Children & vulnerable groups

I strongly oppose the placement of wireless communication towers or other wireless devices near residential communities, schools, churches, daycares, parks, and other places where children and families spend their time. Based on my own observations using an EMF detector, I have concerns about the levels of electromagnetic radiation emitted by these towers. I believe these emissions may pose potential health risks, especially to children whose bodies and brains are still developing. While I am not including scientific studies in this letter, there are many researchers and organizations that have raised concerns about the long-term effects of electromagnetic radiation exposure on human health. I do not believe that faster wireless internet speeds or any other reasons justify placing these towers close to areas where people live, learn, worship, and gather. Our society is already becoming increasingly dependent on internet-connected devices, and I am concerned that the continued expansion of wireless infrastructure encourages even greater screen use and digital dependency. Children especially need safe environments that support learning, social interaction, physical activity, and healthy development. For these reasons, I believe communication towers should be located well away from schools, churches, daycares, neighborhoods, and other places frequented by families and children. I respectfully ask that decision-makers prioritize public health and community well-being when considering the placement of these towers.

Dear Secretary Kennedy and the OASH Policy Team, My name is Addison Hansen, I am 16 years old, and I live in Frost, Minnesota. Please accept the attached letter as my official youth submission regarding the Department of Health and Human Services’ Request for Information on Electromagnetic Fields (Docket ID: HHS-OASH-2026-0397). I am writing to you because my generation's future health is directly on the line. While your office is doing the right thing by opening this inquiry to investigate the dangers of EMF radiation, regional utilities are trying to build the massive PowerOn Midwest 765 kV transmission line project right through our communities. It makes no sense to rush and build the biggest high-voltage powerline project in our region's history at the exact same time the federal government is admitting we need to pause and study whether these EMF levels are actually safe for us. My peers and I will have to live next to this infrastructure for decades to come. In my attached letter, I am calling on you, Secretary Kennedy, to stand up for young people and ask grid operators to halt the PowerOn Midwest project until your department finishes this RFI and updates federal safety standards. Thank you for listening to youth voices on this critical health issue. I have also mailed the letter to your office by express mail, but it will not be able to reach your office in time for the deadline. Sincerely, Addison Hansen 45468 60th St, Frost, MN 56033 507-525-8024

https://www.researchgate.net/publication/397309717_Increasing_Numbers_of_Children_Aged_5-19_Years_with_Memory_Problems_in_Sweden_and_Norway "Increasing Numbers of Children Aged 5-19 Years with Memory Problems in Sweden and Norway" "Discussion The data presented here show very disturbing trend of a rapidly increasing number of children and teenagers consulting medical care for memory problems or diagnosed with mild cognitive impairment, in particular over the last ve to 14 years in Norway and Sweden. The increase cannot be explained by changed diagnostic criteria or reporting frequency.What changes in children’s environment and life style might have contributed to this worrying trend of impaired memory and cognitive functions? There are multiple reports, both from animal experimental studies and epidemiological studies on humans, showing that microwave RF radiation exposure negatively impacts memory and cognitive functions. The hippocampus in the brain is important for short and long term memory, learning, and spatial navigation [41,42]. Several animal studies have also reported damage to the hippocampus from exposure to microwave RF radiation. Children’s exposure to microwave RF radiation from wireless technologies such as smart phones, base stations/antennas, Wi-Fi-routers, smart meters, and other wireless technologies that emit microwave RF radiation has also increased rapidly during the same time period as the increasing number of children with decline in memory and cognitive functions"

https://pmc.ncbi.nlm.nih.gov/articles/PMC6539318/ "Relationship between Physical Activity, Screen Time, and Sleep Quantity and Quality in US Adolescents Aged 16–19" "Abstract Despite the health benefits associated with physical activity (PA), screen time reduction, and sleep quantity and quality, the relationships between PA, screen time, and sleep quantity and quality remain unclear in adolescents. The present study is a cross-sectional analysis of data from adolescents aged 16–19 years who participated in the 2005–2006 National Health and Nutrition Examination Survey (n = 542). Multivariable logistic regression models, adjusted for confounders, examined the relationship between objectively measured PA, self-reported screen time, and sleep quantity and quality. Respondents who met the current PA recommendation had 50% lower odds of having sufficient sleep (≥8 h) than those not meeting the recommendation (OR = 0.50, 95% CI: 0.26, 0.94). Respondents who met the screen time recommendation (≤2 h/day) had 55% lower odds of reporting poor sleep quality than those whose screen time exceeded the recommendation (OR = 0.45, 95% CI: 0.22, 0.91), with similar patterns observed for females and males. However, males who met both PA and screen time recommendations had 73% lower odds of reporting poor sleep quality than males who met neither recommendation (OR = 0.27, 95% CI: 0.07, 0.99). In conclusion, PA and screen time are associated with sleep quantity or sleep quality in adolescents, and there are differences in these associations by sex."

https://bioinitiative.org/wp-content/uploads/pdfs/sec19_2012_Fetal_neonatal_effects_EMF.pdf Pregnant women with laptops close to their belly receive more EMF for the child than safety limits allow. But less so if the laptop is on a table. "Induced electric currents were estimated for both the pregnant woman and the fetus. Statistical values of the averaged current density were evaluated for body tissues including the body of the fetus, and the grey and white matter of the brain of the mother; the mother’s cerebellum, the mother’s cerebrospinal fluid and mother’s muscle tissue. In each case, the larger exposure was generated by the power supply rather than the laptop operation. Levels of induced current substantially exceeded ICNIRP public safety limits, assuming close proximity of the laptop to the belly of the pregnant woman (for the fetus, between 182% and 263.7% of the ICNIRP standard); and for the woman (between 346.7% and 483.5% of the ICNIRP standard). Simple measures to distance the laptop during use (placing it on a table or desk and not on the body of the user) will result in significant reduction of ELF-EMF exposure and induced electric current in both mother and fetus..." On how to reduce extremely low frequency EMF exposure in incubators. "To allow what is an essential medical intervention for the growing premature baby, or the sick infant who needs exceptional care following birth, at least two possible solutions to reduce ELF-EMF levels are:  Designing incubators with the motor far from the baby (some incubators already have adopted this measure) and  Using ELF-EMF absorbing panels to shield the baby’s body from emissions (like Mu metal)." ... Nurses get EMF near incubators. High EMF influences baby heart rate variability. "Another paper showed that nurses are also exposed to high EMF while working near incubators [ Bellieni, 2002]. Bellieni et al [2008] reported that the exposure to high electromagnetic fields can interfere with the sympathetic nervous system in altering babies’ heart rate variability. Heart rate variability (HRV) of 43 newborns in incubators was studied. HRV is an index of Autonomous Nervous System activity. The study group comprised 27 newborns whose HRV was studied throughout three 5-minute periods: 1) with incubator motor on, 2) with incubator off, and 3) with incubator on again, respectively. Mean HRV values obtained during each period were compared. The control group comprised 16 newborns but exposed to no source of ELF-EMF; they were exposed to changes in background noise similar to those provoked by the incubator motor (to reproduce the conditions of the first cohort). Mean total power and the high-frequency (HF) component of HRV increased significantly and the mean low-frequency (LF)/HF ratio decreased significantly when the incubator motor was turned off. Basal values were restored when incubators were turned on again. Changes in background noise did not provoke any significant change in HRV. We therefore concluded that ELF-EMFs produced by incubators influence newborns' HRV, showing an influence on their 8 autonomous nervous system. More research is needed to assess possible long-term consequences, since premature newborns may be exposed to these high ELF-EMFs for months." ... "Existing FCC and ICNIRP public safety limits seem to be not sufficiently protective of public health, in particular for the young (embryo, fetus, neonate, very young child). The World Health Organization International Agency for Research on Cancer has classified both ELF-EMF and RF EMF (wireless radiofrequency) as Possible Human Carcinogens (Group 2B). New, biologically-based public exposure standards are critically needed. Common sense measures to limit both ELF-EMF and RF EMF in these populations is needed, especially with respect to avoidable exposures like incubators that can be modified; and where education of the pregnant mother with respect to laptop computers, mobile phones and other sources of ELF-EMF and RF EMF are easily instituted. It is not in the public interest to wait: A precautionary approach may provide the frame for decision making where remediation actions have to be realized to prevent high exposures of children and pregnant woman."

https://www.scielo.br/j/jmoea/a/hS9VJvKddrTsTtyqLrVdNZx/?lang=en "...While the maximum simulated psSAR values are below the recommended limits, it is observed that, in some classroom arrangements, the psSAR can be substantially increased (e.g., up to 26 dB in the back) comparing to just one student with his laptop. One objective of this study is to provide guidelines for the design of safer classrooms in the context of widespread laptop usage."

"Mobile Phone Base Station Tower Settings Adjacent to School Buildings: Impact on Students’ Cognitive Health" https://pmc.ncbi.nlm.nih.gov/articles/PMC6775553/ "...High exposure to RF-EMF produced by MPBSTs was associated with delayed fine and gross motor skills, spatial working memory, and attention in school adolescents compared to students who were exposed to low RF-EMF."

"...Most recent studies find a positive correlation between RF-EMF and malig- nant glial cell tumors (Falcioni et al 2018).This study is unique as the researchers projected a lower SAR over a longer period of time. This suggests that long-term exposure may in fact be the cause for concern and not the SAR. If this is the case, it would render todays safety standards useless, as they are based on SAR. Another study found that there was an increased risk for glioblastoma and acoustic neuroma in heavy cell phone users (Hardell et al. 2013). The tumors observed were usually ipsilat- eral to the preferred side of cell phone use. These results are extremely important. Acoustic neuroma is a benign tumor on the vestibulocochlear nerve, just inside the inner ear. This is the closest organ to which one holds the cell phone while talking on the phone. While acoustic neuroma is not malignant, it can cause deleterious effects by putting pressure on the brain stem. The mechanisms by which RF-EMF potentially causes cancer are unclear. It is highly unlikely that RF-EMFs have enough energy in them to significantly heat up brain tissue to the point that would cause denaturing of DNA. It is highly debated whether they have enough energy to break a strand of DNA. However, even if there is not enough energy to denature or break strands of DNA, there would be enough energy to create ROS which can lead to genetic damage in the long term. Another adverse effect that RF-EMFs can have is on memo- ry. It has been reported that RF-EMF impair memory, cognitive function, and learning. Experiments show that rats that have been exposed to RF-EMFs for four weeks have performed poorly on inhibitory avoidance tests. The suggested mechanism for learning and memory impairment is that RF-EMF stimulates the opioidergic system in the amygdala, hippocampus and other areas crucial for memory consolidation. This may in turn impair the release of NO, which plays a role in memory consolidation (Ahmadi et al. 2018). Despite this, many researchers have not found RF-EMF to impair memory, learning or cognitive function (Klose et al. 2014). RF-EMF has been blamed for many other conditions that are not associated with the brain, such as hypofertilization and can- cers of the eyes and glands. These are extremely broad fields and are beyond the scope of this paper. Researchers are of the opinion that the mechanism that causes all these ailments is long-term exposure to RF-EMF. However, RF-EMFs do have the energy to potentially create ROS. ROS can be created by transfer of energy from the EM wave to the oxygen molecule or the transfer of a free electron. This has been shown to cause the creation of micronuclei (Kesari et. al 2014). A micronucleus contains a chromosome or part of a chromosome that is not in- cluded in the daughter nucleus after the nuclear envelope forms around the chromosomes during mitosis.This part of DNA that has been left out of the nucleus is enclosed in its own nuclear 42Aaron Skaist envelope and is attached to the nucleus. Formations of micronu- clei have also been associated with DNA double-strand breaks that lead to the incorrect copying of the chromosomes and for- mation of the nuclear envelope around them. Micronuclei have been used as markers for researchers and healthcare providers to reveal DNA damage and potential cancerous cells. If these micronuclei are a direct consequence of the EMF, then we can see a definite link between RF-EMF and DNA damage. However, even if the mechanism of the formation these micronuclei is not DNA damage, research has shown that the chromosomes inside the micronucleus have reduced functioning (Hatch et. al 2013). Eventually, due to the close proximity of the micronu- cleus to the nucleus, the contents of the micronucleus will be released into the nucleus. This often results in incorporation of non-functional DNA into functional DNA which can cause the cell to turn cancerous. Thus, even if the mechanism for micro- nuclei formation is not DNA damage, it is almost inevitable that the formation of micronuclei will lead to DNA damage. Each of these effects is highly debated amongst researchers. It is not clear whether the cause is the cell-phone or perhaps some other environmental stressor. However, there is over- whelming evidence that cell-phones have a negative effect on the brain of a child." https://touroscholar.touro.edu/cgi/viewcontent.cgi?article=1218&context=sjlcas

"...Most recent studies find a positive correlation between RF-EMF and malig- nant glial cell tumors (Falcioni et al 2018).This study is unique as the researchers projected a lower SAR over a longer period of time. This suggests that long-term exposure may in fact be the cause for concern and not the SAR. If this is the case, it would render todays safety standards useless, as they are based on SAR. Another study found that there was an increased risk for glioblastoma and acoustic neuroma in heavy cell phone users (Hardell et al. 2013). The tumors observed were usually ipsilat- eral to the preferred side of cell phone use. These results are extremely important. Acoustic neuroma is a benign tumor on the vestibulocochlear nerve, just inside the inner ear. This is the closest organ to which one holds the cell phone while talking on the phone. While acoustic neuroma is not malignant, it can cause deleterious effects by putting pressure on the brain stem. The mechanisms by which RF-EMF potentially causes cancer are unclear. It is highly unlikely that RF-EMFs have enough energy in them to significantly heat up brain tissue to the point that would cause denaturing of DNA. It is highly debated whether they have enough energy to break a strand of DNA. However, even if there is not enough energy to denature or break strands of DNA, there would be enough energy to create ROS which can lead to genetic damage in the long term. Another adverse effect that RF-EMFs can have is on memo- ry. It has been reported that RF-EMF impair memory, cognitive function, and learning. Experiments show that rats that have been exposed to RF-EMFs for four weeks have performed poorly on inhibitory avoidance tests. The suggested mechanism for learning and memory impairment is that RF-EMF stimulates the opioidergic system in the amygdala, hippocampus and other areas crucial for memory consolidation. This may in turn impair the release of NO, which plays a role in memory consolidation (Ahmadi et al. 2018). Despite this, many researchers have not found RF-EMF to impair memory, learning or cognitive function (Klose et al. 2014). RF-EMF has been blamed for many other conditions that are not associated with the brain, such as hypofertilization and can- cers of the eyes and glands. These are extremely broad fields and are beyond the scope of this paper. Researchers are of the opinion that the mechanism that causes all these ailments is long-term exposure to RF-EMF. However, RF-EMFs do have the energy to potentially create ROS. ROS can be created by transfer of energy from the EM wave to the oxygen molecule or the transfer of a free electron. This has been shown to cause the creation of micronuclei (Kesari et. al 2014). A micronucleus contains a chromosome or part of a chromosome that is not in- cluded in the daughter nucleus after the nuclear envelope forms around the chromosomes during mitosis.This part of DNA that has been left out of the nucleus is enclosed in its own nuclear 42Aaron Skaist envelope and is attached to the nucleus. Formations of micronu- clei have also been associated with DNA double-strand breaks that lead to the incorrect copying of the chromosomes and for- mation of the nuclear envelope around them. Micronuclei have been used as markers for researchers and healthcare providers to reveal DNA damage and potential cancerous cells. If these micronuclei are a direct consequence of the EMF, then we can see a definite link between RF-EMF and DNA damage. However, even if the mechanism of the formation these micronuclei is not DNA damage, research has shown that the chromosomes inside the micronucleus have reduced functioning (Hatch et. al 2013). Eventually, due to the close proximity of the micronu- cleus to the nucleus, the contents of the micronucleus will be released into the nucleus. This often results in incorporation of non-functional DNA into functional DNA which can cause the cell to turn cancerous. Thus, even if the mechanism for micro- nuclei formation is not DNA damage, it is almost inevitable that the formation of micronuclei will lead to DNA damage. Each of these effects is highly debated amongst researchers. It is not clear whether the cause is the cell-phone or perhaps some other environmental stressor. However, there is over- whelming evidence that cell-phones have a negative effect on the brain of a child." https://touroscholar.touro.edu/cgi/viewcontent.cgi?article=1218&context=sjlcas

"Results When cell phones are held close to the head most of the energy (more than 80%) from the transmitting antenna is absorbed by the head. When the phone is used for virtual reality viewing, the head absorbs 50% of the energy. Discussion In summary, compared with adult models, children experience two- to three-fold higher RF doses to: 1) localized areas of the brain when a cell phone is positioned next to the ear; and 2) the eyes and frontal lobe when a cell phone is used to view virtual reality. These findings raise serious questions about the current approach to certify cell phones; particularly the use of the SAM. In 2012, the U.S. Government Accountability Office advised that the test system used to estimate human exposure Conclusions Our findings support reexamination of methods to determine regulatory compliance for wireless devices, and highlight the importance of precautionary advice such as that of American Academy of Pediatrics (2016). The Academy recommends that younger children should not use cell phones, and that prudent measures should be taken to eliminate exposure (e.g. using devices for amusement or education only when all wireless features are turned off – in “airplane mode”) or to minimize exposure (e.g. ..." https://www.sciencedirect.com/science/article/abs/pii/S0013935118302561?via%3Dihub