Katherine Moore
25th September 2023Maidstone Mast Update #5 - Monday 25th September 2023
Dear friends, supporters and fellow-campaigners,
I have some good news, some bad news, and some news that might be of interest to anyone else who is currently fighting plans for telecoms masts in their areas.
Firstly, I wanted to give you a quick update on the situation with the mast in Maidstone that I've been campaigning against. In my last update, I said that I'd be writing letters to the MP for Maidstone, Helen Grant, and to the following Secretaries of State, calling on them to intervene and overturn the council's decision to approve the mast. I posted my letters using Royal Mail 'Signed For' in July:
Steve Barclay - Dept of Health
Gillian Keegan - Dept for Education
Thérèse Coffey - Dept for Environment
Chloe Smith - Dept for Science, Innovation and Tech.
The outcome:
Helen Grant MP said that she couldn't do anything for me.
The Department for Education said this:
“I note your concerns about the installation of the 5G mast, however this falls outside of the department's remit and will be a matter for the local planning authority.”...
...“We have passed your enquiry on to the Department for Levelling Up, Housing & Communities as they are responsible for the policy on the issue you have raised”
To date, I haven't received a response from any of the other Government Departments that I wrote to.
LAST MONTH'S PLANNED PROTEST AT THREE HQ
In August, I intended to protest outside of Three's Headquarters in Reading. However, after doing an online recce of their site, I came to the conclusion that a protest in this location could be a wasted effort. The headquarters is fronted by a large staff car-park and it is situated in a bleak-looking industrial park. Getting anywhere close to the building without being ushered away would be difficult, and protesting on the outskirts of Three's grounds would simply go unnoticed. Plus, there's a tall 5G mast on the edge of the staff car-park and I didn't feel comfortable spending any length of time around it.
Instead, I decided to write an assertive, but polite, letter to Three's CEO, Robert Finnegan. The response I received was unsurprisingly disappointing. Most of the letter referred to ICNIRP.....
“The planning application included details of the proposed location, site design and an ICNIRP certificate....
“...the certificate confirmed the site complies with the ICNIRP standards, as required by our Government and its health advisers.”...
...“The ICNIRP standards cover all the population including children. The Government has said that adherence to the ICNIRP standards provides all the necessary health precautions.”
There was a bit more about ICNIRP, followed by some links to further information, before ending with:
“In conclusion this site has received a planning approval and will be built in line with Government guidance and the decision notice attached.”
At least someone at Three took the time to look through the planning application in question, so there's that.
INVALID HEALTH AND SAFETY CERTIFICATES
On the subject of ICNIRP, a fellow-campaigner recently pointed out something very interesting. Now, this could be useful for anyone else fighting plans for telecoms masts around the country, specifically those masts that operate on the Three mobile network. Some of you will know this information already. It relates to the 'ICNIRP Certificate', also known as the 'Declaration of Conformity'. It's a document that must be submitted to the council by the applicant when proposing to erect a telecoms mast.
ICNIRP is an abbreviation for the International Commission on Non-Ionizing Radiation Protection. The ICNIRP Certificate is a critical part of a planning application for a new, or upgraded telecoms mast. It is a declaration, made by the telecoms company involved, that the mast will operate in accordance with the ICNIRP Guidelines, and that it will comply with domestic and European legislation concerning the exposure of the public to electromagnetic radiation. An incorrect ICNIRP Certificate may invalidate the entire planning application.
You can find a copy of the ICNIRP Certificate if you visit any council's planning portal and search through the 'Documents' tab on any mast application made in recent years.
In the case of the Maidstone mast, the ICNIRP Certificate says this:
--------------
Declaration of Conformity with International Commission on NonIonizing Radiation Protection Public Exposure Guidelines
Three UK Limited
Star House,
20 Grenfell Road
Maidenhead,
SL6 1EH
Declares that the proposed equipment and installation as detailed in the attached General Permitted Development Order application at:
Address:
ASHFORD ROAD,
BOXLEY,
MAIDSTONE,
KENT,
ME14 5DL
is designed to be in full compliance with the requirements of the radio frequency public exposure guidelines of the International Commission on Non-Ionizing Radiation Protection1 as expressed in EU Council Recommendation 1999/519/EC of 12 July 1999 “on the limitation of exposure of the general public to electromagnetic fields (0 Hz to 300 GHz)".
Cell No: MAI26036
Cell Name: ASHFORD ROAD STREETWORKS
Reference: MAI26036_M001
Date: 03/03/2023
Signed: D.Hadden
Name: Dave Hadden
Position: Senior Cad Lead/QA
--------------
Click the link below to go to Maidstone Borough Council's planning portal. This ICNIRP Certificate can be found under the 'Documents' tab.
Maidstone Borough Council Planning Portal (application no. 23/501215/TNOT56)
So, Three UK Limited is making health and safety declarations in relation to the RF emissions from this mast. The trouble is, the named company, Three UK Limited, was dissolved back in 2015. Also, it was never based at the Star House address. See the Companies House records here:
THREE UK LIMITED - Company number 03004157
The confusion may stem from the fact that 'Three UK' (without the word 'Limited') is a brand name used by Hutchison 3G UK Limited, which, presumably should have been the company named on this certificate. Three UK Limited is a different company altogether, and as far as I know, it bears no relationship to Hutchison 3G UK Limited (i.e. Three UK). However, Hutchison 3G UK Limited was based at Star House up until March 2021. After that, it moved to Reading. The person who produced this ICNIRP Certificate obviously didn't get the memo. The certificate was signed in March 2023.
It could be argued that these errors are just technicalities. At best, they're merely clerical errors, but at worst, they may constitute an attempt to gain planning permission using false information.
Certificates such as this, with the incorrect company name and address, have been issued in support of numerous, possibly thousands, of mast applications around the country, going back as far as 2019. My view is that all these incorrect certificates should be deemed invalid, thus, rendering the telecoms masts non-compliant with heath and safety guidelines.
If you're currently opposing plans for a Three mast in your area, or you intend to challenge a recent decision to approve one, then it's worth checking the ICNIRP Certificate, and using this information to support your case, where appropriate. However, it seems that the telcos may have recently got wind of this issue, as I'm beginning to see new mast applications appearing on planning portals that include the correct company details for Three in the ICNIRP Certificates.
Also, don't take it for granted that the proposed site address listed on the planning application documents is correct. In my case, every application document for the Maidstone mast contained an error in the site address. See the details on the ICNIRP Certificate that I referred to earlier; Boxley is an area of Maidstone situated approximately 2 miles from the intended site of the mast. Also, the postcode, ME14 5DL, is actually 100 metres down the road from the intended site. This was pointed out to Maidstone Borough Council back in April, and I was hoping to use this error as one of the grounds in my Judicial Review proceedings earlier this year.
According to the Government's 'Code of Practice for Wireless Network Development in England (2022)'...(emphasis is mine):
'High-quality applications are essential and this includes ensuring the information provided in the application is of a good standard. The application information should be complete and straightforward.....'
'The quality of information submitted as part of an application for telecommunications development is very important. It should always be clear, accurate and complete.....'
Code of Practice for Wireless Network Development in England
It is evident that many of the planning applications that are being approved by councils all around the country are far from being of high-quality, and in some cases, they're certainly not straight-forward, clear, accurate or complete!
POLITICAL INTERVENTION IN LINCOLNSHIRE
Some of you may be aware of a recent campaign against a telecoms mast in Wrangle, Lincolnshire. The situation in this case was very similar to that of the Maidstone mast, i.e. the same company supplied an invalid ICNIRP Certificate to the council, who gave the green light to install a mast outside of a school. (Why does this company insist on siting these masts right outside of schools and nurseries?).
Fortunately, the plans were eventually halted after the intervention of the local MP, Matt Warman (former Digital, Culture, Media and Sport minister). Here's some of what he said in his Facebook post:
“...the positioning of masts is an emotive topic, and in order to maintain public confidence it’s important that networks get these decisions right. I am pleased that following my intervention, the Chief Executive of Three has agreed not to proceed with the proposed mast outside Wrangle Primary School, and has now committed to exploring other more suitable sites in the local area.”
A screenshot of his whole Facebook post is attached to this update.
Matt Warman might have saved the day with his intervention, but I'm aware that the campaigners of Lincolnshire had been seeking his help for months, but to no avail. Coincidence or not, it wasn't until the issue surrounding the validity of the ICNIRP Certificate had been raised that he finally stepped in. Either way, I am so pleased with the result.
I'm currently seeking a meeting with my constituency MP, Tom Tugendhat, to urge his intervention over the Maidstone mast, also on the basis of an incorrect ICNIRP Certificate.
ANOTHER FORMAL COMPLAINT
In light of the issues with the ICNIRP Certificate for the Maidstone mast, I've lodged another formal complaint with the council. I'm prepared to escalate my complaint right up to the Local Government and Social Care Ombudsman if I have to. I'm asking that the decision to approve this mast outside of my son's school be reversed, since it was based on the supply of false and invalid information. I am awaiting a response.
SOME GOOD NEWS
I've been invited back onto the Richie Allen show tomorrow evening (Tuesday 26th September). I'll be joined by one of the volunteers, Julia Burgess, who's been helping me with my campaign over the last few months, and we hope to discuss the issues with the ICNIRP Certificates, amongst other things. Please listen in to the show, if you can. It goes out live from 5pm until 7pm. The link is below. Go to the 'Listen LIVE!' box on the right hand side of the page:
PARLIAMENTARY PETITION
Please sign this Parliamentary Petition. It calls on the Government to outlaw the practice of installing 5G masts close to schools and nurseries. If it receives more than 100,000 signatures, then the subject will be considered for debate in Parliament. Please help to make this happen by sharing it all over social media. Here's the link to it:
Prohibit 5G Masts near Schools and Nurseries
NOW HERE'S THE BAD NEWS....
I've recently discovered that the work to install the Maidstone mast is due to begin on Saturday 7th October. This is obviously a massive blow to me and the others who've helped me during this long campaign. Unless a miracle happens between now and then, it looks like we may have lost our fight. But..... it's not over, 'til it's over!!
CROWD FUNDER
I wanted to thank everyone for contributing to my crowd funder. With your help, I've now been able to settle all my legal costs from earlier this year, so thank you very much for that! However, I'm still welcoming donations to my crowd funder, because when the fight against the Maidstone mast comes to an end, I'll have more time to join other campaigners in their fights against masts outside of schools, and if legal action is necessary, then it would be very useful to have a kitty built up in readiness to help fund any such action. A huge factor that prevented me from proceeding with my Judicial Review case against the Maidstone mast was a lack of funds and a lack of time in which to raise them. It would be great if someone else had the opportunity to see any legal action through to the end, if it ever became necessary.
Finally, I have an eight foot banner that was made for my peaceful demonstrations outside the two schools earlier this year. It says 'STOP THE MAST OUTSIDE THIS SCHOOL'. You can see it in the photos on my previous update. I'd be very happy to loan the banner to anyone who's planning a similar protest outside of any other schools. All I'd ask is that you cover the postage costs both ways (medium parcel tracked delivery is approx £7 each way). I'd also be very grateful for a small contribution towards my crowd funder in return. Any contributions will help to build up the kitty that I mentioned. The link to the crowd funder is below.
Thank you again, for being there for me, and for giving your much-needed support. I couldn't do this without you.
Kate x
My Crowd Funder - Stop 5G Mast by Maidstone Schools
My Facebook Page - Stop 5G Mast by Maidstone Schools
Parliamentary Petition - Prohibit 5G Masts near Schools and Nurseries
RF Info - To learn more about issues with telecoms masts and what can be done
Useful Facebook Group - Post UK 5g Mast Applications That Need Objections Here
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