Wildlife & environment

The FCC says it operates under a "Public Interest Mandate", however by ignoring mounting evidence that radio frequency radiation is harmful, it is not fulfilling that mandate. There are many, many scientific studies that provide evidence that this technology is harmful. FCC should have exercised the Precautionary Principle ("When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause-and-effect relationships are not fully established scientifically") when cellular technology was first being introduced instead of believing the industry "experts" who were just interested in selling and expanding this technology as fast as possible. My job required that I used a cell phone as soon as they became widely available. I now have a brain tumor behind my right ear - exactly where I used to hold my cell phone to my head. The technology is dangerous and it is the job of the FCC to exercise its "Public Interest Mandate" and protect the public and not cave to the interests of corporations who just want to make a buck even if their products are harmful - sound like the tobacco industry? There are many experts in this area that can provide technical guidance and guidelines to the FCC. Some suggestions may include limiting cell tower locations, limiting the RF power of cell phones, requiring wired internet access to all homes, requiring copper wire land lines in all homes, the list can go on and on. Please have the courage to protect the citizens of the US.

I am writing regarding the FCC’s response to the D.C. Circuit Court of Appeals’ remand concerning its decades-old radiofrequency (RF) radiation exposure guidelines. The Court directed the FCC to provide a reasoned explanation for its determination that its guidelines adequately protect humans against harmful effects of RF radiation unrelated to cancer. Specifically, the court required the FCC to address the impacts of RF radiation on children, the health implications of long-term exposure, the ubiquity of wireless devices and technological developments, impacts on the environment, and the adequacy of the FCC’s testing procedures for cell phones and other portable devices. The FCC should fully consider evidence and real-world experiences concerning the health and environmental impacts of wireless radiation, including non-cancer health effects, impacts on children, long-term and cumulative exposure, cancer, and impacts on wildlife and the environment. The FCC is not a health agency and does not have expertise in medicine, biology or public health. Yet, the agency continues to assert authority over RF exposure standards and is preparing to reach conclusions about whether its existing guidelines adequately protect the public. I urge the FCC to recognize the critical role of federal health agencies, including the U.S. Department of Health and Human Services, and to rely on appropriate health and biological expertise when addressing the issues identified by the court. This issue matters to me personally because: I am a 34 year old woman whose life has been profoundly affected by a chronic, debilitating health condition, and who has spent nearly two decades searching for answers. My chronic migraines began when I was 15 years old. Around that time, a cell tower was constructed approximately 0.2 miles directly behind my family’s home. I cannot claim that this tower caused my illness, but the timing of these events has remained significant to me throughout my health journey. My symptoms quickly became so severe that I had to reduce my high school schedule. I woke up nearly every morning with debilitating migraines and vertigo, often unable to function. At one point, I missed more than 30 consecutive days of school. My family and I went from doctor to doctor, desperately searching for the underlying cause. I was prescribed countless medications in an effort to manage my symptoms, many of which came with adverse effects. My education suffered, my grades declined, and what should have been a formative, exciting period of my life became a daily struggle to get through the day. Rather than improving with age, my condition became progressively more severe. By age 26, I was experiencing symptoms that I associated with exposure to wireless devices and infrastructure. My arms would go numb while using my phone. I experienced stabbing pains in my head and stomach when people with cell phones came near me or when I was in areas near cell towers. As newer wireless technologies were introduced, I became increasingly concerned about the relationship between these exposures and my symptoms. My family went to extraordinary lengths to try to help me. We invested significant money in completely hardwiring our home and removing all wireless devices in an effort to reduce my potential exposure and find some measure of relief. This was not a casual lifestyle choice; it was a response to the debilitating reality of my daily life and our desperation to find answers. My family has had to make significant adjustments to our home and way of living because of the severity of my condition. The fact that my health concerns have required these kinds of sacrifices speaks to just how profoundly this has affected not only my life, but the lives of the people who love and support me. Also, when 5G technology was introduced in stadiums, attending sporting events became extraordinarily difficult for me because of the debilitating migraines I experienced. Travel became another challenge. Wi-Fi on airplanes, Bluetooth connections, and the wireless devices used by people around me became sources of concern as I struggled to manage my symptoms. Activities that most people take for granted; attending a game, boarding a plane, going into public spaces, or simply being around other people, became obstacles I had to weigh against the possibility of becoming severely ill. The consequences have extended far beyond physical pain. This condition has isolated me from experiences, relationships, opportunities, and the independence that most adults work toward building. I have struggled to maintain the health necessary to work consistently and support myself. Today, at 34 years old, I remain financially and physically dependent on my parents in ways I never imagined would define my adult life. I would give anything to have the freedom to attend a sporting event without fearing the consequences, travel without anticipating debilitating pain, work toward financial independence, and participate in everyday life without having to calculate the potential cost to my health. No one should have to spend nearly two decades fighting to reclaim a life they feel they have lost, while wondering whether an environmental exposure could be contributing to their suffering. People deserve answers. They deserve rigorous science, transparency, and a regulatory process willing to examine difficult questions. 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.

**Re: FCC ET Docket No. 13-84 — Human Exposure to Radiofrequency Electromagnetic Fields** To the Federal Communications Commission: My name is Elizabeth Anne Dunlap. I am a Colorado resident, a medical visualisation specialist with a master's degree in Medical Visualisation and Human Anatomy from the University of Glasgow, and an individual living with severe electromagnetic sensitivity (ES). I am submitting this comment to urge the FCC to reconsider its radiofrequency exposure guidelines in light of contemporary scientific research, reported health effects, and the lived experiences of people whose health and ability to participate in ordinary society are profoundly affected by their electromagnetic environments. **1. Existing RF exposure standards are inadequate** The FCC's existing exposure limits are largely based on protection against established adverse effects associated with tissue heating. These standards do not adequately resolve questions concerning potential biological effects of long-term, low-intensity, pulsed, or cumulative RF exposure. Research into oxidative stress, cellular signalling, neurological function, and other biological responses warrants continued independent investigation. The absence of scientific consensus about the clinical significance of reported non-thermal effects should not be mistaken for proof that all exposures below existing limits are harmless. **2. Electromagnetic sensitivity is a serious accessibility issue** My own experience illustrates the practical consequences of electromagnetic sensitivity. I experience severe physical symptoms that I associate with exposure to wireless infrastructure and devices, including migraines, stabbing pain, dizziness, burning sensations, nausea, and significant sleep disruption. These experiences have fundamentally altered my ability to work, travel, obtain housing, access public services, and participate in community life. I have invested considerable resources in modifying my living environment, including removing wireless equipment, using wired communications, and implementing electrical and RF mitigation measures. Regardless of ongoing scientific disagreements about the causes of electromagnetic sensitivity, the functional limitations experienced by affected individuals deserve serious consideration and appropriate accommodation. **3. The public needs meaningful opportunities to reduce exposure** Wireless technology is increasingly difficult to avoid. Smart meters, cellular infrastructure, wireless routers, connected appliances, and other transmitting devices have become pervasive in residential and public environments. People who wish to minimise their exposure should have practical, affordable options, including: - Access to wired telecommunications and internet services. - Non-transmitting utility meters and alternatives to mandatory wireless equipment. - Transparent information about RF emissions and infrastructure deployment. - Consideration of residential proximity and cumulative exposure when evaluating wireless installations. - Preservation of environments where individuals can live and work with reduced RF exposure. **4. Independent research and modernised exposure assessment are essential** The FCC should support a transparent review of peer-reviewed research, including studies examining biological endpoints beyond tissue heating. Exposure assessment should consider realistic conditions involving multiple transmitters, variable signal characteristics, chronic exposure, and populations with differing health circumstances. The Commission should also meaningfully address the findings and concerns raised by independent researchers, clinicians, and affected communities rather than relying exclusively on historical exposure assumptions. **5. Requested FCC action** I respectfully request that the Commission: 1. Reassess the scientific basis of its RF exposure limits through an independent, transparent, multidisciplinary review. 2. Evaluate evidence concerning non-thermal biological effects and long-term exposure. 3. Consider cumulative and real-world exposure conditions in future regulatory decisions. 4. Protect access to wired alternatives and reasonable accommodations for individuals reporting electromagnetic sensitivity. 5. Improve public participation, disclosure, and accountability in decisions affecting residential RF exposure. The Commission's responsibility extends beyond facilitating wireless communications. It must also give serious consideration to public health, accessibility, and the ability of Americans to make informed decisions about their environments. For individuals such as myself, this is not merely an abstract scientific debate. It concerns the ability to maintain a home, pursue a profession, obtain essential services, and live with dignity. Respectfully submitted, Elizabeth Anne Dunlap, MSc Morrison, Colorado

Before addressing the core matter of this submission, I must formally object to the absurd and needlessly restrictive architecture of the FCC’s public comment system. It is painfully obvious that this interface is designed to suppress public participation rather than encourage it, effectively shutting out the average citizen from participating in having their concerns heard and considered. Unlike the Department of Health and Human Services, which transparently routes public feedback through their centralized, user-friendly Regulations.gov portal, the FCC forces the public to navigate its own proprietary Electronic Comment Filing System. The FCC’s system does not even allow simple keywords and instead the user must use a highly specific numeric docket number (13-84) just to find the submission box. Unless you are actively tracking the court transcripts of current lawsuits against this agency, you will not know about this bracket number. By burying public comment portals behind an obscure and independent interface, the FCC has built a systemic barrier to entry. If a regulatory agency genuinely cares about public input, its systems should be built for the public, not just for corporate lawyers in insider litigants. But this is not merely a problem with how the FCC receives public comments. It is a problem with what happens when those comments are made and the agency fails to adequately respond to the human consequences. My complaint is real. It is personal, documented, and ongoing. As you are fully aware, the current RF exposure guidelines date back to 1996. In more than 30 years since those guidelines were established, wireless technology and the number and proximity of wireless transmitting facilities have changed dramatically. Yet the regulatory framework governing RF exposure has not kept pace with those changes. I live in Florida where state law allows communication facilities, including small wireless facilities, to be placed within public right of ways; Florida Statute 337.401. In my case, that regulatory framework resulted in a 5G small cell installation being placed on the swale adjacent to my property, 32 feet from my bedroom window. The combination of expansive telecommunications citing laws and outdated RF exposure standards has had a real consequence for my family. We have been forced to move from our home due to sickness directly related to RF exposure. I contacted the FCC directly. I explained my circumstances, documented my concerns, and provided two independent third-party reports specifically addressing the RF exposure situation at my property. I asked the agency responsible for this technology, you…the FCC, to consider what was happening to my family. I received no intervention. Looking back, you know what the court ordered you to do. The D.C. Court of Appeals found that the FCC had failed to provide a reasoned conclusion that its RF exposure guidelines adequately protected the public from harmful effects. You were directed to address those deficiencies. Yet five years later, I am living with the consequences of a regulatory system that has failed to adequately account for those concerns. I am asking the FCC to recognize that this issue is no longer theoretical. Families are living in close proximity to increasingly ubiquitous wireless infrastructure, and existing regulations must account for the realities of that environment. The public should not have to sacrifice access to their homes in order to accommodate an expanding wireless infrastructure. The FCC must comply with the law, meaningfully address the scientific evidence before it, and consider human consequences of its regulatory decisions. Public safety cannot be treated as an afterthought. -Amanda Albertelli

I urge the FCC to take a careful, science-based look at the potential health effects of long-term exposure to radiofrequency (RF) radiation and to reconsider whether the current exposure limits are adequately protective. The FCC's existing limits date back to 1996, while wireless exposure has increased dramatically with cell phones, Wi-Fi, Bluetooth, cell towers, and newer 5G technologies. Research has raised concerns about biological effects that are not adequately addressed by limits based primarily on thermal effects, including oxidative stress, DNA damage, reproductive effects, neurological effects, and effects on children. The scientific evidence deserves a thorough and independent review. Research has reported potential effects involving children's exposure, prenatal and developmental outcomes, oxidative stress, DNA damage, reproductive health, neurological function, long-term exposure, and wildlife. I ask the FCC to fully address this evidence, including potential effects from long-term and cumulative exposure and the particular vulnerability of children, before continuing to rely on exposure standards developed three decades ago. Public health protections should keep pace with the technology and the current scientific evidence. **References** 1. Gandhi, O. P., et al. (2012). *Exposure limits: The underestimation of absorbed cell phone radiation, especially in children.* Electromagnetic Biology and Medicine, 31(1), 34–51. doi:10.3109/15368378.2011.622827. 2. Fernández, C., et al. (2018). *Absorption of wireless radiation in the child versus adult brain and eye from cell phone conversation or virtual reality.* Environmental Research, 167, 694–699. 3. Aldad, T. S., Gan, G., Gao, X. B., & Taylor, H. S. (2012). *Fetal radiofrequency radiation exposure from 800–1900 MHz-rated cellular telephones affects neurodevelopment and behavior in mice.* Scientific Reports, 2, 312. doi:10.1038/srep00312. 4. Foerster, M., et al. (2018). *A prospective cohort study of adolescents' memory performance and individual brain dose of microwave radiation from wireless communication.* Environmental Health Perspectives, 126(7). 5. Yakymenko, I., et al. (2016). *Oxidative mechanisms of biological activity of low-intensity radiofrequency radiation.* Electromagnetic Biology and Medicine. 6. Güler, G., et al. (2012). *The effect of radiofrequency radiation on DNA and lipid damage in female and male infant rabbits.* International Journal of Radiation Biology, 88(4), 367–373. doi:10.3109/09553002.2012.646349. 7. Zothansiama, et al. (2017). *Impact of radiofrequency radiation on DNA damage and antioxidants in peripheral blood lymphocytes of humans residing in the vicinity of mobile phone base stations.* Electromagnetic Biology and Medicine. 8. Panagopoulos, D. J. (2019). *Comparing DNA damage induced by mobile telephony and other types of man-made electric fields.* Mutation Research – Reviews in Mutation Research, 781, 53–62. 9. Adams, J. A., et al. (2014). *Effect of mobile telephones on sperm quality: A systematic review and meta-analysis.* Environment International, 70, 106–112. 10. Houston, B., et al. (2016). *The effects of radiofrequency electromagnetic radiation on sperm function.* Reproduction. 11. Altun, A., et al. (2018). *Effects of mobile phone exposure on metabolomics in the male and female reproductive systems.* Environmental Research, 167, 700–707. 12. Yahyazadeh, A., Deniz, Ö. G., & Kaplan, A. A. (2018). *The genomic effects of cell phone exposure on the reproductive system.* Environmental Research, 167, 684–693. 13. Falcioni, L., et al. (2018). *Report of final results regarding brain and heart tumors in Sprague-Dawley rats exposed from prenatal life until natural death to mobile phone radiofrequency field representative of a 1.8 GHz GSM base station environmental emission.* Environmental Research, 165, 496–503. 14. Belpomme, D., Hardell, L., Belyaev, I., Burgio, E., & Carpenter, D. O. (2018). *Thermal and non-thermal health effects of low intensity non-ionizing radiation: An international perspective.* Environmental Pollution, 242, 643–658. 15. Balmori, A. (2015). *Anthropogenic radiofrequency electromagnetic fields as an emerging threat to wildlife orientation.* Science of the Total Environment, 518–519, 58–60. 16. Cucurachi, S., et al. (2013). *A review of the ecological effects of radiofrequency electromagnetic fields (RF-EMF).* Environment International, 51, 116–140. doi:10.1016/j.envint.2012.10.009. 17. Thielens, A., et al. (2018). *Exposure of Insects to Radio-Frequency Electromagnetic Fields from 2 to 120 GHz.* Scientific Reports, 8, 3924.

We have our house cabled, our TV and our computers. I keep my cell phone on airplane mode unless using. I can feel the energy in the house when the Wi-Fi is turned on and I do not sleep well. We keep the Wi-Fi off. The last studies on the current standards we use ( set in 1996) were done in the 90s.. don’t you think a little has changed since then?? All these satellites?? Wireless routers and cell towers popping up everywhere? Follow the trail of illness, sleep issues, etc. over the years. The decline in pollinators, known to be sensitive to electromagnetic energy..it is no accident and needs to be seriously studied. Do your due diligence! Thank you!

I am an eighty five year old retired female living in a retirement community in Northern California, since October 1013. After living here for about six months, I began having strange physical symptoms - heart palpations, dizziness, nausea and tinnitus. I started investigating the cause of these symptoms, and found six electric smart (wireless) meters on the outside bedroom wall close to where I sleep. They are pulsating high levels of radio frequency radiation 24 hours a day. I discontinued sleeping in that bedroom and the symptoms disappeared, except for the tinnitus. When I stayed at my nephews house in the country which has low EMFs, the tinnitus subsided. This scenario is a classic of someone suffering from electro hypersensitivity (EHS). I urge the FCC to reevaluate the upper limits of radio frequency radiation that are safe for humans and wildlife. In the many years since you set these limits, there have been many scientific studies showing that these limits are entirely too high. Many people like myself have suffered from wifi and 5G exposure. It is time for you to make changes.

I am writing regarding the FCC’s response to the D.C. Circuit Court of Appeals’ remand concerning its decades-old radiofrequency (RF) radiation exposure guidelines. The Court directed the FCC to provide a reasoned explanation for its determination that its guidelines adequately protect humans against harmful effects of RF radiation unrelated to cancer. Specifically, the court required the FCC to address the impacts of RF radiation on children, the health implications of long-term exposure, the ubiquity of wireless devices and technological developments, impacts on the environment, and the adequacy of the FCC’s testing procedures for cell phones and other portable devices. The FCC should fully consider evidence and real-world experiences concerning the health and environmental impacts of wireless radiation, including non-cancer health effects, impacts on children, long-term and cumulative exposure, cancer, and impacts on wildlife and the environment. The FCC is not a health agency and does not have expertise in medicine, biology or public health. Yet, the agency continues to assert authority over RF exposure standards and is preparing to reach conclusions about whether its existing guidelines adequately protect the public. I urge the FCC to recognize the critical role of federal health agencies, including the U.S. Department of Health and Human Services, and to rely on appropriate health and biological expertise when addressing the issues identified by the court. This issue matters to me personally because: [Please add your personal story here. You may wish to describe how wireless radiation has affected you, your child or family; health effects or cancer you have experienced; concerns about long-term exposure; experiences involving cell phones, Wi-Fi, cell towers or other wireless sources; or impacts you have observed on animals, wildlife, plants, or the environment.] I urge the FCC to give meaningful consideration to the experiences and evidence before it and to fully address each of the issues identified by the court.

I am writing regarding the FCC’s response to the D.C. Circuit Court of Appeals’ remand concerning its decades-old radiofrequency (RF) radiation exposure guidelines. The Court directed the FCC to provide a reasoned explanation for its determination that its guidelines adequately protect humans against harmful effects of RF radiation unrelated to cancer. Specifically, the court required the FCC to address the impacts of RF radiation on children, the health implications of long-term exposure, the ubiquity of wireless devices and technological developments, impacts on the environment, and the adequacy of the FCC’s testing procedures for cell phones and other portable devices. The FCC should fully consider evidence and real-world experiences concerning the health and environmental impacts of wireless radiation, including non-cancer health effects, impacts on children, long-term and cumulative exposure, cancer, and impacts on wildlife and the environment. The FCC is not a health agency and does not have expertise in medicine, biology or public health. Yet, the agency continues to assert authority over RF exposure standards and is preparing to reach conclusions about whether its existing guidelines adequately protect the public. I urge the FCC to recognize the critical role of federal health agencies, including the U.S. Department of Health and Human Services, and to rely on appropriate health and biological expertise when addressing the issues identified by the court. This issue matters to me personally because: While in the military I developed migraines and vertigo that were triggered by high EMF environments. Moreover, It is well know that HF radios in fighter jets cause cancer. Please reference any fighter jet systems manual. We use to call the cone of the antenna in front of the jet the cone of cancer. There are notes, warnings and cautions pertaining to this danger. While there are different frequency ranges to the many avionics in a fighter jet some of these frequency bands reserved for the military have been released for use by the tech industry within the civilian population(Why?). There is a clear safety issue with this current technology please also reference the military studies done on radar operators in the 60's and 70's showing health concerns. It's time to FOIA all government organizations to include the military for all experiments regarding technology using any type of frequency based power. Non ionizing radiation should be looked at differently than ionizing radiation. Ionizing radiation is more apt to cause damage via thermal heating. Non ionizing radiation is more likely to affect the calcium channels of the body therefore showing damage later in a persons life that is not expressed by thermal damage. Because of this it also tends to affect people in different ways depending on their individual exposures and body type. We know that different types of frequency's can affect a person with more fat differently than someone with less fat. We know a millimeter wave cannot penetrate the body as deep as a longer wave frequency. Therefore more fat could potentially equal more protection against a millimeter wave reaching an organ. This is especially important with children as most do not have the body fat of an adult allowing the millimeter wave to penetrate deeper into their developing bodies. Currently the FCC only looks at ionizing radiation effects, this is pure negligence on the FCC's side as it is common knowledge among anyone that works with avionics that there are other dangers to frequency then just ionizing radiation as I explained above. This issue is going to have the most damaging effects on our children. It's time to start caring about our future generations and immediately stop any further roll out of cell towers and wireless technologies, remove all antennas from schools, remove wifi from schools and cease the use of 3g/4g/5g towers within our cities until the FCC does its job and does a complete overhaul of its safety standards to reflect measuring all the dangers that can result from this use of technology. The FCC must also ensure the Tech companies are held to the strictest 3rd party study's to ensure what they are proposing is safe. Then the FCC must remove all employees with conflicts of interest ensuring no industry employees are allowed to ever work for the FCC or vice versa. Or at least have a 5 year no compete agreement in their contracts. The FCC should also be required to work with HSS. The HSS should study the health effects and then the FCC must be required to update its standards to ensure the dangers Identified by HSS are addressed in their safety standards. I urge the FCC to give meaningful consideration to the experiences and evidence before it and to fully address each of the issues identified by the court.

I am writing regarding the FCC’s response to the D.C. Circuit Court of Appeals’ remand concerning its decades-old radiofrequency (RF) radiation exposure guidelines. The Court directed the FCC to provide a reasoned explanation for its determination that its guidelines adequately protect humans against harmful effects of RF radiation unrelated to cancer. Specifically, the court required the FCC to address the impacts of RF radiation on children, the health implications of long-term exposure, the ubiquity of wireless devices and technological developments, impacts on the environment, and the adequacy of the FCC’s testing procedures for cell phones and other portable devices. The FCC should fully consider evidence and real-world experiences concerning the health and environmental impacts of wireless radiation, including non-cancer health effects, impacts on children, long-term and cumulative exposure, cancer, and impacts on wildlife and the environment. The FCC is not a health agency and does not have expertise in medicine, biology or public health. Yet, the agency continues to assert authority over RF exposure standards and is preparing to reach conclusions about whether its existing guidelines adequately protect the public. I urge the FCC to recognize the critical role of federal health agencies, including the U.S. Department of Health and Human Services, and to rely on appropriate health and biological expertise when addressing the issues identified by the court. This issue matters to me personally because both myself and at least 4 other of my family members have been irreparably injured by wireless radiation. Genetic testing has shown that members of our family lack a key gene responsible for detoxification of a wide array of pollutants, including wireless radiation. When exposed, our symptoms include headaches, dizziness, rashes, tachycardia, severe chest pain, uncontrollable shaking, and even seizures. Our lives have been impacted such that we no longer are physically able to live near towns or other sites of cellular towers. We are unable to maintain most jobs within the public sector because of the prevalence of wi-fi, Bluetooth, wearable wireless devices, and cellular phones. Increasingly, we are finding it difficult or impossible to travel anywhere, to attend public events, church services, concerts, schools, and other gatherings. We are also unable to drive or ride in newer vehicles with tire pressure sensors, GPS, and other wireless components. In one frightening episode, my infant grandson stopped breathing and turned blue when his mother simply sat down with him for a moment in her sister's emergency services truck, a vehicle equipped with Bluetooth, a mobile Hotspot, GPS, and a host of other wireless technology. Thankfully, my grandson's mother immediately removed him from the vehicle, and he began breathing again. She later measured the radio frequencies within the vehicle with the HF35C detector, and they were higher than the device could register. 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.