Dr Isaac Jamieson, Dr Erica Mallery-Blythe – Written Evidence (BEN0216)

 

There many planning issues that need to be addressed in order to create the maximum benefits for the country and its inhabitants.

 

1. ELECTROMAGNETIC RADIATION AND THE DESIGN OF THE BUILT ENVIRONMENT

Mains frequency magnetic fields and radiofrequency electromagnetic fields (RF EMFs) are classified as group 2B carcinogens (WHO/IARC 2011, 2002). Recently there have been calls to upgrade RF EMFs to a group 2A, or even a group 1 carcinogen (Morgan et al. 2015, Hardell & Carlberg 2013). There is also evidence excess electrostatic charge and mains frequency electric fields can negatively impact health at levels that can be encountered in the built environment (Jamieson 2014, Jamieson et al. 2010). Appropriate design of the built environment can greatly reduce such risks.

 

THE INSURANCE INDUSTRY PERSPECTIVE

Many insurance companies (including those providing cover for architectural and engineering firms) are now refusing to cover claims linked with electromagnetic radiation (EMR) (AVIVA 2015, HCC 2015, Hiscox PLC 2015). This development will greatly influence how the built environment is designed. Appropriate guidance, including best practice measures, are required within planning policies to reflect this change.

 

Already legal actions are being won for individuals who have had their health damaged by electromagnetic pollution (BBC 2015, GSMA 2013, WEEP News 2011). [Electrohypersensitivity [EHS] can be identified using disease biomarkers (Belpomme et al. 2015)].


BACKGROUND INFORMATION

The review undertaken of 919 studies by Rahmani et al. (2011) revealed that the majority of studies on electro-magnetic fields (EMFs) report biological effects as a result of exposure (Figure 1).

 

 

Figure 1: The majority of peer-reviewed EMF papers indicate biological effects.

 

Similar findings were made in the review of 113 RF EMF studies by Cucurachi et al. (2013) [where around two thirds documented effects], and the review by Yakymenko et al. (2015), related to low intensity RF radiation (RFR), which found that: “… among 100 currently available peer-reviewed studies dealing with oxidative effects of low-intensity RFR, in general, 93 confirmed that RFR induces oxidative effects in biological systems.” [There are both direct and indirect connections between oxidative stress and around 200 human diseases. Oxidative stress is also recognised as a contributing factor to aging (Hybertson et al. 2011)]. The provision of healthier EMF environments should be part of National Planning policy to better protect both humans and the environment.

 

OPINIONS GIVEN ON ENVIRONMENTAL EMR EXPOSURES

PROFESSOR PAOLO VECCHIA AND ICNIRP

“… the ICNIRP guidelines are neither mandatory prescriptions for safety, the “last word” on the issue nor are they defensive walls for Industry or others,” Professor Paolo Vecchia [ICNIRP Chairman from 2004-2012] (Vecchia 2008). “... children, the elderly, and some chronically ill people might have a lower tolerance for one or more forms of [non-ionising radiation] exposure than the rest of the population,” (ICNIRP 2002). [Note: The UK presently adheres to ICNIRP (1998) guidelines].

 

TELECOMMUNICATIONS INDUSTRY

Members of the telecommunications industry too appear to have concerns over EMFs: "I want to be very clear. Industry has not said once - once - that ... [RF / microwave radiation is] safe. The federal government and various interagency working groups have said it is safe," K. Dane Snowden [when Vice President, External & State Affairs of CTIA-The Wireless Association. The CTIA is the International Association for the Wireless Telecommunications Industry] (Safeschool 2010).

Additionally, a major telecommunications provider is on record as stating: “The influence of electrosmog on the human body is a known problem. ... The risk of damage to health through electrosmog has also become better understood ... When, for example, human blood cells are irradiated with electromagnetic fields, clear damage to hereditary material has been demonstrated and there have been indications of an increased cancer risk,” Swisscom AG (2003).

 

SCIENTISTS

The above health-related concerns are shared by a growing number of scientists:

In 2015 an international appeal that has now been signed by over 200 scientists was submitted to the United Nations, UN member states and the WHO requesting that more protective EMF exposure guidelines be adopted (EMFscientist.org 2015).

 

ADVERSE HEALTH CONDITIONS LINKED WITH EMR

An increasing number of studies indicate adverse health effects as a result of environmental exposure to electromagnetic pollution. There is substantial evidence indicating that even low intensity EMF exposures can cause ill health. Conditions linked with environmental EMF exposures include:

 

Cancer (Coureau et al. 2014, Moon et al. 2014, Hardell & Carlberg 2013); Alzheimer’s disease (Davanipour & Sobel 2009, Huss et al. 2009); Childhood & adult leukaemia (Dolk et al. 1997, Hocking 1996); Autism (Herbert & Sage 2012, Kane 2004); Immune system effects (Boscolo et al. 2001, Novoselova et al. 1999); Miscarriage (Li et al. 2002); Infertility (Avendaño et al. 2010, Otitoloju et al. 2010, Aitken & De Iuliis 2007); Asthma (Jamieson et al. 2010, Bach 1967); DNA damage (De Iuliis et al. 2009, REFLEX 2004); Oxidative stress (Kumar et al. 2012, Agarwal et al. 2009, Ilhan et al. 2004).

 

We suggest the cost to the National Economy of “electromagnetic pollution” runs into many billions of pounds in terms of reduced health, wellbeing and productivity. This situation can be reversed.

 

SLEEP QUALITY: The annual cost to the UK of chronic sleep deprivation has been estimated at £1.6 billion (Bupa 2010). Many studies indicate that individuals sleep better in environments with very low EMF levels compared to those with even slightly raised EMF levels. As examples: Improved sleep has been noted in low-field environments with exposures of 0.05-0.22 V/m (0.0006-0.0128 µW/cm2) compared to 0.25-1.29 V/m (0.0165-0.4400 µW/cm2) (Oberfeld et al. 2004) and for 0.7 V/m exposures compared to 1.17 V/m exposures (Eger & Jahn 2010).

 

Sleep problems have been reported after wireless smart meter roll-outs which increase individuals EMF exposures 24/7 (Lamech 2014, Conrad & Friedman 2013, Halteman 2011). [Contrary to popular belief, smart meters are not compulsory (StopSmartMeters!UK 2014, Hansard 2011)].

 

Additionally, a dose-response relationship has been shown between sleep-related fatigue and injuries (Swaen et al. 2003), and almost 20% of all serious car crash injuries are associated with driver sleepiness (Connor et al. 2002).

 

Promoting the creation of low EMF building layouts and environments, and the specification of low EMF technologies, as a matter of best practice would help significantly reduce sleep deprivation, thereby improving health, wellbeing and productivity.

 

DEPRESSION: Suicide is the leading cause of death in England and Wales for men between 20-49 years old, and one of the main causes of death among 5-19 year olds (ONS Digital 2015). Depression is a gigantic public health burden that exceeds other common sources of morbidity and mortality. [In England in 2000, the annual cost of depression was estimated to be £9 billion (Thomas & Morris 2003)]. Individuals with depression are at heightened risk of: Alzheimer’s disease; Cancer; Diabetes (type 2); Epilepsy; Obesity; and Stroke (BC’s Physicians 2009).

 

Oberfeld et al. (2004) noted depressive tendency with 900/1800 MHz exposures of 0.25-1.29 V/m (0.0165-0.4400 µW/cm2) compared to 0.05-0.22 V/m (0.0006-0.0128 µW/cm2) (p = 0.0016). Others have made similar findings (Eger & Jahn 2010, Bortkiewicz et al. 2004, Santini et al. 2002). [Many wireless smart meters create RF EMF exposure levels above those associated with increased depressive tendency].

 

EFFECTS OF EMR ON BIOIVERSITY: Creating more natural built environments can be cost effective, increase biodiversity and be highly beneficial on many levels. Unfortunately, Nature too can be adversely affected by electromagnetic pollution. As examples:

 

Ants: Ants perform many vital services including: pollination, predation and seed removal and dispersion. Exposures of 0.0795 µW/cm2 significantly inhibited memories and association between food sites and visual and olfactory cues. The overall state in exposed colonies appeared similar to bee colony collapse disorder (CCD) (Cammaerts et al. 2012). [Effects of on pollinators, such as bees, have also been reported (Rahmani et al. 2011)].

Birds: “… migratory birds are unable to use their magnetic compass in the presence of urban electromagnetic noise,” Engels et al. (2014). The RF levels assessed [0.001 µT, approximately equal to 0.3 V/m or 0.0236 μW/cm2] are similar to the levels found in the 2 kHz to 5 MHz frequency range in urban environments as a result of electromagnetic pollution.

 

Mice: Mice and rats can act as pollinators and form an important part in Nature’s food chain (Pattemore & Wilcove 2012). Exposure to 80-900 MHz radiation at 1.053 µW/cm2 could cause irreversible infertility in mice after 3 generations, and levels of 0.168 µW/cm2 caused total infertility after 5 generations (Magras & Zenos 1997). As mentioned earlier, research has additionally shown that EMFs can reduce human fertility (Avendaño et al. 2012, Falzone et al. 2011, Santini et al. 2002).

 

Revised planning and building guidelines that feature low EMF initiatives, and promote the use of the most biologically friendly types of technology and exposures, are urgently required to help protect the environment and help create the most viable long-term sustainability initiatives.

 

EMF EXPOSURE GUIDELINES AND BEST PRACTICE

The UK presently adheres to the ICNIRP (1998) exposure guidelines, which are amongst the most lax in the World, i.e. maximum permitted RF EMF exposures to the general public of 1000 μW/cm2 at 2.1 GHz, compared to: 10 μW/cm2 in Italy for sensitive areas [dwellings; playgrounds; school premises; areas where people spend ≥4 hours daily]; 10 μW/cm2 in China as 1st class exposure limits [>0.3-300 GHz]; and a maximum power density level per carrier of 0.1 μW/cm2 in Castilla-La Mancha, Spain for sensitive areas (President of the Council of Ministers 2013, Chiang 2009, Presidencia de la Junta 2001, ICNIRP 1998).

 

In China, out of 109 epidemiological studies, 108 noted biological effects as a result of EMF exposure. “No matter what the exposure level may be, lower or higher than [the Chinese] EMF exposure limits for public, health effects had been reported in these papers. …” Cao (2007).

 

Over 44% of the World’s population live in countries or regions that have substantially more rigorous EMF exposure limits and non-binding EMF exposure recommendations than ICNIRP’s guidelines (Jamieson 2014). It would be prudent and wise to introduce proactive best practice measures to reduce electromagnetic pollution in the built environment wherever practical. Such initiatives are already being undertaken elsewhere. As an example, Italy aims “… to progressively minimise exposure to electromagnetic fields,” President of the Council of Ministers (2013). The latest country to promote low field environments is France, which in 2015 passed a proposed law prohibiting the use of Wi-Fi in nursery and daycare settings and restricting its use in primary schools (Assemblée Nationale 2015). In Russia there is already planning guidance in place showing how the layout of rooms and items within them can be improved to reduce occupants EMF exposures (Jamieson 2014). Ideally, EMF field templates should be developed for distinct items of electrical equipment to allow appropriate separation distances to be planned & their locations optimised.

 

The Council of Europe’s Resolution 1815 (PACE 2011) suggests that all reasonable measures should be taken to reduce exposure to electromagnetic pollution. In the design of the built environment, such measures include the creation and development of low EMF environments and technologies and improved low EMF layouts for rooms. 

 

PROMOTION OF INCLUSIVE DESIGN MEASURES

INCLUSIVE DESIGN – ACCESSIBILITY REQUIREMENTS

“For people who are electromagnetically sensitive, the presence of cell phones and towers, portable telephones, computers, fluorescent lighting, unshielded transformers and wiring, battery re-chargers, wireless devices, security and scanning equipment, microwave ovens, electric ranges and numerous other electrical appliances can make a building inaccessible. ... the Committee recommends that measures be taken to reduce EMF whenever possible in order to increase access for these individuals as well as taking a precautionary approach to protecting the health of all,” US National Institute of Building Sciences, (NIBS 2005).

 

The Parliamentary Report prepared by Lobb et al. (2015) for the Parliament of Canada states: “That the Government of Canada continue to provide reasonable accommodations for environmental sensitivities, including electromagnetic hypersensitivity, as required under the Canadian Human Rights Act.” It is proposed that the need to comply with such basic Human Rights should be stipulated in the National Policy for the Built Environment. [For further discussion refer to the supplementary information provided].

 

Between 3-6 % of the general public may presently be affected by EHS, a number well in excess of the 1-2% of the population using wheelchairs (Jamieson 2014, Wheelchair 2015). It is predicted that such numbers will substantially grow in the future (Hallberg & Oberfeld 2006). Measures to address EHS could easily be added to inclusive design protocols. Many measures to create low EMF environments are no cost / low cost.

 

“Electromagnetic hypersensitivity sufferers experience a serious deterioration in their quality of life, not only because of the physical symptoms it usually entails, but also because their lives are totally disrupted by the need to avoid exposure. In practice, it means that they not only have to avoid almost all public facilities such as transport, hospitals and libraries, but even their own homes, in order to escape adverse health effects, which is a breach of rights that are enshrined in the EU Charter of Fundamental Rights,” (EESC 2014). Such matters have to be addressed through the creation of low EMF environments and biologically safe technologies.

 

We proposed that planning policy guidelines should stipulate the requirement for creating low EMF environments and ‘White Zones’. The creation of ‘White Zones’, particularly when run in conjunction with biophilic initiatives, would create the further benefit through encouraging biodiversity.

 

2. ADDRESSING TIER 1 THREATS IN NATIONAL PLANNING POLICY

Severe Weather Events, Manmade EMP Events and Cyber-Attack Events

The creation of low EMF environments and ‘White Zones’ could additionally form a starting point in helping protect buildings (and the built environment in general) against potential events that the UK Government already recognise as Tier 1 threats.

 

A. TERRESTRIAL SEVERE WEATHER EVENTS

It appears highly probable that terrestrial severe weather events will at some point compromise unprotected modern electronic technologies. As an example, smart meters have far lower resilience to severe weather events than the meters they were intended to replace (Jamieson 2012). Their widespread use could cause severe disruption and loss of life [due to sudden loss of power for heating or cooling during such events] due to their being designed to automatically disconnect when they fail. As mentioned earlier, contrary to popular belief, smart meters are not compulsory (StopSmartMeters!UK 2014, Hansard 2011).

 

B. NATURAL AND MANMADE ELECTROMAGNETIC PULSE [EMP] EVENTS

Space weather electromagnetic pulse [EMP] events present a very real threat to the built environment as they can knock out power supplies and electronic devices. It has been suggested by the Royal Academy of Engineering (2013) that any component with a design lifetime of greater than 8.25 years needs to consider the threat of severe space weather. Manmade EMP events can also be created that would bring the country, or selected areas of the country, to a standstill and potentially result in high financial loss and high loss of life. Both are recognised as Tier 1 threats (House of Commons Defence Committee 2012). Proper protective measures against such threats need to included in national and local planning policies.

 

Proposed EMP protection plan

Tier 1: EMP protection for new build homes, offices, major shops and hospitals, with EMP-protected solar panels for on-site power generation. EMP protection of critical infrastructures.

Tier 2: Refurbishment of existing building stock to provide EMP protection. At least one room per building to be shielded. Also external EMP-protected solar panels, or other protected means of sustainable on-site energy production encouraged.

Tier 3: Lower income dwellings to have one room EMP shielded and external EMP-protected solar panels to provide on-site power.

 

EMP-protected solar energy generation to become the design norm. Refer also to: White (2015).

 

[Note: As it is indicated that long-term occupation of Faraday cage like enclosures can be harmful to immune system function (Jamieson et al. 2010), special design measures are required for EMP protected buildings].

 

C. CYBER THREATS

Cyber threats, which could cause whole areas to be without power and basic services for prolonged periods of time, urgently need to be addressed within the National Policy for the Built Environment. They present a Tier 1 threat (Gov.UK 2015).

 

“The current attack surface for [smart] cities is huge and wide open to attack. This is a real and immediate danger. The more technology a city uses, the more vulnerable to cyber attacks it is, so the smartest cities have the highest risks” (Cerrudo 2015). Most cities are poorly protected against cyber attacks, and are at risk of high financial loss through lack of adequate contingency planning.

 

“In the near future, smart power or water meters could become targets, to black out an area of a city and demand a ransom …” (Flanagan 2015).

 

The intelligent provision of energy efficient low-tech systems and independent off-line smart systems in the design of the built environment can provide highly cost effective alternatives and help address many cyber threats.

IMPROVING THE RESILIENCE OF THE BUILT ENVIRONMENT

We propose that 20% of all developments should be created as EMP-shielded, low EMF environments with hard-wired connectivity and manual overrides to help address EMP events and cyber threats. Such provision will also enable low EMF zones for those who are EHS to be easily established.

 

We also suggest that in order to properly increase community resilience to natural and manmade threats, the creation of urban farms (including vertical farms and rooftop farms) and power provisions should be encouraged to allow the provision of locally sourced food, water and energy (at least at emergency ration level) in times of emergency.

 

Additionally, the extended promotion of biophilic design initiatives could help substantially reduce storm water runoff, heat island effects and levels of airborne pollutants. [The greening of street canyons with building integrated vegetation (BIV) can reduce street-level NO2 levels by as much as 40% and airborne particulate matter (PM) levels by ≥60% (Pugh et al. 2012)].

 

Resilient design policies and best practice measures should encourage the standard adoption of measures to enable basic energy, food and water provision to be maintained in areas should power and electronics fail for prolonged periods of time, and the creation of more sustainable environments and technologies to aid health, wellbeing and productivity.

 

3. ETHICAL, ENVIRONMENTAL AND SUSTAINABILITY ISSUES

Properly addressing ethical, environmental and sustainability issues delivers considerably better long-term financial returns on equity and returns of assets than failing to address such issues. High sustainability companies significantly outperform their low sustainability rivals. The same should hold true for countries (Juniper 2013, Eccles et al. 2011).

 

The ethical creation of safer, more biosustainable built environments and technologies that respect the rights of the individual can create substantial long-term benefits for all. A ‘Win/Win’ situation.

 

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For detailed background information on the matters discussed please refer to the document specifically prepared to accompany this submission.

 

 

02 December 2015