The advocacy group describes gaps in local RF testing, disclosure and health oversight and requests indep…

I am submitting this comment in response to HHS's Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure. I am responding on behalf of Nevada County for Safe Tech (NCST), a community advocacy group of residents in Nevada County, California. NCST formed in 2025 when our county began updating its ordinance for cell towers and wireless facilities. Hundreds of residents have since commented to our Planning Commission and Board of Supervisors. What we learned is that when residents raise health concerns about wireless facilities, no one in local government has the authority or expertise to answer them. What we have seen locally: • A resident near a tower activated in December 2025 reported headaches and insomnia beginning when the tower went live. The county had no way to require independent RF testing, and because the tower was approved under prior rules, no post-installation testing was required. • County staff acknowledged they lack the expertise to evaluate carrier RF compliance reports. A report can certify compliance without showing exposure levels at nearby homes. • Carrier predictive models can underestimate real-world exposure because of terrain, antenna orientation and multiple co-located transmitters. Consumer meters cannot measure 5G frequencies, so residents have no practical way to know their exposure. • Our county treats new small cells as a building-permit matter with no public notice. Residents may first learn of an antenna in front of their home when the crew arrives. • Elevated exposure is not only a ground-level issue. Arborists and maintenance workers can enter high-exposure zones at height. Federal law (47 U.S.C. § 332(c)(7)(B)(iv)) bars local governments from regulating wireless facilities on health grounds when they meet FCC limits, and the FCC is proposing to narrow local enforcement further. The FCC is not a health agency. Communities are left with health questions and no health authority responsible for answering them. We ask HHS to: 1. Develop independent field-measurement protocols that cover all frequencies in use, including 5G and 6G, measure cumulative exposure from multiple sources, and test at ground and upper-story heights, so local health departments can verify exposure. 2. Recommend what RF information should be public for each facility, such as predicted exposure at nearby homes and schools. 3. Create a way for individuals and clinicians to report symptoms they associate with RF exposure, and guide local health departments on responding. 4. Prioritize research on chronic ambient exposure, effects below current limits, and vulnerable groups including children, pregnant women and people living close to facilities. 5. Advise the FCC on exposure limits and on health-protective distances between facilities and homes and schools. I support HHS taking an active role in examining the potential health and environmental effects of wireless radiation. Questions about human health should be addressed by federal agencies with appropriate expertise in medicine, biology, epidemiology, and public health, and the experiences of individuals and families who report being affected should be considered alongside the scientific evidence. I urge HHS to carefully evaluate these experiences and the scientific evidence, identify gaps in current research, give particular attention to children and other potentially vulnerable populations, and establish appropriate federal research priorities regarding wireless radiation and public health. Thank you for providing individuals and families with an opportunity to be heard.