Environmental Health Sciences, through their Wireless and EMF program, submits responses to FCC dockets in order to advance U.S. federal regulatory accountability, promote the development of science-based exposure limits for wireless radiofrequency (RF) radiation and ensure transparency and oversight independent of corporate influence.
Comment on the FCC’s National Environmental Policy Act Rules Petition
No. RM-12003 Regarding DA-25-290
On May 1 2025, Environmental Health Sciences submitted the following comments in response to CTIA’s request that the FCC streamline the National Environmental Policy Act (NEPA) rules to facilitate nationwide broadband deployment. EHS urged the FCC to reject CTIA’s petition to weaken NEPA’s environmental review processes, arguing that current regulations already fail to account for the growing scientific evidence of wireless radiation’s harm to human health and the environment. EHS supported the arguments made by the Public Employees for Environmental Responsibility (PEER) and called for improved oversight and meaningful environmental assessments.
Reply Comment on the FCC’s “Delete Delete Delete” Docket
No. 25-133 Regarding DA-25-219
On April 29 2025, Environmental Health Sciences replied in support of comments from the National League of Cities, National Association of Counties, The United States Conference of Mayors and many other filers urging the FCC to revoke several wireless infrastructure streamlining rules, arguing they bypass critical environmental and health reviews required under NEPA and the Administrative Procedure Act. The comments note that in 2019, Montgomery County, Maryland challenged the FCC’s small cell rules, citing the agency’s failure to complete its long-open RF safety limit inquiry. Though the Ninth Circuit dismissed the case as moot in 2020, the argument is now revived because in 2021, the D.C. Circuit ruled the FCC’s decision to retain its 1996 RF limits was “arbitrary and capricious” in EHT et al v. The FCC. This ruling validates Montgomery County’s arguments and underscores the need for legal and regulatory reconsideration of the FCC’s actions. EHS cited copious scientific evidence related to human health and the environment and court rulings showing FCC limits were outdated and called for updated science based safety standards and independent testing.
Comment on the FCC’s “Delete Delete Delete” Docket
No. 25-133 Regarding DA-25-219
On April 14 2025, Environmental Health Sciences submitted the following comments in response to the FCC’s opening of a public docket (known as “Delete Delete Delete”) seeking input on all rules and regulations the agency should modernize and or eliminate. EHS urged the FCC to update outdated wireless radiation safety limits based on current scientific evidence showing health and environmental harm at levels below existing standards. They also called for independent safety testing, improved compliance procedures, public transparency, and a pause on 5G expansion until proven safe.
Scientific Research Submissions to the FCC
RF Radiation Human Exposure Proceedings 19-226, 03-137 and 13-84
Numerous times a year, Environmental Health Sciences (EHS) submits up-to-date scientific research and policy recommendations to the Federal Communications Commission, highlighting the urgent need to revise its human exposure limits for wireless radiation. Theodora Scarato, now Director of the Wireless and EMF Program at EHS, has submitted hundreds of submissions in various capacities for over a decade. These submissions ensure the FCC has critical science on its record that cannot be ignored.