Dear Mr. Schneider,

the Forum Mobilkommunikation is the Austrian Mobile Operators´ Association. I am writing to you in my capacity as Managing Director following the public hearing on electromagnetic hypersensitivity in Brussels on Nov 4, 2014.

Activists have for some time now been claiming that Austria, especially the provinces Styria and Salzburg, have imposed EMF limits significantly below the internationally accepted WHO and ICNIRP limits. After the hearing held by EESC on November 4, 2104, we feel it most urgent to clarify this issue:

Any claims that there are stricter limits than ICNIRP in Austria are false.

Austria has imposed the WHO/ICNIRP limits for the protection of the general public from radiofrequency EMF without any deviation from the recommendations by the WHO, ICNIRP and EU Council.

The above mentioned activist claims refer to the so-called 'Salzburg Milliwatt' of 1 mW/m² (as compared to 4.5 W/m² or 10 W/m², depending on the radio frequency of mobile telecommunications, as defined by ICNIRP). The 'Salzburg Milliwatt' is not a legally binding framework in Austria. Even the council of the City of Salzburg itself has publicly stated that this value does not exist („Salzburger Nachrichten“, 22.4.2005)

The Austrian operators have always maintained that it is not possible to build a nation-wide network coverage – especially in urban areas under the restriction of a value at the level of the 'Salzburg Milliwatt'. Several measurement series are proof to that (e.g. the measurement campaign in the City of Salzburg that was conducted by the Swiss government

( ).

A full documentation on the history of the „Salzburg Milliwatt“ can be found on our homepage:

We also want to take the opportunity to comment on a „guideline“by the Austrian medical chamber for „diagnosing and treating the EHS syndrome“.

The Austrian medical chamber is a national interest representation of MDs in Austria with mandatory membership for doctors. The chamber´s advisor for environmental issues is Dr. Gerd Oberfeld/Salzburg.

In March 2013 this guideline could temporarily be found on the ÖÄK´s homepage. The guideline gave a curriculum for diagnosis and also suggestions for treatment - of a condition which the WHO in its Fact sheet 296 does not acknowledge ( ).

WHO clearly states that

„the condition EHS is characterized by a variety of non-specific symptoms that differ from individual to individual. The symptoms are certainly real and can vary widely in their severity. Whatever its cause, EHS can be a disabling problem for the affected individual. EHS has no clear diagnostic criteria and there is no scientific basis to link EHS symptoms to EMF exposure. Further, EHS is not a medical diagnosis, nor is it clear that it represents a single medical problem.“ Further, it addresses physicians: „Treatment of affected individuals should focus on the health symptoms and the clinical picture, and not on the person's perceived need for reducing or eliminating EMF in the workplace or home“.

As causality between EMF and EHS is the central issue and could not be demonstrated in clinical studies (cf. eg the meta study by Oftedal, Rudin, Hillert and van Rongen which was partly financed by COST BM0704), we feel it being a major point of concern should the EECS deviate from the WHO in its assessment of EHS and suggest measures like the introduction of EMF limits which deviate from the WHO limits. This would undermine not only the validity of the WHO´s protection scheme but cause even more concern in the general public.

Please feel free to get back to us any time for more information on the matter or for any questions!

We will be directing this letter also to Mr Bataller and MEP Sender.

Yours sincerely,

Margit Kropik

Managing Director

Forum Mobilkommunikation