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ESC is an alliance of European organisations that strives to reduce the
impact of modern communications and electricity use on health and the environment. We are not against technology, but we are pro safe technology and safe connections.


    Have your say – Environmental law

    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:

    EU environmental law – 2025 implementation review

    About this initiative: The environmental implementation review is a regular cycle of analysis to improve the implementation of EU environmental policy and law in EU countries.

    Feedback period: for stage 2 it is 07 June 2024 – 05 July 2024


    Feedback from Europeans for Safe Connections

    We, “Europeans for Safe Connections“, would like to draw your attention to electromagnetic fields (EMFs) and therefore we have these comments to the areas addressed in the EIR:


    Every smartphone includes 1000+ substances each with its own energy-intensive, toxic waste-emitting supply chain that is a threat to the environment. In addition to the current 5G technology rollout with huge amounts of antennas, the introduction of billions of 5G-connected wireless devices (like household appliances, watches, clothes, nappies, blinds) into our daily lives will expand consumerism, technological obsolescence and electronic waste that is difficult to recycle.

    Environmental impact of digital device production: The environmental costs of “upgrading” to a new device or a new program which often requires a new computer and new peripherals, each with embodied energy and toxins, are extremely high. The exponential development of wireless communications leads to an accelerated cycle of buying new devices and disposing of old ones. The production of these devices, including satellites, antennas, mobile phones and tablets, requires the extraction of large amounts of natural resources, including rare earth minerals and metals.

    Pollution and environmental degradation related to material extraction: The extraction and use of raw materials for digital devices contribute to water pollution, water depletion, habitat destruction, deforestation and drought. These processes also have negative impacts on flora, fauna and human health. For example, the mining of lithium, a key component of electric vehicle batteries, has been linked to air pollution, fluorosis and heavy metal pollution of soil in Tibet.

    The OECD predicts that global use of primary materials will double by 2060, further exacerbating water pollution, water resource depletion, habitat destruction, deforestation and drought.

    We propose to include “Waste from Electrical and Electronical Equipment” (WEEE), other waste products, and the environmental impacts of mining for rare earth minerals and metals used in electronical equipment in the “Zero pollution action plan”. Read more here:

    We propose to reduce the massive electricity consumption caused by digital communication technology, e.g. by prioritizing wired solutions and low energy solutions in the action plan for the European Green Deal. Read more here:


    We would like to draw your attention also to the rapid and widespread introduction of artificial EMFs around the world, the intensity of which is much higher than natural background levels. The increase in electromagnetic pollution, particularly from the use of wireless communication technologies, poses a potential threat to biodiversity. There is an ongoing debate in science about the health effects of EMFs from analog and digital technologies on wildlife and humans. Laboratory studies have already demonstrated negative effects of EMFs on various species:

    1. Oxidative Stress Amplification: RF EMFs amplify air pollution’s health effects by triggering increased oxidative stress within the organisms. Oxidative stress can harm cells and tissues. There is sufficient evidence in experimental animals for the carcinogenicity of RF EMF.
    2. Reproductive cells and organs: According to STOA metastudy “Health impact of 5G“, RF EMF clearly affect male fertility (including human) and are likely to affect female fertility and the development of embryos, foetuses and newborns.
    3. Behavioral alterations (e.g. birds and insects) such as avoiding base stations
    4. Blood-Brain Barrier Permeability: RF EMF exposure increase the permeability of the blood-brain barrier, allowing pollutants to more easily infiltrate the brain. This could raise the risk of neurological harm.

    We propose to include monitoring of all biological harmful parameters of RF EMF in Environmental monitoring programmesBiodiversity Strategy 2030EU Nature restoration targetsHabitats and Birds Directives and Natura 2000. Read more here:

    • ZERO POLLUTION (namely air quality, industrial emissions, major industrial accidents prevention, noise, water quality and management)

    RF EMF is generally considered by scientists and biologists to be an environmental pollutant. We regret that the EU is ignoring these scientific developments and only taking into account the views of formal committees that are shown to be linked to only one school of science. The views of many scientists who see adverse health effects and effects on nature in their research are not taken into account. Peer-reviewed research, and even heavily peer-reviewed research that demonstrates serious long-term effects on human and animal health, is left out. The advice of the European Environment Agency in the report ‘Late lessons from early warnings’ is ignored. Never in history have scientists and physicians raised false alarms about environmental or health risks; on the contrary, in many cases governments have reacted very hesitantly, and enforcement of protective measures against some recognized pollutants has taken decades (tobacco, air pollution), if not a century (asbestos). The Polluter pays principle should also be applied to this type of pollutant.

    It should be also emphasised that no impact assessment report has yet been produced on the effects of RF EMF on animal and plant species, biodiversity and ecosystems, at a time when the deployment of wireless technologies is being promoted widely in landscapes and populated areas. As a result, industry is not required to produce digital devices and infrastructure without the side effects of RF EMF on health of humans and nature. It has become standard practice in the medical, automotive and food industries to test their products and services for public health risks before they are placed on the market.

    For example, we refer to what we believe to be a neglected analysis of the environmental, energy, and health impacts of 5G wireless technology in the Impact Assessment of the Gigabit Infrastructure Act, Part 1 (p. 51, footnote 150).

    We propose to recognize all biologically harmful parameters of RF EMF as a pollutant. Include them in all relevant EU Environmental Policies and Directives. Read more here:


    Wireless technologies have negative impacts on climate change:

    1. Energy Consumption: The proliferation of smart devices (such as smartphones, tablets, and IoT devices) contributes to increased energy consumption. Wireless access networks are the largest and most inefficient consumers of energy in the cloud environment. Wireless devices, antenna networks and data centres consume an increasing portion of the global energy supply, which is largely based on coal.
    2. Server Farms: The data generated by these devices is stored in server farms, which require significant power. By 2040, these devices could produce 3.5% of global emissions, with the industry using up to 20% of the world’s electricity.
    3. Growing Power Demands: As we digitalize more aspects of our lives, server farms demand more electricity. Predictions indicate a substantial increase in power needs by 2025.

    Let’s also delve into the relationship between self-driving cars and energy consumption. Self-driving cars, also known as autonomous vehicles, have the potential to impact energy consumption. Here are some key points:

    1. Computational Power: Self-driving systems rely heavily on computational power for perception, decision-making, and control.
    2. Hardware Efficiency: Achieving energy efficiency within today’s data center emissions levels would require autonomous vehicle computers to use less than 1.2 kilowatts of computing power, a challenging goal with current hardware efficiencies.
    3. Moore’s Law: The industry’s accepted rate of computational power doubling every two years may not suffice. Autonomous vehicles might need even faster improvements to maintain emissions levels.
    4. Unforeseen Factors: Demographics, travel patterns, and neural networks introduce complexity.

    We propose to update Directive 2011/92/EU to include 5G deployment and all telecommunication as projects in Annex 1 to ensure that such projects are made subject to environmental assessment or a screening as prescribed by the directive. Read more here:

    The pursuit of economic growth and profit by industrial companies or other entities should not prevail over the primary need to protect the environment, sustainable management of natural resources and the right to health. Without a dedicated policy to limit these environmental impacts, the Green Deal will not be made a reality. The facts that clearly demonstrate these side effects are widely available and should not be overlooked or ignored.

    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:

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