Written for Dr Peter Brookes to submit to the Court of Appeal
in the Harrogate case (January 2005).
In Sir William Stewart’s report page 113, frequencies between 300 MHz and 300 GHz are defines as microwaves. This is in line with the International Commission’s definition of microwaves as defined in 1998. Therefore everything discussed in this report is in the microwave frequency.
Microwaves react
very differently in our water-based bodies to radio waves. The term ‘Radio
Frequency’ is often used to describe microwaves based communication
systems. It is important that the term
‘Radio Frequency’ is not associated with Radio Waves, but associated with
microwaves. Microwaves are used by the communications industry because they are
more penetrative than radio waves.
The Stewart
Report 2004 asks that anecdotal evidence be taken seriously in the absence of
long-term epidemiological studies, concerning illnesses around the area of
mobile phone transmitters. Such anecdotal evidence produced July 2002 refers to
92 cases of cancer around just 19 mobile phone transmitters. Other illnesses on
the same paper refer to breast cancers, thyroid, bowel and blood problems. Another report dated November 2003 titled
‘School References (school and cell tower antennas)’ from 138 schools lists
miscarriages, brain tumours, cancers, breast cancers and teachers ill within
this report. One single school had
transmitters on its roof in the Saint-Cyr-l’Ecole quarter of France where 8
cases of cancer were confirmed among children in the district. Common sense dictates that if you surround
the school with mobile transmitters, the children will be able to use their
mobile phones in school; this obviously exacerbates the problem of surrounding
the children with microwave radiation.
The Stewart
Report on page 63, section 4.1.1 recommends… RF fields to which the public will
be exposed will be kept to the lowest practical level that will be commensurate
with the system….
The same page
the Stewart Group recommend. Base Stations sited within school grounds that the
beam of greatest intensity should not fall on any part of the school grounds or
buildings without agreement from the school and parents. Similar considerations should apply to macro
base stations sited near school grounds.
Professor Gerd
Oberfield of the Environmental and Resource Studies Programme, Trent
University, Ontario, Canada, published a report dated November and December
2004, titled “Putting Cell phone Antennas near schools is too Risky”. This
report states: with respect to negative health effects on people living in
close proximity to cell phone towers, there are three different epidemiological
studies including our recent study. All of them found statistically significant
relationships between exposure to radiation and health effects. Two of the studies did measurements in
subject’s bedrooms and found significant increases in stress related symptoms
as well and neurological symptoms…. Also
depression, fatigue, sleep disorders and concentration difficulty were found. These symptoms were related to exposure
levels, not distance from the antennas.
A recent research project called EU-Reflex or European Union Risk
Evaluation of Potential Environmental Hazards from Low Frequency
Electromagnetic Field Exposure using sensitive in Vitro Methods shows that
cells exposed to cell phone radiation exhibit chromosomal damage well below the
exposure guidelines of the W.H.O.
It is worth
mentioning that the ICNIRP Guidelines also the NRPB Guidelines are based purely
on the thermal effect of the waves. No
account what so ever is given to the effect of the electric and magnetic of the
wave interacting with the physiology of the body. The WHO’s Guidelines are based on the short-term effects of this
radiation. No long-term experiments have been done in terms of safety
levels. Further, no experiments have
been done to determine the safety levels from the pulsed microwaves exhibited
by all microwave communication systems.
Professor
Oberfield’s report concludes…as a general rule cell towers should not be placed
near schools.
The recent
Stewart Report on page 31, states: ‘Where a base station is to be installed
near a school or college, local consultation is also required prior to the
submission of an application for Planning Permission’. Page 53 continues…we also recommend that the
mobile phone industry should refrain from promoting the use of mobile phones by
children. Placing mobile transmitters in the vicinity of schools cannot
discourage the use of mobile phones by children. Only this last Christmas the German VERUM group which consists of
twelve research groups from seven countries, concluded that mobile phones cause
DNA damage. It can be argued that as
responsible adults in charge of Planning, giving the opportunity to children to
use mobile phones, some responsibility MUST fall on the Planners for the
scientific ignorance of the children.
Referring back
to semi-scientific and/or anecdotal evidence concerning masts, at this present
time in Osafia, Israel in the last four years, 165 people have died of cancer
from living in the vicinity of antennas. This has now become a legal case.
Scientific
research by Dr. John Walker has highlighted cancer clusters within the
‘footprint’ of base station transmissions. Coloured photographs of cancer
clusters can be found in the main part of base station beams. Theoretically,
looking at this research, which has covered several transmitters, it should be
possible to predict future cancer clusters.
Dr. Walker’s research is on the Internet.
General
practitioners in Naila examined the medical histories of nearly 1000 patients,
searching for link between the distance of the patient’s living quarters from a
long-standing mobile phone base station and the incidence of cancer. The physicians distinguished between an
inner circle, within a 400m radius from the tower, and the area outside
it. Tumours were found in patients
living within 400m of the base station three times more frequently than among
patients living outside.
The result of the Naila study, November 2004 shows that the proportion of newly developing cancer cases was significantly higher among those patients who had lived during the past 10 years at a distance of up to 400 m from the transmitter site, and that the patients fell ill on average 8 years earlier.
A similar study
from the National Institute of Sciences (Professor Santini) showed from a study
of 270 men and 260 women less than 300 m from a transmitter, showed signs of
nausea, loss of appetite, visual and motor problems. Less than 100 m the symptoms were irritability, depression,
concentration problems, memory dysfunction, dizziness, libido problems, headaches, sleep and skin problems.
The highly
respected Professor Olle Johansson in his 2004 paper ‘Malignant melanoma of the
skin – not a sunshine story’ states that women seem to be more susceptible to
these electromagnetic waves than men. Possibly because of the influence on
hormones within the body he concludes ..”we believe this environmental factor
to be radio frequency, electromagnetic radiation which is capable of affecting
the proper function of cell repair and auto immune system mechanisms”.
In an earlier
paper Professors Hallberg and Johansson – ‘Cancer Trends during the 20th
Century’. These Professors studied the
cancer rates before and after telecommunication systems were introduced into
different countries. They found after the introduction of the systems the
cancer rates increased. They
conclude….breast, bladder, prostate, lung, colon and cuteaneous melanoma
cancers are all associated with each other….relate melanoma to radio frequency
EMF.
It continues,
Estonia had a steep increase in the cancer mortality in 1991, the year that the
western FM radio frequencies were allowed and introduced all over the
country. This report was published in
the Australian Journal of Environmental Medicine, Volume 21, No.1, pages 3-8
(April 2002).
An argument
often given against protestors is that cancers cannot develop in under 10
years, therefore all recent cancers cannot be caused by the telecommunications
industry. There are many published
research papers showing that electromagnetic waves may act as both cancer
promoters and initiators, for example:
Lyle et al 1983
…Hence EMR appears to be both a cancer initiator and a cancer promoter which
also enhances progression. In this way the similarity with cigarettes is quite
strong.
Adey 1992…. Many
papers give evidence of EMR as a cancer promoter.
Hagmar et al
1994 ….Microwaves have also been shown to potentize cancer initiators…with exposure
to GSM digital base stations…. hence EMR is implicated in increasing cancer
rates in exposed populations.
The safety
levels set by ICNIRP and the NRPB are the highest in the world. Being thermally based, it is very unlikely,
if not impossible for any person to receive the warming of the body to exceed
their safety levels if this person is not sitting right on top of the mobile
phone transmitter. As an example of safety levels in units of Microwatts per
cm², our maximum levels for 400, 900 and 1800 MHz transmitters are 2640, 3300
and 10,000 of these units. By contrast Russia and China have a total maximum of
10 of these units, Toronto has a maximum of 6 and Salzburg has a maximum of 0.1
of these units.
Clearly if you
were going into a chemist’s shop and the chemist said ‘you may take either
10,000 pills or 1/10th of one pill there would be confusion. That is
how ridiculous these safety levels look to the rest of the world. Professor
Vladimir Binhi of the Russian Academy of Sciences was asked why their safety
levels were so low. He replied ‘In Russia we have experience of what can be
achieved by using radio frequency radiation. So we know what we think is needed
to avoid adverse health effects’.
It is published that in Sweden, 3.15% of
its population is medically recognised and registered as being handicapped from
electro-sensitivity. This number is comparable in California and it is believed
Australia. If this number were compared with the population of the UK, roughly
1.8 million people are electro-sensitive.
Electro-sensitivity is best described rather like a food allergy that
can only get worse the more you are exposed to it.
Interestingly, a
High Court Judge ruled in the case of Yasmin Skelt –v- The First Secretary of
State and Three Bridges District Council and Orange PCS Limited that…. reliance
on ICNIRP Certification is not enough.
Whilst our
Government and its Scientists are keen to promote the knowledge of their
scientific advisors, they only represent a small proportion of the scientists
in the world, making judgements on safety levels.
For
example: The June 2000 International
Conference at Salzburg consisted of 19 of the world’s top scientists in this
field and they set the level already given as 0.1 of our units. It can be
argued that the more power given to the companies to ‘pump out’ the more profit
they can make. It could also be argued that as the Government has a huge
financial stake with this industry, the Government cannot be unbiased in its
decision making processes.
NRPB and ICNIRP’s safety levels are based
purely on thermal effects. Looking at scientific papers, most of the rest of
the world disagrees with this assessment.
Doctor Cletus Kanavy, Chief of the biological effects group of the
Phillips Laboratory’s Electromagnetic Effects Division at Kirkfield Air Force
Base in New Mexico, says ‘Large amount of data, both animal, experimental and
human clinical to support the existence of chronic non thermal effects….these
include behavioural, neural, foetal, blood, metabolic, endocrine and immune
problems.
Professor John R Goldsmith who holds 11
Professorships, WHO Officer for Europe
and International Consultant for RF Communication, possibly the world’s leading expert in this field (now deceased),
wrote in his paper ‘The End of Innocence’
‘to use the lack of significant heating effect as evidence of lack of
risk is the red herring’
During September 2002 at the University
of Vienna, 19 of the world’s top scientists met to discuss electromagnetic
waves. This was known as the Catania Resolution. They stated ‘we take exception
to arguments suggesting that weak, low intensity EMF cannot interact with
tissue. There are plausible mechanistic explanations for EMF induced effects
which occur below present ICIRP guidelines and exposure recommendations by the
EU.
In a confidential note to its military
personnel in March 1976, document number DST-181OS-074-76 states ‘personnel
exposed to microwave radiation below thermal effects experience more
neurological, cardio-vascular and haemodynamic disturbances than do their
unexposed counterparts. This document
from the US Defence Intelligence Agency continues to warn personnel of
headache, fatigue, dizziness, menstrual disorders, sleeplessness, depression,
anxiety and so on.
Professor Adey, a Fellow of the American
Academy of Scientists and a distinguished visitor of the Royal Society of
Medicine said ‘of his own research in parallel with similar studies in Russia in the early 1980’s showed
that radio frequency and the lower microwave range affected enzyme systems that
regulate growth and division of white blood cells.
Clearly there is experts’ world opinion
both military and from Universities showing that radiation below thermal
effects can impinge on our physiological functions.
Pulsing
It should be noted that whilst
professional bodies have noticed the effects of pulsed microwaves on the
physiology of the body, no safety levels exists for pulses microwave
radiation. All mobile communication
systems pulse in some way.
Sometimes academic arguments arise where
the word ‘pulsing’ is not used and a word like ‘modulated’ substituted. Theoretically, there can be very little
difference between a modulated wave and a pulsed wave.
The Health Council of the Netherlands
Radio Frequency Radiation Committee say in their 1997 report, page 134
concerning frequencies of 300 Hz to 300 GHz…. ‘The experimental data indicate
that the effects of EM fields occur at lower power densities when the object is
exposed to pulsed electromagnetic fields. In other words the illnesses already
reported, you will get quicker if the microwaves are pulsed. The Freiburger Appeal on the 9th
October 2002 signed by approximately 2,000 doctors and scientists says ‘One can
no longer evade these pulsed microwaves. They heighten the risk of already
present chemical/physical influences, stress the body’s immune system and can
bring the body’s still functioning regulatory mechanisms to a halt. Pregnant
women, children, adolescents, elderly and sick people are especially at risk.
Professor Salford at Lund University in
Sweden has shown in his work in the year 2000 that pulsing can alter the
permeability of the blood/brain barrier in rats. If occurring in humans, this could have profound effects on brain
function.
In terms of planning, I wonder whether
encouraging the use of mobile phones in an around children would not have a
detrimental effect on their concentration levels during the school day.
The Accumulative Dose
Professors Sosskind, Provsnitz, Lai,
Cherry and a Russian International Medical Commission have all warned about the
cumulative effect of these microwaves.
This is not surprising; a property of the
electromagnetic spectrum is that these waves are accumulative.
If we go out on a cloudy day we can still
get sunburned, it just takes longer, slow cookers work on the same principal.
Professor Sosskind and Provsnitz write
‘an accumulated cellular level damage mechanism is not necessarily related to
the intensity but can relate to total dose’.
In their report ‘Mobile telephones, their
base stations and health’ from the
French Health General Directorate January 2001, they warn of the cumulative
exposure over the lifetime of a child.
This body conclude with an interesting
sentence stating ‘biological effects occur at energy levels that do not cause
any rise in local temperature’ It can
be argued that biological effects may not be hazardous but beneficial. It could
also be argued that the responsibility for this decision concerning children
should lay with the parents, guardians or those in loco-parentis and not the
Planners.
3 G
The new breed of 3 G masts appear to be
particularly alarming.
The wave lengths of these microwaves are
roughly 14 -15 cm. This is roughly
6”. It can be argued that any part of a
child’s anatomy – head or organ exposed to these waves will act like an aerial
and resonate with the frequency. This is how aerials work and as we are
water-based or fluid based, resonance could occur in these organs or bones, in
particular bones containing marrow. The
power a child would receive at 30m from a 3G transmitter would be roughly 2
micro Watt per cm² and at 100m roughly 0.2 micro Watt per cm².
Professor Hocking in 1996 wrote that a
twofold increase in childhood leukaemia could arise from RFR at 0.2 micro Watt
per cm². Similarly, Kolodynski in 1996
said that motor function, memory, attention problems may occur at 0.1 micro
Watt per cm².
The new 3 G transmitters also have a
higher frequency than most mobile transmitters. This higher frequency comes
with more energy. It can be argued that the symptoms of ‘microwave sickness’
will arise more quickly from children if these transmitters are certainly at
these powers near schools.
The two papers previously mentioned show
that at 100m the children are twice the level argued by Kolodnyski and at 30m
20 times this level.
It can be argued by the Planning
Authorities that children are only in school a few hours a day and do not
receive long term exposure. This
argument is flawed in so far as children are really everywhere and the
transmitters are quite capable of penetrating their bedrooms and play areas.
The Government
The Stewart Report 2004, Section 9
states: ‘Within the UK there is a lack
of hard information showing that mobile phone systems in use are damaging to
health. It is important to emphasise this crucial point’ It can be argued that every time scientific
evidence is produced or MPs try and bring up this issue in Parliament, the Government’s
response is usually the same and that is ‘We would need to replicate this
experiment’, which generally means finding funding which can take a few years,
repeating the experiments which can take up to
10 years and then having it published, which can take another couple of
years. Another ‘stock answer’ when complaints are broached towards the
Government, it is said ‘our transmitters are within Government
Guidelines’. This of course means that
you won’t get too warm near the transmitter and nothing else.
In the same report, paragraph 4 ‘The UK
Government has given strong encouragement to the development of mobile phone
technology’. With respect to the
science, Michael Meacher, Minister for the Environment 1997-2003 wrote, which
was published in The Times:
‘Our Universities eye the donor as a
potential source of funds and try to ensure nothing is said which might
jeopardise big new cash possibilities.’
Academics who raise embarrassing questions –
-
Who is paying for the Lab?
-
How independent is the peer review?
-
Who profits from the research?
-
Is the University’s integrity
compromised?
Soon learn that keeping their heads down
is the best way not to risk their careers, let alone future funding. The message is clear, making money is good
and dissent is stifled.
Similarly in the science magazine,
Scientific American May 2004, Congressman Henry Waxman wrote an article saying
roughly the same of the American Government.
Published in the International Ecologist
Science & Technology section, June 2004, they write ‘You will hear
statements by supposed experts, always the same few in the pay of the
telecommunications industry, to the effect that cell phones, cell towers,
microwave radiation have been proved safe in countless studies. It is an easy
lie, one that the news media have been eager to propagate. Such studies don’t exist. Quite the contrary, it has been shown that
just as for X-rays there is no safe level of exposure to microwave radiation.
In Parliament on 28th January
2004, 20 pages of questions and answers were printed with respect to MP’s
complaining about their constituents ill-health from mobile phone transmitters.
At the end of all this the Minister
replied ‘UK/ICNIRP Guidelines are based on a comprehensive assessment of
current scientific knowledge’. It could
be argued that this is very selective current scientific knowledge and not a
wide based review of research from around the world.
This topic was again brought to
Parliament on 10th June 2004, and again dismissed.
On 21st May 2004 again MP’s tried to bring up this
debate in Parliament. In Hansard,
Section 1245 concerns illnesses of school children and reports on what the MP’s
describe as sensible people. Section
1247, again covers children where in one case 11 children under the age of 11
have leukaemia within the vicinity of a transmitter and Section 1258, the
Stewart Report is quoted as saying ‘The beam of greatest intensity should not
fall on any part of the school grounds or buildings, without agreement of the
school or parents’.
Again it appears that despite the efforts
of many MP’s, transmitters are still being allowed to be erected near schools.
Reported in the Sunday Herald, 4th
July 2004 Doctor Keith Baverstok who was the WHOs senior radiation advisor in
Europe says that science has been perverted for political ends by Government
Agencies which should be protecting public health.
He continues ‘Politics, aided and abetted
by some in the scientific community has poisoned the well which sustains
democratic decision making’.
He accused the NRPB of mis-using science.
It could be argued that there appears to
be no democratic decision making process in where masts are to be sited. If a community does not want a mast, it
appears that this community has to take on the communications industry, the
Planning Department and the Government in order to win their case. As the onus is on the community to prove
that the mast is dangerous and expenses can run at £140,000 a day, it appears
not surprising that both the Government and the industry are getting their
way. It also appears that challenging
this ‘super giant’ is futile. The question then is – Is this Democracy?
Legal Responsibility
It was reported in the Saturday Mail,
January 22 2005, that when a transmitter was erected outside a house £50,000
was instantly wiped off its value. If we look at these implications across the
country, many billions of £’s must be wiped off the value of houses. The question of course is, who is
responsible for this? Further
complications must arise where Planning Permission is not required. It could be
argued that legislation should be brought about whereby responsibility is
attributed to a named ‘body’.
The Stewart Report 2004, Section 3.0
states ‘It is important that as the Networks develop there is a need for
clarity in terms of legal responsibilities and regulations’….
An interesting legal argument can be
based on the countries that have over 3% of their population’s
electro-sensitive. By association, it could be argued that 3% of this
population must also be electro-sensitive.
Electro-sensitivity is written about in
the Stewart Report on page 34.
Interestingly, the Children’s Act 1989, part 3, section 17, places a
legal obligation to protect children from a ‘perceived risk’. This risk does not have to be real, it could
be argued that 3% of our children could be electro-sensitive and therefore
should be protected from the harm, supposedly caused by microwaves from base
stations.
Also the 1993 UN Directive for
Handicapped People, states that they must not be disadvantaged. This argument
then may follow that electro-sensitive children cannot be ignored as they have
a disability. Clearly, it could be
argued that the mobile industry, by introducing such children to their
microwaves; if the children are
suffering; are breaking the law.
In the Court of Appeal on November 13th
2003, the Court spelled out the duty of care resting on the landowner/occupier
of land in respect of activities which he permitted or encouraged on his
land. See Bottomley –v- Secretary and
members of Todmorden Cricket Club and others.
An interesting argument is :
-
Who are the landowners?
-
Do they have full Insurance Indemnity in
writing?
-
Would this Indemnity cover medical
illness for several children for the rest of their lives?
Mr Wulf Dietrich Rose, expert in mobile
communications of Kitzbühl, Austria, internationally known for his research
works in this field, won his Court case for the third time on 26th
April 2001. He proved, through his
studies and researches that mobile radiation represents serious health risks to
the nearby living populations like cancer, brain tumours, genetic problems and
deformity of newborns.
In this country Appeal Decision
APP/U1105/A/04/1137356 concluded that a mast be refused because of … ‘Likely
effects of the project on the health of local people’
In 1998 a Court of Appeal Decision found
that ‘Genuine public fear and concern is a material planning consideration even
if the fear is irrational and not based upon evidence’ – see Newport BC –v-
Secretary of State for Wales 1998 JPL 377.
An interesting statement made on 7th
June 2004 by Australia’s leading Neuro-Surgeon Dr Charles Teo stated that he has seen a 21% increase in
children’s brain tumours over the past few years. Dr Teo issued a warning on national TV for parents to be aware.
It is his opinion that there is a connection between EMR and the development of
brain cancer.
Birmingham City Council Planning Department on 5th January 2004
wrote : ‘I believe that there is a pressing need for urgent further research
into the health aspects of telecommunications developments together with a
review of the existing guidance and regulations on how such proposals should be
considered’. It was signed by Mr Jones,
Chief Planning Officer.
It may be possible that under the Human
Rights Act a person’s human rights may be infringed by the sighting of a mast
or base station. In so far as the individual’s right of privacy and to quiet
enjoyment of the home. Re: The Right of Privacy, Article 8 (2).
UK Case Law also makes it clear that the
perceived risk to health need not relate solely to radiation but the stress
caused by the actual installation of the mast.
It could be recommended that for in-depth
knowledge of this subject, expert legal counsel should be consulted. With reference to Insurance Indemnity, it
is worth checking the policy of the landowner. For example: One company excludes any legal
responsibility with regard to :
-
Personal damage
-
Illness
-
Disability of any type
-
Death
-
Mental illness
-
Anguish
-
Mental or physical pain
-
Mental or physical deterioration
-
Mental or physical disorder
-
Any mental or physical disability
-
Any symptoms caused or said to have been
caused by or attributed to the continuous use of mobile telephones.
It could be argued that if you are
placing a transmitter near a school, you are encouraging children to use mobile
telephones.
It could be argued that Planning
Authorities, the Government and the Government Scientists are immune from
prosecution because the only ill effects they will recognise are from excess heating.
It could also be argued that the insurance companies have not made this
comprehensive list of illnesses just for something to do. Their information must be based on worldwide
research covering effects below our Government’s guidelines.
Miscellaneous Evidence
There is a plethora of extensive, well
researched documents highlighting illnesses caused by microwave sickness around
the world. These papers (in their
thousands) highlight the illnesses caused by low level (below thermal)
microwaves as:
-
Arrhythmia
-
Heart attack
-
Cell death
-
Diseases of the blood
-
Interference to bone marrow
-
Brain tumours
-
DNA damage
-
Altered Calcium level in cells
-
Reduction in night-time Melatonin
-
Suppression of the Immune System
-
Arthritis
-
Rheumatism
-
Skin problems
-
Lymphatic diseases
-
Vaginal discharge
-
Vascular system disease
-
Tinnitus
-
Leukaemia
-
Childhood cancer
-
Sleep problems
-
Mental problems involving depression,
irritability, memory loss, difficulty in concentrating, headache, dizziness and
fatigue, suicidal tendencies, miscarriage and infertility.
Clearly, this is the work of thousands of
overseas scientists, although some are in this country, but below thermal
effects, none of these illnesses will be accepted by our Government and its
scientists.
It can often be argued that these
illnesses are psychosomatic i.e.: when a neighbourhood sees the erection of a
mast, any illness they get is instantly blamed on that mast. Or,
psychologically the mast is reported to cause the illnesses.
However, an argument against this are the
many cases where masts have been erected without local knowledge and these
illnesses still occur.
There are some 40 farm studies where
animals have been affected by masts on their land, and once removed, have
recovered. When the animals return they
instantly become ill again.
Other studies show effects on the
migratory patterns of birds and even insects. Peer reviewed and published works
show that plants (trees) can stop growing when exposed to long-term low level
microwaves.
It could be argued that everything in
this report need to be considered very seriously before the sitting of a mast
or masts close to schools, residential areas, nursing homes, nurseries and
hospitals.
A solution to this problem is not so much
where the masts are sited but the power transmitted. If the power transmitted were at the Salzburg level, this would
instantly seem more acceptable to the scientific community opposing masts.
The implication of this would probably
mean less profits for the mobile industry and mobile phones would not work
inside houses. However, mobile phones would work outside houses and open fields
where children are thought to be at most risk from danger and/or accident.
Signed:
________________________________________
Date: ____________________
B. Trower
3 Flowers Meadow
Liverton
Devon
TQ12 6UP
Tel: 01626 821 014
My work is done entirely free of charge
and I have never accepted money from any person or organisation in the years I
have been doing this research.
I consider myself absolutely independent.
All of the documents I have mentioned
(enough to fill a suitcase) I am prepared to bring to any Planning Office free
of charge, should they wish any photocopies.
The last time they were photocopied it took about 6 hours.