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COMMENT ON SCOPE, AUTHORITY, AND SCIENTIFIC METHODS Formal Request for Transparency This comment raises material issues concerning HHS’s RF/EMF RFI. The notice says responses are voluntary and HHS will not comment on individual submissions. I do not claim HHS must answer each question now. If HHS, or other agencies involved in this RFI (e.g. FCC, and others), later relies on this record for reviewable action, HHS should disclose its basis and address material issues through the applicable process. 1. AUTHORITY. The notice cites “21 CFR subpart J” without a part or section. Give the exact citation and statutory authority. Distinguish research authority (42 U.S.C. § 241; 21 U.S.C. § 360ii) from binding electronic-product performance standards (§ 360kk). For power-frequency fields, consumer products, communications infrastructure, and occupational exposures, identify the authority and intended output. For sources outside “electronic product radiation” under § 360hh(1), identify the separate authority. 2. SCOPE AND LEGAL EFFECT. Will HHS separately evaluate power-frequency fields, consumer RF devices, communications infrastructure, and occupational exposures? Is the intended output research/nonbinding advice or binding requirements? Confirm the RFI itself does not change limits, testing, disclosure, or siting rules and cannot substitute for procedures required for later binding action. 3. CORRECTING QUESTION 6. The RFI asks about effects “caused by current exposure limits.” A limit is a threshold, not an exposure. Does HHS mean effects associated with exposures at or below applicable limits? How will it define exposure/outcome and distinguish measured from estimated exposure and association from causation? 4. REVIEW PROTOCOL. Before synthesizing evidence, will HHS disclose its search sources/dates, inclusion/exclusion criteria, outcomes, screening/extraction methods, and material protocol deviations? If no systematic protocol will be used, how will it guard against selective study inclusion? 5. STUDY QUALITY. What predefined criteria will assess confounding, exposure misclassification, statistical power, multiple comparisons, publication bias, replication, and conflicts? Will positive, null, and contradictory studies face the same criteria? Will human, animal, and mechanistic evidence be evaluated separately, distinguishing biological response, adverse outcome, association, and causation? 6. EXPOSURE MEASUREMENT. How will HHS validate dosimetry, report uncertainty, and distinguish SAR, power density, electric fields, and magnetic fields? Will it identify source, frequency, intensity, duration, and whether exposure was measured, modeled, or self-reported? 7. CUMULATIVE EXPOSURE. What validated method permits aggregation across different sources, frequencies, units, and durations? Will HHS justify additivity or dose-equivalence assumptions? If no common metric is valid, will it report source-specific measures rather than sum unlike quantities? 8. STANDARDS COMPARISON. For each standard, identify issuer/date, binding or advisory status, frequency range, metric, averaging time, population, endpoints, and uncertainty. Explain material differences before comparing limits. 9. SUBGROUPS AND ENVIRONMENT. For sensitive groups, will HHS identify prespecified analyses, statistical power, and multiple-comparison limits? How will it treat personal/clinical reports as hypothesis-generating, not causal proof? For wildlife and infrastructure, will it distinguish proximity from measured/modelled exposure and address confounders and field-study gaps? 10. TRANSPARENCY AND AGENCY ROLES. Will HHS publish methods, evidence tables, exclusions, bias assessments, exposure characterizations, uncertainty, and gaps, as law permits? Will it avoid vote-counting and double-counting studies across reviews? How will it distinguish HHS functions from FCC authority over communications facilities? Pursuant to 21 U.S.C. §§ 360ii, 360kk; 47 U.S.C. §§ 302a, 332(c)(7)(B)(iv). Thank you and God Bless.

See attached file(s)

*See Attached: Non-thermal Electromagnetic Field studies demonstrating harmful effects.

*See Attached: Non-thermal Electromagnetic Field studies demonstrating harmful effects.

*See Attached: Non-thermal Electromagnetic Field studies demonstrating harmful effects.

I submit this comment requesting independent scientific investigation, transparent environmental monitoring, and stronger public accountability regarding electromagnetic field (EMF), WIFI, and ELF exposure and its potential effects on human health, cellular function, neurological development, and future generations. The expansion of telecommunications and electrical infrastructure raises legitimate public-health and bioethical questions. Wireless RF radiation and extremely low-frequency (ELF) fields, including 60 Hz power transmission, have distinct physical characteristics and must be evaluated separately, including their potential cumulative and long-term effects. Located on schools, churches and parks. Children are stakeholders, not merely passive recipients of technological development. Their developing nervous systems, cellular processes, and longer potential lifetime exposures warrant specific scientific attention. Pregnancy, fetal development, infancy, and childhood represent critical periods during which environmental influences may have lasting consequences. Human health depends upon cellular homeostasis, mitochondrial bioenergetics, ATP production, DNA integrity, and coordinated neurological signaling. Disruption of these processes can contribute to disease and impaired development. Whether particular environmental EMF exposures adversely affect these mechanisms, and under what conditions, requires rigorous investigation rather than unsupported assumptions of either harm or safety. HHS should prioritize research examining oxidative stress, mitochondrial signaling, membrane potential, cellular repair, neurodevelopment, reproductive outcomes, and potential intergenerational effects. Studies must distinguish correlation from causation and evaluate exposure intensity, frequency, duration, developmental stage, and individual susceptibility. Existing epidemiological research has identified associations between certain residential ELF magnetic-field exposures and childhood leukemia, although a causal relationship remains unestablished. Such findings demonstrate the importance of continued investigation rather than premature dismissal of unresolved questions. The ethical question extends beyond whether an exposure meets current regulatory limits. It concerns whether those limits adequately account for developing biological systems, prolonged exposure, combined environmental conditions, and populations not sufficiently represented in existing research. Under principles of environmental justice, nonmaleficence, transparency, and intergenerational equity, the public deserves meaningful access to scientific findings and environmental exposure information. The burden of investigating potential public-health risks should not fall exclusively upon families who lack the resources to commission environmental testing or independent scientific evaluations. Communities should have access to infrastructure information, standardized exposure measurements, monitoring results, and understandable explanations of applicable safety standards. Public participation must be meaningful, particularly where infrastructure affects residential neighborhoods, schools, and vulnerable populations. I request that HHS: Support independent longitudinal studies evaluating RF, EMF and ELF exposures, particularly during pregnancy, infancy, and childhood. Investigate cellular and neurological mechanisms, including mitochondrial function, ATP metabolism, oxidative regulation, and neurodevelopment, using reproducible methods. Evaluate cumulative and chronic exposure patterns while distinguishing established effects from emerging hypotheses. Assess potential ecological consequences for wildlife, pollinators, vegetation, and interconnected environmental systems. Establish transparent public reporting of exposure measurements, research limitations, funding sources, and regulatory assumptions. Examine disproportionate environmental burdens and ensure meaningful stakeholder participation in research and policy development. Coordinate with the FCC, EPA, and relevant agencies to address scientific gaps and clarify oversight responsibilities. The absence of conclusive evidence of harm is not equivalent to conclusive evidence of safety under every exposure condition. Scientific uncertainty requires investigation, not speculation or complacency. Technological advancement carries corresponding responsibilities. Public-health protection should not depend upon proving widespread injury after exposure has occurred. Children, families, communities, ecosystems, and future generations are stakeholders in decisions affecting shared environments. Our responsibility is not simply to accommodate technological progress, but to ensure that progress does not compromise the biological integrity, developmental potential, and environmental inheritance of generations yet to come. Respectfully, Cherrish Castaneda Roots Indigenous Priory Sacramento County, California

I am a healthy person in my mid 60s. For the last 10 years, it's been increasingly difficult for me to engage in all the activities I enjoy, due the side effects that Wireless Radiation causes in my body. I am a scientist by training and have repeatedly observed how specific symptoms such as headache, elevated heart rate, increased blood pressure, insomnia, nausea and tingling skin sensations occur when I'm around wifi technology, and then dissipate when I leave wifi laden rooms and buildings. I have modified my home and work environments so there is no wireless radiation or smart devices, only wired connectivity, which produces measurable relief of my symptoms. The scientific literature on the physiological effects of EMFs and RF goes back to the 1950s when the military first conducted studies, and at this point consists of well over 10,000 published studies. The FCC safety guidelines are antiquated and inadequate, and there's an urgent need for these guidelines to be updated to incorporate scientific findings from recent decades. It is grossly negligent for the FCC to continue with their status quo, and to delay the implementation of more rigorous and accurate guidelines to protect public health.

It does not make sense that the policy has not changed over 30 years despite the sign having changed, and that it does not factor in recent developments, showing the toxic effects of proximity to these cell towers. It doesn’t make sense.

I am 92 years old and was told about the ill effects of wireless radiation and how it can affect peoples' lives. I now live in Oxford, CT. I am very surprised and concerned that the Oxford, CT schools would allow a cell tower to practically overlook the playground of an elementary school. Not only is there one school near the tower, but there are a total of three schools within about a quarter of a mile from the tower! The radiation from the tower could cause possible damage to the children, teachers, and staff which would impact them later in life. I think the federal government should regulate the placement of these towers and make sure they are not near any schools. I was a school teacher for 23 years with the Farmingdale School District on Long Island. I taught fourth and fifth grade. If I was teaching at the school where the cell tower is here in Oxford, I would have protested the placement of the tower in that location. Thank you for your consideration of this matter.

ORSAA is a not for profit research orgnaisation that compiles the resarch and publishes on the effects of electromagnetic fiels used in telecommunications and everyday devices on biological and halath effects in humans, animals and plants. Please find a repsonse to Q12 attacehd from ORSAA Australia