Atawhai

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