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Comments of Erin Finegold ET Docket No. 13-84, DA 26-997 Remand Issue: Testing Procedures for Cell Phones and Other Portable Devices I write in support of compliance testing that measures portable devices as they are carried and used. I am the founder and CEO of StingRay Shields Corporation, which develops patented passive RF technology, including Shield Antenna. I request no endorsement of any product and submit no proprietary information. This comment rests on the Commission’s own record. The question on remand is narrow. The court did not resolve the scientific debate and did not find the Commission’s procedures technically invalid. It held that the Commission had not reasonably explained its decision to retain them. Environmental Health Trust v. FCC, 9 F.4th 893 (D.C. Cir. 2021), slip op. at 19–20, 31. A reasoned explanation must address three points. First, the Commission cannot merely repeat its safety-margin rationale without curing the explanatory deficiency identified by the court. In paragraph 14 of FCC 19-126 the Commission gave four reasons for declining zero-spacing body testing: head testing with no separation, maximum-power testing, actual test distances that tended to be less than 2.5 centimeters (with a maximum of 1 centimeter for hotspot testing), and the “large safety margin” in the limits. The court held that the safety-margin explanation depended on an inadequately explained premise: that RF exposure below the existing limits does not cause harmful non-cancer effects. The court concluded that this explanatory defect also undermined the justification for retaining the testing procedures, noting that footnote 49 of the order linked challenges to testing with challenges to the exposure limits. On remand the Commission should state whether the first three reasons independently justify retaining the procedures, and on what record basis. Second, the Commission should separate two questions it merged in 2019: whether a certified device stays within the numerical limits in ordinary body-contact use, and whether those limits protect health. The first is a measurement question. The Commission should explain, with record support, whether a device certified at the distances described in paragraph 14 can exceed the applicable SAR limit at zero spacing and, if it can, why the procedure remains adequate. Third, footnote 47 relies on proximity sensors that reduce power near the body and on manufacturers’ antenna design changes. The Commission should identify the certification procedures that apply to those features, explain how they are verified, and describe how test configuration, separation distance, and power-control behavior are documented so that results are reproducible. If the Commission cannot make these showings on the record, it should revise the procedures to test devices in the configurations in which they are used. The Commission’s own footnote recognizes that design, including antenna design, affects exposure. A procedure that measures the device as sold would allow any design remedy to be judged on demonstrated performance in that device rather than on assumed benefit. The Commission should answer the deficiency the court identified directly rather than restate its 2019 assurances. References: FCC Seeks Comment on RF Exposure Issues Subject to D.C. Circuit Remand in Environmental Health Trust v. FCC, Public Notice, DA 26-997, ET Docket No. 13-84 (OET rel. Sept. 17, 2026), 91 FR 60128 (Sept. 22, 2026). Resolution of Notice of Inquiry, Second Report and Order, Notice of Proposed Rulemaking, and Memorandum Opinion and Order, FCC 19-126, 34 FCC Rcd 11687, ¶ 14 and nn.46–49 (2019). Environmental Health Trust v. FCC, 9 F.4th 893 (D.C. Cir. 2021), No. 20-1025 (consolidated with No. 20-1138), slip op. at 19–20, 30–31.

I've been a real estate agent in the Snowflake area since 2002. I've been working closely with a well know MCS (multiple chemical sensitivity) community near the town. Over the past year I've helped them fight to keep a Verizon 5G tower out of their neighborhood. We thought we had it won as county sided with us, but Verizon brought a law suit on the county and won. This tower just got completed yesterday. It will completely ruin these residents (approx 30) property values. It is an unimaginable crime against them, destroying their lives/livelihood. Cell service at this location was good...this was a total waste of time, resources, and a 30 some year thriving neighborhood.

Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Reassessment of Federal Communications Commission Radiofrequency Exposure Limits and Policies ET Docket No. 13-84 To: Secretary, FCC Comments: Jean Lemieux, President of the Massachusetts Association for the Chemically Injured, Inc. submits comment in the above-captioned proceeding. I, Jean A. Lemieux, am providing comment on behalf of the members of the Massachusetts Association for the Chemically Injured (MACI), a volunteer, non-profit statewide support, education and referral organization for people with Multiple Chemical Sensitivity on the proceeding of FCC Docket 13-84. The Massachusetts Association for the Chemical Injured’s comment centers on the issue of EMFs, wireless (RF) technology and potential health effects and harms experienced from the EMF and RF exposure from a general population public health perspective and specifically for vulnerable segments of the population, including those living with Multiple Chemical Sensitivity/Intolerance and those who are electrically sensitive (EHS)/EMR-S. My position on the current proceeding focuses on its reassessment of FCC exposure limits and policies that address the following: 1). a complete review of all of the science, inclusive of the biological health effects in the non-ionizing exposure category that has accumulated ii this docket and past one. FCC needs to review for reassessment the vast amount of research and scientific evidence that had been submitted in response to an update of new FCC guidelines and public health policy. 2). MACI’s comment on this proceeding will demonstrate the impact that the FCC’s failure to update guidelines on the current research and scientific evidence inclusive of the non-thermal biological evidence impacts human health. MACI participated in Public Comment to our State Departments of Public Utilities Dockets and the impact of the deficient FCC guidelines was used as a benchmark by the Department in the setting of policy (see MACI Reply Comment to DPU). My comment furnished evidence of real-life experience in related matters before our State Department of Public Utilities Dockets. 3). The unaddressed potential health risks by the FCC failure to update guidelines failed the Federal Agency’s duty to reflect a public health standard and failure to consider vulnerable populations who should be afforded special protection under federal and state laws. Many people who suffer from chemical sensitivities are concomitantly vulnerable to the effects of electromagnetic fields (EMF) and radio frequency radiation (RFR). A population survey of Hypersensitivity to Electromagnetic Fields in CA found chemical sensitivity to be an important risk factor for hypersensitivity to EMFs. The combination of sensitivities is quite disabling and puts their ability to work or live in their residences at greater risk. See submitted published research and studies that attest to the issue on prevalence of MCS and EHS, health effects experienced, risk for vulnerable members of public, comment to Docket HHS-OASH-2026-0397, exposure to smart meters - a device covered under the FCC, and the Public Comment to Massachusetts Department of Public Utilities. They should be considered part of my comment. The FCC must recognize, acknowledge and take the necessary steps to implement guidelines and rules based on all of the science, not just the “thermal” limits exposure that may have been protective in the 1980’s. The FCC has a duty and the responsibility to review and reassess fully the range of exposure to this environmental pollutant where EMFs and RFR exposure has become ubiquitous to ensure safe exposure for the population, for vulnerable members of the population, and equal access for this vulnerable population in their living environment, their workplace, and access to participate in society in today’s environment. The current research and scientific evidence which has become extensive showing biological health effects, epidemiological evidence through published studies, surveys, and real-life experience should be assessed in the setting of guidelines and policy. The matter of this docket did indicate that a broad range of commenters could participate. I offer this brief introductory comment with the submitted documents. In conclusion, there has been a failure of the FCC to update guidelines for today’s exposures and the current state of the science on EMFS and RFR. A view of impact on the public and especially those most vulnerable to EMF and RF and wireless exposure must be included in the reassessment of FCC radiofrequency exposure limits and policy. This failure on the Federal level has implications for State regulatory agencies who have hid behind and used as a benchmark these FCC guidelines which are insufficient to protect public health and allows for the pressure of Industry to control and set public health policy. There is sound reason why this is an important issue and the Federal Communication Commission should heed this important information and recommendations in the Commissions deliberation and the setting of FCC policy, rules and regulations. Respectfully submitted, Jean A. Lemieux President Massachusetts Association for the Chemically Injured, Inc. P.O. Box 754 Andover, MA 01810 978- 681-5117 macimcs@aol.com There was no box to upload the attachments. The regular form to submit by pdf failed in the Proceedings and didn't allow my filing of comment on this proceeding. Attachments: • AAEM Board of Directors, Statement: “Wireless Smart Meters Case Series”, American Academy of Environmental Medicine, October 23, 2013. • Belpomme, Dominique and Phillippe Irigaray, Electrohypersensitivity as a Newly Identified and Characterized Neurologic Pathological Disorder: How to Diagnose, Treat, and Prevent it”, International Journal of Molecular Sciences, 2020: 21, 1915. • Belpomme, Dominique and Phillippe Irigaray, “Why electrohypersensitivy and related symptoms are caused by non-ionizing man-made electrmagnetis fields: An overview and medical assessment.”, Environmental Research, 212 (2022) 113374. • International Commission on the Biological Effects of Electromagnetic Fields, “Electromagnetic Hypersensitivity (EHS) Is A Humanitarian Crisis That Requires An Urgent Response”, Issued July 2024: Revised December 2024. • Lamech, Federica, MBBS, “Self-Reporting of Symptom Development From Exposure to Radiofrequency Fields of Wireless Smart meters in Victoria, Australia: A Case Series”, Alternative Ther Health Med. 2014; 20(6): 28-39. • MACI’s statement outlining a section of the Reply Comment from the Massachusetts Association for the Chemically Injured, Inc. to the Department of Public Utilities on D.P.U. 12-76 on two questionnaire surveys on smart meters and health effects (Reference #12 on comment to HHS). • Massachusetts Association for the Chemically Injured, Inc. Comment to the Department of Health and Human Services, Federal Register: Notice of Request for information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure. • McCredden, McLean, and Steinemann study titled “Wireless sensitivity and co-morbidities: A prevalence study in Australia, Canada, and the United States.” March 2026. Science Direct, Next Research [https://www.sciencedirect.com/science/article/pii/S3050475926002745]

https://x.com/RosalitoEhs/status/1961682070473752975 Can also view my website here to view other linked resources etc https://sickpeopleinneedehscommunity.com/#resources

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My experiences inclue: a strongheadache (an 8 on a scale of 10) after a new cell tower was built and activiated. Previously, I never had a migrane headache, like other people. I went to Swede. There everone I met were either harmed by electromagnetic radiation or knew people who were! In Sweden, I felt fine for 4 days. I relocated. Four days agai, headache reaapreared. Grrr! This experience repeated again and again......I slept uncomforatbly in the rental car. Rarely I asked a homeowner for a shower. To get food was distant. I slept in a Swedish log cottage with a ground fire in the middle space and layers of deer fir to sleep on. Nice. I had to leave. New guests were arriving. To continue: People harmed by electromagnetic radiation may carry in their bodies a remembered the injury from invisible electromagnetic radiation. My home is similar to a faraday cage. No wifi, no drones, in a no-fly-zone, NRQZ (National Radio Quiet Zone) protected by USA congress in 1956. A person visited, was here 10 minutes. She HAD to leave immediately. She did not allow her body to forget the constant invisible pain (in faraday like cage) in our home. I tried to contact her. No luck. A hospital diagnosed her having "VibroAcousticDisease" (VAD= vibro acoustic sound waves) in her obituary (2025). She had died. I feel sad and very helpless. Harmful places I deteted: creeks and rivers carry frequencies (my reactions were confirmed by a medical doctor / scientist), stil lakes, ponds reflect th sun (I met a few people can only go out during certain nights. The ocean is too moving to reflect a constant-continual frequency. A rock clif reflects radiation emitted from vehicles. Trains (higher frequency as the train approaches: experience, the radiation harms and rightens me. I experienced the ding ding of an approaching train, the gate arms lowered, I braced myself. No train. the dings stopped, no train. Wish, the train very quickly passed.

This filing was submitted as an attachment. Open the document below to read the comment.

This filing was submitted as an attachment. Open the document below to read the comment.

This filing was submitted as an attachment. Open the document below to read the comment.