Appeal No. APP/P1615/A/01/1065956

1. My name is Mrs Frankie Evans. I submit this proof of evidence in support of the case against the Appellants application to site a telecommunication lattice tower and ancillary equipment at Littledean Reservoir, Cinderford, and as a consequence of the Order of the Secretary of State and the requirements contained in Rule 8 of the Town & Country Planning Appeals (Determination by Inspectors) (Inquiry Procedure) (England) Rules 2000.
2. I give this evidence, and such other oral evidence that I may give, solely as that of a concerned mother of a 12 year old child, and not as a consequence of any qualification, and the reports, statements and other documents submitted with my Statement of Case and this Proof of Evidence that are not specifically stated to be within my own knowledge and academic ability are to be taken as being attached to the qualifications of the respective original authors of such reports, statements and other documents.
3. I am Joint Co-ordinator of Mast Action UK (MAUK) Gloucestershire. Which includes co-ordinating and advising local residents within Cinderford on issues relating to Phone Masts, in particular those for the TETRA system. Along with many members of the local community I have grave concerns for the health of all who live work and visit the area, and parents of school age children in Forest View School and Heywood School.
4. I have read many of the reports and official documents relating to the TETRA system, and am of the firm view that insufficient information is available to conclusively state that this system is safe. However, I would go further than that, and state that the evidence available in the public arena is such as to indicate that there is a greater chance of an adverse health effect, both from the installations and the communication devices, than there being no such risk. This is demonstrated in the reports by Barrie Trower (Appendix 'A') and Dr Gerard Hyland (Appendix 'B').
5. I am specifically concerned that the effect of the emissions from this mast will in common with emissions from high powered cable cause children to be at a greater risk of being susceptible to contracting Leukaemia, and other ill effects, than they would if the installation was not installed. Whilst that research was conducted specifically to measure the effects of high powered cables, it nevertheless reflects the concerns I have for the health of the community, especially as the Government and the same source of this admission the NRPB had spent many years denying any such link. A denial that the NRPB are now stating in relation to the similar effects from TETRA, and other forms of telecommunication installations.

1. I specifically refer the inquiry to the Report dated September 2001 by Barrie Trower for the Police Federation, where he explains at para 2 page 2 "the basic principles of the effects of radio waves …namely radio, TV and waves from overhead power cables. All of these waves have the same properties; that is to say they all behave the same". I see this statement, I then see the statement of the NRPB which leads me to firmly believe, especially as they are the body charged by the Government with policing the levels of emissions that waves similar to those that they claim do increase the risk of leukaemia in children. I can find no evidence to dispute that simple statement of Barrie Trower. Therefore from the evidence of the NRPB I now hold a real and tangible fear that the communities health is at risk from the proposed installation. Even if this risk is very slight (we do not have conclusive evidence of the level of potential effect), it nevertheless is in my mind, a real risk.

'Possible Heath Effects from Terrestrial Trunk Radio (TETRA)' Report of an Advisory Group on Non-ionising Radiation Vol:12 No. 2 2001:

1. I would like to refer the inquiry to the list of health effects caused by long-term low level electromagnetic radiation found between pages 8 and 15 of Barrie Trower's Report (Appendix 'A'), along with the effects set out in the BMA report (Appendix 'C') and those listed in the book by Dr Richard Lawson 'Bills of Health' (Dr Lawson is a family GP with a practice in Congressbury Devon) (Appendix 'S').
2. As a lay person without the expertise required to make the necessary scientific analysis of the available data, much of which is conflicting, I must err on the side of caution where the health of the community is concerned. As is set out in the proof of evidence of Alan Meyer the Stewart Committee Report concluded that the Government should avoid the amplitude modulation of around 16Hz. If that is accepted then it follows that there are greater grounds for taking a precautionary approach to the installation of TETRA systems, than there are in other forms of telecommunication base stations. When referring to the precautionary principle I am relying upon the interpretation of the precautionary approach as set out in the Treaty of European Union (Maastricht, 1992) Title XVI: Environment, Article 130r:

Community policy on the environment shall aim at a high level of protection taking into account the diversity of situations in the various regions of the Community. It shall be based on the precautionary principles that preventative action should be taken, that environmental damage should be rectified at source and that the polluter should pay...

I would also refer you to the Friends of the Earth Scotland Briefing found at Appendix 'YY' page 6 of that document:

"European Legislation/Treaties: The UK already has an obligation under the Maastrict Treaty 1993 (Article 130r) to take a precautionary approach and this was re-inforced more specifically by a recent European Parliament recommendation, 1o March 1999, which stated that people living in member states should be protected from the "potentially harmful long term effects" of electromagnetic fields, as generated by these transmitter masts".

 

3. In this respect I would again refer you to the explanation put forward by Barrie Trower, where he explains at page 21 of his report that contrary to other forms of health checks for products related to the pharmaceutical industry who have to prove something is safe before use, with TETRA the opposite applies, and therefore in my submission this is contrary to the precautionary principle, that the Government subscribes to.
4. Paragraph 89 of the Appendix to the August 2001 version of PPG8 Telecommunications, states that:

"the possibility of harm cannot be ruled out with confidence and that the gaps in knowledge are sufficient to justify a precautionary approach"

It is my contention that the specific precautionary approach advocated elsewhere in PPG8 and in the amendments to the Town & Country Planning (General Permitted Development) Order 2001 are not sufficient to soothe the public's perceptions of a risk to public health, indeed the inconsistencies in parts of PPG8 might increase the public's feelings in this regard.

PPG8 states at para 29 (and I go into this in more detail below) that:

"Health considerations and public concern can in principle be material considerations…"

It then goes on to say:

"It is for the decision-maker (usually the local planning authority) to determine what weight to attach to such considerations in any particular case".

It is my case that is exactly what the Planning Committee has done in this instance. The fact that the following paragraphs in PPG8 then seek to severely confine that consideration is unrealistic given the nature of public concern. If public concern is capable of being a material consideration then it must be capable of constituting a reason for refusal.

5. Paragraph 29 of PPG8 was added as a direct consequence of the ruling of the Court of Appeal in Newport County Borough Council v The Secretary of State for Wales and Browning Ferris Environmental Services. Coupled to other cases such as R v Tandridge District Council exparte Mohamed Al Fayed and the Case of Hatton and Others v. The United Kingdom (ECHR Application no. 36022/97).
6. Whilst we argue that it matters not if the guidelines are broken, if fear is a material consideration then, it is a material consideration whatever the emission levels. However I put the case that the question of health effects and whether the proposals exceed the ICNIRP guidelines are limited to those effects that are measured by the guidelines (thermal only) and not issues relating to the biological effects, or the mental state of the local community resulting from the fear expressed by the community, and other issues relating to emissions not covered within the criteria that the ICNIRP guidelines are based.

Trade and Industry Minutes (Appendix 'E') paragraph 8 of Sir William Stewart's evidence:

"There are two issues. One is that the ICNIRP guidelines refer, in particular, to the heating effects. The question is that there is some evidence that there are non-thermal effects and because of that, advocated a precautionary approach. This is new technology in recent times. The question is: are we confident that everything that is going on at the present time is safe? The evidence that we have elucidated suggests that there is sufficient concern to adopt this precautionary approach".

Paragraph 9: Mr Chope

"You think there is sufficient concern to adopt the precautionary approach in relation to ordinary mobile phone technology and you would say even more strongly that should apply to the issue of the police airwave system".

Sir William Stewart:

"I am pretty sure that it will become a major facet of any future investigation. As far as our report was concerned, the timing was not right".

7. Whilst it is our primary case that the local community do not have to go on to demonstrate anything more than the fear they hold, nor do they have to present any evidence as to whether there is or is not a provable link between the proposed installation and an adverse health effect. It is also our case that there is little or no research that has been produced (at least into the public domain) that categorically demonstrates that there is no harm from the specific emissions created by the TETRA system:

Police Magazine March 2001 - (Appendix 'SS')

"In total, around the world, there appear to be six small studies into TETRA signal bio-effects, five using cell cultures, and one using live hamsters. Only one of these studies is published in a scientific journal. No human safety work has so far been done using TETRA signals. The COST 244 bis report on the 'Possible Health Effects Related to the use of Radiotelephones', funded DGX 111 of the European Commission, merely mentions TETRA in a list of systems and makes no comment about it".

 

8. The best statements available are that there is no risk to the 'general' population, as opposed to the population, indicating that there is a risk to an element of the population, but possibly not every member of the population. As such it is my case that no reasonable decision maker could conclude on the available evidence that there is 'no' risk to health. This is set out clearly by BT Cellnet in its memorandum to the Trade & Industry Committee of the Commons (Appendix 'E') paragraph 9 (page 50 of the report) which states:

1. The report by Barrie Trower was commissioned by the Police Federation and points to a range of potential adverse health effects in particular those listed at page 20 of that report states:

Two recent surveys printed in Electromagnetic Hazard & Therapy 1998, Volume 9 and 2000, Volume 11; the first of a study of 11,000 mobile phone users, the second a study of 17,000 mobile users showed the symptoms already mentioned of fatigue, headache, warmth behind the ear, warmth on the ear and burning skin in various degrees, depending on the use and type of person. From the 17,000 persons studied, these symptoms varied from 31% to 78% of the users.

A news article in the Sunday Times on the 14^th January 2001 'Scientists Link Eye Cancer to Mobile Phones' by their Science Editor Jonathan Leake states Appendix 'WW':

Mobile Phones have been linked to human cancer for the first time. The research suggests there is a threefold increase in eye cancer among people who regularly use the devices. …. It investigated a form of eye cancer called uveal melanoma, in which tumours form in the layer that makes up the iris and base of the retina.

The research was carried out by Dr Andreas Stang and reported in the Journal 'Epidemiology'.

2. A local resident of Stockport has been granted leave to apply for judicial review (R. v. Stockport MBC exparte Smith) in order to clarify the perception of an adverse health effect in specific relation to phone masts. In granting leave The Honourable Mr Justice Ouseley stated:

'It is arguable that actual and perceived health risks are relevant to siting of these masts, and that the latter was not taken into account'.

This clearly indicates that the court will (if the circumstances of the case merit it) grant leave for judicial review where health is not taken into account, or potentially is not fully taken into account.

3. It is our case that the Stewart Report points over and over again to instances of concerns of potential risk. Para 1.16 sets it out clearly, that there is little research and little published scientific evidence, this fuels the fears of the public. And that is what the perception aspect is about, it is not about some provable link, merely the fear caused by there being no scientific evidence either way.

Trade and Industry Minutes paragraph 22 of Sir William Stewart's evidence:

"I want to emphasise something else that we considered. First, the BSE inquiry impacted upon us. Never again will any scientific committee say there is no risk".

We have been reassured on many occasions relating to the potential adverse health effects on major issues, only then to have these reassurances seen to be unwisely given, such as Asbestos, Thalidamide, BSE Variant CJD…….. .Lloyds of London are now paying out millions of pounds in compensation for Asbestosis - Financial Mail on Sunday 20^th January 2002 'Asbestos Claim Shock for Insurer'.

4. The Stewart Report put it into context when referring to adverse health effects, by pointing to the stress suffered by the local community, caused by the fear of the unknown, rather than the actual radiation. It is this same aspect that Lord Aldous was referring to in the Newport case, albeit that case was related to waste incineration, rather than the effects of EMF emissions. It is therefore my case that I do not have to go so far as proving an actual health link, only the psychological effects of not knowing whether there is, or is not, an adverse health effect, and this has been more than demonstrated, by the written submissions (both to the LPA and the Inspectorate) of members of the public, and the various academic reports, and news articles. It is clearly set out in point 26 of Sir Williams evidence:

"The argument that has been put to us, not in relation to computer screens, but in relation to microwave ovens, is that you have a choice about using a microwave oven and you have a choice about using a computer but you do not have a choice on whether a base station is stuck outside your house or not".

5. An article by Matt Youson in the magazine 'Engineering' (February 2001) (Appendix 'P') sets out what he describe as a 'well reported case' that a man suffering from a heart attack being rushed to hospital died after the ambulance crews TETRA radio affected the ambulances equipment. This effect upon life saving equipment is catalogued elsewhere, particularly in the Article in the Police Federation Magazine 'Police' (Appendix 'H') which sets out that police officers were advised not to use equipment in or near accident and emergency units. And by the effect on other forms of electronic equipment such as the incident in the Manchester Evening News found at (Appendix 'J') where car locking systems were affected by TETRA emissions at the Trafford Centre. The AA stating that they were aware of a further 24 such locations where this was known to have happened. This incident came about despite the industry being aware of the problem since 1999, and having set up a special research project to address the problem called 'RAKE' (see Appendix 'P' Static and Silence page 2 para 3):

"A committee called RAKE (Standing for Remote Keyless Entry) was established to find a solution to the problem of radio-key interference. Rake counts amongst its members the Low Power Radio association, the Society of Motor Manufacturers and traders, the AA, the RAC, the European Vehicle Seurity Association, the Motor Industry Research Association (MIRA), the Police Scientific Development Branch, the Radio Society of Great Britain and the Radio Communications Agency. …… but as John Pope. Leader of the Electronics Group at MIRA , explain "……The TETRA mobile communications system operates at an adjacent frequency to that used by remote keyless entry systems, so that if you park your car near one of these transmitters you may not be able to lock it or even worse, get back into it".

6. These latest incidents clearly demonstrate that the problem has not been resolved. But in any event the problem is attempting to be resolved not by making the TETRA system safer, but by suggesting that key fob manufacturers alter the design of their products. Illustrating the inability to ensure that even a simple item such as a key fob cannot be made safe from TETRA without altering the design and frequencies of other equipment. This means that potentially billions of pounds could be spent by industry trying to resolve the cost forced upon them by the introduction of this flawed and unsafe system, not just in relation to key fobs, but any industry that uses equipment that could be affected by radio frequencies, thereby having a profound effect upon the economy. At present it is a requirement that mobile phones (GSM) are switched off at petrol filling stations.
7. These and other incidents demonstrate that the fears that members of the public have are not necessarily restricted to actual physical effects, but may be the fear of the effect upon vital life saving equipment, or even other ways that could endanger life by the failure of electronic equipment to work correctly, thereby causing accidents resulting in injuries or even death. I reiterate here that this is a view I hold based solely upon the reports compiled by others. As I understand it both heart pacemakers and hearing aids can be affected, and I would like to point out that a public footpath runs adjacent to the site, and as such could put members of the public at risk.
8. Concern also has to be raised that not only Police Officers but members of the public are being put at risk from the use of TETRA hand sets. Barrie Trower states at page 38 of his report that he is aware of at least 4 deaths from the carrying of handsets on the belts of officers from cancer of the spine from existing equipment, which highlights the potential problems with the introduction of the new TETRA handsets. Other reports indicate potential risk to women officers from cancer of the breast (The Sunday Mirror on the 6^th May 2001 reported two cases of women officers having suffered from breast cancer from the constant possible exposure to existing handsets (Appendix 'AA'). Whilst Police Officers are naturally at greatest risk due to the constant exposure they are subjected to, nevertheless it is my submission that it is at least arguable that members of the public are at risk every time they are in close proximity to a police officer. The question then has to be raised will the handsets affect sensitive equipment. From the information contained in the reports by Barrie Trower, the BMA and the Medical Devices Agency which suggests that such equipment is likely be affected (at least up to a distance of 1m). My concern here is for that of young children who will be at greater risk than adults due to the norm of police officers carrying their radios at waist height, thereby effectively beaming emissions directly at the heads of children every time they pass close to a police officer.

The Executive Summary of the Medical Devices Agencies report (Appendix 'T') states:

"Overall, in 23% of tests medical devices suffered electromagnetic (EMI) from handsets. 43% of these interference incidents would have had a direct impact on patient care, and were rated as serious.

The type of radio handset made a difference to the likelihood of interference. At a distance of 1m; 41% of medical devices suffered interference from emergency services handsets, 35% suffered interference from security/porters handsets but only 4% from cellphones".

In the majority of hospitals ordinary mobile phones are required to be switched off at the present time. This will be more crucial with the TETRA handsets.

9. The installation is close to two local schools, one of which has a nursery section with young babies. It is my understanding that the advice from leading academics including the Sir William Stewart that no beam of maximum intensity should fall on any part of a school grounds. It is my case that the operator should demonstrate in clear terms that no beam of maximum intensity will fall on any part of a school grounds. To the best of my knowledge the Operator has failed to release the coverage maps into the public domain. Similarly I am not aware of any evidence being presented demonstrating that the beam of maximum intensity will not fall on any part of the school grounds. Albeit the requirement not to allow such beams of maximum intensity to fall on any part of a school grounds has not been carried through from the Stewart Report into PPG8, there is nevertheless clear indications that it is the Government's view that such a requirement should be put into practice. Indeed the previous Planning Minister Nick Raynsford stated in a media release dated 16^th March 2001 (Appendix 'PP')

"Gaps in scientific knowledge led the Group (Stewart Group) to recommend a precautionary approach to the use of mobile phone technologies, comprising a series of specific measures, until more research findings become available. We agree with this approach".

The Government then went on to issue a response to the Stewart Group Report (Appendix 'QQ') at 3.7 of that Response they set out:

"The Government accepts the conclusions of the risk assessment of mobile phone technology set out in the Stewart Group's report".

Paragraph 4.1

"The Government accepts the recommended precautionary approach advised by the Stewart Group….."

The Stewart Report dealt with a precautionary approach in some detail within their report, see Section 6 (Appendix 'L'). Whilst this whole section deals with the precautionary approach the important paragraphs are 6.38:

"There is now scientific evidence, however, which suggests that there may be biological effects occurring at exposures below these guidelines".

Paragraph 6.39:

"We conclude therefore that it is not possible at present to say that exposure to RF radiation, even at levels below national guidelines, is totally without potential adverse health effects, and that the gaps in knowledge are sufficient to justify a precautionary approach".

Paragraph 6.40:

"In the light of the above considerations we recommend that a precautionary approach to the use of mobile phone technologies be adopted until much more detailed and scientifically robust information on any health effects becomes available".

Paragraph 6.41:

"On its own, adoption of the ICNIRP exposure guidelines will not allow fully for the current gaps in scientific knowledge, and particularly the possibility of, as yet, unrecognised thermal or non-thermal adverse effects at lower levels of exposure. One way in which this uncertainty could be taken into account would be to apply a higher assessment factor in the derivation of the exposure guidelines. This would have the merit of simplicity. However, as yet, there is no satisfactory scientific basis on which to set the size of any increase".

Paragraph 6.44:

"We believe this approach is not optimal since it does not allow adequately for the uncertainties in scientific knowledge. Although it seems highly unlikely that the low levels of RF radiation from base stations would have significant, direct adverse effects on health, the possibility of harm from exposures insufficient to cause important heating of tissues cannot yet be ruled out with confidence. Furthermore, the anxieties that some people feel when this uncertainty is ignored can in themselves affect their well-being".

From this it can be seen that the requirement to consider the precautionary principle is at the backbone of Government policy. Indeed paragraph 89 of the Appendix to PPG8 states:

"The Government's acceptance of this precautionary approach is limited to the specific recommendations in the Group's report and the Government's response to them".

 

Study of a number of London locations (as set out in the RA Site Finder Database) Powerwatch questions the validity of the statement contained in para 100 of the Appendix to PPG8 (Appendix 'RR'):


"Mobile phone operators already keep their RF power outputs to the lowest possible levels commensurate with effective service provision"


From the data on the Radio Communications Agency 'sitefinder' database, this is clearly untrue in some places.

For example, in a sample half square mile of central London, bounded by Euston Road, Oxford Street, Baker Street and Tottenham Court Road, we find the following low height (3 to 9 metres above street level, mostly between 4 and 6 metres) base stations:
One2One: - no low height base stations (all on the tops of buildings)
Vodafone:- 73 low height base stations (Minimum 2 W, Typical 5 Watt, Maximum 5.2 W)
Cellnet:- 65 low height base stations (Minimum 2 W, Typical 5 Watt, Maximum 16 W)
Orange:- 17 low height base stations (Minimum 71 W, Typical 132 Watt, Maximum 339 W)


Report by Alasdair Philips (Appendix 'DD')

The Stewart Report 'Advice to Government' includes [numbers are from the Report]

"[1.27] We recommend that, as a precautionary approach, the ICNIRP guidelines for public exposure be adopted for use in the UK rather than the NRPB guidelines".

"[1.36] We recommend that for all base stations, including those with masts under 15 m, permitted development rights for their erection be revoked and that the siting of all new base stations should be subject to the normal planning process".

"[1.41] We recommend that particular attention should be paid initially to the auditing of base stations near to schools and other sensitive sites".

"[1.43] We recommend that in making decisions about the siting of base stations, planning authorities should have the power to ensure that the RF fields to which the public will be exposed will be kept to the lowest practical levels that will be commensurate with the telecommunications system operating effectively".

 

That being the case, it can be seen that wholesale abuse of the emission levels is taking place, and clearly the policing of emissions is not being effective, yet the assumption on the grant of permission is that this is taking place, and that permission is only granted if the guidelines are to be kept, thus the need for a certificate to that effect. That is not happening therefore the supply of a certificate in it self is offering no guarantee that emission levels are not going to be broken.

10. Nothing in my submission could be clearer the recommendations that I set out above are to be taken into account in the decision making process. PPG8 paragraph 29 making it even clearer that health is a material consideration. It makes it clear that the decision-maker must consider what weight should be attached to the fear held by the local residents that this installation will cause them and their families to suffer adverse health effects from the emissions that will be emitted. In my submission the weight of evidence before this inquiry is of such significant weight that it cannot be ignored, and once it is considered no reasonable decision-maker could conclude that this installation could be approved.

Tamino Proposals 25^th February 1999 - page 13 para 3 (Appendix 'FF')

"In view of the above, the rapporteur proposes that Member States should lay down minimum safety distances from public buildings, housing, and work places for the siting of electrical lines, radar and broadcasting and re-broadcasting transmitters, including cellular phone repeaters, and from domestic electrical appliances capable of generating electromagnetic fields".

11. Below I set out in detail relevant quotes from eminent specialists in their relevant fields, as well as references taken from official reports, some from Government Agencies and established bodies such as the British Medical Association. This evidence contrary to what may be intimated by other parties has been compiled, and peer reviewed by academics of the highest standard. Ranged against these reports are statements by interested parties, scientists that are employed by those within the industry, and others with a vested interest in the technology.
12. Paragraph 16 of PPG8 advises that reference should be made to PPG7 'The Countryside - Environmental Quality and Economic and Social Development'. Stating:

"In accordance with PPG7 high priority should be given to safeguard areas of particular environmental importance".

The Forest of Dean, which includes the application site, is considered by the LPA to be an Area of Outstanding Natural Beauty in waiting (see para 1.4 of the Statement of Case of the Local Authority). And as such has afforded the area the local status of Special Landscape Area, it therefore should in my submission be given greater consideration in terms of siting and design than areas without any form of designation.

13. Besides the normal visual aspects affecting the scenic value of the locality we invite the Inspector to consider the economic consequences of an intrusion into this special area. We believe that to be very much the case, one of the primary economic bases for the County as a whole, and in particular the Forest of Dean, is tourism. This ugly proposed new installation will adversely affect the character of the area, therefore it is arguable that the scenery will be less attractive, and as a consequence fewer tourists will be prepared to visit the area, and therefore the economy will see a downturn. One of the primary arguments of telecommunication system operators is that if the developments are not allowed to be completed then the country will suffer an economic consequence. If that is the case, and I argue that this is not so in the case of TETRA (as there is no economic consequence from the use, as it is not a commercial development), then equally consideration must be given to the effect on the local economy, that is already suffering as a result of the Foot & Mouth outbreak, will be devastating. However, even if as we argue there is no economic plus for the development, I argue that the consequences for the local economy is still a valid material consideration that must be taken into account. Those wishing to purchase property, choose a school and leisure and holiday pursuits may well look to the RA Site Finder database, discover that their proposed new home is close to a telecommunication installation and decide that they will not put their families at risk. This will have a devastating effect that will potentially see 'no go areas', where there is a down turn in amenity value with all the knock-on effects this will cause for the locality as a whole.
14. A growing number of HM Planning Inspectors have in recent cases concerning telecommunication masts included in regard to siting and location the need to ba1ance 'network need' against 'local amenity harm'. TETRA's can be at a considerable distance from each other (see proof of Alan Meyer - 56km) and still operate efficiently in a network, this is particularly so in this network area. BT Airwave puts across the argument that they are contractually obliged to provide 100% coverage, right across the country, this is not the case, as there are exceptions. Condition 24 of Part 'D' Exceptions and Limitations on Obligations, in Schedule 1 of the licensing agreement granted by BT Airwave. This recognises the difficulties of providing cover in sensitive landscapes by allowing BT Airwave the option not to meet its obligations if due to 'any physical, topographical or other natural feature'. The topography of the area of the application site is such an area, where this exclusion clause could very well be brought into play.
15. Whether it is due to restrictions that local authority officers have placed upon the release of information or whether it is a case that the Operator has failed to supply sufficient information I am unable to say. However, as of the date of this proof I have not seen any documentation, which demonstrates, that the installation in the proposed location is required to the degree set out in legislation. It is my case that the operator must show much more information than has been readily available to the public. They must demonstrate that the sites in question, and only the sites in question, will fulfil the required degree of coverage, in clear and precise terms. Nor do we accept the argument being put forward (at least in other areas of the country, which I also believe to be the case here) by BT Airwave that this information should be excluded from the public on national security grounds.

I attach at Appendix "BBB" copies of correspondence, and statements of case for the Torbay District Council and BT Airwave, which demonstrates that unless forceful representation is made these coverage plans will not be released into the public domain. This is demonstrated in the present case by the absence of the doocuments so far placed before this inquiry.

16. It is our case that the failure to provide information on coverage directly conflicts with our rights under Article 6.1 of the ECHR to have equality of arms, as well as the dicta from Common Law that 'Justice must not only be done, it must be seen to be done'. Mr Alan Meyer in his proof of evidence deals with the question of violations under the Convention. It is thought useful to raise this here to emphasise the inability of the public to adequately address the question of coverage if, as I believe it to be the case, the Appellant fails to provide the required degree of information. In our argument on this question, if we are right that the information is not in the public domain, then we would go as far as saying that without this information being made publicly available then the Inspector can only conclude that he does not have the required degree of information available in order to make a lawful decision, and therefore must reject the appeal.
17. Questions that must be answered in that respect as to what is the coverage from existing installations, what will be the effect with and without the proposed installation. Once this information is available it will then be a simple case of testing this against other potential sites, masts, structures and buildings to ascertain whether there are other more suitable locations, away from the two schools and residential areas. As well as questions of whether indeed this site is required to get the degree of coverage required within the proposed coverage area of the installation.
18. It follows from this that the question of the need and coverage must be looked at in detail, unfortunately as the Appellant has chosen not to put into the public domain the coverage maps and information we cannot comment further, other than to state that it is my view that as this vital information has not been made available, then I, along with all other members of the public, and organisations I am being prejudiced in the case I can present to the inquiry.
19. It is our case that the criteria set out in Annex 1 para 13 of PPG8 which lists factors that may involve siting should be applied to full planning applications, although this section specifically relates to the prior approval process, all these criteria are relevant:

• the height of the site in relation to surrounding land;

• the existence of topographical features and natural vegetation;

• the site when observed from any side, including from outside the authority’s own area;

• the site in relation to areas designated locally for their scenic or conservation value;

• the site in relation to existing masts, structures or buildings, including buildings of a historical or traditional character;

• the site in relation to residential property;

• any other relevant considerations.

1. I have a fear for the wildlife, cattle, horses and domestic animals, from the radiation travelling across the surrounding fields to the TETRA mast. And the threat that its effects could turn the surrounding land into an effective wilderness. And the complete lack of security people will feel in their own homes where radiation could penetrate any of the roofs or walls and cause health damage 24 hours a day. As well as affecting everyone's enjoyment of jogging, riding, sport and walking dogs on the local recreational land, this severely damages residents' sense of amenity and quality of life. Special reference should be made to the number of footpaths that criss cross the area, and the potential effect on those using all these facilities.
2. In November 2001 British Telecom de-merged Airwave together with two other elements of the company into a new firm MMO2. Financial analysts predicted from this point, and continue to predict that MMO2 will be the subject of a buyout. Police authorities for each area have been asked to sign new contracts by PITO, the Home Office's Police Information Technology Organisation. It is not known how many have still to do so. To date potential buyers predicted have included Italian, Spanish and Far Eastern telecommunications companies. Given current and potential circumstances, along with many Cinderford residents I have no confidence in the safe and professional monitoring of the proposed - considerably more powerful installation. The prospectus for the demerger makes it clear that not all the emergency services have signed up to the TETRA system.

BT Airwave Prospectus - re demerger (Appendix 'LL')

"Airwave also has the opportunity to generate further revenue on a competitive basis, from other public safety users such as fire and ambulance services".

Network News 31^st January 2001 (Appendix 'O'):

"Jeff Parris General Manager of BT Airwave Division, said that unless Ambulance and Fire Services sign up Airwave would 'not be sufficiently profitable to be worthwhile'. Network News revealed in December 2000 that Airwave might lose the Fire Service as a potential customer, when it uncovered the fact that TETRA hand sets spark and cannot be used in explosive situations".

3. Mr Alan Meyer will deal with issues relating to planning legislation and the consequences of the European Convention on Human Rights, as well as issues resultant from the UK's obligations under the Maastricht Treaty. However there are a number of local planning policy issues that I will deal with here. The proposal conflicts with Regional Planning Guidance 10 The South West. In particular policy 5.21 which sets out that telecommunication installations due to the large extent of areas of high quality landscape and environmental sensitive areas it is important that the location and design of equipment for these sites gives adequate regard to their surroundings and potential impact, in particular the policy is to 'promote the choice of location of sites and design of necessary equipment that has regard to local environmental and amenity considerations'. Other policy areas for consideration are 2.1; 2.6 and 3.80.
4. The proposal conflicts with the Gloucestershire Structure Plan Second Review (Adopted Plan) policies NHE2; NHE5; & TEL1. Areas of local authority policies that the proposal will conflict with are policy FC.10; FCL.1 and FBE.2. And policy (R)FBE.16 of the First Deposit Draft Local Plan. The points in relation to the effect of these policies are set out in the Statement of Case of the Forest of Dean and I rely upon the comments set out in that document as justification that the proposed installation does not conform with the Draft Local Plan.

EMERGENCY SERVICES 'NEED' FOR THE TETRA SYSTEM

5. Please refer to newspaper cuttings from the national and regional press - And the technical communications industry weekly Network News which support the following points.

 

 

POLICE FEDERATION

6. The Police Federation were alerted in January 2001 to possible health risks for their members in using TETRA handsets (accepted as up to 50% more powerful than mobile telephones) and in-vehicle equipment, which is also highly bio-active, by Channel Four News journalists and Radio Four reporters (You and Yours) seeking their comments on the health risks from the system - operating as it does on 17.6Hz so falling into the area which former Government Chief Scientist Sir William Stewart and his committee urged be avoided for health reasons in their May 2000 report. Sir William re-iterated this warning in March 2001 to the Trade and Industry Select Committee {see document point 5) when he described TETRA as 'a hazard' because it operates in dangerous proximity to 16Hz.
7. They had already been alerted by police in Jersey who had been undertaking trials of TETRA there, and by The Times reports of the Jersey Police findings of serious interference with police and hospital equipment (refer to Network News January 2001).
8. The Po1ice Federation Chairman Mr Fred Broughton started asking question in January 2001 of the Home Office about the safety of equipment on behalf of his members in January 2000. The first answers over any health risks came in the second week of December 2001, after the Federation had commissioned a report by independent physicist Barrie Trower (see Appendix 'A') examining and commenting on all the national and much of the international scientific evidence. After studying this report, Mr. Broughton and his fellow officers were so concerned by the strong likelihood of health risk for officers using TETRA that the Federation warned the Home Secretary Mr Blunkett that if satisfactory answers backed up by scientific evidence were not given to the organisation very speedily, members would be instructed to boycott TETRA. At the date of this proof of evidence (January 7^th 2002) to the best of my knowledge no answers had been given. Nor has any information been released that could be scrutinised by independent scientists, or other organisations with the requisite depth of knowledge of radiation.

The Network News in its Article on the 3^rd July 2000 entitled 'Police Fear TETRA Upgrade' (Appendix 'O') they quote Chief Inspector Ian Harrison of the City of London Police as saying:

"We are really worried about how we are going to pay for Tetra. It will cost about £1,25m a year to run, and this must come out of our already struggling budget. The old system is much cheaper".

"Police forces are being forced over to Tetra because the existing radio frequencies were sold off in the recent £20bn 3G bundle"

 

9. I attach as Appendix 'H' Articles from the in-house Police Federation Magazine detailing their concerns to their members, I also attach at Appendix 'I' the Police Federation Policy Statement on TETRA 'Airwave - The new police radio system'. I invite the Inspector to read these documents and to fully take into account the views of those considered being most at risk, our local police officers.

FIRE FIGHTERS

10. The Fire Service has also been approached by BT and encouraged by the Home Office to sign up for TETRA, tipped off by their Dutch counterparts, British fire-fighters tested TETRA and found the handsets put them at greater hazard than their existing, old system, handsets. That is because they sparked at the scene of a fire when fire fighters attempted to use them to call for help and report dangers. The men and women using them also found they had to remove their protective fireproof gloves to be able to operate the emergency button, and other controls - hence risking being badly burned. Hence fire fighters have informed the Home Office they will stick to their old handsets. ?

AMBULANCE SERVICE

11. It is my understanding that currently the union is considering advising members to reject TETRA since it is known to interfere with the safe operating of pacemakers, and much electrical equipment in ambulances.

QUOTES FROM INDEPENDENT SCIENTIFIC SOURCES:

12. Alasdair Philips: EMF bioeffects researcher, BSc Engineering, EMC Engineering, DAgE, MIAgE and member of Scientist for Global Responsibility and Founder and Director of Powerwatch Consultants and Publications.

"TETRA masts operate at a more concerning frequency than mobile phone masts. They give off high-level microwave transmissions at emissions 50% to 100% more powerful than mobile phone masts. Recent international research has shown that their frequency on 17.6 Hz is close to the frequency, which causes changes in the brain and interference with its beta-rhythm. No conclusive research has yet been done on the effects of these changes".

13. Sir William Stewart: Former Government Chief Scientific Officer, currently President of the Royal Society for the Advancement of Science, and Chair of the Stewart Committee on Mobile Phones and Health (which could not comment on TETRA when it sat two years ago because it was not then thought to be a mobile phone system. Now arguably since MMO2 is actively canvassing commercial clients to link up to TETRA and signing up mobile phone companies to add to their installations to TETRA masts, increasing emissions, that no longer applies and we call for the reconvening of the committee to examine all aspects of the Airwave System). In the conclusion of point 5.59 of the Stewart Report, May 2000 it states:

"AS A PRECAUTIONARY MEASURE the amplitude modulation around 16Hz be avoided".

Over a year ago I requested my MP Diana Organ to make representation on my behalf to the Right Honourable Nick Raynsford the then Minister for Planning to re-convene the panel (Appendix 'EE' Letter dated 15^th March 2001).

TRADE AND INDUSTRY COMMITTEE TENTH REPORT 'MOBILE PHONE MASTS' 27^TH MARCH 2001

Sir William Stewart responding to questioning about TETRA and the frequency of 17.6Hz which it operates, published in the Tenth Report of the Trade and Industry Select Committee (March 27^th 2001) asked about the TETRA amplitude modulation by:

Christopher Chope MP (point 4)

"Would you accept that is the most critical area where there is the highest risk ?"

Sir William

"We thought that was an area that should be avoided if at all possible. Clearly it has not been avoided".

Again when asked about TETRA's amplitude modulation (point 5):

"We did not focus particularly on the issue, but we pointed out that was a hazard".

Mr Chope MP (point 6):

"That is a hazard and the government are investing £2.5 billion on introducing a system that will adopt that frequency which you have identified in your report as being the most hazardous frequency".

Sir William

"That is a question for the Government and not for me".

(Point 2)

Sir William

"If you talk about health you also talk about well-being. When we went around the country, I was absolutely convinced that the well-being of some members of the population had been adversely affected by the erection of masts. We heard examples of masts appearing overnight; we heard examples of how some masts were going to be more than 15 metres high and then when they heard that they would need planning permission for that height, they reduced them to fourteen and a half metres. That cannot be right.

(Point 3)

Mr Chope

"I understand what you are saying, but are you also saying that if you do not like something near you there is a risk that it is detrimental to your health?"

Sir William

"No. I believe there are two points that affect the general population. One is that if you have a choice, you should give people a choice. People can choose whether to use a mobile phone or not and legislation should not be introduced for that because it is not necessary. But if the population has no choice and there is a perceived risk associated with it, then one has to take a different approach to the issue. That was one of the facets that we considered in relation to masts".

Conclusions and recommendations of the above Select Committee (para 81).

"We welcome the evaluation of the TETRA system now underway and recommend the results are made publicly available as soon as possible. Whilst we appreciate the importance of the system, we are very disturbed that there seems to have been no examination of the evidence on potentially adverse health effects before bringing it into service, and disregard for the conclusions of the Stewart Report published only two months after contract award, and drawing on over 20 years of research".

14. Dr Alan W Preece - Biophysics Group, Medical Physics University Research Centre, Bristol University - See Submissions to the Public Inquiry about Amberley Gloucestershire - dropped by Applicant one week before Proofs of Evidence due to Planning Inspectorate - no reason was given. In letter to Planning Inspectorate dated 3-11-2001 Dr Preece writes (Appendix 'U'):

"I have considerable experience in researching the interaction of radiofrequency with the human body, I have published a number of peer-reviewed papers on the topic and am, in particular continuing with specific research in the effect of TETRA transmissions on the human brain".

"We know (from evidence) that cellular radio transmissions, within existing NRPB and ICNIRP standards, affect the cognitive processes of the brain, (see references 1, 2, 3, 4, 5, 6, attached) and also affects sleep patterns (references 7, 8) On this basis the Stewart Committee recommended that more research is urgently needed".

"In particular, they commented that transmissions with low frequency modulation should be avoided until the research has been done. This is because of previous research (Baldwin and Adey - see references 9 and 10) which showed that low frequency modulation induced calcium release from the brain. We are only just about to start a study of TETRA and human responses and are also planning a study of GSM and children's responses".

"So it would possibly seem that to inflict unresearched modality on a non-receptive population whatever the commercial pressure, is possibly an unreasonable act since such information should soon be available to allow informed decisions".

With the exception of his recently started study (Nov 2001) Dr Preece pointed out that despite it being almost two years since the government-appointed Stewart Committee made recommendations

"no research has been started, let alone been completed".

15. Yvette Cooper: Former Health Minister (Appendix 'KK') in reply to concerned inquiry from MP Jonathan Said RE: Risk of TETRA planned for his constituency (included in proofs of evidence documents) Mrs Cooper states in a letter dated 2^nd October 2000, no research relating to TETRA and how it operates has been done on humans:

"I am informed that there have been several studies into the possible biological effects of the TETRA signal and although none of these were on humans……..".

16. Dr Gerard Hyland: In his peer-reviewed piece in the Lancet, Nov 2000 (see submission put in by Dr Hyland and accompanying documents). He has concluded from decades of work in this field that low level microwave radiation, of the type emitted by TETRA, produces biological effects in humans not measured in current safety thermal guidelines from ICNIRP and the National Radiological Protection Board. He has shown these are known to change the action of the brain. He believes it could be particularly harmful to children whose softer skulls and smaller heads allow far deeper penetration, and whose brain-waves do not stabilise until the age of 12 at best. This essential stabilisation could be interfered with because of this penetration.
17. Professor Ross Adey: Professor of Physics at the University of California interviewed by Will Yates for You and Yours Radio 4 programme item on TETRA; dated Jan 23^rd 2001.

"The increase in the level of interaction (between radiation and humans) is significant in the vicinity of 16Hz. Anything higher than this has been shown to lead to an outflow of calcium from brain tissue".

18. Barrie Trower: Independent physicist and author of the TROWER report commissioned by the Police Federation on TETRA. Commenting on:

"Possible Heath effects from Terrestrial Trunked Radio (TETRA)". Report of the National Radiological Protection Board's Advisory Group on Non-Ionising Radiation (Vol 12, no. 2 2001).

"RE; Section 135, Sections 5 & 6. These sections clearly suggest that residents living near a TETRA transmitter will be monitored as part of an epidemiological study for future cancers and illnesses".

"I believe TETRA masts should be refused planning permission until further research can be produced on their safety".

(Please see his written submission to this inquiry, and his report for the Police Federation).

19. John EH Tattersall: Research Scientist, at Porton Down. See Appendix 'OO' Express on Sunday 7^th October 2001. A study by Dr Tattersall:

"… published a few weeks ago in the journal Brain Research, showed that radio frequency radiation can affect brain cell signalling at intensities well below those that cause heating. " We don't know what this means at the moment, " Dr Tattersall said. "The Effects we have found could be hazardous - they could even be beneficial." A Tetra report for the NRPB was mostly reassuring, though it did call, among other things, for studies of the calcium effect, research on volunteers, and efforts to see if there is a link with epileptic fits. Co-author Prof Colin Blakemore of Oxford University said that in some circumstances, TETRA could breach existing NRPB safety guidelines and added that Dr Tattersall's Brain Research study meant that a new effect on brain cells of low-level radio waves has been discovered. "This is the first direct evidence I know of that very-low intensity radio frequency radiation can indirectly affect the potential difference [voltage] across nerve membranes," Prof. Blakemore said "There does seem to be something going on. "Personally I am not worried, but this is the best-documented example of a non-thermal effect on the nerve cells. This issue needs to be pinned down once and for all by additional research." Like mobile phones, Tetra seems destined to be a victim of the adage that it is impossible to prove safety. Unless incontrovertible hard evidence of a health risk emerges, we will have to continue to wonder about health effects of our love affair with the mobile telephone."

Note: Prof. Blakemore was a member of the Stewart Committee. Also a Member of the NRPB Advisory Group on Non-Ionising Radiation.

Peer Reviewed report in the Publication 'Brain Research' 'Effects of low intensity radiofrequency electromagnetic fields on electrical activity in rat hippocampal slices').

20. British Medical Association Report - Mobile Phones and Health (re: TETRA) - (Appendix 'C' page 2 - Statement of Case)

"Little research has been conducted into its possible adverse health effects, and therefore this research is necessary".

This report goes on to list the following potential adverse health effects from non-thermal effects. Full details are set out in the report, and I refer the inquiry to the report as a whole which gives a clear indication from a source not connected to the industry or those opposed to the installation of these technologies that there is real concern within the medical profession of the effects from all forms of telecommunication installations:

Cancer - 'might possibly promote or progress it';

Reproductive System - 'Since developing embryos or foetuses are vulnerable to environmental hazards at lower levels than adults, assessing the possible effects of RF fields on fertility and development should be a priority area';

Effects on the eye - 'The eye has limited capability to dissipate heat and is not protected by bone like the brain. Hence, the Royal Society of Canada has concluded that the possibility of adverse effects to the eye by RFR should be treated with caution and concern.

Cognitive effects - 'There has been concern that RFR may effect cognitive functions such as memory, reaction times, and sleep processes.

Children - 'Due to their developing nervous systems, greater absorption of energy in the tissues of the head, and their longer lifetime exposure, children may be more vulnerable to the effects of RFR.

Subjective disorders - This section concludes that more research is required.

The summary of conclusions on health states:

"However, all the main professional organisations have called for more research to be conducted, since the possibility that radiofrequency radiation may cause adverse effects cannot be ruled out on the currently available data. Clearly there are large gaps in the knowledge that need to be addressed".

The report raises concerns at the level of usage by motorists, recommending that no calls are made whilst vehicles are on the move.

21. The MDA report also raises grave concerns relating to the effect on 'medical devices'. There being ample evidence now available that the TETRA system has a greater effect on electronic equipment than other systems, in that respect I would refer the inquiry to Appendix 'J' which is the report in the Manchester Evening News, and brings home the potential effects. Whilst the MDA report refers to a distance of only 1m the reality of TETRA is far more than this as the Manchester Evening News report shows, where the electronic devices were over 50m from the base station. Also the report in 'Engineering' - 'Static and Silence'

'Of course automotive EMC problems amount for one small area among many, it's just that in a vehicle a large number of systems are present in a relatively small area. There are reports of EM interference causing problems in everything from industrial robots to cat flaps (there is a recorded case of a high-tech cat flap with magnetic locks located in a computer room rattling every time a certain PC was booted). With the environment seeing a greater saturation of technology the problem is liable to get worse — anything from a waste disposal unit to a portable fan can create havoc'.

Quoted in the BMA report we see the warning:

'Pacemakers and hearing aids - Mobile phones used close to these devices may possibly cause interference. If there is any concern, technical specifications of both the mobile phone and the device (hearing aid or pacemaker) should be obtained from the product literature, and advise sought from the Medical Devices Agency'.

This is of particular concern as I have already mentioned the area around the site is criss crossed with public footpaths which must raise concerns relating to the effect on passers by who may have medical devices fitted such as pacemakers and hearing aids.

Clearly, this refers to concerns to do with the use of actual mobile phone handsets, rather than base stations, however we maintain that this equally applies to the stronger transmissions of TETRA base stations, as I have already demonstrated TETRA will potentially affect electronic devices from a far greater distance (See Appendix 'J' Car Immobilisers). Therefore it is our case without clear evidence to dispute these known effects that the public are right to have concerns, not simply of the measurable health effects, but effects that could affect their health indirectly, as well as affecting the communities quality of life by adversely affecting the every day electronic equipment that surrounds us.

22. One of the causes of initial cell/DNA derangement is nuclear ionising radiation (including x-rays). The most likely role that electric or magnetic fields may play in this scenario is in weakening the human immune response, thereby allowing cancerous cells to exist and multiply.
23. The trials of the TETRA system in Lancashire has demonstrated that there is an adverse effect upon sensitive electronic equipment, in particular police breathalyser testing equipment (see report from Police Federation Appendix 'H'). Recent newspaper reports (from the first week of operation of the TETRA network in Greater Manchester) have demonstrated other adverse effects from TETRA installations such as the locking of car security systems (Manchester Evening News - Nov 23^rd 2001 Appendix 'J'), in some cases destroying the systems completely. The AA have indicated that there are at least 24 similar locations nationally. These problems are causing the local community some considerable concern, thereby causing stress. The local community have particular concerns about the potential for any adverse effect on life support systems such as pacemakers and dialysis equipment. Indeed the BMA report flags this up as a concern, and advises Practitioners to seek advice from the Medical Devices Agency if there are any concerns.
24. During 2001 there have been 6 planning appeals to the High Court. In two at Thurrock APP/M1595/A/00/1052881 &2 which were appealed to the High Court there was no challenge by either the local authority or the Secretary of State, and therefore the decisions have been referred back to the Inspector for reconsideration (those cases are still awaiting re-determination). One at Guildford APP/Y3615/A/00/1044138, and another at Stevenage APP/K1935/A/00/1045220 were again not contested, and therefore were referred back for re-determination. In another at Basingstoke and Dean BC APP/H1705/A/00/1038665 the case was not resisted by the Secretary of State or the Local Authority, however a member of the local community raised the issue of health but the case was dismissed on the grounds that the issue had not been raised before the Inspector (which is not the case in the present appeal). Which leaves one outstanding appeal before the High Court, however our inquiries at the beginning of November revealed that a decision by the Secretary of State whether to contest the Appeal had not been taken. It is clear therefore that no decision challenging any question (including health) on an appeal of an inspectors decision on phone masts has been 'determined' by the courts.
25. Between January and the beginning of November 2001 there were 298 decisions by planning inspectors on phone masts. The decisions in all these cases are set out in the spread sheet attached to our Statement of Case at Appendix 'D' (please note these should be read as sets of 8 pages, thus pages 1 to 8 make set A, 9 to 16 makes set B, and so forth). From case No.1 through to case No. 189 the appeals were allowed, whereas from case No. 190 through to case No. 293 the appeals were dismissed, there were 9 appeals against enforcement notices, 5 were upheld, and 4 were quashed, the remaining cases (2) were quashed on legal grounds.
26. Inspection of the decisions demonstrate there has been a wide variety of grounds for rejection, however the primary ground is that of the effect on the character/landscape or similar effect on the area (The Effect On Landscape and On Neighbouring Building(s)/Surrounding Area (By Reason Of Scale, Character etc)) of the proposed installation. Also featuring prominently in the grounds is that of coverage (and/or issues related to Radio/TV Signals: Radio Telescope, Communication System). Clearly indicating that this is a vital issue that has to be addressed in more detail than the appellants have done in the present case.
27. An Article in the Daily Mail dated 26^th January 2002 headed 'Cynicism of the Mobile Phone Firms' Quotes extensively Sir William Stewart and his concerns about the use of mobile phones by young persons (Appendix 'AAA').

"I said last year that I wasn't prepared to let my grandchildren use mobile phones and I have not changed that attitude".

"But I have seen reports over the Christmas period where some commercial companies were not acting in a precautionary mode".

In the same Article Prof. Challis of the University of Nottingham warned in relation to text messaging:

"The phone is not held next to the head. But of course if its in the lap you are exposing other organs which may be vulnerable. I would advise children to hold the phone away from themselves, not in the lap, particularly if they are boys".

The implication being that boys in particular may well be putting themselves at risk of becoming sterile. Also 15 separate research projects were announced almost two years after Sir William Stewart's recommendation for the need for further research. I urge the Inspector to ask himself the question is this too little too late especially for the children of Cinderford?

28. In an Article in the Daily Mail on the 13^th July 2001 entitled 'Mobile Phone Airship' (Appendix 'AA') refers to an Airship known as 'StratSat' that has the potential to revolutionise the way the World's communications systems are structured. The manufacturers claim that the whole country can be covered with just 19 airships, each one replacing around 4000 phone masts.

"With the capacity to be launched and function anywhere in the world, the StratSat will bring a sophisticated, practical and cost-effective solution to cater for the ever expanding mobile and Internet markets".

"As well as replacing around 4,000 mobile phone masts, ATG claims the network of airships could also take the place of 10,000 of the masts that will be needed to provide nationwide coverage for so-called 'third-generation' mobile phones".

29. I submit that on the basis of the statements, research and evidence of the leading scientists expressing detailed concerns about the lack of research on humans of the TETRA system the extreme fears of families and others living in proximity to mast sites is entirely rational and justified. Since it has a legal status in law, of a material planning consideration and a right to amenity and security in ones own home.

I ask that this appeal be dismissed on the following ground:

1. Insufficient information provided that would allow the decision maker to make an informed decision;
2. The perception (fear) that the local community hold that the development will have an adverse health effect;
3. The development is contrary to regional, structure and local plan policies;
4. The proposed installation would emit radiation of which the beam of maximum intensity will fall within the grounds of two local schools.
5. The proposal will have a detrimental effect upon the visual amenity of the area and the special landscape area,
6. Footpath adjacent to site
7. Ugly structure on skyline

Frankie Evans

Gloucestershire Mast Action UK - January 2002