ICLE Comments to the FCC on Radiofrequency Exposure Limits
I. Introduction and Overview
The International Center for Law & Economics (ICLE) submits these comments in response to the Federal Communications Commission’s (FCC) public notice on radiofrequency (RF) exposure issues remanded by the U.S. Court of Appeals for the D.C. Circuit in Environmental Health Trust v. FCC.[1] ICLE is a nonprofit, nonpartisan research center that applies law & economics to public policy. Its work promotes sound economic analysis and consumer welfare, particularly in dynamic, technology-driven markets such as telecommunications.
The FCC’s RF exposure limits aim to protect human health and reflect the best available scientific evidence. Periodic review helps ensure that those limits account for new research. Most concerns in the record, however, reflect fears that the scientific evidence does not substantiate. Those concerns deserve a clear response. Allowing them to drive restrictions that offer no demonstrated health benefits would impose substantial costs on American wireless technology and the consumers who rely on it.
The FCC can resolve the remanded issues through a thorough explanation of the evidence. The Administrative Procedure Act (APA) requires reasoned agency decision-making and leaves the FCC room to retain its existing limits if it adequately justifies them. The court identified gaps in the FCC’s explanation, including its treatment of record evidence and several substantive issues.
The record supports the FCC’s decision, and subsequent research has found no substantial evidence of harm that would justify changing the rules. On remand, the FCC should address the court’s concerns directly and explain why the cited studies and other record evidence do not warrant changes to its exposure limits.
II. The Remand Requires a Reasoned Explanation
Under the APA’s arbitrary-and-capricious standard, a reviewing court sets aside agency action that is “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.”[2] The agency must “examine the relevant data and articulate a satisfactory explanation for its action including a ‘rational connection between the facts found and the choice made.’” The court, however, may not “substitute its judgment for that of the agency.”[3] This standard requires agency action to be “reasonable and reasonably explained.” The court’s role is to ensure that the agency “has acted within a zone of reasonableness” by reasonably considering the relevant issues and explaining its decision.[4]
The D.C. Circuit recognized that two features of this case warrant especially deferential review. First, the Commission’s 2019 order was “akin to a refusal to initiate a rulemaking,” which receives a “high degree of deference.”[5] Second, the issues involve “highly technical determinations of the kind courts are ill-equipped to second-guess.”[6] When an agency exercises its “special expertise, at the frontiers of science,” judicial review “must generally be at its most deferential.”[7]
The Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, 603 U.S. 369 (2024), requires courts to exercise independent judgment when interpreting statutes. It does not displace deferential review of an agency’s scientific judgments. Congress expressly directed the FCC to “prescribe and make effective rules regarding the environmental effects of radio frequency emissions.”[8] Evaluating the scientific evidence falls within that assigned responsibility.
The court remanded the 2019 order without vacating it, leaving the existing rules in force. The FCC may reach the same result if it adequately explains its reasoning. On remand, an agency may offer “a fuller explanation of the agency’s reasoning at the time of the agency action” or “deal with the problem afresh” through new action.[9] The first option permits the agency to elaborate on its original reasons. New reasons require new agency action and compliance with the applicable procedural requirements.
The Commission need not establish that its standards are the best possible standards. Even when an agency changes policy, it “need not demonstrate to a court’s satisfaction that the reasons for the new policy are better than the reasons for the old one; it suffices that the new policy is permissible under the statute, that there are good reasons for it, and that the agency believes it to be better.”[10] The APA also “imposes no general obligation on agencies to conduct or commission their own empirical or statistical studies.” The agency may reasonably rely on the evidence before it.[11] When the science remains unsettled, the D.C. Circuit has upheld the FCC’s decision to “maintain a stance of what appears to be watchful waiting” because tentative studies did not establish risks sufficient to require action.[12]
Deference still requires a reasoned explanation. As Environmental Health Trust makes clear, conclusory statements and references to broad scientific assessments may leave important record evidence unanswered.[13] The FCC must therefore address the specific evidence the court identified, particularly the five studies cited by the majority.[14]
The Commission must also explain its own reasoning when relying on other expert agencies. It may credit the Food and Drug Administration (FDA) and other expert bodies, but it “may not . . . rely on an outside expert’s silence or conclusory statements in lieu of some reasoned explanation for its decision.”[15] When adopting an expert body’s conclusion, the FCC should explain how that body addressed the evidence at issue.
The record supports retaining the current RF exposure limits. The FCC can satisfy the remand by addressing the identified evidence directly and explaining why it does not establish harms that warrant changing those limits.
III. The Evidence on Children Does Not Warrant Stricter Limits
The record’s claims of harm to children rely largely on unvalidated exposure estimates, findings that lack consistent replication, and results the authors themselves describe as preliminary. Subsequent research has not supplied clear confirmation of those findings.
The most prominent child-specific submission the court cited was a letter from the American Academy of Pediatrics.[16] It argued that “[c]urrent FCC standards do not account for the unique vulnerability and use patterns specific to pregnant women and children.”[17] The letter offers a precautionary policy recommendation from a respected organization, but it identifies no study demonstrating harm to children from exposure below the FCC’s limits. It asks the Commission to give particular attention to vulnerable populations.
As the FCC explained, the standard cell phone compliance test accounts for children as well as adults.[18] On remand, the Commission should explain more fully how that testing protects vulnerable populations. It should also detail the FDA’s analysis and explain how that analysis supports the existing limits.
Some submissions question whether compliance testing adequately accounts for children. Om P. Gandhi et al. argue that the Specific Anthropomorphic Mannequin (SAM)—the model head used in testing—reflects a large adult head. They estimate that a 10-year-old’s specific absorption rate (SAR), a measure of absorbed RF energy, can exceed the SAM estimate by as much as 153%.[19]
That estimate does not establish harm to children. First, the study concerns energy absorption rather than health effects. Even accepting its estimates, a smaller margin below an exposure limit does not establish that exposure at or below that limit causes harm. Second, its computational models depend on assumptions about tissue properties and phone placement. Kenneth R. Foster and Chung-Kwang Chou, who reviewed the same literature, concluded that children do not systematically experience greater exposure.[20] Third, experiments using physical models of 3- and 8-year-old children’s heads found that SAM remained conservative—it provided a protective estimate of exposure for those models.[21]
The court also cited a study by Milena Foerster et al. as evidence the FCC had not adequately addressed.[22] The study followed roughly 670 Swiss adolescents for one year and associated higher estimated cumulative brain exposure from phone calls with lower scores for figural memory—the ability to remember visual patterns and shapes.
The FCC can reasonably find that this study does not warrant a rule change. The authors expressly cautioned that “[o]ur findings do not provide conclusive evidence of causal effects and should be interpreted with caution until confirmed in other populations.”[23] The association appeared for figural memory but not verbal memory. The authors also acknowledged studies reporting improved working memory with RF exposure.[24] Moreover, they estimated brain exposure from reported use, operator records, and phone models rather than measuring it directly.[25]
Although the FCC has limited this proceeding to the record before the court, later research provides additional context. A World Health Organization (WHO)-commissioned review pooled data from studies that followed children over time. It found little to no association between mobile phone use and learning and memory, executive function (skills used to plan and manage tasks), or complex attention. The reviewers rated the evidence as very low to low certainty.[26]
Research on prenatal exposure also warrants careful interpretation. A 2017 analysis pooled data on 83,884 mother-child pairs from five countries. It found a small association between maternal phone use and children’s hyperactivity and inattention, but no statistically significant association with overall behavioral problems. The authors cautioned that “[t]he interpretation of these results is unclear as uncontrolled confounding may influence both maternal cell phone use and child behavioral problems.”[27] In other words, other factors could account for the association.
A 2024 WHO review of human observational studies likewise found substantial uncertainty about RF exposure and female reproductive outcomes. The reviewers could not combine the studies of mobile phone exposure and congenital anomalies or miscarriage into pooled estimates.[28]
These limitations leave uncertainty, but they do not establish harm below the current limits. The APA requires the FCC to explain why the record does not warrant changing its rules. The child-specific studies do not reliably demonstrate such harm, and subsequent reviews have not supplied the confirmation needed to justify stricter limits.
IV. Long-Term Exposure Does Not Warrant Stricter Limits
The court directed the Commission to address “the health implications of long-term exposure to RF radiation.”[29] The FCC should begin by explaining why exposure duration alone does not undermine its limits. Those limits regulate energy absorption over specified averaging periods and aim to protect against continuous, indefinite exposure.[30] Tissue heating—the established mechanism of RF harm—depends on the balance between energy absorption and heat dissipation, rather than a lifetime accumulation of exposure.[31] Claims of long-term harm below the limits therefore require evidence of persistent or cumulative effects that those limits do not address, including possible nonthermal mechanisms. The cited studies do not reliably establish such effects.
One study directly at issue, by Henrietta Nittby et al., reported increased leakage of albumin, a blood protein, into rats’ brains seven days after a single two-hour exposure.[32] The finding warrants a response, but related experiments have produced contrary results. Jill M.S. McQuade et al. tested whether RF exposure increased albumin leakage across the blood-brain barrier—the tightly joined cells that help protect the brain—and found no significant increase under their experimental conditions.[33] The FCC should explain how the differences in experimental design and results affect the weight it assigns to Nittby’s findings.
Another cited review, by Igor Yakymenko et al., reported oxidative effects in 93 of 100 studies and argued that low-intensity RF exposure could cause oxidative stress, a cellular imbalance that can contribute to disease.[34] Judge Karen LeCraft Henderson identified two important limitations. The review defined “low-intensity” exposure against the International Commission on Non-Ionizing Radiation Protection’s higher standard, rather than the FCC’s lower limits, and it did not assess the quality of the studies it counted.[35]
Counting positive findings cannot establish harm below the FCC’s limits without examining study design, exposure measurements, and temperature controls. The review also did not establish how many studies involved exposures below those limits. A subsequent systematic review by Felix Meyer et al. assessed study quality and rated most of the evidence as low or very low certainty.[36] These limitations support retaining the existing limits while continuing to evaluate the research.
The court also cited the BioInitiative Report for evidence that low-level RF exposure damages human sperm and their DNA.[37] The report offers limited support for regulatory changes. Its authors self-published it, it is not a peer-reviewed systematic review, and it provides neither a reproducible search strategy nor a systematic assessment of study quality. Henderson observed that it “has been widely discredited as a biased review of the science.”[38]
Later WHO-commissioned reviews reinforce the need for caution in interpreting these claims. They rated evidence of adverse effects on human sperm exposed in laboratory conditions as low certainty. The review of human observational studies found no clear adverse effect on male fertility, with very low to low certainty.[39]
The roughly 200 commenters who attributed “radiation sickness” to chronic exposure also deserve a respectful response. Their symptoms may be real even when RF exposure does not explain them. A review of 46 blinded studies—experiments in which participants did not know when electromagnetic fields were present—found no robust evidence that exposure triggered symptoms in people reporting electromagnetic sensitivity. The studies instead supported a role for perceived exposure and expectations of harm in triggering acute symptoms.[40]
The FCC should explain these findings and their limits directly. Some cited research does not establish effects below the Commission’s exposure limits, other findings lack consistent replication, and later reviews continue to identify substantial uncertainty. Taken together, the evidence supports retaining the current limits while monitoring research on long-term exposure.
V. Environmental Evidence Does Not Warrant Stricter Limits
The court’s environmental holding was narrow. The FCC “should have said something about its sister agency’s view rather than ignore it altogether.” The court expressly allowed the Commission to conclude that “the link between RF radiation and environmental harms is too weak to warrant an amendment to its RF radiation limits.”[41] The record supports that conclusion.
The court focused on the Department of the Interior’s 2014 letter to the National Telecommunications and Information Administration. The letter criticized the FCC’s reliance on tissue heating as “a criterion now nearly 30 years out of date and inapplicable today.”[42] Yet it also acknowledged a substantial evidentiary gap. “[T]o date, no independent, third-party field studies have been conducted in North America on impacts of tower electromagnetic radiation on migratory birds.”[43] Its principal concerns about communications towers involved bird collisions with towers and guy wires, and the effects of lighting. The FCC addresses those physical hazards through its antenna-structure and lighting rules.[44]
The Commission should also acknowledge the limits of human exposure standards. Its rules protect people, and international standards do not establish wildlife-specific limits. Birds and insects can enter areas inaccessible to the public, including directly in front of base station antennas.
That possibility warrants consideration, but it does not itself establish a need for stricter limits. Even evidence of risk to individual animals would leave a separate question about effects on wildlife populations. The record provides no reliable basis for concluding that these exposures cause population-level harm. The FCC should explain the evidentiary gaps, assess any expected benefits of tighter limits against their costs, and commit to coordinating future research with the U.S. Fish and Wildlife Service.
A particularly rigorous study by Svenja Engels et al. illustrates the distinction between a biological response and demonstrated environmental harm.[45] In double-blinded experiments at the University of Oldenburg, European robins lost their ability to orient using Earth’s magnetic field amid urban electromagnetic noise. Their orientation returned when screening reduced noise between 50 kilohertz (kHz) and 5 megahertz (MHz).
Three limitations matter for this proceeding. First, the experiments concerned broadband noise at roughly 2 kHz to 5 MHz, a range that includes AM radio and unintentional emissions from everyday electronics. They did not test the much higher frequencies—commonly 600 MHz and above—used by cellular networks, Wi-Fi, and 5G wireless services. The FCC should distinguish its Part 15 controls on unintentional emissions from its RF exposure limits when explaining the study’s regulatory implications.
Second, the study measured caged birds’ orientation in an expected migratory direction. It did not measure injury, mortality, or population effects. Nor did it test the sun and stars, which provide other navigational cues for migrating birds.
Third, birds oriented normally without screening at sites one to two kilometers outside the city. That finding suggests a localized effect under the tested conditions, rather than establishing harm to migratory birds generally. The study demonstrates that a specialized sensory system can respond to extremely weak fields. It does not establish that the FCC’s exposure limits fail to protect wildlife.
Broader reviews reinforce the need to distinguish uncertainty from demonstrated harm. The FCC cites an environmental review by the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA). In that work, Australian government scientists screened more than 24,000 articles and identified 334 relevant studies of RF effects on animals and plants. The vast majority involved laboratory experiments rather than field observations.[46] A follow-up analysis found that study quality predicted effect size better than exposure level or duration.[47] The authors emphasized the shortage of high-quality studies and the need for further research, particularly at 5G frequencies.
A 2019 review by Adam J. Vanbergen et al. reached a similarly cautious conclusion about pollinators. It characterized knowledge of risks from human-generated electromagnetic radiation as “inconclusive, unresolved, or only partly established.” Robust evidence of RF effects on pollinator abundance or diversity came from a single study that reported both positive and negative effects, depending on the pollinator group and location.[48]
These findings support further research and a clear explanation of the existing record. They do not establish an environmental benefit from stricter RF exposure limits.
VI. Conclusion
The D.C. Circuit required a fuller explanation of the FCC’s decision, leaving the Commission free to retain its RF exposure limits with adequate justification. Across the remanded issues—children’s health, long-term exposure, and environmental effects—the cited studies have important limits. Modeled absorption does not establish health harm, preliminary findings require confirmation, and biological responses do not necessarily demonstrate adverse health or population effects. Later reviews continue to identify substantial uncertainty.
The FCC should address the evidence the court identified, explain its reasoning, and show how the expert assessments it credits account for that evidence. It should also acknowledge gaps in the research, respond respectfully to public concerns, and commit to continued monitoring and coordination with other expert agencies.
A thorough explanation can satisfy the remand while preserving standards the evidence supports. Changes to those standards should rest on demonstrated risks and expected benefits sufficient to justify their costs to wireless networks and the consumers who rely on them.
[1] Reassessment of Federal Communications Commission Radiofrequency Exposure Limits and Policies, ET Docket No. 13-84, Public Notice, DA 26-997 (Sept. 17, 2026), https://docs.fcc.gov/public/attachments/DA-26-997A1.pdf.
[2] 5 U.S.C. § 706(2)(A).
[3] Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983).
[4] FCC v. Prometheus Radio Project, 592 U.S. 414, 423 (2021).
[5] Env’t Health Tr. v. FCC, 9 F.4th 893, 903 (D.C. Cir. 2021) (citing Am. Horse Prot. Ass’n v. Lyng, 812 F.2d 1, 4–5 (D.C. Cir. 1987)).
[6] Id.
[7] Balt. Gas & Elec. Co. v. Nat. Res. Def. Council, Inc., 462 U.S. 87, 103 (1983).
[8] Telecommunications Act of 1996, Pub. L. No. 104-104, § 704(b), 110 Stat. 56, 152 (directing the Commission to “prescribe and make effective rules regarding the environmental effects of radio frequency emissions” within 180 days).
[9] Dep’t of Homeland Sec. v. Regents of the Univ. of Cal., 591 U.S. 1, 20–21 (2020).
[10] FCC v. Fox Television Stations, Inc., 556 U.S. 502, 515 (2009).
[11] FCC v. Prometheus Radio Project, 592 U.S. 414, 427 (2021).
[12] EMR Network v. FCC, 391 F.3d 269, 274 (D.C. Cir. 2004).
[13] Env’t Health Tr. v. FCC, 9 F.4th 893, 903 (D.C. Cir. 2021).
[14] Id. at 903–04.
[15] Id. at 905.
[16] Letter from Thomas K. McInerny, President, Am. Acad. of Pediatrics, to Mignon L. Clyburn, Acting Chairwoman, FCC, & Margaret A. Hamburg, Comm’r, FDA, ET Docket No. 13-84 (Aug. 29, 2013), https://www.fcc.gov/ecfs/document/6017465568/1.
[17] Id. at 1.
[18] Proposed Changes in the Commission’s Rules Regarding Human Exposure to Radiofrequency Electromagnetic Fields; Reassessment of Federal Communications Commission Radiofrequency Exposure Limits and Policies, ET Docket Nos. 03-137, 13-84 & 19-226, Resolution of Notice of Inquiry, Second Report and Order, Notice of Proposed Rulemaking, and Memorandum Opinion and Order, 34 FCC Rcd. 11687, 11696 (2019), https://docs.fcc.gov/public/attachments/FCC-19-126A1_Rcd.pdf.
[19] Om P. Gandhi et al., Exposure Limits: The Underestimation of Absorbed Cell Phone Radiation, Especially in Children, 31 Electromagnetic Biology & Med. 34 (2012), https://pubmed.ncbi.nlm.nih.gov/21999884.
[20] Kenneth R. Foster & Chung-Kwang Chou, Are Children More Exposed to Radio Frequency Energy from Mobile Phones than Adults?, 2 IEEE Access 1497 (2014), https://ieeexplore.ieee.org/document/6982034.
[21] Marie-Christine Gosselin et al., Experimental Evaluation of the SAR Induced in Head Phantoms of Three- and Eight-Year-Old Children, E95-B IEICE Trans. Commc’ns 3215 (2012), https://www.jstage.jst.go.jp/article/transcom/E95.B/10/E95.B_3215/_article.
[22] Milena Foerster et al., A Prospective Cohort Study of Adolescents’ Memory Performance and Individual Brain Dose of Microwave Radiation from Wireless Communication, 126 Env’t Health Persps. 077007 (2018), https://pubs.acs.org/evhpaz/article-pdf/doi/10.1289/EHP2427/66406634/ehp2427.pdf.
[23] Id. at 077007-12.
[24] Id. at 077007-11.
[25] Id.
[26] Geza Benke et al., The Effects of Radiofrequency Exposure on Cognition: A Systematic Review and Meta-Analysis of Human Observational Studies, 188 Env’t Int’l 108779 (2024), https://pubmed.ncbi.nlm.nih.gov/38821015.
[27] Laura Birks et al., Maternal Cell Phone Use During Pregnancy and Child Behavioral Problems in Five Birth Cohorts, 104 Env’t Int’l 122 (2017), https://pmc.ncbi.nlm.nih.gov/articles/PMC5506372.
[28] Eugenie Evelynne Johnson et al., The Effects of Radiofrequency Exposure on Adverse Female Reproductive Outcomes: A Systematic Review of Human Observational Studies with Dose-Response Meta-Analysis, 190 Env’t Int’l 108816 (2024), https://pubmed.ncbi.nlm.nih.gov/38880062.
[29] Env’t Health Tr. v. FCC, 9 F.4th 893, 914 (D.C. Cir. 2021).
[30] See 47 C.F.R. § 1.1310(c), (e)(1) tbl. 1 (2025) (setting specific absorption rate and maximum permissible exposure limits, with a 30-minute averaging period for general population/uncontrolled exposure).
[31] See Off. of Eng’g & Tech., FCC, OET Bulletin No. 56, Questions and Answers About Biological Effects and Potential Hazards of Radiofrequency Electromagnetic Fields 6–7, 14 (4th ed. Aug. 1999), https://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet56/oet56e4.pdf.
[32] Henrietta Nittby et al., Increased Blood–Brain Barrier Permeability in Mammalian Brain 7 Days After Exposure to the Radiation from a GSM-900 Mobile Phone, 16 Pathophysiology 103 (2009), https://pubmed.ncbi.nlm.nih.gov/19345073.
[33] See Jill M.S. McQuade et al., Radiofrequency-Radiation Exposure Does Not Induce Detectable Leakage of Albumin Across the Blood-Brain Barrier, 171 Radiation Rsch. 615 (2009), https://pubmed.ncbi.nlm.nih.gov/19580497.
[34] Igor Yakymenko et al., Oxidative Mechanisms of Biological Activity of Low-Intensity Radiofrequency Radiation, 35 Electromagnetic Biology & Med. 186 (2016), https://pubmed.ncbi.nlm.nih.gov/26151230.
[35] Env’t Health Tr. v. FCC, 9 F.4th 893, 915–16 (D.C. Cir. 2021) (Henderson, J., dissenting in part).
[36] See Felix Meyer et al., The Effects of Radiofrequency Electromagnetic Field Exposure on Biomarkers of Oxidative Stress In Vivo and In Vitro: A Systematic Review of Experimental Studies, 194 Env’t Int’l 108940 (2024), https://pubmed.ncbi.nlm.nih.gov/39566441 (rating most evidence of RF-induced oxidative stress as low or very low certainty).
[37] BioInitiative Working Grp., BioInitiative 2012: A Rationale for Biologically-Based Exposure Standards for Low-Intensity Electromagnetic Radiation (Cindy Sage & David O. Carpenter eds., Dec. 31, 2012), https://www.infrastructure.gov.au/sites/default/files/submissions/BioInitiative_Working_Group.pdf.
[38] Env’t Health Tr., 9 F.4th at 916 n.3 (Henderson, J., dissenting in part).
[39] See Eugenia Cordelli et al., Effects of Radiofrequency Electromagnetic Field (RF-EMF) Exposure on Male Fertility: A Systematic Review of Experimental Studies on Non-Human Mammals and Human Sperm In Vitro, 185 Env’t Int’l 108509 (2024), https://pubmed.ncbi.nlm.nih.gov/38492496 (rating evidence of adverse effects on human sperm exposed in vitro as low certainty); Robert P.W. Kenny et al., The Effects of Radiofrequency Exposure on Male Fertility: A Systematic Review of Human Observational Studies with Dose-Response Meta-Analysis, 190 Env’t Int’l 108817 (2024), https://pubmed.ncbi.nlm.nih.gov/38880061 (finding no clear adverse effect on male fertility, with very low to low certainty).
[40] G. James Rubin et al., Idiopathic Environmental Intolerance Attributed to Electromagnetic Fields (Formerly “Electromagnetic Hypersensitivity”): An Updated Systematic Review of Provocation Studies, 31 Bioelectromagnetics 1 (2010), https://pubmed.ncbi.nlm.nih.gov/19681059.
[41] Env’t Health Tr., 9 F.4th at 910.
[42] Letter from Willie R. Taylor, Dir., Off. of Env’t Pol’y & Compliance, U.S. Dep’t of the Interior, to Eli Veenendaal, Nat’l Telecomm. & Info. Admin., U.S. Dep’t of Com. (Feb. 7, 2014), https://www.ntia.doc.gov/files/ntia/us_doi_comments.pdf.
[43] Id. at 4.
[44] See 47 C.F.R. pt. 17 (2025) (governing antenna-structure construction, marking, and lighting).
[45] Svenja Engels et al., Anthropogenic Electromagnetic Noise Disrupts Magnetic Compass Orientation in a Migratory Bird, 509 Nature 353 (2014), https://pubmed.ncbi.nlm.nih.gov/24805233.
[46] Ken Karipidis et al., What Evidence Exists on the Impact of Anthropogenic Radiofrequency Electromagnetic Fields on Animals and Plants in the Environment: A Systematic Map, 12 Env’t Evid. 9 (2023), https://pmc.ncbi.nlm.nih.gov/articles/PMC11378816 (identifying 334 relevant studies among 24,432 articles and reporting that the vast majority of included studies involved laboratory experiments).
[47] Chris Brzozek et al., Investigating the Impact of Anthropogenic Radiofrequency Electromagnetic Fields on Animals and Plants in the Environment: Analysis from a Systematic Map, 81 Int’l J. Env’t Stud. 2343 (2024), https://www.tandfonline.com/doi/full/10.1080/00207233.2024.2375861#d1e2244 (finding that study quality better predicts effect size than exposure level or duration).
[48] Adam J. Vanbergen et al., Risk to Pollinators from Anthropogenic Electro-Magnetic Radiation (EMR): Evidence and Knowledge Gaps, 695 Sci. Total Env’t 133833 (2019).