Comment on HHS-OASH-2026-0397: street-level RF exposure data from the Netherlands Submitted by citizen sc…

Comment on HHS-OASH-2026-0397: street-level RF exposure data from the Netherlands Submitted by citizen science project EMF Mapper (EMF kaart NL), the Netherlands. https://emfmapper.com / https://emfkaart.nl This comment responds mainly to question 15 (proximity, cumulative neighborhood exposure, antenna density) and question 18 (additional data). We submit independent street-level measurements from the Netherlands, where 5G was introduced in 2020 and upgraded in July 2024 when 3.5 GHz came on. Since 2022, trained volunteers have measured RF exposure at more than 5,500 locations, with more than 2,000 repeat measurements, using a protocol based on the work of Prof. Dr. Magda Havas. About the data EMF Map NL is a citizen science project. Volunteers use the same calibrated meter (Safe and Sound Pro II, 200 MHz to 8 GHz) and a fixed protocol: average and peak power density at the four corners of an intersection, about 6 minutes per location. Analyses use published Dutch measurements from May 2022 to September 2025, excluding anomalies and sites near defence radar. Antenna positions come from the official Dutch Antenna Register. 1. Distance to masts and antenna density Linking about 3,000 locations per period to the nearest telecom antenna shows that exposure depends on distance and on how many antenna installations stand nearby. Median peak values within 100 m of a mast with 10 or more installations within 500 m rose from 73,775 to 176,000 µW/m². Locations 100 to 200 m from a mast rose from 11,661 to 26,500 µW/m². Most distance classes show an increase of about 2x after July 2024. This analysis is updated automatically as new measurements are published. https://emfkaart.nl/en/analysis/straling-telecom-antennes 2. Before and after the 3.5 GHz introduction (July 2024) The same pattern appears in two cuts of the same analysis. At 92 locations measured both before and after the upgrade, peak values rose by a factor of 2.8 (versus 1.2 among repeats before the upgrade); 80.4% of those locations were higher afterwards. Across 4,948 Dutch measurements, the median peak rose from 2,240 to 5,820 µW/m². Low and moderate exposure categories fell by 31%; the highest category grew by 104%. https://emfkaart.nl/en/analysis/3.5ghz https://emfkaart.nl/en/analysis/3.5ghz/herhaal-metingen 3. Plausibility check against the regulator At six locations, our values were compared with measurements by the Dutch Authority for Digital Infrastructure (RDI, Narda NBM 550). Peak values were mostly in the same range, and the differences could be explained by position and height. https://emfkaart.nl/en/analysis/rdi-vergelijking Limitations The measurements are made by volunteers with a broadband consumer meter, not by frequency-selective professional equipment. Geographic spread differs per year. The antenna register has no history, so current antenna positions are used. We cannot separate the effect of 3.5 GHz from wider network changes in the same period. All values remain below ICNIRP-based reference levels. We submit them as data on exposure trends and on the effect of antenna density, not as evidence that limits are exceeded. Why this may be useful to HHS Regulators usually take a few hundred spot measurements per year. A dense, repeatable network of street-level measurements can show changes in cumulative exposure after a network rollout, and the role of antenna density, at a scale that spot checks miss. We suggest that federal research priorities (question 16) include long-term, repeated, location-based exposure monitoring before and after new deployments, including small cells. Full methodology and datasets: https://emfkaart.nl/en/methodology