5G Tower Proposal update

Hi Geoff,

I will raise the possibility of you discussing matters directly with the Amplitel and Telstra team. I will say at the outset that this is very rarely done, instead persons such as myself serve as the ‘in-between’ so that those teams can focus o their specific work and not have to worry about saying the ‘wrong’ thing to a member of the public.

With respect to the meeting minutes themselves notification letters were hand-delivered to residences in close proximity to the proposed facility. Two (2) signs were put up in the area, one (1) at the railway crossroads and one (1) at the site of the proposed facility. These were put up so that people walking by the location, or driving by the railroad crossroad would be able to see information on the proposal. Emails were also sent to various interested and affected parties in the wider area, including the Steiner School. These emails were sent on 12 June 2024, over two weeks prior to the start of the school holidays. A site-specific webpage on the radio-frequency national site archive (RFNSA) was also created with a copy of the proposal plans, the site-specific environmental EME report, links to additional information on electromagnetic energy (EME), copies of the montages and copies of the notification letters.

CPS realised there had been an issue with some notification letters not being received by some residences very early in the consultation. As a result additional letters were sent out our via express post and I have had confirmation from most residences that these have been received. The consultation timeframe in these resent letters was extended, and an announcement made on the RFNSA page for the proposed facility advising everyone of this. It is known that the proposed facility has become an item of considerable discussion on the community Facebook page, which was private and so unreachable by us, helping assist with greater notification to the wider community.

There was some confusion in the meeting minutes on the extent of the proposal itself. The proposed facility includes the following:

• The installation of a 35m monopole (36.3m including antennas)

• Attached to the top of the monopole, a new headframe accommodating nine (9) Telstra 4G and 5G antennas

• The installation of an equipment shelter (2.5m wide x 3m long x 2.9m high) to accommodate internal Telstra equipment;

• The installation of associated ancillary equipment necessary for the proper functioning of the facility; and

• A compound approximately 8m x 8m to 10m x 10m containing the above

The proposed facility does not include any lighting and the facility does not include a generator, with power coming from the existing power network in the area. The proposal does include a small residential-style air-conditioning unit in the equipment shelter that ensures that the network equipment inside is operating at the proper temperature. The proposed facility does not include equipment by any other Carrier at this time and while there is sufficient space and capacity in the tower and within the compound for another Carrier, any Carrier will need to comply with all applicable planning requirements in order to install their equipment on the proposed facility. Copies of the proposal plans showing specific detail on the proposal are available at  https://www.rfnsa.com.au/3159002/consultation

The meeting minutes include a concern with respect to property prices. To work effectively, base stations need to be located near to the people who are accessing this technology. Property valuation is a complex issue, with fluctuations in price being subject to several factors. Many of these are subjective, and may be as diverse as aspect, views, condition of the property, local amenity and access to services, including high quality communications.  Since the mid-1990s, thousands of telecommunication facilities have been installed throughout Australian metropolitan and regional areas. During this period, property values have continued to increase, showing no clear signs of deterioration as a result of the location of communications facilities. Amplitel is not aware of any credible evidence that directly links the siting of telecommunications facility to a decrease in property prices.

Amplitel, and Telstra as the Carrier with equipment on the proposed facility, relies on the expert advice from the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) for overall assessments of health and safety impacts.   Research into EME and health has been going on for many years now.  ARPANSA’s advise that here is no substantiated scientific evidence that radiofrequency technologies that operate within national and international safety standards cause health effects. Additional information from ARPANSA on this can be found at https://www.arpansa.gov.au/understanding-radiation/radiation-sources/more-radiation-sources/mobile-phone-base-stations .

Telstra is obligated to comply with the mandated safety standard known as “RPS S-1”.  I can assure you that all of Amplitel’s mobile base stations are designed to comply with RPS S-1. The safety standard is set by ARPANSA and is based on the safety guidelines recommended by the World Health Organisation (WHO).

The RPS S-1 ARPANSA EME standard:

• protects all people including children

• is very conservative and includes large reduction factors

• covers all RF EME frequencies including those used by 5G and future technologies

• was developed after a thorough review of all relevant scientific literature in conjunction with ICNIRP and an extensive public consultation process.

ARPANSA provides an opportunity for the public and community to talk directly with scientists on issues about radiation exposure and protection in Australia.  https://www.arpansa.gov.au/contact-us/talk-to-a-scientist

Additionally, the radiofrequency used by 5G technology has been used for many decades and has been researched. The References section of both the ICNIRP Guidelines and the ARPANSA Standard RPS S-1 lists the significant studies which were reviewed.

https://www.icnirp.org/cms/upload/publications/ICNIRPrfgdl2020.pdf

https://www.arpansa.gov.au/sites/default/files/rps_s-1.pdf

The EMF-Portal is a worldwide comprehensive scientific literature database on biological and health-related effects of non-ionizing electromagnetic energy. The database has approximately 40,000 publication and over 7,000 summarises of individual scientific studies on the effects of electromagnetic fields.  You can search it here:  https://www.emf-portal.org/en.

The material provided for the site includes an EME Environmental Report prepared by CPS Technology & Infrastructure in accordance with the required standards. The Environmental Report estimates the maximum cumulative EME emitted from the base station as being 3.75%, or 1/26 of the ARPANSA limit. The estimated levels have been calculated on the maximum mobile call and data capacity anticipated for a particular site.  This estimation does not allow for possible radio signal attenuation due to buildings and the general environment.  Actual EME levels will generally be significantly less than predicted, due to path losses and the base station automatically transmitting power to only serve established phone calls and data transmissions. The Australian Communication and Media Authority (ACMA) has undertaken independent testing of mobile phone base stations across nearly all states in Australia, including Victoria. This is constantly updated and is publicly available at EME Checker | ACMA. As an example of the difference between the levels within an EME report and actual measured levels, the published EME report for a nearby site at Beaconsfield shows a maximum level of 3.740%, but the levels measure by ACMA are a maximum of 0.183% and an average of 0.076%, being over 20 and 50 times respectively under the maximum levels within that EME report.

The location and consideration for any new Telecommunications Facility needs to satisfy and balance a range of considerations, these primarily include environmental impacts, tenure, planning and related approvals, community considerations including proximity to community sensitive locations, buildability, power availability, network connectivity (generally fibre) and coverage considerations.

The proposed site is part of the Peri Urban Mobile Program, an initiative of the Federal Government that focuses on rural residential style areas of low or no mobile connectivity and where there is an identified bushfire hazard. The coverage requirements of the program must be met for a site to proceed to the lodgement of a planning application and then further build. This can be difficult in areas such as Menzies Creek where there are limited commercial or industrial areas (where Telecommunications Facilities is easiest placed), residences tend to be located on the top of ridgelines and valley areas tend to be undeveloped and with protected scenic qualities.  The proposed site must provide coverage north and south of Menzies Road, which can be difficult for a tower on either side of the ridge without creating coverage ‘blackspots’ caused by the relatively steep downslopes. The coverage requirements must then be balanced with the ability to secure tenure on a site, environmental and planning issues (including visual impact), buildability and access to the wider telecommunications network.

There is also a need to ‘balance’ the area serviced by the facility. The proposed facility includes three (3) antenna sectors, which when combined each provide 360 degree coverage in the area. Each antenna sector provides a set amount of network capacity to the area, assisting with making sure that there are no call dropouts or data issues with too many users using one (1) sector. The proposed facility at this location, and other areas close by, allows for the coverage capacity of each sector to be split in a relatively balanced manner.

The proposed location was arrived at after an assessment of the area where we knew coverage requirements would be met for the funded solution. We then undertook a more detailed assessment of available locations with regards to the considerations mentioned earlier. I can advise that we approached the nearby fire authority to see if we could locate on the existing fire tower, replace it (ensuring it still functions for the fire authority) or place a tower next to it. The fire authority were unable to consider the proposal further due to a lack of resources on their end. We have had a number of discussions with Puffing Billy about the use of their land, including at the toilet block and the area to the west of the old managers’ residence. This included consideration by Puffing Billy for impacts on the railway and museum operations and its heritage nature.  We have also held several discussions with Council on planning matters relating to the project and individual sites. After these discussions, Puffing Billy were clear that their preferred location was the one put forward to the community.

It is recognised that the location is a sensitive one, and this has been one of the key reasons for why this voluntary consultation with nearby residents has occurred.

We are currently examining alternative locations in the wider area, though whether these will meet coverage requirements, or the other considerations, is still being assessed.

I hope the above information has been of assistance to you.