26110083452
https://www.fcc.gov/ecfs/filing/26110083452

Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Reassessment of Federal Communications Commission Radiofrequency Exposure Limits and Policies ET Docket No. 13-84 To: Secretary, FCC Comments: Jean Lemieux, President of the Massachusetts Association for the Chemically Injured, Inc. submits comment in the above-captioned proceeding. I, Jean A. Lemieux, am providing comment on behalf of the members of the Massachusetts Association for the Chemically Injured (MACI), a volunteer, non-profit statewide support, education and referral organization for people with Multiple Chemical Sensitivity on the proceeding of FCC Docket 13-84. The Massachusetts Association for the Chemical Injured’s comment centers on the issue of EMFs, wireless (RF) technology and potential health effects and harms experienced from the EMF and RF exposure from a general population public health perspective and specifically for vulnerable segments of the population, including those living with Multiple Chemical Sensitivity/Intolerance and those who are electrically sensitive (EHS)/EMR-S. My position on the current proceeding focuses on its reassessment of FCC exposure limits and policies that address the following: 1). a complete review of all of the science, inclusive of the biological health effects in the non-ionizing exposure category that has accumulated ii this docket and past one. FCC needs to review for reassessment the vast amount of research and scientific evidence that had been submitted in response to an update of new FCC guidelines and public health policy. 2). MACI’s comment on this proceeding will demonstrate the impact that the FCC’s failure to update guidelines on the current research and scientific evidence inclusive of the non-thermal biological evidence impacts human health. MACI participated in Public Comment to our State Departments of Public Utilities Dockets and the impact of the deficient FCC guidelines was used as a benchmark by the Department in the setting of policy (see MACI Reply Comment to DPU). My comment furnished evidence of real-life experience in related matters before our State Department of Public Utilities Dockets. 3). The unaddressed potential health risks by the FCC failure to update guidelines failed the Federal Agency’s duty to reflect a public health standard and failure to consider vulnerable populations who should be afforded special protection under federal and state laws. Many people who suffer from chemical sensitivities are concomitantly vulnerable to the effects of electromagnetic fields (EMF) and radio frequency radiation (RFR). A population survey of Hypersensitivity to Electromagnetic Fields in CA found chemical sensitivity to be an important risk factor for hypersensitivity to EMFs. The combination of sensitivities is quite disabling and puts their ability to work or live in their residences at greater risk. See submitted published research and studies that attest to the issue on prevalence of MCS and EHS, health effects experienced, risk for vulnerable members of public, comment to Docket HHS-OASH-2026-0397, exposure to smart meters - a device covered under the FCC, and the Public Comment to Massachusetts Department of Public Utilities. They should be considered part of my comment. The FCC must recognize, acknowledge and take the necessary steps to implement guidelines and rules based on all of the science, not just the “thermal” limits exposure that may have been protective in the 1980’s. The FCC has a duty and the responsibility to review and reassess fully the range of exposure to this environmental pollutant where EMFs and RFR exposure has become ubiquitous to ensure safe exposure for the population, for vulnerable members of the population, and equal access for this vulnerable population in their living environment, their workplace, and access to participate in society in today’s environment. The current research and scientific evidence which has become extensive showing biological health effects, epidemiological evidence through published studies, surveys, and real-life experience should be assessed in the setting of guidelines and policy. The matter of this docket did indicate that a broad range of commenters could participate. I offer this brief introductory comment with the submitted documents. In conclusion, there has been a failure of the FCC to update guidelines for today’s exposures and the current state of the science on EMFS and RFR. A view of impact on the public and especially those most vulnerable to EMF and RF and wireless exposure must be included in the reassessment of FCC radiofrequency exposure limits and policy. This failure on the Federal level has implications for State regulatory agencies who have hid behind and used as a benchmark these FCC guidelines which are insufficient to protect public health and allows for the pressure of Industry to control and set public health policy. There is sound reason why this is an important issue and the Federal Communication Commission should heed this important information and recommendations in the Commissions deliberation and the setting of FCC policy, rules and regulations. Respectfully submitted, Jean A. Lemieux President Massachusetts Association for the Chemically Injured, Inc. P.O. Box 754 Andover, MA 01810 978- 681-5117 macimcs@aol.com There was no box to upload the attachments. The regular form to submit by pdf failed in the Proceedings and didn't allow my filing of comment on this proceeding. Attachments: • AAEM Board of Directors, Statement: “Wireless Smart Meters Case Series”, American Academy of Environmental Medicine, October 23, 2013. • Belpomme, Dominique and Phillippe Irigaray, Electrohypersensitivity as a Newly Identified and Characterized Neurologic Pathological Disorder: How to Diagnose, Treat, and Prevent it”, International Journal of Molecular Sciences, 2020: 21, 1915. • Belpomme, Dominique and Phillippe Irigaray, “Why electrohypersensitivy and related symptoms are caused by non-ionizing man-made electrmagnetis fields: An overview and medical assessment.”, Environmental Research, 212 (2022) 113374. • International Commission on the Biological Effects of Electromagnetic Fields, “Electromagnetic Hypersensitivity (EHS) Is A Humanitarian Crisis That Requires An Urgent Response”, Issued July 2024: Revised December 2024. • Lamech, Federica, MBBS, “Self-Reporting of Symptom Development From Exposure to Radiofrequency Fields of Wireless Smart meters in Victoria, Australia: A Case Series”, Alternative Ther Health Med. 2014; 20(6): 28-39. • MACI’s statement outlining a section of the Reply Comment from the Massachusetts Association for the Chemically Injured, Inc. to the Department of Public Utilities on D.P.U. 12-76 on two questionnaire surveys on smart meters and health effects (Reference #12 on comment to HHS). • Massachusetts Association for the Chemically Injured, Inc. Comment to the Department of Health and Human Services, Federal Register: Notice of Request for information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure. • McCredden, McLean, and Steinemann study titled “Wireless sensitivity and co-morbidities: A prevalence study in Australia, Canada, and the United States.” March 2026. Science Direct, Next Research [https://www.sciencedirect.com/science/article/pii/S3050475926002745]