Pregnancy & reproduction

I am writing regarding the FCC’s response to the D.C. Circuit Court of Appeals’ remand concerning its decades-old radiofrequency (RF) radiation exposure guidelines. The Court directed the FCC to provide a reasoned explanation for its determination that its guidelines adequately protect humans against harmful effects of RF radiation unrelated to cancer. Specifically, the court required the FCC to address the impacts of RF radiation on children, the health implications of long-term exposure, the ubiquity of wireless devices and technological developments, impacts on the environment, and the adequacy of the FCC’s testing procedures for cell phones and other portable devices. The FCC should fully consider evidence and real-world experiences concerning the health and environmental impacts of wireless radiation, including non-cancer health effects, impacts on children, long-term and cumulative exposure, cancer, and impacts on wildlife and the environment. The FCC is not a health agency and does not have expertise in medicine, biology or public health. Yet, the agency continues to assert authority over RF exposure standards and is preparing to reach conclusions about whether its existing guidelines adequately protect the public. I urge the FCC to recognize the critical role of federal health agencies, including the U.S. Department of Health and Human Services, and to rely on appropriate health and biological expertise when addressing the issues identified by the court. This issue matters to me personally because: Our family personally feels mentlaly and physically drained and gets headaches when exposed to WiFi or towers for extended period of time. A good friend of ours who lives near a cell tower has experienced pregnancy complications and a baby born at 23 weeks, who passed away shortly after birth. Another close friend qho lives by a 5G antenna has many autoimmune and health issues. Ontop of this, there are many people who live by cell towers and antennas who develop cancers. I urge the FCC to give meaningful consideration to the experiences and evidence before it and to fully address each of the issues identified by the court.

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