Tuesday, 10 August 2010


Dear Mr. Martin:
I write in reference to the Federal Communication Commission's vote on the authorization of
new unlicensed "White Spaces" devices for wireless communications in the TV Broadcast
Bands, scheduled for its November 4th meeting. FCC adoption of rules to authorize use of White
Spaces spectrum for wireless devices operating in the home will lead to the repeated, chronic,
long-term exposure of individuals, at all age levels, and to more frequencies and quantities of
radiofrequency (RF) radiation at very close range than is currently the case. Whether these
exposures pose human health risks is under investigation by members of the scientific and public
health research communities. I am writing to remind FCC to consider the potential for serious
human health effects that could result from the proliferation of these devices in the home, before
allowing the proliferation of such devices.
By design, the White Spaces devices rule will increase the bandwidth available for wireless
devices operating at close range, for general use in the home and elsewhere. As a result, it is
expected that the number of transmitters in the broadcast frequency range will increase
exponentially with the roll out of White Spaces devices and infrastructure. The Commission has
classified unlicensed broadband White Spaces devices to be used in the TV bands into two
general functional categories. The first category consists of lower power "personal/ portable"
unlicensed devices, such as Wi-Fi cards in laptop computers or wireless in-home local area
networks (LANs). The second category consists of higher power "fixed/access" unlicensed
devices that are generally operated from a fixed location and may be used to provide a
commercial service such as wireless broadband Internet access. Whereas high-powered analog
broadcast transmitter sites have traditionally been found at locations somewhat removed from
business centers and residential neighborhoods, the new White Spaces devices that will also
transmit in the digital broadcast frequencies are designed to operate at close range to members of
Mr. Kevin J. Martin
November 3,2008
the public who choose to use them as well as to their colleagues and neighbors who may choose
not to use them.
This proliferation of RF exposure follows the September 25,2008 hearing before the
Domestic Policy Subcommittee of the Oversight and Government Reform Committee on
"Tumors and Cell Phone Use-'What the Science Says," at which witnesses raised serious
concems about the potential public health implications of RF exposures through cell phones.
Some specific concerns were raised about FCC RF radiation exposure limits. Namely, they may
not be adequate to protect humans from adverse biological effects; may not provide protection
from long-term exposure; are only based on tissue heating reactions on a non-representative
sample of the total population (a six-feet tall male); do not address the current state of scientif,rc
research establishing non-thermal biological effects; and do not err on the side of precaution.
While RF exposures from cell phones are different than the RF exposures that will be
generated through the White Spaces auction, there is much that is unknown about the health
effects of these exposures that corresponds with concerns raised in the hearing. In its 2005 Fact
Sheet entitled, "Studies on Radiofrequency Radiation Emitted by Cellular Phones," the National
Toxicology Program (NTP) at the National Institute of Environmental Health Sciences states:
Over 100 million Americans curuently use wireless communication devices with over 50
thousand new users daily. This translates into a potentially significant public health
problem should the use ofthese devices even slightly increase the risk ofadverse health
effects. Cellular phones and other wireless communication devices are required to meet
the radiofrequency radiation (RFR) exposure guidelines of the Federal Communications
Commission (FCC, August 1996). The existing exposure guidelines are based on
protectionfrom acute injuryfrom thermal fficts of RFR exposure. Cunent datq are
insfficient to draw definitive conclusions concerning the adequacy of these guidelines to
be protective against any non-thermal fficts of chronic exposures.
In January 2008 the National Academy of Sciences (NAS) issued a report entitled:
Identification of Research Needs Relating to Potential Biological or Adverse Health Effects of
Wireless Communication Devices. The following excerpts from the NAS Report support the
NTP's conclusion that the research record upon which FCC's RF Safety Guidelines are based
does not adequately safeguard the public from non-thermal chronic exposures:
Research Needs
l. There is a need to characterize exposure ofjuveniles, children, pregnant women,
andfetuses, bothfor personal wireless devices (e.g., cell phones, wireless
personal computers, tPcsl) and for RF fields from base station antennqs
including gradients and variability of exposures, the environment in which
devices are used, and exposures from other sources, multilateral exposures, and
multiple frequencies.
Mr. Kevin J. Martin
November 3, 2008
Page 3
2. Wireless networlcs are being built very rapidly, and many more base station
antennas are being installed. A crucial research need is to characterize radiated
electromagnetic fields for typical multiple-element bqse station antennas andfor
the highest radiated power conditions with measurements conducted during peak
hours of the day at locations close to the antennas as well as at ground level . . .
3. The use of evolving types of antennas for hand-held cell phones and text
messaging devices need to be characterizedfor the Specffic Absorption Rates
(SARÐ that they deliver to dffirent parts of the body so that this data is available
for use infuture epidemiologic studies.
4. RF exposure of the operational personnel close to multi-element newer base
station antennas is unlcnown and could be high, These exposures need to be
characterized. Also needed are dosimetric absorbed power calculations using
realistic anatomic models for both men and women of dffirent heights.
Most of the reported studies to date have involved one base station antenna and
have used mostly homogeneous models, often of simplified circular or rectangular
cross sections of the exposed human . . . In other words, the studies to date do not
pertain to the commonly used multiple-element base station radiators. Also,
unlike highly localized cell phone RF energt deposition, the base station
exposures involve much, if not all, of the body and would have slightly dffirent
radiator origins (for multiple-element base stqtions) and may be multi-frequency
as well, particularly if several dffirent-frequency base stcttion antennas are colocated.
Furthermore, because of the whole-body resonance phenomenon, the
SIR is likely to be higher for shorter individuals due to the closeness of the
fr e quency/fr e qu enc i e s of exp o s ur e t o the w hol e -b o dy r e s onanc e fr e que ncy.
FCC has committed detailed and thorough analysis of what this White Spaces technology
might do to cause interference with other commercial uses. I call upon the Commission to match
its concern for commercial interests with concern for human health of the future consumers of
this technology. To that end, I hereby request that the Commission stay its November 4,2008
vote pertaining to "White Spaces" devices. In the interim, I urge you to immediately take
appropriate agency action to consider what RF human exposure guidelines FCC should set to
protect the health and safety of the American public before authorizing this technology to be
licensed or deployed. I also request that the Commission provide my Subcommittee with a
detailed description of the measures FCC has taken to date to ensure public health will not be
jeopardized by the auctioning of the White Spaces spectrum, given the scientific concerns and
unknowns about RF exposure and the proliferation of new RF exposures that will result.
Mr. Kevin J. Martin
November 3, 2008
Page 4
The Oversight and Government Reform Committee is the principal oversight committee in
the House of Representatives and has broad oversight jurisdiction as set forth in House Rule X.
An attachment to this letter provides information on how to respond to the Subcommittee's
request. W'e request that you provide these documents as soon as possible, but in no case later
than 5:00 p.m. on Monday, November 17,2008.
If you have any questions regarding this request, please contact Jaron Bourke, Staff Director,
at (202) 225-6427.
ù,u^;- ù,\ü^-;cL Dennis J. Kucinich
Domestic Policy Subcommittee

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