I am writing as a private citizen regarding ET Docket No. 13-84 and the Commission's response to the D.C.…

I am writing as a private citizen regarding ET Docket No. 13-84 and the Commission's response to the D.C. Circuit's remand in Environmental Health Trust v. FCC, No. 20-1025 (D.C. Cir. 2021). The court remanded for the Commission to provide a reasoned explanation for its determination that its guidelines adequately protect against harmful effects of RF radiation unrelated to cancer, and directed it specifically to address its testing procedures for cell phones and other portable devices, the impacts of RF radiation on children, the health implications of long-term exposure, the ubiquity of wireless devices and technological developments since the guidelines were last updated, and environmental effects. That mandate issued in October 2021. Nearly five years passed before this record was reopened. The delay is itself part of what the Commission should account for. The scale of what is being decided. The guidelines at issue were set in 1996. In the three decades since, wireless exposure has gone from occasional and voluntary to continuous, ambient, and involuntary. Nearly every person in the country is now exposed, in every room they occupy, from birth, with no practical ability to opt out. Because FCC limits and FCC device certification shape international practice and because US-certified handsets are sold worldwide, the reasoning the Commission puts on this record does not stay domestic. The Commission is not choosing between acting and waiting. The exposure is already universal and expands by default while the question remains open. Continuing without a reasoned explanation is itself a decision, and it is the one the court found inadequate. On children, specifically. This is where the Commission's position is weakest, and where the consequences of being wrong are least recoverable. SAR compliance testing relies on a standardized head phantom derived from adult male anthropometry. Children differ in head size, skull thickness, tissue dielectric properties, and the proximity of developing tissue to the device. The Commission has not explained why a model built on adults adequately represents them. More fundamentally: a child born today will accumulate RF exposure continuously from infancy across a full lifespan. No epidemiological cohort of that kind exists, because no such population has yet lived long enough to be studied. The reassurance drawn from existing studies of adult mobile phone users does not transfer to that exposure profile — not because those studies are wrong, but because they did not examine it and could not have. The Commission should say plainly whether it is treating the absence of such evidence as evidence of adequacy. If it is, the court's remand is not satisfied. If it is not, it should state what would satisfy it, and on what timeline. On device testing procedures. Under 47 CFR § 2.1093(d)(2) and OET guidance in KDB 447498, portable devices are certified for body-worn operation at a manufacturer-specified separation distance. Actual use does not match that condition. Phones are carried in pockets, held against the body, and used in skin contact for hours daily — and by children, whose use patterns the certification regime never contemplated. Independent regulator testing, including measurements by France's Agence nationale des fréquences, has found handsets exceeding applicable limits at zero separation. This is a bounded, testable question and the court identified it first. The Commission should either justify the protocol against documented use or revise it. On institutional expertise. The Commission's 2019 order relied substantially on the Food and Drug Administration, including the April 24, 2019 letter from the Director of the Center for Devices and Radiological Health. Deference to a health agency is appropriate — the Commission is not a health agency and holds no expertise in biology, toxicology, or pediatric development. But deference is not the reasoned explanation the court required. The Commission should state which specific remanded questions federal health authorities have actually evaluated, on what record, and when. Where they have not addressed a question, the Commission should say so rather than treat silence as endorsement. Given the concurrent request for information issued by the Department of Health and Human Services, the Commission should coordinate with HHS, incorporate its evidence assessment into this docket, and explain how that assessment informs its conclusions. Neither agency should be able to defer to the other while the exposure continues to expand. I have three children. They did not choose this exposure, they cannot avoid it, and they will carry it for a lifetime under a standard written before any of them were born and before the technology that now surrounds them existed. I am not asking the Commission to conclude that harm has been proven. I am asking it to do what the court ordered: address each of these questions on its merits, state clearly which it is answering and which it is deferring, and put its actual reasoning on the record.