Proposed biological mechanisms

"...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

How do we know that 5G cell towers are safe to be placed directly on school campuses, where for example an elementary student will be in close proximity to that cell tower for up to 7 years (pre-K, kindergarten, 1st-5th grade)? One study examined students attending schools near cell towers and found differences in certain cognitive measures, and a new 2026 study of 200 elementary-aged children at eight schools found an association between higher RF exposure and a biological marker of genomic instability. Neither study proves RF causes illness, but the important point is that **the long-term effects of continuous environmental RF exposure in young children aren't settled**, and much of the broader research relies on cellphone exposure rather than school-based tower exposure. When there is uncertainty, especially when children are involved, it is prudent to use caution when discussing health impacts, especially because children don't get to choose their school environment. 2018: https://pmc.ncbi.nlm.nih.gov/articles/PMC6775553/ 2026: https://www.nature.com/articles/s41598-026-60822-1 The 2026 article finds that the higher RF levels schoolchildren were exposed to, the more micronuclei they found in those children. What are micronuclei exactly? From a different article, “Micronuclei research has regained its popularity due to the realization that genome chaos, a rapid and massive genome re-organization under stress, represents a major common mechanism for punctuated cancer evolution.”

I am writing as a concerned citizen to urge HHS to take seriously the growing body of evidence linking chronic, low-level exposure to radiofrequency electromagnetic fields to measurable biological and health effects, including the condition now recognized as EMR Syndrome (Electromagnetic Radiation Syndrome). Since the term was formally adopted in early 2025, awareness of this condition has grown rapidly, with an estimated 3–5% of the global population reporting symptoms ranging from headaches, insomnia, and cognitive impairment to heart palpitations, tinnitus, and neurological decline. These are not isolated or anecdotal complaints; they represent a pattern consistent with the peer-reviewed literature on non-thermal biological effects of EMR, including oxidative stress, mitochondrial dysfunction, and disruption of calcium signaling. As the wireless environment becomes denser with 5G small cells, Wi-Fi 6/6E/7, IoT devices, and the coming deployment of 6G at millimeter and sub-terahertz frequencies, cumulative exposure is no longer a theoretical concern but a daily reality for millions of Americans. I respectfully request that HHS and the interagency community treat the coming 6G rollout as an opportunity to apply the precautionary principle rather than repeating the regulatory lag that allowed 5G to be deployed before adequate long-term safety data existed. Current FCC exposure limits were established in 1996 based solely on thermal effects and do not account for non-thermal mechanisms, pulsed or modulated signals, or the cumulative burden of multiple simultaneous sources. I urge the Department to (1) fund independent, long-term epidemiological and mechanistic research specifically addressing 6G frequency bands and signal characteristics, (2) review and, if warranted, lower current exposure limits to reflect the best available science, (3) require pre-deployment environmental and health impact assessments for new wireless infrastructure, and (4) provide clear, accessible public guidance on reducing personal EMF exposure in the interim. The health of the American public — and particularly children, whose developing tissues are most vulnerable — should not be an afterthought in the race to deploy the next generation of wireless technology. It is critical to understand what 6G actually is, because it is not simply a faster version of 5G. A defining architectural feature of 6G is Integrated Sensing and Communication (ISAC), which merges radar-style sensing and data transmission into a single radio front-end, waveform, and signal-processing chain. In practice, this means every 6G base station will simultaneously carry data and act as a radar probe — transmitting a dual-function waveform, then analyzing its reflections to detect, locate, and track objects in real time. Because the network is ultra-dense, with hundreds or thousands of access points per square mile, the result is a massive distributed radar system that can image the physical environment continuously, from street level to the upper atmosphere. On top of that sensing layer sits the Internet of Everything (IoE) — a paradigm that goes far beyond the Internet of Things by intelligently connecting people, processes, data, and physical objects into a single living system. In an IoE world, the network does not merely transmit packets; it perceives, reasons, and acts. It monitors air quality, tracks vehicle and pedestrian movement, manages energy grids in real time, and coordinates autonomous systems — all while bathing the population in a denser, more complex, and more persistent electromagnetic field than any previous generation of technology has produced. The combination of ISAC and IoE means that 6G will not be a network we use; it will be an ambient, always-on sensing and decision-making layer woven into the fabric of daily life. That is precisely why the health implications cannot be assessed after deployment. The exposure environment will be qualitatively different — more sources, more frequencies (including sub-terahertz bands with no prior human exposure history), more modulation complexity, and no meaningful "off" state. I respectfully insist that HHS treat this not as an incremental upgrade but as a fundamental shift in the human electromagnetic environment, and that the precautionary measures requested above be in place before the first 6G base station goes live.

Non-thermal radiofrequency radiation is entropic waste. It is a fidelity stressor that disrupts the critical timing components of biology, and what it produces is bioelectrical dissonance and a meta-disease state. The evidence is already on the record. NTP and the Ramazzini Institute found the same rare heart tumor. The WHO-commissioned review rated glioma and heart schwannoma high-certainty. The FCC's own 2 mm tests hit 5.2 W/kg. Europe moves body testing to 0 mm by March 7, 2028. HHS should act now, and the end game is Li-Fi compatibility through the Clean Ether Act. Comment of John Coates on Docket HHS-OASH-2026-0397. Individual respondent. My full comment, with sources, is attached: It answers Questions 2 through 18, with every subpart, in order. THE EVIDENCE IS ALREADY ON THE RECORD (Q6, Q12). - NTP and Ramazzini, two independent lifetime bioassays, found the same rare tumor, malignant heart schwannoma, in male rats. Germany's BfS called Ramazzini's exposures "at a comparable level to the basic limit values for humans." - The WHO-commissioned review: "The CoE for an increased risk in glioma was judged as high." Heart schwannoma was rated high too. - NTP held heating under 1 degree C, and NTP itself says: "The role of thermal changes on cancer development needs to be further investigated." GSM gliomas ran 0, 3, 3 and 2 per 90 across sham, 1.5, 3 and 6 W/kg. Heat does not draw that curve. HHS should fund the investigation NTP called for. - NTP's 1.5 W/kg is a whole-body average; the FCC's 1.6 W/kg limit is a 1-gram local peak. Different measures, but the numbers sit right on top of each other. The iPhone Air's 1.60 W/kg is the highest simultaneous-transmission value reported in its FCC grant. THE TEST MISSES THE BODY (Q5(p), Q7, Q8, Q9). - The FCC's own 2019 tests at 2 mm recorded up to 5.2 W/kg. - Europe moves body testing to 0 mm by March 7, 2028. The U.S. still certifies at typically 5 to 15 mm. - SAR averages away the timing biology reads: GSM bursts about 217 times a second, Wi-Fi beacons about ten times a second, DECT and 5G NR use 10 ms frames. - Require 0 mm testing, and disclose test distance and pulse structure with every SAR value. THE META-DISEASE STATE (Q10, Q12). RF does not need to cause one unique disease to matter. It only needs to reduce the fidelity of the systems that prevent many diseases. Bioelectrical dissonance is the process, low-fidelity biology is the state, and disease susceptibility is the consequence. The causal fingerprint is not one diagnosis. It is a shifted distribution of biological failure: rare becomes less rare, late becomes early, recoverable becomes persistent. S4-MITO-SPIN (Q12). The S4 helix of the VGCCs, including CACNA1C, is the bulk-calcium gate; Cyb5b is the internal-timing transducer (Kim et al., Cell, 2026: "an essential mediator likely acting as an EMF sensor"); mitochondria are the redox amplifier (95% of 131 non-thermal studies found oxidative effects); cryptochrome-to-flavins spin dynamics are the modulator. At matched SAR, pulse modulation, not the carrier, changed human EEG and blood flow. HHS should test whether pulsed exposure disrupts pulsatile insulin release, which runs on the same calcium machinery. SENSITIVE POPULATIONS (Q11). Development has no restore point. Children absorb higher local doses; NTP pups were born smaller; responses differ by CACNA1C genotype and mouse strain; aging neurons carry more L-type calcium channels. WHAT I ASK (Q5, Q15, Q16, Q17, Q18). - Reinvigorate Public Law 90-602. It is HHS's job. The Secretary "shall establish and carry out an electronic product radiation control program" and develop techniques "for minimizing exposure." Publish the performance-standard determination and a public work plan; replace FDA's tumor-only 2020 review. - Run the meta-disease experiment: pulsed RF vs carrier-only vs sham at matched SAR, from the womb, measuring fidelity endpoints before pathology (NIEHS/NTP). - Fund Cyb5b, CACNA1C and organoid replication (NIH); build registries and measured-exposure cohorts (CDC); issue precautionary guidance now. - Repeal Section 704, which bars localities from weighing RF health effects in siting. - Pass the Clean Ether Act: fiber, Ethernet and Li-Fi on IEEE 802.11bb indoors, with pilots in Head Start, childcare, maternity and pediatric care, and HHS facilities. Invisible does not mean irrelevant. Non-ionizing does not mean non-biological. Legal does not mean safe. I was diagnosed with kidney cancer at age 7 in 1977, with my left kidney removed at age 8, while my family lived near a radar installation on a military base. In 1995 my daughter Angel Leigh was born with anencephaly and did not survive. My daughter was the canary in the coal mine... and so was I. John Coates RF Safe

Strong manmade wireless radiation damages all living things. The biological effects have been known for many years. saferemr.com bioinitiative.org The race to saturate the earth over the last 30yrs may have had many different motives, but it has thrived on public ignorance. Nature already had the perfect balance of electricity in all things, now it is hard to find a natural place. EMR & RFR causes chaos in molecules, disturbing & damaging natural function. Radiation sickness is now common as emissions are now hard to avoid. Blood, brain, heart and body functions are all immediately affected by exposure to wireless fields. I have witnessed hundreds of people suffering with conditions and cancers. The industry needs to be regulated. There needs to be rules. There needs to be balance. Only low radiation products should be allowed. Irradiating should be a crime. There should be routine testing of RFR & EMR levels in all areas. There should be information & education. There should be consent/choice/options. There should be safe areas/low radiation zones in all buildings/transport/parks etc. There should be more shielding in products and in public places. Thank You.

2. Individual & research entity 3.a. Everything is frequency 3.b. 24/7/365 3.c. Discombobulation 3.d. 2012, 1995 3.f. Meta cognition 5.n. Transparency 5.o: Aliens minimize exposure to electromagnetic radiation as they are telepathic and traverse space through time through consciousness. They have an understanding about how everything – light, dimensionality, fractality – makes One. Light travels at 186,282 miles/sec*. If you convert that to nautical miles per geometric second*, its approximately 143,526.736. The reason the figure is not exactly 144,000 is because space time is changing. When you measure in geometric time, you can drop leading and trailing zeros, the decimal point and truncate numbers because space collapses to a wave where time is eternal. Therefore, light can more simply be expressed as 144. Since we have intuition and can do things like channel, we are in the 5th dimension which is expressed as 432 hertz* and cymatically as the penteract or the double pentagon. All of nature is expressed fractally by the golden ratio, 162*. This is how aliens see the Oneness in everything, the product of - light, dimensionality, fractality – 144 times 432 times 162 equals One. All light expressed as a pentagon has an equal and opposite pentagon in the penteract which must be an information field. The light and opposing information field must meet on an inertial plane with gravity making gravity the reciprocal of light. Accessing that plane through two roots of the golden ratio, one for each the light and the information field, equals the Schumann resonance (1/144 X root root 162 = 783). The Schumann resonance is the standing wave of earths cavity and everything on it connected non-locally through piezoelectric transduction of the pineal gland. Two opposing waves creating that differential must access the plane as it recreates the double pentagon where all living organisms exist uniquely through DNA. Life can then be modified through a gravity quantum computer using meta materials by reflecting down into the 5th dimension for an ion cyclotron resonance like effect. This is efficiently radiating consciousness evolution tech that can be programmed for either ascension or descension as it works in the infinite quantum information field where One, or our fragment of it, see either possibility (no nanites required) or a limited 3rd dimension based on reinforced models. My opinion: 1. Research the 144 degree angle of the penteract in a ten by ten resonance in DNA for singularity through meta material space wave collapse in a light based quantum computer. 2. Accelerate acknowledgement of the profound positive health effects of ion cyclotron resonance in the biologically active window of 70 millivolts or 50 microtesla. 3. Collaborate art and science to merge subjectivity and objectivity through transformative fine art so community taps into its natural creativity to ask – how is this possible? (Montreal engineer now in Sedona Jimmy Blanchette of Human Initiated Contact has done ground breaking research into this. Gerret Lisi of E8 has begun discovering the science behind the penteract and hyper cube geometry based on existing models. Klee Irwin of Quantum Gravity Research has begun laying the philosophical foundations. Seqex of Italy has created ion cyclotron resonance technology). *Expressions of fixed intervals over another. Special thanks to: Dr. Nick Begich, Dr. Joe Dispenza, and Adam Apollo 7. RF, Gauss meters 8. Anomalous biofield decoherence detection 9. Non-thermal effects of non-ionizing radiation 10. Additional biofield monitoring survey system 11. Unique individualized assessment for all individuals 12. Anomalous body emissions by Cosmic Clarity Connections LLC 13. a – k. Millimeter and Terahertz waves create biofield decoherence 14. Anomalous body emissions by Cosmic Clarity Connections LLC 15. a – e. Deconstructive interference increases transmission proximity 16. Non-thermal effects of non-ionizing radiation 17. a – c. Cross functional team communication

The science shows that EMF's damage DNA. Children are at more of risk. They have these towers really close to schools which is insane. Protect our kids and the adults from over exposure. I'm a sensitive person and feel ill a lot now aways from it coming through my home. I leave and go where there isn't any EMPs form towers and I start feeling better.

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 parent, family member, caregiver, advocate, and concerned member of the public. I have been following the multitude of studies that are available since 2010 on the harmful effects of EMF on all biological life at the cellular level at levels FAR lower than SARS (the current heating effect measurements used). I am appalled at how the FCC has acted like a captured agency to the wireless industries it is trying to regulate. Please reevaluate the safety standards based on the, now, 20+ years of new studies/evidence!!

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…)WiFi, mobile phones, smart TV 3b. Nature, duration, frequency, and approximate timing (e.g., years):25+ years 3c. Adverse health effect(s) experienced:Fatigue, poor concentration, short term memory issues, general malaise and muscle weakness 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:~2012 with wireless router placed in house on desk in proximity to home computer. Yes, bio-effects immediately recognized. 3e. Was medical evaluation or treatment sought? (Optionally:) Was there a diagnosis?Yes. No EHS specialists in area, DX reduced to CFS/ME syndromes. 3f. Were steps taken to reduce or eliminate exposure, and were there subsequent changes in the effects?Yes, house subsequently wired for Ethernet, low power WiFi router installed and relocated to garage. All wireless transmitters, including Bluetooth/BLE, eliminated or controlled via breaker cut-off switches. 3g. Any supporting documentation? This includes Scientific Reports, exposure measurements, or other relevant information:Yes, See publications of Arthur Firstenberg, Ross Adey, Martin Pall, Leif Safford, Sharon Goldberg, etc. Additional Details you would like to share about your experiences of adverse health effects you believe to be associated with exposure to wireless radiation or EMF's:Interuption of Cellular Metabolism via generation of ROS, notable changes in VGCC's, alteration of mitochondrial electron transport chains, DNA damage and changes across multiple species as evidenced in mitosis and apoptosis. B1a. Sources you experience as causing you Adverse Effects:Proximity to WiFi routers, unshielded cell phones and unshielded house wiring (dirty electricity) B1b. Sources you can sense, but don't seem to harm you:Bluetooth/BLE B1c. Sources you can use without sensing or being harmed:Cell phones at over 4 feet B1d. Sources that seem to provide benefit (i.e., electrotherapy):Distance from sources, aggressive rest therapy, grounding and transport to new environments B2a. Health conditions you think may contribute to your sensitivity to EMFs including wireless:excessive fatigue, problems with short term memory and concentration, muscle and joint weakness. B2b. Health conditions you don't necessarily associate with your sensitivity to EMFs including wireless, but might be relevant:CFS/ME Lyme B3. For each subquestion please list up to 5 drugs or therapies or home remedies (if any) B3a. That you recommend, as they helped you tolerate or recover from EMF exposure:Sauna, outdoor walks, excessive rest B3b. That you recommend, but you’re not positive that they help:Diet B3c. That helped you but you don’t recommend. (e.g., the benefit did not last long or the side effects were too harmful):Most B3d. Treatments that had no effect:none B3e. Treatments that made your sensitivity worse:55-64 B4. What is your age range?55-64 B5. What year did you become aware of your sensitivity to wireless radiation or electromagnetic fields?1994 B6. What country, state, province, or major city were you living in when you first noticed your sensitivity to wireless or electromagnetic fields?New York City