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Scientific Letter to the Senate Calling For FCC Accountability on Cell Tower and Wireless Radiation Safety

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The ICBE-EMF Scientific Letter to the Senate Calling For FCC Accountability on Cell Tower and Wireless Radiation Safety

 

The International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF) submitted this letter to the Honorable Ted Cruz, Chairman, and the Honorable Maria Cantwell, Ranking Member, and all Members of the U.S. Senate Committee on Commerce, Science, and Transportation

Re: Oversight Hearing of the Federal Communications Commission—December 17, 2025

We write to you as experts of the International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF), an international consortium of scientists, doctors, and researchers with extensive expertise and peer-reviewed publications on the biological and health effects of non-ionizing electromagnetic fields, including the radiofrequency (RF) radiation emitted by cell towers and 4G/5G infrastructure. 

We have just submitted our scientific comments to the FCC opposing its “Build America: Eliminating Barriers to Wireless Deployments” NPRM due to the serious public health and environmental implications, its disregard for established scientific research, and its erosion of democratic, community-based decision-making. In our filing, we told the FCC that cell towers, 5G, and wireless infrastructure should not be fast-tracked as this will increase public exposure to RF radiation, an environmental exposure that peer-reviewed scientific research has associated with numerous health and environmental harms. U.S. limits on allowable exposures to RF radiation, unchanged since 1996, are not science-based and do not protect the public. 

We write to you to request that you ask the FCC several questions regarding the FCC’s activities related to cell tower and wireless safety. 

As documented by ICBE-EMF, in our paper published in Environmental Health entitled “Scientific evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation: implications for 5G,” FCC’s RF radiation exposure guidelines ignore decades of peer-reviewed research showing biological harm at levels far below those that cause heating (1). The FCC’s outdated 1996 limits are based on scientifically unsupported assumptions, focusing only on short-term heating effects while ignoring the extensive peer-reviewed published scientific evidence of biological harm at lower, non-heating levels. The FCC’s 1996 limits were derived almost entirely from short-term behavioral disruption studies in animals, such as heat-induced changes in behavior and the limits do not account for chronic exposure or the pulse-modulated signals transmitted by wireless technologies. Further, despite a federal court order (2, 3) to explain how its limits are adequately protective, FCC limits have not been updated based upon a comprehensive review of the current scientific evidence on cellular, neurological, reproductive, or carcinogenic effects. Thus, they do not account for long-term health effects, children’s vulnerability, electromagnetic hypersensitivity, cumulative exposures, or the documented impacts on wildlife and ecosystems. 

A rapidly expanding body of peer-reviewed research demonstrates that RF radiation from wireless infrastructure, including cellular towers and 5G small cell towers, can produce harmful effects at levels far below current FCC limits (4,5,6,7,8,9,10,11).

Large-scale animal research, including the U.S. National Toxicology Program (NTP) and Ramazzini Institute studies, both found increased brain and heart tumors (12,13). Notably, the Ramazzini Institute (RI) used much lower RF radiation levels as compared to the NTP, with RF levels that were lower than the FCC limit for cell tower emissions (14,15). Further, the same types of tumors reported in the NTP and RI studies have also been observed in human studies,, adding significant confidence that the associations observed in human studies are real (16,17). Studies of people living near cell towers show increased biomarkers of DNA damage, oxidative stress, hormonal disruption, sleep disturbance, neurological symptoms, and increased cancer rates (18,19,20).

The American Academy of Pediatrics has repeatedly urged (21) the FCC to update its outdated wireless radiation regulations to account for children’s increased vulnerability, noting that the research shows children absorb higher rates of RF radiation deeper into their more sensitive brains, as compared to adults (22,23). Further, research has also documented that cell phone radiation exposure can exceed limits when the phone is close to the body (24,25),  and that Wi-Fi and cell towers can increase children’s exposure in schools (26,27).

Further, the FCC plan puts wildlife at risk. The FCC has not established guidelines to protect non-human species from RF radiation even though there is a large and growing body of evidence that demonstrates the biological effects of RF radiation on animals and plants (28,2930,31,32).

We caution that the FCC’s proposed changes will come at a serious cost to public health and the environment, as well as strip state and local government authority.  

In 2021, the D.C. Circuit Court of Appeals issued a remand order on the FCC RF radiation emission limits, requiring it to provide a reasoned explanation for not updating its RF radiation emission limits, which were last set in 1996, when only a fraction of the cell towers and cell phones that we have today existed. The order stated that the FCC had failed to respond to “record evidence that exposure to RF radiation at levels below the Commission’s current limits may cause negative health effects unrelated to cancer.” The Court ordered the FCC to examine the effects of long-term exposure to humans and the environment, particularly to children (2,3). To date, the FCC has not complied.

The FCC’s reliance on Section 704 of the Telecommunications Act to preempt local consideration of environmental and health impacts is unjustified because the Commission has not conducted any meaningful review of RF radiation effects, nor ensured that any federal agency is doing so. Without updated safety limits or an up-to-date current scientific evaluation, how can the FCC continue to claim that health and environmental impacts may not be considered by local governments when considering where to place a cell tower? The Commission has failed to perform the very scientific and environmental oversight that Congress presumed when enacting Section 704, and it cannot lawfully claim that state and local governments are barred from considering impacts the FCC itself has never reviewed.

There is not a consensus for wireless safety.

The International EMF Scientist Appeal, a petition submitted to the United Nations and signed by more than 260 scientists who have published over 2,000 papers on EMF, biology, and health, states that the current wireless RF radiation human exposure guidelines set by the FCC and other national and international organizations are based on avoiding heating effects and do not adequately protect against known health risks that do not involve heat that can cause long-term health risks (33,34). The science is far from settled, and numerous medical organizations and public health experts recommend reducing exposure as substantial evidence exists pointing to serious risks (35). 

The FCC’s proposal effectively treats American communities as test subjects in an uncontrolled national radiation experiment, one conducted without consent, without monitoring, and without updated safety limits. If the Commission proceeds to fast-track cell towers without revising its outdated 1996 RF radiation exposure limits, it will knowingly promote densification of industrial wireless transmitters and expose millions to cell tower RF radiation levels that multiple peer-reviewed studies associate with increased cancer risk, neurological reproductive harm.

Given the FCC’s continued reliance on outdated 1996 cell tower and wireless RF radiation exposure limits and the agency’s lack of proper substantive scientific review in the nearly three decades since, we respectfully request clear and direct answers to the following oversight questions.

 

  1. Your RF exposure limits were set in 1996. What specific scientific review since then has the FCC conducted that justifies treating those limits as protective for today’s chronic cell tower radiation exposures? 
  2. What evidence does the FCC rely upon to conclude its limits adequately protect children, especially for long-term exposure? 
  3. In 2021, the D.C Circuit ordered the FCC to provide a reasoned explanation for not updating its wireless RF limits and to address scientific evidence of harm below FCC RF limits, including impacts on children and the environment. What has the FCC done since that remand, and why has it still not updated the limits? Provide the timeline and deliverables regarding the FCC’s response to the court.  
  4. The FCC relies on Section 704 of the Telecom Act to preempt local consideration of health/environmental effects, yet the FCC has not shown it has conducted any meaningful review of the health effects of RF radiation. On what basis can the FCC bar local consideration of impacts the FCC itself has not fully analyzed? 
  5. In a February 6, 2019, Senate Commerce, Science, and Transportation Committee hearing on 5G, when industry executives were asked what safety testing has been performed on 5G, wireless industry representatives were asked whether they have supported research on the safety of 5G technology and the industry representatives conceded they have not. Then Senator Blumenthal stated, “we’re kind of flying blind here” with respect to the health and safety of 5G. What have the FCC, FDA, and federal agencies done during the past 7 years to assure the Senators and the American public that 5G and new technologies are safe? (36, 37)
  6. What safety testing has been done on 5G and new and emerging technologies to ensure protection for long-term exposures? 
  7. In light of the increased daily wireless RF radiation exposure to the population, why isn’t the FCC recommending policies to monitor and reduce public exposure to RF radiation as many other countries already have done?  
  8. What incentives does the FCC provide to support R and D for safer technology with lower RF emissions? (38)

The public cannot be assured of safety, and Congress cannot exercise its oversight function, without a clear accounting of the scientific basis for continued reliance on decades-old limits that predate modern wireless technologies, chronic exposures, and the ubiquity of RF sources in daily life. We welcome continued dialogue that could lead to more health-protective solutions. 

Our experts stand ready to meet with you and provide any additional information or clarification needed to support the fulfillment of the Committee’s oversight responsibilities.

 

Respectfully submitted, 

John Frank MD, Chairperson, ICBE-EMF

Ronald L. Melnick PhD, Senior Advisor, ICBE-EMF

Elizabeth Kelley, MA, Managing Director, ICBE-EMF Management@ICBE-EMF.org

 

 

Scientific References

  1. International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF), Belyaev I, Blackman C, Chamberlin K, DeSalles A, Dasdag S, Fernández C, Hardell L, Héroux P, Kelley E, et al. Scientific evidence invalidates health assumptions underlying the FCC and ICNIRP exposure limit determinations for radiofrequency radiation: implications for 5G. Environ Health (2022) 21: doi: 10.1186/s12940-022-00900-9
  2. Environmental Health Trust et al. v. Federal Communications Commission. (2021). https://www.fcc.gov/document/dc-circuit-decision-environmental-health-trust-v-fcc
  3. Landmark Federal Court Decision on Wireless Radiation Human Exposure Limits.https://ehsciences.org/lawsuit-wireless-radiation-safety/\
  4. Lai H, Levitt BB. Cellular and molecular effects of non-ionizing electromagnetic fields. Rev Environ Health (2024) 39:519–529. doi: https://doi.org/10.1515/reveh-2023-0023
  5. Lin JC. Health and safety practices and policies concerning human exposure to RF/microwave radiation. Front Public Health (2025) 13: doi: 10.3389/fpubh.2025.1619781
  6. Lai H, Levitt BB. Radiofrequency radiation-induced gene expression. Rev Environ Health. 2025 Oct 29. doi: 10.1515/reveh-2025-0104. 
  7. Henshaw DL, Philips A. A mechanistic understanding of human magnetoreception validates the phenomenon of electromagnetic hypersensitivity (EHS). Int J Radiat Biol (2025) 101:186–204. doi: 10.1080/09553002.2024.2435329
  8. McCredden JE, Cook N, Weller S, Leach V. Wireless technology is an environmental stressor requiring new understanding and approaches in health care. Front Public Health (2022) 10: doi: 10.3389/fpubh.2022.986315
  9. Davis D, Birnbaum L, Ben-Ishai P, Taylor H, Sears M, Butler T, Scarato T. Wireless technologies, non-ionizing electromagnetic fields and children: Identifying and reducing health risks. Curr Probl Pediatr Adolesc Health Care (2023) 53:101374. doi: 10.1016/j.cppeds.2023.101374
  10. Joel M. Moskowitz, Effects of Exposure to Electromagnetic Fields: Thirty Years of Research, Science Blog (Feb. 2018) https://www.saferemr.com/2018/02/effects-of-exposure-to-electromagnetic.html
  11. Lai H, Levitt BB. The roles of intensity, exposure duration, and modulation on the biological effects of radiofrequency radiation and exposure guidelines. Electromagn Biol Med (2022) 41:230–255. doi:  10.1080/15368378.2022.2065683
  12. Lin JC. Carcinogenesis from chronic exposure to radio-frequency radiation. Front Public Health (2022) 10:1042478. doi: 10.3389/fpubh.2022.1042478
  13. Melnick RL. Commentary on the utility of the National Toxicology Program study on cell phone radiofrequency radiation data for assessing human health risks despite unfounded criticisms aimed at minimizing the findings of adverse health effects. Environ Res (2019) 168:1–6. doi: 10.1016/j.envres.2018.09.010
  14. Moon J, Kwon J, Mun Y. 2024. “Relationship between radiofrequency-electromagnetic radiation from cellular phones and brain tumor: meta-analyses using various proxies for RF-EMR exposure-outcome assessment. Environ Health 23, 82. https://doi.org/10.1186/s12940-024-01117-8
  15. Choi, Y-J, Moskowitz JM, Myung S=K, Lee Y-R, Hong Y-C. 2020. “Cellular Phone Use and Risk of Tumors: Systematic Review and Meta-Analysis” Int J Environ Res Public Health 17, no. 21: 8079. doi: 10.3390/ijerph17218079
  16. Hardell L, & Carlberg M. (2019). Comments on the US National Toxicology Program technical reports on toxicology and carcinogenesis study in rats exposed to whole-body radiofrequency radiation at 900 MHz and in mice exposed to whole-body radiofrequency radiation at 1,900 MHz. IntJ Oncology, 54(1), 111–127. https://doi.org/10.3892/ijo.2018.4606
  17. Prasad M, Kathuria P, Nair P, Kumar A, Prasad K. 2017. “Mobile phone use and risk of brain tumours: a systematic review of association between study quality, source of funding, and research outcomes.” Neurol Sci.doi: 10.1007/s10072-017-2850-8
  18. Balmori A. Evidence for a health risk by RF on humans living around mobile phone base stations: From radiofrequency sickness to cancer. Environ Res (2022) 214:113851. doi: 10.1016/j.envres.2022.113851
  19. Hardell L, Nilsson M. Summary of seven Swedish case reports on the microwave syndrome associated with 5G radiofrequency radiation. Rev Environ Health (2025) 40:147–157. doi: 10.1515/reveh-2024-0017
  20. Sailo, L, Laldinpuii, Zosangzuali M, Weller S, Varte CL, Tochhawng L, Zothansiama. (2025). Greater prevalence of symptoms associated with higher exposures to mobile phone base stations in a hilly, densely populated city in Mizoram, India. Electromagn BiolMed, 44(4), 385–404.doi: 10.1080/15368378.2025.2513900
  21. American Academy of Pediatrics. Letter in Support of the Cell Phone Right to Know to The Honorable Dennis Kucinich. (2012). Letter to the FCC Honorable Mignon L. Clyburn and FDA Honorable Dr. Margaret A. Hamburg Commissioner (2013); Letter to the FCC  Honorable Julius Genachowski (2012) Available online at: https://icbe-emf.org/wp-content/uploads/2025/01/American-Academy-of-Pediatrics-Letters-to-FCC-and-Congress-on-cell-phone-radiation-health-effects-.pdf
  22. Fernández C, de Salles, AA., SearsM. E., Morris RD, & Davis D L Absorption of wireless radiation in the child versus adult brain and eye from cell phone conversation or virtual reality. Environmental Research (2018) 167, 694–699 https://doi.org/10.1016/j.envres.2018.05.013
  23. Mohammed B, Jin J, Abbosh AM, Bialkowski KS, Manoufali M and Crozier S, “Evaluation of Children’s Exposure to Electromagnetic Fields of Mobile Phones Using Age-Specific Head Models with Age-Dependent Dielectric Properties,” IEEE Access (2017) vol. 5, pp. 27345-27353, 2017, doi: 10.1109/ACCESS.2017.2767074 
  24. Gandhi, O. P. (2019). Microwave Emissions from Cell Phones Exceed Safety Limits in Europe and the US When Touching the Body. IEEE Access, 7, 47050–47052. 
  25. Scarato T. U.S. policy on wireless technologies and public health protection: regulatory gaps and proposed reforms. Front Public Health (2025) In press.
  26. Soares NE, Bulla G, Fernández-Rodríguez CE, de Salles AA. “SAR Estimations in a Classroom with Wireless Computers” Journal of Microwaves, Optoelectronics and Electromagnetic Applications (2025) Vol. 24, No. 2, e2025288526 DOI: http://dx.doi.org/10.1590/2179-10742025v24i3288526
  27. Bhatt CR, Redmayne M., Billah B., Abramson MJ., & Benke, G. Radiofrequency-electromagnetic field exposures in kindergarten children. Journal of Exposure Science & Environmental Epidemiology (2017) 27(5), 497–504. https://doi.org/10.1038/jes.2016.55 
  28. Levitt BB, Lai HC, Manville AM. Effects of non-ionizing electromagnetic fields on flora and fauna, part 1. Rising ambient EMF levels in the environment. Rev Environ Health. 2021 May 27;37(1):81-122. doi: 10.1515/reveh-2021-0026.
  29. Levitt BB, Lai HC, Manville AM. Effects of non-ionizing electromagnetic fields on flora and fauna, Part 2 impacts: how species interact with natural and man-made EMF. Rev Environ Health. 2021 Jul 8;37(3):327-406. doi: 10.1515/reveh-2021-0050.
  30. Levitt BB, Lai HC, Manville AM. Effects of non-ionizing electromagnetic fields on flora and fauna, Part 3. Exposure standards, public policy, laws, and future directions. Rev Environ Health. 2021 Sep 27;37(4):531-558. doi:10.1515/reveh-2021-0083. 
  31. Levitt BB, Lai HC, Manville AM. Low-level EMF effects on wildlife and plants: What research tells us about an ecosystem approach. Front Public Health (2022) 10: doi: 10.3389/fpubh.2022.1000840
  32. Levitt BB, Lai HC., Manville AM II, & ScaratoT. Flora and fauna—How nonhuman species interact with natural and man-made EMF at ecosystem levels and public policy recommendations. Frontiers in Public Health, 13. doi:10.3389/fpubh.2025.1693873 
  33. EMF Scientist International Appeal. 4G/5G antenna densification is escalating health risks – a global crisis [Internet]. New York, NY: EMFscientist.org; 22 Jul 2019 [cited 2025 Oct 29]. Available from: https://emfscientist.org/
  34. Kelley E, Blank M, Lai H, Havas M, Moskowitz J. International Appeal: Scientists call for protection from non-ionizing electromagnetic field exposure. European J Oncol. 2015;20(3/4):180-182.  Available from: https://www.mattioli1885journals.com/index.php/EJOEH/article/view/4971
  35. Environmental Health Sciences. Doctors and scientists on cell phone radiation health effects EHSciences.org; 2025. Available from: https://ehsciences.org/doctors-and-scientists-on-cell-phone-radiation-health-effects/
  36. U.S. Sen. Richard Blumenthal, At Senate Commerce Hearing, Blumenthal Raises Concerns on 5G Wireless Technology’s Potential Health Risks, U.S. Senate Press Release. https://www.blumenthal.senate.gov/newsroom/press/release/at-senate-commerce-hearing-blumenthal-raises-concerns-on-5g-wireless-technologys-potential-health-risks
  37. Video of Senator Bliementhal Link https://www.youtube.com/watch?v=2QgGA_dLVYw
  38. Héroux P, Belyaev I, Chamberlin K, Dasdag S, De Salles AAA, Rodriguez CEF, Hardell L, Kelley E, Kesari KK, Mallery-Blythe E, et al. Cell Phone Radiation Exposure Limits and Engineering Solutions. International Journal of Environmental Research and Public Health. 2023; 20(7):5398.
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