The commenter urges updated RF limits reflecting continuous body-worn and combined-device exposure, nonth…

To: Federal Communications Commission (FCC) Department of Health and Human Services (HHS) / Food and Drug Administration (FDA) Subject: Public Comment Regarding Outdated RF Radiation Exposure Limits, Multi-Device Realities, and Implementation of the EHT v. FCC Court Mandate To Whom It May Concern: I am submitting this comment to formally urge the Federal Communications Commission (FCC) and the Department of Health and Human Services (HHS) to update the United States exposure limits for radiofrequency (RF) electromagnetic fields. The current federal exposure limits were adopted in 1996 and remain rooted in an obsolete thermal model that presumes biological harm occurs only if tissue is acutely heated. In 1996, mobile phones were utilized sporadically and held away from continuous bodily contact. Today, wireless exposure is near-constant, multi-source, and delivered directly against human skin across an expansive ecosystem of personal and commercial devices: 1. Continuous Contact and Body-Worn Devices: The 1996 standards never envisioned hardware engineered to operate in direct, uninterrupted contact with the human body for 16 to 24 hours a day. Millions of Americans now continuously wear smartwatches, fitness trackers, and connected rings, alongside direct-in-ear transmitters like Bluetooth earbuds and wireless headsets. Testing standards based on short-duration, separated-distance models fail to reflect the cumulative biological load of these skin-contact technologies. 2. Dense Multi-Source Living and Work Environments: Current Specific Absorption Rate (SAR) evaluations assess a single isolated device. However, daily environments subject individuals to simultaneous, overlapping fields from: Mobile hardware: High-powered smartphones running simultaneous cellular (5G/4G LTE), Wi-Fi, and Bluetooth radios, frequently carried directly in pants or jacket pockets. Portable computing: Wi-Fi- and cellular-enabled tablets, laptops, and e-readers resting directly on laps or near vital organs during work and education. Household and municipal infrastructure: High-output Wi-Fi 6/7 mesh routers, smart electric and water utility meters, smart TVs, voice-assistant smart speakers, and automated home security hubs broadcasting continuous beacon signals. 3. Non-Thermal and Chronic Low-Level Biological Effects: The assumption that only thermal burns or acute heating warrant safety margins is contradicted by substantial independent, peer-reviewed scientific literature—including research from the National Toxicology Program (NTP). Studies demonstrate cellular oxidative stress, metabolic disruption, and potential neurological impacts from persistent low-level pulsed fields, even when temperatures remain unchanged. 4. Failure to Protect Developing Neurological Systems: Standardized plastic mannequins modeled after adult male dimensions do not account for children or adolescents. Thinner cranial bones, greater fluid conductivity, and smaller body mass mean modern wireless tablets, educational laptops, and phones deliver higher relative doses to children’s developing nervous systems. 5. Mandated Compliance with EHT v. FCC: In Environmental Health Trust, et al. v. FCC (11 F.4th 912, D.C. Cir. 2021), the U.S. Court of Appeals for the D.C. Circuit ruled that the FCC acted arbitrarily and capriciously by terminating its inquiry into its 1996 limits without providing a reasoned explanation regarding non-cancer harms, chronic exposures, and modern children's usage. The FCC, in coordination with HHS and the FDA, must fulfill this legal remand through a transparent, science-based review rather than maintaining reliance on a 30-year-old framework. The federal government must align its regulations with today's multi-device, body-worn reality by updating RF exposure limits to account for continuous, non-thermal, cumulative exposures. Respectfully submitted, Mark Kuether Oostburg WI 53070