Framework for the migration from legacy infrastructure to modern infrastructure 2022 – Submission 8th May

Commission For Communication Regulations (ComReg) submitted 9th May 2022
Reference: Submission re ComReg 22/13 – Ethna Monks
Framework for the migration from legacy infrastructure to modern infrastructure 2022

The action put forward in ComReg’s framework regarding the ‘migration from legacy infrastructure’ involves the removal of the traditional copper-wired system currently used for our landline phones to be replaced through connection with fibre broadband infrastructure. This is yet another dramatic leap in the use of modern technology. However, it seems that the effect on many vulnerable and elderly people has not been considered well enough nor does the framework address what happens in the event of an electrical power cut, or the Internet being ‘down’. Traditional landline phones have always been exceptionally reliable, providing a secure link to the outside world for social or emergency interactions.

The main concern here relates to members of the population who rely on their landline phones for social interaction, for emergencies and for use of personal alarm systems connected using traditional methods. There are also those who suffer from  electrohypersensitivity/microwave sickness (EHS) for whom hardly a week goes by without some further assault on their ability to survive in an environment laden with radiofrequency electromagnetic radiation (EMR). The exchange of the traditional copper-wire system by a fibre system will require a modem that is switched on all day, and/or a mobile phone, which will attract the nearest, strongest signal. This places those who are EHS in an untenable situation. It is understood that ComReg does not have any specific role in relation to the health effects of Non-ionising Radiation (NIR) electromagnetic fields – but they do
have responsibility for protecting consumers under the Communications Regulation Act 2002. It is imperative therefore that they make themselves aware of this, now well-known and clearly evidenced, environmental intolerance that affects an estimated 3% to 5% of the population.

There are two major issues involved in awareness about the functional impairment EHS, an
intolerance that appears now to be further threatened by having no prospect of making a phone call without having to use some form of modern EMR. The first is specifically addressed in a recent submission sent to the Irish Government and also to ComReg.

This spells out the problems regarding the current EMR guidelines as created by the International Commission for Non-ionizing Radiation Protection (ICNIRP). It also presents information regarding the affects suffered by EHS along with up-to-date scientific evidence regarding these, as well as highlighting the well-known conflict-of-interests of this somewhat industry led commission who produced these guidelines.

The second major issue is the fact that the basic science being used regarding biological effects of EMR contained in the ICNIRP standards and adopted by ComReg and all Government Departments is inappropriate being based only on thermal effects i.e. the Specific Absorption Rate (SAR). The Radiological Protection Act 1991 (non-ionising radiation) Order 2019, S.I. No. 190 of 2019 defines ‘non-ionising radiation’ as consisting of photons. Current science would strongly disagree with this. Take, for example, the work of Professor Dimitri Panagopoulos (National Centre for Scientific Research, Athens) who, in Horizons in World Physics – Volume 296 (July 2018) states “Realization of the fact that man-made electromagnetic fields/radiations do not consist of photons, but of
continuous polarized waves leads to better understanding of their action on living organisms. Not realising this leads to a science that is totally disconnected from reality.” Professor Panagopoulos also collaborated with Associate Professor Olle Johansson of the Karolinska Institute and Dr. George Carlo of the Institute for Healthful Adaptation, USA in their published study ‘Evaluatiion of specific absorption rate as a dosimetric quantity for electromagnet fields bioeffects’ in (23750202) 2013, US National Library of Medicine, National Institutes of Health. They strongly suggest that the use of safety standards based on the Specific Absorption Rate (SAR) i.e. the thermal effects, as promulgated by the ICNIRP is inappropriate because the ‘vast majority of the recorded biological effects from man-made non-ionizing environmental radiation are non-thermal … the
biological/health effect is determined by tiny amounts of energy/power absorbed by specific
biomolecules, which cannot be calculated.’ Professor Panagopoulos’s theory is supported by other scientists around the globe e.g. physicist Dr. Leendert Vriens of the Netherlands. (see reference in recent interview at:

Given ComRegs responsibility for protection of consumers a re-evaluation is needed regarding the EMR standards being used and the science it supports prior to any further increased use of EMR as e.g. in the changeover from a copper wire system to a fibre system for landlines. Current scientific knowledge means that ComReg cannot justify the use of telecommunication guidelines that are not biologically sound and that are based on obsolete science. The fear and apprehension caused by the possibility of losing our ability to, in the worst case scenario, protect ourselves must be accounted for in any action taken by ComReg. To this end please consider a postponement of any action to remove our landlines until the truth about the standards and the science being used are independently reviewed and until the consequences of any action, particularly to the 3% to 5% of the population who are EHS and only use landlines, have been taken into account.

Thanking you,
Ethna Monks
Member of Electromagnetic Sense Ireland (
9th May 2022