ACTION ALERT-Submit Comments to FCC on Proposed New Wireless Radiation Rules - Moms Across America

ACTION ALERT-Submit Comments to FCC on Proposed New Wireless Radiation Rules

The following information was adapted from Environmental Health Trust:

The Federal Communications Commission (FCC) in the U.S. has released new rules regarding radio frequency (RF) exposure limits, cell phone testing procedures, etc. The new rules extend the original RF exposure limits adopted in 1996 to higher frequencies which include 5G and millimeter waves. The rules are still not based on bioeffects or health effects research. Rather the rules are based on behavioral changes observed in lab animals which physicists and engineers consider to be "thermal effects."  Hence, the new rules pave the way for the deployment of 5G infrastructure and other new wireless technologies including wireless power jeopardizing the health of the public and the environment.

The FCC opened Docket No. 19-226 for public comments on their proposed rules.  The deadline for submission of comments has been extended to JUNE 17 2020.

In making a decision whether to adopt these new rules, the FCC is only required to consider information submitted to this docket.  And, they can only be held to account legally for making an inappropriate or bad decision if the information showing that they did so is in this docket.  Thus, your submission of comments and/or studies to this docket is critical. Please see below for details.

Here's what the FCC is considering: 

Issue #1: The FCC is planning to establish "safe" human exposure guidelines to ultra-high frequencies, above 100 Gigahertz (GHz). (Click here to read more
Issue #2: The FCC is considering allowing manufacturers to average the radiation output of consumer devices over time. (Click here to read more.
Issue #3: How should the FCC regulate Wireless Power Transfer (WPT) technology that can wirelessly charge devices while the user is in motion? (Click here to read more.

Everyone can file comments to ensure the FCC has the scientific facts on the record. Please consider submitting a filing (a statement, scientific research, see below) to the FCC. It is critical that the FCC hear from the public and experts.

  • Please ensure your submission has documented scientific evidence showing a biological effect from non-ionizing electromagnetic radiation. Important --  If you have links to scientific studies please state the following, “Links hereby incorporated by reference” to ensure that the study becomes a part of the record. Or paste the entire study or citation with full reference into the comments.
  • Please be sure to clarify what you think the impact will be if the FCC allows rules to move forward. Some things you should know about the rules.
  • They set allowable limits for the higher frequencies to be used in 5G based on heating only, not biological impacts. The rules ask questions about how to measure the radiation with averages--despite the fact that averaging is an inadequate way to measure these frequencies in terms of biological effects.

See the filing in the Federal Register here that your comments are responding to  Human Exposure to Radiofrequency Electromagnetic Fields A Proposed Rule by the Federal Communications Commission.

You must comment before the end date of May 15, 2020.


Instructions for submitting "Standard Filing" comments with attachments.

Short Video instructions here too: https://www.youtube.com/watch?v=UlkGGwtNF4Y 

1. Click on this link https://www.fcc.gov/ecfs/filings

2. Click on "Submit a Filing" navy blue Tab, at the top of the page.

3. Click on "Standard Filing" Tab.

4. Fill out all "required" fields and click "Enter" or "Return" before you go to the next field. The field should turn yellow when you click enter.


Required Fields are:

  • "Proceeding(s)" - Type in 19-226

  • "Name(s) or Filer(s)" - Type in your name - Click enter

  • "Primary contact email" - This is optional, but you may want to include to get an email confirmation of your submission.

  • "Type of Filing" - Click "Comment"

  • "Address Of" - Click "Filer"

  • "Address" - Type in your address

  • "City", "State" and "Zip" - Type in your city, state and zip code. Be sure to click enter after completing each field.

  • "Upload Documents" - You can drag and drop up to 5 files as long as they are less than 25 MB. If you have additional files you will need to submit multiple times. You may attach studies ( after downloading) to the submission from https://www.momsacrossamerica.com/rfr_studies

  • You can click on "email confirmation" to get a confirmation of your submission emailed to you. (You have to include an email address above if you want this.)


5. Once all fields are filled - click on the blue button "continue to review screen".


6. Review your submission and click submit.


7. Make sure you write down your confirmation # so that you can check on your submission.


Issue 1

Sample Comment: The FCC's repeated refusal to consider biological effects from exposure to all types of wireless radiation shows a clear and dangerous intention to disregard the emerging science which must inform its decisions regarding public health.

The agency's reliance on organizations of physicists and engineers for advice on human exposures has resulted in a sole focus on "thermal" effects, despite thousands of published, peer-reviewed studies showing biological harm, even at non-thermal levels, for various frequency ranges.

The FCC's own admission that it is unaware of any other types of effects demonstrates a failure to actively investigate the issue by proactively engaging with the scientific community studying the short and long-term biological impacts of exposure to humans and possible interference with systems of the natural world. Failure to seek out and consider the latest science makes decisions of the FCC suspect. 

Moreover, the complex comment process used by the FCC virtually ensures that most commenters will be those who follow the activities of the agency closely and have a financial interest in the agency's decisions.  

Issue 2

I do not support the proposed change to allow manufacturers to produce wireless devices that govern their own radiation power output, especially for notebooks and tablets frequently used by children who, according to the International Agency for Research on Cancer (IARC), are more vulnerable to RF radiation than adults.

Since the justification for this proposed rule change is that manufacturers want to be able to deliver more data to notebooks and tablets, it seems obvious that this change would result in higher exposures for users.

I object to the practice of allowing exposures to be averaged over time to comply with FCC exposure limits. There is no scientific basis to support the notion that short, periodic bursts of RF radiation are not biologically harmful, or that only cumulative effects over time may have an impact. The FCC should establish temporal limits for both Specific Absorption Rate (SAR) and power density.

Further, I agree with the American Academy of Pediatrics that the FCC's current method of testing wireless devices is not reflective of the way people actually use technology today. Given the increasing use of wireless devices by children and adolescents, we encourage the FCC to seek out and utilize testing protocols that reflect real-world situations. 

Issue 3

Sample Comment: I recommend that before the agency considers even tentative approval of WPT devices operating at ranges in excess of 50 cm, it requires manufacturers to conduct pre-market testing to demonstrate the safety of such devices when used in all possible “worst case” scenarios, including mitigation techniques to avoid inadvertent or collateral damage to the public. Such an analysis must include consideration of biological impacts. 

The issues here are very significant. How will this impact an older person with an implanted cardiac pacemaker who uses a remote charger to charge his cell phone while he is moving around with the phone in his shirt pocket?  Or consider the couple trying to get pregnant if the man's phone is frequently being charged wirelessly in the front pocket of his pants, with the beam irradiating his testicles?

What kind of human is the FCC considering protecting? What size, shape, age, and with what kind of underlying medical problem or weakness? I urge the agency to consider updating its standard anatomical models to reflect the wide variety of possible users. 

Insert any comment here about a personal situation regarding wireless power transfer.  If you include links to scientific studies please state the following: “Links hereby incorporated by reference” to ensure that the study becomes a part of the record. To submit a PDF of the study itself, please use the standard comment form that allows attachments to be uploaded along with your comment, not the Express comment form.


How to File to the FCC Docket No. 19-226

  • Online: Go to the  Federal Communications Commission’s Website: https://www.fcc.gov/consumers/guides/how-comment. Go to the top of the page where it states “Submit a filing” Click on that. Fill out the form.
    • Under Proceedings put in 19-226.  Be sure to get a confirmation number.
  • Mail: Filings can be sent to the Commission’s Secretary, Office of the Secretary, Federal Communications Commission.
  • People with Disabilities: Contact the Commission to request reasonable accommodations (accessible format documents, sign language interpreters, CART, etc.) by email: FCC504@fcc.gov or phone: 202-418-0530 or TTY: 202-418-0432.

Remember, you must comment before the end date of May 15, 2020.

Detailed instructions related to the content of submissions

General:  Please ask the FCC to request the FDA to establish biologically-based population-protective limits for all electronic product radiation, as they are statutorily required to do (http://www.electricalpollution.com/documents/PressReleaseFDANegligence12Feb2020.pdf).  The FCC has readily acknowledged that they lack the expertise to set safety limits themselves so they should be asking the FDA to do so.  Specifically, any limits should be readily measurable on location, necessitating the use of maximum permissible exposure (MPE) field strength and power density.  Although thermal effects must be a backstop (just like immediate toxicity for chemicals) and NO MPE should be allowed whose corresponding SAR would result in thermal harm, long-term biological effects of chronic exposure should guide the formation of population-protective RF/MW safety limits.  This is what the BioInitiative Recommendations are based on.  The FCC and FDA should adopt the latest BioInitiative recommendations in the interim as they begin to set up their own continuous review program to revise those recommendations as additional studies show that reductions and refinements are needed.  Limits for higher frequencies should be established using available literature and FDA should commission additional studies to further determine safety limits that prevent adverse biological effects using techniques like the one recommended by Dr. Martin Pall to test for inappropriate voltage-gated ion channel activation https://www.ncbi.nlm.nih.gov/pubmed/25879308.  Addressing paragraph 120, peak exposure levels should be used to determine compliance, not averages, because peak measurements are more predictive of adverse biological effects.
 
Any comment only needs to be submitted once, but be sure to get a confirmation number.  Any further references can either be submitted as standalone documents if they speak for themselves or with a cover letter discussing what you think the FCC should learn from that particular document or set of documents and how it should influence their decision and actions, include a reference to a particular question where appropriate.  These arguments can be used later legally, but only need to be made once if they are generally applicable.

Experts: Your comments are very important, please address the specific technical questions asked and proposals being made (***p.56-72 of FCC 19-126 (https://docs.fcc.gov/public/attachments/FCC-19-126A1.pdf).  The FCC is most likely to listen to answers that specifically address their questions and proposed actions.  You are not necessarily limited in addressing them e.g. they want to know how to average exposures, but biological responses are often not best predicted by averages.  It is fine to disapprove of their proposal, but please elaborate and support your answer with peer-reviewed published papers as much as possible.

Concerned individuals: Please make a statement about the reason for your concern and provide references to studies published in peer-reviewed journals as support if you can.
 
Injured individuals: Ideally your submission will contain your personal statement documenting biological harm, including any experiential evidence you can offer sowing that the harm is indeed caused by electronic product radiation (http://www.electricalpollution.com/documents/PressReleaseFDANegligence12Feb2020.pdf) (e.g. you feel better when it is turned off or you leave the area, especially any “blinded” exposures that illustrate the connection), a doctor’s letter stating the connection as their medical opinion, and scientific studies supporting the connection.

Some excerpts from the newly proposed rules found at  Human Exposure to Radiofrequency Electromagnetic Fields: A Proposed Rule by the Federal Communications Commission.

The FCC referenced the FDA as a source showing there is no danger to children from cellular radiation, “With respect to any special considerations for children and consumer information, we refer to the FDA website, which states that “[t]he scientific evidence does not show a danger to any users of cell phones from RF exposure, including children and teenagers.”

The FCC also again quotes the FDA as part of their proof of safety for these higher frequencies stating, “I want to underscore that based on our ongoing evaluation of this issue and taking into account all available scientific evidence we have received, we have not found sufficient evidence that there are adverse health effects in humans caused by exposures at or under the current radiofrequency energy exposure limits. Even with frequent daily use by the vast majority of adults, we have not seen an increase in events like brain tumors. Based on this current information, we believe the current safety limits for cell phones are acceptable for protecting public health.”

The FDA reaffirms the limits as based on heating only, ignoring biological effects, and states, “We are unaware of any reason the limits should be different above 100 GHz than across the already existing wide frequency range. As the difference in body penetration further diminishes towards zero, there is no apparent reason to expect that thermal effects will effect change in the increasingly higher frequencies. Accordingly, we propose to extend the same constant exposure limits that presently apply from 6 GHz to 100 GHz up to an upper frequency of 3,000 GHz (3 THz), which is considered to be the upper bound of existing radiofrequency bands.”

“The Commission’s RF exposure rules do not yet specify a spatial maximum power density limit for localized exposure at higher frequencies. As portable devices are being developed for operation at higher frequencies for future 5G services in millimeter-wave bands, we propose a general localized power density exposure limit above 6 GHz of 4 mW/cm2 averaged over 1 cm² for the general population or uncontrolled exposure, applicable up to the upper-frequency boundary of 3 THz, also proposed above.”

“The Commission further seeks comment on what factors it should consider ensuring that the RF beam from the transmitting unit is closely concentrated at the receiving unit, such that RF energy along the path(s) does not exceed the applicable RF exposure limit for any human that may be situated along the path(s)…”

“If the Commission establishes power limits, what should be the basis for such limits, and should any consideration be given to potential harmful interference to other non-part 18 devices, given the popularity of these ISM frequency bands for consumer devices? With respect to the potential for harmful interference from wireless power transfer devices to active medical devices that may be worn or implanted (e.g., body-worn insulin pumps, implantable cardiac pacemakers, implantable deep brain stimulators (DBS), spinal cord stimulators, and the like), what mitigation techniques should be required?”

https://ehtrust.org/action-alert-submit-comments-to-the-fcc-on-5g-and-cell-tower-radiation/


Showing 3 reactions

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  • Zara Zay
    commented 2020-05-15 14:52:47 -0700
    5G is a military weapon. There are ZERO safety studies. Top scientists around the world concur this roll out to be an exponential increase in radiation exposure and children are most at risk. I do not consent!!!
  • Jacquelina Carmen De Losrios
    commented 2020-05-12 01:22:36 -0700
    I’m totally,completely,fully and 100 per cent, AGAINST the 5G and also against all kind of wireless devices and the installation of the tours and satellites ,this is the biggest crime against Humanity and the destruction of our planet , I’m Furious ! This must stop,We have the right to live ! Powerful people are taking advantage of the ignorance of the simple people
  • Aja Puglisi
    commented 2020-04-29 11:25:23 -0700
    I agree with all of the above but it’s ALOT to take in and don’t know where to start not what to say exactly. Any example letters to follow?

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