JURISDICTION AND VENUE

This action arises under the Compact Clause of the United States Constitution, Article 1, section 10, clause 3; and the Tahoe Regional Planning (“TRPA”) Compact, Public Law No. 96-551, 94 Statute 3233 (1980), Cal. Gov. Code §66801, Nev. Rev. Stat. 277.200 (copy of Compact attached as Exhibit A). Jurisdiction of this Court is conferred by 28 U.S.C. §1331 (federal question), 28 U.S.C. §1367(a) (pendent jurisdiction over state claims), and Article VI(j) of the Compact. Declaratory relief is available pursuant to 28 U.S.C. §2201-02 and Rule 57 of the Federal Rules of Civil Procedure.1.Venue is proper in this Court pursuant to Article IV(j)(2)(A) and (B) of the Compact, because the specific action challenged relates to a project area in the City of South Lake Tahoe, within this Court’s judicial district, and the more general allegations all relate to the Tahoe Region and the extensive wireless infrastructure proposed to be added or modified which, all together, constitute one major federal/state action fragmented into many piecemeal projects, as these terms are defined and interpreted under the National Environmental Policy Act (NEPA), the California Environmental Quality Act (CEQA) the TRPA and other federal and state statutes.2.The Compact is a federal law for the purposes of jurisdiction.3.This Court has supplemental jurisdiction for state law claims set forth in this Complaint pursuant to 28 U.S. C. Sec. 1387.

SUMMARY

4.The Tahoe Regional Planning Agency (TRPA) is an Interstate Compact established by a special act of Congress in 1980 involving the states of California and Nevada, in close and continuing collaboration with various agencies of the federal government “to ensure an equilibrium between the region’s natural environment and its man-made environment.”5.TRPA is actively engaged in licensing a few telecom companies to blanket the Tahoe Region with Radiofrequency Radiation (RFR) emitting small and large cell towers, without any consideration or assessment of the risks to Tahoe’s unique environment, the increased fire hazard, and the danger from increased and untested RFR exposuresto thousands of Tahoe’s residents, especially our most vulnerable communities —children, the elderly, disabled persons, and minorities. 6.Plaintiffs contend that the piecemeal approval and implementation of the TRPA’s wireless infrastructure program flagrantly violates the terms of the Compact itself, TRPA’s own Regional Plan, and several relevantfederal and state laws, prominently the Administrative Procedure Act (APA), the National Environmental Policy Act (NEPA), the Americans with Disabilities Act (ADA), the Fair Housing Amendments Act (FHAA), the California Environmental Quality Act (CEQA), among many others. The fact that a number of TRPA GoverningBoard members named in this lawsuit are under a clear conflict of interest as defined in the Compact makes the review of their decisions even more urgent. 7.Plaintiffs are requesting the court to issue a series of Declarations, a writ of Mandamus to compel compliance with federal and state established procedures, and to establish a moratoriumon the proposed expansions of antennas, as other federal courts have done in the past; in this case halting further piecemeal blanket implementation of cell tower and antenna approvals and installations, until TRPA complies fully with all applicable federal and state laws, and is consistent with the terms of its Compact and Regional Plan.