Monday, August 29, 2016

FCC needs input regarding allocation of spectrum for 5G

The FCC needs your input regarding allocation of spectrum for 5G. The deadline is September 30, 2016.

Submit your comments regarding allocation of additional frequencies within the 5G spectrum that the FCC is going to vote on including 24-70 GHz as well as higher spectrum: 71-76 GHz, 81-86 GHz and 95 GHz.

For more information about these proceedings: http://bit.ly/FCC16-89A1.

If you follow the instructions below, you can comment on five different dockets at once. You may want to comment specifically on the ways they want to use 5G technology such as: "machine-to-machine communications, healthcare devices, autonomous driving cars, and home and office automation."

Follow These Instructions to Make Comments:
1. Click on this link   http://fjallfoss.fcc.gov/ecfs2/.
2. Click on "Submit a Filing" Tab at the top of the page.
3. Click on "Express a Comment" (on top of the page) to just make a comment or "Standard Filing" to attach documents (one of which can be your comment).
4. You can make one comment for all five docket numbers at once. Simply type in or Copy and Paste each of these Docket numbers one at a time into the "Proceedings" Field and make sure they are accurately displayed in the window:
14-177
15-256
RM-11664
10-112
97-95 
5. Fill out all required fields and click "Enter" or "Return" before you go to the next field. There is a check box to request an email confirmation.
6. Once all fields are filled out - click continue screen.
7. Review and submit.
8. Write down your confirmation # so you can check on your submission.
--

I submitted the following express comment today:


In light of your upcoming votes on allocation of additional spectrum for 5G, I want to draw your attention to the International EMF Scientist Appeal (https://EMFscientist.org) which calls for stronger regulatory standards on radio frequency (RF) emissions.

The Appeal has been signed by 221 scientists from 41 nations. All of these scientists have published peer-reviewed research on electromagnetic fields and biology or health.

The FCC's RF guidelines were adopted 20 years ago. Many scientists and health professionals believe these guidelines do not protect the population from non-thermal health risks due to RF radiation exposure. To ensure public health and safety, the FCC should commission an independent review of the biologic and health research to determine stringent RF standards before allowing additional spectrum to be used for new commercial applications.

I also wish to remind you that the FCC has yet to act on NOI #13-84, "Reassessment of Federal Communications Commission Radiofrequency Exposure Limits and Policies," issued in 2013 and a similar NOI issued a decade earlier. The 2013 NOI has received more than 900 submissions--almost all call for stronger regulation of RF radiation. Links to key submissions can be found on the Electromagnetic Radiation Safety website at http://www.saferemr.com/2014/08/part-i-why-we-need-stronger-cell-phone.html.

Finally, the General Accountability Office issued a report entitled, “Exposure and Testing Requirements for Mobile Phones Should Be Reassessed” (GAO-12-771: Published: Jul 24, 2012. http://www.gao.gov/products/GAO-12-771). The report made the following recommendations which have yet to be addressed by the FCC:

“FCC should formally reassess and, if appropriate, change its current RF energy exposure limit and mobile phone testing requirements related to likely usage configurations, particularly when phones are held against the body. FCC noted that a draft document currently under consideration by FCC has the potential to address GAO’s recommendations.”

Thursday, August 25, 2016

iPhone 6 radiation levels: Most popular post on Electromagnetic Radiation Safety

The most popular post on the Electromagnetic Radiation Safety website addresses the radiation levels or Specific Absorption Rate (SAR) and minimum separation distance for Apple's iPhone 6 models. This post from last September has had more than 100,000 page views.

Apple is selling about 40 million iPhones per quarter and will soon pass the billion sales mark for all models. Apparently, many iPhone users and potential consumers are interested in learning about the cellphone radiation emitted by this phone and the potential effects on their health.

Saferemr.com has reached the 600,000 page view mark today.

More than 200 countries are represented among those who visited the website. Residents of 29 nations had a thousand sessions or more. U.S. residents accounted for almost half of the sessions. Residents of Canada, India, United Kingdom, Australia, Israel, Greece, Russia, Spain, and Italy accounted for the next fourth.

See the links below for the ten most popular posts to date.

Sep 29, 2015
Mar 4, 2013
Jun 24, 2016
Oct 5, 2015
Aug 3, 2016
Aug 11, 2016
Nov 3, 2013
May 12, 2016
Apr 18, 2016
May 4, 2016

Friday, August 12, 2016

Secondhand Exposure to Cell Phone Radiation: An Emerging Public Health Problem?

Radiofrequency radiation at Stockholm Central Railway Station in Sweden and some medical aspects on public exposure to RF fields

Lennart Hardell, Tarmo Koppel, Michael Carlberg, Mikko Ahonen, Lena Hedendahl. Radiofrequency radiation at Stockholm Central Railway Station in Sweden and some medical aspects on public exposure to RF fields. International Journal of Oncology. Published online August 12, 2016.

Abstract

The Stockholm Central Railway Station in Sweden was investigated for public radiofrequency (RF) radiation exposure. The exposimeter EME Spy 200 was used to collect the RF exposure data across the railway station. The exposimeter covers 20 different radiofrequency bands from 88 to 5,850 MHz. In total 1,669 data points were recorded. The median value for total exposure was 921 µW/m2 (or 0.092 µW/cm2; 1 µW/m2=0.0001 µW/cm2) with some outliers over 95,544 µW/m2 (6 V/m, upper detection limit). The mean total RF radiation level varied between 2,817 to 4,891 µW/m2 for each walking round. High mean measurements were obtained for GSM + UMTS 900 downlink varying between 1,165 and 2,075 µW/m2. High levels were also obtained for UMTS 2100 downlink; 442 to 1,632 µW/m2. Also LTE 800 downlink, GSM 1800 downlink, and LTE 2600 downlink were in the higher range of measurements. Hot spots were identified, for example close to a wall mounted base station yielding over 95,544 µW/m2 and thus exceeding the exposimeter's detection limit. Almost all of the total measured levels were above the precautionary target level of 3-6 µW/m2 as proposed by the BioInitiative Working Group in 2012. That target level was one-tenth of the scientific benchmark providing a safety margin either for children, or chronic exposure conditions. We compare the levels of RF radiation exposures identified in the present study to published scientific results reporting adverse biological effects and health harm at levels equivalent to, or below those measured in this Stockholm Central Railway Station project. It should be noted that these RF radiation levels give transient exposure, since people are generally passing through the areas tested, except for subsets of people who are there for hours each day of work.

Excerpts

The mean measurements in the Stockholm Central Station showed a total RF radiation between 2,817 to 4,891 μW/m2. Studies with laboratory animals exposed to RF radiation at or below these levels have shown influence on several physiological parameters in the body of mammals. Influence on the blood-brain barrier, proteins and microRNA in the brain, testicular function, oxidative stress in the cells and DNA damage have been shown. Also neurotransmitters in people living in a village were changed after activation of a GSM mobile phone base station. These are non-thermal effects and are discussed briefly …

Due to the rapid development of the telecommunications technology and the evolution of the wireless infrastructure, it is imperative to measure public's exposure. Yearly monitoring measurements would allow an overview of the public's exposure budget, since nowadays, rapid deployment of new RF radiation sources take place. The information obtained by the exposure studies allows assessing public's exposure to RF radiation today and in the years to come, when future epidemiologic studies seek for information in assessing the historic exposure levels to which the public was commonly exposed. Unfortunately studies on human risk from long-term environmental RF radiation based on personal exposure monitoring do not exist to our knowledge. Given the lack of good historic RF radiation exposure information to date, it is imperative that better efforts be directed to periodic collection of RF radiation exposures in daily life for use in epidemiological studies of cancer as well as of neurological diseases and other adverse health effects attributed to RF radiation exposures.

Open access paper: https://www.spandidos-publications.com/10.3892/ijo.2016.3657

--

Assessment of contribution of other users to own total whole-body RF absorption in train environment

Plets D, Joseph W, Aerts S, Vermeeren G, Varsier N, Wiart J, Martens L. Assessment of contribution of other users to own total whole-body RF absorption in train environment. Bioelectromagnetics. 2015 Oct 29. doi: 10.1002/bem.21938. [Epub ahead of print]

Abstract


For the first time, the contribution of radio-frequent radiation originating from other people's devices to total own whole-body absorption is assessed in a simulation study.

Absorption in a train environment due to base station's downlink is compared with absorption due to uplink (UL) of the user's own mobile device and absorption due to the UL of 0, 1, 5, or 15 other nearby active users.

In a Global System for Mobile Communications (GSM) macro cell connection scenario, UL of 15 other users can cause up to 19% of total absorption when calling yourself and up to 100% when not calling yourself. In a Universal Mobile Telecommunications System (UMTS) femtocell connection scenario, UL of 15 other users contributes to total absorption of a non-calling user for no more than 1.5%. For five other users in the train besides the considered person, median total whole-body Specific Absorption Rate is reduced by a factor of about 400,000 when deploying a UMTS femtocell base station instead of relying on the GSM macrocell.


http://1.usa.gov/1jXzFRZ


Excerpts

Two train scenarios were investigated, for which a 20 m × 2.83 m train wagon (type M6, lower floor of double-decker, built by Bombardier (Montreal, Canada) and Alstom (Levallois-Perret, France)) with 66 passenger seats were considered (Fig. 1). The first scenario was a reference scenario, where people in the train made a phone call and connected to a GSM macro cell base station at 900 MHz (GSM900), a typical current deployment. The second scenario considered a future deployment, in which people on the train made a phone call and connected to an in-train UMTS FBS.

It can be concluded that for current deployments, contributions of other in-train users is sometimes not negligible: 15 other users connected to a GSM 900 macro cell base station can induce absorption rates up to 24% of that induced by user's own device. This corresponds for the scenario to a contribution of 19% to total absorption rate when calling yourself and a contribution of 100% when not calling yourself. A UMTS femtocell deployment in this environment drastically reduces total absorption (when calling, at least by a factor 39097) and makes the other users' contributions to total absorption negligible (at most 1.5% of the total absorption when not calling yourself). Future research will consist of considering influence of antenna orientation of mobile device and of assessment of 4G and 5G scenarios. In-train Long-Term Evolution (LTE) femtocell BS will provide a user with high data rate traffic, while keeping exposure low, thanks to power control mechanisms.


--

October 29, 2012

Secondhand Exposure to Cell Phone Radiation: An Emerging Public Health Problem?

Exposure to other people's cell phone radiation on buses and trains can be considerable according to a newly published study.

Joel M. Moskowitz, PhD, Press Release, Oct. 29, 2012 - PRLog 

Many people are unaware that they are exposed to cell phone radiation when their cell phones are in standby mode.  This occurs because their cell phone contacts the nearest cell tower periodically to update its location.

In a moving vehicle, cell phones in standby mode contact cell towers more frequently. Thus, exposure to cell phone radiation from one's cell phone is greater in transit.

The Israeli Environmental Protection Ministry found that "when one fourth of the passengers in one train car or bus use their cell phones, all the passengers are exposed to a level of radiation higher than the allowable 0.8 watts per kilogram" (0).  Thus, everyone's exposure exceeds the legal safety limit.

Two Swiss researchers, Damiano Urbinello and Martin Roosli, set out to measure personal cell phone radiation exposure during car, bus and train trips when one's own phone was in standby mode. 

Their study just published in the Journal of Exposure Science and Environmental Epidemiologyidentified a source of cell phone radiation that may constitute a public health problem. Namely, secondhand exposure to cell phone radiation from other people's cell phones can be considerable while traveling on buses and trains (1).

During bus or train trips, individuals may be exposed to considerable amounts of cell phone radiation from other people's cell phones. Buses and railroad cars act like "Faraday cages" that reflect much of the electromagnetic radiation emitted by cell phones throughout the vehicles' interiors. Thus, all passengers, including infants and pregnant women as well as those without cell phones, may be exposed to considerable levels of cell phone radiation emitted by others' phones.

As for car trips, the results of the study suggest that exposure to cell phone radiation from one's own phone in standby mode is relatively low compared to overall exposures during public transit. Nonetheless, those who are concerned about their exposure to cell phone radiation should turn off their phones during car trips, or at the very least, avoid using their phones for calls.

● "The study indicates that own uplink exposure during car driving can be considerably reduced (about a fraction of 100) when turning off ones own mobile phone in order to prevent it from location updates."  (1)

The researchers found that GSM, the 2G carrier system in Europe which is used in the U.S. for voice communication by AT&T and T-Mobile, is particularly problematic compared to UMTS, a 3G carrier system used for data transmission. The researchers did not test CDMA which in the U.S. is used by Verizon and Sprint for voice calls. Other research has found that GSM emits 13 to 28 times more radiation on average than CDMA during phone calls. No published studies have examined exposures from LTE, the 4G carrier system now in widespread use in this country.

● "GSM levels in the reference scenario during bus and train rides were about 100 times higher than those during car rides. As a consequence of this high background exposure in trains, due to the use of other people's mobile phone in a closed area intensified by the Faraday cage effect, the relative contribution of the location update from ones own mobile phone is small"  (1)

The study also reported that smart phones, including the iPhone 4 and the Blackberry Bold 8800, which can operate on four radiofrequency bands emit more radiation during standby mode than classic phones, like the Nokia 2600, which operate on two bands. 

Earlier this year, a study was published that examined cell phones in standby mode while stationary. Kjell Mild and his colleagues from Sweden found that under these conditions cell phones contacted the cell towers only once every two to five hours. They concluded that exposure to cell phone radiation in this situation "can be considered negligible."  (2)

These studies should be replicated in the U.S. as well as in other countries since every cell phone carrier system operates differently. 

In the meantime it is advisable to keep cell phone use in moving vehicles to a minimum as low level exposures to cell phone radiation have been associated with deleterious effects in humans.

To protect us from the health risks associated with cell phones and related devices (e.g., cordless phones, Wi-Fi, wireless Smart Meters and security systems, and cell towers), we need research independent of industry to develop biologically-based standards and safer technologies.  A nickel a month from each cell phone subscription would suffice to fund a comprehensive program of research. Since the average cell phone subscription costs more than $47.00 per month, this tiny fee constitutes a prudent investment in our health and our children's health.

References

0) Minat, Z. Ministries look at cell phone-free zones on public transit. Haaretz. Apr 10, 2012.

1) Urbinello D, Roosli M. Impact of one's own mobile phone in stand-by mode on personal radiofrequency electromagnetic field exposure. Journal of Exposure Science and Environmental Epidemiology advance online publication, Oct 24, 2012.

Abstract

When moving around, mobile phones in stand-by mode periodically send data about their positions. The aim of this paper is to evaluate how personal radiofrequency electromagnetic field (RF-EMF) measurements are affected by such location updates. Exposure from a mobile phone handset (uplink) was measured during commuting by using a randomized cross-over study with three different scenarios: disabled mobile phone (reference), an activated dual-band phone and a quad-band phone. In the reference scenario, uplink exposure was highest during train rides (1.19 mW/m(2)) and lowest during car rides in rural areas (0.001 mW/m(2)). In public transports, the impact of one's own mobile phone on personal RF-EMF measurements was not observable because of high background uplink radiation from other people's mobile phone. In a car, uplink exposure with an activated phone was orders of magnitude higher compared with the reference scenario. This study demonstrates that personal RF-EMF exposure is affected by one's own mobile phone in stand-by mode because of its regular location update. Further dosimetric studies should quantify the contribution of location updates to the total RF-EMF exposure in order to clarify whether the duration of mobile phone use, the most common exposure surrogate in the epidemiological RF-EMF research, is actually an adequate exposure proxy. 

http://www.ncbi.nlm.nih.gov/pubmed?term=23093102

2) Mild KH, Andersen JB, Pedersen GF. Is there any exposure from a mobile phone in stand-by mode?Electromagnetic Biology and Medicine. 2012 Mar;31(1):52-6.

Abstract

Several studies have been using a GSM mobile phone in stand-by mode as the source for exposure, and they claimed that this caused effects on for instance sleep and testicular function. In stand-by mode the phone is only active in periodic location updates, and this occurs with a frequency set by the net operator. Typical updates occur with 2-5 h in between, and between these updates the phone is to be considered as a passive radio receiver with no microwave emission. Thus, the exposure in stand-by mode can be considered negligible.

http://informahealthcare.com/doi/abs/10.3109/15368378.201...

Wednesday, August 3, 2016

Part I: Why We Need Stronger Cell Phone Radiation Regulations--Key Testimony Submitted to the FCC

Selected FCC Submissions re: 

"Reassessment of Federal Communications Commission Radiofrequency 

Exposure Limits and Policies" (Proceeding Number 13-84)


Part I: Key Testimony Submitted to the FCC


Last revision: Aug 3, 2016
The FCC received more than 900 submissions regarding its cell phone radiation regulations. These documents reveal what we know about wireless radiation health effects, and why we need to strengthen regulations and provide precautionary warnings to the public.
In response to the Federal Communications Commission's (FCC) request for input regarding its radiofrequency radiation regulations adopted in 1996, individuals and organizations submitted thousands of documents, testimonials, research papers and scientific publications that are now available to the public. 
These documents reveal what we know about wireless radiation health effects, and why we need to strengthen regulations and provide precautionary warnings to consumers.

Although fifteen countries have issued precautionary health warnings about cell phone radiation and recommendations about how to reduce risks, the wireless industry in the U.S. has opposed precautionary warnings and wants to weaken cell phone radiation standards.
In all, the FCC received 928 submissions between June 25, 2012 and August 3, 2016. Many submissions include multiple documents. To view or download the submissions go to Proceeding Number 13-84 on the FCC web site.
The FCC's obsolete RF exposure limits are twenty years old. The current request for public input is four years old. The FCC is not likely to act on the current submissions until it addresses a similar request issued in 2003.
Obviously, updating RF regulations and testing procedures is not a priority for the FCC even though the U.S. General Accountability Office recommended this four years ago.
Last year a Harvard publication exposed how industry captured the FCC, "As a captured agency, the FCC is a prime example of institutional corruption. Officials in such institutions do not need to receive envelopes bulging with cash. But even their most well-intentioned efforts are often overwhelmed by a system that favors powerful private influences, typically at the expense of public interest."

Although there is a search engine on the FCC web site, one cannot easily find important documents. Hence, I constructed several indices.
Part I which appears below contains key submissions to the FCC regarding cell phone radiation and its health effects, and cell phone testing procedures and regulatory standards.

The submissions are organized under the following categories:

(1) Scientific Expert Resolutions Calling for Stronger Regulations
(2) Expert Comments in Support of Stronger Regulations
(3) Expert Comments that Support Weaker Regulations
(4) Consumer, Environmental and Health Organizations
(5) Government Agencies
(6) Wireless Industry Corporations and Associations
(7) Miscellaneous Other 
Not indexed below are submissions from individuals without organizational or institutional affiliations.  Many of these submissions discuss electromagnetic hypersensitivity (EHS).
Part II contains a list of key research papers that can be downloaded from the FCC web site. 
Part III lists 98 scientific experts from 23 nations who have signed resolutions between 2002 and 2014 that call for stronger regulations on wireless radiation, especially cell phone radiation.

In 2015, scientists who published peer-reviewed research on the health effects of electromagnetic fields (EMF) submitted a petition to the United Nations, the World Health Organization, and all world leaders calling for stronger EMF regulations. The International EMF Scientist Appeal has also been submitted to the FCC. The Appeal has now been signed by 221 scientists from 41 nations. All have published peer-reviewed research on electromagnetic fields and biology or health.
 Scientific Expert Resolutions Calling for Stronger Regulations  
Catania Resolution (2002; 16 signees)

Benevento Resolution (2006; 52 signees)
http://apps.fcc.gov/ecfs/document/view?id=7520941320
Seletun Scientific Panel (2009); 7 signees)
Health Canada Safety Code 6 Declaration  (Jul 9, 2014); 54 signees)
International EMF Scientist Appeal (May 11, 2015; 200 signees)

Expert Comments in Support of Stronger Regulations
Omer Abid, MD, MPH

Norm Alster ("FCC captured agency")
http://
bit.ly/FCCcapturedagency

BioInitiative Working Group (29 contributing authors)
http://apps.fcc.gov/ecfs/document/view?id=7521097953



Devra Davis PhD MPH, Alvaro de Salles PhD, Susan Downs MD, Gunnar Heuser MD PhD, Anthony Miller MD. Lloyd Morgan BSEE, Yael Stein MD. Elihu Richter MD MPH (rebuttal of CTIA's claims)
http://apps.fcc.gov/ecfs/document/view?id=7520958286

Alan H. Frey

Martha Herbert, MD, PhD
http://apps.fcc.gov/ecfs/document/view?id=7520940748
https://ecfsapi.fcc.gov/file/1070786836035/MarthaHerberttoMCPS2015.pdf
Olle Johansson, PhD
https://ecfsapi.fcc.gov/file/7022311370.pdf
Suleyman Kaplan, PhD
http://apps.fcc.gov/ecfs/document/view?id=7520941388
Henry C. Lai, PhD

Victor Leach / Simon Turner   

De-Kun Li, MD, PhD, MPH

Don Maisch, PhDhttps://ecfsapi.fcc.gov/file/7022311348.pdf 

Joel M. Moskowitz, PhD
http://apps.fcc.gov/ecfs/document/view?id=7022311233
http://apps.fcc.gov/ecfs/document/view?id=60002030879
http://apps.fcc.gov/ecfs/document/view?id=60002031262
https://ecfsapi.fcc.gov/file/60002031262.pdf
Jerry L. Phillips, PhD
http://apps.fcc.gov/ecfs/document/view?id=7520940948
Ronald M. Powell, PhD
https://ecfsapi.fcc.gov/file/1070786836035/Message%20to%20Public%20Schools%20about%20Wireless%20Devices.pdf
William J. Rea, MD
http://apps.fcc.gov/ecfs/document/view?id=7520940950

Cindy Sage, Lennart Hardell, MD & Martha Herbert, MD, PhD
http://apps.fcc.gov/ecfs/document/view?id=7520940054

Cindy Sage & David O. Carpenter, MD

Miriam D. Weber, MD


Expert Comments that Support Weaker Regulations

Consumer, Environmental and Health Organizations

American Academy of Environmental Medicine
http://apps.fcc.gov/ecfs/document/view?id=7520941435

Center for Electrosmog Prevention


Electromagnetic Safety Alliance, Inc.
http://apps.fcc.gov/ecfs/document/view?id=7022311420
http://apps.fcc.gov/ecfs/document/view?id=7520941598
EMF Safety Network


Environmental Working Group
Environmental Working Group (petition w/ 26,000 signatures):
http://apps.fcc.gov/ecfs/document/view?id=7520941684
Global Union Against Radiation Deployment from Space http://apps.fcc.gov/ecfs/comment/view?id=60001390648

Pharmacists Planning Service Inc (PPSI)


Stop Smart Meters New York
http://apps.fcc.gov/ecfs/document/view?id=7520941985

Wireless Education Action
http://apps.fcc.gov/ecfs/document/view?id=7022311599


Government Agencies

Cities of Boston, Massachusetts and Philadelphia, Pennsylvania
http://bit.ly/1kAYSu7
Environmental Protection Agencyhttps://ecfsapi.fcc.gov/file/7520941527.pdf
FCC Office of the Chairman (Response to Sen. Blumenthal & Rep. Eshoo)http://apps.fcc.gov/ecfs/document/view?id=60001353996
FCC Office of Engineering Technology Bureau
http://apps.fcc.gov/ecfs/document/view?id=7022136643
International Agency for Research on Cancer, World Health Organization

Los Angeles Unified School District

National Cancer Institute & National Institute of Environmental Health Sciences https://ecfsapi.fcc.gov/file/7521123438.pdf 
National Institute for Occupational Safety and Health

City and County of San Francisco

Radiation Protection Division, Environmental Protection Agency
http://apps.fcc.gov/ecfs/document/view?id=7520941527
Radiofrequency Interagency Working Group(Federal)
http://apps.fcc.gov/ecfs/document/view?id=7520941598
City of Tucson and County of Pima, Arizona Resolution


Wireless Industry Corporations and Associations

Alarm Industry Communications Committee
http://apps.fcc.gov/ecfs/document/view?id=7520958406

ARRL, the National Association for Amateur Radio
http://apps.fcc.gov/ecfs/document/view?id=7520941424


Fixed Wireless Communications Coalition

GSM Association
http://apps.fcc.gov/ecfs/document/view?id=7520940433

IEEE International Committee on Electromagnetic Safety (ICES)
http://apps.fcc.gov/ecfs/document/view?id=7520940730 
Medtronic Inc
http://apps.fcc.gov/ecfs/document/view?id=7520941474

National Association of Broadcasters
http://apps.fcc.gov/ecfs/document/view?id=7520941561

National Association of Telecommunications Officers and Advisors

PCIA-The Wireless Infrastructure Association and The HetNet Forum
http://apps.fcc.gov/ecfs/document/view?id=7520941685
http://apps.fcc.gov/ecfs/document/view?id=60000971924
Telecommunications Industry Association
http://apps.fcc.gov/ecfs/document/view?id=7520941840
Richard Tell Associates

American Association for Justice
http://apps.fcc.gov/ecfs/comment/view?id=6017466603
Green Swan, Inc.
http://apps.fcc.gov/ecfs/document/view?id=7520941846
North America's Building Trade Unions
http://apps.fcc.gov/ecfs/comment/view?id=60001483296http://apps.fcc.gov/ecfs/comment/view?id=60001328468https://ecfsapi.fcc.gov/file/60001514689.pdf