E-Rate & school connectivity

Letter to FCC re RF radiation. The current and greatly outdated standards for RF were and are completely inadequate. They are allowing and facilitating serious harm to humans, other animals and biological systems. See and read: https://bioinitiative.org/ I ask the FCC to do an adequate major reassessment of safety standards, organize and start this reassessment now - with all deliberate speed to begin it - with experts and scientists in the field who have no ties to the relevant industries and put new standards in place that are actually, scientifically and demonstratively protective of humans. A dear friend of mine was exposed to a cell tower when she moved into a friends house to house sit. Her friend had agreed to allow a cell tower be installed near her house in exchange for monthly payments for the placement. Until moving in, my friend had been an energetic, healthy person working as a gardener. She was so connected to nature. When I would take walks with her, it had been so wonderful as she exclaimed about the various birds and what the squirrels were doing, etc. When she moved in my friend could not understand what was happening to her, as she could barely get off the couch to get food. She could not get any relief. She could not figure out what was going on. As a result, she became so electrically sensitive that she was strongly negatively affected whenever she subsequently went in or near various places in the US where there was RF radiation near by. Now those threats are ubiquitous. She could not stand anyone having a cell phone on when we were driving in a car. She was negatively affected every time the drive brought us near to communication towers. She would say, she felt like she had to flee. I actually felt that one time and it was awful. I had gone into a Verizon store and immediately felt that feeling of needing to flee as she had described it. There was a cell tower on the roof of the Verizon store. I am so grateful that I never felt that again - it was awful and I never want to feel it again. Subsequently, my friend visited a friend in another State. At that friend’s house, she met Arthur Furstenberg who had become electrically sensitive in medical school. He subsequently did a deep dive into electrical sensitivity, wrote a book about it and started an organization. He recognized her electrically sensitive condition and explained it to her. She was found unconscious by a neighbor. She was taken to a hospital. She died there on January 13, 2019. She did not have any medical conditions. I have another friend who is also very electrically sensitive and has many of the same symptoms as the friend who died. They did not know each other, lived in different states and I never mentioned the other friend. They both described the very same sensations all over the top of their shoulders and backs. Like very weird and disturbing crawling electrical sensations. They both showed me the same location and described it in the same way. They were both paranoid that people were sending electrical sensations into their bodies. One said it was her husband sending bad, disturbing energy into her, the other said it was from next door neighbors sending similar bad electrical like sensations from pointing electrical emissions through the wall and sometimes from helicopters. This is/was a terrible situation for them to live with. As fellow humans, please do the studies and initiate protective standards and actions asap. Many, too many, people are suffering and children are at risk, especially due to their thinner skulls with the spreading of cell phone use among younger and younger children. https://bioinitiative.org/updated-research-summaries/ https://www.sciencedirect.com/science/article/pii/S2213879X14000583

The Telecommunucations Act paralleled The Health Insurance Portability and Accountability Act (HIPAA) signed into United States federal law signed into law on August 21, 1996, the FCC may be liable for data trafficking—especially given high-end corporate and small business users which are coerced into private electronic health records, of little import to the original substance to their electronic data securities, transfers! Also see HIGHTEC ACT, 2009. As well, since frequency ranges of small digital devices parallel DEW-frequency ranges, there is a seemingly deliberate phishing for terorrists. FCC could also experience blowback, for lackadaisical bandwidth wars. Scrutinize your DOD criminal codes, if FCC enmeshes mass with corporate markets. Finally, Public Health Emergencies of International Concern appears to underwrite model laws for universal model laws such as, for example, Arizona Title 36-543, Annual review of a patient with a grave (literally?), or persistent (shouldn’t the purported medication mitigate whatever target), or acute (-ly dehydrated! and shouldn’t UPC have already mitigated this level of concern?) disability.. notice.. court-order for continued treatment (inevitable?) ..rules (legal fiction does NOT apply to living beings)   ..immunity (from liability for iatrogenic cause of death) displays anticipatory rhetoric, reiterates a constructive and lucrative, fraud which gives rise to unlawful conversion of living beings to chattel for enslavement by willful international cohorts.

Thank you for the opportunity to provide my comments to you. I am responding from the perspective of a concerned member of the public. I am aware that in 2021 (and in 2026 when the Court gave the FCC 30 days to explain why they took no action on their 2021 order), the U.S. Court of Appeals for the D.C. Circuit ruled that the FCC’s decision to retain its 1996 radiofrequency (RF) radiation exposure guidelines was arbitrary and capricious because the FCC failed to consider a mountain of peer-reviewed scientific studies demonstrating serious biological harm. Over the years, there has been a growing body of scientific research raising concerns about non-ionizing electromagnetic radiation effects on human health and the environment. From what I understand, the only studies the FCC has relied on for its guidelines were those done in the1980's, which focused on the behavioral effects of animals who were exposed to heat from microwave radiation (short term study), and not on cell, DNA, etc. effects of humans/animals who were exposed to RF radiation (long-term study needed). The court ordered the FCC to provide a reasoned explanation for its determination that its RF exposure guidelines adequately protect humans and the environment against the harmful effects of such exposure (RF radiation unrelated to cancer). My opinion on this is that since 1996 there have been massive increases in the levels of radiation exposure in the environment due to advances in the technology, and, therefore, it is incomprehensible that the 1996 radiation exposure guidelines would have any relevance in 2026. For this reason, I also believe that the FCC never should have adopted, in 7/2026, changes allowing certain mobile and portable wireless devices to transmit at a fourfold increase in power levels, without assessing the potential implications for human exposure; Specifically, the court directed the FCC to address: (1) the impacts of RF radiation on children; (2) the health implications of long-term exposure to RF radiation; (3) the ubiquity of wireless devices and technological developments since the FCC’s RF exposure guidelines were last updated in 1996; (4) the impacts of RF radiation on the environment; and (5) the adequacy of the FCC’s RF radiation testing procedures for cell phones and other portable wireless devices. I strongly believe that in responding to the 2021 court order, the FCC should work with HHS Secretary RFK Jr. (who has expressed great interest in addressing this issue) and let his health agency take 100% of the lead in addressing each of the issues identified by the Court. HHS has the expertise in medicine, biology, epidemiology, and public health, for which the FCC does not (its expertise is primarily in regulating communications, communications technology, and spectrum management). Also, given HHS's expertise, and the fact that it doesn't regulate the telecommunications industry, I believe that public trust in its studies/conclusions, its responses to the Court, and its implementation of protective measures, will be greatly enhanced. I believe the following should be done, which will also encompass the issues identified by the court: (1) study the human health and environmental effects (animals, plants, etc. - court ordered this to be done) of electromagnetic radiation from all sources, such as cell phones, 5G and 6G networks, wifi routers, wifi infrastructure (cell towers, small cells, etc.) smart meters, wearable devices, wireless medical equipment, satellites, etc.; (2) review published independent, non-conflict of interest scientific studies. A compilation by researcher Henry Lai, Ph.D. includes more than 3,000 peer-reviewed studies published since 1990 that reported significant adverse effects from EMF exposure; (3) do not review any studies prepared or funded by the conflict of interest telecommunication industry unless their studies have been replicated by independent non-conflict of interest studies; (4) if the current published studies are insufficient (gaps in research) in any areas, such as real-world exposure levels, long-term consequences (court ordered this to be done – L-T exposures), and cumulative exposure, appropriate federal research priorities should be established (new studies- short term or long-term, as required). And the studies that are done should be transparent so that independent, non-conflict of interest scientists can replicate them; (5) with regard to the impacts on human health, pay particular attention to children (court order required this), but also to other vulnerable groups, such as pregnant women, workers, people with implanted devices, etc.; (6) listen to the people who have become very ill from electromagnetic radiation and study them because their experiences provide important insights into potential areas of scientific investigation. Symptoms include headaches, nausea, dizziness, brain fog, anxiety, heart palpitations, insomnia, and tinnitus, and more serious diseases like cancer, diabetes, cardiac irregularities, neurological conditions/issues, and infertility. In Pittsfield, Massachusetts, lawyers represented residents who reported serious health effects directly following the installation and activation of a cell tower in their neighborhood; (7) listen to parents who have reported their concerns about the growing presence of wireless devices and screen-based technology in schools; (8) 330 of the studies reviewed by Henrry Lai, Ph.D listed oxidative stress and free radicals as adverse effects from electromagnetic radiation, which we know are precursors to cancer. So even though the Court did not require this information, long-term studies should be done to identify cancer issues; (9) After all the studying, investigating, analysis, etc. has been done and the results are in as to the human health and environmental (animal, plants, etc.) impacts of electromagnetic radiation, and the necessary protections to our citizenry and our environment have been proposed: (a) update the exposure guidelines and prepare any other protections that are necessary. In this vein, also answer the Court order on the ubiquity of wireless radiation and technology development since the last Guidelines update in 1996; (b) update the RF radiation testing procedures for cell phones and other wireless devices as the Court ordered. In updating, use adults, children, etc. and not a plastic head since it doesn't model real human tissue. Do long-term studies to measure non-thermal biological effects as well as thermal effects; (c) HHS and FFC should review all the completed data together, give meaningful consideration of the experiences and evidences before it, prepare an answer to the 2021 court order; and swiftly implement the protections to public health and the environment; (10) until all the above steps are completed, there should be a moratorium on any expansion of electromagnetic radiation technologies in our communities. I do not have a story of the health effects of electromagnetic radiation on myself, and no one I know has expressed any of these issues. However, in the last 5 years, I have listened to, and read articles by, independent non-conflict of interest scientists that say that my body (cells, DNA, etc) may be continuously affected without my awareness and eventually lead to a symptom or illness (long-term exposure). One study that speaks about this is https://www.spandidos-publications.com/10.3892/ijo.2021.5272 Human-made electromagnetic fields: Ion forced-oscillation and voltage-gated ion channel dysfunction, oxidative stress and DNA damage (Review). Therefore, based on the above, I am very concerned about the health and environmental impacts from the following: (1) cell towers going up at an accelerated pace, many in areas that already have sufficient broadband access, such as my community. A nearby church has a cell tower and that concerns me; (2) the smart meter on the side of my garage; (3) the increases from 5G to 6G and further, which will increase the electromagnetic radiation we are subject to; (4) the small cell towers that they will need to put on properties every 700 or so ft. in order to accommodate the 5G or up cell phones; (5) my wifi router, which sits right next to my desktop computer; and (6) my smart appliances. Thanks Janice

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 The FCC's limits were set 30 years ago, amidst a very different environment and lifestyle and there has been no scientific review since. And even with all the existing science, the United States still has no radio-frequency exposure guidelines that address long term, chronic, non-heating exposures. Therefore I request that the FCC update and correct their guidelines in line with all of the research that was presented in the original court case, EHT/CHD vs FCC . Declaration of Toby Stover Toby Stover declares under penalty of perjury the following: 1. I live in Ulster County, New York. 2. I never gave consent, nor do I consent today, to continuous, involuntary exposure of pulsed modulated, biologically active electrical and radio frequency / microwave (RF/MW) radiation emitted into my home or on my property. 3. I was perfectly healthy, living in my home for many years with an analog electric utility meter but was made ill by the electrical and pulsed modulated RF/MW radiation coming from a “smart” digital electric utility meter which was installed on my property without my consent. 4. After having a grid-tied solar system installed on my home, Central Hudson Electric Company switched my mechanical analog meter to a “smart” electric utility meter without my knowledge. A number of weeks later, I became extremely ill and discovered that the company had switched out my meter. I contacted the electric company demanding that they remove the “smart” meter and return an analog meter. I was told by Central Hudson that the solar array would not work without a “smart” utility meter. After researching this, I discovered that solar arrays work perfectly well with analog meters but Central Hudson still refused to remove the “smart” meter. Since I was unable to live with the continuous pulsation of the smart meter I was left with the decision to either have to leave my home of 35 years or cut the electric line to the smart meter. I chose to cut the wire rather than be sickened in my home as I had no means to move. As a single woman in her 60’s, I was living without electricity for 9 months through the winter, using a wood cook stove and candles. I had to store food in a cooler and buy ice to keep it fresh. Finally I hired an electrician to disconnect my wiring to the “smart” meter & re-connect my home wiring to an analog meter which was on my barn. I was then able to use electricity in my home again. 5. However, having been injured by weeks of exposure to RF/MW pulsed radiation, many years later, I am still unable to go into buildings that are using smart meters or wifi. I cannot tolerate the radiation for more than a few minutes without becoming ill and must leave the area as I now have Eletromagnetic Radiation Syndrome, known as EMR Syndrome. This has made it difficult for me to travel as I cannot stay in hotels, motels or shop at stores where there is microwave radiation. As a professional musician, I am often hired to go into public buildings or play music for school shows. It is a frequent occurrence that today I can no longer spend much time in these buildings without my symptoms returning. I consider this a grave personal injury that has made my life much more difficult. 6. When I am exposed to RF/MW radiation, I experience severe pain and pressure in my head, especially in the forehead. I also feel tingling sensations on my skin as well as tightness in the chest, dizziness, nausea, difficulty concentrating and insomnia. I simply must leave the area as I feel sick around the microwave radiation. 7. Since I have been injured by “smart” meter radiation, I have become a member on the board of New York Safe Utility Meter Association, (NYSUMA). This organization has been working for years in the effort to legislate a safe utility meter choice to anyone who chooses to have returned, or to retain an analog utility meter. Analog utility meters have been used safely and successfully for many years. All utility companies should be required by law to provide analog meters to all consumers who choose to have them. Analog meters work perfectly well and are safe. No one should be forced to accept a device on their property that is a known health hazard. The FCC must update their exposure guidelines for MW/RF radio-frequency radiation exposures from "smart" meters and cell towers and all other wireless devices. 8. References: https://virginiansforsafetech.org/wp-content/uploads/2023/03/Balmori-Cell-Tower-Radiation-2022-Review-.pdf https://www.sciencedirect.com/science/article/pii/S001393512601371X https://www.degruyterbrill.com/document/doi/ 10.1515/reveh-2016-0011/html https://ieeexplore.ieee.org/abstract/document/11672739 https://www.womenscollegehospital.ca/wp-content/uploads/2022/06/Preliminary-Clinical-Guidelines-for-EHS.pdf https://journal.fcrisk.ru/eng/2021/3/4 https://smartmeterharm.org/2025/04/26/victory-against-enedis-the-court-rules-against-the-forced-installation-of-linky-meters/ 9. According to Public Law 90-602, October 18, 1968, AN ACT to amend the Public Health Service Act to provide for the protection of the public heath from radiation emissions from electronic products. “Subpart 3 - Electronic Product Radiation Control “DECLARATION OF PURPOSE “ Sec. 354.The Congress hereby declares that the public health and safety must be protected from the dangers of electric product radiation”. I declare under penalty of perjury the foregoing is true and correct. 10/22/26 Toby Stover

I reside in Lewis County, Washington. I did not consent, nor do I consent today, to the continuous, involuntary exposure to pulsed modulated, biologically active electrical and radiofrequency / microwave (RF/MW) radiation. The health effects of such have been widely studied by government agencies including from the US Navy in 1972 and by thousands of scientists worldwide. You need only look so far as the International Appeal to Stop 5G on Earth and in Space which was signed by over 24,000 professionals demanding a response to what can only be called a crisis brought on by lack of proper public policy on wireless technology. Dr Martin Pall, Professor Emeritus from Washington State University, has studied the effects of RF on the body. His work shows that RF radiation causes oxidative stress and leads to the depletion of glutathione which is critical in melatonin production. His overall assessment is that the damages caused by RF radiation are causing a tidal wave of dementia which we are seeing at earlier and earlier ages. I lost my mother, my mother-in-law, my 64 year old sister-in-law, two uncles and now my own husband is in Stage 5 early onset Alzheimers at age 67. This is not genetic. My father died in 2017. He had spent his last few years unable to sleep. My Mom's memory started failing in the early 2010's. I believe both my parents suffered from the installation of a smart meter as neither had a cell phone and they did not have wifi. As a normal consumer and well educated professional, I did not have any clue that the tech I was using in my work and personal life could be harmful. In 2010, the time of the installation of the smart meter on my home in Oregon, I became unable to sleep and became extremely anxious and depressed. These are symptoms caused by exposure to pulsed radiofrequency radiation. I'd get what felt like restless leg syndrome but all over my body. It turns out that response was from an increasing sensitivity to all electronics. The trigger was the new smart meter. At the time, I did not know what was causing my symptoms. I went to my doctor and sought treatment. I'm now on SSDI. I spent two years trying to treat a mental health condition that only existed as the result of the exposure to EMF to which I'd become increasingly sensitive. And the medication could not help an ongoing toxic exposure. It was adding another biological insult to one of the very systems that's electrical in nature and that's damaged by EMF exposure - the nervous system. By 2015, I'd lost the ability to read more than a few paragraphs and I struggled to write my own name. The fatigue was so bad that when I went shopping for groceries, I had to hold onto the cart just to get around the store. At age 46, I had people stop me and ask if I was OK. Any stress resulted in extreme outbursts as EMF exposure symptoms include irritability which isn't surprising because when your body is under constant assault, you are in a high cortisol state. In 2017, we moved to a rural community where I thought I'd be safe. We had no wireless devices. The smart meter was only the kind that could be read once a month by a truck when they drove by taking readings. My health improved. But in 2024, the meters were changed to a constantly pulsing type and my health became absolutely devastated once again. I became unable to leave my home. After a few months, we removed the meter but the damage was done. I'd become so sensitive to all EMF fields, I could no longer tolerate my own home. I moved my old motorhome to my pasture where I measured the lowest fields (RF, AC and magnetic) and I lived out there without running water and with little electricity. After several months, I made the difficult decision to move again which meant packing all of our belongings by myself as my husband could not remember if he was packing or unpacking a box. The process of even looking for another home was so brutal, I had to be helped out of many homes. Because every county surrounding me had moved to smart meters for power, I could not properly evaluate other fields. I finally gambled and settled. Here we pay $35/month for the privilege to not be irradiated by our meter. I still often sleep in the motorhome. My symptoms include burning sensations, screen dermatitis, dizziness, heart palpitations, chronic insomnia, cognitive fog, extreme fatigue, irritability and an inability to concentrate. I have debilitating digestive issues I believe are being caused by over exposure when I do try to live like a normal human being. Everyone including Social Security is now requiring a cell phone for identity verification to access services online. I find it repulsive to have to pay for the technology that's destroying everything I love including me. Technology that is offensive biologically and disabling to a human being should not be a mandatory exposure by design of our infrastructure.

I want to write a coherent comment here. But the truth is - I am far too angry with the FCC to do it. And far to sick and tired of this whole situation and thoroughly annoyed by your requirement to cite a scientific study to be taken seriously. You mean - like the study that shows how 5g de-oxigenates the air in order to operate? And reactive molds and so-forth, then thrive in the environment. Leading to mold infections. Just one lousy effect - scientifically shown - yet study gets revoked in 2020? Why am I responsible for making the FCC actually read science? I've had to leave my city of choice for a few reasons, largely related to over-developed, unchecked wireless antennna constructions and poorly monitored smart meters, all contributed to ridiculous levels of dirty electricity. Plus the mulitple cellphones always on, and wireless routers, always creating high ambient radiation levels in space after space. I've luckily been able to work from home, but after tripping on a sidewalk, blocked up by some joker zigging all over the place, talking loudly on a cellphone - I ended up losing my job due to those injuries. But I was also half asleep that day - like every day - thanks to the insomnia that comes with having an environment of high EMF and RF forced into my home by celltowers, city cameras, and the neighbors' wireless. AND a the whole building's bank of smart meters under my bedroom - which I did stop using - and moved to the living room to sleep - due to waking with injuries. One should not be getting injured while simply sleeping. But shifting rooms did nothing to stop the discordant line noise from untested, rushed to market, cellular and electrical products. Or the injuries for that matter, which I will not bore you with in detail. I will say this one part again - not to mention the horrific electrical line noise that comes off the lines from the dirty electric, pumped due to the meters, etc. Which is also the case where I had to move to - apparently the grid is now so trashed - there is no where 'clean' to live. My patience is done. Your agency is paid off. My life has been irrevokably changed and lots of time is gone that I will never get back. But the FCC can get off their duffs now - and force the wide-scale environmental impact studies that should have been done in the first place. Not to mention - there are physical areas of my old city that have crazy high ambient radiation levels. These towers creating this issue - they need to go. The city cameras? All need their power setting checked. Banks of smart meters? Need to go. We deserve a safe car or space on public transit, buses and planes as well. I could keep going - but why are we called on to do your jobs ???? Well, I am available for hire - I could help you get your act together. Help you structure some studies. Because right now - it's just Shame on this agency.

After suffering from a brain injury as flight crew in 2017 I began experiencing reactions around wireless technology. Since then it is impossible for me to leave my home without suffering from symptoms of migraine, vertigo, latent sleep disorder, and even at times seizures. Thankfully I can function on my own property without wi-fi as I was able to switch to wired internet. Sadly though, every year it seems the intensity of my neighbor’s wireless networks increases, causing me to suffer mild symptoms on a round the clock basis. If I am so affected by these frequencies, what might they be doing to the developing child’s brains or to our pets and wildlife? After deep diving into published research, it is clear that the literature shows wireless technologies are neuro-toxic to biology via neurotransmitter changes and Voltage Gated Calcium Channel dysfunction. With our current uptick in maladies such as cancers of all kinds, infertility, neuro-degeneration, Cardiovascular Disease, ASD, Hoshimoto’s Thyroiditis, Type 2 Diabetes, and more, we should be asking why this is happening exponentially as we increase the rate of our wireless radiation exposures. On top of the physiological effects, our population's mental health is also suffering. It appears from psychological studies this is largely due to the overload of communications and information. Our governing bodies have not performed their due diligence in investigating potential harms from wireless technology. Focusing on the thermal effects of non-ionizing radiation does not suffice in assuring the public you are required to protect that these technologies are safe. At the very minimum, while we continue to perform long-term studies on the non thermal effects of non-ionizing radiation exposures on humans and the environment, I propose that we: .Re-introduce wired phone lines and ethernet connections in homes, businesses, and public places. . Require all wireless technologies sold in the US to have an “offline mode” which completely disables all wireless functions. . That all wireless functions of all devices be required to be in their offline mode at our schools, parks, public buildings, places of gathering, hospitals, public transportation, and the like. . That cell phone towers, power stations, and other facilities or antenna that emit ELF, EMF, or RF be required to be positioned a mile or more away from buildings, public spaces, and areas of residence OR require informed consent from all potentially affected parties as to the exposures and their unknown possible effects. . That public warnings be instituted regarding the unknown or possible harms of using wireless devices. . That our governing bodies and manufacturers be held responsible for any adverse effects from their approved devices, products, or the infrastructure of wireless technologies.

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: • 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

Here's a three minute video containing data that is published science, testing results, or public standards including the serious detrimental effects of these over-powerful man-made radiation frequencies. Please watch it. https://www.facebook.com/reel/1748284186236212 In my home office I experienced disabling head pain, frightening heart palpitations, shortness of breath and brain fog leading to an inability to think. It took me AVOIDING my office to figure it out. After spending nearly two years refusing Xcel Energy access to install a smart meter, Xcel and the Colorado Public Utilities Commission FORCED US TO INSTALL THE SMART METER, A RADIATION EMITTING DEVICE, or Xcel Energy would shut our electric power off. When Xcel threatened us I was desperate to learn how to protect our live bodies. Constant research about radiation frequencies, including dirty electricity that's inherent in our power grid from 42% wind and solar power delivered to our house... I purchased SaticShield and Aulterra products to shield, filter and "retune" the POWERFUL man-made smart meter radiation and technology frequencies constituting interference with our natural live electrical bodies; including the wifi router, cell phones, laptop, desktop and big screen tv. We applied individual products to the technology devices, a whole house filter to our electrical lines and each of our automobiles. We wear the protection on our bodies as well. Finally the buzzing in my head reduced some and sleep was improved some. We shielded the FORCED UPON US smart meter from pulsing extremely heavy loads of radiation into our kitchen where we stand to cook and walk past EVERY DAY. What do people do that can't afford to mitigate the harmful health effects? Or those that don't know a silent killer is frequenting them every day practically all day and all night? I can't imagine the terror moms and dads have over their young children being constantly bombarded by man made radiation frequencies that disturb the young and old alike and do damage to the DNA level to every live member of mankind, animal kind and plant kind! Yes, the radiation frequencies did not raise my body temperature but they certainly harmed my everyday life!!! The radiation and dirty electricity are sneaky. People are unaware of the huge dirty electricity readings caused by led lights, dimmers, florescent lights, and all those aforementioned technological devices. I'm absolutely appalled by a small town in Iowa where family lives... placing frequency devices DIRECTLY ON all the town's people's WATER TOWER!!! Are you kidding? The corporate officials that took money to do that ought to be ousted in the public square! Those frequencies directly on the water tower destroy the structure of water so desperately needed by every living thing. Stop this madness. Denial is the problem because there's too powerful much money to be made by continuing down this path! The truth is not hidden from the All Mighty. The number one job of "government" is to protect the people and their assets. DO IT.