From : Shri A. M. JOSHI , ( Retired ) Wireless Adviser to the Govt. of India
A –22 , RAIL Vihar ,
Sector 30 / 31, Bijali Nagar , Chinchwad , PUNE 411 033 .
Tel .: ( 020 ) –2765 3020
E mail : email@example.com
Dt.—22nd Jan., 2010
Response from Shri A.M. JOSHI on TRAI’s Pre-consultation
on “Mobile Tower Design, Radiation and Other Issues” by the TRAI .
Ref. :- TRAI's e-mail of 12th Jan. , 2010
1. Extent of Mobile Tower Spread in the Country & their Large No.s
1.1 With the mobile subscriber base crossing 500 million and the target of 700 m , envisaged by the DoT by 2012 ; the no. towers being installed by the mobile service providers are spreading to all areas –urban , semi-urban as well as rural -- of the country. The next phase of expansion of towers will mainly be in tier II and tier III towns and areas as the service providers had established their tower infrastructure in first phase of their roll out of service in major cities and towns.
1.2 Some idea of the no.s and spread of mobile towers can be had from the following statistics gathered from recent news items :
1.2.1 GTL Infrastructure , which leases towers to Cellphone Operators , which has recently agreed to buy Aircel’s towers will have more than 50,000 towers by May 2010 from present 33,000 towers . ( Ref. Times of India : 15 –1-2010 )
1.2.2 Bharati, Vodafone Essar , Idea Cellular joined hand and spun of their towers into an Independent firm.
1.2.3 Reliance Communications have formed a separate arm , Reliance Infratel which has installed 30,000 towers in last 2 yrs and has presently 50,000 telecom towers
( Ref. R-Com Annual Report 2008-09 & T.O.I ; 19 /1/2010 )
1.2.4 Mobile Towers have emerged as a separate business as an Infrastructure and sale of equity stake of
these Infrastruture firms have generated huge funds . A Tower sale has fetched a price of Rs. 52 lakhs to
1. 75 Crore depending on its location and design.
1.2.5 Tower Infrastructure Sharing is encouraged by the D.O.T. / Govt. and is also advantageous to mobile service providers and companies providing this infrastructure . The present Tenancy Ratio i.e. no. of telecom operators per tower is 1: 2 and is expected to surge to 1: 3 by mid –2010 with new operators signing infrastructure sharing deals with tower companies. ( Ref. : -T.O.I. 19 /1/ 2010 )
1.2.6 Sharing of Towers should be encouraged as it will be beneficial to all , including general public as this will eventually lead to better design / location and will thereby lead to better protection to public from radiation hazard and other nuisance.
1.2.6 Service Providers have covered as much area as possible in the initial phase by installing / hiring
towers very rapidly in the race to grab subscribers . This has resulted in installation of 3 –5 towers , in
very close proximity at many locations in residential colonies increasing significantly health hazards
from radiations from tower antennae and other problems like fumes /noise of standby Diesel Generator
sets for tower installations to the residents in those areas . Their complaints are largely ignored due to
the financial clout and other influences used by the service providers with the local authorities. DOT norms
in this regard are largely ineffective and are only on paper.
1.2.7 The effort by the TRAI to address this issue by initiating the ( pre) Consultation Process on the range of issues connected with the Mobile Tower Installations is therefore a very welcome step. It is hoped that this will eventually lead to better regulations for tower installations to provide the common man from potential Health Hazards from Tower Antennae Radiations and other nuisance.
2 Health Hazard from Tower Antennae Radiations :
2.1 DOT Order no. 842 –998 /2008 –AS – IV /13 dt. 4th Nov. ,2008 inserting a new clause no. 43.6 A in Licence conditions stipulates that the Licensee shall conduct and provide a self –certificate annually , as per procedure prescribed by the TEC etc. for confirming to limits for Antennae ( Base Station ) Emissions for general public exposure as prescribed by International Commission on Non-Ionising Radiation Protection ( ICNIRP )
These limits indicated are :
2.1.1 In 400 –2000 MHz band :
1.375 multiplied by sq. root of frequency in MHz for EMF in Volts /meter ;
0.0037 multiplied by X sq. root of frequency in MHz for H field in Amp . / meter , Power Density in Watts per Sq. meter as frequency in MHz divided by 200.
In 2 GHz to 300 GHz band , the similar values are 61 , 0.16 and 10 resp.
2.1.2 For a common man to assess whether a tower near him is causing harmful radiation or not this is of no relevance . From the ICNIRP limits , the DOT should work out and specify easily understood , thumb rule yardsticks, giving minimum physical distance / clearance w.r.t. tower installation [ from ground and to nearby building / habitat ] which will again be primarily a function of no. of transmitters, antenna gain etc. i. e on the basis of total EIRP from a tower installation in worst scenario.
2.1.3 Even if the service provider gives to DOT , a self-certificate of limiting the radiation to ICNIRP limit, the common man may not be aware or get access to such a certificate. He may not also believe in such a certificate . Such measurement has to be done by a body / third party in which he would have a confidence.
2.2 Again on lakhs of towers in the country , how the crores of people are to be satisfied about the radiation safety limits ? For this purpose , portable radiation measurement meters should be easily available. Such measurements need to be carried out by the company , with pre-announced programme for information of nearby residents and alongwith independent technical experts in whom residents have confidence. For such an approach , retired Govt. Tech. Officers can be empanelled , help of professional bodies like the Institution of Engineers can be availed of. Like Certified Tax Planners , Govt. can create a pool of certified examiners . No Govt. organsation will have enough man-power and resources to undertake such measurements on such a gigantic scale and novel ways of involving various competent persons and bodies outside the Govt. will have to be devised if the public at large is to be kept satisfied, on a continuing basis , about the health safety from radiations from towers as this cannot be a one hop exercise due to the fact more and more transmitters will get added in the installations.
2.3 There should a proper display of such certificates , easily accessible /visible like the fitness certificates of Lifts /Elevators installed in a tall building .
2. 4 Electromagnetic Radiation ( EMR ) survey in the Pune city was carried out by using a portable meter and published in Sept. 1 , 2008 issue of Pune Mirror of the times of India. It showed alarming levels of EMR at most locations in Pune City. Similar results were also reported in Mumbai Mirror for Mumbai City. There was no official response to these articles by the DOT . Similar reports might have been emanated from other parts of the country .
Complaints of increasing health problems with possible linkage to Mobile Tower installations nearby have been reported in newspapers by residents of cities like Mumbai ,Pune , Latur etc.
2.5 The layout of residential areas in our cities and towns is too dense and crowded as compared to American and Western European cities / suburbs and cities . Hence, FCC and Western standards of radiation limits have to be modified. It would be better to follow / examine the limits adopted by countries like China / Japan / Thailand etc. in Asia pacific region. Our population is more in danger due to lack of general technical awareness and congested residential localities where presently towers have proliferated.
2.6 Even if radiation limits are specified / observed by a tower , the compounding effect of all nearby towers need to be evaluated. In many residential areas of Pune city, where I stay , I observe that there are usually 3-4 four towers in close vicinity [ due to the need for better coverage of the area ] . Houses located in the central portion the area formed by these towers will be worst sufferers from radiation hazard. Actual measurement is the solution in such a case.
2.7 What happens if radiation limits are exceeded and are detected either immediately or later on ? The service providers cite tenancy / lease agreement for a period of “ X “ years already executed with building owner and refuse to close / vacate the tower . The affected party can hardly do any thing but to suffer. Any civil suit will take years to decide .
2.8 With lure of high rent received for the tower installation, many bunglow owners / copoperative housing societies permit construction of such towers. In such a situation, the nearby bunglows /society residents are exposed to radiation without their consent. Even in the same society , in view of a majority decision for approval of tower installation, upper floor residents who are more vulnerable to radiations & even though they are in opposition for such an installation get overruled by majority . In such cases approval of all residents must be mandatory and this would warrant amendments to Co-operative Housing Socities Acts /Bye-Laws as well as Building Bye-Laws of local Authorities who give permissions for tower installations.
2.9 Reconsideration of ICNIRP Guidelines :
2.9.1 The ICNIRP Guidelines mentioned in para 2.1 above need to be carefully reconsidered and vetted. The DOT ( WPC ) letter no. K-19012 /1 / RTI /2009 – CFA dt .18th May ,2009 in its para 3 , thereof ; cites that as per studies of WHO as well as DG , Indian Council of Medical Research no adverse effects on health due to mobile telephone networks have been proven so far.
2.9.2 The ICMR reached the above conclusion in just one meeting held in 2006. There were no wireless experts in that committee. No public representative was also included . It also cited stringent than ICNIRP standards adopted by China compared to Western Developed world. It also called for periodic review of standards adopted. It also mentioned that the height of Mobile Base station antenna is nominally 36 meters . This is not practically true for many installations in cities . Near by bulidings are too close to antenna for any comfort or allaying fears of higher exposure levels. Our mobile network has developed by leaps and bounds since 2006 and lot of new data is now available, globally. European Parliament has passed in Sept. , 2008 a Resolution calling for improvement in ICNIRP guidelines as these have become obsolete. The 1998 Report of the ICNIRP states that the limits indicated were for SHORT Term exposure . The ICNIRP limits therefore leave room for doubt as regards their applicabilty , to continuous , round the clock exposure from mobile tower radiations.
[ There is also a need to carry out study in the Indian conditions , however this is a long drawn process of many years to reach any definitive conclusion and should be independent of the TRAI Consultation process ]
2.9.3 To facilitate proper re-consideration of this most important aspect of Mobile Tower installation affecting millions of Indian population , the TRAI should in its Consultation Paper provide :
---a ) A summary of medical studies carried out in various countries incl. India , if any , and their conclusions
--b ) A summary of standards limits adopted by other countries and related rules , on site verification / measurement procedures etc.
2.9.4 TRAI , by Newspaper advertisements , also invite reactions / views of the public at large if they suspect occurrence of health problems due to tower installations in their vicinity .
3 . General Problems of Tower Installations :
3.1 Other common problem faced by nearby residents is the nuisance from high audio noise and smoke / oil fumes from Diesel Generators provided as back up for such tower installations in the event of power supply failures. These are for long hours in not only in rural areas but even in cities and towns. These nearby residents [ who are also exposed to high levels of radiation due to close proximity of tower antennae ] have even no say in permitting tower installations. Such complaints are lodged to local Police authorities / Local Bodies and in the absence of any uniform standard / guidelines ; the solutions tend to be arbritary and based on extraneous considerations.
3.2 Adequate norms for sound level and smoke levels have to be specified and also measured and implemented like those for radiation levels.
3.2.1 In this context it is recalled that recently , Mr. Jairam Ramesh, Minister for Environment announced setting up of audio noise measurement centers in 260 cities in the country in some other context of general health concern of protecting the citizens from high audio noise levels in cities.
4. Tower Installations : Central and State Govt. Have to Frame Proper Rules.
While the Radiation and other Technical Parameters of the Tower Installations will come under the jurisdiction of the Central Govt. ; issues like giving permission from building installation , structural safety , levels of Generator Noise and Control of Smoke / Fume levels etc. , clearance of nearby residents, housing society members etc. will fall under the State Govt.s and Local Authorities / Bodies.
4.1 In view of the latter aspect , the TRAI Consultation should be more wide-spread involving Urban Development Authorities, Federation of Co-operative Housing Socities etc. and the TRAI should make a pro-active effort to approach them , in this regard as these bodies are generally not aware of TRAI’s technical consultation process which largely deals with telecom related issues. Involving such non-telecom agencies in consultation process is a must as the Cellular Operators Association of India ( COAI ) , who is a strong professional body and fully conversant with the TRAI process will be able to protect the interests of service providers.
4.2 Tower Infrastructure Companies also need to be consulted and associated to get their suggestions with a view to evolve , if possible , model or standard guidelines [ incl. Those for levy of charges for installations , rent etc. for the benefit of large no. of local civil / local authorities who are involved in giving NOC to Tower Installations. Similar approach may also help for R.O.W. procedures. Presently, they levy various charges arbitrarily . At least within a State , there should be some uniformity in the charges levied by local authorities.
4.3 Maharashtra State Development Control Regulations permit 20 sq. m area per building
as free of FSI for DOT’s licenced Service Provider to install equipment cabin etc. This
may be recommended to others also.
4.4 Town Planning Considerations :
When new large residential colonies / commercial areas are planned , the planners should earmark , separate clear area for mobile tower installations [ preferably, a central tall tower to cover the whole area ] so that exposure to radiation is minimized and better service is provided . The exisiting Cantonments , controlled by Defence Authorities and Govt. colonies are also getting poor service due to difficulties encountered by service providers to have Towers in such areas.
5. Conclusion : Mobile Telephone Service has become an essential part of modern life , even to a common man. However, due to large no. of towers , installed in many residential areas; the health hazard due to exposure to radiation on H 24 basis , by base station antennae is a major concern of the citizens. In the absence of proper implementation and verification mechanism on the part of the Central Govt. , in this regard; their fears on this aspect are not removed . For general health and welfare aspect of the citizens , urgent steps are called for in this direction and the TRAI Consultation should provide necessary guidance and recommendations for action by the Central and State Govt.s
I hope that the inputs in this write-up , drawn in my individual capacity , will be helpful to the TRAI for its finalizing of the Consultation Paper on this subject.