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Karen Banks

From: Grace Maddan Sent: 05 February 2021 10:01 To: Andrew Bishop; Planning; [email protected]; localplan Subject: Planning Application R/85/514/GDO

Adambottom Farm, West Burton, North ,

DL8 4UL

I object to the proposed mast at on visual impact grounds.

Grace Maddan

1 Karen Banks

From: Humphrey Maddan Sent: 05 February 2021 08:47 To: Planning; Andrew Bishop; [email protected]; localplan Subject: Planning application R/85/514/GDO

Adambottom farm West Burton DL8 4UL

Dear Planners,

I strongly object to the proposed mast at West Scrafton. I think there are many reasons why it is unwise to accept 5G modernisation at the cost of the world class Yorkshire Dales. Here are a few:

1) Economically - the business cases I've viewed about the benefits to do with IoT does simply not stack up in having a meaningful benefit to our communities. Faster internet yes - see next point: 2) Technically - fibre optic would be hugely preferable as a solution to faster internet - due to speed and precision with no visual collateral. 3) Aesthetically - I would hope that individuals responsible for stewarding the Yorkshire Dales are conscious of how rare a landscape they are able to either preserve or change. 4)Environmentally - I think the effect on pollinators and species (not to mention humans) seems to be relatively unquantified. Therefore in light of the other areas, there is no reason to bring this risk to our community.

I realise that it must be a hard decision - but please scrutinise your motives in this area. Unnecessary and visual modernisation of the Yorkshire Dales would be self-defeating - you would lose what makes this place so special for resident and visitor alike.

Yours sincerely, Humphrey Maddan

1 Karen Banks

From: Francis Maddan Sent: 05 February 2021 08:01 To: Planning; [email protected]; [email protected]; localplan Subject: Planning application R/85/514/GDO

Adambottom farm West burton Leybur DL8 4UL

I object to the proposed mast at West scrafton on visual grounds

Francis Maddan

1 Dr Diane Green

The Old Town Hall

Market Place

Middleham

North Yorkshire. DL8 4NR

[email protected]

04/02/2021

The Planning Officer

Planning Department

Yorkshire Dales National Park Authority

Yoredale, Bainbridge, Leyburn,

North Yorkshire. DL8 3EL

Application R/85/51A/GDO

Land to the south east of existing agricultural buildings off High Lane, West Scrafton, Leyburn

Application for prior approval under Part 16 of Schedule 2 to the Town & Country Planning (General Permitted Development) () Order 2015 as amended by the Town & Country Planning (General Permitted Development) (England) (Amendment) (no.2) Order 2016 and in accordance with the electronic communications code under the Telecommunications Act 1984 Schedule 2 as amended by the Communications Act 2003 for the installation of a 17m wooden utility Pole (15m above ground level) with mobile communications antenna and equipment cabinet

Dear Sir or Madam

I am writing to object to the above application, for the reasons below.

Visual amenity:

Coverdale has a strongly rural, highly scenic visual quality and is very little spoilt by intrusive evidence of modern life. I consider that the proposed mast, at 15 metres above ground level, would represent an alien and intrusive feature in the landscape. It would be considerably taller than the surrounding trees and local buildings and alien in character to its wider surroundings. It would rival the scale of the surrounding hills and moors and reduce their appearance of wildness. It would be an intrusive and visually unwelcome suburbanisation of this remote rural landscape.

Nature conservation

I have very serious wider concerns about the impact of the proposed telecoms mast upon the natural environment of . I also have very serious concerns about the impact of the wider (‘MANY’) telecoms project of which this is a part, specifically upon the welfare of the local flora of Coverdale and upon the animals which live within or migrate to this remote rural area. The physical impact of the 5G radio waves upon the health and welfare of bees, butterflies and other insects, birds and mammals and upon the plant life of the area around this proposed mast and also around the other proposed masts in North Yorkshire County Council’s ‘MANY’ project to which this one belongs, has not been addressed in this application. Its safety for the animals and the wild plant-life of this beautiful and remote part of the Yorkshire Dales National Park is unproven. Indeed EMR (electro-magnetic radiation) has been associated with growing evidence of many harmful effects upon plants and animals (as documented in https://www.5gspaceappeal.org/the-appeal and many other sources). No Environmental Impact Assessment has been carried out for the present development and the wider project to which it belongs. As noted in Government Guidance, ‘The aim of Environmental Impact Assessment is to protect the environment by ensuring that a local planning authority when deciding whether to grant planning permission for a project, which is likely to have significant effects on the environment, does so in the full knowledge of the likely significant effects, and takes this into account in the decision making process.’

I note that it is part of your Council’s remit to conserve and enhance the natural beauty and wildlife of the Yorkshire Dales National Park. In accordance with this I strongly urge your Council to adopt the precautionary principle in considering this application, until (or unless) the safety of this new technology is proven. It is my understanding that the prevailing ICNIRP (International Commission on Non-Ionising Radiation Protection) safety standards have been called into question by many scientists internationally, not least because of that organisation’s close links with the telecoms industry. Once lost, the rich biodiversity of Coverdale is unlikely to return and will no longer be capable of being enjoyed by future generations.

Disturbance resulting from use

Disturbance resulting from use is a further material planning consideration. Electromagnetic radiation (EMR) has been linked to a range of adverse health impacts upon human beings; notably to damage to DNA, cancer, impaired cellular function and to nervous, circulatory and reproductive system damage. This is well documented, although not currently accepted by ICNIRP. Furthermore the proposed mast and the others in the MANY project would subject the local population to not just occasional but continuous, involuntary electromagnetic radiation. Any damage to the health of local residents would clearly cause them ‘disturbance’ and this is therefore a legitimate concern in determining a planning application. Therefore, this serious matter also calls for the use of the precautionary principle to be applied by your Council.

Alternatives available

It is my understanding that there are alternative means of providing connectivity in Coverdale, notably fibre broadband, which I understand may have been considered too expensive for parts of Coverdale, but which is likely to provide a safer method of bringing connectivity for the residents and businesses in the dale. I further understand that the emergency services masts (of which I understand there is one at Braidley, one being erected at Coverhead and one recently approved at Gildersbeck) are also intended to be activated for commercial use (timing to be decided) and could cover local requirements.

In the light of the above, I question whether it is appropriate for your Council to approve the present application for the proposed mast at West Scrafton and thereby to allow the introduction of an unproven technology which could put some of the chief objectives of your Council at risk, when your Council could choose to adopt the precautionary principle and honour its remit to conserve and enhance the natural beauty and wildlife of this beautiful area.

For the above reasons I strongly urge your Council to refuse this application.

Yours sincerely

Dr Diane Green (B.A. Hon; D.Phil)

Middleham resident. Karen Banks

From: [email protected] Sent: 04 February 2021 18:25 To: Andrew Bishop; Planning Cc: localplan; Neil Heseltine; David Butterworth Subject: West Scrafton mast Planning Application R/85/514/GDO

M J Sparrow Thirns Farmhouse Healaugh Richmond North Yorkshire DL11 6UW 4th February 2021 Attn: YNDPA Planning Committee Ref: Application for planning consent for a telecommunications mast, antenna and cabinet at West Scrafton - R/85/51A/GDO Dear Planning Committee, I write further to receiving a copy of the Senior Planning Officer’s recommendation for approval of the above application, to correct information which the Officer may have relied upon in good faith, and to register my objection on the basis that the application fails to meet an acceptable assessment of need or protection of human health and ecology. 1. Paragraph 6 of the recommendation. The recommendation says that there are no wildlife conservation constraints to this application based upon the data we hold.

• The YDNPA purpose includes a responsibility for ‘conserving and enhancing the natural landscape and wildlife … of the National Park’. Scientific studies provide strong evidence that electromagnetic radiation (EMR) from telecommunications masts is damaging to flora and fauna. (See examples in the addendum below). 2. Paragraphs 8-18 - need for the development. The MANY project states that the application is required to enable a trial service aimed at providing superfast broadband and mobile phone signal to a ‘not-spot’ rural community. If this is the purpose of the trial, and consequently the application, then there appears to be no justification of need because Coverdale Connect and Protect, who advocate for a safe and optimal connectivity solution, have conducted a survey of the community which suggests;

• 90% of properties within the trial area are currently connected to a fibre broadband service. The balance of properties would be better served with an extension of the fibre network, which would provide a higher quality, more reliable service • EE plan to add a mobile phone transmitter to the already approved Gildersbeck Emergency Services mast, which will then provide mobile phone service for the trial area • MANY plan to dismantle and remove the mast at West Scrafton in March 2022 if the trial service proves non-viable, and they cannot secure a commercial partner operator.

1 3. Paragraphs 25-28 - health impact (a) The application has provided a certificate of conformance with ICNIRP guidelines. However, the committee should note that;

• Internationally, there is considerable concern among expert scientists who study the effects of EMR, that the safe exposure guidelines set by ICNIRP are inadequate to protect ecology and human health. • In 2020, ICNIRP was judged by the Appeal Court of Turin to be conflicted because of the relationship of its members with the telecommunications industry. • In 2020, an investigative report prepared by two EU Parliament Commissioners concluded that there was evidence of collusion between ICNIRP and industry, and recommended that ICNIRP should be disbanded and replaced by an independent advisory body. • The UK Government and Public Health England rely currently upon ICNIRP’s advice for defining safe levels of exposure to EMR. (b) Notwithstanding the above, telecommunications operators are required, not simply to submit a certificate of conformance, but to demonstrate conformance by;

• Ensuring that exclusion zones are clearly marked on the application, and that signage is erected to mark those areas. • Notifying vulnerable individuals about the effects of EMR eg: people with implants, children, or those who use hearing aids, who are more susceptible to adverse effects. • Providing calculations of electromagnetic field density and Specific Absorption Rate (SAR) that will be emitted by the planned infrastructure, to demonstrate that it will comply with international safety standards? It is important to note that an ICNIRP certificate is not issued by ICNIRP, who provide a disclaimer to that effect on their website https://www.icnirp.org/en/activities/news/news-article/certificate.html Hence, it is incumbent upon the Planning Committee to satisfy themselves that the requirements of the certificate have been fulfilled, failing which, the application should be rejected. (c) There is extensive international debate about whether non-ionising radiation emitted from wireless devices and infrastructure causes harm to health. In January 2021, Professor John Frank published a review in the British Medical Journal which says that he is, ‘convinced that RF-EMF’s may well have serious human health effects’. Additionally;

• The Environmental Health Trust now cites over 30,000 studies into the effects of EMR. • Several recent reviews of such studies have concluded that 70% or more of studies demonstrate ‘significant adverse biological effects’ arising from exposure to EMR below the standards set by ICNIRP. • Dr Anthony Miller, former senior advisor to the World Health Organisation and senior epidemiologist for the International Agency for Research on Cancer, insists that EMR should now be classified as a group 1 human carcinogen. • Numerous studies demonstrate harm to humans caused by the EMR emitted from telecommunications masts. (See examples in the addendum below). Given the above, I believe that application for planning consent for this mast should be rejected on the basis that it does not satisfy an assessment of need for the development, and there is credible evidence to suggest that it would present a risk to human health and YDNPA precious wildlife. Yours sincerely

Mike J Sparrow Addendum. 1. Examples of studies that demonstrate the harm that EMR from telecommunications masts causes to flora and fauna;

2 • Kumar, Warnke - ‘no worker bees returned to EMF exposed hives, queens laid half the eggs, and hive population reduced by 70%’. • Balmori – ’90% mortality in frogs placed 150m from mast compared to 4% in control group’. • Ramazinni Institute – ‘Heart Schwannoma, glial brain tumour and DNA damage in rats exposed to environmental levels of EMR equivalent to a cellphone mast’. • DiCarlo and Litovitz – ‘statistically significant mortality of chicken embryos caused by 2 and 3G radiation’. Replicated by Grigor’ev (2003), Xenos and Magras (2003). • Balmori (2005) – ‘nest abandonment, locomotion problems and death in Wood Storks, House Sparrows, Rock Doves, Magpies and Collared Doves. 40% of nests within 200m of a mast produced no chicks’. • Cucurachi et al (2012) – ‘70% of 113 studies from peer-reviewed publications demonstrated significant effects of RF EMR on birds, insects and other organisms and plants’. 2. Example of studies that demonstrate the harm that EMR from telecommunications masts causes to human health;

• 2010, Hardell et al, review of research into the effects of telecommunications masts on human health concluded, ‘8 out of 10 studies found increased incidence of neuro-behavioural effects and cancer in communities living <500m from a mast’. • 2004, Eger et al, ten year Bavarian study found ‘threefold increase in malignant tumours for people living within 400m of a mast for five years or more’. • 2004, Wolf and Wolf found ‘fourfold increase in cancer among 622 people living within 350m of a cellphone mast. Women exhibited a tenfold increased incidence of cancer’. • 2005, Hutter et al. studied 365 people in Austria and found ‘increased incidence of headaches, vertigo, tremors, exhaustion, stress, difficulty concentrating, and poor sleep at radiation levels hundreds of times lower than safety standards’ – 0.2 to 0.4 volts/m. Note, a Dutch court judged in December 2020, that ‘harm could not be ruled out at field density as low as 1 volt/m’ – sixty times lower than the ICNIRP safety standard.

Sent from Surface

3 Gail Dent

From: Juliet Madden Sent: 04 February 2021 16:50 To: Andrew Bishop; Planning; [email protected]; localplan Subject: Objection to West Scrafton Mast Attachments: Electromagnetic fields 5G and health - John William Frank.pdf; Base station health effects Hardnell.pdf

Planning Application R/85/514/GDO

Adambottom Farm, West Burton, North Yorkshire, DL8 4UL

Dear YDNPA planning committee, members and chief planning officials, I would like to add my objection to the above mast being proposed for West Scrafton. I have attached a recent BMJ article ‘Electromagnetic fields, 5G and health: what about the precauitionary principle?’ (October 2020 by Professor John Frank). In this article I would like to point out the section entitled 'Persistent allegations of unscientific bases for existing health protection guidelines on RF-EMFs amid unmanaged conflicts of interest on expert advisory panels'. I.E. ICNIRP is riddled with conflicts of interest and shows all the signs of corporate capture by the Tech industry. The emerging science showing the inadequacy of safety standards over existing EMR should mean NYCC and the YDNP dare not proceed with a 5G testbed trial which emits even higher levels of radiation until there is clear science showing no risk. The YDNP lack of certainty that these masts won't cause harm to the local ecology and human health should mean that they implement ‘The Precautionary principle’. The so called safety standards are not fit for purpose as per the BMJ article. I have also attached Dr Lennart Harrell study which says in the summary that 8 out of 10 studies found increased prevalence of adverse neuro-behavioural symptoms and cancer among communities living within 500m from a mast. We challenge MANY to produce some robust science showing the opposite. MANY hide behind Ofcom, PHE, WHO safety standards, who all take their standards from ICNIRP . This is like building a house on sand. Once the damage is done, who is going to indemnify the damages? So far the industry has failed to get any insurance cover against health harm caused by EMR . Lloyds likened the risk to the asbestos scandal and have therefore refused to insure the industry. 5G poses an even greater risk if the emerging science is correct. The unsightly impact of these artificial structures is bad enough. Please do not allow anymore masts to be erected in our ico nic Dales. The YDNP role is to preserve the landscape and protect wildlife . This should be their number one priority. The YDNP have a wide body of evidence to back up a precautionary approach. If YDNP does not protect our landscape and ecology it rather begs

1 the question of what their role is? Especially if they allow an unsuitable and possible harmful role out of a 5G trial that many locals do not want or need. I look forward to hearing that this mast and other masts down the line are recognised as being incompatible with the high standards of care that the YDNP adhere to when looking at the impact of planning on these precious unspoilt rural areas. To implement the precautionary principle is surely correct until more is known of the increased effects of added EMR in this 5G trial. Also a safe alternative of fibre optic cable below ground would solve the issues facing those with poor broadband.

Yours sincerely, Juliet Maddan

2 Essay Electromagnetic fields, 5G and health: what about the precautionary principle? John William Frank ‍ ‍

Usher Institute, University of ABSTRACT electromagnetic field (RF-­EMF) exposures.5–8 This Edinburgh, Edinburgh, UK New fifth generation (5G) telecommunications systems, commentary sets out the reasons for such concern. now being rolled out globally, have become the subject Correspondence to of a fierce controversy. Some health protection agencies Professor John William Frank; WHAT IS 5G AND WHY IS IT DIFFERENT FROM ​john.​frank@​ed.​ac.​uk and their scientific advisory committees have concluded that there is no conclusive scientific evidence of harm. PAST EMF EXPOSURES? Received 2 December 2019 Several recent reviews by independent scientists, Developed over just the last decade, radio frequency Revised 13 October 2020 however, suggest that there is significant uncertainty (wireless) transmission systems in the 5G category Accepted 16 October 2020 on this question, with rapidly emerging evidence are being rolled out throughout the world. These of potentially harmful biological effects from radio systems will massively increase the volume, speed 4–6 frequency electromagnetic field (RF-­EMF) exposures, at and spatial reach of digital data transfer. The four the levels 5G roll-­out will entail. This essay identifies four successive previous generations (1G, 2G, 3G and relevant sources of scientific uncertainty and concern: 4G) of wireless transmission systems were deployed (1) lack of clarity about precisely what technology is initially for wireless and mobile phones (1980s and included in 5G; (2) a rapidly accumulating body of 1990s), followed by WiFi (2000s), and then smart laboratory studies documenting disruptive in vitro and metres and the Internet of Things (2010s). Each in vivo effects of RF-­EMFs—but one with many gaps successive generation of transmission systems has in it; (3) an almost total lack (as yet) of high-­quality used higher frequencies of electromagnetic waves epidemiological studies of adverse human health to carry ever-­larger volumes of data, faster, in more effects from 5G EMF exposure specifically, but rapidly ubiquitous locations. 5G is widely acknowledged emerging epidemiological evidence of such effects from to be a step change in this sequence, since it addi- past generations of RF-­EMF exposure; (4) persistent tionally uses much higher frequency (3 to 300 GHz) allegations that some national telecommunications radio waves than in the past. 5G will also make use regulatory authorities do not base their RF-­EMF safety of very new—and thus relatively unevaluated, in policies on the latest science, related to unmanaged terms of safety—supportive technology (including conflicts of interest. The author, an experienced pulsing, beaming, phased arrays and massive input/ epidemiologist, concludes that one cannot dismiss the massive output (MIMO)—see below) to enable this growing health concerns about RF-­EMFs, especially in higher data transmission capacity.4–6 an era when higher population levels of exposure are However—unlike prior generations of wireless occurring widely, due to the spatially dense transmitters transmission systems—5G ultrahigh-­frequency which 5G systems require. Based on the precautionary waves are easily interrupted by vegetation foliage principle, the author echoes the calls of others for (and building walls, often requiring additional a moratorium on the further roll-­out of 5G systems signal boosting within each building). This inherent globally, pending more conclusive research on their fragility of 5G high-­frequency waves means that safety. transmission boosting ‘cell’ antennae are gener- ally required every 100–300 m or less—far more spatially dense than the miles-­apart transmission masts required for older 2G, 3G and 4G technology BACKGROUND using lower frequency waves.4–6 Fifth generation (5G) technology is being widely This dense transmission network is also required promoted by politicians, government officials, in order to achieve the ‘everywhere/anytime’ and private sector interests.1–3 They contend that connectivity promised by 5G developers, and its advent will bring clear economic and lifestyle necessitated by new technology such as driverless benefits, through massive increases in wireless and cars, which must never be out of internet contact, mobile connectivity at home, work, school and for safety reasons. Critics of 5G agree6–8—but its AUTHOR PROOF © Author(s) (or their in the community. Examples of these 5G benefits supporters do not9 10—that the overall popula- employer(s)) 2020. No include driverless vehicles and ‘The Internet of tion levels of exposure to RF-EMFs­ will be greatly commercial re-­use. See rights and permissions. Published Things’—automated and continuous communica- increased by the 5G roll-out.­ One compelling argu- 4 5 by BMJ. tion between the machines in our daily lives. On ment for that view is the ‘inverse square law’ of the other hand, the public health response to this EMF exposure: intensity varies as the inverse of the To cite: Frank JW. J wave of communications innovation has become square of the distance from the emitting source.11 Epidemiol Community Health Epub ahead of print: [please a sense of deep concern, related to widespread With plans afoot internationally to put a 5G booster include Day Month Year]. scientific uncertainties, as well as a lack of use of antenna on ‘every second or third lamp-­post’, it is doi:10.1136/jech-2019- existing evidence, in the current international safety difficult to believe that overall population expo- 213595 guidelines for 5G and related radio frequency sures will not increase substantially. Existing 4G

Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 1 Essay systems can service up to 4000 radio frequency using devices resulting from chronic rather than acute exposures, and effects per square kilometre; 5G systems will connect up to one million not mediated by thermogenesis. devices per square kilometre—greatly increasing the speed of data transfer (by a factor of 10) and the volume of data trans- KEY CONTENTIOUS ISSUES AND SCIENTIFIC UNCERTAINTIES mitted (by a factor of 1000).6 Lack of clarity about precisely what sorts of EMFs will result from 5G roll-out THE CURRENT CONTROVERSY A striking feature of this public controversy is that various International health protection agencies and their scientific commentators—even those with advanced training in telecom- advisory bodies have published several reviews over the last munications physics and engineering—inconsistently refer to decade, of varying scientific quality, of the research evidence quite different specific technologies when they discuss the pros regarding potential adverse biological and health effects of and cons of ‘5G’. American authors tend to state that the 5G RF-­EMFs.5 12–15 These reviews—by Health Protection England,12 system roll outs already underway in that part of the world are 13 using very high-­frequency (24–100 GHz)/short-­wavelength RF the International Agency for Research on Cancer (IARC), 6 14 transmission—so-­called ‘millimetre range’ waves. However, an Expert European Union (EU) Committee and the Inter- 9 national Commission on Non-­Ionising Radiation Protection some UK/EU industry websites state that ‘no new frequencies (ICNIRP)15—have, with one exception, not converged around are required’ (at present) beyond those already in use in existing a strong warning about such effects. IARC is the outlier in this 4G mobile networks, WiFi, smart metres. However, indepen- respect, having determined in 2011 that EMFs are ‘possibly dent authors commenting on current private sector plans in the 13 EU, to extend 5G networks more widely in the future, tell a carcinogenic to humans’. Meanwhile, independent radiation 23 24 and health scientists have published serious concerns about different story. These commentaries imply that the use of the current roll-­out of 5G transmission systems.6–8 16–18 Their millimetre wave frequencies—about which we have very few reasoning is twofold: (1) these systems have an unprecedented conclusive studies of human health effects—is already planned potential to create human and non-­human RF-­EMF exposures and inevitable in the EU, and eventually globally, in order to orders of magnitude more intense (eg, in terms of ‘power flux accommodate anticipated consumer requirements—especially density’) than was the case only a few decades ago (16); (2) there the ‘Internet of Things’ and driverless vehicles. Tellingly, the Guardian (one of the UK’s most respected newspapers) reported is a remarkable dearth of evidence on the safety of 5G-specific­ 25 EMF emissions, but a growing body of research suggestive of last year that UK lamp posts were becoming the subject of harms from other RF-­EMF exposures, which have been studied expensive legal battles, over ‘who can charge what’ for mounting for much longer.6–8 17 18 5G booster cell antennae on them. Cash-­strapped Local Coun- Moreover, a growing number of engineers, scientists, and cils had hoped to profit from such charges to telecom compa- doctors internationally have been calling on governments to raise nies. These companies have taken local governments to court their safety standards for RF-­EMFs, commission more and better to block those charges. The USA provides a cautionary tale in research, and hold off on further increases in public exposure, this respect: nearly 25 years ago national legislation there took pending clearer evidence of safety.18–21 Some politicians have local authorities completely out of the telecommunications regu- listened: France, Israel, Cyprus and Russia have banned WiFi latory system, leaving local 5G installation and similar decisions entirely in the hands of central authorities—that is, the Federal in preschool and restricted its use in primary schools. Belgium 6 has banned the sale of mobile phones to children under seven. Communications Commission. In response to such concerns, several jurisdictions have recently Equally inconsistently described in writings about 5G is the blocked the installation of 5G antennae systems in their commu- complex set of special signal modulations, pulses, polarisation, nities: Brussels, Florence, Rome, as well as Glastonbury, Frome phased arrays and novel equipment designs—for example, and Totnes in the UK; and widespread anti-­5G campaigns are ‘massive MIMO antennas’—which represent the cutting edge now emerging in Australia, North America and elsewhere.21 technologies that accompany 5G system installation—many of Some countries have lowered allowable RF-EMF­ exposure them proprietary. As some commentators on potential health levels far below those permitted in the UK and USA. Powerwatch, effects from such exposures have pointed out, it is highly likely a non-­profit, independent organisation in the UK, has published that each of these many forms of transmission causes somewhat different biological effects—making sound, comprehensive and comparisons of international recommendations on permitted 5–7 26 27 22 up-­to-­date research on those effects virtually impossible. maximum exposure levels to EMFs. Those comparisons show In short, ‘5G systems’ is not a consistently defined term. This that the highest permitted RF-­EMF exposures which are used confusion has not helped clarify the health and safety issues globally, as the basis for national safety guidelines, are those surrounding 5G roll outs internationally. used in the USA, the UK and most of the EU. These exposure limits are derived from the recommendations to WHO in 1998 (recently updated, but essentially not changed, in March 2020) An emerging preponderance of laboratory studies indicating byAUTHOR PROOF the ICNIRP.15 These international comparisons show that RF-EMFs’ disruptive biological effects: with many knowledge the safety limit for RF-­EMF exposure set by ICNIRP is 10-fold­ gaps higher than that set by the next most liberal guidelines, found The lack of a consistent definition of ‘5G’ matters enormously. in Israel and India, and 100-­or-­more-­fold higher than the limits This is clearly demonstrated in a sophisticated recent review of set by other guidelines, spanning 14 EU jurisdictions as well as the laboratory science evidence of RF-­EMF effects in diverse China. As discussed in detail below, one reason that ICNIRP’s biological systems.26 That review shows that the existing scien- permitted exposures are so high is that they are based solely on tific literature on the biological effects of more recently devel- the acute thermogenic (heat-producing)­ effects of RF-­EMF in oped technology is quite limited, in that there is hardly any animal tissues; this is unlike more conservative jurisdictions’ study replication—the hallmark of reliable research. We often guidelines, which are based on a wider variety of biological and have only one extant study of any given biological effect of a health effects documented in recent decades, including effects specified combination of radio frequencies, modulation and

2 Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 Essay pulse patterns. The literature that does exist identifies remark- the highest-­quality epidemiological study designs for establishing ably heterogeneous biological effects, across hundreds of such evidence of causation: prospective cohort studies. Such studies specific RF-­EMF exposure patterns. Furthermore, a compre- typically require decades of follow-up­ to detect delayed health hensive Canadian review of the same evidence states that some effects, such as most cancers. of the new RF-­EMF technologies—such as innovations in radio Miller et al find compelling evidence of carcinogenesis, espe- frequency ‘pulsing,’ ‘polarisation’ and ‘modulation’—are so new cially in the brain and acoustic nerve, as well as the breast, from that biological scientists have not been able to keep up—that strong RF-­EMF exposures to previous generations of mobile is, no studies yet exist of these new technologies’ biological phone transmissions. Perhaps the most convincing evidence effects.27 they cite comes from the oldest and most-often-­ ­maligned These recent reviews of laboratory (ie, non-­epidemiological) study design—case reports. While admittedly old-­fashioned, studies of the biological effects of RF-EMFs­ do identify diverse, case reports can, when they involve pathognomonic effects (ie, multibody system effects, operating by a range of physicochemical pathological features absolutely specific to a particular expo- pathways which are not mediated by thermogenesis.6 8 26 27 The sure) provide useful evidence of exposure/outcome specifici- reviewers document a growing body of evidence that RF-­EMF ty—a valuable but often unobtainable epidemiological criterion exposures produce effects spanning reproductive/teratogenic, for inferring causation, according to the standard epidemi- oncological, neuropsychiatric, skin, eye and immunological ological criteria first enunciated by Sir Austin Bradford Hill body systems. In addition, there are many fundamental effects over 50 years ago.34 35 Strikingly localised breast tumours, of at the subcellular level, in terms of oxidation, DNA alteration, unusual morphology, have been diagnosed in several women gene expression and bacterial antibiotic resistance. Particularly with particularly strong exposures to previous generations of striking is a 2018 study from Israel documenting the capacity mobile phones: they habitually placed their phones in their bras, of the sweat ducts in human skin to act as ‘helical antennae’ on the same side of the body where the tumour has developed. receptive to 5G frequencies of RF-EMF.­ When sweat ducts are Miller et al call for an urgent update of the last (2011) review exposed to these RF-EMFs,­ there are remote systemic effects, of EMFs and cancer by the International Agency for Research through the skin’s established capacity to secrete and send on Cancer.13 They predict that such an update would now rate hormones and other signals to the entire body.28 This report RF-­EMFs as, at minimum, ‘probable’ (not merely ‘possible’ as in alters one’s sense of the potential risks from such high frequency 2011) carcinogens, based on current evidence. waves, since they have long been thought to be ‘inherently less dangerous’, because they are largely absorbed in the top few millimetres of exposed tissue (thus limiting any adverse effects, Persistent allegations of unscientific bases for existing health in theory, to the skin or eye). protection guidelines on RF-EMFs and unmanaged conflicts of Finally, it is instructive to look at the two widely cited NIH interest on expert advisory panels toxicological studies of specific EMFs’ effects on thousands of A senior epidemiologist from Sweden, Hardell, has repeatedly rodents,29 30 conducted by experienced and highly respected published in peer-­reviewed journals detailed allegations regarding laboratory scientists at a world-­leading institution. Since their the main WHO scientific advisory body on EMF health effects publication in 2018, epidemiologists and other scientists have and safety—the previously mentioned ICNIRP. Hardell contends pointed out several methodological weaknesses in the conduct that ICNIRP’s membership includes over-­representation of and analysis of these studies that make their unequivocal inter- vested interests, especially the giant multinational telecommu- pretation almost impossible, particularly in terms of their rele- nications firms who are heavily invested in the roll out of 5G vance to human health: excessive statistical inference testing of systems internationally.36 37 ICNIRP has long been influential in multiple (over 1000) hypotheses, without appropriate adjust- EMF regulation: its scientific recommendations to WHO were ment of p values considered ‘statistically significant’; reporting first issued in 1998, updated in 2009, and revised and updated of results ‘often ignoring statistical tests’; failure to explain major again in March 2020.15 Hardell points out that ICNIRP’s pro-­ internal inconsistencies of findings across EMF doses, tumour industry bias may explain its continued reliance only on studies of types and rodent sexes; use of experimental EMF exposures far the thermogenic (heat-­producing) effect of RF-­EMFs in biolog- in excess of any known human ones; uncontrolled confounding ical tissues: these studies would be expected to paint an overly by direct thermogenesis effects—the list goes on.31 32 benign picture of RF-EMF­ safety. This narrow ICNIRP focus In short, laboratory studies of EMF exposure are fraught with flies in the face of published reviews by independent scientists (6, both internal and external validity issues, and cannot replace 8, 13, 26, 27) citing compelling research evidence, accumulating high-­quality human epidemiological studies—though, as we will steadily over the last few decades, of non-thermogenic­ adverse now discuss, these are also hard to come by. effects of RF-­EMFs, affecting diverse human and animal subcel- lular function, tissues and organ systems (see above). In detailed, almost lawyer-­like publications,36 37 Hardell fastidiously docu- Lack of conclusive human epidemiological studies of ments the ICNIRP’s 20 years of dogged defiance, in the face of 5G-specific health effects (but increasing epidemiological widespread criticism by other scientists, that the scientific base AUTHOR PROOF evidence of serious health effects from previous generations for their recommendations remains dated and narrow, rendering of RF-EMF exposures) their guidelines on ‘safe’ RF-­EMF exposure unsafe. Canada’s most senior cancer epidemiologist, Miller et al have last The most damning evidence adduced by Hardell is a table of year summarised the human epidemiological evidence33 linking the cross-­appointments held by six members of the WHO Mono- human breast and brain tumours, male reproductive outcomes graph Group, across five major international advisory panels and child neurodevelopmental conditions to RF-­EMF exposures on the health effects of non-­ionising radiation [36 – page 408]. resulting from the use of past generations of transmission systems. Hardell also describes these scientists’ strong personal links to Critically, this evidence is not about exposure to the high radio the telecommunications industry, a situation likely arising from frequency/short wavelength 5G systems. These systems are too the fact that the ICNIRP itself is a ‘private organisation (non-­ newly deployed to have been extensively studied, especially by governmental organisation; NGO) based in Germany. New

Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 3 Essay expert members can only be elected by members of ICNIRP.’ when pandemic control actions are paramount.42 This writer Hardell contrasts the ICNIRP’s reports to the publications of the completely supports that view of the broader scientific commu- ‘BioInitiative 2012’38 group, of nearly 30 international experts nity: the theory that 5G and related EMFs have contributed to in this field, whose operations are not only wholly independent the pandemic is baseless. of any such ‘vested interests,’ but also entirely transparent. The It follows that, for the current 5G roll-­out, there is a sound current version (March 2020) of the BioInitiative 2012 website38 basis for invoking ‘the precautionary principle’.43 This is the provides detailed descriptions of 988 peer-­reviewed scientific environmental and occupation health principle by which signifi- studies of adverse potential health and biological effects of cant doubt about the safety of a new and potentially widespread EMFs arising from RF and similar non-­ionising sources. The human exposure should be a reason to call a moratorium on vast majority (84.6%) of these 988 studies document disruptive that exposure, pending adequate scientific investigation of its biological effects from such EMFs, almost all of them oper- suspected adverse health effects. In short, one should ‘err on the ating via non-­thermogenic pathways. (This writer would have side of caution’. In the case of 5G transmission systems, there is preferred to see more ‘critical appraisal’ of the quality of the no compelling public health or safety rationale for their rapid studies than the BioInitiative 2012 website provides. However, deployment. The main gains being promised are either economic the major effort entailed in assembling this massive body of (for some parties only, not necessarily with widely distributed scientific evidence, and updating it regularly since 2012, is financial benefits across the population) or related to increased impressive). consumer convenience. Until we know more about what we are Finally, Carpenter has recently published a well-­researched getting into, from a health and ecological point of view, those analysis of how source of funding correlates with study find- putative gains need to wait. ings, across many peer-­reviewed publications over the last few decades, of the relationship between various kinds of EMF expo- Contributors JWF is the sole author of this essay, responsible for all aspects of its sure and several cancers.39 He shows convincingly that studies conceptualisation, background research and writing. funded by private sector entities, with strong vested interests in Funding The authors have not declared a specific grant for this research from any maintaining their current use of the sources of EMFs under study, funding agency in the public, commercial or not-­for-­profit sectors. tend to find no association—whereas studies funded by public Competing interests None declared. sector or independent sources find the opposite. As Carpenter Patient consent for publication Not required. points out, this suggests that many systematic reviews and meta-­ Provenance and peer review Not commissioned; externally peer reviewed. analyses in this field, having failed to correct for this ‘source of Data availability statement Data sharing not applicable as no datasets funding bias,’ likely underestimated the evidence for causation. generated and/or analysed for this study. No data were collected, or repurposed/ used in the writing of this essay.

CONCLUSIONS AND RECOMMENDATION ORCID iD In assessing causal evidence in environmental epidemiology, John William Frank http://​orcid.​org/​0000-​0003-​3912-​4214 Bradford Hill himself pointed out that ‘the whole picture matters;’ he argued against prioritising any subset of his famous REFERENCES nine criteria for causation. One’s overall assessment of the likeli- 1 Scottish Government. 5G: strategy for Scotland. Available: https://www.​gov.​scot/​ hood that an exposure causes a health condition should take into publications/​forging-​digital-​future-​5g-​strategy-​scotland/ [Accessed 8 Oct 2020]. account a wide variety of evidence, including ‘biological plausi- 2 Negreiro M. Towards a European Gigabit Society: Connectivity Targets and 5G. bility’.34 35 After reviewing the evidence cited above, the writer, European Parliament Research Service (EPRS)/ Brussels, European Parliament, 2017. Available: https://www.​europarl.​europa.​eu/​RegData/​etudes/​BRIE/​2017/​603979/​ an experienced physician-epidemiologist,­ is convinced that EPRS_​BRI(​2017)​603979_​EN.​pdf [Accessed 8 Oct 2020]. RF-­EMFs may well have serious human health effects. While 3 Directorate-­General for Internal Policies, European Parliament. 5G deployment: state there is also increasing scientific evidence for RF-­EMF effects of play in Europe, USA and Asia. Brussels: European Parliament, 2019. https://www.​ of ecological concern in other species,6–8 16–18 23 both plant and europarl.​europa.​eu/​RegData/​etudes/​IDAN/​2019/​631060/​IPOL_​IDA(​2019)​631060_​ animal, these have not been reviewed here, for reasons of space EN.​pdf 4 Nordrum, Amy; Clark, Kristen (January 27, 2017). Everything you need to know about and the author’s disciplinary limitations. In addition, there is 5G. IEEE Spectrum Magazine. Institute of Electrical and Electronic Engineers, 2019. convincing evidence, cited above, that several nations’ regula- Available: https://www.​fitce.​gr/​everything-​need-​know-​5g/ [Accessed 8 Oct 2020]. tory apparatus, for telecommunications innovations such as the 5 Karaboytscheva M. Effects of 5G Wireless Communication on Human Health. 5G roll-­out, is not fit for purpose. Indeed, significant elements in European Parliament Research Service (EPRS)/ Brussels, European Parliament, 2020March. Available: https://​europarl.​europa.​eu/​RegData/​etudes/​BRIE/​2020/​ that apparatus appear to have been captured by vested interests. 646172/​EPRS_​BRI(​2020)​646172_​EN.​pdf [Accessed Oct. 8, 2020]. Every society’s public health—and especially the health of those 6 Russell CL. 5 G wireless telecommunications expansion: public health and most likely to be susceptible to the hazard in question (in the case environmental implications. Environ Res 2018;165:484–95. of EMFs, children and pregnant women)—needs to be protected 7 Moskowitz JM. We have no reason to believe 5G is safe. Scientific American blogs, by evidence-­based regulations, free from significant bias. 2019. Available: https://​blogs.​scientificamerican.​com/​observations/​we-​have-​no-​ reason-​to-​believe-​5g-​is-​safe/ [Accessed 8 Oct 2020]. AUTHOR PROOF Finally, this commentary would be remiss if it did not mention 8 Di Ciaula A. Towards 5G communication systems: are there health implications? Int J a widely circulating conspiracy theory, suggesting that 5G and Hyg Environ Health 2018;221:367–75. related EMF exposures somehow contributed to the creation or 9 Vodaphone UK. Is 5G safe? Available: https://​newscentre.​vodafone.​co.​uk/​5g/​is-​5g-​ spread of the current COVID-19 pandemic. There are knowl- safe/ [Accessed 24 Mar 2020]. 10 Foster KR. 5G Is Coming: How Worried Should We Be about the Health Risks? So far, edgeable commentators’ reports on the web debunking this at least, there’s little evidence of danger. Scientific American blogs, 2019. Available: theory, and no respectable scientist or publication has backed https://​blogs.​scientificamerican.​com/​observations/​5g-​is-​coming-​how-​worried-​should-​ it.40 41 Indeed, combatting it is widely viewed by the scien- we-​be-​about-​the-​health-​risks/?​print=​true [Accessed 24 Mar 2020]. tific community as critical to dealing with the pandemic, as 11 Powerwatch UK. Radiofrequency EMFs and health risks. Available: https://www.​ powerwatch.​org.​uk/​library/​downloads/​rf-​emfs-​1-​intro-​2018-​11.​pdf [Accessed Oct. 8, conspiracy theorists holding this view have already carried out 2020]. violent attacks on mobile phone transmission facilities and other 12 AGNIR. Health effects from radiofrequency electromagnetic fields. Report from the symbolic targets, distracting the public and authorities at a time Independent Advisory Group on Non-­Ionising Radiation. In: Documents of the health

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Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 5 Epidemiological Evidence for a Health Risk from Mobile Phone Base Stations

VINI G. KHURANA, LENNART HARDELL, JORIS EVERAERT, ALICJA BORTKIEWICZ, MICHAEL CARLBERG, MIKKO AHONEN

Human populations are increasingly exposed to METHODS microwave/radiofrequency (RF) emissions from wire- less communication technology, including mobile By searching PubMed and using keywords such as base phones and their base stations. By searching PubMed, station, mast, electromagnetic field (EMF), radiofre- we identified a total of 10 epidemiological studies that quency (RF), epidemiology, health effects, mobile assessed for putative health effects of mobile phone base stations. Seven of these studies explored the asso- phone, and cell phone, and by searching the refer- ciation between base station proximity and neurobe- ences of primary sources, we were able to find only 10 havioral effects and three investigated cancer. We human population studies from seven countries that found that eight of the 10 studies reported increased examined the health effects of mobile phone base sta- prevalence of adverse neurobehavioral symptoms or tions. Seven of the studies explored the association cancer in populations living at distances < 500 meters between base station proximity and neurobehavioral from base stations. None of the studies reported expo- symptoms via population-based questionnaires; the sure above accepted international guidelines, suggest- other three retrospectively explored the association ing that current guidelines may be inadequate in pro- between base station proximity and cancer via medical tecting the health of human populations. We believe records. A meta-analysis based on this literature is not that comprehensive epidemiological studies of long- possible due to differences in study design, statistical term mobile phone base station exposure are urgently required to more definitively understand its health measures/risk estimates, exposure categories, and end- impact. Key words: base stations; electromagnetic field points/outcomes. The 10 studies are therefore summa- (EMF); epidemiology; health effects; mobile phone; rized in chronological order (Table 1). radiofrequency (RF); electromagnetic radiation. RESULTS AND DISCUSSION INT J OCCUP ENVIRON HEALTH 2010;16:263–267 We found epidemiological studies pertaining to the health effects of mobile phone base station RF emis- INTRODUCTION sions to be quite consistent in pointing to a possible adverse health impact. Eight of the 10 studies reported Mobile phone base stations are now found ubiquitously increased prevalence of adverse neurobehavioral symp- in communities worldwide. They are frequently found toms or cancer in populations living at distances < 500 near or on shops, homes, schools, daycare centers, and meters from base stations. The studies by Navarro et hospitals (Figure 1). The radiofrequency (RF) electro- al.,2 Santini et al.,3 Gadzicka et al.,4 and Hutter et al.5 magnetic radiation from these base stations is regarded reported differences in the distance-dependent preva- as being low power; however, their output is continu- lence of symptoms such as headache, impaired con- ous.1 This raises the question as to whether the health centration, and irritability, while Abdel-Rassoul et al.6 of people residing or working in close proximity to base also found lower cognitive performance in individuals stations is at any risk. living ≤ 10 meters from base stations compared with the more distant control group. The studies by Eger et al.7 and Wolf and Wolf8 reported increased incidence of cancer in persons living for several years < 400 meters Received from: Department of Neurosurgery, The Canberra Hos- from base stations. By contrast, the large retrospective pital, The Australian National University Medical School, Garran, study by Meyer et al.9 found no increased incidence of Australia (VGK); Department of Oncology, University Hospital, 10 Orebro, Sweden (LH, MC); Research Institute for Nature and Forest cancer near base stations in Bavaria. Blettner et al. [INBO], Brussels, Belgium (JE); Department of Work Physiology reported in Phase 1 of their study that more health and Ergonomics, Nofer Institute of Occupational Medicine, Lodz, problems were found closer to base stations, but in Poland (AB); Department of Computer Science, University Hospital, Phase 211 concluded that measured EMF emissions Orebro, Sweden (MA). Send correspondence to: Dr. Vini G. Khu- were not related to adverse health effects (Table 1). rana, Department of Neurosurgery, The Canberra Hospital, PO Box 103, Woden ACT 2606, Australia; email: . Each of the 10 studies reviewed by us had various Disclosures: The authors declare no conflicts of interest. strengths and limitations as summarized in Table 1. Per-

263 Figure 1—Mobile phone base stations ("antennae" or "masts") in Australia. Upper left: Community shop roof showing plethora of flat panel antennae. Upper right: Hospital roof with flat panel antennae painted to blend in. Lower left: Top of a street light pole. Lower center: Mast erected next to a daycare center. Lower right: Antennae mounted on an office block top floor. taining to those base station studies in which EMF meas- Other problems in several population-based ques- urements were not carried out,3,4,7,9 it should be noted tionnaires are the potential for bias, especially selection8 that distance is not the most suitable classifier for expo- and participation2,3,5,6,11 biases, and self-reporting of sure to RF-EMF. Antennae numbers and configurations, outcomes in combination with the exposure assessment as well as the absorption and reflection of their fields by methods used. For example, regarding limitations in houses, trees, or other geographic hindrances may exposure assessment, in a large two-phase base station influence the exposure level. Further, self-estimation of study from Germany,12,13of the Phase 1 participants (n = distance to nearest base station is not the best predictor 30,047), only 1326 (4.4%) participated with a single of exposure since the location of the closest base station “spot” EMF measurement recorded in the bedroom for is not always known. Such exposure misclassification Phase 2. Further, health effect contributions from all inevitably biases any association towards null. Multiple relevant EMF sources and other non-EMF environmen- testing might also produce spurious results if not tal sources need to be taken into account.12 We acknowl- adjusted for,3,5 as might failure to adjust for participant edge that participant concern instead of exposure age and gender.7 Latency is also an important consider- could be the triggering factor of adverse health effects, ation in the context of cancer incidence following or however this “nocebo effect” does not appear to fully during a putative environmental exposure. In this explain the findings.4,5 Further, the biological relevance regard, the study by Meyer et al.9 found no association of the overall adverse findings (Table 1) is supported by between mobile phone base station exposure and the fact that some of the symptoms in these base-station cancer incidence, but had a relatively limited observa- studies have also been reported among mobile phone tion period of only two years. On the other hand, the users, such as headaches, concentration difficulties, and studies by Eger et al.7 and Wolf and Wolf8 found a sig- sleep disorders.13,14 Finally, none of the studies that nificant association between mobile phone base station found adverse health effects of base stations reported exposure and increased cancer incidence, although the RF exposures above accepted international guidelines, approximate five-year latency between base station the implication being that if such findings continue to exposure and cancer diagnosis appears to be unexpect- be reproduced, current exposure standards are inade- edly short in both of these studies. quate in protecting human populations.15

264 • Khurana et al. www.ijoeh.com • INT J OCCUP ENVIRON HEALTH b Observation period only 2 EMF measurements not car- Limitations unknown, distance to base station unknown surement in one place dwelling, no occupational exposure assessed, time lag from assessment of symptoms subjects aware and EMF measurement age and sex. exposure, exposure onset a . intensity calculated, factors not assessed; Strengths nocebo effect assessed Beckhoff et al., 2009; below) nocebo effect studied nocebo studied exposures assessed station details c incidence in municipal- assessed (Bavaria) years, vague definitions of closer proximity to base distances & other EMF measurements, no base after 3–7 yrs exposure ographic data, no other factors assessed; possible proximity < 150 m; distances & EMF studied, station details 5 yrs of exposure ities with or without base stations cognitive performanceif living under or < 10 m and testing, EMF mea-from base station sured, distances studied, participants n/s, low number of closer to base station(< 500 m) subjects unaware assessed, detailed survey, ried out (see phase II in Berg- station (< 150 m)station (< 300 m) ces studied (< 350 m); early ageof cancer diagnosis major environmental pollutant identifiednocebo unlikely selection bias; no age, sex adjustment. concentration at higherpower density; nocebo and testing, EMF mea-unlikely sured, distances studied; participation rate (< 400 m); early age of cancer diagnosis reliable cancer data collection analysis not adjusted for 165 Yes More symptoms & lower Detailed questionnaire Exact base station details 336 Yes Headaches & impaired Detailed questionnaire Subjects aware, low 967 No 3 x risk of cancer after Maximum beam Other environmental risk 530 No More symptoms with Detailed questionnaire, As above, plus no EMF 500 No More headache with Detailed questionnaire, Subjects aware, no base 1844 Yes > 4 x risk of cancer Reliable cancer & dem- Not all environmental risk 30,047 No More health complaints Wide population 177,428 No No increased cancer Wide population Base MHz Cancer Retrospective GSM incidence case review behavioral sectional Neuro-Neuro- Survey- Survey- GSM-DCS n/s Cancer 101 Retrospective Yes TDMA Neuro- More symptoms withNeuro- Survey- Detailed questionnaire, Low participation, self- Cross- n/s Cancer 900 MHz Retrospective n/s Neuro- Cross-Neuro-Neuro- n/s Cross- Cross- n/s GSM 900 MHz 1326 Yes Health effects probably Measured EMF emissions, Low participation, no incidence case review 935 MHz 6 11 8 4 2 10 2 9 5 7 olf & Wolf “Distance” refers to distance between base station and subjects’ households. “Subjects aware” refers to study participants being aware of the nature study. “Nocebo” effect unlikely because the majority of subjects in study reported little or no concern for base station proximity ABLE 1 Summary of Epidemiological Studies Mobile Phone Base Station Health Effects Navarro T Country)(Year; Assessment DesignSantini Details Participants Measured Key Findings a b c Berg-Beckhoff (2006; Germany) Abdel-Rassoul (2007; Egypt) behavioralBlettner sectional (2009; Germany) Publication Clinical(2003; Spain) behavioral Study(2003; France) questionnaire behavioral 1800 MHzEger Station questionnaire (2004; Israel) incidenceGadzicka (2006; Poland) case review behavioral 850 MHz EMF closer proximity to base questionnaire EMF measured, distan- estimated distances, Meyer (2009; Germany) behavioral sectional GSM 1800 MHz UMTS 1920–1980 caused by stress and not standardized detailed list of symptoms by RF-EMF questionnaires published, single “spot” mea- Hutter (2006; Austria) behavioral sectional n / s = not specified. (2004; Germany) W

VOL 16/NO 3, JUL/SEP 2010 • www.ijoeh.com Health Risks from Mobile Phone Base Stations • 265 CONCLUSIONS References

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Einfluss der raum- remain to be determined. Despite this, the accu- lichen nahe von mobilfunksendeanlagen auf die krebsinzidenz. mulating epidemiological literature pertaining to the [The influence of being physically near to a cell phone trans- health effects of mobile phones13,20 and their base sta- mission mast on the incidence of cancer]. Umwelt-Medizin- Gesellschaft. 2004;17:326-332. tions (Table 1) suggests that previous exposure stan- 8. Wolf R, Wolf D. Increased incidence of cancer near a cell-phone dards based on the thermal effects of EMF should no transmitter station. Int J Cancer Prev. 2004;1:123-128. longer be regarded as tenable. In August 2007, an 9. Meyer M, Gartig-Daugs A, Radespiel-Troger M. Cellular tele- phone relay stations and cancer incidence. Umweltmed Forsch international working group of scientists, researchers, Prax. 2006;11:89-97. and public health policy professionals (the BioInitia- 10. Blettner M, Schlehofer B, Breckenkamp J, Kowall B, Schmiedel tive Working Group) released its report on EMF and S, Reis U, Potthoff P, Schüz J, Berg-Beckhoff G. Mobile phone 21 base stations and adverse health effects: Phase 1 of a population- health. It raised evidence-based concerns about the based, cross-sectional study in Germany. Occup Environ Med. safety of existing public limits that regulate how much 2009;66:118-123. EMF is allowable from power lines, cellular phones, 11. Berg-Beckhoff G, Blettner M, Kowall B, Breckenkamp J, Schlehofer B, Schmiedel S, Bornkessel C, Reis U, Potthoff P, base stations, and many other sources of EMF expo- Schüz J. Mobile phone base stations and adverse health sure in daily life. The BioInitiative Report21 provided effects: Phase 2 of a cross-sectional study with measured radio detailed scientific information on health impacts frequency electromagnetic fields. Occup Environ Med. 2009; 66:124-130. when people were exposed to electromagnetic radia- 12. Neubauer G, Feychting M, Hamnerius Y, Kheifets L, Kuster N, tion hundreds or even thousands of times below limits Ruiz I, Schüz J, Uberbacher R, Wiart J, Röösli M. Feasibility of currently established by the FCC and International future epidemiological studies on possible health effects of mobile phone base stations. Bioelectromagnetics. 2007;28:224- Commission for Non-Ionizing Radiation Protection in 230. Europe (ICNIRP). The authors reviewed more than 13. Khan MM. Adverse effects of excessive mobile phone us. Int J 2000 scientific studies and reviews, and have con- Occup Environ Health. 2008;21:289-293. 14. Söderqvist F, Carlberg M, Hardell L. Use of wireless telephones cluded that: (1) the existing public safety limits are and self-reported health symptoms: A population-based study inadequate to protect public health; and (2) from a among Swedish adolescents aged 15-19 years. Environ Health public health policy standpoint, new public safety 2008;7:18. 15. Hardell L, Sage C. Biological effects from electromagnetic field limits and limits on further deployment of risky tech- exposure and public exposure standards. Biomed Pharma- nologies are warranted based on the total weight of cother. 2008;62:104-109. evidence.21 A precautionary limit of 1 mW/m2 (0.1 16. Salford LG, Nittby H, Brun A, Grafström G, Malmgren L, Som- 2 marin M, Eberhardt J, Widegren B, Persson BRR. The mam- microW/cm or 0.614 V/m) was suggested in Section malian brain in the electromagnetic fields designed by man with 17 of the BioInitiative Report to be adopted for out- special reference to blood-brain barrier function, neuronal door, cumulative RF exposure.21 This limit is a cau- damage and possible physical mechanisms. Prog Theor Phys Suppl. 2008;173:283-309. tious approximation based on the results of several 17. Sheppard AR, Swicord ML, Balzano Q. Quantitative evaluations human RF-EMF studies in which no substantial of mechanisms of radiofrequency interactions with biological adverse effects on well being were found at low expo- molecules and processes. Health Phys. 2008;95:365-396. 18. Khurana VG. Cell phone and DNA story overlooked studies. Sci- sures akin to power densities of less than 0.5 – 1 ence. 2008;322:1325. mW/m2.2,5,22–26 RF-EMF exposure at distances > 500 m 19. Yang Y, Jin X, Yan C, Tian Y, Tang J, Shen X. Case-only study of from the types of mobile phone base stations reviewed interactions between DNA repair genes (hMLH1, APEX1, MGMT, XRCC1 and XPD) and low-frequency electromagnetic herein should fall below the precautionary limit of fields in childhood acute leukemia. Leuk Lymphoma. 2008; 0.614 V/m. 49:2344-2350.

266 • Khurana et al. www.ijoeh.com • INT J OCCUP ENVIRON HEALTH 20. Hardell L, Carlberg M, Soderqvist F, Hansson Mild K. Meta- 24. Thomas S, Kühnlein A, Heinrich S, Praml G, Nowak D, von analysis of long-term mobile phone users and the association Kries R, Radon K. Personal exposure to mobile phone frequen- with brain tumours. Int J Oncol. 2008;32:1097-1103. cies and well-being in adults: A cross-sectional study based on 21. Sage C, Carpenter D, eds. BioInitiative Report: A rationale for a dosimetry. Bioelectromagnetics. 2008;29:463-470. biologically-based public exposure standard for electromag- 25. Zwamborn APM, Vossen SHJA, van Leersum BJAM, Ouwens netic fields (ELF and RF) [Internet]. 2007 [cited April 3, 2009]. MA, Makel WN. Effects of global communication system radio- Available from: http://www.bioinitiative.org. frequency fields on well being and cognitive functions of 22. Kundi M, Hutter HP. Mobile phone base stations - Effects on human subjects with and without subjective complaints. Orga- wellbeing and health. Pathophysiol. 2009;16:123-35. nization for Applied Scientific Research (TNO), Physics and 23. Henrich S, Ossig A, Schlittmeier S, Hellbrück J. Elektromag- Electronics Laboratory: The Hague, Netherlands, 2003. netische Felder einer UMTS-Mobilfunkbasisstation und 26. Regel SJ, Negovetic S, Röösli M, Berdinas V, Schuderer J, Huss mögliche Auswirkungen auf die Befindlichkeit—eine experi- A, Lott U, Kuster N, Achermann P. UMTS base station like expo- mentelle Felduntersuchung [Electromagnetic fields of a UMTS sure, well being and cognitive performance. Environ Health mobile phone base station and possible effects on health – Perspect. 2006;114:1270-1275. results from an experimental field study]. Umwelt Med Forsch Prax. 2007;12:171-180.

VOL 16/NO 3, JUL/SEP 2010 • www.ijoeh.com Health Risks from Mobile Phone Base Stations • 267 Gail Dent

From: [email protected] Sent: 04 February 2021 15:07 To: [email protected] Subject: RE: Planning Application R/85/51A/GDO

Dear Mr Bishop

Thank you for sending me a copy of your report in advance of Tuesday's planning committee meeting re the West Scrafton mast.

I notice in the report that you say only one of the numerous town and parish councils and parish meetings contacted by MANY had not given their project their support. The exception was Agglethorpe with . For the sake of clarity may I point out that East Witton Parish Council was approached by MANY and was given a Zoom presentation in Sept 2020. Following that the council took the decision not to get involved. It concluded that broad band connection and mobile coverage was more than adequate for the needs of those in the parish and saw no benefit in proceeding.

As East Witton Parish Council has one of the larger populations in Coverdale, I would like to think that its decision not to take part is worthy of note. It may provide some balance. If you wish to verify any of the above the parish clerk is Sarah Sayer who I am sure will be happy to help. I believe she is known to you.

Yours

Richard Wells Parish Councillor East Witton

-----Original Message----- From: [email protected] Sent: 29 January 2021 15:40 To: [email protected] Subject: Planning Application R/85/51A/GDO

Please see attached letter regarding Application for prior approval under Part 16 of Schedule 2 to the Town & Country Planning (General Permitted Development) (England) Order 2015 as amended by the Town & Country Planning (General Permitted Development) (England) (Amendment) (no.2) Order 2016 and in accordance with the electronic communications code under the Telecommunications Act 1984 Schedule 2 as amended by the Communications Act 2003 for the installation of a 17m wooden utility Pole (15m above ground level) with mobile communications antenna and equipment cabinet at Land to the south east of existing agricultural buildings off High Lane, West Scrafton, Leyburn

Planning Department Yorkshire Dales National Park Authority

1 Gail Dent

From: Andrew Bishop Sent: 04 February 2021 14:46 To: Planning Subject: FW: R/85/51A/GDO - Proposed Telecommunications Mast, West Scrafton

Another supporter

Andrew Bishop Senior Planning Officer

Direct: Mobile:07783 876142 Switchboard: 0300 456 0030

www.yorkshiredales.org.uk

Yorkshire Dales National Park Authority Yoredale | Bainbridge | Leyburn | DL8 3EL

From: Enquiries [mailto:[email protected]] Sent: 04 February 2021 12:48 To: Andrew Bishop Subject: R/85/51A/GDO - Proposed Telecommunications Mast, West Scrafton

Dear Mr Bishop

We understand from some of our clients in Coverdale that the above application has been submitted for a mast the purpose of which is to improve communications for the dale.

This is just a letter of support on behalf of a number of clients we have in the dale who’s businesses would benefit from improved communications so I would be grateful if you could take this as a letter of support.

Kind regards

Malcolm Tempest

Malcolm Tempest Ltd High Parks Newton le Willows Bedale North Yorkshire DL8 1TP

01677 450 777

1 Mount Pleasant Carlton Coverdale Leyburn DL8 4BG

18th January 2021

To Whom it may Concern Leer in support of the Planning Applicaon R/85/51A/GDO– telecommunicaons mast I am wring in support of the planning applicaon ref: R/85/51A/GDO for a telecommunicaons mast to be constructed at High Lane, West Scraon, Leyburn. I am a resident of Coverdale who would significantly benefit from improved mobile and broadband connecons. We struggle and feel disadvantaged by not having reliable mobile recepon. People in urban areas and other parts of the Dales have had coverage for many years now and if you have this connecvity people tend to take it for granted – connecvity is not going to go away, this year highlights this. The MANY project offers us an opportunity to do something about it. Some parts of Coverdale are lucky enough to have Fibre to the premises but unfortunately this can not be relied on to provide total coverage and having tried this opon our property did not get any increase in speed or reliability. Like most parts of the UK, communicaon needs to be a mixture of both good broadband and mobile coverage. The MANY project has carried out significant community engagement and our household has had the opportunity to talk at length about the implicaons regarding failing unreliable mobile recepon coupled with very slow and unreliable broadband speeds. My husband works full-me from home for an American company with worldwide responsibilies, I run a holiday coage business from home and our son is currently studying from home for his final university year - all of these necessitate us using Zoom etc for meengs, briefings, seminars and only one of us can be online at any one me. This project gives us an opportunity to change Coverdale for the beer, whilst influencing future Government policy. We need to bring Coverdale and similar areas in line with the rest of the UK so we can ensure the sustainability of the area. I publicly back the project and their request for planning.

Rebecca Parr

OFFICIAL Gail Dent

From: Jo Harrison-Topham Sent: 03 February 2021 21:16 To: Andrew Bishop; Planning; [email protected]; localplan Subject: Planning Application R/85/51A/GDO

Dear YDNPA Planning Committee Members, and Chief Planning Officer,

I would like to object to the above planning application, and would like you to record my objection for the following reasons:

1) The project has not been sufficiently well presented to all residents, and the information is woefully incomplete and actually misleading.

2) I absolutely do not want to see any masts in Coverdale, it is one of the very rare areas of natural unspoilt beauty in the world, and the benefits to all residents and visitors must not be sold down the line in the name of “progress”. Real understanding of progress would be to protect the area, it will be an unquestionable plus in the future on many levels.

3) A fuller understanding of effective connectivity in Coverdale, whilst protecting the environment, should be further investigated and understood. The project MANY presents "Coverdale as a test bed for 5G connectivity” is a shameful waste of public money, and I will be writing to our MP to protest.

Yours sincerely,

Jo Harrison-Topham

Cotescue Park Middleham Leyburn North Yorkshire DL8 4RJ

Tel: 01969 640 575 Mob: 07730 700 461 jo@.com

1 Name ~ C/100 S1mpS.or;

Address Gt I ders beet -fur~ fVU2_ I me_ r b "} ULlj bvV-V) V\ . j 0 ,r(C -3 ()L 0 ~ TL-0

18th January 2021

Dear Pl CIYlfl 'r>.3 c('C1Ce_v ' Letter in support of the Planning Application R/85/SlA/GDO- telecommunications mast

I am writing in support of the planning application ref: R/85/SlA/GDO for a telecommunications mast to be constructed at High Lane, West Scrafton, Leyburn.

I am a resident of the Coverdale who would significantly benefit from improved mobile and broadband connections. We struggle and feel disadvantaged by not having any mobile reception. People in urban areas and other parts of the Dales have had coverage for many years now and if you have this connectivity people tend to take it for granted - connectivity is not going to go away, this year highlights this.

The MANY project offers us an opportunity to do something about it. Some parts of Coverdale are lucky enough to Fibre to the premises but unfortunately this can not be relied on to provide total coverage and there are many properties that will not get any increase in speeds or new infrastructure for a long time. Like most parts of the UK, communication needs to be a mixture of both good broadband and mobile coverage.

The MANY project has carried out significant community engagement. This project gives us an opportunity to change Coverdale for the better, whilst influencing future Government policy. We need to bring Coverdale and similar areas in line with the rest of the u.K so we can ensure the sustainability of the area.

I publicly back the project and their request for planning.

Yours faithfully

Signature

RECEIVED BY:- Yorkshire Dale~ National Park Authority I I 2 7 JAN 2021 Name

18th January 2021

Dear

Letter in support of the Planning Application R/85/SlA/GDfr telecommunications mast

I am writing in support of the planning application ref: R/85/SlA/GDO for a telecommunications mast to be constructed at High Lane, West Scrafton, Leyburn.

I am a resident of the Coverdale who would significantly benefit from improved mobile and broadband connections. We struggle and feel disadvantaged by not having any mobile reception. People in urban areas and other parts of the Dales have had coverage for many years now and if you have this connectivity people tend to take it for granted - connectivity is not going to go away, this year highlights this.

The MANY project offers us an opportunity to do something about it. Some parts of Coverdale are lucky enough to Fibre to the premises but unfortunately this can not be relied on to provide total coverage and there are many properties that will not get any increase in speeds or new infrastructure for a long time. Like most parts of the UK, communication needs to be a mixture of both good broadband and mobile coverage.

The MANY project has carried out significant community engagement. This project gives us an opportunity to change Coverdale for the better, whilst influencing future Government policy. We need to bring Coverdale and similar areas in line with the rest of the UK so we can ensure the sustainability of the area.

I publicly back the project and their request for planning.

Yours faithfully

RECEIVED BY:- • 1Yorkshire fJa!eE National Park Authority 2 6 JAN 2021 Name ~'2-EEN Address SIA:BLc

13th January 2021

Dear

Letter in support of the Planning Application R/85/SlA/GD~ telecommunications mast

I am writing in support of the planning application ref: R/85/SlA/GDO for a telecommunications mast to be constructed at High Lane, West Scrafton, Leyburn.

I am a resident of the Coverdale who would significantly benefit from improved mobile and broadband connections. We struggle and feel disadvantaged by not having any mobile reception. People in urban areas and other parts of the Dales have had coverage for many years now and if you have this connectivity people tend to take it for granted - connectivity is not going to go away, this year highlights this.

The MANY project offers us an opportunity to do something about it. Some parts of Coverdale are lucky enough to Fibre to the premises but unfortunately this can not be relied on to provide total coverage and there are many properties that will not get any increase in speeds or new infrastructure for a long time. Like most parts of the UK, communication needs to be a mixture of both good broadband and mobile coverage.

The MANY project has carried out significant community engagement. This project gives us an opportunity to change Coverdale for the better, whilst influencing future Government policy. We need to bring Coverdale and similar areas in line with the rest of the UK so we can ensure the sustainability of the area.

I publicly back the project and their request for planning.

Yours faithfully

Signature

i RECEIVED BY:- . , lYorkshirP. DalP" M<>tional Park Authonty ' ·l 2 6 JAN 2021 Karen Banks

From: Jennifer Lister Sent: 03 February 2021 13:35 To: Planning; localplan Subject: Ref R/85/51A/GDO

YDNPA Yorebridge Bainbridge Leyburn DL8 3EL

3 February 2021

Dear Sirs

Ref R/85/51A/GDO

As a resident of Coverdale I write to object to the above 5G test bed mast application and wish my objection to be recorded.

I have heard that Coverdale, as a whole, shall not be covered and that the mast will just duplicate the service already offered by BT, which I have found most efficient in Gammersgill.

I am also very concerned about the health and environmental impacts which I believe you have not researched adequately. If I am mistaken please furnish me with details of access to your findings.

Yours faithfully

Jennifer Lister Walnut Tree Cottage Gammersgill Leyburn DL8 4TP

1

Gail Dent

From: Andrew Bishop Sent: 02 February 2021 15:44 To: Planning Subject: FW: Coverdale 5g Mast R/85/51A/GDO

Andrew Bishop Senior Planning Officer Direct: Mobile:07783 876142 Switchboard: 0300 456 0030 www.yorkshiredales.org.uk

Yorkshire Dales National Park Authority Yoredale | Bainbridge | Leyburn | DL8 3EL

-----Original Message----- From: Georgina Anderson [mailto:[email protected]] Sent: 02 February 2021 15:41 To: Andrew Bishop Cc: [email protected] Subject: Coverdale 5g Mast

Dear Andrew,

Ref: R/85/51A/GDO ————————————-

Please record my objection to the above planning application.

1. I do not believe the project of which it is part properly addresses the connectivity needs of Coverdale, and in particular, we do not need a 5G ‘test bed’ 2. It duplicates other efforts to provide these and I do not wish to see an uncontrolled proliferation of masts in Coverdale. 3. There has been insufficient openness about the project, and the information which has been presented has not included all the facts, and in some cases misled residents.

Yours sincerely. Georgina Anderson

The Grange Farmhouse, East Witton Leyburn N. Yorks DL8 4SL

Sent from my iPad

1 Gail Dent

From: lily leatham Sent: 02 February 2021 15:34 To: Andrew Bishop; Planning; [email protected]; localplan Cc: [email protected] Subject: 5 g

Dear YDNPA planning committee members and chief planning officer,

PLANNING APPLICATION: R/85/51A/GDO

Please record my objection to the above planning application.

. I do not believe the project or which is part properly addresses the connectivity needs of Coverdale and in particular, we do not need a 5G “test bed” . It duplicates other efforts to provide these and I do not wish to see an uncontrolled proliferation of masts in Coverdale. . There has been insufficient openness about the project, and the information which has been presented has not included all the facts, and in some cases misled residents.

Yours sincerely

Lily leatham Leyburn hall DL8 5BP

Sent from my iPhone

1 Gail Dent

From: Lucy Leatham Sent: 02 February 2021 15:27 To: Andrew Bishop; Planning; [email protected]; localplan Cc: [email protected] Subject: Ref No: R/8551A/GDO

Dear YDNPA planning committee members and chief planning officer,

PLANNING APPLICATION: R/85/51A/GDO

Please record my objection to the above planning application.

. I do not believe the project or which is part properly addresses the connectivity needs of Coverdale and in particular, we do not need a 5G “test bed” . It duplicates other efforts to provide these and I do not wish to see an uncontrolled proliferation of masts in Coverdale. . There has been insufficient openness about the project, and the information which has been presented has not included all the facts, and in some cases misled residents.

Yours sincerely

Lucy Leatham Leyburn Hall Leyburn North Yorkshire DL8 5BP

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1 02/02/2021

Dear Sir, Madam

My name is Jonathan Brown and I am writing to you this letter of support for your 5G role out within the local community of Coverdale. As a boy who grew up in Coverdale over the last 25 years, I cannot tell you how much this Technology would benefit the Dale for all aspects of life from private homes and local services to farms and Business operating within the dale.

I myself work as Communications Engineer in the British Army and have experience and training in technologies of 3G, 4G and 5G and am well informed of the Benefits, Limitations, Rates and hazards associated with the Technology and can safely say that the planned installation of these systems in Coverdale would have great benefits with very little risk in the area in terms of public health as well as local wildlife and farm stock which are crucial to the dale.

Having grown up in the dale between 1994 – 2019 I can tell you first hand the struggles and differences Coverdale has in comparison to an area no more than 10 miles away in the nearest towns. Having to walk to the top of Pen Hill to get a basic Mobile signal to answer a text was one of my more memorable experiences as a kid there. Likewise, local internet access has varied over the years in the dale but still can be considered behind in comparison again with other areas not so far away.

I have had a look over the Planning application (85/51A/GDO) and again I support the application for the Installation of the Mast near West Scrafton to extend coverage in the dale. Knowing these types of systems from my work, I find that this planning application provides the best option to provide the best coverage and service to the area with little disruption to local scenery and wildlife.

It goes without saying that in a remote area like Coverdale Accidents and Emergency services require these technologies as well, such mobile apps such as What3Word provide a great life saving service and are designed for areas such as Coverdale and can be the difference between a Life and death scenario. Emergency service and Mountain rescue systems as well are upgrading to use 4G and 5G technologies more as well, again Coverdale needs these technologies to avoid an unfortunate incident which could have been prevented with better Data coverage.

I hope this letter serves the Project well and look forward to its Benefits that it will bring Coverdale.

Yours Sincerely Mr Jonathan Brown

Mobile No: 07584024860

Email: [email protected]

Gail Dent

From: Andrew Bishop Sent: 02 February 2021 13:49 To: Planning Subject: FW: Many mast application R/85/51A/GDO west scrafton

Please acknowledge and record correspondent Thanks

Andrew Bishop Senior Planning Officer

Direct: Mobile:07783 876142 Switchboard: 0300 456 0030

www.yorkshiredales.org.uk

Yorkshire Dales National Park Authority Yoredale | Bainbridge | Leyburn | DL8 3EL

From: [email protected] [mailto:[email protected]] Sent: 02 February 2021 12:26 To: Andrew Bishop Subject: Many mast application R/85/51A/GDO west scrafton

Dear Sir /Madame

My name is Raymond brown , I am a resident in Coverdale , the dale which my family has lived in for generations and I run my business from.

I have had help from the planning team before at the 11th hour when we saved our local pub and turned it into a community pub of which I was chair for nearly 10 years

I was one of the people who erected the Coverdale Hollywood type sign and the person who ran the soapbox derbys after the TOUR De Yorkshire had rolled through the dale In short I wish to try to reassure you I want only what I feel is best for the dale ! In Carlton we have a reasonable broadband speed but up the dale it drops off to 2 to 3 mbs when you get to Braidley with not enough upload speed to send much more than an email making working from home difficult as it all the time "drops out "

The past year if nothing else has highlighted the necessity for a good broadband connection and the ability to "work from home " the Dale needs residents not empty houses . Young Families if they have the ability to work from home will find it much more of an attractive proposition to live in the dale . This must surly be a goal ?

We DESPERATELY need a mobile signal in the dale ! the MANY project whilst maybe not ideal could be our only chance left as a vehicle to achieve this ! It is a test-bed so at the outset is not in

1 a position to say exactly what can be 100% obtainable but "hopes " (key word) to roll out broadband to the main of the outlying properties in the dale

The infrastructure again " Hopefully "will eventually be able to offer a roaming signal and so a mobile signal for all networks in the dale which can as you will be aware be a case of life and death

To do my banking or authenticate a credit card I need to receive a text !! Try this with no facility ! mobiles now work on wi fi but vodafone texts dont !

I have conducted a survey and would estimate 60% of the dale are for trying this project 30 % claiming not to know enough to have an opinion and 10% against the 10 % have been fairly busy stirring the pot

I implore you to try to help Coverdale obtain a mobile signal and service the outlying properties with broadband

Could I also pass my thanks on to Neil Heseltine for publicly acknowledging the work the gamekeepers /farmers do on our behalf looking after the countryside please could you acknowledge receipt of this email yours

Raymond Brown

2 Gail Dent

From: Oliver Leatham Sent: 02 February 2021 13:06 To: Andrew Bishop; Planning; [email protected]; localplan Cc: Juliet Maddan; Harriet Corner Subject: Ref Planning Application: R/85/51A/GDO

Dear YDNPA planning committee members and chief planning officer,

Ref Planning Application: R/85/51A/GDO

Please record my objection to the above planning application.

• I do not believe the project of which it is part properly addresses the connectivity needs of Coverdale, and in particular, we do not need a 5G “test bed”.

• It duplicates other efforts to provide these and I do not wish to see an uncontrolled proliferation of masts in Coverdale.

• There has been insufficient openness about the project, and the information which has been presented has not included all the facts, and in some cases misled residents.

Yours sincerely,

Oliver Leatham

Oliver Leatham Non-executive Director

Leyburn Hall, Commercial Square, Leyburn, North Yorkshire DL8 5BP

Office – +44 (0)1969 624558 Mobile - +44 (0)7710 819387

Disclaimer

This e-mail and any attachments are confidential and intended solely for the addressee. If you are not the addressee or have received this e-mail in error, please notify the sender immediately, delete it from your system and do not copy, disclose or otherwise act upon any part of this e-mail or its attachments.

Internet communications are not guaranteed to be secure or virus-free.

Leathams Ltd does not accept responsibility for any loss arising from unauthorised access to, or interference with, any Internet communications by any third party, or from the transmission of any viruses. Replies to this e-mail may be monitored by Leathams Ltd for operational or business reasons.

Any opinion or other information in this e-mail or its attachments, that does not relate to the business of Leathams Ltd, is personal to the sender and is not given or endorsed by Leathams Ltd.

1 Gail Dent

From: James Brumfitt Sent: 02 February 2021 11:59 To: Andrew Bishop; Planning; [email protected]; localplan; [email protected] Subject: Objections to MANY Attachments: 1st proof 25th Jan CCandP Letter (dragged).pdf

I strongly object to the planned 5G installation Mr James Brumfitt Home Farm Coverdale Dl84RR

1

2nd February 2021

Dear YDNPA planning committee members and chief planning officer,

Planning Application: R/85/51A/GDO

Please record my objection to the above planning application.

• I do not believe the project of which it is part properly addresses the connectivity needs of Coverdale, and in particular, we do not need a 5G “test bed”.

• It duplicates other efforts to provide these and I do not wish to see an uncontrolled proliferation of masts in Coverdale.

• There has been insufficient openness about the project, and the information which has been presented has not included all the facts, and in some cases misled residents.

Yours sincerely,

Sophie Dingwall Lane House Jervaulx Ripon North Yorkshire HG4 4PQ Clemmie Corner Coverham Abbey Leyburn North Yorkshire DL8 4RL

Dear YDNPA Planning Committee Members and Chief Planning Officer

Planning Application R/85/51A/GDO

Please record my objection to the above planning application.

Having lived in Coverdale all my life, surrounded by natural beauty and complete tranquillity I have found it completely heart-breaking to find out about a 5G “test bed”.

This only came to my attention after hearing about it in the newspaper, as you can imagine this came as a huge shock as I pictured the peacefulness of Coverdale being obscured by masts and other apparatus. As The Yorkshire Dales National Park has said themselves, it is best known for it’s “stunning scenery”; I find it extremely hard to believe that this will carry on being said after we are left with the remains of this project in 2 years time.

As a teenager, I honestly cannot think of a single reason why I would have any need for 5G. From having done significant research into it for myself, I am not only concerned about the effects on mental health but also on wildlife. I am struggling to understand why this project chooses to do their tests in a place flourishing with curlews and oyster catchers? I think the project does not address the connectivity needs of Coverdale, furthermore, I believe that the project has not listened to our community wants and needs.

In conclusion, it would extremely sadden me when I return to this amazing place that I call home in 10 years’ time to find out that the views and nature have been destroyed. People come here to escape from their fast lives in the city, why bring the city to the countryside?

Yours sincerely

Clemmie Corner

Gail Dent

From: Freddie Corner Sent: 01 February 2021 21:44 To: Andrew Bishop; [email protected]; localplan; Planning Subject: Fwd: Planning Application R/85/51A/GDO

My address is as follows:

Coverham Abbey, Middleham, Leyburn, North Yorks DL8 4RL 01969 640218 07710. 899589 (no reception at home though)

------Forwarded message ------From: Freddie Corner Date: Mon, 1 Feb 2021 at 8:14 pm Subject: Planning Application R/85/51A/GDO To: , , ,

Dear Planning Committee Members and Chief Planning Officer

Please record my objection to the above planning application. I am a 22 year old Coverdale resident, currently studying for my finals at University and I have a number of issues with the idea of 5G masts being erected in Coverdale and the surrounding area.

Firstly, I am currently writing my Dissertation on affordable housing in the YDNP and my primary research has solidified my view that there needs to be connection improvements in the Dales to allow for people to work from home and to attract business growth in the area. However, I struggle to understand it possible that our beautiful Dale should be used as a "test bed" for what is quite frankly, an unknown and potentially dangerous form of connection (5G).

Those in charge of this proposition have completely disregarded all local and public opinion and I for one am certainly not happy with the thought that the Dales should be blighted by these enormous 15 metre masts. Furthermore, nobody has much (if any knowledge) of the health repercussions of this outlandish experiment and there are certainly a great number of health related questions that need answering. Connectivity is of course important to many but to choose a mostly rural area, an Area of Outstanding Natural Beauty and a safe haven for wildlife and livestock is baffling to me. There are a number of other avenues that need to be investigated first, including the introduction of super fast, fibre optic broadband and I believe that these can be both safer and more cost effective.

Finally, I will leave you with section 172 of the National Planning Policy Framework:

'Great Weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas and should be given great weight in National Parks.'

1 And Section C: Consideration of such applications SHOULD include an assessment of any detrimental effect on the environment (this case), the landscape (this case) and recreational opportunities (this case).

I really hope that you, as a protective body, investigate the harmful effects of this idea. It is incredibly important to protect this outstanding area, for my generation and for many generations to come. Thank you for reading.

Yours sincerely

Freddie Corner

2

Karen Banks

From: William Harrison-Topham Sent: 31 January 2021 20:57 To: Andrew Bishop; Planning; [email protected]; localplan Subject: Planning Application R/85/51A/GDO

Dear YDNPA planning committee members and chief planning officer,

Please record my objection to the above planning application.

1. I do not believe the project of which it is part properly addresses the connectivity needs of Coverdale, and in particular, we do not need a 5G “test bed”.

2. It duplicates other efforts to provide these and I do not wish to see an uncontrolled proliferation of masts in Coverdale.

3. There has been an insufficient openness about the project, and the information which has been presented has not included all the facts, and in some cases misled residents.

I am 15 years old and fibre broadband gives me everything that my age group and I need because we can talk on our phones and do whatever we need on WiFi.

I have got my whole life ahead of me, and do you seriously think that you need to introduce 5G to an unspoilt AONB like Coverdale after all of the damage that you adults have already done to his world? I’m not very good at science anyway but there seems to be a lot of health related issues as which have not been addressed yet, no one knows what happens and nor do you. In my view what is the point of a national park if you don’t protect the wildlife and scenery too. I’m no eco warrior myself, I just hope my age group doesn’t have to go picking up the mess that you have created and left behind.

Yours sincerely,

William Harrison-Topham Cotescue Park Leyburn North Yorkshire DL8 4RJ

Sent from my iPad

1 Karen Banks

From: Eileen Harrison-Topham Sent: 31 January 2021 17:05 To: Andrew Bishop; Planning; [email protected]; localplan; [email protected] Subject: Planning Application R/85/51A/GDO

Dear YCNPA Planning Committee members and Chief Planning Officer,

Planning Application : R/85/51A/GDO

Please record my objection to the above planning application.

* I do not believe the project of which it is part properly addresses the connectivity needs of Coverdale and, in particular, we do not need a 5G "test bed".

* It duplicates other efforts to provide these and I do not wish to see an uncontrolled proliferation of masts in Coverdale.

* There has been unsufficient openness about the project, and the information which has been presented has not included all the facts, and in some cases misled residents.

Yours sincerely

Eileen Harrison-Topham (Mrs)

Caldbergh Hall, Caldbergh, Leyburn. DL8 4RW

1 Karen Banks

From: Rebecca Suttill Sent: 31 January 2021 16:11 To: Planning Cc: [email protected] Subject: Objection to Planning Application R/8551A/GDO

Dear YDNPA planning committee members and chief planning officer,

Planning Application R/85/51AGDO

Please record my objection to the above planning application.

I do not believe the project of which it is part properley addresses the connectivity needs of Coverdale, and in particular, we do not need a 5G test bed.

It duplicates the other efforts to provide these abd i do not wish to see an uncontrolled proliferation of masts in Coverdale.

There has been insufficient openness about the project, and the information which has been presented has not included all the facts, and in some cases mislead residents. yours sincerely

Rebecca Jane Suttill

Garden Cottage Cotescue Park Coverham Leyburn DL8 4RJ

1 Karen Banks

From: David Langley Sent: 31 January 2021 13:50 To: Andrew Bishop; Planning; [email protected]; localplan Subject: R/85/51A/GDO Objection

David Langley Saltoun Cottage Cotherstone Barnard Castle DL12 9PF

Dear YDNPA planning committee members and chief planning officer

Planning Application Objection: R/85/51A/GDO

Please record my objection to the above planning application.

I do not believe the project of which it is part, properly addresses the connectivity needs of Coverdale, and in particular, we do not need a 5G “test bed.”

It duplicates other efforts to provide these and I do not wish to see an uncontrolled proliferation of masts in Coverdale.

There has been insufficient openness about the project, and the information which has been presented has not included all the facts, and in some cases arguably misled residents.

Further, there are myriad unresolved health, privacy, and security concerns pertaining to 5G technology. There are many examples now of moratoriums on the rollout of this untested technology being called for and in place around the world.

Yours faithfully David Langley

1 Karen Banks

From: Daniel McMillen Sent: 30 January 2021 16:07 To: Andrew Bishop; Planning; [email protected]; localplan Subject: Objection - Planning Application: R/85/51A/GDO

Dear YDNPA planning committee members and chief planning officer,

Planning Application: R/85/51A/GDO

Please record my objection to the above planning application.

* I do not believe the project of which it is part properly addresses the connectivity needs of Coverdale, and in particular, we do not need a 5G “test bed”.

* It duplicates other efforts to provide these and I do not wish to see an uncontrolled proliferation of masts in Coverdale.

* There has been insufficient openness about the project, and the information which has been presented has not included all the facts, and in some cases misled residents.

Areas of natural beauty within a designated national park should be kept as such, natural, and without visually invasive and unnecessary construction for “test” projects.

Yours sincerely,

Daniel McMillen, Park Cottage, Cotescue Park DL84RJ

1 Karen Banks

From: Clare Sent: 30 January 2021 10:52 To: Planning Subject: R/85/51A/GDO

Dear YDNPA planning committee,

Planning application ref as above.

Please record that I have NO OBJECTIONS for the mast at West Scrafton.

We desperately need better connectivity in the area. Many residents are working from home and aren’t able to provide a professional service to their customers. As a direct result, from poor broadband connectivity. Home schooling has been a nightmare, due to loss of connection. I’ve been waiting over 16 years for a better service. Working from home all these years, has at times been impossible due to poor internet speeds.

The list is endless as to why we need this type of technology in the Dale.

Yours Sincerely,

Clare Lambert

Braidley Manor Braidley Leyburn North Yorkshire DL8 4TX

Sent from my iPhone

1 Gail Dent

From: James Harrison-Topham Sent: 29 January 2021 15:28 To: Andrew Bishop; Planning; [email protected]; localplan Subject: Planning Application R/85/51A/GDO Attachments: Electromagnetic fields 5G and health - John William Frank.pdf

Dear YDNPA planning committee members and Chief Planning Officer,

Planning Application: R/85/51A/GDO

Please record my objection to the above planning application on a number of grounds:

• I do not believe the project of which it is part properly addresses the connectivity needs of Coverdale, and in particular, we do not need a 5G “test bed”.

• Superfast broadband is currently more than sufficient and the focus should be made on completing the roll- out of this throughout the dale. Over 90% of the population of the dale already have it – YDNP should be lobbying with the residents to get it to the remaining 10%.

• It duplicates other efforts to provide these and I do not wish to see an uncontrolled proliferation of masts in Coverdale.

• There has been insufficient openness about the project, and the information which has been presented has not included all the facts, and in some cases misled residents.

• I have seen the paper by Frank (attached) in the British Medical Journal (BMJ) – which is externally peer reviewed and I concur with his advocating the application of the precautionary principle.

• I have been brought up in Coverdale and my family have owned the Caldbergh Estate for over 400 years. Much of the estate falls within a SSI and we consider ourselves very honoured to be tasked with the management of this area. We are a nesting site for Hen Harriers, Black Grouse, Curlews, Merlin, Lapwing (all red listed) and Red Grouse (amber listed). If there is any potential for the unknown consequences of 5G to impact on any of these species it would be an impact of international significance. As it stands there is no conclusive proof that the deployment of 5G represents no harm to ecological receptors. On the contrary there is a growing body of evidence to suggest otherwise.

• We are incredibly privileged to live in this beautiful dale and we just do not need to have the landscape ruined further through the installation of masts. The wild, remote and unspoilt nature of the dale is its true strength – it is why we live here and visitors come.

Your Sincerely

James Harrison-Topham

Cotescue Park Middleham Leyburn North Yorkshire DL8 4RJ t: +44 1423 259 250 m: +44 7831 708 181 e: [email protected]

1 Essay Electromagnetic fields, 5G and health: what about the precautionary principle? John William Frank ‍ ‍

Usher Institute, University of ABSTRACT electromagnetic field (RF-­EMF) exposures.5–8 This Edinburgh, Edinburgh, UK New fifth generation (5G) telecommunications systems, commentary sets out the reasons for such concern. now being rolled out globally, have become the subject Correspondence to of a fierce controversy. Some health protection agencies Professor John William Frank; WHAT IS 5G AND WHY IS IT DIFFERENT FROM ​john.​frank@​ed.​ac.​uk and their scientific advisory committees have concluded that there is no conclusive scientific evidence of harm. PAST EMF EXPOSURES? Received 2 December 2019 Several recent reviews by independent scientists, Developed over just the last decade, radio frequency Revised 13 October 2020 however, suggest that there is significant uncertainty (wireless) transmission systems in the 5G category Accepted 16 October 2020 on this question, with rapidly emerging evidence are being rolled out throughout the world. These of potentially harmful biological effects from radio systems will massively increase the volume, speed 4–6 frequency electromagnetic field (RF-­EMF) exposures, at and spatial reach of digital data transfer. The four the levels 5G roll-­out will entail. This essay identifies four successive previous generations (1G, 2G, 3G and relevant sources of scientific uncertainty and concern: 4G) of wireless transmission systems were deployed (1) lack of clarity about precisely what technology is initially for wireless and mobile phones (1980s and included in 5G; (2) a rapidly accumulating body of 1990s), followed by WiFi (2000s), and then smart laboratory studies documenting disruptive in vitro and metres and the Internet of Things (2010s). Each in vivo effects of RF-­EMFs—but one with many gaps successive generation of transmission systems has in it; (3) an almost total lack (as yet) of high-­quality used higher frequencies of electromagnetic waves epidemiological studies of adverse human health to carry ever-­larger volumes of data, faster, in more effects from 5G EMF exposure specifically, but apidlyr ubiquitous locations. 5G is widely acknowledged emerging epidemiological evidence of such effects from to be a step change in this sequence, since it addi- past generations of RF-­EMF exposure; (4) persistent tionally uses much higher frequency (3 to 300 GHz) allegations that some national telecommunications radio waves than in the past. 5G will also make use regulatory authorities do not base their RF-­EMF safety of very new—and thus relatively unevaluated, in policies on the latest science, related to unmanaged terms of safety—supportive technology (including conflicts of interest. The author, an experienced pulsing, beaming, phased arrays and massive input/ epidemiologist, concludes that one cannot dismiss the massive output (MIMO)—see below) to enable this growing health concerns about RF-­EMFs, especially in higher data transmission capacity.4–6 an era when higher population levels of exposure are However—unlike prior generations of wireless occurring widely, due to the spatially dense transmitters transmission systems—5G ultrahigh-­frequency which 5G systems require. Based on the precautionary waves are easily interrupted by vegetation foliage principle, the author echoes the calls of others for (and building walls, often requiring additional a moratorium on the further roll-­out of 5G systems signal boosting within each building). This inherent globally, pending more conclusive research on their fragility of 5G high-­frequency waves means that safety. transmission boosting ‘cell’ antennae are gener- ally required every 100–300 m or less—far more spatially dense than the miles-­apart transmission masts required for older 2G, 3G and 4G technology BACKGROUND using lower frequency waves.4–6 Fifth generation (5G) technology is being widely This dense transmission network is also required promoted by politicians, government officials, in order to achieve the ‘everywhere/anytime’ and private sector interests.1–3 They contend that connectivity promised by 5G developers, and its advent will bring clear economic and lifestyle necessitated by new technology such as driverless benefits, through massive increases in wireless and cars, which must never be out of internet contact, mobile connectivity at home, work, school and for safety reasons. Critics of 5G agree6–8—but its AUTHOR PROOF © Author(s) (or their in the community. Examples of these 5G benefits supporters do not9 10—that the overall popula- employer(s)) 2020. No include driverless vehicles and ‘The Internet of tion levels of exposure to RF-EMFs­ will be greatly commercial re-­use. See rights and permissions. Published Things’—automated and continuous communica- increased by the 5G roll-out.­ One compelling argu- 4 5 by BMJ. tion between the machines in our daily lives. On ment for that view is the ‘inverse square law’ of the other hand, the public health response to this EMF exposure: intensity varies as the inverse of the To cite: Frank JW. J wave of communications innovation has become square of the distance from the emitting source.11 Epidemiol Community Health Epub ahead of print: [please a sense of deep concern, related to widespread With plans afoot internationally to put a 5G booster include Day Month Year]. scientific uncertainties, as well as a lack of use of antenna on ‘every second or third lamp-­post’, it is doi:10.1136/jech-2019- existing evidence, in the current international safety difficult to believe that overall population expo- 213595 guidelines for 5G and related radio frequency sures will not increase substantially. Existing 4G

Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 1 Essay systems can service up to 4000 radio frequency using devices resulting from chronic rather than acute exposures, and effects per square kilometre; 5G systems will connect up to one million not mediated by thermogenesis. devices per square kilometre—greatly increasing the speed of data transfer (by a factor of 10) and the volume of data trans- KEY CONTENTIOUS ISSUES AND SCIENTIFIC UNCERTAINTIES mitted (by a factor of 1000).6 Lack of clarity about precisely what sorts of EMFs will result from 5G roll-out THE CURRENT CONTROVERSY A striking feature of this public controversy is that various International health protection agencies and their scientific commentators—even those with advanced training in telecom- advisory bodies have published several reviews over the last munications physics and engineering—inconsistently refer to decade, of varying scientific quality, of the research evidence quite different specific technologies when they discuss the pros regarding potential adverse biological and health effects of and cons of ‘5G’. American authors tend to state that the 5G RF-­EMFs.5 12–15 These reviews—by Health Protection England,12 system roll outs already underway in that part of the world are 13 using very high-­frequency (24–100 GHz)/short-­wavelength RF the International Agency for Research on Cancer (IARC), 6 14 transmission—so-­called ‘millimetre range’ waves. However, an Expert European Union (EU) Committee and the Inter- 9 national Commission on Non-­Ionising Radiation Protection some UK/EU industry websites state that ‘no new frequencies (ICNIRP)15—have, with one exception, not converged around are required’ (at present) beyond those already in use in existing a strong warning about such effects. IARC is the outlier in this 4G mobile networks, WiFi, smart metres. However, indepen- respect, having determined in 2011 that EMFs are ‘possibly dent authors commenting on current private sector plans in the 13 EU, to extend 5G networks more widely in the future, tell a carcinogenic to humans’. Meanwhile, independent radiation 23 24 and health scientists have published serious concerns about different story. These commentaries imply that the use of the current roll-­out of 5G transmission systems.6–8 16–18 Their millimetre wave frequencies—about which we have very few reasoning is twofold: (1) these systems have an unprecedented conclusive studies of human health effects—is already planned potential to create human and non-­human RF-­EMF exposures and inevitable in the EU, and eventually globally, in order to orders of magnitude more intense (eg, in terms of ‘power flux accommodate anticipated consumer requirements—especially density’) than was the case only a few decades ago (16); (2) there the ‘Internet of Things’ and driverless vehicles. Tellingly, the Guardian (one of the UK’s most respected newspapers) reported is a remarkable dearth of evidence on the safety of 5G-specific­ 25 EMF emissions, but a growing body of research suggestive of last year that UK lamp posts were becoming the subject of harms from other RF-­EMF exposures, which have been studied expensive legal battles, over ‘who can charge what’ for mounting for much longer.6–8 17 18 5G booster cell antennae on them. Cash-­strapped Local Coun- Moreover, a growing number of engineers, scientists, and cils had hoped to profit from such charges to telecom compa- doctors internationally have been calling on governments to raise nies. These companies have taken local governments to court their safety standards for RF-­EMFs, commission more and better to block those charges. The USA provides a cautionary tale in research, and hold off on further increases in public exposure, this respect: nearly 25 years ago national legislation there took pending clearer evidence of safety.18–21 Some politicians have local authorities completely out of the telecommunications regu- listened: France, Israel, Cyprus and Russia have banned WiFi latory system, leaving local 5G installation and similar decisions entirely in the hands of central authorities—that is, the Federal in preschool and restricted its use in primary schools. Belgium 6 has banned the sale of mobile phones to children under seven. Communications Commission. In response to such concerns, several jurisdictions have recently Equally inconsistently described in writings about 5G is the blocked the installation of 5G antennae systems in their commu- complex set of special signal modulations, pulses, polarisation, nities: Brussels, Florence, Rome, as well as Glastonbury, Frome phased arrays and novel equipment designs—for example, and Totnes in the UK; and widespread anti-­5G campaigns are ‘massive MIMO antennas’—which represent the cutting edge now emerging in Australia, North America and elsewhere.21 technologies that accompany 5G system installation—many of Some countries have lowered allowable RF-EMF­ exposure them proprietary. As some commentators on potential health levels far below those permitted in the UK and USA. Powerwatch, effects from such exposures have pointed out, it is highly likely a non-­profit, independent organisation in the UK, has published that each of these many forms of transmission causes somewhat different biological effects—making sound, comprehensive and comparisons of international recommendations on permitted 5–7 26 27 22 up-­to-­date research on those effects virtually impossible. maximum exposure levels to EMFs. Those comparisons show In short, ‘5G systems’ is not a consistently defined term. This that the highest permitted RF-­EMF exposures which are used confusion has not helped clarify the health and safety issues globally, as the basis for national safety guidelines, are those surrounding 5G roll outs internationally. used in the USA, the UK and most of the EU. These exposure limits are derived from the recommendations to WHO in 1998 (recently updated, but essentially not changed, in March 2020) An emerging preponderance of laboratory studies indicating byAUTHOR PROOF the ICNIRP.15 These international comparisons show that RF-EMFs’ disruptive biological effects: with many knowledge the safety limit for RF-­EMF exposure set by ICNIRP is 10-fold­ gaps higher than that set by the next most liberal guidelines, found The lack of a consistent definition of ‘5G’ matters enormously. in Israel and India, and 100-­or-­more-­fold higher than the limits This is clearly demonstrated in a sophisticated recent review of set by other guidelines, spanning 14 EU jurisdictions as well as the laboratory science evidence of RF-­EMF effects in diverse China. As discussed in detail below, one reason that ICNIRP’s biological systems.26 That review shows that the existing scien- permitted exposures are so high is that they are based solely on tific literature on the biological effects of more recently devel- the acute thermogenic (heat-producing)­ effects of RF-­EMF in oped technology is quite limited, in that there is hardly any animal tissues; this is unlike more conservative jurisdictions’ study replication—the hallmark of reliable research. We often guidelines, which are based on a wider variety of biological and have only one extant study of any given biological effect of a health effects documented in recent decades, including effects specified combination of radio frequencies, modulation and

2 Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 Essay pulse patterns. The literature that does exist identifies remark- the highest-­quality epidemiological study designs for establishing ably heterogeneous biological effects, across hundreds of such evidence of causation: prospective cohort studies. Such studies specific RF-­EMF exposure patterns. Furthermore, a compre- typically require decades of follow-up­ to detect delayed health hensive Canadian review of the same evidence states that some effects, such as most cancers. of the new RF-­EMF technologies—such as innovations in radio Miller et al find compelling evidence of carcinogenesis, espe- frequency ‘pulsing,’ ‘polarisation’ and ‘modulation’—are so new cially in the brain and acoustic nerve, as well as the breast, from that biological scientists have not been able to keep up—that strong RF-­EMF exposures to previous generations of mobile is, no studies yet exist of these new technologies’ biological phone transmissions. Perhaps the most convincing evidence effects.27 they cite comes from the oldest and most-often-­ ­maligned These recent reviews of laboratory (ie, non-­epidemiological) study design—case reports. While admittedly old-­fashioned, studies of the biological effects of RF-EMFs­ do identify diverse, case reports can, when they involve pathognomonic effects (ie, multibody system effects, operating by a range of physicochemical pathological features absolutely specific to a particular expo- pathways which are not mediated by thermogenesis.6 8 26 27 The sure) provide useful evidence of exposure/outcome specifici- reviewers document a growing body of evidence that RF-­EMF ty—a valuable but often unobtainable epidemiological criterion exposures produce effects spanning reproductive/teratogenic, for inferring causation, according to the standard epidemi- oncological, neuropsychiatric, skin, eye and immunological ological criteria first enunciated by Sir Austin Bradford Hill body systems. In addition, there are many fundamental effects over 50 years ago.34 35 Strikingly localised breast tumours, of at the subcellular level, in terms of oxidation, DNA alteration, unusual morphology, have been diagnosed in several women gene expression and bacterial antibiotic resistance. Particularly with particularly strong exposures to previous generations of striking is a 2018 study from Israel documenting the capacity mobile phones: they habitually placed their phones in their bras, of the sweat ducts in human skin to act as ‘helical antennae’ on the same side of the body where the tumour has developed. receptive to 5G frequencies of RF-EMF.­ When sweat ducts are Miller et al call for an urgent update of the last (2011) review exposed to these RF-EMFs,­ there are remote systemic effects, of EMFs and cancer by the International Agency for Research through the skin’s established capacity to secrete and send on Cancer.13 They predict that such an update would now rate hormones and other signals to the entire body.28 This report RF-­EMFs as, at minimum, ‘probable’ (not merely ‘possible’ as in alters one’s sense of the potential risks from such high frequency 2011) carcinogens, based on current evidence. waves, since they have long been thought to be ‘inherently less dangerous’, because they are largely absorbed in the top few millimetres of exposed tissue (thus limiting any adverse effects, Persistent allegations of unscientific bases for existing health in theory, to the skin or eye). protection guidelines on RF-EMFs and unmanaged conflicts of Finally, it is instructive to look at the two widely cited NIH interest on expert advisory panels toxicological studies of specific EMFs’ effects on thousands of A senior epidemiologist from Sweden, Hardell, has repeatedly rodents,29 30 conducted by experienced and highly respected published in peer-­reviewed journals detailed allegations regarding laboratory scientists at a world-­leading institution. Since their the main WHO scientific advisory body on EMF health effects publication in 2018, epidemiologists and other scientists have and safety—the previously mentioned ICNIRP. Hardell contends pointed out several methodological weaknesses in the conduct that ICNIRP’s membership includes over-­representation of and analysis of these studies that make their unequivocal inter- vested interests, especially the giant multinational telecommu- pretation almost impossible, particularly in terms of their rele- nications firms who are heavily invested in the roll out of 5G vance to human health: excessive statistical inference testing of systems internationally.36 37 ICNIRP has long been influential in multiple (over 1000) hypotheses, without appropriate adjust- EMF regulation: its scientific recommendations to WHO were ment of p values considered ‘statistically significant’; reporting first issued in 1998, updated in 2009, and revised and updated of results ‘often ignoring statistical tests’; failure to explain major again in March 2020.15 Hardell points out that ICNIRP’s pro-­ internal inconsistencies of findings across EMF doses, tumour industry bias may explain its continued reliance only on studies of types and rodent sexes; use of experimental EMF exposures far the thermogenic (heat-­producing) effect of RF-­EMFs in biolog- in excess of any known human ones; uncontrolled confounding ical tissues: these studies would be expected to paint an overly by direct thermogenesis effects—the list goes on.31 32 benign picture of RF-EMF­ safety. This narrow ICNIRP focus In short, laboratory studies of EMF exposure are fraught with flies in the face of published reviews by independent scientists (6, both internal and external validity issues, and cannot replace 8, 13, 26, 27) citing compelling research evidence, accumulating high-­quality human epidemiological studies—though, as we will steadily over the last few decades, of non-thermogenic­ adverse now discuss, these are also hard to come by. effects of RF-­EMFs, affecting diverse human and animal subcel- lular function, tissues and organ systems (see above). In detailed, almost lawyer-­like publications,36 37 Hardell fastidiously docu- Lack of conclusive human epidemiological studies of ments the ICNIRP’s 20 years of dogged defiance, in the face of 5G-specific health effects (but increasing epidemiological widespread criticism by other scientists, that the scientific base AUTHOR PROOF evidence of serious health effects from previous generations for their recommendations remains dated and narrow, rendering of RF-EMF exposures) their guidelines on ‘safe’ RF-­EMF exposure unsafe. Canada’s most senior cancer epidemiologist, Miller et al have last The most damning evidence adduced by Hardell is a table of year summarised the human epidemiological evidence33 linking the cross-­appointments held by six members of the WHO Mono- human breast and brain tumours, male reproductive outcomes graph Group, across five major international advisory panels and child neurodevelopmental conditions to RF-­EMF exposures on the health effects of non-­ionising radiation [36 – page 408]. resulting from the use of past generations of transmission systems. Hardell also describes these scientists’ strong personal links to Critically, this evidence is not about exposure to the high radio the telecommunications industry, a situation likely arising from frequency/short wavelength 5G systems. These systems are too the fact that the ICNIRP itself is a ‘private organisation (non-­ newly deployed to have been extensively studied, especially by governmental organisation; NGO) based in Germany. New

Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 3 Essay expert members can only be elected by members of ICNIRP.’ when pandemic control actions are paramount.42 This writer Hardell contrasts the ICNIRP’s reports to the publications of the completely supports that view of the broader scientific commu- ‘BioInitiative 2012’38 group, of nearly 30 international experts nity: the theory that 5G and related EMFs have contributed to in this field, whose operations are not only wholly independent the pandemic is baseless. of any such ‘vested interests,’ but also entirely transparent. The It follows that, for the current 5G roll-­out, there is a sound current version (March 2020) of the BioInitiative 2012 website38 basis for invoking ‘the precautionary principle’.43 This is the provides detailed descriptions of 988 peer-­reviewed scientific environmental and occupation health principle by which signifi- studies of adverse potential health and biological effects of cant doubt about the safety of a new and potentially widespread EMFs arising from RF and similar non-­ionising sources. The human exposure should be a reason to call a moratorium on vast majority (84.6%) of these 988 studies document disruptive that exposure, pending adequate scientific investigation of its biological effects from such EMFs, almost all of them oper- suspected adverse health effects. In short, one should ‘err on the ating via non-­thermogenic pathways. (This writer would have side of caution’. In the case of 5G transmission systems, there is preferred to see more ‘critical appraisal’ of the quality of the no compelling public health or safety rationale for their rapid studies than the BioInitiative 2012 website provides. However, deployment. The main gains being promised are either economic the major effort entailed in assembling this massive body of (for some parties only, not necessarily with widely distributed scientific evidence, and updating it regularly since 2012, is financial benefits across the population) or related to increased impressive). consumer convenience. Until we know more about what we are Finally, Carpenter has recently published a well-­researched getting into, from a health and ecological point of view, those analysis of how source of funding correlates with study find- putative gains need to wait. ings, across many peer-­reviewed publications over the last few decades, of the relationship between various kinds of EMF expo- Contributors JWF is the sole author of this essay, responsible for all aspects of its sure and several cancers.39 He shows convincingly that studies conceptualisation, background research and writing. funded by private sector entities, with strong vested interests in Funding The authors have not declared a specific grant for this research from any maintaining their current use of the sources of EMFs under study, funding agency in the public, commercial or not-­for-­profit sectors. tend to find no association—whereas studies funded by public Competing interests None declared. sector or independent sources find the opposite. As Carpenter Patient consent for publication Not required. points out, this suggests that many systematic reviews and meta-­ Provenance and peer review Not commissioned; externally peer reviewed. analyses in this field, having failed to correct for this ‘source of Data availability statement Data sharing not applicable as no datasets funding bias,’ likely underestimated the evidence for causation. generated and/or analysed for this study. No data were collected, or repurposed/ used in the writing of this essay.

CONCLUSIONS AND RECOMMENDATION ORCID iD In assessing causal evidence in environmental epidemiology, John William Frank http://​orcid.​org/​0000-​0003-​3912-​4214 Bradford Hill himself pointed out that ‘the whole picture matters;’ he argued against prioritising any subset of his famous REFERENCES nine criteria for causation. One’s overall assessment of the likeli- 1 Scottish Government. 5G: strategy for Scotland. Available: https://www.​gov.​scot/​ hood that an exposure causes a health condition should take into publications/​forging-​digital-​future-​5g-​strategy-​scotland/ [Accessed 8 Oct 2020]. account a wide variety of evidence, including ‘biological plausi- 2 Negreiro M. Towards a European Gigabit Society: Connectivity Targets and 5G. bility’.34 35 After reviewing the evidence cited above, the writer, European Parliament Research Service (EPRS)/ Brussels, European Parliament, 2017. Available: https://www.​europarl.​europa.​eu/​RegData/​etudes/​BRIE/​2017/​603979/​ an experienced physician-epidemiologist,­ is convinced that EPRS_​BRI(​2017)​603979_​EN.​pdf [Accessed 8 Oct 2020]. RF-­EMFs may well have serious human health effects. While 3 Directorate-­General for Internal Policies, European Parliament. 5G deployment: state there is also increasing scientific evidence for RF-­EMF effects of play in Europe, USA and Asia. Brussels: European Parliament, 2019. https://www.​ of ecological concern in other species,6–8 16–18 23 both plant and europarl.​europa.​eu/​RegData/​etudes/​IDAN/​2019/​631060/​IPOL_​IDA(​2019)​631060_​ animal, these have not been reviewed here, for reasons of space EN.​pdf 4 Nordrum, Amy; Clark, Kristen (January 27, 2017). Everything you need to know about and the author’s disciplinary limitations. In addition, there is 5G. IEEE Spectrum Magazine. Institute of Electrical and Electronic Engineers, 2019. convincing evidence, cited above, that several nations’ regula- Available: https://www.​fitce.​gr/​everything-​need-​know-​5g/ [Accessed 8 Oct 2020]. tory apparatus, for telecommunications innovations such as the 5 Karaboytscheva M. Effects of 5G Wireless Communication on Human Health. 5G roll-­out, is not fit for purpose. Indeed, significant elements in European Parliament Research Service (EPRS)/ Brussels, European Parliament, 2020March. Available: https://​europarl.​europa.​eu/​RegData/​etudes/​BRIE/​2020/​ that apparatus appear to have been captured by vested interests. 646172/​EPRS_​BRI(​2020)​646172_​EN.​pdf [Accessed Oct. 8, 2020]. Every society’s public health—and especially the health of those 6 Russell CL. 5 G wireless telecommunications expansion: public health and most likely to be susceptible to the hazard in question (in the case environmental implications. Environ Res 2018;165:484–95. of EMFs, children and pregnant women)—needs to be protected 7 Moskowitz JM. We have no reason to believe 5G is safe. Scientific American blogs, by evidence-­based regulations, free from significant bias. 2019. Available: https://​blogs.​scientificamerican.​com/​observations/​we-​have-​no-​ reason-​to-​believe-​5g-​is-​safe/ [Accessed 8 Oct 2020]. AUTHOR PROOF Finally, this commentary would be remiss if it did not mention 8 Di Ciaula A. Towards 5G communication systems: are there health implications? Int J a widely circulating conspiracy theory, suggesting that 5G and Hyg Environ Health 2018;221:367–75. related EMF exposures somehow contributed to the creation or 9 Vodaphone UK. Is 5G safe? Available: https://​newscentre.​vodafone.​co.​uk/​5g/​is-​5g-​ spread of the current COVID-19 pandemic. There are knowl- safe/ [Accessed 24 Mar 2020]. 10 Foster KR. 5G Is Coming: How Worried Should We Be about the Health Risks? So far, edgeable commentators’ reports on the web debunking this at least, there’s little evidence of danger. Scientific American blogs, 2019. Available: theory, and no respectable scientist or publication has backed https://​blogs.​scientificamerican.​com/​observations/​5g-​is-​coming-​how-​worried-​should-​ it.40 41 Indeed, combatting it is widely viewed by the scien- we-​be-​about-​the-​health-​risks/?​print=​true [Accessed 24 Mar 2020]. tific community as critical to dealing with the pandemic, as 11 Powerwatch UK. Radiofrequency EMFs and health risks. Available: https://www.​ powerwatch.​org.​uk/​library/​downloads/​rf-​emfs-​1-​intro-​2018-​11.​pdf [Accessed Oct. 8, conspiracy theorists holding this view have already carried out 2020]. violent attacks on mobile phone transmission facilities and other 12 AGNIR. Health effects from radiofrequency electromagnetic fields. Report from the symbolic targets, distracting the public and authorities at a time Independent Advisory Group on Non-­Ionising Radiation. In: Documents of the health

4 Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 Essay

protection agency R, chemical and environmental hazards. RCE 20. London: Health Frequency Radiation at a Frequency (900 MHz) and Modulations (GSM And CDMA) Protection Agency UK, 2012: 1–348. Used by Cell Phones [NTP 595]. Bethesda: National Institutes of Health/ Public Health 13 International Agency for Research on Cancer. Non-­ionizing radiation, part 2: Service, U.S. Department of Health and Human Services, 2018. radiofrequency electromagnetic fields. IARC Monographs on the evaluation of 30 National Toxicological Programme. NTP Technical Report on the Toxicology and carcinogenetic risks to humans, volume 102. Lyon, France: IARC, 2013: 1–460. Carcinogenesis Studies in B6C3F1/N Mice Exposed to Whole-­Body Radio Frequency 14 SCENIHR [Scientific Committee on Emerging and Newly Identified Health Risks]. Radiation at a Frequency (1,900 MHz) and Modulations (GSM And CDMA) Used by Potential Health Risks of Exposure to Electromagnetic Fields [EMF]. Luxembourg: Cell Phones [NTP 596]. Bethesda: National Institutes of Health/ Public Health Service, European Commission, 2015: 1–288. https://​ec.​europa.​eu/​health/​sites/​health/​files/​ U.S. Department of Health and Human Services, 2018. scientific_​committees/​emerging/​docs/​scenihr_​o_​041.​pdf 31 International Commission on Non-­Ionizing Radiation Protection (ICNIRP)1. ICNIRP 15 International Commission on Non-­Ionizing Radiation Protection (ICNIRP). ICNIRP rf note: critical evaluation of two radiofrequency electromagnetic field animal EMF guidelines 2020. Oberschleissheim, Germany: ICNIRP, 2020: 1–44. https://www.​ carcinogenicity studies published in 2018. Health Phys 2020;118:525–32. icnirp.​org/​en/​activities/​news/​news-​article/​rf-​guidelines-​2020-​published.​html 32 Elwood M, Wood AW. Animal studies of exposures to radiofrequency fields. N Z Med J 16 Bandara P, Carpenter DO. Planetary electromagnetic pollution: it is time to assess its 2019;132:98–100. impact. Lancet Planet Health 2018;2:e512–4. 33 Miller AB, Sears ME, Morgan LL, et al. Risks to health and well-­being from radio-­ 17 Pall ML. 5G risks 8 types of harm. Available: https://www.​radiationresearch.​org/​ frequency radiation emitted by cell phones and other wireless devices. Front Public articles/​5g-​risks-​8-​types-​of-​harm-​martin-​pall-​2018/ [Accessed 9 Oct 2020]. Health 2019;7:1–10. 18 International EMF scientists appeal statement, 2020. Available: https://www.​ 34 Hill AB, Bradford Hill A. The environment and disease: association or causation? Proc emfscientist.​org/ [Accessed 8 Oct 2020]. R Soc Med 1965;58:295–300. 19 Carpenter DO. Open letter about the risks of the intensively pulsed EMFs from “smart 35 Carlberg M, Hardell L. Evaluation of mobile phone and Cordless phone use and meters”, 2012. Available: https://www.​saferemr.​com/​2015/​02/​health-​experts-​caution-​ glioma risk using the Bradford Hill viewpoints from 1965 on association or causation. about-​smart.​html [Accessed 8 Oct 2020]. Biomed Res Int 2017;2017:1–17. 20 International appeal: stop 5G on earth and in space. Available: https://www.​ 36 Hardell L. World Health Organization, radiofrequency radiation and health - a hard 5gspaceappeal.​org/ [Accessed 8 Oct 2020]. nut to crack (Review). Int J Oncol 2017;51:405–13. 21 Physicians for safe technology. Available: https://​mdsafetech.​org/​2019/​04/​28/​stop-​5g-​ 37 Hardell L, Nyberg R. Appeals that matter or not on a moratorium on the may-​15-​2019-​day-​of-​action/ [Accessed 8 Oct 2020]. deployment of the fifth generation, 5G, for microwave radiation. Mol Clin Oncol 22 Powerwatch UK. International guidance levels. Available: https://www.​powerwatch.​ 2020;12:247–57. org.​uk/​science/​intguidance.​asp [Accessed 8 Oct 2020]. 23 Physicians’ Health Initiative for Radiation and Environment (PHIRE). Safety limits 38 BioInitiative 2012 (updated 2017 and 2019). A rationale for biologically based and political conflicts of interest. Available: http://​phiremedical.​org/​safety-​limits-​and-​ exposure standards for low-­intensity electromagnetic radiation. Available: https://​ political-​conflicts-​of-​interest/ [Accessed 8 Oct 2020]. bioinitiative.​org/​updated-​research-​summaries/ [Accessed 24 Mar 2020]. 24 Zieszczynski D. Response to blog “5G Misinformation campaign by the Mobile and 39 Carpenter DO. Extremely low frequency electromagnetic fields and cancer: how source Wireless Forum”,. Available: https://​betw​eenr​ocka​ndha​rdplace.​wordpress.​com/​2019/​ of funding affects results. Environ Res 2019;178:108688. 09/​12/​5g-​misinformation-​campaign-​by-​the-​mobile-​wireless-​forum-​mwf/ [Accessed 8 40 Lewis K. Full fact. 2020 MAR 31. 5G is not accelerating the spread of the new Oct 2020]. coronavirus. available at. Available: https://​fullfact.​org/​health/​5G-​not-​accelerating-​ 25 Weaver M. Revealed: 5G rollout is being stalled by rows over lampposts. The coronavirus/ [Accessed 12 Oct 2020]. Guardian, 2019. Available: https://www.​theguardian.​com/​technology/​2019/​may/​19/​ 41 Shanapinda S. The Conversation. 2020 Apr 07. No, 5G radiation doesn’t cause or revealed-​5g-​rollout-​is-​being-​stalled-​by-​rows-​over-​lampposts [Accessed 12 Oct 2020]. spread the coronavirus. Saying it does is destructive. Available: https://​tinyurl.​com/​ 26 Simkó M, Mattsson M-­O. 5G wireless communication and health effects-­A pragmatic uppng7w https://​theconversation.​com/​no-​5g-​radiation-​doesnt-​cause-​or-​spread-​the-​ review based on available studies regarding 6 to 100 GHz. Int J Environ Res Public coronavirus-​saying-​it-​does-​is-​destructive-​135695 [Accessed 12 Oct 2020]. Health 2019;16:3406–28. 42 Waterson J, Hern A. The guardian. 2020 Apr 06. at least 20 UK phone masts 27 Kostoff RN, Heroux P, Aschner M, et al. Adverse health effects of 5G mobile vandalised over false 5G coronavirus claims. Available: https://www.​theguardian.​ networking technology under real-­life conditions. Toxicol Lett 2020;323:35–40. com/​technology/​2020/​apr/​06/​at-​least-​20-​uk-​phone-​masts-​vandalised-​over-​false-​5g-​ 28 Betzalel N, Ben Ishai P, Feldman Y. The human skin as a sub-­THz receiver - Does 5G coronavirus-​claims [Accessed 12 Oct 2020]. pose a danger to it or not? Environ Res 2018;163:208–16. 43 Health and Safety Executive. Reducing Risks, Protecting People: HSE’s Decision-­ 29 National Toxicological Programme. NTP Technical Report on the Toxicology and Making Process. London: Health and Safety Executive, 2001: 1–88. https://www.​hse.​ Carcinogenesis Studies in Sprague Dawley Rats Exposed to Whole-­Body Radio gov.​uk/​risk/​theory/​r2p2.​pdf AUTHOR PROOF

Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 5 Gail Dent

From: [email protected] Sent: 29 January 2021 15:08 To: Planning; Andrew Bishop Subject: Planning Application R/85/51A/GDO Attachments: Electromagnetic fields 5G and health - John William Frank.pdf

Planning Application R/85/51A/GDO

We are opposed to the current proposal for a mast in West Scrafton. Not, in principle about masts in general, but, specifically in this case, because of the proposal to operate at 5G at some point. We endorse Prof. David Hill's objection and I attach an article from the British Medical Journal, which identifies important factors arising from 5G. Both the Hill objection and the BMJ article are representative of an increasing range of information about the consequences of 5G operation and reinforce the need for caution before authorising its deployment within the National Park, particularly in the context of health and environmental matters.. Our view is that, whilst there is this level of expert concern, there is no merit in our becoming part of a 5G experiment. A mast providing either a 3 or 4G service would cover either the majority or even all of the concerns about mobile telephony availability in the proposed area of coverage. In respect of superfast broadband, the NYNet initiative has cabling, either already in place or in prospect. This is providing a service which is free of the concerns being raised about a 5G operation from the proposed mast and there is no practical merit.in its duplication, particularly in the context of the limited duration of the MANY operation. In addition, we understand that EE has received consent (21 January 2021) for a mast at Gildersbeck Farm (Melmerby) for provision of a 4G service. Given its location. there is the possibility that it could serve at least part of the coverage of the proposed West Scrafton mast. (R/85/51A/GDO).

Finally, given the County Council's involvement in supporting this application, we have grave concerns about the probity of County Council representatives on the Planning Committee being involved in any aspect of the Committee's consideration of this application.

John and Carole Brown, Roova House, DL8 4RU.

1 Essay Electromagnetic fields, 5G and health: what about the precautionary principle? John William Frank ‍ ‍

Usher Institute, University of ABSTRACT electromagnetic field (RF-­EMF) exposures.5–8 This Edinburgh, Edinburgh, UK New fifth generation (5G) telecommunications systems, commentary sets out the reasons for such concern. now being rolled out globally, have become the subject Correspondence to of a fierce controversy. Some health protection agencies Professor John William Frank; WHAT IS 5G AND WHY IS IT DIFFERENT FROM ​john.​frank@​ed.​ac.​uk and their scientific advisory committees have concluded that there is no conclusive scientific evidence of harm. PAST EMF EXPOSURES? Received 2 December 2019 Several recent reviews by independent scientists, Developed over just the last decade, radio frequency Revised 13 October 2020 however, suggest that there is significant uncertainty (wireless) transmission systems in the 5G category Accepted 16 October 2020 on this question, with rapidly emerging evidence are being rolled out throughout the world. These of potentially harmful biological effects from radio systems will massively increase the volume, speed 4–6 frequency electromagnetic field (RF-­EMF) exposures, at and spatial reach of digital data transfer. The four the levels 5G roll-­out will entail. This essay identifies four successive previous generations (1G, 2G, 3G and relevant sources of scientific uncertainty and concern: 4G) of wireless transmission systems were deployed (1) lack of clarity about precisely what technology is initially for wireless and mobile phones (1980s and included in 5G; (2) a rapidly accumulating body of 1990s), followed by WiFi (2000s), and then smart laboratory studies documenting disruptive in vitro and metres and the Internet of Things (2010s). Each in vivo effects of RF-­EMFs—but one with many gaps successive generation of transmission systems has in it; (3) an almost total lack (as yet) of high-­quality used higher frequencies of electromagnetic waves epidemiological studies of adverse human health to carry ever-­larger volumes of data, faster, in more effects from 5G EMF exposure specifically, but apidlyr ubiquitous locations. 5G is widely acknowledged emerging epidemiological evidence of such effects from to be a step change in this sequence, since it addi- past generations of RF-­EMF exposure; (4) persistent tionally uses much higher frequency (3 to 300 GHz) allegations that some national telecommunications radio waves than in the past. 5G will also make use regulatory authorities do not base their RF-­EMF safety of very new—and thus relatively unevaluated, in policies on the latest science, related to unmanaged terms of safety—supportive technology (including conflicts of interest. The author, an experienced pulsing, beaming, phased arrays and massive input/ epidemiologist, concludes that one cannot dismiss the massive output (MIMO)—see below) to enable this growing health concerns about RF-­EMFs, especially in higher data transmission capacity.4–6 an era when higher population levels of exposure are However—unlike prior generations of wireless occurring widely, due to the spatially dense transmitters transmission systems—5G ultrahigh-­frequency which 5G systems require. Based on the precautionary waves are easily interrupted by vegetation foliage principle, the author echoes the calls of others for (and building walls, often requiring additional a moratorium on the further roll-­out of 5G systems signal boosting within each building). This inherent globally, pending more conclusive research on their fragility of 5G high-­frequency waves means that safety. transmission boosting ‘cell’ antennae are gener- ally required every 100–300 m or less—far more spatially dense than the miles-­apart transmission masts required for older 2G, 3G and 4G technology BACKGROUND using lower frequency waves.4–6 Fifth generation (5G) technology is being widely This dense transmission network is also required promoted by politicians, government officials, in order to achieve the ‘everywhere/anytime’ and private sector interests.1–3 They contend that connectivity promised by 5G developers, and its advent will bring clear economic and lifestyle necessitated by new technology such as driverless benefits, through massive increases in wireless and cars, which must never be out of internet contact, mobile connectivity at home, work, school and for safety reasons. Critics of 5G agree6–8—but its AUTHOR PROOF © Author(s) (or their in the community. Examples of these 5G benefits supporters do not9 10—that the overall popula- employer(s)) 2020. No include driverless vehicles and ‘The Internet of tion levels of exposure to RF-EMFs­ will be greatly commercial re-­use. See rights and permissions. Published Things’—automated and continuous communica- increased by the 5G roll-out.­ One compelling argu- 4 5 by BMJ. tion between the machines in our daily lives. On ment for that view is the ‘inverse square law’ of the other hand, the public health response to this EMF exposure: intensity varies as the inverse of the To cite: Frank JW. J wave of communications innovation has become square of the distance from the emitting source.11 Epidemiol Community Health Epub ahead of print: [please a sense of deep concern, related to widespread With plans afoot internationally to put a 5G booster include Day Month Year]. scientific uncertainties, as well as a lack of use of antenna on ‘every second or third lamp-­post’, it is doi:10.1136/jech-2019- existing evidence, in the current international safety difficult to believe that overall population expo- 213595 guidelines for 5G and related radio frequency sures will not increase substantially. Existing 4G

Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 1 Essay systems can service up to 4000 radio frequency using devices resulting from chronic rather than acute exposures, and effects per square kilometre; 5G systems will connect up to one million not mediated by thermogenesis. devices per square kilometre—greatly increasing the speed of data transfer (by a factor of 10) and the volume of data trans- KEY CONTENTIOUS ISSUES AND SCIENTIFIC UNCERTAINTIES mitted (by a factor of 1000).6 Lack of clarity about precisely what sorts of EMFs will result from 5G roll-out THE CURRENT CONTROVERSY A striking feature of this public controversy is that various International health protection agencies and their scientific commentators—even those with advanced training in telecom- advisory bodies have published several reviews over the last munications physics and engineering—inconsistently refer to decade, of varying scientific quality, of the research evidence quite different specific technologies when they discuss the pros regarding potential adverse biological and health effects of and cons of ‘5G’. American authors tend to state that the 5G RF-­EMFs.5 12–15 These reviews—by Health Protection England,12 system roll outs already underway in that part of the world are 13 using very high-­frequency (24–100 GHz)/short-­wavelength RF the International Agency for Research on Cancer (IARC), 6 14 transmission—so-­called ‘millimetre range’ waves. However, an Expert European Union (EU) Committee and the Inter- 9 national Commission on Non-­Ionising Radiation Protection some UK/EU industry websites state that ‘no new frequencies (ICNIRP)15—have, with one exception, not converged around are required’ (at present) beyond those already in use in existing a strong warning about such effects. IARC is the outlier in this 4G mobile networks, WiFi, smart metres. However, indepen- respect, having determined in 2011 that EMFs are ‘possibly dent authors commenting on current private sector plans in the 13 EU, to extend 5G networks more widely in the future, tell a carcinogenic to humans’. Meanwhile, independent radiation 23 24 and health scientists have published serious concerns about different story. These commentaries imply that the use of the current roll-­out of 5G transmission systems.6–8 16–18 Their millimetre wave frequencies—about which we have very few reasoning is twofold: (1) these systems have an unprecedented conclusive studies of human health effects—is already planned potential to create human and non-­human RF-­EMF exposures and inevitable in the EU, and eventually globally, in order to orders of magnitude more intense (eg, in terms of ‘power flux accommodate anticipated consumer requirements—especially density’) than was the case only a few decades ago (16); (2) there the ‘Internet of Things’ and driverless vehicles. Tellingly, the Guardian (one of the UK’s most respected newspapers) reported is a remarkable dearth of evidence on the safety of 5G-specific­ 25 EMF emissions, but a growing body of research suggestive of last year that UK lamp posts were becoming the subject of harms from other RF-­EMF exposures, which have been studied expensive legal battles, over ‘who can charge what’ for mounting for much longer.6–8 17 18 5G booster cell antennae on them. Cash-­strapped Local Coun- Moreover, a growing number of engineers, scientists, and cils had hoped to profit from such charges to telecom compa- doctors internationally have been calling on governments to raise nies. These companies have taken local governments to court their safety standards for RF-­EMFs, commission more and better to block those charges. The USA provides a cautionary tale in research, and hold off on further increases in public exposure, this respect: nearly 25 years ago national legislation there took pending clearer evidence of safety.18–21 Some politicians have local authorities completely out of the telecommunications regu- listened: France, Israel, Cyprus and Russia have banned WiFi latory system, leaving local 5G installation and similar decisions entirely in the hands of central authorities—that is, the Federal in preschool and restricted its use in primary schools. Belgium 6 has banned the sale of mobile phones to children under seven. Communications Commission. In response to such concerns, several jurisdictions have recently Equally inconsistently described in writings about 5G is the blocked the installation of 5G antennae systems in their commu- complex set of special signal modulations, pulses, polarisation, nities: Brussels, Florence, Rome, as well as Glastonbury, Frome phased arrays and novel equipment designs—for example, and Totnes in the UK; and widespread anti-­5G campaigns are ‘massive MIMO antennas’—which represent the cutting edge now emerging in Australia, North America and elsewhere.21 technologies that accompany 5G system installation—many of Some countries have lowered allowable RF-EMF­ exposure them proprietary. As some commentators on potential health levels far below those permitted in the UK and USA. Powerwatch, effects from such exposures have pointed out, it is highly likely a non-­profit, independent organisation in the UK, has published that each of these many forms of transmission causes somewhat different biological effects—making sound, comprehensive and comparisons of international recommendations on permitted 5–7 26 27 22 up-­to-­date research on those effects virtually impossible. maximum exposure levels to EMFs. Those comparisons show In short, ‘5G systems’ is not a consistently defined term. This that the highest permitted RF-­EMF exposures which are used confusion has not helped clarify the health and safety issues globally, as the basis for national safety guidelines, are those surrounding 5G roll outs internationally. used in the USA, the UK and most of the EU. These exposure limits are derived from the recommendations to WHO in 1998 (recently updated, but essentially not changed, in March 2020) An emerging preponderance of laboratory studies indicating byAUTHOR PROOF the ICNIRP.15 These international comparisons show that RF-EMFs’ disruptive biological effects: with many knowledge the safety limit for RF-­EMF exposure set by ICNIRP is 10-fold­ gaps higher than that set by the next most liberal guidelines, found The lack of a consistent definition of ‘5G’ matters enormously. in Israel and India, and 100-­or-­more-­fold higher than the limits This is clearly demonstrated in a sophisticated recent review of set by other guidelines, spanning 14 EU jurisdictions as well as the laboratory science evidence of RF-­EMF effects in diverse China. As discussed in detail below, one reason that ICNIRP’s biological systems.26 That review shows that the existing scien- permitted exposures are so high is that they are based solely on tific literature on the biological effects of more recently devel- the acute thermogenic (heat-producing)­ effects of RF-­EMF in oped technology is quite limited, in that there is hardly any animal tissues; this is unlike more conservative jurisdictions’ study replication—the hallmark of reliable research. We often guidelines, which are based on a wider variety of biological and have only one extant study of any given biological effect of a health effects documented in recent decades, including effects specified combination of radio frequencies, modulation and

2 Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 Essay pulse patterns. The literature that does exist identifies remark- the highest-­quality epidemiological study designs for establishing ably heterogeneous biological effects, across hundreds of such evidence of causation: prospective cohort studies. Such studies specific RF-­EMF exposure patterns. Furthermore, a compre- typically require decades of follow-up­ to detect delayed health hensive Canadian review of the same evidence states that some effects, such as most cancers. of the new RF-­EMF technologies—such as innovations in radio Miller et al find compelling evidence of carcinogenesis, espe- frequency ‘pulsing,’ ‘polarisation’ and ‘modulation’—are so new cially in the brain and acoustic nerve, as well as the breast, from that biological scientists have not been able to keep up—that strong RF-­EMF exposures to previous generations of mobile is, no studies yet exist of these new technologies’ biological phone transmissions. Perhaps the most convincing evidence effects.27 they cite comes from the oldest and most-often-­ ­maligned These recent reviews of laboratory (ie, non-­epidemiological) study design—case reports. While admittedly old-­fashioned, studies of the biological effects of RF-EMFs­ do identify diverse, case reports can, when they involve pathognomonic effects (ie, multibody system effects, operating by a range of physicochemical pathological features absolutely specific to a particular expo- pathways which are not mediated by thermogenesis.6 8 26 27 The sure) provide useful evidence of exposure/outcome specifici- reviewers document a growing body of evidence that RF-­EMF ty—a valuable but often unobtainable epidemiological criterion exposures produce effects spanning reproductive/teratogenic, for inferring causation, according to the standard epidemi- oncological, neuropsychiatric, skin, eye and immunological ological criteria first enunciated by Sir Austin Bradford Hill body systems. In addition, there are many fundamental effects over 50 years ago.34 35 Strikingly localised breast tumours, of at the subcellular level, in terms of oxidation, DNA alteration, unusual morphology, have been diagnosed in several women gene expression and bacterial antibiotic resistance. Particularly with particularly strong exposures to previous generations of striking is a 2018 study from Israel documenting the capacity mobile phones: they habitually placed their phones in their bras, of the sweat ducts in human skin to act as ‘helical antennae’ on the same side of the body where the tumour has developed. receptive to 5G frequencies of RF-EMF.­ When sweat ducts are Miller et al call for an urgent update of the last (2011) review exposed to these RF-EMFs,­ there are remote systemic effects, of EMFs and cancer by the International Agency for Research through the skin’s established capacity to secrete and send on Cancer.13 They predict that such an update would now rate hormones and other signals to the entire body.28 This report RF-­EMFs as, at minimum, ‘probable’ (not merely ‘possible’ as in alters one’s sense of the potential risks from such high frequency 2011) carcinogens, based on current evidence. waves, since they have long been thought to be ‘inherently less dangerous’, because they are largely absorbed in the top few millimetres of exposed tissue (thus limiting any adverse effects, Persistent allegations of unscientific bases for existing health in theory, to the skin or eye). protection guidelines on RF-EMFs and unmanaged conflicts of Finally, it is instructive to look at the two widely cited NIH interest on expert advisory panels toxicological studies of specific EMFs’ effects on thousands of A senior epidemiologist from Sweden, Hardell, has repeatedly rodents,29 30 conducted by experienced and highly respected published in peer-­reviewed journals detailed allegations regarding laboratory scientists at a world-­leading institution. Since their the main WHO scientific advisory body on EMF health effects publication in 2018, epidemiologists and other scientists have and safety—the previously mentioned ICNIRP. Hardell contends pointed out several methodological weaknesses in the conduct that ICNIRP’s membership includes over-­representation of and analysis of these studies that make their unequivocal inter- vested interests, especially the giant multinational telecommu- pretation almost impossible, particularly in terms of their rele- nications firms who are heavily invested in the roll out of 5G vance to human health: excessive statistical inference testing of systems internationally.36 37 ICNIRP has long been influential in multiple (over 1000) hypotheses, without appropriate adjust- EMF regulation: its scientific recommendations to WHO were ment of p values considered ‘statistically significant’; reporting first issued in 1998, updated in 2009, and revised and updated of results ‘often ignoring statistical tests’; failure to explain major again in March 2020.15 Hardell points out that ICNIRP’s pro-­ internal inconsistencies of findings across EMF doses, tumour industry bias may explain its continued reliance only on studies of types and rodent sexes; use of experimental EMF exposures far the thermogenic (heat-­producing) effect of RF-­EMFs in biolog- in excess of any known human ones; uncontrolled confounding ical tissues: these studies would be expected to paint an overly by direct thermogenesis effects—the list goes on.31 32 benign picture of RF-EMF­ safety. This narrow ICNIRP focus In short, laboratory studies of EMF exposure are fraught with flies in the face of published reviews by independent scientists (6, both internal and external validity issues, and cannot replace 8, 13, 26, 27) citing compelling research evidence, accumulating high-­quality human epidemiological studies—though, as we will steadily over the last few decades, of non-thermogenic­ adverse now discuss, these are also hard to come by. effects of RF-­EMFs, affecting diverse human and animal subcel- lular function, tissues and organ systems (see above). In detailed, almost lawyer-­like publications,36 37 Hardell fastidiously docu- Lack of conclusive human epidemiological studies of ments the ICNIRP’s 20 years of dogged defiance, in the face of 5G-specific health effects (but increasing epidemiological widespread criticism by other scientists, that the scientific base AUTHOR PROOF evidence of serious health effects from previous generations for their recommendations remains dated and narrow, rendering of RF-EMF exposures) their guidelines on ‘safe’ RF-­EMF exposure unsafe. Canada’s most senior cancer epidemiologist, Miller et al have last The most damning evidence adduced by Hardell is a table of year summarised the human epidemiological evidence33 linking the cross-­appointments held by six members of the WHO Mono- human breast and brain tumours, male reproductive outcomes graph Group, across five major international advisory panels and child neurodevelopmental conditions to RF-­EMF exposures on the health effects of non-­ionising radiation [36 – page 408]. resulting from the use of past generations of transmission systems. Hardell also describes these scientists’ strong personal links to Critically, this evidence is not about exposure to the high radio the telecommunications industry, a situation likely arising from frequency/short wavelength 5G systems. These systems are too the fact that the ICNIRP itself is a ‘private organisation (non-­ newly deployed to have been extensively studied, especially by governmental organisation; NGO) based in Germany. New

Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 3 Essay expert members can only be elected by members of ICNIRP.’ when pandemic control actions are paramount.42 This writer Hardell contrasts the ICNIRP’s reports to the publications of the completely supports that view of the broader scientific commu- ‘BioInitiative 2012’38 group, of nearly 30 international experts nity: the theory that 5G and related EMFs have contributed to in this field, whose operations are not only wholly independent the pandemic is baseless. of any such ‘vested interests,’ but also entirely transparent. The It follows that, for the current 5G roll-­out, there is a sound current version (March 2020) of the BioInitiative 2012 website38 basis for invoking ‘the precautionary principle’.43 This is the provides detailed descriptions of 988 peer-­reviewed scientific environmental and occupation health principle by which signifi- studies of adverse potential health and biological effects of cant doubt about the safety of a new and potentially widespread EMFs arising from RF and similar non-­ionising sources. The human exposure should be a reason to call a moratorium on vast majority (84.6%) of these 988 studies document disruptive that exposure, pending adequate scientific investigation of its biological effects from such EMFs, almost all of them oper- suspected adverse health effects. In short, one should ‘err on the ating via non-­thermogenic pathways. (This writer would have side of caution’. In the case of 5G transmission systems, there is preferred to see more ‘critical appraisal’ of the quality of the no compelling public health or safety rationale for their rapid studies than the BioInitiative 2012 website provides. However, deployment. The main gains being promised are either economic the major effort entailed in assembling this massive body of (for some parties only, not necessarily with widely distributed scientific evidence, and updating it regularly since 2012, is financial benefits across the population) or related to increased impressive). consumer convenience. Until we know more about what we are Finally, Carpenter has recently published a well-­researched getting into, from a health and ecological point of view, those analysis of how source of funding correlates with study find- putative gains need to wait. ings, across many peer-­reviewed publications over the last few decades, of the relationship between various kinds of EMF expo- Contributors JWF is the sole author of this essay, responsible for all aspects of its sure and several cancers.39 He shows convincingly that studies conceptualisation, background research and writing. funded by private sector entities, with strong vested interests in Funding The authors have not declared a specific grant for this research from any maintaining their current use of the sources of EMFs under study, funding agency in the public, commercial or not-­for-­profit sectors. tend to find no association—whereas studies funded by public Competing interests None declared. sector or independent sources find the opposite. As Carpenter Patient consent for publication Not required. points out, this suggests that many systematic reviews and meta-­ Provenance and peer review Not commissioned; externally peer reviewed. analyses in this field, having failed to correct for this ‘source of Data availability statement Data sharing not applicable as no datasets funding bias,’ likely underestimated the evidence for causation. generated and/or analysed for this study. No data were collected, or repurposed/ used in the writing of this essay.

CONCLUSIONS AND RECOMMENDATION ORCID iD In assessing causal evidence in environmental epidemiology, John William Frank http://​orcid.​org/​0000-​0003-​3912-​4214 Bradford Hill himself pointed out that ‘the whole picture matters;’ he argued against prioritising any subset of his famous REFERENCES nine criteria for causation. One’s overall assessment of the likeli- 1 Scottish Government. 5G: strategy for Scotland. Available: https://www.​gov.​scot/​ hood that an exposure causes a health condition should take into publications/​forging-​digital-​future-​5g-​strategy-​scotland/ [Accessed 8 Oct 2020]. account a wide variety of evidence, including ‘biological plausi- 2 Negreiro M. Towards a European Gigabit Society: Connectivity Targets and 5G. bility’.34 35 After reviewing the evidence cited above, the writer, European Parliament Research Service (EPRS)/ Brussels, European Parliament, 2017. Available: https://www.​europarl.​europa.​eu/​RegData/​etudes/​BRIE/​2017/​603979/​ an experienced physician-epidemiologist,­ is convinced that EPRS_​BRI(​2017)​603979_​EN.​pdf [Accessed 8 Oct 2020]. RF-­EMFs may well have serious human health effects. While 3 Directorate-­General for Internal Policies, European Parliament. 5G deployment: state there is also increasing scientific evidence for RF-­EMF effects of play in Europe, USA and Asia. Brussels: European Parliament, 2019. https://www.​ of ecological concern in other species,6–8 16–18 23 both plant and europarl.​europa.​eu/​RegData/​etudes/​IDAN/​2019/​631060/​IPOL_​IDA(​2019)​631060_​ animal, these have not been reviewed here, for reasons of space EN.​pdf 4 Nordrum, Amy; Clark, Kristen (January 27, 2017). Everything you need to know about and the author’s disciplinary limitations. In addition, there is 5G. IEEE Spectrum Magazine. Institute of Electrical and Electronic Engineers, 2019. convincing evidence, cited above, that several nations’ regula- Available: https://www.​fitce.​gr/​everything-​need-​know-​5g/ [Accessed 8 Oct 2020]. tory apparatus, for telecommunications innovations such as the 5 Karaboytscheva M. Effects of 5G Wireless Communication on Human Health. 5G roll-­out, is not fit for purpose. Indeed, significant elements in European Parliament Research Service (EPRS)/ Brussels, European Parliament, 2020March. Available: https://​europarl.​europa.​eu/​RegData/​etudes/​BRIE/​2020/​ that apparatus appear to have been captured by vested interests. 646172/​EPRS_​BRI(​2020)​646172_​EN.​pdf [Accessed Oct. 8, 2020]. Every society’s public health—and especially the health of those 6 Russell CL. 5 G wireless telecommunications expansion: public health and most likely to be susceptible to the hazard in question (in the case environmental implications. Environ Res 2018;165:484–95. of EMFs, children and pregnant women)—needs to be protected 7 Moskowitz JM. We have no reason to believe 5G is safe. Scientific American blogs, by evidence-­based regulations, free from significant bias. 2019. Available: https://​blogs.​scientificamerican.​com/​observations/​we-​have-​no-​ reason-​to-​believe-​5g-​is-​safe/ [Accessed 8 Oct 2020]. AUTHOR PROOF Finally, this commentary would be remiss if it did not mention 8 Di Ciaula A. Towards 5G communication systems: are there health implications? Int J a widely circulating conspiracy theory, suggesting that 5G and Hyg Environ Health 2018;221:367–75. related EMF exposures somehow contributed to the creation or 9 Vodaphone UK. Is 5G safe? Available: https://​newscentre.​vodafone.​co.​uk/​5g/​is-​5g-​ spread of the current COVID-19 pandemic. There are knowl- safe/ [Accessed 24 Mar 2020]. 10 Foster KR. 5G Is Coming: How Worried Should We Be about the Health Risks? So far, edgeable commentators’ reports on the web debunking this at least, there’s little evidence of danger. Scientific American blogs, 2019. Available: theory, and no respectable scientist or publication has backed https://​blogs.​scientificamerican.​com/​observations/​5g-​is-​coming-​how-​worried-​should-​ it.40 41 Indeed, combatting it is widely viewed by the scien- we-​be-​about-​the-​health-​risks/?​print=​true [Accessed 24 Mar 2020]. tific community as critical to dealing with the pandemic, as 11 Powerwatch UK. Radiofrequency EMFs and health risks. Available: https://www.​ powerwatch.​org.​uk/​library/​downloads/​rf-​emfs-​1-​intro-​2018-​11.​pdf [Accessed Oct. 8, conspiracy theorists holding this view have already carried out 2020]. violent attacks on mobile phone transmission facilities and other 12 AGNIR. Health effects from radiofrequency electromagnetic fields. Report from the symbolic targets, distracting the public and authorities at a time Independent Advisory Group on Non-­Ionising Radiation. In: Documents of the health

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Lancet Planet Health 2018;2:e512–4. 33 Miller AB, Sears ME, Morgan LL, et al. Risks to health and well-­being from radio-­ 17 Pall ML. 5G risks 8 types of harm. Available: https://www.​radiationresearch.​org/​ frequency radiation emitted by cell phones and other wireless devices. Front Public articles/​5g-​risks-​8-​types-​of-​harm-​martin-​pall-​2018/ [Accessed 9 Oct 2020]. Health 2019;7:1–10. 18 International EMF scientists appeal statement, 2020. Available: https://www.​ 34 Hill AB, Bradford Hill A. The environment and disease: association or causation? Proc emfscientist.​org/ [Accessed 8 Oct 2020]. R Soc Med 1965;58:295–300. 19 Carpenter DO. Open letter about the risks of the intensively pulsed EMFs from “smart 35 Carlberg M, Hardell L. Evaluation of mobile phone and Cordless phone use and meters”, 2012. Available: https://www.​saferemr.​com/​2015/​02/​health-​experts-​caution-​ glioma risk using the Bradford Hill viewpoints from 1965 on association or causation. about-​smart.​html [Accessed 8 Oct 2020]. Biomed Res Int 2017;2017:1–17. 20 International appeal: stop 5G on earth and in space. Available: https://www.​ 36 Hardell L. World Health Organization, radiofrequency radiation and health - a hard 5gspaceappeal.​org/ [Accessed 8 Oct 2020]. nut to crack (Review). Int J Oncol 2017;51:405–13. 21 Physicians for safe technology. Available: https://​mdsafetech.​org/​2019/​04/​28/​stop-​5g-​ 37 Hardell L, Nyberg R. Appeals that matter or not on a moratorium on the may-​15-​2019-​day-​of-​action/ [Accessed 8 Oct 2020]. deployment of the fifth generation, 5G, for microwave radiation. Mol Clin Oncol 22 Powerwatch UK. International guidance levels. Available: https://www.​powerwatch.​ 2020;12:247–57. org.​uk/​science/​intguidance.​asp [Accessed 8 Oct 2020]. 23 Physicians’ Health Initiative for Radiation and Environment (PHIRE). Safety limits 38 BioInitiative 2012 (updated 2017 and 2019). A rationale for biologically based and political conflicts of interest. Available: http://​phiremedical.​org/​safety-​limits-​and-​ exposure standards for low-­intensity electromagnetic radiation. Available: https://​ political-​conflicts-​of-​interest/ [Accessed 8 Oct 2020]. bioinitiative.​org/​updated-​research-​summaries/ [Accessed 24 Mar 2020]. 24 Zieszczynski D. Response to blog “5G Misinformation campaign by the Mobile and 39 Carpenter DO. Extremely low frequency electromagnetic fields and cancer: how source Wireless Forum”,. Available: https://​betw​eenr​ocka​ndha​rdplace.​wordpress.​com/​2019/​ of funding affects results. Environ Res 2019;178:108688. 09/​12/​5g-​misinformation-​campaign-​by-​the-​mobile-​wireless-​forum-​mwf/ [Accessed 8 40 Lewis K. Full fact. 2020 MAR 31. 5G is not accelerating the spread of the new Oct 2020]. coronavirus. available at. Available: https://​fullfact.​org/​health/​5G-​not-​accelerating-​ 25 Weaver M. Revealed: 5G rollout is being stalled by rows over lampposts. The coronavirus/ [Accessed 12 Oct 2020]. Guardian, 2019. Available: https://www.​theguardian.​com/​technology/​2019/​may/​19/​ 41 Shanapinda S. The Conversation. 2020 Apr 07. No, 5G radiation doesn’t cause or revealed-​5g-​rollout-​is-​being-​stalled-​by-​rows-​over-​lampposts [Accessed 12 Oct 2020]. spread the coronavirus. Saying it does is destructive. Available: https://​tinyurl.​com/​ 26 Simkó M, Mattsson M-­O. 5G wireless communication and health effects-­A pragmatic uppng7w https://​theconversation.​com/​no-​5g-​radiation-​doesnt-​cause-​or-​spread-​the-​ review based on available studies regarding 6 to 100 GHz. Int J Environ Res Public coronavirus-​saying-​it-​does-​is-​destructive-​135695 [Accessed 12 Oct 2020]. Health 2019;16:3406–28. 42 Waterson J, Hern A. The guardian. 2020 Apr 06. at least 20 UK phone masts 27 Kostoff RN, Heroux P, Aschner M, et al. Adverse health effects of 5G mobile vandalised over false 5G coronavirus claims. Available: https://www.​theguardian.​ networking technology under real-­life conditions. Toxicol Lett 2020;323:35–40. com/​technology/​2020/​apr/​06/​at-​least-​20-​uk-​phone-​masts-​vandalised-​over-​false-​5g-​ 28 Betzalel N, Ben Ishai P, Feldman Y. The human skin as a sub-­THz receiver - Does 5G coronavirus-​claims [Accessed 12 Oct 2020]. pose a danger to it or not? Environ Res 2018;163:208–16. 43 Health and Safety Executive. Reducing Risks, Protecting People: HSE’s Decision-­ 29 National Toxicological Programme. NTP Technical Report on the Toxicology and Making Process. London: Health and Safety Executive, 2001: 1–88. https://www.​hse.​ Carcinogenesis Studies in Sprague Dawley Rats Exposed to Whole-­Body Radio gov.​uk/​risk/​theory/​r2p2.​pdf AUTHOR PROOF

Frank JW. J Epidemiol Community Health 2020;0:1–5. doi:10.1136/jech-2019-213595 5 Karen Banks

From: alan jones Sent: 29 January 2021 16:08 To: [email protected] Subject: Re: Planning Application R/85/51A/GDO

Dear Yorkshire Dales Planning,

For the avoidance of any confusion, I re-submit my objection to planning application R/85/51A/GDO.

My objection is as follows:

Quickline is the lead partner of a consortium named MANY. I have submitted written evidence to North Yorkshire County Council that MANY has presented false and misleading information as part of its 'consultation' process. I have drawn this to the attention of councillors and a senior manager who works for the council. MANY mistakes ignorance and confusion for informed consent, which it cannot demonstrate. A piece of low quality academic output titled "Performing a Myth to Make a Market", co- authored by a representative of MANY from Lancaster University, offers an insight into MANY's approach to engagement - perseverance with its deflective and sloppy use of jargon will uncover its vacuity. MANY proclaims an "ethical" approach and at the same time classifies residents who raise questions as "anti 5G campaigners". Again, I have written evidence to support this. This project should be the subject of much closer scrutiny by decision makers to determine the reliability of its claims, possible alternatives and its fitness for rollout in a national park. I have raised points of sufficient seriousness to warrant postponing a planning decision until those making the decision are adequately informed and a proper consultation has taken place.

I should like to add, in connection with MANY's and NYCC's engagement process, that MANY and NYCC are attempting to wholly stage manage remaining meetings by asking for questions in advance and requiring participants to declare their stance on the project as a precondition of admission. I would like this noted as part of my objection.

Yours sincerely, Alan Jones

From: [email protected] Sent: 29 January 2021 15:34 To: [email protected] Subject: Planning Application R/85/51A/GDO

Please see attached letter regarding Application for prior approval under Part 16 of Schedule 2 to the Town & Country Planning (General Permitted Development) (England) Order 2015 as amended by the Town & Country Planning (General Permitted Development) (England) (Amendment) (no.2) Order 2016 and in accordance with the electronic communications code under the Telecommunications Act 1984 Schedule 2 as amended by the Communications Act 2003 for the installation of a 17m wooden utility Pole (15m above ground level) with mobile communications antenna and equipment cabinet at Land to the south east of existing agricultural buildings off High Lane, West Scrafton, Leyburn

Planning Department Yorkshire Dales National Park Authority

1 Karen Banks

From: Scar House Sent: 29 January 2021 14:18 To: Andrew Bishop; Planning; localplan; [email protected] Subject: Objection to R/85/51A/GDO

I would like to register my objection to the proposed mast at West Scrafton. I did object previously but as the date has been extended and the MANY project has recently been subject to more exposure I would like to make the following comments.

In my opinion this planning application is not simply about whether a mast should or should not be erected at West Scrafton, or indeed any other site in the YDNP. This planning application stands to determine the future direction of the Yorkshire Dales National Park. By granting planning permission for this mast you will be giving permission to enable 5G technology in the Yorkshire Dales. This is a massive decision.

Real 5G is a key enabler for the Internet of Things, for SMART (self-monitoring and recording technology) communities and data gathering. It is so much more than being better than 3G or 4G. The implementation of real 5G will be an immersive technology. It is said that it will be all around us and unfortunately not something we can choose to opt in or out of. Is such technology in line with the statutory purpose of the YDNP 'to conserve and enhance the natural beauty, wildlife and cultural heritage'? My own view is that 5G technology is at odds with the statutory purpose of the YDNP and moreover, I feel, would actually serve to destroy the cultural heritage of these areas. People come to the Yorkshire Dales to experience nature, remoteness, wilderness. There are few remaining areas in the UK which remain wild and remote and they should be cherished.

Coverdale is for the most part served by super fast broadband. It is my understanding that there will soon be 3 Emergency Services masts which EE look to activate for a commercial service. Coverdale residents not served by super fast broadband have the right to access it. Fibre would provide a fast and largely unobtrusive solution to the connectivity issues of both residents, visitors and people looking to move to the YDNP. 5G and connectivity should not be viewed as the same beast.

In deciding on this planning application I would be pleased if you could also:

• seek to establish the long term plan for the 5G implementation. MANY claim that the project will not be using wavelengths and frequencies associated with real 5G but it is unclear therefore how the 5G applications will work. I urge you, at the very least, to guard against an invisible expansion of this infrastructure and upgrade to real 5G. • seek to establish what further masts/antenna etc will be required if the project is to be extended into the high Dale and make provision to protect Coverdale from a proliferation of masts.

Yours sincerely

Helen Alderson Scar House Arkleside DL8 4TU

1 Karen Banks

From: Karl Alderson Sent: 29 January 2021 13:53 To: Andrew Bishop; Planning; localplan Subject: Objection to R/85/51A/GDO

I was born in Coverdale and have lived here all my life. I have worked on the moors in the Dale when there were no mobile phones whatsoever. I have owned a mobile phone for the last 10 years and accept that there are areas that get signal and areas that don't. I regard that as part of the beauty of living here.

I believe that all we need in Coverdale is fibre broadband, not 5G and all the potential risks, masts, drones etc that it may bring. In my opinion it would be like living in a town or a city and that is not what these Dales areas are about. They are unspoilt areas and should be kept like that.

Please register my objection.

Yours sincerely Karl Alderson Scar House Arkleside DL8 4TU

1 Karen Banks

From: kate cuthbert Sent: 29 January 2021 10:45 To: Andrew Bishop; Planning; [email protected]; localplan Subject: Planning Application: R/85/51A/GDO

Dear YDNPA planning committee members and chief planning officer PLANNING APPLICATION: R/85/51A/GDO

Please record my objection to the above application.

I feel the project does not extensively address the problem of connectivity in the whole of Coverdale. MANY have been less than open regarding the long term health issues.

Coverdale needs better communication infrastructure but not at any cost and not only for the benefit of the supplier.

Yours sincerely Kate Cuthbert Barn Owl Cottage West Scrafton DL8 4RU

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1 Karen Banks

From: ijbrotherton Sent: 29 January 2021 10:32 To: [email protected]; [email protected] Subject: Re: Planning Application R/85/51A/GDO

Dear Mr Bishop, Thanks for this in response to our objection letter, also of 27 January. We have at last got to view the application on your web- site (how easy to do when you know how) and having seen who is involved and what is involved, also havin g received answers to various queries, and fully accepting we should have done all this before sounding off, we wish to withdraw our objections. We remain generally concerned as to where technology may be taking us all, but that perhaps is an age thin g; also in particular as to impacts on the parks. But please be assured this application has our full support an d sincere apologies for our shillying. Yours sincerely Ian and Jenny Brotherton

------Original Message ------On Wednesday, 27 Jan, 2021 At 15:36, [email protected] wrote:

Please see attached letter regarding Application for prior approval under Part 16 of Schedule 2 to the Town & Country Planning (General Permitted Development) (England) Order 2015 as amended by the Town & C ountry Planning (General Permitted Development) (England) (Amendment) (no.2) Order 2016 and in accor dance with the electronic communications code under the Telecommunications Act 1984 Schedule 2 as ame nded by the Communications Act 2003 for the installation of a 17m wooden utility Pole (15m above ground level) with mobile communications antenna and equipment cabinet at Land to the south east of existing agri cultural buildings off High Lane, West Scrafton, Leyburn

Planning Department Yorkshire Dales National Park Authority

1 Karen Banks

From: [email protected] Sent: 28 January 2021 19:38 To: Andrew Bishop; Planning; [email protected]; localplan Subject: Planning application R/85/51A/GDO

Dear YDNPA planning committee members and Chief Planning Officer,

Please record my objection to the above planning application.

I don’t believe the project which it’s a part of properly addresses the connectivity needs of Coverdale – and we don’t need a 5G ‘test bed’ It duplicates other efforts to provide these and I don’t wish to see an uncontrolled proliferation of masts in an otherwise unspoilt Coverdale. There has been insufficient openness about this project and the information which has been presented has not included all the facts – and in some cases has misled residents.

Finally, I am not a believer in daft conspiracy theories and generally embrace proven technology – but when we follow poorly executed scientific research, the results usually negatively effect us further down the line. If peer-reviewed articles are appearing in the BMJ questioning the quality of ‘data’ implying 5G is entirely problem free, I would very much hope that you would all encourage more and better research to prove 5G is entirely safe for humans and wildlife alike. Until then, please do NOT progress with this project in Coverdale.

Yours sincerely,

J Wallace West Deerclose Horsehouse Coverdale

1

Mount Pleasant

Carlton

Leyburn DL8 4BG

28th January 2021

Dear Sir

Letter in support of the Planning Application R/85/51A/GDO– telecommunications mast

I am writing in support of the planning application ref: R/85/51A/GDO for a telecommunications mast to be constructed at High Lane, West Scrafton, Leyburn.

I am a resident of the Coverdale who would significantly benefit from improved mobile and broadband connections. I work from home and so struggle constantly, on both a professional and personal level, with extremely low internet speeds and lack of mobile reception. People in urban areas and other parts of the Dales have had coverage for many years now and if you have this connectivity people tend to take it for granted – connectivity is not going to go away, this year highlights this.

The MANY project offers us an opportunity to do something about it. Some parts of Coverdale are lucky enough to Fibre to the premises but unfortunately this can not be relied on to provide total coverage and there are many properties that will not get any increase in speeds or new infrastructure for a long time. Like most parts of the UK, communication needs to be a mixture of both good broadband and mobile coverage.

The MANY project has carried out significant community engagement. This project gives us an opportunity to change Coverdale for the better, whilst influencing future Government policy. We need to bring Coverdale and similar areas in line with the rest of the UK so we can ensure the sustainability of the area.

I publicly back the project and their request for planning.

Your faithfully

OFFICIAL Karen Banks

From: [email protected] Sent: 28 January 2021 17:04 To: Planning Subject: PLANNING APPLICATION R/85/51A/GDO

Dear Sir/Madam

I am writing in support of the planning application Ref R/85/51A/GDO for a telecommunications mast to be constructed at High Lane, West Scrafton, Leyburn. I am a resident of Coverdale who would significantly benefit from improved Mobile and Broadband connections. We struggle and feel disadvantaged by not having any mobile reception. People in urban areas and other parts of the Dales have had coverage for many years now and if you have this connectivity people tend to take it for granted-connectivity is not going away, this past year highlights this. The MANY Project offers us an opportunity to do something about it. Some parts of Coverdale are lucky enough to have the Fibre option but it doesn't come up as far as me (it stopped a mile away) but even this cannot be relied upon to provide total coverage and there are many properties that wont get ant increased speeds or new infrastructure for a long time. Like most parts of the UK, communications need to be a mixture of both good broadband and mobile coverage. The MANY Project has carried out significant community engagement, this project gives us an opportunity to change Coverdale for the better whilst influencing Government Policy. We need to bring Coverdale and similar areas inline with the rest of the UK so we can ensure sustainability of the area.

I publicly back the project and their request for planning.

Yours Sincerely Alison Rice

1 Well House Horsehouse Leyburn North Yorkshire DL8 4TS

28 January 2021 FAO: Andrew Bishop, Senior Planning Officer

RE: Planning Application: R/85/51A/GDO

Dear Mr Bishop

I am writing to object to the above referenced planning application submitted by Quickline Communications for a 5G mast in West Scrafton as part of the Mobile Access North Yorkshire (MANY) project.

The argument that both Mobile Access North Yorkshire (MANY) and its proponents use is that all residents deserve good connectivity. This is a statement that I fully support.

However, MANY then goes on to make the spurious connection that support for better connectivity equates to support for the MANY project and 5G. It does not.

Putting to one side the overwhelming scientific evidence that 5G has damaging effects on human health, wildlife and the environment, and the impact of mast proliferation on the aesthetics of an unspoilt corner of the Yorkshire Dales National Park, the kind of fixed wireless broadband and mobile signal that MANY is proposing is not the best solution for our needs.

Fibre broadband is the gold standard. It is safe, fast, reliable, weather-proof and future-proof. A 3G or 4G mobile signal would be more reliable, have greater range, and would require fewer masts. These are the robust solutions that the people of Coverdale want and need.

SuperfastNY has already run fibre down a good part of the dale as far as and including Horsehouse; I estimate that of the 500 or so households within the target area of the MANY project, fewer than 40 currently don’t have access to superfast fibre. This number is approximately 80 if the properties in the upper dale outside the target area are included.

Outside mobile phone signal coverage is patchy, but with the recent approval of the Gildersbeck mast, there are now 3 emergency service masts along the dale and I understand from enquiries to the CEO of EE that these masts are capable of delivering a 4G commercial signal, subject to instruction from the Home Office.

NYCC councillors are giving partial and misleading information to those residents who currently suffer from poor connectivity by telling them that supporting MANY and 5G is their best and only option to access community learning, online schooling, deal with loneliness and isolation, work from home, access health care via online appointments, text messages and online video consultations, etc.

These are presented as the benefits of having 5G coverage. They are not. They are the benefits of fast broadband and a decent mobile phone signal.

This begs the questions: what is the point of the MANY project? How is it in the best interests of the people of Coverdale? Who is benefitting from this? Why is NYCC so keen to promote it that its councillors are resorting to misleading residents in order to claim ‘community support’?

An extension of the existing superfast fibre broadband cabling to the remaining handful of properties in the dale plus an adequate 3G/4G roaming mobile phone signal (which could be provided by ‘activation’ of the 3 emergency services masts for commercial use) are what is needed, and are all that is needed.

I find it shocking that the YDNPA is even considering allowing a corner of the National Park to be used as a ‘test-bed’ for a controversial technology that can at best deliver a sub-standard connectivity solution to the residents of Coverdale, and at worst, could have lasting damage to the health, wildlife, beauty and ecology of this unspoilt dale.

I urge you to respect your statutory purpose “to conserve and enhance the natural beauty, wildlife, and cultural heritage of the national parks” and to reject this application.

Kind regards,

Anne Pilling

Mr G Dye, Byemoore Farm, Melmerby

I note with interest this application to establish the means for Coverdale to have the undoubted advantage of good communications for its residents and businesses, which it is entirely fair to say, it does not have at present.

The single timber pole of modest dimensions will almost certainly go unnoticed by the vast majority of people as do the many thousands of other poles in this dale providing electricity transmission and telephone communications.

Unless one is of the belief, false in my view, that the antenna, which will sit at the top of this post, are likely to ‘fry’ residents and wildlife in the environment with micro waves then to all sane observers this application should be approved without any concern whatsoever.

If, however one sides with the activists in the undergrowth, anonymously active in our dale under the guise of ‘Coverdale Connect & Protect,’ then clearly such a pole and equipment is going to shorten our lifespan.

I and likely the majority of residents, who are unable currently to enjoy the undoubted benefits of excellent modern communications here, will however be delighted to see the Planning Authority grasp common sense with a firm hand and determine this application by granting the provider approval without delay.

I would therefore encourage all members to raise their hands in the affirmative and fully support the application. Gail Dent

From: Andrew Bishop Sent: 28 January 2021 15:05 To: Planning Cc: Clare Tamea; Clare Bevan Subject: FW: Planning application R/85/51A/GDO

Hi Planning,

Please register representations from Cllr Sedgwick and acknowledge.

Thanks, Andrew

Andrew Bishop Senior Planning Officer

Direct: Mobile: 07977 400500 Switchboard: 0300 456 0030

www.yorkshiredales.org.uk

Yorkshire Dales National Park Authority Yoredale | Bainbridge | Leyburn | DL8 3EL

From: Cllr.Karin Sedgwick [mailto:[email protected]] Sent: 28 January 2021 12:24 To: Andrew Bishop Subject: Planning application R/85/51A/GDO

Good morning Andrew, Reference Planning application R/85/51A/GDO

As the North Yorkshire County Councillor for the Middle Dales Division I would like to express my support for the proposed planning application regarding the MANY project.

Connectivity is vital to the rural areas in my division. I have received a lot of communication regarding the MANY project from a lot of people and I have attended various parish engagement events over the last year. Every one of my parishes were given the opportunity by MANY for an engagement event. Most of them were accepted and well attended.

The people that are definitely against 5G have had their questions and issues answered and have spoken about their concerns at numerous meetings arranged by them and also arranged by MANY. These meetings were also attended by others who lived outside the proposed areas for 5G. This had an intimidating effect on some residents who attended the meetings. I was told by them that they felt intimidated and were afraid to speak out.

The benefits of connectivity for businesses and residents are many. 35% of North Yorkshire does not have coverage and this is our opportunity to catch up. Attracting Young Families to the Dales is a priority for the YDNPA and this is definitely the way forward with that. Digital connectivity will make running a business from home possible, enable school age children to work on line. Yes, this pandemic will pass but it has been very difficult for A level students, some of whom have to be driven, in a car to a ‘hot spot’ and left there, just so that they can connect to school and take part in lessons. Receiving IT equipment from the government is excellent, to help with the current problem of

1 school closures, but not if you do not have connectivity. 5G will also enable online banking. An important way forward because of the proposed closure of more banks in the area.

Village hall users have expressed their delight at (hopefully) getting 5G. This would, they say, enable them to set up some community learning sessions with IT trainers, such as the Silver Surfers. Isolation and loneliness have been a big issue during the current lockdown but you do not have to be elderly, living alone or vulnerable to experience this. Greater digital connectivity benefits all and for those who say that they prefer to live without it, all they need to do is not make use of it.

I also understand, that a view, or lack of a view, is not a planning consideration. As such, then there should be no problem with the siting of 15m poles to enable 5G.

Leyburn Medical Practice have also stressed to me how important it will be to them. Online appointments, text messaging results and online video consultations are a few of the discussed benefits of having 5G coverage.

I shall be attending the YDNPA planning meeting on 9th February in my capacity as County Councillor for the Middle Dales.

Regards, Karin Sedgwick

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