Tuesday, October 14, 2014

Take Action: NHTSA mandating Vehicle to Vehicle communication in every vehicle!

Take Action: NHTSA mandating Vehicle to Vehicle communication in every vehicle!

Please Distribute Widely!

I know that there may seem to be a lot of proceedings to comment in, but please take the time to submit a comment.  Your comments build the basis of a legally actionable record.  Without them, this ordeal will never end.  Below is the link to the National Highway Traffic Safety Administration public notice about the proposed rule to mandate vehicle to vehicle (V2V) communication in ALL VEHICLES.  

The deadline is October 20, 2014!

Please take a moment to let NHTSA know what you think of their rule to require V2V communications systems in all vehicles  Some points you may want to include are listed below.  Please expand them by illustrating the hardships you personally will suffer if V2V communications technology is rolled out in all or even almost all vehicles.

You can submit your input at http://www.regulations.gov/#%21docketDetail;D=NHTSA-2014-0022 by pushing the "comment now" button.

Thank you,

Date Posted:Aug 20, 2014
CFR:49 CFR Part 571
Federal Register Number:2014-19746

Vehicle to Vehicle Communication Research Report

You can submit your input at http://www.regulations.gov/#%21docketDetail;D=NHTSA-2014-0022 by pushing the "comment now" button.

The wireless technology that would make V2V communications work and that NHTSA proposes to require in all vehicles for safety reasons has been classified as a class 2B possible carcinogen by the World Health Organization and only complies with completely outdated thermally-based "safety" limits.  See this video of Professor Emeritus Dr. Anthony Miller, of the University of Torontoabout the carcinogenicity of radiation from wireless devices which can be found at http://www.youtube.com/watch?v=wARxnaxrRKk.  Reputable scientists are calling for it to classified as a probable carcinogen (http://www.pathophysiologyjournal.com/article/S0928-4680(13)00003-5/abstract), while other equally qualified experts are calling for it to classified as a carcinogen  (http://dx.doi.org/10.1515/reveh-2013-0006). It should not be required in ANY vehicles.  Use should be discouraged, not encouraged. 

V2V communications systems would continuously emit pulsed modulated microwave radiation.  The emissions would have to be virtually continuous due to the nature of what the system is trying to do with continuously tracking the positions, velocities, and directions of motion of vehicles around in order to be able to provide the functions sought by the NHTSA.  The NHTSA is proposing the rule because they believe "that V2V capability will not develop absent regulation, because there would not be any immediate safety benefits for consumers who are early adopters of V2V"  NHTSA believes that V2V capability will save lives and has no downsides and so feels that they do not need to do a NEPA review - "The agency has preliminarily determined that installation of V2V technology alone would not have any significant impact on the quality of the human environment."  In their questions, they do not ask about safety hazards or societal costs.  

Everyone needs to weigh in with their experiences with radiation from wireless devices and references (a list of points to include are listed below).  Experts are needed to address areas of safety, privacy, security, and the environment.  NHTSA techies have their hearts set on implementing this technology nationwide and globally.  It is imperative that they receive comments from everyone - ranging from personal impact to expert testimony.  It will take an outpouring to stop this so please take time to write and submit your comment and pass this email on widely.

Important Points:Below are some points that you might want to include in your input, then personalize/support them with a brief account of your own experience and your favorite references (which you can also upload for the NHTSA to read).
  • No one should be forced to have V2V technology in their vehicle.  It utilizes a potentially hazardous technology compliant only with outdated safety limits which pregnant women and people with a whole range of medical conditions are being warned to avoid.
    • In a recent letter, the United States Department of the Interior states that “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)
    • IARC of the World Health Organization classified radiofrequency radiation as a class 2B possible carcinogen in May 2011.  Experts think the classification should be changed to probable carcinogen or even carcinogen. 
    • 2012 BioInitiative Report classifies radiofrequency radiation as a carcinogen.  [Here is a sample wording to use to include 2012 BioInitiative Report in your comment without uploading the whole thing:  The 2012 BioInitiative Report is incorporated by reference herein in its entirety (http://www.bioinitiative.org /)]
    • “Public safety standards are 1,000 – 10,000 or more times higher than levels now commonly reported in mobile phone base station studies to cause bioeffects.”(http://www.bioinitiative.org/conclusions/) - You can find other great quotes relevant to your situation to include by visiting their conclusions section.
    • The FCC has a duty to the public to protect the public health and safety from harm from radiofrequency radiation.  (H.R. Report No. 104-204, p. 94)
    • FCC does not possess the expertise to set biologically-based radiofrequency radiation safety limits.  EPA does.  Therefore, the FCC should advocate that Congress direct the EPA to establish biologically-based radiofrequency radiation safety limits and provide the budget and resources to carry out that task.  2012 HR6358 was an excellent example of legislation to authorize the EPA to establish biologically-based radiofrequency radiation safety limits
    • The Baby Safe Project was launched in June to warn pregnant women of the hazards of exposure to radiation from wireless technology during pregnancy.  (www.babysafeproject.org)
    • A recent symposium for MDs discusses a range of safety hazards posed by radiation from wireless technology, particularly pregnant women are urged to avoid it.  (http://www.c4st.org/MDSymposium)
  • Requiring V2V technology violates the 2008 ADA Amendments since it will further isolate and marginalize many people with radiofrequency sickness, electromagnetic hypersensitivity, etc.  Many people with radiofrequency sickness/EHS already cannot use public transportation due to the presence of cellphones and WiFi, this could make public roads and highways inaccessible as well.  Therefore, requiring V2V technology is not in compliance with the ADA (Americans with Disabilities Act), particularly the 2008 ADA Amendments, which base their disability determination on interference with bodily functions (http://www.govtrack.us/congress/bills/110/s3406/text).  There are many many studies showing the RF radiation interfere with bodily processes, often seriously (www.bioinitiative.org).
  • Courts have interpreted the ADA and the 2008 ADA Amendments broadly to ensure accessibility throughout society and require broad inclusivity.  (http://www.justice.gov/osg/briefs/2003/3mer/2mer/2002-1667.mer.aa.htmlhttp://disabilitylaw.blogspot.com/2012/06/d-mass-allows-ada-title-iii-challenge.html)  Thus, NHTSA cannot require V2V technology, a technology which would greatly restrict access to people with symptoms of RF sickness - estimated at 3-30% of the population and ranging from severely impaired to less severely impaired.  People with RF sickness cannot safely use wireless technology or technology which exposes them to RF on wiring, nor can they be around it, as they would be with V2V technology if they purchased a new vehicle or used a road or were near a road.
  • No new source of RF radiation exposure should be allowed without examining the ADA compliance.  Many people are now excluded from public buildings, public places, parks, highways, and limited in almost all aspects of normal daily living.  Continued rollout of additional sources of RF radiation puts the NHTSA in direct violation of the ADA.
  • If you are restricted in your activities by the presence of RF radiation, please give personal examples to add power to your input.
  • An Environmental Impact Statement is required due to the potential for serious negative environmental impact from the additional and ubiquitous emission of pulsed microwave radiation.  A NEPA evaluation and EIS are necessitated by the presence of three options which have the potential to have radically different impacts [Burkholder v. Peters, 58 F. App’x 94, 96 (6th Cir. 2003) (quoting42 U.S.C. § 4332(2)(C)).] The EIS should include a review of the impact of all options on the environment, as well as on human health and safety. "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 (incorporated by reference herein in its entirety http://www.moef.nic.in/downloads/public-information/ final_mobile_towers_report.pdf) and "Impacts of radio-frequency electromagnetic field (RF-EMF) from cell phone towers and wireless devices on biosystem and ecosystem – a review,"" (incorporated by reference herein in its entirety http:// www.biolmedonline.com/Articles/Vol4_4_2012/Vol4_4_202-216_BM-8.pdf) and the letter from the Department of Interior (incorporated by reference herein in its entirety http://www.ntia.doc.gov/files/ntia/us_doi_comments.pdf)  provide enough compelling evidence of potential environmental harm at to the environment by RF technologies at existing RF limits to necessitate an EIS evaluating the harm done by promoting use of additional wireless technology, or continuing in the status quo, compared to requiring car manufacturers to decrease the RF exposures within and outside the vehicles.
  • Vehicle safety needs to be improved (as is the NHTSA mission) by decreasing RF exposures within vehicles through improved engineering of their internal wiring systems to decrease RF on the car's wiring. See www.electricalpollution.com for more information about the health effects of RF on wiring systems.  Exposure to RF radiation from wireless technology within cars also needs to be decreased within vehicles to avoid the cognitive effects cites in old Soviet literature and now being rediscovered in recent studies - slowed reaction times, cognitive difficulties, poor memory, etc.).  Such improvements could include shielded compartments for cellphones, tablets, etc.  So that they are not emitting signals into the driver's compartment during transit and causing impairment.  Additionally, all technologies within the car should be hardwired, not wireless.

Don't wait until the last minute or the server may be too busy to take your comments.

1. Submit your input at http://www.regulations.gov/#%21docketDetail;D=NHTSA-2014-0022 by pushing the "comment now" button.

2. If this is a potential ADA access issue for you, send a copy to the DOT Department of Civil Rights at https://www.civilrights.dot.gov/about-docr/contact-us and to the general NHTSA contact at http://www.nhtsa.gov/Contact    The Department of Transportation is supposed to have its own ADA office, however, while the process for filing a complaint against an employer was fairly clear, the process for bringing an ADA related problem of another nature to their attention was not.  Please still take a moment to send a copy of your input to DOT Civil Rights Office and the NHTSA using their contact forms and ask that they investigate this new threat to universal access and public safety.

3. Send a copy to your federal Senators and Representative and ask for them to advocate for you with the NHTSA, especially if this is a potential access issue for you.

Protecting my health and that of others by using a hardwired computer in a low RF environment.  For more information, see www.electricalpollution.com

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