HHS and FCC RFI Submissions
The HHS and FCC RFI Submissions relate to two U.S. government requests for information concerning electromagnetic fields (EMFs) and radiofrequency (RF) radiation. The U.S. Department of Health and Human Services (HHS) sought public input on EMFs and wireless radiation exposure. Separately, the Federal Communications Commission (FCC) invited comments in connection with its reassessment of RF exposure limits and policies, following a court remand in Environmental Health Trust v. FCC (2021).
This post presents James Chrystopher Lech’s two submissions, which address different aspects of RF exposure, including research, measurement and assessment.
1. Submission to the U.S. Department of Health and Human Services (HHS)
Request for Information on Electromagnetic Fields (EMFs), Radiofrequency (RF) Radiation, and Wireless Radiation Exposure
Docket No.: HHS-OASH-2026-0397
Comment by: James Chrystopher Lech
Date: 30 September 2026
The comment addresses the HHS request for information from the perspective of an independent scientist who submitted South Africa’s national reports to the WHO International EMF Project for 2021 and 2022.
Its topics include exposure characterisation, a proposed “light-first envelope”, the importance of considering exposure configurations rather than relying on a single numerical limit, and an offer to brief on the simulation of combined exposures.
The submission also refers to professional engagement with Dr Rune Floberghagen of the European Space Agency, Prof. László G. Boros, Dr Stephanie Seneff and former U.S. Ambassador Claire A. Pierangelo, as well as the Dutch Hacking Health Award. The submission cites related correspondence and supporting documents, which are not attached to the comment.
View the HHS submission on Regulations.gov | HHS submission (PDF)
2. Submission to the Federal Communications Commission (FCC)
In the Matter of Reassessment of Federal Communications Commission Radiofrequency Exposure Limits and Policies
Docket: FCC ET Docket No. 13-84
FCC document: DA 26-997
Comment by: James Chrystopher Lech
Date: 30 September 2026
The FCC submission addresses the six issues remanded in Environmental Health Trust v. FCC (2021), as framed in DA 26-997:
- Portable-device testing procedures
- Children
- Long-term exposure
- The ubiquity of wireless devices
- Technological changes since 1996
- Environmental effects
The comment identifies Lech as an independent scientist and outlines his background in non-ionising radiation research, reporting for the WHO International EMF Project, selected research publications and applied research projects. It also refers to professional correspondence concerning research methods and exposure assessment.
The comment states that it addresses only the six issues remanded to the FCC and does not ask the Commission to relitigate matters the court left undisturbed.
Read James Chrystopher Lech’s FCC submission
Institutional disclaimer
The submissions state that they were not made on behalf of the World Health Organization (WHO), the South African National Defence Force (SANDF), the European Space Agency (ESA), the South African National Research Foundation (NRF), the International Commission on Non-Ionizing Radiation Protection (ICNIRP), Vrije Universiteit Amsterdam, or any government. The FCC submission also states that it was not made on behalf of FCC peer agencies.
Access to Public Submissions
Public submissions to both requests for information can be accessed free of charge through the official U.S. government websites. The records include submissions from scientists, researchers, organisations and other interested parties, allowing readers to explore a range of perspectives.
- HHS: View public comments and documents in Docket HHS-OASH-2026-0397 on Regulations.gov
- FCC: Search public filings in the FCC Electronic Comment Filing System (ECFS). Search for ET Docket No. 13-84 to find filings relating to the reassessment of radiofrequency exposure limits and policies.