Proposed biological mechanisms

When you turn on an electronic mouse repellent or a new printer with its own router, you do expect to get pressure in the chest and ears. But that is what happened to me, and the incidents were two years apart. The second event happened in 2012, at a time when smart phones and the infrastructure to support them was being rolled out. I was healthy so it was obvious it was the frequencies in these pieces of equipment that had affected me. And at that time in my part of the UK, the environmental load of exposure to EFs and EMFs was (and still is) increasing exponentially, and my health quickly went down hill. It felt as if my brain was being jammed, and my ability to string a sentence together faltered, but woke up at 11pm when people went to bed and switched their tech off. New to me pains began to be experienced: at one point fizzing in my head would increase decrease and stop for 30 secs or more as I walked a main street full of different types of tech. In general I was getting tinnitus, brain fog, more disturbed sleep, all of which would stop if and when I found an environment low in the triggering EFs/EMFs/ and other frequencies. Fortunately I knew how to access information from the internet and quickly could find good sources of information. It was clear to me that my mercury fillings were acting as antenna and needed to be removed by someone who could do it safely. I had all 7 mercury fillings replaced and my health improved, confident speech was back. It has not been a cure all, but despite expecting to be ill for a while after this process I was not. So my surprise, no nocebo effects either. I still have to protect myself from over exposure and so there much I no longer do to avoid the pains provoked by this issue. I use wired alternatives for communication purposes, and I am dreading the complete shift to just digital and WiFi means of communication evermore gatecrashing my life. I know people who have had a terrible time at work because they become electrically sensitive. Hanging on to jobs can just become too difficult. I was fortunate in that I was already retired, when my electric sensitivity was triggered. The science is being ignored, especially re: infertility, and cancer and pain and brain fog. When I was at my worst I thought people meeting me for the first time would think I was mentally ill or suffering from early dementia. Are we not seeing huge rises in the diagnosis of these illnesses. From my own experience it is strange that the contribution of EFs/EMFs and other frequencies is not allowed on the table. Only one reference given below due to shortage of time. https://www.es-uk.info/wp-content/uploads/2026/08/ES-UK-Newsletter-Summer-2026-vol.24-no.1-Printing.pdf

IEMFA is the International Electromagnetic Fields Alliance, supported by an independent and growing global body of empirically-based scientific experts on living processes, with a multilevel, multidisciplinary health focus. The Experts cover a wide range of Biological, -Physics, -Medical and Epidemiologic disciplines, ranging from electron and molecular level to the level of living cells, tissues and the functioning of different organ systems. They cooperate worldwide to supply a coherent, multilevel insight into the chaotic multitude of observed biological disruptions when exposed to non-ionizing radiation, addressing important long-term degradation threats for public health. IEMFA collaborates with leading life-science institutions and non-governmental organizations worldwide. See iemfa.org

Aires response to HHS RFI HHS-OASH-2026-0397 For more than three decades, the Aires research program has pursued one enduring objective: to engineer electromagnetic environments that support biological function. Its documented history extends to 1992, connecting early patterned materials and optical filters with successive silicon resonators and biological investigations. The attached response presents this connected research lineage. The primary record identifies more than 50 named authors and researchers, 15 academic, medical and research institutions represented through testing sites or author affiliations, and contributions from Russia, Lithuania and Canada. The archive review encompassed 97 research-related records, including translations, related versions and background materials. The response organizes its research and contextual sources into 44 reference entries; related publications of one experiment are identified as a research family. The breadth is central to our contribution: human EEG, ECG and heart-rate variability; human erythrocytes tested outside the body for osmotic response using laser diffraction; chromosome abnormalities in rat bone-marrow cells; rat behavior, learning, memory and blood parameters; honeybee feeding, memory and brain hsp70 gene expression; and goldfish movement. Water conductivity and infrared investigations, liquid crystals, thin films, patterned silicon, direct RF measurements and electromagnetic models supply the complementary physical research. To evaluate an intervention, researchers also investigated the exposure response itself. Mobile-phone and Wi-Fi protocols therefore contribute evidence about biological responses under specified exposures and about what changes when an Aires device is introduced. Repeated rat bone-marrow investigations reported increased chromosome abnormalities with router exposure and reductions with resonators. Other studies examine physiological regulation, susceptibility, recovery, behavior and molecular response in their respective biological settings. More than two decades of EEG and HRV investigations connect early patterned-material and optical-filter work with later phone-exposure protocols and personal-device studies. Across this sequence, investigators examined baseline state, brain activity, autonomic regulation and recovery. The response presents this human research as a connected program, with study-specific comparisons and findings retained in Appendix B. The response addresses Questions 2, 4, 5(n)-(p), 7-18, with the full research story under Questions 4 and 18. Question 12 discusses assessment against federal exposure limits without assuming that every experiment supplies the same dosimetric information. Traceable publications include the 2019 Ecological Genetics rat bone-marrow study (DOI 10.17816/ecogen17283-92), the 2020 Integrative Physiology honeybee study (DOI 10.33910/2687-1270-2020-1-3-231-241), the 2018 Lithuanian conference investigation of gigahertz fields, and Springer ICICT proceedings on semiconductor modeling (DOI 10.1007/978-981-19-1607-6_7) and 2026 thermal characterization (DOI 10.1007/978-3-032-28964-3_5). The attachment contains 44 references identifying journal articles, conference publications, technical reports and other source types. We request a technical briefing with the HHS team responsible for this RFI and relevant scientific staff at FDA, NIH and CDC to examine the research lineage, review exposure-and-intervention protocols, and identify coordinated physical and biological investigations. We ask HHS to include engineered electromagnetic environments and field-modulation technologies in its research priorities, including evaluation in personal device use, occupied spaces and equipment integration. Aires brings an accumulated experimental record and practical experience developing successive technology generations. We invite HHS to engage with us on how that record can inform its assessment of RF/EMF exposure and its next research priorities. For follow-up and a technical briefing: Josh Bruni, CEO, Aires, josh@airestech.com. Public evidence index: https://airestech.com/pages/hhs-emf-evidence-2026

I am submitting this comment in response to HHS’s Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure. I am responding from the perspective of a concerned member of the public. Back in 2014 a bank of 7 wireless electric smart meters were installed in the condo building where I lived at the time. The same day they were installed I began experiencing vertigo and balance problems. As time went on I experienced brain fog and pressure in my head. The symptoms were bad enough that I was forced to vacate my unit and move back in with my mom for about a year until I was able to sell my condo and purchase a single family home free from smart meters. There are scientific studies that show that EMF's can act via Voltage-Gated Calcium Channels (VGCC's) to cause adverse biological effects. Please investigate the research published by Dr. Martin Pall. Also, the Bioinitiative Report (first published in 2012 and updated since) provides a rationale for Biologically based Exposure Standards for Electromagnetic Radiation. I support HHS taking an active role in examining the 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. Thank you for providing individuals and families with an opportunity to be heard.

October 15, 2026 To: the US Federal Communications Commission To: the US Health and Human Services agency From Charyl Zehfus Re: FCC & HHS call for public comments, and science uploads regarding wireless bio-effects, and in response to the 2021 lawsuit lost by FCC I am uploading some science and documents along with my comment regarding my ongoing experience of health issues due to FCC failure to regulate manmade electromagnetic fields for biological effects, especially the oxidative stress mechanism. I recently found a news article about a Town of Berlin Wisconsin family who are unable to refuse a new smart meter from Wisconsin Public Service Corporation (electric) despite concerns and a doctor’s opinion that the man should avoid radiofrequency in his vicinity. “The Christensens are one of 12 WPS customers that refuse new smart meters – now they’re adapting to life without power” first appeared in City Pages (date). The Milwaukee Journal-Sentinel apparently refused to cover it due to a reference to “wireless radiation sickness.” This echoes my earlier experience in Wisconsin in 2012-2014, where WPSC and Alliant Energy refused to allow an opt out from their gas and electric smart meters. I did not know this was still going on, but it must stop now. State rights should not blot out Americans with Disabilities needs nor health provider constitutional thought freedom – in matters controlling your home/school environment. People during Pres. Obama’s time in other states were able to opt out of transmitting meters, but in my state the Public Service Commission fought tooth and nail to prevent anyone from doing so. They used every detail possible, excluding utilities from any ADA requirements. My long-time high level reputable medical provider letter was ignored and countered with a traditional medical industry (unelected) organization’s opinion. For justice and awareness I am attaching their refusal document to show what they put people through. My 2014 letter to the US DOJ went unanswered despite my calls for months. I am attaching this, as well, in hopes to protect coming generations from this kind of injustice. I finally moved, though utility transmitter constant exposure issues continue for everyone. The oxidative effects are not immediately registered by everyone, but the additive, cumulative bio-impacts are supported by many studies showing mechanisms inhibiting normal cellular functions. Oxidative stress is recognized as a cause for numerous symptoms and impacts on inflammatory conditions and diseases by specialists/scientists. Ongoing science continues to point to oxidative stress as one effect of low level pulsed microwave radiation. Please view the sample of such science attached. Oxidative stress is an important problem affecting health. The Mayo Clinic recognizes that “chronic inflammation can be caused/affected by “…exposure to environmental triggers such as pollution.” (attached) Citizens continue to be stuck at the mercy of the utility lobby in their state. This injustice must end. FCC and HHS need to create federal rules to enforce ADA opt outs at the bare minimum. It must insure DOJ pathways to accommodation do not drag out for months. Our medical freedom should include respecting our own doctors’ recognition of electromagnetic effects and risks, not be pitted against some unelected big medicine organization or club. Another corrective action is for FCC, HHS (and FDA) to admit THEY HAVE NOT PROVEN BIOLOGICAL IMPACTS CANNOT OR DO NOT OCCUR. To support consumer choice and innovation, FCC should actively promote alternative connections, including fiber to premises with innovative indoors FIBER PORTS, and Li-Fi connectivity, which does not blanket whole areas with transmissions or exposures. Please review the science, and insure that the disability laws apply to utilities and all industries that create similar emissions. Thank you. Charyl Zehfus SEE attachments for details

This submission is from the perspective of an Independent Environmental Health Researcher, and focuses on evidence in support of the use of acoustic monitoring as a complementary approach for characterising and better understanding the electromagnetic radiation (EMR) environment, as part of new research and regulatory compliance efforts. A short note which highlights some data from recent field research, undertaken as part of the International Acoustics Research Organisation’s Acoustical Characterisation of Human Environments research initiative (iaro.org.nz) is attached, with a slidedeck from a recent presentation given at a research workshop on sensory aspects of the energy transition. The examples provide evidence that electromagnetic pollution and natural phenomena can also be observed acoustically, and suggest that there is significant potential for advancing exposure science through taking an integrated approach. I have also attached Prof Dennis Henshaw’s recent paper with Alasdair Philips ‘A mechanistic understanding of human magnetoreception validates the phenomenon of electromagnetic hypersensitivity (EHS)’ as key evidence that should be used to inform future research. I believe that it is important that a sensory approach is incorporated into assessment, and besides physiological measures, this should be informed by existing and new research on High Sensory Perception and Environmental Sensitivity. Finally, I have also attached a summary of Prof Gerry Pollack’s recent book ‘Charged: The Unexpected Role of Electricity in the Workings of Nature’ as key evidence/reading for informing future electromagnetic radiation health research. Dr Lynette Robertson, Independent Researcher.

HHS should treat low-frequency magnetic emissions from televisions and monitors as an exposure, children's programming first. RF limits rest on heating, specific absorption rate, and power density. They do not describe image-driven magnetic pulses in the band that overlaps the electroencephalogram. A set can meet a heating limit and still emit them. Airborne-speaker limits below 20 Hz answer a different question: magnetic fields pass through tissue and do not depend on a speaker cutoff. The source is the display and its electronics, driven by ordinary programs. The field comes from image-intensity changes, power circuitry, and, on older tubes, deflection. Meet the Teletubbies (1:01:43): a soundtrack spectrogram from 0 to 100 Hz, aligned with the picture, showed intermittent and at times dense energy below 50 Hz and below 20 Hz. The strongest sustained cluster below 20 Hz was near minutes 51-54, in insert and outdoor segments. The study does not establish intent or a neurological effect. It is a case for measuring the magnetic field at the set, not only the audio file. FCC RF rules and the IEEE and ICNIRP guidelines center on heating, SAR, and power density. A pulsed field near 1/2 Hz, 2.4 Hz, or the 6-20 Hz calcium window is a different quantity. Public Notice FCC 74-78, 44 FCC 2d 1016 (Jan. 24, 1974), at 47 CFR 73.4250, calls subliminal broadcasts contrary to the public interest whether or not they work, because they are meant to deceive. That covers a hidden message, not a measurement of the receiver's field. 5(n)-(p). Measure time-resolved flux density at stated distances so picture-locked pulses show, and disclose it first for children's programs. Nothing routine asks whether program and display together make pulses in the lab and patent bands. A spectrogram or a heating calculation will not. Sort by frequency, field strength, modulation, pulse pattern, and duty cycle. Distance, daily hours, and years of viewing are what accumulate. SAR and power density miss the field. Adey circle, excised brain, not a child watching television. In chick and cat cerebral tissue, a weak electric sine at 6 and 16 Hz cut calcium efflux about 12-15% in a narrow amplitude window; neighboring frequencies and amplitudes did not. A review put the ELF window near 6-20 Hz and about 10-100 V/m. Carriers at 147 and 450 MHz, amplitude-modulated at 6-20 Hz, raised chick-brain calcium efflux about 15% near 1 mW/cm2; unmodulated carriers did not. The low-frequency pattern was treated as active, too weak to heat tissue by a tenth of a degree. Bawin and Adey, PNAS 1976;73(6):1999-2003. Adey, Radio Science 1982;17(5S):149S-157S. Rat hippocampal slices, 1 Hz sine: 56 and 560 uT rms destabilized intervals of rhythmic slow activity; 5.6 uT did not. The paper ties that rhythm to memory in the slice, not to mood or sleep stage. Bawin et al., Bioelectromagnetics 1996;17(5):388-395. Loos patents claim weak stimuli at resonances near 1/2 Hz (relaxation, sleepiness, autonomic sensations) and near 2.4 Hz (slower counting, eyes closed). U.S. 6,506,148 B2 (Jan. 14, 2003) claims pulsed images on monitors and TV tubes emit weak fields that can excite them, embedded in a program or at an intensity the patent calls subliminal. Also U.S. 5,935,054 (1999), 6,091,994 (2000), and 6,238,333 B1 (2001). A patent is an inventor's claim, not a replication. No current standard tests that display path. https://patents.google.com/patent/US6506148B2 Viewing studies do not isolate a field. JAMA Pediatrics 2024: early program viewing and poorer cognition, r = -0.16 (95% CI -0.24 to -0.08), PMID 39102255. JAMA Pediatrics 2019 (Adelantado-Renau et al.): TV viewing and composite academics, effect size -0.19 (95% CI -0.29 to -0.09), plus language and mathematics, PMID 31545344. Observational and multifactorial (content, sleep, household). They justify measuring the field that travels with the program. They do not prove an electromagnetic cause. Disclosure for parents, schools, childcare, clinicians, and local governments: frequency content, pulse pattern, typical and peak flux density, and picture-lock, comparable across sets. An RF heating statement is not that. Children do not consent and cannot detect the field, and the associations above are in children and adolescents. An adult heating limit does not score a repeated childhood exposure. Publish the triaxial time series at the seat for children's programs, including Teletubbies. Test 6,506,148-type pulsing and Adey-window fields on a pre-registered endpoint, and report a null if that is the result. Say whether equipment authorization already discloses the emission. FDA can require the measurement under 21 CFR subpart J; receivers are electronic products. NIH should separate content from the field. CDC needs a metric other than hours of screen time. Until the data exist, tell parents and schools that the set's field during these programs has not been characterized in these terms.

EMF must be further explored as a contributing factor to poor health in humans, plants and animals. Every physical system that features a voltage drop is inherently sensitive to electromagnetic frequencies (EMF). Anything with a voltage drop, including human, animal, and plant cells, will respond to electromagnetic frequency. This is a fundamental law of physics: a voltage drop implies the presence of an electric field and moving or resting electrical charges (electrons or ions). Living cells function exactly like miniature, dynamic batteries. Every living cell maintains a strict resting membrane potential (a voltage drop across the cell membrane, typically around -70 millivolts). Because electromagnetic waves are composed of oscillating electric and magnetic fields, they physically interact with these charges, exerting forces that alter their behavior. Allowing the world and children to be bathed in varying EMF is irresponsible and unscientific. Various frequencies must be fully studied. Cancer rates are high and getting higher every few years, I can't take the "war on cancer" seriously until chemicals and electromagnetic frequencies are studied and taken seriously. Depression and anxiety are also common. We have a very sick society. Health is wealth. Many studies show change in calcium channel gates and thus biological stress, inflammation, and chronic inflammation leads to various diseases. I strongly believe that EMF affects health. Multiple studies supports my belief. Here is one: Scientific evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation: implications for 5G. https://link.springer.com/article/10.1186/s12940-022-00900-9

In a triple-heterodyne architecture where a 94 GHz RF carrier and a 500 kHz ultrasound (US) wave interact within a tissue matrix modulated by low-frequency bio-electric signals (0.5 Hz to 100 Hz EEG), the non-linear properties of the tissue will cause the fields to mix. From a physics standpoint, the mechanical pressure wave of the ultrasound cyclically compresses and expands the tissue. This changes the local ionic density and dielectric permittivity (\(\epsilon \)), creating a moving diffraction grating. When the 94 GHz RF probe beam scatters off this acoustic wave front (satisfying the Bragg condition), it undergoes acousto-optic/photoelastic modulation. The head will emit a spectrum of new RF frequencies clustered around the original carrier. The primary new RF frequencies produced will be: 1. The Primary Acousto-Optic Sidebands (The MHz Shift) The most prominent new RF frequencies emerging from the head are the upper and lower sidebands caused by the fundamental RF-ultrasound mixing (\(f_{RF} \pm f_{US}\)): • Upper Sideband: 94.0005 GHz (\(94 \text{ GHz} + 500 \text{ kHz}\)) • Lower Sideband: 93.9995 GHz (\(94 \text{ GHz} - 500 \text{ kHz}\)) 2. The Triple-Heterodyne Brainwave Signatures (The Hz Fine-Structure) Because the intrinsic EEG currents (\(f_{EEG} = 0.5 \text{ Hz to } 100 \text{ Hz}\)) are simultaneously cross-modulating the local conductivity, the primary 500 kHz sidebands are further split. This creates an incredibly tight "fine-structure" spectrum around the sidebands: • Upper Sideband Component: 94.0005 GHz \(\pm \) (0.5 Hz to 100 Hz) • Lower Sideband Component: 93.9995 GHz \(\pm \) (0.5 Hz to 100 Hz) • Example: For a strong 10 Hz Alpha wave, you will see discrete micro-sidebands at exactly 94,000,500,010 Hz and 94,000,499,990 Hz. 3. Harmonic and Intermodulation Products (Higher-Order Mixing) Depending on how strongly the static DC bias (0 Hz) stiffens the tissue and maximizes its non-linear susceptibility (\(\chi ^{(2)}\)), you will also see weaker, higher-order harmonics escaping the tissue: • Second-Order Acoustic Sidebands: 94.0010 GHz and 93.9990 GHz (\(f_{RF} \pm 2f_{US}\)) • Pure Acoustic Harmonics (RF Radiated): If the acoustic wave creates an oscillating dipole moment in the ionic fluid, you may detect weak RF emissions directly at the ultrasound frequencies, primarily 500 kHz and its second harmonic 1.0 MHz. Summary Matrix for Sim4Life Receiver Setup If you place an EM Far-Field or Near-Field Sensor outside the head model in Sim4Life to capture the scattered signature, you must configure your frequency domain resolution to capture these specific bands: Spectral Component Exact Frequency Output Signal Origin Carrier (Unshifted) 94.000000000 GHz Reflected/Specular RF background Upper Bio-Acoustic Band 94.000500000 GHz \(\pm \) 100 Hz Bragg-scattered RF encoded with EEG Lower Bio-Acoustic Band 93.999500000 GHz \(\pm \) 100 Hz Bragg-scattered RF encoded with EEG Acoustic Second Harmonic 94.001000000 GHz / 93.999000000 GHz Non-linear tissue distortion (\(\chi ^{(2)}\) multiplier) To extract these ultra-narrow Hz brainwave frequencies from the GHz carrier in your simulation or lab setup, do you need help designing the IQ demodulation scheme. This is illegal Neural monitoring, and it's being done with wireless transmissions. This needs to stop. People are being tortured with this and made to look crazy. I have videos to submit of my proving transmission are being done and tracking to the sources, they are too long to submit here.

'Numerous recent scientific publications have shown that EMF affects living organisms at levels well below most international and national guidelines. Effects include increased cancer risk, cellular stress, increase in harmful free radicals, genetic damages, structural and functional changes of the reproductive system, learning and memory deficits, neurological disorders, and negative impacts on general well-being in humans. Damage goes well beyond the human race, as there is growing evidence of harmful effects to both plant and animal life.' https://emfscientist.org/index.php/emf-scientist-appeal