Stop proposed TPG Mobile Base Station: Community Sensitive Area (Liston Street Glen Iris)

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This is a residential and community area. We object to the proposed development. 

We object to this proposal on several grounds including: inadequate process to consider the Interested and Affected Parties, narrow environmental impact report, uncertain health impacts and high visual impact on the area. 

In addition to signing this petition, also ensure you email: including your reason for objection.  

Summary of the objection points

- Inadequate assessment of what is a Community Sensitive Location

o   Why is this facility being put near homes, children's playground, kindergarten's and schools?

- Inadequate and incomplete environmental impact report

o   Why hasn't there been consideration of the Electromagnetic Energy impacting the Liston Reserve, Glen Iris Childcare, Ashburton Primary or homes?

- World Health Organisation concerns about such facilities

o   What are the long term health impacts of such facilities?

- Evolving research into the health impacts

o   The Radiation Protection Standard does not fully alleviate the concerns about these facilities.

- Visual impact of abnormal construction on the area

o   The new facility will sit nearly 1m above the existing light pole

Detailed assessment of each of the objection points: 

1. Inadequate assessment of Community Sensitive Location:


4.1.5 The procedures must require, as a minimum, that for each site the Carrier have regard to:…

c) the likelihood of an area being a community sensitive location. (Examples of sites which sometimes have been considered to be sensitive include residential areas, childcare centres, schools, aged care centres, hospitals and regional icons);


The Consultation Report States: “On this occasion we have not been able to locate a facility that is not near a community sensitive location due to the area the planned service must cover.”

We consider this a dismissive response with inadequate consideration for the community, rather a priority is given to the commercial interest of TPG.

2. Selective Consultation Process / Consultation Guidelines not followed


6.3.1 In developing a consultation plan for a site the Carrier must endeavour to meet the objectives of:

(a) identifying and informing Interested and Affected Parties of the proposed project;

(b) maximising the level of accurate and accessible information about the project to Interested and Affected Parties;

(c) using its reasonable endeavours to identify community sensitive locations; and

NOTE: Examples of sites which sometimes have been considered to be sensitive include residential areas, childcare centres, schools, aged care centres and hospitals.

D Consultation Guidelines D.2.1 States:

At an early stage in the planning process, the Carrier is required to undertake a stakeholder analysis to identify who the Interested and Affected Parties may be and the potential for concerns to be raised about a particular proposed facility. The greater the likelihood for concern, the greater the extent and nature of the consultation with stakeholders that is required.


It is our view that three areas that would be impacted and that have not been notified of the proposal as an Interested and Affected Party, include Ashburton Primary School, Glen Iris Childcare and Kindergarten and users of Liston Street Reserve.

We do not consider this to be an open and transparent approach to stakeholder management.

3. Inadequate and incomplete Assessment impact report

The document: “A Guide to the Environmental EME Report” states:

The industry Code requires the mobile network companies to take account of community concern about locations of particular interest, such as places where children spend a lot of time, or multistorey residential buildings facing the antennas. The table 'Calculated EME levels at other areas of interest' on the report provides additional estimates of EME levels at a small number of such locations….. It is expected that for an average report, there may be 3 to 5 additional areas of interest calculations.


As a result of not including the afore mentioned Interested and Affected Parties, the report does not provide an Calculated EME Levels for any of the other related community areas where children spend a lot of time including Ashburton Primary School, Glen Iris Childcare and Kindergarten and users of Liston Street Reserve. This report only includes 1 estimate of EME levels at Rowan Street Kindergarten. In our view this highlights, again the desire for expediency rather than true community consultation.

The document: “A Guide to the Environmental EME Report” states:

Commonly, wireless base stations are located on a high point and the assumption of flat ground provides a worst-case estimate for these situations. Sometimes, however, the ground may slope upwards away from the base station and this can cause concern that levels may be higher than calculated. In these cases the 'Calculated EME levels at other areas of interest' table should include the levels of EME at a selection of heights where maximum levels are expected.


The proposed location is not on flat ground. The difference in Elevation levels in the related areas, per are:

- From the proposed Site to Vears Road: 58m increasing to 64m

- From the proposed Site to Glen Iris Childcare and Kindergarten: 58m increasing to 83m; and

- From the proposed Site to Ashburton Primary: 58m increasing to 70m.

The Environmental report does not include an analysis of EME levels at a selection of different elevations. This again highlights a disregard for the guiding documents that have been prepared to address community concerns, but rather a narrow, cursory and expeditious review of the proposed location. 

4. World Health Organisation - Lifestyle Adjustments

The World Health Organisation’s advice on electromagnetic fields and public health with respect to mobile telephones and their base stations (fact sheet 193 June 2000) includes the following precautionary measures:

Individuals: Present scientific information does not indicate the need for any special precautions for use of mobile phones. If individuals are concerned, they might choose to limit their own or their children’s RF exposure by limiting the length of calls, or using ‘hands-free’ devices to keep mobile phones away from the head and body.

More recently Lyon, France, May 31, 2011 ‐‐ The WHO/International Agency for Research on Cancer (IARC) has classified radiofrequency electromagnetic fields as possibly carcinogenic to humans (Group 2B), based on an increased risk for glioma, a malignant type of brain cancer1 , associated with wireless phone use.


Whilst inadequate in its suggestions for individual “precautionary measures”, specifically relative to base stations, this would suggest as a resident adjust they way they enjoy and use the area if we are cautious about our children’s lives. This is an unacceptable outcome.

5. Health Impact: Evolving Research

The document “RADIATION PROTECTION STANDARD, Maximum Exposure Levels to Radiofrequency Fields — 3 kHz to 300 GHz” states:

There is currently a level of concern about RF exposure, which is not fully alleviated by existing scientific data. It is true that data regarding biological effects, at levels below the limits specified in the Standard, are incomplete and inconsistent. The health implications for these data are not known and such data could not be used for setting the levels of the basic restrictions in the Standard. Research is continuing in many countries into possible effects on health arising from RF exposure. In recognition of this, the Radiation Health Committee will continue to monitor the results of this research and, where necessary, issue amendments to this document.


Australia’s Inter-governmental Agreement on the Environment (IGAE) notes: ‘Essentially, the precautionary principle offers administrators advice about how to act responsibly in the face of uncertainty and lack of full scientific knowledge. Under this Principle, policy makers are advised to use great care when authorising resource use where the outcomes of that use cannot be predicted with confidence, where one or more of the possible outcomes could have extremely adverse implications for future generations, or where no known substitutes exist for the resource being used.’

I have not seen any longitudinal studies completed on the impact to children from sustained and continual EME exposure. Given the relatively early stages of this technology, the guiding policy suggests caution. Installations in close proximity to residential, community and educational facilities seems irresponsible and unnecessary.

6. Visual Impact / Property Values / Misrepresentation / Abnormal

“Figure 2” of the letter dated 15 October from Site Logic, shows an example of a small cell facility being attached half way up the existing light pole. 


This Figure 2 is misleading. The Site Elevation and Set-Out Plan indicates the proposed installation would site 775mm above the top of the existing United Energy Pole, as shown in the cover picture of this petition. 

This proposed lay out is inconsistent with all the other proposed sites TGP is reviewing in the area. We suspect this has been done to increase the elevation due to the gradient of the road, further highlighting the inappropriateness of the site.

Having such a prominent and abnormal feature attached to the top of the light pole will have a material impact on surrounding property values and highlights that no effort has been made to blend the facility in with the existing surrounds.


We believe that due process has not been followed by TPG as we have highlighted by reference to the Code and the Environmental Exemplar Report.

We believe the questions remaining around the health impacts place the residents under unnecessary risk and therefore these facilities are inappropriate to be located near homes or where children congregate.

We believe the proposed developed has been misrepresented in the diagram included in the Letter. We believe the facility is abnormal in appearance and does not fit in to the area, and this will have a clear detrimental impact on the valuations of property in proximity to the structure.

We believe a more appropriate site should be found for this facility.