Draft Environmental Scoping report
Five Mini BTS sites in Ludwigsdorf, Windhoek
November 2012
Five Mini BTS sites in
Ludwigsdorf, Windhoek
Draft Environmental Scoping
Report
November 2012
Draft Environmental Scoping report
Five Mini BTS sites in Ludwigsdorf, Windhoek
November 2012
COPYRIGHT © ENVIRO DYNAMICS, 2012. ALL RIGHTS RESERVED
PROJECT NAME Environmental Scoping Report for the proposed construction of
five mini BTS towers in Ludwigsdorf, Windhoek
STAGE OF REPORT Draft Environmental Scoping Report for Public review
CLIENT AGA Technical Services (PTY) LTD
Enquiries: Willem Horn
Tel: (061) 247 872
E-Mail: [email protected]
LEAD CONSULTANT Enviro Dynamics
Enquiries: Eloise Carstens
Tel: (061) 223-336
E-Mail: [email protected]
DATE OF RELEASE November 2012
AUTHOR Eloise Carstens, Eddy Kuliwoye, Lester Harker, Lahya Haitembu
Internal Reviewer: Norman Van Zyl
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DECLARATION
I hereby declare that I do:
(a) have knowledge of and experience in conducting assessments, including
knowledge of the Act, these regulations and guidelines that have
relevance to the proposed activity;
(b) perform the work relating to the application in an objective manner, even if
this results in views and findings that are not favourable to the applicant;
(c) comply with the Act, these regulations, guidelines and other applicable
laws.
I also declare that there is, to my knowledge, no information in my possession that
reasonably has or may have the potential of influencing –
(i) any decision to be taken with respect to the application in terms of the Act
and the regulations; or
(ii) the objectivity of this report, plan or document prepared in terms of the Act
and these regulations.
Eloise Carstens
Environmental Assessment Practitioner (EAP)
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TABLE OF CONTENTS
LIST OF TABLES AND FIGURES .................................................................................................. vi
ABBREVIATIONS AND ACRONYMS ....................................................................................... viii
1 INTRODUCTION .................................................................................................................... 1
1.1 Background .................................................................................................................. 1
1.2 Terms of Reference ...................................................................................................... 1
2 BACKGROUND TO CELLULAR INFRASTRUCTURE .............................................................. 3
2.1 What is a cellular system? ........................................................................................... 3
2.1.1 Cells ......................................................................................................................... 3
2.1.2 Base Station ........................................................................................................... 4
2.2 Concluding remarks on this section .......................................................................... 5
3 PROJECT DESCRIPTION ....................................................................................................... 6
3.1 Rationale for the proposed project ........................................................................... 6
3.2 Proposed locality.......................................................................................................... 8
3.3 The alternatives .......................................................................................................... 11
3.3.1 Tower sharing ....................................................................................................... 11
3.3.2 Alternative site locations .................................................................................... 11
3.3.3 Alternative technology ...................................................................................... 11
3.4 Infrastructure requirements ....................................................................................... 14
3.5 Concluding remarks on this section ........................................................................ 15
4 LEGAL AND REGULATORY REVIEW .................................................................................. 16
5 AFFECTED ENVIRONMENT ................................................................................................. 22
5.1 General description ................................................................................................... 22
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5.2 Social environment .................................................................................................... 22
5.3 Existing background radiation ................................................................................. 26
6 PUBLIC CONSULTATION PROCESS ................................................................................... 29
6.1 Legal and Policy requirements ................................................................................ 29
6.1.1 Environmental Management Act (Act 7 of 2007) and Regulations (2012) 29
6.1.2 Policy for the erection of telecommunication facilities in Windhoek
(2008) .................................................................................................................... 30
6.1.3 Best practice (as described by the world health organization) .................. 31
6.2 Consultation process followed during the EIA ....................................................... 31
6.3 Limitations of the public participation process ...................................................... 32
6.4 The interested and affected parties (I&APS) ......................................................... 32
6.4.1 The Industry - MTC ............................................................................................... 33
6.4.2 Public .................................................................................................................... 34
6.4.3 Service complaints .............................................................................................. 35
6.4.4 Government ........................................................................................................ 36
6.4.5 Public interest groups ......................................................................................... 37
6.4.6 Media.................................................................................................................... 37
6.4.7 Electromagnetic Field (EMF) specialist ............................................................ 37
6.5 Outcome of the public participation process ....................................................... 38
6.5.1 History between MTC and Ludwigsdorf ........................................................... 38
6.5.2 Perceived risks vs. perceived benefits ............................................................. 39
6.6 The key issues .............................................................................................................. 40
6.7 Concluding remarks on this section ........................................................................ 41
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7 IMPACT ASSESSMENT ......................................................................................................... 32
7.1 Methodology employed for the impact assessment ........................................... 32
7.2 Identification of key issues ........................................................................................ 34
7.3 Economic implications .............................................................................................. 43
7.3.1 Background to the need for the project ......................................................... 43
7.3.2 Potential effects of the project ......................................................................... 44
7.3.3 Significance ......................................................................................................... 44
7.4 Disappearance of bees ............................................................................................ 45
7.4.1 Background to the problem .............................................................................. 45
7.4.2 Potential effects from Electromagnetic Radiation (EMR) ............................. 45
7.4.3 Significance of the current project .................................................................. 46
7.4.4 Mitigation measures ........................................................................................... 46
7.5 Reduction in property value ..................................................................................... 47
7.5.1 Background to the problem .............................................................................. 47
7.5.2 Potential effects on property values ................................................................ 47
7.5.3 Significance of the current project .................................................................. 47
7.5.4 Mitigation measures ........................................................................................... 48
7.6 EMF exposure .............................................................................................................. 49
7.6.1 Background to EMF ............................................................................................ 49
7.6.2 Potential biological and health effects associated with EMF ...................... 50
7.6.3 EMf exposure guidelines and policies .............................................................. 53
7.6.4 Compliance of the proposed project with exposure limits .......................... 54
7.6.5 Significance of the current project .................................................................. 55
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7.6.6 Mitigation measures ........................................................................................... 56
8 CONCLUSIONS AND RECOMMENDATIONS ................................................................... 57
8.1 The EIA and public consultation process ................................................................ 57
8.2 Synopsis of the key issues .......................................................................................... 58
8.3 Recommendations .................................................................................................... 59
8.3.1 Considering the no-project alternative ........................................................... 60
8.3.2 Recommendations ............................................................................................. 61
8.4 Final Recommendation ............................................................................................. 62
9 BIBLIOGRAPHY ................................................................................................................... 63
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LIST OF TABLES AND F IGURES
Table 3-1: Description of the five proposed sites. .......................................................... 10
Table 5-1: Description of the social environment surrounding each of the
proposed sites. ................................................................................................. 24
Table 5-2: Ambient RF exposure levels measured at sites in the Ludwigsdorf area
in % below ICNIRP standards. ......................................................................... 26
Table 6-1: Public consultation process followed during the EIA. ................................. 29
Table 6-2: Authorities involved in this project. ................................................................ 36
Table 6-3: Main issues of concern. ................................................................................... 40
Table 7-1: Definition of each of the criteria used to determine the significance of
the impacts ....................................................................................................... 32
Table 7-2: Definitions of the various significance ratings .............................................. 33
Table 7-3: Identification of key impacts. ......................................................................... 43
Table 7-4: Expected significance of the economic implications................................ 44
Table 7-5: Expected significance of the impact on bees ............................................ 46
Table 7-6: Expected significance of the project on property prices. ......................... 48
Table 7-7: Different types of electromagnetic radiation (adapted from (World
Health Organization, 2002) ............................................................................. 49
Table 7-8: Predicted maximum exposure summary at 1.5m above ground level. .. 55
Table 7-9: Expected significance of EMF exposure from the five proposed sites. .... 55
Figure 2-1: Extent of reach of each of the type of cells (Mobile Operators
Association, 2012). ............................................................................................. 3
Figure 2-2: Proximity to base station is one of the factors that influence signal
strength (Mobile Manufacturers Forum, 2008). .............................................. 4
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Figure 3-1: Possition of macro BTS sites close to Ludwigsdorf. ......................................... 6
Figure 3-2: The current coverage in the area provided by the existing macro BTS
sites (A) will be improved by the construction of the proposed five mini
BTS sites (B). Red circles indicate the grouped locations from where
the customer complaints were lodged. ......................................................... 7
Figure 3-3: Location of the five proposed mini Base Station sites .................................. 9
Figure 3-4: Example of a mini BTS in Windhoek. .............................................................. 12
Figure 3-5: Proposed ground plan for the five mini BTS.................................................. 12
Figure 3-6: Pole Structure ................................................................................................... 13
Figure 3-7: A non-scientific depiction of the signal propagation of Omni and
Directional antennae (view from above)................................................... 13
Figure 5-1: The topography of Ludwigsdorf. Note that the proposed sites are
located on the shadow sides of slopes. ...................................................... 23
Figure 5-2: Surrounding land use activities in the area, based on the Windhoek
Town Planning Scheme of 2007 (as amended in draft 2012 version
(No.91)). ............................................................................................................. 25
Figure 6-1: Posters were put up at a conspicuous place close to each of the sites. 30
Figure 6-2: Fourty-six people attended the scheduled public meeting. .................... 31
Figure 6-3: Key role players identified on this project. ................................................... 33
Figure 6-4: Answers obtained for the questions asked during the public meeting. .. 35
Figure 6-5: Overlay of the groupings of people that complained about the
service vs. people that oppose the project. ................................................ 32
Figure 7-1: Screening process to determine key issues .................................................. 34
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ABBREVIATIONS AND ACRONYMS
AM Amplitude Modulation
BID Background Information Document
BTS Base Transceiver Station
CCD Colony Collapse Disorder
COW City of Windhoek
CRAN Communications Regulatory Authority of Namibia
CV Curriculum Vitae
EIA Environmental Impact Assessment
ELF Extremely Low Frequency
EMF Electromagnetic Field
EMP Environmental Management Plan
EMR Electromagnetic Radiation
FM Frequency Modulation
I&APs Interested and Affected Parties
IARC International Agency for Research on Cancer
MET Ministry of Environment and Tourism
MTC Mobile Communications Company
NBC Namibian Broadcasting Corporation
NCC Namibia Communications Commission
Non-Ionising Electromagnetic radiation that does not carry enough energy
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Radiation per quantum to ionise atoms or molecules.
RF Radiofrequency Radiation
SCENIHR Scientific Committee on Emerging & Newly Identified Health
Risks
UMTS Universal Mobile Telecommunications Systems
WHO World Health Organisation
Wi-Fi Wireless Fidelity
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1 INTRODUCTION
1.1 BACKGROUND
With the increasing growth in the use of mobile communication in Windhoek, service
providers such as MTC are under pressure to continuously expand their networks.
MTC argues that by providing additional capacity in areas that suffer from
congestion or poor coverage, the quality of the service provided is greatly
enhanced. It is for this reason that MTC intends to construct five 3G Mini Base
Transceiver Stations (BTS) in Ludwigsdorf, Windhoek.
In accordance with the Environmental Management Act (2007) and its Regulations
(2012) an Environmental Impact Assessment (EIA) is required for the “construction of
masts of any material or type and of any height, including those used for
telecommunication broadcasting and radio transmission”.
Enviro Dynamics has been appointed to conduct an EIA and develop an
Environmental Management Plan (EMP) for the proposed masts. Eloise Carstens and
Norman Van Zyl are the Environmental Assessment Practitioners that conducted the
EIA. Their CVs are attached as APPENDIX A.
1.2 TERMS OF REFERENCE
The Terms of Reference for the proposed project is based on the requirements set out
by the Environmental Management Act (2007) and its Regulations (February 2012).
The process covered the following steps, which are reported on in this document as
follows:
Provide a detailed description of the proposed activity;
Identify all legislation and guidelines that have reference to the proposed
project;
Identify existing environmental (both bio-physical and socio-economic)
conditions of the area in order to determine their environmental sensitivity;
Inform Interested and Affected Parties (I&APs) and relevant authorities of the
details of the proposed development and provide them with a reasonable
opportunity to participate during the process;
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Consider the potential environmental and social (including biological) impacts
of the development, and assess the significance of the identified impacts.
Outline management and mitigation measures in an Environmental
Management Plan (EMP) to minimize and/or mitigate potentially negative
impacts.
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2 BACKGROUND TO CELLULAR INFRASTRUCTURE
2.1 WHAT IS A CELLULAR SYSTEM?
Networks are designed to ensure that mobile phones maintain a link with the network
as users move from one cell to another.
2.1.1 CELLS
Each individual geographic area in a network is called a 'cell'. At the heart of the cell
is a base station. The cells overlap at the edges to prevent holes in coverage. If base
stations are too far apart, calls cannot be handed over from one area to another
and are interrupted or 'dropped' when mobile users are on the move (Mobile
Operators Association, 2012).
There are three types of cells (Figure 2-1):
Macrocell: Provides the main coverage in a network. Typically constructed on
higher ground so that it is not obstructed by surrounding buildings and terrain.
The base station on Bowker Hill is an example of a macrocell.
Microcell: Provides infill coverage and additional capacity where there are a
high number of users in a macrocell. It is constructed at street level, usually
between 300 m and 1000 m apart. The sites proposed in this study are all
microcells.
Picocells: Provides localised coverage and are usually less visible. They are put
up in shopping centres and airports to strengthen the signal.
Figure 2-1: Extent of reach of each of the type of cells (Mobile
Operators Association, 2012).
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2.1.2 BASE STATION
To communicate with each other mobile phones and base stations exchange radio
signals. When a mobile phone is switched on, it searches for a signal from nearby
base stations. As soon as a suitable base station has been located and a signal
established, it maintains a network connection (Swedish Post and Telecom Agency,
2008). The power level generated by a mobile phone to maintain a good
connection depends on the distance from the base station; the greater the
distance, the more power is needed. Mobile phones automatically step down to the
lowest power level that maintains communication with the base station. The power
output is therefore less when the base station is close to the phone user. Hence,
base stations are being placed closer together, to make it simpler for a phone and a
base station to communicate reliably.
Each base station is configured to cope with a certain number of calls being made
at the same time. When there are too many sources sending data simultaneously, it
may become too much for the network to handle (Mobile Operators Association,
2012). When this happens, the network slows down or starts loosing data, a
phenomenon known as network congestion. It degrades the quality of the service
and can lead to delays, lost data or dropped calls on a telephone network. The
situation is worse during peak times such as the holiday seasons when there are large
volumes of text messaging and voice traffic. This is just one of the reasons why one
single base station cannot serve an entire area.
In order to ensure the lowest risk of interference between base stations in the
network, operators have to keep their RF power outputs to the lowest possible level
that could still provide effective service provision (United Kingdom: Department for
Communities and Local Government, 2001).
Figure 2-2: Proximity to base station is one of the factors that influence signal strength (Mobile Manufacturers Forum, 2008).
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Depending on the number of cellphone users at any one time and the distance of
these users to the nearest base station, the power output from the base station is still
likely to fluctuate throughout the day.
2.2 CONCLUDING REMARKS ON THIS SECTION
In this section background information was provided to explain how cellphone
networks work and why base stations are needed at specific positions.
The following section provides the details of what MTC proposes for this specific
project.
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3 PROJECT DESCRIPTION
3.1 RATIONALE FOR THE PROPOSED PROJECT
Worldwide, mobile experiences are becoming increasingly faster. Service providers
such as MTC are not only under constant pressure to provide good quality voice and
data services to their customers but also to keep up with international standards. The
aim is therefore to provide a wider range of services from which to choose whilst
providing reasonable access to the latest technologies as they become available.
The services that MTC provides are demand-led. The constant increase in cellphone
users requires MTC to continuously expand their networks to accommodate
customer requirements of service and quality. The need for base stations is usually
concentrated in built-up areas where the greatest density of cellphone users is, and
close to main roads, where the demands on network capacity are greatest.
Accordingly, the Ludwigsdorf area currently relies primarily on coverage from three
macrocells, namely that created by the BTS at Hidas, Bowker Hill and the NBC Tower
(Figure 3-1).
Figure 3-1: Possition of macro BTS sites close to Ludwigsdorf.
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Unfortunately, due to the ever increasing number of service users in the area
(currently estimated at more than 2700 in the Ludwigsdorf area), these macro sites
are subjected to high traffic and are therefore severely congested. The undulating
landscape further causes poor coverage on the shadow side of slopes (Figure 3-2).
The reality of the problem is portrayed in the number of customer complaints
received by MTC in this area (APPENDIX B).
It is for this reason that MTC is proposing the construction of five mini BTS sites (for 3G
not 4G). These sites will provide infill coverage in areas that are not currently
covered and will provide additional capacity where congestion is experienced in a
macrocell (Figure 3-2). This will not only result in improved services for MTCs
customers, but will also provide:
Additional capacity.
Improvement of existing coverage.
Resolution of customer complaints.
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Figure 3-2: The current coverage in the area provided by the existing macro BTS sites (A) will be improved by the construction of the proposed five mini BTS sites (B). Red circles indicate the grouped locations from where the customer complaints were lodged.
A B
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3.2 PROPOSED LOCALITY
Based on technical investigations MTC identified optimal sites that are motivated by
quality, coverage and statistical analysis. These investigations were focused
specifically on addressing the issues of dropped calls and problematic coverage
experienced in the area. MTC wishes to fill this telecommunication gap by providing
the most optimal and complete network coverage in the area through the proposed
sites.
However, when selecting the most appropriate site for the construction of a base
station, it is not only the existing network infrastructure that determines the
positioning, but also the following:
Surrounding topography and built-up environment
Established and future urban area
The required footprint, and
The design of the facility.
By considering the above criteria, MTC has decided upon the five locations in
Ludwigsdorf as illustrated in Figure 3-3 below.
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Figure 3-3: Location of the five proposed mini Base Station sites
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The description of each of these sites is provided in Table 3-1 below:
SITE NAME COORDINATES DESCRIPTION OF SITE PURPOSE
Mission Road S22.57090
E17.11310
On the western side of
Mission Road
To provide coverage in
the area not currently
covered by NBC and the
Cone Towers.
Gloudina Road S22.56870
E17.11880
On the corner of
Gloudina and Babs
street, next to the
power transformer
building yard.
To provide coverage in
the area not currently
covered by NBC and the
Cone Towers.
Kwame Road S22.56520
E17.11310
On the southern side of
Kwame Street
To provide coverage in
the area not currently
covered by NBC and the
Cone Towers.
Hebenstreit S22.56820
E17.10950
On the corner of
Hebenstreit and
Willemien Street
To cover the area not
covered by the NBC and
Cone towers, as well as to
serve the commercial
establishment across the
road and the Chinese
embassy.
Reuning S22.56650
E17.10480
Outside the Lutheran
church yard on
Reuning Street
To cover the area not
covered by the NBC and
Cone towers, as this area
is situated in a depression
behind the mountains on
which the above
mentioned towers are
built, thus prohibiting
signal propagation.
Table 3-1: Description of the five proposed sites.
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3.3 THE ALTERNATIVES
3.3.1 TOWER SHARING
In terms of the Communications Act of 2009, service providers are required to first
consider sharing existing infrastructure in the area, before constructing new
structures. Neither Leo nor Telecom has structures in the area that could possibly be
shared. Buildings were considered but will not serve the specific needs of the
customers and MTC.
3.3.2 ALTERNATIVE SITE LOCATIONS
The siting of a potential BTS site is affected by surrounding obstructions e.g. hills,
buildings and trees, as well as the curvature of the earth and differing atmospheric
conditions. MTC did investigate all possible options when determining the proposed
locations but two major limitations were encountered. Firstly, the problem area is
located in a residential zone which limits the available space to construct the base
stations in relation to the specific coverage needs. Secondly, the undulating
topography creates “dead zones” on the shadow side of slopes. This inhibits optimal
coverage in the area. The proposed mini sites have a small and specific coverage
area and have thus specific locations from where optimal coverage will be
achieved. The sites could be moved a couple of meters if needed.
3.3.3 ALTERNATIVE TECHNOLOGY
To determine the best technology for the specific project it is important to
understand the options that are available and what the limitations and advantages
of each are:
Mini vs. Macro BTS sites
A Base Transceiver Station (BTS) refers to the electronic equipment that facilitates
wireless communication between the user and the network. It consists of a number
of components including a transceiver and amplifier. Mini/macro refers to the size of
the container in which this equipment is stored as well as the coverage area it
provides.
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Figure 3-4: Example of a mini
BTS in Windhoek.
The number and size of the equipment stored on a macro site is much more than
that of a micro site. Because of the heat emitted from the equipment air
conditioners are required to cool it down. Macro sites provide more options for
expanding the coverage capacity but due to the size of the equipment it requires a
larger footprint area and is often visually obtrusive. The antennae should also be
located higher from the ground than what is required for the mini BTS. This means
that macro BTS are usually either constructed on elevated ground (increasing the
visual impact) or on structures of more than 15 m high (increasing the visual impact
and the risk of civil aviation interference).
Mini BTS, on the other hand, are usually confined to
compact containers with a footprint area of no more
than 1 or 2 meters (Figure 3-4). The BTS equipment and
the pole to which the antenna is attached are
contained in a small enclosure (with palisade fencing)
to preventing unauthorized access. The overall size of
the equipment makes it visually more acceptable than
macro BTS. These sites are however restricted in the
number of antennae or radios it can accommodate
and consequently a higher concentration of sites is
needed to transmit the signal in the area.
Due to the longer transmission range of macro BTS another macro site in the project
area could cause interference with the existing macro sites (i.e. NBC, Cone, Hidas
and Bowker Hill) and thus compromise on the quality
of the signal. For this reason MTC is proposing the
construction of five
mini BTS (Figure
3-5). The localized
coverage of the
mini BTS provides
good quality
services for a small
area.
Figure 3-5: Proposed ground plan for the five mini BTS.
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Pole structure vs. other BTS structures (e.g. steel lattice, monopole)
A number of BTS structures are available that are commonly associated with macro
BTS. The heights of these vary considerably depending
on the requirements of the specific project. As soon as
the height exceeds 15 m it is standard practice to
consider the implications on Civil Aviation. Should it be
required by the Directorate of Civil Aviation, these
structures could be painted red and white to make it
more visible.
For this project, pole structures are proposed. The height
of these poles is 9 m (a 3-storey building‟s height) with the
antenna mounted on top (for all of the proposed sites)
(Figure 3-6). It resembles the poles used for lampposts
(Lampposts are also normally 6 - 9 m high) and will have
a relatively low visual impact. The structure will be
mounted to a concrete foundation and will not require any supporting cables.
The physical assembling of the tower structure and the fence as well as the
construction of the foundations will take place on site by using manual labour as far
as possible. The structure will be earthed to protect it from lightning.
Directional vs. Omni Directional Antennae
Directional Antennae are designed to focus the signal in a particular direction over
greater distances (Figure 3-7). These antennae allow for increased performance
when transmitting and receiving information and ensure reduced interference from
unwanted sources. It is often used when a signal is to be submitted over a longer
distance through a number of obstacles such as buildings.
Figure 3-7: A non-scientific depiction of the signal propagation of
Omni and Directional antennae (view from above).
9 m
1 m
Figure 3-6: Pole Structure
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1What is the UMTS 2100
frequency band?
The UMTS frequency bands
are used for the third
generation (3G)
communication networks.
The various bands are
deployed to different
regions. The 2100 band is
specifically assigned to
Africa.
Omni Directional Antennae on the other hand, are designed to provide 360 degree
coverage from one antenna instead of installing 3 panel antennas to provide the
same degree of coverage (Figure 3-7). It is used in instances where coverage is
needed in all directions from the antenna. Because of the dispersed nature of this
type of antenna, the signal is generally weaker and is therefore ideal to provide
coverage over short distances.
For this project, MTC proposes the use of Omni
Directional Antennae. These antennae provide
unidirectional cover over short distances. The specific
antenna is called Kathrein 741790 and they are
designed to operate in the UMTS 2100 frequency
band1.
The antenna is 2000 mm high and 200 mm wide with a
power output of 20 Watt and 0° electrical tilt and -5°
mechanical tilt (i.e. the antennae will be tilted slightly
towards the ground to optimize coverage).
The equipment used by MTC must adhere to the standards set by the European
Telecommunications Standards Institute (ETSI). ETSI is an independent, non-profit,
standardization organization in the telecommunications industry which endorses the
ICNIRP standards for EMF exposure (Cooper, Mann, Khalid, & Blackwell, 2004).
3.4 INFRASTRUCTURE REQUIREMENTS
In terms of infrastructure requirements, the following applies:
SITE NAME ROAD ACCESS ELECTRICITY TRANSMISSION
Mission Road Accessible from
Mission Road
Application to be
submitted to the City of
Windhoek‟s electricity
department.
Transmission – connection
between BTS and Base
Station Controller (BSC).
Transmission will be
provided by means of a
MTC microwave.
Gloudina Road Accessible from
Gloudina and Babs
street.
Kwame Road Accessible from
Kwame Road
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SITE NAME ROAD ACCESS ELECTRICITY TRANSMISSION
Hebenstreit Accessible from
Hebenstreit and
Willemien Street.
Reuning Accessible from
Reuning street.
3.5 CONCLUDING REMARKS ON THIS SECTION
In this section of the report the need for the proposed project was elaborated on
and the technical details of what is projected, including the location, the alternatives
and the design, were explained. In short, the following is proposed by MTC for this
project:
Five mini BTS sites in Ludwigsdorf,
The sites are for 3G not 4G and both data and voice services,
9 m high pole structures resembling a lamppost and an outdoor Huawei BTS
on a 1 m x 1 m footprint area enclosed with a palisade fence,
Omni directional antennae (Type Kathrein 741790) designed to operate in the
UMTS 2100 frequency band (Cagle, 2012).
The following section deals with the legal environment in which the proposed project
will be operated and specifies the relevance of the legislation to the project.
16
4 LEGAL AND REGULATORY REVIEW
The following table provides a summary of all pertinent international and national standards, guidelines, policies and laws that are
of relevance to the project. It furthermore specifies the regulatory authority and provides the contact details of a knowledgeable
person in the field:
TOPIC LEGISLATION PROVISIONS REGULATORY
AUTHORITY APPLICATION TO PROJECT CONTACT PERSON
NAMIBIAN LOCAL LEGISLATION
Erecting
telecommunication
facilities in
Windhoek
City of Windhoek:
Policy for the erection
of
Telecommunication
facilities in Windhoek
(2008)
Provides uniform, clear
standards and assessment
criteria to assist the
development, control, design,
installation, appearance and
monitoring of
telecommunication facilities
within the City of Windhoek
area
City of Windhoek Provides clear guidelines to
the specific issues that should
be investigated during the
Environmental Assessment.
These include amongst
others, the visual impact,
anticipated electromagnetic
field exposure strength and
impact on Civil Aviation.
Promotes co-location or site
sharing of operators to
maximise the use of existing
network resources.
Promotes community
consultation with the
surrounding residents.
Environmental Division:
John Shilongo
Tel: 061 290 2491
Email:
17
TOPIC LEGISLATION PROVISIONS REGULATORY
AUTHORITY APPLICATION TO PROJECT CONTACT PERSON
Use of sidewalks in
Windhoek
Local Authorities Act
23 of 1992 Section 50
(1b)
“A local authority council may
subject to such terms and
conditions….as may be
determined by the local
authority council, let or grant
the right to use temporarily, any
public place or part of a public
place or any street or portion
of a street closed in terms of
paragraph (a) to any person
for any period during the
period in which it is so closed;”
City of Windhoek MTC needs to apply to the
local authority council to
temporarily close off the site
on the sidewalk.
Environmental Division:
John Shilongo
Tel: 061 290 2491
Email:
NAMIBIAN NATIONAL LEGISLATION
Environmental
Assessment and
Management
Systems
Environmental
Management Act
(Act 7 of 2007), and
EIA Regulations
(2012):
Provides list of activities that
require an environmental
assessment, including:
“(k) The erection or
construction of communication
networks including towers,
telecommunication lines and
cables as well as structures
associated therewith including
roads”
Provides for adequate public
Ministry of Environment
and Tourism,
Directorate of
Environmental Affairs
Communication site triggers
an EIA.
Conduct public participation
as part of the EIA process
described in the act.
Dr Freddy Sikabonga
Tel: 061 284 2718
Email: [email protected]
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TOPIC LEGISLATION PROVISIONS REGULATORY
AUTHORITY APPLICATION TO PROJECT CONTACT PERSON
participation during the
environmental assessment
process for interested and
affected parties to voice their
opinions about a project.
Broadcasting Communications Bill,
2009.
Promotes the sharing of
infrastructure of the dominant
carrier with other carriers.
Provides for the regulation of
telecommunications activities.
The Bill provides for licensing
and enforcement of
conditions, and the approval
of equipment and technical
standards to ensure public
health and safety.
Communications
Regulatory Authority of
Namibia (CRAN)
Encourage the sharing of
towers to avoid cumulative
impact.
Mr Stanley Shanapinda
Tel: 061 222 666
Email:
Namibian
Communications
Commission Act, Act
4 of 1992
Provides for the establishment
of the Namibia
Communications Commission
responsible to issue
broadcasting licenses, control
or supervises certain
broadcasting activities and
program content, and among
other activities is responsible for
Namibian
Communications
Commission (NCC),
Directorate
Communications
Provides the standards for
setting up cellular, wireless
and satellite services.
Mr Henri Kassen
Tel: 061 283 2486
Email:
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TOPIC LEGISLATION PROVISIONS REGULATORY
AUTHORITY APPLICATION TO PROJECT CONTACT PERSON
the setting of specifications
and standards for new
technologies such as cellular,
wireless and satellite services.
Radiation The Atomic Energy
and Radiation
Protection Act, Act 5
of 2005:
Provides for the adequate
protection of the environment
and of people against the
harmful effects of radiation by
controlling and regulating the
production, processing,
handling, use, holding, storage,
transport and disposal of
radiation sources and
radioactive materials, and
controlling and regulating
prescribed non-ionising
radiation sources according to
the standards set out by the
ICNIRP.
Ministry of Health and
Social Services, Atomic
Energy Board of
Namibia
Used to determine the “safe
distance” around the site.
Mr Axel Tibinyane
Tel: 061 203 2416/7
Email:
a
INTERNATIONAL STANDARDS AND GUIDELINES
Non-ionizing
Radiation
“Guidelines for
Limiting Exposure to
Time-Varying Electric,
Magnetic, and
Provides international
standards and guidelines for
limiting the adverse effects of
non-ionising radiation on
The EMR levels
proposed by the
ICNIRP are endorsed
by Namibia.
Justifies the need for
assessing the impact of
electromagnetic radiation
from the towers, on the
Mr Axel Tibinyane
Tel: 061 203 2416/7
Email:
20
TOPIC LEGISLATION PROVISIONS REGULATORY
AUTHORITY APPLICATION TO PROJECT CONTACT PERSON
Electromagnetic
Fields (up to 300GHz)”
(April 1998
developed by the
International
Commission on Non-
Ionizing Radiation
Protection (ICNIRP))
human health and well-being,
and, where appropriate,
provides scientifically based
advice on non-ionising
radiation protection including
the provision of guidelines on
limiting exposure. ICNIRP
exposure limits for non-ionizing
radiation is 4.5W/m².
nearby residents. [email protected]
a
World Health
organization
Health and safety of
wireless networks – A
guide to local
authorities (Draft,
2012)
Intended to help local
authorities understand the
different types of wireless
networks and the infrastructure
they need. Furthermore, it
provides an overview of the
health and safety issues
involved with wireless networks.
Locally enforced by
the City of Windhoek.
Provides background
information to wireless
networks and research on
potential health effects and
exposure standards.
Environmental Division:
John Shilongo
Tel: 061 290 2491
Email:
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5 AFFECTED ENVIRONMENT
In this chapter the status quo of the proposed project area is provided. It provides a
description of the biophysical conditions and the social environment as well as the
current background Electromagnetic Radiation emissions.
5.1 GENERAL DESCRIPTION
The five proposed sites are located in the higher income, low density, residential area
of Ludwigsdorf. The surrounding landscape comprises of undulating hills (Figure 5-1)
and although it forms part of a built-up area, some natural vegetation remains in the
non-perennial drainage lines flowing towards the Klein Windhoek River. When
overlaying the positions of the proposed BTS sites on the topographical map of the
surrounding area, one can clearly see that these sites are located on the shadow
side of slopes. This agrees with the rationale provided in the project description
(Section 3.1).
5.2 SOCIAL ENVIRONMENT
The social environment of the project area is made up of four land uses, namely:
Residential Houses various densities
Businesses and offices
Schools
Religious institutions (e.g. churches)
The position of these in relation to the proposed sites is discussed in Table below:
The land use activities indicated on Figure 5-2 are based on the draft amendment
scheme No. 91 of the Windhoek Town Planning Scheme (2007).
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Figure 5-1: The topography of Ludwigsdorf. Note that the proposed sites are located on the shadow sides of slopes.
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Table 5-1: Description of the social environment surrounding each of the proposed sites.
SITE NAME PHOTOGRAPHIC RECORD DESCRIPTION OF SURROUNDING
SOCIAL ENVIRONMENT
Mission Road
Site is proposed at intersection
of Herbst Street and Mission
Road.
Herbst Street is a cul de sac.
Surrounding land uses:
Primarily single storey
residential houses
The site is located on slightly
higher ground than Mission
Road.
Gloudina Road
Site is proposed in front of the
Gloudina pump station facility.
Surrounding land uses:
Primarily residential
double storey houses
The ground level of most
houses is higher than at the
site.
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SITE NAME PHOTOGRAPHIC RECORD DESCRIPTION OF SURROUNDING
SOCIAL ENVIRONMENT
Kwame Road
On the corner of Kwame and
Jeanette Street.
Surrounding land uses:
Primarily residential houses
(mixture of double and
single storey houses).
The ground levels of most
houses are higher than at the
site. South of the site, houses
are either on the same ground
level or lower.
Three schools are located less
than 600 m from the site.
Hebenstreit
On the corner of Hebenstreit
and Willemien Street.
Chinese Embassy to the south
Square park – businesses to the
east
Surrounding land uses:
Primarily residential houses
(mixture of double and
single storey houses).
Houses are on the same
ground level as the site.
Reuning
Next to the boundary of the
Evangelical Lutheran Church
In Namibia (ELCIN).
Surrounding land uses:
Primarily double storey
residential houses
Houses are on the same
ground level as the site.
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Figure 5-2: Surrounding land use activities in the area, based on the Windhoek Town Planning Scheme of 2007 (as amended in draft 2012 version (No.91)).
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5.3 EXISTING BACKGROUND RADIATION
To establish what the current radiation exposure in the project area is, including the
exposure from other BTS sites such as Hidas and the NBC site1, measurements were
taken at 25 positions close to each of the proposed BTS sites.
The findings indicate that the highest value measured is 0.1483% of the ICNIRP
General Public guidelines and were obtained at position 22 (Table 5-2). This is more
than 650 times below the General Population limit. See Appendix M for the detailed
description of the assessment and the findings.
Table 5-2: Ambient RF exposure levels measured at sites in the Ludwigsdorf area in % below
ICNIRP standards.
LOCATION TOTAL EXPOSURE CELLULAR EXPOSURE
The proposed position of the Mission
Road Mini site.
0.0025% 0.0002%
On the road in front of 52 Quenta Street. 0.0141% 0.0047%
On the driveway of 24 Dr. Kwame
Nkrumbah
0.0177% 0.0090%
In front of 2 Herbst Street at the end of
the cul de sac.
0.0036% 0.0010%
At the proposed position of the Gloudina
Road Mini site.
0.0027% 0.0004%
In front of 1A Babs street. 0.0016% 0.0003%
On the driveway of the house on the
corner of Olga and Portia streets,
opposite 19 Portia Street.
0.0119% 0.0028%
On the driveway of 39 Joseph Mukwayu
Ithana Street.
0.0072% 0.0008%
1 These measurements do not include exposure from Bowker Hill which was activated after
the Radiation assessment for this study was done.
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LOCATION TOTAL EXPOSURE CELLULAR EXPOSURE
At the proposed position of the Kwame
Road Mini site.
0.0042% 0.0008%
On the corner of Dr. Kwame Nkrumah
Avenue and Jeanette Street.
0.0030% 0.0016%
In front of 73 Dr. Kwame Nkrumah
Avenue.
0.0049% 0.0029%
Opposite the proposed position of the
Kwame Road Mini site.
0.0061% 0.0013%
At the gate of 68 Dr. Kwame Nkrumah
Avenue.
0.0019% 0.0004%
At the proposed position of the
Hebenstreit site.
0.0091% 0.0047%
In front of 45 Hebenstreit Street, close to
the small gate.
0.0094% 0.0059%
In front of 38 Hebenstreit Street 0.0106% 0.0036%
In the courtyard of the Square Park
Shopping Centre, in front of the entrance
to Hugo Scheepers Architects.
0.0082% 0.0037%
At the proposed position of the Reuning
site.
0.0020% 0.0005%
Against the north-eastern corner of the
Lutheran Church building.
0.0055% 0.0019%
In front of the gate of 11 Reuning Street 0.0111% 0.0023%
On the driveway of 20 Reuning Street. 0.0103% 0.0040%
At the base of the Gevers Street Mobile
site.
0.1483% 0.1407%
Next to the entrance gate to 89 Dr.
Kwame Nkrumah Avenue Street.
0.0318% 0.0240%
Close to the Dr. Kwame Nkrumah
Avenue entrance of the Belvedere
0.0698% 0.0622%
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LOCATION TOTAL EXPOSURE CELLULAR EXPOSURE
Guesthouse.
On the disabled parking, in front of the
steps leading to the East Side Baptist
Church entrance.
0.0044% 0.0030%
In the following section the procedure followed to inform the public is elaborated on.
It provides details on the legal procedures that were needed during the EIA process,
the limitations and the findings of the communications with the public.
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6 PUBLIC CONSULTATION PROCESS
6.1 LEGAL AND POLICY REQUIREMENTS
6.1.1 ENVIRONMENTAL MANAGEMENT ACT (ACT 7 OF 2007) AND REGULATIONS
(2012)
The Act and its newly passed regulations are the key protocols governing
environmental impact assessment in Namibia. One of the key objectives of the Act is
to prevent and mitigate the significant effects of activities on the environment by:
“(b) ensuring that there are opportunities for timeous participation of interested and affected
parties throughout the assessment process; and (c) ensuring that the findings of an
assessment are taken into account before any decision is made in respect of activities.”
In order to achieve this goal Section 21 of the Regulations specifies the following:
“(2) The person conducting a public consultation process must give notice to all potential
interested and affected parties of the application which is subjected to public consultation
by -
a) fixing a notice board at a place conspicuous to the public at the boundary or on the
fence of the site where the activity to which the application relates is or is to be
undertaken;
b) giving written notice to -
i. the owners and occupiers of land adjacent to the site where the activity is or is
to be undertaken or to any alternative site;
ii. the local authority council, regional council and traditional authority, as the
case may be, in which the site or alternative site is situated;
iii. any other organ of state having jurisdiction in respect of any aspect of the
activity; and
c) advertising the application once a week for two consecutive weeks in at least two
newspapers circulated widely in Namibia.
(3) A notice, notice board or advertisement referred to in subregulation (2) must -
a) give details of the application which is subjected to public consultation; and
b) state -
i. that the application is to be submitted to the Environmental Commissioner in
terms of these regulations;
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ii. the nature and location of the activity to which the application relates;
iii. where further information on the application or activity can he obtained: and
c) the manner in which and the person to whom representations in respect of the
application may be made.
(6) When complying with this regulation, the person conducting the public consultation
process must ensure that -
a) information containing all relevant facts in respect of the application is made
available to potential interested and affected parties; and
b) consultation by potential interested and affected parties is facilitated in such a
manner that all potential interested and affected parties are provided with a
reasonable opportunity to comment on the application.
28. For the purpose of the Act and these regulations a notice is given to a person or a person
is informed of a decision, if a document to that effect is -
(a) delivered personally to that person;
(b) sent by registered post to the persons last known address;
(c) left with an adult individual apparently residing at or occupying or employed at the
person’s last known address; or
(d) in the case of a business-
(i) delivered to the public officer of the business;
(ii) left with an adult individual apparently residing at or occupying or
employed at its registered address;
(iii) sent by registered post addressed to the business or its public officer at
their last known addresses; or
(iv) transmitted by means of a facsimile transmission to the person concerned
at the registered office of the business.”
6.1.2 POLICY FOR THE ERECTION OF TELECOMMUNICATION FACILITIES IN WINDHOEK
(2008)
In terms of communicating with the public, the Windhoek BTS policy requires:
“Community consultation with the surrounding residents that are living within a 50 meters
radius of the Base Transceiver Station….”.
This requirement is superseded by the 2010 Council Resolution which states that:
“The community consultation report should present a clear representation of community
information living within a radius of 300 metre.”
The policy does not specify how the consultation process should be undertaken.
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6.1.3 BEST PRACTICE (AS DESCRIBED BY THE WORLD HEALTH ORGANIZATION)2
The WHO (2002) describes communication with the public in four stages:
1. Analysing the risk:
Information is provided to the public while the potential risk of the proposed
project is researched and analysed.
Communication with Regional and Local Authorities and other Interested
and Affected Parties (I&APs).
2. Triggering Event:
Public awareness is raised through triggering events such as media
attention, organized activist intervention and word of mouth.
3. Taking action:
Communication is established through passive engagement techniques
(e.g. fact sheets, brochures) and active engagement techniques (e.g.
public meetings).
4. Evaluation of issues:
Evaluation of outcomes, distribution of documents (e.g. minutes of
meetings conducted).
6.2 CONSULTATION PROCESS FOLLOWED DURING THE EIA
Public Participation forms an important component of the Environmental Assessment
process. Communication with stakeholders about the proposed development was
facilitated through the following means (elaborated on in Table 6-1):
Sharing of information with stakeholders:
Newspaper adverts
Written notices
Notice boards
Information documents
Stakeholder meetings
Reasonable opportunity for the public to register and comment on the project.
2 World Health Organization, 2002. Establishing a dialogue on risks from electromagnetic fields. WHO
Library Cataloguing-in-Publication Data, Switzerland.
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Table 6-1: Public consultation process followed during the EIA.
DESCRIPTION OF PROCESS TIME ALLOWED
SHARING OF INFORMATION WITH PUBLIC
Identification of
stakeholders:
Key stakeholders (See Subsection 6.3.) were identified and included in a register
(APPENDIX C). The contact details of potential I&APs were obtained from the City
of Windhoek.
The register was maintained throughout the
process.
Newspapers
adverts:
Notices were placed in the press, briefly explaining the development and its
locality, inviting the public to register as stakeholders and informing them of the
time and venue of the public meeting (APPENDIX D).
On the 5th and 12th of September 2012 in The
Namibian and Republikein.
Written Notices: People living within a 300 m radius from each of the proposed sites were
consulted. This includes more than 600 erven. The information obtained from the
CoW was refined by identifying:
Owners with more than one property,
Government owned properties (e.g. Ministry Of Works and City of
Windhoek),
Building complexes.
Only one letter was printed per owner, government institution and body
corporate.
A total of 379 people were informed, by either:
Hand delivering information letters (APPENDIX E). No letters were placed in
gates and the recipient of the letter was requested to sign for it (APPENDIX F).
For 5 days – from the 4th of September 2012
to the 8th of September 2012. Letters were
delivered from 17h00 to 19h00 in the
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DESCRIPTION OF PROCESS TIME ALLOWED
A total of 164 houses received hand delivered letters. evenings when most people were expected
to be at home.
Mailing information letters through registered post (APPENDIX G). Not all of
the identified I&APs could be reached through direct delivery. The most
recent postal addresses were therefore obtained from the CoW and mailed
through registered post (215 registered letters were sent).
Nampost (the postal service of Namibia)
stated that delivery within Windhoek takes 2
days. The letters were posted a week
before the public meeting.
Notice boards: In addition, posters (APPENDIX H) were placed close to each of the proposed sites
informing the public of the proposed project as well as the intended meeting
(Figure 6-1).
Put up on sites 3 weeks before the public
meeting.
Information
documents
A Background Information Document (BID) was compiled that contained the
information of the project (APPENDIX I). The BID was forwarded to all authorities
and registered stakeholders.
Continued throughout the process every
time someone registered.
Figure 6-1: Posters were put up at
a conspicuous place close to each of the sites.
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DESCRIPTION OF PROCESS TIME ALLOWED
Meetings: A consultation meeting was held at the Eastside Baptist Church (corner of
Hebenstreit and Dr Kwame Nkrumah Street) on the 19th of September 2012
(Figure 6-2Error! Reference source not found.). Forty-six people attended the
eeting. The audience consisted of home owners, the media, MTC representatives
and some authorities from the Ministry of Health and Social Services and CRAN.
The main concern raised during this meeting was related to the health impacts
associated with cellphone towers, the lowering of property prices and the visual
impact of the structure. The documents (i.e. minutes, attendance lists and
presentations) to this meeting are attached in APPENDIX J.
Public meeting on the 19th of September
2012. Two weeks were allowed for
registrations before the public meeting.
An authorities meeting was also scheduled to which representatives from the
various divisions of the City of Windhoek and MTC were invited. Representatives
from the Environmental and Property Divisions attended. During the meeting the
proposed project was discussed as well as the EIA process and the concerns
raised by I&APs.
Authorities meeting on the 2nd of October
2012.
Figure 6-2: Fourty-six people attended the scheduled public meeting.
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DESCRIPTION OF PROCESS TIME ALLOWED
OPPORTUNITY FOR PUBLIC TO COMMENT
The initial date for final comments was set for the 26th of September 2012, allowing
a one week comments period after the public meeting. After various requests
from the public to extend this period, the comments period was prolonged to the
3rd of October 2012. Some late registrations were received after this date, which
have also been included in the stakeholders register.
The total period allowed for comments from
the first placement of the adverts (5th of
September 2012) to the 3rd of October 2012
is 28 days. This does not include the
unofficial time allowed for after the 3rd of
October 2012.
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6.3 LIMITATIONS OF THE PUBLIC PARTICIPATION PROCESS
The process followed for the public participation was limited by a number of factors:
Delivering letters by hand is extremely time-consuming and although it ensures
that the residents do receive the information, some factors limit the effectiveness:
o People are on leave or not at home for the period Enviro Dynamics was
contacting them,
o Some houses currently don‟t have any residents,
o Some people refused to sign or receive the letters.
Addresses from CoW are out-dated and there is no way to proof that the owners
received the letters or how long it takes for them to check their mail.
Despite these limitations, the consultants are of the opinion that the various methods
of informing the public provided them with sufficient time to register as I&AP.
During the public issues and responses period, we received a notification that an
objection to the proposed project has been sent to the Directorate of Environmental
Affairs. The details of the official objection are included as part of the Issues and
Responses trail (APPENDIX K).
6.4 THE INTERESTED AND AFFECTED PARTIES (I&APS)
An I&AP can be defined as „(a) any person, group of persons or organization
interested in or affected by an activity; and (b) any organ of state that may have
jurisdiction over any aspect of the activity’ (MET, 2010).
The I&APs for this project were identified using information provided by the CoW and
the existing Enviro Dynamics stakeholder database. In addition, notices were placed
in various newspapers inviting the public to register as interested and affected
parties. Organizations were also selected whom the consultant considered to be
interested in or affected by this particular project. The results of this process are
displayed in Figure 6-3 below.
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The proposed project has received a great deal of public interest. It is therefore
important to understand not only the I&APs and the role they played during the
consultation process, but also their needs and concerns.
6.4.1 THE INDUSTRY - MTC
As service provider MTC has an obligation to their customers to provide a good
quality service. Telecommunication services are an advancing technology and
particularly the use of wireless communication services continues to develop at a
very rapid rate worldwide. Despite the technological advantages continuous
advancement pose for Namibia, it is crucial for MTC to involve the public in a
responsible way. They are therefore required to have a proactive and positive
approach to managing the risks associated with the industry.
KEY ROLE PLAYERS
Figure 6-3: Key role players identified on this project.
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6.4.2 PUBLIC
This group of I&APs includes any directly or indirectly affected member of the public.
It comprises nearby residents and neighbours (for the purpose of this EIA residents
living within a 300 m radius from the sites) as well as other individuals that do not
necessarily live close to the sites but that have an interest in the project. The most
contributions i.t.o. public concern came from this group and a total of 68 members
registered for the project. The group also contributed tremendously in terms of
sharing of information and informing others by means of e.g. word of mouth.
During the public meeting (attended primarily by members of this group), three
questions were posed and attendees were asked to provide an answer:
1. Do you experience call and data problems?
2. Do you want the status quo to continue?
3. Do you want further MTC development in principle?
As can be seen in Figure 6-4, the answers obtained from these questions indicate
two primary results3. Firstly it shows that the meeting was attended primarily by those
residents that do not currently experience problems with the network (78% of
responses) and that do not want the current situation in Ludwigsdorf to change (85%
of responses). Secondly, it shows that 61% of the attendees are completely against
any further MTC development in the area.
3 Percentages are based on the responses received and not on the number of attendees. See
APPENDIX J for responses on cards handed out during the meeting.
.
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It should however be noted that these responses are purely based on the results
obtained during the public meeting. It does not take into consideration the larger
group that did not attend.
6.4.3 SERVICE COMPLAINTS
From the information obtained from MTC‟s customer care department, 43 historical
complaints are listed for the Ludwigsdorf area. However, this number does not
reflect current complaints, which are not logged given the lack of an expanded
network in the area. Current complaints are recorded at the nearby sites such as
Bowker Hill and the NBC Cones, for those areas with poor coverage. Complaints
from the “white” areas on Figure 5-6 are not recorded at all. The nature of the
complaints is typically related to the quality of voice and data service and the slow
data speeds. Although the situation has improved slightly since the construction of
Figure 6-4: Answers obtained for the questions asked during the public meeting.
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The final EIA document (after
being circulated to the public)
will be sent to the DEA for
environmental clearance.
Should the project be
approved, the clearance
certificate and accompanying
documents will be sent to the
City of Windhoek for their final
approval.
the Bowker Hill BTS, the number of customers and the topology of the area
necessitate the construction of additional base stations in the area.
This group has not been represented well during the public consultation process but
since they contribute to the rationale for the project, they play an integral part. A list
of the service complaints is attached as APPENDIX B.
6.4.4 GOVERNMENT
This group forms the regulators that not only devise the standards and guidelines but
also approves or rejects a particular project. The group is divided into two
subcategories namely a) the regulators and b) the national and local authorities
(Table 6-2).
Regulators: CRAN (Communications Regulatory Authority of Namibia) is the official
regulator of the Namibian communications, broadcasting and postal services sector.
They are also the body responsible for the
authorizing spectrum frequencies. During the
consultation process, CRAN was informed of the
proposed project (a BID was sent to them) and
they attended the public meeting. All draft
documents will also be sent to them for comments.
National and Local Authorities: A number of
National and Local Authorities have been
identified on this project. They, too, play an
important role in the decision making process.
Information has been sent to them and a meeting was held with the City of Windhoek to
inform them of the project. A representative from the Ministry of Health and Social
Services also attended the public meeting.
ITEM LEVEL DESCRIPTION
STA
KEH
OLD
ER
DA
TAB
ASE
NA
TIO
NA
L
AU
THO
RIT
IES Ministry of Environment and Tourism
Ministry of Works and Transport
Ministry of Health and Social Services
Ministry of Regional and Local Government and Housing
Table 6-2: Authorities involved in this project.
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ITEM LEVEL DESCRIPTION
Ministry of Information and Communication Technology
REG
ION
AL
AN
D
LOC
AL
AU
THO
RIT
IES
Erongo Regional Council
City of Windhoek
6.4.5 PUBLIC INTEREST GROUPS
Throughout the project Radiation Awareness Namibia has been actively involved in
the public consultation process. They aided in informing the public about the project
and requesting them to register and comment.
6.4.6 MEDIA
Due to the contentiousness of base stations in residential areas and the known history
between MTC and residents of Ludwigsdorf, the project has received broad media
coverage. An article was placed in the Algemeine Zeitung on the 24th of September
2012 covering discussions that took place at the public meeting on the 19th of
September 2012. In addition, reporters from both NBC (National Broadcasting
Corporation) and TV One reported at the public meeting.
6.4.7 ELECTROMAGNETIC FIELD (EMF) SPECIALIST
Enviro Dynamics appointed an independent electromagnetic radiation specialist
(SATCOM) to do a radiation assessment prior to the public meeting. SATCOM in
addition subcontracted a specialist from EMSS in South Africa.
EMSS Consulting (EMSS) has expertise in the field of human exposure assessment to
radio-frequency fields. Work performed includes site surveys, numerical predictions
(computer simulations) and the interpretation and establishment of guidelines for
limiting exposure. For more than a decade EMSS has focused its efforts in this area
on the assessment of human exposure to cellphone technologies. These include
measurements and numerical predictions of exposure to cellphones and base
station antennas. EMSS publishes its research results in international peer-reviewed
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literature and has written numerous technical reports on base station site surveys
performed on request from cellular operators and/or members of the public.
For this EIA, the specialist was required to provide the following scientific information:
Background to electromagnetic radiation;
Current research;
Limitations in the research;
Current and future radiation expected from the proposed project;
Compliance with international standards and guidelines.
The results of their research were presented at the public meeting.
6.5 OUTCOME OF THE PUBLIC PARTICIPATION PROCESS
The main conclusion that can be drawn from the public participation process is that
there is a high degree of distrust amongst the public particularly in terms of official
views and the sources of information. Possible reasons for this are highlighted below:
6.5.1 HISTORY BETWEEN MTC AND LUDWIGSDORF
Although the Bowker Hill project has a limited bearing on the current project, the
reaction of the public to the proposed project is based on their perceptions and
evaluations of the risk.
In 2010, MTC proposed the construction of a BTS on Bowker Hill. This was apposed by
several of the neighbouring residents. The main concerns were centred around
a) the environmental impacts on Bowker Hill and b) the health concerns. Following a
case filed with the High Court and a subsequent law suit, the public stated that MTC
and the City of Windhoek continued to ignore their objections and that their
concerns were not heard.
“Strategies included repeated last-minute timing of notices to residents, preventing
residents from being properly heard by the decision-makers, (the City Council of
Windhoek), and misrepresentations in the media and in Agendas, all recorded in
detail in Affidavits for legal proceedings and in submissions to the Ombudsman.”
(Bowker Hill Conservation Group, 2012)
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Hazard – Object or set of
circumstances that can
potentially harm a
person‟s health.
Risk – The likelihood or
probability that a person
will be harmed by a
particular hazard.
The public‟s previous experience with the Bowker Hill project is just one of the factors
that influence their risk perception.
6.5.2 PERCEIVED RISKS VS. PERCEIVED BENEFITS
Technological progress has always been associated with hazards and risks both
perceived and real. Every activity that we undertake has an associated risk. This risk
can be lowered by avoiding certain activities but it can never be abolished
completely. Driving a car is a potential health hazard. Driving a car fast presents a
risk. The higher the speed, the more risk is associated with the driving (World Health
Organization, 2002).
Individuals perceive a risk as:
Negligible
Acceptable
Tolerable or
Unacceptable.
Whether a risk is found to be acceptable or not
has a lot to do with the individual‟s ability to
control the hazard. If the person feels that they do not have a say or are unable to
control the outcome despite of what they say, they will perceive the risk as high. This
risk will increase where they feel that their exposure to the risk is involuntary as
apposed to voluntary exposure.
Direct versus indirect benefits of the project is another factor that influences the
person‟s risk perception. The proposed project in this instance will improve both data
and voice services in the area. If a person e.g. does not own a cellphone or
computer they will not benefit directly from the project and will therefore perceive
the risk as high.
For this project the following ratings apply in terms of perceived risk vs. perceived
benefits.
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These figures indicate, that:
Either the public does not have enough information on the radiation topic to
lower their risk perception, or
the potential benefits of the project are not well defined, or
there is a real risk.
6.6 THE KEY ISSUES
Before one can assess the potential impacts associated with this project, it is
necessary to define the key issues that came from the public participation process.
From the comments submitted to Enviro Dynamics, a number of key issues were
identified. These issues have been grouped according to theme to clearly distinguish
the main issues of concern (
Table 6-3). The complete list of issues and responses can be viewed in APPENDIX K.
Table 6-3: Main issues of concern.
THEME ISSUE NUMBER OF
CONCERNS
HEALTH
CONCERNS
Impact on children
Long term effects of non-heating continuous pulsing
BTS in a residential area
Possible carcinogen
Possible upgrade to 4G and the health effects.
21
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THEME ISSUE NUMBER OF
CONCERNS
Involuntary, uncontrolled, continuous exposure
Lack of policy in Namibia to protect against radiation
Cumulative impact with x-ray equipment
Cumulative impact with other BTS e.g. Bowker Hill
First floor radiation exposure
Health effects on already ill individuals
EIA PROCESS Poor communication with the public and insufficient
time allowed for communication.
ENVIRONMENTAL
IMPACTS
Disappearance of bees 1
PROPERTY VALUE Reduction in property value
Visual impact/aesthetics
2
LOCATION Potential entry point for crime 1
6.7 CONCLUDING REMARKS ON THIS SECTION
This section of the report focuses on the need and desirability of the proposed
project. The need for better cell-phone coverage is represented by the MTC
customers who complained about poor service in the area. The opposition to the
project, on the other hand, is represented by those who objected against it during
the EIA process.
It is important to understand that approval for an EIA is not based on which of these
groups has the highest number of support. Whether the need of the project can be
confirmed and justified, and whether the issues raised can be sufficiently addressed
determines the outcome of the process.
Considering the locations from where the complaints were received (both for and
against the project), groupings can be formed around the proposed BTS sites of their
locality (Figure 6-5). These groupings show the distribution of the complaints.
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The following conclusions can be drawn from the groupings:
The existing coverage4 in the project area is lower than that of neighbouring
areas (e.g. west of Reuning street);
Considering the existing coverage, the areas with poor coverage or
congestion correlates with the grouping of service complaints;
The project opposition is grouped around the proposed BTS sites and therefore
constitutes site specific concerns and not community level concerns.
The issues highlighted in this section of the report are collated in Section 7 where the
potential impacts related to the sensitivities are further assessed.
4 Coverage is not the only factor that determines the quality of the service. White areas
indicated on the map does not necessarily imply the absence of coverage. MTC‟s service
might still be available in these area but due to the distance from the nearest BTS and the
topography, strain may be placed on the existing BTS consequently lowering the quality of
the service.
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Figure 6-5: Overlay of the groupings of people that complained about the service vs. people that oppose the project.
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7 IMPACT ASSESSMENT
7.1 METHODOLOGY EMPLOYED FOR THE IMPACT ASSESSMENT
In order to define the key potential impacts associated with the project, the
information obtained from Sections 3 to Section 6 is subjected to the following
criteria.
Table 7-1: Definition of each of the criteria used to determine the significance of the impacts
CRITERIA DESCRIPTION
Nature Reviews the type of effect that the proposed activity will have on the
relevant component of the environment and includes “what will be affected
and how?”
Extent Indicates whether the impact will be site specific; local (limited to within 15
km of the area); regional (limited to ~100 km radius); national (limited to the
coastline of Namibia); or international (extending beyond Namibia‟s borders).
Duration Reviews the lifetime of the impact, as being short (days, <1 month), medium
(months, <1 year), long (years, <10 years), or permanent (generations, or >10
years).
Intensity Establishes whether the magnitude of the impact is destructive or innocuous
and whether or not it exceeds set standards, and is described as none (no
impact); low (where natural/ social environmental functions and processes
are negligibly affected); medium (where the environment continues to
function but in a noticeably modified manner); or high (where environmental
functions and processes are altered such that they temporarily or
permanently cease and/or exceed legal standards/requirements).
Probability Considers the likelihood of the impact occurring and is described as
improbable (low likelihood), probable (distinct possibility), highly probable
(most likely) or definite (impact will occur regardless of prevention measures).
Degree of Confidence
in Predictions
Is based on the availability of specialist knowledge and other information.
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The application of the above criteria to determine the significance of potential
impacts uses a balanced combination of duration, extent, and intensity/magnitude,
modified by probability, cumulative effects, and confidence. Significance is
described as follows:
SIGNIFICANCE RATING CRITERIA
Low Where the impact will have a negligible influence on the environment
and no modifications or mitigations are necessary for the given
development description. This would be allocated to impacts of any
severity/ magnitude, if at a local scale/ extent and of temporary
duration/time.
Medium Where the impact could have an influence on the environment, which will
require modification of the development design and/or alternative
mitigation. This would be allocated to impacts of moderate
severity/magnitude, locally to regionally, and in the short term.
High Where the impact could have a significant influence on the environment
and, in the event of a negative impact the activity(ies) causing it, should
not be permitted (i.e. there could be a „no-go‟ implication for the
development, regardless of any possible mitigation). This would be
allocated to impacts of high magnitude, locally for longer than a month,
and/or of high magnitude regionally and beyond.
Table 7-2: Definitions of the various significance ratings
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7.2 IDENTIFICATION OF KEY ISSUES
To determine potentially significant impacts of a project involves pooling together all
the sensitivities derived from the baseline conditions, legal requirements as well as the
concerns raised by I&APs. This list of issues is further screened to derive at issues for
which further investigation is required, using a thought process explained in
Figure 7-1.
Table 7-3 below shows all the potential impacts identified for this project, with the
above process applied.
Does the issue fall within the scope of the project and the
responsibility of MTC?
Figure 7-1: Screening process to determine key issues
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Table 7-3: Identification of key impacts.
7.3 ECONOMIC IMPLICATIONS
7.3.1 BACKGROUND TO THE NEED FOR THE PROJECT
MTC is currently experiencing problems with congestion and coverage in the
Ludwigsdorf area. This is brought about by the high number of service users in the
area causing the existing BTS structures on Bowker Hill and Hidas Centre to become
congested. Another factor that influences the coverage in the area is the
surrounding topography. The undulating landscape causes areas with poor
coverage on the shadow side of slopes. The mini BTS sites proposed by MTC will
provide specific coverage in these areas, thereby improving the service.
IMPACT/ISSUE MTC
RESPONSIBILITY
YES/NO
SUFFICIENT
INFO
YES/NO
MITIGATION
AVAILABLE
YES/NO
FURTHER
WORK TO BE
CONDUCTED
ADDRESSED
IN:
Economic
implications
Yes Yes Yes No Subsection
7.3.
Disappearance
of bees
Yes No No Yes Subsection
7.4.
Reduction in
property value
Yes No No Yes Subsection
7.5.
Potential entry
point for crime
Yes Yes Yes No Addressed
in the EMP
Perceived
health risks
associated with
radiation from
BTS structures.
Yes No Yes Yes Subsection
7.6.
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7.3.2 POTENTIAL EFFECTS OF THE PROJECT
By implementing the project, MTC will improve the service they current provide in the
Ludwigsdorf area. This will be achieved by:
Improving the speed of data connections,
Improving the quality of voice calls
7.3.3 SIGNIFICANCE
By implementing the proposed project, the significance for MTC can be summarized
as follow:
Table 7-4: Expected significance of the economic implications
CRITERIA DISTURBANCE OF ECOSYSTEMS
Extent Local
Duration Permanent
Intensity/
Magnitude
High
Probability Definite
Significance Before
Mitigation
High positive
Significance After
Mitigation
High positive
Degree of Confidence in
Predictions
High
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7.4 DISAPPEARANCE OF BEES
7.4.1 BACKGROUND TO THE PROBLEM
Since 2007, scientists have researched the causes for the rapid collapse in honey
bee colonies. This rapid collapse poses significant environmental and economical
impacts, due to the pollination role bees play in plant communities and agricultural
crops. The phenomenon, although not uncommon in apiculture, has recently been
labelled Colony Collapse Disorder (CCD), following a drastic collapse in honey bee
colonies in North America in 2006. Several causes for this collapse have been
proposed, including:
Biotic factors such mites and pathogens,
Malnutrition,
Pesticides,
Genetically modified crops,
Pest control methods,
Electromagnetic Radiation from cellphones and base stations, and
A combination of all of the above and not single factors.
7.4.2 POTENTIAL EFFECTS FROM ELECTROMAGNETIC RADIATION (EMR)
Some studies done (Pttazhy, 2012; Sainudee, 2011) state that the EMR produced by
base stations and cellphones are causing an interference with the navigational skills
of bees, preventing them to return to hives.
Another study done by the CCD Steering Committee (2009) lent credence to the
hypothesis that CCD may be a syndrome caused by many different factors, working
in combination or synergistically. These findings were supported by a study that
tested 61 quantified variables (including adult bee physiology, pathogen loads, and
pesticide levels). The results showed that no single measure emerged as a most-likely
cause of CCD (Van Engelsdorf, et al., 2009).
Favre (2011) found no direct link between the EMR emitted from base stations and
CCD. His findings support that of Steve & Khun (2004).
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Most of the studies are however in agreement that further research is needed to
establish a scientific link, if any, between the observed abnormalities and disorders in
bee hives such as Colony Collapse Disorder and EMR from base stations.
7.4.3 SIGNIFICANCE OF THE CURRENT PROJECT
The causal link between EMR and the occurrence of bees in a particular area is still a
grey area for which no clear answer is available. However, the effect is cumulative
and not restricted to a specific BTS. The following site specific (not cumulative)
significance ratings apply:
Table 7-5: Expected significance of the impact on bees
CRITERIA DISTURBANCE OF ECOSYSTEMS
Extent Local
Duration Permanent
Intensity/
Magnitude
Low
Probability Probable
Significance Before
Mitigation
Low (small contribution of the specific project)
Significance After
Mitigation
Low
Degree of Confidence in
Predictions
Medium
7.4.4 MITIGATION MEASURES
MTC should stay up to date with recent research. Should new policies or
guidelines be presented in the international community, MTC should consider it
and adapt current infrastructure accordingly.
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7.5 REDUCTION IN PROPERTY VALUE
7.5.1 BACKGROUND TO THE PROBLEM
Concerns with the effect of base stations on property values have been well
documented in similar studies worldwide (Bond, et al., 2003; Bello, 2010).
7.5.2 POTENTIAL EFFECTS ON PROPERTY VALUES
To determine the effect of the current project on neighbouring properties, two
valuators in Windhoek were contacted5.
Both valuators indicated that the presence of BTS sites close to a property does not
affect the valuation of the property. The valuator from FNB stated that, if anything, it
could increase the appeal of a property due to the better cellphone and data
reception it pose.
According to the private valuator, it is the perception of the buyers that can
influence the period a property stays in the market. Should buyers perceive the BTS
as a potential health hazard, it could result in the property staying in the market for
longer time periods, thereby forcing the selling price to be dropped.
That being said, the high demand for property in Windhoek makes the market
extremely lucrative. Both valuators stated that in their experience, the presence of a
BTS close to a property very rarely influence the physical value.
Another factor that can potentially influence the perception of buyers is the visual
impact of the BTS. An unsightly structure could reduce the appeal of the property.
7.5.3 SIGNIFICANCE OF THE CURRENT PROJECT
Based on the statements made by the valuators, the significance of the potential
impact is analysed as follows:
5 Pers. communication: Anonymous, private property valuator, 15 October 2012.
Pers. communication: Anonymous, FNB property valuator, 15 October 2012.
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Table 7-6: Expected significance of the project on property prices.
CRITERIA DISTURBANCE OF ECOSYSTEMS
Extent Local
Duration Permanent
Intensity/
Magnitude
Low
Probability Improbable
Significance Before
Mitigation
Low (due to the contribution of the specific project)
Significance After
Mitigation
Low
Degree of Confidence in
Predictions
Medium
7.5.4 MITIGATION MEASURES
The aesthetics of the surrounding area should be considered when deciding on
a final design for the BTS structure (particularly the container and palisade
fence). Landscaping to conceal it will reduce the visual impact.
MTC should ensure that the BTS sites are within the internationally prescribed
radiation emission limits endorsed by the Atomic Energy and Radiation
Protection Act, Act 5 of 2005 (i.e. ICNIRP, 2009).
The public should be informed of these limits and presented with proof of how
MTC intends to stay within these limits. Open communication channels should be
maintained whereby no information is withheld from the public
A Strategic Environmental Assessment should be undertaken by MTC where the
issue of property values and BTS sites are evaluated and the results
communicated with the public.
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7.6 EMF EXPOSURE
7.6.1 BACKGROUND TO EMF
Electromagnetic fields occur naturally on earth in the form of visible light. Our
exposure to EMF has however steadily increased with the turn of the century
following the ever advancing wireless technologies such as radio, television and
more recently cellphone technologies. EMF travels away from a source and carries
energy with it (World Health Organization, 2012).
Two types of EMF can be distinguished, namely ionizing radiation (e.g. x-rays and
gamma rays) and non-ionizing radiation. The power transmitted from base stations
places it in the Radio Frequency (RF) range. Table 7-7 below explains the different
frequencies and the effect it can have on the human body.
Table 7-7: Different types of electromagnetic radiation (adapted from (World Health Organization,
2002)
NON-IONIZING RADIATION
IONIZING
RADIATION
Frequency <100 kHz 100 kHz - 1 GHz 1 – 300 GHz 300 GHz -750 THz 750 -950 THz
Type Extremely
low
frequency
Radio frequency Microwave Visible light x-rays and
gamma rays
Non-Thermal Thermal Optical Broken Bonds
Effect Induces low
currents
Penetrate a short
distance into the
body.
Induces high
currents
Excites electrons Damages DNA
Biological
effect
Disturbance
of nerve and
muscle
responses
Heating of body
tissue, raised body
temperature
Heating of
body tissue
Photochemical
effects
Skin
pigmentation
Source Power lines Television, FM, AM,
shortwave and
base stations
Cellphones,
microwave
oven, Wi-Fi
Sunlight, fire, light
bulbs, lasers
Sunlight
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The effect of exposure to high levels of radio frequencies is known to cause
biological cell heating that can lead to tissue damage. Studies done by the WHO
has consistently shown that the radio frequencies from base stations are well below
the levels needed to cause heating and an increase in body temperature (World
Health Organization, 2002).
How the radio frequency from a base station affects a persons health is determined
by the level of exposure. This depends on the following factors:
“The distance from the antennae. Generally, exposure decreases with the
inverse square of the distance as one moves away from an antenna (in other
words, the exposure 200 m from the antenna is one quarter of the exposure
I00 m from the source).
The output power of the antenna (i.e. the strength of the emissions from the
antenna).
The direction of the main beam of the antenna. Within the main beam of the
antenna, high above the ground, the signal is far stronger than on the ground
just beneath the antenna.
Height of the antenna above ground.
Local terrain (for example, trees and building materials absorb radio signals).”
(Taken from World Health Organization, 2012)
7.6.2 POTENTIAL BIOLOGICAL AND HEALTH EFFECTS ASSOCIATED WITH EMF
Information on health effects are obtained through thorough international research.
According to the World Health Organization (2012) the information is usually based
on:
Laboratory studies – where cell cultures, animals and humans are exposed to
RF fields under defined conditions,
Epidemiological studies – where the health of different groups of people may
have different exposures due to where they live or work,
In vivo - experimentation on living organisms, and
In vitro - experimentation using a partial or dead organism to do biopsies.
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The current standing of the WHO is that “exposure to low level RF fields (such as those
emitted by mobile phones and their base stations) does not cause adverse health
effects” (WHO, 2012). According to WHO (2002) some scientists have reported minor
effects from cellphone usage, including changes in brain activity, reaction times and
sleep patterns. These are however believed to be within the normal bounds of
human variation.
Apart from the WHO, a number of governments have initiated health reviews of their
own on the topic. Many of these reviews have concluded that there is no reason to
believe that exposure to EMF at levels typically found around base station sites is
detrimental to the general public‟s health.
Examples of some of the most recent of these reviews are:
the UK Health Protection Agency, April 2012,
the Independent Expert Group report on Electromagnetic Fields (Swedish
Radiation Safety Authority), December 2010,
the joint statement by the Nordic Radiation Safety Authorities on Exposure of the
General Public to Radiofrequency Electromagnetic Fields, November 2009,
the European Commission‟s 2009 SCENIHR: Health Effects of Exposure to EMF
report, January 2009 and
the Health Council of the Netherlands review on Electromagnetic Fields,
updated in March 2009.
SCIENTIFIC UNCERTAINTIES
Science is not error free. Some limitations do exist, including:
“Scientific evaluations of biological responses from environmental exposures rarely lead to
unanimous conclusions.
Epidemiological studies are prone to bias.
Extrapolation from animal studies to humans is often questionable.
“Weight of evidence” determines the degree to which available results support or refute a
given hypothesis.
No single study can provide a definite answer.
Public interprets uncertainties in scientific knowledge on EMF health effects as declarations
of the existence of real risks. “
Taken from World Health Organization (2002)
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GROUP 2B: THE AGENT IS POSSIBLY CARCINOGENIC TO HUMANS.
“This category is used for agents for which there is limited evidence of carcinogenicity in
humans and less than sufficient evidence of carcinogenicity in experimental animals. It
may also be used when there is inadequate evidence of carcinogenicity in humans but
there is sufficient evidence of carcinogenicity in experimental animals. In some instances,
an agent for which there is inadequate evidence of carcinogenicity in humans and less
than sufficient evidence of carcinogenicity in experimental animals together with
supporting evidence from mechanistic and other relevant data may be placed in this
group. An agent may be classified in this category solely on the basis of strong evidence
from mechanistic and other relevant data.”
Taken from International Agency for Research on Cancer (IARC), 2006
The current health debate regarding base stations and human health are however
centred on whether long-term, low level exposure can cause adverse health effects
or influence people‟s well being (also indicated in Radiation Awareness Namibia‟s
Memorandum of concerns, 19 September 2012).
The concerns associated with Extreme Low Frequency (ELF) magnetic fields are often
based on the findings of the 2002 report of the International Agency for Research on
Cancer (IARC). In the report (IARC, 2002), the following conclusions are drawn:
“There is limited evidence in humans for the carcinogenicity of extremely
low-frequency magnetic fields in relation to childhood leukaemia.
There is inadequate evidence in humans for the carcinogenicity of
extremely low-frequency magnetic fields in relation to all other cancers.
There is inadequate evidence in humans for the carcinogenicity of static
electric or magnetic fields and extremely low-frequency electric fields.”
“No effect on melatonin was seen following night-time exposure of human
volunteers to 50 or 60-Hz magnetic fields under controlled laboratory
conditions. In contrast, a small reduction in melatonin concentration has
been observed in occupational and residential environments, but it is
difficult to distinguish between effects of the magnetic field and those of
other environmental factors.”
The report concluded that static and extremely low frequency electric and
magnetic fields should be classified as a Class 2B – a possible human carcinogen.
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An example of a well known agent classified in the same category is coffee, which
may increase the risk of kidney cancer.
Since the publishing of IARC report in 2002 most of the scientific research examining
long-term risks from ELF magnetic field exposure has focused on childhood
leukaemia (WHO, 2007).
In 2010, ICNIRP released guidelines for limiting exposure to time‐varying electric and
magnetic fields (1 hz – 100 khz) (ICNIRP, 2010). The report concluded that a causal
relationship between magnetic fields and childhood leukemia has not been
established nor have any other long term effects been established.
Although the epidemiological evidence for this finding is weakened by
methodological problems such as selection bias, the technology is simply too recent
to completely rule out possible long term effects (WHO, 2007).
7.6.3 EMF EXPOSURE GUIDELINES AND POLICIES
Although countries normally set their own national standards for exposure to EMF,
most of these standards are based on the guidelines set by the International
Commission on Non-Ionizing Radiation (ICNIRP). The organization is formally
recognized by the WHO and its primary objective is to evaluate scientific research
and provide guidelines recommending the limits of exposure. The research done by
ICNIRP are reviewed periodically and updated as necessary – the validity of the
recommendations was reaffirmed in 2009 following a review (ICNIRP, 2009).
The exposure limits recommended by ICNIRP:
1. Covers the non-ionizing radiation frequency range between 0 and 300 GHz,
2. Are based on all published, peer reviewed literature, and
3. Are related to short term exposure.
The reason for the latter is based on the fact that the available scientific information
on the long term exposure to EMF fields is considered to be insufficient to establish
quantitative limits (WHO, 2002).
The international guidelines proposed by ICNIRP consider the threshold level that
could potentially lead to biological effects. The lowest threshold level is then further
reduced to allow for uncertainties in the science and set limit values fro human
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exposure. According to WHO (2002) ICNIRP uses a reduction factor of 10 to derive at
occupational limits for workers and a factor of about 50 to arrive at exposure limits for
the public. This factor serves as a precautionary buffer to compensate for
uncertainties in the research.
7.6.4 COMPLIANCE OF THE PROPOSED PROJECT WITH EXPOSURE LIMITS
The five proposed sites have been subjected to an electromagnetic radiation
exposure study to ascertain if the radiation outputs are in line with those permitted by
the ICNIRP guidelines or not. SAT-COM and EMSS Consulting were commissioned for
this, because of their combined expertise in the field of human exposure assessment
to RF fields. The complete report of their findings can be viewed in APPENDIX L.
Measurements were performed at and around the locations of the five planned and
one mobile base station sites of MTC in the Ludwigsdorf area. The aim of the survey
was to measure the ambient electromagnetic exposure, the expected exposure
levels at various positions around these sites and then to compare the results to the
ICNIRP standards (Sat-Com, 2012).
From the findings of the assessments done by SAT-COM on the five sites, it was clearly
indicated that RF field measurement results were below the ICNIRP guideline values.
Many authorities base their limits on the guidelines published by ICNIRP.
The results obtained show that:
The maximum expected RF exposure anywhere at 1.5 m above ground level
around all the proposed sites is at least 2300 times below the general public
guidelines of limiting exposure proposed by ICNIRP (Table 7-8).
The maximum expected RF exposure at 1.5 m above the level of expected
maximum exposure of a multiple storey building near the Gloudina Road Mini
base station is at least 450 times below the ICNIRP general public guidelines.
According to the numerical EMF exposure assessment performed by Sat-Com
and EMSS, the site is classified as Provisionally Compliant and will be Compliant
with the ICNIRP Guidelines if the equipment is installed as specified in the
planned documentation.
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7.6.5 SIGNIFICANCE OF THE CURRENT PROJECT
To put a potential significance value on the public‟s perceived risk posed by EMF
radiation is impossible to determine. However, ICNIRP is the accepted standard for
EMF radiation measurement and is considered a conservative tool in the radiation
impact assessment regime worldwide. The significance rating is therefore based on
the specialist‟s assessment which used ICNIRP as its basis.
Table 7-9: Expected significance of EMF exposure from the five proposed sites.6
CRITERIA DISTURBANCE OF ECOSYSTEMS
Extent Local
Duration Permanent but varies in intensity
Intensity/
Magnitude
Low
Probability Probable
Significance Before
Mitigation
Low
Significance After
Mitigation
Low
Degree of Confidence in
Predictions
High
6 This assessment does not take into account long term exposure.
Table 7-8: Predicted maximum exposure summary at 1.5m above ground level.
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7.6.6 MITIGATION MEASURES
Should MTC in future intend to change the radiation outputs from these sites by
upgrading to e.g. 4G or any other technology that could change the current
radiation conditions, a new radiation assessment (followed by extensive public
review) will be required.
An infrastructure related communications plan should be put in place by MTC.
As a minimum requirement, this plan should encompass and provide for:
A comprehensive information campaign whereby the public is informed of
unbiased progress in EMF radiation and public health research.
Communication from the public where they can raise their concerns and
provide input in future projects.
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8 CONCLUSIONS AND RECOMMENDATIONS
8.1 THE EIA AND PUBLIC CONSULTATION PROCESS
The process followed in this report was aimed at providing the public reasonable
access to unbiased information. The objective in this instance was to discern what
type of information was needed from the public whilst clarifying the technical
aspects of the project. Despite this, the EIA and particularly the public consultation
process were conducted under conditions of extreme distrust and cynicism from the
public.
It is our opinion that the EIA process followed for this project complied with the
regulations provided by the Local and National Authorities.
The public consultation process however had some limitations such as:
Addresses from CoW are out-dated and there is no way to prove that the owners
received the letters or how long it takes for them to check their mail.
The effectiveness of delivering letters by hand was limited by the following
factors:
o People were on leave or not at home for the period we were contacting
them,
o Some houses currently don‟t have any residents,
o Some people refused to sign or receive the letters.
These limitations do not imply that the consultation process was flawed since various
other methods were also used to reach the community including the use of notices
in the newspapers and posters on each site.
During the study, Enviro Dynamics received notification that an official objection
regarding the public participation process was lodged at the Environmental
Commissioner (Directorate of Environmental Affairs). The contents of this objection
have been dealt with in the EIA Report and Issues and Responses trail as needed.
We therefore deem the EIA and public consultation process followed as compliant
and comprehensive.
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8.2 SYNOPSIS OF THE KEY ISSUES
The issues raised by the public on this project are mostly related to the potential
health effects associated with EMF exposure in residential areas. From our review of
available literature, organizations such as WHO and ICNIRP review thousands of
studies to determine what the real risks of BTS sites in populated areas are. To say
that the findings of these studies are “conclusive” one way or another would be
premature. It is for this very reason that these organizations base their radiation
guidelines on the precautionary principle, i.e. that they include in their standards
margins which include potential health effects which have not yet been confirmed.
Summarizing the key issues raised during the project:
Economic Implications: Considering the number of complaints MTC received
from the public, the surrounding topography and existing coverage in the area
(based on coverage prediction maps) it is clear that the proposed project will
improve the quality of voice and data services in the area.
Disappearance of bees: The disappearance of large colonies of honey bees
(called Colony Collapse Disorder (CCD)) is not a new phenomenon but since
2006 research studies have included EMF as another possible cause for it.
Various studies in India found a possible causal link between the increase in
cellphones and BTS sites and CCD. Other scientists are of the opinion that CCD
has existed long before the use of cellphones and BTS sites and that the causal
link is very weak. They uphold that it is a combination of factors and not just one
single factor that is the cause. Although the disappearance of bees could have
serious implications for the environment and agricultural industry the impact of
the project on this is considered low.
Reduction in property values: International studies done on this issue have found
that there is an increasing awareness of EMR in the property market. Local
valuators however indicated that the value of a property is not affected by the
presence of base stations. It is rather the perception of the public that could
have an effect on how fast a property is sold or not. This is also affected by the
visual appeal of the BTS. However, due to the lucrative property market and the
high demand for property, both of the valuators indicated that public
perception of base stations very rarely affect property prices in Windhoek. The
impact of the project on this issue is regarded as low.
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EMF exposure: Thousands of studies have been done and are done annually to
research the concerns about the health effects of BTS sites. Although some
exceptions do exist the majority of these studies are in agreement that the
energy emitted from BTS sites is too low to cause adverse health effects. Based
on the information from the WHO, BTS sites do not pose risks for cancer. The fact
that it was recently classified by the IARC (2006) as “possibly carcinogenic to
humans” is based on research on childhood leukemia. The classification implies
that “there is limited evidence of carcinogenicity in humans and less than
sufficient evidence of carcinogenicity in experimental animals.”
This being said, there are still gaps in the research for which no clear answer is
available. This is particularly true of long-term, low level exposure. Current
guidelines provided by ICNIRP (2009) only consider the effects of short term
acute exposure. This is because the available scientific information on the long-
term low level effects of exposure to EMF fields is considered insufficient to
establish quantitative limits. The ICNIRP guidelines do however include
consideration to potential biological effects even though they have not yet
been confirmed, by including a very conservative threshold level. This level is
further reduced to allow for uncertainties in the science and set limit values for
human exposure.
The ICNIRP standards are endorsed by the larger international community, and
also by Namibia. For this reason, the study by the independent consultants
(EMSS) to determine the ambient exposure levels in Ludwigsdorf and the
expected exposures from the new sites were also based on the ICNIRP
standards. Based on the findings of EMSS the potential risk posed by the
proposed project is considered low.
8.3 RECOMMENDATIONS
Based purely on the findings listed above there is no reason why this project can not
proceed. However, there is a deeper lying concern that is related to the desirability
of the project. It seems that there is reluctance from a portion of the residents of
Ludwigsdorf who desire the status quo in the area to continue without further
intervention from MTC.
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8.3.1 CONSIDERING THE NO-PROJECT ALTERNATIVE
The rationale for this project is to a large extent based on the number of complaints
that MTC received from residents/visitors to the area that had problems with
dropped calls or slow network connection speed. Although the project received a
significant degree of public participation, this specific group of I&APs (those who
want improved service) are not well represented. The reason for this is most likely
due to the fact that they perceive the project as positive and therefore see no
reason to participate because they have no complaints or concerns regarding the
construction of the sites.
Should this project not continue the number of dropped calls and slow network
speed will continue due to the continued congestion on the existing BTS sites. The
problem could also flow over to other areas covered by the macro BTS sites due to
the pressure added from Ludwigsdorf. This will likely increase the number of
complaints. The area shown on Figure 6-5 as having poor coverage will remain that
way without the implementation of this project.
If one considers the findings of the radiation assessment7, the five new sites could
result in a 0.02% increase in the Total levels of exposure in the project area. This is
99.96% below ICNIRP standards compared to the 99.98% prior to the construction.
CURRENT TOTAL LEVEL OF EXPOSURE
(AVERAGE OF 25 SITES)
PREDICTED LEVEL OF EXPOSURE
(AVERAGE AT THE 5 SITES) INCREASE
0.02% 0.04% 0.02%
7 Presented as a percentage of the ICNIRP guidelines, where a 100% value would indicate
the safe exposure limit for the General Public.
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8.3.2 RECOMMENDATIONS
From the public participation process it is clear that there is a lack of communication
between the public and MTC. The public perceives MTC as overly profit driven whilst
not listening to their concerns and not truly involving the public in their decision
making processes.
While there certainly are limitations to the extent of consultation that can be done,
the recommendation of this EIA is that MTC undertakes a Strategic Environmental
Assessment (SEA). The aim of which should be to determine the level of service to be
provided for each area. This is to be done in close collaboration with the community
of each area, by using effective strategies for consulting affected communities. The
assessment should provide two deliverables:
The SEA should include a Community Consultation Plan: This plan will allow for
information feedback between MTC and the public. Its aim will be to show what
communication strategies work when informing the public of a proposed project
and what does not. It should also assign specific timeframes for each of these
procedures, allowing sufficient time for information sharing before commencing with
the public participation process outlined in the EMA (2007) and its regulations (2012).
The plan should also address the limitations that have been identified during this EIA
process. A community assessment poll (not just a customer services poll) should also
form part of this plan, focussed at determining the needs of the community and
acceptability of risks.
MTC should undertake an Infrastructure Related Communications Plan: This plan
should cover a comprehensive information campaign whereby the public is
informed of unbiased progress in EMF radiation and public health research. It should
also allow for communication from the public where they can raise their concerns
and provide input in future projects.
Available resources on the subject of dialogue between the community and the
service providers such as that provided in WHO (2002): Establishing a Dialogue on
risks from electromagnetic fields, should be utilized in drawing up the two plans.
Some guidelines are provided in the Environmental Management Plan
(APPENDIX M).
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8.4 FINAL RECOMMENDATION
The issues that were raised during the EIA process can be divided into either site or
project specific issues or community level issues. Although some community level
concerns were raised during the process, the EIA assessed the project specific
concerns which translate to the need and desirability of the project:
Need for the project: As illustrated in the report, the need for the project is
based on the poor coverage in the study area, which is confirmed by
complaints received by MTC on the voice and data service in the area.
Based on this need MTC aims to improve the coverage in the areas that
currently have poor coverage (indicated in Figure 6-5) to the same level as
that of the nearby Ludwigsdorf.
Desirability of the project: Based on the impacts assessed, the potential
impacts and concerns of the public have all been addressed and mitigation
to acceptable levels, and the desirability of the project is therefore confirmed.
This, however, does not negate the low level of trust which exists amongst a group of
the interested and affected parties, particularly with regard to potential health
effects caused by EMF.
The aim of the EIA was not to choose sides for or against the current health debate.
However, after researching a wide range of opinions, the environmental consultant
finds no reason to doubt the standards prescribed by ICNIRP (endorsed by the
Namibian Government).
In terms of the uncertainties related to BTS sites and human health (e.g. pulsing and
ELF), the ICNIRP standards are based on the precautionary principle. Since the
radiation assessment used scientific methods to determine the potential risk of the
proposed sites in comparison to the guidelines prescribed by ICNIRP, the
Environmental Consultant finds no reason for the proposed project not to be
approved by the Environmental Commissioner.
We do however recommend further community-wide work which aims at
determining the level of service which will be provided in future in close consultation
with the community. There also needs to be better communication to disclose the
levels of radiation emitted from all existing and future base stations not only in
Ludwigsdorf but any new sites constructed by MTC.
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