In August of 2019, the City of Sacramento wasted $61,522 dollars on a useless and unnecessary radio frequency compliance analysis of 28 “small cell” antennas in the Pocket area. The City of Sacramento commissioned the study in August, 2019 and retained engineering firm Hammett and Edison to take radio frequency emissions measurements at 28 small cell sites in the Pocket area. The City also retained Dr. Jerrold Bushberg of UC Davis to perform an analysis of the measurements performed by Hammett and Edison.
The purpose of the study was to measure radio frequency emissions (the type of energy used in wireless communications devices) from the antennas and determine whether or not these emissions were compliant with FCC safety guidelines. According to City staff, this action was taken as a result of the safety issues raised by members of the public concerned about the safety of the 5G antenna network being deployed in Sacramento.
While on its surface the City’s decision to commission this study may seem like the appropriate course of action, the study was completely unnecessary, did NOT demonstrate that these antennas are safe, and ultimately, wasted $61,522 of taxpayer money. Anyone with a basic technical understanding of the antennas being installed could have determined mathematically that the antennas do not have nearly enough effective radiated power to exceed the ridiculously high FCC safety limits at ground level. The limit can be exceeded near the height of the antenna, but compliance is only required at ground level and inside nearby buildings. If you get up on a ladder next to one of these antennas, and it literally cooks your brain, well that’s just too bad for you.
Not only was it pointless to pay Hammett and Edison to come out and confirm that the mathematically impossible was indeed not occurring, it also does not demonstrate that the antennas are safe! The measurements demonstrate that exposure at ground level is below FCC limits, that’s it. Many of the complaints from members of the public who are opposing these cell antennas has been aimed directly at the FCC safety limits, and for good reason.
The FCC’s safety limits are over 20 years old and based entirely on a “thermal model” for damage. This means if the radiation source is not literally cooking you, it is assumed safe. Interference with cell function or brain function, genetic damage, even cancer are not considered at all by the FCC safety limit. This is best explained in a 2002 letter from the U.S. Environmental Protection Agency (EPA) which states “the generalization by many that the [FCC] guidelines protect human beings from harm by any or all mechanisms is not justified.”
It was the job of Jerrold Bushberg to come before council and convince everyone that compliance with FCC safety limits is indeed a guarantor of safety. You can see his full performance at the September 3rd City Council meeting here. After a five minute, forty second introduction, Bushberg delivered a presentation that essentially boiled down to “the FCC safety limits are safe, because the IEEE and the NCRP say they are safe.” ZERO studies were presented; just a high school physics lesson and bureaucratic finger pointing between various agencies. Questions and safety issues raised by the public were never addressed by Dr. Bushberg, even though Councilmember Jennings explicitly said they would be on multiple occasions.
Ultimately Dr. Bushberg’s presentation failed to convince members of the public and even some council members that the hundreds of new cell antennas being installed in Sacramento will be safe for residents or the environment at large.
Show Me The Money
On January 29th, 2020, I finally received the invoices for Hammett and Edison and Dr. Bushberg. I have been requesting these invoices since August 29th, 2019. The City has consistently withheld information regarding the 5G deployment and has generally been as secretive as possible, despite their repeated claims that this project is a tremendous boon to the City. It’s so good that they don’t want anyone to know about it!
Hammett and Edison charged the City $33,600 for their services which consisted of field measurements of 28 antennas and a largely copy/pasted report describing those measurements. From the report we can see that all the measurements were performed on August 5th, 6th, and 8th and that the field technician spent as little as 20 minutes at many of the sites and a maximum of about twenty total hours performing the measurements. It is impossible to determine how much time was spent producing the report but we can deduce that almost all of the report was copy/pasted from other reports performed by Hammett and Edison and that the one page analyses of each antenna are copy/pasted from themselves. Let’s be generous and say it took a full eight hour day to produce the report. $33,600 for about 28 hours of work, works out to about $1,200 dollars per hour. I wish I made that kind of money!
You can view and download the Hammett and Edison report and invoice below:
Dr. Jerrold Bushberg charged the City $27,922 for his services. He provided a breakdown of some of his charges for participating in meetings and conference calls at an hourly rate of $595 per hour, which is arguably fair considering his credentials. However, he was much less transparent with the bulk of his charges to the City. “Review wireless encroachment packets,” i.e. look over the permits for the antennas, $5,600. “Review of testing results,” i.e. look over the measurements performed by Hammett and Edison, $5,600. “Provide a detailed written analysis for applicable federal and state regulatory compliance,” i.e. written report stating that the antennas are compliant with FCC safety guidelines, $7,500. So $18,700 of Bushberg’s invoice is more difficult to determine the justification for.
I was unaware that Dr. Bushberg had performed a written analysis despite my multiple public records requests to the City for ALL information pertinent to the commissioned study. As such, I do not know what level of detail was provided in Bushberg’s report. I have made a public records request specifically for this report and I am eager to see whether or not Bushberg identified the same problems and missing information that I have identified when reviewing some of the antenna permits. Because there are only two types of antennas being installed, with a total of three possible configurations, and because the measurement analyses provided by Hammett and Edison were virtually identical for each antenna, my guess is that Dr. Bushberg did not spend much time on his review and analysis. This is purely speculation based on the simplicity of establishing regulatory compliance. A review of Bushberg’s written analysis will provide more insight into the amount of time and effort that went into his analysis.
You can view and download Dr. Bushberg’s invoice here:
Credible Experts or Industry Shills?
Hammett and Edison (H&E) and Jerrold Bushberg seem to be the “go to” experts in their respective fields whenever a wireless company or California municipality is looking to demonstrate the safety of wireless communications facilities, but is that necessarily a good thing? Both parties have long track records of consulting on wireless safety. Hammett and Edison is a small, family owned company founded in 1951. Bushberg has been consulting for the wireless industry since at least 1993. With all of the engineering firms and wireless experts available, why are these two parties continually called upon?
A google search of Hammett and Edison will give you an idea of how many times wireless companies and California cities have retained this firm to demonstrate that a cell antenna is “safe.” This report by H&E, performed on behalf of Verizon Wireless regarding a cell antenna in Santa Cruz, is nearly identical to the report prepared for the City of Sacramento and demonstrates the copy/paste/rubber-stamping nature of what they do. In fact, MOST of their reports are nearly identical and I have yet to find one report in which they determined that a particular facility was hazardous or out of compliance with FCC safety standards.
Hammett and Edison have also been involved in of some controversial issues regarding cell antenna safety. For example, H&E was the firm retained by Sprint on multiple occasions to demonstrate that the antenna at Weston Elementary School in Ripon, CA was safe for the faculty and students at that school. That antenna was turned off in March of last year after TEN cancer cases were reported in students, faculty, and children living near the antenna. Sprint and H&E still maintain that the antenna is safe and was not the cause of those cancers.
Others have noticed a potential conflict of interest and other problems with H&E consulting on wireless safety. This article from the Elk Grove Citizen, published last year, raises these issues after H&E was retained by the City of Elk Grove to present at their wireless safety workshop in advance of Elk Grove’s small cell roll-out. The activist mentioned in the article has a web page demonstrating how William Hammett himself mislead Elk Grove City council and public. H&E were also called out as industry loyal and untrustworthy in a San Francisco Board of Appeals brief filed in March 2019. The brief states:
Verizon’s agents repeatedly misrepresent that H&E is an “independent third
party” and that the City conducts an “independent review” to assure compliance
with FCC guidelines. The truth however, is that H&E is paid by and works for
Verizon and is represented by Verizon’s lawyers. (p.7-8)
Verizon eventually withdrew their application for the cell antenna that was being contested, though it is unclear whether this action was taken as a result, in part or in whole, of the reported problems with H&E.
In the past year, I have attended city council meetings in Sacramento, Davis, Elk Grove, and Santa Rosa, pertaining to the 5G roll-out in each city. I go to share my family’s experience with the small cell antenna installed just outside our home and to educate these cities on how to prevent this tragedy from happening to their constituents. So far, these other cities have been far more receptive to my message than Sacramento and have passed protective ordinances to protect the health, property, and rights of their constituents.
Nearly one hundred percent of public participation in these meetings comes from people who are opposing small cell technology or who do not want a cell antenna near their home. The only people at these meetings in favor of this technology are representatives from the wireless industry and representatives from Hammett and Edison. H&E have participated in the debate over small cell technology every single California city that I have watched or participated in. Sometimes they are contracted by the city or a wireless company to present information to the City Council. More interesting though, are the times where H&E engineers show up uninvited and use public comment to profess the safety of small cell technology. To me, this is extremely telling. Why would a for profit entity based in Sonoma send their engineers all over the state trying to convince city councils to implement controversial small cell technology?
The most logical answer, in my opinion, is that there must be a direct and/or indirect financial incentive to do so. It is possible that wireless companies pay H&E to send their engineers to these meetings. It could also be as simple as the more antennas being installed, the more H&E gets hired to perform measurements and safety analyses. Why else would they spend hours at these meetings when they could be making $1,200/hour rubber-stamping antennas?
Here are a couple videos of H&E engineers participating in public comment. Notice how they use many of the same talking points as Jerrold Bushberg.
City of Davis Video (1:30:55) *not only is this engineer working for H&E on behalf of Verizon, he is also an IEEE sub committee member responsible for setting the safety standards relied upon by the FCC. How many conflicts of interest is that?
Jerrold Bushberg’s participation in Sacramento City’s exposure study makes a lot more sense. Although he is a nationally renowned expert, he actually lives in the Pocket area, where the study was performed. From the City’s perspective, they could not have found a more appropriate candidate.
Here are a couple videos of H&E engineers participating in public comment: