Exposure limits & oversight

I am writing as a concerned parent and member of the public to urge the Department of Health and Human Services to conduct a thorough, independent evaluation of the potential health effects of electromagnetic fields (EMFs), particularly radiofrequency (RF) radiation from wireless technologies. I am concerned that current U.S. exposure standards may not adequately account for the full range of potential biological effects of RF radiation. Although non-ionizing radiation does not have the same properties as ionizing radiation, the absence of sufficient energy to directly ionize atoms does not, by itself, establish that all forms of non-ionizing exposure are biologically harmless. I urge HHS to carefully evaluate the full body of scientific literature, including research investigating potential effects beyond established thermal mechanisms, long-term exposure, and impacts on children. I am also concerned about the influence of industry on the development of wireless safety standards and the independence of the regulatory process. I encourage HHS to examine the issues raised in Norm Alster's Captured Agency: How the Federal Communications Commission Is Dominated by the Industries It Presumably Regulates and to ensure that future assessments are transparent, scientifically rigorous, and free from undue industry influence. Safety standards should reflect an independent assessment of the evidence and be updated when warranted by new findings. Other countries have adopted different approaches to wireless exposure limits and precautionary measures, particularly in settings involving children. I ask HHS to compare U.S. standards with international approaches, identify the scientific evidence underlying those differences, and explain whether research considered in other countries has been adequately evaluated in the United States. Particular attention should be given to evidence concerning children, long-term exposure, and the potential effects of cumulative or repeated exposure. I also wish to share a personal observation as a parent. From a very young age, my daughter has repeatedly appeared noticeably flushed when near devices such as mobile phones and laptops for a period of time. I have observed this pattern over many years, and it concerns me that I have not received a satisfactory explanation for it. I recognize that an observation alone cannot establish the cause or mechanism of a physical reaction. Nevertheless, I believe experiences like this deserve careful, objective investigation rather than dismissal, and that further research is needed to understand whether any relationship exists between reported symptoms and RF/EMF exposure. I urge HHS to apply a precautionary, public-health-centered approach while scientific uncertainties remain. This should include commissioning and supporting independent research, reviewing the adequacy of existing exposure standards, investigating potential effects on children and other potentially vulnerable populations, and making the scientific basis for its conclusions publicly accessible. Research priorities should include areas where evidence is conflicting, where significant knowledge gaps remain, and where existing standards may not fully address the questions raised by emerging research. Technological progress and public health should not be treated as competing priorities. The public deserves confidence that wireless technologies are evaluated through an impartial, transparent, and comprehensive scientific process, and that economic interests do not take precedence over the protection of human health. I ask HHS to take these concerns seriously and to ensure that safety is demonstrated through rigorous evaluation rather than assumed in advance.

The current fairly unregulated use of EMFs via the abundant towers is unacceptable for the general health of all people and especially children. There is enough research at this point to acknowledges that the current EMF frequencies are harmful to everyones health and general well being. Some have mentioned the destruction of the mitochondria and the inability of the body to adjust to the firing and perpetual bombardment of frequencies not compatible with humans and probably any animals. These frequencies can probably be made more harmonious for all living beings but have not been. The question is why not? Cell phones have been linked with brain tumors and the current views of some doctors is that 50% of people will develop Alzheimers. One contributor is most likely cell phones and the lack of awareness of the dangers of using them next to the head. Why is there no information presented with the purchase of these devices. this needs to changes as well as once again the frequencies being used.

Our environment is a shared, communal resource. The air we breathe, the land we inhabit, and the spaces where our children grow are not the exclusive property of industry, companies, utilities, or stockholders. Yet corporations profit from infrastructure that introduces electromagnetic exposures into environments shared by families with little opportunity to object. Telecommunications providers, SMUD, PG&E, and Comcast benefit economically from expanding electrical and wireless infrastructure. Meanwhile, children and communities may bear environmental and health risks without informed participation, compensation, or adequate long-term scientific assurances. The profits are privatized, while potential risks are distributed across the public. As a mother, I invest my body, time, resources, and energy into my children's health. Pregnancy, breastfeeding, nutrition, education, and medical care are investments in their neurological development, cellular health, and future well-being. Why should corporations introduce additional environmental exposures without adequately demonstrating their long-term safety for developing children? Children are stakeholders. They cannot negotiate exposure conditions, commission independent studies, or participate in infrastructure decisions. Their inability to consent creates a greater ethical responsibility for adults, corporations, and government agencies. The long-term neurological effects of chronic RF exposure, particularly during critical developmental periods, warrant independent investigation. I am concerned about mitochondrial function, cellular homeostasis, oxidative stress, neurological signaling, reproductive development, and potential intergenerational consequences. The absence of conclusive evidence of harm does not establish safety under every exposure condition. There is also a serious security concern. Telecommunications and electrical infrastructure are increasingly interconnected with digital control systems. Cybersecurity vulnerabilities, unauthorized access, deliberate interference, and malicious manipulation deserve independent assessments. These systems should be protected against misuse, including intentional disruption or hazardous operation. What safeguards prevent infrastructure designed for communication and electrical distribution from being deliberately misused to harm the public? I request transparent cybersecurity oversight, independent vulnerability assessments, enforceable security standards, and public accountability without disclosure of sensitive security details. Under principles of environmental justice, nonmaleficence, intergenerational equity, and responsible stewardship, government must consider every affected stakeholder—not merely infrastructure owners, investors, and commercial beneficiaries. The public should not have to finance private environmental testing, establish individual medical causation, or suffer injury before legitimate concerns receive investigation. I request that HHS recommend a precautionary pause on further wireless infrastructure expansion in residential and child-centered environments pending independent review of long-term developmental risks. I also request evaluation of removal or relocation of existing towers where site-specific evidence demonstrates unacceptable exposure or safety risks. I request independent longitudinal research, publicly accessible exposure measurements, meaningful community participation, and regulatory coordination among HHS, FCC, EPA, and appropriate state authorities. I do not consent to my children being treated as involuntary experimental subjects in an environment where long-term exposure questions remain unresolved. Environmental exposure does not automatically constitute human-subjects research under federal law. However, widespread exposure under scientific uncertainty raises profound ethical questions about informed participation, precaution, and justice in distributing potential harm. No corporation should receive the economic benefits of technological expansion while transferring potentially preventable health and environmental costs to children and future generations without accountability. Our children are not collateral costs of technological progress. Their neurological development, cellular health, bodily integrity, and environmental inheritance deserve consideration before additional infrastructure is approved. I demand that public-health protection take precedence over unchecked expansion, that existing infrastructure be independently evaluated, and that future generations receive the protection and representation they cannot yet demand for themselves. Respectfully submitted, Cherrish “I Do Not Consent” Castaneda Mother of Three | Student of Law and Bioethics Sacramento County, California

It’s horrible seeing my sister in law go through this and feel sick from wireless. They need to research this more, and set real standards for safety and health based on science. The wireless industry is not protecting our health. We need more protection from public health agencies and effort to examine the effects of RF radiation on our health without delay.

1. Who I am professionally: I am a licensed professional counselor and life coach practicing in Texas, mostly in DFW area. More EMF in multifamily residences. I lived in Ft Worth for 16 years and relocated to Dallas in 2025. I have rented an apartment in both cities rather than owned or rented a home. This is important to mention because from my personal apartment, I have been within range of as many as 25 other residents’ Wi-Fi sources. Which means I have been within range of the effects of the EMF from their wireless devices. My experience in the Ft Worth apartment homes was with high magnetic EMF and somewhat lower RF inside my unit. The most significant measurements for EMF are from my current apartment home in Dallas. At my current apartment, there are 11 smart meters located approximately 6 ft. from my bed mounted on the outside wall of the building and located outside the bedroom of the unit directly below me. The measured RF in my bedroom is higher than I’ve ever lived with before. They range from 600-1500 uW/m2 at the level of the bed and 400-4,000 uW/m2 at the level of the floor. Both of these values register either in the severe or extreme range for frequencies recommended for sleeping areas. The highest levels are in the living area. They range from 19,000 uW/m2 – 40,000 uW/m2 and are located over the location of the wi-fi device in the unit below mine. Other averages in the unit are from 400-24,000 in the living/dining areas. 2. What I have observed and experienced physically: First, I want to state that I have prioritized my health since I was 13 years old. Committed to exercise, healthy diet, outdoor activities, good choices for indoor activities, friendships, etc. I’ve lived a healthy life. I’ve had no need for regular prescription medications other than an occasional antibiotic when I was in my teens. I’ve been fortunate to sleep well, feel energized and motivated, and live a healthy mental/emotional life. Since the jump to 4G and especially 5G, and in the residences I’ve been living in, I’ve experienced the following: • Sleep disturbance • Anxiety (never before in my life had I experienced anxiety) • Restlessness • Cognitive slowing that is more noticeable when I’m home a lot. • Appetite reduction and general decline in interest for food. • Increases in cholesterol readings, A1C (even though I Never eat sugar foods), and unwanted weight loss. These are VERY unusual for me. 3. What I have observed professionally: My practice has focused and worked primarily with high-functioning adults, many of which are professionals. They range in age from 30-55. Most of them are committed to their physical, emotional, and mental health beyond that of the average person. My exposure to adults of all ages in a wide range of life stages and demographics offers me the opportunity to NOTICE common frequent signals that inform me about my clients and perhaps the population in general. Most of the clients that have reported the experiences below have also reported that they seem similar patterns in their friends and family. They recognize these in themselves and also in those around them. Since 2022, I’ve witnessed clients presenting with: greater sleep disturbances increase in relationship challenges and less ability to understand each other profound anxiety increase—prevalent throughout my practice greater sense of entitlement difficulty including the needs of others increased need for somatic calming exercises but less ability to remember them. I’ve also witnessed and observed more: mood impulsivity/less ability to self-regulate emotionally less memory about the previous session (even when it was the prior week) less ability to organize information and create structure for themselves I anticipate that the COVID shutdown precipitated/contributed to some of these, but even after the pandemic was over and people had been back to a normal schedule for some time, these observations have continued to escalate—more and more prevalently. What I observe in the youngest people: My exposure to the youngest of our population is not as frequent as with adults. What I’ve witnessed is a lack of or significant reduction of social skills. Play is impacted by lessened creativity and lessened spontaneity. 4. Precautionary Approach I have no proof that EMF/RF is responsible for my clients’ changes in behavior, nor for the physical and mental changes I’ve experienced—other than the concurrent timing of them. However, facts about 5G is that it brings wider frequency channels, more information per wave, more antennas signaling individual devices, and more “small” cells creating “densification” which is clearly changing the experience of exposure at close range—in homes, workplaces, apartment buildings. I urge HHS to find ways to reduce EMF exposure to below existing limits NOW.

I have been aware of health risks from Electromagnetic Fields (EMF) and RF wireless radiation for many years. Here is a website that has a list of research links for your consideration: https://ehtrust.org/send-science-to-the-fcc-govt-is-asking-for-evidence-you-can-help-now/ Because I have been aware of the dangers, to the best of my ability, I have created a safe environment for my husband, our son, and I where I can better control the RF wireless radiation levels inside of our home. We do not have WIFI in our home and haven't for years. We have internet but we have it safely hard-wired. We kindly ask anyone entering our home to please turn off their Cellular Data, Bluetooth, and WIFI on their phones and tablets as my husband and I do the same. Rarely do we need to use the internet on our phones but if we do, we do it quickly and away from our son and then once we are done, we make sure to turn it back off, immediately. We have asked our neighbors to apply faraday cages on their digital meters and they gladly obliged. We take all these measures, and I could go on listing more, because we are aware of the dangers of exposure to EMF and other sources of RF wireless radiation. We do the best we can, to control what we can, knowing once we leave our house, it's a battle zone of cell towers, cell phones, wireless and digital “smart” utility meters, public Wi-Fi, and other sources of RF wireless radiation. The last thing I want on or around my home and my child is a cell tower or wireless smart meter. I am completely opposed to 2-way wireless "smart" utility meters, digital utility meters, and opt-out fees. Wireless smart meters are data collecting devices that were forced on Americans and they emit harmful radiation. I have participated and continue to participate in state and national campaigns asking for utility meter choice legislation. I have collected signatures of Ohioans opposed to these meters and have sent them to state lawmakers. Here is a link for a national campaign for utility meter choice legislation: https://childrenshealthdefense.org/community-forum/support-utility-meter-choice/ I have filed several complaints already about smart and digital meters with the Public Utilities Commission of Ohio (PUCO) to only be ignored. I do not like the wireless smart meter "opt out" option that we currently are offered because it cancels our own rights when we do so. With this option, we’ve had to AGREE to ALLOW utility providers and unknown 3rd party companies, to violate our constitutional rights – so we are legally consenting to being violated. Why should my "option" (opt out) be coercion to violate my own rights? That doesn't seem like an option to me. I have sent the CEO of my gas and electric utility provider, AES an Affidavit of Truth stating many points of intent to harm and multiple violations to my rights and I’ve received no rebuttal. Because I received no rebuttal, my affidavit stands as truth. Listed in the affidavit are my constitutional rights that have the potential to be violated, if I am forced against my will, into a smart or digital meter. I know my family’s health will 100% be affected by these types of meters. It’s not a matter of IF, but WHEN, we will be sick as long as we have it, being forever. We want old-fashioned analog meters but we have been forced to settle for digital meters (for which we pay opt-out fees) which are safer than smart meters but still not as safe as analog meters. Over 1,000 peer-reviewed scientific studies have demonstrated serious adverse health effects from the wireless radiation coming from cell phones, cell towers, and the "smart" meters radiating our homes and other buildings 24/7. This includes DNA damage, infertility and reproductive damage, cardiac effects and arrest, neurological conditions (anxiety, depression, Alzheimer's), immune system dysfunction, and even cancer. The FCC was sued in 2021 for failing to update their safety guidelines for human exposure limits that were established in 1996 when we were using 2G wireless technologies, not the 4G and 5G we have today. The lawsuit was successful, but all these years later the FCC still has not responded to the courts and is refusing to regulate the Telecoms. The reality is NO ONE is measuring our cumulative daily human exposure of EMF “electro smog” coming from all of our current sources of wireless radiation including 4G/5G “mega” towers, 5G small cells, and the EMF pulsing Smart meters attached to our homes. https://ehtrust.org/in-historic-decision-federal-court-finds-fcc-failed-to-explain-why-it-ignored-scientific-evidence-showing-harm-from-wireless-radiation/ I ask that HHS make more Americans aware of risks from wireless devices and infrastructure so they can create healthier homes and communities for their families too. Thank you for accepting my comment.

As an American physician, I am deeply concerned that U.S. electromagnetic field (EMF) exposure standards have not been updated since 1996 and address only thermal effects. In a rapidly evolving wireless environment, outdated guidelines warrant rigorous reassessment. Current permitted exposure levels exceed recommendations from building biologists and most other countries. As cell towers, 5G, Wi-Fi, Bluetooth, smart meters, electric vehicles, and other wireless technologies proliferate, finding places with reduced exposure is increasingly difficult for sensitive individuals. Dismissing validated non-thermal effects simply because this radiation is non-ionizing ignores biologically important interactions. My own experience with electrohypersensitivity (EHS), since 2017, has included insomnia, migraines, lightheadedness, trigeminal neuropathy, and tinnitus, associated with nearby Bluetooth devices, cell towers or transformer stations. I reduce exposure to cope: avoiding housing near towers, limiting Bluetooth, using wired headphones and computer peripherals, keeping devices on airplane mode, disabling Wi-Fi overnight. I have had to leave certain hotels and forgo modern conveniences such as smart-home devices and electric vehicles. Even ordinary appliances increasingly incorporate unnecessary and unavoidable wireless or bluetooth connectivity (air filters, electric toothbrushes, etc), making exposure reduction difficult. The expansion of data centers is concerning due to EMFs from the facilities themselves and associated high-powered electrical infrastructure. Public participation in decisions about cell towers, power lines, and data centers is extremely limited (my own community fighting a data center build with the guise of public input,) leaving residents with little control over exposures. My patients have described a range of concerning experiences: man in his 40s with occupational exposure linked radiation-associated cancer; mid-aged female with cognitive decline and severe EHS after a transformer was installed near her home; a veteran whose military exposures have forced him into homelessness and food insecurity in Minnesota's winters as he can't tolerate electricity; and a couple with sudden insomnia after a smart meter was installed outside their bedroom, resolved after its relocation. In my clinical experience, commonly reported symptoms include insomnia, headaches, neuralgias and arrhythmias, which can substantially affect quality of life. These accounts warrant compassionate care and further investigation, not the ridicule and diagnosis of "functional" symptoms that have accrued. Specific absorption rate (SAR), commonly used to assess radiofrequency exposure, has serious limitations. Standardized testing doesn't represent real-world conditions- device position, body shape, tissue density, age, or differences between men, women and children. Furthermore, the cumulative effects of living in a highly connected environment remain insufficiently characterized. Exposure can come from multiple sources simultaneously, including phones, 5G infrastructure, Wi-Fi, Bluetooth, computers, televisions, smart meters, electric vehicles, chargers, and electrical systems. Compliance with individual-device limits does not necessarily resolve questions about combined, long-term exposure. International exposure standards vary, and some countries impose magnitudes of power greater restrictions on EMF exposure limits and wireless infrastructure near sensitive locations such as schools and hospitals. National Toxicology Program animal studies have brought concerns of chronic cell-phone radiation exposure and cancer risk, the need for additional human research, and the outdated nature of U.S. standards. Resources such as Physicians for Safe Technology discuss these issues as well. Biological mechanisms of harm include changes in oxidative and nitrosative stress, mitochondrial dysfunction, blood-brain barrier permeability, genotoxicity, immune-system effects, cell-membrane signaling, voltage-gated calcium-channel activity, inflammatory pathways, magnesium depletion, nitric oxide signaling, changes in neurotransmitters and receptors, including NMDA, dopamine, and serotonin, microbiome alterations, hepatic lipid metabolism and blood glucose regulation, mast-cell activation, depletion of antioxidants such as glutathione, oxidation of LDL cholesterol and altered prenatal brain development and fertility. These proposed mechanisms could have implications for neurological, cardiovascular, hormonal, metabolic, immune, and reproductive health. I urge updated, independent, and transparent reviews of standards regarding long-term, cumulative, and real-world exposures. Protecting public health requires neither dismissing patients' experiences nor the scientific data that exists. It requires rigorous science and standards that evolve alongside technology and it's unfathomable that no meaningful updates have been made in 30 years.

Comment of the Coalition of Mothers, Rebekah Ricks, President and Co-Founder, Winter Haven, Florida, in Docket HHS-OASH-2026-0397. Our letter is attached. It responds to Questions 9 and 15(a) as numbered in the notice. Florida shows the gap. Florida now generally bars elementary and middle school students from using their own wireless devices during the school day (s. 1006.07(2)(f), Fla. Stat., as amended by Ch. 2025-109, Laws of Fla.). Our state has decided that a child's phone at school is a question of public policy. Yet the district's own wireless access points, which transmit whether or not a child's phone is off, are not addressed. We searched chapters 1001 through 1013 of the Florida Statutes and chapter 6A of the Florida Administrative Code and found no requirement that a district tell parents what wireless equipment operates in their child's classroom. A Florida mother can learn the school's rule on her child's phone. She cannot learn what is installed above her child's desk. Question 9. We ask the Department to recommend a short notice that schools and licensed child care providers post for parents, listing the wireless equipment in each classroom, when it operates, whether a wired option exists, and whom to call with questions. Disclosure makes no health finding. It treats parents as the decision-makers they already are in every other part of school life. Question 15(a). No federal agency publishes the number of transmitters within a defined distance of a school or licensed child care facility, and no federal agency has measured RF levels in an occupied American classroom. We ask the Department to make both a research priority, and to give particular attention to rooms serving the youngest children. We support the fuller comment filed in this docket by Protection of the Educational Rights of Kids (PERK), which addresses the remaining questions with primary-source citations. Prepared by Rebekah Ricks. Contact: rricks@thecoalitionofmothers.com.

I am submitting as an individual with several years of hands-on radiofrequency field-measurement experience in Flushing, Queens, New York City. I respond to Questions 2, 7, and 8. Q2 — Perspective: I am a citizen measurer, not a clinician, researcher, or industry professional. Everything below comes from my own field measurements with a handheld GQ EMF-390 multi-field meter (manufacturer-stated RF range 10 MHz–10 GHz, three-axis sensor, peak-hold on), not from peer-reviewed research. I make no claims about health effects; my contribution is measurement methodology and real-world observation. Q7 — How real-world exposure is measured in practice: I measure with a handheld GQ EMF-390 multi-field meter (manufacturer-stated RF range 10 MHz–10 GHz, three-axis sensor), peak-hold on. Across several evening sessions at home in Flushing, live RF power-density readings sat between 2.3 and 19 mW/m², while the meter's peak-hold repeatedly captured short electric-field spikes far above the live number — 77, 100, 139 and 397 V/m, and 1002 V/m in one session; a daytime outdoor session captured 725 V/m. The device's spectrum view labeled the dominant activity "WiFi/Phone," but I was unable to verify the specific source of the repeated peak spikes — their origin is unidentified. Two practical observations: (1) the peak number and the live number on the same meter, seconds apart, can differ by orders of magnitude, and compliance-style time-averaged measurements report only the latter; (2) there is no public dataset capturing what a person experiences at home or at a bus stop with a phone in hand, versus what a compliance measurement at a fixed distance, height, and averaging time reports. Q8 — How exposure could be measured better: (a) HHS should publish a standardized, low-cost field-measurement protocol — instrument class, detector, resolution bandwidth, sweep settings, and averaging time — so that citizen measurements are comparable across people and places; (b) both peak and time-averaged values should be reported and disclosed side by side, since the public only ever sees one number; (c) HHS should maintain a public repository for citizen-collected measurement data with location and timestamp, so real-world exposure maps can be built from thousands of independent readings instead of relying solely on carrier compliance filings. Q18 — One clear request: recognize citizen-measured RF exposure data as a complement to compliance data, not a replacement. The people who live under the antennas are willing to do the measuring; what is missing is a standard that makes their measurements count. Sources: my own field measurements as described above. No medical or personal identifying information is included, per the notice's instructions.

I am Robert J. Berg, the principal of the Law Office of Robert J. Berg PLLC. My law firm specializes in representing persons seeking the responsible siting of wireless communications facilities. Essentially, our clients oppose the placement of cell towers and other wireless facilities in residential neighborhoods, near schools, day care and senior centers, parks, ball fields, nursing homes, and similar areas where people live, recreate, or spend considerable time. Their concern primarily is that the health risks of non-consensual exposure to wireless radiation 24/7 are considerable and needs to be minimized or prevented if possible. Unfortunately, when Congress passed the Telecommunications Act of 1996, it acceded to industry's demand that State or local law is preempted if it denies a permit for the installation and operation of a wireless facility based on environmental concerns of the effect of wireless radiation exposure so long as the RF levels are within the FCC's RF emissions guidelines. Thus, federal law prevents our clients from raising health and environmental concerns when objecting to the siting of cell towers and other wireless facilities in their communities. Our clients then must rely on the FCC to be the guardian of their health with its RF emissions guidelines. Sadly, the FCC has refused to update its 1996 emissions guidelines despite many thousands of peer reviewed published scientific studies showing serious health and environmental impacts from exposure to wireless radiation from cell towers and cell phones and other wireless products. The FCC's 2019 decision to end its inquiry on a proposed rule-making inquiry to revise its 1996 guidelines was challenged in the DC Circuit, and the Court ruled that the FCC's decision, in large part, was arbitrary and capricious. The Court remanded the matter, in part, to address the questions posed by the Court and to reconsider the scientific literature. The FCC cannot be trusted. It has admitted that it has no expertise in the health, environmental, and medical issues. The FCC will need to rely on HHS's expertise. We are very fortunate that HHS is engaging in an analysis of the health issues relating to wireless radiation, and we applaud HHS for undertaking this important work. Thank you.