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Written evidence submitted by Dr Joseph

Call for Evidence : Broadband and the road to 5G

Written and compiled by Dr Joseph, PhD

Brief Introduction

I am molecular biologist by discipline and have worked in multiple University departments in Cambridge (Departments of Physiology & Clinical Pharmacology, University of Cambridge) as an academic postdoctoral research associate during the course of my scientific career (e.g. at the Department of Physiology I worked on beta-adrenergic receptor function alongside colleagues in the same lab who were studying voltage gated sodium channel genes which cause sudden cardiac arrest, i.e. Brugada syndrome).

Prior to this, I worked at the Wellcome Trust Sanger Institute, Hinxton, in the X chromosome group helping to map the human genome. Latterly, I have also worked for a contract research company, Cogenics, and in the scientific distribution industry doing bioscience product management and marketing for companies like Thermo Fisher Scientific, Scientific & Chemical Supplies and Appleton Woods.

I am submitting my evidence, because as a scientist, I understand the implications of negative biological effects on human pathophysiology.

I am deeply concerned that key scientific literature, pointing to very real, non-thermal negative biological effects of EMR radiation is being ignored by the mobile and broadband industry as well as bodies like the ICNIRP, that our government relies upon, to give guidance regarding the safety of 5G.

These concerns are very important because they have a direct impact on the ‘Broadband and the road to 5G’  consultation, and if they are ignored, it will be to the detriment of the health and wellbeing of the whole UK population, particularly that of our children, future generations, as well as our delicate ecosystem.

Summary of my Evidence regarding the Consultation on Broadband and the road to 5G

1. Very real, negative non-thermal biological effects occur as a direct result of extremely low electromagnetic radiation (EMR) levels, which are several orders of magnitude lower than the current safety limits set by the International Commission for Non-ionising Radiation Protection (ICNIRP).

2. The current legislative and regulatory plans for the roll out of 5G are misguided by Public Health England (PHE) which relies entirely on ICNIRP safety guidelines on EMR radiation which have been shown to be deeply flawed – see Pall, M. (2018) (1) and Hardell & Nyberg (2020) (3). ) and Naren et al. (2020) (24).

3. The ICNIRP safety guidelines are flawed because:
1. They assume average EMR intensities and average SAR can be used to predict biological effects and therefore safety. In fact, negative non-thermal biological effects occur approximately 100,000 times below current allowable levels.
2. They ignore demonstrated biological heterogeneity and established biological mechanisms
3. They ignore pulsed EMRs which are much more biologically active than are non-pulsed EMRs of the same average intensity
4. They ignore complex sinusoidal dose-response curves
5. They also ignore many important scientific reviews which show non-thermal negative biological effects caused by EMRs (see body of evidence in Tables 1,2 & 3)
6. There are many articles which state that EMRs produce diverse non-thermal effects through voltage gated calcium channels (VGCCs) in cells and produce negative biological effects such as oxidative stress, cellular DNA damage and increased calcium signalling but the voltage sensor of the VGCC is ignored by the 2020 ICNIRP safety guidelines. (see the following articles for which  Pall,M. 2018 (1) & Doyon PR et al, (2017) (8) Herbert MR & Sage C (2013) (15),Panagopoulos et al (2002) (30).

4. Negative non-thermal biological effects of electromagnetic radiation listed in the literature across humans and other species are : (see Tables 1, 2, 3 below and References below from Pall (2018) (1))
1. Lowered adaptive immune responses or immune system dysregulation
2. Cardiac effects, including tachycardia, bradycardia and arrythmias, and ventricular developmental defects
3. Cancer including initiation, promotion and progression
4. Pathological damage to multiple organs (e.g. liver, kidneys, uterus, bladder, testis)
5. Trace element disturbances in tissues
6. Ocular damage
7. Lowered fertility
8. Hormonal dysregulation
9. Neurological / neuropsychiatric effects
10. Sleep disruption
11. Memory, motor skill, attention, cognition impairment
12. Apoptosis / programmed cell death
13. Oxidative stress / free radical damage
14. Single strand and double strand breaks in cellular DNA
15. Increased intracellular calcium levels causing chronic effects

5. Considering all of the above negative effects of lower intensity electromagnetic radiation already out there, many scientists globally have asked for a moratorium on the deployment of 5G until the electromagnetic radiation risks associated with this new emerging technology have been fully investigated by industry-independent scientists, but this is falling on deaf ears. The responses from the EU seem to have thus far prioritized industry profits to the detriment of human health and the environment. Hardell & Nyberg (2020) (3)

6. This means that the current situation in the United Kingdom is a violation of Human Rights similar to that which has been tabled to the United Nations Human Rights Council in early 2019 for Australia by S.J. Toneguzzo. (See below UN NGO document link, page 11)

7. The deployment of 5G without safety testing in the UK violates over 15 international agreements, treaties and recommendations, including article 7 of the International Covenant on Civil and Political Rights and principle 9 of the Declaration of Helsinki of 1964. (links listed on page 11 below)

8. Wireless carriers have already conceded to U.S. Senator Richard Blumenthal that they are not aware of any independent scientific studies on the safety of 5G technologies – see reference 13 below. They are also making misleading comments about the safety of 5G – see comment by Dr Jack Rowley below, page 16).

9. Clearly if existing low level EMRs are having damaging biological responses such as those listed in point 4 above, surely untested frequencies such as 5G, should mean that we should be invoking the precautionary principle on 5G, and re-evaluating and revising current safety limits, as well as putting a moratorium on the roll out of 5G? Naren et al. (2020) (23) have stated that 5G should only be deployed after having completed thorough research and well-designed safety testing, as the EMR radiation exposure levels they see with 2-4G are well over the safe limits set by Building Biology, Austrian Medical Association, and the BioInitiative standards which do take into account non-thermal negative biological EMR effects.

10. The precautionary principle has already been applied by multiple local city councils in England (Brighton, Hove, Devonshire, Shepton Mallet, Somerset, Frome, Totnes, Wells, Glastonbury, Trafford) as well as other rightly concerned countries like Nigeria, Slovenia, etc. – see URL links 11 and 12 in References for a full list.

11. We should be insisting that adequate safety testing is done for 5G, and that current safety limits are re-evaluated in the light of the overwhelming body of current scientific literature which points to non-thermal negative biological responses across multiple species (see Tables 1, 2, 3), not just human beings. (see also letter to House of Commons from Radiation Research Trust requesting safety testing in reference 14 below) Naren et al. (2020) (24) state that “If 5G networks are deployed without careful analysis of expected exposure levels, almost all people in the area of coverage may be exposed to dangerous levels of power flux density, the outcomes of which, in the near future, may turn out to be calamitous.” They strongly suggest that a study similar to theirs be conducted in countries which choose to deploy 5G, by correlating the findings with the Basic Biology Standard, the Austrian Medical Association standard (AMA) and the BioInitiative standard (see Table 4) in order to get a consistent view of radiation exposure in 5G networks as compared to previous generations. This would provide much-needed insight and caution to all countries that are yet to adopt 5G.

12. Only after safety testing of 5G had been done by the mobile and broadband industry and by independent non-industry scientists who have no economical allegiance or scientific bias towards such emerging technology, should 5G have even be considered to be deployed in the UK. Any such safety testing data needs to be independently verified by a non-industry scientific committee (see page 10, paragraph 2 below for suitable constituents of such a non-industry committee).

13. Right now, we should be consulting and informing constituents of their rights in those parts of the UK, for whom 5G has been rolled out, without safety testing, as well as putting a halt to access to 5G, until we are aware of the full impact of 5G on, not just humans, but also on all species. This is because we now know that existing low level EMR radiation, is already damaging humans as well as less complex species such as plants, insects, birds and lower mammals (see list of articles in Table 1, 2 & 3 and Naren et al. (2020) (24)).

14. I have assessed much of the latest data on EMR radiation (see Tables 1, 2, & 3 and References section below) and find that we should be doing all we can, to protect our public from harmful EMR radiation as follows:

1. Doing safety testing of 5G before we authorise any further roll outs and putting a halt to the operation of existing installations until the safety testing has been verified and approved by not just the mobile and broadband industry but by a non-industry working group of scientists, physicians and members of the public who can assess the data independent of 5G manufacturers

2. Prioritising and incentivising the use of safer wired fibre optic solutions in our homes, shopping centres, airports, hospitals, workplaces and schools

3. Encouraging families to protect their future generations by minimising the use of portable devices which produce EMR radiation like mobile phones, tablets, laptops, etc. (see letter requesting the same in reference 14 below)

4. Suggesting urgent research on the safety and efficacy of shielding methods combined with use of generators emitting weak pulses of similar frequency, intensity, and waveform with the natural atmospheric resonances - see Panagopoulos & Chrousos (2019) (16)

5. Getting a better understanding of the molecular mechanisms underlying the EMR potential challenges to not only a single system but to all our biological systems, in order to improve preventive strategies  - see Santini et al. (2018) (17)

6. Putting in place mobile and broadband industry-independent safety and usage regulations to protect our public (adults and children) and other species and advising appropriate restrictions on the use of EMR emitting mobiles and all portable devices in order to protect the health of all users, i.e. not with respect to only one organ but with respect to our bodies as a whole, as well with respect to the health of the delicate ecosystem around us – see multiple papers in Table 3 which show:
1. working memory impairment in human beings with mobile phone use (Kalafatakis et al. 2017)
2. strong cancer causality with mobile phone use (Pareja-Peña et al. 2020)
3. negative physiological and morphological effects on multiple plants (Halgamuge MN. 2017)
4. cognitive and motor damage on insects  (Shepherd et al. 2018).

7. Naren et al. (2020) (24) have done a highly informative study of the exposure to EMR radiation across multiple wireless devices. They have determined the radiation concern levels in several scenarios using a handheld radiation meter by correlating the findings with several international standards, which are determined based on thorough scientific evidence  They have suggested individual and collective human-centric protective and preventive measures that could be undertaken to reduce the risk of EMR radiation absorption but these are not fully protective for Electromagnetic Hypersensitivity (EHS) individuals, so these can only be looked upon as a non-comprehensive interim measure in an environment where wireless EMR radiation cannot be avoided due to the lack of a wired fibre optic infrastructure.

8. Barnes & Greenebaum  (2020) (25) have also sought to give advice on how governments, mobile and broadband industry and associated regulatory bodies could assemble EMR safety guidelines for individuals, mobile and broadband companies, and system operators. They state that we don’t yet know whether biological effects seen due to lower level, long term EMR exposure are resulting in medical problems for a much larger number of people. Therefore, governments need to investigate long‐term exposure to weak EMRs, and put in place safety guidelines to address this issue.

9. I strongly urge the UK government to use an independent scientific committee (ISC – see page 19 below for its composition) and PHE, to:

1. Re-evaluate the body of scientific evidence on extremely low EMRs (continuous and pulsed) which produce non-thermal negative biological responses across multiple species not just humans

2. Understand and communicate to the public which safety guidelines most closely adhere to protecting our people from any further EMR damage (by evaluating also the rationale of the Building Biology, Austrian Medical Association, and the BioInitiative standards which do take into account non-thermal negative biological EMR effects)

3. Work together with the scientists of other countries who are assessing their exposure limits prior to rolling out 5G, to understand all the dangers of 2G-5G

4. Set up UK-specific EMR safety guidelines based on what is found from the above exercise, and not just rely on the currently flawed ICNIRP guidelines (the new guideline could be then used as a gold standard globally)

5. Set up new individual, worker, manufacturer, public spaces and atmospheric safety guidelines for existing 2G-4G EMR emitting portable and stationary devices, base stations and towers

6. Use the protective and preventive measures from Naren et al. (2020) (24) in  a public information campaign to inform the UK population on the best methods of shielding themselves from existing 2G-4G EMR radiation in the absence of any other consensus (see Table 4 below)

7. Set up a study similar to the one conducted by Naren et al 2020) (24) in these countries, by correlating the findings with the Building Biology, Austrian Medical Association, and the BioInitiative standards in order to get a consistent view of radiation exposure in 5G networks as compared to previous generations.

8. Set up new individual, worker, manufacturer, public spaces and atmospheric safety  guidelines for existing 5G EMR emitting portable and stationary devices, base stations and towers

9. Halt the operation of existing 5G installations until safety testing has been verified and approved by not just the mobile and broadband industry but by a non-industry working group of scientists, physicians and members of the public who can assess the data independent of 5G manufacturers

10. Contact the public in any area where 5G is going to be deployed or already deployed and ask them if they still want to have the greater connectivity of 5G despite the potential long term harms associated with exposed to very high levels of power flex density emitted by 5G EMR radiation. Leave the choice to the public, and where they still want access, ensure that 5G is made available only through wired fibre optic technology thereby protecting those members of the public who prefer not to be exposed, e.g. EHS individuals.

11. Take action now for all those persons with Electromagnetic Hypersensitivity (EHS) where they have been already subjected to 5G to inform them that the existing 5G masts will be decommissioned and a wired fibre optic technology solution put in to replace 5G masts..

12. If existing non-5G masts are within a few yards of a property, action should be taken immediately to rectify this as residential buildings and schools should be protected from close by sources of EMR radiation. Safe distances for these masts should be determined by the bodies that have created the Basic Biology Standard, the Austrian Medical Association standard (AMA) and the BioInitiative standard who recognise non-thermal negative biological effects of EMR radiation.

I provide feedback on each of the Government’s questions in this consultation below:

• How realistic is the Government’s ambition of nationwide gigabit-capable broadband by 2025, and what measures (regulatory, financial, technical, other) will be needed to achieve it?

The Government’s ambition of nationwide gigabyte-capable broadband by 2025 needs to be tempered by an understanding and deep concern regarding the negative biological impact, that nationwide 5G roll out will incur, on the people of this country. As it stands, in the UK, 5G has already been rolled out in key cities without any safety testing.

It is clear from the scientific literature that very real, negative non-thermal biological effects occur as a direct result of extremely low EMR radiation levels (Tables 1, 2,& 3). These levels are orders of magnitude lower than the current safety limits set by the ICNIRP (the body that PHE relies on to set safety EMR guidelines). This has a direct consequence for what regulatory and technical steps should be taken by the UK Government to achieve safe broadband connectivity without harming the health of our nation (see paper written to authorities of the EU by Martin Pall in 2018.(1) )

We, as a country, need to stop prioritizing industry profits to the detriment of our human health, the environment and many species (see Tables 1, 2, & 3) for a list of the species affected by EMRs).

• What are the challenges to the roll-out of 5G and gigabit-capable networks? To what extent do existing legislative, regulatory and spending plans address them?

The major challenge to the roll-out of 5G and gigabyte-capable networks is that the current legislative and regulatory plans are, unfortunately for us the public, misguided by Public Health England which relies on ICNIRP safety guidelines which have been shown to be deeply flawed.

The reasons for this, are as follows:

1. ICNIRP, US FCC, EU and other EMR safety guidelines are all based on the assumption that average EMR intensities and average SAR can be used to predict biological effects and therefore safety. Eight different types of quantitative or qualitative data have been analyzed by Pall (2018) (1) & (2) to determine whether these safety guidelines predict biological effects. In each case the safety guidelines fail and in most of these, fail massively. Effects occur at approximately 100,000 times below allowable levels (see also Tables 1, 2, & 3)  and the basic structure of the safety guidelines is shown to be deeply flawed. The safety guidelines ignore demonstrated biological heterogeneity and established biological mechanisms. Even the physics underlying the safety guidelines is shown to be flawed. Pulsed EMRs are in most cases much more biologically active than are non-pulsed EMRs of the same average intensity, but pulsations are ignored in the ICNIRP safety guidelines despite the fact that almost all of our current exposures are highly pulsed. There are exposure windows such that maximum effects are produced in certain intensity windows and also in certain frequency windows but the consequent very complex dose-response curves are ignored by the safety guidelines. Several additional flaws in the safety guidelines are shown through studies of both individual and paired nanosecond pulses. The properties of 5G predict that guidelines will be even more flawed in predicting 5G effects than the already stunning flaws that the safety guidelines have in predicting our other EMR exposures.’ – see Pall, M. (2018) (1)
2. Nine distinct types of repeatedly found patterns of evidence clearly show that the “safety guidelines” do not predict biological effects” as seen in Pall, M. (2018) (1) and Pall, M.(2019) (2)
3. Hardell & Nyberg (2020) (3) further state “In an appeal sent to the EU in September, 2017 currently >260 scientists and medical doctors requested for a moratorium on the deployment of 5G until the health risks associated with this new technology have been fully investigated by industry-independent scientists. The appeal and four rebuttals to the EU over a period of >2 years, have not achieved any positive response from the EU to date. Unfortunately, decision makers seem to be uninformed or even misinformed about the risks. EU officials rely on the opinions of individuals within the ICNIRP and the Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR), most of whom have ties to the industry. They seem to dominate evaluating bodies and refute risks. It is important that these circumstances are described. In this article, the warnings on the health risks associated with RF presented in the 5G appeal and the letters to the EU Health Commissioner since September, 2017 and the authors' rebuttals are summarized. The responses from the EU seem to have thus far prioritized industry profits to the detriment of human health and the environment.”
4. The 2020 ICNIRP guidelines have been published in March, and state: “For the purpose of determining thresholds, evidence of adverse health effects arising from all radiofrequency EMR exposures is considered, including those referred to as ‘low-level’ and ‘non-thermal’, and including those where mechanisms have not been elucidated.

But this is not what I understand from having watched the online 2020 ICNIRP presentation on the latest guidelines  by Eric Van Rongen, Chairman.  (https://www.icnirp.org/en/frequencies/radiofrequency/index.html)

He states that there is no evidence for cancer, electro hypersensitivity, infertility or any other health effects. The only adverse EMR radiation effects he acknowledges to exist are: nerve stimulation at <10MHz and heating at > 100kHz (see screenshots below).

Is he looking at a completely different set of biased scientific data to what I see in Entrez Pubmed (https://www.ncbi.nlm.nih.gov/pubmed/) when I do a search for ‘EMR radiation?

I looked at the scientific data (extracted in Tables 2 & 3) and I can see that there are loads of papers showing peer reviewed scientific evidence across multiple species for negative biological health effects due to low level EMR radiation. I then extracted data from these tables to generate Table 1 below which shows the following:

1. Multiple species are negatively affected by low level EMR radiation as a whole, not just human
2. Multiple organs are negatively affected in any given species by low level EMR radiation
3. Multiple biological pathways are negatively impacted by low level EMR radiation as seen by the type of effects caused
4. Multiple negative biological effects are seen (nerve, kidney, bladder, testis damage, blood brain damage and cognitive impairment) in a single species, (e.g. rat) when a single level of EMR radiation is applied (e.g. 900 MHz)

Table 1: Multiple Species Show Various Negative Biological Responses to EMRs

Barnes & Greenebaum  (2020) (25) state: ”ICNIRP have not found sufficient evidence to include health effects of long‐term exposures at lower levels. However, over the last 20 years the evidence has become extremely strong that weaker EMR over the whole range for frequencies from static through millimeter waves can modify biological processes. There is now solid experimental evidence and supporting theory showing that weak fields, especially but not exclusively at low frequencies, can modify reactive free radical concentrations and that changes in radical concentration and that of other signaling molecules, such as hydrogen peroxide and calcium, can modify biological processes.”

Barnes & Greenebaum  (2020) (25) also state: “ … it is not clear whether the biological effects seen for lower levels of exposure and long‐term exposure are not resulting in medical problems for a much larger number of people. Additionally, there seem to be a smaller number of “hypersensitive people” who have very real and serious problems that they believe are based on exposure to weak RF fields. What is missing in the current guidelines or regulations are guidelines for long‐term exposure to weak EMR.”

Negative non-thermal biological effects from EMRs seen in many peer reviewed scientific articles reviewed by Pall (2018) (1) are as follows:

1. Lowered fertility, including tissue remodeling changes in the testis, lowered sperm count and lowered motility and other measures of lowered sperm quality, lowered female fertility including ovarian remodeling, oocyte (follicle) loss, lowered estrogen, progesterone and testosterone levels (that is sex hormone levels), increased spontaneous abortion incidence, lowered libido (25 articles).

2. Neurological/neuropsychiatric effects including sleep disturbance/insomnia; fatigue/tiredness; headache; depression/depressive symptoms; lack of concentration/attention/cognitive dysfunction; dizziness/vertigo; memory changes; restlessness/tension/anxiety/stress/agitation; irritability (29 articles).

3. Effects on cellular DNA including single strand and double strand breaks in cellular DNA and on oxidized bases in cellular DNA; also evidence for chromosomal mutations produced by double strand DNA breaks. These produce all of the important type of mutations, as described at the DNA level that have roles in cancer causation and in human whole organism mutation (24 articles).

4. Apoptosis/cell death (an important process in production of neurodegenerative diseases that is also important in producing infertility responses) (15 articles).

5. Oxidative stress/free radical damage (important mechanisms involved in almost all chronic diseases; direct cause of cellular DNA damage) (25 articles).

6. Endocrine, that is hormonal effects; Includes changes in non-steroid and also steroid hormones (15 articles).

7. Increased intracellular calcium levels, thought to be the cause in all other effects (16 articles).

8. Cancer including initiation, promotion and progression, further including tumor progression, tissue invasion and metastasis) (39 articles)

9. Cardiac effects, include tachycardia, arrhythmia and bradycardia (with bradycardia typically reported after long times of exposures). Some recent studies have also reported heart palpitations. Arrhythmias, especially when they are associated with either bradycardia or severe tachycardia, are often associated with sudden cardiac death. Sudden cardiac death causes over 5% of the total mortality in technologically advanced countries, so this could be a major source of EMR-caused fatality. (9 articles)

Tables 2, 3 & 4 further list other and more recent low level non-thermal EMR biological effects which I have found by searching Entrez Pubmed (https://www.ncbi.nlm.nih.gov/pubmed/). These are just a fraction of the non-thermal EMR biological effects that there are in the literature as some of the articles go back as far as the 1970’s. Wilke (2018) (19)

Pall (2018) (1) also states that there are 26 different studies that have shown that EMRs produce diverse non-thermal effects through voltage gated calcium channels (VGCCs) in our cells and produce negative biological effects such as oxidative stress, cellular DNA damage and increased calcium signalling. The voltage sensors of the VGCCs are very sensitive to low intensity EMRs causing increases in intracellular calcium which has downstream very large pathophysiological effects and major cell damage. The voltage sensor of the VGCC is the predominant target of the EMR radiation and as such is currently ignored by the current safety guidelines of the ICNIRP. The effects of VGCCs are also backed up by & Doyon PR et al, (2017) (8) Herbert MR & Sage C (2013). (15)

Pall (2018) (1) quotes: The failure of the "safety guidelines" to discuss the relevant physics of the voltage sensor means that the physics underlying the “safety guidelines” is deeply flawed.’ 

The ICNIRP safety guidelines further ignores many publications which show non-thermal effects of EMR radiation - see pages 22-32 of Pall (2018). (1)

This means that the current situation in the United Kingdom is a similar violation of Human Rights as was tabled to the United Nations Human Rights Council in early 2019 for Australia by S.J. Toneguzzo. See below UN NGO document link:

https://www.radiationresearch.org/wp-content/uploads/2019/03/pace-UN-Human-Rights-Council-5G-statement.pdf

The deployment of 5G without safety testing in the UK violates over 15 international agreements, treaties and recommendations, including article 7 of the International Covenant on Civil and Political Rights, which derives from the Nuremberg Code of 1947, i.e. “No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment. In particular, no one shall be subjected without his free consent to medical or scientific experimentation.”

(see below document link):

https://treaties.un.org/doc/publication/unts/volume%20999/volume-999-i-14668-english.pdf

It also violates the Declaration of Helsinki of 1964 and its several revisions, as well as other international guidelines that have been translated into national laws in various countries, because it “is the duty of physicians who are involved in medical research to protect the life, health, dignity, integrity, right to self-determination, privacy, and confidentiality of personal information of research subjects.” (Principle 9, page 1 of below document)

https://www.wma.net/policies-post/wma-declaration-of-helsinki-ethical-principles-for-medical-research-involving-human-subjects/

But Public Health England and the UK government are in effect not protecting public health by ignoring the overwhelming amount of scientific literature that points to EMR radiation which damages rather protects the health of the UK population.

The above mentioned UN NGO document provides clear parallels between the tobacco industry strategy and the regulatory and research capture by the wireless industry today.

Ziskin, M. (2013) (4) states: “The resulting “millimeter wave signal” is transmitted through the cutaneous nerve through the dorsal root ganglion into the spinal cord [Radzievsky et al.,2001]. At the first synapse in the spinal cord, there is a release of endogenous opioids. The release of endogenous opioids occurs in at least two other spots in the brain. The subsequent release of endogenous opioids into the blood stream spreads these chemicals throughout the body, and certainly is adequate for explaining why pain relief can result from MMW exposures. The involvement of endogenous opioids in MMW therapy is verified by the fact that the beneficial effect of MMW therapy is completely abolished upon the administration of naloxone, a general opioid inhibitor [Radzievsky et al., 2000, 2008]. Opioids are also known to have wide-ranging effects on various systems in the body including the immune system. The transmission of the MMW signal through the cutaneous nerve is verified by the fact that the beneficial effect of MMW therapy is completely abolished by severing the nerve leading to the spinal cord”.

Treatments that are therapeutic in moderation are harmful in an overdose situation. A constant release of opioids, stimulation of the immune system and cell growth in conjunction with DNA mutations (e.g. cancer), might see the UK population significantly harmed.

A recent BBC news article (see below link) described Dr Simon Clark, associate professor of microbiology at Reading University as saying, “"The idea that 5G lowers your immune system doesn't stand up to scrutiny.” 

https://www.bbc.co.uk/news/52168096

However, multiple areas of electromagnetic systems negatively impact the immune system including frequencies relevant to 5G i.e. both ELF-EMR and RF-EMR evidence exists in the literature. I have listed four peer reviewed scientific papers below to illustrate this in Table 2 below:.

Table 2: Negative Immune Responses as result of EMR radiation

Pall (2019) (2) states we now have available to us, two translated CIA documents (Zalyobokskaya NP, 1977) (27) and (Levedeva NN, 2000 (28) which show the following:

5. Biological effects by low intensity continuous millimeter wave radiation which are 20 times deeper than what is claimed by industry, occur to the internal organs of rodents including heart, kidney, liver, spleen and bone marrow. There are even more severe effects on the skin of the rodents (Zalyobokskaya NP, 1977) (27)
6. The biological effects seen by Zalyobokskaya NP, 1977(27) are modest at first that can be reversible with cessation of exposure but become much more severe with increasing times of exposure.
7. Levedeva NN, 2000 (28) did EEG study where electrical activity in the brain was being monitored. Here for the low intensity millimeter continuous wave EMR exposure to have effects, it had to penetrate the hair, skin, skull and meninges surrounding the brain. Human effects are found at least 20 times deeper than the industry claims is possible.

This is also what I am seeing by scanning the literature:

a)      The findings of Zalyobokskaya NP, 1977 are matched by my search of the literature in Tables 2 & 3 and summarised in Table 1 after which I have said that the effects of low level EMR radiation are seen across multiple organs (see above, page 7, point 2).

b)      Lazlo et al 2018 (Table 3) show that after a 1-wk-long adaptation period, EMRs of 10 μT  at 50 Hz applied to turkeys for 3 weeks result in a decreased NE-activated β-adrenoceptor function in treated birds in a time-dependent manner, but during a 5 week regeneration period, the decreased NE-dependent β-adrenoceptor function could be compensated by the homeostatic complex. This supports the reversibility of effects seen by Zalyobokskaya NP, 1977.(27)

c)       Mortazavi & Mehdizadeh (2019) (Table 3) replot data from Morgan et al (2015) (26) and show evidence which supports a nonlinear J-shaped dose-response relationship for the carcinogenesis of non-ionizing RF-EMR from mobile phone radiation. This also supports the cumulative effect of EMR radiation seen by Zalyobokskaya NP, 1977.(27)

• What needs to happen to ensure the Government’s ‘outside in’ approach successfully addresses the digital divide while also delivering value for money?

Value for money should not be at the cost of human health. It is clear to me that in order for our health and wellbeing to be protected long term, there needs to be a realisation by the UK government of the large bodies of scientific data now pointing to very real negative biological responses, as a result of long term EMR radiation. Maximum effort needs to be taken by the UK government to enable the population to access digital services if the public needs them, but not to subject the public to continuous exposure in order to get access to these digital services.

Digital connectivity is still viable with protective measures by using fibre optic wired technology for our homes, hospitals, workplaces and schools - see Sage & Burgio (2018) (4) which states: “Symptoms of retarded memory, learning, cognition, attention, and behavioral problems have been reported in numerous studies and are similarly manifested in autism and attention deficit hyperactivity disorders, as a result of EMR and RFR exposures where both epigenetic drivers and genetic (DNA) damage are likely contributors. Technology benefits can be realized by adopting wired devices for education to avoid health risk and promote academic achievement.”)

Wilke (2018) (19) analysed more than 100 scientific articles on 2.45 GHz radiation (level used for Wi-Fi), and found associated adverse changes in most of these studies compared to the control groups at levels below the safety guidelines of the ICNIRP. She states: “Wired solutions should be given preference. Current exposure limits and SAR values do not protect from health risks associated with Wi-Fi radiation. The adverse effects on learning, attention, and behavior serve as a basis for educational institutions of all age groups to forgo the use of Wi-Fi applications. Due to cytotoxic effects, Wi-Fi technologies are not suitable for hospitals and telemedicine. Wi-Fi technologies should not be used in bedrooms, work spaces, common lounges, hospital rooms, lecture halls, classrooms, and public transport. The possible risks associated with Wi-Fi radiation could be avoided by testing alternative technologies at other frequency bands like optical VLC/Li-Fi technologies (visible light communication). When Wi-Fi cannot be avoided as a transition solution, the ALARA principle must be applied: no continuous transmission, instead Wi-Fi networks that can be turned off and feature dynamic power management.”

Precaution and appropriate risk management are not just about physical health, but also an issue of economics. Both matters need to be considered in determining the public benefit and hence the national interest. The economy will also be affected if large numbers of our population are sick due to long term EMR radiation exposure and a sick population will cause NHS costs soar, which will in effect, damage the economy, thereby delivering the opposite of value for money. Keeping the population healthy for longer periods of time, enables the population to give longer periods of service in work, and thereby boosts the economy.

Democratic freedom in this country needs to be safeguarded, so that the policy of unlimited economic freedom is replaced by planned economic intervention of the state. Unrestrained capitalism needs to give way to economic interventionism for the wellbeing of the public. The economic freedom and self-regulation that has been accorded to technology firms by this government should be balanced with the need to protect the interests, health and well-being of the UK population. (See below link by Prof Tom Butler)

https://www.radiationresearch.org/wp-content/uploads/2019/10/On-the-Clear-Evidence-of-the-Risks-to-Children-from-Smartphone-and-WiFi-Radio-Frequency-Radiation-Final-2019.pdf

Belyaev et al. in the 2016 EUROPAEM EMR Guideline (18) state: “New wireless technologies and applications have been introduced without any certainty about their health effects, raising new challenges for medicine and society. For instance, the issue of so-called non-thermal effects and potential long-term effects of low-dose exposure were scarcely investigated prior to the introduction of these technologies. Common electromagnetic field or EMR sources: Radio-frequency radiation (RF) (3 MHz to 300 GHz) is emitted from radio and TV broadcast antennas, Wi-Fi access points, routers, and clients (e.g. smartphones, tablets), cordless and mobile phones including their base stations, and Bluetooth devices. Extremely low frequency electric (ELF EF) and magnetic fields (ELF MF) (3 Hz to 3 kHz) are emitted from electrical wiring, lamps, and appliances. Very low frequency electric (VLF EF) and magnetic fields (VLF MF) (3 kHz to 3 MHz) are emitted, due to harmonic voltage and current distortions, from electrical wiring, lamps (e.g. compact fluorescent lamps), and electronic devices. On the one hand, there is strong evidence that long-term exposure to certain EMRs is a risk factor for diseases such as certain cancers, Alzheimer's disease, and male infertility. …We recommend treating electromagnetic hypersensitivity (EHS) clinically as part of the group of chronic multisystem illnesses (CMI), but still recognizing that the underlying cause remains the environment. In the beginning, EHS symptoms occur only occasionally, but over time they may increase in frequency and severity. Common EHS symptoms include headaches, concentration difficulties, sleep problems, depression, a lack of energy, fatigue, and flu-like symptoms. A comprehensive medical history, which should include all symptoms and their occurrences in spatial and temporal terms and in the context of EMR exposures, is the key to making the diagnosis. The primary method of treatment should mainly focus on the prevention or reduction of EMR exposure, that is, reducing or eliminating all sources of high EMR exposure at home and at the workplace. The reduction of EMR exposure should also be extended to public spaces such as schools, hospitals, public transport, and libraries to enable persons with EHS an unhindered use (accessibility measure). If a detrimental EMR exposure is reduced sufficiently, the body has a chance to recover and EHS symptoms will be reduced or even disappear. Many examples have shown that such measures can prove effective… Anything that supports homeostasis will increase a person's resilience against disease and thus against the adverse effects of EMR exposure. There is increasing evidence that EMR exposure has a major impact on the oxidative and nitrosative regulation capacity in affected individuals.”

Di Ciaula A (2018) (9) state that “preliminary observations showed that millimeter waves (MMW) increase skin temperature, alter gene expression, promote cellular proliferation and synthesis of proteins linked with oxidative stress, inflammatory and metabolic processes, could generate ocular damages, affect neuro-muscular dynamics. …available findings seem sufficient to demonstrate the existence of biomedical effects, to invoke the precautionary principle, to define exposed subjects as potentially vulnerable and to revise existing limits.”

• What does take-up of broadband and mobile services indicate about consumer and business attitudes to digital connectivity? What needs to be learnt from this for the roll-out of, and switchover to, gigabit-capable networks?

Broadband and mobile device take up enables consumers and businesses to gain access to communications, services and mechanisms of purchasing and selling that was previously unavailable to them. This does not mean that they should all be switched over to, as an only mechanism of communication, purchasing and selling. The public should be given the choice of how they choose to connect with or not connect with digital media, particularly 5G, considering the safety testing of this emerging technology is yet to be done (see reference 11 below). Not all human beings choose to exist continuously connected with digital media, nor do they want to be subjected to untested, potentially harmful 5G. Ethical judgements used in the design of such technology needs to be transparent to the public, and we need a set of global principles that shape the  norms and standards that shape the emergence of 5G roll out. This has yet to be done.

Naren et al (2020) (24) state: “Different countries have different regulations to limit the radiation density levels caused by these devices. The radiation absorbed by an individual depends on various factors such as the device they use, the proximity of use, the type of antenna, the relative orientation of the antenna on the device, and many more. Several standards exist which have tried to quantify the radiation levels and come up with safe limits of EMR absorption to prevent human harm.” We need to ensure that we use the standards that specify safe levels of radiation based on the recognition of both thermal as well as non-thermal negative biological effects of EMR radiation.”

Currently, the UK is using a standard from the ICNIRP which only recognises thermal negative biological effects.  This means that not only has there not been any safety testing for 5G roll out, but the standards used by government are inadequate as they only recognise a small fraction of the negative biological effects caused by EMR radiation. This needs to be corrected immediately, and the UK government needs to recognise the standards set by the medical bodies such as the Building Biology, BioInitiative, and Austrian Medical Association Standards. These limits have been arrived at after extensive scientific research of thermal, non-thermal, chronic exposure, and biological effects carried out by health experts from across the world. On comparing these limits with those prescribed

by the ICNIRP, it can be seen that the limits prescribed by the medical bodies are several orders of magnitude lower than those prescribed by the ICNIRP. Therefore, a clear understanding of the differences between these limits, and an assessment of the current exposure levels in accordance with both kinds of exposure limits mentioned is desperately needed at present.

Furthermore, a significantly large body of peer reviewed scientific papers now indicate that gigabit-capable networks are predicted to be damaging to human health, as EMR radiation at levels 100K lower than those allowable by current ‘safety’ guidelines, cause actual biological damage to many types of cells not just human. (see Tables 2, 3 & 4 which list all the scientific papers I have pulled out for Entrez Pubmed by just putting int the search team ‘EMR radiation’ and which describe multiple negative biological effects in many species). Of note are the biological indicators in Table 4 below such as bee colony collapse, bee developmental delay and bee motor damage and this is backed up by news articles such that  written by Jo Lamiri in the Independent: (3 August 2018) stating: “one-third of the UK’s bee population has disappeared over the past decade and 24 per cent of Europe’s bumblebees are now threatened with extinction.” https://www.independent.co.uk/life-style/food-and-drink/national-honey-bee-day-save-species-decline-pollinators-environment-pesticides-a8461426.html

Do we really want to wait until we have damaged so many species including ourselves before we stop and take stock of what we are doing to ourselves and to our environment?

If such gigabit-capable networks are not managed with a true understanding of the wealth and breadth of scientific data that is currently published, we will only know its damaging impact many years hence, and then it will be too late, as the damage will then already have been done to us, and subsequent generations and to our delicate ecosystem.

A roll-out therefore first of all, needs to address the current lack of understanding by government and the PHE of the wealth of scientific data that points to real biological negative effects, and then think about ways to limit that damage to our population.

The Nuremberg trials and subsequent Code were supposed to ensure that never again would a population be experimented upon or harmed without consent. Surely it is morally and legally (both in UK and under international law) wrong for Public Health England to condone or support flawed guidelines by the ICNIRP which flagrantly disregard key scientific data pointing to non-thermal negative biological effects of pulsed EMR radiation, in all manner of species? (e.g. Halgamuge MN. (2017) – see Table 4)

The mobile and broadband industry are making statements that are on face value misleading and deceptive and forcing foreseeable risk of harm upon a partly non-aware (e.g. misled), and partly aware and non-consenting population. See their comment from the Guardian below:

https://www.theguardian.com/technology/2020/mar/12/5g-safe-radiation-watchdog-health?CMP=share_btn_fb&fbclid=IwAR3NS278WnlqENmtaAd1CVy4jHWH_Y0L0cDiu6fBMcsOSG6HMWaCCnNnqNA

“But millimetre-wave 5G, and other broadcast connections above the 6GHz band, “were not anticipated in 1998”, according to Dr Jack Rowley, the senior director for research and sustainability at GSMA, the industry body for mobile network operators.

Higher frequencies interact with organic tissue differently, dissipating more energy at the surface and penetrating less, which means the new standards take measurements across a smaller cross section, and specifically pay attention to the power absorbed by, rather than simply exposed to, a body.

“The most important thing is that the fundamental health risk assessment is unchanged,” Rowley said. “The limits that we had in 1998 are still protective now.”

However, Denis Henshaw, Emeritus Professor of Human Radiation Effects, School of Chemistry, University of Bristol, states in the following article:

“The idea that since cell phone radio waves do not have the quantum energy to damage DNA and therefore cannot cause ill health is a fallacy. It is flawed at a number of levels, from the very physics upon which it is supposedly based, to chemistry and biology. Most of all, the idea is not born out by the tens of thousands of peer-reviewed studies reporting biological effects from exposure to electric, magnetic and electromagnetic fields and electromagnetic radiation, including those associated with radio wave frequencies used by cell phones.”

https://ehtrust.org/wp-content/uploads/Henshaw-2019-Non-ionising-radiation-quantum-energy-fallacy-11th-April.pdf

Hertzgaard and Dowie (2018) (21) further state that “ the wireless industry has obstructed a full and fair understanding of the current science, aided by government agencies that have prioritized commercial interests over human health and news organizations that have failed to inform the public about what the scientific community really thinks. In other words, this public-health experiment has been conducted without the informed consent of its subjects, even as the industry keeps its thumb on the scale.”

Wilke, I (2018) (19) also states: “The potential health impact of Wi-Fi, even at low exposure levels, can no longer be called into question or relativized away, not even by those studies that found no effects. The decision-makers in government, school boards, and health agencies have a responsibility to deal with the available body of research and not to be deceived by the arguments of the industry lobby or boilerplates of government institutions. Health risks are a reality.

• What will be the impact on individuals and communities whose broadband and mobile connectivity fails to keep pace with the rest of the country over the next 10 years? What is the link with other DCMS policy concerns, such as changing patterns in the consumption of digital media?

Not everyone in every community in this country needs or wants superfast broadband / mobile connectivity.

Individual connectivity needs are different across this country. 5G roll out should only ever have been considered:

1. after appropriate safety testing had been completed by the mobile and broadband industry as well as independent scientific bodies and
2. after consultation with people in this democratic country as to its downstream health, economic and sociological impact on our future overall wellbeing

If gigabit connectivity is necessary for particular industries, it behoves this government to ensure it is available in a manner that doesn’t compromise the safety, health and wellbeing of the rest of the UK, where lower speed connectivity is sufficient for a given community. Where gigabit connectivity has to be installed for functional and economic reasons, a solution should be sought which removes long term EMR exposure of all constituents in that area, by using wired fibre optic solutions, thereby also removing detrimental health effects due to wireless EMR-instigated negative biological responses which is likely to result in chronic and possibly acute diseases in the future, in exposed populations. Naren et al. (2020) (24) state: “The carcinogenic nature of EMR which results in mutation of sperm cells as well as testicular cancer has also been reported [22]. Thus, the probability that future generations will inherit unhealthy or low-immunity genes is also increased.”

My scan of the literature (Table 4) shows the existence of damaging outcomes to multiple reproductive systems both human (Santini et al 2018) and other species like rat (Sepehrimanesh et al 2017; Yang et al 2018; Oh et al 2018) and mice (Li et al 2017), by EMR radiation which backs up Naren et al. (2020) (23) in their prediction above that future generations are most at risk. Both Pall (2018) (29) and Wilke (2018) (19) advocate getting rid of Wi-Fi in schools to protect future generations as well as teachers from EMR damage.

Santini et al. (2018) (17) after showing oxidative stress effects of EMR radiation in male and female reproductive systems urge that we should be aiming to get “a better understanding of the molecular mechanisms underlying EMR potential challenge to our reproductive system in order to improve preventive strategies.”

Regarding existing 5G networks which have already been installed in various parts of the UK without consulting local residents who are uninformed about the dangers of 5G : such affected residents should be retrospectively informed as to the massive body of scientific data that points to negative non-thermal biological responses to pulsed electromagnetic radiation, and told that existing 5G has had no safety testing.  They should be told that existing installations will be decommissioned until further notice, and that future 5G roll outs will be halted, until adequate safety testing has been conducted. It is very likely that already deployed installations of 5G are already having a direct, negative, cumulative effect on the short term and long term health of the UK public. For example, having read the literature, it is clear to me that one of the biological responses to continuous exposure to electromagnetic radiation is to also negatively affect the behaviours of autistic individuals - see link below and in Table 4 of this document.

https://bioinitiative.org/wp-content/uploads/pdfs/sec20_2012_Findings_in_Autism.pdf

• How effectively do the different stakeholders (UK and devolved governments, local authorities, Ofcom, industry) work together in both the mobile and broadband sectors? How might these relationships be improved to support gigabit-capable roll-out?

From what I have seen of how current stakeholders work in the government, PHE, AGNIR, HPA, local authorities and Ofcom, we need a rethink of how they assess the safety, ethics and use of not just mobile and broadband technologies but others as well. It is clear to me, that they heavily rely on a non-independent body (ICNIRP) for their safety guidelines on current EMR radiation limits. Not only that, they are too heavily reliant on segregated government bodies and the mobile and broadband industry themselves, for their understanding of EMR emitting emerging technologies.  These bodies need to have members of the public as independent scrutinisers in order for them to be held accountable to ensure that they are indeed acting in the best interests of all of the UK population.

Clearly the AGNIR and the HPA too are governed by the flawed safety guidelines of the ICNIRP as they state on the below website the following:

https://www.gov.uk/government/publications/radiofrequency-electromagnetic-fields-health-effects/health-protection-agency-response-to-the-2012-agnir-report-on-the-health-effects-from-radiofrequency-electromagnetic-fields

See below AGNIR and HPA’s statement on health effects from radiofrequency electromagnetic fields:

“AGNIR’s main conclusion is that, although a substantial amount of research has been conducted in this area, there is no convincing evidence that RF field exposures below guideline levels cause health effects in adults or children. These “guideline levels” are those of the International Commission on Non-Ionizing Radiation Protection, which already form the basis of public health protection in the UK and in many other countries.

AGNIR concludes there is increasing evidence that RF fields below guideline levels do not cause symptoms and cannot be detected by people, even those who consider themselves sensitive to RF fields. HPA agrees with AGNIR that this does not undermine the importance of the symptoms that are experienced, but it does suggest causes other than those directly related to RF fields should be considered.  HPA will undertake another comprehensive review of the scientific evidence and its advice when sufficient new evidence has accumulated.”

See also below statement by the HPA on smart meters:

“The results confirm PHE’s existing advice that exposure to radio waves from smart meters is well below the guidelines set by the International Commission on Non-Ionizing Radiation Protection (ICNIRP).”

As long as the health governing bodies that advise the government like the PHE, AGNIR, HPA, and Ofcom are blinded by the flawed guidelines of the ICNIRP, and not bothering to look at actual biological data such as that in Tables 2, 3 & 4 that I have pulled out of Entrez Pubmed, the government too, will continue to make misguided decisions. There needs to be a major rethink in government to understand that real scientists are speaking out to alert them of the dangers of EMR radiation to the public. If nothing else they need to stop allowing industry to upgrade mobile and digital technology without doing adequate safety checks and without consulting the public. This is the case, especially when it comes to wireless connectivity, which involves exposure of the unaware public, of just how damaging low level EMRs are, to humans, as well as all species. There is enough data out there now, for the UK government to be held accountable for blinded decisions.

I don’t think that PHE, AGNIR or HPA are independently assessing the scientific data, or like me, they would have come to the conclusion that low level EMRs are having a direct, visible, detectable, measurable and negative biological impact on multiple species not just humans, which needs to be understood and managed safely, rather than allowing the mobile and broadband industry to upgrade to more penetrating and more pervasive digital technologies like 5G, which will require more dense 5G base stations in the network, thereby exposing the public to several fold higher and continuous EMR radiation than ever before, (see Naren et al 2020 (23)) without adequately considering the impact of such frequencies on the health of the public and the ecosystem around us. The UK government needs to be aware that due to the base station density required for 5G to be effective, the UK public will be exposed to 60GHz frequencies of EMR radiation indoors and outdoors with no chance of ever being able to switch it off. This is dangerous and all the scientific peer reviewed data for 2G-4G frequencies (1900 MHz – 2.6GHz) is already pointing to damaging biological effects for frequencies of EMR radiation from existing digital sources (see Tables 2, 3 & 4).

It is important when scientists worldwide, are calling for a moratorium, on the roll out of 5G, for reasons that lower frequencies than 5G are already causing negative biological responses, that questions should be asked of the above stakeholders, i.e. the UK and devolved governments, local authorities, Ofcom and the mobile and broadband industry, by an independent scientific committee (ISC).

This committee should consist of:

1. Representatives from the scientific community who are independent of the mobile and broadband industry
2. Concerned members of the public with no overt affiliation, and
3. Members of EMR-aware public-centric organisations like that of the Radiation Research Trust and PHIRE (Physicians' Health Initiative for Radiation and Environment).

Such an ISC should ask the above stakeholders how future emerging microwave technologies like 5G are being assessed for:

1) overall public benefit (not just economic but sociological)

2) overall public wellbeing (physical and mental) and

3) continued health of future generations in the UK.

All three of the above criteria need to be met before emerging technologies like 5G are disseminated within the population. This is not the case with 5G as we already know that already deployed EMR radiation at lower frequencies than 5G has negative effects on our physical wellbeing, and exposure to these frequencies is having a negative effect on future generations such as our adolescents (Meo et al. (2019) (Table 1)  and children (Fernández et al. (2018) (Table 4).

Barnes & Greenebaum (2020) (25) believe a carefully targeted program of (government) research funds is called for, supplemented by communications system operators and corporations that manufacture equipment, under independent scientific management. Both governmental and private entities that emit RF signals would be well advised to fund research to elucidate and define threshold signal levels for the generation of long‐term biological effects.

My understanding of having written to my Mayor and MP on the topic of EMR radiation, is that they heavily rely on another government body such as PHE, to inform them of the safety of emerging technologies like 5G, who in turn rely on another non-independent body such as the ICNIRP.  If a body such as the ICNIRP displays any scientific bias when assessing the biological impact of emerging  EMR technologies such as 5G from the mobile and broadband sectors, without adequate concern for public health, this results in misguided policy making by this government, which will result in definite harm to our UK population.

MP’s, Mayors, PHE and planning committees need to use joined up thinking with respect to the public’s concerns of how and where and what 5G / gigabit installations are implemented. In my case, writing to my Mayor, he referred me onto the PHE to express my concerns, but I am aware that the PHE tries to absolve its powers to planning committees when it comes to the planning of 5G installations. Therefore, it is a mute action to send the constituent to another body which seems to be either not empowered or disinclined to make a difference to the request of halting an installation in the first place. Mayors, MP’s, PHE, Ofcom, planning committees and local city council digital teams should all work together to resolve matters of safety and public welfare – be they regarding our health, economic, sociological or environmental welfare. Each of these bodies need to be accountable and have a good understanding of the impact of their decisions regarding emerging technologies and their impact on existing and future generations as well as our environment. Currently, they seem to be passing the buck from one government department to the other, instead of taking ownership of the problem.

The disregard of the ICNIRP of important scientific data on EMR radiation harms, has resulted in the current situation in the UK where current PHE safety guidelines used by this government are deeply flawed, and unfortunately reams of peer reviewed scientific data pointing to very real negative biological responses to EMR radiation, in humans and other species, have been ignored. This problem can only be resolved by concerned scientists like myself speaking out, to highlight current misguided decisions by government stakeholders, without truly considering independent science which has been shouting to the tree tops, that the global health of humans and other species is being damaged by rampant and ever increasing EMR radiation.

The UNESCO 2005 Precautionary Principle (PP) (22) states: ”Companies need to become partners  with  the  public  and  the  administration, and they thus need to adopt a principled attitude of transparency and knowledge sharing….Yet, precaution typically involves public consultations, deliberations and hearings that may focus on selected side effects or possible harms.  Such consultations are often deemed avoidable and obstructive by business. Yet product development strategies that do not take account of community values will often place the company in the position of having to defend risky products.  The call for precaution is then seen as anti-industrialist, anti-innovation and anti-technology. Yet, several companies now realize that this can be avoided if their product development is made more flexible and responsive to outside input from the very beginning. …To the extent that companies manage  to  integrate the spectrum of outside concerns at an early stage, they stand a better chance to come up with products  that are widely seen as good solutions. Precautionary measures should in any case be judged transparently on a case-by-case  basis, and be subjected to scrutiny from many parties….Implementation of the PP needs to accommodate various cultures of risk regulation and  administrative  regimes, while still addressing the basic tenets of the PP (uncertainties, science, values, transparency and participation, etc.)

Where in the roll out of 5G has there been any address to the public of its safety?

Where is the scientific data which should have been scrutinised by many parties regarding 5G being a good solution for better and safer connectivity?

I have seen none.

There has been no attempt by the companies that have rolled out 5G to become ‘partners with the public.’ In fact the public are unaware of the safety data around 5G, they have not been involved in its roll out, and there has been no deliberations involving the public in the UK that have addressed side effects or possible harms. In fact the Precautionary Principle has been completely ignored with respect to 5G roll out.

This needs to be addressed urgently by the government and all stakeholders.

Much of the scientific evidence is pointing to deep concern regarding the dangers of 5G to our human population as well as even greater danger to delicate smaller mammals, birds and insects which “will be heavily impacted because of their large surface to volume ratios. The same thing will be true of plants where even large trees have their leaves and reproductive organs highly exposed.” Pall 2019 (2) This is because the type of radiation that 5G consists of, is the type where due to its “low penetration and very high energy deposition per unit distance, this can lead to generation of high levels of free radicals in a short distance which in turn increases the risk of skin cancer.” Mortazavi & Mehdizadeh (2019) (25).

Naren et al (2020) (23) state:  “5G is set to use frequencies between 30 GHz and 100 GHz and would have a bandwidth of 60 GHz, which is much higher than all previous generations. Owing to the increased frequency, the wavelengths in 5G communications will be in the order of few millimeters. Shorter wavelengths travel shorter distances; therefore, 5G networks will be much denser compared to existing networks. This necessitates that more base stations be placed at much closer distances in order to achieve good coverage… in the case of 5G networks, the base station (BS) density is expected to be increased to about 40-50 base stations/km2 due to the high propagation loss of millimeter wave technology. The area served by each base station in 5G networks is very small and is commonly called a small cell. The shorter millimeter waves would also not be able to penetrate building walls effectively. Therefore, the 5G architecture will separate indoor and outdoor networks, which means there will be separate access nodes for indoor users. 5G BSs will also be installed on street light poles meaning that people will be extremely close to the BS antennas, whether they are indoors or outdoors. In addition, 5G will also employ relay nodes that amplify the wireless signals from the BSs before they reach the device. The high data rate requirement of 5G, which is around 1000 times more than 4G, is expected to be solved by the use of massive-MIMO technology, which incorporates a large number of antennas. Thus, 5G networks contain Macrocells, microcells, relays, street light access points and separate indoor nodes, which operate simultaneously all the time. Due to the extremely high density of BSs, street light access points, separate indoor BSs, relays and Massive MIMO technology employed in 5G, a person will be exposed to very high levels of power flux densities (PFDs), whether he is indoors or outdoors, or whether or not he is using any wireless devices in close proximity. In other words, it may be suspected that even the ambient PFD which a person is exposed to in most situations throughout the day may fall under the category of `Severe Concern' according to the Building Biology Standard, `Far above normal' according to the AMA standards, and may be higher than the precautionary action level recommended by the BioInitiative Guidelines.”

Pall (2019) (2) predict that similar but much more severe effects are likely to be produced by 5G than seen currently. He also predicts that because of the roles of aqueous dissolved ions in producing these deep effects, that regions of the body with large such internal “bodies of water” may be expected to produce particularly severe problems.  These are as follows:

1. Various types of birth defects because of the role of the amniotic fluids and the increased extracellular water content in the tissues of the foetus.

2. Blindness due to the role of the aqueous and vitreous humours of the eye.

3. Kidney failure due to the water in the kidney.

4. Cardiac changes in the electrical control of the heart, because of the large blood fluids in the heart.

5. Circulatory problems, possibly including aortic and other arterial aneurisms.

5G technology that has been implemented in this country is untested as to the dangers it is placing mankind under. This is irresponsible and needs to be addressed as a matter of great urgency by our government and all our regulatory health bodies.

• What is the impact of COVID-19 on the roll-out of full-fibre and 5G infrastructure in both the short and medium-to-long term, including any differences in different parts of the UK?

Viral infections occur as a result of a dampened or inadequate immune system which is unable to fight the invader. Our ecosystem contains many natural anti-viral agents (e.g. neem) (Tiwari et al. (2010) (31) which are effective against viruses that occur naturally. However, when there is a highly virulent strain like COVID-19 prevalent in the environment, the ability of human beings to fight such infection depends on their inherent, pre-existing immune system. The state of that immune system is likely to be negatively impacted by electromagnetic radiation as seen by multiple papers citing negative immune biological responses to EMRs in Table 2:

1. Doyon & Johanssen (2017) suggest the following mechanism of action: EMRs cause a pathological increase in the influx of calcium into the cytoplasm of the cell, which induces a pathological production of reactive oxygen species, which in turn can have an inhibitory effect on calcineurin. Calcineurin inhibition leads to immunosuppression, which in turn leads to a weakened immune system and an increase in opportunistic infection.

2. Mahaki et al. 2019 find ELF-EMRs long-term (2-24 h/d up to 8 years) exposure to low-density ELF-EMR may cause a decrease in adaptive immune response in rats

3. Valedez-Lira et al. 2017 found that the antimicrobial peptides cecropin, lysozyme, gallerimycin, and pgrp were downregulated by EMRs in moth larvae

4. El-Gohary et al. 2017 found that EMR exposure resulted in significant decrease in immunoglobulin levels (IgA, IgE, IgM, and IgG); total leukocyte, lymphocyte, eosinophil and basophil counts in rats

Therefore, in the light of an external environment which has a greater density of EMRs due to a 5G roll out, this is likely to cause an environment of dirty electricity, which increases the likelihood for the exposed human population to have:

1. a weakened immune system due to calcineurin inhibition which in turn causes immunosuppression

2. an increase in opportunistic infection as a result of a decrease in adaptive immune responses

3. downregulation in the expression of antimicrobial peptides

4. decreases in antibodies (immunoglobulins) and cells that defend the body against infection like leukocytes, lymphocytes, eosinopils and basophils

The impact of denser EMRs in the UK environment is not going to help the COVID-19 situation with respect to enabling our human population to fight infections effectively, for the above four listed biological reasons. There is no safety testing data on 5G which has already been rolled out in the UK, and so it becomes even more urgent to ensure that hospitals which house infected individuals are free of electromagnetic radiation, so that both patients and NHS staff are given the best chance to fight the virus in a electromagnetically clean environment.

It therefore behoves the UK government to urgently re-evaluate their 5G roll out strategy in the light of negative biological evidence with respect to EMRs and therefore the same is even more likely for 5G, which point to the likelihood of very real negative genetic, biochemical and morphological effects that will surely occur in time and are probably already concurrent, as I write, in our population as a result of polluting EMRs in our environment.

I have presented here, positive actions to implement broadband connectivity more safely across the UK, i.e. using wired fibre optic technology, which will be in the best interests of all our people, our environment and the delicate ecosystem around us. I have suggested ways and means to resolve the existing unknowns around the safety of  5G (Summary, Point 14, page 3&4 of this document) so that the mobile and broadband industry which produces products and services which are held accountable to the public.

This will require the UK government to implement a strategy which uses independent intervention and scrutiny by non-industry led scientists and stakeholders (see page 19, paragraph 2 above for constituents of an ISC) who can probe all safety testing data by the mobile and broadband industry as well as associated scientific studies by independent scientists, so that the mistakes made by governments globally in allowing the tobacco and fossil-fuel industries to proliferate without adequate regulatory and economic control, will not be repeated in the wireless industry as well.

Table 3: More Negative EMR effects Published in the Literature

Table 4: Comparison of EMR Safety Standards compiled from Naren et al. 2020 (23)

References

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