Court remand & agency accountability

The Peace Research Institute of Oslo, PRIO, provides in an article titled: Imagining War in the Neurotechnological Age: ‘We are entering a world, where technologies no longer simply threaten our bodies. They are directly affecting our minds’ (quoted in Evans, 2022). In this new neurotechnological age, which is characterized by a growing geopolitical neurobiological and Artificial Intelligence (AI) arms race (NSI, 2017a: 20), traditional concepts of war, security and peace are increasingly replaced by terms such as ‘cognitive warfare’ (NATO, 2021), ‘neurodeterrence’ (NSI, 2012: 50), and digital biosecurity” (Giordano and DiEuliis, 2021: 22). Just a few sources on this topic are accessible here: Imagining War in the Neurotechnological Age: https://www.prio.org/comments/1816 https://spectrum.ieee.org/neurotechnology-battle-for-your-brain https://www.darpa.mil/research/programs/next-generation-nonsurgical-neurotechnology https://mronline.org/2021/10/13/behind-natos-cognitive-warfare-battle-for-your-brain-waged-by-western-militaries/ As cited by Soucie v. David in a Third Circuit Court of Appeals case from 1970 that was presented in an effort at government disclosure: Congress passed the Freedom of Information Act in response to a persistent problem of legislators and citizens, the problem of obtaining adequate information to evaluate federal programs and formulate wise policies. Congress recognized that the public cannot make intelligent decisions without such information, and that governmental institutions become unresponsive to public needs if knowledge of their activities is denied to the people and their representatives. The touchstone of any proceedings under the Act must be the clear legislative intent to assure public access to all governmental records whose disclosure would not significantly harm specific governmental interests. The policy of the Act requires that the disclosure requirement be construed broadly, the exemptions narrowly. The public's need for information is especially great in the field of science and technology, for the growth of specialized scientific knowledge threatens to outstrip our collective ability to control its effects on our lives. The OST itself was created to help alleviate this problem; Congress intended that the OST would provide better information and coordination with respect to federal activities in the scientific field. It would defeat the purposes of the OST, as well as the purposes of the Act, to withhold from the public factual information on a federal scientific program whose future is at the center of public debate (https://openjurist.org/448/f2d/1067/soucie-v-e-david). With this in mind, I am writing regarding the FCC’s response to the D.C. Circuit Court of Appeals’ remand concerning its decades-old insufficient 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 and should include known effects of non ionizing radiation from thousands of publications found in early research studies. 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. Because the FCC controls this policy during a time when there has been a massive roll out of essentially all wireless technology that is also entirely weaponized and evidence suggests is sharing the same exact network being used by the civilian population to drive all that we use in the day to day for everything we do in our lives from the workplace, inside of our homes and in our schools to the wireless of the medical body area network now advancing in many areas of public health and now also involving increasing surveillance, SMART city and SMART meter technologies that are largely pulsed frequency radiation technologies advancing a system mostly without any safety testing capable of communicating with our appliances, vehicles, HVAC systems, home wiring, and most certainly the bodies of ourselves, our children and our pets. https://technav.ieee.org/topic/wireless-sensing/ The FCC, as a gatekeeper, must reconcile established evidence that is well documented and published like the evidence given in the numerous Biological Effects of Radiation and or Electromagnetic radiation studies in the government records database that have been conducted or originated by agencies such as ARPA, DOD, the Department of National Intelligence, known by the Directors of National Intelligence,published decades ago by the Behavioral Radiology Laboratory, the Division of Neuropsychiatry, the Walter Reed Army Institute of Research, Walter Reed Army Medical Center, U.S. ARMY MEDICAL RESEARCH AND DEVELOPMENT COMMAND and a long list of others—frankly, too many of them to name them all have every one conducted their own research studies as well in those agencies. To illustrate how well known this has been across agencies of government, consider the following quote from the July 1971 report on the Biological Effects of Electromagnetic Radiation: Mead Data Central has had the contractual responsibility for building a computerized data bank of abstracts of the literature which would subsequently be made available to investigators interested in the effects and hazards of nonionizing radiation (Biological Effects of Electromagnetic Radiation, July1971, p.1). https://archive.org/details/DTIC_AD0887119/page/1/mode/2up). The FCC should fully consider all evidence and real-world experiences concerning the health and environmental impacts of wireless radiation electromagnetic radiation,, including non-cancer health effects, impacts on children, long-term and cumulative exposure, cancer, and impacts on wildlife 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, which clearly do not and that are decade after decade being used to cover for what may amount to crimes against humanity if not properly dealt with. Please consider the testimonies given in 2011 to the Presidential Commission on the Study of Bioethical Issues here: Study of Bioethical Issues 3-1-2011 Public Comment part 1/6: https://youtu.be/9iqIaQ94c8o?si=9Xbej-CEqufC0fzP Study of Bioethical Issues 3-1-2011 Public Comment part 2/6: https://youtu.be/MinTxWhEwiw?si=IPtVc6I74fo1MjA_ Study of Bioethical Issues 3-1-2011 Public Comment part 3/6: https://youtu.be/-Gim3EQ2s88?si=nrOEhwM5MPsyV1hL Study of Bioethical Issues 3-1-2011 Public Comment part 4/6: https://youtu.be/TrgSpF70ZRo?si=pbJoWhtfHUBVCYU4 Study of Bioethical Issues 3-1-2011 Public Comment part 5/6: https://youtu.be/MAxVYPYUVwA?si=vxCZmsHedn8rmHQj Study of Bioethical Issues 3-1-2011 Public Comment part 6/6: https://youtu.be/8JkcYM6YsBE?si=Ev6DooUTJLSwtASt As noted by the International Association of Firefighters IAFF: The FCC authorizes and licenses products, transmitters, and facilities that generate RF and microwave radiation. It has jurisdiction over all transmitting services in the U.S. except those specifically operated by the Federal Government. Under the National Environmental Policy Act of 1969 (NEPA), the FCC has certain responsibilities to consider whether its actions will significantly affect the quality of the human environment. Therefore, FCC approval and licensing of transmitters and facilities must be evaluated for significant impact on the environment. Human exposure to RF radiation emitted by FCC-regulated transmitters is one of several factors that must be considered in such environmental evaluations. In 1996, the FCC revised its guidelines for RF/MW radiation exposure as a result of a multi-year proceeding and as required by the Telecommunications Act of 1996 (https://www.iaff.org/cell-tower-radiation/). 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, which in all honesty may be seriously deficient given the nature of wireless frequency based technology and the capability to interact with human bodies and biological systems that are also weapons systems. I also 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. It is critical that we have a widespread campaign to address what has been kept from the record for decades regarding wireless based technologies and their impact on health systems and the environment. These are also very much so weaponized as already noted, and the same weapons in use by intelligence, law enforcement, military and its contractors now are made a part of our daily lives coexisting in the spaces we share while causing significant unregulated effects and subsequent damages. This has likely been since the very beginning but is only increasing with their widespread implementation. In many ways, bringing this weapon system into the hands of civilians is also having the effect of damaging the testimonies of those who have been made into victims of systematic non consensual and for dual use human subjects of weapons research because what is happening is that those reporting similar health effects as the ones who are intentionally being targeted for experimentation declared legal for purposes other than warfare, are the same or similar symptoms being reported by those who are having various health effects simply from chronic daily exposure to wireless devices without this being necessarily weaponized against them in any way. The two may have similarities but those who are targeted are experiencing things that others are not experiencing, so it is important to make the very clear distinction to recognize that this is a technological system that should never have been made available for dual uses in the civilian environment because this technology was released and employed without any update to the safety guidelines making it impossible for many people who have suffered long before the full scale introduction of wireless for civilian use to be recognized as research subjects or for those who are being targeted simultaneously to this full scale introduction. There were already a growing number of people reporting to government agencies of this experimental dual use program going back to the writing of EO 12333 stating that they were being targeted by various hidden methods and weapons prior to the roll out of cellphones and completely wireless systems, so that must be dealt with to give relief to those people, because if not, what type of government are we running and what type of government do we really have? Because the FCC gate keeping of information regarding this technology and its safety guidelines have not been updated in thirty years even those who in their day to day jobs are around, maybe are testing and or are using these technological weapons are not always able to receive adequate health coverage for any injuries or chronic health conditions as a direct result of a lack of full disclosure.

As a future nurse practitioner (current student), I am deeply passionate about improving and advocating for public health. The FCC states, "The available scientific evidence does not show that any health problems are associated with using wireless phones." Further, the Telecommunications Act of 1996 restricts state and local governments from regulating wireless infrastructures (like cell towers) based on health or environment effects of radio frequency emission. Firstly, there is an overwhelming amount of research and studies that demonstrate the negative health effects of radio frequency / non-ionizing radiation on the human body (https://www.emf-portal.org/en). Secondly, the Telecommunications Act of 1996 is entirely outdated considering the exponential increase in technology since the early 2000s. Revisions to this act should include regular review of RF exposure standards, research, protection of sensitive locations such as schools, expand environmental review, increase transparency, and allow local governments and their constituents to have more decision-making power over wireless facility placement.

I had had several years of heart palpitations, confirmed by a 24 hour Holter Monitor test, when in 2015 I realized it came on strong in the evening when I sat down to read the newspaper- an experience that forced me to bed, even at 6:30 PM. A friend mentioned Smart Meters and other WiFi as a possible source of those palpitations. On the other side of the exterior wall from where I sat to read was a Smart Meter on my water meter and my regular electric meter. I had the the water dept remove that Smart Meter and for good measure, I replaced my Wi-Fi modem with a model without Wifi. The cardiac symptoms stopped cold, and I slept better! A couple of months later, I sat down to read the paper and got a spontaneous nose bleed. I don't get nose bleeds, but I was better educated. I went outside and saw the Water Dept had reinstalled the smart meter. I had it removed and posted a sign on the side of the house. This was in 2015. I had no more problems until 2020. During the Covid lockdown that spring, I allowed a relative to live with me because he was a "non-essential worker" who suddenly had no income, and I was recovering from an injury and needed assistance. After a couple of weeks, I put in a WiFi modem, again, so he could use his laptop. In short order, I started getting pains in my solar plexus and insomnia. The day he left, I disconnected that modem. No more pain and no more insomnia. FWIW: I do not talk on a wireless phone. I have one, but I forward calls to hard wired phones in my house that run off of VOIP on my Ethernet wired computer. It's hard enough to avoid fluoridated water and pesticide-ladened food. We don't need invisible poisons radiating through our bodies because it is more profitable for the Telecom industry! Neither do we need "smart" appliances. Until they figure out a safe technology, stick with wired connections.

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 As a Doctor who has been injured from radiofrequency radiation, I have a sincere interest in updated, evidence-based regulations of the FCC to protect all living things from the known biological harm of RFR. The FCC is currently not fulfilling its mandate to promote the “safety of life and property” (Communications Act of 1934). Since 2018, living near a cell tower, sleeping close to a smart meter and having a wifi router from a neighbor within 10 feet of my sleeping space, I have had neurological harm. Since then, when I'm near a wifi router or another person's phone or smart watch, I get burning pain on my skin in the area closest to the pulse-modulated RF radiation. I also get severe fatigue, brain fog, a pressure headache, and the next days to weeks I feel "hungover" from the exposure. It makes normal functioning very difficult. When I sleep next to someone with a smart watch on or sleep in a house/hotel with wifi on, my sleep is very poor- I wake up many times and have trouble falling asleep. When I sleep at home with our wifi router turned off and phones off, I wake up much more rested and do not wake up in the middle of the night. I fear for my young daughter and unborn baby, since research shows their brains absorb much more radiofrequency radiation, and it is pervasive in classrooms, places of worship, as well as playgrounds. I am calling for more research on the biological harms from radiofrequency radiation, particularly pulse-modulated RF radiation. As more cell towers proliferate and new bands of frequency are being used, there needs to be a halt to all new infrastructure until solid research has been done to investigate the impacts on living beings- humans, flora and fauna. The current FCC guideline is based on an antiquated study from 30 years ago. Telecommunications have changed drastically over that time period, so those guidelines are now irrelevant. What studies have the FCC done to evaluate RFR's effects on cellular health and oxidative stress, which manifest into countless disease states? What about neurobehavioral outcomes, like children learning in school near a wifi router, or productivity and concentration in the workplace? How are migrating animals and insects affected by the never-ending bombardment of frequencies running through their bodies? How does that impact ecosystems and ultimately human health? Europe has more stringent standards on pulse-modulated RF radiation to protect the health of its citizens and wildlife- why don't we mirror their regulations as a starting point and add on as more research has accumulated? The cost of inaction is far too high- if the FCC fails to produce relevant research to protect the health of all living beings, what is the cost to all of humanity? The cost of healthcare is already astronomical in the US. Could limiting the number of towers, satellites, smart devices, band frequencies and the power produced by these structures decrease the amount of human suffering and cost of "mystery" chronic disease states? Before any new technology is developed, I urge the FCC to study chronic radiofrequency radiation exposure at ambient levels in a cohort study as well as RCT studies to assess the cellular and physiological changes with acute exposure to pulse-modulated RF radiation. Please see the references attached as evidence to support my claims. The inaction of federal agencies, including the FCC, in studying the biological and environmental effects of RFR and pulse-modulated RF radiation is extremely disappointing. As a Doctor and one who has been injured by RFR, I see the damage this has on my patients as well. I did not consent, nor do I consent today, to the continuous, involuntary exposure to biologically active RF radiation. Please allocate necessary funding to study RF radiation's effects on living beings. It is the ethical, responsible action to do that. Sincerely, Dr. Colton References: Belyaev I, Dean A, Eger H, Hubmann G, Jandrisovits R, Kern M, Kundi M, Moshammer H, Lercher P, Müller K, Oberfeld G, Ohnsorge P, Pelzmann P, Scheingraber C, Thill R. EUROPAEM EMF Guideline 2016 for the prevention, diagnosis and treatment of EMF-related health problems and illnesses. Rev Environ Health. 2016 Sep 1;31(3):363-97. doi: 10.1515/reveh-2016-0011. PMID: 27454111. Kaszuba-Zwoińska J, Gremba J, Gałdzińska-Calik B, Wójcik-Piotrowicz K, Thor PJ. Electromagnetic field induced biological effects in humans. Przegl Lek. 2015;72(11):636-41. PMID: 27012122. International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF). Scientific evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation: implications for 5G. Environ Health. 2022 Oct 18;21(1):92. doi: 10.1186/s12940-022-00900-9. PMID: 36253855; PMCID: PMC9576312.

Along with all the scientific evidence that is cited below in all the research documents. I have personal experiences which I feel relate to health and safety. My father died of cancer 5 years ago. He didn't like or use cell phones but once he had one that was smart he slept with it by his head listening to music. Talked to friends for hours with it by his head. After getting the smart cell phone he got cancer within 2 years of having teh smart phone and died within 3 months of diagnosis. He had a growth in his neck next to where he would rest his cell phone on his pillow in bed. He believed and so do I that the cancer was because of his cell phone use. I personally can not sleep when wifi is on or near me. When traveling, I have to sleep with a EMF blocking hat to sleep, otherwise my brain has the to do list running all night long. I try to make our cell phones safer by putting EMF shielding fabric in our cell phone cases but I worry about my kids and their use. They do not understand the dangers. They say everyone has their cell phones with them all the time but they are not old enough to see the evidence or experience friends dying from the shape of a tumor where they held their cell phones up to their heads. We have 3 additional friends who died of brain cancer besides my dad. If regulations were nation wide kids would understand the actual dangers. We need safer regulations! Below are cited documents research documents etc showing the findings that all the radiation is not healthy. Levitt, B. B., Lai, H. C., Manville, A. M., II, & Scarato, T. (2025). Flora and fauna—How nonhuman species interact with natural and man-made EMF at ecosystem levels and public policy recommendations. Frontiers in Public Health, 13, 1693873. https://doi.org/10.3389/fpubh.2025.1693873 Melnick, R. L., Moskowitz, J. M., & International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF). (2026). Exposure limits to radiofrequency EMF do not account for cancer risk or reproductive toxicity assessed from data in experimental animals. Environmental Health, 25(1), 42. https://doi.org/10.1186/s12940-026-01288-6 International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF). (2026). Safeguarding children’s health in the digital age: Addressing screen time, wireless radiation and extremely low-frequency non-ionizing electromagnetic field exposures. Position statement https://icbe-emf.org/wp-content/uploads/2026/09/ICBE-EMF-Child-Health-Cell-Phone-Cell-Tower-EMF-Position-Statement-PDF-982026-1.pdf Scientific Documentation That Limits Are Inadequate Melnick, R. L., Moskowitz, J. M., & International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF). (2026). Exposure limits to radiofrequency EMF do not account for cancer risk or reproductive toxicity assessed from data in experimental animals. Environmental Health, 25(1), 42. https://doi.org/10.1186/s12940-026-01288-6 International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF). (2022). Scientific evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation: Implications for 5G. Environmental Health, 21(1), 92. https://doi.org/10.1186/s12940-022-00900-9 Lai, H., & Levitt, B. B. (2024). Cellular and molecular effects of non-ionizing electromagnetic fields. Reviews on Environmental Health, 39(3), 519–529. https://doi.org/10.1515/reveh-2023-0023 Lai, H., & Levitt, B. B. (2022). The roles of intensity, exposure duration, and modulation on the biological effects of radiofrequency radiation and exposure guidelines. Electromagnetic Biology and Medicine, 41(2), 230–255. https://doi.org/10.1080/15368378.2022.2065683 Lai, H. (2021). Genetic effects of non-ionizing electromagnetic fields. Electromagnetic Biology and Medicine, 40(2), 264–273. https://doi.org/10.1080/15368378.2021.1881866 Lai, H., & Levitt, B. B. (2025). Radiofrequency radiation-induced gene expression. Reviews on Environmental Health. Advance online publication. https://doi.org/10.1515/reveh-2025-0104 Lin, J. C. (2025). Health and safety practices and policies concerning human exposure to RF/microwave radiation. Frontiers in Public Health, 13, 1619781. https://doi.org/10.3389/fpubh.2025.1619781 Golomb BA. Diplomats’ Mystery Illness and Pulsed Radiofrequency/Microwave Radiation. Neural Comput. 2018 Nov;30(11):2882-2985. doi: 10.1162/neco_a_01133. Uche, U. I., & Naidenko, O. V. (2021). Development of health-based exposure limits for radiofrequency radiation from wireless devices using a benchmark dose approach. Environmental Health, 20(1), 84. https://doi.org/10.1186/s12940-021-00768-1 Wildlife Impacts Levitt, B. B., Lai, H. C., & Manville, A. M., II. (2022). Low-level EMF effects on wildlife and plants: What research tells us about an ecosystem approach. Frontiers in Public Health, 10, 1000840. https://doi.org/10.3389/fpubh.2022.1000840 Levitt, B. B., Lai, H. C., & Manville, A. M., II. (2022a). Effects of non-ionizing electromagnetic fields on flora and fauna, Part 1: Rising ambient EMF levels in the environment. Reviews on Environmental Health, 37(1), 81–122. https://doi.org/10.1515/reveh-2021-0026 Levitt, B. B., Lai, H. C., & Manville, A. M., II. (2022b). Effects of non-ionizing electromagnetic fields on flora and fauna, Part 2: Impacts—How species interact with natural and man-made EMF. Reviews on Environmental Health, 37(3), 327–406. https://doi.org/10.1515/reveh-2021-0050 Levitt, B. B., Lai, H. C., & Manville, A. M., II. (2022c). Effects of non-ionizing electromagnetic fields on flora and fauna, Part 3: Exposure standards, public policy, laws, and future directions. Reviews on Environmental Health, 37(4), 531–558. https://doi.org/10.1515/reveh-2021-0083 Manville, A. M., II, Levitt, B. B., & Lai, H. C. (2024). Health and environmental effects to wildlife from radio telemetry and tracking devices—State of the science and best management practices. Frontiers in Veterinary Science, 11, 1283709. https://doi.org/10.3389/fvets.2024.1283709 Thill, A., Cammaerts, M.-C., & Balmori, A. (2024). Biological effects of electromagnetic fields on insects: A systematic review and meta-analysis. Reviews on Environmental Health, 39(4), 853–869. https://doi.org/10.1515/reveh-2023-0072 Panagopoulos, D. J., Karabarbounis, A., & Chrousos, G. P. (2024). Biophysical mechanism of animal magnetoreception, orientation and navigation. Scientific Reports, 14(1), 30053. https://doi.org/10.1038/s41598-024-77883-9 Balmori, A. (2021). Electromagnetic radiation as an emerging driver factor for the decline of insects. Science of the Total Environment, 767, 144913. https://doi.org/10.1016/j.scitotenv.2020.144913 Children’s Vulnerability International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF). (2026). Safeguarding children’s health in the digital age: Addressing screen time, wireless radiation and extremely low-frequency non-ionizing electromagnetic field exposures. Position statement https://icbe-emf.org/wp-content/uploads/2026/09/ICBE-EMF-Child-Health-Cell-Phone-Cell-Tower-EMF-Position-Statement-PDF-982026-1.pdf Davis, D., Birnbaum, L., Ben-Ishai, P., Taylor, H., Sears, M., Butler, T., & Scarato, T. (2023). Wireless technologies, non-ionizing electromagnetic fields and children: Identifying and reducing health risks. Current Problems in Pediatric and Adolescent Health Care, 53(2), 101374. https://doi.org/10.1016/j.cppeds.2023.101374 Fernández, C., de Salles, A. A., Sears, M. E., Morris, R. D., & Davis, D. L. (2018). Absorption of wireless radiation in the child versus adult brain and eye from cell phone conversation or virtual reality. Environmental Research, 167, 694–699. https://doi.org/10.1016/j.envres.2018.05.013 Soares, N. E., Bulla, G., Fernández-Rodríguez, C. E., & de Salles, A. A. A. (2025). SAR estimations in a classroom with wireless computers. Journal of Microwaves, Optoelectronics and Electromagnetic Applications, 24(2), e2025288526. https://doi.org/10.1590/2179-10742025v24i3288526 Thyroid Effects Alkayyali, T., Ochuba, O., Srivastava, K., Sandhu, J. K., Joseph, C., Ruo, S. W., Jain, A., Waqar, A., & Poudel, S. (2021). An exploration of the effects of radiofrequency radiation emitted by mobile phones and extremely low frequency radiation on thyroid hormones and thyroid gland histopathology. Cureus, 13(8), e17329. https://doi.org/10.7759/cureus.17329 Reproductive Impacts Lamzouri, O., Ahl Laamara, R., & Drissi, L. B. (2025). Impact of electromagnetic field exposure on reproductive health: An umbrella review and meta-analysis of systematic reviews. Middle East Fertility Society Journal, 30, 42. https://doi.org/10.1186/s43043-025-00258-1 Vijay, S., Ibrahim, S. F., Osman, K., Zulkefli, A. F., Mat Ros, M. F., Jamaludin, N., Syed Taha, S. M. A., Hairulazam, A., & Jaffar, F. H. F. (2025). Histomorphometry and sperm quality in male rats exposed to 2.45 GHz Wi-Fi. Reproduction, 169(5), e250048. https://doi.org/10.1530/REP-25-0048 Zhang, Y., Song, J. Y., & Sun, Z. G. (2025). Exploring the impact of environmental factors on male reproductive health through epigenetics. Reproductive Toxicology, 132, 108832. https://doi.org/10.1016/j.reprotox.2025.108832 Bektas, H., & Dasdag, S. (2025). The effects of radiofrequency radiation on male reproductive health and potential mechanisms. Electromagnetic Biology and Medicine, 44(3), 359–384. https://doi.org/10.1080/15368378.2025.2480664 Assefa, E. M., & Abdu, S. M. (2025). Histopathologic effects of mobile phone radiation exposure on the testes and sperm parameters: A systematic literature review of animal studies. Frontiers in Reproductive Health, 6, 1515166. https://doi.org/10.3389/frph.2024.1515166 Maluin, S. M., Osman, K., Jaffar, F. H. F., & Ibrahim, S. F. (2021). Effect of radiation emitted by wireless devices on male reproductive hormones: A systematic review. Frontiers in Physiology, 12, 732420. https://doi.org/10.3389/fphys.2021.732420 Santini, S. J., Cordone, V., Falone, S., Mijit, M., Tatone, C., Amicarelli, F., & Di Emidio, G. (2018). Role of mitochondria in the oxidative stress induced by electromagnetic fields: Focus on reproductive systems. Oxidative Medicine and Cellular Longevity, 2018, 5076271. https://doi.org/10.1155/2018/5076271 Adams, J. A., Galloway, T. S., Mondal, D., Esteves, S. C., & Mathews, F. (2014). Effect of mobile telephones on sperm quality: A systematic review and meta-analysis. Environment International, 70, 106–112. https://doi.org/10.1016/j.envint.2014.04.015 Agarwal, A., Durairajanayagam, D. (2015). Are men talking their reproductive health away? Asian Journal of Andrology, 17(3), 433–434. https://doi.org/10.4103/1008-682X.140963 Agarwal, A., Desai, N. R., Makker, K., Varghese, A., Mouradi, R., Sabanegh, E., & Sharma, R. (2009). Effects of radiofrequency electromagnetic waves (RF-EMW) from cellular phones on human ejaculated semen: An in vitro pilot study. Fertility and Sterility, 92(4), 1318–1325. https://doi.org/10.1016/j.fertnstert.2008.08.022 Gautam, R., & Arora, T. (2023). Radio frequency electromagnetic radiation (RF-EMR) emitted from mobile phone and its impact on male reproductive health. EIACP: Diversity and Impact on the Environment, 28(3), 8–11. https://www.researchgate.net/publication/375799722_Radio_Frequency_Electromagnetic_Radiation_RF-EMR_Emitted_from_Mobile_Phone_and_its_Impact_on_Male_Reproductive_Health Summary and Review Papers Weller, S. G., McCredden, J. E., Leach, V., Chu, C., & Lam, A. K. (2025). A scoping review and evidence map of radiofrequency field exposure and genotoxicity: Assessing in vivo, in vitro, and epidemiological data. Frontiers in Public Health, 13, 1613353. https://doi.org/10.3389/fpubh.2025.1613353 McCredden, J. E., Cook, N., Weller, S., & Leach, V. (2022). Wireless technology is an environmental stressor requiring new understanding and approaches in health care. Frontiers in Public Health, 10, 894447. https://doi.org/10.3389/fpubh.2022.894447 Miller, A. B., Sears, M. E., Morgan, L. L., Davis, D. L., Hardell, L., Oremus, M., & Soskolne, C. L. (2019). Risks to health and well-being from radio-frequency radiation emitted by cell phones and other wireless devices. Frontiers in Public Health, 7, 223. https://doi.org/10.3389/fpubh.2019.00223 Belpomme, D., Hardell, L., Belyaev, I., Burgio, E., & Carpenter, D. O. (2018). Thermal and non-thermal health effects of low intensity non-ionizing radiation: An international perspective. Environmental Pollution, 242, 643–658. https://doi.org/10.1016/j.envpol.2018.07.019 Panagopoulos, D. J., Karabarbounis, A., Yakymenko, I., & Chrousos, G. P. (2021). Human-made electromagnetic fields: Ion forced-oscillation and voltage-gated ion channel dysfunction, oxidative stress and DNA damage (Review). International Journal of Oncology, 59(5), 92. https://doi.org/10.3892/ijo.2021.5272 Wang, M., Zhang, Y., Angley, M., Kleiman, N. J., Wang, X., & Kahe, K. (2026). A systematic review of mobile phone use and pregnancy and fetal outcomes. Journal of Exposure Science & Environmental Epidemiology. Advance online publication. https://doi.org/10.1038/s41370-026-00958-4 Hu, C., Zuo, H., & Li, Y. (2021). Effects of radiofrequency electromagnetic radiation on neurotransmitters in the brain. Frontiers in Public Health, 9, 691880. https://doi.org/10.3389/fpubh.2021.691880 Cell Towers Balmori, A. (2022). Evidence for a health risk by RF on humans living around mobile phone base stations: From radiofrequency sickness to cancer. Environmental Research, 214, 113851. https://doi.org/10.1016/j.envres.2022.113851 Pearce, J. M. (2020). Limiting liability with positioning to minimize negative health effects of cellular phone towers. Environmental Research, 181, 108845. https://doi.org/10.1016/j.envres.2019.108845 Rodrigues, N. C. P., Dode, A. C., Andrade, M. K. N., O’Dwyer, G., Monteiro, D. L. M., Reis, I. N. C., Rodrigues, R. P., Frossard, V. C., & Lino, V. T. S. (2021). The effect of continuous low-intensity exposure to electromagnetic fields from radio base stations to cancer mortality in Brazil. International Journal of Environmental Research and Public Health, 18(3), 1229. https://doi.org/10.3390/ijerph18031229 Dode, A. C., Leão, M. M. D., Tejo, F. A. F., Gomes, A. C. R., Dode, D. C., Dode, M. C., Moreira, C. W., Condessa, V. A., Albinatti, C., & Caiaffa, W. T. (2011). Mortality by neoplasia and cellular telephone base stations in the Belo Horizonte municipality, Minas Gerais state, Brazil. Science of the Total Environment, 409(19), 3649–3665. https://doi.org/10.1016/j.scitotenv.2011.05.051 Levitt, B. B., & Lai, H. (2011). Biological effects from exposure to electromagnetic radiation emitted by cell tower base stations and other antenna arrays. Environmental Reviews, 19, 495–514. https://doi.org/10.1139/A10-018 Khurana, V. G., Hardell, L., Everaert, J., Bortkiewicz, A., Carlberg, M., & Ahonen, M. (2010). Epidemiological evidence for a health risk from mobile phone base stations. International Journal of Occupational and Environmental Health, 16(3), 263–267. https://doi.org/10.1179/107735210799160192 School Recommendations Clegg, F. M., Sears, M., Friesen, M., Scarato, T., Metzinger, R., Russell, C., Stadtner, A., & Miller, A. B. (2020). Building science and radiofrequency radiation: What makes smart and healthy buildings. Building and Environment, 176, 106324. https://doi.org/10.1016/j.buildenv.2019.106324 Collaborative for High Performance Schools. (n.d.). Low EMF best practices summary. https://healthytechhome.org/wp-content/uploads/sites/201/CEHPAC-EMF-in-HomeWi-Fi-in-School-Report.pdf Maryland State Children’s Environmental Health and Protection Advisory Council. (n.d.). Guidelines to reduce electromagnetic field radiation. https://health.maryland.gov/phpa/OEHFP/EH/Shared Documents/CEHPAC/MD_CEHPAC_SchoolWiFi_022017_final.pdf Maryland Children’s Environmental Health and Protection Advisory Council. (2017). Wi-Fi in school report. https://health.maryland.gov/phpa/OEHFP/EH/Shared Documents/CEHPAC/MD_CEHPAC_SchoolWiFi_022017_final.pdf Santa Clara County Medical Association. (2023). Best practices for safe technology in schools. https://www.sccma.org/Portals/19/LiveBlog/3697/SCCMA Best Practices for Safe Technology in Schools Recommendations 21423.pdf Cell Tower Health Studies Airpods and Bluetooth Genetic Impacts, DNA Damage 5G Reviews | C-Band / 3.5 GHz | Millimeter Waves | Terahertz / THz Why FCC and ICNIRP Limits are Not Protective and Conflicts of Interest in Science ELF EMF Magnetic Fields / Power Lines (for HHS only) Category: Cell Towers Tag: cell phones, cell towers, children's health, emf, FCC, health effects, policy, science

The FCC says it operates under a "Public Interest Mandate", however by ignoring mounting evidence that radio frequency radiation is harmful, it is not fulfilling that mandate. There are many, many scientific studies that provide evidence that this technology is harmful. FCC should have exercised the Precautionary Principle ("When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause-and-effect relationships are not fully established scientifically") when cellular technology was first being introduced instead of believing the industry "experts" who were just interested in selling and expanding this technology as fast as possible. My job required that I used a cell phone as soon as they became widely available. I now have a brain tumor behind my right ear - exactly where I used to hold my cell phone to my head. The technology is dangerous and it is the job of the FCC to exercise its "Public Interest Mandate" and protect the public and not cave to the interests of corporations who just want to make a buck even if their products are harmful - sound like the tobacco industry? There are many experts in this area that can provide technical guidance and guidelines to the FCC. Some suggestions may include limiting cell tower locations, limiting the RF power of cell phones, requiring wired internet access to all homes, requiring copper wire land lines in all homes, the list can go on and on. Please have the courage to protect the citizens of the US.

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. 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 because: I am a 34 year old woman whose life has been profoundly affected by a chronic, debilitating health condition, and who has spent nearly two decades searching for answers. My chronic migraines began when I was 15 years old. Around that time, a cell tower was constructed approximately 0.2 miles directly behind my family’s home. I cannot claim that this tower caused my illness, but the timing of these events has remained significant to me throughout my health journey. My symptoms quickly became so severe that I had to reduce my high school schedule. I woke up nearly every morning with debilitating migraines and vertigo, often unable to function. At one point, I missed more than 30 consecutive days of school. My family and I went from doctor to doctor, desperately searching for the underlying cause. I was prescribed countless medications in an effort to manage my symptoms, many of which came with adverse effects. My education suffered, my grades declined, and what should have been a formative, exciting period of my life became a daily struggle to get through the day. Rather than improving with age, my condition became progressively more severe. By age 26, I was experiencing symptoms that I associated with exposure to wireless devices and infrastructure. My arms would go numb while using my phone. I experienced stabbing pains in my head and stomach when people with cell phones came near me or when I was in areas near cell towers. As newer wireless technologies were introduced, I became increasingly concerned about the relationship between these exposures and my symptoms. My family went to extraordinary lengths to try to help me. We invested significant money in completely hardwiring our home and removing all wireless devices in an effort to reduce my potential exposure and find some measure of relief. This was not a casual lifestyle choice; it was a response to the debilitating reality of my daily life and our desperation to find answers. My family has had to make significant adjustments to our home and way of living because of the severity of my condition. The fact that my health concerns have required these kinds of sacrifices speaks to just how profoundly this has affected not only my life, but the lives of the people who love and support me. Also, when 5G technology was introduced in stadiums, attending sporting events became extraordinarily difficult for me because of the debilitating migraines I experienced. Travel became another challenge. Wi-Fi on airplanes, Bluetooth connections, and the wireless devices used by people around me became sources of concern as I struggled to manage my symptoms. Activities that most people take for granted; attending a game, boarding a plane, going into public spaces, or simply being around other people, became obstacles I had to weigh against the possibility of becoming severely ill. The consequences have extended far beyond physical pain. This condition has isolated me from experiences, relationships, opportunities, and the independence that most adults work toward building. I have struggled to maintain the health necessary to work consistently and support myself. Today, at 34 years old, I remain financially and physically dependent on my parents in ways I never imagined would define my adult life. I would give anything to have the freedom to attend a sporting event without fearing the consequences, travel without anticipating debilitating pain, work toward financial independence, and participate in everyday life without having to calculate the potential cost to my health. No one should have to spend nearly two decades fighting to reclaim a life they feel they have lost, while wondering whether an environmental exposure could be contributing to their suffering. People deserve answers. They deserve rigorous science, transparency, and a regulatory process willing to examine difficult questions. 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 ET Docket No. 13-84 — Human Exposure to Radiofrequency Electromagnetic Fields** To the Federal Communications Commission: My name is Elizabeth Anne Dunlap. I am a Colorado resident, a medical visualisation specialist with a master's degree in Medical Visualisation and Human Anatomy from the University of Glasgow, and an individual living with severe electromagnetic sensitivity (ES). I am submitting this comment to urge the FCC to reconsider its radiofrequency exposure guidelines in light of contemporary scientific research, reported health effects, and the lived experiences of people whose health and ability to participate in ordinary society are profoundly affected by their electromagnetic environments. **1. Existing RF exposure standards are inadequate** The FCC's existing exposure limits are largely based on protection against established adverse effects associated with tissue heating. These standards do not adequately resolve questions concerning potential biological effects of long-term, low-intensity, pulsed, or cumulative RF exposure. Research into oxidative stress, cellular signalling, neurological function, and other biological responses warrants continued independent investigation. The absence of scientific consensus about the clinical significance of reported non-thermal effects should not be mistaken for proof that all exposures below existing limits are harmless. **2. Electromagnetic sensitivity is a serious accessibility issue** My own experience illustrates the practical consequences of electromagnetic sensitivity. I experience severe physical symptoms that I associate with exposure to wireless infrastructure and devices, including migraines, stabbing pain, dizziness, burning sensations, nausea, and significant sleep disruption. These experiences have fundamentally altered my ability to work, travel, obtain housing, access public services, and participate in community life. I have invested considerable resources in modifying my living environment, including removing wireless equipment, using wired communications, and implementing electrical and RF mitigation measures. Regardless of ongoing scientific disagreements about the causes of electromagnetic sensitivity, the functional limitations experienced by affected individuals deserve serious consideration and appropriate accommodation. **3. The public needs meaningful opportunities to reduce exposure** Wireless technology is increasingly difficult to avoid. Smart meters, cellular infrastructure, wireless routers, connected appliances, and other transmitting devices have become pervasive in residential and public environments. People who wish to minimise their exposure should have practical, affordable options, including: - Access to wired telecommunications and internet services. - Non-transmitting utility meters and alternatives to mandatory wireless equipment. - Transparent information about RF emissions and infrastructure deployment. - Consideration of residential proximity and cumulative exposure when evaluating wireless installations. - Preservation of environments where individuals can live and work with reduced RF exposure. **4. Independent research and modernised exposure assessment are essential** The FCC should support a transparent review of peer-reviewed research, including studies examining biological endpoints beyond tissue heating. Exposure assessment should consider realistic conditions involving multiple transmitters, variable signal characteristics, chronic exposure, and populations with differing health circumstances. The Commission should also meaningfully address the findings and concerns raised by independent researchers, clinicians, and affected communities rather than relying exclusively on historical exposure assumptions. **5. Requested FCC action** I respectfully request that the Commission: 1. Reassess the scientific basis of its RF exposure limits through an independent, transparent, multidisciplinary review. 2. Evaluate evidence concerning non-thermal biological effects and long-term exposure. 3. Consider cumulative and real-world exposure conditions in future regulatory decisions. 4. Protect access to wired alternatives and reasonable accommodations for individuals reporting electromagnetic sensitivity. 5. Improve public participation, disclosure, and accountability in decisions affecting residential RF exposure. The Commission's responsibility extends beyond facilitating wireless communications. It must also give serious consideration to public health, accessibility, and the ability of Americans to make informed decisions about their environments. For individuals such as myself, this is not merely an abstract scientific debate. It concerns the ability to maintain a home, pursue a profession, obtain essential services, and live with dignity. Respectfully submitted, Elizabeth Anne Dunlap, MSc Morrison, Colorado

Before addressing the core matter of this submission, I must formally object to the absurd and needlessly restrictive architecture of the FCC’s public comment system. It is painfully obvious that this interface is designed to suppress public participation rather than encourage it, effectively shutting out the average citizen from participating in having their concerns heard and considered. Unlike the Department of Health and Human Services, which transparently routes public feedback through their centralized, user-friendly Regulations.gov portal, the FCC forces the public to navigate its own proprietary Electronic Comment Filing System. The FCC’s system does not even allow simple keywords and instead the user must use a highly specific numeric docket number (13-84) just to find the submission box. Unless you are actively tracking the court transcripts of current lawsuits against this agency, you will not know about this bracket number. By burying public comment portals behind an obscure and independent interface, the FCC has built a systemic barrier to entry. If a regulatory agency genuinely cares about public input, its systems should be built for the public, not just for corporate lawyers in insider litigants. But this is not merely a problem with how the FCC receives public comments. It is a problem with what happens when those comments are made and the agency fails to adequately respond to the human consequences. My complaint is real. It is personal, documented, and ongoing. As you are fully aware, the current RF exposure guidelines date back to 1996. In more than 30 years since those guidelines were established, wireless technology and the number and proximity of wireless transmitting facilities have changed dramatically. Yet the regulatory framework governing RF exposure has not kept pace with those changes. I live in Florida where state law allows communication facilities, including small wireless facilities, to be placed within public right of ways; Florida Statute 337.401. In my case, that regulatory framework resulted in a 5G small cell installation being placed on the swale adjacent to my property, 32 feet from my bedroom window. The combination of expansive telecommunications citing laws and outdated RF exposure standards has had a real consequence for my family. We have been forced to move from our home due to sickness directly related to RF exposure. I contacted the FCC directly. I explained my circumstances, documented my concerns, and provided two independent third-party reports specifically addressing the RF exposure situation at my property. I asked the agency responsible for this technology, you…the FCC, to consider what was happening to my family. I received no intervention. Looking back, you know what the court ordered you to do. The D.C. Court of Appeals found that the FCC had failed to provide a reasoned conclusion that its RF exposure guidelines adequately protected the public from harmful effects. You were directed to address those deficiencies. Yet five years later, I am living with the consequences of a regulatory system that has failed to adequately account for those concerns. I am asking the FCC to recognize that this issue is no longer theoretical. Families are living in close proximity to increasingly ubiquitous wireless infrastructure, and existing regulations must account for the realities of that environment. The public should not have to sacrifice access to their homes in order to accommodate an expanding wireless infrastructure. The FCC must comply with the law, meaningfully address the scientific evidence before it, and consider human consequences of its regulatory decisions. Public safety cannot be treated as an afterthought. -Amanda Albertelli

I'm writing in regards to the FCCs lack of response to the D.C Court of Appeals remand concerning it's decades old - radio frequency (RF) radiofrequency exposure guidelines. The FCC has had more than enough time to review and address the evidence by the 9th Circuit Court win, on August 13, 2021. This has to be done! Enough lives have already been taken and ruined! This will effect the most vulnerable and already has. I've done extensive research and the ITU BDT (R-T-D) IPEC-WB-WRC-GSR- Plenipotentiary, via the Department of State has to be stopped! We have an industry and government that are both rogue. Not only is wireless harmful it DOES cause cancers! The new P25 warnings out of CA state on the new 5GHz phones "May cause reproductive harm." Since when do we test (never tested) cell phones for RF harm, using a plastic head! Now we are dealing with smart meters, smart grid, Broadband, Wi-fi, satellites, etc. 5GHz now going to over 8GHz via WRC27. Enough is enough and start doing what is right! It may be your own lives you are saving. TRUST ME...losing my son from a cell-tower/cell-phone RF has destroyed my life and I've witnessed many others being harmed. This has to be covered by disabilities. I know people that are so disabled from being exposed that they pray to make it to another day. All of this has to be reigned in. The WEF-WB are not in charge! Sincerely, Virginia Farver