Five Mini BTS sites in Ludwigsdorf, · PDF file2.1 What is a cellular system? ... for the erection of telecommunication ... intends to construct five 3G Mini Base Transceiver Stations

Draft Environmental Scoping report

Five Mini BTS sites in Ludwigsdorf, Windhoek

November 2012

Five Mini BTS sites in

Ludwigsdorf, Windhoek

Draft Environmental Scoping

Report

November 2012



November 2012

COPYRIGHT © ENVIRO DYNAMICS, 2012. ALL RIGHTS RESERVED

PROJECT NAME Environmental Scoping Report for the proposed construction of

five mini BTS towers in Ludwigsdorf, Windhoek

STAGE OF REPORT Draft Environmental Scoping Report for Public review

CLIENT AGA Technical Services (PTY) LTD

Enquiries: Willem Horn

Tel: (061) 247 872

E-Mail: [email protected]

LEAD CONSULTANT Enviro Dynamics

Enquiries: Eloise Carstens

Tel: (061) 223-336

E-Mail: [email protected]

DATE OF RELEASE November 2012

AUTHOR Eloise Carstens, Eddy Kuliwoye, Lester Harker, Lahya Haitembu

Internal Reviewer: Norman Van Zyl

mailto:[email protected]


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November 2012

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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November 2012

TABLE OF CONTENTS

LIST OF TABLES AND FIGURES .................................................................................................. vi

ABBREVIATIONS AND ACRONYMS ....................................................................................... viii

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

1.1 Background .................................................................................................................. 1

1.2 Terms of Reference ...................................................................................................... 1

2 BACKGROUND TO CELLULAR INFRASTRUCTURE .............................................................. 3

2.1 What is a cellular system? ........................................................................................... 3

2.1.1 Cells ......................................................................................................................... 3

2.1.2 Base Station ........................................................................................................... 4

2.2 Concluding remarks on this section .......................................................................... 5

3 PROJECT DESCRIPTION ....................................................................................................... 6

3.1 Rationale for the proposed project ........................................................................... 6

3.2 Proposed locality.......................................................................................................... 8

3.3 The alternatives .......................................................................................................... 11

3.3.1 Tower sharing ....................................................................................................... 11

3.3.2 Alternative site locations .................................................................................... 11

3.3.3 Alternative technology ...................................................................................... 11

3.4 Infrastructure requirements ....................................................................................... 14

3.5 Concluding remarks on this section ........................................................................ 15

4 LEGAL AND REGULATORY REVIEW .................................................................................. 16

5 AFFECTED ENVIRONMENT ................................................................................................. 22

5.1 General description ................................................................................................... 22

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November 2012

5.2 Social environment .................................................................................................... 22

5.3 Existing background radiation ................................................................................. 26

6 PUBLIC CONSULTATION PROCESS ................................................................................... 29

6.1 Legal and Policy requirements ................................................................................ 29

6.1.1 Environmental Management Act (Act 7 of 2007) and Regulations (2012) 29

6.1.2 Policy for the erection of telecommunication facilities in Windhoek

(2008) .................................................................................................................... 30

6.1.3 Best practice (as described by the world health organization) .................. 31

6.2 Consultation process followed during the EIA ....................................................... 31

6.3 Limitations of the public participation process ...................................................... 32

6.4 The interested and affected parties (I&APS) ......................................................... 32

6.4.1 The Industry - MTC ............................................................................................... 33

6.4.2 Public .................................................................................................................... 34

6.4.3 Service complaints .............................................................................................. 35

6.4.4 Government ........................................................................................................ 36

6.4.5 Public interest groups ......................................................................................... 37

6.4.6 Media.................................................................................................................... 37

6.4.7 Electromagnetic Field (EMF) specialist ............................................................ 37

6.5 Outcome of the public participation process ....................................................... 38

6.5.1 History between MTC and Ludwigsdorf ........................................................... 38

6.5.2 Perceived risks vs. perceived benefits ............................................................. 39

6.6 The key issues .............................................................................................................. 40

6.7 Concluding remarks on this section ........................................................................ 41

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7 IMPACT ASSESSMENT ......................................................................................................... 32

7.1 Methodology employed for the impact assessment ........................................... 32

7.2 Identification of key issues ........................................................................................ 34

7.3 Economic implications .............................................................................................. 43

7.3.1 Background to the need for the project ......................................................... 43

7.3.2 Potential effects of the project ......................................................................... 44

7.3.3 Significance ......................................................................................................... 44

7.4 Disappearance of bees ............................................................................................ 45

7.4.1 Background to the problem .............................................................................. 45

7.4.2 Potential effects from Electromagnetic Radiation (EMR) ............................. 45

7.4.3 Significance of the current project .................................................................. 46

7.4.4 Mitigation measures ........................................................................................... 46

7.5 Reduction in property value ..................................................................................... 47

7.5.1 Background to the problem .............................................................................. 47

7.5.2 Potential effects on property values ................................................................ 47



7.6 EMF exposure .............................................................................................................. 49

7.6.1 Background to EMF ............................................................................................ 49

7.6.2 Potential biological and health effects associated with EMF ...................... 50

7.6.3 EMf exposure guidelines and policies .............................................................. 53

7.6.4 Compliance of the proposed project with exposure limits .......................... 54


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8 CONCLUSIONS AND RECOMMENDATIONS ................................................................... 57

8.1 The EIA and public consultation process ................................................................ 57

8.2 Synopsis of the key issues .......................................................................................... 58

8.3 Recommendations .................................................................................................... 59

8.3.1 Considering the no-project alternative ........................................................... 60

8.3.2 Recommendations ............................................................................................. 61

8.4 Final Recommendation ............................................................................................. 62

9 BIBLIOGRAPHY ................................................................................................................... 63

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LIST OF TABLES AND F IGURES

Table 3-1: Description of the five proposed sites. .......................................................... 10

Table 5-1: Description of the social environment surrounding each of the

proposed sites. ................................................................................................. 24

Table 5-2: Ambient RF exposure levels measured at sites in the Ludwigsdorf area

in % below ICNIRP standards. ......................................................................... 26

Table 6-1: Public consultation process followed during the EIA. ................................. 29

Table 6-2: Authorities involved in this project. ................................................................ 36

Table 6-3: Main issues of concern. ................................................................................... 40

Table 7-1: Definition of each of the criteria used to determine the significance of

the impacts ....................................................................................................... 32

Table 7-2: Definitions of the various significance ratings .............................................. 33

Table 7-3: Identification of key impacts. ......................................................................... 43

Table 7-4: Expected significance of the economic implications................................ 44

Table 7-5: Expected significance of the impact on bees ............................................ 46

Table 7-6: Expected significance of the project on property prices. ......................... 48

Table 7-7: Different types of electromagnetic radiation (adapted from (World

Health Organization, 2002) ............................................................................. 49

Table 7-8: Predicted maximum exposure summary at 1.5m above ground level. .. 55

Table 7-9: Expected significance of EMF exposure from the five proposed sites. .... 55

Figure 2-1: Extent of reach of each of the type of cells (Mobile Operators

Association, 2012). ............................................................................................. 3

Figure 2-2: Proximity to base station is one of the factors that influence signal

strength (Mobile Manufacturers Forum, 2008). .............................................. 4

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November 2012

Figure 3-1: Possition of macro BTS sites close to Ludwigsdorf. ......................................... 6

Figure 3-2: The current coverage in the area provided by the existing macro BTS

sites (A) will be improved by the construction of the proposed five mini

BTS sites (B). Red circles indicate the grouped locations from where

the customer complaints were lodged. ......................................................... 7

Figure 3-3: Location of the five proposed mini Base Station sites .................................. 9

Figure 3-4: Example of a mini BTS in Windhoek. .............................................................. 12

Figure 3-5: Proposed ground plan for the five mini BTS.................................................. 12

Figure 3-6: Pole Structure ................................................................................................... 13

Figure 3-7: A non-scientific depiction of the signal propagation of Omni and

Directional antennae (view from above)................................................... 13

Figure 5-1: The topography of Ludwigsdorf. Note that the proposed sites are

located on the shadow sides of slopes. ...................................................... 23

Figure 5-2: Surrounding land use activities in the area, based on the Windhoek

Town Planning Scheme of 2007 (as amended in draft 2012 version

(No.91)). ............................................................................................................. 25

Figure 6-1: Posters were put up at a conspicuous place close to each of the sites. 30

Figure 6-2: Fourty-six people attended the scheduled public meeting. .................... 31

Figure 6-3: Key role players identified on this project. ................................................... 33

Figure 6-4: Answers obtained for the questions asked during the public meeting. .. 35

Figure 6-5: Overlay of the groupings of people that complained about the

service vs. people that oppose the project. ................................................ 32

Figure 7-1: Screening process to determine key issues .................................................. 34

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November 2012

ABBREVIATIONS AND ACRONYMS

AM Amplitude Modulation

BID Background Information Document

BTS Base Transceiver Station

CCD Colony Collapse Disorder

COW City of Windhoek

CRAN Communications Regulatory Authority of Namibia

CV Curriculum Vitae

EIA Environmental Impact Assessment

ELF Extremely Low Frequency

EMF Electromagnetic Field

EMP Environmental Management Plan

EMR Electromagnetic Radiation

FM Frequency Modulation

I&APs Interested and Affected Parties

IARC International Agency for Research on Cancer

MET Ministry of Environment and Tourism

MTC Mobile Communications Company

NBC Namibian Broadcasting Corporation

NCC Namibia Communications Commission

Non-Ionising Electromagnetic radiation that does not carry enough energy

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November 2012

Radiation per quantum to ionise atoms or molecules.

RF Radiofrequency Radiation

SCENIHR Scientific Committee on Emerging & Newly Identified Health

Risks

UMTS Universal Mobile Telecommunications Systems

WHO World Health Organisation

Wi-Fi Wireless Fidelity

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November 2012

1 INTRODUCTION

1.1 BACKGROUND

With the increasing growth in the use of mobile communication in Windhoek, service

providers such as MTC are under pressure to continuously expand their networks.

MTC argues that by providing additional capacity in areas that suffer from

congestion or poor coverage, the quality of the service provided is greatly

enhanced. It is for this reason that MTC intends to construct five 3G Mini Base

Transceiver Stations (BTS) in Ludwigsdorf, Windhoek.

In accordance with the Environmental Management Act (2007) and its Regulations

(2012) an Environmental Impact Assessment (EIA) is required for the “construction of

masts of any material or type and of any height, including those used for

telecommunication broadcasting and radio transmission”.

Enviro Dynamics has been appointed to conduct an EIA and develop an

Environmental Management Plan (EMP) for the proposed masts. Eloise Carstens and

Norman Van Zyl are the Environmental Assessment Practitioners that conducted the

EIA. Their CVs are attached as APPENDIX A.

1.2 TERMS OF REFERENCE

The Terms of Reference for the proposed project is based on the requirements set out

by the Environmental Management Act (2007) and its Regulations (February 2012).

The process covered the following steps, which are reported on in this document as

follows:

Provide a detailed description of the proposed activity;

Identify all legislation and guidelines that have reference to the proposed

project;

Identify existing environmental (both bio-physical and socio-economic)

conditions of the area in order to determine their environmental sensitivity;

Inform Interested and Affected Parties (I&APs) and relevant authorities of the

details of the proposed development and provide them with a reasonable

opportunity to participate during the process;

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November 2012

Consider the potential environmental and social (including biological) impacts

of the development, and assess the significance of the identified impacts.

Outline management and mitigation measures in an Environmental

Management Plan (EMP) to minimize and/or mitigate potentially negative

impacts.

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November 2012

2 BACKGROUND TO CELLULAR INFRASTRUCTURE

2.1 WHAT IS A CELLULAR SYSTEM?

Networks are designed to ensure that mobile phones maintain a link with the network

as users move from one cell to another.

2.1.1 CELLS

Each individual geographic area in a network is called a 'cell'. At the heart of the cell

is a base station. The cells overlap at the edges to prevent holes in coverage. If base

stations are too far apart, calls cannot be handed over from one area to another

and are interrupted or 'dropped' when mobile users are on the move (Mobile

Operators Association, 2012).

There are three types of cells (Figure 2-1):

Macrocell: Provides the main coverage in a network. Typically constructed on

higher ground so that it is not obstructed by surrounding buildings and terrain.

The base station on Bowker Hill is an example of a macrocell.

Microcell: Provides infill coverage and additional capacity where there are a

high number of users in a macrocell. It is constructed at street level, usually

between 300 m and 1000 m apart. The sites proposed in this study are all

microcells.

Picocells: Provides localised coverage and are usually less visible. They are put

up in shopping centres and airports to strengthen the signal.

Figure 2-1: Extent of reach of each of the type of cells (Mobile

Operators Association, 2012).

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November 2012

2.1.2 BASE STATION

To communicate with each other mobile phones and base stations exchange radio

signals. When a mobile phone is switched on, it searches for a signal from nearby

base stations. As soon as a suitable base station has been located and a signal

established, it maintains a network connection (Swedish Post and Telecom Agency,

2008). The power level generated by a mobile phone to maintain a good

connection depends on the distance from the base station; the greater the

distance, the more power is needed. Mobile phones automatically step down to the

lowest power level that maintains communication with the base station. The power

output is therefore less when the base station is close to the phone user. Hence,

base stations are being placed closer together, to make it simpler for a phone and a

base station to communicate reliably.

Each base station is configured to cope with a certain number of calls being made

at the same time. When there are too many sources sending data simultaneously, it

may become too much for the network to handle (Mobile Operators Association,

2012). When this happens, the network slows down or starts loosing data, a

phenomenon known as network congestion. It degrades the quality of the service

and can lead to delays, lost data or dropped calls on a telephone network. The

situation is worse during peak times such as the holiday seasons when there are large

volumes of text messaging and voice traffic. This is just one of the reasons why one

single base station cannot serve an entire area.

In order to ensure the lowest risk of interference between base stations in the

network, operators have to keep their RF power outputs to the lowest possible level

that could still provide effective service provision (United Kingdom: Department for

Communities and Local Government, 2001).

Figure 2-2: Proximity to base station is one of the factors that influence signal strength (Mobile Manufacturers Forum, 2008).

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November 2012

Depending on the number of cellphone users at any one time and the distance of

these users to the nearest base station, the power output from the base station is still

likely to fluctuate throughout the day.

2.2 CONCLUDING REMARKS ON THIS SECTION

In this section background information was provided to explain how cellphone

networks work and why base stations are needed at specific positions.

The following section provides the details of what MTC proposes for this specific

project.

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November 2012

3 PROJECT DESCRIPTION

3.1 RATIONALE FOR THE PROPOSED PROJECT

Worldwide, mobile experiences are becoming increasingly faster. Service providers

such as MTC are not only under constant pressure to provide good quality voice and

data services to their customers but also to keep up with international standards. The

aim is therefore to provide a wider range of services from which to choose whilst

providing reasonable access to the latest technologies as they become available.

The services that MTC provides are demand-led. The constant increase in cellphone

users requires MTC to continuously expand their networks to accommodate

customer requirements of service and quality. The need for base stations is usually

concentrated in built-up areas where the greatest density of cellphone users is, and

close to main roads, where the demands on network capacity are greatest.

Accordingly, the Ludwigsdorf area currently relies primarily on coverage from three

macrocells, namely that created by the BTS at Hidas, Bowker Hill and the NBC Tower

(Figure 3-1).

Figure 3-1: Possition of macro BTS sites close to Ludwigsdorf.

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November 2012

Unfortunately, due to the ever increasing number of service users in the area

(currently estimated at more than 2700 in the Ludwigsdorf area), these macro sites

are subjected to high traffic and are therefore severely congested. The undulating

landscape further causes poor coverage on the shadow side of slopes (Figure 3-2).

The reality of the problem is portrayed in the number of customer complaints

received by MTC in this area (APPENDIX B).

It is for this reason that MTC is proposing the construction of five mini BTS sites (for 3G

not 4G). These sites will provide infill coverage in areas that are not currently

covered and will provide additional capacity where congestion is experienced in a

macrocell (Figure 3-2). This will not only result in improved services for MTCs

customers, but will also provide:

Additional capacity.

Improvement of existing coverage.

Resolution of customer complaints.

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November 2012

Figure 3-2: The current coverage in the area provided by the existing macro BTS sites (A) will be improved by the construction of the proposed five mini BTS sites (B). Red circles indicate the grouped locations from where the customer complaints were lodged.

A B

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November 2012

3.2 PROPOSED LOCALITY

Based on technical investigations MTC identified optimal sites that are motivated by

quality, coverage and statistical analysis. These investigations were focused

specifically on addressing the issues of dropped calls and problematic coverage

experienced in the area. MTC wishes to fill this telecommunication gap by providing

the most optimal and complete network coverage in the area through the proposed

sites.

However, when selecting the most appropriate site for the construction of a base

station, it is not only the existing network infrastructure that determines the

positioning, but also the following:

Surrounding topography and built-up environment

Established and future urban area

The required footprint, and

The design of the facility.

By considering the above criteria, MTC has decided upon the five locations in

Ludwigsdorf as illustrated in Figure 3-3 below.

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November 2012

Figure 3-3: Location of the five proposed mini Base Station sites

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November 2012

The description of each of these sites is provided in Table 3-1 below:

SITE NAME COORDINATES DESCRIPTION OF SITE PURPOSE

Mission Road S22.57090

E17.11310

On the western side of

Mission Road

To provide coverage in

the area not currently

covered by NBC and the

Cone Towers.

Gloudina Road S22.56870

E17.11880

On the corner of

Gloudina and Babs

street, next to the

power transformer

building yard.




Cone Towers.

Kwame Road S22.56520

E17.11310

On the southern side of

Kwame Street




Cone Towers.

Hebenstreit S22.56820

E17.10950

On the corner of

Hebenstreit and

Willemien Street

To cover the area not

covered by the NBC and

Cone towers, as well as to

serve the commercial

establishment across the

road and the Chinese

embassy.

Reuning S22.56650

E17.10480

Outside the Lutheran

church yard on

Reuning Street

To cover the area not

covered by the NBC and

Cone towers, as this area

is situated in a depression

behind the mountains on

which the above

mentioned towers are

built, thus prohibiting

signal propagation.

Table 3-1: Description of the five proposed sites.

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November 2012

3.3 THE ALTERNATIVES

3.3.1 TOWER SHARING

In terms of the Communications Act of 2009, service providers are required to first

consider sharing existing infrastructure in the area, before constructing new

structures. Neither Leo nor Telecom has structures in the area that could possibly be

shared. Buildings were considered but will not serve the specific needs of the

customers and MTC.

3.3.2 ALTERNATIVE SITE LOCATIONS

The siting of a potential BTS site is affected by surrounding obstructions e.g. hills,

buildings and trees, as well as the curvature of the earth and differing atmospheric

conditions. MTC did investigate all possible options when determining the proposed

locations but two major limitations were encountered. Firstly, the problem area is

located in a residential zone which limits the available space to construct the base

stations in relation to the specific coverage needs. Secondly, the undulating

topography creates “dead zones” on the shadow side of slopes. This inhibits optimal

coverage in the area. The proposed mini sites have a small and specific coverage

area and have thus specific locations from where optimal coverage will be

achieved. The sites could be moved a couple of meters if needed.

3.3.3 ALTERNATIVE TECHNOLOGY

To determine the best technology for the specific project it is important to

understand the options that are available and what the limitations and advantages

of each are:

Mini vs. Macro BTS sites

A Base Transceiver Station (BTS) refers to the electronic equipment that facilitates

wireless communication between the user and the network. It consists of a number

of components including a transceiver and amplifier. Mini/macro refers to the size of

the container in which this equipment is stored as well as the coverage area it

provides.

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November 2012

Figure 3-4: Example of a mini

BTS in Windhoek.

The number and size of the equipment stored on a macro site is much more than

that of a micro site. Because of the heat emitted from the equipment air

conditioners are required to cool it down. Macro sites provide more options for

expanding the coverage capacity but due to the size of the equipment it requires a

larger footprint area and is often visually obtrusive. The antennae should also be

located higher from the ground than what is required for the mini BTS. This means

that macro BTS are usually either constructed on elevated ground (increasing the

visual impact) or on structures of more than 15 m high (increasing the visual impact

and the risk of civil aviation interference).

Mini BTS, on the other hand, are usually confined to

compact containers with a footprint area of no more

than 1 or 2 meters (Figure 3-4). The BTS equipment and

the pole to which the antenna is attached are

contained in a small enclosure (with palisade fencing)

to preventing unauthorized access. The overall size of

the equipment makes it visually more acceptable than

macro BTS. These sites are however restricted in the

number of antennae or radios it can accommodate

and consequently a higher concentration of sites is

needed to transmit the signal in the area.

Due to the longer transmission range of macro BTS another macro site in the project

area could cause interference with the existing macro sites (i.e. NBC, Cone, Hidas

and Bowker Hill) and thus compromise on the quality

of the signal. For this reason MTC is proposing the

construction of five

mini BTS (Figure

3-5). The localized

coverage of the

mini BTS provides

good quality

services for a small

area.

Figure 3-5: Proposed ground plan for the five mini BTS.

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November 2012

Pole structure vs. other BTS structures (e.g. steel lattice, monopole)

A number of BTS structures are available that are commonly associated with macro

BTS. The heights of these vary considerably depending

on the requirements of the specific project. As soon as

the height exceeds 15 m it is standard practice to

consider the implications on Civil Aviation. Should it be

required by the Directorate of Civil Aviation, these

structures could be painted red and white to make it

more visible.

For this project, pole structures are proposed. The height

of these poles is 9 m (a 3-storey building‟s height) with the

antenna mounted on top (for all of the proposed sites)

(Figure 3-6). It resembles the poles used for lampposts

(Lampposts are also normally 6 - 9 m high) and will have

a relatively low visual impact. The structure will be

mounted to a concrete foundation and will not require any supporting cables.

The physical assembling of the tower structure and the fence as well as the

construction of the foundations will take place on site by using manual labour as far

as possible. The structure will be earthed to protect it from lightning.

Directional vs. Omni Directional Antennae

Directional Antennae are designed to focus the signal in a particular direction over

greater distances (Figure 3-7). These antennae allow for increased performance

when transmitting and receiving information and ensure reduced interference from

unwanted sources. It is often used when a signal is to be submitted over a longer

distance through a number of obstacles such as buildings.

Figure 3-7: A non-scientific depiction of the signal propagation of

Omni and Directional antennae (view from above).

9 m

1 m

Figure 3-6: Pole Structure

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November 2012

1What is the UMTS 2100

frequency band?

The UMTS frequency bands

are used for the third

generation (3G)

communication networks.

The various bands are

deployed to different

regions. The 2100 band is

specifically assigned to

Africa.

Omni Directional Antennae on the other hand, are designed to provide 360 degree

coverage from one antenna instead of installing 3 panel antennas to provide the

same degree of coverage (Figure 3-7). It is used in instances where coverage is

needed in all directions from the antenna. Because of the dispersed nature of this

type of antenna, the signal is generally weaker and is therefore ideal to provide

coverage over short distances.

For this project, MTC proposes the use of Omni

Directional Antennae. These antennae provide

unidirectional cover over short distances. The specific

antenna is called Kathrein 741790 and they are

designed to operate in the UMTS 2100 frequency

band1.

The antenna is 2000 mm high and 200 mm wide with a

power output of 20 Watt and 0° electrical tilt and -5°

mechanical tilt (i.e. the antennae will be tilted slightly

towards the ground to optimize coverage).

The equipment used by MTC must adhere to the standards set by the European

Telecommunications Standards Institute (ETSI). ETSI is an independent, non-profit,

standardization organization in the telecommunications industry which endorses the

ICNIRP standards for EMF exposure (Cooper, Mann, Khalid, & Blackwell, 2004).

3.4 INFRASTRUCTURE REQUIREMENTS

In terms of infrastructure requirements, the following applies:

SITE NAME ROAD ACCESS ELECTRICITY TRANSMISSION

Mission Road Accessible from

Mission Road

Application to be

submitted to the City of

Windhoek‟s electricity

department.

Transmission – connection

between BTS and Base

Station Controller (BSC).

Transmission will be

provided by means of a

MTC microwave.

Gloudina Road Accessible from

Gloudina and Babs

street.

Kwame Road Accessible from

Kwame Road

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November 2012

SITE NAME ROAD ACCESS ELECTRICITY TRANSMISSION

Hebenstreit Accessible from

Hebenstreit and

Willemien Street.

Reuning Accessible from

Reuning street.


In this section of the report the need for the proposed project was elaborated on

and the technical details of what is projected, including the location, the alternatives

and the design, were explained. In short, the following is proposed by MTC for this

project:

Five mini BTS sites in Ludwigsdorf,

The sites are for 3G not 4G and both data and voice services,

9 m high pole structures resembling a lamppost and an outdoor Huawei BTS

on a 1 m x 1 m footprint area enclosed with a palisade fence,

Omni directional antennae (Type Kathrein 741790) designed to operate in the

UMTS 2100 frequency band (Cagle, 2012).

The following section deals with the legal environment in which the proposed project

will be operated and specifies the relevance of the legislation to the project.

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4 LEGAL AND REGULATORY REVIEW

The following table provides a summary of all pertinent international and national standards, guidelines, policies and laws that are

of relevance to the project. It furthermore specifies the regulatory authority and provides the contact details of a knowledgeable

person in the field:

TOPIC LEGISLATION PROVISIONS REGULATORY

AUTHORITY APPLICATION TO PROJECT CONTACT PERSON

NAMIBIAN LOCAL LEGISLATION

Erecting

telecommunication

facilities in

Windhoek

City of Windhoek:

Policy for the erection

of

Telecommunication

facilities in Windhoek

(2008)

Provides uniform, clear

standards and assessment

criteria to assist the

development, control, design,

installation, appearance and

monitoring of

telecommunication facilities

within the City of Windhoek

area

City of Windhoek Provides clear guidelines to

the specific issues that should

be investigated during the

Environmental Assessment.

These include amongst

others, the visual impact,

anticipated electromagnetic

field exposure strength and

impact on Civil Aviation.

Promotes co-location or site

sharing of operators to

maximise the use of existing

network resources.

Promotes community

consultation with the

surrounding residents.

Environmental Division:

John Shilongo

Tel: 061 290 2491

Email:

[email protected]


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Use of sidewalks in

Windhoek

Local Authorities Act

23 of 1992 Section 50

(1b)

“A local authority council may

subject to such terms and

conditions….as may be

determined by the local

authority council, let or grant

the right to use temporarily, any

public place or part of a public

place or any street or portion

of a street closed in terms of

paragraph (a) to any person

for any period during the

period in which it is so closed;”

City of Windhoek MTC needs to apply to the

local authority council to

temporarily close off the site

on the sidewalk.


John Shilongo

Tel: 061 290 2491

Email:

[email protected]

NAMIBIAN NATIONAL LEGISLATION

Environmental

Assessment and

Management

Systems

Environmental

Management Act

(Act 7 of 2007), and

EIA Regulations

(2012):

Provides list of activities that

require an environmental

assessment, including:

“(k) The erection or

construction of communication

networks including towers,

telecommunication lines and

cables as well as structures

associated therewith including

roads”

Provides for adequate public

Ministry of Environment

and Tourism,

Directorate of

Environmental Affairs

Communication site triggers

an EIA.

Conduct public participation

as part of the EIA process

described in the act.

Dr Freddy Sikabonga

Tel: 061 284 2718

Email: [email protected]



18



participation during the

environmental assessment

process for interested and

affected parties to voice their

opinions about a project.

Broadcasting Communications Bill,

2009.

Promotes the sharing of

infrastructure of the dominant

carrier with other carriers.

Provides for the regulation of

telecommunications activities.

The Bill provides for licensing

and enforcement of

conditions, and the approval

of equipment and technical

standards to ensure public

health and safety.

Communications

Regulatory Authority of

Namibia (CRAN)

Encourage the sharing of

towers to avoid cumulative

impact.

Mr Stanley Shanapinda

Tel: 061 222 666

Email:

[email protected]

Namibian

Communications

Commission Act, Act

4 of 1992

Provides for the establishment

of the Namibia

Communications Commission

responsible to issue

broadcasting licenses, control

or supervises certain

broadcasting activities and

program content, and among

other activities is responsible for

Namibian

Communications

Commission (NCC),

Directorate

Communications

Provides the standards for

setting up cellular, wireless

and satellite services.

Mr Henri Kassen

Tel: 061 283 2486

Email:

[email protected]


19



the setting of specifications

and standards for new

technologies such as cellular,

wireless and satellite services.

Radiation The Atomic Energy

and Radiation

Protection Act, Act 5

of 2005:

Provides for the adequate

protection of the environment

and of people against the

harmful effects of radiation by

controlling and regulating the

production, processing,

handling, use, holding, storage,

transport and disposal of

radiation sources and

radioactive materials, and

controlling and regulating

prescribed non-ionising

radiation sources according to

the standards set out by the

ICNIRP.

Ministry of Health and

Social Services, Atomic

Energy Board of

Namibia

Used to determine the “safe

distance” around the site.

Mr Axel Tibinyane

Tel: 061 203 2416/7

Email:

[email protected]

a

INTERNATIONAL STANDARDS AND GUIDELINES

Non-ionizing

Radiation

“Guidelines for

Limiting Exposure to

Time-Varying Electric,

Magnetic, and

Provides international

standards and guidelines for

limiting the adverse effects of

non-ionising radiation on

The EMR levels

proposed by the

ICNIRP are endorsed

by Namibia.

Justifies the need for

assessing the impact of

electromagnetic radiation

from the towers, on the

Mr Axel Tibinyane

Tel: 061 203 2416/7

Email:



20



Electromagnetic

Fields (up to 300GHz)”

(April 1998

developed by the

International

Commission on Non-

Ionizing Radiation

Protection (ICNIRP))

human health and well-being,

and, where appropriate,

provides scientifically based

advice on non-ionising

radiation protection including

the provision of guidelines on

limiting exposure. ICNIRP

exposure limits for non-ionizing

radiation is 4.5W/m².

nearby residents. [email protected]

a

World Health

organization

Health and safety of

wireless networks – A

guide to local

authorities (Draft,

2012)

Intended to help local

authorities understand the

different types of wireless

networks and the infrastructure

they need. Furthermore, it

provides an overview of the

health and safety issues

involved with wireless networks.

Locally enforced by

the City of Windhoek.

Provides background

information to wireless

networks and research on

potential health effects and

exposure standards.


John Shilongo

Tel: 061 290 2491

Email:

[email protected]



22



October 2012

5 AFFECTED ENVIRONMENT

In this chapter the status quo of the proposed project area is provided. It provides a

description of the biophysical conditions and the social environment as well as the

current background Electromagnetic Radiation emissions.

5.1 GENERAL DESCRIPTION

The five proposed sites are located in the higher income, low density, residential area

of Ludwigsdorf. The surrounding landscape comprises of undulating hills (Figure 5-1)

and although it forms part of a built-up area, some natural vegetation remains in the

non-perennial drainage lines flowing towards the Klein Windhoek River. When

overlaying the positions of the proposed BTS sites on the topographical map of the

surrounding area, one can clearly see that these sites are located on the shadow

side of slopes. This agrees with the rationale provided in the project description

(Section 3.1).

5.2 SOCIAL ENVIRONMENT

The social environment of the project area is made up of four land uses, namely:

Residential Houses various densities

Businesses and offices

Schools

Religious institutions (e.g. churches)

The position of these in relation to the proposed sites is discussed in Table below:

The land use activities indicated on Figure 5-2 are based on the draft amendment

scheme No. 91 of the Windhoek Town Planning Scheme (2007).

23



October 2012

Figure 5-1: The topography of Ludwigsdorf. Note that the proposed sites are located on the shadow sides of slopes.

24



October 2012

Table 5-1: Description of the social environment surrounding each of the proposed sites.

SITE NAME PHOTOGRAPHIC RECORD DESCRIPTION OF SURROUNDING

SOCIAL ENVIRONMENT

Mission Road

Site is proposed at intersection

of Herbst Street and Mission

Road.

Herbst Street is a cul de sac.

Surrounding land uses:

Primarily single storey

residential houses

The site is located on slightly

higher ground than Mission

Road.

Gloudina Road

Site is proposed in front of the

Gloudina pump station facility.


Primarily residential

double storey houses

The ground level of most

houses is higher than at the

site.

25



October 2012

SITE NAME PHOTOGRAPHIC RECORD DESCRIPTION OF SURROUNDING

SOCIAL ENVIRONMENT

Kwame Road

On the corner of Kwame and

Jeanette Street.


Primarily residential houses

(mixture of double and

single storey houses).

The ground levels of most

houses are higher than at the

site. South of the site, houses

are either on the same ground

level or lower.

Three schools are located less

than 600 m from the site.

Hebenstreit

On the corner of Hebenstreit

and Willemien Street.

Chinese Embassy to the south

Square park – businesses to the

east


Primarily residential houses

(mixture of double and

single storey houses).

Houses are on the same

ground level as the site.

Reuning

Next to the boundary of the

Evangelical Lutheran Church

In Namibia (ELCIN).


Primarily double storey

residential houses

Houses are on the same

ground level as the site.

25



October 2012

Figure 5-2: Surrounding land use activities in the area, based on the Windhoek Town Planning Scheme of 2007 (as amended in draft 2012 version (No.91)).

26



October 2012

5.3 EXISTING BACKGROUND RADIATION

To establish what the current radiation exposure in the project area is, including the

exposure from other BTS sites such as Hidas and the NBC site1, measurements were

taken at 25 positions close to each of the proposed BTS sites.

The findings indicate that the highest value measured is 0.1483% of the ICNIRP

General Public guidelines and were obtained at position 22 (Table 5-2). This is more

than 650 times below the General Population limit. See Appendix M for the detailed

description of the assessment and the findings.

Table 5-2: Ambient RF exposure levels measured at sites in the Ludwigsdorf area in % below

ICNIRP standards.

LOCATION TOTAL EXPOSURE CELLULAR EXPOSURE

The proposed position of the Mission

Road Mini site.

0.0025% 0.0002%

On the road in front of 52 Quenta Street. 0.0141% 0.0047%

On the driveway of 24 Dr. Kwame

Nkrumbah

0.0177% 0.0090%

In front of 2 Herbst Street at the end of

the cul de sac.

0.0036% 0.0010%

At the proposed position of the Gloudina

Road Mini site.

0.0027% 0.0004%

In front of 1A Babs street. 0.0016% 0.0003%

On the driveway of the house on the

corner of Olga and Portia streets,

opposite 19 Portia Street.

0.0119% 0.0028%

On the driveway of 39 Joseph Mukwayu

Ithana Street.

0.0072% 0.0008%

1 These measurements do not include exposure from Bowker Hill which was activated after

the Radiation assessment for this study was done.

27



October 2012


At the proposed position of the Kwame

Road Mini site.

0.0042% 0.0008%

On the corner of Dr. Kwame Nkrumah

Avenue and Jeanette Street.

0.0030% 0.0016%

In front of 73 Dr. Kwame Nkrumah

Avenue.

0.0049% 0.0029%

Opposite the proposed position of the

Kwame Road Mini site.

0.0061% 0.0013%

At the gate of 68 Dr. Kwame Nkrumah

Avenue.

0.0019% 0.0004%

At the proposed position of the

Hebenstreit site.

0.0091% 0.0047%

In front of 45 Hebenstreit Street, close to

the small gate.

0.0094% 0.0059%

In front of 38 Hebenstreit Street 0.0106% 0.0036%

In the courtyard of the Square Park

Shopping Centre, in front of the entrance

to Hugo Scheepers Architects.

0.0082% 0.0037%

At the proposed position of the Reuning

site.

0.0020% 0.0005%

Against the north-eastern corner of the

Lutheran Church building.

0.0055% 0.0019%

In front of the gate of 11 Reuning Street 0.0111% 0.0023%

On the driveway of 20 Reuning Street. 0.0103% 0.0040%

At the base of the Gevers Street Mobile

site.

0.1483% 0.1407%

Next to the entrance gate to 89 Dr.

Kwame Nkrumah Avenue Street.

0.0318% 0.0240%

Close to the Dr. Kwame Nkrumah

Avenue entrance of the Belvedere

0.0698% 0.0622%

28



October 2012


Guesthouse.

On the disabled parking, in front of the

steps leading to the East Side Baptist

Church entrance.

0.0044% 0.0030%

In the following section the procedure followed to inform the public is elaborated on.

It provides details on the legal procedures that were needed during the EIA process,

the limitations and the findings of the communications with the public.

29



October 2012

6 PUBLIC CONSULTATION PROCESS

6.1 LEGAL AND POLICY REQUIREMENTS

6.1.1 ENVIRONMENTAL MANAGEMENT ACT (ACT 7 OF 2007) AND REGULATIONS

(2012)

The Act and its newly passed regulations are the key protocols governing

environmental impact assessment in Namibia. One of the key objectives of the Act is

to prevent and mitigate the significant effects of activities on the environment by:

“(b) ensuring that there are opportunities for timeous participation of interested and affected

parties throughout the assessment process; and (c) ensuring that the findings of an

assessment are taken into account before any decision is made in respect of activities.”

In order to achieve this goal Section 21 of the Regulations specifies the following:

“(2) The person conducting a public consultation process must give notice to all potential

interested and affected parties of the application which is subjected to public consultation

by -

a) fixing a notice board at a place conspicuous to the public at the boundary or on the

fence of the site where the activity to which the application relates is or is to be

undertaken;

b) giving written notice to -

i. the owners and occupiers of land adjacent to the site where the activity is or is

to be undertaken or to any alternative site;

ii. the local authority council, regional council and traditional authority, as the

case may be, in which the site or alternative site is situated;

iii. any other organ of state having jurisdiction in respect of any aspect of the

activity; and

c) advertising the application once a week for two consecutive weeks in at least two

newspapers circulated widely in Namibia.

(3) A notice, notice board or advertisement referred to in subregulation (2) must -

a) give details of the application which is subjected to public consultation; and

b) state -

i. that the application is to be submitted to the Environmental Commissioner in

terms of these regulations;

30



October 2012

ii. the nature and location of the activity to which the application relates;

iii. where further information on the application or activity can he obtained: and

c) the manner in which and the person to whom representations in respect of the

application may be made.

(6) When complying with this regulation, the person conducting the public consultation

process must ensure that -

a) information containing all relevant facts in respect of the application is made

available to potential interested and affected parties; and

b) consultation by potential interested and affected parties is facilitated in such a

manner that all potential interested and affected parties are provided with a

reasonable opportunity to comment on the application.

28. For the purpose of the Act and these regulations a notice is given to a person or a person

is informed of a decision, if a document to that effect is -

(a) delivered personally to that person;

(b) sent by registered post to the persons last known address;

(c) left with an adult individual apparently residing at or occupying or employed at the

person’s last known address; or

(d) in the case of a business-

(i) delivered to the public officer of the business;

(ii) left with an adult individual apparently residing at or occupying or

employed at its registered address;

(iii) sent by registered post addressed to the business or its public officer at

their last known addresses; or

(iv) transmitted by means of a facsimile transmission to the person concerned

at the registered office of the business.”

6.1.2 POLICY FOR THE ERECTION OF TELECOMMUNICATION FACILITIES IN WINDHOEK

(2008)

In terms of communicating with the public, the Windhoek BTS policy requires:

“Community consultation with the surrounding residents that are living within a 50 meters

radius of the Base Transceiver Station….”.

This requirement is superseded by the 2010 Council Resolution which states that:

“The community consultation report should present a clear representation of community

information living within a radius of 300 metre.”

The policy does not specify how the consultation process should be undertaken.

31



October 2012

6.1.3 BEST PRACTICE (AS DESCRIBED BY THE WORLD HEALTH ORGANIZATION)2

The WHO (2002) describes communication with the public in four stages:

1. Analysing the risk:

Information is provided to the public while the potential risk of the proposed

project is researched and analysed.

Communication with Regional and Local Authorities and other Interested

and Affected Parties (I&APs).

2. Triggering Event:

Public awareness is raised through triggering events such as media

attention, organized activist intervention and word of mouth.

3. Taking action:

Communication is established through passive engagement techniques

(e.g. fact sheets, brochures) and active engagement techniques (e.g.

public meetings).

4. Evaluation of issues:

Evaluation of outcomes, distribution of documents (e.g. minutes of

meetings conducted).

6.2 CONSULTATION PROCESS FOLLOWED DURING THE EIA

Public Participation forms an important component of the Environmental Assessment

process. Communication with stakeholders about the proposed development was

facilitated through the following means (elaborated on in Table 6-1):

Sharing of information with stakeholders:

Newspaper adverts

Written notices

Notice boards

Information documents

Stakeholder meetings

Reasonable opportunity for the public to register and comment on the project.

2 World Health Organization, 2002. Establishing a dialogue on risks from electromagnetic fields. WHO

Library Cataloguing-in-Publication Data, Switzerland.

29



October 2012

Table 6-1: Public consultation process followed during the EIA.

DESCRIPTION OF PROCESS TIME ALLOWED

SHARING OF INFORMATION WITH PUBLIC

Identification of

stakeholders:

Key stakeholders (See Subsection 6.3.) were identified and included in a register

(APPENDIX C). The contact details of potential I&APs were obtained from the City

of Windhoek.

The register was maintained throughout the

process.

Newspapers

adverts:

Notices were placed in the press, briefly explaining the development and its

locality, inviting the public to register as stakeholders and informing them of the

time and venue of the public meeting (APPENDIX D).

On the 5th and 12th of September 2012 in The

Namibian and Republikein.

Written Notices: People living within a 300 m radius from each of the proposed sites were

consulted. This includes more than 600 erven. The information obtained from the

CoW was refined by identifying:

Owners with more than one property,

Government owned properties (e.g. Ministry Of Works and City of

Windhoek),

Building complexes.

Only one letter was printed per owner, government institution and body

corporate.

A total of 379 people were informed, by either:

Hand delivering information letters (APPENDIX E). No letters were placed in

gates and the recipient of the letter was requested to sign for it (APPENDIX F).

For 5 days – from the 4th of September 2012

to the 8th of September 2012. Letters were

delivered from 17h00 to 19h00 in the

30



October 2012


A total of 164 houses received hand delivered letters. evenings when most people were expected

to be at home.

Mailing information letters through registered post (APPENDIX G). Not all of

the identified I&APs could be reached through direct delivery. The most

recent postal addresses were therefore obtained from the CoW and mailed

through registered post (215 registered letters were sent).

Nampost (the postal service of Namibia)

stated that delivery within Windhoek takes 2

days. The letters were posted a week

before the public meeting.

Notice boards: In addition, posters (APPENDIX H) were placed close to each of the proposed sites

informing the public of the proposed project as well as the intended meeting

(Figure 6-1).

Put up on sites 3 weeks before the public

meeting.

Information

documents

A Background Information Document (BID) was compiled that contained the

information of the project (APPENDIX I). The BID was forwarded to all authorities

and registered stakeholders.

Continued throughout the process every

time someone registered.

Figure 6-1: Posters were put up at

a conspicuous place close to each of the sites.

31



October 2012


Meetings: A consultation meeting was held at the Eastside Baptist Church (corner of

Hebenstreit and Dr Kwame Nkrumah Street) on the 19th of September 2012

(Figure 6-2Error! Reference source not found.). Forty-six people attended the

eeting. The audience consisted of home owners, the media, MTC representatives

and some authorities from the Ministry of Health and Social Services and CRAN.

The main concern raised during this meeting was related to the health impacts

associated with cellphone towers, the lowering of property prices and the visual

impact of the structure. The documents (i.e. minutes, attendance lists and

presentations) to this meeting are attached in APPENDIX J.

Public meeting on the 19th of September

2012. Two weeks were allowed for

registrations before the public meeting.

An authorities meeting was also scheduled to which representatives from the

various divisions of the City of Windhoek and MTC were invited. Representatives

from the Environmental and Property Divisions attended. During the meeting the

proposed project was discussed as well as the EIA process and the concerns

raised by I&APs.

Authorities meeting on the 2nd of October

2012.

Figure 6-2: Fourty-six people attended the scheduled public meeting.

32



October 2012


OPPORTUNITY FOR PUBLIC TO COMMENT

The initial date for final comments was set for the 26th of September 2012, allowing

a one week comments period after the public meeting. After various requests

from the public to extend this period, the comments period was prolonged to the

3rd of October 2012. Some late registrations were received after this date, which

have also been included in the stakeholders register.

The total period allowed for comments from

the first placement of the adverts (5th of

September 2012) to the 3rd of October 2012

is 28 days. This does not include the

unofficial time allowed for after the 3rd of

October 2012.

32



October 2012

6.3 LIMITATIONS OF THE PUBLIC PARTICIPATION PROCESS

The process followed for the public participation was limited by a number of factors:

Delivering letters by hand is extremely time-consuming and although it ensures

that the residents do receive the information, some factors limit the effectiveness:

o People are on leave or not at home for the period Enviro Dynamics was

contacting them,

o Some houses currently don‟t have any residents,

o Some people refused to sign or receive the letters.

Addresses from CoW are out-dated and there is no way to proof that the owners

received the letters or how long it takes for them to check their mail.

Despite these limitations, the consultants are of the opinion that the various methods

of informing the public provided them with sufficient time to register as I&AP.

During the public issues and responses period, we received a notification that an

objection to the proposed project has been sent to the Directorate of Environmental

Affairs. The details of the official objection are included as part of the Issues and

Responses trail (APPENDIX K).

6.4 THE INTERESTED AND AFFECTED PARTIES (I&APS)

An I&AP can be defined as „(a) any person, group of persons or organization

interested in or affected by an activity; and (b) any organ of state that may have

jurisdiction over any aspect of the activity’ (MET, 2010).

The I&APs for this project were identified using information provided by the CoW and

the existing Enviro Dynamics stakeholder database. In addition, notices were placed

in various newspapers inviting the public to register as interested and affected

parties. Organizations were also selected whom the consultant considered to be

interested in or affected by this particular project. The results of this process are

displayed in Figure 6-3 below.

33



October 2012

The proposed project has received a great deal of public interest. It is therefore

important to understand not only the I&APs and the role they played during the

consultation process, but also their needs and concerns.

6.4.1 THE INDUSTRY - MTC

As service provider MTC has an obligation to their customers to provide a good

quality service. Telecommunication services are an advancing technology and

particularly the use of wireless communication services continues to develop at a

very rapid rate worldwide. Despite the technological advantages continuous

advancement pose for Namibia, it is crucial for MTC to involve the public in a

responsible way. They are therefore required to have a proactive and positive

approach to managing the risks associated with the industry.

KEY ROLE PLAYERS

Figure 6-3: Key role players identified on this project.

34



October 2012

6.4.2 PUBLIC

This group of I&APs includes any directly or indirectly affected member of the public.

It comprises nearby residents and neighbours (for the purpose of this EIA residents

living within a 300 m radius from the sites) as well as other individuals that do not

necessarily live close to the sites but that have an interest in the project. The most

contributions i.t.o. public concern came from this group and a total of 68 members

registered for the project. The group also contributed tremendously in terms of

sharing of information and informing others by means of e.g. word of mouth.

During the public meeting (attended primarily by members of this group), three

questions were posed and attendees were asked to provide an answer:

1. Do you experience call and data problems?

2. Do you want the status quo to continue?

3. Do you want further MTC development in principle?

As can be seen in Figure 6-4, the answers obtained from these questions indicate

two primary results3. Firstly it shows that the meeting was attended primarily by those

residents that do not currently experience problems with the network (78% of

responses) and that do not want the current situation in Ludwigsdorf to change (85%

of responses). Secondly, it shows that 61% of the attendees are completely against

any further MTC development in the area.

3 Percentages are based on the responses received and not on the number of attendees. See

APPENDIX J for responses on cards handed out during the meeting.

.

35



October 2012

It should however be noted that these responses are purely based on the results

obtained during the public meeting. It does not take into consideration the larger

group that did not attend.

6.4.3 SERVICE COMPLAINTS

From the information obtained from MTC‟s customer care department, 43 historical

complaints are listed for the Ludwigsdorf area. However, this number does not

reflect current complaints, which are not logged given the lack of an expanded

network in the area. Current complaints are recorded at the nearby sites such as

Bowker Hill and the NBC Cones, for those areas with poor coverage. Complaints

from the “white” areas on Figure 5-6 are not recorded at all. The nature of the

complaints is typically related to the quality of voice and data service and the slow

data speeds. Although the situation has improved slightly since the construction of

Figure 6-4: Answers obtained for the questions asked during the public meeting.

36



October 2012

The final EIA document (after

being circulated to the public)

will be sent to the DEA for

environmental clearance.

Should the project be

approved, the clearance

certificate and accompanying

documents will be sent to the

City of Windhoek for their final

approval.

the Bowker Hill BTS, the number of customers and the topology of the area

necessitate the construction of additional base stations in the area.

This group has not been represented well during the public consultation process but

since they contribute to the rationale for the project, they play an integral part. A list

of the service complaints is attached as APPENDIX B.

6.4.4 GOVERNMENT

This group forms the regulators that not only devise the standards and guidelines but

also approves or rejects a particular project. The group is divided into two

subcategories namely a) the regulators and b) the national and local authorities

(Table 6-2).

Regulators: CRAN (Communications Regulatory Authority of Namibia) is the official

regulator of the Namibian communications, broadcasting and postal services sector.

They are also the body responsible for the

authorizing spectrum frequencies. During the

consultation process, CRAN was informed of the

proposed project (a BID was sent to them) and

they attended the public meeting. All draft

documents will also be sent to them for comments.

National and Local Authorities: A number of

National and Local Authorities have been

identified on this project. They, too, play an

important role in the decision making process.

Information has been sent to them and a meeting was held with the City of Windhoek to

inform them of the project. A representative from the Ministry of Health and Social

Services also attended the public meeting.

ITEM LEVEL DESCRIPTION

STA

KEH

OLD

ER

DA

TAB

ASE

NA

TIO

NA

L

AU

THO

RIT

IES Ministry of Environment and Tourism

Ministry of Works and Transport

Ministry of Health and Social Services

Ministry of Regional and Local Government and Housing

Table 6-2: Authorities involved in this project.

37



October 2012

ITEM LEVEL DESCRIPTION

Ministry of Information and Communication Technology

REG

ION

AL

AN

D

LOC

AL

AU

THO

RIT

IES

Erongo Regional Council

City of Windhoek

6.4.5 PUBLIC INTEREST GROUPS

Throughout the project Radiation Awareness Namibia has been actively involved in

the public consultation process. They aided in informing the public about the project

and requesting them to register and comment.

6.4.6 MEDIA

Due to the contentiousness of base stations in residential areas and the known history

between MTC and residents of Ludwigsdorf, the project has received broad media

coverage. An article was placed in the Algemeine Zeitung on the 24th of September

2012 covering discussions that took place at the public meeting on the 19th of

September 2012. In addition, reporters from both NBC (National Broadcasting

Corporation) and TV One reported at the public meeting.

6.4.7 ELECTROMAGNETIC FIELD (EMF) SPECIALIST

Enviro Dynamics appointed an independent electromagnetic radiation specialist

(SATCOM) to do a radiation assessment prior to the public meeting. SATCOM in

addition subcontracted a specialist from EMSS in South Africa.

EMSS Consulting (EMSS) has expertise in the field of human exposure assessment to

radio-frequency fields. Work performed includes site surveys, numerical predictions

(computer simulations) and the interpretation and establishment of guidelines for

limiting exposure. For more than a decade EMSS has focused its efforts in this area

on the assessment of human exposure to cellphone technologies. These include

measurements and numerical predictions of exposure to cellphones and base

station antennas. EMSS publishes its research results in international peer-reviewed

38



October 2012

literature and has written numerous technical reports on base station site surveys

performed on request from cellular operators and/or members of the public.

For this EIA, the specialist was required to provide the following scientific information:

Background to electromagnetic radiation;

Current research;

Limitations in the research;

Current and future radiation expected from the proposed project;

Compliance with international standards and guidelines.

The results of their research were presented at the public meeting.

6.5 OUTCOME OF THE PUBLIC PARTICIPATION PROCESS

The main conclusion that can be drawn from the public participation process is that

there is a high degree of distrust amongst the public particularly in terms of official

views and the sources of information. Possible reasons for this are highlighted below:

6.5.1 HISTORY BETWEEN MTC AND LUDWIGSDORF

Although the Bowker Hill project has a limited bearing on the current project, the

reaction of the public to the proposed project is based on their perceptions and

evaluations of the risk.

In 2010, MTC proposed the construction of a BTS on Bowker Hill. This was apposed by

several of the neighbouring residents. The main concerns were centred around

a) the environmental impacts on Bowker Hill and b) the health concerns. Following a

case filed with the High Court and a subsequent law suit, the public stated that MTC

and the City of Windhoek continued to ignore their objections and that their

concerns were not heard.

“Strategies included repeated last-minute timing of notices to residents, preventing

residents from being properly heard by the decision-makers, (the City Council of

Windhoek), and misrepresentations in the media and in Agendas, all recorded in

detail in Affidavits for legal proceedings and in submissions to the Ombudsman.”

(Bowker Hill Conservation Group, 2012)

39



October 2012

Hazard – Object or set of

circumstances that can

potentially harm a

person‟s health.

Risk – The likelihood or

probability that a person

will be harmed by a

particular hazard.

The public‟s previous experience with the Bowker Hill project is just one of the factors

that influence their risk perception.

6.5.2 PERCEIVED RISKS VS. PERCEIVED BENEFITS

Technological progress has always been associated with hazards and risks both

perceived and real. Every activity that we undertake has an associated risk. This risk

can be lowered by avoiding certain activities but it can never be abolished

completely. Driving a car is a potential health hazard. Driving a car fast presents a

risk. The higher the speed, the more risk is associated with the driving (World Health

Organization, 2002).

Individuals perceive a risk as:

Negligible

Acceptable

Tolerable or

Unacceptable.

Whether a risk is found to be acceptable or not

has a lot to do with the individual‟s ability to

control the hazard. If the person feels that they do not have a say or are unable to

control the outcome despite of what they say, they will perceive the risk as high. This

risk will increase where they feel that their exposure to the risk is involuntary as

apposed to voluntary exposure.

Direct versus indirect benefits of the project is another factor that influences the

person‟s risk perception. The proposed project in this instance will improve both data

and voice services in the area. If a person e.g. does not own a cellphone or

computer they will not benefit directly from the project and will therefore perceive

the risk as high.

For this project the following ratings apply in terms of perceived risk vs. perceived

benefits.

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October 2012

These figures indicate, that:

Either the public does not have enough information on the radiation topic to

lower their risk perception, or

the potential benefits of the project are not well defined, or

there is a real risk.

6.6 THE KEY ISSUES

Before one can assess the potential impacts associated with this project, it is

necessary to define the key issues that came from the public participation process.

From the comments submitted to Enviro Dynamics, a number of key issues were

identified. These issues have been grouped according to theme to clearly distinguish

the main issues of concern (

Table 6-3). The complete list of issues and responses can be viewed in APPENDIX K.

Table 6-3: Main issues of concern.

THEME ISSUE NUMBER OF

CONCERNS

HEALTH

CONCERNS

Impact on children

Long term effects of non-heating continuous pulsing

BTS in a residential area

Possible carcinogen

Possible upgrade to 4G and the health effects.

21

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October 2012

THEME ISSUE NUMBER OF

CONCERNS

Involuntary, uncontrolled, continuous exposure

Lack of policy in Namibia to protect against radiation

Cumulative impact with x-ray equipment

Cumulative impact with other BTS e.g. Bowker Hill

First floor radiation exposure

Health effects on already ill individuals

EIA PROCESS Poor communication with the public and insufficient

time allowed for communication.

ENVIRONMENTAL

IMPACTS

Disappearance of bees 1

PROPERTY VALUE Reduction in property value

Visual impact/aesthetics

2

LOCATION Potential entry point for crime 1


This section of the report focuses on the need and desirability of the proposed

project. The need for better cell-phone coverage is represented by the MTC

customers who complained about poor service in the area. The opposition to the

project, on the other hand, is represented by those who objected against it during

the EIA process.

It is important to understand that approval for an EIA is not based on which of these

groups has the highest number of support. Whether the need of the project can be

confirmed and justified, and whether the issues raised can be sufficiently addressed

determines the outcome of the process.

Considering the locations from where the complaints were received (both for and

against the project), groupings can be formed around the proposed BTS sites of their

locality (Figure 6-5). These groupings show the distribution of the complaints.

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October 2012

The following conclusions can be drawn from the groupings:

The existing coverage4 in the project area is lower than that of neighbouring

areas (e.g. west of Reuning street);

Considering the existing coverage, the areas with poor coverage or

congestion correlates with the grouping of service complaints;

The project opposition is grouped around the proposed BTS sites and therefore

constitutes site specific concerns and not community level concerns.

The issues highlighted in this section of the report are collated in Section 7 where the

potential impacts related to the sensitivities are further assessed.

4 Coverage is not the only factor that determines the quality of the service. White areas

indicated on the map does not necessarily imply the absence of coverage. MTC‟s service

might still be available in these area but due to the distance from the nearest BTS and the

topography, strain may be placed on the existing BTS consequently lowering the quality of

the service.

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October 2012

Figure 6-5: Overlay of the groupings of people that complained about the service vs. people that oppose the project.

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October 2012

7 IMPACT ASSESSMENT

7.1 METHODOLOGY EMPLOYED FOR THE IMPACT ASSESSMENT

In order to define the key potential impacts associated with the project, the

information obtained from Sections 3 to Section 6 is subjected to the following

criteria.

Table 7-1: Definition of each of the criteria used to determine the significance of the impacts

CRITERIA DESCRIPTION

Nature Reviews the type of effect that the proposed activity will have on the

relevant component of the environment and includes “what will be affected

and how?”

Extent Indicates whether the impact will be site specific; local (limited to within 15

km of the area); regional (limited to ~100 km radius); national (limited to the

coastline of Namibia); or international (extending beyond Namibia‟s borders).

Duration Reviews the lifetime of the impact, as being short (days, <1 month), medium

(months, <1 year), long (years, <10 years), or permanent (generations, or >10

years).

Intensity Establishes whether the magnitude of the impact is destructive or innocuous

and whether or not it exceeds set standards, and is described as none (no

impact); low (where natural/ social environmental functions and processes

are negligibly affected); medium (where the environment continues to

function but in a noticeably modified manner); or high (where environmental

functions and processes are altered such that they temporarily or

permanently cease and/or exceed legal standards/requirements).

Probability Considers the likelihood of the impact occurring and is described as

improbable (low likelihood), probable (distinct possibility), highly probable

(most likely) or definite (impact will occur regardless of prevention measures).

Degree of Confidence

in Predictions

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

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October 2012

The application of the above criteria to determine the significance of potential

impacts uses a balanced combination of duration, extent, and intensity/magnitude,

modified by probability, cumulative effects, and confidence. Significance is

described as follows:

SIGNIFICANCE RATING CRITERIA

Low Where the impact will have a negligible influence on the environment

and no modifications or mitigations are necessary for the given

development description. This would be allocated to impacts of any

severity/ magnitude, if at a local scale/ extent and of temporary

duration/time.

Medium Where the impact could have an influence on the environment, which will

require modification of the development design and/or alternative

mitigation. This would be allocated to impacts of moderate

severity/magnitude, locally to regionally, and in the short term.

High Where the impact could have a significant influence on the environment

and, in the event of a negative impact the activity(ies) causing it, should

not be permitted (i.e. there could be a „no-go‟ implication for the

development, regardless of any possible mitigation). This would be

allocated to impacts of high magnitude, locally for longer than a month,

and/or of high magnitude regionally and beyond.

Table 7-2: Definitions of the various significance ratings

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October 2012

7.2 IDENTIFICATION OF KEY ISSUES

To determine potentially significant impacts of a project involves pooling together all

the sensitivities derived from the baseline conditions, legal requirements as well as the

concerns raised by I&APs. This list of issues is further screened to derive at issues for

which further investigation is required, using a thought process explained in

Figure 7-1.

Table 7-3 below shows all the potential impacts identified for this project, with the

above process applied.

Does the issue fall within the scope of the project and the

responsibility of MTC?

Figure 7-1: Screening process to determine key issues

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October 2012

Table 7-3: Identification of key impacts.

7.3 ECONOMIC IMPLICATIONS

7.3.1 BACKGROUND TO THE NEED FOR THE PROJECT

MTC is currently experiencing problems with congestion and coverage in the

Ludwigsdorf area. This is brought about by the high number of service users in the

area causing the existing BTS structures on Bowker Hill and Hidas Centre to become

congested. Another factor that influences the coverage in the area is the

surrounding topography. The undulating landscape causes areas with poor

coverage on the shadow side of slopes. The mini BTS sites proposed by MTC will

provide specific coverage in these areas, thereby improving the service.

IMPACT/ISSUE MTC

RESPONSIBILITY

YES/NO

SUFFICIENT

INFO

YES/NO

MITIGATION

AVAILABLE

YES/NO

FURTHER

WORK TO BE

CONDUCTED

ADDRESSED

IN:

Economic

implications

Yes Yes Yes No Subsection

7.3.

Disappearance

of bees

Yes No No Yes Subsection

7.4.

Reduction in

property value

Yes No No Yes Subsection

7.5.

Potential entry

point for crime

Yes Yes Yes No Addressed

in the EMP

Perceived

health risks

associated with

radiation from

BTS structures.

Yes No Yes Yes Subsection

7.6.

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October 2012

7.3.2 POTENTIAL EFFECTS OF THE PROJECT

By implementing the project, MTC will improve the service they current provide in the

Ludwigsdorf area. This will be achieved by:

Improving the speed of data connections,

Improving the quality of voice calls

7.3.3 SIGNIFICANCE

By implementing the proposed project, the significance for MTC can be summarized

as follow:

Table 7-4: Expected significance of the economic implications

CRITERIA DISTURBANCE OF ECOSYSTEMS

Extent Local

Duration Permanent

Intensity/

Magnitude

High

Probability Definite

Significance Before

Mitigation

High positive

Significance After

Mitigation

High positive

Degree of Confidence in

Predictions

High

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October 2012

7.4 DISAPPEARANCE OF BEES

7.4.1 BACKGROUND TO THE PROBLEM

Since 2007, scientists have researched the causes for the rapid collapse in honey

bee colonies. This rapid collapse poses significant environmental and economical

impacts, due to the pollination role bees play in plant communities and agricultural

crops. The phenomenon, although not uncommon in apiculture, has recently been

labelled Colony Collapse Disorder (CCD), following a drastic collapse in honey bee

colonies in North America in 2006. Several causes for this collapse have been

proposed, including:

Biotic factors such mites and pathogens,

Malnutrition,

Pesticides,

Genetically modified crops,

Pest control methods,

Electromagnetic Radiation from cellphones and base stations, and

A combination of all of the above and not single factors.

7.4.2 POTENTIAL EFFECTS FROM ELECTROMAGNETIC RADIATION (EMR)

Some studies done (Pttazhy, 2012; Sainudee, 2011) state that the EMR produced by

base stations and cellphones are causing an interference with the navigational skills

of bees, preventing them to return to hives.

Another study done by the CCD Steering Committee (2009) lent credence to the

hypothesis that CCD may be a syndrome caused by many different factors, working

in combination or synergistically. These findings were supported by a study that

tested 61 quantified variables (including adult bee physiology, pathogen loads, and

pesticide levels). The results showed that no single measure emerged as a most-likely

cause of CCD (Van Engelsdorf, et al., 2009).

Favre (2011) found no direct link between the EMR emitted from base stations and

CCD. His findings support that of Steve & Khun (2004).

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October 2012

Most of the studies are however in agreement that further research is needed to

establish a scientific link, if any, between the observed abnormalities and disorders in

bee hives such as Colony Collapse Disorder and EMR from base stations.

7.4.3 SIGNIFICANCE OF THE CURRENT PROJECT

The causal link between EMR and the occurrence of bees in a particular area is still a

grey area for which no clear answer is available. However, the effect is cumulative

and not restricted to a specific BTS. The following site specific (not cumulative)

significance ratings apply:

Table 7-5: Expected significance of the impact on bees


Extent Local

Duration Permanent

Intensity/

Magnitude

Low

Probability Probable

Significance Before

Mitigation

Low (small contribution of the specific project)

Significance After

Mitigation

Low


Predictions

Medium

7.4.4 MITIGATION MEASURES

MTC should stay up to date with recent research. Should new policies or

guidelines be presented in the international community, MTC should consider it

and adapt current infrastructure accordingly.

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October 2012

7.5 REDUCTION IN PROPERTY VALUE

7.5.1 BACKGROUND TO THE PROBLEM

Concerns with the effect of base stations on property values have been well

documented in similar studies worldwide (Bond, et al., 2003; Bello, 2010).

7.5.2 POTENTIAL EFFECTS ON PROPERTY VALUES

To determine the effect of the current project on neighbouring properties, two

valuators in Windhoek were contacted5.

Both valuators indicated that the presence of BTS sites close to a property does not

affect the valuation of the property. The valuator from FNB stated that, if anything, it

could increase the appeal of a property due to the better cellphone and data

reception it pose.

According to the private valuator, it is the perception of the buyers that can

influence the period a property stays in the market. Should buyers perceive the BTS

as a potential health hazard, it could result in the property staying in the market for

longer time periods, thereby forcing the selling price to be dropped.

That being said, the high demand for property in Windhoek makes the market

extremely lucrative. Both valuators stated that in their experience, the presence of a

BTS close to a property very rarely influence the physical value.

Another factor that can potentially influence the perception of buyers is the visual

impact of the BTS. An unsightly structure could reduce the appeal of the property.


Based on the statements made by the valuators, the significance of the potential

impact is analysed as follows:

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

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

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October 2012

Table 7-6: Expected significance of the project on property prices.


Extent Local

Duration Permanent

Intensity/

Magnitude

Low

Probability Improbable

Significance Before

Mitigation

Low (due to the contribution of the specific project)

Significance After

Mitigation

Low


Predictions

Medium


The aesthetics of the surrounding area should be considered when deciding on

a final design for the BTS structure (particularly the container and palisade

fence). Landscaping to conceal it will reduce the visual impact.

MTC should ensure that the BTS sites are within the internationally prescribed

radiation emission limits endorsed by the Atomic Energy and Radiation

Protection Act, Act 5 of 2005 (i.e. ICNIRP, 2009).

The public should be informed of these limits and presented with proof of how

MTC intends to stay within these limits. Open communication channels should be

maintained whereby no information is withheld from the public

A Strategic Environmental Assessment should be undertaken by MTC where the

issue of property values and BTS sites are evaluated and the results

communicated with the public.

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October 2012

7.6 EMF EXPOSURE

7.6.1 BACKGROUND TO EMF

Electromagnetic fields occur naturally on earth in the form of visible light. Our

exposure to EMF has however steadily increased with the turn of the century

following the ever advancing wireless technologies such as radio, television and

more recently cellphone technologies. EMF travels away from a source and carries

energy with it (World Health Organization, 2012).

Two types of EMF can be distinguished, namely ionizing radiation (e.g. x-rays and

gamma rays) and non-ionizing radiation. The power transmitted from base stations

places it in the Radio Frequency (RF) range. Table 7-7 below explains the different

frequencies and the effect it can have on the human body.

Table 7-7: Different types of electromagnetic radiation (adapted from (World Health Organization,

2002)

NON-IONIZING RADIATION

IONIZING

RADIATION

Frequency <100 kHz 100 kHz - 1 GHz 1 – 300 GHz 300 GHz -750 THz 750 -950 THz

Type Extremely

low

frequency

Radio frequency Microwave Visible light x-rays and

gamma rays

Non-Thermal Thermal Optical Broken Bonds

Effect Induces low

currents

Penetrate a short

distance into the

body.

Induces high

currents

Excites electrons Damages DNA

Biological

effect

Disturbance

of nerve and

muscle

responses

Heating of body

tissue, raised body

temperature

Heating of

body tissue

Photochemical

effects

Skin

pigmentation

Source Power lines Television, FM, AM,

shortwave and

base stations

Cellphones,

microwave

oven, Wi-Fi

Sunlight, fire, light

bulbs, lasers

Sunlight

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October 2012

The effect of exposure to high levels of radio frequencies is known to cause

biological cell heating that can lead to tissue damage. Studies done by the WHO

has consistently shown that the radio frequencies from base stations are well below

the levels needed to cause heating and an increase in body temperature (World

Health Organization, 2002).

How the radio frequency from a base station affects a persons health is determined

by the level of exposure. This depends on the following factors:

“The distance from the antennae. Generally, exposure decreases with the

inverse square of the distance as one moves away from an antenna (in other

words, the exposure 200 m from the antenna is one quarter of the exposure

I00 m from the source).

The output power of the antenna (i.e. the strength of the emissions from the

antenna).

The direction of the main beam of the antenna. Within the main beam of the

antenna, high above the ground, the signal is far stronger than on the ground

just beneath the antenna.

Height of the antenna above ground.

Local terrain (for example, trees and building materials absorb radio signals).”

(Taken from World Health Organization, 2012)

7.6.2 POTENTIAL BIOLOGICAL AND HEALTH EFFECTS ASSOCIATED WITH EMF

Information on health effects are obtained through thorough international research.

According to the World Health Organization (2012) the information is usually based

on:

Laboratory studies – where cell cultures, animals and humans are exposed to

RF fields under defined conditions,

Epidemiological studies – where the health of different groups of people may

have different exposures due to where they live or work,

In vivo - experimentation on living organisms, and

In vitro - experimentation using a partial or dead organism to do biopsies.

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October 2012

The current standing of the WHO is that “exposure to low level RF fields (such as those

emitted by mobile phones and their base stations) does not cause adverse health

effects” (WHO, 2012). According to WHO (2002) some scientists have reported minor

effects from cellphone usage, including changes in brain activity, reaction times and

sleep patterns. These are however believed to be within the normal bounds of

human variation.

Apart from the WHO, a number of governments have initiated health reviews of their

own on the topic. Many of these reviews have concluded that there is no reason to

believe that exposure to EMF at levels typically found around base station sites is

detrimental to the general public‟s health.

Examples of some of the most recent of these reviews are:

the UK Health Protection Agency, April 2012,

the Independent Expert Group report on Electromagnetic Fields (Swedish

Radiation Safety Authority), December 2010,

the joint statement by the Nordic Radiation Safety Authorities on Exposure of the

General Public to Radiofrequency Electromagnetic Fields, November 2009,

the European Commission‟s 2009 SCENIHR: Health Effects of Exposure to EMF

report, January 2009 and

the Health Council of the Netherlands review on Electromagnetic Fields,

updated in March 2009.

SCIENTIFIC UNCERTAINTIES

Science is not error free. Some limitations do exist, including:

“Scientific evaluations of biological responses from environmental exposures rarely lead to

unanimous conclusions.

Epidemiological studies are prone to bias.

Extrapolation from animal studies to humans is often questionable.

“Weight of evidence” determines the degree to which available results support or refute a

given hypothesis.

No single study can provide a definite answer.

Public interprets uncertainties in scientific knowledge on EMF health effects as declarations

of the existence of real risks. “

Taken from World Health Organization (2002)

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October 2012

GROUP 2B: THE AGENT IS POSSIBLY CARCINOGENIC TO HUMANS.

“This category is used for agents for which there is limited evidence of carcinogenicity in

humans and less than sufficient evidence of carcinogenicity in experimental animals. It

may also be used when there is inadequate evidence of carcinogenicity in humans but

there is sufficient evidence of carcinogenicity in experimental animals. In some instances,

an agent for which there is inadequate evidence of carcinogenicity in humans and less

than sufficient evidence of carcinogenicity in experimental animals together with

supporting evidence from mechanistic and other relevant data may be placed in this

group. An agent may be classified in this category solely on the basis of strong evidence

from mechanistic and other relevant data.”

Taken from International Agency for Research on Cancer (IARC), 2006

The current health debate regarding base stations and human health are however

centred on whether long-term, low level exposure can cause adverse health effects

or influence people‟s well being (also indicated in Radiation Awareness Namibia‟s

Memorandum of concerns, 19 September 2012).

The concerns associated with Extreme Low Frequency (ELF) magnetic fields are often

based on the findings of the 2002 report of the International Agency for Research on

Cancer (IARC). In the report (IARC, 2002), the following conclusions are drawn:

“There is limited evidence in humans for the carcinogenicity of extremely

low-frequency magnetic fields in relation to childhood leukaemia.

There is inadequate evidence in humans for the carcinogenicity of

extremely low-frequency magnetic fields in relation to all other cancers.

There is inadequate evidence in humans for the carcinogenicity of static

electric or magnetic fields and extremely low-frequency electric fields.”

“No effect on melatonin was seen following night-time exposure of human

volunteers to 50 or 60-Hz magnetic fields under controlled laboratory

conditions. In contrast, a small reduction in melatonin concentration has

been observed in occupational and residential environments, but it is

difficult to distinguish between effects of the magnetic field and those of

other environmental factors.”

The report concluded that static and extremely low frequency electric and

magnetic fields should be classified as a Class 2B – a possible human carcinogen.

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October 2012

An example of a well known agent classified in the same category is coffee, which

may increase the risk of kidney cancer.

Since the publishing of IARC report in 2002 most of the scientific research examining

long-term risks from ELF magnetic field exposure has focused on childhood

leukaemia (WHO, 2007).

In 2010, ICNIRP released guidelines for limiting exposure to time‐varying electric and

magnetic fields (1 hz – 100 khz) (ICNIRP, 2010). The report concluded that a causal

relationship between magnetic fields and childhood leukemia has not been

established nor have any other long term effects been established.

Although the epidemiological evidence for this finding is weakened by

methodological problems such as selection bias, the technology is simply too recent

to completely rule out possible long term effects (WHO, 2007).

7.6.3 EMF EXPOSURE GUIDELINES AND POLICIES

Although countries normally set their own national standards for exposure to EMF,

most of these standards are based on the guidelines set by the International

Commission on Non-Ionizing Radiation (ICNIRP). The organization is formally

recognized by the WHO and its primary objective is to evaluate scientific research

and provide guidelines recommending the limits of exposure. The research done by

ICNIRP are reviewed periodically and updated as necessary – the validity of the

recommendations was reaffirmed in 2009 following a review (ICNIRP, 2009).

The exposure limits recommended by ICNIRP:

1. Covers the non-ionizing radiation frequency range between 0 and 300 GHz,

2. Are based on all published, peer reviewed literature, and

3. Are related to short term exposure.

The reason for the latter is based on the fact that the available scientific information

on the long term exposure to EMF fields is considered to be insufficient to establish

quantitative limits (WHO, 2002).

The international guidelines proposed by ICNIRP consider the threshold level that

could potentially lead to biological effects. The lowest threshold level is then further

reduced to allow for uncertainties in the science and set limit values fro human

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October 2012

exposure. According to WHO (2002) ICNIRP uses a reduction factor of 10 to derive at

occupational limits for workers and a factor of about 50 to arrive at exposure limits for

the public. This factor serves as a precautionary buffer to compensate for

uncertainties in the research.

7.6.4 COMPLIANCE OF THE PROPOSED PROJECT WITH EXPOSURE LIMITS

The five proposed sites have been subjected to an electromagnetic radiation

exposure study to ascertain if the radiation outputs are in line with those permitted by

the ICNIRP guidelines or not. SAT-COM and EMSS Consulting were commissioned for

this, because of their combined expertise in the field of human exposure assessment

to RF fields. The complete report of their findings can be viewed in APPENDIX L.

Measurements were performed at and around the locations of the five planned and

one mobile base station sites of MTC in the Ludwigsdorf area. The aim of the survey

was to measure the ambient electromagnetic exposure, the expected exposure

levels at various positions around these sites and then to compare the results to the

ICNIRP standards (Sat-Com, 2012).

From the findings of the assessments done by SAT-COM on the five sites, it was clearly

indicated that RF field measurement results were below the ICNIRP guideline values.

Many authorities base their limits on the guidelines published by ICNIRP.

The results obtained show that:

The maximum expected RF exposure anywhere at 1.5 m above ground level

around all the proposed sites is at least 2300 times below the general public

guidelines of limiting exposure proposed by ICNIRP (Table 7-8).

The maximum expected RF exposure at 1.5 m above the level of expected

maximum exposure of a multiple storey building near the Gloudina Road Mini

base station is at least 450 times below the ICNIRP general public guidelines.

According to the numerical EMF exposure assessment performed by Sat-Com

and EMSS, the site is classified as Provisionally Compliant and will be Compliant

with the ICNIRP Guidelines if the equipment is installed as specified in the

planned documentation.

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October 2012


To put a potential significance value on the public‟s perceived risk posed by EMF

radiation is impossible to determine. However, ICNIRP is the accepted standard for

EMF radiation measurement and is considered a conservative tool in the radiation

impact assessment regime worldwide. The significance rating is therefore based on

the specialist‟s assessment which used ICNIRP as its basis.

Table 7-9: Expected significance of EMF exposure from the five proposed sites.6


Extent Local

Duration Permanent but varies in intensity

Intensity/

Magnitude

Low

Probability Probable

Significance Before

Mitigation

Low

Significance After

Mitigation

Low


Predictions

High

6 This assessment does not take into account long term exposure.

Table 7-8: Predicted maximum exposure summary at 1.5m above ground level.

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October 2012


Should MTC in future intend to change the radiation outputs from these sites by

upgrading to e.g. 4G or any other technology that could change the current

radiation conditions, a new radiation assessment (followed by extensive public

review) will be required.

An infrastructure related communications plan should be put in place by MTC.

As a minimum requirement, this plan should encompass and provide for:

A comprehensive information campaign whereby the public is informed of

unbiased progress in EMF radiation and public health research.

Communication from the public where they can raise their concerns and

provide input in future projects.

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October 2012

8 CONCLUSIONS AND RECOMMENDATIONS

8.1 THE EIA AND PUBLIC CONSULTATION PROCESS

The process followed in this report was aimed at providing the public reasonable

access to unbiased information. The objective in this instance was to discern what

type of information was needed from the public whilst clarifying the technical

aspects of the project. Despite this, the EIA and particularly the public consultation

process were conducted under conditions of extreme distrust and cynicism from the

public.

It is our opinion that the EIA process followed for this project complied with the

regulations provided by the Local and National Authorities.

The public consultation process however had some limitations such as:

Addresses from CoW are out-dated and there is no way to prove that the owners

received the letters or how long it takes for them to check their mail.

The effectiveness of delivering letters by hand was limited by the following

factors:

o People were on leave or not at home for the period we were contacting

them,

o Some houses currently don‟t have any residents,

o Some people refused to sign or receive the letters.

These limitations do not imply that the consultation process was flawed since various

other methods were also used to reach the community including the use of notices

in the newspapers and posters on each site.

During the study, Enviro Dynamics received notification that an official objection

regarding the public participation process was lodged at the Environmental

Commissioner (Directorate of Environmental Affairs). The contents of this objection

have been dealt with in the EIA Report and Issues and Responses trail as needed.

We therefore deem the EIA and public consultation process followed as compliant

and comprehensive.

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October 2012

8.2 SYNOPSIS OF THE KEY ISSUES

The issues raised by the public on this project are mostly related to the potential

health effects associated with EMF exposure in residential areas. From our review of

available literature, organizations such as WHO and ICNIRP review thousands of

studies to determine what the real risks of BTS sites in populated areas are. To say

that the findings of these studies are “conclusive” one way or another would be

premature. It is for this very reason that these organizations base their radiation

guidelines on the precautionary principle, i.e. that they include in their standards

margins which include potential health effects which have not yet been confirmed.

Summarizing the key issues raised during the project:

Economic Implications: Considering the number of complaints MTC received

from the public, the surrounding topography and existing coverage in the area

(based on coverage prediction maps) it is clear that the proposed project will

improve the quality of voice and data services in the area.

Disappearance of bees: The disappearance of large colonies of honey bees

(called Colony Collapse Disorder (CCD)) is not a new phenomenon but since

2006 research studies have included EMF as another possible cause for it.

Various studies in India found a possible causal link between the increase in

cellphones and BTS sites and CCD. Other scientists are of the opinion that CCD

has existed long before the use of cellphones and BTS sites and that the causal

link is very weak. They uphold that it is a combination of factors and not just one

single factor that is the cause. Although the disappearance of bees could have

serious implications for the environment and agricultural industry the impact of

the project on this is considered low.

Reduction in property values: International studies done on this issue have found

that there is an increasing awareness of EMR in the property market. Local

valuators however indicated that the value of a property is not affected by the

presence of base stations. It is rather the perception of the public that could

have an effect on how fast a property is sold or not. This is also affected by the

visual appeal of the BTS. However, due to the lucrative property market and the

high demand for property, both of the valuators indicated that public

perception of base stations very rarely affect property prices in Windhoek. The

impact of the project on this issue is regarded as low.

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EMF exposure: Thousands of studies have been done and are done annually to

research the concerns about the health effects of BTS sites. Although some

exceptions do exist the majority of these studies are in agreement that the

energy emitted from BTS sites is too low to cause adverse health effects. Based

on the information from the WHO, BTS sites do not pose risks for cancer. The fact

that it was recently classified by the IARC (2006) as “possibly carcinogenic to

humans” is based on research on childhood leukemia. The classification implies

that “there is limited evidence of carcinogenicity in humans and less than

sufficient evidence of carcinogenicity in experimental animals.”

This being said, there are still gaps in the research for which no clear answer is

available. This is particularly true of long-term, low level exposure. Current

guidelines provided by ICNIRP (2009) only consider the effects of short term

acute exposure. This is because the available scientific information on the long-

term low level effects of exposure to EMF fields is considered insufficient to

establish quantitative limits. The ICNIRP guidelines do however include

consideration to potential biological effects even though they have not yet

been confirmed, by including a very conservative threshold level. This level is

further reduced to allow for uncertainties in the science and set limit values for

human exposure.

The ICNIRP standards are endorsed by the larger international community, and

also by Namibia. For this reason, the study by the independent consultants

(EMSS) to determine the ambient exposure levels in Ludwigsdorf and the

expected exposures from the new sites were also based on the ICNIRP

standards. Based on the findings of EMSS the potential risk posed by the

proposed project is considered low.

8.3 RECOMMENDATIONS

Based purely on the findings listed above there is no reason why this project can not

proceed. However, there is a deeper lying concern that is related to the desirability

of the project. It seems that there is reluctance from a portion of the residents of

Ludwigsdorf who desire the status quo in the area to continue without further

intervention from MTC.

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8.3.1 CONSIDERING THE NO-PROJECT ALTERNATIVE

The rationale for this project is to a large extent based on the number of complaints

that MTC received from residents/visitors to the area that had problems with

dropped calls or slow network connection speed. Although the project received a

significant degree of public participation, this specific group of I&APs (those who

want improved service) are not well represented. The reason for this is most likely

due to the fact that they perceive the project as positive and therefore see no

reason to participate because they have no complaints or concerns regarding the

construction of the sites.

Should this project not continue the number of dropped calls and slow network

speed will continue due to the continued congestion on the existing BTS sites. The

problem could also flow over to other areas covered by the macro BTS sites due to

the pressure added from Ludwigsdorf. This will likely increase the number of

complaints. The area shown on Figure 6-5 as having poor coverage will remain that

way without the implementation of this project.

If one considers the findings of the radiation assessment7, the five new sites could

result in a 0.02% increase in the Total levels of exposure in the project area. This is

99.96% below ICNIRP standards compared to the 99.98% prior to the construction.

CURRENT TOTAL LEVEL OF EXPOSURE

(AVERAGE OF 25 SITES)

PREDICTED LEVEL OF EXPOSURE

(AVERAGE AT THE 5 SITES) INCREASE

0.02% 0.04% 0.02%

7 Presented as a percentage of the ICNIRP guidelines, where a 100% value would indicate

the safe exposure limit for the General Public.

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8.3.2 RECOMMENDATIONS

From the public participation process it is clear that there is a lack of communication

between the public and MTC. The public perceives MTC as overly profit driven whilst

not listening to their concerns and not truly involving the public in their decision

making processes.

While there certainly are limitations to the extent of consultation that can be done,

the recommendation of this EIA is that MTC undertakes a Strategic Environmental

Assessment (SEA). The aim of which should be to determine the level of service to be

provided for each area. This is to be done in close collaboration with the community

of each area, by using effective strategies for consulting affected communities. The

assessment should provide two deliverables:

The SEA should include a Community Consultation Plan: This plan will allow for

information feedback between MTC and the public. Its aim will be to show what

communication strategies work when informing the public of a proposed project

and what does not. It should also assign specific timeframes for each of these

procedures, allowing sufficient time for information sharing before commencing with

the public participation process outlined in the EMA (2007) and its regulations (2012).

The plan should also address the limitations that have been identified during this EIA

process. A community assessment poll (not just a customer services poll) should also

form part of this plan, focussed at determining the needs of the community and

acceptability of risks.

MTC should undertake an Infrastructure Related Communications Plan: This plan

should cover a comprehensive information campaign whereby the public is

informed of unbiased progress in EMF radiation and public health research. It should

also allow for communication from the public where they can raise their concerns

and provide input in future projects.

Available resources on the subject of dialogue between the community and the

service providers such as that provided in WHO (2002): Establishing a Dialogue on

risks from electromagnetic fields, should be utilized in drawing up the two plans.

Some guidelines are provided in the Environmental Management Plan

(APPENDIX M).

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8.4 FINAL RECOMMENDATION

The issues that were raised during the EIA process can be divided into either site or

project specific issues or community level issues. Although some community level

concerns were raised during the process, the EIA assessed the project specific

concerns which translate to the need and desirability of the project:

Need for the project: As illustrated in the report, the need for the project is

based on the poor coverage in the study area, which is confirmed by

complaints received by MTC on the voice and data service in the area.

Based on this need MTC aims to improve the coverage in the areas that

currently have poor coverage (indicated in Figure 6-5) to the same level as

that of the nearby Ludwigsdorf.

Desirability of the project: Based on the impacts assessed, the potential

impacts and concerns of the public have all been addressed and mitigation

to acceptable levels, and the desirability of the project is therefore confirmed.

This, however, does not negate the low level of trust which exists amongst a group of

the interested and affected parties, particularly with regard to potential health

effects caused by EMF.

The aim of the EIA was not to choose sides for or against the current health debate.

However, after researching a wide range of opinions, the environmental consultant

finds no reason to doubt the standards prescribed by ICNIRP (endorsed by the

Namibian Government).

In terms of the uncertainties related to BTS sites and human health (e.g. pulsing and

ELF), the ICNIRP standards are based on the precautionary principle. Since the

radiation assessment used scientific methods to determine the potential risk of the

proposed sites in comparison to the guidelines prescribed by ICNIRP, the

Environmental Consultant finds no reason for the proposed project not to be

approved by the Environmental Commissioner.

We do however recommend further community-wide work which aims at

determining the level of service which will be provided in future in close consultation

with the community. There also needs to be better communication to disclose the

levels of radiation emitted from all existing and future base stations not only in

Ludwigsdorf but any new sites constructed by MTC.

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Documents

Five Mini BTS sites in Ludwigsdorf, · PDF file2.1 What is a cellular system? ... for the erection of telecommunication ... intends to construct five 3G Mini Base Transceiver Stations