Response to Archbishops Council letter of 9th Feb 01
Dear Mr Hopgood,
Thank you for your letter of 9-02-01. While we appreciate your awareness of the health and safety issues in this area, certain aspects of your proposed guidance seem to us to be seriously flawed. Most importantly, the Archbishops Council seems to have misunderstood the safety implications of the Stewart Report.
You quote from Section 1.33, which is part of Planning issues, without any mention of it’s referral to other adverse effects [6.44] “the possibility of harm from exposures insufficient to cause important heating of tissues cannot yet be ruled out with confidence”. You fail to mention that the report’s main conclusions on health effects [sections 1.16 –1.22], overall don’t claim that existing phone radiation levels are safe.
Throughout the Stewart report they apply existing assumed base station powers, see below, not what the licences permit. In fact the licence permits up to 8 times more power than assumed in the report and these higher powers could be transmitted as technology advances. So when your letter quotes from the report [section 1.33] that “exposures are expected to be small fractions of guidelines” as the report only refers to the present assumed typical example this is no assurance of future safety as equipment ‘improves’ and power levels increase.
It seems hard enough to find that a new installation is even planned; secrecy about later equipment upgrades, with power increases, is likely to be even tighter. Why should the public have to live with fear of the unknown? It would be better to avoid this fear by assuming maximum licensed power when siting antennas.
The Stewart Report emphasises the ‘Precautionary Principle’. This should mean that where there are uncertainties we are protected to the greatest possible extent, until safety can be proven. Section 1.43 says “…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”. In other countries, with effective telecomms systems, a 300 to 500 metre exclusion zone between high power base-stations and inhabited properties is observed. This distance ensures that exposure levels are below those at which biological effects, harmful or otherwise, can be observed.
Your inclusion of specific guidance on sensitive locations e.g. school sites is welcome, hopefully this will include toddler group sites as vulnerability is increased at younger ages. However it needs to be remembered that children need equal protection at home. [Stewart Report 6.63, 4.37]
The reason why the Stewart report only considers the exposure of children to base-station radiation while at school, is given in ‘Clarification of Stewart Report Issues’ http://www.iegmp.org.uk/Queries.htm It explains that The Expert Group was specifically asked by government to address the issue of siting of base stations on or near schools as “It is known that children are in school for a large proportion of the day, whereas their whereabouts outside school are much less clearly defined”.
When children’s whereabouts outside school are known, a reasonable position to take, based on what the report says, would be -
In considering how base-stations are to be sited, proper application of the precautionary
principle means do not allow ‘the beam of maximum intensity’ to fall on schools or school land (knowing that children could be there 6 hours a day) or on any residential properties or land where children live for 6 hours a
day or more.
Some land owners are prepared to put community health concerns before a bit of extra income. Is the Church of England?
You say that the proposed guidance "package" for parishes, which will ultimately have to take their own view of the health and safety issues, will direct them to the Stewart Report. Much of this report is technical jargon that not many would understand. You seem to have misunderstood parts yourselves, so what chance will those with lesser resources have? You are not alone in demonstrating how easy it is to quote only those phrases or sections which suit you.
Assumed Base-station Power - The Stewart Report is based on evidence collected by the Expert Group from others, not any new research.
The figures for typical base station antenna power emissions given by the telecom operators as typical will be assumed in this report [section 4.32]. It also notes “the total radiated power, is limited by technical rather than legal requirements, which would in fact permit significantly larger powers to be radiated”.
We hope this will enable you to give accurate information to parishes and help them to make informed decisions about these matters. Above all we would like to repeat that you consider the equal sensitivity of schools and children’s homes.
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Stewart Report pertinent sections.
[1.33] We conclude that the balance of evidence indicates that there is no general risk to the health of people living near to base stations on the basis that exposures are expected to be small fractions of guidelines. However, there can be indirect adverse effects on their well-being in some cases (paragraphs 5.264, 6.44 and 6.45).
[5.264] Effect of mobile phone base stations on well-being
Whilst we have focussed on the information available in the published literature, the Group was struck by the concerns expressed by many who attended the
public meetings and who wrote to us about adverse effects on their well-being which they attributed to the presence of mobile phone base stations near to residences, schools, etc (see paragraphs 3.5 and 3.6). The social impact
of mobile phone technologies needs to be fully considered. In addition to the improvements in planning which we consider to be essential (paragraphs 6.55–6.62) there is a need for a significant research programme to be
initiated so that the impact of mobile phone technologies on well-being in its broadest sense is properly addressed and understood through epidemiological or other approaches. This should be brought to the attention of funding
agencies such as the Economic and Social Research Council, the Medical Research Council, the European Commission and other bodies.
[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.
[4.32] The licence sets the maximum EIRP at 1500 W per frequency channel corresponding to a maximum total radiated power of about 30 W per channel (= EIRP/gain). It also limits the number of channels per antenna to 16 (for 1800 MHz) and 10 (for 900 MHz). However, we have been told that in practice the number of channels is typically less than 4 for 1800 MHz and 2 to 4 at900 MHz (FEI, 2000), which would correspond to maximum radiated powers of less than 120 Wand 60–120 W, respectively. Similarly, the total radiated power emitted from an antenna is generally limited by the characteristics of the equipment to somewhat under 70 W (FEI, 2000),and a figure of 60 W will be assumed in this report. It needs to be stressed that the number of channels used, and hence the total radiated power, is limited by technical rather than legal requirements, which would in fact permit significantly larger powers to be radiated. As with a phone, and for largely the same reasons, the average power transmitted by a base station is normally less than the maximum power, although in this case it could rise to the maximum at times (rather than to one-eighth of the peak power in the case of a phone). By the inverse square law, the maximum intensity in the main beam at a point on the ground 50 m from a 10 m tower carrying an antenna transmitting 60 W into a 120 sector is about 100 mW/m2. This corresponds to oscillating electric and magnetic fields of about 5 V/m and 0.02 µT, respectively, very roughly about 50 to 100 times smaller than those 2.2 cm from the antenna of a phone. The heating effects that these fields would produce will vary with the intensity and are about 5000 times smaller than the maximum value 2.2 cm from the antenna of a mobile phone..
