“Radiation impacts have only recently become a conservation issue with field studies on nesting birds initiated around 2000 in Europe… and laboratory studies conducted in the U.S.during the late 1990s on chicken embryos. Virtually unknown however are the potential effects of non-ionizing nonthermal tower radiation on wild nesting avifauna of North America including at extremely low radiation levels, far below the safe exposure level previously determined for humans. Unfortunately, these safe levels continue to be based on thermal heating standards now in applicable. Based on studies in Europe, communication towers appear to be the cause of radiation impacts to breeding migratory birds”