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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.

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Have your say – Small cells

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

Light deployment regime for small cells – amendment

About this initiative: 

Commission Implementing Regulation 2020/1070 specifies the physical and technical characteristics of small cells (small-area wireless access points) that are exempted from any individual town planning permit or other individual prior permits. This initiative will amend the Regulation to facilitate the deployment of small cells.

Feedback period: for stage 4 it is 13 May 2024 – 10 June 2024

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14029-Light-deployment-regime-for-small-cells-amendment_en

Feedback from Europeans for Safe Connections

We, “Europeans for Safe Connections“, have these comments to this amendment:

  • we welcome that in Article 1, the second paragraph is deleted. This means that the regulation will also apply to small-area wireless access points with an active antenna system from now on.
  • we do not care about prolonging deadlines for operators, we think that EU should think more about the health of people
  • Article 4 is only about monitoring
  • We see that in the Annex there are only grammar changes plus one sentence at the end added: “In the case of co-located deployment of antenna systems, or portions thereof, evidence of the compliance of the aggregate EIRP can be submitted jointly by the deploying entities, unless otherwise provided by national law.” We agree to this.

We have to say that we are deeply concerned with the whole REGULATION (EU) 2020/1070.

We draw your attention to the Article 1, para 3, point (a): “…any portion thereof in excess of 30 litres shall be invisible to the general public.
and
to the original REGULATION (EU) 2020/1070 , article 3, point 1a, which stays unchanged:”be fully and safely integrated in their supporting structure and therefore invisible to the general public
and
to the original REGULATION (EU) 2020/1070 , point (8) “…requires that the lowest radiating part of the antenna of a Class E10 has a height of at least 2,2 metres above the general public walkway to ensure a distance of at least 20 cm between the main antenna lobe and the human body of a 2 m tall person”
This is unacceptable for us.

By hiding small area wireless access points from public view, the European Commission may aim to reduce public health concerns arising from an explosion in the number of new transmitters. But this is unacceptable!

This action can be interpreted as an action against transparency and against the right to informed consent of the citizen or against the right to health protection. Citizen have the right to know about wireless equipment and the radiation to which they are exposed, since we know that neither governments nor insurance companies will insure or be legally responsible for any harm to the public’s health caused by exposure to RF EMF. Also a study funded by European Parliament confirms these risks. For devices of class E2 and E10, we are talking about powers of approximately 2 W and 10 W. Such devices have radiated power emissions that can have an adverse effect on health and should be clearly marked with warning labels indicating a safe distance from the device.

Moreover, there is the risk of reduced property values due to the presence of small base stations nearby.

It’s also worth noting that the Regulatory Scrutiny Board, which was tasked with reviewing the impact of the GIA proposal, found a number of flaws and there was no assessment of the environmental impacts or the human health impacts of 5G deployment. The revised version of the impact assessment acknowledges that “… we did not seek to quantify the deployment-related impacts of different options for mobile networks…” and acknowledges that “the literature on the environmental impacts of 5G deployment is limited as it is an area that is still subject of research.

Also European Parliamentary Research Service documents state that “Various studies suggest that 5G would affect the health of humans, plants, animals, insects, and microbes – and as 5G is an untested technology, a cautious approach would be prudent. The UN Universal Declaration of Human Rights, the Helsinki Accords and other international treaties recognise that informed consent prior to interventions that might affect human health is an essential, fundamental human right, which becomes even more controversial when considering children’s and young people’s exposure.

Please read more in our article:
signstop5g.eu/en/solutions/5g-in-depth-analysis-for-itre-committee

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/14029-Light-deployment-regime-for-small-cells-amendment/F3469656_en

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