Research & federal duties

As a scientist who has done a great deal of published research in this area, I have attached a file of my published research. I have also given invited lectures in many countries all over the world on my emf research. Allan H. Frey

I submit this as an individual consumer and family member, relying on peer-reviewed research, federal reports, and court findings cited below (Qs 2, 3). Concern (Qs 5, 6): FCC's RF limits date to 1996 and address only short-term tissue heating, not chronic exposure, pulsed/modulated signals, multi-source cumulative exposure, or children's thinner skulls. In Environmental Health Trust v. FCC (D.C. Cir. 2021), the court found the FCC failed to justify that its limits protect against non-cancer harms, citing unaddressed evidence on children and long-term exposure, and remanded the issue. HHS, not FCC, should lead on the health basis for any standard. Evidence below current limits (Q12): NTP's $30M study (2018) found "clear evidence" of heart schwannomas and "some evidence" of brain/adrenal tumors in RF-exposed rats, with DNA damage reported in a follow-up (Smith-Roe et al. 2020). Italy's Ramazzini Institute independently found the same rare tumor at lower exposures comparable to cell tower emissions (Falcioni et al. 2018). IARC classifies RF-EMF as "possibly carcinogenic" (Group 2B, 2011). Reviews report oxidative stress (Yakymenko et al. 2016), reduced sperm quality (Adams et al. 2014), and DNA strand breaks (Lai & Singh 1995; REFLEX project 2004). Technologies changing cumulative exposure (Q13): 5G/small cells near homes and windows; Wi-Fi transmitting continuously in classrooms; smart meters installed on homes, often without real opt-out, pulsing near bedrooms; satellite broadband (e.g., Starlink) creating a new planet-wide RF source; networked cameras (e.g., Flock) on public poles with cellular modems and no resident notice; wireless earbuds transmitting inside the ear canal for hours daily, especially in teens; EVs producing low-frequency magnetic fields in cabins where children ride (IARC links this field type to childhood leukemia); AI data centers driving new high-voltage lines near communities; LED/"smart" lighting suppressing melatonin (AMA 2016) and adding RF transmitters with little safety study. Environmental effects (Q14): Thielens et al. (2018) found insects absorb more RF above 6 GHz, the direction 5G/6G are heading. Levitt, Lai & Manville (2021–22) reviewed reported effects on birds and insects, noting no federal environmental RF standard exists. Sensitive populations (Q11): Children, pregnant women, and implant recipients need separate risk evaluation. France restricted Wi-Fi for under-3 childcare settings in 2015. Disclosure (Q9): Residents deserve public antenna/exposure maps, advance notice before installations near homes and schools, clear device transmission labeling, and a genuine no-fee smart meter opt-out. Research priorities (Qs 10, 16, 17): Fund independent long-term cohort studies with real exposure measurement, especially in children; commission NTP follow-up at current 5G/mmWave frequencies; build a national RF/EMF environmental monitoring network; create an adverse-event reporting pathway; direct FDA to test consumer devices under realistic body-contact conditions. This research must be free of industry funding. Conclusion (Q18): We have deployed unprecedented, involuntary population-wide EMF exposure without proving it safe. Credible research has found cancer signals, DNA damage, oxidative stress, and reproductive effects. I ask HHS to investigate this independently and thoroughly, and prioritize human and environmental health over the pace of commercial deployment.

European Parliament requested a research report “Health Impact of 5G” which was released in July 2021 and concluded that commonly used RFR frequencies (450 to 6000 MHz) are probably carcinogenic for humans and clearly affect male fertility with possible adverse effects on the development of embryos, fetuses and newborns. Radiofrequency radiation is emitted by cell towers. This review paper concludes that “Based on the evidence reviewed it is our opinion that IARC’s current categorization of RFR as a possible human carcinogen (Group 2B) should be upgraded to Carcinogenic to Humans (Group 1).”

European Parliament requested a research report “Health Impact of 5G” which was released in July 2021 and concluded that commonly used RFR frequencies (450 to 6000 MHz) are probably carcinogenic for humans and clearly affect male fertility with possible adverse effects on the development of embryos, fetuses and newborns. Radiofrequency radiation is emitted by cell towers. This review paper concludes that “Based on the evidence reviewed it is our opinion that IARC’s current categorization of RFR as a possible human carcinogen (Group 2B) should be upgraded to Carcinogenic to Humans (Group 1).”

European Parliament requested a research report “Health Impact of 5G” which was released in July 2021 and concluded that commonly used RFR frequencies (450 to 6000 MHz) are probably carcinogenic for humans and clearly affect male fertility with possible adverse effects on the development of embryos, fetuses and newborns. Radiofrequency radiation is emitted by cell towers. This review paper concludes that “Based on the evidence reviewed it is our opinion that IARC’s current categorization of RFR as a possible human carcinogen (Group 2B) should be upgraded to Carcinogenic to Humans (Group 1).”

I am submitting this comment as a concerned member of the public urging HHS to undertake a comprehensive, independent investigation into the potential human and environmental health effects of the rapidly expanding electromagnetic environment created by modern technology. My concern is not based on the assumption that every wireless technology has been proven harmful. Rather, it is that society has dramatically increased the intensity, density, duration, proximity, and variety of electromagnetic exposures while the long-term biological consequences of this cumulative exposure remain incompletely understood. Today, people can be exposed simultaneously and continuously to Wi-Fi, 4G/5G and future 6G infrastructure, cell towers and small cells, Bluetooth and wireless headphones, smartphones, smart meters, wireless cameras and security systems, wearables, smart-home devices, connected and electric vehicles, wireless medical devices, satellite communications such as Starlink, and the rapidly expanding infrastructure supporting AI and data centers. The central question should therefore not simply be whether each individual device complies with an existing exposure limit. HHS should determine whether current standards adequately address real-world, cumulative, lifelong exposure from multiple sources operating simultaneously. I respectfully ask HHS to investigate potential effects on: sleep and circadian biology; hormonal and endocrine function; reproductive health and fertility; pregnancy and fetal development; neurological and cognitive function; immune and metabolic function; oxidative stress and cellular signaling; DNA integrity, repair and epigenetic processes; cancer and other chronic diseases; and children and other potentially vulnerable populations. Research should specifically examine effects that may occur below existing exposure limits and should evaluate frequency, power density, modulation, pulsing, duty cycle, beamforming, proximity to the body, duration, and simultaneous exposure to multiple frequencies. HHS itself identifies these factors as important areas for investigation. I am particularly concerned about involuntary residential exposure. Smart meters, nearby wireless infrastructure, small cells, and other continuously operating devices can expose people inside their own homes regardless of whether they personally choose to use wireless technology. Americans should have meaningful information and reasonable options for reducing unnecessary exposure in their homes, schools, workplaces, and communities. HHS should also investigate the rapidly changing exposure environment created by 5G, future 6G, satellite networks, IoT devices, autonomous vehicles, wireless charging, electric vehicles, smart cities, and other emerging technologies before assuming that older exposure research adequately represents these systems. The investigation should extend beyond human health. HHS should coordinate with appropriate federal agencies to examine potential effects on wildlife, birds, insects, pollinators, livestock, plants, and ecosystems. HHS specifically requests information concerning environmental effects and wireless infrastructure near homes, schools, childcare facilities, workplaces, and livestock. Independent research is essential. Federal research should be transparent, independently replicated, and protected from conflicts of interest. Long-term studies should measure actual exposure rather than relying solely on estimates of device use. The government should develop standardized methods for measuring individual and neighborhood exposure and consider longitudinal health studies, environmental monitoring, occupational monitoring, disease registries, biomonitoring, and adverse-event reporting. I also urge HHS to improve public transparency. Consumers, parents, schools, workers, and communities should have understandable information about the emissions and realistic exposure characteristics of wireless devices and infrastructure. The scientific evidence contains established findings, conflicting findings, emerging research, and significant uncertainty. That uncertainty is not a reason to dismiss public concern; it is a reason to investigate more rigorously. We should neither assume that modern wireless technology is harmless nor assume that every health problem attributed to EMF has been scientifically proven to be caused by EMF. We should measure the exposures, study the biology, monitor health outcomes over time, investigate potential risks, and make the evidence publicly available. The unprecedented proliferation of wireless and electrically powered technology should be matched by an equally serious commitment to understanding its long-term consequences for human health and the environment. I urge HHS to make cumulative, real-world EMF/RF exposure and its potential biological effects a significant federal research priority.

I have been dealing with EMF issues for 6 years now. I'm 76yrs old and have a 90 yr old husband that I have been trying to take care. There is so much to eexplain. But. Unfortunately I can't be on this cell phone long enough. But thank God your doing research. Maybe people like me will get some help with the EMF issues. I wouldn't wish this on my worst enemy!

Comment on Docket HHS-OASH-2026-0397 Perspective (Q1): Individual / adult educator in a community Lifelong Learners setting. Not a physician. I teach practical exposure-reduction, not products. Q8 — What should be disclosed People need plain-language facts at the point of use: phones are radio transmitters; distance drops exposure sharply; night-time household wireless can be switched off; wearables and routers add to the load even when you are not “on a call.” Federal consumer and school guidance should say that in one page, without a store attached. Q10 — Sensitive populations Exposure assessment should treat children, pregnant women, and those with implants or unexplained symptoms as groups that may need extra caution while the science is incomplete — not as proof of a single disease. Schools and childcare should have the option of wired connections and phones stored off the body. Q11 — Evidence below current U.S. limits IARC classified RF electromagnetic fields as *possibly carcinogenic to humans* (Group 2B, 2011). The National Toxicology Program reported tumor findings in male rats after long-term RF exposure. The D.C. Circuit in *Environmental Health Trust v. FCC* (2021) found the FCC had not adequately explained its decision to retain 1996-era limits in light of subsequent evidence on children and long-term exposure. Those three items are enough to justify a current HHS evidence review. They are not, by themselves, a diagnosis of any person. Q15 — Research priorities Highest gaps: real-world *cumulative* exposure (phone + Wi-Fi + infrastructure), non-thermal biological endpoints, pediatric and in-utero cohorts, and independent replication of NTP-type work at current waveforms (including 5G). Coordination: NIH for biology, FDA for device emissions and labeling, CDC for school/community guidance. Practical recommendation While agencies update the science, HHS can publish the same three habits already used in many public-health pages: increase distance, take the phone off the body, turn household transmitters down or off at night. That does not require a new standard to be finished first. Thank you for this opportunity to comment.

I have a 5G tower placed near my home in the country 2 years ago and since then have developed random headaches and insomnia with no previous history of either. All health tests done render me healthy and doctors have no understanding of where these symptoms are coming from. Strangely, we go camping far north every end of summer for a couple of weeks with no towers anywhere and my symptoms are no longer. How can being in the vicinity of a 5G tower & having symptoms, and then being outside of any tower's reach which brings relief from said symptoms not induce inquiry? No type of technology is worth the degradation of even one life, but many lives are at risk because these towers are so numerous everywhere now. Are we as a country willing to say that we knew that people were being negatively affected and looked the other way? Wasn't it Theodore Roosevelt that said "The man who knows the truth and has the opportunity to tell it, but who nonetheless refuses to, is among the most shameful of all creatures' God forbid that we should ever become so lax as that." EMFs are damaging the cells of every body and no one can escape unscathed. So many things that happen in this world are out of our control, but this can be regulated and can be improved.

Dear HHS, I am writing as an individual concerned about the potential health effects of exposure to electromagnetic radiation from wireless technology, including Wi-Fi routers and cell phones. I first became aware of a possible connection between my own sleep and exposure to wireless radiation approximately ten years ago. I was visiting a friend who had placed a Wi-Fi router underneath the guest bed. My son and I were unable to sleep properly for three nights. When we discovered that the router was directly underneath the bed and disconnected it, we were subsequently able to sleep normally. That experience made me much more attentive to my environment and to the possible effects of wireless exposure. Since then, I have devoted considerable time and effort to reducing wireless exposure in my home. I have even worked with a consultant who specializes in this area to help me create a wireless-free environment and reduce unnecessary exposure to wireless signals and cell phones. I recognize that individual experiences do not, by themselves, establish scientific causation. However, I know from my own experience that I notice significant physiological effects, particularly with respect to sleep, when I am exposed to certain wireless environments. This has led me to believe that this subject deserves continued serious and independent scientific investigation. I respectfully encourage HHS to look carefully at the existing research on electromagnetic radiation and wireless technologies and to support further research into possible physiological effects, including effects on sleep and other aspects of human health. I also believe it is important to listen to people who report experiencing symptoms or changes in their well-being associated with wireless exposure, even when the scientific understanding of those experiences remains incomplete. Thank you for your attention to this matter and for providing an opportunity for members of the public to be heard on an issue that I believe deserves thoughtful scientific consideration. Sincerely, Lydia MacLear