Exposure limits & oversight

My name is Dr. Marion Van Horn. I am a neuroscientist and mother of three. I am submitting this comment because I believe there is an urgent need to reassess whether the Federal Communications Commission’s (FCC) radiofrequency (RF) exposure limits adequately protect human health and the environment. This issue recently came to our attention when our friend Alison Morrow Westover tried to stop a cell tower from being installed in her neighbour’s backyard. What surprised us most was learning that, under the Telecommunications Act of 1996, health concerns cannot be used as grounds to reject a proposed cell tower, provided it complies with FCC exposure limits. But I was shocked to learn that the FCC’s RF exposure limits haven’t been substantially updated in nearly 30 years, despite ongoing scientific research in this area! As a neuroscientist who has studied brain development, I know that early-life environmental exposures can profoundly influence the developing brain. These are critical periods of development, during which environmental influences can have lasting consequences. While the long-term health effects of RF exposure remain an active area of scientific investigation, parents are absolutely justified in asking questions about the safety of placing a cell tower so close to where their children are growing up. Given the evolving scientific evidence, I believe it is essential that the FCC undertake a thorough, independent review of its exposure limits, with particular attention to long-term exposure, children’s developing nervous systems, and potential environmental effects. We should not have to wait for conclusive evidence of harm before asking whether our existing safety standards are sufficiently protective.

I approve of the HHS department working on updating the FCC communications act from 1986. Technology has changed drastically since then and we need to make changes.

Re: Radiofrequency Exposure Standards, Biological Effects, and Outstanding Research Gaps I am submitting this comment as a concerned member of the public regarding the adequacy of existing radiofrequency (RF) exposure standards. The central issue is not whether RF radiation can produce biological effects. Experimental research demonstrates that electromagnetic energy can interact with biological systems. The unresolved question is whether existing exposure standards adequately account for potentially adverse effects across different exposure conditions, particularly those involving modulation, pulsing, chronic exposure, and developing biological systems. Of particular interest is U.S. Air Force-funded research conducted by Drs. Gale Craviso and Indira Chatterjee at the University of Nevada, Reno (AFOSR Grant FA9550-06-1-0377). Their 2008 final performance report documented apparent nonthermal alterations in catecholamine release from adrenal chromaffin cells exposed to pulsed microwave frequency sweeps, particularly between 5 and 6 GHz. Bulk temperature and pressure were monitored, although the researchers acknowledged that localized microscopic heating remained a possible explanation. Related experiments demonstrated that extremely brief, high-intensity electrical pulses could trigger intracellular calcium influx and catecholamine release. These experiments involved exposure conditions substantially different from ordinary wireless communications, but illustrate the importance of investigating biological responses to different electromagnetic exposure parameters. Separately, the National Toxicology Program's 2018 studies (Technical Report 595) reported clear evidence of malignant heart schwannomas in male rats exposed to high levels of RF radiation, alongside certain noncancerous tissue changes. Although these exposure conditions cannot be directly extrapolated to typical human wireless-device use, they warrant appropriate consideration in risk assessment. The scientific literature contains both positive and negative findings. Biological responses are not automatically adverse health outcomes, but neither should the absence of substantial tissue heating be treated as sufficient evidence that all biologically relevant effects have been excluded. I respectfully request that federal agencies prioritize independent, reproducible research evaluating: 1. Biological effects of RF modulation, pulsing, frequency sweeps, and peak versus time-averaged exposures. 2. Potential neurological, endocrine, reproductive, and cellular effects, including calcium signaling and oxidative stress. 3. Long-term, cumulative, and simultaneous exposures from multiple wireless sources. 4. Vulnerability during childhood and development, alongside realistic device-use conditions. 5. Whether existing SAR-based compliance procedures adequately characterize relevant exposure parameters. In Environmental Health Trust v. FCC (2021), the D.C. Circuit required the FCC to provide a reasoned explanation concerning noncancer health effects and related shortcomings in its assessment. Compliance with an existing exposure limit is not, by itself, proof that every potentially relevant biological effect has been investigated or excluded. I urge federal agencies to transparently identify unresolved questions, evaluate the evidence according to methodological quality, and support targeted research before making categorical assurances about the safety of current and emerging wireless technologies. Relevant sources: Craviso & Chatterjee, Final Performance Report FA9550-06-1-0377 (2008); Vernier et al., Bioelectrochemistry 73, 1–4 (2008); National Toxicology Program, Technical Report 595 (2018); Environmental Health Trust v. FCC, 9 F.4th 893 (D.C. Cir. 2021).

I live within 500 feet of a cell tower and since I lived here I have gotten migraines, insomnia, tinnitus and an auto immune disease that is excruciatingly painful to live with. My life is over from these conditions but I would hope and pray that others can be saved, please update the regulations, people cannot and should not live like this. Thank you, Susan Emrick

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.

I'm writing on behalf of my wife, son and myself. We are the Haller family from Minnesota. Our story has been all over the internet so privacy is already compromised. We live in very very rural northern MN. Only 4 neighbors in a half mile. We purchased our property in 2007 and while building our home in 2008 a 300 food tall cell tower went up at the same time. We were unaware this was even happening until it reached above the trees and almost appeared to be on our property. It ended up being on the neighbors land but only 900 feet from our home. We didn't think much at the time and even joked at least we'll have great cell service. Life was normal from 08 until 2012, when I was diagnosed with moderate to severe rheumatoid arthritis at Only 39 years old. No family history of it but I learned how to deal with it and once again life returned to normal until 9-2019. A large crane appeared at the tower for two weeks, we watched the workers remove the top and replace it with a new one. When they left we noticed immediately our phones switched from 4glte to 5g. Within a week of the crane leaving my wife was stricken with severe vertigo, that's what the hospital said anyway. After a few days of no relief and worsening symptoms we were back at the emergency room. After a MRI the confirmed she was having mini strokes, buy the dozens. Local hospitals had no idea what was happening so we were referred to the mayo clinic in Rochester. They treated her with plasmapherisis and chemo therapy to slow her immune system down enough to make the strokes stop. This worked for a short time until we returned home. Symptoms returned with our return. While we were navigating our own problems we learned our neighbor who owned the property where the tower is had a brief battle with aggressive cancer and died from a stroke at home in 2/2020. We couldn't stay at home so we moved to the inlaws house which is only a mile away. They were working across the country at the time and offered it to us. We moved there in March 2020 and stayed until they returned home in Oct 2020. While staying there the wife's condition improved immensely, she went from walking with a walker to walking on her own. Her brain function improved and she decided to return to nursing school, she was in school when the first round of strokes started but we had her withdrawn. As a family I noticed we were happier, more energetic, sleeping better and just "better". When we returned home in just days the nightmare was returning. With no choice at the time I built her a room in our detached garage and made it RF proof. It worked excellent, while in the room she feels no Symptoms. When she would feel like she had been exposed for too long she'd simply say "I'm going out to the room"! I nicknamed it "the penalty box"! We've stayed away from home as much as possible since Mar 2020 and sleep together every night in that black box I created. It's now been 6 years sleeping in there. She fully recovered to a point, she completed nursing school and is indeed a nurse. She can take some exposure but too much time on the computer or phone and she has to go out to the room. She can feel the tower in her head as soon as she comes home, describing it as a "buzzing" in her head. We've adapted as best as possible. Doctors still are baffled at how this all happened and what made it stop(I never told them what we did), they said it's a miracle...I beg to differ. We tried getting the tower owners to redirect the antennas, through local town board and even federal court. Each time we were told that the FCC preempts local government from any action against telecom. If I was better at computers I would attach files and documents but I simply don't know how. I would love to discuss this further with you and would love if you reached out to us. In closing I would like to say no business/person/organization should be immune from causing personal harm to others, such as the wireless industry. More studies, more testing needs to be done at today's levels of radiation and done so in a 24-7 exposure time. This wireless radiation affects more than just humans. I've studied the local American Grey(timber) wolf as well as whitetail deer, hummingbirds and bats for the last 6 years. I've learned much about their behavior around this tower and the lengths they go through to avoid it. We've lost family pets to this as well. Our beloved dog Ms Daisy had so many tumors on her the weight of them wouldn't let her breathe. The vet had never seen anything like this when we brought her in to be put down. Please HHS listen to all these pleas you are receiving, for too long they have been swept under the rug. I've met hundreds to thousands of families like our after out story aired on the children's health defense website. We were receiving phone calls everyday from people asking for help. I told them what I did for us and it helped. Now I'm asking for your help! We are not crazy,we are victims. Jay & Marcia Haller

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.

We are deeply concerned by the ample evidence of harm caused by radiofrequency radiation (RFR) to our own health and to public health in this country. Current exposure limits for RF radiation are based on numerous assumptions; however, research studies published over the past 25 years show that most of those assumptions are not supported by scientific evidence. Based on this abundance of scientific evidence we want strict laws to protect us and allow us to opt out of excess radiation, and provide local control for when and where to site infrastructure that causes radiation. We want better safeguards to limit RFR in all public spaces. We have personally experienced a reduction from symptoms of RFR exposure by turning off the wireless feature on our router and putting many our electronic devises on ethernet cables, and by reducing our cell phone use. The majority of the scientific literature related to RFR stems from cell phone studies. There is strong evidence that people who use a cell phone held directly to their ear for more than ten years are at significantly increased risk of developing gliomas of the brain and acoustic neuromas of the auditory nerve. There is also evidence that the risk of developing these cancers is greater in younger than older people. The May 2016 report from the US National Toxicology Program showing that rats exposed to cell phone radiation for nine hours per day over their life-span de- velop gliomas of the brain and Schwannoma of the heart (the same kind of cancer as acoustic neuroma) adds proof to the conclusions from the human health studies that radiofrequency radiation increases risk of cancer. While the strongest evidence for hazards coming from RFR is for cancer, there is a growing body of evidence that some people develop a condition called electrohypersensitivity {EHS). We are among these individuals that respond to being in the presence of RFR with a variety of symptoms, including headache, fatigue, memory loss, ringing in the ears, "brain fog" and burning, tingling and itchy skin. Some reports indicate that up to three percent of the population may develop these symptoms, and that exposure to smart meters is a trigger for development of EHS. Please find attached some relevant studies and references that relate to the dangers of RFR. There are thousands more listed at https://ehtrust.org/science/science-on-health-effects-of-cell-phone-and-wireless-radiation/?link_id=5&can_id=4e10ca07001c7ba173b2541d8c5cab8e&source=email-act-now-to-support-h3551-in-the-ma-legislature&email_referrer=email_3146404&email_subject=act-now-to-support-h3551-in-the-ma-legislature Please take the following actions to protect our family and the public from the dangers of RFR. • Governmental and institutional support of data collection and analysis to monitor potential links between RFR associated with wireless technology and cancers, sperm, the heart, the nervous system, sleep, vision and hearing, and effects on children. • Further dissemination of information regarding potential health risk information that is in wireless devices and manuals is necessary to respect users' Right To Know. Cautionary statements and protective measures should be posted on packaging and at points of sale. Governments should follow the practice of France, Israel and Belgium and mandate labeling, as for tobacco and alcohol. • Regulations should require that any WTD that could be used or carried directly against the skin (e.g., a cell phone) or in close proximity (e.g., a device being used on the lap of a small child) be tested appropriately as used, and that this information be prominently displayed at point of sale, on packaging, and both on the exterior and within the device. • IARC should convene a new working group to update the categorization of RFR, including current scientific findings that highlight, in particular, risks to youngsters of subsequent cancers. • Emerging human evidence is confirming animal evidence of developmental problems with RFR exposure during pregnancy. RFR sources should be avoided and distanced from expectant mothers, as recommended by physicians and scientists (babysafeproject.org). • Other countries should follow France, limiting RFR exposure in children under 16 years of age. • Cell towers should be distanced from homes, daycare centers, schools, and places frequented by pregnant women, men who wish to father healthy children, and the young.

I have been electrosensitive for a few decades. I must wear shielding when I go out and can't have wireless or anything "smart" in my home. I can't socialize normally because I can't be around cell phones or wifi. I can't go in an ambulance or a public bus,train or airplane. I can't go the hospital and can't have surgery if I need it. Too much wireless radiation. It's a big problem that other people will increasingly experience. My cardiologist tested me with a cell phone & saw an increase in my heart rate.I also get arrhythmias, brain fog, nausea, dizziness, fatigue, headaches that land me in bed.I am very concerned about the effects on babies,children,all people. You know that wireless radiation is harmful. I am not going to attach studies.You have all of them you don't need me to show you. I am aware of the studies at ehtrust.org & mdsafetech.org. Our radiation exposure standards are less protective than most countries & are not protective at all. I want you to protect us and our environment (animals, insects and birds) from this pollution.I want you to maintain land line infrastructure & service for national security and health reasons.Children who use wireless phones before adulthood have a 4x higher rate of brain cancer according to the scientific literature. Yet most children now use cell phones and do not have land lines at home. People need to be made aware of what that is doing to their children, to our future, including to their fertility and the fertility of future generations, and to their lifespan and health. Protect children in schools. Stop irradiating babies and children, including in doctor's offices. Stop irradiating hospital patients. Study the exposures from medical devices like insulin pump therapy that is a 24/7 exposure, put a focus on these patients, be transparent, communicate findings to endocrinologists and other involved practitioners so that best practices can be determined and implemented without further delay. Use hard wired connections in schools and wherever possible in society. Start a nationwide program to measure individual exposure levels so that we know what people are actually exposed to from all these separate sources that add up. Investigate the exposure levels of employees required to use tech for work like store employees that are required to use a business cell phone and/or tablet throughout their workday and police officers who are required to wear wireless cameras over their hearts and laptops in their cars, &other wireless equipment on or near them throughout their shifts. What are the exposure levels for these people? Nurses too who are required to wear hospital cell phones around their necks, over heart, lungs and thyroid, above pregnant abdomens, that transmits to and from the nurse's station throughout their shifts. The FCC didn't approve the radiation from these extra phones. And these employees usually have a personal cell phone in their pockets. Even while pregnant. Measure the exposure of pregnant women and teach them how to minimize it. Make knowledgeable experts available to help citizens measure, understand and deal with this pollution. TEACH the public what the problems are and how to mitigate them. Teach children in schools so they understand what this is and how it works and how to use it safely (if there is a way to use it safely). END the use of technology that is known to be dangerous until it is shown/proven to be safe. Stop exposing people in nursing homes and other institutions like prisons. Follow the precautionary principle. Keep wireless out of schools, BAN cell tower placement anywhere near homes, schools, and businesses of any kind. And here is the big problem with cell tower placement - there is no place on earth where there is not life that can be harmed and we should be concerned about ALL life, not just human life. Animals, birds and even plant life is adversely affected. The bird population is declining rapidly. Birds roost on cell towers. It is a crime. EMR even causes an increase in mold and fungal growth and illness. It affects all body systems, every cell, and makes people very sick. People affected are often misdiagnosed because physicians do not recognize the cause since it is invisible and our government assures it is safe. Young adults have a massively increased rate of colon cancer. The most likely cause is radiation from growing up with laptops on their laps, wireless game controllers in their hands in their laps and cell phones in their pockets. NO ONE bothered to tell a generation that a laptop should not be closer than 8 inches from the body and cell phones should not be closer than 5/8" from the body according to the manufacturer's fine print. And they still don't know. And most doctors don't know. Stop denying that there is a problem. Stop playing games and do your job. PLEASE. This is a neglected crisis.

I am commenting as an individual consumer and parent. My comment relies on peer-reviewed research, government reports, and a federal court decision, each cited below. The safety limits are almost 30 years old. The FCC set its wireless radiation limits back in 1996 and hasn’t updated them since. In 1996, about 44 million Americans had cell phones. Now nearly everyone does, and most of us also have Wi-Fi, smartwatches, tablets, and smart meters running all day [1]. In 2021, a federal appeals court ruled that the FCC acted “arbitrary and capricious” when it kept those old limits. The court found the FCC never gave a real answer to evidence of non-cancer health effects below the limits, especially for kids, and didn’t address long-term exposure or the environment [2][3]. There’s real science here (Q12) In 2011, the World Health Organization’s cancer agency (IARC) classified radiofrequency fields as “possibly carcinogenic to humans,” based on an increased risk of glioma, a malignant brain cancer, linked to wireless phone use [4]. In a study nominated by the FDA, the government’s own National Toxicology Program exposed rats to cell phone radiation. Male rats developed malignant heart tumors, and both male and female rats showed heart tissue damage. The lowest exposure level matched the highest amount allowed today for local tissue exposure from phones. The NTP said the tumors resembled ones reported in some studies of frequent cell phone users [5]. NTP also pointed out that 4G and 5G use different frequencies and signal types than the ones it tested. So the networks we’re all using right now haven’t been studied this way [5]. Kids deserve extra care (Q11) Children’s bodies and brains are still developing, and they’ll be exposed for a lifetime. The American Academy of Pediatrics has asked for limits that account for children and pregnant women [3]. The court specifically faulted the FCC for not explaining why it brushed off evidence about children [3]. What I’m asking HHS to do I’m not asking for the government to control what devices I buy. I’m asking for honest information and the freedom to choose. Tell the FCC plainly that the 1996 limits aren’t backed by current health science. Then have HHS, not the wireless industry, lead the health review the court ordered. Give us the facts. Radiation levels (SAR) and the minimum distance from your body should be on the box and at the store, not hidden in phone menus. Let people opt out. Families should be able to decline smart meters without penalty fees and ask for wired internet options for their kids at school. Neighbors should get a heads-up before antennas go up near homes and schools. Give communities a say again. Right now, local towns can’t consider health concerns when deciding where towers go. HHS should support restoring that local voice. Fund independent research. NIH should follow up on the NTP findings using 4G and 5G signals, with scientists who aren’t funded by the wireless industry. Share simple tips. Use speakerphone, keep your phone off your body, and use a wired connection when you can. HHS should share this as voluntary guidance, stated clearly. Until independent research shows this is safe for kids and lifelong use, the burden of proof should be on the technology, not on families. Thank you for asking the public about this. [1] Washington Spectator, “FCC & Electromagnetic Radiation” (2022): https://washingtonspectator.org/fcc-electromagnetic-radiation/ [2] Environmental Health Trust v. FCC (D.C. Cir. 2021), summary by Davis Wright Tremaine: https://www.dwt.com/blogs/broadband-advisor/2021/08/fcc-radiofrequency-limits-dc-circuit [3] Law Street Media, D.C. Circuit remand summary: https://lawstreetmedia.com/?p=12895 [4] IARC Press Release No. 208 (2011): https://www.iarc.who.int/wp-content/uploads/2018/07/pr208_E.pdf [5] NIH news release on NTP findings (2018): https://www.nih.gov/news-events/news-releases/high-exposure-radiofrequency-radiation-linked-tumor-activity-male-rats