Exposure limits & testing

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 The current and greatly outdated standards for RF were and are completely inadequate.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

Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Reassessment of Federal Communications Commission Radiofrequency Exposure Limits and Policies Docket No. 13-84 COMMENTS OF Shirley Jackson Dated: October 22, 2026 Our youth are our future. FACT: By definition of the huge increase in EMF infrastructure during the Covid slow-down years, the exposure levels of children and pregnant mothers have skyrocketed especially since the EMF infrastructure deployment during the Covid shutdown years. FACT: the FCC has NOT completed its task to review the science pertinent to considering a change in Human Exposure Levels. On August 13, 2021, the federal district court ruled that the FCC had been arbitrary and capricious, i.e., did NOT do its job reviewing the huge number of public comments provided to them! As confirmed by email to FCC from then Environmental Health Trust's executive director Theodora Scaratto, there were no scheduled meetings calling for any of your "working groups" to properly analysis the science for indicators that a change in human exposure levels was warranted, no risk analysis. Why does this resistance to transparency and accountability go on and on; you wait 5 years (until after a major push-out of EMF infrastructure) to then say, "Oh we don't need any better regulatory guard rails or changes in human exposure limits." That makes about ten years of stalling so that corporations do not have to be accountable for a safe roll out. I love technology! I was a research project manager for the School District of Palm Beach County and I created a game-changing database that allowed us to detect when risk factors were showing up in a student's life. We designed programs for "Safe Schools" based on an astute reality of "what was happening." Decades ago, research was proposed linking various EMF exposures to people's ability to work or learn or to reproduce children. Back then the task of collecting data (time and specific device usage information) and then anonmously relating it to nationally detrimental risk factors (frequently now collected learning levels, work productivity, patterns of health challenges/absences, addiction rates/buying habits, car accidents, etc) was discounted as feasible. NOW, isn't that type of thing wireless companies do routinely? IT IS TIME THAT THE FCC STEP UP - to realizing that it CAN provide economic incentives and fair and equal access by realizing that there are sub-populations that SHOULD NOT be exposed to the current guidance. CONCLUSION Accordingly, I strongly urge the Commission to establish an expert working group – scientists and public health personnel to apply the priorities of citizen safety, to review the scientific evidence from the numerous studies conducted on this EMF human exposure topic and find that the current RF exposure limits are insufficient to protect public health and the environment. Change the basic premise that you cannot expect these exposures to be safe when they are based on only ONE device, instead of real-world usage…at least 25 devices, one per student in a single room. The exposure limits should be lowered to reflect the science previously disregarded by the Commission. Sincerely, Shirley Jackson Attached Study https://www.frontiersin.org/journals/public-health/articles/10.3389/fpubh.2026.1915745/full

I've been around computers and electronics since 1977, starting with mainframe computers and the old-fashioned tube displays. That was my job until 2003 when I retired. I'm always somebody who wants to try new things when they come out. At one time,I had three microwaves in my kitchen, or so I could cook three different items at the same time and have a full course meal come out in 30 minutes. When I started to work from home, I always asked for the fastest modem that was possible from my work. When the iPhone came out in 2007, I bought one and used it incessantly. I made the comment to myself “this may cause me problems later on, but I will deal with that then, because right now it is wonderful”. In 2012, I was living in my condo in Port Hueneme, California, called Surfside IV. I was on the second of three floors at the end of the building. In March, the electric company installed seven smart electric meters in the utility room that was directly underneath my master bedroom, underneath a closet. In May, for about two weeks, I noticed that whenever I walked back to the master bedroom, I tended to get a headache. My neighbor downstairs reported the same thing. I now believe this is when they were testing the smart meters. I was excited for them to be activated, so that I could monitor my electrical usage by the hour. Once a month I would call, asking when they were going to be fully activated. About three weeks into September, I called and was notified that they were activated at the beginning of September. Starting around the beginning of September, my sleep had gone from nine hours a day to 4 1/2 hours a day. I thought I just had a bad bout of insomnia. I had no idea that the smart meters had been turned on. I'm fairly smart, but with my lack of sleep, it took me a year to figure out what to do. I got four of the 7 smart meters replaced with manual ones. I replaced my wireless phones with wired, and I switched to Ethernet cords instead of wireless for my computer. This made a small improvement. The final step was to construct a Faraday cage, made out of aluminum screening that I constructed around my mattress on my platform bed, with one side opening up for me to get in and out, and the mattress inside. This reduced the reading on my meter to -65 DB. I then was able to sleep for 8 hours. At times, the cage would get tears in it and I found that if the reading went over -60 DB my sleep would deteriorate to six hours. This happened several times, so it was a multiple experiment that was corroborated. I found that if I was in an area that had -35 dB or greater, that within a half an hour, I would feel very nervous and my sleep would be affected that night. I found that being in meeting rooms with other people that had cell phones, even though there was Wi-Fi in the building, that if I had everybody turn their cell phones off, that the radiation was reduced by 90% most times. In other words, having cell phones on, in close proximity to me in a group, was much stronger than the Wi-Fi in the building. In a movie theater, I would have to go to a far corner, to be away from being in the middle of the group of people. In 2018 and in 2019, I was in the hospital for a total of 4 weeks . I had to be given drugs to help me get any sleep at all. In 2024 I was in the hospital for over three weeks. With opiates in me, I still had trouble sleeping more than two hours a night. I finally relented and let them give me Ambien, which allowed me to sleep six hours. I ordered an EMF blocking single pup tent that is designed to be used on motel beds. We installed that on my hospital bed and I was able to sleep six hours with no Ambien. In 2026, I was in the hospital again and used the same pup tent in both the emergency room and in the hospital, to good effect. I now find that I need to be in an area with no bars on my cell phone and no Wi-Fi hotspot around me to be able to sleep good. If I have electrical wires that are not metal shielded near my sleeping bed, my legs feel like I am being bit by small bugs. There are no bugs on my legs and no red marks indicating that I'm being bit. After shielding the wires or turning the circuit breaker off for them, the feeling goes away. If the building wires going near my bed are from circuits where neutrals have been shared or neutrals have been connected to ground, causing large magnetic fields to form, depending on the current flow, it will wake me up. In 2024 I collapsed with complete heart block, while traversing the spot in my bedroom that had high magnetic fields caused by not per code wiring. I had tried for several years to get the building inspector in the city, the HOA board, and the homeowners where the code violations seem to come from, to fix the code violation that had been identified by three different building biologist. I found that only about 1% of electricians are aware of this code violation, and that they regularly violate it because it saves them money and the building inspectors don't check for it. Human beings have a habit of enthusiastically adopting new technology. The new technology is sold and promoted by some individuals to make money. Therefore, they don't want anything to get in the way of enlarging their bank account. When DDT first came out, there was an advert in the 1947 issue of TIME magazine that said: "DDT is good for me". When automobiles first came out, it took decades before anybody put a seatbelt in them, even though anybody who knew physics, understood that that was an obvious cheap safety feature. The manufacturers did not want anyone to think, when they saw a car with a seatbelt, that maybe they might get hurt by using the car and therefore not buy it. This pattern is being repeated with wireless technology. DDT was banned, but we have made many improvements to make automobiles safer, as the benefits were worth the injuries and deaths that occurred. I believe the path that we took with automobiles, is the same one we need to take with wireless technology. I have read numerous scientific studies that indicate that children are much more affected negatively by wireless technology than adults. Children rely upon adults to guide them to live life safely. Are we implementing this technology in a way that minimizes the negative effects on children? Are we using the equivalent of booster seats, shoulder harnesses, and speed limits with wireless technology? Are we teaching the children how best to access the Internet with the minimum of wireless exposure? Are we giving parents hints on minimizing wireless exposure to their children? Certified electrical building biologists can help the FCC with this.

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

Thank you to the FCC for requesting information and public comment. I am commenting as an individual with a degree in physics and extensive knowledge of electromagnetic fields (EMF) and radio frequency (RF) radiation. The FCC invites comments on “other technological developments that have occurred since the Commission last updated its guidelines.” These guidelines and associated testing methodology from 1996 are beyond outdated for modern wireless infrastructure using digital pulse-modulated beam-formed radio frequency radiation. In laymen’s terms, the FCC's guidelines and testing methodologies are trying to measure a high-speed physical projectile, for example a bullet, with an old film camera. The impact of this physical projectile would be deemed harmless by the FCC’s methodology of basically averaging over outsize time and area. Cell phones from twenty years ago obviously don’t work on today’s cell networks. I encourage the FCC to contact Waterford Consultants in Frederick, Maryland, waterfordconsultants.com. Waterford Consultants has more than twenty years’ experience in radio frequency engineering, exposure assessment, and regulatory compliance. Waterford Consultants has recommendations for the gaps in the FCC’s testing methodology. The FCC also invites comments on “the ubiquity of wireless devices.” The telecommunications industry is frantically pushing wireless infrastructure and multitudes of cell antennas into every corner of the United States. Do the FCC’s guidelines and testing methodology address cumulative exposure to RF radiation that more and more Americans are experiencing? What was that about “safety of life”? Tobacco smoking was considered safe for decades driven by the tobacco industry’s greed before governments finally took action.

We are really in a public health emergency with all of the wireless devices and waves of exposure all around us. These exposure levels are said to be thousands of times over what could be a possible safe level where the science tells us that there really aren’t any truly safe levels for this kind of radiation (microwave exposure). There are thousands of studies, many collected in the Bioinitiative Report BioInitiative Report: A Rationale for a Biologically-based Public Exposure Standard for Electromagnetic Fields (ELF and RF) that demonstrate clearly that these exposures, even at very low levels, have dangerous biological effects. There is even an important study known as the EU Reflex Study which demonstrates that wireless radiation damages cells and DNA on pare with nuclear or gamma radiation. Reflex Study Finds Genotoxic Effects 2004 In city life we are completely surrounded and penetrated by countless exposures from every direction. There is not only the danger that comes from one cellphone,which is enormous, but the cumulative exposures from our neighbors, those coming from satellites, cell towers, smart meters, Bluetooth speakers, multiple WiFi routers in schools with multiple cellphones and other devices. It is a non-stop bombardment which is the cause of extraordinary health damage including cancers, neurological disorders, dementia ( Dr Sharon Goldberg says even in teenagers now) cardiovascular disorders, brain damage, blood toxicity, and anxiety, among many other health problems. I became extremely sensitive to these wireless microwave radio frequency radiation exposures after buying and driving an electric car. After a two hour drive I had an intense neurological breakdown where I could no longer sense the periphery of my body nor could I remember or track my thoughts. It was quite like I was experiencing dementia with a feeling of squeezing across the top of my head as well as a feeling that my brain was vibrating. I healed over time by avoiding all wireless exposures as much as possible as well as consuming large doses of many supplements, but I remain an electro sensitive person whose body is intensely disturbed by surrounding wireless exposures. I used to have to drive out to the countryside to be able to breathe when my neighbor would have his Bluetooth on (as well as when the smart meter was installed on my home- so fortunate to have my smart meter in opt out mode now but there is still some “dirty electricity” it causes that affects my health). I am very fortunate to have a new neighbor who keeps his Bluetooth off for me. There are also places in my home where I can feel the smart meters shooting through my home. I can’t stand very long at my sink without getting pains in my body from this, can not sit at parts of my dining room table nor use one of my bedrooms ( as it is to close to my other neighbors who use Bluetooth etc). It is quite a challenging life for an electro sensitive person ( though we are all biological and are all being damaged from wireless, the electro sensitive can feel the damage as it is happening). It really limits where I can go and how long I can stay in any given place. I could definitely not work in an office or school or even attend a dinner with people with their cellphones on etc. There are millions of people like me who have become electro sensitive all over the world. Many have been displaced from their homes because of cell towers or smart meters and other wireless nightmares. Many can no longer work in their jobs for which they have trained. Some have had to seek refuge in the forest or rural settings, though now with the proliferation of satellites and almost ubiquitous wireless coverage it is becoming more difficult to find a safe place to live. There are also dangers to our atmosphere, other living beings of nature( bees, birds, trees, etc, and the planet which we must be arrested immediately. This wireless proliferation should have been stoped a long time ago as the science has been available for decades. There is an important article from The Lancet - Planetary Electromagnetic Pollution: is it time to assess its impact? This is a critical situation, a real emergency, to preserve the health of people and planet. It requires immediate, sober and creative action. It is critically important that we primarily wire for communications and eliminate the waves passing through/damaging bodies. Cell phones as they exist now can be used in airplane mode with Bluetooth, cellular, and WiFi off, with an Ethernet adapter to access internet etc. There could be stations available at home, workplaces, around town, etc where one could plug in one’s phones or computers for connection. Utility meters and other tech could also be wired, avoiding the extremely damaging bodily trespass of microwave radiation.

Biological health and safety must be accounted for when placing cell towers- currently it is not. The FCC is not a health and safety agency, nor are they versed in biological harms from exposure to RF EMF from wireless base stations and devices. I have been injured and have a medical diagnosis of injury and disability from exposure from RF EMF from a cell tower base station, and it has upended my life, given me migraine like blinding ice pick headaches, nausea, dizziness, palpitations, insomnia and forced me from my home, having to sleep in my car and in makeshift accommodation to avoid exposure to let my body recover. Those injured by cell towers and smart meters should not be considered "collateral damage" and "the cost of doing business" as we were called. Health and safety cannot be guaranteed, and this docket shows the science and mechanism of harm. Those sharing their stories are the evidence of this harm and we deserve to be protected, assisted and made whole. The FCC does not track those injured by wireless. There is no registry, no avenue for redress or avenue to be made whole. In our case, our home was rendered uninhabitable by our Board of Health due to the nuisance, toxin and hazard emitted from the wireless transmitting facility built at the top of our neighborhood. We have been in litigation for over six years, more recently in the Supreme Judicial Court, who less than three months ago ruled that a uniform network is more important than the health and safety of those living in communities with wireless base stations- despite the science, the testimony of our doctors and subject matter experts and our lived experiences of injury and harm. The FCC prevents health and safety from being considered when siting a tower- but what is worse is those injured once the tower starts transmitting have no recourse. In my neighborhood, a resident commented that when she learned about the tower she had no feelings either way, but started developing insomnia and headaches once it started transmitting. She spent time at her boyfriend's house not near a base station and the insomnia and headache resolved. She returned home and so did her symptoms. This was the story of so many of our neighbors who testified to our City Council, Board of Health and our legislators. Soon we learned this was the story of many communities and individuals who had a wireless facility constructed near them or on their apartment buildings or school. This is backed up by studies of symptoms near cell towers, which return to normal baseline levels of illness at around 1640 feet. The FCC has all of these studies on file and have had them for years and years. Yet no action has been taken. Yet the FCC argues this is safe because the levels measured in my neighborhood are a small percentage of the FCC's antiquated 1996 exposure standards based on 80's science before the smartphone was invented and before towers were widespread. We have literally testified next to wireless representatives that towers were meant to built on the sides of highways and mountain tops. Now they are being built 100 feet from our children's bedroom windows and our babies are sleeping with vomit buckets because they are being sick in the middle of the night, experiences rashes, headaches, insomnia and dizziness to the point they are walking into the wall- so ill that their teachers are commenting they can't focus or stay awake in class, that they are passing out when sitting under a wireless access point, that 911 is being called to take them to the hospital when exposed to the wireless after it was "turned up" to accomodate more devices. This is inexcusable that our lives, our children and seniors lives are being upended because of being made ill from wireless exposure. Those who are suffering are not invisible. The FCC needs to work with our physicians whose goal is to protect our health. Literally our doctors wrote that they swore an oath to protect health, and with these exposures they simply cannot do their jobs because constant, 24/7 ongoing exposure is in direct conflict with the precautionary principle. And we have moved far beyond precaution. When a tower is placed in your neighborhood and 17 people come forward formally and publicly, and several more come forward informally and everyone agrees that the harm is from the cell tower, but no one knows how to help because of the FCC's rules and standards, there is no recourse, no action, no accountability and no help for those sick, displaced, suffering and now disabled due to their exposure. Our only medical remedy and recourse is to reduce exposure, but when we live next to a tower that is transmitting 24/7, and the source of the injury, the only option we have is to move. Many of those retired, on a fixed income, low income, or families simply in this economy cannot move. The choice is our homes or our health. If we pick health, we have to find somewhere else to go without wireless. Our Boards of Health have advised not to mistake ubiquity with safety. Many of us injured must constantly advocate for disability accommodations both in school, in the workplace and in our community buildings like the library or City Hall. We must hire attorneys, provide medical documentation and go through the test of if the accommodation to have a low RF environment is reasonable or not. Not everyone can afford to do this process, and those who try are told the FCC binds their hands. We should not have to fight for safety in our own homes. Our houses should be safe. We should be able to follow our doctor's orders in our own homes. If someone is disabled and installs a ramp to access their home, no one should remove the ramp. Yet when a tower is placed next to our homes, the RF is trespassing onto our properties and into our bedrooms and creating an environment that triggers life altering symptoms and our homes are no longer healthy or safe. The wireless company has essentially removed our ramp and now we must struggle to access and function within our homes. RF EMF is a hazard, carcinogen, nuisance and toxin- and we do not consent to ourselves or our children or our neighbors being involuntarily exposed. Unlike other sources of wireless, we cannot turn this off, limit our exposure or put it on a timer. We have no power, no control, no say and no recourse and this must change. The FCC's goal is to roll out telecommunications infrastructure to ensure everyone has connectivity, but this should not continue to be done at the expense of everyday Americans' health, safety, homes, families, neighborhoods, communities or our well being. We love, use and depend on our technology. We've learned that to be healthy, we need to do this safely so we are not sick. Cell towers near homes, exposing children, seniors and vulnerable populations is simply not safe. The FCC needs to revisit section 704 of the Telecommunications Act to ensure health and safety is considered when siting towers, and that there is a accountability and action for those sick, displaced and suffering. Given everyone agrees the 877 South Street Pittsfield Verizon cell tower should be moved, and land owners have offered alternative locations, perhaps the FCC should have a fund for communities to relocate injurious towers to safer locations, or a program where the FCC intervenes when people are injured. All I know is that the more we share our story, the more people reach out to us with stories of their own of wireless harm. Every state has a group or an organization. Every community knows of someone impacted. We will keep asking for help until we can live safely, full time in our homes without symptoms of wireless exposure. Thank you for your attention and your timely action in creating remedies for those harmed, and preventing others from being harmed through updating the TCA to reflect the lived experiences of those injured, the science, medicine and NH Commision Report recommendations for cell tower and wireless safety. The work has been done and the solutions have been proposed. Please listen to these experts. With gratitude, Courtney

I am a concerned Indigenous American, Creek Nation, and a Board Director of the Community and Friends of Seattle-Tacoma Pet Cemetery, a 501(c)(3) nonprofit. I submit these comments as an individual, not on behalf of the organization. I am a community member and advocate who is directly affected by a 100-foot industrial AT&T cell tower sited in a historic human and pet cemetery, and I write from firsthand experience. I have followed the permitting and legal record closely. The situation. The historic Seattle-Tacoma Pet Cemetery est. 1950 on Kent's West Hill is located in unincorporated South King County, Kent, Washington, in a community of color, immigrants, refugees, and low-income households. Humans, pets, K-9 officers, and service animals are buried here, some as whole families. Many cultural traditions exist here. In Indigenous cultures and spiritual traditions, animals are regarded as equally important as humans, deserving of the same dignity, honor, and respect in life and death. I hold that humans and animals call for the same and equal respect in life and death. In 2020, during the COVID-19 pandemic, Crown Castle installed a 100-foot industrial AT&T cell tower inside active Burial Block 13 with graves and mourners and 115 feet from neighboring homes in opposition to cemetery patrons, neighbors, and community members at large. It was installed in the wrong zone without a conditional use permit, in violation of King County Code and Washington State cemetery law. Additionally, Crown Castle did not disclose the human burials or the cemetery's historic significance on its permit application, and the project was pushed through the King County Department of Permitting and Environmental Review without addressing them. I have opposed its placement and operation since 2019. Why this matters to the issues before the Federal Communications Commission (FCC). The FCC is open to public comments for Cell Phone and Wireless Radio Frequency Radiation (RF) Health Effects and other Non-ionizing Electro Magnetic Frequency (EMF). I am talking about RF in this comment because that is the issue in the situation. The FCC's standards are the primary protection communities have against radio frequency radiation (RF) exposure. Under federal law, local governments generally cannot deny a cell tower based on RF health effects when it meets FCC limits. However, it is my understanding that communities can raise health concerns alongside other legitimate issues, such as zoning, permitting requirements, human remains, historic significance, etc. Our cemetery case involves all of these concerns. We should have the right to raise RF health concerns independently, without having to rely on other grounds for objection. If the FCC's standards are outdated, communities have limited recourse to protect residents, mourners, and their loved ones from potential RF exposure risks. Changes since 1996. The limits predate smartphones, small cells, etc., and constant connectivity. Towers now stand close to where people live and grieve, and people spend long periods near them. I ask the Commission to evaluate whether 1996 limits account for the ways that cell phones, cell towers, and the like are used and installed today including but not limited to chronic, daily, close-range RF exposure. Children and vulnerable people. Children live in the homes near this tower and visit the cemetery with their families. The record includes research showing children absorb more RF energy than adults (e.g., Fernández et al., 2018, Environmental Research). I ask the Commission to address children, pregnancy, and medically vulnerable people specifically. Long-term and non-cancer effects. The Commission should examine long-term, low-level exposure and non-cancer effects, including neurological, reproductive, and developmental effects, oxidative stress, and DNA damage, rather than relying on short-term heating thresholds. Animals and the environment. Pets, K-9 officers, and service animals are buried here, and wildlife lives on the grounds. The FCC has no wildlife-specific exposure limits. I ask the Commission to consider the research on effects on animals, insects, birds, and plants (e.g., Levitt, Lai & Manville, 2022, Reviews on Environmental Health, Parts 1–3). Testing and compliance. I ask the Commission to require independent, post-installation RF testing with public results that are easily accessible, so communities can verify compliance themselves at any time. There should be no barriers here. Why this is also a sacred space issue. Cemeteries are sacred regardless of a visitor's religion, meant to offer peace and tranquility, and dedicated in perpetuity to honor, remembrance, and love. A 100-foot industrial AT&T cell tower this close to graves and mourners intrudes on that purpose and raises serious concerns about exposure and potential harm to people and animals. My requests: • Update RF exposure limits based on a comprehensive review of current science, including but not limited to long-term, cumulative, and non-thermal effects, with specific protections for children, pregnancy, and vulnerable people. • Establish wildlife and environmental exposure standards, make them publicly accessible, and enforce them. • Modernize compliance testing and require public, independent post-installation testing. • Require easily accessible public records of tower locations, measurements, compliance, and complaints. • Adopt protective siting policies for sensitive places such as homes, schools, and cemeteries, and require disclosure of burial grounds and historic sites when towers are proposed. • Provide free advocates for the public to use to educate and support them in fighting for RF safety when necessary. • Stop giving away local control in cell tower permitting. Allow local jurisdiction and the public to decide if a cell tower siting plan is legal and appropriate and disallow it when necessary. • Support the retraction of permits when a cell tower or antennae modification application provides false information or omits information that is required for a complete application for consideration. I am not against cell towers. I support responsible telecommunications infrastructure and advocate for the safe, lawful, legal, ethical, and appropriate placement of cell towers. Not here. Not in an active, historic cemetery. Not among our beloved dead and those who come to mourn them. Thank you.

I am the Board Secretary of the nonprofit, Community and Friends of Seattle-Tacoma Pet Cemetery, a 501(c)(3) nonprofit. I submit these comments as an individual, not on behalf of the organization. I am a community member and advocate who is directly affected by a 100-foot industrial AT&T cell tower sited in a historic human and pet cemetery, and I write from firsthand experience. I have followed the permitting and legal record closely. The situation. The historic Seattle-Tacoma Pet Cemetery est. 1950 on Kent's West Hill is located in unincorporated South King County, Kent, Washington, in a community of color, immigrants, refugees, and low-income households. Humans, pets, K-9 officers, and service animals are buried here, some as whole families. Many cultural traditions exist here. In Indigenous cultures and spiritual traditions, animals are regarded as equally important as humans, deserving of the same dignity, honor, and respect in life and death. I hold that humans and animals call for the same and equal respect in life and death. In 2020, during the COVID-19 pandemic, Crown Castle installed a 100-foot industrial AT&T cell tower inside active Burial Block 13 with graves and mourners and 115 feet from neighboring homes in opposition to cemetery patrons, neighbors, and community members at large. It was installed in the wrong zone without a conditional use permit, in violation of King County Code and Washington State cemetery law. Additionally, Crown Castle did not disclose the human burials or the cemetery's historic significance on its permit application, and the project was pushed through the King County Department of Permitting and Environmental Review without addressing them. I have opposed its placement and operation since 2019. Why this matters to the issues before the Federal Communications Commission (FCC). The FCC is open to public comments for Cell Phone and Wireless Radio Frequency Radiation (RF) Health Effects and other Non-ionizing Electro Magnetic Frequency (EMF). I am talking about RF in this comment because that is the issue in the situation. The FCC's standards are the primary protection communities have against radio frequency radiation (RF) exposure. Under federal law, local governments generally cannot deny a cell tower based on RF health effects when it meets FCC limits. However, it is my understanding that communities can raise health concerns alongside other legitimate issues, such as zoning, permitting requirements, human remains, historic significance, etc. Our cemetery case involves all of these concerns. We should have the right to raise RF health concerns independently, without having to rely on other grounds for objection. If the FCC's standards are outdated, communities have limited recourse to protect residents, mourners, and their loved ones from potential RF exposure risks. Changes since 1996. The limits predate smartphones, small cells, etc., and constant connectivity. Towers now stand close to where people live and grieve, and people spend long periods near them. I ask the Commission to evaluate whether 1996 limits account for the ways that cell phones, cell towers, and the like are used and installed today including but not limited to chronic, daily, close-range RF exposure. Children and vulnerable people. Children live in the homes near this tower and visit the cemetery with their families. The record includes research showing children absorb more RF energy than adults (e.g., Fernández et al., 2018, Environmental Research). I ask the Commission to address children, pregnancy, and medically vulnerable people specifically. Additionally on the topic of children, as a public schools educator, board certified in special education, and again submitting this comment as an individual, I am against cell phone towers on near schools because they raise valid safety concerns for children and the staff that work with them. Research notes that children absorb more radio-frequency radiation due to their developing bodies which exposes them to long-term health problems such as cancer and neurological symptoms. (https://ehsciences.org/addressing-cell-towers-at-schools-science-based-policy-health-risks/) Long-term and non-cancer effects. The Commission should examine long-term, low-level exposure and non-cancer effects, including neurological, reproductive, and developmental effects, oxidative stress, and DNA damage, rather than relying on short-term heating thresholds. Animals and the environment. Pets, K-9 officers, and service animals are buried here, and wildlife lives on the grounds. The FCC has no wildlife-specific exposure limits. I ask the Commission to consider the research on effects on animals, insects, birds, and plants (e.g., Levitt, Lai & Manville, 2022, Reviews on Environmental Health, Parts 1–3). Testing and compliance. I ask the Commission to require independent, post-installation RF testing with public results that are easily accessible, so communities can verify compliance themselves at any time. There should be no barriers here. Why this is also a sacred space issue. Cemeteries are sacred regardless of a visitor's religion, meant to offer peace and tranquility, and dedicated in perpetuity to honor, remembrance, and love. A 100-foot industrial AT&T cell tower this close to graves and mourners intrudes on that purpose and raises serious concerns about exposure and potential harm to people and animals. My requests: • Update RF exposure limits based on a comprehensive review of current science, including but not limited to long-term, cumulative, and non-thermal effects, with specific protections for children, pregnancy, and vulnerable people. • Establish wildlife and environmental exposure standards, make them publicly accessible, and enforce them. • Modernize compliance testing and require public, independent post-installation testing. • Require easily accessible public records of tower locations, measurements, compliance, and complaints. • Adopt protective siting policies for sensitive places such as homes, schools, and cemeteries, and require disclosure of burial grounds and historic sites when towers are proposed. • Provide free advocates for the public to use to educate and support them in fighting for RF safety when necessary. • Stop giving away local control in cell tower permitting. Allow local jurisdiction and the public to decide if a cell tower siting plan is legal and appropriate and disallow it when necessary. • Support the retraction of permits when a cell tower or antennae modification application provides false information or omits information that is required for a complete application for consideration. I am not against cell towers. I support responsible telecommunications infrastructure and advocate for the safe, lawful, legal, ethical, and appropriate placement of cell towers. Not here. Not in an active, historic cemetery. Not among our beloved dead and those who come to mourn them. Thank you.

I am the Board President of the nonprofit, Community and Friends of Seattle-Tacoma Pet Cemetery, a 501(c)(3) nonprofit. I submit these comments as an individual, not on behalf of the organization. I am a community member and advocate who is directly affected by a 100-foot industrial AT&T cell tower sited in a historic human and pet cemetery, and I write from firsthand experience. I have followed the permitting and legal record closely. The situation. The historic Seattle-Tacoma Pet Cemetery est. 1950 on Kent's West Hill is located in unincorporated South King County, Kent, Washington, in a community of color, immigrants, refugees, and low-income households. Humans, pets, K-9 officers, and service animals are buried here, some as whole families. Many cultural traditions exist here. In Indigenous cultures and spiritual traditions, animals are regarded as equally important as humans, deserving of the same dignity, honor, and respect in life and death. I hold that humans and animals call for the same and equal respect in life and death. In 2020, during the COVID-19 pandemic, Crown Castle installed a 100-foot industrial AT&T cell tower inside active Burial Block 13 with graves and mourners and 115 feet from neighboring homes in opposition to cemetery patrons, neighbors, and community members at large. It was installed in the wrong zone without a conditional use permit, in violation of King County Code and Washington State cemetery law. Additionally, Crown Castle did not disclose the human burials or the cemetery's historic significance on its permit application, and the project was pushed through the King County Department of Permitting and Environmental Review without addressing them. I have opposed its placement and operation since 2019. Why this matters to the issues before the Federal Communications Commission (FCC). The FCC is open to public comments for Cell Phone and Wireless Radio Frequency Radiation (RF) Health Effects and other Non-ionizing Electro Magnetic Frequency (EMF). I am talking about RF in this comment because that is the issue in the situation. The FCC's standards are the primary protection communities have against radio frequency radiation (RF) exposure. Under federal law, local governments generally cannot deny a cell tower based on RF health effects when it meets FCC limits. However, it is my understanding that communities can raise health concerns alongside other legitimate issues, such as zoning, permitting requirements, human remains, historic significance, etc. Our cemetery case involves all of these concerns. We should have the right to raise RF health concerns independently, without having to rely on other grounds for objection. If the FCC's standards are outdated, communities have limited recourse to protect residents, mourners, and their loved ones from potential RF exposure risks. Changes since 1996. The limits predate smartphones, small cells, etc., and constant connectivity. Towers now stand close to where people live and grieve, and people spend long periods near them. I ask the Commission to evaluate whether 1996 limits account for the ways that cell phones, cell towers, and the like are used and installed today including but not limited to chronic, daily, close-range RF exposure. Children and vulnerable people. Children live in the homes near this tower and visit the cemetery with their families. The record includes research showing children absorb more RF energy than adults (e.g., Fernández et al., 2018, Environmental Research). I ask the Commission to address children, pregnancy, and medically vulnerable people specifically. Long-term and non-cancer effects. The Commission should examine long-term, low-level exposure and non-cancer effects, including neurological, reproductive, and developmental effects, oxidative stress, and DNA damage, rather than relying on short-term heating thresholds. Animals and the environment. Pets, K-9 officers, and service animals are buried here, and wildlife lives on the grounds. The FCC has no wildlife-specific exposure limits. I ask the Commission to consider the research on effects on animals, insects, birds, and plants (e.g., Levitt, Lai & Manville, 2022, Reviews on Environmental Health, Parts 1–3). Testing and compliance. I ask the Commission to require independent, post-installation RF testing with public results that are easily accessible, so communities can verify compliance themselves at any time. There should be no barriers here. Why this is also a sacred space issue. Cemeteries are sacred regardless of a visitor's religion, meant to offer peace and tranquility, and dedicated in perpetuity to honor, remembrance, and love. A 100-foot industrial AT&T cell tower this close to graves and mourners intrudes on that purpose and raises serious concerns about exposure and potential harm to people and animals. My requests: • Update RF exposure limits based on a comprehensive review of current science, including but not limited to long-term, cumulative, and non-thermal effects, with specific protections for children, pregnancy, and vulnerable people. • Establish wildlife and environmental exposure standards, make them publicly accessible, and enforce them. • Modernize compliance testing and require public, independent post-installation testing. • Require easily accessible public records of tower locations, measurements, compliance, and complaints. • Adopt protective siting policies for sensitive places such as homes, schools, and cemeteries, and require disclosure of burial grounds and historic sites when towers are proposed. • Provide free advocates for the public to use to educate and support them in fighting for RF safety when necessary. • Stop giving away local control in cell tower permitting. Allow local jurisdiction and the public to decide if a cell tower siting plan is legal and appropriate and disallow it when necessary. • Support the retraction of permits when a cell tower or antennae modification application provides false information or omits information that is required for a complete application for consideration. I am not against cell towers. I support responsible telecommunications infrastructure and advocate for the safe, lawful, legal, ethical, and appropriate placement of cell towers. Not here. Not in an active, historic cemetery. Not among our beloved dead and those who come to mourn them. Thank you.