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Responding to the FCC 19-226

April, 2020

Issue #2: The FCC is considering allowing manufacturers to average the radiation output of consumer devices over time.

Synopsis of Paragraphs 131-135 - Current FCC human exposure limits allow for averaging exposure over time ("time-averaging") for devices not controlled by the user. Now manufacturers want to be able to "time-average" the bursts of radiation from consumer devices. They claim that current rules constrain their ability to offer "increased data capacity for consumer devices," particularly for devices used close to the body such as notebooks and tablets. 

Manufacturers are claiming that they will build in the capability for the device itself to measure and regulate its own radiation output. They call this "device-based-time-averaging." 


Currently, consumer devices are tested at a certain distance from the body over a period of time. The FCC asks how manufacturers will guarantee that these new devices will actually work as claimed, and how they should be tested.  The FCC seeks comment on the "range and type of parameters that need consideration."

Our Analysis: Averaging exposures over time may allow manufacturers to comply with FCC limits, but this practice assumes that periodic high-level exposures are not harmful. To our knowledge, there is no scientific basis for this claim; anecdotal information suggests quite the opposite is true.  As one scientist remarked recently, the average wind speed in Tornado Alley is 6 miles per hour. 

An example of how averaging can be deceptive is smart utility meters, which can emit very high, periodic bursts of radiation. When those bursts are averaged over time, their impact is hidden. 


There is quite a bit of evidence that a brief but intense exposure can trigger electromagnetic hypersensitivity (EHS) that can last for years, but more research is needed regarding the impact of these high episodic exposures before any conclusions can be drawn. 


In this section, manufacturers are seeking the ability to have devices periodically exceed FCC limits if the devices themselves monitor their radiation output and automatically "power up" or "power down" to meet FCC limits.

The FCC also seeks comment on how these devices should be tested. This is an opportunity to discuss how the FCC needs to test wireless devices in lab settings that reflect real-world circumstances. 

Sample Comment: I do not support the proposed change to allow manufacturers to produce wireless devices that govern their own radiation power output, especially for notebooks and tablets frequently used by children who, according to the International Agency for Research on Cancer (IARC), are more vulnerable to RF radiation than adults.

Since the justification for this proposed rule change is that manufacturers want to be able to deliver more data to notebooks and tablets, it seems obvious that this change would result in higher exposures for users.

I object to the practice of allowing exposures to be averaged over time to comply with FCC exposure limits. There is no scientific basis to support the notion that short, periodic bursts of RF radiation are not biologically harmful, or that only cumulative effects over time may have an impact. The FCC should establish temporal limits for both Specific Absorption Rate (SAR) and power density.

Further, I agree with the American Academy of Pediatrics that the FCC's current method of testing wireless devices is not reflective of the way people actually use technology today. Given the increasing use of wireless devices by children and adolescents, we encourage the FCC to seek out and utilize testing protocols that reflect real-world situations. 

Insert any comment here about a personal situation regarding periodic high levels of exposure and any adverse effects experienced following such exposure.  If you include links to scientific studies please state the following: “Links hereby incorporated by reference” to ensure that the study becomes a part of the record. To submit a PDF of the study itself, please use the standard comment form that allows attachments to be uploaded along with your comment, not the Express comment form.

Ready to send your comment to the FCC? Click here for more information about how to submit your comment. 

If you know of a medical, public health or telecommunications professional we should contact about submitting expert comments, please send their name and email address to Thanks!