Stop the Radio Towers

Subtitle

HELP FUND THE LEGAL FIGHT:  

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Checks payable to: PRTA/FTT  

P.O. Box 158, Point Roberts, WA 98281 

Informal Objection


Arthur Reber submitted the IO to the 

Federal Communications Commission (FCC) 

and to the attorney of the company 

that owns the radio station.


Click on the green button to view


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Informal Objection of the Cross-Border Coalition

to be submitted to our 

Washington DC attorneys and eventually to the

Federal Communication Commission


click here to read


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Letter from our group's leadership


November 4, 2013

Suzanne Bosman
Whatcom County
Planning and Development Services

Re: Correspondence from Ms. Linda White Atkins of Davis Wright Tremaine, LLP


Suzanne:


We know you’re still working on the report for CUP2013-00004-KRPI Transmitter Site but we (the members of the Cross-Border Coalition) feel that we need to respond to the letter from Ms. Atkins of Davis Wright Tremaine, LLP, the firm representing BBC Broadcasting, Inc.


The letter is remarkable on several fronts. First, it acknowledges what no other document submitted by BBC Broadcasting has: the existence of the city of Tsawwassen, British Columbia, Canada and its approximately 24,000 residents (estimate based on growth since the 21,000 plus recorded in the 2006 census).


Second, it makes abundantly clear that by not previously mentioning this population center, BBC did not act in good faith in its initial application to the FCC nor to Whatcom County’s PDS. By extension, this omission allowed them to remain under the radar when it came to the FCC seeking clearance with Industry Canada (IC). So long as Tsawwassen and its high-population density parameters were suppressed, there was no reason for IC to object – and object they would have as is outlined below.


Third, the letter also acknowledges what we have known all along: there will be significant blanketing interference that will affect the thousands of residents and businesses across the border and not just the 300 or so identified in the original applications.


Fourth, the issue of enforcement is not broached. Ms. Atkins’ letter is a promissory note but one with no legal mechanism to back it up. The company can promise all it wants in order to secure the permit but once the towers are up they are under no legal obligation to carry through. This point is important. The FCC only requires that mitigation be carried out according to their guidelines in the US. There are no official mechanisms in place for cross-border complaints.


Fifth, independent of Ms. Atkins’ word that BBC Broadcasting will work to mitigate all complaints from Tsawwassen (and to do so even after the 1-year period has expired), it is virtually certain that they will not be able to. The reason is obvious – and it is precisely the reason why both the FCC and Industry Canada impose constraints on the proportion of a region’s population that lies within the 1 V/m contour (in the US) and the 250 mV/m contour (in Canada).


Because the towers are planned to be sited at a location that the neither the FCC nor Industry Canada would permit if all the facts were known, the proportion of the population of Tsawwassen that will be impacted by the interference is so large that even partial mitigation will be virtually impossible.


According to the letter from Ms. Atkins, KRPI has on call a single engineer who apparently lives in or near Ferndale. This person, one David Harris, presumably has a visa to work in Canada and has the ability to travel to Tsawwassen on a regular basis – and we say “regular” because the number of individual homes and business that lie within the 250 mV/m contour of the nighttime 50kW signal is the entire city of Tsawwassen and some of the surrounds. Hence, the population that would potentially suffer blanketing interference is approximately 24,000 individuals. To get a feeling for what’s involved here, let’s do a little counting.


Let’s assume that there are only some 15,000 individual homes, apartments, condos and business offices involved. Let’s also give them the benefit of the doubt and estimate that only about 15% of them will experience blanketing interference (this is based on the proportion of residents in Ferndale who filed complaints relative to the population there). This gives a minimum of 2,250 cases that will need mitigation. If Mr. Harris, who will be travelling up from Ferndale, is able to fix three instances a day it will take him at least 3 years to complete the job – assuming he has no other duties to perform for the company and that he can actually do three a day. It’s worth keeping mind that in Ferndale many complaints turned out to require more than one attempt and many ended up unmitigated.


In short, the promise to mitigate the anticipated blanketing interference that will hit Tsawwassenites is an empty one. There is no way they will be able to do this – and this estimate is on the “soft” side. There are reasons for expecting a significantly higher proportion of complaints in Tsawwassen than there were in Ferndale. The towers there are in a field some distance from population centers. The planned Point Roberts array will be within 950 feet of the border – across which is the most densely populated area of Tsawwassen. And, as noted in an earlier comment we submitted, within the community of radio aficionados AM stations that broadcast at 50 kW at night are called “blowtorches.” Wide-spread blanketing interference is the reason.


There was one other comment in Ms. Atkins letter that is almost embarrassingly self-serving. She notes that the company includes two documents (one a handbook) on how to mitigate blanketing interference. This handbook is simply the one the FCC uses as standard operating procedure. It is, in case you or anyone in your office hasn’t looked at it, virtually impossible to follow or use by anyone who doesn’t have a background in science and is comfortable with electrical work. Very few individuals without such experience will be able to carry out the complex and intricate procedures involved in shielding and filtering the unwanted signals. We can’t help wondering why Ms. Atkins mentioned these documents when the purpose of the letter was to ensure all concerned that BBC Broadcasting would mitigate all complaints and continue to do so even after the mandatory 1-year period.


We can sum up this analysis simply.

•If the population of Tsawwassen had been included in the original application to the FCC to relocate the tower array to Point Roberts, they would not have approved it.

•If the towers were to be sited a mere 950 feet to the north across the border, IC would never approve the project.

•As soon as the actual population density parameters are put into the equation (independent of the border) the project is immediately seen as wholly inappropriate and in violation of standard principles of the operation of AM radio stations in both the United States and Canada.

Best,

The Cross-Border Coalition:

Point Roberts -Arthur Reber, Mark Robbins, Jennifer Urquhart, Suzanne Rosser, Steve Wolff, Renee Coe

Tsawwassen - Nancy Beaton, Steve Graham, James Ronback


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Reasons why the towers should not be built

The proposed radio tower site is not consistent with the Point Roberts Character Plan and is only 330 meters (1,080 feet) from the border.


On both sides of the border property values around towers can drop 20%.


Five 150' towers blasting 50,000 watts during the day and 50,000 watts proposed at night would present a visual blight and a hazard to migratory birds along the Pacific Flyway.  Aircraft warning lights mounted on top the towers could be seen by residents on both sides of the border.


There are over a thousand US neighbors and several thousands of Canadians within a radius of 9,140' (2.786 km) - the radiation beam of the antennas directed towards Canadian listeners in Surrey, BC.


BBC Broadcasting Inc, has owned the KPRI AM broadcasting towers in Ferndale, WA, for 15 years.  BBC Broadcasting Inc. is a registered American corporation.  But the KRPI studio, 99% of the corporate officers & employees, the target audience, advertisers, and revenue are all in Canada.  


The FCC denied KRPI's request to raise their nighttime wattages from 10,000 to 50,000 watts.  KRPI is now trying to relocate to Point Roberts.


Why have a radio tower in Washington State?  Cheaper land and less onerous regulations than in Canada.  


Mark Robbins of Point Roberts stated:

"Americans on our peninsula were given scant public notice: KRPI Radio and its owner BBC Broadcasting Inc ran the minimal one-inch ad in the Bellingham Herald, which isn't sold in Point Roberts."


"The FCC's notification to the good people of Point Roberts was published much earlier in the Federal Register, which of course no normal person follows.  It's a source for insiders."


"South Deltans, who will be severely affected if this move is made, were given no notice at all, so we have many questions and several concerns."



A multitude of potential health risks like insomnia, headaches, and hypertension have been reported worldwide.  Cancer clusters have been reported around long-operating European AM radio stations.  Some people's health will be more affected than others.


The International Agency for Research on Cancer (IARC) in 2011 declared that Electromagentic Energy shall be classified as Class 2B Carcinogen akin to the now infamous Benzene chemical.  IARC is a subgroup of the World Health Organization. 

Click here to read IARC Classifies Radiofrequency Electromagnetic Fields as Possibly Carcinogenic to Humans


A cell phone is a 1/2 watt device you use 30 minutes per day.  The proposed AM Transmitter is designed to be a 50,000 watt system that everyone is exposed to 24 hours a day, 7 days a week, 365 days a year.


Click to read an article in the American Journal of Epidemiology Radio-Frequency Radiation Exposure from AM Radio Transmitters and Childhood Leukemia and Brain Cancer "


In Ferndale blanketing interference caused problems with radios, televisions, DSL connections, landline reception, Ham radio transmission, First Responder hand-held equipment, personal safety / medical devices, and public address systems.  Some people experienced shocks and burns when working with metal.


KRPI engineers "overlooked" 21,000 Tsawwassen residents - probably so they could give short shrift to Point Roberts' 1,300 American residents in a falsely-described "low density, rural, economically depressed" area.


 


The Point Roberts Conservation Society is behind the Stop the Radio Towers email list.  PRCS is assisting in the NoTower.com website project.


The Point Roberts Conservation Society is a nonprofit foundation, registered in 1993. We are committed to providing education on responsible land use, indigenous history, protection and sustenance of our unique environment of forest, wetlands, and coastline. 

We welcome new members: s.rosser@inter-the-gateway.com

http://prcsorg.com/

What you can do


Please email, write, or phone the people / agencies listed below.  


See the Topics subpage for points you can make in your communications.  Please write or phone today!


Join the Stop the Radio Towers email list for latest news by sending an email request to Suzanne Rosser:

S.Rosser@Inter-The-

Gateway.com


Congresswoman Suzan Delbene

Contact form at

http://delbene.house.gov/contact-me/email-me

Phone (202) 225-6311


Senator Maria Cantwell 

Contact form at

http://www.cantwell.senate.gov/public/index.cfm/email-maria

Phone (425) 303-0114


Senator Patty Murray

Contact form at 

http://www.murray.senate.gov/public/index.cfm/contactme

Phone (425) 259-6515


Kerry-Lynne Findlay Q.C.

MP Delta-Richmond East

607 Confederation

House of Commons

Ottawa, ON K1A 0A6

Canada

Kerry-Lynne.Findlay@parl.gc.ca


Vickie Huntington, MLA, Delta South

(604) 940-7924

Vicki.Huntington.MLA@Leg.BC.CA

4805 Delta Street, Delta, BC 

VAK 2T7


Lois E Jackson, Mayor of Delta

(604) 946-3210

Mayor@Delta.ca


Write to the US Consul General via

http:Vancouver.USConsulate.gov/contact.html


Write to the  Honourable James Moore, Minister Industry Canada minister.industry@ic.gc.ca


Sign the online petition at 2care.com

Click HERE to go to the

online petition 


Donate funds to help cover out-of-pocket expenses related to educating the public, payments to experts and attorneys if needed, and travel costs related to in-person testifying.  Just click on the Donate button below or on the Donate subpage to learn how you can help.


Thanks for your support!