Court remand & agency accountability

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 of what I have witnessed change in the environment since the increase of wireless communications and electro magnetic frequencies. The incidence of all cause cancers seems to be on the rise. Public anxiety is more evident. Lives are disrupted by the continual bombardment of information from cell phone and computer use. Driving and bike riding are more dangerous with the increased use of cell phones. The level of surveillance has become an invasion of privacy. 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.

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 have children that are exposed the these types of radiation regularly. I want them to be protected and aware of the consequences. Thank you.

The FCC must become a proactive agency, placing Americans' health first before businesses and other objectives. Subsequently, amending current exposure limits to ensure safety is urgently needed. Independent experts concur that the 1996 RFR exposure limits remain ineffective because they were based on thermal heating of tissue, while ignoring lower frequencies. Studies based on thermal heating used a 200 lb male dummy and a water filled balloon for head exposure. Debilitating health effects occur at much lower frequency levels. Health impacts for pregnant women, babies, children and those working in fields with chronic exposures weren't included. Fast forward thirty years, and the amount of RFR emitting devices and ambient RFR levels has skyrocketed. The proliferation of cell phones, cell towers, 5G, 6G, antennas, WiFi, smart meters, and other smart products is unprecedented. No federal agency has assessed/evaluated the impacts on human health and our environment by addressing these combined multiple exposures. Major areas of concern include: impacts on children, the environment, EHS individuals and the cumulative, involuntary exposure most people encounter every day. As a grandmother, I'm extremely worried about the constant RFR exposure experienced by our children and its long term effects. Children are more susceptible to environmental harms as they are smaller physically and in the process of developing. Their skulls are thinner, allowing more radiation to penetrate. Many schools now default to wireless connectivity with no evidence of safety, subjecting our children to this invisible toxin daily.  An increasing number of people experience Electromagnetic Hypersensitivity due to current excessive exposure levels. This involuntary exposure while navigating work and/or public spaces is impossible to avoid.  Many individuals through repeated exposure develop hypersensitivity and must actively avoid all exposures. Personally, I find airports intolerable; I experience headaches, vision problems and brain fog that lingers for hours. My home is hard-wired with ethernet cables and I keep my cell phone on airplane mode when not in use. Additionally, unless a state has enacted a no-fee opt-out, involuntary exposures include Smart Meters, which emit continuous pulsed radiation. Independent testing of all devices should reflect real life usage. For example, cell phones are carried in pockets, next to skin, close to the face and head.  The US should implement the European Commission's new standard requiring cellphones to be tested for radiation while touching the body — which is how people actually carry and use cellphones: in a pocket or against the skin. Dr. Marc Arazi, Phonegate Alert's founder and president, stated that a recent court ruling represents an “historic victory for European consumer protection and the culmination of nearly 10 years of campaigning against cellphone radiation testing protocols that failed to reflect real-world conditions of use.”  The natural world is similarly affected. It is known that RFR radiation affects bees and migratory birds, disrupting their ability to navigate and forage effectively. Flora and fauna are known to experience die-offs in close proximity to cell towers. In 2021, Kent Chamberlin Chairman, Emeritus of Electrical & Computer Engineering, University of New Hampshire concluded one of the key recommendations of the New Hampshire Commission to Study The Environmental and Health Effects of Evolving 5G Technology is that cell towers be placed no nearer than 1,640 feet from places where people live, work or recreate. This 500 meter setback should become immediate public policy. There should be an immediate moratorium on any new devices while safety studies are performed to evaluate the countless RFR emitting products already on the market.  European Union study finds children absorb more wireless radiation than adults across rangeof 5G frequencies - EHNhttps://www.ehn.org/5g-wireless-radiation-children-exposure 1 The FCC Is Supposed to Protect the Environment. It Doesn’t. https://www.propublica.org/article/fcc-environment-cell- towers-failures Environmental Procedures at the FCC: A Case Study in Corporate Capture (2022) 19 https://ehtrust.org/electromagnetic-fields-impact-tree- plant-growth/ 20 https://ehtrust.org/environmental-effects-of-wireless- radiation-and-electromagetic-fields/ 21 https://ehtrust.org/published-research-adverse-effect- wireless-technology-electromagnetic-radiation-bees/ 22 https://ehtrust.org/radiofrequency-radiation-effects-on- agronomy-agricultural-crops-and-crop-yields

I am an occupational therapist, a mother, and a small business owner. The health impacts from RF emissions from a "smart" electric meter installation on my office, along with daily cellphone use, and a new "super powerful" router for my office .... cumulated in an 180 degree change in my life's quality in 2018. Unregulated, unmonitored standards are killing our kids and our society. There are well researched results of the health impact of wireless devices on cellular health. Wireless frequencies have been the standard of which I now navigate my life. Unfortunately, this country that is denying the very real impact of wireless frequency bands is destroying the very base of which it depends upon for future success. FCC’s invitation claims its 1996 wireless radiation exposure limits stem from “gold-standard research” from organizations “including the National Council on Radiation Protection and Measurements (NCRP), the American National Standards Institute and the Institute of Electrical and Electronics Engineers (IEEE), internationally recognized standard-setting organizations.” Two other such recognized groups include the International Commission on Nonionizing Radiation Protection (ICNIRP) and the Institute of Electrical and Electronic Engineers (IEEE), which shared membership by Dr. James Lin, who concluded: “... RF exposure limits make allowances only to worry about heat with RF radiation. These limits are devised for restricting short-term heating by RF radiation and aim to prevent increased tissue temperatures. Thus, they are not applicable to long-term exposure at low levels. Instead of advances in science, they are predicated on assumptions using outdated exposure metrics, thus their ability to protect children, workers, and the public from exposure to the RF radiation or people with sensitivity to electromagnetic radiation from wireless devices and systems. Furthermore, the limits are based on outdated information and circumvent important animal data. These issues are even more relevant in the case of millimeter-wave radiation from 5G mobile communications for which there are no adequate health effects studies in the published literature. Finally, the guidelines do not adequately address conclusions from scientific organizations, such as the IARC (International Agency for Research on Cancer). Thus, many of the recommended limits are questionable from the standpoint of scientific justification for the safety and public health protection.” Society needs to know the impact of wireless devices and communications are on cellular health. Ignoring sound historical and current research and discounting debilitating impacts no longer is accepted. REAL integration of the science and regulations need to occur.

This comment is in regards to to FCC's reliance on outdated guidelines for radiofrequency (RF) radiation exposure. Fact: The levels of electromagnetic output, and thus, exposure have increased every year. Fact: The FCC has not studied long term effects of increased exposure in regards to humans, flora or fauna. 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 one study I believe the FCC should review when addressing the concerns about wireless radiation: Levitt, Lai & Manville (2021): Effects of non-ionizing electromagnetic fields on flora and fauna, Part 1: Rising ambient EMF levels in the environment – Examined increasing environmental electromagnetic-field exposure and research concerning potential effects on wildlife, plants, and ecosystems. 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: The life cycle of bees, in particular are crucial to our existence. The potential harm has not been measured in any meaningful way. We have anecdotal evidence of electromagnets improving the production of the hive. 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.

Department of Health and Human Services - Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure FCC Seeks Comment on RF Exposure Issues Subject to D.C. Circuit Remand in Environmental Health Trust V. FCC - ET Docket No. 13-84 To the respectful and understanding reader, First of all, please don’t judge my English, as this is my secondary language. When I was young, my father working in the broadcasting industry, gave our family the love of technology. He believed, like everyone was told, that nnEMF were safe. Having seen a housing opportunity, our whole family moved to a house near huge electric pylons. I lived there for about 10 years. However, I started having health problems on the 5th years. Unfortunately, my father passed away on the 13th year and my mother a bit later, after moving away from this house. A few years later, I started having a permanent headache that wouldn’t go away. I would go to sleep with a headache, then wake up with a headache. I went for a CT Scan and they told me everything was "fine". But it wasn’t fine. Fortunately, I started to have some clues: - My permanent headache went away only when going in the forest, and came back gradually while reentering the city. It occurred a few time, but couldn’t understand the link between my headache and the forest. - A long lasting power outage of 5 days, which affected the whole neighborhood: no headaches during that time. Headaches came back as soon as the power went back on. This is the moment I understood my headache was linked to electricity, somehow. I wasn’t sure, though, having been told again and again that non-ionizing EMFs were totally harmless. Anyhow, having a better idea of the problem, I tried to get help from professionals. I thought they would know better than me. After getting next to no help from my doctor and about 7-8 health specialists, that is when I tried to find answers by myself. This led me to a long and enduring path of discovery toward the truth, both for personal and professional reasons. Being a product designer, I use a scientific, neutral and intuitive approach on almost all subjects. So, I did what I normally do when doing research: checking both sides of the argument and trying to spot inconsistencies and biases. I also learned in my career that if you cannot measure it, you cannot improve it. So I started buying various and increasingly expensive EMF meters, covering different frequencies. This led me to understand that there were wiring errors in my house. I also discovered how "noisy" are WiFi and Bluetooth devices. I then tried to turn those antennas off. My headaches went away almost immediately after. Finally, 3 years after the beginning of my permanent headache, I was making progress. As of today, almost 7 years after the beginning of my permanent headache, I did more than 3000 hours research of the subject of EMF of many ranges and sources in order to understand the subject thoroughly. From my understanding so far, the problem isn’t necessarily nnEMF themselves, but their overabundance. You might be familiar with this: we call that "electrosmog". Don’t get me wrong: I LOVE technology and wouldn’t want to quit my day to day job. It has just became very hard to practice under those conditions. So, my long term goal is to get to know and understand the subject as much as possible in order to create safer products that are respectful of biology, including humans, animals and plants, as I know now that those are affected too. Most of us just aren’t aware. In one line: all lifeforms runs on electricity. Electricity is data. Any change of frequency, energy and vibration is affecting cell at microscopic levels. Under weak non-ionizing nnEMF (WiFi, BT, 60Hz powerline, among others), it first affect blood cells (rouleau formation) after just 10 minutes of exposure but resolves by itself when it stops or if the subject is moving enough to activate blood circulation. However, if someone stand still while using those devices and that it happens all days over a year, bigger problems start appearing. That’s why most lab tests are failing to find evidence: their tests aren’t lasting nearly long enough to find those. The defining characteristic of nnEMF (non-native electromagnetic fields) is polarization. nnEMF are artificially generated and highly polarized, which changes how they interact with matter, and, in this case, with living tissue. Polarization forces ions to oscillate, which, through a cascade of events, forces calcium channels open (voltage-gated ones, yes, you read that right), driving calcium into cells. Excess calcium stimulates the production of nitric oxide (NO), which reacts to form peroxynitrite (ONOO⁻), a highly reactive and aggressive oxidant. Over time, this damages mitochondria, alters cell membranes, and ultimately causes DNA strand breaks. Here is a problem which you guys have the power to solve: as you know, all cells phones are tested for SAR. Their levels are tested against your own rules and they pass it before the product gets released to the public. This is fine by itself. However, when you go inside a cramped bus or subway, those numbers are suddenly going through the roof. Nobody is checking for exposure in those areas. That being said, there are other solutions, such as LiFi, which could be a good alternative. Also, making wireless frequency unpolarized might be another path to explore. Before concluding, I must admit though that speaking of this problem with other people wasn’t all good. Many people, including some close friends, didn’t want to believe my story. I had to insist to the point of this health problem nearly breaking our friendship. Thanksfully, I had more listening ears around me than judging ones. I also met many people having the same problem as me, which was a relief. Many people are downright hostile toward this unknown problem, as you might have noticed. From what I’ve found so far, what we were told since the 60’ hasn’t evolved much in the public mindset. I really hope it changes at last. Thanks for caring about all of this. Philippe D. Côté

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, not to mention the fact that technology is moving at an incredible pace that is impossible to keep up with potential long term hazards. We do not want this to be another "If we had only known then what we know now" scenarios with countless people suffering from the harmful effects that could have been prevented if only more care, caution, and common sense had been used before blindly jumping on board with the latest technology. Here is just one study I believe the FCC should review when addressing the concerns about wireless radiation: https://www.sciencedirect.com/science/article/pii/S2213879X14000583 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 blindly 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. As a mother whose children have devices within constant reach as well as a daughter of an elderly mother whose assisted care facility relies heavily on mobile data, his issue matters to me personally 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 with the full understanding that once this is done, the damage and harm created cannot be undone even if changes are made later due to the harm already caused.

The wireless radiation must be abated. The FCC cannot enjoy immunity from placing American's in harms way and turning a blind eye. We know that silicone valley executives do NOT allow their children to use hand held devices, and we know how the blood behaves closer to wifi signals, we also know how the revolving door behaves in government. However. the tide has turned, the public servants will not continue to get away from accountability to the people.

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ET Docket No. 13-84: I am writing because I have general and personal concerns and experience symptoms related to RF radiation and feel strongly regarding the FCC’s response to the D.C. Circuit Court of Appeals’ remand concerning its decades-old radiofrequency (RF) radiation exposure guidelines. I understand that 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. I wholeheartedly believe that 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: BioInitiative Report (2012, with Subsequent Research Updates): Updated Research Summaries – Collection of scientific research concerning neurological effects, oxidative stress, DNA damage, genetic effects, and electromagnetic sensitivity. Individual summaries have different update dates, including 2022. The FCC 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. This is unconscienable! I wholeheartedly 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 live near numerous cell towers and our home is increasingly being surrounded by the installations of numerous 5G, 6G, 8G local telecommunication networks, besides the smart meters of utiilty companies. I experience headaches, extreme fatigue and disorintation from even cell phone exposure for any length of time. I have gone through the trouble to purchase an EMF meter and tested areas in and around my home, our celll phone, our computer and TV to find the readings high on all counts, even after I have taken what measures I could to mitigate exposures. I suffer chronic fatigue, many and increasing allergies and a low immune system, which I believe to be in great part a result of constant EMF exposure. After living in our current home for over 30 years, I have seen a large decrease in the bird and bee populations and in the health of the backyard wildlife. I have witnessed heightened tensions, anxiety, depression and significant declining general health in the people of the neighborhood. I very strongly 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.