Proposed biological mechanisms

This comment shares my perspective as a private citizen of the United States. I am a 37-year-old male. Below, I address questions 2, 3, 5, 6, 12, 13, 14, and 15 from the Request for Information. Exposure to Electromagnetic Fields (EMF), Radiofrequency (RF) radiation, and Wireless radiation is a major environmental contributor to my own illness: chronic, neurologic Lyme disease, tick-borne co-infections, and related autoimmune complications. When exposed to this radiation, I suffer fatigue, brain fog, headaches, vertigo, and exacerbation of underlying neurologic illness. I have been a patient of a practitioner of orthomolecular and environmental medicine for the past 17 years. My symptoms increase in severity the stronger the radiation, the closer the source, and the longer my time of exposure. Two hours of driving in a car on a highway past cell towers induces mild to moderate fatigue and brain fog. An entire day of exposure to WiFi at a home, school, or hotel induces moderate to severe headache, brain fog, fatigue, and vertigo. Repeated exposures day after day in a workplace eventually contributes to severe episodes of head pain, debilitating vertigo, vision disturbances, and loss of ability to think and speak. I have had to leave jobs due to this inability to function. In hindsight, this was also a reason why I had to take multiple medical leaves while attending college on a campus covered with 24/7 WiFi. My family and I have remediated our home environment from wireless radiation by hard-wiring all of our computers, telephones, and electronic devices. We disable all wireless capabilities and do not use any “smart” devices or appliances. I do not use a cell phone. I am able to stay healthy in this low-EMF environment, and in outdoor environments in my semi-rural town. I cannot function for prolonged periods in city or densely-populated suburban environments with high radiation levels. I do not think of myself as “electrically-sensitive,” but simply as a living being who is aware of the harm that EMF, RF, and Wireless radiation cause me. The harms of this radiation to all of life on Earth are well documented in the scientific literature. Arthur Firstenberg presents this evidence in his book "The Invisible Rainbow: A History of Electricity and Life". The presence of electrical, radio, satellite, and wireless infrastructure correlates strongly to the major diseases of modern man: cancer, heart disease, diabetes, and infectious disease. Man-made radiation inhibits the basic functioning of the cells of all living organisms, damaging their metabolism and ability to communicate properly. The result is confusion, disease, and death in humans, animals, and plants. The current regulatory standards and exposure limits regarding this radiation do not protect anyone. The Federal Communications Commission (FCC) is a captured agency, controlled by the telecommunications industry it is supposed to regulate. Through this agency and federal law which shields them from liability, telecom companies can build and deploy any technology that suits them, without threat of litigation for health and environmental harms. This state of affairs consolidates power and profit for a few giant corporations, while actually benefitting nobody. Our cell tower and wireless infrastructure is making us all sick, and we must acknowledge this damage and turn off these technologies. At the very least, individuals must have the freedom to opt out of smartphones, smart meters, and all other wireless technologies, and local communities must have the right to reject cell towers and antennas if they do not want them. Once we recognize the cost of unchecked wireless radiation throughout all of society, we can return to wired connections and encourage engineers and inventors to develop communication technologies that do no harm to living beings. We have many such technologies already, including pencil and paper! I encourage all at HHS to read "The Invisible Rainbow: A History of Electricity and Life" by Arthur Firstenberg (Chelsea Green Publishing, 2020), to read the scientific literature demonstrating the health harms of EMF, RF, and Wireless radiation, and to work with any and all parties willing to cooperate with the reduction and elimination of the technologies harming us all. For more information about the work of Arthur Firstenberg and his book "This Invisible Rainbow", visit the website of the Cellular Phone Task Force: https://www.cellphonetaskforce.international/ Thank you for this opportunity to comment on the harms of EMF, RF, and Wireless radiation exposure.

After suffering from a brain injury as flight crew in 2017 I began experiencing reactions around wireless technology. Since then it is impossible for me to leave my home without suffering from symptoms of migraine, vertigo, latent sleep disorder, and even at times seizures. Thankfully I can function on my own property without wi-fi as I was able to switch to wired internet. Sadly though, every year it seems the intensity of my neighbor’s wireless networks increases, causing me to suffer mild symptoms on a round the clock basis. If I am so affected by these frequencies, what might they be doing to the developing child’s brains or to our pets and wildlife? After deep diving into published research, it is clear that the literature shows wireless technologies are neurotoxic to biology via neurotransmitter changes and Voltage Gated Calcium Channel disfunction. With our current uptick in maladies such as cancers of all kinds, infertility, neurodegeneration, Cardiovascular Disease, ASD, Hoshimoto’s Thyroiditis, Type 2 Diabetes, and more, we should be asking why this is happening exponentially as we increase the rate of our wireless radiation exposures. At the very minimum, while we continue to perform long-term studies on the effects of non-ionizing radiation exposures on humans and the environment, I propose that we: .Re-introduce wired phone lines and ethernet connections in homes, businesses, and public places. . Require all wireless technologies sold in the US to have an “offline mode” which completely disables all wireless functions. . That all wireless functions of all devices be required to be in their offline mode at our schools, parks, public buildings, places of gathering, hospitals, public transportation, and the like. . That cell phone towers, power stations, and other facilities or antenna that emit ELF, EMF, or RF be required to be positioned a mile or more away from buildings, public spaces, and areas of residence OR require informed consent from all potentially affected parties as to the exposures and their unknown possible effects. . That public warnings be instituted regarding the possible harms of using wireless devices. . That manufacturers be held responsible for any adverse effects from their devices, products, or their infrastructure of wireless technologies.

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, as a person negatively affected by RF and a concerned member of the public. I am also an elected official for my small town. This last year I realized that I am negatively affected by RF and EMF. I had been sleeping for six year with a smart meter on the outside of our bedroom wall and though I am a very healthy individual, this has negatively affected my body. I can feel in my body when there is strong WIFI as it makes my body feel anxious and uncomfortable. My sleep is negatively affected by WIFI. I frequently have headaches when I go out in the public and am around strong WIFI. It takes me a couple of hours to recover. Places like Target are untenable with the strength of their WIFI. Air travel is very difficult. We had to sell our electric vehicle because it was negatively affecting my body. We have cut back on our WIFI at home and have put shielding between ourselves and our smart meter. I am trying to live wisely but still be part of our modern world but it is hard with all the increasing infrastructure. Even if we take measures at home, our neighbors do not which is discouraging. My children are exposed to wireless radiation all day while at school. They come home exhausted and have to spend the rest of the day recovering. Scientific studies have shown that wireless radiation is a toxin and causes oxidation on the cellular level. Many of my friends now have cancer and thyroid disease in their 40s. Their children have ADHD, autism and emotional problems and I believe it is because all of our bodies are being bombarded from RF and EMF everywhere we go. I am also concerned by the rise in Parkinson and dementia that I am seeing in our general population. Websites: https://doi.org/10.1590/2179-10742025v24i3288526 https://www.cureus.com/articles/66244-an-exploration-of-the-effects-of-radiofrequency-radiation-emitted-by-mobile-phones-and-extremely-low-frequency-radiation-on-thyroid-hormones-and-thyroid-gland-histopathology#!/ There should be laws against building homes and offices next to phone towers and phone towers being erected near schools. I support HHS taking an active role in examining the potential 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. I urge HHS to carefully evaluate these experiences and the scientific evidence, identify gaps in current research, give particular attention to children and other potentially vulnerable populations, and establish appropriate federal research priorities regarding wireless radiation and public health. The strength of a nation depends on its youth and having a healthy population and I believe our nation's strength and vitality is compromised by this hidden assault of EMF and RF. Thank you for providing individuals and families with an opportunity to be heard.

The key word in the RFI is the word “scientific”; it is repeated eleven time in different contexts as the main motive is to “Understand”; it is mentioned in the RFI: “At the same time, scientific literature is extensive, technically complex, and not always easy for policymakers or public health stakeholders to interpret.” This comment is from a care giver perspective; an independent healer offering services to Harmonize/Balance contaminated areas, places, devices (smart or not) with EMF and RF. The outcome of this so called (Harmonization/Balancing) is the disappearing or the dramatic improvement of the adverse health effects experienced by suffering people living in these places or using these devices. The approach used for Harmonization/Balancing is a "Holistic" approach, considered as Pseudoscience by the contemporary main scientific community, it is called (Physical Radiesthesia): a modality created by independent French researchers in the 1930’s, it works on the subtle effects/planes of the EMF, RF and the Human Subtle Energy Field, i.e. the physical measurements of EMF & RF rest unchanged after the Harmonization. The RFI is asking the following questions: 5.o. Is additional research needed to develop, test, and evaluate the effectiveness of procedures and techniques for minimizing exposure to electronic product radiation? Where are the largest gaps, if any, in knowledge? 16. What are the highest priority research gaps regarding EMF and RF radiation and public health that the federal health agencies should address? The answer is Yes, the gaps in knowledge is to embrace this different paradigm shift with an open and new mind; I personally have published scientific articles (in another field) in top peer reviewed journal in Physics, therefore “I have been there and actually I am still there in terms of awareness of the scientific rigorous process”; so, the scientific path of researching and publishing "shall" start shedding light on this modality (or other Holistic approaches) without prejudgment. On another note, the big challenge of the EMF & RF adverse health effects is that most of it are “subjective” in its core nature; the Physical symptoms (such as chronic fatigue, muscle aches, or digestive distress) are "invisible/intangible" by the standard medical tests as it shows no underlying organic disease or structural damage! The good news is that there a large similarity between the EMF & RF adverse health effects and Psychosomatic conditions that lack clear and tangible medical causes; so, we don’t have to start from scratch or to invent the wheel! The Standardized Questionnaires which are Medical approved tools like the Patient Health Questionnaire (PHQ-15) or the Screening for Somatic Symptom Disorders (SOMS-7) translate subjective physical complaints into quantifiable scientific data. (This was the answer of the question 8. from the RFI) 8. What, if any, improvements in exposure assessment methodologies are needed to better evaluate real-world exposure conditions? RFI is asking practical strategies to reduce unnecessary EMF and RF exposure where appropriate! But what if the "exposure" is not the problem per se, i.e. it is "not the physical/detectable components" of EMF and RF waves that cause the adverse health effects ?! What if that our scope/limits of contemporary scientific perspective is "limiting us" to see, study, analyze "other subtle component" of the EMF and RF waves, which is not detectable by our orthodox devices and Equipment ?! What if that there is other modality that can detect these adverse effects and transmute it into another quality that is positively resonating with living beings ?! In that context, this a formal invitation to policymakers or public health stakeholders for cooperation to apply the suggested protocol of Harmonization/Balancing for testing, evaluating its efficiency, strength, and eventually for approval as a big sector of the world population, with our contemporary highly intensive EMF & RF environment, is in real desperate need of this new paradigm shift.

Previous assessments of the health effects of EMF/RF have been based upon the assumption that non-ionizing and non-thermal radiation is not harmful to biological systems. This is a false assumption however. Allow me to quote Paul Héroux: "What escaped the attention of many is that life's metabolism and design make it much more vulnerable to NTER [non-thermal electromagnetic radiation] than inert matter. Living tissue has mostly adapted to the Sun's radiation as well as to the static field of the Earth only through the course of 3.5 billion years of evolution. ... But the levels of NTER from wireless techniques that we are experiencing now are totally unprecedented, and living systems have no defense against this new arrival." This is from his May 2025 Heliyon paper: "The collision between wireless and biology" https://www.cell.com/heliyon/fulltext/S2405-8440(25)00647-4 This diagram https://www.thelancet.com/cms/10.1016/S2542-5196(18)30221-3/asset/68f73d5d-0e58-49c6-af8f-99d0e7f7869d/main.assets/gr1_lrg.jpg from a 2018 Priyanka Bandaraa and David O Carpenter paper illustrates how unprecedented our exposures, particularly in the gigahertz range, have become. I am involved with South West Ohio for Responsible Technology (SWORT), which has been informing the public and elected officials about the hazards of 5G, smart meters, WiFi, and the like. We welcome HHS examining these technologies with greater detail, particularly focusing on the ill -or possibly beneficial- effects of certain frequency ranges upon biological systems.

I urge the Department of Health and Human Services (HHS) to independently review the scientific evidence on radiofrequency (RF) exposure from cell towers, particularly potential non-thermal effects, long-term exposure, and antenna placement near homes, bedrooms, schools, and childcare facilities. Documented premature tower activation Official City of San Mateo correspondence states that Crown Castle energized 19 wireless facilities before receiving required final city inspections and approvals. The City demanded de-energization and identified outstanding construction, electrical, permitting, and compliance issues. In subsequent correspondence following a June 26, 2024 meeting, Assistant City Attorney Linh P. Nguyen reported that only seven of the 19 sites had received final inspections and approval, two had been de-energized for necessary work, and 10 remained essentially unchanged. The City also discovered additional facilities energized without its knowledge, including one with an expired permit and no final inspection or approval. The City warned of further enforcement action. These letters document serious compliance and oversight concerns. While they do not establish health effects, they raise questions about transparency, enforcement, and public safety. Community reports and my experience During this period, members of our community group began reporting headaches, tinnitus, insomnia, anxiety, feeling unwell, and feeling unusually “off.” Some asked whether the towers had been activated. At the time, neither I nor the residents contacting us knew they were operating. After making inquiries, we learned of the City's findings regarding Crown Castle's premature activation of multiple facilities. I cannot prove that RF exposure caused these symptoms, but the timing and similarity of the reports warrant investigation. Around the same time, I developed severe insomnia for the first time in my life. Suddenly, I struggled to sleep, relied on sleep aids, and often awoke feeling unrefreshed. The timing was striking. I offer this experience not as proof of causation, but as a significant health change coinciding with the reported tower activation. I ask that it be considered alongside objective exposure measurements and scientific evidence. Request for scientific review I urge HHS to review the full scientific literature, including studies reporting effects, systematic reviews, and unresolved research questions. Please examine: * Sleep disruption, headaches, tinnitus, neurological function, cognition, and other reported symptoms. * Proposed non-thermal mechanisms, including oxidative stress and cellular signaling, and whether findings are reproducible at real-world exposure levels. * Long-term and cumulative exposure from multiple antennas and wireless sources. * Frequency, modulation, pulsing, duty cycle, beamforming, signal strength, and exposure duration. * Exposure in bedrooms, homes, schools, and childcare facilities, including overnight exposure and potential vulnerabilities of children. * Whether current standards adequately address real-world exposure and evolving scientific evidence. Compliance with outdated existing RF limits should not end scientific inquiry. Agencies should distinguish established adverse health effects from biological findings, plausible hypotheses, and unsupported claims. I respectfully request that the agencies: 1. Review the City's correspondence and examine premature operation before final inspections and approvals. 2. Support independent RF measurements near affected facilities, including in nearby homes, bedrooms, and schools where appropriate. 3. Commission independent research on non-thermal effects, sleep, neurological outcomes, and long-term exposure. 5. Establish appropriate ways to document community health reports and investigate exposure changes. 6. Evaluate reasonable exposure-reduction measures and alternative siting near homes 7. Clarify federal and local responsibilities for permitting, notification, compliance, and enforcement. Conclusion I am not asking agencies to presume that cell towers caused these symptoms. I am asking them to take documented regulatory failures, residents' experiences, and unresolved scientific questions seriously. The City's correspondence documents facilities energized before final approval and additional facilities reportedly activated without its knowledge. During the same general period, residents reported unusual symptoms and I experienced unprecedented insomnia. These circumstances warrant transparent investigation, reliable exposure measurements, and rigorous scientific review. Please evaluate whether current standards adequately reflect the evidence and take appropriate action to strengthen transparency, accountability, and public health protection. Thank you for considering my comment. Attachments: Official City of San Mateo correspondence regarding Crown Castle's premature activation and outstanding inspections and approvals.

This response addresses point 5 of the HHS remand in general, and 5.n in particular: “What scientific, technical, or regulatory changes by federal health agencies, if any, would improve the assessment, disclosure, and regulation of wireless radiation exposure.” Of particular concern are the assessments recommended by ICNIRP and IEEE ICES which underpin current exposure limits and will form the basis for future recommendations, as these assessments do not adequately meet reasonable scientific requirements, particularly when assessing studies investigating realistic RF-EMF exposures. Furthermore, these assessments apply requirements creating an in practice insurmountable evidentiary threshold before any non-thermal effect is given evidentiary weight, with serious consequences when setting exposure limits. This combination has so far produced conclusions of “no proof of risk”, which may be viewed as an artefact, i.e. produced by the assessments as such. Having studied this field for more than a decade, I have, together with scientific colleagues, developed a set of assessment criteria we consider necessary to improve the regulatory regime. These criteria aim to ensure that health risk assessments adequately consider studies investigating non-ionizing RF-EMF exposures below thermal levels, particularly under realistic exposure conditions, such as those encountered in everyday wireless communications. 1. Potential hazards and conclusions: Credible indications of potential harm must be identified and not disregarded due to a lack of full scientific certainty. All available evidence should be considered, and only excluded from the assessment based on scientific criteria such as serious flaws in the study design. 2. Distinguishing lack of evidence from evidence of no hazard: Insufficient evidence of harm must be distinguished from evidence that potential hazards are absent. 3. Transparent reporting: Evidentiary thresholds that reflect risk-management preferences must be explicitly identified. Risk-management preferences should not interfere with the risk-assessment. 4. Precautionary decisions: Credible indications of potential harm must be clearly reported, even when causation remains uncertain, to provide a scientific basis for considering preventive measures and their ethical, economic, and legal implications. 5. Exposure relevance and evidentiary weight: The relevance of the exposure characteristics to the target exposure scenario must be considered when assigning evidentiary weight to study findings, including findings of no effect. 6. Interpretation of exposure metrics: When assessing dose-response relationships, replication, and consistency across studies, the similarity of exposures must be evaluated using biologically relevant exposure characteristics, rather than assuming that similarity in a single exposure metric establishes biological equivalence. 7. Control-group exposure contrast: For hazard identification, exact dosimetry is not required, provided that it is reliably demonstrated that the exposed group is substantially more exposed than the control group. The exposure contrast must be sufficiently large and well characterized to support a meaningful comparison and minimize exposure misclassification. Assessments underlying the exposure limits recommended by ICNIRP and IEEE ICES do not fulfill these requirements, especially as to their handling of scientific uncertainty and the evidentiary weight they assign to studies investigating realistic RF/EMF exposures, while systematically assigning most evidentiary weight to studies with unrealistic exposures. Such methodological concerns also apply to other RF/EMF assessments based on ICNIRP and ICES theoretical foundations and methodologies, e.g. the European Commission's SCHEER opinion on RF/EMF health risks and the WHO systematic reviews prepared for its RF/EMF Environmental Health Criteria monograph. I recommend that HHS evaluate all scientific assessments intended to inform RF/EMF risk-management decisions against the proposed criteria before relying on their conclusions. The attached document, authored by five researchers who have studied and published scientific papers and books on the foundations of the current regulatory regime, provides the detailed reasoning behind these recommendations. It also forward references to methodologies suitable for assessing RF-EMF effects on human health in ways consistent with standard risk assessments for potentially toxic agents, as well as scientific literature establishing the scientific rationale for the proposed criteria. Else K. Nordhagen, Ph.D., Univ.of Oslo, Norway

THE GOVT. AND THE CELLULAR COMPANIES PROFITEERING FROM THE ADVERSE HEALTH IMPACTS OF CELLULAR TECHNOLOGY ARE WELL AWARE OF THE DANGEROUS NATURE OF MICROWAVE TECHNOLOGY FOR HUMAN AS WELL AS ALL BIOLOGICAL HEALTH. THIS IS WHY IT IS BEING USED AS A WEAPON OF SILENT DEATH BY THE MILITARY INDUSTRIAL COMPLEX. WE LEARNED IN SCHOOL THAT THE MICROWAVE RADIATION CAUSES NON IONIZING DAMAGE TO ALL CELLS, AND DNA..HOW CAN IT BE "SAFE". HOW STUPID DOES THE GOVT THINK WE ARE???

Thank you to HHS for examining this urgent issue. I am commenting as someone who has studied the cautioning peer-reviewed research meticulously for many years. I know a growing range of individuals who are functionally disabled by rising wireless radiation pollution with far-reaching negative impacts on their lives, including loss of access to everyday services plus deepening social isolation. I too have experienced some deleterious health effects personally from exposure, including two years of extreme sleep starvation that was unresponsive to all measures other than eventual wireless radiation mitigation when, after the two years, I discovered from records and measurements that (i) symptom onset had coincided with simultaneous wireless makeovers at work and home, and additionally (ii) the highest level of cell-tower (mast) radiation in our home was in our main bedroom, precisely over my pillow. I continue to be prone to dizzy headaches, loss of cognition, and sleep impairment from wireless-radiation pollution. Life impacts have included loss of work, having to move house, and difficulty accessing shops, events, social groups, and medical services: typically, for example, I have to wait outside clinics rather than in waiting rooms and sometimes have to leave appointments early; I am similarly unable to linger in shops, social spaces, or public transport crowded with smartphones and/or WiFi or DECT transmitters. I suspect that those who have uncovered their relative sensitivity to the growing pollution are but the “tip if the iceberg” and that, as with all environmental toxins, there is a bell-curve of impairment across the wider populace with more individuals losing quality of life as the pollution intensifies. As you examine peer-reviewed evidence of harm, notice oxidative / nitrosative damage to cells and tissue – a frequent finding and risk factor for degenerative diseases – and also that the pulsed, polarized, variable nature of wireless outputs adds to their biological effects (Panagopoulos et al)1. Remember that the (outdated) “safety standards” normally refer to single-source exposures and that the young, sick, pregnant, or elderly, and other vulnerable groups, are now besieged on all sides. Less toxic technologies using, for example, state-of-the-art cable and (subject to biological safety testing) modulated light offer inspiring ways forward but humankind is tragically mired in outdated paradigms and addictions that are driving up the pollution while divorcing us from the unmediated beauty of the non-virtual world, at profound cost to body and soul – Lynne W. 1: see Panagopoulos, D. J., ed., Electromagnetic Fields of Wireless Communications: Biological and Health Effects, Routledge 2023 - an excellent reference work

I am a 64-year-old man whose family owns a vacation home in Hillman Township, Michigan. A cell tower developer is seeking to construct a massive telecommunications tower just feet from my property. Like others who live nearby, we purchased and maintained this home to enjoy peace, privacy, and the natural environment -- not to face the prospect of significant, long-term exposure to high levels of wireless radiation emissions. This is not a matter of NIMBY-ism. This is a matter of public health and the responsible, thoughtful sitting of powerful industrial equipment. I urge HHS to prioritize research into the biological mechanisms of harm. Federal research should investigate the effects of RF radiation on cellular signaling, oxidative stress, DNA damage and repair, neurological function, and reproductive and developmental health. HHS should fund independent, replicated laboratory studies, long-term animal research, and prospective human studies examining chronic and cumulative exposure, including levels below current federal limits. Research should also examine particularly vulnerable populations, including children, pregnant women, and older adults. According to the International Agency for Research on Cancer's 2013 Monograph Report on Non-Ionizing Radiation, children absorb up to ten times more wireless radiation in the bone marrow of the skull compared to adults due to their thinner skulls, smaller heads, and higher brain conductivity. I urge HHS to recommend that the Federal Communications Commission (FCC) reassesses and lowers its existing RF exposure limits. Current RF exposure limits are so permissive that they’re essentially the equivalent of a 500-mph speed limit. No wonder people are getting sick! The FCC must reconsider the Specific Anthropomorphic Mannequin (SAM) model used to assess cell phone RF exposure. SAM is based on a simplified model of a standardized adult head and was developed to assess localized RF energy absorption under specified testing conditions. It does not adequately represent the full range of human anatomy, including children, differences in head and body size, or the complexity of real-world phone use and exposure. A compliance test based on a standardized model cannot, by itself, establish that all users are adequately protected under all realistic conditions. HHS should encourage independent evaluation of SAM's limitations and support improved testing methods that better reflect diverse users, realistic usage patterns, and modern wireless devices. I am not opposed to telecommunications technology. I am asking that public health receive the same serious consideration as infrastructure expansion. I respectfully urge HHS to lead a coordinated federal research effort, further investigate the biological mechanisms of RF-related harms, recommend stronger FCC exposure limits, and support more scientifically representative cell phone testing methods. Americans deserve nothing less. Thank you for your consideration of my comment. Respectfully submitted, Chris Caswell