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Written evidence submitted by Ian Jarvis


Broadband and the road to 5G

Opening Remarks and Setting the Scene

This submission is focussing solely on the effects of ENF/RF on human and other biological tissue. That aspect is of primary importance and MUST be addressed before any of the questions/points posed in this consultation. The first duty of any government is to protect its citizens – the citizens who give it validity and employ it.

It’s important that there is an understanding of both the limitations of science, its complexity and also its simplicity in interpretation. I read and hear many times an argument that “there is no consistent science”, “results of research are inconclusive” or “the result is not statistically significant”.

In a very simple and obvious way what these are ALL reporting is that there are some results that show whatever was the purpose of the research – in our case negative biological or health effects.

To take an analogy, in the UK it used to be thought that all swans were white. If I want to disprove this theory and show that black swans exist, I do not have to prove that EVERY swan is black. I merely have to show a single swan that is black and I have made my case.

In the current argument over the safety or otherwise of EMF/RF it is sufficient to prove that SOME cases in SOME experiments show negative effects SOME of the time. There is more than enough evidence of that.

Even where individual cases are difficult to reproduce this is still enough to prove evidence of harm. Throughout the history of science, biologists have always had a problem with the reproducibility counter argument because biological tissue is notably contrary and variable, especially when it is part of a living animal or human subject.

This is where the much vaunted “scientific method” is actually a barrier to conducting science.

We are content to use EMF/RF at certain power and frequency ranges in health monitoring and treatment. ECG and EEG devices give the data they do because we are essentially electric beings. TENS and PEMF devices are used in mainstream and complementary systems alike to aid healing. It is completely illogical to argue that something can be positive or neutral and yet not have the possibility of being negative.

My second general argument is one of history. Even a shallow understanding of the history behind every regulated substance or process shows how the industry argued strongly that it caused no harm against powerful evidence to the contrary from the public, health bodies and independent science.

In many industries, where the companies involved knew their product was unsafe, they warned the shareholders of potential future dangers to their investment whilst simultaneously winning court cases and advising the public there was no such evidence. Apart from the well-known cases of tobacco and asbestos there are myriad examples of this in the chemical industry. Today the mobile phone companies are also doing this.

I recommend that the committee for this consultation all read “Corporate Ties That Bind; an Examination of Corporate Manipulation and Vested Interest in Public Health” edited by Martin J Walker. This will illustrate the dangers when research is funded by industry and where representatives from industry are members of regulating panels.

The above statements should be enough for every member of the committee to see the need for a moratorium on the addition of ANY more EMF/RF exposure in our towns and cities. You do not need to read specific evidence to evoke the precautionary principle no matter what “G” we are discussing.

I will gently drop in what you already know. The International Agency for Research on Cancer (IARC) named EMF/RF as a class 2B carcinogen – “probably carcinogenic”. Shouldn’t this of itself suggest a need for a precautionary approach? After all we do have enough things that can cause cancer without an additional one!

Finally, a quote in 2008 from Sir William Stewart, the ex-chair of the UK Health Protection Agency:

“Since 2000 there has been a mass of publications, reports, observations, and views purporting at the very least to implicate phones/base stations as a cause of adverse health effects. At a time of uncertainty when more information is required, non-peer reviewed articles should not be ignored. Doing so is ridiculous. They may be right but unproven and/or offer pointers to be thought about and followed up.”

But Who am I to make these Arguments?

Your Consultation Paper asks that submissions contain some personal details. I am a ‘concerned citizen’ who has for many years been following arguments about the effects of EMF/RF fields on humans. Technically, I have a degree in Computing Science plus 30 years experience working in that industry. I also have an education in health and have worked as a complementary body therapist for some 20 years.

Now retired, I am an independent thinker with no ties to any industry, university or company.

The Case from Science

I do not wish to overload the committee with masses of scientific reports which might only obfuscate. I am sure that many others will give you references and links to research. All I would add is that you be aware that every scientist has his or her biases (sometimes justified) and influences (eg financial, career, reputation).

Before delving into the detail, I think it important to set a context for research. Taking my “black swan” argument further, I have yet to find the study that has ZERO cases that show a negative biological effect. Even those that conclude there is no significant result (or similar wording) have within their sample cases ones that show negative effects. I could thus argue that every single study has shown some negative effects and thus make my point with the help of black swans.

Since at least the early years of the 20th century there have been conflicts of interest in scientific research at individual levels and organisational levels and this is no less in the area we are discussing. It is a serious issue, since it is a clash between the public interest and the profits of industry, and it is easy to understand the pressure on a scientist and PR ghostwriter alike.

There are many ‘tricks’ that can skew the results of a study in a particular direction from the outright lie to the careful design of the testing and some are easier to spot than are others. There are also many inducements from the financial to career progression. It is important that this committee is aware of these potential influences  when studying any research. At the very minimum, you should always ask who funded the study.

I will first remind you of the following which you should already know about, because they were written and signed by concerned scientists and submitted to the UK Government among others. The following include references to many research projects.

  1. A letter dated 11 October 2019 to the Ministry of Housing, Communities and Local Government from the EM Radiation Research Trust.
    For a copy you can go here:
  2. The International Appeal to stop 5G on Earth and in Space has been signed by many scientists, doctors, environmentalists and just ordinary citizens. It is exactly what it says and can be found here:
  3. A specifically EU appeal recommends “a moratorium on the roll-out of the fifth generation, 5G, for telecommunication until potential hazards for human health and the environment have been fully investigated by scientists independent from industry.”
    Find it here:

I will now propose a more pragmatic and intellectually digestible approach for your deliberations. You may as well enjoy the process!

  1. Here is a lecture given by UK medical doctor, Dr Erica Mallery-Blyth and aimed at schools and teachers. It is packed with good science. She is a founding member of the Physicians Health Initiative for Radiation and the Environment (PHIRE) and there are other videos on their website
    The direct link for the presentation is:
  2. Dr Devra Davies is an American doctor and scientist who has worked for many years in research on cancer. This is a recording of a lecture she gave at the University of Melbourne (Australia). It can be found on youtube here:
  3. Dr Paul Ben-Ishai gets more technical in this lecture. He is a physicist and this talk is important as he explains how mm waves (eg 5G) use our sweat ducts like antennae to penetrate the EMFs deeper into our bodies.

Even if you do not read the research literature these three talks will give you more than enough education to validate the common calls for a moratorium on more roll-out of wifi systems.

One final illustration. I have read many times that the sun is more powerful than (eg) 5G so what are you worried about? That is of course true. It is also the case that sun can cause a lot of harm through over-exposure. I can monitor and manage my exposure to the sun. With the increasing swamping of the environment with EMF/RF from masts and satellites, I will soon be unable to manage my exposure to that.

The Case in Law and Governance


Late in 2019 when Matt Hancock MP wrote his letter to Local Authorities, specifically about 5G, he broke most of the ideals I have already mentioned in my opening. This is part of his text,

“There is no compelling evidence for any increased concern

        “no compelling evidence” retranslated means there is some evidence (but we don’t like it!)

        “(no) increased concern” retranslated means that there is already some concern (but we think there won’t be any more!)

He went on  (we) “will bust health myths over 5G and provide evidence-based reassurance” which reads as if “we” have made our minds up already. Your health concerns are “myths” and we will find the right science to “reassure” you. In other words we are not going to be looking for any negative signs.

This is not science, it is politics at best, personal subjective opinion at worst.

A Legal Opinion:

In May 2019, Danish Attorney-at-Law Christian F. Jensen published his legal opinion

“on whether it would be in contravention of human rights and environmental law to establish the 5G-system in Denmark.”

Although it was meant for concerned citizens in Denmark, it is relevant here since he refers to EU and international law. It was commissioned by “Rachel Santini, head of the scientist network the Danish Institute for Public Health, together with the Council for Health-Safe Telecommunications, the EHS-association, and the Danish Health Association May Day,”

It can be accessed here:

Particularly notable are his concluding remarks,

“It is the conclusion of this legal opinion that establishing and activating a 5G-network, as it is currently described, would be in contravention of current human and environmental laws enshrined in the European Convention on Human Rights, the UN Convention on the Rights of the Child, EU regulations, and the Bern- and Bonn-conventions.

The reason is the very significant body of scientific documentation available, showing that radiofrequent electromagnetic radiation is harmful and dangerous to the health of humans (particularly children), animals and plants.

This also applies when the radiation remains within the limits recommended by ICNIRP and currently used in Denmark as well as broadly within the EU.

The exact damaging effects to health from 5G are not known, since the system is not exactly defined, though given the background of the current research on the effects of radiofrequent electromagnetic radiation on, e.g. the bodies of humans and animals, including the provocation of DNA damage and oxidative stress, it appears highly unlikely that it would not lead to similar harm as the current systems, particularly since it is based on the same basic form of radiation.”

Who sets the Standards?

It has been generally accepted that the International Commission on Non-Ionising Radiation (ICNIRP) is the primary international body for standards in the industry. But ICNIRP has no legislative framework and is simply a private organisation based in Germany with no European or International mandate. It seems to self-select members and gives no scrutiny on conflicts of interest nor appropriateness of posting.

Within the UK, it was the Advisory Group on Non-Ionising Radiation (AGNIR) that was supposed to review the ICNIRP guidelines and make recommendations to the Government through the Health Protection Agency (now Public Health England).

Dr Sarah Starkey has the best view of AGNIR and ICNIRP in her 2016 paper titled “Inaccurate official assessment of radiofrequency safety by the Advisory Group on Non-ionising Radiation”. This is another ‘must read’ for the council and can be found as a pdf here:

There is also a recording of her giving a presentation in which she shows the following interesting graphic.

It shows an almost nepotistic approach to the selection of members for various committees. It should be noted that AGNIR was quietly closed. It is a little out-of-date now but suffices to show the close ties between the organisations. Bear in mind that some of these are supposed to be reviewing the recommendations of others. If someone sits on the committee that created the standard and also on the one that is reviewing it then they cannot be independent by any definition.

What this doesn’t show are the industry conflicts within the members. Many of these eminent people will have ties or financial links to mobile telephony companies.

Who Controls Space?

Last year the Federal Communications Commission (FCC) of the USA granted permission for the launch and placement of 20,000 satellites for 5G transmissions. It increased to 50,000 and may be even more by now. These will form a grid around the earth.

There are many questions raised. The simplest is that the FCC is calmly handing out permission for American companies to fly satellites over the land of every other country on earth! Who is giving the FCC permission to do that?

Concerned scientists include:

         Astronomers whose work will be interfered with by the satellites flying past their telescopes.

         Meteorologists who are concerned that the frequencies to be used may well interfere with their bands, negatively influencing their ability to forecast weather and in particular to give severe weather warnings.

         Those studying the electric nature of the earth and her surrounding atmospheres. How will these effect the electro-magnetic nature of our planet and bio-sphere?

         Environmentalists who are concerned about the effect on navigation abilities of animals, birds etc and also the direct effects on plant life.

A few brief observations to conclude:

         No provider of EMF/RF equipment has ever described it as “safe”.

         Telecomm companies are issuing warnings to their investors about possible future liabilities whilst ‘assuring’ the public there is no harm.

         Insurance companies, including Lloyds, have put exclusion clauses in their policies to protect themselves against claims for injuries caused by EMF/RF. An example:
We will not make any payment on your behalf for any claim, or incur any costs and expenses, or reimburse you for any loss, damage, legal expenses, fees or costs sustained by you, or pay any medical expenses directly or indirectly arising out of, resulting from or contributed to by electromagnetic fields, electromagnetic radiation, electromagnetism, radio waves or noise.
This would include the microwave radiation and electromagnetic radiation emitted from Smart Meters (AMR, AMI, PLC), from Home Area Network devices and appliances (including AC and thermostats), from Wi-Fi transmitters, from wireless devices in schools, offices, and homes, and from wireless sensors and wireless-connected fire alarms.”

         The above point would make the likes of school Governors and employers the sole bearers of responsibility.

         I often see notices on street furniture advising me to keep clear because there is a radio frequency transmitter nearby. If there is no harm then why would this be needed?

Concluding Remarks

In this brief submission, I have shown that it is not necessary to have “consistent” or even “significant” evidence of harm before it makes sense, in the name of humanity and public health, to adopt a precautionary approach to the increase of EMF/RF into the environment. There is a myriad of studies from around the world that show quite clearly that these non-natural fields CAN have negative biological and health effects. It is almost too obvious to mention that this will affect ALL biological life and not just us!

The magnitude of this is greater than any other single development humanity has ever made.

We are about to envelope the entire planet in something for which we can have no proof of its safety. There is no way of testing what effects a grid of 50,000 satellites around the earth will have. (Plus whatever other countries such as China and Russia might launch.) It could even presage a war if (for example) China decides to destroy any – it has shown it has that capability.

There is no ‘control planet’ for experimentation nor a ‘planet B’ to which we can all decamp.