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August 30, 2013 – The EMR Policy Institute filed extensive Comment in FCC 13-39 along with 19 Exhibits (also see below / with links). In this proceeding the FCC asks if it should reassess its current radiofrequency (RF) radiation safety policies. EMRPI’s position is that the FCC continues to disregard the research published after 1986, the cut-off date for the research which is the basis of FCC’s current policies. EMRPI’s Comment emphasizes that the FCC’s safety policies expressly fail to protect from “harmful interference” children, persons with medical implants, sensitive subgroups of the US populations, and workers whose occupations require them to spend time on rooftop antenna sites. EMRPI’s Exhibits present many recent studies that demonstrate biological effects and harm from RF exposure levels well below the FCC’s allowed levels.

Exhibits for FCC 13-39 - Comment of The EMR Policy Institute

1. North American Journal of Medicine & Science, Vol.6, Issue 3, July 2013. Preface to the
special issue on autism.

2. Letter of Martha H. Herbert PhD, MD, February 8, 2013, to the Los Angeles Uni fied
School District.

3. Letter of Superintendent of the Los Angeles Unified School District, May 13, 2012, to
then-FCC Chairman Julius Genachowski.

4. Guideline of the Austrian Medical Association (OAK) for the diagnosis and treatment of
EMF-related health problems and illnesses (EMF syndrome). Adopted 3rd March 2012 in

5. EPA Budget for EMR Activities – Fiscal Years 1990-2000.

6. Seletun Scientific Statement. “Scientific Panel on Electromagnetic Field Health Risks:
Consensus Points, Recommendations, and Rationales.” Reviews in Envi ronmental
Health. Vol. 25, No. 4, 2010.

7. “Induction of Vertebrate Regeneration by Transient Sodium Current,” and “Cracking the
bioelectric code,” by the research team Ai-Sun Tseng and Michael Levin, Department of
Biology and Center for Regenerative and Developmental Biology, Tufts University.

8. Electromagnetic fields act via activation of voltage-gated calcium channels to produce
beneficial or adverse effects. Martin Pall, Journal of Cellular and Molecular Medicine,

9. A review of the ecological effects of radiofrequency electromagnetic fields (RF_EMF). S.
Cucurachi, et al. Environmental International, Vol. 51, 2013.

10. Adverse Influence of Radio Frequency Background on Trembling Aspen Seedlings:
Preliminary Observations. Katie Haggerty, International Journal of Forestry Research,
Vol. 2010.

11. EMR and Plants: reference list of 29 studies on effects of EMR exposure on plants.
Compiled by Joris Everaert, M.SC. in Biology, University of Ghent.

12. EMR and Birds: reference list of 25 studies on effects of EMR exposure on birds.
Compiled by Joris Everaert, M.Sc., University of Ghent.

13. A Possible Effect of Electromagnetic Radiation from Mobile Phone Base Stations on the
Number of Breeding House Sparrows (Passer domesticus). Everaert and Bauwens,
Electromagnetic Biology and Medicine
, Vol. 26: 63-72, 2007.

14. Electromagnetic pollution from phone masts. Effects on wildlife. Alfonso Balmori.
Pathophysiology, Volume 16: 191-199, 2009.

15. EMR and animals other than birds: reference list of 63 studies on effects of EMR
exposure on animals other than birds. This includes bats, honeybees, bumble bees, farm
animals, rabbits, rats, mice, tadpoles, frogs, fruit flies, and ants.

16. Studies published in the British Journal of Cancer in 2011-2012 demonstrating successful
treatment of liver and breast cancers with specific modulation frequencies.

17. Treating cancer with amplitude-modulated electromagnetic fields: a potential paradigm
shift, again? Carl Blackman. British Journal of Cancer, Volume 106, 241-242, 2012.

18. Changes of Clinically Important Neurotransmitters under the Influence of Modulated RF
Fields – A Long-term Study under Real-li fe Conditions. Klaus Buchner and Horst Eger,
Umwelt-Medizin_Gesellschaft,Volume 24 (1): 44-57, 2011.

19. Impacts of radio-frequency electromagnetic fields (RF-EMF) from cell phone towers and
wireless devices on biosystem and ecosystem – a review. S Sivani and D Sudarsanam.
Biology and Medicine, Volume 4 (4): 202-216, 2012.

March 19, 2013 - Below are documents pertaining to EMR Policy Institute press release 3/19/13 on Wireless Industry Safety Failure:

  • December 9, 2011 letter to FCC Chairman Julius Genachowski Re: Wireless Sites Nationwide Found in Violation of FCC Radiation MPE Limits
  • May 17, 2012 letter to FCC Enforcement Bureau Chief P. Michele Ellison Re: Radiofrequency Radiation Exposure Complaint No. EMR026 located at 121 Riverside Avenue,
    Medford, Massachusetts 02155.
    There are two licensed wireless carriers at this location. Using the Narda survey system, EMRPI’s expert measured greater than 600% spatially averaged of the FCC Public limit in front of one readily accessible antenna and 507% spatially averaged of the FCC Public limit in front of the second readily accessible antenna.

March 6, 2013 - Reply filed The EMR Policy Institute in FCC Notices of Proposed Rule Making for ET Docket No. 03-137 and WT Docket No. 12-357 asserting that:

The EMRPI complaint letters sent to the FCC EB (Enforcement Bureau) document actual violations, not “potential” violations. The FCC has had more than a year since December 2011 to act upon and resolve the violations reported by EMRPI, and to publicly acknowledge enforcement actions.

February 5, 2013Comment filed by The EMR Policy Institute in FCC Notices of Proposed Rule Making for ET Docket No. 03-137 and WT Docket N0. 12-357 asserting that:

It is past time that the FCC adopt RF safety regulations that apply to today’s real-life exposure environments and that incorporate current peer-reviewed published research findings on biological effects of low-intensity electromagnetic radiation exposure.

May 20, 2011 – The EMR Policy Institute’s Reply in FCC 11-13. If the FCC's proposal passes, citizens will be denied the right to choose a landline. Existing landlines should not be replaced with wireless infrastructure. The FCC's duty is to facilitate communications for the whole country and for all US citizens. Its new proposal ignores issues of health, safety, privacy, affordability, reliability and security.

April 17, 2011 - The EMR Policy Institute’s Motion for Extension of Time in FCC 11-13 Notice of Proposed Rule Making on the petition of phone companies to abandon their landline phones as well as to bring mobile broadband service to 98% of the US in the next few years. In this FCC NPRM there are no references to considering the impact of the wireless method for the “Last Mile" of connection to homes on the health of people with electrohypersensitivity and medical implants that The EMR Policy Institute documented in our previous filing on broadband that is part of this docket.

Note: The EMR Policy Institute FCC filing from June 7, 2009, has been resubmitted in this proceeding as Appendix A. The EMR Policy Institute FCC filing from July 18, 2009 has been resubmitted in this proceeding as Appendix B.

January 24, 2011 - The EMR Policy Institute filed official comment with the Department of Justice (DOJ) Disabilities Section in its Advanced Notice of Proposed Rulemaking - Non-Discrimination on the Basis of Disability: Accessibility of Web Information and Services of State and Local Government Entities and Public Accommodations.

EMRPI advocates that the US Department of Justice must ensure that individuals with Implanted Medical Devices (IMDs) or with the EMR functional impairments of Electrohypersensitivity (EHS) and Radiofrequency Sickness avoid injury in their daily living and continue to have access to Web Information and Services through hard-wired communications equipment.

DOJ Comment submitted by Cindy Sage MA, Sage Associates, Santa Barbara, California

DOJ Comment submitted by Gary R. Olhoeft, PhD, Colorado Schools of Mines.

July 18, 2009 - EMR Policy Institute Reply Comment with Exhibits in FCC 09-31 Notice Of Inquiry in GN Docket No. 09-51 A National Broadband Plan for Our Future.

June 7, 2009 - EMR Policy Institute Comment in FCC 09-31 Notice Of Inquiry in GN Docket No. 09-51 A National Broadband Plan for Our Future.

Exhibits filed in EMR Policy Institute Comment. Included are personal statements of 41 citizens from the states of Alaska, Arizona, California, Colorado, Illinois, Indiana, Iowa, Kansas, Maryland, Massachusetts, Michigan, New Hampshire, New Mexico, New York, North Carolina, Pennsylvania, Texas, Vermont, Washington, West Virginia, and Wisconsin.

July 11, 2008 - The Cellular Telecommunications and Internet Association (CTIA), a trade association of the wireless industry in the US, petitioned the FCC to declare new limitations on local zoning authority as it affects antenna siting.

September 28, 2008 - The EMR Policy Institute’s Comment and Cross Petition in opposition.

All filings in this proceeding are found at: http://fjallfoss.fcc.gov/prod/ecfs/ comsrch_v2.cgi Type 08-165 in "Box 1:Proceeding" and click "Retrieve Document List" at the bottom of the form on this web page.

November 4, 2008 – [08-258 FCC Memorandum Opinion and Order] announcing its approval of the Verizon Wireless – Alltel merger. Discussion of EMRPI arguments along with those of the IBEW is found at VIII. Other Issues G. Radiofrequency Exposure pp. 92-99 at paragraphs 202-208. *Other filings in this proceeding are listed below:

August 18, 2008 – [Verizon Wireless – Alltel Joint Opposition] to EMRPI Petition to Deny and the IBEW letter in opposition. Discussion is found at: Proposed RF Exposure Conditions Are Neither Merger-Specific Nor Warranted p. 81 in the pagination found on bottom of the pages in the document.

August 8, 2008 - EMR Policy Institute (EMRPI) Petition to Deny FCC approval of the Verizon Wireless – Alltel merger WT Docket 08-95. EMRPI argues that the FCC has not addressed the impact of long-term exposure to radiofrequency (RF) radiation on human health. Providing protection for human exposure to potentially unsafe levels of RF radiation as required by the National Environmental Policy Act (NEPA) will not occur if the FCC approves this transfer before updating its present obsolete and inadequate RF safety guidelines. FCC should deny the license transfer from Alltel to VZW until VZW implements an RF safety solution that protects the public and all categories of workers whose workplaces are found near to VZW’s antenna sites.

August 8, 2008 - The International Brotherhood of Electrical Workers files letter with FCC opposing the VZW – Alltel merger until VZW enacts an RF safety program that protects all workers at its antenna sites. IBEW represents approximately 750,000 members who work in every state of the nation and in a wide variety of fields, including utilities, construction, telecommunications, broadcasting, manufacturing, railroads and government.

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