COM/S2/05/9/A

COMMUNITIES COMMITTEE

AGENDA

9th Meeting, 2005 (Session 2)

Wednesday 16 March 2005

The Committee will meet at 9.30 am in Committee Room 1.

1. Housing (Scotland) Bill: The Committee will take evidence at Stage 1 from—

Panel 1

David Rogers, Jean Waddie and Roger Harris, Private Sector and Affordable Housing Policy Division, Archie Stoddart, Housing Bill Team and Katie Wood, Office of the Solicitor to the Scottish Executive (OSSE), Scottish Executive and Neil Ferguson, Single Survey Team, Communities Scotland

Panel 2

Andrew Robinson and Dave Cormack, Scottish Housing Condition Survey, Communities Scotland.

2. Petitions: The Committee will consider the following petitions—

PE650 by Alison Mackay, on behalf of NO 2 TETRA, on TETRA communication masts in Scotland

PE728 by Paul Goddard, on behalf of the Comrie Action on TETRA, on TETRA communication masts in Scotland

PE769 by Alan I Cameron on mobile phone and TETRA installations.

Steve Farrell Clerk to the Committee

Tel. 0131 348 5211 email: steve.farrell@scottish.parliament.uk

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The following papers relate to the meeting: Agenda Item 1 Note by the Clerk (private paper) Briefing paper by SPICe (private paper)

COM/S2/05/9/1(P) COM/S2/05/9/2(P)

Agenda Item 2 Note by the Clerk (petitions attached) COM/S2/05/9/3

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COMMUNITIES COMMITTEE

16 March 2005

PETITIONS PE650, PE728 AND PE769 1. The Committee has previously considered petitions PE650 and PE728

and is invited to consider them again in light of further developments. Petition PE 769 has also been referred to the Committee to consider with PE650 and PE7 as it is similar in subject matter.

PE650, PE728 and PE769 2. Petition PE650 is by Alison Mackay on behalf of NO 2 TETRA, calling for

the Scottish Parliament to take the necessary steps to delay the installation of terrestrial trunked radio (TETRA) communication masts in Scotland until potential health risks have been properly assessed and the relevant planning guidance has been amended to incorporate mandatory health and safety standards.

3. Petition PE728 is by Paul Goddard, on behalf of the Comrie Action on

TETRA, calling for the Scottish Parliament to urge the Scottish Executive to carry out a full inquiry into the health effects of TETRA and to implement an immediate moratorium on the installation and activation of the system until the outcome of such an inquiry is known.

4. Petition PE769 is by Alan I Cameron, calling for the Scottish Parliament to

unify the permission process for mobile phone and TETRA installations to ensure clarity and transparency within the decision-making process in order that the concerns of local communities are fully taken into account at every stage; there is a halt on all TETRA installations until health and other effects are clarified, and that all installations approved by ‘Licence notification’ be revoked and the ‘precautionary principle’ be exercised when granting planning permission for sites adjacent to residential properties.

Previous Committee consideration of petitions PE650 and PE728 5. The Committee considered PE650 on 31 March 2004, and considered this

petition again with PE728 at its meetings on 23 June and 29 September 2004.

6. At the meetings on 31 March and 23 June, the Committee considered

written evidence from O2 Airwave, police groups and the Scottish Executive. In summary, evidence received from those listed above stated that there were no specific concerns regarding use of TETRA and the Executive stated that the evidence to date has not shown a link between this technology and ill health. The Communities Committee also consulted the Health Committee and the Environment and Rural Development

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Committee who had no specific concerns to raise from their respective remits although the Health Committee agreed to appoint a reporter on health matters to participate in any Communities Committee inquiry.

7. At its meeting on 29 September 2004, the Committee considered an

Executive report, ‘An Evaluation of Revised Planning Controls over Telecommunications Development’1. The main aim of this research was to evaluate the effect of the land use planning controls introduced by the Scottish Executive in 2001 on various communities of interest involved in the development of telecommunications in Scotland. The report does not discuss at any length health issues of the nature raised by the petitioners although the research specification acknowledged that health concerns would arise through discussion of planning controls. It is also important to note that the report considers planning controls in relation to telecommunications development generally as opposed to specifically examining the issue of TETRA communication masts.

8. Following debate of this report, the Committee requested clarification from

the Executive in three main areas. The Minister for Communities responded on behalf of the Executive in November 2004 (attached as Annex A).

Response from the Executive on petitions PE650 and PE728 9. Firstly, the Committee asked for more detailed information on the rationale

behind the Executive’s view that health concerns should not be treated as material planning considerations, and consequently not taken into account in terms of planning decisions. The Committee also asked for an indication as to whether the Executive has any plans to consider a change to its position on this matter as it develops its proposals for forthcoming planning legislation.

10. The Executive’s response stated that ‘what constitutes a material

consideration in planning terms is not defined in legislation and is potentially very wide’ and is ‘ultimately a matter for the courts’. The Executive also outlined the purposes and background to ‘National Planning Policy Guideline (NPPG) 19: Radio Telecommunications’. This was developed to provide guidance to planning authorities following the IEGMP2 report and the Transport and the Environment Committee’s report on planning controls for telecommunications development. The Executive considers NPPG 19 to be sufficient and highlights that international ICNIRP3 standards are being followed as a precautionary approach in the

1 This report is available on the Executive’s website with separate links attached below for research findings: http://www.scotland.gov.uk/cru/resfinds/drf183-00.asp and the full report: http://www.scotland.gov.uk/library5/enterprise/rpctd-00.asp 2 The Independent Expert Group on Mobile Phones (IEGMP) issued its report ‘Mobile Phones and Health’ on 11 May 2000. The IEGMP report is also known as the ‘Stewart report’ in reference to the group’s chairman, Sir William Stewart. 3 The International Commission Non-ionising Radiation Protection (ICNIRP).

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UK as recommended by the IEGMP. Finally, the Executive stated that it has no plans to change its position via the proposed planning bill.

11. Secondly, the Committee requested more information regarding the

existing scientific studies of the impact of TETRA masts. In its discussion on 29 September, the Committee agreed that it would welcome more information on current research in this field, especially that being conducted by the Home Office and by other countries outside the UK. Related to this request was the public anxiety about the potential health implications of TETRA, which motivated these petitions and which was recognised as a concern in the Executive’s research report. The Committee also therefore wanted to know whether the Executive had any plans to produce public information material to help allay these concerns.

12. The Executive referred the Committee back to its previous response to the

Committee regarding research on TETRA and highlighted that the Home Office is continuing its studies on the health effects of TETRA (see annex to the Executive’s response). The Executive also stated that health and safety issues surrounding TETRA have been scrutinised by independent experts who have advised that:

• Results from Defence Science and Technology Laboratory (DSTL)

studies show that TETRA signals have no effect on calcium exchanges in cells – the main concern of the Stewart report;

• Airwave masts do not pulse. They meet international guidelines on emissions in areas accessible to the public, just like mobile phone masts;

• Airwave equipment conforms to health and safety guidelines. In particular, hands-free kits transmit very little energy into the head or body of users.

13. Other ongoing studies are on Specific Absorption Rates in vehicles,

studies into cognitive performance, electrophysiology and whether TETRA might cause epileptic seizures. Imperial College is carrying out a long-term health monitoring study of police users of Airwave. The Executive did not comment on the Committee’s query regarding public information material to assist in reducing public concerns.

14. Finally, the Committee asked how planning systems deal with health

concerns, both generally and more specifically in relation to TETRA masts, in other parts of the UK, as well as in other countries in Europe.

15. With regard to on how planning systems deal with health issues, the

Executive states that positions are similar in the UK in that health concerns can in principle be planning considerations, government guidance has been issued in relation to concerns regarding telecommunication masts and the international ICNIRP guidelines are considered sufficient. The Executive is not aware of any research on approaches within Europe to health concerns on phone masts or TETRA however the Minster states that ICNIRP guidelines are accepted but it is not known to what extent. In

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addition, the Executive states that planning systems are not necessarily comparable to those in the UK.

Other evidence sent to the Committee 16. In addition to the Minister’s response, the Executive has also received

written evidence from the petitioners in relation to both PE650 and PE728, and also from other individuals regarding the issues raised in the petitions. These are attached as Annex B).

17. The petitioners for PE650 have sent research conducted by themselves;

‘Residential Survey Around TETRA Installation at Worthing FC’. The PE728 petitioners have submitted a briefing; ‘ICNIRP Standard Guidelines and Pulse Modulated Electromagnetic Fields’. The report details the petitioners’ concerns regarding ICNIRP guidelines and specifically highlights that petitioners believe that TETRA masts do create a pulse-type effect and that the planning guidelines do not consider a full range of potentially detrimental effects such long-term effects, athermal effects, etc. The petitioners are also concerned regarding planning guidelines and believe that people are exposed to radiation without health factors being considered for masts sites or the precautionary principle being adhered to. The Committee has also received correspondence from individuals (one of which has been received via the Health Committee) who have expressed similar concerns regarding health as a material planning consideration for TETRA masts.

18. Additional material has also been sent to the Convener recently by

individuals concerned about the health impact of 3G telecommunication masts. Similar material received by the Conveners of both the Environment and Rural and Health Committees has also been passed to the Committee. These are also attached in Annex B.

Suggested action

19. The petitioners are primarily concerned with the potential health risks associated with TETRA masts. They do not have confidence in the ICNIRP guidelines for public exposure which are accepted by the Executive and the UK Government. They also disagree with the latest findings of the Home Office sponsored research which indicate that TETRA technology is unlikely to pose a risk to health. As a consequence of their concerns, they are requesting action on 3 fronts. The Committee is invited to consider the merits of each of these requests individually:

(a) an inquiry into the health effects of TETRA. Notwithstanding the ongoing research into the potential health effects of TETRA both at a UK level and internationally, the Committee may wish to consider whether it would be appropriate for it to reach a view on the merits of conducting such an inquiry given that health matters are outwith its remit.

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(b) a moratorium on the installation of further TETRA masts until the outcome of such an inquiry is known. The consideration of individual planning applications is a matter for planning authorities. It is suggested that it would be inappropriate for either the Parliament or the Executive to seek to impose such a moratorium without specific evidence that TETRA has harmful effects on the public.

(c) greater transparency and community involvement in the application process for both mobile phone and TETRA masts. This is a matter which clearly falls within the Committee’s remit. In response to its recent consultation on community involvement in the planning process, the Executive is likely to bring forward proposals in its forthcoming White Paper on Planning which will suggest improvements in this area. The Committee will scrutinise the Planning Bill which will follow the White Paper later in 2005. It is suggested that it may wish to consider taking the petitioners’ concerns in relation to this aspect of the planning system into account as part of that process.

20. It may also be possible for the Committee to pursue further with the Executive the wider issue of how public health matters are taken into account in the consideration of planning applications for certain categories of development such as TETRA masts, opencast mining, landfill sites etc. The Executive states that material planning considerations are not defined in legislation and are ultimately a matter for the courts. It would however seem reasonable for the Committee to discuss the relationship between health and planning issues during its scrutiny of the Executive’s forthcoming proposals for the development of the planning system. The Committee is invited to consider whether it would wish to take such action.

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Minister for Communities Malcolm Chisholm MSP Donald Gorrie MSP Depute Convener Communities Committee The Scottish parliament Committee Office Tower 2 – T3.40 EDINBURGH EH99 1SP

Victoria Quay Edinburgh EH6 6QQ Telephone: 0845 774 1741 scottish.ministers@scotland.gsi.gov.uk http://www.scotland.gov.uk Our ref: PGK/1/45/2 November 2004

_____ _____ Thank you for your letter of 14 October prompted by the Committee’s consideration of two petitions, PE650 and PE728 on the issue of terrestrial trunked radio (TETRA) equipment. You sought clarification of the rationale behind the Executive’s guidance that health concerns should not be treated as material planning considerations. I should say at the outset that the scope of what constitutes a material consideration in planning terms is not defined in legislation and is potentially very wide. Health considerations and public concern can in principle be material considerations in determining applications for planning permission. Whether such matters are material in a particular case is ultimately a matter for the courts. It is for the decision-maker (usually the planning authority) to determine what weight to attach to such considerations in any particular case. In relation to radio telecommunications development, concerns have been expressed about the possible effects of radiofrequency emissions from mobile phone handsets and base stations on health. It was as a result of such concerns that Tessa Jowell MP, the then Health Minister, asked the National Radiological Protection Board to undertake a survey of the available evidence. As you know, the Independent Expert Group on Mobile Phones (IEGMP) issued its report ‘Mobile Phones and Health’ on 11 May 2000. Two of the Report’s principal conclusions were that the balance of evidence to date suggested that (i) exposure to radiation from mobile phone technologies at levels below current guidelines did not cause adverse health effects to the general population, and (ii) there was no general risk to the health of people living near to base stations on the basis that the exposures are expected to be a small fraction of the guidelines. The report went on to recommend further research and measures to act as a precautionary approach. National Planning Policy Guideline (NPPG) 19: Radio Telecommunications was developed in light of the findings of the IEGMP and of the Scottish Parliament’s Transport and the Environment Committee report on planning controls for telecommunications development. Paragraphs 53-54 of NPPG 19 concluded that in light of the measures adopted in response to the report of the IEGMP, the roles of other bodies, such as the Health and Safety Executive, planning requirements to provide declarations regarding compliance with guidelines on public exposure to radio frequency emissions

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and the low powered nature of the technology that it is not necessary for planning authorities to treat radio frequency emissions as a material consideration in planning applications. Paragraph 40 of NPPG 19 acknowledges that there can be a degree of public concern about the siting and design of mobile phone base stations and that siting and design can play a part in allaying public concerns. It goes on to state that it is expected that operators will make all reasonable efforts to select sites which minimise public concerns. Paragraph 55 of NPPG 19 concludes that provided the guidance in the NPPG is followed it is unlikely that planning authorities could find justification for applying extended or alternative requirements either in development plans or development control in relation to health matters in the this context. Executive planning policies are of course subject to review and this will be the case NPPG 19, although we have no fixed timetable at present for such a review. As indicated, material considerations are not specified in legislation and we have no plans to make any changes as regards health as a material planning consideration in the context of a future planning bill. The IEGMP recommended that, as a precautionary approach, the International Commission Non-ionising Radiation Protection (ICNIRP) guidelines for public exposure be adopted for use in the UK. It took the view that this would bring the UK into line with other countries in the European Union. The UK Government and the Executive accepted this recommendation in the context of agreement with the EU Recommendation of 12 July 1999 on limiting public exposure to electromagnetic fields. Further reduction, or as they said "a higher assessment factor", was considered by the IEGMP, as this would have "the merit of simplicity", but was rejected as there was "no scientific basis to set the size of any increase". The UK has accordingly not accepted arbitrary reductions to the exposure guidelines as a basis of implementing regulation in electromagnetic field exposure. The view is that such arbitrary limits have no identifiable health benefits. The international guidelines have been developed to protect everyone in the population. It is important to acknowledge that ICNIRP is an international body that puts considerable effort into developing comprehensive reviews of scientific information available for providing a basis for recommendations on exposure guidelines for non-ionising radiation, including electromagnetic fields (EMF). The members of ICNIRP are experts in their field and they are supported by a number of standing committees on epidemiology, biology, physics and optics. Information on the work of ICNIRP can be found on its website at www.icnirp.org. The organisation also works closely with the World Health Organisation and its EMF Programme as well as the International Agency for Research and Cancer (IARC) in its review of scientific evidence of health effects of EMF. The advice that ICNIRP gives on exposure guidelines comes about as a result of extensive consultation that is based on the totality of the scientific evidence on possible health effects that is available. For this reason, ICNIRP guidelines are widely accepted around the world and are the basis for exposure standards in very many countries, both within Europe and further afield. With regard to your second point on information on the existing scientific studies of the impact of TETRA masts, Annex A contains, for ease of reference, the previous information given to the Committee by the Executive in this regard. The main programme of UK research focussing on the possible health continues to be that sponsored by Home Office and referred to in Annex A to this letter. A summary of the latest findings of this work is available on the Internet at http://www.policereform.gov.uk/implementation/tetra/tetra2.html. This states that:

TETRA health and safety issues have been subject to careful investigation by independent experts. Their advice is that is that TETRA technology is unlikely to present a risk to health:

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• Results from Defence Science and Technology Laboratory (DSTL) studies show that TETRA signals have no effect on calcium exchanges in cells – the main concern of the Stewart report;

• Airwave masts do not pulse. They meet international guidelines on emissions in areas accessible to the public, just like mobile phone masts;

• Airwave equipment conforms to health and safety guidelines. In particular, hands-free kits transmit very little energy into the head or body of users.

Further work on Specific Absorption Rates (see below) in vehicles is underway, as are studies into cognitive performance, electrophysiology and whether TETRA might cause epileptic seizures.

Imperial College is carrying out a long-term health monitoring study of police users of Airwave.

Finally, with regard to how planning systems elsewhere deal with health issues, as far as the UK is concerned, the position is similar across the board. In general, health concerns can in principle be planning considerations and government guidance has been issued in relation to concerns about radiofrequency emissions from mobile communication masts. In England, Planning Policy Guideline 8: Telecommunications, states at paragraph 30:

“it is the Government’s firm view that the planning system is not the place for determining health safeguards. It remains central Government’s responsibility to decide what measures are necessary to protect public health. In the Government’s view, if a proposed mobile phone base station meets the ICNIRP guidelines for public exposure it should not be necessary for a local planning authority, in processing an application for planning permission or prior approval1, to consider further the health aspects and concerns about them.”

In Wales, “Planning Policy Wales” (March 2002) states (Paragraph 12.13.7) that health considerations can be material considerations in determining applications for planning permission and prior approval as, in principle, can public concerns in relation to such effects. It goes on to stipulate (paragraph 12.13.8) that, with regard to health implications of proposed development, it is the Assembly Government’s view that, if the development meets the ICNIRP guidelines it should not be necessary for a local planning authority in processing an application for planning permission or prior approval, to consider further the health aspects and concerns about them.

The Welsh Technical Advice Note 19: Telecommunications states at paragraphs 85 and 86:

“Operators have responsibilities under health and safety legislation. They have a responsibility to assess any risk to health and safety which may arise, including an assessment of likely exposure levels, and to take any measures to restrict public access (e.g. through suitable locked and signed anti-personnel barriers). The practical effect of health and safety legislation should be to ensure protection of the public in respect of the established health effects of telecommunications apparatus.

“Local planning authorities should not seek to replicate through the planning system controls under the health and safety regime”

In Northern Ireland, paragraph 6.30 of Planning Policy Statement 10: Telecommunications states:

“As regards health concerns raised about emissions associated with mobile telecommunications, the Department of Health, Social Services and Public Safety (DHSSPS) while conscious of the need for further research and contributing financially towards the same,

1 In Scotland there is no prior approval system in relation to permitted development rights for telecommunications development. This reflects a recommendation of the Transport and the Environment Committee in their report on the planning controls on telecommunications development.

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considers that the guidelines of the International Commission on Non-Ionising Radiation Protection (ICNIRP) for public exposure to electromagnetic fields, as accepted by the World Health Organisation, are based on the best evidence available to date. Accordingly where concern is raised about the health effects of exposure to electromagnetic fields, it is the view of DHSSPS that if the proposed mobile telecommunications development meets the ICNIRP guidelines in all respects it should not be necessary for the Department to consider this aspect further.”

The documents referred to also describe the context for these statements, including for example the findings of the IEGMP and the responses made by the administrations to their recommendations. The above approaches relate to TETRA masts in the same way they do to other mobile communications masts. We are not aware of any research on the current approaches within the rest of Europe to health concerns about mobile phone masts generally or TETRA masts in particular. As indicated above, we understand that the ICNIRP public exposure guidelines are accepted around Europe, however, we do not have detailed information on the extent to which they may be incorporated as a consideration in the planning systems of European countries. Also, the planning systems and mechanisms in other European countries are not necessarily directly comparable to those which exist in the UK. In addition, there may be differences between national policies and those of regional or sub-regional authorities in some European countries. From contacts in Sweden, we understand that health matters connected to mobile telecommunications are the responsibility of the Swedish Radiation Protection Authority and the National Board of Health and Welfare. Generally, however, radiation from antennas for TETRA or other types of telecommunications facilities are not looked upon as a health matter in Sweden. I hope this information is of assistance.

MALCOLM CHISHOLM

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ANNEX A - HEALTH RESEARCH AND TETRA While it is not possible to say with absolute certainty that there are no health risks associated with the use of mobile telecommunications equipment, including TETRA handsets and associated base stations, the evidence to date has not shown a link between this technology and ill health. The Independent Expert Group on Mobile Phones (IEGMP) issued its report ‘Mobile Phones and Health’ on 11 May 2000. The Report provides a comprehensive study into the effects of telecommunications technology. Two of the Report’s principal conclusions were that the balance of evidence to date suggested that (i) exposure to radiation from mobile phone technologies at levels below current guidelines did not cause adverse health effects to the general population, and (ii) there was no general risk to the health of people living near to base stations on the basis that the exposures are expected to be a small fraction of the guidelines. The National Radiological Protection Board (NRPB) advises Government on radiation hazards. Following a request to the NRPB by the Home Office, the issue of possible health effects caused by signals from TETRA equipment was comprehensively addressed in a report by NRPB's independent Advisory Group on Non-ionising Radiation (AGNIR), chaired by Sir Richard Doll. The Report, “Possible Health Effects from Terrestrial Trunked Radio (TETRA)” was published in 20012. We are aware that the issue of pulsing is a concern with TETRA technology, however one of the report’s findings was that ‘It is notable that the signals from base stations are continuous, not pulsed, in contrast to those from mobile terminals and repeaters, which are pulsed’. The AGNIR Report also found that exposures of the public to signals from TETRA base stations are small fractions of international guidelines. There is, therefore, no reason to believe that signals from TETRA base stations should be treated differently from other base stations. An additional conclusion from the AGNIR Report was that ‘current evidence suggests that it is unlikely that the special features of the signals from TETRA mobile terminals and repeaters pose a hazard to health’. The AGNIR recently published (14 January) a further report “Health Effects from Radiofrequency Electromagnetic Fields, a report of an independent Advisory Group on Non Ionising Radiation (AGNIR)”. The report is fulfilling a recommendation of the IEGMP to review the science within three years. Although this further AGNIR report does not specifically consider TETRA signals, no further information was identified that altered the AGNIR's conclusions about the signals given in the 2001 report. I should stress that emissions from base stations and handsets, be they GSM or TETRA systems need to comply with stringent exposure guidelines laid down by the International Commission on Non-Ionising Radiation Protection (ICNIRP). In compiling its guidelines, ICNIRP has demonstrably reviewed the broad base of the scientific evidence, including studies covering suggestions of thermal and athermal effects and those using pulsed signals. OFCOM (Office of Communications) is carrying out an ongoing audit of radio frequency (RF) emissions from base stations (including TETRA base stations). To date, the audit has not found any instances where measured exposures exceed the ICNIRP guidelines. In addition, the Defence Science and Technology Laboratory (DSTL) were asked by the Home Office to undertake further research into whether TETRA signals can affect calcium levels and signalling in neurones and other cells. That part of the study examining intercellular exchanges is now complete and the details of its conduct and outcomes are summarised on the internet at 2 The reply to the petitions Committee gave the date of this report as 2002 in error.

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http://www.homeoffice.gov.uk/docs/tetra.html. From the reported findings of this major study the Home Office conclude that: • Results from the DSTL study indicate that TETRA signals have no effect on calcium exchanges in cells - the main concern that had been raised in the Stewart report. In addition to the DSTL study, the Home Office are also funding a long-term national health monitoring study of Airwave police users by Imperial College in London. As you are aware Airwave is the commercial name for the new police communications system which is currently being rolled out across England, Scotland and Wales by O2. The latest (third) quarterly report from the Imperial College team on progress on the “Airwave Health Monitoring” project is now available on the internet3. This project is at an early stage and, as might be anticipated, none of the progress to date has a direct bearing on the debate concerning possible health effects. In relation to these and other related studies the Home Office has made a clear statement that ‘If at any point an adverse effect is found, the Home Office will immediately make the information available and take appropriate action.’ This position is wholly in keeping with the approach taken by the Scottish Executive Health Department on public health issue of this nature.

3 http://www.homeoffice.gov.uk/docs3/thirdquarterlyreport.pdf

ICNIRP Standard Guidelines and PEMF 1

ICNIRP Standard Guidelines and Pulse Modulated Electromagnetic Fields

Andy Davidson BA, MA, MBA, DipM; Mast Sanity, Worthing, W Sussex

Abstract

In addition to the argument that ICNIRP guidelines are inadequate for protection of the general public from high-tension power lines creating time-varying electromagnetic fields (EMF) at 50/60 Hz (eg Draper 2004), it is now apparent that the ICNIRP guidelines are wholly inadequate for protection against amplitude-modulated or pulse-modulated EMF at other extremely low frequencies (below around 200 Hz).

The grounds for this concern are two-fold:

1. There is a substantial and growing body of peer-reviewed research indicating that confidence in the absence of risk from identified biological effects from ELF EMF is misplaced.

2. There is a growing awareness among people living in the vicinity of transmission masts that all is not well, and that nothing is being done.

In the absence of any degree of certainty as to safety, transmission masts are rapidly being erected in large numbers in residential areas, close to where people live and work, close to schools and hospitals. This is being permitted by the current planning guidelines, which give no rights to people obliged to receive chronic exposure to the radiation. In this, no precaution is being shown at all. Despite other articles of the guidelines, schools and hospitals are not in practice being protected. Even if they were, many thousands of children are today living far closer to masts for 18 hours a day, than for the six hours they spend at school.

Our premise is that ICNIRP guidelines are not suited to the situation of (typically) pulse modulated ELF EMF under long-term exposure, and that the planning guidance offered by the ODPM runs counter to the precautionary principle, even as stated by the Stewart Report (IEGMP, 2000).

Our assertion is that the safety guidelines require proper re-examination and that masts must not be sited near where people live and work.

________________________

ICNIRP Standard Guidelines and PEMF 2

Guidelines

The problem we wish to present is that current planning guidance from the Office of the Deputy Prime Minister states:

‘In the Government’s view, if a proposed mobile phone base station meets the ICNIRP guidelines for public exposure it should not be necessary for a local planning authority … to consider further the health aspects and concerns about them.’

The ICNIRP guidelines (1988, amended, 1998) say:

‘Only established effects were used as the basis for the proposed exposure restrictions. Induction of cancer from long-term EMF exposure was not considered to be established, and so these guidelines are based on short-term, immediate health effects such as stimulation of peripheral nerves and muscles, shocks and burns caused by touching conducting objects, and elevated tissue temperature resulting from absorption of energy during exposure to EMF. In the case of potential long-term effects of exposure, such as increased risk of cancer, ICNIRP concluded that available data are insufficient to provide a basis for setting exposure restrictions, although epidemiological research has provided suggestive, but unconvincing, evidence of an association between possible carcinogenic effects and exposure at levels of 50/60 Hz magnetic flux densities substantially lower than those recommended in these guidelines.

‘In vitro effects of short-term exposure to ELF or ELF amplitude-modulated EMF are summarized. Transient cellular and tissue responses to EMF exposure have been observed, but with no clear exposure-response relationship. These studies are of limited value in the assessment of health effects because many of the responses have not been demonstrated in vivo. Thus in vitro studies alone were not deemed to provide data that could serve as a primary basis for assessing possible health effects of EMF.’

What this means is that, even in 1988 and 1998, these guidelines subsequently adopted by Government to protect the public from adverse reactions and ill-health to installations emitting oscillating, amplitude-modulated or pulse-modulated electromagnetic fields, specifically exclude:

1. long-term effects of any kind

2. cancer, brain disorders, motor-neurone disease etc. (conditions suggested by in vitro research) caused not by intensity, but by coherent frequency.

What it means also is that the guidelines only apply to short-term acute exposures, based on the premise that only thermal effects of EMFs present any risk to health. In excluding this research, ICNIRP has been extensively criticised internationally.

ICNIRP Standard Guidelines and PEMF 3

Reliance on ICNIRP

These guidelines apply to mobile phones, DECT phones, TETRA handsets, and base stations of any characteristic. From all these sources we experience ELF pulse-modulated signals characterised by frequencies that figure in the scientific research as presenting particular concern through biological interaction. The research has demonstrated repeatedly that exposure at very low levels, and certainly well below the thermal safety guidelines, can cause physiological effects. In the case of TETRA two factors are of specific concern:

1. TETRA handsets are pulse modulated at 17.64 Hz

2. TETRA base stations do not employ adaptive power control; they therefore transmit on all four slots per frame at full power, all the time. This in itself creates a background modulated EMF envelope at 70.56 Hz, with a rhythmic 17.64 Hz ‘marker’ caused by the join in slot 4 of one frame and slot 1 of the next. (See appendix and further notes.) Whilst this has been defined away as not constituting a pulsed waveform by averaging power throughout the waveform, it is similar to the rhythmic pattern of a train’s wheels, which are never silent, yet which we all recognise.

The ICNIRP guidelines are therefore applied entirely inappropriately for protection from chronic low-level exposure and athermal biological effects arising from particular frequency windows. (It is for this reason that the TE/7 Committee in Australia, in March 1999, would not approve the ICNIRP guidelines.) Therefore there is no protection from these effects by adherence to these guidelines. Yet reliance on ICNIRP is expressed as satisfying the ‘precautionary approach’ in planning decisions and Planning Inquiries in accordance with PPG8.

Dosimetry

Examination of dosimetry research for ELF EMR appears to indicate that it is still in its infancy concerning low-level long-term exposure. Primarily, this appears to be because for thermal effects it is simpler to measure absorption than for athermal effects. Thermal effect dosimetry is proportional to radiation intensity, whereas athermal effect dosimetry must relate equally to the frequency mix. In addition, some effects are paradoxical, ie while certain thermal effects decrease with intensity, other effects simultaneously increase towards certain frequencies. So whilst there is any disagreement that athermal effects occur, the dosimetry cannot progress.

Without dosimetry for low-level chronic exposure, there can be no progress on guidelines. Therefore, at the very least it must be acknowledged that the ICNIRP guidelines have no bearing on athermal effects and no basis to suggest they might.

The table below exemplifies the current situation regarding dosimetry and base station exposure, but examination of the substance of the dosimetry research reveals that it primarily concerns energy absorption, not frequency response or entrainment.

ICNIRP Standard Guidelines and PEMF 4

MTHR programme of research

No. of studies: 19

Human studies on biology of mobile phone use: 7

Non-human studies on biology of mobile phone use: 3

Studies on psychology of mobile phone use: 3

Non-health studies of mobile phones: 1

Studies on how to study mobile phone use, eg dosimetry: 4

Studies on mobile phone base stations: 1

Studies that include TETRA signals: 3

Studies involving human biology and TETRA handsets: 1

Studies involving dosimetry and TETRA handsets: 2

Studies on TETRA base stations: 0

Treatment of the science

Even at the time of the Stewart report in 2000, there were eleven studies of calcium efflux research under ELF EMF available. Seven were positive, four (three by one researcher) were negative. All those on a 450 MHz carrier were positive. Since then a further peer-reviewed study has produced a positive result. The DSTL study has not, is not published, and is not-peer-reviewed, but is presented as definitive.

This situation is somewhat carelessly presented by Colin Blakemore as Chair of the Medical Research Council (and contributor to this concern in Stewart), as not somehow replicating similar studies of the 1970s, and as having no relevant health implications, whereas calcium assuredly does ‘play an important role in many biological processes, especially in the function of nerve cells.’ (Blakemore, NRPB, 2001). Whilst the experiments of the 70s may not have been replicated, all these further studies demonstrate the same effects but by different methodologies.

It is similarly suggested that confirmation of safety in ELF EMF comes from WHO. This is important, because the appeal is that WHO should recommend ICNIRP as a harmonized international standard. WHO, in its International EMF project, is far from proving concern unfounded.

The publication rate of peer-reviewed papers on biological effects of EMFs is now well over 1,000 per annum, also suggesting that the matter is far from settled. However, there is an industry of research in perception management, based, it seems, on the principle that the real problem is unfounded concern in an area of uncertainty. This is echoed in the sentiment expressed quite openly and publicly by mmO2 that all the public require is to be properly ‘educated’ and all the problems and anecdotal evidence (see below) will go away.

ICNIRP Standard Guidelines and PEMF 5

The question therefore is whether the uncertain science is being treated dispassionately in the face of enormous industry, economic and social/market pressure. Scientists such as Ross Adey, Neil Cherry and Robert Becker, highly respected in their fields, are discredited by those who have a clear need to demonstrate that their work is obstructive. Are these experts (and the many others who report the same findings) completely wrong?

Perhaps this protectionism from unpalatable facts is understandable: what are we to do tomorrow, if today we find our entire electricity and communications infra-structure to be damaging to our health? What if everyone were to learn the same and become fearful? And claim damages for loss of mobility for unsaleable property, or worse, for damages to health? Or if we had to move our pylons, our telecoms masts, and even change our domestic electric alternating frequency? This problem will not go away by compounding it, but can begin to be ameliorated by having adequate respect for the scientific voice and respond accordingly in our infra-structure planning, our health guidance, and our health and safety advice. Why the absence of independent base station research? Why has the Stewart recommendation that mobile phones should only be used by children for essential calls been at best completely neglected, at worst suppressed? To protect a multi-million pound market rather than children’s health?

The situation must be compared to asbestos: from compulsory use in buildings to compulsory removal, we have had to face the cost. ELF EMF will not be a smaller problem.

ICNIRP, NRPB and the real environment

Whatever our guidelines, the planning process betrays all precaution. According to the NRPB and ICNIRP, accumulative radiation is treated like two plays of the lottery: both plays are so infinitesimally small that two are no better than one. Mast sharing may reduce damage to the visual environment, but in terms of cumulative radiation, interference, local hotspots and secondary frequencies it is treated very naively. And all of this is in the context that ‘low’ emissions are only low in relation to short-term heating effects.

Instead of addressing the long-term low-level athermal concern, our whole system is constructed around visual amenity. We know that few people actually like tall metal structures in proximity to their homes, let alone in the middle of the countryside, or on ancient hilltops. But to base all our rights entirely on this as if they were (a) otherwise harmless, (b) resulted in no perception of threat or (c) not something communities should have any say about, is socially quite wrong. It is indeed the triumph of industrial might over common sense.

The author has confirmed by measurement with the proper radio equipment that certain EMF hotspots occur within his house, adjacent to a number of telecoms masts. The reason for these spots to be investigated was that they quickly cause headaches. As a result of the headaches being caused, there are parts of the house

ICNIRP Standard Guidelines and PEMF 6

where he will not stand or sit, in order to avoid the guaranteed discomfort. But how is this explained, and what investigation of this far-from-unique experience is there? Plainly something physiological is happening that goes completely against the assertions of ICNIRP.

The role of observation

It should be of great concern that communities living around telecoms masts are reporting clusters of unexpected effects. These range from a large number of reports of cancer and MND clusters that remain unexamined, to many instances of reported electrical sensitivity, or microwave syndrome, that appear much more quickly. That the experience is not properly named, let alone recognised, is testament to the lack of attention it has received in the UK. It appears in some quarters to be preferable to regard ‘nebulous’ conditions as psychosomatic, since this is simpler and removes any common cause or source of blame. This approach has been taken to ME (CFS), and Gulf War Syndrome long before EHS. It appears to be reflected in the awarding of EHS research under MTHR disproportionately to university psychology departments. It is interesting that the same researcher (Simon Wessely) who demoted CFS to a psychosomatic disorder was also part of the demoting of GWS similarly, yet only on 16 October 2004, GWS was affirmed as being a real syndrome by Professor Golombe. Simon Wessely’s unit is now studying the ‘psychobiological effects of using mobile phones’. Understandably, it would be nice to find that however uncomfortable the adverse effects of living near masts was, the cause was purely psychosomatic. But is this likely? And who is accepting the reports and investigating correlation and causation, without predetermining the outcome from the predictive origins of current scientific theory? In other words, it is strongly assumed that if the science cannot predict the displayed outcomes, then those outcomes cannot be valid.

Nevertheless, a pronounced effect during the period of installation of TETRA in the UK, is that particular sensitivity has been raised much more quickly. Whether this is properly EHS is questionable, since the people concerned are not generally also sensitive to sources other than microwave, nor previously sensitive. The Oberfeld, Navarro and Santini studies name this ‘microwave syndrome’ for this reason.

Example

One investigation in Sussex is under completion, but preliminary results show that out of a sample population of 346 living within 250 metres of a TETRA mast, 58.5 per cent reported a range of symptoms associated with microwave sensitivity since activation of the TETRA mast. 40 per cent have experienced disturbed sleep since it was switched on. Of seven common symptoms, four are strongly correlated with each other (sleep, headaches, nausea and dizziness). The survey included a question of use of DECT phones, and there is a significant difference in profiles or reported effects between owners and non-owners. The community observed, surrounds five co-located mobile installations (2 x GSM, 2 x UMTS, 1 x TETRA) and a sixth is under

ICNIRP Standard Guidelines and PEMF 7

construction. For years the residents have accepted the development of the masts, but with TETRA something appears to have ‘tipped them over the top’. This is not out of fear or over-awareness, and the effects, whilst obviously not all being attributable to the masts, are beyond the bounds of being entirely psychosomatic where the cause is not other than the masts. Perhaps DECT phones have a role to play too? Certainly, they too are covered by ICNIRP, are sold without any warnings of adverse effects (though many people are now experiencing this), and are used in offices with no guidelines as to appropriate density, siting on desks, or in certain kinds of structures.

Yet observation of this kind is of no official interest, and is dismissed. This study was run out of exasperation that no official response could be elicited to apparent but unassessed reports of problems. In a similar area (Isle of Wight), a report was produced by the Director of Public Health to demonstrate that no such study could possibly produce meaningful results, all based on NRPB and ICNIRP premises.

Where has the role gone of observation giving rise to hypothesis, to investigation and analysis? In situations like these, if the problems had arisen from more physical environmental factors, due investigation would be done, to the air, the water, the local supermarket etc.

There certainly appears to be something happening, among people who are not particularly followers of the news or research on masts or phones. These are people who love their phones and trust the government that they must be safe or they would not be allowed. Toys with dangerous eyes are banned at Christmas, after all.

Social acceptability

The author of this paper is not generally electrically sensitive, and never has been. Yet TETRA base station have a curious effect. First, the local one causes a severe sleep disorder, but interestingly, he can feel TETRA masts from a distance. This is not imagined, and is certainly unexplained.

The question about sleep deprivation being not only inconvenient but a long-term danger to health is unquestionable. Whether the physical awareness of TETRA masts is a danger or just a discomfort is quite unknown. But this, as with the people with persistent headaches that they put down to the masts, is surely not an acceptable social cost of the ability to sell and operate more mobile phones with increasing bandwidth.

The current situation is that in many ‘mast communities’ the effects are clearly being felt, that no-one is interested, that they are being told it is psychological thing, or that, whilst of unidentified source, it somehow cannot be anything to do with the masts. This, despite mast inactivity or by living away, clearly demonstrating that the effects cease. How many people are suffering low-level discomfort from these symptoms, quite unaware that it may be due to their DECT phone, or the local mast? They are uncounted, but if the aware communities are anything to go by, there must

ICNIRP Standard Guidelines and PEMF 8

be very many more unaware communities, whose well-being is daily being compromised, and whose long-term health is in question.

Reading the WHO: Establishing a Dialogue on Risks from Electromagnetic Fields, presents objectors and campaigners as necessarily wrong and risk as being absent. The tone of the NRPB response to what they term ‘anecdotal reports’ is that the real problem is people’s sensitivity, not the underlying cause of their sensitivity. It is worth comparing: would smoking related diseases be acceptable if we could cure everyone from the effects?

Appropriate response required

The whole situation of the relevance of ICNIRP to pulsed MW EMF in wireless technologies is now urgent. The proliferation of networks for mobile phones, of TETRA, DECT, wireless networks, public wi-fi hot-spots, NetRail, the highways project, and the growth of UMTS and bandwidth demand, is rapidly making the real-life assessment of effects too complex ever to separate out and measure.

Either this whole argument for precaution is quite unfounded, or there is a possibility that the reports of effects on well-being and health of some people are indeed linked to MW EMF.

If, as seems increasingly apparent, some people are indeed vulnerable to this increasing amount of radiation, they deserve and need public protection. At the very least, transmission masts must not be sited in residential areas, and devices such as DECT, mobile phones and wireless networks need not only to carry SAR ratings with practical explanation, but also obligatory precautionary advice for people sensitive to them, similar to adverse reaction advice provided for food or drugs.

In the meantime a better assessment of dose-effect is required than ICNIRP standards on short-term acute thermal effects.

ICNIRP Standard Guidelines and PEMF 9

Appendix: TDMA Concerns of TETRA

The familiar trace of a TETRA base station signal (Source: AGNIR)

Notes:

1. In this TDMA signal, each ‘bunch’ of modulations is a slot, and there are four slots in a frame. The overall wave envelope is characterised by 70.56 Hz, marked by a pronounced changes in amplitude modulation. Frames occur at 17.64 Hz, marked by missing changes, (long bursts where slot 4 is joined to the next slot 1). Were this acoustic, the rhythmic pattern ‘di-di-dah-di-di-dah’ would be quite apparent, and it does not require Fourier transforms to recognise the rhythm of the ‘dah’ at 17.64 Hz. The question is whether induced currents in the body from EMF, reflecting this rhythm, are perceived in any way similar to the body’s own bioelectromagnetic frequencies.

2. Whilst the 16 Hz concern relating to cellular Calcium efflux underpins one of the issues of TETRA (especially the aggressive handset pulsing), another is that of our underlying beta brain frequencies between 13 and 40 Hz under low but chronic exposure. This may be part of an explanation of the abrupt waking, experienced by many people living near TETRA base stations, at intervals coinciding with the transition from alpha to beta brain activity. Allied to this concern is the one of frequency entrainment, where bioelectromagnetic frequencies ‘fall in’ with imposed field frequencies.

3. The primary objection to frequency-dependent biological effects is not that this is not borne out by laboratory experiments (which it is), but that there is apparently inadequate understanding of a mechanism in the body whereby these signals can be recognised (ie distinguished from the 400 MHz carrier wave). Several mechanisms have been suggested, by Becker, Hyland, Cherry and Coghill, amongst others, but rather than test these hypotheses, the official view seems to be that whatever is seen in the laboratory, in the absence of an established mechanism, coherent signals such as these simply cannot be having an effect. Hence the absence from ICNIRP of coherent frequency effects, continues to be accepted. Effects, such as those on calcium, melatonin production and the blood-brain barrier, however, do present well-defined health risks.

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References

This list is highly selective. The intention has not been to create a definitive argument, but to point out the obvious problems in the current approach to ELF EMF safety assurance and protection. The literature on biological effects of ELF EMF is overwhelming; the Cherry paper below, for example cites 461 other papers.

Cherry N (2000), Safe Exposure Levels (130pp, a critique of ICNIRP), available from:

http://www.whale.to/b/cherry3.html

COST 281 (2003), Mobile Phone Base Stations and Health, Dublin Conference and Workshop Proceedings

Hyland G (2003), How Exposure to GSM and TETRA Base station Radiation can Adversely Affect Humans

ICNIRP (1998), Guidelines for Limiting Exposure to Time-varying Electric, Magnetic and Electromagnetic Fields (up to 300 GHz), International Commission on Non-ionising Radiation Protection

ICNIRP (1996), Health Issues Related to the Use of Hand-held Radiotelephones and Base Transmitters, International Commission on Non-ionising Radiation Protection

IEGMP (2000), The Stewart Report, Independent Expert Group on Mobile Phones

Maisch D (2004), The ICNIRP Guidelines: RF Risk Assessment Built on a House of Cards, presentation to Radiation Research Trust

NRPB (2004), Proposals for Limiting Exposure to Electromagnetic Fields (0 to 300 GHz), NRPB-W59, June

NRPB (2003), Mobile Phones and Health — an Update, NRPB eBulletin No. 3, March 2

NRPB/AGNIR (2001), Possible Health Effects from Terrestrial Trunked Radio (TETRA): Report of an Advisory Group on Non-Ionising Radiation

Navarro EA, Segura J, Gómez-Perretta C, Portolés M, Maestu C, Bardasano JL (2003), About the Effects of Microwave Exposure from Cellular Phone Base Stations: a First Approach

Oberfeld G, Navarro EA, Portoles M, Maesto C, Gomex-Perretta C (2004), The Microwave Syndrome — Further Aspects of a Spanish Study

Santini R, Santini P, Seigne M, Danze JM (2001), Symptoms expressed by people living near cell phone relay stations, La Presse Médicale

Silk A (2004), Mobile Communications and Interactions with Further RF and EMF Signal Systems, submission to the All Party Mobile Group, July

WHO (2002), Establishing a Dialogue on Risks from Electromagnetic Fields

COM/S2/05/9/3

Annex B

COMMUNITIES COMMITTEE

16 March 2005

PETITIONS PE650, PE728 AND PE769

Correspondence from Mrs G Hyslop

To Whom it may concern, From the Evening of the 20th.November 2002, I was in a Contact House at RAF Leuchars in Fife. I had gone there after ringing SSAFA for help. As I had lost my home on the 26th April 2002, and had travelled all round the UK trying to find somewhere to live. I have a problem being sensitive to Electo Magnetic fields and having a Medical Device which causes a problem. I drove up from Scots Corner Travel Lodge after being in touch with Angela from Leuchars SSAFA who was arranging accommodation . Will be near to Radar, but I will have to see how things go Funds are getting low and 222 miles to Leuchars is longer than I have travelled towing my caravan but I am really tired out, and ISLA my Retriever needs a better quality of life. 21st November 2002 Contact House, Buchanan House Had a good night¹s sleep Whacked a bit while over with Angela at SSAFA Office trying to sort things out. Went to the Hive for Coffee. Angela is taking me to a Caravan Site tomorrow to have a look. (They have long stay Caravans Static) Wish I could get a normal life back. I have a pass to get access to Laundry Facilities on Camp. 22nd November 2002 Had good night¹s , but my ears and chest hurt all day when we arrived at the Caravan Park, Hum Horrendous so had to leave and go back to RAF Leuchars my ears and chest still hurting I am not sure I can take much more. I phoned Stuart re my furniture to see if Jean can hold on for a little longer with it. I am running out of places to go 23rd November 2002, Did NOT have a good night my chest ached and my ears burned. I went into Cupar but there is a Mast in the middle of the town felt ill Prices out of my reach for property if I could stay there. I met a couple when I returned to Leuchars who watched ISLA when I went in to the Supermarket. They invited me for`Tea to their Mobile Home They had had a Retriever I am to take ISLA at 2pm tomorrow 15,00 hrs. do not feel as bad as I did this morning

COM/S2/05/9/3

Annex B 24th November 2002 Feel really weak and shaky do not think I can last the week here the couple who invited me out were Wilma and Bill Normand. Was not too bad in their caravan. 25th November 2002 Hardly any went to sleep feel really shaky went into the Hive for a coffeeI am feeling worse Really shaking now. Bill the Chaplain went to tell Angela at the SSAFA office she took me by car to the village Surgery the Doctor did not know what to do, but I explained to her if I drank a lot of water, I would hopefully feel better. Although I know I must leave here the bouts are getting more frequent, and the Contact House feels like being in a Tumble Drier. Also the vibratons from the Jets taking off is also affecting ISLA Angela and another Officer helped me to get my caravan hitched up and I set off for the DeanPark Hotel in Renfrew to be near the Southern General Hospital for my appointment to look at my Implant. One other point, is I have relatives at Balmullo but could not stay long at their house, in fact I spoke `to them outside. Now I know a Tetra Mast is behind their house, and is affecting them. Having now travelled over 14.000 miles all over the UK trying to find somewhere to live a normal life, I now know there is not anywhere. And many people have been badly affected by Mast Emmisions. Leuchars has been one of the worst places I visited . Mrs G Hyslop

COM/S2/05/9/3

Annex B

COMMUNITIES COMMITTEE

16 March 2005

PETITIONS PE650, PE728 AND PE769

Correspondence from Adam Alexander Please see copy of my letter to Fife Council's Chief Executive (below} Douglas Sinclair,CBE, Chief Executive, Fife Council Fife House North Street GLENROTHES Fife KY7 5LT 18 November 2004 Dear Mr. Sinclair, PETITION TETRA MAST PITTENWEEM PRIMARY SCHOOL I refer to my previous correspondence with Mr. Jim Birrell, Development Manager (Development & Regeneration) regarding the above, copies of which you should have received. Twice now I have requested information from Mr. Birrell about complaint procedures so that I may pursue a complaint regarding the Council¹s act of discrimination against the citizens of Pittenweem as expressed in the above petition. I also wish to pursue a complaint about the misinformation promulgated by various Council officers regarding the assertion that as a planning authority the Council is not able to legitimately concern itself with possible health effects when dealing with planning applications to erect TETRA masts. There is much to question about the Council¹s assessment of its own role as being restrictedin relation to possible health risks associated with TETRA masts, balanced against its duty of care towards the citizens of Fife, especially towards our children and our elderly population There are also serious issues concerning the way in which Fife Council¹s mechanisms for decision making have undermined and eroded some very fundamental democratic principles, so it would seem. Initially the wishes of many communities were reflected in their local councillors¹ decisions to refuse

COM/S2/05/9/3

Annex B planning permission for the erection of TETRA masts. Those wishes were then thwarted by a central Fife committee, the Environment & Development Committee, which took control and approved those planning applications, contrary to the wishes of the communities and their elected representatives. As I have received no information from Mr. Birrell about the Council¹s complaint procedures regarding the above, I would be grateful for some clear guidance on how I may use whatever complaint procedures are in place. I feel you should know that there are many of us in and around Pittenweem who remain deeply unhappy about the Council’s role in siting a TETRA mast so close to peoples¹ homes and to the Primary School. Judging from the response we had from local residents and visitors to the petition referred to above, the concern is shared by an overwhelming majority of Fife citizens Yours sincerely, Adam Alexander East Neuk Campaign Against Tetra