Biological mechanisms & metabolism

Thank you for the opportunity to provide my comments to you. I am responding from the perspective of a concerned member of the public. I am aware that in 2021 (and in 2026 when the Court gave the FCC 30 days to explain why they took no action on their 2021 order), the U.S. Court of Appeals for the D.C. Circuit ruled that the FCC’s decision to retain its 1996 radiofrequency (RF) radiation exposure guidelines was arbitrary and capricious because the FCC failed to consider a mountain of peer-reviewed scientific studies demonstrating serious biological harm. Over the years, there has been a growing body of scientific research raising concerns about non-ionizing electromagnetic radiation effects on human health and the environment. From what I understand, the only studies the FCC has relied on for its guidelines were those done in the1980's, which focused on the behavioral effects of animals who were exposed to heat from microwave radiation (short term study), and not on cell, DNA, etc. effects of humans/animals who were exposed to RF radiation (long-term study needed). The court ordered the FCC to provide a reasoned explanation for its determination that its RF exposure guidelines adequately protect humans and the environment against the harmful effects of such exposure (RF radiation unrelated to cancer). My opinion on this is that since 1996 there have been massive increases in the levels of radiation exposure in the environment due to advances in the technology, and, therefore, it is incomprehensible that the 1996 radiation exposure guidelines would have any relevance in 2026. For this reason, I also believe that the FCC never should have adopted, in 7/2026, changes allowing certain mobile and portable wireless devices to transmit at a fourfold increase in power levels, without assessing the potential implications for human exposure; Specifically, the court directed the FCC to address: (1) the impacts of RF radiation on children; (2) the health implications of long-term exposure to RF radiation; (3) the ubiquity of wireless devices and technological developments since the FCC’s RF exposure guidelines were last updated in 1996; (4) the impacts of RF radiation on the environment; and (5) the adequacy of the FCC’s RF radiation testing procedures for cell phones and other portable wireless devices. I strongly believe that in responding to the 2021 court order, the FCC should work with HHS Secretary RFK Jr. (who has expressed great interest in addressing this issue) and let his health agency take 100% of the lead in addressing each of the issues identified by the Court. HHS has the expertise in medicine, biology, epidemiology, and public health, for which the FCC does not (its expertise is primarily in regulating communications, communications technology, and spectrum management). Also, given HHS's expertise, and the fact that it doesn't regulate the telecommunications industry, I believe that public trust in its studies/conclusions, its responses to the Court, and its implementation of protective measures, will be greatly enhanced. I believe the following should be done, which will also encompass the issues identified by the court: (1) study the human health and environmental effects (animals, plants, etc. - court ordered this to be done) of electromagnetic radiation from all sources, such as cell phones, 5G and 6G networks, wifi routers, wifi infrastructure (cell towers, small cells, etc.) smart meters, wearable devices, wireless medical equipment, satellites, etc.; (2) review published independent, non-conflict of interest scientific studies. A compilation by researcher Henry Lai, Ph.D. includes more than 3,000 peer-reviewed studies published since 1990 that reported significant adverse effects from EMF exposure; (3) do not review any studies prepared or funded by the conflict of interest telecommunication industry unless their studies have been replicated by independent non-conflict of interest studies; (4) if the current published studies are insufficient (gaps in research) in any areas, such as real-world exposure levels, long-term consequences (court ordered this to be done – L-T exposures), and cumulative exposure, appropriate federal research priorities should be established (new studies- short term or long-term, as required). And the studies that are done should be transparent so that independent, non-conflict of interest scientists can replicate them; (5) with regard to the impacts on human health, pay particular attention to children (court order required this), but also to other vulnerable groups, such as pregnant women, workers, people with implanted devices, etc.; (6) listen to the people who have become very ill from electromagnetic radiation and study them because their experiences provide important insights into potential areas of scientific investigation. Symptoms include headaches, nausea, dizziness, brain fog, anxiety, heart palpitations, insomnia, and tinnitus, and more serious diseases like cancer, diabetes, cardiac irregularities, neurological conditions/issues, and infertility. In Pittsfield, Massachusetts, lawyers represented residents who reported serious health effects directly following the installation and activation of a cell tower in their neighborhood; (7) listen to parents who have reported their concerns about the growing presence of wireless devices and screen-based technology in schools; (8) 330 of the studies reviewed by Henrry Lai, Ph.D listed oxidative stress and free radicals as adverse effects from electromagnetic radiation, which we know are precursors to cancer. So even though the Court did not require this information, long-term studies should be done to identify cancer issues; (9) After all the studying, investigating, analysis, etc. has been done and the results are in as to the human health and environmental (animal, plants, etc.) impacts of electromagnetic radiation, and the necessary protections to our citizenry and our environment have been proposed: (a) update the exposure guidelines and prepare any other protections that are necessary. In this vein, also answer the Court order on the ubiquity of wireless radiation and technology development since the last Guidelines update in 1996; (b) update the RF radiation testing procedures for cell phones and other wireless devices as the Court ordered. In updating, use adults, children, etc. and not a plastic head since it doesn't model real human tissue. Do long-term studies to measure non-thermal biological effects as well as thermal effects; (c) HHS and FFC should review all the completed data together, give meaningful consideration of the experiences and evidences before it, prepare an answer to the 2021 court order; and swiftly implement the protections to public health and the environment; (10) until all the above steps are completed, there should be a moratorium on any expansion of electromagnetic radiation technologies in our communities. I do not have a story of the health effects of electromagnetic radiation on myself, and no one I know has expressed any of these issues. However, in the last 5 years, I have listened to, and read articles by, independent non-conflict of interest scientists that say that my body (cells, DNA, etc) may be continuously affected without my awareness and eventually lead to a symptom or illness (long-term exposure). One study that speaks about this is https://www.spandidos-publications.com/10.3892/ijo.2021.5272 Human-made electromagnetic fields: Ion forced-oscillation and voltage-gated ion channel dysfunction, oxidative stress and DNA damage (Review). Therefore, based on the above, I am very concerned about the health and environmental impacts from the following: (1) cell towers going up at an accelerated pace, many in areas that already have sufficient broadband access, such as my community. A nearby church has a cell tower and that concerns me; (2) the smart meter on the side of my garage; (3) the increases from 5G to 6G and further, which will increase the electromagnetic radiation we are subject to; (4) the small cell towers that they will need to put on properties every 700 or so ft. in order to accommodate the 5G or up cell phones; (5) my wifi router, which sits right next to my desktop computer; and (6) my smart appliances. Thanks Janice

We are really in a public health emergency with all of the wireless devices and waves of exposure all around us. These exposure levels are said to be thousands of times over what could be a possible safe level where the science tells us that there really aren’t any truly safe levels for this kind of radiation (microwave exposure). There are thousands of studies, many collected in the Bioinitiative Report BioInitiative Report: A Rationale for a Biologically-based Public Exposure Standard for Electromagnetic Fields (ELF and RF) that demonstrate clearly that these exposures, even at very low levels, have dangerous biological effects. There is even an important study known as the EU Reflex Study which demonstrates that wireless radiation damages cells and DNA on pare with nuclear or gamma radiation. Reflex Study Finds Genotoxic Effects 2004 In city life we are completely surrounded and penetrated by countless exposures from every direction. There is not only the danger that comes from one cellphone,which is enormous, but the cumulative exposures from our neighbors, those coming from satellites, cell towers, smart meters, Bluetooth speakers, multiple WiFi routers in schools with multiple cellphones and other devices. It is a non-stop bombardment which is the cause of extraordinary health damage including cancers, neurological disorders, dementia ( Dr Sharon Goldberg says even in teenagers now) cardiovascular disorders, brain damage, blood toxicity, and anxiety, among many other health problems. I became extremely sensitive to these wireless microwave radio frequency radiation exposures after buying and driving an electric car. After a two hour drive I had an intense neurological breakdown where I could no longer sense the periphery of my body nor could I remember or track my thoughts. It was quite like I was experiencing dementia with a feeling of squeezing across the top of my head as well as a feeling that my brain was vibrating. I healed over time by avoiding all wireless exposures as much as possible as well as consuming large doses of many supplements, but I remain an electro sensitive person whose body is intensely disturbed by surrounding wireless exposures. I used to have to drive out to the countryside to be able to breathe when my neighbor would have his Bluetooth on (as well as when the smart meter was installed on my home- so fortunate to have my smart meter in opt out mode now but there is still some “dirty electricity” it causes that affects my health). I am very fortunate to have a new neighbor who keeps his Bluetooth off for me. There are also places in my home where I can feel the smart meters shooting through my home. I can’t stand very long at my sink without getting pains in my body from this, can not sit at parts of my dining room table nor use one of my bedrooms ( as it is to close to my other neighbors who use Bluetooth etc). It is quite a challenging life for an electro sensitive person ( though we are all biological and are all being damaged from wireless, the electro sensitive can feel the damage as it is happening). It really limits where I can go and how long I can stay in any given place. I could definitely not work in an office or school or even attend a dinner with people with their cellphones on etc. There are millions of people like me who have become electro sensitive all over the world. Many have been displaced from their homes because of cell towers or smart meters and other wireless nightmares. Many can no longer work in their jobs for which they have trained. Some have had to seek refuge in the forest or rural settings, though now with the proliferation of satellites and almost ubiquitous wireless coverage it is becoming more difficult to find a safe place to live. There are also dangers to our atmosphere, other living beings of nature( bees, birds, trees, etc, and the planet which we must be arrested immediately. This wireless proliferation should have been stoped a long time ago as the science has been available for decades. There is an important article from The Lancet - Planetary Electromagnetic Pollution: is it time to assess its impact? This is a critical situation, a real emergency, to preserve the health of people and planet. It requires immediate, sober and creative action. It is critically important that we primarily wire for communications and eliminate the waves passing through/damaging bodies. Cell phones as they exist now can be used in airplane mode with Bluetooth, cellular, and WiFi off, with an Ethernet adapter to access internet etc. There could be stations available at home, workplaces, around town, etc where one could plug in one’s phones or computers for connection. Utility meters and other tech could also be wired, avoiding the extremely damaging bodily trespass of microwave radiation.

Electromagnetic Hypersensitivity (EHS): Research, Disability Accommodation, and Public Health Concerns Submitted by Sheena Symington, B.Sc., MA, sheena@electrosensitivesociety.com Director, Electrosensitive Society Inc. www.electrosensitivesociety.com Background and Experience My name is Sheena Symington, and I am the Director of the Electrosensitive Society. For more than 20 years, I have studied the biological effects of electromagnetic fields (EMF) and radiofrequency radiation (RFR) while supporting individuals affected by electromagnetic hypersensitivity (EHS), also referred to as electromagnetic injury. My work includes educating the public about electromagnetic hygiene, providing individual support, and advocating for accommodations that allow people with EHS to access safe housing, workplaces, schools, medical facilities, hospitals, and public spaces. I have worked with more than 14 hospitals to reduce and contain electromagnetic exposure so that patients with EHS can access medical care. Containing wireless radiation within designated areas is an important accommodation, comparable to managing other forms of environmental pollution. https://www.electrosensitivesociety.com/how-hospitals-can-accommodate-patients-who-have-ehs/ A growing number of physicians are diagnosing this environmentally induced disability, while specialists in EMF and RFR remediation are helping affected individuals reduce their exposure. EHS as a Disability and Barriers to Accommodation EHS can be debilitating, isolating, and life-altering. Symptoms vary considerably, ranging from mild discomfort to severe impairment that prevents individuals from working or participating in everyday activities. For some, electromagnetic exposure affects cardiovascular and neurological function, including the heart and brain. Symptoms may improve substantially or resolve when exposure is eliminated. The widespread use of wireless technologies, including cell phones, Wi-Fi, and cellular antennas, makes it increasingly difficult for affected individuals to access medical care, maintain employment, or secure suitable housing. Access to affordable housing with low electromagnetic exposure is particularly urgent. Such environments are becoming increasingly difficult to find in both urban and rural areas. Some individuals have been displaced or become homeless because they cannot find housing that accommodates their environmental sensitivities. In Canada, individuals with environmentally induced disabilities have applied for Medical Assistance in Dying (MAID) because of their inability to secure suitable living environments. This underscores the importance of developing affordable, low-exposure housing for people with environmental sensitivities. Progress in Medical Education, Accessibility, and Legal Recognition Several developments demonstrate growing attention to EHS and the need for appropriate accommodations. Information for Doctors on how to prevent electromagnetic injury: https://www.electrosensitivesociety.com/information-for-health-care-professionals/ Medical education: Two EMF medical conferences offering Continuing Medical Education (CME) accreditation were held in California in 2019 and online in January 2021. The latter remains available to physicians. EMF Medical Conference 2021 National Council on Disability: In May 2022, I was invited to present to the U.S. National Council on Disability (NCD) on accommodating individuals with EHS in hospital settings. Electrosensitive Society – NCD Presentation, May 12, 2022 Legal recognition and accommodation: In June and August 2022, Physicians' Health Initiative for Radiation and Environment (PHiRE), based in the United Kingdom, reported successful legal action securing full accommodation for EHS in a public school. PHiRE also reported that a woman received Early Ill-health Retirement and Employment Support Allowance on the basis of EHS. PHiRE – News   Reducing Electromagnetic Exposure Radiofrequency electromagnetic fields associated with wireless technologies have been classified by the International Agency for Research on Cancer (IARC) as Group 2B: Possibly Carcinogenic to Humans, a category that also includes lead and DDT. We should consider examples from European schools and hospitals that have reduced or removed Wi-Fi to limit unnecessary exposure. Relevant examples include: • Cyprus Hospital Removes Wi-Fi to Protect Children • Schools Worldwide Removing Wi-Fi and Reducing Exposure Practical measures to reduce exposure and accommodate individuals with EHS include: • Locating cellular towers away from residential areas, schools, hospitals, and other sensitive locations. • Establishing areas free from cellular towers and unnecessary wireless transmissions. • Turning off wireless devices wherever possible. • Replacing Wi-Fi with shielded Ethernet cabling and fibre-optic connections without wireless components. • Providing wired internet access in homes, workplaces, schools, hospitals, and other public facilities. These measures would help create accessible environments while maintaining high-quality internet connectivity. Additional guidance on electromagnetic hygiene and accommodations is available through the Electrosensitive Society. Research on the Biological Effects of Electromagnetic Exposure Through our work at The ROSE Lab (www.theroselab.com), we investigate and document biological responses to electromagnetic fields and radiation. EHS is frequently interpreted as a psychological rather than physiological condition. Our research examines measurable biological responses that may help distinguish these explanations. Studies conducted by our research group including double-blind, placebo-controlled investigations, have reported the following findings:   1. Cardiovascular and autonomic nervous system responses Some individuals exposed to RFR experience tachycardia (rapid heart rate), increased sympathetic nervous system activity, and reduced parasympathetic activity. These responses have been documented during controlled exposure studies. 2. Blood glucose regulation Dr. Magda Havas has documented changes in blood glucose among individuals with diabetes and EHS. Blood glucose increased during RFR exposure and decreased in electromagnetically cleaner environments, with changes observed within approximately 20–30 minutes. 3. Multiple sclerosis (MS) symptoms Observations involving individuals with MS and EHS have reported reduced tremors in environments with lower electromagnetic exposure. 4. Blood viscosity and circulation Research has reported changes in blood characteristics associated with electromagnetic exposure, including increased viscosity and reduced blood flow. These findings raise concerns about potential cardiovascular implications, including heart attack and stroke risk. 5. Effects on plants We have also investigated the effects of Wi-Fi exposure on seed germination and plant growth, including broccoli, peas, red clover, and garden cress. These studies contribute to our understanding of biological responses to electromagnetic exposure and the importance of further research and appropriate accommodations. Research References Diabetes and electromagnetic exposure PubMed – PMID 18568931 Multiple sclerosis and electromagnetic exposure PubMed – PMID 17178585 Tachycardia and autonomic nervous system responses Havas – DECT Phones Affect the Heart Blood viscosity PubMed – PMID 24192494 Effects of Wi-Fi Radiation on Germination and Growth of Broccoli, Pea, Red Clover and Garden Cress Seedlings: A Partial Replication Study ResearchGate – Study Conclusion Individuals with EHS face significant challenges in accessing healthcare, housing, employment, education, and public spaces. Greater recognition of their accommodation needs, together with practical measures to reduce electromagnetic exposure, is essential to improving accessibility and quality of life. The Electrosensitive Society provides one-on-one assistance to affected individuals and their families, while The ROSE Lab continues to investigate biological responses to electromagnetic exposure. I welcome the opportunity to share our research, experience, and practical approaches to accommodating individuals disabled by electromagnetic exposure. Please confirm receipt of this submission and contact me if further information or assistance would be helpful. Sincerely, Sheena Symington, B.Sc., MA Director, Electrosensitive Society Inc. The ROSE Lab Email: sheena@electrosensitivesociety.com Website: www.electrosensitivesociety.com Research: www.theroselab.com

I am a concerned Indigenous American, Creek Nation, and a Board Director of the Community and Friends of Seattle-Tacoma Pet Cemetery, a 501(c)(3) nonprofit. I submit these comments as an individual, not on behalf of the organization. I am a community member and advocate who is directly affected by a 100-foot industrial AT&T cell tower sited in a historic human and pet cemetery, and I write from firsthand experience. I have followed the permitting and legal record closely. The situation. The historic Seattle-Tacoma Pet Cemetery est. 1950 on Kent's West Hill is located in unincorporated South King County, Kent, Washington, in a community of color, immigrants, refugees, and low-income households. Humans, pets, K-9 officers, and service animals are buried here, some as whole families. Many cultural traditions exist here. In Indigenous cultures and spiritual traditions, animals are regarded as equally important as humans, deserving of the same dignity, honor, and respect in life and death. I hold that humans and animals call for the same and equal respect in life and death. In 2020, during the COVID-19 pandemic, Crown Castle installed a 100-foot industrial AT&T cell tower inside active Burial Block 13 with graves and mourners and 115 feet from neighboring homes in opposition to cemetery patrons, neighbors, and community members at large. It was installed in the wrong zone without a conditional use permit, in violation of King County Code and Washington State cemetery law. Additionally, Crown Castle did not disclose the human burials or the cemetery's historic significance on its permit application, and the project was pushed through the King County Department of Permitting and Environmental Review without addressing them. I have opposed its placement and operation since 2019. Why this matters to the issues before the Federal Communications Commission (FCC). The FCC is open to public comments for Cell Phone and Wireless Radio Frequency Radiation (RF) Health Effects and other Non-ionizing Electro Magnetic Frequency (EMF). I am talking about RF in this comment because that is the issue in the situation. The FCC's standards are the primary protection communities have against radio frequency radiation (RF) exposure. Under federal law, local governments generally cannot deny a cell tower based on RF health effects when it meets FCC limits. However, it is my understanding that communities can raise health concerns alongside other legitimate issues, such as zoning, permitting requirements, human remains, historic significance, etc. Our cemetery case involves all of these concerns. We should have the right to raise RF health concerns independently, without having to rely on other grounds for objection. If the FCC's standards are outdated, communities have limited recourse to protect residents, mourners, and their loved ones from potential RF exposure risks. Changes since 1996. The limits predate smartphones, small cells, etc., and constant connectivity. Towers now stand close to where people live and grieve, and people spend long periods near them. I ask the Commission to evaluate whether 1996 limits account for the ways that cell phones, cell towers, and the like are used and installed today including but not limited to chronic, daily, close-range RF exposure. Children and vulnerable people. Children live in the homes near this tower and visit the cemetery with their families. The record includes research showing children absorb more RF energy than adults (e.g., Fernández et al., 2018, Environmental Research). I ask the Commission to address children, pregnancy, and medically vulnerable people specifically. Long-term and non-cancer effects. The Commission should examine long-term, low-level exposure and non-cancer effects, including neurological, reproductive, and developmental effects, oxidative stress, and DNA damage, rather than relying on short-term heating thresholds. Animals and the environment. Pets, K-9 officers, and service animals are buried here, and wildlife lives on the grounds. The FCC has no wildlife-specific exposure limits. I ask the Commission to consider the research on effects on animals, insects, birds, and plants (e.g., Levitt, Lai & Manville, 2022, Reviews on Environmental Health, Parts 1–3). Testing and compliance. I ask the Commission to require independent, post-installation RF testing with public results that are easily accessible, so communities can verify compliance themselves at any time. There should be no barriers here. Why this is also a sacred space issue. Cemeteries are sacred regardless of a visitor's religion, meant to offer peace and tranquility, and dedicated in perpetuity to honor, remembrance, and love. A 100-foot industrial AT&T cell tower this close to graves and mourners intrudes on that purpose and raises serious concerns about exposure and potential harm to people and animals. My requests: • Update RF exposure limits based on a comprehensive review of current science, including but not limited to long-term, cumulative, and non-thermal effects, with specific protections for children, pregnancy, and vulnerable people. • Establish wildlife and environmental exposure standards, make them publicly accessible, and enforce them. • Modernize compliance testing and require public, independent post-installation testing. • Require easily accessible public records of tower locations, measurements, compliance, and complaints. • Adopt protective siting policies for sensitive places such as homes, schools, and cemeteries, and require disclosure of burial grounds and historic sites when towers are proposed. • Provide free advocates for the public to use to educate and support them in fighting for RF safety when necessary. • Stop giving away local control in cell tower permitting. Allow local jurisdiction and the public to decide if a cell tower siting plan is legal and appropriate and disallow it when necessary. • Support the retraction of permits when a cell tower or antennae modification application provides false information or omits information that is required for a complete application for consideration. I am not against cell towers. I support responsible telecommunications infrastructure and advocate for the safe, lawful, legal, ethical, and appropriate placement of cell towers. Not here. Not in an active, historic cemetery. Not among our beloved dead and those who come to mourn them. Thank you.

I am the Board Secretary of the nonprofit, Community and Friends of Seattle-Tacoma Pet Cemetery, a 501(c)(3) nonprofit. I submit these comments as an individual, not on behalf of the organization. I am a community member and advocate who is directly affected by a 100-foot industrial AT&T cell tower sited in a historic human and pet cemetery, and I write from firsthand experience. I have followed the permitting and legal record closely. The situation. The historic Seattle-Tacoma Pet Cemetery est. 1950 on Kent's West Hill is located in unincorporated South King County, Kent, Washington, in a community of color, immigrants, refugees, and low-income households. Humans, pets, K-9 officers, and service animals are buried here, some as whole families. Many cultural traditions exist here. In Indigenous cultures and spiritual traditions, animals are regarded as equally important as humans, deserving of the same dignity, honor, and respect in life and death. I hold that humans and animals call for the same and equal respect in life and death. In 2020, during the COVID-19 pandemic, Crown Castle installed a 100-foot industrial AT&T cell tower inside active Burial Block 13 with graves and mourners and 115 feet from neighboring homes in opposition to cemetery patrons, neighbors, and community members at large. It was installed in the wrong zone without a conditional use permit, in violation of King County Code and Washington State cemetery law. Additionally, Crown Castle did not disclose the human burials or the cemetery's historic significance on its permit application, and the project was pushed through the King County Department of Permitting and Environmental Review without addressing them. I have opposed its placement and operation since 2019. Why this matters to the issues before the Federal Communications Commission (FCC). The FCC is open to public comments for Cell Phone and Wireless Radio Frequency Radiation (RF) Health Effects and other Non-ionizing Electro Magnetic Frequency (EMF). I am talking about RF in this comment because that is the issue in the situation. The FCC's standards are the primary protection communities have against radio frequency radiation (RF) exposure. Under federal law, local governments generally cannot deny a cell tower based on RF health effects when it meets FCC limits. However, it is my understanding that communities can raise health concerns alongside other legitimate issues, such as zoning, permitting requirements, human remains, historic significance, etc. Our cemetery case involves all of these concerns. We should have the right to raise RF health concerns independently, without having to rely on other grounds for objection. If the FCC's standards are outdated, communities have limited recourse to protect residents, mourners, and their loved ones from potential RF exposure risks. Changes since 1996. The limits predate smartphones, small cells, etc., and constant connectivity. Towers now stand close to where people live and grieve, and people spend long periods near them. I ask the Commission to evaluate whether 1996 limits account for the ways that cell phones, cell towers, and the like are used and installed today including but not limited to chronic, daily, close-range RF exposure. Children and vulnerable people. Children live in the homes near this tower and visit the cemetery with their families. The record includes research showing children absorb more RF energy than adults (e.g., Fernández et al., 2018, Environmental Research). I ask the Commission to address children, pregnancy, and medically vulnerable people specifically. Additionally on the topic of children, as a public schools educator, board certified in special education, and again submitting this comment as an individual, I am against cell phone towers on near schools because they raise valid safety concerns for children and the staff that work with them. Research notes that children absorb more radio-frequency radiation due to their developing bodies which exposes them to long-term health problems such as cancer and neurological symptoms. (https://ehsciences.org/addressing-cell-towers-at-schools-science-based-policy-health-risks/) Long-term and non-cancer effects. The Commission should examine long-term, low-level exposure and non-cancer effects, including neurological, reproductive, and developmental effects, oxidative stress, and DNA damage, rather than relying on short-term heating thresholds. Animals and the environment. Pets, K-9 officers, and service animals are buried here, and wildlife lives on the grounds. The FCC has no wildlife-specific exposure limits. I ask the Commission to consider the research on effects on animals, insects, birds, and plants (e.g., Levitt, Lai & Manville, 2022, Reviews on Environmental Health, Parts 1–3). Testing and compliance. I ask the Commission to require independent, post-installation RF testing with public results that are easily accessible, so communities can verify compliance themselves at any time. There should be no barriers here. Why this is also a sacred space issue. Cemeteries are sacred regardless of a visitor's religion, meant to offer peace and tranquility, and dedicated in perpetuity to honor, remembrance, and love. A 100-foot industrial AT&T cell tower this close to graves and mourners intrudes on that purpose and raises serious concerns about exposure and potential harm to people and animals. My requests: • Update RF exposure limits based on a comprehensive review of current science, including but not limited to long-term, cumulative, and non-thermal effects, with specific protections for children, pregnancy, and vulnerable people. • Establish wildlife and environmental exposure standards, make them publicly accessible, and enforce them. • Modernize compliance testing and require public, independent post-installation testing. • Require easily accessible public records of tower locations, measurements, compliance, and complaints. • Adopt protective siting policies for sensitive places such as homes, schools, and cemeteries, and require disclosure of burial grounds and historic sites when towers are proposed. • Provide free advocates for the public to use to educate and support them in fighting for RF safety when necessary. • Stop giving away local control in cell tower permitting. Allow local jurisdiction and the public to decide if a cell tower siting plan is legal and appropriate and disallow it when necessary. • Support the retraction of permits when a cell tower or antennae modification application provides false information or omits information that is required for a complete application for consideration. I am not against cell towers. I support responsible telecommunications infrastructure and advocate for the safe, lawful, legal, ethical, and appropriate placement of cell towers. Not here. Not in an active, historic cemetery. Not among our beloved dead and those who come to mourn them. Thank you.

I am the Board President of the nonprofit, Community and Friends of Seattle-Tacoma Pet Cemetery, a 501(c)(3) nonprofit. I submit these comments as an individual, not on behalf of the organization. I am a community member and advocate who is directly affected by a 100-foot industrial AT&T cell tower sited in a historic human and pet cemetery, and I write from firsthand experience. I have followed the permitting and legal record closely. The situation. The historic Seattle-Tacoma Pet Cemetery est. 1950 on Kent's West Hill is located in unincorporated South King County, Kent, Washington, in a community of color, immigrants, refugees, and low-income households. Humans, pets, K-9 officers, and service animals are buried here, some as whole families. Many cultural traditions exist here. In Indigenous cultures and spiritual traditions, animals are regarded as equally important as humans, deserving of the same dignity, honor, and respect in life and death. I hold that humans and animals call for the same and equal respect in life and death. In 2020, during the COVID-19 pandemic, Crown Castle installed a 100-foot industrial AT&T cell tower inside active Burial Block 13 with graves and mourners and 115 feet from neighboring homes in opposition to cemetery patrons, neighbors, and community members at large. It was installed in the wrong zone without a conditional use permit, in violation of King County Code and Washington State cemetery law. Additionally, Crown Castle did not disclose the human burials or the cemetery's historic significance on its permit application, and the project was pushed through the King County Department of Permitting and Environmental Review without addressing them. I have opposed its placement and operation since 2019. Why this matters to the issues before the Federal Communications Commission (FCC). The FCC is open to public comments for Cell Phone and Wireless Radio Frequency Radiation (RF) Health Effects and other Non-ionizing Electro Magnetic Frequency (EMF). I am talking about RF in this comment because that is the issue in the situation. The FCC's standards are the primary protection communities have against radio frequency radiation (RF) exposure. Under federal law, local governments generally cannot deny a cell tower based on RF health effects when it meets FCC limits. However, it is my understanding that communities can raise health concerns alongside other legitimate issues, such as zoning, permitting requirements, human remains, historic significance, etc. Our cemetery case involves all of these concerns. We should have the right to raise RF health concerns independently, without having to rely on other grounds for objection. If the FCC's standards are outdated, communities have limited recourse to protect residents, mourners, and their loved ones from potential RF exposure risks. Changes since 1996. The limits predate smartphones, small cells, etc., and constant connectivity. Towers now stand close to where people live and grieve, and people spend long periods near them. I ask the Commission to evaluate whether 1996 limits account for the ways that cell phones, cell towers, and the like are used and installed today including but not limited to chronic, daily, close-range RF exposure. Children and vulnerable people. Children live in the homes near this tower and visit the cemetery with their families. The record includes research showing children absorb more RF energy than adults (e.g., Fernández et al., 2018, Environmental Research). I ask the Commission to address children, pregnancy, and medically vulnerable people specifically. Long-term and non-cancer effects. The Commission should examine long-term, low-level exposure and non-cancer effects, including neurological, reproductive, and developmental effects, oxidative stress, and DNA damage, rather than relying on short-term heating thresholds. Animals and the environment. Pets, K-9 officers, and service animals are buried here, and wildlife lives on the grounds. The FCC has no wildlife-specific exposure limits. I ask the Commission to consider the research on effects on animals, insects, birds, and plants (e.g., Levitt, Lai & Manville, 2022, Reviews on Environmental Health, Parts 1–3). Testing and compliance. I ask the Commission to require independent, post-installation RF testing with public results that are easily accessible, so communities can verify compliance themselves at any time. There should be no barriers here. Why this is also a sacred space issue. Cemeteries are sacred regardless of a visitor's religion, meant to offer peace and tranquility, and dedicated in perpetuity to honor, remembrance, and love. A 100-foot industrial AT&T cell tower this close to graves and mourners intrudes on that purpose and raises serious concerns about exposure and potential harm to people and animals. My requests: • Update RF exposure limits based on a comprehensive review of current science, including but not limited to long-term, cumulative, and non-thermal effects, with specific protections for children, pregnancy, and vulnerable people. • Establish wildlife and environmental exposure standards, make them publicly accessible, and enforce them. • Modernize compliance testing and require public, independent post-installation testing. • Require easily accessible public records of tower locations, measurements, compliance, and complaints. • Adopt protective siting policies for sensitive places such as homes, schools, and cemeteries, and require disclosure of burial grounds and historic sites when towers are proposed. • Provide free advocates for the public to use to educate and support them in fighting for RF safety when necessary. • Stop giving away local control in cell tower permitting. Allow local jurisdiction and the public to decide if a cell tower siting plan is legal and appropriate and disallow it when necessary. • Support the retraction of permits when a cell tower or antennae modification application provides false information or omits information that is required for a complete application for consideration. I am not against cell towers. I support responsible telecommunications infrastructure and advocate for the safe, lawful, legal, ethical, and appropriate placement of cell towers. Not here. Not in an active, historic cemetery. Not among our beloved dead and those who come to mourn them. Thank you.

This issue matters to me personally: The most safe eletromagnetic radiation (EMR) is 1.0 uw/m2 according to the Building Biology Institute (BBI) but can be workable in the day time only up to 10.0 uw/m2 maximum. Therefore, anything beyond is a detriment to thriving and wellness. Of the 4 EMR frequencies I am only speaking of the radio frequency (RF) today. I had an event where I had to sit on my analog water meter out in the hot FL sun to preserve it or get regularly radiated my a nearby cell tower of 1K uw/m2, which could be inappropriately changed without notice. It was totally detrimental and unsafe for me. The whole event was very scary with 3 men towering over me, while I was on the ground, including a sheriff that I said to all do not touch me being a small, slight woman. It was very stressful, disturbing and fortunately being informed ahead of time I was at home. They attempted to talk me into moving but I did not and they eventually left. Gratefully I still have that analog meter, which the water company physically reads and bills as usual. I am asking: 1.That these EMR responsibilities be taken over my appropriate departments, such as the U.S Deptment of Health and Human Services, which contain doctors, health practitioners, building biologists, electrical engineers and the like who have expertise in these areas without prejudice and are regularly audited. 2.That with decades of evidence of harm it very overdue to upgrade the carcinogenic grade level of EMR to Definitely Carcinogenic or may be even worse than that. 3.That everyone needs to be educated, trained and simply explained with proof to turn off RF at night, keep devices off your body and hard wire all devices at a minimum. 4.That with the RF boundary-less invasion through over densification of cell tower RF and surveillance that need to be re-purposed to emit healthful, rejuvenating output. Here is one study I believe the FCC should review when addressing the concerns about wireless radiation: Panagopoulos et al. (2021): Human-made electromagnetic fields: Ion forced-oscillation and voltage-gated ion channel dysfunction, oxidative stress and DNA damage – Reviewed evidence and proposed mechanisms linking human-made electromagnetic fields to oxidative stress, DNA damage, and cellular dysfunction. I urge the FCC to give meaningful consideration to the experiences and evidence before it and to fully address each of the issues identified by the court.

Re: FCC Seeks Comment on RF Exposure Issues Subject to D.C. Circuit Remand in Environmental Health Trust v. FCC - ET Docket No. 13-84 I am writing regarding the FCC’s response to the D.C. Circuit Court of Appeals’ remand concerning its decades-old radiofrequency (RF) radiation exposure guidelines. This is my second comment and the next several paragraph's are the same as yesterday's. The Court directed the FCC to explain its determination that FCC guidelines adequately protect humans against harmful effects of RF radiation unrelated to cancer. Specifically, the court required the FCC to address the impacts of RF radiation on children, the health implications of long-term exposure using wireless devices and technological developments, environmental impacts, and the adequacy of the FCC’s testing procedures for cell phones and other portable devices. The FCC should fully consider evidence from those of us who have suffered harm from the accumulative effects of RF radiation along with the environmental impacts of wireless radiation, including non-cancer health effects, impacts on children, long-term and cumulative exposure, cancer, and impacts on wildlife and the environment. I believe the FCC should review the following study to address the concerns regarding wireless radiation because my sibling and I both suffer from neurological effects, oxidative stress, probably DNA damage if we can get tested and electromagnetic sensitivity and I have witnessed many of the same symptoms in other families in my community who suffer from EMR Syndrome: BioInitiative Report (2012, with Subsequent Research Updates): Updated Research Summaries – Collection of scientific research concerning neurological effects, oxidative stress, DNA damage, genetic effects, and electromagnetic sensitivity. Individual summaries have different update dates, including 2022. Updated Research Summaries Updated Research Summaries 2022 Updated Research Summaries (May 2022) These are invaluable sets of abstracts and tables covering the RFR... MY STORY CONTINUED: Another expense I will now incur is restating my Living Trust and specifically my Special Needs Trust for my sibling. I am now sailing into unchartered waters as I navigate options, along with an attorney, that should something happen to me, my sibling needs to remain in my shielded home and shielded car. I need to be able to sleep at night knowing she will be protected because there are no words to describe how devastating the ill-effects of RF radiation on the body really are. Even though my older car has RF blocking window film on it and although the RF signal is lower inside my car going from "extreme" on the outside of the vehicle to "high" on the inside of the vehicle in my driveway which, then of course the signal fluctuates driving through different neighborhoods, I still have a high magnetic field inside my car confirmed by my building biologist with his specialized and more sensitive meters. As an amateur, I detect the magnetic field using my TriField EMF meter TF2. Approximately three weeks ago, I realized the roof of my mouth was throbbing every time I was driving but then realized the throbbing stopped every time I got out of my vehicle so we are still being effected by RF radiation even with RF window film shielding. This might explain the excessive bony overgrowth in my upper mouth and a possible link with tooth crowns that I will be researching next and am out of time today. Wanted to mention for others to consider. Prior to the roll-out of 5G my sibling was beaming from ear to ear on a daily basis and couldn't wait to get out of bed daily as we both were living life to the fullest with a huge support system. Daily, she would ask where we were going and what would we be doing that day. Now daily she asks what we're going to watch on TV all day long. My sibling just started in-home PT because she hasn't been to the gym in almost 2.5 years and her body is very stiff but there is a limit on the number of covered home visits. An at home, personal trainer is too expensive and not covered by insurance. It's too hard for me to train her. We don't even get to use our Medicare Advantage plans free gym membership(s) anymore when we need it the most. How are we expected to go to the DMV (Department of Motor Vehicles) in person when or if required, social security office if needed, nursing homes (hard time visiting our mom in 2023 before she died) with RF radiation, smart TV's and staff cell phones, i-watches, riding with a tow truck driver should our car need towing, could possibly drive somewhere for a day outing but can't stay in hotel or motel, I could camp or ideally backpack but my sister can't, financial institutions and most importantly, health care settings especially hospitals? We need solutions. We are equally as important as anybody else. Questions/Comments: 1. I was able to opt-out of both electric and gas RF radiation smart meters that humans are getting sick from. I would like the FCC to provide a way for those affected, to "opt-out" of 5G, RF radiation that's making us sick. 2. Why would I spend approximately $100,000,00 from my retirement IRA instead of "paying off my mortgage" if RF radiation wasn't making me too sick to live inside my own home? 3. Why are there over approximately 100 non-profits challenging and/or bringing awareness to 5G radiation if it wasn't a danger to human health and probably all living species' health? 4. I used to have an abundance of bees on my property. Now I don't. Why? 5. Why are so there so many excellent and reputable companies selling EMF protection to shield your house and body from 5G, RF radiation if it wasn't a danger to human health? Thank you excellent companies. 6. On the flip side, why are there so many "online predators" taking advantage of those of us with EMR Syndrome claiming their products will protect us from RF radiation? I was forced to spend approximately $100,000.00 incrementally, over the last many years to protect my families health because the FCC failed to protect me and my sibling's health from the harmful effects of RF radiation. As a "non-licensed" agency in regards to medicine, biology and public health, the FCC must not assert authority over RF exposure standards. I urge the FCC to recognize the critical role of federal health agencies, including the U.S. Department of Health and Human Services, and to rely on appropriate health and biological expertise when addressing the issues identified by the court. I urge the FCC to consider the real-life experts which are those of us suffering from bodily and financial harm from RF radiation and to completely address ALL issues identified by the courts. The evidence is clear that the FCC needs to change it's rules and protect human health. Our lives matter and so do your lives and your families lives. Thank you.

I reside in Lewis County, Washington. I did not consent, nor do I consent today, to the continuous, involuntary exposure to pulsed modulated, biologically active electrical and radiofrequency / microwave (RF/MW) radiation. The health effects of such have been widely studied by government agencies including from the US Navy in 1972 and by thousands of scientists worldwide. You need only look so far as the International Appeal to Stop 5G on Earth and in Space which was signed by over 24,000 professionals demanding a response to what can only be called a crisis brought on by lack of proper public policy on wireless technology. Dr Martin Pall, Professor Emeritus from Washington State University, has studied the effects of RF on the body. His work shows that RF radiation causes oxidative stress and leads to the depletion of glutathione which is critical in melatonin production. His overall assessment is that the damages caused by RF radiation are causing a tidal wave of dementia which we are seeing at earlier and earlier ages. I lost my mother, my mother-in-law, my 64 year old sister-in-law, two uncles and now my own husband is in Stage 5 early onset Alzheimers at age 67. This is not genetic. My father died in 2017. He had spent his last few years unable to sleep. My Mom's memory started failing in the early 2010's. I believe both my parents suffered from the installation of a smart meter as neither had a cell phone and they did not have wifi. As a normal consumer and well educated professional, I did not have any clue that the tech I was using in my work and personal life could be harmful. In 2010, the time of the installation of the smart meter on my home in Oregon, I became unable to sleep and became extremely anxious and depressed. These are symptoms caused by exposure to pulsed radiofrequency radiation. I'd get what felt like restless leg syndrome but all over my body. It turns out that response was from an increasing sensitivity to all electronics. The trigger was the new smart meter. At the time, I did not know what was causing my symptoms. I went to my doctor and sought treatment. I'm now on SSDI. I spent two years trying to treat a mental health condition that only existed as the result of the exposure to EMF to which I'd become increasingly sensitive. And the medication could not help an ongoing toxic exposure. It was adding another biological insult to one of the very systems that's electrical in nature and that's damaged by EMF exposure - the nervous system. By 2015, I'd lost the ability to read more than a few paragraphs and I struggled to write my own name. The fatigue was so bad that when I went shopping for groceries, I had to hold onto the cart just to get around the store. At age 46, I had people stop me and ask if I was OK. Any stress resulted in extreme outbursts as EMF exposure symptoms include irritability which isn't surprising because when your body is under constant assault, you are in a high cortisol state. In 2017, we moved to a rural community where I thought I'd be safe. We had no wireless devices. The smart meter was only the kind that could be read once a month by a truck when they drove by taking readings. My health improved. But in 2024, the meters were changed to a constantly pulsing type and my health became absolutely devastated once again. I became unable to leave my home. After a few months, we removed the meter but the damage was done. I'd become so sensitive to all EMF fields, I could no longer tolerate my own home. I moved my old motorhome to my pasture where I measured the lowest fields (RF, AC and magnetic) and I lived out there without running water and with little electricity. After several months, I made the difficult decision to move again which meant packing all of our belongings by myself as my husband could not remember if he was packing or unpacking a box. The process of even looking for another home was so brutal, I had to be helped out of many homes. Because every county surrounding me had moved to smart meters for power, I could not properly evaluate other fields. I finally gambled and settled. Here we pay $35/month for the privilege to not be irradiated by our meter. I still often sleep in the motorhome. My symptoms include burning sensations, screen dermatitis, dizziness, heart palpitations, chronic insomnia, cognitive fog, extreme fatigue, irritability and an inability to concentrate. I have debilitating digestive issues I believe are being caused by over exposure when I do try to live like a normal human being. Everyone including Social Security is now requiring a cell phone for identity verification to access services online. I find it repulsive to have to pay for the technology that's destroying everything I love including me. Technology that is offensive biologically and disabling to a human being should not be a mandatory exposure by design of our infrastructure.

Today we know that physiological behaviour is far more nuanced than was realized when the radiation standards were created in the 90s. There are several avenues of causation possible beyond just that resulting from DNA's heating of the human tissue. This can include damage directly from the radiation that impact the electromagnetic interactions of enzymes and/or nucleotides with their substrates without heat being involved, not to mention the possibility of radiation creating stress inflammatory cytokines without heat being the causative etiology. Ample evidence of this possibility is present in tissue culture and animal models. Moreover, the chronic exposure to the radiation over time has not even begun to be evaluated (cell phones held against the heart or brain, cell towers, etc.) The standards from the 90s are absurdly outdated when you consider the mass exposure of ever larger amounts of radiation that your constituents are being exposed to. Studies are needed but their results wouldn't be known for years. First do no harm.