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    Have your say – Air Pollutants

    You can also get involved in forming EU laws. The European Commission offers a platform “Have your say” with the list of all new EU initiatives open for public consultation. You need to register to write your feedback: ec.europa.eu/info/law/better-regulation/have-your-say

    National Emission Reduction Commitments Directive – evaluation

    About this initiative: This evaluation will assess if the legislation has been successful in reducing five air pollutants.

    Feedback period: for stage 2 it is 15 February 2024 – 14 March 2024

    Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13968-National-Emission-Reduction-Commitments-Directive-evaluation_en

    Feedback from Europeans for Safe Connections

    We, “Europeans for Safe Connections”, understand that this initiative evaluates five air pollutants responsible for significant negative impacts on human health and the environment. The Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants is evaluated.

    We would like to provide our comment according to standard evaluation criteria (relevance) and we are offering our perspective for future consideration:

    In light of developments and technical and scientific progress we would like to point out that the Directive’s scope in terms of the coverage of pollutants, their sources and their impact on ecosystems should be updated.

    We propose future broadening the scope to encompass a pollutant of significant concern – radiofrequency electromagnetic fields (RF EMF) spreading wirelessly through the air.

    EXPLANATION:

    Regulation (EC) No 166/2006 concerning the establishment of a European Pollutant Release provides a list of 91 pollutants and defines a pollutant as: “a substance or a group of substances that may be harmful to the environment or to human health on account of its properties and of its introduction into the environment”.

    RF EMF, however, is not included in this list even though scientists consider it a pollutant [1] [2].

    It is unacceptable that the EU does not classify RF EMF as a pollutant, while insurance companies, which do not want to insure against certain damages relating to pollutants, clearly define RF EMF as pollutants:

    Pollutants mean: Any solid, liquid, gaseous, or thermal irritant or contaminant including smoke, vapor, soot, fumes, acid, alkalis, chemicals, artificially produced electric fields, magnetic field, electromagnetic field, sound waves, microwaves, and all artificially produced ionizing or non- ionizing radiation and waste. Waste includes materials to be recycled, reconditioned or reclaimed.” (AT&T Mobile Insurance)

    The document Late lessons from early warnings describes very well the slowness of the authorities in dealing with environmental issues. Some pollutants, despite knowledge of the risks, have been left unresolved for many decades.

    EU increases EMF exposure for both humans and the environment. New types of signals are being deployed at frequencies and with characteristics that have not yet been tested by research for long-term health safety.

    It is time to recognize ambient EMF as a novel form of pollution and develop rules at regulatory agencies that designate air as ‘habitat’ so EMF can be regulated like other pollutants.” (Levitt et al 2022: Effects of non-ionizing electromagnetic fields on flora and fauna, Part 2 impacts: how species interact with natural and man-made EMF; https://pubmed.ncbi.nlm.nih.gov/34243228/)

    Existing environmental laws, such as the National Environmental Policy Act and the Migratory Bird Treaty Act in the U.S. and others used in Canada and throughout Europe, should be strengthened and enforced. New laws should be written to accommodate the ever-increasing EMF exposures.

    Cyto- and geno-toxic effects have long been observed. It is time to recognize ambient EMF as a novel form of pollution and develop rules at regulatory agencies that designate air as ‘habitat’ so EMF can be regulated like other pollutants.“.

    Long-term chronic low-level EMF exposure standards should be set accordingly for wildlife, including, but not limited to, the redesign of wireless devices, as well as infrastructure, in order to reduce the rising ambient levels.” (Levitt et al 2022: Effects of non-ionizing electromagnetic fields on flora and fauna, Part 3. Exposure standards, public policy, laws, and future directions; https://pubmed.ncbi.nlm.nih.gov/34563106/)

    Finally, a legal argument:
    Given art. 1, 2, 3, 6, 7, 24, 35, 37, in the CFR it is imperative to accept RF EMF as an pollutant that must be monitored and restricted for proper protection of all life on Earth.

    Best regards
    Europeans for Safe Connections
    This feedback was sent from a wired internet connection
    – No use of harmful radiation
    – Less electricity consumption
    – Increased data security

    Link to our feedback: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13968-National-Emission-Reduction-Commitments-Directive-evaluation/F3458680_en

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