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.