Selected
FCC Submissions re: 


“Reassessment of Federal Communications
Commission Radiofrequency 

Exposure Limits and Policies”
(Proceeding Number 13-84)


Part I: Key Testimony Submitted to the FCC



Last revision: Aug 12, 2019
The FCC received more than 1,200 submissions regarding its cell
phone radiation regulations. These documents reveal what we know about wireless
radiation health effects, and why we need to strengthen regulations and provide
precautionary warnings to the public.
In response to the Federal Communications Commission’s (FCC)
request for input regarding its radiofrequency radiation regulations adopted in
1996, individuals and organizations submitted thousands of documents,
testimonials, research papers and scientific publications that are now
available to the public. 
These documents reveal what we know about wireless radiation health effects,
and why we need to strengthen regulations and provide precautionary warnings to consumers.

Although more than fifteen countries have issued precautionary health warnings about cell
phone radiation and recommendations about how to reduce risks, the wireless
industry in the U.S. has opposed precautionary warnings and wants to weaken cell phone radiation standards.

In all, the FCC received 1,270 submissions between June 25, 2012 and August 12, 2019. Many submissions include multiple
documents. The preponderance of submissions call on the FCC to adopt stronger exposure limits on radiofrequency radiation.
Hundreds of individuals submitted statements that document their personal health problems and diseases experienced from exposure to radiofrequency radiation. These and other submissions can be viewed or downloaded by clicking on Proceeding Number 13-84 on the FCC web site.

The FCC’s obsolete RF exposure limits are 23 years old. The current request for public input is six years old. The FCC never reported on or acted upon a similar request for public input issued in 2003.

In 2015, a Harvard publication exposed how industry captured the FCC, “As a captured agency, the FCC is a prime example of institutional corruption. Officials in such institutions do not need to receive envelopes bulging with cash. But even their most well-intentioned efforts are often overwhelmed by a system that favors powerful private influences, typically at the expense of public interest.”

Obviously, updating RF regulations and testing procedures has not been a priority for the FCC even though the U.S. General Accountability Office recommended this in 2012. The FCC has no health expertise and relies upon federal health agencies to monitor the vast and growing body of peer-reviewed research on effects from radiofrequency exposure. Those in federal agencies with this expertise have left, and these agencies have shirked their responsibility to provide evidence-based guidance to the FCC and to the public– a classic case of diffusion of responsibility. 

Although there is a search engine on the FCC web
site, one cannot easily find important documents. Hence, I constructed several indices.

Part I which appears below contains key submissions to the FCC regarding cell phone radiation and its health effects,
and cell phone testing procedures and regulatory standards.
The submissions are organized under the following categories:

(1) Scientific Expert Resolutions Calling for Stronger Regulations
(2) Expert Comments in Support of Stronger Regulations
(3) Expert Comments that Support Weaker Regulations
(4) Consumer, Environmental and Health Organizations
(5) Government Agencies
(6) Wireless Industry Corporations and Associations
(7) Miscellaneous Other 

Not indexed below are submissions from individuals without organizational or institutional affiliations.  Many of these submissions discuss electromagnetic hypersensitivity (EHS).

Part II contains a list of key research papers that can be downloaded from the FCC web site. (to be updated soon)
Part III lists 98 scientific experts from 23 nations who have signed resolutions between 2002 and 2014 that call for stronger regulations on wireless radiation, especially cell phone radiation.
In 2015, scientists who published peer-reviewed research on the health effects of electromagnetic fields (EMF) submitted a petition to the United Nations, the World Health Organization, and all world leaders calling for stronger regulations on exposure to radiofrequency radiation than current national and international exposure limits allow.The International EMF Scientist Appeal was also submitted to the FCC. The Appeal has now been signed by 249 scientists from 42 nations. All have published peer-reviewed research on electromagnetic fields and biology and health. These scientists have published more than 2,000 papers and letters on EMF in professional journals. This petition was recently submitted to the United Nations Environment Programme. 

Scientific Expert Resolutions Calling for Stronger Regulations  
Catania Resolution (2002; 16 signees)
Seletun Scientific Panel (2009); 7 signees)
Health Canada Safety Code 6 Declaration  (Jul 9, 2014); 54 signees)
The International EMF Scientist Appeal (May 11, 2015; 200 signees)
Expert Comments in Support of Stronger Regulations
Omer Abid, MD, MPH

BioInitiative Working Group (29 contributing authors)
http://apps.fcc.gov/ecfs/document/view?id=7521097953
https://ecfsapi.fcc.gov/file/111701910403/17111608-1.pdf

Martin Blank, PhD
http://apps.fcc.gov/ecfs/document/view?id=7520940937
https://ecfsapi.fcc.gov/file/1092868197238/5%20-%20Attachment%205%20-%20Martin%20Blank%20PhD%20-%20Opposition%20Statement%20-%20File%2013-0953.pdf

David O. Carpenter, MD

Neil Cherry, PhD
https://ecfsapi.fcc.gov/file/1092868197238/4%20-%20Attachment%204%20-%20Olle%20Johansson%20PhD%20-%20Opposition%20Statement%20-%20File%2013-0953.pdf


Alan H. Frey

Martha Herbert, MD, PhD
http://apps.fcc.gov/ecfs/document/view?id=7520940748
https://ecfsapi.fcc.gov/file/1070786836035/MarthaHerberttoMCPS2015.pdf
 

Isaac Jamieson, PhD

https://ecfsapi.fcc.gov/file/10930270536460/IAJ_comments_to_FFC_Sep_30_2016.pdf

Olle Johansson, PhD

https://ecfsapi.fcc.gov/file/7022311370.pdfhttps://ecfsapi.fcc.gov/file/1092868197238/4%20-%20Attachment%204%20-%20Olle%20Johansson%20PhD%20-%20Opposition%20Statement%20-%20File%2013-0953.pdf

Suleyman Kaplan, PhD
http://apps.fcc.gov/ecfs/document/view?id=7520941388

Henry C. Lai, PhD
Victor Leach / Simon Turner   
De-Kun Li, MD, PhD, MPH

Don Maisch, PhD

https://ecfsapi.fcc.gov/file/7022311348.pdf

Joel M. Moskowitz, PhD
http://apps.fcc.gov/ecfs/document/view?id=7022311233
http://apps.fcc.gov/ecfs/document/view?id=60002030879
http://apps.fcc.gov/ecfs/document/view?id=60002031262
https://ecfsapi.fcc.gov/file/60002031262.
https://www.fcc.gov/ecfs/filing/1082955067871

Martin Pall, PhD
https://www.fcc.gov/ecfs/filing/1092725512546

Jerry L. Phillips, PhD

http://apps.fcc.gov/ecfs/document/view?id=7520940948

Ronald M. Powell, PhD

https://ecfsapi.fcc.gov/file/1070786836035/Message%20to%20Public%20Schools%20about%20Wireless%20Devices.pdfhttps://ecfsapi.fcc.gov/file/1083040514650/The%20Health%20Argument%20against%20Cell%20Phones%20and%20Cell%20Towers.pdf

Cindy Lee Russell, MD
https://www.fcc.gov/ecfs/filing/1001076789440


Miriam D. Weber, MD
Expert Comments that Support Weaker Regulations
Consumer, Environmental and Health Organizations

Center for Electrosmog Prevention

Electromagnetic Safety Alliance, Inc.

http://apps.fcc.gov/ecfs/document/view?id=7022311420
http://apps.fcc.gov/ecfs/document/view?id=7520941598

EMF Safety Network

Environmental Health Trust
http://apps.fcc.gov/ecfs/document/view?id=7022311561
https://ecfsapi.fcc.gov/file/10512278328322/Ex%20Parte-Pai%20051017.pdf

Environmental Working Group

Global Union Against Radiation Deployment from Space http://apps.fcc.gov/ecfs/comment/view?id=60001390648

Pharmacists Planning Service Inc (PPSI)

Environmental Protection Agency

https://ecfsapi.fcc.gov/file/7520941527.pdf

FCC Office of the Chairman (Response to Sen. Blumenthal & Rep. Eshoo)

http://apps.fcc.gov/ecfs/document/view?id=60001353996

FCC Office of Engineering Technology Bureau

http://apps.fcc.gov/ecfs/document/view?id=7022136643http://apps.fcc.gov/ecfs/document/view?id=7520936584https://ecfsapi.fcc.gov/file/10809296013805/13-84.pdf https://ecfsapi.fcc.gov/file/10809189809418/13-84b.pdfhttps://ecfsapi.fcc.gov/file/1080943159446/13-84c.pdfhttps://ecfsapi.fcc.gov/file/1032547831999/TIA-MWF%20Notice%20of%20Ex%20Parte%20for%20OET-Labs%20Meeting.pdf

National Assn. of Telecommunications Officers, National League of Cities, National Assn of Counties, & U.S. Conference of Mayors
https://ecfsapi.fcc.gov/file/100252268811/Joint%20letter%20re%20RF%20to%20FCC%20NACo%20Final.pdf
https://ecfsapi.fcc.gov/file/1062194009350/Wireless%20Bureau%20Ex%20Parte%20061918.pdf

North America’s Building Trade Unions
http://apps.fcc.gov/ecfs/comment/view?id=60001483296http://apps.fcc.gov/ecfs/comment/view?id=60001328468https://ecfsapi.fcc.gov/file/60001514689.pdf

https://www.saferemr.com/2014/08/part-i-why-we-need-stronger-cell-phone.html