The FCC Has Failed to Protect Children's Physical, Mental, and Emotional Health
Please put it in writing by April 11, DELETE, DELETE, DELETE is GN Docket No. 25-133
Swan riding on parent: image courtesy Lori McCray
The FCC is soliciting comments from the public about how to make the agency more efficient, in accordance with DOGE directives, (Trump admin. Dept. of Government Efficiency).
Comments Due: Friday, April 11, 2025
Reply Comments Due: Monday, April 28, 2025
The Order: https://docs.fcc.gov/public/attachments/DA-25-219A1.pdf 6 pages
The order states:
"Are there existing rules that could give rise to a risk of regulatory capture?" (The FCC is a Captured Agency)
“We also invite more general comment on rules that should be considered for elimination on other grounds.”
We Test Cell Phone Safety on an Inanimate Model Representing a 220-pound Male Head
Testing the safety of cellphones on a model that replicates the measurement for a male military recruit’s head filled with the equivalent of Jello would only be appropriate if a child’s head was the size of male military recruit’s and filled with something inanimate, like Jello.
Learn all about it here at We Are Not Sam.
“Firstly, Sam, the test dummy, consists of a plastic head. It has no tissue, organs or bones, torso, arms or legs and bears no physical resemblance or similarities to an actual human.” “The plastic test dummy head is based on a male of 100kg and 6ft, and this body type and size represents 3% of the actual population. There is no allowance for the 97% of the population who are not in this range, and it is widely proven that children absorb twice the radiation of an adult.” - Learn more at We Are Not Sam
Cost Benefit Analysis
The FCC’s order also states,
“[] cost-benefit considerations can be relevant in their own right, such as where a rule when originally adopted was not grounded in a proper assessment of the relevant costs and benefits of the requirement, or where the initial cost-benefit evaluation was highly uncertain. We thus broadly seek comment on cost-benefit considerations relevant to our analysis. Are there existing Commission rules for which the costs exceed the benefits? Are there rules that, if eliminated or modified, could result in greater benefits relative to the associated costs of the new regulatory framework?”
(The greater benefit relative to the direct costs of inappropriate safety testing would be to stop cost-shifting the burden for chronic illness and disease to the social sector and to address the underlying cause, - a polluted environment caused by an inadequately regulated industry.)
Vulnerability of Children
In the post Vulnerability in Children, Physicians’ Health Initiative for Radiation and Environment (PHIRE) (UK) notes:
Children are more vulnerable due to multiple factors:1 It is noteworthy that brain tumours have overtaken leukaemia as a leading cause of cancer death in young people.
1. Children absorb more radiation:
The brain of a child (age 5-8yrs) can absorb 2x the radiation of an adult.2
Exposure in bone marrow can be up to 10x greater than an adult.3
2. Outcomes in children may be worse as:
Children have systems which are still developing.
Children have a longer time ahead for latent effects to manifest.
(Footnotes are live at source link)
Extrapolating Animal Study Results?
The Gilardi family’s children (and neighbors) experienced direct harm when an industrial-scale cell tower as installed in their residential neighborhood (Pittsfield MA) during the pandemic shut-downs.
In the March 31 article Residents of Massachusetts Town Head Back to Court in Case Alleging Verizon Cell Tower Is Making Them Sick Children’s Health Defense quoted Courteny Gilardi: “People need to know the RF standards were established almost 30 years ago … In no way do they protect men, women and children from the 24/7 exposure to the kind of radiation that is pervasive today.”
“As The Defender previously reported, the FCC’s RF radiation limits are based on a handful of outdated studies, including a 1977 study involving eleven rats; a 1982 study involving five rhesus monkeys, one squirrel monkey and one rat; and a 1984 study involving five rhesus monkeys. The studies focused on finding out how hot from radiation the animals needed to become to stop seeking food.”- Source
Submit a comment for 25-133.
Addressing risks posed to children by technology is much more involved than denying food to research animals; endorsing a ‘dumbed down’ cellphone ‘for texting and calls only'; and limiting screen time and access to social media or devices during school hours, but it’s a start.
We need a complete overhaul of the safety science.
Please submit a comment to the docket.
Electronic Filers: Comments may be filed electronically using the Internet by accessing the ECFS: https://www.fcc.gov/ecfs/
The FCC asked: "Are there existing rules that could give rise to a risk of regulatory capture?" Yes, they really did.
You can simply say that the FCC as a captured agency has failed to protect children’s health, and/or the health and the environment and include a reference if possible.
Norm Alster, The Edmond & Lily Safra Center for Ethics, Harvard University
“Captured Agency: How the Federal Communications Commission Is Dominated by the Industries It Presumably Regulates,” 2015
Peter Elkind's two articles from ProPublica:
https://www.propublica.org/article/fcc-5g-wireless-safety-cellphones-risk. (2022)
Also his article on FCC and its failure to consider the environment: https://www.propublica.org/article/fcc-environment-cell-towers-failures. (2023)
If you are not familiar with the history or the procedure for posting to the FCC, see the in-depth explanation here:
FCC: Please Submit a Comment by April 11th The FCC asked: "Are there existing rules that could give rise to a risk of regulatory capture?" Yes, they really did.
If you are looking for more references or science to submit, here are some helpful sites (there is enough science):
Americans for Responsible Technology
SCIENTIFIC STUDIES | Americans for Responsible Technology
Canadians for Safe Technology (Former President of Microsoft Canada Frank Clegg)
C4ST, worked with 23 other volunteer organizations and groups across Canada to launch the Urgent Appeal to the Government of Canada to Suspend the 5G Rollout and to Choose Safe and Reliable Fibre Connections. The Appeal asks the Government of Canada to invest in wired technologies to expand high-speed Internet as much as possible and update Health Canada’s Safety Code 6 guidelines regarding wireless technology radiation exposure. We are also asking for a complete economic analysis of the total potential economic burden for Canadians from 5G, and to assign responsibility to the technology industry to prove their products are safe before releasing to the market. The suspension of the auctioning of all spectrum licences and the installation of new “small cell” antennas should last until the safety guidelines are updated and the economic analysis is completed.
Electromagnetic Radiation Safety (SaferEMR)
International Commission on the Biological Effects of Electromagnetic Fields FCC and ICNIRP Human Exposure Limits Inadequate to Protect Health or Environment
Massachusetts for Safe Technology Resources:
Understanding EMFS Impacts on Children
Understanding EMFs - Wi-Fi in Schools
More at link: https://sites.google.com/site/understandingemfs/
Physicians for Safe Technology
Physicians’ Health Initiative for Radiation and Environment (PHIRE)
A 1996 Paper: Prof Om Gandhi: O. P. Gandhi, G. Lazzi and C. M. Furse, “Electromagnetic absorption in the human head and neck for mobile telephones at 835 and 1900 MHz,” in IEEE Transactions on Microwave Theory and Techniques, vol. 44, no. 10, pp. 1884-1897, Oct. 1996, doi: 10.1109/22.539947. https://ieeexplore.ieee.org/document/539947?arnumber=539947
Please share this widely with everyone who loves children and nature.