CELLULARPHONES.ORG / RF SAFE — COMMENT WORKSHEET Prepared September 18, 2026. Review, personalize and verify every claim. These are advocacy starters, not submitted comments. Deadline status: HHS October 21 is expected only if publication is September 21; FCC calendar deadline unverified. Check official records. HHS: https://www.regulations.gov/docket/HHS-OASH-2026-0397 FCC: https://www.fcc.gov/ecfs/filings/express?proceeding%5Bname%5D=13-84 Do not include private medical or child-identifying information. Save your official filing confirmation. HHS COMMENT STARTER ======================================== Re: HHS-OASH-2026-0397 — RF/EMF and Wireless Radiation Exposure I submit this comment as a concerned member of the public. I support stronger, independently assessed wireless-radiation protections and practical reduction of unnecessary exposure, especially for children. Perspective: Question 2. My requests address Questions 5–18 as indicated below. I ask HHS to translate this record into an accountable research and health-protection program. MY PERSPECTIVE [Add your own reason for participating. Remove this placeholder before filing.] REQUESTED ACTIONS 1. Independent, health-based risk assessment Questions 5, 6 and 12: Commission an independent health-based review of exposure limits, including cancer, reproduction, development and neurological endpoints. Publish study-level evidence tables, dosimetry, benchmark-dose choices, uncertainty factors and sensitivity analyses. Explain where compliance metrics do and do not establish protection. 2. Fund Public Law 90-602 implementation Questions 16 and 17: Publish and fund an implementation plan for the electronic-product-radiation responsibilities in 21 U.S.C. 360hh–360ss, originating in Public Law 90-602. Support chronic, developmental and mechanism research; exposure surveillance; techniques that minimize unnecessary exposure; and public reporting. Coordinate FDA, NIH, CDC and relevant EPA expertise with accountable milestones. 3. Children, pregnancy and real-world exposure Questions 7–11 and 13–15: Improve near-body and cumulative-exposure measurement. Include carrier frequency, SAR, electric and magnetic fields, pulse and modulation characteristics, duty cycle, beamforming and simultaneous radios. Evaluate children, pregnancy and other potentially susceptible groups separately. Build exposure-linked surveillance while distinguishing RF effects from screen behavior and other environmental stressors. 4. Reform Section 704's RF preemption provision Questions 5 and 18: Assess the public-health consequences of 47 U.S.C. 332(c)(7)(B)(iv), which makes compliance with FCC RF rules the condition for preempting state and local RF-based siting regulation of personal wireless facilities. Recommend that Congress revisit or repeal that provision where it prevents health-protective local decisions. This is a legislative reform request, not a claim that the statute has already been invalidated. 5. Li-Fi compatibility and lower-RF infrastructure Questions 5, 9, 13, 15 and 18: Evaluate fiber, Ethernet and optical wireless alternatives that can reduce avoidable indoor RF. Support a phased Li-Fi interoperability and device-compatibility requirement, school and federal-building pilots, transparent exposure comparisons and usable radio-off options. Assess optical safety, flicker, cost, access, reliability and emergency connectivity. Consider RF Safe's Clean Aether Act model statute as a legislative proposal. 6. Waveform-aware, independent mechanism studies Questions 5, 12, 16 and 17: Fund preregistered, blinded, independently replicated studies of calcium timing, membrane voltage, mitochondrial recovery and redox signaling across well-characterized waveforms. Test RF Safe's low-fidelity-biology hypothesis using measurable endpoints, including recovery time and genotype. Report null results and thermal controls, publish raw data and disclose standards-setting, industry and advocacy roles. SELECTED SUPPORTING EVIDENCE [1] National Toxicology Program. Technical Report 595, 2018; agency study summary. NTP's lifetime rat bioassay reported clear evidence of malignant heart schwannomas and some evidence of malignant gliomas in exposed male rats. I request an independent quantitative assessment of the relevance of these hazard findings to human protection, with exposure and species differences explicitly modeled. Exposure / interpretation: Whole-body 900 MHz GSM/CDMA exposures, 1.5–6 W/kg, over approximately two years. Not a handset-use dose estimate; findings differed by sex and species. Source: https://ntp.niehs.nih.gov/whatwestudy/topics/cellphones [2] Mevissen M et al. Environment International. 2025;199:109482. Corrigendum: 2026;214:110368. The WHO-commissioned animal-cancer review rated evidence high certainty for glioma and malignant heart schwannoma in male rats. I ask HHS to assess these endpoint-specific hazard findings explicitly, including the corrigendum, and publish the implications for a health-based exposure standard. Exposure / interpretation: 52 animal studies; certainty is endpoint-specific. It does not mean high certainty of cancer from ordinary phone use in humans. Read the linked corrigendum. Source: https://pubmed.ncbi.nlm.nih.gov/40339346/ Correction: https://pubmed.ncbi.nlm.nih.gov/42442967/ [3] Melnick RL, Moskowitz JM. Environmental Health. 2026;25:42. DOI: 10.1186/s12940-026-01288-6. Melnick and Moskowitz's 2026 risk assessment derives reference levels below the public whole-body limit using benchmark-dose and uncertainty-factor methods. I request independent reanalysis of their cancer and reproductive calculations, including duration assumptions, low-dose extrapolation and human variability. Exposure / interpretation: Rat-data extrapolation, a one-in-100,000 excess cancer-risk target and exposure-duration assumptions produce the reported ratios. These are proposed estimates, not an EPA finding or adopted limit. Source: https://doi.org/10.1186/s12940-026-01288-6 [4] Cordelli E et al. Environment International. 2024;185:108509; corrigendum 2025;198:109449. The Cordelli male-fertility review and its corrigendum deserve explicit consideration in standards assessment. The corrected pregnancy-rate endpoint after male-animal exposure is identified as high certainty by Melnick and Moskowitz. I request a reproductive-risk assessment, including sperm outcomes and exposure-response uncertainty. Exposure / interpretation: This endpoint concerns male reproductive capacity, not every effect of exposure during pregnancy. Many studies used exposures above typical environmental levels; certainty varies across outcomes. Source: https://doi.org/10.1016/j.envint.2024.108509 Correction: https://doi.org/10.1016/j.envint.2025.109449 Legal source: 21 U.S.C. 360ii — https://www.law.cornell.edu/uscode/text/21/360ii Legal source: 47 U.S.C. 332(c)(7)(B)(iv) — https://www.law.cornell.edu/uscode/text/47/332 Proposed model statute (not enacted law): https://rfsafe.net/hhs-fcc-action/assets/documents/clean-aether-act-2026-model-statute.pdf I request a public response identifying what action will be taken, which uncertainties will be investigated, who is responsible, and when the public can expect results. Protecting children and future generations should be an explicit measure of success. FCC COMMENT STARTER ======================================== Re: ET Docket No. 13-84 — DA 26-997, RF-Exposure Remand I submit this comment as a concerned member of the public. I support stronger, independently assessed wireless-radiation protections and practical reduction of unnecessary exposure, especially for children. I ask the FCC to provide a reasoned response to the evidence within the 2021 remand, including non-cancer effects, children, long-term exposure, testing, technological change and environmental effects. MY PERSPECTIVE [Add your own reason for participating. Remove this placeholder before filing.] REQUESTED ACTIONS 1. Independent, health-based risk assessment Provide a reasoned, evidence-specific response to non-cancer health effects, children, long-term exposure and other issues returned by the D.C. Circuit. Explain the basis for protective assumptions and request an updated independent HHS health assessment. Publish the analyses underlying any decision to retain or revise testing and exposure rules. 2. Fund Public Law 90-602 implementation Coordinate with HHS/FDA's electronic-product-radiation program under Public Law 90-602, now codified at 21 U.S.C. 360hh–360ss. Request a current health assessment and make the interagency scientific record and follow-up timetable public. 3. Children, pregnancy and real-world exposure Address the remand's child, long-term-exposure, testing and environmental issues with evidence specific to real use. Evaluate near-body contact, simultaneous radios, adaptive power, cumulative duration, modulation and duty cycle. Examine how population variability and susceptible groups are represented in testing assumptions and safeguards. 4. Reform Section 704's RF preemption provision Document the consequences of relying on current RF-compliance rules under 47 U.S.C. 332(c)(7)(B)(iv). Recommend that Congress revisit or repeal that preemption provision to restore meaningful health-protective authority. I recognize that Congress, not this comment proceeding alone, must amend the statute. 5. Li-Fi compatibility and lower-RF infrastructure Within the appropriate authority, evaluate and support lower-RF connectivity choices, including fiber/Ethernet backhaul and interoperable optical wireless links. Recommend a phased Li-Fi compatibility program, measured school pilots and genuine radio-off controls, while preserving reliability, accessibility and emergency service. Recommend legislation where agency authority is insufficient. 6. Waveform-aware, independent mechanism studies Explain how waveform-dependent biological findings are evaluated beyond averaged absorption alone. Request independent, blinded work on calcium timing, membrane potential, mitochondrial recovery and redox endpoints, with thermal monitoring, genotype-aware designs and open data. Disclose institutional, funding and standards-setting roles and resolve methodological disputes transparently. SELECTED SUPPORTING EVIDENCE [1] Smith-Roe SL et al. Environmental and Molecular Mutagenesis. 2020;61:276–290. DOI: 10.1002/em.22343. Smith-Roe and colleagues found RF-associated DNA damage in selected tissues using the comet assay, but not increased micronucleated red blood cells. I request a reasoned evaluation of the positive tissue-specific findings and independent replication with complementary assays. Exposure / interpretation: Subchronic exposure; rats 900 MHz, mice 1,900 MHz. Micronucleated red-blood-cell frequency did not significantly increase. DNA endpoints are not interchangeable. Source: https://pubmed.ncbi.nlm.nih.gov/31633839/ [2] Foerster M et al. Environmental Health Perspectives. 2018;126:077007. DOI: 10.1289/EHP2427. Foerster and colleagues reported adverse figural-memory associations in selected adolescent analyses using estimated brain RF dose. I request replication with improved dosimetry, operator data and controls for screen-use behavior, rather than treating adult averages as sufficient evidence for children. Exposure / interpretation: Swiss adolescents followed for one year. The whole-sample estimate included no effect within its confidence interval; modeled exposure and residual confounding remain important. Source: https://pubmed.ncbi.nlm.nih.gov/30044230/ [3] Sousouri G et al. NeuroImage. 2025;317:121340. DOI: 10.1016/j.neuroimage.2025.121340. Sousouri and colleagues reported a CACNA1C-genotype-dependent sleep-spindle response after 3.6 GHz exposure. I request larger blinded replications and functional follow-up, because a population average may miss susceptibility differences. The reported EEG response should be evaluated, not automatically equated with disease. Exposure / interpretation: 34 genotyped volunteers; 30-minute pre-sleep exposure to 700 MHz or 3.6 GHz. A physiological EEG response does not by itself establish injury or electromagnetic hypersensitivity. Source: https://pubmed.ncbi.nlm.nih.gov/40541756/ [4] Engels S et al. Nature. 2014;509:353–356. DOI: 10.1038/nature13290. Engels and colleagues demonstrated disruption of migratory-bird magnetic orientation by anthropogenic electromagnetic noise under blinded conditions. I request ecological assessments that address sensitive biological mechanisms and distinguish exposure spectra rather than relying only on human thermal limits. Exposure / interpretation: Broadband noise in the 50 kHz–5 MHz range; not a direct test of GHz Wi-Fi, cellular signals, or human health. Source: https://pubmed.ncbi.nlm.nih.gov/24805233/ Legal source: 21 U.S.C. 360ii — https://www.law.cornell.edu/uscode/text/21/360ii Legal source: 47 U.S.C. 332(c)(7)(B)(iv) — https://www.law.cornell.edu/uscode/text/47/332 Proposed model statute (not enacted law): https://rfsafe.net/hhs-fcc-action/assets/documents/clean-aether-act-2026-model-statute.pdf I request a public response identifying what action will be taken, which uncertainties will be investigated, who is responsible, and when the public can expect results. Protecting children and future generations should be an explicit measure of success.