Responding to the FCC 19-226

April, 2020

Issue #1: The FCC is planning to establish "safe" human exposure guidelines to ultra high frequencies, above 100 Gigahertz (GHz).

Synopsis of Paragraphs 125 and 126 - The FCC seeks to establish new rules on exposure to ultra high frequencies (above 100 GHz), where there are currently no limits. The FCC reasons that since its existing exposure limits are the same for the entire range from 6 GHz to 100 GHz, due to "minimal body penetration," these same exposure limits could theoretically be extended to ultra high frequencies, which will be used for the next generation of wireless devices. 


The FCC reasons that as body penetration diminishes as frequencies get higher, "there is no apparent reason to expect that thermal effects will effectively change" at higher frequencies. So the proposal is to extend current RF limits up to the 3 THz range.

Our Analysis: The FCC appears to be pushing ahead with plans for the next generation of wireless ("6G") while scientists are still documenting evidence of cancer and other biological harms from 2G, 3G & 4G exposures. There are no human or animal studies yet on these much higher frequencies, but an absence of studies does not mean an absence of harm.

The FCC needs to stop taking advice about health effects solely from organizations dominated by physicists and engineers. These organizations cling to the long-outdated notion that the only impact of exposure is "thermal" (heating of human tissue), despite thousands of published, peer-reviewed studies showing biological harm at non-thermal levels for various frequency ranges.

The ultra high frequencies being considered here may also interfere with the natural world in ways we don’t yet understand. The agency’s assumption that these ultra high frequency waves will produce no biological harm to humans or unintended disruption to the natural world is not supported by any current science.

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.  

Insert any comment here about a personal situation regarding biological impacts.  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.

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