EM Radiation Research Trust – Formal Planning Objection

Application Reference: 25/04239/FUL
Location: Beechen Cliff School, Kipling Avenue, Bear Flat, Bath, Bath and North East Somerset, BA2 4RE
Objector: EM Radiation Research Trust (RRT)
Comment Submission Reference: C32478
Date: 26th November 2025

Dear Sir/Madam,

On behalf of the EM Radiation Research Trust (RRT), a registered UK charity focused on the health risks associated with electromagnetic fields (EMFs), we are formally objecting to the proposed telecommunications equipment at Beechen Cliff School.

1. Primary Evidence of Carcinogenicity and 5G-Specific Risks

Independent studies show biological effects from RF exposure, including 5G deployments:

  • ◆ IARC / WHO (2011): RF EMFs classified as Group 2B “Possible Human Carcinogen”.
  • ◆ National Toxicology Program (NTP, 2018): Clear evidence of carcinogenicity in rats.
  • ◆ Ramazzini Institute (2018): Brain and heart tumours at non-thermal exposure levels.
  • ◆ Mevissen et al. (2025): Increased cancer in male rats at environmental exposure levels.
  • ◆ EU REFLEX Project (2000–2004): Non-thermal RF exposure caused DNA/genotoxic effects in human cells, equivalent to 1,600 chest X-rays in 24 hrs.
  • ◆ Hardell & Nilsson (2024/2025): Case reports and reviews document adverse health effects associated with 5G base stations, including severe symptoms in children and adults.
  • ◆ Nyberg, Nilsson & Hardell (2024): 5G densification and beam-forming increase real-world exposure; current ICNIRP limits may not be protective.
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These studies demonstrate that 5G and other mast emissions are a real-world concern, especially for children and vulnerable populations.

2. Vulnerable Populations

The proposed installation is adjacent to a school. Children are particularly sensitive due to:

  • ◆ Developing nervous systems
  • ◆ Higher tissue absorption
  • ◆ Longer lifetime exposure

The Precautionary Principle requires local authorities to carefully consider these risks before approving RF-emitting infrastructure near schools.

3. Policy Precedent – Stewart Report (2000)

The Stewart Report (2000), commissioned by the UK Government, explicitly recommended a precautionary approach:

  • ◆ 1.18: Biological effects may occur below guideline levels.
  • ◆ 1.19: Exposure below guidelines is not guaranteed to be entirely safe.
  • ◆ 1.42: The beam of greatest RF intensity should not fall on any part of school grounds or buildings without agreement from the school and parents.
  • ◆ 1.53: Children may be more vulnerable due to developing nervous systems, higher absorption, and longer lifetime exposure.

Reference: Stewart Report 2000 – EM Radiation Research Trust

4. Millstead Primary School Incident – Measured Exposure & Child Health Risk

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At Millstead Primary School, Liverpool, following the tragic deaths of two children from unknown causes, RRT measured peak RF levels near a mast at 1,554,932 µW/m².

For comparison:

  • ◆ Russia and China set public RF limits at 0.1 W/m² (100,000 µW/m²).
  • ◆ The levels measured at Millstead far exceed international precautionary thresholds.

This incident highlights the need for extreme caution when siting or upgrading telecommunications infrastructure near schools and vulnerable populations.

Reference: RRT Call for Investigation – Millstead School

5. Legal Precedent – Thomas v Cheltenham Borough Council

  • ◆ The High Court (2024) and Court of Appeal (2025) confirmed that ICNIRP compliance does not remove a council’s obligation to assess health risks, including risks to vulnerable individuals.
  • ◆ Health impacts from RF-emitting infrastructure must be considered independently, not dismissed on the basis of guideline compliance alone.

6. Legal and Procedural Considerations

UKHSA and ICNIRP guidance is not legally binding. Councils retain statutory duties to residents, including:

  • ◆ Duty of care
  • ◆ Human rights obligations (Articles 2 & 8)
  • ◆ Requirement to apply the Precautionary Principle
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Approving this application without fully considering independent scientific evidence, the Stewart Report recommendations, and legal obligations would be contrary to statutory duties, precautionary governance, and public trust.

Yours faithfully,

EM Radiation Research Trust

References & Supporting Evidence

Thomas v Cheltenham Borough Council, High Court 2024 / Court of Appeal 2025

Monster Mast Info Pack – EM Radiation Research Trust

IARC Monograph Volume 102 (2011)

NTP RFR Studies

EU REFLEX Project

Hardell & Nilsson 2024/2025; Nyberg, Nilsson & Hardell 2024

Stewart Report (2000) – RRT

Millstead Primary School RF Investigation – RRT

Source