Exposure limits & oversight

#3: I am commenting regarding the FCC's response to the D.C. Circuit Court of Appeals' remand concerning its decades-old highly outdated radiofrequency (RF) radiation exposure guidelines. The FCC should fully consider the overwhelming evidence and real-world experiences concerning the health and environmental impacts of wireless radiation, including non-cancer health effects, impacts on children, long-term and cumulative exposure, cancer, and impacts on wildlife and the environment and critically also bees and pollinators that we all rely on for our food!” *A major review by Germany’s NABU and other NGOs analyzed 190 studies, finding that 72 out of 83 scientifically relevant studies reported negative effects of non-ionizing radiation on insects, suggesting EMR acts as a driver of insect decline alongside pesticides and habitat loss. Here is just one study of many100s I have seen over the years documenting the harmful results of RF Microwave exposure to all biological beings, I believe the FCC and HHS should review: The landmark 2018 National Toxicology Program (NTP) study, which provided comprehensive evidence of significant health risks from radiofrequency radiation (RFR). -The NTP study demonstrated significantly increased rates of Schwannomas and malignant gliomas (brain cancers), as well as chromosomal DNA damage in rodents exposed to RFR levels mimicking lifetime human exposure. −The study is particularly critical for children because their developing bodies absorb higher RF radiation into their brains and bodies during sensitive developmental stages. −Research indicates that children’s brains absorb 2-3 times more radiation than adults, and their skull bone marrow absorbs a roughly 10-fold higher local dose, making the NTP’s findings on DNA damage and tumor growth highly relevant to pediatric vulnerability. The FCC is not a health agency and does not have expertise in medicine, biology, environmental or public health… This issue matters to me deeply because my parents suffered greatly from RF exposures, as well as myself. After moving into a house that had 3 smart meters positioned right outside our bedrooms, we all started having insomnia and low energy. And because we made the grave error of trusting the FCC, and letting the naïve telecom technician install the highly radiating router next to my parent’s bedroom my otherwise vibrant father started to complain of feeling immense fatigue, and having to go to myriad doctors who could not explain this sudden change. That is when I began researching what could be the root cause, as I literally was getting from no sleep to an hour or two a night. That is when I discovered others with smart meters were similarly having many health issues. Then I learned about “electrosmog”. I got a Tri-Field meter and took steps to reduce all emfs in/around our house and had PGE remove the smart meters and replace them with analog – which we had to pay to do so as well as pay an extra monthly rate – which is a crime in itself. I also learned that many other states would not let their customers use analog, which is a much worse crime. The day the smart meters were changed out all of our sleep improved drastically. Being able to sleep again was a lifesaver. I started unplugging the router at night and during the day I draped a faraday cloth over it to try and mitigate the harmful radiation. Although not ideal, it helped and my dad’s energy returned. At that time I didn’t understand how particularly harmful RF was so when the solar company said we should stop unplugging the router at night, my dad started to feel unwell again. The router was positioned right next do his bedroom and behind him in the den where he also spent a lot of time. He never recovered and devastatingly we lost him within 3 years. I am still trying to forgive myself for allowing the telecom tech to put the router in the worst possible location it could be. I started to carry the Tri Field meter and test everything. I tossed the microwave oven and noticed the city had allowed a massive 5G tower across the street from my health food store. Standing in the parking lot of that store, I turned on the meter and the dial shot to the max level allowed on the meter! So I do not buy anymore from that store for obvious reasons. There is an apartment complex right below that 5G tower, which is another crime to those unsuspecting residents. And there are no more birds to be seen in the trees in front of that health food store anymore, where they used to hop around looking for treats from the shoppers. The frequency of nature, the Schumann Resonance 7.83 Hz, which includes humans that our bodies have evolved with has suddenly been replaced with unnaturally and recklessly high man made frequencies in the RF Microwave range - 600 MHz – 39 GHz. We are playing with fire here.

I am submitting this comment in response to HHS’s Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure. As a concerned parent and member of the public, I support further research into the potential health and environmental effects of wireless radiation, particularly its long-term effects on children and other vulnerable populations. With wireless technology becoming increasingly common in our homes, schools, and communities, I believe it is important that federal agencies thoroughly examine potential health risks, consider the experiences of individuals reporting adverse effects, and identify gaps in existing research. I urge HHS to prioritize independent scientific research, evaluate current safety standards, and ensure that public health decisions are based on comprehensive, transparent, and up-to-date evidence. I have suffered for the last decade from extreme sensitivity to RF and EMF. I have meters that measure both and have been able to confirm over and over that in low EMF/RF environments, my body can rest, but in high environments, I react as if it is plugged in to the wall- my whole body feels as if it is on fire (nerve pain), and I frequently experience arrhythmias in high exposure situations (again, I have confirmed this with my meters). I have been to many doctors, who can not find anything wrong with my heart or body even though they can see it reacting to outside stimuli in a very exaggerated way. I am asking for more study of this problem, as the effects of high EMF and RF exposure have been my family and it is in every public space, at high levels, so very hard to avoid if you are sensitive. My children are also sensitive and experienced very poor health when living near a tower and next to power lines. When we moved to a place that was low EMF/RF, their health issues dramatically decreased. I’d like more research to be done so that we can keep our children and vulnerable populations safe and not degrade the health of everyone else. I’m hoping for more conservative, wise use of technology in the future and I know that the science will show support for that, if it is studied and measured thoroughly and appropriately. Thank you for providing the public with an opportunity to voice these concerns.

thank you for the this opportunity, I have waited a long time to tell my story. If it is possible for the HHS dept to just have a EMF dept, so our voices can be heard.

Hello, Thank you for this opportunity to provide the DHHS with information on this important topic. In order to both provide evidence to support my concerns and to hopefully make things more easily accessible, I have included many resources in the form of a PDF document that also contains my personal comment in reply to the invitation to provide our experiences with exposure to these technologies. I am a former military spouse and was born on a military base in Fort Knox Kentucky and then married a member of the National Guard who eventually decide to join the Active Duty military. I will be providing my personal experiences as someone that has potentially been a human research subject that I provide the background of this history in my attached comment. I know that the DHHS' NIH in 2011 under former President Barack Obama had formed his Presidential Commission for the Study of Bioethical Issues, and my comment will include evidence to support my own personal history with similar experiences to those who gave their testimony; though I admit that I ran out of time to put together a much more detailed testimony, but I hope that what I have provided will give the DHHS enough information on my experiences that I began having in the late 1990's time frame. There are many people reporting this and we all would like to have a Congressional hearing on this in order to bring this experimentation into the open, but I am very appreciative of this opportunity and hope that I have completed my comment as requested in the Commenter's Checklist. Thank you

See attached file(s) Katie Webb, QuantaX Technology HHS-OASH-2026-0397 HHS must act now to reduce unnecessary wireless radiation exposure and protect biological fidelity: the precision with which living systems develop, regulate energy and information, repair damage, and recover. I support and present John Coates's complete comment, included in the attached PDF with my position statement and our illustrated plausible pathways. Low-fidelity biology is the upstream vulnerability HHS must investigate and prevent. Mistimed calcium signals, mitochondrial and redox mismatch, impaired repair, and persistent compensation can reduce the reserve needed for healthy development and later challenges. The S4–Mito–Spin framework connects these processes through specific molecular targets and measurable functions. A standard based on average absorbed energy cannot, by that number alone, characterize biological timing, recovery, or developmental susceptibility. The cancer evidence demands action. NTP and the Ramazzini Institute reported malignant heart schwannomas in male rats. The WHO-commissioned animal review rated evidence for increased glioma and heart schwannoma as high certainty. Melnick and Moskowitz (2026), applying EPA risk-assessment methods, calculated that the public whole-body limit is 15–900 times above modeled exposure levels for one additional cancer per 100,000 people, depending on daily exposure duration, and 8–24 times above their male-reproductive protection estimates. HHS and EPA must derive health-based limits and reduce avoidable exposure while completing that assessment. Put the Yale developmental findings at the center. Aldad and colleagues found hyperactivity, impaired memory, and altered prefrontal-cortex synaptic transmission in mice exposed prenatally to cellular-phone radiation. Yale's senior author described the experiment as showing that prenatal cell-phone exposure caused ADHD-like behavioral problems in mice. Cakir and colleagues subsequently identified delayed radial-glial differentiation and BET-mediated developmental effects in human cortical organoids. A developing child gets one chance at each developmental window. HHS must respond with prenatal protection and a funded developmental research program. Test the full pathway. Measure the S4/channel and CYB5B interfaces, calcium timing, mitochondrial reserve, spin-sensitive chemistry, chromatin responses, and later function together. Kim and colleagues' CYB5B gene-switch study identifies a molecular route from a defined field to rhythmic calcium-dependent gene regulation. The CACNA1C sleep study identifies genotype-dependent response. Use sham, carrier-only, and pulsed exposures at matched SAR with temperature control, then apply molecular blocking, rescue, and timed replay to establish the sequence. Protect future generations now. RF experiments already warrant offspring follow-up: Yan and colleagues reported sex-specific offspring growth and metabolic changes after paternal RF exposure. Separate diet and toxicant experiments demonstrate molecular transmission through sperm RNA and persistence of environmental effects across generations. HHS must directly test RF-associated germline transmission, following maternal gestational lines through F3 and paternal preconception lines through F2, with unexposed descendants and molecular mediation tests. Also measure repeated direct exposure across successive pregnancies. Continued exposure and inherited effects are distinct routes that both require investigation and prevention. My requests are concrete: 1. Publish a federal quantitative RF risk assessment using current cancer and reproductive evidence and established EPA methods. 2. Restore sustained NTP research, independent replication, prospective pregnancy cohorts, and multigenerational studies linked to early fidelity measurements. 3. Reduce unnecessary exposure in pregnancy, childcare, schools, healthcare, and sleeping environments. Fund practical wired and optical alternatives. 4. Require realistic body-contact testing and disclosure of test distance, dose averaging, active radios, and waveform conditions. 5. Reinvigorate Public Law 90-602. Ask Congress to place RF health-protection standards under HHS/EPA and repeal Section 704's health-based siting restriction. 6. Advance the Clean Ether Act through interoperable optical networks, wired-first procurement, independently evaluated pilots, and measured reductions in unnecessary transmissions. Publish a ninety-day work plan, a one-year assessment and research program, named responsible officials, and annual results. The accompanying 5,000-word statement, pathway images, and John Coates's complete comment provide the evidence and implementation requests. Protect biological fidelity before the developmental window closes. Katie Webb QuantaX Technology

As a qualified scientist that has done a lot of research in this area, it is crucial that head and body resonance is legitimately used in the determination of the safety standards. The fact that it is not, and that this goes against the obvious science, is very questionable, and I'd say in even stronger terms that it's actually very suspicious. Some research from Grok 4.7 Extra High references this obvious science: "Head size sets the radiofrequency dose. Standards and most of the research behind them use one adult size. That misses what decides how much energy is absorbed, and where in the brain it lands. The head works as an antenna. Size sets the frequency it absorbs most strongly, and which parts of the brain receive that energy. Head size changes greatly from infancy to adulthood, and among people of the same age. The FCC does not measure this. Phones are tested on a single adult head. The environmental limits are tightest where an adult body resonates, and they loosen where the head resonates. The ARRL RF Safety Committee states it directly. "The adult head, for example is resonant around 400 MHz, while a baby's smaller head resonates near 700 MHz. Body size thus determines the frequency at which most RF energy is absorbed." The same guidance puts a grounded adult body near 35 MHz and an insulated adult near 70 MHz, with further resonances near 1 GHz at the body surface. An adult and a baby are not the same antenna. Absorption peaks when head size matches the wavelength in tissue. The field inside the skull then forms a standing wave, so some parts of the brain absorb several times more than others. A head about 10 percent smaller peaks about 10 percent higher in frequency. Circumference is about 35 cm at birth and 54 to 58 cm in adults, a factor of roughly 1.6. Applied to the adult figure, 400 MHz moves to about 640 MHz, beside the ARRL figure of 700 MHz for a baby head. At one age the spread is still several centimeters, about a 10 percent shift, enough to move a peak on or off a band in real use. A small adult and a large child overlap. Age is not a stand-in for head size (Nellhaus, Pediatrics 1968; Rollins, Collins, and Holden, J Pediatr 2010; CDC and WHO growth charts). Calculated models show the same size dependence, and a second peak a uniform head misses. Kritikos and Schwan (IEEE Trans Biomed Eng 1972) found internal hot spots in a tissue-like sphere, the frequency of strongest heating set by radius. Joines and Spiegel (IEEE Trans Biomed Eng 1974) modeled the skull in layers, skin through brain, at 7 and 10 cm radius, to cover different skull sizes. The layered head has a broad peak near 2.1 GHz. A uniform head of the same size does not. At that peak the field is a standing wave that shifts with frequency. Weil (IEEE Trans Biomed Eng 1975) mapped layered heads from 2 to 12.5 cm radius, and the hot spots move with size. The 400 and 700 MHz resonances and this peak near 2 GHz are different. Both move with head size. One adult size sees neither one. The FCC tests a phone at the ear on one shell, the SAM phantom required by IEEE 1528 and FCC KDB 865664. It is the 90th-percentile adult male from the 1988 Army survey (Gordon et al., Natick/TR-89/044, 1989), filled with uniform liquid, which misses the layered peak. It is not a child, a small adult, or the spread at one age, and it cannot compare 400 MHz with 700 MHz. SAM was meant as a cautious overestimate for older handsets (Beard et al., IEEE Trans Electromagn Compat 2006). Later work finds designs where an anatomical head, including a child's, exceeds SAM (Lee and Choi, ETRI Journal 2019). Papers disagree on the size of that gap (Gandhi, Lazzi, and Furse 1996; Christ et al. 2010). One shell measures neither side. Away from the phone, the limits (47 CFR 1.1310; OET Bulletin 65) are strictest from 30 to 300 MHz, at 0.2 mW/cm2. The ARRL states why they loosen above 300 MHz: higher power densities are permitted "based on the concept that the body will not be resonant at those frequencies and will therefore absorb less energy." The head resonances sit in that range. At 700 MHz the limit is f/1500, about 0.47 mW/cm2, more than twice the 30 to 300 MHz limit. A smaller body resonates higher as a whole. The University of Florida newborn model resonates at 240 MHz, with a second peak near 800 MHz, and at resonance the public reference level does not hold the whole-body dose to the basic restriction (Dimbylow, Bolch, and Lee, Phys Med Biol 2010). The same shortfall appears for 1-year and 5-year models (Dimbylow and Bolch 2007). A study or a limit built on one adult head assigns the wrong frequency, and the wrong place in the brain, to children and to many adults. The effect happens where the energy lands, and those peaks move when head size changes. A certification number is the result for one large adult shell. Research and standards need the resonant frequency and the internal pattern across real head sizes, including people of the same age."

There is no research on the longterm effects of wireless radiation exposure. And because there are no long term studies, the technology should be prohibited (at the least, heavily regulated). Have you ever read the fine print on a cell phone package which warns you to hold the phone against your body? Have you noticed the high percentage of brain cancers in young people? This is due to cell phone use and wireless internet modems in bedrooms. Anecdotally, I know of several deadly cancers caused by phones or modems. Please pursue. I can tell you I walked into a building last year with heavy wireless amplifiers and I was struck with temporary tinnitus and very heavy pressure in my head. I do not have these conditions in a safe setting. It threw me off for hours and once I left the building I immediately felt better. When we removed all wireless devices and the modem from our home last year and hardwired our computer and phones, immediately our home felt more peaceful and we started sleeping through the night. As an American citizen who wishes live a healthy life and raise my children in freedom and health, I am very troubled by the lack of consent and freedom in my own home and in my own life when it comes to wireless radiation exposure. The electric company attached a "smart meter" to my home without my consent. I asked them for the right to "opt out" of the technology as it would be attached to my house close to our living areas (bedrooms, office, deck/backyard play area). They said I would be charged a monthly fee for someone to read the meter and I agreed. But a month later when my dog was inside, they attached the smart meter to my home anyway. I have a meter which reads RF and the meter emits dangerous levels of radiation into my child's bedroom and our backyard area where we gather. This same electric company allows Missouri customers to OPT OUT and pay an extra fee for a non communicating meter, but just yards away across the state border, Kansans cannot opt out. Everytime we're in an airport or at a school or a city building or shopping center, there is wireless internet blasting us. All without my consent. The cell towers being built next to schools and churches, on top of hospitals and hotels are attacking our bodies and cells. Many cell phone companies will pay these businesses or non profits to locate their towers on the property and for non profits and for profits the offer may seem irresitible. Did the cell phone company inform the property owner of the risks of radiation? I highly doubt it. The effect on humans and animals have not been studied and it is very unnerving that it is all being done without our consent. At a doctors office we are now handed a WiFi tablet to check in and update our records. Our own city street lights have 5G antennae caps on top. Without our consent and for someone else's profit. The gas meter next to my house was updated to a communicating wireless device without my consent. The workman said we need to update your meter. He did not tell me it would be a communicating device. This meter is outside of my other child's bedroom. None of this is fair. 1-at a minimum, all American citizens should have the right to OPT OUT of communicating emitting devices attached to our homes. 2-it should be illegal to install or build cell phone towers near neighborhoods, parks, schools, nursing homes, hospitals, hotels or churches 3-because people have the option to use a certain amount of data within the cell phone monthly contract, installing wireless in public spaces and commercial businesses is completely unnecessary as it affects the liberty and right to consent of the individual. I should not be forced to be exposed to wireless radiation if someone else chooses to carry a cell phone. Their choice should not affect my body or health or my children. Thank you for requesting these comments and starting to address the egregious loss of liberty and lack of the right to consent to be subjected to wireless.

Question 2 — Perspective Individual consumer reporting unlicensed wireless transmissions, NIER fraud, and FCC complicity. Question 5(n) — Regulatory changes Abolish all RF categorical exclusions. Require independent annual NIER safety inspections of every wireless facility, without exception. Question 8 — Improvements in exposure assessment Require independent site inspections, verification of all antennas and transmitters, transmission identification, and residential-area measurements. Investigate unlicensed transmissions and missing equipment rather than accepting company paperwork at face value. Question 9 — Technical and exposure-related disclosures Require public disclosure of each facility’s FCC registration, installed antennas and transmitters, licensed frequencies, power levels, inspection results, and RF safety records. Question 15 — Evidence concerning wireless infrastructure The Crown Castle Edgemont cell tower, BU 855801, at 5351 W. 6th Avenue, Lakewood, Colorado, has no current FCC registration (permit TELE24-00035; project CN13-796 / 2400001). There are no registered active call signs or frequencies for this site in the FCC’s Universal Licensing System (ULS). All transmissions measured at this site are publicly unlicensed. Two antennas physically present on the tower are omitted from the current site plan. Using a TinySA Ultra ZS-407 spectrum analyzer and HTOOL HT8 directional antenna, I measured an unlicensed transmission at 10.7777 GHz at +22.3 dBm beneath the tower and +9.4 dBm on my patio, approximately 0.27 miles away. At that same patio location, my cell phone signal measured −90 dBm. The +9.4 dBm reading represents approximately 8.7 billion times the received power of the phone signal. I also measured unlicensed transmissions at 10.0912 GHz and 11.5878 GHz. These transmissions, omitted antennas, and lack of FCC registration demand investigation. Question 18 Crown Castle’s NIER checklist identifies its radio service as Wireless Communications Services (Part 27). That service is not included among the services eligible for the checklist’s categorical exclusion. Crown Castle nevertheless claimed a categorical exemption that does not apply to Wireless Communications Services (Part 27) and left the follow-up power-screening questions blank. The FCC/LSGAC guide sets a 1,640 W EIRP threshold for routine environmental evaluation of Wireless Communications Services. The permit lists two Ericsson AIR 6419 antennas: the B77D has a published maximum EIRP of 80 dBm (100,000 W), and the B77G has a published maximum EIRP of 79 dBm (approximately 79,433 W). Both published maximum EIRP ratings vastly exceed the 1,640 W threshold, even before accounting for two additional antennas omitted from the site plan. Because Crown Castle left the required power calculations blank, the actual effective EIRP of the installed equipment cannot be independently verified from its submitted safety paperwork. Edgemont demands a full RF environmental evaluation, not a categorical exclusion. I allege Crown Castle committed NIER categorical-exclusion fraud by claiming an exemption that did not apply and bypassing RF safety screening. I also allege FCC complicity in a coordinated cover-up and circumvention of NIER safety regulations. Through FOIA, I requested all Edgemont site documentation held by the FCC. The FCC reported that it had no responsive records. I later obtained Crown Castle’s completed NIER categorical-exclusion checklist and site documentation through the City of Lakewood. The checklist identifies itself as the FCC/LSGAC Local Official’s Guide to RF and applies FCC RF-exposure rules to this facility. The FCC’s assertion that it possessed no responsive records is difficult to reconcile with the existence of this documentation. When I reported the unlicensed transmissions and missing antennas, the FCC dismissed my report by focusing on whether my equipment was calibrated instead of investigating. I allege that the FOIA discrepancy, refusal to investigate, and dismissal of my measurements are evidence of a cover-up warranting investigation into the FCC’s role. I allege regulatory capture and a cover-up enabling unlicensed spectrum deployment while bypassing RF safety safeguards. The FCC’s proposed “Build America” rules (WT Docket No. 25-276) would fast-track wireless deployment and restrict local oversight, which would further weaken the FCC’s safety rules. AT&T’s role in the site’s equipment, transmissions, and operation must also be investigated. Abolish all RF categorical exclusions. Require independent annual NIER safety inspections of every wireless facility, without exception. Investigate the unlicensed transmissions and Edgemont facility, establish responsibility for the alleged NIER categorical-exclusion fraud and cover-up, and hold Crown Castle, AT&T, and the FCC accountable.

It's about time public safety trumped money.

In 1996 the telecom industry got a law passed to bring toxic wireless radiation to market with no safety testing, and no accountability for harm. The science now shows neurotoxicity, ADD/ADHD, seizures, cancer, infertility and more! It's been 30 years in the making but we now have an unprecedented short window with both the Federal Communications Commission AND Health and Human Services to build the public record and document the fallout. Regulations for the wireless radiation industry MUST be established for us and for our future generations for healthy safety and the protection of the planet. Stop the excessive diseases and conditions from the radiation. I am also being charged an extra unauthorized fee of $12.00 from NJ PSE&G energy company because I refuse to install a SmartMeter. SmartMeters release radiation that causes cancer and I have cancer. I offered to read or phone in the monthly meter readings but PSE&G refuses to remove the extra charge. They argue that they must send in a person to my district to remotely read my meter and they must spend gas money. They could send in an electric vehicle to save gas or a hybrid. There is no reason to charge me an extra $12.00 per month since I do not want a SmartMeter installed in my home. Please help me in this situation. Thank you. Susan Scherman, RN, BA, CSN, Certified NJ School Nurse & Certified Health Education Teacher