PERK requests school and childcare wireless-equipment disclosure, exposure-reduction guidance, classroom …

Comment of Protection of the Educational Rights of Kids (PERK), Amy Bohn, President, in Docket HHS-OASH-2026-0397. Our full comment is attached. It responds to Questions 2, 5(n), 9, 11(a), 12, 13(c), 15(a), 16, and 17 as numbered in the notice. We file as a parent-led organization. Children in American public schools and licensed child care spend six to seven hours a day, roughly 180 days a year, inside wireless infrastructure that their parents were never told about and never asked to approve. That is the parent side of this docket, and it does not depend on how the science comes out. The FCC's exposure limits date to 1996 (11 FCC Rcd 15123). The D.C. Circuit held in 2021 that the FCC had not given a reasoned explanation on children, long-term exposure, and the spread of wireless devices, while taking no position in the scientific debate (Environmental Health Trust v. FCC, 9 F.4th 893). The FCC reopened that record only on September 17, 2026, while a mandamus petition was pending (In re Children's Health Defense, No. 26-1121). The FDA's 2020 literature review addressed cancer only. This notice itself says public concern has risen, particularly around children, schools, and long-term cumulative exposure. When the government cannot say the question is closed, the decision belongs with the parent, and a parent cannot decide without information. What changed since 1996: the FCC funded classroom Wi-Fi through E-Rate Category Two (FCC 14-99; 47 CFR 54.502); 88 percent of public schools now run one-to-one device programs (NCES, 2024-25); and Florida regulates the student's phone during the school day (s. 1006.07(2)(f), Fla. Stat.) but no Florida statute or State Board rule requires a district to tell parents what wireless infrastructure operates in a classroom. The only federal notice requirement attached to E-Rate concerns content, not equipment (47 U.S.C. 254(l)). We ask HHS to do four things. 1. Disclosure (Question 9). Issue a six-item notice format for schools and licensed child care providers: an inventory of transmitters by classroom; the operating schedule; device practices; any measurements taken; wired alternatives and how to request a lower-exposure placement; and a contact. France's 2015 law (Law No. 2015-136, art. 7) and Maryland's 2016 advisory council report already recommend practices of this kind, and Oregon (SB 283, 2019) and New Hampshire (HB 522, 2019) have put the question to study. 2. Guidance (Question 5(n)). Issue practical exposure-reduction guidance for schools and child care providers: wired connections where practical, access points off when not in use for instruction, devices off the body, and no wireless equipment in rooms for the youngest children. School network controllers in common use already support scheduled availability as a standard feature. 3. Measurement (Question 16). Fund a national study of RF levels in occupied classrooms and child care rooms during the school day. No federal agency has published such a dataset. The one government classroom measurement study we found is ARPANSA's 2017 study of 23 Australian schools. Add wireless infrastructure and parent notice questions to CDC's School Health Profiles, which ask nothing on the subject today. State whether the National Toxicology Program's RF research, listed as completed, will resume. 4. Coordination (Question 17). Open a standing channel with the Department of Education and the FCC, and ask that E-Rate Category Two recipients post the equipment disclosure at the internet safety hearing the statute already requires. We also ask the Department to state in its summary of this docket that schools and child care facilities are settings of involuntary, long-duration exposure for children, and that disclosure to parents is warranted on that basis whatever the outcome of the scientific review. PERK's September 2026 filings in Docket HHS-OS-2026-0332 rest on a survey of 664 parents. We offer to run a wireless version of that instrument, measuring notice and consent as parents experience them, with partner organizations across multiple states, and to provide the results to the Department in whatever form it designates. The instrument is available on request. This comment contains no personally identifiable or personal health information. Every factual claim in the attachment is cited to a primary source, with a Sources list at the end. Prepared by Rebekah Ricks, Senior Consultant. Contact: abohn@perk-group.com; Rebekah@PERK-GROUP.com.