The National Highway Traffic Safety Administration has opened a docket make a rule which will require V2V Communication in all new vehicles. V2V Communication utilizes a transmitter in each vehicle to continuously signal oncoming vehicles as to your position, speed and direction of travel. It is supposed to be a safety feature. Please see this notice in the Federal Register for more information. So far the National Highway Traffic Safety Administration has moved forward with complete disregard to the very real public health hazard that continuous exposure to yet another source of radiofrequency (microwave) radiation will cause.

File a comment with the National Highway Traffic Safety Administration in opposition to requiring V2V technology in all new vehicles (Docket No. NHTSA-2016-0126). Comments are due by April 12, 2017. Submit comment at http://www.regulations.gov/#!submitComment;D=NHTSA_FRDOC_0001-1752. Cars have both "dirty" electricity and transmitters. Both can cause functional impairment and, therefore, increase the risk of accidents. Please read the Background section below for an explanation of why radiofrequency (RF) exposure in cars from both "dirty" electricity and transmitters, including radiation-emitting assistive driving technology (e.g. V2V, etc.), is a bad idea.

1. Use a meter to measure radiofrequency radiation emitted by wireless technology to check your car for transmitters.

2. Remove fuses for transmitters installed in your car in consultation with your car's manual. Alternatively, your can have the dealer remove or disconnect the transmitters.

It is important to de-power your transmitters, especially those controlled by outside companies since they can turn them on and off as THEY want. At least one person has had a problem with such a system being turned on and causing functional impairment for them against their explicitly expressed request to have the transmitter off. The company seemed to feel that as long as they weren't charging for having it on, it was fine. The company did not "believe" that RF had health effects and apparently wanted the data they could collect with the transmitter on. Transmitters in cars can include: bluetooth, WiFi, cellphones, transmitters for roadside assistance companies, GPS, radar for assistive driving technology (a.k.a V2V communication), and wireless tire pressure monitors. Always verify that the transmitters are turned off using an appropriate RF meter.

3. Use a portable battery operated transistor radio to check for electrically polluting technologies (e.g. stereos, video systems, GPS systems, windshield wiper motors, air re-circulators, unfiltered and unshielded spark plugs in gas engines, ignition switches, alternators, fuel pumps, and a variety of other DC motors which may contribute RF that is conducted around the car on wires and returned on the frame.) Please use great care - do not touch radio antenna to electrical or moving parts or injury can result - or have a professional check for the polluting devices. Radiofrequency pollution often radiates from the polluting device and wires, leading to recognized RF interference problems and unrecognized RF health problems. Older radios which have not been "hardened" to prevent interference from RF "noise" work best for this step. It can be a challenge to track down the culprits. Start in the AM range, preferably inside an RF-blocking space like a steel shed, and move through the AM dial. Then, try FM. Pulling non-essential fuses carefully while listening for changes in the RF "noise" on the radio while the car key is in the accessories position can be helpful in tracking down the source. If you do this for too long, there is the potential for draining the battery. (Be sure not to run the car in a closed space since carbon monoxide poisoning can result.)

Please watch Mitigating Electronic Product Radiation a.k.a. Radio Frequency Interference (RFI) - a short video to see how significant these sources of RF can be and how easily it can be reduced, even by non-engineers.

4. Remove fuses for non-essential electrically polluting devices like the inverter which provides 60 Hz electricity to AC outlets.

5. Filter the alternator using capacitive filters. Careful selection of capacitors is important. According to what I have read, capacitors must be motor-run or rated for continuous usage and preferably rated for 4 times the voltage of the system they will be installed in so that they can withstand the large transients (RF) they will be filtering. We have used Panasonic Dry Film 20microFarad 180VAC capacitors (JS181206-AA) connected from the hot to the ground on the alternator for years. On vehicles where the alternator output leads are difficult to access, we have installed the filters from the positive to neutral on the battery. The suggestion for this approach was provided in the 1996 edition of Radio Frequency Interference: How to find and fix it published by the American Radio Relay League (ISBN 0-87259-375-4). We have since added some smaller capacitors, as discussed in Radio Frequency Interference: How to find and fix it.

6. Carefully use ferrites, capacitive filters, and shielding to minimize RF exposure from essential components of the car that are "Incidental" and "Unintentional" Radiators. You may need a professional to do this. See these links for directions for filtering DC motors like the ones used in windshield wipers and fan blowers: https://www.pololu.com/docs/0J15/9 point number nine "Dealing with Motor Noise" and http://www.kerrywong.com/2012/01/26/a-short-guide-on-motor-electrical-noise-reduction/ and http://robotics.stackexchange.com/questions/267/why-are-capacitors-added-to-motors-in-parallel-what-is-their-purpose and http://www.recentscientific.com/sites/default/files/2485.pdf

7. After care has been taken to minimize RF emissions from inside the vehicle, it may be helpful to install shielding on the vehicle's windows to block RF radiation out. This can be done using SD100 from Signals Defense or some other RF-blocking window film. Do NOT shield your windows if wireless will be used in the car.

Steps to minimize RF exposure in your home can be found on the Solutions page at www.electricalpollution.com

Radiofrequency Pollution in Cars
Cars have long been a problem for people with radiofrequency (RF) sickness. In recent years, however, they have become so polluted with wireless technology that they are causing symptoms for people who did not previously realize that they had RF sickness.

Cars have always contained RF generating elements. FCC regulates what are called "Incidental" and "Unintentional" Radiators, as well as "Unlicensed Intentional" Radiators, Industrial, Scientific, and Medical (ISM) Radiators, and Licensed Radiators. The regulations governing "Incidental" and "Unintentional" radiators are not related to protecting human health at all. They are solely designed to prevent RF interference with other devices. These regulations have encouraged "hardening" of electronics receiving the RF interference almost as much as reducing "Incidental" and "Unintentional" RF emissions.

We now know that the human body is extremely sensitive to that same interference. Since the human body cannot be "hardened" to prevent "noise" (a source of radiofrequency (RF) exposure) from affecting it, regulations need to be tightened substantially to make technology safe. Currently, polluting technology is causing serious health problems. Cars are one area that is becoming particularly problematic.

For safety reasons, regulations governing "Intentional", "Unintentional", and "Incidental" radiators in cars need much tighter regulatory control.

Brief General Information about Hazards of Radiofrequency Radiation
Multiple U.S. Government Agencies have acknowledged that the FCC RF limits do not protect people from experiencing biological effects when exposed chronically to levels of RF radiation commonly found in our environment.

• In 2016, the U.S. National Toxicology Program (NTP) released results showing that exposure to non-thermal levels of RF radiation causes cancer and DNA breakage. Furthermore, a replicated European toxicology study showed that RF radiation promotes cancer growth (http://ehtrust.org/science/facts-national-toxicology-program-cellphone-rat-cancer-study/). This alone provides an important basis for tightening regulations on "Intentional", "Unintentional", and "Incidental" RF levels in cars.

• The Department of Interior 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."(http://www.ntia.doc.gov/files/ntia/us_doi_comments.pdf)

• The Environmental Protection Agency stated "The FCC's current exposure guidelines, as well as those of the Institute of Electrical and Electronics Engineers (IEEE) and the International Commission on Non-ionizing Radiation Protection, are thermally based, and do not apply to chronic, nonthermal exposure situations. They are believed to protect against injury that may be caused by acute exposures that result in tissue heating or electric shock and burn. The hazard level (for frequencies generally at or greater than 3 MHz) is based on a specific absorption dose-rate, SAR, associated with an effect that results from an increase in body temperature. The FCC's exposure guideline is considered protective of effects arising from a thermal mechanism but not from all possible mechanisms. Therefore, the generalization by many that the guidelines protect human beings from harm by any or all mechanisms is not justified." (emphasis added) (http://www.emrpolicy.org/litigation/case_law/docs/noi_epa_response.pdf). As the EPA makes plain, the FCC RF radiation limits are not protective from all adverse effects only those from thermal mechanisms during acute exposures. FCC RF radiation limits are based on thermal effects in a large male. They are not population-protective. They do not and were never intended to protect from biological effects or even thermal effects during the chronic exposures we all experience today.

• U.S. Occupational Safety and Health Administration (OSHA) website acknowledges, "There are no specific standards for radiofrequency and microwave radiation issues." https://www.osha.gov/SLTC/radiofrequencyradiation/index.html

• The Centers for Disease Control had precautionary statements posted on its website which were changed after attention was drawn to them (probably due to industry pressure). The original statements were "Along with many organizations worldwide, we recommend caution in cell phone use. More research is needed before we know for sure if using cell phones causes cancer."; "Scientific studies are ongoing. Someday cellphones may be found to cause health problems we are not aware of at this time."; and "Children who use cell phones - and continue to use them as they get older - are likely to be around RF for many years. If RF does cause health problems, kids who use cell phones may have a higher chance of developing these problems in the future." (http://www.prlog.org/12359483-cdc-issues-precautionary-health-warnings-about-cell-phone-radiation.html) These statements have been replaced with statements expressing more uncertainty and calling for more research, in other words typical industry stall statements, very distinct from statements of safety (http://www.prlog.org/12362077-cdc-retracts-its-precautionary-health-warning-about-cell-phone-radiation.html).

There is increasing consensus within the research community that existing RF limits are not protective. Two hundred twenty scientists from 42 countries 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 (http://www.emfscientist.org). Many other nations are taking precautionary action (http://ehtrust.org/policy/international-policy-actions-on-wireless/), the U.S. ought to be as well.

Even professional organizations are beginning to grudgingly acknowledge the inadequacy of the limits for protecting the public health of the population. The International Commission on Non-Ionizing Radiation Protection (ICNIRP) states:

"Different groups in a population may have differences in their ability to tolerate a particular NIR (non-ionizing radiation) exposure. For example, children, the elderly, and some chronically ill people might have a lower tolerance for one or more forms of NIR exposure than the rest of the population. Under such circumstances, it may be useful or necessary to develop separate guideline levels for different groups within the general population, but it may be more effective to adjust the guidelines for the general population to include such groups. Some guidelines may still not provide adequate protection for certain sensitive individuals nor for normal individuals exposed concomitantly to other agents, which may exacerbate the effect of the NIR exposure, an example being individuals with photosensitivity." from ICNIRP STATEMENT, GENERAL APPROACH TO PROTECTION AGAINST NON-IONIZING RADIATION PROTECTION, (HEALTH PHYSICS 82(4):540-548; 2002) https://www.icnirp.org/documents/philosophy.pdf

After the NTP results were released, the Institute for Electrical and Electronics Engineers (IEEE) posted an article with comments from Kenneth Foster of the IEEE committee that reviews RF radiation exposure limits:

"With the NTP study results, Foster expects more governments to put out cautionary guidelines and radiation labeling for cellphones. He says he wouldn't be surprised if California adds RF radiation to its Proposition 65 list of carcinogenic chemicals, and if the IARC ups its classification rating from 2B: possibly carcinogenic to humans to 2A: probably carcinogenic to humans. "And they wouldn't be out of line in doing that," he says. "This is going to change the rhetoric in the field. People can point to much more hard evidence that [cellphone RF exposure] really is a problem." (http://spectrum.ieee.org/the-human-os/biomedical/ethics/cellphone-radiation-causes-cancer-in-rats)

Cellular Telephone Russian Roulette (http://microondes.files.wordpress.com/2010/03/robert_c_kane_cellular_telephone_russian_roulette.pdf), written by Robert C. Kane, a former Motorola engineer, discusses the fact that numerous studies show that significant biological effects occur at such low levels that useful wireless technology is by definition unsafe wireless technology. He further discusses the problem of microscopic, but biologically harmful hot spots which occur at levels far below those normally considered to cause thermal harm.

Radiofrequency Pollution a Serious Safety Issue in Cars
Cardiac Arrest
A number of studies show that electromagnetic radiation, including radiofrequency radiation, alters heart rate variability, blood pressure (including inducing hypertension with microwave exposure) and increases risk of arrhythmia related heart disease and heart attack. (Mahra et al 1971)(Cherry 2000)(Havas et al 2010)(Havas and Marrongelle 2013)(Havas 2013).

Cardiac arrhythmias can be caused by wireless technology. Recent replicated double blind studies show that a cordless phone base station operating at WiFi frequencies can cause cardiac arrhythmias in susceptible individuals (Havas et al 2010)(Havas and Marrongelle 2013)(Havas 2013). This short video discusses the cardiac effect that wireless can have-http://www.youtube.com/watch?v=_EI9fZX4iww. View this video http://www.youtube.com/watch?v=sv1E9IXUd6M/a> to see further discussion. You can read the studies at http://www.magdahavas.com/wordpress/wp-content/uploads/2012/01/Havas-HRV-Ramazzini.pdf and http://www.ncbi.nlm.nih.gov/pubmed/23675629#.

A recent 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 et al 2015). A mouse cardiac study showed that mice exposed to RF radiation from a cellphone had significantly lower vitamin D levels, low calcium, low antioxidant capacity, low cardiac tissue MDA and elevated renin levels compared to controls. They also had enlarged left ventricles and ECG abnormalities (Fatma 2011). Both these cardiac effects are pre-disposing factors toward cardiac arrest. Obviously, these serious cardiac effects caused by RF radiation exposures from consumer devices should preclude them from cars.

Cardiac arrest is undesirable at any time but when a person is operating a large potentially lethal object like an automobile or truck, it is particularly so.

Cars and trucks should not have wireless technology in them and they should have shielded compartments for the storage of consumer wireless technology during transport. Furthermore, other sources of RF exposure in cars should be minimized through good engineering by automobile manufacturers.

The very serious consequences of cardiac arrhythmia or cardiac arrest while operating a vehicle should impel the FCC and the National Highway Traffic Safety Administration to tighten RF limits on all classes of RF emitters in vehicles.

Cognitive and Neurological Impairment
A review of old Soviet literature discusses the fact that reflexes, including conditioned reflexes, are slower in individuals exposed to RF. They go on to state "It is possible to observe degeneration of the neurons in the cerebral cortex and the basal ganglia, the pons, the medulla oblongata, and in some cases even the cerebellum, as well as histological and chemical changes in the vicinity of nerve fibers." Obviously, it is not a good idea to have an environmental toxin that can impair reflexes and damage nerves inside vehicles whose safe operation relies on those very reflexes and good neurological and brain function. (Mahra et al 1971)

Many more people are adversely affected by RF radiation than realize it. Radiation from wireless devices may exacerbate the effects of a distraction such as conversation and impair reflexes and slow brain processing even at the lower levels phones emit when not connected. This may occur in part due to RF lowering dopamine levels (Buchner and Eger 2011) or thyroid levels (Eskander 2012), as well as the other effects mentioned above.

"A Comparison of the Cell Phone Driver and the Drunk Driver" shows delays in reaction times that may relate to the RF emissions from the phone (Strayer et al 2006). Unfortunately, driving studies have not been designed to examine whether it is the RF emissions of the phones that are causing the problem. In "Examining the Impact of Cell Phone Conversations on Driving Using Meta-Analytic Techniques," the authors state "There was a similar pattern of results for passenger and remote (cell phone) conversations."(Horrey and Wickens 2006) However, it is not clear whether both driver and passenger had their cellphones on and emitting at the time of the conversation, which would obviously be a confounder. Measuring Cognitive Distraction in the Automobile, a recent report on distracted driving also provides data additional technology in cars may not be safe (Strayer et al 2013). Unfortunately, the potential effect of the RF exposure itself whether from transmitters, electronics, or the vehicle electrical system was not factored into the experimental design. An article with the great title "A Problem of the Brain, Not the Hands: Group Urges Phone Ban for Drivers" probably has it right - although perhaps not for the right reason. Radiation from cellphones does indeed interfere with brain function, thus it may matter little whether the driver is conversing on a phone they hold, hands-free, or, indeed, with a passenger, as long as phones are on in the car or the area is high in wireless radiation. Ambient microwave radiation levels have gotten quite high in many metropolitan areas.

Public Health Implications of Radiofrequency Pollution in Cars
There are long-term public health implications of wireless radiation exposure. Detrimental biological effects, distinct from tissue heating effects, have been extensively documented in studies at a range of different frequencies and at levels below the current United States safety standard (Cherry 2000)(Hyland 2000)(Santini 2003). Many other nations already have more rigorous safety standards than does the US. Microwave and radiofrequency radiation are now being associated with attention deficit disorder, autism, sleep disorders, multiple sclerosis, Alzheimer’s disease and epilepsy, as well as asthma, diabetes, malignant melanoma, breast cancer, and other illnesses that have become increasingly more common. Please see www.bioinitiative.org to read a 2012 review of the peer-reviewed science on the long-term risks of exposure to transmitted microwave and radio frequency radiation. Studies finding no health effects are predominantly industry funded (Huss 2007). A report published in Pathophysiology asks the provocative question about whether the recent (1997 and later) increase in exposure to microwave frequencies may be responsible for the recent deterioration in public health in Sweden (Halberg and Johansson 2009). The data seem to say that public exposure to microwave frequencies is a likely culprit.

Independent reviews such as "Criticism of the Health Assessment in the ICNIRP Guidelines for Radiofrequency and Microwave Radiation (100 kHz - 300GHz)", first completed on behalf of Ministry of Health/ Ministry for the Environment of New Zealand, and the BioInitiative Report, written by highly qualified independent scientists (www.bioinitiative.org), conclude that there are biological effects at levels well below existing safety limits. Both reviews find existing RF limits to be completely inadequate.

In light of the very serious threat that RF poses to public health, limiting exposure to RF in vehicles from all sources makes sense.

There are numerous studies linking proximity to cell towers/base station antennas with adverse health outcomes (http://www.bioinitiative.org). V2V communication would cause vehicles, highways, and roads to be similarly dangerous.

Availability of Low RF Cars Required by 2008 American's with Disabilities Act Amendments and Section 504 of the Rehabilitation Act
Radiofrequency sickness is a functional impairment caused by overexposure to radiofrequencies, which includes the pulsed modulated microwave frequencies used in wireless communication, as well as "Incidental" and "Unintentional" radiators (Mahra et al 1971)(Cherry 2000)(Grant)(Johnson Liakouris 1998). Once one has radiofrequency sickness, exposure to radiofrequencies causes functional impairments which can range from frustrating to life-threatening. EHS or electrohypersensitivity, which often encompasses radiofrequency sickness, affected 3% of the population twelve years ago, according to the California State Department of Health. More recent independent studies show the numbers may be higher now.

The proliferation of wireless technology is increasing the number of people with radiofrequency sickness and also restricting the daily activities of people with radiofrequency sickness. Past rules changes by the National Highway Traffic Safety Administration have made it more difficult for people with radiofrequency sickness to get vehicles that do not cause functional impairment for them - one example of an access-limiting requirement is the requirement for wireless tire pressure gauges. While the radiation levels emitted are below the FCC guidelines, that is irrelevant in terms of biological symptoms and safety, as previously discussed. A rules change that results in minimizing RF levels in vehicles would benefit everyone, improving public health, but it would particularly benefit the growing segment of the population experiencing RF sickness.

The FCC and the National Highway Traffic Safety Administration would violate Section 504 of the Rehabilitation Act and the intent of the 2008 ADA Amendments if they proceed with V2V communication, thereby further isolating and disabling people with radiofrequency sickness. In compliance with Section 504 of the Rehabilitation Act and the intent of the 2008 ADA Amendments they should act to make personal vehicles safe for persons with radiofrequency sickness. Private vehicles are often the only way people with radiofrequency sickness can travel due to the rampant proliferation of wireless technology.

Requiring that vehicles be engineered to minimize EMF/RF would be consistent with the EUROPAEM [European Academy for Environmental Medicine] EMF Guideline 2016 for the prevention, diagnosis and treatment of EMF-related health problems and illnesses states, "The primary method of treatment should mainly focus on the prevention or reduction of EMF exposure, that is, reducing or eliminating all sources of high EMF exposure at home and at the workplace." The Guideline provides strong support for initiating regulations to minimize EMF/RF in vehicles since the authors emphasize the importance of making changes necessary to include those already injured by RF/EMF in society and reiterate and support the statement by Hedendahl, Carlberg, and Hardell that "It is time to consider ELF EMF and RF EMF as environmental pollutants that need to be controlled." (Belyaev 2016)

The functional impairment that occurs with RF radiation exposure varies depending on the particular frequencies involved, their amplitude, and the duration of exposure and the size, height, and build of the exposed person. Headache, brain-fog, short-term memory loss, scattered thinking, irritability, nerve pain, muscle weakness, heart palpitations, and appetite loss are common. Longer stays in polluted environments intensify and worsen the symptoms. (Mahra et al 1971)

Halting development of V2V technology and requiring minimization of the RF in cars would benefit public health , the environment, and the inclusiveness of society, providing persons with radiofrequency sickness a safe method of travel and allowing them to fully exercise their civil rights.

Regulatory Action Needed to Minimize RF Exposure in Vehicles
It is important that the FCC Office of Engineering and Technology and National Highway Traffic Safety Administration work together to promulgate rules related to vehicle engineering to minimize RF exposure from all sources within vehicles to improve overall vehicle safety and minimize RF impaired driving. For public health reasons, it is important that vehicles not cause radiofrequency sickness in previously well individuals. To satisfy the intent of the Americans with Disability Act and Section 504 of the Rehabilitation Act, there must be well-engineered vehicles that are accessible for people with radiofrequency sickness available at prices comparable to ordinary stripped-down vehicles.

Regulatory Recommendations to Minimize RF Exposure in Vehicles: