URGENT: Comments needed for FCC rule making on RF exposure standards – September 3rd deadline!


August 26, 2013ActionNo comments


View this on-line at:  http://tinyurl.com/mmfxgo5

Take Action – Submit your Comment in the FCC’s latest proceeding FCC 13-39 on its Radiofrequency (RF) Radiation exposure policy.

The 90-day Comment deadline is Tuesday, September 3rd (allowing for Labor Day holiday).

The 150-day Reply deadline is November 1, 2013.

Don’t wait until the last minute. Try to submit your Comment on Friday August 31, 2013 before Labor Day.

We have been pushing for this for 15 years!  The FCC is reassessing its Radiofrequency (RF) Radiation exposure limits and policies.  The FCC is asking if it should change its rules regarding human exposure to RF radiation.

In 1965, the first key federal court decision dealing with a federal agency’s responsibility to protect the environment (Scenic Hudson v. Federal Power Commission) said:

If the Commission is properly to discharge its duty in this regard, the record on which it bases it determination must be complete.  The petitioners and the public at large have a right to demand this completeness.  It is our view, and we find, that the Commission has failed to compile a record which is sufficient to support its decision.  The Commission has ignored certain relevant factors and failed to make a thorough study of possible alternatives . . .

. . . the public is entitled to know on the record that no stone has been left unturned.
The Commission of its own motion, should always seek to insure that a full and adequate record is presented to it.

A regulatory commission can insure continuing confidence in its decisions only when it has used its staff and its own expertise in manner not possible for the uninformed and poorly financed public.  (Emphasis added.)

In this case, as in many others, the Commission has claimed to be the representative of the public interest.  This role does not permit it to act as an umpire blandly calling balls and strikes for adversaries before it; the right of the public must receive active and affirmative protection at the hands of the Commission.

The Commission must see to it that the record is complete.  The Commission has an affirmative duty to inquire into and consider all relevant facts.

Two Key Points to Make:
Tell the FCC that it should make a direct request to the EPA to use its taxpayer-funded resources and experts present at its National Risk Management Research Laboratory to conduct all of the cost analyses it has asked for in this proceeding.

Remind the FCC that it has a duty under Scenic Hudson to create a complete record and to consider seriously your Comment in order to fulfill its obligation to represent the public interest.

Best regards –  Janet Newton

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