1. Whether by 47 U.S.C. § 332(c)(7)(B)(iv) the preemption of any State remedy for injury by telecommunications facilities without providing a substitute federal remedy violates the constitutional right of access to courts and conflicts with a century of Supreme Court jurisprudence.

2. Whether, consistent with its ordinary meaning, as well as its meaning in every other federal statute in which it occurs, the term "environment effects" in 47 U.S.C. § 332(c)(7)(B)(iv) should be interpreted to mean "effects on the environment" and not "effects on human health," thereby restoring to all Americans their fundamental rights to life, liberty, and property and adhering to the principle that statutes should be construed to avoid rendering them unconstitutional.

Whether the preemption by 47 U.S.C. § 332(c)(7)(B)(iv) of any State remedy for injury by telecommunications facilities without providing a substitute federal remedy violates the constitutional right of access to courts and conflicts with a century of Supreme Court jurisprudence