RE: Application 2020/02153/TEL56

Proposed telecommunications installation: Proposed Phase 8 Monopole C/W

wrapround Cabinet at base & associated ancillary works.

Site Address - Talgarth Road, Brook Green, London Borough of Hammersmith and
Fulham, London, Greater London, W14 9DA

Dear Mr Opolot,

I write to you in my role as a trustee of The Study Society (TSS). The charity is located at
Colet House, 151 Talgarth Road, W14 9DA. Colet House is adjacent to Ealing
Hammersmith and West London College at the Junction of Gliddon Road and Talgarth Road
W14 9BL.

The applicant has asked the council whether permitted development rights applies.
It does not apply because:

(a) The proposal may affect the setting or context of a listed building; and
(b) The proposed development adjoins a conservation area and may affect its character
and appearance.

Planning permission is therefore, required, and we submit that the application should be
refused for the following reasons.

The purpose of The Study Society is to help support and educate the general public on
wellbeing and spiritual development. The charity has an office at Colet House, a library, a
residential flat (for a house manager who is currently on holiday), over 200 members, over
70 room hire clients, and thousands of visitors who come to the house for events, workshops
and educational gatherings every year: https://studysociety.org

Colet House has a culturally significant history and is regarded as a spiritual ‘home’ for me,
for all TSS members, teachers, and many of our room hire clients and visitors.

I completely object to the proposed 20 meter high telcom mast application currently
proposed by Hutchinson 3G on two counts:

1) negative potential impact of such a mast on the character, appearance and property
value of Colet House as an asset for the charity.

2) immense concern about future radiation to be pulsed from antennae on this mast based
on current ICNIRP guidelines of up to 300GHz. This would negatively impact my own
safety, health and wellbeing both as working board member and frequent visitor to Colet
house. And, the health of all working and visiting the house.

The application is defective in a number of material respects listed below:

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Major defects in the application

1. The site map does not adequately demonstrate how this 60 foot pole will look in its
setting. The application contains just two images which give any sense of what this
monolith will look like which are below:
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2. The first is a pretty picture, but it is not accurately drawn to show how it will look in its
setting. The second picture gives no sense of scale and dominance which these
proposals will manifest.

3. How is anyone supposed adequately to comment on an application such as this with

just these two images which misrepresent the true nature of the visuals of these
proposals?

4. Instead, The Study Society has prepared true visuals of what this 60 foot monolithic
pole will truly look like when in place, in its setting.

Pic 1 – we start with its setting against the conservation area. The parts shaded in green on
the image below are the conservation areas of this district. The red star on this image
shows where the 60 foot pole will be placed with its attendant massive cabinets which look
to be at least 5 feet tall and which will also dominate the site.
 4

Pic 2

This is not an accurate image of the proposed pole with its attendant antennae but is a mock
up of what the height of the pole will look like (taken from other masts of a similar height) in
its setting. The mock up pole is sited in the spot in which these proposals propose to place
the pole. You will see its dominance clearly and the impact of its cabinets outside of this
college.
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Pic 3

There are the beautiful listed buildings on the other side of the street against which this
dominant structure will be set. While the structure will be on the other side of the road, this
shows the scale of the structure against the listed buildings opposite.

Pic 4

This is the same view without the 60 foot pole for comparison purposes.
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Pic 5

This is a stretched shot to show the visuals of this 60 foot pole against the setting of the
street and the view along the road. You can see the dominance of the structure against the
skyline.

Pic 6

Another view
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Pic 7 - And again.

5. Why have these views been prepared by the applicant for an accurate assessment of
the proposals and so that the public can comment properly on the true impact of
these proposals? In particular the distant vistas are important and have totally been
ignored by the applicant. See further below.

6. The pole in the picture at Pic 1 we suggest is misrepresentative of the true scale of
these proposals. The picture shows a slim pole which is made to look as unobtrusive
as possible.

7. Below is a picture of a 60 foot pole with a similar antennae configuration in an

application by the same mobile service provider to Camden Council which was
rejected by Camden Council. You will see a different configuration at the top. Given
that it’s the same kind of 60 foot pole and configuration, we submit that the drawing
sent to you is not a true representation of the eventual pole which will be fitted.

8. Of course, once planning permission is given, the service provider can put up
whatever they want on the top of the pole. But it is incumbent on the service provider
to provide accurate drawings and we suggest that these drawings are not accurate.
 8

9. There is no information about the frequency or power to be used for the equipment or
any other information to give interested parties information to be able to comment
appropriately on the application.   The Stewart Report on which Public Health
England relies recommends that operators should provide information about the
frequency and modulation characteristics and the power output of antennae. None of
this has been provided.

10. None of the General Principles for Telecoms Development in the Code have been
adhered to.  The Code states:

“General Principles for Telecommunications Development

...  Sensitivity to context of the proposed development should be considered.

In particular, the following general design principles should be regarded as
important considerations in respect of telecommunications development:

•        Proper assessment of the character of the area concerned, especially in

relation to designated heritage assets and their setting, where more
sensitive design solutions may be required
•        Design should be holistic and three dimensional showing an
appreciation of context;
•        Analysis of the near and far views of the proposal and to what extent
these will be experienced by the public and any residents;
•        Proposals should respect views in relation to existing landmarks and
distant vistas;
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•        Proposals should seek to consider the skyline and any roofscapes
visible from streets and spaces;
•        Choice of suitable designs, materials, finishes and colours to produce a
harmonious development and to minimise contrast between equipment
and its surroundings.”

11. In addition, Hammersmith and Fulham council’s planning policies stated below have
not been complied with for the reasons set out below:

Policy DC10 states:

...
b. the siting and appearance of the proposed apparatus and associated
structures should be compatible with the scale and character of existing
development, their neighbours and their setting, and should minimise impact
on the visual amenity, character or appearance of the surrounding area;

c. the siting and appearance of the apparatus and associated structures

should not have an unacceptable impact on conservation areas, listed
buildings, buildings of merit or areas of open space; and d. where
appropriate, proposed apparatus and associated structures should share
locations where there is an existing facility.

12. The height of the proposed structure is out of keeping with the character and setting
of the area.  It is clear that there are no tall buildings in the area – it is a low rise area.
The tower of the college in front of which this structure in the area. This 60 foot pole
will dominate the area and be totally out of keeping with the environment.

13. The siting is not sensitive to the area.  The structure will be able to be seen from
many angles and will detract from the character of the area which has conservation
areas on three quarters of the area concerned.  The skyline of the area will be ruined
as the structure will be prominent in this area.

14. This part of Talgarth Road, which is directly outside of the Ealing Hammersmith and
West London College heaves with people during its busy times. This pole is to be
sited with cabinets in the middle of what is a very busy pedestrian way and right next
to traffic lights and a pedestrian crossing. Just look at the size of the equipment
which will be placed in the middle of the pathway. The size of the pole to hold up the
weight of the antenna at 60 feet is considerable. The cabinets to make this work are
massive.

15. It is totally unacceptable that this monolith should be placed in the middle of a very
busy pedestrian footway in a very busy environment where the crush of people
coming out of the college all day on busy days is a real threat on a daily basis. This
monolith is not sensitively sited at all.

16. The height of the nearest part of the nearest building, which is the college, is 10m
according to the applicant’s measurement. The tower which is further back, is 20m.
 10

This protuberance will be 10m more above the nearest part of the nearest building
and will be visible from every angle for miles.

17. There is no information on the kinds of 5G antennae to be placed on the pole and
whether or not they are beam forming.

18. There is no information on the height of the “wrap around” cabinet to go around the
base of this pole. There is no information on the diameter of the pole so that one can
properly understand the visual impact.

19. It is not clear how many antennae will be placed on the pole.

20. There is no impact assessment for the impact on the disabled who may be blind and
having to navigate this stretch of footway. Having such a big obstruction in the
middle of the pathway is a health and safety hazard. The council must carry out its
public sector equality duty and do an impact assessment in relation to this
application. The application should be refused in the meantime.

21. This is the largest structure of this kind proposed at this intersection. It will be
prominent against the skyline and be totally out of character with the area and will
detract from it.

22. The site specific supplementary information document has not mentioned whether
there are other operators in the area which means that there may be other equipment
with other antennae in the area. Paragraph 115 of the NPPF requires that
applications should be supported by the necessary evidence to justify the proposed
development which should include:

“b) for an addition to an existing mast or base station, a statement that self-
certifies that the cumulative exposure, when operational, will not exceed
International Commission guidelines on non-ionising radiation protection”

23. There are likely to be other masts or base stations in the area. There is no statement
with the application on the planning website that cumulative exposure from this
antennae with all the other antennae in the area will not exceed ICNIRP guidelines.

24. The area where this massive pole is proposed to be installed is also a residential
area. It may be helpful to set out some of the guidance of the Stewart Report in
relation to its advice to the UK government.

You can see the summary and recommendations below:

https://webarchive.nationalarchives.gov.uk/20100910162959/http://www.iegm
p.org.uk/report/text.htm

Planning issues

1.31 ...
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Adverse impacts on the local environment may adversely impact on the

public’s well-being as much as any direct health effects.

1.34 We perceive a lack of clear protocols to be followed in the public

interest prior to base stations being built and operated and note that
there is significant variability in the extent to which mobile phone
operators consult the public on the siting of base stations. We have
heard little specific criticism of most of the network operators, apart
from Orange. The Department of the Environment, Transport and the
Regions and the National Assembly for Wales (DETR, 1998)
produced a Code of Best Practice: Telecommunications prior approval
procedures as applied to mast/tower development. We understand
that consideration is being given to extending this to include health
concerns (paragraphs 6.104–6.109). We support this development.

1.35 Overall we consider that public concerns about the siting of base
stations demand changes in the planning process. Thus:

...

1.37 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 new base station
(paragraphs 6.58–6.62). We consider the protocol should cover the following
issues.

...

• The operator should provide to the local authority a statement for each site
indicating its location, the height of the antenna, the frequency and
modulation characteristics, and details of power output.

1.38 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 (paragraphs 6.55–6.62).

1.39 We recommend that a national database be set up by Government

giving details of all base stations and their emissions. This should include the
characteristics of the base stations as described in paragraphs 6.47 and 6.48
and should be an essential part of the licence application for the site.

1.40 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 if there is significant departure from the stated
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characteristics, then the base station should be decommissioned until

compliance is demonstrated (paragraphs 6.53
and 6.54).

1.43 We recommend that in making decisions about the siting of base

stations, planning authorities should have the 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 (paragraphs 6.55–6.62).

25. There is no information about the exclusion zone which will apply to these antennae.
The propagation of waves of 5G masts are different to 2G – 4G masts and have a
wider exclusion zone. It is important to see the diagram with the propagation of
waves from these antennae.

26. This mast is above the roofs of the college. It will be important to know whether the
exclusion zones for these antennae impact the roofs of these buildings because it
means that workmen on these roofs will be subject to excessive levels of radiation if
they are within the exclusion zones for these antennae. There is no information in the
application about this potential health hazard.

27. Apart from the Code, there is no proper guidance to a local council about how to
consider applications for masts. At present, the information which is being presented
by all operators is inadequate to permit a proper consultation with the public through
the planning permission structure. The lack of information is systemic and pervasive.

28. The supplementary information states the following:

School/College

Location of site in relation to school/college:

James Lee Nursery School, Parayhouse School and West London College are located
within 200m of the proposed site.

Outline of consultation carried out with school/college:

The above were sent a letter of consultation prior to submission of the application.

Summary of outcome/Main issues raised:

N/A

29. The Ealing Hammersmith and West London College which is immediately next to the
proposed site has not received any notification of these proposals. The buildings
opposite, including The Study Society, has not received any notification of these
proposals.
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30. The Study Society rents rooms at Colet House to LAMDA (London Academy of
Music and Art). LAMDA students of different ages gather at Colet throughout the
year

(a) Theatre students -university age (eg 18-21). 

(b) Summer school: teenagers (15-16)

(c) LAMDA hires space at Colet for weekend exams with kids (how to speak
confidently).  eg: 60-120 kids which include  primary age kids with parents.

31. We would challenge the applicant to produce the letters of consultation which they
say that they sent to nearby schools.

32. Para 113 of the NPPF states:

“Where new sites are required (such as for new 5G networks, or for
connected transport and smart city applications), equipment should be
sympathetically designed and camouflaged where appropriate

33. It cannot be said that these proposals comply with para 113 at all. The pole is not
sympathetically designed or camouflaged. It is gigantic and very visible.

34. The applicant has provided no information as to why this site was chosen or included
any evidence.

35. Hammersmith and Fulham council’s planning policies include the following (bold is
our emphasis):

Policy DC8 states:

The council will conserve the significance of the borough’s historic

environment by protecting, restoring and enhancing its heritage assets. These
assets include: listed buildings, conservation areas historic parks and
gardens, the scheduled monument of Fulham Palace Moated site,
unscheduled archaeological remains and buildings and features of local
interest. When determining applications affecting heritage assets, the council
will apply the following principles:

a. the presumption will be in favour of the conservation, restoration and

enhancement of heritage assets, and proposals should secure the long
term future of heritage assets. The more significant the designated heritage
asset, the greater the presumption should be in favour of its conservation;
b. applications affecting designated heritage assets, including alterations and
extensions to buildings will only be permitted if the significance of the heritage
asset is conserved or enhanced;
c. applications should conserve the setting of, make a positive
contribution to, or reveal the significance of the heritage asset. The
presence of heritage assets should inform high quality design within their
setting;
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d. applications affecting non-designated heritage assets (buildings and

artefacts of local importance and interest) will be determined having regard to
the scale and impact of any harm or loss and the significance of the
heritage asset in accordance with paragraph 135 of the National planning
Policy Framework;
e. particular regard will be given to matters of scale, height, massing,
alignment, materials and use;
f. where changes of use are proposed for heritage assets, the proposed use,
and any alterations that are required resulting from the proposed use should
be consistent with the aims of conservation of the asset’s significance,
including securing its optimum viable use;
g. applications should include a description of the significance of the
asset concerned and an assessment of the impact of the proposal upon
it or its setting which should be carried out with the assistance of a suitably
qualified person. The extent of the requirement should be proportionate to the
nature and level of the asset’s significance. Where archaeological remains of
national significance may be affected applications should also be supported
by an archaeological field evaluation;
h. proposals which involve substantial harm, or less than substantial harm to
the significance of a heritage asset will be refused unless it can be
demonstrated that they meet the criteria specified in paragraph 133 and 134
of the National Planning Policy Framework

36. The above policies are clearly aimed at achieving the highest standard of design in
all developments including developments of the highest urban design quality, which
improves the function, appearance and character of the area.

37. The policy also states that the council will preserve, and where appropriate, enhance
Hammersmith and Fulham’s rich and diverse heritage assets and their settings. This
equipment is very prominent and will cause unacceptable visual harm to the area.
The cabinets are fully visible from the street and not camouflaged in any way and
would cause harm to the character and appearance of the adjoining conservation
areas.

38. The height and location of the pole and equipment will make the equipment very
prominent and clearly visible in long and short range views from all directions.

39. The site is in a very sensitive location adjacent to several heritage assets including
the 3 conservation areas which abound it and listed buildings which are on the other
side of the road, directly across from it. The proposed telecommunications
equipment will cause unacceptable harm to the character and appearance of the
three adjacent conservation areas on account of its prominence in the street scape,
where it would be highly noticeable against the skyline and clearly visible from public
views.

40. The height of the pole and the antennas would upset the largely uniform, low rise and
uncluttered roof scape when viewed from within the adjoining conservation areas and
would appear unsightly when viewed from and towards these conservation areas.
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41. The bulk of the pole, its base and the cabinets would be clearly visible in views along
Talgarth Road with the listed buildings opposite the site and their overall appearance,
quantity and visibility will cause harm to the historical setting of the listed terrace.

42. Therefore, from the bulk, height and prominent siting, it is submitted that these
proposals will result in a proliferation of harmful visual clutter which would be
unattractive and over-dominant in the area and would cause harm to the character
and appearance of the adjoining conservation areas and wider townscape.

43. There is insufficient information to determine this application and we would invite
Hammersmith and Fulham Council to refuse this application.

44. The Code of Best Practice on Mobile Network Development in England has a traffic
light model which developers are required to use. This is a sensitive site being right
outside of a college and more consultation with the local community should have
taken place. This did not happen. Appendix 4 of the Code is at Schedule 2. This
type of consultation did not take place with The Study Society or the Ealing
Hammersmith and West London College.

45. On the basis of the above, we invite the Council to refuse this application on the
grounds of inappropriate siting and design.

Issues about health

46. I now turn to the issues of health. 

47. The NPPF states the following:

116. Local planning authorities must determine applications on planning

grounds only. They should not seek to prevent competition between different
operators, question the need for an electronic communications system, or set
health safeguards different from the International Commission guidelines for
public exposure.

48. This states that local planning authorities should not “set health safeguards different
from the International Commission guidelines for public exposure”. 

49. We appreciate that the council cannot do that.  But, the council has an obligation to
safeguard the health of its constituents by virtue of s. 2B of the National Health
Service Act 2006 (bold is my emphasis):

2B         Functions of local authorities and Secretary of State as to

improvement of public health
(1)         Each local authority must take such steps as it considers appropriate
for improving the health of the people in its area.
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(2)         The Secretary of State may take such steps as the Secretary of State
considers appropriate for improving the health of the people of
England.
(3)         The steps that may be taken under subsection (1) or (2) include—
(a)         providing information and advice;
(b)         providing services or facilities designed to promote healthy living
(whether by helping individuals to address behaviour that is
detrimental to health or in any other way);
(c)         providing services or facilities for the prevention, diagnosis or
treatment of illness;
(d)         providing financial incentives to encourage individuals to adopt
healthier lifestyles;
(e)         providing assistance (including financial assistance) to help
individuals to minimise any risks to health arising from their
accommodation or environment;
(f)          providing or participating in the provision of training for persons
working or seeking to work in the field of health improvement;
(g)         making available the services of any person or any facilities.
(4)         The steps that may be taken under subsection (1) also include
providing grants or loans (on such terms as the local authority
considers appropriate).
(5)         In this section, “local authority” means—
(a)         a county council in England;
(b)         a district council in England, other than a council for a district in a
county for which there is a county council;
(c)         a London borough council;
(d)         the Council of the Isles of Scilly;
(e)         the Common Council of the City of London.

50. Your council also has obligations to safeguard the health and safety of its residents
under the following (bold is my emphasis):

Heath and Safety at Work Act 1974

3 General duties of employers and self-employed to persons other than

their employees.
(1) It shall be the duty of every employer to conduct his undertaking in such
a way as to ensure, so far as is reasonably practicable, that persons
not in his employment who may be affected thereby are not
thereby exposed to risks to their health or safety.

51. It must also promote the wellbeing of its residents under (again bold is my emphasis):
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(a) Care Act 2014

Promoting individual well-being

(1) The general duty of a local authority, in exercising a function under
this Part in the case of an individual, is to promote that individual’s
well-being.
(2) “Well-being”, in relation to an individual, means that individual’s well-
being so far as relating to any of the following—
(a) personal dignity (including treatment of the individual with respect);
(b) physical and mental health and emotional well-being;

52. These are positive duties on the council.  This is in conflict with the NPPF.  Where
there is a conflict, the health considerations take precedence. 

53. The government is not indemnifying Councils and its councillors against action taken
against them for failure to safeguard the health and safety of their constituents, a
duty which all councils have under the legislation set out above.

54. A Court of Appeal decision confirmed that it is a human right under Article 6 of the
Human Rights Convention for a resident to make representations about health to its
council – Nunn, R (on the application of) v First Secretary of State and Ors England
and Wales Court of Appeal (Civil Division) (8 Feb, 2005).

https://www.casemine.com/judgement/uk/5a8ff71360d03e7f57ea72fd

55. This decision refused the right of appeal to the Supreme Court so stands as the law
of the UK. Councils in the UK have been interpreting the NPPF incorrectly by
considering that they cannot consider issues of health when considering planning
appeals.

56. The case of Nunn is clear that, regardless of the national planning policy framework
(NPPF) it is a human right under Article 6 to make representations about health and
the value of one’s home and the homes in the local area. 

57. In this case the judges confirmed that it “was right to make representations to the
LPA on effects on health and on the appearance of masts as it affected them and the
value of their homes”.  

58. The council must interpret the law so as to be compatible with human rights. Those
in Articles 2, 6 and 8 are relevant here.

59. So, while the council may not “set health safeguards different from” the International
Commission guidelines, it can take health into account in relation to considering
whether these proposals are permitted by the council.

60. Please see in the document below concerns about 5G and the health impacts.
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https://www.scribd.com/document/473893147/5G-health-impact-briefing-final-as-
sent-20-8-20-docx
 
61. Schedules to the note are below:

https://www.scribd.com/document/473893296/5G-health-impact-briefings-schedules-
final-as-sent-20-8-20-docx
 
62. The first is a report on the health impacts and the second are schedules to support
the statements made in the first report. 

63. It is important that Hammersmith & Fulham Council consider the health impacts now.
This is not simply about 5G but about manmade radiofrequency radiation (RFR) in
general.

64. The current ICNIRP electromagnetic frequency radiation (EMR) also known as
radiofrequency radiation (RFR) guidelines are not fit for purpose in that they only
address EMF heating (thermal) effects and not the many other potential effects at
cellular or physiological level.

65. The government and the telcoms industry are presenting 5G roll out as just more of
the same as with 2G-4G with no further radiation risk. The ICNIRP certificate
attached to the application for this mast is laying the groundwork for a massive
expansion of man-made radiation up to 300GHz. For comparison purposes a
microwave oven uses 2.5 GHz as do Apple airpods.

66. The earth has its own electromagnetic fields which is referred to as the Schumann
Resonance at 7.83 Hz. The frequency of our brain waves is also at 7.83 Hz. We are
electrical and magnetic beings and our cells interact directly with magnetic stimuli.

67. There is already a huge body of work by specialist biochemists, scientists and
doctors citing adverse the effects on health of prolonged exposure to high frequency
EMF radiation at levels well below the ICNIRP recommended maximum guidelines.
The members of ICNIRP, the EU’s SCENHIR and the WHO EMF project represent a
minority view amongst scientist and health researchers around the world.

68. Based on the information in the links above, it is clear that there are substantial
adverse health impacts from electromagnetic radiation (“EMR”) which includes 5G.

69. One of the recent articles (Mar 2020) setting out the adverse health effects of 5G is
below:

https://www.scribd.com/document/463599697/Adverse-Health-Effects-of-5G-Mobile-
Networking-Technology-Under-Real-life-Conditions

70. EMR is particularly dangerous for children and the route immediately next to this
proposed site is used by thousands of children going to and from college and the
Lamda school every day.  A statement from Professor Anthony Miller is at Schedule
1 to this note.  Please note his comments as regards children:
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“Of particular concern are the effects of RFR exposure on the developing
brain in children. Compared with an adult male, a cell phone held against the
head of a child exposes deeper brain structures to greater radiation doses per
unit volume, and the young, thin skull’s bone marrow absorbs a roughly 10-
fold higher local dose.” 

71. There are a lot of children who visit this area and who live there.

72. See also this article on the Clear Evidence of Harm to Children from radiofrequency
radiation which is produced by the type of antennae to be erected in this application:

https://www.gr3c.com/wp-content/uploads/2019/02/On-the-Clear-Evidence-of-the-
Risks-to-Children-from-Smartphone-and-WiFi-Radio-Frequency-Radiation_Final.pdf

73. On the basis of the above and the wholesale failure of the Applicant to comply with
the Code of Best Practice, this application must be refused and I call on the council
to refuse this application.

18.9.20
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SCHEDULE 1

Statement on 5G by Anthony B. Miller, MD, FRCP, CM. Professor Emeritus, Dalla Lana
School of Public Health, University of Toronto, Toronto, ON, Canada.
Radiation exposure has long been a concern for the public, policy makers and health
researchers. Beginning with radar during World War II, human exposure to radio-frequency
radiation (RFR) and associated technologies has grown more than 100,000-fold. In 2011,
the International Agency for Research on Cancer (IARC) reviewed the published literature
and categorized RFR as a ‘possible’ (Group 2B) human carcinogen. A broad range of
adverse human health effects associated with RFR have been reported since the IARC
review, including brain cancer. In addition, two large-scale carcinogenicity studies in rodents
exposed to levels of RFR that mimic lifetime human exposures have shown significantly
increased rates of Schwannomas and malignant gliomas, as well as chromosomal DNA
damage.
Of particular concern are the effects of RFR exposure on the developing brain in children.
Compared with an adult male, a cell phone held against the head of a child exposes deeper
brain structures to greater radiation doses per unit volume, and the young, thin skull’s bone
marrow absorbs a roughly 10-fold higher local dose.  Recent reports also suggest that men
who keep cell phones in their trouser pockets have significantly lower sperm counts and
significantly impaired sperm motility and morphology, including mitochondrial DNA damage,
as well as an increased risk of colon cancer.
Based on the accumulated evidence, I believe that if IARC were to re-evaluate its 2011
classification of the human carcinogenicity of RFR, it would be categorized as Group
1, i.e. carcinogenic to humans. Thus, current knowledge provides justification for
governments, public health authorities, and physicians/allied health professionals to support
measures to reduce all exposures to RFR to As Low As Reasonably Achievable, something
we learnt was necessary for exposures to ionizing radiation (e.g. X-rays) many years ago.
The Telecom industry’s fifth generation (5G) wireless service will require the placement of
many small antennae/cell towers close to all recipients of the service, because solid
structures, rain and foliage block the associated millimeter wave RFR. 5G technology is
being developed as it is also being deployed, with large arrays of directional, steerable
antennae, operating at higher power than previous technologies. 5G is not stand-alone – it
will operate and interface with other (including 3G and 4G) frequencies and modulations to
enable diverse devices under continual development for the “internet of things,” driverless
vehicles and more.
This novel 5G technology is being rolled out in several communities, although potential
chronic health or environmental impacts have not been evaluated. The range and magnitude
of potential impacts of 5G technology are under-researched, although important biological
outcomes have been reported with the associated millimeter wavelength exposure to RFR.
These include oxidative stress and altered gene expression, effects on skin and systemic
effects such as on immune function, all of which highlight the need for research before
population-wide continuous exposures occur.

An individual, if appropriately informed, can reduce her or his exposure to radiofrequency

radiation from devices inside their home, but in the case of cell towers and small cell
transmitters of 5G the exposure they receive is outside their control. With the people who
manufacture these devices and those who promote small cell technology in front of homes
 21

failing to issue adequate health warnings, we are reaching a situation where homes,
schools, and workplaces are being saturated with radiofrequency radiation.
Thus, to avoid a potential epidemic of cancer caused by radiofrequency radiation from small
cell transmitters and other devices, and heart damage, brain damage and infertility, we
should introduce means to reduce such exposures to As Low As Reasonably Achievable,
something we learnt to do many years ago for ionizing radiation (X-rays). Instead use fiber-
optic connections to the home, place small cell transmitters away from residential
neighborhoods and schools and strengthen the rules that are meant to protect the public. 
Those who support the introduction of 5G should recognize that no insurance agency
(including Lloyds of London) will cover them against liability from ill health effects caused by
radiofrequency radiation.
A moratorium on the roll-out of 5G is essential.

                                               February 12, 2020

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SCHEDULE 2

Appendix D: Consultation with Schools and Colleges

Since 2001, planning guidance has advised that, where it is proposed to

install, alter or replace a mobile phone base station on or near a school or
college, operators should discuss the proposed development with the
relevant body of the school or college of further education concerned
before submitting an application for planning permission or prior approval
to the local authority. This guidance was originally drawn up when mobile
telephony was relatively new, when there had been much less research
into its possible effects, and when public concern about mobile phone
masts was greater than it is now. Since then, there has been a great deal
of research into the possible health effects of mobile phone technology
and The World Health Organisation’s current advice12 is that a large
number of studies have been performed over the last two decades, and
that to date, no adverse health effects have been established as being
caused by mobile phone use. The World Health Organisation’s agency,
the International Agency for Research on Cancer has concluded that
‘typical exposures to the brain from mobile phone base stations are
several orders or magnitude lower than those from handsets.’

Nevertheless operators recognise that some parents can be concerned

about the possible health effects of mobile phone masts, and therefore, as
a matter of good practice, carry out a specific pre-application consultation
exercise with schools and colleges where appropriate. This will give them
the opportunity to feed in their comments and concerns and to have them
considered by the operators at an early stage. However, it is important to
reiterate that there is no evidence that supports any health-related
concerns about masts that operate within international guidelines. Health
and safety issues are dealt with under a separate regulatory regime.
Operators should discuss and agree with local planning authorities in
advance which particular schools and colleges should be consulted. In
any cases of doubt, consultation with the school or college should be
undertaken. The following guidelines may be of help in determining which
schools or colleges should be consulted.

A school is an institution providing education for children within the

nursery (2-5), primary (5-11), and secondary (11-16) education ranges.
Schools can be maintained (i.e. funded by Government through local
education authorities) or non-maintained/independent (i.e. funded and run
by other means).

A college of further education is an institution providing full- or part-time

education for students over the age of 16. This includes sixth form
colleges (16-19). Institutions may be maintained by a local education
authority, a further education corporation (e.g. the institution’s governing
body) or be an institution designated under section 28 of the Further and
Higher Education Act 1992.
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Where school or college playing fields are separate from the institutions
themselves the guidelines should be applied to the playing fields
separately.

There are no hard and fast rules for determining whether a base station is
near a school or college for the purposes of pre-application consultation.
The institutions concerned need to be considered on a case-by-case
basis, in the light of local circumstances.

In determining whether a school or college should be consulted the

following factors should be taken into account by operators and local
planning authorities:

 The proposed site is on school/college grounds;

 The proposed development would be seen from the school/college
or its grounds;
 The site is on a main access point used by pupils/students to the
school/college;
 There is a history of concern about base stations within the local
community;
 The local planning authority has requested consultation with the
school/college;
 The school/college has requested that it be included in any
consultation (Department for Education and Science has advised
schools and colleges that if they wish to be consulted about base
station in their locality they should notify the local planning authority
setting out the circumstances in which they would wish to be
consulted).

For consultation purposes the following actions should take place as a

minimum:

 Two copies of the standard letter (see below) should be sent

recorded delivery to the school/ college, one to the Head Teacher
(or Principal in the case of Further Education Colleges) and one to
the chair of school governors or equivalent body for Further
Education colleges.

 The operator should wait a minimum of 14 days from the date of

the letter to allow an opportunity for the school to respond prior to
submitting an application for planning permission or prior approval.

To ensure a complete record of the consultation process is kept, a copy of

the completed consultation assessment and any consultations with the
school/college should be retained on the operator’s site files. This will
ensure accurate records that can be referred back to in discussions with
the local authority in respect of any subsequent planning submission.
Copies of the consultations undertaken should be included with any
subsequent application if required by the local authority.