(Continuation of US Dept. of the Interior 2/14/14 letter to National Telecommunications and Information Administration) <br />Enclosure A <br /> <br />Background <br />The placement and operation of communication towers, including un-guyed, unlit, monopole or <br />lattice-designed structures.Jrppact;protected ..migratory birds in two. significant ways. <br />The first is by injury, crippling loss, and death from collisions with towers and their supporting <br />guy-wire infrastructure, where present. Mass mortality events tend to occur during.periods of <br />peak spring and fall songbird bird migration when inclement weather events coincide with <br />migration, and frequently where lights (either on the towers and/or on adjacent outbuildings) are <br />also present. This situation has been well documented in the U.S. since 1948 in the published <br />literature (Aronoff 1949, see Manville 2007a for a critique). The tallest communication towers <br />tend to be the most problematic (Gehring et al. 2011). However, mid-range (-400-ft) towers as <br />proposed by the First Responder Network Authority (FirstNet, a newly created entity under the <br />Department of Commerce) can also significantly impact protected migratory birds, as can un- <br />guyed and unlit lattice and monopole towers (Gehring el al. 2009, Manville 2007x, 2009, 2013x). <br />Mass mortalities (more than several hundred birds per night) at unguyed, unlit monopole and <br />lattice towers were documented in fall 2005 and 2011 in the Northeast and North Central U.S. <br />(e.g., Manville 2007a). It has been argued that communication towers including "short" towers <br />do not impact migratory birds, including at the population level (e.g., Arnold and Zink. 2011), but <br />recent findings have contradicted that assertion (Manville 2007a, 2013a, Longcore el al. 2012, <br />2013). <br /> <br />The second significant issue associated with communication towers involves impacts from non <br />.iontatrig electromagnetic radiation emitted by these structures.' Radiation studies at cellular <br />=communication towers were begun circa 2000 in Fill Ohe and continue today on wild nesting. <br />dbirds. Study results have d0enmented nest and sits ab. ndunment,.plumage deterioration,` <br />Aocomotion problems, redncc(l survivorship;,and d~ iili (e.g.,Balmori 20Ox_ Balmori_and <br />'Hallberg 2007, and'Fveraert and Bauwens 2007). Nesting migratory bir& <ind their offspring <br />have apparently been affected by the radiation from cellular:phone toy. crs in the 900 and 1800. <br />'MHz frequency ranges 91;5 MHz is the standard cellular phone frequency used in the United <br />-States. However, the electromagnetic radiation standards used by the Federal Communications <br />Commission (FCC) continue to be based on thermal heating, a criterion now nearly: 30 years out <br />of date and inapplicable today. This is primarily due`.to the lower levels of radiation output from <br />microwave-powered communication devices such as cellular telephones and other sources of _ <br />point-to-point communications; levels typically lower. than: from microwave ovens'. "The <br />problem, however, appears it) IOcuti on very lore levels of non'-ionizing, electromagnetic: <br />radiation. For`example , in l,ihor~itory studies, T. Litovitz (personal communication) a6d`DiCarl0 <br />et a1L (20,02) raised concenis about impacts of low-level, non-thermal ' electroma~nctxradiation <br />from-the st~mdard 915 MHz cell phone frequency on domestic chicken ernbi, w v idi some <br />leihal rc,ults (Manville 2009,2013a). Radiationatextremelyxlow: levels (0.001 rttz level <br />emitted !by the arcra«~ di,: ital cellular telephone) caused heart attacks and the deaths of some <br />chicken embryos subjected to hypoxic conditions in the'labor.ttorv while controls subjected to <br />hypoxic were unaffected (DiCarlo el al. 2002). To date, no independent, third-part y field studies. <br />,have been conducted in North America on impacts of tower electromagnetic radiation on <br />migratory birds. With theLuropean field and U.S. laboratory evidence already available,' <br />