ComReg’s Draft Electronic Communications Network and Services Strategy Statement 2023-2025 – Submission Ethna Monks

Commission for Communications Regulation – Public Consultation – ComReg 22/109b 

Public Consultation on ComReg’s Draft Electronic Communication Network and Services (ECN and ECS) Strategy Statement 2023-2025. 

Submitted: 9th February, 2023

ComReg’s draft ECN/ECS Strategy Statement notifies us that its role is ‘to ensure that communications markets operate in the interests of end-users and society’. Basic tenets include the facilitation of competition in the market, encouragement of innovation and protection of consumers.

Thank you for the opportunity of expressing a response to the public consultation of ComReg’s Draft ECN/ECS Strategy Statement which will be perused from the point of view of those in our population (considered to be 5% or upwards) who are suffering from Electrohypersensitivity (EHS)/microwave sickness. See: Digitalisation: Challenges for Europe, European Economic and Social Committee, page 85.

Electrohypersensitivity/microwave sickness is an environmental impairment emanating from the use of Electromagnetic/Radiofrequency fields (EMR) and mainly due to over-exposure to pulsed microwave radiation emissions from modern technological devices. Use of this technology is novel in human experience and biological effects were not anticipated however current scientific studies provide clear evidence of effects of EMR on all living things, even well below the standards that are currently being used to monitor infrastructure and devices placed on the market by economic operators.

For evidence of the negative health effects of exposure to EMR pulsed microwave radiation, access: The BioInitiative Report (2012) (, a study that is based on evaluation of research papers by a group of worldwide renowned independent scientists and medical experts.

Clear evidence of harm is also demonstrated in the largest study undertaken to date i.e. The National Toxicology Program, by the U.S. National Institute of Environmental Health Sciences (NIEHS). ( This study contains evidence regarding the link between mobile phone radiation and cancer as well as DNA damage.

The findings of the NTP are mirrored in a report published by the Ramazzini Institute, Italy (2018) on exposure to radiofrequency generated by mobile phone base stations. (

With regard to the five Questions contained in the Consultation Document – these are answered within the following statements under the Sections corresponding to those in the ECN/ECS: 


(1) SECTION: 4.2 Consumer Harm; 

As part of its Role, ComReg holds statutory responsibility for a range of developments in regulations, including the regulation of the radio spectrum being used to power the Electronic Communications Networks (ECN). Currently, standards used for monitoring are grounded in guidelines that have been created by the International Commission on Non-Ionising Radiation Protection (ICNIRP) – a non-governmental organisation. The ICNIRP are recognised as an expert group on the subject of Electromagnetic Fields/Radiofrequency (EMR) and with financial support from the World Health Organisation and many countries established a co-organisation i.e. the International EMF Project. There are numerous concerns expressed regarding the use of the ICNIRP Standards. They are considered to be ambiguous and obsolete as they do not take the majority current scientific findings into account. In Ireland it seems that the ICNIRP guidelines bypassed the approval of the Houses of the Oireachtas by being adopted directly into the licensing practice of ComReg. The ICNIRP standards refer only to the heating/thermal effects of EMR and are based upon experiments undertaken in the 1950s on dummy heads that supposedly mimicked a human head. Major agreement currently exists amongst scientists that the ‘heat’ only measurement is out-of-date and misleading and there is a general acceptance that the mechanistic basis behind biological effects arise chiefly through the non-thermal effects of EMR.

Further information and evidence regarding issues with the ICNIRP’s standards and the use of the Specific Absorption Rate as grounds for monitoring is contained in the submission by ES-Ireland to Irish Government Departments and also to ComReg in 2021. ‘Are the Electromagnetic Radiation Guidelines Currently being used … Protective of our Health? This can be accessed at:

(2) Section 6.2.2 Compliance and Enforcement in the context of Product Safety;  

       and Section 4. 2 Consumer Harm. 

Compliance and enforcement in the context of Product Safety requires monitoring of the EMR radiation being emitted from various technological devices that use radiofrequency. It appears that no market surveillance body has been set up as yet in Ireland to assess devices using radiofrequencies despite EU Directive 2014/53/EC. French Authorities currently undertake this work, particularly regarding mobile phones. The French National Agency of Frequencies discovered that 9 out of 10 mobile phones emitted more radiation than the EU regulatory threshold of 2W/kg. Also, mobile phones were being measured as if the public were holding them at least 5mm from their bodies, as directed by the Telecom industry in their terms and conditions of use. At present 38 models of mobile phones have been found to violate limit values for radiation.

In 2020 the French National Agency for Food, Environment and Occupational Health and Safety (ANSES) sent a formal objection to the European Commission regarding the way mobile phones are being assessed, requesting that they be measured at 0mm i.e. directly against the body.

Further information and evidence is contained in the letter emailed to ComReg on 7th February, 2023 regarding issues around non-compliance with EU Directive 2014/53/EC.

See Appendix (1)

(3) Section: 4.9 Consumer Complaints and Redress 

It is noted that the Breakdown of Issues Logged (Queries/Complaints) 2017 to 2022 in the ECS does not contain any information about the many complainants who made contact with ComReg over many years regarding their experience of Electrohypersensitivity/microwave sickness or, and concerns about ComReg’s use of the ICNIRP/SAR standards.


SECTION: 3.4.4 Legacy Networks

ComReg expresses its intention to migrate from legacy network landline phones to replace them with “reliable connectivity using modern technology”. ComReg also acknowledges that extensive consultation and planning will be required in order to protect end-users (including vulnerable end-users at all stages of the process).

In May 2022 ES-Ireland responded to ComRegs public consultation on the Migration from Legacy Infrastructure to Modern Infrastructure, thereby becoming involved in the discussion regarding the removal of copper system landlines. It is noted that no definitive decision has been made as yet as ComReg continues to give consideration to the responses.

ES-Ireland’s submission considered the affect of this transition on vulnerable and elderly people – especially in the event of an electrical power cut (which by all accounts we are to expect more of), or the Internet being ‘down’. The effects of this transition on the population who suffer from electrohypersensitivity/microwave sickness and their difficulties in using technological devices emitting pulsed microwave or millimeter wave radiation is spelled out in this submission.

Further information and evidence is contained in the Submission sent to ComReg (22.13) May 2022

Section: 4.13 Environmental Sustainability 

               and Section 5.44 reference to Climate Change  

 A few issues are constantly referred to in most reports on the subject of climate change and sustainability i.e. carbon emissions and green house gases and the response promulgated is to stop using coal/kerosene/petrol and ‘move forward’ through progression into an electrical era i.e the use of man-made artificial electromagnetic/radiofrequency fields. ComReg’s Strategy Statement denotes its awareness of terms such as sustainability and energy efficiency. Concern is expressed about resilience of the ECN, however, no recognition appears to have been taken regarding, for example, the environmental cost of moving data to the cloud, or of E-Waste – with over 60 million metric tons generated globally made up of discarded electronic devices, or indeed the hundreds of thousands of satellites using rockets and rocket fuel to locate them into position surrounding the Earth.

In May 2021, in response to a Consultation on the Strategic Environmental Assessment Environmental Report for the Climate Action and Low Carbon Development (Amendment) Bill 2021, a submission was forwarded on behalf of ES-Ireland to the Department of the Environment, Climate and Communications (DECC). This submission addressed the negative effects of radiofrequency pulsed microwave emissions on humans, wildlife and all living things, and highlights the issues of E-Waste and Satellites/Rockets.

Further information and evidence can be accessed at:

In the December 2018 issue of the medical journal The Lancet, comment was made by the independent Oceania Radiofrequency Scientific Advisory Association ‘Planetary Electromagnetic Pollution: It is Time to Assess its Impact.’ The comment was based upon an evaluation of 2,266 peer-reviewed studies on the effects of EMR on the biological systems of humans, animals and plants and it concluded that 68.2% of the conclusions identifying negative effects were proven to be true – without doubt.

We need to protect our environment and biodiversity with all its living things, which are currently being damaged by EMR pulsed microwave radiation. A study by Dr Ulrich Warnke and his team sums up why we need to care: Bees, Birds and Mankind, Destroying Nature by ‘Electrosmog’.

Fifth Generation: 5G 

There seems to be great haste to establish fifth generation broadband (5G) and infrastructure for the ‘Internet of Things’. This will involve the use of millions of microwave and millimeter wave antennas and also earth surrounding satellites that will transmit 5G and wireless signals to earth from space, all using pulsed radiofrequency radiation.  

 On 12th January 2023 the Seventh Appeal, The EU’s illegal precedence of economy over health, signed by 400 scientists and doctors was forwarded to EU Legislative bodies requesting that guidelines set by ICNIRP be reduced dramatically to protect the health of all living things and for a moratorium on 5G to be established.

Link to the Seventh Appeal:

The Stop 5G on Earth and in Space Appeal 2017 – signed by over 200 scientists working in the field of EMR from 41 countries included 10,000+ peer-reviewed scientific studies. These provided clear evidence about the harm to human health and to wildlife. 10] [11] Effects noted include:

Alteration of heart rhythm [12], Altered gene expression[13], Altered metabolism[14], Altered stem cell development [15], Cancers[16], Cardiovascular disease[17], Cognitive impairment[18], DNA damage[19], Impacts on general well-being[20], Increased free radicals[21], Learning and memory deficits[22], Impaired sperm function and quality[23], Miscarriage[24], Neurological damage[25], Obesity and diabetes[26], Oxidative stress[27]. Effects in children include autism [28] attention deficit hyperactivity disorder (ADHD)[29][30] and asthma. [31]

This Appeal reminds us that damage goes well beyond the human race, as there is abundant evidence of harm to diverse plants, wildlife [32][33] and laboratory animals, including:

Ants[34], Birds[35][36], Forests[37], Frogs[38], Fruit flies[39], Honey bees[40], Insects[41], Mammals[42], Mice[43][44], Plants[45], Rats[46], Trees[47]. Negative microbiological effects[48] have also been recorded.

LINK: All of the above are referenced on the Stop 5G on Earth and in Space Appeal 2017, 5G on Earth and in Space.

Section 5 – Social Inclusion 

The Strategy Statement informs us that ComReg takes consumer choice into account, this is not the real experience of those who are suffering from Electrohypersensitivity (EHS). Main issues for them lie in an inaccessible environment associated with unsustainable levels of EMR both within and outside their homes. Although effects are accumulative, those with less severe symptoms can initially manage their lives by taking measures to shield rooms with specialist paint and materials and/or their bodies with protective clothing etc – at great expense to themselves. For others, symptoms become so severe that they have no option but to move house, others move from place to place continuously, some resort to living in sheds; sleeping in cars, avoid public/social service providers, hospitals, schools etc. Some become prisoners in their own homes.  Needs such as shopping, attending the doctor, using public transport, use of social services etc., become almost impossible. At the severe stage there is an inability to continue participating in society or the social activities considered necessary for health and wellbeing. These people, if included in ComReg’s ECN/ECS strategy, will be seriously affected by having no choice whether they want to be exposed to continuous EMR or not.

More information and links with evidence regarding social inclusion are included on ES-Ireland’s Submission to The Joint Committee on Disability Matters, Houses of the Oireachtas in 2020

Link with evidence:

Thanking you for the opportunity of taking part in ComReg’s public consultation on ECN/ECS.

Ethna Monks

Member of ES-Ireland

Appendix (1) is a copy of the letter emailed to ComReg on 7th February 2023

To: Commission for Communication Regulations (ComReg), 7th February 2023  

 ComReg will be aware that on 16th April 2014 the E.U. Parliament and E.U Council harmonised the laws of member states in relation to the marketing of radio equipment. This was enacted through Directive 2014/53/EC. The focus of Directive 2014/53/EC was to ensure a single market for radio equipment by setting essential requirements for safety and health, electromagnetic compatibility and the efficient use of the radio spectrum.

Two very important Articles were adopted under this new Directive i.e. Article 3, Essential requirements (1) Radio equipment shall be constructed so as to ensure the protection of health and safety of persons and of domestic animals and the protection of property and, Article 42 which clarifies actions to be taken by EU Member States and relevant economic operators should a situation arise in which radio equipment is identified as presenting a risk to health or safety. Member States are to immediately inform the Commission and the other Member States and the shared information should include all data involved in enabling the identity of the radio equipment concerned, as well as the origin and supply chain, the nature of the risk involved and the nature and duration of national measures taken. The European Commission will then (without delay) consult with other Member States and Telecom operators to evaluate national measures to be taken and to decide whether to immediately adopt acts to be implemented. In summing up the Directive it would be difficult to avoid noticing that it is laden with the language of urgency. Directive 2014/53/EC applies to all products using the radio frequency spectrum. This letter will focus specifically on mobile phones in support of the work of Dr. Marc Arazi of Phonegate Alert.

Many people are unaware that their mobile phones are two-way pulsed microwave radios that have never been properly tested for safety or that their phones contain a warning alerting them to keep their phone at least 5mm from the body at all times. This warning is usually contained within the Terms and Conditions within the phone itself. People feel secure in the notion that no Government authority would willingly harm them or their children so little notice is given to the possibility that exposure to radiofrequency pulsed microwaves from all and any wireless device could be a problem. Complicity with industry by a non-independent media who depend on advertising cements this notion. In Ireland no market surveillance body has been set up to assess mobile phones despite EU Directive 2014/53/EC. Generally it is the Telecom companies themselves who have been certifying their mobile phones as safe. Implementation of the adopted standards has been generated through use of an outdated and misleading test i.e. the Specific Absorption Rate (SAR) i.e. heating of the body through exposure levels of radiation.

The use of the Specific Absorption Rate (SAR) as a measurement of bodily absorption of wireless pulsed microwave radiation is a problem. SAR dates back to experiments undertaken in the 1950s when dummy heads, filled with liquid designed to mimic the human brain, were used for test purposes. The greatest problem is that SAR only takes account of the heating or thermal effects of pulsed microwave radiation on the brain and body and only in relation to short-term use i.e. around 6 minutes. Hundreds of scientists have clearly evidenced the fact that it is the non-thermal effects that are the greatest cause of harm at the biological/cellular level and point out the fact that mobile phones are now in constant use. This is an on-going problem for assessing all devices that use wireless radiofrequency radiation.

The second problem lies in the fact that Telecom companies are basing their safety tests as if mobile phones are being used at 15mm (now reduced to 5mm) from the head/body. This has helped to create an impression that the radiation is not as bad as it is in reality. Most people hold their phone against their head and keep them in a pocket against the body. Given the multi-use of phones now it is more likely that length of connection is greater than 6 minutes. Liability for Telecom companies for damage is avoided through the inclusion of warnings contained in the terms and conditions of their devices.

It seems that no supervisory body or market surveillance authority has, as yet, been set up in any European country, other than France. The French National Agency of Frequencies (ANFR) carried out measurement tests of exposure to pulsed microwave radiofrequency emissions from mobile phones, completing a total of 862 test reports to date. Measurements, which are carried out at an accredited laboratory on behalf of ANFR revealed that 9 out of 10 mobile phones emitted more radiation than the European regulatory threshold of 2W/kg and 1 out of 4, a SAR value higher than 4W/kg.

Dr. Marc Arazi, a medical doctor who became concerned about potential harm from over-exposure to radiation emissions from mobile phones established PHONEGATE ALERT in 2016. He discovered that mobile phones are not being tested for health and safety in the way that they are being used i.e. against the body. The aim of PHONEGATE ALERT is to inform, protect and defend the hundreds of millions of mobile phone users in the world regarding potential health effects of pulsed microwave emissions. Given ANFR’s initial refusal to publish its findings of non-compliant models, Dr Arazi successfully campaigned for these to be made public. To date 38 mobile phone models that have been positively identified as violating limit values for radiation have been dealt with by the Authorities – hundreds more await assessment.. Manufacturers of defective phones were given the option of removing their phones from the market or of providing them with software to reduce the radiation. Some Telecom companies have already been sanctioned.

Given the role of Member States and the language of urgency within Directive 2014/53/EC the question needs to be asked as to whether any concrete action has been taken in Ireland since the sharing of this information between EU Member States. At present Ireland undertakes no market verification of the safety of mobiles phones, however government authorities including ComReg are aware that a formal objection was lodged by the French Authorities to the European Commission in September 2020. This objection was based upon the opinion of the French National Agency for Food, Environment and Occupational Health and Safety (ANSES), who became involved in the issue, producing a report Exposure to Mobile Telephones Carried Close to the body in 2019. ANSES recommended that the pertinence of using SAR as a measurement of limit values of exposure of people be re-evaluated (noting the thermal only effects); to develop a measurement of the actual exposure and finally to ensure respect by Telecom economic operators of regulatory limits. ANSES seem most concerned about effects such as the development of cancer, the alteration of cerebral functioning and fertility. The formal objection from the French Authorities to the EU recommended that the measurement of compliance regarding SAR should be carried out in contact position, i.e. at a distance of 0mm – on the body.

Given the urgency of this public health issue the questions we now are left with depends on the response of ComReg to the situation, given that part of their remit is to protect consumers. Questions we would like answered are:

  • has ComReg given any serious consideration to actions to be taken regarding the current day-to-day harm being caused to the public through overexposure to pulsed microwave radiation from mobile phones, especially for children and foetuses;
  • will ComReg provide the necessary technical, human and financial resources to carry out similar tests on the mobile phones and other wireless devices being sold and used in Ireland;
  • will we see some responsibility being passed to Big Telecom to provide financial support for problems caused or will the cost be pilfered from the public purse;
  • will the Irish Mobile Phone Radiation Warning Bill 2011 (Bill 20 of 2010) be resurrected. This bill was placed before the Dail and passed many stages but was ‘dropped’, apparently due to the dissolution of the Dail and Seanad.
  • will ComReg harbour a sense of unease given that the Global Insurance Industry has already decided that the risk of harm from electromagnetic fields/radiofrequency is too great as demonstrated through the introduction of Exclusion 32. This excludes cover for any illnesses caused by continuous long-term non-ionising electromagnetic/radiofrequency radiation exposure;
  • will ComReg take all reasonable steps to have radiofrequency emissions from mobile phones and other wireless devices reduced and in particular keep children in mind, “who seem to be most at risk from head tumors” as noted in the Council of Europe Parliamentary Assembly’s Resolution 1815 (2011) The potential dangers of electromagnetic fields and their effect on the environment,
  • will all devices using pulsed radiofrequency microwave radiation now have clear labelling showing the SAR rate in a legible, intelligible manner;
  • will the public be made aware of the dangers of pulsed microwave radiation from wireless devices through targeted information campaigns, as per Resolution 1815 (2011) (see above);
  • will schools now be encouraged to use wired up (ethernet) internet access ;
  • will the 5%, and growing number of the population who already suffer from electrohypersensitivity (microwave sickness) be taken into account in any future discussion/decisions regarding emissions of radiofrequency pulsed wireless microwaves from all and any wireless devices? page 85;
  • will the standard test currently being used i.e. SAR be replaced by more honest and real standards based upon biological/cellular effects of pulsed microwave radiation as per current scientific evidence;
  • Will measurements be taken to protect our environment and biodiversity including all living things that are currently being damaged by pulsed microwaves radiation?   See study by Dr Ulrich Warnke: Bees, Birds and Mankind, Destroying Nature by ‘Electrosmog’.

This issue concerns everyone. The Telecom Industry is following in the footsteps of Big Tobacco who suppressed and attacked all science that contradicted them for many years. The safe use of radiofrequency is an issue that needs to be addressed urgently. There are ways of making technology safer but it seems that the will to change will depend upon public awareness and demand. Cases are currently being presented within Court systems that include lists of hundreds of scientific publications, supported by hundreds of scientists worldwide. These clearly demonstrate that exposure to radiofrequency radiation affects living organisms at levels well below most international and national guidelines. Effects include increased cancer risk, cellular stress, increase in harmful free radicals, genetic damages, structural and functional changes of the reproductive system, learning and memory deficits, neurological disorders, and negative impacts on general well-being in humans. Clear evidence is contained within the 1,706 amicus brief filings submitted for the case successfully taken against the Federal Communications Commission, USA by the Enivironmental Health Trust and the Children’s Health Defence accusing them of ignoring current scientific evidence and for using outdated standards.

We would be grateful for a response that will answer our questions and present us with a summary of concrete actions taken by ComReg to date regarding this matter, particularly as we are most concerned about effects of pulsed microwave radiation from wireless devices on the developing brains of children and foetuses.

Thanking you in anticipation.

Ethna Monks

Member of ES-Ireland

PS: It should be noted that ES-Ireland does not promote one mobile phone over another – the aim of ES-Ireland is to provide information, create awareness and campaign for the safe technology the public deserve.