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John Coates presents a theory of RF-induced bioelectrical disruption and increased disease susceptibility, cites animal tumor and device-testing evidence, and requests mechanistic experiments and federal radiation-control action. He advocates zero-distance testing, Section 704 repeal, wired and Li-Fi deployment, and recounts childhood kidney cancer and the loss of a daughter born with anencephaly.
- Proposed biological mechanisms: “Bioelectrical dissonance is the process”
- Cancer & tumors: “malignant heart schwannoma”
- Research & federal duties: “Reinvigorate Public Law 90-602”
- Exposure limits & oversight: “Require 0 mm testing”
- Section 704 / TCA: “Repeal Section 704”
- Li-Fi, fiber & alternatives: “fiber, Ethernet and Li-Fi”
- Children & vulnerable groups: “Development has no restore point”
- Reproduction & pregnancy: “my daughter Angel Leigh was born with anencephaly”
ORIGINAL COMMENT · UNEDITED TEXT
Non-thermal radiofrequency radiation is entropic waste. It is a fidelity stressor that disrupts the critical timing components of biology, and what it produces is bioelectrical dissonance and a meta-disease state. The evidence is already on the record. NTP and the Ramazzini Institute found the same rare heart tumor. The WHO-commissioned review rated glioma and heart schwannoma high-certainty. The FCC's own 2 mm tests hit 5.2 W/kg. Europe moves body testing to 0 mm by March 7, 2028. HHS should act now, and the end game is Li-Fi compatibility through the Clean Ether Act.
Comment of John Coates on Docket HHS-OASH-2026-0397. Individual respondent. My full comment, with sources, is attached: It answers Questions 2 through 18, with every subpart, in order.
THE EVIDENCE IS ALREADY ON THE RECORD (Q6, Q12).
- NTP and Ramazzini, two independent lifetime bioassays, found the same rare tumor, malignant heart schwannoma, in male rats. Germany's BfS called Ramazzini's exposures "at a comparable level to the basic limit values for humans."
- The WHO-commissioned review: "The CoE for an increased risk in glioma was judged as high." Heart schwannoma was rated high too.
- NTP held heating under 1 degree C, and NTP itself says: "The role of thermal changes on cancer development needs to be further investigated." GSM gliomas ran 0, 3, 3 and 2 per 90 across sham, 1.5, 3 and 6 W/kg. Heat does not draw that curve. HHS should fund the investigation NTP called for.
- NTP's 1.5 W/kg is a whole-body average; the FCC's 1.6 W/kg limit is a 1-gram local peak. Different measures, but the numbers sit right on top of each other. The iPhone Air's 1.60 W/kg is the highest simultaneous-transmission value reported in its FCC grant.
THE TEST MISSES THE BODY (Q5(p), Q7, Q8, Q9).
- The FCC's own 2019 tests at 2 mm recorded up to 5.2 W/kg.
- Europe moves body testing to 0 mm by March 7, 2028. The U.S. still certifies at typically 5 to 15 mm.
- SAR averages away the timing biology reads: GSM bursts about 217 times a second, Wi-Fi beacons about ten times a second, DECT and 5G NR use 10 ms frames.
- Require 0 mm testing, and disclose test distance and pulse structure with every SAR value.
THE META-DISEASE STATE (Q10, Q12). RF does not need to cause one unique disease to matter. It only needs to reduce the fidelity of the systems that prevent many diseases. Bioelectrical dissonance is the process, low-fidelity biology is the state, and disease susceptibility is the consequence. The causal fingerprint is not one diagnosis. It is a shifted distribution of biological failure: rare becomes less rare, late becomes early, recoverable becomes persistent.
S4-MITO-SPIN (Q12). The S4 helix of the VGCCs, including CACNA1C, is the bulk-calcium gate; Cyb5b is the internal-timing transducer (Kim et al., Cell, 2026: "an essential mediator likely acting as an EMF sensor"); mitochondria are the redox amplifier (95% of 131 non-thermal studies found oxidative effects); cryptochrome-to-flavins spin dynamics are the modulator. At matched SAR, pulse modulation, not the carrier, changed human EEG and blood flow. HHS should test whether pulsed exposure disrupts pulsatile insulin release, which runs on the same calcium machinery.
SENSITIVE POPULATIONS (Q11). Development has no restore point. Children absorb higher local doses; NTP pups were born smaller; responses differ by CACNA1C genotype and mouse strain; aging neurons carry more L-type calcium channels.
WHAT I ASK (Q5, Q15, Q16, Q17, Q18).
- Reinvigorate Public Law 90-602. It is HHS's job. The Secretary "shall establish and carry out an electronic product radiation control program" and develop techniques "for minimizing exposure." Publish the performance-standard determination and a public work plan; replace FDA's tumor-only 2020 review.
- Run the meta-disease experiment: pulsed RF vs carrier-only vs sham at matched SAR, from the womb, measuring fidelity endpoints before pathology (NIEHS/NTP).
- Fund Cyb5b, CACNA1C and organoid replication (NIH); build registries and measured-exposure cohorts (CDC); issue precautionary guidance now.
- Repeal Section 704, which bars localities from weighing RF health effects in siting.
- Pass the Clean Ether Act: fiber, Ethernet and Li-Fi on IEEE 802.11bb indoors, with pilots in Head Start, childcare, maternity and pediatric care, and HHS facilities.
Invisible does not mean irrelevant. Non-ionizing does not mean non-biological. Legal does not mean safe.
I was diagnosed with kidney cancer at age 7 in 1977, with my left kidney removed at age 8, while my family lived near a radar installation on a military base. In 1995 my daughter Angel Leigh was born with anencephaly and did not survive. My daughter was the canary in the coal mine... and so was I.
John Coates
RF Safe
Discussion
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