Biological mechanisms & metabolism

My life has been horribly effected by wireless technology. The lives of millions of people are being harmed on a daily basis by today's wireless world. FCC's RF exposure guidelines for the omnipresence of wireless devices and technological developments were last updated in 1996. This is the same as thirty years ago that leaded gasoline was still considered OK. Thirty years ago cell phones were bulky, expensive devices primarily used for making calls and sending texts. The cell phones were so expensive very few people used them. Now, the world is full of wireless technology. The fact that the FCC has not updated the guidelines is the same as still allowing people to smoke in the neonatal (new babies) area of the hospital and on airplanes. It is vital to update the exposure guidelines. Please refer to 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. The FCC's job is to protect consumers. Currently consumers are being harmed on a constant basis by wireless technology. It is the FCC's job to fix this terrible problem.

The current limits on EMF/GSM-like RF exposure on the human population must be re-examined in light of the increasing use of cell phones, Wi-Fi, cell towers and small cells, smart meters, Bluetooth AirPods, 5G, and emerging 6G technologies. Children are reportedly especially vulnerable in that they absorb higher rates of RF radiation. More and more studies are confirming severe neurotoxic effects. See Neurotoxic effects of 3.5 GHz GSM-like RF exposure on cultured DRG neurons: a mechanistic insight into oxidative and apoptotic pathways. Bektas H, Seker A, Ustun R, Dogu S, 2026. The current limits relating to "heating tissue" are insufficient to protect the human population. I am requesting that the FCC conduct specific research on the true effects of radiation on humans, animals, and any living tissue. The ever increasing levels of radiation are deleteriously affecting all of us. I request that you take immediate action to protect us from further harm and institute truly safe limits.

I'm a very healthy and fit 71yo woman. I take a lot of precautions with regard to EMR exposure, however, the introduction of 5G has obviously been impossible to avoid in public spaces. I've had an unexplained rise in my Hemoglobin A1c, from 5.3 to 5.9 over the past few years. I don't have any risk factors for type 2 diabetes, so wonder if the beta cells in my pancreas are being negatively effected by 5G. I have 2 friends who are in their mid 60's who like me are very health conscious, lean, and fit. They do not take precautions with regard to EMR and both have HgbA1c's in the pre-diabetic range! What's going on in our environment? Please look into this potential connection. Thank you.

Children's schools should not be located near mobile phone towers or TV towers or electrical transmission power lines. And the powerful Wi-Fi routers often used in schools should not be near any children's desks. California officially issued guidelines advising of mobile phone dangers, warning of increased risk of brain cancer and other health problems, and that children’s developing brains could be at greater risk. The biggest source of RF exposure for most people is using a mobile phone next to the head. You can reduce RF exposure a lot by using the phone's speaker and holding the phone farther away from your head, or using wired headphones say neuro-oncologists & public heath experts. The city council in Berkeley California passed a law that requires retailers to tell consumers how far away their phone should be held. The European Union recommends wired Internet rather than wireless in schools. France also banned WiFi routers in nursery and daycare centers, and restricted elementary school WiFi to only when in use for education. The American Academy of Environmental Medicine (AAEM) states in an open letter to school superintendents, “There is a consistent, emerging science that shows people, especially children who are more vulnerable due to developing brains and thinner skulls, are being affected by the increasing exposure to wireless radiation.” In 2021 a New Hampshire report outlined health risks of cell phone towers in residential neighborhoods. Scientific American reported a study of mobile phone exposure and cancer in rats: www.scientificamerican.com/article/major-cell-phone-radiation-study-reignites-cancer-questions/ According to Dr. Joel Moskowitz (UC/Berkeley), "The study's results reinforce the need for more stringent regulation of radiofrequency radiation and better disclosure of the health risks associated with wireless technologies." Dr. Martha Herbert, a Harvard Pediatrician, wrote in this letter to Montgomery County Schools "there are thousands of papers...that document adverse health and neurological impacts of EMF/RFR"..."Radiofrequency electromagnetic radiation from wifi and cell towers can exert a disorganizing effect on the ability to learn and remember, and can also be destabilizing to immune and metabolic function"..."Powerful industrial entities have a vested interest in leading the public to believe that EMF/RFR, which we cannot see, taste or touch, is harmless, but this is not true". The American Academy of Pediatrics in 2013 requested a review of EMF radiation emissions from technology devices, citing impact on children. Some schools have reduced WiFi exposure of children: https://ehtrust.org/tag/wifi-in-schools/ https://www.mirror.co.uk/news/uk-news/school-wifi-networks-could-put-12602188 In 2011 the World Health Organization classified cell phones (and other wireless devices) as a possible carcinogen due to RF emissions. In 2013 Dr. Anthony Miller from University of Toronto School of Public Health recommended that based on new research, radio frequency (RF) exposure should be reclassified as a probable carcinogen. Regarding power lines: Researchers have found health effects, including a doubling of leukemia rates associated with living in AC magnetic field strengths greater than 4.0 mG. www.emfs.info/health/leukaemia/ www.powerwatch.org.uk/elf/overview.asp www.ncbi.nlm.nih.gov/pubmed/10944614 www.ncbi.nlm.nih.gov/pubmed/20877339 www.ncbi.nlm.nih.gov/pubmed/11055621 The Swedish National Energy Department issued an advisory warning that schools, playgrounds, and day-care centers should not be sited near power lines, and that children should not be subjected for long periods every day to AC magnetic fields over 3.0 mG.

I am writing to ask you to allow freedom of choice regarding the wireless, RF, and EMF radiation that is known to be dangerous to human health. The NIH has shown that these can cause DNA damage, especially in children. Here in Massachusetts, the utility companies charge residents several hundred dollars a year if they opt out of having a Smart Meter (RF radiation) mounted on their homes. These fees are unrestricted and can increase at the whim of the utility companies. This is wrong. I should not have to pay to keep RF devices off my home. Thank you for your consideration.

I have 2 grandchildren in public schools and am very worried about health radiation exposure from the wireless technology used in our schools. The risks include cancer (which is the 2nd cause of death in children). The core issue is that wireless technology was implemented, without consideration of the impact on human health, based on the 1996 FCC Regulation. Since then, new scientific studies have proven links to health risks from wireless radiation. I learned first-hand about illness from wireless exposure when I became ill in my own home. Having spent my career as a university librarian, I educated myself about this. The science points to strong associations between wireless radiation and multiple illnesses. The [U.S.] National Toxicology Program reports that wireless radiation causes DNA damage which results in cancer. Dr. Anthony Miller, former senior advisor to the WHO states that it should be promoted from 2B to 1A, a human carcinogen. In fact, this radiation is absorbed deeper into the bodies of children than into adults. The danger is not only in years to come, but NOW. For example, at Fay School in Southboro, MA, children exposed to Wi-Fi became ill with nose-bleeds, headaches, and nausea. The following steps should be implemented for schools: 1. Require that all computers within schools be hard-wired and eliminate wireless transmission. [This has already been done in Europe]. 2. To immediately minimize WI-FI signals, instruct school personnel to keep wireless routers and devices off when not in use. 3. Since funding may be a challenge, negotiate with the industry that brought in this toxic technology to subsidize the hard-wiring of school computer systems. Our children’s health should take top priority over corporate profit. 4. In addition to the many hours of exposure inside school, there is radiation from outside. Please oppose the installation of 5G antennas within a half-mile of school buildings [as has been done in Europe]. 5G increases radiation exposures manyfold, and at a crucial time of their development, children will be even more bombarded. Given that 1 in 3 people will develop cancer in their lifetime, please take action to protect ALL our children, teachers, and staff! [See sources below] Links to Health Effects of Wireless Radiation "Generation Zapped" https://generationzapped.com/watch-the-film/ Trailer to “Generation Zapped”: https://www.youtube.com/watch?v=Kj_30YDVkaI Understanding EMF's , including Impact on Children https://sites.google.com/site/understandingemfs/home Cell towers: https://sites.google.com/site/understandingemfs/cell-towers Childhood cancer rates by state: https://statecancerprofiles.cancer.gov/quick-profiles/index.php?statename=massachusetts Schools Banning Cell-Towers The Los Angeles Unified School District has adopted several Board resolutions that ban cell towers on or near schools: http://emrpolicy.org/news/headlines/29may09_lausd_press_release.pdf http://sunroomdesk.com/2009/12/10/lausd-calls-for-increased-setbacks-advance-notification-on-locations-near-schools/  See the Environmental Health Trust for information to provide schools: https://ehtrust.org/cell-tower-proposed-near-home-childs-school-need-scientific-resources-health-safety/ Jeromy Johnson, M.S. Engineering https://www.youtube.com/watch?v=F0NEaPTu9oI&t=11s Sharon Goldberg, M.D. https://www.youtube.com/watch?v=CK0AliMe-KA Environmental Health Trust https://ehtrust.org/science/whoiarc-position-on-wireless-and-health/ Huntington NY Accoustimeter measuring radiation from "small cells" https://www.youtube.com/watch?v=pcozqp5Op78 Children sickened from wi-fi at Fay School, Southboro, MA See https://www.boston25news.com/news/parents-say-schools-wifi-signal-making-son-sick-1/7363498 Major cities revolt against FCC’s proposed small cell deployment rules https://www.fiercewireless.com/wireless/major-u-s-cities-revolt-against-fcc-s-proposed-small-cell-deployment-rules "Burlington Union" report of Verizon's withdrawal of application for 7 "small cells" in Burlington, MA http://burlington.wickedlocal.com/news/20181026/verizon-withdraws-burlington-cell-tower-application Among children ages 0 to 14 years, it is estimated that, in 2018, 10,590 will be diagnosed with cancer and 1,180 will die of the disease (1). Among adolescents ages 15 to 19 years, about 5000 will be diagnosed with cancer and about 600 will die of the disease. https://www.cancer.gov/types/childhood-cancers/child-adolescent-cancers-fact-sheet Presentation by Cece Doucette at Burlington, MA Library https://www.youtube.com/watch?v=JX3DS6cK53Q&t=110s BCAT summary of Burlington presentation https://www.youtube.com/watch?v=2KyOzIyxRo8

Comment in Response to Public Notice DA 26-997, ET Docket No. 13-84 This comment addresses FCC’s methodological criteria for assessments of responses to the mentioned Public Notice as one may interpret from its questions in the FCC Public Notice page 7. These criteria are by and large those used by IEEE ICES and ICNIRP. The methodological criteria used by IEEE ICES and ICNIRP to identify thresholds for RF-EMF caused harmful health effects, are flawed – and so for several reasons detailed in referenced material: 1. At non-thermal levels, these standards explicitly restrict themselves to acute effects only, not accepting temporarily annoying effects as harmful effects (e.g., not tinnitus…), nor long term effects (e.g., not cancer, diabetes, …), and only effects objectively observable (e.g., not headache, nausea, , …). Effects have to be proven by research methods primarily appropriate for identifying thermal effects, even when effects are well demonstrated by acceptable methods not to be thermal. Research proving effects, but not using thermally based methods is regarded as no or poor evidence, hence dismissible. 2. Such thermal methodological criteria and stringent demands for proof may all be traced back to historical contexts of research on ionizing radiation effects and non-ionizing radiation’s thermal effects in which they are defensible. In the context of non-thermal effects of non-ionizing radiation they are not. However, they have been made part of standards in which they function as a bulwark against accepting any effects from RF-EMFs below thermal levels. Using such a thermal methodology produces conclusions of «no health effects found» as an artefact, i.e. as a result of the methodology as such, and is thus without any evidentiary power – just flawed. Such methodology also means dismissing a precautionary approach, as the scope is set far too restrictive. 3. The ICNIRP 2020 and ICES C95.1 2019 standards, by which, a.o., 5G deployment were legitimized worldwide, are based on research studies and assessments based on essentially these same methodological elements, and thus flawed, having no predictive value for non-thermal health risk identification. 4. The assessments carried out by WHO’s The International EMF Project in order to be used as a platform for RF-EMF standard revisions, have been required to use study protocols based on such thermally based methodology, and therefore flawed, too (apart for the one assessment which did not accept using such a thermal protocol). Details underpinning the statements above are found in the following scientific papers and responses to the FCC and HHS Request for Information: Nordhagen EK, Flydal E. WHO to build neglect of RF-EMF exposure hazards on flawed EHC reviews? Case study demonstrates how "no hazards" conclusion is drawn from data showing hazards. Rev Environ Health. 2024 Jul 10;40(2):277-288. doi: 10.1515/reveh-2024-0089. PMID: 38981511. Nordhagen EK, Flydal E. Self-referencing authorships behind the ICNIRP 2020 radiation protection guidelines. Rev Environ Health. 2022 Jun 27;38(3):531-546. doi: 10.1515/reveh-2022-0037. PMID: 35751553. Else K. Nordhagen, Einar Flydal, Cornelia Waldmann-Selsam, and Vibeke Frøkjær Jensen: Comment in Response to FCC Public Notice DA 26-997, ET Docket No. 13-84, Submitted Oct.20.2026. https://bit.ly/4i6XM0h Else Nordhagen, Vibecke Frøkjær, Einar Flydal, Cornelia Waldmann-Selsam, Fiorella Belpoggi: Quality criteria for RF/EMF Health-Risk Assessments, Essential Criteria for Assessing Health Risks from Wireless Radiation, Response to HHS Request for Information, Submitted Oct.20.2026. https://bit.ly/3UCWjFO It follows that the methodology used to assess RF-EMF health effects should be thoroughly revised. As shown in the mentioned references, more relevant methodological frameworks for assessments do exist. Signed by Einar Flydal Oslo, Norway, Oct. 20, 2026 Einar Flydal is a Master of political science from the University of Oslo, Norway, and Master of Telecom Strategy and Technology Management from the Norwegian Polytechnical University (NTNU), Trondheim, Norway. Before retiring, Flydal was a Senior Researcher at Telenor Research & Development. He has also served as a Senior Strategy Adviser in the Telenor corporate management, and, a.o., as adjunct assistant professor at NTNU. Since 2010, he has studied and published, first and foremost for the general public in Scandinavia, on EMFs, health and environmental impacts. He chaired the Norwegian mirror commitee of the development of the ISO 26000 standard on the social responsability of organizations.

Federal Communications Commission (FCC) Public Comment on Reopened Docket Regarding Wireless Radiation Safety Limits Dear Commissioners, As a deeply concerned citizen who values both technological innovation and the health of my family, I am writing to urge the FCC to completely overhaul its outdated radiofrequency (RF) radiation exposure guidelines. The current standards, established decades ago, rely exclusively on preventing thermal (heating) harm. However, as an everyday user watching our children grow up surrounded by a 24/7 blanket of Wi-Fi, cell towers, and smart infrastructure, I know that our constant, real-world exposure looks nothing like the brief laboratory simulations used to set these guidelines. In my own home, I have taken steps to hardwire our internet connection to protect our sleep and focus, but we cannot escape the dense web of neighborhood cell towers outside our home and when visiting the towns and cities. The D.C. Circuit Court correctly ruled in 2021 that the FCC failed to address severe gaps in its safety logic. I urge you to look at the independent, peer-reviewed data disproving the assumption that non-thermal radiation is harmless: • Definitive Evidence of DNA Damage: The U.S. National Toxicology Program (NTP) comprehensive $25 million study proved that chronic exposure to cell phone radiation causes significant, measurable DNA damage—specifically in the frontal cortex and hippocampus—as well as clear evidence of rare malignant tumors. DNA damage occurs without any tissue heating, directly undermining the FCC's regulatory foundation. • Unique Vulnerabilities of Children: Our children's skulls are thinner, and their nervous systems are still dynamically developing. Millions of students sit directly under powerful industrial Wi-Fi routers all day. Compiled data from the BioInitiative Report establishes that low-intensity, non-thermal RF radiation alters gene expression and triggers neurological impacts at levels far below current FCC limits. • Environmental and Wildlife Disruption: Our ecosystem is suffering the collateral damage of unchecked wireless infrastructure. Multi-author analyses show that continuous RF radiation alters biological rhythms, disrupts the navigation patterns of crucial pollinators like bees, and inflicts oxidative stress on local flora and fauna. The FCC must stop deferring to industrial convenience and prioritize living biology. I ask that you adopt protective, biologically-based exposure standards that reflect the independent science of today. Sincerely, Marcia Keizer Yelm Washington

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.

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. The Court directed the FCC to provide a reasoned explanation for its decision that its guidelines adequately protect humans against the harmful, non-cancer-related effects of radiofrequency radiation. Specifically, the Court required the FCC to address the effects of radiofrequency radiation on children, the health consequences of prolonged exposure, the ubiquity of wireless devices and technological advancements, environmental impacts, and the adequacy of the FCC’s testing procedures for mobile phones and other portable devices. The FCC should carefully examine evidence and real-world experiences regarding the health and environmental impacts of wireless radiation—including non-cancer-related health effects, impacts on children, long-term and cumulative exposure, cancer, and effects on wildlife and the environment. Below is one study, among others, that I believe the FCC should review when addressing concerns related to wireless radiation: • Panagopoulos et al. (2021): Man-made electromagnetic fields: Ion-gated channel dysfunction, oxidative stress, and DNA damage—an examination of the evidence and proposed mechanisms linking man-made electromagnetic fields to oxidative stress, DNA damage, and cellular dysfunction. The FCC is not a health agency and possesses no expertise in medicine, biology, or public health. Yet, it continues to assert its authority over radiofrequency exposure standards and is preparing to conclude whether its current guidelines provide adequate protection for the public. I urge the FCC to recognize the essential role of federal health agencies—most notably the U.S. Department of Health and Human Services—and to draw upon appropriate expertise in the fields of health and biology to address the issues raised by the court. This matter is of particular personal concern to me because: For several years, I have suffered the consequences of exposure to electromagnetic waves; my health has been lastingly impaired (manifesting as chronic pain and severe sleep disturbances). I find it difficult to work in environments where such exposure exists; I can no longer travel by train due to the presence of Wi-Fi and passengers’ mobile phones; I cannot stay in hotels because of Wi-Fi; and my life has been significantly diminished by the omnipresence of these waves. I urge the FCC to give serious consideration to the experiences and evidence submitted to it, and to fully address each of the questions raised by the court.