Saturday, 2 November 2019

UK: 5G Consultation





















The UK Government is currently conducting a public consultation into its plans to ease the deployment of 5G infrastructure, through changes to the planning system. This consultation ends on 4th November 2019, and you can find details of the Government's plans, and how to comment on them, here:

https://www.gov.uk/government/consultations/proposed-reforms-to-permitted-development-rights-to-support-the-deployment-of-5g-and-extend-mobile-coverage

The Government is seeking responses to six questions concerning its plans, which you can see via the link above. Questions 2-6 are relevant to private individuals, as opposed to companies.

I've submitted a response, in which I go into a number of issues concerning 5G (as well as existing wireless technologies), and how the radiation emitted by 5G masts and small cells will pose a particular challenge for electrosensitive people such as myself. This was produced in quite a hurry, so there are probably many mistakes in it. Hopefully the general message will be clear though!


Proposed reforms to permitted development rights to support the deployment of 5G and extend mobile coverage

Response from: Dave Ashton
Capacity: Responding as an individual

Responses to questions 2 – 6:

2.1 No. Please see comments below.
2.2 No. Please see comments below.
3.1 No. Please see comments below.
4.1 No. Please see comments below.
5.1 No. Please see comments below.
6 Yes. Please see comments below.

Introduction

In considering the Government's plans to facilitate and encourage the roll-out of 5G technologies through a drastic reform of the planning regime, it must be right to ask if this course of action is both necessary and desirable in the first place. I would argue that it is neither, and in fact that it is dangerous, anti-democratic, and entirely counter-productive.

The primary duty of any Government is to protect its citizens from harm, such as the adverse health effects resulting from exposure to the RadioFrequency (RF) radiation emitted by wireless technologies and devices.

Everybody is already exposed to layer upon layer of this radiation from 2G, 3G, and 4G mobile phones, WiFi, WiMax, smart meters, DECT cordless phones and baby monitors, mobile mast base stations, TETRA masts, radar transmitters, tv and radio transmitters, wireless laptops and tablets, wireless wearables and implantables, and an ever-growing ecosystem of 'smart' devices in the home, in cars, and just about everywhere else too.

If this radiation were categorically known to be harmless, then in 2011 it would not have been classified by the World Health Organisation (WHO) / International Agency for Research on Cancer (IARC) as a Group 2B Possible Carcinogen. [1]

Precautionary Approach: First recommended, then ignored...

On 22nd September 2019, I performed a search on the website gov.uk for 'Group 2B' and IARC' within the following official documents:

2012 AGNIR Report:  Radiofrequency electromagnetic fields: health effects [2]
2013 Guidance: Radio waves: reducing exposure [3]
2013/2019 Guidance: Mobile phone base stations: radio waves and health [4]
2012/2017 Guidance: Smart meters: radio waves and health [5]
2013 Guidance: Wireless networks (wi-fi): radio waves and health [6]
2019: House of Commons Library - 5G Briefing Paper [7]

I found no reference to either term in the Government's official advice to the public, nor in its internal advice, which is a very surprising omission. Apparently, it doesn't matter to the Government that this ubiquitous radiation could be promoting cancer throughout the population, and nor is there any need for people, especially children and vulnerable individuals, to be warned about this.

In 2000, Sir William Stewart - who had been the Government's chief scientific adviser, and who chaired the  Independent Expert Group on Mobile Phones (IEGMP) – recommended, in what became known as the Stewart Report [8], that:

'...a precautionary approach to the use of mobile phone technologies be adopted until much more detailed and scientifically robust information on any health effects becomes available'

Also:

'If there are currently unrecognised adverse health effects from the use of mobile phones, children may be more vulnerable because of their developing nervous system, the greater absorption of energy in the tissues of the head (paragraph 4.37), and a longer lifetime of exposure. In line with our precautionary approach, we believe that the widespread use of mobile phones by children for non-essential calls should be discouraged. We also recommend that the mobile phone industry should refrain from promoting the use of mobile phones by children'

This report highlighted the 'precautionary principle':

'Where there is uncertainty as to the existence or extent of risks to human health, the [European] Commission may take protective measures without having to wait until the reality or seriousness of those risks becomes apparent'

We now have much more scientific evidence linking the use of wireless technologies to an extensive array of harmful health effects, including cancer, than was available at the time of the Stewart Report.

For example, an IARC expert committee recently recommended that RF radiation be re-evaluated with high priority in the light of recent scientific findings [9] – particularly relating to the results of the National Toxicology Program studies in the U.S., and the Ramazzini Institute studies in Italy.

However, although lip-service is paid to the idea, the precautionary approach doesn't actually exist. The use of RF radiation-emitting devices is ubiquitous, even amongst very young children, and their chronic exposure now starts in utero.

Government and the authorities in denial

Successive governments have ignored the warnings of independent scientific and medical experts, listening instead to the industry, and to conflicted groups and organisations with an agenda. Worst of all, people are not being warned.

In June this year, when asked a parliamentary question about 5G by the MP for Stroud, Nicky Morgan, the Digital Minister, said that:

'A considerable amount of research has been carried out on radio waves and we anticipate no negative effects on public health' [10]

In media articles about 5G, Public Health England (PHE) says that:

'...there may be a small increase in overall exposure to radio waves when 5G is added to an existing network or in a new area. However the overall exposure is expected to remain low relative to guidelines and as such there should be no consequences to public health.' [11]

Matt Warman, Minister for Digital and Broadband, is quoted by Inside Towers as saying:

“There is no compelling evidence for any increased concern about 5G roll-out compared to WiFi, 3G or 4G and there are well-established limits for radio equipment within which any new kit must operate...These limits are acknowledged by Public Health England in the UK and the World Health Organization. We want to support work that will bust health myths over 5G and provide evidence-based reassurance to the public” [12]

So, no negative effects are anticipated, exposure is expected to remain relatively 'low', there should be no consequences to public health, and there is no compelling evidence for increased concern. Imagine if untested drugs were sold on this uncertain basis, and the Government and other public bodies encouraged this. Yet, with 5G, this is precisely what is happening.

5G will increase exposure to radio waves, and the proposals detailed in this consultation will increase exposure to radio waves, through the removal of any remaining mobile 'not-spots', the addition of more layers of electrosmog, and the siting of radiation emitting masts (called 'small cells') even closer to people's homes, schools, shops, and to other public areas.

In addition, we have some new technologies to be tested out on the unsuspecting public for the first time, such as millimetre wave radiation, MIMO (Multiple-Input Multiple-Output), and 'beam-forming' (which appears to essentially involve targeting the hapless 5G phone user with a directed beam of radiation, although what happens to anybody who happens to get in the way isn't clear).

The Digital Minister can anticipate whatever she likes, but the independent, non-industry science should give any responsible Member of Parliament considerable pause for thought. 5G has not been safety tested by independent experts who are unsullied by links to the industry prior to its introduction. As U.S. Senator Richard Blumenthal put it in a recent 5G Senate Commerce Hearing when grilling wireless industry representatives:

'So there really is no research ongoing.  We’re kind of flying blind here, as far as health and safety is concerned' [13]

Whilst some towns, cities, and countries around the world are pausing the 5G rollout until independent science shows that the technology is safe, the UK seems intent on removing any remaining checks and balances provided by the planning system. It is therefore limiting the ability of local councils – and people - to have a meaningful say in a matter that will be of huge and lasting consequence for them.

A recent article in a US legal journal, 'Putting the Cart Before the Horse – The FCC’s “5G First, Safety Second” Policy' [14], describes how the Federal Communications Commission, which regulates wireless communications, still uses out-of-date RF Radiation safety limits, which ignore the independent, non-industry scientific evidence, and which therefore fail to protect the public. In the UK, we are doing exactly the same thing.

State of the Art Science

The National Toxicology Program in the U.S. has been described as the 'gold standard' of toxicology research. It has fairly recently tested the RF Radiation from 2G and 3G mobile phone technologies, at exposure levels that were too low to cause significant heating of bodily tissues in the test animals. In the information leaflet that accompanied the results [15], it summarised the findings:

* Clear evidence of tumors in the hearts of male rats. The tumors were malignant schwannomas.
* Some evidence of tumors in the brains of male rats. The tumors were malignant gliomas.
* Some evidence of tumors in the adrenal glands of male rats. The tumors were pheochromocytomas.

It noted that:

 '...the studies question the long-held assumption that radio frequency radiation is of no concern as  long as the energy level is low and does not significantly heat the tissues'

This is a very significant statement, because it is this 'long-held assumption' that forms the basis of the UK's RF Radiation exposure limits, through its implementation of the International Commmission on Non-Ionizing Radiation Protection's (ICNIRP's) Guidelines. RF Radiation is of huge concern, as everybody is already exposed to this Group 2B Carcinogen, whether they like it or not, and whether they use wireless devices or not. We're all lab rats now.

A companion study [16], carried out by the Ramazzini Institute in Italy, reported that:

'A statistically significant increase in the incidence of heart Schwannomas was observed in treated male rats at the highest dose (50 V/m)'.

It gets worse though. The NTP has recently published its 'Evaluation of the genotoxicity of cell phone radiofrequency radiation in male and female rats and mice following subchronic exposure' [17]. This paper states that:

'...these results suggest that exposure to RFR (RadioFrequency Radiation) is associated with an increase in DNA damage'

The NTP is a U.S. inter-agency program, which is composed of three Government agencies. It is not a bunch of wild conspiracy theorists pushing an agenda. What it says matters. The implication of DNA damage being done to humans, plants and animals through environmental exposure to RF Radiation is truly chilling, and the Government bears large responsibility for this, through its support for harmful wireless technologies such as 5G.

The results of these two major toxicology studies, with more results to follow, stand in stark contrast to the  official advice that is provided by Public Health England, the Government, and other organisations.

Crisis at ICNIRP, the WHO, PHE, and COMARE

The UK follows the RF Radiation exposure guidelines provided by ICNIRP, which is a private, unaccountable, self-appointed, and industry-friendly organisation, based in Germany, and which is part-funded by the German State.

244 scientists from around the world have put their names to the EMF Call [18]. This states that:

'ICNIRP’s opinion and guidelines are unscientific and protect industry, not public health.'

They continue:

'ICNIRP’s mandate to issue exposure guidelines needs to be seriously questioned. ICNIRP is not independent of industry ties as it claims...Its opinions are not objective, not representative of the body of scientific evidence, but are biased in favor of industry. It is obvious from their reluctance to consider scientific findings of harm that ICNIRP protects industry, not the public health, nor the environment.

ICNIRP’s first chairman and other experts have or have had financial ties to the telecom, military and/or power industry...Their first chairman managed to head the WHO EMF project using WHO as an umbrella to promote ICNIRP guidelines as the world standard. That person was also responsible for channeling funding from the telecom industry to the WHO EMF project for several years.'

Concerning 5G, an article in the Telegraph [19] recently quoted Dr Eric Van Rongen, ICNIRP Chairman, as saying:

'It was not set up as a public health experiment, but of course you can consider it as such'.

Indeed. 5G is self-evidently a public health experiment, on a massive scale.  As are 2G, 3G, 4G, WiFi, and all other artificial sources of pulsed, polarized, and modulated RF/microwave radiation. What is more, there is no provision to opt out of this particular public health experiment.

ICNIRP's assumption informs PHE, the Committee on Medical Aspects of Radiation in the Environment (COMARE), the former Advisory Group on Non-Ionising Radiation (AGNIR), and even the World Health Organisation (WHO).

Analysis by Investigate Europe [20] shows how intertwined all of these organisations are, and how the same names keep cropping up. One of these names is an engineer called Dr Simon Mann, who is an ICNIRP Scientific Expert Group member, at the same time as being Head of the Physical Dosimetry Department at PHE.

I understand that he is / was also involved with:

The COMARE Secretariat
The former AGNIR
The National Institute for Health Research Health Protection Research Unit (NIHR HPRU) in Health Impact of Environmental Hazards
The WHO
The former National Radiological Protection Board (NRPB)
The former Health Protection Agency (HPA)
The former Mobile Telecommunications and Health Research (MTHR) Programme (50% funded by the wireless industry)

Media articles about 5G and health effects, such as this one in the Bristol Post, [21] regularly quote Dr Mann:

“It is possible that there may be a small increase in overall exposure to radio waves when 5G is added to an existing telecommunications network or in a new area.

“However, the overall exposure is expected to remain low relative to guidelines and as such there should be no consequences for public health.”

What these articles generally do not mention is his membership of ICNIRP. In her critique [22] of the former AGNIR,  neuroscientist Dr Sarah Starkey said:

'Currently, six members of AGNIR and three members of PHE or its parent organisation, the Department of Health (DH), are or have been part of ICNIRP...When the group charged with assessing whether there is evidence of health effects occurring at exposures below current ICNIRP values have members who are responsible for setting the guidelines, it introduces a conflict of interest'

Shortly after her paper was published, coincidence or not, AGNIR was quietly disbanded. Dr Mann's involvement in COMARE and PHE continues though, along with his membership of ICNIRP.

In the UK, the National Planning Policy Framework prevents health concerns - for example over the installation of a new mobile phone base station close to homes – from being taken into account in planning decisions. RF Radiation exposures complying with ICNIRP's limits are deemed to be safe. All scientific evidence showing that ICNIRP's Guidelines are flawed is dismissed.

In addition, it has recently been reported by The Times [23] that Matt Warman, the digital and broadband minister, has ordered councils not to block 5G due to health concerns. He is quoted as saying that:

'There is currently no compelling evidence to back up concerns about 5G'

This is a bold statement to make, given that the safety of 5G has not been independently tested and verified. Again, ICNIRP's Guidelines, which have been redrafted to cover the higher frequencies to be used in 5G, serve as a figleaf. Everything will be within ICNIRP's limits, therefore everything will be fine.

The criticism of ICNIRP's Guidelines comes from many directions. The author of a recent article in IEEE Microwave Magazine [24] recently said this:

'The time is right for the IARC to upgrade its previous epidemiology based classification of RF exposure to higher levels in terms of the carcinogenicity of RF radiation for humans'

What is remarkable, and what must surely be causing consternation behind closed doors at ICNIRP, PHE and COMARE, is that the person who wrote this is Dr James C. Lin, a former member of the ICNIRP Commission.

To compound ICNIRP's woes, the 252 experts from all around the world who have signed the International EMF Scientist Appeal [25], say that:

'Numerous recent scientific publications have shown that EMF affects living organisms at levels well below most international and national guidelines. Effects include increased cancer risk, cellular stress, increase in harmful free radicals, genetic damages, structural and functional changes of the reproductive system, learning and memory deficits, neurological disorders, and negative impacts on general well-being in humans.

Damage goes well beyond the human race, as there is growing evidence of harmful effects to both plant and animal life...It is our opinion that, because the ICNIRP guidelines do not cover long-term exposure and low-intensity effects, they are insufficient to protect public health''

The results of the studies of the NTP and the Ramazzini Institute appear to disprove ICNIRP's assumption, as all exposures of the test animals were calibrated at levels that were insufficient to cause thermal effects. In these toxicology studies, exposure to 2G and 3G RF Radiation was found to promote DNA damage, and to lead to cancer in some of the test animals. The evidence was categorised as 'clear' and 'statistically significant' respectively. Indeed, the Ramazzini Institute results served to replicate the findings of the National Toxicology Program.

An attempt by ICNIRP to downplay the significance of the NTP and RI results [26] smacks of desperation. What is more, the NTP and RI results build upon the substantial scientific literature showing harmful effects that already exists.

ICNIRP/WHO/PHE/COMARE are being confronted with credible, non-conflicted scientific evidence, which  contradicts their thermal effects-only paradigm. It follows that the RF Radiation 'safety levels' that govern the  exposure of every single person in the UK (even honourable and right honourable Members of Parliament) have been shown to be fatally flawed.

ICNIRP is in crisis, as the non-industry scientific evidence keeps stacking up. PHE, COMARE and the WHO, because of their close working relationship with ICNIRP, are also therefore in crisis. What ICNIRP says, they say. ICNIRP's flawed  assumption is their flawed  assumption.

The UK Government is therefore encouraging and facilitating the irradiation of its population with an untested technology, using flawed safety limits. Every type of artificial RF Radiation – including 5G - is currently classified as a possible carcinogen. The UK Government is therefore in a crisis that is partly of its own making, even if it doesn't yet know it, or admit it.

The discrimination of people with 'Protected Characteristics'

Question 6 of the Government's 5G consultation refers to 'people with protected characteristics', as is set out in section 149 of the Equality Act of 2010.

The Government believes that 'the changes raised in this consultation will have a positive effect on all persons, including those with protected characteristics'. In fact, the Government's plans would be deeply discriminatory against many of these people.

It is known that children, for example, are particularly vulnerable to RF radiation from mobile phones and so on (see papers on the subject by Professor Om Gandhi).  The public is not being warned, and people - including very young children - are using these devices in an unconstrained manner. They are being exposed to the radiation from wireless infrastructure on a daily basis, and very few will have any idea of what the long term consequences are likely to be.

In addition, people who are sensitised to this radiation, such as myself,  will also be discriminated against, as we will be subjected to yet more RF radiation, and will lose any last remaining 'not spots' of reduced levels of RF radiation to which we can flee.

It appears that we are to be denied the fundamental human right to say whether or not we wish to be exposed to ubiquitous radiation in the environment. First it was cellular services such as 2G, 3G and 4G, then WiFi everywhere, then so-called 'smart meters', and now 5G small cells and other infrastructure. We are being steadily disenfranchised, concerning one of the most critical issues of our time.

Many of us lose our jobs, and sometimes our homes, because of our sensitivity, and the terrible symptoms that we are forced to endure on a daily basis. Our condition is then denied as being 'real' by the ignorant, or  by those with interests to protect. Our right to protest via the planning process is removed. We are patted on the head, and told that our condition is 'psychological'. With the honourable exception of one or two MPs, the Government and official organisations treat us with utter contempt.

With the advent of 5G small cells in close proximity to our homes, and the relaxation of any remaining planning constraints for wireless infrastructure, who knows what the effect on sensitised people will be, except to say that it will be very bad indeed.

The Government has been warned repeatedly over the years about the harmful effects of RF Radiation, not just on sensitised people such as myself, but on everybody, including infants, children, pregnant women, the elderly, and those who are either sick, or who are predisposed to illness. The non-industry science is clearly showing that these warnings were, and are, well-founded. The Government is in very big trouble indeed.

Summary

In light of the credible, compelling, and deeply disturbing, scientific evidence, the Government would be best advised to abandon its plans for 5G altogether, let alone its misguided attempts to relax the planning regime. The country needs 5G like it needs a hole in the head, and any so-called 'benefits' of this technology will be an illusion, when set against the costs.

Sooner or later, the Government is going to have to bow to reality, and deal with the long-term health, societal, and economic issues which result from the ubiquitous and 24/7 exposure of the whole population to harmful electromagnetic radiation.

As people throughout the country start to become aware of what is happening, in a sort of Age of Electromagnetic Enlightenment, they will demand that the Government, of whatever political colour, stops denying everything, stops relying on conflicted individuals and organisations for advice, and instead starts to take its fundamental duty to protect them seriously.

The number of decent and informed individuals who are becoming aware of this self-induced public health crisis is steadily growing, and they are seeing through the fog of misinformation and propaganda to the truth which lies beyond. To proceed with 5G would be an act of monumental folly, which the people would surely never forgive.


References

1) Non-ionizing Radiation, Part 2: Radiofrequency Electromagnetic Fields - IARC
https://publications.iarc.fr/126
2) Research and analysis: Radiofrequency electromagnetic fields: health effects (AGNIR Report 2012)
https://www.gov.uk/government/publications/radiofrequency-electromagnetic-fields-health-effects
3) Guidance: Radio waves: reducing exposure
https://www.gov.uk/government/publications/radio-waves-reducing-exposure
4) Guidance: Mobile phone base stations: radio waves and health
https://www.gov.uk/government/publications/mobile-phone-base-stations-radio-waves-and-health
5) Guidance: Smart meters: radio waves and health
https://www.gov.uk/government/publications/smart-meters-radio-waves-and-health
6) Guidance: Wireless networks (wi-fi): radio waves and health
https://www.gov.uk/government/publications/wireless-networks-wi-fi-radio-waves-and-health
7) 5G Briefing Paper (House of Commons Library)
https://researchbriefings.parliament.uk/ResearchBriefing/Summary/CBP-7883
8) Mobile Phones and Health - Independent Export Group on Mobile Phones, 2000
http://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.602.5821&rep=rep1&type=pdf
9) Report of the Advisory Group to Recommend Priorities for the IARC Monographs during 2020–2024
https://monographs.iarc.fr/wp-content/uploads/2019/10/IARCMonographs-AGReport-Priorities_2020-2024.pdf
10) 5G will have ‘no negative effects on public health’, says digital minister
https://www.publictechnology.net/articles/news/5g-will-have-%E2%80%98no-negative-effects-public-health%E2%80%99-says-digital-minister
11) Should we be hung up over 5G mega masts?... - Mail, 16th October 2019
https://www.dailymail.co.uk/news/article-7581565/5G-set-transform-internet-speeds-residents-fighting-back.html
12) UK Puts Local Authorities on Notice: Say ‘Yes’ to 5G - Inside Towers, 16th October 2019
https://insidetowers.com/cell-tower-news-uk-puts-local-authorities-on-notice-say-yes-to-5g/
13) At Senate Commerce Hearing, Blumenthal Raises Concerns on 5G Wireless Technology's Potential Health Risks
https://www.blumenthal.senate.gov/newsroom/press/release/at-senate-commerce-hearing-blumenthal-raises-concerns-on-5g-wireless-technologys-potential-health-risks
14) Putting the Cart Before the Horse – The FCC’s “5G First, Safety Second” Policy
https://www.khlaw.com/Files/40925_CATALANO%20ET%20AL-SEPT-OCT%202019%20ML%20-%205G%20ARTICLE%20-%209-3-2019.pdf?fbclid=IwAR1wEF09vq8naU2HPrQf4ImqipO5_cLlwTdw-aKc2ZlTfy96Am50Qj-QnQ4
15) Cell Phone Radio Frequency Radiation Studies - National Toxicology Program
https://www.niehs.nih.gov/health/materials/cell_phone_radiofrequency_radiation_studies_508.pdf
16) Report of final results regarding brain and heart tumors in Sprague-Dawley rats exposed from prenatal life until natural death to mobile phone radiofrequency field representative of a 1.8 GHz GSM base station environmental emission - Ramazzini Institute
https://www.ncbi.nlm.nih.gov/pubmed/29530389
17) Evaluation of the genotoxicity of cell phone radiofrequency radiation in male and female rats and mice following subchronic exposure
https://www.ncbi.nlm.nih.gov/pubmed/31633839
18) The EMF Call - Call for Truly Protective Limits for Exposure to Electromagnetic Fields (100 kHz to 300 GHz)
https://www.emfcall.org/the-emf-call/
19) ICNIRP Chairman, Eric van Rongen, clarifies issues from ‘The Telegraph’ interview - Between A Rock and a Hard Place, 15th March 2019
https://betweenrockandhardplace.wordpress.com/2019/03/15/icnirp-chairman-eric-van-rongen-clarifies-issues-from-the-telegraph-interview/
20) The 5G Mass Experiment - Investigate Europe
https://www.investigate-europe.eu/publications/the-5g-mass-experiment/
21) Could Bristol councillors end the roll-out of 5G in Bristol? Bristol Post, 5th September 2019
https://www.bristolpost.co.uk/news/bristol-news/could-bristol-councillors-end-roll-3287797
22) Inaccurate official assessment of radiofrequency safety by the Advisory Group on Non-ionising Radiation
https://www.ncbi.nlm.nih.gov/pubmed/27902455
23) Don’t block 5G, ministers tell councils - Times, 14th October 2019
https://www.thetimes.co.uk/article/dont-block-5g-ministers-tell-councils-lx3zvrw32
24) NTP Cell Phone Radiation Study: Final Reports – Electromagnetic Radiation Safety
https://www.saferemr.com/2018/11/NTP-final-reports31.html
25) International EMF Scientist Appeal
https://www.emfscientist.org/
26) ICNIRP Note 2019
https://www.icnirp.org/cms/upload/publications/ICNIRPnote2019.pdf