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Written evidence submitted by 5G Action West Sussex


Call for Evidence—Broadband and the Road to 5G



This submission is made on behalf of 5G Action West Sussex, and addresses the following Terms of Reference in the Call for Evidence:

Our submission focusses exclusively on public health and environmental issues.

The 5G Action West Sussex Group

The 5G Action West Sussex group was formed in 2019 to raise awareness of the issues surrounding the rollout of 5G, and for West Sussex residents to exchange information on what is happening locally.

A large body of scientific research clearly indicates a range of adverse effects of microwave radiation upon living systems, but this evidence has been denigrated or ignored by the regulatory bodies. No risk assessments, environmental impact assessments or monitoring is being done or planned. The Group regards this as the height of irresponsibility: we have here the makings of a 21st Century public health and environmental catastrophe compared to which tobacco, DDT, asbestos, lead, Thalidomide CFCs and opioids could pale into insignificance.

Regulatory Aspects

The Department for Digital, Culture, Media and Sport (DCMS) and Public Health England’s (PHE’s) Centre for Radiation, Chemical and Environmental Hazards (CRCE) assure us that safety standards are rigorous and trustworthy and that 5G technology is completely safe with regard to potential impacts on human health and the environment. These safety standards rely on the guidelines published by the International Commission on Non-Ionizing Radiation Protection (ICNIRP).


ICNIRP safety standards, as referenced by Government regulators, are not fit for purpose, being based on an out of date, inadequate and discredited methodology, and wilful ignorance of the many complex interactions between non-ionising electromagnetic radiation and living organisms [1]. ICNIRP & PHE attempt to discredit this body of science by misinterpreting “no consistent evidence of harm” to mean “evidence that there is no harm”. Significantly, meta-studies have shown that industry funded research is several times less likely to report adverse effects than truly independent research. There are instances of mobile ‘phone manufacturers pressurising researchers when a study they funded started to find adverse effects. The lack of consistency does not prove lack of effects; rather, it is a consequence of the extreme complexity of RFR-biological system interactions and a lack of consistency in research methodology.

The ICNIRP safety levels only take account of heating effects, and the tests involve exposing models of different tissue types for short periods of time (e.g., six minutes) and measuring temperature rises to ensure that they do not exceed 2 - 5°C depending on the tissue type. This technique fails to account for the fact that developing children are much more susceptible to heating effects than mature adults, on account of their thinner skulls – the radiation penetrates further into their brain. The test also fails to account for the longer periods of exposure typical of mobile ‘phone usage, nor the continuous exposure to increasing levels of electromagnetic pollution in the general environment.

More importantly, there is a large body of scientific evidence that a variety of non-thermal adverse biological effects occur at field strengths many orders of magnitude lower ICNIRP’s so-called ‘safety’ levels [2]. It is also noted that biological effects are exacerbated by pulse modulation, polarisation mode and beam coherence.

ICNIRP does not itself certify equipment or installations [3] – device and network providers are expected to self-certify conformance and the Group wishes to know whether regulators will actively test installations on a regular basis, or merely accept self-certified conformance without verification.

ICNIRP, upon whom PHE relies, also has a legal disclaimer regarding their Guidelines; their website states:

“ICNIRP e.V. undertakes all reasonable measures to ensure the reliability of information presented on the website, but does not guarantee the correctness, reliability, or completeness of the information and views published. The content of our website is provided to you for information only. We do not assume any responsibility for any damage, including direct or indirect loss suffered by users or third parties in connection with the use of our website and/or the information it contains, including for the use or the interpretation of any technical data, recommendations, or specifications available on our website”.

In short, the regulatory bodies have been captured by the multi-trillion-dollar telecommunications industry and now serve the interests of the industry, not those of public health [4].

Public Health England

In the light of all this, we are deeply concerned that central Government has ruled that local planning authorities may not take health or environmental concerns into account when considering 5G-related planning applications. This is extraordinary, since it conflicts directly with a Planning Authority’s legal obligation to protect the health and wellbeing of the population in their area, especially children. Even PHE’s own solicitors [5] advise that:

“A public body must determine how much weight to put on the PHE guidance. Equally that body must determine what other evidence from your client or other members of the public or interested parties to consider in making any decision. If it be alleged that a public body now or in the future acted unlawfully in placing reliance on the guidance, that cannot retrospectively taint the guidance with illegality”.

The above statement from the solicitors to PHE unequivocally states that public bodies should balance PHE’s guidance with other sources of evidence, i.e., they should indeed question that guidance.

In other words, neither PHE or ICNIRP stand behind their own guidelines and whilst councils are instructed not to set their own safety standards, nevertheless they have the legal right not to accept these guidelines.

The directive that planning authorities may not take health or environmental concerns into account conflicts with their legal obligation to protect the health and safety of the  population within their administrative locality and it conflicts with the legal principle that Government signatories to a contract bear ultimate responsibility and liability for public health and other outcomes. It also conflicts with Article 3 of the Universal Declaration of Human Rights – the Right to Life and Integrity of Person [6]. Elected representatives also bear a personal responsibility for protecting the health and safety of those whom they represent, which cannot lawfully be negated by adopting a position of wilful ignorance or abdication of responsibility through deference to PHE and ICNIRP.

Liability and Insurance

In the event that 5G technology is subsequently shown to have caused significant harm in the population or the environment, who will bear the legal responsibility? Someone must be held accountable for ignoring evidence and failing to heed the warnings. Note that major insurers such as Lloyds of London and Swiss Re refuse to insure against 5G health liabilities, because the risks are all too clear to them [7].

Adverse Health Effects

There are thousands of peer-reviewed scientific studies published over many decades in respected journals, that identify a variety of adverse biological effects of microwave radiation in the 700MHz–300GHz frequency range [8].

Among the serious effects noted are: brain tumours, gliomas and other cancers [9], headaches [10], insomnia [11], cognitive impairment [12], neurological and neuro-developmental disorders [13], ovum abnormalities [14], impaired sperm quality, motility and morphology [15], heritable single- and double-strand DNA damage [16], oxidative tissue damage [17], blood cell damage [18], cardiac stress [19], skin diseases [20], eye lens opacity [21].

A global coalition of hundreds of eminent scientists has called for a moratorium on 5G rollout, pending proper safety research [22].

Several states, cities and towns in the UK, Europe and elsewhere have already implemented such a moratorium [23].

The Council of Europe’s Resolution 1815 of April 2011 expressed a unanimous vote to ban Wi-Fi and mobile ‘phones from schools and to prioritise reduction of human exposure to all sources of EM radiation [24].

Adverse Environmental Effects

Damage to plants and animals especially insects and pollinators [25], amongst many other effects. In recent decades, mobile communication technology has increased levels of electromagnetic radiation in the environment to billions of times natural background levels, and insect population levels have plummeted. A wide variety of adverse effects on plants and animal are noted in various studies [26].

Environmental Impact Assessment

There does not appear to be any requirement for local authorities to require environmental impact assessments.

Before and After Studies

There are a number of 5G pilot trials in the UK but we have found no evidence that any of them have taken any steps to detect adverse health or environmental consequences of the trials. One would expect at a minimum to see studies of ‘before and after’ public health and biotic indices. Similarly, one would expect that longer-term studies of this kind would be conducted on a national basis during the 5G rollout and ongoing thereafter.


Here are some sample references on biological effects of electromagnetic radiation; there are many others.

[1] AGNIR/ICNIRP standards discredited:

[2] ICNIRP safety levels orders of magnitude too high:

[3] ICNIRP does not certify devices or installations:

[4] Regulatory capture by industry:

[5] In a letter from DLA Piper, UK solicitors for PHE, to Leigh Day solicitors, dated 8th August 2019.

[6] Universal Declaration of Human Rights:

[7] Lloyds Insurers Refuse to Cover 5G Wi-Fi Illnesses:

Swiss Re. Concerns Over 5G Health & Other Risks:

[8] EMF Portal:

[9] Brain tumours & other cancers:

[10] Headaches:

[11] Insomnia:

[12] Cognitive impairment:

[13] Neuropsychiatric effects:

[14] Ovum abnormalities:

[15] Sperm quality, motility, morphology:

[16] DNA damage:

[17] Oxidative stress:

[18] Blood cell damage:

[19] Cardiac stress:

[20] Effects on skin:

[21] Effects on eyes:

[22] 248 EMF scientists & medical doctors from 42 nations:

[23] Brussels stops go ahead of 5g – Brussels Times article:

Bay Area city blocks 5G deployments over cancer concerns:

[24] Council of Europe Resolution 1815:

[25] Effects on wildlife, insects and pollinators:

[26] Science: Plant and Animal Electromagnetic Sensitivity:


Additional references are cited in the following document: