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realizing that non-ionizing radiation also can cause biological effects in all systems of the body and in wildlife, including changes in DNA.'3 From its earliest days, the U.S. Environmental Protection Agency (EPA)' investigated adverse health and environmental effects of non-ionizing radiation. Pursuant to authority under 42 U.S.C. §2021(h), EPA published notice of its intent to develop guidance for federal agencies to limit public exposure to radiofrequency radiation in 1982.15 FCC Chairman Mark Fowler wrote to EPA encouraging the agency to complete guidance "as expeditiously as possible so that a uniform federal standard will be available for use by the FCC and other affected agencies."' In 1986, EPA published a report discussing the sources and levels of radiofrequency radiation to which the public was exposed and other analysis relevant to the development of exposure guidelines.'7 13 See, e.,g., Id. at 58("EMF can damage DNA even at low EMF-exposure levels"); 58("exposure not only causes immediate danger, but also unleashes a chain of processes that continue to produce damage well after the exposure itself'); 63("The type of cellular damage caused by EMF is similar to that caused by aging. The residual errors and genetic mutations accumulate, leading to malfunction and disease."). 14 GAO, Efforts by the Environmental Protection Agency to Protect the Public from Environmental Nonionizing Radiation (CED 78-79) (March 29, 1978), at 4-5. 15 EPA, Federal Radiotioll Protection Guidancc tbr Public Exposure to Radiolrequenci- Radiatiou, 47 Fed. Reg. 57338 (December 23, 1982). 16 Letter from FCC Chairman Mark S. Fowler to Anne Burford, EPA Administrator re Docket 81-43 (February 22, 1983), see Addendum Exh. B. 17 Norbert M. Hankin, EPA, Office of Air and Radiation, The Radiofrequency Radiation Environment. Environmental Exposure Levels and RF Radiation Emitting Sources (July 1986)(EPA-520/1-85-014).