Environmental Impact Report of the draft ordinance of the Brussels Region aiming to increase the protection limit against electromagnetic radiofrequency radiation (EMC-RF) from 6 to 14.5 V/m implicitly considers that the deployment of 5G is inevitable and does not consider at any time the possibility of staying with the current situation (2G, 3G and 4G). Both the saturation of the current network and the rollout of 5G are considered inevitable, while the possibility of taking adequate measures to limit data traffic is not mentioned. The report (or its « non-technical summary ») presents a first major bias.
It is regrettable that an administration like Brussels Environment , which is supposed to be independent of the executive, publishes such a biased report, just like the establishment of the « 5G » citizens’ deliberative commission by this executive. As a reminder, this commission, composed of 15 deputies and 45 citizens chosen at random from the Brussels population, had to answer the question » How do we want 5G to be implemented in the Brussels-Capital Region, taking into account the environment, health, economy, employment and technological aspects? « . From the outset, there was no room in this commission for citizens opposed to the deployment of 5G, who had no choice but to refuse to participate. To claim to be based on the « recommendations » of this Commission, as is done in the report, is therefore inadmissible, whether it be for the recommendation « to adopt a strict emission standard (sic) of 14.5 V/m », the « environmental measures » to be taken, the « complementary or corrective measures », etc.
On the vital issue of anthropogenic climate change, which we do not need to revisit in light of current events, the findings of Brussels Environment in the summary seem unbearably light: despite the observation of the » the telecommunications sector is a major consumer of energy and emitter of greenhouse gases » (page 9 of the summary) and, as everyone knows, despite the enormous efforts to be made to reduce greenhouse gas emissions, the increase in energy consumption and greenhouse gas production related to the deployment of 5G is quietly envisaged, this aspect not even being mentioned in the conclusions of this summary (the majority of readers of the study will be content to read the summary which is still 18 pages long, the report being 90).
However, the conclusions of the report (page 86) are much more clear: « … although environmental provisions are included in the Ordinance, they will only slightly mitigate the significant increase in energy consumption and waste generation generated by the deployment of 5G compared to this deployment under the current ordinance (alternative 0), which is moreover in opposition to the Region’s climate and environmental objectives aimed at a reduction in GHG emissions and sustainable, sober, local and circular consumption « . Why didn’t you leave this sentence in the summary’s conclusions?
ICNIRP, an instrument for the lobby
With this report, Brussels Environment continues the democratic smoke and mirrors process initiated by the executive while at the same time disinforming and contributing to the factory of ignorance dear to the telecom lobby, in particular on the international protection standards, notably those of the ICNIRP (International Commission on Non-Ionizing Radiation Protection), which would protect from the « only proven biological effect », namely the thermal effect; there are many other « potential » biological and even health effects[6 ], but no study has shown a causal relationship (section 1.3.1.f of the summary, page 11).
In this respect, the report simply cites studies that support the theses of the ICNIRP and the telecom lobby and ignores all the others, in fact thousands of studies published over the last 50 years. For example, what the report says about genetic effects is particularly appalling and reaches the heights of misinformation: » Reassuringly, the results show that the more scientifically serious a study is, the lower the observations of genetic damage » (on these genotoxic effects, see below). A fortiori, the authors of the report cannot be relied upon to expose meta-analyses that show that the conclusions of studies on biological and health effects are a function of the mode of financing: for the most part, studies financed by industry do not show biological or health effects, unlike those financed by public funds or by organizations independent of industry This influence is not new: for 85 studies on the genotoxicity (DNA damage) of RF-EMCs published from 1990 to 2005, 43 studies showed an effect, 42 found none, a more or less equal distribution (which is not unusual in this type of comparison). On the other hand, what is remarkable is that 32 of the 35 studies funded by the cell phone industry lobby and the US Air Force show no effect; moreover, one of the three lobby-funded studies that did find an effect was almost not published (source: www.microwavenews.com/RR.html ).
Most countries in the world rely on the recommendations of the ICNIRP which is a private institution under German law created in 1992 by Michael Repacholi to best serve the needs of the telecom industry. It works like a closed club: its members decide who can enter and only those who defend the idea that if there are no thermal effects, there can be no health consequences are admitted. It does not apply any rules of transparency or independence, since on the contrary most of its past or present members are known for their links with the telecom industry.
ICNIRP’s close relationship with industry has long been documented in the following surveys and documents:
- ICNIRP: conflicts of interest, regulatory capture and 5G.
In June 2020, MEPs Klaus Buchner and Michèle Rivasi published a report on the independence of the ICNIRP, the main conclusion of which is that » for truly independent scientific advice, we cannot and should not rely on ICNIRP. The European Commission and national governments of countries like Germany should stop funding ICNIRP ».
Information and report on Michèle Rivasi’s website : michele-rivasi.eu/a‑la-une/icnirp-conflicts-interests-5g-and-regulatory-capture .
- How much is safe?
Aninvestigation byInvestigate Europe journalists: » Scientists are sounding the alarm about the health risks caused by radiation from mobile technology. Unfounded, assure most radiation safety authorities. These take the advice of a small circle of insiders who reject alarming research and set safety limits « .
investigate-europe.eu/publications/how-much-is-safe (January 2019).
- Self-referencing authorships behind the ICNIRP 2020 radiation protection guidelines.
» …the ICNIRP 2020 guidelines do not meet the basic requirements of scientific quality and are therefore not suitable as a basis for setting exposure limits for RF-EMF for the protection of human health. With its thermal-only view, ICNIRP opposes the majority of research results… Therefore, the ICNIRP 2020 guidelines cannot provide a basis for good governance ».
By Else K. Nordhagen and Einar Flydal in the journal Reviews on Environmental Health in June 2022. https://www.degruyter.com/document/doi/10.1515/reveh-2022–0037/html
- Aspects on the International Commission on Non-Ionizing Radiation Protection (ICNIRP) 2020 Guidelines on Radiofrequency Radiation.
» The ICNIRP conclusion on cancer risks is, « In summary, no effect of radiofrequency EMFs on the induction or development of cancer has been proven. » This conclusion is not correct and is contradicted by the scientific evidence. Abundant and convincing evidence of increased cancer risks and other negative health effects is now available. The 2020 ICNIRP guidelines allow for exposure at levels known to be harmful. In the interest of public health, the ICNIRP 2020 guidelines should be immediately replaced by truly protective guidelines produced by independent scientists ».
By: Hardell L, Nilsson M, Koppel T, Carlberg M.
Published in Journal of Cancer Science and Clinical Therapeutics
- Conflict of interest and bias in health advisory committees: the case of the WHO working group on electromagnetic fields (EMF). Don Maisch. Published in 2006 in the journal of the Australasian College of Nutritional and Environmental Medicine (ACNEM). Available in French upon request.
Totally inadequate protection limits
» Based on this threshold [ofadverse thermal effect]. and the precautionary principle, the ICNIRP recommends limiting the exposure of the population to radiation not exceeding 41.2 V/m. The current Brussels standard of 6 V/m is therefore 50 times  lower than the ICNIRP recommendation. The Brussels Region has one of the strictest standards in the world, stricter than in Flanders and Wallonia » (abstract, page 8). In fact, this difference is very limited, of the same order as that between plague and cholera as explained below.
The ICNIRP recommended limit is 41.2 V/m (volt/meter) for the electric field strength of radiation with a frequency of 900 MHz (megahertz), which, when converted to power density, equals 4.5 W/m2 (watt/square meter).
The limits recommended by many independent experts for radio frequencies (RF) are far below those of the ICNIRP, by a factor of about 100,000, and thus also below those currently in force in Brussels (by a factor of 2000), in terms of power density. For example, the authors of the BioInitiative report[9 ] recommend a limit of about 5 μW/m2 (microwatt/m2 or 0.04 V/m) for the cumulative exposure of RF waves outside the home. For 2G, 3G and 4G, the European Academy of Environmental Medicine (EUROPAEM) recommends 100 μW/m2 (0.2 V/m), but 10 times less during sleep and 100 times less for children and frail people (1 μW/m2, or 0.02 V/m). TheInstitut für Baubiologie recommends similar values.
These limits may seem low, but they are not surprising when one considers that the values adopted by the ICNIRP represent a billion billion times the level of natural EMF at these frequencies (which means that the limits proposed by the independent experts are still more than a billion times higher than natural EMF).
Moreover, to transport data, the EMFs used for telephony are modulated, which does not exist in nature and represents a little understood component of their toxicity, nevertheless important according to some studies  .
A flawed measurement procedure
The Brussels Region follows the ICNIRP recommendations for the calculation or measurement of RF-EMF: the intensity level of an EMF is averaged over 6 minutes (« RMS value ») and does not account for instantaneous intensity peaks, which are the rule for mobile telephony and to which a « peak value » corresponds. For the biological effects of EMF, it is these peak values that count; to illustrate this fundamental difference, let’s just say that if you were to undergo 100 needle sticks 1 mm deep in the heart (average value), you would not suffer any after-effects, whereas a single needle stick of 100 mm (peak value) could be fatal
The ratio of peak to RMS value in terms of power density is of the order of 25 for a 2G, 3G or 4G antenna, but is much larger, of the order of 1000, for a 5G antenna. From this perspective, 5G could prove to be even more toxic than previous generations.
Why don’t the authors of the report mention this well-known subterfuge?
Misinformed authors of the report?
Section 3.6 of the report(Human Health, page 39) is introduced by a preamble which states, among other things, that » the state of the art presented below is therefore based essentially on the preliminary work carried out by the expert committee « .
It ends with this conclusion (page 41): » For the frequencies currently used, the available data are the result of 20 to 30 years of research… In conclusion, the current state of knowledge does not make it possible to demonstrate any harmful effect, but does not make it possible either to conclude with a total absence of effect on health « .
For anyone who knows anything about the field, this excerpt from the report is shocking. On the one hand, the first data appeared after the end of World War II, almost 70 years ago, and on the other hand, the » harmful effects » have been widely demonstrated, all things that are easy to verify.
Regarding the date of the first studies on the toxicity of artificial RF EMFs, here are two documents that attest to their age. They show that the discovery of non-thermal « adverse effects » goes back nearly 70 years:
1. The report of a symposium on microwave risks held in 1957 in Washington: Proceedings of tri-service conference on biological hazards of microwave radiation, 15–16 july 1957. Pattishall, Evan G. George Washington Univ, 1958.
2. More than 2000 Documents prior to 1972 on Bioeffects of Radio Frequency Radiation.
Glaser, Z.R. [U.S.] Naval Medical Research Institute, 1972.
A bibliography of over 2000 references on biological responses to radiofrequency radiation, published up to June 1971.
Dr. Magda Havas, PhD.
Among many other studies produced over 30 years ago, there are those on the blood-brain barrier (BBB) and the immune system.
Effect on the blood-brain barrier (BBB)
The BBB is a special layer of cells that protects the brain by preventing toxins in the bloodstream from reaching it. The opening of this barrier can lead to developmental diseases of the nervous system, neurodegenerative diseases (Alzheimer’s, etc.) and the development of tumors in the brain.
In 1975, Allan Frey published the result of his research in the Annals of the New York Academy of Sciences: exposure to low-intensity 1.9 GHz microwaves opens the BBB in rats. Subsequently, other peer-reviewed studies confirmed Frey’s findings, in particular those published by the team of Professor Leif G. Salford in the 1990s (Lund University). Leif G. Salford presented the results of his research and his concerns to the EU Parliament in 2000.
- Permeability of the blood-brain barrier induced by 915 MHz electromagnetic radiation, continuous wave and modulated at 8, 16, 50, and 200 Hz
Leif G. Salford et al. 1994.
- Cell Phone Health Risk ?
Allan Frey. 2012.
Allan Frey revisits his 1975 study and explains how corrupt scientists discredited him while at the same time succeeding in reducing research on the health effects of electromagnetic radiation in the United States to a trickle:
- Nerve Cell Damage in Mammalian Brain after Exposure to Microwaves from GSM Mobile Phones
Leif G. Salford et al. 2003. Free access.
- Leif G. Salford’s presentation to the EU Parliament in 2000: electrosmog.grappe.be/doc/sc/brain/Salford-Leif_Parliament-EU_2000.pdf
From 1970 onwards, studies were conducted in the USSR on the effects of RF-EMF on the immune system of laboratory animals. Key findings include:
- Chronic daily exposure of 100–500 μW/cm2 can induce irreversible biological pathological reactions.
- 50 μW/cm2 is the exposure threshold for adverse biological effects. These effects are not pathological, as the body can compensate, but in the long term the continuous compensation can lead to undesirable effects.
For comparison, the ICNIRP limit at the frequencies considered (around 2 GHz) is close to 1000 μW/cm2.
- This research has also shown the existence of a dose-dependent relationship in the effects of RF-EMF on the immune system.
Source: Evidence for Effects on Immune Function. BioInitiative Report, Section 8. https://bioinitiative.org
In 1995, Henry Lai, professor of bioengineering at the University of Washington, and N.P. Singh published the first paper reporting DNA damage in the brain cells of rats exposed to radiation similar to that emitted by cell phones.
In June 2022, the same Henry Lai made an inventory of studies on the genotoxic effects of very low frequency and radio frequency (RF) electromagnetic radiation. For RF, he identified a total of 423 studies, of which 291 (68%) showed genetic effects and 132 (32%) did not.
The precautionary principle hijacked
Page 27 of the report: » The threshold for biological effects has been identified at 4W/kg, or 292 V/m2, which corresponds to an exposure beyond which the thermal effect is harmful, because the body is no longer able to evacuate the heat properly. The ICNIRP has established maximum exposure guidelines based on the precautionary principle and only known and proven effects [i.e. the only thermal effect, all other effects being denied]. The precautionary principle implies that where there is uncertainty about the existence or extent of risks to human health and the environment, protective measures should be taken without waiting for the reality or seriousness of these risks to be fully demonstrated. Therefore, the ICNIRP applies a safety factor of 50 and recommends limiting the exposure of the population to radiation not exceeding 41.2 V/m. The current Brussels standard of 6 V/m is therefore 50 times lower than the ICNIRP recommendation « .
The authors of the report could not have defined the precautionary principle better, but they are staggeringly blind to all the scientific literature on the biological and health effects of RF-EMFs, which allows them to say, without shame perhaps, that the precautionary principle is well respected. They also refuse to listen to the appeals of scientists and doctors from all over the world, which have been multiplying over the last 20 years. For example, consider the call initiated in 2015 and signed in April 2020 by 253 EMF experts from 44 different countries; these scientists, all of whom have published peer-reviewed research on the biological and health effects of EMF, are calling for stricter exposure limits and for a review of the potential biological impacts of 4G and 5G telecommunications technologies on plants, animals, and humans ( emfscientist.org ). Another example is the international appeal launched in 2018 calling for a halt to the deployment of the 5G terrestrial and space network ( 5gspaceappeal.org ) having gathered over 300,000 signatures from scientists (7,000+), engineers (14,000+), doctors (4,400+) and citizens.
Economic cost of 5G deployment
The increased energy consumption associated with the rollout of 5G will inevitably result in higher costs for mobile network users, especially given the current surge in electricity prices. This is obvious when you consider that, just for the operation of the 5G network, an increase in the country’s power consumption of around 2% is commonly accepted.
It’s to the point where the economic viability of 5G has been questioned by Orange France employees in a fortunately leaked internal document; they also challenge the rollout of 5G on the basis of its environmental consequences: www.stop5g.be/fr/doc/Orange_Pourquoi-stopper-la-5G_sept2020.pdf
Spokesperson of the Collectif stop5G.be
The Collectif stop5G.be invites you to respond to the public survey,
see the Actions section of his website:
 RF-EMF: radio frequency (or microwave) electromagnetic field (or radiation).
 See La 5G et la démocratie cosmétique, the letter from a citizen who refused to participate in this « fool’s game » on the website of the newspaper La Libre: https://www.lalibre.be/debats/opinions/2021/04/01/la-5g-et-la-democratie-cosmetique-ESTTTZNHA5DIBK7ZIDXC5ELYNQ/
 Dramatic floods, gigantic forest fires and other disasters that are no longer natural given their frequency and size, acceleration of the decline in biodiversity, etc.
 The thermal effect: the heating of the tissues.
 In this section on the state of current human health (before 5G deployment), there is no mention of health effects, although cancer and other diseases are cited in the potential effects. The report itself is hardly more specific on this point (page 39).
 In a similar vein (cancer caused by very low frequency EMF), but more recent : Extremely low frequency electromagnetic fields and cancer: How source of funding affects results. David O. Carpenter. 2019. https://doi.org/10.1016/j.envres.2019.108688
[8 ] V/m (electric field strength) cannot be directly compared to W/m2 (electromagnetic field power density). It is necessary to convert the intensities into power densities and then compare the densities. Alternatively, since the power density varies as the square of the intensity, it is sufficient to take the square of the ratio of the intensities — (41.2/6) squared equals about 50.
 BioInitiative 2012. A Rationale for Biologically-based Exposure Standards for Low-Intensity Electromagnetic Radiation (Argument for low-level electromagnetic radiation protection standards based on biological effects).
The BioInitiative report is the work of 29 independent scientists from 10 countries, all of whom are experts in the field (21 of whom have one or more PhDs and 10 of whom have one or more medical degrees). It provides a state of knowledge of the effects of electromagnetic fields (EMF) on humans and living organisms, based on several thousand scientific studies.
- org (2012. 1500 pages). Since 2012, it has gone through several updates.
- The French translation of the report summary : grappe.be/doc/BIR/BioInitiative_Resume-for-the-public_2014.pdf
 Planetary electromagnetic pollution: it is time to assess its impact.
Priyanka Bandara, David O Carpenter. 2018.
 The roles of intensity, exposure duration, and modulation on the biological effects of radiofrequency radiation and exposure guidelines. Henry Lai & B. Blake Levitt. Electromagnetic Biology and Medicine. 2022. https://doi.org/10.1080/15368378.2022.2065683
 Root mean square: root mean square.
 Or « peak value » (PEAK).
 The Dark Side of 5G (David Bruno, 2022), page 45.
 For example, it is well known that the peak signal power of a DECT cordless phone base station can be up to 100 times higher than the average signal power.
 Genetic Effects of Non-Ionizing EMF Abstracts (2022)
Henry Lai. 2022.