Thursday, September 19, 2013

Comment P.R.Munshi on BMC Draft Policy

These are 4 pages signed by Municipal Commissioner on August 13.

Dy. Chief Engineer Building Proposal City signed on May 22 , 2013
Dy. Chief Engineer Development Plan signed on June 19, 2013
Chief Engineer Development Plan signed on June 27, 2013
Municipal Commissioner signed on August 13 , 2013.

See the delay .


1. This is based on June 1, 2013 Draft Model Guidelines of DoT .
    I cannot understand how Dy. Chief Engineer Building Proposal City
    signed on May 22 , 2013.

2. Under point 3 DoT mention that " India Has adopted strict limit for Radiation
    from  Base Tower Radiation ( BTS ) as below , which is 1/10th of the
    International Norms ( ICNIRP )

    What they fail to tell the Citizens that 95% of the readings were already below
    the revised Norm ( 10% of original ) and so the objective of REDUCING
    RADIATION LEVELS AND HEALTH   HAZARDS were not achieved at
    ground level. This was an EYE WASH.

    The DoT should have divulged the highest reading of the 95% and given a chart
     of Readings under each 10% like :

     Number of Readings          EMFR levels milliwatts per square meter

             0 - 10%
           11 - 20 %
           21 - 30 %
          and so on till
           91- 100 %  

    What was the basis in fixing revised norm to 10% of original and not 25%
    0r 5% ? There was no SCIENTIFIC BASIS as admitted by Secretary DoT.

3. Since the Municipal Commissioner signed on August 13, 2013
    the concerned Departments should have incorporated the ADVISORY
    Guidelines for State Governments for Issue  of Clearance for Mobile Towers
    effective August 1, 2013.

    The Advisory clearly mentions under point 4 " These guidelines are issued
    in supersession of all earlier guidelines on the subject."

3. The Owner of the Building or Co-operative Housing Society must obtain a
    written consent from 70 % of the Tenants or  Occupants  of the Apartments /
    Condominium  before installing or renewing a Contract. This consent should be
    submitted to the Municipal Corporation of Greater Mumbai within three months of
    the announcement of the Revised Policy  and every year thereafter.

4. NOC ( No Objection Certificate  ) in writing  is  MANDATORY from the Top Floor
    Tenants / Residents  to install the Mobile Tower Antennae on the Terrace of the Building
    every year in addition to the written consent of 70% of the Tenants / Occupants as
    specified under point 3 above and under point A. VIII of the DoT Advisory Guidelines.

5. There will be a Ban on Installtion of Mobile Tower Antennae  on top of and
    within 100 meters of Educational Institutions  ( Nurseries , Schools and Colleges)
    Hospitals , Nursing Homes , Old Peoples’ Homes , Balsudhargriha and Hostels /
    Orphanage Buildings  for Children and the Antennae should not be directed /
    positioned towards these Buildings.

    The existing mobile antennae approved earlier on Educational Institutions
    ( Nurseries , Schools and Colleges) Hospitals , Nursing Homes , Old Peoples’ Homes ,                                  
    Balsudhargriha and Hostels / Orphanage Buildings for Children shall be removed within
    one month of the date of these REvised Policy.

    The condition of 3 meters distance from Educational Institutions  
    ( Nurseries , Schools and Colleges) Hospitals , Nursing Homes , Old Peoples’ Homes ,                                  
    Balsudhargriha and Hostels / Orphanage Buildings  for Children  is dropped    in view
    of  the first paragraph  of Point 5 mentioned above.

6.  The Tower and Infrastructure Provider / Cellular Operator  must submit in their
     Data Sheet also the Distance from the Neighbouring Building to expedite approval.

7. Antennae should be fixed on Tripod Towers at a Height of 30 feet (i.e.10 meters) on 
    Terrace of the Highest Building in the locality of 100 meters radius , and away from
    Children , Senior Citizens  and Residents using the Terrace.

   At the entrance to the  Terrace  where Tower is erected , a warning  signboard at entry
    to the terrace to that effect  shall be displayed.

8. There will be a ban on Tripod or any other Towers at Ground level to fix Antennae
    on such Towers in the City of Greater Mumbai.

9.  Maximum One Tower with two Antennae will be permitted per site.
    The condition mentioned of Two Towers is vague. The Towers are not hazardous.
    Towers are only structures. It is the Antennae installed on these Towers that are
    connected to High Power cables which emit EMF Radiation which create Health Hazards.
    It is the number of Antennae per site which has to be restricted and not number of Towers. 
    One Tower can have 10 Antennae or two Towers can have 20 Antennae.
    So it should be explicit and clear in terms of number of Antennae not number of Towers.

    Reasons thereof are also given under point 15.

10. There will be a ban on Installation of Antennae on Brackets or Mobile Towers on
      sidewalls of the Buildings. 

11. Pole Mounted Antenna ( e ) along Roads / Express ways  should be installed at
      least at a height of 5 meters above ground / road level and comply with radiation levels.
      No two installations of Antenna( e ) will be permitted in the vicinity of 35 meters of each 
      installation on Roads / Flyovers / Bridges / Highways / Expressways.

12. Maximum Power Transmission per Antenna should be reduced to  2Watts  ,
     10% of presently permitted 20 Watts per Antenna to reduce Radiation levels to double digit.
     In view of Power Transmission being reduced to 2Watts the TAIPA / Operators must
     consider Solar Energy as a Source of Power to save Electricity , Diesel and make this

13. Fire Brigade Department  ( Chief Fire Officer ) and Electricity Supplying Company
      clearance Mandatory for all Antennae installed.

14.  The Government Agency TERM should get the necessary funds , Manpower and Equipment
      to monitor the Radiation levels and Power Transmission  of thousands of Antennae in the city.
      This has to be provided by the Central Government with a schedule and frequency of Monitoring
      all Antennae installed in the city.

      Power drawn by the antennae should be available as a webtool easily accessed by people
      for effective public watch and reporting misuse.

        The other Norms of this Revised Policy not within the Jurisdiction of
        TERM will be monitored by MCGM at regular intervals

  15. Radiation Levels from Antennae depend on FOUR major parameters :

i)                 Combined Power Output from Antennae
ii)               Number of Antennae installed
iii)             Safe Distance the Antennae are installed from Neighbouring Building
iv)              Safe Height at which the Antennae are installed from Ground Level.

                  Department of Telecommunications , Ministry of Communications & Information
                  Technology have advised the following  norms:
                                Number of Antenna ( e )                     Building Structure safe distance
                          pointed in the same direction                  from the Antenna (e ) at the
                                                                                               same height in  meters
1                                                                       20
                                                  2                                                                    35
4                                                                    45
6                                                                    55         
There is no scientific basis on fixing of the distances for the number of Antennae given above.  Please see the NDTV program “ We The People “ of September 16, 2012                                  a link of which is given below :    

The EMF Radiations from above are much higher than safe levels  according to  Austrian Medical Association norms adopted  on 3, March 2012  in Vienna , Building Biology Guidelines for sleeping areas , Germany  which is 1 milliwatts per square meter compared to 450 milliwatts per square meter.
 In view of the above and to cover any missing parameters we have recommended combined Power Transmission  to 10% of original Power Transmission norm  as was done for the EMF norm.
 In the case of reduction of EMF norm to 10% there was very little or no reduction of EMF radiation as 95% of the Antennae were within the revised upper limit.
 It is only with the reduction of Power Transmission will the radiation levels go down
to TWO digits compared to present THREE digits which can go upto four times during rush / peak hours according to TERM letter to Cuffe Parade Residents Association.
 There are only two options available to reduce Radiation Levels and Health Hazards  in Mumbai :
  Reduce Power Transmission to TWO Watts per Antenna and a maximum of                      
         TWO ANTENNAE per site
  1. Increase the distance norms mentioned above if Power Transmission will continue at 20 watts per Antenna and NOT reduced to 2 Watts .

                               Number of Antenna ( e )                     Building Structure safe distance
                          pointed in the same direction                 from the Antenna (e ) at the
                                                                                                    same height in  meters
                                                  1                                                                 50
                                                  2                                                               100
                                                  4                                                               150
                                                  6                                                               200       

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