ORIGINAL COMMENT · UNEDITED TEXT
Docket HHS-OASH-2026-0397. RFI on EMFs, RF radiation, and wireless exposure. U.S. radiofrequency limits need a comprehensive health review. That review should be run with the Department of Defense and the medical and scientific teams already investigating directed-energy bioeffects (DEBE), Havana syndrome, and anomalous health incidents (AHIs). It should cover non-ionizing RF, thermal and non-thermal, and it should not ignore ionizing radiation, which the public is also entitled to have explained in plain terms. Citizen health should not be traded for corporate convenience or an outdated heating-only rule.
Russia set much lower public RF limits than the United States, and did so from chronic, non-thermal studies rather than from a six-minute heating test. The history of those standards is in Repacholi, Grigoriev, and colleagues, Bioelectromagnetics 2012. Soviet and Russian public power-density limits have long been on the order of 10 microwatts per square centimeter. The FCC public limit above 1.5 GHz is about 1,000 microwatts per square centimeter, roughly 100 times higher. I take that gap as evidence that RF is under-controlled here and is a credible contributor to neurological and chronic disease that has been explained away for years. HHS should test that claim. It should not leave it to the licensing agency.
The mechanism file already exists inside the U.S. government. The National Academies (2020), An Assessment of Illness in U.S. Government Employees and Their Families at Overseas Embassies, found directed, pulsed RF energy the most plausible mechanism for the acute, directional AHI cases. Dizziness, headache, fatigue, nausea, cognitive deficit, and memory loss were also consistent with known RF effects. A 2022 intelligence-community experts panel likewise found pulsed electromagnetic energy plausible. The 2023 assessment that a foreign weapon was unlikely is an attribution finding, not a finding that pulsed RF cannot injure tissue. Pakhomov and Murphy (2000), written for the Air Force Research Laboratory Directed Energy Bioeffects Division, reviewed 114 Russian experimental studies and reported that pulsing, not average intensity, was treated as the dominant factor in low-intensity effects. Frey (Aerospace Medicine 1961; J Applied Physiology 1962) showed that pulsed microwaves produce a sound inside the head by thermoelastic expansion, a bioeffect set by the pulse, not by core heating.
Cancer evidence below a meaningful thermal story: NTP TR-595 (2018), an HHS study, found clear evidence of malignant heart schwannoma and some evidence of malignant glioma in male rats exposed to 900 MHz GSM and CDMA. Falcioni et al., Environmental Research 2018 (Ramazzini), found the same heart tumor in male rats at far-field, base-station-like exposure near 0.1 W/kg, close to the FCC whole-body public limit of 0.08 W/kg. IARC Monograph 102 (2013) classifies RF as Group 2B, possibly carcinogenic, on limited evidence for glioma and acoustic neuroma. In Environmental Health Trust v. FCC, 9 F.4th 893 (D.C. Cir. 2021), the court held that keeping the 1996 limits was arbitrary and capricious because non-cancer evidence was not addressed.
I want objective studies across major disease categories, not another thermal reassurance. Priority is Parkinsonian and Lewy-body syndromes: tremor, rigidity, autonomic failure, cognitive decline, and the overlap with AHI brain injury. Existing power-frequency meta-analyses do not show a clear Parkinson's association (Huss et al., Int J Environ Res Public Health 2015, summary RR about 1.05; Gunnarsson and Bodin, Int J Environ Res Public Health 2019, EMF RR about 1.02 for Parkinson's, higher for ALS and Alzheimer's). That is not a study of pulsed or modulated RF. Yakymenko et al., Electromagn Biol Med 2016, found oxidative stress in 93 of 100 low-intensity RF studies. Oxidative and mitochondrial injury is a shared pathway into nigral and Lewy-body disease and should be tested directly. Lai and Singh (Bioelectromagnetics 1995, 1996) reported DNA strand breaks in rat brain after low-intensity microwaves. Salford et al., Environ Health Perspect 2003, reported blood-brain barrier leakage and neuronal injury after GSM exposure at non-thermal SAR.
Request: a joint HHS-DoD-AHI evidence review; a public table of U.S. versus Russian limits and the biology each used; NTP restarted on pulsed versus continuous wave at equal average SAR, at or below 0.08 W/kg; disease-category studies, led by Parkinsonian syndromes, neurodegenerative disease, cancer, cardiovascular, immune, and reproductive outcomes; a de-identified registry for acute neurological events tied to a measured RF source; and a plain-language correction of the claim that compliance with the FCC limit means no biological effect. Ionizing exposure should stay under its own regulators, but HHS should publish one map so the public can see thermal, non-thermal, non-ionizing, and ionizing evidence side by side.