Exposure limits & oversight

HHS seeks to update the record on whether the science on the effects of RF radiation has changed since the FCC considered this question in 2019. I herein submit comment as City Councilmember of Monterey, California, representing a constituency very concerned and knowledgeable about the abundant studies since both 1996 (the date of the FCC’s holding on exposure limits) and 2019, when the FCC held there was no appreciable change in the science. Two areas stand out to me as having changed and as areas of concern as a parent, grandparent, and Certified Nurse Midwife: 1) the impacts on children, and 2) the ubiquity of wireless devices. One study, Microwave Emissions from Cell Phones Exceed Safety Limits in Europe and the US When Touching the Body (https://ieeexplore.ieee.org/document/8688629) notes that emissions exceed recommended limits when in contact with the body. I have observed babies clutching phones and devices and resting them directly on their bodies. We know that, unfortunately, devices are used as babysitters, replacing humans interacting with infants. We have all seen children as young as one holding and staring at devices powered by radio emissions. These children, in playing with devices, ignore their environment at an age (such as 1 year old) when learning the nuances of human interaction and the rewards thereof are essential milestones in their development and in their ability to survive through social bonding. Additionally, our children are exposed to higher lifelong levels of radio-wave radiation than we have ever studied. Infants today are exposed to much more than previous generations. Authors AK Lee and HD Choi document that a child’s brain absorbs more cell tower radiation than an adult brain due to such factors as the smaller head of a child and hence less density and due to the thinner skull relative to adults, resulting in higher localized absorption of RF energy (EMF exposure in Korean mobile communication networks. 2023) For the safety of children , we must welcome review of the last 30 years of science. The health of our children depends on review of current science. https://www.sciencedirect.com/science/article/abs/pii/S0160412017319724

2.I am responding as a healthcare provider. The federal limits for human exposure to radiofrequency radiation were adopted by the Federal Communications Commission in 1996. n 2013 the FCC itself asked whether the limits should be revisited. In 2019 it answered: no. Environmental Health Trust, Children’s Health Defense and others sued. On August 13, 2021, the U.S. Court of Appeals for the D.C. Circuit ruled that the FCC’s decision was “arbitrary and capricious.” The court found the Commission had failed to respond to “record evidence that exposure to RF radiation at levels below the Commission’s current limits may cause negative health effects unrelated to cancer,” had failed to address the impacts on children, long-term exposure, and the ubiquity of wireless devices, and had shown “a complete failure to respond to comments concerning environmental harm.” It noted roughly 200 comments from people reporting illness or injury that the agency had not addressed. It sent the matter back to the FCC with instructions to explain itself. (Environmental Health Trust v. FCC, No. 20-1025) 18. (https://greenmedinfo.com/problematic-action/electromagnetic-field-harms) The FCC had relied on the Food and Drug Administration’s assurance that the limits were fine. The court said an agency cannot lean on another agency’s conclusion if that conclusion comes without an explanation. 3g. Five years later, no explanation has been produced. https://greenmedinfo.com/problematic-action/electromagnetic-field-harms Recommendations (m). I recommend (1) a validated clinical intake instrument for suspected RF/EMF-related complaints; (2) a federal adverse-event intake comparable to MedWatch; (3) biomarker studies in symptomatic patients following the oxidative-stress findings of Irigaray, Caccamo & Belpomme (Int J Mol Med 2018, https://pubmed.ncbi.nlm.nih.gov/30015864/); and (4) exposure-measurement studies that do not rely on self-report, following Bogers et al. (Environ Int 2018, https://pubmed.ncbi.nlm.nih.gov/30227317/).12. https://pubmed.ncbi.nlm.nih.gov/31540320/ (Adams et al., Environ Int 2014, https://pubmed.ncbi.nlm.nih.gov/24927498/; Liu et al., Andrology 2014, https://pubmed.ncbi.nlm.nih.gov/24700791/) and exposure reduction is low-cost. The peer-reviewed record on 5G, 6G, satellite, IoT and smart-meter exposures is thin (Simkó & Mattsson, Int J Environ Res Public Health 2019, https://pubmed.ncbi.nlm.nih.gov/31540320/, concluded available studies "do not provide adequate and sufficient information for a meaningful safety assessment"). This is a gap, not a reassurance.(https://pubmed.ncbi.nlm.nih.gov/34047144/; https://pubmed.ncbi.nlm.nih.gov/34243228/); Balmori, Sci Total Environ 2015 (https://pubmed.ncbi.nlm.nih.gov/25747364/).

I appreciate the opportunity to share my comments. I have followed the format of your questions. 2: I am responding as an individual injured by RF/EMF. Additionally, my spouse has been severely injured by RF/EMF. 3a: As to my history with RF/EMF…As a requirement of my job, I was an early adopter of cell phones. I also worked in an office environment with wi-fi. I lived in a house with a smart meter until we had it removed in 2011. 3b: I was exposed daily to wireless radiation at work and at home with a smart meter. 3c: As a result of holding a cell phone to my head in the late 1990s, I developed a brain tumor right behind my right ear – exactly where I held my cell phone to my head. Fortunately, it continues to be benign, however it was growing so rabidly that I needed radiation treatment to slow its growth. It is stable now but must be regularly monitored. This is the only health effect that has manifested for me, however it is unknown what other injuries I may have that have not yet been detected. 3d: My brain tumor was discovered in 2000. I immediately stopped holding a cell phone to my head and only used it when absolutely necessary. 3e: I saw multiple neurosurgeons and had many diagnostic tests. My diagnosis was confirmed of meningioma. I have to have MRIs every 2 years now to monitor the tumor. The Mayo clinic sites radiation exposure as a potential cause for this type of tumor. Is it a coincidence that on that spot on my head where I held my phone is where my tumor grew? 3f: I stopped holding a phone to my head and also greatly reduced the usage of cellular phones. Also, with my spouses’ EHS, we removed all the sources of EMF in our house. My tumor has been stable for over 20 years, but because of my injury – I have the ongoing expense of monitoring it. With regard to recommendations to HHS, I would share the following: - Regulate the amount of radiation/power that mobile phones can emit - Update the standards for “safe” exposure. The current FCC SAR limits are ridiculously outdated and the science has been proven that they are not sufficient - Enforce better notification to the public about the hazards of wireless radiation from all sources (wi-fi, phones, smart meters, smart watches, IoT devices, bluetooth devices, etc.) I have included some studies that support the science that RF / EMF causes cell disruption that can lead to tumors

I urge HHS to prioritize the health of people, animals, and ecosystems when evaluating cellphone-tower radiofrequency emissions. As a parent and concerned member of the public, I support independent investigation of sustained exposure, prompt correction of exposures shown to be harmful, and research into safer transmission methods. My central proposal concerns the frequencies and transmission characteristics emitted by cellphone towers themselves. I ask HHS to investigate whether carefully defined changes in carrier frequency, modulation, power, antenna configuration, or operating schedules could reduce adverse biological effects. I also support rigorous investigation of proposed harmonic transmission methods for any measurable biological benefit. “Harmonic” expresses my aspiration for technology compatible with living systems; a healing claim must be demonstrated through independently replicated research. Please evaluate repeated and long-term exposure under realistic conditions, including exposure from multiple transmitters. Studies should document frequency, intensity, duration, peaks, and changes in network traffic. Measurements should represent homes, schools, childcare facilities, workplaces, farms, and wildlife habitats. Distance from a tower alone should not substitute for an exposure assessment. I request particular attention to children, pregnant people, workers with elevated exposure, and people with implanted medical devices, using evidence appropriate to each group. People reporting symptoms they associate with wireless environments deserve respectful medical evaluation and careful investigation. Reports should inform research without prematurely assuming or dismissing a causal connection. Animal findings warrant serious scrutiny. The National Toxicology Program reported heart schwannomas in male rats under its experimental RF exposure conditions. Falcioni and colleagues’ 2018 study of lifelong exposure to a 1.8 GHz GSM far field reported increased heart schwannomas in male rats at the highest exposure. These findings support further investigation; they do not directly establish the risk to humans living near modern towers. Human evidence, animal findings, and exposure differences should be evaluated transparently together. Ecological protection should be an explicit research priority. Please study relevant outcomes in pollinators, birds, livestock, plants, and aquatic organisms, including survival, reproduction, navigation, growth, and ecosystem function. Account for pesticides, habitat loss, artificial light, disease, weather, and other influences. Insect absorption models and bird electromagnetic-noise experiments raise specific research questions, but should not be generalized into proof that all cellular emissions harm wildlife. If credible evidence identifies harmful exposure, agencies should act to reduce it and verify that corrective measures work. Communities need accessible exposure reports, independent measurements, a clear complaint process, and timely explanations of findings. Research funding, conflicts of interest, methods, and negative results should be disclosed. Protective decisions should be accountable to evidence and public well-being. Proposed beneficial tower transmissions require equally rigorous evaluation. Researchers should specify the signal, compare it with matched conventional and sham exposures, control absorbed energy and temperature, and directly measure benefits and adverse effects. Any therapeutic application should undergo appropriate ethical and safety review before deployment. The research summarized in my accompanying document does not establish a tower frequency that heals people, animals, or water. My broader interest includes harmonious music, bells, singing bowls, prayer, and restorative environments. Music research supports benefits for selected outcomes such as pain and anxiety. These findings do not prove that musical frequencies carried by a wireless network make its RF emissions therapeutic. I also request fair, independent testing of hypotheses inspired by Masaru Emoto’s water-crystal work. Crystal appearance or changes in water spectra alone cannot demonstrate improved water quality, ecological restoration, or human healing. Please prioritize technology that serves life: investigate potential harm honestly, correct demonstrated problems, publish understandable evidence, and test promising alternatives without commercial pressure or predetermined conclusions. I support a responsible path toward safer, more biologically compatible communications infrastructure, including rigorous investigation of harmonic transmission proposals. My accompanying research document provides supporting sources, limitations, and detailed recommendations.

Dominion Energy is our power company and they forced us to install a smart meter on our home even though we did not want one. They claimed I denied them access to their equipment which is untrue. They came to our home on 4-5 occasions asking/wanting to install the smart meter. I told them I had real concerns about the technology and did not want the so called "upgrade." Upon receiving Dominion Energy's initial notification of the upcoming smart meter change, I promptly called their office and told them I did not want them change my meter. My request fell on deaf ears. For about a month later, Dominion Energy sent out a 3rd party contractor to swap everyone's meter in our neighborhood. When I asked them if they had received my request they said did not. The subcontractors instructions were to replace everyone's meter. At that time, I explained to the contractor I had chosen not to upgrade and he said okay and went onto the house. At that time, Dominion offered a so called "detuned" smart meter for an additional cost, unless your doctor completed a separate medical exemption form. Since I do not like any smart meter technology.. I did initially choose that meter either. For I was perfectly happy with the performance of my existing meter and determined there was no benefit for our household to do so. Over roughly the next 12 months, on 3 or 4 different occasions, they sent the same installer to our home wanting to do the smart meter install. I told their representative I/we did not want the meter, but never denied them access to their equipment mounted on our home. For them to claim I did is a lie. Their installer asked to see the meter and I granted permission and went back in the house. They had full unmolested access to their equipment on every occasion. The meter base is within 15 feet of where we sleep. The meter is located on the exterior side of the same wall our headboard is located on. Due to its close proximity to our bedroom... I was very concerned about how the smart meters EMF emissions negatively impacts human health, amongst other things. On March 24, 2026 I received an email from a Dominion Energy employee named Cindi G. Hux (Customer Relations & Policy Business Consultant). She threatened to cut off our power and gave us a 10 days notice to comply. I had until April 6, 2026 to schedule the installation. Since I work full-time from home, I/we had no other option but to comply. For I/we did so under duress, for I could not jeopardize my livelihood over this dispute. See my attachment for that conversation. After being coerced and forced to comply, the smart meter was installed on our home on or before April 15, 2026. Since that time, my wife has had ongoing lingering inner ear related health issues that her doctors are unable to diagnose. My wife is 68 years old and started getting migraines out of the blue along with having a general feeing of malaise and being disoriented. She complains of ear fullness, dizziness, nausea with gagging, and the inability to sleep or drive a motor vehicle. Up until the smart meter was installed, my wife was in perfect health, took zero prescription medications and drive a motor vehicle safely. As time went on, her symptoms have become worse. For the last 3 or more months, she not had a full nights sleep. She has been to her ENT on two different occasions, her PCP on one other occasion and her Chiropractor every week. During her 1st ENT visit, the doctor sent her to a Vestibular Therapy twice a week. That went on for over two months. On the 2nd visit, the doctor prescribed her a steroid for ear fullness issue. Also, her PCP prescribed her Imitrex and an antibiotic for her migraines her ear fullness issue to see if that would help. She read online that cervical related issues can cause some of these symptoms, so she asked Chiropractor & the office message therapist to focus on her neck. Despite all this treatment her symptoms remain and continue to worsen. I too get periodic migraines and have been prescribed Imitrex for several years for other reasons. My health is relatively stable compared to my wife's. We have since requested the detuned meter from Dominion Energy but they denied our request, would not accept their medical exemption opt out form, completed by doctor. They are retaliating against us because I would not allow them to swap out the meter originally. If consumers want to complain or have concerns they are directed to contact the Office of Regulatory Staff at 803-737-5230. I spoke to someone named Greg in March or April of 2026. He did nothing and in appears to be cahoots with the power company. They along w Dominion need to be investigated. Consumers need more protection and the ability to opt of EMF generating smart meter devices on their homes and reduced exposure for while out in public from high powered EMF generating devices such as cell phone towers. Respectfully, Mark and Donna Kuzia

See attached file(s) IEEE Standards Association's 2019 guidelines to Human Exposure to EMF. Small edits were added in 2022 called "Corrigendum 2". Corrigendum 2 was appended to the standard as of June 29, 2022. This corrigendum addressed technical corrections, specifically fixing Figure 1 and Figure 2 in the original 2019 document which were found to be incorrect. Corrigendum 1 (C95.1-2019/Cor 1-2019) was incorporated directly into the 2019 publication and did not appear as a separate standalone standard. The core exposure limits and scientific basis established in the 2019 edition remain the active standard, with these corrigenda serving as necessary technical amendments to the documentation. 2019 IEEE Standards Association's guidelines remain the standard of safety reference still currently being used in the United States. Other countries however have their stricter safety standards applying to EMF exposure levels. France for example has more stringent safety standards and it is rumored that one of the latest iPhone models is banned from retail sale due to being too powerful and operates higher than European safety standards. Please have your professional staff reference the 2019 IEEE guidelines attached, I'm sure the staff has seen/heard of this standard before. Also ask staff to explore the safety standards in other European nations. With the rollout of 5G cellular networks in European states/countries, also came the beginnings of physical and mental health effects believe to be originated from 5G towers. Complaints are very similar to the now widely recognized "Havana Syndrome" or Anomalous Health Incidents.

there is no convincing scientific evidence that exposure within established safety limits causes harm to humans

I am submitting these comments in two capacities: 1. As an individual: Based on my personal experience with Wi-Fi and my concerns regarding potential health effects associated with wireless radiation. 2. As a board member of The Civil Health Rights Movement May Day, Denmark: My comments also draw on a legal opinion obtained in 2019 concerning the deployment of 5G in Denmark. The legal opinion references numerous scientific studies. I have included its conclusion below and attached the full document for reference. 1) Individual consumer Question 3 Seven years ago, I spent approximately six hours a day working at my computer for about a week on a major project at my summer house. I had just received a new router (TP-Link) for my fiber net and was very happy that the whole set-up worked so well out in the middle of nowhere. I was writing on my computer and the Wi-Fi was on as I had to be in constant communication with several people all over the country, and I was well connected. Then after three days, I woke up with an overwhelming tinnitus and pressure headache. I wondered for a day why this had suddenly come and then I realized it was probably the radiation from the Wi-Fi. I managed to cut the Wi-Fi and get a cabled solution instead. After 4-5 hours in a Wi-Fi free environment and a walk by the beach, the tinnitus was gone and since then I have experienced the same on tests: 2-3 days in a Wi-Fi environment and the tinnitus and headache turns on. Now everything in my house is cabled. No medical doctor or medicine was involved. No measurements were done at the time. 2) Member of The Civil Health Rights Movement May Day, board member (Denmark) Question 12 and 18 I would like to draw attention to a legal opinion entitled LEGAL OPINION on Whether it would be in Contravention of Human Rights and Environmental Law to Establish the 5G System in Denmark obtained in 2019 by May Day and other stakeholders in Denmark. The opinion examines scientific studies relating to potential health and environmental effects of radiofrequency electromagnetic radiation, including exposure within the limits recommended by ICNIRP. The conclusion of the legal opinion is reproduced below. The full document is attached as supporting material. “It is the conclusion of this legal opinion that establishing and activating a 5G-network, as it is currently described, would be in contravention of current human and environmental laws enshrined in the European Convention on Human Rights, the UN Convention on the Rights of the Child, EU regulations, and the Bern- and Bonn-conventions. The reason is the very significant body of scientific documentation available, showing that radio frequent electromagnetic radiation is harmful and dangerous to the health of humans (particularly children), animals and plants. This also applies when the radiation remains within the limits recommended by ICNIRP and currently used in Denmark as well as broadly within the EU.” Charlotte, Denmark

I live in a small Canadian town that did not have 5G. Suddenly the 5G icon appeared on my work issued phone and I knew that it had been activated here without any warning or consultations. I grabbed my Safe and Sound 2 meter and went out and found the small cell located on a telephone pole at the end of street. The readings on my meter were in the "Extreme" range which means you should immediately leave the area. My house is about 150 ft from the small cell which is located between 2 residential homes, one of which has young children. I took a picture of it and sent it to my city council office. They didn't even know what it was or who it belonged to. After a 2 week investigation, they reported back that it was the property of a local internet provider Rogers Communications. Next, a neighbour contacted me to ask about a truck with a 50 foot antenna that was parked in front of my house while I was at work. This turned out to be a test being run by the Canadian Federal Government Communications Research Centre to "check levels". My house is about 150 ft from the small cell which is located between 2 residential homes, one of which has young children. The fact that the residents and city councilman were not even made aware that these small cells were being installed is outrageous. He said it's because telecommunications are under the Federal Government's responsibility. One of the homes beside it is now up for sale and the 2 homes beside That have already sold. It does seem odd that 3 homes in a row would all sell at the same time but now I'm speculating. I do everything I can to protect myself from the well known health hazards of EMF. That could have been installed outside me bedroom window and I would have had no say. This is deplorable! This technology and infrastructure is very dangerous and does not benefit those who have to live in its vicinity. It benefits corporations and the government while harming us. I am sensitive to EMF and would have had to move if they had installed next to me. The fact that the residents had no warning and were not given any opportunity to speak out is shameful government overreach especially when we know that safe levels of exposure have not even been established or properly tested for health. Profit over people is unacceptable and needs to be stopped.

Re: Docket HHS-OASH-2026-0397, Request for Information on EMF/RF Exposure Question 2 (Perspective): I'm responding as an individual and family member. My husband and I are adults in our fifties who have dealt with RF exposure in our homes for many years. This response is based on our personal experience and our own measurements taken with a consumer RF meter. Question 3 (Experiences): a. Sources: wireless infrastructure (a small-cell node that was later replaced with a much larger unit), and rooftop solar systems on rental homes. b. Exposure: Over several years, we reduced RF in our Los Angeles bedroom to about 1 to 5 µW/m². Then the small-cell node outside our apartment was replaced with a unit about the size of a refrigerator. Our meter then read about 10,000 µW/m² in our living room and 30,000 µW/m² on our front step. In later rentals with rooftop solar, we measured very high readings in the bedroom. c/d. Health effects and timing: We both experienced increased inflammation, migraines and headaches, hormonal imbalance, trouble sleeping, fatigue, brain fog and difficulty concentrating, a persistent buzzing sensation and ringing in the ears, skin tingling or burning, heart palpitations, dizziness, irritability and anxiety, and joint and muscle aches. These began to ease once we reduced our bedroom exposure to 1 to 5 µW/m², and they returned after the larger node was installed. We now rent a home with rooftop solar panels, and all of these symptoms have come back. f. Steps to reduce exposure: While our bedroom stayed at 1 to 5 µW/m², we saw our health start to improve. Since the larger node went in, finding low-exposure housing has been a constant struggle, especially in the DC area. Question 5n (Regulatory changes): Exposure limits and siting rules should account for long-term, close-range residential exposure from infrastructure placed next to homes. That includes enforceable setbacks from bedrooms and living spaces. Question 9 (Disclosure): Residents should get advance public notice when wireless equipment near their homes is installed or upgraded. That notice should include the frequency bands and expected power levels. Rental listings should disclose nearby antennas and rooftop solar inverters. Question 15 (Infrastructure): Please study how small-cell deployments and their upgrades affect actual exposure inside nearby homes. In our case, one equipment swap raised the reading in our living room by thousands of times. Question 16 (Research priorities): Which frequency bands, signal types, and exposure levels are linked to harm. Practical, evidence-based ways for people to reduce their exposure at home. How people recover after exposure is reduced, and clinical guidance for doctors seeing patients who report these symptoms. Enforcement, meaning keeping bands found to be harmful out of residential areas. Thank you for considering this comment.