Children, schools & development

Dear Ms. Marlene Dortch: We are writing regarding the Federal Communications Commission's (FCC) Notice of Proposed Rulemaking and Further Notice of Proposed Rulemaking on the E-Rate program, and we appreciate the opportunity to comment ahead of the October 13, 2026 deadline, asking the FCC to preserve the current E-Rate program. Our students have reliable internet access at our school because of E-Rate. Without E-Rate funding, we would have to cut core services, programs, and operations to maintain the internet service our school requires. High-speed, reliable internet is central to daily learning at our school. We are concerned by proposals in this proceeding that would narrow the program's scope, including reducing support for schools in less-resourced communities, eliminating funding for certain special construction projects, or ending E-Rate eligibility for early childhood programs. Losing E-Rate support would severely impact our entire school budget, forcing difficult choices between funding essential technology and supporting other critical educational programs. Sixty percent of our internet budget is paid for through E-Rate, and we save several dollars on other technology. We are also concerned about proposed administrative changes that would add significant new burdens on schools without a clear corresponding benefit to students. Eliminating the "Kalamazoo exception" would require schools like ours to re-bid and re-sign existing, already competitively bid contracts more frequently, adding staff time and creating potential service gaps. As a small private school without dedicated E-Rate compliance staff, this change would fall disproportionately hard on us compared to larger districts with dedicated procurement teams. Similarly, requiring a new annual consultant disclosure form (Form 5654) from every applicant, even schools that do not use a consultant, adds a filing requirement with no clear purpose for schools that manage their own applications. E-Rate is an essential program, and we ask for the FCC's continued commitment to ensuring that schools across the nation have access to the federal funds needed to provide secure, scalable, future-ready connectivity that supports the current and evolving needs of our community. We also urge the FCC not to impose overly restrictive mandates or administrative burdens, particularly around screen use and content-monitoring requirements proposed in this proceeding, as they will undermine the flexibility schools need to deliver high-quality, digital learning. Our school has already developed its own internet safety and technology policies tailored to our students and our educational mission, and we ask the Commission to preserve that local flexibility rather than impose a one-size-fits-all federal standard. Respectfully, Mark Peterson - Head of School Racine Christian School

Comments of Rosemarie Russell ET Docket No. 13-84 (Public Notice DA 26-971) I am a resident in Hurricane, UT. I file this comment so the Commission will complete the work the U.S. Court of Appeals for the D.C. Circuit required in Environmental Health Trust v. FCC, 9 F.4th 893 (D.C. Cir. 2021). I live with nearby wireless infrastructure, so this is not an abstract proceeding. It is the air around my home. I am filing because I have EMR Syndrome. My ability to travel freely throughout my neihborhood and community is severely curtailed due the ever increasing levels of EMF from cell towers, SMART meters, wifi and other sources of non natural frequencies. The court remanded the 2019 decision to keep the 1996 RF exposure guidelines. It ordered a reasoned explanation of how those guidelines protect against harmful effects unrelated to cancer, including impacts on children, long-term exposure, the ubiquity of wireless devices, device-testing procedures, and the environment. The mandate issued October 5, 2021. The 1996 limits remain in force. The remand is not closed. A new comment cycle is not a substitute for a Commission-level answer. Current FCC limits are thermal-only. They were derived from short-duration animal studies and are designed to prevent tissue heating. They do not independently evaluate non-thermal disruption of ion-channel gating, calcium waveform signaling, or mitochondrial redox. Those processes operate well below heating thresholds. A guideline that treats average power deposition as a complete proxy for harm is inadequate as a public-health standard. Melnick and Moskowitz (Environ. Health 25:42, 2026, doi:10.1186/s12940-026-01288-6), using EPA-style methods on experimental-animal data, estimate that the FCC/ICNIRP whole-body public limit of 80 mW/kg is 15- to 900-fold above modeled 1×10⁻⁵ cancer-risk levels depending on daily duration, and 8- to 24-fold above male-reproductive reference levels (3.3–10 mW/kg). These are whole-body SAR comparisons, not localized phone ratings. The Commission should state which assumptions it accepts or rejects. NTP TR-595 (2018) reported clear evidence of malignant heart schwannomas in male rats and some evidence of brain gliomas, plus DNA damage in rats and mice. The Ramazzini Institute (Falcioni et al., 2018) reported heart schwannomas at base-station-like intensities. WHO-commissioned systematic reviews have treated the animal cancer and male-fertility evidence as high-certainty. The Commission must explain why a thermal-only number is retained in the face of that record. Male reproductive toxicity is a non-thermal endpoint the 1996 guidelines were not designed to prevent. Melnick–Moskowitz conclude the public whole-body limit would need to be reduced 8- to 24-fold to protect male fertility. Germ-line DNA integrity is transgenerational. I ask the Commission to evaluate fertility, pregnancy, and development independently of tissue heating. The D.C. Circuit expressly required the Commission to address impacts on children. Children have different dielectric properties, thinner skulls, developing nervous and endocrine systems, and a longer remaining lifetime of exposure. Adult-male phantom testing of brief, held-to-ear use does not represent a child in a classroom of transmitters. I ask for the pediatric dosimetry and developmental analyses the Commission relies upon. Non-thermal hazards must be evaluated at the layer where biology transduces electromagnetic information: ion-channel voltage sensing (including the S4 helix) and calcium waveform signaling, with downstream mitochondrial redox and radical-pair effects. Pulsed and modulated emissions are not equivalent to a continuous-wave heating dose at the same time-averaged SAR. Therapeutic use of low-intensity amplitude-modulated RF is itself evidence that non-thermal, modulation-specific effects exist. The court required a reasoned explanation for retaining portable-device testing procedures. Existing SAR certification does not represent body-worn distances, children, all-day carriage, simultaneous radios, or the ambient field of a dense network. The Commission should explain how those procedures remain protective given 4G/5G, small cells, and always-on body-worn transmitters. The 1996 guidelines rest on short-term thermal thresholds. The public condition in 2026 is chronic, multi-source exposure over decades. The court required the Commission to address long-term exposure and the ubiquity of wireless devices. If chronic, low-dose, and cumulative-risk analyses do not exist, the Commission should say so and complete them before reaffirming a heating-based number. Thermal-only guidelines are inadequate to protect public health. They were never designed to evaluate non-thermal disruption of biological fidelity — ion-channel gating, calcium waveform signaling, and related redox biology — or transgenerational reproductive harm. I ask the Commission to: 1. Issue a Commission-level order that actually answers the 2021 remand, with a public timetable, rather than leaving ET Docket 13-84 as an open comment bin. 2. State clearly whether the Commission contends that the absence of tissue heating is equivalent to the absence of biological effect. If it does, cite the evidence. If it does not, explain why a thermal-only guideline remains the public standard. 3. Independently evaluate non-thermal hazards at the ion-channel and calcium-waveform layer, including pulsed and modulated signals, instead of collapsing every emission into a time-averaged SAR. 4. Address, with pediatric dosimetry and developmental evidence, how the 1996 limits protect children in homes and schools. 5. Address long-term, cumulative, multi-source exposure — the condition the public actually lives in — and the adequacy of current device-certification testing. 6. Respond on the record to the 2026 Melnick–Moskowitz EPA-method risk assessment, including the findings that current whole-body limits are 15- to 900-fold above modeled cancer-risk reference levels (duration-dependent) and 8- to 24-fold above male-reproductive reference levels. The administrative record should be built from evidence, not from the assertion that a 1996 heating number is still enough. Please complete the remand. Respectfully submitted, Rosemarie Russell 854 W 3390 S Hurricane, UT 84737 September 16, 2026

I am writing on behalf of Notre Dame de la Baie Academy, a private 9–12 high school in Green Bay, Wisconsin, to express our strong support for the continuation of E-Rate funding. Our school relies on E-Rate support to maintain essential internet access and our internal network throughout our school. In recent years, we have seen a rise in the number of students qualifying for free and reduced lunch. As our traditional fundraising capacity is limited, E-Rate funding is vital to enhancing our internal connectivity for our students and ensuring equal access to resources. Reliable, high-speed connectivity is essential for preparing our students for higher education and/or the workforce. Without E-Rate support, our limited operating budget would force us to delay critical network equipment upgrades, resulting in aging infrastructure. This would directly impact daily learning and teaching. Also, absorbing these connectivity costs would force us to make difficult cuts to other educational programs that we've spent so much time and energy to build. We implemented an A/V Studio class in the last 5 years where students are video streamed to our classrooms via Vimeo each morning with our daily announcements. The class allows our students to learn about media, on-air presence, directing, controls for video and sound as well as writing script. Without funding for our internet connectivity, this class would struggle or need to be revamped and the bandwidth to stream would likely be in jeopardy. On behalf of our students, faculty, and school community, I respectfully urge the FCC to maintain current E-Rate funding levels. This support remains essential to helping us provide a solid education for our students.

Dear Ms. Marlene Dortch: We are writing regarding the Federal Communications Commission's (FCC) Notice of Proposed Rulemaking and Further Notice of Proposed Rulemaking on the E-Rate program, and we appreciate the opportunity to comment ahead of the October 13, 2026 deadline, asking FCC to preserve the current E-rate program. Our students have reliable internet access at our school because of E-Rate. Without E-Rate funding, we would have to cut core services, programs, and operations to maintain the internet service our school requires. High-speed, reliable internet is at the heart of daily learning in our school. We are concerned by proposals in this proceeding that would narrow the program's scope, including reducing support for schools in less-resourced communities, eliminating funding for certain special construction projects, or ending E-Rate eligibility for early childhood programs. Losing E-Rate support would severely impact our entire school budget, forcing difficult choices between funding essential technology and supporting other critical educational programs. We are also concerned about proposed administrative changes that would add significant new burdens on schools without a clear corresponding benefit to students. Eliminating the "Kalamazoo exception" would require schools like ours to re-bid and re-sign existing, already competitively bid contracts more frequently, adding staff time and creating potential service gaps. As a small private school without dedicated E-Rate compliance staff, this change would fall disproportionately hard on us compared to larger districts with dedicated procurement teams. Similarly, requiring a new annual consultant disclosure form (Form 5654) from every applicant, even schools that do not use a consultant, adds a filing requirement with no clear purpose for schools that manage their own applications. E-Rate is an essential program, and we ask for the FCC's continued commitment to ensuring that schools across the nation have access to the federal funds needed to provide secure, scalable, futureready connectivity that supports the current and evolving needs of our community. We also urge the FCC not to impose overly restrictive mandates or administrative burdens, particularly around screenuse and content-monitoring requirements proposed in this proceeding, as they will undermine the flexibility schools need to deliver high-quality, digital learning. Our school has already developed its own internet safety and technology policies tailored to our students and our educational mission, and we ask the Commission to preserve that local flexibility rather than impose a one-size-fits-all federal standard. Respectfully, Christ Child Academy

The United States Government has a primary duty to protect it's citizens. Our children deserve to live and learn in a safe environment. The studies on nnEMF are clear. Extra noise in a lab or a body creates quantum decoherence. Decoherence creates disease or a ruined experiment. This is especially true in kids and the elderly. It is imperative that we create EMF free zones so that those who have this disability can live. The public must be informed. Autism, brain tumors, endocrine diseases, etc.,have gone up on the same vector as cell phone use, towers, nnEMF. Unseen microwave destroys how the mitochondria communicate. This evidence is irrefutable. We can now change how society views this invisible threat. Create legislation to make it mandatory to inform the public. Save our most vulnerable, our future, our kids.