Radio-frequency 5.1 Standards

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5.1 Standards

Radio-frequency emissions are addressed by the National Environmental Standards for Telecommunication Facilities (NESTF) in Regulation 4, which mandates compliance with two New Zealand standards:

NZS 2772.1:1999 Radiofrequency Fields Part 1: Maximum Exposure Levels – 3 kHz to 300 GHz

NZS 6609.2:1990 Radiofrequency Radiation: Principles and Methods of Measurement – 300 kHz to 300 GHz.

The two questions addressed here are whether the standards are still relevant, and if so, whether they are being complied with.

Relevance was ascertained through two sources. The first was the minutes of the Interagency Committee on the Health Effects of Non-Ionising Fields. This committee keeps a watching brief over international research on these matters and has been meeting every six months since 2001.¹³ The second source was the expert advice of Mr Martin Gledhill.¹⁴

5.1.1 NZS 2772.1:1999

Expert advice suggests that this standard is still relevant. NZS 2772.1:1999 is based on guidelines published by the International Commission on Non-Ionising Radiation Protection (ICNIRP),¹⁵ and these guidelines were reconfirmed in 2009.¹⁶^,¹⁷ However, the fact that the guidance was published 14 years ago has attracted criticism from some community members that they are out of date, despite the reconfirmation.

In 2011, the International Agency for Research on Cancer (IARC) classified radio-frequency fields as a class 2B ‘possible carcinogen’. The evidence for this is largely based on studies of mobile phone use that suggest that higher levels of use are associated with some types of brain tumour. However, it has been acknowledged that the apparent risk could be due to biases in the data. Laboratory research does not suggest that radio-frequency radiation could affect cancer development. The IARC has noted that typical ‘environmental’ exposures are considerably lower than those the head is exposed to when using a mobile phone.

Scientific reviews published since 2011 have generally concluded that, overall, the evidence does not support there being a causal link between radio-frequency fields and cancer. However, this fails to address the fears of some sectors of the community.

5.1.2 NZS 6609.2:1990

NZS 6609:2:1990 has been superseded by AS/NZS 2772.2:2011: Radiofrequency Fields Part 2: Principles and Methods of Computation – 3 kHz to 300 GHz. The Ministry has advised that NZS 6609.2:1990 should be replaced by AS/NZS 2772.2:2011 in Regulation 4 of the National Environmental Standards . The updated standard provides more practical guidance than its predecessor and is more rigorous in its requirements, and as such follows developments in similar standards overseas.

5.1.3 Are the standards being complied with?

The evidence to hand suggests that NZS 2772.1:1999 is being complied with. Councils do not undertake monitoring and compliance work for permitted activities, mainly because there is no mechanism for them to recover costs.¹⁸ This does not mean that no monitoring is undertaken. Vodafone has a radio-frequency field-monitoring programme at a sample of their cell sites. Since 2004, the National Radiation Laboratory (NRL) has measured radio-frequency fields around a random sample of 10 Vodafone sites (of a total of approximately 200), which the NRL chooses independently of Vodafone. In their 2011/12 report¹⁹ the maximum radio-frequency exposures in public areas were all less than 1 per cent of the public limit.

The NRL undertook a round of monitoring of 2degrees’ sites in 2010, with similar results. Until recently Telecom (now Spark) has had an environmental audit programme, but this is currently under review.

Network operators supply a radio-frequency report to the council for each radio-frequency-emitting device they install. These reports specify where the device is to be installed and whether radio-frequency field exposures in areas reasonably accessible to the public comply with NZS 2772.1:1999.²⁰

Regulation 4(5) states that when a device’s field is predicted to reach or exceed 25 per cent of the maximum level, then ‘post-build’ measurements must be done within three months of the facility becoming operational. There are some methodological issues with this approach, which is known as the ‘25% Rule’, and these are described in section 7.2.3.1 and discussed fully in appendix 6.

All of the councils that responded to the evaluation survey indicated they had a system for retaining radio-frequency reports.

5.2 Data gaps

Evidence suggests that radio-frequency fields from individual devices (or clusters of devices, as measurements must take adjacent devices into account) have been well below maximum exposure limits. However, there is a data gap in that there are no time series on exposures to radio-frequency fields in New Zealand that allow an analysis of change in exposure over time.

Mr Gledhill advises that the most likely change to have occurred since the introduction of the NESTF is that, because the number of cell sites has increased, the average exposure in urban and suburban areas will have increased slightly. Maximum exposures would not have changed even when sites are located close together because of the limits set by NZS 2772.1:1999.

6 How real were the risks identified with the introduction of the NESTF?

6.1 Risks as a result of the NESTF

Some risks to the success of the National Environmental Standards for Telecommunication Facilities (NESTF) were identified during its development and early implementation phase. Whether these risks have been realised after five years is summarised below. Of the seven identified risks, there is evidence of three being realised to some extent.

Table 3: Risks as a result of the NESTF

Risk	Was it realised?
Lack of consistency in how the NESTF is being applied across the country	Not a widespread issue, but examples exist due to: varying interpretation of regulations (see sections 7.1.1–7.1.2) use of Regulation 6 (see section 7.2.2).
Councils being unaware of the NESTF and so not applying the NESTF at all	No reports from industry of this
External factors affecting application of the NESTF, such as the Christchurch rebuild	No reports from industry of this
The NESTF being used as a maximum allowable limit (ie, if facilities do not comply with the NESTF they are not allowed at all, rather than having them revert back to plan rules)	No reports from industry of this
The NESTF could create a permitted baseline for other activities in the road reserve	Unknown
Unintended consequences, such as councils having the ability to require radio-frequency reports for activities that previously would not have needed them	May be occurring. Some councils may be requiring radio-frequency reports for devices that emit weak fields, such as femto-cells and smart meters.
The industry incurring costs because of the dual role of council as consenting authority and corridor manager of the road reserve	Yes. Further investigation is needed to determine the magnitude of the issue.

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