Cancer & tumors

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 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 determination that its 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, the ubiquity of wireless devices and technological developments, impacts on the environment, and the adequacy of the FCC’s testing procedures for cell phones and other portable devices. The FCC should fully consider evidence and real-world experiences concerning the health and 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. Here is just one study I believe the FCC should review when addressing the concerns about wireless radiation: McCredden, McLean, and Steinenmann (2026): Wireless sensitivities and comorbidities: A prevalence study of co-morbidities in Canada, Australia, and the United States Although this study does not establish causation, I believe the information gathered raises enough red flags to warrant further investigation of both the thermal and non-thermal effects of electromagnetic fields. These studies are crucial for studying its impact on both the human population and the environment. The FCC is not a health agency and does not have expertise in medicine, biology or public health. Yet, the agency continues to assert authority over RF exposure standards and is preparing to reach conclusions about whether its existing guidelines adequately protect the public. 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. This issue matters to me personally. I have always been sensitive to electromagnetic frequencies. I first noticed it as a child when we would drive under high power electrical wires. I would feel “pressure” or pain in my head and chest. Decades later, as cell towers started to be constructed, I noticed increased intensity and headaches when within a certain range of cell towers. In 2012, while vacationing at a resort that was in close proximity to a cell tower, I ended up in the emergency room with chest pain. They found trace levels of troponin in my blood and a cardiac catheritization was performed. I was 44 years old and otherwise healthy. Around the same time, I started to have symptoms when near Wi-Fi and security systems, while holding a cell phone next to my head, when wearing wireless headphones, and when using Bluetooth in my car. Now, with 5G expansion, satellite technology, and increased security systems, my symptoms have increased tremendously and are often unbearable. There is frequent ringing in my ears, headaches, chest pressure, shortness of breath, and extreme fatigue. I find that it is especially bad on overcast days. 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. People should always come before profits!

Please address the concerns about cancer and reproductive toxicity that are raised in Melnick R and Moskowitz J, Exposure limits to radiofrequency EMF do not account for cancer risk or reproductive toxicity assessed from data in experimental animals. Please take account of Mevissen et al. Effects of radiofrequency electromagnetic field exposure on cancer in laboratory animal studies, a systematic review.

PUBLIC COMMENT TO THE FEDERAL COMMUNICATIONS COMMISSION ET Docket No. 13-84 Submitted by: Direct Energy Weapons Agency, Inc. Date: October 20, 2026** 1. Introduction Direct Energy Weapons Agency, Inc. sincerely thanks the Federal Communications Commission (FCC) for inviting public participation in its review of radiofrequency (RF) exposure standards, testing procedures, and potential health effects. Incorporated in 2021, our organization provides advocacy, education, and incident-documentation services for civilians reporting unexplained physical and neurological symptoms they believe may involve directed-energy, radiofrequency, electromagnetic, or acoustic energy exposure or assault. We support technological innovation while believing that public safety protections must advance alongside wireless technology. 2. Our Experience Our organization began receiving civilian incident reports because people repeatedly told us they could not find an agency willing to document their experiences. We could not stand by while Americans were suffering and feeling that their country did not care. Despite limited resources and no permanent physical investigation facility, we established procedures to receive complaints, conduct case reviews, and prepare incident reports. Approximately 1,000 civilians throughout the United States have submitted incident reports to our organization. Complainants describe unexplained pain, burning sensations, vibrations, pressure, sleep disturbances, unusual sounds, and other physical and neurological symptoms. Complainants stated in their reports that they have no mental health conditions and that their injuries are often misdiagnosed. Some believe remotely operated, wall-penetrating energy technologies are responsible for their experiences. Others report electronic intrusion, unwanted communications, and possible technology-assisted harassment. These reports do not independently establish RF exposure, identify particular devices, or confirm the cause of symptoms. However, they highlight concerns deserving appropriate scientific and medical evaluation. We have contacted federal security and investigative agencies requesting assistance with these reports but have not received a substantive response. 3. RF Exposure Standards and Testing We encourage the FCC to carefully review whether existing RF exposure limits and testing procedures adequately address today's wireless environment. This includes widespread mobile-device use, multiple sources of RF exposure, emerging wireless technologies, and potential health effects associated with long-term exposure. Special consideration should be given to children, who may experience many years of wireless technology use beginning at an early age. We encourage the FCC to examine reliable scientific research concerning possible non-cancer health effects and determine whether existing testing procedures adequately protect the public. We ask that conclusions be based on reproducible scientific evidence, with clear explanations of the strengths and limitations of available research. 4. Public Safety and Consumer Protection The advancement of wireless communications makes public safety, accountability, and consumer protection increasingly important. We encourage clear federal guidance on RF exposure standards, compliance requirements, and safe wireless-device operation. Our organization has also received reports from civilians who describe hearing external sounds, voices, or communications without being able to identify their direction or source. Directional speakers and Long Range Acoustic Devices (LRADs) demonstrate that sound can be projected toward particular areas or listeners over distances. These reports do not establish that acoustic devices caused the experiences described. However, they raise concerns about the need for appropriate technical and medical evaluations. An unexplained auditory experience should not automatically be classified as either a mental health condition or evidence of technological harassment. We encourage appropriate federal agencies to examine safeguards against the intentional misuse of acoustic technologies to threaten, intimidate, or harm men, women, or children. 5. Recommendations We respectfully request that the FCC: 1. Review existing RF exposure limits and portable-device testing procedures using reliable scientific evidence. 2. Evaluate scientific findings concerning potential non-cancer health effects and long-term RF exposure, particularly involving children. 3. Consider whether current testing procedures adequately reflect widespread wireless-device use and technological advancements. 4. Strengthen public education concerning RF exposure standards, regulatory compliance, and consumer protection. 5. Coordinate with HHS and appropriate federal agencies regarding RF exposure research, public health concerns, and safety standards. 6. Provide clear procedures for reporting suspected violations of FCC regulations and referring matters outside the Commission's authority to appropriate agencies. 6. Closing Statement The United States is a world leader in wireless technology. We believe it should also lead in public safety, responsible regulation, and consumer protection. People are asking for answers. They deserve credible scientific information, appropriate medical attention, and meaningful consideration of their reported experiences. We encourage the federal government to examine whether existing criminal laws adequately address the intentional misuse of emerging technologies to harm, threaten, or harass individuals. DEW Agency welcomes opportunities to collaborate with appropriate federal agencies and provide civilian triage services, including receiving complaints, documenting incidents, identifying urgent needs, and referring individuals to qualified authorities. We respectfully request consideration of our organization's experience and willingness to assist with civilian reporting and referral efforts. Thank you for this opportunity to contribute to an important national public safety discussion. Respectfully submitted, Direct Energy Weapons Agency, Inc Ms. Mechael Wright-Hodges, Founder and Executive Director Website: www.DEWAgency.org Telephone: 781-561-8753 Email: info@dewagency.org

In 2016, I developed EMF hypersensitivity (EMR Syndrome) shortly after being exposed to 5 electrical and another 5 gas smart meters on my apartment bedroom wall while living in California. I was also subjected to my neighbors' wifi signals and their cell phone transmissions, and lived within 900 feet of a cell tower. My symptoms included: brain fog, depression, leg cramps, insomnia, severe tinnitus, and skin cancer that required two surgeries to successfully remove. I purchased an EMF meter to read the radiation output, but could not get the levels down low enough to sleep in my bedroom, despite shielding the walls. Consequently, I was forced to sleep on my living room floor. My only remedy was to move to Oregon, where I could replace the smart meter with an analog one, use a copper landline for telephone calls, and completely hardwire my internet connection. Since then, most of my symptoms have disappeared except the tinnitus. However, despite all of the precautions I have taken to protect my health, I cannot spend time in a crowd of people using their cell phones, nor in a building bathed in wifi. I'm lucky that I know how to protect myself, but most people are unaware of the damage that EMFs are doing to their mental and physical health. I pray that you will see fit to reassess the danger of EMFs so that no one else will ever be subjected to the suffering that I've had to endure.

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

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 determination that its 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, the ubiquity of wireless devices and technological developments, impacts on the environment, and the adequacy of the FCC’s testing procedures for cell phones and other portable devices. The FCC should fully consider evidence and real-world experiences concerning the health and 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. Here is just one study I believe the FCC should review when addressing the concerns about wireless radiation: Morgan, Kesari & Davis (2014): Why children absorb more microwave radiation than adults: The consequences – Reviewed evidence that children may absorb more wireless radiation than adults due to anatomical and physiological differences, raising questions about the adequacy of existing exposure standards. The FCC is not a health agency and does not have expertise in medicine, biology or public health. Yet, the agency continues to assert authority over RF exposure standards and is preparing to reach conclusions about whether its existing guidelines adequately protect the public. 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 give meaningful consideration to the experiences and evidence before it and to fully address each of the issues identified by the court.

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.