Cooran - Development Application

         “Studies to date provide no indication that environmental exposure to RF fields, such as from base
         stations, increases the risk of cancer or any other disease.” 17

The facility proposed, which represents an environmental exposure to
radiofrequency energy, is strictly consistent with WHO safety standards, and,
unlike personal mobile phone use, is not subject to special advice from the WHO
regarding additional precautionary measures to reduce exposure.



7.12.4 Precautionary Approach

The WHO-recommended standard that Australia has adopted has a significant
safety margin, or precautionary approach built into it. The WHO states:

         “International guidelines and national safety standards for electromagnetic fields are developed
         on the basis of the current scientific knowledge to ensure that the fields humans encounter are
         not harmful to health. To compensate uncertainties in knowledge (due, for example, to
         experimental errors, extrapolation from animals to humans, or statistical uncertainty), large safety
         factors are incorporated into the exposure limits.”18

The Australian Radiation Protection and Nuclear Safety Authority (ARPANSA)
reiterates that the safety standard has a precautionary level already built into
the standard:

         “Significant safety factors are incorporated into the exposure limits – that is, the limits are set well
         below the level at which adverse health effects are known to occur.” 19

By operating the fixed wireless network at maximum signal strengths that are
significantly below that safety standard, nbn has additionally applied a
precautionary approach to the operation of its network, in keeping with the
expectations of the Standard, which defines a valid precautionary approach as
follows:

          “Minimising, as appropriate, RF exposure which is unnecessary or incidental to achievement of
         service objectives or process requirements, provided this can be readily achieved at reasonable
         expense. Any such precautionary measures should follow good engineering practice and relevant
         codes of practice. The incorporation of arbitrary additional safety factors beyond the exposure
         limits of this Standard is not supported.” 20

The proposed facility reflects this requirement. ARPANSA states:

         “Similarly, the ACIF Code does not specify arbitrary distances at which infrastructure must be
         sited from community sensitive locations, because arbitrary distances do not necessarily reflect a
         precautionary approach. In fact, infrastructure sited further from a community sensitive area may
         need to operate at a higher power and may result in higher EME exposures in that sensitive area.


17
   www.who.int/features/qa/30/en/
18
   http://www.who.int/peh-emf/about/WhatisEMF/en/index1.html
19
   http://www.arpansa.gov.au/pubs/rps/rps3_qa.pdf
20
   Australian Radiation Protection Standard, Maximum Exposure Levels to Radiofrequency Fields 3kHz to 300GHz

                                                                                                               68