Scope and limits

ATTRIBUTION CORRECTED. SRC-100 is two bound documents: a White Paper of about 33 pages, and a much longer attached Report of the Inter-Commission Working Group beginning at PDF page 59. This content is in the Report, not the White Paper. The two have different standing and must not be conflated: a URSI White Paper is a formal issued document on a controversial subject, while the attached Report is the working group's own fuller account. The bird research is cited by the Report and has not been read here. A proposal in a working group report is not an adopted standard. THAT SENTENCE UNDERSTATES THE GAP AND IS CORRECTED 2026-09-15 AFTER READING THE PAGE. THE DETECTION RESEARCH IS NOT CITED AT ALL. SRC-100 PDF p.178, printed p.157, read first-hand from the rendered page because a missing note marker is exactly what a text layer will not show reliably: "However, at 25 mW/cm2, research has shown that some birds exhibit evidence of detecting the microwave radiation" carries no note marker. The only note in the passage is 37, and it attaches to the NEXT sentence, about larger birds suffering more heat stress during 30 minutes of exposure; note 37 is an entire proceedings volume - the 1980 US DOE Solar Power Satellite Program Review - with no paper, author or page. So the proposed limit rests on a detection premise with no source and a heat-stress premise sourced to a conference. The same page also shows that the 25 mW/cm2 is the working group's OWN proposal and not a finding carried in from elsewhere: "Thus to assure environmental health and safety, the proposed limit for the 'center-of-beam' power densities is approximately 25 mW/cm2 for microwave transmission." AND THE ONE NAMED AVIAN STUDY IS SOMEWHERE ELSE AND SAYS SOMETHING DIFFERENT: at section 4.5.4, printed p.162, note 42 names Dickinson, "Estimated Avian Temperature Rise During Flyover of a 5.8 GHz Wireless Power Transmission Beamer", WPT-2001, and reports that 23 mW/cm2 "did not disturb the birds much" while doubling it would strongly affect them. Detection is not disturbance, so the two do not formally conflict - but the better-sourced statement is the one nobody cites, and it sits five printed pages from the passage this record quotes. The named documents behind both, all unheld and none with a register row, are listed in the acquisition material; none has been acquired. THE CITED VOLUME IS NOW HELD, AND IT CONTRADICTS THE SENTENCE URSI ATTACHED NOTE 37 TO. ESTABLISHED 2026-09-15, READ FIRST-HAND. Note 37's volume is SRC-449, the 1980 DOE/NASA Program Review proceedings, and it contains exactly one avian paper, at printed pp.383-384. URSI's cited sentence says larger birds suffer more heat stress "during 30 min of exposure". The paper says 30 SECONDS, verbatim at PDF p.405: "the rapid onset of gaping under microwaves, e.g. 30 seconds, while birds core temperatures, presumably still low, may be a valuable and sensitive indicator for microwave effects." And no comparison by body size appears in it at all. So URSI's body-mass reasoning is URSI's own, presented as consistent with a cited result the cited volume does not contain. THE UNCITED SENTENCE FARES BETTER THAN THE CITED ONE, which is the reverse of what a reader would assume: the detection premise, which carries no note marker, is supported by that paper's account of birds at 25 mW/cm2 showing occasional gaping, reduced fluffing and a greater tendency to rest. AND THE VOLUME IS A STATUS REPORT, NOT A RESULT: the facility was in its "final stages of construction" and all six studies were still "to be conducted", so a 2007 recommendation cites a 1980 volume announcing that the experiments had not yet been run. The paper's own headline figure is a preliminary median lethal dose of about 150 mW/cm2 for resting birds in winter field conditions. AND THE PROGRAMME'S PUBLISHED PAPER, NOW HELD AS SRC-454, CONTRADICTS THE HEAT-STRESS SENTENCE CLAUSE BY CLAUSE. 2026-09-15. No higher-ambient experiment (all exposures below 6 or 7 degrees C); no larger-against-smaller comparison (similar body masses); an INVERSE mass relation, "SAR = 1.005 - 0.0045 X body mass", so absorption per unit mass falls as birds get larger, the opposite of URSI's reasoning; and 30 seconds, not 30 minutes. Its conclusion is that below 25 mW/cm2 birds "do not seem to be severely affected" and keep their flock position. This does not show the URSI sentence is false about birds; it shows it is unsupported by its citation and contradicted by the programme's own published result.