Environmental Health Sciences, through its Wireless and EMF program, submits science-based comments in numerous FCC proceedings 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. EHS also files into international proceedings to support international efforts.
FCC’s current wireless radiation exposure limits, unchanged since 1996, are scientifically outdated and fail to account for long-term exposure, vulnerable populations like children. These limits were designed only to prevent short-term heating effects and ignore growing scientific evidence of biological impacts, ecological harm, and real-world exposure conditions.
Comment on the FCC’s National Environmental Policy Act Rules Proposals That Could Weaken NEPA
No. RM-12003 Regarding DA-25-217
On September 18 2025, Environmental Health Sciences submitted comments to the FCC regarding its proposal that could weaken the National Environmental Policy Act (NEPA) review of wireless infrastructure. EHS argues that existing FCC rules are outdated, fail to address well-documented health and environmental harms from radiofrequency radiation and satellite expansion, and must be modernized to comply with court mandates and safeguard public health, wildlife, and ecosystems.
“The record before the Commission is clear: the environmental and health consequences of wireless infrastructure are neither speculative nor remote, but reasonably foreseeable, well documented in the scientific literature, and already observable in both human populations and ecological systems. The FCC’s obligations under NEPA do not exist in isolation, they intersect with the Endangered Species Act, the National Historic Preservation Act, and the Administrative Procedure Act. Weakening NEPA review would place the Commission in conflict with these statutory responsibilities, while ignoring a binding federal court mandate in Environmental Health Trust et al. v. FCC. This proceeding is therefore not simply about administrative efficiency; it is about whether the Commission will uphold its duty to the public and future generations by ensuring that technological development does not come at the expense of human health, ecological integrity, and environmental justice.”
Comment on the French Government Proposal to Weaken its Wireless Radiation “Atypical Point” Threshold Triggering Action and Oversight
Proposals to change the threshold of atypical points for EMF in L.123-19-1 of the Environmental Code and L.32-1 of the Postal and Electronic Communications Code
On September 12 2025, Environmental Health Sciences (EHS) submitted expert comments to France’s National Frequency Agency (ANFR) public consultation on a proposal to weaken its policy regarding the threshold of “atypical points” for wireless radiation 6 V/m to 9 V/m. This proposal would allow more radiation exposure before triggering action to reduce exposure. EHS’ filing provided extensive scientific documentation on how the change would weaken protections for the public, children, and wildlife.
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.