If you want to hold the local authority to account for health and environmental impacts, please use this objection template which refers to the recent legal challenge about the obligations to risk reconcile under the EECC. ‘Mast objection-inc-EECC’ found on blog page with more information.
Note: change to GPDO 2022: “All new masts will still require the prior approval of the local planning authority, which will assess the proposed siting and appearance of the mast. Masts that exceed these heights will require full planning permission. The new Code of Practice will also provide detailed guidance on how operators could engage and consult with local communities on new development proposals to ensure that their views are considered.“
UK applications Forum: https://ukstop5g.freeforums.net/board/3/post-object
Councils will assess Prior Approval applications on the reserved matters of SITING and APPEARANCE.
Headline with these points about appearance and impact on the site (see template below), but do still mention the contested subject of health and environmental impact (see template under Step1, Option2).
There is an ongoing debate as to whether environmental and health impacts arising from Siting constitute legitimate or exceptional information that must also be addressed in determining compatible use. (The Gov has been challenged to resolve this with regard to EECC rules in Sept 2023, link.)
Notwithstanding, we would recommend mentioning these related issues, they are vital and information sows seeds even when not taken into account.
RFR non-thermal effects are polluting, or potentially polluting, and credible evidence of this can be submitted to support your case that the mast application will result in an “unacceptable and incompatible use” of the land/site.
The Council will quote para 118 of the NPPF and claim they cannot assess any incompatible use or “set health safeguards other than ICNIRP”, but this conflicts with para 185, and other Acts. One policy is not Law. We still contend that conflicting policies should be resolved by taking into account all information to determine a material planning consideration.
Appeal from a Planning Officer 2023
- Please keep representations as brief as possible; with hundreds of representations expected to be received it really reduces the time needed to analyse all the comments received if they are concise. Bullet pointed lists of identifiable concerns are given just as a much weight as representations that take up several pages.
An application in Brighton was quashed upon application for Judicial Review. All 3 grounds were conceded including failure to adequately address public health.
An application in Frome carried a vote to Refuse at Planning Committee, on the basis of a threshold of evidence having been reached in the scientific community that regarded hazards to health. It was then withdrawn by the applicant.
Write a single paragraph in the Comments box of the Application: such as one of these
“I contend that the evidence for harm to health and the environment from next generation 5G Telco masts represents an incompatible & unacceptable use of land, as per the Town & Country Planning Act 1990. As such the evidence must be evaluated, under both Prior Approval and Full Planning, as a material planning consideration when assessing the siting of the mast.”
“This is a siting issue – it is ‘incompatible and unacceptable use’ of land and that is a material planning consideration. There is evidence of a pollutant involved causing adverse health effects which need to be evaluated under sentence 1, section 185 of the NPPF, and the Planning department has to take account of that evidence. The polluting effects have to be investigated by competent persons. That competence falls under the environmental health/director public health remit. The evidence shows this application is unsustainable under the NPPF social sustainability objective – there is no net benefit – the application should be refused.”
“There is faulty logic with increasing EMF’s with 5G when all the facts show there is a huge risk to our health and the environment. Adding infrastructure, be it masts, small cells and satellites to support the internet of things consumes enormous amounts of energy and has important security and surveillance consequences. Environmental impact is increased, health impacts are increased, a precautionary approach must be adopted.”
“I object to this mast as it is overbearing and incongruous with the surrounding area. There is also evidence in the Kostoff 2020 paper (https://www.sciencedirect.com/science/article/abs/pii/S037842742030028X) and https://ehtrust.org/science/ that the emissions from masts are a pollutant which cause adverse health effects, beyond the effects which are recognised in the UK adopted ICNIRP guidelines. Despite the policy to only consider ICNIRP under NPPF para 118, it is important to make an evidence-based determination of the material planning consideration ‘incompatible and unacceptable use’ of land under NPPF para 185. 1999/519/EC: Council Recommendation (19) and the 2018 EECC code, transposed into Law in Dec 2020, both clearly state that public health is an imperative and competent authorities should be reconciling the risks. In view of the mounting evidence of harm and any uncertainty, please apply precaution and refuse this mast.”
“I am a visitor to the area and someone who cares about the wellbeing of the residents and children in nearby schools. I object to this proposal, it is out of proportion to the surrounding area. It is unsightly and overbearing. I object to people being subject to vast amounts of radiation, it is known that radiation exposure levels within 500m of a mast increases the risk of neurological symptoms, headaches and loss of memory and learning capabilities, especially in children. (https://www.researchgate.net/publication/337624982_Limiting_liability_with_positioning_to_minimize_negative_health_effects_of_cellular_phone_towers)”
“I am writing to urge you to reject this application. I hope you will consider the application responsibly. It is easy to wave it through with the underlying belief that it’s good for business and you can’t ‘stop progress’. However, the world is changing, and your overriding concern must be for the welfare of local people and the natural world in which we flourish.
The world is in a more dangerous state now than at any time since the Second World War. The dangers have been allowed to grow because of a blind belief in technological progress, economic growth and profit above all. We need to think again and caution is the best policy. It’s time to push back against the expectation that because something is new it will be good for local people and will be welcomed by them.
We are far more questioning than you may suppose and we seriously question the real benefit of more telecoms, more data and more virtualisation. We see that these technological toys divide us from the world we live in, create anxiety and hopelessness, lock us into our screens and separate us from each other. It’s time to be courageous and to start saying NO to this application and others of its kind.”
Alternative very comprehensive guidance, with other ideas:
Comment online (usually restricted length) and Email a longer objection Letter to the council / case officer, you can link YOUR health concerns with the relevant science.
Update all red text in the Template Objection Letter with the details relevant to your mast application.
To select a few [more] scientific references in your submission please Click on the buttons, or use the List attached, below which relate most to your health and environmental concerns at the application site.
You don’t have to select references from each section. Just go to the sections that most interest you and pick one or two from each to back up your objections. (Please DON’T copy and paste the whole table or document into your objection)
We suggest these sources of info for site specific info in your letter:
* Local Plan ‘Policies Map’ – look at conservation areas and their wider setting in particular, and Public Open Spaces
* Local Plan policies – quote them. Look at design, urban environment, heritage, public open space, etc
* Council website for info on TPO protected trees
* Historic England (for listed buildings) https://historicengland.org.uk/listing/the-list/map-search
Note listed buildings and Conservation Areas both have legal protection under Planning (Listed Buildings and Conservation Areas) Act 1990.
* DEFRA Magic Map – for enviro info https://magic.defra.gov.uk/MagicMap.aspx
Create & distribute flyers containing information about health concerns being a “siting” issue.
Change yellow highlighted areas in the Template (below) to add in location, planning application number. Print and distribute.
SCIENTIFIC REFERENCES FOR USE IN OBJECTIONS
Note: it is helpful (but not essential) if you can make your objection as relevant to the local population or area as possible.
Pick relevant studies using the Buttons below, or the document versions attached (List is easier to copy from).
For example, you could say something like “I live near the proposed mast and already have poor health or x health condition. The science shows that RFR from masts can cause or contribute to various health issues/this health condition, so I’m worried that my health will deteriorate even more.” Then copy and paste some of the scientific references provided on masts, or RFR in general, that cause or exacerbate these health issues.
If you have children for example, you could say that you are concerned about your children’s health, and copy and paste some of the scientific references from the ‘Mast Proximity Consequences Especially for Children’ and ‘Children and RFR’ sections. Likewise, if you’re concerned about effects on ecology (bearing in mind nearby parks, gardens or coastal wildlife, especially birds) you could state this and copy and paste some of the scientific references from the ‘Ecology and RFR’ section.