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MOA (Mast Operators Association)
TRAFFIC LIGHT SCHEME

The main documents that relate to this briefing are the MOA Traffic Light Scheme
and its associated Site Selection Procedure and the operators Ten Commitments.
That site has links to the MOA documents on the TLS and its implementation.
Planning Sanity comment on most of these below.

MOA is the effective trade organisation for the Mobile Phone Operators, whilst MOA hold no real power or ability to control the operators, they do handle most of the operators wider public relations, part of that process was the compiling and promotion of the so called Ten Commitments and the Traffic Light Scheme (TLS), which they state is an instrument to weedle out those installations that fail the test in the Ten Commitments. Reality is something different, experience demonstrates that the Ten Commitments is only used when it suits the operators in any PR exercise, and as justification to politicians not to introduce greater statutory controls.

Planning Sanity wants to see a statutory process introduced, as opposed to the present scheme that is voluntary and arbitary in nature, and which has no appeal structure. However, many of the so called commitments are actually mirrored within Government Guidance, and with a slight of hand we can nearly turn those commitments ito a statutory framework by which a case can be madeout that if the operators do not follow the processes then the Local Planning Authority (LPA) would be justified in refusing permission.

So first let us look at the Ten Commitments, then the Government Guidance to see how close we get to a statutory provision though the back door. However, we need concrete evidence of how the various operators are implementing the TLS and Ten Committment Schemes, and whether on the ground issues raised by you, as members of the public have been seriously taken on board, as well as whether the findings of the TLS have been submitted with planning applications, and what degree of consideration did the LPA attach to them. Any such info should be sent to info@planningsanity.co.uk.

MOA have produced a booklet titled Working with the Community - Handbook on Mobile Telecoms Community Consultation for Best Siting Practice (PDF doc). We do not support the contents of the booklet, but provide the link as a means of research in order that you are able to understand the tactics used by the Operators in persuading local communities that their systems are safe. Also keeping in mind that irrespective of the issues raised in various briefings on the Planning Sanity WEB site we make no comment as to whether there is, or is not, a health risk, only that in our view, and for planning purposes, until all research is completed and the matter is finally settled by the scientific community a precautionary approach to site selection should be adopted.

The Ten Commitments have had an update, this was work carried out by a company paid by the operators to review the documents. Some campaign groups participated in this process. Both Mast Sanity and Planning Sanity after much debate declined to take part, on the grounds that we are in the first instance opposed to the voluntary scheme, and from past experiences of activists working with the operators and the predecesor of MOA we were concerned that our participation would be used as justification, and thereby lending legitimacy to a procedure we are opposed to. Those who want to read the Dolette and Touche Report may do so here. (PDF file)

Number
MOA Commitment
Planning Sanity Comment
1 IMPROVED CONSULTATIONS WITH COMMUNITIES
Develop, with other stakeholders, clear standards and procedures to deliver significantly improved consultation with local communities.
Where consultation does take place this is more akin to a PR exercise aimed not at genuinely taking onboard the concerns of the community, but instead of persuading that community that in their view the system is safe, that clearly is NOT consutation.

There is a three tier process of consultation set out in PPG8, the first tier involves the operator consulting with the LPA on the annual pre-role out of installations within that authorities area. The pre application consultation that is supposed to take place with the operator statutory and none statutory organissations such as the LPA, schools and residents groups. And finally the statutory consultation of the planning process. There is a clear argument in light of these obligations for stiffing up the consultation processes to make them mandatory, it is but a little step to take them from obligatory to mandatory

2 DETAILED CONSULTATION WITH PLANNERS
Participate in obligatory pre-rollout and pre-application consultation with local planning authorities.
The same comments could be made out as in Commitment 1. There is an obligation to consult within two of the processes with the LPA, the pre-roleout and the pre-application. However, even if they were not made mandatory there is a strong case to make them more transparent and open to inspection by the public.
3 SITE SHARING
Publish clear, transparent and accountable criteria and cross-industry agreement on site sharing, against which progress will be published regularly.
This is the greatest joke of all, it is rare for mast sharing, except when that is the only option available, as opposed to an active attempt to achieve it. The simple answer is to abolish the present system, put in place a national grid of installations that all operators have access too, in that way up to 80% of masts could be removed. This would in the long term be more cost effective for the operastor, more easily controled by the Government through licence fees and access fees, whilst reducing the numbers of communities destroyed by not a single mast but many serving not only the system operators, but the service industry that have their own systems, the emergency services, and so forth, just a little thought, and a lot less cash than is being spent at the moment could achieve this.
4 WORKSHOPS FOR COUNCILS
Establish professional development workshops on technological developments within telecommunications for local authority officers and elected members.
Workshops in various forms are actively participated with Councils, however, the quality of these presentations are not exactly in the top leaque, those where Planning Sanity and Mast Sanity have participated have resulted infrequently in the representatives of MOA and the Operators having to be corrected, or answers given by Planning Sanity representatives as MOA and the operators cannot answer the point. There is then a sound case for joint presentations in order to put a fair balance on the issues involved, as well as addressing the technical and legislative provisions from the perspective of all parties. There can be nothing worse than a mis-informed decision maker, who due to that mis-information goes on to make poor quality decisions.
5 DATABASE OF BASE STATION SITES
Deliver, with the Government, a database of information available to the public on radio base stations.
Whilst this is one element of the Commitments hat Planning Sanity supports, the quality of the service at the point of delivery to the public is very poor. The database is constantly up to 6 months out of date, many installations that by pass the planning process are not inclued at all, as well as some other forms of installations such as the system being developed by Network Rail. The whole process should be mandatory, with stiff fines when information is not supplied, or inaccurate information is supplied. Although with the intruction in the Communication Act 2003 of an obligation on OFCOM to require registration of sites, the situation might improve.

The quality of the information should also be improved, for instance giving information on the beam of maximum intensity, the direction and range of the beams, the angle of the downward beam, are just some illustrations of useful information that should be available and be able to be included without too much difficulty.

6 COMPLIANCE WITH ICNIRP PUBLIC EXPOSURE LEVELS GUIDANCE
Assess all radio base stations for international (ICNIRP) compliance for public exposure, and produce a programme for ICNIRP compliance for all radio base stations as recommended by the Independent Expert Group on Mobile Phones (IEGMP).
ICNIRP is so discredited, it is over ten years out of date, some countries like Russia have emission levels of a fraction of the ICNIRP levels, but more importantly they do not take into account the biological effects of emissions. Nor do they take into account effects on sensitive electronic equipment such as pace-makers.
7 ICNIRP CERTIFICATION
Provide, as part of planning applications for radio base stations, a certification of compliance with ICNIRP public exposure guidelines.
The ICNIRP certificates are far too often used as an excuse for not giving due consideration to public concerns on phone masts despite the repeated observations of the courts to the contrary. The ICNIRP certificates in real terms are no more than an indication, and are not a brick wall to taking health concerns into effect, to do so would fetter the obligation of the decision maker to fully take the publics concerns into accout. Therefore the operators should look to other means of justifying their developments.
8 PROMPT RESPONSES TO ENQUIRIES
Provide specific staff resources to respond to complaints and enquiries about radio base stations, within ten working days.
This rarely occures, often operators even refuse to talk to local communities, and when they do they either send a PR person to talk to the public or send a standard letter that fails to address specific questions asked of the operator.
9 SUPPORT RESEARCH INTO HEALTH AND MOBILE PHONES
Begin financially supporting the Government's independent scientific research programme on mobile communications health issues.
The operators paid 24.5billion for the licences for G3, yet collectively only 15million has been put into research, which quite frankly is a waste of money. Real funding needs to be put in place of at least 20% of the licence fees, 50% by the Government and 50% by the operators raised through a tax on the calls made, a failure to undertake this level of research will assuredly never answer the questions on health, they will not find alternative processes that are safer and at some stage or another we will be faced with yet another crisis on a par with BSE or Asbestos.
10 STANDARD DOCUMENTATION FOR PLANNING SUBMISSIONS
Develop standard supporting documentation for all planning submissions whether for full planning or prior approval.
Standard documentation for planning permissions is the worse suggestion that could be made. Applications should be determined on the criteria that applies to each individual development, you cannot cater for a single standard. Issues that must be considered is the effect of the topography, the local weather patterns, the angle and extent of the beam, the closeness to residential property and other sensitive locations. The effect on wildlife and farm stock, the visual effects and a 1001 other individual reasons that need to be assessed through the individually tailored application.

(c) Planning Sanity - July 2004 (can be freely used by local communities within their campaigns. Publication by third parties is permitted providing acknowledgement of Planning Sanity is given)

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