To: Planning Authority ( County Council)
Planning Application Reference No:
Applicant: (name of company who submitted application)
Proposed: (what applied for)
Submission/Observation by (NAME AND ADDRESS)
I/We object to the erection/extension of the proposed …………. for the purpose of supporting telecommunication antennae for …(company)… and other operators including ground- based equipment cabinets and the provision of 2G, 3G, 4G, 5G and wireless telecommunications and broadband.
Comments contained in this submission/observation are based upon contradictions of stated goals and purposes contained in various guidelines, policies, goals and Directives and upon ethics, unconstitutionality and illegality of the planning process itself.
Planning Departments are aware that objecting to planning applications for telecommunications infrastructure under the Telecommunications Antennae and Support Guidelines 1996 might be a wasted exercise. This statement recognises that sections of the Telecommunications Antennae and Support Guidelines 1996 were updated through Circular Letter PL 07/12 as a result of the findings of the Next Generation Taskforce whose remit included the Identification and Removal of Barriers to the establishment of National Broadband in Ireland. Their conclusions (Circular Letter PL 07/12) resulted in Planning Authorities being instructed they “should not … determine planning applications on health grounds” or on location and design of masts. Also deregulated in this letter are, time limitation of permission, separation distances from possible unfavourable places such as schools, hospitals or sports grounds. In 2018 a subsequent letter i.e. Circular Letter PL 01/2018 from the Department of Housing, Planning and Local Government introduced further deregulations in favour of telecommunications operators such as height of poles or other support structures, increase in the number of and size of dishes/antennae and a plethora of exemptions regarding the deployment of small cell antennae (5G for the Internet of Things).
Such an extraordinary release of regulatory levers has created a ‘free for all’ climate for the telecommunications industry and has left little leeway for any foundation upon which objections can be made by the public.
(Provide here a description of the area in the application and why it would not benefit the community/why it is necessary e.g. a sports ground used by children, a built up residential area, there is already a free-standing structure/mast or antennae established in the area that is already providing 2G, 3G and 4G or wireless broadband, or wired broadband to homes and businesses).
In 2007 the BioInitiative Working Group, an international collaboration of prestigious scientists and public health experts from across the world, reported that chronic exposure to even low-level EMF/RF/Wi-Fi emitted from mobile and cordless phones, masts/antennae, Wi-Fi and all wireless devices can cause adverse health effects. Collective studies in the BioInitiative Report identified key scientific Biological Affects with peer reviewed evidence from independent scientific research:
- Damage to Sperm and Reproduction
- Children are more vulnerable
- Fetal and Neonatal Effects
- Effects on Autism (Autism Spectrum Conditions)
- Effects from Cell Tower-Level RFR Exposures
- Effects on the Blood-brain Barrier
- Effects on Brain Tumours
- Effects on Genes (Genetoxicity)
- Effects on the Nervous System (Neurotoxicity)
- Effects on Cancer (Childhood Leukemia, Adult Cancers)
- Melatonin, Breast Cancer and Alzheimer’s Disease
- Stress, Stress Proteins and DNA as a Fractal Antenna
- Effects of Weak-Field Interactions on Non-Linear Biological Oscillators and Synchronized Neural Activity.
More at: BioInitiative 2012 – Summary for the Public (2014 Supplement)
In a climate where “Irelands Electro Magnetic Field Policy is not to allow the Electro magnetic field health issue effect the growth and prosperity of the Irish economy (Tom McManus – chief technical advisor to the Department of Communication said in 1998), there seems little point in considering this possibility as an objection or, likewise, in repeating the facts that:
- in 2011 the World Health Organisation’s (WHO), IARC Team classified all Electromagnetic Fields/Radio Frequency (EMF/RF/Wi-Fi) used to power modern technology and emitted by these masts/antennaes and technological gadgets, as a Class 2b Carcinogen (WHO IARC Monograph, Volume 102, part 2, page 419);
- that the Parliamentary Assembly of the Council of Europe generated Resolution 1815 (2011) – The potential dangers of electromagnetic fields and their effect on the environment, in which they recommend member states to:
“8.1.1. take all reasonable measures to reduce exposure to electromagnetic fields, especially to radiofrequencies from mobile phones, and particularly the exposure to children and young people who seem to be most at risk from head tumours.
8.3.1. (to Ministries of education, environment and health) ‘targeted information campaigns [should be] aimed at teachers, parents and children to alert them to the specific risks of early, ill-considered and prolonged use of mobiles and other devices emitting microwaves”
- that in 2019 Professor Tom Butler of University College Cork produced a report “On the Clear Evidence of the Risks to Children from Non-Ionizing Radio Frequency Radiation: The Case of Digital Technologies in the Home, Classroom and Society.”
The Guidelines currently used by the Irish Government, produced by The International Commission on Non-ionising Radiation Protection (ICNIRP), have been described as obsolete by the European Parliament – Doc: A6-0260/2008, No.23. These (ICNIRP) guidelines are limited to the thermal effects of Electromagnetic Fields/Radiofrequency/Wi-Fi (EMF/RF/Wi-Fi) and to short-term exposure (6 minutes). In addition the Specific Absorption Rate (SAR) used was conjured up using large military males and so does not address different body sizes or vulnerability/developmental issues of children. Research papers by world-renowned independent scientists have demonstrated that adverse health effects from EMF/RF/Wi-Fi radiation can occur at levels well below the thermal level i.e. at non-thermal levels.
The latter point is interesting as the Government and Authorities will be aware that in contradiction to the ICNIRP Guidelines, Directive 2013/35/EU of the European Parliament and of the Council of 26 June 2013 which was transposed into the Irish Statute Book as Safety, Health and Welfare at Work (Electromagnetic Fields) Regulations 2016, S.I. No. 337 of 2016, actually includes information on the non-thermal effects of EMF/RF/Wi-Fi:
“Article 2 (b) (ii) non-thermal effects – such as stimulation of muscles, nerves or sensory organs. These effects might have a detrimental effect on the mental and physical health of exposed workers.” Sadly these too only refer to short-term exposure and ignore the fact that we all sit in a non-consensual sea of pulsing microwaves 24/7/365.
This Directive transposed into the Irish Statute Book – Ref: S.I. No. 337 of 2016
Yet despite all of this clear information regarding potential adverse health effects and the thousands of available research reports from world renowned independent scientists, Circular Letter PL07/12 states that planning authorities “should not … determine planning applications on health grounds” – “These are regulated by ‘other codes’.”
This refusal/wilful blindness in acknowledging health issues is exacerbated by the fact that no Government Department has been designated or has accepted responsibility for EMF/RF/Wi-Fi and public health, or has any idea what these ‘other codes’ are. No register, complaints procedures or redress scheme has been set up on behalf of the public. This is especially important for those whose lives have already been impacted by EMF/RF/Wi-Fi pollution, said to be between 3% to 10% of the population.
Finally and most importantly this objection is made on the grounds that Circular Letter PL 07/12 concerning Telecommunications Antennae and Support Guidelines 1996 is in breach of the Constitution of Ireland in a number of ways. It is understood that multiple submissions, including a Critique of the Legislative and Constitutional Rights re Guidelines for Planning Authorities were made to various Government Departments in 2017, including the Department of Housing, Planning and Local Government and An Bord Pleanala. Some of the main Constitutional Breaches within the Planning Guidelines were identified as follows:
- They ignore and violate the stated and operative Government policy in relation to public health and wellbeing and Better Regulation;
- Abandon the provisions of the Constitution and the Cabinet Handbook in regard to the legislative process;
- Commandeer the legislative role of Oireachtas Eireann,
- Are outside of the legislative powers of the Minister for Housing, Planning and Local Government or indeed, the Minister for Communication, Climate Change and Environment, especially with regard to the public health and wellbeing aspects of the Guidelines (DCCAE). Yet the public are continuously informed by the Department of Health that the DCCAE hold responsibility for health in relation to EMF/RF/Wi-Fi.
- Are not legally acceptable without being made the subject of primary Oireachtas legislation.
In short they subjugate the Constitutional and legislative rights and protections available to the public and residential property owners and consequentially favour immunity from responsibility for telecommunications operators.
It appears that the Department of Housing, Planning and Local Government bypassed Dail Eireann and Oireachtas Eireann regarding the issuing of Circular Letter: PL 07/12. This raises serious issues of accountability for An Bord Pleanala and for local planning authorities regarding the decision making process. As decision makers they cannot nullify their responsibility to ensure that the overall planning system adopted is Constitutionally compatible and protects the health and wellbeing of the citizen. The issues raised here may also apply to any past decisions made in relation to telecommunications infrastructure.
Immediate adoption of the Precautionary Principle and replacement of wireless Radio Frequency with a safer wired broadband system should be considered as a means of matching the rhetoric that Ireland should be a ‘place where everyone has the opportunity to live a healthful life’ (Healthy Ireland Framework, 2013).
We already have confirmation of the possibility that more positive and sustainable changes can be introduced as noted in the Department of Housing, Planning and Local Government’s National Planning Framework, Peoples Health and Wellbeing 2013 which verifies their belief that they “are prepared to make changes now so that a ‘healthier places’ legacy can be handed over to the next generation.” This is also the main aim of this submission/observation.
Please note that the above information refers to the affects of EMF/RF/Wi-Fi on all living things and not just on humans.
Supporting Documents: World International Property Organization (WIPO), Patentscope – Application by telecommunication companies including SwissCom, re a method of Reduction of Electrosmog in Wireless Local Networks – Ref: WO/2004/075583 – (see under Description page 2)
Scientific Committee on Health, Environmental and Emerging Risks
Statement on emerging health and environmental issues (2018)