Letter to FCC Chairwoman Rosenworcel

May 18, 2021

The Honorable Jessica Rosenworcel Commissioner
Federal Communications Commission
445 12th Street, S.W.
Washington, DC 20554

Dear Chairwoman Rosenworcel,

We are writing to request that the FCC ensure an up to date examination of its wireless radio-frequency microwave radiation regulations by reopening Docket 13-84 (“Reassessment of FCC Radiofrequency Exposure Limits and Policies”) to refresh the record before issuing its final response to the mandate of the 8-month-old August 13, 2021 ruling by the U.S. Court of Appeals for the District of Columbia Circuit, in Environmental Health Trust et al. v. the FCC.

A 2020 GAO Report on wireless technology noted that federal agencies have only reviewed a subset of the relevant research.1 There is no federal agency with health or environmental expertise ensuring existing cell towers and any 4G/5G so-called “small” Wireless Telecommunications Facilities (sWTFs) do not cause biological harm or negative health consequences for we the people of the United States.. It is a regulatory gap.

Thus, in order to provide a comprehensive basis of evidence, before issuing its response to the DC Cir., the FCC should ask the relevant U.S. health and environmental agencies to systematically review the science that relates to their respective expertise, perform hazard/risk analysis, and offer science-based recommendations.

Several major studies on radio-frequency, human health and the environment have been published since this FCC Docket 13-84 was closed in 2019.2 If the FCC does not reopen its docket, the FCC’s review, and thus its conclusions, would again be deficient because it would have excluded a review of the last two years of published science on the matter.

The totality of the science should be evaluated in a transparent process and proper federal radio-frequency microwave radiation maximum public exposure limits should be based on this full scientific review. We also urge the FCC to refresh the record by reopening Docket 13-84 in order to update the evidence of actual documented human harm from the irresponsible placement of Wireless Telecommunications Facilities (WTFs) of any size of any “G” since 2019 There has been a large volume of such evidence already placed in the FCC’s record.

Wireless radio frequency microwave radiation is bioactive and is currently being insufficiently regulated., consistent with the scientific findings from over 11,000+ pages of peer-reviewed, scientific evidence that the Environmental Health Trust and Children’s Health Defense and others plaintiffs placed in the FCC’s public record: Vol-1, Vol-2, Vol-3, Vol-4, Vol-5, Vol-6, Vol-7 Vol-8, Vol-9, Vol-10, Vol-11, Vol-12, Vol-13, Vol-14, Vol-15, Vol-16, Vol-17, Vol-18, Vol-19, Vol-20, Vol-21, Vol-22, Vol-23, Vol-24, Vol-25, Vol-26 and Vol-27.

New wireless facilities are being proposed for our community and residents are questioning how FCC RF microwave radiation exposure limits can fulfill the FCC’s very mission: “for the purpose of promoting safety of life and property” (U.S.C Title 47 § 151 Purposes of Federal Communications Commission) — as there has been no scientific evaluation in response to the Aug 13, 2021 DC Cir. mandate for the FCC to do so.

We thank you for your attention and response to this critically important request.

  1. US Government Accountability Office, 5G Wireless: Capabilities and Challenges for an Evolving Network. U.S. GAO, November 24, 2020 — https://www.gao.gov/products/gao-21-26sp  ↩
  2. Levitt BB, Lai HC, Manville AM. (2021) Effects of non-ionizing electromagnetic fields on flora and fauna, Part 3. Exposure standards, public policy, laws, and future directions. Rev Environ Health. Sep 27. ; Choi Yoon-Jung et al., (2020) Cellular Phone Use and Risk of Tumors: Systematic Review and Meta-Analysis. International Journal of Environmental Research and Public Health. 17(21), 8079; Schuermann, David, and Meike Mevissen (2021) “Manmade Electromagnetic Fields and Oxidative Stress—Biological Effects and Consequences for Health” International Journal of Molecular Sciences 22, no. 7: 3772.; Halgamuge MN, Skafidas E, Davis D. (2020) A meta-analysis of in vitro exposures to weak radiofrequency radiation exposure from mobile phones (1990–2015) Environmental Research, Volume 184; Uche, U.I., Naidenko, O.V. (2021) “Development of health-based exposure limits for radiofrequency radiation from wireless devices using a benchmark dose approach.  ↩