Dr. Timothy Schoechle, Senior Research Fellow at the National Institute for Science, Law and Public Policy, has submitted comments to the Federal Communications Commission on the adequacy of the FCC’s Radio Frequency Radiation (RFR) Exposure Guidelines. Please see 10 Conclusions below and read the PDF of the full report here.


Final Comments:

1. The existing limits are inadequate because they do not consider weak field (non-thermal)
effects on biological systems and processes. This entire FCC inquiry has a problem from
the get-go—it is based on a fallacious and obsolete assumption that thermal effects are
sole risk.

2. Well below the threshold of thermal RFR effects, the inquiry needs to consider weak
field (non-thermal) effects, including the difference between long term and short term
exposures, and that because of the adaptive characteristics of biological systems, one can
switch from gain to loss by changing the modulation, the frequency, or the time delay
between pulses as well as the presence of reactive oxygen—all of which have not been
adequately taken into consideration by the FCC.

3. If existing limits are not adequate for weak field (non-thermal) effects, it makes little
sense to simply extend these limits to frequency ranges above 6 GHz.

4. It makes little sense to further weaken thermal limits by relying on effective power alone.
Dropping SAR-based limits excludes consideration of absorption into the body that
should be accounted for by SAR with the additional consideration of duration of
exposure as well as more sophisticated measures of impact on bodies and cells.

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5. Averaging power over time is inadequate and deceptive because it does not deal with
peak power, is still based on the assumption that the only mode of potential harm is
heating (e.g., SAR or MPE), does not consider weak field (non-thermal) effects on
biological systems and processes, and does not deal with effects over time, or with long
term exposure effects.

6. The 19-126 inquiry and the FCC exposure guidelines are largely based on assumptions
and theoretical models rather than on experimental evidence or testing. Exposure limits
should be based on empirical science (i.e., verifiable by observation or experience rather
than theory or pure logic). “Increased emphasis on long?term exposures may require
refining the concept of dose to more flexibly combine exposure time and field intensity or
energy absorbed.” (Barnes and Greenebaum, 2020, p. 4). “What is missing in the current
guidelines or regulations are guidelines for long-term exposure to weak EMF” (p. 5).

7. The Commission should request the FDA and/or other agencies with appropriate health
science competence to pursue or undertake establishment of actual safety standards based
on actual animal or human safety testing, recommendations, or guidelines for both short
term and long term RFR exposures and emissions as proposed by Barnes & Greenebaum,
2020, p. 4-5). The FCC should recuse themselves from the process of setting human
RFR exposure guidelines due lack of expertise.

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8. “Limits on the time for operations of base stations and exposures in adjacent living
spaces are not controlled by the user and must be set by competent authorities, based on
scientific evidence. It is likely to be difficult to specify times when exposures to RF
signals are zero or below some limit. What will be needed is being able to say with some
certainty that exposure below a given level has not been shown to cause changes in body
chemistry above some level” (p. 5).

9. “A starting point might be current levels from TV and radio stations that are large enough
to give signal to noise ratios around 20 dB (100?fold) with typical receiving systems.
Currently, mean values for the population’s exposure to these systems are estimated to be
around 0.1 V/m and peak exposures range up to 2 V/m, which exceed current exposure
limits for a small fraction of the population” (p. 5).

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10. Consumers are entitled to informed consent to risk. The public should be educated about
the real risks involved in using cellphones and being near cell antennas big or small as
well as the risks of being exposed to RF radiation in general. It is the responsibility of the
FCC to inform the public openly and accurately. The FCC has not done so in this
proposed rulemaking.

PDF of Dr. Schoechle’s submission

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