25 January 2015
Delivered Via Electronic Mail
Mr. Dale Keller – Environmental Health
Salt Lake County Health Department
788 East Woodoak Lane
Murray, Utah 84107
Re: Request for Inspection and Assistance
Dear Mr. Keller,
On behalf of the residents living within the District 2 boundaries of the Salt Lake City School District and in my capacity as an elected official,  I am requesting your assistance because I have reason to believe that the Salt Lake City School District is in violation of the following Utah State Office of Education, Rules:
R392-200-2(2): The governing body of the school, shall ensure that the school building and grounds are constructed, operated, and maintained in accordance with this rule.
R392-200-5 School Grounds
(2) Mechanical equipment, electrical transmission lines, poles, transformer boxes, and other electrical equipment shall be located or protected with a barrier to prevent an electrical or other safety hazard. & (8) Playgrounds must be located in areas that maximize safety.
The Salt Lake City School District is poised to allow Verizon Wireless to install a cell tower with multiple antennas on the roof of a school in my neighborhood. The school administration bypassed the notification and approval process of the local School Community Council and the Board of Education. I was only made aware of a cell tower coming into my community because of the vigilance of a couple of parents who noticed it listed on the Salt Lake City Planning Commission agenda.
As a result of this revelation, I asked the Superintendent for a list of other schools in the Salt Lake City School District that currently have cell towers on their property. The Superintendent provided me with a list showing that ten schools in the district are the so called “host” sites for cell towers.
As part of my process of investigating and researching the dangers that cell towers pose to our students, I went to Nibley Park Elementary located at 2785 S. 800 E. and Uintah Elementary located at 1571 E. 1300 S. (both in Salt Lake City) and measured the RF radiation levels in the play grounds of both schools. I utilized an HF35C Meter  and it registered RF radiation in excess of 2,000 µW/m² which exceeded the limits of the meter I was using.
As you will note in the attached video, readings in excess of 2,000 microwatts per square meter occurred whenever I pointed the meter in the direction of the cell antennas perched on top of the schools. Based on my observation, I concluded they were the source of the RF radiation that was registering off the scale.
My measurements far exceed the standards set by the BioInitiative 2012 document.  I call upon the expertise of your office, as I am not familiar with the application of time, distance, exposure etc…in determining what level of electromagnetic radiation exposure is acceptable for children by the standards utilized by your office. I can say, as a policymaker, the levels I have witnesses are much too for my comfort.
I am deeply troubled that the school administration allowed the installation of these cell towers without any effort on their part to evaluate the risks these towers pose to our students, faculty and surrounding residents.
There doesn’t appear to be any type of monitoring to ensure that the towers do indeed meet FCC guidelines of RF radiation exposure. Who is monitoring the accumulative effect of three different companies installing cell towers on the roof of Uintah Elementary?
In my opinion, one tower is bad enough. It would seem to me that the students and faculty are being exposed to an inordinate amount of radiation on a daily basis, inside and outside of the building due to the accumulative exposure from numerous antennas perched over their heads.
During my tour of schools that have cell towers on their roofs, I noted a series of signs that are blue, yellow, orange and red. Each of these signs displayed cautions and warnings about the “radio frequency fields” exceeding the FCC rules for human exposure.
I have to ask myself, who in their right mind would think that this type of equipment is okay to be installed in the midst of children?
I also noted a recent letter by the U.S. Department of Interior, expressing concern that cell towers pose a danger to migratory birds.
The Interior Department accused the Federal government of employing outdated radiation standards set by the Federal Communications Commission (FCC), a Federal agency with no expertise in health. The standards are no longer applicable because they control only for overheating and do not protect organisms from the adverse effects of exposure to the low-intensity radiation produced by cell towers: “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.”
It boggles my mind to think that the FCC requires warning signage to be placed near the cell towers stating that the antennas on the tower do indeed exceed (outdated) radiation exposure standards. Yet, the school administration did not give it a second thought to install not one, but many towers at one school.
I find it equally perplexing that one agency in the federal government inexplicitly states that
“Impacts from nonionizing electromagnetic radiation emitted by these structures…[has caused] nest site abandonment, plumage deterioration, locomotion problems, reduced survivorship and death”. 
In contrast, our board president informed us that the Business Administrator, Janet Roberts has determined that it is safe for children to be in and around all of these cell towers. At the rate that Uintah Elementary is accumulating cell towers, I fear that the school is going to be morphed into some kind of cell tower Disney land.
I am outraged to think that a cell tower is poised to be installed in the heart of my community. My neighbors elected me to ensure a bright future for their children. I instead feel that I have failed them because I have allowed the school bureaucracy to use the school system for a purpose that has nothing to do with education and everything to do with potentially destroying the future of our children’s health. I am saddened to think of the dangers the school district has already exposed students, faculty and resident at the ten school “hosting” existing cell towers.
It is my hope that you can use the full weight of your office to evaluate the threat of RF radiation exposure to the students and faculty to, at the two Elementary schools mentioned above.
I believe that you have the authority and jurisdiction to address these concerns: R392-200-2(3):
However, if the …the Local Health Officer determines that conditions in any school are a threat to the health of persons using the school, the … Local Health Officer may order correction of any condition that impairs or endangers the health or life of those attending schools.
J. Michael Clára
Board Member, District 2
 § 53A-3-401(5), Utah Code: Notwithstanding a local school board’s status as a body corporate, an elected member of a local school board serves and represents the residents of the local school board member’s district, and that service and representation may not be restricted or impaired by the local school board member’s membership on, or obligations to, the local school board.
 Salt Lake City Planning Division Staff Report PLNPCM 2014-00643 Verizon Wireless Rooftop Antennas and Electrical Equipment 1430 W. Andrew Avenue (Glendale Middle School).
 Salt Lake City School District, Cell Site Agreement Information 2014-2015 provided by Superintendent Withers on 01/22/2015
 Gigahertz Solutions High-Frequency Analyzers
 BioInitiative 2012 –A Rational for Biologically-based Exposure Standards for Low-Intensity Electromagnetic Radiation pg. 101-107.
 Mr. Willie R. Taylor, Director, Office of Environmental Policy and Compliance- U.S. Department of Interior –Letter, addressed to U.S. Department of Commerce