Research & federal duties

To: Federal Communications Commission (FCC) Department of Health and Human Services (HHS) / Food and Drug Administration (FDA) Subject: Public Comment Regarding Outdated RF Radiation Exposure Limits, Multi-Device Realities, and Implementation of the EHT v. FCC Court Mandate To Whom It May Concern: I am submitting this comment to formally urge the Federal Communications Commission (FCC) and the Department of Health and Human Services (HHS) to update the United States exposure limits for radiofrequency (RF) electromagnetic fields. The current federal exposure limits were adopted in 1996 and remain rooted in an obsolete thermal model that presumes biological harm occurs only if tissue is acutely heated. In 1996, mobile phones were utilized sporadically and held away from continuous bodily contact. Today, wireless exposure is near-constant, multi-source, and delivered directly against human skin across an expansive ecosystem of personal and commercial devices: 1. Continuous Contact and Body-Worn Devices: The 1996 standards never envisioned hardware engineered to operate in direct, uninterrupted contact with the human body for 16 to 24 hours a day. Millions of Americans now continuously wear smartwatches, fitness trackers, and connected rings, alongside direct-in-ear transmitters like Bluetooth earbuds and wireless headsets. Testing standards based on short-duration, separated-distance models fail to reflect the cumulative biological load of these skin-contact technologies. 2. Dense Multi-Source Living and Work Environments: Current Specific Absorption Rate (SAR) evaluations assess a single isolated device. However, daily environments subject individuals to simultaneous, overlapping fields from: Mobile hardware: High-powered smartphones running simultaneous cellular (5G/4G LTE), Wi-Fi, and Bluetooth radios, frequently carried directly in pants or jacket pockets. Portable computing: Wi-Fi- and cellular-enabled tablets, laptops, and e-readers resting directly on laps or near vital organs during work and education. Household and municipal infrastructure: High-output Wi-Fi 6/7 mesh routers, smart electric and water utility meters, smart TVs, voice-assistant smart speakers, and automated home security hubs broadcasting continuous beacon signals. 3. Non-Thermal and Chronic Low-Level Biological Effects: The assumption that only thermal burns or acute heating warrant safety margins is contradicted by substantial independent, peer-reviewed scientific literature—including research from the National Toxicology Program (NTP). Studies demonstrate cellular oxidative stress, metabolic disruption, and potential neurological impacts from persistent low-level pulsed fields, even when temperatures remain unchanged. 4. Failure to Protect Developing Neurological Systems: Standardized plastic mannequins modeled after adult male dimensions do not account for children or adolescents. Thinner cranial bones, greater fluid conductivity, and smaller body mass mean modern wireless tablets, educational laptops, and phones deliver higher relative doses to children’s developing nervous systems. 5. Mandated Compliance with EHT v. FCC: In Environmental Health Trust, et al. v. FCC (11 F.4th 912, D.C. Cir. 2021), the U.S. Court of Appeals for the D.C. Circuit ruled that the FCC acted arbitrarily and capriciously by terminating its inquiry into its 1996 limits without providing a reasoned explanation regarding non-cancer harms, chronic exposures, and modern children's usage. The FCC, in coordination with HHS and the FDA, must fulfill this legal remand through a transparent, science-based review rather than maintaining reliance on a 30-year-old framework. The federal government must align its regulations with today's multi-device, body-worn reality by updating RF exposure limits to account for continuous, non-thermal, cumulative exposures. Respectfully submitted, Mark Kuether Oostburg WI 53070

This is a second person account, but the person in reference is dead so he cannot speak for himself. I and concerned neighbors picketed a church for two years, because of a proposed cell tower on church property, that would materially impact our neighborhood because of it close proximity to our homes. One Sunday morning Jerry, a local coach and teacher approx 50 years old (and his 12 year old son) approached me on the the picket line and asked me if I felt the WIFI in his classroom and the headset and phone he constantly had next to his head when coaching could have caused the Gioblastoma he had in his brain. I was not versed in what teachers are subject to in our district, nor did I know enough to give Jerry any kind of appropriate answer, I gave Jerry some websites to go to and felt badly that I at the time was not educated enough to give Jerry some answers. He was concerned that the WIFI and Headset and close phone usage may have caused this. Jerry Died in 2024 of geoblastoma at the age of 50 leaving a young family. I am no expert, but is a teacher standing between the WIFI and 25 laptops and probably 25 phones eminating signal a problem. That is something teachers should be concerned about. I knew nothing about this in 2022. Jerry is prematurely dead, when are we going to start really looking at this. A data base of to be able to see these complaints and possible causes would be a great tool and a great start to pinpointing world wide proximitey, assumed cause, outcome. It sickens me to see the Jerry's of the world simply forgotten for something no one told them was a concern.

I am writing to formally request your attention, oversight, and investigation into grave concerns regarding health, human rights, physical safety, and bodily autonomy in Puerto Rico. A growing number of individuals on the island identify as "Targeted Individuals" (TIs). They report experiencing severe, chronic physiological and psychological distress that they attribute to non-consensual exposure to high-power electromagnetic radiation (EMR), radiofrequency (RF) fields, or directed energy technologies.  Historically, Puerto Rico has been the site of extensive military testing, radar installations, and scientific experiments. This legacy has left a deep-seated vulnerability and distrust among local communities regarding environmental and technological safety. Individuals reporting these experiences frequently describe symptoms such as intense neurological disruption, chronic sleep deprivation, severe headaches, internal vibrations, burns, and cognitive impairments, among other concerns. These symptoms severely degrade their health/quality of life, economic stability, and overall well-being.  I'm part of this growing number of individuals and a victim of this ilegal experimentation. The United Nations Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment—to which the United States is a signatory—strictly prohibits any form of non-consensual experimentation or physical and psychological abuse. When citizens report targeted harassment or physical distress linked to electromagnetic energy, it is imperative that public health and human rights officials take these concerns seriously rather than dismissing them. To address these compounding concerns and ensure the protection of all residents, I respectfully urge your office to take the following actions: Establish Independent Monitoring: Conduct transparent, independent environmental testing of electromagnetic and radiofrequency levels in residential areas, particularly near major technological or industrial installations. Create Formal Reporting Channels: Provide a safe, transparent, and objective framework for citizens to report symptoms, unusual environmental readings, or concerns regarding non-consensual technological exposure without fear of marginalization. Ensure Legal and Medical Oversight: Enforce strict compliance with international human rights standards regarding informed consent, ensuring that medical professionals are equipped to objectively assess and document environmental health complaints. Thank you for your time, consideration, and dedication to upholding human rights, public health, and civil liberties for the people of Puerto Rico. I look forward to your prompt response detailing the steps your office will take to investigate these matters. uesadaphd ________________________________________

I am deeply concerned about the potential long-term health effects of electromagnetic fields (EMFs), radiofrequency (RF) radiation, and the increasing amount of wireless radiation exposure in our everyday environments. As a mother, I am particularly concerned about the cumulative exposure our children experience from an early age through cell phones, Wi-Fi, tablets, wireless devices, and technology in schools and homes. Children are growing up in environments where wireless technology is nearly constant, yet important questions remain about the effects of lifelong exposure. I recognize that current scientific evidence has not established that everyday wireless exposure within existing safety limits causes adverse health effects. However, I believe the remaining scientific uncertainties deserve continued independent investigation, particularly regarding long-term exposure, developing children, pregnancy, sleep, neurological health, and reproductive health. I am also concerned about whether current safety standards adequately reflect modern exposure patterns. People are no longer exposed to just one wireless device at a time. Many of us live and work surrounded by multiple sources of radiofrequency emissions throughout the day. I would like to see more research examining realistic, combined, and prolonged exposure rather than relying solely on short-term assessments. I strongly encourage federal agencies to prioritize transparent, independent, peer-reviewed research, including studies that examine potential effects beyond tissue heating. Research should also consider vulnerable populations and clearly communicate both established findings and areas where evidence remains inconclusive. I believe families deserve accurate information, meaningful choices, and practical ways to reduce unnecessary exposure without fear-based messaging or having to give up essential technology. My request is for greater transparency, stronger long-term research, ongoing evaluation of safety standards, and a precautionary approach where scientific uncertainty remains. Protecting public health, especially the health of future generations, should remain a priority as wireless technology continues to expand.

https://pmc.ncbi.nlm.nih.gov/articles/PMC6435572/ "The Relationship Between Parental Attachment and Mobile Phone Dependence Among Chinese Rural Adolescents: The Role of Alexithymia and Mindfulness" "Mobile phone has experienced a significant increase in popularity among adolescents in recent years. Findings indicate dependence on mobile phone is related to poor parent-child relationship. However, previous research on mobile phone dependence (MPD) is scant and mainly focus on adult samples. In this view, the present study investigated the association between parental attachment and MPD as well as its influence mechanism, in sample of adolescents in rural China. Data were collected from three middle schools in rural areas of Jiangxi and Hubei Province (N = 693, 46.46% female, Mage = 14.88, SD = 1.77). Participants completed the Inventory of Parent and Peer Attachment (IPPA), the twenty-item Toronto alexithymia scale (TAS-20), the Mindful Attention Awareness Scale (MAAS) and the Mobile Phone Addiction Index Scale (MPAI). Among the results, parental attachment negatively predicted MPD and alexithymia were exerting partial mediation effect between parental attachment and MPD. Further, mindfulness acted as moderator of the relationship between alexithymia and MPD: The negative impact of alexithymia on MPD was weakened under the condition of high level of mindfulness. Knowledge of this mechanism could be useful for understanding adolescents’ MPD in terms of the interaction of multiple factors."

About 12 years ago I attended a city council meeting in San Marino, CA, where parents were hoping to get a cell phone tower removed from the playground at their children’s school. I was appalled to learn that the parents could be sued if they expressed any concern that the tower might in some way impair their children’s health. So all they could do was talk about their fear that it could burn, or fall over, or that it looked unsightly, etc. Of course, the tower stayed. This is all you really need to know to realize that those who make and enforce our government's regulations have turned a blind eye to the real probability that our health and the health of plants and animals is likely harmed by some of these increasingly ubiquitous RF/EMF fields. One cannot even ask the question! After learning that I could be sued by the powerful communications industry for expressing concern that cell towers could cause health effects, I tried calling the FCC to ask how they came to the conclusion that RF and microwaves radiating at people were safe. I couldn’t reach a single human being to speak with until I finally selected the choice in the FCC phone menu for those who wanted to buy spectrum. After making this selection, I immediately got an engineer on the line. I explained why I was calling, that I was not buying spectrum but was a concerned citizen, and asked about what research the FCC used to establish safety standards. He told me he felt badly, that likely we needed to study the problem more but it was out of his hands. He told me that there was a group from whom the FCC got their reports on RF and microwave safety. I looked at the website he had mentioned. It described a small firm of 5 women whose mandate was to produce reports which interpreted complex data in their clients’ strategic interests. Wow. We were being sold a bill of goods. I tried to interest people at Caltech, where I was working, in this problem. I was told by my PI in no uncertain terms that if I took any measurements with an RF meter or EMF meter I would not be able to work in the HIV research lab anymore. I was told people would be upset and I must not bring “that device” (a simple cheap Trifield meter) to work ever again. I was later fired for specious reasons, and banned from talking to anyone in the lab. This felt really creepy. It was quite an education. I became more interested in the problem. The more I learned the more appalled I became. I appreciate the opportunity to comment. It is not my job to teach you, dear FCC, what you already know: there is something potentially harmful in these energies, else why can we not ask the question at city hall about whether these cell towers on the playground could be harming our kids? You at the FCC already know that you have been encouraging the rapid spread of this powerful addictive technology at the cost of our health and possibly even our climate. You know that in spite of efforts made by you and others to thwart studying this problem, data exists which casts doubt on microwave safety. Why are there articles entitled "The effect of trees on 5G" instead of articles entitled “The effect of 5G on trees"? At Caltech, before the Covid lockdown, I sat in on a bunch of lectures being given by the sustainability people. No one had incorporated the rapid increase in microwaves in our world in their models of our rapidly warming world. I see evidence around me that cell towers harm and kill trees, and likely, dry the soil, start fires, who knows what. The plethora of satellites that measure the ice depth at the poles shine microwaves in and measure what comes back. The difference apparently tells how thick the ice is. But is this a good thing to do? Could the small amount of microwave energy absorbed by the ice be softening the ice’s surface, changing its albedo, causing more of the sun's energy to be absorbed rather than reflected, leading to further ice melt? Are we in a way opening the oven to make sure the cake hasn't fallen yet when we make these measurements? We need to do better. We need a consortium of biologists, physicists, climate scientists, and engineers who are not influenced by profit or lucrative data collection schemes to work together to understand the impact of these energies (with which we did not co-evolve) on our health and on the health of our living world. Thank you for your time.

I am submitting this comment as a consumer concerned about long-term exposure to wireless radiation from phones, Wi-Fi routers, cell towers, and other connected devices. I urge HHS to conduct a thorough, independent review of whether current exposure limits adequately protect public health. This review needs to consider those most heavily exposed and should examine potential effects beyond tissue heating, including evidence concerning cancer, reproductive health, and children’s development. Please prioritize research that reflects how people actually encounter wireless radiation: repeated exposure over many years, often from multiple sources and devices used close to the body. Assessments should consider signal strength, pulse patterns, duration, and combined exposure. Please consider Melnick and Moskowitz’s 2026 analysis of animal data, which argues that existing exposure limits may inadequately protect against cancer and reproductive harm (https://doi.org/10.1186/s12940-026-01288-6). I also ask HHS to evaluate Lai and Levitt’s review of exposure intensity, duration, and signal modulation (https://doi.org/10.1080/15368378.2022.2065683), and Scarato’s review of US regulatory gaps and proposed reforms (https://doi.org/10.3389/fpubh.2025.1677583). These papers warrant careful consideration alongside the broader evidence, including studies that have not found adverse effects. I ask HHS to: •Assess whether additional protections are needed for children, pregnant women, and other potentially vulnerable groups. •Support long-term research with safeguards against industry conflicts of interest. •Provide clear information about exposure and practical ways to reduce it, including wired alternatives in homes and schools. •Recommend updated standards wherever the evidence shows that existing limits are insufficient. Consumers should not have to navigate these questions alone. Please use this inquiry to advance transparent science, meaningful oversight, and public health protection.

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 [patient, parent, family member, caregiver, healthcare professional, researcher, advocate, concerned member of the public, or other]. Wireless radiation has affected my family significantly. The continuous wireless exposure has affected our ability to sleep at night. The only way we can get any real rest if to turn off all wireless transmitters and all the electricity in the sleeping room. The source and duration of the exposure, health effects such as sleeplessness, anxiousness and depression are experienced unless the above actions are taken place. The nearby cell towers producing RF and EMF can only be minimized by distance, and we specifically selected our location to stay away from these towers. Why when a new high school was built in our area was a new cell tower immediately constructed almost on top of the school when science has already proven that these tower affect the human physiology dramatically. We fully support those organizations that represent the public in regards to these harms being put on every human being for the "benefit" of the cell tower providers making a profit. Finally we will have to move out of the local area to a space that has no or minimal cell towers in order to maintain our health. HHS MUST conduct a real investigation into the harms caused by these emitters of EMF and RF, and also examine the thousands of already produced scientific reports that have identified these threats to humans. They can't be ignored any longer. EMF and RF exposure is clearly harmful and there is not two ways about it. For the sake of humanity, do something!!! 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. Thank you for providing individuals and families with an opportunity to be heard.

Public discussion of RF/EMF still centers almost exclusively on thermal/heating effects and “no proven harm at current levels.” This ignores decades of official U.S. patents and military analyses that describe remote sensing, modulation, and alteration of human brain activity via electromagnetic means. These are not fringe claims—they are government-granted patents and open-source military work. Key examples: - **U.S. Patent 3,951,134** (filed 5 Aug 1974, issued 20 Apr 1976, Robert G. Malech / Dorne & Margolin): “Apparatus and method for remotely monitoring and altering brain waves.” It describes transmitting RF signals that interfere in the brain, producing a waveform modulated by the subject’s own brain activity. That signal is received, demodulated, analyzed, and a compensating signal can be sent back “to effect a desired change in electrical activity therein.” - **U.S. Patent 7,051,636 B1** (filed 21 Sep 2004, issued 30 May 2006, Snow et al. / U.S. Navy): “Electromagnetic weapon.” Semi-random antenna elements form an active phased array controlled by a central computer, capable of finding and exciting a resonant mode of a target with enough energy to disable it. - **U.S. Patent App. US 2013/0194092 A1** (filed 27 Jan 2012, published 1 Aug 2013, Moriarty et al. / Qualcomm): “Unlocking a Body Area Network.” Describes body-area networks with sensors for EEG, ECG, blood pressure, glucose, toxins, and implants, controlled wirelessly and able to transmit physiological data. - Naval Postgraduate School thesis **“Neurowar Is Here!”** (Gramm & Branagan, Dec 2021, public release): Argues neurowarfare—targeting and weaponizing the human brain—is already underway, linking Havana Syndrome-type incidents and the biotechnological focus on the nervous system. These documents establish that the technical capability has been formally recognized for decades. Current regulatory frameworks that treat RF solely through thermal SAR limits are incomplete if non-thermal modulation, resonant targeting, or closed-loop neural feedback capabilities exist in the patent and military literature. **Systemic level:** Independent research into long-term, low-level, pulsed, and information-bearing RF exposures is needed. Dual-use research transparency should be required. Impact assessments for dense wireless infrastructure (including 5G beamforming and body-area networks) must include neurological and cognitive endpoints, not only heating or cancer metrics. **Individual level:** People reporting unexplained neurological symptoms, sleep disruption, or cognitive changes currently lack accepted diagnostic pathways or protective options. Practical measures that should be studied include better personal exposure tools, accessible shielding, medical protocols that take non-thermal effects seriously, and informed-consent/opt-out mechanisms for dense infrastructure and implantable systems. The patents and the NPS thesis are public record. Pretending the technical possibility does not exist, or that only thermal effects matter, is no longer scientifically or ethically defensible. This RFI must address both the documented capabilities and the gap between those capabilities and current public-health frameworks—for populations and for affected individuals. Thank you for looking into this.

I am writing as a mother and caregiver in response to this Request for Information. My son is seven months old, and like many parents I make dozens of small decisions every day about the environment he grows up in — including his exposure to wireless radiation. In our home we have taken simple precautionary steps: we keep phones off and away from our bodies, we use air-tube headphones instead of holding a transmitting phone to the head, our e-reader stays in airplane mode, and wireless devices stay out of the rooms where our baby sleeps. I have also looked into EMF-shielding textiles for his sleeping area. I am not a scientist, and I don't claim certainty about specific harms. But the existing exposure standards were designed around adults, and I have not seen clear, modern guidance that accounts for infants and small children — smaller bodies, developing brains, and decades more lifetime exposure ahead of them. That gap is exactly why I am writing. I ask HHS to: (1) develop child-specific, precautionary guidance for families; (2) fund independent research on RF exposure in infants and children; and (3) make the evidence behind any updated standards public and understandable to non-specialists. Thank you for inviting the voices of families and caregivers into this process.