I respond to the UK's consultation on getting rid of planning barriers to telecoms masts, small cells and other digital infrastructure.
The questions in this consultation ignore the possibility that increasing wireless communciation without due diligence might be undesirable to local communities. I challenge this.
Reforming planning rules to accelerate deployment of digital infrastructure
I respond to this consultation as an individual and particularly wish to address the question of “adequacy of safeguards,” and the various “needs of communities”, particularly certain sectors.
In its aim to “enable quicker, lower-cost deployment of fixed and mobile digital infrastructure” and to address “specific, evidenced barriers, that may exist in the planning system, to infrastructure deployment”, the Government is bypassing any responsibility for public health.
I suggest the Government goes back to the drawing board and fully involves the Department for Health, whose expert committee COMARE now includes an EMF and Health Working Group. Further deployment of wireless infrastructure needs to be paused, not accelerated, until the public health aspects have been fully and independently evaluated.
ADEQUACY OF SAFEGUARDS
Presently, local planning authorities are assumed to have taken care of any potential health issues by ensuring that applicants provide a Declaration of Conformity with exposure guidelines set by the International Commission for Non-Ionising Radiation Protection (ICNIRP).
There are numerous issues with ICNIRP exposure limits which are very much higher than those set by many countries throughout the world as shown in this graph:
The Department of Health has just written to my MP Rishi Sunak, following an enquiry on my behalf and made clear that there is no scientific consensus on the health effects of electromagnetic fields including radio-frequency radiation (RFR), saying,
“UKHSA acknowledges the difficulty in development of exposure protection guidance – the interpretation of studies of potential health effects is a matter of judgement, and there is a spectrum of opinion within the scientific community and elsewhere. UKHSA is aware that different groups have concerns about EMFs; where alternative limits have been proposed, these do not appear to have a scientific rationale based on health effects in the same way as the ICNIRP guidelines.”
Scientific invalidity of the ICNIRP exposure guidelines
The 14 flawed assumptions behind the ICNIRP guidelines have been described by the International Commission for the Biological Effects of Electromagnetic Fields (ICBE-EMF) in this scientific paper: https://link.springer.com/article/10.1186/s12940-022-00900-9
Here is the abstract:
In the late-1990s, the FCC and ICNIRP adopted radiofrequency radiation (RFR) exposure limits to protect the public and workers from adverse effects of RFR. These limits were based on results from behavioural studies conducted in the 1980s involving 40–60-minute exposures in 5 monkeys and 8 rats and then applying arbitrary safety factors to an apparent threshold specific absorption rate (SAR) of 4 W/kg. The limits were also based on two major assumptions: any biological effects were due to excessive tissue heating and no effects would occur below the putative threshold SAR, as well as twelve assumptions that were not specified by either the FCC or ICNIRP.
In this paper, we show how the past 25 years of extensive research on RFR demonstrates that the assumptions underlying the FCC’s and ICNIRP’s exposure limits are invalid and continue to present a public health harm. Adverse effects observed at exposures below the assumed threshold SAR include non-thermal induction of reactive oxygen species, DNA damage, cardiomyopathy, carcinogenicity, sperm damage, and neurological effects, including electromagnetic hypersensitivity. Also, multiple human studies have found statistically significant associations between RFR exposure and increased brain and thyroid cancer risk. Yet, in 2020, and in light of the body of evidence reviewed in this article, the FCC and ICNIRP reaffirmed the same limits that were established in the 1990s.
Consequently, these exposure limits, which are based on false suppositions, do not adequately protect workers, children, hypersensitive individuals, and the general population from short-term or long-term RFR exposures. Thus, urgently needed are health protective exposure limits for humans and the environment. These limits must be based on scientific evidence rather than on erroneous assumptions, especially given the increasing worldwide exposures of people and the environment to RFR, including novel forms of radiation from 5G telecommunications for which there are no adequate health effects studies.
Groups excluded from the ICNIRP guidelines
Those with medicinal or metallic implants are not covered by these guidelines. This was confirmed in the Thomas v. Cheltenham Borough Council case, when Judge Jarman ruled, that the existence of a Declaration of Conformity was not sufficient with regard to those with metal implants, and that,
“The failure on the part of the authority to grapple with potential impacts on medical implants was, in my judgment, an error and this ground succeeds”
Cheltenham Council appealed against this ruling but failed. Councils do not have the expertise to make judgements in these matters and this needs to be addressed by central Government and the Department of Health.
ICNIRP and the WHO
Recently the long-awaited 12 systematic reviews commissioned by the WHO to investigate the health effects of RFR were published.
However, the ICBE-EMF has found serious methodological and scientific flaws in 11 of the 12 reviews and says they provide no assurance of safety. Their detailed critique is here: https://link.springer.com/article/10.1186/s12940-025-01220-4 They point out that ICNIRP board members were included in each of the 12 review teams. ICNIRP members maintain that harm will only occur if tissue is heated above a certain threshold and they deny long-term effects such as cancer.
The WHO interferes in the scientific process
Since then, the lead-author (Professor Meike Mevissen) of the only review considered by ICBE-EMF to be correctly executed, has revealed that the WHO had interfered in the scientific process and obstructed her work. She stood her ground, however. Her review found high certainty evidence that RFR causes some cancers in animals. Her German interview is described here: https://dailysceptic.org/2026/02/05/the-wi-fi-and-mobile-phone-cancer-debate-heats-up/ It seems likely that the WHO tried to influence the outcome of all the reviews in a similar way, but with more success.
NEEDS OF COMMUNITIES
Those with electromagnetic hypersensitivity (EHS)
This fast-growing group clearly needs a world with less wireless radiation, not more. In 2019, European Commission’s EESC 2019 Report on Digitalization: Challenge for Europe estimated that 3 to 5% of the population (up to 3.45 million in the UK) suffers from EHS, some of those being so severely disabled, that they live in poverty and isolation due to their needing a very low-EMF environment. They cannot work or travel, may have to live rough and may have severe ill-health. Doctors rarely understand this condition and awareness amongst employers is low. However, there have been individual UK legal actions resulting in a local authority being mandated to provide low-EMF accommodation for a child, as well as an award of early ill-health retirement and compensation for a worker, due to disabling EHS. Sufferers, however, need to be accommodated, without having to take legal action.
In the UK there is no policy seeking to accommodate those disabled by EHS, whereas in the US, for example, the National Council on Disability has recognised EHS as an EMF-induced disability and has created a policy framework to help achieve health equity for all with disabilities, including EHS. Accommodations for the EHS-disabled have already been made throughout the world.
People not wishing to be exposed to wireless radiation
Others, aware of the current scientific uncertainty as regards safety as well as of potential long-term health effects and therefore wishing to reduce their exposure, need to be able to do so. At present they cannot avoid involuntary exposure and decreasing their exposure means withdrawing from normal life. If politicians wish to increase wireless connectivity in trains, these people will be prevented from travelling, to give an example.
The Elderly and Vulnerable
An essential lifeline for the elderly and vulnerable is the fixed copper landline, as this is not dependent on an electricity supply and is reliable during electric outages and storms. If there is a large outage, the mobile infrastructure will fail too as shown in Spain.
Frail or confused elderly people cannot be expected to keep a mobile charged or to depend on mobile signals working well in times of emergency. A digital fixed connection also depends on electricity and the smooth working of internet and is no solution.
Elderly people need simplicity of use, reliability and clear uninterrupted sound, which is only available via a copper landline.
I maintain that the copper networks should remain fully operational for all who need them or want them.
CONCLUSION
It seems that there are serious doubts as to the reliability of either ICNIRP or the WHO EMF Project and that their guidance may well be misleading. Both groups are known to have links with the telecoms industry and for the sake of our health, it would seem prudent to stop the rush to irradiate the country, both for the sake of people, wildlife and the environment and to make a concerted effort to engage independent scientists to investigate the matter.



Thank you for taking the time to present this excellent submission, very much appreciated!
You summarised the situation so clearly for us. Cheers.