ORIGINAL COMMENT · UNEDITED TEXT
Re: ET Docket No. 13-84 — RF Exposure Issues Subject to Remand in Environmental Health Trust v. FCC
To the Federal Communications Commission:
I submit this comment as a member of the public concerned that the FCC’s current radiofrequency (RF) exposure standards and testing procedures may not fully reflect today’s communications environment.
Wireless technology provides enormous benefits. My concern is not opposition to Wi-Fi, cellular networks, satellites, wearables, 5G, 6G, or emerging systems. My concern is that safety testing and regulatory review should evolve as rapidly as the technology itself.
The Commission should not presume that RF exposure below existing limits is harmful where causation has not been established. But scientific uncertainty should not automatically be treated as proof of safety.
REAL-WORLD AND CUMULATIVE EXPOSURE
People may now be exposed simultaneously to phones, Wi-Fi routers, Bluetooth devices, wearables, computers, connected vehicles, smart-home devices, cellular infrastructure, satellites, and other RF sources. The FCC should examine whether its framework adequately evaluates aggregate and cumulative exposure rather than considering devices mainly in isolation.
Testing should reflect foreseeable use, including devices against the body, near the head, worn for long periods, and operating multiple radios simultaneously. Where relevant, it should also consider multiple frequencies, modulation, pulsed transmissions, beamforming, and changing duty cycles.
LONG-TERM EXPOSURE AND CHILDREN
Modern exposure can occur throughout the day and over decades. The FCC should distinguish short-term exposure from chronic, cumulative, and lifetime exposure.
Children deserve specific analysis because they may begin using wireless devices early and experience exposure over much longer portions of their lives. The Commission should clearly explain the scientific basis for concluding that its limits and testing procedures adequately protect children.
NON-CANCER EFFECTS
The Commission should rigorously evaluate credible evidence concerning possible non-cancer effects, including neurological, cognitive, reproductive, oxidative, and other biological endpoints. Inconsistent findings or methodological limitations should lead to careful analysis, not blanket acceptance or dismissal.
The FCC should identify which findings have been replicated, whether credible dose-response relationships exist, how exposure was measured, whether appropriate controls were used, whether confounding factors were addressed, and whether observed biological changes represent actual adverse health outcomes at exposures relevant to FCC limits.
ENVIRONMENTAL EFFECTS
Environmental impacts also deserve meaningful investigation. Research should distinguish possible RF effects from tower lighting, collisions, habitat disruption, construction, and other confounding factors. A lack of high-quality independent field studies should be identified as a research gap, not automatically treated as evidence of no effect.
PRIVACY, SECURITY, AND MALICIOUS USE
As RF-dependent technology becomes ubiquitous, the FCC should also recognize related privacy and cybersecurity risks, either here where relevant to technological developments or through a separate proceeding.
RF energy itself does not collect personal information. However, wireless systems can create mechanisms through which devices may be identified, tracked, impersonated, disrupted, or subjected to unauthorized interception. Documented concerns include rogue cellular base stations, rogue Wi-Fi access points, wireless identifiers, Bluetooth vulnerabilities, spoofing, jamming, interference, and techniques capable of distinguishing devices through characteristics of their RF transmissions.
As wireless systems expand, regulators should consider unauthorized tracking, location-related metadata, RF fingerprinting, malicious interference, and transparency about what systems transmit, collect, infer, retain, or disclose.
REQUESTED ACTION
I respectfully ask the FCC to modernize RF compliance testing; evaluate aggregate, long-term, and lifetime exposure; specifically address children; transparently evaluate non-cancer effects; identify replicated and unreplicated findings; support independent environmental and human-exposure research; improve public access to testing methods and assumptions; and establish recurring review of RF standards as technology evolves.
The United States can lead in communications technology while also leading in independent research, transparent safety standards, privacy protection, and realistic exposure assessment.
Scientific uncertainty should lead to better measurement, better research, and better safeguards—not complacency.
Respectfully submitted,
Official attachments · 3
Attachment contents are not included in the category review.