Research, evidence & monitoring

I hereby object to the Federal Communications Commission’s continued reliance on RF radiation exposure limits that have not been adequately updated to reflect current scientific evidence, modern wireless technologies, cumulative and long-term exposure, and the potential for non-thermal biological effects. The public deserves safety standards based on current, independent scientific research, transparent risk assessment, and the precautionary consideration of potential harm to human health. Regulatory standards must be periodically reassessed as new evidence emerges, rather than presumed adequate simply because they were adopted decades ago. I respectfully request that this objection be entered into the official record and that the FCC undertake a comprehensive, independent review of its RF radiation exposure standards, including their scientific basis, adequacy for contemporary technologies, and protection of residents, workers, and other potentially exposed populations. From my personal experience: I have been overexposed to EMF and RF radiation from unpermitted 5G wireless base station installed right above our living quarters. This cluster of transmitters were operated under FCC Experimental Radio License utilizing untested, unauthorized prototype equipment without any prior testing for RF/EMF emission compliance. Our family started to feel ill effects right after the activation of these devices and the symptoms got worst with each passing day. It got so bad that we ultimately had no other choice then to relocate to a new apartment to get away from this constant exposure. My mother now suffers from EHS and other symptoms which greatly affected quality of her life. Despite the many complaint we reported to FCC of the nature of the antennas, being used for experimentation and testing and the site not being registered and so forth, FCC's response was that the equipment is operating within the FCC limits even though they could not provide such verification themselves for such unregistered prototype. I urge you to update your safety standards based on recent studies provided to you by many scientist from all over the world so general public has a chance for better protection and that people do not have to go through similar experience of loosing their home or health. Sincerely, Oliver Kabilka

For 9 years I have been researching and lecturing on the biological effects of wireless radiation, at conferences, on podcasts, and to legislatures. I have looked at 100's, possibly 1000's, of research results among the more than 10,000 published studies. I work with people who have developed extreme sensitivity to electromagnetic radiation (EMR), and seen positive results when the radiation is removed. My family has been affected by EMFs. We have had building biologists and EMF remediation experts in our home, where shielding has helped. Please see this DOCUMENT containing hundreds of references to scientific evidence of harm: https://docs.google.com/document/d/1Cv_XZ4NdDBI3zl62aSJAfCx7GlqxC2PVh22ijw4rYAg/edit?usp=sharing

I have 2 grandchildren in public schools and am very worried about health radiation exposure from the wireless technology used in our schools. The risks include cancer (which is the 2nd cause of death in children). The core issue is that wireless technology was implemented, without consideration of the impact on human health, based on the 1996 FCC Regulation. Since then, new scientific studies have proven links to health risks from wireless radiation. I learned first-hand about illness from wireless exposure when I became ill in my own home. Having spent my career as a university librarian, I educated myself about this. The science points to strong associations between wireless radiation and multiple illnesses. The [U.S.] National Toxicology Program reports that wireless radiation causes DNA damage which results in cancer. Dr. Anthony Miller, former senior advisor to the WHO states that it should be promoted from 2B to 1A, a human carcinogen. In fact, this radiation is absorbed deeper into the bodies of children than into adults. The danger is not only in years to come, but NOW. For example, at Fay School in Southboro, MA, children exposed to Wi-Fi became ill with nose-bleeds, headaches, and nausea. The following steps should be implemented for schools: 1. Require that all computers within schools be hard-wired and eliminate wireless transmission. [This has already been done in Europe]. 2. To immediately minimize WI-FI signals, instruct school personnel to keep wireless routers and devices off when not in use. 3. Since funding may be a challenge, negotiate with the industry that brought in this toxic technology to subsidize the hard-wiring of school computer systems. Our children’s health should take top priority over corporate profit. 4. In addition to the many hours of exposure inside school, there is radiation from outside. Please oppose the installation of 5G antennas within a half-mile of school buildings [as has been done in Europe]. 5G increases radiation exposures manyfold, and at a crucial time of their development, children will be even more bombarded. Given that 1 in 3 people will develop cancer in their lifetime, please take action to protect ALL our children, teachers, and staff! [See sources below] Links to Health Effects of Wireless Radiation "Generation Zapped" https://generationzapped.com/watch-the-film/ Trailer to “Generation Zapped”: https://www.youtube.com/watch?v=Kj_30YDVkaI Understanding EMF's , including Impact on Children https://sites.google.com/site/understandingemfs/home Cell towers: https://sites.google.com/site/understandingemfs/cell-towers Childhood cancer rates by state: https://statecancerprofiles.cancer.gov/quick-profiles/index.php?statename=massachusetts Schools Banning Cell-Towers The Los Angeles Unified School District has adopted several Board resolutions that ban cell towers on or near schools: http://emrpolicy.org/news/headlines/29may09_lausd_press_release.pdf http://sunroomdesk.com/2009/12/10/lausd-calls-for-increased-setbacks-advance-notification-on-locations-near-schools/  See the Environmental Health Trust for information to provide schools: https://ehtrust.org/cell-tower-proposed-near-home-childs-school-need-scientific-resources-health-safety/ Jeromy Johnson, M.S. Engineering https://www.youtube.com/watch?v=F0NEaPTu9oI&t=11s Sharon Goldberg, M.D. https://www.youtube.com/watch?v=CK0AliMe-KA Environmental Health Trust https://ehtrust.org/science/whoiarc-position-on-wireless-and-health/ Huntington NY Accoustimeter measuring radiation from "small cells" https://www.youtube.com/watch?v=pcozqp5Op78 Children sickened from wi-fi at Fay School, Southboro, MA See https://www.boston25news.com/news/parents-say-schools-wifi-signal-making-son-sick-1/7363498 Major cities revolt against FCC’s proposed small cell deployment rules https://www.fiercewireless.com/wireless/major-u-s-cities-revolt-against-fcc-s-proposed-small-cell-deployment-rules "Burlington Union" report of Verizon's withdrawal of application for 7 "small cells" in Burlington, MA http://burlington.wickedlocal.com/news/20181026/verizon-withdraws-burlington-cell-tower-application Among children ages 0 to 14 years, it is estimated that, in 2018, 10,590 will be diagnosed with cancer and 1,180 will die of the disease (1). Among adolescents ages 15 to 19 years, about 5000 will be diagnosed with cancer and about 600 will die of the disease. https://www.cancer.gov/types/childhood-cancers/child-adolescent-cancers-fact-sheet Presentation by Cece Doucette at Burlington, MA Library https://www.youtube.com/watch?v=JX3DS6cK53Q&t=110s BCAT summary of Burlington presentation https://www.youtube.com/watch?v=2KyOzIyxRo8

To Whom it May Concern: Please think about the future of the children in your lives by looking at current research on how the existing RF exposures may be harming us all and our environment. Thank you.

Comment in Response to Public Notice DA 26-997, ET Docket No. 13-84 This comment addresses FCC’s methodological criteria for assessments of responses to the mentioned Public Notice as one may interpret from its questions in the FCC Public Notice page 7. These criteria are by and large those used by IEEE ICES and ICNIRP. The methodological criteria used by IEEE ICES and ICNIRP to identify thresholds for RF-EMF caused harmful health effects, are flawed – and so for several reasons detailed in referenced material: 1. At non-thermal levels, these standards explicitly restrict themselves to acute effects only, not accepting temporarily annoying effects as harmful effects (e.g., not tinnitus…), nor long term effects (e.g., not cancer, diabetes, …), and only effects objectively observable (e.g., not headache, nausea, , …). Effects have to be proven by research methods primarily appropriate for identifying thermal effects, even when effects are well demonstrated by acceptable methods not to be thermal. Research proving effects, but not using thermally based methods is regarded as no or poor evidence, hence dismissible. 2. Such thermal methodological criteria and stringent demands for proof may all be traced back to historical contexts of research on ionizing radiation effects and non-ionizing radiation’s thermal effects in which they are defensible. In the context of non-thermal effects of non-ionizing radiation they are not. However, they have been made part of standards in which they function as a bulwark against accepting any effects from RF-EMFs below thermal levels. Using such a thermal methodology produces conclusions of «no health effects found» as an artefact, i.e. as a result of the methodology as such, and is thus without any evidentiary power – just flawed. Such methodology also means dismissing a precautionary approach, as the scope is set far too restrictive. 3. The ICNIRP 2020 and ICES C95.1 2019 standards, by which, a.o., 5G deployment were legitimized worldwide, are based on research studies and assessments based on essentially these same methodological elements, and thus flawed, having no predictive value for non-thermal health risk identification. 4. The assessments carried out by WHO’s The International EMF Project in order to be used as a platform for RF-EMF standard revisions, have been required to use study protocols based on such thermally based methodology, and therefore flawed, too (apart for the one assessment which did not accept using such a thermal protocol). Details underpinning the statements above are found in the following scientific papers and responses to the FCC and HHS Request for Information: Nordhagen EK, Flydal E. WHO to build neglect of RF-EMF exposure hazards on flawed EHC reviews? Case study demonstrates how "no hazards" conclusion is drawn from data showing hazards. Rev Environ Health. 2024 Jul 10;40(2):277-288. doi: 10.1515/reveh-2024-0089. PMID: 38981511. Nordhagen EK, Flydal E. Self-referencing authorships behind the ICNIRP 2020 radiation protection guidelines. Rev Environ Health. 2022 Jun 27;38(3):531-546. doi: 10.1515/reveh-2022-0037. PMID: 35751553. Else K. Nordhagen, Einar Flydal, Cornelia Waldmann-Selsam, and Vibeke Frøkjær Jensen: Comment in Response to FCC Public Notice DA 26-997, ET Docket No. 13-84, Submitted Oct.20.2026. https://bit.ly/4i6XM0h Else Nordhagen, Vibecke Frøkjær, Einar Flydal, Cornelia Waldmann-Selsam, Fiorella Belpoggi: Quality criteria for RF/EMF Health-Risk Assessments, Essential Criteria for Assessing Health Risks from Wireless Radiation, Response to HHS Request for Information, Submitted Oct.20.2026. https://bit.ly/3UCWjFO It follows that the methodology used to assess RF-EMF health effects should be thoroughly revised. As shown in the mentioned references, more relevant methodological frameworks for assessments do exist. Signed by Einar Flydal Oslo, Norway, Oct. 20, 2026 Einar Flydal is a Master of political science from the University of Oslo, Norway, and Master of Telecom Strategy and Technology Management from the Norwegian Polytechnical University (NTNU), Trondheim, Norway. Before retiring, Flydal was a Senior Researcher at Telenor Research & Development. He has also served as a Senior Strategy Adviser in the Telenor corporate management, and, a.o., as adjunct assistant professor at NTNU. Since 2010, he has studied and published, first and foremost for the general public in Scandinavia, on EMFs, health and environmental impacts. He chaired the Norwegian mirror commitee of the development of the ISO 26000 standard on the social responsability of organizations.

Federal Communications Commission (FCC) Public Comment on Reopened Docket Regarding Wireless Radiation Safety Limits Dear Commissioners, As a deeply concerned citizen who values both technological innovation and the health of my family, I am writing to urge the FCC to completely overhaul its outdated radiofrequency (RF) radiation exposure guidelines. The current standards, established decades ago, rely exclusively on preventing thermal (heating) harm. However, as an everyday user watching our children grow up surrounded by a 24/7 blanket of Wi-Fi, cell towers, and smart infrastructure, I know that our constant, real-world exposure looks nothing like the brief laboratory simulations used to set these guidelines. In my own home, I have taken steps to hardwire our internet connection to protect our sleep and focus, but we cannot escape the dense web of neighborhood cell towers outside our home and when visiting the towns and cities. The D.C. Circuit Court correctly ruled in 2021 that the FCC failed to address severe gaps in its safety logic. I urge you to look at the independent, peer-reviewed data disproving the assumption that non-thermal radiation is harmless: • Definitive Evidence of DNA Damage: The U.S. National Toxicology Program (NTP) comprehensive $25 million study proved that chronic exposure to cell phone radiation causes significant, measurable DNA damage—specifically in the frontal cortex and hippocampus—as well as clear evidence of rare malignant tumors. DNA damage occurs without any tissue heating, directly undermining the FCC's regulatory foundation. • Unique Vulnerabilities of Children: Our children's skulls are thinner, and their nervous systems are still dynamically developing. Millions of students sit directly under powerful industrial Wi-Fi routers all day. Compiled data from the BioInitiative Report establishes that low-intensity, non-thermal RF radiation alters gene expression and triggers neurological impacts at levels far below current FCC limits. • Environmental and Wildlife Disruption: Our ecosystem is suffering the collateral damage of unchecked wireless infrastructure. Multi-author analyses show that continuous RF radiation alters biological rhythms, disrupts the navigation patterns of crucial pollinators like bees, and inflicts oxidative stress on local flora and fauna. The FCC must stop deferring to industrial convenience and prioritize living biology. I ask that you adopt protective, biologically-based exposure standards that reflect the independent science of today. Sincerely, Marcia Keizer Yelm Washington

I am writing regarding the FCC’s response to the D.C. Circuit Court of Appeals’ remand concerning its decades-old radiofrequency (RF) radiation exposure guidelines. The Court directed the FCC to provide a reasoned explanation for its determination that its guidelines adequately protect humans against harmful effects of RF radiation unrelated to cancer. Specifically, the court required the FCC to address the impacts of RF radiation on children, the health implications of long-term exposure, the ubiquity of wireless devices and technological developments, impacts on the environment, and the adequacy of the FCC’s testing procedures for cell phones and other portable devices. The FCC should fully consider evidence and real-world experiences concerning the health and environmental impacts of wireless radiation, including non-cancer health effects, impacts on children, long-term and cumulative exposure, cancer, and impacts on wildlife and the environment. Here is just one study I believe the FCC should review when addressing the concerns about wireless radiation: Morgan, Kesari & Davis (2014): Why children absorb more microwave radiation than adults: The consequences – Reviewed evidence that children may absorb more wireless radiation than adults due to anatomical and physiological differences, raising questions about the adequacy of existing exposure standards. The FCC is not a health agency and does not have expertise in medicine, biology or public health. Yet, the agency continues to assert authority over RF exposure standards and is preparing to reach conclusions about whether its existing guidelines adequately protect the public. I urge the FCC to recognize the critical role of federal health agencies, including the U.S. Department of Health and Human Services, and to rely on appropriate health and biological expertise when addressing the issues identified by the court. I urge the FCC to give meaningful consideration to the experiences and evidence before it and to fully address each of the issues identified by the court.

The world we live in, from electrical frequencies within the body to the Schumann Resonance of the planet itself, works on frequencies. While many frequencies could be labeled as beneficial, there are MANY that are not. The types of radiation that eminate from dirty electricity, WiFi, Bluetooth, "smart" meters, LED lights, Cell phones/towers, some musical frequencies, and many many from military devices are extremely harmful to human health. Please do the righ thing for once and force any company to comply with third-party studies into the harmful effects of the frequencies they are putting out and make data reporting MANDATORY!

Re: ET Docket No. 13-84, Public Notice DA 26-997 I write as a concerned member of the public to urge the Commission to update its radiofrequency (RF) electromagnetic radiation (EMR) exposure limits, adopted in 1996 and based only on heating effects. The court’s remand. In Environmental Health Trust v. FCC, 9 F.4th 893 (D.C. Cir. 2021), the court found the Commission failed to explain its dismissal of evidence of non-cancer harms. That evidence has grown. The International Commission on the Biological Effects of Electromagnetic Fields concluded that current science invalidates the assumptions behind the FCC limits (ICBE-EMF, Environmental Health, 2022;21:92). Large animal studies. The U.S. National Toxicology Program found clear evidence of malignant heart schwannomas in male rats exposed to RF EMR, along with evidence of DNA damage (NTP TR-595, 2018). The Ramazzini Institute independently found the same tumor type at exposures modeled on cell towers (Falcioni et al., Environmental Research, 2018;165:496-503). The WHO’s International Agency for Research on Cancer classifies RF EMR as possibly carcinogenic, Group 2B (Baan et al., Lancet Oncology, 2011). Sleep and well-being. Controlled studies show RF exposure alters sleep EEG and cerebral blood flow (Huber et al., Journal of Sleep Research, 2002;11:289-295). Sleep underlies immune, hormonal and mental health, so even modest disruption across a population matters. Children. Children absorb more RF energy in the brain and bone marrow than the adult model used to set the limits (Gandhi et al., Electromagnetic Biology and Medicine, 2012;31:34-51). Testing based on an adult male head does not protect them, and today’s children are exposed from birth, around the clock. Long-term, ubiquitous exposure. When the limits were set, exposure was brief and occasional. Today it is continuous: phones carried against the body, Wi-Fi, smart meters and dense 5G infrastructure. The limits have never been evaluated for decades of cumulative exposure from many sources at once. Environment. The Department of the Interior warned in 2014 that tower radiation may harm migratory birds. Research published in Nature found that weak human-made electromagnetic noise disrupts the magnetic compass of migratory songbirds (Engels et al., Nature, 2014;509:353-356). I respectfully ask the Commission to: (1) adopt limits that protect against non-thermal biological effects; (2) base device testing on children and on body-contact use; (3) evaluate long-term, cumulative exposure; and (4) give weight to independent health researchers and agencies, not only industry-involved standard-setting bodies. Thank you for considering these comments.

I have EMRS (Electro- Magnetic Radiation Syndrome) I experience numerous negative health consequences when exposed to wireless devices. I will not list my specific issues here due to privacy in a public record, However, the research has shown many negative health and symptom related issues with exposures to radio frequency (RF) radiation. I have most of the symptoms that have already been published in scientific literature. Some exposures are disabling. Holding a cell phone brings on a lot of pain in my hands as well as flu-like symptoms. I have had to unplug all wi-fi, tv's, digital anteannas, cordless phones from my home. I have had to place a shield on the smart meter which severely sickened me when they were installed. Cell towers and other wireless can bring severe pain to the center of my brain that feels like a burn. There are numerous symptoms that occur when exposed but will go away when removed from the offending source of RF radiation. Different sources can bring different symptoms. My life has been crippled from this technology and it is getting harder to purchase any item without wi-fi (i.e. refrigerators, vehicles and more) and are unable to turn off the RF emitted from them. Please review the independent scientific literature and make life tolerable again for those of us suffering.