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complied with FCC regulations concerning such emissions.' The Act required the <br /> FCC to "prescribe and make effective rules regarding the environmental effects of <br /> radio frequency emissions" within 180 days.34 <br /> Seeking to avoid a patchwork of standards across the country, Congress <br /> gave the FCC the authority and responsibility to establish exposure limits to <br /> address the environmental effects of RF radiation.35 Wireless service providers did <br /> not want the difficulty and expense of complying with different local and state <br /> regulations.' The regulatory responsibility that Congress gave the FCC in 1996 to <br /> limit the environmental impacts differed from its previous responsibility under <br /> NEPA to understand the impacts. <br /> In addition to barring state and local regulation of the environmental effects <br /> of RE radiation, Congress limited EPA oversight by eliminating EPA's funding for <br /> activities related to RF radiation.' At the time, EPA was poised to issue new <br /> standards for RF radiation. It had briefed both the FCC and the National <br /> .33 47 U.S.C. § 332(c)(7)(B)(iv). <br /> 34 PL 104-104, supra note 3. <br /> 35 Report by. Rep. Bliley, Committee on Commerce, H.R. Rep. No. 204(1), <br /> 104th Cong., Sess. 1995. <br /> 36 See, e.g., Carol R. Goforth, "A Bad Call: Preemption of State and Local <br /> Authority to Regulate Wireless Communication Facilities on the Basis of <br /> Radiofrequency Emission's," 44 Sch. L. Rev. 311 , 364 (2001 ) ("compliance <br /> [with different state and local regulations] would be difficult and time-consuming <br /> for the telecommunications industry"). <br /> 37 See Senate Report 104-140, supra note 4, at 91("EPA shall not engage in EMF <br /> activities."). <br /> 20 <br />