TCA preempted state law which placed the burden of proof on the applicant to show the lack of substantial evidence. See, e.g., Sprint Spectrum L.P. v. Town of Easton, 982 F.Supp. 47, 49 (D.Mass.1997) (citing United States Cellular Corp. v. Board of Adjustment of City of Des Moines, Polk County District Court, LACL No. CL 00070195 (Iowa District Court for Polk County, January 2, 1997)). However, TCA preempted local zoning authority only in a limited number of areas and the burden of proof was not included in any such limitation. Therefore, to find that the TCA preempts the traditional placement of the burden of proof on the applicant contravenes the text and history of § 332(c)(7) as discussed above. 28 . Cellular Telephone Co. v. Town of Oyster Bay, 166 F.3d 490, 494 n. 3 (2d Cir.1999) (<HOLDING>). 29 .The court acknowledges that its role is
holding statutory terms concern over environmental effects from rf emissions included concern over health effects caused by such emissions holding over holding that section 1252d effects a statutory exhaustion requirement which accordingly precludes any common law exceptions for procedural default holding that specific statutory provisions take priority over general statutory provisions recognizing the principle that gives precedence to the terms of the more specific statute where a general statute and a specific statute speak to the same concern