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‘Proposed reforms to the National Planning Policy Framework and other changes to the planning system’  

Scope of government consultation: ”The Ministry of Housing, Communities and Local Government is seeking views on how we might revise national planning policy to support our wider objectives. Full details on the scope of consultation are found within Chapter 1. In responding to this consultation, we would appreciate comments on any potential impacts on protected groups under the Public Sector Equality Duty.“

Our response below (main authors Karen Churchill, Neil McDougall) describes why changes to the current NPPF are needed, under the PSED, and sets out our suggestions arising from campaign experience.

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ACTION –  RESPOND TO THE NPPF CONSULTATION

Option 1 If time is short and you do not have time to compose your own response please EMAIL THIS STATEMENT to: PlanningPolicyConsultation@communities.gov.uk

“I am not the Author of this document but fully support its content, and request your careful consideration. Policy 121/122 needs to be brought into alignment with European Electronics Communications Code legal obligations and include all matters identified in Appendix 2 of the EECC submission. ‘ https://safetechinternational.org/wp-content/uploads/2023/09/EECCsubmission12-9-2023-info-version.pdf

Policy guidance must reflect an inclusion of those with Electrohypersensitvity and those with metal implants include hearing aids, pace-makers, joint replacements, dental fillings etc under the  ‘Public Sector Equality Duty. Thank you.’’

OR, Option 1 A, if you have more time, please refer to the content of the document and answer the questions online by RESPONDING TO THE NPPF CONSULTATION ONLINE:

https://consult.communities.gov.uk/planning/planning-reform

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Option 2 email to your Council officers,

Dear Cllr/Planning office etc ,

I am writing to you about the opportunity to respond to the open consultation regarding changes to the National Planning Policy Framework.

Whilst the consultation does not propose changes to Section 10 re: Telecommunications specifically, the attached Submission explains why changes to Policy paragraphs 121 and 122 are urgently needed.

If time is short please refer to the Index, and Submission Sections 1) Introduction, 8) Summary & 10) iii) NOTES legal background.

The government has ‘adopted’ the ICNIRP exposure guidelines, but the application of these guidelines is not being fulfilled at the planning stage because of misleading wording in policy paragraphs 121 and 122. Telecoms self-certification is failing, so for this reason alone, policy wording needs changing.

I appeal to you to respond to the consultation to protect those who are being condemned to living inside radiation exclusion zones.

Contradictions in how different Councils are processing applications are highlighted in Section 5) ii) INCONSISTENCIES. These inconsistencies need to be resolved to safeguard Local Councils from judicial reviews.

Regarding the Public Sector Equality Duty, which is a focus of the consultation, it is imperative that those with Electrohypersensitvity (EHS) are protected by their vulnerabilities being accommodated within Policy.

If time is short, as a minimum,

EMAIL 

‘Policy paragraphs 121/122 need reforming to clarify procedures so that the ICNIRP guideline is applied and valid certificates are always processed with applications’.

to

PlanningPolicyConsultation@communities.gov.uk

If you have time to absorb the full picture about failing regulation and you agree with the full range of issues presented in the Submission, please endorse the Submission in full.

Thank you,

Signed xxx, address.

Download

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It is sometimes claimed that radio frequency radiation (in the ‘non ionising’ spectrum) has the ability to ionise the air at relatively low power levels.

There may be exotic conditions in which low power can have amplified non linear effects – via rarely witnessed quantum processes such as tunnelling, but so far the mechanisms and conditions for such effects are poorly understood.

The emerging discipline of quantum electro-biology however does offer to bring deeper understanding of the processes behind the biological effects that are caused by low power and low frequency exposure, that can result in ROS (from oxidative stress) in the body.

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1) WHAT IS IONISATION OF AIR?

Ionization of air refers to the process by which neutral air molecules or atoms gain or lose electrons, resulting in the formation of charged particles known as ions. This process occurs when air is exposed to high levels of energy, such as from electric fields, ultraviolet light, radiation, or high temperatures.

Key Points about Ionization of Air:

1. Formation of Ions:
   • Positive Ions: When an air molecule (typically nitrogen or oxygen) loses an electron, it becomes a positively charged ion.
   • Negative Ions: If an air molecule gains an extra electron, it becomes a negatively charged ion.
2. Causes of Ionization:
   • Electric Fields: Strong electric fields, such as those near high-voltage power lines or during lightning strikes, can cause the air molecules to ionize. This is because the electric field provides enough energy to knock electrons out of their atomic orbitals.
   • Radiation: High-energy radiation, such as X-rays, gamma rays, or cosmic rays, can ionize air molecules by imparting enough energy to free electrons.Ultraviolet Light: UV light, particularly at high intensities, can ionize air by exciting electrons to the point where they escape from their parent atoms or molecules.
   • Heat: Extremely high temperatures, such as those found in a plasma, can provide enough energy to ionize air molecules.
3. Plasma Formation:
   • When a significant amount of ionization occurs, the air can transition into a plasma state, which is a hot, electrically conductive mixture of ions and free electrons. Lightning is an example of plasma formed by ionization of air.
4. Applications and Effects:
   • Air Purifiers: Some air purifiers use ionization to generate negative ions, which attach to airborne particles and cause them to settle out of the air, effectively reducing particulate matter.
   • Electrical Discharges: Ionization is a key factor in the formation of electrical discharges like sparks, corona discharge, and lightning.
   • Communication Interference: Ionization of the atmosphere can affect radio wave propagation, especially at high altitudes or during solar storms, where the ionosphere becomes highly ionized.
5. Health Implications:
   • While ionized air can have some benefits, such as removing dust and allergens, excessive ionization, especially in confined spaces, can produce ozone and other byproducts that may be harmful if inhaled in large quantities.

Summary

Ionization of air is the process where air molecules gain or lose electrons, resulting in the formation of ions. This process can occur due to high electric fields, radiation, ultraviolet light, or high temperatures. Ionization is essential in many natural phenomena (like lightning) and technological applications (like air purification) but can also have implications for human health and communication systems.

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2) CAN 13V/M CAUSE THE POSITIVE CHARGING (IONISATION) OF AIR ?

This question arose because the Ionisation potential of Oxygen in a ground state is 12.6eV. This however does not equate to being activated in a low field strength of 13 V/m:

A field strength of 13 volts per meter (V/m) is relatively weak and is not sufficient to cause ionization of air.

Understanding Ionization of Air:

• Electric Field Strength and Ionization: Ionization of air requires an electric field strong enough to impart energy to electrons to overcome the binding energy that holds them to their parent atoms or molecules. For air (composed mainly of nitrogen and oxygen), the ionization energy is relatively high.
• Breakdown Threshold of Air: The electric field strength required to ionize air and cause a breakdown (such as a spark or corona discharge) is known as the “breakdown field strength.” In standard conditions (at sea level and room temperature), the breakdown field strength of air is approximately 3 million volts per meter (3 MV/m or 3 × 10⁶ V/m). This is much higher than 13 V/m.

What Happens at 13 V/m:

• Insufficient Energy for Ionization: At 13 V/m, the electric field is far too weak to cause ionization. It does not provide the necessary energy to free electrons from air molecules, so no significant ionization occurs at this field strength.
• Impact on Air: Such a low field strength may cause a slight movement of charge carriers (like ions already present in the air) but not enough to create new ions. The air remains largely non-ionized and behaves as an insulator under these conditions.

Conclusion:

An electric field strength of 13 V/m is not capable of causing ionization of air. Ionization requires much stronger fields, typically on the order of millions of volts per meter, to break down the air and create free ions.

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3) HOW IS OXIDATIVE STRESS RELATED TO IONISATION OF AIR ?

Oxidative stress and ionization of air are connected through the production of reactive oxygen species (ROS), such as ozone and free radicals, which can result from air ionization and have implications for biological systems.

How Ionization of Air Leads to Oxidative Stress:

1. Ionization and Reactive Oxygen Species (ROS) Production:
   • Ionization Process: When air is ionized, typically by high-energy sources like ultraviolet light, strong electric fields, or radiation, it can lead to the formation of reactive oxygen species (ROS). These ROS include ozone (O₃), superoxide anions (O₂⁻), hydroxyl radicals (OH•), and other reactive molecules.
   • Chemical Reactions: The ionization process can cause molecular oxygen (O₂) in the air to split and recombine with other molecules, forming ROS. For example, O₂ can be ionized to form O₂⁻, which can further react to produce more reactive species.
2. Exposure to ROS and Oxidative Stress:
   • Oxidative Stress: When living organisms, including humans, are exposed to high levels of ROS, it can lead to oxidative stress. This is a condition where the balance between ROS production and the body’s ability to detoxify them (or repair the resulting damage) is disrupted.
   • Biological Impact: ROS can damage cellular components like lipids, proteins, and DNA, leading to various health issues. Chronic oxidative stress is associated with aging, inflammation, and diseases such as cancer, cardiovascular diseases, and neurodegenerative disorders.
3. Ozone and Health Effects:
   • Ozone (O₃): Ozone is a significant ROS that can be produced by air ionization. While ozone in the upper atmosphere protects us from harmful UV radiation, at ground level, it is a pollutant with harmful effects on respiratory health.
   • Health Impact: Inhalation of ozone can cause respiratory issues, exacerbate asthma, and lead to oxidative damage in lung tissue, contributing to oxidative stress in the body.

Sources of Air Ionization Leading to ROS:

• Natural Sources: Lightning and cosmic rays naturally ionize the air, producing ROS in the environment.
• Human-Made Sources: Industrial processes, high-voltage power lines, air purifiers, and ionizers can also ionize air and generate ROS, including ozone.

Summary:

Oxidative stress is related to the ionization of air because ionization can produce reactive oxygen species (ROS), such as ozone and free radicals. These ROS can cause oxidative damage to biological tissues when inhaled or encountered, leading to oxidative stress. Chronic exposure to high levels of ROS can contribute to various health problems, including respiratory issues, inflammation, and more severe conditions like cancer and cardiovascular diseases.