Research, evidence & monitoring

DA 26-997 Released: September 17, 2026: FCC SEEKS COMMENT ON RF EXPOSURE ISSUES SUBJECT TO D.C. CIRCUIT REMAND IN ENVIRONMENTAL HEALTH TRUST V. FCC, ET Docket No. 13-84. I am Robert J. Berg, the founder and principal of the Law Office of Robert J. Berg PLLC. My law firm specializes in wireless telecommunications law. My firm is one of the very few law firms which primarily represents the interests of residents of communities where wireless carriers are seeking permits to install and operate personal wireless communications infrastructure. My firm also represents local governments which seek expert counsel as they consider applications for such wireless facilities. I, personally, have been practicing law for 43 years. I graduated from the University of Chicago Law School and the University of Chicago Graduate School of Business, receiving my JD and MBA degrees in 1983. For most of my career, I have litigated complex multi-party litigations, and specialized in complex class action litigation in the federal and state courts nationwide. Over the past several years, however, I have focused my practice nearly exclusively on wireless matters. I am fully familiar with the Environmental Health Trust v. FCC action in the US Court of Appeals for the DC Circuit, and I have represented Environmental Health Trust on certain filings following the Court of Appeals decision in 2021. I am submitting this Public Comment in response to the FCC’s DA 26-997 Released: September 17, 2026: FCC SEEKS COMMENT ON RF EXPOSURE ISSUES SUBJECT TO D.C. CIRCUIT REMAND IN ENVIRONMENTAL HEALTH TRUST V. FCC, ET Docket No. 13-84. In my experience, the FCC has a long and ignoble history of disserving the American people as a captured agency beholden to the industry it is supposed to regulate in the public interest. The agency has been captured for decades – under both Republican and Democratic administrations. But under the leadership of corrupt and conniving Chairman Brendan Carr, the FCC has reached a new nadir. The instant disingenuous Request for Public Comment represents a pathetic response to the Order of the DC Circuit requiring the FCC to respond to the Petition for Writ of Mandamus filed by Environmental Health Trust and Children’s Health Defense with the DC Circuit this past Spring. Petitioners filed for writ of mandamus after the FCC contemptuously ignored for 4 ½ years the mandate from the DC Circuit to reconsider most of the FCC’s unreasoned and arbitrary 2019 ruling refusing to conduct a rule-making procedure to update its 1996 RF exposure guidelines. The DC Circuit’s landmark decision in EHT v. FCC, 9 F.4th 893 (D.C. Cir. 2021), dealt a humiliating blow to the FCC. The panel eviscerated the FCC for its utter lack of reasoned decision-making on all the significant health and environmental issues raised, except for cancer, which the panel found that the FCC at least set forth a reasoned basis – without opining on the merits of the FCC’s reasoning. The DC Circuit excoriated the FCC for relying on the utterly conclusory and unreasoned statement of FDA Dr. Jeffrey Shuren that scientific studies do not show health risks from exposure to low level RF radiation. The DC Circuit held that Dr. Shuren’s statements were so conclusory and lacking in substantiation that reliance thereon is unreasonable, arbitrary, and capricious as a matter of law. The FCC, which lacks any scientific expertise of its own with respect to the human health and environmental impacts of wireless radiation exposure, necessarily must consult with and rely upon other agencies having such expertise, ruled the DC Circuit. Instead, by relying on Dr. Shuren’s unsubstantiated conclusory assertion of no health impact, the FCC acted as arbitrarily and capriciously as Dr. Shuren, and the DC Circuit held that two wrongs don’t make a right. After the DC Circuit issued its opinion, the NY Times later revealed that Dr. Shoren handled numerous matters at the FDA involving clients represented by his wife, an attorney, matters from which the law and FDA rules required him to recuse himself from considering. Dr. Shuren retired from the FDA before formal ethics investigations into his conduct were instituted. Given the FCC’s sordid ethical standards, it’s no surprise that the FCC would rely extensively on conclusory, unsupported statements of an unethical scoundrel like Dr. Shuren to justify maintaining archaic RF exposure guidelines that are not protective of human health and fail to reflect current independent scientific research untainted by industry money and influence. Yet, even in the present Notice for Public Comment, the FCC is unbowed by its public humiliation by the DC Circuit. Instead, this Notice blithely misstates the DC Circuit opinion, and intentionally solicits public comment based on its wrong and constricted interpretation of the EHT decision. The EHT mandate is about assuring that the FCC’s 1996 RF emissions guidelines adequately safeguard the health of the public today – thirty years later. The 1996 FCC guidelines were issued in a rush at the dawn of the wireless age when hardly any cell phones, no less a plethora of wireless devices, existed, and the number of cell towers and other wireless communications facilities around the country were minimal. Today, there are approximately 500,000 cell towers and other wireless communications facilities in the US, all transmitting RF radiation 24/7. Meanwhile, virtually every person in the country possesses a cell phone and/or other wireless devices. Human exposure to wireless radiation is ubiquitous and constant. In 1996, the telecommunications industry effectively lobbied (bribed) Congress to pass Section 332(c)(7) of the Telecommunications Act of 1996, which prohibits State and local governments from denying wireless carriers permits to construct and operate wireless facilities on the basis of the health risks of wireless radiation exposure. But there’s an important caveat to this provision – the federal preemption applies so long as the wireless facility at issue transmits at levels within the FCC’s RF guidelines. Thus, Congress has circumscribed State and local governments’ traditional zoning powers with respect to health in reliance on the FCC’s assurance that the FCC’s wireless emissions guidelines protect human health. Congress also mandates that the FCC guidelines protect against other environmental concerns, which means that wireless radiation exposure should not negatively impact flora and fauna. The 1996 guidelines were weak and seriously flawed from the outset. But now, 30 years later, they are a laughingstock to serious independent scientists who are not on the industry payroll. Literally thousands of peer reviewed published studies demonstrate statistically significant linkages between exposure to wireless radiation from wireless devices and wireless transmission facilities and serious negative health impacts to humans. While the exact etiology has not definitively been determined for all diseases and negative health impacts, persistent wireless radiation exposure appears to lead to oxidative stress which is well known to precipitate a cascade of negative human health conditions. Similarly, serious scientific studies of the impact of wireless radiation exposure on flora and fauna are ongoing, and already numerous studies show negative impacts on birds, bats, bees, and flora. Fortunately, in response to this request for public comments, many of these contemporary studies are being introduced into the administrative record for the FCC’s consideration. The problem is that under Chairman Carr’s reign, the agency takes a wholly dismissive view of the dangers of wireless radiation exposure to both humans and flora and fauna. Even under his Democratic predecessor, the FCC failed to take the DC Circuit’s mandate seriously. It has done nothing at all for 4 ½ years. The panel should find the FCC in contempt of court. That deserved outcome is unlikely. Equally unlikely is the FCC giving the submitted evidence herein an objective review and a fair shake. However, what’s new and what gives practitioners like me some hope is that HHS has also opened a proceeding requesting public comment on essentially the same issue. HHS actually has expertise in examining the health impacts of wireless radiation exposure to humans – or at least in studying the issue and coming up with informed conclusions and recommendations. I understand that HHS will study the issue – and hopefully issue well-informed recommendations which the FCC will have to follow inasmuch as the FCC has no internal expertise. My experience in dealing with the FCC on various cell tower matters is that the FCC has operated entirely against the public interest. Its rulings in the matters in which I have been involved have always been conclusory and are sloppy and usually contain seriously errors of fact. Most federal agencies in my experience are filled with people trying to do good for the public at large. The FCC is interested only in protecting the revolving door between the industry and the agency and thus, protects only the industry’s interests. Respectfully, Robert J. Berg

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. Mevissen et al. (2025): Effects of radiofrequency electromagnetic field exposure on cancer in laboratory animal studies, a systematic review – Reported high-certainty evidence of increased brain gliomas and heart schwannomas in male rats under studied exposure conditions. A corrigendum was published in 2026. 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 several friends and family members have been affected by cancer and NO ONE KNOWS WHY. 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. Here is just one study I believe the FCC should review when addressing the concerns about wireless radiation: • McCredden, McLean & Steinemann (2026): Wireless sensitivity and co-morbidities: A prevalence study in Australia, Canada, and the United States – Examined the prevalence of self-reported wireless sensitivity and co-occurring health conditions in the United States, Canada, and Australia, without establishing causation. 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 writing to express my deep concern about the potential health effects of radiofrequency (RF) radiation from cell towers and to ask that the FCC take a more serious, proactive role in investigating the experiences of individuals and families who believe their health has been affected by exposure to these emissions. In 2007, a cell tower was erected near our home. Following its installation, my daughter began experiencing a series of serious and debilitating health problems that dramatically altered the course of her life. The timing of these symptoms and the profound impact they have had on her life have left our family deeply concerned about the possible relationship between her health and her exposure to RF radiation. Her symptoms were so severe that her school attendance became extremely poor, and she was on the verge of being forced into homeschooling. As parents, we were desperate to understand what was happening to our daughter and to find answers that would allow her to live a normal, healthy life. We pursued extensive medical care, including multiple appointments with specialists in cardiology, neurology, and other practitioners, including neurological chiropractors. We even spent ten days at the Carrick Brain Center trying to determine the cause of her debilitating symptoms. Among other problems, she experienced stabbing abdominal pains, chronic migraines, and numbness in her arm when she used a cell phone. These were not minor inconveniences; they interfered with her ability to attend school, participate in everyday activities, and enjoy the quality of life every young person deserves. She was eventually diagnosed with an autoimmune disorder, electrosensitivity, and postural orthostatic tachycardia syndrome (POTS). Despite years of effort to understand and manage her conditions, the consequences have been devastating. My daughter is now 34 years old and remains unable to work outside the home. Our family has gone to extraordinary lengths to investigate and reduce potential environmental exposures in our home. We have had the house thoroughly checked for electrical wiring problems. She sleeps in a specially tented bed surrounded by silver-lined material intended to block wireless signals. We have eliminated Wi-Fi from our home and turn off the electrical power to the rooms surrounding her bedroom every night. These are not steps a family takes lightly. They reflect years of concern, searching for answers, and trying to give our daughter the best possible chance of improving her health. I recognize that the timing of an exposure and the onset of symptoms do not, by themselves, establish medical causation. However, the fact that her symptoms began after the cell tower was erected, followed by years of serious illness and disability, raises questions that deserve careful, independent scientific investigation rather than dismissal. Meanwhile, more cell towers and wireless infrastructure continue to be added to our surrounding area. For families who are concerned about RF exposure, it increasingly feels as though there is nowhere to go to escape it. We need reliable research, transparent information, and meaningful consideration of the people who report serious health problems and whose lives have been profoundly affected. I respectfully urge the FCC to: 1. Support and facilitate independent, long-term research into the potential health effects of RF exposure, including the effects of chronic exposure from multiple wireless sources over time. 2. Ensure that research examines a broad range of reported health concerns, including neurological symptoms, migraines, autonomic dysfunction, and other chronic conditions, while using rigorous scientific methods to establish what relationships, if any, exist. 3. Reevaluate existing exposure standards as new evidence emerges, with transparent scientific review and appropriate consideration of uncertainty, vulnerable populations, and cumulative environmental exposure. 4. Improve transparency and public access to information about cell tower locations, emissions, compliance measurements, and the scientific evidence used to establish safety standards. 5. Create a meaningful process for documenting and investigating reported health concerns from individuals and families who believe their symptoms began or worsened following the installation of nearby wireless infrastructure. 6. Consider precautionary measures and appropriate policy changes if credible evidence identifies risks that current standards do not adequately address. My family has spent years trying to understand why our daughter became so ill and why, at 34, she still cannot work outside the home. We cannot go back and change what happened, but we can ask that our experience contribute to a more thorough examination of a public health question that deserves attention. This is not simply an argument about technology. It is about people, families, and the responsibility to investigate legitimate concerns with openness, scientific rigor, and compassion. Wireless technology continues to expand rapidly, and the public deserves confidence that its safety standards are based on the best available evidence and are revisited when warranted. I ask the FCC to take these concerns seriously, to encourage independent research, and to consider what changes may be necessary to better protect public health. Families should not have to spend decades searching for answers while watching a loved one struggle with chronic illness and disability. Thank you for your attention to this important matter. I hope the FCC will give serious consideration to the experiences of families like ours and take meaningful steps toward obtaining the answers that are still needed. Sincerely, Beth Osborn Carmel, IN 46032

As a mother I advocate for safer tech habits, including using speakerphone and wired headphones, keeping wireless devices away from one self and my children's bodies when practical, turning Wi-fi off when not in use and utilizing direct hard wire connection when feasible. Therefore I believe there should be more regulations and studies to limit this radio frequency exposure, mothers should not have to choose between benefits of modernized tech and the health of ones family.

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: https://link.springer.com/article/10.1186/s12940-025-01220-4#Sec15 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: As this is a global issue please accept my submission from the UK. I understand there are similar levels of permitted RF-EMR (Radio Frequency Electromagnetic Radiation) in the USA and UK. Also please understand that I started experiencing symptoms years before I understood about RF-EMR or was introduced to the idea of being EHS (Electro Hypersensitive) so my symptoms are NOT psychosomatic. Interestingly I discovered recently that the severity of my symptoms has increased in line with the rising levels of RF-EMR in the UK from mobile phone masts and mobile phones, Wifi routers, SMART meters and appliances, satellites etc. The first symptom I experienced was in the early 2000’s when I used a cordless phone for the first time. I started to make the call and my head felt hot and my brain felt confused. I had to stop making the call and put the phone down. I was shocked. Then I noticed, as mobile phones were upgraded to 3G and then 4G, my head felt hot where my mobile phone was close to my ear and my brain felt confused. I could not continue to use my mobile phone. When the router in our house became wireless rather than wired and my son bought a computer that connected to the router wirelessly, I felt disorientated and as though I might collapse when standing between the router and his computer. Interestingly the engineer installing the computer knew exactly what I was experiencing and wired the computer via ethernet immediately. Since then all our computers, landline phone (via internet now), TV etc are all wired via ethernet cables. This has improved my health but has been very expensive. My health went into, what I would describe, chronic RF-EMR sensitivity, when I started to make regular car journeys through a large town with 4G and 5G masts in 2022. As I drove past 2 mobile phone masts that were positioned close together (causing interference?) I felt ill. I started experiencing tinnitus and heart palpitations. When I am in a high RF-EMR environment for any length of time I can also experience vertigo and I feel as though my body is shutting down and I might collapse. The tinnitus and heart palpitations became persistent symptoms, so I investigated protecting myself with clothing and a Blushield device. Also grounding helps. All my symptoms improve when I have been in a low RF-EMR environment for some time eg when I am in the countryside. With increasing ubiquitous levels of environmental RF-EMR in the town where I live, I have now become quite isolated. I only make occasional short trips to my local town for necessary shopping. I do not use public transport due to possible Wifi on trains and buses and being near other travellers’ mobile phones. I could not even contemplate going on a plane for a holiday abroad. I only make short visits to friends and family due to Smart Meters and Wifi in their house, and I take a router shielding bag for use when agreed. Some friends and family I no longer visit when there are numerous Smart appliances as well at a router and Smart meter at their house. I do not go to the cinema or theatre. The list goes on of the restrictions to my life to avoid my health being impacted further. If this is affecting me so acutely, how many others are going to be affected by long term and increasing levels of exposure, and what about the animal, insect and plant life? It is utter madness! I do not consent to these levels of environmental RF-EMR. Surely this must contravene the Nurenberg Code? Something needs to be done. 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.

Posting for a Friend that wishes to remain anonymous. We'll call the person Jade. Here is Jade's Story: I was comfortable and healthy. In 2010, when my area switched from analog to radio utility meters (aka "SMART" meters), and T.V.s were switched form analog to digital, I went from feeling comfortable in my bedroom and in the world, to very uncomfortable. It took a while to figure out what was going on. I met others that were suffering and felt great dis-ease with this technology. Also more towers and antennas were added to the hill outside my bedroom window. I learned that by turning off or unplugging electronics, I felt well again. Also re moving myself to a healthy location, I immediately felt well again. This horror/toxic trespass has changed my life. Can you imagine how difficult it can be to find a safe and healthy place to live and to work? I did a count of 100 people in my everyday life. It turns out 20% of them felt ill around this technology, ie. man-made, toxic non-ionizing radiation. I figured that probably about 2x as many (40%) are not feeling well around it. They were just not aware of the symptoms of radio poisoning. Not connecting the dots. I later read that scientists that had studied the matter came up with the same results (40% of the population suffering in an obvious way)! We have over 50,000 published peer-reviewed studies showing harm from these non-native emfs, including pollinator collapse, childhood leukemia, and cancerous tumors, ill health of insects and animals and plants, problems affecting the brain, the heart, the blood, the DNA, due to this technology. It is the fiduciary responsibility of the government to protect the health, welfare and safety of the people. A Swedish oncologist, in the early 1900's, wisely said that Anything that is harmful to one living cell is harmful to all living cells. I think this is true. Never put tracking devices on insects or animals! These days my symptoms around too much radio/microwave frequency include: stress, fatigue, pain in the ears and head, feeling frazzled, heart palpitations, and general discomfort. How many are feeling ill and not connecting the dots? How many doctors are not connecting the dots? We must take an honest look at this non-native and harmful technology now. We must protect life on Planet earth for all to thrive.Landlines, ethernet, cable and wired technology are much safer than wireless. Let's use and encourage wired tech as much as possible. If not now, when will you take your fiduciary responsibilty seriously, and mindfully curb and regulate this technology, so that life may thrive once again? Thank you for hearing us, Anonymous Jade

Posting for a Friend that wishes to remain anonymous. We'll call the person Jade. Here is Jade's Story: I was comfortable and healthy. In 2010, when my area switched from analog to radio utility meters (aka "SMART" meters), and T.V.s were switched form analog to digital, I went from feeling comfortable in my bedroom and in the world, to very uncomfortable. It took a while to figure out what was going on. I met others that were suffering and felt great dis-ease with this technology. Also more towers and antennas were added to the hill outside my bedroom window. I learned that by turning off or unplugging electronics, I felt well again. Also re moving myself to a healthy location, I immediately felt well again. This horror/toxic trespass has changed my life. Can you imagine how difficult it can be to find a safe and healthy place to live and to work? I did a count of 100 people in my everyday life. It turns out 20% of them felt ill around this technology, ie. man-made, toxic non-ionizing radiation. I figured that probably about 2x as many (40%) are not feeling well around it. They were just not aware of the symptoms of radio poisoning. Not connecting the dots. I later read that scientists that had studied the matter came up with the same results (40% of the population suffering in an obvious way)! We have over 50,000 published peer-reviewed studies showing harm from these non-native emfs, including pollinator collapse, childhood leukemia, and cancerous tumors, ill health of insects and animals and plants, problems affecting the brain, the heart, the blood, the DNA, due to this technology. It is the fiduciary responsibility of the government to protect the health, welfare and safety of the people. A Swedish oncologist, in the early 1900's, wisely said that Anything that is harmful to one living cell is harmful to all living cells. I think this is true. Never put tracking devices on insects or animals! These days my symptoms around too much radio/microwave frequency include: stress, fatigue, pain in the ears and head, feeling frazzled, heart palpitations, and general discomfort. How many are feeling ill and not connecting the dots? How many doctors are not connecting the dots? We must take an honest look at this non-native and harmful technology now. We must protect life on Planet earth for all to thrive.Landlines, ethernet, cable and wired technology are much safer than wireless. Let's use and encourage wired tech as much as possible. If not now, when will you take your fiduciary responsibilty seriously, and mindfully curb and regulate this technology, so that life may thrive once again? Thank you for hearing us, Anonymous Jade

Public Comment to the Federal Communications Commission Re: ET Docket No. 13-84 — Reassessment of FCC Radiofrequency Exposure Limits and Policies I am submitting this comment as a concerned resident and parent regarding the serious imbalance between federal telecommunications policy, public health protections, and the rights of local communities to determine whether wireless telecommunications infrastructure should be constructed near their homes and schools. The Telecommunications Act of 1996 fundamentally altered the ability of local governments to protect their communities from unwanted wireless infrastructure. Under Section 704, codified at 47 U.S.C. § 332(c)(7)(B)(iv), local governments are prohibited from regulating the placement, construction, or modification of wireless facilities based on the environmental effects of radiofrequency emissions when those facilities comply with FCC regulations. For nearly three decades, this restriction has placed residential communities in an extraordinarily difficult position. Residents may express concerns about long-term RF exposure, proximity to children, cumulative exposure from multiple installations, or the adequacy of existing safety standards, yet their elected local officials are severely restricted in their ability to consider those concerns when deciding whether to approve a tower. In practical terms, federal law has deprived communities of meaningful local authority over one of the very issues that matters most to them: whether continuous, involuntary RF exposure near their homes and schools presents an acceptable risk. As a resident in a suburban neighborhood marketed to buyers as a "healthy living" community, I have seen the number of cell towers near my home grow from approximately 40 towers four years ago, to over 100 towers currently. This includes three currently in progress, which were forced through administrative approvals without opportunity for public notifications and public hearing. Wireless communications development companies are abusing the liberal policies established under the Federal Telecommunications Act, forcing tower construction upon residential neighborhoods, against the will of the local community. Not only does this deprive the community of an opportunity to voice opposition, but it also takes away freedom of choice for exposure to something that the American Cancer Society cannot definitively declare "safe" or that it does not cause cancer, due to lack of long term studies to substantiate that it does not cause cancer. Further, the limited studies that exist, are based upon estimated exposure levels and not actual exposure levels, and are limited to exposure from one towers RF emissions, rather than considering the collective level of exposure from all sources. If someone already has 5 towers within 1,000 yards from their home, adding an additional tower is not necessarily within tolerable safety limits because the estimated exposure from the new tower does not consider the cumulative levels emitted from all towers and sources. Because populated areas have limited spaces to erect these towers, the wireless communication companies are aggressively targeting unincorporated areas, public utility easements, and even school grounds. Many school districts in Austin TX are entering into lease agreements with wireless communications companies, erecting towers on top of schools, which poses a risk to student health. My own children have a cell tower right on top of their middle school. I personally have a BRCA mutation and I am more susceptible to DNA damage from RF. I may have passed my gene to my children. It is wrong that there is RF exposure continually forced upon us in our own backyard, and we should have the right to refuse. There should be a moratorium on new cell tower construction in residential areas and school zones until such time that there is long term safety data definitively proving that it is completely safe with no risk. I recognize that reliable wireless communication is important. However, the public's need for connectivity should not automatically outweigh the rights of residents, parents, and communities to participate meaningfully in decisions affecting their immediate living environments. I am particularly concerned about the placement of wireless infrastructure on or near school properties. Schools should be places where children's health, safety, and welfare are the foremost considerations. Yet school districts and telecommunications companies may enter into arrangements allowing wireless infrastructure on educational property, potentially generating revenue while exposing surrounding families and students to an installation they may have little practical ability to oppose on RF health grounds. The fact that a telecommunications facility complies with existing FCC exposure limits should not automatically end the public health discussion, especially when those limits themselves are the subject of ongoing scientific and regulatory scrutiny. The 2021 decision in Environmental Health Trust v. FCC illustrates why public confidence cannot rest solely on the assertion that existing standards are adequate. The court found deficiencies in the FCC's explanation for retaining its RF exposure limits in light of issues raised in the administrative record, including noncancer health effects, children's health, and long-term exposure. Communities should not be legally prevented from considering potential RF health impacts while the federal agency responsible for establishing the governing exposure limits is still addressing questions concerning the adequacy of those standards. This creates a fundamental accountability problem: federal law restricts local governments from considering RF health concerns, while residents must rely on federal standards that they have no meaningful ability to challenge through the local tower approval process. I urge the FCC to take the following actions: Conduct a comprehensive, transparent, and independent reassessment of RF exposure standards, including long-term exposure, potential nonthermal biological effects, children's health, and cumulative exposure from multiple wireless installations. Give particular consideration to wireless facilities located near residences, schools, childcare facilities, and other locations where children and families spend substantial amounts of time. Require meaningful public disclosure of proposed antenna configurations, operating frequencies, projected RF exposure, and cumulative exposure from existing nearby facilities before new installations are approved. Establish stronger public participation and independent exposure-assessment procedures for wireless infrastructure proposed near residential neighborhoods and schools. Recommend that Congress revisit the preemption provisions of the Telecommunications Act of 1996 so that local governments can meaningfully consider RF exposure and public health concerns when evaluating proposed wireless facilities. Ensure that the burden of demonstrating compliance with scientifically justified safety standards rests with wireless infrastructure operators, rather than requiring individual residents to prove harm after a facility has already been constructed. I am not advocating for the elimination of wireless communication. I am advocating for a regulatory framework that recognizes that technological advancement and public health protections are not mutually exclusive. The wireless infrastructure landscape has changed dramatically since 1996. The number, density, configuration, and proximity of wireless installations to homes and schools have evolved, and federal oversight must account for those changes. No community should be forced to accept a wireless installation near its homes or schools without meaningful consideration of health and safety concerns simply because federal law prevents local officials from evaluating those concerns. The FCC has an obligation to ensure that the standards relied upon to override local decision-making are supported by a thorough, transparent, and current scientific assessment. I respectfully urge the Commission to address these concerns and to recognize the consequences that federal preemption has had on residential communities and families across the country. Thank you for considering my comment.

I appreciate being asked by HHS for comments on this topic. The FCC has not done so in the thirty years since the Telecommunications Act was enacted in 1996. I do not have reason to believe that I have been injured physically. However, I do not want a Smart Meter on my house and Pennsylvania is the only state that does not allow opting out which is a negation of the liberty given to us in the Constitution: “life, liberty and the pursuit of happiness.” Many studies have been done over a period of many years that show the effects of EMF’s (Electro Magnetic Frequency) on the health of humans, animals and the environment. For any industry to not test their products for more than thirty years is ludicrous and dangerous. The wireless devices available today are completely different from what available in 1996. Smartphones didn’t even exist yet. 4G and 5G were unheard of. Children are particularly vulnerable to this damage as their bodies are smaller and spend more time outside where they can be near sources of EMR (Electro Magnetic Radiation). The FCC clearly only cares about the bottom line and not the welfare of the taxpayers who support them. I learned about the dangers of cell phone radiation twenty years ago, not from the industry, but from independent doctors and researchers. It’s time for the wireless industry to prove the safety of their products. Until then, those products are to be viewed as unsafe and the industry to be untrustworthy. Note the following review: Investigation of the Adverse Health Effects of Cell Phone Radiation and Propose Solutions to Minimize Them: A Systematic Review https://pmc.ncbi.nlm.nih.gov/articles/PMC11111148/ Sec. Kennedy has promised the American people, “gold-standard science.” It’s time for the FCC to do the same.

Posting for a Friend that wishes to remain anonymous. We'll call the person Jade. Here is Jade's Story: I was comfortable and healthy. In 2010, when my area switched from analog to radio utility meters (aka "SMART" meters), and T.V.s were switched form analog to digital, I went from feeling comfortable in my bedroom and in the world, to very uncomfortable. It took a while to figure out what was going on. I met others that were suffering and felt great dis-ease with this technology. Also more towers and antennas were added to the hill outside my bedroom window. I learned that by turning off or unplugging electronics, I felt well again. Also re moving myself to a healthy location, I immediately felt well again. This horror/toxic trespass has changed my life. Can you imagine how difficult it can be to find a safe and healthy place to live and to work? I did a count of 100 people in my everyday life. It turns out 20% of them felt ill around this technology, ie. man-made, toxic non-ionizing radiation. I figured that probably about 2x as many (40%) are not feeling well around it. They were just not aware of the symptoms of radio poisoning. Not connecting the dots. I later read that scientists that had studied the matter came up with the same results (40% of the population suffering in an obvious way)! We have over 50,000 published peer-reviewed studies showing harm from these non-native emfs, including pollinator collapse, childhood leukemia, and cancerous tumors, ill health of insects and animals and plants, problems affecting the brain, the heart, the blood, the DNA, due to this technology. It is the fiduciary responsibility of the government to protect the health, welfare and safety of the people. A Swedish oncologist, in the early 1900's, wisely said that Anything that is harmful to one living cell is harmful to all living cells. I think this is true. Never put tracking devices on insects or animals! These days my symptoms around too much radio/microwave frequency include: stress, fatigue, pain in the ears and head, feeling frazzled, heart palpitations, and general discomfort. How many are feeling ill and not connecting the dots? How many doctors are not connecting the dots? We must take an honest look at this non-native and harmful technology now. We must protect life on Planet earth for all to thrive.Landlines, ethernet, cable and wired technology are much safer than wireless. Let's use and encourage wired tech as much as possible. If not now, when will you take your fiduciary responsibilty seriously, and mindfully curb and regulate this technology, so that life may thrive once again? Thank you for hearing us, Anonymous Jade