independcni, third-party peer-re% sewed studies need to be conducted in the U.S. to begirt: <br />examing:the.:effects from radiation on migratory birds; and other trust species,: <br />Discussion <br />Collision Deaths and Categorical Exclusions <br />Attempts to. estimate bird-collision mortality at communication towers in the U.S. resulted in <br />figures of 4-5 million bird deaths per year (Manville 2005, 2009). A meta-review of the <br />published literature now suggests, based on statistically determined parameters, that mortality <br />may be 6.8 million birds per year in Canada and the U.S.; the vast majority in the United States <br />(Longcore et al. 2012). Up to 350 species of birds have been killed at communication towers <br />(Manville 2007a, 2009). The Service's Division of Migratory Bird Management has updated its <br />voluntary, 2000 communication tower guidelines to reflect some of the more recent research <br />findings ('Manville 2013b). However, the level of estimated mortality alone suggests at a <br />minimum that FirstNet prepare an environmental assessment to estimate and assess the <br />cumulative effects of tower mortality to protected migratory birds. <br />A second meta-review of the published mortality data from scientific studies conducted in the <br />U.S. and Canada (Lon-core et al. 2013) strongly correlates population effects to at least 13 <br />species of Birds of Conservation Concern (BCC, USFWS 2008). These are mortalities to BCC <br />species based solely on documented collisions with communication towers in the U.S. and <br />Canada, ranging from estimated annual levels of mortality of 1 to 9% of their estimated total <br />population. Among these where mortality at communication towers was estimated at over 2%0 <br />annually are the Yellow Rail, Swainson's Warbler, Pied-billed Grebe, Bav-breasted Warbler, <br />Golden-winged Warbler, Prairie Warbler, and Ovenbird. Longcore et al. (2013) emphasized that <br />avian mortality associated with anthropogenic sources is almost always reported in the <br />aggregate, i.e_, "number of birds killed," which cannot detect species-level effects necessary to <br />make effective and meaningful conservation assessments, including determining cumulative <br />effects. These new findings strongly suggest the need for at least an environmental assessment <br />by FirstNet, or more likely, an environmental impact statement. <br />:Radiation Impacts and Categorical L:xclusion.s <br />.There is a growing level of anecdotal eviden c linking effects of non therm al. non-ionizing <br />,electromagnetic radiation from communication ioNvers on nesting and roosting wild birds.and <br />other wildlife in the U.S. Independent, third-p; -tv studies have yet to be=conducted i:n t1ie:.U.S. or <br />Canada, altfiw.igh a_peer-reviewed researc li pr()t,)cul developed for the U.S. Forest Service by the <br />Service's Division of Migratory Bird 'Management is available to study both collision and <br />radiation impacts (Manville 2002). <br />As previously`mentioned, Ral'm`6ri (2005) found strong negat~ v'e correlations Between levels of <br />1uwei-emitted microwave radiation and bird breeding, nesting, and, ~roosting. inAhe vicinity,.,of. <br />elccuoinagnetic fik4ds in Spain. "He documented nest and site abandonment, plumage <br />deterioration, locomotion problems, reduced survivorship, and death. in House Sparrows; White <br />Storks, Rock Doves, Magpies, Collared Doves, and other species. Though thewspecies had <br />historically been documented to roost and nest in these areas,'Balmori (2005) did not.observe. <br />-these symptoms prior to c.onstructi`on and operation of the cellular phone"towers__ Balmon and <br />Hallberg (2007) and'Everaert and Bauwens (20Q7,)µfound.-siniilar strong negative correlations: <br />