 USC) VIW ZC Speetnun (5% Damping) Period Shift (Code-Oenned to 'TnIe Value~YIeld) IJVlI Damping ZJC I (3R.,,1 8) (AbO\lltfi'-o( Cflllalll - OVerstrength (Inelastic ResponM) ~ ZlC/Rw r Load Factors r . . 1Cin:ker. ADodat.. e-tdeeEalbo-n 8 VNI COMPONENTS OF THE R FACTOR (S'lRENGni DESIGN - 1997 USC) C Spectrum R= ~RJI IC I R.t IC IR.t~ Period Shift (~ro True \I..at Y\eld) Damping (AbOWftoOl Overstrength (lneIUCIC RHpOnM) T Til! T. Period 9 S1. . ............_- _ __???_-_._----_???""7 ?????._ _ ????????????????????-: SOIL PROFILE TYPES - 1997 USC (NEHRP) '-"'$o'ii-"''':''-'''--son'p~~ie'''''''''''''''Sh~;'W~~;···;..···A·p·p·;:~;;.::······ : Profile: Name/Generic . Velocity . 1994. USC ? L!.~~L~.~~~!i_~.~J~.~~~.l.~~~.~.!Y.J>.~. S Hard Rock 1 500 A (EUS Only) > , Rock ? 760 to 1.500 ? l················..·..~-- -..- -..-.- :....----_.._._~_ : ; Sc : Very Dense Soil 360 to 760 ? ? ~: and Soft Rock S2 f" ????- _ ??????~???_ ?????????- _ .0--- _ 0.__ _..? _ _'0' '" _~. SD. Stiff Soil 180 to 360 . .:-_ _.._-_~-_.._.._-------_._-_.-.__ _ ,..__ _- _ -..~_ -.._~ SoftSoil < 180 53 ~_---_~---_.._--._----_._----,;.,..__ _--- _-_ ...;..- _---_.._ : SF Soil Requiring Site-Specific . 54 . Evaluation. , -_.__ __..__.._--_ _-_._-_ __ _-_.._--..-.-.-._ _ __ ._ --_.- - .. ICirdH:r A .bMd.... C~"'IEa&l~ 10 DESIGN SPECTRUM· 1997 USC 1 T,. - CvIQ.8ZNv I ControlPerfods T s Co CyJ2.'c A T A ? O.2T. 12.5C A I I;EPA~CAI . . : T,. Period (Seconds) IOIUIII' a .ow....... c_.....cEa&fm n 11 SHORT-PERIOD SEISMIC COEFFICIENTS - 1997 USC ? Short-Period (Aculeration-Domain) Relationship: V = 2.5C A W (1)1) ? Values ofSeismic Coefficients. c A (Table 1s.Q): r-------,--.-------.------.--.-..---.--- - -- _ . : Soil j Seismic Zone Factor. Z ; j Typej~Oi$1T~51ri;o:i1-T-z;ii:i1rz;o~4:;·-·1 j SA 1 0.06 1-!:12 i 0.16_.,L~~~,_L~:.3~~-J i s. i 0.08~0.15~.0.20 ;0.30 ! OAONA 1 ~: _ -:- -.-..-.-..·····:··--···--······--·:----·---···--7------········, i Se \ 0.09 ( 0.18 t 0.24 i 0.33 j O..40N" i < 0 0 (" _ _._??~?? ? ._ ? .t \ GD i 0.12 ! 0.22 ; 0':8 t 0.3$ \ O.44N A ; t~~j~.:~.~_L~.~~_..J__..~:~_l_~:~~.L~~!.~_~_J 12 LONG-PERIOD SEISMIC COEFFICIENTS -1997 USC ? Long-Period(Velocity~omain)Relationship: C a.8ZN V = R! W~a.IleAIW~RI v W (Zone· 4) (11)T (II) Values of Seismic Coeffident, Cv (Table 16-R): ,., } _-----------------._----_.._.._ . j Soil I seismic Zone Factor. Z j ;!--------::---------------~---_- .,.. _ ; ! Type~Z=O.075";Z=O.15 1 i Z=O.2 1 ~Z=O.3 1 \ Z=O.4 1 1 ~?'~??'4?..,__,."".,.,..,.".~~,.~~ ! SA j _.0..01; ; 0.12 0.16; 0.24 i 0.32Nv : ~...t . > \ S. l 0.08~0.15 : 0.20 ; 0.30 ; O.40Nv 1 r-----~.._---.-- --_:-.--- ---._.(-.. u ??????????????????! ????. '-0~???.?????? u ?? O& ????-~ : Sc j 0.13 i 0.25 i 0.32 ] 0.45 1 0.56Nv 1 , _-_._ ...-----_._-_._--------..------_._-_..__..- _-_ ---_ .. j So j 0.18 j 0.32 . 0.40 i 0.54 ; D.64Nv 1 ~....... ......-... ...-.t I ~SE j 0.26 j 0.50 < 0.64 ] 0.84 1 0.96Nv 1 ~?????_ ????_ ??_ ???:._ _????t ???? _._ ??????_._ 1 __???~???_ ??_.~__???-.._?? ?????~ NEAR SOURCE FACTOR N A -1997 USC ? Values of Near Source Factor, N" (Table 1&-8): : Seismic~Closest Di5tiInce to Known Seisnlc SO&m:e " . :Source Type;~2km. Sian .~10km. ~=~~...~~=J==.....~~!:.~....;..~.~~~~~...~~~~=~~~~~f~~=~~~~ t~:==···~-====t===·_~~·_=~-~===~.·-i~~==:::=I====~~~:=:::::~ ? Seismic Source Type (Table 16-T): 13 ~. . . , ,' , _ . ~Seismic: seismic Source~~~..~~~~~_ < ~Source Type i Description ; Magnitude: Slip Rate : ::::::::::::::::::::::::::::!~~~:::~~:=~~::r~~.~~?~~~I~~s.~~J;;~ ······ ..·..···c·····.·.·:.·.···.·.T.~.~.·~~..~.~..~~.~~.p..~.;....·.·.·~.·~·.~.~~..·.·.·.·.·~.~·.~...~~1Ji.·.1 14 NEAR SOURCE FACTOR N v - 1997 USC ? Values of Near Source Factor, Ny (Table 16-T): r····S;iSmiC······~·..···c~st·DiStMa·tD·Knc;.~··hi~·~; .................., .' ; , : iSource Type :~2 Ian) 5 kin 10 kin :~15 Ian ! 1.. ··· ··A i .. · ·io·· r ..-·i6····~..· ii· ·; ..· ·1·:0·..··~ t······························:··..·· ·..···..·····.~_ _ u_???? _ ........??????????_ ??-<t : B : 1.6 i 1.2 : 1.0 : 1.0 : ~.·_·._······.·??__??? ???? ? ???? __ ????? n ??_ ??????_·· ???'1" ?????????????????, - .. . C -. 1.0 - 1.0 1.0' 1.0 . . . > , .. " ??????????? , ?????? ,.?? ? SeiSmic: Source Type (Table 16-U): r--S;;-m·~-···__··..····S;iSm-;;-~u;C;;···.._.. ····y··_ ..·sou;~··~·nitiO·n·..····· iSource Type: Description !..M~nitUd~..;..snp·~..1 ~..·...... ·· ..A· .... ··· ·:··..~·-Ma.. ·Hi9h·sliP-R*··_·:··--··M·;;7ji··..·:·~-5·mmiYf··: t ???_???__??_ ??? ._ __? ???_. ??? ???__ _ ??????~????_ ??__ _ ??_ ~B ; Not A or C SOurce: : : ~:~~~~~~~:~~~=~I~~.~~~~~~.~~~~T~~~:~:~~~:::~:;~~I~~J IGrdacr..A-. I.Ca C ""If!apeas 15 BASIS FOR NEAR SOURCE FACTOR ? Near--source factors developed by the Ground Motion Subcommittee ofthe SEAOC Seismology Committee as an extension ofthe N factor required for base-isolated buildings ? Near-source factors are based on the increase in ground shaking. above Zone 4 level. predic1ed by empiricaUy-derived median estimates of ground motion for: ? momentmagnitude M =7.5 - Type A faults ? d\6d\Adt MlfP\dUftl M !!: 7.0 - I~i:S tiuM ? Median estimates of ground motion based on the average of Boore. Joyner, Fumal (BJF 13194) and Sadigh, Chang, Abrahamson, Chiou, Power (S&digh 13) attenuation functions ? same combination ofattenuation functions used by Project '97 (USGS) to develop the newspectral maps ofthe 1991 NEHRP Provisions for rock/stiff soil sites in the western US: 1148JF 93194(A) + 114BJF 93/94(8) + 112Sadigh'93 (RoCk) 16 BASIS FOR NEAR SOURCE FACTOR ? Near-source factors applyto both strike-slip and reverse-alip (thrust) fault mechanisms (although reverseaslip faults produce about 20% greatershaking. onthe average) ? Short-period (accaleration-domain) near..source factor (NAl ~don response at 0..3 seconds and lon!jH)eriod (velocity domain) near-source factor (Ny) based on 1.Q.second response ? Values of Ny are bumped upward by about 20 1t ;. to account for the mcntase in average response in the fault-nonnal direction above that predicted by the attenuation functions for the random component of horizontal ground shaking (Somerville, 1996. 7th US/Japan WOrkshop. Lessons Learned frOm Kobe andNorthridge). ? COmmentary to SEAOC Blue Book notes that ground shaking at ""forward directivity" sites is likely be about 1.25 times the Cv (and CJ coefficients based on average fault-nonnal response DISTANCE TO SOURCE -1997 UBC ? TM "Cl03C3t di3tnnoc to knownGOiGmi~Qcnm:e" (d,) shaD be taken as the minimum distance between the site and the area described by the surface projection of the source. The surface projection need not include portions of the source at depths of 10 lan, or greater. ~(km)10 5 0 0 5 10 dt(km) . \. \- jP=:' 17 18 PROJECT'97 ? Joint Effort BSSC, FEMA and USGS ? Purpose: Update NEHRP ReeommQndedProvisions torthe development ofSeismic RegUlatJons for New BuHdinDS, inCluding up.to.date seismie hazard maps and related design procedul"8 ? seismic Design Procedures Group (SDPG) Goals: - Replace existing effective peak ground acceleration and velocity design maps with spectral response design maps based on new USGS spectraJ response hazard maps - Develop and propose new design values maps that are conai.3tent with the framework of the NEHRP Provi3iono - Develop and propose new design procedures for use with the new design valUK map$ in tM NEHRP Provb:ions DEVELOPMENT OF SEISMIC INPUTS USGS Spectral Contour Maps (ProbabilisticJDetenninistic Measures of Hazard) SDPG Spectral Contour Maps (Maximum Considered Earthquake - Reference Site) SDPG Design Procedures (Combine Contour Maps with NEHRP Provisions) lardMr. Anoda'" e-JdlllEatlMen 19 20 NEW EARTHQUAKE DEANmONS ASSUMFnONSANOTENTA~PROCEDURES ? For all Seismic Zones: Define consistent relationship between Design Earthquake (DE) and Maximum Considered Earthquake (MeE) shaking levels: DE = 2 MCE or MCE~(J.S)DE 3 ? DE is the "de$ign-basis- earthquake, used for "regular" design, with margin provided by intentional conservatism's of the NEHRP Provisions ? MCE is the "worst-caseJno collapse" earthquake, used for design of special (base isolated) buildings or for collapse check of existing buildings [FEMA 273] KIrc:IMI''' A-.dllt.. C Idat~&lMen 21 DESIGN EARlliQUAKE CRITERIA 3 ? - ?? "'CeiUng- (e4......7.5, Med_ Atten.) --- ~(e...1J., m CII Q.2g) - ? - ?? PrOUbIlstk (e.g., 213 r:Jt 2%I!lO V.,.rs) 1:1 - ... - Duign Spec:tr"", v.aue ? . ... tA 2 " l: &. ... , ? Zone DC I Zone P i Zone DFi ZOne 0 & (DlttrmllnlStlC celllng) 1 (PrabMill.tJtic) I (Dit. Roof)I (No Culgn) ii ... ) I I c-. ! t I - "13 1 .... I I &. " 1 I I 1-..Coc» Level .1 I I m ................................. ............ I I..... "r- .. I I ...... \ I o .....---------------~--.~~.- 10 3 ,00 2 3 .. 10 1 2 :s 4 ,OZ 2 3 .. Zone$lSource Distance (km) 1CIn:Iol!r ..A-t.us Cn .....,~1'lI 22 \ I I , , ? M.gnItudeM- 8.0 I . . . - - ? MagnIudlt Mw: 7.!5 , \ , , ? I - - MIvJIUde M-7.D , - ? MIgnIIudItM=&.5 . "' -1187UBC·TypeA I , ,7 ." , . 'VI - '" " -18lJ7lEC·TpB . .' . _'..t.~ .-', s;;s:..,-: ? ? ??1 L- ?? J- l-'" ? or' .. .... L... -.-:1 .. - ~- .... -' i I - I"""_~- .. -. I ! \ i' _. I , I I 1 COMPARISON OF 1997 USC & NEHRP PROVISIONS (1.0..5eCOND RESPONSE NEAR STRlKE..sUP FAULTS) NEHRP ? 1l4BJF'13(A) ... 1148JF'I3(B) + 112Sad1gh"13 RcdtSItes. strtke-Up F-* (WIcIh ? AD. DCp· 0 DegNes) 1.2D 1.10 1 r i I ??? M8gn1tude,. ..a.o i! 1.00 I I - . 1IIIgnItUde,.. 7.5 i,~ --~M·7.lJ gQJlO I ? I ' - ? MagnItude M-1.5 1:; I ?r-:--\.. -1987USC.Typ.A -G.AO I I /" I ..... "· -,v.n UBC - Type B ~0.10 I. '/'~...-1...~ ~ I , '! OAO I J. ? I~,/ J ...... ~'·1 1~.. ." ,.. I "~'I ...... r--._ ? -1- ~.- . G.3O f- :.1- . _ -t - -J -'\ I -. -1__ -- - - flO Il20 .-\ i I.~--~-_.- i I .- 0.10 . I I I OJlO 40~..z -1& .10 ..5 0 :5 10 is 11) Z 110 DlstancetD swtaceEx~of Fault (Ilm) 1ardIla'. A-'etes e-!lli·I~ 23 COMPARISON OF 1997 USC & NEHRP PROVlSIONS (1.D-SECONO RESPONSE NEAR THRUST FAULTS) NEHRP "1I4BJf'I3CAl+ 114BJF'S3(BJ +sad~'93 RackSbs, 1bIustFall (\\WII=15 Un, Dp·GJ) 1.2D 1.10 ~'UI) c IUlO ~QJI) "'G.70 lOAD f,) .:lUll "GAO t:= flO 0.10 0.00 ~~~4~~0 5~~~~~ HmdIlQM4II DcInce1l)Swt.::eE:qu..o""ofFUt(lcm) FoCI('NaIl lClrdI.-.It Awod.... e-JUJacb~ 24 Near-Source Summary ? Earthquake ground shaking in the near-source region can be violent and capable of collapsing weak, non-ductile bUildings, particularly if irregular in configuration. - Earthquake recordings near fault rupture indicate site response as much as twice that of 1994 UBC design spectra (Zone 4 sites). ? The 1997 UBC (1996 SEAOC "Blue Book") includes new near source (N" and N v ) factors that substantially increase design base shear for buildings located near faults. - 1997 UBC near-source factors are similar to the near-fault factors required for design of base-4solated structures by the 1991 and 1994 UBC's (1990 SEAOC "Blue Book") - 1997 UBC near-source factors are required for design of all buildings, except short, stiff buildings of regular configuration. Charles Kircher, Ph.D., P.E. July 9.1997 Near-Source Presentation SEAOC Seismology Committee California Seismic Safety Commission Supplementary Documents: (1) "The Kobe Earthquake: Ground Shaking, Damage and Loss," Charles A. Kircher, Proceedings ofStructures Congress XlV, April 15 - 19, 1996, Chicago, Illinois, ASCE, New York, New York. This paper describes near-source ground shaking and summarizes damage and loss statisticsfor buildings located within 5 km offault rnpture during the 1995 Kobe earthquake. (2) "Ground Shaking Criteria: 1997 Codes and Beyond," (slide set), Charles A. Kircher and Robert E. Bachman, SMlP97: Utilization of Strong-Motion Data, May 8, 1997, California Division ofMines and Geology, Sacramento, California. These slides describe and compare seismic ground shaking criteria of the 1994 UEe, 1997 UBC and the 1997 NEHRP Provisions (2000 lBC) with special emphasis on new site near-source factors ofthe 1997 VEe. (3) January 22, 1996, Letter from Professor James M. Kelly, University of California at Berkeley, to Mr. David Choi of the California Office of Statewide Health Planning and Development. This letter responds to an aSHPD request to review a paper by Hal/, Heaton and others on the response offlexible buildings to near-source ground motion and raises concerns regarding methods used in the subject paper to model and evaluate hase-isolated buildings. Mtachment 5 Seventh U.S.-Japan Workshop on Improvement of Structural Design and Construction Practices. Lessons Learned from Kobe and Northridge. Jan. 18-20. 1996, Kobe FORWARD RUPTURE DIRECTIVITY IN THE KOBE AND NORTHRIDGE EARTHQUAKES, ANDI~lPLICATIONSFOR ST)tUCTURAL ENGINEERING by Paul Somerville Woodward-Clyde Federal Services. 566 El Dorado Street. Pasadena, CA 91101 Tel: (818) 449-7650 Fax: (818) 449-3536 Email: pgsomerO@wcc.com Abstract The ground motion characteristics of the Kobe and Northridge earthquakes were very similar, with each earthquake generating large near-fault motions due to forward rupture directivity effects. The largest recorded peak velocities in the two earthquakes were the same: 175 crn/sec in the fault-normal direction at Takatori, Kobe and Rinaldi, San Fernando. The effects of forward rupture directivity on near-fault ground motions are very similar for the 1995 Kobe, 1994 Northridge and 1989 Lorna Prieta earthquakes, even though these earthquakes had different faulting mechanisms. Averaged over these three earthquakes, the absolute amplitudes of average horizontal ground motions containing forward directivity effects are 50% larger than those for average directivity conditions for magnitude '7 and closest distance 5 kIn for periods longer than about 0.5 second. Also, the ratio of fault normal to average horizontal ground motion for forward directivity is about twice as large as for average directivity conditions in this period range. New provisions in the proposed 1997 revision of the UBC for near-fault motions appear to provide an adequate representation of the average horizontal component for forward rupture directivity conditions, but are significantly lower than the fault normal component at periods longer than about 0.8 sec. Although both the Kobe and Northridge earthquakes occurred within dense urban regions, the damage estimate for the Kobe earthquake is about one order of magnitude larger than that for the Northridge earthquake. This large difference in damage may have been due in part to differences in the location of the region that experienced very large long-period ground motions produced by rupture directivity effects. In Kobe, the largest long period motions were within the densely populated urban regions, whereas for Northridge, the largest long period motions were to the north of the densely populated urban region. This suggests that losses of Kobe proportions could potentially occur during earthquakes in California if forward rupture directivity conditions occur within densely populated urban regions. Introduction The rupture of the Kobe earthquake directly into downtown Kobe produced near-fault ground velocity time histories having large, brief pulses of ground motion. These long-period pulses are indicative of rupture directivity effects and are potentially damaging to multi-story buildings and other long-period structures such as bridges. Rupture models. of the Kobe earthquake that explain these pulses have been derived by several investigators including Sekiguchi et al. (1995), Wald (1995), and Yoshida et al. (1995). Rupture directivity effects have also been widely observed in near fault strong motion data in California (Somerville and Graves, 1993), and their average effect has been quantified as a modification to empirical attenuation relations by Somerville et al. (1995). Although the focus of this paper is on rupture directivity effects, they were not the only contributor to the large ground motions caused by the Kobe earthquake. Much of the damage from the Kobe earthquake was concentrated in a region where there is a shallow layer of alluvium. The zone of severe damage, which coincided with a layer of thin alluvium about 10 meters thick, lies to the southeast of the mapped active faults that are inferred to have ruptured at depth, indicating that the widespread damage in this zone is not explained simply by proximity to the fault rupture. Preliminary measurements of site response indicate large amplification of ground motions within this zone (Kawase et al., 1995). Similar conditions exist in many parts of California, such as Oakland and Long Beach. We do not have many recordings of large earthquakes on thin soil sites at close distances in the United States, which makes the Kobe data of special importance for evaluating the response of thin soils to strong shaking from large earthquakes in California. Rupture Directivity Effects At long periods (longer than about I second), ground motions are strongly influenced by the earthquake faulting mechanism (the orientation of the fault and the direction of slip on the fault); the location of the earthquake hypocenter; and the location of the recording station in relation to the fault. A particularly important effect at long periods is the rupture directivity effect in near-fault strong ground motion, which is manifested by a large long-period pulse of motion in the direction normal to the fault. Not all near-fault locations experience forward rupture directivity effects. The forward rupture directivity effect occurs when two conditions are met: the rupture front propagates toward the site, and the direction of slip on the fault is aligned with the site. The propagation of the rupture toward the site at a velocity that is almost as large as the shear wave velocity causes most of the seismic energy from the rupture to arrive in a single large pulse of motion which occurs at the beginning of the record. This pulse of motion represents the cumulative effect of almost all of the seismic radiation from the fault. The radiation pattern of the shear dislocation on the fault causes this large pulse of motion to be oriented in the direction perpendicular to the fault. Backward directivity effects, which occur when the rupture propagates away from the site, give rise to the opposite effect: long duration motions having low amplitudes at long periods. Rupture Directivity Effects in Strong Motions Recorded during the 1995 Kobe earthquake The conditions for generating rupture directivity effects are readily met in strike-slip faulting, where the fault slip direction is oriented horizontally in the direction along the strike of the fault, and rupture propagates horizontally along strike either unilaterally or bilaterally. The rupture of the Kobe earthquake directly into downtown Kobe caused near-fault rupture directivity effects. The recorded peak velocities were as large as 175 em/sec at Takatori in western Kobe, and the largest values occurred in the densely populated urban region, as shown in Figure 1. In Figure 2, we show the acceleration, velocity and displacement time histories of the Kobe earthquake recorded at Kobe JMA. The near-fault ground velocity time histories have large, brief pulses of ground motion that are indicative of rupture directivity effects. The horizontal peak velocity and displacement in the fault normal direction are about two and three times as large respectively as those in the fault parallel direction, but this difference diminishes at short periods (peak acceleration). The acceleration response spectrum of the fault normal component greatly exceeds that of the fault parallel component for periods longer than 0.5 second, as seen in Figure 3. Rupture Directivity Effects in Strong Motions Recorded during the 1995 Northridge event The conditions required for forward directivity are also met in dip slip faulting, including both reverse and normal faults. In this case, coincidence of the fault slip alignment and the rupture direction occurs in the updip direction, causing forward rupture directivity effects at sites located updip from the hypocenter. Unlike the case for strike-slip faulting, where we expect forward rupture directivity effects to be most concentrated away from the hypocenter, dip slip faulting produces directivity effects that are most concentrated updip from the hypocenter. The rupture of the Northridge earthquake updip and toward the north produced near-fault rupture directivity effects along the northern margin of the San Fernando Valley (Wald and Heaton, 1994). The recorded peak velocities were as large as 175 em/sec at Rinaldi in the northern San Fernando Valley, but unlike the Kobe earthquake, the largest values occurred outside the densely populated urban region, as shown in Figure 4. In Figure 5, we show the acceleration, velocity and displacement time histories of the Northridge earthquake recorded at Rinaldi. The near-fault ground velocity time histories have large, brief pulses of ground motion that are indicative of rupture directivity effects. The horizontal peak velocity and displacement in the fault normal direction are about twice as large as those in the fault parallel direction. The acceleration response spectrum of the fault normal component greatly exceeds that of the fault parallel component for periods longer than 0.5 second, as seen in Figure 6. Average Rupture Directivity Effects Somerville et al. (1995) developed modifications to empirical attenuation relations to incorporate average rupture directivity conditions. The modifications, based on an empirical analysis of near-fault data and checked using broadband strong motion simulations, give the fault normal and fault-parallel components of motion, which differ from each other at periods longer than one-half second in a manner that is both magnitude- and distance-dependent. The earthquakes used in the regression analysis of recorded data include all California crustal earthquakes with magnitudes of 6 or larger for which digital strong motion data and faulting mechanism are available (including the 1994 Northridge earthquake), together with selected crustal earthquakes from other regions (including the 1995 Kobe earthquake) to augment the data set for larger magnitudes. The data set provides a fairly uniform sampling of the magnitude range of 6.0 to 7.5 and the distance range of 0 to 50 km. The dependence of the ratio of fault normal to average response spectral acceleration on magnitude, distance, style of faulting, and site category was examined by means of a regression analysis of the data using the random effects method (Abrahamson and Youngs, 1992). This method provides a means of partitioning random variability in ground motion amplitudes into inter-event and intra-event terms, and ensures that the results of the regression are not unduly influenced by events having large numbers of recordings. The style of faulting and site terms were found not to be significant. The model of the fault-nonnal to average ratio is displayed in Figure 7, which shows the distance dependence of the fault-nonnal to average horizontal ratio for various magnitudes and periods at the top, and the period dependence of the ratio for various magnitudes and distances at the bottom. For periods longer than 0.5 seconds, the ratio increases as magnitude increases and as distance decreases. The largest ratios occur within about 10 k.m of the fault. Generally, the ratio increases with increasing period up to about 5 seconds, where it tends to level off for all but the closest distances and largest magnitudes. In Figure 8, we apply this model to calculate response spectra for a magnitude 7 earthquake recorded at a closest distance of 6 km on soil for average rupture directivity conditions. The fault nonnal and fault parallel spectra diverge at periods longer than 0.5 seconds. Forward Rupture Directivity Effects The model shown in Figure 7 is appropriate for estimating the fault nonnal and fault parallel components of ground motion under average rupture directivity conditions, and can be used in either probabilistic or detenninistic seismic hazard analyses. The detenninistic approach, which is based on the occurrence of a maximum magnitude earthquake on the controlling source, will give the fault nonnal and fault parallel motions at a given site averaged over rupture directivity conditions. However, it may be desired to include the most severe rupture directivity condition (forward directivity) in the deterministic approach, since forward directivity has a high likelihood of occurring at any near-fault site. Accordingly, we have developed a second modification that allows the estimation of ground motions having forward rupture directivity effects. This was done by quantifying the difference between forward rupture directivity effects and average directivity effects. The difference is characterized by two factors: an increase in the level of average ground motions, and by an increase in the ratio of fault nonnal to average ground motions. These adjustment factors can be applied to the average horizontal ground motion derived from empirical attenuation relations. Comparison of Forward Rupture Directivity Effects in the Kobe, Northridge" and Lorna Prieta Earthquakes We quantified forward rupture directivity effects in the near-fault strong motion recordings of three recent earthquakes in the magnitude range of 6.7 to 7.0. These are the 1989 Lorna Prieta earthquake (oblique faulting), the 1994 Northridge earthquake (reverse faulting), and the 1995 Kobe earthquake (strike-slip faulting). The recordings used in the analysis are listed in Table 1. The results of the analysis are shown in Figure 9. At the top, we show the ratio of fault nonnal to average ground motions, which is quite similar for all three earthquakes even though they have different rupture mechanisms. The ratio averaged over the three events, shown by the bold line, is about twice as large as for average rupture directivity conditions. At the bottom of Figure 9, we show the ratio of the average horizontal motion from the forward directivity records to the motion predicted by the empirical attenuation relation of Abrahamson and Silva (1995). The ratio becomes larger than zero at periods longer than about 0.5 second. The average horizontal ground motion for forward rupture directivity conditions is about 50% larger than for average rupture directivity conditions. The period dependence of this ratio is similar to that of the ratio of fault normal to average horizontal ground motions. This indicates that the large fault nonnal motion caused by forward rupture directivity effects causes the average horizontal motion for forward rupture directivity to exceed that for average rupture directivity conditions. Table 1. Data used in analysis of forward rupture directivity effects Earthquake Magnitude (Mw) Mechanism Recording Stations 1989 Lorna Prieta 7.0 oblique Lexington Dam Los Gatos Saratoga 1994 Northridge 6.7 thrust Newhall Olive View Rinaldi Sylmar converter stn 1995 Kobe 6.9 strike-slip Kobe JMA Port Island Takatori In Figure 10, we have estimated the ground motions for forward directivity conditions for a magnitude 7 strike-slip earthquake recorded at a closest distance of 6 km on soil. We fIrst modifed the average horizontal ground motion derived from the empirical attenuation relation of Abrahamson and Silva (1995) in order to represent the average of the two horizontal components for forward directivity conditions. The increase is about a factor of about 1.5 for periods longer than about 0.5 second. Based on this average component, we then estimated the fault nonnal and fault parallel motions for forward directivity conditions. These are a factor of about 1.5 higher and lower respectively than the average ground motions for forward directivity conditions for periods longer than about 0.5 second. The combination of these two modifications for forward directivity conditions results in the fault nonnal motion being about 2 times higher than the average given by the empirical attenuation relation for periods longer than about 0.5 second, and the fault parallel motion being about the same as the average given by the empirical attenuation relation. Adequacy of Current Design Approaches for Representing Forward Rupture Directivity Effects In Figure 10, we also compare the spectra derived above for forward rupture directivity conditions for a magnitude 7 strike-slip earthquake at 6 !an with the spectrum from the proposed 1997 UBC for a distance of 5 !an from a highly active fault. This spectrum matches the average horizontal component for forward rupture directivity quite well, but is signifIcantly lower than the fault normal component at periods longer than about 0.8 sec. The spectral shape of the UBC spectrum may need to be broadened to longer periods to accommodate fault-normal motions from forward rupture directivity. Currently, buildings over 60 meters in height inth~Kansai District in Japan are designed to withstand peak velocities of 40 cm/sec without collapse. The peak velocities recorded at Fukiai and Takatori were about 100 cm/sec and 175 cm/sec respectively, and it has been estimated by Kawase and Hayashi (1995) that the strong ground motions in the heavily damaged part of the Sannomiya district in Chuo Ward, Kobe exceeded 100 cm/sec. The fact that many modem structures probably experienced ground motions that substantially exceeded the current design levels without serious damage has important implications for the evaluation of structural analysis and design. Recent modeling analyses by Heaton et al. (1995) have suggested that modem buildings may collapse when subjected to very large near-fault ground motions. The performance of modem buildings in Kobe may provide a valuable experimental basis for assessing these analyses. Engineering Implications of Forward Rupture Directivity Effects: Kobe, Northridge and Future Earthquakes The Kobe earthquake - a worst case scenario for long-period ground motions The Kobe earthquake was a magnitude Mw 6.9 strike-slip earthquake that ruptured directly into downtown Kobe, producing forward rupture directivity effects throughollt Kobe and adjacent cities. The largest recorded peak velocities were in the densely populated urban region, as shown in Figure 1. Worst case scenarios (like Kobe) for strike-slip earthquakes in California There are many densely populated urban regions in California which, like Kobe, are located very close to major strike-slip faults. These include San Diego (Rose Canyon fault); San Bernardino (San Andreas and San Jacinto faults); Long Beach and the Port of Los Angeles (Palos Verdes fault); Hollywood and West Los Angeles (Hollywood and Santa Monica faults); cities on the east San Francisco Bay (Hayward fault); and cities on the San Francisco Peninsula (San Andreas fault). However, California has not experienced a strike-slip earthquake that ruptured directly into a heavily populated urban region, and haS no experience of a strike-slip earthquake rupturing into the downtown region of a major city since the 1933 Long Beach earthquake. We therefore do not have much data from California on the performance of structures exposed to rupture directivity effects from a strike-slip earthquake that ruptured directly into an urban region, as occurred in Kobe. The strong motion characteristics of the Kobe earthquake, including its near-fault rupture directivity effects, are comparable to those that have been recordedclos~to fifteen crustal earthquakes in California in the past 25 years. The performance of soils and structures during the Kobe earthquake may therefore be very useful for predicting damage effects from an urban strike-slip earthquake in California. The Northridge earthquake - a best case scenario for long-period ground motions in Los Angeles The 1994 Northridge earthquake occurred on a blind thrust fault beneath the San Fernando Valley. The earthquake ruptured updip to the north, away from the dense urban region, and produced large peak velocities in the northern San Fernando Valley and adjacent Santa Susana Mountains, as shown in Figure 4. Although the Northridge earthquake occurred beneath an urban region, almost all of the faulting occurred at depths greater than 10 kIn. The great majority of the multi-story buildings in the San Fernando Valley were at least 15 kIn from the closest part of the fault, and were not exposed to large peak velocities due to forward rupture directivity effects, because these buildings are mostly located along the southern margin of the valley. Considering this lack of exposure of the dense urban region to large long-period ground motions due to forward rupture directivity, the Northridge earthquake was a best-case scenario. With the exception of freeway bridges and a few large buildings in the northern San Fernando Valley and adjacent mountains, it did not provide us with data (of the kind available from Kobe) on the performance of structures exposed to rupture directivity effects. Worst case scenarios for thrust earthquakes in Los Angeles Recent studies have proposed the presence of blind thrust faults underlying many parts of the greater Los Angeles region (Dolan et al., 1995). Unlike the Northridge earthquake, which ruptured safely to the north away from the dense urban region, some of these blind thrust faults may rupture directly toward dense urban regions. These include the Elysian Park thrust, which could rupture toward downtown Los Angeles; the Santa Monica Mountains thrust, which could rupture toward Hollywood, West Los Angeles and Santa Monica; and the Compton thrust, which could rupture toward coastal cities between Santa Monica and Huntington Beach. These earthquakes would cause the largest long-period ground motions to occur with.in densely populated urban regions, as occurred in Kobe, instead away from the dense urban region, as occurred in Northridge (Somerville and Graves, 1995). Conclusions The effects of forward rupture directivity on near-fault ground motions are very similar for the 1995 Kobe, 1994 Northridge and 1989 Lorna Prieta earthquakes, even though these earthquakes had different faulting mechanisms. This indicates that for engineering purposes, it is not necessary to distinguish between different styles of faulting in characterizing near-fault rupture directivity effects. Averaged over these three earthquakes, the absolute amplitudes of average horizontal ground motions containing forward directivity effects are 50% larger than those for average directivity conditions for magnitude '7 and closest distance 5 km for periods longer than about 0.5 second. Also, the ratio of fault normal to average horizontal ground motion for forward directivity is about twice as large as for average directivity conditions in this period range. New provisions in the proposed 1997 revision of the UBC for near-fault motions appear to provide an adequate representation of the average horizontal component for fon¥ard rupture directivity conditions, but are significantly lower than the fault normal component at periods longer than about 0.8 sec. Given the widespread damage that occurred in Kobe. and the similarity between the strong ground motions experienced there and those that have been recorded outside urban regions in California, it is important to make loss estimates for urban earthquakes in California based on the performance data from Kobe, and to assess whether they may greatly exceed those of the 1994 Northridge earthquake. If it is concluded that losses of Kobe proportions could occur in an urban earthquake in California, this could have important implications for code provisions and other policy decisions concerning the reduction of earthquake damage in the United States. References Abrahamson, N.A. and R. R. Youngs, "A stable algorithm for regression analyses using the random effects model," Bull. Seism. Soc. Am., 82, pp. 505-510 (1992). Abrahamson, N.A. and WJ. Silva (1995). A consistent set of ground motion attenuation relations including data from the 1994 Northridge earthquake, Seism. Res. Lett. 66, p. 23 (abstract). Dolan, IF., K. Sieh, T.K. Rockwell, R.S. Yeats, J. Shaw, J. Suppe, GJ. Huftile, and E.M. Gath (1995). Prospects for larger and more frequent earthquakes in the Los Angeles Metropolitan Region, California. Science 267, 199-205. Heaton, T.H., J.F. Hall, D.J. Wald, and M.W. Halling (1995). Response of high-rise and base isolated buildings to a hypothetical Mw 7.0 blind thrust earthquake, Science 267, 206-211. Kawase, H., T. Satoh and S. Matsushima (1995). Aftershock measurements and a preliminary analysis of aftershock records in Higashi-Nada Ward in Kobe after the 1995 Hyogo-Ken Nanbu earthquake, ORI Report 94-04. Kawase, H. and Y. Hayashi (1995). Strong motion simulation in Chuo Ward, Kobe, during the Hyogo-ken Nambu earthquake of 1995 based on the inverted bedrock motion, Architectural Institute of Japan Sekiguchi, H., K. Irikura, T. Iwata, Y. Kakechi, and M. Hoshiba (1995). Minute location of fault planes and source process of the 1995 Hyogo-Ken Nanbu (Kobe), Japan earthquake from the wavefonn inversion of strong ground motion. EOS 76, p. F378 (abstract). Somerville, P.G. and R.W. Graves (1993). Conditions that give rise to unusually large long period ground motions, The structural design of tall buildings 2, 211-232. Somerville, P.G. and R.W. Graves (1995). Ground motion potential of the Los Angeles Region. Proceedings of the 1995 Annual Meeting of the Los Angeles Tall Buildings Structural Design Council, May 5. Somerville, P.G., N.F. Smith, R.W. Graves, and N.A. Abrahamson (1995). Representation of near-fault rupture directivity effects in design ground motions, and application to Caltrans bridges. Proceedings of the National Seismic Conference on Bridges and Highways, San Diego, December 10-13, 1995. Wald, D.l. and T.H. Heaton (1994). A dislocation model of the 1994 Northridge, California earthquake determined from strong ground motions, U.S. Geological Survey Open File Report 94-278. Wald, D.J. (1995). A preliminary dislocation model for the 1995 Kobe (Hyogo-ken nanbu), Japan, earthquake detennined from strong motion and teleseismic waveforms, Seism. Res. Lett. 66, 22-28. Yoshida, S., K. Koketsu, B. Shibazaki, T. Sagiya, T. Kato, and Y. Yoshida (1995). Joint inversion of near- and far-field waveforms and geodetic data for the rupture process of the 1995 Kobe earthquake, manuscript submitted to Journal of Physics of the Earth. 17 January 1995 Hyogoken Nanbu Earthquake, M = 6.9 35 *epicenter (JMA) - Mapped Faults within Aftershock Zone H+++4 Surface Rupture of 1995 Event ~~Dense Urban Region Peak Horizontal Velocity ?) 50 em/sec ? lOOcm/sec e 15oc m/sec (j) Clipped recording ol.l "'d 34.8 0 ::l ·5 j ~ 0 Z 34.6 34.4 135.4 East Longitude 135.6 o Km ; 135.8 20 Figure 1. Location of the mainshock epicenter, mapped active faults within the aftershock zone (including surface rupture of the Nojima fault on Awaji Island), the dense urban region, and average horizontal peak velocities recorded from the 1995 Kobe earthquake. 17 Jan 95 Kobe, M6.9 .. Kobe (JMA) FN 846.97 FP 514.95 V 332.62 ~~"""""""'_1'_ Acceleration (ern/sec/sec) FN 104.29 FP 51.88 V 40.08 Velocity (em/sec) FN 26.69 FP 9.01 V 10.51 Displacement (em) I 60 I 50 I 40 I 20 I 10 I o I 30 Time (sec) Figure 2. Recorded acceleration, velocity and displacement time histories of the 1995 Kobe earthquake at Kobe JMA rotated into fault-normal and fault-parallel components. 17 January 1995 Hyogoken Nanou Earthquake, M=6.9 3 ~ Takatori (JR) Kobe (IMA) on -- t:: 0 2"=' , ~ Ij~ Q) \' - Q) 'I' u u , -< \ I, , - 1 1 , , ~ I \ , 1::l I \ , U " " \ Q) 'I -..... , , 0.. , , ", CI:l .. , " \ .. , ... .. ........ 0 I -------- 3 I I ~ Port Island Fukushima 0.0 -- t:: 0 2 .- - -..-. ~ ~ Q) - Q) u u -< - 1 ~ - - 1::l u Q) 0.. CI:l -- ... _----- ....... ----- ~- .- I 00 :-- 1 2 3 0 1 2 3 Period (sec) Period (sec) Fault Normal Fauit Parallel Figure 3. Response spectral acceleration of the fault-normal and fault-parallel components of the 1995 Kobe earthquake recorded at Takatori, Kobe JMA, and Port Island (forward directivity) and Fukushima (neutral directivity). 17 January 1994 Northridge Earthquake, M=6.7 -118.2 \ " -118.4 West Longitude -118.6 ....~ pacific' Ocean " o K.m 34.2 34.4 D Surface exposure ofrecent alluvium * Epicenter (Wald et.al,1994) o Rupture Zone (Wald et.al,1994) / / Dense urban regions Peak. Horizontal Velocity ? 50 em/sec e 100cm/sec e 15oc m/sec Figure 4. Location of the mainshock epicenter. surface projection of the fault rupture model of Wald and Heaton (1994), dense urban regions, and average horizontal peak ground velocities recorded from the 1994 Northridge earthquake. FN t.d .IA. u'l 875.52 r~WIN"I,~V~ FP jJJ"Nu,,~d~~~lJ,~"'t~IiI.Ml386.58 f""r.,~~rr~r~'YYli'""'If~~ V 829.98 A celeration (em/sec/sec) FN 178.43 FP 67.47 V 48.55 Velocity (em/sec) FN 38.09 ~ FP 20.17 ~~.~ V 9.19 Displacement (em) I I 1 o 5 10 15 Time (sec) Figure 5. Recorded acceleration, velocity and displacement time histories of the 1994 Northridge earthquake at Rinaldi rotated into fault-normal and fault-parallel components. 17 January 1994 Northridge Earthquake, M=6.7 3 f' ..- Newhall Rinaldi on '-' I ::: t- o 2 .-.... ~ ~ 0,) - 0,) u u < I - I ~ 1 \ tl "" f .. , ~ ~, , " " 0.. .. " ,... ~ " ' .. " .. ,1 .. " .. -_ ... -. 4IiI __ ,., ----- 0 3 ..- Sylmar Arleta 0.0 '-' c: , 0 , .- 2 , .... ~ , I-l , 0,) - \ 0,) , U \ U < , ,. - 1 " , ~ tl , u 0,) " 0.. " ~ " ,-.. '- , .. , .. ...... ... _-. 00 1 2 3 a 1 2 3 Period (sec) Period (sec) Fault Normal Fault Parallel Figure 6. Response spectral acceleration of the fault-nonnal and fault-parallel components of the 1994 Nonhridge earthquake recorded at Newhall, Rinaldi and Sylmar (forward directivity) and Arleta (neutral directivity). I I f '''''I 1.0 sec 2.0 sec .~1.5 f- - M::6.0 ~ M=6.5 M=7.0 0 M:=7.5 > -< - ~ -------I I 3.0 sec 4.0 sec .~1.5 "i e::: 0 > -< ~ 1 0.1 1 10 100 0.1 1 10 100 Distance (kIn) Distance (kIn) ------------. -- Okm - - - - 2krn 5krn 10krn 20km 30lcm 50krn ~ ",~ , _..:':..:::------ Mw6.5 1.5 1.5 Mw7.0 o 2 4 6 Mw7.5 o 2 4 I 1 6 Period (sec) Period (sec) Figure 7. Empirical model of the fault-normal to average horizontal response spectral ratio, for average rupture directivity conditions, shown as a function of distance for various magnitudes and periods (top) and as a function of period for various magnitudes and distances (bottom). Median - - - _. 84th Percentile --- --- --- --- ,"----... , ...... I ...... I ... I ...... I FN ... I ...... I ...... ... I ... ... I ... ... , ...... .., ... ...... 1 2 3 Period (sec) Figure 8. Response spectra for average rupture conditions for a magnitude 7 strike-slip earthquake at a closest distance of 6 kIn on soil. The fault-normal and fault-parallel components are shown for the median ground motion level. N 2 .- 1-0 - '- 0 '- - ::r= - - (1) .-~- - - on - -- - - - .- ~ '- .- 1-0 (1) > 1 -< - ~ Kobe Loma Prieta Northridge Average ° .. - .- .. - .......... 2 - - - - .....- - - ~- - '- - COd -- ::l ------ "'0 .- ~ (1) 1 ~ Kobe Loma Prieta Northridge Average °0 1 2 3 4 5 Period (sec) Figure 9. Ratio of fault-nonnal to average horizontal response spectra (top) and ratio of average horizontal response spectra to that predicted by the attenuation relation of Abrahamson and Silva (1995; bottom) for near-fault recordings containing forward directivity. The ratios are shown for three recent earthquakes and for the average of all three. _. - Median - - - _. 84th Percentile Forward Directivity URe with Near Fault Factor; 5kmfrom highly active fault ,,--- ... , I I I I I I , , I 1 2 3 Period (sec) Figure 10. Response spectra for forward rupture conditions for a magnitude 7 strike-slip earthquake at a closest distance of 6 kIn on soil. The fault-normal, fault-parallel and average horizontal components are shown for the median ground motion level. The UBC spectrum for a closest distance of 5 kIn from a highly active fault for site category D, which includes a near-fault factor of 1.5, is also shown. State of California Memorandum To Date:~~ne~997 From Subject l~V\ Fred :urner, StaffStr~ct~ralEngineer Seismic Safety Commission 1900 K Street. Suite 100, Sacramento Ca 95814 (IMS 0-4) Phone (916) 327-1606. Fax (916) 322-94715 Internet:: fredt5@aol.com Continuation of Hearing on Near Source Effects on Tall Structures Summary ~heS~r~c~~~alShg~nee~sAssoc~at~c~0:Califor~~aa~d the Los Angeles Tall Buildings :ouncil has asked co =es?o~dt8statemen~smade 2C~~eC8mm~ssiQ~/sMav ~ear~ngG~~earsourceef~ec~s. Background -:-::.-~.~ ---- - '-"" ..... '- ......... ~~a~"?e~h2ps~;es~cu~~deC~2~e3~:=2~:=~~~:~~~:l~~~l~i~gs 'J.ntil 'tie figure :::mt ':::.owc::--,ey:::.c:.'-.:.a~':"/:oerf::::r:,:"."Chairr:l.a"~lUf:\.c c:: umm a ,...;~;::>d ... 1-, e s '" s c:: l' ",.., '- " ,.., at' r r< - 1-, ;=> - " ... '" e c::~;ent' ,= i,..,~,..,r< u '-'~__ .1,._ <.-.1.. __ '"-' \....J .... ...)'j "'. _".'j L- ..... '-"'L. _ ... .1. '-<'._ ......... ''-' c:. ...~.--.4I""-- governnent cOffinunitjs~ouldbecaref~lnot to overly :::.larn people~ about near-source effects because ether site conditions are also 1 ;,...,po,...-;=>..,t--~1-,e~;::>r:",,...~l~pssa"e~'r:n,,'--1j..-.p -""'~s~-;'";::>(':Ie -"'a- "co" I' ......... 1. ....... __'-"'~'--........ .1. '::_ ._ .... .::....:.... .,,_ 'j ,,::) kV ........... \....L ....... _ C.~r,-,J...'-...:... ../ __ ....... ' ,_ .... L. ....~_... _ des i g:-: e dandecn s t:. n.:c ted ;:m i 1d'::" n c; s :::: n good sitesC.i d 'tie 1 =- . " - CommissionerS~api::::-aobserved ::':-.2:' ":::::Jdes a::::-e beginn':"r.g CJ recog~izenear-sourceeffec~s,~~t~arge~~rect~~Ji~y~:l:sesa=e st~llmajo= concerns~ha~are~~tbel~;ajdressed." Speakers Responding to these Statements ~r.C~arlesA.~i::::-cherrepresen:.~n;:.~eStr~ct~ral Associa:.ion cf:aliforn~3(S~AOC;~~l:~resen:.the ,....., - --. :: .: -...v' ...... SeismologyCamm~ttee'srecentlys~ccessfulchanges to tne :997 Uni~~rmB~~~dina=~de~~a~add=ess~ea~-sourceeffec~s.~he ~earS~urceMO 6/30/91 () =oo:n:"ssiC:1. ,....... ,-...f""''''""r~.- -O~ -"V".l..(.~,-_ ~eac::.cn/s c._s,::; s::c::.emen::s ?::cfess:::::: ~ixe,~eat~~and~a:lag~eed~~s~a=e~~ei=~oce:s,~oweve~,~o detai:ed~eviewe~:e~tual:l=~ck81a:e. Jne~ecc~~enda~~c~:~8m aga.:.n -.~ '-'-.;. i:-.:::ieper.den:: a Civil Engineer and chairs SEAOC'sGro~::.d~ccicn ::~e3eis:nolDgi~C:::rnmi::~ee:;";'ld~s2..3.rgel~/ ::ne nea::-scurce c::::de ::::hange as~e:las SlDl_ar Dr. ?:irc:;'er is ~2Wu~de~~2~~~ta__~_ - - :..?9' Counci~,~asalso~eaues~ed~~speak.~~isis an8~gan~=a~~=nc~ ~os~:jeng:~ee~s~~O.~OlG~-a~~ca:=~n:e~e~ce~~dexc~2~ge info::r:1.ac::.i::::n ::::n~~e call buildings. M::. and 0ohns::on In Los Commissioner. des:";,.,::et.rc:i~,::::epal::, and c::msc::::'-.:c::i::::n of ~oh~stonlS aS~~uc~~~al2ng~nee~~=om3randc~ Angeles and~rormer5uild~~cSta~~a=ds Staff Recommendation r .................... c:'''' """"'cr '-" "-"' ..~-..J ...L.. '-'"_ .... Ric:;'ard YlcCar-chy Execut.ive Direct.a.:::- ~3.S ........... -,.....,,~ ... '-' '-- -~~'~ :.:::-cm Page 2 Attachment 7 Response to ProDosed !'v!orarorIum on Base-Isolation and Buildings over 10 Stories in~earSource Testimony Before Seismic Safety Commission. July 10. 199i Los Angeles Tall Buildings StructurJi DesIgn Council Testimony Before the Seismic Safety Commission on Near Sour'ce Effects (July 10, 1997) Good morning ladies and gentlemen. My name is Farzad :-Taeim and together with :VIr. :-Tabih Youssef and Dr. Gary Hart we are privileged to present to you the vie\vs ofthe Los Angeles Tall Buildings Structural Design Council on the subject of a proposed moratorium on base isolated buildings and buildings over lO stories,~vIr.Youssef is Executive Director of our council and Dr. Hart and I have both served as Council president 1 \vill present to you our comments and the three of us can then answer any questions you may have. The Los Angeles Tall Buildings Structural Design Council was formed in 1988 is a nonprofit organization whose members are those individuals who have demonstrated exceptional professional accomplishments in the structural design of tall buildings. \Ve are honored to have among our 18 council members Professor George Housner. the father of earthquake engineering and distinguished life-time professionals such as Roy Johnston. John Martin. Ed Teal and Clarkson Pinkham. Also serving on the council are two principal building officials from the City of Los Angeles, I personally have been involved in studying and eV3.luation of e3.rthquake records for m3.ny ye3.rs. As a structur3.1 engineer. my main interest in earthqu3.ke records has been. 3.nd continues to be. the identification and classification of those characteristics \vhich are most damaging to structural systems. In 1993 as the FEMA/EERI NEHRP Professional Fellow. I had the opportunity of evaluating and classifying all available accelerograms for north and central America. Alaska and Hawaii for the period of 1933 to 1992 (a total of more than 6000 earthquake accelerograms)111 . In subsequent years in an investigation sponsored by USGS we expanded the scope of this evaluation to consider more than 640 components from the 1994 Northridge earthquake[':] . Near source effects. namely directivity, large ground velocity. and acceleration pulses near the source of energy release are real. But this is hardly new information. nor is it a discovery contributed by the Northridge and Kobe earthquakes. The first indication of this phenomenon Page 1 ResDonse to Proposed \loratorium on Base-Isolatlon and Buildings over 10 Stories in i'lear Source Testimony Before Seismic Safety Commission. July 10, 1997 Los Angeles Tall Buildings Structural Design Council was observed in the Chalome Shandon Array #2 record obtained from the 1966 Parkfield earthquake, Much stronger indications \vere observed in arecord obtained from the 1978 Tabas. Iran earthquake and several records obtained from the 1979 Imperial Valley earthquake. To this date the latter records probably represent the largest long-period pulses ever observed. In his 1981 Ph.D. Dissenation P1 . and later during an ATC seminar in early 1984, Dr. J.P. Singh explained in detail the characteristics of near-source earthquake ground motions and their importance in building design[.ll. During the same ATC seminar Prof. James C. Anderson and 1. independent from Dr. Singh. presented similar observa.tions. Furthermore. we took a computer model of a 10 story SMRF building designed and optimized to comply with the 1982 UBC code provisions and subjected it to records containing near-source effects and performed 3. series of linear and nonlinear dynamic analysis[5] We then concluded that ''jor jlexible moment frames the most severe type ofloading as far as damage is concerned is the impulse type ofbase motion which is representative ofsires which are in close proximity ro active faulrs. This type ofmotion tends to concentrate the relative displacement and inelastic behavior in the lower )700rs of structure". We recommended that soft and weak stories be avoided at the base oftaIl buildings. We modified our code designed building to implement a strong column-weak girder philosophy which was not a part of building code for steel structures at the time and showed that such a minor refinement in design could bring about a building which could \vithstand the considered pulses quite successfully..-\ couple of years later we verified our conclusions by application to a 20-story SMRF designed similarly l 6 1 , Y1any things have changed over the r: years that has passed since we announced these conclusions. The codes have become much more prescriptive and provisions which were then on our wish-list are now integrated parts of contemporary codes. If our 1982 code based proper design could withstand near-source pulses successfully, we do not see why the properly designed and proportioned 1995 designs cannot. Structural engineering as practiced by the three of us and our firms in general and seismic design of buildings in particular are a combination of science and professional experience. Proper design of a building requires a considerable amount ofengineering judgment which results from this professional experience. Engineering judgment cannot be extracted from the code Page 2 ResDonse to Proposed :'10ratorium on Base-IsolatIOn Jnd Buildings over: 0 Stories in~e::lrSource . Testimonv Before Seismic Safety Commission. July 10. 1997 Los Angeles Tall Buildings Strucrural DesIgn Council provisions no matter how advanced the codes. Quite to the contrary. building codes e:mbody the absolute minimum requirements deemed necessary to protect against lapses in judgment. E\en the highest levels of technical excellence cannot be trusted to extract proper building design practice from code provisions. Thearticle[~lpublished in the Science :vlagazine and presented to the Seismic Safety Commission during its May meeting does not meet the standards we expect and practice. We would have rejected such a design if it \vas revie\ved as a part of a peer review process. For example, a 20 story frame with column depths changing along the height of the frame is very impractical and is very rarely, if ever, built We have never seen a real lateral frame with the same girder size from the first level all the way up to the 15 th . As Professor hmes Kelly' of University of California. Berkeley said[SI in referring to the base isolation conclusions presented in the same paper "Whar Hearon er af have IS nor a building, bur Q marhemarica! model andyields v/hen ir is specified lO J'ield". In another words. the example frame is not real. Properly designed buildings of various heights and shapes resist severe ground motions by a combination of strength. stiffness. and deformation capability. There is no magic number of stories beyond which a building is safe or unsafe. Limiting the number of stories is a very simplistic and narrow-minded approach to a very complex problem. and in our opinion has no scientific merit. To us proposing such a limit is to show disrespect for the profession of structural engineering. A prudent approach. for well intended individuals and organizations. is to identify problems and then work to rectify the situation (for example as UBC-97 does in response to near-source ground motions) not avoid the problem by banning the practice. The information contained in the Science :vlagazine anicle is not enough to pennit independent duplication of the results Heaton et at. have obtained. \Vhat is the required infomlation? As professional structural engineers we would expect as a minimum the same documentation that we are expected to provide to the State of California for design of a hospital building. For example. (1) a complete user's manual for the computer program utilized including a complete set of verification examples which sufficiently demonstrate the accuracy of the program: (2) a Page 3 Response to Proposed Moratorium on Base-isolation and Buildings over 10 Stories in Near Source Testimony Before Seismic Safety Commission, July 10, 1997 Los Angeles Tall Buildings Structural Design Council complete source code listing, or cross-program verifications \vhich could be used to evaluate the program in detail: and (3) a complete documentation of thOe assumptions made in development of the mathematical model used to represent the building. This type of documentation is standard in our professional practice and is needed if the results are to be evaluated in a professional manner. Not having access to the above information. we took their frame and made our best guess computer model of it the way we would have for a typical office building ofthe same size and height. According to our analysis, Heaton et. al.· s 20 story frame fails the UBC-94 inter story drift limitation in 15 of its 20 stories. Before we continue \vith the subject of tall buildings. we would like to bring to your attention the opinion rendered by Professor James Kelly one of the foremost authorities in base isolation for over 30 years in a letter to OSHPDl 8 ] dealing with the same subject (copies of this letter can be obtained from him or us). He presents some calculations to prove that current code provisions provide reasonable requirements for near-source effects and he states that "the conclusions drawn bJ' Hall et. aI., are based on a modeling ofa base isolated structure that is seriously flawed. Furthermore. the.v state [heir model exceeds UBC requirements. This simply cannot be true and ifthey believe it is true. they must be interpreting the code in a very strange manner. " In order to clearly understand the irrationality of a proposal to ban base-isolated buildings. let us take a look at the worst possible scenario, the most catastrophic event that can possibly happen to base isolated buildings: either they exceed the bearing's deformation capacity and land on the backup gravity system and hence become a stable building a couple offeet away from their original position. or they hit the retaining wall in the vicinity oftheir maximum displacement and hence minimum kinetic energy. While this. of course, is not desirable, it poses minimum threat to life and limb. Compare this worst case scenario to that of more than 2,500 existing tuck-under wood-framed buildings (the type similar to that of the Northridge Meadows Apartments) in the City of Los Angeles alone and hundreds of non-ductile concrete buildings in the historical .~~ corridor of Los Angeles which have the potential ofkilling or injuring hundreds, if not thousands of people. Is it not time to focus our attention and resources on the real problems that we are facing, the real potential sources of loss of life and injury, rather than inventing fictitious ones? Page 4 Response to Proposed :Yloratorium on Base-Isolation Jnd Buildings over 10 Stories In Near Source Testimony Before Seismic Safety Commission, July 10. 1997 Los Angeles Tall Buildings Strucwr:ll Design Councli The fact of the matter is that while our theories have changed somewhat after each major earthquake. the earthquakes have not. The sum total of our experience during the past century strongly suggests that well designed, well detailed. J.I1d \vell constructed buildings perform much better than we design them to perform. A clear case in point may be illustrated by evaluation of performance of extensively instrumented buildings during the 1994 Northridge earthquake!9 1 MJ.I1Y ofthese buildings experienced base shears well in excess of their design strength (sometimes by a factor of 3 to 4), did not experience J.I1y significant structural damage, and exhibited lateral drifts which were far smaller than those predicted by conventional design analysis. Another commonly ignored characteristic is the fact that the motion at the base of significJ.I1t structures is usually substantially smaller than that observed in free-field. This can be seen by a simple comparison of the motion at the base and at the parking lot ofthe Sylmar County Hospital during the 1994 Northridge earthquake. Historical experience of earthquakes shows that generally speaking the geographic area affected and damaged by near-source effects is far smaller than the area affected and damaged by strong ground motion. This is also obvious from evaluation of available earthquake records. l\mong more than 7.000 earthquake records available today the number of records \vhich exhibit strong near-source effects is less than 30 (0.4%). Does it make sense to ban those types of buildings \vhich fare much better during more thJ.I1 99% of cases in favor of those which fare bette:- in less than half a percent of likely motions? Historical experience also shows that most ofthe damage caused by earthquakes is concentrated on irregular buildings and poorly detailed fixed-base buildings of low to moderate height. Should we foreclose on a century of observed information on the basis of a couple of unsubstantiated theories and models? In closing, it is our opinion that properly designed and constructed base isolated buildings as well as fixed base tall buildings are among the safest building types we have in existence. \Ve also think that they are going to be even safer as new insight is obtained by studying the characteristics of near-source ground motions and refurbishing our design and analysis Page 5 Response to Proposed :Y1oratorium on Base-Isolation and Buildings over 10 Stories in Near Source Testimony Before Seismic Safety Commission. July 10. 1997 Los Angeles Tall Buildings Strucrurai Design CouncIl techniques to further enhance the behavior ofsuch buildings. Recent editions ofbuilding codes. UBC-97 provisions in particular. represent a very positive' step in that direction. We strongly recommend that the Seismic Safety Commission re-double it emphasis and focus on the real seismic challenges that faces us as a community, chief among them tuck-under wood framed buildings and non-ductile concrete frames. We further recommend that the Commission urge independent evaluations ofthe scientific merits of the Heaton et. al. article and ask the authors ofthe referenced article to cooperate with such independent evaluations. The Los Angeles Tall Buildings Structural Design Council will be pleased to be a party to such independent evaluation. We thank you for this opportunity to present our opinions on this matter. Page 6 Response to Proposed Moratorium on Base-isolation and Buildings over 10 Stories in Near Source Testimony Before Seismic Safety Commission. July 10.1997 Los Angeles Tall Buildings Strucrural Design Council REFERENCES 1. Naeim. Farzad and Anderson. James C. Classification and Evaluation ofEarthquake Records for Design. A report to EER! and FEMA. Report No. 93-08. Department of Civil Engineering, University of Southern California. June 1993. ! Naeim. Farzad and Anderson, James C.. Design Classification ofHorizontal and Vertical Earthquake Ground A/otion (1933-199-1). A report to USGS, Report No. 7738.68/96. John A. Martin and Associates, Inc., 1996. 3. Singh. J.P.. The Influence ofSeismic Source Directivity on Strong Ground lv/otions. Ph.D. Dissertation. University of California. Berkeley, /981. -t. Singh. J.P., "Characteristics ofNear Field Strong Ground Motion and their Importance in Building Design,"' in Critical Aspects ofEarthquake Ground Motion and Building Damage Potential. Applied Technology Council, ATC-1 0-1, 1984. 5. Anderson, James C. and Naeim, Farzad "Design Criteria and Ground Motion Effects on Seismic Response ofMultistory Buildings:' in Critical Aspects ofEarthquake Ground Ai'otion and Building Damage Potential. Applied Technology Council. ATC-1 0-1. 1984. 6. Anderson, James C. and Naeim. Farzad "Ground Motion Effects on the Seismic Response of Tall Buildings," Workshop Proceedings, Third International Conference on Tall Buildings, 1986. 7. Heaton. T.H., Hall. J.F .. Wald, D. Land Halling,l'v1.W., "Response of High-Rise and Base Isolated Buildings to a Hypothetical tvt 7.0 Blind Thrust Earthquake." SCIENCE. Vol. 267. 13 January 1995. 8. Kelly. James M. "Letter Dated January 22. 1996 to OSHPD". 9. Naeim. Farzad. Performance ofExtensively Instrumented Buildings During {he January }7, 1994 Earthquake. A report to CSMIP/CDMG. Report No. 7530.68/97. John A. Martin and Associates, Inc., Page 7 Date: From: Subj: To: Wednesday, July 9, 1997 12:41 :54 PM gildavis@earthlink.net (Gil Davis) Article fredt5@ao!.com ';ttacnmen: Faulty Towers? Copyright 1~7by Gil Davis All Rights Reserved (415/364-7769, gildavis@earthlink. net) It looks like a great office building. It has an upscale address: 555 Twin Dolp:lin Drive in the Redwood Shores area of Rem'JOodC;~y. Lots of people come and go from the!ar~;eparKing tot. Some drive off for lunch while others head for a jog up to Oracle and back. But lurking beneath the rose-colored facade of this six-story building IS a steel structure that was seriously damaged by the 1989 Lama Prieta Earthquake. Cracks were recently found in over half the 192 critical beam-to-column steel connections in the building's north/south frames, according to a public cocument 'Nritten by iv1s. Maryan n Phipps c f Deg enkolb Er-:g ineering I: San Francisco. In her report to the building's owner, Pacific Dolphin Corporation of San Ramon, she said 44 of those steel connections ranked 10 on a scaie of 0 to 10 with 10 equaling "complete loss of moment resisting capabilities of the connection." (Earthquakes induce "momer,t" forces in this type of building.) An additional 51 connections were given a ranking of 8 and three more were ranked 4. There was almost no damage to the east/west steel framework and the building is fully capable of supporting gravity loads, she said. Ms. Phipps concluded, "Under seismic leads, however, the building In its 7/9/97 i:"'r~mc, ___ .......... -..J ?age~ Park. He said the destruction took place when the bay fill under this building rocked back and forth a total of 4.5 inches at a peak acceieration of °.29 0 f eart h'S gravity. "An earthquake shakes the ground 'I-lith a wlce range of frequencies," Holzer said. "Bay mud will take the low frequencies of about one cycle per second and amplify them. Unfortunately, :he one-per-second frequency IS about the natural frequency of high-rise- buiidings between SIX to 10 stories ta \\." He explained the destructive phenomenon oy c:tlng a pendulum~.ovlng back and fonh at one cycle per second. A little push applied at the right time can make the pendulum swing in a much wider arc. The danger for buildings located on Bay)~reafill is highlighted by the f ac t that 70 percent of the Lama Prieta Earthquake's destruction took piace In structures located on bay fill, said Holzer. He said geologists have known aboutthE~ampiification of bay fill since th e 1960s when instruments :ocated 01 bay r-l!,Ja~2cordedthe force of ato:ilic bomb explosions at two to three times more than motions recorded on bedrock. Bay Area Problem? An estimated 900 medium to high-rise steel buildings in the Bay Area could have been impacted by the Loma Prieta Earthquake, according to Professor Barclay Jones of Cornell University wno is researching the number of different types of buildings in the Bay Area. He estimated there are 400 medium-rise 'ouildings (100,000 to 200,000 square feet) in the earthquake's impact zone and about 500 high-rise buildings (above 200,000 square feet) in the same area. One of the most important structures 11 the Bay Area that's built on 7,/'9,/97 ?ace -5 Redwood Shoresc~rrentlycontains abou: 2 million square feet of office space, said Joshua Steinhauer, a reoresentat:ve ror Redwood Shore Properties. He said more construction by Oracle, Electronic Arts and Westport should bring the total square footage to 6 million and house some 24,000 workers. Calls to 15 building officials up and down thePenins~lafound fiO~ewiy discovered steel buildings with problems like those uncovered at 555 Twin Dolphin Drive. Budding officials said that doesn't mean other Peninsula steel structL:~es were not weakened by the Magnitude -;-.1 LamaPr~e::aEarthouaKe. i: j:..;st means building owners don't want to know about earthquake damagebE~causeof th e high cost of repairs. As a result, the only time such damage comes to light is when a building IS for sale and a potential owner ;,nsists on a structural inspection, they said. In the greater Bay Area, 24 to 40 steel structures are now known to have been Significantly camagea c;yt~eLorna Prieta EannqL:a:"'8, est:rT13:eo two structural eng ineers. Building Owners Warned As early as November 1994, the California Seismic Safety Commission warned building owners, city councils, bUilding code officials and engineers that buildings exposed :0 strong ground shaking from the Northridge and Loma Pri eta earthquakes should be inspected :0 see if their steel joints were cracked. "Because the Northridge eartr,quake damaged over 100 steel rT,omem resisting frame buildings, and because the future performance of this type of building is of concern throughout California, the Seismic Safety Commission ?3.0e 5 and progressed across the panel zone. There are some instances where columns fractured entirely across the section depth. "The detection of structures containing this damage !s quite oifficult. Even structures with a great many fractured ccnnections often exhibit little outward evidence that sTructural damage has occurred.... Reliable detection of this damage requires removal of fireproofing and careful visual and non-destructive examination of the connections. "His:or:c practces used 70r steel~omen:'esistir,g G::Jnnect:ons are no longer approorta:e for oesign andcons:rLC'~:onof new steel Duildings. "As a class, existing undamaged steei r.'ol1lent frame buildings appear to have a lower risk of collapse than many other types of existing buildings with known seismic vulnerabilities. Consequently, mandated oremer~Jency programs to upgrade the performance of these buildings does not appear necessary to achieve levels of life safety protection currently tolerated by society. "However, the risk of collapse is definitely greater than previousiy thought. Indiviauai Ql,vners SllO uid be made aware c f the Increased ievei of seismiC r 1 s k and encouraged to perform modifications to provide more reliable seismic perfo rmance. "Following strong ground shaking, SMF (steel moment frame) buildings incorporating vulnerable connections should be subjected to rigorous evaluations to determine the extent and implications of damage." The distribution list fo r th is adviso ry i1eluded major professi 0nal associations for architects, building owners, civil engineers, structu ral eng ineers and building officials in the Bay Area, said Rojahn. How It Happened Since the Northridge Earthquake, structural engineers say they are looking ?ace -; "However, it is clear that where these fractures occur, 80th the lateral stiffnes;3 and strength of the building is reduced, resulting in lower capacity to resist lateral forces such as are induced by strong winds and earthquakes." Hamburger said the public should understand that building codes typically aren't designed to prevent damage to a b'Jilding from an earthquake, but only to prevent collapse so as to protect the lives of people inside. He said it would probably cost more:~anCalifornia could afford to construct steel buildings that would resist an earthquake without damage. Faith in steel buildings goes back to t:l8 1906 San Francisco Earthquake when some 20 steel structures performed well, he said. "This experience created the myth of invulnerability," Hamburg'9r saId. "Engineers didn't want to let go of th at. I t took th e Northridge Earthquake to reexamine that myth." Up until the 1970s, steel buildings had been largely assembled using bo Its and rivets. During the early 1970's, labora:ory tests on scale models showed steel oeams and columns couid be weldedtoge:~9r.~esaid. "Over time, the kinds of steel 'Jsed, the Sizes, [',ow they were 'iveldea together and other factors essentially revolutionized the industry, but building codes were still being extrapolated from early tests on scale models. Very few full-size tests were actually done," he said. "What happened in the 1994 Northridge Earthquake was that sENeral hundred steel buildings developed fractures in the connections between horizontal beams and vertical columns," Hamburger said. He said both the damage and its severity were not anticipated by structural engineers. "It was more damage than we had everSE~enbefore," Hamburger said. "There wasn't any case in which it was life threatening except a two-story 7/9/9: ?aae0 Because of the expertise he's deveiooed. Castro said he's scheduled to speak at major steei industry conferences and the California Seismic Safety Commission. "I'm urging everyone :0 really fix ::::s orobiem and not sweeot~ings under the rug," he said. "l don't want the litigation that could follow a major earthquake because that could mean hundreds, if not thousands, of people had died In co Ilapsed steel bu ildings.·' Castro saia the main structt..:rai arab/em that was uncovered by the Northridge Earthquake ',';'as :r,e "i::;rit:leness" of welded connections Detween steel girders. The welds didn't have the toughness to resist tr,ebencin~jand twisting forces that occur during an earthquake. "What should be happening right now is for the state legislature to urge Congress to supply low-interest loans so building owners can afford to repair and upgrade their structures," he said. "If we don't take this constructive route, I predict cities will eventually pass ordinances mandating the removal of all brittle welds or the building will have to be vacated, just like was cone 'Nith non- reinforced brick buildings." Castro said structural engineers should especially be promoting this legislative avenue because if one or more high-rise steel buildings collapses during an earthquake. people are going to be calling for criminal prosecution. "\ know what engineers will say in court. They'll say I used ths design, and these materials because it's cheaper for the owner and my Duddy down the street does t:-,e same thing,"~esaid. "But that's not a standard of care, that's a pattern of negligence." --; 19/'T ?2.ge above~rou nd \ncreases, But:o n said. "vVith seismic isolation, a building's top floor might experience 0.1 gravity while a non-isolated structure's top floorn~ightr,ave to resist r,early 10 times that motlOr.,'· 1e said. "People in tall b'Jildings experience this ohenomena in an earthquake when they sway back and forth." Button said dynamic isolation was much more accepted in Japan after the Kobe Earthquake in January 1995 compared with the United States following the Northridge Earthquake in January 1994. Japan ncreased the rate of constructic:-1 of seismically isolated ::Julidi:lgs from an average of eight :Jer year to 200 per year. Bycontras~,:here was aimost no similar increase In the US after Northridge, he said. "Obviously, the Japanese are taking their earthquake problems a lot more seriously than we do in this country," Button said. ### Sidebar: INhar You ShOUld Know: A reiatively new, six-story office building in Redwood Shores may be th e tip-of-the-iceberg In terms of structural damage caused to steel buildings in the Bay Area by the Lama Prieta Earthquake. An estimated 26 to 40 Bay Area steel buildings are now k,10wn to have been damaged by the 1989 Loma Prieta Earthquake. They are in the counties of Alameda, San Mateo and Santa Clara. Anestima~ed900 Bay Area medium to high-rise steel buildings could have been impacted by the Magnitude 7.1 earthquake on Oct. ; 7, 192,9. The condition of these 900 buildings is largely unknown because help develop new building codes. A Los Angeles attorney immersedi~representing property cwners involved in Northridge Earthquake litigation is calling for public loans to help owners of steel-buildings. Using this money owners could inspec: and repair their structures before another earthquake results In collapsed buildings and "unlimited liability" for anyone involved In constructing such buildings. ### ----------------------- Headers --.-----------------------.------- From giidavis@earthlink.net Tue Jul 8 i -\ :36:59 i 997 Return-Path: <gildavis@eanhlink.net> Received: from italy.it.earth!ink.net (italy-c.it.eanhlink.net [204.250.46.18]) by mrin58.mail.aol.com (8.8.5/8.8.5/AOL-4.0.0) with ESMTP id LAA11469 for dredt5@aol.com>; Tue, 8 Jul 1997 11 :36 :56 -0400 (EDT) Received: from 153.34.226.29 (1 Cust29.Max40.San Francisco2.CA.MS.UU.NET [153.34.226.29]) by italy. it. earth link. net (8.8.5/8.8.5) with SM TP id IAA22550 for <fredt5@aoi.com>; Tue,S J:.JI 1997=8:36A:=<~7CO(PDT) Message-ID: <33C1 FCFE.1A89@eartnlink.r~e:> Date: Tue, 08 Jul 1997 08:40:31 +0000 From: Gil Davis <gildavis@earthlink.net> Reply-To: gildavis@earthlink.net X-Mailer: Mozilla 3.0-C-NSCP (Macintosh: U; PPC) MIME-Version: 1.0 To: fredt5@ao\.com Su bject: Article Cantent-TYPe : textlpIain; charset=ISO - 8859- i Content-Transfer-Encoding: 8bit - '0 i- I ,I J I '::J :' ?age :5 Clarendon AamIIlive elemenl8ry School ........BIlingual !icullul'1ll Program s-.cs Community Progl'1lm 5ClO C1l1111nOon AYlIIlue San "....-co, CA 14131 .15.751.2711 Hillary E. Gite1ltan '!be Envirormental Review Officer Planning DepartItent 1660 Mission St., 5th Floor San Francisco, CA. 94103-2414 Dear Ms. Gitelman: As the principal of Clarendon Alternative Ele.m::mtary SChool I am requesting that we be provided with any and all available seismic studies done on Sutro 'I\:IWer before any additions are approved. Concerned neighbors of the school have inforned the staff and parent groups of a plan to add another HlJI'V tower within the existinq structure. Clarendon Elenentary houses over 560 students in grades K-5 and 50 staff rretbers. In concern for the health and safety of these individuals our school carm.mity would like to be assured that we will be safe fran any future Fall Zone disaster or other environrrental dangers involving Sutro Tower. I respectfully request that the EIR place Clarendon Alternative ElerrentaIy SChool on the list to receive a revised EIR report. Sincerely, Dr. v. Kanani Choy Clarendon Principal Lynn E. O'Connor, Ph.D. 4440 23rd Street, San Francisco CA 94114 Phone: (415) 821·4760 September 2, 1997 Hillary E. Gitelman The Environment Review Officer Planning Department 1660 Mission Street, 5th floor San Francisco CA 94103-2414 Dear Ms. Gitelman: Fax: (415) 641·7047 E·mail: LynnOC@aol.com I have recently been informed that Sutro Tower Inc. is planning to add a new support structure with additional antennas which will broadcast digital TV as well as analog NTSC television from existing antennas. I am writing as a citizen of Noe Valley, San Francisco and as a clinical psychologist practidng in the city, to object to this plan. I have lived and raised mv children under the shadow of Sutro Tower, with a .- vague sense of unease which I managed to put aside. However, as we have all become increasingly alert to the dangers of "minor" radiation and other environmental hazards, it seems incredible to me that Sutro Inc. is planning to expand this already questionable artifact of our technology. The claim that this level of radiation presents no danger to people or the environment may turn out to be equivalent to the tobacco companies asserting that nicotine is not an addictive drug, nor detrimental to our health. It was in the financial interests of the tobacco companies to withhold growing evidence about the dangers of tobacco, and it is certainly in the financial interests of Sutro to withhold evidence related to the effects of various levels of radiation. Those of us who live near Sutro know that it effects our use of electronic equipment, and most certainly it must be having some kind of effect on us personally, on a physiological level. As a clinical psychologist, I can tell you that there are profound psychological effects on people who are forced to live with technological dangers. They either become extremely anxious --an adaptive response to an environment of danger, and one that when possible leads to safety-seeking action-- or when they perceive that no action is possible, they may go into denial about the danger. I was pleased when 1 heard that there is a neighborhood group attempting to stop the proposed expansion of Sutro, because it indicates that at least some of my fellow citizens are ready to step forward and take action. And 1 certainly want to join them, however I can. I strongly object to the plan to expand the Tower; and until it has been proven without question that there is no danger from the radiation and other effects of the Tower, I would support the city refusing to sanction its expansion, And in fact, I would support the dty beginning a process which could lead to taking it down altogether. Sincerely, Lynn O'Connor cc: Pam Patania Steve Nahm Kathryn L. Goldman 220 Palo Alto Avenue San Francisco. CA 94114 415/681-6488 September 7,1997 Hillary Gitelman Planning Department, City and County of San Francisco 1660 Mission Street San Francisco CA 94103-2414 Dear Ms Gitelman: I am concerned about the proposed expansion of Sutro Tower for Digital Television (DTV) transmission. I am not a technical expert, but I have carefully read the entire Draft EIR and have done my best to understand the full range of issues. I am a homeowner and direct neighbor of the tower, living approximately 500 feet from its base. My home is roughly at location #3 of their measurements of RFR emissions, where the RFR power density is at almost 7% of FCC guidelines. This is one of the closer (though fortunately not the closest) locations. Before buying our home in 1995, we thoroughly researched the presence of the tower, contacted Sutm Tower, Inc., and were more or less satisfied. At that time, we were told by them that the lifetime of the tower was approximately another 20 to 25 years. It seems odd that in fact the tower at that time had already prepared documents for expansion to DTV and thus plans to extend its life, even while telling us that changes in technology would tend to terminate its value. The proposed expansion of the tower (the DTV mast) only came to my attention through neighborhood action. I am surprised that this expansion was not brought to neighbors' attention by City Planning, and 1request that 1be placed on all neighbor notification lists which City Planning might require for Sutm Tower in the future. I respectfullY request that the Planning Department denv the requested expansion of Sutro Tower to add a mast for DTV transmission, or at least postpone this expansion until all concerns can be adequately addressed. Points OfConcern 1. Structural soundness and impacts in case of disaster. How will the structure be impacted by the addition under various possible disaster scenarios: earthquakes of various magnitudes; small plane hitting tower; winds of roughly 100 mph; terrorism - all of which unfortunately are quite possible. What are the health and biological tissue impacts? While these may not be germane to resolving this permit, they should be of real importance to the city government Rarely do we have an opportunity to re-consider things that may be harmful to the people of the city. This is such an opportunity. Much is now known that wa" not when the city originally allowed this construction. I have been informed that Sutro Tower is the only such tower located so close to people's homes. That means that it is possibly the only site where people are exposed for long periods (daily - 8 to 12 hours or more) to the concentrations of RFR that it emits. Although the percentage of allowable emissions may range only up to 6 - 14 % in our homes, this is aI~onstantin our bodies and cells, rather than something that only happens intermittently, as with the Mount San Bruno site, where people might hike or picnic for an afternoon, but not live all the time. Goldman Letter to Gitelman RE: Sutro Tower . P. 1 The preliminary EIR raises the following areas that give cause for concern: - It is not clear that the same standards should apply for "general public exposure" and for people living in homes where exposure is a constant day after day. Nowhere does the EIR address this question. . .. How do we know for certain that exposure will notincrea~emore than IS antIcIpated during the period of time when there will be both DTV and NTSC signals? How do we know that this additional unexpected exposure does not raise the possibility of a slight thermal effect that makes possible the types of biological and physiological damage mentioned as possible, though not likcly'l Even if much research shows no damage, as a PhD scientist, I know that this does not mean the issue is resolved. Throughout the history of science, we have seen many instances where' generally accepted scientific views' later turned out to be incorrect. For a list of relevant citations from the Draft EIR, see attached Appendix. 3. Compatibility with the City's Environmental Planning Although the site itself is and would function consistent with its zoning, that zoning is not in character with the surrounding neighborhoods, nor has it been, since construction. The planning director at the time of construction, Allen Jacobs, told the Planing Commission in 1970 that "he could not recommend that the project be built, " but that he did not see how to prevent it. In fact, The Planning Commission had voted 6-4 against the lower in 1966, but that was 2 votes short of the 2/3 needed. In other words, although we are now 'stuck with it' (so to speak) there was considerable disagreement as to whether it was appropriate for the location and should have been built, even \vithout the wealth of controversial data that now exists. With regard to the city's eight Priority Policies, I believe problems exist with: protection of neighborhood character This is a neighborhood of single family detached homes. It is totally out of character with the neighborhcxx1 and always was. maximization of earthquake preparedness No scenarios exist for the tower as is; let alone studies done to determine the: impact of proposed changes on homes in neighborhood abutting the site in case of earthquakes. No studies have been done of the impact of the proposed changes on possible flooding of the immediately adjacent reservoir. These arc potentially serious issues which could cause loss of life, as well as considerable financial damage for homeowners and the city. Noise. Although the Draft EIR states that no change in the noise of wind through the tower is expected, no data is provided to indicate that this has been computer-modeled or studied in any way. We would like such proof. Hazardous materials. Because painting of the tower caused considerable damage to local homes and automobiles in the past, we would hkc to be assured that the paints referred to on p.3-40 will not again be handled in ways that cause damage. In conclusion, I ask you not to permit this modification to proceed until studies are done to provide the above information, and it is made a\ailable to the city, the interested neighborh()(x1 ~"isociationsand the immediately adjacent property owners. I oppose extending the useful life of the tower because (1) San Francisco should not be the sole city in which residents are exposed so closely to the ongoing unknown effecl"i of RFR; (2) the harmful potential when the 'Big One' Earthquake finally occurs is tremendous, whether from collapse or furthering the likelihood of reservoir nooding; (3) it is unnecessary, since technological changes since the late 1960's make it possible to use other sites. Sincerely yours, Kathryn L. Goldman Goldman letter to Gitelman RE: Sutro Tower - P.2 APPENDIX - Citations from the Draft EIR indicating possible adverse health problems Examples: 1. p. 3-16, Draft EIR. "While the substantial weight of scientific research has indicated that no adverse health effect,> would result at low power levels, some findings have been contrary. The Technical Report concludes that the adverse effects identified were the result of a thermal effect (a measurable increase in body or ccll temperature).....or that the evidence for adverse effects was inconclusive .... " '") Possible Impacts On The Eyes: p. 3-18, Draft EIR. although vision was noll affected "ophthalmologic examinations showed various eye abnormalities." 3. Central Nervous System Effects: p. 3-20, Draft EIR Here studies have been done primarily on animals. "Changes in the central nervous system were seen at relatively low specific absorption rates in two studies, but their significance with regard to human health hazards is unclear." In other words, there is no proof that harm is likely - but there is rca')on for further study before drawing conclusions either way. (To me, this suggest,> that one would not expose dozens of households (those living closest to the tower) to such a condition, but would seck ways to eliminate the possible arm, were such alternatives possible. ) Altering the Amount of Calcium-Binding to Cells and Tissues: "There arc contradictory findings ... Resolution of this issue is not likely in the foreseeable future. This effect, if valid, appears to be a non-thermal effect. What this does to the human body is still unknown. 4. Lifespan. - Contradictory effects here as well. p.3-21, Draft EIR. "There appears to be a tendency toward enhanced lifespan for mildly thermal (elevated temperatures) exposures but reduced lifespan when the RF exposure is combined with chemical carcinogens." One might well expect such a combination for inhabitants of a city like San Francisco. 5. Cardiovascular Effects. Here, as in other areas, the impacts resulted only in combination with a thermal effect. 6. RFR and Drugs. p.3-23, Draft EIR. "lll\estigations that sought interactions between RFR exposure and psychoactive drugs yielded unclear or inconsistent result'). At relatively low RFR levels, the role of heat regulation in the results is unclear and the occurrence ofrelatively high local specific absorption rates in the brain cannot be ruled out. " 7. Cancer. two recent studies done in England by 0011. et al (1997a, b) (Draft ElK p. B-18-19) with a tower similar to Sutrn Tower suggest that leukemia occurred more often for people living closer to the tower, at twodim~renttime periods. Since they defined 'close' as '2 kilometers' and here 'close' is less than a third of a kilometer, one would suspect that the pattern (and therefore the hazard) may be even stronger. Basically, the EIR summary shows that there is a lack 01" data on the impact of long-term, close up exposure to humans, as occurs for those of us living near the tower. The fe ..v studies that exist suggest the possibility or leukemia, but do not prove it~~itherway. In summary, although no evidence of actual hann has been found at the levels to which residents would be exposed, such harm cannot be ruled out, although the EIR a')serts thallhe weighl of reliable scientific evidence suggests there is no problem. many situations have happened where il was the lone individual in opposition Lo some given established belief who turned out to be correct. This is not always true, of course, but it happens often enough that these indications 01" possible harm should not be ignored by the City. Goldman Letter to Gitelman RE: Sutro Tower, P. 3 %omas & Jocfy 1(pm6er;g 50(jfen6rook.~venul~ San 'francisco, (5t 94114 September 3, 1997 Hillary E. Gitelman The Environmental Review Officer Planning Department 1660 Mission Street, 5th Floor San Francisco, CA 94103 Dear Ms. Gitelman; This letter is written to protest the Draft EIR filed on behalf of the Sutro Tower Inc. for the addition of Digital Television capability. In my opinion, this EIR is severely deficient in a number of areas, namely: 1. The EIR does not adequately address the exposure levels of RFR that will saturate the neighborhood during the construction phase, when the current analog signal antennas will be inactivated and replaced by temporary antennas mounted at a location considerably closer to areas of public access. The EIR does not address whether the levels of RFR contaminating the neighborhood will exceed Federal limits during the construction phase of the project. 2. The EIR states on page 1-4 that aUxiliary "standby" antennas are mounted on the first rung of the Tower, and that although they are apparently used infrequently, three of the auxiliary antennas emit more power than the main antennas. Since these auxiliary antennas are also closer to the surrounding neighborhood, we must conclude that their RFR emissions exceed those measured, calculated and quoted in the ErR The EIR appears to have presented data that can be construed as "the best case scenario", and not the more realistic description of the way in which the Tower is actually used. The EIR is therefore deficient in not addressing the levels of emissions that contaminate the neighborhood under all conditions of its use. It should calculate and measure emissions at all relevant locations under conditions in whichall of the auxiliary antennas are operating, since this is a possible state that the Tower is currently equipped and ready to operate. Without this information, it is not possible to accurately assess the likely consequence of the additional DTY antennas. 3. The EIR states on page 1-4 that the auxiliary antennas are describe on page 2-5. They are not. 4. On pare 1-6, the EIR states that the new DTV antennas will not be visually intrusive, and on page 3-28 that the new antenna structure would be painted the same color as the tower. It is worth recalling that in 1966 the Sutro Tower Inc. represented to the residents of San Francisco and to the Board of Supervisors and Planning Commission that the Tower "will be painted a neutral color consistent with the surroundings" and not the ugly white and orange stripes that it is. More recently, we have been told that the addition of strobe lights to the tower would obviate the need for the orange and white striping. Perhaps it is time to require that the Sutro Tower Inc. comply with the design that they originally proposed and for which approval was obtained. 5. The EIR presents theoretical data on RFR exposure levels at a distance of "one city block" from the tower, but does not address RFRlevE~lsat the closest points of public access. The description on page 1-5, paragraph 3 mentions that the closest residence is 250 feet from the base of the tower and that the closest public roadway is about 150 feet from the tower, but it does not make clear how these locations and distances relate to the actual perimeter of the Sutro Tower property and to the various different antennas that are used at the Tower. Since public access in the region of the reservoir directly abutting the Sutro Tower property is in fact heavily utilized, this is more than a theoretic consideration. 6. According to Mr. Lee of the San Francisco Department of Public Health, he has identified at least one "hot spot" near the Sutro Tower where it is likely that there are levels of RFR significantly higher than those noted in the EIR. He has stated in public meetings that the levels of RFR emissions were sufficient to melt paint from a metal sign at this location. If this is indeed the case, then the theoretical treatment described in the EIR is inadequate as it fails to identify such "hot spots", and its findings cannot be accepted as a valid representation of the RFR levels contaminating the vicinity of the Tower. 7. On page 6-5, the EIR states that San Bruno Mountain would be able to serve all of San Francisco with DTV signals and on the same page the EIR states that it would not be able to serve all of San Francisco. Thus, it remains unclear from the statements in the EIR whether or not San Bruno Mountain is in fact a viable alternative. 8. The EIR states that the Sutro Tower is currently not in compliance with the current Building Code and thus can be considered to be an earthquake hazard today..Although reinforcement of the current structure will bring the Tower into compliance with the 2 current Building code, it is reasonable to expect that this state of compliance will be only temporary. The Code has been revised on several occasions since 1966 when the Tower was built, and it will certainly be revised again as more is learned about the forces unleashed in earthquakes and the response of buildings to them. It is therefore reasonable to expect that the Tower will again be in non-compliance in the future and that the additional weight of the new DTV antenna at the highest elevations of the Tower will exacerbate the hazard. The history of the Tower is that it has not been in compliance with contemporary building codes for many years, and we can confidently predict that it will again be in non-compliance in the not too distant future. Careful consideration must therefore be given to the various scenarios that will likely result from catastrophic structural failure. The EIR does not adequately address these concems. 9. According to a published report in July 21, 1997'~Broadcasting& Cable" in which Mr. Gene Zastrow, the general manager of Sutro Tower lnc., is quoted, construction to prepare for the DTV antenna system has already begun. This would seem to violate the purpose and intention of the EIR and its public review. 10. Subsequent to the initial building permit for construction of the Sutro Tower in 1966, there have been many changes and additions to the Tower that have included a significant increase to its size and height, numerous construction projects, as well as frequent upgrades to improve transmission, add capacity and signal strength. We can expect this scenario to continue as the technology of transmissions evolves and the requirements change. The EIR ignores the impact of any future changes and additions and mentions no commitment by Sutro Tower Inc. to limit the number of antennas or the level of RFR contamination to the levels proposed in this phase. What assurance do we have that this proposal does not represent a "low ball" estimate designed to provide a structural capability that can accommodate significant increases in RFR transmission in the future, increases that may not require another EIR and its accompanying public discussion? 11. The EIR states that the level of noise and dust contamination of the neighborhood will not increase significantly as a result of the construction for the proposed DTV antennas. This presumes that the current level is both acceptable and within the accepted limits currently applied elsewhere in the City. In fact, the Tower has proven itself to be an exceedingly poor neighbor in this regard. For instance, although it is common practice in the City to create barriers around structures to insulate surrounding homes and buildings from detris such as sand spray, paint spray, and falling objects that are the unavoidable consequences of all construction projects, the recent refurbishing of the Tower inundated the neighborhood with sand, paint chips, and paint spray. The Tower was sandblasted frequently during times of heavy winds and without any 3 barriers, resulting in massive sand spray and paint chips spread over large distances around the neighborhood. After repeated objections from residents living near the Tower, cloth barriers were placed around the areas of sandblasting, but these were largely ineffective. The Sutro Tower Inc. made no effort to assist in the cleanup of the sand or paint chips. During the painting phase that followed, paint spray damaged many homes and automobiles in the neighborhood, and this is itself ample testimony to the ineffectiveness of the options for protection that were available to the Sutro Tower Inc. We can attribute the blame to little, no or insufficient effort paid to protecting the immediate environment of the Tower, but this is only part of the problem. The enormous size of the Tower is certainly the dominant: factor, since creating barriers strong enough to survive the high winds and large enough to cover the tower is probably prohibitively difficult and expensive. Indeed, representatives ofSutro Tower Inc. have indicated that the problems in the Twin Peaks neighborhood caused by routine maintenance of the Tower are unique to the Sutro Tower and are not encountered at other locations around the country because only the Sutro Tower among all of the transmission towers of this size in this country, is situated in a densely populated urban environment. Therefore, the issue that must be addressed is whether a construction project of this magnitude and the routine maintenace of the new structure can in fact be carried out in a residential neighborhood without unreasonably impacting the persons and property in the immediate vicinity. Past performance tells us uniquivocally that the Sutro Tower Inc. cannot. The EIR should evaluate the consequences of the proposed construction and maintenance of the new antenna structure with standards that are relevant to neighborhoods elsewhere in the City, not to existing substandard levels that currently exist at the Tower. That is, it is not acceptable to simply state that the conditions during construction would be no worse than those now present at the Tower site. Since the current situation at the Tower is not the proper standard, the comparison that the EIR makes to existing conditions is inherently misleading and unacceptable. Any valid comparison or evaluations should address in detail the specific measures that would be employed to eliminate any and all material contamination of the neighborhood that might be a consequence of the proposed construction. Sincerely, Thomas Kornberg 4 226 Palo Alto Avenue San Francisco, CA 94114 September 7', 1997 Ms. Hillary E. Gitelman The Environmental Review Officer Planning Department 1660 Mission Street, 5th Floor San Francisco, CA 94103-2414 Dear Ms. Gitelman: I am writing to you to comment on the Sutro Tower DTV Environmental Impact Report. Specifically, your inadequate evaluation of the noise factor currently extant at the tower, and the fact that placing another 120 foot steel beam, plus guy wires and antennae, etc. up there will make it worse. The tower makes a lot of noise. Even in mild wind, the hum from the guy wires and tower legs sounds like a hurricane-level storm. When the trees are just gently rustling in the wind, the tower is howling. I can't believe that you have talked to anyone about this issue or come up to the tower on a windy day, or you would not have downplayed the issue as you did in the draft EIR on pages 3-35 and 3-36. There are many other factors that also need addressing -- earthquake safety in the neighborhood, electromagnetic radiation effects from both existing analog and the new DTV, and further noise pollution to name just a few. There is an ideal non-residential area in which to place the tower, at Mt. San Bruno. If this was done, Sutro Tower could be phased out and eliminated when it is no longer needed. I urge you to make stricter evaluations of these issues before completing the final EIR, and request wind-tunnel studies before construction begins. I am enclosing a letter from the files of Mr. Jules Heumann to let you see the level of frustration that has been here on this issue ever since the tower was built. This file (two inches thick) is available for your perusal. I will bring it to you any time you ask for it. It includes letters from the Department of Public Health and the Board of supervl.'sors, a\stic engineering reports, to name a few. Sincerely, r,~ r---. '\ '" .}~ ~~\,\.~ Edward Paul Braby " ....·'"'iLES M. HEUMANN ., .. 20 May 1916 Mrs. Charlotte C. Poole, Cha.1.rma.n CoI:mJ.1ttee #1 Civil Grand Jury Room 165 City Rall San Francisco, Cal1.forn1a 94102 Dear FIrs. Poole: Spea.k:1Dg both for the Twin Peaks Improvement Association and for m;yself personally, I again thank you and your Committee for the time and obvious interest at your meet1:cg with us on Thursda\r, 6~1916, at the Midto.lm Terrace Recreation Center. I hope you will forgive this belated response -to follow up the SUbject I broached; several files had 1;0 be searched for all the printed ma.tter we could find. The subject is the Sutro Tower and the wind noise emanating therefioom. To briefly review the story: '-the Tower was begun in approximately 1972 and to ;a design substant!.uly eha.nB'ed from that which was publici,zed as f1.na.l approval. In approximately 1974 the Tower had reached its height and the antenna. were insta1.led. So far, other than noises due to const:rc.ction (which were expected and. toler· ated) there were no other undue noises from the Tower. Commencing with the installation of' the antenna gJy 'Wires a most annoying noise commenced which is explained in the enclosed letters. To date, despite many promises, nothing has been done to alleviate the truly serious annoyance. The enclosures are OlIr letter of 8 March 1974 to Sutro Tower, their answer of 3 July, our letter of 30 March 1975; the files reveal no other correspondence. You must realize that a constant telephonec~01IIIUWlicationwas main tained with Mr. Harry Jacobs and the writer as well as nth Mr~Jacobs and the current presidents of TPIA. Approximately one year ago a fo:rma..l complaint was registered with the Noise Pollution Division C)! the City Real.th :Depart ment (Mr. Robert McDonoU8h); upon his first visitation omd read.1ng with a decibel meter he was asto'OIlded a.t the volume of the rea.diJ:lg observed which was :f:'a.r in excess of the legaJ. 17e 51"- Oerzn&1n Avenue· S&n :P'r&noleoo.C~lrornl&? 94114 ? .. " Page 2 maximum and in fact read off the scale of'his meter at the high end. The next day he put a siXty day order upon them to alleviate the noise. Within that time a six month ex tension vas requested by and granted to the Towel' and subse quently, another six month extension. The elate nothiD8 has been done. When the windblo~strongly enoU8h the noise is loud enough that it can actuaJ.ly awaken one from. sleep. The noise may be heard in all neighborhoods surrounding the Tower depending upon the direction the wind is coming from. The sound also t:ravels very straJ:lg'ely at times, jumping over certain areas and be ooming quite loud in areas fUrther avay. Reading between the lines, from what information we have been able to glean, it would appear that the Tower is 'now endeavoring to avoid compliance with the order to remove the noise. This is not su:rprising as I am S'ln'e it will be an e:xpensive 8ituation to remedy; top this with the fact that most of the :Board of Directors, I am told, live .in New York! -- ".' ... Also enclosed are two letters .m.ich were distributed in the neighborhood, primarily to the '!!PIA area. The 8 October 1975 one is self-explanatory.~9 December 1975 one, though sel.f-explanatory as well, must be .interpreted: the reason M:r. salter has a DeW twenty-four hour telephone is because the calls to him in compla.int of the wind noise (and for his scientific observation at that time) were be·· coming such a bother to him that he installed a phone answering service. I would assume. he gets his messages the next morning when obviously the chance of the wir.d and noise remaining is mnch diminished. It should also be po1l'lted out that because of our extremely UtI11Sual winter 1975/1976 that we have not had high winds very often and so there have not been as~complaints as before. This is not normal and we would expect our seasonal winds to return again at the end of this year. It should also be pointed out that; Ht. Sutro is approxi mately 900' elevation and that the antenna gay wires are approXimately another 900'~elevation; it is entirely possible rox wind to beblo~at the 1800 foot level and not at the 900 foot level or lower; in this instance in this inatance when it does occur the noise is al.J. the louder. " ·..., .,..~, Page 3 TPIA is azmoyed with this situation as is the Midtown Terrace Association. Forest Knolls as well have voiced their UDhappiness. We seek to enlist your assistance in -this unpleasant matter.~efeel, and not without some justification, that we are being stalled until we get tired of com plaining. If there are a:r.y questions that I might answer it would be rrry pleasure; my office n'CIllber is 871-6222 and my home number is 664-1247. Very- truly yours, Jules H. Reama.tDl Vice President ']!pIA jmh:a Ene. ... ". CC: Charles :Breyer, Esq. %Jacobs Sills and Coblentz 555 CalU'o:rnia Street San Francisco, CaJ.ifornia 94104 James Fitzpatrick, President Twin Peaks Improvement Association 86 C1arendon Avenue San Francisco, California 94114 lJ~) T\X'l:--: PEAKS1l-1PROVEJ'.1E~TASSOCIATION SAl-: FJi:Al-:CISCO "'.lU 8 October 1975 Dear Nei ghbor: A 5 you are all aware, the Mt. Sutro television tower has been the source of bothersome and severe noise for a period of years. In 1973 a constant personal, verbal contact 'was maintained with the chief en gineer of the Sutro Tower and although promises were maCle.. nothing was done to alleviate the noise. In March 1974 TPIA sent a letter to the tower asking for relief from the noise. It was answered but no results were forthcoming. In March 1975 TPIA again wrote the tower, this time assuming a more threat ening position. Still nothing happened. In May of 1975 the City Health Department noise engineer recorded tower noise during a windstorm; the~ecibellevel of the sound exceeded the maximum allow able in city statutes and a :60 day noise abatement order was placed on Sutro Tower. In July 1975 Sutro Tower, Inc. received a six month extension of the noise abate ment order and hired their own-engineer.s to irivestigate thenois~:_ Sutro Tower will probably do a.ll they can in order not to comply with the noise abatement order. If the city is to make this noise abatement o:rder sUck they must have our assist ance: WHEN THE WIND IS BLOWING AND THE TOWER IS MAKING ITS UNPLEASANT NOISES-CALL-BOTH OF THE FOLLOWING PEOPLE AT ANY HOUR OF. DAY OR NIGHT: Robert MacDonough Charles Salter Office Office 558-4731 982-4370 Home Home 922 -1452 284-7572 Mr. MacDonough is the city engineer; Mr. Salter is a private engineer employed ~ythe Buonaccorsi and Associates firm as hired by Sutro Tower, Inc. It is im portant that both men be notified. They expect to be called at any hour. Please call as often as you are disturbed by the tower noise. ·TPIA jmh:m , . ? Ak~UM~NTSFOR REGULATION OF THE Ml. SUTROTO~ER The t11qun 1 eld froRi ell perspective of hlstory and logic 1e. af:> 1::>1101,018: In t l-,p t\Nentiee., it \Nas possible and legal to purchase){-n'~y lubes and Mony \Nele purchased ior homeexperi~enl8and party9a~e5. Also 1n the twenties. people drank rad10aclive water (oiten because of theirphYBiclan'~advice) because they thought it waeheal~hy.In the forties and fiftles, people were fooling around with radloact1ve substances (proepecling, experulemting and atoillc teetHlg) unaware Ci the danger bnd ojten wellbelo~the absurd standard that was ineffec~ at~het.1Jl\e.\N(~)}into the seventies, people .pent much tillle 111 thE; sun and under tanning lamp8 because~heythought it was healthy.ND~ we know that ultraviolet raye cause C5ncer and cataracts. Infrared reys <heat) can couse burne. Hlcrowaves cook our food, and couldcoo~ us aa~ell.Ev@n prolonged exposure to high intensity light can cause blindness. In eech case, too much radletion can cause damage~cth~ hu~anbody~In 1..he case of X-Rays, radi.oactive water, al,d sun exposure. thes& were thought to be aafe or eYen healthy. lhey Bubeequentlywe~eiound to behar~ful.The sun hae been around since before life on this planet; X-rad1ation and 10nizt09for~aof radiatioll (ladioactive substdncee) have been known for over a hundred yeara. Radiowavee have been artlf1cally generated only since the twenties (except for experiments and coaBtal-marine use). The frequencIes used 1ft TV and FM Radlc have only be""n in general use dUl"ing and sillce~Wrl. No scientifiC study has ehown thatelectro~agneticradiation ie harmful 10 doses which resident6 around Sutro Tower are receiving, but neilher' are there any eludiee to ehow that the levels are ssfe. The current etan.ard is arbItrary Without anye~plricaleVidence or fact to Justify It. Since mosl, 11 not all, other forms of radiation have been shown lo be harmful to thehu~anorgani~min prolonged doses it is indeed possible that electromagnetlc radiatiorl 18 also harmful. It 18 wise to err on the 81de (If caution. The abovefor~aofr6diati~nwere found tu be harmful after u fairly large group of people became ill with cancer or other problem and a doctor 01aC1enti~ttried to find the cause. Aiter much Lrlsl nnd error, varlouacom~oncauses were postulated and experlments were deVised to test the hypotheses. After mucn experlmentatlon e.I,c1 repetition of experiments, conclueiollS woul.d be crawn and furlhel studies made to ecertain $afe limite tif any) of E'>:poeurl?Sta.nd~lldswould be creat.edba~ed\!pon these studies. This lakes a long~ime.A lot of people had to get sick and die for 6cientlBts to gel thelr daLB. Othere~ec8~e~llwhile the studies were being done and 6tanderds created. Are~ethe ones who will have to give our 1 iv?"s le. et,ow that electrolllagnetic radiat.ion istoy.ic~·Many Dubstances are mOle orl~8acarcinogenic. In some csses, Ohly 8 few people are eenBillve to a certein carcinogen at a 91ven level. In other cases, e large percentage of the population are seneetive to 6 ~~rcinogen.Socipty has to draw a line between the percieved value oj ~carcinogen and the possible number of~eoplewho Will COme down with :"allcer alld 1,.1111 probably die. Since t111s data ie. dlfficult to obtain, some standardsel~abeurdly low and othere absurdly high. The ones that are toc, t'.i9h are adju6led downward when the level of cancer :>ecomes 1..00 Llgh (<''1s1n tsk1ngti~eand 11..,,98). l\re we to bE;: theon?~ t.o "adJUBt" the~ldqdald'!A "safe" level of rgdiation eX?06Ure shoul,1 :·e determined bv~"'IT,pillcele\'id~nceend (loud p,.:ierltii ic study; e 6t~'ldaldcleet.ed baaed upon this data: and then and only lhen can levels of radiation be increased if poaalble. Perhaps a l@duction until th1s standard i8 crealed ig 1n order. SlllC-'t;' eC.l.ence, hietory and logic often play litlle part on political deci8iona, perhaps the following economic am.endment should be added to the above argument: If end when the above studies are~ade and it i8 found that we have been exposed to overly higha~ountsof radiation, can The City (and indeed the owners of Sutro Tower) afford the lawsuits that will ineVitably occurr? Even if The City wine, the cost oflitlgeti'~nwill be 1n the lI\i11ions. Since t.he t:1\\'iroRlent affe(:ta how we 1 ive and cUl'l'enl th1nking JLB that we have the light to have an enviroment that allow8 us to live normal 1 i veE. Tt,e following eonoma 11 ies show that. l-esidence around the Tower 1s notnor~al:Anything with tapeheads (tape recorders, VCRs, onsweringmachine~etc.) are affected by radiationfro~the Tower. A bU7z1ng sound occurs, if indeed the devicework~at all. Often oneha~ Lo return ltema purchased for other modele unLil one is found that will work at ell. I can heaL a radio station on the magnetic cartridge 1LpUt. of Il',y slel'''-'o. Certain FI'I st.at ione will blanket enti re sectione of the FM dial. FM overloads TV etations whose frequenc1ee are close to the FM bands. J pick-up FI1 overload on my highly shielded AM only receiver on frequencies well below the FM Band (sub harmonics), 1 even have gotten FM on rllY AM only Crystal Set! One time when I waa £i):1n9 an old radio. it started emoking. Examination of the set showed the antenne trensfvrmer was overhealir.g. I fhat t.hought that the coil all the radio aide of thetransforme~was rece1ving too much current. A thorough check of the eet revealed this not to be so. I SUbsequently acertained thal the antenna side~aBoYe~heatin9.The only cause could be that~Yantenna was receiving~uchmore radio frequency current than lhat for which the wire in the coil wae deSigned to handle (by at leeet 8 factor of ten 01 more). Tha probes on~y8t~lndardACvolt~enterpick up enough radio frequency energy to~ovethe needle. When I waB grounding the fiIst part of the Faraday Shield on~yroof, I recieved a shock. The eppl'Co>:imdt..ely four hundred square feet of mesh on J\Y roof <attached to nothillg butt~eroof I picked up enoughr8di~t.ionto legister13~volt~on my AC voltmeter (at. 2000 ohms/voll). Of course the current waB very low. You ehould see the filtrationequip~ent1 elBe to filt.?H- oul excess radiat10n cOl1ling froll' both the houae wiring (WhiCh acts like e big antenna) and from the air so that my electronlC ~quipll\ent<TV. VCR Hl-FI etc.) will work~oreor lees properly. I cen :Ittach a coat. hanger to It\}. osc.l.lloscope and get. all kinds of Interesting waveforms at radio frequencies. A policeman told~ethat 1@ can notu~eradar up here because of the Tower's radiation. We have )een told that the sand and residue irom Bsndblasting was low in leed .hat fell uponOUI~houses, garden$ and cara. I wonder how much othel' .eavy metals were preaent in the sluff. They ere often present 1n ,and. They were net tested for and are just aB deadly ae lead. We liten heer cables (01so~ethingelse metallc) banging In high windB. lhst would happell if something large and heevy fell from so greet a ,eight upon our homes? By the wey, even some telephones pick-up.radio .~ations.To protect my femily and myselffro~radiat10n both tor eelth and lifestyle reesonB, I heve erected a Faraday Shield around my Duae. It leduces radletion about 78% inaide~yhOUBe. However, it oeB no good whE!n 1 am out-side and only one ot.her house in this 6P,"e\ as one. Others report radios snd garege door openers turning on Y5~eriously.Some people have trouble with their computers and~Able V. Some elf t.he-8E' effects can t.f'" demonBtratecl for you, if you 10.1.1 ';l!. --- - ----------- One quick-fIx that will reduce the rediatioll level.o~ewhet1EL0 make the FM statlons that use the Tower. change theixantenn~types {ro~single bay and even bay types to odd bay types. Th15 wlll cause h t 1 t re and reMove the the propagation patterns to be more orizon e In ne u,~. spherical pattern that rain Much rediation upon us. I talKed with Phll Lasky, the~anwho deai9 ned the Tower at a CSA convention a few years ago and het~ldme that we should not be having the probleMSth8~we are having. He blamed it on poor manag_ent of thetrane~lttersandt~e >:ant.enna ell.l.ay. Vlhen high definit.i.on TV 15 instituted in mid decade. adoit.i.omd lrans~itteLswill be necessary because HDTV isinco~patablewith traditional TV. Mr. Zestro says lhet there will be less radiation with HDTV. That might be ao because it mlght require less power than traditional TV. However, the change will not be overnight. The government hee etated that for a perlod of fifteen years TV etatione ~illhave to~1~ulca8tHDTV and tradltional TV. Radiation ia cumulative, s(. during the transition period, the curr'ent emouut of traditional TV radiation plus (repeat plus) the HDTV radiatiol)~ill aminate from the Tower. Since we have trouble with overload and harmonics now. we will certainly have moreproble~8~hen. MI-. Zastlo gays that hie Federal mandate reqUiresh1~to supply facilitiee to anyone who wantethe~.he is obliged to take on MOle customers. He says the FCC pre-empte city regulations. 1 wae told by a member of the planningco~miesion,a~e publiC~eetlng5 year& or8~ 8g0, that she knew of twenty-one structures that were erected without a permit. Zestroo.J eays that he does not need one beceuee of Fedensl. pr"e empt.ion. I have been t.old that this is not true, that. Federalpt'E~­ emption doeB not exempthl~from t.he permit.proc~se. Recently w("! passed a la"", requiring el\'lployers to plece shields 011 co~puterCRT screens to protect users~rompoaslble health r1aks.Ho~ come~ecarl protect people from radiationtro~their CHlbU~not~rom the radiation irom t.he·rower~APOSSlbl~precedent here. Mr. Zaalr" says that the FCC~i11 protect and l'egulate an)' c:hangee. occuring on the Tcwer. The FCC nee a repute·tion 6S being "reluct.ent. enf"orcere." and t.his 'Was before current. events. The fCr.... an<:1 rAA are currently 1n a bet.tIe for t.uri. I:.ach wante llIore power" over the olhel.. This is so each will get more of the ShrinKing federal budget.. They have notl~eor~anpower(which has been severely cutrecently~to regUlate the Tuwer. My FCC 1 ieensa used to l'equ l.re a t.e-st and renewl is. Now all one has to do 1s fl11 out a card and one is licensed for lite. rhis ls becauae they have neither the lunde or manpower to regUlate people who work at broadcast eL&tione as t.hey once dld. The amateur banda are selt·~egulatedbecause the~ccc:an not spare t.he manpower. And you expect the FCC to protect UB? The onlyw~ywe can stop expanSion of the faCility le it theywen~ to bUild 6 bUllding or eddlt.ion.~astroweave that. he probably 'Wl11 not. to accomodate HDTV. 1 wonder it the lower aLcrowavedl~hesere legal 1 n that U ... ey are not- atlacned to the Tower. 1 have 6lreaoy~entlonedthe damage to the trees. Thle eXletea long before the drought or freeze of recent years. TheIS 18 aleo the danger 01 aircraft collelon witht~e~ower.1 am not worried aboutcom~erc1alaircra1t. they have radar. smell planee are notr~qujredto have or use radar. If a emall plene~0t - ID~~in the fog, Lhe Tower could be struck,~eaul~1nginda~ageLot~e houses below. The FAA(re.e~berthe turf fight) did not want ato~e~ the size of Sulro Tower built on Mt. San Bruno because of the proxmily to the airport. The Tower can not be aeen on very foggy days or nights from My house (lese than 10ee feet away>. A pilot .ey not be able Lo manouver out of the~8YIn t1me 1n a fog. We do not need thia hazard ln the middle of a city. Hope thiB helps. Call me anytime(b48-848~). TO:_.C_~-f1lJJ!1~-..-LJJ1.~~.Jj.W_._ _ __ FAX Number: 1J./...1..'tf.f. '!"...fL _ . FROM: paul Joseph Bourbin RE:d1~..r;wl'!.t?._..h_lf?.f.,_~.._ __ -, __ . ~Plellsever~fyn,!clept of l.hl<:.: FA):tr~n~n\h:slonleav;o!.} tl voh;e mess6ge Ijt: (415) 648-6489.. sentj't,:']t~F i,~trtlnSmlSS10n t.o: (415) 64B-t>}t·9 or sending emuH to'PAULB;:)qRB!N~Oetpnl_f;om / September 9, 1997 Ms. Hillary E. Gitdman The EoviroomentaJ Review Officer Plaming Department 1660 Mission S1reet, 5thfloor San Francisco, CA94103-2414 Dear Hillary. I am writing in response tothe Draft E.nviromneotal1mpact Report which raises many coocems for me and the household in which I live. As a student who spends a great deal oftime studying I am very concerned about the increase in noise level during the construction ofthe proposed 125-foo1 vertical support structure. This additiooal125-foot vertical support structure a1Io nisal coocems about projectiles from the Tower strikingthe surroundin8 neigbbcrhood including, bolts, wires, cables, tools, md metal siding. The Draft EoviroomentaJ Impact Report does not explain how this additiooall25·foot 1008 beam will effect the balance ofthe Tower al0D8 with the significant increase in structural weight and its effect ontbe 8f'OUIId surrounding the Tower. WbIIt is the seismic integrity ofthe hill 011 which the Sutro Tower is located? How is the wound surroundin8 the water reservoir adjacent to the Tower going to sbif)jch.an@e with the additional weight ofthe proposed project? Regarding the increue in nsdiofrcqumcy radiatiOll as the result ofsinndtaoeoU! broadcast ofboth DTV and NTSC signals how will electrooic equipment which I am currently experiencing difficulties with be effected such as, television reception interference. nsdio reception interfermce. audio cassd1e playing and recording interference, VCR playing and taping clarity, answeringmachine clarity and telepbooe cl8rity? The diagram ofthe propoll(".d 125·foot support beam does not semJ.to accurate1y depict the aesthetics ofb: Tower after the construction period. I write to you as a very clistnssed citizen who along with many otbm; in the surroundin8 neigbbcrhood are experiencing a dreaded fear oftbe future implicatioos ofthi8 Jl'I'OP08ed expansionto Sutro Tower. 1'beIe llWlieties, frustrations, anger, md feelings ofbelplesmess are very real and alone according to the Jlb"yclloneuroimmunological model ofbeahb can be responsible for ill-health effects as a~peaceful and healthy enviromnent is being overshadowed by bigbusiness without much regard tothe citizens who must live in close proximity to a growing eyesore. I look forward to your reply Very tnJly yOUl'S, , ,- =-:::r/~-/~r:A/C:::~ Todd D. MeLillo 74 F'uview Court San Francisco, CA94131-1212 .ce: Steve Nabm Mrs. Doris Linnenbach 155 St. Germain Avenue San Francisco, CA 94114 September 7, 1997 Ms. Hillary E. Gitelman The Environmental Review Officer Planning Department 1660 Mission Street, 5th Floor San Francisco, CA 94103-2414 Dear Ms. Gitelman: I am writing this letter as a 3D-year resident of the Twin Peaks area. Since 1966 the residents of this area have been victims of the communications-media establishment. There was a communications blackout at the time that the original permits were being discussed and finally issued for Sutro Tower. The neighbors fought against this tower but to no avail. David Sacks of KGO and his media influence and deep money pockets forced the issue and won. Thirty years have passed. Twenty-five years of living with a huge metal structure in the midst of a residential neighborhood. Twenty-five years of noise, interference, constant problems of maintenance, sandblasting, paint falling on the homes and cars, and the stress of seeing articles in the newspapers relating to the EMF issue. Twenty-five years of living with a bad neighbor. Twenty-five years of having the various agencies to which we have turned for noise abatement, or air quality analysis as a result of sandblasting, or interference mitigation turn their backs on us and say we do not qualify for help. Twenty-five years of being "dismissed" by the cavalier attitude from the owners of the tower. We, the residents of Twin Peaks, Midtown Terrace, Garwood Circle, Forest Knolls and many other neighboring communities hereby put the City and County of San Francisco on notice by stating ...Enough is Enough...No More Power on Sutro Tower! I do not base my objections on the raw emotion of having lived with a "bad neighbor" for thirty years, but on the articles, materials and research which has been conducted in response to the Draft EIR which was published on July 9, 1997. I am deeply concerned about the dangers related to the structural integrity of this tower and the resulting catastrophic loss of human life and property which could occur should this tower fall in the residential area due to a natural or man-made collapse of the tower. All of the residents who live within a thousand-foot radius of Sutro Tower should be considered as potential "fall zone" victims and my concerns will address this issue: In October 1996 a 1500 foot transmission tower in the Dallas-Ft. Worth area collapsed into a mass of twisted red and white metal killing three workers when wind caught machines used to hoist a new antenna on to the existing structure. (St. Louis Post-Dispatch, Sunday October 13, 1996) The EIA (Electronics Industries Association) released tower standards in 1996. An analysis of Sutro Tower should be done with these new standards in mind. Sutro Tower has been standing for over twenty-five years. In 1992, Cooper, White and Cooper, Sutro Tower's own attorneys, admit in a letter to Mr. Dean Macris of the Planning Department that the fog and salt air have badly corroded the structure and it is an ongoing process. In Electronic Media (copyright 1994, Croin Communications Inc., December 1994), Michael Schneider states that snow, ice, hurricanes, earthquakes, bombings and years of neglect are enemies of towers. There are definite standards for construction of towers today. The Electronics Media article refers to towers which have been "grandfathered" in and do not meet with today's standards. We want the revised EIR to include an analysis of Sutro Tower's classification in regards to "grandfathering" of towers. Has it been "grandfathered"? If so, how could any responsible agency "grandfather" a 977 foot tower in the middle of a residential area? Electronics Media also states that "in San Francisco the threat of a major earthquake is a constant consideration". Eugene Zastrow states that "Sutro Tower is a self supporting tower". The EIR does not adequately address the earthquake issue, the impact of seismic activity, the new available technology in the building of safer towers, the current seismic status of Sutro Tower, and the future obligation of Sutro Tower to continue to retrofit the tower. The Kline study of 1995 was not made available to me when I requested it from Debra Stein. I was told we could not obtain this report because "Watson also wants to construct at HDTV" station. This study should be made available so that we could properly respond to it. Any report that Kline or any other company has conducted over the years regarding seismic upgrading should be revealed to San Francisco's citizens and especially citizens who live within Sutro Tower's fall zone according to the Freedom of Information Act. The FCC mandates annual inspections of towers. We want the EIR to include copies of the last three years of inspections relating to the condition of tension and plum of Sutro's guy wires, structural integrity, all attachments such as transmission lines, and the structure itself, such as antennas and lines, lighting and paint. We want a comprehensive report on the response of Sutro Tower, Inc. to the required upgrades. Recent upgrades to the tower were approved by the Zoning Administrator. Why? And by what standards? We would like both the FCC requirements and the status of Sutro Tower's current compliance included in the revised EIR. Along with the FCC, FAA regulations have played a large part in decisions regarding the tower (strobe lights, paint colors, etc.). We also want access to all files regarding FAA mandated work on Sutro Tower, and this information should be included in the final EIR. With respect to the FAA and air traffic, the project sponsors should not discount the possibility of a light aircraft hitting the tower in heavy fog. In the early 1960s, such an accident occurred--a light airplane crashed into the base of Mt. Sutro, covering the area with debris. Joel Brinkley of the New York Times in an article written in May 1997 "Digital TV May Be Short on Towers...Few Crews Ready, Sites Hard to Find" states that tower builders will be on a crash program to build with only a few crews which will have the experience to put up these towers. He also states that "fully loaded towers - even one more antenna along with the 2000 feet of fat copper wire cable leading to it - would add more weight than the tower could bear... " Sutro Tower also needs to upgrade its structure before they can attach the proposed new HDTV tower on its existing structure at the 755 foot level. The EIR does not address the specifics of the upgrade. What assurances do the fall zone residents have that a qualified group of tower builders will perform the work? Will they rush the job regardless of wind conditions and other foul weather in order to complete the job on time? We experienced this type of irresponsible behavior when the tower was conducting their sandblasting maintenance job. They kept working in spite of adverse weather conditions, in order to do the job "on time". As a result of their pushing ahead during high winds, our houses, cars and the surrounding area was covered with the fine silica used for sandblasting. Should they use the same "unholy haste" in attaching the antennae, Sutro Tower, Inc. could be responsible for a major catastrophe. And...should this occur, to whom do we turn for help? Sutro Tower? The City Attorney's Office of the City & County of San Francisco? FEMA? The Police Department? The Fire Department? Who has the ultimate responsibility to monitor their actions during the course of this planned upgrade and attachment of the HDTV tower antennae? This leads to the issue of Fall Zone Insurance. Brinkley adds..."In the years since, insurance companies have begun to require television stations building towers to use land large enough that the tower can fall in any direction without hitting anything - meaning that in some cases a circular plot with a diameter of 4,000 feet is needed. Towers do in fact fall on occasion. Seven of them collapsed during a storm in Minnesota and North Dakota last month. No one was injured". The EIR fails to address safety precautions which should be taken to protect fall zone residents. Does Sutro Tower carry Fall Zone Insurance? Does Kline & Co. carry Fall Zone Insurance? Who is financially responsible to the fall zone residents if a singular accident or catastrophic accident should occur during the course of installation and construction of the new tower with the existing old and corroded tower? Have adequate structural studies and visual inspections been done in the areas of attachment to be sure that the almost 20,000 pound DTV tower can safely be attached? If in the event that neither Kline nor Sutro Tower has adequate Fall Zone Insurance to cover the loss of life and property to the potential fall zone victims, the City & County of San Francisco should take some sort of action to protect its citizens. If, in the event that citizens would be forced to buy their own fall zone insurance, the City & County of San Francisco should be prepared to lower our assessed property tax based on the lower value of our property. A fall zone catastrophe is an accident on its way to happen if the City of San Francisco grants Sutro Tower, Inc. the right to place an HDTV tower with their old and corroded existing structure. In Video Technology News, dated February 10, 1997 "ATV Roll Out Likely to Result in Tower Crunch", the industry is put on notice that "...the effort required to strengthen a tower is comparable to erecting a new tower. In some respects, it is more expensive and dangerous." The EIR clearly ignores this impact on the fall zone residents and the environment in general. In this same article, the problem of grandfathering in existing towers that do not meet new specifications is also addressed again. Let it be known that no one's life can be reinstated through "grandfathering". Today's windload factor standards must be addressed and Sutro Tower stands 1800 feet above sea level. The EIR has failed to address the dangers of creating a tower within a tower and it must do so on the revised draft which must be sent to everyone in the fall zone. I call upon the project's sponsor to create a fall zone list and add these people to their list of "interested parties". I hesitate to mention my final concern, but nevertheless we cannot ignore the potential for an act of terrorism. Sutro Tower is a communications nerve center, located in an easily accessible area, among dense trees with minimal security. Given the unimaginable events in Oklahoma City and the World Trade Center, and given that San Francisco is such a powerful "photo-op", anyone with any sense of public responsibility would consider Sutro Tower a potential site for sabotage. What are the FCC and FAA regulations regarding protection of such sites? Has this scenario even been considered in decisions to allow the tower to remain in such an indefensible location? It is your civic duty to factor this potential threat into your decisions regarding expansion of Sutro Tower. In conclusion, I want to state that I am very angry that the Twin Peaks-Midtown Terrace community was handed such a poor and incomplete EIR and that we were expected to accept it on its merits. We want more information on the peer reviewers. We want their credentials. We are a group of highly intelligent citizens who expected a complete EIR. In fact we wonder how a focus EIR could have been done when a Master EIR was never completed on the project initially in 1966. This community deserves a Master EIR done. If you c:heck your records, this was requested of you by Armin Perlmutter in a letter sent to Mr. Passmore in 1988. OUf records contain this information. Do yours? We have been denied access to your files. They have been deemed missing since I requested them in July. See enclosed letter from Mark Berkowitz. Let me assure all of our City fathers that this time we are not going to be placated and go away like good obedient little children. We are going to get all the facts out in the public record this time and are going to exercise every remedy available to us. You have no community support for this project. This was made very evident to us by the huge turn out at our informational meeting held at St. John's Church on Wednesday, September 3, 1997. The irony of all of this is that this meeting was held in a week that the entire world mourned the death of Princess Diana, which was caused in no small part by the greed and destructive power of an unrelenting industry called the communications media. The issue of Sutro Tower has been one of media greed and power from the onset in 1966. I am angry that over the years we as a community have had to spend thousands of hours policing Sutro Tower, Inc. on our own time and at our own expense. We have had no help from our City fathers in all these years. Why, we ask? The City & County of San Francisco receives only $125,000 per year in property taxes. So why, we ask, is this structure, which is an "unattractive nuisance" -- so attractive to the powers that be in our City. Could it perhaps be the huge monetary contributions made to our local politicians by the communications industry? Perhaps it is time that you check the list of campaign contributors and get the answers to the political implications behind Sutro Tower, Inc. Again, I said to all of you in City Plannin& we want answers, we want the City of San Francisco to be responsible for their actions. Enough is Enough -- No More Power on Sutro Tower! Sincerely, Doris S. Linnenbach Christina Deardorff 62 Midcrest Way San Francisco. CA 94131 415.821.4703 Hillary E. Gitelman Environmental Review Officer Planning Department 1660 Mission Street, 5 th floor San Francisco. CA 94103-2414 September 3, 1997 Re: Summary comments to Sutro Tower Digital Television Draft Environmental Impact Report 95.544e. dated July 9. 1997 Recently. I attended an informational meeting regarding the addition of DTV antennas to Sutro Tower. The Draft Environmental Impact Report was also reviewed. I went into the meeting ignorant of the Tower's history, the amount of electromagnetic radiation emissions, and the impact it has on the surrounding neighborhood. I wasn't aware that paint chips from the Tower had fallen to the ground. nor that the Tower emits "hot spots" of radiation. nor that these emissions propose any health risks. The thought of the Sutro Tower collapsing during an earthquake or the event of an airplane crashing into the colossal structure never entered my mind. They say ignorance is bliss. I find it disturbing that no studies on the effects of electromagnetic radiation emissions on humans have been performed. I find it more disturbing that Sutro Tower Inc. and San Francisco's planning department would allow people of the Midtown Terrace & other surrounding neighborhoods to be exposed to electromagnetic radiation withoutrE~searchingits effects on humans. This is simply unethical & irresponsible. One study was mentioned at the meeting in regards to the surrounding neighborhood and electromagnetic radiation emissions. This study, based on Department of Health data, looked at residential areas surrounding the Tower. The residential areas that were selected were all located North. Northwest. and Southwest of the Tower. The emissions point Southeast of the Tower. 1found this study to be inconclusive because the areas tested are not neighborhoods directly affected by the Tower's emissions. One question: If the Tower's emissions are presumably at "safe levels" then why are employees at the Tower. while performing work on the Tower. required to wear protective suits??? These suits are designed to protect against harmful levels of radiation. The proposed expansion needs to be halted until substantial data on potential health hazards has been collected. In addition to health risks. I'm concerned about the selected location of the DTV antennas. Why Sutro Tower and not San Bruno Mountain? Is it merely an issue of money? Or greed. in this matter? San Bruno Mountain. as stated in the Draft Environmental Impact Report. is a better sight for the antennas. It will have an environmental impact, nonetheless. it is a nonresidential site. At the meeting. the impact on the environment (us humans being included in the environment) was of utmost concern. Mr. Zastrow of Sutro Tower Inc. was not qualified nor did he have any substantial information to comment on the environmental impact of the antennas. Overwhelmed with questions and concerns about the impact on Midtown Terrace residents and surrounding neighborhood residents. he crumbled and quoted: "There are concerns regarding San Bruno Mountain's environment as well. There is wildlife at that location to consider." - Mr. Zastrow. Sutro Tower Inc. 9/3/97 This quote. by Mr. Zastrow. was a desperate attempt to defend the proposed site of the antennas. Mr. Zastrow. the quote came from your mouth. Yes. the antennas will have an environmental impact. Whether it be of aesthetic impact or the health of our families and children. The proposed site to San Bruno Mountain should be considered!!! I. as a resident of this neighborhood. feel that the current antennas and the DTV antennas pose a substantial health risk to persons living in Midtown Terrace and surrounding neighborhoods. There is a more appropriate site on top of San Bruno Mountain to consider. I suggest you do the right thing and choose people's welfare over income earned. Sincerely. CX P6 Christina Deardorff A. Anthony Dodson 62 Aquavista Way. San Francisco. CA 94131 (4151 826-5343 September 1, 1997 Ms. Hillary E. Gitelman The Environmental Review Officer Planning Department 1660 Mission street, 5th Floor San Francisco, CA 94103-2414 Dear Ms. Gitelman: Re: Sutro Tower Digital Television Draft Environmental Impact Report written Comment Period extended to Sept. 10, 1997 There are three general areas I wish to comment on: 1. The lack of any description of directionality of the new antennas. 2. Unsupported and unexplained matters in the technical report on biological effects, and 3. Various typos and inconsistencies. LACK OF ANY DESCRIPTION OF DIRECTIONALITY OF THE NEW ANTENNAS I consulted a book, "Reference Data for Radio Engineers", pub lished by Howard W. Sams & Co., Inc., (a sUbsidiary of I.T.T.) sixth Edition, 1975. The book jacket indicates it was accepted for classroom use in more than 200 of our leading colleges and universities. It states at page 27-20: "ANTENNA ARRAYS The basis for all directivity control in antenna arrays is wave interference. By providing a large number of sources of radiation, it is possible with a fixed amount of power to greatly reinforce radiation in a desired direction while suppressing it in undesired directions. The individual sources may be any type of antenna..... " This indicates to me that the 10 new television antennas will have directional properties. Yet, the draft E.I.R. is silent on this point. Surely, Sutro would like to beam more power inland than out to sea. Additionally, the reference book states at page 27-47: "DETERMINATION OF POWER DENSITIES In estimating the radiation hazards that may exist in front of an antenna, it is necessary to determine in which areas Ms. Hillary E. Gitelman, September 1, 1997, Page 2 the power density is greater than the safe limit for short exposure, and in which areas indefinitely long exposure can be permitted. with a paraboloidal antenna the power density is greatest on the antenna axis, so that it is first neces sary to determine if the power density exceeds 10 milliwatts per square centimeter at any point on the antenna axis, and if so, to what distance from the antenna does the power density exceed this safe limit for short exposure. The same estimate must then be made for a power density of 1 milli watt per square centimeter, which is assumed to be the safe limit for indefinitely long exposure. At all distances where these limits are exceeded, estimates must be made of the radial distance from the antenna axis at which the power density is reduced to the required safe limit. From the estimated safe radial distance the minimum antenna elevation angle, relative to the terrain and buildings; may be deter- mined " The safe limits for power density in this passage appear to be outdated but the principles are undoubtedly still in effect. It appears to me, from this passage, that the power density at the end of Farview Court, for instance, would vary depending on the direction the antennas were pointed. I can find nothing in the draft E.I.R. on this. Surely, information on the antenna directionality is readily available from the manufacturer, or, if manufactured by Sutro, then readily available from their electrical engineer. Omitting this information appears to me to be a very serious omission. Since the power radiation is line-of-sight, why wouldn't reflec tors or baffles shelter nearby homes from high density radiation? UNSUPPORTED AND UNEXPLAINED MATTERS IN THE TECHNICAL REPORT ON BIOLOGICAL EFFECTS 1. What are Peter Polson's credentials? 2. What are Louis N. Heynick's credentials? 3. What are Asher Sheppard's credentials? 4. What are C. K. Chou's credentials? 5. How much was Woodward-Clyde paid for this report? 6. How many other broadcasters are utilizing substantially the same report? 7. Why was lack of peer-review used to exclude studies? 8. Are there any standards for peer review, and if so, what organization codified the standards? 9. Did C. K. Chou prepare a report on his peer review? If 50, shouldn't a copy of his report be included in the E.I.R.? 10. What studies without peer-review conflict with the Technical Report's conclusions? Ms. Hillary E. Gitelman, September 1, 1997, page 3 11. How is it that so many scientists have pUblished studies (with peer reviews) that Polson finds unconvincing? 12. Mr. Polson's reviewed Milham's second study starting at page B-15 of his report. To paraphrase, he indicates that due to the small number of deaths, the results of the study are not convincing. How many deaths would make it convincing to Mr. Polson? Why? VARIOUS TYPOS AND INCONSISTENCIES 1. On page 3-5, it states, 1I ????the maximum permissible power density ranges from 1.00 to 2.69 milliwatts per square centimeter squared." I understand per square centimeter, but not IIper square centimeter squared". How accurate is this draft E.I.R.? 2. I can't find locations 1 through 5 on the map in Figure 5 on page 3-8 indicating power density measurement locations. Yours very truly, ((- tf;a:k1ty&4x~ A. Anthon/Dodson cc: Steve Nahm P. O. Box 31097 San Francisco, CA 94131 George Linn 53 Aquavista Way San Francisco, CA 94131 Association of Bay Area Governments P. o. Box 2050 Oakland, CA 94604 Attn: Sally Germain Sierra Club 730 Polk Street San Francisco, CA 94109 Doris Linnenbach Twin Peaks Improvement 155 st. Germaine Ave. San Francisco, CA 94114 Ms. Hillary E. Gitelman, September 1, 1997, Page 4 Kent Bach, President Twin Peaks Improvement Assoc. P. O. Box 31002 San Francisco, CA 94131 Elizabeth Kantor, Co-President Twin Peaks East Neighborhood Assn. P. O. Box 14025 San Francisco, CA 94114 Associated Press 1390 Market street, suite 318 San Francisco, CA 94102 Attn: Bill Shiffman San Francisco Chronicle 925 Mission street San Francisco, CA 94103 Attn: Elliot Diringer San Francisco Examiner P. O. Box 7260 San Francisco, CA 94120 Attn: Gerald Adams ~W?';f~1, 1997 A. Anthony Dodson 62 Aquavista Way, San Francisco, CA 94131 (?"'"'- ... ...- ,----- "... I \. r- "" ~.~~J'" I ( V - " ~':-!"JI. ' C ~ .L' 1 #"~-:~,~ c-~~j '. ' I:.. 1 ./ ? --.~'''~'- --'------~ -~.. _--- --- .---- . ~--~~- -- ...-...----- -. ---~. '3~\ 7":, \ -I..> '''> 1"..l'L Kent Bach President Twin Peaks Improvement Association P. o. Box 31002 San Francisco, CA 94131 ILl! ',/. ,I ;f ; IL;IL!,j JIll, ,'! /, ,1 " !! !I ' LIII " I I ,Ll/' i 1,1 A. Anthony Dodson 62 Aquavista Way, San Francisco, CA 94131 (415) 826-5343 September 5, 1997 Ms. Hillary E. Gitelman The Environmental Review Officer Planning Department 1660 Mission Street, 5th Floor San Francisco, CA 94103-2414 Dear Ms. Gitelman: Re: Sutro Tower Digital Television Draft Environmental Impact Report written Comment Period extended to Sept. 10, 1997 I have the following questions regarding Appendix A: Radio Fre quency Levels - Engineering Analysis of Radio Frequency Exposure Conditions with Addition of Digital TV Channels prepared by Hammett & Edison, Inc., Consulting Engineers: 1. On Figure 5, Comparison of Measured RF Power Density with Calculated Values, I divided Calculated Power Density by % FCC Standard in order to obtain the FCC Standard and ob tained the following: Measurement Location FCC Standard 1 .2167 2 .2339 3 .2450 4 .2450 5 .2451 6 .2134 7 .2340 8 .2162 9 .2215 10 .2628 How can the FCC Standard be different at different measuring locations? I understand the standard is dependent upon frequency so that the standard would be a blended figure taking into account the different frequencies being broad cast. But, why different at different locations? 2. I understand that RFR decreases by the square of the dis tance away from the antenna. In the tabulation of Calculat ed RF Power Density, I compared the percent of FCC Standard for existing stations at E-W 1,500 meters, N-S zero, .607%, with E-W 3,000 meters. N-S zero, .267%. I would have ex pected the 3,000 meter figure to be one fourth of the 1,500 meter figure, or .152, instead of the figure given, .267. Why the difference? Does it have anything to do with the Ms. Hillary E. Gitelman, September 5, 1997, Page 2 antennas emitting signals in a compressed vertical plane? If so, there should be an explanation of this. 3. On the page marked methodology, Appendix B, it states: "The factor of 2.56 accounts for the increase in power density due to ground reflection. 1I How can the power density be two and a half times greater just from reflection? Unless the reflection were focused, I would expect that the most you could get from reflection would be a doubling, a factor of 2.0, and that in the real world you would get far less than that. This should be explained. 4. I do not understand the following from the Appendix B: liThe operation of the program is as follows: first, the antenna height, relative field factors due to antenna azimuth and elevation pattern, and effective radiated power are input for each station at Sutro Tower." Is the antenna height part of the relative field factor (RFF)? There should be an explanation of what antenna azimuth is. There should be an explanation of what elevation pattern is. 5. The following from Appendix B needs clarification: liThe factor of 1.64 is the gain of a half-wave dipole relative to an isotropic radiator." Are all the antennas on Sutro Tower half-wave dipoles? In the drawing on Figure 1A I see things that don't look like dipoles. Are they all dipoles? When I look up at Sutro Tower I see parabolic antennas which I can't find on Figure 1A. Are parabolic antennas the same as dipoles? The Woodward-Clyde drawing of the DTV antennas look more like panel antennas than dipoles, although the draft E.I.R. doesn't describe the type. Does the factor of 1.64 apply to the DTV antennas anyway? This should be explained. There should be an explanation as to how different types of antennas (if there are such) are accounted for in Methodolo gy, Appendix B. 6. The denominator in the formula in Methodology Appendix B includes the value, 4 pi. This should be explained. 7. Page 3 states: "The computer program is supposed to give high, 'worst case' numbers." Why wasn't a computer program devised to give accurate Ms. Hillary E. Gitelman, September 5, 1997, Page 3 numbers instead of worst-case? 8. What were the qualifications of the Department of Public Health representative who came along to help with the meter readings, in terms of radio engineering education and expe rience? 9. When the Holaday meter was calibrated, was it adjusted to give the proper reading or was a conversion factor derived in order to correct its reading or was some other method employed to calibrate? 10. When the meter was calibrated, what was used as the stand ard? 11. There should be an analysis of all the facts and circum stances taken into account, including relative weight given to each, in the determination that no peer review was to be prepared for the engineering analysis. Yours very truly, (/. i/;;;;:;;tJ+1I/ /YFif~ A. Anthony 4odson cc: Steve Nahm P. O. Box 31097 San Francisco, CA 94131 George Linn 53 Aquavista Way San Francisco, CA 94131 Association of Bay Area Governments P. O. Box 2050 Oakland, CA 94604 Attn: Sally Germain Sierra Club 730 Polk Street San Francisco, CA 94109 Doris Linnenbach Twin Peaks Improvement 155 st. Germaine Ave. San Francisco, CA 94114 Kent Bach, President Twin Peaks Improvement Assoc. P. O. Box 31002 Ms. Hillary E. Gitelman, September 5, 1997, Page 4 San Francisco, CA 94131 Elizabeth Kantor, Co-President Twin Peaks East Neighborhood Assn. P. o. Box 14025 San Francisco, CA 94114 Associated Press 1390 Market Street, suite 318 San Francisco, CA 94102 Attn: Bill Shiffman San Francisco Chronicle 925 Mission Street San Francisco, CA 94103 Attn: Elliot Diringer San Francisco Examiner P. o. Box 7260 San Francisco, CA 94120 Attn: Gerald Adams ~~WJj~5, 1997 A. Anthony Dodson 62 Aquavista Way. San Francisco. CA 94131 ( \.'" ,. Q:.' Pr'1 ~1- -~ :'. r SL il " , I I"" I '.",.. -'''' "' ,; "- ,'~) ':', j ,.. - ~~.-....-----~ '30, i.:-~?? -(".)\.)\..:"2 Kent Bach President Twin Peaks Improvement Association P. o. Box 31002 San Francisco, CA 94131 II ! I. I , ii, L! ,I L! II. I I I ill! ! , I II, I , II, I I I I It II LI ! , ,I, II, I j,I A. Anthony Dodson 62 Aquavista Way I San Francisco. CA 94131 (4151 826-5343 September 8, 1997 Ms. Hillary E. Gitelman The Environmental Review Officer Planning Department 1660 Mission Street, 5th Floor San Francisco, CA 94103-2414 Dear Ms. Gitelman: Re: Sutro Tower Digital Television Draft Environmental Impact Report Written Comment Period extended to sept. 10, 1997 I have the following questions regarding section 6.3, OFF-SITE ALTERNATIVES relating to the San Bruno mountain alternative: 1. This section cites FCC Rules (e.g., section 73.685(b» but no citation is given for the section giving the deadline for beginning DTV signal broadcasts in the Bay Area which is said to be October 1998. Since the FCC deadline is the reason for the E.I.R" it is appropriate that it be cited so that interested parties can check it. 2. Is there a procedure by which Sutro can obtain an extension of time from the FCC? 3. What are the penalties for failing to make the deadline? 4. The draft E.I.R. states on page 6-5: "This alternative would include construction of one or more approximate 325-foot tall towers in the vicinity of the existing broadcasting tower on San Bruno Mountain on which DTV antennas would be installed." Why wouldn't DTV antennas be added to existing towers at San Bruno similarly to the manner in which they are proposed to be added to the Sutro Tower? 5. The draft E.I.R. states on page 6-9: "Sutro Tower, Inc. 's project objective eliminates any need for new tower construction, whereas any project alternative is expected to require new construction and thus this additional substantial delay with likely resulting FCC rule violations as to the DTV deadlines." Why is new tower construction expected instead of adding to existing San Bruno towers? If there are technical reasons why DTV antennas cannot be added to existing towers at San Ms. Hillary E. Gitelman, September 8, 1997, Page 2 Bruno the reasons should be given. 6. The draft E.I.R. states on page 6-9: "In contrast, as noted, any alternative site for the project will likely require the construction or substan tial enlargement of tower facilities at the alternative site (s) . II In reason 3 for rejection, new construction at San Bruno was given as the reason while in reason 4, substantial enlarge ment of a San Bruno tower was also given. A comparison should be given in the E.I.R. of the Sutro Tower strengthen ing and reinforcement versus the substantial enlargement of the San Bruno tower. 7. The draft E.I.R. states on page 6-9: nThus any project alternative would, in itself, neces sarily create sUbstantially greater environmental im pacts than the modest modification required for sutro Tower to accommodate the new DTV antenna unit." There is no showing in the draft E.I.R. that the modifica tions to Sutro Tower would be more modest than substantial enlargement of the San Bruno tower. In addition, there is no E.I.R. provided for the substantial enlargement of the San Bruno tower. The draft E.I.R. statement that there would be greater environmental impact from the substantial enlargement of the San Bruno tower is unsupported. The only supporting information provided is the use of the adjective modest versus the adjective substantial. The E.I.R. should cite the regulations concerning preparation of E.I.R.s and explain how this unsupported information complies with the regulations. Or, if such unsupported information does not comply with E.I.R. regulations, there should be a complete dissertation on the San Bruno tower modifications and envi ronmental impacts. 8. The draft E.I.R. states on page 6-5: "This same report shows that for these three stations, DTV signals from San Bruno Mountain would be able to serve all of San Francisco." and on page 6-7: "Consistent with FCC's finding in its initial authoriza- tion (4) providing lesser household coverage over the geographically varied terrain of the San Fran cisco area due to signal blocking, degradation and reflection by surrounding land forms " The consistency of FCC's original finding with the 1993 Browne report needs to be clarified. It appears that, contrary to reason 1 for rejection, it is not consistent. 9. Throughout the draft E.I.R. REFERENCES appear at the end of sections but with no keying to the passages to which they Ms. Hillary E. Gitelman, September 8, 1997, Page 3 refer. For example, on page 6-9, under REFERENCES is print ed, "Jay Watson, President, Watson Communications, telephone conversation, January 30, 1997." What does this refer to? Can this be corrected? Yours very truly, .. /t:;a4~~Pv(~ A. Anthony Dodson cc: Steve Nahm P. O. Box 31097 San Francisco, CA 94131 George Linn 53 Aquavista Way San Francisco, CA 94131 Association of Bay Area Governments P. O. Box 2050 Oakland, CA 94604 Attn: Sally Germain Sierra Club 730 Polk Street San Francisco, CA 94109 Doris Linnenbach Twin Peaks Improvement 155 st. Germaine Ave. San Francisco, CA 94114 Kent Bach, President Twin Peaks Improvement Assoc. P. O. Box 31002 San Francisco, CA 94131 Elizabeth Kantor, Co-President Twin Peaks East Neighborhood Assn. P. O. Box 14025 San Francisco, CA 94114 Associated Press 1390 Market Street, suite 318 San Francisco, CA 94102 Attn: Bill Shiffman San Francisco Chronicle 925 Mission Street San Francisco, CA 94103 Ms. Hillary E. Gitelman, September 8, 1997, Page 4 Attn: Elliot Diringer San Francisco Examiner P. O. Box 7260 San Francisco, CA 94120 Attn: Gerald Adams ~~~~8.1997 , -- ~-- ~._...._-- ----- "----;-- --~~- - -_. i./ -._.-/ - ~~~ ,..... () 'e" L;"' '", 0; I, I ? jJ.. (_ z- r~, \ r . .I i ' A. Anthony Dodson 62 Aquavista Way, San Francisco, CA 94131 Doris Linnenbach Twin Peaks Improvement 155 st. Germaine Ave. San Francisco, CA 94114 r:\r-~\. '.\.. ':" .:. \. \ \-;.. II I. I ! 11 i,! i! 11 11 I') i, 1,1,,1 ,11 A. Anthony Dodson Accountancy Corporation Certified Public Accountant 62 Aquavista Way, San Francisco, CA 94131 (415) 826·5343 MEMBER, California Society of CPAa National Society of Accoununte PROFESSIONAL AFFILIATE C.lifornia Society of Enrolled AQenta October 9, 1997 Former Controller, EMPORIUM deportment .tor.. AWARDED, Certificate of Education.1 Achieve ment bV the American lnatitute of CPAa in recognition of lucceaaful compJetjon of an integr.ted program in PERSONAL FINANCIAL PLANNING. Honorable Willie L. Brown, Jr., Mayor city and county of San Francisco 401 Van Ness, Room 336 San Francisco, CA 94102 Dear Mayor Brown: The Planning Department issued a draft Environmental Impact Report (EIR) on July 9, 1997 for the Sutro Tower Digital Televi sion Antennas. THE NEW DIGITAL ANTENNAS SHOULD BE PLACED ON MOUNT SAN BRUNO, NOT SUTRO. I sent three different letters with my questions to Hillary Gitelman in the Planning Department during the public comment period. I hope my questions about the matters in the draft EIR will be answered in the final EIR when it comes out. I'm enclosing copies of my letters with the hODe that you will have someone on your staff check with Ms. Gitelman to make sure that my questions are answered in the final EIR which is now being prepared. Under the provisions of the California Environmental Quality Act (CEQA), San Francisco is required to consider the potential environmental effects associated with this project. The types of environmental issues that must be considered include noise ,r water, aesthetics, human health and safety, light, and pUblic facilities, among others. The CEQA process enables varying degrees of review, which include categorical exemptions, negative declarations, or EIRs. I am concerned that the Sutro EIR is low-balling the radiated power from the ten proposed digital antennas. The EIR shows 500 kilowatts for each of the proposed new UHF digital stations even though existing UHF stations radiate 1,333 to 5,000 kilowatts, up to ten times more. I am concerned that Sutro may follow this Honorable Willie L. Brown, Jr., October 9, 1997, Page 2 low-ball 500 kilowatt EIR with subsequent negative declarations (instead of EIRs) for 5,000 kilowatts for each station thus circumventing pUblic awareness. All the facts and circumstances surrounding this subject should be covered in the final EIR now being prepared. Co-location is locating antennas for more than one provider on a single site. Sutro Tower is a co-location since it provides for 74 existing stations. One of Sutro's objectives (2.1.2.) is maintaining minimum broad cast signal interference with and separations between other TV and non-TV broadcasters and communication service providers in accordance with FCC rules. Sutro's existing antennas are for: 5 VHF TV stations 5 UHF TV stations 4 FM stations 20 Microwave stations 40 Private radio stations 74 Sutro proposes to add 10 UHF digital TV stations bringing 1:he total to 84. This co-location of 84 stations may create signal interference between antennas, which would be contrary to Sutro's (and FCC's) objective of maintaining minimum interference. All the facts and circumstances surrounding this SUbject as well as their study showing what amount of interference there will be, should be cov ered in the final EIR which is now being prepared. It appears to me from all the information in the draft EIR and all the questions it leaves unanswered that the new digital TV antennas SHOULD BE PLACED ON SAN BRUNO MOUNTAIN, NOT SUTRO. I am sure that if you read the draft EIR and my enclosed letters you will agree. Yours very truly, /I.;;i~1l:r-1tt;4-Ht~?--/ A. Anthony~odson,CPA cc: Supervisor Barbara Kaufman Board of Supervisors-Reception, Room 308 Veterans Building, 401 Van Ness Avenue Honorable Willie L. Brown, Jr., October 9, 1997, Page 3 San Francisco, CA 94102 Supervisor Torn Arnrniano Supervisor Sue Bierman Supervisor Amos Brown Supervisor Leslie Katz Supervisor Susan Leal Supervisor Jose Medina Supervisor Gavin Newsom Supervisor Mabel Teng Supervisor Michael Yaki Supervisor Leland Y. Yee cc: (without the attachments which were mailed previously) Hillary E. Gitelman The Environmental Review Officer Planning Department 1660 Mission Street, 5th Floor San Francisco, CA 94103-2414 Steve Nahm, Midtown Terrace Homeowners' Assn. P. O. Box 31097 San Francisco, CA 94131 George Linn 53 Aquavista Way San Francisco, CA 94131 Association of Bay Area Governments P. O. Box 2050 Oakland, CA 94604 Attn: Sally Germain Doris Linnenbach Twin Peaks Improvement 155 st. Germaine Ave. San Francisco, CA 94114 Kent Bach, President Twin Peaks Improvement Assoc. P. O. Box 31002 San Francisco, CA 94131 Elizabeth Kantor, Co-President Twin Peaks East Neighborhood Assn. Honorable Willie L. Brown, Jr., October 9, 1997, Page 4 P. O. Box 14025 San Francisco, CA 94114 Associated Press 1390 Market Street, suite 318 San Francisco, CA 94102 Attn: Bill Shiffman San Francisco Chronicle 925 Mission Street San Francisco, CA 94103 Attn: Elliot Diringer San Francisco Examiner P. O. Box 7260 San Francisco, CA 94120 Attn: Gerald Adams ~~~O~9. 1997 i I J ~ - CT ;: ,.:-q9~ - -~ /. '.J C' I"', _;' '-:t' Pt" '0 A. Anthony [\odson Accountancy Corporation Certified Public Accountant 62 Aquavista Way. San Francisco. CA 94131 Doris Linnenbach Twin Peaks Improvement 155 st. Germaine Ave. San Francisco, CA 94114 ~~\\~-~i.7'l,\\'2 ILL Ill!; i!! iii III II! I! I\! i It I!! II \!ilL 1IIlL Ill! II! L! I!! 11 150 Graystone Terrace San Francisco, CA 94114 September 05, 1997 Hillary E. Gitelman The Environmental Review Officer Planning Department 1660 Mission Street, 5th floor San Francisco, CA 94103-2414 Re: Sutro Tower Digital Television Draft Environmental Impact Report Dear Ms. Gitelman: I have requested a copy of the Environmental Impact Report but have not yet received it. I need additional time to read and study the contents of the report. I live in the neighborhood several blocks from the Sutro TV Tower. I have been a resident of the area for over 25 years. I have many friends who live right under the tower on Palo Alto Avenue and on st. Germain Avenue and visit them in their homes frequently. I am concerned about the safety of the tower. It has been on the Mt. Sutro site since 1971. Mr. Gene Zastrow, current general manager of Sutro Tower, Inc. has written letters stating that the tower is substantially corroded and is in need of repair. Now the proposal is to add another antenna at 760 feet to extE!nd down 125 feet. How much weight will this add to a structure built to support only NTSC antennas for 200 feet of the tower?ThE~tower is 26 years old and built to 1966 earthquake standards. What will happen in the event of an earthquake of a severe magnitude? Is adequate insurance carried by Sutro Tower, Inc. totakE~care of damage to surrounding properties and the two water reservoirs at the base of the tower? How are the water reservoirs insured in the event Sutro Tower falls and causes destruction to the city's water supply? How will sutro Tower failure and reservoir damage affect Neighborhood Emergency Response Teams in event of a disaster such as a fire in the heavily forested eucalyptus acreage extending from Mt. Sutro to Parnassus Avenue? There are many other concerns about Sutro Tower. Noise from gale winds blowing through the tower; interference to telephones, TVs, radios, VCRs, garage door openers; large and heavy objects blowing off the tower, metal debris and paint from tower maintenance, are experienced by numerous neighborhood residents. There is an existing non-residential San Bruno Mountain site that should be explored before considering any addition to Sutro Tower. A comparison needs to be made between both sites and a detailed presentation should be demonstrated to residents in the tower area and concerned San Francisco residents before allowing any construction to proceed. As a public official, it is your duty to impartially review the proposed project and determine the most environmentally safe alternative for the human beings who live in the area. Sincerely yours, Elaine A. Eklund 4. Ms. Hillary Gitelman lffic~of Environment31p~vi~w ='c:pt. of City Pl.3nnin'3 3an Francisco, CA Dear Ms.Git~lman; ), sane ; 9 hb 0 r' 0 f~H,': ut roT0 we f' for' 2 S ye .';1 r::, I W3 nt t 0 1 i s t my complaints and state my objection to any new~dditionsor ex pansion to the tower. 1, Dan,::/er' and :3.sfetv to the nei'}hbod"\Ood i.,::. earthquake, air~raffic.fa:ling equipment, etc. ~,Constantann~vancet~th~neighbors~~rhtraffic. d F- 1 i \,'.:::: (' ,. ,::.:' t:,~;1: he:: C \"i e 1", rna _oj' i-I t~j"'l-~jn c~.;... .., :.: C. k ::, -:-: n d r-' -:? pair noise on the tower. High levels of sounds from strong, high winds that are frequent in winter time, and all 1ear round. A threat for greater impacts of future transmissions from the tower, causing great concerno)~rth~health risks inth~n~iqhborhood. The to\t"el ['c:::.=.s ,e'thr'~3tto pr'operty'i::-I'Je:: ; -: th'? To ErR is ~oncer'n sum up my complaints and concerns, the proposed Draft in direct conflict with adopted environmental plans. for' th"" ci ti 7;:,:ns of :'.::tll Fr'i3i)ci sea .::Inc! communi t'l::Joals. , -:'/ /- C'. . / ~'II~~/i,-;.,~?e-;;'t"{.~;,,/ '-. ·3 the f' i n ei~,Fit z;ia t i" i c \ 86 C 1,::wendon Ave. ':,3nFr'anci:~co,C/.. c)4114 ~':ptemb e r'L~,I9 g7 JAMES L. FITZPATRICK 86 CLARENDON AVENUE ~~NFRANCIS:0, 1997 :::~::ptem!) '2 1 4 ,I9 9 -: itvrl~nni~l?cmm~:--on ::1 il f= r'c; il cisC () j C.\ Towe r':::: "of: .:: u t r' '.) - . t.:<pailSl0il E I F - - ..3:;:' :J GS 4 4 E ~33 homeowner int~eshad)w of Sutro Tower, I Jb ect to any expansion :::' p r .:, t i::) ',:. G f <'. u t t' 0 T :-:' wet': =n c . ·:1 tits p r' e ':; e n t f::lelitie.:. The p r' 0 j e c t '::!orn·:dor'3tructur',]1~hai,·~e::to the --'()\"er' to r'einfol-ce it to ,::nabl.=: a 1: :--·:~~t\'~'r'i::"1"""EI-\Cjl,:·mc:=::I-':::e: :::--=---:(_\d~dl?-~-ub?-t:,3nti3l'-han'=!,::'~Tlli'3 pt"OP!):" -,,~;-i i~i ,) il~(ll(1 iJ -j~~_\,_~~c .:::~_::\"1 m(-:~:~;·3 T: -:: ,- .-: r' i .::. -.3 .') t~11 -: h C-.~f i i1 i t -' '.) 1\ T..-." 1 --. \1 -j :3 i ()!I.:~n 1"",~Ii il .",::': \:.: l ': i i . 'r r' 1J ,':: 1': IJ (,~"TI-I 'S' '3.~:.:,'~'; :-l=i I:' ,3 r' ~:' -: '2 Ii Ei ! .::~a Ii~"lEl 1~:-:'(: T'" 0 m ~:n cI ,- t h ':::. r' d~v -;c,~s t \':~t3r'~7. - ;-1.::~~\.1'1~I' -:~-~.'?i c: ,'? 11 ? ~-,\!,::rthe ~n3d~iTiontoTh~radiation from the.~nal( ,~:d i 0 t (':. '1 I ul .::1 r' p h0n~:?,~::e c. uri T y ,/ ell :: a .=, 1: .::- r' C 8 ;; t' ("~ :',.',t ,-1.1:) 1 i c 1 ,c!dv,=:rti :3.-:-cl t!-,3t iI.3''--='-b::~n'::ldd::-:! :; uti' : 0 '1'/ e l' , I i-, c. :,,:;: S -=' J J r' e s :' i vel 'r' ~:-,,::C~·Ue.LE""H.-:l..H:'IV,)- "'C1dis"'i:'1! r;",:,m i:,,:,-', :'!j1.j'I':'J:"nd r!i·:}it31 -i::tn,:lls, ~11+heoth~rd~V1C~':~hatmayb~aJd 0 d to a~ubst2n:i311yr~intorc~d ~i1continue for 3tl~astnine -; : t:)'d The operation of these devices in a residential neighborhood, and adjace ':0,-",i::si':~iI,ated':H"?::lIi::-=:lt i: anoth'?;- llv::ur':;;l»i1 c,f .] commer-ci':11, for pr'ofi "qUE,:.; pu!)lic.~··-:.!"v',>::,':\ientl.ll"::. TillS ;::.;j tot,,::,llv inapprof,:'i.":'!t-::bus~nc? --)r' t:l'~·:-1 r' ,.:- 3 . ~:',.: r? h.:'1 :3 \) '2 e il II 0 rn.::: n T. i () ;-, 1 ,-. t h ,7, ElF ,') t the 'J n - 'J r' ':",1 II cl :' 1J P po 1-- t f ,] eli' -:: j -'~?~~l:;'d1::-,:::cc:c~mmc;,~.j.::"t-.:-:-i~::i"''::~Whr'oc1(j·.::,:::-~~:",:::~n,3rfii-+:t·:r=,.~h~diSi"'up'tinn~,_I~..ij ~i1::;tr'ucti()n,:1ild-r:h,:: ultimat.::: imp,3ct ,Ji, th.=: i1,,:iqhbC)f'hoOd~i-'iil'onm.=:nt. ~ur-r:hermorc,I stron31y object to the lack of real scientificdat~th i~veal:3th.::: h0alth hazards, historY of illness andint~rferenc~wi conduct of our daily lives, and that of all the neighbors in the vicinit -h~latest~ridemio~ogicstudy, 3S 3dmitted by the PlanningD~partm.=: ~nvlronm~ntalr~Vlew~r.was based on data at 1-::8st five vears old. ~tr~n~lj~Upr0r+~h~conc?pt)flocatin~all th.::: HOTV antennae~o Jf~~opriJ-r:eat~a:c~r~3a~edfrom our densely populated nelghbarhood. Ti' ,!(lul~!31101'l:! ph,s::: 'Jut of 311 br'oadcastin'] fr'om the Sutr'o Tower' :3i,::: ~-\(!.-.+.,~nl;-'=-·":::-:"·7"i·'~()d,,:::lnd 'J;\;'-':' usb'=':lct~our'r;·?;·~hbc:"·11()o~~11 -, + (') n!, Q 7 i 1 f +r"'7:~I(:"~''''''.., .' '"~:' J _' :.-- . mes L. Fitzp.'" id: August 25. 1997 Supervisor Michael Yaki San Francisco Board of Supervisors 401 Van Ness Avenue San Francisco. CA 94102 RE: Sutro Tower Expansion Dear Supervisor Yaki: We write to express our concern and opposition to the proposed expansion of Sutro Tower. It should probably be torn down. not expanded. The materials sent by the Sutro Tower Company are outrageous. Basically. they say: "Sure, the radiation from the tower will go up following the expansion, but we think the new levels are still safe." Of course they don't know. As people living near the tower, we don't particUlarly want to be part of some science experiment. They also say, "The tower was built m the 1970s Changing television technology now requires expansion." This logic is fatally flawed. A decision made more than 20 years ago should not be repeated and expanded just because it was made once. Do we learn nothing? Can we change nothing? Not only are there very real pUblic health concerns (let alone the effect of the tower on electric appliances such as stereos and telephones), there can be an adverse effect on property values to the extent that people believe the tower and its various forms of radiation may pose a health risk. We have seen the San Francisco city government get agitated about the possibility of a Blockbuster Video coming to Ninth and Irving and potentially affecting the "character of the neighborhood." We have seen concern over the number of coffee bars in some neighborhoods. It would be nice to see a comparable level of concern about something of much greater public health and public policy concern--namely. Sutro Tower. We oppose the expansion of Sutro Tower, and hope the Board of Supervisors and the planning commission will do the right thing and forbid it. Yours truly. Jeffrey Pfeffer Kathleen F. Fowler Hillary E. Gitelman The Environmental Re\iew Officer Planning Department 1660 \1ission Street, 5th floor San Francisco, CA 94103-2414 Em'iromnental Impact Report Proposed Addition toS~troTO\,."er 4 September] 997 Dear 115. Gitelman: We understand that Sutro Tower, Inc is planning to add a new 125-foot vertical support structure which ""iII hang from one ofthe top crossbars ofSutro Tower. FOR THE RECORD, WE OPPOSE .-\.K1 T EXP.-\.'\SIO:"\ OF SUJRO TOWER. The reasons for our opposition to the addition are as follows: 1. Our main area of concern is the potential for adverse health effects from radiofrequency radiation (RFR) During the time when bo:h Digital Tele\ision (DTV) and J\Tational Tele\'ision Systems COITIInittee G\TSC) signals would be broadcast, RFR \\ auld increase above existing lenls. We do not believe lhe! lhe health effect isssue has been adequately addressed in the draft Environrnefltal Impaact Report There have been no published reports to our knowledge that explain the actual biological effects ofRFR Hm\', then, can the report come to the CDnclusiDn that there would not be any ad\'erse health effects from the proposed project? 2. \Ve are concerned about the additional interference \\ith telephones, radios, TV's, etc. which limit the use and enjoyment ofour home. We presently experience considerable interference when we use our telephone. At times it is difficult to understand what people are saying. We have a stereo audio receiver which we are unable to use in the upstairs ofour house \>',ithout haying rock music blasting in the backgro:.md. I purchased an electronic btchen scale last Christmas which ,,,arks fine in the store but does not work in our home. \\Te had a e,Tuest to our home complain that his car security system would not work. The increased levels ofradio frequency radiation we will experience ifthis propsed expansion of Sutro Tower is approved will certainly not correct the problems we aree~periencing,they \vill only make them worse. Page Tv. a 4 September 1997 We are distressed that Sutra Tower, Inc did not see fit 10 notify us oftheir plans as we live only a block or tv.'o from the tower. We understand that there was public meeting on the project on 15 July 1997. \Vh)' weren't we notified ofthis meeting so that \\e might have been able to attend') PLEASE ADD 01..-'R NAo\fES TO THE LIST OF 'I\'TERESTED PARTIES' REGARDNG A,\Y ISSUE PERTAr\~GTO Sl.'TRO TO\\'ER.,~C Sincerely yours, . I ./l.<...J~c~r Wendell E and Hilde L Gerken 156 Marview Way San Francisco. CA 94131-12.20 (415) S26-2669 cc \ir Stephen X~a.hm,President \lid1own Terrace Homeowners Association PO Box31097 S2..'1 Francisco, CA 94131 towerOOl.wpw 101 Villa Terrace San Francisco, CA 94114 September 8, 1997 Ms. Hillary E. Gitelman The Environmental Review Officer Planning Department 1660 Mission Street, 5th Floor San Francisco, CA 94103-2414 Re: Sutro Tower Digital Television - Draft Environmental Impact Report Dear Ms. Gitelman: I am writing to you as the current President of the Twin Peaks Improvement Association. I am also writing to you as a second-generation San Franciscan who was born and raised and has continued to live in the shadow of Mt. Sutro and Twin Peaks. The current attempt by Sutro Tower to upgrade its facilities is almost a mirror image of the controversy which riled the neighborhood in the 1960s and early 1970s. At that time, we were told that we had to accept the tower here, as Mt. San Bruno could not provide the height needed for line of sight transmissions to the majority of Bay Area television viewers. As I am sure you are already aware, the reason for the push by the FCC at that time was the desire to improve direct reception and as a result, increase the number of color televisions purchased by consumers. If they couldn't get good reception, they were certainly not going to upgrade to a new TV. Now we are told that the Tower must upgrade to DTV and it must be up and running by October of 1998. This time, the broadcasters want to encourage the purchase of new TV sets to receive this new upgraded signal. The "mandated date", however, is not a result of an FCC mandate, rather it is a voluntary agreement between the major broadcasters and the FCC. The date has little to do with public service and a great deal to do with getting your product to market first. Recently it was announced that ABC, the parent company of KGO, which owned the tower site in 1966, has disclosed they will probably forgo broadcasting HDTV altogether and instead compress a number of regular-definition programs and some pay-TV programs into the digital pipe. If ABC/KGO is considering something other than DTV, the over 150 pages based on the assumption that the ten panel antennae will be broadcasting only HDTV are incorrect and must be redone with more complete data. NTSC or analog transmissions operate on a line of sight basis. DTV, however, does not. The necessity for such a tall tower no longer exists. Even Sutro Tower admits that a lower elevation is acceptable, as its current plan calls for antennae which begin at 200 feet below the top of the current tower. Representations made by Sutro Tower in its general information sheet issued to the public that DTV cannot be placed on San Bruno are incorrect. The EIR states in its "Off-Site Alternatives" section (pages 1-7 through 1-9) that DTV can be placed on Mt. San Bruno. The main objection by Sutro Tower appears to be the potential loss of revenue if they do not place DTV at their site. Unlike the situations in 1966 and 1971, the community now has experienced over twenty-one (21) plus years of real, verifiable effects from the existence of this tower in a heavily populated residential area of single family homes. The EIR states that this is a "low density" residential area. This is an incorrect characterization of the area, and would lead the uninformed reader to assume that this was an area of few homes on large lots, similar to a suburban landscape. I need not remind anyone in the Planning Department that San Francisco, by virtue of its 49 square mile limit, has no area that could be reasonably called "low-density", even if it is zoned RH1. The area surrounding Sutro Tower has one of the most stable populations in all of San Francisco. There is very little turnover, and residents rarely move when they retire, or when their children leave home. As a result, we have a~long collective memory. Many of the residents have kept files on their dealings with the tower over the years. The current sentiment is that Sutro Tower is not a "good neighbor". Not that they haven't made attempts over the years to mitigate problems; however, it is simply not in the nature of a 977 foot tall radio and television broadcast tower located in an urban residential area to be a "good neighbor" and continue to operate a successful business. The sandblasting, painting, guy wire repairs, "moaning" noises during windy days, and regular interference with everything from telephones to car alarms is a constant reminder that Sutro Tower is a neighbor. As a result of my perusal of the Sutro Tower Digital Television draft Environmental Impact Report, I would like to see the following issues addressed: Exactly who is Sutro Tower, Inc? Are the parent companies of Sutro Tower, Inc. fully liable for any eventuality concerning the tower? Is Sutro Tower, Inc. fully insured against catastrophic risks? How much insurance does the corporation have? Is it required to carry insurance? It is covered by a reinsurance company in case of a catastrophic failure? Who regulates the building codes for Sutro Tower, Inc.? Are broadcast towers covered under the 1997 Uniform Building Code? If so, is Sutro Tower up to date? If not, why not? Is the broadcast tower industry self-regulating? Under what guidelines are maintenance schedules kept? Do other comparable broadcast towers of similar weight and design exist? If so, are any located in major urban areas? Are any located in active seismic zones? Who regulates security for broadcast towers? Is a regular risk-assessment analysis taken by the industry? Are Sutro Tower's security procedures up to date? With the increased seismic activity in California, Washington and even Japan, and with the odd weather patterns we have experienced in the last 15 to 20 years" it is time that the Planning Department and the broadcast industry itself consider whether a major broadcast tower should be located at Mt. Sutro. Remember the Bay Bridge in 1989? No one ever expected it to fall...and as the result of a previously unknown fault. The current DTV project would be an ideal time to begin to phase out Sutro Tower. The old technology on the tower has served the Bay Area well, but at a very high price to its neighbors. I urge you to move DTV to San Bruno and phase out the current Sutro location. Sincerely yours, Nancy C. Hogan Everett R. Holn1boe 129 Marvie\v Way San Francisco. CA 94131-1219 Telephone 415 826 - 6378 Fax 415 826 - 6138 email erhinsf@aol.com September 4, 1997 Hillary E. Getelman The Environmental Review Officer Planning Department 1660 Mission Street, 5th Floor San Francisco. CA 94103-2414 Dear Ms. Getelman, Re: SUTRO TOWER DIGITAL TELEVISION I am writing to express my concerns regarding the proposed addition of multiple digital television transmission antennas to the Sutro Tower mast here in San Francisco. I am a resident of the Midtown Terrace district and live in the shadow of the tower. I recently learned of plans to considerably increase the hroadcast radio frequency radiation being emitted from the tower. hy introducing additional structural elements and antennas. The plan also calls for a considerahle increase in power usage ami dissipation at the sight. In an effort to understand the proposal I acquired a copy of the City and County of San Francisco ;Sutro Tower Diuital Television (DTV) - Draft Environmental Impact Report. I have studied the draft report and found that it does not address a numher of serious concerns I have regarding the environmental impact to my neighhorhood and l.lUr city Yesterday I had the opportunity to attend a community meeting along with two hundred fifty to three hundred other interested citizens. Many of these people present expressed concerns about the same issues I am addressing. as well as other issues that may effect their well heing. During the course of the meeting a numher of specific topics and questions were raised relating to the expansion into digital service. ? - Earthquake Safety Has the additional weight and wind loading surface effects heen adequately investigated vis-,l.-vis possible structural failure. Has the "fall zone" and possible environmental impact of rupture of reservoirs in the area heen addressed? Are these contingencies addressed hy the San Francisco Disaster Emergency Response Plan'? September 4, 1997 - San Francisco Planning Department .. Page 2 ? - Epidemiological Survey Have any studies been done that specifically address concerns regarding present or proposed increased levels of RFR at the frequencies and modulation patterns being proposed for the sight. Several attendees commented on the disparity between the studies sighted in the draft report and the actual frequencies and modulation methods being proposed. The RFR impact studies in the EIR are not on point in that they investigate frequencies that are orders of magnitude different than those we are exposed to. The vast majority of these studies address acute exposure, rather than chronic exposure. at various exposure levels that we are experiencing in the vicinity of Sutro Tower. In point of fact the Draft EIR states: "most experimemal data that indicate the existence of thresholds were obtained by the use o{ single or repetiti\'e exposures of relatively short durations and/or time periods. " What are the possible long term carcinogenic, mutagenic, and teratogenic effects of these combinations'? Are they adequately predicted by studies of other frequencies and modulation methods'! l{ave PEL TLV, STEL studies been conducted that renect the exposures being planned'? I live on Marview Way. essentially an equal distance from Sutro Tower and the additional radio masts and transmission sights located on the north peak of Twin Peaks. I am caught in a "cross-fire" between the two radiation locuses. I did not see anywhere in the Draft EIR any discussion on the possible cumulative and/or synergistic effects I might expect hy receiving the combined radiation from two strong RFR sources in fairly close proximity to my home. I do not believe that the constructive and destructive interference resonances of these multiple sources is fully understood or analyzed. and the physiological effects of exposure to these fluctuating RF fields is no!entirel~'quantifiable. ? - Increased "Electronic Noise" What can we, as residents of the area, expect in further degradation of our quality of life caused by a significant increase in the level of RFR emissions. The new transmissions being planned will include from ten to sixty additional radio frequency carriers, all with the possibility of interfering with existing RF sensitive equipment. Many of the residents of the district recounted ongoing problems with all manner of electronic devices. September 4, 1997 - San Francisco Planning Department - Page 3 ? - Increased "Electronic Noise I' - Continued... Will our quality of life be even further diminished by increased interference with common electronic instruments and devices? We are currently denied "normal" usage of telephones, televisions, audio and video recorders and play back equipment, garage door openers, and automobile alarms. What are the potential hazards of induced arrhythmia. bradycardia or tachycardia to those members of our population that require a heart pacemaker of monitor? ? - Failure to Address Long Term - Key Environmental Issues - Impacting Our Neighborhood and/or Potential Alternate Sites. Cont1icts with adopted environmental plans and community goals. Inadequate examination and treatment of alternative site proposals - specifically Mount San Bruno, Mount Tamalpais, Mount Diablo., or other alternatives. The draft EIR also contains factual inaccuracies and omissions regarding FCC deadlines and schedules. In view of the above concerns and open questions, it would seem prudent to reevaluate the advisability of introducing a significant source of additional radio frequency radiation to the heart of our urban environment. Sutro Tower should not be a test bed or laboratory to evaluate the possible deleterious effects of a significant increase in RF energy radiating into our environment. Especially considering that there are excellent alternate locations available that do not have potential sensitive receptors abutting the immediate perimeter of the transmitter facility. The proposal to add DTV transmission antennas to Sutro Tower has brought to light a number of environmental considerations relating to the existing facility and structure. We have been given an opportunity to reevaluate the necessity and desirability of a project that was built prior to our present level of sensitivity to, and awareness of. environmental issues. It is probable that if the existing structure had not been constructed, it would never be allowed to be built at its current location. Sutro Tower is an unmitigated environmental disaster. We are being given an opportunity to redress, rather than perpetuate, the excesses of the go-go sixties that allowed abominations like the Embarcadero freeway and Sutro Tower to be built. September 4. 1997 - San Francisco Plalming Department - Page 4 Many of the people attending the community meeting recounted numerous negative environmental impacts on their day to day lives. A number of people also expressed a high level of anxiety regarding potential dangers inherent in having Sutro Tower in the heart of an urban area. Many of these concerns will be exacerbated by the addition of DTV transmitters and antennas / ancillary structures to the tower. These existing environmental disasters and concerns for potential danger include: ? - Existing Radio Frequencies Interference This currently exists at a level that precludes day to day enjoyment and usage of common electronic devices. ? - Foreign Object Damage Below the Structure. Objects and debris have fallen off / been blown off the tower on a number of occasions and have been found on city streets and residential areas adjacent to the perimeter of the structure. ? - Possible Hazard of Collapse Due to Earthquake or Terrorist Activities. There is a very real potential for injury to population and damage to residences and personal property in the area. The base of the structure is easily approached on foot and very difficult to secure from possible terrorist attack. The height of the tower is such that a number of private homes and public facilities, including reservoirs, are at risk in the event of a collapse. The initial design load engineering called for only 50 mile per hour wind pressures. We have witnessed collapse of other structure built to 1960s design specifications, ie; the Bay Bridge and the Cypress Structure. Sevrember 4, 1997 - San Francisco Planning Department .. Page 5 ? - Exposure to Hazardous and Carcinogenic Substances. In 1992 an extensive maintenance project exposed a wide radius of the surrounding community to known carcinogens; silica (sand), lead (paint particles) and other chemicals utilized in a major cleaning and painting project. After only twenty years the facility had considerable rust and corrosion damage that necessitated grinding and sand blasting as well as subsequent repainting. These activities exposed many people to unhealthy levels of toxic and hazardous materials. This action will undoubtedly need to be repeated a number of times in the next centurv. ? - Hazard to Aircraft The top of Sutro Tower raises to a height of over 1800 feet above sea level. This is almost twice the height of the highest natural land form in San Francisco. Twin Peaks rise to 904 feet and 920 feet, exceeded only by Mount Davidson at 927 feet. The entire tower is often shrouded in fog and the potential danger to aircraft has necessitated expansion of the strobe light arrays in an effort to mitigate this danger. The possible alternate site on Mount San Bruno would allow lower antenna structures, present less of a hazard to aircraft, and virtually eliminate the possibility of injury to persons, or destruction of property on the ground, in the event of an accident. Any aircraft collision with Sutro Tower presents a significant risk of injurv or death to the general populace in the vicinity of the tower. One of the most frightening hazards that came to Iight during the community meeting on September 3, 1997 is the existence of documented "hot spots" in the vicinity of the tower. One of the people present at the meeting recounted an incident \vhereby a metal warning sign attached to a perimeter fence became thermally hot enough to hubble the paint on its surface. The sign was thermally hot enough to present a contact hazard to anyone touching it. This incident was confirmed by another person attending the meeting, Mr. Richard Lee of the San Francisco Public Health Department. The hazard was serious enough to necessitate removal of the metal sign in favor of a wooden sign that would not develop eddy currents and exhibit thermal heating. This incident demonstrates the interaction of environmental factors or radiation sources in an unpredictable manner that was not anticipated. ~e(ltember4, 1997 - San Francisco Planning Department - Page 6 The possible acute and chronic health effects of these unpredictable occurrences would definitely incline me to lean toward a very conservative approach to adding additional high power energy sources to my immediate environment. What is the effect of induced localized hyperthermia resulting from metal plates, pins, fillings, or prosthetic devices implanted in the bodies of some members of our popUlation. I have had extensive metallic hardware implanted in my tibia and fibia as a result of an accident. I am concerned as to the acute or chronic effects of localized hyperthermia occasioned by their interaction with extensive fluctuating RF fields in my environment. We, in this country, and on this planet, are witness to many many disastrous environmental legacies that in their day did not pose a recognized or regulated potential for hazard. The rust belt in the mid west and extensive "brown field" acreage in inner cities of the east coast bear witness to the unwitting damage that has been wrecked upon our living spaces. We have a golden opportunity to set right and reverse a potentially long term environmental hazard that is our legacy of the sixties. Sutro Tower is a project constructed at a time when NTSC broadcast signals was the preferred method of propagation of television programming. ()ver the past twenty five years technologies have changed and the market necessity for such a tower is now very much in question. Currently fully two thirds of the populace receives television via cable. For the remaining one third of the population DTV signals broadcast form an alternate site would be equally effective in providing service that would be comparable to that provided by allowing Sutro Tower to engage in increased RFR emissions. I understand that essentially no human endeavor is without risk, and that part of our existence is a risk / benefit analysis with regard to environmental hazards and safety for our general population. The Draft EIR states: "In the specific case(~rRFR from the proposed Sutro Tower Digital TV hroadcasting. there are no studies in\'ol1'ing precisely this technology nor is there an extensive bod.\'(~!e\'idence (i'oll/ studies ot exposure to the general population tram broadcast to\\'ers. " In this case alternate sites clearly would achieve the stated goal of delivery of digital television to this market area, with a considerable reduction in current and potential risk ItO the general population impacted by Surro Tower. September 4, 1997 - San Francisco Planning Department - Page 7 At the very least, I feel it is prudent and necessary to request additional studies. gather more information, and request additional time to review alternatives to adding digital TV to Sutro Tower. A decision to stop the plan to install DTV transmitters and antennas would have two fold benefits. It would be a proactive decision to obviate known environmental degradation as well as potential disastrous health effects occasioned by poorly understood interactions of untested technologies. A secondary, and perhaps more important benefit, would be the removal of an existing proven environmental hazard by rendering it llhsolete. What an opportunity! Seize the day~ Everett R. Holmboe CC: Mr. Steve Nahm President Midtown Terrace Home Owners Association Senator Quentin L Kopp California State Senate District 8 Everett R. Holmboe 129 Marview Way San Francisco, CA 94131-1219 Telephone 415 826 - 6378 Fax 415 826 - 6138 email erhinsf@aol.com September 10, 1997 Hillary E. Getelman The Environmental Review Officer Planning Department 1660 Mission Street. 5th Floor San Francisco, CA 94103-2414 Dear Ms. Getelman, Re: SUTRO TOWER DIGITAL TELEVISION This is a follow up letter to my letter of September 4, 1997. I realize that today is the last day to comment on the Draft EIR and there are several additional points that have come to mind since my last correspondence. At the community meeting of Wednesday September 3, 1997 Mr. Eugene Zastrow, Vice President and General Manager of Sutro Tower Inc., addressed the meeting with regard to concerns regarding increased exposure to RFR should the project move forward. In his comments he remarked the part of the redesign of the tower includes moving several FM radio transmission antennas fifteen to twenty feet higher on the tower. Mr. Zastrow stated that due to the inverse square law of energy propagation, there would be a small reduction in RFR energies from these few antennas, that could be measured at ground level, and at sensitive receptor sites beyond the perimeter of the installation. Upon study of Mr. Zastrow's comments I again reviewed the Draft EIR and found that there is no discussion of the impact of increasing the power output by a factor of ten for three stations, from 100 kw to 1,000 kw each, and more than doubling the combined output of the remaining VHF stations. while lowering the antenna location by several hundred feet. If Mr. Zastrow's remarks, based on the inverse square law of propagation. regarding raising the position of a couple of FM radio antenna would lower the RFR emissions at ground level, would not the same laws of physics lead to an increase in RFR energies at ground level due to a substantially lower position of the new antemlas on the tower? Mr. Zastrow further stated that the FCC bases many of their studies on a magic number of I kilometer from the source. In point of fact, we have a situation where residences and potential sensitive receptor sites are at one tenth the distance from the base of the tower. I would presume that the information presented in the Draft EIR is predicated on the height of the lOwer being factored into the distance from public exposure. If that is the case the new location proposed for DTV antennas is considerably less distant than top of the tower where the existing antennas are located. September 10, 1997 - San Francisco Planning Department- Page 2 The Draft EIR also fails to address the difference in height between the primary broadcast antennas at higher than above 900 feet above ground level, and the secondary antennas located at less than 200 feet above ground level. If these standby antennas are operating at the same power level as the primary antennas the RFR exposure for residences adjacent to the site is quadrupled! Does this four time increase in energy density move the populace from a risk factor of 12 % to a risk factor of 48 % of the FCC mandated sate levels') One other topic not fully explored in the Draft EIR is the impact on structural integrity of the tower due to increased load and wind resistance. The Draft EIR does not stipulate the potential fall zone around Sutro Tower The fall zone varies with elevation from 297 Meters (976fc~t) to 280 Meters (921 feet), from the center of the base of the tower. The potential fall zone includes properties on the following residential and community access streets: Palo Alto Ave. Gleenbrook Marview Way Panorama Dr. Dellbrook Ave. Oak Park Dr. Crestmont Dr. Clarendon St. Germain Ave. Farview Ct Clearview Ct. Greenview Ct. Forrest Knolls Dr. Woodhaven Ct. La Avanzada How is this potential hazard addressed by the San Francisco Emergency Response Plan? All of these issues become moot if the project simply moves to a less urban site. The closest possible sensitive receptor site from existing antennas on San Bruno Mountain is over I kilometer, tens times the safety zone available to SUlro Tower! Everett R. Holmboe Enc1: Fall Zone Map and Table of Elevations CC: Mr. Steve Nahm President Midtown Terrace Home Owners Association Senator Quentin L. Kopp California State Senate District 8 Sutro Tower Fall Zone Analysis September 10 I 1997 Distance From Base in Meters Distance From Base in Feet Drop Elevation in Feet Height Tower in feet Elevation At Impact Point 298 977 25 977 809 297 976 50 977 784 297 974 75 977 759 296 972 100 977 734 295 969 125 977 709 294 965 150 977 684 293 961 175 977 659 291 956 200 977 634 290 951 225 977 609 288 944 250 977 584 286 937 275 977 559 283 930 300 977 534 281 921 325 977 509 ~7'30n 1 :.~""" -?.:5::'~!..~., _ .." ... _.. _-------- . ,_.,_, __,,~.1'l...'JjRJHi,]Y\1~~I&L,_/'3.£yjE.w.,-C2EFI~CJE1 -_._--------- ---,---' --- -----,-- --- ,. ,----------,-'----' .- ___. , ":QE_~~_~jl\ h~f ) -------l'l~..;-\-1.)Q._C~=to I:rp.c.$.L---i..h.L--~pQ.n5..;..:.<1,o£'..:L!"c- _'5 ......:\'..---'_ - ==:Lc w. 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As a homeowner residing since 1966 at the above address which is located less than 500 feet westerly of Sutro Tower I respectfully request you to then take into consideration and address the following : 1. In the letter dated May 9, 1997 of Ms. D. Stein of GCA to Ms. H. Gi telman of the Planning Department - a letter '''''hic:h was adopted by the Department as, or part of, the Categorical Exemption it is stated ( page 1 ) that " ... after decades of exposure and corrosion , the Tower is no longer at peak structural integrity and seismic safety." , and again ( page 2 ) ..... improvements are required to restore the deteriorated structure to meet current safety standards, .. 2. The San Francisco Bay Bridge and the Golden Gate Bridge, both over 60 years old and located in a substantially more corrosive environment than Sutro Tower, appear not to have required any corrosion - offsetting structural strengthening . Evidently, that need. was.- obviated, or minmized, by constant rigorous rust-inhibiting maintenance. 3. In his letter to "Dear Neighbor" dated September 24, 1992 , Mr. Eugene Zastrow, General Manager of Sutro Tower Inc. mentioned 'I' .' ,of' ,. / 2 that, during the first nearly twenty years of the Tower's existence there has " never been an overall cnrrosion rem'Jval and repainting project, . 4. Several hundred people live within a 977-folt radius of the Tower . 5. Is it a function of the San Francisco Planning Department, or any other City agency - and if it is not, sh'Juldn't it be ? - to m'")nit~r,on a c'Jntinu8us basis: a) the residual structural integrity of Sutr"l Tower and its conformance with applicable safety standards as to wind loads and concurrent seismic acceleration ; and b) an effective and continual corrosion-inhibiting maintenance program established and implemented by the management of Sutro Tower Inc. ? Let me assure you of my appreciatinn for Y::lUr giving attention to this matter. ~~ Ernest Kahn cc: The H'Jnorable Quentin L. Kopp, Senat..,r, Eighth District, California Legislature 1\'1r. Eugene S. Zastrow, Vice President and GeneralManagE~r, Sutro TaVieI' Inc. Mr. Stephen X. Nahm, President, Iviid tov,m rrerrace Homeowners Assn. Ernest K0hn 497Dellbr0~kAvenue San Francisco, CA 94131 September 7, 1997 Ms. Susan Lowenberg, President San Francisco Planning Commission c/o Ms. Hillery E. Gitelman The Environmental Review Officer 1660 Mission Street San Francisco, CA 94103-2414 ccPy Subject: Supplementary Comments to Sutro Tower Digital Television (DTV) Draft Envir::Jnmental Impact Report Dear Ms.L~wenbergand Commissioners Please regard the fJllowing as supplementary to my comments 0f August 25, 1997 . 1. The DELi. being f:)cussed on p0tential health hazards due to RFR , my cnmments addressed the inadequacy Jf the material presented tJ suppJrt the assertion that Sutro T')wer RFR levels do not and w')uld not exceed the FCC Guidelines 96 allowable maximum . My comments further suggested detailed and comprehensivemeasuremen~sto cJrrect that inadequacy. In the absence of such measurements, and in deference to yJur judgement whether to concur - with or without qualifications - wi th the Public Heal th Department!;s quoted npini jn that exposure below the FCC Guidelines 96 level "... w:)uld not be harmful tn human health.", I refrained from advocating either aoprJval or disapproval of thepr~ject. 2. At the September 3, 1997 infJrmatinnal meeting here in Midtown Terrace, spsnsored by tw:>neighb)rh')~)dassociations, the sentiments e::pressed by many l')cal residents re-.emphasized our ccncerns nnt nnly ',dth the health issue, but als') wi th these nther impacts : a) risk ()fc~llapseof the tower due to earthquake, settlement, structural corrosion etc.; b) v isual intrusion nn the neighb")rh')od character c) reducti')n of priperty values; d) sandblasting debris, paint, falling objects; e) wind nnise; f) interference with telephone, radio, 'rv, etc . My uncommitted stance re approval/disapproval of the project within the context of the as yet to be corroborated issue of exposure levels does not apply to these other impacts. These constitute either potential safety hazards, or constant impingements on one's peace of mind , or periodic damages or nuiSances. Approval of the 1 project would not only aggravate these impositions - be it only marginally - but it would also, more importantly, place the Planning Commission's and Department's imprimatur on their perpetuation . On these grounds, I respectfully urge you to disapprove the project . J. In 1988, in the absence of a DEIR, but in "... an aura of doubt and uncertainty as to the safety of exposure to electromagnetic radiation... " ( Resolution 11399 ) the then Planning Commission adopted a motion of intent to disapprove the application for the addition of two antennas to Sutro Tower. The applicant then withdrew the application which left the Commission" ... without a vehicle for a written expression of its concern over this matter It. It appears likely that the absence of such an expression may have aggravated the "aura of doubt", and, worse, contributed to the perception, in the minds of many a local homeowner - occupant or prospective - that this kind of RFR does indeed constitute a serious health risk. 4. If adequate documentation presented in the FinalEL~supports the argument that the project could be apprt)ved because RFR exposure levels were found and expected to be within the range considered to be "safe" as to human physical health effects ... . . . but if the pro ject is disapproved:m the gr')unds that appr')val would implicitely sanction the perpetuation of other impacts namely some or all of those listed under item 2., above - impacts v:hich are , or have the potential to be " ...detrimental to the health, safety, convenience or general welfare of persons residing or working in the vicinity" ( Code Section 303 ) ... . . . then , in order to minimize the counterproductive psychological impacts of the kind which may have resulted as a side effect of the 1988 ".... absence of expression ... " , I would respectfully urge you to state for the record - and for press release - the fact'Jrs v:hich were, and those which were no t , the bases for the disappr:ival. Again, thank you for your efforts and consideratiJn given. S~JYV;L :2rnest Kahn cc '£he Honorable Quentin L. Kopp, Senator, Eighth District California Legislature Mr. Stephen X. Nahm, President, Midtown Terrace Homem"'l1ers Assn. ,,-. l'v1s. Doris Linnenbach ,I'vdn Peaks Improvement Association 2 Ernest K:ihn 497 Dellbr:i'K Avenue San?rancisc~,CA941~1 Sep~ember26, 1997 The Hon0rable Quentin L. Klpp Senator, Eighth District C21ifornia Legislature 2171 Junipero Serra Blvd. Suite 530- Daly City, CA 94014 He Sutr 1 r~werDTV Dear Senator Kopp 'Thank you for your letter)f September 1:). 1997, and especially for the prospect of your lending supportt~~he~pp~siti:)ntJ the additi:in jf antennas for DTV on Sutr0 'l''''::er. I - :: 'r "ne - will greatly appreciate it if Y0U could use the means ,f Yjur :iffice to that purpjse. About two hundred local residents partici?ated in the September J, 1997 informational neighborho0d meeting ( see enclosed copy of an article in The Independent of September 9 ) which was sp"nsored jointly by the Mid tnwn Terrace HomeClwners Assnc iat i"n(r,~'n{C)A)and the Twin Peaks Imprnvement AssociatiCln (TPIA) . Many of the attendees voiced their c'mcerns regarding the tr)wer. and a petition form ( copy :if blank is enclosed ) listing the plethora of impositions was used - at and after the meeting - by them and other neighb'Jrs t'J enumerate their e'jneerns . It is my understanding that several hundreds 'Jf signed forms were delivered by the associati:ins tJ the San Francisc'l PlanningDe~artment. The MTHOA and TPIA Boards are now engaged in ajoin~effort to ensure that DTV antennas are not added to Sutr; f'Jwer. I have mentioned the tenor of Y:jur letter tj Mr. Stephen Nahm. President of MTHOA ? Although I cannr:Jt speak for the Boards of Directors of the two associations nor for the actively interested hun&reds of residents in this~icinity? I just cannot but feel that most - if not all - of them would also welcome your support . Thank you for your interest of many years standing in this matter. Sincerely yours I1j ~rnest \ Encl.'\ Kahn cc :Mr~Stephen X. Nahm , President, MTHOA Mrs. Doris Linnenbach , 'rPIA Ernest K"')hn 497 Dellbr'l'lK Avenue S~.nFrencisc'" I CA 94131 liitchell Eatz, r';:.D. A.cting Direct,r San Francisc r ; Department ;~r,'1m 306 101 Gr'we street San FranciscJ, CA 94102 Dear Dr. Katz : ~ct,ber26, 1997 --:,f Public Health sutro Tower Digital felevisi3n (DTV) DraftEnvi~onmentalImpact i{ep0rt (DEIH) DTV Radiofrequency Radiation ( DTV RFR ) Potential Health Hazards I liveab~ut100' frJm Sutrn Tower. Like hundreds of my neighbors, I am c'Jl1cerned ab'Jut pr)tentially detrimental health effects due to RFR fr'lm the proposed DTV transmissions from that tower. Press reports ( Seotember 16 -Oct~ber14, 1997 issue of The City Vnice ) have brnught tl the public's attentiln certain new details regarding the involvement ,f y,ur department in the preparation 0f the DEIii , in particular y,ur selectinn .' under pressure" of Dr. C.K.Ch~uas Peer Reviewer ,)f the P'Jlson-Heynicit Bi')l'lgical Effects rep'lrt ( Appendix B ,f the DElH ) . As the DEIA d,es n,t include a statement ')f opinion byOr~Chnu - he is 'inly named as peer rev iewer 'In the title page of the rather complex 104-page repr)rt - it appears that this expert agreed in t:-Jto vii th the evaluations, opinLms and c:Jnclusions Df the other two experts . Similarly ( see statements 0n pages 1-4 and 3-14 of the DElR ) your department concurred with one of the critical conc1usians of the .. u Appendix B repnrt - and did nGt disagree with any parts of that rep0rt nor present any comments or reservations . That gives rise to dQubts as to the extent and detail of your department's review of that report. Therefore, I submit the following points for your consideration - or re-consideration , as the case may be : 1. Safety: Positive Standards vs. Probabilities and Reservations 2. New Technr,l.)gy : Biol()gic Effects c0llaterally inferred but as yet n0t specifically determined 3. Biol'lgical Effects : Pulsed vs. Continuous Wave (CW)i~'R 4. Sutrn rower DTV : RFR Pulse Peak Power Densities 5. Minimize Health Hazards 1. Safety: Positive Standards vs. Probabilities andReservati~ns lbe intr'Jduct',ry paragraph)f Chapter 7.0 General C0nclusinm, ( page B-7l of Appendix B ) ends with the phrase :" Based on present kn1wledge, human exposure at Clr belT"! the permissible levels recommended by the IEEE and ') ther Jrganizat Lms « e. g. adJpted by the FCC 96 Guidel ines )) is n0 t harmful tn h'_tman healttl ." " Cfhat is a positive, jet qualified, stater1ent . C)nversely, Ch3Dters5.0 Unresolved Issues and 7.0 ( pBges B-69 thru 13-72.) are fraught v,l th pr)baoilistic qualifiers and reservati ms : " basic uncertainties .... " " Y1"stunli~~elyto be deleteri 'US " n tful~-:lunderstlod.... " " n)t n"ssible t-:> guarantee .... " "C~i:ltl~'lversyremains .... " " need f;I'~)ntinuedresearch...... .. D;,t IHi:el.r t'>pr~,ducehea.lth effects.... " " n') t dem 'D'S tl'.'ated any 1i:.cely health hazard " 'rhus, we have here the juxtap,')siti')n~fa Federal and')rganiza~i'mal. Standard t ')n the')ne hand, and findings ",'hich are')ften tentatlve , glven with much scientific hlnesty and prudence - which is commendable - and probably with some legalistic caution. which isunderstandabl?~. ~eref0re, as even the standard is qualified by the recogniti 0 n 0f as yet inc )mplete kn<Jvrledge , i tma~\:esC')mm0n sense that , if given the ch:Jice, the m:1st prudent alternative must be ()pted for . ..s. Nev' Technol-,gy : Binlogic Effects c"llaterally inferred 'but as yet not specifically determined The following statements, from Appendix B, tend tn indicate that the conclusions regarding 2.nticipated bL)logical effects']f sutro T,"wer DTV pulsed RFR were based~nmajor or minor similarities - but not congruence with the cause/bil-effects relationships nf certaln,ther types ;If RFR of different p 0 wer, frequency, modulation, duration ofexpos~restc. a, (page B-3) ", .. . DTV signals are distinct from all signal types used in health-related research." b. (page B-8) "The various types ()f radar use a variety of pulse width and repetition pattern. These factors make biological andepide~i~lngicalstudies nf radar exp0sure least relevrl.nt t'l DTV ." c. (page B-19): " A few « epidemiological ))studies directly address populations near radio and TV towers, but none concerns signals fr')m DTV transmitters operating in the range fr;m approximately 500 .,;.-, 800 MHz. {( as v!iuld Sutr') 'rr)';,:er DTV )) " d. (pages B-IO/ll) : ":~either the typelf ffi'Jdulati'Jn I')f the prJTnsed sutr; T')wer Digital crv signals nor 'If the existing SutrJ 'rrnver TV signals matches)r clisely resembles thety~oeaf mcdulati'ln used in past biilogical research ((~fnlnthermal interacti'Jns ») v'.'i th ffi,)dulated HFR." These statements lead t') the perceptiJn that all the research results selected for evaluatiJn in Appendix 3 - ')r indeed the entire b')dy 0f past RFR research results_is 0nly marginallyreleva~tt~the ,bjective of predicting the potential 'biological effects of hwnane:Yp:~suret) the proposed Sutro 'rmver my pulsed RFR ? And, c')nsequently , that this objective still remains to be pursued by direct research vri th this particular type ')f radiati0n . ." L · 'J, Eillogic8.l Effects : Pulsed vs. Crmtinuc)us Wave (CW) RFR ..~- ~everalstudies discussed on page B-2? indicate that there is greater eye damage due to pulsed F.FR than to CoW RFH under corresp-:mding c')nd i ti ins. Al~3'( pages B-25/26 and B-2?/28 ), humans can perceive certain pulsed ,{?l{ as apparent sClund due to thermoelastic V'2.ves in their heads . The repnrt d:J8S not say .....rhat would be the sh"rt- or l:)ng-:-term (years r,r decades) bi"llngical effect :if such waves, of intenSity levelbel~wthat )f auditJry perception. Effects ']n DNA 'If.rere f;:mnd to be stronger due to pulsed RFR than t":J CW.RF~ ( page B-29 ), and results of tests with rats expc'sed ta pulsed RFh at l0",er than tissue heating levels showed that these It ??? may influence the c,urse of the cancer process." ( page B-34 ). It thus seems obvious that future research should be focussed on pulsed RFR of the characteristics proposed for sutro Tower DTV ? In the present absence of the results of such research, the report appears to have been c .... nfined t'" ...' skirting the target . 1+.~)utr" l'!wer DTV : RFR Pulse Peak P,wer Dens i ties. The about 1700 : 1 ratio~fpeak vs. average power density (~ayand Behari study, page B-29 ) and the 1000 : 1 such rati:) limit specified by the internatirmal guidelines ( page B-4 ) indicates a difference of three :,)rdersJf magnitude that needs tn be addressed : rhe " Summary of p"tential Bi01cJgical Effects" (page 3-13) states that 12'ry£v~r~g~power w'Juld beE.elo~the presentNT~C_p~a1spower , and 12TYav~r§:g~power would be ab0ut 1/8 of theNr~C_ayeEagepnvler . lI'lention (if the proposed Sutro T,wer DrV Dulse Deak power is c:msnicu"us for its absence . - - - - - The highest reported incident average povrer densities from the present S~t~~.towerN~SCtransmissions 2 at any residentialrec~pt0rin the VlClYnty, are ab'Jut 0.03 rnW/cm . Using the above mentl.cmed 1000:1rati~ the pUIZe peak power densities to be expected there w1uld be about 4 mW/cm (O.OJ x 1000 / 8 ). Since the pulses wl')uld be I')f very sh)rt durat i on, theremaY,\b~,presumably, no heating effect ; but ",'hat cluld possibly be~therl'Jng-term biologically deleterious effects? ( At site A , a breeze fluctuating between 1.2 and 2.0 mph (cf NTSC peak) has an average speed of 1.6 mph (cf NTSC average). At site B , the average wind speed is 1/8 'Jf the site A average speed, or 0.2 mph ( cf DTY average) . But here the wind gusts f,r just one minute about every 16t hours .... at 200 rrmh ( cf DTV pulse peak) ....~: ~fth,:-t happens during a single st;rrn (cf experiment ), the lnhabltants ( cf cells ) may rebuild ; but if it is a daily, year-r'Jund~ccurrence( cf long-term human exposure) ..... J ~:'Ilinirnize Hec,l th Hazards Th8 line-if-sight distance from the prop0sed Sutr'J TJwer antennas tn the nearestn~sidentialreceptor is abJut 800' ; fr'"Jffi the antenna l Cj e:lti;n( s) "I U:t. Sen Brunt) - tr) the nearest residential recept,r it is (VI uld be)iVer JOOC' . ,r f,ur (4) times that far. Giv r>D the inverse square principle of RFR wave pr::-pagati-:n. impacts):~ DTV pulsedRF~1n the ffi0St critically exposed general p,pu1atinn w0uld bf) ;,i.zteen ( 16 ) times weaker with the DTV antennas l,cat,ed 'In rH. San Bruno than if l'Jcated 'in Sutrr: T0wer . Unless and until ( detrimental) health effects ')f flrV RFR are better 0r fullyunderst~0d- and this is evidently nat yet the case - ,an unquantifiable risk fact,r remains. To minimize it - as is eVidently quite feasible - it'i'~Juldbereasrmable~prudent, and in the best interest .,f public health t') 1::)cate the new transmittersn()t~,n Sutr'! 'r,wer~but.n a highl(Jcat.i~:nmore rem0te fr"m residential areas. such as Mt. San 3run' . 1 trustth~tI have added ,t~S'lme degree,t~y'lur aopreciati0n 'If the c'lncerns regarding thispr~ject.T~the extent that this is the case, I respectfully urge y'1U to c'lmrnunicate your Jpin3.m t'J the members "f the San Francisc) Planning C':nnmissiQn . '~'hanl(y'lU fnr yr;ur attenti')n to this matter . 3incerely y-mrs cc l'he Hr;norable Quentin L. J(opp, Senator, Eighth District, California Legislature JiIlr. Paul Maltzer, EIR C0ordinator , San Francisc-) Planning Departmen Mr. Stephen X.i~ahm,President. Midt'Jv·m 'rerrace H.,meJwners Assn . .....Jtr,js. Nancy Hlgan. President, '.L'1rin Peaks Impr:wement Ass)ciation , cjr,; (and f"ir perusalJ"JVs.D'J~isLinnenbach, 'rPIA ,.;IJI1'" 4 Marian Bernstein 180 Palo Alto Ave San Francisco, CA 94114 (415) 731-9309 September 9, 1997 Hillary E. Gitelman Planning Department 1660 Mission Street 5th floor San Francisco, CA 94103-2414 Dear Ms. Gitelman: This letter is written to express my alarm about the proposed changes to the Sutro Tower. As you can see from my address, where I have lived for over 40 years, I am directly in the "fall radius" of the Sutro Tower. I). The Tower is now over 30 years old., fortunately has withstood one earthquake, is rusting (see your EIR), and covered with various antennae, (many more than had been originally approved). All towers built several years after the Sutro Tower. could be located ONLY in an area where the "fall radius" was WITHOUT human habitation. My home is directly in the "fall radius" of the aging Sutro tower. Not only am I concerned about its present state, BUT I am horrified that any responsible agency could conceive of ADDING to this AGING tower. 2). Noise from the tower IS impossible, whenever there is a strong wind storm. To add another unit, suspended from the center of the tower to house the new digital equipment, is INSANE! 3). Electronic static, disturbance of answering machines, ghost openings of garage doors, inability to get the classical FM stations are only some of the problems we have faced for 30 years. And now a plan to more than double the output from the station: THIS IS OUTRAGEOUS! Sincerely, 445 Del1brook Avenue San Francisco, CA 94131 September 4, 1997 Ms Binary E. Gitelman The Environmental Review Officer Planning Department 1660 :Mission Street, 5th Floor San Francisco, CA 94103-2414 Dear Ms. Gitelman: I am writing with reference to the proposed modifications to the Sutro Tower antenna to increase transmissions to allow sending digital TV signals in addition to the cunent analog signals .. I was out oftown much ofthe time since the Draft EIR on this project was issued and I have not had a chance to read it. Nevertheless I have several serious concerns to bring to your attention for your consideration. The first pertains to health aspects ofthe proposed increased signal. As you are undoubtedly av.;are, the question ofhazards to people's health from RF radiation is controversial today. My question to you is whether it is really not irresponsible to pennit increases in the RF radiation originating from a site near the geometric center ofa very densely populated city. There is no absolute assurance that this radiation will be hannJess. In the, perhaps unlikely, event that the increased RF radiation is indeed subsequently shown to be hazardous, It would been hard to fmd an area for the transmitter that would have impacted more people. My main reason for writing you is concern the over the em'ironmental impact ofthis increased level ofradiation on our home electronic devices. The problems res.ulting from interference from even the present transmitters atop Sutro Tower are frankly unacceptably severe. For example, I have recently had to give a\vay an expensive electronic keyboard because the annoying interference from the Tower made it unusable at this location. This is just the last event in a long series ofinterference problems with virtually all ofour electronic devices. Another example is that cable is necessary to receive viewable TV. But even with cable, interference is significant. If the proposal to double the number oftransmitters on the tower is approved, then the resulting radiation effects - and thus interference -\\~1lpresumably be more than doubled. The radiation levels would be especially high because the new transmitters are to be lower on the tower and thus closer to the nearby homes. It is frightening to anticipate increased problems with our electronic devices from radiation hvice as high as current levels. The one electronic device for which we have not observed interference problems is the personal computer. However, I have a serious concern over how the proposed increased radiation levels and the presence ofa differently modulated signal would impact my PC's. In the late 20th century, it would be difficult for many people to lead productive lives\\~thoutreliable PC's. My home is very close to the foot of Sutro Tower. But our problems seem to be typical of people living in the general area. I have lived here for 34 years - before Sutro TO\ver was built. This is a great neighborhood, and I love living here. Please don't allow increased transmissions from the Tower to force me to move. Sincerely, Orij;in.al signed (jera (JS ofLl'in..iolt Gerald S. Levinson caples: J\1r. Steve Nahm, Pres. MTHOA .,/ r 79 Forest Knolls Drive San Francisco, CA 94131-1117 September 4, 1997 Paul Maltzer c/o San Francisco Planning Commission 1660 Mission Street, Sib floor San Francisco CA 94103 Dear Mr. Maltzer: I am writing to express my concerns about the proposal to install Digital Television (DTV) antermas onto Sutto Tower. I do not believe that the draft Environmental Impact Report addresses the issues of concern to residents living in the area and I want to share some of my concerns with you. As you know, expansion of Sutro Tower is a controversial issue and this controversy has a long history. In 1988, when the Tower wanted to expand its operations, the San Francisco Plarming Commission turned down the proposal on a unanimous vote because of the potential health hazards of electromagnetic signals that might cause additional radiation. This issue has never been resolved. I would like to point out that government smdies have not been able to establish criteria based upon medical evidence for "safe" radiation levels from this type of signal. In effect, the draft EIR findings are based upon suppositions and even the EIR admits that investigations into the potential biological effects of radiofrequency radiation (RFR) are not able to provide defmitive answers because "some of the mechanisms of interaction of RFR with various biological entities are not fully understood, and life processes are complex." In addition, the measuring devices used to determine levels of radiation at street level are crude at best. I have watched them drive through our area with the device pointed out a vehicle window. The measuring devices are not sensitive enough to read low levels. I would like the Planning Conunission to consider the following questions: 1. What has changed since 1988? At that time, the Plarming Commission came to a unanimous conclusion against Sutro Tower expansion due to concerns about health hazards 0 Studies of the impact of RFR do not take into consideration those persons who have moved out of the area and later developed serious health problems. 2. What assurances do residents have that the proposed expansion using an invened antenna which is lower and whose signals point directly beneath the tower will not produce RFR that adversely impacts people, dwellings, and the environment? If, at a later date I the transmission signals are determined to be the cause of health problems in the area, will the City of San Francisco and Sutro Tower be liable for damages caused-including the probable substantial reduction in property values in the area?? The EIR is written in a style reminiscent of tobacco industry reports over the years which gave us equally bold statements about the "safe" nature of tobacco products. 3. Historically, Sutro Tower has not been a good neighbor. Decisions are made without adequate notice or input from the community. They always do what they want and let us know after the fact-or they address concerns only after complaints reach a level that can no longer be ignored. For example: installation of strobe lights, sandblasting, painting, and construction. Sutro Tower does not even have a phone number answered by a human being; instead, there is a recorded message. In conclusion, I urge the Planning Commission to consider alternatives to expansion of Sutro Tower. Since the health questions raised in 1988 have not been satisfactorily answered, I endorse the idea of erring on the side of caution rather than needlessly exposing the neighborhood to hazards we can, at present, only guess at, Sincerely, ~~ City & QJunty of San Francisco Planning Commission Hilary E. Gitelman The Environmental Review Officer Planning Department 1660 Mission St., 5th Floor San Francisco, Ca. 94103-2U4 9/9/97. *** HAND DELIVERED *** Re: EIR on surRO TOWER 96.5hhE The Ehvironmental Impact Report as presented is FLAWED. It does not address - especially in detail - alternative sites such as those afforded at San Bruno facilities. Furthermore, it does not sufficiently analyze effects on Hmnans other radio technological usages Earthquake - seismic rift Water reservoir etc. The EIR purports to be complete yet lacks on so many fronts, it does not truly analyze the effect which can be of an extremely adverse condition, and its subsequent effects. Although in Appendix B action and re-action was alluded to yet DISCLAnlERS were deliberately included such as: "incomplete" and "based on present knowledge". I want to particularly (iraw your attention to page B-7l (7.1) 2nd paragraph ?. 11 ?? no studies ?.? vary_ing degrees of relevance" <:is well as "accurate information". The next paragraph states " ??? conflicting evidence" and end with the open ended 11 ??? future research". Inconsistencies are ripe such as pg. B-72 3rd paragraph re detrimental health effects lIhich could oeem- it there were suf'f'icient research. Particular concern is with sensitivity to modulation. It actually mentions ·LETERIOUS EFFECTS. other specific research was (if not deliberately) ignored. Consequences were not tully addressed with regard to all of the above concerns. It is not only the exposure of people and other living organisms (e.g. pets) but the geological hzards on the site. There was failure in the Em as presented to identify all potential problems. Impacts were diminished. Comparative studies 'were either ignored or sluffed over. Analysis of potential problems were flawed. It was implied that only Sutro Tower was eligible to support the pre-conceived conclusion. Hilary Gitelman - 2 - EIR on Sutro Tweer 9/9/97. The ErR as presented is limited and narrow. Failure to fully anaJ..yze all potentials renders this EIR useless. As an example: Photo pg. 3-32 as pertains to Sutro TOlfer is either smudged or, at least, impossible to draw a conclusion from whe:-ClaJJ the foreground is clear. Pg. 6-4 and. 6-S mentions DTV signals from San Bruno lfountain 'Would be able to serve all of San Francisco YET this was not followed through completely as a viable alternative. Whose conclusion on 6-S was it re " ?? not practicable to dE!Ilolish?? 1I It seems everything is based on the monetary incentive for the owners of Sutro Tower. Just vlhat would be so terrible to construct new towers at San Bruno except that the current owners of Sutro Tower lVOuld be monetarily impacted. This would res1.ut in monetary dimunit:ion and therefore is not being considered in this ElR commissioned by Sutro Tower ownership. Monetary considerations are also referred to on 6-2. Mitigation measures are NOT addressed except for a one (1) praragraph reference on 4-1 and that states tha.t no potentially significant effects have been identified. Why not? The neighbors seem to be able to identify numerous problems and concerns. There also seems to be some discrepancy with regard_ t..o the specific SITING of the DTV antennae. -I'e haVE! a three-legged structure wi.th very little differentiation between Fig. 6 &Fig. 7. As long as modifications to the Sutro Tower are asked for and applied for by the owners of this project, why then do they not agree to mitigate some of the problems encountered by the most i:mmediate neighbors such as the noise condition Pg. 3-36'1 This EIR as presented is a one-way street for the benefit of the crmership of Sutro Tower and request for expansion without giving due regard to problems enumerated on the previous page as well as the neighborhoods concerns. 3.ll Geology & Soils pg. 3-38. The Dames & Keore report is 30 thirty years old. Since then we have had a major 1989 earthquake. There is a fissure there and more extended and up-to-date informa tion is certainly indicated to be forthcoming. 1991 & 1995 studies in their entirety need to be made part of this EIR to be meaningful. Hilary Gitelman - 3 - EIR on Sutro Tower '/9/97. If CU (Conditional Use) is based on this ppoposed EIR then it is significantly lacking in full disclosure. I t is imperative that further information needs to be made part of the record so that it can be referred to kG" current and future residents of the neighborhood and other affected people and possessions. The questions and concerns of the neighbors need to be fully addressed and validated. The scope of the currently presented Em is liJnited. The interpretation is slanted in favor of the project snonsor and Data utilized seems to be selected on the basis of whether it helps or hurts the conclusions sought. Sincerely, Edith l4cl4illan 647 - 28th .lV'3nue San Francisco, Ca. 94121 cc: Planning Director Gerald Green Zoning Administrator Bob Passmore Neighborhood Organizations Ii "L_ '~'-7 " .;/. . ./~--C--..:..--_ / ..it: / ",....,...,,-...;.....:-....~-~-',/'" -~v.Ji~ ~".,!.---.:-:. .,-/'-r;,,~.. .............- .-'-":,..-- - -..,.-- ..,...::.-. .- ,(;:' -., 1'~-~7~<- -~-<.- , /,¢:. ~ j'/", .'--<,.--.u ..I- -. --... ......- _....,-~.--: --......c'..'"'t·'\..-~1 ~-~ .~/--;:.,k,"'-- ..-'(·<.-1 -~--.;-~~-:<..... / .....- ..:t,........"'.~/-""--"""'-'"' .....~--;';,.,j 7~>.- ';:. L......'~_<r:~ , . . _~:.,..<-';,::..."""_-c~....-..,-,-;.:...-....?.-;: .::-<: "';'~/"i-,,""((A."-f~ .-<:.::....,;6 -I..'-f-:t' ,4-- ..~,'~v I --- ; -//'- ..~.. /. '-- .~.- / - / / / ,.~- ... I_.'_-_~-.~ ~)f ...~~_./..:,.~-c..-......-v:"- I ./:-.:r.:_ i ?? -::-<~ , , _-I ? ./j I,I~/'-'~ ! Mr James P. Moran SP~t.rviewv.."at' Sr. franci'lCO, CA. P413l-122P 160 Palo Alto Ave. San Francisco. CA 94114 September 8, 1997 Hillary E. Gitelman Planning Dept, 1660 Mission St. San Francisco CA 94103-2414 Dear Ms. Gitelman: I live at 160 Palo Alto Avenue approximately one block from the base ofSutro Tower. I never received a copy ofthe Draft ofthe Environmental Impact Report for Sutro Tower Digital Television dated July 9, 1997 (96.544E). However, I procured a copy on my own and find it to be inadequate for the following reasons: [1] Sutro Tower is in non-compliance with major objectives ofthe San Francisco General Plan. [A] Objective 12 ofthe Residence Element calls for the provision of "a quality living environment." Living in the neighborhood ofSutro Tower and having to deal with the daily annoyances and inconvenience ofradio frequency interference with stereos, telephones, car alarms and garage door openers is not a quality living environment. I am a serious amateur musician and recording artist. I personally had to spend thousands ofdollars to create a copper-lined "Faraday Shield" around my music room to avoid the constant interference ofSutro Tower's RFI. All the non-shielded rooms in my house contain music amplifiers that are corrupted by RFI. Sutro Tower is aware ofthis and does nothing. Now we are expected to put up with more electromagnetic interference from additional digital antennae. You would think that intruding in a residential community as they have, they would show a greater desire to be good neighbors. [B] Objective 4, Policy 4 ofthe Environmental Protection Element calls for the promotion of "non-polluting" industry. Electromagnetic radiation is pollution. It is known to be toxic to humans. The effects ofcombined analog and digital electromagnetic radiation has not been verified as safe for humans and indeed has not been tested at all. The reassurances of safety provided by the owners ofSutro Tower in their self-serving EIR is belied by the very words oftheir technical consultants hired to provide the RFR health risk assessment found in Appendix B ofthe ElR. They state on page B-19 that "A few studies directly address populations near radio and TV towers, but none concerns signals from DTV transmitters..." Ifthe unknown effects ofcombined analog and digital transmission are safe, why then do the owners ofSutro Tower put forth the disclaimer that "it is not scientifically possible to guarantee that exposure to Radio Frequency Radiation at relatively low levels will not result in the appearance of harmful effects for many in the future." Are the citizens ofSan Francisco, particularly those that live in close proximity to Sutro Tower to be unwilling guinea pigs in testing the safety ofunproven and untested technology? No steps are being proposed for heath monitoring ofresidents who live in proximity to the Tower. Ifit turns out to be not so safe after all, what recourse will we have? [C] Objective 7, Policy 2 calls for the protection ofland from changes that make it unsafe or unsightly. [i] With respect to safety, the specter ofdisaster following the potential collapse ofSutro Tower due to an earthquake is increased considerably by its location in a residential neighborhood and its location next to 2 concrete reservoirs holding a total of45 million gallons ofwater. These reservoirs are not even mentioned in the EIR. There is no other transmission Tower ofthis magnitude in a residential area anywhere else in the entire United States. The entire concept ofa fall-zone in the event ofthe Tower's collapse has been ignored in the EIR. Plans for evacuation, emergency vehicle access, electrical fires, etc. are not mentioned in the EIR. [ii] With respect to safety: [a] none ofthe measurements performed in the EIR measured analog and digital transmission and are not valid. [b] none ofthe calculations take into account the additional radiation of the two additional fire and CHP antennae on Palo Alto Avenue. [c] It is virtually impossible to tell exactly where the measurements that appear were taken. The scale ofthe map makes accurate placement impossible and distances from the measured sites to the tower should have been provided. [d] It does not appear that any measurements were taken from the perimeter ofthe Palo Ave reservoir that abuts Sutro Towers property and represents a walking path regularly used by neighborhood residents. Considering that electromagnetic radiation falls offwith the square ofthe distance, cites particularly close to the Tower itselfwill receive the greatest radiation exposure. [iii] With respect to unsightliness, few ifany residents ofSan Francisco consider this orange-and-white-striped Eiffel Tower-sized monstrosity as anything but unsightly. It is a blight to our world-famous city skylines and an abhorrently ugly reminder ofour dependence on soon-to-be-outdated TV technology. [2] The EIR fails to adequately consider an alternative site on Mount San Bruno. Sutro Tower is a monstrosity foisted upon the citizens ofSan Francisco almost 30 years ago to satisfy the needs ofan analog TV technology which is about to run its course and be replaced by Digital television (DTV). As the existing non-residential TV transmission site on Mount San Bruno is perfectly capable ofproviding DTV coverage for San Francisco, there is no reason to expand the facility on Mount Sutro. After the nine years anticipated by the FCC for the changeover from analog to digital TV, there would be no need for maintaining this public health hazard and eyesore in a residential neighborhood ofSan Francisco. I feel that an amended EIR needs to be prepared, circulated, and made available for public comment. I think it is obvious to all that were Sutro Tower to be proposed today, it would be found completely unacceptable to the residents ofthe city ofSan Francisco. There is no reason to allow the self-serving interests ofa few TV Tower owners to overwhelm the interests ofthe rest ofthe City. We should be planning for the phased removal ofSutro Tower, not its expansion. Very truly yours, Robert D. Nachtigall, M.D. Stephen X. Nahm 282 Dellbrook Avenue San Francisco, California 94131 August 3, 1997 Hillary E. Gite1man The Environmental Review Officer Planning Department 1660 Mission Street, 5th floor San Francisco, CA 94103 Dear Ms. Gitelman: I am writing in reference to the Draft Environmental Impact Report (EIR) for Sutro Tower Digital Television (96.544E, July 9, 1997). The Draft EIR is deficient in several areas. I request that the final EIR contained detailed responses to the issues which I raise below. Impacts not addressed by the Draft EIR Several potential impacts of the proposed project have not been discussed at all in the Draft EIR. 1. Psychological impact of proposed project I have resided for thirteen years in the Midtown Terrace community which is directly adjacent to Sutro Tower, and am now President of the neighborhood's homeowners association, Midtown Terrace Homeowners Association. During this time I have come to understand personally and through neighbors' comments the psychological stress caused by having Sutro Tower immediately adjacent to their homes. Most homeowners understand that scientific evidence cannot rule out potential harm of the high levels of Radio Frequency Radiation (RFR) generated by Sutro Tower. Does RFR harm their children? Does RFR harm themselves? Living under Sutro Tower, in some cases for 24 hours a day, seven days a week, might result in a cumulative harmful effect from the tower's RFR. Statements in the draft EIR support this concern. None of the studies listed in Appendix B address health impacts of chronic, continuous RFR exposure at the levels generated by Sutro Tower over the period which the tower has been in service, 24 years. Comments given throughout Section 3.1.4 ofthe draft EIR state that, "The substantial weight ofreliable scientific evidence is that because the project would be at a maximum of about 14.3 percent of the federal standards at the closest sensitive receptor, it is unlikely to cause such effects in the general population." (Quote is taken from the end of the second paragraph on page 3-22, however similar statements are found throughout this section.) This statement does not say that scientific evidence is that Sutro Tower's proposed RFR is safe, nor does it say that the various health-related impacts are certain to not occur to residents exposed continuously to its RFR. The result of these unknowns is a level of stress in the residents ofMidtown Terrace and adjoining communities. This has been made evident to me, as President of the Midtown Terrace Homeowners Association, through past events. Our Association has sponsored informational events in the past to discuss issues surrounding Sutro Tower (specifically sandblasting and painting which was performed there). These events are consistently the most well attended meetings that our organization sponsors. The residents who attend these meetings often express concern and frustration about the effects the tower is having on them. - I - Psychological stress can be assessed and characterized through a population study of the residents of the neighborhood. The addition of DTV to Sutro Tower can reasonably be expected to add to this stress (it will certainly not decrease the stress). The draft EIR does not address in any respect the psychological stress which has been caused by the tower in the past, and will be exacerbated by the proposed project. Therefore, I request that the final EIR include a detailed study of the psychological stress of the residents within one mile of Sutro Tower. 2. Impact ofSutro Tower on values of homes in surrounding communities Midtown Terrace consists of 820 homes on the west side of Twin Peaks. Homes are a mixture of three bedroom and two baths plus two bedrooms and one bath structures. Typical sales prices for 2 bedroom homes is $250,000 to $275,000. For 3 bedroom houses, sales prices range from $275,000 to $325,000. These prices are considerably below equivalent housing prices in San Francisco for equivalent residences. Some of this decrease in home value may be the result of the concern of potential buyers for the possible impacts from Sutro Tower. Buyers who fear harmful effects from Sutro Tower will refuse to consider this neighborhood for purchasing a house, forcing potential sellers to reduce their prices. The draft EIR does not address this impact in any way, nor does it consider the potential additional impact on home values that the proposed DTV project will have. Given the number of homes in the area, this impact could be considerable. Therefore, I request that the final EIR include an analysis of the values of homes in Midtown Terrace prior to the construction of Sutro Tower, comparing these values to comparable homes in San Francisco during the same period; and an analysis of the values ofMidtown Terrace homes after Sutro Tower was constructed to the present period, again comparing to comparable houses in San Francisco. This study should project the additional impact which the DTV project could have on home values in this neighborhood. I further recommend that the study be expanded beyond Midtown Terrace to all homes within one mile of Sutro Tower. 3. Partition of project is contrary to California Environmental Quality Act (CEQA) The draft EIR does not address the partition of the proposed project, in a manner which is contrary to CEQA. On page 3-38 is stated, "The tower legs, haunch diagonals, and diagonals are being reinforced to bring the tower structure into compliance with current codes." (My emphasis) Presumably this is in reference to Planning Department Case Number 97.357D, a project proposed by Sutro Tower to perform "structural upgrades" to the tower. As of the date of the issuance of the draft EIR (July 9, 1997), no permit was issued for this work, so the statement that the various tower structures "are being reinforced" is not true. Additionally, CEQA requires that all relevant projects related to a proposed change be submitted as a unit, and not divided into subprojects. An EIR must cover all portions ofthe total project. The final EIR must address whether the structural upgrades described in Case 97.357D are actually part of the DTV project (Case 96.544E); that is, could the DTV project proceed with none of the upgrades proposed for Case 97.357D? Ifthe structural upgrades are required for the completion ofthe DTV project, the two projects must be withdrawn by Sutro Tower, Inc., and a new project proposed which includes the structural work. The new EIR for the combined project must then include details ofthe structural upgrades and the environmental impacts they will cause. - 2 - 4. Impacts from foreseeable future activities The draft EIR does not address possible impacts from foreseeable future activities which will result from the proposed project. A complete EIR must include all potential environmental impacts. a. Paint and paint-laden sand outfall from tower maintenance The addition of a 125-foot beam to Sutro Tower will result in the requirement for periodic maintenance. In the past, Sutro Tower has been sandblasted and painted to maintain its structural integrity. This work has resulted in paint-embedded sand falling on the houses surrounding the tower, as well as orange and white paint. Residents have expressed to me their concern of the possible toxic properties of this residue which has fallen on their homes. The new beam will add to the maintenance requirement. The draft EIR does not discuss the magnitude of additional future maintenance work; nor does it discuss the toxic properties of this intrusive fallout from the maintenance work on residents; nor does it discuss the health impacts of the sand and paint which will again fall on surrounding residences during future maintenance work. The EIR must answer each ofthese points and describe how this outfall can be entirely halted in future maintenance work. b. Noise The draft EIR discusses Noise impact of the project in section 3.7. However, the noise discussed is only the noise which will be generated during construction. The presence ofthe tower causes an ongoing low frequency hum during periods of moderate to high wind. This noise has been noticed and mentioned to me by area residents on several occasions, and causes residents a significant degree ofannoyance. The draft EIR does not measure or study the existing tower wind noise in any respect, nor does it analyze noise which may be generated by the proposed DTV structure. The EIR must discuss how the addition of a 125-foot beam will modify tower noise, what steps can be taken to mitigate this noise, and the psychological impact of tower noise on adjacent residents. c. Dropped tools and other objects The only object which I am currently aware has fallen from the tower is a large metallic strut cover. The addition of a new beam will present additional opportunities for objects and tools to fall from the 762-foot Level 6 and the 657-foot Level 5. Any object falling from these heights could cause considerable harm to property and person. Homes surround the tower, presenting a high probability that any falling object could cause injury. The EIR must discuss how existing procedures and maintenance seek to ensure that all tools and other tower objects are prevented from falling, how the addition of the DTV beam will affect these procedures, and the possible impact of any falling object including the distance from the tower that an object might fall and the force of any object that might fall could have on a person or house. d. Condensation Sutro Tower is often surrounded by coastal fog. The addition of a DTV support beam will result in additional fog condensation on the tower. The EIR must discuss the additional amount of condensation which will occur, and the potential outfall of this condensation on surrounding homes. - 3 - 5. Paint scheme of proposed beam The draft EIR does not discuss the paint scheme of the proposed DTV beam. The existing tower is painted alternating colors oforange and white according to FAA rules which were applicable prior to the recent addition of strobe lights to the tower. The draft EIR does not describe whether this orange/white scheme is still required despite the presence ofdaytime strobe lights. Ifnot, the visual impact of the tower could be considerably reduced by painting it a neutral color such as gray or white. The DTV beam's visual impact in particular could be reduced in this manner. The EIR must describe whether the orange/white paint scheme continues to be required by the FAA despite the daytime strobe lights on the tower, and if not, how the project can reduce the visual impact ofthe DTV beam and the tower itself by adopting a unobtrusive paint scheme. This section should include a discussion of how the tower could be repainted without the outfall impacts discussed above. 6. No discussion of the nature of digital modulation Section 1.2 on page B-7 of Appendix B explains digital TV modulation from a descriptive standpoint. However, none of the studies cited in Appendix B examine DTV modulation. This section does not discuss how the different modulation used by DTV affects the relevance of the cited studies. Does DTV's unique modulation render these studies inapplicable? Are there effects possible because of DTV's unique modulation that are not represented in any study cited? Digital signals often result in high-order harmonics in a broadcasted signal; what additional filtering must be used to ensure these parasitic signals are eliminated? On page B-8, the statements made that "DTV signals are distinct from all signal types used in health-related research." Does this render the ANSI and FCC Guidelines irrelevant, since they are developed from health-related research? How can any safe RFR exposure limits be adequately calculated for DTV modulation? 7. Draft EIR not available through electronic media For the extremely short review period allowed for this draft EIR (originally 30-days, but extended to 60-days), the vast amount of information presented is difficult to process through printed material. Given the growing popularity of web pages and accessibility of these to the general population at public libraries, the EIR should be published in its entirety on an Internet web page. This will allow more effective and efficient review of EIR material. 8. No allowance for RFR "hot spots" Appendix A presents a computational model of Sutro Tower radiation based on just six randomly placed measurements within 1/2 mile of the tower (plus four other measurements further away). Electromagnetic broadcasts from antennas are not uniform. Signals are greater or lesser at various positions surrounding the antenna, as a function of the antenna design and the nature of the signal. Just as two waves in the ocean can combine to form a "super" wave, certain radio "hot spots" can result from antenna broadcasts. This issue is not discussed in Appendix A. Hot spots are unlikely to be detected with six randomly placed measurements. Only a more comprehensive study based on a regular pattern of measurements and taking into account the signal patterns of the antennas can uncover such hot spots. RFR hot spots have the potential for greatly exceeding the FCC Guidelines, and can occur in the areas surrounding Sutro Tower. -4- 9. No discussion of the reduced need for high-elevation antennas with DTV The draft EIR does not describe the characteristics of DTV which would reduce the need for high elevation antennas such as are proposed by this project. DTV includes various technologies, such as error correction and adaptive receiver gain which reduces the need for high level antennas. The EIR should explain how DTV is compatible with antennas which are of lesser height, and describe in detail the height needed to achieve coverage which is comparable to existing NSTC broadcasts. This discussion should also consider the ability to locate antennas at a more remote site, such as San Bruno Mountain. Additional alternative sites should be discussed which are compatible with this reduced height requirement. 10. No discussion of the potential for multiple broadcast sites DTV includes technology which reduces the effect ofmultiple path signals, which causes ghosting and other reception problems in NSTC TV. These technologies would allow multiple lower-power broadcast sites to serve a metropolitan area. The EIR must describe how DTV signals would allow the use of multiple broadcast sites in place of a single centrally located high elevation site such as Sutro Tower, and present additional alternative sites which are allowed by this. Deficiencies of the Draft EIR 1. Clarendon School not shown on project maps The maps on pages 2-4 and 3-8 show considerable detail, however they do not show the existence and location of Clarendon School. It is essential that this facility be shown in all project maps to assist policy makers in evaluating the project with respect to a location where children congregate for extended periods during the year. The EIR must include a depiction of Clarendon School on all project maps. 2. In adequate display of graphic data Figures 2A, 2B, 3A and 3B in Appendix A (Section 8) purport to show differing levels of RFR radiation on areas surrounding Sutro Tower based on the computer model used by Hammett & Edison. The greyscale rendition of these tables is entirely inadequate to show the data being presented. A reviewer must expend considerable effort to distinguish the subtle shades ofgreyscale displayed by these figures. This defeats the intent of the figures, which is to present information in a manner that can be readily grasped by reviewers, and in fact may contribute to the radiation differences being hidden. This information can be presented better in color, which would immediately catch the attention of a reviewer where changes in color are shown. The EIR should display these figures in color. 3. No description of DTV support beam weight The project description does not describe the weight of the proposed DTV beam. Nor does this section describe whether Sutro Tower as it stood on the date of publication of the draft EIR was capable of supporting this weight. Nor does it describe the procedures which will be used to elevate the three segments to Level 6, and the additional temporary weight which the tower will be required to support during construction. Each of these could substantially impact the environment if the project exceeds allowable weights and the DTV beam structure falls due to a catastrophic failure. The EIR should present the weight impacts of the DTV beam and the steps which will be taken to ensure that the beam will not cause a catastrophic failure of Sutro Tower. - 5 - 4. No description of DTV beam attachment to Sutro Tower The project description does not describe how the DTV beam would be attached to Sutro Tower, nor how this attachment will be adequate for surviving an earthquake of 8.3 magnitude (used as a reference level for strengthening road structures in the Bay Area). Should the DTV beam fail to remain attached to Sutro Tower during such an earthquake, or should Sutro Tower itself fail during such an earthquake as a result of the attachment of the DTV beam, the impacts on the surrounding areas will be considerable. The EIR must discuss these issues, the impact on the DTV beam of a 8.3 magnitude earthquake, and the possible impact on the surrounding area of a possible collapse of Sutro Tower or the DTV beam during such an earthquake. 5. No discussion of low-level, chronic RFR exposure Each of the studies cited in Section 3 and Appendix B (Section 8) study occupational RFR exposure, or short-term, high-level exposure of RFR to animals and humans. The residents surrounding Sutro Tower are exposed to low-level, continuous RFR. No studies examine this type of RFR exposure. Sutro Tower has been broadcasting for 24 years with considerable levels ofRFR for nearby residents. Are RFR effects cumulative? Temperature elevations which, on an instantaneous basis, may be negligible could be significant when taken cumulatively over decades. How will the addition of DTV signals add to this RFR burden? 6. No discussion of RFR impact on dental appliances Neither Section 3 nor Appendix B discuss RFR effects on metallic dental appliances. Such appliances, which could include fillings, braces, prosthetic teeth, and dentures, could be directly affected by RFR to a degree in excess of normal body exposure. In turn, such appliances could act as re-radiators of RFR, capturing radio energy and reradiating it to the body. These effects should be discussed in the EIR. 7. Obscure language Throughout Section 3, the draft EIR refers to "sensitive receptors." Exactly what is being referred to by this phrase? I assume that this refers to residents and children of Clarendon School which might absorb RFR. If this is the case, the EIR must be modified to clearly state the subjects being referred to by the "sensitive receptors" euphemism. I recommend that the EIR instead use the phrase "community residents and children of Clarendon School." 8. Misleading phrasing Throughout Section 3.1.4, the following phrase is use with minor variations: "The substantial weight of reliable scientific evidence is that because the project would be at a maximum of about 14.3 percent of the federal standards at the closest sensitive receptor, it is unlikely to cause such effects in the general popUlation." This phrase appears with variations related to the topic being discussed on pages 3-17, 3-18 (twice), 3-19, 3-20, 3-21 (twice), 3-22, 3-23 (twice) and 3-24. Given the frequency with which this phrase is used, it is important that it be informative, accurate and representative of the facts. However, the phrase is misleading as stated. As stated previously, this statement does not say that the scientific evidence is that Sutro Tower's proposed RFR is safe, nor does it say that the various health-related impacts are certain to not occur to residents exposed continuously to its RFR. A more accurate and balanced statement should be used in place of this phrasing. I recommend that the following phrasing be used: "There is no definite scientific - 6 - evidence that [the effect] does or does not occur given the RFR levels proposed by this project as a result of continuous exposure by nearby residents." 9. No listing of required actions Section 4 mentions, but does not list, the mitigation measures required by law. This section should list all action required by law under FCC 96 Guidelines, FCC and Cal/OSHA limits for public and personnel exposure to RFR, and Cal/OSHA worker safety regulations. Other mitigation measures should also be listed, including any possible protection of nearby residents from tower outfalls (objects, paint, sandblasting) and RFR. 10. DTV RFR interference with electronic devices On page 3-37, the last sentence of the second paragraph states that "the existing interference would not be expected to change with addition of the DTV broadcasts." First, no explicit characterization of this interference is given. I have also received complaints from residents about interference to various devices due to RFR from Sutro Tower. Such interference is a major environmental impact of Sutro Tower and should receive substantial attention in the EIR. The single paragraph given to this matter is entirely inadequate. This interference must be characterized and the addition ofDTV RFR analyzed for additional effect. Second, no substantiation of any kind is given for the quoted statement other than a comment that DTV modulation is different from NSTC and FM RFR. No explanation is given why modulation technology matters in this sort of interference. At a minimum, a study of area residents experiencing interference should be conducted which characterizes the existing interference and models how the addition of DTV RFR will change this interference. 11. Calculation methodology is not representative of chronic exposure Section 1.1 of Appendix B provides detail of the methodology used for calculating RFR exposure. The ANSI standard, upon which the FCC Guidelines are based, requires a six-minute averaging period for RFR exposure measurements. This measurement may be appropriate for occupational exposure, however the residents surrounding Sutro Tower are exposed to its RFR continuously, in some cases 24 hours a day and seven days a week. Is the averaging methodology appropriate for chronic exposure such as this? Should a shorter interval be used (such as one second or less)? 12. Calculation is not given for infants The SAR models described in Section 2.1 of Appendix B (pages B-9 and B-lO) are relevant to adults and 5-year old children, however a model is not given for infants. What is the resonant absorption characteristics of an infant body? Various arbitrary safety factors are reported for the ANSI and FCC standards in Section 1.1 of Appendix B (a factor of lOin one case and a factor of 5 in another, both stated on page B-2). Are these safety factors appropriate for infant under continuous exposure to Sutro Tower RFR? Are they appropriate for children attending Clarendon School for significant portions of the day? 13. Ocular studies are not representative of chronic exposure The studies cited in Section 3.3 of Appendix B do not address the type ofexposure that occurs with the residents surrounding Sutro Tower. No residential or chronic, continuous exposure studies are cited. What is nature of ocular RFR related impact under chronic, continuous exposure? - 7 - Deficiencies of the Draft EIR in Relation to the Offsite Alternatives 1. No analysis of the differences in environmental impact of Offsite Alternatives On page 6-1, the draft EIR states, "the project would not result in any significant environmental effects. Thus, no alternatives were formulated regarding significant effects." This result renders the draft EIR entirely inadequate. The primary environmental element surrounding Sutro Tower is the people of Midtown Terrace and the surrounding communities. Even the draft EIR cites environmental impact on page 3-37 with regard to interference with electronic devices. I have previously discussed the psychological impact on the nearby residents caused by the presence of Sutro Tower. These are real impacts that must be recognized. The offsite alternatives would have no impacts on residents surrou