Exposure limits & testing

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 matters to me personally because my family (especially our son with brain-injury) has repeatedly noted the negative effects of the increasing presence of radio frequency radiation. Although my husband and I have experienced difficulty sleeping, headaches and difficulty focusing, it is our son who is most noticeably affected by these symptoms. We have observed him more symptomatic in the presence of cell towers or buildings with high levels of wi-fi and a cessation of these symptoms when vacationing in remote parts of NYS. When a smart meter was installed by our electric company, my son cried all night. I thought he was sick but walked around the house, discovering the new meter. Our power company quickly and very cooperatively replaced it with an analog meter (for which we pay a monthly reading fee) and my son's crying and sleeplessness ceased. We do all we can to minimize wireless signal in our home, but it is impossible to avoid the increasing exposure, unstudied and unregulated. 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.

I am pleased that the FCC is reopening the record on the health and environmental impacts from RF radiation exposure. Neighborhoods now seem to be full of 5G cell towers and nobody knows what effect all this radiation has on human bodies and on the environment. Also we don't know how the constant presence of our cell phones and routers is affecting us because radiation testing procedures for cell phones and other portable wireless devices has not been updated. I wonder if some of the mental confusion I've experienced lately can be attributed to having these devices around me so many hours each day. I encourage the FCC to sincerely and thoroughly undertake these studies.

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: I can not be anywhere where there are cell towers nearby or even around people carrying cell phones. There is definitely a health affect from the radiation being emitted from all these devices. I will get headaches and migraines and feel awful in a short time and have to leave the area I am in. If I see a cell tower overlooking a main street when I am on vacation, I won't even attempt to go shopping on the street. It is ridiculous how cell towers are put right where people want to be. I have even seen them right on school grounds. There needs to be good regulations on cell towers because they are making people short tempered, giving people anxiety and all kinds of health problems that they aren't even aware of. I keep my home wi-fi free and require anyone who enters to turn their cell phone off or even wrap it in aluminum foil since they don't even seem to really shut off anymore. 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.

I am writing as a private citizen regarding ET Docket No. 13-84 and the Commission's response to the D.C. Circuit's remand in Environmental Health Trust v. FCC, No. 20-1025 (D.C. Cir. 2021). The court remanded for the Commission to provide a reasoned explanation for its determination that its guidelines adequately protect against harmful effects of RF radiation unrelated to cancer, and directed it specifically to address its testing procedures for cell phones and other portable devices, the impacts of RF radiation on children, the health implications of long-term exposure, the ubiquity of wireless devices and technological developments since the guidelines were last updated, and environmental effects. That mandate issued in October 2021. Nearly five years passed before this record was reopened. The delay is itself part of what the Commission should account for. The scale of what is being decided. The guidelines at issue were set in 1996. In the three decades since, wireless exposure has gone from occasional and voluntary to continuous, ambient, and involuntary. Nearly every person in the country is now exposed, in every room they occupy, from birth, with no practical ability to opt out. Because FCC limits and FCC device certification shape international practice and because US-certified handsets are sold worldwide, the reasoning the Commission puts on this record does not stay domestic. The Commission is not choosing between acting and waiting. The exposure is already universal and expands by default while the question remains open. Continuing without a reasoned explanation is itself a decision, and it is the one the court found inadequate. On children, specifically. This is where the Commission's position is weakest, and where the consequences of being wrong are least recoverable. SAR compliance testing relies on a standardized head phantom derived from adult male anthropometry. Children differ in head size, skull thickness, tissue dielectric properties, and the proximity of developing tissue to the device. The Commission has not explained why a model built on adults adequately represents them. More fundamentally: a child born today will accumulate RF exposure continuously from infancy across a full lifespan. No epidemiological cohort of that kind exists, because no such population has yet lived long enough to be studied. The reassurance drawn from existing studies of adult mobile phone users does not transfer to that exposure profile — not because those studies are wrong, but because they did not examine it and could not have. The Commission should say plainly whether it is treating the absence of such evidence as evidence of adequacy. If it is, the court's remand is not satisfied. If it is not, it should state what would satisfy it, and on what timeline. On device testing procedures. Under 47 CFR § 2.1093(d)(2) and OET guidance in KDB 447498, portable devices are certified for body-worn operation at a manufacturer-specified separation distance. Actual use does not match that condition. Phones are carried in pockets, held against the body, and used in skin contact for hours daily — and by children, whose use patterns the certification regime never contemplated. Independent regulator testing, including measurements by France's Agence nationale des fréquences, has found handsets exceeding applicable limits at zero separation. This is a bounded, testable question and the court identified it first. The Commission should either justify the protocol against documented use or revise it. On institutional expertise. The Commission's 2019 order relied substantially on the Food and Drug Administration, including the April 24, 2019 letter from the Director of the Center for Devices and Radiological Health. Deference to a health agency is appropriate — the Commission is not a health agency and holds no expertise in biology, toxicology, or pediatric development. But deference is not the reasoned explanation the court required. The Commission should state which specific remanded questions federal health authorities have actually evaluated, on what record, and when. Where they have not addressed a question, the Commission should say so rather than treat silence as endorsement. Given the concurrent request for information issued by the Department of Health and Human Services, the Commission should coordinate with HHS, incorporate its evidence assessment into this docket, and explain how that assessment informs its conclusions. Neither agency should be able to defer to the other while the exposure continues to expand. I have three children. They did not choose this exposure, they cannot avoid it, and they will carry it for a lifetime under a standard written before any of them were born and before the technology that now surrounds them existed. I am not asking the Commission to conclude that harm has been proven. I am asking it to do what the court ordered: address each of these questions on its merits, state clearly which it is answering and which it is deferring, and put its actual reasoning on the record.

Regarding the FCC’s response to the D.C. Circuit Court of Appeals’ remand concerning its decades-old radiofrequency (RF) radiation exposure guidelines. This issue matters to me personally because I am negatively physically affected by RF radiation exposure and microwave radiation. I have to use my landline for communication. I will NOT give up my landline. I can't have Wi-Fi on my computer because, again, it affects my physical well-being. 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.

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: As a multispecialty board-certified physician with over 30 years of experience in the practice of medicine, I have consulted with and treated numerous patients who have reported significant health effects from exposure to RF radiation resulting from the use of cell phones or other wireless devices. These reported health effects have involved multisystem illnesses including neurological, musculoskeletal, cardiovascular, gastrointestinal and immunological. In a more personal manner, my wife has suffered serious ill health effects due to RF radiation exposure resulting from the use of a cell phone. The international scientific literature documents a clear signal regarding the potential noxious effects that exposure to RF radiation can have on human health. RF radiation exposure guidelines urgently need to be updated to reflect the current knowledge base in order to minimize the impact that the exploding wireless technology industry is inflicting on human health and the environment.

I would like to say that I read different publications and I watched videos about EMF and I am very concerned about it. I watched some scientists talking that this radiation breaks down the DNA and it causes cancer .My best friend who was a doctor she used to have her cell phone in the pocket ( left chest pocket ) and she developed left breast cancer and died of it. I also read that it causes thinning of the cerebral cortex and dementia , increases risk of neurodegenerative disorders 3 times and decreases the attention span . I also find myself many times I am kind of scattered. It definitely affected my eyes , I had a very good vision and now my eyes are not good anymore . I read the emf has the same radiation as the microwave and than I am thinking wow , Am I microwaveing my eyes !Since 30 Y ago I heard that Microwave is not good because it produces free radicals , so I never used it to heat the food or anything . Than some PHDs told me that it decreases your dopamine and it causes addiction . I read about EMF that it is way above the safety limit and that Children are more sensitive to it because their skull is not ossified until later. I can not imagine the horror of having this cells and tablets in the hands of the little children when they blind them and thin their cortex , or give them cancer and also sterility and decreases their attention span. Also I heard it gives brain cancer if kept near the temple when talking on the phone . The wireless headphones are very dangerous because to much EMF to the brain . Than everyone is talking about nanotechnology in vaccines and in Pepsi and Coca Cola and that this interact with EMF and connect us to internet which has the same brain wave as the brain and will hijaack our independent thinking and individuality and our sense of self. I think that regulating the emf exposure and this devices would be of great benefit for the children with are our future and for all the people overall.We need children that are smart and emotionally and physically healthy.

PUBLIC COMMENT REGARDING THE D.C. CIRCUIT REMAND ON RF RADIATION EXPOSURE GUIDELINES I am submitting this comment in direct response to the remand ordered by the U.S. Court of Appeals for the D.C. Circuit, which mandated that the Federal Communications Commission (FCC) provide a reasoned explanation for maintaining its decades-old radiofrequency (RF) radiation exposure guidelines. The Court made it abundantly clear that the FCC failed to establish that its 1996 guidelines adequately protect against non-cancer health effects, cumulative long-term exposures, vulnerability in developing children, and impacts on wildlife and the environment. As a communications regulator rather than a biomedical or health agency, the FCC cannot continue to dismiss peer-reviewed scientific evidence and real-world human experience while clinging to obsolete, thermal-only models. Why This Issue Matters Personally In my day-to-day work and personal life, I regularly interact with individuals, families, and chronically ill patients who report debilitating sensitivities and symptom flares when exposed to ambient, near-field, and cumulative wireless radiation. From headaches, brain fog, and severe sleep disruptions to heightened biological stress responses, these experiences are real, observable, and disruptive to daily living. Modern life has created an unprecedented environmental shift: citizens no longer experience single, isolated RF exposures. Instead, we are subjected to a continuous, overlapping blanket of non-ionizing electromagnetic radiation from modern cell phones held directly against the body, high-output Wi-Fi routers operating 24/7 in homes and schools, smart utility meters, and an accelerating density of small-cell infrastructure placed within feet of bedroom windows. To achieve even a baseline level of comfort and restorative sleep, an increasing number of people are forced to take extraordinary measures—relying on RF shielding fabrics, hardwired Ethernet connections, and physical barriers just to reduce ambient field exposure in their own living spaces. When individuals consistently experience tangible relief and improved well-being simply by eliminating or attenuating these fields, the agency's insistence that "no non-thermal biological effects exist" is directly contradicted by everyday reality. Furthermore, testing protocols that rely on large plastic mannequins (such as the legacy SAM phantom) filled with liquid do not reflect real-world device usage. Real people—and specifically children with thinner skulls, developing central nervous systems, and smaller body geometries—absorb proportionally higher rates of radiation from devices used directly against the head and lap. Direct Actions Requested of the Commission In accordance with the D.C. Circuit’s mandate, the FCC must: Defer to Legitimate Health Authorities: Re-engage with independent biomedical researchers, toxicologists, and relevant federal health agencies—including the U.S. Department of Health and Human Services (HHS) and the National Institute of Environmental Health Sciences (NIEHS)—rather than relying on decades-old industry assumptions. Update Testing Procedures for Modern Devices: Overhaul device compliance testing so that cell phones, tablets, and wearable tech are evaluated in direct contact with biological tissue at maximum power output, eliminating artificial separation distances. Establish Biologically Based Standards: Transition away from an outdated thermal-only standard to an exposure model that accounts for chronic, low-level, non-thermal biological impacts, pulsed wave modulations, and cumulative lifetime exposures. Evaluate Environmental and Wildlife Impacts: Give substantive, non-dismissive consideration to the documented impacts of radiofrequency radiation on plant biology, pollinator behavior, and avian populations. The public record must reflect that the public demands accountability, scientific integrity, and public health safeguards over unchecked commercial deployment. I urge the Commission to address each deficiency identified by the federal court completely, transparently, and rigorously. Respectfully submitted, James Concerned Citizen & Clean Environment Advocate

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: [Please add your personal story here. You may wish to describe how wireless radiation has affected you, your child or family; health effects or cancer you have experienced; concerns about long-term exposure; experiences involving cell phones, Wi-Fi, cell towers or other wireless sources; or impacts you have observed on animals, wildlife, plants or the environment.] 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.

I am highly concerned about the FCC’s response to the D.C. Circuit Court of Appeals’ remand concerning its radiofrequency (RF) radiation exposure guidelines. The FCC has no authority or expertise in biology or public health nor have they studied RF radiation affects on public health, but the agency continues to assert authority over RF exposure standards. RF radiation DOES affect public health and DOES cause biological harm. This issue matters to me personally because I am sensitive to ALL wireless devices, including cell towers, cell phones, and smart meters. I became sensitive seven years ago after driving a newer car equipped with bluetooth devices. After researching the internet to understand my condition, I sold that car and removed all wireless devices from our house, because they cause me to have hours of painful headaches which nothing, except 10-24 hours of staying at home, will remove; our house is now wired with ethernet. Where I frequently drive, there are six cell towers within ten miles of my house. These wireless devices are dangerous to human and animal health. More wireless will cause chronic illness to continue rising and even death for millions of people. I urge the FCC to give meaningful consideration to the experiences and evidence of others and to fully address each of the issues identified by the court.