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18 October 2020

Switzerland: Open letter to the Swiss Federal Council on increase in limit values

Open letter to the Swiss Federal Council on increase in limit values addressed by the association "Protection against Radiation" and other organizations
https://schutz-vor-strahlung.ch/, 30 September 2020 - translation

Mrs. Simonetta Sommaruga
President of the Swiss Confederation

Federal Councilors 

30 September 2020

Thank you for your reply to our letter of 15 July 2020. We are very pleased that the Federal Council has decided not to relax the limits, and that the great skepticism in many parts of the population is taken seriously. This shows us that the protection of the people in our country is an important concern.

But we are all the more surprised that the Federal Council - according to Sonntagsblick of 13 and 20 September 2020 - wants to introduce a "facilitation factor" for adaptive antennas, which is highly  controversial. Because in reality, such a "facilitation factor" is a massive increase in the limit values.

With this factor, the operators get permission to transmit with much more power than they are allowed via the approved building permit. With conventional antennas, radiation exposure should still never exceed the limits, but in the vicinity of adaptive antennas, exceeding the limits can be expected with certainty.

Radiation from adaptive antennas is generally more dangerous to human health than radiation from conventional antennas. Why? Adaptive antennas only irradiate those areas where users are located. Within a millisecond, they can focus the radiation on a narrow area like a spotlight and thus follow the users. In the process, the radiation increases strongly. Particularly serious is the fact that adaptive antennas have become a novel, extremely strongly fluctuating radiation exposure. In addition, every adaptive antenna irradiates its entire radius every 20 milliseconds to find new users.

The Federal Constitution obliges the Confederation to enact regulations for the protection of humans  from harmful or annoying effects. According to Art. 11 para. 3 of the Environmental Protection Act, the emission limits must be tightened if it is to be expected that future impacts will be harmful or will be annoying. However, already today, the current limit values do NOT comply with Art. 11 para. 3 of the Environmental Protection Act. According to the latest findings, mobile phone radiation has biological effects: It is already annoying and probably harmful below the permitted limits.

The biological effects depend on the one hand on the electrical field strength [V/m], which is the basis of our current limit values. On the other hand, pulsation, modulation, strong continuous exposure, fluctuations and other factors have a considerable influence on various biological structures in the organisms of humans, animals and plants.

Particularly serious are the indications of the carcinogenic effect of mobile phone radiation. The new antenna technology and the stronger pulsations considerably intensify this situation. With regard to the precautionary principle, scientifically probable but not yet proven effects must also be taken into account.

In its comprehensive report on the effects of 5G on human health, the scientific service of the EU Parliament explicitly warns against numerous dangers of 5G and adaptive antennas. In particular, pulsed mobile phone radiation is biologically more active and thus more harmful than unpulsed radiation.

A "facilitation factor" enabling this dangerous, strongly pulsed radiation would by itself already result in even higher radiation exposure than is already permitted today (Annex 1 No. 63 ORNI [Ordinance on Protection against Non-Ionizing Radiation]). And that higher radiation would mainly occur in homes, workplaces, schools, hospitals and kindergartens - in other words, in the very places that you consider to be particularly worthy of protection. Therefore we ask you, dear Federal President, to please keep your word and to completely re-set the limit values to their current levels, or even to lower them.

The damage to our health would not be the only violation of rights as a result of the "facilitating factor". Rather, such a factor would lever (block) out the rights of the population, communities and cantonal NIR [non-ionizing radiation] departments. As soon as the OFEV [Federal Office of the Environment] would publish the enforcement recommendation, the Swiss population as well as its municipalities and cantonal offices would be forced, for the first time since the introduction of ORNI , to accept higher-than-permitted radiation exposure without authorization for each individual antenna.

Another important fact: Adaptive antennas would be privileged over conventional ones, which would be contrary to the Swiss Constitution. Without an objectively justified reason for privileging, the amendment to the ordinance - especially with regard to a nationwide 5G network – would constitute an inestimable danger of harmful radiation.

In addition, the Federal Office for the Environment would in the future indirectly participate in the decision on the limit values for adaptive antennas, which in view of the great importance of mobile radio limit values is not legally justifiable.

Public interest in 5G and its possibilities is very limited. Since its launch in 2018, not a single company has shown serious interest in nationwide 5G - with the exception of the mobile network operators themselves. The population raises objections against about 95% of all building applications. According to the latest omnibus studies of the Federal Statistical Office, we can see that as early as 2019, over 60% of the population classified mobile phone systems as dangerous, while the vast majority of municipalities put applications for construction of adaptive antennas on hold.

In summary: The "facilitation factor" and its associated excess of permitted radiation limits are neither legally justifiable nor are they in the public interest.

We would be happy to give you a short presentation (15 minutes) during a personal meeting to explain the extent and effects of a "facilitation factor" - using charts and practical examples.

We represent the interests of more than 130'000 people who are directly affected by (planned) adaptive antennas and strictly reject the introduction of a "facilitation factor". Therefore, we consider it proportionate to be heard in person - with the same right as mobile phone operators.

Independently of this, larger sections of the population will take all legal measures against the excessive expansion of mobile communications and the gradual conversion of the fixed network to the mobile network. In accordance with the Federal Constitution, Article 74 paragraph 2, we demand that the Federal Council actually take every step possible to avoid harmful and annoying effects. Together we are committed to the protection of our health, nature and the environment. Those affected will fight through all instances for their right to a healthy life.

Like the Doctors for Environmental Protection, we also demand the retention and strengthening of protection levels – without any hidden limit value increases!

Therefore, our central demand is: To compensate for the increased danger of adaptive antennas, a distinction between conventional and adaptive antennas is necessary. To implement Annex 1 point 63 of ORNI, the only correct solution remains the introduction of stricter limits for adaptive antennas - e.g. in the form of a health factor that reduces the aggressive pulsation as well as other properties that now increase the hazards of 5G.

We thank you in advance for a decision in the sense of real and sustainable health protection.

Kind regards, 

Rebekka Meier
President Association « Protection against Radiation »

and subsequent co-signatories 

Original letter in German:

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