Two federal agencies are asking the public what it knows about wireless radiation, and the public is answering—loudly. As of Sept. 30, the two dockets held 1,519 submissions: 1,155 published comments on the Department of Health and Human Services’ RF/EMF docket and 364 filings in the FCC’s reopened RF exposure proceeding.
A Wireless Estimator review of 146 of the HHS comments, along with the 66 document filings made so far at the FCC, found a record dominated by personal health accounts, a sizable contingent of “targeted individual” claims, and only a thin layer of material either agency is likely to treat as evidence. For tower owners, carriers, and site acquisition specialists, what commenters are asking for matters more than how they argue it: setbacks from homes and schools, an end to right-of-way siting, European-style exposure limits, and other onerous notifications.
Two dockets, two very different invitations
HHS posted its Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure to Regulations.gov on Sept. 20 under docket HHS-OASH-2026-0397, with comments due Oct. 21. The RFI asks for the current state of the science, a comparison of domestic and international safety standards, research gaps, and recommendations for “policymakers, public health stakeholders, families, schools, and communities.” It also asks respondents to identify the perspective they are writing from — patient, caregiver, healthcare professional, worker — which, read plainly, is an open invitation to personal testimony.
The FCC’s Public Notice, DA 26-997, released Sept. 17 in ET Docket No. 13-84, is narrower. It seeks comment only on the three issues the U.S. Court of Appeals for the D.C. Circuit remanded in Environmental Health Trust v. FCC in August 2021: testing procedures for phones and other portable devices; the effects of exposure on children, long-term exposure, device ubiquity and technological change since the Commission’s 1996 limits; and environmental impacts. Comments are due Oct. 22.
The Commission was unusually direct about what it will and won’t count. It said it will give “particular weight to submissions that reflect specialized experience in health and safety issues on RF exposure,” and will not afford scientific weight to “unverifiable or repetitive testimonial submissions” or to meta-analyses that “simply compile studies marked by wide ranges in scientific rigor.” It specifically asked whether cited studies establish a dose-response relationship at exposure levels below the FCC’s limits, and whether they distinguish correlation from causation.
The timing is not incidental. The notice landed while the FCC was defending itself in the D.C. Circuit against a writ of mandamus petition filed May 18 by Environmental Health Trust and co-petitioners over the Commission’s nearly five-year delay in responding to the remand. The FCC’s Sept. 25 opposition argued the delay was not unreasonable and asked for at least nine more months if the court orders action.
In other words, HHS asked the public what it has experienced. The FCC asked what it can prove. The public has largely answered both questions the same way.
Most of the HHS record is personal testimony
Most of the HHS comments reviewed are first-person accounts of headaches, insomnia, tinnitus, heart palpitations, and “brain fog,” attributed to a nearby macro tower, a small cell, a smart meter mounted on a bedroom wall, or a phone carried in a pocket. A commenter in Scotland tied a sharp health decline to two 5G masts installed near her home in April 2020 — while conceding that the timing alone was not proof, a caveat few others offered.
An Austin, Texas, renter wrote that she now sleeps in her living room because of a smart meter on her bedroom wall. An Oklahoma commenter said a tower went up about 500 yards from her house on a neighbor’s land, with no notice to anyone nearby. A Florida commenter asked HHS to examine cancer records at Vineyards Elementary School in Naples, where towers were built on or adjacent to the campus in 2011.
Much of the file is template-driven. Many comments open with identical language — “I am submitting this comment in response to HHS’s Request for Information” — followed by “I am responding from the perspective of.” At least one was submitted with the form’s bracketed menu still intact: “[patient, parent, family member, caregiver, healthcare professional, researcher, advocate, concerned member of the public, or other].”
A handful of comments make an actual argument
The most cogent comment reviewed came from a commenter identified as Rosie Libert, who argued that the U.S. “needs to stop confusing regulatory compliance with proof of biological safety.” Her point is regulatory, not anecdotal: a phone that passes a specific absorption rate (SAR) test under lab conditions says nothing about chronic exposure from many simultaneous sources. She cited the National Toxicology Program’s animal cancer findings and France’s post-market SAR testing of phones — and, rare for this docket, acknowledged that “human studies have produced mixed results.”
Beverly A. Jensen, Ph.D., who lists a doctorate in Communication from the University of Washington (1987) and founded the advocacy group 10 Million Moms for Safer Telecom, filed at both agencies. Her HHS submission pairs a background in public health campaigns with her own reported EMF sensitivity and asks for safe-use and distance labeling and long-term research not funded by industry. It is organized and specific in its requests, but light on citations.
Other commenters leaned on the European Parliament’s July 2021 study “Health Impact of 5G” and on a review arguing the International Agency for Research on Cancer should move RF radiation from Group 2B, “possibly carcinogenic,” to Group 1. One attached a compilation titled “Biological Effects of EMR and other Studies.” Several recommended online videos by British physicist Barrie Trower.
The policy asks are where this industry should pay attention. The founder of the Florida Coalition for Safe Technology argued towers should be confined to industrial areas and called Florida’s siting rules “PRO TELECOM,” questioning why structures are allowed in rights-of-way, school parking lots, daycares, and churches. Other comments asked for exposure limits matching Europe’s, mandatory notice before construction, smart meter opt-outs, and a halt to 6G.
Then there’s the rest of the file
Roughly one in five comments in the sample fall into a different category entirely. Commenters wrote that 5G towers and satellites are being used “to beam human minds with pulsed microwave radiation” for “mass mind control,” with the CIA, NSA, and DARPA named as participants.
One commenter described himself as “fully telepathic (not schizo).” Another reported being electrocuted three times by “6G lamp posts” in a ski-hill parking lot, said a phone app registered more than 3,000 microtesla, and wrote of having “died on the way to the hospital.”
One attributed his symptoms to COVID vaccine “shedding.” Another attached an article on bee propolis as protection against Wi-Fi. Several were addressed personally to Secretary Robert F. Kennedy Jr., one opening with family recollections of President John F. Kennedy.
Others reported neighbors “diagnosed with electromagnetic radiation poisoning,” which is not a recognized medical diagnosis, and a tower that “killed the surrounding trees and plants.” None of these claims came with documentation, and under the FCC’s stated standard none would carry weight. HHS set no such standard, which is precisely why its docket looks the way it does.
The FCC record is thinner — and more technical
Since the Sept. 17 notice, ET Docket 13-84 has logged 364 filings as of Sept. 30: 298 express comments, largely personal accounts, and 66 standard filings with attached documents. The docket’s full count on the FCC’s filing system tops 2,500 because it includes every submission since the proceeding opened in 2013. Wireless Estimator reviewed the filing records and attachment titles for all 66.
The most substantive include Theodora Scarato of Environmental Health Sciences, who filed her 2025 Frontiers in Public Health paper on U.S. regulatory gaps, a paper on EMF effects on flora and fauna, and ICBE-EMF position statements and letters to Congress on children and cell towers. Gerald Steel, a professional engineer and retired environmental attorney, attached work by Martin Pall (2015), Igor Yakymenko (2014), B. Blake Levitt (2010), and Cindy Sage, along with Albert Manville’s 2016 wildlife report and its exhibits. The Kelly Legacy Institute submitted a seven-page technical filing; Dr. Carlos Sosa, M.D., filed a paper titled “Radiofrequency Disease”; and Henry Eckstein filed “Public Comments to the FCC and HHS – 23 Studies.”
The detail worth flagging: much of that literature predates the FCC’s 2019 decision to keep its limits, and compilations of it are exactly what the Commission now says it will discount. The Manville wildlife material and the children’s exposure papers line up most directly with the issues the court sent back.
Who hasn’t shown up yet?
As of Sept. 30, neither docket contained a filing from CTIA, the Wireless Infrastructure Association, NATE, a tower owner, a carrier, or a federal science agency. The American Institute of Physics reported that the National Council on Radiation Protection and Measurements will not respond to the HHS request but will respond to the FCC. Industry filings in FCC proceedings routinely arrive close to the deadline, so the absence may say more about the calendar than the stakes.
Scientists outside the advocacy community have already flagged the HHS approach. Brown University epidemiologist David Savitz told AIP the RFI “is sure to elicit a very large number of anecdotal reports without any scientific value.” University of Pennsylvania bioengineering professor emeritus Kenneth Foster warned that “making public health decisions on the basis of unfiltered, albeit very deeply felt, opinions of the public can lead to very bad advice.”
Even Environmental Health Sciences’ own filing guide urged commenters to submit peer-reviewed research. It cautioned that publicly describing a personal injury could start the clock on the statute of limitations for any future lawsuit. Most commenters filed their stories anyway.
Reading it all together
Volume is not evidence, and 1,519 submissions won’t move an RF exposure limit. But the HHS RFI is explicitly aimed at recommendations for “families, schools, and communities” — the same local bodies that sit on zoning boards and school boards and vote on site applications. The siting demands in this record are concrete and repeated — and most of them, from RF-based setbacks to European-style limits, are exactly what Section 332(c)(7) bars a town from imposing. That doesn’t mean they won’t show up at a zoning hearing dressed as aesthetics.
The FCC asked for proof. HHS asked for perspectives. So far, both agencies have mostly received perspectives.
