Exposure limits & oversight

Re: HHS-OASH-2026-0397, Request for Information on EMFs, RF Radiation, and Wireless Radiation Exposure Thank you for asking. Federal RF exposure limits date to 1996, and in 2021 the D.C. Circuit found the FCC had not adequately explained why it kept them. Since then wireless has moved from 3G to 4G to 5G, with 6G planned around 2030: more antennas, closer together, more of the time. It doesn't stop. HHS should give the public, and the FCC, a real health record to work from. 1. Update the limits on modern science. Revisit the 1996 limits using current research, with special attention to children and long-term, close-to-body exposure. HHS should lead the health review and hand the FCC a record that answers the court. 2. Take public reports seriously. Many Americans report real symptoms they connect to wireless exposure. Their experiences should not be dismissed simply because no one has funded a peer-reviewed study to examine them. Absence of funded research is not evidence of safety. HHS should collect these reports systematically and fund independent studies, free of industry money, designed to test them. 3. Review each generation before and after rollout. Every new wireless generation should get an exposure assessment before broad deployment and ongoing monitoring afterward, rather than riding on decades-old assumptions. As another commenter noted, most instruments were built to check heating limits, not to record everyday exposure continuously. HHS should fund continuous, real-world measurement where people live, work, and sleep. 4. Set device efficiency standards. For most people the closest source is their own phone. Push for standards that make phones and wearables connect at lower transmit power, whether to towers or satellites, and publish real-world exposure data for each model. 5. Study satellite connectivity as a lower-exposure path. Satellites with large antenna arrays, paired with more efficient phones, could cover rural and remote America with fewer towers near homes and schools. HHS should study this side by side with dense 5G and 6G networks, including the higher power phones may use to reach orbit, and communities should be able to choose it where it works. 6. Health comes first. More connectivity is not automatically progress. Faster video is not what stands between Americans and abundance; affordable energy, medicine, and housing are. Each new generation should show it is needed and safe before it is built into every neighborhood, and the burden of proof belongs on the deployers, not on families. Please publish the underlying data and keep the review independent. Alec Snelling California This comment was crafted with super intelligence (SI) support.

I've suffered from Seizures almost all my life, and its stolen near everything from me, agitated by EMFs and RFs and Dirty Electricity. It wasn't until I was 28 after seeing world renown specialist from across the globe that I on my own tried EMF reduction tactics like filtering powerlines, shielding wireless, using grounded devices and hardline connections that I recovered enough to walk and have my eyesight repair, migraines that never ended recovered. I'm the canary in the coal mine growing up in southern CA and later near Scilicon valley since my pre-teen years of age in the late 90s into the 00s. We'll all suffer more and more as signals add up and pollute each other. We need to use software on wireless that puts the device when not in use like the JSR-eco Router, saving our cyber security and electricity as well as our bodies. Education in this field will spur on not only engineering but biological intelligence in the coming generations too, demystifying this technology through its physical and biological interactions. It took almost a decade to repair my lifetime of nerve damage to the extent I have which isn't total, but 7 seizures a week is much more than now 2-3 a year. I remained HYPER sensitive to foods and wireless radiation swelling and having radical inflammation so great I can have a seizure or not process food the next few days, small scale seizures for a few days that burn and hurt and make it dangerous just to stand and go to the bathroom are then common after being on a train or near a cell tower too long. Please consider Xemes coating on the towers that exist and angle them up away from residential zones, school, hospital, ect. just like radio and airplane tower signals are supposed to be. I have an IQ tested by Sandford of 138-147 and studed neurology and computer science, I was an olympic level swimmer too, now i'm and unemployed cripple and try everywhere I go to help those I see with mounting symptoms and they're getting worse. Powerlines aren't being well maintained and conduict standards are being lowered to pvc instead of steel, most houses I've lived in I've called power companies and they find the power pole to not even have a grounding wire in the conduit tube it having rotted away long ago. The telecom companies would jump at a chance to market "a radiation safe company" if you set standards like the organic food crazy, try using that on them. Titanium with Vanadium should be used on and with cases for wireless like routers/modems, and reinvesting in this with our new steel systems would be a great boon in modernizing tech while creating potent economic opportunitiesa, longer lasting too. Please do what you can, the pain is never ending. God Bless

My name is Sarah Aminoff, and I am a member of Safe Tech International, and a San Francisco, California educator. San Francisco has been a key test ground for driverless robotaxis, and being part of that experiment was not what I was thinking during student field trips to Golden Gate park. People are able to opt out of TSA Airport Scanners due to cumulative radiation concerns, but not Waymo robot taxi exposures, yet both use millimeter frequencies. Since 2024 onwards, it has been hard to reduce exposure to Waymo, given California Public Utilities Commission has also approved expansion. Waymo Robotaxis send out millions of radar sensors to create a 3D picture, using millions of radar millimeter sensors or laser pulses that impinge on an automobile or pedestrian and its a complex EMF soup. The Robocars use three primary sensors: cameras, LIDAR and radar. Radar uses millimeter wave frequencies to provide Waymo with crucial details like an object's distance and speed. LiDAR uses laser beams to create dense, accurate 3D maps. The Waymo 5th Generation, has 29 cameras, six radar sensors tracking larger objects and four LiDAR sensors, which use laser pulses to "see" the car's surroundings in 3D. To answer HSS question 5n and 8  The FCC still fails to capture ubiquitous and aggregate exposures. An aggregate signal analysis has yet to be done for driverless vehicles. Most of the compliance with federal standards are typically claimed for only one set of lights or emitters, as the FCC regulates RFR and Millimeter, yet on the Waymo 5th Generation there are 51 sensors. Time averaging dosimetry should not be permitted, especially for mmWaves and RF, as peak exposures that fall within FCC limits when time averaged over 30 minutes, can have serious non-thermal bioeffects at a cellular level potentially inducing reactive oxygen species and DNA, and sperm damage, according to International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF). With driverless vehicles, radiofrequency radiation (RF) in the MMWave part of the spectrum and near IR poses possible deep thermal heating effects, yet the FCC relies on 30 minute dosimetry, averaging in peak exposures. Environmental Health Trust shares science research around the millimeter frequency concerns, including:  “A 2021 paper “Millimeter (MM) wave and microwave frequency radiation produce deeply penetrating effects: the biology and the physics” by Martin L Pall PHD reviews the science on how MMwaves can have highly penetrating effects  stating that “in humans, MM-waves have penetrating effects including impacts on the brain, producing EEG changes and other neurological, neuropsychiatric changes, increases in apparent electromagnetic hypersensitivity and produce changes on ulcers and cardiac activity”   To answer Question 5 The FCC assessing for one vehicle only, not multiple car exposures is a gap in knowledge. According to Ron Kostoff in his article on radar and cars, ‘If you’re walking on a crosswalk in front of stopped traffic, you….could be exposed directly full body to a million microwatts/square meter.  And, there’s no glass or metal to absorb or block the radiation.  And, that’s with the assumption that you’re being radiated from one car only….what we really need to get are the codes the auto manufacturers use to compute actual radar exposures to car occupants and pedestrians. If some of the radars are mounted on the front bumper, then small children walking a crosswalk are most vulnerable. “ Time Averaging in Evaluating Dosimetry Levels in Smart Vehicles by the FCC is an inherent flaw. Technologies get approved without sufficient pre-market testing is another gap, see John P. Thomas’ article, Health Impact News “Will Driverless Cars Cause DNA Damage and Cancer? April 15, 2018.”   We need to know Waymo will tag a pedestrian as an ‘object detected” with a velocity vector as a moving target and an obstacle to avoid. People are being mapped with radar, lidar, ultrasonic signals and were also captured on optical cameras that use IR and LED beam lights. The LiDAR, Radar and Camera sensors can detect images from hundreds of meters. These are artificial exposures targeting every square centimeter of the body. Many autonomous vehicle incident were reported to: Block traffic Trap cars at the curb Enter construction zones Enter crime scenes, fail to follow directions Hit a cat and dog, also child Get in the way of emergency vehicles And yet, state and federal agencies allow children to ride in robot taxis (Waymo with adult supervision, or parental consent) while the FCC and agencies fail to include children’s unique biology in guidelines. Driverless vehicles have multiple sensors, when children are exposed to Waymo et al, e.g. idling outside schools. A new study from Europe found children have higher RF absorption rates than adults.

Thank you for this opportunity to share the public concerns with exposure to RF 's. I personally have fought in a local level to stop the installation of a verizon tower within 500 feet of our property line to no avail, the concerns about these towers in close proximity to homes is very real for my neighborhood. Putting the pressure on local counties to regulate these telecommunications companies is a disaster. The regulations need to be updated to match the current studies and real life repercussions of exposure to such high levels of RF's.

See attached file(s) Protect Our Children First: Urgent Call for Updated, Science-Based Wireless Radiation Safety Standards To: Federal Communications Commission (FCC) and U.S. Department of Health and Human Services (HHS) My name is Zen Honeycutt, and I am the Founder and Executive Director of Moms Across America, a national educational nonprofit organization dedicated to empowering mothers and families to create healthy, non-toxic environments for our children. On behalf of Moms Across America, I am calling upon the Federal Communications Commission (FCC), in coordination with the Department of Health and Human Services (HHS), to undertake an immediate, comprehensive, and transparent reassessment of federal radiofrequency (RF) radiation exposure standards, with particular attention to children's developing bodies, long-term exposures, and potential biological effects beyond tissue heating. The FCC's current RF exposure limits were adopted in 1996 and subsequently retained. Although these standards address established adverse effects associated with RF exposure, they have not been comprehensively revised to reflect the enormous changes in wireless technology and patterns of human exposure over the past three decades. Today, children routinely encounter wireless devices in classrooms, homes, and public spaces. They may experience exposures from multiple sources over many years, beginning during prenatal development. The fact is that close and constant exposure to devices such as routers in homes, wireless access points in schools, and hot spots in hospitals harms human health. We believe this exposure environment warrants renewed scientific scrutiny, independent research, and reasonable precautionary protections. The federal courts have already recognized the need for greater accountability. In Environmental Health Trust et al. v. FCC (2021), the U.S. Court of Appeals for the D.C. Circuit found that the FCC had not adequately explained its decision to retain existing RF exposure guidelines with respect to potential harmful effects unrelated to cancer. The court directed the FCC to address several important issues, including: Potential effects of RF exposure on children Pulse variations and possible changes which could reduce harm Health implications of long-term exposure The widespread use of wireless devices and technological developments The adequacy of existing device-testing procedures Potential environmental impacts on trees, animals, aquatic life, and insects This decision provides a compelling legal and public-health basis for renewed review of existing federal protections. We request action. Th ecell phones and router can be made safer by altering the pulse variations. The manufacturers just nee dto be required to do so. Please see the attached comment for further details. Zen Honeycutt

I have known about my severe Electromagnetic Frequency (EMF)/Electromagnetic Radiation (EMR) sensitivity since 2018. This malady has changed my life in a bad way. It forces me to live the life of a hermit because I cannot be exposed to EMF radiation which happens if I leave my house. I will describe the symptoms that I get when I am exposed to wireless, Wi-Fi, cell towers, antennas, fluorescent lights, LED lights, electrical fields in walls, magnetic fields in walls, Dirty Electricity in Breaker Boxes, household lamps that have metal in them, wireless in automobiles, magnetic fields in electric cars, etc, etc, etc. I have spent tens of thousands of dollars on work to make my house safe for me to live in. I have to spend this money for my life – meanwhile the telecom industry gets to make tons and tons of money to make me sick ….. It is very unfair!!! My symptoms go through a progression – based on the exposure time and the severity of the EMF situation I am in. Also based on the exposure time and the severity of the EMF event, I have a recovery time with different symptoms. My initial symptoms – are a warning from my body - that I had better get out of there ASAP!!! INITIAL PROGRESSION: When I initially get into an EMF situation I get dizzy, foggy, headache, nauseas. When I get these feelings, I immediately leave wherever I am. If I get out of there immediately, my recovery symptoms are minimized. NEXT PROGRESSION STEP: This occurs in stores, friends’ houses, any gathering of multiple people (whom of course all have wireless devices going simultaneously). I quickly progress into a situation where people think I am having a stroke. Although I can think of what I want to say, I am unable to articulate the words. I start slurring speech. missing words, only getting like 1 in 5 words correct. The first time this happened I was at a Thanksgiving event. I was in the living room and started not being able to say the words I could clearly think. When I looked around the room, there were about 20 people in the room, and I counted 8 cell phones and I-Pads out that were being used in the room. When my frantic host drove me home (30 minute drive) – within 15 minutes of leaving her house – I was starting to be able to speak correctly. When we got to my house - 30 minutes away – I was totally fine as far as language was concerned. I did have residual exhaustion, unable to make a decision and brain fog for several days afterwards. WORST CASE SO FAR: The worst case I have had so far has to do with AT&T. I had fought with them for a number of months that I wanted a modem WITHOUT Wi-Fi. They kept saying that I could turn off the Wi-Fi on the web. The problem is that they kept turning the Wi-Fi on from the web. They did it during the day so that when I started getting sick I would go out onto the web and turn off the Wi-Fi and call them again that I wanted a modem WITHOUT Wi-Fi. So one night I woke up in the middle of the night – HUGE symptoms – dizzy, nauseas, I COULD NOT THINK – I was extremely weak. Somehow I had the consciousness and determination to crawl to my office and pull the plug for my modem out of the wall. It was hours before I was able to get back to my bedroom. This was the worst case of residual symptoms I have had - I was unable to function for a week from this experience. After that week, I fired AT&T – I had been a customer of theirs for 42 years. I beg you – please please please pass some laws to rein in the telecommunications industry. Childre are so sensitive to the EMFs – my heart is wrenched when I see a small child with a cell phone near their head. I have heard that the radiation from EMF/EMR is cumulative. I was a computer programmer for IBM for 21 years. We had test floors that were as big as a football field. I suspect that I got a ton of radiation during my years at IBM. I cannot go out to you because of the EMFs. However I do have a PC with wires- and a telephone which is connected to the wall. I am happy to talk to anybody who wants to gather data about real life experiences with EMF sensitivity. Sincerely, Florence Gans

Greetings! Concerning question 18: 1) A better measurement for rf-EMF is necessary, since SAR lumps together situations with extremely different potential for biological effects: SAR measures simply the absorbed energy over 6 minutes in standard cubicles of different sizes. It ignores peaks and modulations of the signal. The problem with that is that modulations might lead to resonance-like effects in biological molecules like Proteins (ion channels, enzymes,) even DNA. The peak intensities in suitable modulation and orientation in space might be responsible for „throwing the switch“ in those molecules, leading to ion influx and disturbed signalling in cells, or impaired mitochondrial funcion. Effects on voltage gated ion channels or the respiratory chain could explain the symptoms of people with EHS to a great extent. Panagopoulos states that in studies with real mobile telephony-exposure, over 95% of the studies find biological effects even below current limits where as continuous-wave exposure with the same SAR, and even „simulated exposure“ with highly repetetive modulation yield ambiguous results. He states that the polarisation and the variability and the modulation in the ELF/VLF-range are responsible for the biological effects, not the SAR. (as stated in the european parliament-workshop). Panagopoulos tested the hypothesis in Drosophila oogenesis and did find different results in different exposure settings with similar SAR. It is deeply concerning that public agencies like the BfS are caught in the circulatory reasoning that due to difficulties with dosimetry in real-mobile-telephony-settings, those studies are excluded for methodological flaws. Therefore, only studies with a small likelyhood of biological effects are considered, which acts as confirmation that there is no danger at all at this SAR. Therefore, no further exploratory research seems necessary.. 2) When testing for electrohypersensitivity (EHS) in provocation studies, it is crucial to take into account: In almost all EHS people, reliable symptom onset is delayed, sometimes by hours, and more so in high-adrenaline-situations like a provocation study. Likewise, symptom-offset is extremely delayed, often by a day or longer. This makes provocation studies hard to do: Required would be: max 1 test per day, without need to travel through traffic or public spaces or places with higher EMF, a daylong reporting-window, and several days of recovery are needed, as well as using real signals as described above. Some backup for my requests: The inadequacy of SAR can be seen when comparing exposure with the same SAR but different signal charactersistics as seen here: https://doi.org/10.1016/j.mrrev.2019.03.003 (bigger numbers would be nice, but funding seems to be hard to come by). A very good source of information is this workshop of the European Parliament (4 hours): (english starts after a few seconds) https://www.youtube.com/watch?v=s1Kn7pGy3CI Both Panagopoulos (talking about the above points) and Yael Stein provide important insights, if you have only limited time to skim. Yael Stein is a md and proposes different stages of sensitivity - the early stages are characterized by late onset of symptoms and light symptoms overall, the later stages of late offset of symptoms even hours after the exposure has ended, and the symptoms are severe. __ That effects can occur even theoretically can be seen in this preliminary model: (autoimmune d) - this also points to a lack of funding for testing the effects of shielding during sleep on autoimmune disease in a double blind study. This does not take away from the simulation of the vit D-receptor and the result that at least in theory, mobile phone radiation might lead to functional vit D deficiency in humans in general, with very small SAR values. Models like this for the voltage gated ion channels (sodium an calcium might be of highest interest) could be very useful, but so far we don’t have a complete model of those channels (according to the German Bundesamt für Strahlenschutz/FCC-equivalent). Some personal motivation: I know several people who are extremely sensitive to Wifi and mobile phones in use and phone masts, which has led me to look into possible reasons for their reactions (headaches, brainfog, fatigue, clenched muscles, altered circulation in the face - red and white spots). From my experience with them, I can rule out nocebo, since in a place where we had measured extremely low fields, they both had symptoms without expecting them (when they insisted, we measured again and found a switched-off IPAD with strong intermittent signals for location when lost, which had been brought in after the first measurement). I'm afraid the technology also hurts nature and the normal population.(see athem3, bee-fi). Thank you for your consideration. People with EHS suffer greatly and unnecessarily, and might be the canary in the coal mine for the rest.

Hi, I am a resident of Wallington, NJ and I live 1,200 feet away from the Hathaway Street Park cell tower. This concerns me as I moved here approximately two years ago with my family of four. I do not wish to share my name at this time, as I work for a government agency and am concerned that a public record such as this, may negatively reflect on my standing. I would appreciate it, if you look into "our" little town (approximately one square mile) and its six antenna installations. From what I have been able to glean, as public record shows, Wallington's own codes do not conform to the town regulations for "cell tower" distance from residences, schools, or parks. Also, there are no yearly Radiofrequency (RF) reading reviews as is mandated by Wallington policies. Furthermore, residents have no discernible way of knowing if they are suffering any adverse health effects from exposure to Electromagnetic Fields (EMFs) or RF Radiation, and no meaningful recourse to mitigating any studies or showings of such thereof. Please, Please, look into these issues as I have two young children and am concerned for my kids health, my families well being, along with "our" communities exposure to adverse health risks. I am not asking for the HHS to muscle compliance. I am simply asking HHS to care enough to give Wallington residents a fair and reasonable response to regulations and safety measures which serve to protect the community and uphold the dignity of Wallington's residence. Especially those that are most vulnerable. Thank you in advance for your care in this matter. Sincerely, Wallington resident, near the Hathaway Street Park cell tower.

I have been intolerant to pulsed radio frequencies since 2004. I get lancing pain through my brain on exposure to certain phones (certain frequencies), burning pain in the soles of my feet. I have had a microneurography test done which shows altered amplitude on a Rasta chart on exposure to mobile phones. Microneurographer says it is likely to be through the Somato sensory pathway. This would be in accordance to my research and other ion channel tests done showing hyperexcitability in ion channel variants. No allowance for people with peripheral nerve sensitivity. ICNIRP acknowledge these are from extremely low frequencies. Public Health England acknowledge 2.08hertz and 8.34 hz from mobiles 10 hz from WIFI. This can be demodulated from the signal via a non-linear system. As per attached you see that the cell membrane is calculated as linear when in fact it should be non-linear which is one mistake. Another is the staircasing error. Instantaneous peaks are then smoothed out by computer algorithms but they are not like this in real life which all lead to a false picture on what is really going on with the nerve system as in real life the nerves will spike. Acoustic blasts will also be experienced as thernoelastic bursts but these also are averaged out per 6 minute intervals. Again not a real life scenario. As an EHS sufferer I experience vasodilation all the blood goes to my feet away from my heart and brain on exposure which has been witnessed at the hospital. I get brain fog where it's like I am drunk - thinking overload of glutamate or ammonia. My memory is like it is completely wiped near a mobile or router. I have extensive research and written a thesis on the matter when I am not in an emf area I can function but I cannot function around WIFI or mobile phones. It has taken away the best years of my life.

I appreciate being asked by HHS for comments on this topic. The FCC has not done so in the thirty years since the Telecommunications Act was enacted in 1996. I do not have reason to believe that I have been injured physically. However, I do not want a Smart Meter on my house and Pennsylvania is the only state that does not allow opting out which is a negation of the liberty given to us in the Constitution: “life, liberty and the pursuit of happiness.” Many studies have been done over a period of many years that show the effects of EMF’s (Electro Magnetic Frequency) on the health of humans, animals and the environment. For any industry to not test their products for more than thirty years is ludicrous and dangerous. The wireless devices available today are completely different from what available in 1996. Smartphones didn’t even exist yet. 4G and 5G were unheard of. Children are particularly vulnerable to this damage as their bodies are smaller and spend more time outside where they can be near sources of EMR (Electro Magnetic Radiation). The FCC clearly only cares about the bottom line and the welfare of the taxpayers who support them. I learned about the dangers of cell phone radiation twenty years ago, not from the industry, but from independent doctors and researchers. It’s time for the wireless industry to prove the safety of their products. Until then, those products are to be viewed as unsafe and the industry to be untrustworthy. Note the following review: Investigation of the Adverse Health Effects of Cell Phone Radiation and Propose Solutions to Minimize Them: A Systematic Review https://pmc.ncbi.nlm.nih.gov/articles/PMC11111148/ Sec. Kennedy has promised the American people, “gold-standard science.” It’s time for the FCC to do the same.