2.01 What can we do as a Council? 

•You can lobby to apply safety criteria that exceed ICNIRP guidelines in this case, as you do in many other instances as a council.  

•RF EMRs are shown to be a biological hazard, and therefore ALL the scientific studies and evidence must be considered when evaluating Harm that could be caused to the Environment and Public.

The harmful biological effects of EMR are fully established and cannot be defined at any exposure level to be sufficiently safe in a public setting. The harm caused is a zero-threshold process. It is unlawful and unethical to install infrastructure that causes harm.

  • You can:  lobby to prevent further upgrades until there is safe technology – to protect your wide remit for Duty of Care. Particularly it is not too late to halt mmWave 5G.
  • You can: refuse test beds in your area
  • You can: if you are a Borough or District Council you can make a Public Declaration, and call a moratorium on any further installation of harmful tech and that you will prioritise wired broadband
  • You can: question the NPPF para 116 since its directive directly conflicts with para 180, and your other legal obligations.
  • You can: reply to government Telecoms consultations demanding tighter regulation of the levels of radiating power from wireless telecom facilities (WTFs), exposure levels, and monitoring of hot spots from multiple sources.
  • You can: issue a “Non-Compliance Report” against ISO Standards: ISO 9001 (Quality) or the
    equivalent TL 9000, ISO 14001 (Environment) and ISO 18001 (Health and Safety).  See 2.13

2.02 The NPPF para 116 requires us not to consider health impacts when assessing new applications.

•Para 116 does not state that the local council cannot take health concerns into account.  It merely states that it cannot set health safeguardsdifferent from the ICNIRP.  ICNIRP’s guidelines may provide for a certain safe level of exposure, but it says nothing about the harm which is being done to residents at levels below these limits.  

•From the information enclosed you will see that there is harm to residents at levels below ICNIRP’s guidelines.  Health IS a planning consideration and if residents are telling you that they are sick from radiation sickness or fear such sickness, this is relevant information which you can take account of and raise an objection or refuse planning permission on that basis.  You do not need to set different exposure levels but you can reject the efficacy of those advised, to protect environmental and public health.

• Reliance upon paragraph 116 NPPF policy as being sufficiently protective of public safety, and for the purposes of addressing broader environmental protection concerns evidenced by the submission of the applicant’s ICNIRP certificate will not suffice as taking properly into account the polluting effects of RFR emissions.

Para 180: Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development. Etc.

All public objections made on health or environmental public health concerns regarding the siting of a telecommunications installation must be addressed as evidence of ‘incompatible or unacceptable use’ of the land/building upon which it is intended to be deployed, and the Council’s Director of Public Health and/or an Environmental Health Officer, or another relevant professional, must be engaged to assess the evidence of the polluting effects of RFR exposure against the applicant’s ICNIRP certificate.

Such an assessment is an essential prerequisite to your Officers making a determination on an application on siting grounds, as paragraph 116 and paragraph 180 of the NPPF are in conflict with each other.  How this ‘incompatible or unacceptable use’ category material planning consideration relevant to this application is determined in the public interest must be accepted by your Authority as decisive.

•The NPPF also states that authorities must use the best available evidence when carrying out assessments. (see also 2.07)

2.03 There is still a debate about the science though.

There is only a manufactured debate. There is sufficient knowledge gathered over the last 80 years about the fact of, and reasons for, damage to living systems caused by RFR. The mechanisms and causes of damage are also well known now. See appendix 4.0, 5.0.  


2.04 But sunlight doesn’t harm us in this way so why should ‘non-ionising’ waves?

Sunlight is naturally un-polarised and consists of a complete packet of informational and organizational fields.  Man-made EMR (electromagnetic radiation) is not.  We have also evolved in an environment where background levels below THz were practically zero.  

The alterations caused to biological mechanisms are seen to be detrimental to proper cell function and cause a cascade of functional and therefore health issues.  Explained in the first paragraph of this paper:


For one example of how the effects of man-made pulsed EMR have been understood refer to this patent which resolved an issue faced by the US army in the Iraq war where their soldiers were being harmed by WiFi equipment in their helmets:

Diagram of Biological Trigger mechanism related to US patent 5544665A.



2.05 It is normal for a risk-benefit analysis to be done in many daily tasks, and in this case the risks seem way smaller than the benefits the tech offers

•The analysis needs to be made from a fully informed position, you will find if you weigh up all the evidence for biological harm, from 1000’s of studies, that harm is caused at exposure levels down to at least 0.05 V/m, and compare that to the fact that the environmental levels and those within buildings from WiFi also exceed this low level by 100s of times.  

•The effects are multifarious, have long latency and affect different people in many different ways, the one size fits all approach is to have zero to minimal exposure.  We all without exception are affected by this radiation, but we all have different tolerances. Electro Sensitive people are like the canaries in the coalmine, they feel what is happening, and also their needs should not be ignored.

•It is normal for a risk-benefit analysis to be done and to use the ALARA principle to define exposure levels.  The problem is that the current situation takes no account at all of the real risks, a re-balance is urgently needed.

•It is crucial that we focus on safer alternatives such as conventional or new plastic fibre-optic broadband.

Public Health England now recommends that we reduce our exposure to mobile phones, ‘due to uncertainties in the science’, because they are not safe. When something is not safe then the hazard must be recognised in all situations, we cannot make general prescriptions that fall short of removal of the hazard, or mitigation to levels that have meet with a general consensus of agreement.  This cannot be claimed where up to 70% of independent studies show that low level NIR is harmful. 


2.06  ICNIRP and PHE  say the available scientific evidence (for non thermal biological effects) is not sufficiently robust or compelling

This begs the question, “what does constitute robust, consistent or compelling” evidence? Especially when the US federal govt spends $25m on a 10 year study that finds clear evidence at below thermal of a link with cancer? [NTP study] What kind of research would ICNIRP accept that would move them away from their obsession with heating???

It is also notable that two former ICNIRP members, Dr Andrew Miller and Dr Lin both think that NTP, and Ramazzini Institute studies are compelling, and have called for the WHO to consider re-classifying RF radiation as a Class 1 carcinogen.

2.07 “The ICNIRP guideline exposure levels are what PHE say are safe and are what we must rely on, so as a Council we cannot set different criteria.”

Section 2A of the Public Health Act provides the legal basis on which PHE currently issues information and advice as part of its general duty to protect the general public from disease and other dangers to health. The Guidance is not maintained and revised by PHE for the explicit purpose of any other body undertaking any other statutory function. If in any other context regard is had to the Guidance, that is entirely a matter for the discretion of the relevant body and it must determine what weight to place on the Guidance given the clear indication as to the sources from which the advice and recommendations in the Guidance are derived. Equally, that body must determine what other evidence from your clients or other members of the public or interested parties to consider in making any decision.”

• Public Health England solicitors state: If it be alleged that a public body now or in the future acted unlawfully in placing reliance on the guidance, that cannot retrospectively taint the guidance with illegality”. 8 August 2019

The above statement from the solicitors to PHE unequivocally asserts that public bodies should balance PHE’s guidance with other sources of evidence i.e. that they should indeed question that guidance. 

•ICNIRP, on whom PHE solely rely, also have a legal disclaimer regarding their Guidelines on their website:

“The ICNIRP undertakes all reasonable measures to ensure the reliability of information presented on the website, but does not guarantee the correctness, reliability, or completeness of the information and views published. The content of our website is provided to you for information only. We do not assume any responsibility for any damage, including direct or indirect loss suffered by users or third parties in connection with the use of our website and/or the information it contains, including for the use or the interpretation of any technical data, recommendations, or specifications available on our website” 

•The ICNIRP guidelines (2002) require you to make a balanced judgement regarding health effects. 

Page 9 Nature of Health Effects: “People being protected: Different groups in a population may have differences in their ability to tolerate a particular NIR exposure.  … Exposure to NIR may cause different biological effects, with a variety of consequences for a human being. Biological effects may be without any known adverse or beneficial consequences, other effects may result in pathological conditions (diseases), while still other biological effects have beneficial consequences for a person. Annoyance or discomfort may not be pathological per se but, if substantiated, can affect the physical and mental well-being of a person and the resultant effect should be considered as a potential health hazard. ….Because adverse consequences of NIR exposure can vary across the entire range from trivial to life threatening, a balanced judgement is required before deciding on exposure guidance.”

Safe RF exposure levels: organizations reflexively quote ICNIRP guidelines to justify all RF exposure (mirrored by Public Health England). These guides are irrelevant to long term public exposure, the ICNIRP advised maximum exposure levels are peak 56 V/m, but were defined for totally different conditions, only thermal effects, and in 1998. Whereas international long-term biological guidelines, based on scientific evidence and to protect health, include:  Seletun 2010, Bioiniative 2012, EUROPAEM 2016 and IGNIR 2018. 

  • ICNIRP guidelines are only for short term exposure to a mobile phone for 6-30 mins, and are therefore completely inadequate considering the variety of emissions we’re exposed to today.
  • International long-term biological guidelines: 0.006-0.2 V/m (0.1-100 μW/m2)
  • In many public areas and streets in the UK the levels are now around 3 V/m on a constant basis, this is not acceptable and contravenes your statutory Duty of Care.

In a letter dated July 2002 from the US Environmental Protection Agency, to the President of the EMR network.  The EPA stated that “the FCCs current exposure guidelines do not apply to chronic non-thermal exposure situations. They are considered protective of effects arising from a thermal mechanism, but NOT from all possible mechanisms. Therefore the generalization by many that the guidelines protect human beings from harm by any or all mechanisms is not justified.”

Most authorities now reject the UK government’s heating-only claim and argue for adopting biological limits. The USSR adopted biological limits in 1958 and an increasing number of countries have done so since, most recently India in 2013. Since 2008 the majority of involved scientists have accepted non-thermal effects. In 2009 the EU parliament voted that current heating-only limits were “obsolete” and new biological limits were needed. In 2011 the Council of Europe warned governments against WiFi in schools. The international BioInitiative Report of 2012 by 29 experts proposed new biological limits, as did the Seletun panel in 2010. The UK government has not yet accepted this majority scientific viewpoint based on the weight of established evidence.  See Appendix 2-4

The Council of Europe passed the draft Resolution 1815 in which they voted unanimously to ban Wi-Fi and mobile phones in schools and that on 27th May 2011 the Parliamentary Assembly of the Council of Europe called on Member States to reduce exposure to radiofrequency electromagnetic fields, asking for particular attention to be given to children and young people, who are most at risk, and called for restrictions on the use of wireless technologies (Wi-Fi) in schools with a clearly stated recommendation for fully-wired networks to be used. 

The Institute of Electrical and Electronics Engineers (IEEE) which helped to set existing exposure limits decades ago acknowledges these are not protective and the public should take precautionary measures now while public policy catches up to the science.

Long term effects/non-thermal effects: ICNIRP guidelines contain inadequacies regarding long term effects, and with regard to effects seen at low exposures below those which are referenced in the guidelines criteria for thermal effects. 

Carpenter DO, Hardell L, Moskowitz JM, Oberfeld G. The EMF Call for truly protective limits for exposure to electromagnetic fields (100 kHz to 300 GHz).

The authors, academic and public-health physicians, argue that ICNIRP’s limits are “unscientific, obsolete and do not represent an objective evaluation”; they “only protect against acute thermal effects from very short and intense exposure”, not against “harmful effects from low-intensity and long-term exposure, such as cancer, reproductive harm, or effects on the nervous system.” 


2.08 Anti 5G opinions would like to have it both ways.

On one hand they claim that 5G was not tested for its health impact on humans. Meaning, there are no studies available to prove its safety. But then, they claim that 5G is dangerous and proven to damage human health (Pall, Firstenberg, Davis et al.) Which is true ?

The industry are lying, they have done tests, but state that they plan to do no further tests. The industry agent who testified before Congress in Feb 2019 said that they had done no tests, and none were being planned, so he was half truthful.  For one there was Jerry Phillips’ cellular study, commissioned by Motorola, 1997. They also deny that there is reputable or sufficient evidence of harm. This is also a lie.  

There are 1000’s of military and non-industry studies since 1888. (See Appendix 4.0)

What 5G frequencies do they mean when referring to 5G?  Those well below 6 GHz, that were used already and are known to possibly/probably affect health, though the proof of health damage is still elusive?  Or are they talking about 26 GHz and 28 GHz and other frequencies over the 30 GHz (mmWaves) that were not studied?

The proof of health effects is not elusive, there are 1000’s of peer reviewed papers – enough to establish harm and the need to minimise exposure and cause liability if not.  The biological trigger is known to occur at ANY frequency and at any dose, with an unpredictable result each time since the transfer from physical to biological effects is non linear.  So, there is harm from any ‘G’.

5G is both sub 6GHz which is much of the existing spectrum being used, and cm and mmWave above 6GHz which is probably even more damaging considering the wavelength is closer to a physical match with our biological features.

All of this increase in exposure is a step too far in aggregate considering the unacceptably high levels already present in our homes and high streets. 

4G-5G Microwave Radiation imposes serious Privacy, Security, Health, Safety and Environmental problems that must immediately be remedied.