New Program Threatens Public Health, Group Warns FCC

Global Union Against Radiation Deployment from Space

December 17, 2015

google-wifiMs. Marlene H. Dortch
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C., 20554

Re: Informal Objection Under Section 5.95 to Application of Google, Inc., Application for Experimental License, File No. 0747-EX-PL-2015

Dear Ms. Dortch,

We are writing in opposition to the request by Google, Inc. for an experimental permit to blanket 88.6 – 99.6% of the land area of the continental U.S. with radiofrequency (RF) radiation. Due to the documented harmful effects of RF radiation exposure on human health and the environment, along with the fact this project violates the U.N. Convention on the Rights of Persons with Disabilities, several sections of the U.N. Convention on the Rights of the Child, and International Human Rights Law in the Universal Declaration of Human Rights, approval of this permit should be denied. Question 9 of the Google, Inc. FCC application asks if there will be an Environmental Impact from the project and the applicant has answered in the negative. We emphatically disagree.

GUARDS is an international coalition against global WiFi from space, a technology that endangers all life on Earth. The insurance industry currently recognizes the immense risks of insuring companies against radiofrequency injury claims, and coverage from the major firms like Lloyds and Swiss Re is no longer available. With the lack of adequate insurance, and RF radiation (including the microwave radiation utilized by wireless technology) currently classified a “possible human carcinogen” by the World Health Organization, there are legal implications related to irradiating entire countries and their citizens without their informed consent. Strong correlations exist between RF radiation exposure from wireless technologies, increasing rates of Radiofrequency Sickness and many cancers. In several countries (Italy, France, Spain Australia), plaintiffs have gone beyond correlation to successfully prove causation, and damages have been awarded by the courts. It is also important to highlight the potential for satellites/upper atmosphere antennas and their communications to be hijacked, posing serious security risks.

RF Radiation – Environmentally Harmful and a Public Health Hazard

U.S. Department of Interior States: Current Radiation Standards Inapplicable
On February 7, 2014, the U.S. Department of Interior (DOI) stated, “the electromagnetic radiation standards used by the Federal Communications Commission (FCC) continue to be based on thermal heating, a criterion now nearly 30 years out of date and inapplicable today,” in reference to the current limits governing radiation utilized by WiFi. The DOI letter discusses a number of studies in which birds appear harmed by low-level RF radiation associated with cell towers and other wireless technologies, as are planned by Google, Inc.

FCC Investigation of Current Exposure Limits Underway
With the FCC finally beginning re-evaluation of current irrelevant and obsolete non-ionizing RF exposure guidelines, it seems imprudent to approve technology applications encouraging global proliferation of RF microwave radiation.

In the Inquiry the FCC requests comment to determine whether its RF exposure limits and policies need to be reassessed. Since consideration of the limits themselves is explicitly outside of the scope of ET Docket No. 03-137, the FCC opens a new docket, ET Docket No. 13-84, with the Inquiry to consider these limits in light of more recent developments. The Inquiry is intended to open discussion on both the currency of our RF exposure limits and possible policy approaches regarding RF exposure.

International Recognition of Need for More Conservative RF Safety Limits
Countries around the world are increasingly recognizing the risks of RF radiation and advising action to protect the public Even the U.S., as cited above, is in the process of reviewing RF exposure guidelines. Countries such as China, Russia, Italy and Switzerland already have wireless radiation safety limits 100 times lower than the United States.

Canada: Previous Safety Code 6 Inadequate
In June 2015, Canadian Parliament’s Standing Committee on Health (HESA) issued a report with 12 unanimous recommendations for increased caution, investigations, reporting and data gathering with regard to RF/EMF and wireless devices. Canada’s Safety Code 6 provided guidelines for RF exposure virtually identical to 1996 FCC guidelines until recently (March 2015) when Canada reduced its maximum permissible exposure limits by nearly 50%. “The [HESA] Committee agrees that the potential risks of exposure to RF fields are a serious public health issue that needs to be brought to the attention of Canadians so that they have the knowledge to use wireless devices responsibly and are able to make decisions about the use of wireless devices in a manner that protects their health and the health of their families.” The Standing Committee report shares themes including cancer, illness, fertility, autism, public awareness, school environments, and medical responsibilities. It discusses studies demonstrating adverse effects at levels below Health Canada’s guidelines.

World Health Organization (WHO) Scientists Warn of Increased Risk to Public Health

We are also concerned spatial and temporal increases in microwave radiation caused by this and other planned airborne Wi-Fi deployments will be harmful to public health. Wireless technology operates using pulsed microwave radiation: “The human body,” says Dr. G.J. Hyland (International Institute of Biophysics, Neuss- Holzheim, Germany), “is an electrochemical instrument of exquisite sensitivity,” noting that, “like a radio, it can be interfered with by incoming radiation.” If a signal is strong enough to operate a device, it is strong enough to
disturb every cell in the human body.

In 2011, the International Agency for Research on Cancer (IARC), a committee of the WHO, classified RF radiation as a Group 2B carcinogen in the same category as lead and DDT. Alarmingly, several scientists who were members of the IARC working group involved with this classification now conclude the risks are much greater than originally thought. For example, Dr. Dariusz Leszczynski warns that RF-EMF should be classified as a Group 2A carcinogen, and Dr. Lennart Hardell reports that several studies indicate a Group 1 classification is justified, placing RF-EMF in the same category as tobacco, asbestos, and benzene.

Dr. Dariusz Leszczynski MSc, DSc, PhD
“In conclusion, I consider that currently the scientific evidence is sufficient to classify cell phone radiation as a probable human carcinogen – 2A category in IARC scale. Time will show whether ‘the probable’ will change into ‘the certain’. However, it will take tens of years before issue is really resolved. In the mean time we should implement the Precautionary Principle. There is a serious reason for doing so.”

Dr. Lennart Hardell MD, PhD
“Based on the Hill criteria, glioma and acoustic neuroma should be considered to be caused by RF-EMF emissions from wireless phones and regarded as carcinogenic to humans, classifying it as group 1 according to the IARC classification. Current guidelines for exposure need to be urgently revised.”

Statements like these support our contention that no new large-scale irradiation of the public, like Google’s proposed project, should be allowed prior to establishment of biologically protective RF safety limits. In fact, permitting such a project without first updating RF safety limits to be biologically protective of the whole population for the exposures they are likely to experience daily would be in direct violation of the entire Nuremberg Code of Ethics (

International Scientists Warn of High Risk and Multigenerational Effects
The 1,500-page BioInitiative Report on RF/MW health effects was published in 2012. The authors are 29 scientists from 10 countries. They reviewed thousands of studies showing interference with chemical processes in the body, implicating RF/MW in a whole spectrum of alarming effects including genetic damage, cancer, immune dysfunction, neurological injury, and infertility

More recently, in 2015, from 40 countries over 200 scientists with over 2,000 peer-reviewed journal articles to their collective credit in the field of biological impacts from RF/EMF appealed to the U.N. and the WHO for greater precautions with regard to exposures from wireless technologies. This is the latest in many such alerts to the health effects of RF/EMF exposure

A paper by Michrowski, Electromagnetic Fields: High Level Microwave Technology Concerns,etc-1.pdf references a study by, Magras and Xenos 1997, RF Radiation-induced Changes in the Prenatal Development of Mice The study indicates at environmental wireless exposure levels (0.168 ìW/cm2 to 1.053 ìW/cm2 ) lower than those now commonplace outdoors in Metro Toronto, Hamilton, Mississauga, mice become infertile between third and fifth generations.

The continuous exposure to microwave radiation proposed in this Google, Inc. project along with that emitted from a myriad of wireless devices may have implications far greater than we could imagine with nothing less than the continuation of the human race at stake.

Violation of International Human Rights

This Google, Inc. proposal violates Article 3 of The UN Declaration of Human Rights, ratified by the General Assembly in 1948, which states “everyone has the right to life, liberty and security of person.” Data exist showing RF radiation can cause serious biological effects at levels far below the existing FCC RF limits (

David Dees

These include damage to DNA which can lead to an increased risk for cancer and deleterious genetic mutations passed on to future generations. Decreases in sperm count and quality and increases in miscarriage and infertility have also been demonstrated in response to exposure to RF radiation. Although much of the recent research focuses on frequencies in WiFi and cellphone ranges, prior research is available showing serious biological effects in the mm wavelengths that Google, Inc. proposes to use.

Observed higher resonance frequencies of a living cell coincide with frequencies of radiation of communications satellites. The power densities and duration of irradiation created by these satellites will significantly exceed (by ten or more orders of magnitude—such irradiation is possible over the course of a whole lifetime) the energetic doses inducing changes in living cells.

Negative consequences of this may be changes in cell structures and physiological processes, genetic changes, and alteration of psychophysiological conditions and behavior;

More recent scientific publications look specifically at causality, such as M.L. Pall in “Microwave Frequency Electromagnetic Fields (EMFs) Produce Widespread Neuropsychiatric Effects Including Depression” (J Chem Neuroanat. 2015 Aug 20; It discusses the causal relationship between exposure to radiation from wireless technology and neuropsychiatric effects. Mechanisms of action are also discussed.

Yakymenko et al. discuss the fact that RF radiation is documented in numerous studies to cause oxidative damage and discuss mechanisms (Low Intensity Radiofrequency Radiation: A New Oxidant for Living Cells; Oxid Antioxid Med Sci 2014; 3(1):1-3; (

A more recent study by Yakymenko, et al., 2015, Oxidative Mechanisms of Biological Activity of Low-intensity Radiofrequency Radiation finds in 93 of 100 reviewed studies a wide pathogenic potential of the induced Reactive Oxygen Species (ROS) and their involvement in cell signaling pathways explains a range of biological/health effects of low intensity RF radiation, which include both cancer and non-cancer pathologies. Their concluding analysis demonstrates low-intensity RF radiation is an impressive oxidative agent for living cells with a high pathogenic potential and that the oxidative stress induced by RF radiation exposure should be recognized as one of the primary mechanisms of the biological activity of this kind of radiation.

Lerchl, et. al. in 2015 performed a replication experiment of work done by Tilmann, et. al. in 2010 but increased the N. Their work: Tumor Promotion by Exposure to Radiofrequency Electromagnetic Fields Below Exposure Limits for Humans found tumors in mice promoted by exposures to levels of RF at below government exposure limits for the use of mobile phones. Numbers of tumors of the lungs and livers in exposed animals were significantly higher than in sham-exposed controls. In addition, lymphomas were also found to be significantly elevated by exposure; (

Non-ionizing radiation does act through oxidative mechanisms on cells. Oxidative mechanisms=formation of free radicals. Free radicals may cause cancer. Therefore non-ionizing radiation may cause cancer.

Replicated double-blind studies show that a cordless phone base station operating at WiFi frequencies can cause cardiac arrhythmias in susceptible individuals ( and
Blanketing the continent with radiation that can have such a serious, even deadly effect, is unethical. A study in rabbits found that not only did WiFi change heart function parameters, but it dramatically changed the cardiac effects of both dopamine and epinephrine: Saili L, et al. Effects of Acute Exposure to WIFI Signals (2.45 GHz) on Heart Variability and Blood Pressure in Albinos Rabbit. Environmental Toxicology and Pharmacology 40 (2015) 600–605; ( Therefore, ubiquitous RF radiation may not only cause cardiac emergencies, but prevent treatments from working and cause deaths. The threat to cardiac health is also supported by epidemiological studies showing increased death from cardiac events and heart disease – Criticism of the Health Assessment in the ICNRP Guidelines for Radiofrequency and Microwave Radiation (100 kHz – 300 GHz). (

Forced exposure to an agent that has the effects discussed above and enumerated in the resources listed above would have to be considered as violations of the Nuremberg Code of Ethics ( Google, Inc.’s project would force such an exposure.

Furthermore, this proposal violates Article 25 of International Human Rights (1), which states, “Everyone has the right to a standard of living adequate for the health and well-being of himself and of his family, including food, clothing, housing and medical care and necessary social services, and the right to security in the event of unemployment, sickness, disability, widowhood, old age or other lack of livelihood in circumstances beyond his control.”

Exposure to an agent that disrupts hormones, sleep, cardiac, and neurological function, and has forced numerous people from their homes and into poverty is an obvious violation of numerous fundamental rights which are to be universally protected according to The U.N. Declaration of Human Rights.

Violation of U.N. Convention on the Rights of the Child

Under the Convention on the Rights of the Child, states/countries are responsible for acting in their children’s best interest. In this case, that would mean denying Google, Inc.’s request for an experimental permit to blanket the country in RF radiation.

In a letter to Congress, the American Academy of Pediatrics stated: “Children are disproportionately affected by environmental exposures, including cell phone radiation. The differences in bone density and the amount of fluid in a child’s brain compared to an adult’s brain could allow children to absorb greater quantities of RF energy deeper into their brains than adults.”

No child should be forced to be exposed to RF radiation and therefore forced to incur an increased risk of cancer, functional impairment leading to ill health or cognitive impairment, or genetic damage in their children.

Any of these outcomes, which research supports as likely, violate children’s rights. Electromagnetic Radiation, Health and Children 2014 by Dr. Erica Mallery-Blythe is a must-watch presentation about the hazard that RF radiation emitted by wireless technology poses to children.

Dr. Mallery-Blythe’s presentation references several U.N. Conventions on the Rights of the Child that would be violated by this project including:

Article 3 (best interests of a child) The best interests of a child must be a top priority in all decisions and actions that affect children.

Article 23 (children with a disability) A child with a disability has the right to live a full and decent life with dignity, and, as far as possible, independence and to play an active part in the community. Governments must do all that they can to support disabled children and their families.

Article 24 (health and services) Every child has the right to the best possible health. Governments must provide good quality health care, clean water, nutritious food and a clean environment and education on health and wellbeing so that children can stay healthy.

Article 28 (right to education) Every child has a right to education.

The United Federation of Teachers, representing 200 000 members, currently provides information on their website advising members to reduce to RF radiation, with resources for pregnant mothers in order to protect their unborn children noting that “Wireless radiation is emitted by the myriad of wireless devices we encounter every day. It was once thought to be relatively harmless. However, we now know that wireless radiation can cause non thermal biological effects as well, including damage to cells and DNA, even at the lowest levels.” (

A Brief from the Canadian Teachers’ Federation “The Use of WiFi in Schools (2014), warns that “Teachers and school communities have not been informed regarding the implementation of WiFi and any inherent potential hazards” and go on to share that “Teachers are rightly concerned for their personal safety and the safety of the children in their care” (

Violation of U.N. Convention on the Rights of Persons with Disabilities
Increasing numbers of countries, such as Sweden and France, (as do the Canadian Human Rights Commission and European Parliament) recognize Electrohypersensitivity (EHS) as an environmentally induced functional impairment or disability triggered by exposure to electromagnetic fields (including RF). Continental or global WiFi would contravene: Article 1 “promote, protect and ensure the full and equal enjoyment of all human rights and fundamental freedoms by all persons with disabilities, and to promote respect for their inherent dignity”; Article 3 “Full and effective participation and inclusion in society”; Article 15(2) states: “Parties shall take all effective legislative, administrative, judicial or other measures to prevent persons with disabilities, on an equal basis with others, from being subjected to torture or cruel, inhuman or degrading treatment or punishment”; and violate the intent of many more Articles, since the planet would be blanketed with microwave radiation that those suffering EHS could not escape.

The European Economic and Social Committee (EESC) is an E.U. advisory body comprising representatives of workers’ and employers’ organizations and other interest groups. It issues opinions on E.U. issues to the European Commission, the Council of the E.U., and the European Parliament, thus acting as a bridge between the E.U.’s decision-making institutions and E.U. citizens. In February 2015, a formal letter of notice was sent to the EESC by the Radiation Research Trust (based in U.K.) and approximately 90 other organizations from around the world in support of millions of people, estimated to be between 22,000,000 and 37,000,000 throughout Europe currently suffering EHS due to exposure to the proliferation of RF emissions and emitters (i.e., mobile phones, DECT cordless phones, cordless baby monitors, phone masts, WiFi, smart meters, the smart grid, et al.) (

Some researchers estimate approximately 3% of the population has severe symptoms of EHS and another 35% of the population has moderate symptoms such as impaired immune system and chronic illness (Havas, 2007). Hallberg and Oberfeld published in Electromagnetic Biology and Medicine (2006) historical EHS data and project if past trends continue that 50% of the total population is expected to suffer due to EHS by year 2017
( ).

Canadians For Safe Technology (C4ST) points out, “EHS is accepted as a functional impairment in Sweden and the Canadian Human Rights Commission recognizes it as an environmental sensitivity and classifies it as a disability.” With some countries already recognizing the medical needs of those affected by EHS and the potential for millions of people around the world to suffer EHS from increased exposure to radiation from wireless technology, further proliferation of wireless technology on a wide scale is unacceptable.

Jenny Fry (age 15) hanged herself when her school refused to understand that being in classrooms with WiFi caused her to experience serious physical discomfort and harassed and bullied her by requiring her to serve detentions for leaving classes due to WiFi induced symptoms in rooms where she experienced intense functional impairment ( International Human Rights, Article 26 states that “(1) Everyone has the right to education.” People with disabilities and functional impairments like Jenny’s have a right to go to school in an environment free from RF radiation, in a school that will not make them sick. Her rights, like the rights of all those experiencing this type of
functional impairment, should be protected under the Universal Declaration of Human Rights.

Many other persons experience similar functional impairment when exposed to RF radiation: “Parents Sue School, Claim Wi-Fi Makes Son” (, “WiFi in Schools: How Safe” ( and “Maryland women suffers acute radiation exposure from a bank of smart meters” (

The EUROPAEM EMF Guideline 2015 for the prevention, diagnosis and treatment of EMF-related health problems and illnesses has found: “The health problems may range in severity from benign, temporary symptoms, such as slight headaches or paresthesia around the ear, e.g. when using a cell phone, or flu-like symptoms after maybe some hours of whole body EMF exposure, to severe, debilitating symptoms that drastically impair physical and mental health. It has to be stressed that, depending on the individual state of susceptibility, EHS symptoms
often occur only occasionally, but over time they may increase in frequency and severity. On the other hand, if a detrimental EMF exposure is sufficiently reduced, the body has a chance to recover and EHS symptoms will be reduced or will vanish.” (

Environmental Impacts

A parade of studies continue to be published implicating wireless technology in the die-off of forests, the demise of frogs, bats, and honey bees, the threatened extinction of the house sparrow, and damage to the DNA of the human species. It is vital to the continuation of life that large parts of Earth are spared the incessant radiation that accompanies wireless technologies.

• “The Report on Possible Impacts of Communication Towers on Wildlife Including Birds and Bees” commissioned on 30th August 2010 by the Ministry of Environment and Forest, Government of India
• “Impacts of radio-frequency electromagnetic field (RF-EMF) from cell phone towers and wireless devices on biosystem and ecosystem – a review,”
• Balmori, A. “Electromagnetic pollution from phone masts. Effects on wildlife,” Pathophysiology (2009), doi:10.1016/j.pathophys.2009.01.007
• October 31, 2014 presentation to the Manitoba Entomological Society, reviewing 91 studies on the effects of RF/MW radiation on honey bees, insects, birds, etc:!topic/mobilfunk_newsletter/0RUPGTI4qQY

United Nations Rio Declaration on Environment and Development
The Precautionary Principle as drawn up in Rio in 1992 – the Rio Declaration:

In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.

Principle 15 codified for the first time at the global level the precautionary approach, which indicates that lack of scientific certainty is no reason to postpone action to avoid potentially serious or irreversible harm to the environment. Central to principle 15 is the element of anticipation, reflecting a requirement that effective environmental measures need to be based upon actions which take a long-term approach and which might anticipate changes on the basis of scientific knowledge.

From the U.N. General Assembly: Resolution adopted by the General Assembly July 2012 66/288 The Future We Want
We recognize the importance of strengthening international, regional and national capacities in research and technology assessment, especially in view of the rapid development and possible deployment of new technologies that may also have unintended negative impacts, in particular on biodiversity and health, or other unforeseen consequences.

An ETC Group Press Release UN Moves Towards an Early Listening System shares: “The decision paves the way for a badly needed early warning system on the impacts of new technologies” and explains:

ETC Group proposed the creation of a technology assessment capacity in the UN in the lead up to the 2012 Rio Summit. At that time, the proposal was backed by the G-77 and China and a few OECD states such as Sweden and Norway. The Summit concluded with a surprisingly strong call for technology assessment from local to global levels warning that new technologies could pose significant health and environmental risks.

And from The Lancet:

Planetary health is a new science that is only beginning to draw the coordinates of its interests and concerns. It demands new coalitions and partnerships across many different disciplines to meet the pervasive knowledge failures identified by this Commission. It demands new attention to governance and implementation. And,
perhaps most of all, it demands more creative imagination among scientists and practitioners working in health—redefining the meaning of human progress, rethinking the possibilities for human cooperation, and revitalising the prospects for the health of human civilizations. (par 7)


Second, planetary health concerns the natural systems within which our species exists—for example, the health and diversity of the biosphere. Human beings live within a safe operating space of planetary existence. If the boundaries of that space are breached, the conditions for our survival will be diminished.” Currently, natural systems are being degraded to an extent unprecedented in history, with known and as yet unknown and unquantified effects on human health. (par 2)

Insurance Companies Warn of Large Losses Due To Electromagnetic Fields

We also note that insurance in the event of injury due to RF/MW radiation is not likely to be adequate – see pages 1 and 2 in the document at the following link:

Stop Smart Meters UK shares that: “Insurance Firm, Swiss Re, Warns of Large Losses from “Unforeseen Consequences” of Wireless Technologies: (Source:

Specialists from the Emerging Risks team at leading global reinsurance firm, Swiss Re, are warning the insurance industry that “unforeseen consequences of electromagnetic fields” could lead to a raft of claims and significant product liability losses in the next 10 years.

In its Swiss Re SONAR Emerging Risks report, 2013, which covers risks that could “impact the insurance industry in the future”, the company categorizes the impact of health claims related to electromagnetic fields (EMFs) as ‘high’. It acknowledges recent reports of courts’ ruling in favor of claimants who have experienced health damage from mobile phones, and also says that anxiety over risks related to EMFs is “on the rise”.

The document states that whilst the majority of the topics covered in its pages were of “medium impact”, health issues associated with EMFs sit in the highest impact category. Other topics discussed include the dangers of cyber attacks, power blackouts, workplace safety and Big Data all of which are exacerbated and/or added to with the ill-conceived “smart” metering programs.

Lloyd’s listed hazards from new technologies including EMF in its 2011 Top 50 Risks. Coverage for RF/EMF injuries typically related to cell phones and cell towers is now categorically excluded. In their 2013 Risk Report, new technology risks have increased slightly in risk rank. It is worth noting these risks are classified under Environmental (i.e., does the applicant expect to have an adverse environmental impact?) as distinct from the Lloyd’s appraisal of cybersecurity risks (also applicable to Google, Inc. and rated much higher risk).

GUARDS asserts the Google, Inc. project would intensify these concerns on a continental and global scale.

Interference with Airplane Instrumentation and Hazard to Flight Crew and Passengers
The proposed Google, Inc. project locates transmitters at altitude 62,000 feet. Commercial airspace extends to 60,000 feet. The Google transmitters would broadcast at up to 300 kW immediately overhead all aircraft, whereas a cell tower would be only 1 to 4 kW. It seems likely that these very powerful transmitters pose a risk to commercial aircraft.
Wireless signals are already causing interference with aircraft systems. An FAA Airworthiness Directive (or AD) points out that WiFi on board aircraft is blanking out display units in the cockpit (, The FAA has given a five-year time limit for airlines to replace all these display units. However, even new units may not be able to withstand the strength of signal that the Google, Inc. project would expose them to. There is reason for concern because the same AD mentions, “The intent of this AD is to eliminate this known susceptibility of the phase 3 DUs to RF transmissions, including those from sources outside the airplane. This susceptibility is not limited to WiFi transmissions, but has been verified to exist in a range of the RF spectrum used by mobile satellite communications, cell phones, air surveillance and weather radar, and other systems.”

Furthermore, the signal strength will certainly be strong enough to cause biological functional impairment of the flight crew and the passengers. Since biological functional impairment induced by exposure to RF radiation from wireless technology can range from minor to serious, even including death, it is of paramount importance for the safety of air travel that the permit be denied.

NEPA and Environmental Review

This is major Federal action significantly affecting the quality of human environment; as such, a NEPA review would be triggered. The potential environmental and human health hazards from Google, Inc.’s project necessitate comprehensive NEPA review [Envtl. Def. Fund v. Tenn. Valley Auth., 468 F.2d 1164, 1174 (6th Cir. 1972)] and, specifically, a formal Environmental Impact Statement (EIS). The EIS should include a full review of environmental effects, as well as human health and safety. The FCC has an obligation to evaluate whether “services or capabilities are essential to public health, safety, or in the public interest” (H.R. Report No. 104-204, p. 94), so must protect the public from possible harm caused by radiofrequency radiation.

The FCC is not entitled to essentially disregard comments that do not provide global cost-benefit analysis (Scenic Hudson v. Federal Power Commission). The Commission has an affirmative duty to inquire into and consider all relevant facts. The FCC must use government resources to perform the relevant analysis. The FCC should request the EPA use its National Risk Management Research Laboratory resources and experts to conduct all cost analyses necessary.

This proposal also triggers the need for a Memoranda of Understanding (MOU) with U.S. Fish and Wildlife Service under Executive Order 13186 concerning effects on migratory birds. Legal issues and liability aside, the cumulative and additive environmental and health risks of microwave radiation (MWR) saturation from the upper atmosphere are extremely high. Approval of such technology may never be appropriate given the high risks to societies but certainly at present, given the current state of our knowledge, permit approval would be premature.


Increased health care costs, increased disability and associated costs, decreased productivity from missed or substandard work performance, lost or compromised ecological services and agricultural harm from RF-EMF exposure could cost societies billions of dollars. Not only is RF-EMF proliferation bad for health and the environment directly, this damage has a major economic cost as well.

Please consider our comments as reasons a permit for Google, Inc.’s proposed project should be denied. In brief, those reasons include insurance industry recognition of serious risk to health, cyber and national security, demonstrated detrimental biological effects at levels far below existing inadequate RF safety limits, radiofrequency radiation currently classified “possible human carcinogen” by the World Health Organization, legal implications related to irradiating the entire continent without informed consent, personal security risks, and
resultant violations of U.N. Conventions and Universal Declaration of Human Rights.

Because the potential global effects of this and similar proposals from Facebook, SpaceX and others are devastating, any consideration must proceed only with maximum levels of due diligence, including full public access to application documents and all project specifications—not heavily redacted secretive applications like Google, Inc.’s. The potential dangers to society outweigh any proprietary rights of Google, Inc. The public should have a chance to evaluate and comment on the full application.

Global wireless access, with all its serious safety problems, is an unacceptable hazard. Widely available fast internet access is a goal that can be safely attained using various forms of cabled connectivity.

GUARDS respectfully requests Google, Inc.’s application be denied.

Global Union Against Radiation Deployment from Space
info at

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52 thought on “Google Moves to Blanket 95% of US Land Mass with Microwave Radiation”
  1. Combined with the irreversible destruction of the ozone layer that is causing the greenhouse effect irreversibly warming the planet and melting ice caps – on our way to becoming the same as Mars as water is now evaporating from earth into space – we are now being microwaved as well. Sad they will get away with this just like polluting corporations, oil companies and deforesters get away with all the damage they cause. The fake scientists release so much propaganda people are misinformed and the word ozone, greenhouse effect and Amazon rainforest are banned from media usage.

    1. Wow. Congrats. You outdid yourself

      As far as evaporating water “into space”. That will and cannot happen as gravity keeps the water, in some form, on this earth ( the atmosphere or on land). It’s the same reason you don’t see clouds( water droplets) drifting off to space

      Greenhouse gases are not “banned”. The greenhouse effect is known to many caused by water vapor, methane, and Carbon dioxide gas.

      Please educate yourself

    2. To add on to what Roger said: 95% of greenhouse gases IS water vapor..3.5% is CO2, 4% of 3.5% is what human industrial activity produces.,, covers this extensively.

    3. Mary, Ozone hole appears seasonally & regenerates itself. There was no need to outlaw freon. The whole scam was because a large corp had developed a replacement for freon and wanted the govt to ensure a huge (unnecessary) replacement market. Global warming is not occurring. The planet alternates between warming for approx 27 years, then cooling, then warming, etc. You might want to look at

      or listen to this series of scientist interviews

      I know how persuasive the activists and media are on the subject of global warming. There is immense money behind this lie because the oligarchs hope to do two things: stop development, especially in the 3d world; and make money. The Cap n Trade scam wherein they sell carbon credits is expected to make them $1 trillion annually.

      Let me give you just one example of the type of global warming deception that they use: I have seen many articles which infer that the Antarctic is melting and will flood our coasts. The specific locations that they mention are the West Antarctic Ice Sheet (8% of the Antarctic) or the named glaciers which are a part of the Antarctic Peninsula (2% of the Antarctic). They never tell you that the rest of the Antarctic (90%) is growing. The ice on the rest of Antarctica averages 1 mile thick. Even in summer it is -31 degrees fahrenheit. In order for it melt, the temperature would have to increase by 64 degrees fahrenheit in order to be 1 degree above freezing! The continent of Antarctica where all this ice is, is almost twice the size of the US.

      The sea ice which surrounds the continent does wax and wane w the seasons and from year to year. In 2012 it set a record high, then increased in 2013, and broke that record, too, in 2014. In 2015 it decreased below the 2012 level.

      Unfortunately this microwave matter is very serious. Even the use of a cell phone or carrying one is potentially hazardous. This article gives startling info as to what happens.


  2. Thanks for posting on this.

    A while back I commented on how my sister, who has Down Syndrome, is sensitive to wifi (she had vibrations and humming/buzzing after the next door neighbors got wifi and had it on 24/7). Well, now, as things turn out, it’s looking like she might actually have Lyme Disease–I’ve actually found a couple of doctors (Klinghardt on Mercola’s site) talk about how people with Lyme are actually especially sensitive to wireless radiation. Klinghardt actually suspects that the radiation is making pathogens like Lyme more virulent. We are still in the process of getting her tested, and as it turns out, it’s somewhat difficult to get doctors to sign-off on the proper testing. There’s a lot of controversy within the medical mafia establishment on Lyme–I kind of think it has something to do with Lyme possibly being a US bioweapon with origins on Plum Island. For those interested, an excellent documentary to watch is “Under Our Skin”

    1. If you can, miss, please look into LYME DISEASE as a bioweapon. A lot of what we believe are natural sicknesses(like Salk’s Polio vaccine causing Polio…Simian Virus #40 in vaccine causing cancers) are being caused by the vaccines themselves. Professor Tracy put out a PDF on vaccines some time ago written by an author published in the ’50s. Can you refer her to it, Dr. Tracy?

      1. Can any lawyers comment on whether I can sue my doctor for threatening to drop my baby as a patient if I refuse vaccinating him? I signed the waiver by the CDC which allowed parents in CA to opt out of vaccinating their children (if signed by 12/31/15). She has bullied me into giving in on each appt threatening to drop him and saying no other doctor will take him as a patient which is somewhat true based on calls I have made to other offices. They get paid hundreds of dollars per vaccine visit every 1-3 months. Now that he’s turned 1 I don’t want to continue getting him injected with the MMR booster and the rest of the junk with cow, chicken, horse and other animal components, ethyl mercury which is still found in the shots though she says it’s not, aluminum and other junk. 3 of my nephews came down with autism after completing their shot schedule and I don’t want my son to be the 4th in the family. Can she legally drop him as a patient as she’s threatening? She says he will die of the diseases the shots are created to prevent. I asked what about the Disneyland incident recently when those who contracted measles from the international tourist there, they had been immunized and it didn’t prevent them from getting the measles so what’s the point? Her response was maybe they hadn’t had their booster shots, which is unlikely. Those who are immunized that far along likely continue on their schedule. I can research to see if that was the case.

        1. “drop your baby as a PATIENT, not drop your baby physically”, I hope this is what you are saying.

        2. My advice is to find a new pediatrician.

          Lawsuits are a nightmare, expensive and time consuming…and you could be stuck paying opposing counsel’s fees if you lose.

          If your child isn’t sick, why take her/him to a doctor anyway? When my son’s pediatrician retired (my son was only about 3 at the time), I didn’t bother getting a new one. We saw a specialist when we needed one, or my doctor the few times he was sick enough to warrant a doctor’s visit.

        3. A Dr. has the right to drop you. They must notify you by certified mail and give you 30 days to find a new Dr, you must send them a release letter so they can send the medical records to your new Dr. of choice.

  3. I guess there’s no turning back now, is there? Honestly, I believe that if it was proved beyond a shadow of a doubt that WiFi/cell phones cause cancer, most of the population would not blink an eye; they are too addicted to this technology. Maybe the government will tax it as they do cigarettes, but it looks like this is here to stay, consequences be damned!

    1. It’s already proven that some foods (processed meet and certain dairy) cause cancer and a few days ago a study stated certain sugars in the large quantities an average American consumes causes cancer to grow and spread yet I doubt people are changing their diets. So…

  4. This is your TECHNOCRACY STUDY COURSE(PDF it) in spades!! Patrick J. Wood seems to be the most articulate so far in uncovering much of this, but those commenters should also read(if the Professor hasn’t already) “Between Two Ages: America’s role in the Technetronic Era” by Trilateralist Zbigniew Brzezinski (Rockefeller flunky like Heinz(Henry) Kissinger).

  5. What I find interesting is that REAL ENVIRONMENTALISM is completely disregarded, but if you wish to deindustrialize back to the FLINTSTONES…well, everything’s fine!! No animal husbandry, because that’s cruelty, so how about we use mid-19th century electric technology to bring us to..THE GUILDED AGE once again! Orville & Wilbur…WRONG! Rubbing two sticks together increases CO2, which is responsible for environmental devastation such as…PHOTOSYNTHESIS!! Again, what a joke. Hope your family’s well during this crap, Prof.

    1. Agreed..

      Where are the so called Environmentalists when it comes to:

      GMO’s, Weather Mod (chemtrails), Bio Weapons, Corporate Vaccines for profit.

      Congress just approved removing all labels on meat so we don’t know where it came from. I want to know and will not buy meat from other countries.

      ust as the “Environmentalists” don’t care that WE WANT to Know if our crap food has GMO’s.

      I just want to know……..Whats the problem? 98% of the Zombie’s don’t care. It wont hurt your bottom line Wall Street.

      Please Label My Food Wall Street and Democrats.

      1. Lenin said: “we shall win by slogans”. He also said(I believe) that the best way to eliminate the opposition is TO CREATE IT. Controlled opposition is the order of the day. One of the ” founders” of the CLUB OF ROME(on paper)was a British intelligence operative who intercepted the patents to DDT…interestingly intelligence ops was responsible for the ban of DDT and the subsequent deaths from malaria in African countries (why they need mosquito nets)…by the made up story of Rachel Carson regarding her husband( blows this wide open regarding no scientific evidence of DDT causing cancers). “The First Global Revolution” by The Club Of Rome elucidates that author. But, check into the founders of Club of Rome(hint…it ain’t the Italian industrialist/activist).

  6. I live about 30 miles away from Porter Ranch, north of LA. Porter Ranch is a bourgeois community with an average income of over a hundred thousand a year. It is located near an underground gas storage area of Southern Cal Gas. Since October, this underground gas storage facility has sprung a leak, and is spewing huge amounts of methane and carcigenics in the air, causing headaches, vomiting, and other symptoms in the people and animals. The people have had to leave their homes and live elsewhere.

    Recently, finally, the state of Cal declared an Emergency, and doctors have told the remaining people to move away from the still spewing gas.
    It is apparently a situation like the BP oil spill in the Gulf of Mexico, where SouthCal Gas cannot make repairs. There are 81 other underground gas storage cites near LA, apparently the same age as this one.

    This situation is a function of the corporations controlling the government, rather than the government regulating the corporations. The problem is Free Enterprise, not restrictive government, which is not restrictive enough. Telling this to US alienated reaction is like explaining to my cat as she lies on my desk that I would really appreciate her not chewing on my notes as I work, or knocking the papers and pens on the carpet.

    American opinion cannot accept that government is necessary to restrict and regulate Free Enterprise in order to make it livable. The central US problem is not government, but the Free Enterprise oligarchy that controls both government and corporations. This has created an anti-people state power system of government AND corporations, that subjugate and rule people, allowing disasters like this, and the gulf, to occur.

    Modern society can only function effectively ruled by a people-controlled state-market system. The big banks should not be broken up, as Dem Progressives demand, but should be nationalized to control the major corporations. And the major corps should be nationalized as well, otherwise they will do, and not do, anything they wish. including spewing methane and other chemicals into the communities it supposedly serves. But when I say this to my neighbors who work for corporations, I get the same response as I do from my cat. And you can understand this; after all, disaster is still thirty miles away.

    1. Here in California the new year is not so happy for the thousands of Porter Ranch refugees. Porter Ranch has grown since we bought a house there is 1985. Grown too big while destroying some beautiful hills and wildlife locations. An estimated 30,000 residents live(ed) there now. The governor finally declared a state of emergency.

      It has been suggested that instead of retaining his famous moniker “Governor Moonbeam” he should be renamed “Governor Gasbag” – as in the massive gas blowout in PR. It is not a leak, it is a blowout. In 1979 SoCal Gas Co. removed a shut off valve there, intending to replace it. It was never replaced despite numerous state inspections since. So that is part of the problem. Gasbag’s sister sits on the board of SoCal Gas Company’s parent company Sempra. She is paid a cool $188,000 annually for basically a small part time job. It is not what you know, it is who you know – in politics, the corporate world and the entertainment industry.

      Governor Gasbag just announced additional taxes on the already high gasoline prices here – the highest in the country. So Governor Gasbag has a dual ring to it.

      I am suffering the consequence from house sitting for two weeks in Porter Ranch during the recent holidays. I was just one mile directly south of the blowout location. One of the many ailments that people who’ve fled complain about is skin rashes. I came down with a serious one and is now under a dermatologist’s care. The skin is peeling off on hands and arms, very painful.

      The blowout has health consequences for all of Los Angeles, Ventura and Kern counties, never mind what the gas company’s mouthpieces say. It is spreading for miles and miles around. I live eight miles as the crow flies directly north of the gas blowout – on the other side of Oat Mountain. There is a beautiful hiking trail that goes from Porter Ranch over this mountain to the north side where I live. Not too many people are aware of this trail, even fewer will be now, but mountain lions are fond of this area.

      1. Brown’s sister sits on the board of SothernCal Gas, Anne? That explains the delay in declaring an emergency. I wonder how this could be made generally known.


          “SAN FRANCISCO >> Gov. Jerry Brown’s sister is a paid board member of the company that owns a natural-gas well whose leak is forcing thousands from their Southern California homes, and a watchdog group and the governor’s aides disagree over whether that makes a conflict of interest for the governor.

          Brown’s sister, Kathleen L. Brown, a lawyer and a former California state treasurer in the 1990s, has served as a director of Sempra Energy since 2013, receiving $188,380 in salary last year. Federal filings show she also holds stock in the company currently worth about $400,000.”

          Southern California Gas Company is a subsidiary of San Diego-based Sempra Energy. Ms. Brown sits on the Sempra board.

        2. There are over 250 oil and gas wells in and around Porter Ranch according to State of California records. As the old oil wells drilled back in the thirties ran dry, the empty underground spaces were used to store gas which has been trucked in from all over. It is now the second largest gas storage facility in the country. The residents were never told about the magnitude of this facility right in their back yards. We knew that SoCal Gas had a place in those hills, but not to the extent that is now known – a ticking time bomb.

          The SoCal Gas mouth pieces keep saying there will be no long term health risks from the blowout. Sure. Talk to the people in Simi Valley who lives around the Santa Susana Field Lab some 10 miles directly west of Porter Ranch. People moved up that way to get away from the big city and no one really knew what was there in them beautiful thar hills – from Simi Valley to Porter Ranch.


        3. That is truly disgusting, both physically and philosophically.

          I can’t imagine what it is like to endure such a situation (I know you did, Anne, for a few days, but that was apparently before oil droplets and brine were misting up the place).

          Of course, I can’t imagine the people of California transforming their paradise into a hellhole voluntarily, but they did it. (I read everything Victor Davis Hanson writes about the pathologies he has to endure).

          Who would buy your house in Porter Ranch now, if you were fed up and just wanted to slip away from the dysfunctional state? Will the pathological legislature float another bond issue to buy out all those house owners ala Love Canal? How long would that take, if they did do that? How sick would everybody be my then?

          What a nightmare.

        4. Good lord, 250 wells! This is what happens, Anne, when the people no longer control, or even influence, the power system. The cops shoot Blacks, and give them tickets to fund the city, as in Ferguson, change the water system to put lead in the water, as in Flint, and place old gas depots underground that spew toxics in the air of the community, as in Porter Ranch and Simi Valley.

          And the American people are riven by their various hatreds of each other that prevents us from uniting to oppose anti-people power.

        5. “And the American people are riven by their various hatreds of each other that prevents us from uniting to oppose anti-people power.”

          What a recalcitrant hypocrite you are.

        6. I’ve passed along, Anne, your report about Brown’s sister sitting on the board of the parent company of SoCalGas on a few blogs. People understand financial corruption, being confronted with so much of it in the USA, so your comment may have some political effect.

        7. When the BP disaster happened in the Gulf of Mexico almost six years ago, predictions for the coastline were dire. Who would want to live there after that? Well, plenty do. Alabama has a sliver of gulf coast frontage that prior to the event had a feel of what Florida’s panhandle in the fifties and sixties looked like. I have seen photos of the panhandle from those days gone by, much more to my liking than present day’s high rises there.

          Today this sliver of Alabama’s gulf coast is bustling with brand new high rises and more on the way. And there is no shortage of tourists and new residents. So life goes on as it always has, maybe not so much for the sea creatures.

          As for the financial situation for homeowners in Porter Ranch, in addition to health issues, who wants to purchase a home there now? No one in their right mind, unless they want to grab some property for cheap and sit on in until all’s forgotten. Much like the 1994 earthquake in that area and people left swearing they would never return. Many old timers never returned, but new residents moved in. There will always be California dreamin’.

    2. Folk,
      That scares me. I thought you lived in Pennsylvania or somewhere back east?

      We should hook up and have some Tea and Cucumber Sandwiches. I’d love to talk to you face to face.

        1. We here in California may have to flee and seek refugee status somewhere in Europe. When all goes to hell in a hand basket here we can apply as economic refugees and become neighbors over there. Party all day long on government handouts. I suggest Iceland.

          With a California tan and a name change we may be accepted as true refugees. I see that thousands of stateless people are accepted into Europe. We could claim to be stateless – not a far stretch.

          Iceland here we come…..

        2. the nicest city in northern America, Anne, is Vancouver. A few years ago, pretty young girls could walk home in the dark after a concert with perfect security. Ad also hitchhike in secluded areas. One we picked up wanted to hitchhike down to Mexico, and we had to warn her that things were different in the USA.

          Lately there is a rumor that the heroin addict situation has changed things, but I haven’t been there myself. US power is the biggest trafficker in narcotics in the world.

        3. Folk, I have to agree with you. Nicest large city on the North American continent. Not that Canadians don’t complain about their own version of our complaints, but imho they are still better off (for now) than the neighbors south of the border and their contemporaries in Europe.

          An American movie was filmed in Vancouver and they needed a ghettoized area for some scenes. None could be found to fit the criteria so one had to be created from scratch with the film crew throwing trash around.

          I watched a movie the other night with the scripted town being Baltimore – a mystery in Baltimore. It did not take long to figure out that the movie location was something other than physical Baltimore. The city on the screen was way too clean and pleasant. Happened to be Montreal.

          Used to live in Canada – Toronto. Have had some regrets about leaving that country and suggested more than once to my daughter to get out of Los Angeles and move up north to Vancouver while she can. Europe is gone, sorry to say. The British Monarch, Queen Liz, reportedly told her staff last month to enjoy Christmas because it would be the last.

        4. Odd you should talk about movies in Vancouver; I used to play tennis with a director who made some of them there. Cheaper. Now he goes to Mexico. Really shlock films. I once suggested he redo The Seventh Seal in color, but he did not think it was funny.

        5. Ingmar Bergman’s movies depress me. Don’t think any of his black and white films in color would’ve made a difference.

        6. Anne, ran across this picture I thought you might like in some photos released by the NY Public Library, though it is a little Bergman-like.

          “Lapland children, possibly from Sweden, from a collection of photographs of immigrants by Augustus Sherman. Sherman worked at Ellis Island from 1892 to 1925.”

        7. Toni, thank you so much. What a treasure trove of photographs. More here – children and adults in their finest:

          “Augustus Francis Sherman was the chief registry clerk at Ellis Island, and an avid amateur photographer. He had special access to the immigrants who were temporarily detained while waiting on escorts, money or travel tickets. Sherman persuaded many of these immigrants to pose for his camera, encouraging them to put on their finest clothes or national dress.”

          This was a typical Lapland setting in 1900:

        8. Anne, I grew up in California. I fled over twenty years ago. I have absolutely NO regrets. It used to be a nice place to live. Not anymore. Frankly, I’m hard pressed to find anything nice to say about it.

          I have two daughters that still live there. I keep trying to get them to move. I frankly don’t see the attraction. There is simply far too much of everything negative.

          Prior to Ronnie Ray-Gun it was a good place to live. I pity anyone who lives there now. Between the high costs, exorbitant fees, taxes and regulations galore, the jobs are leaving and the “Mexification” is causing it to look like a suburb of Tijuana.

          What you are seeing is what happens when unrestricted corporate greed becomes public policy. If you have the chance, get out while you can.

        9. I would love to hear Folk tell me to my face why I’m the Poster Child of whats wrong with America as he did in his rant a few months ago.

          Pat, If I had the bank, I’d fly you out here in a heart beat ..haha

        10. I never said that, Ric. Patrick is such a poster child, however. And tea and cucumber sandwiches? I didn’t know you were an Oscar Wilde fan. Perhaps a few trips around the big hall on your parent’s Merry-go-round.

        11. I’m betting you are a very gracious person, in person, Mark, and that you only expose your vicious, true, nature, here, in disguise.

          So, were we to have a proper English tea together, you would not betray who you really are. Of course, knowing you as I do, I’d have to have someone watching my back.

        12. Hey, folktruther

          How come you won’t respond when you’re confronted directly?

          Patrick’s right about your trustworthiness. It’s like you slink around avoiding eye contact, and waiting to spring your ugly remarks.

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