The Honorable Robert F. Kennedy, Jr.
Secretary of Health and Human Services
U.S. Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, D.C. 20201
Re: Protecting U.S. Children from Radiofrequency Radiation — Correcting MAHA, Enforcing Public Law 90-602, and Launching a National Li-Fi-First Initiative
Dear Secretary Kennedy,
You know the federal RF record as well as anyone. As counsel and plaintiff in the litigation that forced a judicial remand of the FCC’s 1996-era exposure limits, you have seen firsthand how aggressively agencies and industry have resisted accounting for non-thermal biological effects.
I am writing not only as an engineer, but as a father who has already paid the ultimate price, to ask HHS to take the lead on a child-first reset of federal RF policy — one that:
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Corrects the glaring omissions in the White House MAHA Assessment.
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Enforces Public Law 90-602’s mandate for continuous safety review.
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Moves our nation immediately to a Li-Fi-first indoor connectivity plan while updated protections are put in place.
This is not abstract. My firstborn daughter is gone. My seven-year-old daughter sits 465 feet from a cell tower at her school desk. Section 704 of the Telecommunications Act prevents our community from contesting such siting on health grounds so long as 1996 thermal metrics are met — metrics that a federal court has already found indefensible. Parents are told “the standards are safe,” even as the science has moved far beyond heating-only assumptions.
What MAHA Missed — and Why It Matters
Evidence window: MAHA’s RF section relies on pre-2023 sources, labels evidence for child harms as “low to inadequate,” and fails to incorporate two WHO-commissioned mega-reviews (2024–2025) that elevate certainty for key hazards. It also ignores the best-documented funding bias in environmental health: wireless-industry sponsorship effects. The result is a skewed, outdated picture that understates risk to children.
Convergent animal evidence:
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NTP (2018): “Clear evidence” of heart schwannomas and malignant gliomas in male rats. Tumors were present at all exposure groups, absent in controls. For GSM brain lesions in males: 0/90 (control), 3/90 (1.5 W/kg), 3/90 (3 W/kg), 2/90 (6 W/kg) — a non-monotonic pattern.
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Ramazzini (2018): Same tumor type at far-lower, tower-like exposures (~0.1 W/kg).
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WHO review (2025): Certainty of evidence for gliomas and heart schwannomas in male rats judged high; non-monotonicity noted again.
Male fertility: WHO-commissioned review (2024; corrigendum 2025) found moderate-certainty evidence that male RF exposure reduces pregnancy rates in mating studies, with additional sperm and DNA endpoints trending adverse. These effects carry intergenerational consequences.
Sponsorship bias:
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EHP systematic review (2007): industry-funded RF studies were ~9× less likely to report significant biological effects than independent studies.
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Updated tallies: ~72% of industry-funded studies report “no effect,” versus roughly one-third of independent studies.
Any national assessment that names corporate capture in pesticides and pharmaceuticals must name wireless — or it protects the bias by omission.
Historical record: Before 1996, the federal and military literature already documented non-thermal effects — from Frey’s microwave auditory effect (1960s) to the Navy’s 1971 NMRI compendium, through Air Force/Navy reviews of the 1980s–90s, EPA analyses in the early ’90s, and the CTIA’s own $25-million Wireless Technology Research program. The adoption of thermal-only limits in 1996 did not happen in ignorance; it happened in defiance of the record.
Why Heat-Only Limits Are Scientifically Indefensible
Biology is not linear. Tumor and fertility patterns documented by NTP and WHO cannot be explained by heating alone. Mechanisms including ion-channel perturbation, calcium signaling disruption, oxidative stress, and DNA damage operate at intensities far below FCC thresholds.
The 1996 FCC limits were not merely “outdated.” They were fraudulent from inception — constructed to ensure compliance with a narrow, heat-only model that excluded known risks.
The Legal Context HHS Must Address
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1996 thermal limits still govern, despite massive changes in exposure patterns and technology.
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2021 D.C. Circuit ruling: FCC’s decision to keep those limits was “arbitrary and capricious” for ignoring long-term, non-thermal, and child-specific effects. Matter remains on remand.
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Section 704 (47 U.S.C. § 332(c)(7)(B)(iv)) gags state/local governments from considering health in antenna siting decisions if FCC rules are met.
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Public Law 90-602 tasks HHS with controlling radiation from electronic products through research and performance standards. Halting RF research and failing to update protections violates this mandate.
A Practical Path Forward — Li-Fi First, Starting Now
Nationwide wired coverage to meaningfully reduce indoor RF exposures is decades away. Children cannot wait. The fastest, most achievable way to slash indoor RF exposure is to shift high-throughput traffic from radio waves to light — Li-Fi — while expanding fiber backbones in parallel.
Li-Fi delivers:
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Immediate reduction of indoor RF exposure by shifting payloads to infrared/visible light.
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High throughput, low latency, and room-scale confinement for better security.
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Energy efficiency and dense spectral reuse without raising ambient RF.
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Strategic boost to U.S. photonics manufacturing and technology leadership.
Requested Actions from HHS
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Correct the MAHA record — Issue an erratum and technical annex incorporating WHO 2024–2025 reviews, NTP/Ramazzini convergence, and sponsorship-bias literature; explain non-monotonic biology in plain language.
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Form an HHS-led Pediatric RF Health Task Force (FCC, EPA, DOE, ED) to produce within six months a public roadmap addressing the D.C. Circuit remand for children, long-term exposures, modulation, and modern devices.
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Restart and expand federal RF health research under HHS authority with independent governance, preregistration, open data, and COI firewalls.
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Issue a national Li-Fi-first advisory for schools/childcare, with procurement specs, device settings, and facilities guidance to minimize RF indoors.
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Launch a Li-Fi School Demonstration — 100 schools in Phase I, 1,000 in Phase II; track RF reduction, performance, and health/learning metrics.
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Publish child-protective siting principles for federal properties serving children; recommend state/district adoption; urge Congress to revisit Section 704.
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Modernize consumer guidance — replace SAR-only messaging with clear steps to reduce cumulative exposure at home, in transit, and during sleep.
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Commission the National Academies to synthesize mechanisms/non-monotonic effects relevant to child health and translate into HHS-usable metrics.
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Coordinate with Commerce and Energy to align Li-Fi rollout with domestic photonics manufacturing, leveraging CHIPS-adjacent funding.
Closing
Mr. Secretary, HHS is uniquely positioned to act. The pediatric chronic-disease crisis demands plain truth: the 1996 thermal-only limits are scientifically indefensible, Section 704 strips communities of protective rights, and the evidence now before us — WHO 2024–2025 reviews, NTP and Ramazzini studies, decades of military and EPA findings, and quantified sponsorship bias — requires immediate action.
Li-Fi-first is the fastest way to protect children indoors while we modernize our standards and infrastructure.
Please accept the attached figures and references. I welcome the opportunity to brief your team and connect you with districts ready to pilot Li-Fi now.
Respectfully submitted,
John Coates
Founder, RF Safe
