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Talking Points for FFLA Campaign

• Public Comment Portal -  https://publiccomment.bos.lacounty.gov/
• Contact Person - Alyson Stewart, Ordinance Studies, ordinance@planning.lacounty.gov (213) 974-6432
• Latest Wireless Ordinance Information - https://planning.lacounty.gov/wireless 
• Agenda Item # - TBD

Email Addresses for BOS’s:

District 1:  Hilda L. Solis               213-974-4111                Firstdistrict@bos.lacounty.gov 

District 2:  Holly J. Mitchell          213-974-2222                HollyJMitchell@bos.lacounty.gov 

District 3:  Sheila Kuehl                213-974-3333                

Sheila@bos.lacounty.gov 

District 4:  Janice Hahn                213-974-4444                Fourthdistrict@bos.lacounty.gov 

District 5:  Kathryn Barger           213-974-5555                

Kathryn@bos.lacounty.gov

Please include in your email or letter the three items below:

Dear BOS's:

Please include this in the public record for 11/15/22 changes to Title 16 & 22 of L.A. County wireless code." I'm requesting that you please consider the redlined copies of Title 16 & 22 that were submitted by Fiber First L.A. and that the current amendments to Titles 16 & 22 must not be adopted!

Include 1 or more of the following - pick your topic:

Fairness and Due Process

• The draft Title 16 & 22 amendments remove public notification and public hearings. They will remove the public - the most important stakeholders from these decisions - those who will be directly affected by individual projects and infrastructure as a whole. These are the ones most impacted by a facility siting decision. Removing the public is not only unfair, it’s undemocratic. It also violates basic due process because it will impact their personal and property interests. There must be adequate notice and an opportunity for hearing.
• I do not want a tower showing up in my front yard with no hearing and no ability to have my voice heard in the public record. It’s simply illegal.

Environmental Concerns

• Research finds bees and pollinators absorb between 3% to 370% more of the higher frequencies of 5G, leading the scientists to warn, “This could lead to changes in insect behavior, physiology, and morphology over time....” California agriculture depends on healthy bee populations. Wireless wireless frequencies also interfere with birds’ navigation systems and circadian rhythms, and can harm their development and reproduction and trees can be harmed by the standard radiation emissions from antenna equipment. Effects include altered growth, thinner cell walls and adverse biochemical changes
• Serious environmental impacts from plastic faux trees discharging hazardous waste involving microplastics, lead, and other Proposition 65 listed chemicals are being observed. What is the impact in environmentally sensitive areas?  (See: https://www.theguardian.com/us-news/2022/oct/23/environmental-toxins-neurological-disorders-parkinsons-alzheimers?CMP=share_btn_link)
• Designated environmentally sensitive areas have not been considered and wireless frequencies pose a threat to these sensitive areas. 
• Wireless deployments are highly energy intensive and inefficient, and therefore climate change unfriendly and violative of federal and state policy. A 2020 ABI Research DataCenter Forum white paper Environmentally Sustainable 5G Deployment reports that 5G could increase power consumption by 61 times from 2020 to 2030. This is one of numerous industry report stating that 5G and the phenomenal growth in internet traffic from the internet of things will dramatically increase energy consumption.
• Title 16 & 22 remove all CEQA, NEPA, & NHPA. The courts, the FCC and Telecommunications Act all preserve local environmental oversight. United Keetoowah Band of Cherokee Indians, et al v. FCC, 933 F.3d 728 (D.C. Cir., Aug 19, 2019).  Some areas of LA County are near sensitive and historic areas that the courts have determined are covered under CEQA, NEPA & NHPA. The FCC has not preempted, and cannot preempt state environmental rules that go farther than do NEPA or NHPA, and its own rules (47 C.F.R. §§1.1307 and 1.1320) require an environmental assessment for any facility that “may have a significant environmental effect” on wilderness areas, wildlife preserves, threatened or endangered species, and designated critical habitats.
• Four major wildfires in Southern California have been started, in whole or in part, by telecommunications equipment. That includes the Woolsey Fire. Fire risk needs to be considered, especially in high fire risk areas. Title 16 & 22 remove any checks and balances to address these unique, very important, life threatening concerns.
• An Oct, 2022 Science Direct study shows that wildfire emissions in 2020 were 127 million metric tons (mmt); seven times the 2003–2019 mean. It also found that wildfires are the second most important source of emissions in 2020 and that these wildfires negate reductions in greenhouse gas emissions from other sectors. It also states that it’s contributing to global damages due and climate change at a cost of $7.1 billion.
• Wireless infrastructure harms bees, birds, and trees. Scientific studies confirm that radiofrequency radiation (RFR) emissions from wireless infrastructure have contributed to the sharp decline in bee populations and have adversely affected navigation of birds as well as their growth and reproductive cycles. They also have identified harm to trees causing thinner cell walls and increased terpenes that make them more flammable. https://www.sciencedirect.com/science/article/abs/pii/S0176161714001710
• Fake trees that contain camouflaged cell antennas discharge hazardous microplastics as well as lead (and other Prop 65 chemicals) into the environment. https://ehtrust.org/cell-towers-disguised-as-trees-create-microplastic-pollution-an-environmental-nightmare/

Designated Historic Preservation Sites

• Title 16 & 22 remove any historical site protections. The courts, the FCC and the Telecommunications Act all preserve historical oversight. United Keetoowah Band of Cherokee Indians, et al v. FCC, 933 F.3d 728 (D.C. Cir., Aug 19, 2019). The FCC’s rules (47 C.F.R. §§1.1307 and 1.1320) require an environmental assessment for any facility that may have an adverse effect on districts, sites, buildings, structures or objects, significant in American history, architecture, archeology, engineering or culture, that are listed, or are eligible for listing, in the National Register of Historic Places.” historic areas that the courts have determined are covered under CEQA, NEPA & NHPA. The FCC has not preempted, and cannot preempt state environmental rules that go farther than do NEPA or NHPA.

Health Impacts

• General health effects from RF/EMF exposure resulting from intensifying small cell and macro towers in highly densified populations with no monitoring or measurement of continuous, aggregate, and cumulative exposures. The FCC exercises no meaningful regulatory oversight over the location, operation or the levels of radiation emitted by wireless facilities. Therefore, local governments are citizens' first and only line of defense against the irresponsible placement and construction of telecommunications equipment. Title 16 & 22 are void of any safety precautions.  RF Safety FAQ | Federal Communications Commission (fcc.gov)
• Health effects on already disabled communities, including those with EHS. https://ehtrust.org/science/electromagnetic-sensitivity/
• Research Documents  Children’s Vulnerability to Cell Phone Radio-frequency Radiation
• Children have smaller heads than adults.  Cell phones and wireless radiation can go deeper into their brains because children have a shorter distance from their skull to their brain center. Government regulations were based on a 220-pound man’s head, not a child’s head. Our skulls actually slow down wireless as it moves into our brain. The thicker the skull, the more roadblocks to the wireless radiation moving forward. Since children have much thinner skulls than adults, they have less protection. Research shows that children can absorb up to ten times the radiation in the bone marrow of their skulls than adults, https://ehtrust.org/childrencellphoneradiationeffects  
• https://ehtrust.org/research-on-childrens-vulnerability-to-cell-phone-radio-frequency-radiation
• There will be Health Impacts. This is no longer up for debate! The densification of the wireless radiation (RFR) in our environment is taking a biological toll on humans. Continuous, aggregate, and cumulative exposure with no monitoring by any agencies is irresponsible at best. Well over a thousand studies have documented this harm. Especially vulnerable are the disabled, elderly, and environments such as schools, hospitals, retirement communities, airports, and essential emergency services (e.g. fire stations). https://ehtrust.org/science/top-experimental-epidemiological-studies

Social/Environmental Justice and the Digital Divide

• Special lack of information and vulnerability of minority populations. Despite outreach from LA County, most of the people in unserved and underserved areas are not informed about any available service, let alone fiber to the home. If they understood the superiority of fiber; it’s futureproof and end user affordable qualities, why would they choose wireless? 
• The industry  is making false claims relating to wireless solving the Digital Divide. Wireless service will not be able to provide the robust services that a family needs and that new technology will demand. Equitable, futureproof service is fiber to the home! 
• Immediate federal funding under BEAD and Infrastructure Act is being denied to underserved, poor, and minority communities that demand superior optical fiber  Internet access. Based on the assumption that fiber to the home will require disruptive practices with noisy equipment and digging up streets and extending deployment for months or years. This is not true as there are many processes that can hasten fiber infrastructure and minimize any disruption to communities. Fiber to the Home (FTTH) Fiber Optic Solutions | OFS (ofsoptics.com); Deployment Methods of FTTH - Meldium
• The BOS recognizes the superiority of fiber to the home as noted in BOS meetings, but are under the impression that it will be too expensive and take too long. But many communities have found that in the long run, this is not true. As well, fiber services are more affordable to the end user without suprise add-ons for additional services and is therefore a more equitable choice for financially strapped unserved and underserved communities. See this article for more information. City of Riverside to Receive Citywide High-Speed Fiber Network Following Approval of Agreement with SiFi Networks | riversideca.gov
• Like many communities around the country L.A. County is currently addressing the digital divide and the BOS is in a unique position to be a leader in solving the digital divide in an equitable, thoughtful manner using fiber to the home. 2022 Fiber-To-The-Home Top 100 (bbcmag.com)
• In the haste of wanting to quickly address this issue, we can not let go of the prudence necessary to do it right. This is a social justice issue. If we do not get this right today, we will extend the digital divide into the next decade. 
• The magnitude of finally solving the digital divide once and for all is a subject that the BOS does not take lightly, as clearly expressed during past hearings. But it is socially unjust and unconscionable to streamline Title 16 & 22 and rush services to communities that have been notoriously redlined. Inferior wireless will not give these communities equitable broadband and will not solve the digital divide. It will only prolong it. 
• Fiber to the home has been prioritized by the Federal Government because it's superior  to wireless based on access, overall cost of infrastructure, equitable service, enhancing economic growth, specific speeds for upload and download; reliability of service, consistency in quality of service, and affordability to the end user. Wireless doesn’t compare to fiber when it comes to any of these issues.
• If we are truly concerned about digital equity we would be looking at ways to fund fiber instead of making it a "future" ambition as noted by the BOS's in meetings going back to November, 2021. http://file.lacounty.gov/SDSInter/bos/supdocs/163611.pdf
• The BOSs must think of the long term when considering broadband and changes to their ordinance for both wireless infrastructure and fiber. You must fight the temptation to cave in to industry spin with underwhelming service that will not address the fundamental need of equitable broadband. As some of the BOS’s have stated many times in the past, this is a civil rights issue. Therefore, we must address this equitably and with the mindset that we will find a way to serve our communities with robust, futureproof broadband that will finally give unserved and underserved communities what they deserve, fiber optics. 
• They Remove Due Process. This is simply undemocratic and illegal! There will be NO public notification, NO public hearings and NO opportunity for appeal. We can literally wake up one morning and see a tower or array being put up right next to our house or apartment. This removal of due process will apply to all sitings of telecommunications facilities (cell towers, small cells, and antenna arrays). 
• ALL oversight from environmental rules such as CEQA, NEPA & NHP will be removed! The courts, the FCC and Telecommunications Act all preserve local environmental oversight. Environmental assessments are required for any facility that “may have a significant environmental effect” on wilderness areas, wildlife preserves, threatened or endangered species, and designated critical habitats.
• Social Justice Issues and the Digital Divide- False Claims: The availability of viable alternatives- Fiber to the Premises (FTTP) are being suppressed. It is socially unjust and unconscionable to streamline Titles 16 & 22 and rush wireless to communities that have been notoriously ignored by faster, safer, more future-proof fiber connectivity. Inferior wireless will not give these communities equitable broadband and will not solve the digital divide. It will only prolong it. 
• Fiber to the home has been prioritized by the Federal Government. It's superior to wireless based on access, overall cost of infrastructure, equitable service, enhancing economic growth, specific speeds for upload and download; reliability of service, consistency in quality of service, and affordability to the end user. Wireless doesn’t compare to fiber when it comes to any of these issues.
• The amendments to Titles 16 & 22 must not be adopted!

Please tell everyone you know to contact the Los Angeles Board of Supervisors!

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