What Happened to “Irradiated”, the Massive EMF Safety Advocacy Document that was Submitted to the FCC?

The FCC Requested Public Comments on Revisions to EMF Exposure Standards

Patricia Young

A book sized 416 page document strikingly titled:

“IRRADIATED A comprehensive compilation and analysis of the literature on radio frequency fields and the negative biological impacts of non-ionizing electromagnetic fields (particularly radio frequency fields) on biological organisms“

was delivered online to the FCC, in response to their request for “Comments on Revisions to EMF Exposure Standards” from the public, which would have bearing on their 5G Fast Plan and proposals, in hopes that its massive “thump factor” (the impressive sound the ample sized document made when thumped down on a table) and obvious large amount of work referencing scientific studies, biological research, personal electo-hypersensitivity stories, not to mention its formidable heart and soul would persuade the FCC to revise their current USA public EMF exposure safety levels in the face of such compelling evidence.

The document/book has achieved archival immortality by its inclusion on the FCC.gov website and, along with all other public comments that were submitted, it will remain part of the public record forever. However it passed through the entire public feedback process without making even the fainest thump in terms of making the positive difference that it set out to do. To understand what went wrong, and why the document did not receive the consideration that many concerned citizens and supporters of EMF advocacy groups thought it merited, a look at the Table of Contents outlining what the document contained is instructive.

When you have time I encourage you to download “IRRADIATED” in its entirety and take the opportunity to read its 416 pages more thoroughly. It is a shining example of the efforts of an EMF Advocate Group called Wireless Action, one of the many advocate groups working on behalf of the American public to achieve a safer EMF living environment.

Here, for the convenience of a quick overview, is the four-page Table of Contents of Irradiated, listing what topics were included and discussed in its submission to the FCC during the call for public comment, which was held December 4th 2019 to January 3rd 2020.

As complete as the document seems judging by its Table of Contents (copied here as it appears in the FCC archive), it could not be considered by the FCC, simply because it did not follow the protocols for submitting, and without that they have no formal structure with which to draw conclusions, or even to take its contents into consideration.

How could this happen?

When the FCC called for comments they also published the guidelines for submitting comments, which included a specific structure for telling the FCC reviewers basically what to change and why, So, while comments are open to everyone (paraphrased from FCC Docket 13-84 Document 13-39) from “the general public to highly training health and safety agencies to federal and expert organizations”. Open means open, so even if someone off the street submitted their comments the FCC is mandated to handle each comment by the same structure and criteria, respecting each comment without regard to who the commenter was or if he/she are qualified to make suggestions. But similarly, guidelines means guidelines, so all comments are considered according to the structure laid out in the guidelines for commenting.

As fussy, or crazy-making, as that may seem, official regulation setting (i.e. government law making) bodies, in this case the FCC (Federal Communication Commission), and the respected bodies that make EMF standard recommendations to the regulating body, which in the case of the FCC are the IEEE, ICNIRP, FDA, EPA and the general public, can only operate using the same structure applied to all input.

The recommending bodies, (always keep in mind that the general public is a respected part of these), must follow guidelines that are in place to provide the official FCC committee reviewers a consistent format for examining the facts, understanding the rationale, and achieving a basis for making concrete suggestions that are put forward as recommendations for changes to the standards by the committee reviewers to the FCC regulators.

This structure is what forms the basis for the FCC to justify any changes in regulations (laws), because the FCC does not create standards it merely selects them from the information that they are provided with.

Understanding this is key to understanding why the Irradiated document, impassioned though it was, will languish in the FCC Comment archive forever disregarded, at least by this commenting process if not by countless concerned citizens who recognize themselves in page after page.

Taking a look at the FCC’s January 2020 response to the public comments it received tells us how the Irradiated document, and the thousand or so other public documents like it that were reportedly received by the FCC, could have been submitted in order to be regarded, taken into consideration, and produce the changes, or the impetus for change, that it intended. And in the reading of this official response we can learn more about how to follow the guidelines.

The guidelines for commenting serve as a roadmap that all EMF Advocate groups and private concerned citizens alike can follow going forward. Because the good news is that the commenting process is open to the public at regular intervals for exactly this type of input from you, since all USA government agencies dealing with the public must provide means for direct input from the public whom they serve.

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