Atawhai

Dear Ministers, bureaucrats, experts and interested citizens

Please find attached information sent to me by Andrew Goldsworthy, of Imperial College London, in response to recent claims that cellphones can help with Alzheimers disease. Andrew is very concerned about these claims and invites you to use his material as you see fit, circulate it and post it relevant websites.

I would be grateful if Sally/Martin and or Jim could urgently arrange for the Interagency Committee to urgently review the claims about cellphones and Alzheimers (and all the other relevant research about the safety or otherwise of EMR).

If cellphones can influence the brain in a way that can cause, contribute to or delay Alzheimers, then it is yet more evidence that EMR can cause biological effects at well below the levels allowed by NZS2772:1 1999 and that far more precaution is needed.

Urgent action is needed to warn parents about the potential dangers of cellphones for their children.

The government's ongoing failure to address the international concerns about the safety or otherwise of cellphones phones and EMR (electro-magnetic radiation) from other sources is increasingly concerning.

The Ouruhuia AM/FM Radiotower case is back in the High Court in Christchurch on 3 February 2010. The last round of that decision (by Associate Judge Christiansen in November 2008) highlighted a wide range of very serious adverse health effects on nearby residents and their horses, cows and other animals which were attributed to the radiotower. This was despite emissions being within the limits allowed by NZS2772:1 1999 (at least according to Mr Gledhill's monitoring).

Many highly qualified experts around the world have raised serious and legitimate concerns founded on their own and accumulated research and evidence.  Other governments are increasingly adopting a more precautionary approach and warning their citizens of the risks. The Local Government and Environment Select Committee released a report on 24 November 2009 calling for a review of EMR management in New Zealand and for more expert and community representation on the Interagency Advisory Group. So far as I am aware none of the community experts have yet been invited to assist with this.

These matters are serious and urgent. I am happy to assist how I can.

Thanks for you interest

Sue Grey LLB(Hons), BSc, RSHDipPHI
Atawhai
Nelson

1st December 2009

Via Email

Dear Submitter

Outcomes of Public Consultation on the Guidelines for Undertaking Community Engagement for Wireless Telecommunications Facilities

Thank you for your interest and submission on the Guidelines for Undertaking Community
Engagement for Wireless Telecommunications Facilities (the Guidelines), as prepared by the Telecommunications Carriers' Forum (TCF). The final version of these Guidelines have been approved and endorsed by the TCF, and they can be viewed at www.tcf.org.nz/CE.

Over 50 submissions were received on the draft Guidelines. The purpose of this letter is to summarise the key themes raised in these submissions; to detail how the TCF responded to these; and to inform you of what changes were made to the Guidelines as a result.

Timing and Nature of Engagement

A number of submitters commented on the original proposal which proposed three levels of engagement. The first level did not allow for engagement prior to construction, and only the third level involved engagement with those in the relevant community prior to obtaining council approvals.

As a result of numerous suggestions in the submissions received, the Working Party substantially increased the level of engagement prescribed by the Guidelines. The final version recently approved by the TCF has been refined to only having two levels of engagement:

• Level One: When an existing Wireless Telecommunications Facility is being upgraded (as per the definition in the Guidelines), engagement will occur 20 working days prior to construction.


• Level Two: When the Wireless Telecommunications Facility is new, engagement will occur prior to lodgement with the relevant Council of any consents, approvals or permissions required to locate the site at this location; and again 10 working days prior to construction.


• The Guidelines now also state that operators should include in this engagement:


• An explanation of the rationale used to select the location of a Wireless Telecommunications Facility.


• Under Level two, an explanation of the type of consent, permission or authorisation that will be sought.

Consistency of Language and Terminology

As a result of feedback received, particularly from Territorial Authorities, the definitions and terms used throughout the Guidelines were reviewed and amended to make definitions within the Guidelines more consistent with other documents, such as the National Environmental Standard and the Resource Management Act.

The Principles

The "Principles" section of the Guidelines was also substantially amended as a result of the submissions made. These changes streamlined and clarified the principles to make them more relevant to the scope and purpose of these Guidelines.

Comments on the New Zealand Standard for Radiofrequency fields; National Environmental Standards for Telecommunications Facilities; Resource Management Act

Many submitters expressed their opinion concerning the inadequacy of aspects of the regulatory framework for locating Wireless Telecommunications Facilities. Examples of these opinions are that the levels in the New Zealand Standard for Radiofrequency fields are set too high; or that Council District Plans, the Resource Management Act or the National Environmental Standards do not sufficiently allow for community engagement or participation in the decision making process.

These matters lie outside the scope of the Guidelines for community engagement and therefore could not be given consideration by the TCF in its review of the submissions received. However, the TCF takes this opportunity to clarify its broader position on these matters.

On the subject of the New Zealand Standard for Radiofrequency fields, the TCF notes its understanding that the Standard is based on sound scientific principles and is consistent with the majority of international guidelines in use around the world. The TCF also notes that the guidance given by the International Commission on Non Ionising Radiation Protection (ICNIRP) which forms the basis of most standards for radio frequency used in the world today, including New Zealand, has recently been reviewed by that body and found to be still appropriate.

On the subject of the National Environmental Standard for Telecommunications Facilities, the TCF notes a significant degree of public misunderstanding about the purpose and impact of these as they relate to the rollout of wireless networks and would welcome public communications from the relevant public agencies to address these misunderstandings.

Finally, the TCF would like to underline that the Guidelines have been designed to work alongside and augment the existing regulatory frameworks. The Guidelines cannot legally effect statutory or district plan changes. Should submitters feel that further changes are needed to these regulatory frameworks, and then the TCF encourages them to contact the relevant regulatory authority to understand the process through which these may be reviewed.

Location of Wireless Telecommunications Facilities

Submissions were received that argued that due to the perceived risk of negative health impacts, operators should not build Wireless Telecommunications Facilities near public or residential areas, or near any public facilities. Submitters argued for "exclusion zones" ranging from 100 metres to over five kilometres.

The TCF felt that consideration of concepts such as "exclusion zones" were beyond the scope and authority of these Guidelines. It is the role of the relevant Territorial or Unitary Authority to specify appropriate land use and activities via the District Planning process. However we note that such an approach would be at odds with the Resource Management Acts effects based approach. The TCF also notes that such concepts would make it difficult, if not impossible, to design a correctly functioning wireless network, particularly in urban areas. Furthermore, the notion is inconsistent with the principles of efficient wireless network design where sites are located as close as possible to users to minimise power output and radio frequency emissions from both the site and the devices using the site. Finally the notion has no scientific backing and therefore is inconsistent with World Health Organisation guidance that all consideration of effects should be based on scientific study. Accordingly, such limitations were not included in the final version of the Guidelines.

Emerging Research on the Impact of Wireless Telecommunications Sites

Submissions were received that highlighted pieces of research that alleged various negative impacts of mobile phones upon the health and wellbeing of the public. The majority of these submissions asked the TCF to ban the construction of further Wireless Telecommunications Facilities.

The TCF does not have a position on the relevance or applicability of this research, and considers matters such as these to be out-of-scope of these Guidelines. The TCF continues to encourage operators to monitor the latest research undertaken in this area, and to continue to follow the advice of the Ministry of Health, the Ministry for the Environment and the World Health Organisation. The TCF has built into the Guidelines a requirement for operators to refer members of the public to sources of information that are recognised by the national and international public health authorities as part of the community engagement process.

Thank You

Once again thank you for your interest and submission on the Guidelines.

Yours sincerely

David Stone

Chief Executive Officer

Telecommunications Carriers' Forum

Dear Minister

I would like to bring to your attention serious concerns about New Zealand's report to the WHO "WHO International EMF Project

14th International Advisory Committee meeting New Zealand country report 2009"

This report is available from:

http://www.who.int/peh-emf/project/mapnatreps/NEW_ZEALAND_Report_2009.pdf

The relevant part of the report states:

"Cellsites

There has been increased concern over the past year about cellsites, due partly to

publicity about the new National Environmental Standards for Telecommunication

Facilities discussed previously, and partly to the rollout of a new cellular network and

modifications of sites and installation of new sites by the two existing cellular network

operators. Measurements made by National Radiation Laboratory staff continue to

show that maximum exposures in publicly accessible areas around cellsites are

generally less than 1% of the ICNIRP limits (and typically much lower still). This

remains the case even where several sites are within a few tens of metres of each other.

One community group presented a petition to the Local Government and Environment

Select Committee, seeking (amongst other things) the prohibition of cellsites within 1

km of educational facilities, and a legislative requirement for notification and

community consultation for sites in residential areas. The Select Committee held

hearings but further consideration was postponed by an election."

As you know I have kept a very active interest in this issue for the last 18 months or so. During that time I have made regular contact with numerous community representatives around New Zealand and internationally. I have also presented oral and written submissions to the Local Government and Environment Select Committee and initiated regular contact with various Ministers, opposition MPs, public servants at the NRL, Ministry of Health and Ministry for the Environment and with various Telco representatives. I have also provided information to the government's Interagency Committee on the Health Effects of Non-Ionising Radiation, received and considered all the minutes and made suggestions seeking more qualified representation on that committee and the removal of vested interests.  I believe I have a very clear understanding of community concerns about cell sites.  

Despite my active engagement in this issue I have not been made aware of any community concern arising solely from publicity about the new NES. To characterise the concerns this way minimises the serious and genuine concern of many experts, parents and other community interests throughout New Zealand about the current state of EMR management in New Zealand.

All the individual and community submissions on the NES opposed the proposed regulation for a variety of significant reasons, including public health concerns, the inadequacy of NZS2772:1 1999 and the removal of the rights provided by the RMA, in a way that undermined the sustainable management purpose of that Act. The process for adoption of the NES was abysmal. Nobody who was employed by government apparently reviewed the submissions (this task was contracted out) and so far as I can ascertain, not a single point of concern raised in any public submission was addressed. The mandatory s32 report was delayed to so late in the process that it became meaningless and the Minister asked himself and answered the wrong question (see s44 of the RMA) before signing off on the Regulations.

The very serious and widespread public concerns about EMR management in New Zealand include requests for:

a) exclusion zones around schools, preschools and homes ? or at least much stricter criteria there to create an incentive for Telco's to locate new towers in sane places

b) a review of NZS2772:1 1999 to ensure best international practice and much stricter emission limits;

c) revocation of the "NES" (Resource Management National Environmental Standards for Telecommunications) Regulations 2008 which the Telco's largely wrote themselves and which gives them exemptions form all the usual environmental requirements for consultation and risk benefit assessments;  

d) removal of vested interests from the Government's Interagency Advisory committee and more representation from people who have expertise in assessing the health effects of non-ionising radiation; and

e) NZS2772:1 1999 adopting the wrong standard of proof and a far too narrow test to meet the definition of "effect" in s3 of the RMA.

Your report to the WHO seriously understates the degree of public concern and overstates the government's response to address these. The responses taken by the NZ government to date do nothing to address the inadequacies of NZS2772:1 (and the ICNIRP standard) which protects only against the microwave-oven type "thermal" effects of EMR and which provides no protection at all against the biological effects of much lower levels of EMR. Nor does it protect against effects on pregnant women, effects on people who are sensitive or hyper-sensitive to EMR, effect son people with pacemakers, the cumulative effects of EMR and other toxins and EMR with metals.  To protect against biological effects the maximum permitted limits should be reduced to 1/100 or preferably 1/1000 of the limits allowed by NZS2772:1 1999. I have seen no evidence of regular monitoring of any cellsites to support claims made in the report.  

It is very important that New Zealand reports accurately to WHO. I am therefore very keen to understand how the NZ situation came to be reported in these terms.

Please could you provide:

1) all draft reports and all documentation and evidence relied on that shows how the NZ report came to be submitted to WHO with this content and who authorised this.

2) copies of monitoring relied on to support the claim that "maximum exposures in publicly accessible areas around cellsites are generally less than 1% of the ICNIRP limits (and typically much lower still). This remains the case even where several sites are within a few tens of metres of each other."

3) Please also include the date and circumstance so this monitoring as the results you suggest are very different than the monitoring results that have been provided to me;

4) Any other information relied on by your officials to support the claims in the report and the sources of this information; and

5) Please could you also advise the date of the NZ report to the WHO and the period of time it covered.

I presume it is a relatively straightforward task to provide this information as it should all have been assembled to assist with the preparation of the report.

My preference would be for this information to be provided electronically.

Please ring me (ph xxxxxxxx) if you have any queries about the scope of this request. Meanwhile, please could you advise who will be handling my request.

Thank you for your interest and assistance.

Regards

Sue Grey LLB(Hons), BSc, RSHDipPHI

Atawhai

Nelson

Dear Ministers

Even if you are not concerned about the effects of cellphones on kids brains, you may be interested in their effect on male fertility!

This study is one of hundreds which identify adverse "biological effects" from low level exposure RF EMR (radiofrequency electromagnetic radiation).

The New Zealand standard (NZS2772:1 1999) does not recognise the possibly of EMR causing and long term biological effects (it protects only against the short term heating/microwave oven type effect). This is despite the potential for long term biological effects from RF EMR now being established beyond any doubt and despite the now ignored advice in the MfE/MOH National Guidelines for Managing the Effects of Radio Frequency Transmitters that exposure should be avoided where possible.

Other countries have emission limits 100 time more stringent that New Zealand's.  The governments of other countries and many international experts have issued warnings that children's exposure to RF/EMR should be minimised.

Why is New Zealand unnecessarily exposing its children to EMR. Think of the long term public health and environmental consequences if the research is correct. Why cant best international practice and a more precautionary approach be adopted? Why is the government not informing our residents of the risks so people can make their own decisions about the exposure they and their children are prepared to accept? Why are all the usual community participation rights for environmental legislation excluded in the case of EMR ? despite the enormous public concern and the increasing knowledge of the longer term risk form even low level exposure?

I look forward to your advice as to what action you are taking to address these concerns.

As always I'm very happy to discuss.

Regards

Sue Grey LLB(Hons), BSc, RSHDipPHI and concerned mother of three

Cell Phone Use Could Damage Semen 

Mobile Phone Use: Brain Tumor Risk

From: (MIN)

Sent: Thursday, 12 November 2009 5:12 p.m.

To: Sue Grey

Subject: RE: Celltowers story on Target ! the Sue Grey email

Dear Ms Grey,

On behalf of the Hon Dr Nick Smith, Minister for the Environment, I acknowledge receipt of your email, received 28 October 2009, in which you request the following information:

- a copy of the full statement that you made to Target plus all related communications to you and/or to your office from any of your own officials, the National Radiation Laboratory and any other public servants which led to this statement being released to Target?

- I would also be grateful for you advice as to if and when the NZ government intends to take action to bring New Zealand inline with best international environmental practice in relation to the management of celltowers, and other radiofrequency.

Your request will be responded to under the provisions of the Official Information Act. Your request for urgency has been noted.

Yours sincerely

-----Original Message-----

From: Sue Grey

Sent: Wednesday, 28 October 2009 8:11 am

To: Hon. Dr. Nick Smith (MIN)

Subject: Celltowers story on Target !

Dear Minister

I am very concerned that the statement attributed to you on "Target" last night may be misleading and deceptive. I do not know if the show accurately represented your words.

Your words bore similarities to misleading claims made in the house by Damien O'Connor prior to the election about this issue and presumably were prepared by the same individual or organisation.

Please could I urgently have (by reply email) a copy of the full statement that you made to Target plus all related communications to you and/or to your office from any of your own officials, the National Radiation Laboratory and any other public servants which led to this statement being released to Target?

I would also be grateful for you advice as to if and when the NZ government intends to take action to bring New Zealand inline with best international environmental practice in relation to the management of celltowers, and other radiofrequency.

Thanks

Sue Grey