Reproduces questions and dissenting arguments about whether cited studies undermine FCC exposure limits, …

We seek comment on whether “the five articles on which the majority opinion relied… do not

challenge a fundamental premise of the Commission’s order” and we ask the same question as to any

record information that the panel identified in arriving at its holding.

• One such article, the dissenting opinion noted, purported to present evidence of non-cancerous

“oxidative effects” but conceded that it “[did] not provide conclusive evidence of causal effects

and should be interpreted with caution until confirmed in other population.

• Another meta-analysis, the dissent observed, summarized the results of human studies on the

behavioral effects of RF radiation and identified “31 studies that showed no significant behavioral

effects compared to 20 studies that showed behavioral effects,” including “four [that] found

behavioral improvements, not negative health effects.

• Yet another, according to the dissent, failed to “address the critical issue—whether RF radiation

below the Commission’s current limits can cause negative health effects” because it examined the

International Commission on Non-Ionizing Radiation Protection’s (ICNIRP) recommended RF

exposure limit, which “is significantly higher than the Commission’s current limit—0.08 W/kg

averaged over the whole body and a peak spatial-average of 1.6 W/kg over any 1 gram of

tissue.

• And yet another, the dissent noted, acknowledged that “the health effects of [exposure to

radiofrequency electromagnetic fields (RF-EMFs)] are still unknown … [and] to date studies

addressing this topic have produced inconsistent results.