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of exposure to RF radiation. The assumption underlying these standards was that <br /> electromagnetic fields were harmful to humans only at levels powerful enough to <br /> increase the temperature of human tissue.22 <br /> At the time, the FCC did not impose specific radiation limits on all the <br /> industries it regulated. Rather than prohibiting services that exceeded the <br /> voluntary ANSI/IEEE guidelines, the FCC used the guidelines as a trigger to <br /> require an analysis of environmental impacts by wireless service providers.23 <br /> The worldwide explosion of wireless services has dramatically increased <br /> exposure of humans and wildlife to radiofrequency radiation. The International <br /> Telecommunications Union (ITU) reported an increase in global cellular <br /> subscriptions from 15.5% of the population in 2001 to an estimated 96.2% in <br /> 2013.24 <br /> exposures. For "uncontrolled" environments where civilians are likely to be <br /> exposed, the FCC uses standards developed by the National Council on Radiation <br /> Protection (NCRP). B. Blake Levitt, ed., Cell Towers, Wireless Convenience? Or <br /> Environmental Hazard? (Safe Goods/New Century Publishing 2000), at 35-36. <br /> 22 J. Elder, RADIOFREQUENCY RADIATION: ACTIVITIES AND ISSUES. <br /> U.S. Environmental Protection Agency, Washington, D.C., EPA/600/D-86/135 <br /> (NTIS PB86217155), 1986, <br /> https://cfpub.epa.govisi/sirecord_Report.cfm?Lab=NHEERL&dirEntrylD <br /> =47568. <br /> 23 Id., at 251011 84Xciting 42 U.S.C. §4332(2)(C)). <br /> 24 United Nations, International Telecommunication Union, Global ICT <br /> Developments, available at http://www.itu.intien/ITU- <br /> D/Statistics/PaRes/stat/defaultaspx. See generally, Kenneth A. Jacobsen, A Tale of <br /> Two Circuits: Curbs on Legal Remedies for Exposure to Potentiallv Harmful Cell <br /> Phone Radiation Emissions, 10 Seton Hall Circuit Review 1, 2-3 (2013). <br /> 13 <br />