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TABLE OF CONTENTS <br /> RULE 26.1 DISCLOSURE STATEMENT i <br /> CERTIFICATE AS TO PARTIES, RULINGS, RELATED CASES, <br /> AND OF SEPARATE BRIEF ii <br /> STATEMENT REGARDING ORAL ARGUMENT iv <br /> TABLE OF AUTHORITIES vii <br /> GLOSSARY xii <br /> STATEMENT OF AUTHORITY TO FILE AND AUTHORSHIP <br /> AND FINANCIAL CONTRIBUTIONS 3 <br /> STATUTES AND REGULATIONS 3 <br /> I. National Environmental Policy Act (NEPA) 3 <br /> II. Telecommunications Act of 1996 (TCA) 5 <br /> SUMMARY OF THE ARGUMENT 6 <br /> ARGUMENT 9 <br /> I. Exposure to Radiofrequency Radiation Has Increased with <br /> Proliferation of Wireless Services 9 <br /> II. FCC Has Not Satisfied its Obligations under NEPA. 15 <br /> A. FCC Has Recognized Since 1985 that It Has Obligations <br /> under NEPA 15 <br /> B. 2019 Order Fails to Fulfill the FCC's NEPA Obligations16 <br /> III. FCC Misunderstands its Obligations under the TCA 19 <br /> A. Congress Gave the FCC the Responsibility to Protect the <br /> Public from RF Hazards 19 <br />