"Proposed Changes in the Commission’s Rules ) ET Docket No. 03-137
Regarding Human Exposure to Radiofrequency )
Electromagnetic Fields " -
From:
Whitney North Seymour, Jr.
455 Lexington Avenue, Room 1721
New York, New York 10017
email: wseymour@stblaw.com
Telephone: (212) 455-7640
Gabriel North Seymour
Gabriel North Seymour, P.C.
200 Route 126
Falls Village, CT 06031
Tel: 860-824-1412
Email: certioari@earthlink.net
Janet Newton, President
P.O. Box 117
Marshfield VT 05658
E-mail: info@emrpolicy.org
Telephone: (802) 426-3035
***
Who is Whitney North Seymour?
Whitney North Seymour, Jr., Esq.
Retired Partner, Simpson Thacher & Bartlett LLP;
Former New York State Senator & United States Attorney, Southern District of NY
Co-Founder, Natural Resources Defense Council
He graduated Princeton University and Yale University Law School. Seymour was independent counsel or special prosecutor in the case of Michael Deaver, a senior aide to President Ronald Reagan, who was convicted of perjury in 1987.
This document was dated November 13, 2013 and there were many, many other submissions to the FCC advising them of this same information, all of which they have chosen to disregard - some of the text below. Please read the entire document here. There are a number of audio presentations from experts worldwide imploring action to this public health crisis worldwide here.
Regarding those with implanted medical devices (such as the VP shunt implanted in my brain), he advised:
III. HARMFUL INTERFERENCE
13. EMRPI reiterates that the FCC’s definition of “Harmful Interference” must be
expanded if it is to be relevant to the ubiquitous environmental RF radiation exposure now present in Americans’ daily lives.
14. FCC’s “Harmful Interference” definition must be expanded to include acute,
chronic, or prolonged exposure to RF signals and emissions that endangers, degrades, obstructs or repeatedly interrupts biological functioning of a person, plant, animal or ecosystem, or results in adverse health effects, or malfunctioning of medical devices or equipment. EMRPI Comment page 13 Paragraph 55.
15. “Harmful Interference that results in biological harm” is defined as “any negative change in a measurable biological, physiological or ecological parameter. “
16. The “Harmful Interference” definition must take into account the fact that RF radiation penetrates children and adults differently.
a. Exposure to electronics, metal detectors or wireless services that causes an FDA approved medical device such as a cardiac pacemaker, an insulin pump, a deep brain stimulator, a cochlear implant to malfunction and results in pain, bodily harm or death;
b. Exposure to metal detectors and/or RF signals while a person is in a metal or electronic wheelchair and results in pain, bodily harm, negative health effects or death;
c. Exposure to metal detectors and/or RF signals to a person with implanted metallic bone replacement devices that results in pain, bodily harm, negative health effects or death.
18. Smart meters are some of the many devices that can cause such “Harmful Interference” that are described in Comments and affidavits filed in this proceeding. Various individuals filed Comments about RF interference with implants that should be heeded. Laddie W. Lawings, retired Naval Nuclear Inspector; Judi Hangarther, RN; Kate Reese Hurd; and Gary Olhoeft, PhD in Geophysics (in the EMRPI Comment).
19. Medtronics, manufacturer of medical implants, warns of harmful interference to implanted medical devices in uncontrolled or controlled environments at current levels.
20. “Cardiac pacemakers, defibrillators, and drug delivery systems…may exhibit improper operation when subjected to strong RF fields. …It is critical…that any new RF rules…ensure that RF exposure limits below 300 kHz do not cause harmful interference to implanted medical devices….” pg 7 Laddie W Lawings, retired Naval Nuclear Inspector.
21. The Mayo Clinic advises that cardiac pacemaker patients take precautions to prevent electromagnetic interference with the proper functioning their device:
COST ANALYSIS:
IV. COST ANALYSIS
22. The FCC appears to be assuming that there will be a large cost to lowering its current RF safety limits. If setting RF safety limits much more restrictive than the current FCC RF safety limits has a substantial cost, the countries such as Switzerland, Russia, China, and others who use a 0.1 µW/cm2 RF safety limit would have experienced these costs. No such adverse cost to countries that allow 100 times lower RF safety limits has been substantiated.
23. As for the dollar cost of the health damage caused to millions of Americans from using RF safety limits that allow this radiation to interfere with the health and well-being of citizens, the responsibility and resources for compiling and comparing the dollar cost from lax vs. protective RF safety limits rest on the FCC and relevant Federal Agencies.
24. The EPA should be provided with the extensive Comments on health in this record that indicate damage at the present FCC-allowed levels of RF exposure and asked to provide the dollar value of this damage, insisted upon by the FCC. The FCC can then subtract the documented cost of requiring RF safety limits that are 100 times more protective based on what has happened in the countries using those RF limits and arrive at the cost of not acting to protect human health.
25. Federal Agencies put the economic value of a human life at $ 6-7.9 million.
26. Substantial damage occurs when people are disabled from an environmental illness. The Annual Cost to the U.S. of Environmental Illness is between $57 billion and $397 billion.
Muir & Zegarac-Charyl Zehfus Sept 16, 2013 filing of PMID 11744507 [PubMed-indexed for
MEDLINE] PMCID: PMC1240624
27. Costs of some diseases associated in the peer-reviewed research record with EMR exposure that are found in academic journals and government and foundation resources are:
• Autism - $137 Billion USD - Xuejun Kong, MD - Christopher McDougle, MD. N. Am J.
Med. Sci. 6(3) 2013
• Cancer - $125 billion USD - (2010) http://www.ncbi.nlm.nih.gov/pubmed/21228314
• Cardiovascular Disease - $444 billion (2010)
http://www.cdc.gov/chronicdisease/resources/publications/AAG/dhdsp.htm
• Diabetes – Statistics from the new report of The International Diabetes Foundation:
1. An estimated 5.1 million people died of diabetes-related complications in 2013.
2. 17% of babies in 2013 were born to women with high blood sugar levels, a sign of gestational diabetes that will contribute to the global diabetes burden in years to come.
3. More than 79,000 children developed Type 1 diabetes in 2013; that's up from 77,800 in 2011.
4. The equivalent of $548 billion were spent on health care for diabetes patients around the world in 2013.
5. China, India and the United States top the list for the most cases of diabetes per
country; around 24.4 million Americans had the disease in 2013.
28. In addition to the host of diseases linked to EMR at current levels, electrohypersensitivity (EHS), which afflicts 3% of the population, often substantially disables these people.
(Grassroots Environmental Education, Inc. View 97 filed 9/24/13).
29. On October 15, 2013, the French federal agency ANSES (National Agency for Food, Environment and Work Health Security) published an update to its 2009 report http://www.anses.fr/sites/default/files/documents/PRES2013CPA18EN_0.pdf on the state of knowledge on risk related to exposure to radiofrequencies “based on a review of the international scientific literature” stating that:
. . . against a background of rapid development of technologies and practices, ANSES recommends limiting the population’s exposure to radiofrequencies – in particular from mobile phones – especially for children and intensive users, and controlling the overall exposure that results from relay antennas. It will also be further developing its work on electro-sensitive individuals, specifically by examining all the available French and international data on this topic that merits attention.
30. Numerous individual Comments on EHS such as Richard Meltzer, Shelley Master, Miriam Weber, M.D. Michele Hertz, Michael Schwaebe, Kevin Mottus, Heather Lane, Scott Spiegal, Kate Reese Hurd, Edna Willadsen, Diane Schou, Deborah Rubin, and many others are of record in this proceeding.
31. Commenter Kit Weaver presents documentation that Utilities, and others in the smart grid, smart meter and smart home industry are violating the ADA by subjecting people with electromagnetic sensitivity to RF radiation in their own homes. “The FCC should stipulate that no utility, government, or other entity can require installation of an RF-emitting device upon one’s property without consent.”
32. EMRPI strongly opposes the Reply of the Utilities Telecom Council (UTC) that calls for categorical exclusion of Smart Meter facilities from routine evaluation. There is no need to return to the dangerous concept of exclusion by category. There has been no FCC evaluation of the complex emissions scenarios that arise from wireless Smart Meter buildout. The FCC does not know what the radiation patterns and emissions levels are when antennas are clustered on apartment buildings or in neighborhoods where buildings are close to each other.
V. INSURANCE COMPANIES RECOGNIZE SUBSTANTIAL RISK OF DAMAGE
CLAIMS
33. Lloyd’s of London is excluding coverage for claims for negative health effects from RF
radiation exposure as stated in the submitted affidavit of Michael Schwaebe, Professional
Engineer, who swears to physiological effects experience by himself and observed in 13 of his
clients:
Two of the world's largest insurance companies, Lloyds and Swiss Re, have
recommended to other insurance companies to write in exclusion clauses against
paying compensation for illnesses caused by continuous long-term non-ionizing
radiation exposure.[1,2] . The recent Austrian insurance company AUVA report
confirms DNA-breaks caused by non-ionising radiation, but the report leaves many
issues open. Remember what Swiss Re wrote in 2005?
For the insurance industry, this standoff gives rise to an extremely
dangerous risk of change composed of two parts: the classical development
risk, that is, the possibility that new research findings will demonstrate
electromagnetic fields to be more dangerous than has hitherto been
assumed; and the sociopolitical risk of change, in other words, the
possibility that changing social values could result in scientific findings
being evaluated differently than they have been thus far.
Update 24th September: This is bad news for those employers who expose their
workers heavily to non-ionising radiation. Precedents: There are already several
cases where the worker got compensation because their tumours etc., were caused
by mobile phone& other occupational EMF exposure [1,2,3,4,5] . And the amount of cases will most likely increase:
http://beyondradiation.blogs.com/mblog/2010/09/insurance-companies-do-not-cover-health-damage-caused-by-mobile-technologies-disconnect.html34. EMRPI and the endorsed Commenters lay out evidence of widespread present disease and disability with the resultant medical bills and loss of work from over-radiating the public. The future economic impact on young children now being affected will ripple forward in time and amplify as the negative health effects multiply with their cumulative and ever-increasing exposure.
35. The concept that thermal injury is “the only scientifically established mechanism of harm” for EMR and RF effects is simplistic and outdated.
36. Biological Mechanisms are comprised of complex interrelationships at the microscopic level. The FCC must accommodate changes in scientific knowledge found in studies published since 1986 on mechanisms of non-thermal effects of EMR and RF radiation exposure to humans and the environment.
37. The FCC must assess the research needs and gaps relating to potential biological and adverse health effects of wireless communications devices identified in the 2008 National Academies of Science Report 12036.
38. Recent research findings support continuing precautionary actions by various governments and agencies. Current research findings support the concept of biologically-based EMR and RF exposure safety limits.
39. NEPA mandates that it is time for the FCC to establish biologically-based EMR and RF Radiation Safety regulations. The FCC must comply with NEPA requirements.
40. The evidence of the need to revise FCC RF safety limits and exposure regulations to protect all members of the public are overwhelming. The FCC's duty to protect the public is beyond dispute. The Commission has failed to comply with the House Committee on Commerce's mandate to adopt "uniform, consistentent requirements, with adequate safeguards of
the public health and safety," and that these were to be "established as soon as possible." (H.R.
Report No. 104-204, p. 94) This is a core duty imposed on this Commission. The
Congressional Committee reiterated this expectation for emphasis on page 95 of House Report
104-204:
The Committee believes the Commission rulemaking on this issue (ET Docket 93-62) should contain adequate, appropriate and necessary levels of protection of the public, and needs to be completed expeditiously.
41. This Congressional statement requires on-going conscientious Commission compliance -- sufficient to protect the public in light of all of the research, health studies and experience now available to the agency.
Respectfully submitted,
The EMRadiation Policy Institute
by Janet Newton, President
P.O. Box 117
Marshfield VT 05658
E-mail: info@emrpolicy.org
Telephone: (802) 426-3035
Whitney North Seymour, Jr.
425 Lexington Avenue, Room 1721
New York, NY 10017
Tel: 212-455-7640
Fax: 212-455-2502
Email: wseymour@stblaw.com
Gabriel North Seymour
Gabriel North Seymour P.C.
200 Route 126
Falls Village, CT 06031
Tel: 860-824-1412
Email: certiorari@earthlink.net
November 18, 2013 Attorneys for The EMRadiation Policy Institute
http://apps.fcc.gov/ecfs/document/view?id=7520958408
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