On 8/10/2022, a paper was sent home with some children at Oak Creek School giving notice that a cellular antenna was going to be placed on school grounds on a light pole at the baseball field. On that announcement there were a few items needing more clarity. This document serves to seek clarity on what is being presented to parents that it is factually correct and leads to genuine transparency and correct parental understanding. As stated on the notice OCS has "an OBLIGATION to exercise out DUE DILLIGENCE to ensure safety and security of our students and staff.” Due diligence is defined legally as a process of acquiring objective and reliable information, prior to a specific event or decision. It is usually a systematic research effort, which is used to gather the critical facts and descriptive information which are most relevant to the making of an informed decision on a matter of importance. The OCS Child Safety Group seeks to ensure the publicly admitted responsibility for due diligence was adhered to.

 

        The first and most important area of OCS responsibility and due diligence is regarding the children’s health and safety so we will start there. On the notice sent to parents OCS states they have weighed the scientific evidence from the American Cancer Society, presumably on cell tower safety on an elementary school campus with children ranging from 3 to14 years of age. This is a direct link to the American Cancer society website as was given on this notice: https://www.cancer.org/healthy/cancer-causes/radiation-exposure/cellular-phone-towers.html.

 

        The OCS Child Safety Group has reviewed the information given on this link and will quote directly from it. The first and most concerning realization noted in this link is that the American Cancer Society has never conducted a single study on cell tower safety or the safety of developing children experiencing long term exposure to cell tower radiation. In fact, the website states “The American Cancer Society does not have any official position of statement on whether or not radiofrequency (RF) radiation from cell phones, cell phone towers, or other sources is a cause of cancer.” It is unclear to the OCS Child Safety Group exactly what scientific evidence from the American Cancer Society the school board weighed in their due diligence as the American Cancer Society has never performed a single study.

 

Here is what the link to the American Cancer Society website does say:

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- “At this time there is no strong evidence that exposure to RF waves from cell towers causes any noticeable health effects. However, this does not mean that the RF waves from cell phone towers have been proven to be absolutely safe. Most expert organizations agree more research is needed to help clarify this, especially for any long term-effects.”

 

- “Based on a review of studies published up until 2011, the International Agency for Research on Cancer (IARC) has classified RF radiation as “Possibly carcinogenic to humans’” On the IARC’s website you can see a list of all other exposures categorized as possibly carcinogenic to humans: https://monographs.iarc.who.int/list-of-classifications.

Included in the same category as RF exposure from a cell tower is Lead, AIDS, HPV (Human papillomavirus), Methylmercury compounds, Chloroform and 300 more substances and frequencies.

 

- “Researchers in Taiwan compared children with cancer to a group of similar children without cancer. They found slightly higher overall risk of cancer in those who lived in towns what had an estimated RF exposure from cell phone towers.”

 

- "Some studies have found possible increased rates of certain types of tumors in lab animals exposed to RF radiation”

 

- “Large studies published in 2018 by the US National Toxicology Program (NTP) and by the Ramazzini Institute in Italy exposed groups of rats (as well as mice, in the case of the NTP study) to RF waves over their entire bodies for many hours a day…Both studies found an increased risk of uncommon heart tumors called malignant schwannomas in male rats… The NTP study also reported possible increased risk of certain types of tumors in the brain and adrenal glands.”

 

- “The results of these studies do not rule out the possibility that the RF waves used in cell phone communication might somehow impact human health.”

 

        The OCS Child Safety Group would like to know how the OCS Board has interpreted these findings in making their decision to place a cell tower on OCS campus. On the referenced link to the American Cancer Society that OCS sent out to parents on 8/10/2022, the American Cancer Society references the “National Cancer Institute Cell Phones and Cancer Risk” website. The OCS Child Safety Group has reviewed this website and their selected studies and would like to point out some disturbing facts.

 

        The National Cancer Institute states “A study that used personal portable exposure meters to assess exposures to different sources of radiofrequency EMFs among children in Europe found that the single largest contributor to the total radiofrequency EMF exposure was the proximity to base stations” (cell towers/antennas). So we know that a cell antenna will expose the children at OCS to large amounts of radiation, more so than any other place in their lives.

 

        The National Cancer Institute's website includes a study from 2004 on the epidemiology of health effect of radiofrequency exposure. The researchers in this study state that current (as of 2004) “studies have too many deficiencies to rule out an association (of cancer, cardiovascular disease, adverse reproductive outcome, and cataract). A key concern across ALL studies is the quality of assessment of RF exposure (meaning most studies never measured a single RF exposure of the people in the study.) Despite the ubiquity of new technologies using RF’s. little is known about population exposure from RF sources and even less about the relative importance of different sources. Other cautions are that mobile phone studies to date have been able to address only relatively SHORT lag periods, that almost no data are available on consequences of childhood exposure, and that published data largely concentrate on a small number of outcomes, especially brain tumor and leukemia.”

 

        The National Cancer Institute says that “studies of animals have not provided any indications that exposure to ELF-EMFs is associated with cancer” and they cite four studies confirming this conclusion, so let's take a look at the main study they are referring to. “Source 11” is one of the studies referenced in making the statement that ELF-EMF’s are not association with cancer and is titled “chronic toxicity/oncogenicity evaluation of 60hz power frequency magnetic fields in B6C3F1 mice.” Although this study is referenced as current and applicable, the study took place in 1999 (before 3G, 4G, or 5G technologies even existed) and was measuring the effects of 60 hertz on these mice. The hertz (symbol: Hz) is the unit of frequency in the International System of Units (SI) equivalent to one event (or cycle) per second. Current low band cell towers produce a range of frequencies ranging from 600 million - 2billion 300 million hertz and 5G towers produce a range between 3.5 billion -39 billion hertz. So, the most current study the National Cancer Institute cites looks at the effects of 60 cycles per second and its potential health effects on mice, meanwhile the current technology being installed on the OCS campus produces up to 39 billion cycles per second. The OCS Child Safety Group does not believe the “current” studies from 1999 are accurate comparisons to determine cell tower safety for our children. Over 1800 recent studies, which we will reference in this letter, show massive and extensive damage to human health at the higher levels of hertz this on campus cell tower will produce, especially in children.

 

        The National Cancer Institute has a specific section on their website titled “What have studies shown about possible associations between non-ionizing EMF’s and cancer in children.” In this section they cite three studies and conclude from those studies that “no consistent evidence for an association between any source of non-ionizing radiation EMF and cancer has been found.” We were very excited to review these three studies and shocked to what they actually reveal. The first cited study (13) is a book that must be purchased and no other references to this study and its results exist so we must rely on the other two studies. Source 14, titled “Review of the epidemiologic literature on EMF and Health” published in 2001 states “Among all the outcomes evaluated in epidemiologic studies of EMF, childhood leukemia in relation to postnatal exposures above 0.4 microT is the one for which there is most evidence of an association….On the basis of epidemiological findings, evidence shows an association of amyotrophic lateral sclerosis with occupational EMF exposure although confounding is a potential explanations. Breast cancer, cardiovascular disease, and suicide and depression remain unresolved.” So, the cited study actually DOES show a correlation to childhood cancer and the current levels of radiation exposure our children will encounter once the tower at OCS is turned on will be thousands of times higher than in this study.

 

        The only other source the National Cancer Institute cites for their basis in stating there is no consistent evidence between non-ionizing EMF and cancer is reference 15, https://pubmed.ncbi.nlm.nih.gov/21946043/ A 2011 study on “Exposure to extremely low frequency magnetic fields and the risk of childhood cancer” which states “There is an ongoing scientific controversy whether the observed association between exposure to residential extremely low-frequency magnetic fields (ELF-MF) and the risk of childhood leukemia observed in epidemiological studies is causal or due to methodological shortcomings of those studies. Recent pooled analysis confirm results from previous studies, namely an approximately two-fold risk increase at ELF-MF exposures ≥0.4 μT, and demonstrate consistency of studies across countries, with different design, different methods of exposure assessment, and different systems of power transmission and distribution….Overall, the assessment that ELF-MF are a possible carcinogen and may cause childhood leukemia remains valid. Ongoing research activities, mainly experimental and few new epidemiological studies, hopefully provide additional insight to bring clarity to a research area that has remained inconclusive.”

 

        Can OCS governing board legitimately believe that a cell tower on campus would be safe for our children given the referenced science, from decades ago, showing the ELF-MF is possibly carcinogenic and may cause childhood leukemia?

 

        The National Cancer Institute has a section on their website titled “Exposure from cell phone base stations.” And proposes to have analyzed the risk of tumors in children spending extended periods of time in close proximity to cell towers/antennas. They cite three studies (source 33, 34, and 35) upon which they drew that conclusion. Let’s look at those three studies and see what they say.

 

        Source 33 is a link to a study titled “Radio-Frequency radiation exposure from AM radio transmitters and childhood leukemia and brain cancer.” This study was conducted from 1993-1999 in South Korea, before 3G was rolled out in 2003, 4G in 2010, and 5G in 2019. This study did not take a single RF reading during that time. The study was on AM radio towers, not cellular towers operating at completely different frequencies. This study did not interview a single child or parent. OCS Child Safety Group believes this study is irrelevant to the potential risks to our children of having a high-powered cell mast on campus and therefore we must look at more current and applicable studies to make any kind of legitimately informed predictions on potential risk.

 

        Source 34 is a link to a study from West Germany titled “Childhood leukemia in relation to radio frequency electromagnetic fields in the vicinity of tv and radio broadcast transmitters.” This study looked at data from children diagnosed with leukemia between 1984-2003 only. Again, not a single RF reading was taken, not a single child or parent was interviewed, and this was prior to the roll out of 3G, 4G and 5G frequencies. In addition, the study did not look at ANY potential health effects of RF from cell towers emitting 3G, 4G, and 5G as it only looked at potential correlations of leukemia with TV and radio antennas over 20 years ago. Again, the OCS Child Safety Group believes this study is irrelevant in relation to the cell tower proposed on OCS campus and the potential health impacts it can have on our children.

 

        The final referenced study showing cell phone base stations are likely “safe” to be around children is Source 35 titled ‘Mobile phone base stations and early childhood cancers” which occurred between 1999-2001 in Great Britain and only looked at cancers associated with the mother’s exposure to RF from cell towers during pregnancy. The study did not investigate a single child after birth for effects of exposure during critical developmental stages. And again, this study looked only at pregnancy and occurred decades before today’s current technology and frequencies that will be installed at OCS, which will be billions of hertz higher than were present in 1999. This third and final study concluding children are potentially safe around cell towers is simply not relevant in any way to the ages of children at OCS and the exposure levels they will receive for 8 hours a day, five days a week for almost their entire childhood and critical developmental stages.

 

        The National Cancer Institute concludes their report on EMF’s by stating that “The Working Group classified ELF-EMFs as “possibly carcinogenic to humans”” and “In 2015 the European Commission Scientific Committee on Emerging and Newly Identified Health Risks reviewed electromagnetic fields in general, and well as cell phones in particular, It found that, overall, epidemiological studies of extremely low frequency fields show an increased risk of childhood leukemia” at levels far below what our children will be exposed to with the OCS tower.

 

        We hear a lot of parents asking questions regarding the FCC safety limits on EMF exposure. Certainly, the tower will be at or below the FCC’s determined safety limits and therefore, our children are safe, right? Well let’s talk about the FCC, the Federal Communications Commission and their limits and determining of safety. When and how did the FCC establish their safety limits. You might be surprised to learn, there are no federally developed safety standards. After years of a robust research effort by US agencies, the US EPA was tasked to develop proper safety standards and was developing two tiered guidelines on both thermal and biological effects. Then, in 1996 it was defunded. Instead of proper safety limits, the US government adopted “guidelines” developed by industry, based on decades old research. Guidelines have a much lower certainty than a “standard” as proper long term safety testing was not done to ensure the public was protected from all possible harm. In fact, no “safe” level has been scientifically determined for children or pregnant women. Therefore, the claim that a device “meets government standards” or that radiation levels are “FCC compliant” gives a false impression of safety.

 

        The FCC established their current “guidelines” in 1996, yes that’s right, 25 years ago! And the testing they utilized to establish their limits were never done on a single human or even a human cell, or even an animal or animal cell. The testing they used was on a rubber head filled with salt water meant to mimic a 220 pound man’s head, and the only measurement they took of EMF’s effects on the rubber head were heat measurements. All current safety standards set by the FCC were established 25 years ago on a 220 pound man rubber head. For more information about how the FCC set their guidelines please visit https://ehtrust.org/policy/fcc-safety-standards/

 

        A 2014 letter from the U.S. Department of Interior states, “The electromagnetic radiation standards used by the Federal Communications Commission (FCC) continue to be based on thermal heating, a criterion now nearly 30 years out of date and inapplicable today.” A letter from Norbert Hankin of the EPA about the FCC guidelines states that children, pregnant women, and the elderly were not considered in the regulations and that the regulations were to protect against hearing damage only and did not consider long-term chronic exposure.

 

       In fact, the FCC was just sued by the Environmental Health Trust to examine the new evidence and studies regarding updating their 25 year old safety limits. Surprisingly the FCC fought this, not wanting to consider any of the mountain of safety studies and evidence now available. But they lost and thankfully the U.S Court of Appeals for DC Circuit issued a judgment against the FCC in August of 2021. The court opinion states that "The (FCC) Commission failed to provide a reasoned explanation for its determination that its guidelines adequately protect against the harmful effects of exposure to radiofrequency radiation." This was a major victory and we look forward to the FCC reviewing all the current published scientific studies on RF and thier negative impacts on human health. Our special thanks to the doctors and scientists who initiated this litigation including but not limited to: recently retired Director of the National Institute of Environmental Sciences Linda S. Birnbaum, PhD; Jerome A. Paulson, MD, FAAP, retired chair of environmental health for American Academy of Pediatrics; and other experts: Lennart Hardell MD, Ph; Devra Davis, PhD, MPH; Ronald M. Powell, PhD; David O. Carpenter, MD; Anthony Miller, MD; Kent Chamberlin, PhD; Fiorella Belpoggi PhD; Livio Giuliani, PhD; Morando Soffritti, MD; Rodolfo E. Touzet, PhD; Theodora Scarato, MSW; Colin L. Soskolne, PhD; Paul Héroux, PhD; Paul Ben-Ishai, PhD; Meg Sears PhD; Claudio Fernández Rodríguez; Igor Belyaev, PhD; Marc Arazi MD; Frank Clegg; John Frank MD; David Gee; Suleyman Dasdag PhD; Christos D. Georgiou, PhD; Prof. Dominique Belpomme, MD; Philippe Irigaray, PhD; Dr. Pierre Madl; Stella Canna Michaelidou, PhD; Alvaro Augusto de Salles, PhD; and Adejoke Olukayode Obajuluwa PhD.

 

        So, what do the over 1800 new studies on RF exposure show, especially on the effects to children? Overall, more than 1800 or so new studies are contained within the bioinitiative report which you can read here: https://bioinitiative.org/table-of-contents/. A summary of these studies show abnormal gene transcription (Section 5); genotoxicity and single-and double-strand DNA damage (Section 6); stress proteins because of the fractal RF-antenna like nature of DNA (Section 7); chromatin condensation and loss of DNA repair capacity in human stem cells (Sections 6 and 15); reduction in free-radical scavengers -particularly melatonin (Sections 5, 9, 13, 14, 15, 16 and 17); neurotoxicity in humans and animals (Section 9); carcinogenicity in humans (Sections 11, 12, 13, 14, 15, 16 and 17); serious impacts on human and animal sperm morphology and function (Section 18); effects on offspring behavior (Section 18, 19 and 20); and effects on brain and cranial bone development in the offspring of animals that are exposed to cell phone radiation during pregnancy (Sections 5 and 18). This is only a snapshot of the evidence presented in the BioInitiative 2012 updated report.

 

        To give you an overview of scientific evidence published since December 4, 2019. Of 39 new genetic effect studies, 79 % (31 studies) showed effects. Of 33 new neurological effect studies, 85 % (28 studies) showed effects. Of 30 new oxidative effect studies, 93% (28 studies) showed effects.

 

        The Presidential Cancer Panel (2010) found that children “are at special risk due to their smaller body mass and rapid physical development, both of which magnify their vulnerability to known carcinogens, including radiation.”

 

The BioInitiative “conclusions” report found at https://bioinitiative.org/wp-content/uploads/pdfs/section_1_table_1_2012.pdf states:

 

- “several thousand scientific studies over four decades point to serious biological effects and health harm from EMF and RFR. These studies report genotoxicity, single-and double-strand DNA damage, chromatin condensation, loss of DNA repair capacity in human stem cells, reduction in free-radical scavengers (particularly melatonin), abnormal gene transcription, neurotoxicity, carcinogenicity, damage to sperm morphology and function, effects on behavior.”

 

- Base-station level RFR at levels ranging from less than 0.001 uW/cm2 to 0.05 uW/cm2. In 5 new studies since 2007, researchers report headaches, concentration difficulties and behavioral problems in children and adolescents; and sleep disturbances, headaches and concentration problems in adults.

 

- DNA acts as a ‘fractal antenna’ for EMF and RFR. The coiled-coil structure of DNA in the nucleus makes the molecule react like a fractal antenna to a wide range of frequencies. The structure makes DNA particularly vulnerable to EMF damage. The mechanism involves direct interaction of EMF with the DNA molecule (claims that there are no known mechanisms of interaction are patently false) Many EMF frequencies in the environment can and do cause DNA changes.

 

- The EMF-activated cellular stress response is an effective protective mechanism for cells exposed to a wide range of EMF frequencies. EMF stimulates stress proteins (indicating an assault on the cell). EMF efficiently harms cells at a billion times lower levels than conventional heating.

 

- Autistic children are far more susceptible to negative health impacts of EMF and RF.

 

- Human stem cells do not adapt to chronic exposures to non-thermal microwave (cannot repair damaged DNA), and damage to DNA in genes in other cells generally do not repair as efficiently.

 

        The list goes on and on and we highly recommend that every parent and staff at OCS read the conclusions report from the BioInitiative Report. Based on EXTENSIVE studies and the evidence of severe negative health effects, especially on children, the OCS Child Safety Group respectfully requests that the cell tower on campus be abandoned for a safer option for better cell service, like an off campus tower, a safe enough distance away for the children to be out of the known dangers an on campus tower will inevitably impose.

 

        The notice OCS sent home with the children on 8/10/22 states a T-Mobile cellular

antenna will be placed on campus and that cellular service is practically non-existent. Independent testing of cell phone reception on Oak Creek School Campus had been unable to locate a single outside place on campus where a cell phone call could not be effectively made, in fact much of the campus has three bars out of five bars of service. The public announcement states that “the ability to make a cell phone call from any campus location could greatly increase response time” and we agree, but the OCS Child Safety Group’s documentation already shows that cell phone calls can be made anywhere on campus. We request that the intelligence of our community be tapped into, and that alternative, safe solutions for better cell service on campus.

 

        The announcement of the cell mast also states that the district will be entering into an agreement with Yavapai County Sherrif’s Office to pilot a new program for the county called Mutuallink that will provide enhanced security features on campus and reliable cellular service is vital to this agreement. OCS Child Safety Group has reviewed Mutualink’s offerings and discovered that Mutualink utilizes CAT5 wiring and a web-based interface, meaning that Mutualink will rely on the school's internet service. The exact same internet system the OCS phone system runs on. If there are concerns about internet going down and phones not working, based on our research the exact same issue will present itself with Mutualink, as it runs off the internet and not cell service. It appears that since so much of the critical emergency response plan for OCS relies on internet connect, the board should first and foremost look to secure reliable internet service and seek to install fiber optic cables as soon as possible. This single act will eliminate all need for a cell tower on campus.

 

        In fact, it appears that OCS is a part of an existing Arizona program that will be installing high speed fiber-optic cables to provide the most secure and reliable communication system available, far beyond what even the best cell service can offer. See the announcement here: Cable ONE Builds Fiber-Optic Network for Education Service - One to One (sparklight.com)

 

        According to the link above, Sparklite was "recently awarded the opportunity to build a new 1 Gigabit fiber-optic Wide Area Network (WAN) with Dedicated Internet Access (DIA) for the Yavapai County Education Service Agency, which encompasses more than 50 schools and libraries and 100 businesses within Yavapai County, Arizona." While the current cable internet is subject to outages and breakdowns in case of severe weather conditions, fiber-optic internet cables, in contrast, require less maintenance, and are not affected by moisture and electric fluctuations. So, it appears to the OCS Child Safety Group that the concern over internet outages resulting in the inability to contact emergency services is already being addressed and will be solved with the installation of the new fiber optics internet.

 

        The precautionary principal requires those in positions of authority use the utmost care, discernment, and due diligence in their decision making regarding the health and safety of those they govern. “Good government requires a serious hard look at the growing scientific evidence that indicates current levels of wireless radiation pose a serious threat to human health and the environment,” stated Devra Davis Ph.D., MPH, president of Environmental Health Trust.

 

        The OCS Board Member Ethics states that the board must “become informed concerning the issues to be considered at board meetings,” “recognize that decisions should be made only after discussion at publicly held Board meetings,” and “render all decisions based on the available facts and independent judgment, and refuse to surrender that judgment to individuals or special-interest groups.” Yet no public discussions at a school board meeting have been released, only an “agenda” item regarding the cell mast that did not involve any discussions. The OCS Board Members could not have made their decision to place a cell tower on OCS campus based on the available facts as the most current studies and facts, as those facts clearly and undeniably show that placing children in such close proximity to a cell antenna is highly detrimental to their health, wellbeing, and learning ability. As such, we believe the Board has violated their ethical duty and obligation to allow for public discussion in the matter of the OCS cell tower and has failed to base their decision on the available facts and independent judgement required of them.

 

        Considering the extensive studies documenting the risks to children of RF exposure, particularly from base station (cell antennas), we respectfully request that OCS abandon the cell mast anticipated to be installed and instead opt for alternative solutions to improve cell service of the staff at OCS. We have many potential solutions that will keep our children safe and protect their health during their critical developmental years. We request that the many alternatives be explored and for community involvement in that process. The “Mission Statement” of this District states that “Students will be provided the tools necessary to develop the highest possible level of achievement and encouraged to be lifelong learners through: A. Partnership with family and community. B. Highest level of staff training. C. Excellent facilities. E. Providing a wide range of learning methods and experiences in a safe environment.” We request the Board Members adhere to their mission statement and partner with the families and community at OCS, train staff on the dangers of EMF-RF frequencies and their effects on human biology, create excellent facilities that do not expose our children to dangerous levels of RF that have been proven to be harmful to them, and provide a truly safe environment in which our children can thrive.

 

Respectfully yours,

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The OCS Child Safety Group