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A Precautionary Approach
Many of those who submitted evidence to the Expert Group, either orally or in writing, urged theapplication of a precautionary approach to the new technology of mobile phones, and especiallyto the siting of base stations. Before considering the case for this and the ways in which it mightoperate, it is helpful to review the general principles of risk assessment and risk management.
Risk Assessment
Risk assessment is the process whereby the potential adverse consequences (hazards) associatedwith a technology or development are identified, and the probability (risk) of their occurrence isestimated. The hazards may be to human health or to the environment, or may be economic, butbelow we focus on hazards to human health. The identification of health hazards and theestimation of associated risks may be based on various sources of information.
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 hazardsare well understood then risk assessment may only require an estimate of the levels of exposurethat will occur. For example, the main hazard associated with a new industrial plant might be oneof noise-induced deafness in the people who will work on it. The quantitative relation betweennoise exposure and deafness is well characterised, and an assessment of risk would therefore bepossible once the likely levels of workers’ exposure to noise had been established.
Laboratory experiments are another source of information. Experiments may be carried out invitro (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 oringested), or more rarely, using human subjects. Such investigations form the basis for the riskassessment of many new chemicals such as drugs and pesticides.
Epidemiological studies of people are also important. These involve comparing rates of diseasein different groups of people according to their exposure to known or suspected hazards.
Each source of information has advantages and disadvantages to its use. Background scientificknowledge can be applied relatively cheaply and quickly. Experience indicates that it is usuallyreliable, although not always. For example, it would have been difficult to predict the hazard ofcancer from asbestos on the basis of scientific knowledge at the time the mineral first came intouse. Similarly, before the emergence of new-variant CJD, it seemed unlikely that BSE wouldpose a significant health risk to people.
Laboratory experiments may take up to several years to complete, but can usually be carried outbefore 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 107
A Precautionary Approach
known to cause skin and lung cancer in people, but attempts to demonstrate the hazard in animalshave failed.
Epidemiological studies provide direct information about risks in people, but by definitionelevations of risk can only be demonstrated once disease has started to occur. Ideally, hazardswould be prevented or eliminated before any ill-effects in people had resulted. Furthermore, theaccuracy with which risks can be estimated from epidemiological studies is limited by thepractical and ethical constraints of working with human subjects.
At each stage in the development of a new technology, risk assessment entails a synthesis of allthe relevant information that is available from the sources described. Depending on how muchinformation is available, risk estimates will be more or less certain. Thus, our knowledge aboutthe adverse effects of ionising radiation is such that we can predict risks with relative precision.
On the other hand, the risks associated with many industrial chemicals have been much lessstudied, and while current evidence may not suggest any important risk, we cannot alwaysexclude this possibility with the same confidence.
Risk Management
Risk management is the process by which the risks and benefits associated with a technology ordevelopment are weighed against each other and decisions are made on whether and how toproceed with its implementation. The benefits may be real or potential, and direct (eg animprovement in health from a new drug) or indirect (eg making an industry more competitive andthereby promoting employment). The balancing of risks and benefits should take account of theuncertainties in risk estimates and also the severity of the adverse effects that might result. Asmall risk of a minor health effect such as transient headache might be acceptable, whereas thesame risk of a more serious outcome such as brain cancer would not be acceptable.
A common approach in risk management is to identify a critical adverse health effect, (usuallythat which occurs at the lowest level of exposure). The lowest exposure at which this effect hasbeen 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 startingpoint for the calculation is the adverse health effect that occurs most readily, others, which onlyoccur at higher exposures, should also be prevented. The assessment factor is designed to allowfor differences in sensitivity between individuals, and also, if the assessment is based on datafrom animals, between species. It may be increased if the critical health outcome is particularlyserious, 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 orguidelines is based only on observed adverse effects. There may be evidence for other biologicaleffects at lower exposures, but if these are not considered to be adverse, they do not enterthe calculation.
Risk management is not a simple accounting process since, in general, risks cannot be quantifiedin the same units as benefits. For example, it may be necessary to weigh a risk to health againstan economic gain. This is not an impossible task. It is something that all of us do regularly in ourday-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 byundertaking a “do-it-yourself” (DIY) task in the home, we accept the risks of accidental injurythat may be entailed. Such decisions involve value judgements, and individuals will differ inwhere they draw the balance between perceived risks and benefits.
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A further complication arises because the people who benefit most from a new development arenot necessarily those who will incur the highest risks. A new municipal incinerator may be to theadvantage of most people in a community, but may pose an increased risk of road trafficaccidents to those who live nearby. In this circumstance, balancing the risks and benefits posesmoral and ethical questions and, in a democratic society, is overseen by the electedrepresentatives of the people.
The Precautionary Principle/Approach
We live in an era in which science and technology are advancing at an ever-increasing rate. Thishas led to many improvements in health and in the quality of life. Thus in the UK, as in manyother 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 adverseconsequences if new developments are not appropriately controlled – if science has greater powerto do good, it also has greater power to do harm. They therefore advocate a precautionaryapproach to new technology where there are uncertainties about the associated risks. In thiscontext it is important to note the recent publication of the European Commission on theprecautionary principle (EC, 2000), where guidance is given on approaches that should be used.
Most importantly, this document indicates that actions taken under the precautionary principleshould be commensurate with anticipated risks of health detriment. This has also been outlined ina World Health Organization (WHO) background publication entitled “Electromagnetic Fieldsand Public Health: Cautionary Policies” (WHO, 2000).
Some people propose that new developments should only be permitted when they have beenshown to be completely safe, but this is unrealistic. Science can never provide a guarantee of zerorisk. It may, however, offer strong reassurance that any risks from a technology are small incomparison with many other risks that we accept in our lives.
The precautionary approach is not all or none in nature. Rather, it is a matter of degree. Inessence, it requires that before accepting a new development we should have positive evidencethat any risks from it are acceptably low, and not simply an absence of convincing evidence thatrisks are unacceptably high. However, individuals will differ in the strength of evidence that theyneed before concluding that risks are sufficiently small. The implementation of a precautionaryapproach carries costs, which may be direct, eg for better engineering, or from a delay in thebenefits that the new technology will bring. Important indirect costs may also arise if resourcesare 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 whichminimises the chance of adverse outcomes without unnecessarily stifling progress.
The policy by which a precautionary approach is applied to risk management in situations ofscientific uncertainty has been termed the precautionary principle. This principle was formallyadopted by countries of the European Union in the Treaty of Maastricht (1992), and is evident ina ruling of the European Court of Justice when it upheld the decision of the EuropeanCommission 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 havingregard to the objective of the decision, the Commission did not act in a manifestlyinappropriate manner by adopting the decision, on a temporary basis and pendingthe production of more detailed scientific information. 109
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“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 thereality or seriousness of those risks becomes apparent.” The application of this principle was defined further in an EC Commentary in February 2000(EC, 2000).
Against this general background, we now consider how the potential health risks from mobilephone technology should best be managed.
Application of the Precautionary Approach to Mobile Phone
Technology
Exposure guidelines for RF radiation
As described in paragraph 6.11, one approach that is often adopted in risk management is todefine exposure limits or guidelines, below which the recognised adverse effects of a hazardwould not be expected to occur. In the UK, national guidelines on exposure to RF radiation weredrawn up by NRPB (NRPB, 1993a,b), and have been accepted and implemented by GovernmentDepartments and Agencies.
Having reviewed all relevant epidemiological studies, NRPB concluded that the results wereinconclusive and did not provide an adequate starting point from which to derive exposureguidelines (NRPB, 1993b,c). Instead, therefore, the guidelines were based on the potential of RFradiation to cause illness or injury through heating of body tissues. While some research hadsuggested that adverse health effects might occur from exposures lower than those needed toproduce significant heating, the evidence for this was not considered sufficiently robust to form abasis for the derivation of exposure guidelines.
The NRPB exposure guidelines incorporate basic restrictions on the specific energy absorptionrate (SAR, see paragraph 4.37). For mobile phones, the relevant restrictions are for frequenciesbetween 10 MHz and 10 GHz, and these are given in Table 6.1. To verify that the exposure of anindividual is within NRPB guidelines, it is necessary to demonstrate that none of the four basicrestrictions is exceeded. The SAR is averaged over an exposure time and a specified mass oftissue, depending on the tissue region. Averaging times are specified because of the time takenfor 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)
These restrictions apply equally to workers and to members of the general public. NRPB hastaken the view that they provide adequate protection against harmful thermal effects for allexposed individuals under all conditions (NRPB, 1999a,b).
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Application of the Precautionary Approach to Mobile Phone Technology
Since SARs cannot easily be measured in living people, the NRPB guidelines also specifyinvestigation levels for external electromagnetic field strengths, at or below which the basicrestriction on whole-body SAR will not be exceeded. If an investigation level is exceeded, moredetailed investigation of the resultant SAR is indicated. For children, additional reductions ininvestigation levels for the whole body are applied because, over certain RF frequencies, smallchildren absorb more energy from external electromagnetic fields than adults. Table 6.2 showsthese investigation levels for the frequency range covered by mobile phones.
Table 6.2 NRPB investigation levels for exposure at mobile
telecommunications frequencies (NRPB, 1993b)
The three investigation level quantities shown in Table 6.2 are related to each other (the fields areassumed to be in the far-field region – see paragraph 4.24), and it is only necessary to considerone of them. To investigate compliance, measurements are usually made of either electric fieldstrength or magnetic field strength.
For the current generation of mobile phones and their base stations the investigation levels in thefrequency range 800–900 MHz are from 26 to 33 W/m2 and for the range 1800–1900 MHz thelevel is 100 W/m2.
Since publication of its guidelines, NRPB has continued to monitor and review the publishedscientific 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 bySir Richard Doll. Its current position is that compliance with its guidelines for exposuresto electromagnetic fields will prevent any known adverse effects on human health(NRPB, 1999a,b).
Guidelines on exposure to RF radiation have also been published by the InternationalCommission on Non-Ionizing Radiation Protection (ICNIRP, 1998a,b). Similarly to the NRPBguidelines, these are designed to prevent illness or injury through heating effects. Their startingpoint is the behavioural changes that have been found when experimental animals were exposedto RF radiation at levels that produced a rise in whole-body temperature in excess of 1°C. AnSAR of 1–4 W/kg or higher is needed to cause these changes (1 W/kg when animals are exposedin conditions of adverse temperature, humidity and air movement, and 4 W/kg under normalenvironmental conditions). ICNIRP considered that there was no firm evidence for any effectsthat would impair health at lower levels of exposure to RF radiation.
In contrast to the NRPB guidelines, the ICNIRP guidelines feature a two-tier system with lowerlimits for exposure of the general public than for occupational exposure. For occupationalexposure, the basic restrictions on SAR are the same as those recommended by NRPB (seeTable 6.3), except that an averaging time of six minutes and an averaging mass of 10 g apply tothe three localised SAR restrictions.
However, for exposure of the general public, the guidelines are five times lower than foroccupational exposure. This difference was intended to allow for the following circumstances.
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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)
• 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 thatcompromise thermal tolerance. Further arguments in support of the additional reduction factor for public exposure were alsogiven 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 unnecessaryexposure. 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 exposureduration is approximately five times that of workers; hence the derivation of the extra safetyfactor 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 energyfrom external electromagnetic fields than adults. The ICNIRP guidelines are presented with reference levels analogous to the NRPB investigationlevels, and these also reflect the factor of five difference between the public and occupationalbasic restrictions. In general, over the frequency range used by mobile phones, the ICNIRPreference level for the public is lower (in terms of power density) than the NRPB investigationlevel by a factor of between 6.5 and 11. The ICNIRP public reference levels for the frequenciesused by mobile phones are shown in Table 6.4. Reference levels for mobile telecommunicationsin the frequency range 800–1000 MHz are from 4 to 5 W/m2 and for 1800–1900 MHz from 9 to9.5 W/m2 (ICNIRP, 1998a).
Table 6.4 ICNIRP reference levels for public exposure at
mobile telecommunications frequencies (ICNIRP, 1998a)
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Application of the Precautionary Approach to Mobile Phone Technology
Following a detailed comparison of the NRPB and ICNIRP guidelines and the implications forpractical hazard assessment (NRPB, 1999a), the National Radiological Protection Board issuedthe following Statement: “The Board has concluded that for occupational exposure the basic restrictionsin the new ICNIRP guidelines do not differ in any significant way from thosepreviously recommended by NRPB and have no implications for the UKguidelines. For members of the public, ICNIRP has generally included areduction factor of up to five in setting basic restrictions across the frequencyrange to 300 GHz. There is, however, a lack of scientific evidence to support theintroduction of these additional reduction factors. The Board believes that theexisting UK advice by NRPB on limiting exposures for the general public alreadyprovides sufficient protection from direct and indirect effects and that any healthbenefits to be obtained from further reductions in exposure have not beendemonstrated. It sees no scientific justification, therefore, for altering the advicepreviously given by NRPB on exposure guidelines for members of the public. Itdoes, however, accept that other factors may need to be taken into account bygovernment in establishing generally accepted exposure guidelines for the public. “In relation to furthering knowledge on possible health effects of exposure toEMFs, the Board supports the need for further epidemiological and experimentalstudies.” The Board also said that the Statement reflected “understanding and evaluation of the currentscientific evidence. If and when further relevant information becomes available, the Board willreview its advice”.
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.
From a review of the scientific evidence, we conclude that the prevention of heating effects currentlyremains the best basis for exposure guidelines. We further conclude that the approach adopted byICNIRP is preferable to that of NRPB. Within the general public there may be people with illnessesthat render them unusually susceptible to the heating effects of RF radiation, and this justifies the useof a higher assessment factor than for occupational exposures. 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).
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.
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).
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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).
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.
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.
On its own, adoption of the ICNIRP exposure guidelines will not allow fully for the current gaps inscientific knowledge, and particularly the possibility of, as yet, unrecognised thermal or non-thermaladverse effects at lower levels of exposure. One way in which this uncertainty could be taken intoaccount 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 onwhich to set the size of any increase.
An alternative would be to adopt the exposure guidelines recommended by ICNIRP, and in additionhave a policy that requires best engineering practice for equipment and installations that ensures thatfields are kept to the lowest levels commensurate with the telecommunications system operatingeffectively. We believe that this approach is preferable. We next consider how it might be applied inrelation to the design and siting of base stations, and the design, marketing and use of mobile phones.
Base Stations
The location of base stations and the processes by which they are authorised appear to be theaspects of mobile phone technology that generate most public concern (see Chapter 3). Publictelecommunications operators have been granted a number of rights similar to those enjoyed bygas, water and electricity companies. These include permitted development rights, which allowthem 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 currentplanning situation with respect to telecommunications is given in paragraphs 6.96–6.117.) Inassessing the potential impact of a planned base station on health, the current approach in the UKis to determine whether it might cause exposures in excess of NRPB guidelines (NRPB, 1993a,b;1999). If this can be ruled out satisfactorily, risks to health are not considered further.
We believe this approach is not optimal since it does not allow adequately for the uncertainties inscientific knowledge. Although it seems highly unlikely that the low levels of RF radiation frombase stations would have significant, direct adverse effects on health, the possibility of harm fromexposures insufficient to cause important heating of tissues cannot yet be ruled out withconfidence. Furthermore, the anxieties that some people feel when this uncertainty is ignored canin themselves affect their well-being.
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Base Stations
Other aspects of the planning process for base stations are also unsatisfactory. Some citizens feelthat the siting of base stations, and particularly of masts, can result in a loss of amenity andpossibly a reduction in the value of property, and it is clear that, in the face of this threat, manyfeel excluded and disempowered by the planning system now in operation. The resultantfrustration also has negative effects on people’s health and well-being.
We conclude therefore, that changes to the regulation of base stations are necessary. National register of base stations
A first requirement is for reliable and openly available information about the location andoperating characteristics of all base stations. Easy access to such information would help toreduce mistrust among the public. Furthermore, the data would be useful when applications fornew base stations were being considered, and might also be of value in epidemiologicalinvestigations.
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
Although exposures to RF radiation from base stations will generally be well below exposureguidelines, the need remains to prevent access by workers or the public to places where therelevant guidelines might be exceeded. Therefore, we endorse the practice of defining clearexclusion zones around base stations.
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).
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.
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
There is a need to ensure that base stations are operating within the parameters specified whenthey were approved.
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
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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
As described in the annex to this chapter, the erection of base stations for mobile phone networksis 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 wouldnormally be required. The lack of public consultation is a major cause of grievance in people whosuffer a loss of amenity when base stations are erected and we consider the current situation to beunacceptable.
One operator has told us that it now seeks full planning permission for all new masts, even if theywill be less than 15 m high, but there appears to be significant variation in the extent to whichoperators consult the public about the siting of base stations.
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.
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.
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 andpicocells.
• 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 signalcharacteristics, 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.
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.
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.
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Where recommendations (paragraphs 1.30–1.46) impact on the devolved responsibilities of theScottish Parliament, the Welsh National Assembly and the Northern Ireland Assembly thenthey should be considered by their appropriate authorities or bodies. We have noted withinterest the recent report on planning procedures for telecommunications developments producedby the Transport and the Environment Committee of the Scottish Parliament in 2000(paragraphs 6.112–6.114).
Base stations near schools
A common concern among members of the public who attended our open meetings was the sitingof macrocell base stations on or near school premises. The placement of a base station on aschool building may indirectly benefit its pupils through the income generated in rent. Thebalance of evidence indicates that there is no general risk to the health of people living near tobase stations where the exposures are only small fractions of guidelines. However, it wassuggested to us that children might be especially vulnerable to any adverse effects of RFradiation. There is evidence that at the frequencies used in mobile phone technology, children willabsorb 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 toaccumulate exposure over the course of their lives, and a longer time for any delayed effects ofexposure to develop.
In recognition of this, some countries have prohibited the placement of macrocell base stations onsensitive sites such as schools. Such policies have the merit of being easy to administer, but theymay not always produce the desired effect. For example, because of the way in which emissionsare beamed, a macrocell base station located near to a school may cause higher exposure topupils than if it were placed on the roof of the school building.
We suggest therefore that a better approach would be to require that the beam of greatest RFintensity (see paragraph 4.32) from a macrocell base station sited within the grounds of a schoolshould not be permitted to fall on any part of the school grounds or buildings without agreementfrom the school and parents. Furthermore, when consent is sought from a school and parentsabout this question, they should be provided with adequate information to make an informeddecision, including an explanation of the way in which the intensity of radiation falls off withdistance 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 bereadjusted.
We further suggest that similar considerations should apply in relation to a macrocell base stationoutside the grounds of a school but at a distance from the edge of the grounds comparable to thatof a macrocell base station were it to be placed within the school grounds. In this case, ifrequested by the school or parents, the network operator should be required to inform the schoolwhether the beam of greatest intensity (see paragraph 4.32) falls on the school grounds orbuildings. If it does, the operator should tell them where it falls and the nearest distance from theantenna to these points. It should also provide them with adequate information to make aninformed consideration of the level of the intensity of RF radiation. This information shouldinclude an explanation of the way in which the intensity of radiation falls off with distance fromthe antenna. If there is major concern about the situation from the school and parents, it may benecessary for the network operator to make adjustments to the antennas.
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We suggest that the responsibility for monitoring the requirements of paragraphs 6.65 and 6.66should be given to local authorities with advice from the agency responsible for maintaining thedatabase. Disputes could be referred to the Ombudsman (see paragraph 3.51).
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
In urban environments and adjacent to major roads and railways, the need for new base stationswill arise principally from growth in the number of phone calls that must be handled at any onetime. In rural areas, however, the main drive to expansion of networks at present is the need forwider geographical coverage. In this circumstance, there may be scope to limit the number ofmasts that are required through agreements between operators on mast sharing and roaming.
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
Use of a mobile phone can expose tissues adjacent to the antenna to levels of RF radiation morethan a thousand times higher than people would normally encounter from base stations. Weunderstand from the Mobile Manufacturers Forum that all mobile phones presently marketed inthe UK comply with both NRPB and ICNIRP guidelines for RF radiation and on currentevidence, it seems unlikely that the exposures experienced by users would have importantadverse effects on health. However, direct empirical support for this assessment is limited, andseveral observations suggest a need for caution.
As described in Chapter 5, recent experiments in people have suggested that subtle effects on brainfunction might occur from the use of mobile phones held to the head (Preece et al, 1999; Koivisto etal, 2000, in press; Krause et al, 2000), although even if confirmed by further research, these effectson function would not necessarily result in illness. Also of concern is the observation in one studythat exposure to pulsed RF radiation may accelerate the development of tumours (Repacholi et al,1997). These findings require independent confirmation. However, the uncertainties that suchresearch raises are a reminder that the current evidence base is not yet so secure that the possibility ofharmful effects from the use of mobile phones can be totally discounted.
These uncertainties are less problematic in so far as people can choose whether or not to use amobile 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 theywish to do.
Information for consumers
To this end, purchasers of mobile phones should have information to allow them to makeinformed 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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• At present scientific evidence suggests that the RF radiation produced by mobile phones is highly unlikely to be a cause of direct adverse health effects on the general population of theUK.
• There is, however, still some uncertainty about this, and individuals may therefore wish to minimise their exposure to such radiation.
• This can be achieved in several ways including, for example, by making fewer and shorter • Specific absorption rate (SAR) values are a relevant measure of exposure in this situation and should allow people to make an informed choice.
• Another way of reducing exposure would be by use of an approved, hands-free set (see We understand that an internationally agreed standard testing protocol for the assessment of SARvalues from mobile phones will soon be available. We welcome this development.
We recommend that an international standard for the assessment of SAR values from
mobile phones should be adopted for use in the UK once it has been demonstrated to be
scientifically sound.
We recommend that information on SAR values for mobile phones must be readily
accessible to consumers:
• at the point of sale with information on the box,
• on leaflets available in stores giving comparative information on different phones and
with explanatory information,
• as a menu option on the screen of the phone, and as a label on the phone,
• on a national web site, which lists the SAR values of different phone types.
In order that consumers can interpret SAR values it will also be necessary to provide them withan explanation of the measure and its application.
Such information could be given by mobile phone manufacturers or retailers in addition to thatalready provided (see paragraphs 3.28 and 3.29). However, we believe that it would carry moreweight if it came from Government and were clearly seen to be independent.
Shields seek to reduce the RF radiation to which users of mobile phones are exposed, and varioustypes of device have been produced for this purpose. For most of them, eg ceramic absorbingdevices, there is no apparent physical basis for their alleged effect, and there are no convincingtest results to verify that they reduce exposure.
One particular type does have a physical basis. This type consists of a case that fits over thehandset and has a metallic or metallic-mesh screen within the case and a “guard” for the antenna.
Together these partially screen the radiation emitted by the phone.
Tests by various laboratories, including some that formed the basis of a Which? report publishedin April 2000, have measured the effect of this type of shield on the radiation from a mobilephone when it was set to produce constant power. The shield substantially reduced the radiationby a factor that could be adjusted by the user.
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In most normal use, however, the shield would not reduce the exposure of the user to this extent,since the reduction in radiation produced by the shield would automatically be compensated forby adaptive power control. (This increases or reduces emissions to give an optimal signal at thebase station, see paragraph 4.14.) An exception would occur where the mobile phone was alreadyoperating at or close to its maximum power, eg because it was a long way from the base stationor in a building, but in this situation, the signal at the base station would be weakened by theshield and communication might not be possible.
Some of the test results have shown that the radiation is reduced more in the direction of the headthan in the direction away from it. If so, users could reduce their exposure somewhat by turningthe appropriate side of their head towards the base station. However, this could only be done ifthey could see the base station, which is not the usual situation. For other orientations of the headthe tests imply that the reduction in exposure would be very small.
We conclude that, in practice, there would be very little reduction in the exposure received bymost users through use of a shield of this type, and that their reception could be impaired whenthey were a long way from a base station or in buildings, cars, etc. If the use of shields becamewidespread there could also be adverse effects on the environment, since more base stationswould likely be needed to maintain the quality of communication.
Hands-free kits
Exposure to RF radiation from a mobile phone can be reduced by increasing the distance of thephone from the body. This could be achieved by using an appropriately designed hands-free kit.
Little or no advantage will be gained, however, if the phone is merely moved from the head to,say, the waist since in that case other organs may receive comparable exposure.
Even if the mobile phone is some distance from the body, reduction in exposure may not beachieved if the wires from the handset to the earpiece can carry radio signals to the ear orthemselves radiate significantly. Since the original purpose of hands-free kits was to permit theuse of both hands while phoning, they may not all have been designed with exposure in mind.
The Which? report published in April 2000 showed that the hands-free kits tested could increasethe exposure to the user. On the other hand, we are aware of other tests which claim a verysubstantial reduction. In both cases there is insufficient published information about themeasurement methods to form a clear view. We believe, however, that it should be possible todesign hands-free kits which would significantly reduce exposure to the user if used correctly (iewith the phone some distance from the body).
The regulatory position on the use of hands-free kits and shields is unclear and the only
information available to the public appears to be that supplied by their manufacturers. We
recommend that the Government sets in place a national system which enables independent
testing of shielding devices and hands-free kits to be carried out, and which enables clear
information to be given about the effectiveness of such devices. A kite mark or equivalent
should be introduced to demonstrate conformity with the testing standard.
Use by children
We have already discussed the arguments for minimising the exposure of children in school toRF radiation from base stations (see paragraphs 6.63–6.68). These apply even more to the higherexposures that occur from use of mobile phones. There may be circumstances where the use of amobile phone by a child can promote safety (eg to ask a parent for a lift rather than walk homealone).
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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.
Use near hospitals
As described in paragraphs 4.5 and 4.6, there is a potential hazard from the indiscriminate use ofmobile phones in hospitals and other sites where RF radiation could interfere with sensitiveelectronic equipment. We support the steps that are already being taken both by mobile phonemanufacturers and hospitals to warn people about the dangers of using phones in such sites.
We understand that health authorities/boards issue guidance on the use of mobile phones.
We recommend that they should ensure that all hospitals comply. This guidance should
include the placing of visible warning signs at entrances to buildings to indicate that mobile
phones should be switched off.
Use while driving
As described in paragraphs 5.201–5.214, there is strong evidence that use of a mobile phonewhilst driving significantly increases the risk of accidents. It has been suggested to us that the useof hand-held phones while driving should be banned, and the Department of the Environment,Transport and the Regions (DETR, 2000) considered this issue sufficiently important to warrant apublicity campaign aimed at dissuading drivers from using a mobile phone, especially one whichis hand-held, when in control of a vehicle.
We welcome this initiative, but note that, perhaps surprisingly, current evidence indicates that thenegative effects of phone use while driving are broadly similar whether the phone is hand-heldor hands-free.
We conclude that the detrimental effects of hands-free operation are sufficiently large that
drivers should be dissuaded from using either hand-held or hands-free phones whilst on
the move.
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ANNEX (based on material provided to the Expert Group by DETR)
Current Planning Procedures for Telecommunications
Development
All development requires planning permission. In most cases, this will entail a full application tothe local planning authority (LPA) for express permission. LPAs are required to determineapplications in accordance with the development plan, unless material considerations indicateotherwise. These considerations can include views expressed by local people. LPAs have topublicise all planning applications.
Relatively minor development does not require express permission. It is granted planningpermission under the Town and Country Planning (General Permitted Development) Order 1995– the “GPDO”. These “permitted development rights” are enjoyed by a range of bodies,including householders and statutory undertakers.
Legal position
Larger developments, such as masts over 15 m high, require a full planning application, whichwill be considered by the LPA.
Public telecommunications operators hold licences under Section 7 of the TelecommunicationsAct 1984 to run telecommunications systems. In order to help them do this, they have beengranted Telecommunications Code Powers (contained in Schedule 2 of the TelecommunicationsAct 1984). These essentially confer on telecommunications operators a number of rights similarto those enjoyed by the gas, water and electricity companies. These Powers enable them to installtheir systems in the maintainable highway and, with the appropriate consents, on private land.
The Code also places a number of obligations on operators.
Part 24 of the GPDO grants a range of permitted development rights for telecommunicationscode system operators. These allow operators to carry out specified development, subject tocertain conditions and limitations, without the need to make a full planning application to theLPA. This development includes masts of 15 m and below. However, there are special provisionsregarding the installation of any mast in designated areas such as National Parks, Areas ofOutstanding Natural Beauty, Conservation Areas and Sites of Special Scientific Interest. In theseareas the installation of masts of 15 m and below do not enjoy permitted development rightsunder the GPDO. The installation of all masts in such areas is subject to a full planningapplication.
In general, permitted development under the GPDO is subject to various conditions andlimitations. For telecommunications permitted development in England and Wales the GPDOincludes an important additional control mechanism – the prior approval procedure. Followingchanges made in 1999 LPAs now have 42 days (rather than the previous 28) in which todetermine and notify whether they wish to approve the siting and appearance of ground-basedmasts. Operators are also now required to post a site notice to publicise the proposeddevelopment. These changes were designed to give the public a better opportunity to comment tothe LPA on its siting and appearance. There is also a statutory requirement for LPAs to consultthe relevant parish council, at the council’s request. Where the LPA considers that the proposeddevelopment would have a detrimental effect upon local amenity, it is able to refuse approval.
However, LPAs are advised to explore the scope for modifying its siting and/or appearancebefore doing so.
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For a number of other forms of telecommunications development under Part 24 of the GPDO the28-day prior approval procedure continues to apply. This includes masts installed on a buildingor structure. Although there is not a statutory requirement for operators (or LPAs) to publicisesuch proposals, LPAs are encouraged to give proposals publicity so that local people can maketheir views known.
It is a condition of the permission granted by the GPDO that apparatus that is no longer requiredfor telecommunications purposes should be removed as soon as reasonably practicable from theland or building on which it is located, and the land restored to its previous condition.
Policy guidance
In England, Government policy on planning for telecommunications development is set out in“Planning Policy Guidance Note 8” (PPG8), issued in December 1992. In Wales, similarguidance is to be found in “Planning Guidance (Wales): Planning Policy, First Revision” (April1999), together with Technical Advice Note (Wales) 19, “Telecommunications”, August 1998.
This guidance should be taken into account by LPAs as they prepare their development plans,and may be material to decisions in individual planning applications and appeals. It issupplemented by DETR Circular 4/99 and Welsh Office Circular 29/99 (“Planning forTelecommunications”), issued in June 1999 in parallel with the GPDO changes outlined inparagraph 6.101 above.
It is Government policy that the number of telecommunications masts should be kept to aminimum and to encourage mast sharing where appropriate. The licences issued to the fourexisting network operators require them to take all reasonable steps to investigate using, orreplacing, an existing mast or other structure before erecting a new mast. Where a new mast isrequired, operators are required to investigate co-operating with another operator in erecting amast for joint use.
Planning Circulars 4/99 and 29/99 underline the Government’s expectation that developersshould provide the LPA with clear evidence that they have fully considered the use of existingmasts, buildings and other structures before seeking to erect any new mast. If the evidenceregarding the consideration of such alternative sites is not considered satisfactory, the LPA maybe justified in refusing approval to the installation of the mast.
However, mast sharing is not always possible. Although an existing mast might be in closeproximity to a proposed site, the precise location and height of the existing mast may not becompatible with the operator’s network. The size of the mast will also affect the ability to mastshare; smaller masts may not be suitable for additional operators either because the structure isinadequate for the additional weight, or because there would be insufficient vertical separationbetween different sets of antennas to avoid interference. In addition, LPAs may consider themerits of mast sharing on a case-by-case basis. In some locations it may appear that a single largemast would have less impact, whilst in others it may be considered that several smaller masts,even in close proximity, are less visually intrusive.
The Government is keen to encourage early discussions between the operator and the LPA aboutproposed telecommunications development. Under a Code of Best Practice, issued by DETR in1998, for telecommunications prior approval procedures in England and Wales, operators areencouraged to provide information to the LPA on significant installation plans in the LPA areaand to undertake informal discussions on these plans. Close consultation between the operatorand LPA before an application for consent for telecommunications development is made willallow the two sides to examine locally not only alternative mast locations, including 123
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opportunities for site sharing, but also different design solutions. We understand thatconsideration is being given to extending this to include health concerns.
Draft guidance to LPAs in drawing up development plan policies or deciding planningapplications for development giving rise to electromagnetic fields, such as telecommunicationsbase stations, is contained in the joint DETR/DH draft circular, “Land-use Planning andElectromagnetic Fields (EMFs)”, issued for consultation in December 1998. A similarconsultation exercise was carried out in Wales by the then Welsh Office. The circulars will befinalised as soon as practicable. In July 1999 the then Minister for Public Health and the thenMinister for Planning jointly wrote to all Members of Parliament for constituencies in England,and to all Council Leaders in England, setting out the Government position about the possibilityof adverse health effects associated with telecommunications base stations. In October 1999, asimilar letter was issued in Wales by the two Assembly Secretaries with responsibility for healthand planning to all Members of Parliament for constituencies in Wales, all Assembly Membersand to all Council Leaders in Wales.
Scotland
In Scotland broadly similar permitted development rights apply to telecommunicationsdevelopment but with a number of significant differences. For example, the restrictions onpermitted development rights for masts in certain designated areas currently relate only to mastsfor “microwave antennas” (as defined in Scottish planning legislation) in National Scenic Areasand conservation areas. There are no prior approval procedures in Scotland fortelecommunications permitted development, the system in Scotland relying more upon theobligations contained in the telecommunications code system operator’s licence. This is also truein relation to the general condition requiring the removal of redundant telecommunicationsequipment that has benefited from permitted development rights.
The Scottish Executive intends to increase the controls on permitted development rights inScotland to a level approximating that in England and Wales, including the introduction of aprior approval regime. Work on the relevant legislative amendments is in hand and will beconsidered by the Scottish Parliament in due course. New guidance will also be issued to updatethat currently contained in the Scottish Executive’s Circulars 25/1985 and 5/1992. Similarly, aCode of Best Practice for telecommunications prior approval procedures, in the form of aPlanning Advice Note, is also intended. These documents will reflect the policies mentioned atparagraphs 6.104–6.109 above. The Scottish Executive produced its own version of the draftcircular on “Land-use Planning and Electro-Magnetic Fields”, which will also be finalised assoon as practicable.
The Scottish Parliament’s Transport and the Environment Committee recently produced areport entitled “Planning Procedures for Telecommunications Development” (ScottishParliament, 2000). This was prompted by public concern about mobile phone masts and theScottish Executive’s proposals to increase controls on permitted development rights (seeparagraph 6.111). The Committee concluded that the existing system was inadequate and thatchange was required. It expressed significant concern about the prior approvals process andrecommended the introduction of full planning controls. In addition, the Committee identifiedthree key factors that should inform policy in this area: amenity, health, and a precautionaryapproach.
In relation to amenity, the Transport and Environment Committee concluded that environmentalimpact could be minimised through early discussion of strategic network requirements, sitesharing, mast sharing, design and disguise, and the introduction of national roaming. Althoughguidance was required to minimise the impact of development on environmentally sensitive 124
Current Planning Procedures for Telecommunications Development
areas, this should allow for local flexibility. In relation to health the Committee decided thatwhilst there was no conclusive scientific evidence for non-thermal effects, there was reasonabledoubt about health risks, and it therefore recommended that health should be a material planningconsideration. It also recommended adopting a precautionary approach, and urged planningauthorities to consider a hierarchy of preferred locations that would favour development insparsely populated areas, such as industrial sites. However, the Committee concluded that therewas insufficient evidence to justify a cordon sanitaire.
The Committee recommended the development of a national policy framework in consultationwith interested bodies, including telecommunications developers and operators. Within thisframework the Committee identified a need for clear guidance based on a precautionaryapproach.
Northern Ireland
In Northern Ireland planning decisions are the responsibility of the Planning Service, a NextSteps Agency of the Department of the Environment. This Agency has six divisional offices andtwo subdivisional offices, each covering a number of district council areas.
As in England and Wales, larger developments, such as masts over 15 m high, require fullplanning permission. However, telecommunications code system operators enjoy permitteddevelopment rights for a range of developments under the Planning (General Development)Order (Northern Ireland) 1993, as amended by the Planning (General Development) (Amendment) Order (Northern Ireland) 1998. These rights are subject to limitations andconditions to protect amenity and the environment, and essentially mirror those in Englandand Wales.
Some permitted developments, such as erection of masts up to 15 m high, are conditional uponprior approval by the Planning Service. Under this procedure, the Planning Service has 28 days inwhich to whether to approve the site and appearance of the installation. Where it considers thatthe development would pose a threat to amenity, the Planning Service may refuse approval. InEngland and Wales the prior approvals process was modified by the Town and Country Planning(General Permitted Development) (Amendment) Order 1999, and similar changes are currentlybeing introduced in Northern Ireland. It is expected that these changes will be implemented in2000, and will extend to 42 days the period allowed for notification that prior approval isrequired, and the decision on whether to approve the siting and appearance of the installation.
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