Stewart Commission on Maastricht Precautionary Principle
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A Precautionary Approach
by "UK Independent Expert Group on Mobile Phones" (reproduced from UK Stewart Commission Report 11th May 2000)

(this material is unedited/uncorrected but readers should be aware that "independent", in the above title, means government appointed, government financed, and that "group" membership was selected from the population of a dysfunctional educational/scientific establishment the primary characteristics of which have been exposed in the BSE ("mad cow disease") Phillips report - Ed. Ft-P

6.1 Many of those who submitted evidence to the Expert Group, either orally or in writing, urged the application of a precautionary approach to the new technology of mobile phones, and especially to the siting of base stations. Before considering the case for this and the ways in which it might operate, it is helpful to review the general principles of risk assessment and risk management.

Risk Assessment

6.2 Risk assessment is the process whereby the potential adverse consequences (hazards) associated with a technology or development are identified, and the probability (risk) of their occurrence is estimated. The hazards may be to human health or to the environment, or may be economic, but below we focus on hazards to human health. The identification of health hazards and the estimation of associated risks may be based on various sources of information (unfortunately in Britain, it's done a la BSE - ed. Ft P).

6.3 It is often possible to predict the hazards from a new technology on theoretical grounds, especially where it has evolved from other similar technologies already in use. If these hazards are well understood then risk assessment may only require an estimate of the levels of exposure that will occur. For example, the main hazard associated with a new industrial plant might be one of noise-induced deafness in the people who will work on it. The quantitative relation between noise exposure and deafness is well characterised, and an assessment of risk would therefore be possible once the likely levels of workers' exposure to noise had been established.

6.4 Laboratory experiments are another source of information. Experiments may be carried out in vitro (eg tests of a chemical's capacity to cause mutations in the genetic material of bacteria), using living animals (eg tests for long-term toxicity when a chemical is regularly inhaled or ingested), or more rarely, using human subjects. Such investigations form the basis for the risk assessment of many new chemicals such as drugs and pesticides.

6.5 Epidemiological studies of people are also important. These involve comparing rates of disease in different groups of people according to their exposure to known or suspected hazards.

6.6 Each source of information has advantages and disadvantages to its use. Background scientific knowledge can be applied relatively cheaply and quickly. Experience indicates that it is usually reliable, although not always. For example, it would have been difficult to predict the hazard of cancer from asbestos on the basis of scientific knowledge at the time the mineral first came into use. Similarly, before the emergence of new-variant CJD, it seemed unlikely that BSE would pose a significant health risk to people (this is proven untrue by the Phillips report - ed. Ft P).

6.7 Laboratory experiments may take up to several years to complete, but can usually (and could and should be - ed. Ft P) be carried out before any extensive human exposure to a new technology has occurred. There are, however, uncertainties in the extrapolation of findings from animals to people. For example, arsenic is known to cause skin and lung cancer in people, but attempts to demonstrate the hazard in animals have failed (Gee! - Ed. Ft P).

6.8 Epidemiological studies provide direct information about risks in people, but by definition elevations of risk can only be demonstrated once disease has started to occur. Ideally, hazards would be prevented or eliminated before any ill-effects in people had resulted !. Furthermore, the accuracy with which risks can be estimated from epidemiological studies is limited by the practical and ethical constraints of working with human subjects ?.

6.9 At each stage in the development of a new technology, risk assessment entails a synthesis of all the relevant information that is available from the sources described. Depending on how much information is available, risk estimates will be more or less certain. Thus, our knowledge about the adverse effects of ionising radiation is such that we can predict risks with relative precision (garbage in, garbage out - in other words if a blind eye is turned to much of the knowledge in the public domain about past and ongoing research, and the remainder is wilfully or negligently misinterpreted, then the prediction, the environment in which it is made, and the motivation behing the 'prediction', are strongly reminiscent of inputs (to BSE scandal related 'predictions') described by Phillips - Ed. Ft P). On the other hand, the risks associated with many industrial chemicals have been much less studied, and while current evidence may not suggest any important risk (in year 2000, when Stewart published, this is simply not true in relation to physiological (non cooking) effects of non ionising radiation on mammalian systems - ed. Ft P), we cannot always exclude this possibility with the same confidence.

Risk Management

6.10 Risk management is the process by which the risks and benefits associated with a technology or development are weighed against each other and decisions are made on whether and how to proceed with its implementation. The benefits may be real or potential, and direct (eg an improvement in health from a new drug) or indirect (eg making an industry more competitive and thereby promoting employment). The balancing of risks and benefits should take account of the uncertainties in risk estimates and also the severity of the adverse effects that might result. A small risk of a minor health effect such as transient headache might be acceptable, whereas the same risk of a more serious outcome such as brain cancer would not be acceptable ?.

6.11 A common approach in risk management is to identify a critical adverse health effect, (usually that which occurs at the lowest level of exposure). The lowest exposure at which this effect has been shown to occur is then multiplied by an "assessment" factor, also known as a "safety" or "uncertainty" factor, to derive an exposure limit or guideline. The aim is that, below this limit, exposures will not cause the adverse effect in any individual. Moreover, because the starting point for the calculation is the adverse health effect that occurs most readily, others, which only occur at higher exposures, should also be prevented. The assessment factor is designed to allow for differences in sensitivity between individuals, and also, if the assessment is based on data from animals, between species. It may be increased if the critical health outcome is particularly serious, eg cancer or congenital malformations. The exact size of assessment factors used, however, is to some extent arbitrary. It should be noted that this derivation of exposure limits or guidelines is based only on observed adverse effects. There may be evidence for other biological effects at lower exposures, but if these are not considered to be adverse (by the incompetent and or wilfully negligent a la BSE - Ed. Ft P), they do not enter the calculation ?.

6.12 Risk management is not a simple accounting process since, in general, risks cannot be quantified in the same units as benefits. For example, it may be necessary to weigh a risk to health against an economic gain !. This is not an impossible task. It is something that all of us do regularly in our day-to-day lives. When we buy a new car, we make a decision – conscious or unconscious – whether to pay extra for additional safety features. When we decide to save money by undertaking a "do-it-yourself" (DIY) task in the home, we accept the risks of accidental injury that may be entailed. Such decisions involve value judgements, and individuals will differ in where they draw the balance between perceived risks and benefits.

6.13 A further complication arises because the people who benefit most from a new development are not necessarily those who will incur the highest risks. A new municipal incinerator may be to the advantage of most people in a community, but may pose an increased risk of road traffic accidents to those who live nearby (or pollution of nearby homes and schools - Ed. Ft p). In this circumstance, balancing the risks and benefits poses moral and ethical questions and, in a democratic society, is overseen by the elected representatives of the people (a la BSE - Ed. Ft P).

The Precautionary Principle/Approach

6.14 We live in an era in which science and technology are advancing at an ever-increasing rate. This has led to many improvements in health and in the quality of life. Thus in the UK, as in many other developed countries, life expectancy is currently increasing. At the same time, however, many people have anxieties about the pace of change and the potential for major adverse consequences if new developments are not appropriately controlled – if science has greater power to do good, it also has greater power to do harm. They therefore advocate a precautionary approach to new technology where there are uncertainties about the associated risks. In this context it is important to note the recent publication of the European Commission on the precautionary principle (EC, 2000), where guidance is given on approaches that should be used. Most importantly, this document indicates that actions taken under the precautionary principle should be commensurate with anticipated risks of health detriment. This has also been outlined in a World Health Organization (WHO) background publication entitled "Electromagnetic Fields and Public Health: Cautionary Policies" (WHO, 2000) (and here, here, here, etc - Ed. Ft P).

6.15 Some people propose that new developments should only be permitted when they have been shown to be completely safe, but this is unrealistic (others have proposed reasonable constraints on siting and operating of powerful macro cell base stations - such constraints are realistic buty unfortunately eat into owners' profits - Ed. Ft P). Science can never provide a guarantee of zero risk. It may (but actually only technoquacks, charlatans, and the wilfully negligent do so, a la BSE - Ed. Ft P), however, offer strong reassurance that any risks from a technology are small in comparison with many other risks that we accept in our lives.

6.16 The precautionary approach is not all or none in nature. Rather, it is a matter of degree. In essence, it requires that before accepting a new development we should have positive evidence that any risks from it are acceptably low, and not simply an absence of convincing evidence (or deliberate selection of 'evidence' to promote a governmental/industrial cause, a la BSE - Ed. Ft P) that risks are unacceptably high. However, individuals will differ in the strength of evidence that they need before concluding that risks are sufficiently small. The implementation of a precautionary approach carries costs, which may be direct, eg for better engineering, or from a delay in the benefits that the new technology will bring. Important indirect costs may also arise if resources are directed away from a more serious risk to deal with another risk that is in fact very minor. The aim, therefore, must be to follow a policy that is acceptable to most people, and which minimises the chance of adverse outcomes without unnecessarily stifling progress (reasonable constraints would not "stifle progress" they would merely impose costs that reduce owners' large profits - Ed. Ft P).

6.17 The policy by which a precautionary approach is applied to risk management in situations of scientific uncertainty has been termed the precautionary principle. This principle was formally adopted by countries of the European Union in the Treaty of Maastricht (1992), and is evident in a ruling of the European Court of Justice when it upheld the decision of the European Commission to ban beef from the UK with a view to limiting the risk of transmission of BSE. The Court concluded as follows:
"In view of the seriousness of the risk and the urgency of the situation, and having regard to the objective of the decision, the Commission did not act in a manifestly inappropriate manner by adopting the decision, on a temporary basis and pending the production of more detailed scientific information. "Where there is uncertainty as to the existence or extent of risks to human health, the Commission may take protective measures without having to wait until the reality or seriousness of those risks becomes apparent."
The application of this principle was defined further in an EC Commentary in February 2000 (EC, 2000).

6.18 Against this general background, we now consider how the potential health risks from mobile phone technology should best be managed.

Application of the Precautionary Approach to Mobile Phone

Technology

Exposure guidelines for RF radiation

6.19 As described in paragraph 6.11, one approach that is often adopted in risk management is to define exposure limits or guidelines, below which the recognised adverse effects of a hazard would not be expected to occur. In the UK, national guidelines on exposure to RF radiation were drawn up by NRPB (NRPB, 1993a,b), and have been accepted and implemented by Government Departments and Agencies.

6.20 Having reviewed all relevant epidemiological studies, NRPB concluded that the results were inconclusive and did not provide an adequate starting point from which to derive exposure guidelines (NRPB, 1993b,c). Instead, therefore, the guidelines were based on the potential of RF radiation to cause illness or injury through heating of body tissues. While some research had suggested that adverse health effects might occur from exposures lower than those needed to produce significant heating, the evidence for this was not considered sufficiently robust to form a basis for the derivation of exposure guidelines (a la BSE - Ed. Ft P).

6.21 The NRPB exposure guidelines incorporate basic restrictions on the specific energy absorption rate (SAR, see paragraph 4.37). For mobile phones, the relevant restrictions are for frequencies between 10 MHz and 10 GHz, and these are given in Table 6.1. To verify that the exposure of an individual is within NRPB guidelines, it is necessary to demonstrate that none of the four basic restrictions is exceeded. The SAR is averaged over an exposure time and a specified mass of tissue, depending on the tissue region. Averaging times are specified because of the time taken for the temperature of tissues to equilibriate when they are exposed to the radiation.

Table 6.1 NRPB basic restrictions on exposure in the frequency range 10 MHz to 10 GHz (NRPB, 1993b)

Averaging parameters

Tissue region SAR limit (W/kg) Mass (g) Time (minutes)

Whole body 0.4 – 15

Head, fetus 10 10 6

Neck, trunk 10 100 6

Limbs 20 100 6

6.22 These restrictions apply equally to workers and to members of the general public. NRPB has taken the view that they provide adequate protection against harmful thermal effects (only! - Ed. Ft P) for all exposed individuals under all conditions (NRPB, 1999a,b).

6.23 Since SARs cannot easily be measured in living people, the NRPB guidelines also specify investigation levels for external electromagnetic field strengths, at or below which the basic restriction on whole-body SAR will not be exceeded. If an investigation level is exceeded, more detailed investigation of the resultant SAR is indicated. For children, additional reductions in investigation levels for the whole body are applied because, over certain RF frequencies, small children absorb more energy from external electromagnetic fields than adults. Table 6.2 shows these investigation levels for the frequency range covered by mobile phones.

Table 6.2 NRPB investigation levels for exposure at mobile telecommunications frequencies (NRPB, 1993b)

Frequency (MHz)

Electric field

strength (V/m)

Magnetic field

strength (A/m)

Power density

(W/m 2 )

400 – 800 100 0.26 26

800 – 1550 125f 0.33f 41f 2

1550 – 3000 194 0.52 100

f is the frequency in GHz.

6.24 The three investigation level quantities shown in Table 6.2 are related to each other (the fields are assumed to be in the far-field region – see paragraph 4.24), and it is only necessary to consider one of them. To investigate compliance, measurements are usually made of either electric field strength or magnetic field strength.

6.25 For the current generation of mobile phones and their base stations the investigation levels in the frequency range 800–900 MHz are from 26 to 33 W/m 2 and for the range 1800–1900 MHz the level is 100 W/m 2 .

6.26 Since publication of its guidelines, NRPB has continued to monitor and review the published scientific literature relevant to exposure to electromagnetic fields and human health. In this, it is supported by its independent Advisory Group on Non-ionising Radiation chaired by Sir Richard Doll. Its current position is that compliance with its guidelines for exposures to electromagnetic fields will prevent any known adverse effects on human health (NRPB, 1999a,b).

6.27 Guidelines on exposure to RF radiation have also been published by the International Commission on Non-Ionizing Radiation Protection (ICNIRP, 1998a,b). Similarly to the NRPB guidelines, these are designed to prevent illness or injury through heating effects. Their starting point is the behavioural changes that have been found when experimental animals were exposed to RF radiation at levels that produced a rise in whole-body temperature in excess of 1C. An SAR of 1–4 W/kg or higher is needed to cause these changes (1 W/kg when animals are exposed in conditions of adverse temperature, humidity and air movement, and 4 W/kg under normal environmental conditions). ICNIRP considered that there was no firm evidence for any effects that would impair health at lower levels of exposure to RF radiation.

6.28 In contrast to the NRPB guidelines, the ICNIRP guidelines feature a two-tier system with lower limits for exposure of the general public than for occupational exposure. For occupational exposure, the basic restrictions on SAR are the same as those recommended by NRPB (see Table 6.3), except that an averaging time of six minutes and an averaging mass of 10 g apply to the three localised SAR restrictions.

6.29 However, for exposure of the general public, the guidelines are five times lower than for occupational exposure. This difference was intended to allow for the following circumstances.

Table 6.3 ICNIRP basic restrictions on occupational exposure and general public exposure (in brackets) in the frequency range 10 MHz to 10 GHz (ICNIRP, 1998a)

Averaging parameters

Tissue region SAR limit (W/kg) Mass (g) Time (minutes)

Whole body 0.4 (0.08) – 6

Head, trunk 10 (2) 10 6

Limbs 20 (4) 10 6

Exposure under extreme environmental conditions – high temperatures, high humidity, low air movement and high activity increase the thermal burden from RF exposure.

Potentially higher thermal sensitivity in certain population groups such as those who are frail or elderly, infants, young children, and people with diseases or taking medications that compromise thermal tolerance.

6.30 Further arguments in support of the additional reduction factor for public exposure were also given in an earlier publication (INIRC/IRPA, 1988) as follows.

Workers are normally healthy adults exposed under controlled conditions, who are trained to be aware of potential risks and to take appropriate precautions to avoid unnecessary exposure. The general public cannot reasonably be expected to take the same precautions.

Workers are exposed only during the working day (usually 8 hours per day). On the other hand, the general public can be exposed for 24 hours per day (this total weekly exposure duration is approximately five times that of workers; hence the derivation of the extra safety factor of five for the general public).

In general, children and babies are normally considered to be more sensitive to exposures to physical, chemical or biological agents. At higher frequencies, children absorb more energy from external electromagnetic fields than adults.

6.31 The ICNIRP guidelines are presented with reference levels analogous to the NRPB investigation levels, and these also reflect the factor of five difference between the public and occupational basic restrictions. In general, over the frequency range used by mobile phones, the ICNIRP reference level for the public is lower (in terms of power density) than the NRPB investigation level by a factor of between 6.5 and 11. The ICNIRP public reference levels for the frequencies used by mobile phones are shown in Table 6.4. Reference levels for mobile telecommunications in the frequency range 800–1000 MHz are from 4 to 5 W/m 2 and for 1800–1900 MHz from 9 t 9.5 W/m 2 (ICNIRP, 1998a).

Table 6.4 ICNIRP reference levels for public exposure at

mobile telecommunications frequencies (ICNIRP, 1998a)

Frequency (MHz)

Electric field

strength (V/m)

Magnetic field

strength (A/m)

Power density

(W/m 2 )

400 – 2000 1.375f 0.0037f f /200

2000 – 3000 61 0.16 10

f is the frequency in MHz.

6.32 Following a detailed comparison of the NRPB and ICNIRP guidelines and the implications for practical hazard assessment (NRPB, 1999a), the National Radiological Protection Board issued the following Statement:

"The Board has concluded that for occupational exposure the basic restrictions in the new ICNIRP guidelines do not differ in any significant way from those previously recommended by NRPB and have no implications for the UK guidelines. For members of the public, ICNIRP has generally included a reduction factor of up to five in setting basic restrictions across the frequency range to 300 GHz. There is, however, a lack of scientific evidence to support the introduction of these additional reduction factors. The Board believes that the existing UK advice by NRPB on limiting exposures for the general public already provides sufficient protection from direct and indirect effects and that any health benefits to be obtained from further reductions in exposure have not been demonstrated. It sees no scientific justification, therefore, for altering the advice previously given by NRPB on exposure guidelines for members of the public. It does, however, accept that other factors may need to be taken into account by government in establishing generally accepted exposure guidelines for the public. "In relation to furthering knowledge on possible health effects of exposure to EMFs, the Board supports the need for further epidemiological and experimental studies."
The Board also said that the Statement reflected "understanding and evaluation of the current scientific evidence. If and when further relevant information becomes available, the Board will review its advice".

6.33 The ICNIRP guidelines for the public have been adopted in a European Council Recommendation (1999), which has been agreed in principle by all countries in the European Union, including the UK. In Germany the ICNIRP guidelines have been incorporated into statute.

6.34 From a review of the scientific evidence, we conclude that the prevention of heating effects currently remains the best basis for exposure guidelines. We further conclude that the approach adopted by ICNIRP is preferable to that of NRPB. Within the general public there may be people with illnesses that render them unusually susceptible to the heating effects of RF radiation, and this justifies the use of a higher assessment factor than for occupational exposures.

6.35 We recommend that, as a precautionary approach, the ICNIRP guidelines for public exposure be adopted for use in the UK rather than the NRPB guidelines. This would bring the UK into line with other countries in the European Union and accord with the recommendations of the House of Commons Select Committee on Science and Technology Report on Mobile Phones and Health (1999).

6.36 We are not convinced of the need to incorporate ICNIRP guidelines into statutes. We believe that they are liable to change as more scientific information on possible health effects becomes available.

6.37 The balance of evidence to date suggests that exposures to RF radiation below NRPB and ICNIRP guidelines do not cause adverse health effects to the general population (paragraphs 5.267–5.269).

6.38 There is now scientific evidence, however, which suggests that there may be biological effects occurring at exposures below these guidelines. This does not necessarily mean that these effects lead to disease (paragraph 5.266).

6.39 There are additional factors that need to be taken into account in assessing any possible health effects. Populations as a whole are not genetically homogeneous and people can vary in their susceptibility to environmental hazards. There are well-established examples in the literature of the genetic predisposition of some groups, which could influence sensitivity to disease. There could also be a dependence on age. We conclude therefore that it is not possible at present to say that exposure to RF radiation, even at levels below national guidelines, is totally without potential adverse health effects, and that the gaps in knowledge are sufficient to justify a precautionary approach.

6.40 In the light of the above considerations we recommend 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. We further recommend that national and local government, industry and the consumer should all become actively involved in addressing concerns about possible health effects of mobile phones.

6.41 On its own, adoption of the ICNIRP exposure guidelines will not allow fully for the current gaps in scientific knowledge, and particularly the possibility of, as yet, unrecognised thermal or non-thermal adverse effects at lower levels of exposure. One way in which this uncertainty could be taken into account would be to apply a higher assessment factor in the derivation of the exposure guidelines. This would have the merit of simplicity. However, as yet, there is no satisfactory scientific basis on which to set the size of any increase.

6.42 An alternative would be to adopt the exposure guidelines recommended by ICNIRP, and in addition have a policy that requires best engineering practice for equipment and installations that ensures that fields are kept to the lowest levels commensurate with the telecommunications system operating effectively. We believe that this approach is preferable. We next consider how it might be applied in relation to the design and siting of base stations, and the design, marketing and use of mobile phones.

Base Stations

6.43 The location of base stations and the processes by which they are authorised appear to be the aspects of mobile phone technology that generate most public concern (see Chapter 3) (and here - Ed. Ft P). Public telecommunications operators have been granted a number of rights similar to those enjoyed by gas, water and electricity companies. These include permitted development rights, which allow them to carry out certain developments, including the erection of masts less than 15 m high, without the need to make a full planning application. (A more detailed description of the current planning situation with respect to telecommunications is given in paragraphs 6.96–6.117.) In assessing the potential impact of a planned base station on health, the current approach in the UK is to determine whether it might cause exposures in excess of NRPB (cooking effect - Ed. Ft P) guidelines (NRPB, 1993a,b; 1999). If this can be ruled out satisfactorily, risks to health are not considered further (a la BSE Ed. Ft P).

6.44 We believe this approach is not optimal since it does not allow adequately for the uncertainties in scientific knowledge. Although it seems highly unlikely that the low levels of RF radiation from base stations would have significant, direct adverse effects on health, the possibility of harm from exposures insufficient to cause important heating of tissues cannot yet be ruled out with confidence. Furthermore, the anxieties that some people feel when this uncertainty is ignored can in themselves affect their well-being.

6.45 Other aspects of the planning process for base stations are also unsatisfactory. Some citizens feel that the siting of base stations, and particularly of masts, can result in a loss of amenity and possibly a reduction in the value of property, and it is clear that, in the face of this threat, many feel excluded and disempowered by the planning system now in operation. The resultant frustration also has negative effects on people's health and well-being.

6.46 We conclude therefore, that changes to the regulation of base stations are necessary.

National register of base stations

6.47 A first requirement is for reliable and openly available information about the location and operating characteristics of all base stations. Easy access to such information would help to reduce mistrust among the public. Furthermore, the data would be useful when applications for new base stations were being considered, and might also be of value in epidemiological investigations.

6.48 We recommend that a national database be set up by Government giving details of all base stations and their emissions. For each this should list: the name of the operating company; the grid reference; the height of the antenna above ground level; the date that transmission started; the frequency range and signal characteristics of transmission; the transmitter power; and the maximum power output under the Wireless Telegraphy Act. Moreover, this information should be readily accessible by the public, and held in such a form that it would be easy to identify, for example, all base stations within a defined geographical area, and all belonging to a specified operator.

Exclusion zones

6.49 Although exposures to RF radiation from base stations will generally be well below exposure guidelines, the need remains to prevent access by workers or the public to places where the relevant guidelines might be exceeded. Therefore, we endorse the practice of defining clear exclusion zones around base stations.

6.50 We recommend the establishment of clearly defined physical exclusion zones around base station antennas, which delineate areas within which exposure guidelines may be exceeded. The incorporation of exclusion zones should be part of the template of planning protocols that we advocate (paragraphs 6.54, 6.58 and 6.59).

6.51 Each exclusion zone should be defined by a physical barrier and a readily identifiable nationally agreed sign with a logo. This should inform the public and workers that inside the exclusion zone there might be RF emissions that exceed national guidelines. We recommend that the design of the logo should be taken forward by the British Standards Institute and implemented within 12 months.

6.52 We recommend that warning signs should be incorporated into microcell and picocell transmitters to indicate that they should not be opened when in use.

Audit of base stations

6.53 There is a need to ensure that base stations are operating within the parameters specified when they were approved.

6.54 We recommend that an independent, random, ongoing audit of all base stations be carried out to ensure that exposure guidelines are not exceeded outside the marked exclusion zone and that the base stations comply with their agreed specifications. If base station emissions are found to exceed guideline levels, or there is significant departure from the stated characteristics, then the base station should be decommissioned until compliance is demonstrated. We recommend that particular attention should be paid initially to the auditing of base stations near to schools and other sensitive sites. The audit should include appropriate checks to ensure that base stations conform to the operational parameters specified when they were approved, and that exclusion zones are properly demarcated and signed.

Planning process

6.55 As described in the annex to this chapter, the erection of base stations for mobile phone networks is not subject to such stringent planning procedures as some other types of construction project. In particular, masts less than 15 m high can be built without the planning permission that would normally be required. The lack of public consultation is a major cause of grievance in people who suffer a loss of amenity when base stations are erected and we consider the current situation to be unacceptable.

6.56 One operator has told us that it now seeks full planning permission for all new masts, even if they will be less than 15 m high, but there appears to be significant variation in the extent to which operators consult the public about the siting of base stations.

6.57 We recommend that for all base stations, including those with masts under 15 m, permitted development rights should be revoked, and that the siting of all new base stations should be subject to the normal planning process. This planning process should also apply when a change to an existing base station will increase its power output.

6.58 We recommend that, at national Government level, a template of protocols be developed, in concert with industry and consumers, which can be used to inform the planning process and which must be assiduously and openly followed before permission is given for the siting of a base station.

6.59 We consider that the protocol should cover the following points.

All telecommunications network operators must notify the local authority of the proposed installation of base stations. This should cover installations for macrocells, microcells and picocells.

The local authority should maintain an up-to-date list of all such notifications, which should be readily available for public consultation.

The operator should provide to the local authority a statement for each site indicating its grid reference, the height of the antenna above ground level, the frequency and signal characteristics, and details of maximum power output.

Any change to an existing base station that increases its size, or the overall power radiated, should be subject to the normal planning process as if it were a new development.

6.60 We recommend that a robust planning template be set in place within 12 months of the publication of this report. It should incorporate a requirement for public involvement, an input by health authorities/health boards and a clear and open system of documentation which can be readily inspected by the general public.

6.61 We recommend that in making decisions about the siting of base stations, planning authorities should have power to ensure that the RF fields to which the public will be exposed will be kept to the lowest practical levels that will be commensurate with the telecommunications system operating effectively.

6.62 Where recommendations (paragraphs 1.30–1.46) impact on the devolved responsibilities of the Scottish Parliament, the Welsh National Assembly and the Northern Ireland Assembly then they should be considered by their appropriate authorities or bodies. We have noted with interest the recent report on planning procedures for telecommunications developments produced by the Transport and the Environment Committee of the Scottish Parliament in 2000 (paragraphs 6.112–6.114).

Base stations near schools

6.63 A common concern among members of the public who attended our open meetings was the siting of macrocell base stations on or near school premises. The placement of a base station on a school building may indirectly benefit its pupils through the income generated in rent. The balance of evidence indicates that there is no general risk to the health of people living near to base stations where the exposures are only small fractions of guidelines. However, it was suggested to us that children might be especially vulnerable to any adverse effects of RF radiation. There is evidence that at the frequencies used in mobile phone technology, children will absorb more energy per kilogram of body weight from an external electromagnetic field than adults (see paragraph 4.37). A one year old could absorb around double, and a five year old around 60%, more than an adult. Additionally, since children are being exposed to RF radiation from base stations (and from mobile phones) from a younger age than adults, they will have a longer time in which to accumulate exposure over the course of their lives, and a longer time for any delayed effects of exposure to develop.

6.64 In recognition of this, some countries have prohibited the placement of macrocell base stations on sensitive sites such as schools. Such policies have the merit of being easy to administer, but they may not always produce the desired effect. For example, because of the way in which emissions are beamed, a macrocell base station located near to a school may cause higher exposure to pupils than if it were placed on the roof of the school building.

6.65 We suggest therefore that a better approach would be to require that the beam of greatest RF intensity (see paragraph 4.32) from a macrocell base station sited within the grounds of a school should not be permitted to fall on any part of the school grounds or buildings without agreement from the school and parents. Furthermore, when consent is sought from a school and parents about this question, they should be provided with adequate information to make an informed decision, including an explanation of the way in which the intensity of radiation falls off with distance from the antenna. This may be particularly relevant for schools with large grounds. If, for an existing base station, agreement could not be obtained, its antennas might need to be readjusted.

6.66 We further suggest that similar considerations should apply in relation to a macrocell base station outside the grounds of a school but at a distance from the edge of the grounds comparable to that of a macrocell base station were it to be placed within the school grounds. In this case, if requested by the school or parents, the network operator should be required to inform the school whether the beam of greatest intensity (see paragraph 4.32) falls on the school grounds or buildings. If it does, the operator should tell them where it falls and the nearest distance from the antenna to these points. It should also provide them with adequate information to make an informed consideration of the level of the intensity of RF radiation. This information should include an explanation of the way in which the intensity of radiation falls off with distance from the antenna. If there is major concern about the situation from the school and parents, it may be necessary for the network operator to make adjustments to the antennas.

6.67 We suggest that the responsibility for monitoring the requirements of paragraphs 6.65 and 6.66 should be given to local authorities with advice from the agency responsible for maintaining the database. Disputes could be referred to the Ombudsman (see paragraph 3.51).

6.68 We recommend, in relation to macrocell base stations sited within school grounds, that the beam of greatest RF intensity should not fall on any part of the school grounds or buildings without agreement from the school and parents. Similar considerations should apply to macrocell base stations sited near to school grounds.

Developments in rural areas

6.69 In urban environments and adjacent to major roads and railways, the need for new base stations will arise principally from growth in the number of phone calls that must be handled at any one time. In rural areas, however, the main drive to expansion of networks at present is the need for wider geographical coverage. In this circumstance, there may be scope to limit the number of masts that are required through agreements between operators on mast sharing and roaming.

6.70 We recommend that operators should actively pursue a policy of mast sharing and roaming where practical, and that they should be considered by planning authorities as an alternative option when new masts are proposed.

Mobile Phones

6.71 Use of a mobile phone can expose tissues adjacent to the antenna to levels of RF radiation more than a thousand times higher than people would normally encounter from base stations. We understand from the Mobile Manufacturers Forum that all mobile phones presently marketed in the UK comply with both NRPB and ICNIRP guidelines for RF radiation and on current evidence, it seems unlikely that the exposures experienced by users would have important adverse effects on health. However, direct empirical support for this assessment is limited, and several observations suggest a need for caution.

6.72 As described in Chapter 5, recent experiments in people have suggested that subtle effects on brain function might occur from the use of mobile phones held to the head (Preece et al, 1999; Koivisto et al, 2000, in press; Krause et al, 2000), although even if confirmed by further research, these effects on function would not necessarily result in illness. Also of concern is the observation in one study that exposure to pulsed RF radiation may accelerate the development of tumours (Repacholi et al, 1997). These findings require independent confirmation. However, the uncertainties that such research raises are a reminder that the current evidence base is not yet so secure that the possibility of harmful effects from the use of mobile phones can be totally discounted.

6.73 These uncertainties are less problematic in so far as people can choose whether or not to use a mobile phone. However, it is important they should be adequately informed when making theirchoice, and that they be advised of the best way in which to reduce their exposure if that is what they wish to do.

Information for consumers

6.74 To this end, purchasers of mobile phones should have information to allow them to make informed choices about personal exposures resulting from their use. Based on current evidence, the main points to convey would be as follows.

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