Cellular Phone Task Force Post Office Box 6216 Santa Fe, NM 87502 USA (505) 471-0129 www.cellphonetaskforce.org November 24, 2015

Arthur Firstenberg President Santa Fe, NM

MCPS CEO Dr. Andrew Zuckerman MCPS Board of Education Montgomery County Schools Carver Educational Services Center 850 Hungerford Drive Rockville, MD 20850

Kathy Hawk, B.Sc. Butler, PA

Regarding: Dangers of WiFi to Children

Board of Directors

Duane Dahlberg, future. Ph.D. Frazee, MN Marcia Frumberg, M.S.W. Plano, TX Marilyn Garrett Aptos, CA Erica Mallery-Blythe, M.D. UK Tim McNerney Northampton, MA Janet Palmer Patagonia, AZ Jolie Andritzakis Secretary Santa Rosa, CA

Dear Dr. Zuckerman and the Board, I am president of the Cellular Phone Task Force. We provide education, advocacy and support around electromagnetic radiation and its dangers. Our organization was founded in 1996. I am personally in touch with thousands of individuals who have been injured by wireless technology in its various forms, including children unable to go to school because of WiFi in their classrooms. I'm not talking about children whose parents are "concerned." I'm talking about children who cannot go to school because if they do, they come home dizzy, nauseous, with headaches, skin rashes, nosebleeds, and worse. I have a B.A. in mathematics and physics from Cornell University, and went to medical school (1978-1982) at the University of California, Irvine School of Medicine. I have been studying bioelectromagnetics, the science of the interaction between electromagnetism and life, for 35 years. Here are my comments on the Frequently Asked Questions that are on the MCPS’s website: 1. Protocol: "Data were collected for six minutes." The required averaging time is six minutes for occupational exposure, and 30 minutes for the general population. They therefore did not use a protocol authorized by the FCC.

The Cellular Phone Task Force is a 501 (c)(3) non-profit organization as defined by the U.S. Internal Revenue Service.

2. Narrow band measurements will not tell you what you want to know. Radiation injury is cumulative over time as well as over the whole spectrum. WiFi, RF-ballasted lighting, AM, FM, TV, and cell phone frequencies are all present and you need a broadband measurement to see what the students are actually exposed to. Adding WiFi to an already

substantial mix can turn a safe environment into a toxic one that can cause permanent injury. 3. The FCC guidelines were adopted in 1996. The database it relied on was current only to 1986, ten years before digital cell phones came to the United States and fifteen years before WiFi was invented. Those guidelines are thirty years out of date. 4. The Environmental Protection Agency drafted Stage I RF-exposure guidelines in 1995, and sent them around to other agencies for their comment prior to planned release of the guidelines in early 1996. Stage I was for thermal effects. EPA announced that Stage II guidelines, to protect against non-thermal effects, would be ready in 1998. The Telecommunications Industry Association lobbied Congress to prohibit the EPA from releasing any guidelines. The 1996 Appropriations Bill that Congress passed not only defunded the EPA's work in this area, but contained language specifically prohibiting the EPA from releasing its regulations. We requested a copy of them under FOIA and were refused. The 1996 Telecommunications Act awarded authority over the health effects of wireless technology to a non-health agency, the FCC. It is a major scandal. I have thorough documentation of all of this. 5. MCPS's statement that "there is no basis on which to establish a different safety threshold" has some truth to it, because when they say "threshold" they are talking about power levels only. Power levels are an engineering concept that has no relevance to biology. When I say there is some truth, that is because there is no safe power threshold for pulsed RF radiation. The limit should be zero. For the same amount of power, continuous waves are enormously less harmful than pulsed (digital) radiation. We also have many studies showing power "windows" of maximal effect, and other studies showing that lowering the power increases the harm. See the work of Salford's team at the University of Lund, Sweden, finding an inverse relationship between power levels of a cell phone and damage to the blood-brain barrier. It is simply not the case that you can eliminate the harm of digital wireless technology by reducing the power level. 6. MCPS's statement that there is "no scientific evidence" establishing a causal link between wireless device use and any illnesses is a flat lie. I receive an average of five emails a day forwarding me new studies showing a causal link between cell phones, WiFi, cordless phones, baby monitors, cell towers, etc., and various types of neurological, cardiological, and other types of injury, including cancer. 7. The WHO is absolutely correct that there have been over 25,000 scientific studies published over the last 30 years on the biological

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effects of non-ionizing radiation. What the WHO does not tell you is that the majority of these 25,000 studies found one or more harmful effects of the radiation. The WHO's statement of no harm is not based on an analysis of that database, but is purely a political statement, unpublished, not peer reviewed, and without any named author. 8. MCPS's claim that its system is not industrial strength contains an admission that it is industrial strength. It says the access points are not even plugged into the wall, but "are powered by 7.5-15 watts of power." That is a huge, dangerous amount of power for a wireless transmitter. If you stood one foot in front of a 15 watt wireless antenna you would be over the limit allowed by the FCC. Furthermore, WiFi access points are regulated as mobile devices under Section 2.1093 of the FCC's Rules. As such, they are required to be at least 20 centimeters from all persons at all times. The public is not told this. Sincerely, Arthur Firstenberg P.O. Box 6216 Santa Fe, NM 87502 (505) 471-0129 [email protected]

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