Thursday, December 26, 2013

American Academy of Environmental Medicine


6505 E Central • Ste 296 • Wichita, KS 67206
Tel: (316) 684-5500 • Fax: (316) 684-5709

August 30, 2013

 Office of the Secretary
Federal Communications Commission
445 12th Street, SW
Washington, D.C. 20554

Re: ET Docket No. 13-84
Dear Federal Communications Commission Commissioners:

The American Academy of Environmental Medicine is writing to request that the
FCC review radiofrequency (RF) exposure limits (reference is made to the FCC's
NOI sections 48, 51, 52, 53, 56, 60, 65 and 69), recognize non-thermal effects of
RF exposure (NOI sections 66 and 69), and lower limits of RF exposure to protect
the public from the adverse health effects of radiofrequency emissions (NOI
sections 48, 52, 54, 65 and 71).

Founded in 1965 as a non-profit medical association, the AAEM is an international
association of physicians and scientists who study and treat the effects of the
environment on human health. With an elite membership of highly trained
physicians and clinicians, AAEM is committed to education, public awareness and
research regarding Environmental Medicine.

It became clear to AAEM physicians that by the mid 1990’s patients were
experiencing adverse health reactions and disease as a result of exposure to
electromagnetic fields. In the last five years with the advent of wireless devices,
there has been an exponential increase in the number of patients with
radiofrequency induced disease and hypersensitivity.

Numerous peer reviewed, published studies correlate radiofrequency exposure
with a wide range of health conditions and diseases. (NOI sections 54, 59, 60 and
65) These include neurological and neurodegenerative diseases such as Parkinson’s
Disease, ALS, paresthesias, dizziness, headaches and sleep disruption as well as
cardiac, gastrointestinal and immune disease, cancer, developmental and
reproductive disorders, and electromagnetic sensitivity. The World Health
Organization has classified RF emissions as a group 2 B carcinogen. This research is
reviewed and cited in the following attached documents: AAEM Electromagnetic
and Radiofrequency Fields Effect on Human Health and AAEM Recommendations
Regarding Electromagnetic and Radiofrequency Exposure.

The scientific literature proves that non-thermal adverse effects of RF exposure
exist and negatively impact health and physiology. New guidelines based on
measurements of non-thermal effects and lowering limits of exposure are needed
and critical to protect public health.
Page 2 FCC

In fact, electromagnetic sensitivity and the health effects of low level RF exposure have
already been acknowledged by the federal government. In 2002, the Architectural and
Transportation Barriers Compliance Board stated:



“The Board recognizes...electromagnetic sensitivities may be considered disabilities
under the ADA if they so severely impair the neurological, respiratory or other functions
on an individual that it substantially limits one or more of the individual’s major life
activities”

Additionally, in 2005, the National Institute of Building Sciences, an organization established by
the U.S. Congress in 1974, issued an Indoor Environmental Quality Report which concluded:

For people who are electromagnetically sensitive, the presence of cell phones and
towers, portable telephones, computers,... wireless devices, security and scanning
equipment, microwave ovens, electric ranges and numerous other electrical appliances
can make a building inaccessible.”

By recognizing electromagnetic sensitivity, the federal government and affiliated organizations
are clearly acknowledging the existence of non-thermal effects. The AAEM urges the FCC to
recognize that non-thermal effects of RF exposure exist and cause symptoms and disease. (NOI
sections 66 and 69) The AAEM also requests that the FCC base guidelines of RF exposure on
measurements of non-thermal effects and lower the limits of RF exposure to protect the health
of the public. (NOI sections 48, 52, 54, 65 and 71)

Sincerely ,

 Amy L. Dean, DO, FAAEM, DABEM, DAOBIM
President

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