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This response addresses point 5 of the HHS remand in general, and 5.n in particular: “What scientific, technical, or regulatory changes by federal health agencies, if any, would improve the assessment, disclosure, and regulation of wireless radiation exposure.” Of particular concern are the assessments recommended by ICNIRP and IEEE ICES which underpin current exposure limits and will form the basis for future recommendations, as these assessments do not adequately meet reasonable scientific requirements, particularly when assessing studies investigating realistic RF-EMF exposures. Furthermore, these assessments apply requirements creating an in practice insurmountable evidentiary threshold before any non-thermal effect is given evidentiary weight, with serious consequences when setting exposure limits. This combination has so far produced conclusions of “no proof of risk”, which may be viewed as an artefact, i.e. produced by the assessments as such. Having studied this field for more than a decade, I have, together with scientific colleagues, developed a set of assessment criteria we consider necessary to improve the regulatory regime. These criteria aim to ensure that health risk assessments adequately consider studies investigating non-ionizing RF-EMF exposures below thermal levels, particularly under realistic exposure conditions, such as those encountered in everyday wireless communications. 1. Potential hazards and conclusions: Credible indications of potential harm must be identified and not disregarded due to a lack of full scientific certainty. All available evidence should be considered, and only excluded from the assessment based on scientific criteria such as serious flaws in the study design. 2. Distinguishing lack of evidence from evidence of no hazard: Insufficient evidence of harm must be distinguished from evidence that potential hazards are absent. 3. Transparent reporting: Evidentiary thresholds that reflect risk-management preferences must be explicitly identified. Risk-management preferences should not interfere with the risk-assessment. 4. Precautionary decisions: Credible indications of potential harm must be clearly reported, even when causation remains uncertain, to provide a scientific basis for considering preventive measures and their ethical, economic, and legal implications. 5. Exposure relevance and evidentiary weight: The relevance of the exposure characteristics to the target exposure scenario must be considered when assigning evidentiary weight to study findings, including findings of no effect. 6. Interpretation of exposure metrics: When assessing dose-response relationships, replication, and consistency across studies, the similarity of exposures must be evaluated using biologically relevant exposure characteristics, rather than assuming that similarity in a single exposure metric establishes biological equivalence. 7. Control-group exposure contrast: For hazard identification, exact dosimetry is not required, provided that it is reliably demonstrated that the exposed group is substantially more exposed than the control group. The exposure contrast must be sufficiently large and well characterized to support a meaningful comparison and minimize exposure misclassification. Assessments underlying the exposure limits recommended by ICNIRP and IEEE ICES do not fulfill these requirements, especially as to their handling of scientific uncertainty and the evidentiary weight they assign to studies investigating realistic RF/EMF exposures, while systematically assigning most evidentiary weight to studies with unrealistic exposures. Such methodological concerns also apply to other RF/EMF assessments based on ICNIRP and ICES theoretical foundations and methodologies, e.g. the European Commission's SCHEER opinion on RF/EMF health risks and the WHO systematic reviews prepared for its RF/EMF Environmental Health Criteria monograph. I recommend that HHS evaluate all scientific assessments intended to inform RF/EMF risk-management decisions against the proposed criteria before relying on their conclusions. The attached document, authored by five researchers who have studied and published scientific papers and books on the foundations of the current regulatory regime, provides the detailed reasoning behind these recommendations. It also forward references to methodologies suitable for assessing RF-EMF effects on human health in ways consistent with standard risk assessments for potentially toxic agents, as well as scientific literature establishing the scientific rationale for the proposed criteria. Else K. Nordhagen, Ph.D., Univ.of Oslo, Norway

I first noticed a light headed feeling when I was close to a modem many years ago. When I moved to another room, the feeling subsided. The next experience was when our power company installed smart meters wherever it was most convenient for them. They put one on my bedroom wall and I was dizzy, light headed and unable to sleep. I had to move and when it happened again at another rental unit, I was told I was too sensitive. I am unable to be close to modems for more than 15 minutes as I get dizzy and light headed, and have chosen to shut them off at night in order to sleep more soundly. I have found that I cannot live in some places because of the EMF fields and the radio frequencies, etc. and that if I can put up a 16" piece of sheet metal, on the wall where the smart meter or fuse box is, I cannot pretty much mitigate the intensity of the waves. I recently was visiting a home of a friend and felt very strange and light headed, almost losing my balance when I entered the bathroom, and it subsided when I went into the other room down the hall. I went back to that area and the same thing happened. I asked my friend and she said that their TV satellite dish was on the roof right at that room. And when I went into the bedroom to take a nap, the same thing happened. I looked on the wall and the smart meter was right on the bedroom wall and the neighbor's Satellite dish on their roof was aimed right at the bedroom as well. I had to leave the home as I was starting to feel very shaky from the EMF's and radio waves. Some of us are truly more sensitive than others to EMF, radio frequency waves and wifi. The cell towers they are putting into our communities are put right in front of people's homes and there are numerous cases of children and adults getting symptoms and there is nothing we can do about it because the county gave them permission to "help" us have better cell phone access and they are not required to alert the homeowners and phone companies are able to put them where they feel it is best for their company. We, the people, would like to have choice about our bodies and how we are impacted by new technologies. Smart meters should be put on garages where no one lives and not on our bedroom walls. And now we have new AI data centers that are being built with no care for the impact on the populations nearby. I cannot sleep with the modem on at night and have had to shut it off to avoid the way it impacts my sleep and my brain function. My hand starts aching when I hold my cell phone for more than 10 minutes. I use some protections that are sold by companies claiming to have devices that block the EMF's but they do not block them completely. I feel relieved when the phone is on airplane mode but still, the only full relief I feel is when it is shut off completely. I only can share personal experiences and have no documents to prove anything. I request that you please expedite safety reviews of the new technologies that will be even stronger than 5 G. As well as how we can be protected from all the smart meters and cell towers and computers that are everywhere emitting radio frequencies and wifi signals that truly have an impact on our bodies and brains and immune systems. There have not been enough research studies done to clearly document the impacts. And the research needs to be across a large population of children, adolescents and elders and those who have compromised health issues already, because I truly believe that we are harming ourselves and our families by not having protections available and having choice about what the new technology companies can do without our permission. Thank you for finally considering science do research about this. In our area, those of us who have the financial means to hire specialists come to our homes to use expensive meters that can check for "dirty electricity" and for EMF exposure and help us find ways to shield ourselves from the impacts on our bodies when we have not been able to figure out why we are not feeling well and there is no reason for it. And then we find out that our homes have very high EMF and radio frequencies and that the cell towers close by are all contributing to the high readings.

I support HHS taking an active role in examining the potential health and environmental effects of 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 HHS 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.

THE GOVT. AND THE CELLULAR COMPANIES PROFITEERING FROM THE ADVERSE HEALTH IMPACTS OF CELLULAR TECHNOLOGY ARE WELL AWARE OF THE DANGEROUS NATURE OF MICROWAVE TECHNOLOGY FOR HUMAN AS WELL AS ALL BIOLOGICAL HEALTH. THIS IS WHY IT IS BEING USED AS A WEAPON OF SILENT DEATH BY THE MILITARY INDUSTRIAL COMPLEX. WE LEARNED IN SCHOOL THAT THE MICROWAVE RADIATION CAUSES NON IONIZING DAMAGE TO ALL CELLS, AND DNA..HOW CAN IT BE "SAFE". HOW STUPID DOES THE GOVT THINK WE ARE???

1. & 2. I am responding as: an individual 3a. Type of wireless or RF/EMF sources involved (e.g., mobile phones, Wi-Fi, smart meters… ) WIRELESS TECHNOLOGY, SMART METERS, WIFI, CELL TOWERS, CELL ANTENNAS 3b. Nature, duration, frequency, and approximate timing (e.g., years): TEN YEARS 3c. Adverse health effect(s) experienced: DIZZY EQUILIBRIUM, AGITATED, EXACERBATION OF CHRONIC ILLNESSES 3d. Time from first exposure to first appearance of adverse health effects; and did a change in exposure coincide with the onset of adverse effects: A FEW MINUTES 3e. Was medical evaluation or treatment sought? (Optionally:) Was there a diagnosis? YES 3f. Were steps taken to reduce or eliminate exposure, and were there subsequent changes in the effects? FELT MUCH HEALTHIER WHEN AVOIDED EXPOSURE TO WIRELESS TECHNOLOGY, CELL ANTENNAS, CELL TOWERS, SMART DEVICES, WIFI AND BLUE TOOTH DEVICES 3g. Any supporting documentation? This includes Scientific Reports, exposure measurements, or other relevant information: YES. TOOK METER READINGS THAT SHOWED THERE WERE UNSAFE TO DANGEROUS LEVELS OF RADIATION AND EMF FIELDS Additional Details you would like to share about your experiences of adverse health effects you believe to be associated with exposure to wireless radiation CELL TOWERS, CELL ANTENNAS, WIRELESS TECHNOLOGY, WIFI DEVICES MUST BE BANNED. AND REPLACED WITH WIRED, CORDED TECHNOLOGY AND COPPER LANDLINE PHONE EQUIPMENT SERVICES B1a. Sources you experience as causing you Adverse Effects: CELL TOWERS, CELL ANTENNAS, SMART METERS, WIRELESS MODEMS AND DEVICES, WIFI, BLUE TOOTH B1b. Sources you can sense, but don't seem to harm you: SOME CELL PHONES, B1c. Sources you can use without sensing or being harmed: NONE B1d. Sources that seem to provide benefit (i.e., electrotherapy): NOTHING BUT AVOIDANCE OF EXPOSURE B2a. Health conditions you think may contribute to your sensitivity to EMFs including wireless: EXPOSURE TO EMF FIELDS AND RADIATION WORSENS ALL HEALTH CONDITIONS AND ILLNESSES B2b. Health conditions you don't necessarily associate with your sensitivity to EMFs including wireless, but might be relevant: NONE B3. For each sub question please list up to 5 drugs or therapies or home remedies (if any) NONE B3a. That you recommend, as they helped you tolerate or recover from EMF exposure: SHIELDING OF EXPOSURE, AVOIDANCE OF EXPOSURE B3b. That you recommend, but you’re not positive that they help: SOME NOT ALL SHIELDING SOURCES ARE NOT EFFECTIVE TO STOP EMF FIELDS OR RADIATION LEVELS B3c. That helped you but you don’t recommend. (e.g., the benefit did not last long or the side effects were too harmful): THE ONLY EFFECTIVE TREATMENT WAS ELIMINATE EXPOSURE TO THE WIRELESS TECHNOLOGY AND CELL TOWERS B3d. Treatments that had no effect: ONLY EFFECTIVE TREATMENT WAS TO AVOID EXPOSURE TO ALL WIRELESS, WIFI TECHNOLOGY, AND TO CELL TOWERS, CELL ANTENNAS, SMART METERS B3e. Treatments that made your sensitivity worse: ANY THAT INVOLVED USE OF WIRELESS, WIFI, BT TECHNOLOGY OR DEVICES B4. What is your age range? 60-75 B5. What year did you become aware of your sensitivity to wireless radiation or electromagnetic fields? IN 2015 B6. What country, state, province, or major city were you living in when you first noticed your sensitivity to wireless or electromagnetic fields? CALIF

A neighbor of mine, a former public official in a very responsible position has begun suffering from anxiety for the first time in his long life coincident with the rollout of 5G in our town. Doctors have been unable to find the cause. This person is now retired, spending most of his time at home helping with extended family child care. About 6 months ago a 5G station was installed on a pole on his street about 10 yards from his house. His formerly episodic anxiety has become nearly continuous and grown worse. In August he went on a two week family vacation in a fairly remote area with no cell service. He experienced a complete lack of anxiety at that location. His anxiety returned with a vengeance a few hours after he returned home. His doctor has advised him to move from his life long home to a rural location without cell service. This is not a controlled study, but as a natural history experiment it strongly suggests that there are serious health impacts from cell phone system radiation.

Every time i hold my cell phone to my ear to answer a phone call, I head a head buzz, feel spacy and brain fog. When I am in the city or near a cell tower I feel the same effects. The evidence has been proven for several years, thank you for now taking it into account.

See comment attached. *See Attached Testimonial From Another Innocent Individual Injured By Wireless RF Radiation Kevin Mottus, Outreach Director CA Brain Tumor Assn Email: wirelessbiologicaleffects@gmail.com

5G proliferation along interstate highways is rendering my car's AM radio unusable. I first started noticing significant disruption of AM reception in my 2010 Toyota Sienna early summer 2025. Affected interstates in Massachusetts were extensive segments of I95, I24, I495, I295 in particular. Over time the affected segments elongated and merged to the point where my radio has become unusable. Since last summer, the interference spread to local roads to the point that AM is unusable almost anywhere. This has clearly been caused as 5G nodes began appearing on poles along our local streets. If the emf radiation is powerful enough to prevent me from listening to a 50,000 watt nearby clear channel AM broadcast station, what detrimental effects has it been having on people?

See comment attached. *See Attached Testimonial From Another Innocent Individual Injured By Wireless RF Radiation Kevin Mottus, Outreach Director CA Brain Tumor Assn Email: wirelessbiologicaleffects@gmail.com