{"id":"26110082715","name":"Fern Taylor","organization":"","posted":"2026-10-21","received":"2026-10-20","body":"Re: ET Docket No. 13-84, Public Notice DA 26-997 I write as a concerned member of the public to urge the Commission to update its radiofrequency (RF) electromagnetic radiation (EMR) exposure limits, adopted in 1996 and based only on heating effects. The court’s remand. In Environmental Health Trust v. FCC, 9 F.4th 893 (D.C. Cir. 2021), the court found the Commission failed to explain its dismissal of evidence of non-cancer harms. That evidence has grown. The International Commission on the Biological Effects of Electromagnetic Fields concluded that current science invalidates the assumptions behind the FCC limits (ICBE-EMF, Environmental Health, 2022;21:92). Large animal studies. The U.S. National Toxicology Program found clear evidence of malignant heart schwannomas in male rats exposed to RF EMR, along with evidence of DNA damage (NTP TR-595, 2018). The Ramazzini Institute independently found the same tumor type at exposures modeled on cell towers (Falcioni et al., Environmental Research, 2018;165:496-503). The WHO’s International Agency for Research on Cancer classifies RF EMR as possibly carcinogenic, Group 2B (Baan et al., Lancet Oncology, 2011). Sleep and well-being. Controlled studies show RF exposure alters sleep EEG and cerebral blood flow (Huber et al., Journal of Sleep Research, 2002;11:289-295). Sleep underlies immune, hormonal and mental health, so even modest disruption across a population matters. Children. Children absorb more RF energy in the brain and bone marrow than the adult model used to set the limits (Gandhi et al., Electromagnetic Biology and Medicine, 2012;31:34-51). Testing based on an adult male head does not protect them, and today’s children are exposed from birth, around the clock. Long-term, ubiquitous exposure. When the limits were set, exposure was brief and occasional. Today it is continuous: phones carried against the body, Wi-Fi, smart meters and dense 5G infrastructure. The limits have never been evaluated for decades of cumulative exposure from many sources at once. Environment. The Department of the Interior warned in 2014 that tower radiation may harm migratory birds. Research published in Nature found that weak human-made electromagnetic noise disrupts the magnetic compass of migratory songbirds (Engels et al., Nature, 2014;509:353-356). I respectfully ask the Commission to: (1) adopt limits that protect against non-thermal biological effects; (2) base device testing on children and on body-contact use; (3) evaluate long-term, cumulative exposure; and (4) give weight to independent health researchers and agencies, not only industry-involved standard-setting bodies. Thank you for considering these comments.","source_hash":"55b7b9593a5af9c8eb716c3b96ea4fb86484d18d1d76b9bc3ac7b94c7ff33e13","filing_type":"COMMENT","proceedings":"ET 13-84","captured_at":"2026-10-22T22:31:29.841Z","source_name":"Fern Taylor","number":"26110082715","withheld":false,"attachment_inventory":true,"capture_reviewed":false,"source":"https://www.fcc.gov/ecfs/filing/26110082715","slug":"sleep-neurology-filing-26110082715","tags":[],"attachments":[],"attachment_names":[],"classification":{"id":"26110082715","body_sha256":"246057344931a74833eef356690ae8e456a96f7652473c3cb02387ba74602614","status":"text_matched","primary_topic":"sleep-neurology","topics":[{"id":"sleep-neurology","evidence":"Sleep and well-being."},{"id":"cancer","evidence":"2021), the court found the Commission failed to explain its dismissal of evidence of non-cancer harms."},{"id":"children-schools","evidence":"Children."},{"id":"biology-metabolism","evidence":"National Toxicology Program found clear evidence of malignant heart schwannomas in male rats exposed to RF EMR, along with evidence of DNA damage (NTP TR-595, 2018)."},{"id":"towers-antennas","evidence":"The Ramazzini Institute independently found the same tumor type at exposures modeled on cell towers (Falcioni et al., Environmental Research, 2018;165:496-503)."},{"id":"wifi-devices","evidence":"Today it is continuous: phones carried against the body, Wi-Fi, smart meters and dense 5G infrastructure."},{"id":"wildlife-environment","evidence":"Environment."},{"id":"standards-testing","evidence":"13-84, Public Notice DA 26-997 I write as a concerned member of the public to urge the Commission to update its radiofrequency (RF) electromagnetic radiation (EMR) exposure limits, adopted in 1996 and based only on heating effects."},{"id":"remand-accountability","evidence":"The court’s remand."},{"id":"research-requests","evidence":"Large animal studies."}],"summary":"","method":"Supplied topics validated against current body hash and exact passages","scope":"Captured filing text only. Attachment contents not examined."},"supplied_classification":{"id":"26110082715","body_sha256":"246057344931a74833eef356690ae8e456a96f7652473c3cb02387ba74602614","status":"text_matched","primary_topic":"sleep-neurology","topics":[{"id":"sleep-neurology","evidence":"Sleep and well-being."},{"id":"cancer","evidence":"2021), the court found the Commission failed to explain its dismissal of evidence of non-cancer harms."},{"id":"children-schools","evidence":"Children."},{"id":"biology-metabolism","evidence":"National Toxicology Program found clear evidence of malignant heart schwannomas in male rats exposed to RF EMR, along with evidence of DNA damage (NTP TR-595, 2018)."},{"id":"towers-antennas","evidence":"The Ramazzini Institute independently found the same tumor type at exposures modeled on cell towers (Falcioni et al., Environmental Research, 2018;165:496-503)."},{"id":"wifi-devices","evidence":"Today it is continuous: phones carried against the body, Wi-Fi, smart meters and dense 5G infrastructure."},{"id":"wildlife-environment","evidence":"Environment."},{"id":"standards-testing","evidence":"13-84, Public Notice DA 26-997 I write as a concerned member of the public to urge the Commission to update its radiofrequency (RF) electromagnetic radiation (EMR) exposure limits, adopted in 1996 and based only on heating effects."},{"id":"remand-accountability","evidence":"The court’s remand."},{"id":"research-requests","evidence":"Large animal studies."}],"summary":"","method":"Local topic rules v1; exact supporting passages; not an AI or medical review","scope":"Captured filing text only. Attachment contents not examined."},"mirror_fingerprint":"fafdedcccf9a77ac0198aa8f85800368a3c3fdae549873621cda0fba1de35daf","seo_modified":"2026-10-29T15:50:59Z","forum_topics":["sleep-neurology","cancer","children-schools","biology-metabolism","towers-antennas","wifi-devices","wildlife-environment","standards-testing","remand-accountability","research-requests"],"primary_topic":"sleep-neurology","forum_title":"Re: ET Docket No. 13-84, Public Notice DA 26-997 I write as a concerned member of the public to urge the …"}