October 6, 2021

U.S. Fish and Wildlife Service MS: PRB/3W 5275 Leesburg Pike Falls Church, VA 22041-3803

Attention: Louise Clemency, Chicago Ecological Services Field Office

Re: American Bumble Bee Docket No. FWS–R3–ES–2021–0063

THREAT TO THE AMERICAN BUMBLE BEE FROM RF RADIATION

In response to a petition from the Center for Biological Diversity, the Fish and Wildlife Service published a Notification of Status Review on September 29, 2021 in the Federal Register. The Service proposes to list the American bumble bee as a threatened or endangered species and requests comments and new information concerning threats to the existence of that species. In its Notification, FWS lists four threats that to the American bumble bee that it has identified: habitat destruction, loss of genetic diversity, climate change, and competition from nonnative honeybees.

I submit the following information regarding a fifth threat to this species: radio frequency (RF) radiation. RF radiation is a threat to both honeybees and bumble bees and is a greater and more urgent threat to the American bumble bee than any of four threats the Service has listed. This pollutant has been responsible for reducing both domestic and wild bee populations for more than a century. This threat to bees has intensified since the beginning of the wireless revolution in 1996, with the construction of hundreds of thousands of cell towers and antennas in all areas of the United States including farmland, forest land, parkland, and nature preserves. It has become an emergency in the past two years with the national rollout of 5G technology, which is multiplying the density of antennas tenfold and more, as well as increasing the frequency, bandwidth, and effective radiated power from each antenna. Cell towers are already exposing the entire world to levels of RF radiation that are up to ten million times stronger than the natural radiation that comes from the sun and stars.

Mechanisms of Action

RF radiation is a form of electromagnetic energy that is used for communication. It is emitted by radio and TV towers, radar stations, cell towers, cell phones, and all of the other wireless devices that are proliferating in today’s world. It interferes with navigation, communication and metabolism in bees. It is the effect on metabolism that is killing bees the quickest and driving them to extinction.

Metabolism

Electronic devices and systems manufactured today must be hardened against electromagnetic interference (EMI) from RF radiation coming from so many sources today. A living organism is also electronic in nature and is also subject to EMI. However, life evolved in the virtual absence of RF radiation and is not hardened against it. This radiation affects biology in many ways, but most critical for bees is the interference with electron transport in the mitochondria of cells. The electron transport chain is which is where the last, energy-producing step in metabolism takes place. It is where electrons generated by the metabolism of the sugars, fats and proteins we eat are transferred to the oxygen we breathe, resulting in the generation of ATP. Interference with metabolism affects bees more than other creatures because bees have such a high metabolic rate. It deprives them of energy by starving them of oxygen.

That this actually happens was proved in 2011. N. Kumar, S. Sangwan and P. Badotra, “Exposure to Cell Phone Radiations Produces Biochemical Changes in Worker Honey Bees.” Toxicology International 181(a):70-72 (2011). These researchers exposed bees to an ordinary cell phone and sampled their hemolymph. After 10 minutes of exposure to a cell phone, the concentration of total carbohydrates in their hemolymph increased from 1.29 to 1.5 mg/ml. After 20 minutes it increased to 1.73 mg/ml. The glucose content rose from 0.218 to 0.231 to 0.277 mg/ml. Total lipids rose from 2.06 to 3.03 to 4.50 mg/ml. Cholesterol rose from 0.230 to 1.381 to 2.565 mg/ml. Total protein rose from 0.475 to 0.525 to 0.825 mg/ml. In other words, after just ten minutes of exposure to a cell phone, metabolism of sugars, fats and proteins was severely inhibited.

If bees cannot metabolize their food they cannot fly and they will crawl on the ground and die.

Science

The quickest way to destroy a bee hive, scientists have found, is to place a wireless telephone inside it.

In 2009, VP Sharma and N Kumar placed two cell phones each—one in talk mode and one in listening mode in order to maintain the connection—in two of four hives. They turned them on at 11:00 in the morning for 15 minutes, and again at 3:00 in the afternoon for 15 minutes. They did this twice a week between February and April. As soon as the phones were turned on the bees would become quiet and still. During the course of three months fewer and fewer bees flew in and out of those two hives. The number of eggs laid by the queen declined from 546 to 145 per day. The area under brood declined from 2,866 to 760 square centimeters. Honey stores declined from 3,200 to 400 square centimeters. “At the end of the experiment there was neither honey, nor pollen nor brood nor bees in the colony resulting in complete loss of the colony,” wrote the authors.

The following year Kumar performed the experiment described above in which she demonstrated that electromagnetic fields from a cell phone interfere with cellular metabolism in bees and cause them to become oxygen starved.

Daniel Favre, at the Apiary School of the City of Lausanne, Switzerland, observed that bees exposed to a cell phone would become quiet and still at first, but within 30 minutes they would starts to produce loud, high frequency sounds like worker piping, which is usually produced by bees when they are preparing to swarm.

Sainudeen Pattazhy, a professor at Sree Narayana College, placed one cell phone inside each of six bee hives and turned the phone on for just ten minutes, once a day for ten days. While the phone was on, the bees became still. The egg-laying rate of the

PLANETARY EMERGENCY

The Earth needs your help. Now.

Many are the assaults on our planet. The oceans—Jacques Cousteau said it already in 1970—are dying. The majestic wilderness is no more. The very oxygen we breathe is being converted to carbon dioxide.

Others are wrestling with those problems, and they are not going to be solved overnight. But there is one that must be: we must leave space alone.

On March 29, 2018, the Federal Communications Commission gave its approval to SpaceX’s plan to launch an unprecedented 4,425 satellites into low orbit around the Earth. And that’s only the beginning. SpaceX has applied to the FCC to increase the number of satellites to 42,000 in order to provide “ultrafast, lag-free Internet” to every square inch of the earth. 5G from space. The name of SpaceX’s project is “Starlink.” As of May 2022, Starlink already has about 2,500 operating satellites in low-earth orbit.

The global electrical circuit, which sustains all life, is about to be seriously disturbed unless we act.

Recent History

In 1997, in my first book, Microwaving Our Planet, in the last chapter, titled “The Danger from Satellites,” I wrote: “The proliferation of satellites we are about to witness—unless this world wakes up soon—is mind boggling, and nobody seems to have considered that popping thousands of them up there like so much confetti might have consequences for our atmosphere and our climate.” I wrote about the expected ozone loss; the destruction of the Van Allen belts; global warming from the addition of water vapor to the stratosphere; toxic wastes; groundwater pollution; space junk; microwave radiation; and the vandalism of the night sky. My 1997 book is posted here, courtesy of the Spanish website AVAATE, one of the best websites on this issue: www.avaate.org/IMG/doc/Microwaving_Our_Planet_firstenberg.doc

A year later the radiation problem asserted itself. On September 23, 1998, the world’s first satellite phones became operational. Service was provided by 66 satellites in low orbit around the Earth, launched by the Iridium Corporation. They unleashed a new kind of rain that turned the sky red and emptied it of birds for a couple of weeks.

A six-nation telephone survey was done of electrically sensitive people, support groups, and nurses and physicians serving this population. The results: 86% of electrically sensitive people and a majority of patients and support group members became ill on Wednesday, September 23 exactly, with typical symptoms of electrical illness including headaches, dizziness, nausea, insomnia, nosebleeds, heart palpitations, asthma attacks, ringing in the ears, etc. Follow-ups revealed that some of these people were acutely ill for up to three weeks. Some were so sick they weren’t sure they would live. In the United States the national death rate rose by 4% to 5% for two weeks. During those two weeks, very few birds were seen in the sky and thousands of homing pigeons failed to return home in pigeon races throughout much of the country. This was all documented in No Place to Hide, Vol. 2, No. 1, Feb. 1999, pp. 3-4.

The second satellite service, Globalstar, began commercial service on Monday, February 28, 2000. Widespread reports of nausea, headaches, leg pain, respiratory problems, depression, and lack of energy began on Friday, February 25, the previous business day, and came from people both with and without electrical sensitivity. See No Place To Hide, Vol. 2, No. 3, March 2000, p. 18.

Iridium, which had gone bankrupt in the summer of 1999, was resurrected by a contract with the United States Armed Forces. On March 30, 2001, commercial service resumed. Again the sky turned red. Again came reports of nausea, flu-like illness and feelings of oppression. But the events that made the news were catastrophic losses of race horse foals that were reported throughout the United States and as far away as Peru. On June 5, 2001, Iridium added data and Internet to its satellite phone service. Again came widespread reports of nausea, flu-like illness and oppression, and this time also hoarseness. See No Place To Hide, Vol 3, No. 2, Nov. 2001, p. 15.

Additional details are provided in chapter 17 of my new book, The Invisible Rainbow: A History of Electricity and Life (AGB Press, 2017).

Between 2001 and 2019, our skies did not essentially change. Iridium and Globalstar, operating 66 and 40 satellites respectively, were still the only providers of satellite phones. The amount of data raining on us all from space was still dominated by those two fleets. The predicted fleets of thousands of satellites had not materialized. But they are doing so now. Everything we know and love is at stake—not just hawks and geese, pigeons and race horses, not just the human race, but life itself. This is a mortal threat not just to our children and grandchildren, but to all of us.

The Details

The biggest planned fleet of satellites is the Starlink constellation being launched by Elon Musk’s company, SpaceX. But there are about 150 other companies competing with Starlink, several of which are already launching satellites. The number of satellites proposed to be operated by all of these companies totals, incredibly, more than 442,000. Almost all are proposed to be orbited at altitudes ranging from 210 to 700 miles in altitude. They will all operate at millimeter wave frequencies and they will all be phased arrays. Each satellite will have thousands of antenna elements that will aim focused, steerable beams at any desired point on the surface of the earth. The effective radiated power of each beam from each of the satellites can range up to 5,000,000 watts, depending on its altitude and how many simultaneous customers it is serving. The satellites will communicate both with individual users and with gateway earth stations, of which there will be several hundred just in the United States for just the Starlink constellation.

One of the other companies planning a megaconstellation is the UK’s OneWeb. Its founder and Executive Chairman is Greg Wyler. To build and launch its constellation of 7,088

1993: Environmental Protection Agency (EPA): The FCC’s exposure standards are “seriously flawed.” Official comments to the FCC on guidelines for evaluation of electromagnetic effects of radio frequency radiation, FCC Docket ET 93-62, November 9, 1993.

1993: Food and Drug Administration (FDA): “FCC rules do not address the issue of long-term, chronic exposure to RF fields.” Comments of the FDA to the FCC, November 10, 1993.

1993: National Institute for Occupational Safety and Health (NIOSH): The FCC’s standard is inadequate because it “is based on only one dominant mechanism—adverse health effects caused by body heating.” Comments of NIOSH to the FCC, January 11, 1994.

1994: Amateur Radio Relay League Bio-Effects Committee: “The FCC’s standard does not protect against non-thermal effects.” Comments of the ARRL Bio-Effects Committee to the FCC, January 7, 1994.

2000: UK Department of Education: Children under 16 should not use cell phones except in an emergency.

2002: Interdisciplinary Society for Environmental Medicine (3000 physicians in Germany) recommends banning cell phone use by children and banning cell phones and cordless phones in preschools, schools, hospitals, nursing homes, events halls, public buildings and vehicles. http://cellphonetaskforce.org/wp-content/uploads/2021/07/Freiburger-Appeal-English.pdf

2003: American Bird Conservancy and Forest Conservation Council: Brought a lawsuit against the FCC because millions of migratory birds were being disoriented by microwave radiation and crashing into cell towers.

2004: International Association of Fire Fighters opposes communication antennas on fire stations. https://mdsafetech.files.wordpress.com/2019/09/iaff-cell-tower-resolution-health-and-safety-fact-sheets-copy.pdf

2005: Salzburg, Austria’s Public Health Department bans WLAN and DECT phones in public schools.

August 2005: Austrian Medical Association: Warns against Wi-Fi, cordless phones, and cell phone use by children.

August 2005: Vienna Medical Association warns against Wi-Fi, and cell phone use by children up to age 16.

2006: Frankfurt, Germany’s government states it will not install WiFi in its schools until it has been shown to be harmless. https://www.icems.eu/docs/deutscher_bundestag.pdf

2006: UK schools remove their wireless networks: Prebandal Preparatory School, Chichester, West Sussex; Ysgol Pantycelyn School in Carmarthenshirem, Wales; and Stowe School, in Buckinghamshire, England. London Times, November 20, 2006.

2007: Ballinderry Primary School, Ireland: Removed Wi-Fi to protect young children.

2007 Bavaria, Germany’s Parliament recommends against Wi-Fi in schools. https://www.icems.eu/docs/deutscher_bundestag.pdf

2007 Australian Democrats: The “explosion in wireless communications technology” is causing widespread illness.

2007: European Environmental Agency, Europe’s top environmental watchdog, calls for immediate action to reduce exposure to radiation from Wi-Fi, mobile phones and their masts. https://www.nzherald.co.nz/world/news/article.cfm?c_id=2&objectid=10463870

2008: International Commission on Electromagnetic Safety (comprised of scientists from 16 nations): Recommends limiting cell phone use by children, teenagers, pregnant women and the elderly. https://www.magdahavas.com/wp-content/uploads/2011/06/Venice_Resolution-2008.pdf

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2007: Therold, Ontario closes down its citywide Wi-Fi pilot scheme.

2008: Lakehead University, Ontario bans Wi-Fi on campus. https://www.cbc.ca/news/canada/toronto/story/2010/08/15/ontario-wifi.html

2008: Madhya Pradesh, India: Bans cell phones in schools by both students and teachers.

2008: National Library of France: Removes Wi-Fi because of health concerns and limits installation to cable connections. http://cellphonetaskforce.org/wp-content/uploads/2022/05/France-National-Library-Gives-Up-Wifi.pdf

2008: Paris, France removes Wi-Fi from four public libraries because of health concerns. https://www.odwyerpr.com/story/public/6385/2016-02-23/french-national-library-banned-wi-fi-2008.html

2008 Sainte-Geneviève University, Paris: Removes Wi-Fi from its library because of health concerns.

2008: Progressive Librarians Guild recommends against wireless technology in libraries.

2008: Russian National Committee for Non-Ionizing Radiation Protection warns that cell phones are unsafe even for short conversations. Children under 16, pregnant women, epileptics, and people with memory loss, sleep disorders and neurological diseases should never use cell phones. https://www.radiationresearch.org/wp-content/uploads/2018/06/021235_grigoriev.pdf

2008 Sebastopol, California: Reneges on its contract to install citywide Wi-Fi. https://www.boingboing.net/2008/03/24/town-of-sebastopol-c.html

2008: University of Pittsburgh Cancer Institute: Children should never use a cell phone except in an emergency. https://www.post-gazette.com/pg/08205/898803-114.stm

2008: Voice (UK Teachers Union) calls for a ban on Wi-Fi in schools.

2009: Hérouville Saint-Clair, France: Bans Wi-Fi in public schools.

2009: Irish Doctors Environmental Association: Warns that current safety guidelines are “not appropriate.”

2009: Karnataka State, India: Bans cell phones in all schools and pre-university colleges.

May 2009: U.S. Fish and Wildlife Service urges Congress to focus on the potential connection between electromagnetic fields and “Bee Colony Collapse”. https://electromagnetichealth.org/electromagnetic-health-blog/emf-and-warnke-report-on-bees-birds-and-mankind/

December, 2010: French Parliament passes a law prohibiting advertising cell phones to children under 14; prohibits children up to age 14 from using cell phones in pre-schools and public schools; requires cell phones to be labeled with SAR values and a recommendation to use headsets. https://www.legifrance.gouv.fr/affichTexteArticle.do;jsessionid=1E9805FB777CC9228F41FE523855508D.tpdjo14v_1?idArticle=JORFARTI000022471515&cidTexte=JORFTEXT000022470434&dateTexte=29990101&categorieLien=id

May 27, 2011: Council of Europe passes a resolution recommending wired Internet connections in schools, and the creation of radiation-free zones to protect electrosensitive people. https://assembly.coe.int/Documents/AdoptedText/ta11/eRES1815.htm. http://cellphonetaskforce.org/wp-content/uploads/2012/01/eres1815.pdf

August 30, 2011: The Israeli Ministry of Education publishes guidelines strictly limiting the use of mobile phones on all school grounds, citing children’s and youths’ increased risk of malignant tumors and the “passive exposure” experienced by children who do not use phones. https://norad4u.blogspot.com/2011/09/israeli-ministry-of-education-is-going.html

September 8, 2011: Pretty River Academy in Collingwood, Ontario removes WiFi from campus as a precaution, joining Roots and Wings Montessori school in Surrey, British Columbia.

Feb 13, 2012: Citing safety concerns, the Ontario English Catholic Teacher’s Association representing 45,000 teachers, is calling for a ban on new Wi-Fi installations in the province’s 1,400-plus Catholic schools and advocating that computers in all new schools should be hardwired as well. https://www.cbc.ca/news/canada/toronto/story/2012/02/13/toronto-oecta-wifi.html

March, 2012: the Austrian Medical Association (ÖAK) releases guidelines for the diagnosis and treatment of health problems caused by exposure to electromagnetic fields. https://magdahavas.com/electrosmog-exposure/austrian-medical-association-guidelines-to-diagnosing-and-treating-patients-with-electrohypersensitivity/

June 19, 2012: The Russian National Committee on Non-Ionizing Radiation Protection has officially recommended that WiFi not be used in schools. https://youtu.be/5CemiJ-yIA4.

25 Aug 2012: Israeli Minister of Health Rabi Yaakov Litzman states that he supports calls to action for a ban on Wi-Fi in schools. https://www.mast-victims.org/index.php?content=news&action=view&type=newsitem&id=5723

5 July 2013: Supreme Court of India upholds a decision of the High Court of the State of Rajasthan to remove all cell towers from the vicinity of schools, colleges, hospitals and playgrounds because of radiation “hazardous to life.” The over 200-page November 27, 2012 Rajasthan decision reviews worldwide evidence