Comments on Environmental Impacts of Wireless Submitted to the National Telecommunications and Information Administration
EHT submitted expert comments after the White House released a Presidential Memorandum Modernizing United States Spectrum Policy and Establishing a National Spectrum Strategy, and the National Spectrum Strategy on November 13, 2023.
EHT also met with the senior legal and engineering staff of the NTIA regarding the National Spectrum Strategy and the need to include an environmental review and include wildlife protections. We highlighted the serious regulatory gaps and the impacts of EMF/RF to pollinators and insects. EHT’s comments and powerpoint presentation are now posted online at the NTIA website.
Excerpts from EHT’s submission:
We submit that responsible spectrum management considers not only the impact of spectrum decisions on networks and devices but also on the environment and all life forms, including humans, animals, plants, and microbes.
The Federal Communication Commission’s RF human exposure limits remain almost entirely unchanged since 1996 and they are designed only to protect against heating effects of short term exposures, not biological impacts from long term exposure. An ever growing body of scientific evidence documents adverse effects from RF radiation at exposure levels well below FCC limits with research findings that include cancer, the induction of oxidative stress, epigenetic effects, impacts to neurotransmitters, memory, brain development and damage to the immune, endocrine, hematological and reproductive system. Further, studies have found impacts to tree canopy, plant growth, pollinator health and the orientation, migration and breeding of wildlife. The science clearly indicates that wireless networks create harmful interference in humans as well as flora and fauna.
A study by U.S. Army and Air Force Research Laboratories found that high powered pulsed microwave exposures could reach the same threshold pressures of explosive blast brain and football head impact injuries even at levels considered “safe” and compliant with current FCC RF limits.
EHT’s extensive written comments submitted on January 2, 2024 made 5 recommendations:
Recommendation #1: NTIA must not make any spectrum utilization decisions that increase RF exposure until the FCC complies with the U.S. Court of Appeals DC Circuit mandate issued in EHT et al. v. FCC, to address record evidence including long term health effects, children’s vulnerability and environmental impacts of RF exposure.
Recommendation #2: NTIA must condition any future spectrum utilization decisions that will increase human or environmental RF exposure on (i) creating industry leading premarket testing for long term safety (for humans, flora, and fauna), (ii) ensuring that devices and networks pass such safety testings, and (iii) establishing quarterly post-market health and environmental surveillance along with monitoring and compliance oversight. Because human and environmental health is a paramount concern to the nation’s population and economic vibrancy, NTIA must consider treating any spectrum utilization decision as a major federal action requiring an environmental impact statement under NEPA.
Recommendation #3: The Strategy must expressly state that it is United States Spectrum Policy for its wireless networks and devices to compete on safety, and thus ensure the public and environment is protected from harmful radio frequency interference.
Recommendation #4: NTIA must ensure that spectrum is allocated in accordance with the entire public interest, not just certain narrow corporate or agency priorities.
Recommendation #5: Broaden the definition of stakeholders to include public health and environmental health organizations. The Securities and Exchange Commission (SEC) has already alerted industry of the need to include Environmental Health Stakeholders in its Environmental, Social Governance (ESG) proposed rules. Thus is it important for government agencies to be consistent in their broad policy strokes.
