Cancer & tumors

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

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

Biological health and safety must be accounted for when placing cell towers- currently it is not. The FCC is not a health and safety agency, nor are they versed in biological harms from exposure to RF EMF from wireless base stations and devices. I have been injured and have a medical diagnosis of injury and disability from exposure from RF EMF from a cell tower base station, and it has upended my life, given me migraine like blinding ice pick headaches, nausea, dizziness, palpitations, insomnia and forced me from my home, having to sleep in my car and in makeshift accommodation to avoid exposure to let my body recover. Those injured by cell towers and smart meters should not be considered "collateral damage" and "the cost of doing business" as we were called. Health and safety cannot be guaranteed, and this docket shows the science and mechanism of harm. Those sharing their stories are the evidence of this harm and we deserve to be protected, assisted and made whole. The FCC does not track those injured by wireless. There is no registry, no avenue for redress or avenue to be made whole. In our case, our home was rendered uninhabitable by our Board of Health due to the nuisance, toxin and hazard emitted from the wireless transmitting facility built at the top of our neighborhood. We have been in litigation for over six years, more recently in the Supreme Judicial Court, who less than three months ago ruled that a uniform network is more important than the health and safety of those living in communities with wireless base stations- despite the science, the testimony of our doctors and subject matter experts and our lived experiences of injury and harm. The FCC prevents health and safety from being considered when siting a tower- but what is worse is those injured once the tower starts transmitting have no recourse. In my neighborhood, a resident commented that when she learned about the tower she had no feelings either way, but started developing insomnia and headaches once it started transmitting. She spent time at her boyfriend's house not near a base station and the insomnia and headache resolved. She returned home and so did her symptoms. This was the story of so many of our neighbors who testified to our City Council, Board of Health and our legislators. Soon we learned this was the story of many communities and individuals who had a wireless facility constructed near them or on their apartment buildings or school. This is backed up by studies of symptoms near cell towers, which return to normal baseline levels of illness at around 1640 feet. The FCC has all of these studies on file and have had them for years and years. Yet no action has been taken. Yet the FCC argues this is safe because the levels measured in my neighborhood are a small percentage of the FCC's antiquated 1996 exposure standards based on 80's science before the smartphone was invented and before towers were widespread. We have literally testified next to wireless representatives that towers were meant to built on the sides of highways and mountain tops. Now they are being built 100 feet from our children's bedroom windows and our babies are sleeping with vomit buckets because they are being sick in the middle of the night, experiences rashes, headaches, insomnia and dizziness to the point they are walking into the wall- so ill that their teachers are commenting they can't focus or stay awake in class, that they are passing out when sitting under a wireless access point, that 911 is being called to take them to the hospital when exposed to the wireless after it was "turned up" to accomodate more devices. This is inexcusable that our lives, our children and seniors lives are being upended because of being made ill from wireless exposure. Those who are suffering are not invisible. The FCC needs to work with our physicians whose goal is to protect our health. Literally our doctors wrote that they swore an oath to protect health, and with these exposures they simply cannot do their jobs because constant, 24/7 ongoing exposure is in direct conflict with the precautionary principle. And we have moved far beyond precaution. When a tower is placed in your neighborhood and 17 people come forward formally and publicly, and several more come forward informally and everyone agrees that the harm is from the cell tower, but no one knows how to help because of the FCC's rules and standards, there is no recourse, no action, no accountability and no help for those sick, displaced, suffering and now disabled due to their exposure. Our only medical remedy and recourse is to reduce exposure, but when we live next to a tower that is transmitting 24/7, and the source of the injury, the only option we have is to move. Many of those retired, on a fixed income, low income, or families simply in this economy cannot move. The choice is our homes or our health. If we pick health, we have to find somewhere else to go without wireless. Our Boards of Health have advised not to mistake ubiquity with safety. Many of us injured must constantly advocate for disability accommodations both in school, in the workplace and in our community buildings like the library or City Hall. We must hire attorneys, provide medical documentation and go through the test of if the accommodation to have a low RF environment is reasonable or not. Not everyone can afford to do this process, and those who try are told the FCC binds their hands. We should not have to fight for safety in our own homes. Our houses should be safe. We should be able to follow our doctor's orders in our own homes. If someone is disabled and installs a ramp to access their home, no one should remove the ramp. Yet when a tower is placed next to our homes, the RF is trespassing onto our properties and into our bedrooms and creating an environment that triggers life altering symptoms and our homes are no longer healthy or safe. The wireless company has essentially removed our ramp and now we must struggle to access and function within our homes. RF EMF is a hazard, carcinogen, nuisance and toxin- and we do not consent to ourselves or our children or our neighbors being involuntarily exposed. Unlike other sources of wireless, we cannot turn this off, limit our exposure or put it on a timer. We have no power, no control, no say and no recourse and this must change. The FCC's goal is to roll out telecommunications infrastructure to ensure everyone has connectivity, but this should not continue to be done at the expense of everyday Americans' health, safety, homes, families, neighborhoods, communities or our well being. We love, use and depend on our technology. We've learned that to be healthy, we need to do this safely so we are not sick. Cell towers near homes, exposing children, seniors and vulnerable populations is simply not safe. The FCC needs to revisit section 704 of the Telecommunications Act to ensure health and safety is considered when siting towers, and that there is a accountability and action for those sick, displaced and suffering. Given everyone agrees the 877 South Street Pittsfield Verizon cell tower should be moved, and land owners have offered alternative locations, perhaps the FCC should have a fund for communities to relocate injurious towers to safer locations, or a program where the FCC intervenes when people are injured. All I know is that the more we share our story, the more people reach out to us with stories of their own of wireless harm. Every state has a group or an organization. Every community knows of someone impacted. We will keep asking for help until we can live safely, full time in our homes without symptoms of wireless exposure. Thank you for your attention and your timely action in creating remedies for those harmed, and preventing others from being harmed through updating the TCA to reflect the lived experiences of those injured, the science, medicine and NH Commision Report recommendations for cell tower and wireless safety. The work has been done and the solutions have been proposed. Please listen to these experts. With gratitude, Courtney

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.

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'm suffering from the emr-syndrome (electrohypersensitivity since 2020. When exposed to man-made electromagnetic fields, I experience the following problems: headaches, extreme fatigue, a sensation of being "electrified," cognitive difficulties, speech impairments—sometimes progressing to total aphasia—short-term memory issues, tremors and spasms, and tachycardia (at times so intense that it feels like a heart attack). I also suffer from joint and mobility issues, such as complete stiffness in my legs—to the point where I am almost unable to move—after a car journey or after remaining still in an environment where electromagnetic fields are present. Other symptoms include an urgent need to urinate every 15 minutes, immune system issues, sharp, highly painful stabbing sensations in various parts of my body, and muscle pain, feelings of nervousness, anxiety, and depression—with no apparent reason. When I am in a place free from electromagnetic waves, I feel perfectly well and all my symptoms disappear. I know a great number of persons who suffer from the same symptoms. I am in touch with patient organizations all over the world, and we can see that the phenomenon is the same everywhere. Even people who do not identify as having EHS (electromagnetic hypersensitivity) exhibit symptoms such as fatigue, insomnia, feelings of nervousness, anxiety, and depression. We can also observe that the number of children suffering from ADHD has increased at an alarming rate—as has the number of cancer cases, particularly among children, a increasing number of persons suffering from fibromyalgia, Alzheimer etc. Despite more than 50 international appeals from the independent scientific and medical community, our governments continue to push for ever-increasing wireless technology—a trend that is affecting a growing number of people. It is urgent to take measures to protect the entire population, especially the most vulnerable: those suffering from electrohypersensitivity, children, pregnant women, and the ill. The number of people with electrohypersensitivity who have died in recent years is alarming. Our lives are truly at risk; the symptoms are a form of torture, and we face a significantly higher risk of serious illnesses, including cancer, neurodegenerative diseases, cardiovascular conditions, and immune-system disorders. There are almost no places left where we can still find refuge. The situation has become untenable for us.