E-Rate & school connectivity

I submit this comment as a 27-year-old resident of France who gradually developed severe, localized physiological and neurological symptoms from ambient and near-field electromagnetic fields since early 2021. It provides real-world data demonstrating that current regulatory safety margins completely fail to protect individuals with heightened physiological sensitivities. First of all, Current safety compliance models generally evaluate portable wireless devices under static, isolated transmission loads within laboratory environments. However, modern mobile applications, especially real-time navigation and maps, force simultaneous, high-capacity polling across multiple internal antennas, including GPS, cellular data, and Wi-Fi networks. This concurrent multi-radio aggregation drives localized thermal output and electromagnetic power density significantly higher than what is accounted for during single-antenna laboratory testing. The wireless industry itself explicitly recognizes this volatile phenomenon, as documented in hardware engineering blueprints like U.S. Patent No. US20120231784A1 (https://patents.google.com/patent/US20120231784A1/en), which designs proprietary methods for dynamic emission control to handle the erratic exposure fields generated by multi-carrier architectures. To more accurately align with typical consumer usage, it is recommended that the Commission update its Specific Absorption Rate (SAR) and power-density testing protocols. These updates should account for maximum simultaneous multi-radio aggregation configurations evaluated in realistic handling positions rather than standard laboratory spacing. Secondly, Current regulatory exposure models evaluate man-made radiofrequency (RF) emissions in isolation, which may overlook how background atmospheric conditions compound human physiological stress. Meteorological events like thunderstorms generate massive static electric charges, creating a highly dense, localized electrostatic field that acts as an environmental catalyst. For sensitized individuals, the convergence of these background fields, low-frequency device currents, environmental heat, and hardware acoustics can create a state of severe sensory overload within the central nervous system. Under these multi-field conditions, the brain may initially suppress immediate neural discomfort; however, the moment the primary environmental stimulus shifts, baseline neurological defenses can drop. This often triggers a central sensitization event, causing the nervous system to register the accumulated environmental irritation all at once as a sudden, sharp wave of debilitating pain. To more accurately reflect how individuals interact with a dynamic matrix of overlapping fields under real-world conditions, it is recommended that the Commission expand its exposure paradigms to account for these cumulative environmental co-factors and associated neurological feedback loops. Thirdly, structural metal enclosures, including subways, trains, elevators, and passenger vehicle cabins, can act as partial Faraday cages that attenuate incoming signals from cellular base stations. To maintain a stable network connection under these conditions, mobile device power-control algorithms automatically increase emission output toward maximum capacity. When an individual operates a handset directly against the ear inside a vehicle, this automated power surge occurs with zero physical spacing from the user, concentrating radiofrequency energy, increasing battery current draw, and elevating localized thermal output next to the central nervous system. For individuals with heightened physiological sensitivities, these transient spikes inside closed cabins can contribute to acute neurological tension and nervous system strain, even when devices are kept at a distance. To address these enclosed environmental dynamics, it is recommended that the Commission evaluate real-world transient exposure profiles and power-control spikes inside public transit corridors and automotive cabins, rather than relying solely on open-air, averaged outdoor metrics. Fourthly, the relationship between urban topography, architectural design, and radiofrequency (RF) distribution introduces complex spatial dynamics that standard shielding assumptions often overlook. While dense historic urban centers with thick masonry and stone construction inherently dampen external RF penetration, open coastal areas and low-profile environments with strict height limitations allow for less obstructed signal propagation, which can increase ambient spatial exposure. Furthermore, structural variations within buildings present specific localized vulnerabilities; standard glass windows often serve as unshielded entry points that allow ambient signals to bypass protective masonry, creating distinct exposure gradients near openings. Similarly, upper-floor elevations frequently align directly with the horizontal trajectories of elevated cell antennas, negating any presumed safety from height, while neighboring rooftops can scatter, reflect, and amplify signals rather than effectively blocking them. Consequently, addressing these material and topographical vulnerabilities requires a more nuanced understanding of architectural shielding to properly safeguard sensitive environments. The FCC should initiate interdisciplinary coordination with architects, material scientists, and civil engineers to fund research into, and mandate standardized compliance testing for, specialized shielding window glass and building materials. These structural innovations must be optimized to establish unified, continuous protection against ambient RF accumulation across entire building envelopes, regardless of unit elevation or proximity to neighboring rooftops. Lastly, transitioning to hardwired Ethernet connections and disabling wireless interfaces effectively removes high-frequency radiofrequency radiation, yet individuals with heightened sensitivities frequently report ongoing physical strain when operating close to active computer hardware. This discomfort extends beyond optical fatigue from blue light and is directly linked to low-frequency electromagnetic fields, thermal emissions, and localized electrical signatures generated by active internal components, motherboards, and current drawn by lithium-ion batteries. Because internal circuitry continues to project localized electromagnetic footprints even when communication antennas are inactive, current high-frequency regulatory frameworks remain incomplete. To ensure comprehensive safety in close-proximity device usage, regulatory bodies should expand their evaluation standards to thoroughly assess and mitigate the biological and physiological impacts of low-frequency emissions originating from both battery-operated and grid-powered consumer electronics. To conclude, current federal safety guidelines do not fully reflect the operational realities of modern consumer technology or the physiological impacts of cumulative, multi-field environmental exposure. Regulatory bodies like the Federal Communications Commission are encouraged to update baseline safety metrics beyond traditional thermal and oncological frameworks. Proactively establishing more conservative safety margins would better account for real-world usage intensity, multi-field accumulation, and non-cancer physiological or neurological feedback loops, thereby ensuring comprehensive protection for sensitive and vulnerable populations.

Here is what I know: if you take even minimal steps to reduce wi-if in the school, kids will be calmer and healthier. If health risks that doctors/scientists and thousands of studies do indeed exist, then we owe it to our children. We are bioelectrical beings, and wi-fi and cellular signals interfere with our cell-to-cell communication. Studies show wi-fi causes the cell membrane to leak, which produces a very destructive free radical and can contribute to cancer. Wi-Fi also has been shown to interfere with melatonin's ability to clean up free radicals. Other damages shown in the 1000s of studies performed: compromising the blood-brain-barrier (which keeps toxins out of the brain); cellular communication interference; damage to cell metabolism; single-and double-strand DNA damage; loss of DNA repair capacity in human stem cells; reduction in free-radical scavengers (particularly melatonin); abnormal gene transcription; neurotoxicity; carcinogenicity; damage to sperm morphology and function; and effects on behavior. This causes real damage to accumulate, especially in the small bodies of children. U.S. wireless radiation standards (set 20 years ago) based on a 6-foot, 200 pound healthy male? Why have no field studies been performed on children - and the child brain overall absorbs twice as much radiation as that of an adult, and their bone marrow absorbs 10x that of an adult. The following experts have said: • Dr. David Carpenter, M.D., public health physician educated at Harvard Medical School: "RF penetration is greater relative to head size in children, and they have a greater absorption of RF energy in the tissues of the head at WI-FI frequencies because their skulls area thinner, their brains are smaller, and their brain tissue is more conductive than that of adults since it has a higher water content and ion concentrations….Thus it is important that all of us, and especially children, restrict our use of cell phones, and limit exposure to background levels of WI-FI.” • Dr. Keith Black, Neurosurgeon, Cedars-Sinai Medical Center: “In children, the microwave radiation can penetrate deeper into the brain, and their cells are dividing at a much faster rate so the impact can be much larger.” As a side note, WiFi systems in school districts are usually much higher in strength than home systems because they are designed to operate hundreds of computers simultaneously and can be up to three times more powerful than a phone mast outside a school. This will be the first generation ever to spend 6-8 hours each day for years in industrial strength WiFi environment. Dr. George Carlo, who was the cell phone industry's Director of Research and was hired to run their $28 million dollar, 7 year research program to find out if cell phones were dangerous, is now an outspoken advocate of informing the public and calling for more research. We all love wireless. It has connected us, made life so much easier, and has brought information to our fingertips. I know the ease of cell phones, and the money behind cell phone companies is a powerful entity to fight, but if Dr. Carlo did the right things, so can we. Please I beg of you: we need strong leaders who care about the health of our children to step forward and protect them. Thank you for your time. Lauren Heller 74 Green Street, unit 1 Brookline, MA 02446

Part 1 - Professional Background and Personal Journey 1.1 My teaching career and life before electromagnetic hypersensitivity symptoms As the Director of Canadian Educators for Safe Technology (CE4ST), I work with teachers, and families of students attending schools in the United States and Canada. I was diagnosed by Dr. Riina Bray, Director, Environmental Health Clinic, Women’s College Hospital, Toronto. My diagnosis was Electromagnetic hypersensitivity (EHS) - also known as electromagnetic intolerance to wireless radiofrequency radiation. CLINICAL PRACTICE GUIDELINES IN THE DIAGNOSIS AND MANAGEMENT OF ELECTROMAGNETIC FIELD HYPERSENSITIVITY (EHS) https://www.womenscollegehospital.ca/wp-content/uploads/2022/06/Preliminary-Clinical-Guidelines-for-EHS.pdf As a person living with Electromagnetic Hypersensitivity, I am gravely concerned that the rapid expansion of wireless technology could leave me and my family with severely limited options where we can live safely live, access essential services, and participate fully in society. For those of us who can be disabled by symptoms triggered by radiofrequency radiation, towers close to home, or work could mean repeated displacement of families; loss of housing, employment, participation in their community, and access to essential services. We need parks, beaches, and trails, to remain accessible for recovery and healing. No one should have to choose between enduring debilitating symptoms and withdrawing from everyday life. Preserving accessible homes, public services, and areas with reduced wireless exposure is essential to my dignity, independence, and future. More than ever, we urgently need RF-reduced public spaces. There are a multitude of ways to create barrier free, inclusive RF-reduced, modernized wired places to support the diverse needs of Canadians. Signage in public places encouraging airplane mode with Wi-Fi and Bluetooth turned off, modelled on smoke-free and scent-free notices; public health awareness campaigns promoting safe technology practices; and stronger accessibility policies and protections to address barriers faced by people living with electromagnetic sensitivities and other environmentally induced disabilities. 1.2 Genetic Precursors that lead to my intolerance to radiofrequency wireless radiation: Genetic testing conducted through the Toronto Environmental Health Clinic identified several genetic variants that, according to my physician, may influence my susceptibility to environmental exposures. My physician also explained the role of environmental epigenetics and its potential relevance to my symptoms. These findings were discussed as possible contributing factors to the symptoms I experience in environments with wireless radiation. These genetic precursors indicate my inability to manage symptoms: I’m missing the GSTTI gene, the GSTMI detox gene and my GSP1 is suboptimal. I also carry the MTHFR gene which reduces my ability to methylate and remove toxins. An estimated 2% of the population carries this specific combination of genetic variants. Doctors diagnose and treat mild, moderate, or severe EHS symptoms. When symptoms become chronic, or severe, EHS is recognized by some doctors as an environmental disability. This environmentally induced sensitivity is diagnosed and treated by doctors. People who are electromagnetically sensitive, can become disabled if they are not accommodated. People with EHS need Wi-Fi absent and wired, essential services: homes, accessible workspaces, schools, hospitals, medical clinics, public facilities. Extremely low levels of wireless radiofrequency radiation (RF) (beyond 50 µW/m2, approaching 100 µW/m2 can trigger debilitating symptoms that interfere with my ability to function and participate in everyday life. While exposure levels may fall within established regulatory guidelines, this does not mean I can comfortably tolerate them or access services in environments where wireless technologies are continuously operating. Wireless exposure presents a significant barrier to my participation in the workplace, and in public. My accommodation needs must be assessed individually, with respect for my dignity and my right to equitable access. Meaningful inclusion requires accommodations that address the symptoms and functional limitations I experience. No amount of wireless radiation is okay for someone who is living with EHS. RF-reduced environments and accessible public spaces with wired technology are essential accommodations. They can make the difference between being able to enter a building, attend an appointment, participate in a meeting, access healthcare, shop for necessities, remain employed, or being effectively excluded from these activities. Health guidelines intended to protect the public from nerve stimulation and subsequent debilitating effects, fail to protect me and an estimated 3-12% of people who experience mild, moderate, or severe symptoms. 1.3 My Experience: Acute Nerve Stimulus-Responses to Wireless Radiation Acute zaps in the central region of my head appear whenever I’m around cell towers, cell phones, and all wireless emitting products, without exception. The time, onset, and intensity of my neurological symptoms (head zaps; sharp, piercing pain deep within the central region of my head, accompanied by a progressively intensifying sensation of pressure in the frontal region, behind my forehead), vary with the signal strength, my proximity to the wireless source and the duration of my exposure. These “zaps” appear to mimic a nerve test I had. Peak and cumulative exposures appear to have a greater impact on me. My symptoms can last for hours, or days. In the presence of wireless signals in public, my symptoms often become a chronic and progressively debilitating. I feel physically and mentally agitated. I have to stop what I am doing, leave the environment, and search for an RF-reduced location to relieve my symptoms. 1.4 Wireless Impacts, Functional Limitations: My experience around wireless transmissions have been chronic and debilitating. With the onset of intense symptoms I experience impaired information processing, reduced working memory, and difficulty with planning, decision-making, and task sequencing. My symptoms can interfere with my ability to think clearly, retain details, retrieve words, organize my thoughts, process information, concentrate, make decisions, communicate effectively, and carry out even routine tasks. With prolonged exposure, I have experienced neurological symptoms including impaired gross motor coordination (left side), reduced balance and stability, and an increased tendency to stumble or trip. Chronic classroom exposures led to challenging physical, functional limitations, I felt compelled to hide, to keep my job. My symptoms are significantly heightened and can become debilitating around: • Cell phone calls and texts within 15 meters • Wi-fi routers, access points within 15 meters • Cell towers within 2 km • Neighbours in-home wi-fi router signals reaching sidewalks Cellular signals from cell phones, and cell towers trigger more intense symptoms per minute, followed by Wi-Fi routers, wireless access points (WAPs). Bluetooth signals trigger weaker symptoms. 1.2 1.5 My Experience: Varying Signal Strengths, Varying Symptoms Over the past 16 years, I have consistently experienced these recurring symptoms in association with exposure to electromagnetic radiation in the microwave frequency range, with their severity and duration varying according to signal strength, my proximity to the signal, and duration of exposure. Although I can feel signals around 10 µW/m2, and I often tolerate signals around 50 µW/m2, as the signal strength approaches 100 µW/m2, these signals become intolerable. To recover from daily exposures, I leave and ground outdoors. Hiking or swimming for a couple of hours typically alleviates my symptoms from chronic exposures. Living and playing in an RF-absent environment (at our beautiful log cabin, or our home) allows me to be symptom free. 1.3 1.6 Different Wireless Signals, Distinct and Recurring Symptoms Texts: appear to send the strongest signals and create a searing pain through the posterior part of my head. Cell Phones: depending on my proximity - farther away pins and needles (head), closer; frontal head pressure and building pain. I must leave within 5 - 10 minutes, depending on the phone signals (some phones appear worse than others - I haven't documented this) Neurological symptoms (from cellular and wireless signals) typically linger 8 hours to 3 days after wireless signals are absent. Bluetooth: Mild, diabetes-like symptoms, including a sudden, compelling need to eat to alleviate discomfort may be due to fluctuations in blood sugar levels (I had gestational diabetes, so I’m familiar with symptoms related to fluctuations in blood sugar. I estimate that within approximately 20 minutes (possibly longer), the symptoms progressively intensify until I experience an overwhelming need to eat to get some relief. Wireless signals WAP: Within 5 min. (near the WAP) or 10 min. (a few meters away within a classroom) – electric shocks in my head, building head pressure, and with prolonged chronic exposure hours - brain fog, loss of executive functioning; impaired coordination, problems with balance, increased tripping, if there are no opportunities to recover (leave, ground outdoors). Wireless Computer on desk: Mild zaps in upper body - chest. These zaps appear similar to zaps I experienced once from a nerve test. Mental Health, Anxiety: I discovered that repeatedly experiences pain in the presence of wireless signal, simply seeing a WAP, or device would often heighten my anxiety because I wanted to avoid these painful experiences. Conversely, if the source was turned off and if I was informed, my anxiety naturally diminished. I’d gain reassurance that the source of discomfort was no longer active. When friends confirm their devices are in airplane mode, with cellular, Wi-Fi, and Bluetooth signals disabled, I feel relaxed and comfortable. However, if symptoms returned, my anxiety increased, prompting Brian or me to check that all wireless functions are indeed disabled. When I am not around wireless signals, I feel symptom free, energetic and healthy. These are not minor discomforts. They are symptoms that can significantly disrupt my neurological functioning, independence, mental health (stress, anxiety around uncomfortable or painful nerve stimulation) and ability to participate in everyday activities. Access to healthcare, education, employment, public transportation, and public services should include meaningful consideration of accommodations that allow individuals experiencing such limitations to participate with dignity. Avoiding wireless radiation in public can be extremely challenging and almost impossible. I experience chronic and often debilitating symptoms from accidental exposures; driving by a cell tower, a friend forgetting to turn off a router or cell phone. I need to drive beside trucks to reduce cell tower exposures. I can’t tolerate signals at a stop light if a cell tower is close by. I cannot easily use public transportation, stay with my family in hotels, or access my grocery store, medical clinics, or hospitals, without experiencing intensifying and debilitating, neurological symptoms. I must minimize my time in these public areas. Family or disability bathrooms in airports provide me with the refuge I need to avoid signals and debilitating symptoms. At medical clinics I let staff know where I will be waiting (RF-reduced area, including the washroom, my car, etc.), and they notify me in person when they are ready to see me. Accessibility is not simply about reducing the strongest wireless signal. It is also about minimizing sustained exposure from multiple sources so that I can remain in an environment long enough to participate meaningfully in everyday activities. No one should have to endure sudden, piercing sensations of pain, electrical shock-like symptoms deep within in their head, progressively intensifying head pressure, migraines, cognitive fog, or impairment in executive functioning simply to enter public spaces, to simply get a drink of water, or access essential services. The cognitive effects can be particularly disabling. Tasks that normally require little effort following a conversation, understanding instructions, planning my next steps, or responding to questions can become increasingly difficult. My ability to think clearly, exercise judgment, and manage several pieces of information at once may become mildly, moderately, or substantially impaired. What should be an ordinary activity, visiting a grocery store, attending a medical appointment, entering a government building, participating in a community gathering, or accessing public transportation, can become an overwhelming; a physically distressing experience. As my symptoms intensify, I may struggle to follow conversations, remember information, organize my thoughts, or make decisions that would normally come easily. Instead of being able to participate fully in the activity, my attention shifts toward managing my symptoms and finding a place where I can recover. Access to public spaces should not come at the expense of a person's health, dignity, independence, or ability to function. People experiencing these limitations deserve to have their accommodation needs taken seriously and to be offered practical, individualized solutions. 1.4 Inclusive, Accessible, Safer Public Spaces For Everyone, Including Pets: To consider the diverse needs of people, including children, medically vulnerable, and electromagnetically sensitive people: True accessibility means creating environments where people can do more than simply enter a building; it means they can remain, function, participate, and belong without experiencing debilitating symptoms. Practical accommodations, Providing RF-reduced Environments: such as designated low-RF areas, wired internet connections, reduced wireless transmissions, and alternatives to wireless-only services, can help remove barriers that would otherwise prevent my participation. Wired technology alternatives (fiber optics to the premises with no wireless connections), and flexible access arrangements can help people like me participate more fully in education, employment, healthcare, community activities, and everyday life. Promote Public Health and Environmental Sensitivity Signage in Public Spaces: No-smoking; Environmental Sensitivities including scent sensitivities and electromagnetic in public spaces can make public spaces accessible. Place Cell Towers, at Least 1 km away from Schools, Parks, Beaches, Trails: To protect teachers and students with environmental sensitivities, cell tower siting should follow a precautionary approach that prioritizes school accessibility and accounts for scientific evidence concerning children’s vulnerability to environmental exposures. This means locating towers away from schools. The BioInitiative Report’s 2007 outdoor values recommend RF levels should not exceed 1,000 µW/m². Cell towers also need to be at least 1 km away from parks, beaches, trails; places where people like me need to go to heal and recover from wireless exposures in public. My RF-Reduced, Wired Home, Safe for Everyone: I live in a RF-reduced, wired, home with ambient exposures around 3-5 µW/m2. We have no wireless emissions from within our home. We no longer have a microwave oven; we prepare our meals using a stovetop and a conventional oven. Our home is equipped with analogue utility meters and a wired network using powerline Ethernet adapters, Ethernet cables, and compatible adapters to connect all our devices. All members of my family, and friends who visit use our adaptors to wire their wired devices to maintain an RF-reduced accessible home environment. Our home is fully equipped with wired internet connections, providing reliable, high-speed connectivity while supporting energy-efficient operation and minimizing our reliance on wireless technology. We use USB-C ports, adaptors, ethernet cables, powerline carriers plugged into duplex receptacles. We also use landline phones with VoIP devices at home and at our cottage. I stay connected with family and friends through Facebook Messenger on my wired-only computer, allowing me to maintain meaningful relationships, share experiences, and enjoy social interaction, while accommodating my need to minimize wireless exposure. My functional limitations and need for individualized accommodations are important considerations in ensuring equitable access to public spaces and essential services. No one should have to experience head zaps, building migraines, brain fog, loss of executive functioning in public spaces. Ultimately, accessibility means more than being allowed through the door - it means having an environment in which I can safely and meaningfully participate. CE4ST recommends that school boards adopt comprehensive technology policies addressing both digital well-being and environmental accessibility. These policies should promote responsible device use, limit unnecessary classroom distractions, strengthen cyberbullying prevention, provide digital citizenship education, and support students experiencing mental health or behavioural difficulties. At the same time, schools should preserve wired connectivity options, provide alternatives to continuous wireless access where practical, and establish clear accommodation procedures for students and staff experiencing significant functional limitations. Wireless network design should be reviewed to ensure equipment is appropriately configured and unnecessary transmissions are minimized without compromising educational requirements. We also recommend that federal and provincial authorities support independent research into the long-term biological effects of RF-EMR exposure, including potential implications for developing children and medically vulnerable populations. Our goal is not to eliminate beneficial educational technologies, but to ensure that their implementation supports students' physical and mental well-being, protects instructional time, respects accessibility needs, and strengthens the learning environment. By combining evidence-informed digital wellness policies, responsible technology practices, appropriate mental health resources, and accessible wired alternatives, Canadian schools can create more focused, inclusive, and supportive environments in which students and educators have the opportunity to thrive. Part 6 - Telecommunications Infrastructure, Schools, and Communities 20. Densification of Cellular Towers and Antennas Telecommunications infrastructure has expanded considerably to meet growing demand for mobile connectivity. This includes cellular towers, rooftop antennas, small-cell installations, and newer network technologies. CE4ST is particularly concerned about infrastructure located on or near schools, daycares, playgrounds, residential neighbourhoods, and healthcare facilities. Cell tower induced cancer clusters are real at levels deemed safe by regulatory organizations. At an elementary school in Ripon, California, there were causalities among 8 students, 4 teachers, and 100 (nearby) residents. One of those students, Mason Ferullis, had surgeries and treatments that resulted in brain necrosis, nerve pain and paralysis on the left side of his body, bone degradation in both shoulders, loss of hearing, loss of vision. His right eye had to be sutured shut. Mason’s brain and spine cancers continue to return, year after year. Schools, waterparks, and playgrounds deserve careful consideration because children and other individuals may spend substantial periods of time there. Infrastructure planning should include meaningful community consultation, transparent technical information, and appropriate exposure assessment. We recommend consideration of alternative sites and network designs when sensitive locations are involved. Alternative information communication technology (ICT) services can provide adequate RF-reduced, wireless and wired services. Satellite service, cell booster amplification, and Wi-Fi calling are superior alternatives which consider the short term and long-term health of young children and medically vulnerable residents and reduce the Municipality’s liability risks. Cell phones can communicate with satellite in an emergency. Cell boosters can amplify the signal to make phone calls. Wi-Fi calling let’s users place and receive calls and send messages over a wireless internet connection as opposed to using a cellular signal. Most devices including smartphones and tablets have built-in voice over IP (VoIP) capabilities to transmit voice and multimedia content over Internet Protocol networks. This can provide a more consistent and reliable connection. These measures provide a strategic approach to limiting cell tower proliferation, reducing community RF exposure, and minimizing wireless emissions within homes. Minimizing the number of cell towers in communities and providing fiber optics to the premises will provide superior signals required for residents and achieve a number of health, wellness and accessibility goals for communities: • Reduce potential injury, create accessibility, and reduce costly trial and error (remember asbestos?). • Support the Precautionary Principle. There are more than 6,000 studies that indicate pervasive, less than 24/7 exposures to electromagnetic signals in the radiofrequency/microwave range can cause injury (leukemia, brain tumours, infertility, heart arrhythmia/failure, debilitating migraines, vertigo, etc.). Cardiologist, Dr. Sinatra claims these signals can cause heart failure in some children. • Reduce health risks of the potential impacts of long term, cumulative exposure for students and staff. • Likely avoid cluster cancers (500 meters may be even too close to children who are more vulnerable). • By just doubling the distance from residents the signal strength will be reduced by 4 times! This is known as the “square of the distance”. • Protect children and pregnant staff (unborn children) who are more sensitive to wireless signals because these cumulative 24/7 signals penetrate more deeply in their rapidly growing brains. According to Devra Davis Ph.D., signals can have a significant impact on the development of thinking and memory cells in the fetal brain (causing “Environmental Autism”, ADHD, etc.). Brain studies reveal that radiofrequency exposures can spike glucose levels in the brain leading to ADHD, addictive behaviour, or other hormone disruptions which amplify mental health issues . (Dr. Davis was one of the main scientists responsible for having lead removed from gasoline.) • The American Academy of Pediatrics , the largest US medical association of pediatricians and pediatric specialists state, “Children are disproportionately affected by environmental exposures, including cell phone radiation. The differences in bone density and the amount of fluid in a child’s brain compared to an adult’s brain could allow children to absorb greater quantities of RF (radiofrequency) energy deeper into their brains than adults.” • Support Health Canada guidelines for young children; According to Health Canada “Children are more sensitive to environmental agents” (Health Canada, May 2019). • Support the ALARA Principle (As Low As Reasonably Achievable); providing students and staff with the signals needed to operate devices efficiently, while minimizing signal strength. (Following the BioInitiative Report limits whenever possible.) • Support children and staff who are more sensitive to cell tower signals (Electromagnetic Hypersensitivity – EHS) and or those who can experience amplified injury; residents living with Lyme disease, Autism, MS, Parkinson’s, diabetes, and other neurodegenerative diseases, or others who experienced over-exposure to chemical/electrical signals and cannot tolerate additional signals which trigger debilitating symptoms. • Support children who are healing from cancer (there is evidence that radiofrequency radiation can act as a cancer promotor even if it is not the initiator). Reducing the number of cell towers in communities, while providing superior signals from fiber optics to the premises will balance the needs for superior signals, while supporting the health of residents, especially children, pregnant women (developing fetuses), as well as people who are medically vulnerable (recovering from cancer, head injuries – concussions, immune deficiencies, neurodegenerative illnesses – Parkinsons, dementia, etc.) and those who have additional electrical or chemical workplace exposures (electrical workers – EMF exposures, fire fighters – chemical exposures). Frank Clegg, CEO of Canadians for Safe Technology (C4ST), and retired President of Microsoft Canada summarizes concerns of wireless radiation exposures from antennas and towers. Small cell antennas will provide 3G, 4G, and 5G signals, all of which are biologically active and can cause adverse, biological effects. https://www.youtube.com/watch?v=h4TdY344Now Fiber Optics to the premises is superior. Timothy Schoechle’s, (PhD) book, Reinventing Wires: the Future of Landlines and Networks published by The National Institute for Science, Law and Public Policy (NISLAPP) published, demonstrates this superior, energy efficient, sustainable, and consistent service. 21. William Lyon Mackenzie Collegiate Institute: A School Community's Concerns In November 2024, I wrote to Ontario's Minister of Education concerning reports from 18 staff members at William Lyon Mackenzie Collegiate Institute in Toronto. In November 2023, 18 teachers at William Lyon Mackenzie Collegiate Institute initiated a formal work refusal over concerns about radiofrequency exposure from a nearby cellphone tower. Their union reported that repeated concerns and delays in the employer’s response prompted the action. Teachers returned to work after the TDSB committed to addressing their concerns and arranged an independent review. Our organization reviewed preliminary RF measurements supplied by Safe Guard Solutions and communicated concerns about the results of the exposure assessment and possible mitigation. We also referenced correspondence from Dr. Riina Bray of the Environmental Health Clinic at Women's College Hospital. CE4ST requested that the relevant school board, provincial ministries, telecommunications authorities, and other responsible parties investigate the concerns and consider appropriate responses. 22. Cell Tower Setbacks and Sensitive Locations CE4ST has previously proposed precautionary separation distances between telecommunications installations and sensitive locations. We recommend installations be at least 1 km from schools and residential areas. Antennas don’t belong next to homes, or outside children’s bedroom windows. These proposals have drawn upon recommendations from researchers and environmental health organizations. However, distance alone does not determine RF exposure. Exposure depends on transmitted power, antenna orientation, elevation, frequency, network design, surrounding structures, and other factors. We recommend site-specific independent assessments (measurements) rather than relying exclusively on fixed-distance assumptions. Local governmetns should have meaningful opportunities to examine alternative locations and consider the circumstances of nearby schools, healthcare facilities, and residents. 23. Antenna-Siting Consultation Framework CE4ST recommendf adequate municipal review periods, accessible notification procedures, and transparent disclosure of proposed infrastructure. We also request that public consultation records accurately reflect submissions from non-profit organizations, affected persons living with EHS and affected communities. 24. Independent RF Measurements and Public Disclosure CE4ST recommends that telecommunications infrastructure assessments include reliable technical information and appropriate verification. Relevant information may include operating frequencies, transmitted power, antenna characteristics, predicted exposure levels, and measurements taken under typical operating conditions. Where significant equipment or operational changes occur, updated assessments are appropriate. We also recommend exploring publicly accessible RF monitoring programs to improve transparency and support independent research. ________________________________________ Part 7 - Accessible Communities and Practical RF-Reduced Solutions Accessibility is not simply about entering a building. It is about being able to participate meaningfully in the life taking place inside it. 25. RF-Reduced Schools and Learning Environments RF Assessment and Mitigation: Schools/ Employers - hire building biologists to identify, measure, and reduce RF levels for everyone. As you know RF Meters can be used to measure peak and maximum levels. Schools should measure peak signals which are the most biologically active and maximum levels over the full period. Signals must be measured while all devices are operating to assess typical real life exposure levels and to assess the effectiveness of accommodations implemented. Ambient classroom levels should be as close to 10 µW/m2, as possible, if there are electromagnetically sensitive students/teachers in the classroom. Using an existing, superior wired system, will reduce RF exposures for all children, and reduce energy costs. All schools can apply the ALARA Principle to provide “As low as reasonably achievable” signal levels, with maximum efficiency. Wi-Fi on demand provides signals when required and a portable access point on a cart can create additional signals, when needed. A power over ethernet (POE) switch can be connected to a POE access point. Hartsbrook and Lindbrook Schools (Ontario) reduced power density by 25% “without a noticeable impact on device performance”. Reducing signals by 25% may prevent additional student/staff injuries, but it does not protect persons with EHS disabilities. Turning off one access point and wireless signals on devices, and simply wiring devices, is required. Wired devices provide superior connections, protection, accessibility, data privacy, and are healthier for everyone. Multiple laptops can be connected using one existing wired connection and an ethernet switch. In high school ideally; schools could equip selected classrooms with wired network connections and centrally managed wireless access points. Through managed Power over Ethernet (PoE) switches or wireless network controllers, authorized IT personnel could disable designated access points according to classroom schedules while maintaining wired internet access. Access to an RF meter can ensure RF signals are appropriate for the individual. A Healthy Learning Environment: Prioritizes wired internet connections. Teachers along with students keep wireless devices in airplane mode, with Wi-Fi and Bluetooth turned off when not needed. When wireless connectivity is required for a specific instructional activity, for example, using tablets, temporary access through a mobile cart equipped with a wireless access point can be used. Wireless connectivity should only be activated only for the duration of the activity, then switch off the access point and disable the devices’ wireless functions before returning the cart to a central storage area. Health Curriculum: Integrating Safe Technology Practices which Promote Health, Safety, Responsibility, and Accessibility A Safe Technology Practices health program could focus on helping students make informed choices about technology that support physical health, mental well-being, healthy relationships, personal safety, and inclusion. Individualized Accessibility for Electrosensitive students and teachers: Schools should provide accessible options for students and staff who require modifications to their learning or working environments. Airplane mode signage, turning off one access point (on/off switch), wiring a couple of devices and instructing students to use safe tech practices can begin to (accommodate) meet the needs of a disabled student or teacher. In high school ideally; schools could equip selected classrooms with wired network connections and centrally managed wireless access points. Through managed Power over Ethernet (PoE) switches or wireless network controllers, authorized IT personnel could disable designated access points according to classroom schedules while maintaining wired internet access. Access to an RF meter can ensure RF signals are appropriate for the individual. RF-Reduced and wired technology: Practical measures include teaching safe tech practices to students and teachers (airplane mode, or specific antennas turned off when not in use), wired internet connections, Ethernet adapters, offline educational resources, and disabling unnecessary wireless functions. School boards can also review wireless access-point placement, equipment configuration, and individualized accommodation requests. These measures can preserve the benefits of digital education while offering greater flexibility. Such accommodations would offer practical options for reducing reliance on wireless connectivity while supporting equitable access to education, curriculum participation, and school activities for students requiring reduced-RF environments. 26. Accessible Homes and Housing Stability Accessibility planning should recognize that meaningful community participation extends beyond employment, education, and healthcare. Housing presents particular challenges for individuals who seek RF-reduced environments. People living with EHS may be able to replace wireless routers with wired connections, use wired telephones, and reduce wireless transmissions inside their homes. However, they may have limited control over nearby cellular installations or wireless equipment on neighbouring properties. CE4ST has heard accounts of EHS persons in effect-evicted from their homes, and needing to relocating repeatedly, becoming separated from family members, or struggling to find a suitable accommodation. This housing crisis may become particularly severe during the colder seasons, late fall, early spring, and winter when these environmentally disabled persons may face significant hardship finding safe, warm and accessible places to live. From an accessibility perspective, Canadians living with electromagnetic disabilities encounter barriers comparable to those faced by individuals with other environmental sensitivities. Unlike other environmental accessibility accommodations, there are currently few housing policies, accommodation standards, planning frameworks, or programs that recognize their needs and address RF exposure within shelters or shared housing environments. There are no widely adopted public policies encouraging the creation of RF-reduced areas, wired connectivity options to reduce unnecessary wireless emissions to accommodate people with electromagnetic disabilities. These gaps in housing policies and standards have created insurmountable hurdles for those living with Electromagnetic Disabilities, who are desperately seeking accessible housing. The expansion of wireless infrastructure, including cell towers installations can significantly limit housing options. Persons living with electromagnetic disabilities may be forced to relocated repeatedly, disrupting their ability to establish long-term housing stability, maintain employment, access to healthcare (limited RF-reduced hospitals/medical clinics), build lasting community connections, and participate fully in local life. Recommendations to the FCC, and Government Committees: 1. Recognize electromagnetic disability-related housing needs within accessibility and housing policies. 2. Support the development and preservation of low-electromagnetic-exposure housing options, particularly for individuals with documented medical needs. 3. Require consideration of electromagnetic accessibility in publicly funded housing projects, including options for wired internet access and the ability to disable unnecessary wireless technologies within designated units. 4. Develop accommodation guidelines for housing providers, property managers, and social housing agencies to assist them in responding appropriately to accommodation requests. 5. Encourage the use of fibre-optic and wired communications infrastructure as accessible alternatives that can provide connectivity without requiring wireless transmissions within living spaces. 6. Ensure that medically vulnerable individuals are not excluded from housing opportunities because of their disability-related environmental requirements. The availability of RF-reduced and scent-free housing options is critical to removing significant barriers and will ensure access to safe and accessible housing for medically vulnerable individuals living with environmentally induced disabilities. Such accommodations support health, dignity, inclusion, and meaningful participation in community life. Homeless shelters filled with wireless signals are not accessible: For individuals living with electromagnetic disabilities, access to emergency shelters, and temporary housing can be extremely challenging. (e.g., a teacher we worked with was unable to find an RF-reduced workplace/apartment/temporary emergency shelter). Most homeless shelters, transitional housing facilities, and emergency accommodations rely heavily on wireless technologies, including Wi-Fi networks, cellular devices, smart building systems, wireless security systems, and other RF-emitting technologies. As a result, these environments may become inaccessible for their needs. We recommend that housing and accessibility strategies explore wired connectivity, RF-reduced residential options, and consideration of strategically placed telecommunications infrastructure, at least 1-2 km from persons living with EHS. A voluntary, confidential municipal registry could help identify the accommodation needs of residents living with EHS/EMR-S and inform consultation on proposed cell tower locations. With residents’ explicit consent, this information could support consideration of alternative sites and measures to reduce RF exposure near their homes. Participation would need to be optional, with strict privacy protections and no public disclosure of residents’ identities, addresses, or medical information. 27. Inclusive Workplaces and Employment Opportunities Employers should consider practical accommodation options for employees experiencing electromagnetic sensitivities. These may include wired workstations, alternative communication systems, designated lower-RF spaces, and wired equipment. Individual accommodation plans should be developed collaboratively and assessed for effectiveness. The objective is to preserve meaningful employment, professional dignity, and equitable participation. 28. A Model of Compassionate Healthcare Accessibility: My Experience at Royal Victoria Hospital My experience at Royal Victoria Hospital demonstrated how thoughtful planning, compassionate leadership, and coordinated efforts among healthcare professionals can successfully accommodate a patient with electromagnetic hypersensitivity (EHS), enabling access to essential medical services with dignity and greater comfort. To minimize my exposure to radiofrequency electromagnetic radiation (RF-EMR) in busy public areas, arrangements were made for me to receive my patient identification wristband directly from the Patient Representative Office. This accommodation allowed me to bypass the crowded registration area, where numerous patients and visitors were using wireless devices. Hospital staff then escorted me through quieter, lower-level hallways, enabling me to avoid the busy main elevators. I experience particularly debilitating symptoms in enclosed elevators when passengers are using cell phones. The confined metal environment and close proximity to transmitting devices make these spaces especially challenging for me. The Reception Manager personally introduced me to the Fracture Clinic Manager, who explained that patients had been provided with an informational fact sheet encouraging them to place their cell phones and other wireless devices in airplane mode while attending the clinic. An accompanying poster reinforced this request, helping to promote awareness, cooperation, and consideration for patients with electromagnetic sensitivities. I was also informed that my surgeon would advise me whether he had left his cell phone at reception or turned it off completely before meeting with me in the designated EMF-protected area. This thoughtful communication provided reassurance that my accommodation needs were being recognized and respected throughout my medical appointment. What made this experience exceptional was the seamless coordination among hospital staff, managers, and medical professionals. Each person understood their role, communicated effectively, and contributed to creating a more accessible healthcare environment. Rather than placing the responsibility entirely on me to repeatedly explain my disability or negotiate accommodations, the hospital proactively implemented practical measures that reduced the barriers I encountered. These accommodations did not require the hospital to discontinue essential wireless services or undertake extensive infrastructure changes. They involved considerate adjustments to registration procedures, patient movement, wireless device practices, staff communication, and the location of medical care. For me, these measures made a profound difference. I was able to access essential healthcare with greater comfort, dignity, and confidence, knowing that my medical needs were being taken seriously. Royal Victoria Hospital demonstrated that meaningful accessibility is achievable when healthcare institutions combine compassionate care, effective communication, and practical environmental accommodations. This experience offers a valuable model for other hospitals, medical clinics, and essential service providers seeking to create more inclusive environments for patients with electromagnetic sensitivities. Most importantly, it demonstrated that no patient should have to choose between accessing essential medical care and managing a disabling medical condition when reasonable accommodations can help remove barriers to care. Healthcare facilities can examine the feasibility of lower-RF examination rooms, wired administrative systems, alternative registration procedures, and patient communication protocols. Staff training and clear accessibility procedures can reduce the burden on patients who otherwise must repeatedly explain their circumstances. My experience at Women's College Hospital demonstrates how coordinated planning and compassionate care can improve accessibility. 29. Public Buildings and Essential Services Libraries, community centres, government offices, and other public facilities can consider environmental disability signage, wired public-access terminals, accessible service counters, and designated spaces with reduced wireless transmissions. Essential services should remain accessible without requiring every individual to use a wireless smartphone. These options can support broader digital inclusion and accessibility. 30. Transportation, Travel, and Community Participation Transportation and travel are important components of independent living. For individuals who experience symptoms in wireless environments, airports, public transit, hotels, and other facilities can present significant challenges. Where operationally feasible, service providers can consider alternative communication methods, lower-RF waiting areas, and individualized assistance. Fibre Optic Infrastructure as Canada's Digital Foundation CE4ST supports prioritizing fibre optic networks as a foundation for reliable and inclusive digital connectivity. Fibre optic cables transmit information using light within an enclosed medium and do not require RF transmission along the fibre itself. When combined with Ethernet connections inside buildings, fibre networks can provide high-capacity communication while offering reduced-RF options. Wireless networks remain useful for mobile connectivity and situations where fixed connections are impractical. However, wired alternatives should remain available. We recommend that publicly funded schools, hospitals, government buildings, and major infrastructure projects preserve practical wired connectivity options. 34. Energy Efficiency, Privacy, and Environmental Sustainability Digital infrastructure planning should consider energy consumption, equipment lifecycles, maintenance costs, reliability, and privacy. Wired and wireless systems have different technical characteristics, and their relative energy efficiency depends upon network architecture, equipment, and utilization. We recommend transparent lifecycle assessments and infrastructure planning that supports accessibility, affordability, security, and environmental sustainability. Drawing upon my personal experiences, professional background, and consultations with experts and affected families, I respectfully recommend that the Government to: 1. Commission an independent, multidisciplinary scientific review of RF-EMR research, including biological effects, long-term exposure, vulnerable populations, and emerging technologies. 2. Review the scientific basis and implementation of FCC and Safety Code 6 guidelines with current, peer-reviewed, independent science (primarily biological effects). 3. Develop national guidance for wired technology options and individualized accommodations in schools: public campaigns, and accessibility laws to close the gap and support persons living with electromagnetic, environmentally induced disabilities. 4. Preserve meaningful municipal consultation, public notification, and transparent decision-making for telecommunications infrastructure. 5. Require enhanced consideration of schools, daycares, playgrounds, healthcare facilities, and residential areas in wired (fiber optics to the premises, FTTP) infrastructure planning. 6. Establish appropriate mechanisms for independent RF exposure verification and public disclosure. 7. Develop practical disability accommodation guidance for individuals experiencing electromagnetic sensitivities. 8. Investigate RF-reduced housing options and wired connectivity as part of accessibility planning. 9. Prioritize fibre optic infrastructure and preserve wired alternatives in publicly funded buildings and major projects. 10. Support independent environmental research concerning potential RF effects on wildlife and ecosystems. 11. Ensure government consultation processes and scientific assessments remain transparent, inclusive, and accountable. 40. Conclusion: No One Should Be Left Behind, Government Health Guidelines and Accessibility Policies Must Address the Needs of Electromagnetically Persons I spent 29 years teaching children that every person matters. I encouraged my students to be compassionate, responsible, curious, and respectful of others. I taught them that differences should be understood and that challenges can often be overcome through creativity, cooperation, and determination. Today, I am asking the government and regulatory organizations to demonstrate those same values. The United States and Canada do not have to choose between technological advancement and accessibility. No-one should have to choose between managing debilitating symptoms and participating in everyday life. A person should not have to establish the complete biological mechanism of an illness before being treated with compassion, dignity, and respect. I believe the true measure of technological progress is not simply how connected our society becomes, but whether every person has a meaningful opportunity to participate. Government health guidelines and accessibility policies should provide a clear pathway toward dignity, inclusion, independence, and meaningful participation for electromagnetically sensitive individuals. I know what it is like to love your career but struggle to remain in your workplace. I know what it is like to lose access to ordinary public spaces, to plan daily activities around physical symptoms, and to encounter skepticism when asking for help. I also know the profound difference that compassionate and thoughtful accommodations can make. I have experienced both exclusion and inclusion. Through Canadian Educators for Safe Technology (CE4ST), I have witnessed the determination of parents seeking help for their children, educators trying to remain in the profession they love, and individuals searching for accessible homes and essential services. I believe their experiences deserve to be heard. Currently, invisible regulatory barriers created by the FCC and SC6 appear to upstage accessibility policies. The FCC and Health Canada claims SC6 exposure levels are safe for vulnerable persons. School Boards and Employers use FCC and SC6 recommendations as a health guide and feel they have “official permission” to dismiss accessibility guidelines even when a medical note is provided from the Director of the Environmental Clinic at Women’s College Hospital. Government health guidelines must include clear recommendations, policies, and practical accommodations that address the needs of people living with EHS/EMR-S and break the cycle of suffering, exclusion, and barriers to participation. Government guidelines dismissing the legitimacy of EHS/EMR-s has led to unfair treatment of persons with EHS. For decades, they have been stigmatized, discriminated, and segregated. Until EHS/EMR-S is explicitly addressed in accessibility standards and consistently recognized across all levels of government, persons living with this environmental sensitivity may continue to face significant barriers to obtaining timely and appropriate accommodations. Although some EHS disabled persons have been accommodated in the workplace, this accommodation can sometimes depend on the employer. Without clear, consistent guidance, access to accommodations can vary considerably between employers and institutions, leaving individuals dependent on the understanding, willingness, and discretion of individual decisionmakers rather than a predictable, equitable, and inclusive accommodation process. We can support innovation while investigating scientific uncertainties. We can provide public services while recognizing that individuals have different environmental and accessibility needs. As Physicians for Safe Technology promote: We can build reliable digital networks while preserving wired alternatives. My hope is that the United States and Canada will become leaders in developing inclusive digital infrastructures, compassionate accessibility practices, and evidence-informed public health policies. No child should be unnecessarily excluded from learning. No employee should be unnecessarily excluded from meaningful work. No patient should be unnecessarily excluded from healthcare. And no American or Canadian should be left without reasonable opportunities to access housing, essential services, and community life. Let us build a digital future in which innovation and human dignity advance together- and so no one is left behind. Respectfully submitted, Shelley Wright, B.A., B.Ed. Founding Director Canadian Educators for Safe Technology (CE4ST)

I have EMR syndrome. My utility put a smart meter on my home and I have never been the same. There were never any problems when the analog meter was in use. The government needs to protect people who do not want or cannot tolerate some devices or electromagnetic radiation. We want and need safe choices. Allow us to feel and be safe in our homes!

I have been personally affected by my cell phone, computer and wireless radiation since January of 2019 when I had an “electrical accident” in my home office. Since then, when I touch my cell phone or use my laptop, I get these symptoms: tingling on the tip of my tongue that spreads further back toward my throat, my lips swell, nausea, swelling in my joints, ...until I stop using the device. The cell phone impacts me extremely quickly, just by touching the front of it, and I often get a pulse through my arm. Awhile back, I began to get a lump in my breast. It was right where I could feel the signal from my fingers on the cellphone to my breast. This lump kept increasing in size until I went to the doctor and showed her. It felt important that a medical person see the lump and record it in my health records. Realizing the cell phone seemed to be causing the lump, I stopped using it for 4 days until the limp went away. I can only use a computer for a short time before these reactions occur and nausea sets in. I have friends for whom the reaction is a lightning bolt headache that lasts many days, burning skin and worse. I have also had tinnitus since this occurred. It is loud and affecting my hearing. Hearing aids will be necessary, and you know what they cost, but I can’t have wireless hearing aids which are now wireless or have a battery, something I also can’t tolerate at close range. In the "electrical accident," I was using my computer with the wireless on and charging my cellphone in the same unit of 4 outlets. I was back and forth using the computer and the cell phone when I needed to text/make/take a phone call. Suddenly, tingling began on my tongue, and my lips swelled. I have been told that my hands on both the keyboard and the cell phone at the same time completed something like a closed circuit, charging my body. Since that time, I have had this sensitivity. My doctor and my chiropractor both diagnosed it as Electromagnetic Hypersensitivity. My MD says I am something of an antenna now, possibly exacerbated because we all have metals in our bodies from environmental pollutants. There are costs associated with being electrically sensitive. I cannot have wireless on in my home and must hardwire my laptop. Wireless is free, and cell data, which I am forced to use, is expensive. I purchased a good meter, between $350 and $800. My RF/EMF meter told me there is no place is my home that is really safe enough to sleep on a regular basis and I had to invest in some very expensive shielding material ($1500.00) that shuts out radiowaves in my bedroom. I need to hire a Building Biologist to determine what about my home makes the sensitivity worse. This hire is expensive ($800-1000.00) as well as costs for anything that person determines I must do to mitigate my exposure. I have great concerns (terrified, really) about 5G and all that will come in the future. Smart meters aren't local yet, but we have gotten the dreaded letter saying they are putting them on houses now. These must be studied as they emit huge amounts of strong radiation and will be installed right on our homes. They also put dirty electricity into our wiring, and I and some others react to that. I actually have to turn off the circuit to my bedroom when I sleep so I don’t get a killer headache. What else is forced on us this way? Please let us have free meters on our homes for water, electricity and gas. The more radiation we add to the environment, the more people will be negatively affected. Please study the effects of the enormous amount of cumulative radiation in the air in towns with strong wireless infrastructure and those with little. We have seen huge differences. Please study the effect on children, wildlife, the elderly and immuno-compromised. Our lives are in your hands. Please protect us and keep services people-centered not profit driven. Thank you so much! ~LWodin, Upton, MA

I am submitting this comment in response to FCC’s Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure. I am responding from the perspective of a chronically ill individual dealing with pain and fatigue. In my search for answers to alleviate my pain and exhaustion, I learned about EMFs and how they damage the long-term biological health of our cells and prevent healing according to Dr. Devra Davis, Dr. Martin Pall, and Dr. Deitrich Klinghardt. So I decided to do my own experiment to see if eliminating sources of EMFs would make me feel better. I had 2 certified building biologists come into my home and do an assessment of the current EMFs. I had high levels of magnetic fields due to nearby powerlines, moderate levels of electric fields due to in house wiring mistakes, and extreme levels of wireless radiation in the home (according to Building Biology guidelines) due to wireless devices throughout my home. The building biologist suggested the following: 1) I turn off the electricity at night to combat the electrical fields in certain rooms, 2) I hardwire everything in my home and eliminate all RF and Wireless devices, and 3) obtain a Qi Machine that is suppose to help neutralize the various EMFs and create a more balanced energy field. I did all 3 of these suggested changes, and I had really great results with my severe back pain and overall body aches and fatigue. I still suffer from these ailments, but I went from a 9 out of 10 to a 6 out of 10 by making these changes. I even did multiple experiments where I would take the 3 suggestions and turn them on one night and turn them off the next. The results were consistent and my pain/fatigue would re-surge when I exposed myself to the EMFs, or the pain/fatigue was reduced when I made the changes each night and removed the EMFs as much as I could. I have noticed since I made these changes in my home, I have developed an almost 6th sense to when someone is sending/receiving on their cell phones. I have developed a heightened sense that occurs in my brain when signals are present and close by. This further deepens my experience as these EMFs should really be studied. I support FCC taking an active role in examining the potential health and environmental effects of EMFs and specifically, wireless radiation. Questions about human health should be addressed by federal agencies with appropriate expertise in medicine, biology, epidemiology, and public health, and the experiences of individuals and families who report being affected should be considered alongside the scientific evidence. I urge FCC to carefully evaluate these experiences and the scientific evidence, identify gaps in current research, give particular attention to children and other potentially vulnerable populations, and establish appropriate federal research priorities regarding wireless radiation and public health. Thank you for providing individuals and families with an opportunity to be heard!

I have been sensitive to radiofrequency (RF) radiation since about the time it became widely adopted. As coverage grew, I had to limit cell phone and DECT phone usage, as these cuased headaches within minutes. Having avoided cell phones for years, I became tolerant to a degree, and after living in a remote area my symptoms went away completely and I could even tolerate some RF. However, now that I had to move back to the city for work, despite not using a cell phone, I can feel the negative effects from other people's phones and nearby towers. Research is now conclusive that it is impossible that RF is not causing some negative effects, and we can be sure they are going to be varied, and have a greater effect on children and people with underlying conditions. Studies have found that schools with RF or cell phone towers placed near them have a higher incidence of childhood cancers. Studies on cell phone radiation have shown immediate negative effects to blood viscosity, and other biological markers. The FCC's rules are very dated, and do not account for the science since the 80s, nor the experts' testimony such as that found in the Bioinitiative Report (2012). I believe the recognition of this issue is long overdue, and imperative for the health of future generations.

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

I am writing regarding the FCC’s response to the D.C. Circuit Court of Appeals’ remand concerning its decades-old radiofrequency (RF) radiation exposure guidelines. The Court directed the FCC to provide a reasoned explanation for its determination that its guidelines adequately protect humans against harmful effects of RF radiation unrelated to cancer. Specifically, the court required the FCC to address the impacts of RF radiation on children, the health implications of long-term exposure, the ubiquity of wireless devices and technological developments, impacts on the environment, and the adequacy of the FCC’s testing procedures for cell phones and other portable devices. The FCC is not a health agency and does not have expertise in medicine, biology or public health. And yet, the agency continues to assert authority over RF exposure standards and is preparing to reach conclusions about whether its existing guidelines adequately protect the public. This issue matters to me personally because my health has been adversely affected by wireless radiation, particularly after a smart meter was installed on the verandah outside my bedroom. The meter was installed in 2016/17. Over the approximately two years while it was there my health gradually deteriorated. Eventually, I became more ill than I had ever been in my life. In 2018 I came down with a bug that completely wiped me out for two months, along with a secondary eye infection. I could not work. My sleep had been affected for those one and a half to two years of the smart meter presence - waking, and then taking hours to get back to sleep. I experienced fatigue during the day. There was head pressure and I began to experience 'brain fog'. These things I initially assumed might just be part of my aging process (73 years old). My blood pressure was high when I did go to the doctor for the eye infection. I had been using a shungite sphere between the smart meter transmitting aerial and my bedroom, which I had thought would protect me, however I now feel it was not enough to deal with the quite strong emr transmissions coming 24/7 from the smart meter and affecting me as I slept. It was at a local meeting about 5G in 2019 that I realised that it might not be the ageing process as I had assumed, but rather, the smart meter on my verandah, that might be causing these rather rapid declining changes to my health. I learnt at the meeting that there were ways to counter wireless radiation adverse effects in your home space. I wanted to make my home an emr safe place. I contacted the local geobiologist who had addressed the meeting, and he came to read the emr and geobiology in two sleeping spaces in my home. He found that indeed the radiation emissions from the smart meter were strong and likely affecting me, and he also made suggestions re protecting me from the effects of the electrical currents flowing through me as I slept which were from the wiring in my bedroom area. When the assessor came back with a spare piece of shielding mesh as a temporary measure, and placed it at the rear of the smart meter a week or two later, – I felt a greater ease in sleeping again and felt so grateful for the help. Realising that wireless radiation was likely the main culprit in what was happening to my health, I began to research emr on the internet and learnt that in NSW in Australia where I lived, some rulings had just come about that meant that NSW, QLD, SA, Tas and ACT electricity customers were allowed to have communications on ALREADY INSTALLED smart meters, turned off.. This was a ruling by the Australian Energy Market Commission (AEMC) that allowed metering coordinators to deactivate the communications on already-installed smart meters. The final rule allows metering coordinators, at their discretion, to deactivate the remote communications in response to customer objection. This was the information I needed to begin the process of negotiation with the electricity provider to change my meter from a 'communicating' to a 'non-communicating' meter. The whole process took a good 5 months however finally the provider removed the offending modem. Some years on, (2026), my sleep has improved a lot from where it was. My body feels great really. One unintended and unforeseen consequence of the changes I instigated back then, is a relative absence of the little stiffnesses that had begun to creep in since the installation of the smart meter. (I see from my research that the effects of wireless radiation on the body are cumulative.) On waking I noticed that my body felt good, whereas previously, since smart meter installation, it had begun to be a little stiff upon getting out of bed. I attribute this to several things - my bed was shifted so as to be away from the pathogenic earth stressors, which had been picked up by the assessor, and it was also shifted away from the wall so as to be away from the electricity fields in the wall. Additionally I currently turn the power off at night at the main switchboard, which would I imagine be eliminating electrical fields as I sleep completely. The main thing is that there has been no pulsing emr radiation impacting my body as I sleep. (I understand from my research, that emr does have impacts on our musculature as well as many other biological and neurological adverse biological impacts). However another factor in both my body's well-being, plus my brain's improved functioning would/could be coming from the supplements I have been taking to remediate my body from the adverse accumulative biological effects of exposure to the manmade emr. Mg citrate and Mg glycinate that are two of the four forms suggested by Mercola in his book "EMF'D". Mg Stearate is another form that I will take which is also suggested by him. I think the other supplement that is immensely helpful in dealing with the damaging health effects of wireless radiation transmissions in my body and brain, is the fermented pawpaw which was used by Belpomme and Irigaray with their trial subjects as in their paper "Electrohypersensitivity as a Newly Identified and Characterised Pathological Disorder: How to Diagnose, Treat and Prevent It" . They also used Gingko Biloba which I am only now just starting.. Their article is well worth reading. From their research they found that those who experience electrohypersensitivity, like myself, never come back to zero, and need to continue to minimise their exposure to wireless radiation as a preventative throughout their life. In 2023, a short film, (approx. 10 mins) on electrohypersensitivity, titled "Remembering Nearfield", won at the Cannes Film Festival in the Health Section. I feel prevention is the best route. When out in unknown wifi territory I mostly carry my emf radiation detector, so I can assess the least emr active zone to be in, and to minimise my time and presence in high emr zones. Having the emf detector is also handy if others are coming into my home with their devices. It enables me to check that there are no radiation fields being emitted unnecessarily in my home safe zone. (2025 update – I also carry my Blushield 01 scalar device when out and about and away from home.) The actual physical process of changing to a non-communicating meter simply involved a technician coming and removing the modem (for communicating), from the meter box, in my case. They left the aerial there, however it is not active without the modem. Having the emf radiation detector I find helpful for peace of mind to know that, for example, the modem HAD been removed and to confirm that indeed it was not transmitting . When taking readings from a smart meter with a wifi detector, it is important to know that you need to be reading the detector ongoing for at least 5 minutes, since the peak pulse of the smart meter occurs around every 5 minutes, 24/7, that is every 5 minutes. There are multitudinous lesser pulses actually many times a minute. I understand that there are almost 10,000 radiation pulses coming out of smart meters 24/7. (If you set the radiation measuring meter to also make sound you will then HEAR should there be a strong transmission, when, and if, your gaze is averted from the measuring meter.) (See "Biological and Health Effects of Radio Frequency Transmission: A Review of the Research Literature" ; A Report to the Staff and Directors of the Eugene Water and Electricity Board: June 2013, they served a court order to PG&E to provide clear documentation of what the smartmeters were actually doing.) I currently don't have a mobile phone at all which works for me. I experience unpleasant sensations in my arm when holding such devices. I have a landline, NBN, and wired ethernet cables for internet. The modem provided me by my server did not have a button to turn off the wifi, so I had to request for them, the server, to disable or turn off the wifi at their end. This means there is no wifi in my home. I have no other wified things, and that meant deliberately shopping for a no wifi tv, for example. For me, my home feels energetically safe and quiet again. I feel some balance is returning, however I still feel myself at some threat from escalation of 3G, 4G, 5G and the proliferation of wifi and emr in public buildings, schools of learning, and other public spaces. I used to enjoy visiting my library to read, however now because of so much wifi in the library, I avoid it. Becuase of the remediation measures that I have undertaken in my home, I have a safe , natural emr free space to return to and to recuperate. Travelling is somewhat limited for me as I need to have that emr free space in which to sleep and recuperate. I am still able to undertake short plane flights occasionally and wear an emr shielding singlet for the plane trip (I have to take it off while going through the metal detector though, as it is threaded with silver and copper). I need to wrap an emr shielding scarf around my whole head, face and shoulders when the wifi is turned on in the plane carriage. With my detector I can measure the radiation level outside the scarf and inside the scarf. The scarf wrapping noticeably decreases the level of radiation impacting my head and upper torso region. Without the shielding I experience unpleasant head pressure in a wified plane carriage. Because there is still a relative ignorance of the health hazards of wireless radiation, so far people/individuals affected by it, like me, have to find their own solutions for themselves. I feel a deep concern for my grandchildren and the next generations, and the impact on nature and the bird, animal and insect life with whom we share and enjoy this planet. Two of my grandchildren used to attend Primary Schools where there was an emr impact from either existing or proposed towers and one was in a school with a wifi system that could not be turned off because the switch was installed on the roof. This is of extreme concern to me. The other resource from the 5G meeting was connection with a group of people who were feeling similar concerns regarding the impact of emr for our own and society's future. There is some solace and comfort in knowing that, and in being able to join with others, and too, in learning and knowing of the existence of paths forward being taken by other groups and individuals. I appreciate and find hope, in that some countries, regions and cities are looking at, examining and accepting, the debilitating health experiences of many people who have been exposed to toxic emr environments and they are also examining available independent scientific research proving biological effects from emr, and they are saying 'no', or else, caution is needed here, to the escalation of emr in areas under their jurisdiction.. Thank you for the opportunity to contribute. 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. Your sincerely, Marian (Porter) Australia

I have experienced mild to moderate to strong sensitivity to emf's ,increasingly being emitted from household and commercial WiFi and cell towers. I have been evaluated by health care practitioners for a combination of symptoms: low calcium levels, skin rashes, heart palpitations and irregularities and brain fog and mild generalized anxiety. I ask you to do independent research on the impacts of this technology on the whole ecosystem, as well as human health. I am deeply distressed that this technology has been rolled out without safety research. I remember watching Senator Blumenthal's hearing and panel of the ceo's of 5 big tech corporation and their admission that no safety research had been done.