Requests a modern, independent reassessment of RF limits and cumulative, lifelong and multi-source exposu…

To the Department of Health and Human Services and the Federal Communications Commission: I am submitting this comment because I believe the federal government has waited far too long to conduct a thorough, modern reassessment of radiofrequency (RF) radiation exposure standards and their ability to protect the public. The FCC adopted its RF exposure limits in 1996. Wireless technology and our exposure environment have changed dramatically since then. We have moved through multiple generations of cellular technology while wireless infrastructure and the number of wireless devices surrounding us have greatly increased. Yet the fundamental FCC RF exposure limits remain unchanged. The question should not simply be whether an individual antenna, tower, or device complies with an existing limit. Federal agencies should determine whether those limits adequately address the real world environment people live in today. People are not exposed to one RF source at a time. We may encounter cell towers and antennas, WiFi routers, cell phones, tablets, Bluetooth devices, smart devices, security systems, and other wireless technologies throughout the day. I am especially concerned about infrastructure located near places where children, older adults, and other potentially vulnerable populations spend significant amounts of time. This includes daycares, schools, 55 and older communities, senior housing, assisted living facilities, and residential neighborhoods. Children may experience wireless RF exposure for virtually their entire lives. Older adults, people with implanted medical devices, workers with substantial occupational exposure, and people with existing health conditions also deserve appropriate consideration. Technology continues to advance rapidly. Public health research and exposure standards should advance with it. There is scientific evidence that deserves serious consideration. The U.S. National Toxicology Program conducted large animal studies of RF radiation and reported findings including malignant schwannomas of the heart in male rats under certain exposure conditions. Research from the Ramazzini Institute and subsequent systematic reviews has added to the scientific literature. At the same time, some human epidemiological research has not found increased risks for several health outcomes. Differences in findings should not be used as a reason to stop investigating. They are a reason for better research. Scientific uncertainty should not become an excuse for continued inaction while wireless technologies and infrastructure continue to expand. I am asking HHS, the FCC, NIH, FDA, CDC, NIEHS, and other appropriate agencies to support rigorous, independent research into cumulative RF exposure, multiple simultaneous RF sources, lifelong exposure beginning in childhood, potentially sensitive populations, reproductive and developmental effects, neurological and biological effects, cancer outcomes, occupational exposure, and current and emerging wireless technologies. Federal agencies should also evaluate real world RF environments around daycares, schools, senior communities, assisted living facilities, and residential areas where people may experience prolonged exposure. The public deserves transparency. Americans should be able to understand when exposure standards were established, the scientific assumptions behind them, how compliance is determined, what research supports them, what research raises concerns, and what remains unknown. I am not asking federal agencies to presume the outcome of the science. I am asking them not to presume the answer before adequately investigating the questions. After three decades of extraordinary changes in wireless technology, the American public deserves a comprehensive reassessment based on today's technologies, today's exposure environment, and today's scientific evidence. Technology should not advance faster than our willingness to investigate its potential effects on human health. I respectfully urge HHS and the FCC to conduct the rigorous, independent, transparent review this issue deserves and to ensure that protection of public health, including potentially vulnerable populations, remains a priority. Thank you for the opportunity to comment. Gina Paeth