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”The limits currently being employed in Denmark have their basis in recommendations from
the EU, which are founded on limits set by the International Commission on Non-Ionizing
Radiation Protection (ICNIRP).
The telephone companies shall ensure compliance with these limits, which are 2 W/kg
wherever people are staying and move about. These limits are technology neutral which
means that the limits apply irrespective of the technology employed, e.g. 2G, 3G, 4G or 5G.
The telephone companies have informed that they expect the number of mast positions to be
increased by 15-25% towards 2025 as a result of the phasing in of 5G. It is the companies'
expectation that the combined electromagnetic exposure will be increased by 10-20%
compared to today.
The telephone companies expect the exposure from the mobile nets to remain far below the
limits, also when the 5G-nets have been fully expanded.
The 5G-net will be based on higher frequencies than the other technologies, and the mobile
signals will therefore have a shorter range. This means that there will be need of a finer mesh
with more base stations (small cells). These base stations will transmit using a lower effect
than e.g. the antennas transmitting on 2G, 3G and 4G. The radiation will therefore be
correspondingly smaller.” 3
1.2. Research.
Scientific research has been documenting health damage caused by electromagnetic fields
since at least 1966. 4
It is this research which will be compared with the intended 5G-system's known
characteristics, cf. item 1.1 above, as well as the ”limits” (maximums for emitting a certain
kind of environmental affector) which are currently being employed in the EU and Denmark, cf.
item 2.1 below.
It has not been practically possible to peruse the full body of available scientific material that
underpins the above mentioned health damage effects on humans and animals by means of
exposure to radiofrequent electromagnetic radiation, as this material comprises several
thousand articles.
A portion of the analysed material has been compiled by the undersigned, and a portion has
been sent by the commissioner of this legal opinion, including by request from the
undersigned.
1.2.1. The focus of this legal opinion.
This legal opinion is centred around the results that positively document either actual damages
or risks thereof to humans, animals, and plants.
To the extent that such provable research results are available, they are inherently of much
greater significance than examinations which have been incapable of identifying a damage or
risk thereof, since the latter group does not in itself exclude the possibility that there exist real
damages or risks.
3
4
For further information, see item 2.1 below which deals with the limits currently employed in Denmark.
Cf. Pall (2018, p. 9) which refers to Marha K.’s (1966) article: “Biological effects of high-frequency electromagnetic
fields” (translation).
4