ENVIRONMENTAL SCOPING STUDY FOR THE PROPOSED …€¦ · for CV). 1.2 TERMS OF REFERENCE The Terms...

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Auasblick Macro Telecommunications Site

Final Scoping Report

April 2015

2015

ENVIRONMENTAL SCOPING STUDY FOR THE PROPOSED DEVELOPMENT OF A MACRO TELECOMMUNICATIONS SITE IN AUASBLICK, WINDHOEK

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COPYRIGHT © ENVIRO DYNAMICS, 2015. ALL RIGHTS RESERVED

PROJECT NAME Environmental Scoping Report for the proposed construction of a Macro Telecommunications Structure in Auasblick, Windhoek

STAGE OF REPORT Environmental Scoping Report

CLIENT Mobile Telecommunication Company (MTC)

Enquiries: Morne Weitz

Tel: (061) 280 2634

E-Mail: [email protected]

LEAD CONSULTANT Enviro Dynamics

Enquiries: Eloise Carstens

Tel: (061) 223-336

E-Mail: [email protected]

DATE OF RELEASE April 2015

AUTHOR Eloise Carstens, Charlotte Cronje, Lester Harker, Eddy Kuliwoye, Sheldon Husselmann

Internal Reviewer: Norman Van Zyl

mailto:[email protected]

mailto:[email protected]

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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 APPENDICES ....................................................................................................................... vii

ABBREVIATIONS ................................................................................................................. viii

1 INTRODUCTION............................................................................................................. 1

1.1 BACKGROUND ...................................................................................................... 1

1.2 TERMS OF REFERENCE ........................................................................................... 1

2 PROJECT AND SITE DESCRIPTION ................................................................................ 4

2.1 WHAT IS A CELLULAR NETWORK? ......................................................................... 4

2.2 SUMMARY DESCRIPTION OF PROJECT ................................................................. 5

2.3 RATIONALE FOR THE PROPOSED PROJECT .......................................................... 6

2.4 THE ALTERNATIVES ................................................................................................. 8

2.4.1 TOWER SHARING ............................................................................................ 8

2.4.2 ALTERNATIVE SITE LOCATIONS ....................................................................... 8

2.4.3 ALTERNATIVE TECHNOLOGY ......................................................................... 8

2.5 SUMMARY DESCRIPTION OF SITE ........................................................................ 10

3 LEGISLATION POLICIES AND GUIDELINES .................................................................. 12

4 PUBLIC CONSULTATION PROCESS ............................................................................. 15

4.1 THE INTERESTED AND AFFECTED PARTIES (I&APS) .............................................. 17

4.1.1 THE INDUSTRY - MTC ..................................................................................... 17

4.1.2 PUBLIC ........................................................................................................... 17

4.1.3 GOVERNMENT .............................................................................................. 17

4.2 OBJECTIONS RAISED AGAINST THE PROPOSED PROJECT BY I&APs ................. 19

4.3 DISCUSSION OF OBJECTIONS ............................................................................. 19

4.3.1 PERCEIVED RISKS VS PERCEIVED BENEFITS .................................................. 19

4.3.2 THE INFLUENCE OF PERCEPTION IN THE EIA PROCESS ................................ 21

5 IDENTIFICATION OF KEY ISSUES .................................................................................. 22

6 IMPACT ASSESSMENT.................................................................................................. 23

6.1 METHODOLOGY .................................................................................................. 23

6.2 SCREENING AND ASSESSMENT OF IMPACTS ...................................................... 26

6.3 DISCUSSION ......................................................................................................... 31

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6.3.1 HEALTH CONCERNS ..................................................................................... 31

6.3.2 POTENTIAL EFFECTS ON PROPERTY VALUES ................................................ 36

7 CONCLUSIONS AND RECOMMENDATIONS ............................................................. 37

8 REFERENCES ................................................................................................................ 38

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TABLES Table 1: Project description ............................................................................................ 5

Table 2: Site description of preferred alternative ....................................................... 10

Table 3: Public consultation process followed during the EIA ................................... 15

Table 4: Authorities involved in this project ................................................................. 18

Table 5: Main issues of concern ................................................................................... 22

Table 6: Definitions of each of the Criteria used to determine the significance of impacts ............................................................................................................ 25

Table 7: Definitions of the various significance ratings ............................................... 26

Table 8: Screening and assessment of impacts .......................................................... 27

FIGURES

Figure 1: Coverage prediction plots. .......................................................................... 3

Figure 2: Extent of reach of each of the type of cells (Mobile Operators Association, 2012). ......................................................................................... 4

Figure 3: Example of a disguised tree structure (proposed for this site) ................... 5

Figure 4: Proposed location for the Macro Telecommunication Site in Auasblick, Windhoek ....................................................................................................... 7

Figure 5: A non-scientific depiction of the signal propagation of Omni and Directional antennae (view from above) ................................................... 9

Figure 6: A photo of a poster that was put up in Auasblick .................................... 16

Figure 7: Screening process to determine key impacts .......................................... 24

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APPENDICES

APPENDIX A Curriculum Vitae: Eloise Carstens

APPENDIX B Environmental Management Plan (EMP)

APPENDIX C Stakeholders List

APPENDIX D Newspaper Advertisements

APPENDIX E Posters

APPENDIX F Background Information Document

APPENDIX G Exposure to Electromagnetic Fields

APPENDIX H Issues and Responses Trail

APPENDIX I Antennae Specifications

APPENDIX J Meeting proceedings

APPENDIX K Comments and Responses Trail

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ABBREVIATIONS

AM Amplitude Modulation

BID Background Information Document

BTS Base Transceiver Station

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 Telecommunications Company (Pty) Ltd

NBC Namibian Broadcasting Corporation

NCC Namibia Communications Commission

Non-Ionising Radiation

Electromagnetic radiation that does not carry enough energy per quantum to ionise atoms or molecules.

RFR Radiofrequency Radiation

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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

An increase in the use of mobile communication in Windhoek has resulted in the need for service providers (such as MTC) to expand their networks. Service provision to areas that suffer from congestion or poor coverage can be increased by providing additional capacity (Figure 1). It is for this reason that MTC needs to erect a macro telecommunications site in Auasblick, 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 project. Eloise Carstens is the Environmental Assessment Practitioner that conducted the EIA (see Appendix A for CV).

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 (Section 2);

• Identify existing environmental (both bio-physical and socio-economic) conditions of the area in order to determine their environmental sensitivity (Section 2);

• Identify all legislation and guidelines that have reference to the proposed project (Section 3);

• 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 (Section 4);

• Consider the potential environmental and social (including biological) impacts of the development, and assess the significance of the identified impacts (Section 6).

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• Outline management and mitigation measures in an Environmental Management Plan (EMP) to minimise and/or mitigate potentially negative impacts (Appendix B).

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Figure 1: Coverage prediction plots.

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Figure 2: Extent of reach of each of the type of cells (Mobile Operators Association, 2012).

2 PROJECT AND SITE DESCRIPTION

2.1 WHAT IS A CELLULAR NETWORK?

Networks are designed to ensure that mobile devices maintain a link with the network as users move from one cell (geographic area served by a Base Transceiver Station (BTS)) to another.

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 (Extent of reach of each of the type of cells (Mobile Operators Association, 2012).Figure 2):

• 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 site proposed in this study is 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.

• Picocells: Provides localised coverage and are usually less visible. They are put up in shopping centres and airports to strengthen the signal.

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2.2 SUMMARY DESCRIPTION OF PROJECT

Table 1: Project description

Project Aspect Detail

Site location • Physical address: Erf 469, Montreaux Street, Auasblick, Windhoek.

• GPS Co-ordinates: S22.60278, E17.11666

Structure design Height: 15 meter

Mast type: Disguised tree structure

Power output: 20 W

Radio frequency: 880 - 960 MHz / 1920 - 2170 MHz

Antennae: 3 x Kathrein 742265 (65 degree, dual band) – (please see Appendix I for the antenna’s specifications).

Footprint 81 m2 (9 m x 9 m)

Road Access The nearest existing road is Montreaux Street in Auasblick. Access to site can be granted from there and a single track will be made through the veld to site.

Power supply A connection will be made to the power grid of the City of Windhoek.

Security Surrounded by a 2 m high palisade fence (with electric fencing on top)

Figure 3: Example of a disguised tree structure (proposed for this site)

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Equipment containers One 2.4 m x 2.4 m equipment container

Assembly and erection (construction personnel)

Approximately 5 permanent staff will be employed. Local labour will be used for unskilled labour. No employees will be accommodated on the site.

Assembly and erection (duration)

The civil works takes approximately 4 weeks after which the foundation rests for 2 weeks. Tower installation takes about 2 weeks depending on the weather.

2.3 RATIONALE FOR THE PROPOSED PROJECT

Due to the increase in the demand for quality mobile communication services in Windhoek, MTC should continuously expand their communications network in order to achieve additional capacity and coverage. This ensures that the quality of the service provided by MTC to their customers is ensured and greatly improved. The lack of serving signal level strength causes customer service in/around the area to be below license (CRAN) agreement and improvements are only possible by constructing a new site.

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Figure 4: Proposed location for the Macro Telecommunication Site in Auasblick, Windhoek

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2.4 THE ALTERNATIVES

2.4.1 TOWER SHARING

The Communications Act of 2009 requires that service providers consider sharing existing infrastructure in the focus area first, before constructing new structures. MTC has considered this, but no existing structures in the focus areas could be found that suited their purpose. Improvements to the serving signal strength is only possible by building a new structure.

2.4.2 ALTERNATIVE SITE LOCATIONS

A number of factors determine the location of a telecommunications site. These factors form the selection criteria used by MTC, to select the best possible site to erect cellular infrastructure.

These are:

• Coverage of existing network infrastructure

• Surrounding topography and built-up environment

• Established and future urban area

• The required footprint

• The most appropriate design of the facility

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 location 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 station 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 site is located on elevated ground and is optimally positioned to avoid these concerns.

2.4.3 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:

Ø 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

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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.

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).

Due to the longer transmission range of macro BTS MTC is proposing the construction of macro structure at the Auasblick site.

Ø Directional vs. Omni Directional Antennae

Directional Antennae are designed to focus the signal in a particular direction over greater distances (Figure 5). 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.

Omni Directional Antennae on the other hand, are designed to provide 360-degree coverage from one antenna instead of installing three panel antennas to provide the same degree of coverage (Figure 5). 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.

Figure 5: A non-scientific depiction of the signal propagation of Omni and Directional antennae (view from above)

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The antennae 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 (Enviro Dynamics, 2012).

The directional antennae to be used on the structure at the Auasblick site will be capable of covering a longer transmission range, through its three Directional 65 Degree dual band Antennae, typical of a macro BTS of this type. This will ensure far-reaching coverage and improved network services in the target area.

Ø Alternative structure

Because the structure may be visible from certain neighbouring houses consequently affecting the visual amenity of the area, a disguised telecommunications tree structure is proposed as indicated in Figure 3.

2.5 SUMMARY DESCRIPTION OF SITE

Only the most pertinent environmental sensitivities have been provided in Table 2 below.

Table 2: Site description of preferred alternative


Climate • Annual precipitation: Approximately 350 – 450 mm • Maximum temperature: 28-30˚C • Minimum temperature: 4-6˚C

Landscape The 15 m high disguised tree structure will be located on an elevated area in the undulating suburb of Auasblick, which forms part of the Khomas Hochland Plateau.

Soil and geology Mostly Lithic Leptosols. These soils are very thin or shallow and form in actively eroding landscapes. They are coarse textured and has low water-holding capacity. Surface runoff is therefore high during periods of rainfall (Mendelsohn, 2009).

Habitat It forms part of the Highland Shrubland where dense shrubland vegetation is dominant. The site is undisturbed and the veld is in a pristine condition.

Site ownership and occupancy

The proposed site is located on erf 469 in Auasblick. It is zoned as Public Open Space and belongs to the City of Windhoek (CoW). A lease agreement will be set up between MTC and

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the CoW regarding the use of land for the proposed site.

Surrounding land uses The proposed site is undeveloped virgin veld in the east of Windhoek. The Auasblick extension closest to site is currently developing and most erven are still empty or being cleared for development.

• A new development – Auas Hills Retirement Village – is being constructed in close proximity to the proposed telecommunications site. The village will consist of 316 apartments, medical facilities and other amenities. Its closest boundary is located approximately 90 m from the proposed site.

• The future residence of the current President of Namibia is also being constructed close by.

• Seven erven in total are located within 150 m of the proposed site.

Civil aviation Clearance is required from the Directorate of Civil Aviation in compliance with the International Civil Aviation Organization because:

• The site is less than 8km from the Eros aerodrome.

• The tower is located on an elevated area.

• The proposed site is located approximately 3.5 km directly west of Eros Airport in Windhoek abeam the approach path for runway 27.

Visual amenity The structure may be visible from certain neighbouring houses and affect the visual amenity of the area. For this reason, a disguised telecommunications tree structure is proposed as indicated in Figure 3.

Key population statistics Auasblick is a low-density residential suburb on the outskirts of Windhoek with an average household size of 3.7 (NPC, 2011). Diversifying the density of the area, the Auas Hills Retirement Village is a sectional title development falling in the medium-high population density range.

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3 LEGISLATION POLICIES AND GUIDELINES

The following table provides a review of pertinent international and national legislation, standards and guidelines that are of relevance to the project. The review serves to inform the reader as well as the decision making authorities

LEGISLATION/ GUIDELINE

RELEVANT PROVISIONS IMPLICATIONS FOR THIS PROJECT

NAMIBIAN NATIONAL LEGISLATION

Namibian Constitution First Amendment Act 34 of 1998

“The State shall actively promote… maintenance of ecosystems, essential ecological processes and biological diversity… and utilization of living natural resources on a sustainable basis for the benefit of all Namibians, both present and future” (Article 95(l)).

Ecological sustainability should inform and guide this EA and the proposed development.

Environmental Management Act (EMA) (7 of 2007)

• Requires that projects with significant environmental impact are subject to an environmental assessment process (Section 27).

• Details principles which are to guide all EAs.

The principles laid out in the EMA should inform and guide this EIA process.

Forestry Act 12 of 2001

Nature Conservation Ordinance 4 of 1975

Prohibits the removal of and transport of various protected plant species.

A permit needs to be obtained from the Municipality before felling protected plant species.

Civil Aviation Annex 14 to the Convention on International Civil Aviation.

• Chapter 4: Obstacle restrictions and removal

• Chapter 6: Visual aids and donating of obstacles

The proposed new structure may be an obstacle to Eros aerodrome. The location of the telecommunications site needs to be assessed in accordance with Annex 14.

Visual aids to the new masts to make them visible to aircrafts need to be applied in accordance with this Convention.

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Labour Act 11 of 2007

Details requirements regarding minimum wage and working conditions (S39-47).

MTC should ensure that all contractors involved during the construction, operation and maintenance of the proposed project comply with the provisions of these legal instruments.

Health and Safety Regulations GN 156/1997 (GG 1617)

Details various requirements regarding health and safety of labourers.

Listed Activities Notice and Environmental Impact Assessment Regulations GN 29-30 (GG 4878)

• Requires ECC for the “construction of masts of any material or type and of any height, including those used for telecommunication broadcasting and radio transmission”

• Details requirements for public consultation within a given environmental assessment process (GN 30 S21).

• Details the requirements for what should be included in a Scoping Report (GN 30 S8) and an Assessment Report (GN 30 S15).

Telecommunication site triggers an EIA.

Conduct public participation as part of the EIA process described in the act.

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.

Encourage the sharing of infrastructure to avoid cumulative impact.

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 the setting of specifications and standards for new technologies such as cellular, wireless and satellite services.

Provides the standards for setting up cellular, wireless and satellite services.

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.

ICNIRP standards will be used to determine the “safe distance” around the proposed site.

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INTERNATIONAL STANDARDS AND GUIDELINES

ICNIRP Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic, and EMFs (up to 300GHz) (April 1998)

Provides international standards and guidelines for limiting the adverse effects of non-ionising radiation on 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.

The proposed project needs to adhere to exposure limits set out in these guidelines.

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4 PUBLIC CONSULTATION PROCESS

Public Participation forms an important component of the Environmental Impact Assessment process. A summary of the public consultation process following during this EIA process is provided in Table 3 below:

Table 3: Public consultation process followed during the EIA

DESCRIPTION OF PROCESS TIME ALLOWED

SHARING OF INFORMATION WITH PUBLIC

Identification of I&APs

Key Interested and Affected parties (I&APs) were identified and included in a register (Appendix C). The contact details of potential I&APs were obtained in various ways:

1) Existing datasets

2) From the City of Windhoek

3) Web searches

4) Letters delivered by hand

The register was maintained throughout the process.

Newspapers advertisements

Notices were placed in the press, briefly explaining the development and its locality and inviting the public to register as I&APS (Appendix D).

On 10 and 14 November 2014 in The Namibian and on 7 and 14 November 2014 in Republikein.

Written Notices People living within a 300 m radius from the proposed site was consulted. This includes approximately thirty erven.

Each erf owner was sent a BID, a letter and a factsheet per e-mail or registered post.

Not all of the identified I&APs could be reached electronically. E-mail addresses for five of the erven (numbers 225, 226, 230, 240 and 245,) in Auasblick could not be obtained, as the ervens are registered in cc’s. However, the most recent postal addresses were made available by the CoW and a BID, factsheet and letter was sent via registered mail to the five owners.

Nampost (the postal service of Namibia) stated that delivery within Windhoek takes 2 days. The letters were posted on 26 November 2014.

Notice boards In addition, posters (Appendix E) were placed close to the proposed site informing the public of the project and inviting them to comment.

Posters were put up at three strategic locations (Figure 6):

1) On the Woermann and Brock notice board in Olympia (this is the closest shopping

The posters were up for 17 days from 18 November 2014 to 4 December 2014.

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DESCRIPTION OF PROCESS TIME ALLOWED

centre to the proposed site)

2) On the corner of Montreaux and Sean McBride Streets

3) On the corner of Demonte Street and Sean McBride Street

Information documents

A Background Information Document (BID) was compiled that contained the information of the project (Appendix F). The BID was forwarded to all authorities and registered I&APs.

Continued throughout the process every time someone registered.

Meetings A public meeting was held on the 24th of February 2015 at the Windhoek Gymnasium School Hall at 18:00 (See Appendix J).

An additional comments period was allowed after the meeting until the 3rd of March 2015.

OPPORTUNITY FOR PUBLIC TO COMMENT

I&APs had the opportunity to raise their comments until 4 December 2014 and all comments received up to that date have been taken into consideration during the reporting phase. A commentary period was allowed between the 13th of march and the 27th of March on the Scoping Report. Comments received are contained in the Comments and Responses Trail (Appendix K)

The total period allowed for comments from the first placement of the adverts (7 November 2014) to the 27rd of March 2015 is 127 days.

Figure 6: A photo of a poster that was put up in Auasblick

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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.

4.1 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 proposed project has received public interest and 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. The following section highlights the key I&APs.

4.1.1 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.

4.1.2 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.

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 metres.”

4.1.3 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

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national and local authorities (Table 4).

• 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 authorising spectrum

frequencies. During the consultation process, CRAN was informed of the proposed project. All documents was sent to them for comments.

• The National Radiation Protection Authority: This authority is charged with the administration of the act by a) inspecting any radiation source in order to assess radiation safety conditions b) taking the necessary action to enforce the provisions made in the Act. This authority recommends the use of standards and guidelines published by the International Commission on Radiological Protection (ICNIRP), the International Commission on Non-ionising Radiation (ICNR), the International Atomic Energy Agency (IAEA), or other relevant international organisations.

• 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 and as such, information was sent to them.

Table 4: Authorities involved in this project

ITEM LEVEL DESCRIPTION

STA

KEH

OLD

ER D

ATA

BASE

NA

TION

AL

AUT

HO

RITIE

S

Ministry of Environment and Tourism

Ministry of Works and Transport

Ministry of Health and Social Services

Ministry of Regional and Local Government, Housing and Rural Development

Ministry of Information and Communication Technology

REG

ION

AL

AN

D

LOC

AL

A

UTH

ORI

TIES

City of Windhoek

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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.

4.2 OBJECTIONS RAISED AGAINST THE PROPOSED PROJECT BY I&APs

During the public issues and responses period (7 November 2014 to 4 December 2014), we received objections against the construction of the tower in Auasblick from three sets of erven owners in Auasblick as well as other Windhoek residents. The following people strongly objected to the project and their official correspondence is included as part of the Issues and Responses Trail (Appendix H).

Owners/residents in Auasblick:

1. Mr R. McNamara 2. Ms T. McNamara 3. Mr F. van der Westhuizen 4. Mr R. Volker 5. Ms A. Volker

Windhoek residents not residing in Auasblick:

1. Mr K. McNamara 2. Ms S. McNamara 3. Mr W. Schweiger 4. Mr P. Mostert

The issues raised revolved mainly around the potential health risks associated with the telecommunications sites, the potential hindrance to civil aviation activities (Eros aerodrome) as well as a possible reduction in property value.

4.3 DISCUSSION OF OBJECTIONS

The main conclusion that can be drawn from the objections is that there is a fear regarding the health risks the structures may pose to the neighbouring residents (please see Appendix G for the full discussion). Official views and the sources of information have also been called into question. Possible reasons for this are highlighted below:

4.3.1 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

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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 opposed 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. For example, if a person does not own a cellphone or computer they will not benefit directly from the project and will therefore perceive the risk as high. On the other hand, a person who has a medical history and relies on a cellphone as his or her only means of obtaining medical attention may perceive the benefit as high while the immediate risk may be perceived as less.

Based on the communication received from the concerned I&APs on this project the following ratings apply in terms of perceived risk vs. perceived benefits.

These figures indicate, that:

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• 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.

4.3.2 THE INFLUENCE OF PERCEPTION IN THE EIA PROCESS

It is very difficult to assess perception as it cannot be scientifically measured. The fact that perceptions play a major part in the views of the public cannot be ignored.

However, it is the task of the EIA consultant to stay as objective as possible and

evaluate a situation according to the information available at a given time. This is

why, in the absence of scientific proof that telecommunications sites have a

definitive negative effect on human health; the precautionary principle is applied

where ICNIRP Standards are followed. For a more comprehensive discussion of

exposure to EMF and the precautionary principle built into ICNIRP, please see Appendix G.

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4.4 IDENTIFICATION OF KEY ISSUES

Before one can assess the potential impacts associated with the proposed project, it is necessary to define the key issues that were raised during 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 5). The complete list of issues and responses can be viewed in Appendix H.

Table 5: Main issues of concern

THEME ISSUE

HEALTH CONCERNS • Impact on children

• Long term effects of non-thermal EMF

• BTS in a residential area

• Possible carcinogen

• Involuntary, uncontrolled, continuous exposure

• BTS adjacent to Auas Retirement Village currently in construction

PROPERTY VALUE • Reduction in property value

• Visual impact/aesthetics

CIVIL AVIATION • The proposed new structure may be an obstacle to Eros aerodrome.

ISSUES BEYOND THE SCOPE OF THIS EIA

• Commitment requested from MTC ensuring they will not cause damage to the environment or human health (comment has been passed on to MTC).

• Letter requested from MTC stating that the proposed location is the only option in the area that provides the most benefit or causes the least damage to the environment as a whole, at a cost acceptable to society (comment has been passed on to MTC).

The following chapter will assess the identified key issues.

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5 IMPACT ASSESSMENT

5.1 METHODOLOGY

The EIA Regulations require “a description of the significance of any significant effects, including cumulative effects that may occur as a result of the undertaking of the activity”. In order to determine significance each of the potential impacts identified have been subjected to the following questions displayed graphically (steps 1 and 2 – Figure 7) and in tabular form (Table 8) below. These questions form the methodology for assessing the significance of the effects or impacts identified through this EIA process:

1. The first step is to screen out (set aside) all impacts which do not fall within the scope of this project and responsibility of the developer;

2. The next step is to determine whether sufficient information exists to assess the potential impacts of those that remain. If insufficient information is available to assess, or insufficient mitigation measures to address a given impact, further investigation will be required; and

3. If sufficient information is available to assess a given impact (with a high degree of confidence) and to recommend mitigation measures, no further investigation will be required and the impact will be addressed in the EMP.

Application of the abovementioned steps is displayed in Table 5.

4. Finally based on the answers obtained after applying steps 1-3, a decision can be made regarding the significance of the impact based on three categories – low, medium or high.

To fully understand the significance of each of the potential impacts, it is necessary to subject each to a range of assessment criteria. The application of these criteria, in determining the significance of potential impacts, uses a balanced combination of duration, extent, and intensity/magnitude, modified by probability, cumulative effects, and confidence. The definitions of each of the criteria are contained in Table 6.

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Figure 7: Screening process to determine key impacts

Sufficient information to assess the impact

Insufficient information to assess the impact

No further investigation required

Further investigation required

Issue communicated to applicable authority

NO YES

Does the issue/potential impact fall within the scope of this EA and the

responsibility of the Developer?

Determination of impact significance

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Table 6: Definitions of each of the Criteria used to determine the significance of impacts

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 Geographic area. Indicates whether the impact will be within a limited area (on site where construction is to take place); local (limited to within 25km of the area); regional (limited to ~200km radius); national (limited to the borders of Namibia); or international (extending beyond Namibia’s borders).

DURATION Whether the impact will be temporary (during construction only), short term (1-5 years), medium term (5-10 years), long term (longer than 10 years, but will cease after operation) or permanent.

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 uncertain, improbable (low likelihood), probable (distinct possibility), highly probable (most likely) or definite (impact will occur regardless of prevention measures).

SIGNIFICANCE Significance is given before and after mitigation. Low if the impact will not have an influence on the decision or require to be significantly accommodated in the project design, Medium if the impact could have an influence on the environment which will require modification of the project design or alternative mitigation (the design can be used, but with deviations or mitigation). High where it could have a “no-go” implication regardless of any possible mitigation (an alternative design should be used).

STATUS OF THE IMPACT

A statement of whether the impact is positive (a benefit), negative (a cost), or neutral. Indicate in each case who is likely to benefit and who is likely to bear the costs of each impact.

DEGREE OF CONFIDENCE IN

PREDICTIONS

Is based on the availability of specialist knowledge and other information.

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Table 7: Definitions of the various significance ratings

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 intensity/ 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 medium intensity/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 intensity, locally for longer than a month, and/or of high intensity regionally and beyond.

5.2 SCREENING AND ASSESSMENT OF IMPACTS

All impacts included in the table below fall within the scope of this project and responsibility of MTC. Each of the potential impacts is screened (Figure 7) and subjected to the criteria stipulated above (Table 6). The significance of each potential impact is determined based on the criteria in Table 7.

Detailed descriptions of mitigation measures for impacts that require mitigation are contained in the EMP (Appendix B).

Impacts with a medium or high significance rating discussed at the end of this chapter.

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Table 8: Screening and assessment of impacts

POTENTIAL IMPACT

STATUS/ NATURE EXTENT DURATION INTENSITY PROBABILITY CONFIDENCE/ SUFFICIENT

INFORMATION AVAILABLE?

SIGNIFICANCE

PRE-MITIGATION

MITIGATION POST-MITIGATION

PLANNING AND DESIGN PHASE

Civil Aviation Hindrance

Negative. A potential risk to civil aviation operations at Eros aerodrome.

Local Long-term Low Improbable Yes Low Ensure that the placement of the telecommunications site does not influence civil aviation operations at Eros aerodrome – obtain clearance from the Directorate of Civil Aviation.

Low

Visual amenity impact

Negative. The visual amenity in the vicinity of the telecommunications site is negatively impacted.

On site Long-term Medium Probable Yes Medium Ensure that the design of the telecommunications site enhances/minimally affects the amenity of the area eg. disguised structure

Low

Radiation impact

Negative. Concerns regarding the impact of radiation on human health.

On site Long-term Low Uncertain Yes Medium-High

Ensure that ICNIRP standards are adhered to when a location is proposed.

Low

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POTENTIAL IMPACT



SIGNIFICANCE

PRE-MITIGATION


CONSTRUCTION PHASE

Soil contamination

Negative. Waste and hazardous substances utilised during construction may spill on the ground and contaminate the soil.

On site Temporary Low Probable Yes Low Clean up any spills and waste immediately

Low

Dust impacts Negative. Construction activity will generate dust, which may affect nearby residents.

On site Temporary Low Improbable Yes Low Implement dust suppression techniques

Low

Limited job opportunities

Positive. Temporary creation of unskilled jobs during construction of project components and services infrastructure.

Local Temporary Medium Probable Yes Low Implement locals only for all unskilled labour jobs

Low

Noise impacts Negative. Construction activity will generate noise, which will affect nearby residents.

On site Temporary Low Improbable Yes Low Work only between 7h00 and 17h00

Low

OPERATION AND MAINTENANCE PHASE

Provision of access to a mobile cellular network

Positive. Access to a mobile cellular network will be provided.

Local Long-term High Definite Yes High Construct the telecommunications site

High

Influence on Civil Aviation

Negative. Potential impact on civil aviation operations at Eros

Local Long-term Low Improbable Yes Low Ensure that the location adheres to

Low

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POTENTIAL IMPACT



SIGNIFICANCE

PRE-MITIGATION


Airport. Civil Aviation requirements regarding the placement of a telecommunications site

Health impacts associated with thermal effects of EMF

Negative. Thermal effects due to exposure to EMF experienced by residents located in the areas adjacent to the proposed structure.

On site Long-term Low Improbable Yes Low Adhere to ICNIRP Guidelines

Low

Health impacts associated with non-thermal effects of EMF

Negative. Non-thermal effects due to exposure to EMF experienced by residents located in the areas adjacent to the proposed structure.

On site Long-term Low Uncertain Yes Medium Adhere to ICNIRP Guidelines

Low

Impact on property value

Negative. Construction of the telecommunications site may impact on the property value of neighbouring erven.

On site Long-term Low Improbable Yes Low If civil aviation is not influenced by the structure, do not paint it red and white

Low

DECOMMISSIONING PHASE

Soil contamination

Negative. Waste and hazardous substances utilised during deconstruction may spill

On site Temporary Low Probable Yes Low Clean up waste and spills immediately

Low

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POTENTIAL IMPACT



SIGNIFICANCE

PRE-MITIGATION


on the ground and contaminate the soil.

Dust impacts Negative. Deconstruction activity will generate dust and may affect nearby residents.

On site Temporary Low Improbable Yes Low Implement dust suppression techniques

Low

Noise impacts Negative. Construction activity will generate noise, which will affect nearby residents.

On site Temporary Low Improbable Yes Low Work only between 7h00 and 17h00

Low

Limited job opportunities

Positive. Temporary creation of unskilled jobs during deconstruction of project components and services infrastructure.

Local Temporary Medium Probable Yes Low Implement locals only for all unskilled labour jobs

Low

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5.3 DISCUSSION

The following should be noted concerning the negative impacts listed above that have a medium/high pre-mitigation significance rating:

5.3.1 Visual impact

The proposed structure will be 15 meter high, on elevated ground in a primarily residential area. For this reason a disguised tree structure is recommended.

5.3.2 Health Concerns

Ø Radio Frequency (RF) radiation

In a recent report, the American Cancer Society (ACS) (2014) states that although there is a concern from the public that living, working or going to school near a cell phone tower may increase the risk of cancer or other health problems, there is currently very little evidence to support this. The ACS (2014) provides the following points to consider:

• Energy level of radiofrequency (RF) waves is relatively low, especially when compared with the types of radiation that are known to increase cancer risk, such as gamma rays, x-rays, and ultraviolet (UV) light. The energy of RF waves given off by cell phone towers is not enough to break chemical bonds in DNA molecules, which is how these stronger forms of radiation may lead to cancer.

• RF waves have long wavelengths. This makes it unlikely that the energy from RF waves could be concentrated enough to affect individual cells in the body.

• The level of RF waves present at ground level is very low – well below the recommended limits.

• Wood or cement block reduces the exposure level of RF radiation by a factor of about 10.

• The energy from the antennae, is directed toward the horizon (parallel to the ground), with some downward scatter. The amount of energy decreases rapidly as the distance from the antenna increases. As a result, the level of exposure to radio waves at ground level is very low compared to the level close to the antenna. Actual measurements have shown that distance to a base station is not a good proxy for exposure, due to the considerable variability in characteristics of the antennae, and shielding

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and reflection of the waves (International Agency for Research on Cancer (IARC), 2013).

• Today’s society relies on mobile phones working everywhere including at home, at school and at work. When base stations are located close to users, the transmitter power required by the mobile phone and the base station to communicate is relatively low. If base stations were located further away, the power required is generally higher, and this means a higher EMF (ACS, 2014).” In 2013 the IARC affirmed this by stating that “the better the connection, which is ensured by a dense network of base stations, the lower the energy output from the phone.”

Ø Long-term, Low level exposure

The current health debate regarding base stations and human health are centred on whether long-term, low level exposure can cause adverse health effects or influence people’s well-being.

The potential health effects associated with long-term low-level exposure have been extensively studied over the last few decades (ICNIRP, 2014). In 2006 the International Agency for Research on Cancer (IARC) published a report that concluded that static and extremely low frequency electric and magnetic fields should be classified as a Class 2B – a possible human carcinogen (i.e. may be cancer causing). This statement was reviewed in 2013, by an IARC Monographs Working Group who considered recent epidemiological evidence, cancer bioassays, and mechanistic and other relevant data to reach conclusions as to the carcinogenic hazard to humans from exposure to these electromagnetic fields. They concluded that “With “limited evidence” for carcinogenicity in humans based on an increased risk of glioma – a malignant brain tumour – among heavy users of mobile telephones, radiofrequency electromagnetic fields were classified as “possibly carcinogenic to humans” (Group 2B)” (IARC, 2006).

According to ICNIRP (2010) “a causal relationship between magnetic fields and childhood leukemia has not been established nor have any other long term effects been established. The absence of established causality means that this effect cannot be addressed in the basic restrictions. However, risk management advice, including considerations on precautionary measures, has been given by WHO (2007) and other entities”. “At present, these bodies consider the scientific evidence related to possible health effects from long-term, low-level exposure to ELF fields insufficient to justify lowering these quantitative exposure limit” (WHO, 2007).

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“To date, no adverse health effects from low level, long-term exposure to radiofrequency or power frequency fields have been confirmed, but scientists are actively continuing to research this area” (WHO, 2015).

Ø Latest Research

Various health reviews have been undertaken not only by WHO but also other organizations (See list of research under Section 6: Bibliography). For this report, individual case-based studies were not considered. Instead, the approach to the review of the most recent research was based on WHO: Establishing a dialogue on risks from electromagnetic fields (2002), that states that “the best sources of information are from panels of independent experts who periodically provide summaries of the current state of knowledge”. Many of these reviews have found no evidence of risks to health from the radio waves produced by mobile base stations.

REPORT/WORKSHOP YEAR REFERENCE

Mobile Telecommunications and Health Research Programme

2012 (MTHR, 2012)

Health Effects from Radiofrequency Electromagnetic Fields – Report of the independent Advisory Group on Non-ionising Radiation.

2012 (Health Protection Agency, 2012)

Radiofrequency Toolkit for Environmental Health Practitioners

2013 (BC Centre for Disease Control, 2013)

IARC Monographs on the evaluation of carcinogenic risks to humans

2013 (IARC, 2013)

WHO RF and Health Presentation – ITU Workshop on EMF Turin May 2013

2013

Research 2013:19 Eighth report from SSM:s Scientific Council on Electromagnetic Fields

2013 (SSM:S Scientific Council on Electromagnetic Fields, 2013)

Opinion of the French Agency of Food, Environmental and Occupational Health and

2013 (ANSES , 2013)

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REPORT/WORKSHOP YEAR REFERENCE

Safety concerning the update of the “Radiofrequency electromagnetic fields and health” expert appraisal.

Review of Radiofrequency Health Effects Research – Scientific Literature 2000 – 2012

2014 ARPANSA Radiofrequency Expert Panel (ARPANSA, 2014)

ICNIRP workshop on RF field health effects & standards

November 2014

The international EMF Project – Progress Report June 2013-2014

2014 (WHO, 2014)

World Cancer Report 2014 (Stewart & Wild, 2014)

Research 2014: 16 Ninth report from SSM:s Scientific Council on Electromagnetic Fields

2014 (SSM:S Scientific Council on Electromagnetic Fields, 2014)

A Review of Safety Code 6 (2013): Health Canada’s Safety Limits for Exposure to Radiofrequency Fields.

2014 (Demers, et al., 2014)

The current standing of the WHO is that “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” (WHO, 2013).

Ø The role of ICNIRP

ICNIRP is formally recognized by the WHO and its primary objective is to evaluate scientific research and provide guidelines recommending the limits of EMF exposure. All research done on non-ionising radiation is reviewed periodically by ICNIRP and its standards are updated as proven necessary by the research. Updated guidance from ICNIRP and WHO are expected to be published at the end of 2014/start of 2015 (ARPANSA, 2014).

ICNIRP standards are determined based on all published, peer reviewed research done on short term exposure. Available scientific information on the long term exposure to EMF fields is considered to be insufficient to establish quantitative limits (ICNIRP, 2010). Although epidemiological studies have found that everyday chronic low-intensity power frequency magnetic field exposure is associated with an increased risk of childhood leukemia, it has not been supported by laboratory studies. The causal relationship between magnetic fields and childhood leukemia

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and any other long term effect have not been established. For this reason the long term effect has not been addressed in the basic restrictions of ICNIRP (ICNIRP, 2010).

Therefore, the international guidelines proposed by ICNIRP are adjusted to 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 for human exposure. ICNIRP uses a reduction factor of

• 10 times to derive at occupational limits for workers and

• a factor of about 50 times to arrive at exposure limits for the public (ICNIRP, 2010).

This factor serves as a precautionary buffer to compensate for uncertainties in the research.

Ø The Namibian Context

The protection of the environment and people against the harmful effects of radiation is regulated by the Atomic Energy and Radiation Protection Act (Act no 5 of 2005). Section 43 (3) of the Act specifically makes reference to the standards published by ICNIRP:

“Regulations made under subsection (1) must take due account of any guidelines or standards published by the International Commission on Radiological Protection, the International Commission on Non-ionising Radiation, the International Atomic Energy Agency or other relevant international organisations. (3) The Minister may incorporate the guidelines established and published by the International Atomic Energy Agency, World Health Organisation, the International Commission on Radiological Protection or the International Commission on Non-Ionising Radiation or any other standards or guidelines published by any international organisation into regulations made under this section by reference. (4) The Minister may incorporate such standards or guidelines with such amendments as he or she thinks fit.”

Pursuant to Section 43 The Electromagnetic Fields Exposure Regulations have been drafted with the specific purpose of:

i. Minimizing the exposure of persons to the harmful effects of non-ionizing radiation; and

ii. Creating the regulatory framework for the control and regulation of sources of non-ionizing radiation.

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These draft regulations have been formulated from the WHO Model Regulations for EMF protection which is based on the ICNIRP Guidelines.

The National Radiation Protection Authority acknowledges that ICNIRP standards are based on short-term exposure of EMF and advises the adoption of precautionary principles (Eiman, 2015. Pers Com.). For further information see Appendix G.

5.3.3 Potential effects on property values

In 2012, Enviro Dynamics conducted a similar EIA and to determine the effect of the current project on neighbouring properties, two valuators in Windhoek were contacted1. Both valuators indicated that the presence of BTS sites close to a property does not affect the valuation of the property and this is still the case today. 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.

1 Pers. communication: Anonymous, private property valuator, 15 October 2012. Pers. communication: Anonymous, FNB property valuator, 15 October 2012.

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6 CONCLUSIONS AND RECOMMENDATIONS

The negative impacts with a medium significance rating have been identified.

Mitigation measures have been devised and outlined above to address these so as to ensure that this project (if granted Environmental Clearance) is implemented in the most sustainable way possible. All impacts discussed above will be addressed in the EMP (Appendix B). The key impacts and their mitigation measures are summarised below:

• Non-thermal health impacts of EMF exposure: No consistent evidence exists that substantiate the claim that the non-thermal effects of exposure to EMF from BTSs increases cancer risk. The World Health Organization’s (2012) official stance is that “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.” (WHO, 2013). In the absence of consistent evidence for these claims however the current ICNIRP (2010) standards will be used to inform safe exposure limits for residential and occupational areas. The ICNIRP standards hold to the precautionary principle and has been applied in compiling the safe exposure limits.

Until such time that the National Radiation Protection Authority of Namibia has published specific directives for dealing with non-thermal, long and short term exposure of BTS structures, the limits set by ICNIRP should apply to the Namibian context. 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 and by adhering to the standards set by ICNIRP, the risks are expected to be minimal.

• Impact on property value: 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, 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.

It is the opinion of Enviro Dynamics that sufficient information is available to address all impacts identified during this Scoping-Level EIA through the recommended mitigation and management actions for the construction, operation and decommissioning phases of the proposed project. If the recommendations included in this report and the EMP is implemented, the significance of the impacts can be reduced to reasonably acceptable standards and durations.

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7 REFERENCES

American Cancer Society (ACS). (2014, 02 12). Cellular Phone Towers. Retrieved 12 16, 2014, from American Cancer Society: http://www.cancer.org/cancer/cancercauses/othercarcinogens/athome/cellular-phone-towers

ANSES . (2013). Opinion of the French Agency for Food, Environmental and Occupational Health and Safety concerning the update of the "Radiofrequency electromagnetic fields and health" expert appraisal. Maisons-Alfort: French Agency for Food, Environmental and Occupational Health and Safety.

Australian Radiation Protection and Nuclear Safety Agency (ARPANSA). (2014). Review of Radiofrequency Health Effects Research - Scientific Literature 2000 - 2012. Yallambi: ARPANSA Radiofrequency Expert Panel.

BC Centre for Disease Control. (2013). Radiofrequency Toolkit for Environmental Health Practitioners. Vancouver, Canada: Environmental Health Services.

Demers, P., Findlay, R., Foster, K. R., Kolb, B., Moulder, J., Nicol, A.-M., et al. (2014). A Review of Safety Code 6 (2013): Health Canada's Safety Limits for Exposure to Radiofrequency Fields. Ottawa: Royal Society of Canada.

Eiman, J. (2015, January 29). The directive of the Atomic Energy Board of Namibia on non-ionising radiation from EMF. (E. Carstens, Interviewer)

Health Protection Agency. (2012). Health Effects from Radiofrequency Electromagnetic Fields: Report of the independent Advisory Group on Non-ionising Radiation. London: Health Protection Agency.

IARC. (2006). IARC Monographs on the Evaluation of Carcinogenic Risks to Humans. Lyon, France: World Health Organization .

ICNIRP. (2010). ICNIRP Guidelines for limiting exposure to time-varying electric and magnetic fields (1Hz - 100 kHz). Health Physics , 99 (6), 818-836.

ICNIRP. (2014). International Commission on Non-Ionizing Ratiation Protection. Retrieved December 12, 2014, from Low Frequency: 1 Hz - 100 kHz: http://www.icnirp.org/en/frequencies/low-frequency/index.html

International Agency for Research on Cancer. (2013). Non-ionizing radiation, Part 2: Radiofrequency electromagnetic fields, Volume 102. Lyon, France: IARC Working Group.

Mobile Telecommunications and Health Research Programme (MTHR). (2012). Report. England: MTHR Programme Management Committee.

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MTHR Programme Management Committee. (2012). Mobile Telecommunications and Health Research Programme: Report 2012. Public Health England.

SSM:S Scientific Council on Electromagnetic Fields. (2013). Research 2013:19 - Eight report from SSM:S Scientific Council on Electromagnetic Fields. Stockholm: Swedish Radiation Safety Authority.

SSM:S Scientific Council on Electromagnetic Fields. (2014). Recent Research on EMF and Health Risk - Ninth report from SSM's Scientific Council on Electromagnetic Fields. Sweden: Research.

Stewart, B. W., & Wild, D. P. (2014). World Cancer Report . Lyon France: IARC.

World Health Organization. (2002). Establishing a dialogue on risks from electromagnetic fields. Switzerland: WHO Library Cataloguing-in-Publication Data.

WHO. (2007, June). World Health Organization. Retrieved December 12, 2014, from Electromagnetic fields and public health: Exposure to extremely low frequency fields: http://www.who.int/peh-emf/publications/facts/fs322/en/

WHO. (2013, September 20). Retrieved December 10, 2014, from World Health Organization: http://www.who.int/features/qa/30/en/

WHO. (2014). International EMF Project - Progress Report 2013-14. WHO.

WHO. (2015). World Health Organization. Retrieved December 12, 2014, from Electromagnetic fields (EMF): http://www.who.int/peh-emf/about/WhatisEMF/en/index1.html

Environmental Information Service Namibia, 2014. Powerlines and birds assessment tool. [Online] Available at: http://www.the-eis.com/ [Accessed 1 December 2014].

ICNIRP, 2009. Exposure to high frequency electromagnetic fields, biological effects and health consequences (100 kHz-300 GHz), Germany: International Commission on Nono-Ionizing Radiation Protection (ICNIRP).

International Commission on Non-Ionising Radiation Protection, 1998. ICNIRP Guidelines for Limiting Exposure to Time-Varying Electric, Magnetic and Electromagnetic Fields (up to 300 GHz). Health and Physics, 74 (4), p. 494‐522.

Khurana, V. G. et al., 2010. Epidemiological Evidence for a Health Risk from Mobile Phone Base Stations. International Journal of Occupational and Environemental Health, Volume 16, p. 263–267.

Mendelsohn, J., Jarvis, A., Roberts, C. & Robertson, T., 2009. Atlas of Namibia. 3rd ed. Cape Town: Sunbird Publishers.

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Mobile Operators Association, 2012. Mobile Operators Association. [Online] Available at: http://www.mobilemastinfo.com/base-stations-and-masts/ [Accessed 10 October 2012].

Other Sources

BioInitiative Working Group. (2012). BioInitiative Report: A Rationale for Biologically-based Public Exposure Standards for Electromagnetic Radiation. Retrieved December 12, 2014, from BioInitiative 2012: www.bioinitiative.org

Jamieson, I. (2014). RF/Microwave Radiation - Risk Awareness.

Gomez-Perretta, C., Navarro, E. A., Segura, J., & Portoles, M. (2013). Subjective symptoms related to GSM radiation from mobile phone base stations: a cross-sectional study. British Medical Journal .

Scientific Committee on Emerging and Newly Identified Health Risks. (2013). Potential health effects of exposure to electromagnetic fields (EMF). Luxembourg: European Commission.

Swedish Radiation Protection Foundation. (2014, April 16). Comments on the SCENIHR preliminary opinion on 'Potential health effects of exposure to electromagnetic fields (EMF) approved at the 4th plenary of 12 December 2013. Luxembourg, Sweden. Retrieved from http://www.emfacts.com/2014/05/further-critique-of-the-scenihr-spin/

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