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ARGUMENT <br /> As Petitioners explain, the FCC's 2019 Order violates fundamental <br /> principles of the APA. The FCC finalized several actions in the December 4, <br /> 2019, order. Most important, it resolved the inquiry it had initiated in 2013 <br /> regarding the adequacy of its RF radiation limits. Despite numerous scientific <br /> studies of potential harm from exposure below the limits set by the FCC in 1996, <br /> the Commission chose not to change them.'° The FCC misunderstands its <br /> responsibilities under NEPA and the TCA. As a result, the record lacks the <br /> support for the FCC's decision to continue to rely upon its 1996 limits for RF <br /> exposure. <br /> I. Exposure to Radiofrequency Radiation Has Increased with <br /> Proliferation of Wireless Services. <br /> Wireless services such as cell phones operate by using a form of <br /> electromagnetic radiation — energy moving through space as a series of electric and <br /> magnetic waves. The spectrum of electromagnetic radiation ranges from very low <br /> frequencies, such as electrical power from power lines to extremely high <br /> frequencies such as gamma rays. The portion of the spectrum used by mobile <br /> 1° 2019 Order, supra note 5, at ;2 ("we find no appropriate basis for and thus <br /> decline to propose amendments to our existing limits at this time"). <br /> 9 <br />